IR 05000317/1987099
| ML20248A280 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/30/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248A218 | List: |
| References | |
| 50-317-87-99-01, 50-317-87-99-1, 50-318-87-99, NUDOCS 8906080090 | |
| Download: ML20248A280 (48) | |
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- -ENCLOSURE 2
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, . FINAL SALP REPORT ,
, W U.S. NUCLEAR REGULATORY COMMISSION SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 1
, REPORT NO. 50-317/87-99 AND 50-318/87-99 BALTIMORE GAS'AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT
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ASSESSMENT PERIOD: . SEPTEMBER 1, 1987 - NOVEMBER 30, 1988 BOARD MEETING DATES: JANUARY 17-18, 1989
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SUMMARY OF RESULTS A. Overview Although ' there were consistent areas of strength during this pe'riod and . indications of modest improvement in some other areas, this assessment of licensee performance indicated an overall decline when compared to the last two assessments. Primary contributors to this decline were perceived to be continuing difficulties in the function-ing of the licensee's organization across interfaces, in the flow o communications, both vertically and. horizontally within the organiza-tion, and in .the safety assessment of events and findings to achieve timely resolution of problem Licensee management was not effective in setting and achieving high standards to assure efficient functioning across all organizational interfaces. Although licensee management made concerted efforts throughout' the period, there were difficulties in achieving recogni-
, tion and acceptance of this as a significant problem at the depart-ment and group level. Interface problems contributed to difficulties in control of work (prioritization) and inefficient use of resource Further, insufficient troubleshooting controls led directly t several events and contributed to equipment operability problem Inter and intra-department communications were often weak. The Oper-ations staff often failed to include Engineering in resolution of equipment problems and Engineering did not always involve itself in a substantial and timely manner in the resolution of operating issue Engineering and Maintenance department inconsistencies in specifying, maintaining and applying setpoints led to a plant trip. Ineffective communication between shift supervision and operators and between Operations- and Engineering contributed to events in which a diesel generator was rendered inoperable and in which inappropriate adjust-ments were made to the reactor differential temperature power instru-mentatio Communication breakdowns, when compounded with failures to interface with other departments during problem resolution /
troubleshooting efforts, resulted in some decisions being made uni-laterally, at the working level, without proper supervisory or multi-disciplinary revie Although there were improvements in the licensee's identification of potential problems, good safety assessment of the significance of findings and events was sometimes untimely. For example, the 11cen-see was slow to recognize potentially widespread procedural adherence problems although most failures to follow procedures were self-identified. In several cases, extensive corrective action programs were implemented. However, the licensee lacked good tools for meas-uring corrective action program effectiveness leading to an apparent inability to evaluate the effectiveness of corrective actions.
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Notwithstanding the' problems discussed .above, several ifcensee strengths were evident during the'. period. The licensee's staff is considered to be competent and generally knowledgeable of the plan The Engineering.' organization, although suffering .from weak controls over prioritization and resource scheduling is competent in its dis-cipline areas and performs generally good engineering and design wor Increased' management ' attention to emergency planning was evi-dent and this resulted in improvements in performance during exer-cises. The performance in the security area was exemplary. ~ Success-ful licensee attention to ALARA considerations has consistently led i to low total ~ site exposure . _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _ . _ _ _ _
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, ' Facility Performance Analysis Summary l
Functional Area : Last Period This Period . Trend l Operations 2(Improving) 2 Declining
. Radiological Controls 1 ~1 Maintenance / Surveillance 2 2 - . Emergency Preparedness 2 2 Improving l Security 1 1 Engineering / Technical Support 3* (Improving)/NA 2
- Safety Assessment /
l - Quality Verification NA/2** 3
*'A similar area (Engineering Support) was assessed last perio ** A similar. area (Assurance of Quality) was assessed last perio .
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.. . Unplanned Shutdowns, Plant Trips and Forced Outages Unit 1 Date power Level Root Cause Functional Area 9/11/87 100% Component failure Engineering / Technical Support Description: An RCP surge capacitor failed causing a RCP breaker to -
open. This resulted in an automatic RPS trip on. low reac-tor coolant flo The facility .has had a long standing - , problem with the repetitive failures of these component During this SALP period the licensee completed modifica-tions removing these capacitors from both units and replac-ing them with inductor /05/87 100% Control problems Maintenance / Surveillance with AFW steam driven pumps Description: Control ' problems with steam driven AFW pumps caused con-cerns over their operability. A forced shutdown was neces-sary to meet Technical Specifications action statement requirements and to comply with an NRC confirmatory action letter. The problems apparently resulted from one or more of the following deficiencies: worn control linkages, excessive condensate in steam lines, and use of (possibly) improper type governor buffer spring /11/87 100% Component failure NA Description: During a storm, an electrical arcing fault developed on a main transformer leading to a loss of load automatic reactor tri /14/87 and 11/20/87 66% Forced shutdowns NA to facilitate repairs to transformer Description: Forced shutdowns to facilitate repairs to transformer damaged during above 11/11/87 even ___-____-_____ _ __ _ _ _ - F , ,
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. -Date Power Level Root Cause Functional Area 1/29/88 97% Component failure- Maintenance / Surveillance Description: Forced outage to repair welds on high pressure extraction drain pipin /15/88 89% Personnel Error Maintenance / Surveillance Description,: Improper isolation of feedwater heater level switches-resulted in a: high level indication causing a turbine trip -
and automatic reactor tri /24/88 100% Design Safety Assessment / Quality Verification Description: A fatigue failure in an instrument air line to a main feed-water regulating valve. caused the valve to fail open. The
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turbine tripped on high steam generator level which in turn caused an automatic reactor trip. A poor design led to the failur A relatively heavy ~pressu_re switch was not properly supported. This was identified by Engineering as a potential problem but corrective actions were not taken in time to prevent failur /14/88 100% Procedural Engineering / Technical <
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Weaknesses Support Description: Due to an improperly adjusted set point for low generator stator liquid cooling pressure, a turbine run back oc-curred. Reactor power could not. be reduccd quickly enough and a manual reactor trip was initiated. Set point con-trols did not clearly state whether or not an offset for instrument height correction was include < < i _- _- _ _ _ _ _ _ _ . _ _ _ - _ - _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - - _ _ _
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Unit 2 ' D' ate Power Level Root Cause Functional Area 9/7/87 100% Component failure N/A c Description: Stainless steel tubing in the turbine electro-hydraulic control (EHC) system ruptured due to vibration induced metal fatigue. The unit was manually tripped when closur of turbine main steam valves was imminent due to low EHC pressur /28/87' 40% Component failure Engineering / Technical Support Description: Forced outage to fix un' isolable steam leak on #22 steam generator blow down line. Erosion problems in blow. down lines has been a repetitive proble /22/87 75% Personnel error Maintenance / Surveillance Description: During Control Element Assembly (CEA) surveillance testing, a CEA dropped into the core. A second CEA dropped during follow up troubleshooting due to technician pulling out a control module for the wrong CEA. Two rods in a dropped condition required, by procedure, a manual reactor tri /21/87 100% Personnel error Maintenance / Surveillance Description: During a previous outage the stator frame and rotating shaft of the Permanent Magnet Generator (PMG) for the main generator were not properly aligned. The maintenance crew omitted the alignment procedure because of a mistaken belief that previous work had not affected alignments. A rub developed causing a short' circuit resulting in a loss of load automatic reactor tri /22/88 100% Inadequate Maintenance / Surveillance troubleshooting controls Description: Troubleshooting activities on an inverter. caused a loss of power to a non-vital instrument bus due to introduction of a ground. This resulted in a loss of control power to main feedwater regulating valves and main feed pump speed con-trol circuitry. A manual reactor trip was initiated before automatic trip setpoints were reache I
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Date- Power Level Root-Cause Functional Area'--
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4/27/88- 100%- Unknown N/A-p Description: - Automatic reactor trip on low steam generator level follow--
- ing ' a . trip . of a main feedwater pump. The cause of pumps trip was never positively identified.
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.. \' .I III. CRITERIA ~ ' Licensee' performance is . assessed in. selected functional areas, depending on whether.the facility is in'a construction, or operational phase.. Func-tional areas normally represent areas significant~to nuclear safety 'and '
the environmen Some functional; areas may not be assessed because o little or' no licensee. activities or lack of meaningful:- observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable,.to assess each functional area: Assurance _ of quality, including management involvement and control; 2 .' Approach to resolution of technical issues from a safety standpoint;. s . Responsiveness to NRC initiatives; Enforcement history;- Operational and construction events (including response to, analyses of, reporting'of,'and corrective actions for); Staffing'(includingmanagement);and Effectiveness of training and qualification progra , On' the- basis of the NRC assess' ment, each functional area evaluated is rated 'according to three performance categories. -The definit 4ns of these performance categories are: Category-1: Licensee management attention and involvement are evident and place emphasis on. superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regu-latory requirements. Licensee. resources are ample and effectively used :so that a high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category 2: Licensi.: management attention to and involvement in the per-formance of nuclear safety or safeguards activities is good. The licensee L has attained a level of performance above that needed to meet regulatory " . requi rements. Licensee resources are adequate and reasonably allocated so' g that good plant and personnel performance are being achieved. NRC atten- ' = > tion should be maintained at normal levels.
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.. Category 3: Licensee management. attention to and involvement in the per-formance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that. needed to meet minimal regulatory requirements. Licensee resources .' appear to ' be strained or not effectively used. NRC attention should be increased above normal-level ~ The SALP Board may assess a functional area to compare the licensee's- performance during the last quarter of the assessment period to that dur-ing the entire period in order to -determine the recent ' trend. The' trend categories used by the SALP Board are as follows:
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Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Licensee performance was determined to be declining near. the - close of the assessment period and the licensee had not taken meaningfu steps to address this patter A trend is assigned only when, in the opini.on of the SAlp Board, the trend is L significant enough to be considered indicative of a likely change in the' performance category-.in the near future. For example,- a classifica-
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tion of ." Category 2, Improving" indicates the clear potential for
" Category 1" performance in the next SALP perio It. should be noted that Category 3 performance, the lowest category, represents acceptabl~, e although minimally adequate, safety performanc If at any time the NRC concluded that a licensee was not achieving an . adequate level of safety performance, it would then be incumbent upon NRC to take prompt ' appropriate action in the interest of public health and safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP proces It should be also noted that the industry continues to be subject to rising performance expectation NRC expects licensee to use industry-wide and plant-specific operating experience actively in order to effect performance improvemen Thus, a licensee's safety performance would be expected to show improvement over the years in order to maintain consist-ent SALP rating l
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I PERFORMANCE ANALYSIS Operations - (1688 hours, 37.5%)
' Analysis 'This area was rated Category 2 with an improving trend in the previous SALP assessment. That assessment identified a poten-tial for the Plant- Operations. ' and Safety Review Committee (POSRC) to be biased towards operations due to excessive influ-ence by the Chairman. . A concern was expressed that insufficient -
controls existed to ensure that all equipment failures, partic-ularly those occurring during surveillance testing, were brought to ' management. attention. Weakness was noted in the post-maintenance testing progra A reduction was seen in the average annual rate of reactor trips-(manual and automatic combined) from 5.4 per unit in the pre-vious SALP period-to 4 per unit this period. In the latter_part
. of the assessment period, a new record for continuous operation . (exceeded 202 days) was set on Unit 2. These reductions were supported by elimination .of reactor coolant. pump surge capaci-tors.and an increased emphasis by the licensee in 1988 on plant niaintenance. The licensee purposely eliminated any: availability goals for 1988. The licensee displayed good initiative in con-ducting a short maintenance outage on Unit 2 in the Spring of 1988 . which went well beyond conducting required surveillance testin During this outage, a number of deficiencies, most notably in the control room, were corrected. Maintenance and Operations personnel were encouraged to take the time necessary to "fix things right" and to conduct post-maintenance testing properly. .The increased emphasis on maintenance and reduced pressure to quickly return to operation was in strong contrast to the licensee's performance early in the SALP period. At that time, the licensee was quick .in declaring components such as diesel generators and auxiliary feedwater pumps operable after experiencing intermittent failures, and was slow in correcting deficiencies in other equipment such as safety injection - tank level. transmitter Near the end of the SALP period, some employees appeared to have sensed a weakening in management commitment to maintenance when Unit I was restarted from an outage wherein corrective maintenance was largely ineffective.
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L' Further: trip reduction : efforts continue to be neede The-licensee.wa's slow to implement hardware related recommendations of their. trip reduction task forc Four trips appear to have been avoidable through better control. of maintenance and troubleshooting activities. Feedwater pump trips' continue to be-a problem are Operator' response to- plant transients was very good including a fire 11n' the - annunciator panel, loss of an instrument bus,: and response to a tripped ' feed ' pump in which a plant trip was avoided. ' Operators took' conservative actions in initiating four manual reactor trips before automatic trip setpoints were exceede . Significant problems were evident with operators and othr e plant staff failing to adhere to procedures. Some of the more signif-- icant events . involving failure -.to- follow procedures included
;mispositioning of a diesel generator. voltage- regulator . mode
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' switch, non conservatively adjusting.. four channels at reactor
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differential temperature (delta T) power. instrumentation, . and - the death of an employee during a diving evolution. The prob-lems appeared to stem from overconfidence and have resulted from
~ inadequate emphasis on procedure compliance 'and poor quality of procedures. They were compounded by the tendency of Operations to attempt problem resolution without requesting or obtaining '
assistance from other departments. _The licensee has been slow to recognize this proble However, once the problem was recognized and acknowledged, corrective actions were initiated including strong disciplinary actions, plans for procedure up-grades, and increased supervisory emphasi Although -the licensee emphasized better communications between Operations and Engineering, the Operations Department made many real-time technical decisions without engineering input. Cases like the delta T power and diesel generator voltage regulator mode switch events, as well as another event in which a pressurizer / spray line delta T limit was exceeded, indicated that operators were still prone to making unilateral technical decisions. Operations did not appear to use Engineering effec-- tively. The Engineering and Technical Support section of this assessment (IV.F) describes general initiatives being taken to integrate engineering into the plant staf The corrective actions noted above to ensure that equipment problems were raised to management attention were also directed at improving
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e Operations / Engineering interface Additional Operations / Engineering interface improvement actions included: (1) rota-tion of engineers into operator licensing programs and full utilization of those individuals on shift as Control Room Super-visors, Plant Watch Supervisors, and Shift Technical Advisors; (2) requiring engineers involved with development of Engineering Test Procedures to be present during the conduct of tests; and (3) limited rotation of licensed operators into engineerin Significant improvements were made during the assessment period in plant housekeeping. In particular, the service water pump rooms, auxiliary feedwater pump rooms, condenser pits, and Emergency Core Cooling Pump rooms were cleaned and painte Color coding was used in selected areas as a human factors improvement to help operators differentiate between unit Operational enhancements were made through creation of a more professional and formal atmosphere in the control room. Renova-tions were made in the control room which included painting, human factors upgrades on control panels, new furnishings, new carpeting, installation of upgraded plant computers, and imple-mentation of safety parameter display systems (SPDS) on both unit Significant reductions were made by maintenance in the number of control room equipment deficiencie Areas of the control room, limited for access for undisturbed operator con-trol, were expanded. The distraction of maintenance personnel entering the cGntrol room for approvals of maintenance activ-ities was reduced by pre-staging maintenance orders late on the day preceding the maintenance evolution (to allow more time for operator review and tagging) and restricting the number of main-tenance personnel approaching operators at any one time. More time was allotted at the end of the Unit I refueling outage for operators to perform post-maintenance testing before plant startu Formality in communications was emphasized to opera-tors through written guidance and in simulator training. Shift Supervisors were trained as monitors and then were periodically assigned to observe their crew's performance in simulator session Additionally, the General Supervisor and Assistant General Supervisor of Operations regularly monitored simulator training. Special emphasis was placed on operator alertness for changes in the plant. Shif t briefings were initiated when more significant evolutions were planned for the shif Briefings were conducted each shift for operators stationed outside the control room. Training was provided to operators on ways of reducing physical stresses due to shift work and to maximize operator alertnes . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ -
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The Licensed Operator Training (LOT) Program was administered I
'and implemented by an' organized group of dedicated,Lwell. trained-individuals who had the respect of the licensed. operating crew JThe procedures pertaining to LOT were well prepared and'provided ' . prescriptive guidance to.'the instructors. . Lesson plans used by'
the instructors : were thoroughly- researched and updated.. on a timely bases. Classroom'. lectures were presented in a ' profess-p ional manner and' held the attention of the operators Simulator-classes were well . organized and were challenging to' the opera-tor Feedback from all individual team members was encouraged and the ShiftLSuperintendent played a major role in determining:
-his crew's. strengths and-weaknesses. However, NRC observations of simulator exercises indicated problems with Control Room Supervisor. command and control. Assignments' to. shift personnel 'during lsuch exercises were .too broad and 'had the potential to result in uncertainties in the status of Emergency Operating-Procedure completio ' . Written quizzes were. considered a' reliable tool by . NRC .in judging the knowledge: levels of the operators because the con-tent of 'the lesson plans .was .used effectively when developing- - the. quizzes. The ' results of the quizzes from ' 1987 showed that .
- high grades were being achieved. The annual' simulator examina : tions were 'also a good. indication of. the skills and abilities of L the operators. Operating events 'were, quickly. incorporated into-the LOT program since a system to rate the importance- of off - normal events was well established . including outside industry-and internally generated. events. Two operator = licensing exam-inations were administered during this ' SALP period with good results. Seven of the eight. candidates passed the initial exam-inations, with the remaining candidate passing after a written examination retak .The licensee has a'significant depth of experience'and consider-able resources in numbers of licensed individuals. At the close of the assessment period, not counting training personnel, 26 individuals. held senior and 28 held reactor operator licenses-which were. either active or could be' activated. This gave the licensee. flexibility to rotate selected individuals off-shift for special assignments such as procedure writing,. tagging, and outage managemen This flexibility strengthened those func-tions. Turnover rate in operations continued to be lo < _
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In summary,. the. licensee responded to concerns identified in th previous SALP. Increased emphasis was placed on plant mainten-ance which. appeared ' to have. beneficial results in terms of reducing the number of plant trips. However, further reductions - : in trip. frequency and challenges to operators appear to be feasible. Operator response to transients was good. Signifi-cant problems were identified with the plant staff as a whole in the area of procedure compliance and quality of procedures,. which will require continued management attention. Operations / engineering interfaces were improving, but still showed indica-E tions of weakness in integration of engineering into operational and safety. decision making. . Improvements were made .in control' room environment, formality and operator professionalis . Performance Rating
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Rating: Category 2
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Trend: Declining 3. Recommendations Licensee: None NRC: None
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l . B. Radiological Controls (482 hours,10.7%) Analysis The Radiological Controls Program was. . rated Category'.1 last assessment perio Identified program strengths included an effective organization, external exposure controls, genera employee training, and ALAR The- Radiation Protection (RP)~ organization was ' adequately staffed with well qualified personne Sufficient levels of contractor personnel were' brought in to support . outage-activitie An appropriate level of supervision was in place to oversee contractor technician activitie Audits of the RP department activities, performed by. the QA group, were noted to be a licensee strength. The scope of the audits _ was broad' and significant findings were identifie Several-QA auditors were well qualified by virtue of previous HP experience; additionally, the licensee made provisions for out-side technical support to review. more technical program area RP-department response to formal QA audit findings was generally timely and effective; however, one example was noted in.which the licensee failed to address a deficiency in the solid rad-waste area which had been identified by the QA grou A weakness was noted during the current period with the-licen-see's response and corrective actions for identified radiolog-ical deficiencies. A significant number of Radiological Control Reports (RCRs) were still open several months after issuance to responsible work group supervision, reflecting a lack of ag-gressive follow-up action by the RP group. The licensee also identified two radiological " incidents" during the current period, related to a failure to follow procedures while admin-1stering an irritant smoke respirator fit-test and to a failure to adequately perform and document a survey prior to work in a High Radiation Area. NRC review of these incidents identified the deficiencies themselves (i.e., procedural noncompliance and inadequate survey performance) were isolated events. Licensee corrective actions for both events, however, were either limited in scope or lacked timeliness.
L An additional example of the above weakness was noted in the i radwaste are The licensee's failure to verify waste stream-scaling factors, as described later in this assessment, had been identified by the licensee's own Chemistry and Quality Control departments. Despite this identification, no actions had been taken in a timely fashion to alleviate this deficienc __ _
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Licensee procedures were effective and generally well-imple-mented. The licensee also developed written job control stand-ards for several high exposure jobs in an effort to improve consistency and upgrade the level of radiation protection job coverage. This was noted as a positive initiativ The licensee's training program for radiation safety workers and RP technicians continued to be effective. Several initiatives in this area were noted, including the development of an in-depth radiation monitor training program, the effective use of training videotapes, and the development of an extensive qualif-ication card system for RP technician The licensee's external exposure controls program was well-implemented. Routine and job-specific radiological surveys were generally effectively performe Numerous high dose rate jobs were well planned and controlle Job-specific special work permits (SWPs) were effective in controlling hazards and worker compliance with SWPs was hig Licensee performance in the internal exposure controls area continued to be effective. Adequate air sampling was performed to support work activities and instances of worker radioactive material intake were minimal. A minor weakness was noted with the level of licensee oversight over vendor bioassay analyses and calibration activities. These weaknesses did not adversely affect the overall quality of the progra Deficiencies were noted with radiological posting and housekeep-ing during the current period which reflected a lack of atten-tion to posting requirements on the part of in-field personne Examples included inconsistent posting of radiological areas, radiological signs obscured by items or fallen down, protective l clothing adrift, potentially contaminated material crossing
- boundaries, etc. Improvement in licensee performance in this l area was noted towards the end of the period.
l l Licensee performance in the ALARA area remained particularly ' stron Licensee annual and job specific exposure goals were competitive and challenging. Actual exposure was low consider-ing the work performed. Total exposure for 1987 (which included a refueling outage) equaled 412 person-rem for the two unit i site; actual total exposure for 1988 was 291 person-rem. Sta-l tion ALARA goals were widely disseminated on site and the vari-ous plant groups (Operations, Maintenance, QC) appeared know-ledgeable of and voiced ALARA concerns during job planning meeting _ _ _ _ _ _ _
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The ALARA staff performed effectively in job planning, ongoing j exposure tracking, and documenting and utilizing lessons-learned. Unit 1 outage ALARA planning was delayed due to the Unit 2 mini maintenance outage; however, this did not appear to ' significantly impact ALARA performanc Licensee exposure sav- , ing initiatives included the use of a remotely operated decon- I tamination machine for cavity decontamination, the effective use , of mock-up training, and modifications to improve reliability of 1 steam generator (S/G) eddy current testing equipment. Licensee water chemistry controls were effective in maintaining a low S/G source term. The licensee also significantly reduced the extent of plant contaminated areas during this assessment period. The above initiatives, coupled with increased worker efficiency, were effective in reducing exposur Transportation documents and procedures used by the licensee showed an inattention to detail when performing calculations for radioactive material classification and preparation of shipping manifests. This was further compounded by the failure of management to properly review calculations and documents pre-pared by the technical staff for accurac This inattention resulted in two of five shipments of radioactive material being improperly labeled and packaged for transportation. This repre-sented a decline in this area from the last assessment perio While the licensee's continued actions in the area of solid radioactive * waste volume reduction were commendable, this pro-gram failed to properly analyze the plant waste streams in a mduner Consistent with NRC guidance and the licensee's own pro-cedure Scaling factors had not been verified since 1985, contrary to the licensee's requirement for semiannual verificatio The licensee maintained an effective program for controlling radioactive effluent releases to the environment as was observed in the previous SALP. Conservative methodologies were used to ensure compliance with dose limit The licensee also calcu-lated expected radiation monitor readings enabling a manual isolation of batch releases at levels far below regulatory requirements and also preventing inadvertent releases from unsampled tank The licensee's performance with respect to actual samples split for confirmatory measurements was excellent, and was an indica-tion of the strength of the radioanalytical measurements QA/QC progra >
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The licensee's radiological environmental monitoring program was consistently applied. Quality assurance / quality control of the analytical laboratory was well maintained. The annual environ-mental monitoring report demonstrated that the licensee per-formed all aspects (sampling, analytical sensitivities, report-ing schedules, and interlaboratory comparison) as. require Overall licensee performance in the ~ majorf Radiation Protection
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functional . areas remained effective during the current period. . ALARA performance was considered to be a significant licensee strength. .. Compared to thei previous period, there has been a
~ discernible decline in performance, particularly in the areas of
. radwaste, transportation, and corrective. actions for identified ' deficiencies. The magnitude of this decline, .however, was not significant enough to change the overall rating in this func-tional are . Performance Rating Rating: Category 1 Trend: None
~3. Recommendations Licensee: None NRC: None
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x C. ~ Maintenance / Surveillance (1193 hours, 26.5%)
: . Analysis During . the previous SALp, Maintenance and Surveillance were '
assessed ' separately and each carea was : assigned a Category 2
' rating. Maintenance demonstrated slow' improvements while facing .
a large work load. The effectiveness of. management programs and initiatives' appeared constrained by limited manpower, resources, and : engineering support. Use of the Integrated Management Sys- . tem (IMS) to . prioritize the use of resources appeared: to . be ineffective in resolving long standing - deficiencies. Lack of effective use of trending for maintenance- history 'and _ component
. failures reduced resource efficienc ~
Poor work practices con-tinued to exist due to lack of attention to detail _and insuf-
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ficient ' supervision; post- maintenance testing required improve- > 1- men In the Surveillance area, it was noted . in .the previous r SALP that licensee policies and procedures did not adequatel . addressLintermittent equipment failures or degradations exhib - ited 'during testing. The surveillance program needed to be.used-more effectively to identify equipment performance and relia-- bility problem The licensee exerted a significant effort to remedy.the afore-mentioned maintenance shortcomings during this period. .The licensee's maintenance organization effectively- reduced the ' . mechanical maintenance backlog . from a previous high of 7 weeks (estimated time needed to complete : existing maintenance requests) to a more manageable . level of 2.9 weeks. The ' 'i n stru-ment / electrical maintenance backlog was reduced from a high of 5 weeks to a recent level of 1.2 ' weeks. The reduction was accom-p11shed by using a combination of overtime, contractors, and other' licensee resources. Elevated . attention was given to increasing mechanical maintenance and welder supervision. Re-source shortages were _ remedied by, in part, increases in the mechanical planning and scheduling areas. This resulted in a greater ability to accurately allocate resources, resolve inter-ferences, identify early potential' schedule conflicts And improve advance planning for all outage related maintenanc There was' an _ increase in supervisors in the field. This super-vision was used as on-the-job training (0JT) instructors and procedure writers during operation and as supervisors during '
- E major outages. Near the end of the assessment period, the post-maintenance testing program was upgraded to contain detailed guidance based on actual maintenance performed; however, imple-mentation had not been accomplishe _----a- m - -- a- -------------a--_.a-- - - . _ - - - - >- ._
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' _ Improved communication was aggressively pursued by the mechan-ital maintenance group through cross-training and loaning of . supervisory and craft personnel to _ various other department This- program increased awareness and promoted understanding' of' concomitant areas. The _ Predictive Maintenance Program proved useful during this period in that the reports highlighted a - number of areas where additional attention was necessary. The information was also useful in improved use of manpower re- l sources such as planned oil changes based solely on lube oil analysis versus periodic- oil changes. Significant . effort 'was expended to improve the prioritization of resources throagh the use of the IMS by requiring review at the General Supervisor level, who are closer to day-to-day problems, thereby improving the efficacy of the syste The licensee st.ccessfully pursued equipment improvement programs reflecting an escalated proactive effort to reduce malfunctions and unnecessary operational challenges. Good initiatives in this - area were as follows: the licensee installed a redundant paralleled set of air dryers on each unit thereby allowing main-tenance on a dryer set without impairing air quality; retubing . of severely ' pitted and eroded salt water heat exchanger tubes reduced the chance of intrusion; and responding to the need to replace the original plant computer, the licensee . installed a new computer which featured a . Safety Parameter Display System and the' ability to store historical- information for- 200 parameter The licensee . continued to conservatively examine all Steam Generator tubes by eddy current testing each outag This effort resulted in high confidence levels concerning tube condition in addition to minimizing the probability of major leaks or breaks. The aforementioned actions were indicative of an aggressive program with good safety perspectiv A strong commitment was made early in 1988 to increase attention-to plant material condition. A general Unit 2 maintenance mini-outage ' was followed by a record setting ru In contrast, limited success was realized during a fall of 1988 Unit 1 main-tenance outag Four trips occurred during this period related to maintenance activities (Section III.C). These involved inadequate control of maintenance work activities (particularly troubleshooting), lack of attention to detail and weaknesses in procedures. Addi-tional examples reflecting work control weaknesses included
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L overtorquing of #11 steam generator manway studs, failure to properly lubricate #22 LPSI coupling resulting in failure, -im-proper lubrication of. safety related motor operated valves, procedure non-compliance during defeating and restoring contain-ment air lock. door interlocks, and' poor troubleshooting tech-
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niques on #12 main feedwater pump turbine Early. in this assessment period,- speed oscillation problems were
, intermittently experienced during testing of Auxiliary Feedwater-(AFW) pumps. After attempts to resolve the problem, the licen-see demonstrated. a nonconservative philosophy of declaring com-ponents operable following only a single successful test. Exper-ience. later showed. .that the root cause of the speed control-problems had indeed not been resolved and that a series of suc-cessful tests' was required in these situations ~ to demonstrate successful corrective actions that restored operability. _ The licensee responded to this concern by subsequently placing increased emphasis on equipment maintenance, including identifi-cation and allowance of adequate time for correction of root causes. These ' efforts were not fully effective as evidenced by .
operator response during attempts .to resolve - apparent ' diesel generator testing and operability problems ;in ' June 1988 where , the voltage regulator switch was left in the wrong mad J
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The previous SALP highlighted a weakness 1n documentation of
. degraded equipment . performance identified during surveillance testing which reduced the effectiveness of the surveillance pro-g ram.' The licensee implemented several corrective actions in the operations area including providing additional guidance-and instructions to workers performing tests, . increasing engineering involvement in the surveillance programs and increasing.QC coverage of operations surveillance activitie A dedicated effort was pursued to improve the documentation of surveillance test finding The requirement for improved documentation of findings was promoted through formal training programs, frequent verbal instructions ~ from supervisory personnel and by revising the procedures to incorporate comments and changes made by tesi.-
ing personne A full time senior licensed individual was designated to audit operations activities, including surveil-lance- testin Some improvements were noted in the operations area, however, there ~ corrective actions were not applied to other area , se '
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An event late in the assessment period demonstrated the need for broader corrective actions. That event involved a failure to adequately document the discovery of an inoperable containment door interlock during testin It showed that maintenance per-sonnel performing the test were not adequately sensitized to the documentation problem and highlighted an organizational short-coming which allowed corrective actions appropriate to all test-ing personnel to be applied to only one grou Responsibilities for surveillance testing were diffused through-out the' 11censee's organization with each department- independ-ently scheduling and conducting tests assigned .to them. This organizational arrangement resulted in the lessons learned in one area not bcing applied to other groups. Responsibility for ensuring uniform follow through of needed improvement actions throughout the organization was not clearly assigne Procedural noncompliance (failures to process appropriate tem-porary changes) were noted during the period indicating that procedure adherence problems also adversely affected this func-tional are Programmatic weaknesses included lack of clear distinction between intent and non-intent changes to procedures and weak controls for ensuring that temporary changes to sur-ve111ance procedures were incorporated into procedure revisions and future test performance Surveillance tests were generally conducted on schedule, but there were several licensee identified problems with missed tests indicating that better tracking and schedular controls were neede Overall, personnel performing surveillance tests were technically knowledgeable and conversant in the test requirements and systems involve The licensee continued an aggressive program to systematically inspect and replace extraction feedwater and drain line By the end of the assessment period, approximately 2700 feet of piping and 400 fittings had been replaced. Despite this gener-ally effective program, a Unit I forced outage was necessary in January 1988 to repair welds on high pressure extraction drain pipin The licensee's engineering department assumed responsibility for ' scheduling review and evaluation of the Operation Surveillance Test Procedures during this assessment perio The change improved the systematic evaluation and trending of test results and assured engineering department involvement in the resolution of problems found during testing. Both verbal and written com-munications between operations personnel, systems engineering, and engineering personnel improved in this area as a result of proactive management initiatives.
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[ , . h - Secondary water . chemistry control during the' assessment perio was excellent. The licensee's programs to control corrosion.and out-of-core radiation field buildup, ensure long term integrityX of. the. reactor coolant and L secondary pressure boundaries and minimize fuel leakage- by' corrosion induced failures were effec-tiv The development and implementation of procedures : were adequate and consistent' with thet Technical Specifications and industry guidelines, such as those ,of Electric. Power Research - Institute. - Noteworthy was the achievement of consistently lower steam generator channel head' radiation levels . than j comparable
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PWR's through the use of an elevated lithium schem The licensee's non-radiological chemistry -laboratory operations - were evaluated twice during this period by NRC. Standard solu-
.tions were submitted to the licensee to analyze;using the.11cen-sec's normal methods and equipment. Twenty-three ~ percent '(6 out of : 26) and fifty-six . percent (19 out of 33) of the_ measurements . were in' disagreement 'with.the criteria used for comparison dur-ing the first and second evaluations. The disagreements between ~
the measurements-and the criteria indicated problems with mini-mum quantifiable concentrations, sampling error, old equipment, and _ training. Additional attention was needed to improve this progra In summary, the licensee implemented a number of initiatives in the areas of backlog reduction, maintenance planning, procedural and equipment improvements and plant material conditions during the assessment period. The licensee ' activities in the area o preventive and corrective maintenance indicated'a lack of atten-tion to detail coupled with insufficient control and supervision
.resulting in a significant number of trips and challenges to safety equipment. _ Improvements were seen in the licensee man-agement's policy toward resolving intermittent equipment prob-1 ems although it is not clear that this :has extended downwar Although corrective actions were taken to resolve deficiencies in documentation of equipment problems, those actions were prin-cipally limited to the operations area while experience showed they should have been more generally applied. A decentralized .
surveillance organization contributed to a lack of an overall corrective action progra Procedure adherence problems were noted. Engineering involvement in the surveillance testing pro-a gram has increased.
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2. Performance Rating-Rating: Category 2-Trend: None
- 3. Recommendations
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. Licensee: The licensee should develop a more. systematic approach to control of maintenance / surveillance activities that ensures greater attention to. detail .' and procedural'
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adherence, especially" with respect to ' troubleshooting
. . activitie NRC: None .
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i Emergency preparedness (246 hours,'5.5%) ~I Analysis During the previous assessment period, licensee performance in this area was rated as Category 2,'primarily based upon. several weaknesses identified in performance of emergency ' response personnel during .the 1986 partial participation exercis During this assessment period, one full participation and one partial participation emergency . exercise were observed. .In addition, a routine inspection was conducted, one special safety inspection specifically related to emergency classification was - conducted,- and changes to emergency plans and implementing pro-
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cedures were reviewe ' '
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In- the . full participation exercise held ' on November 17, 1987,
.the-~11censee's execution. and participation demonstrated good planning and adequate protective measures to ensure. public health and safet NRC observed performance weaknesses which-could have potentially degraded the licensee's response ~ in the-areas of . technical assessment and information flow. Of primary concern was the Technical Support Center (TSC) staff not being =
effectively utilized to provide thorough, timely accident assessmen The evaluation of the partial participation exercise of-December 6,1988, is included in this assessment as it was only a few days beyond the SALP period end and was indicative of per-formance_during this cycle. During this exercise, the licensee again demonstrated good . performance in key decision making area Only minor deficiencies . were observed and . improvements were noted in overall performance. Deficiencies identified in previous exercises were not repeate The licensee conducted meaningful self-critiques following each exercise by documenting both procedural and performance related deficiencies and committed to take appropriate corrective action The licensee's. actions in response to a declaration of an actual Alert due to a loss of annunciators on February 1,1988, demon-strated weaknesses in 'their implementing procedures and emerg-ency response tre.ining, particularly in the areas of classifica-tion and management control over staff notification and augmen-tatio Further, the licensee deviated from procedures by not fully augmenting all response staff or activating emergency l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ - . "
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' . . response facilities. Licensee management did not recognize the procedural deviation as a concern because they believed that the event. posed no threat to either the plant or public health and .. sa fety. Since the implementing procedures did not permit such , flexibility. this represented a failure to' implement established ' Emergency Plan procedures.
, 'The?1icensee established a task; force.of department representa-
-tives' from radiation safety, operations training, emergenc . preparedness - and fuel l cycle management to review existin '
EAL's. - The. licensee - also stressed the need in training 1to ensure' that activation' and other response procedures are strictly followed. ' Task force recommendations resulted in changes' to EAL's for loss .of power, fission product barrier
' degradation and radioactive releases. Performance training on EAL revisions has-been conducte Emergency, Response Facilities were dedicated and common to both units;. .TSC changes' were made- through addition of SPDS dispisy ., terminals and revisions to the facility layout, but TSC size and-space . limitations remained throughout the period. . To . . hel p alleviate TSC. congestion,. systems and design engineering support' -
during: emergencies was relocated to the new Nuclear Engineering Facility. :While this arrangement' appeared to function ade . '
:quately during the'1988 exercise, the long term effectiveness.of this approach is unclear. 'The recently installed speed-dial communication system was effective ~in-implementing-timely notif-ications and provided efficient -information flow within emerg-ency response facilitie A full-time emergency preparedness staff was available to admin-ister and maintain both onsite and offsite activities. associated with the. program. Additional ' support, for scenario development and conduct of exercises and drills.was provided by the training and operations staffs.
f The licensee developed and maintained a good working relation-ship ~ with ~ officials from the Counties of Calvert,. St. Mary's, and Dorchester and the' State of Maryland relative to emergency preparedness issues. Meetings were held.on a regular basis to discuss. EAL's and other areas of mutual interest during emerg-ency. response. Voluntary attendance by local offsite fire and law enforcement personnel in training sessions was good, thereby
~ ' demonstrating licensee-initiatives in coordinating and maintain- .ing positive relations with offsite authorities.
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l . . . i L 'In summary, licensee performance near the end of the period dis - l " played progress in several program areas including exercise per- . formance and upgrading of facilities.and equipment. Management l involvement was adequate to ensure. that the. emergency prepared-
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i ness program could be effectively administered. Although appro-priate actions were taken. with regard to safety, the licensee did not correctly. implement emergency response procedures during : thc loss of annunciator event. Training at all levels was i extensive but not fully effective due to perfor: nance related ! weaknesses identified during the 1987 exercise and' response to j the loss of annunciator even l
; Performance Rating ;
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l Ratino: Category 2 j i Trend: Improving ) i Recommendations Licensee: None j
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,- b E. Security- (144 hours, 3.2%) Analysis During the previous assessment period, the licensee's perform-ance was rated as Category 1. No major regulatory issues were l ' identified. The licensee continued to demonstrate a thorough understanding of NRC security objectives and maintained an excellent enforcement histor During this assessment period, both plant and corporate security-management continued to be aggressively involved in the security program at Calvert Cliffs and in nuclear power plant security, in genera This was demonstrated by the licensee continuing attention to program needs, i.e., upgrading the site firearms range to enhance the existing firearms training program, the acquisition of a new security computer and access control-devices and equipment (on-site but not yet installed), the ran-dom use of drug detection dogs on-site, the use of computerized video tapes in the security training program, the upgrading of emergency response equipment, the implementation of a computer-ized system to expedite processing of. visitors into the protec-ted area, the procurement of battery testers for portable radios to insure that batteries are adequately charged at all times, . and the use' of detectors at protected and owner controlled area egress to preclude protected area badges from leaving the sit Additionally, the licensee's follow-up and resolution of find-ings from the NRC's Regulatory Effectiveness Review demonstrated a clear understanding of the NRC's security program performance objectives, responsiveness to NRC initiatives and a desire to implement an effective security progra The site security supervisor and his staff were well trained and qualified security professionals were vasted with the necessary authority and discretion to ensure that the security program was carried out effectively and in compliance with NRC regulation They were actively supported by a very knowledgeable and effec-tive corporate staf Corporate arid site security management also continued to actively participate in the Region I Nuclear Security Associa-tion and other groups engaged in nuclear plant security matter In addition, they actively interfaced with law enforcement and emergency services agencies to maintain a good working relation-ship. This was evident during February 1988 when the licensee,
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upon its initiative, again held a joint training exercise on-sit These exercises were also supplemented with periodic meetings and on site familiarization tours with those agencie The extent of training and the degree of readiness of the security organization was well-demonstrated during an industrial type accident that occurred during the perio The security organization was promptly mobilized and acted to mitigate the consequences of the accident and to direct off-site medical assistance for the injure The licensee also conducted, at its own initiative, a two-day meeting, which involved the Vice President of the Nuclear Division and his managers, to pursue means to enhance the inter-face between operations and security during emergencies. This was further evidence of the licensee's continuing interest in implementing a highly effective security progra Staffing of the proprietary security force was consistent with program needs as evidenced by the continued effe"1ve oversight and excellent performance during the period and a limited use of overtim The proprietary force was supplemented, as required, by watchpersons provided by a security contracto During this assessment period, staffing was reasonably stable in the proprietary guard forc The security force training and requalification program was well developed and was administrated by an experienced staff of seven full-time employees and one part-time employee, under a training supervisor. Facilities for training and requalifications were available on site. The facilities were well equipped and well maintained. The licensee also budgeted substantial resources for special, off-site training courses for members of the secur-ity organization, including: accident investigation, behavioral observation, weapons proficiency and ar.ti-terrorism. Conting-ency drills were conducted each week and were effectively used for training purposes by conducting critiques that were fed back into the formal training and requalification program. The oper-ations organization became more active in its participation in these exercises when the event could have an adverse effect on plant operatio The licensee's event reporting procedures were clear and con-sistent with the NRC's reporting requirements in 10 CFR 73.7 Five event reports were submitted to the NRC during the assess-ment period. No adverse trend was indicated. Each report was clear and concise, and indicated appropriate response to the even . p G
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During the assessment period, the licensee submitted- eleven : revisions to the security program plans under the provisions of
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10 CFR 50.54(p) in addition to a plan revision to conform to the new 10 CFR' 73.55 Miscellaneous Amendments and search require-ment In general, these revisions were of high quality and technically sound, and reflected well-developed policies and procedures as well as management oversigh In two cases, how-ever, the quality of its staff review process declined in that
.the revision was not up to the licensee's ' str;.o'ard and the revisions required clarification before NRC concurrenc In summary, the licensee continued to maintain a very effective and performance oriented security program. Significant enhance-ments were made to the program which were indicative of manage-ment attention to and interest in the program. The efforts to upgrade. the operation and reliability of systems and equipment during this period (and the preceding period) were commendable and demonstrated the licensee's commitment to maintain an effec-tive and high quality progra . Performance Rating Rating: Category 1 Trend: None Recommendations Licensee: None NRC: None
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.. Engineering and Technical Support (400 hours, 8.9%) Analysis Engineering' and Technical Support was not rated as a separate functional area during the last SALP period. Engineering sup-port was rated as Category 3, Improving. In the previous SALP problems were identified with (1) full integration of the Nuclear Engineering Services Department (NESD) into the plant staff; (2) lack of adequate ' assessment and definition of the roles / responsibilities of systems engineers; (3) for multi-discipline tasks, lack of clear assignment of responsibility; (4) providing the necessary resources to complete corrective actions for past problems (i.e., EQ, MCQ, FCR backlog), ensuring timely and thorough response to NRC initiatives, furnishing better maintenance support and to resolve long standing tech-nical problems; (5) inefficient control and use of existing resources due to insufficient prioritization and poor coordina-tion; (6)-lack of quality and comprehensiveness of the hazards analyses provided to support technical specification amendments; and, (7) ensuring appropriate management attention was given to identified deficiencies (i.e., QA findings and recommendations).
The SALP Board recommended that the licensee have an independent assessment performed of the engineering organization which would identify engineering functions and include a review of.the over-all system for establishing priorities, assigning responsibil-ity, and obtaining resource During this period, the licensee made a concerted effort to integrate NESD into the plant staff by initiatives such as:
(1) attendance of selected systems, design, and licensing engi-neers at daily morning meetings with operations and maintenance personnel to discues anticipated plant activities and eme:rging needs for maintenance and engir.eering support; (2) participation of the prircipal engineers of Technical Services, Design, and Plant and Projects Engineering on the Plant Operations and Safety Review Committee (POSRC); (3) joint participation of operations and engineering supervisors on work planning and scheduling committees; (4) joint participation of engineering personnel on multi-discipline, special teams tuch as Fact Acting Solution Teams (FAST) to solve specific maintenance problems and
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significant event investigation teams (Significant Incident Finding Teams - SIFT); (5) dedication of selected design engi-neers to unanticipated work to support maintenance and opera-tion; (6) participation of systems " experts" from systems engi-neering, maintenance, and operations in systems circles and joint system walkdowns; and (7) participation of the entire plant staff in periodic communications meeting Licensee
" customer sati sf action" surveys showed improved attitudes by station personnel toward engineerin The licensee developed an expanded job description for the systems engineers and incorporated functional responsibilities into the plant procedure Licensee maintenance personnel have found systems engineers to be more responsive and were assigning a higher level of credibility to systems engineers. The scope of the systems engineer responsibilities was reviewed; and the responsibility for implementation of modifications was reas-signed to the project engineering group, thereby allowing more time to support maintenance activities. At the request of the maintenance group, component engineer positions were established to provide expertise on specific generic equipment. To enhance engineer credibility and effectiveness, a training program,.
originally oriented toward systems engineers but also useful for other engineers and technical staff personnel, was developed and was initiated near the end of the period. However, this was approximately 21s years after the system engineer positions were created. Furthermore, the licensee had still not developed a program for qualifying the system engineers on their associated system Nonetheless, there were indications during the assessment period that obstacles still remained to full acceptance and integration of NESD into the plant staf Communications between operators and engineering were weak in that operations personnel were not yet used to having engineering available as a resource that could provide technical information for real time problem Problem identification by engineering improved during this assessment period, however, in some cases, weaknesses in the engineering / operations interface adversely affected resolutio Sech interface problems also limited licensee effectiveness in quickly identifying the safety implications of operating event Periodically operators failed to involve engineering in resolu-tion of emerging technical problems. Engineering did not always provide adequate support to ongoing operations or to preclude plant trips or shutdown For example, despite repetitive erosion problems with steam generator blow down lines, the prob-lem was not resolved and a Unit 2 forced outage in October 1987
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was necessary. An improper setpoint for generator liquid cool-ing pressure that led to a November 1988 Unit I trip was pri-marily due to inconsistencies in the way setpoint values were supplied by engineering. Finally, although primarily due to untimely technical resolution of problems with RCP capacitors in earlier assessment periods, modifications to the design by replacement of capacitors with inductors was not completed until after another trip on 9/11/87 due to a failed capacito ] Engineering failed to complete some modification packages on schedule. This was evidenced during the Spring 1988 Unit I refueling outage when several packages did not arrive for ~ plan-ning and implementation by the maintenance shops until the beginning of the outage. This prevented adequate planning which led to several inadvertent actuations of the Engineering Safety Features Actuation System due to poor coordination of modifica-tion It also led to parts availability problems and outage delay Significant progress was made by the licensee in completing several major commitments and projects. This included a total review and revision of the Q-list, closecut of older Facility Change Requests (FCR's), resolution of a self-identified issue involving incorrect use of commercial quality fasteners in code class systems, significant progress in generating master cali-bration data sheets, and support of a self-initiated QA audit modeled after the NRC's Safety System Functional Inspections ( SSFI 's) . The licensee took steps te address the resource problem and strengthen engineering. In 1988, a 15% staffing increase was approved and another 10% increase is approved for 1989. Con-tractors were being used until additional staff openings arc fille The Company's Chairman of the Board and President recognized weaknesses in engineering and fully supported improvement effort Management personnel and organizational changes were made which included changes at the Manager, NESD, and General Supervisor, Design Engineering positions. Author-ization was given to establish an Engineering Planning an Scheduling Group, a dedicated group was assigned to the EQ pro-ject, and electrical analysis and configuration management sec-tions were created. Duke Engineering performed an independent comprehensive assessment of NESD. The licensee plans to imple-ment all but one of the Duke recommendations for improvement.
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_ Many of the licensee's . engineering analyses _were sufficient alone to support proposed technical specification (TS) amend-ments and ASME Code related requests. - Furthermore, the addi-tional information developed to support incomplete analyses and justification was generally accurate, well conceived, thorough and detailed. This was particularly exhibited in several 24-month cycle TS amendment requests, in the licensee's discussion of their planned ATWS modifications, and in their response to NUREG-0737, TMI Action Item II.D 1, " Relief Valve and Safety Valve Testing," However, in several significant 'TS amendments that were requested during the assessment period, the Nuclear
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Engineering staff did not display an adequate level of compre- . hension and/or concern towards the technical issues involve The licensee took active measures to improve the timeliness and quality of responses to NRC generic issues. Though the timeli-ness of response to certain NRC generic issues has remained a concern, the Itcensee's overall timeliness of response has improved considerabl The licensee's 50.59 process for making changes to the plant also showed improvement over the last six months of the SALP period. Early in the. period, problems were identified with a change made to the design requirements for a salt water pum Since then, the licensee has undertaken an effort to consis-tently perform more detailed and conservative safety analyses to support 50.59 changes. Furthermore, the licensee has been more willing to consider proposed changes as unreviewed safety ques-tions and to request prior NRC review and approval- for such changes. Finally, the Nuclear Engineering Unit has made signif-icant improvements in their tracking and closure of 50.59 changes associated with core reloads, other core and criticality control changes, and accident analyse NRC review of a limited number of facility changes indicated that changes were of good engineering quality, however, some weaknesses were noted in administrative procedures covering the f acility change procese in that they did not provide clear, step-by-step instructions. As a matter of perspective, however, ! the licensee's self-initiated SSFI identified a number of deficiencies i t. engineering design in the Auxiliary Feedwater (AFW) system and its supporting equipment. The licensee has corrected most of the identified concerns in this system. How-ever, it took almost a year to assign resources for a concerted effort to addrcss problems of this nature in other systems. The NRC considers the SSFI activity to be a positive engineering initiative and encourages the continued evaluation of systems using this approac _----- J
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'In the resource management area, management lacked the necessary tools for scheduling and tracking work to ensure that existing . resources were . efficiently utilize This hampered their ability to monitor' work, hold people accountable, provide cred-ible schedules of work completion, anticipate the impact of and respond to emerging problems, estimate manpower needs for addi-tional _ resources, and clearly assign responsibilities and pri- ' orities for. all work activities.- Although an overall' corrective action - program for engineering was contemplated, one - had not been completed by the end of the assessment perio Clear goals, timetables, and ~ tracking mechanisms to measure progress toward. goals had not been established. Though progress had been made in reducing some backlogs (i.e., open audit findings and non-conformance reports), overall back1 cgs remained high, and FCR's - were being initiated faster L than they were being com-pleted. Progress was slow in' resolving trip reduction task force recommendations. Outstanding items lists of the POSRC and its subcommittee which reviews industry problems (Plant Opera-ting and Experience Assessment Committee) were long and growing in part due to backlogs in engineerin As a positive initiative, in February 1988, the licensee pro-actively conducted a third party review of their procurement program and parts dedication process. A: project team was then established to correct discrepancie In summary,' significant progress has been made in engineering as evidenced by the quality of staff work, the 'self assessment that was performed and the efforts to improve the operations /
engineering interface. However, improvements are still needed to strengthen the operations / engineering interface to ensure effective utilization of resources for the resolution of prob-lems. Further, engineering must develop effective scheduling and prioritization techniques to optimize their effectiveness and ensure important tasks are processed and resolved in a timely manne . Pertermance Rating Rating: Category 2 Trend: None Recommendations Licensee: Develop better capability to measure the effectiveness of new initiatives and programs as well as improve tracking for tighter schedular contro NRC: None _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _
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; ,g -n * , :40 e-r G. Safety Assessment /0uality Verificatio (348 hours, 7.7%) .. Analysis
,. This new functional areal assesses the effectiveness of , the h licensee's programs provided to assure the safety and quality.o plant operations and activities. .It is a . compilation of ~the Licensing and Assurance of Quality; functional areas provided' in e previous SALP . reports, and 'also incorporates relevant lin-sights discussed in all_other current functional area During the previous SALP period, the licensee was evaluated a Category 2 in both 'the Licensing and Assurance of Quality func-
.tional areas. In these functional areas, strengths were, noted -
in 'the qualification and capabilities of the . licensee's staff and in the significant- improvements made in the Quality Assur-ance (QA) section. Weaknesses were . iden' ified in - the quality-and. comprehensiveness of safety analyses, in senior management's
, control of departmental interfaces, in the effective use of Q findings, and in the ability to perceive plant problems and , determine root cause In addition, potential problems' were identified in the safety committees' abilities to provide ;inde- ~
pendent views on plant activities to managemen During this assessment period. . the licensee continued the pro-gress noted during the previous SALP period, in . plant ' problem . identification. The QA section continued to increase the effec-
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tiveness of-its audit function as.a result' of the inclusion of
. detailed technical reviews,. sometimes with . the . assistance of . technical contractors, which expanded audits beyond compliance check lists. These detailed ' technical reviews were also -uti-lized in the safety system functional inspection, conduct $d on the auxiliary feedwater . system in 1987, and the safety system outage management inspection performed during the 1988' tinit I refueling outage. .The resulting audits were generally in-depth and of high quality for most of the areas reviewed. .They described both the findings and the agreed upon corrective actions. These audits resulted in the identification of several potentially significant equipment and operating concerns to which plant management appropriately responded. Furthermore, in i Spring 1988, QA instituted a program to independently investi- );
gate all events, including trips, that the licensee deemed as significan These investigations usually provided very detailed reviews of the -chain of events associated with ' the - incident under review. The results were usually presented to
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the safety review committees. However, neither this program nor the semi-annual corrective action audits attempted to identify root causes for events nor did they evaluate and recommend corrective action ____-__-__-_____ - _ -
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I The licensee also took active measures to improve its diagnostic abilities. For example, in response to an NRC recommendation in the previous SALP, the licensee contracted Duke Engineering Ser-vices to conduct a detailed, independent evaluation of the licensee's Nuclear Engineering Services Department. The major-ity of recommendations arising from this evaluation were re-viewed and endorsed by corporate and site management and are in the process of being implemente Finally, the engineering staff has developed a more questioning attitude and became more active in raising equipment concerns to management as demonstrated by the identification of the' impro-perly set ASIC Code relief valves and the -failures of certain Westinghouse circuit breakers. However, the overall impact on the ability of the plant to continue to operate in the face of these types of concerns was not always assessed in a timely manner. Although the licensee's staff continued to experience some difficulties in resolving technical issues with significant difficulties in ensuring the quality of work performed in several' areas, the engineering staff has shown improvement in the quality and detail of many of their submittals demonstrating a greater understanding of the issues involved and providing somewhat more conservative proposed resolution Despite the continued development of the licensee's diagnostic abilities, there were several-instances where all levels of cor-porate and site management failed to recognize or expeditiously correct deficiencies in personnel performance and equipment reliabilit This weakness was exhibited in the handling of several . equipment deficiencies and contributed to. events, including the Unit 1 trip that resulted from fatigue of a main feed regulating valve's instrument air lina. Although the line was inadequately supported and a similar vibration induced fail-ure had recently occurred, corrective action was deferre In addition, there was a tendency to view problems or occurrences as isolated incident This was particularly true regarding management's failure to recognize significant procedural adher-ence problems, although more than twenty instances of procedural deviations were identified during the assessment period. Several of the procedural noncompliance events could have posed poten-tially significant safety cor. sequences. Senior management did not fuliy recognite and ackr.owledge this procedural adherence problem until September 1988. Subsequent to this event, senior management, particularly the Vice President, Nuclear Energy, implemented a very strong and aggressive program to ensure procedural compliance on the part of all employee ___ ________ _______--_____-____ _ ___ -
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Neither the POSRC nor the OSSRC have realized significant improvement in their effectiveness in resolving technical issues, in identifying problems, or in recommending timely and appropriate corrective actions. During some of the instances of degraded equipment performance, the POSRC was willing to toler-ate compliance with only the minimum Technical Specification surveillance requirements in considering or declaring equipment operable until encouraged by the NRC to take further measure Similarly, in reporting events, the POSRC often limited the information provided in licensing event reports such that several provided only minimal information deleting discussion of some conditions associated with the events. In addition, most commitments to take corrective actions, which POSRC is tasked with tracking, were not tracked until QA identified this defici-ency in May 1988. These weaknesses in the performance of the OSSRC and POSRC, when combined with the lack of an independent program for measuring the effectiveness of implemented correc-tive actions, raise concerns regarding the licensee's ability to critically assess performance as well as ensuring proper per-formance of corrective action In the last SALP evaluatior., concerns were raised that the high proportion of onsite managers on the OSSRC and of opera-tions personnel on the POSRC could reduce the effectiveness of these committees in independently reviewing safety issues. In an effort to resolve these concerns, the chair of OSSRC was shifted to an offsite member, who subsequently became the onsite manager of nuclear engineering, and the POSRC commenced using a facilitatory to lead issue discussions at regularly scheduled POSRC meetings to provide independence from operations influ-ence. However, these changes did not appear to have signifi-cantly increased the committees' effectiveness as discussed . above. Rather, it appears that the high proportion of onsite I me nbers or the OSSRC, the dual mertbership of several plant personnel on both the OSSRC and POSRC and the lack of active participation of sueral POSRC members continued to reduce the independence and effectiveness of these two committee In order to address departmental interface problams and strengthen the cbility of the departirents to function together more effectively as a team, a major reorganization including senior level management changes, was implemented between July and September 1988. Since these changes had only been in place l a short period of time, the long-tenn effects of these initia- , tives could not be assessed. The licensee took several other 1 measures to improve interdepartmental communication, particu-larly between Operations and Engineerin These measures ! included improved notification of system engineers of malfunc-tions or failures of their assigned systems and the attendance i of licensing representatives at daily plant status briefing )
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i; However, significant deficiencies. in organizational interfaces 1 .and communications, both intradepartmental and interdepart-mental, continued to adversely affect performance as exhibited in the handling of several events and issues throughout the SALP period. Intradepartmentally, management policies and ' priorities often were either not effectively. communicated to the staff, particularly regarding' actions required for equipment deficien-cies, or. not consistently implemente Similarly, the staff (particularly Operations) frequently failed to inform appropri-- ate management of such deficiencies, but; rather, made opera-bility and corrective action decisions by themselves thereby failing to ensure involvement of others in problem resolutio Management has not achieved effective team work in resolving ongoing problems.
" In summary, the improving diagnostic ability provided by the QA section and outside assessment applied' in~ engineering should facilitate safer and higher quality plant operation and main-tenanc However, despite these improvements,- the licensee ' continued to demonstrate instances of (1) poor coordination and prioritization of tasks, (2) inadequate interdepartmental and intradepartmental communications and interfacing, and (3) weak- ; nesses in the identification and correction of personnel and equipment deficiencie . Performance Rating Rating: Category 3 Trend: None Recommendations Licensee: None l i NRC: None l
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. .V.- SUPPORTING DATA AND SUMMARY Enforcement Activity Number of Violations by Severity Level Functional Area V -IV III II I Total Plant Operations 2 1 2 5 Radiological Controls 1 3 4
' Maintenance / Surveillance 2 2
- Emergency Preparedness 1 1 Security Engineering / Technical. Support Safety Assessment / Quality
' Verification Totals 3 7 2 12 An enforcement conference was held with the licensee on August 8,198 The topics were inoperability of a diesel generator due to . operator error and a July 4,1988 event involving an improper. adjustment of differential .
temperature (delta T) power. Two civil penalties resulted from the asso-ciated: violations. On November 2,1987,' a Confirmatory Action Letter was issued to reiterate NRC concerns regarding the numerous auxiliary feed-water pump turbine trips, the unidentified and uncorrected root cause of the trips and the licensee's approach for determining pump operabilit !
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. ') Inspection Hour Summary Annualized Actual Hours Percent Plant Operations ;1688 1350 3 Radiological Controls- 482 386 1 . Maintenance / Surveillance- 1193 955 2 Emergency. Preparedness 246 197 '
5.5~ Security 144- 115 3.2-Engineering / Technical Support 400 320 Safety Assessment / Quality Verification 348 278 Totals 4501 3601 10 . _ _ _ _ - _ _ _ _ . - - - . - _ _
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. , . Licensee Event Report Causal Analysis Function Area A B C D E X Total Operations 3 7 1 11 Maintenance / Surveillance 5 1 2 2 10 Engineering / Technical Support 1 1 Other .1 1 2 Totals 8 9 1 2 0 4 24 Unit 1 LERs 87-13 through 88-12 (88-01 not reportable); Unit 2 LERs 87-06 through 88-0 Cause Codes *
Type of Events Unit 1 Unit 2 Personnel Error. ........8....0 Design / Man /Constr./ Install . . . 4 . . . . 5 External Cause . . . . . . . . . 1 . . . . 0 Defective Procedure ......1....1 Component Failure .......0....0 Other .............1....3 Total . . . 15 ... 9
. * Root causes assessed by the SALP Board may differ from those listed in the LE The following common mode events were identified:
Approximately half of the reportable events were categorized under opera-tions. Of these, five were attributable to lact of attention to detail (procedural adherence).
One-fourth of the events were attributable to maintenance. Causal factors were poor troubleshooting techniques, inadequate procedures and control _________-______A
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j* LE!!ON I 475 ALLENDALE MOAD ENCLOSURE 3 2 ~ ** KING OF PRUSSIA. PENNSYLVANIA 19406
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0 3 FEB 1989 Docket / License Nos.: 50-317/DPR-53 50-318/DPR-69 Baltimore Gas and Electric' Company ATTN: Mr. George C. Creel Vice President, Nuclear Energy Calvert Cliffs Nuclear Power Plant MD. Routes 2 and 4 Post Office Box 1535 Lusby, Maryland 20657 Gentlemen: Subject: Systematic Assessment of Licensee Performance (SALP) Report Nos. 50-317/87-99 and 50-318/87-99 The NRC Region I SALP Board has reviewed and evaluated the performance of activities at the Calvert Cliffs Nuclear Power Plant for the period of-September-1, 1987 - November 30, 1988. The results of this . assessment are documented in.the enclosed SALP Board report. A meeting to discuss the assess-ment has been scheduled for February 24, 1989, at the site in Lusby, Marylan At .the SALP meeting, you should be prepared to discuss our assessments and your plans to improve performance. In particular, you should be prepared to discuss the status of ongoing measures to improve adherence to procedures and the areas of organizational functioning across interfaces, flow of communications within and between departments, and internal safety assessment of the significance of events and findings. This should include management actions to assure that-high standards are set and that all personnel work together effectively. as' a team to achieve such standards. The meeting is intended to be a candid dia-logae wherein any comments you may have regarding our report may be discusse Additionally, you may provide written comments within 20 days after the met.ti ng . This report has been placed in the Public Document Room. Following our meeting and receipt of your respcase, the final SALP Report and your responses will be placed in the Public Document Roo . Wprij y o_- U7' _ _ _ _ _ _
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'Balti.more Gas and Electric Company 2 0 '5 FE B 1989
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-Your cooperation with us is appreciate '
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Sincerely, r i / William T. Russell Regional, Administrator
- Enclosure:
L SALP Report Nos. 50-317/87-99 and 50-318/87-99 l cc w/enti: ' I W. Lippold. General Supervisor, Technical Services Engineering !
!. T. Magette, Administrator, Nuclear Evaluations M. Eisenberg,:Ph.D., Director, Science and Environmental Health Public Document Room (PDR).
Local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC) NRC Resident Inspector-State of Maryland (2), Chairman Zech Commissioner Roberts
; Commissioner Carr Commissioner Rogers Commissioner Curtiss K. Abraham, PAO-RI (14 copies) ,
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O ENCLOSURE 4
.. BALTI M O RE 1 GAS AND ELECTRIC at CHARLES CENTER. P. O. BOX 1475 BALTIMORE, MARYLAND 21203 Gromoc C. CatcL l' Vict Passiegwy ' NuCLgam chtsov (301) 26 0-d e B S March 23,1989 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 Systematic Assessment of Licensee Performance (SALP) Reoort (Insoection Reoort Nos. 317]88-99: 318/88-99)
Gentlemen: We have completed a careful review .of your assessment of our performance as documented in the subject report. We find that your conclusions and recommendations closely parallel the results of recent self-assessments performed by Baltimore Gas and Electric Company. At the meeting held on March 3,1989, your staff ' verbally- presented the SALP Report to BG&E corporate management and key members of our Nuclear Energy Division staff. We appreciated the candor ' of your remarks and the opportunity to discuss our current - plans and activities for improving our performance and resolving-our mutual concern The purpose of this letter is ' to reaffirm our commitment to address the concerns detailed in the ' SALP Report. We mentioned a number of specific initiatives at the March 3. meeting. We acknowledge that the nature of the issuer identified by yourselses ' and others, such as INPO, demands that they be carefully factored into our site-wide improvement ~ plan. As you are aware, we are in the . final stages of developing such a plan and will be submitting it to the NRC Staff in the very near futur Please call me if you have any questions regarding - the nature or sincerity of our plans.- Very truly yours, . , f
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