ML20117P966
| ML20117P966 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/18/1989 |
| From: | Mcneil S Office of Nuclear Reactor Regulation |
| To: | Capra R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20116D885 | List:
|
| References | |
| FOIA-96-237 NUDOCS 8908240285 | |
| Download: ML20117P966 (13) | |
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UNITED STATES 8
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August 18, 1989 MEMORANDUM FOR: Robert A. Capra, Director Project Directorate I-I Division of Reactor Projects - I/II FROM:
Scott A. McNeil, Project Manager Project Directorate I-1 Division of Reactor Projects - I/II
SUBJECT:
BG&E RESPONSE TO STI RESTART ITEMS On June 21, 1989, BG&E provided its response to additional concerns that arose as a result of the NRC Special Team Inspection (STI) at Calvert Cliffs. These concerns were specifically identified as needing a formal response during the NRC/BG&E June 9, 1989 entrance for the STI Follow-up Inspection.
The STI concerns requiring response were divided into three categories pertaining to the type of corrective actions that were necessitated.
Category 1 Item complete prior to restart Category 2 Program / Plan in place with short-term actions taken prior to restart and with appropriate long-term corrective actions Category 3 Others including additional Performance Improvement Plan (PIP) items.
Included were concerns derived from the body of the STI report in addition to the unresolved items (URIs) that were specifically identified.
In response to a request from' Jim Wiggins, Chie'f of Reactor Projects Branch, Region I, I have examined the licensee's June 21, 1989 submittal to verify that the licensee responded to all non-URI, Category I and 2 STI concerns.
The results of this examination and a cursory evaluation of the associated responses is provided in Enclosure B.
In addition, the following information is also provided 1) a listing of all STI findings and concerns (Enclosure A) and 2) a listing and cursory evaluation of Category 3 concerns that the licensee intends to correct with short-term actions only (Enclosure C).
Please note that the primary purpose of this examination was to determine if the licensee had responded to the additional specified non-URI concerns that resulted form the STI.
It was not conducted with the intent to perform an exhaustive or final evaluation of the adequacy of the licensee's corrective actions for STI concerns.
Scott A. McNeil, Project Manager Project Directorate I-1 Division of Reactor Projects - I/II D[:)cf.
Enclosure:
As stated
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ENCLOSURE A STI Findings and Concerns UNRESOLVED ITEMS Item Category BG8E Response Location
.1 MATE Control 2
6/21/89 Itr item URIf1 2 Procedural Intent Changes 1
6/21/89 Itr item URIf2 3 Standing Instructions vs. Procedures 2
6/21/89 Itr item URIf3 4 Safety Implications of Maintenance,
-2 6/21/89 ltr item URIf4 Modifications & Troubleshooting 5 Lack of Detailed Work Procedures 2
6/21/89 Itr item URIf5 6 Lack of Maintenance History 2
6/21/89 ltr item URIf6 7 Lack of Technical Manual Review 2
6/21/89 Itr item URIf7
& Control 8 Lack of Welding Control 2
6/21/89 Itr item URIf8 9 No Procedures for Control of QC 2
6/21/89 ltr item URIf9 Activities 10 Use of Site-Wide Writer's Guide 3
6/21/89 ltr item URIfl0 11 Procedural Deficiencies Not Promptly 2
6/21/89 ltr item URIfil i
Resolved 12 Incorporation of Vendor Guidance 3
6/21/89 Itr item URIf12 into Surve111ances 13 Calibration of Permanently Installed 2
6/21/89 Itr item URIf13 Equipment 14 Configuration Control Problems 3
6/21/89 Itr item URIf14 i
A-1
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NRC STI CONCERNS Item.(s)
Category BG&E Response. Location i
1-3 Deleted 4
As-Built Drawings Accuracy 3
7/19/89 ltr item 5 5
Continuing Procedural 1
6/21/89 Itr concern 1 Non-Compliances 6
Failure to Properly Control M&TE 1
6/21/89 Itr in item URIf1 7-8 Deleted 9
Adequacy of Training (AOP-9) 2 6/21/89 Itr concern 2 10 Ineffective Corrective Actions /
2 6/21/89 Itr concern 3 Insufficient Response to Plant Problems 11 Qualification / Rotation of System 3
6/21/89 ltr concern 4 Engineers 12 Non-Safety Related Maintenance 3
7/19/89 Itr item 1 13 Post-Maintenance Testing 2
6/21/89 ltr concern 5 14 Control of Overtime Not Set 7/19/89 Itr item 2 15 Non-Intent Changes to Procedures 1
6/21/89 Itr concern 6 and in URI items 2 & 11 16 Control of Temporary Procedural 2
6/21/89 Itr in URI item 11 l
17 Quality of Log Entries 3
7/19/89 ltr item 3 18 Deleted 19 Lack of Identification of Material 3
7/19/89 ltr item 4 Deficiencies 20 Procedure Upgrade Program 2
6/21/89 Itr concern 7 Inadequacies 21 Project Management Manual 3
6/21/89 Itr concern 8 22 Overall Management Responsibility NRC-1 No Response Provided for Calvert Cliffs BG&E-3 23 Effectiveness of Communications of 2
6/21/89 ltr concern 10 1
Goals and Policies 24 Deleted 25 Procurement of Safety-Grade Parts 3
6/21/89 Itr concern 9 for Maintenance 26-29 Deleted 30 Equipment Status Log 1
6/21/89 Itr concern 11 31 Surveillance Test Program Controls 2
6/21/89 Itr concern 12 32 Lack of - Adequate Procedures 2
No Response Provided
- Systems of Programs
- Defined Work Priorities
- Performance Expectations
- QC A-2
ENCLOSURE B Non-URI STI Restart Concerns 5.
Continuing Procedural Non-Compliances (STI Response Concern 1)
STI Problem:
During the course of the STI, four instances of procedural noncompliance occurred which resulted in several operational events. These noncompliances continued occurring in spite of previous management directives to the plant staff regarding procedural adherence. The STI report stated that the lack of procedural compliance continues to be a problem and that increased attention was necessary.
Initial BG&E Position:
This concern is adequately addressed by the CAL.
Initial NRC. Position:
a Prior corrective actions have not been effective. Additional actions beyond those described in the CAL must be taken to ensure procedural adherence becomes the onsite standard of conduct. The CAL actions, which the NRC staff stated were insufficient, were to 1) continue to emphasize procedural adherence i
and 2) perform Human Performance Evaluations for all "significant" procedural violations.
Agreed Position:
BG&E did not take exception with the initial NRC position. Category 1.
STI Response:
BG8E stated that they will comply with the CAL by communicating "to employees our work priorities, the need to control work activities, and to adhere to procedures." In addition, they will determine and correct the root causes of recent noncompliances prior to unit startup.
Evaluation:
i Unclear whether BG&E intends to conduct additional broad-based corrective actions, as the NRC staff believes are appropriate, or only to address each procedural noncompliance as a discrete event. Correction of the root causes of the procedural noncompliance problem at Calvert Cliffs must be broad in scope and should be specifically discussed with the NRC staff before startup of i
either unit.
l B-1
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6.
Failure to Properly Control M&TE (Contained in STI URI #1 Response)
STI Problem:
The failure to properly control M&TE raised concerns that an indeterminate number of technical specification surveillance test results could be in doubt.
Consequently, the operability of the affected components on systems may have been questionable.
Agreed Position:
Category 1 STI. Response:
BG&E appears to have addressed this concern in its response to URI fl. This item was not individually addressed as a unique concern.
Evaluation:
The URI #1 response appears to be broad enough to alleviate this concern.
9.
Adequacy of Training (AOP-9) (STI Response Concern 2)
STI Problem:
The procedural walk through of remote shutdown was inadequate as it was not performed as a team.
l Agreed Position:
Category 2 STI. Response:
A0P-9 will be revised and training provided as necessary before restart.
Combined training will be considered for long-term corrective actions with team training provided at least once ever training cycle.
Evaluation:
.Though not specifically stated in the STI response, the licensing staff has subsequently said that team training shall be conducted prior to startup.
Consequently, the startup actions appear to be adequate.
B-2
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10.
Ineffective Corrective Actions / Insufficient Response to Plant Problems (STIResponseConcern3)
STI Problem:
The ifcensee has had a history of poor, superficial responses to plant problems with inadequate root cause analyses and a practice of implementing corrections for discrete deficiencies rather than for the widespread generic problems.
Agreed Position:
Category 2 STI Response:
The ifcensee provided correction actions only for discrete deficiencies identified in the nonconformance report (NCR) process. The overall corrective action program deficiencies were not to be addressed as a short-term item but rather, included in the PIP.
Evaluation:
The corrective actions to be taken in the short-term are not adequate to address the immediate concerns associated with an inadequate root cause analysis, safety assessment and corrective actions programs. The agreed response was to include the establishment of proper controls to establish an effective program.
- 13. Post-MaintenanceTestingIssues(STIResponseConcern5)
STI Problem:
Due to the process for developing PMTs, the operators were concerned that
. inadequate or improper PMTs could have been prescribed.
Agreed Position:
Category 2 STI. Response:
The licensee states that they have completed PMT revisions for the program to develop PMTs as part of the maintenance test.
Evaluation:
The licensee believes that it has developed a program to handle future PMT concerns. No statement / evaluations were made concerning the effects of the previous PMT process.
B-3
STI Problem:
The lack of a tracking system for non-intent changes to procedures could result in the failure to incorporate them in subsequent uses of the procedure or in procedural revisions.
Agreed. Position:
Category 1 STI. Response:
i No discrete response. Could be part of the URI fil response in which the licensee stated that " pen and ink" changes will also be made to the master copy when made in a procedure being utilized and that the master will be revised after very 5 changes.
Evaluation:
This STI concern was encompassed by the CAL item for procedure use and control of procedure changes. However, the BG8E STI response raises the question as to whether the addition of " pen and ink" changes to the master copy includes changes that are only temporary, in addition to permanent changes.
If so, confusion could result as temporary changes could continue to be used after the condition, for which they were made, has passed.
In addition, the proposed correction still does not provide a temporary procedure change tracking system.
- 16. Marked-up Copy & Control of Procedures with Temporary Changes Eva?uated as a Significant Weakness (Contained in STI URI fil Response)
STI Problem:
The lack of a control and tracking system for temporary changes could result in failure to include these changes in procedural revisions.
Agreed. Position:
Category 2 STI Response:
Same as for Item 15 above.
Evaluation:
Included in evaluation for Item 15 above.
B-4 1
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- 20. Procedure Upgrade Program Insufficient (STI Response Concern 7)
STI. Problem:
Management's action to resolve perceived shortcomings in the quality, control, and use of procedures was limited to guidance requiring compliance with procedures known to be inadequate and a hastily developed Procedure Upgrade Action Program that was deficient for the task at hand.
i Agreed Position:
Category 2 STI Response:
BG8E 1) has contracted with Operations Analysis, Inc. to provide a managerial overview of the project. This overview has been provided in a report and its enclosed recommendations shall be considered to enhance the program; 2) has contracted Arthur Anderson, Inc. to review the procedure preparation process with emphasis on computer applications; 3) will hire an assistant project manager with prior procedures upgrade experience; and 4) replaced the program manager. All other actions shall be part of the Performance Improvement Plan.
Evaluation:
It is unclear whether BG&E shall have a procedures upgrade control process in place prior to starting up or if they believe the hiring personnel to connence the work is an adequate short-tem corrective action. Further, clarification of the intended short-term corrective actions is needed.
- 22. Overall Management Responsibility for Calvert Cliffs STI Problem:
Unclear who has overall control of functions impacting Calvert Cliffs.
Agreed Position:
j Catetory 2 STI Response:
None Evaluation:
The licensee should still provide better insight to clarify how Calvert Cliffs is managed and who has overall responsibility.
B-5 I
i 23.
(Consolidated with 24,27,28,and29)EffectivenessofCommunicationsof Goals and Policies STI Problem:
Senior management goals and policies were not understood by or communicated to the plant staff, including plant safety perspectives.
(STI Response Concern 10)
Agreed Position:
Category 2 l
STI Response:
Prior to startup, BG8E shall itemize and prioritize near-term work on the PIP and for each unit's outage, including the development and implementation of a work schedule integrating PIP and startup items with outage and daily work i
activities.
4 In addition, 1) the 1989 Nuclear Program Plan was published, 2) the VP has met with employees to communicate his goals and expectations, 3) all employees 3
have attended meetings concerning the PIP and management expectations, and
- 4) Unit 2 outage work has been slowed to allow better control.
Evaluation:
Though BG&E says that they shall develoo an integrated schedule prior to startup, the plant is already significantly into the outage (5 months) without i
an integrated work schedule established.
If management waits until just prior to startup to promulgate its schedule, the message sent to the employees could be ineffectual.
With several instances of corporate restructuring taking place and a lack of clear understanding as to the schedule for work activities and unit startup, meetings on VP expectations and the PIP, and promulgation of a Nuclear Program l
Plan, will not effectively connunicate or convince the plant staff that stated goals and policies are actually real goals and policies.
- 30. Equipment Status Log (STI Response Concern 11)
STI Problem:
The licensee does not maintain a log of equipment that is out of service.
Agreed. Position:
Category 1 B-6
STI. Response:
The licensee shall develop an equipment-out-of-service list and instructions for controlling this list. This will be incorporated in the Nuclear Operations Shift Turnover Checklist. Training shall be provided prior to startup.
Evaluation:
)
l The response appears to be adequate to the concern.
- 31. Surveillance Test Program Controls (STI Response Concern 12)
STI Problem:
The surveillance test program at Calvert Cliffs is fragmented amongst several groups with poor controls and no "all encompassing" oversight.
Agreed Position:
Category 2 STI. Response:
An interim program shall be established with different functional test i
coordinators for operations, mechanical, fire protection, In Service Inspection and snubber areas. These coordinators shall be trained and the Calvert Cliffs Instruction for the surveillance program shall be revised.
In addition, upgrade of test procedures shall begin.
Evaluation:
This interim program does not appear to establish an overall controlling authority. The program is still fragmented and in fact, does not superficially appear to be much different from the previous surveillance test program.
- 32. Work force has been Accomplishing Plant Operations without:
Adequate Procedures Systems or Programs Defined Work Priorities Perfcrmance Expectations QC I
l B-7
STI Problem:
Self Explanatory Agreed Position:
Category 2 l
STI Response:
None Evaluation:
NRC should reevaluate if response is needed to this item. This could be considered the combined deficiencies that resulted in the CAL and the PIP.
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B-8
ENCLOSURE C Category 3 Items Corrected By Short-ters. Actions Unresolved Items None NRC STI Concerns
- 17. Quality of Log Entries l
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August 18,198s MEMORANDUM FOR: Robert A. Capra, Director DISTRIBUTION Project Directorate I-1 Docket file Division of Reactor Pr.-jects - I/II PDI-1 r/f AD/RI FROM:
Scott A. McNeil, Project Manager SMcNeil Project Directorate I-1 CVogan Division of Reactor Projects - I/II JWiggins
SUBJECT:
BG&E RESPONSE TO STI RESTART ITEMS On June 21, 1989, BG&E provided its response to additional concerns that arose as a result of the NRC Special Team Inspection (STI) at Calvert Cliffs. These concerns were specifically identified as needing a formal response during the NRC/BG8E June 9, 1989 entrance for the STI Follow-up Inspection.
The STI concerns requiring response were divided into three categories pertaining to the type of corrective actions that were necessitated.
Category 1 Item complete prior to restart Category 2 Program / Plan in place with short-term actions taken prior to restart and with appropriate long-term corrective actions Category 3 Others including additional Performance Improvement Plan (PIP) items.
Included were concerns derived from the body of the STI report in addition o the unresolved items (URIs) that were specifically identified.
In response to a request from Jim Wiggins, Chief of Reactor Projects Branch, Region I, I have examined the licensee's June 21, 1989 submittal to verify that the licensee responded to all non-URI, Category 1 and 2 STI concerns.-
The results of this examination and a cursory evaluation of the associated responses is provided in Enclosure B.
q In addition, the following information is also provided 1) a listing of all STI I
findings and concerns-(Enclosure A) and 2) a listing and cursory evaluation of Category 3 concerns that the licensee intends to correct with short-term actions only (Enclosure' C).
Please note that the primary purpose of this examination was to determine if the licensee had responded to the additional specified non-URI oncerns that resulted form the STI.
It was not conducted with the intent to parform an exhaustive or final evaluation of the adequacy of the 11censee's corrective actions for STI concerns.
i Scott A. McNeil, Project Manager i
Project Directorate I-1 Division of Reactor Projects - I/II
Enclosure:
As stated
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