ML19325C292

Forwards Response to NRC Investigation 1-89-003.Mgt Directives Will Ensure That Any Disagreements Will Receive Appropriate Mgt Attention to Assure Resolution W/Minimal Conflict Between QC Inspectors & Maint Personnel

ML19325C292
Person / Time
Site:	Calvert Cliffs
Issue date:	10/05/1989
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8910160027
Download: ML19325C292 (4)

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BALTIMORE OAS AND I

ELECTRIC

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- CHARLES CENTER P.O. BOX 1476.BAl.TIMORE, MARYLAND 21203 l

Gcomot C. CRttL viet Patuote,t NUCLE AA [hthov ooo eso.....

October 5,1989 s.

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U U. S. Nuclear Regulatory Commission l

Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant j

Unit Nos. I & 2; Docket Nos. 50-317 & $0-318 Reolv to NRC Investination No. 1-89-003 i

REFERENCE:

(a) Letter from Mr. W. F. Kane (NRC) to Mr. G. C. Creel (BG&E),

dated September 5,1969, name subject Gentlemen:

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The fact that an NRC Office of Investigation (01) inspection was deemed necessary to investigate ' alleged violations of employee protection regulations is of great concern to us. The need. for such an investigation, regardless of its outcome, indicated that an environment adverse to impioving safety and quality was perceived to exist at Calvert Cliffs. We are committed to hnproving safety and quality. The findings of your investigation team were in agreement with our own investigations and conclusions that lead to actions contained in our Performance improvement Plan, t

r Attached is our response to your request in Reference (a) for a summary of steps that o

_ have been taken and planned,- and results achieved to address the concerns set forth in Investigation No. 1-89-003. Should you have any further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, h

I GCC/CDS/ dim

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8910160027 891003 PDR ADOCK 05000317 O

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..! October 3,1989

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c D. A. Brunt, Esquire J. E.

Silberg, Esquire R. A.Capra,NRC I

S. A.McNeil,NRC.

W. T. Russell, NRC V. L. Pritchett, NRC.

T.' Masette, DNR j

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C AHACilMENT_(O t

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REPLY TO NRC INVESTIGATION NO.

1-89-003 i

i NRC Investigation No. 1-89-003 validated many of the Quality Control Improvements discussed in our Performance Improvement Plan. The goals of the Quality Control (QC) portion of our Performance improvement Plan are to improve the QC training program, improve the inspection process, and properly prioritize the QC work load. These actions address many of the sources of friction between our QC and maintenance personnel.

Our new QC mission statement calls for implementing a Critical Characteristics Inspection process. The Critical Characteristic Inspection process utilizes plan and hold points which are controlled by QC Procedures representing an integration of design, maintenance, and QC criteria. The QC organization will be organized,

trained, and augmented to ensure this new inspection process is effectively implemented.

These actions will provide QC personnel with a clear definition of the independent verification - of quality and with effective administrative and inspection procedures.

As a by-product of a better inspection process, we expect a better relationship between QC inspectors and maintenance craft personnel.

The specific methods for achieving these actions include root cause analysis training, technical

training, and performance-based training for QC inspectors.

We also continue the preparation of administrative and inspection procedures for QC activities.

We have undertaken extensive actions to assure that maintenance work instructions have i

sufficient detail to reflect the complexity and detail of the work. These actions are part of our Procedures Upgrade Project. We have trained maintenance supervision and planners regarding this issue and have revised - key controlling procedures to require more detail and consistency in maintenance work instructions, The ultimate goal of this project is to prepare and implement procedures of appropriate consistency, detail, and accuracy to maintain high levels of safety and quality. This project will reduce p

future conflicts between QC and maintenance personnel by providing procedures which are less ambiguous and require less interpretation.

L The Maintenance Superintendent has issued instructions to his line supervision on the j

subject of relations with QC inspectors. This memo emphasized that maintenance personnel are to conduct themselves professionally and unemotionally in instances where disagreements occur. Issues that cannot be immediately resolved are to be referred up the supervisory line, as necessary, for resolution. it was also emphasized that both maintenance and QC have the same objective to conduct maintenance in a safe and quality manner. The maintenance line supervision was instructed to ensure that l

maintenance craft personnel understand and abide by this policy.

In conclusion, the changes and initiatives described above will limit future conflicts between our QC inspectors and craft personnel. QC inspectors will be provided with l:

the appropriate training, internal procedures, organizational structure, and inspection process to assist them in performing the required independent inspection function.

Craft personnel have been provided with appropriate management directives and will be -.

3 ATTACliMENT (1) e.~

REPLY TO NRC INVESTIGATION NO. 1-89-003 provided with detailed, accurate, and consistent procedures. These changes will i.

result in fewer situations where interpretations of procedural requirements becomes necessary and, thus, reduces the potential for disagreements between QC and craft personnel-in the future. Management directives will ensure that any disagreements which do occur will receive appropriate management attention to assure resolution with minimal conflict between QC inspectors and maintenance personnel.

We feel that in the past several months, relations between QC and maintenance personnel have improved. We expect to see additional improvements as the actions described above come closer to completion.

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