IR 05000317/1988028

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/88-28 & 50-318/88-28

ML20235G458
Person / Time
Site:	Calvert Cliffs
Issue date:	02/14/1989
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Creel G BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8902230257
Download: ML20235G458 (2)

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FEB 141999 Docket No. 50-317 50-318 Baltimore Gas and Electric Company ATTN: Mr. George C. Creel Vice President Nucitar Energy Calvert Cliffs Nuclear Power Plant MD Rts 2 & 4, P.O. Box 1535 Lusby, Maryland 20657 Gentlemen:

Subject: Inspection No. 50-317/88-28 and 50-318/88-28 This refers to your letter dated January 20, 1989, in response to our letter dated December 23, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate

Sincerely, Oridnal S!2ned By:

Jcch R. Strosnider Jacque P. Durr, Chief Engineering Branch Division of Reactor Safety cc:

W. J. Lippold, General Supervisor, Technical Services Engineering T. Magette, Administrator, Nuclear Evaluations Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Maryland (2)

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OFFICIAL RECORD COPY RL CC 88-28 - 0001. /09/89 J 8902230257 890214 -_L E50) {

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. FEB 141989

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Baltimore Gas and Electric Company 2 bec:

Region I' Docket Room (with concurrences)

Man;;cm:nt A;;i; tant, DRMA (v/c caci)

J. Wiggins,'DRP L. Tripp, DRP D. Limroth, DRP P. Wils'on, DRP R. Bores, DRSS S. McNeil, NRR PA0 (14) SALP Reports Only C(4 h RI:DRS RI:DRS RI:DRS Koshy/geb Anderson (Durr i 2//3/89 2/13/89 2//4/89 l OFFICIAL RECORD COPY RL CC 88-28 - 0002. /09/89 l

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BALTIMORE G AS AND ,{

ELECTRIC

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CHARLES CENTER P. O. BOX 1475 BALTIMCRE. MARYLAND 21200 JostPH A.TitmNAN Vict PatsacgNT .

NucLean Entnov January 20, 1989 U. S. Nuclear Regulatory Commission-Washington, DC 20555 A1TENTION: Document Control Desk

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SUBJECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Combined Insoection Reoort No. 50-317/88-28 50-318/88-28 REFERENCE: (a) Letter from . M P. Durr (NRC) to M Tiernan (BG&E), dated December 23, 1988, same subject Gentlemen:

This is in response to Reference (a) and the exit interview held on November 4, 1988, at Calvert Cliffs. Appendix A to Reference (a) is a Notice of Violation of 10 CFR 50 Appendix B, Criterion III. Enclosure (1) provides a response to the Notice of Violation as require Should you have any further questions regarding this matter, we will be pleased to discuss them with yo ' ~

Very truly yours I coh JAT/CDS/ dim Enclosure cc: D. A. Brune, Esquire .-

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) u J. E. Silberg, Esquire R. A.Capra, NRC _A S. A.McNeil,NRC W. T. Russell, NRC V. L. Pritchett, NRC

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T. Magette, DNR

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ENCLOSURE (1)

RESPONSE TO APPENDIX A OF NRC INSPECTION REPORT 50-317/88-28; 50-318/88-28

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Appendix A of NRC Inspection Report 50-317/88-28; 50-318/88-28 is a Notice of Violation of 10 CFR 50, Appendix B, Criterion III. The Notice of Violation identifies an apparent failure to satisfy this requirement in that a design change (Field Engineering Change [FEC) 87-30-01) was performed and verified by the same individua CFR 50, Appendix B, Criterion III states, in part, that: "The verifying or checking process shall be performed by individuals or groups other than those who performed the original design."

The Inspection Report requested a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved, (2) corrective steps to avoid further violations; and (3) the date when full compliance will be achieved. Additionally, it was requested that the results of our examination of the unresolved item regarding the regulatory reporting requirements for non-conforming conditions be addresse . Corrective Actions Taken and Results Achieved An independent design review has been performed for the design change in question by a reviewer who satisfies the requirements of 10 CFR 50, Appendix B, Criterion Il Thus, the FEC (87-30-01) is now in compliance with the requiremen A review of 50 other Facility Change Requests (FCRs) has been completed in an attempt to identify any additional violations of the independent design review  !

requirement. Facility Change Requests normally are the parent documents for  !

FECs. None were found in a random sample of 50 Design Engineering Section FCRs completed between November 1987 and November 1988. Thus, we have concluded that this violation is an isolated cas A root cause analysis has been performed to identify the causes which contributed to the breakdown of the independent review process for FEC 87-30-01. The major contributing causes were that the ~ Design Engineering Section Procedure (DESP)

used for the design and design review process did not adequately define,

" Independent Reviewer," and the engineers involved were not fully cognizant of what constitutes an independent design review or reviewer. The applicable DESP has been reviewed by an independent committee to determine how the FCR process can be improved. Several recommendations for changes to the DESP have been implemented, as detailed belo . Corrective Actions to Avoid Future Violations The applicable DESP has been revised to more clearly explain the requirements of independence for a design reviewer. The DESP has also been revised to allow for three methods of reviewing a design; testing, calculation, or standard review questions. In the past. only the standard review question method was used.

l These changes are in accordance with 10 CFR 50, Appendix B, Criterion 11 . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _

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• a ENCLOSURE (1)

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, RESPONSE TO APPENDIX A OF NRC . INSPECTION REPORT L 50-317/88-28; 50-318/88-28 l

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l Design ~ Engineers were briefed on the requirements for an independent design reviewer in training sessions held on December 5 and . 8, 1988. ' This requirement will also be re-emphasized as ptrt of the periodic retraining on DESP It should also be noted that - the root cause for this event was determined and corrective actions were identified primarily by oersonnel who were 'not part of the Design Engineering Section at the time that the violation occurred. Thus, we feel that an independent assessment of this incident has been performed, and that the cause and appropriate corrective actions have been identifie . Renulatory Reportine Requirements fer Non-Conformine items Flow charts have been prepared which outline the thought process which is expected of engineers as they review items which are assigned to them for evaluation. The flow charts have been distributed to all of the engineers in the Design Engineering Section. Training sessions were held with these engineers, on December 5 and 9, 1988, to re-emphasize the importance of addressing deportability and operability with respect to Technical Specifications along with all design issues. We believe that our staff has a clear understanding of the requirements to address regulatory reporting requirement A sample of 52 Non-Conformance Reports (NCRs) were reviewed by the Quality Assurance Deputment to assure that the deportability and safety significant issues were adequately addressed. The review identified no ne, reportable or safety significant NCRs. The review did identify several potential deficiencies in our NCR review process. These potential deficiencies and their suggested corrective actions are currently in the process of being prepared for presentation to plant management for review. The Quality Assurance Department presently adds standard wording to Non-Conformance Reports to require that certain questions be addressed on operability and deportability as part of the response to the NC . .

Procedures will be developed and revised to assure that events and review items are properly screened for deportability requirements. These procedures shall implement the flow charts and other controls to assure that the regulatory reporting requirements for non-conforming conditions are addresse The estimated completion date for these procedural changes is April 7, 198 . Conclusion Calvert Cliffs is presently in full compliance with 10 CFR 50, Appendix B, Criterion Ill The cause and appropriate corrective actions have been identified and implemented to assure that 10 CFR 50, Appendix B, Criterion III is not violated again in the future. Adequate controls are in the process of being implemented to assure that regulatory reportinE requirements for non-conforming conditions are properly addressed at Calvert Cliff _ _ _ _ - _ _ _ _