ML20081F256
| ML20081F256 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/03/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106070257 | |
| Download: ML20081F256 (4) | |
Text
i B A t.T I M OF,i' GAS AND ELECTRIC CHARLES CENTER e P.O. BOX 1475
- BALTIMORE, MARYLAND 21203 1475 Gromot C Cattt Vicc Pot s ct Y N sc t t a le [ s.t m o y June 3,1991 noo m -
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk SUlUECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 SALP Report Response
REFERENCE:
(a)
Letter from hir. Thomas T, htartin (NRC) to hir. G. C. Creel (BG&E), dated hiay 9,1991, Initial Systematic Assessment of Licensee Performance Gentlemen:
We have reviewed your Systematic Assessment of Licensee Performance (SALP) Report of h!ay 9, 1991, and concur that it accurately describes Calvert Cliffs' performance from January 1,1990 to h1 arch 31,1991. The SALP report provides us with a useful perspective to supplement our own self-assessment in analyzing plant performance for broad trends and root causes. We are pleased that the report notes many substantialimprovements we have made. We are determined to continue this improvement trend.
OVERALL L : attribute the overall performance trend to our comprehensive improvement efforts. These have consisted of a thorough analysis of the root causes of earlier weaknesses to develop our Performance Improvement Plan (PIP), a sound PIP implementation plan, and a conscientious verification program. Although our PIP is nearly fully accomplished (26 Action Plans closed,7 more to finish this year, and 7 longer term), we recognize the need for a continuing improvement process. Our Nuclear Program Plan, which incorporated the remaining Action Plans, fills that need through a continuing assessment and planning cycle. Execution of this effort has required an effective management team and a revised management structure. These were established at a pace that ensured safety and stability while accomplishing the change. This team has shown its ability to communicate the appropriate standards of safety and quality through the positive resolution of substantial safety issues.
Additional elements of our program included strengthening our self-assessment capability so that both the line and the quality assurance / nuclear safety oversight organizations were more alert to problems and more effective in raising them to management's attention. This capability is d7I mso702 37 +10503 A
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Document Control Desk J une 3,1991 Page 2 supplemented by close involvement and oversight by the Off Site Safety Review Committee and by senior corporate management, ensuring effective problem resolution and a clear safety perspective, While additional work remains to be done, we are confident this enhanced self assessment and oversight will prevent recurrence of the problems previously noted at Calvert Cliffs.
PI ANT OPER ATIONS We agree with the report's assessment that operator performance during major evolutions is a strength and that plant operations are conducted in a cautious, controlled manner. Each event noted in the report has been carefully analyzed, and corrective actions have been determined. Our efforts to emphasize attention to detail and control of activities, such as providing standard guidance on pre-evolution briefs, show evidence of being effective. Further enhancements such as improving controls on concurrent use of procedure steps and specific training for Plant Watch Supervisors are expected to further help us achieve our goal of event free operation.
Overall, we are pleased with the progress made in plant operations over the last year. We feel that the improvements stem from an effective quality and safety philosophy within the organization.
However, recent events highlight the need for continued management attention to ensure proper attention to detail and control of activities.
RADIOLOGICAL CONTROM We agree with the noted strengths in ALARA and dosimetry programs, and we believe that significant tangible gains are resulting from our efforts at plant decontamination and restoration. We believe these initiatives send strong signals of management's commitment to a safe quality work environment.
We will continue to devote substantial resources to personnel contamination incident (pCl) reduction, further decontamination, and an aggressive training program. Deficiencies noted in high radiation area entries have been effectively addressed, the Off Site Dose Calculation Manual enhancements identified are expected to be completed in mid June, and we are working to improve our responsiveness to internal audits. Overall, we feel Radiological Controls is a strong and improving area.
MAINTENANCE / SURVEILLANCE The SALP's assessment that maintenance and surveillance programs matured during the past year and that program refinements remain to be done matches our own evaluation. We see a clear measure of improvement in the substantial reduction of maintenance order, temporary modification, and drawing backlogs. Our post-maintenance test program upgrade appears effective. We have recently implemented organizational changes to elevate management attention of surveillance testing, and we are in the process of revising our work planning and scheduling structure to enhance controls. We have undertaken substantial training and administrative improvements in the area of cleanliness control.
Overall, Maintenance / Surveillance has shown improvement, and we are committed to applying the necessary resources and refinements to continue this trend.
l.
Document Control Desk June 3,1991 Page 3 EMERGENCY PREPAREDNESS We concur with the SALP's assessment that Emergency Preparedness levels of staffing. training, and facilitier are appropriate and that improvements were achieved in these areas.
We have implemt nted several improvements in our Emergency Action Levels, and we are anxious to resolve those issues which remain. Communications with your staff on this subject have been scheduled. We believe Emergency Preparedness is a sound program with strong potential for improvement, SECllRI'IY During the Fall oi 1990, we noted the declining trend in this area and took strong steps to turn this trend around. To address the increase in personnel errors, our Tr.
Unit has placed increased emphasis on task testing for all Security Officers and Systems Opunc as Personnel. A team-building program has been initiated to improve vertical and horizontal er nmunications within the organization. The authorized staffing level was increased by 10 pos, ns to accommodate the
- training, After reviewing the security incidents, we concluded that communications weaknesses between Calvert Cliffs Security Operations and the corporate Security Support in Baltimore were a contributing factor. To correct this and to streamline the interface of security operations with other plant processes, we reassigned security responsibility to the Nuclear Support Services Department onsite. This transition is still in progress. We feel that these measures will effectively arrest the problem trend.
We will continue to provide substantial resources to upgrade security facilities as part of our commitment to maintaining excellence in all facets of security.
ENGINEERINGfl'ECllNICAL StJPPORI We concur with the SALP assessment and appreciate its recognition of our continued improvements over the period. Most significant of these was our reorganization to create a Technical Support organization under the Plant General Manager.
Coupled with the staffing and training improvements, this change positions us well to meet our goal of continued improvement.
To achieve this goal, we will maintain our current strengths through improved self assessment, including enhanced performance indicators. Areas we are not satisfied with will receive increased emphasis. These include improving our work prioritization process and reducing the facility change request backlog: placing a high priority on our Drawing Improvement Project; strengthening our Saltwater resolution efforts; enhancing performance of our NDE program; and continuing our temporary modification reduction efforts. We feci these initiatives will substantially enhance the safety and quality of plant operations.
SAFETY ASSESSMENT /OtJAIJIY VERIFICATION We agree with the SALP's conclusion that Safety Assessment and Quality Verification improved significantly over previous performance.
A consistent and deliberate effort was made to communicate a safety and quality perspective through management decisions. We feel this has been effective, and that people throughout the organization are convinced that management's highest priority is safety and quality. The reorganization conducted during this year enhanced the Plant l
9 Document Control Desk June 3,1991 l
Page 4 General hianager's lines of authority. It strengthened communications within the staff, and it provided better management oversight. These improvements form the basis for steady, continued improvements in our performance.
Our continued improvement also relies on our effectiveness in identifying problems in a manner that brings appropriate management attention to bear. Our current Problem Report system has substantially improved on the previous systems, and we are about to implement the issue Report which will further integrate identification and prioritization of corrective actions. This process, however, is less important than the staff's underlying commitment to a questioning attitude and to reporting and solving problems as they are found. We see strong evidence that this attitude exists.
We have worked hard to achieve the improvements noted. We feel we have laid the basis for long-term improved performance at Calvert Cliffs with the substantial infrastructure building of the past two years. We recognize that there is still substantial need for improvement and m. ire hard work ahead. We continue to have the full attention, guidance, and support of semor corporate management in these efforts. hianagement's emphasis during the current sal.P period is on accountability, self-assessment, and attention to detail to ensure safe, quality operation as we continue our improvemen'.s. We are confident in our ability to succeed.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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GCC/GLD/JV/bjd cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. hicDonald, Jr., N RC T. T. hiartin. NRC L. E. Nicholson, NRC R.1. hiclean, DNR J. II. Walter, PSC l
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