ML19324B781

Requests Opportunity to Discuss Stated Questions Re Util Readiness to Restart Plant,Including Licensee Identification of Problem & Root Causes of Problem & Development of Plan W/ Specific Tasks to Be Accomplished for Solving Problem

ML19324B781
Person / Time
Site:	Calvert Cliffs
Issue date:	10/26/1989
From:	Magette T MARYLAND, STATE OF
To:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8911080211
Download: ML19324B781 (3)

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' Maryland Department of Natural Resources s

. Tidewater Administration j

' Tawes State Office Building c~' .'"/ < 580 Taylor Avenue Annapolis, Maryland 21401 Torrey C. Brown, M.D.

William Donald Schaefer Governor Suretary l l

October 26, 1989

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!~ James T..Wiggins, Chief ,

Reactor Projects Branch No. 1 Division.of Reactor-Projects United 6tates Nuclear Regulatory Commission [;

Region I i 475 Allondcle Road King of Prussia,'PA 19406 .

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Dear Jim:

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• ' 1 .In light 'of the upcoming meeting with raltimore Gas and Electric to discuss their readiness to restart Calvert Cliffs, I have several questions .regarding - the NRC's review process for l assessing readiness. Norma.lly, the NRC has required licensees of D'

problem planta to follow a certain aequence of events prior to

l. ' restart.' Generally, for licensees to demonstrate . rendiness to restart a plant in Calvert Cliffs' position, several steps would needLto be taken identify the problem and the root causes of the problem, develop a plan with specific tasks to be accomplished for solving the problem, and demonstrate that these. tasks have not only been completed, but that they have alsobeen effective in solving L -

the problem.

With respect te the Peach Bottom Atomic Power Station readiness-for restart review, all but'the last two of the items listed above had not only been completed, but also had been ,

formally accepted by the NRC prior to scheduling a team inspection.

,3 The team's activities were des!gned to confirm the corrective actions and verify that corrective actions had been completed and had been effective. In the casa of Calvert Cliffs, I am not aware o

'whether the root cauce analyses or corrective actions under the Performance Iraprovement Plan .nplementing Procedures have yet been accepted by the NRC. This is not to say that we believe they have not been accomplished, or successfully completed. We simply do Has not know the status of BG&3 corrective action review by the NRC.

the NRC formally approved any effort expended by any BG&E or, in the information context of the Performance Improvement Plan, submitted to the NRC? We haven't yet received the standard s

documentation of their acceptance.

8911(>60I.11 891026 Telephone: _. NO/

00 7 DNR TTY for Deaf; 301 974-3683 ,

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James.T. Wiggins  !

October 26, 1989 1 Page 2 )

E BGEE has identiflod a list of root causes, as contained in the P1P, which is still undergoing review by the NRC. We casume that i the same root causes which must be identified in order to solve long term problems are those necessary to satisfy Action 2 of the ,

May 25, 1989 Confirmatory Action Letter. Since the CAL requires i identification of root causes, will the NRC ' formally accept (or )

possibly require some modification to) BG&E's root cause portion

.- of the PIP prior to restart, as was the case during the Peach i Bottom review? It is unclear whether the team inspection will be  :

i responsible for reviewing the adequacy and acceptability of root s

4 causes. If so, will the team inspection be responsible for determining whether BG&E has properly identified the correct plan  ;

of attack and list of corrective actions? If not, it appears that L these items will have to be addressed prior to the inspection.

It would seem prudent to establish the acceptability of some of these items prior to the inspection, 'especially the list of corrective actions. BG&E has been aggressively working off a list '

of action items, without any formal notice from the NRC as to the sufficiency 'of the. action items. BG&E risks having to substantially alter or add corrective actions pending formal review and door so at the extreme risk that accomplishing the items may  ;

not satisfy the requirem its of the Confirmatory Action Letter.

I think this-should quickly be resolved. ,

For example, BG&E reduced the size of the work force on site and the number of jobs being worked as one of its corrective #

actions designed to gain control of work activities. That was, I belir4ve, a prudent first step and showed sound judgement on their part, and it appears a straightforward and simple step to verify. {

However, formal NRC review may determine that completing this task ,

may be necessary but not sufficient to address the problem of ,

inadequate control of wod activities. Addressing the issue of ,

suf ficiency (Does BG&E now have proper control of work activities?  !

What level of work is appropriate? What level of work can BG&E adequately control? Can the level of staff now be increased to its  ;

old level? If not the old level, what level? If not now, when?)

probably should be accomplished by reviewing the list of corrective actio.s, not just whether or not the actions listed have been accomplished.

Before BG&E proceeds further on its own initiative to try to correct problems which they hope will hit the NRC target for reauthorization tc restart, the NRC targat should be confirmed.

This way, BG&E can be sure that what they're aiming for is what they're supposed to hit.

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,. ' James T. Wiggins I October 26, 1989 1

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I would appreciate the opportunity to discuss these questions

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l with you or members of the Region I or headquarters staff.

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homas E. M

~p f ett~e, Manager Nuclear Pr rsms ,

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George Creel, BG&E Scott McNeil, NRC'  ?

James Peck, DNR b

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