ML20197H729
| ML20197H729 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/17/1986 |
| From: | Jaffe D Office of Nuclear Reactor Regulation |
| To: | Miraglia F, Russell W, Speis T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20197H722 | List: |
| References | |
| NUDOCS 8605190257 | |
| Download: ML20197H729 (14) | |
Text
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. , (v3 V April 17, 1986 Docket Nos. 50-317 and 50-318 MEMORANDUM FOR: Frank J. Miraglia, Director Division of PWR Licensing-B William T. Russell, Director Division of Human Technology Themis P. Speis, Director Division of Safety Review and Oversight Dennis Crutchfield, Assistant Director for Technical Support Division of PWR Licensing-B THRU: Ashok C. Thadani, Director PWR Project Directorate #8 Division of PWR Licensing-B FROM: David H. Jaffe, Project Manager PWR Project Directorate #8 Division of PWR Licensing-B
SUBJECT:
DRAFT NRR SALP INPUT FOR CALVERT CLIFFS Enclosed is a draft of the NRR input to the SALP review for Calvert Cliffs. The draft report.is based partly upon input from selected staff personnel who have substantial contact and involvement with Calvert Cliffs licensing material. Please review the draft evaluation and provide any comments you feel appropriate. All comments received by April-25, 1986 will be considered in the final report. Your comments may be provided verbally due to the short turn-around time. Please note that the licensee was evaluated to be a Category 1.
/s/
David H. Jaffe, Project Manager PWR Project Directorate #8 Division of PWR Licensing-B
Enclosure:
As stated Distribution: Docket File PBD#8 SALP File AThadant' NRC & L PDRs D hfield DJaffe PKreutzer l PBD#8 PBD# PBD#8 PKredtzer. DJaf1 ;eh Atha ni f[/4 /86 0 86
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. Enclosure 1 Detailed Review - Licensing Activities Facility Name: Calvert Cliffs Nuclea? Power Plant, Units 1 and 2 Licensee: Baltimore Gas and Electric Company Evaluation Period: October 1, 1984 to April 30, 1986 NRR Project Manager: D. H. Jaffe I. INTRODUCTION This report represents the results of an evaluation of the licensee in the functional area of " Licensing Activities." It is intended to provide NRR's input to the SALP review process as described in NRR Offica Letter No. 44 dated January 3, 1984, and NRC Manual Chapter 0516.
II.
SUMMARY
OF RESULTS NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance Category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of Baltimore Gas and Electric Company, in the functional area of " Licensing Activities", is rated Category 1. III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance. IV. METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Project Manager (ORPM) and those technical reviewers who expended significant amounts of effort on Calvert Cliffs Nuclear Power Plant, Units 1 and 2 licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the ORPM and each reviewer applied specific evaluations to the relevant licensee performance criteria, as delineated in Chapter 0516, and assigned an overall rating Category (1, 2, or 3) to each criterion. The reviewers included this information as part of each Safety Evaluation prepared for Calvert Cliffs. The ORPM, after reviewing inputs of the technical reviewers, combined this information with his own assessment of the licensee performance and, using appropriate weighting factors, arrived at ! a composite rating for the licensee. This rating also reflected the comments ' of the NRR Senior Executive assigned to the Calvert Cliffs Nuclear Power Plant SALP assessment. A written evaluation was then prepared by the ORPM , and circulated to NRR management for comments. ! l l
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i. The basis for this appraisal was the licensee's performance in support of licensing actions that were completed during the current rating period. These actions consisted of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions, as shown in Table 1 below and in Enclosure 2. Table 1 Licensing Activities Completed During the SALP Period
- Issue Completion Date AFW Pump Endurance Test Safety Evaluation 11/04/84 Environmental Qualifications of Safety Related Electrical Components - Safety Evaluation 11/20/84 Post Accident Sampling System (II.B.3.2) Safety Evaluation 02/12/85 GL 83-28 Item 1.1 - Post Trip Review Safety Evaluation 04/11/85 IREP Safety Evaluation 05/09/85 TMI Items II.K.3.30 and II.K.3.31 (Small Break LOCA Models) Safety Evaluation 06/28/85 Control of Heavy Loads (Phase II) Safety Evaluation 06/28/85 GL 83-28 Item 4.2 (Reactor Trip Reliability) Safety Evaluation 07/10/85 I&E Bulletin 80-11 (Masonry Walls) Safety Evaluation 07/18/85 TMI Item II.K.3.25 Safety Evaluation 10/07/85 Extended Burn-up Report Safety Evaluation 10/10/85 GL 83-28 Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 and 4.5.1 Safety Evaluation 11/21/85 Safety Parameter Display System - Safety Evaluation 03/24/86
*Also, see licensing actions identified in Enclosure 2 l l
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i l i , j V. ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of the six criteria specified in NRC Manual Chapter 0516. These are: Management Involvement and Control in Assuring Quality
-- Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives Staffing
-- Reporting and Analysis of Operational Events Enforcement History In addition to the above, Housekeeping and Control Room Behavior and Training and Qualification Effectiveness are also discussed.
A summary of the SALP ratings for the six areas and the remaining tcpics is shown in Table 2 below. Table 2 Summary of SALP Ratings Criterion Rating Management Involvement and Control in Assuring Quality 1 Approach to Resolution of Technical Issues 1 Responsiveness to NRC Initiatives 1 Operational Events 2 Staffing 1 Training 2 Housekeeping and Control Room Behavior 1 Enforcement History 2 Composite Rating 1
A. Management Involvement and Control in Assuring Quality During the SALP evaluation period, the licensee continued to show good
! management overview in the area of licensing activities. The' licensee consistently balances the licensee's desire to maintain or improve plant productivity with the need to protect the health and safety of the public. The majority of the licensing actions completed during the SALP period were resolved within the licensing group at Calvert Cliffs (or via technical experts utilized by the licensinggroup). In the few instances where matters were referred to the licensee s upper management, these individuals proved to be well informed and helpful in resolving questions of a corporate nature. For example, the licensee's Vice President for Supply was directly involved in the resolution of the Radiological Effluent Technical Specifications (RETS) and problems associated with Post-Accident Sampling. The licensee's management has also shown itself , to be innovative and fomard thinking. During the SALP period, the licensee 4
has (1) obtained a full 40 year operating license for Calvert Cliffs Nuclear Power Plant, Units 1 and 2; (2) worked diligently to establish an industry position on station blackout; and (3) requested a reduction in their emergency planning zone from 10 miles to 2 miles. 4 The licensee's submittals are most often timely and of high quality. Of particular note is the licensee's treatment of the "significant hazards consideration" standards of 10 CFR 50.92, " Issuance of amendments." During the SALP period, the licensee has substantially improved the way in which "significant hazards considerations" are addressed and now presents detailed safety cnalysis and plant-specific design information in addressing the standards of 10 CFR 50.92. Based upon the uniform and consistent performance of the Calvert Cliffs licensing group and the willingness of a knowledgeable upper management to get involved, as needed, a SALP rating of Category 1 is assigned to the criterion, " Management Involvement and Control in Assuring Quality". B. Approach to Resolution of Technical Issues from a Safety Standpoint The licensee continues to maintain a significant technical capability in almost all engineering and scientific disciplines necessary to resolve items of concern to the NRC and the licensee. The licensee continues to utilize the services of Combustion Engineering for accident analysis. The licensee, however, is improving its accident analytic capability and has submitted a j request for review and approval of a RETRAN model for Calvert Cliffs. The licensee has also established a probabilistic risk assessment capability that was evident in their requested contribution to NRC's Interim Reliability Evaluation Program. The NRC has also benefitted from the licensee's technical capabilities in the following areas, as a result of NRC's requests for comments and/or participation: j Seismic Qualifications of Equipment (USI A-46) Safety Implications of Control Systems (USI A-47) Pressurized Thermal Shock (USI A-49) i i i _ . _ _ _ _ _ ._. ..~ .._ _ _ _ .. _ _ _.._ _.. _ . _ _ _ . _ _ _
l . During the SALP period, the licensee has decided to relocate those technical staff members, still working at the Baltimore corporate offices, to Calvert Cliffs. A new building will house the technical staff. This move will further improve the on-site technical capability. The licensee's extensive technical capability is reflected in submittals in support of or in response to licensee or NRC initiated actions. Where additional information has been request ~d, e the licensee has in most cases promptly responded in a manner which resolves the issue. Few, if any, licensee responses to NRC requests for additional information require subsequent questions. Based upon the licensee's extensive technical capability and effective use of this resource, a rating of Category 1 is assigned to the criterion, " Approach to Resolution of Technical Issues from a Safety Standpoint". C. Responsiveness to NRC Initiatives The licensee continues to respond promptly to all NRC staff initiatives. During the SALP period, the licensee assisted the.NRC in res'olving a number of multiplant (generic) items and TMI Action 'ifems. In each case, the ' licensee has carefully evaluated the item in question to assure the degree of applicability to Calvert Cliffs. Where requirements are generic rather than plant-specific, the licensee has diligently negotiated changes in requirements to assure that the final requirements (e.g., Technical Specifications or equipment design) fully reflect the Calvert Cliffs plant design. In some cases, the licensee's upper management has been involved in final negotiations. In all cases where the licensee's position does not meet the final NRC position, the licensee has changed their position to achieve conformance. One example of the licensee's cooperation is the Technical Spec"ications for the Raactor Coolant System High Point Vents which were og.eed upon during the SALP period. Based upon the above, a rating of Category 1 is assigned to the criterion,
" Responsiveness to NRC Initiatives".
D. Operational Events Calvert Cliffs Unit 1 was in operation for 13-1/2 months of the 18 month SALP period. The licensee reported 25 non-security events per 10 CFR 50.72 to the NRC Operations Center during the report period. An additional 27 Licensee Event Reports (LERs) were received per 10 CFR 50.73. Approximately half of the reports involved equipment problems. Of the 25 non-security events, 7 involved unplanned reactor trips. Over 2/3 of the reactor trips involved personnel or maintenance errors, which is about twice the national average. A large majority of the trips (5) can be linked to the resumption of operation after a 4 month refueling outage. The unit's 4.8/ year reactor trip frequency compares favorably to the current national average frequency of 5.9 trips / plant / year.
l P i 6-0 Two events considered significant were reviewed in detail: the inoperability l
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of the unit's three Emergency Diesel Generators (EDGs) on May 26, 1985 due to the discovery of fatigue cracking in the rotor straps; and the repeated reactor trip breaker problems between February and July ~1985. Calvert Cliffs Unit 2 was in operation for 15-1/2 months of the 18 month SALP ! period. The licensee reported 18 non-security events per 10 CFR 50.72 to the NRC Operations Center during the report period. An additional 22 Licensee Event Reports (LERs) were received per 10 CFR 50.73. Approximately half of ! the reports involved equipment problems. Of the 18 non-security events, 5 involved reactor trips of which 4 were attributed to equipment problems. The unit's 3.5/ year reactor trip frequency is considerably l lower than the current national average frequency of 5.9 scrams / plant / year. The inoperability of the unit's three EDGs on May 26, 1985 was the single event considered significant.
- We conclude that the majority of events have been reported promptly and i
, accurately. While the reactor-trip frequency is well below average, the
- monthly rate of reported events (1.6 for Unit 1 and 1.0 for Unit 2) is extremely low. Based upon the above, a SALP rating of Category 2 for the criterion " Reporting and Analysis of Reportable Events," is appropriate.
E. Staffing
, The licensing group consists of a manager and five engineers, all of whom are degreed; the manager is a former reactor operator licensee. The relatively low turn over rate (all but one member _of the current licensing group has been employed in the group during the entire SALP period) and high productivity of this group has resulted in a successful licensing program. Submittals are most often complete, timely, and of high quality. A high degree of cooperation with the NRC is exhibited at all times. ;
f Based upon the above, a SALP rating of Category 1 for the criterion i " Staffing" is appropriate. t F. Training and Qualification Effectiveness 1 Members of the licensing group have received training in the following areas: FSAR and Technical Specifications , Calvert Cliffs Instructions (CCI) concerning licensing and safety issues. t Plant system In addition to the above, the vicensing group holds informal seminars on topics of current and future interest. The result of the training program is reflected in a licensing staff that is knowledgeable of plant design and the { impact of current and future NRC requirements. i,
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The licensing training program is being up graded to include the following areas: Simulator (on-site) Accident assessment Overview of plant transient response Degraded core behavior Process control system theory Integrated systems and control panels The above program is expected to be integrated into the training program during the next SALP period. Based upon the above, a SALP rating of Category 2 for the criterion " Training" is appropriate. G. Housekeeping and Control Room Behavior The licensee has demonstrated a desire to maintain a clean and efficient plant. The housekeeping at Calvert Cliffs is exemplary and plant tours usually show many areas to be recently cleaned and some areas freshly painted. During the SALP period, the control room panels have been repainted and panel mimics have been placed as-is or improved. The licensee also maintains an extensive tagging program. It should be noted that the clean-up/fix-up progress in some plant areas is the result of NRC rather than licensee initiatives. In this regard, the licensee should develop a more uniform standard for plant housekeeping. This situation notwithstanding, the licensee has promptly corrected almost all. housekeeping problems identified by the NRC. During the SALP period, the boric acid areas, the control room, and the diesel generator rooms were significantly improved with regard to housekeeping. With regard to control room behavior, the licensee continues to matntain a dress code for control room operators which adds to the professional atmosphere in the control room. During a number of observations, the control room appeared clean and reasonably quiet with a notable absence of unnecessary personnel. Areas in front of the control boards are kept clear to afford the operators an unobstructed view. The personal conduct of the operating staff has always been observed to be helpful and professional. Based upon the above, a SALP rating of Category 1 is assigned to
" Housekeeping and Control Room Behavior".
. -g-0 H. Enforcement History During the SALP period, one enforcement action was directly related to licensirg activities. The subject enforcement action involved the imposition of a civil penalty of $50,000 resulting from the inadequacy of the post accident sampling system (PASS).
On January 12, 1985, the NRC issued a safety evaluation concerning the
- licensee's PASS which consisted of a skid mounted unit purchased from
, Combustion Engineering. The licensee subsequently proposed Technical
- Specifications (TS), which were issued by the NRC on February 22, 1985, that were substantially more restrictive than required by the NRC. While the NRC had proposed PASS TS that addressed mostly programmatic aspects of PASS (training, procedures and maintenance), the licensee proposed and received NRC approval of TS with specific remedial actions (Limiting Conditions for Operation) and Surveillance Requirements. One key provision of the licensee's-PASS TS was the requirement for a back-up PASS capability when the primary (skid mounted unit) became inoperable.
During the NRC site inspections from June 24 to 28, 1985 and July 15 to i 19, 1985, the NRC determined that the licensee had neither a primary nor secondary PASS capability. The licensee giroved remiss from a licensing standpoint as a result of: ' Proposing excessively restrictive TS - The requirement for a backup system in the TS increased the severity of the noncompliance. The TS was proposed for an unproven system - The licensee should not have proposed the TS until the PASS had been shown to be reliable. . The above problems seem to indicate less than fully adequate communication between the operating and licensing staffs. The licensee should improve communications between operating and licensing staffs during the next SALP ! period. ' Based upon the above, and the review of enforcement actions and the j licensee's responses during the SALP period, a SALP rating of 2 is assigned ) to the criterion, " Enforcement History". 1 VI. Conclusion The licensee's licensing activities are conducted by a well staffed and well trained group resulting in an overall efficient operation. Management overview is obvious in that the licensing group is, for the most part, well
- integrated into other plant activities and licensing activities reflect a uniform approach. Upper management becomes directly involved in licensing J
+ actions only rarely to assist in resolving potential deadlocks. The licensee is to be commended for the diligent way in which multiplant (generic) and TMI Action Items are resolved and the willingness of the licensee to compromise when necessary to achieve agreement with NRC positions. Direct plant observations during the SALP period indicate that the plant is well maintained and.the , operating personnel are professional in appearance and demeanor. I
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_g_ o The licensee's greatest strengths appear to be in the following areas: Responsiveness to NRC Initiatives - The licensee's willingness to hold productive discussions with the NRC staff has resulted in the resolution of a significant number of multiplant action items and TMI action items. Management Involvement and Control in Assuring Quality - The licensee's submittals are of high quality with a noticeable improvement in the manner in which the licensee addresses the "no significant hazards considerations" criteria of 10 CFR 50.92. - The following area needs additional attention: Enforcement history - The licensee should assure proper communication between operations and licensing staffs to assure that equipment that is to be the subject of Technical Specifications is reliable. Based upon the evaluation of the above criteria, an overall SALP rating of Category 1 for the area of " Licensing Activities" is appropriate. 5 i
Enclosure 2 SALP EVALUATION FOR CALVERT CLIFFS NUEEEAR POWER PLANT SUPPORTING DATA AND
SUMMARY
- 1. NRR LICENSEE MEETINGS March 27, 1986 Reactor Coolant System High Point Vent Tech. Specs.
December 13, 1985 Main Steam Line Safety Valves - Setpoint Problems September 7, 1985 Control of Heavy Loads August 26, 1985 Post-Accident Sampling System July 10, 1985 Containment Purge and Vent Valves April 24, 1985 Masonry Wall Evaluation March 20, 1985 Reactor Coolant Pump Seal Cooling
- 2. NRR SITE VISITS March 20, 1986 Security Retraining and inspect plant housekeeping January 27, 1986 to January 31, 1986 Inspection of Boric Acid Subsystem Deceinber 5,1985 Inspect plant housekeeping September 23, 1985 to September 26, 1985 Inspect Spent Fuel Pool Cooling System August 26, 1985 Control Room Habitability Inspection July 19, 1985 Post-Accident Sampling System Inspections (exit interview)
June 24, 1985 Security Retraining and inspect plant housekeeping April 4, 1985 Inadequate Core Cooli g Instrumentation Inspection February 8, 1985 Inepect plant housekeeping January 16', 1985 Inspect MSIVs and obtain data on recent failures
- 3. COMMISSION BRIEFINGS None
- 4. SCHEDULAR EXTENSIONS GRANTED March 31, 1985 Environmental Qualifications schedule extension
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- 5. RELIEFS GRANTED l April 18, 1985 ASME Code - Common start for Calvert Cliffs Units 1 and 2 Programs May 20, 1985 ASME Code - Pressurizer Spray Line inspection September 18, 1985 ASME Code - Reactor Coolant Pump Weld inspection November 14, 1985 ASME Code - System pressure tests March 10, 1986 ASME Code.- Pump tests
- 6. EXEMPTIONS GRANTED January 8, 1986 Appendix J to 10 CFR Part 50 - ISI/ILRT Schedule
- 7. LICENSE AMENDMENTS ISSUED April 14, 1986 License Amendments 117 and 99 - Miscellaneous TS Changes (applications dated February 22, 1985 and October 25,1985)
March 31, 1986 License Amendment 116 (Unit 1) - Incore Detector TS February 20, 1986 License Amendments 115 and 98 - Containment Vent TS February 20, 1986 License Amendments 114 and 97 - Station Battery TS February 19, 1986 License Amendments 113 and 96 - Post-Accident Sampling System TS January 8, 1986 License Amendments 112 and 95 - ILRT/ISI Schedule December 31, 1985 License Amendments 111 and 94 - Diesel Generator TS (GL 84-15) December 30, 1985 License Amendments 110 and 93 - Organizational Charts December 9, 1985 License Amendments 109 and 92 - Miscellaneous TS Changes (application dated April 26, 1985) l l December 4, 1985 License Amendments 108 and 91 - Miscellaneous TS Changes (application dated June 28,1985) November 21, 1985 License Amendment 90 - (Unit 2) Cycle 7 Reload . 1 August 30, 1985 License Amendment 89 - (Unit 2) TS Changes in Support of Cycle 7 Reload August 26, 1985 License Amendments 107 and 88 - TS for RCS Leakage l
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. . 1 August 1,-1985 License Amendments 106 and 87 - Alternate STA l Qualifications 1 July 1, 1985 License ~ Amendments 105 and 86 - RETS (Effluent Monitoring)
May 20, 1985 , License Amendment 104 (Unit 1) - Cycle 8 Reload May 16, 1985 License Amendments 103 and 85 - Miscellaneous TS Changes (applications dated September 20, 1984 and ; January 31,1985) ' May 1, 1985 License Amendments 102 and 84 - License Expiration Dates March 7, 1985 License Amendments 101 and 83 - Revised TS for Halon Systems February 22, 1985 License Amendments 100 and 82 - RETS (Environmental Monitoring) February 22, 1985 License Amendments 99 and 81 - GL 83-37 (TS for TMI Action Items) February 14, 1985 License Amendments 98 and 80 - ILRT Schedule January 14, 1985 License Amendments 97 and 79 - Miscellaneous TS Changes (applications dated April 9, 1984 and June 29, 1984)
- 8. EMERGENCY TECHNICAL SPECIFICATIONS ISSUED None
- 9. ORDERS ISSUED July 16, 1985 Order Modifying License Confirming Additional Licensee Commitments on Emergency Response Capability (Supplement 1 to NUREG-0737) 1 I
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- 10. Status of Licensing Backlog At the conclusion of the SALP period, the licensing backlog donsisted of the following number of unresolved TMI related and plant-specific actions for each Calvert Cliffs unit:
TMI-related - 12 unresolved items Plant-specific - 4 unresolved items The status of multi plant action (MPA) items was as follows for each Calvert Cliffs unit: MPA - 5 unresolved items With regard to the above MPAs, there are no outstanding requests for additional information. 1 I
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