ML20116F010
| ML20116F010 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/19/1989 |
| From: | Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20116D885 | List:
|
| References | |
| FOIA-96-237 EA-89-141, NUDOCS 9608060199 | |
| Download: ML20116F010 (15) | |
Text
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[,S NUCLEAR REQULATORY COMMISSION E
MEGION I
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47C ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 MEMORANDUM FOR: Distributton JOL 10 lbb FROM:
Lowell E. Tripp, Chief Reactor Projects Section No. IA Division of Reactor Projects t
SUBJECT:
BRIEFING PAPER FOR JULY 20, 1989 CALVERT CLIFFS ENFORCEMENT CONFERENCE (EA 89-141)
Enclosed is a subject paper summarizing events which will be the subject of the Enforcement Conference scheduled for 1:00'p.m., July 20, 1989, at Region I, owell E. Tripp, Chief Reactor Projects Section No. lA
Enclosure:
As stated Distribution w/ enclosure:
W. Russell, RI T. Martin, RI J. Gutierrez, RI D. Holody, RI W. Kane, RI S. Collins, RI J. Wiggins, RI D. Limroth, RI H. Lathrop, RI H. Eichenhqlz.,_ SRI _Calvert. C11ffs..
G P ri tche tt',) RI U;_r; Cal ve rti Cl i f f s
g g eo g 9 96o731 DINICOL96-237 PDR
l ENCLOSURE Briefing paper for Calvert Cliffs Nuclear Power Plant i
Enforcement Conference - July 20, 1989
1.0 INTRODUCTION
During the NRR/RSIB conducted Special Team Inspection, 14 unresolved items were reported.
A regional inspection team followed up on five of these i
items regarded as having the most potential to result in enforcement issues, four of which were identified as apparent violations.
Another item related to control of overtime was also inspected resulting in a fifth apparent violation.
It is believed that a commonality of root cause was identified in this inspection; specifically, procedures for the control of activities impor-tant to safety are either weak, absent, or not followed.
This common weakness was noted to pervade several areas (criteria), (e.g., Document
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Control (Criterion VI); Control of Special Processes (Criterion IX);
Inspection (Criterion X); Control of Measuring and Test Equipment (Crf-l terion XII); and Corrective Actions (Criterion XVI), and could in a broader sense be categorized as a failure to satisfy the requirements of Criterion II, Quality Assurance Program, which requires that the program be documented by written policies, procedures or instructions, be carried out in accordance with those policies, procedures or instructions, l
provide control over activities af fecting the quality of (safety related) structures, systems and components.
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Briefing Paper - Calvert Cliffs 2
Enforcement Conference 7/20/89 2.0 CONCERNS AND APPARENT VIOLATIONS I
l 2.1 Measuring and Test Equipment (M&TE) a.-
Findings i
f
- Responsibility for the M&TE program has been delegated to the I
supervisor of each group using M&TE, ensulting in a fragmented and non-uniform approach to a calibration program.
One instrument had repeatedly failed calibration checks and was
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i not entered into the Nonconformance Report (NCR) system as I
required until brought to licensee attention by the NRC inspec-i tor.
Further review of records indicated five cases of repet-
}
itive failure and the instrument had not been removed from ser-vice. This indicated a lack of trending of failures.
Some pressure gauges used for calibration of installed gauges used in the conduct of STps, were not controlled within the M&TE program. Gauges were comparison tested against a mor,e accurate standard and then issued for use.
Following use, the gauge would be returned to the cage / shelf until again required without post-use calibration checking.
Other instruments were stored in a cage located in the water treatment plant area which satisfied neither cleanliness, environmental, or controlled condition requirements, nor segre-gation' of ca.1ibrated from uncalibrated instruments.
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Briefing Paper - Calvert Cliffs 3
Enforcement Conference 7/20/89 Mechanical ' Maintenance MTE calibration data sheets were rou-tinely reviewed two to six weeks af ter calibration wa:, performed without a means to highlight out of tolerance equipment to assist in expedited review of known deficiencies.
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Good practice which would dictate calibration checks following use to assure that an instrument had not gone out of tolerance during use, were not employed.
b.
Enforcement Issues / Potential Violation -
)
Failure to control test pressure gauges within MTE pro-t
- gram, Failure to prepare timely NCRs, Improper control, segregation and storage of Performance Engineering MTE, are specific examples of failure to properly implement the MTE program as required by CCI 1200 and QAP 17 and const'itutes an apparent violation of quality-assurance program requirements (10 CFR 50, Appendix B Criteria) and requirements of standards to which the licensee is committed (ANSI N18.7-1976). No direct 3
impact on nuclear safety was determined from these apparent violations.
c.
Causal Factors i
Inadequate and/or inconsistent administrative controls to imple-ment an effective program for the control of MTE to satisfy regulatory requirements or good engineering practices.
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Briefing Paper - Calvert Cliffs 4
Enforcement Conference 7/20/89 l
d.
Corrective Actions NCRs were prepared as required for out-of-calibration instru-ments; the instrument which had repeatedly failed calibration was removed from service; test gauges which were not controlled under the M&TE program were reportedly being brought within the program; gauges in question were calibration checked and found l
to be satisfactory; all STPs for which questionable gauges were l
used were identified for further review should a gauge have failed calibration checks.
2.2. Technical Manuals a.
Findings l
l Copies of unapproved technical manuals had been distributed to the onsite operating organization with the only control being a l
statement in an instruction (CCI 122) to the effect that users are to use only controlled copies of technical manuals.
(Con-trolled copies are identified by a cover sheet bearing a control stamp).
Onsite operating ' organization personnel had " personal copies" of technical information received from training courses, and in one case, a technical writer was on a vendor distribution list for technical literature; however, no instances were identified where these data were used in safety-related work.
Rather, it 9
was discussed as a questionable, practice where better receipt control mi g h,),t be appropriate.
The individuals had forwarded j
copies of f.'h'i s technical information to the Document Control j
Center per CCI 122.
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l Briefing Paper - Calvert Cliffs 5
Enforcement Conference 7/20/89 An issue had been raised during the STI regarding lack of guid-
)
ance relative to engineering review of technical manuals.
A i
memorendum had been issued June 9,1989, providing that guidance and the content of that memorandum was being' incorporated into a pending revision to CC1 122.
l b.
Enforcement Issues / Potential Violation Issuing unapproved documents to onsite operating organization personnel is an apparent violatiod of 10 CFR 50, Appendix B, Criterion VI, which requires that measures shall assure that documents are reviewed for adequacy and' approved for release by authorized personnel.
l c.
Causal Factors Iaadequate administrative control coupled with a perceived lack l
of understanding on the part of plant personnel regarding the j
reason for document control.
f d.
Corrective Actions i.
Copies of 'unrev'iewed technical manuals were recalled from the field and a licensee representative agreed to cease the l
l practice.
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Licensee had done an apparently thorough job of identifying
.,00 technical manua.ls, requiring engineering review.
about 3
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Detaileii guidance had been issued relative to engineering
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review requirements.
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Briefing Paper - Calvert Cliffs 6
Enforcement Conference 7/20/89
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2.3 Control of Welding Process Activities a.
Findings i
There was no evidence of pervasive problems with control of weld filler material at the site.
j Company-wide welding oriented administrative procedures were in i
use without having had POSRC review and plant management approval.
CCI 222, " Control of Welding Activities" had been cancelled l
February 28, 1989, leaving the plant without an approved govern-1 ing procedure on the subject. A " shop / lab memo" had been issued in the interim (February 14,1989) to cover the deficiency; this memo had not been reviewed / approved by the POSRC, but is reportedly in accordance with another CCI (119) (per licensee l
response of June 21, 1989 to STI report).
)
b.
Enforcement Issues / Potential Violation
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l Apparent failure to maintain adequately reviewed and approved procedures for the conduct of special processes as required by 10 CFR 50, Appendix B, Criterion IX.
c.
Causal Factors I
l Indeterminate.
d.
Corrective Actions Shop / lab memo to be changed to POSRC approved procedure.
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Briefing Paper - Calvert Cliffs 7
Enforcement Conference 7/20/89 l
l 2.4 Control of Quality Control (QC) Inspection Activities l
a.
Findings 9
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No descriptions of the methodology or process to be followed by QC in implementation of inspection and overview responsibil-ities.
QC inspectors were provided little or no direction i
regarding what was to be inspected, criteria, etc., and relied l
almost entirely on the' inspector's judgement relative to what l
was to be inspected, what was satisfactory, and what inspection results were-to be documented.
j Review of work in progress and completed worked revealed a broad spectrum of results ranging from very general work directions to the crafts with a non-explanatory signature on the package by a l
QC representative to signature on hold / witness points with ll specifics of inspection requirements to short written remarks by QC inspectors regarding work done and inspected.
b.
Enforcement Issues / Apparent Violation Lack of adequate work detail in maintenance orders and/or lack of direction with respect to inspection and acceptance criteria are an apparent violation of 10 CFR 50, Appendix B, Criterion V, which requires that activities affecting safety be prescribed by documented instructions,... and be accomplished in accord-ance with these instructions.
.if c.
Causal Factors j
Indeterminate.
The QC function does not appear to have received adequate management attention / priority in the past.
Its loca-tion within the overall organization had been relocated; QC lacked continuity and direction.
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Briefing Paper - Calvert Cliffs 8
Enforcement Conference 7/20/89 d.
Corrective Actions Reorganization within QA Department and assignment of an indi-vidual with a good track record to manage QC activities.
Independent contractor hired to assist in developing and imple-menting improvements.
QC administrative procedures under accelerated developement.
Three quality Engineers had been hired.
Apparent high-level management (Vice President-Nuclear Energy) attention has been-focused on issues.
2.5 Control of Overtime I
a.
Findings During the STI, 20 instances in which the licensee employees had exceeded the guidelines of CCI-140E, " Shift Staffing and Over-
' time Controls" were identified.
A further review of records j
covering the per'iod March-May 1989, was conducted indicating another seven instances in which employees exceeded the 72-hours within a 7-day period without before-the-fact management approval.
It was noted that employees were getting one day off/
7-day period.and that the hours by which the 72-hour limit was exceeded were low; i.e., about 4-12 hours.
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Briefing Paper - Calvert Cliffs 9
l-Enforcement Conference 7/20/89 b.
Enforcement Issues / Apparent Violation The failure to review and approve exceeding overtime limits before-the-fact is an apparent violation of failing to follow CCI-140.
l c.
Causal Factors Inattention on part of supervisors or lack of planning.
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Corrective Action i
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None indicated.
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Briefing Paper - Calvert Cliffs 10 Enforcement Conference 7/20/89 4
3.0 PERTINENT ENFORCEMENT HISTORY 3.1 May 25, 1989 (Confirmatory Action Letter 89-08) issued confirming
' licensee commitment to maintain units shut down as follows:
i Unit 2:
Determine and resolve apparent material defects asso-ciated with pressurizer penetrations.
Unit 1:
Provide basis for determination that Unit 2 pressur-izer penetration problem is not applicable to Unit 1 or, if applicable, that issue has been resolved.
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l Both:
Determine and correct cause(s) of the problems mani-fested as weaknesses in:
I Control of system status Control of work activities Procedure use and control of procedure changes, i
Also, participate in a management meeting to present results of near-term corrective action" taken to provide assurance that problems will not recur.
Regional Administrator concurrence required for restart of first unit.
3.2 April 17-19,1989 (Inspection Report 89-11) identified two instances of noncompliance resulting in one Leyel III ($75,000 Civil Penalty) related to failure to maintain containment integrity during core alterations and failure to perform required safety evaluations to ensure that temporary modifications did not involve an unreviewed safety question.
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-l Briefing Paper - Calvert Cliffs 11 Enforcement Conference 7/20/89
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3.3 February 21 - April 3, 1989 (Inspection Report 89-04) identified j
three Level IV and one Level V violations related to procedure viola-tions, inadequate procedures, and failure of'POSRC to review facility
. operations to detect pertinent safety hazards.
3.4 January 10 - February 20,1989 (Inspection Report 89-08) identified l
!l one Level IV violation related to inadequate control of procedure 1
changes, which resulted 'in repeated reactor startups without having performed TS required surveillance of the manual trip channel func-tional test.
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t 3.5 January 1-12,1989 (Inspection Report 89-01) identified two related l
Level IV violations associated with shipment of contaminated material.
j.
3.6 October 31 - November 1,1988 (Inspection Report 88-29) identified 1
two Level IV violations, one related to the solid radwaste system and l!
one related to transportation.
The violation related to radwaste j
involved not only a procedural noncompliance but, perhaps more significantly, had been earlier identified by a licensee NCR and had not been corrected.
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3.7 October 24 - November '4,1988' (Inspection Report 88-28) identified one Level V violation related to Appendix 8, Criterion III, design review by same individual as the one performing the design.
Weak procedural discretion was identified as the cause.
l 3.8 August 9 - Septeper 12, 1988 (Inspection Report 88-19) identified one Level IV violation stemming from failure to comply with proced-ures which resu1Ied in defeating the interlock of both containment
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l airlock doors.
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a Briefing Paper - Calvert Cliffs 12 Enforcement Conference 7/20/89
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3.9 June 27 July 13,1988 (Inspection Report 88-17) identified two violations associated with an inoperable EDG and an improper adjust-ment to reactor protective instrumentation.
This resulted in escalated enforcement and a civil penalty-of $75,000 for each event.
Attachments:
1.
Applicable Excerpts from 10 CFR 50, Appendix B 2.
Inspection Report No. 50-317/89-15 and 50-318/89-16 l
e e9 9
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l te2 ting of the structures, systems, and com-functions cre those of (a) assuring that an have bee ponents of the facility. Every cpplicant for appropriate quality assurance program is es.
into acco an operating license is required to include, tablished and effectively executed and (b) procef s in its final safety analysis report, informa-verifying, such as by checking, auditing, and to attain tion pertaining to the managerial and ad-Inspection, that activities affecting the for veriffi
)
ministrative controls to be used to assure safety related functions have been correctly test.YIIe 7
safe operation. Nuclear power plants and performed. The persons and organizations nWon an
)
fuel reprocessing plants include structures, performing quality assurance functions activities systems, and components that prevent or shall have sufficient authority and organi-assure th
- l mitigate the consequences of postulated ac-zational freedom to identify quality prob.
and malt ji cidents that could cause undue risk to the lems; to initiate, recommend, or provide so-larly revi health and safety of the public. This appen-lutions; and to verify implementation of so.
quality ac
" dix cstablishes quality assurance require-lutions. Such persons and organizations per.
other or m!nts for the design, construction, and op-forming quality assurance functions shall quality a
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i eration of those structures, systems, and report to a management level such that this review th components. The pertinent requirements of required authority and organizational free.
of the
(,
this cppendix apply to all activities affect-dom, including sufficient independence they are <
ing the safety-related functions of those from cost and schedule when opposed to structures, systerns, and components; these safety cons!derations, are provided. Because I'I activities include designing, purchasing, fab-of the many variables involved, such as the Measur 0
ricating, handling, shipping, storing, clean-number of personnel, the type of activity that appl ing, erecting, installing, inspecting, testing, being performed, anel the location or loca-operating, maintaining, repairing, refueling, the desir and modifying.
tions where activities are performed, the or-specified As used in this appendix, " quality assur-ganizational structure for executing the those str l
ance" comprises all those planned and sys-quality assurance program may take various to which j
temntic actions necessary to provide ade-forms provided that the persons and organl-translate j
quite confidence that a structure, system
- zations assigned the quality assurance func-
- cedures, i
or component will perform satisfactorily in tions have this required authority end orga-shall ine' service. Quality assurance includes quality nizational freedom. Irrespective of the orga-propriate control, which comprises those quality as-nizational structure, the individual (s) as-and incle surance actions related to the physical char
- signed the responsibility for assuring effec-deviation i
acteristics of a material, structure, compo-tive execution of any portion of the quality trolled. I nent, or system which provide a means to assurance program at any location where for the s I
control the quality of the material, struc-activities subject to this appendix are being
- of appilt ture, component, or system to predeter-performed shall have direct access to such
- tuent, aru mined requirements.
levels of management as may be necessary safety re!
to perform this function.
systems r I* DO*"0" II. QUAMTT AssURacs PaOGaAM j
The applicant
- shall be responsible for jdent le the establishment and execution of the The applicant shall establish at the carij.
faces ani 4
i quality assurance program. The applicant est practicable time, consistent with the pating de
- may d
- legate to others, such as contractors, schedule for accomplishing the activities, a shall inc a agents, or consultants, the work of estab-uality assurance program which complies dures arr i lishing and executing tle quality assurance w
the requirements of this append 1x.
tiens for program, or any part thereof, but shall This program shall be documented by aTit:
i retain responsibility t! erefor. The author, kn policies._ procedures, or instructiu and ity and duties of persons and organizations. shall be carried spt througnout plant life in g
2 performing activities affecting the safety re.
accordance with those policies, procedures, r ve l lated functions of structures, systems, and or instructions. The applicant shall identify 8
components shall be clearly established and the structures, systems, and components to
! delinnted in writtrig These activities in.
be covered by the quality assurance pro-j clude both the performing functions of at.
gram and the major organizations partici-oN
- taining quality objectives and the quality pating in the program, together with the 4
i sasurance functions. The quality assurance designated functions of these organizations.
orme The quality assurance program shall.32I2-j
. ride control over activities affecting the bi
- While the term " applicant" is used in quality of the identiflRR7tictures, systems. -
tion.
3 th:se criteria, the requirements are, of and components, to an extent consistent verify th course, applicable after such a person has with their importance to safety. Activities ture in 1 i received a license to construct and operate a affecting quality shall be acco_mplish_ed processes i
nucitar powerplant or a fuel reprocessing under suitably controlled condlRQDE con.
Alons tes,
! plant. These criteria will also be used for trolled conditions include the use of appro-Incet ads guidance in evaluating the adequacy of priate equipment
- suitable environmental hol men:
quality assurance prograrns in use by hold.
conditions for accomplishing the activity, 88 3
ers of construction permits and operating 11-such as adequate cleanriess; and assurance censes.
that all prerequisites for the given activity compatg 8
550 b6 TA G H n JT I
Mtlen)
Nuclear Regul:ttry Commissi:n Pcrt 50, App. B that an have been satisfied. The program shall take inservice inspection, maintenance, and
.an is es.
Into account,the need for special controls, repair; and delineation of accept.ance crite.
(by procegus, test equipment, tools, and skills ria for inspections and tests.
ti and to attain the requiredlBality, and the need Design changes, including field changes, ing the -
for verification of aualltv hv insoection and shall be subject to design control measures correctly test The program shall provide for indoh commensurate with those applied to the
' nizatitns ria! Ton and training of personnel performing original design and be approved by the orga-functions [ -
acurlues affecung quaHty as necessary to nization that performed the original design assure that suitable profielency is achieved unless the applicant designates another re-d crgant}
and maintained. The applicant shall regu-sponsible organization.
ity prob
. vid larly review the status and adequacy of the
^ ton cf quauty assurance pmgrazn. Management of W. Nmmm Dem Comot.
tions other organizations participating La the ons quality assurance program shall regularly Measures shall be established to assure that applicable regulatory requirements, t
review the status and adequacy of that part anal of the quality assurance program which design bases, and other requirements which pen they an execudng.
are necessary to assure adequate quality are suitably included or referenced in the docu-2 III. Daston Comot, ments for procurement of material, equip-l 1.
ment, and services, whether purchased by ach as Measures shall be established to assure the app!! cant or by its contractors or sub.
.f neu that applicable regulatory requirements and contractors. To the extent nerwamary, pro-a or the design basis, as defined in i 60.2 and as curement documents shall require contrac-id, specified in the lleense application, for tors or subcontractors to provide a quality Jting those structures, systems, and components assurance program consistent with the per-ke to which t.hls appendix applies are correctly Linent provisions of this appendix.
nd transhted into specifications, drawings, pro-mee cedures, and instructions. These measures V. InsraccrIonk, Paoccuomas, un and shall include provisions to assure that ap-DRAWINCs
- the propriate quality standards are specified
- ual '
and included in design documents and that Activities affecting quality shall be pre.
- ring, deviadons from such standards are con-scribed by documented instructions, proce-he troUed. Measures shall also be established dures, or drawings, of a type appropriate to it for the selection and review for suitability the circumstances and shall be accom-
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of application of materials, parts, equip-plished in accordance with these instruc-ment, and processes that are essential to the tions, procedures, or drawings. Instructions, safety related functions of the structures, procedures, or drawings shall include appro-oc systems and components.
priate quanutative or qualitative acceptance 4
Measures shall be established for the criteria for determining that important ac-tivities have been satisfactorily accom-ImAst jdentiflCatlon SDd Control of design intef*
plished.
ggg faces and for coordination among particb pating design organizations. These measures VI. DocunutwT CoNTRo!.
shall include the establishment of proce-dures among participating design organiza-Measures shall be established to control Uons for the review, approval, release,' dis.
the issuance of documents, such as instruc-ed tribudon, and revision of documents involv-tlans, procedures, and drawings, including ing design interfaces, changes t. hereto, which prescribe all activi-The design control measures shall provide ties affecting quality. These measures shall 3
<for verifying or checking the adequacy of assure that documents, including changes, all design, such as by the performance of are reviewed for adequacy and approved for design reviews, by the use of alternate or release by authorized personnel and are dis-skapufled calculational methods, or by the tributed to and used at the location where j
performance of a suitable testing program.
the prescribed activity is performed.
j
'Ibe verifying or checking process shall be Changes to documents shall be reviewed
. performed by individuals or groups other and approved by the same organizations than those who performed the original that performed the original review and ap-damigm but who may be from the same orgs-proval unless the applicant designates nn-es,-
.,alsaMon. Where a test program is used to other responsible organization.
verify the adequacy of a specific design fea-ture in lieu of other verifying or checking VII. CoNTRo!. or PURCHASED MATEa1AL, processes, it shall include suitable qualifica-EQUIrnrENT, AND SERVICES tiens testing of a prototype unit under the Measures shall be established to assure ausst adverse design conditions. Design con-that purchased material, equipment, and 6{
ameasures shall be appUed to items such services, whether purchased directly or es the following: reactor physics, stress, through contractors and subcontractors, l*
Serenal, hydraulic, and accident analyses; conform to the procurement documents.
ibility of materials; accessibility for These measures shall include provisions, as s
551
a I
CALVERT CLIFFS SALP MANAGEMENT MEETING APRIL 23, 1990 U.S. NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORTS NOS, 50-317/88-99 AND 50-318/88-99 CALVERT CLIFFS NUCLEAR POWER PLANT ASSESSMENT PERIOD:
LECEMBER 1, 1988 - DECEMBER 31, 1989 i
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>/8 190c'/!CC & Waw I
=
l
'i l l]l OPERATIONS l
EARLY PART OF ASSESSMENT PERIOD c
PRODUCTION OVER QUALITY PHILOSOPHY MANAGERIAL AND ADMINISTRATIVE CONTROL PROBLEMS WEAK PROCEDURE ADHERENCE PHILOSOPHY /0UALITY OF PROCEDURES SOME WEAK INTERDEPARTMENTAL COMMUNICATIONS
+
PROFESSIONAL KNOWLEDGEABLE OPERATORS; GOOD CONTROL 0F SIGNIFICANT EVOLUTIONS:
GOOD RESPONSE TO PLANT CHALLENGES
- l LATTER PART OF ASSESSMENT PERIOD
+
COMMITMENT TO IMPROVE
+
SATISFACTORY CONTROL 0F OPERATIONS
+
EFFECTIVE SHIFT BRIEFINGS l
+
IMPROVED PROCEDURAL ADHERENCE l
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CONCLUSION:
CATEGORY 3 TREND:
IMPROVING
RADIOLOGICAL CONTROLS l
+
CONTINUED EFFECTIVE PROGRAM
+
GOOD ALARAs LOW CUMULATIVE EXPOSURE
+
WATER CHEMISTRY IMPROVEMENTS
+/ - OVERALL EFFECTIVE TRAINING CONTINUED UllTIMELY RESOLUTION OF IDENTIFIED ISSUES PROCEDURAL ADHERENCE / CONTROL PROBLEMS l
REPEAT RAD WASTE SHIPPING INADEQUACIES 1
l CONCLbSION:
CATEGORY 2 l
RECOMMENDATION:
LICENSEE:
CORRECT PROBLEM RESOLUTION PROCESS i
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i MAINTENANCE / SURVEILLANCE I
EARLY IN ASSESSMENT PERIOD
+
CHANGED ORGANIZATION TO CORRECT DEFICIENCIES / PERSONNEL
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l-ADDITIONS
+
SOME GOOD MAINTENANCE PERFORMANCE BATTERY CONNECTION PROBLEM CONTINUING EQUIPMENT PROBLEMS ADVERSELY AFFECTED PERFORMANCE l
AFW PROBLEMS EDG PROBLEMS WEAK CONTROL OF MAINTENANCE ACTIVITIES QC SUPPORT P00R WORK INSTRUCTIONS RELIED HEAVILY ON CRAFT JUDGEMENT SURVEILLANCE PROGRAM FRAGMENTED F
MISSED AND INCORRECTLY PERFORMED SURVEILLANCES l
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MAINTENANCE / SURVEILLANCE 2
(CONTINUED)
LATTER PART OF ASSESSMENT PERIOD IMPROVED MAINTENANCE PROCEDURES
+
IMPROVED LEVEL OF PERFORMANCE
+
SOME INEFFICIENCIES IN IMPLEMENTATION IMPROVED CONTROL AND ACCOUNTABILITY FOR SURVEILLANCE PROGRAM
+
CONCLUSION:
CATEGORY 3 TREND:
IMPROVING l
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EFFECTIVE CORRECTION OF DEFICIENCIES
+
EFFECTIVE STAFF; GOOD OFF SITE COORDINATION
+/-
PROCEDURES GOOD r
+/-
GOOD ANNUAL EXERCISE PERFORMANCE - EXCEPTION NOTIFICATION TINELINESS OF STATE AND LOCAL 0FFICIALS l
l
+/-
TRAINING GOODS 3 PERSONS FOR EACH KEY POSITIONS EXCEPTION
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l 0VERDUE PERIODIC REFRESHER SHIFT STAFF DOSE ASSESSMENT DEFICIENCY CONCLUSION:
CATEGORY 2 t
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e, p-D, E
1; i SECURITY
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+
CONTINUED EFFECTIVE PROGRAM 1
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+
KNOWLEDGEABLE, PROFESSIONAL STAFF l
+
STRONG CORPORATE SUPPORT a
+
SOUND WELL DEVELOPED TRAINING PROGRAM
]
1
+
RESPONSIVE TO IDENTIFIED PROBLEMS
+
SOUND PROCEDURES l
l CONCLUSIONS:
CATEGORY I i-l l
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I' 1
. ENGINEERING / TECHNICAL SUPPORT
+
COMMITMENT TO IMPROVE AND CORRECT PREVIOUS PROBLEMS: PIP INITIATIVES l
+
INCREASED STAFFING
+
SYSTEM ENGINEER PROGRAM l
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+/- MOVED STAFF TO IMPROVE COMMUNICATIONSs SOME PROBLEMS REMAIN j
+/-
CONDUCTED HIGH QUALITY SSFI
)
ANNUAL SSFI NOTEWORTHY INITIATIVE DID NOT BROADLY APPLY FINDINGS SOME P00R TECHNICAL SUPPORT STARTUP WITH UNIS0LABLE SG LEAK EDG FUEL OIL ANALYSIS AFW FAILURES LTOP CONCERNS l
- CONCLUSION:
CATEGORY 2 RECOMMENDATION:
NRC: REVIEW UNIT 2
PZR PROGRAM PRIOR TO
~
RESTART 1
s,m,-
, --w t-m, um
~
i l
SAFETY ASSESSMENT /00ALITY VERIFICATION
+
SAFETY EMPHASIS LATER IN PERIOD
+
SELF-ASSESSMENT OF PERFORMANCE
+
REVIEW COMMITTEES EXHIBITED GOOD SAFETY ETHIC
+/-
QA AUDITS IDENTIFY DEFICIENCIES l
FOLLOWUP 0F DEFICIENCIES NOT EFFECTIVE l
+/-
LICENSING DEPARTMENT PERFORMANCE MIXED
-/+
QC PROGRAM DEFICIENCIES EXPERIENCE OF INSPECTORS WEAK PROGRAM PROCEDURE CONTROL RESTRUCTURE TO STRENGTHEN IMPROVEMENT LATE IN PERIOD PRODUCTION VS QUALITY EMPHASIS EARLY WEAK INTERDEPARTMENTAL COMMUNICATIONS WEAKNESS IN CORRECTIVE ACTIONS AND COMMITMENT MANAGEMENT SYSTEMS 1
WEAK SAFETY EVALUATION PROCESS
SAFETY ASSESSMENT / QUALITY 2
VERIFICATION (CONTINUED)
CONCLUSION:
CATEGORY 3 RECOMMEllDATION:
LICENSEE: REEVALUATE SCOPE OF PIP NRC:
CONDUCT IPAT 1
l
l l'
SUMMARY
EARLY PERFORMANCE DECLINE PROCEDURE ADHERENCE / ADEQUACY I
PRODUCTION VS QUALITY PHILOSOPHY PERFORMANCE IMPROVEMENTS LATE IN PERIOD OPERATIONS DEPARTMEllT IMPROVEMENT SUBSTANTIAL CHANGE IN PHILOSOPHY / AGGRESSIVE EFFORT T0 i
IMPROVE l
MANAGEMENT / PROGRAMMATIC CHANGES TO IMPROVE IMPROVED PROCEDURE ADHERENCE /0 lit.LITY SOME WEAKNESSES STILL EXIST l
l CORRECTIVE ACTION AND COMMITMENT MANAGEMENT PROGRAMS i
RESOLUTION OF IDENTIFIED PROBLEMS l
CONTINUED SENIOR MANAGEMENT ATTENTION NECESSARY l
d 4
BALTIMORE GAS AND ELECTRIC MEMORANDUM l
DATE:
August 16,1990 fi
.g a;M 2 A plw' TO:
Mr. H. W. Kerch FROM:
Mr. M. D. Milbradt
SUBJECT:
Extension of Commitment i
Per our telephone conversation on Wednesday, August 15,1990, I would like to, inform you;of.our desire to extend the date for a Commitment we made in our response to NRC Inspection Report 504 717S0-017aii543,1,8@l)
The second item in Violation A of the report describes examples of poor radiographic work practices as a result of failing to follow procedures. In our response, dated May 15,1990, we committed to incorporating more detailed and specific directions for radiography into our radiographic procedures by August 31,1990.
j As I stated in our conversation on August 15, we would like to extend the August 31,1990 date by 4 weeks to September 28,1990. Due to the extension of the Calvert Cliffs Unit 1 and 2 outages, i
personnel who would normally be available to work on the procedure changes have been involved 1
with outage related work. Additionally, we have grouped the radiographic procedure changes with other procedure changes and prioritized based on need. With very little radiography..being.<=r
,m performed at Calvert Cliffs, other procedures of greater importance are being changed first.
I As stated in our May 15 response, a memo containing new directions for complete and accurate film reviews has already been issued to all certified radiographers at Calvert Cliffs. The new radiographic procedure changes will provide additional guidance to the radiographers.
If you have any questions regarding this matter please contact me (301) 260-4352.
l MYT
%,0 Complia/
nce cc:
L S. Larragoite G. L Detter L Nicholson S. R. Buxbaum B. Watkins f
j
e 2
Page No.
1 CALVERT CLIFFS 1&2
, 06/08/89 SYNPOSIS OF INSPECTION REPORTS REPORT NUMBERS TYPE TOTAL I
TCTION DATES INSPECTION HOURS DESCRIPTION
= _______
87-23 87-25 RESIDENT 396 ROUTINE RESIDENT INSPECTION INCLUDING ASCO 09/01/87 11/20g87 SOLENOID VALVE AND DIESEL GENERATOR PROBLEMS, PORSC AND INSERVICE TESTING 87-24 SPECIALIST B
MANAGEMENT MEETING TO DISCUSS EQUIPMENT 11/10/87 11/10/87 DEGRADATIONS RESULTING IN INOPERABILITY OF NOS. 11 AND 12 AUXILIARY FEEDWATER PUMPS 87-21 87-23 SPECIALIST 16 EMERGENCY PREPAREDNESS INSPECTION AND 11/16/87 11/18/87 OBSERVATION OF FULL PARTICIPATION ANNUAL EMERGENCY PREPAREDNESS EXERCISE 87-25 87-26 SPECIALIST 40 REVIEW OF WATER CHEMISTRY CONTROL PROGRAM 11/30/87 12/04/87 DURING ROUTINE SAFETY INSPECTION 87-27 87-28 RESIDENT 208 ROUTINE RESIDENT INSPECTION 11/21/87 12/31/87 87-26 87-27 SPECIALIST 32 REVIEW OF IMPLEMENTATION OF RADIATION 11/30./87 12/04/87 SAFETY PROGRAM 02 88-02 RESIDENT 294 ROUTINE RESIDENT INCLUDING LICENSEE 0.s1/88 02/12/88 RESPONSE TO FIRE IN U2 ANNUNCIATOR CABINETS AND REACTOR TRIP U2 AND SAFETY l
l INJECTION TANK #21 l
87-28 87-29 SPECIALIST 25 PHYSICAL SECURITY INSPECTION 12/15/07 12/18/87 88-01 88-01 SPECIALIST 619 01/19/88 01/29/88
~
INTEGRATED PERFORMANCE ASSESSMENT (IPA)
INSPECTION 88-03 88-03 SPECIALIST 33 ROUTINE INSPECTION OF NONRADIOLOGICAL 02/29/88 03/04/88 CHEMISTRY PROGRAM 88-04 88-05 SPECIALIST 8
SPECIAL INSPECTION OF CONDITIONS O2/11/88 02/12/88 SURROUNDING CLASSIFICATION, REPORTING AND RESPONSE TO ALERT DECLARED ON FEBRUARY 1, 1988 88-06 88-07 SPECIALIST 32 INSPECTION OF FIRE PROTECTION / PREVENTION 03/14/88 03/18/88 PROGRAM 88-05 88-06 RESIDENT 157 ROUTINE RESIDENT 02/13/88 03/31/88
-07 88-08 RESIDENT 173 ROUTINE RESIDENT C
1/88 05/16/88 88-08 88-09 SPECIALIST 36 INSERVICE TESTING OF PUMPS AND VALVES 04/04/88 04/08/88
I I
, age No.
2 CALVERT' CLIFFS 1&2 l'6608/89 l
SYNPOSIS OF INSPECTION REPORTS REPORT NUMBERS TYPE TOTAL TCTION DATES INSPECTION HOURS DESCRIPTION
==--------------
88-10 88-11 SPECIALIST 32 INPSECTION OF RADIOLOGICAL CONTROLS 5/09/88 05/13/y8 PROGRAM DURING THE UNIT 1 OUTAGE 88-13 88-13 SPECIALIST 16 UNIT 1 CONTAINMENT INTEGRATED LEAK RATE 5/26/88 05/27/88 TEST AND REVIEW OF PREVIOUSLY IDENTIFIED ITEM FOR UNIT 2 88-12 88-12 RESIDENT 226 ROUTINE RESIDENT INSPECTION 3/17/88.06/30/08 88-17 88-17 RESIDENT 20 SPECIAL INSPECTION REGARDING 6/4/88 EVENT
$/27/88 07/13/88 OF INOPERABILITY OF DG DUE TO OPERATOR
{;
i l
ERROR AND 7/4/08 EVENT OF IMPROPER 1
ADJUSTMENT OF DELTA T
,l 88-14 SPECIALIST 80 UNANNOUNCED INSPECTION OF ISI AND' STEAM 5/13/88 06/24/88 GENERATOR ACTIVITIES TO ASCERTAIN ASME CODE COMPLIANCE 88-09
~88-10 SPECIALIST 43 UNANNOUNCED INSPECTION OF DESIGN CHANGES
"9/88 05/13/88 AND MODIFICATION PROGRAM, MAINTENANCE
'l PROGRAM, OUALIT. ASSURANCE AND QUALITY CONTROL INTERFACE i'
88-15 88-15 SPECIALIST 40 IMPLEMENTATION OF DESIGN CHANGES AND l 7/05/88 07/08/88 MODIFICATIONS PROGRAM BY-DES WITH SPECIAL 1
INSPECTION EMPHASIS ON FIELD CHANGE
(
REQUESTS i !
88-11 SPECIALIST 73 STARTUP TESTING FOLLOWING REFUELING OF i
!s/16/88 07/01/88 UNIT 1, CYCLE 10, AND POST MODIFICATION l
TESTING PROCEDURES 88-16 88-16 RESIDENT 319 ROUTINE RESIDENT INSPECTION 7/01/88 08/08/88 88-19 88-19 RESIDENT 505 ROUTINE RESIDENT INSPECTION INCLUDING RI 3/09/88 09/12/88 TI 87-04 88-22 88-22 RESIDENT 328 ROUTINE RESIDENT INSPECTION l7/13/88 10/17/88 88-21 88-21 SPECIALIST 20 INSPECTION OF LICENSED OPERATOR TRAINING 3/31/88 09/01/08 PROGRAM 88-20 88-20 SPECIALIST 56 UNANNOUNCED REACTIVE INSPECTION OF EVENTS 4
7/88 08/19/88 ASSOCIATED WITH A HIGHER THAN ANTICIPATED WORK EXPOSURE ON JUNE 21, 1988 I
1 l 88-24 88-24 SPECIALIST 30 EMERGENCY PREPAREDNESS PROGRAM
)/11/88 10/13/88 f.
=--
1 j
te No.
3 CALVERT' CLIFFS 1&2 t *08/99 SYNPOSIS OF INSPECTION REPORTS l: PORT NUMBERS TYPE TOTAL l TCTION DATES INSPECTION HOURS DESCRIPTION
,l
= - -
=_______
18-23 88-23 SPECIALIST 32 REVIEW OF FUNCTIONS AND ORGANIZATION OF_
- 11/88 10/18/88' OFF SITE SAFETY REVIEW COMMITTEE AND PLANT 1
OPERATIONS SAFETY REVIEW COMMITTEE 18-25 88-25 SPECIALIST 24 I&C INSPECTION OF MAINTENANCE AREAS i
L21/88 11/25/88 1
l 18 - 2 7 88-27 RESIDENT 322 ROUTINE RESIDENT INSPECTION I
l'18/88 11/30/88 j]
38-29 88-29 SPECIALIST 120 UNANNOUNCED INSPECTION OF NON-RADIOLOGICAL
'*31/88 11/04/88 CHEMISTRY PROGRAM
{
18-30 88-30 SPECIALIST 99 EMERGENCY PREPAREDNESS INSPECTION
[05/88 12/07/88 l
b8-28 88-28 SPECIALIST 121 INSPECTION OF CORPORATE ENGINEERING F24/88 11/04/89
' SUPPORT FOR CALVERT CLIFFS E8-31 88-31 SPECIALIST 48 INSPECTION OF RESTRUCTURED MAINTENANCE b5/88 12/09/88 ORGANIZATION l
f
.a-32 88-32 RESIDENT 202 ROUTINE RESIDENT INSPECTION F01/88 01/09/89 s
1
- B9-01 89-01 SPECIALIST 82 INSPECTION OF SOLID RADIOACTIVE WASTE l'09/89 01/13/89 SYSTEMS l
59-02 89-02 SPECIALIST 74 INSPECTION OF RADIATION SAFETY PROGRAM l'09/89 01/13/89
[
!B9-03 89-03 RESIDENT 389 ROUTINE RESIDENT INSPECTION l'10/89 02/20/89
!09-05 89-05 SPECIALIST 76 ENGINEERING-EO j'27/89 03/03/89 UNANNOUNCED INSPECTION OF EQ PROGRAM AND CLOSEOUT OF PREVIOUS OPEN ITEMS i
19 - 0 4 89-04 RESIDENT 524 ROUTINE RESIDENT INSPECTION
'21/89 04/03/89.
4
?
I l i 1
j s
i
)
i
~_
_ge No.
1 CALVERT CLIFFS 1&2
/08/89 SYNPOSIS OF VIOLATIONS i
TCTION REPORTS REQUIREMENT SEVERITY FUNCTIONAL
'ECTION DATES VIOLATED LEVEL AREA DESCRIPTION l'
=
l 38-22 10 CFR2, 5
OPERATIONS LICENSEE IDENTIFIED 10/17/88 APP. C VIOLATION - FAILURE TO l
FOLLOW OP-24 l
OVERFLOW OF SPENT FUEL POOL i
i 39-01 10 CFR 4
RAD-CHEM FAILURE TO PROPERLY
'09/89 01/13/89 30.41(C)
LABEL RADIOACTIVE WASTE
(
l SHIPMENT i
,39-01 10 CFR 4
RAD-CHEM FAILURE TO VERIFY
'09/89 01/13/89 30.41(C)
ACCEPTABILITY OF TRANSFEREE'S LICENSE i
l39-03 T.S.
4 OPERATIONS FAILURE TO CONDUCT
' '10/e9 02/20/89 4.3.1.1 FUNCTIONAL TEST OF MANUAL REACTOR TRIP CHANNELS PRIOR TO THREE I
_ REACTOR STARTUPS ON 8/25/88, 11/15/88,
- i
?
1/11/89 j
38-01 T.S.6.8.3.6 4
SURVEILLANCE TEMPORARY CHANGES TO
'19/88 01/29/88 PROCEDURES WERE NOT PROPERLY REVIEWED
!38-28 88-28' 10 CFR 50, 5
OTHER NCR PROGRAM'- LACK OF i
l'24/88 11/04/89 APP.B REPORTABILITY REVIEW l
18-04 T.S.6.8.1.E 4
EMERG PREP.
DURING ALERT CONDITIONS
- 11/88 02/12/88 PORTIONS OF ERPIP 3.0 WERE NOT IMPLEMENTED IN i
THAT EMERGENCY PERSONNEL WERE NOT NOTIFIED OR RECALLED AS NECESSARY I
88-08 TS 4.4.13.1 5
OPERATIONS LICENSEE IDENTIFIED
'01/88 05/16/88 VIOLATION - U2 PRESSURIZER VENT VALVES NOT TESTED FOLLOWING MAINTENANCE OUTAGE i
18 - 0 7 CCI 101J 5
OPERATIONS THREE TEMPORARY CHANGES
'01/88 05/16/88 THAT DID NOT ALTER INTENT MADE TO STP M529-1,REV.4 W/O 1
l REQUISITE APPROVAL 18 - 0 7 TS 6.9.1.4 5
OPERATIONS LICENSEE'S FAILURE TO 01/88 05/16/88 SUMIT ANNUAL REPORT OF l
ALL FAILURES AND CHALLENGES TO U1 AND U2 i
Por998 I?T 7en onnise e no
~
p I
I Page No.
2-CALVERT CLIFFS 162
( 06/08/89 l /
SYNPOSIS OF VIOLATIONS J
l 1I TCTION REPORTS REQUIREMENT SEkERITY FUNCTIONAL
>ECTION DATES VIOLATED LEVEL AREA DESCRIPTION
__m_______________
l 88-07 10 CFR 2, 5
OPERATIONS LICENSEE IDENTIFIED 04/01/88 05/16/88 APP. C VIOLATION - INATTENTION TO DETAIL BY MAINTENANCE PERSONNEL OF GREASE FILLING ON #22 LPSI MOTOR / PUMP COUPLING 88-10 T.S.
6.11 5
RAD-CHEM RESPIRATOR WEARER WAS 05/09/88 05/13/88 ADMINISTERED THE STANNIC CHLORIDE SMOKE TEST WITHOUT FIRST RECEIVING VERBAL CAUTIONS FROM ADMINISTERING INDIVIDUAL l
88-12 SURV.
5 SURVEILLANCE LICENSEE IDENTIFIED
'05/17/88 06/30/88 4.1.1.2.B VIOLATION CONCERNING i
1 REQUIREMENT FOR SHUTDOWN l
MARGIN l
88-17 TS 3.8.1.1 4
OPERATIONS FAILURE TO MEET TS WITH
)s 7/88 07/13/88 RESPECT TO THE MlNIMUM l
NUMBER OF AC POWER SOURCES DEMONSTRATED TO BE OPERABLE l
88-17 OI 30 4
OPERATIONS FAILURE TO PERFORM-A 36/27/88 07/13/88 CALORIMETRIC CALCULATION PER OI 30 BEFORE MAKING ADJUSTMENTS TO NUCLEAR INSTRUMENTATION AND DELTA T POWER
(
t 88-19 T.S.6.8.1 4
OPERATIONS FAILURE OF-MECHANICAL
})8/09/8809/12/88 MAINTENANCE PERSONNEL TO FOLLOW PROCEDURE HE 21 I
IN BOTH DEFEATING AND RESTORING TWO DOOR
' INTERLOCKS 88-20 10 CFR 4
RAD-CHEM FAILURE TO DO ADEQUATE l'8/17/88 08/19/88 20.201 PRE-WORK SURVEY IN VALVE ALLEY 87-23 10 CFR50, 4
MAINTENANCE THE ROOT CAUSE FAILURE t/87 11/20/87 APP. B OF THE #12 EMERGENCY DIESEL GENERATOR ON HIGH l
COOLING WATER i
TEMPERATURE WAS NOT PROMPTLY IDENTIFIED AND CL9RECTED 1
i
7
. - ~ - -.
Page No.
3 CALVERT CLIFFS 1&2
[6/08/89 SYNPOSIS OF VIOLATIONS 1 l t
1
~CTION REPORTS REQUIREMENT SEVERITY FUNCTIONAL l
- ECTION DATES VIOLATED LEVEL AREA DESCRIPTION l
. = - -
1 88-28 10 CFR 50 5
OTHER NCR PROGRAM - LACK OF l
10/24/88 11/04/88 REPORTABILITY REVIEW 88-29 T.S.6.8 4
RAD-CHEM FAILURE TO FOLLOW 10/31/88 11/04/88 SCALING FACTOR VERIFICATION REQUIREMENTS 88-29 49 CFR 4
RAD-CHEM IMPROPER WASTE
'10/31/88 11/04/88 172.204 CLASSIFICATION l
89-04 TS 6.8.1.E 5
OPERATIONS FAILURE OF CONTROL ROOM O2/21/89 04/03/89 AND F PERSONNEL TO IMPLEMENT REQUIREMENTS OF PROCEDURES DUIRNG FIRE IN CONTROL ROOM PANEL 89-04 TS-6.8.1.A 4
OPERATIONS RO'S FAILURE TO FOLLOW O2/21/89 04/03/89 STP O-7-1 CONSTITUTES A VIOLATION OF TS WHICH REQUIRES IMPLEMENTATION OF PROCEDURES FOR CONDUCT OF TS SURVEILLANCE 89-04 TS 4
OPERATIONS FAILURE OF THE POSRC TO O2/21/89 04/03/89 6.5.1.6.8 REVIEW AN EVENT ON SAFETY RELATED COMPONENT INDICATES FAILURE TO IMPLEMENT FUNDAMENTAL RESPONSIBILITY IN TS 89-04 TS 4
OPERATIONS FAILURE TO PERFORM O2/21/89 04/03/89 4.7.8.1.C REQUIRED SURVEILLANCE TESTING, INCLUDING SAFETY RELATED SNUBBERS AS PER TS SURVEILLANCE REQUIREMENTS L
i
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$ $. bW f
/ 27
/
Rsm. ft. & rem PZ~
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l CALVERT CLIFFS T
INFORMATION REQUESTED d'
Pl.E-INSPECTION VISIT TEBRUARY 7-8. 1989 1.
Corporate and site ceganization charts, plus description of h
responsibilities and interfaces.
~
2.-
Sunnary of plant operations, including significant occurrences since January 1, 1988.
j l
3.
Resumes of management personnel, from the Vice President Nuclear through i
the level of supervision immediately below the Operations / Engineering /QA Managers icvel.
I 4.
Engineering Department staffing, including experience levels of personnel, j
5.
Administrative procedures, and other plant procedures involving:
)'
y a.
Deficiency reparts and LERs, b
j b.
In-plant and off-site review comittees, i
c.
Control of changes, d.
50.59 reviews, I
e.
Corrective actions,
(
f.
Self assessments, 1
g.
Internal reviews including QA audits, a,
Ll h.
Modifications and maintenance, and
- 1., Surve111ances.
6.
Discuss the following areas:
s.
Results of internal revicws r.nd assessments relating to l
interdepartmental.interfien.
b.
The Duke Power assessment of the Engineering Department.
Training programs for operators, engineering personnel, auditors and c.
inspectors, and crafts.
d.
Site requirements for unrestricted access by the NRC inspection team, including contract personnel.
I
~~-
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o g
OCT-W PageIo.
1 CALittfCliffS
- 7/88 8=>
JAM 90 L
WISHLIST l
ENLI 1850IFOR tillit!S ttSPONSIBM 18815f SICf!0f t
)
HTH D05/SUSMCfD PROBLE AHA ASSIStiftCfifMISSOfLICIISIIIllfilflitS PSS 83750 C0tt HQ. - PIAIIID SUIP SNCIfl0 SGINMD Piffl0VS Witttt.
TRS IIS3 tNLID FOR IST @ Attt!
HT50 C0tt 180. - PWID SUIPSNClflIDSCIINLIFORPHTIOUS@Attti.
US IISGINJD FOR IST Wattti i
3ffM C0t! 180. - Of!!NI-IISPICfl01 OTRNI. U-2 FACILifAft3 IISPICfl01 STS 37828 Coll !!Q. - PIAHD IISPICfl0E HH!!!D MI 70 SiglflCMT GalGIS II STS LICUSit's UGlHitIN OtGillufl0B 61725 005/SUSMCftDPROBLEalla LICIISit's 00tt!Cfit! ACfl0! 15 WISfl01&BLI.
OPS ORGUIMfl0E IIIfflCflft. t! Wit! ASSIBIIf of IfftCTIfutSS 811N C0tt HQ. - PIAIHD SUIP SGINLI FOR 1/90.
PPS V
ON0D DOW/SISNCTID PtolLill Hu EltfDHCI ft2 IISPICfl01. Il 2515/97 OPS
.9 1
/'
Page No.
1.
FOURTH QUARTER F1888
,,)
05/19/88 CALVERT CLIFFS UNIT 1 NISHLIST MDDULE REASON FOR REQUEST REMARKS 333333 3333333f*3333333333333333333333333 333333333333M33333333333333 l
'.fR06RAMRED.+INSPECTIONDVERDUE Non-license staff training 41400 concentrate on saintenance personnel training l
41701 PRO 6 RAM RE9. - INSPECTION DUE License operating training i
37702 IMPLEMENTS SALP RECOMMENDATION Problems gettirg design changes out to field, result in inadequate plan & implement of mods. Design Engineering overloaded high personnel turnover 82701 FR06 RAM RER. - INSPECil0N DUE Operational Status of"EF Prograe 62702 SUSPECTED PROBLEM AREA Two significant errors & cther SISAS indicate weakness (high IbC turnover, INPD)
Oliviera did 62700
^
62704 SUSPECTED PROBLEM AREA Instrueent saintenance (see note above)
)
38701 KNONN PROBLEM AREA Procurement Program-Glist Dedication (upgrading of parts to SR) probless with spare parts G list upgrade l
I r
72701 PRO 6 RAM REQ. - INSPECT MN DUE Modification Testing
~
11 SIGNNIFICANT FOLLOWUP OF DPEN ITEM T12515/79-Inspection of EDP's il SIGNNIFIEANTFDLLONUP0FDPENITEM T125')0/20 - Implementation of ATNS Rule e.
i
/_-
j
~.-
i i
f+
Page No.
1 FIRST QUARTER F1989 i
08/22/88
'f CALVERT CLIFFS UNIT 1 WISHLIST f'
MODULE REASON FOR REQUEST REMARKS l
64704
- KNDWN PROBLEM AREA FIRE PROTECT!DN PROGRAM - WEAtNESSES IDENTIFIED REQUIRIN6 FDLLOW UP i
35750 PROGRAM RED. - INSPEC110N DUE DA PR06 RAM MEASURING AND TESi!N6 EGUIPMENT CONTROL i
84000 PR06 RAM REG. - INSPECil0N DUE RADIDACTIVE EFFLUENTS AND NASTES i
i 82301
'R06 RAM REG. - INSPECTION DUE EVALUATION OF E!ERCISES FOR POWER REACTORS - ANNUAL EIERCISE l
82701 PRU6 RAM RED. - INSPECTION DUE OPERAi!0NAL STATUS OF THE EP PROGRAM 40701 IMPLEMENTS SALP RECOMMENDATION OFFSITE REVIEW COMMITTEE - NEEDS TO BE REEVALUATED DUE TO REORGAN!!Ai!0N - SALP CONCERN 40700-IMPLEMENTS SALP RECOMMENDAi!0N ONSITE REVIEW CONNITTEE - NEEDS TO BE REEVALUATED DUE TO REDRSANIZAi!DN - SALP CONCERN PRO 6 RAM REO.. INSPECTION DUE TI 2515/79 - EDP PR06 RAM RED. - INSPECil0N DUE il 2500/20 ATWS i l
\\ i PROGRAM RED. - INSPECT!DN DUE EQFOLLONUP l
\\
PR06 RAM REE. - INSPECT 10N DUE TI 2515/78 INSPECil0N OF DUALITY VERIFICAT10N FUNCT!DNS l
1 i
~
(
Page No.
I SECOND QUARTER ~F1989 J".
h Ii j
!!/29/88 EALVERI CLIFFS UNIT 1 WISHLIST 1
'A I
MODULE REASON FOR REQUEST REMARKS
$33333 3333333333333333333223333333333333 333333333333333333333333333 41400 PRO 6 RAM REG. - INSPECTION OVERDUE Non-licensed staff training - concentrate on saintenance 62702 SUSPECTED PROBLEM AREA Two significant errors and other ESF actuations indicate weakness 62704 SUSPECTED PRDBLER AREA Inst. Maintenance, see 62702 resarts 38701 KNOWN PROBLEM AREA Procuresent Progras-0 list dedication (upgrading of parts to safety related)probleas with spare parts /Glist upgrade 64704 PR06 RAM REG. - INSPECTION DUE Fire Protection-known probles area 37700 PR06 RAM REG. - INSPEti!DN DUE Known probles area 37828 PRO 6 RAM REQ. - INSPECTION DUE Known probles area
- Tl TI 2515/79 Insp. of EDP's T!
il 2500/20 laplesentation of ATUS
)
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s a
9
-e l
i w
/
____________.___.m._.--
s i
~l I
SPECIAL INSPECTION PLAN CALVERT CLIFFS NPP 1,
' MODULE REASON FOR REQUEST REMARKS 42700 Suspected Problem Evaluate procedures for Area correctiveness, applicability and 1
implementation i
424008 Suspected Problem Evaluate procedures for I
Area correctiveness, applicability and implementation 40500 Program Requirement Known Problem Area Inspection Due i
Special Team Inspection 1
Operational Safety Team Inspection (OSTI)
{
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' i 5
4 i
I f
4 1
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t
4 y
.g TQ.
f.
i
. June 2,1989
- i. i
!i TO:
DISTRIBUTION
,.']
FROM:
M. D. Milbradt i
SUBJECT:
[
NRC EOP Inspection - Exit Meeting Notes The NRC EOP inspection exit meeting was held on Thursday May 25. A pre-exit meeting
.was held a day earlier to discuss NRC concerns. The inspectors expressed two concerns
>+
' they termed " restart" items and noted several items within our EOPs they felt we could improve upon. The inspection ' was divided into five tasks and a summary of their major I
concerns identified in each task are summarized below:-
]
Generic Issue
>l Potential " Restart" issue: EOPs are considered guidelines by us and not procedures NRC position: If we are using them as procedures we should have them called procedures and.not guidelines. We should have a specific policy on how the EOPs are to be imple-mented.
BGAEs response: We will give the operators more specific guidance and we will follow
' the EOPs verbatim. At the exit meeting we committed to sending them a plan and sched-i i
j ule on how we will correct this item. They are associating the term " restart" 'with
(
approval of our plan.
b i
Task 1 Basic EOP/GTG (CEN-152) Comparison NRC position: 1. CEN-152 has the Loss of Forced Circulation condition in an EOP. At one point we had itlin EOP-2 but now.we go directly into AOP-3E from EOP-0. Their l
concern is that the ' AOP won't get the same scrutiny and control as an EOP.
)
BG&Es response:,We agree with the comment although the curren : 2OP-2 does have the i
appropriate steps within it to handle natural circulation. We will clarify which steps should be performed.
l-Task 2 Independent technical adequacy review of the Emergency Operstmg i
Procedures NRC positions: 1) Potential " Restart" issue The flow chart in EOP-0 doesn't allow operators to fully ask specific questions needed to diagnose which EOP to go into. It is left up to the judgement of the operator as to which procedure to use. We should expand the - diagnostic chart to allow for the identification of events based on symptom I
analysis.
i e
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DISTRIBUTION June 2,1989
' [H Page 2
?! '
y r BG&Es response: We are currently revising the flow chart to give more guidance to the Mr operators. Our commitment to the NRC at the exit meeting was the same as our response under the generic issue.
a
- 2) EOP-8 does not address vital auxiliaries in the text.
BGAEs response: We will add additional guidance in EOP-8 for vital auxiliaries.
,i t
t i
Task 3 Review of the EOPs by Control Room and Plant walkdowns.
NRC positions:
i I
- ?
!) Labeling
~
a.
Titles of equipment in the EOPs and on the panels do not always match. Ex. SI
'l pump recirc lockout vs. 51 pump miniflow.
<]
i b.
Component identification is not consistent. Ex. the EOP will have the valve l
numb'er while the panel will have the handswitch number.
l c.
Identification numbers are missing on some name tags.
1 d.
' identification tags are missing on some equipment in the field and in the control l
- room, l
l l
e.
The NRC also found cases where paper was used as labeling and dynamo tape used as scales.
BG&E's response: Bruce Mrowca explained our DCRDR program and how labeling was identi-fied as a problem' already. We submitted a schedule last year to the NRC detailing how l
we would change our labeling. We will provide the NRC team with an update of our progress so far.
2)
Our NEOGs in general are hard to use because the information is complex; they are not very user fri:ndly to ROs and SROs.
BG&Es response: We are revising the NEOGs to make them user friendly. Indexing, changing number sequence, and writing them in accordance with' our site specific writers guide are all being done. The't Nuclear Engineering revisions should be finished by August 1. Operations will have to look at how to change the EOPs to reflect the number i
sequence of the NEOGs.
j 3)
When referencing or branching out to another procedure from the EOPs we don't always give adequate instructions on where to go. This can be broken down into 3 f
problems:
I
+
a.
No reference at all l
b.
Put into an Ol without stating which section te use i
c.
Sometimes we are sent to the wrong procedure
- BGAEs response: We agreed to look into this issue.
l
DISTRIBUTION June 2,1989 Page 3
.s Task 4 Simulator observations NRC positions:
1)
Naturs! circulation - transition :nto AOP without using an EOP.
2)
The simulator callback rates (pag 2 telephone) are not consistent with what might be experienced in the plant.
3)
A simulator malfunction was treated as a simulator problem and not a real imposed casualty.
4)
There was no evidence that we train in minimum staffing modes.
5)
The lighting arrangement in the simulator is not the same in the control room.
6)
The noise levels in the simulator are high and varying.
7)
The physical location of operator aids are not the same in the simulator as in the control room.
8)
The binding methods are different between the simulator EOPs and the control room EOPs. We should pick the best method such that they are easy to use and do not obstruct the viewer from seeing the text.
Overall, they think the crews performed well.
BG&Es response: We were to respond to #4 and #8,
- 4.
We agree we should have periodic training at minimum staffing levels and those levels are outlined in our admin procedures not the tech. spec manning levels.
- 8.
We agree that the EOPs should be bound in the best manner and will look into that.
Task 5 Ongoing evaluation of the EOPs and Human factors NRC positions: Overall the writers guide is inadequate in that it does not ensure consistency within the procedures. Specifics are:
1.
The logic sequences are not always clear (and, or, etc.). especially' in EOP-8.
2.
There is no guidance on how to write transition steps or how to structure attach-ments.
3.
We have allowed EOP-8 to be written in a different format than the other EOPs.
4.
Consistency standards are not in place. E x. No set standards for type styles, no l
clear definition of substeps, list of terminology has several words that mean the j
same like ensure vs. verify vs. confirm.
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DISTRIBUTION June 2,1989 4
I Page 4 l
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5.
Procedures referenced from EOPs like the AOPs should have the same level of controls and verification and quality as the EOPs.
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6.
Appears to be inadequate verification of Rev.I being consistent with the basis procedure.
7.
We have an inadequate system for controlled copies.
8.
We do not have a controlled system for job performance operator aids (graphs, nameplates).
l
- 9.
We need to strengthen our verification and validation program for the EOPs and l
their branching procedures.
10.
We need more involvement from different organizations such that when changes are made to EOPs everyone is on board, 11.
Our QA involvement has been limited (i.e., audit participation only).
BG&Es response: We responded to #3, #5, #9, #11
- 3.
We said we would look into making EOP-8 better.
- 5.
We will consider this issue.
- 9.
We have a new verification and validation system in effect and will continue to i ;
monitor its effectiveness.
- 11. We have an independent review group that looks at the changes to EOPs, POSRC.
But, we may need to strengthen their role in reviewing them, i
OVERALL They did not find anything that would have shut us down.
They did not find anything tfiat would have forced the team to stay on site.
The procedures do work The operators do know how to use them.
The EOPs appear to be technically correct (if problems do occur while using. them the operators are good enough to overcome them.)
Positive things:
1.
Awareness of key items in the EOPs 2.
We have a procedural group that deals directly with EOP changes 3.
- The placekeeper in the EOPs l
4.
Simulator sessions are handled well 5.
Training appears to be effective 6.
Fire taps-cross connects between water supplies is good.
1 I
i l
yr DISTRIBUTION June 2,1989 Page 5 j
i The written report from the NRC should be issued in approximately 30 days. If you have any questions regarding this inspection please call me at ext. 4352.
]
i l
- d M.
Engineer /
Licensing MDM/miv i
i DISTRIBUTION: G. C. Creel J. F. Lohr L. B. Russell M. D. Patterson C. H. Cruse B. S. Montgomery i
R. E. Denton J. R. Hill l
R. L. Wenderlich J. E. Gilbert P. E. Katz H. Eichenholz W. J. Lippold V.
L.
Pritchett K. J. Nietmann J. A. Mihalcik 1
R. P. Heibel G. C. Wolf
+
J. T. Carroll L. S.
Larragoite e.
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REVIEh! DF ADDIT 1DNAL CONCFRN NO. 2 - AOP-9 REVISION f
In their dune 21, 1989 response to the NRC, BGLE committed to address certain unresolved items and additional concerns prior to the, restart of either-Calvert Cliffs Unit.
Additional Concern No.12 f ocused on the weaknesses identified with Abnormal Operating Procedure (AOP) - 9, Alternate Safe Shutdown Procedure.
A special licensee project team inspection of this procedure determined that in the event of a control room fire the measures contained in AOP - 9 to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, as required by 10CFR50,-Appendix R, could not be performed. The two major weaknesses identified with ADP-9 were insuf ficient shif t manning. levels and design features in the plant which would not permit required local operations.
The 1,1censee committed to revise AOP-9 to account for design modifications made to the plant and to correct procedural inadequacies.. AOP-9A, Control 9
Room Evacuation And Safe Shutdown Due To A Severe Control Room yire, was written to satisfy that commitment. ' A desk review of AOP-9A identified the following concerns:
- 1. AOP-9A is specific to Unit-1.
It is not clear how this procedure interfaces with Unit-2 in.the. event.of.a control room fire since Units 1 and 2 have a common control. room.
- 2. AOP-9A requires responses from seven different d
1ndividuals: a RO,CRO,SS,STA,OSO,TBO aryd a ABO.
Assuming a similar procedure exists for Unit-2, would this require an i
' additional seven individuals?
Would there be any' responses which would be common to both Units?
Would off shift manning be sufficient to support both Units?
- 3. On pages 11 and 21, paragraph'1. requires the RO to
>{
remove the CLOSE fuses prior to tripping the RCP breakers and refers the RO'to the diagram shown below.' 'It ist recommended that the portion of the diagram that"shows where
'l the ruses.are located be relableo La read "CLOSE FUSES" instead of "CLOSE CIR".
i
- 4. On page 22, step 1.,
it'is recommended that the step be expanded to either cl~early spell out each valve number required to be' repositioned OR to indicate the total' number
~
of valves required to be repositioned to' position 2..
\\
UN' 1
On' page 39 step 2 should be expanded to indicate to/ + hat!
(
5.
rw c
level (2300 ppm?) the RCS should be borated.;-
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x
- 6. To help clarify the AOPs it is recommended,th'at the
- ' 4.N i licensee ~ develop a' Writers Guide,.similar to'that'used[cf orf ' '
a i
writing EDPs, to provide consistency and(alclea" M01Q
\\;
T=
1 understanding of what is required. - For-examplel oqipage?61,'
&q?
of AOP-9A,' step 1 would be clearer if"an "OR" wasfplacedfE
\\
"Y clearer if.an."AND"Lwas placed,between the tw
'between each of the three substeps and stepl3,7would" i
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Square mesh steel wire cloth tack welded to the inside of the strainer box. The project wire mesh specification is: Meshes per
.iinear inch: 2-3/4. Wire diameter:
0.120"., Width opening:
0.244*.
. Percentage of open ares 45%.'
This design. constitutes a strong construction and. will. withstand severe shock and loading. With the
' it is very unlikaly that the l
strainer.will.. clog. } wideness.. of _ the projected flow. areas,. velocity, through the. str I
Due '.to!the flow the resulting ~ pressure drop of ;' extremely. iowthe ' box construction will be ' negJ.
The system design is based on the spray water being heated to the temperature of the steam-air mixture within the containment. The nozzles will spray droplets with a mean diameter of approximately 700 microns with the spray system operating at design conditions and the containment at design pressure. In. order that the spray droplets i
attain thermal equilibrium during the fall, adequate distance is provided between the
- spray noz2les and the. highest obstruction. In the containment..
Any of the following combinations of equipment will provide sufficient heat removal i
capability to maintain the post-incident containment temperature and pressure below their design value:
- -_... _ ___. m _ _
j Ah, Here, b o tay bem CA 6 5 % F5AB. T% 0* ch ad T. A,p p s p t li k ia see. At tw f 6AR say h A>
ainment air 4
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f k.,w ' ewe % led"
%. 9 w e. Wwe l
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Andri beds x M h.
Materials appreciable iew of all degree ar.
aluminum CowrAWMenT 50MP erWAn4Eg sceseM
Flow TMSOU4H 6CES84" g
6-29 Rev.6
I l
c.
Square mesh steel wire cloth tack welded to the inside of the strainer box. The project wire mesh specification. is: Meshes per.
, linear inch: 2-3/4. Wire diameter:
0.120". i Width opening:. 0.244*.
1 Percentage of open area: 45%.1 1
j This design constitutes a strons _ construction and will withstand severs abock and loading. iFith i-the
. strainer will clog. ! wideness; of,'the projected flow. areas, it is very. unlikely that t j
Due '.tolthe extremely' low. flow. velocity through
- the strainer box,'
]
the resulting ' pressure drop of the ' box construction will. be ' negligible."
4 i
The system design is based on the spray water being heated to the temperature of the j
steam-air mixture within the containment. The nozzles will spray droplets with a mean i
diameter of approximately 700 microns with the spray system operating at design
{
conditions and the containment at design pressure. In order that the spray droplets j
attain thermal equilibrium during the fall, adequate distance is provided between the
- spray nozzles and the. highest obstruction. In the containment..
i Any of the following combinations of equipment w!Il provide sufficient heat removal capability to maintain the post-incident containment temperature and pressure below i
their design value:
a.
Two containment spray pumps will provide 100 percent cooling j
(_
capacity.
b.
One containment spray pump in conjunction with two containment air cooling units will provide more than 100 percent cooling capacity, c.
Three containment air cooling units will provide 100 percent cooling capacity.
Materials exposed to the containment spray solution that corrode to any appreciable degree are aluminum and zinc. Section 14.21.2.4 provides a detailed review of all aluminum and zinc equipment which may be exposed to the spray solutions.
Cz*nrAWMegT SOMP smAn4Eg ficrecht
" Flow Tes0Ud:H 6CEGGd" 6-29 Rev.6