ML20034C509
| ML20034C509 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/30/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005040052 | |
| Download: ML20034C509 (12) | |
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n BALTIM ORE GAS AND ELECTRIC CHARLES CENTER. P. O. BOX 1476. BALTIMORE, MARYLAND 21203 I
Otonot C. CnttL vice pareion.o sveis *. t ai an April 30,1990 (800#60 ears U. S. Nuclear Regulatory Commission Washington, DC 20$55 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Description of improvements in the hianagement of Regulatory Commitments
REFERENCES:
(a) Letter from G. C. Crtel (BG&E) to W. T. Russell (NRC) dated January 25,1990, " Commitment Implementation Assessment Project" (b) NRC Inspection Report Nos. 50-317/90-81 and 30-318/90-81, NRC Region 1 Combined Inspection Report Gentlemen:
In order to strengthen our ability to identify, implement and maintain the regulatory commitments for Calvert Cliffs Nuclear Power Plant, the Baltimore Gas and Electric Company has added a new Action Plan to the Performance Improvement Plan: the Regulatory Commitment hianagement (RCht) Project. This Project will establish a fotmal process for managing regulatory commitments. This process will control how regulatory commitments are made or identified, assigned, tracked, implemented, documented, revised, closed and maintained. The RChi Project also includes a comprehensive review of our historic licensing commitments. As we promised in Reference (a), Attachment A contains a description of the RChi Project. This description consolidates and supersedes all of our previous discussions and correspondence on this project, in Reference (b), you requested that we also describe the current system for managing regulatory commitments and that we provide an update on the actions being taken to correct the non-conforming conditions identified during the Commitment Implementation Assessment Project. Attachment B and C, respectively, contain that information.
We will keep you informed on our progress on this initiative through the periodic Performance Improvement Plan updates given to the Resident Inspector and to Region I and with specific discussions with the Resident inspector on this subject.
9005040052 900430 ADOCK0500g7
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Doc: ment Cc:tr;l Desk
- April 30,1990 l'agg,2 Y
'Should = you have any further questions regarding this matter. - we ' will be pleased to discuss them with you, Very truly yours, 1
GCC/BDM/db Attachment
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D. A, Brune, Esquire J. E.
Silberg, Esquire R A,Capra,NRC D, G, Mcdonald, Jr., NRC T. T. Martin, NRC L, E. Nicholson, NRC R. McLean, DNR
I A'ITACHMENT A THE REGULATORY COMMITMENT MANAGEMENT PROJECT i
The Regulatory Commitment Management Project is divided into four tasks: 1) the l
Regulatory Commitment Management Process,2) Source Document Storage and Retrieval,3)
Historical Commitment Identification, and 4) IIistorical Commitment Review. The current plans for each Task are described below.
Task 1 Regulatory Commitment Management Process This task will develop and implement a process for managing regulatory commitments.
Managing regulatory commitments includes making, identifying, assigning, tracking, f
implementing, revising, closing and maintaining commitments.
The first step in this process will be to promulgate a policy on regulatory commitments. This policy will state the management expectations for managing regulatory commitments. It will include the definition of a " regulatory commitment".
Further, it will describe the l
organizational responsibilities, authorities, and communications, and the scope of regulatory commitment management.
l The process requirements will be developed following interviews with Calvert Cliffs management and selected Project Managers. The needs of other activities, such 'as the Procedures Upgrade Project, will be identified and addressed in the requireme~s.
Information from the Regulatory Commitment Tracking Group (RCTG) and the experience of other utilities will be utilized in developing the scope of the process.
After the process scope has been established, draft procedures will be written to describe the process implementation. Following the testing of the draft procedures on a test population of documents, they will be used as the basis for developing the functional specifications for the -
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regulatory commitment database needed to support the process. The database will be the central repository for all of Calvert Cliffs regulatory commitments.
t Process implementation will be accomplished following training and customer testing.
Training on BG&E's regulatory commitment management policy will be provided to the responsible individuals, Calvert Cliffs management and, on a continuing basis, general employees. The draft procedures will be finalized and regulatory commitment information 7
stored on the existing system will be transferred to the regulatory commitment database.
Following implementatlan, we will officially inform the Commission of our policies concerning the management of regulatory commitments.
This task is currently scheduled to be completed by the fourth quarter of 1991.
Task 2. Source Document Storage and Retrieval The purpose of this task is to retrieve and make readily available the docketed correspondence between BG&E and the NRC. Almost 11,000 documents comprising approximately 250,000 pages are currently on the Calvert Cliffs Units 1 and 2 docket. A consolidated, ordered collection of our docketed correspondence will be assembled. Our plan is to store the documents on an electronic system with search capabilities.
The ability to add 'new correspondence to the electronic system will be provided so the collection can be kept current.
Besides the obvious benefits to the Project, this electronic document system will be useful to other activities at Calvert Cliffs and should facilitate an increase in the quality and timeliness of our correspondence with the NRC.
This Task is currently scheduled to be completed during the fourth quarter of 1990.
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Task 3. Historical Commitment IdentifictinD The purpose of this task is to review the docketed correspondence between BG&E and the NRC and to identify the commitments contained in that correspondence.
Procedures will be developed describing how to identify regulatory commitments in historical correspondence and on capturing the peninent data from the document and entering it onto the regulatory commitment database created in Task 1.
This Task is currently scheduled to be completed in the third quarter of 1991.
Task 4. Historical Commitment Review The purpose of this task is to review the regulatory commitments identified in Task 3.
The first activity of the historical commitment review will be to prioritize the regulatory commitments for review, Relative importance of commitments to plant safety will be considered in this prioritization.
During the review of the historical commitments, duplicate commitments will be consolidated and superseded commitments will be tied to their replacement commitment and closed. The remaining historical commitments will be separated into two categories: open and closed commitments.
Specific definitions for open and closed historical commitments will be developed during the Project, however, in general, open historical commitments are those which impose current or future obligations. Closed historical commitments are those which have no current or future obligations. Open commitments will be investigated and compliance will be verified and documented. The justification for declaring a commitment closed will also be documented but the implementation of the commitment will not necessarily be investigated. As commitments are reviewed and documented, the regulatory commitment 1
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f database will be updated to contain commitment implementation information. All important aspects of the historical commitment review will be controlled by procedures.
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Commitment information will be passed to the appropriate organizations for inclusion into plant documents (UFSAR, Technical Specification, and procedures).
Deficiencies identified as conditions adverse to quality will be entered into the corrective action system for prioritization, reportability determination, root cause analysis (if justified) and correction. The review priority may be adjusted if a trend of deviations is noted.
This task is currently scheduled to be completed by mid 1992.
Conclusion Baltimore Gas and Electric has e.mbarked upon a major undertaking to improve our process for managing regulatory commitments and to identify and review our historical commitments.
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The Project will last two and a half years and is estimated to cost almost $6 million. We believe that the resulting system for managing regulatory commitments and the information that will be made readily available describing our commitments and their implementation will provide a high assurance of-past commitment accomplishment and the basis for reliably meeting future regulatory obligations.
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j NITACHhtENT H DESCRIPTION OF THE CURRENT REGUIATORY COhth!ITh1ENT j
hfANAGEh!ENT SYSTEh!
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hinnagement of regulatory commitments is currently coordinated by the Nuclear Regulatory Matters Section (NRMS), included in NRMS's responsibilities are:
1)
Review of incoming correspondence from the NRC to identify commitments (i.e.,
stated expectations which constitute a requirement for action within BG&E).
2)
Review of outgoing correspondence to the NRC to identify commitments to future action by BG&E.
3)
Entry of commitments identified in 1) and 2), above, into the Commitment Tracking L
System. This includes assignment to the organization responsible for action and negotiation of due dates. NRMS oversees the NRC module of the Commitment Tracking System which is integrated into the site problem reporting and corrective action systems.
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Providing routine reports to management on the status of commitments made to the 1
NRC.
5)
Review and close out of commitments based on documents submitted by the responsible organizations identifying the actions taken to fulfill the commitment.
6)
Reference assistance in reviewing past commitments and regulatory requirements
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affecting on going activities such as 50.59 reviews and procedure revisions.
These actions were initiated or revised from earlier systems in late 1989 or early 1990.
Procedures to formalize these processes are currently in development with expected completion by July,1990.
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Regulatory commitment management is reviewed through Ouality Assurance audits and surveillances. This includes review of generic issue correspondence (NUREGS, IAE Bulletins, Generic Letters), Licensee Event Reports, Technical Specifications, and the UFSAR. A requirement for specific consideration of regulatory commitment source documents was recently added to QA procedures. Additional monitoring of regulatory commitment management effectiveness will be conducted by the Independent Safety Evaluation Unit by examining missed commitments in their deficiency trending.
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NITACHMENT C k
STATUS OF COMMITMENT IMPLEMENTATION ASSESSMENT PROJECT, -.,/y' NON.CONFORMANCE REPORTS NCR 8220 DESCRIPTION: Sample Piping for the Urbt 1 wil e range noble gas monitor has no insulation. MR tag #26731 dated 1987 still attac1ed to the monitor states that the heat tracing is unable to maintain sample temperature.+
d' STATUS: Hi March,1990.gher rated heat tracing and new insulation inst illed in Unit I hi Post installation testing verified operability of the system.T' he l
same work will be performed on Umt 2 this summer.
<,;t NCR 8243 DESCRIPTION: LER 83-63 (dated 12/9/83) had corrective actims, ire of requiring the installation of locking devices to prevent inadvertent elosi.
containment particulate / gaseous monitor isolathn valves during,
containment sampling. This has not been dore, STATUS: Procedural controls have been put into place to prevent"the inadvertent closure of the isolation valves DESCRIPTION: BG&E 1/4/80 letter to NRdon the em*ironmental, J NCR 9232 qualification of electrical equipment stated that the ESF equipment is qualified to 10E8 rads. The LPSI pump seals contain Teflon parts which are not stable past 10E5 rads. Post accident dose map 62143 indicates that the
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ECCS pump room will have at least 10E5 rads in the first 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of a e
design basis accident. As a result of high postulated due rstes the LPSI pump seals may fail.
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STATUS: A safety evaluation determined that the Teflon seals were not a safety hazard. llowever, due to other undesirableyharacteristics v!the seals, they are being replaced on Unit 1 and 2 during the present obtage.
NCR 9248 DESCRIPTION: BG&E committed to the NRC to install a MFW trip signal
[O by November 17,1983. The installation was mhje( but did not meet the stated requirements of the commitment.
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STATUS: This NCR was initiated due to a mis inter aretaticp 6f t)tc ik$gn drawings. The trip system meets the requirements o f the comniitment.
NCR 9249 DESCRIPTION: The SPDS was installed under FCR 8N10$. The safet analysis was sent to the NRC and OSSRC for review, bLt was not included in
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the FCR package. Therefore, field reviews by the RE and PpSRC wew ppt, i 1
properly documented.
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STATUS: Investigation has revealed that there is no requirnen; to add thc io Safety Analysis to the FCR and that adequate reviews were performed.
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I NCR 9250 DESCRIPTION: The latep revistba to CCI 1!9 omitMd the Generic Letter
JQ.i 8212 requirement to have dght hours between working periods.
" STATUS: The revised procidurd he been drafted and is in final review and approval with implementation expr::ed in May,1990.
I NCR 9252 DESCRIPTION: BG&E 9/2 fet.g(p f e NRC states that two septaate Surveillance Test Procedures STPs) edwing operability and under voltage testing of the Emergency Dies 1 Generators had been combined into one procedure, eliminatmg many redundant requirements." Contrary to this a
statement, such testing is presently condu'eted under four STS.
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I STATUS: The procedures in question hld been drafted but 'were not enacted. Subsequently, Eulerguev Diesel Generator maintenailce has been f
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substantiallyreviewed by tZe NRd. Significant steps to reduce diesel starts to the mirinum u}) awed I the Techmcal Specifications have recently been implemenied%luding p sical circuitry modifications. Procedures accompanvingsnete mod ications have been drafted and are currently in the review +nd approvn) process.
NCR 9253 DESCRIP'110N; BG&E 1/4/80 letter to th'c NRC states that dose calculations and time and motion studies')T,1 be performed for areas requiring post accident access with dose rates greater than 100 mr/hr.
BG&E also committed that there would be no areas requiring infrequent post accident access with dose rates greatdr than 5 R/hr. There is no record of a time and motion study being performed for ONrations. Chemistry j
performed a time and motion study following an NRC violation.
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STATUS: A Prh'ect' Team is being organized to examine procedures, determine if ad tlonal calculations or studies are necessary, and address whether additional administrative controls are needed.
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NCR 9254 DESCRIPTION: The post accident radiation dose maas 62143 throu 'h r 001 written in 1987 has n4 t>ccn inco,rpd62147 have not been kept Med4d estimated dose outside thg emergency escape hetch,2) the floor plan changes on the 69' have no; been mcorporatedamd)3) several shield walls shown on the drawbg3 do not refleiphe plant configuration, o
correct the drawings and the changp'(.cd (a final re) view. STAT y
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<I NCR9255 DESCRIPTION:)3G&E 6/7/83 lettbr 16 the NRC stated that revence flow testing or other closure integrity testing would be performed on a puiodic 1
basis on the Emergency Diesel Generator Cooling Water Discharg(ChMt -
implem(ented. Valves 1 SRW.321 and 322,2 SRW 321). This periodic
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,v these checkvalves/7/83 letter, we stated that the only recpired positiori of STATUS:In War 6 was open. Subsequent analysis shned that reverse flowf testing the valves would cause additional diesel starts and, thuefore, revenF q flow testing was not implemented.' A Facility Change Request has beerb approved to remove the internals of the check valves.
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i NCR 9256 DESCRD'UDR In BG&E's response to Genuic Letter 88-05, we commitre m implement a procre'n to address the conosive effects of RCS.
leakage on carbon steel. TM GA Project reviewer considered the procedure inasquate to ensure the rc@! red surveillance. -
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SI6TUS: Based upon an independent review of the 'iitspection procedure'by.
Bechtel, it was concluded that the procedure was adequate to ensure the<
required' surveillance.
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k1 NCR 9257 DESCRIPTION: BG&E 3/14/84 letter to the NRC stated that a report q u
describin our files.g the seismic qualification of the Auxiliary Feedder System was in This documentation could not be found.-
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STATUS: A copy of the repmt was retrieved from Bechtel an'd placed in our -
files.
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Ya NCR 9265 DESCRIPTION:In BG&E's response to IE Billletin 78-08 we committed to nl posting the radiation hazard around the fuel transfer tube during fuel movement. There is no procedural requirement to post the area.
ETRUS Fuel handling procedures have been revised to requiring posting
]q of the radiation hazard area.'
NCR 9276 BG&E 1/4/80 letter to the NRC on environmental qualification of electrical '
eq lipment stated that no equipment required to function in ar/ accident 1
woald be adversely degraded by radiation, and that the ESF equipment was.
qualified to.10E8 rads. However, there is no evidence that the mechanical -
ESF componehts were reviewed for this degradatiers q
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STA"lUS: A review of our correspondence has determine'd that there was no commitment to establish an environmental qualification program for mechanical components. However, we are required by GDC 4 to ensure that-all necessary e,quipment will operate under accidern conditions. We are i
currently considering what, if any, additional actions me required to assure complete compliance with that criteria.
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s 9.9 NCR 9350 DESCRIPTION: Frem a review of the QA evaluation of 3/12/86 performed y yJ L
on the Technical Su recommendations 5,pport Center it cannot be determined if6,7 and 8 h L
l NRC.
3TATUS: A review of the design basis of the HVAC system to which these J
6 tecommendations referred is in progress but is not yet complete.
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NCR 9351 DESCRIPTION: Audit recommendation OC 25 85-1 suggested that procedures require education verification of prospective mspectors as recommended by ANSI N45.2.6 and Reg Guide 1.58. OCP-3, CCIs 613 and j
.520 do not specify that minimum education and experience records be verified for accuracy.
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$ ATUS: Verification of education is currently performed during security :
sareening. Therefore, specific verification for inspectors is not required.'
NCR 9352 DESCRIPTION: The preventative maintenance reguirement to perform fuel l
oilleak checks were dropped on #12 EDG after LcR 79 74/3L stated that the leak requirements were the corrective actions to resolve the concern of Amall fuel oilleaks on the EDG;'
STATUS: Bi weekly testing was replaced with operator watch rounds performed each shift and by monthly testing per'ormed under STP-0-8.
' NCR 9353.
DESCRIPTION: A Quality Assurance audit recommendation stated that L
Radiation Safety has no procedural guidance as to when to describe "Special L
Maintenance" in the annual report to the NRC required by Reg Guide 1.16 adl Technical Specifications 6.9.1.5a.
STATUS: Invest 1gation revealed that BG&E's rep' orting is consistent with the Reg. Guide, Technical Specifications, and industry practice.
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