IR 05000317/1992099
| ML20058E560 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/30/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058E559 | List: |
| References | |
| 50-317-92-99, 50-318-92-99, NUDOCS 9312070056 | |
| Download: ML20058E560 (7) | |
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l
CALVERT CLIFFS NUCLEAR POWER PLANT
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REPORT NO. 50-317/92-99 & 50-318/92-99
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1.
BACKGROUND
The SALP Board convened on October 20,1993, to assess the nuclear safety performance of
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Calvert Cliffs Units 1 and 2 for the period March 29,1992, to October 9,1993. The board
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was conducted pursuant to U.S. Nuclear Regulatory Commission (NRC) Management
- Directive (MD) 8.6 (see NRC Administrative Letter 93-02). Board members were:
Wayne D. Lanning (Board Chairman), Deputy Director, Division of Reactor Projects, NRC
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Region I (RI); Charles W. Hehl, Director, Division of Radiation Safety and Safeguards,
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NRC RI; Wayne M. Hodges, Director, Division of Reactor Safety NRC RI; and Robert A.
j Capra, Director, Project Directorate I-1, NRC Office of Nuclear Reactor Regulation. The board developed this assessment for approval of the Region I Administrator.
The performance category ratings and the assessment functional areas used below are defined and described in NRC MD 8.6, " Systematic Assessment of Licensee Performance (SALP)."
II.
PERFORMANCE EVALUATION - OPERATIONS i
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Plant operations were rated as Category 1 in the previous SALP period. Operator performance during major evolutions and plant transients was a strength. Management
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oversight and improved communications contributed to strong operator performance.
Operators maintained a clear and complete understanding of plant conditions. Minor weaknesses were noted in housekeeping in safety-related areas and in fire fighter refresher training.
Operators continued their strong performance during this SALP period. Operators were well
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trained, demonstrated a high degree of professionalism, and maintained a strong nuclear safety-conscious approach toward plant operations. Operators consistently acted promptly
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and according to procedures in responding to plant transients. Plant operators consistently conducted their rounds efficiently, properly communicated their observations to operations
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supervisors, and displayed a questioning attitude. Baltimore Gas and Electric Company's (BG&E's) program to evaluate operator log-keeping activities was in-depth and comprehensive. The licensed operator training program was excellent, as evidenced by a very high pass rate for both initial and requalification exams BG&E's requalification l
training pmgram was noted for its strong planning, administration, and challenging simulator scenarios.
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BG&E implemented a strong shutdown safety program including a number of shutdown i
safety enhancements for refueling outages beginning in 1992. These initiatives were effective
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in ensuring that plant systems required for shutdown safety were always available. However, 9312070056 931130 i
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inadequate control of some activities during the Unit I refueling outage caused three reactor coolant inventory overfill events over a short period of time. BG&E's corrective actions for these events were aggressive. The Startup Review Board functioned effectively in overseeing startup effons and in focusing on safety concerns during the startups following both refueling outages during the period.
Significant event investigations and root cause analyses were consistently thorough, detailed, and appropriately focused on nuclear safety significance and causal factors. Management's i
response to plant events was prompt, safety significance was thoroughly understood, and corrective actions were commensurate with the nuclear safety significance of the events.
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Operations management's focus on and strong support for the event-free operations program l
demonstrated a strong safety perspective. This program was a very good initiative that has l
been successful in reducing the severity and frequency of operator-induced events. BG&E
implemented a strong, multifaceted, self-assessment program to improve the process further
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and support the goal of event-free operation. However, the program was not fully effective
in that four reactor trips and the three reactor overfill events occurred during the period due to operational activities. The causal factors for some of these events included lapses in a questioning attitude, wea'c supervisory control of activities, and inadequate procedures.
The NRC noted other strengths during the period. The Offsite Safety Review Committee
provided thorough assessments of safety-related plant activities. The performance of the Onsite Safety Review Committee was good. Preparations for a severe winter storm and Hurricane Emily were proactive, with nuclear safety the primary focus. Intra-and interdepartmental communications, particularly with system engineering and maintenance, were strong and ensured safe plant ope ations.
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In summary, operators continued their strong performance. The licensed operator training program was excellent. Operator performance during plant transients continued to be a
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strength. BG&E's shutdown safety program was a noteworthy strength. Operations management's event-free operations program was a very good initiative. Self-assessments j
have resulted in improved performance. Significant-event investigations were particularly l
good. Weaknesses in the control of activities during periods of high activity followmg j
refueling have resulted in several unplanned events.
l The operations area is rated as Category 1.
IH.
PERFORMANCE EVALUATION - MAINTENANCE
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Maintenance was rated as Category 2 in the previous SALP period. There was a
centralization of work control and a reduction in the maintenance backlog. There were several instances of inadequate program implementation in work controls, post-maintenance
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testing, foreign material exclusion, scaffolding, and unrestrained transient equipment.
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i During this SALP period, management attention to maintenance produced concrete and measurable improvements. In addition to rework goals being met, there was a significant reduction in control room deficiencies, maintenance order backlog, outstanding priority
maintenance items, and maintenance orders awaiting post-maintenance testing.
Maintenance efficiency improved as a result of several initiatives. Staffing of maintenance engineers and engineering analysts was increased, and they were relocated close to the
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planners. Frontline supervisors were moved closer to the shops. Shiftwork for maintenance personnel, including maintenance engineers, was initiated to provide expanded maintenance coverage during backshifts. Maintenance trending was improved and provided effective feedback to management. A strong maintenance technician training program was implemented.
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Interdepartmental coordination was generally excellent. Meeting formats were revised and i
reorganized to be more productive and informative for operations and maintenance personnel.
A maintenance feedback process was implemented and used effectively.
Corrective actions for some problems identified in the previous SALP evaluation were not fully effective. Poor work practices were noted in the welding program, including NDE.
There was a number of missed quality verification (QV) hold points and QV notifications throughout the period. Foreign material exclusion control was significantly improved but continued to suffer occasional lapses. In addition, poor work control continued to present challenges to plant operations throughout the SALP period. Programmatic weakness was also noted in the control of parts and materials maintained at dropoff points in the facility.
In su..imary, significant improvements were made in reducing maintenance backlogs and meeting rework goals. Management initiatives, such as increased engineering support, e
expanded backshift coverage, and improved maintenance trending, contributed to an overall improvement in maintenance performance. However, corrective actions for previously identified problems, such as foreign material exclusion control and work control practices,
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were not fully effective.
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The maintenance area is rated as Category 2.
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IV.
PERFORMANCE EVALUATION - ENGINEERING Engineering was rated as Category 2 in the previous SALP period. Strengths were noted in
modification engineering, handling of emerging engineering issues, and improved contractor control. Weaknesses were noted in safety evaluation justifications for minor modifications.
Concerns with design adequacy and control were also identified.
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During the current SALP period, engineering management demonstrated excellent involvement in and oversight of engineering tasks and issues while maintaining a strong safety perspective. Engineering goals were established, and comprehensive performance
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measurement and trending methods were used to monitor progress.
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Engineering response to operational events and issues was excellent. For example, the short-term engineering response to self-identification of areas in which a fire could cause the loss j
of both trains of control room air conditioning was excellent. The engineering analysis for fuel pin failures was extensive and maintained a good safety perspective. Response to a user manual error for the Better Axial Shape Selector System was prompt and thorough.
The root cause program was excellent. Operability determinations and corrective actions for emergent conditions were generally prompt and thorough, and demonstrated good
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engineering and the proper safety perspective. For example, Reliability Engineering's evaluation of the effect on Calvert Cliffs of the Millstone 2 loss of offsite power scenario leading to a station blackout and loss-of-coolant accident was thorough and well-documented.
During this evaluation period, BG&E was actively engaged in the development and
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processing of a significant number of licensing actions. In almost all cases, the detailed engineering design and analyses used to support the resolution of these issues were
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comprehensive, well managed, and technically accurate. For example, licensing submittals for the emergency diesel generator project involved the coordinated efforts of all engineering
disciplines and resulted in the submittal of five detailed, high quality reports. Work control on the construction project itself was excellent throughout the period.-
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The life cycle management (LCM) program resulted in an improved and more comprehensive understanding of age-related problems, such as the analog to digital equipment replacement and the salt water system piping replacement programs, and more definitive identification of safety-related system boundaries and interfaces. The LCM program is a comprehensive and detailed program that has resulted in a net safety benefit to the plant.
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A weakness in the design review process resulted in changing an important setpoint of the loss-of-coolant incident sequence timer, which was previously corrected during the EDSFI inspection to prevent overloading of the emergency diesel generators. An alert planning group found the discrepancy during research to resolve a minor drift concern associated with a similar relay.
Inadequate supervision was a factor in some problems that arose during the assessment period. The Unit 2 core was reloaded with a defective fuel assembly. Acceptance of the new spent fuel handling crane was marked by inadequate supervisory control and overall
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inattention to detail. - The weaknesses in the latter event were mitigated to some extent by the Procedure Review Committee showing a strong questioning attitude and good safety
perspective during post-modification testing.
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In summary, significant improvement in engineering was noted during this SALP period.
l Engineering management demonstrated excellent involvement in and oversight of engineering
tasks and issues while maintaining a strong safety perspective. Engineering responded well i
to operational events and issues. Root cause analysis, operability determinations and
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corrective actions for emergent conditions were excellent. Licensing submittals were of high i
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quality. The LCM program resulted in a net safety benefit to the plant. Open engineering items were being effectively addressed. Weaknesses were noted in the adequacy of
supervision of some engineering activities.
The engineering area is rated as Category 1.
V.
PERFORMANCE ANALYSIS - PLANT SUPPORT
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This functional area is new, representing a significant change from the previous SALPs. The i
plant support functional area covers all activities related to plant support functions, including
radiological controls, emergency preparedness, security, chemistry, fire protection, and
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housekeeping controls.
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In the previous SALP period, the radiological controls and security functional areas were rated as Category 1 and the emergency preparedness functional area was rated as Category 2,
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with an improving trend assigned. Performance in radiation protection was identified as a strength because of continued strong performance in maintaining radiation exposures as low as reasonably achievable (ALARA) and dosimetry programs. Significant improvement was
noted in radiological housekeeping, in response to quality assurance audit findings, and in l
radiation protection staffing levels. A weakness was identified in the manifests of radwaste
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shipments near the end of the evaluation period. The effluent and environmental monitoring programs remained highly effective with recognition of the radiation monitoring system upgrade project. The security program was identified as a strength with excellent plant and corporate support, aggressive audit and self-assessment programs, program upgrades, and a well trained and professional security force. Performance in the emergency preparedness
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area was excellent with effective responses to actual events and in the full participation exercise noted. Weaknesses were identified in exercise scenario review due to insufficient
operations input and the insufficient level of detail in emergency action levels to support f
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accurate and timely classifications of fast-moving events.
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i During this SALP period, radiation controls generally remained strong. Radiation areas, contaminated areas, and hot spots were appropriately posted, indicative of good health
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physics technician control and monitoring of radiological activities. There were continued reductions in the numbers of personnel contaminations due to an aggressive and comprehensive commitment oflicensee resources. Strong radiological housekeeping
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continued, while general housekeeping significantly improved. Highly visible activities, such j
as the initiative to remove highly radioactive crud from the Unit 2 spent fuel pool, were l
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l characterized by excellent supervision and detailed ALARA actions that included mockups, i
contingency plans, and extensive dosimetry coverage. The transportation /radwaste program
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improved, especially during the second half of the period.
i However, a significant decline in outage ALARA performance occurred. Weak outage ALARA planning and an apparent lack of strong support for ALARA goals by some plant staff contributed to the Unit I outage having double the budgeted dose and the Unit 2 outage
also significantly exceeding the budgeted dose. A lack ofin-field observations of
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radiological work by ALARA personnel and inaccurate estimates of work activity doses also i
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contributed to poor ALARA performance during these outages. Repetitive problems in high radiation area (HRA) access controls involving outage management and operations personnel
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were symptomatic of a general weakness in HRA access controls for operations personnel.
l Near the end of the period, programmatic weaknesses contributed to two improper entries j
into the radiation control area.
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Performance in the radiological environmental monitoring and effluent control programs
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continued to be strong. An upgraded offsite dose calculation manual and effective programs for measuring radioactivity in process and effluent samples contributed to strong
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performance. Quality assurance audits were thorough and of high technical quality.
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The emergency preparedness program continued to be effectively implemented. Considerable
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resources were expended to improve emergency action level documents. Performance during
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the annual emergency exercise was good; for example, control room operators demonstrated l
a sound safety perspective, emergency response facilities were staffed in a timely manner, t
and effective interfaces were established with state and local governments. The emergency l
plan was appropriately implemented for both events requiring its activation during the SALP period. Site response to the threat of Hurricane Emily was proactive and demonstrated a j
good safety perspective.
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However, some weaknesses were noted in the attention given to some emergency preparednes: program administrative areas. Iror example, emergency kits and lockers were
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not maintained and inventoried and some required emergency plan training was not
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conducted.
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The overall effectiveness of the security program continued to be excellent. Management i
attention and involvement continued at a high level, evidenced by further program
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improvements and enhancements. Maintenance support of security equipment was
sggressive. The creation of a security maintenance support unit resulted in more timely repairs and a significant reduction in manhours expended for taking compensatory measures.
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Overall, the plant support functions continued to be effective and contributed to safe plant
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operations. Although performance in the radiation protection area continued to be effective, significant weaknesses were identified in outage ALARA and access control. There was continued good performance in the emergency preparedness area; however, weaknesses were noted in the attention given to some program administrative areas. Security program i
performance continued to be a strength.
The plant support area is rated as Category 2.
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