ML20033E179
| ML20033E179 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/02/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003090254 | |
| Download: ML20033E179 (3) | |
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. BALTIMOR E t
GAS AND ELECTRI I
CHARLES CENTER. P. O. BOX 1476. BALTIMORE, MARYLAND 21203
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March 2,1990 v
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U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318
Response
to Weaknesses identified in Inspection Report
- Nos, t
50-317/89-30 and 50-318/89-31 (a) Letter from Mr. J. P. Durr (NRC) to Mr. G. C. Creel (BG&E),
REFERENCE:
dated January 30, 1990, NRC Inspection Report Nos. 50-317/89-30 and50-318/89-31 e
Gentlemen:
As requested in Reference (a), Baltimore Gas and Electric Company is providing a response to the sub.iect inspection report which concerned engineering support of Calvert C:lffs Units 1
and 3.
Otu actioris taken to strergthen the identified l
weaknesses are povided la Attachwnt (1) j Should you have any further questions regstding this matter, we will be pleased to
'i discuss them with you.
Very truly y)ou s,
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GCC/DWM/db Attachment t
cc:
D. A.' Brune, Esquire J. E, Silberg, Esquire A%
R. A.Capra NRC
. D. G. Mcdonald, Jr., NRC
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]8 f't1@N W. T. Russell, NRC F
J. E. Beall, NRC b
T. Magette, DNR 9003090254 900302 D
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PDC Q.
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A*ITACitMENT (1) 1 WEAKNESS #1
- An excess number of Non-Conformance Reports (NCR) presently are open.'
RESPONSE
The increased number backlog of NCRs represents an increased awareness of the need for problem reporting on the part of - all personnel at Calvert Cliffs. As such, this increase is a healthy sign of improvement. We have taken steps to improve the quality and efficiency of the NCR process. Both the Licensing and Design Engineering organizations have directed resources to enhance the process of reviewing NCRs for safety significance. Increased resources have been directed to the Quality Control organization, which manages the NCR process. Calvert Cliffs Instruction CCI-l l 6, Control of Deficiencies and Nonconformance Reports, is presently undergoing a revision which will serve as a necessary first step toward decreasing the number of NCRs initiated while ensuring that appropriate nonconforming conditions will continue to be identified. We will continue to encourage that NCRs be initiated so that problems get identified and resolved promptly.
WEAKNN #2 "Only approximately 40% of the Maintenance Orders (MO) for February and September of 1989 identified the System Engineer, suggesting less than full identification of the system engineer to those performing maintenance work."
B l$t M in Both the Maintenance Pir,m.er Gnideline (MPG) and Glvert Cliffs Instruction CCI-200, whl:A govetns nuclear naintennce, require that the appFeable engineer's name be identified on the MO. On February 1,1990, the Maintenance Lead Planners were trained on the contents and use of the MPG. One of the specific issues addressed was the need to list the applicable System Engineer'; imme on tle MO.
Ei&K.NlSS #3 "The hck of review of SSFI findings by Design and System Engineers to establish thosr findings that may be applicable to other plant systems."
RESPONSE
The majority of the findings of the recent SSFI were unique in nature in that they dealt with a specific condition or isolated occurrence. Several findings did have generic implications and are currently under investigation for applicability to other systems at Calvert Cliffs, in general, Audit Findings are reviewed to determine if the identified discrepancies may be applicable to other systems or components at the plant. Current BG&E procedures are not clear in the requirement to document such a review. Applicable plant procedures will be reviewed and amended as necessary to reinforce this good engineering practice of considering generic implications.
Appropriate personnel will be trained on the revised procedures.
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ATTACHMENT fI) x L
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WEAKNESS #4 I
The procedure DESP-6 on calculations emphasizes the computational aspect of a calculation but does not clearly define other aspects of the calculation process such as statement of the problem, design basis considerations, and methodology."
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RESPONSE
Design Engineering Section Procedure DESP-6 will be revised to expand and strengthen l
the requirements of calculation process.
The procedure will provide improved i
instructions for the following: Objective / Purpose, Givens / Design inputs, Assumptions,
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and Method of Analysis. Training of applicable personnel will follow the revision of t
DESP-6.
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WEAKNFM #5 l
"A Maintenance Order (Example M.O.
299-161-825C) with an unsatisfactory Post Maintenance Test (PMT) is closed out on the basis of issuing another MO or Maintenance Request (MR). However, the original MO is not shown to be cleared when i
l the Post Maintenance Test is later performed satisfactorily under the subsequent MO l
or MR. This practice is permitted by the procedure on MO processing; 'however, the situation where test results remain noted as unsatisfactory after they have been performed satisfactorily in subsequent work presents increased possibility of bypassing j
a required test."
R129 HSE CCI-200, Appendit 30 governs the PMT program. The procedure requires that a Post j'
Mainter.ance/ Operability Test Docurr.er.t (PMTD) be filled out foc every PMT. In the ever.1 of an unsuccessful test, the number of the new MO/MR is recorded or. the PMTD, l
wMch is combined ' with the old MO/MR for closure. An 'tO c!cred with ar.
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um.atisfactory PMT will include the romber of the subsec;uent MOfMR. It is therdore l
possible.to trace any unsatisfactory test to n subsequent successful one.
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