ML20235G696

Forwards Draft NRR SALP Input for Review.Comments Received by 870924 Will Be Considered for Incorporation in Final Rept

ML20235G696
Person / Time
Site:	Calvert Cliffs
Issue date:	09/21/1987
From:	Mcneil S Office of Nuclear Reactor Regulation
To:	Miraglia F, Starostecki R, Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8709300160
Download: ML20235G696 (18)

Text

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DISTRIBUTION

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p September 21, 1987 Docket File PDI-1 Rdg.

C. Vogan S. McNeil Docket Nos. 50-317 J. Sniezek and 50-318 MEMORANDUM FOR:

Frank J. Miraglia, Associate. Director i

for Projects i

Steven A. Varga, Director Division of Reactor Projects I/II Bruce A. Boger, Assistant Director for Region I Reactors Division of Reactor Projects I/II Richard W. Starostecki, Associate Director for Inspection and Technical Assessment Lawrence Shao, Director Division of Engineering and System Technology Charles E. _ Rossi, Director Division of Operational Events Assessment i

James G. Partlow, Director Division of Reactor Inspection and Safeguards Frank Congel, Director Division of Radiation Protection and Emergency Preparedness Jack W. Roe, Director Division of Licensee Performance and Quality Evaluation THRU:

Robert A. Capra, Acting Director Project Directorate I-I Division of Reactor Projects I/II FROM:

Scott Alexander McNeil, Project Manager Project Directorate I-1 Division of Reactor Projects I/II

SUBJECT:

DRAFT NRR INPUT FOR SALP - CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 Enclosed is a draft of the NRR input for the SALP for the Baltimore Gas and Electric Company.- This draft report is based primarily upon the mini-SALP evaluations enclosed with SEs prepared during this SALP period for Calvert Cliffs Units 1 and P.

Please review the draft evaluation and provide'eny comments you feel appropriate. All comments received by September 74, 1987 will be MNDO

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- I considered for incorporatiori in the final report. Your coments may be provided verbally due to the short turn-around time.

Please note that the licensee overall evaluation for " Licensing Activities" is a Category P.

.The assigned SES for this plant is R. Capra.

Signed 1

Scott Alexander McNeil, Project Manager Project Directorate I-1 l

Division of Reactor Projects I/II

Enclosure:

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t-ENCLOSUPE 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 evaluation of the licensee in the functional area of " licensing activities".

These included 1) the degradation of the #12 emergency diesel generator IEDG) 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 normally good management overview with respect to licensing activities. The senior engineering management actively participates in these actinns 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 safety-significance of the item. Due to a staffing 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 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 performance of licensing activities.

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i 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 POPV's and code safety valves) had not been filed for severr.1 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 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 licensee initiated actions or in response to NRC initiatives. Most of the license's j

evaluations of the significant hazards considerations were accurate though brief, thus routinely requiring additional infonnation 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

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flow conditions that 'would have placed the plant outside the analyzed bounds of the steam line break design basis event, 2) a change, unspecified in the licensee's submittal and unreviewed by the licensee's safety review committees, to the NPC cpproved peak reactor coolant system (RCSI pressure limit for the 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 moderator temperature coefficient limit, 3) the. justification for continued Unit 1 operation with the existing flaw in the main steam line was technically andregulatorilydeficient,and4)numeroustechnicalinconsistenciesand l

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 nonroutine 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 circumspec' at bast.

Generally, the l wensee has responded to the NRC in a timely manner, particularly, in regards to requests for additional infomation made to obtain technical su'pport for licensee requested activities. Response has not been as prompt in response to NRC issues of generic concern. 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 often 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 thorough 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 Licensing linit 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 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 and a free exchange of information.

The Licensing Unit has actively sought to improve communications with the NRC.

1 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 tasks assigned to this unit remain incomplete over periods of several The Fuel Cycle Management Facility Change Pequest (FCR) years due to neglect.

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 1983 though 24, including 5 core reloads and 10 TS

. amendments (9 of which were approved by the NRCI 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 licensing 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 Docket Nos. 50-317 and 50-318 FACILITY:

Calvert Cliffs Nuclear Power Plant LICENSEE:

Baltimore Gas and Electric Company EVALUATION PER!00: May 1, 1986 to August 31, 1987 PROiECT MANAGER:

Scott Alexander McNeil 1

I.

INTPODUCTInN 1

This report contains the results of the NRR eva'uatinn of the licensee in the 4

" Licensing Activities" SALP functional area..This assessment was performed in accordance with NPR Office Letter No. 44, Revision 1, "NRR Inputs to SALP

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Process," dated December 22, 1986 and NRC Manual Chapter 0516, " Systematic I

Assessment of Licensee Performance," dated July 25, 1986.

I 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 " Licensing Activities" is rated Category 2.

III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual l

Chapter 0516 Appendix, Table 1, " Evaluation Criteria with Attributes for j

Assessment of Licensee Performance."

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l IV. METHODOLOGY

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.i This evaluation represents the integrated inputs of the Operating Reactor i

Project Manager (ORPM) and those technical reviewers who expended significant I

amounts of effort on Calvert Cliffs Nuclear Power Plant, Units 1 and 2 licensing i

actions during the current rating period. Using the guidelines of NRC Manual

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Chapter 0516, the ORPM and each reviewer applied specific evaluations to the t

relevant licensee performance criteria, as delineated in Chapter 0516, and l'

assigned an overall rating Category (1, 2 or 3) to each criterion. The reviewers j

included this information as part of each Safety Evaluation prepared for Calvert j

Cliffs. The ORPM, after reviewing the SALP inputs of the technical reviewers,

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combined this infonnation with his own assessment of the licensee perforrence and, using appropriate weighting factors, arrived at a composite rating fnr the licensec. This rating also reflected the comments, if any, of the NRR Senior Executive assigned to the Calvert Cliffs Nuclear Power Plant SALP assessment.

A written evaluation was ten prepared by the ORPM and circulated to NPR manage-ment for comments, i

The basis for this appraisal was the licensee's performance in support of licensing actions that were completed during the current rating period. There I

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 I 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, 20 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 l

common to both Units 1 and P.

These 1icensing actions consist of amendment requests, exemption reauests,

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relief requests, responses to generic letters, TMI Action items, and other j

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 period i

of which 6 have been closed for each Unit. Those completed actions were.

GL 83-28, Items 1.2, 2.1, 3.1.3, 3.2.3, 3.7.3, and 4.5.?

10 CFR 50.61, Pressurized Thennal Shock Rule Plant Specific Actions:

Seven were active for Unit 1 and 7 for Unit P at the beginning of the SALP rating period. During the rating period, 32 actions were added for Unit I and 30 actions were added for Unit 2, c(35 actions were ommon to both Units).iving n total o I and 37 active actions on Unit 2 Of these actions,19 were closed for Unit I and 17 for Init 2.

Sixteen of these actions were comon to both Units 1 and 2.

Some of ;he more significant completed plant specific actions included:

DFOST Outage Time MSIV Replacement Closure Time l

Moderator Temperature Coefficient Limit Relaxation (withdrawn) l Exigent Diesel Generator LCO Change Request i

Emergency Change; Tech. Spec. for DG 12 Emergency Amendment: Refueling Without an EDG l

Request for ASME Code Relief for Main Steam Piping, Cycle 9 i

'TMI (NUREG-0737) Action Items:

For each unit, of the l' TMI Action items outstanding at beginning of the SALP rating period, 6 were completed durina the rating period, including:

III.A.).? - TSC, OSC and EOF III. A.P.2 - Meteorological Data Upgrade II.R. ).

- RCS Vents II. F. ;.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 ir. NRC Manual Chapter 0516:

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 sumary of the SALP ratings for the seven rating criteria is shown in Table 1 below.

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SUMMARY

OF SALP RATINGS Criterion Rating Management Involvement in Assuring Quality 2

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Approach to the Resolution of Technical Issues from a Safety Standpoint 2

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Responsiveness to NRC Initiatives 2

l Enforcement History 2

q Operational Events 2

Staffing (includingmanagement) 2' Training and Qualification Effectiveness 2

Composite Rating 2

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f l A.

MANAGEMENT INVOLVEMENT IN ASSURING QUALITY During the SALP evaluation period, the licensee has shown normally good management overview in the area of licensing activities with substantial efforts made over the last six months to improve the actual quality of management involvement.

At Calvert Cliffs, management participates in planning by actively deciding which activities to undertake, to defer or to cancel.

Currently, senior

-engineering management, significantly influenced by direct input from the operations manager, assigns priorities on a case-by-case basis dependent upon the impact on current or future-planned plant operations and upon the licensee's perception of the safety-significance of the activity.

The licensee's current prioritization system has had an impact on the timeliness of submittals and activities required by regulation, by Technical Specifications (TSF, and for NRC multi-plant actions. Many of these submittals and activities were deferred due to lack of adequate senior management concern and attention or due to a conscious management decision to utilize the manpower resources elsewhere that were necessary to complete the activity.

Some of the schedular delay requests submitted required very short NRC response tines.

The licensing actions that were deferred during this period include Safety Parameter Display System (SPDS) operability, Dedicated Control Room Design Review (DCRDR), the annual 10 CFR 50.71(e)(4) FSAR update, the annual 10 CFR 50.59 report, and the annual steam, generator tube inservice inspection test report.

In addition, inconsistent senior management attention towards licensing requirements was demonstrated through the NRC prompted report that the licensee had not submitted the annual report of challenges to and failures of the pressurizer PORV's and safety valves as required by TS 6.9.1.5.c since 1984 nor the annual financial reports required by 10 CFR 50.4 and 10 CFR 50.71(b) since 1979. Currently, no licensee unit is tasked with the responsibility of ensuring licensee compliance with the various NRC reporting requirements.

To effect corrective actions, the licensee is conducting an audit to detemine which reporting requirements are applicable to Calvert Cliffs and to verify that these reports actually are submitted and in a timely fashion.

The regulatory and technical quality of most routine ifcensing submittals has been adequate though most submittals have required additional explanatory information. However, when the activity was nonroutine, such as, for the exigent and emergency diesel generator TS amendment requests and for the Unit 1 main steam line flaw relief request, the submittals did not reflect adequate management review for either technical soundness or for regulatory compliance.

Marked improvement has been observed over the last six months with respect to management involvement in nonroutine issues, as management has taken a more active role in ensuring prompt, sufficient technical and regulatory solutions to licensing issues, particularly the environmental qualification and replacement parts certification difficulties, arising at Calvert Cliffs.

On the basis of the improving perfomance of Calvert Cliffs in licensing activities and the actions taken by management to improve the quality of their oversight of these licensing activities, a rating of 2 is assigned in this area.

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B.

APPROACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT The licensee possesses significar.t 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 consultants for nuclear core design, accident analysis and to assist in the resolution of technical issues or the performance of technical services requiring a high degree of specialization.

Often, the licensee's technical capabilities have not been reflected in the quality of the submittals provided to support licensee initiated actions or in response to NRC requirements and requests.

In reauesting TS amendments, most of 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 hazards considerations, ore of which was subsequently withdrawr, 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 judgement, example of which included li the licensee justified a main steam isolation valve (MSIV) closure time TS amendment request upon the erroneous assumption that MSIV closure time was totally independent of the steam flow across the valve seat, 2) 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 NF.C 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 f

an accident previously analyzed... the resultant peak RCS pressures are within l

the limits established by the analyses criteria." Furthermore, in obtaining management approval for the amendment request submittal, the responsible design I

engineer did not infom the plant operations and safety review committee (POSRC) f or the off site safety review comittee (OSSRCi of this change to the event's RCS pressure limit though it was an integral part of the amendment request, i

(3) in requesting relief from Section XI of the ASME Code for a Unit I main steam line flaw, the licensee's justification was methodological 1y deficient in not providing the information 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 certification deficiencies the licensee has demonstrated an increasingly conservative approach with regards to safety significance. The licensee voluntarily shut down Unit 1 and devoted significant manpower t,o performing an exhaustive review of all systems and components that could have been impacted by improper environmental qualification or by the use of uncertified replacement parts.

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l Based upon the technical capability demonstrated Fy the licensee over the course of the SALP rating period in considering the safety significance of licensing activities, a Category 2 is assigned to this criterion.

C.

RESPONSIVENESS TO NPC INITIATIVES The licensee has been generally timely in repsonding to NRC staff initiatives, particularly, requests for additional infomation in support of licensee requested TS changes. The licensee has requested extensions for responding to several NRC generic letters and has deferred action on SPOS operability, DCPDD and the annual FSAR update. However, licensee responses to NRC initiated issues are nomally thorough and often technically superior.

Resolution of licensing issues has often been marked by the licensee's reticence to yield on any licensinq 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 chani,e 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 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.

12 EDG that CO was leaking into the jacket cooling water system (MRf's 009138 and009415). 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 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 criterion.

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 (LERs) during this period. Of these LERn 5 were conrnon to linit 2 but were reported for Unit 1 only. Approximately one 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

? 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 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 LERs, 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.

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 MP EDG (Units 1 and 2) pressurizer code safety valve setpoint drift (Unit li 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 ?)

1 Inadvertent spraydown of containment (Unit li Inoperable dynamic response circuit in the reactor protection system delta T calculator (Unit 1) l Uncontrolled Boration (Unit li l

Total loss of offsite a.c. power (Units 1 and 2)

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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 marginal. For example, the 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 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 ar.d are not environmentally qualified. Without operable PORVs, the peak RCS pressures determined in the licensee's analyses 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 2 rating has been assioned to this criterino.

F.

STAFFING (INCLUDING MANAGEMENT)

Licensing actions (re carried out by three different groups in the Technical l

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., com reloads and reactivity control TS) and almost all responses to NRC initiatives, The Fuel Cycle Management Unit processes all TS amendment requests effected 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.

i 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 I

improving work product.

Conrnunications with the Licensing Unit are marked with good relations, a high degree of cooperation and a free exchange of infonnation 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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Pequest (FCR) process through which this unit initiates TS changes, core reloads' and other related modifications, changes, tests or experiments as j

permitted in 10 CFR 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 I was withdrawn) have been initiated since then. When asked for an explanation, licensee management' stated that these' tasks could nnt be properly completed because this unit had insufficient manpower to perform and complete 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 required training records.

i Communications between this unit and the NPC have been adequate though the staff was hesitar.t on one occasion to infom the NPC of errors in the Unit ?

Cycle 8 reload report, thus necessitating reissuance of the associated NPC l

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 NPR 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 Seminars on topics of current industry licensing interest Chernobyl lessons learned Plant industrial safety Official records are required to be mair tained 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 perfor:ned 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.

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l The Technical Services Engineering training records for the Fuel Cycle Management Unit were examined in November 1986. At this time, licensee management was infomed that these records were not up to date and that corrective' action was necessary. By the end of this FALP rating period, the 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 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:

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 Inprove 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 initiatives in a more timely fashion and to pemit 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.

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-4 ENCLOSURE 3 RECORD OF MEETINGS AND OFFICIAL DOCLNENTS 1.

NRR/Licenset Peetings September 19, 1986 Pequest for Emergency TS Amendment;

1. 12 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 Flew January 7,1987 Future Licensing Actions May 5, 1987 Materials Qualification Deficiencies 2.

NRR Site Visits /Feetings July 14', 1986 Site Familiarization and Training for New 0 RPM July 18', 1986 SALP Meeting August 1, 1986 Discuss Licensing Actions Status

' August 7, 1986 Investigate #12 EDG C0 Inleakage October 2, 1986 Followup Information on #12 EDG November 3-7, 1986 Containment Integrity Inspection April 1, 1987 ATWS Modification Review May 11-15, 1987 Restart Inspection (Joint Region 1/

NRR Team)

June 10, 1987 Steam Generator Tube ISI Amendment Request August 10-28, 1987 OSART 3.

Comission Meetings None 4.

Schedular Extensions Granted September 30, 1986 Order for Operable SPDS, Units 1 and 2 l

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e 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 i

Class 1 and 2 Bolting and Control Rod Drive Housings May 29, 1987 ASME Section XI Temporary Relief -

Unit 2 Auxiliary Feedwater Hydrostatic Test

' 6.

Exemptions Granted None 7.

Exigent / Emergency Actions Granted September 8, 1986 Exigent Diesel Generator LCO Change Request September ?3, 1986 Emergency Change; TS for DG 19 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, 1986) l 1

June 30,1986 119 101 Miscellaneous TS Changes

)

(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 Reguest September 23, 1986 122 104 Emergency Change; TS for DG IP October 6,1986 123 105 DFOST Outage Time i

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Date Unit 1 Unit 2 Title 1

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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 MSIV Replacement Closure Time June 30, 1987 108 Unit 2 Cycle 8 Reload Request July 7, 1987 127 109 CEA Misalignment / Purge 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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