ML20042F039

Submits Initial Response to SALP Rept Dtd 900404.Licensee Devoted Substantial Senior Mgt Attention & Resources to Improving Facility Performance & Committed to Continue Efforts to Attain High Stds of Safety & Quality

ML20042F039
Person / Time
Site:	Calvert Cliffs
Issue date:	04/19/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9005070135
Download: ML20042F039 (4)

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BALTIMORE GAS AND CHARLES CENTER . P. O. BOX 1476 a 6 6TIMORE, MARYLAND 21203 oc a c a cace' Wet Passiote a@ril 19* 1990 Nuctram CNr.mov .;

(300 aso-dess U. S. NucMr Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 ATTENTION: Mr. Thomas T. Martin Regional Administrator

SUBJECT:

Calvert Cliffs Nuclear Power Plant i Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 SALP Report initial Resnonse ,,

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Gentlemen:

We have reviewed your Systematic Assessment of Licensee = Performance (SALP) Report of April 4, 1990. It has . provided . substantial feedback for our consideration In the operation of Calvert Cliffs Nuclear Power Plant. We look forward to a full discussion at our scheduled public meeting on April 23, 1990. This letter is intended - to further the usefulness of that discussion by providing our initial assessment of' the points identified in your report' and their relationship to the current status of the plant. A formal response to the SALP will be provided after the April 23 meeting.

As your report makes clear, 1989 was a year of major change at Calvert Cliffs.

Conditions today are far different from those reflected in the grades for the performance for the full year of this SALP report. The rate of change at Calvert  ;

Cliffs confronts any evaluator with the difficulty of measuring a moving target. I Nonetheless, there are some key points from the SALP report which are important for us to acknowledge.

First, it is clear that there were many changes needed at the start of 1989. Your assessment closely paralleled one which we did in August 1989. Both identified significant symptoms which weighed heavily in the low grades in Operations, in Maintenance and Surveillance, and in Safety Assessment / Quality Verification. The '3' ratings in each of these areas indicate how far we have had to come and still have to go.

Second, we are pleased to note the recognition provided in the report of the substantial improvements which have been made. The many statements acknowledging effective corrective measures taken during the latter half of the year provide a balance in the report's perspective. These improvements were the result of a concerted j management effort to address not just the problem symptoms, but the root causes which led to their existence. A broad array of action plans was developed to analyze the problems, devise a strategy for correction, implement the defined actions, and measure 9005070135 900419 g\p.

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..- .o Mr. Thomas T. Martin

• April 19,1990 Page 2 ,

the results. To assist us in controlling this effort and to communicate its - content '

both inside and outside the company, these action plans were consolidated into the Performance improvement Plan (PIP). It has been management's challenge to prove that -

the PIP is a well-designed and effective tool--not simply a public relations ploy or a .

shell of empty promises. The PIP describes a dynamic program. We have submitted one revision, and you . will be receiving the second at the end of this month. . We are  ;

continually analyzing the effectiveness of our improvement efforts and will modify our plans .to ensure that- the1 desired end results are achieved. The SALP provides valuable evidence that ' PIP is working, and that its results are visible in the plant today.

Examples include:

- In Maintenance and Surveillance, the report credited advances in organizational structure, communications between Operations and Maintenance, safety perspective, and - controls and accountability for surveillance testing. These relate directly to PIP Action Plans for Resource Allocation, POSRC, Surveillance Test Program, Visiting Other Plants, and Post-Maintenance Testing.

- In Operations, the SALP report identified improvement in adherence to procedures, Operations' staffing levels, procedure quality, and operator awareness of plant status. These stem from PIP Action Plans for Communications, Resource Allocation, Procedure Upgrade, and Daily and Outage Work Control. All these plans were developed and initiated last spring, and their results are now apparent.

Other accomplishments, such as Quality Control improvements, Quality Assurance Internal Assessment Improvements and establishing the Independent Safety Evaluation Unit, were noted. Each was initiated using the PIP as a management tool.

The improvements did not stop at the end of the SALP period, in 1990, NRC reports have recognized the System Engineer training program as a notable strength, and the February Maintenance Team Inspection showed substantial improvement over a similar BG & E evaluation a year ago. Preparations for the current operating period of - Unit I show similar evidence of sustained strong performance. These preparations were. accomplished with minimal injuries, no damage to plant equipment, and no significant schedule setbacks attributable to planning or personnel errors. These are truly noteworthy achievements of which we are proud.

This is not to say that we have mis-read your report to indicate that our work is done.

You have clearly stated your continuing concerns regarding procedure quality and compliance, management involvement in licensing activities, and corrective action / commitment management systems. Regarding corrective actions we believe the initiatives undertaken have been effective in documenting problems. A natural outcome of this effort is a backlog of items requiring resolution. We recognize that a major effort will be required to address this issue. Additionally, you have noted that careful observation of many instituted changes is still required. These intentions and concerns are consistent with - our expectations. The PIP, which will be incorporated in the existing Nuclear Program Plan, includes several major assessments to measure its effectiveness in correcting these concerns. We are confident of and committed to ensuring that these issues are effectively addressed.

Mr. !rhomas T. Martin

' April 19,1990.

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Baltimore Gas and Electric Company ha: devoted substantial senior management attention and resources to improving Calvert Cliffs' performance. We are firmly committed to continuing our efforts to attain higher standards of safety and quality. We expect that these improvements will be reflected in markedly improved SALP scores in the current evaluation period, and that in the longer term that we will restore Calvert Cliffs to our goal of excellent performance.

Should you have any further questions regarding this matter, we will be pleased to discuss them with you-Very truly yours, GCC/GLD/JMO/bjd cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra, NRC D. G. Mcdonald, Jr., NRC L. E. Nicholson, NRC T. Magette, DNR I

B. A.Doger,NRC 4

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