ML20062E899
| ML20062E899 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/14/1982 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| Shared Package | |
| ML20062E902 | List: |
| References | |
| NUDOCS 8208100366 | |
| Download: ML20062E899 (6) | |
See also: IR 05000317/1982001
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UNITED STATES
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NUCLUAR REGULATORY COMMISSION
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WASHING ton. D. C. 205a5
APR 14 1993
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Docket Nos. 50-317
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50-318
Baltimore Gas and Electric
ATTN:
Mr. A. E. Lundvall, Jr.
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Vice President, Supply
P. O. Box 1475
Baltimore, Maryland 21203
Gentlemen:
Subject:
Performance Appraisal Inspection 50-317/82-01, 50-318/82-01
This refers to the Performance Appriasal Inspection conducted by Mr. J. Woessner
and members of the Performance Appraisal Section, Office of Inspection and
Enforcement, an January 18-28, and February 8-11, 1982, of activities authorized
by NRC Operating Licenses OPR-53 and DPR-69 for Calvert Cliffs, Units 1 and 2.
This also refers to the observations discussed with Mr. Trueschler, and members
of his staff on February 11, 1982, at the BG&E corporate offices.
This inspection is one of a series of Performance Appraisal inspections being
conducted by the Office of Inspection and Enforcement.
The results of these
inspections are used to evaluate, from a national perspective, the performance
of your management control programs in support of nuclear safety.
The enclosed report 50-317/82-01, 50-318/82-01 identifies the areas examined
during the inspection.
Within these areas, the' inspection consisted of a
comprehensive examination of your management controls over licensed activities
that included examination of procedures and records, observation of various
activities, and interviews with management and other personnel.
The enclosed appraisal report includes observations that may result in
enforcement actions; these matters will be followed by the NRC Regional Office.
The report also addresses other observations and the conclusions made by the
team for this inspection.
Section 1 of the report provides further information
regarding the observations and describes the Performance C'ategories identified
in the conclusion section of each area.
Appendix A to this letter is an
Executive Summary of the conclusions drawn for the eight functional areas
inspected.
The Performance Category for the area of Corrective Action Systems was desig-
nated as Category Three, the area of Plant Operations as Category One, and the
remaining areas as Category Two.
As a result of the significant weaknesses identified in Corrective Action
Systems, designated as Category Three, you are requested to inform this office
within 30 days of receipt of this letter of the actions you have taken or plan
to take to improve the management controls in this area.
Your response will be
followed by the NRC Regional Office.
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NRC FORM 3I8p0 BO(NRCM O240
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OFFICIAL RECORD COPY
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In addition, you are requested to inform this office within 30 days of receipt
of this letter of the actions you have taken or plan to take to improve your
management controls over the significant weaknesses identified in the area of
10 CFR 50.59 Safety Evaluations for Facility Changes, particularly in the
adequacy of and review of these evaluations [(Section 2A, Observation (8)].
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s)
will be placed in the NRC Public Document Room unless you notify this office,
by telephone, within 10 days of the date of this letter and submit written
application to withhold information contained therein within 30 days of the
.
date of this letter.
Such application must be consistent with the requirements
of 2.790(b)(1).
,
The responses directed by this letter are not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction
' Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
Isl
James M. Taylor, Director
Division of Reactor Programs
Office of Inspection and Enforcement
Enclosures:
1.
IE Management Appraisal Report 50-517/82-01, 50-318/82-01
2.
Appendix A ~ Executive Summary
cc w/ Enclosures:
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B. C. Trueschler, Chairman of the Board, BG&E
G. V. McGowen, President, BG&E
E. P. Wilkinson, INPO
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NRC FORM 318 s10-80i NRCM O240
OFFICIAL RECORD COPY
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Distribution (w/ Report):
SECY
OPE
OCA (3)
W. J. Dircks, ED0
H. R. Denton, NRR
C. Michelson, AE00
W. P. Haass, NRR
S. H. Hanauer, NRR
H. Boulden, 01A
R. Architzel, NRC Sr. Resident Inspector
D. H. Jaffe, NRR Project Manager
R. C. DeYoung, IE
J. H.
Sniezek, IE
J. M.
Taylor, IE
Region I Reading Rooin
All Licensees
State of Maryland
PAS Regional Coordinators
PAS Files
IE Files
LPDR
Distribution (w/o Report):
IE Reading
PAB Reading
PDA Reading
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Appendix A
EXECUTIVE SUMMARY
A team of four NRC Inspection Specialists from the Performance Appraisal
Section conducted an announced inspection at Calvert Cliffs and the
Baltimore Gas and Electric corporate offices during the period January 18
through February ll,1982.
Management controls in eight areas were
evaluated:
Plant Operations was rated as Category One, Corrective Action
Systems as Category Three, and the other areas as Category Two.
The licensee had established adequate management controls over most areas
inspected and evaluated.
An exception was the area of Corrective Action
Systems.
The written guidance appeared confusing and contradictory; the
various types of deficiencies were not comprehensively covered; sufficient
training in the definition, purpose, and methods of corrective actions were
not provided; and management reviews and QA audits in this area were inadequate.
Another subject requiring management attention was Facility Change Request
(FCR) safety evaluations.
Many of those reviewed did not adequately address
the issue of an unreviewed safety question and appeared to be based on
insufficient technical information.
The Off-Site Safety and Review Committee
(OSSRC) review of these safety evaluations was superficial and required
significant improvements.
The inspection revealed that numerous changes had been made in the previous two
years to improve the facility's performance and to increase the ability to meet
or exceed federal regulations and industry standards.
These changes were made
in the organizational structure, in the personnel filling supervisory positions,
and in new and expanded programs in several different areas.
One of the most
significant strengths with the potential for lasting consequences was the
high morale noted among all licensee personnel interviewed and a strong
dasire to improve their record of performance and safety.
At the conclusion
of the inspection, corrective action was in progress or proposed for every
significant weakness identified by the inspection team.
Additional strengths ncted included the extent of QC coverage of maintenance
activities and the use of the Plant Operating Experience Assessment Committee
(POEAC). With minor exceptions, the team was impressed with the effective
management controls in the areas of Licensed Training and Plant Operations.
Observed strengths and weaknesses in the licensee's management controls are
further discussed in the following compilation of the inspection conclusions
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for the individual areas.
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Committee Activities;
Category Two (Section 2).
Both the OSSRC and Plant
Operations Safety Review Comnittee (POSRC) exhibited many strengths.
The
charters for each were comprehensive, as compared to other facilities similarly
inspected by PAS, and they effectively complemented the Technical Specifications.
Both committees kept detailed meeting minutes and effective tickler systems.
The frequency of meetings and the degree of member participation, as measured by
attendance, was high for both.
The POSRC had a particularly significant strength
in their use of the POEAC, which from all indications appeared to be an invaluable
resource to the safe operation of the facility.
A weakness common to both committees was their limited involvement in the
review of QA audits and corrective action systems, particularly Nonconformance
Reports (NCRs).
The most significant weakness was the OSSRCs inadequate
raview of FCR safety evaluations.
Coupled with this was the poor quality of
many of the safety evaluations examined.
QA Audits:
Category Two (Section 3).
A significant strength in the QA audit
program was the written guidance.
Significant weaknesses included a lack of
depth in some audits, incomplete checklists, failure to conduct adequate
corrective action audits, and lack of management review.
These weaknesses
indicated a lack of management attention to program implementation.
Design Changes and Modifications:
Category Two (Section 4).
The licensee
had established and implemented an adequate program to control safety related
design changes and modifications.
Programmatic weaknesses involved
inadequacies in the design change procedure, drawing control problems, and
lack of guidance defining the turnover of modified systems to operations.
The licensee had been aware of the drawing control problems and corrective
action was in progress.
Maintenance:
Category Two (Section 5).
The licensee had established an
ef fective program to control corrective and preventive safety-related maintenance
activities. Weaknesses in the program included the lack of controls to
assure prompt closecut of Maintenance Requests (MRs); lack of an equipment
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failure trending program; lack of independent verification of instrument valve
lineups; and failure to systematically identify and evaluate root causes of
maintenance problems.
Strengths in the program included effective QC coverage
of maintenance activities and the effective use of mockups in maintenance
activities.
Plant Operations:
Category One (Section 6).
The licensee had a well written
program for controlling plant operations.
The most significant weaknesses
identified were the shortage of licensed operators, the lack of independent QA/QC
inspection or surveillance of plant operation activities, and lack of timely
corrective action on fire protection problems.
Management was cognizant of
the manpower problems and was making a concerted effort to resolve this
issue.
The most significant strength identified was the effort expended in
communications with the plant staff, resulting in a positive plant staff
attitude and increased personnel knowledge of plant activities.
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Corrective Action Systems;
Category Three (Section 7).
The principal
weaknesses in the corrective action systems were in implementation of the
program and in the training of personnel.
There were several problems
found in the completeness of NCR forms and in the timeliness of their
resolution.
Neither MRs or NCRs were analyzed for their generic implica-
tions or their potential as precursors to future events.
There was no
mechanism or process established to funnel significant NCRs or MRs into
training programs, or as pointed out in Section 2 of this report, to any of
the review committees.
In practice, there seemed to be no effective corrective
action system to identify software deficiencies.
The available systems, as
used and as described by licensee personnel during interviews, were limited by
the type of deficiencies identified and by who was allowed to use them, or both.
There was no general system available to all members of the staff.
This was due
in part to apparent contradictions in the written guidance and, more significantly,
to a lack of training in corrective action systems.
Licensed Training:
Category Two (Section 8).
The licensee's written
programs for training license candidates and annual requalification of
licensed personnel adequately met the regulatory requirements.
The most
significant weaknesses identified were inadequate recordkeeping, failure to
describe the General Supervisor - Training and Technical Services
responsibilities, and lack of sufficient requalification classroom training
in 1981.
The most significant strength identified was management's effort
to improve the requalification program as witnessed by the 1982 training
schedule.
Non-Licensed Training:
Category Two (Section 9).
The licensee had made a
concerted effort to upgrade the training program for non-licensed personnel
at the site.
The reviews indicated that the Plant Maintenance Department
was much closer to their goal than was the Nuclear Power Department.
The
Nuclear Power Department had concentrated their resources on the licensed
training programs (see Section 8, Training) at the apparent expense of the
non-licensed training programs.
While the non-licensed training programs
were beginning to be implemented, there was insufficient implementation to
determine the effectiveness of the program.