ML20245G645
| ML20245G645 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/21/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906290209 | |
| Download: ML20245G645 (26) | |
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< ;4 BALTIMORE GAS AND ELECTRIC F
CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 GEORGE C. CREEL Vice PatsiotNT NUCLE An ENtnov (300 aco-44ss June 21,1989 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to inspection Report Nos. 50-317/89-200; 50-318/89-200 (Soecial Team Insoectiod Gentlemen:
We have completed a careful review of the subject Special Team Inspection tSTI) repon. Our 30-day response is provided in Enclosure (1). As requested, we have addressed the 14 unresolved items identified in the report. We are also providing the actions taken or planned to be taken for additional weaknesses which were noted in the report.
Our. response is divided into both short-term and long-term actions. Many of the short-term actions were completed during or immediately following the inspection. In addition,' many of the programmatic weaknesses requiring long-term actions had already been identified. and are being addressed through our Performance Improvement Plan (PIP). Therefore, where appropriate, our response will reference our PIP for the long-term actions.
We are presently in an outage on Unit I and an extended refueling outage on Unit 2.
Since the short-term actions are based on addressing the identified immediate concerns, we will complete the remaining short-term actions prior to the start-up of either unit.
In closing, let me assure you that all concerns will receive appropriate management attention.
- However, of particular concern are the areas related to procedural compliance, Quality Control, procedure upgrade, and management effectiveness. These areas will receive our highest attention.
8906290209 890621 E
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' Docum;nt C ntr:1 Desk-l June 21,1989 Page 2 1
l Should you -have any further questions regarding this matter, we will be pleased to discuss them with' you.
Very truly yours,
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GCC/LSL/ dim
' Enclosure -
cc:
D. A. Brune, Esquire J. E.
Silberg,- Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC -
H. Eichenholz/V. L. Pritchett, NRC T. Magette,' DNR L
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ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT.
RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION -
UNRESOLVED ITEM NO. 1:
Control Over Measuring and Test Equipment (M&TE)
Temporarily installed gauges used for tests were maintained and calibrated prior to use by our Instrument and Control (I&C) Maintenance Group. Following their use, these gauges were returned to their storage shelf. No records were maintained on usage and no post-use calibration was performed. This practice was contrary to our CCI-120 (Calibration Program for Measuring and Test Equipment).
Corrective Actions The following actions were immediately taken during the inspection:
o All gauges maintained by the I&'? Maintenance shop were checked and verified to be within calibration.
o All I&C Maintenance shop perso inel were directed to check all temporary gauges for calibration immediately before and after each installation.
o Additional test equipment gauges were ordered.
The following provides the status of additional corrective actions we have taken:
o A - Non-Conformance Report (NCR) was issued. This NCR addressed the use of uncontrolled. M&TE gauges installed by the Instrument Maintenance Groups for several Operations Surveillance Test Procedures (STPs). The NCR addressed actions to control the M&TE gauges and check previously run STPs for unusual data.
o The new test equipment gauges have been received. These gauges are maintained by our Test Equipment Unit and issued from the Test Equipment Cage. If they become radiologically contaminated, they will be issued from the E&C llot Shop.
o Instrument Maintenance Technicians and Planners have been instructed to use only M&TE instrumentation controlled and calibrated by the Test Equipment Unit.
Usage logs are being maintained on these gauges and their serial numbers are being recorded on the installation / removal maintenance orders, o
Because the Test Equipment Unit now calibrates and maintains these gauges, the calibration stickers will reflect calibration and calibration due dates.
o As stated previously, all test gauges maintained by the 1&C Maintenance shop were verified within calibration. In addition, a review of the Operations STPs that used temporary gauges installed by the IAC - - - _ - _ _ _ - _ _ -
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ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 f
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SPECIAL TEAM INSPECTION Maintenance Shop has been completed back through 1988. The temporary gauges are used primarily to verify a change of state of a component (check valve) to help conclude that it did in fact shut. These are gross measurements and would not have been significantly affected if the gauge had been slightly out of calibration.
o A
Quality Assurance surveillance was requested and compieted.
No l-discrepancies were identified.
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The remaining short-term corrective action will be completed prior to the start-up' of L
either unit:
o A
review of all active test equipn.ent calibration records will be completed. This will ensure NCRs have been appropriately generated for any test equipment that was out-of-calibration.
l Although we consider this specific issue resolved,. as a long-term corrective action, each appropriate General Supervisor will review their section's implementation of the M&TE CCis.
UNRESOLVED TrEM NO. 2:
Procedure Changes Which Change the Procedure's Intent Technical Specification 6.8.3 states that Temporary Changes to procedures (required by Technical ' Specification 6.8.1 ) may be made, provided the intent of the original procedure is not altered and the change is reviewed by our Plant Operations and Safety Review Committee (POSRC) within 14 days of implementation.
Our controlling procedures (Calvert Cliffs Instructions) need to clearly describe what types of procedure changes do not change the intent of a procedure.
Corrective Actions A well-defined description of what constitutes a
- Change of Intent" has been developed and is being reviewed. Upon final review of the definition by our POSRC, and approval by the Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD), the definition will be incorporate ( into CCI-101 (Calvert Cliffs Implementing Procedures Development and Control). A checklist is also being developed to aid in the implementation of the definition's use. This short-term action will resolve this item and will be completed prior to the start-up of either unit. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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j ENCLOSURE (1)-
l CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECrlON IJ_NRESOLVED ITEM NO. 3:
Use of General Supervisor-Nuclear Operations (GS-NO) Standing Instructions Three GS-NO Standing Instructions were identified as instructions which should be included in a procedure. Specifically, these were:
o 83-2, Sampling of Oils - This instruction directs that samples of tube oil or electro-hydraulic control fluid be tested when received.
o 83-12, Loss of Bus No,11 (125 VDC) - This instruction provides direction to station operators at the Unit 2 Turbine upon a Bus No. 11 125-VDC undervoltage condition. This is required since a loss of Bus No. 11 will prevent the Unit 2 Turbine from being tripped automatically or manually from the Control Room.
o 84-2, Reactor Trip Breaker Operabil.ity - This instruction refers the operators to CCl-ll 8 (Calvert Cliffs Reporting Requirements) if one or more reactor trip breakers are inoperable.
Corrective Actions The following short-term corrective actions will be completed prior to the start-up of either unit:
o The requirement to sample oil drums and trucks is contained in other applicable procedures, with the exception (? the Emergency Diesel Generator (EDG) lube oil day tank's procedure. Therefore, Operating instruction (01)-21 (Emergency Diesel Generators) will be revised to include the guidance in GS-NO Standing Instruction 83-2.
o The Alarm Manual will be revised to incorporate the requirements of GS-NO Standing Instruction 83-12.
o A reference to CCI-Il8 will be placed in Surveillance Test Procedure (STP) O-6 (Reactor Protective System Start-up Test), as well as other apolicable STPs and Preventive Ma;atenance Procedures.
o We will establish controlled administrative guidance to prevent the substitution of GS-NO Standing Instructions for procedures.
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ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION All GS-NO Standing Instructions have been reviewed in light of this concern.
Additional GS-NO Standing Instructions, in addition to the above three will be incorporated into an appropriate procedure. We have reviewed these additional Standing Instructions and believe that ncne will adversely affect plaat safety before they are incorporated. Therefore, our long-term corrective action will be to incorporate these additional GS-NO Standing Instructions into an appropriate procedure by October 31, 1989.
UNRESOLVED ITEM NO. 4:
Control of Temporary Modifications CCI-il7 (Temporary Modifications Control) allowed for the installation of a temporary modification without prior POSRC review and a 10 CFR 50.59 consideration if the equipment affected was no'.
safety related.
- However, Calvert Cliffs' Technical Specifications require review of all proposed changes or modifications to plant systems or equipment that affect nucle'ar safety.
Corrective Actions The below corrective actions have been taken. No short-term corrective actions are remaining.
o A screening form was developed by Design Engineering and all outstanding temporary modifications (65) were reviewed by the Design Engineering Section and POSRC. Of these, 18 were determined to " affect nuclear safety" under the new screening criteria. Six temporary modifications were identified as modifications which should have received a 10 CFR 50.59 analysis. One of these was determined to constitute an unreviewed safety question (for additional
- details, see Inspection Report 50-317/89-11; 50-318/89-11).
o Currently, Design Engineering is screening all new temporary modifications.
As an interim measure, our POSRC is reviewing all new temporary modifica-tions and will continue to do so until the revised CCl-117 is issued.
One long-term action will be to revise CCI-ll7 (ECD - September 1989). Additional long-term actions will De covered by the PIP. Our goal is to provide a multi-layered approach to safety consideration of all activities (e.g.,
maintenance, modifications, and troubleshooting). _ ________- _ _ _- _.
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ENCLOSURE (IF
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CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECrlON REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION UNRESOLVED ITEM NO. 5:
Lack of Detailed Work. Instructions j
Some maintenance packages and procedures reviewed by the STI team did not contain adequate details for. the complexity of the work. When Technical Manuals were referenced for accomplishing work, specific sections of the Technical Manual were not always identified.
Corrective Actions The following corrective actions have been taken:
Training has been given to Maintenance Supervisors and Planners regarding o
the significance of this ;ssue and the important role they play in providing adequate instructions for the conduct of maintenance activities.
o CCI-200 (Maintenance Orders) has been revised to specify that when MOs reference a technical manual, they must specify the particular portions of the technical manual to be used, o
CCI-101 has been issued and will provide for consistency in the development of human-factored maintenance procedures.
o Additional procedure writers have been allocated to support and expedite the development of detailed
- p..eedures. Many of the additional resources allocated to the ' Procedure Upgrade Project are focused on improving the preventive maimenance procedures.
i The remaining short-term corrective action will be taken prior to the start-up of either unit:
o Maintenance Orders (MOs) will be planned to a greater level of detail and
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when necessary will receive prior POSRC review. Additional planners are
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being supplied to the planning effort in order to support this initiative.
J As a long-term corrective action, these concerns will ultimately be addressed through the completion of the Procedure Upgrade Project, which is addressed in our PIP.
I UNRESOLVED ITEM NO. 6:
Incomplete Documentation of Completed Maintenance Completed Preventive Maintenance records did not have the appropriate sign-offs in designated spaces. The examples provided indicated insufficient attention to detail in completing documentation. Completed maintenance activities which are not adequately documented do not facilitate root cause analysis and trending activities. l l
i b]iCJ.OSURE (I) g j
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION Corrective Actions The following corrective actions have been taken in order to ensure that this concern is appropriately addressed until further long. term programmatic actions can be implemented:
o In October 1988, which was subsequent to the dates of the examples cited in the STI report, the Maintenance General Supervisors stated in writing Management's expectations with regard to procedural compliance. Since that period, appropriate disciplinary action has been administered whenever a deviation was identified.
o In addition, throughout 1989, a series of meetings are being conducted within the Maintenance Sections to explicitly state Management's expectations with regard to procedural compliance and documentation adequacy.
o The Maintenance Supervisory Job Observation Program has been instituted to routinely assess overall maintenance performance. This program includes the oversight of procedural compliance and documentation adequacy, o
CCI-101 has been revised to assist in the development of accurate L. 6 human-factored maintenance procedures. This will make it easier to follow procedures e.nd to facilitate the signing off of individual steps.
o CCI-200 has been changed to allow for the revision of the " Action Taken" section of MOs.
As part of our long-term corrective actions, we are examining ways to reformat the
" Action Taken" section of the MO in order to include the appropriate information on MOs for the purpose of documenting root cause and corrective actions. In addition, the implementation of the Nuclear Information Planning System (NIPS) maintenance planning and management project is part of our PIP.
UNRESOLVED ITEM NO. 7:
Control of Vendor Technical Manuals The following weaknesses regarding the receipt, control, review, and distribution of vendor Technical Manuals were identified:
o Cover sheets were not always developed and completed for new or revised Technical Manuals received on-site. _ _ _ _ _
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. ENCLOSURE (1) l^
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CALVERT CLIFFS NUCLEAR POWER PLANT j
RESPONSE TO INSPECTION - REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION l
o Technical revieu, required by CCI-122 (Control of Technical Manuals),
were not completed within the specified 15-day time frame. In some cases, new or revised Technical Manuals were issued for use before the review was completed.
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L detailed engineering guidance was provided for technical reviews of new or revised Technical Manuals. A draft revision to' CCI-122 was pending; however, was not yet published.
Corrective Actions The following corrective actions have been taken:
o A project team has been. formed to address both short and long-term corrective actions.
o All new Vendor Technical Manuals and pending Technical Manual revisions which 1. ave not received an engineering review have been identified.
o Detailed engineering guidance for technical reviews of Vendor Technical Manuals has been published.
The' remaining short-term corrective actions will be taken prior to the start-up of either unit.
o All pending Vendor Technical Manual revisions will be screened for safety significance, Plant procedures which need to be used in the near-term, and are affected o
by a safety-significant Technical Manual revision, will be revised prior to use.
o Technical Manual revisions will not be issued for use in the future unless the technical review is complete.
Our long-term corrective actions will be addressed by the PIP. - _ - _ _ _ _ _ _ _ _ _ _ _ _
ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION UNRESOLVED ITEM NO. 8:
Control Over Welding Process Activities The' concerns expressed on this issue center around the control and ' issuance of weld rod and - the welding process. This issue arose very late in the STI inspection and did not allow sufficient time to ' completely assess and. validate the observations.
However, following the STI, we have reviewed our welding process controls in light of aese concerns. Some of the specific STI observations contained in the report require clarification. Accordingly, the following is an assessment of these issues as they are described in the STI report.
o 2.2.6 This paragraph states that POSRC-approved welding process procedures were not implemented.
Welding Program Procedures (WPP) 6.006 and 6.009 are reviewed and approved by the Material Engineering and Analysis Unit of our Fossil Energy Division. The responsibility of reviewing and approving these very narrow and technically focused procedures has been delegated to this Engineering Unit due to their uniquely capable expertise in this area. Recently, we revised CCI-103 to require a quarterly presentation of new and revised welding program procedures to be presented to POSRC by the Materials Engineering and Analysis Unit.
This paragraph states that CCI-222 was cancelled on o
2.2.6 (1)
November 11, 1988, that Shop / Lab Memo M-64, Rev. O was issued on February 14, 1989, and that there was a period of time when there was no approved written instructions for Filler Material Control.
Actually, Shop / Lab Memo M-64 was effective on February 14 and CCI-222 was subsequently cancelled on February 28 at POSRC Meeting 88-022. We ' believe the Inspector misinterpreted November 11, 1988, which was the approval date of the last revision of CCl-222, as the cancellation date. In addition, training was given to Welding Personnel (Awareness Training Memorandum 89-009) on the implementation of Shop / Lab Memo M-64 on February 17,1989 in order to review Shop / Lab Memo M-64. Shop / Lab Memos are approved for use under CCI-il9 (Shop / Lab Memos). They are auditable documents approved by the General Supervisor. In this particular case, the Shop / Lab Memo implements the unique specifics with regard to the issuance of weld rod filler material for Calvert Cliffs.
o 2.2.6 (2) - This paragraph states that a sketch was posted adjacent to the weld rod ovens and was used to specify where weld rod should be maintained within the oven.
1 The sketch is only used as an aid to the attendant to direct the attendant to the right oven. It is not used to ensure the proper rod was issued.
The Filler Material Control Tag is used to ensure correct weld rod issue i.
i ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-206 SPECIAL TEAM INSPECTION and is signed by the Toolroom Attendant as well as the welder. Each rod is individually verified, in response to this item and in order to reduce confusion, the sketches have been removed from the Weld Rod Ovens as they are not necessary.
o 2.2.6 (
- This paragraph states that Shop / Lab Memorandum M-64 related to issuing weld material was not available at the stat ons that issue the weld i
material.
Weld rod Toolroom Attendants are trained in accordance with Shop / Lab Memo M-64(Calvert Cliffs Training Memo #89-M-109). Copies of procedures are now also located on station as a result of this observation.
o 2.2.6 (4) - This paragraph states that the team determined that on the back shift, welders were drawing weld rods without Toolroom Attendants being present and completing the Toolroem Attendants portion of the filler material control tags.
We believe this statement reflects the fact that this situation could happen as a result of the fact that the Weld Shop Supervisors do have keys to the Tool & Equipment Area and may withdraw weld rods on the night shift if necessary. Ilowever, we can cite few examples where this has actually happened due to the fact that Toolroom Attendants are scheduled on shift-work whenever major maintenance activities are taking place. It should be noted that it is not our practice for welding personnel or supervisors to withdraw weld rods from the Tool & Equipment Area.110 wever, supervisors are properly trained to allow them to withdraw weld rod,, ? necessary, in addition, the report states that the welders v.;re attaching both the hard and soft copies to the weld rod containers.
- - This statement reflects that under special situations we establish field issue of bulk quantities of weld rod in the field whenever large jobs are scheduled to take place in relatively confined areas.
For
- example, during this observation period, major welding activities were taking place in the waterfront area regarding the fabrication of salt water piping. For a situation such as this, the Weld Shop would withdraw large quantities of weld rod (large enough to fill a welding oven). At this time, the filler material control tags (both copies) were issued along with the entire can of weld rods. Once in the field the weld rod (controlled) was issued by Lead Personnel who were trained in accordance with Shop / Lab Memo M-64.
Full Quality Control Coverage was established for this particular job to verify proper compliance with weld rod control. Because the work was located at the point of issue, both copies of tags were completed simultaneously. The filler material control tag is typically issued in two copies because weld rods are issued at one point and consumed at another.
Two copies facilitate control and accountability of weld rods. In this 9
ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECrlON REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION I
L particular situation, the issuance and use of the weld rod occurred at the same location; therefore, both copies were filled out simultaneously and the weld rods were under control and accountability was maintained.
1 This part of the observation indicates that differat o
2.2.6 - (5). : (c) revisions of' data sheets _ were used during the Test Equipment Calibration Procedure.
This observation refers to two different data sheets (different in format only) that contain identical information. One is used for holdirg ovens, while the other is used for baking ovens. However, to reduce confusion, both attachments are being reformatted to similar configurations.
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.2.2.6 (6) - This paragraph refers to a welding oven that appeared to be out-of-calibration and maintaining temperature too low. It states that the attendants at the weld rod issue station did not know the temperature requirements.
The gauge referred to in this observation is a low quality gauge that is supplied with and installed in t'.e door of the weld rod ovens. These gauges are only rated accurate to 10 and are not used to determine correct oven settings. They are only sufficient to ensure that ovens are powered and functioning. Instead, ovens are calibration-checked semi-annually to ensure appropriate setting. To date, during the course of these semi-annual calibration checks, our records show no identified failures of these ovens.
In summary, the oven temperature requirement i:, determined by the calibration procedure. We have identified no oven temperature control problems during our calibration checks for these ovens and are confident that there are no performance issues that need attention in this area.
Additionally, the gauge cited in the inspection report was checked and found to be inaccurate, while the oven temperature setting was proper and appropriate. We have subsequently ordered a new gauge to replace the gauge installed in the door.
Corrective Actions A summary of the remaining short-term corrective actions which will be taken prior to the start-up of either unit is as follows:
o Shop / Lab Memorandum M-64 will be changed to a POSRC-approved procedure (CCI-226). l 1
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ENCLOSURE (1) l CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION o
Revision numbers will be placed on the Preventive Maintenance (PM) documents associated with welding process controls.
o The formats of the Data Sheets, associated with the weld rod oven calibration procedures, will be revised to be consistent.
Consistent with the above, we plan to make appropriate adjustments to the control of our welding process program as required in the future.
UNRESOLVED ITEM NO.9:
No Procedures for Control of Quality Control (QC)
Inspection Activities Calvert Cliffs did not have approved procedures or written instructions for controlling, implementing, and documenting QC inspections.
The issue is accurate in that Calvert Cliffs did not have procedures for controlling, implementing, or documenting QC inspections that were specifically for Quality Control. However, Quality Control activities are included in the Quality Assurance Policy (QAP), QuaGty Assurance Procedures (14, 15, 16, 26 and 35); and CCIs (101, 104, 116, 119, 1.U, 150, 152, 200, 201, 204, 208, 210, 211, 212, 218, 220, 410, 613, 620, 700, 701, 303 and 805). Quality Control procedure deficiencies were identified in May 1988, during work on a Job Task Analysis (JTA) for QC Inspectors. In February 1989, following completion of the JTA, a Senior QC Inspector began developing procedures specifically for QC activities. In March 1989, two contractor personnel were hired to support the procedure development task.
Although independent procedures for QC did not exist, abundant evidence of independent inspections is available in the documentation of MOs, Controlled Work Packages, Non-destructive Examination Reports, Inspection Reports, and NCRs. Development of QC i
procedures, specific to QC activities, will improve the existing program.
Corrective Actions The following immediate corrective actions have been taken:
o The Vice President (VP) - Nuclear Energy Division (NED) made QC improvements a top priority project.
o A Project Manager was assigned to resolve QC problems and improve the QC inspection process. !
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-ENCL,OSURE'W CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE -TO INSPECTION REPORT. 50-317/89-200; 50-318/89-200 SPECIAL TEAM-INSPECTION o
An independent contractor was hired to evaluate the QC process and assist with developing and implementing improvements.
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' Three contractor Quality Engineers have been hired to provide technical support for QC and to. assist with QC improvements.
o A. priority list was developed and issued to provide criteria for QC inspector coverage of work activities.
o Quality Control administrative and inspection procedure development was accelerated.
o The QC organization has been evaluated and the process of reorganization along functional craft lines has begun. Interim QC organization and staffing changes have been implemented.
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o An independent contractor evaluated the NCR System and has been retained I
1 to revise and optimize the program.
Short-term corrective actions have been taken to address the concern. Long-term corrective actions are covered by the PIP. Some of these actions are in progress and include:
o Development of the inspection process and plans to enhance QC review of procedures and MOs during the planning process for inclusion of critical characteristic inspection hold points, and 1
o Development of administrative procedures for QC.
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UNRESOLVED ITEM NO.10 No Site Writer's Guide for STPs l
An STP Writer's Guide was maintained by only Operations and Electric & Controls
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(E&C) Maintenance. In addition, each guide was developed independently by Operations i
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and cAC Maintenance and varied with respect to format and use of sign-offs.
Corrective Actions CCI-101 has been revised to provide a Writer's Guide. This guide is applicable ta all site STPs and addresses the concerns relative to this issue.
No short-term corrective actions remain prior to either unit's start-up. As a long-term corrective action, format inconsistencies and acceptance criteria will be addressed through our PIP.
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ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION I
i UNRESOLVED ITEM NO. I1:
Permanent Resolution of Identified Procedure Deficiencies I
Many procedure changes identified and performed in the field were not subsequently incorporated into the permanent procedure. Therefore, different personnel subsequently performing the same procedures were required to identify and resolve the same previously identified deficiencies.
Corrective Actions CCI-101 has been revised to require immediate " pen and ink" changes to procedure master copies when procedure changes are made in the field in accordance with our CCIs. Subsequent users of the permanent procedure will therefore have the benefit of all previous field changes. CCI-101 requires that the procedure be revised upon accumulation of a maximum of five " pen and ink" changes. It further requires that any
" pen and ink" changes be incorporated during the procedures' periodic review. No short-term corrective actions remain prior to either unit's startup.
UNRESOLVED ITEM NO.12 Evaluation and Incorporation of Vendor Recommenda-tions into Surveillance Procedure Requirements During review of the maintenance and surveillance section of the Emergency Diesel Generators (EDG) vendor technical manual, the team identified a vendor recommendation to periodically start each EDG. The recommendation further states that this should be a slow start (idle speed - 300 to 500 rpm, and gradually incteased in speed to 900 rpm within one to two minutes). Comparing this recommendation to Calvert Cliffs' established STPs, they noted a scheduled surveillance to start the Nos. 11 and 21 EDGs four times per month, and the No. 12 EDG eight times per month. The STI report concluded:
o "The team found that there was no justification for deviating from the vendor's recommendation."
o "The team felt that the area of evaluation and incorporation of the recommendations made by the vendor in its technical manual required further licensee attention to determine whether there were programmatic weaknesses in this area." The team considered the item unresolved and potentially linked to Unresolved item No. 7 (Control of Vendor Technical Manuals)...
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ENCLOSURI;_UJ CALVERT CLIFFS ' NUCLEAR POWER PLANT RESPONSE TO INSPECFION REPORT 317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION I
The vendor's technical manual recommends a surveillance test slow start (gradually increasing engine speed to the-rated speed over a period of 2 minutes) every 14 days, based on our engines having the original: keep warm design. The STI report cites a recommendation of once per 31 days, and implies this to mean a maximum surveillance.
Calvert Cliffs is fully aware of both the vendor's recommendations and the issue of reduction of EDG starts to minimize engine wear and increase reliability and longevity. Ilowever, the." Maintenance and surveillance testing program" section in the vendor's technical manual are minimum recommendations. The STI report further discusses an above average number of engine starts for Calvert Cliffs. The report acknowledges the principle reason for 'the excessive starts is the inability in' the system ~ design to test the safety injection actuation signal (SIAS) and undervoltage UV relay contacts without starting the engine. Facility Change Request (FCR)88-034 was initiated to ' address these concerns. However, the STI report indicates that implementation of this FCR will allow SIAS and UV testing totally without engine start. This is not correct. Certain tests require two engines to start. The present design change requires an EDG to be taken out-of-service in order to utilize the test handswitch. Since by current Technical Specification requirements, we cannot take both EDGs (for a unit) out-of-service at the same time, we must start one EDG during these tests.
FCR 88-034 addresses the STI report's specific concerns. The status of the FCR is as follows:
o All the hardware is installed on each EDG. Only the electrical leads need to be connected.
o The Engineering Test Procedures for each EDG, which functionally test the FCR, have been reviewed by our POSRC.
o Operating Instructions and STP revisions need to be Ceveloped prior to connecting the electrical leads.
Corrective Actions l
In a subsequent response to this Inspection Report (no later than July 20, 1989), we will provide a reasonable ECD for completion of FCR 88 034. This FCR is considered a long-term corrective action.
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I llG & E No.12-310 Vol.
2, Ch.
2, Section 1: " Maintenance and Surveillance Testing Program," dated July 18, 1986, Rev. 1 -
ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 I
SPECIAL TEAM INSPECTION UNRESOLVED ITEM NO.13 Program Weaknesses Associated with the Calibration of Permanently Installed Plant Equipment Our calibration program for permanently-installed plant equipment is scheduled and controlled by our preventive maintenance and surveillance programs. There is no master-calibration / plant usage matrix which combines the pertinent information. Also,'
our use of calibration stickers was discontinued in 1980 and subsequently recommenced in 1987. As a result, the use of calibration stickers throughout the plant is inconsistent.
- Finally, STPs which use permanently-installed equipment do not consistently log the calibration performance dates or calibration due date for the instruments used.
Corrective Actions We have completed our review of the concerns identified within the STI report. The following long-term corrective actions will be taken:
o Our Performance Engineering Unit will develop a matrix of all process instruments used for data collection by STPs. This matrix cf critical process instrumentation will be verified againct our PM and STP calibration program to verify that all critical instrumentation is contained within the calibration program.
(Operations STPs will be completed by December 31, 1989, remaining STPs will be completed by
. March 31,1990.)
o Following verification, we will consider modifying our QAP and removing calibration stickers from installed process instrumentation.
UNRESOLVED ITEM NO. 14:
No Administrative Mechanism to Ilandle Minor Modifications Presently, there exists no administrative mechanism to handle minor modifications.
Therefore, minor modifications require a full engineering evaluation. The team was concerned that the large administrative workload required by our modification procedures could potentially lead to attempts to circumvent the modification process.
Corrective Actions l
We agree that the present engineering design process does not have the flexibility to tailor the level of design input to the complexity of the modification. However, we have not identified any instances of intentional, unauthorized modifications. As a long-term corrective
- action, our PIP does include the development of a _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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ENCLOSURE (1)
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CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION l
l minor-modifications program which will improve the efficiency of the engineering process. As discussed in our response to Unresolved item No.
4, our P7P will also address safety reviews of all activities.
ADDITIONAL CONCERNS:
The following is a summary of additional concerns identified in the STI report, as well as our corrective actions.
1.
The report acknowledged continuing examples of procedural non-compliance.
Corrective Actions As discussed in our May 23, 1989 letter (Mr. G. C. Creel to NRC Document Control Desk, Restart Commitments), we will communicate to employees our work priorities, the need to control work activities, and to adhere to procedure.e. We will also determine and correct the root causes' of our recent procedural non-compliances prior to the start-up of either unit.
2.
The team walked through Abnormal Operating Procedure (AOP) -9, " Alternate Safe Shutdown Control Room Evacuation Procedure." This AOP requires extensive operator (licensed and non-licensed) actions throughout the plant.
Presently, our training on AOP-9 consists of ' independent classroom training and procedure walk-through training for licensed and non-licensed operators. A recommendation was made to conduct AOP-9 walk-through training with both licensed and non-licensed personnel trained together.
Corrective Actions As discussed in our May 23, 1989 letter, we are presently evaluating potential weaknesses in our AOP-9.
We will revise the procedure.
Following revision of AOP-9, training will be provided, as necessary, prior to the startup of either unit. As a long-term corrective action, licensed and non-licensed operators will be trained together on AOP-9 at least once every training cycle. - - _ -
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ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO. INSPECTION ' REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION 3.
. Our corrective action process was identified to have weaknesses in:
- Initiation of Non-Conformance Reports (NCRs) when appropriate,
. Timeliness in responses to NCRs, Root cause analysis, Assessment of safety significance, and Corrective and Preventive Acthus.
Corrective Actions-We agree with the STI team's assessment of our corrective action process.
In the past, the threshold for initiating Calvett Cliffs' NCR program was too high. This created the perception that either Operations or Quality Control were the sole initiators ' of the corrective action process.
Although recent improvements have been made (e.g., NCRs are now being issued for procedure failures as well as equipment failures),' further improvement is necessary. Our MO and PM processes do not specifically provide a mechanism for initiating root cause analysis or evaluating generic applications of identified deficiencies.
The following short-term corrective actions will be completed prior to the start-up of either unit:
o CCI-ll6 (Control of Deficiencies and Non-Conformance Reports) has been rewritten and will be issued followiag review by our POSRC.
This CCI revision was being developed during the STI inspection, but was not reviewed by ~the tea:n since it was still in the. draft form.
o All General Supervisors will re-enforce the purpose and proper threshold of NCRs to their people.
As a long-term corrective action, this issue is being addressed by the PIP.
4.
Although interface, support, and qualification of engineers was perceived to be improving, weaknesses were noted in the experience of our system engineers.
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ENCL,OSURE ilf CALVERT CLIFFS NUCLEAR POWER PLANT
' RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION l
Corrective Actions As a long-term corrective action, this issue will be addressed by the PIP.
5.
The process for determining post-maintenance testing requires operators to detennine all post-maintenance testing. The process is cumbersome and places a significant burden on the operator due to the large number of Maintenance Orders processed during a typical outage.
Corrective Actions The following corrective actions have been taken:
o A comprehensive Post Maintenance-Testing (PMT) Program has been developed to verify that the deficiency covered by an MR has been corrected. This PMT, which is. administered by maintenance, is
. separate from, and in addition to, the Operational Test performed by Operations.
o A PMT Guide was recently issued with all Mechanical Modules. The PMT guide provides a matrix for-each component type to help determine what PMT will be required for each maintenance activity.
o The Nuclear Maintenance System software change which allows for PMT to be a part of every MO has been tested and implemented. Every MO now contains a PMT Document which outlines the PMT require-ments for the individual MO.
o-The controlling administrative document, CCI-200, has been revised to control the PMT process, and will become effective July 1, 1989.
1 The remaining short-term corrective action will be completed prior to the start-up of either unit:
o The E&C Modules will be completed and combined into the PMT
- Guide, i
As part of our long-term corrective actions, the training lesson plan will be completed by July 1989, and training to this CCI will be as outlined by the PIP Procedure Upgrade Project.
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ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT
-1 RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200-1 SPECIAL TEAM INSPECTION 6.
A concern was raised regarding use of a marked-up procedure (STP-O-9-2,
" Auxiliary - Feedwater (AFW) Actuation System, Monthly Logic Test) to 1
verify the operability of an AFW pump following a fire in an AFW pump i
trip switch.
Corrective Actions This concern (related to non-intent changes) is being addressed through our final ' resolution of Unresolved item No. 2.
7.
Many weaknesses were identified in the Procedure Upgrade Project.
Corrective Actions Management has and will continue to periodically re-enforce their procedure compliance expectations to all site personnel. The VP-NED has met with all site supervision to state his expectations. Each Department Manager has formulated and implemented procedure compliance action plans tailored to their individual needs. The Quality Assurance Policy has been revised to include clear guidance on procedural compliance for all personnel involved in our nuclear program. The Manager-Celvert Cliffs Nuclear Power Plant Department recently issued a
letter to all personnel in his department reiterating his personal expectations. Continuing this process, the VP-NED has issued a similar letter to all Division personnel stating his expectations on this vital issue.
The Procedures Upgrade Project has and will continue to receive the highest priority accorded to any task in the PIP. Consistent with this priority, production of state-of-the-art procedures embodying instructional
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visual aids, and other requirements to enhance their usability is now being accomplished within all disciplines.
We consider the development of superior procedures to be a dynamic process.
The state-of-the-art in procedure development is continuously evolving. We intend to keep abreast of developments in this area, and revise our program as required.
To facilitate this
- process, we have contracted with Operations Analysis, Inc. to provide a managerial overview of the project.
This report has been received and its recommendations will be utilized to enhance our program. Similarly, we have contracted with Arthur Anderson, Inc. to review our process for procedure preparation with particular emphasis applied to enhancing our quality and productivity through use of advanced computer hardware anri software. We also intend to add at least one contractor to the project team who has participated in major procedure i
l upgrade efforts at other facilities. This individual, who we anticipate to l C __ __
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ENCLOSURE (II
' CALVERT CLIFFS NUCLEAR POWER PLANT l-RESPONSE TO. INFPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION be on-site in J uly, will function as assistant to the project manager. In addition to the above initiatives, appropriate liaisons ' have been i
established with personnel conducting procedure upgrades at other sites.
The resulting exchange of information, sample procedures, writers guides, etc.,
should prove mutually beneficial.
At present, the training.and experience level of our maintenance personnel
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.and supervision are sufficient to ensure the safe and effective conduct of plant maintenance. These personnel have been instructed - by. Management to remain : cognizant ' of ~ their limitations in this area. Should they confront a situation requiring detailed procedural guidance or-if they believe.
available guidance is incorrect, the job will be stopped until adequate -
guidance is obtained.
We have_ recently moved to strengthen the project management of this project by assigning an individual as Project Manager charged with gaining stronger control, direction and consistency of managing it as a project.
Completion of the Procedure Upgrade Project, currently projected for January 31, 1991, will provide detailed, technically correct and useable procedures to each dicripline.
8.
The Project Management Mar.ual does not provide a readily understood definition - of functional ' responsibility or accountability.
In
- addition, accountability' for project completion is diffused and not clearly defined.
Corrective Action As a long-term corrective action, this issue will be addressed by the PIP.
9.
The STI team noted weaknesses in our inventory of safety grade spare parts.
Corrective Actions As a long-term corrective action, this issue is being addressed by our PIP.
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CALVERT CLIFFS NUCLEAR POWER PI. ANT j
RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 l
SPECIAL TEAM INSPECTION -
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Goals, expectations, and priorities need to be clearly communicated by Management.
1 Corrective Actions Prior to the start-up of either unit, we will itemize and prioritire near-term work on the PIP and each unit's outage. This will include developing and implementing a work schedule that integrates the PIP items and all commitments related to startup with the outage and major daily work activities.
In addition, the following actions have been completed:
o Our Nuclear Program Plan for 1989 has been developed and published.
o Our VP-NED continues to meet with employees to communicate his goals and expectations.
o Meetings on the PIP and Management's expectations have been held with all NED employees.
o We have extended the outage for Unit 2. This has allowed us to slow down work and gain a tighter control of work. activities.
Our long-term corrective actions are related to the PIP.
11.
Equipment Status Log While conducting Control Room ' observations, the team attempted to obtain the current status of equipment which. was out-of-service. There did-not appear to be an equipment out-of-service log. Equipment out-of-service resulting in a Technical Specification ' Limiting Condition for Operation (LCO) Action Statement was logged in the Control Room Operators' log. A
- computer printout showed what was danger-tagged out-of-service. The team pointed out that systems or components could be placed out-of-service without a tagout and without entering an LCO Action. Statement. The team suggested as an improvement item, the licensee consider having some form of equipment out-of-service status readily available to the operators.
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ENCLOSURE (I) q CALVERT CLIFFS NUCLEAR. POWER PLANT RESPONSE TO INSPECTION REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTION Corrective Actions We concur with the team that this is an area for improvement. Prior to the start-up of either unit, we will develop an equipment-out-of-service list and instructions for controlling the list. These requirements will be incorporated into CCI-307 (Nuclear Operatio' s Shift Turnover Checklist).
Training on these requirements will be provided to operators.
12.
Calvert Cliffs Instruction CCI-104I,
" Surveillance Test Program" establishes the responsibilities and administrative requirements for the surveillance testing program. The team reviewed CCI-104I and found that the responsibility for implementation ' of the surveillance test program was divided among various groups at the plant (e.g.,
operations, maintenance).
The procedure specified that a single individual be responsible for the overall administration of the prograrn;
- however, the various groups independently scheduled, coordinated, and bore responsibility for their - own surveillance activities. CCI-104I appeared to be very detailed and complex for the administrative nature of such a document. The use of lower tier group implementing procedures or a more centralized and consistent program could help ' eliminate implementation inconsistencies and diffused responsibilities that existed in the program. The team found that we had identified this concern as an area needing improvement, and substantive changes to the surveillance testing program were - being made, but were not yet implemented.
Corrective Actions The STI Report provides an accurate assessment of the current surveillance testing program administrative status.
The current administrative configuration of the surveillance testing program described in the STI Report has not had any direct adverse effect on nuclear or personnel safety. However, the administrative nature of the surveillance testing program has resulted in scheduling problems and confusing and occasional
'1 ineffective program implementation.
As part of the Calvert Cliffs Performance Improvement Plan, on June 5,1989 l
a future STP organization was announced,' consisting of Functional Test l
Coordinators reporting to a Site Surveillance Test Coordinator in the l
Perforr.,ance Engineering Un'it.
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. ENCLOSURE (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE 'IO INSPFCflON REPORT 50-317/89-200; 50-318/89-200 SPECIAL TEAM INSPECTsON The following short-term corrective actions will be completed prior to the start-up of either unit,'we will:
o Complete the revision and approval of CCI-104.
o Complete - training of the. interim surveillance testing program organization consisting of Functional Test Coordinators for the Operations, Mechanical, Fire Protection, In Service Inspection and Snubber areas.
o' Impler tent the interim surveillance testing program organization consistlag of Functional Test Coordinators for the Operations,.
Mechanical, Fire Protection, inservice Inspection and Snubber areas.
O Begin the upgrade of all surveillance tut procedures.
Our long-term corrective actions are as follows:
o We will train the Electrical and Controls STP Functional Test Coordinator and implement the new organization by October 1,1989.
O All surveillance test procedures will be reviewed and revised as applicable per the guidance being developed in the revision to CCI-104. This is part of the PIP Procedure Upgrade Project.
o A
basic computerized schedule
.of-operations surveillance tests (without exception reports) is currently under development by the Site ' Surveillance Test Coordinator ar.d is expected to.be functional by-October 1,
1989.
Further refinements including exception reporting will be completed by December 1,
'1989. Computerized scheduling of all surveillaixe testing will be completed by June 1, 1990.
o A manual trending system has been developed and implemented for operations surveillance test data.
A computerized trending application for operations surveillance tests is scheduled for development and implementation by December 1,1989. All surveillance test data suitable for trending will be added to the automated application by June 1, 1990.
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CALVERT CLIFF 5 NUCLEAR POWER PLANT.
l RESPONSE TO INSPECIlON REPORT 50-317/89-200; 50-318/89-200' l
' SPECIAL TEAM INSPECrlON l
We are presently reviewing the following weaknesses noted in the STI report. We will provide an' additional response no later than. July 20, 1989 which details our corrective
- actions, o
Maintenance. of non-safety-related equipment was ' ' perceived to need improvement. This was based on discussions with personnel from Operations, o
Some instances were noted in which overtime guidelines contained in our CCI-140 (Shift Staffing) were exceeded.
o The team reviewed our Control Room Operators' logs and found them to be informative and provided a clear chronology of events. Our CCI-il4 (Plant Logs) was described as providing excellent detailed instructions for keeping Control Room Operators' logs. However, our Control Room log entry detail was noted to oe lacking in the action taken and final resolution of problems.
o The report identified eight cases of material deficiencies, of which none appeared to affect the operability of any system or component. In each case, a Maintenance Request (MR) was initiated by Calvert Cliffs to evaluate each identified deficiency. A conclusion was drawn by the team that additional emphasis on identifying and correcting - similar material deficiencies was needed.
O Instrument piping for the low-pressure side ot' Unit One main feedwater regulating. valve differential pressure de*cetors (PDT-4516 and 4517) was not installed as shown on drawing 60 ~02-E, Revision 10.
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