ML20062E899

Forwards IE Performance Appraisal Insp Repts 50-317/82-01 & 50-318/82-01 on 820118-28 & 0208-11 & Executive Summary. Significant Weaknesses Identified

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: IR 05000317/1982001 ML20062E899
References
NUDOCS 8208100366
Download: ML20062E899 (6)

See also: IR 05000317/1982001

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....e APR 14 1993

Docket Nos. 50-317 "

50-318

Baltimore Gas and Electric

ATTN: Mr. A. E. Lundvall, Jr. d

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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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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Distribution (w/ Report):

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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

D. Goddard, Oregon DOE

Region I Reading Rooin

All Licensees

State of Maryland

PAS Regional Coordinators

PAS Files

IE Files

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Distribution (w/o Report):

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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

I 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

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assure prompt closecut of Maintenance Requests (MRs); lack of an equipment

I 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.