ML20006B511

Forwards Info Re Commitment Implementation Assessment Project Objectively Assessing How Effectively Util Historically Identified,Implemented & Maintained Commitments Made to NRC

ML20006B511
Person / Time
Site:	Calvert Cliffs
Issue date:	01/25/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	Russell W NRC
References
NUDOCS 9002050007
Download: ML20006B511 (7)

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BALTIMORE GAS AND '

ELECTRIC CHARLES CENTER

• P. O. BOX 1476. BALTIMORE, MARYLAND 21203 Gconot nret January 25, 1990 ve p, NUCLt &R rentPOV (300 #80 A4SS

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U. S. Nuclear Regulatory Commission Washington, DC 20555

> ATTENTION: W. , T. Russell

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Commitment Imnlementation Assessment Project

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Dear Mr. Russell:

1 The Baltimore Gas and Electric Company has initiated a project to objectively assess -r how effectively we have historically identified, implemented, and maintained  !

commitments made to the Nuclear Regulatory Commission (NRC). This project consists ,

of four tasks and is described in the attached scope document.

We will complete this assessment, determine the safety significance of any deviations identified, and resolve mode-change restraining issues, as appropriate. Finally, we '

will present these results to and obtain the concurrence of the Regional Administrator prior to restart.

At the conclusion of this near-term project, we will develop our detailed plan and schedule for the comprehensive and long-term licensing commitment review effort described to NRC Region I staff at the January 18 enforcement conference. This will +

be submitted to you by April 30, 1990.

Should you have any further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, ,

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ATTACIIMENT (1)

. PROJECT SCQfE DOCUMENT TITLE This project shall be known as the ' Commitment Implementation Assessment (CIA)

Project".

GOAL The goal of this project is to provide Calvert Cliffs management with an assessment of the company's historical ability to identify, implement and maintain licensee commitments made to the NRC.

RESPONSIBILITY The Project Manager is L. E. Satyards, Principal Engineer of the Configuration Management Unit. The Assistant Project Manager is B. D. Mann of the Licensing Unit.

The project will report to the Manager, Nuclear Engineering Services until February 1, 1990, and to the Manager, Nuclear Safety and Plannlag thereafter.

METilOD The goal shall be accomplished using four separate tasks. They are: '

l. Representative Commitment Review: Perform an analysis of a representative set of approximately six large scope and 20 other issues containing licensee commitments to the Nuclear Regulatory Commission (NRC) to determine if commitments were ide..~. fied, implemented and maintained properly.

2. Quality Assurance Audits: Identify all available Baltimore Gas and Electric Company (BG&E) Quality Assurance (QA) and Joint Utility Management Audit (JUMA) audits licensee commitments and provide an overall historical assessment of how QA views BG&E's ability to meet those commitments, including strengths and weaknesses.

3. NRC Inspection Reports: Identify and review all NRC Inspection Reports generated from NRC reviews of the implementation of licensee commitments resulting from the "

resolution of generic safety issues and provide an overall historical assessment of how the NRC views our ability to meet those commitments.

4. Industry Experience: Examine the efforts of other utilities who have performed the same type of review of licensee commitments to determine past utility and NRC expectations, suggested methods of analysis, and suggested acceptance criteria.

ATTACllMENT (I)

. PROJECT SCOPE DOCUMENT Any deficiencies noted in Tasks 1 - 3 which have not already been identified shall be reported using the Non-Conformance Report system. This project will not address resolution of outstanding commitments. 110 wever, the safety significance of any identified deficiencies shall be assessed.

DELIVER ABLE The results of the four tasks shall be reviewed and incorporated into a single report and a presentation to BG&E management which shall assess the historical ability of Calvert Cliffs programs and personnel to identify, implement and maintain licensee commitments. The report shall also make a subjective judgment on whether there are pervasive problems with our ability to identify, implement and maintain safety significant NRC commitments.

1 PROJECT SCHEDULE Develop Scope 1/20 Identify Project Manager, Asst. Project Manager and Task Managers 1/20 Receive Approval of Scope and Selected issues 1/22 Select Task i Team Leaders and Team Members 1/22 Receive Task i Files from Licensing Unit 1/24 l Summarize Task 1 Commitments from Issues 1/25 Complete Task 1 Commitment Review 2/01 Task 1 Team Reports Due to Asst. Project Manager 2/03 All Task Reports to Project Manager 2/05 '

Prepare Draft Report 2/07 Final Report Complete 2/12 Brief NRC on Results TBD TASK DESCRIPTIONS Task I: Representative Commitment Review Assistant Project Manacer: Brian Mann, Engineer - Licensing Unit

Description:

Using several qualitative criteria, six representative large scope licensing issues and approximately 20 other licensing issues have been selected for review (see Enclosure 1). Each large scope issue is assigned to a team leader and the other licensing issues are divided between two team leaders. Another set of criteria shall be used to select approximately 60 commitments from the 6 large scope issues and approximately 40 commitments from the 20 other issues.

Each selected commitment shall be identified, documented and researched to ascertain if it was properly identified, implemented and maintained. Any commitments that were not identified, implemented or maintained shall be f _2

. A'ITACilMENT (1)

PROJECT SCOPE DOCUMENT reviewed to determine the safety significance of the commitment and an Non-Conformance Report (NCR) issue. Procedures shall be provided to the Team Leaders to ensure consistency as they assess safety significance of findings and as they document reviews.

The Team Leader, through the Assistant Project Manager, shall have the authority '

to assign responsibilities to General Supervisors and Principal Engineers as needed to accomplish their assigned tasks.

The Team Leaders shall provide the Assistant Project Manager with commitment description packages for each selected commitment and an assessment of how well DG&E identified, implemented and maintained the commitments. The Assistant Project Manager shall provide the Project Manager an overall assessment based upon the information in the Team Leaders' reports. Examples shall be incorporated as appropriate.

The responsibility of the Assistant Project Manager shall be to ensure that a!!  !

issues are reviewed thoroughly and to a consistent level of detail, to resolve resource allocation and schedular difficulties, to keep the Project Manager informed of the progress of the task, to review the Team Leader reports and to prepare the task report.

Task 2: Ouality Assurance Audits Task Mannern Ana B. Anuje, Supervisor - Quality Audits Unit Descrintion:

Identify all available BG&E Quality Assurance and JUMA audits and review them for licensee commitments. When appropriate, show plant follow-up of identified deficiencies. Provide an overall assessment of how Quality Assurance views our historical ability to meet commitments. include examples as appropriate.

Task 3: NRC Insnection Reports -

Task Manacer: Bruce Montgomery, Principal Engineer - Licensing Unit

Description:

Identify and review all NRC Inspection Reports from NRC inspections of Calvert Cliffs implementation of NRC requirements (i.e., Generic Letters, Bulletins, new regulations). Provide a Licensing Unit assessment of how the NRC has viewed our historical ability to identify, implement and maintain licensee commitments.

Include examples as appropriate.

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, ATTACilMENT (1)

PROJECT SCOPE DOCUMEtil Task 4: Industry Evoerience i Task Manacer: Stephen Kale - Consultant

Description:

Review the work of other utilities in commitment identification and verification to determine appropriate methods and forraat. Determine the utility's and NRC's expectations and suggest appropriate acceptance criteria for the project.

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ENCLOSURE (1)

Selected Large Scope lasues i

NUREG 0737,11.B.2 Plant Shielding NUREG 0737,Ill.A. SPDS NUREG 0737,II.F.1 Post Accident Monitoring 10CFR50.62. GL 83-28 ATWS 1 Bulletin 80-04 Main Steam Line Break 4 10CFR50.63 Station Blackout l

Candidate Other issues Generic Letter 88-05 Boric Acid Corrosion of Stainless Steel Piping i Bulletin 88-01 Defects in Westinghouse Circuit Breakers Generic Letter 1/28/87 Requirements for Criminal llistory Checks  !

Bulletin 87-02 Fastener Tests i Generic Letter 87-08 Implementation of 10CFR72.55 Search Requirements Generic Letter 87-06 Periodic Verification of Lenk Tight integrity of Pressure Isolation Valves Generic Letter 86-06 Implementation of TMl item II.K.3.5 Bulletin 85-01 Steam Binding AFW Pumps Generic Letter 84-15 Proposed Staff Actions to improve and Maintain Diesel Generator Reliability .

Gwfic Letter 84-13 Technical Specifications for Snubbers l Garsic Letter 83-37 NUREG 0737 Technical Specifications Op,wle Letter 83-14 Definition of Key Maintenance Personnel Nktia 83-3 Raw Water Failure Check Valves Ceneric Letter 82-12 Nuclear Power Plant Staff Working flours Generic Letter 81-14 Seismic Qualification of AFW Systems -

Generic Letter 4/17/80 NRC Letter Regarding Certification of Personnel Dosimetry Processors ,

Bulletin 79-24 Frozen Lines Generic Letter 12/21/79 Environmental Monitoring for Direct Radiation Generic Letter 4/11/78 NRC Guidance on Radiological Environmental Monitoring Bulletin 78-08 Radiation Levels from Fuel Element Transfer Tubes