ML20235G411
| ML20235G411 | |
| 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: ML20235G411 (19) | |
Text
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Docket Nos. 50-317 DISTRIBUTION and 50-318 Docket Filem September 21, 1987 NRCPDR PDI-1 Rdg.
S. Varga MEMORANDUM FOR:
Thomas E. Murley, Director B. Boger Office of Nuclear Reactor Regulation S. McNeil C. Vogan THRU:
Robert A. Capra, Acting Director J. Sniezek Project Directorate I-1 L. Tripp Division of Reactor Projects, I/II J. Wiggins FROM:
Scott Alexander McNeil, Project Manager Project Directorate I-I Division of Reactor Projects, I/II
SUBJECT:
NRR SALP REPORT FOR THE BALTIM0RE GAS AND ELECTRIC COMPANY FOR CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 A copy of the draft NRR SALP Report addressing the Baltimore Gas & Electric Company as owner / operator of the Calvert Cliffs Nuclear Power Plant Units I and 2 from May 1, 1986 to August 31, 1987 is enclosed. The report includes Appendices that 1) provide an NRR summary overview of licensing activities et Calvert Cliffs, 2) discuss licensing activities with respect to each specific l
SALP performance rating criterion, and 3) provide the data summary of licensing actions and activities for the course of the SALP rating period. The licensee's l
performance in the SALP functional area of " Licensing Activities" is rated l
Category 2.
Also enclosed for your information is a summary of the NRR
" Licensing Activities" ratings and the overall SALP ratings for the past two SALP evaluation periods.
We intend to transmit this rep 1rt to Region I on September PS, 1987.
Signed Scott Alexander McNeil, Project Manager Project Directorate I-1 Division of Reactor Pro,iects, I/II
Enclosures:
As stated d
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NRR'S EVAUIATION OF LICENSING ACTIVITIES PERFORMANCE CRITERI A 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 Assuring Ouality 1
1-2 Approach to Resolution of Technical Issues from a Safety Standpoint
.i 1
1 2
Responsiveness to NRC Initiatives
'2 1
2 Enforcement History None P
2 Operational-Events
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?
2 Staffing (Includ'ns' Management)
None 1
2 Training and Qualification Effectiveness None
?
2 Housekeeping and Control Room Behavior None 1
N/A 4
Overall 1
1 2
1 1
)
0 I
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_0VERALL 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 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 1.
Assurance of Quality N/A 2
No Basis J.
Training and Qualification Effectiveness N/A 2
Consistent
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l ENCLnSUPE 1 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 evelvation 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 reauests, 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 41 the assignment of a new operating reactors project l
manager (ORPPI 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 i
management overview with respect to licensing activities. The senior engineering management actively participates in these actions by prioritizing l
these actions with the informal concurrence cf 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 safety-significance of the item. Due to a staffing shortage, this prioritization scheme has had an adverse impact upon the timeliness of NRC reouested 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 NRC's view of the safety-significance and priority of the activity. The licensee has submitted this new system to the NRC for information purposes and has made 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 rout"ely filed late and some annually required reports (e.g., challenges to and failures of the pressurizer POPV's and code safety valves) had not been 1
filed for several years. Currently, no licensee unit is tasked with the I
responsibility for or the authority to ensure that these reports are 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, these capabilities often have not been reflected in the cuality of the submittals provided to support licenset initiated actions or in response to NRC initiatives. Most of the license's evaluations of the significant hazards considerations were accurate though brief, thus routinely requiring additional information to,iustify the request.
Several instances of poor senior management review and/or flawed engineering judgement have occurred during this rating period. These instances included
- 1) a requested TS main steam isolation valve closure time limit for no steam l
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2 flow conditions that would have placed the plant outside the analyzed bour.ds 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, to the NPC approved peak reactor coolant system (RCS1 pressure limit for the j
feedline break event from 110% design RCS pressure to 120! design RCS pressure was made in the event's safety analysis to justify a proposed increase in the i
moderator temperature coefficient limit, 3) the, justification for continued Unit 1 operation with the existina flaw in the main steam line was technica1'y and regulatorily deficient, and 4) numerous technical inconsistencies and regulatory inadequacies were noted in the licensee's submittels 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 nonroutine licensing activities, particularly the environment' qualification and replacement parts certi'ication deficiencies arising at Calvert Cliffs.
1 Further questionable,iudgement was indicated in the licensee's evaluation of the safety hazards of proposed TS amendment requests. Every amendment request I
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 determined that characterizations of the amendment requests were not justifiable based upon technical facts and were circumspect at best.
Generally, the licensee has responded to the NRC in a timely manner, particularly, in regards to requests for additional infonnation made to obtain technical support for licensee requested activities.
Response has not been as prompt in response to NRC issues of generic concera. The licensee 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 of ten technically superior.
Resolution 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 thorouoh 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 Nuclear Engineering Services.
Primary 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.
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The Ldcensing l' nit is capably sta# fed though there has been a staff turnover o' apgoximately 45t during this rating period. Though the level of experience has appreciably declinec', this unit's work product has continually and significantly improvec' much due to the persistence and dedication of the unit's sta'f and to the quality of training provided. This unit maintains an effective training program which is well maintained.
NRC communications with the Licensing linit are marked with good relations, a high degree of cooperation ard a free exchange of information. The Licensing Unit has actively sought to improve communications with the NRC.
The fuel Cycle Management 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 tatks assigned to this unit remain incomplete over periods of several years due to neglect.
The Fuel Cycle Management Facility Change Pequest (FCRI process is used to initiate TS changes, core reloads and other related changes, modifications, test and experiments as pemitted under 10 CFR 50.59.
No FCRs have been completed by this unit since April 1083 though 24, includin amendnents (9 of which were approved by the NRC) g 5 core reloads and 10 TS 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 infom the NRC of problems with licensirig actions in a timely manner.
In sumary, 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 pemit response to NRC initiatives in a more timely fashion and to pemit the staff to perfom all tasks that are required, particularly for Fuel Cycle Management,
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ENCLOSURE 2 Dor %t Nos. 50-317 and 50-318 FACILITY:
Calvert Cliffs Nuclear Power Plant LICENSEE:
Baltimore Gas and Electric Company EVALVAT]nN PERTOD: May 1, 1986 to August 31, 1987 PRO.1ECT MANAGER:
Scott Alexander McNeil I.
INTPODUCTInN This report contains the results of the NRR evaluatinn of the licensee in the
" Licensing Activities" SALP functional area. This assessment was performed in accordarce 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 Performance," dated July 75, 1986.
II. SUW.ARY 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 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 Manual Chapter 0516 Appendix, Table 1. " Evaluation Criteria with Attributes for Assessment of Licensee Performance."
IV. METHODOLOGY This evaluation reoresents 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 performance 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,
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combined this information with his own assessment of the licensee perferr.ence and, using appropriate weighting factors, arrived at a composite rating for the licensec. This rating also reflected the comments, if any, of the NPR Senior Executive assigned to the Calvert Cliffs Nuclear Power Plant SALP assessment.
A written evaluation was ten prepared by the ORPM and circulated to NPP manaae-ment for comments.
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 added 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 added to the docket during the rating period.
For Unit 1, 31 licensing actions were closed during the rating period, leaving 32 active items, whereas, for Unit 2, 29 licensing actions were closed, leaving 32 active licensing actions. All of the active licensing actions, with the exception of one item for each Unit, are comon to both Units 1 and 2.
These licensing actions consist of amendment requests, exemption reouests, 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 83-2$, Items 1.2, 2.1, 3.1.3, 3.2.3, 3.2.3, and 4.5.?
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10 CFR 50.61, Pressurized Thermal Shock Rule Plant Specific Actions:
Seven were active for Unit 1 and 7 for Unit ? at the beginning of the SALP rating period. During the rating period 32 actions were added for Unit 1 and 30 actions were added for Unit 2, giving a total of 39 active actions on Unit I and 37 active actions on Unit 2 (35 actions were common to both Units). Of these actions,19 were closed for Unit 1 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 MSIV Replacement Closure Time l
Moderator Temperature Coefficient Limit Relaxation (withdrawn)
Exigent Diesel Generator LCO Change Request 1
Emergency Change; Tech. Spec. for DG 12 Emergency Amendment: Refueling Without an EDG Request for ASME Code Relief for Main Steam Piping, Cycle 9 1
4.,
i TMI (NUREG-0737) Action Items:
For each unit, of the l' TMI Action items outstanding at beginning of the SALP i
rating period, 6 were completed during the rating period, including:
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TSC, OSC and EOF III.A.P.2 - Meteorological Data Upgrade II.R.1
- RCS Vents II.F.1.1
- Noble Gas Steam Monitors V.
ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of the following seven evaluation criteria that were specified in NRC Manuel Chapter 00 6:
Management Involvement in Assuring Quality Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives Enforcement History Operational Events Staffing (including Management)
Training and Qualification Effectiveness A sununary of the SAlp ratings for the seven rating criteria is shown in Table 1 below.
Table 1 SUMMAPY OF SALP RATINGS 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
Staffing (including management) 2 Training and Qualification Effectiveness 2
Composite Rating 2
I.
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A.
PANAGEMEN1 INVOLVEMENT IN ASSURING QUALITY During the SALP eva'uation period, the licensee has shown management overview in the area of licensing activities with normally scod efforts made over the last six months to improve the actual qua substantial manaaerent involvement.
y of which activities to undertake, to defer or to cancelAt ng by actively deciding engineering managem operatinns manager,ent, significantly influenced by Currently, senior the impact on current or future-planned plant operation licensee's perception of the safety-significance of th s and upon the e activity.
of submittals and activities required by regulationThe n impact on the timeliness (TSi, and for NRC multi-plant actions.Many of these submittals and activitie were deferred due to lack of adequate senior management conc or due to a conscious management decision to utilize the manpow elsewhere that were necessary to complete the activity ern and attention delay requests submitted required verv short NRC respons Some of resources System (SPDS) operability, Dedicated Control Ro e tines. The licensing arameter Display annual steam generator tube inservice inspection eview (OCRDR), the report, and the In addition, inconsistent senior management attention towa d requirements was demonstrated through the NRC prompted repo r s licensing licensee had not submitted the annual report of challen of the pressurizer 00RV's and safety valves as required by TS r
at the ges to 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) j requirements.
k ty of To effect corrective actions, the licensee is conducti l
which reporting requirements are applicable to Calvert Cliffng an au these reports actually are submitted and in a timely f s and to verify that ashion.
The regulatory and technical quality of most routin been adequate though most submittals have required additie licensin informa tion. However exigent and emergency, diesel generator TS amendment r main steam line flaw relief request, the submittals did not n
management review for either technical soundness or for reg l t or the Unit I re' lect adequate Marked improvement has been observed over the last u a ory compliance.
management involvement in nonroutine issues, a six months with respect to to licensing issues, particularly the environmentalas taken a more i
parts certification difficulties, arising at Calvert Cliffqualification and replac a ory solutions j
activities and the actions taken by manaOn the basis of th s,
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s in licensing oversight of these licensing activities,gement to improve the quality of their a rating of 2 is assigned in this area.
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APPDOACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT f
The licensee possesses significant technical capabilities in most of the engineering and scientific disciplines necessary to resolve safety issues of concern to the NRC and the licensee.
In addition, the licensee frequently contracts the services of Combustion Engineering and other engineering l
consultants for nuclear core design, accident analysis and to assist in the i
resolution of technical issues or the performance of technical services i
requiring a high degree of specialization.
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Often, the licensee's technical capabilities have not been reflected in the l
quality of the submittals provided to support licensee initiated actions or in response to NRC requirements and requests.
In reouesting TS amendments, most o' the licensee's evaluations of the significant hazards considerations were accurate' though brief. Additional explanatory information and more detailed review was of ten required of the licensee to,iustify the request.
However, three of. these TS amendment requests were stated as having no significant I
hazards considerations, ore of which was subsequently withdrawn, though the justifiably of these significant hazards determination was at best circumspect.
Furthermore, though sound engineering judgement was demonstrated through almost all licensing actions, there were instances of obviously flawed,iudgement, example of which included li the licensee justified a main steam isolation valve (MSIV) <:losure time TS amendment request upon the erroneous assumption that MSIV closure time was totally independent of the steam flow across the valve seat, 21 to support a requested increase in the moderator temperature coefficient (MTC) TS limit, the licensee raised the event pressure limit for the feedline break safety analysis from the NRC approved value of 110% of design reactor coolant (RCS) pressure to 120% of design RCS pressure. However, this pressure limit change was in no way called to the attention of the NRC, rather, it was obscured by the licensee's statement that "the proposed amendment would not:
(1) involve a significant increase in the probability or consequences of an accident previously analyzed... the resultant peak RCS pressures are within the limits established by the analyses criteria." Furthermore, in obtaining management approval for the amendment request submittal, the responsible design engineer did not infom the plant operations and safety review committee (POSRC) j l
or the off site safety review comittee (OSSRC1 of this change to the event's j
RCS pressure limit though it was an integral part of the amendment request, (3) in requesting relief from Section XI of the ASME Code for a Unit I main steam line flaw, the licensee's justification was methodologically deficient in not providing the infomation specified by the ASME Code as required to
- permit relief and (4) numerous technical inconsistencies and inadequacies existed in the licensee's submittals for the exigent and the first of two emergency TS amendment requests for the No.12 emergency diesel generator (EDG).
Recently, in resolving the environmental qualification the replacement parts j
certification deficiencies the licensee has demonstrated an increasingly
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conservative approach with regards to safety significance. The licensee voluntarily shut down Unit I and devoted significant manpower to performing an exhaustive review of all systems and components that could ha've been impacted by improper environmental qualification or by the use of uncertified replacement parts.
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LBased upon the technical. capability demonstrated by the licensee over the t
. course of. the SALP rating period in considering the safety significance of licensing activities, a Ca+egory 2 is assigned to this criterion.
C..
RESPONSIVENESS-TO NRC INITIATIVES-The' licensee has been generally timely in repsonding to NRC staff initiatives, particul_arly, 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 nonnally thorough and often technically superior.
1 Pesolution of licensing. issues has often 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 i
where considerable NRC effort has been required to obtain acceptable resolutions.
Based upon.th'e above discussion, a Category 2 is assigned to this criterion.
1 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 fonner 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 actions, this SALP period was marked by the licensee's reluctance and slowress 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.
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12 EDG that CO was leaking into the jacket cooling water system _(MRW's 009138 l
and 009415). No violation was given due to the previously demonstrated reliability of the EDGs but corrective action and a response were requested.
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.The management.did'not direct the system engineer'to investigate this deficiency unti1~ 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 (LERsi-during
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this period. Of these LERs, 5 were comon to Unit 2 but were reported for 1
Unit 1 only. Approximately one third of the reports involved equipment
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. failures.
.0f.these LERs, 7 involved unplanned reactor. trips. Of the total 18 LERs,11 g
ir.volved 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 period. The licensee submitted 13 LERs during this period including 5 common to Unit 1.
Approximately one-half of these LERs involved a
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 I 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.
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The following 9 events and safety issues were considered to be significant
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enough to necessitate indepth NRC review:
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' Carbon monoxide in leaksge into the jacket cooling water system of #12 EDG (Units-1 and 2)
Pressurizer code safety valve setpoint drift (Unit II 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 j
Inoperable dynamic response circuit in the reactor protection system i
delta T calculator (Unit 1)
)
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Uncontrolled Roration (Unit II l
Total loss of offsite a.c. power (Units 1 and 2) z
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l f In addition, the resolution of some of these events has been the source of some concern in the NRC. Root cause determination has been slow and sometimes the event analyses are trarginal.
For example, tFe licensee mitigated the safety consequences of the failure of the Unit 1 pressurizer code sa'ety valves to lift within their required setpoint bands /LER 87-006) by taking
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credit for operation of the power operated relief valves (PORVs'.
Yet, the j
PORVs are not recuired to be operable and unisolated during mode 1 operation ard are not environmentally qualified. Without operable PORVs, the peak RCS pressures detemined 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.
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 TS1 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%
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 infomation 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
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I Pequest (FCR) process through which this unit initiates TS 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 i
April 1983; though 24, including 5 core reloads and 10 TS amendments (9 of q
which were approved by the NRC and I 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 l
manpower to perform and comp 7ete all the tasks assigned to it. The licensee 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 NPC have been adequate though the staff was hesitant on one occasion to inform the NDC of errors in the Unit P Cycle 8 reload report, thus necessitating reissuance of the associated NPC safety 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 submittal. This review process demonstrated significant technical expertise with regards to this licensing action.
Communications with this unit were generally good though difficulties arose over this unit's repeated phone calls to the NRC contractor performing the review and to the NRR technical reviewer without the knowledge or concurrence and over the' objections of the ORPM. This communication problem still existed at the end of the SALP period.
Based upon the above, a SALP rating of Category 2 for this criterion would be appropriate.
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 Saninars 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 performed or learned. These items can become an element in that individual's job performance ratings for the year.
Individuals cannot perform job tasks associated with their required qualification factors until they are performed at least once under the supervision of a staff member qualified in that factor.
. 4-The Technical Services Engineering training records for the Fuel Cycle Management Unit were examined in November 1986. At this time, licensee
- 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 appropriate corrective action had not been instituted by the licensee.
The l
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 activities and has seen particular improvement in the quality and 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:
1 The degree of technical capability present in the licensee's staff Management's recently demonstrated determination to improve the quality of their licensing actions 1
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:
i Management should continue to expand the scope and improve the quality of their overview of licensing activities Inprove 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 Provide staffing of adequate levels to permit response to NRC safety initiatives in a more timely fashion and to permit the staff to perform all tasks that are required, particularly for Fuel Cycle Management Based upon the preceeding evaluation of the SALP criteria, an overall SALP rating of Category 2 is assigned to the " Licensing Activities" functional area.
I i
l ENCLOSURE 3 RECORD OF MEETINGS ANP OFFICIAL DOCUMENTS i
l 1.
NPP/Licensec Peetings September 19, 1986 Pequest for Emergency TS Amendment;
- 1? EDG 9eptember 26, 1986 24-month Cycle Reload October 3,.1986 C0 Inleakage into #12 EDG Jacket Cooling Water System December 10, 1986 Unit 1 Main Steam Line Flaw Janua ry 7,1987 Future Licensing Actions l
May 5, 1987 Materials' Qualification Deficiencies 2.
NRR Site Visits /Feetings July 14, 1986 Site Familiarization and Training for New ORPM l
July 18, 1986 SALP Meeting l
August 1, 1986 Discuss Licensing Actions Status August 7, 1986 Investigate #12 EDG CO Inleakage October 2, 1986 Followup Information on #12 EDG November 3-7, 1986 Containment Integrity Inspection April 1, 1987 ATWS Modification Review
)
l May 11-15, 1987 Restart Inspection (Joint Region I/
l NRR Team)
Ste'm Generator Tube ISI Amendment l
June 10, 1987 a
Request August 10-28, 1987 OSART 3.
Comission Meetings None
's 4.
Schedular Extensions Granted September 30, 1986 Order for Operable SPDS, Units 1 and 2
}.
5.
Reliefs Granted March 26, 1987 ASME Section XI Relief - Unit 1 Main Steam Line Flaw May 11, 1987.-
ASME Section XI Relief - Units 1 and 2 Class 1 and 2 Bolting and Cnntrol Rod Drive Housings May 29, 1987 ASME Section XI. Temporary Relief -
Unit 2 Auxiliary Feedwater Hydrostatic Test B
'6.
Exemptions Granted None 7.
Exigent / Emergency Actions Granted September 8,1986 Exigent Diesel Generator LC^ Change Request September 23, 1986 Emergency Change; TS for DG 10
-November 28, 1986 Emergency Amendment: Refueling without an EDG 8..
License Amendments Issued Amendment Number Da te Unit 1 Unit 2 Title June 17, 1986 118 100 Miscellaneous TS Changes.
(applicated dated January 20, i
1986)
'l June 30,1986 119 101 Miscellaneous TS Charges (applications dated December 22, 1983 and October 25, 1985)
August 6, 1986 120 102 Miscellaneous TS Changes (application dated April 14,1986)
September 8, 1986 121 103 Exigent Diesel Generator LCO Change Request September 23, 1986 122 104 Emergency Change; TS for DG IP October 6,1986 123 105 DFOST Outage Time l
l
i Amendment Number Date linit 1 Unit 2 Titl e November 28, 1986 124 Energency Amendment:
Pefueling Without an EDG December 19, 1986 125 106 RCP Flywheel Inspections /
l Snubber Table Deletion Februa ry 25, 1987
'126 MSIV Replacement Closure Time April 29,'1987 107
'MSIV Replacement Closure Time June 30, 1987 108 Unit 2 Cycle 8 Reload Request July 7, 1987 127 109
.CEA Misalignment /Pur9e Valve Isolation Response Time 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.
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