ML20235G409
| ML20235G409 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/21/1987 |
| From: | Mcneil S Office of Nuclear Reactor Regulation |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8709300031 | |
| Download: ML20235G409 (19) | |
Text
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Docket Nos. 50-317 DISTRIBUTION and 50-318 Docket File September 21, 1987 sNRCPDPE PDI-1 Rdg.
S. Varga MEMORANDUM FOR:
Thomas E. Murley, Director B. Roger Office of Nuclear Reactnr Regulation S. McNeil C. Vogan THRU:
Robert A. Capra, Acting Director J. Sniezek Project Directorate 1-1 L. Tripp Division of Reactor Projects, I/II J. Wiggins FROM:
Scott Alexander McNeil, Project Manager Project Directorate I-1 Division of Reactor Projects, I/II
SUBJECT:
NRR SALP REPORT FOR THE BALTIMORE GAS AND ELECTRIC COMPANY FOR CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 1
A copy of the draft NRR SALP Report addressing the Baltimore Gas A Electric Company as owner / operator of the Calvert Cliffs Nuclear Power Plant Units 1 and 2 from May 1, 1986 to August 31, 1987 is enclosed. The report includes I
Appendices that 1) provide an NRR summary overview of licensing activities at Calvert Cliffs, 2) discuss licensing activities with respect to each specific SALP performance rating criterion, and 31 provide the data summary of licensing actions and' activities for the course of the SALP rating period.
The licensee's performance in the SALP functional area of " Licensing Activities" is rated Category 2.
Also enclosed for your information is a sumary of the NPR 4
" Licensing Activities" ratings and the overall SALP ratings for the past two SALP evaluation periods.
We intend to transmit this report to Regicn I on September 25, 1987.
Signed Scott Alexander McNeil, Project Manager Project Directorate I-1 Division of Reactor Pro,iects, I/II
Enclosures:
f CVog i
SMcNe RCap LO 9/H )7 9/2/87
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r 8709300031 870921 PDR ADOCK 05000317 G
kJ NRR'S EVAUIATION OF LICENSING ACTIVITIES PERFORMANCE CRITERIA Category Category Proposed' Period of Period of
. Category 10/1/83 -
10/1/84 -
5/1/86 -
Criteria 9/30/84 4 /30 / 86 -
8/31/ 87 Management Involvement in l
Assuring Ouality 1
1 2
' Approach to Resolution of Technical Issues from a Safety. Standpoint 1
1 2
Responsiveness to.NRC Initiatives 2
1 2
Enforcement History-None 2
2 Operational Events
?
?
?
Staffing (Including Management)
None 1
2 Training and Qualification Effectiveness None
?
2 Housekeeping and Control Room Behavior None 1-N/A t
Overall 1
1 2
)
i l
i___.____..__.'__._._. _
i, r f
OyERALL FACILITY SALP PERFORMANCE Category Category Period of Period of Trend 10/1/83 -
10/1/84 -
2/1/86 -
Functional Area 9/30/84 4/30/86 4/30/86 A.
Plant Operations 1
2 Consistent B.
Chemistry and Radiological Controls 1
1.
Consistent C.
Maintenance 2
2 Consistent l
D.
Surveillance 2
1 Consistent E.
1 No Basis F.
Security and Safeguards 1
1 Consistent G.
Refueling, Outage Management and Engineering Support 1
2 No Basis H.
Licensing Activities 1
1 Consistent' I.
Assurance of Quality N/A 2
No Basis J.
Training and Qualification Effectiveness N/A 2
Consistent i
+
l 1
1
ENCLnSUPE 1 r
Licensing Activities During the SALP evaluation period of May 1, 1986 to August 31 -1987, there were a number of significant occurrences that had a decided impact upon the evaluation of the licensee in the functional area of " licensing activities".
These included 1) the degradation of the #12 emergency diesel generator 'EDG) which necessitated one exigent and two emergency Technical Specification (TS) amendment reouests, 21~the licensee's shift to a 24-month operating cycle,.
- 3) the licensee's discovery of their improper use of uncertified material replacement parts, and 4) the assignment of a new operating reactors project manager (ORPMI to Calvert Cliffs Units 1 and P.
In responding.to these occurences and to other issues and events over the course of the SAlp rating period, the licensee has shown nomally good management overview with respect to licensing activities. The senior engineering management actively participates in these actions by prioritizing these actions with the informal concurrence of the operations manager.
Assignment of priority is based upon the impact on current or future-planned plant operations and upon the licensee's perception of the sa'ety-significance of the item. Due to a steffing shortage, this prioritization scheme has had an adverse impact upon the timeliness of NRC recuested and required licensing activities as senior management has diverted manpower resources from these activities to those deemed by management to be more in the interest of the utility.
The licensee is in the process of developing a prioritization system for all plant specific and multi-plant licensing actions that will consider the NPC's view of the safety-significance and prinrity of the activity, The licensee has submitted this new system to the NRC for information purposes and has made 4
no commitment to actually follow this system in the perfomance of licensing activities.
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 reporting requirements. Several required reports were routinely filed late and some annually required reports (e.g., challenges to and failures of the pressurizer P0pV's and code safety valves) had not been filed for several years. Currently, no licensee unit is tasked with the responsibility for or the authority to ensure that these reports are submitted as required.
The licensee possesses significant technical capabilities in most of the I
engineering and scientific disciplines necessary to resolve issues of concern to the NRC and the licensee. However, thcse capabilities often have not been reflected in the cuality of the submittals provided to support licensee j
initiated actions or in response to NRC initiatives. Most of the license's evaluations of the significant hazards considerations were accurate though j
brief, thus routinely requiring additional infomation to,iustify the request.
]
Several instances of poor senior management review and/or flawed engineering i
judgement have occurred during this rating period. These instances included
- 1) a requested TS main steam isolation valve closure time limit for no steam
'e l
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flow conditions that would have placed the plant outside the analyzed bounds of the steam line break design basis event, ?) a change, unspecified in the licensee's submittal and unreviewed by the licensee's safety review comittees, l
to the NPC approved peak reactor coolant system (RCS1 pressure limit for the l
feedline break event from 1101 design RCS pressure to 120% design RCS pressure l
was made in the event's safety analysis to justify a proposed increase in the j
moderator temperature coefficient limit. 3) the, justification for continued Unit 1 operation with the existina flaw in the main steam line was technica1'y andregulatorilydeficient,and4)numeroustechnicalinconsistenciesand regulatory inadequacies were noted in the licensee's submittals of the exigent and the first of two emergency TS amendment requests for the #12 EDG.
Recently, marked improvement has been observed over the last six months with respect to management involvement in and the quality of the technical responses to nonreutine licensing activities, particularly the environment' qualification and replacement parts certi'ication deficiencies arising at Calvert Cliffs.
Further questionable,iudgement was indicated in the licensee's evaluation of the safety hazards of proposed TS amendment requests. Every amendment request submitted by the licensee during this period has been characterized as not presenting any possible significant hazards considerations with regards to the change In three instances, however, the NRC has detemined that characterizations of the amendment requests were not justifiable based upon technical facts and were circumspect at best.
l Generally, the licensee has responded to the NRC in a timely manner, particularly, in regards to requests for additional infomation made to obtain technical support for licensee requested activities. Response has not been as prompt in response to NRC issues of generic concem. The licenset has reauested extensions for responding to several NRC generic letters and has deferred action on SPDS operability, Dedicated Control Room Design Review and the annual FSAR update, However, licensee responses to NRC initiated issues are normally thorough and often technically superior.
R6 solution of licensing issues has often been marked by the licensee's determination not to yield on any points or issues unless proven to be technically or legally wrong or inferior in their stance. Though this can make resolution more difficult, it has often had the effect of ensuring a complete and thorouch discussion of the matter at hand, sometimes resulting in a superior product.
Licensing issues are carried out by three different groups in the Technical Services Engineering section of huelear Engineering Services.
Primary 3
NRC/ licensee interface has been with the Fuel Cycle Management Unit, which processes all TS amendment requests affected by fuel cycle design and the reactor vessel and internal components, as well as all associated topical reports, and the Licensing and Operational Safety Unit, which processes almost all LERs and all other TS amendment requests.
i
3 The Licensing l' nit is capably sta' fed though there has been a staff turnover of approximately 45" during this rating period. Though the level of experience has appreciably declined, this unit's work product has continually and significantly improved much due to the persistence and' dedication of the unit's sta'f and to the cuality.of training provided. This unit maintains an effective training program which is well maintained. NRC communications with the Licensinq linit are marked with good relations, a high degree of cooperation and a free exchange of information.
The Licensing Unit has actively sought to improve communications with the NRC.
The Fuel Cycle Mansgement Unit has an experienced staff with significant expertise in the technical issues of fuels management.
Staff turnover has been low. The quality of this unit's work product has remained adequate during this period with no significant. decline or improvement noted. Many tasks assigned to this unit remain incomplete over perinds of several years due to neglect.
The Fuel Cycle Management Facility Change Pequest (FCR1 process is used to initiate TS changes, core reloads and other related changes, modifications, test and experiments as permitted under 10 CFR 50.59. No FCRs have been completed by this unit since April 1983 though 24, including 5 core reloads and 10 TS cmendments (9 of which were approved by the NRC1 have been initiated since this date..The~ licensee attributes the failure to complete these tasks to insu'ficient manpower. The licensee also attributed this unit's failure to maintain its training records to this manpower shortage. Communications with this unit have been adequate though the staff has been hesitant to inform the NRC of problems with licensing actions in a timely manner.
In summary, the licensee's greatest strengths are the significant technical capabilities that it's staff possesses and the management's recently demonstrated determination to improve the quality of their licensing actions, as particularly demonstrated through the strides in performance level made by the Licensing and Operational Safety unit.
Still, improvement is needed 1) in the quality and level of management overview,
- 2) in the quality and comprehensiveness of the hazards analyses provided by the various engineering units to support licensing's development of justifications for TS amendment requests, and 3) in the staffing level required to permit 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.
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<fh NUCLEAR REGULATORY COMMISSION
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E'C050RE 2 Docket Nos. 50-317 a nd 318 FACILITY:
Calvert Cliffs Nuclear Power Plant LICENSEE:
Baltimore Gas and Electric Company EVALVATInN PERIOD: May 1, 1986 to August' 31, 1987 PROJECT MANAGER:
Scott Alexander McNeil I.-
INTPODUCTInN i
This report contains the results of the NRR evaluation of the licensee in the
" Licensing Activities" SALP functional area. This assessment was performed in accordance with NPR Office Letter No. 44, Revision 1, "NRR. Inputs to SALP Process," dated December 22, 1986 and NRC Manual Chapter 0516. " Systematic Assessment of Licensee Perfomance," dated July PS,1986.
II. SUWAR'Y OF RESULTS NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned-a, perfomance Category (Category 1, 2 or 3) based on a composite of a number of attributes. The perfomance of Baltimore Gas and Electric Company in the functional area " Licensing Activities" is rated Category 2.
III. CRITERIA The evaluation criteria used in this assessment are given in NRC Mar.ual Chapter 0516 Appendix, Table 1 " Evaluation Criteria with Attributes for Assessment of Licensee Perfomance."
IV. METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Pro,iect 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 perfomance criteria, as delineated in Chapter 0516, and assigned an overall rating Category (1, 2 or 3) to each criterion. The reviewers included this infomation as part of each Safety Evaluation prepared for Calvert Cliffs. The ORPM, after reviewing the SALP inputs of the technical reviewers,
l-
-P-combined this information with his own assess'nent of the licensee perforr.rnce and, usir.g appropriate weighting factors, arrived at a composite rating for the i
licensec. This rating also reflected the comments, if any, of +.he NRR Senior Executive. a'ssigned to the Calvert Cliffs Nuclear Power Plant SALP assessment.
A Written evaluation was ten prepared by the ORPM and circulated to NPP manrae-ment for coments.
The basis for this appraisal was the licensee's performance in support of licensing actions that were completed during the current rating period. There was a total of 32 active licensing actions for Unit 1 all of which were common to Unit 2, at the beginning of the rating period.
A total of 32 actions were add?d to the Unit I docket by the end of the rating period.
Four of these actions were specific to Unit 1 only, while the other 28 additional actions were shared by Unit 2.
Two actions specific to Unit 2 only, were ended to the docket during the rating period.
For Unit 1, 31 licensirg actions were closed during the rating period, leavir.g 3? active items, whereas, for Unit 2, 'o licensing actions were closed, leaving 3? active licensing actions.
All of the active licensing actions, with the exception of one item for each Unit, are common to both Units 1 and P.
These licensing actions consist of amendment requests, exemption reauests, relief requests, responses to generic letters THI Action items, and other miscellaneous actions as shown below and in Enclosure 3.
Multi-Plant Actions:
Thirteen were active for each Unit a the beginning of the SALP rating perind of which 6 have been closed for each Unit. Those completed actions were:
GL B3-?8, Items 1.2, 2.1, 3.1.3, 3.2.3, 3.P.3, and 4.5,2 10 CFP 50.61, Pressurized Thermal Shock Rule Plant Specific Actiony Seven were active for Unit I and 7 for Unit P at the beginning,of the SALP rating period. During the rating period, 32 actioris were added for Unit I and 30 actions were added for Unit 2, giving a total of 39 active actions on Unit 1 and 37 ective actions on Unit 2 (35 actions were common to both Units). Of these actions, 19 were closed for Unit I and 17 for Unit 2.
Sixteen of these actions were comon to both Units 1 and 2.
Some of the more significant completed plant specific actions included:
DFOST Outage Time MS!V Replacement Closure Time Moderator Temperature Coefficient Limit Relaxation (withdrawn)
Exigent Diesel Generator LCO Change Request Emergency Change; Tech. Spec for DG 12 l
Emergency Amendment: Refueling Without an EDG i
Request for ASME Code Relief for Main Steam Piping, Cycle 9 l
I w
i TMI~-(NUREG-0737)' Action Ittms:
For each Unit, of the 1* TMI Action items outstanding at beginning of the SALP rating period, 6 were completed durino the rating period, including:
III.A.1.? - TSC, 0$C and E0F
'll1.A.P.2 - Metet;rological Da ta Upgrade II.B.1
- RCS Vents II. F,1.1
- Noble Gas. Steam Monitors V.
ASSESSMENT OF PERFORMANCE AT~RIBUTES The licensee's performance evaluation is based on a consideration of the following seven evaluation criteria that were 'specified ir NRC Manual Chapter OM6:
Managemer.t involvement in Assuring Quality Approach to Resolution of Technical Issues from a Safety Standpoirt Responsiveness to NRC Initiatives l Enforcement History Operational Events Staffing (including Management)
Training and Qualification Effectiveness A summary of the SALP ratings for the seven rating criteria is shown in Table 1 below.
Table i SUMMAPY OF SALP PATIN35 Criterion Rating Management Involvement in Assuring Quality 2
Approach to the Resolution of Technical Issues from a Safety Standpoint 2
Responsiveness to NRC Initiatives 2
Enforcement History 2
Operational Events 2
i Staffing (including management?
2 Training and Qualification Effectiveness 2.
Composite Rating 2
- l. {,
A.
MANAGEMENT INVOLVEMENT IN ASSURING QUAtiTY During the SALP evaluation period, the licersee has shown h management overview in the area of licensing activities ~ with subst ormally scod
. efforts made over the last six months to improve the actual' q antial
-management involvement.
which activities to undertake, to defer or to cancelA vely deciding engineering managem
' Currently, senior operations manager,ent, significantly influenced by the impact en current or future-planned plant operations a d licensee's perception of the safety-significance of the a ti i n upon the c v ty.
The licensee's current prioritization system has had an imp of submittals and activities required by regulation, by Techni act on the timeliness (TSi, and for NRC multi-plant actions.
ecifications were deferred 'due to lack of adequate senior management concernM i
or due to a conscious management _ decision to utilize the manpo and attention elsewhere that were necessary to complete the activity.
1 delay requests sebmitted required very short NRC response tiSome r resources actions that were deferred during this period include Safety para nes. The licensing System (SPDS) operability, Dedicated Control Room Desig annual steam generator tube inservice inspection e er Display port,.and the In addition, inconsistent senior management attention'toward requirements was demonstrated through the NRC prompted rep s licensing licensee had not submitted the annual report of challenges t of the pressurizer PORV's and safety valves as required by TS a
e o and failures 1984 nor the annual financial reports required by 10 CFR 50 4 since 1979.
....c since ensuring licensee compliance with the various NRC and 10 CFR 50.71(b)
{
y of To effect corrective actions, the licensee is conducting rements.
which reporting requirements are applicable to Calvert Cliffs an audit to determine these reports actually are submitted and in a timely f q
and to verify that ashion.
The regulatory and technical quality of most routine li been adequate though most submittals have required additio information. However censing submittals has exigent and emergency, diesel generator TS amendment re main steam line flaw relief request, the submittels did not or the Unit I management review for either technical soundness or for regulat reflect adequate Marked improvement has been observed over the last six m management involvement in nonroutine issues, as management ha ory compliance.
onths with respect to active role in ensuring prompt, sufficient technical and regulat to licensing issues, particularly the environmental q a en a more parts certification difficulties, arising at Calvert Cliffs. qualification and o utions activities and the actions taken by manaOn the basis of th 7
s in licensing oversight of these licensing activities,gement to improve the qu'lity of their a
a rating of 2 is assigned in this area.
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B.
APPROACH TO RESOLUTION OF TECHNICAL ISSU engineering and scientific disciplinThe licensee posses M A SAFETY STANDPOINT capabilities in most of the contracts the services of Combustion Engineering In additico consultants for nuclear core design, accident analysithe lice other engineering resolution o' technical issues or the perfonnance s and to assist in the requiring a high degree of specialization.
of technical services Often, the licensee's technical capabilities h quality of the submittals provided to support licave not been reflected response to NRC requirements and requests o#
In reouesting TS amendments, mo accurate though brief.the licensee's evaluations of the significant h i
review was often required of the licensee to iAdditional explanato ea ed
, ustify the request.
hazards considerations, ore of which was subHowe s s were stated as having no significant justifiably o#
these significant hazards determination was sequently withdrawn, though the Furthermore, though sound engineering jud at best circumspect.
all licensing actions, there were instances of ob igement was de example of which included 11 that MSIV closure time was totally independe tvalve the licensee justified a main steam isolativ ously f on coefficient (MTC) TS limit, the licensee raised thv on the erroneous assumption t
of the steam flow across the n
feedline brea.k safety analysis from the NRC e moderator temperature approved value ofe event pressure limit for the reactor coolant (pCS) pressure to 120 pressure limit change was in no way ca% of design RCS pressure.110% of design it was obscured by the licensee's state lled to the attention of the NRCHowever, this not:
(1) involve a significant increase in the ment that "the proposed amendment would
, rather, the limits established by the analyses critan accident p probability or consequences of engineer did not infonn the plant operations andman eria." Furthermorepressures are within in obtaining m ttal, the re,sponsible design or the off site safety review committee (OSSRC) of thi (3) in requestinRCS pressure limit though it was an integr l safety review committee (POSRC) s change to the event's in not providing the infonnation specifi d bsteam a
the licensee's justification was methodology permit relief and (4) numerous technical incoy the ASME Code as requir cally deficient e
existed in the licensee's submittals for the exigent nsistencies and inadequacies emergency TS amendment requests for the No and the first of two Recently, in resolving the environmental q 12 e:nergency diesel generator (EDG).
certification deficiencies the licensee has demo voluntarily shut down Unit I and devoted sign nstrated en increasingly n
an exhaustive review of all systems and components thmanpower cance.
The licensee by improper environmental qualification or b pa rts.
y the use of uncertified replacementat
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' Based upon the technical, capability demonstrated by.the licensee over the I
Lcourse of the SALP rating period in'considering the safety significance of licensing activities, a Category 2.is assigned to this criterion.
i C.-
RESPONSIVENESS TO NRC INITIATIVES-1 The licensee has been generally timely in repsonding to-NRC staf f initiatives, j
particularly, requests for additional information in support 'of licensee requested TS changes. The licensee has requested extensions for responding to several.NRC generic letters and has' deferred action'on SPDS operability, DCPDD
.and the annual FSAR update.
However, licensee responses to NRC initiated issues are nomally' thorough and often technically superior.
Pesolution of licensing issues has o' ten been marked by the licensee's
-reticence to yield on any licensing issues.until demonstrated _to be in the wrong or in'erior. technical position.. However, this can be beneficial in
_ promoting the' exchange of ideas and technical information with the end result being a superior. ' produce. Normally, this licensee will change its position and accept a proposed issue resolution in.a fairly cooperative manner when technical reasoning supports such actions, though there have been exceptions where considerable NRC effort has been required.to obtain acceptable resolutions.
Based upon the.above -discussion,.a. Category 2 is assigned to this criterion.
D.
ENFORCEMENT. HISTORY The ORPM has had'the occasional opportunity to participate in onsite inspections and in enforcement conferences and other NRC-licensee management meetings..
- During the SALP rating period, two enforcement conferences were held, one concerning the isolation of the recirculation ~ actuation system level switches and the other dealing with-the licensee's environmental qualification deficiencies.
The fomer issue was mitigated to a level 4 violation and resolution of the latter is as of yet not complete.
Regarding the licensee's taking of appropriate and adequate corrective i
actions, this SALP period was marked by the licensee's reluctance and slowness in determining root'cause evaluations and in instituting effective, indepth corrective action for potential safety issues. This propensity was noted previously by the NRC in the licensee's last SALP (Report No. 50-317/84-99; 50-318/8499) dated September 18, 1986. An example of this was the slowness with which the licensee identified and took appropriate corrective action to repair.the No. 12 EDG.
Inspection Report 50-317/85-30, 50-318/85-32 dated January. 14, 1986 identified to the licensee.the outstanding deficiency on No.
12 EDG that CO.was~ leaking into the jacket cooling water system (MR#'s 009138 and 009415). No violation was given due to the previously demonstrated reliability of the EDGs but corrective action and a response were requested.
l The management did not direct the system engineer to investigate this i
deficiency until March 4, 1986 though the deficiency had been identified originally in September of 1985, a time span of 17 months. Over the last six months, the licensee has made strides in responding to issues requiring corrective action in a timelier and more adequate fashion. This was noted particularly in the licensee's corrective actions following discovery of the replacement parts certification deficiencies.
Consequently, a Category ? rating has been assigned to this criterinn.
E.
OPERATIONAL EVENTS Calvert Cliffs Unit I was in mode 1 operation for 11 months of the 16 month SALP period. The licensee submitted 18 Licensee Event Reports (LERsl during this period. Of these LERs, 5 were comon to Unit 2 but were reported for Unit I only. Approximately nne third of the reports involved equipment failures.
Of these LERs, 7 involved unplanned reactor trips. Of the total 18 LERs,11 involved personnel, procedural or maintenance errors with 4 reactor trips and 2 forced shutdowns resulting from these errors.
Calvert Cliffs Unit 2 was in mode 1 operation for 11-1/3 months of the 16 month SALP pe'riod. The licensee submitted 13 LERs during this period including 5 comon to' Unit 1.
Approximately one-half of these LERs involved equipment failures.
Eight of these LERs involved unplanned reactor trips. Of the total 13 LFRs, 6 involved personnel, procedural or maintenance errors with 3 reactor trips and 3 forced shutdowns resulting from these errors.
Unit 1 had a reactor trip average of 5.25 trips / year while the average for Unit 2 was 5.25 trips / year. The industry average for older plants in 1986 was approximately 4 trips / year.
The following 9 events and safety issues were considered to be significant enough to necessitate indepth NRC review:
Carbon monoxide in leakage into the jacket cooling water system of #12 EDG (Units 1 and 21 Pressurizer code safety valve setpoint drift (Unit 11 Environmental qualification deficiencies (Units 1 and 2)
Loss of shutdown cooling due to a pipe crack (Unit 2)
Breakdown of material control program (Units 1 and 2)
Inadvertent spraydown of containment (Unit li l
Inoperable dynamic response circuit in the reactor protection system delta T calculator (Unit 1)
Uncontrolled Boration (Unit 11 i
Total loss of offsite a.c. power (Units I and 2)
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]n addition, the resolution of some of these events has been the source of l
some concern in the NRC. Root cause determination has been slow and sometimes the event analyses are marginal.
For example, tbc licensee mitigated the safety consequences of the failure of the Unit 1 pressurizer code sa'ety valves to lift within their required setpoint banris /LER 87-006) by taking credit for operation of the power operated relief valves (PORVsi.
Yet, the PORVs are not recuired to be operable and unisolated during mode 1 operation ard are not environmentally qualified.
Without operable PORVs, the peak RCS i
pressures determined in the licensee's analyser of the feedline break event and loss of load events exceeded the design basis upset limit of 110% design RCS pressure.
Based upon the above, a Category ? rating has been assioned to this criterinr.
i F.
STAFFING (INCLUDING MANAGEMENT)
Licensing actions are carried out by three different groups in the Technical Services Engineering Section of Nuclear Engineering Services. The Licensing and Operational Safety Unit processes all LERs, almost all amendment request with the exception of those related to fuel cycle management (e.g., core reloads and reactivity control TS) and almost all responses to NRC initiatives, The Fuel Cycle Management Unit processes all TS amendment requests affected by the fuel cycle design, all reactivity control TS, all reactor vessel and vessel internals TS,'and all associated topical reports. The Analytical Support unit handles all licensing activities concerning computer analytical methodologies.
In all three units, job responsibilities are well defined and understood.
The Licensing Unit has had a fairly high turnover rate of approximately 45%
l during this SALP rating period.
The experience level has seen an appreciable decline during this period. Nevertheless, the presistence and dedication of the Licensing Unit's staff has resulted in a continually and significantly improving work product.
Communications with the Licensing Unit are marked with good relations, a high degree of cooperation and a free exchange of information between Licensing and the NRC which has been beneficial to both organizations in the processing of licensing actions. At the Licensing Unit's behest, face-to-face meetings are now being held at NRC headquarters on at least a quarterly basis between the Licensing Unit staff and the ORPM with the purpose of improving communications and speeding the resolution of licensing actions and other NRC items of concern.
The Fuel Cycle Management Unit has had a low turnover during this rating period. The experience level in this unit is quite high with significant expertise in the technical issues of fuels management. The quality of this unit's work product has remained adequate with no significant decline or improvement noted. Many assigned tasks remain incomplete over periods of several years. An example is the Fuel Cycle Management Facility Change
(.m Pequest (FCR) process through which this unit initiates T5 changes, core reloads.and other related modifications. changes, tests or experiments as
' permitted in'10 CFP 50.59.
No FCRs have been completed by this unit since April 1983; though 24, including 5 core reloads and 10 TS amendments (9 of which were approved by the NRC and 1 was withdrawn) have been initiated since then. When asked for an explanation,. licensee management stated that these. tasks could not be properly completed because this unit had insufficient manpower to perform and complete all the tasks assigned to it._ The licensee 1
the also. attributed the manpower shortage as the cause for this unit's failure to maintain its reovired training records.
Communications between this unit and the NRC have been adequate though the staff was hesitant on one occasion to inform the NDC of errors in the Unit ?
Cycle 8 reload report,. thus necessitating reissuance of the associated NPC safe'ty evaluation.
The NRC has.had little interface with the Analytical Support Unit over this period with the exception of reviewing the licensee's RETRAN topical report submi ttal. This review process demonstrated significant technical expertise i
'with regards to this licensing action.
Comm'unications with this unit were generally good though difficulties arose j
over this unit's repeated phone calls to the NRC contractor performing the J
review and tq the.NRR technical reviewer without the knowledge or concurrence l
and over the objections of the ORPM. This communication problem still existed d
at the end of.the SALP period.
Based upon the above, a SALP rating of Category 2.for this criterion would be appropria te.
G.
TRAINING AND QUALIFICATION EFFECTIVENESS The Technical Services Engineering Units hold training in the following areas:
FSAR and TS Calvert Cliffs Instructions (CCI) concerning licensing and safety issues Plant systems Seminars on topics of current industry licensing interest Chernobyl lessons learned Plant industrial safety Official records are required to be maintained to document this training of the units personnel.
In addition, each staff member has qualification cards with certain technical tasks and areas of knowledge required to be perfomed or 4
learned. These items can become an element in that individual's job 1
perfomance ratings for the year.
Individuals cannot perfom job tasks l
associated with their required qualification factors until they'are perfomed i
at least once under the supervision of a staff member qualified in that factor.
i 1
The Technical Services Engineering training records for the Fuel Cycle Managernent linit were examined in November 1986. At this time, licensee i
management was informed that these records were not up to date and that corrective action was necessary. By the end of this SAlp rating period, the i
appropriate corrective action had not been instituted by the licensee. The reason given was a staff manpower shortage in this unit.
Based upon the above discussion, a SALP rating of Category ? is assigned to this area.
.VI.
CONCLUSION The licensee's licensing activities are conducted by a dedicated, knowledgeable and generally well trained staff whose overall performance has improved over.the course of the rating period. Management overview has been evident in the prioritization of licensing activitie:; and has seen particular improvement in the quality ar.d level of attention provided over the last six months.
The licensee has many strengths with regard to the performance of licensing activities, the most notable of which are:
The degree of technical capability present in the licensee's staff Management's recently demonstrated determination to improve the quality of their licensing actions The dedication demonstrated by the Licensing and Operational Safety Unit in consistently striving to improve their performance even during a period of high personnel turnover and numerous, significant, time consuming safety issues and events.
The following areas need attention:
Management should continue to expand the scope and improve the quality of their overview of licensing activities Ipprove the quality and comprehensiveness of the hazards analyses provided by the various engineering units to support Licensing's development o', justifications for TS amendment requests Provide staffing of adequate levels to permit response to NRC safety i
L initiatives in a more timely fashion and to permit the staff to perform all tasks that are required, particularly for Fuel Cycle Management l
Based upon the preceeding evaluation of the SALP criteria, an overall SAlp rating of Category 2 is assigned to the " Licensing Activities" functional area, t
l ENCLOSUPE 3 RECORD OF PEETINGS AND OFFICIAL DOClHENTS 1.
NRP/Licensec Meetings September 19, 1986 Pequest for Emergency TS Amendment;
- 1 EDG 9eptember 26, 1986 24-month Cycle Reload October 3,1986 CO Inleakage into #12 EDG Jacket Cooling Water System December 10, 1986 Unit 1 Main Steam Line Flaw January 7,1987 Future Licensing Actions May 5, 1987 Materials Qualification Deficiencies 2.
NRR Site Visits /Feetings July 14, 1986 Site Familiarization and Trainina for New ORPM July 18; 1986 SALP Meeting August 1,1986 Discuss Licensing Actions Status August 7, 1986 Investigate #12 EDG C0 Inleakage October 2,1986 Followup Infomation on #12 EDG November 3-7, 1986 Containment Integrity Inspection April 1, 1987 ATWS Modification Review May 11-15, 1987 Restart Inspection (Joint Region I/
NRR Team)
June 10, 1987 Steam Generator Tube ISI Amendment Request August 10-26, 1987 OSART 3.
Comission Meetings None 4
h SJ edular Extensions Granted September 30, 1986 Order for Operable diPDS, Units 1 and 2
qq.
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5.
Beliefs Granted l
It 1
h j' March 26, 1987-ASME Section.X1 Relief - Unit 1 Main
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Steam Line. Flaw i
May 11, 1987 ASME Section X1 Relief - Units 1 and 2 Class 1 and 2 Bolting and Cnntrol Rcd i
Drive Housings j
i
.May 29, 19,87 ASME Section XI Temporary Relief -
Unit 2 Auxiliary Feede ter Hydrostatic
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g Test s-
.6.
Exemptions Granted l
None 7.
Exigent / Emergency Actions Granted i
September 8, 1986 Exigent Diesel Generator LCO Change Request September 23, 1986 Emergency Change; TS for DG l' i
November 28, 19P5 Emer9ency Amendment: Refueling without
(
an EDG B..
[censeAmendmentsIssued Amendment Number Da te Unit 1 Unit 2 Title June 17, 1986 118 100 Miscellaneous TS Changes (applicated dated January 20, 1986)
June 30,1986 119 101 Miscellaneous TS Charges (applications dated December 22 1983 and October 25, 1985) s
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August 6, 1986-120 102 Miscellaneous TI Changes f application dated April 14,1986)
September 8,1986 121 103 Exigent Diesel Generator a
LCO Change Request
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September 23, 1986 122 104 Emergency Change; TS for DG IP 4
October 6,1986 123 105 DFOST Outage Time U: :-
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Amendment Number
- Date Unit 1 Unit 2 Title November 28,-1986 124 Fnergency Amendment: ' Refueling Without an EDG December 19, 1986 125 106 RCP Flywheel inspections /
Snubber Table Deletion February 25, 1987 126 MSIV Replacement Closure Time April 29, 1987 107 MSTV Replacement Closure Time June 30, 1987 108 Unit 2 Cycle 8 Reload Request' July 7, 1987 127 109 CEA Misalignment / Purge Valve Isolation Response Tire 9.
Orders Issued September 30, 1986 Modification of Order on Emergency Response Capability Schedules (Generic Letter 82-33) providing a schedular extension for SPDS Operability.
1.
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