ML20043D728

Responds to NRC 900404 Ltr Re Weaknessess Noted in Maint Team Insp Repts 50-317/90-80 & 50-318/90-80.Efforts to Clean,Insulate & Paint Plant Areas to Improve Cleanliness Being Undertaken

ML20043D728
Person / Time
Site:	Calvert Cliffs
Issue date:	06/04/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006110117
Download: ML20043D728 (9)

Text

{{#Wiki_filter:. .. A BALTIMORE OAS AND ELECTRIC CHARLES CENTER e P.O. BOX 1475 e BALTIMORE. MARYLAND 21203 1475 Gromot C. Cntti var Paa.iosut wea..,c,. ..' Junc 4,1990 no,>,.o-.... U. S. Nuclear Regulatory Commission Washington,DC 20555 ATT!!NTION: Document Control Desk [ SUBJI!Cr: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 NilC 1nspection Report Nos. 50 317/90 80 and 50-318/90 80 Streial Maintenance Team Insr,cetion RI!FERIINCIIS: (a) lxtter from Mr. M. W. Hodges (NRC) to Mr. G. C. Creel (BG&li), dated April 4,1990, same subject-Gentlemen: - linclosed as Attachments (1) and (2) are our responses to pur request for information regarding actions taken or planned in order to enhance our maintenance activitics in areas where weaknesses were identified in the subject ins pection Report. in addition, the response contains our planned actions to resolve the four , identified unresolved items in the inspection Report.

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

Very truly yours, GCC/CDS/bjd Attachments l cc: D. A. Ilrune, Esquire J.11. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr. NRC T. T. Martin, NRC . L E. Nicholson, NRC ej O R. McLean, DNR p4 r/ i g$I i

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     .   .                                         A'ITACllMENT (1)

IKi&E RESPONSE TO NRC INSPECTION REPORT 50 317/90 80; 50 318/90 80 CONCERNING IDENTIFIED WIMKNESSES AND UNRESOINED ITEMS The cover letter of Nuclear Regulatory Commission (NRC) Inspection Report No. 50 317/480 and 50-318fA80 requested that Baltimore Ons and Electric Company (DO&E) notify the NRC in writing of actions taken or planned in order to enhance our maintenance activitics in areas where weaknesses and unresolved items were identified. %c weaknesses and unresolved items were summarized in Appendix 2 and Appendix 3 of the subject Inspection Report. We have responded to the weaknesses and unresolved items in the same order in which they wee summarized. 1.0 WEAKNESS 12 1.1 NRC IDENTIFIED WEAKNESS: Plant walkdowns indicate there are areas in the plant where housekeeping could and should be improved. BO&E RESPONSFJ We are currently undertaking a major effort to clean, insulate, and paint many plant areas to improve cleanliness. A management task force was formed in 1989 to review procedures that delineate area cleanliness requirements and material accountability (Calvert Cliffs Instructions 107 and 206). These procedures are being revised to further strengthen those programs. These procedural controls are enhanced through our Job Observation Program which independently reviews housekeeping on a routine basis. Additional attention to the out of the-way areas noted as deficient during the inspection will be used to improve the uniformity of our cleanliness. A recent memorandum from the Superintendent Maintenance has emphasized continued attention to the details of plant cleanliness by individual workers. 'lhe memorandum emphasizes that Individuals performing work me responsible for making cleanliness an integral part of their daily work activities. 1.2 NRC IDENTIFIED WEAKNESS; The program for using the MR tag appears to be adequate but the number d tags throughout the plant causes concern that each has been properly evaluated. BO&E RESPONSE To ensure that cach MR is evaluated, all MR's are entered and tracked by the Nuclear Maintenence System database and assigned a Maintenance Order (MO) number. Each MR is then reviewed by a Senior Licensed Operator (SRO) who assigns a priority level to the MR. The focus of the SRO review is to ensure an appropriate level of resources are provided to correct the problem based upon its urgency. Maintenance - Planners are then assigned to plan each MR and develop a Maintenanec Order in accordance with CCI 200.10,' Organization and Creation of a Maintenance Order." Since July of 1989, safety related MOs are required to be evaluated by a Quality Engineer (QE) prior to being issued to the fickt. The QE review provides an independent evaluation of the planned work activity. Additional reviews have been conducted by the Maintenance Superintendent and other supervisors prior to significant plant changes. These measures have proven effective. We share your concern about our MR backlog. Throughout 1989 cfforts were introduced to reduce the MR backlog through improved scheduling and manpower increases. An Outage and Project Management Department has recently been created which is focusing on improving scheduling. This Department is currently focused on working priority A MOs. Engineers and Planners have been acquired to review Unit 2 MO packages to ensure cach has been properly prepared and the job is ready to work. It should be noted that many of the MR tags in the alant do not requlte immediate action, but rather are minor deficiencies. A large number of MR tags can be directly attributed to 1

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HGAE RESPONSE TO NRC INSPECTION REPORT 50 317/90 80; 50 318/90 80 CONCERNING IDENTIFIED WIMKNESSES AND UNRESOLVED ITEMS numerous plant walkdowns by Operators, Engineers, and Craft personnel. The specific intent of many of these walkdowns was to identify deficiencies based on an increased sensitivity to potential plant discrepancies, nese walkdowns have resulted in a lan ge number of MR's that document minor or k>w priority discrepancies. Contributing to the MR backlog B was a 1989 skiwdown in work activitics to enhance control. As control has been improvet, I the pace of work has been increased. While a certain constant number of MR's for minor and/or low priority items will always exist, we Iccl that once the current high number is worked off we will return to a relatively constant lower number that is more normal for an operating nuclear power plant. In the meantime, we will continue to focus primarily on working priority A MOs until enough resources are available to start working N Os of lower pnontics. 1.3 NRC IDENTII1ED WEAKNIM The condition of plant supervisory staff, maintenance workers, and others regularly working $$ to 65 hours per week over extended time periods could be considered excessive overtime. BO&E RESPONSE: We agree that more than the usual amount of overtime has been worked by plant personnel in all areas during the recent dual unit outage period. Ilowever, overtime has been mandated in a conscious, deliberate fashion and individual situations have been monitored in an effort to assure an appropriate amount of time-off is received. Based on our concerns about widespread une of overtime over an extended period, a revised policy was instituted on April 11,1990. His policy catablishes an expectation that everyone s1ould get at least tw days off at least every otScr weckend and that no individual is expected to , work more than 50 hours per week on a routine basis. Work schedules have been adjusted accordingly. We expect that this policy will have a positive impact toward our goal of quality  ; and safety and will ultimately lead to an increase in worker productivity. This policy will bc l cffective until September 4,1990.  ! 1.4 NRC IDENTil1ED WEAKNESS: A predictive maintenance program has not been fully  ; developed and implemented.  ; BO& E RESPONSE: We agree that some of our predictive maintenance programs are not  ! yet fully developed and implemented. His is due to a combination of numerous factors including the relative young age of many of the programs and the needs and prioritics of other more urgent programs which have been developed in the past 18 months. We feel that our predictive maintenance programs are progressing consistent with the needs and prioritics of other Nuclear Program demands for resources, i The Reliability Contered Maintenance (RCM) methodology applied at Calvert Cliffs is l analogous to classic preventive maintenance programs develop d for new or operating ' nucient power plants in that vendor recommendations are adopted id modified as operating experience is gained. Our RCM program makes recommendatior. ,ased on pencric failurc 4 rate data. Once recommendations are implemented, operating experience is reviewed to i' determine the effectiveness of the RCM program. The program may then be modified and/or validated to achieve maximum results. The generic data used to perform RCM analysis for defining the predictive maintenance program is derived from the rame data sources as those typically used for Generic Letter 88 20, Individual Plant Examination (IPE) programs. These data sources arc, in general, based on Nuclear Industry failure rates and are the same methodology being applied in the EPRI RCM Demonstration Project. The methodology utilizes generic failure rate sources, 2

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l .. . A1TACitMENT (1) i BG&E RESPONSE TO NRC INSPECTION REPORT 50 317/96-80; 54314/96 80 CONCERNING IDENTIFIED WEAKNESSES AND UNRESOLVED ITEMS thereby climinating a significant amount of resources that would otherwisc be required to obtain similar data on a plant specific basis. Our Reliability Centered Maintenance (RCM) Program is not yet fully complete in that not all system analyses nor recommendations associated with the . project are completedAmplemented. We plan to continue supporting the implementation of RCM on a schedule that is consistent with our needs and resources. We arc an early participant in the industry trend towards adopting RCM methods and we consider all progress made to date in this arca to be a strength.

                                                                                        %c status of other predictive maintenance programs at Calvert Cliffs are listed below.

o infrared ncrmography is a potentially valuable emerging technology. We support further development of the technology and last year invested in state-of the art equipment which has been recently used for root cause investigations of various , equipment problems, we plan on further use of infrared thermography techniques as 1 the technology advances. o database is a predictive Our Integrated maintenance tool that Corrective provides plant Action historical Program data (ICAP) for improving equipmen 3crformance. His program has been fully operational since 1985. ICAP receives nput from corrective action systems as its source of failure data. ne data is trended  ! and screened to identify repetitive, precunor, or generic failures. Once a problem is i identified, recommendations for solutions are developed. The ICAP historical database has been used primarily by system engineers an average of seven times per month in 1990. , o A new system which began operation in 1989 is the Component Failure Analysis Report (CFAR). His system draws upon Nuclear Plant Reliability Data System (NPRDS) reported failures as its data source. he system is a proactive one in that it comparcs failure rates at Calvert Cliffs to equivalent industry rates and provides recommendations to prevent potential equipment failure trends. We Icel that this 1 new system has the proper focus to identify and correct emerging equipment failure i trends. We continue to pursue further enhancements to this system to address the internal assignment and resolution of CFAR recommendations. We feel that the l CFAR program will be more effective with the enhancements in place. The Maintenance luspection Team (MIT) identified a weakness in that the lubrication oil i sample program failed to provide "a direct correlation between the oil sampling and the equipment run time

• As discussed in a February 26,1990 memorandum referenced in the inspection Report, during the period of the inspection, BG&E conducted a system failure history review of representative systems containing safety related equipment. His review focused on bearing failures in rotating machinery and found that bearing failures had significantly decreased (by a factor of seven to one) since the inception of the oil sam ple program. The memorandum concluded, based on the very low rate of bearing failures, that {

the lack of correlation between the oil samples and run times was not a safety issue. We plan , to evaluate the issue (rclative to standard industry practicc) and implement appropriate i improvements sometime near the end 1990. Notwithstanding the lack 01 correlation between j the oil samples and run times, based upon our representative review of failure history, we 4 believe that the oil sampic program has been a strength at Calvert Cliffs.  ! 3

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       .                                          A'ITACliMENT (1) i              BG&E RESPONSE TO NRC INSPECTION REPORT 50 317/90-80; 50 318/96 80 00NCERNING IDENTIFIED WEAKNESSES AND UNRESOLVED ITEMS 1.5    NRC IDENTIFIED WEAKNESS: The QCII procedure for writing QCll's does not define the kind of things QC should inspect.

BG&E RESPONSE: The methods and responsibilities for wreening and review of work controlling documents and development of Quality Control Inspection Instructions (OCII's) is governed by Quality Control Procedure (OCP) 4, " Quality Control Inspection Instructions." QCP-4 Attachment B is a list of elements and activities that are considered when reviewing the work controlling documents for identification of QC inspection points. OCP-4 Attachment B is included as Attachment (2) of this response. We believe ihis list provides excellent guidance on the kind of things QC should inspect, and we will continue to add additional topics as they are identified. 1.6 NRC IDENTIFIED WEAKNESS: he criteria for initiating non conformance reports (NCRs) were reviewed and found to be general and subject to different interpretations by individuals such that MR's are sometimes written when an NCR would provide better trending and tracking of prob! cms. BO&E RESPONSE: De process for identifying and controlling nonconforming conditions is governed by CCl.116 Identification and Control of Nonconforming Conditions." This process was extensively changed and im) roved with the new revision to CCI 116 implemented on April 27,1990. A

• Problem Report" form was created by this revision and is Initiated for " suspected conditions adverse to quality." Problem Reports are reviewed by a knowledgeable supenisor and Procurement Quahty or Quality Control to validate the existence of a quality problem, if the suspected quality problem is valid, then an NCR is issued. CCI 116 also requires the initiation of a Maintenance Request, per CCI 200, to document hardware problems requiring corrective maintenance or modification.

CCI 116 contains a clear definitior, of a " Condition Adverse to Quality," which includes such terms as Deticient Material, Deficient Workmanship, Failures or Malfunctions, Fauhy Design, Inadequate Controls, Inadequate Documentation, and Non Adherence to 1 Procedures. Prior to implementing this procedure change, over 700 site personnel were trained on the requirements and actions for identifying, documenting, reporting and resolving conditions adverse to quality. The new process was explained in detail including the criteria for _  ! initiating Problem Reports and will result in a more consistent interpretation of the critena for initiating NCRs. I 1.7 NRC IDENTIFIED WEAKNESS: Health Physics is staffed primarily with contractors and is . insufficiently staffed with licensee employees.  ! BO&E RESPONSE: The low proportion of permanent technicians in the Radiation Control Operations and Radiation Control ALARA units had been identified by the Radiation Safety line organization in late 1989 as a problem and action was initiated to increase complement. This action is still underway with successful recruiting results. l The number of contracted personnel employed in Radiation Safety is primarily attributable  ; to the fact that we are in an unaccustomed dual unit outage, i 1 1 4

r Le, A'ITACitMENT (1) BG&E RESPONSE TO NRC INSPECTION REPORT 50 317/90-80; 50 318/90-80 CONCERNING IDENTIFIED WEAKNESSES AND UNRESOLVED ITEMS 1.8 - NRC IDENTIFIED WEAKNESS: Health Physics lacks a definitive written plan that describes the department policies, procedures, and communications being used to accomplish 1 their goals. BO&E RESPONSE: -The policies and procedures establishing compliance with 10 CFR Part 20 are defined in Calvert Cliffs Instructions. In an outage situation where additional j wrsonnel and communications are necessary to conduct a planned schedule of work, the - 3asic policies are supplemented with an outage administration document, issued by the j responsible individua: coordinating outage activities. 'Ihe outage administration document - I defines the orpel ational 3 structure, outage scope, and communication pathways Thel  ! Radiation Safety section is included in this document as one of the key support groups and ,

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i follows the requirements presented. ' j During the process of enhancing the interface between ALARA and the Planning and- I Scheduling groups. certain procedural or communication requirements may'nced to be; i revised or established. As evaluations show these to be necessary, the policy documents wil10 -

                                                                                                                     -j be changed.'                                                                                        u 1.9     NRC IDENTIFIED WEAKNESS: Licensee rules for protecting open piping do not include '

j diameters below two inches. Protection of smaller diameter pipe and tubing to prevent'- ingress of foreign material is good industry practice and lack of this protection is considered a , weakness. I BG&E RESPONSE: A management task force was formed in 1989 to review the procedures that govern housekeeping and cleanliness practices.: Proposed revisions to procedures have been drafted and are currently under review. Draft CCI-206,~ " Foreign Material Control," addresses the issue of pipe protection. The draft CCI contains no minimum criteria for pipe size and all piping will be considered for an appropriate level of protection based on the  ; nature of the work. This procedure is scheduled to be approved in the third quarter of 1990. a r 1.10 NRC IDENTIFIED WEAKNESS: Th mdnsee had not fully implemented a program to assess the difference between inadeqtmie maintenance work and other root causes.  ! Generahy, licensee formal evaluation of rework items on a component specific basis was not 'i implememed. BG&E RESPONSE: In conjunction with Performance Improvement Plan Action Plan 4.6,

                  " Root Cause Analysis," several specific efforts are underway to address this issue:

o Appropriate maintenance personnel have or will receive root cause analysis training  ! by the fourth quarter 1990. o The Action Taken form of the MO has been revised to include an "As Found" section and a " Failure Assessment" Section to support the root cause analysis training given < to appropriate craft personnel. o Maintenance Instruction (CCI 200) has recently been revised directing Maintenance personnel to contact the appropriate System Engineer for assistance in root cause analysis for repetitive problems. 4 S 1

L s, A'ITACllMENT (1) BG&E RESPONSE TO NRC INSPECTION REPORT 50417/90 80; 50 318/90 80 , CONCERNING IDENTIFIED WEAKNESSES AND UNRESOLVED ITEMS  ! l

                                                                                        . -                           i o        - A Technica! Authority Guideline (PPE 5) has been issued delineating areas of             J responsibility and interfaces between Maintenance and Engineering personnel for             !

problem resolution. i o System Engineering personnel are responsible for formal root cause analysis and a Root Cause Coordmator position has been established. Implementation of the above items and Action Plan 4.6, (scheduled for completion in the  ! first quarter 1991) will result in a fully developed comprehensive root cause evaluation j program. j

                                                                                                                    ;j 2.0 UNRESOI.VED ITEMS                                                                                         -{

NRC ITEM NOS,317h0-80-01: 31880-80-01. ECCS SW RELIEF VALVE TAIL PIPE. 2.1

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This item was concerned with'a noted difference between Unit I and 2 Salt Water (SW) . System piping associated with the Emergency Core Cooling System (ECCS) Pump Room ' Coolers. The SW pump room coolers rehef valves for Unit 2 have tail piping while the same relief valves for Unit I have no such piping. The isometric drawings did not show the tail piping for Unit 1 cither, The item is pending clarification concerning drawing completeness and configuration of the relief valve tail piping.

                 }}.0&E RESPONSE: We found that the existing existing isometric drawings but notg and                  with   the Pipm, Instrument       plant Drawings     configuration (P&ID's). A        ,

was con non conformance report was initiated on this issue on' March l$,1990. The design l cvaluation of the issue concluded that discharge piping should be installed on the Unit 1 ) relief valves because of the potential that adjacent equipment could be sprayed with salt water if either relief valve were to lift. Field Engineering Change (FEC) 90-0134 has been 3 written to add a small tall pipe to the relief valves on the Unit 1 ECCS Pump Room Coolers -  ! to divert the discharge to the floor. it was concluded that this issue did not cause a loss of function of the relief valve nor did it  ! constitute a substantial safety hazard to the equipment in the room, j 2.2 NRC ITEMS NOS. 317/90-80 02: 318/90 80-02: ECCS ROOM CONTAINMENT VENTILATION TEMPORARY MODIFICATION. An inspector observed a temporary ventilation alignment from the sump to the Engineered i Safety Feature (ESP) ventilation ducting. This ventilation path is a temporary modification and has been in place for a number of years. This path is being used pending a prmanent modification to allow routine containment depressurization without the ~ nsk of an unmonitored release path to atmosphere. j BG&E RESPOMfi A permanent modification has been in progress for sometime to allow i venting through the hydrogen purge system, however, problems have been encountered with its design that have delayed tic removal of the noted temporary modification. The most significant of these problems is ensuring an operable radiation closure signal to the hydrogen  ;~ purge valves for all modes of operation. Solution of these technical problems was delayed by ambiguity in the technical requirements. These problems have since been resolved,'and the > issue is currently assigned a high priority. 6

          , cy                                      A1TACilMENT (1) l i                   HG&E RESPONSE TO NRC INSPEC110N REPORT 50 317/90 80; 50 318/90 80 CONCERNING IDENTIFIED WEAKNESSES AND UNRESOLVED ITEMS 1

1 2.3 NRC ITEMS NOS. 317BO-80-04: 318/90-80-03 BA'ITERY CHARGER LOAD RATE.

                    - This item was concerned with the adequacy of our present test procedure for demonstrating -   j the capability of recharging the batteries at a rate of 5 400 amperes while supplying normal: D DC loads or equivalent or greater dummy loads in accordance with Technical Specification ,    j 4.8.2.3.2.e. The item is unresolved pending demonstration to NRR that the present method meets the intent of Technical Specifications.

BG&E RFJPONSE: We have discussed the issue with NRR. - They were receptive to our initial response to the issue but requested that we offer a complete technical rationale in' .

writing. The estimated completion date for this response is July 15,1990.- l 2.4 NRC ITEMS NOS. 317/90 80-05: 90-80-04 GROUTING OF SWITCHGEAR CUBICLES.~ > This item is unresolved pending completion of grouting undst the'4 KV switch gear cubicle . tracks and performance trip path testing . as defined l inf MO- 200-043 569A Land ' MO.200-043-569B.  ; BG&E RESPONSE: Facility ChangelRequest 88-160 calls for the injection of flowable. epoxy grout underneath the suspended structure which contains the tracks at the base of the switchgear cubicles. The grouting will be injected throughout the run of cubicles and will" provide firm, even support for the tracks. FCR 88-166, which calls for grouting under i cubicles in both Units, is on the current outage schedule. MOs 200-043 569A and B, which - ' were associated with the performance of trip path testing, have been completed.- 4 l 4 i 7 i M

L - ArrACilMDrr m oord - REV980N 1 - PAGE 7 OF S j i ATTACHMENT B .

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p!LEMENTS and ACTIVITIES i

1. The elements shall be considered when rci.g the work controlung docurnents for of QC inspection points. i

       -                                              MECHANICAL                                                                 !

Pressure boundades Seismic capabiky Rotating elemetAs' I Seals Bearings Sealing eurisoes . Bearing surfaces - Lubrication Structuralintegrfly ' l Orientation Location . Capacities i Rotation Design function Coatings: j ELECTRICAL & CONTROW Connections Mechanical - InterfaceTiming

a. contacts a, connections a. stroke :

b, splices integrity b. response  ! Enclosures / housing a. sealants Gearing  ! Conductors / cabling ' b. *0" rings Mounting i

a. routing c. fasteners / conn. Orientation Seals Lubricants Settings .

4 i e . II. The following actMties which are critical to' ensuring the quality of the' elements described . i' above shan be considered when reviewing the work controlling documents for identifloation of QCinsp9ction points. MECHANICAL ,

           . PrecisicnTnessurements                     Post maintenance Tests                Repairs:

Cleanlinessinemtions Machining of parts .  : Welding Functionaltests Calibration . Fabrication Replacement of parts Adlustmer% Alignment Heavy Rfting/ rigging Torquing instatation ELECTRICAL & CQNTROW j Terminations installations Calibtations Timing checks Adjustments Torquing

a. stroke Set ntchanges. Cable pulls : .

b. response time Re monts Functional tests .

Sequential performance Post-maintenance tests I}}