ML20249A772
| ML20249A772 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/15/1998 |
| From: | Katz P BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-317-98-02, 50-317-98-2, 50-318-98-02, 50-318-98-2, NUDOCS 9806180218 | |
| Download: ML20249A772 (4) | |
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e Curun.s II. Carst:
Italtimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Vice President 1650 Calvert Cliffs Parkway Nuclear Energy 1.usby, Maryland 20657 410 495-1455 June 15,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to NRC inspection Report Nos. 50-317/98-02 and 50-318/98-02 and Notice of Violation
REFERENCES:
(a)
Letter from Mr. L. T. Doerflein (NRC) to Mr. C.11. Cruse (BGE), dated May 14,1998, NRC Region I Inspection Report Nos. 50-317/98-02 and 50-318/98-02 and Notice of Violation This letter provides Baltimore Gas and Electric Company's response to Reference (a), which identified one violation. The violation cited has been addressed as specified in the Enclosure to Reference (a). The response to this violation is provided in Attachment (1).
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
/
dec d-CHC/JKK/ dim I;
Attachment:
As Stated cc:
R. S. Fleishman, Esquire II. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC d'i 0 \\
S. S. Bajwa, NRC R. I. McLean, DNR A. W. Dromerick, NRC J.11. Walter, PSC j-9806180218 900615 PDR ADOCK 05000317 G
ATTACIIMENT (0 I
I RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-02 & 50-318/98-02 Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant June 15,1998
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ATTACIIMENT (1)
NRC INSPECTION REPORT NOS. 50-317/98-02 AND 50-318/98-02 10 CFR [Part] $0, Appendix B, Criterion X111, "11andling, Storage and Shipping," requires that when necessary to prevent deterioration, protective environments be specified and providedfor storage of equipment. *rhis criterion is implemented by BGE Quality Assurance Policy 1B.13, flandling, Storage, and Shipping. BGE Vendor Technical Manual Number 37708J, " Woodward EG-B10C Governor,"
Section IV, " Storage," states that Woodward governor units are to be protected against rust and contamination byfilling the governor to the top with lubricating oil and reinstalling the shippingplugs if storedfor more than 90 days before installing.
Contrary to the above, as ofMarch 25,1998, a protective environment was not specified and provided for storage ola Woodward Governor. Specifically, a governor was storedfor periods in excess of 90 days, including an approximate 10 year period, without beingfilled with lubricating oil. When the governor was placed in service on March 25,1998, itfailed to operate as designed, which contributed to exceeding a diesel generator technical specification limiting conditionfor operation.
I.
ADMISSION OR DENIAL OF TIIE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
II.
REASON FOR THE VIOLATION The causes of this violation are as follows:
A. A failure of Procurement Engineering and Warehouse personnel to identify the need to perform specific In-Storage Maintenance (ISM) on Woodward Governors until the ISM program was upgraded in 1997.
B. Failure of the Receipt Inspection Program to require verification that ISM was current on material returned to the warehouse for credit back to stores.
III. CORRECTIVE ACTION THAT IIAS BEEN TAKEN AND RESULTS ACHIEVED A 1997 internal Quality Assurance Audit of Procurement and related activities identified a need to improve ISM practices. The Woodward Governors were identified and included in the scope of the subsequent programmatic upgrade. It could net be determined if the subject governor had been filled with oil in 1997 but it was credited to the warehouse in January,1998, without oil and subsequently issued in March,1998, without oil. The ISM requirements in that time frame required an annual verification of oil level and the installation of protective seals. This ISM was next scheduled to be performed in July 1998. The Calvert Cliffs Nuclear Power Plant ISM program, and more specifically, in-storage preventive maintenance activities applied to the governor, were derived from Electric Power Research Institute guidelines and vendor technical manual recommendations by Procurement Engineering (the responsible design organization) personnel.
A. Procurement Engineering and Warehouse standards, as they relate to vendor-supplied information, were evaluated. This programmatic e'.aluation included an engineering review of existing material and equipment stored by type and resulted in the creation of documented ISM requirements for over 100 stock items. The evaluation utilized vendor technical manual recommendations, as well as Electric Power Research Institute Report NCIG-18 " Guidelines, 1
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ATTACilMENT (1)
NRC INSPECTION REPORT NOS. 50-317/98-02 AND 50-318/98-02 for Determining in-Storage Maintenance of Items for Nuclear Facilities." 'Ihe program also specifies a review to develop ISM requirements for all new materials added to stock. Three procurement standards have been revised and were effective as of June 1,1998. Training for these revisions was conducted with Procurement Engineering and Warehouse personnel.
B. The failed governor was returned to the original equipment manufacturer for a root cause analysis. Results of this analysis have yet to be received.
C. The specific ISM data sheet for the governor was reviewed and determined to reflect vendor j
I technical manual requirements. The periodicity for this ISM has been revised to 90 days.
D. Warehouse Receipt inspection standards were revised to require that the ISMS are verified to be current upon crediting material from the field back into stock.
E. A review ofISM material credited back to stock indicated that two items required ISM. Both items have been verified for ISM and are now current.
These corrective measures will result in proper identification of OEM-supplied ISM requirements, documented engineering evaluation of the requirements, and adequate ISM instructions to Warehouse personnel to prevent degradation of similar equipment.
IV.
CORRECTIVE STEPS TIIAT WILL DE TAKEN TO AVOID FURTIIER VIOLATIONS As noted above in Section 111, all corrective actions to prevent further violations t ive been completed.
V.
DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was achieved June 1,1998, when the three procurement standard revisions were completed.
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