ML20235H986
| ML20235H986 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/25/1987 |
| From: | Boger B Office of Nuclear Reactor Regulation |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8710010246 | |
| Download: ML20235H986 (18) | |
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.c September 25, 1987 Docket Nos. 50-317 DISTRIBUTION and 50-318 t
Docket File 7 NRCPDR PDI-1 Rdg.
MEMORANDUM FOR:
William F. Kane, Director C. Vogan Division of Reactor Projects S. McNeil Region I L. Tripp B. Clayton FROM:
Bruce A. Boger, Assistant Director S. Varga for Region I Reactors B. Boger Division of Reactor Projects, I/II
SUBJECT:
SALP EVALUATION - CALVERT CLIFFS UNITS 1 AND 2 Enclosed for your use is NRR's input for the SALP Evaluation for Calvert Cliffs Units 1 and 2 for the period of May 1,1986 to August 31, 1987.
Comments received from the various divisions within NRR were used in developing this evaluation. presents the NRR summary of " Licensing Activities" occurring over the SALP period; Enclosure 2 is a detailed review of these 1! censing activities; and Enclosure 3 provides the supporting data for these licensing activities.
Bruce A. Boger, Assistant Director for Region I Reactors Division of Reactor Projects, I/II
Enclosures:
As stated
- SEE PREVIOUS CONCURRENCE f.fo r PDI-1 PDI-1 PDI-1 AD:DRP CVogan*
SMcNeil RCapra BBoger 9/24/87 9/2F/8 9/t.5/87 9/zf/87 8710010246 070925 DR ADOCK 05 g7
Docket Nos. 50-317 DISTRIBUTION and 50-318 Docket File NRCPDR PDI-1 Rdg.
MEMORANDUM FOR:
William F. Kane, Director C. Vogan Division of Reactor Projects S. McNeil Region I L. Tripp B. Clayton THRU:
Robert A. Capra, Acting Director S. Varga Project Directorate I-1 B. Boger Division of Reactor Projects, I/II FROM:
Scott Alexander McNeil Project Manager Project Directorate I-1 l
Division of Reactor Projects I/II
SUBJECT:
SALP EVALUATION - CALVERT CLIFFS UNITS 1 AND 2 Enclosed for your use is NRR's input for the SALP Evaluation for Calvert Cliffs Units 1 and 2 for the period of May 1, 1986 to August 31, 1987.
Comments received from the various divisions within NRR were used in developing this evaluation.
Enclosure I presents the NRR sumary of " Licensing Activities" occurring over the SALP period; Enclosure 2 is a detailed review of these licensing activities; and Enclosure 3 provides the supporting data for these licensing activities.
Scott Alexander McNeil, Project Manager Project Directorate 1-1 Division of Reactor Projects, I/II
Enclosures:
As stated PDI-1 PDI-1 PDI-]
AD:DR P CVogan SMcNeil RCapra 6 8.f r 9/q3/87 9/ /87 9/ /87 9//f*7
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,f ENCLOSURE 3
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8 Licensing Activities
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Analysis:
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This licensee was r'ated E Categorya in the licenseing activities DJnctbdal
- 4 area for the previous SALP esaN(iion period." Management involvemst and
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control of Ticensing actisities,;2s well as_ licensee responsivuess to NRC initiatives were, viewed as strengths because the licensee asttsted in resolving several NRC;initiat,1Yes and its submittals were olihigh quality with rioted improvement in the no sigtifiernt hazards analysis provided to support of
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TechnicalSpeciffcation(TS)amendmentrequats.IWeaknisswasnotedon? yin the communicat,1M between the operations cnd licedsinW staffs concerning the
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reliability of errJ p e rt contro11ed by TS.
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1 During the current SALP evaluatioq period of May 1,1986 to August 3I.1987, -
a number cVsignificant occurrentta Wd,a decidelimpct.upon the evaluation of-i
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the licenset M the functional arei> of "licensingiactivities". c These occurrences included 1) thd degradation of tho $12 emergencp diesel generator (EDG) which necessitated one exigent and two emergency TS amendment requests, 2) the licensee's 4
n shift to a+24-month operating cycle which necessitated submittal and review of L
a wide range of TS nendment requests, and 3) the licensee's discovery of environnintal qualibration deficiencies and of the improper use of uncertified material replaceent p}rts.
In responding'to these occurrences ibd to other issues and event? over the course of the SALP rating period, the licshee has shown generally good f
management overview with respect to licensing activities. The senior engineering management'ectively participates in these actions by pHoritizing i
these actions with the concurrence of the Manager of Nuclear Operations.
.j Assignment of priority is based upon tht/ impact on current or future-planned plant operations and upon the licensee's evaluation of the safety-significance of the item.
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Generally, the licensee has responded to r.hei NRC in a timely manner, particularly, p
j with regards to requests for additional information made to obtain technicci support for, licensee requested activities, %spense has not been as prompt to NRC inues of generic concern. Due to a 6taffing shortage, the licensing' activ' ties prioritization scheme has adversely impacted the timeliness of NRC requested and required licensing activit'Esiwhich the licensee has often viewed as of lower priority. Thus, senior managemnt has diverted manpower resources away fFem these 4E-initiated activities h these deemed to be more in tre The licensee'has requested extensions for respo'nd'ng interest of the utility.,
4 to several NRC genwic letters and has deferred action on SPDS operability.
Dedicated Contro11cbm fesign Review and the annual.FSAR update. However, licensee resnoycs to NRC: initiated issuts are normally thorough and often technicallysupe}for.
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r Seniod management" attention towards NRC licensing requirements during this rating period was fomd to be inconsistent with regards to ensuringlicensee were filed late and some annually re? requirements. quired reports (e.g., challenges to compliance with the.various repnrtin Several required reports failures of t!M pessurizer PORV's and code safety valves) had not been filed j
for severalfern. ' Currently, no licensed unit,is tasked with the responsibility for or the autbrity to ensure that these';eport1, are submitted as required.
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. The licensee possesses significant technical capabilities in most of the engineering and scientific disciplines necessary to resolve issues of concern to the NRC and the licensee. However, in several instances these capabilities have not been reflected in the quality of the submittals provided to support licensee 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 infonnatior, to justify the request. The licensee has characterized every amendment request submitted during the rating period as not presenting any possible significant hazards considerations.
In three instances, however, the NRC has determined that these characterizations of the amendment requests were not justifiable based upon technical facts. These three requests were noticed by the NRC with opportunity for a prior hearing.
Subsequently, one was withdrawn, one was anproved with additional safety measures taken, and the third is under review at this time.
Several instances of poor senior management review and/or inadequate engineering
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analysis have occurred during this rating period. These instances included:
- 1) a requested TS main steam isolation valve closure time limit, tested under no steam flow conditions, that would have placed the plant outside the analyzed bounds of the steam line break design basis event; 2) a change to the NRC approved h
peak reactor coolant system (RCS) pressure limit for the feedline break (FLB) event from 110% design RCS pressure to 120% design RCS pressure in the FLB event's safety analysis. This was made to justify a proposed increase in the moderator temperature coefficient limit. This change in peak pressure was not indicated in the licensee's TS amendment request. This peak pressure change was not reviewed by the licensee's safety review committees; 3) the justification for continued Unit 1 operation with an existing flaw in the main steam line was technically and regulatori~y deficient; and 4) numerous technical inconsistencies and regulatory inadequacies were noted in the licensee's submittals of the exigent f,
and the first of two emergency TS amendment requests for the #12 EDG.
Over the last six months, marked improvement has been observed with respect to senior management involvement in and the quality of the technical responses to t
nonroutine licensing activities, particularly the environmental qualification and replacement parts certification deficiencies arising at Calvert Cliffs.
Resolution of licensing issues in several instances has often been marked by the licensee's determination not to compromise on any points or issues unless i
proven to be technically or legally incorrect. Though this has made 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 technically improved product.
Licensing issues are carried out by three different groups inethe Technical Services Engineering section of Nuclear Engineering Services.
Primary NRC/ licensee interface has been with the Fuel Cycle Managemeat unit, and the Licensing and Operational Safety unit.
The third group that carries out licensing activities is the Analytical Support unit. NRC interface with this unit has been minimal.
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. The Licensing unit is capably staffed, 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 signif-icantly improved due to the persistence and dedication of the unit'.s staff and to the quality of training provided. This unit has an effectivtFtraining program that is well maintained.
NRC communications with the Licensing unit are marked with good relations, a high degree of cooperation and a free exchange of infor-mation. This 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. However, many tasks assigned to this unit have remained incomplete over periods of several years.
For example, the Fuel Cycle Management Facility Change Request (FCR) process i's 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 i
completed by this unit since April 1983, though 24, including 5 core reloads and
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10 TS amendments (9 of which were approved by the NRC), have been initiated I
since this date. The licensee attributed the failure to complete these tasks to insufficient 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 senior management's recently
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demonstrated determination to improve the quality of their licensing actions,
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as particular1;, 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 senior management overview, 2) in the quality and comprehensiveness of the hazards analyses provided by the various engineering units to support licensing's development of f
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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Conclusion:==
Rating:
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Recommendations:
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UNITED STATES p,
NUCLEAR REGULATORY COMMISSION E
WASHINGTON, D, C. 20555
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ENCLUSULE 2 Docket Nos. 50-317 and.50-318 FACILITY:
Calvert Cliffs Nuclear Power Plant LICENSEE:
Baltimore Gas and Electric Company EVALUATION PERIOD: May 1, 1986 to August 31, 1987 i
PROJECT MANAGER:
Scott Alexander McNeil r
x I.
INTRODUCTION h
v This report contains the results of the NRR evaluation of the licensee in the
" Licensing Activities" SALP functional area. This assessment was performed in a
f accordance with NRR 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 25, 1986.
II.
SUMMARY
OF RESULTS NRC Manual Chapter 0516 specifies that each functional area evaluated will be h
assigned a perfonnance Category (Category 1, 2 or 3) based on a composite of a j
number of attributes. The perforwarc;e of Baltimore Gas and Electric Company 3
in the functional area " Licensing Activities" is rated Category 2.
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III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, " Evaluation Criteria with Attributes for Assessment of Licensee Performance."
IV. METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Project Manager (ORPM) and those technical reviewers who expenBed 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 MRC 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 infonnation as part of each Safety Evaluation prepared for Calvert Cliffs. The ORPM, after reviewing the SALP inputs of the technical reviewers,
. coinbined this information with his own assessment of the licensee performance and, using appropriate weighting factors, arrived at a composite rating for the licensee. This rating also reflected the comments of the NRR Senior {xecutive assigned to the Calvert Cliffs Nuclear Power Plant SALP assessment. A written evaluation was then prepared by the ORPM and circulated to NRR management for comments.
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 corraon to Unit 2, at the beginning of the rating period. A total of 32 actions were added to the Unit 1 docket by the end of the rating period. Four of these actions were specific to Unit 1 only, while the other 28 additional actions i
were shared by Unit 2.
Two actions specific to Unit 2 only, were added to the
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docket during the rating period. For Unit 1, 31 licensing actions were closed i
during the' rating period, leaving 32 active items, whereas, for Unit 2, 29 I
licensing actions were closed, leaving 32 active licensing actions. All of the i.
active. licensing actions, with the exception of one item for each Unit, are p
connon to both Units I and 2.
These licensing actions consist of amendment requests, exemption requests, relief requests, responses to generic letters TMI Action Plan items, and other miscellaneous actions as shown below and in Enclosure 3.
Multi-Plant Actions:
Thirteen were active for each Unit at the beginning of the SALP rating period of which 6 have been closed for each Unit. Those completed actions were:
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GL 83-28, Items 1.2, 2.1, 3.1.3, 3.2.3, and 4.5.2 10 CFR 50.61, Pressurized Thennal Shock Rule y
Plant Specific Actions:
Seven were active for Unit 1 and 7 for Unit 2 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, giving a total of 39 active actions on Unit I and 37 active actions on Unit 2 (35 actions were comon to both Units). Of these actions,19 were closed for Unit 1 and 17 for Unit 2.
Sixteen of these actions were common to both Units 1 and 2.
Some of the more significant completed plant specific actions included:
DFOST Outage Time MSIV Replacement Closure Time e
l Foderator Temperature Coefficient Limit Relaxation (withdrawn) l Exigent Diesel Generator LC0 Change Request e -
Emergency Change; Tech. Spec. for DG 12 Emergency Amendment:
Refueling Without an EDG i
Request for ASME Code Relief for Main Steam Piping, Cycle 9 j
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. TNI (NUREG-0737) Action Items:
l For each unit, of the 12 TMI Action Plan items outstanding at beginning of the.
i SALPratingperiod,6werecompletedduringtheratingperiod,1,ncJuding:
III.A.I.2 - TSC. OSC and EOF III.A.2.2 - Meteorological Data Upgrade II.B.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
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.following seven evaluation criteria that were specified in NRC Mantial Chapter 0516:
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Management Involvement in Assuring Quality 0
Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives
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Enforcement History Operational Events Staffing (Including Management)
Training and Qualification Effectiveness 5
A sumary of the SALP ratings for the seven rating criteria is shown in Table 1 below.
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.f Table 1 SUPMARY OF SALP RATINGS i
-W Criterion Rating
'anagement Involvement in Assuring Quality 2
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Approach to the Resolution of Technical Issues from a Safety Standpoint 2
Responsiveness to NRC Initiatives 2
Enforcement History
/2 Operational Events
,2; Staffing (includingmanagement) 2 Training and Qualification Effectiveness 2
Composite Rating 2
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A.
MANAGEMENT INVOLVEMENT IN ASSURING QUALITY
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During the SALP evaluation period, the licensee has shown nomally go'od 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. evaluation of the safety-significance of the activity.
-The'11censee's current prioritization system has had an impact on the timel.ine'ss i
4 of submittals and activities required by regulation, by Technical Specifications (TS), and for NRC multi-plant actions. Many of these submittals and activities a.
were deferred due to a senior management decision to utilize the manpower resources
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elsewhere. Some of the schedular delay requests submitted required very short NRC response times. The licensing actions that were deferred during this period RoomDesignReview(DCRDR),theannual10CFR50.71(e)(4)y,DedicatedControl include Safety Parameter Display System (SPDS) operabilit 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 require-ments was demonstrated through the licensee's failure to submit the annual report of challenges to and failures of the pressurizer PORV's and safety valves.as r
E required by TS 6.9.1.5.c since 1984 nor the annual financial reports required by i
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 determine which reporting requirements are applicable to Calvert 1
Cliffs and to verify that these reports actually are submitted and in a timely v
fashion.
The regulatory and technical quality of most routine licensing submittals has been adequate though most submittals have required additional explanatory infomation. Howevar, 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.
1 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 performance 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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APPROACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT 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 consultants for nuclear core design, accident analysis and to assist in the I
resolution of technical issues or the performance of technical services requiring a high degree nf specialization.
i 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 requesting TS amendments, most of the licensee's evaluations of the significant hazards considerations were l,.
accurate though brief. Additional explanatory information and more detailed
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review was often required of the licensee to justify the-request. Every J
amendment request submitted during this period was characterized by the
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licensee.as presenting no significant hazards considerations though in three of these TS amendment requests, one of which was subsequently withdrawn under pressure from the NRC, the characterizations were not justifiable based upon the technical facts. The NRC noticed these three requests with opportunity for prior hearing.
Furthemore, though sound engineering judgement was demonstrated through almost all licensing actions, there were instances of inadequate analysis, examples of which included 1) the licensee justified a main steam isolation valve (MSIV) closure time TS amendment request upon the assumption that MSIY closure time wastotallyindependentofthesteamflowacrossthevalveseat,2)tosupport 3
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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
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pressure to 120% of design RCS pressure. However, this pressure limit change L
was not called to the attention of the NRC, rather, it was obscured by the
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11censee's statement that "the preposed amendment would not:
(1)involvea
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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 infonn the plant operations and safety review comittee (POSRC) or the off site safety review committee (OSSRC) of this change to the event's 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 did not provide the information specified by the ASME Code as required to permit relief and (4) numerous technical consistencies 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 replacem1Dt parts certification deficiencies the licensee has demonstrated an increasingly 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 have been impacted by improper environmental qualification or by the use of uncertified replacement parts.
. Based upon the technical capability demonstrated by the licensee over the course of the SALP rating period in considering the safety significance of
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licensing activities, a Category 2 is assigned to this criterion.
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C.
RESPONSIVENESS T0_NRC INITIATIVES The licensee has been generally timely in repsonding to NRC staff initiatives, 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, DCRDR 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 reticence to compromise on any licensing issues until demonstrated to be in the wrong or inferior technical position.
However, this can be beneficial in promoting the exchange of. ideas and technical infonnation with the end result being a superior produce. Normally, this licensee will change its position t
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.
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ENFORCEMENT HISTORY I;
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.
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The former issue was mitigated to a level 4 violation and resolution of the j
F 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 slowness in determining root cause evaluations and in instituting effective, indepth i
corrective action for potential safety issues. This propensity was noted j
,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 C0 was leaking into the jacket cooling water system (PM 's 009138 and009415). No violation was given due to the previously demonstrated reliability of the EDGs but corrective action and a response were requested.
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 requ,1 ring corrective action in a more timely and adequate fashion. This was noted particularly in the licensee's corrective actions following discovery of the replacement parts certification deficiencies.
Consequently, a Category 2 rating has been assigned to this criterion.
E.
OPERATIONAL EVENTS Calvert Cliffs Unit 1 was in mode 1 operation for 11 months of the 16 month SALP period. The licensee submitted 18 Licensee Event Reports (LERs) during
- i this period. Of these LERs, 5 were common to Unit 2 but-were reported for -
Unit 1 only. Approximately one third of the reports involved equipment t
failures.
' E 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 I
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 consnon to Unit 1.
Approximately one-half of these LERs involved j
3 equipment failures.
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Eight of these LERs involved unplanned reactor trips. Of the total 13 LERs, 6 I
involved personnel, procedural or maintenance errors with 3 reactor trips and
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3 forced shutdowns resulting from these errors.
Unit I had a reactor trip average of 5.25 trips / year while the average for
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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 2)
Pressurizer code safety valve setpoint drift (Unit 1)
Environmental qualification deficiencies (Units 1 and 2)
Lossofshutdowncoolingduetoapipecrack(Unit 2)
Breakdown of material control program (Units 1 and 2)
Inadvertent spraydown of containment (Unit 1)
Inoperable dynamic response circuit in the reactor protection, system delta T calculator (Unit 1)
Uncontrolled Boration (Unit 1)
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 safety valves to lift within their required setpoint bands (LER 87-0067 bf taking cre'iit for operation of the power operated relief valves (PORVs).
Yet, the PORVs are not required to be operable and unisolated during mode 1 operation and 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 assigned to this criterion.
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F.
STAFFING (INCLUDING MANAGEMENT)
I Licensing actions are carried out by three different groups in the Technical Services Engineering Section of Nuclear Engineering Services. The Licensing l
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
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the fuel cycle design, all reactivity control TS, all reactor vessel and vessel j
internals TS, and all associated topical reports. The Analytical Support unit j
handles all licensing activities concerning computer analytical methodologies.
l 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
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(l decline during this period. Nevertheless, the presistence and dedication of the Licensing Unit's staff has resulted in a continually and significantly l
e improving work product.
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p Communications with the Licensing Unit are marked with good relations, a high t
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 withsignificant expertise in the technical issues of fuels management.
The quality of this unit's work product has remained adequate with no significant decitne or i
improvement noted. Many assigned tasks remain incomplete over periods of several years. An example is the Fuel Cycle Management Facility Change
. Request (FCR) process through which this unit initiates TS changes, core reloads and other related modifications, changes, tests or experiments as 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 not 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.
Communications between this unit and the NRC have been adequate though the staff was hesitant on one occasion to inform the NRC of errors in the Unit 2 Cycle 8 reload report, thus necessitating rtissuance of the associated NRC safety evaluation.
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f 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 4
submittal. This review process demonstrated significant technical expertise f
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.
j Based upon the above, a SALP rating of Category 2 for this criterion would be appropriate.
I G.
TRAINING AND QUALIFICATION EFFECTIVENESS t
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 i
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 perfors job tasks associated with their required qualification factors until they are performed at least once under the supervision of a staff member qualified in_t_ hat factor.
. The Technical Services Engineering training records for the Fuel Cy'.le Management Unit were examined in November 1986. At this time, licensee renagement 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 reason given was a staff manpower shortage in this unit.
Based upon the above discussiun, a SALP rating of Category 2 is assigned to I
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 t
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 Improve 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 F. ovide 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 l
rating of Category 2 is assigned to the " Licensing Activities" functional area.
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L ENCLOSURE 3 RECORD OF MEETINGS AND OFFICIAL DOCUMENTS 1.
NRR/ Licensee Meetings September 19, 1986 Request for Emergency T5 Aiiiendment;
- 12 EDG September 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 January 7, 1987 Future Licensing Actions May 5, 1987 Materials Qualification Deficiencies w
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2.
NRR Site Visits / Meetings July 14, 1986 Site Familiarization and Training for New ORPM July 18, 1986 SALP Meeting August 1, 1986 Discuss Licensing Actions Status I
August 7, 1986 Investigate #12 EDG C0 Inleakage
.I October 2, 1986 Followup Infonnation 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 10-28, 1987 OSART r
3.
Commission Meetings None l
4 Schedular Extensions Granted September 30, 1986 Order for Operable SPDS, Units 1 and 2
6.
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 Control Rod Drive Housings May 29, 1987 ASME Section XI Temporary Relief -
Unit 2 Auxiliary Feedwater Hydrostatic Test i.
6.
Exemptions Granted
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r None 7.
Exigent / Emergency Actions Granted September 8, 1986 Exigent Diesel Generator LCO Change Request p
September 23, 1986 Emergency Change; TS for DG 12 November 28, 1986 Emergency Amendment: Refueling without I
an EDG l:
4 8.
License Amenchnents Issued Amendment Number e
I Date Unit 1 Unit 2 Title h
June 17, 1986 118 100 Miscellaneous TS Changes (applicated dated January 20, i
1986)
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 Request September 23, 1986 122 104 EmergencyChange[TSforDG12 October 6, 1986 123 105 DFOST Outage Time
Amendment Number Date Unit 1 Unit 2 Title November 28, 1986 124 Emergency Amendment $ Refueling Without an EDG December 19, 1986 125 106 RCP Flywheel. Inspections /
Snubber Table Deletion MSIV Replacement Closure Time February 25, 1987 126 107 MSIY Replacement Closure Time April 29, 1987 108 Unit 2 Cycle 8 Reload Request l
June 30, 1987 1
July 7, 1987 127 109 CEA Misalignment / Purge Valve.,
Isolation Response Time 1
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t 9.
Orders Issued f
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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