ML20150C335
| ML20150C335 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/14/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8803180139 | |
| Download: ML20150C335 (4) | |
See also: IR 05000317/1986099
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MAR 141988
6
Docket Nos. 50-317/50-318
Baltimore Gas and Electric Company
ATTN: Mr. J. A. Tiernan
Vice President
Nuclear Energy
Post Office Box 1475
Baltimore, Maryland 21203
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report Numbers
50-317/86-99 and 50-318/86-99
This refers to the evaluation of the Calvert Cliffs Nuclear Power Plant oper-
ated by the Baltimore Gas and Electric Company conducted by the NRC staff on
October 16, 1987. This report was . forwarded to you on December 3,1987 and
discussed with you in a meeting held at the Calvert Cliffs Nuclear Power Plant
on December 14, 1987.
The list of attendees at the December 14 meeting is attached as Enclosure 1.
The NRC _ SALP Report is attached as Enclosure 2.
Our letter of December 3
(Enclosure 3) forwarded the SALP Report and solicited your comments within
thirty days of the December 14 meeting.
Your letter of January 13, 1988, in
response to the SALP Report is attached as Enclosure 4.
Your response of January 13, 1988, has been reviewed; it appears to address the
concerns expressed in our report and during the December 14 meeting.
No
changes to the SALP Report were deemed necessary based on discussions during
the management meeting or you written response.
Our overall assessment of activities at the Calvert Cliffs facility during the
assessment period indicated an adequate level of performance. Although several
significant program area strengths were noted, such as your trip reduction
efforts and the performance of your licensed and non-licensed staff, several
weaknesses were noted warranting continued corporate management attention.
These weaknesses included the timeliness and comprehensiveness of root cause
determinations, staffing shortages in the engineering and maintenance areas and
problems in the control of interfaces among the engineering, maintenance and
operations organizations.
Your presentations made at the December 14, 1987
management meeting and further described in your written response, indicate a
recognition of these weaknesses alona with a positive attitude toward improving
performance in these areas.
OFFICIAL RECORD COPY LIMROTH 136 3/2/88 - 0001.0.0
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8803180139 880314
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ADOCK 05000317
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MAR 141988
Baltimore Gas and Electric Company
2
We believe ' that our meeting and interchange of information was beneficial;
future meetings between Region I management and plant management to apprise us
of your progress and to discuss matters of mutual interest 'are encouraged.
No . reply to 'this letter is required.
Your actions in response to the NRC
SALP will be reviewed as part of the ongoing inspection program at Calvert-
Cliffs.
-Your cooperation is appreciated.
'
Sincerely,
Orfcinni Signed By
5:U. .?: ". LI ELL
William T. Russell
Regional Administrator
Enclosures:
1.
List of Attendees
.- 2 .
SALP Report Nos. 50-317/86-99 and 50-318/86-99
3.
NRC Letter to BG&E, dated December 3,1987
4.
BG&E Letter to NRC, dated January 13, 1988
cc w/encis:
i
M. Bowman, General Supervisor, Technical Services Engineering
T. Magette. Administrator, Nuclear Evaluations
Public Document Room (POR)
Local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Maryland'(2)
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
Commissioner Carr
Commissioner Rogers
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Baltimore' Gas and Electric Company-
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bec w/encis:
RegionI-DocketRoom(withconcurrences)'
J. Taylor, DED0
-J. Lieberman, OE
W. Russell, RA
J. Allan, DRA
W.- Johnston,'DRS
F. Congel, DRSS
D. Holody, ES
Management Meeting Attendees
DRP .'VISHLIST Coordinators (2)
M. Perkins, Management Assistant, DRMA (w/o encis)
L. Tripp, DRP Section Chief
0.=Limroth, DRP
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D. Trimble, RI -'Calvert Cliffs (w/ concurrences)
R. Bores, Technical Assistant, DRSS
S. McNeil, LPM, NRR
K. Abraham,-PA0 (14) (SALP Reports Only)
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ENCLOSURE 1
Attendees At SALP Management Meeting - December 14, 1987
1.
Baltimore Gas and Electric Company
G. V. McGowan, President
E. A. Crooke, President Elect
J. A. Tiernan, Vice President, Nuclear Energy
J. R. Lemons, Manager, Nuclear Operations
L. B. Russell, Manager, Nuclear Maintenance
W. J. Lippold, Manager, Nuclear Engineering Services
R. M. Douglass, Manager, Quality Assurance and Staff Services
R. P. Heibel, General Supervisor, Operations
P. T. Crinigan, General. Supervisor, Chemistry
L. A. Sundquist, General Supervisor, QC and Support
N. Millis, General Supervisor, Radiation Safety
R. L. Wenderlich, General Supervisor, Electrical and Controls
R. P. Sheran, General. Supervisor, Mechanical
M. E. Roberson, General Supervisor, QC and Support Services
A. R. Thorton, General Supervisor, Plant and Project Engineering
M. E. Bowman, General Supervisor, Technical Services Engineering
R. F. Ash, General Supervisor, Design Engineering
J. T. Carroll, General Supervisor, Quality Assurance
K. Nietmann, General Supervisor, Nuclear Training
2.
U. S. Nuclear Regulatory Commission
W. T. Russell, Regional Administrator, RI
W. F. Kane, Directo', Division of Reactor Projects (DRP), RI
R. D. Capra, Director, Project Directorate I-1, Office of Nuclear
Reactor Regulatiran (NRR)
J. T. Wiggins, Chief, Reactor Projects Branch No. 3, DRP, RI
L. E. Tripp, Chief, Reactor Projects Section No. 3A, DRP, RI
T. Foley, Senior Resident Inspector, Calvert Cliffs Nuclear Power Plant
S. D. McNeill, Project Manager, PD I-1, NRR
D. Trimble, Resident Inspector, Calvert Cliffs Nuclear Power Plant
3.
Others
T. Magnetta, State of Maryland
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ENCLOSURE 2
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT
J. 50-317/86-99; 50-318/86-99
BALTIMORE GAS AND ELECTRIC COMPANY
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CALVERT CLIFFS NUCLEAR POWER PLANT
ASSESSMENT PERIOD: May 1, 1986 - August 31, 1987
"T'77d OIh7
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TABLE OF CONTENTS
P, age
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I.
INTRODUCTION
1
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A.
Purpose and Overview . . . . . . . . . . . . . .
1
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- B.
SALP Board Members . . . . . . . . . . . . . . .
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- II. CRITERIA
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III. SUMMARY OF RESULTS. .-. . . . . . . . . . . . . . . .
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A.
Overall Summary
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B.
Background . . . . . . . . . . . . . . . . . . .
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C.
Facility Performance Analysis Summary. .
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D.
Unplanned Shutdowns, Plant Trips, and
Forced Outages.
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IV.
PERFORMANCE ANALYSIS
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A.
Plant Operations
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B.
Chemistry and Radiological Controls . . . . . . .
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Maintenance . . . . . . . . . . . . . . . . . . .
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D.
Surveillance
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E.
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F.
Security and Safeguards .
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G.
Refueling, Outage Management
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H.
Engineering Support .
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I.
Licensing Activities
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J.
Assurance of Quality
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K.
Training and Qualification Effectiveness. . . . .
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SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . .
58
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Investigations, Petitions and Allegations . . . .
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B.
Escalated Enforcement Actions . . . . . . . . . .
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C.
Management Conferences
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D.
Licensee Event Reports
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TABLE 1 - INSPECTION REPORT ACTIVITIES . . . . . . . . . .
T1-1
TABLE 2 - INSPECTION HOUR SUMMARY
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TABLE 3 - ENFORCEMENT ACTIVITY
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T3-1
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TABLE 4 - LICENSEE EVENT REPORTS . . . . . . . . . . . . ,
T4-1
TABLE 5 - SUMMARY OF LICENSING ACTIVITIES
T5-1
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I.
INTRODUCTION
A.
Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an inte-
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grated NRC staff effort to collect the available- observations and
data on a periodic basis and to evaluate licensee performance based
upon this information.
The SALP program is supplemental to normal
regulatory processes used to ensure compliance to NRC rules and
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regulations.
The -SALP program is intended to be sufficiently diag-
nostic to provide a rational basis for allocating NRC resources and
to provide meaningful guidance to. the licensee's management to pro-
mote quality and safety of plant operation.
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The NRC SALP Board, composed of the staff members listed below, met
on October 16, 1987 to review the collection of performance observa-
tions and data and to assess licensee performance in accordance with
guidance in NRC Manual Chapter 0516, "Systematic Assessment of
Licensee Pe rfo rmance" .
A summary of the guidance and evaluation
criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Calvert Cliffs Nuclear Power Plant for the period
May 1,1986 through August 31, 1987.
It is noted that the summary
findings and totals reflect a 16 month assessment period.
The SALP Board was comprised of the following:
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Chairman
W. F. Kane, Director, Division of Reactor Projects (DRP)
Members
T. T. Martin, Director, Division of Radiation Safety and Safeguards
(DRSS) (Part-Time)
W. V. Johnston, Acting Director, Division of Reactor Safety (DRS)
(Part-Time)
R. A. Capra, Acting Director, Project Directorate I-1, NRR
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S. J. Collins, Deputy Director, DRP (Part-Time)
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R. R. Bellamy, Chief, Emergency Preparedness and Radiological
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Protection Branch, DRSS (Part-Time)
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J. P. Durr, Acting Deputy Director, DRS (Part-Time)
J. H. Joyner, Chief, Nuclear Materials Safety and Safeguards
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Branch, DRSS (Part-Time)
L. E. Tripp, Chief, Reactor Projects Section (RPS) No. 3A, DRP
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T. Foley, Senior Resident Inspector, Calvert Cliffs Nuclear Power
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Plant
S. A. McNeill, Project Manager, Project Directorate I-1, NRR
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Other Attendees (non-voting)
D. C. Trimble, Resident Inspector, Calvert Cliffs NPP
D. F. Limroth, Project Engineer, RPS 3A, DRP (Part-Time)
A. B. Sidpara, Reactor Engineer, RPS 3A, DRP (Part-Time)
C. A. Carpenter, Reactor Engineer, RPS 3C, DRP (Part-Time)
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II. CRITERIA
Licensee performance is assessed in selected functional areas. Functional
areas normally represent areas significant to nuclear safety and the
environment.
One or more of the following evaluation criteria were used to assess each
area.
1.
Management involvement and control in assuring quality.
2.
Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
-5.
Operation events (including response to, analysis of, and corrective
actions for).
6.
Staffing (including management).
7.
Training and qualification effectiveness .
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories.
The definitions of
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these performance categories are:
Category 1:
Reduced NRC attention may be appropriate.
Licensee manage-
ment attention and involvement are aggressive and oriented toward nuclear
safety; licensee resources are ample and effectively used such that a high
level of performance with respect to operational safety is being achieved.
Category 2: NRC attention should be maintained at normal levels. Licen-
see management attention and involvement are evident and concerned with
nuclear safety; licensee resources are adequate and reasonably effective
so that satisfactory performance with respect to operational safety is
being achieved.
Category 3:
Both NRC and licensee atten+ ion should be increased. Licen-
see management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear
strafned or not effectively used such that minimally satisfactory perform-
ance with respect to operational safety is being achieved.
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The SALP Board may determine to include an appraisal of the performance
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trend of a functional area. Normally, this performance trend is only used
where both a definite trend of performance is discernible to the Board and
the Board believes that continuation of the trend may result in a change
of performance level.
Improving (declining) trend is defined as:
Licensee performance was determined to be improving (declining) near the
close of the assessment period.
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III. SUKVRY OF RESULTS
A.
Overall Summary
Our assessment of your performance during this assessment indicates
that three broad problem arc.n were evident; (1) management control
of interfaces between c'epartments (i.e., dissemination of engineering
requirements to the field, integration of syste.s engineers into the
plant staff, and functioning together as a team), (2) insufficient
resources in the maintenance and engineering departments hampering
their ability to support operations (slow resolution of recurrent
!
equipment problems), and (3) ineffective use of available tools to
recognize emerging plant problems (i.e. QA audits, lack of independ-
ence of oversight committees).
There were additional weaknesses in surveillance testing, communica-
tion of results to appropriate levels of management, and adequate
followup / resolution of indicators of potential epipment operability
problems. As a result, optimal equipment operability / reliability was
not always achieved.
Furthermore, post-maintenance and surveillance
testing appeared to be oriented toward demonstrating Technical Spec-
ification compliance rather than assuring equipment reliability.
Existing systems have achieved limited success in prioritizing main-
tenance activities and resolving long standing deficiencies.
The
failure to demonstrate timely decision making and protective action
recommendations in the emergency planning area indicated reduced
attention to this function. Housekeeping was obserYed to deteriorate
during outages, particularly in individual contaminated areas.
In
addition to being hindered by interface, coordination, communication,
and resourc-e problems, engineering appeared to be overloaded with
better direction and guidance needed regarding prioritization.
Notwithstanding the weaknesses discussed above, notable areas of
strength were observed.
These include (1) the Trip Reduction Task
Force and a Trip Evaluation Review Group that were instrumental in
helping prevent trips from recurrent causes and provided root cause
diagnosis of the cause(s) of feed pump trips, (2) performance of
licensed operators, (3) the in plant radiation protection program
which continued to achieve good control of exposures and a strong
ALARA effort, (4) the 10 year In-Service Inspection program which was
well managed and displayed good initiative in implementing state-
of-the-art techniques that often exceeded regulatory requirements,
(5) a loss of off-site power event which was handled well, (6) well
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coordinated and managed refueling and outage activities, (7) consoli-
dation and movement of engineering functions to the site, (8) the
technical ability, credibility and effectiveness of the QA department
by recent initiatives to add more technically oriented staff and to
use outside consultants to assess performance in complex areas, and
(9) well trained and highly motivated plant employees and first line
supervisors.
In summary, although significant areas of strength were noted, overall
performance slipped during this period.
Recognition and resolution
of deficiencies, including timeliness and comprehensiveness of root
cause analyses, continued to be a problem although some progress was
noted toward the end of the period. Improved interfaces between the
Engineering, Operations and Maintenance Departments to assure that
they work together effectively as a team is considered to be the
primary area for improvement.
B.
Background
1.
Licensee Activities
Unit 1
Unit I was at full reactor power (825 MWe) at the beginning of
the assessment period. From May 16 to May 19, 1986 the unit was
at reduced power (790 Kde) for installation of a new type of
traveling screen. On June 20, puwer was reduced to li; to permit
a containment entry to add oil to No. 12A reactor coolant pump
upper oil reservoir. The unit was returned to 100?; power oper-
ation on June 22, 1986.
On July 10, a ^
ge influx of jellyfish, crabs, ar.d marine life
caused shear pias on the travelling screen motors to shear thus
necessitating a power reductiori. This was followed by several
days where the bay oxygen concentration was below normal causing
increased marine life to accumulate at the intake structure. On
July 20, reactor coolant pump 128 tripped off, due to grounds
within a capacitor, also causing a plant trip. The unit was re-
turned to service the following day.
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On August 3, the licensee reduced power to perform a temperature
coefficient surve'llance.
During much of the month of August,
licensee personnel espent considerable time in preparation for
the upcoming ten year In-Service Inspection (ISI) and refueling
outage scheduled for October 25, 1986. On October 10 an oper-
o
ator mispositioneJ a condenser off gas discharge valva causing ay ['
loss of condendir . vacuum and. a turbine trip, resulting in a
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the restart from thi,s trip, the unit
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tripped again 'on~9rtng
October 11 from 15% power 'due to arial flux
offset.
The b lant was
returned to
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October 11, 1926 and continued routine operation.
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the unit was shut down to comence the p/
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On October 24,
0 year
In-Service Inspection and refueling outage.
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The licensee had requested and was granted an emergency Tech-
nical Specification change to allow refueling 'to be conducte:i
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without an operable diesel generator specifically assigned to
schedule.
Work activities proceeded in a systematic, harmon-
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that unit.
The unit continued the outage keeping close to
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ious, and steady manner.
However, final repair'o1 the No. 12
diesel generator (OG), repairs to the main generator collector
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and retaining ring and failure of the #118 reactor coolant pump
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shaft seal all contributed to delays (a few days each) in outage.
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recovery activities.
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On December 31, the unit was refueled and ready for startup
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activities while a taitirg resolution of the hydrogen seal and
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main generator beriing problems.
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Unit I was returned to power operation on 'Janbary 12, 1987. A
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manual trip occurred on January 27 following"a loss of instru-
ment air pressure due to an operator error in returning
he
instrument air >ystem to a ncrmal valve alignment at the con-
clusion of a system performance test.
Two condensate booster
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pumps were damaged during the event, which delayed unit start up
until January 31.
On February 1, Unit 1 was manually tripped
following a turbine run back due to low stator cooling liquid
pressure.
The' manual trip was in anticipation of an automatic
r
trip on high reactor coolant system pressure.
The unit was
returned to power on February 2.
On February 7, tthe unit was
removed from the grid to repai'e an oil leak on a turbine
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intercept valve.
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On March 10, the reactor coolant quench tank rup'ture disk rup-
tured due to a leaky pressurizer safety valve.
Tne unit was
subsequently shut down, the safety valves ' replaced and the
pressurizer- vent valves repaired. .The unit was returned to
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power operations on March 15.
During the week of March 23, NRC
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regional specialists reviewed environmental qualification (EQ)
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outstanding items and observed apparent inadequacies,in the pro-
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gram.
Routine operations continued until - April
1, when
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licensee identified additional EQ deficiencies and the unit was
shut down to correct discrepancies.
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On April 14, 1987, containment spray was inadvertently initiated
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due to operator error in performing a valve lineup,
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'On April 23, 1987, the licensee informed the NRC that certain
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replacement items (principally threaded fasteners) not fully
,
meeting AMSE code requirements bad been used in Class 1, 2, and
2-
4
3 systeks on both units.
Whih the non-conforming parts ap-
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peared to have been manufactured from ths' correct material, they
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did not meet. code requiremenil, with. respect to marking, certifi-
cation and, in sone cases, non-destructive examination. Resolu-
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tion of this issue coupled with the EQ problems forced Unit 1 to
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extend the shutdown.
On May 27, VAit 1 entered Mode 1 after completing surveillance,
Mechanical Commercial Quality and EQ post maintenance testing.
The unit paralleled- to the grid, escalated in power on May 28
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and remained at 10C% power throughout the remainder of the
period.
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Unit 2
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Unit 2 began the a.sjessment period at full rpctor power (825
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MWe). The unit was manually tripped on May 21, 1986 because of
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a loss of steam generator feed pumps (SGFP). \\"he cause of the
fh
loss of tne SGFPs was not determined.
On May 23, 1986 the unit
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was pa N ileled to the grid.
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On May 27, 1986, the unit was automatically Wipped due to loss
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of SGFPs. On May 28, 1986, the unit was paralleled to the grid
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and remained at 60% power (520 MWe) to test the 3GFP instrumen-
tation.
Testing of the SGFP instri. mentation remained in pre-
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grass from May 28, 1986 until June ?.
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On July 25, a decision was made/to shut down daa to a concern
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regarding increasing vibration ' trends on reactor coviar,t pump
'(RCP) #218. ' Before shut down commenced, a RCP #21A seal prass-
ure transmitter flex hose end fitting separated causing' 'a
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reactor coolant leak. An Unusual Event was d2clared as requirep
by the site Emergency Plan due to any forced shut down required
'f
by Technical Specifications. The plant remained shut down while
industry experts evaluated vibration trms from RCP #218 until
August I when the unit was rvstarted.
On September 5, the unit tripped due to a failed surge capacitor
on No. 21A Reactor Coolant Pump.
The unit . was returned to
operation on September 7.
Full power operation continued until
September 12 when operators manually tripped the plant due to a
loss of No. 21 SGFP and an impending low steam generator water
level.
The unit was returned to service on September 14;
however, power level was maintained at 60% (capacity of a single
feed pump) while the Trip Fvaluation and Review Group (TERG)
directed troubleshooting efforts on 21 $GFP control system. On
Septerber 18, the unit underwent a controlled shutdown antici-
pating the inability to neet a Technical Specification Limiting
Cordition for Coeration Action Statement due to an inoperable
emergency diesel generator. With NRC concurrence, the unit was
returned to 60% power until September 20 when repairs were com-
pleted.
Full power operations were resumed.
During September
considerable time 'was devoted to resolving problems associated
with No. 12 emergency diesel generator jacket water cooling
pressure oscillations, apparently caused by cart.on monoxide (CO)
"
leaking into the cooling system. Tnese , efforts extended from
September 10 through Octcber 7.
Unit
operated at full power until February 28,' when the unit
trippsd on low steam generator water level due to a level con-
trol system failure.
T hc. unit had been in operation for 169
consecuttyedays.
On March .13, the Unit shut down to commence its 10 year In-
Service, Inspection 'nd Refueling Outage.
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On July 3, the unit was paralleled to the grid ano tripped on
low steam pressure dud to an incorrect rheo < tat setting in the
turbine control circuit initial valve posfu on limiter.
The
unit returned to power operations.later that day 5ut was. limited
to reduced power operation due to turbine bearing vibration.
It
was brought to zero power and a balance shot was performed. on
July 8; therc rets gned to power or. July 9,1987.
J
.3
i
e,
,
f
. - - .
.-.
-.
-~
-
.-
.-.-L-
-- ,
].
A
.
_
~
,
so.
ayl
t
w
'
10
2.
Inspection Activities
-Two NRC resident inspectors were assigned during the inspection
period. The total NRC inspection effort for the period was 4018
hours (3013.5 annualized) with a distribution in the appraisal
functional areas as shown in Table 2 (Inq ection Hour Summary).
Table 1 lists every NRC inspection conduct.ed at Calvert . Cliffs
during this period.
During the period, NRC team inspections wee conducted of the
following areas:
a.
Actions taken relative to Gener.ic Letter 83-28 in the area
of Equipment Classification, Vendor Interface, Post Main-
tenance Testing, Surveillance and QA/QC overview (Inspec-
tion Report 317/86-10, 318/86-10.
b.
Emergency Preparedness Partial Scale Exercise and subse-
quent remedial drill (Inspection Report 317/80-14).
c.
Follow up of licensee actions relative to deficiencies pre-
viously identified regarding Post Accident Sampling capa-
bilities (Inspection Report 317/87-03).
d.
Follow up inspection of Environmental Qualification defic-
iencies, Post Maintenance Testing, use of Commercial Grade
Fasteners (Inspection Report 317/87-13 and 318/87-14).
Inspection Activities are summarized in Tables 1 and 2. Enforce-
meat activities are summarized in Table 3.
This report also discusses "Training and Qualification Effec-
1 -
tiveness" and "Assurance of Quality" as separate functional
areas.
Although these topics, in themselves, are assessed in
'
the other functional areas through their use as criteria, the
two areas provide a synopsis.
For example, quality assurance
ef fectiveness has been assessed on a day-to-day basis by resi-
dent inspectors and as an integral aspect of specialist inspec-
tion.
Although quality work is the responsibility of every
employee, one of the management tools to measure this effective-
ness is reliance on quality assurance insoections and audits.
Other major factors that influence quality, such as involvement
of first-line supervision, safety committees, and work atti-
tudes, are discussed in each area.
The topic of fire protection is not discussed as a separate
functional area because of insufficient inspection activity. The
available observations on fire protection and housekeeping are
included in the various relevant functional areas.
~
.
11
C.
Facility Performance Analysis Summary
Category
Category
Last Period
This Period
Functional Area
10/1/84-4/30/86 05/1/86-08/31/87
Trend
1.
Plant Operations
2
2
Improving
2.
Chemistry and
Radiological Controls
1
1
3.
Maintenance
2
2
4.
Surveillance
1
2
5.
Emergency
Preparedness
1
2
6.
Security and
Safeguards
1
1
7.
Refueling, Outage
Management
2
1
Declining
8.
Engineering Support
N/A
3
Improving
- 9.
Licensing Activities
1
2
10. Assurance of Quality
2
2
11. Training and
Qualification
2
2
Improving
Effectiveness
[
..
12
D.
' Unplanned Shutdowns,-Plant Trips, and Forced Outages
' UNIT 1
Functional
D,te & Power Level Description
Cause
Area
07/20/86 - 100%
Loss of flow and automatic
Long-standing
reactor trip; reactor
repetitive
coolant pump surge
design
capacitor failure
deficiency
Engr.
,
10/10/86 - 100%
Automatic turbine / reactor
trip; loss of condenser
vacuum due-to' auxiliary
operator mispositioning
an off gas discharge valve
Personnel error Ops.
10/11/86 - 15%
Inadequate
axial flux offset during
procedure and
start up
training
Ops.
01/27/87 - 100%
Manual reactor trip due to
imminent steam generator low
level caused by loss of
instrument air due to the
same auxiliary operator as
above mispositioning valves
-
during a restoration from a
performance test
Personnel error Ops.
02/01/87 - 70%
anticipation of high RCS
pressure following a turbine
run back caused by low
stator cooling liquid
Inadequate
pressure
procedure
Ops.
02/07/87
Unit was removed from the
grid to repair an oil leak
on the turbine intercept
valves
03/10/87 - 100%
Controlled shutdown due to
a blown RCS quench tank
!
rupture disc caused by leaky
code safety valves and
Component
insufficient spare parts
failure
Ops.
.
13
i
'
Functional
Date & Power Level Description
Cause
Area
04/01/87 - 100%
Controlled shutdown to
Implementation
correct environmental
of inadequate
qualification program
program
deficiencies
Engr.
07/14/87 - 20%
to high steam generator water
level resulting from a transient
on the 16A feedwater heater
combined with operator over
Personnel error /
boration
training
Ops.
07/23/87 - 100%
Total loss of offsite power
initiated by a ground fault
(tree near relay at offsite
transmission line) and overly
sensitive protection relay ~at
Calvert Cliffs
Other
N/A
l
-
_ _ _ _ _ - _ _ _ _ _ _
t-
.
14
-.
' UNIT 2
Functional
Date & Power Level Description
Cause
Area
05/21/86 - 100%
Manual' trip due to loss
of a steam generator feed
Grounds in FW
pump
control circuit
Maint.
~05/27/86 - 100%
Automatic trip due to loss
of a. steam generator feed
Grounds in FW
pump
control circuit
Maint.
'
07/25/86 - 100%
Controlled shutdown to
Random
repair RCP seal flex hose
component
. transmitter line
failure
Engr.
09/05/86 - 100%
Reactor coolant pump surge
capacitor failure
Design
Engr.
09/12/86 - 100%
Manual reactor trip due to
loss of a feed pump.and
impending low steam
Grounds in FW
generator water level
control circuit
Maint.
09/18/86
Unit underwent a controlled
shutdown anticipating the
inability to meet a TS LCO
Maint.
02/28/87 - 100%
low steam generator level
resulting from the failure
of ccntrol system component
Random
i.e., downcomer lead / lag
component
unit
failure
07/03/87 - 15%
low steam pressure due to
Inadequate
improper setting of the
vendor
turbine control circuitry
guidance
Maint.
07/08/87 - 60%
Controlled shutdown to
perform a turbine balance
Normal
shot
maintenance
Maint.
l
l
l
-.
.
____ _
.-.
. _ _ _ _ _ _ _ _ - _ _ _ _ _ _ ~
.
15
Functional
Date & Power Level
Description
Cause
Area
07/17/87 - 80%
Controlled shutdown to
repair vent and drain valves
leaking greater than T/S
Random
limit and correct turbine
component
vibration
failure
07/23/87 - 100%
Total loss of offsite power
(see Unit 1, same trip)
Other
N/A
.
. ..
.
.
..
..
.
_
16
. . '
IV. PERFORMANCE ANALYSIS-
A.
Plant Operations (40.9%)
1.
Analy si s -
The previous SALP determined the Operations area to be Category
2.
It concluded that management needed to be more aggressive in
pursuing recognition of safety issues and perform more thorough
and comprehensive root cause analysis of the issues.
During the beginning of this period, inadequate pursuit of
safety issues continued to be a problem as demonstrated by the
,
three successive reactor trips caused by multiple grounds in the
feedwater control system on May 21, May 27, and August 12, 1986.
The utility responded to the concerns identified in the previous
SALP by instituting a "Trip Evalu'ation Review Group" (TERG) and
a "Trip Reduction Task Force".
The feed pump trips were subse-
quently diagnosed by the TERG.
Throughout the period the TERG
Improved the root cause analysis of operational problems.
Previously,
slow to recognize potential safety issues, the
licensee aggressively pursued RCP subharmonic vibration prob-
lems, unknown elsewhere in the industry, and an Emergency Diesel
generator gassing problem.
In addition to pursing root cause analysis of reactor trips (see
Engineering section of this report), the licensee recognized the
relatively high number of reactor trips (14) during the last
period and instituted a Trip Reduction Task Force.
Recommenda-
tions of the task force appear to be well founded and compre-
hensive, however, many which have a high potential for reducing
reactor trips were slow to be implemented because of engineering
delays and/or resource constraints, i.e, instrument air upgrades
and
replacing RCP surge capacitors.
Those recommendations
requiring minimal time and resources have been implemented.
Much of the initial task force momentum now appears to have
weakened.
A significant portion of the 14 reactor trips which
occurred during this period would have been avertert had all the
recommendations been implemented at the start of this period
(i .e. , loss of instrument air, axial flux offset, steam genera-
tor feed pump trips and two RCP surge capacitor trips).
_ - _ _ - _ _ _ _ _ _ _ _ _ -
_ _ _ _ -
.
u
17
-
During the sixteen month period, five personnel errors occurred-
within -the. Operations area (see Table 4). No consistent trends
or management inadequacies were evident. Operations Department
shift personnel have undergone "team training" sessions on the
simulator and in the classroom to -improve the communications,
coordination and help better use synergism in the recognition.of
plant transients.
Two procedural
inadequacies resulted
in
,
reactor trips (see Table 4).
These were isolated instances and
not indicative of a general problem.
The large number of licensed operators (75 active licenses; 41
SR0's, 34 RO's) allows the Operations Department to utilize
experienced licensed individuals to rotate through a "Procedures
Development" group and a "Tagging Authority" group. Procedures
Development has been tasked with the improving procedures in
general.
Specific upgrades of each procedure which has the
potential for causing plant trips and improving the Emergency
~0perating Procedures (EOPs) were in progress.
Several other
significant
initiatives
have
been
implemented
to
develop
improved procedures.
In spite of the noted personnel and procedural errors, operators
have responded extremely well to plant events and transients.
On several occasions, operators prevented unnecessary plant
transients due to equipment failures (instrument air malfunc-
tions)
by
their
attentiveness
and quick
response,
i.e.,
July 1,1987, during a loss of No. 13 vital AC Instrument Bus
-
causing a loss of four reactor trip breakers and one channel of
ESF. Only by close adherence to procedure and maintaining com-
posure did operators determine the plant had not tripped. Dur-
I
ing the total loss of offsite power event, operators and the
Operations staff performed professionally, conservatively, and
demonstrated the culmination of knowledge by consolidating
emergency preparedness training, emergency operation procedure
training, knowledge of plant conditions and excellent use of
operating instructions in responding to a single event. Opera-
tors performed in a normal fashion; calm, deliberate, and per
procedures.
Notwithstanding the licensee responsiveness to the last SALP,
improvements in the effectiveness of the Plant Operations Safety
Review Committees manner of doing business may be warranted.
The "organization" might be more effective if (1) the prepond-
erance of the attending members were were not directly respon-
sible to the chairman; (2) the chairman was less aggressive ar.d
influential; (3) recommendations were made independently to the
plant manager; and (4) further use of subcommittees was evalu-
ated.
Further, a recent Quality Assurance Audit also noted this
lack of independence and potential for a slight bias towards
plant operation.
. .
.
..
________ - ___- -_ _____--_ _ _ _
.
18
Routine tours of the facility and discussions' with workers have
indicated a very favorable attitude towards plant management and
the . company.
Management was frequently involved. in onsite
activities, managers and the Vice President were usually in at-
tendance at outage meetings 'and most managers were routinely
seen touring the plant on housekeeping inspections.
Periodi-
cally, during outages, all work was stopped in order to stress
the importance of housekeeping.
Generally, housekeeping was
good, however, housekeeping areas within the contaminated, con-
trolled areas were sometimes poorly maintained.
Tools, hoses
and debris were found in some areas with boric acid crystals and
valve leakage.
The licensee continued to display a strong commitment toward
licensed operator training, evidenced by a high success rate in
NRC Reactor Operator (RO) and Senior Reactor Operator (SRO)
examinations. Written and operating examinations were adminis-
tered to four SR0s, all of whom passed, and six R0s, one = who
failed the simulator portion of the examination, and two who
failed the written and operating section. Subsequent'v, two R0s
were re-examined and found satisfactory.
During this period,
the simulator was first used for examinations and performed
well.
The training program appears to be strong overall with' some
minor weaknesses.
For example, the requalification training
program adequately covered the potential axial shape index prob-
lems during start up at the end of cycle with a large xenon
transient in progress, but operators had not practiced such a
start up on the simulator.
The Shift Engineer Pragram was also strong.
Degreed engineers
obtain SR0 licenses and are integrated into operational shifts.
The prospective shift engineers must qualify on all plant oper-
ator watch stations prior to the license class and serve as
control room supervisors and plant watch supervisors as well as
STAS.
The 75 licensed operators provide a considerable depth of talent
to allow for training, vacations, sickness, promotions, and
spare people on shift without unnecessary overtime. The opera-
tions staff is a solid stable work force with little turnover.
A new Assistant General Supervisor of Operations position has
also been allotted and filled.
Shift turnovers were thorough,
one-on-one walk throughs of the control panels with review of
administrative logs.
Shif t Supervisors and Control Room Opera-
tors routinely demonstrated a very conservative approach to
safety.
They are technically knowledgeable, professional, well
trained and provide an added level of assurance in safe opera-
tion.
They typically have good morale, attitudes, and an excel-
lent rapport with the facility staff
.
19
The operations group worked harmoniously with maintenance, HP,
and others throughout this period in 'the area of coordinating
maintenance and operations activities (see outage activities for
engineering. interface). They helped set maintenance priorities,
optimized scheduling, tagged equipment out of service 'at .the
proper . time, and ensured post maintenance testing was accom-
plished.
They improved their guidance on what specific post
operational tests were required for various types of mainten-
ance.
The licensee placed strong emphasis on planning. Improvement in
prior planning, setting priorities, and assignment of responsi-
bilities was evidenced in the establishment of pre-shif t brief-
ings to the oncoming watch section of non-licensed operators. A
recently established morning operations meeting between depart-
ment general supervisors, principal and system engineers and
planners now sets the day's priorities, discusses delays, coor-
dinates activities, and assigns responsibilities. A revised
"Plan of the Day" now includes maintenance, surveillance, and
other expected facility activities rather than a simple status
of each reactor.
The licensee's approach to the resolution of technical issues
from a safety standpoint generally exhibited conservatism and
was technically sound and thorough.
Reactor coolant pump shaft
and cover cracks, LPSI header relief valve weld cracks, and RCP
suction deflector ring failure demonstrated technically sound
resolutions.
However, occasionally during the period,
NRC
intervention was necessary to cause management to be aware of
deficiencies associated with surveillance testing or events
relating to the operability of safety-related equipment. Occas-
ionally, safety related equipment was initiated and failed to
operate.
If attempted a second time and it operated and passed
a Technical Specification surveillance test, the original fail-
ure was not always recorded or identified to management. Once
aware, appropriate reviews and action was taken (see Surveil-
lance section referencing additional details).
In summary, in spite of several visible events which drew atten-
tion to th? facility (EDG gassing, RCP shaft cracking, contain-
ment spray down), numerous program improvements were made. Many
were made in response to the last SALP, others in response to
the licensee's recognition of weaknesses.
The Plant Operations
Safety Review Committee has a potential to be biased towards
operations since the structure places the Chairman in a position
to
lose
objectivity.
Post-maintenance
operational
testing
requires improvements. A formal mechanism appeared to be lack-
ing which ensures that all failures are brought to the appro-
priate level of management attention in a timely fashion. Per-
formance of operating department personnel, especially licensed
operators, was excellent.
. - . . .
..
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ - .
. _ _
_ _______ -_.
_
_ _ _ _ _ .
_ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _
.
20
2.
Conclusion
Rating: 2
Trend:
Improving
3.
Board Recommendation
Licensee: None
NRC:
None
.
i
l
l
l
!
.
- -
21
,
B.
Chemistry and Radiological Controls (11. 6's)
1.
Analysis
The Radiological Controls Program was rated Category '1
last
assessment period. Significant concerns with management control
over the PASS system were noted which led to escalated enforce-
ment and issuance of a civil penalty although the root cause(s)
of this problem primarily reflected on performance in other
functional areas.
During this period, there were seven inspections by regional
specialists in the chemistry and radiation control areas and
routine coverage by the resident inspectors. The in plant radia-
tion protection program was effectively impiemented during both
operational and outage conditions.
The radiation protection organization, particularly in the ALARA
area, was well-defined and adequately staffed, with well-
qualified individuals.
An appropriate number of trained and
qualified contractor technicians were used to support the out-
age. The use of contractors to supplement radiation protection
staff.was well controlled.
The licensee continued to implement
an effective radiation worker training program. Both the radia-
tion protection ALARA and operations groups were aggressive in
assisting in the development of this program. Procedures in the
radiation protection area were well-defined and well-imple-
mented. A need for the proceduralization of certain non-routine
activities, such as the use of steam generator TLD phantoms or
operation of non- routine survey instruments was identified as
an area for improvement.
l
The licensee's external exposure controls program continued to
be effective and contributed to overall program strength. Infor-
,
maticn concerning radiological survey data and conditions was
readily available to workers signing into the work area. Daily
exposure tracking was well-controlled;
reports of accruing
l
exposure for each worker were reported to responsible super-
l
visors twice daily during outage conditions. The licensee ef-
fectively utilized their Special Work Permit (SWP) system to
establish radiological controls.
l
Two unrelated deficiencies occurred during this period in the
area of High Radiation Area controls. During one incident iden-
'
tified by the licensee, two individuals "jimmied" the locked
door to a High Radiation Area and entered rather than waiting
for the HP technician to arrive with the key. Subsequent inves-
tigation, prompted by an allegation, identified that a set of
1
l
.__
. _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ .
. - _
,
22
master keys to the station's locked -High Radiation Areas was
uncontrolled.
No examples of unauthorized use were identified
indicating a significant breakdown of controls in this area had
not occurred.
Licensee corrective actions were timely and
comprehensive.
An effective internal exposure controls program was in place.
The ifcensee aggressively utilized containments and portable
ventilation as methods of controlling airborne activity. Post-
ing of airborne areas and tracking of MPC hours were performed
at action levels more ccnservative than those required by regu-
lations.
Recurring problems were noted with the auxiliary
building drain system, which repeatedly backs up and causes con-
tamination of previously clean flour areas. This creates a sit-
uation that radiation protection personnel are forced to live
with and indicates that plant management needs tc be more
aggressive
in resolving the root causes of this problem.
Similarly, as discussed in the Operations functional area, more
attention needs to be focused on cleanup of individual contam-
inated areas.
The ALARA program continued to exhibit strong performance. ALARA
pre-outage involvement and planning was substantial; numerous
exposure / savings mechanisms (nock-up training, automated equip-
ment, closed circuit TV, temporary shielding) were utilized dur-
ing the outage. Actual exposure for 1986 for the two units was
347 person-rem vs. a projected goal of 390 person-rem. The 1987
-
goal was only 405 man rem, although considerable high rad work
was necessary.
Experience through the end of the SALP period
indicated that this goal was achievable.
This
experience
indicates an aggressive goal setting program was in place and
was used to improve ALARA performance.
The solid radwaste program was ef fective. An aggressive program
for volume reduction resulted in disposal of volumes approxi-
mately one half of those at comparable PWRs. The organizational
responsibilities for processing, preparation and shipping solid
radwaste materials were clearly -defined in procedures, well
l
understood by the responsible groups, and functioned smoothly
j
during the assessment period.
,
i
_ . _ . .
.
_ . , - _ - _ _
. - . .
. , , _ _
, _ . _ _ , ~ . _ _ _ _
_ _ _ . , , . _ . . . . ,
_ , - _ -
_
_
._. _ _ _ _ _ _ __ _ _ _
.
23
The presence of failed fuel pins presented a technical challenge
to the solid radwaste program which was recognized, adequately
analyzed and handled.
Properly constituted corrective actions
were taken to prevent regulatory problems; 10 CFR 61 scaling
factors were modified to reflect the new conditions.
A high
degree of quality control involvement in solid radwaste activ-
ities was effective in ensuring the waste classification, form,
and packaging requirements were being met.
The radioactive effluents control program exhibited positive
controls over radioactive releases and radwaste system operation
with well stated procedures to promote proper performance. When
the plant vent wide range gas monitor (WRGM) original calibra-
tion data was deemed insufficient, the licensee declared the
monitor inoperable, submitted an LER, and notified the NRC.
Management controls resulted in timely restoration; alternative
sampling techniques were used in the interim.
Routine surveillances of the radiation monitoring and air clean-
ing systems were found to meet frequency requirements in all
cases.
In the previous assessment period the licensee had
failed to take carbon samples at the required frequency.
This
suggests an increased level of management involvement.
Routine radiochemical analysis of reactor coolant parameters was
satisfactory.
In one instance identified by the licensee, a
surveillance was missed, due to sn inadequate shift turnover.
-
Managnment response and mitigation efforts were timely.
This
event was a singular occurrence and did not suggest a program-
matic breakdown of management controls.
During the assessment period, licensee management took aggress-
ive action to correct the inoperability of the PASS system iden-
tified in the previous assessment. The original PASS system was
taken out of service and the NSSS sample sink was modified to
meet NRC requirements.
The resolution of the PASS deficiencies
by modifying the NSSS sample sink demonstrated a clear under-
.
standing of issues by the licensee as wall as a technically
(
sound approach.
Furthermore, twelve items were reviewed during
a special NRC follow up inopection and eleven, including all the
'
violations, were closed, indicating timely and thorough resolu-
tion of issues.
i
l
l
l
l
!
. _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
_ _ _ _ _ _ _ _ - _
_
_ _ - _ . _ - _ -
_ _ _ _ _ _ _
__
. _ - _ _ _ _
.
24
}
The
licensee's
program
for. the
Radiological
Environmental
Monitoring program was found to be generally adequate.
Sampling
frequencies, type of measurements, analytical sensitivities, and.
reporting schedules generally complied with Technical- Specifica-
-tion . requirements.
A measurement quality ccntrol program was
implemented including participation'in the EPA Cross Check Pro-
gram. Measurement results'of the collected TLDs between the NRC
and the licensee were generally in agreement.
In summary, the in plant radiation protection program continued
to be effectively implemented during this assessment period. In
particular, good controls were in place and exercised, exposures
were tracked well .and maintained -low, . the ALARA program was
strong, and radioactive effluents and radwaste were minimized
with appropriate monitoring.
2.
Conclusion
Rating:
Category 1
Trend:
None-
3.
Board Recommendation
Licensee: None
,
NRC:
None.
-
.
-
C.
Maintenance- (13.9%)
1.
Analysis
The previous SALP rated the maintenance area as Category. 2.
Material . condition weaknesses required continued effort in-
several areas, but increased management attention and resources
were being devoted to these areas.
Additional . I&C engineering
support
was needed because of - weaknesses in the staffing,
direct line supervision, vendor support, and spare parts areas.
The . licensee was to evaluate the impact of secondary system
maintenance problems on reactor trips and determine if poor
maintenance
and/or design weaknesses were contributing to
,
balance of plant related trips.
During this period, regional specialists conducted six inspec-
tions of this area. Resident inspectors also routinely reviewed
this' area.
During this period, the I&C _ area significantly improved; a new
general supervisor aggressively pursued issues, assigned respon-
sibilities, and held personnel accountable. Systems were imple-
mented which trended and provided status of control room defici-
ency tags.
Some progress was made in reducing the number of
control room MRs. Problems identified last pe'riod regarding the
operability of main steam isolation valves were resolved by the
replacement of those valves; a major modification performed very
well.
As noted in the Operations area, operators, engineers,
and maintenance personnel attended factory acceptance testing
and worked with the vendor to develop operational test, opera-
ting and maintenance procedures.
Grounds on the Feed Water
Control System are also under control.
Several enhancements
took place (separation of power supplies and replacement of
numerous parts with state of the art controls). A task force to
improve the feed systems reliability generated several re com.--
mendations not yet fully implemented.
The licensee installed
two new and improved travelling screens at either end of the
intake structure, where most jelly fish accumulate.
Both communications and coordination between maintenance, oper-
ations, and engineering showed improvements.
General super-
visors visited other nuclear plants to obtain alternatives in
order to improve the recognized weaknesses in the MR system. A
"Perfect Planning" effort was effective in planning outage
activities (see the Outage activities section for datails).
-
-
-
-
- - . - - - . _
___ _ _ _ ____ _ _____ _ _
__j
,
26
Training of both electrical and mechanical personnel improved.
All maintenance' training programs are now' INPO accredited. All
maintenance personnel receive two weeks ' of general- training.
Although improved, the volume of out of service instruments af-
fecting the control room operators performance was excessive,
about 15 per unit.
Additionally, several instruments that do
not have MRs attached were inappropriate for operator use in
that the normal operating parameters were at the top or bottom
5% of the scale.
For example,100% steam flow is recorded at
the very top.
Similar problems exist with the surge line tem-
perature and pressurizer water temperature indicators.
These
examples of maintenance and design / engineering inadequacies had
the potential to adversely affect operator performance.
Other indications of inadequate maintenance impacting operations
was the safety injection tank in-leakage problem.
Operators
must keep No. 21 charging pump in pull to lock in order to pre-
vent dilution of the safety injection tanks (SIT) because of
back leakage through several valves inner-connecting the sys-
tems. Maintenance and testing efforts to date were ineffective.
Similarly, the Instrument Air System air dryers / regeneration
units repeatedly failed to transfer and caused a loss of instru-
ment air.
This problem has been tolerated for several years
causing either plant scrams or near misses.
Only af ter NRC
inspector prompting did the licensee effectuate some improve-
ments to alleviate the problem.
-
Service water pumps and auxiliary feed water pump packings con-
tinued to be a problem.
Maintenance spent considerable time
reworking these packings without significant success. Engineer-
ing efforts were in progress to improve these, however, this
problem has persisted reveral years. Other equipment seemingly
out of service for extended periods were:
the plant air com-
pressors, intake air coolers, and screen wash pumps. Resolution
was slow.
Programs and efforts to address such problems have not worked
very well for the following reasons:
(1) The Integrated Management System (IMS) has been implemented
which provides a systematic method for prioritizing plant
betterment and projects by development of benefit to cost
ratios. The IMS system appeared to hinder improvements in
several areas by excessively cancelling or delaying many
enhancements recommended by veteran supervisors, because
the benefit to cost ratio requirements were not met. Super-
visors appear to have insufficient involvement in the set-
ting of priorities.
This caused several long standing
deficiencies.
--
-
_.
_ _ _ _ _
.
27
(2) During the last three years the Integrated Corrective
Action Program (ICAP) was under developnent to assist in
tracking component failures and identifying rework. Manage-
ment has not tracked component failures or repetitive main--
tenance during this time because ICAP was imminent. Trend-
ing or evaluations of repetitive failures do not occur by
other than. supervisor recollection.
(3) Currently, no consolidation program exists which, during
the life of a component, reverifies vendor technical manual
design requirements or FSAR requirements. Nor is component
performance ascertained during post maintenance testing
(PMT).
Most often PMT only assures that the component
operates.
The above problems and numerous others identified by MRs were
situations which
hinders
plant
operations.
They
existed
-throughout the period and reflected the need for additionel
staffing and resources.
The
licensee focused on preventive maintenance (PM).
existed for both safety related and non-safety related compo-
nents.
PMs had high priority.
Procedures were general.ly good
and a feedback mechanism existed through engineering back to the
maintenance procedure group. However, PM frequency was based on
arbitrary judgment or coincided with Technical Specification
required surveillance frequencies. Often, routine PMs were per-
formed on components seldom operated since the previous PM,
i.e. , ESF components, yet many outstanding corrective mainten-
ance items were not corrected in a tinely manner.
PM results
were not trended or thoroughly evaluated ww.h could provide a
better basis- for frequency of performance.
A better use of
maintenance history or component failure trends would also pro-
vide an excellent tool for managing the limited maintenance
resources.
Another area recognized by the licensee as being deficient was
poor work practices apparently due to a lack of pride in owner-
ship. At times tools and work-related debris were found scat-
tered about after completion of maintenance.
Cleanliness and
housekeeping were at times also below standards.
Maintent.1ce
management attempted to increase craft "job satisf action" by
minimizing reassignment of people from jobs in progress to a
"more urgent job".
This previous practice caused a lack of
ownership of jobs and personal pride in performance.
Operations
I
_ _ _ _ _ _
.
28
personnel would lose confidence in maintenance personnel's abil-
i ty to stay with or adequately complete a job.
Recognizing
maintenance problems, operations personnel were sometimes reluc-
tant to submit MRs believing .they would not be adequately ad-
dressed.
By allowing the same people to start and finish a job,
more. pride and ownership is expected to occur and workers will
receive either positive or negative recognition for "their" job.
Progress has been made despite the above. problems.
Grounds on
the feed system, gassing problems on Emergency Diesel Genera-
tors, replacing two reactor coolant pump rotating assemblies,
back to back ten year In Service Inspection and refueling out-
ages followed by Environmental Qualification and Commercial
Quality issues placed severe stress on the entire plant staff.
Notwithstanding, since the licensee implemented its response to
the last SALP, there has been only one maintenance-related plant
trip compared to eight last period. The procedure to calibrate
the Turbine Generator Electro-Hydraulic Controller was deficient
in prescribing a new micrometer setpoint for a newly purchased
turbine simulator control davice resulting in a reactor trip.
Meetings are now held daily to coordinate maintenance, engineer-
ing, and operations.
Prioritizing MRs, troubleshooting, deter-
mining root causes, scheduling and tracking work activities dur-
ing operation has greatly improved towards the end of this
period, due to the coordination by this morning meeting.
Nuclear maintenance tracks maintenance-related reactor trips,
-
control room instrumentation out of service, valves repacked,
Mode 1 corrective maintenance working backlogs and Mode 1 cor-
rective maintenance orders older than three months. Maintenance
orders are further divided and trended by numbers due to numer-
ous causes for delay.
This trending / tracking system worked
well.
A recently established oil analysis and vibration trending pro-
gram was somewhat successful in predicting component failures.
Previously, problems had occurred with adding the wrong type of
oil to components.
The licensee recognized most of the above problems as well as
others. They established programs or placed these items on the
Key Items List with assigned responsibilities and priorities.
The programs are showing improvement. As an example, the 2000
valves repacked last year resulted in a reduction in dissolved
oxygen by a factor of 5 in Unit 2 condensate. An "Investigative
Planner" has been established to troubleshoot and correct minor
deficiencies within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the MR origination.
This
resulted in a 35% reduction in the MRs greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
old.
._
+
7
29
-
In summary, maintenance' faced a great work load and still demon-
strated slow improvements as compared to last period.
Manage-
ment programs effectiveness appeared constrained by limited man-
power and resources and engineering support. - Use of the IMS to-
prioritize resource use appeared to be ineffective in resolving
long standing deficiencies.
Lack of effective use of trending,
maintenance history and component failures reduces resource
efficiency. Some poor work practices continued to exist due to
lack of attention to detail and insufficient supervision. Post
maintenance testing requires improvement.
2.
Conclusion
Rating:
2
Trend:
None
3.
Board Recommendation
Licensee: Review adequacy of programs for prioritiz'ation.
NRC:
None
. - .
..
.
. .
.
. . ..
.
.
..
.
.
.
.
..
.
..
,
,
30
-
D.
-Surveillance (8.2%)
1.
Analysis
The previous SALP determined performance in this area . to be
Category 1.
Conservatism was noted in licensee policies for
entering and interpreting Technical Specification action state-
ments.
It- was concluded that the program was effectively
managed utilizing good procedures which were rarely violated. It
was noted that a significant problem existed with erosion of
steam piping and that a more aggressive corrective action pro-
gram was needed.
The resident inspectors examined surveillance activities as part
of the routine inspection program. Three inspections by region
based personnel examined activities associated with two plant
ten year In Service Inspections (ISI).
Surveillance activities
related to specific areas of inspection were reviewed during
several additional inspections conducted by NRR and region based
personnel.
The surveillance /ISI program continued to be effectively managed
with only one minor instance of a missed surveillance (radio-
chemical analyses) as discussed in Section IV.B.
Methods for
scheduling tests improved. In addition to the normal surveil-
lance testing /ISI workload, additional effort was required to
successfally complete two ten year in service inspections.
In-
-
creased effort and resources were dedicated to the secondary
piping corrosion / erosion inspection and replacement program.
There were ne, instances of low pressure steam line ruptures, as
had occurred previously, during this period.
As noted in previous SALP reports, workers performing tests and
inspections were knowledgeable of the systems and testing
requirements, and QC involvement was evident.
Licensee policies and procedures did not adequately address
intermittent equipment failures or significant degradations when
the equipment, without undergoing corrective maintenance, was
retested and functioned properly.
Those procedures permitted
such equipment to be declared operable without first requiring
either root cause determination and correction or, in cases
where the root cause cannot be immediately identified, thorough
evaluation of operability and need for compensatory actions.
They also were weak in requiring documentation of these failures
and degradations.
This allowed a problem with intermittent
. .
__
,
_ _ - _ - _ _ _ _ - _ _
__ _ _ _ _ _ - _ _
_ _ _ . _ _ _ _
__-
_
_ _ - - _. _ _ _ _ _ -
. _ _ _ _ _ _ _ - .
_ _ - _ _ .
..
~
31
tripping of the steam driven auxiliary feedwater pumps to per-
sist for an extended period without being recognized by plant
management and demonstrated that the surveillance program was
not being used as effectively as possible in identifying equip-
ment performance and reliability problems.
Such experiences
indiccte that equipment operability has been adversely affected
by inadequate recognition and communications of surveillance
problems as well as a lack of thoroughness in troubleshooting -
and root cause analysis.
POSRC review and plant management
actions on operability issues appear to have been more keyed
towards Technical Specification compliance than on reliability
and safety.
.
The following deficiencies were noted during the period. They
appeared to be unrelated in nature and not indicative of any
significant programmatic weaknesses. Problems were noted by the
NRC and the licensee's QA group with 1.nproper segregation and
storage of out-of-calibration measuring / test equipment.
Three
inadequacies of a more significant nature were .found by the
licensee and NRC in surveillance test procedures. One resulted
in long term inoperability of the wide range noble gas monitors,
the second in inadequate testing of a dynamic response circuit
in the Reactor Protective System, and the third in a failure to
periodically verify closure of certain containment penetrations
prior to movement of irradiated fuel.
As discussed in the Engineering Support functional area, the
licensee has become more proactive in identifying deficiencies.
Examples in the surveillance area of this overall trend in-
cluded:
system engineer discovery of two of the surveillance
test procedure deficiencies noted above, the conduct of a steam
generator tube inspection program that exceeded regulatory
requirements, and continued conduct of an aggressive secondary
piping inspection and replacement program. Another example of
particular note was licensee adaptation, as an industry first,
of current state of the art ultrasonic examination technology to
the field (UDRPS system) and successful use of this system dur-
ing two ten year In Service Inspections. The use of this system
enabled the licensee to conduct inspections which, in many
cases, exceeded regulatory requirements.
The In-Service Inspection (ISI) group and the metallurgical
engineering group which supports ISI activities have histor-
ically been staffed by very technically competent individuals.
This strength continued throughout this assessment period.
In
_ - - - _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
__
_ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
.-
.
32
addition to ISI activities, both groups provided valuable sup-
port to the plant in assessing emerging problems such as reactor-
coolant . pump shaft and cover cracking ind; cations. One area for
improvement the licensee was requested to consider, and which
may assist an already very capable ISI staff in achieving
superior performance, would be the addition of an- independent
Level III. Examiner to review all ISI data.
In summary,
the surveillance /ISI program was well managed.
Workers performing . tests and inspections were knowledgeable of
the systems and testing require.
'ts.
The ISI program was
carried out and supported by par:
Jlarly well -qualified per--
sonnel and went beyond regulatory equirements. However, licen-
see
policies and procedures do not adequately address inter-
mittent equipment failures or degradation. Also, the surveil-
lance program was not being used as effectively as possible to
identify equipment performance and reliability problems.
2.
C_onclusien
~
Rating:
2
Trend:
None
3.
Board Recommendation
Licensee:
Assess
overall
controls
(policies,
procedures,
-
reporting requirements, decision making, trending, and assign-
ments of responsibility)' for identifying and resolving inter-
mittent equipment failure problems.
An NRC/ Licensee meeting
should be scheduled to discuss the results of this assessment.
'NRC: None
__ ____
_ _ _ _ _ _ _ _ _ _ _
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -
..
'
33
E.
Emergency Preparedness (7.7%)
1.
Analysis
Licensee performance. in- this area was rated as Category 1 during
the
previous
assessment
period based upon
good exercise
performance and the licensee's own initiatives in emergency
preparedness.
During the current assessment period, there were three region-
based inspections of emergency preparedness activities which
included a routir e safety inspection, observation of the annual
exercise, and observation of a follow up remedial drill. Obser-
vations regarding implementation of the site emergency plan
during an approaching hurricane in August 1986 and during the
loss of offsite power event in July 1987 are included.
Emerg-
ency planning was also one of.the key areas examined during the
Operational Safety Review Team (0SART) review.
The licensee adequately addressed deficiencies in previous
exercise performance through appropriate program changes and
retraining.
Concerns remained in the areas of emergency notif-
ications and issuance of protective action recommendations (PAR)
for sheltering, evacuations, and authorization of potassium
iodine (KI) to personnel. During the partial
participation
exercise hela on September 9, 1986, NRC observed sweral signif-
icant weaknesses in the licensee's performance.
A recurring
ceficiency occurred relating to an inadequate decision making
process for pars.
The recommendations made to of fsite author-
ities were untimely and did not exhibit conservatism primarily
due to problems in overall direction and control of the accident
and dose assessment staffs.
Dose assessors were observed to
have difficulty in obtaining proper information for input into
the dose assessment model.
Additional inaccuracies were ob-
served in determination of source terms, release pathways, and
calculation of integrated offsite dose.
The lack of efficiency
'
in information flow between the radiological assessment staff
together with a complacent attitude displayed by key response
personnel were the contributing factors in inadequate and
untimely
recornmendations for protective measures.
Scenario
difficulties and inconsistencies may have contributed to this
delay.
E
e
.
- -
34
A Confirmatory Action Letter (CAL) was issued following the
exercise which outlined the major deficiencies.
The CAL re-
quested that the licensee take corrective measures by conducting
a review of the ineffective portions of the Emergency Plan and
Implementing Procedures and provide specialized training in weak
areas. On October 16, 1986, a remedial. drill was held to deter-
mine licensee responsiveness to initiatives in the areas of
protective action recommendations, dose assessment, and infor-
mation flow during emergencies.
Licensee performance in the
deficient areas was acceptable during the remedial drill. Acci-
dent assessment, notifications, communications, and protective
action recommendations were timely, but concerns remained about
the effectiveness of the de:e assessment program. The licensee
subsequently implemented changes to radiological
assessment
procedures and staff direction and control assignments for
evaluation and communication of dose projections. The licensee
emphasized the dose assessment area after the remedial drill
through specialized training and drills; improvements were shown
in subsequent drills.
The licensee had ample full-time onsite and corporate staff
assigned. Assistance was also provided by the Training Depart-
ment staff to integrate corrections of deficiencies in exercise
performance or programmatic areas into emergency response train-
ing. Emergency Response Facilities (ERF) were dedicated for
emergency preparedness and were adequately maintained.
The
overall capability of Emergency Operations Facility is excel-
lent. However, improvements could be made in the size and space
availability cf the Technical Support Center.
During an approaching hurricane in August 1986, the licensee
declared an Unusual Event.
Timely, conservative measures were
taken for hurricane preparation.
In July 1987, the plant
l
experienced a significant loss of offsite power event resulting
in the tripping (shut down) of both units, operation in natural
circulation core cooling conditions for an extended period
(approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />), and declaration of an "Alert" condition
in accordance with the site emergency plan.
During the event,
,
!
operations and plant staff personnel responded correctly and
l
properly implemented emergency operation procedures and the
Communications to the NRC were notably excel-
lent. This event demonstrated the effectiveness of the emerg-
ency plan as well as operations and emergency plan training
programs.
l
-
_
. , . ,
.
.
.
-.- - - - - -
_,
\\
,
.
,
(?
35
i
.<
'
' .
Il
s
.
1
t,
-
$
'
The licensee has ,eitablished a close working relationship with
off . site" of ficials and support groups.
Evidence cf a strong
commitraent to train and inform these groups as well as members
of 'the general public. regarding site activities is evident,
a
In summary, the level of staffing and training to administer
y
'(
basic emergency ' preparedness program functions appears adequate,
x A
however, performance of response persennel during the annual
{ I,'W
,
exercise was parginal . The poor performance appeared to be due
to a complacent attitude and inadequate management attention
-(
rather than a programmatic problem.
The licensee immediately
t.
7
recognized the weakness and performance has improved consid-
(
\\
I
erably since the, annual exercise. This improved perforreance was
demonstrated duriitg the recent loss of all offsite power event.
',1
"
,
,
,
2.
Conclusion
(
<
,
Rating:
Category 2
Trend:
None
.
a
1.
Board Recommendation
r.
,
Licensee: None
NRC:
None
a
\\
L
>
-
-s
8
T
l
J
nom .m.
s.
... . .. _
.y
[
. _-
.
.
.
.
_ .
.
.
.l_Q
r
.
,
,
y
'
<
f
<
36,
$
,
F' .
N:ority 'and / afeguards -('2!29) ,
^
y
.
1
'
1.
Analysis (
>
During the previous SALP - periot, tt e licensee's performance in
this area was Category 1.
W mjor regulatory issues were
-
identified.
,,
There was one physical security and one material control and
accounting inspection conducted by region-based inspectors dur-
,
ing this assessment period.
A mrnagement meeting, at the
request of the. licensee, was held tc discuss the circumstances
of a repetitive violation.
,;
1
.
Both plant and corporate security.tranagement: continue to be
!
aggressively involved in the securitj . program at Calvert Cliffs
-(
and sin nuclear power plant securi i,y , in general.
This was
3
demonstrated by the licensee's concinuing attention to program
L
i s
iy
improvements, e.g., providing a firearms range on owner control-
y
led property adjacent to the site to facilitate i;he maintenance
of firearm skills by members of the security force between
4-
s
requalification periods, the installation of two rhw explosive
'
detectors to facilitate searches at the main entry point to the
,
<
,
protected area, and training program initiatives that are dis-
cussed later in this assessment. Additionally, the licensee was
<-
actively following up on the concerns identified during the
Regulatory Effectiveness Review that was condt.cted in October
-
4
/
1985 by the NRC. Even those findings that were 'not NRC require-
ments were actively pursued by the licensee On an effort to
enhance and upgrade the security systems and we.'e included with
the licensee's previously planned security program upgrades that
'
began in 1982.
Security management also continued , to actively
/
p
interact with other utilities regarding securit9 matters, by
-4
membership in the Region I Nuclear Security Association and
other groups engaged in nuclear plant security matters.
-
' '
Security supervisors were well trained and continued to provide
effective supervision over security force membens who performed
<
'e
their assigned duties in a competent and professional manner.
Security force members were very knowledgeable" and actively
'
encouraged to participate in program implementation and enhance-
ments by making recommendations, particularly duri[.g critiques
after drills and exercises.
The licensee also rentred that
feedback was provided on all routine security duties.
These
0
initiatives were very effective in sustaining the high level of
morale exhibited by members of the security force.
\\
l
.
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _
_
N
,. L
';)
,
a
-
n
1
,.
,
Lt
t
- -
- 37
'
.4
(
5,#'
The l'icensee deve)cped and implImented a - specialized security
.
training' course fod members < of the site' quality assurance staff
-to enable th:Mf 6 lequipmentn 'tcMnduct a more effective aud1+ fof.l
nel' an Q c
performance.
'I additirdn,. the
- licensed gorittnued to maintain effective int 4rface and liaison
with 'lo%1. law enforcement and emergency services : agencies
through periodic meetings and on site drills and familiarization
tours.' Both of-these provided valuable-feedback to the training
program during thf s ass'essrpdt period and were further evidence
of the licensee's interest in implementing an e,ffective security
,
"
program.
During this assessment per od, a "opetitive violation occutted
~
J
involving the. control of vehicles while inside the protected
area.
The licensee requested a management meeting :to discuss
the- previous and additional proposed corrective actions.
The
licensee's corrective actions were extensive and adequate to
<
prevent recurrence. No similar problems were identified during
-the remainder of the assessment period.
The viol.ation identi-
fied in the matr,f al control and accounting area involved the-
licennee's faildre to maintain adequate records to demonstrate
j
i
that physical inventories of special nuclear meterial,s were con--
ducted int accordance with NRC regu'ations / TW7)censee took'
immediate and appropriate action tcr correct arfor ssion in.the
accounting procedure to prevelt recurre*ce. , N ither of the
violations were indicative of a programmatic prcb e% inUprompt
and effective corrective action Jundertaken was 'eddenM yof the
licensee's interest in implementing high ouality' secunty and(
effective safeguard programs,
/
)-
p
x><,
j
Five security event reports were submitted in accordancejwith.
the requirements cf 10 CFR 73.71.
Three reports were r6 quired
,
4
as a rqsult of a recurrent hardware ;>re;bler with th() security
'
computer early in 'the assessment periodf<That problem was pur-
fourth,y the venefor and no recurrence has 'been experienced.
sued b
A
treport, involving the computer,, resulted from an error
madn by a. rraintenance tech ician.
%e fifth >repory <resulted
when a fde bomb-like objeqd was foudd in a building inside the
plant protected area. The 'five events were pro;:orly responded
l
to by the security forcuand appropriate compensatory measures
!
were implecented in each case.
The flicensee's Security Con-
l
i.ingency Pian (SCP), as interpreted by NRC, committed to report-
ing of events, such ar ; the 'three cdmputer related hardware
events, to the TMC
but two such previous events had not been
reported when 'M, occurred.
However, NRC regulations do not
require reportd of such events.
The li';ensee corrected some
ambiguous language / n the SCP that caused the confusion in the
i
reporting commitments.
Each report was clear an# concise and
provided an adequate explanation df the event to enable NRC
analysis.
This demonstrated ptop u management oversight and
l
review of events and reports submitted to NRC.
l
f
'+
,
- ,
,
L-
_
.s
,-.
.
,
..
~_
_
.
- , . _
.
,
.I
p
.
,
'
38
-
l
During the assessment period, the licensee submitted three
revisions to the security plan and a revision to the SCP under
the provisions of 10 CFR ' 50.54(p).
Some minor l modifications
were necessary to several changes but only two changes required
additional information.
Plan changes were of high quality' and
demonstrated management's continuing oversight of the program to
ensure it was consistent with NRC performance objectives.
Per-
sonnel-involved in maintaining plans current and consistent with
NRC objectives were very knowledgeable of NRC requirements.
During the assessment period enhancements of the personnel
screening program were made' by implementation of the Nuclear
Employee Data System.
In summary, the licensee continued to maintain an effective
physical security and safeguards program.
Efforts to improve
and upgrade.-the operation and reliability of system and equip-
j
ment and the performance of personnel were continuing.
2.
Conclusion
Rating:
Category 1
Trend:
None
3.
Board Recommendation
.
Mcensee: None
N
None
E:
i
-
-
- ,_ _ _ _ , . - . _ _
- . , . _ , _ - _ _
.
~
39
G.
Refueling, Outage Management (6.7%)
1.
Analysis
The previous SALP included Engineering Support within this area
and
rated this area as Category 2.
Routine activities were
well planned and coordinated.
Strong management influence in
decision making was evident. Good communications and orchestra-
tion of activities were demonstrated resulting in meeting of
scheduies and minimizing man rem exposure.
Two areas, post
accident sampling, and environmental qualification of equipment
lacked sufficient management attention and required NRC invcive-
ment to identify deficiencies.
.
There were two ten year In Service Inspections and refuelings
conducted during this evaluation period. Outage activities mon ~-
itored
included:
pre-outage
planning meetings,
responsible
engineer presentations on Facility Change Requests (FCRs) and
major modifications, morning coordination / status meetings, steam
generator eddy current testing, reactor vessel level instrumen-
tation modifications, refuelings, in service inspection of the
reactor vessel, replacement of reactor coolant pump rotating
assembly, replacement of main steam isolation valves, numerous
other refueling activities,
i.e., leak rate testing, nozzle dams
work, hydrostatic tests, and human factors improvements made in
the control room.
.
Refuelings typically were characterized by good communications,
excellent planning, good control over contractor personnel, and
a strong management involvement.
Engineering's onsite presence demonstrated a notable strength
by providing responsible engineers to brief general supervisors
and principal engineers at pre-outage meetings on all the sched-
uling, support coordination, responsibilities, potential problem
areas, and details of the more complex evolutions planned to
occur during the outage. This process called "Perfect Planning"
brought together all facets of job planning including ALARA
engineering, mock up training, procedures and spare part status,
and ensured all involved personnel were aware of their assigned
responsibilities.
This planning technique was used primarily
for critical path high impact items and jobs that have never
d
been performed before, jobs with significant potential man rem
l
exposure, or with interfaces between many groups. This technique
impro ed the efficiency and reduced exposure for M5!V replace-
ment, core exit thermocouple modifications and RCP rotating
,
1
l
.
.
_
-
'
.
. -
40
,
assembly replacement.
The outage coordination meetings - held
daily tracked critical paths for primary work, secondary work,
refueling and other major job efforts, ensuring delays for any
reason were minimized and necessary support was provided. These
meetings ' facilitated strict adherence to the schedule 'of activ-
ities. Good communications existed between departments and con-
tractors.
Site management were regularl
in attendance.
The
morning meeting and specific technical meetings thereafter were
succinct and effective.
The outage management section, a divisioa of the Operations
Department, utilized senior reactor operators as operations /
maintenance coordinators to facilitate the availability of
equipment, to ensure operations was aware of ongoing maintenance
and to expedite the isolation of equipment though the tagging
authority.
Another good initiative was the use of shift and
area coordinators /facilitators who facilitated material, coor-
dinated and assigned priority to jobs within an area when con-
flicts arose,
i.e., containment coordinator.
4
Outage meetings were periodically supplemented with "pep talks"
from the Vice President stressing quality work, safety first and
doing the job right the first time. Management conveyed clearly
that plant operation was second to safety and quality work.
Beyond a normal refueling, the two refueling outages involved
the following:
two In Service Inspections of reactor vessel
-
components; a problem with #12 Emergency Diesel Generator gas-
sing; main generator collector ring cracks; failure of #118
reactor coolant pump seal after replacing all of the other RCP
seals; replacement of two reactor coolant pump rotating assem-
blies; replacement of about 2,000 feet of secondary steam piping
and repacking about 2,000 valves with a constant load Chesterton
packings; replacement of the MSIVs on each unit; and installa-
tion of a new plant computer.
These were accomplished with a
site person rem exposure of less than the tight goals despite
additional required work and no individual receiving more than 2
rem thereby exhibiting good planning and control.
During these
events, numerous technical problems faced the licensee. Each in
time was reselved in a technically sound and thorough manner.
Despite the problems experienced beyond a normal refueling, both
the refueling and ISI portions were successfully completed. The
added complications, generator collector ring cracking, environ-
mental qualification and mechanical commercial quality issues
extended each outage, however these did not appear to influence
.
the licensee's well coordinated persistent pace.
Personnel
i
attitudes and morale remained high despite the setbacks.
,
.
,.~,
-,--4
- , . , . . .
.
.,-.-,._._..y...
- , , _ _ _ , - , ,
._.-.--_,,,..---~%
.
-
_ _ _ _ _ _ _
.
-
41
Some problems, however, appeared to be persistent. Upon return-
ing to power operations, an excessive number of maintenance
requests remained outstanding. Some of this was attributable to
the marginal post maintenance test program and the limited
resuurces in wintenance.
However, another contributing factor
was the licensee's tolerance to live with out of service or
deficient equipment upon return to power operation (see also
maintenance functional area).
Another area of concern was the amount of debris in the reactor
coolant system. During tha current fuel cycle, coolant activity
on Unit 2 has been relatively high, 5 micro curies per cubic
centimeter gross activity and 0.3 micco curies per cubic centi-
meter dose equivalent Iodine 131.
This appears to be caused by
debris within the RCS causing fuel pin failures.
The failure
mechanism appears to be debris-related fretting, indicating that
material control practices during outages while systems were
open were weak.
Clean area controls during refueling were
strictly adhered too around the reactor vessel .
However, the
controls was not so strict around other arear where the primary
system was cpen.
The licensee first cle,rly recognized this
problem af ter examining the fuel during this outage.
As an
initial corrective action step the licensee stressed cleanliness
controls in the Calvert Cliffs News Letter to heighten employees
sensitivity to the issue.
Further procedural controls are
planned for future outages.
Similarly, overall housekeeping
significantly declined during the outages, particularly in some
-
contaminated areas as discussed in previous functional areas.
In summary, outages and refuelings were well managed.
Opera-
tions personnel and other outage coordinators /facilitators were
effective in achieving good coordination of activities including
unexpected problems encounters. . ate in the refueling outages.
In
particular,
planned maintenance,
in-service inspeccions,
nodifications and major outage usks were effectively scheduled,
nordinated and managed. Despite the good overall management of
outages, problems were noted near the end of the period as
housekeeping in contaminated areas dt.+.erioratea and the plants
were returned to service with an eacessive number of maintenance
requests outstanding and equipment out-of-service.
2.
Conclusion
Rating:
Category 1
Trend:
Declining
3.
Board Recommendation
Licensee:
Set goals for minimizing out of service equipment
before returning to power operations.
NRC:
None
___
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ - . - - - _ _ _ _ _ _ _ _ _ _
_ _ . _ _ _ _ _ _ _ _ _
______________J
.
42
.*-
H.
Engineering Support ( 6.8*4)
1.
Analysi s
Although this area was not rated separately in the previous
SALP, problems were . identified with (1) a lack of management
attention in the establishment of a viable Equipment Qualifica-
tion (EQ) program and (2) inadequate orchestration of multi-
disciplined tasks in that responsibility and authority were not
vested in individuals in such a manner to ensure effective task
completion. This area was covered as a part of several individ-
ual and team inspections during this assessment period. Further.
evidence of the above concerns was seen during this assessment
period.
Specifically, they were the root causes of significant
deficiencies identified in the EQ program.
Those deficiencies
primarily involved the use of unqualified taped electrical
splices. -The second problem continued to exist in that the
roles and responsibilities of systems engineers (individuals who
are key coordinators in assuring proper maintena.nce, perform-
ance, and design improvement of plant systems) were found to be
p6orly addressed in plant procedures and appeared to be too
broad, thus reducing the effectiveness of this function.
Related to the above problems, communications, both formal and
informal, between engineering and other plant groups were weak.
For example, important mechanisms for communicating engineering
requirements to the field were unclear.
Similarly, the engi-
neering personnel were not made aware of the fact that the set-
points for certain Reactor Protection System (RPS) constants
were net being adjusted to values recommended by the NSSS vendor
following core reloads. The licensee has experienced difficulty
in getting engineers out of their office area and into the plant
and communicating with operational and maintenance personnel to
more fully realize the benefits of the relocation of all engi-
neering functions to the site.
The EQ issue pointed out a failure of engineering department and
plant management to give credence to and heed the advan::e warn-
ings of both the QA grtup ar.d the NRC of program weaknesses.
It
also pointed cut a need for management to more frequently
utilize third party expertise to provide assessments of the ade-
quacy of more specialized or technically complex programs.
1
_ . _ _
..
.
. _ _ _ _ _
__ _
_
__
._.
. _- .-_ _
.
-43
~
During. this period, the licensee pursued an emergency diesel
generator gassing problen which was originally thought to be
only slightly excessive. As the licensee pursued the problem,
it became worse and more complicated durir.g repair attempts
requiring several changes to the Technical Specifications.
The
licensee was candid and responsive to. NRC concerns which facil-
itated an acceptable and timely resolution, however, communica-
tion with- NRC on the issues exhibited a lack of coordination
between engineering and operations.
'
,
During the assessment period, a great deal of licensee manage-
,
ment and NRC attention was focused on the engineering depart-
'
ment.-
Licensee managers now recognize that tho engineering
function was operating unc'er resource' constraints that, at least
in part, prevented (1) the timely close out of Facility Change-
.
Requests for which - physical work has been completed (approxi-
!
mately 400 changes outstanding near the end of the SALP period),
(2) better root cause analysis - of plant maintenance problems,
(3) timely engineering of facility modifications, and (4) needed
improvements in engineering tools
(e.g.,
improved means for
determining and maintaining design basis information).
Resource
constraints additionally s1 wed the development of a performance
based training program fo. the engineers.
The fact that the
general experience level of the systems engineers was low added
'
emphasis to the need for such a training program. Additionally,
.
-the engineering department iad internal and/or external commit-
l
ments to complete final corr ?ctive actions for the EQ and MCQ
-
issues, complete upgrades in the 0-list, and to develop master
'
calibration
data
sneets
in
supprt
of
nmintenance
activities.
While pe rforman: e in the engineering support area
was hindered by work overloae, it also suffered from inefficient
,
control
cod
t. s e of exist'.1g resources due to insufficient
prioritization c.r.d poor coor dinstion.
Immediately prior to and Juting the assessment period, all
.
engineering support functions for the plant, with the exception
of the metallurgical engineer cg group, were moved to the site
and consclidated under one t ,:: ear Engineering Services Depart-
ment.
At the same time, ite systems engineer function was
implemented.
The consolidat'v, coupled with two 10 year ISI
and refueling outages and several plant problems as discussed
previously placed considerable stress on the engineering organ-
ization.
In spite of this and extending beyond response to
i
crisis situations, there were notable accomplishments which
benefitted the plant and which indicate strong potential for the
'
engineering
group,
with
proper
development,
to
further
contribute to the overall improvement of plant operation and
maintenance.
- , . - _ . -
_ _ _
_
.
4
44
l
(1) The Engineering Department directed the efforts of the
"Trip Evaluation Review Group (TERG)".
As noted in the
operations section,
this group successfully identified
-problems' in the feedwater _ control systerr.
Two reactor
trips were caused by failures of reactor coolant pump (RCP)
capacitors. Engineering performed testing to determine if
tne capacitors could be replaced with an-alternative.
Cur-'
rently, a modification is in progress to replace the
capacitors with inductors.
There have been no repetitive
r2 actor trips due to the same cause or unidentified root-
cause since TERG establishment except for the RCP-capacitor
failures.
(2) The organization has become more proactive in identifying
deficiencies.
For example, engineering personnel identi-
fied the MCQ fastener and the RPS set point problems, and
they discovered a significant error in vendor guidance for
calibration of the wide range noble gas monitors. This was
partially due to systems engineers being available to pro-
vide focused attention on assigned systems.
(3) The engineering group provided two useful tools for pre-
dictive maintenance through development of the oil analysis
program and enhancements in the equipment vibration mon-
itoring and analysis program.
(4) The engineering departrent's ISI group and the metallur-
gical laboratory group took state of the art ultrasonic
examination technology and, as an industry first, adopted
it to the field (UDRPS system). This system was then very
successfully used during two 10 year ISI inspections. Also,
for the first time, a zero channel head entry device
(SM-10) was used on a CE designed plant for steam generator
tube eddy current inspection which resulted in an estimated
10 man rem exposure reduction per unit. The ISI group and
the metallurgical laboratory group have historically been
staffed by very technically competent individuals.
These
individuals also provided valuable support to the plant in
analyzing reactor coolant pump shaft and cover cracking
problems.
(5) The licensee's secondary piping inspection / replacement pro-
gram continued to receive high priority.
(6) Upon the initiative of the QA group, immediately following
the SALP period the licensee performed a proactive, in-
house inspection similar to the NRC Safety System Func-
tional Inspection (SSFI) to examine engineering configura-
tion controls. A contractor familiar with SSFI techniques
assisted them in this effort.
.__
.-
'
.
..
~
45
(7)' 500 safety-related loop drawings were- developed to better
support
Electrical
& Controls maintenance activities.
(8) Although progress was slow,_some of the long-standing tech-
nical problems have been resolved 'or appear to _be on the
path to resolution. Examples include: replacement'of high
maintenance requirement main steam line isolation valves
with components of superior design, improved packing. per-
formance for the charging pumps, improved reactor coolant
pump seal rebuild capability, intake structure traveling
screen / screen wash system improvements, and updating of
Unit 2 main feedwater controls.
In summa ry , the consolidation and movement -of all engineering
functions to the site and the implementation of the systems
engineer concept were positive steps toward improving engineer-
ing support of the plant.
Problems still existed with:
(1)
full integration of the Nuclear Engineering Services Department
into the plant staff which includes improved communications as
well as systems engineer training and involvement with opera-
tions/ maintenance personnel to improve engineer credibility and
effectiveness; (2) assessment and, where needed, redefinition of
the roles / responsibilities of systems engineers; (3) for multi-
discipline tasks, lack of clear assignment of responsibility;
(4) providing the necessary resources ~to complete corrective
'
actions for past problems (e.g., EQ, MCQ, FCR backlog) and to
providing better maintenance support and to resolve long stand-
-
ing technical problems; and (5) ensuring appropriate management
attention is given to identified deficiencies (e.g., QA findings
and recommendations).
Several corrective actions have been
initiated (e.g. , team training for managers, daily operations /
maintenance / engineering meetings).
Accomplishment of such a
large agenda of improvement efforts will require dedicated and
skillful management attention.
During the latter part of the
assessment period, areas of improvement were noted.
These
included system engineer identification of problems,
self-
identification and correction of MCQ problems, the SSFI initia-
tive to evaluate engineering configuration controls and improved
engineering support for the licensing functional ereas.
2.
Conclusion
Rating:
Category 3
Trend:
Improving
.
-
46
3.
Board Recommendation
Licensee:
Perform independent assessment of the engineering
organization which identifies engineering functions and includes
a review of the overall system for establishing priorities,
assigning responsibilities, and obtaining resources.
NRC:
None
.
!
[
l
l
I
l
1
l
l
l
l
_ _ _ _
.
47
-
I.
Licensing Activities
(1.9%)
1.
Analysis
This licensee was rated Category 1 in this functional area for
the previous SALP evaluation period. Management involvement and
control of licensing activities, as well as licensee responsive-
ness to NRC initiatives were viewed as strengths because the
licensee assisted in resolving several NRC initiatives and its
submittals were of high quality with noted improvement in the no
significant hazards analysis provided in support of Technical
Specification (TS) amendment requests. Weakness was noted only
in the communications between the operations and licensing
staffs concerning the reliability of equipment controlled by TS.
During the current SALP evaluation period, a number of signifi-
cant occurrences had a decided impact upon the evaluation of the
licensee in this functional area.
These occurrences included
(1) the degrdation of the #12 emergency diesel generator (EDG)
which necessitated one exigent and two emergency TS amendment
requests, (2) the licensee's shift to a 24-month operating cycle
which necessitated submittal and review of a wide range of TS
4.mendment requests, and (3) the licensee's discovery of environ-
mental qualification deficiencies and of the improper use of
uncertified material replacement parts.
Licensing activiths
are summarized in Table 5.
.
In responding to .1ese occurrences and to other issues and
even'.s over the course of the SALP ra+ing period, the licensee
demonstrated generally good management overview with respect to
licensing
activities.
The
senior
engineering
management
actively participated in these actions by orioritizing these
actions with the concurrence of the Manager of Nuclear Opera-
tions. Assignment of priority was based upon the impact on cur-
rent or future planned plant operations and upon the licensee's
evaluati;n of the safety significance of the item.
Generally, the licensee responded to the NRC ii a timely manner,
particularly, with regard to requests for additional information
made to obtain technical support for licensee requested activ-
ities. Licensee responses to NRC initiated issues were normally
thorough and of high technical quality.
Response was not as
prompt to NRC issues of generic concern.
Due to a staffing
shortage, the licensing activities prioritization scheme adver-
sely impacted the timeliness of NRC requested and required
licensing activities which the licensee of ten viewed as a lower
priority.
As a result, senior management diverted manpower
_ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_.
_ _ _ _ _ _ - -
_ _ _ _ _ .
____ ____ ___ ______ __- _ __
-
..
,
-
48
resources away from these NRC initiated activities 'to those
deemed to be more in the interest of the utility. The licensee
requested extensions for responding to several NRC generic
letters and deferred action on SPOS
opera'ility,
Dedicated
o
Control Room Design Review and the annual FSAR update.
Senior management attention towards NRC . licensing requirements
during this rating period was found to be inconsistent with
regards to ensuring licensee compliance with the various report-
ing requirements.
Several required reports were filed late and
'
some annually required reports (e.g., challenges to and failures
of the pressurizer PORV's and code safety valves) had not been
filed for several years. No licensee unit was tasked with the
responsibility for or the authority to ensure that these reports
were submitted as required.
The licensee possesses significant technical capabilities in
most of the engineering and scientific disciplines necessary to
resolve issues of concern to the NRC and the licensee. However,
in several instance > these capabilities were not reflected in
the quality of the submittals. Most of the licensee's evalua-
tions of the significant hazards considerations were accurate
though brief, thus routinely requiring additional information to
>
justify the request.
The licensee has characterized every
amendment request submitted during the rating period as not
presenting any possible significant hazards considerations.
In
three instances, however, the NRC determined that these charac-
-
terizations of the amendment requests were not justifiable based
upon technical facts.
Several instances of poor senior management review and/or inade-
quate engineering analysis occurred during this rating period.
.
!
These instances included: (1) a requestad TS main steam isola-
tion valve closure time limit, tested under no steam flow condi-
i
tions, that would have placed the plant outside the analyzed
bounds of the steam line break design basis event; (2) a change
to the NRC approved peak reactor coolant system (RCS) pressure
limit for the feed line break (FLB) event from 110% design RCS
pressure to 120% design RCS pressure in the FLB event's safety
analysis. This was made to justify a proposed increase in the
moderator temperature coefficient limit.
This change in peak
pressure was not indicated in the licensee's TS amendment re-
,
quest.
This peak pressure change was not reviewed by the
i
licensee's safety review committees; (3) the justification for
continued Unit 1 operation with an existing flaw in the main
steam line was technically deficient; and (4) numerous technical
inconsistencies and regulatory inadequacies existed in the
,
licensee's submittals of the exigent and the first of two
!
emergency TS amendment requests for the #12 EDG.
. - -
- - __ -
- - - - , - -
- ---. ---
~_-
,
-
'
49
Over the last six months, marked improvement has been observed
with respect to senior management involvement in and the quality
of the technical responses to non-routine licensing activities,
particularly the environmental qualification and replacement
parts certification -deficiencies arising at Calvert' Cliffs.
,
Licensing issues were carried out by three different groups in
the Technical Services Engineering section of Nuclear Engt:eer-
ing Services. Primary NRC/ licensee interface was with the Fuel
Cycle Management unit, and the Licensing and Operational Safety
uni * . The third group that carried out licensing activities was
the Analytical Support unit. NRC interface with this unit was
minimal.
The Licensing unit was capably staffed though there was a staff
turnover of approximately 45% during this rating period. _Though
the level of experience appreciably declined, this unit's work
.,
product continually and significantly improved due to the per-
sistence and dedication of the unit's staff and to the quality
of training provided.
NRC communications with the Licensing
unit were marked with good relations, a high degree of coopera-
tion and a free exchange of information.
This unit actively
sought to improve communications.
The Fuel Cycle Management unit had an experienced staff with
significant expertise in the technical issues of fuels manage-
ment. Staff turnover was low.
The quality of this unit's work
-
product
remained adequate during this period with no signifi-
cant decline or improvement noted. However, many tasks assigned
to this unit remained incomplete over periods of several years.
For example, the Fuel Cycle Management Facility Change Request
(FCR) process is used to initiate TS changes, core reloads and
other related changes; and modifications, tests and experiments
as permitted under 10 CFR 50.59. No FCRs have been completed by
this unit since April 1983 although 24 such actions, including 5
core reloads and 10 TS amendments (9 of which were approved by
the NRC) were initiated since this date.
The licensee attri-
buted this failure to insufficient manpower. The licensee also
attributed this unit's failure to maintain its training records
to this manpower shortage.
Communications with this unit were
adequate though they were hesitant to inform the NRC of problems
with licensing actions in a timely manner.
In summary, the licensee's greatest strengths were the signifi-
cant technical capabilities that its staff possesses and the
management's recently demonstrated determination to improve the
quality of their licensing actions, as particularly demonstrated
through the improvements in performance level made by the Licen-
sing and Operational Safety unit.
Still, improvement is needed
in (1) in the quality and level of management overview, (2) the
.
'
50
quality and comprehensiveness of the hazards analyses provided
by the various engineering units to support licensing's develop-
ment of justifications for TS amendment requests, and (3) the
staffing level required to parmit response to NRC initiatives in
a more timely fashion and to permit the staff to perform all
tasks that are required, particularly for Fuel Cycle Management.
2.
Conclusion
Rating:
Category 2
Trend:
None
3.
Board Recommendation
Licensee: None
NRC:
None
.
-_
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _
. . .
'
51
.
J.
Assurance of Quality (0.0%)
1.
Analysis
'
The primary purpose of this functional area is to assess the
effectiveness of the licensee's program for identifying and cor-
'
recting problems.
It includes management control, verification.
and oversight activities which affect or assure the quality of
plant activities,--structures, systems, and components.
It also
,
assesses the attitude and performance of plant staff personnel.
Various aspects of this area were routinely examined as part of
the resident inspector and region-based specialist inspection
programs. A specific QA program review was performed as part of
one team inspection.
!
The previous SALP noted that although an extensive quality pro-
.
'
gram existed throughout the organization, its effectiveness in
incorporating quality into such important plant activities as
identification of root causes of plant trips and installation of
the Post Accident Sampling System was not clearly visible. QA
t
audits were often quite superficial and were not identifying
,
real
problems and root causes.
A Category 2 rating was
assigned.
.
'
In response to these concerns, immediately before and during
this assessment period, several improvements were made.
More
i
-
technically-oriented personnel with a wide variety of plant and
engineering experience were added to the QA unit.
The former
,
General Supervisor, Operations was assigned to manage the QA
unit and has helped to refocus attention more on technical and
performance aspects of areas reviewed rather than just on QA
programs. The findings and recommendations included in several
audit reports during the period were candid and demonstrated
,
l
that deeper levels of insight were being gained into subject
i
areas.
The "Trip Evaluation Review Group" concept was imple-
'
!
mented, and that group was effectively utilized in identi fying
root causes of plant trips.
Increased emphasis was placed on
,
(
interdepartmental
coordination
and
planning
for
major
j
modifications.
During the previous SALP period the licensee consolidated all
departments with nuclear
responsibilities
under
one
vice
president and moved all of these departments to the plant site.
One objective of the move was to improve communications and
interfaces between departments.
The consolidation has had
i
!
_ _ _ _ _ _
_ _ _ _
__
_ _ - _ _ _ - _
_ _ _ _ _ _ _ _ _ _ _ _ - _
_ _ .
_
9-
%
'
52
.
beneficial
effects
this period
as evidenced by increased
involvement of engineering in ' resolving daily plant problems.
The Operations department began to better prioritize anc commun-
.icate its needs for support to both the maintenance.and engi-
neering departments.
Many examples 'were noted- where inter-
departmental interfaces were effective such as in the conduct of
outage activities and in response to emergent equipment problems
such as reactor coolant pump shaft cracking. However, the dis-
covery of major deficiencies in the Equipment Qualification' (EQ)
program and, later, the discovery by the licensee of problems
with use of mechanical commercial quality (MCQ) fasteners demon-
strated that some of the interdepartmental interface problems
,
that had existed prior to the reorganization were still present
c
and were significant.
For example, documents providing engi-
neering guidance to craf t personnel were inadequate. Engineer-
ing personnel were not aware of improper as-built or as-
maintained conditions in the field. Additionally, it was noted
that the licensee was experiencing problems in fully integrating
engineering personnel into the plant staff and in defining their
responsibilities.
Senior management involvement and oversight was weak throughout
the establishment of EQ program.
Although clear warnings of
problems were provided (before and following the reorganization)
by both the NRC and the licensee's QA group, sufficient manage-
ment attention was not paid to them.
The fact that the licensee has of ten demonstrated their capa-
bility to work as a team in successfully resolving plant prob-
lems once those problems are fully recognized by senior plant
+
management suggests that the more significant weakness of
management may lie in their tools and abilities for perceiving
problems.
For example, management did not recognize the need
for third party expertise to provide an independent assessment
,
of the EQ program. In the area of safety review committees, the
Off Site Safety Review Committee (OSSRC) was principally made up
of on site managers. With such strong day to day involvement in
plant activities, members are less likely to be able to provide
independent views on plant activities and may be slow to
recognize emerging plant problems.
The high proportion of
operations department membership on and control of the Plant
Operations and Safety Review Committee (POSRC) has the potential
,
for unduly biasing that committee toward operation and may
<
thereby lessen its effectiveness in identifying safety concerns.
In the area of plant operation, the licensee lacks a policy to
4
uniformly ensure aggressive pursuit of the root cause of inter-
,
mittent failures of plant equipment.
Very little trending of
equipment performance is done to identify imper.di ng failures.
I
-.m-
m
u
.
53
The licensee has taken several new initiatives which address
some of these problems.
The QA unit recently began using out-
side consultants in specialty areas.
For example, immediately
following the SALP period, a consultant was used to perform an
inspection similar in nature to the NRC's Safaty System Func-
tional
Inspections (SSFI).
Additionally, QA personnel were
being used to investigate plant events and make corrective
action recommendations to the POSRC.
In combination, these
efforts appear to improve the credibility of the QA unit with
line organizations as well as adding effectiveness to QA func-
tions.
The upgrades in QA helped the licensee to become more
proactive in identifying their problems. Evidence was also seen
of other plant groups becoming increasingly proactive.
For
example, problems with the use of commercial quality fasteners
g
in code class systems and insertion of improper values for cer-
tain constants in the Reactor Protection System were identified.
New programs were developed to provide early indication of
impending equipment failures (oil analysis and vibration pro-
grams). There wu strong management support for using state of
the art equipment in performing ISI inspections which exceeded
code requirements and increased resources were expended on iden-
tification and precautionary replacement of secondary piping
subject to erosion / corrosion problems. Of significant note, the
licensee volunteered for and participated in the first Inter-
national Atomic Energy Agency (IAEA) Operational Safety Review
Team (0SART) Inspection conducted in the United States.
.
In general, plant employees are well trained, highly motivated
and well supervised at the first line level.
I;owever staffing
constraints appear to hamper the ability of the maintenance and
engineering departments to support operations in areas such as
final close out of Facility Change Requests (FCRs), timely up-
date of engineering construction standards, timely engineering
of needed facility modifications, and correction of control room
deficiencies.
In several areas such as outage management and control, radia-
tion protection and security, effective programs and initiatives
have been implemented thereby assuring quality in these areas as
discussed earlier in this report.
For example, the licensee's
radiation protection and ALARA programs continued throughout the
period to be effective in reducing overall personnel exposures.
The quality of personnel screening was enhanced through imple-
mentation of the Nuclear Employee Data System which is a coop-
erative ef fort by several utilities to exchange security and
health
physics
information
on
employees
and
contractor
personnel.
_ _ .
_ _ _.
__
_
_
__
-
_ _ _
.
54
In summary, weaknesses were ated in senior management control
of interfaces between departments and ability to get departments
to function together more effectively as a team.
Although
significant improvements have been made in the QA group, manage-
ment was not effectively utilizing the information they pro-
vided. Potential weaknesses were seen in the ability of licen-
see senior management to perceive plant problems and determine
root causes and in the safety committees' abilities to provide
independent views on plant activities to management.
Resource
constraints are hampering the ability of the maintenance and
engineering departments
to
support
the
operations
group.
Several initiatives were taken by the licensee during the period
to help the organization become more proactive in identi fying
plant problems. These included participation in the first OSART
inspection conducted in the United States.
Plant personnel are
highly motivated and,
in general, well qualified and well
supervised at the first line level.
2.
Conclusion
Rating:
Category 2
Trend:
None
3.
Board Recommendation
Licensee:
-
,
(1) Review composition of POSRC and OSSRC to determine if they
are sufficiently independent from plant operations to pro-
vide objective assessment and root cause analysis.
(2) Senior corporate management attention is needed to assure
proper functioning of the operations-maintenance-engineering
on-site interface.
NRC: Perform an integrated performance appraisal
inspection
concentrating
on
the
functioning
of
departmental
interfaces.
- _ _ _ _ _ _ _ _ _ - _
, . . ..
, .
.
.. ..
.
.
..
..
..
.. . .
.
_ _ _ _ _ _
gE
55
K.
Training and Qualification Effectiveness (0.0%)
1.
Analysis
The previous SALP recognized that the licensee had expended
significant resources in upgrading training facilities and pro-
grams.
It pointed out that significant improvements were made
in a previously weak maintenance training program, however the
effectiveness of those improvements was not yet apparent. Appro-
'
priate . management attention was being devoted to training.
A
Category 2 rating was assigned.
Although attributes of this topic are discussed in other SALP
.,
functional areas, the topic is segregated here because of its
importance, and to provide a synopsis of the training and qual-
ification programs.
Training effectiveness was assessed pri-
marily by observations of performance of licensee personnel and
reviews of- non-licensed staff training and training associated
with the post accident sampling system, solid radwAste handling,
and health physics activities. An NRC team inspection, in part,
assessed engineering staff training. NRC licensing examinations
were administered twice during the assessment period.
During this assessment period, the licensee continued to dedi-
cate significant attention and resources to training.
In May
1987, the final five training programs requiring INP0 accredi-
tation were accredited. With all 10 of their training programs
accredited, the licensee is now a member of the National Academy
for Nuclear Training.
Beyond accreditation the licensee is continuing to upgrade
training programs.
For instance, the 1986 operator requalifi-
cation examinations more accurately assessed cperator capabil-
ities to perform job functions by greater usage of questions
dealing with real-life situations.
In cooperation with the
University of Maryland, the licensee is developing an educa-
tional proseam, offered on site, which will lead to a Bachelor's
degree in Nuclear Science.
Some courses in the program have
already been provided to interested employees.
Based upon an
analysis of systems engineer job functions (i.e.,
performance-
based analysis), training needs were assessed, and a systems
engineer training program was developed. Implementation of this
program began immediately following the SALP period.
During
outages, maintenance and technical staff training instructors
joined plant maintenance crews,
thereby contributing their
expertise and example to craf t r.ctivities as well as enhancing
their credibility with field personnel
and updating their
knowledge of current plant problems.
!
_ _ _ _ _ _ _ .
.
56
The license training program for operators was effective in
preparing candidates for examination (further detail is provided
in the plant operations analysis section). The training program
for shift engineers was excellent in that it included senior
operator training / examination as well as shif t technical advisor
training.
Additionally,
those individuals received further
on-the-job training by virtue of being fully utilized on shift
as control room supervisors.
In July 1987, the plant experienced a significant loss of off-
site power event resulting in the tripping (shut down) of both
units, operation in natural circulation core cooling conditions
for an extended period (approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />), and declaration
of an "Alert" condition in accordance with the site emergency
plan.
During the event, operations and plant staff personnel
responded correctly and properly implemented emergency operating
procedures and the emergency plan.
Communications to the NRC
were excellent.
This event demonstrated the effectiveness of
the operator and emergency plan training programs.
Effec'ive training was also evident in two very specific areas,
post
accident
sampling
and
steam
generator
nozzle
dam
installation / removal (which resulted in low man-rem exposures).
The general experience level of system engineers was low. As
noted above a training program for these individuals was only in
the initial stages of implementation. Although NRC inspections
have not specifically identified plant problems attributable to
engineer training deficiencies, inspectors did note that oper-
ators and technicians generally lack confidence in the level of
knowledge of the system engineers.
Therefore, the engineers
were not typically viewed as a useful source of expertise in
solving technical problems.
Training weaknesses contributed to two major problems in the
maintenance area. Maintenance planning, QC and craft personnel
were not sufficiently aware of engineering requirements for
replacement mechanical fasteners. As a result, commercial qual-
ity fasteners were improperly installed in ASME Code Class I,
II, and III systems.
Similarly, Electrical and Controls per-
sonnel
lacked sufficient guidance and training to properly
install electrical splices for equipment included in the elec-
trical equipment qualification (EQ) program.
.
57
-
Three reportable events, although not principally caused by
training deficiencies, did indicate ' weaknesses in (1) non-
licensed operator understanding of the safety significance and
administrative controls associated with refueling water tank
level switches, (2) non-licensed operator understanding of the
operating principle of the condenser air removal system which
caused a unit trip, and (3) licensed operator ability to fully
anticipate and control axial flux distribution during plant
start up near end of core life.
In summary, the licensee continued to provide the necessary
resources and management attention to training.
Emphasis is
needed in training craft and QC personnel on engineering
requirements.
Because craft training programs have only been
recently finalized and accrt:dited, their effectiveness could not
be fully assessed.
Adequate training was not provided for
engineering personnel and was a significant weakness.
2.
Conclusion
Rating:
Category 2
Trend:
Improving
3.
Board Recommendation
Licensee: None
-
.NRC :
None
.
.. .
.
.
.
.
_ _ _ _ .
.
58
-
V.
SUPPORTING DATA AND SUMMARY
A.
Investigations and Allegations Review
Two allegations were received in April 1986 regarding personnel
"Jimmying" a high radiation door and that additional keys to high
radiation areas were maintained by several people within the plant
and were generally uncontrolled.
These were
substantiated.
A
violation was issued and licensee response was prompt and effective.
B.
Escalated Enforcement Actions
1.
Civil Penalties
None.
2.
Orders
None.
3.
Confirmatory Action Letters
October
1,
1986 Confirmatory Action Letter issued concerning
deficiencies identified in Emergency Preparedness exercise. A
remedial drill was held with acceptable results.
C.
Licensee Conferences Held During The Assessment Period
April 28, 1987 - Enforcement Conference at Recion I to discuss de-
tails of the isolation of the refueling water tank level switches
resulting in the loss of the automatic feature of the RAS.
May 6,
1987 - Enforcement Conference at Region I to discuss under-
lying causes of violations noted in the Environmental Qualification
Program.
July 13,1987 - Senior NRC manager.ent met with senior BG&E management
at Bethesda, Md. to discuss %dicators of declining performance.
D.
Review of Licensee Event Reports Submitted by the Licensee
The overall quality of Licensee Event Reports (LERs) is good. Over
the assessment period there was a significant improvement noted in
the discussions of safety consequences. Improvements were also noted
in discussions of corrective actions and operator actions.
Areas
which would benefit from added attention lxiude descriptions of
personnel / procedure errors, component failures and safety system
responses.
_ _ _ . . . . _ . . . . .
._
.
59
-
Two LERs (317/86-04 and 318/86-06) concerned failed reactor coolant
pump surge capacitors.
Those failures led to reactor trips. A mod-
ification to remove the capacitors and use inductors for surge sup-
pression is nearing the end of the engineering design phase.
Two LERs (318/87-03 and 318/87-04) reported repeat cracking on a
branch line for a relief valve for the Low Pressure Safety Injection
System.
Three LERs (318/86-04, 318/86-07, and 318/87-02) involved grounds and
component failu ce in Unit 2 feed water control systems. Corrective
actions taken in s,.is area may have largely resolved the problems as
evidenced by no recurrences for a major portion of the SALP period.
Two LERs (317/87-07 and 317/87-09) describe problems with improper
electrical splices on components in the Equipment Qualification pro-
gram and use of improper fasteners in code class systems. Both prob-
lems largely resulted from inadequate engineering guidance to field
personnel.
Four LERs (317/87-03, 317/87-05, 317/87-08, and 317/87-11) involved
personnel, errors and three LERs (317/86-07, 317/87-04, and 318/87-05)
involved procedure errors.
%
..y
...
TABLE 1
INSPECTION REPORT ACTIVITIES-
REPORT NUMBERS
TYPEJ
TOTAL'
INSPEJTION DATES INSPECTION
HOURS
' DESCRIPTION
86-09
86-09
RESIDENT
247.
ROUTINE RESIDENT INSPECTION
05/01/86 06/30/86
86-10
86-10
SPECIALIST
24
GENERIC' LETTER 83-28 EQUIPMENT
06/16/86 06/20/86
CLASSIFICATION, VENDOR INTERFACE, POST
MAINTENANCE TESTING, PLANT SURVEILLANCE
AND QA/QC OVERVIEW
'
86-11
86-11
RESIDENT
261
ROUTINE RESIDENT' INSPECTION
07/01/86'08/31/86
<
'
86-12
86-12
SPECIALIST
40
WRITTEN AND OPERATING EXAMINATIONS
08/11/86 08/15/86
ADMINISTERED TO SIX REACTOR OPERATOR AND
FOUR SENIOR REACTOR OPERATOR CANDIDATES
86-13
86-13
SPECIALIST
40
EMERGENCY PREPAREDNESS EXERCISE
07/21/86 07/25/86
86-14
86-14
SPECIALIST 260
EMERGENCY PREPARE 0 NESS EXERCISE AND
09/08/86 10/17/86
REMEDIAL DRILL
86-15
86-15
SPECIALIST
24
SURVEILLANCE AND CALIBRATION TESTING
08/18/86 08/22/86
PROGRAM AND CONTROL 0F MEASURING AND
TEST EQUIPMENT
86-16
86-16
RESIDENT
206
ROUTINE RESIDENT IMSPECTION
09/01/86 10/17/86
86-17
86-17
SPECIALIST
74
IMPLEMENTATION OF RADIATION
09/15/86 09/19/86
PROTECTION PROGRAM AND OUTAGE
-
PREPARATIONS INCLUDING ALARA EXPOSURE
AND RADI0 ACTIVE MATERIAL CONTROL
'
86-18
86-18
RESIDENT
209
ROUTINE RESIDENT INSPECTION
10/18/86 11/30/86
L
i
f
_ _ _ _ _ _ _ _ .
.
Table 1
T1-2
-
REPORT NUMBERS
TYPE
TOTAL
INSPECTION DATES INSPECTION
HOURS
DESCRIPTION
86-19
86-19
RESIDENT
289
ROUTINE RESIDENT INSPECTION
12/01/86 01/12/87
86-20
86-20
SPECIALIST
94
PLANT OPERATIONS AND SURVEILLANCE
11/03/86 11/07/86
PROGPEMS FOR CONTAINMENT INTEGRITY,
ISOLATION VALVES AND AIR LOCKS,
HYOR0 GEN CONTROL AND OTHER SYSTEMS
86-21
86-21
CANCELLED
86-22
86-22
MEETING
NA
LICENSEE REQUESTED MEETING
86-23
SPECIALIST
24
REV!EW 0F THE ISI PROGRAM, OBSERVATIONS
11/17/86 11/21/86
0F ULTRASONIC AND EDDY CURRENT
EXAMINATIONS AND REVIEW OF NDE PROCEDURES
86-24
86-23
SPECIALIST
30
MAINTENANCE PROCEDURES, ELECTRICAL,
11/17/86 11/21/86
MECHANICAL AND INSTRUMENTATION
MAINTENANCE AND MODIFICATION TASKS AND
QA/QC CONTROL INTERFACES
86-25
SPECIALIST 32
RADIOLOGICAL SAFETY INSPECTION -
12/01/86 12/05/86
IMPLEMENTATION OF RADIOLOGICAL CONTROLS
DURING UNIT 1 OUTAGE
-
87-01
87-01
RESIDENT
196
ROUTINE RESIDENT INSPECTION
01/12/87 02/28/87
87-02
87-02
SPECIALIST 32
FOLLOWUP ON SECURITY PROGRAM EVENT
02/17/87 02/20/87
REPORTS AND A PREVIOUSLY IDENTIFIED
VIOLATION, MANAGEMENT EFFECTIVENESS
AND INDEPENDENT INSPECTION
87-03
87-03
SPECIALIST 84
PASS SAMPLING OF REACTOR COOLANT &
02/24/87 02/27/87
CONTAINMENT ATMOSPHERE, N0BLE GAS
EFFLUENT MONITORS, EFFLUENT MONITORING,
i
IN PLANT RADIO-IODINE MEASURES
87-04
87-04
SPECIALIST 32
NON-LICENSED STAFF TRAINING
02/23/87 02/27/87
i
_ - _ _ _ _ --__ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.-_____ _____- __ ____-__ - ____
.
1
Table 1
T1-3
'
REPORT NUMBERS
TYPE
TOTAL
INSPECTION DATES
INSPECTION HOURS
DESCRIPTION
!
- 87-05
87-05
SPECIALIST' 40
WRITTEN AND OPERATING RETAKE
04/20/87 04/24/87
EXAMINATION ADMINISTERED TO ONE
REACTOR OPERATOR AND RETAKE OPERATING
EXAMINATION TO ONE OTHER R0 CANDIDATE-
l
87-06
87-06
RESIDENT
202
ROUTINE RESIDENT INSPECTION
03/01/87 04/13/87
87-07
SPECIALIST 40
UNANNOUNCED OCCUPATIONAL RADIATION
03/23/87 03/27/87
PROTECTION INSPECTION AT UNIT 2
DURING UNIT OUTAGE
87-07.
87-U8
SPECIALIST 40
UNANNOUNCED INSPECTION OF LICENSEE
03/23/87 03/27/87
ACTIVITY IN RESPONSE TO INFORMATION NOTICE 86-03 AND INFORMATION NOTICE 86-53
87-08
87-09
SPECIALIST 40
UNANNOUNCED INSPECTION OF THE LIQUID AND
03/01/87 04/03/87
GASEOUS RADI0 ACTIVE EFFLUENTS CONTROL
<
PROGRAM REPORT
87-09
RESIDENT
24
SPECIAL INSPECTION TO ASCERTAIN
03/26/87 03/30/87
CIRCUMSTANCES INVOLVING ISOLATION OF ALL
RECIRCULATION ACTUATION SYSTEM LEVEL
-
SWITCHES - LER 317/87-05
87-10
SPECIALIST 40
INSPECTION OF IN SERVICE INSPECTION
04/06/87 04/10/87
PROGRAM AND STEAM GENERATOR INTEGRITY
'
87-10
87-11
RESIDENT
187
ROUTINE RESIDENT INSPECTION INCLUDING
04/14/87 05/18/87
DEFICIENCIES IN EQ PROGRAM, REPETITIVE
BRANCH LINE CRACKING AND CQ REPLACEMENT
PARTS
87-11
87-12
SPECIALIST 40
INSPECTION OF NUCLEAR MATERIAL CONTROL
j
04/28/87 05/01/87
AND ACCOUNTING
I
87-12
87-13
SPECIALIST 40
MECHANICAL, ELECTRICAL, AND I&C
04/27/87 05/01/87
MAINTENANCE INCLUDING PROCEDURES,
'
MODIFICATIONS, EQUIPMENT HISTORIES,
TRANSFORMER REVIEWS & QA INTERFACE
j
i
i
)
i
,
l
-
- _ _
_ _______-
.
'
Table 1
T1-4
.
REPORT NUMBERS
TYPE
TOTAL
t )i
'
INSPECTION DATES
INSPECTION HOURS
DESCFfPTION
'
87-13
87-14
SPECIALIST 308
SPECIAL INSPECTION REVIEWING EQ
05/11/87 05/15/87
DEFICIENCIES, COMMERCIAL QUALITY
MECHANICAL FASTENERS, PM TESTING,
ENGINEERING REQUIREMENTS AND QA
s
87-15
SPECIALIST 40
INSPECTION OF IN SERVICE INSPECTION
'
1
05/11/87 05/15/87
REVIEW 0F ISI DATA AND QA COVERAGE,
7
REPAIR ACTIVITIES ON 2-RV-439, EROSIOM/
'
CORROSION EXAMITATIONS
87-14
87-16
RESIDENT
312
ROUTINE RESIDENT INSPECTION
,
,
05/IS/87 06/30/87
'
87-15
87-17
SPECIALIST 39
SOLID RADI0 ACTIVE WASTE PROCESSING,
I
07/13/87 07/17/87
PREPARATION, PACKAGING AND SHIPPING
PROGRAM
87-17
87-19
RESIDENT
276
ROUTINE RESIDENT INSPECTION
07/01/87 07/31/87
,
87-16
87-18
SPECIALIST
32
RADIOLOGICAL ENVIP0HMENTAL MONITORING
07/13/87 07/17/87
PROGRAM
87-18
87-20
SPECIALIST
8
SENIOR N3HAS_ MENT MEETING HELD AT NRC
07/13/87 07/13/87
HEADQUARTERS
87-20
87-22
SPECIALIST
32
INTERNATIONAL ATOMIC ENERGY AGENCY
08/17/87 08/21/87
VISITATION
87-22
87-24
RESIDENT
80
ROUTINE RESIDENT INSPECTION
08/01/87 08/31/87
87-19
87-21
SPECIALIST
CANCELLED
87-21
87-23
SPECIALIST
CANCELLED
(
s
!
'
_.
-_-
_.
..
i u)t% .
(
_
'
\\
,' e
(
'\\
\\.4
TABLE 2
s,,
,
(
CALVERT CLIFFS 1&2
'
INSPECTION HOUR SvKMARY
,
,
4
'XREA
HOURS
HOURS ANNUALIZE0
PERCEN!
OPERATIO,NS
1646
1234.5
40.9
'
RAUCON/ CHEMISTRY
465
348.7
11.6
'
,, . ,
MAh5?ANCE
559
419.3
13.9
y
SURVEILLANCE
332
249 0
8.2
.s
EMERGENCY PREP.
308
231.0
7.7
o
SEC/ SAFEGUARDS
88
66.0
2.2
,
OUTAGES
271
203.3
6.7
,
ENGINEERING
275
206.2
6.8
LICENSING
/
74
55.5
1.9
s
0
0.0
0.0
9 /
I
1 RAINING / QUALIFICATION
0
0.01
0.0
l
!
'
TOTALS:
4018
3013.5
100.0
)
t
i
s
y
N t
,
<
(
v
>
t
'
l
'
.
Ir
E
(
'N
,
I
J,
\\ ,
\\
\\'
s)
r
,
t'
//
s
<
s
,
,
'
\\
'
i/
s
i
f
,
W
%
t
.
. . . ..
-
.
_
._ _
! , 4 4. ,
.
.
'
i,o
TABLE 3
CALVERT CLIFFS 1&2
'
ENFORCEMENT ACTIVI1 6 '
s
A.
Violations versus Functional Area by S'everity Level
No. of Violations in Each Severity Level
AREA
'l
2
3
4
5
DEV
TOTAL
f
OPERATIONS
1
1
,
,
-
>
RADCON/ CHEMISTRY
1
1
3
MAINTENANCE
1
1
?
SURVEILLANCE
-
2
.
2
EMERGENCY 90,EP.
O
SEC/ SAFEGUARD'S
2
2
OUTAGES
0
ENGINEERING SUPPORT
1*
LICENSING
0
ASSURANCE OF QUALITY
0
TRAINING & QUALIFICATION
0
FIRE PROTECTION-HK
0
TOTALS:
T7
l*
- 0ne or more violations pending in EQ
l
I
.
e
.-
Table 3
T3-2
"~
,B.
Summary of Violations
INSPECTION REPORTS' REQUIREMENT SEVERITY
FUNCTIONAL
' INSPECTION DATES
VIOLATED
LEVEL
AREA
DESCRIPTION
__
__
'86-09-
T . S . . '6 ' 12'.1
-4-
RADCON
FAILURE TO MAINTAIN
.
05/01/86 06/30/86-
CONTROL 0F LOCKED
KEYS
86-10
T.S.6.8.1
4.
MAINTENANCE
FAILURE TO FOLLOW
06/16/86 06/20/86
PROCEDURES AFFECTING
'
SAFETY-RELATED
ACTIVITIES
86-15
_
4
SURVEILLANCE I&C TECHNICIANS
-08/18/86 08/22/86 APPX. B
USING TEST EQUIPMENT NOT
WITHIN THE. CALIBRATION
DATE AND STORAGE
POTENTI0 METERS OUT
OF CALIBRATION
86-16
SECURITY
4
SEC/SAFEGRDS FAILURE TO FOLLOW
09/01/86 10/17/86 ' PLAN
SECURITY PLAN PROCEDURES
FOR VEHICLE KEY CONTROL
86-20
T.S. 6.8
4
SURVEILLANCE FAILURE ~TO PRuii.5 V-
11/03/86 11/07/86-
REVIEW COMPLETED
SURVEILLANCES AND TAKE
CORRECTIVE ACTION FOR
OUT OF SPECIFICATION
TEST RESULTS
i
!
_
_ _ _ _ _ _ ____ _ -__- - __ _
- ___-_
_
_ _ _ _ _ _ _ _ _ _ _
_
_ _ _ _ _ _ . _ _ _ .
. _ _ _ _ - _ _ _
_ _ __
__
_ _ _ _ _ _ _ _
.
Table 3
T3-3
-
INSPECTION REPORTS REQl'IREMENT SEVERITY
FUNCTIONAL
INSPECTION DATES
VIOLATED
LEVEL
AREA
DESCRIPTION
87-07
87-08
ENGINEERING
FAILURE TO ESTABLISH
~*
'03/23/87 03/27/87
ADEQUACY OF THE-
MAINTENANCE PROCEDURES
- Pending
no violation issued yet
FOR MAINTAINING
LIMITORQUE M0V'S
FAILURE TO ESTABLISH
QUALIFICATION OF
ASCO VALVE
LICENSEE FAILED TO
ESTABLISH QUALIFICATION
OF WRAP-AROUND TAPE
SPLICES USED IN PIG-
TAIL LEADS FOR SOLEN 0ID
VALVES
87-09
-
4
OPERATIONS
FAILURE TO COMPLY
03/26/87 03/30/87
WITH THE PRECAUTIONS
OF A SURVEILLANCE
TEST PROCEDURE
ISOLATING RAS FUNCTION
,
-
l
l
87-12
87-13 .
5
MAINTENANCE
FAILURE TO FOLLOW
'
04/27/87 05/01/87
SAFETY TAGGING
ADMINISTRATIVE
CONTROLS DURING
l
MAINTENANCE ACTIVITY
-87-11
87-12
SEC/SAFEGRDS FAILURE ~TO
04/28/87 05/01/87 70.51(D)
MAINTAIN AND KEEP
PHYSICAL INVENTORY
RECORDS TO SUPPORT
THAT INVENTORIES OF
SNM WERE CONDUCTED
BETWEEN 4/30/81
AND 3/30/85
I
i
l
{
l
~
!~
. . - . . . - .
.
.
.
.
TABLE _4
CALVERT CLIFFS 1&2
LICENSEE EVENT REPORTS
A.
LER by Functional Area
Number by Cause Codes
FUNCTIONAL AREA
A
B
C
D
E
X
TOTAL
OPERATIONS
5
3
2
10
RADCON/ CHEMISTRY
-
MAINTENANCE
1
1
1
3
6
SURVEILLANCE
1
1
EMERGENCY PREP.
-
SEC/ SAFEGUARDS
-
OUTAGES
-
i
ENGINEERING SUPPORT
8
8
LICENSING
-
ASSURANCE OF QUALI TY
-
TRAINING AND
QUALIFICATION
-
idTALS:
T i6 l 7
7
7
3
-
-__-__-_____-_;
. . .
[
'
Table 4
T4-2
-
8.
LER Synopsis
- CALVERT CLIFFS 1
LER NUMBER EVENT DATE CAUSE CODE
DESCRIPTION-
86-03
04/30/86
A
BATTERY WATER LEVEL EXCEEDED HIGH LEVEL
'
LIMIT
86-04
07/20/86
B
REACTOR TRIP CAUSED BY REACTOR COOLANT
PUMP SURGE CAPACIl0R
86-05
10/01/86-
0
MAIN VENT WIDE RANGE NOBLE GAS EFFLUENT
MONITOR IN0PERABLE DOE TO DEFICIENT
S
PROCEDURE
86-06
10/10/86
A
REACTOR TRIP DUE TO TURBINE TRIP FROM
86-07
10/11/86
0
REACTOR TRIP CAUSED BY HIGH' AXIAL SHAPE
INDEX
87-01
12/10/86
0
VIOLATION OF TECHNICAL SPECIFICATION
FOR OPERABLE SHUTDOWN COOLING LOOPS
87-02
12/03/86
B
MAIN-STEAM PIPING FLAW
87-03
01/27/87
A
REACTOR TRIP AS A RESULT OF LOSS OF
INSTRUMENT' AIR
87-04
02/01/87
0
REACTOR TRIP AS A RESULT OF TURBINE RUN
BACK
87-05
02/17/87
A
INADVERTENT ISOLATION OF ALL
RECIRCULATION ACTUATION SYSTEM LEVEL
SWITCHES
87-06
03/10/87
X
PRESSURIZER SAFETY VALVES 200 AND
201 SET POINTS OUT OF SPECIFICATIONS
87-07
04/01/87
B
ENVIRONMENTAL QUALIFICATION
DISCREPANCIES REQUIRING SHUT DOWN
87-08
04/14/87
A
IMPROPER VALVE LINEUP RESULTING IN
SPRAYING B0 RATED WATER IN CONTAINMENT
BUILDING
i
__
_
-
- - - - _ - - _ _ _ - - - - - - - _ - _
--_--------------a
._
_
._.
._
. _ ,
.
_
--
-
,
Table 4
T4-3
-
LER NUM3ER EVENT-DATE CAUSE CODE
DESCRIPTION
87-09-
04/23/87
8
USE OF FASTENERS (BOLTS, STUDS, THREADEO
R00 & NUTS) IN ASME CLASS 1, .2, & 3,
,
SYSTEMS WITHOUT PROPER CERTIFICATION,
.87-10
05/22/87
B
PRESSURIZER SPRAY VALVE BONNET WELD
DESIGN DEFICIENCY
87-11
07/14/87-
A
LOSS OF FEED WATER HEATER AND
OVERB0 RATION EVENT WITH REACTOR TRIP
87-12
07/23/87
X
FAULTY 500KV CIRCUIT BREAKER OPERATION
LEADS TO LOSS OF NON-EMERGENCY - AC POWER
CALVERT CLIFFS 2-
86-04
05/21/86
E
MANUAL AND AUTOMATIC TRIPS ON LOW-
STEAM GENERATOR WATER LEVEL
86-05
07/25/86
B
FLEX HOSE FITTING FAILURE ON 21A RCP
REQUIRED UNIT SHUTDOWN AND UNUSUAL
EVENT
86-06
09/05/86
B
REACTOR TRIP CAUSED BY REACTOR COOLANT
PUMP SURGE CAPACITOR FAILURE
-
86-07
09/12/86
B
MANUAL REACTOR TRIP DUE TO PARTIAL LOSS
OF FEED WATER FLOW TO STEAM GENERATORS
87-01
CANCELLED
I
87-02
02/28/87
E
FAILURE OF LEAD / LAG CIRCUIT IN
FEED WATER REGULATING VALVE CONTROL
SYSTEM LEADS TO LOW STEAM GENERATOR
WATER LEVEL REACTOR TRIP
87-03
03/24/87
B
FAILURE OF INLET PIPING TO RELIEF
'
l
VALVE (2-RV-439)
87-04
05/07/87
B
FAILURE OF INLET PIPING TO RELIEF
VALVE (2-RV-439)
87-05
07/03/87
E
FOLLOWING THE CALIBRATION OF THE
TURBINE GENERATOR CONTROLLER, EXCESS
LOAD RESULTS IN A LOW STEAM
GENERATOR PRESSURE REACTOR TRIP
l~
l
l
e
Table 4
T4-4
C.
Licensee Event Reports (LERs)
Tabular Listing
Type of Events
Unit 1
Unit 2
A.
Personnel Error. . . . . .
..6
......0
B.
Design / Man.Constr./Tnstall . . .
5
......5
C.
External Cause . . . . . . . . . 0
......0
D.
Defective Procedure
......4
......0
E.
Component Failure
....0
......3
..
X.
Other
.............2
....0
Total
. .
17
......5
Licensee Event Reports Reviewed:
Unit 1 LER 86-03 through 87-12; Unit 2 LER 86-04 through 87-05.
. .
._-
.
. .- .
_
, _ . _ _
_
.,
~ .
. _ -
_
. . _ , _ _ - .
,
.-
.
TABLE 5
'
'
SUMMARY'0F LICENSING ACTIVITIES
A.
NRR LICENSEE MEETINGS
q
September 19,.1986
Request for Emergency TS Amendment for #12 EDG
September 26, 1986
24-month Cycle Reload
' October 3, 1986
C0 in-leakage into #12 EDG Jacket Cooling Water
' System
!
December 10, 1986
Unit 1 Main- Steam Line Flaw '
January 7,1987 -
Future Licensirg Actions
g q.
May 5, 1987
Materials Qualification Deficiencies
'
B.
NRR SITE VISITS
'
July 14, 1986
Site familiarization and training for new ORPM
July 18, 1986
SALP Meeting
August 1, 1986
Discuss licensing actions status
August 7, 1986
Investigate #12 EDG C0 in leakage
>
i
October 2, 1986
Follow up information on #12 EDG
November 3-7, 1986
Containment Ir tegrity Inspection
j.
April 1, 1987
ATWS Modification Review
May 11-15, 1987
Restart Inspection (joint Region I/NRR team)
June 10, 1987
L
L
August 10-28, 1987
OSART
l
C.
COMMISSION BRIEFINGS
None.
[
!
1
!
l
l
.-
. . .
.-- .
- - . - - .
- . - . . -
. . - . .
. . .
. - .
. - - - . . - - - . - .
.
- _ _ _ - _ _ _ _ _ _ _
.
Table 5
T5-2
-
D.
SCHEDULAR EXTENSIONS GRANTED
September 30, 1986
Order for operable SPDS, Units 1 and 2
E.
RELIEFS GRANTED
March 26, 1987
ASME Section XI Relief - Unit 1 Main Steam Line
Flaw
May 11, 1987
ASME Section XI Relief - Units and 2 Class 1 and
2 Bolting and Control Rod Drive Housing
May 29, 1987
ASME Section XI Temporary Relief - Unit 2
Auxiliary Feed Water Hydrostatic Test
F.
EXEMPTIONS GRANTED
None
G.
LICENSEE AMENDMENTS ISSUED
Date
Unit 1
Unit 2
Title
June 17, 1986 118
100
Miscellaneous TS Changes
June 30, 1996 119
101
Miscellaneous TS Changes
,
August 6. 1986 120
102
Miscellaneous TS Changes
Sept. 8, 1986 121
103
Exigent DG LC0 Change
Sept. 23, 1986 122
104
Emergency Change #12 OG
Oct. 6, 1986
123
105
DFOST Outace Time
Nov. 28, 1986 124
---
Emergency Change Refuel
without a1 EDG
Dec. 19, 1986
I?5
106
RCP Flywheel Inspection /
,
'
~ ble Deletion
a
Feb. 25, 1987
126
---
MSIV Replace Closure
l-
April 29, 1987 ---
107
MSIV Replace Closure
1
June 30, 1987 ---
108
Cycle 8 Reload Request
l
l
i
l
_ _ - _ _ _ _ - _ _ _ _ _
.
Table 5
TS-3
"
July 7, 1987
127
109
CEA Misalignment /
Purge Valve Isolation
H.
ORDERS ISSUED
September 30, 1986
Modification of Order on Emergency Response
Capability Schedules (Generic Letter 82-33)
providing a schedular extension for SPOS
Operability.
.
puso
'o,,
UtJITED STATES
ENCLOSURE 3
, ,.
,
i
NUCLEAR REGULATORY COMMISSION
o
$
,I
REGION l
0,%
g
$31 PANK AVENUE
.,6
(
- . . . . . ,e
KING OF PRUSSIA, PENNCYLVANIA 194o6
Om n31987
DOCKET / LICENSE:
50-317/DPR-53
50-318/DPR-69
Baltimore Gas and Electric Company
ATTN: Mr. J. A. Tiernan
Vice President, Nuclear Energy
Post Office Box 1475
Baltimore, Maryland 21203
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report
No. 50-317/86-99; 50-318/86-99
The NRC Region 1 SALP Board has reviewed and evaluated the performance of
activities at the Calvert Cliffs Nuclear Power Plant for the period of
May 1, 1986 through August 31, 1987.
The results of this assessment are
documented in the enclosed SALP Board report.
A meeting to discuss the
assessment has been scheduled for December 14, 1987, at the site in Lusby,
l
At the SALP meeting, you should be prepared to discuss our assessments and your
f
plans to improve performance. In particular, you should be prepared to ciscuss
the areas of management control of the interfaces between the Engineering,
Operations and Maintenance Departments, the need for additional resources in
the engineering and maintenance areas and more effective use of self analysis
techniques to recognize emerging plant problems. The meeting is intended to be
a candid dialogue wherein any comments you may have regarding our report may be
discussed. Additionally, you may provide written comments within 30 days after
the meeting.
Fc11owing our meeting and receipt of your response, the SALP report and ycur
l
retponse will be placed in the NRC Public Document Room.
l
Your cooperation with us is appreciated.
l
1
l
Sincerely,
l
William T. Russell
l
Regional Administrator
l
Enclosure:
SALP Report No. 50-317/86-99; 50-318/86-99
l
k
w-
.
)
.
. .
' -ty
.
____
o
,
DEC 031987
Baltimore Gas and Electric Company
2
,
,
cc w/ enc 1:
.
M. Bowman, General Supervisor, Technical Services Engineering
Thomas dagette, Administrator, Nuclear Evaluations
Public Document Room (POR)
Local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Maryland (2)
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
Commissioner Carr
Commissioner Rogers
(
(
l
..-d
&.
ENCLOSURE 4
.
.
.
'
BALTIMORE
GAS AND
ELECTRIC
CHARLES CENTER * R O. BOX 1475 BALTIMORE, MARYLAND 21203
JosCPH A.TIERNAN
Viet PRestDENT
NuCLEAM ENEROY
January 13, 1988
U. S. Nuclear Regulatory Commission
Washington, DC 20555
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant
Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318
Systematic Assessment of Licensee Performance (SALP)
REFERENCE:
(a) Letter from Mr. W. T. Russell (NRC) to Mr. J. A. Tiernan (BG&E),
dated December 3,1987, same subject
Gentlemen:
This is in response to Reference (a) and the SALP conference held on December 14, 1987,
at Calvert Cliffs. We appreciate your assessment and constructive criticism of our
nuclear program. Action plans are underway in many areas to strengthen our Nuclear
Program. Enclosure (1) provides some specific comments regarding those efforts.
I will keep you informed of our initiatives and we welcome your comments and insights
,
l
as we continue to strive for excellence at Calvert Cliffs.
Very truly yours,
j
,
!
l
JAT/SRC/ dim
Enclosure
l
~.
cc:
D. A. Brune, Esquire
,
l
J. E.
Silberg, Esquire
.
l
R. A.Capra,NRC
!
S. A.McNeil,NRC
W. T. Russell, NRC
T. Foley/D. C. Trimble, NRC
l
Mi MOr*3-f m
,
l
l
- -
,
'
ENCLOSURE (1)
o
d
REPLY TO SALP REPORT NO. 50-317/86-99; 50-318/86-99
I
,
PLANT OPERATIONS
.
l
We will continue to focus on and strengthen plant operations. For example, we changed
l
the Plant Operations and Safety Review Committee (POSRC) meeting format and introduced
the
facilitator
concept.
The
facilitator
controls
the
meeting
and
ensures
its
i
formality. We will continue to evaluate the effectiveness of POSRC and make changes as
necessary.
l
Communications between the operations organization and the rest of the plant will be
improved. Our supervisory staff has been receiving training to enhance plant teamwork.
I
In August we initiated a morning meeting for plan-of-the-day activities which the
General Supervisor-Operations chairs. The meeting includes engineering and maintenance
personnel and has improved intra-organizational communication.
CIIEMISTRY AND RADIOLOGICAL CONTROLS
No comments.
MAINTENANCE
Additional human resources in the Mechanical and I&C Maintenance areas are being
'
provided through the addition of contractor forces, loaned , crafts from elsewhere in our
company and temporary additions to the complement. The preventive maintenance program
will be improved.
Although we have initiated a strong program to reduce Control Room deficiencies, we
also are not satisfied w ith the number of out-of-service instruments in the Control
Room and we intend to improve in this area. It should be pointed out that the number
of out-of-service instruments has been cut approximately in half in the last 12 months
through our aggressive efforts.
SURVEILLANCE
Documentation of surveillance results will be improved by more aggressively documenting
and reviewing equipment performance. We will continue and strengthen our proactive
efforts regarding equipment problems.
We do not believe that we rely too stringently on the Technical Specification
definition of ' OPERABLE" since we frequently go beyond what is required by the
Technical Specifications in demonstrating operability.
1
'
'
ENCLOSURE (1)
8
REPLY TO SALP REPORT NO. 50-317/86-99; 50-318/86-99
In response to your assessments regarding Emergency Preparedness, we agree that
resources are adequate and reasonably effective so that satisfactory performance is
achieved. Your report accurately reflects the shortcomings experienced in the 1986
annual graded exercise.
However, we believe a definite trend of improving performance is discernible in
Emergency Response. The basis for this includes our own evaluations conducted during
i
'
the February 1987 and June 1987 drills and the SALP Boards' summary statement which
says in part: "The licensee immediately recognized the (1986 exercise) weakness and
performance has improved considerably since . . . ." While the SALP Report does not
elaborate on the results of the IAEA, Operational Safety Review Team (OSART) review, it
is worthy to note that Emergency Response received acclaim in several respects.
SECURITY AND SAFEGUARDS
e
We have no general comments, however, we would like to point out that our engineering
organization is responsible for and conducts the inventory of special nuclear materials
(SNM). The security organization would report unaccounted for shipments, suspected
thefts,
unlawful
diversions,
radiological
sabotage,
or
events
which
significantly
threaten or lessen the effectiveness of safeguards.
i
l
.
REFUELING. OUTAGE MANAGEMENT
l
In
1988, we will focus more attention on improving equipment condition and
availability. We have scheduled an outage on Unit No. 2 specifically to improve the
unit's material condition.
1
ENGINEERING SUPPORT
i
.
l
Your observations on our engineering organization are appropriate. As you said, we are
!
improving. However, we will devote additional resources to the situation and will
l
strengthen prioritization and interdepartmental work relations,
i
With respect to working relationships between Operations, Maintenance, and Engineering,
the TERG (Trip Evaluation and Recovery Group) was implemented last year and established
a teamwork approach to problem solving. We will continue to build on that experience.
We have a first draft of a System Engineer responsibilities and interfaces document.
We are gathering comments and finalizing it.
-2-
_____
. . .
i
l
1
o
.
ENCLOSURE (1)
'
.
REPLY TO SALP REPORT NO. 50-317/86-99; 50-318/86-99
'
We have hired a consultant to develop a customized project management training seminar.
.
A key element in development of that seminar was to reach consensus among Operations,
Maintenance, and Engineering on how we want to perform project management at Calvert
Cliffs.
The
consensus
reaching
sessions
are
completed,
the
results
have
been
s
incorporated into the training syllabus, and the first of several seminar sessions is
i
in progress.
1
d
We have hired a consultant to perform an independent assessment of the Nuclear
Engineering Services Department. Expected completion date is second quarter 1988.
We are in the process of shifting the focus of our System Engineers toward more plant
maintenance engineering, in order to unburden System Engineers, project management of
i
additional modifications will be assigned by System Engineers to the Major Projects
Engineering Unit. We are also increasing our staff and the number of long-term
contractors in the System Engineering area. A third systems unit, Auxiliary Systems
Engineering, is being organized and staffed.
We are increasing our staff and the number of long-term ecntractors in the Design
Engineering area. The Electrical Engineering Unit is being expanded and split into an
Electrical Analysis Engineering Unit and an Electrical Modifications Engineering Unit.
We are increasing our staff in Performance Engineering in the area related to the
Preventive Maintenance Program.
j
The System Engineering Training Program has a high prio'rity. We initiated training in
fall 1987, and we expect to accelerate the scope of that training in 1988 and have the
program fully developed and implemented by 1989.
We
are
also
increasing
the
staff
and
elevating
the
Materials
Analysis
and
Non-Destructive Examination Inservice Inspection Work Group to the status of an
organizational unit.
,
LICENSTHQ
We are increasing our staff in the Licensing & Operational Safety and Fuel Cycle
Management Units. Additionally, we will improve the training and experience of our
licensing staff.
ASSUR ANCE OF OUALITY
Our major emphasis in this area is to improve communications and teamwork.
Programs which emphasize communications and team building have been in progress since
Nuclear Energy Division,
July 1987. The programs have included the Vice President
-
all four Nuclear Energy Division Managers, all Calvert Cliffs General Supervisors, and
during 1988 will include all on-site supervision. It is expected that these pro 8 tams,
-3-
._
_ _ _ _ _ _ _ ___-____ ______ ___________________ -
l
f:
l
'
e
,
ENCLO5URE (1)
s
REPLY TO SALP REPORT NO. 50-317/86-99; 50-318/86-99
i
along with a clarification of responsibilities of various key groups, will have the
desired , effect in assuring the proper functioning and strengthening of interfaces
l
between all on-site groups.
TRAINING AND OUALIFICATION EFFECTIVENESS
<
,
i
Added emphas,s is being placed on developing and implementing additional training
i
programs for both craft and engineering personnel during 1988.
l
.
1
e
_4