IR 05000317/1990081

Insp Repts 50-317/90-81 & 50-318/90-81 on 900305-09.No Violations Noted.Major Areas Inspected:Results of Licensee Commitment Implementation Assessment Project

ML20033G935
Person / Time
Site:	Calvert Cliffs
Issue date:	03/27/1990
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20033G934	List: IR 05000317/1990081 ML20033G933
References
50-317-90-81, 50-318-90-81, NUDOCS 9004130127
Download: ML20033G935 (19)

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f U. S. NUCLEAR REGULATORY COMMISSION

REGION I

i 50-317/90-81 Report Nos.:

50-318/90-81

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50-317

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Docket Nos.:

50-318 DPR-53 License Nos.: OPR-69

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t Licensee:

Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203

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i Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 l

Inspection At: Lusby, Maryland

Inspection Conducted: March 5-9, 1990 Inspectors:

D. Vito, Team Leader, DRP M. Banerjee, Resident Inspector, Oyster Creek

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P. Kelley, Resident Inspector, Indian Point Unit 2

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S. Pindale, esident Inspector, Salem Generating Station l

F. Burrows NR 4 ctrical Systems Branch

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Approved by:

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8 4. Cow 9 04, Chief

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actor Projet#s Section No lA i

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Inspection Summary:

Inspection on March 5-9, 1990 (Combined Inspection Report Nos. 50-317/90-81 an'a 50-318/90-81)

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Areas Inspected:

Special announced team inspection of the results of the licensee's Commitment Implementation Assessment (CIA) Project.

Results:

No violations or deviations were identified.

The inspectors con-

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l cluded that the results of the CIA Project provide reasonable assurance that, l

with the exception of the previously identified Low Pressure Overpressure Pro-l tection issue, prior commitments have been adequately addressed and no new

issues of potentially high safety-significance remain unidentified, l

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DETAILS 1.0 P_ersons Contacted The inspectors interviewed various personrel from the licensee's manage-

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ment and technical staff and from the Quality Assurance Department during

the course of the inspection. The key licensee management representatives in attendance at the exit meeting on March 9,1990 are listed on Attach-

ment A to this inspection report, i

2.0 Background

,I During an Enforcement Conference on January 18, 1990, in response to find-

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ings detailed in NRC Special Inspection Report Nos. 50-317/89-31 and

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50-338/89-32, NRC Region I management questioned the licensee's r.bility to manage commitments. Thi! concern arose from the discovery that BG&E

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had not fully addressed commitments made to the NRC related to the areas

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of Low Temperature Overpressure Protection, Electrical Equipment Environ-

mental Qualification and the Post-Accident Sampling System.

BG&E indi-cated that it has not historically maintained a centralized commitment i

management program and that the curren*, system of maintaining historical

commitments relies heavily on corporate memory and is generally informal.

The licensee committed, dering the Enforcement Conference, to define and

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implement a process for managing regulatory commitments.

Specifically,

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the licensee committed in a letter to NRC Region 1 date January 25, 1990,

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to initiate a near-term project to objectively assess i effectively they

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. have his ttrically identified, implemented and maintained commitments made

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to the NRC. The licensee also committed in this letter to the development of a detailed plan and schedule for a comprehensive, long-term, commitment L

management system to be submitted to NRC by April 30, 1990.

Supplement 1 to ConfirmM.ory Action Letter 89-08 was issued by NRC l

Region I on February 1,1WO acknowledging the licensee's statements and requesting them to (1) complete the near-term assessment described in the

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January 25, 1990 letter, (2) determine the safety significance of any i

deviations identified, (3) resolve a.1y mode change-restraining issues, (4) schedule the resolution of any issues that are not mode change-restraining, and (5) document the results of the near-term assessmcat in a

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report to the NRC. The licensee submitted a summary of the results of the

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near-term Commitment Implementation Assessment (CIA) Project to Region I on February 19, 1990.

The purpose of this team inspection was to evaluate whether the licensee had fully accomplished the tasks which were defined as part.of the CIA Project and to assess the project results in terms of their validity and ability to provide an indication of the licensee's effectiveness in historically identifying, implementing, and maintaining commitments.

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3.0 Evaluation of CIA Project

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3.1 CIA project DeJeription The CIA Project consisted of four separate tasks with the goal of providing an assessment of BG&E's ability, during the years since initial licensing, to identify, implement and maintain commitments made to the NRC.

The four tasks were as follows:

Task 1 hepresentative Commitments Review An evaluation of the documentation related to a selected sample

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of historical commitments to provide an indication of BG&E past performance in.commitr.<:r: management.

Task 2 - Quality Assurance Audits Review A review of past Quality Assurance audits to obtain a qualita-

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tive assessment of how Quality Assurance has historically viewed DGLE's commitment management process.

Task 3 - NpC Inspections Review A review of past NRC Inspection Reports to obtain a qualitative

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assessment of how NRC inspectors have historically assessed BG&E's past performance in meeting commitments.

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Task 4 - Industry Experience Review Other nuclear utilities were polled in an effort to determine

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it.du stry and NRC expectations on performance in meeting commitments.

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The findings identif(ed by Tasks 1, 2 and 3 as unresolved commitments were evaluated by E4 licensee in terms of safety-significance to determine if any esditional issues of high safety-significance have been overlooked.

3.2 Evaluation of Task 1 - Representative Commitments Review The intent of this task was to evaluate a population of selected NRC safety issues to determine BG&E's ability to effectively identify, implement, and maintain commitments related to those issues.

In order to qualitatively assess their ability to address NRC issues of potentially high safety-significance in the past, the licensee selec-ted issues which, in their opinion, had greater potential to bring

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out an item of high safety-significance.

The issues were designated as either large-scope or small-scope.

Large-scope issues were

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k selected by a committee of expar enced BG&E personnel who nominated i

i candidate issues from thef? recollecti n of issues which required major response efforts and involved signd icant management attention.

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The sniall-scope issues were selected from the licensee's knowledge of significant response efforts to NRC Bulletins and Generic Letters which were not identified by the large-scope issue selection process,

$1x (6) large-scope issues and 12 small-scope issues were se1Neted t

for evaluation out of a larger list of candidate issues. A listing

of the selected issues is included in Attachment B to this inspection

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report. The selected issues were assigned to individual team leaders

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who were responsit for the evaluation of commitments as defined in

the procedures ano training developed specifically by the licensee 1 for the CIA effort, The CIA team leaders and their assigned team i

members reviewed available subject-related and chronological corres-

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pondence files for documentation related to each issue. The accumen-tation was then evaluated for commitments made to NRC, Commitments

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were defined as written direction from HRC or BG&E written statements to NRC that certato actions would be taken in. response to NRC

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concerns.

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Comitments were selected for evaluation based on selection criteria defined in CIA Project Procedure CIA-90-02, Rev. O Commitment Selec-i tion Evaluation Basis. The commitments were selected based on one or more of the following factors:

commitment affects batic plant safety functions

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commitment involves multi-departmental actions to accomplish

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commitment pertains to equipment or activities which appear to

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be risk significant (based o.1 core damage)

commitments chosen to reflect a balance of one-tiae and long-

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e term commitments

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commitments chosen to reflect a balance of hardware at d nro-

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grammatic con:mitments i

commitment reprasentative of RG&E actions in the past, both

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positive and negative

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The commitment selection criteria were developed to focus on those

comitments which offered the highest potential to uncover an issue of high safety-significanco if the commitments had not been met.

Although the commitm6 hts evaluated did not represent a statistically significant sample, the inspectors determined the licensee's commit-ment selection process to be appropriate for the intended result (i.e., a qualitative assessment of BME's ability to have histor-ically addressed NRC issues of potentially high safety-significance).

The selected commitments were then researched to determine W, ether or not they had been fully resolved.

Those contitments which were identifitd as missed or unresolved were then evaluated in terms of safety significance.

The following criteria were provided to CIA Project members for the determination cf safety-significance:

HIGH Safety-Significance

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For the most limiting design basis event, no redundant or alter-native manns remains af ter a single failure is postulaf.ed.

No train remains available for the accomplishment of a. required safety function.

MEDIUM Safety Significance

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For the most limiting design basis event, one redundant or alternative means remains after a single failure is postulated.

One train remains available for the accomplishment of a required safety f.inction.

LOW Safety-Significance

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For the most limiting design basis event, at least two redundant or alternative means remain after a single failure is postu-lated. At least two trains remain available for the accomplish-ment of a required safety function.

NO Safety-Sfgnificance

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1, 2 and 3 above do not apply.

Any unresolved issues associated with the implementation of these missed comitments were documented on a Non-Conformance Report and scheduled for resolution.-

A totsi of 131 commitments were stlected out of the large-scope and small-scope i< sues for verification.

Ten (10) of thew dommitments were determineI to be missed. As a result of the licensee's safety-significance etniuations, 3 of the missed commitments were assigned a LOW 1evel of :.afety-significance and the other 7 were evalut.ted to be'

of N0 safety significance.

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The inspectors requested the licensee to review additional documenta-i tion for historical commitments during the inspection. $pecifically, l

the inspectors requested the licensee to investigate the following i

issues:

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1.

Two additional large-scope issues that were on the candidate

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list but were not originally selected for evaluation under CIA l

Tast 1.

The additional issues were Natural Circulation Cooling and Motor Operated Valves (MOVs).

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The additional commitments (those not selectsd for CIA Task I review) out of one of the originally selected large-scope issues (Main Steam Line Break).

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Two additional small-scope issues selected at random by the inspectors.

The issues were NRC Bv11etin 88-04, Potential

Safety-Related Pemp Loss and Bulletin 88-10 Non-Conforming

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Molded Case Circuit Breakers.

This additional review allowed the inspectors to evaluate the effec-l tiveness of the CIA process as well as to have a larger number of evaluated connitments upon which to base their conclusions.

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The inspectors reviewed both the research documentation collected and I

the CIA evaluations developed for all of the commitments examined to determine (1) if the licensee had effectively identified the commit-

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ments from the available documentation, (2) if the licensee could

effectively determine if a commitment had been missed, (3) if the

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licensee had performed an adequate safety-significance evaluation for

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each of the missed connitmonts, and (4) if any issues of high safety-

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significance were identified and remain unresolved.

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The inspectors determined that the commitment definition was appro-priate and that the licensee could effectively research and identify l

historical commitments.

The inspectors also determined that the licensee could discern whether a commitment had been missed.

The inspectors concurred with the licensee's assessment that no unre-i solved issues of high safety-significance had been identified by CIA

Task 1.

The review of the additional commitments (41 total) during the week of the inspection revealed no missed commitments.

The inspectors did however, question the thoroughness of some of the

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licensee's safety-significance evaluations for the missed commitments i

identified by CIA Task 1.

The inspectors found that, in some cases,

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there was not enough information to provide a firm basis for the

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determined safety-signii'icance level.

Examples are noted as follows:

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Plant Shielding Issue #2 Post-TMI requirements called for a review to be performed on safety equipment that may be degraded by radiation fieldt during post-accident operation. An electrical equipment qualification (EQ) review was performed but documentation of a mechanical equipment qualification review could be neither identified nor located. This issue was assigned a LOW 1evel of safety-signifi-cance.

The issue was documented on a Non-Conformance Report and submitted for-resolution and/or additional safety review (POSRC).

The inspectors questioned whether the CIA investigation had

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presented enough information to support the LOW 1evel of safety-significance determination.

The safety-significance evaluation was based primarily on a February 1990 review of the LPSI pump teflon seals which states that they would survive accident radiation doses.

The inspectors noted that there is other equipment which can be affected by radiation which was not part of the review.

The safety-significance level could change depending on other equipment which may be affected.

After further investigation, the inspectors discovered that the original specifications for plant mechanics) equipment addressed the effects of radiation on equipment operation and that know-ledge of this was factored into the licensee's decisionmaking for the determined level of safety-significance. A discussion

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of this information in the original safety-significance evalua-tion would have provided a better justification for the deter-mined safety-significance level.

In addition, if a later mechanical equipment qualification review is to be performed, the safety-significance level for this issue could potentially be raised to MEDIUM.

The inspectors concluded that there was minimal likelihood of identifying a situation which would affect safety systems to a point where a assignment of a HIGH safety-significance level would be warranted.

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Generic Letter 88-05 - Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components on PWR Plants.

The Generic Letter called for the implementation of a program to monitor boric acid leakage.

The licensee identified the weak implementation of a commitment in that the established boric acid corrosion monitoring program only referred to general areas for inspection instead of a specific listing of vulnerable com-ponents. The licensee assigned a LOW 1evel of safety-signifi-cance to this issue based on a " leak-before-break" assumption.

The Generic Letter however, stated one example of a catastrophic leak which occurred af ter valve studs had corroded and subse-quent movement of the valve resulted in failure.

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Otscussions with the licensee revealed that the " leak-before-break" assumption was the basis for the selected boric acid corrosion inspection interval in the procedure developed in response to this Generic Letter, and not necessarily for the safety-significance evaluation.

A conservative assumption for the safety-significance evaluation would have been to assume a catastrophic failure similar to that described in the Generic Letter.

Subsequent safety reviews by way of the Non-Conformance Report process could possibly result in the escalation of the safety-significance level if it is determined that strategic safety-related equipment were to be affected.

However, the inspectors concluded that it would be very unlikely that the safety-significance level could be escalated to HIGH since it would be dif ficult to postulate a situation which would affect'

redundant or' alternate safety systems simultaneously.

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Plant Shieldng Issue #7 Post-accident dose drawings reflecting shielding configurations and dose rates had not been properly maintained during subse-quent floor plan changes.

Also, the calculations to determine post-accident dose rates at the emergency personnel airlock were found to be incorrect. A design change request was initiated in 1987 to revise the Post-Accident Radiation Oose Rate Maps but the change was never initiated.

The calculated doses increased by a f actor of 20 (from 200-300 R to 4000-6000 R).

The licensee determined the safety-significance level to be kONE based on the administrative nature of the deficiencies and the f act that equipment was not affected. The inspectors noted that the licensee did not address either the acceptability of the higher dose values or equipment access considerations during post-accident conditions.

Further discussions with the licensee revealed that the initially determined safety-significance level was accurate because (1) access to safety-related equipment post accident would not be affected by this problem and (2) existing emergency response procedures would effectively control access to this area post-accident.

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Generic Letter 81-14 - Seismic Qualification of Auxiliary Feed-water Systems.

On March 14, 1984, the licensee committed to maintain a seismic qualification report for manual valves in the Auxiliary Feed-j water System.

This qualification report could not be found.

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The licensee assigned a safety-significance level of NONE to this issue, citing it as a simple documentation problem.

The inspectors questioned whether the licensee had confirmed that no subsequent modifications had been made to the Auxiliary feed-water System that could have affected the seismic integrity of the system. The Non-Conformance Report which was generated sub-sequent to the CIA review of this issue only documented that the evaluation was lost.

It contained no recommended actions, such as recovery of the qualification report or identification of Auxiliary Feedwater System modifications.

The licensee stated that they assumed that their design change process works properly and that seismic integrity would have been addressed for any modifications performed.

Also, further review demonstrated that th9 Auxiliary Feedwater System, includ-ing the manual valves in question are maintained under the licensee's seismic qualification program.

None of this ration-ale was discussed in the safety-significance evaluation.

After being provided with the additional information, the inspectors concurred with the initially determined safety-significance level.

The inspectors concluded that while no issues of HIGH safety-signifi-cance had been identified, the CIA Task 1 safety-significance evalua-tions could have been aodressed more thoroughly. While the safety-significance level definitions were appropriate, the team leaders were not provided with instructions on how to classify situations that did not specifically fit any of the definitions or how to expand their evaluation for situations where a non-equipment-relatand concern may indirectly af fect plant safety (e.g., effect of dose on post-accident equipment access, affect on emergency response efforts).

The licensee stated that the team leaders were instructed to use their best judgement, based on the information gathered during the CIA effort, to evaluate safety-significance.

Any further safety reviews would be addressed through existing Calvert Cliffs safety review processes (e.g.,

NCR process, POSRC, Independent Safety Review).

The inspectors requested that the licensee pay particular attention to the determination of safety-significance and reportability in the implementation of their proposed long-term commitment management sys-Program implementation controls shall ensure thut safety-tem.

significance and reportability concerns for historical as well as current issues are brought forward and addressed as quickly as possible.

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3.3 Evaluation of Task 2 - Quality Assurance Audits Review

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The licensee reviewed all available Quality Assurance audits, sur-veillances, and evaluations and Joint Utility Management Audit (JUKA)

reports from 1973 to 1989 (1118 reports total) for all t:ferences to NRC regulatory and safety issues.

The references were evaluated to r

identify NRC commitments.

l The review resulted in the identificatinn of 248 instances of i

apparent NRC commitments in the audit reports. An initial assessment

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of the audit statements indicated that 98 of the 248 commitments were initially not met.

The licensee reassessed the nature of the indi-i vidual commitments in an attempt to provide an explanation for the i

large number of commitments identified as initially not met.

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subsequent evaluation revealed that the tendency of Quality Assurance j

auditors to be as conservative as possible in identifying off-norma)

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conditions resulted in a number of findings which did not meet the

definition of a commitment presented in CIA Task 1.

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many (51) of the 98 " missed commitments" identified by CIA Task 2

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were in reference to regulatory guidance which the licensee had not

committed +o in writing.

These issues were reclassified by the i

licensee as "sof t" commitments.

An additional 12 of the initial 98

" missed commitments" were determined, af ter reassessment, not to be l

commitments at all.

The large majority (72) of the 86 remaining t

commitments (51 "sof t" commitments and 35 "hard" cominitments) were

resolved as part of the initial audit process by the presentation of i

additional information to the auditors which allotted them to close

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out the concern. 1he remaining 14 issues were classified as actual unresolved cemmitments.

These unresolved commitments were then evaluated by the licensee for safety-significance.

The inspectors reviewed the commitments identified by CIA Task 2 and i

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concurred with the licensee's redefinition of the initially identi-

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fied commitments in order to discern the actual number of unresolved

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commitments.

None of the 14 unresolved commitments were identified

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by the licensee as being of HIGH safety-significance.

Eleven (11)

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were assessed as having N0 safety-significance. The other three were assessed as having a 1.0W 1evel of safety significance,

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tions for the 14 unresolved commitn.ents and concurred that no issues i

of HIGH safety-significance had been identified.

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inspectors again expressed a concern with regard to the thoroughness

of two of the safety-significance evaluations.

The concern was l

similar to that noted previously in the discussion of the CIA Task 1 I

safety-significance evaluations.

Those safety-significance evalua-

tions which were questioned are described in the following:

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CIA Task 2. Unresolved Commitment #2 - Inadequate MOV Thermal Overload Heater Sizing This unresolved commitment was derived f rom a finding which resulted from a BG&E internal Safety System Functional Inspec-tion (S$FI). The finding stated the MOV thermal overload heater sizing methodology was inadequate to endure MOV operability dur-ing design basis conditions and that improper safety-related equipment operation may result.

The methodology had been originally established by BG&E in 1981 te meet the intent of NRC Regulatory Guide 1.106.

The licensee assigned a safety-significance level of NONE to this issue based on an engineering review of the MOV thermal overload heater sizing methodology which stated that the cur-rently used methodology was adequate even though it was not in accordance with Reg. Guide 1.106 guidance.

The inspectors questioned why the safety-significance evaluation reflected the enginetring staff's evaluation and not the SSFI auditor's assessment.

The licensee responded that a Quality Assurance auditor would normally request an assessment from the responsible engineering department in order to clarify the significance of a finding.

While the inspectors acknowledged the need for Quality Assurance auditors to seek clarifying information with regard to technical issues they are not familiar with, this situation presented the

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CIA project evaluators with opposing technical assessments, i.e., one from the internal $$FI and one from the responsible enp neeting department.

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If.icher investigation by the NRC inspection team revealed that BG&E routinely reviews new industry guidance and NRC communica-tions in the MOV area as part of its ongoing MOV program. This continuing ovaluation of current guidance is encouraged by the recent NRC guidance on the MOV issue (NRC Bulletin 85-03 and NRC Generic Letter 89-10). Changes to calculations as a result of these evaluations are made as appropriate and in accordance with 10 CFR 50.59 requirements.

Thus, the differences between the 1981 BG&E methodology and currently used methodology have been evaluated and justified.

The inspectors concluded that the safety-significance evaluation (NONE) was justified, Had this issue been explored in more detail during the CIA effort, the resulting safety-significance evaluation would have been more easily understood.

In fact, the evaluation may have led to a conclusion that the commitment was not " missed" in the first plac,.

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CIA Task 2. Unresolved Commitment #2 - Technical Support Center (TSC) compilance with specified regulatory guidance.

This Quality Asburance finding stated that BG&E has not verified whether certain Technical Support Center equipment (computer,

ventilation systems) will re-energize within 50 minutes follow-ing an accident which involves a loss of power to the equipment.

l The licensee assigned a safety-significance level of NONE to

this issue because it deals with non-safety-related equipment

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and personnel dose considerations.

The inspectors noted that

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while this issue does not deal with safety-related equipment,

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NRC guidance (NUREG-0654 and NUREG-0696) specifically discusses i

the Control Room proximity requirements for the TSC and the intent that the TSC be able to provide accident mitigation sup-i port to the Control Room for the duration of the smergency

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response effort.

While the inspectors did not feel that the

reevaluation of this issue with respect to the noted NRC guid-r ance would necessarily raise the level of concern to one of i

MEDIUM or HIGH safety-significance, it would have provided the

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licensee with information as to how they formally documented (or

did not document) differences from the NUREG-0696 requirements f

for emergency response facilities.

The licensee has identified the issue via the Non-Conformance

Report process as one which is to be resolved as part of the restart effort.

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The inspectors concluded that the results of CIA Task 2 identified

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no issues of high safety-significance.

The inspectors also noted

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from the evaluation of the initial 248 commitments identified that

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Quality Assurance has routinely performed survaillances of BG&E

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efforts in response to NRC safety issues.

l The inspectors also questioned the licensee as to the meaning of a summary assessment statement on Page 10 of the February 19, 1990 CIA

Project Report that " reliance on Quality Assurance to meet commit-l ments has led to concerns in the Quality Assurance organization about i

BG&E's effectiveness in meeting commitments." Based on further dis-

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cussions, the inspectors concluded that this statement was intended

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to indicate that Quality Assurance efforts have somewhat compensated

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for the lack of a formal process for controlling commitments in the past. The licensee concurred with this assessment.

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3.4 Evaluation of CIA Task 3 - NRC InspectionjL eview R

The licensee reviewed all NRC inspection reports (572 total) gener-ated from 1973 to 1990 for statements which were indicative of BG&E's effettiveness in meeting commitments related to significant NRC issues (Bulletins, Generic Letters, Post TMI Items, etc.).

This review was intended to provide a purely cualitative assessment of BG&E's ability to address commitments, similar to the intent of the CIA Task 2 review.

CIA Task 2 reviewers were instructed to look only for negative com-ments from NRC inspectors which criticized BG&E's implementation of commitments.

The review scope was further narrowed to e# "'e two other types of apparently negative comments.

These other tv is of comments were (1) a comment in which the inspector disagreed >ith the licensee's interpretation of requirements or (2) a comment in which the inspector judged the licensee's response to be insufficient. The licensee's rationale for the exclusion of these types of statements from further review was that while these types of comments were indi-cative of a disagreement, the commitment itself had been addressed.

As a result of the narrowed scope of review, the CIA Task review resulted in the identification of only 8 negative comments. Five (5)

of these comments were assessed to be of N0 safety-significance. The other three issues were determined to be those which prompted the CIA Project, i.e., l.ow Teniperature Overpressure Protection, Environmental Qualification, and the Post-Accident Sampling System, which were

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assessed safety-significance levels of HIGH, MEDIUM, and LOW, respectively.

While the inspectors agreed with the safety-significance evaluations performed for this CIA Task, they concluded that the narrow scope of the review criteria had essentially predisposed the results to the identification of broad ccope issues.

Had the review included the

"other types" negative comments noted above, some moru specific issues may have been brought out.

3.5 Evaluation of CIA Task 4 - Industry Experience Review Task The licensee surveyed 16 U.S. nuclear utilities in an attempt to determine if any of.them were aware of formal guidance or acceptance criteria from NRC with regard to the format and content of commitmant tracking or commitment verification systems. The licensee was also interested in finding out if other licensees have ever performed a comparable ef fort to the CIA Project or had established formal goals of success rates on completing commitments.

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The licensee obtained no conclusions from this Task. The NRC team noted that they were not aware of any specific NRC acceptance cri-teria or guidance for commitment management strategies.

It is the responsibility of the utility to determine what type of commitment management system will work best within its organizational structure.

3.6 Licensee Conclusions from CIA Project The licensee concluded that four mechanisms were discovered by way of the CIA Project which contributed to the missed commitments iden-tified.

These were:

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Failure to implement a commitment due to unclear assignment of responsibilities between organizations.

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Inadequate expectations or misinterpretation of the requirements by the implementor without adequate internal verification.

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Failure to effectively communicate the status of a commitment between the implementing organization and Licensing, or between Licensing and the NRC, 4.

Loss of a properly implemented commitment through change becadse the reason for a requirement could not be readily identified or related drawings were not annotated.

The inspectors acknowledged that the noted failure mechanisms were appropriate categorizations of the missed commitments identified by the CIA Project. However, the inspectors did not analyze the missed commitments in detail for root cause mechanisms because of the small commitment sample size. The licensee will perform root cause evalua-tions for the missed commitments identified during the implementation of the proposed long-term commitment management system.

The licensee concluded that the results of the CIA Project demon-strated that BGLE has identified, implemented and maintained commit-ments made to NRC that are important to the safe operation of Calvert Cliffs.

The inspectors concurred with the licensee's conclusion and stated that they had been given reasonable assurance that there are no other issues of high-significance other than the previously iden-tified Low Temperature Overpressure Protection issue which remain unidentified.

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4.0 Current Bud Commitment Management Process The inspectors held discussions with the licensee with regard to their current process for managing commitments to determine its adequacy in the interim period unti) the long-term, comprehensive, commitment management system is fully implemented. The inspectors were not able to evaluate the effectiveness of the current commitment management process from the results of the CIA Project due to the limited sample site of commitments evaluated.

Prior to 1987, commitment control at BME was largely informal. Knowledge of departmental responsibilities t:as depended upon to ensure that safety issues were responded to end commitments were maintained.

In 1987, the Licensing Department began to track commitment items by way of a manually generated database.

Also in that time frame, Licensing assumed the responsibility for the initial assignment of commitments.

Commitment tasks are now assigned at the General Supervisor management level.

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process is administrative 1y controlled by a procedure (Calvert Cliffs Instruction 001 154) which discusses line function responsibilities in responding to NRC documents.

More recently, the Licensing commitment tracking system has been expanded and more formalized as part of the Performance Improvement Plan (PIP).

The current system tracks all commitments made in responses that BME sub-mits to NRC. The system does not identify requirements from most incoming

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NRC correspondence (Bulletins and Generic Letters) as commitments.

Incom-ing NRC correspondence is assigned to responsible departments for initial resolution and commitments which result from the initial BME response to the document are then entered into the commitment tracking system.

This arrangement prompted the inspectors to inquire how NRC Inspection Report findings are addressed.

The licensee stated that they are similarly assigned and the numbered findings are tracked individually. The licensee also stated that they have acknowledged that NRC inspectors will often note commitments that the licensee has made without assigning an inspec-tion report tracking number.

These commitment " statements" are extracted from the inspection reports and assigned and tracked accordingly.

The inspectors verified that these items are included on the commitment track-ing system database.

The computer program for the current commitment tracking system database also includes reporting capabilities to assure that responsible depart-ments are periodically reminded of commitment responsibilities.

For NRC commitments, a weekly report is distributed which provid0s responsible managers with a two-week look-ahead.

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The inspectors concluded that the existing commitment tracking 6,atem appears to be adequate to manage present and future commitments until the long-term, commitment management system is implemented.

The inspectors also requested that the licensee's April 30, 1990 submittal which is to discuss the schedule and plan for the long-term commitment management sys-tem also discuss the capabilities of the current system and how it will be maintained as the "new" system is developed.

The licsnses indicated that this information was to be included in the April 30, 1990 submittal.

5.0 Inspection Conclusions The overall conclusions of the inspection team with regard to CIA Project implementation and other commitment management issues are as follows:

1.

The inspectors concluded that the licensee had implemented the CIA Project as stated in their letter of February 19, 1990 2.

The licensee clearly demonstrated the ability in all the CIA Tasks to identify commitments and discern those that had been missed.

3.

The inspectors determined the licensee's commitment selection process for CIA Task 1 to be appropriate for the intended results (i.e.,

qualitative assessment of BG&E's ability to have historically addressed NRC issues of potentially high safety significance.)

4.

No new issues of high safety-significance were discovered durif#g the commitment evaluations, including the additional commitments (41)

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which were evaluated during the inspection.

This permitted the inspection team to conclude that they had been given reasonable assurance that there are no other issues of high safety-significance (like the previously identified Low Temperature Overpressure Protec-tion issue) which remain unidentified.

The inspectors noted that this assessment was purely qualitative since the sample size of com-mitments evaluated could not provide a statistical basis for the assessment.

5.

The licensee's safety-significance evaluations could have been more thorough for the missed commitments identified by the CIA Project.

The licensee shall consider the performance of safety-significance evaluations and reportability evaluations to be important parts of the implementation of the long-term, comprehensive commitment manage-ment program.

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The licensee has scheduled the unresolved issues which have resulted from the CIA Project for resolution by April 30, 1990.

One issue, the teflon seals for the LPSI pumps, has been designated as a mode change-restraining issue and has been prioritized for resolution.

7.

$1nce the over411 assessment of the results of ths' CIA Project can only be qualitative, the licensee shall make provisions during the implementation phase of the new commitment management system to up-date the NRC on the quantitative results of commitments identified vs. commitments missed and the relation of missed commitments to safety-significance.

The licensee shall perforr. root cause evalva-tions for missed commitments identified.

Historical commitment implementation problem areas which are identified shall be brought to the attention of the NRC.

8.

The licensee shall take lessons learned from the CIA Project into the development of a new, comprehensive commitment management system.

The licensee has indicated that this new system will address ongoing as well as current commitmeats to assure that previous commitments have not been missed or inappropriately altered.

9.

The licensee shall assure that other ongoing BME efforts which involve in the assessment of historical information, such as Proced-ures Upgrade Program basis capturing, are incorporated into the new commitment management system.

The licensee's incorporation of lessons learned from the CIA Project into the new commitment management system will be evaluated during future NRC inspections of this area.

6.0 Exit Meetina The NRC team leader met with the licensee representatives listed in Appendix A of this report at the end of the inspection. The team leader summarized the efforts of the inspection team and presented the con-clusions of the inspection as described in Section 5.0 of this report.

Licensee management acknowledged the conclusions and indicated that they would be considered accordingly in their current commitment management system and in the policies and administrative controls to be developed for the long-term commitment management system.

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ATTACHMENT A Attendees at March 9. 1990 Exit Meetino Baltimore Gas and Electric A. Anuje, Supervisor, Quality Assurance audits G. Creel. Vice President, Nuclear Energy C. Cruse, Manager, Nuclear Engineering Services Department R. Denton, Manager, Calvert Cliffs Nuclear Power Plant G. Detter. Director, Nuclear Regulatory Matters R. Heibel, Manager. Quality Assurance Services Department J. Lemons, Manager, Nuclear Dutage Management B. Mann, Engineer, Nuclear Regulatory Matters B. Montgomery, Principal Engineer, Licensing T. Pritchett, General Supervisor, Quality Assurance L. Salyards, Principal Engineer, Configuration Management State of Maryland T. Magette. Administrator, Nuclear Evaluations

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ATTACHMENT B

, CIA Project Selected Issues LARGE SCOPE

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Main Steam Line Break Post Accident Monitoring Station Blackout Safety Parameter Display System Plant Shielding Anticipated Transient Without Scram SMALL SCOPE NRC Bulletin 88-01, Defect, in Westinghouse Circuit Breakers NRC Bulletin 87-02, Fastener Testing NRC Bulletin 83-03, Check Valve Failures in Diesel Generator Raw Water Cooling Systems NRC Bulletin 79-24, Frozen Lines NRC Bulletin 78-08, Radiation levels in Fuel Element Transfer Yubes NRC Generic Letter 88-05, Boric Acid Corrosion in Carbon Steel Reactor Pressure Boundary Components NRC Generic Letter 87-06, Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves NRC Generic Letter 86-06, Implementation of TMI Action Item II.K.3.5 NRC Generic Letter 84-15, Proposed Actions to Improve and Maintain Diesel Generator Reliability NRC Generic Letter 83-37, NUREG-0737 Technical Specifications NRC Generic Letter 82-12, Nuclear Power Plant Staff Working Hours NRC Generic Letter 81-14 Seismic Qualification of Auxiliary Feedwater Systems

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