IR 05000317/1988001
| ML20148A911 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/11/1988 |
| From: | Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20148A904 | List: |
| References | |
| 50-317-88-01, 50-317-88-1, 50-318-88-01, 50-318-88-1, NUDOCS 8803210238 | |
| Download: ML20148A911 (59) | |
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U.S. NUCLEAR REGULATORY COMMISSION- i
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Region I Docket / Report: 50-317/88-01 i 50-318/88-01 i
Licensee: Baltimore Gas and Electric Company Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 i
Inspection At: Lusby, Maryland [
Dates: January 19 - 29, 1988 ;
l Team Leader: Lowell Tripp, Chief, Reactor Projects Section No. 3A i Division of Reactor Projects (DRP) f
Inspectors: Cornelius Holden, Senior Resident Inspector - Maine Yankee l Scott McNeil, Project Manager, Office of Nuclear Reactor l Regulation (NRR) ;
Peter Koltay, Senior Resident Inspector - Indian Point 3 l James Prell, Reactor Engineer, Division of Reactor ,
Safety (DRS) ;
N 8. Le, Operations Engineer, NRR !
Andra Asars, Resident Inspector - Haddam Neck l August Spector, Management Development Project Manager, !
ffice of Person el r Approved By: No JgmefT.Wiggins,Chie'.
M 3'Date
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i Rhettor Projects Branc . 3 - Team Manager !
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Summary: January 19-29. 1988: Combined Inspection Report Nos. 50-317/88-01 !
and 50-318/88-01 Areas Inspected: (1) plant operations, (2) maintenance, (3) engineering sup- f port, (4) surveillance, (5) licensee overview activities (management coordina- ;
tion and control, quality assurance, plant operations safety review committee, !
offsite safety review committee, etc.), and (6) organization and interface ;
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Inspection hours totalled 61 j I
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8803210238 880311 !
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Summary (Continued) 2
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Results: The team's findings indicated generally good performance with posi-tive findings regarding the performance of operators, safety overview provided by the onsite and offsite safety review committees, management initiatives to under-stand and improve performance and the amount of detail in completed maintenance work package One violation was identified in the Surveillance area concern-ing temporary procedure changes and their review and approval (Detail 5.e).
One unresolved items was identified in the Engineering area concerning the precision of the inservice testing of the Salt Water Pumps (Detail 4.b). Weak-nesses were identified in housekeeping in selected areas of the plant (Detail 2.b) and inadequate control and coordination of troubleshooting activities (Detail 3.d).
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TABLE OF CONTENTS f Integrated Performance Assessment Inspection l at Calvert Cliffs Nuclear Power Plant (Inspection Report 50-317/88-01; 50-318/88-01) l
Page i verview.................................................... .1 l i Plant Operations (I.P. Nos. 71707, 71710 and 71715)......... 1 !
! Plant Status........................................... 1 l Plant Tours and Housekeeping........................... 2 i Operator Performance................................... 4 ' Operations Interface................................ .. 5 Summary................................................ 5 l 1 Maintenance (I.P. Nos. 62700, 62702 and 38701).............. 5 !
I Maintenance Progra .................................. 5
! Communications......................................... 8 ) Ma i n te na nce Work Orde r Bac kl og . . . . . . . . . . . . . . . . . . . . . . . . . 9 ! Troubleshooting Process and Management Control......... 9 ) Preventive Maintenance Program......................... 11- Overall Maintenance Summary............................ 14 Engineering Support Activities (I.P. Nos. 37700, 37701 and .
i 37702).................................................... 14' t i Engineering Support.................................... 14 i Engineering - Operations Interface..................... 15 i Engineering-- Maintenance Interface.................... 19 i
- Processing of Facility Change Requests................. 20 .i Control of Technical Manuals............................ 21 i Independent Design Reviews............................. 21 Summary................................................
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t Surveillance Testing (I.P. Nos. 61700, 61725 and 56700)..... 22 !
'i Surveillance Test Program Implementation............... 22 l Surveillance Test Observations......................... 24 I Review of Completed Surveillance Test Programs......... 24 Summary................................................ 26 l
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Table of Contents (Continued)
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Page Licensee Overview Activities (I.P Nos. 40700, 40701, 40704 and 35701).......................................... 26 Plant Operations and Safety Review Committee........... 26 Offsite Safety Review Committee........................ 28 Safety System Functional Inspection.................... 29 Quality Audit Unit..................................... 30 Communications Meetings................................ 31 Summary................................................ 31 Organization and Interfaces (I.P. Nos. 36700 and 40703)..... 31 Communication System................................... 31 Decision Making System................ ... ............ 32 Accountability System....... .......... ............... 33 Reward / Recognition System.............................. 33 Reporting Relationship System....... ........... ...... 33 Cultural / Behavior Norm System............. ... . ..... 34 Summary..... .......................................... 34 Exit Meeting (I.P. No. 30703). ................ ............ 35 Attachment 1 - Persons Contacted Attachment 2 - Additional Details Regarding Review of Organization and Interfaces Attachment 3 - P0RSC Documents Reviewed Attachment 4 - OSSRC Documents Reviewed Attachment 5 - QAU Documents Reviewed
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DETAILS 1. Overview As a result of Calvert Cliffs performance over the past 2-3 years, the recent Systematic Assessment of Licensee Performance (SALP) Board recom-mended an Integrated Performance Assessment (IPA) inspection be conducted to better understand licensee performance. The IPA focused on a number of functional areas with primary emphasis on interfaces between Operations, Maintenance and Engineerin Additionally, the team reviewed the effee-tiveness of available tools (i.e., trending / tracking mechanisms, manage-ment oversight activities) in identifying emerging plant problems, ade-quacy of resources in maintenance and engineering, effectiveness of sur-veillance testing program in assuring equipment reliability and procedural i use and adherenc . Plant Operations This area was reviewed during routine inspection by the team throughout the period and included around-the-clock shif t observations by team mem- ,
bers during the period January 20 through 25, 1988. Many of the inspec- l tion and monitoring activities were performed during windows of oppor-tunity (e.g., shift turnovers, plant evolution, ongoing maintenance and ,
surveillance, followup to events, etc.) as well as the normal daily '
activities performed by the on duty shif ;
i Plant Status
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Units 1 and 2 were operating at 100 percent when the team arrived on- l site. On January 21, 1988 Unit 1 power was reduced to 97 percent in I order to remove the second stage Main Steam Reheater from servic l Plant maneuvering was performed in a smooth, deliberate manner. Unit I 1 remained at 97 percent power for the remainder of the inspectio At 9:58 a.m. on January 22, 1988, Unit 2 tripped from 100% power due i to low steam generator level. The initiator of the low level condi- i tion was a loss of power to both main feedwater pump and the moisture separator reheater (MSR) shell and MSR first and second stage drain tank level control systems. This caused the main feedwater pumps to hold at a constant speed. It also caused the MSR shell and drain tank inventories to dump to the main condenser instead of ultimately flowing to the heater drain tank Heater drain tank (HDT) levels lowered, resulting in HDT level control valves shutting, reducing flow to the main feedwater pump suctions. Less feedwater was then pumped to the steam generators (SG) and SG levels fell. Electrical
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and ' Controls personnel performing a troubleshooting operation on the l Unit 2 computer inverter introduced a phase-to phase short on 120 VAC - '
instrument power bus 2Y10 which caused two inverter supply fuses to .
blow and the feeder breaker for 2Y10 to open. The plant was quickly i stabilized and plant systems performed as designed. The plant was [
returned to power operation at 11:15 p.m. on January 22, 1988 with .
the affected inverter disconnected from 2Y1 ;
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power factor correction capacitors from the circuit ~ as a part of i their inverter troubleshooting effor The inverter was being powered from the AC backup power source (2Y10) at the time. Due to :
a combination of unclear communications between technicians and the j vendor regarding the means of removal of the capacitors and .an l unclear vendor print, technicians installed jumpers around the capacitors which effectively created a short circuit pat More -l information concerning this troubleshooting is contained in Section .
3.d of this report. Plant operators reacted swiftly to the ' loss of i 2Y10 and were ready to crossconnect this bus prior to the trip. How- -
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ever, concerns over crossconnecting a normal bus to a bus- that had a potential problem prevented taking this actio A manyal trip was i initiated, however, the automatic low level trip occurred firs ;
Operator response to the plant trip was good in all areas reviewe ;
Inspectors reviewed the preparations for plant restart. Unit 2 was i taken critical at 11:10 p.m. o'n January 22, 1988 and returned to full '
powe Unit 2 remained at full power for the remainder of the '
inspectio l Plant Tours and Housekeeping l During the inspection period and specifically while observing shif t l crew activities from January 21 through 25, the inspectors conducted ;
tours of all accessible plant area Several tours were taken with l auxiliary operators. During the tours the inspectors evaluated rou- !
tine activities conducted by auxiliary operators, general housekeep- !
ing and radiological controls and. practice l t
Auxiliary building operators were found to have a detailed under- !
standing of the plant and were knowledgeable of existing plant condi- !
tions. Throughout their tours they generally maintained close com-l munications with the control room, and responded to the reactor i operators' request l
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Plant housekeeping appeared to be inconsistent with conditions rang-ing from very good in areas such as the ventilation equipment rooms to poor in areas such as the five foot elevation east penetration room for Unit The following observations - were made by the inspectors in the area of housekeeping:
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Switchgear rooms .and cable spreading rooms located on the 27 foot elevation and switchgear rooms located on the 45 foot ele-vation of both units contained loose tool / test equipment carts and portable work benches on wheels, rolling lifting rig movable cabinets, and loose ladders. The extraneous equipment exposed both safety and non-safety related switchgear and electrical cabinets to potential hazards during a seismic event of being impacted by the movable equipment and causing damag The Unit 2, 5 foot elevation east penetration crea contained loose lagging materials, tools and debris. The area was also being used for storage of scaffolding materials randomly piled in open floor area The intake structure was also poorly maintained with debris stuffed into cable trays and in junction boxes and scaffolding placed in the :rculating water pi The inspectors noted that metal scaffolding erected to facilitate maintenance and/or equipment operation is routinely left in place long after the conclusion of the maintenance activity. Scaffolding in the Emergency Core Cooling System (ECCS) pump room, charging pump room, ECCS ventilation rooms and the component cooling water pump
. room was erected between September and December 1987. According to the operators, scaffolding in the Unit 2 waste gas decay tanks area has been in place for several years. In all instances the ' scaffold- i ing is next to or straddles safety related equipment. The inspector I reviewed licensee procedures governing maintenance activities:
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CCI 2000, Nuclear Maintenance System
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CCI 200E, Maintenance Procedures These procedures were found not to address the removal of scaffolding from work area The inspector discussed the scaffolding-related problem with ; civil engineer responsible for assessing seismic impact on plant equipmen The engineer stated that scaffolding is assumed to be removed immedi-atsiy following maintenance, generally completed during plant out-ages. Therefore, seismic impact on safety related equipment located adjacent to scaffolding is not routinely evaluated by the license All of the above items were discusred with licensee management. While some corrective actions in the area of housekeeping have been initi-ated, long term programmatic improvements in all areas are neede l
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The licensee's decontamination efforts appear to be minimal in the areas of the ECCS pumps. Thus routine access- to the. pumps is curtailed by roped off areas. and requires the use. of protective clothing. Since the pumps are inspected several times per. shift, each inspection generates additional radioactive waste. Due to the lack of prompt removal, -the trash was observed overflowing onto the floor around receptacles located at stepoff pads. -Additional licensee attention appears warrante ~
The unsatisfactory housekeeping and material conditions noted in several areas as discussed above are considered collectively to be indicative of a licensee weakness (50-317/88-01-01; 50-318/88-01-01),
c. Operator Performance The day to day performance of the operators, both in the control room and in the plant, was very good. Shif t turnovers appeared thoroug System knowledge level of the operators was good and the operating crews have a high level of experience at the plant. Contributing to the strong performance of on-shif t personnel was the use of licen-sed and non-licensed operators in support functions including Operations Maintenance Coordinator, Surveillance Coordinators, Pro-cedure Reviewers and tagging activities. The overall effect has been
, the minimizing of the number of control room interruptions and pro-viding for communication flow to the operators. Additionally, admin-istrative controls used to control the personnel who must enter the control room for approval of work packages appeared effective and resulted in minimizing the distraction of the operators' attentio Operator's response to the initiating event and subsequent recovery activities for the Unit 2 trip on January 22, 1988 were very goo Operators responded to the initial loss of bus 2Y10 and were ready to crossconnect this bus and restore power. However, since the oper-ators did not know the cause of the fault on bus 2Y10, they did not want to connect it to a different power supply. The plant tripped about one minute before the nature of the fault was identifie Immediate actions and recovery from the plant trip were goo Procedure use and adherence by operators was observed to be . goo During surveillance and routine watch activities, the operators used plant procedures. When questioned, operators were familiar with plant equipment and the intent of the procedures. Day to day per-formance of the operations staff was considered to be a strengt . - . - _ . _ _ - . _ _ . . - . - . -
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. Operations Interfaces Routine maintenance is planned through the planners and results in a computer printout which includes major maintenance and surveillance items from outside the operations are (Operations surveillances are scheduled through the Operations Surveillance Coordinator and a separate schedule is generated for control room use). Shop Planners and the Operations Maintenance Coordinator meet at 6:30 a.m. each morning to discuss possible schedule conflicts and prioritize main-tenance and surveillance activities. At 8:00 a.m. the General Super-visors meet to discuss major job statu The General Supervisor of Operations leads this meeting and can focus additional attention when needed. At the end of each day the tagging group receives the tag-ging requests for the next day and the time when work will be ready to commence. Using this information, the tagging group prepare tagouts for the next day. Once the job is approved by the control room, the taggers will remove a system or component from service. and tag out the equipment. Plant operators are generally not used to tag equipment out of servic Summary The Operations Department has a well qualified and knowledgeable staf Support functions help reduce the interruptions in the con-trol room to a minimum. Interface activities with other departments allow the General Supervisor of Operations to adjust the priority of other departments in support of operations activities as well as coordinate plant conditions for other departments. However, house-keeping and some radiologically contaminated areas need licensee attentio . Maintenance The inspection team reviewed the maintenance program, associated procco-ures, work controls and equipment history, as well as the material condi-tion for various areas in the plan ;
The licensee preventive and corrective maintenance efforts for maintaining the reliability of plant equipment were reviewed with special emphasis on .!
-the interfaces between the maintenance organization and other department l l Maintenance Program .
J Revision J to Calvert Cliffs procedure CCI-200 provides an overview of the actions necessary to implement and complete maintenance work using the "nuclear raintenance system". This system collects a detailed data base of active maintenance activities such as Mainten-ance Requests (MR's) and Maintenance Orders (M0's). Detailed infor-mation is retained for a period of two years, but for permanent
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J record retention, only abbreviated history data extracted from the Nuclear Information System (NIS), are retained -for plant histor ;
The data are recorded on reels and tapes and are retrievable by using the appropriate Record Set Identifier (RSI) numbers, j t
The inspector had the following observations during the review o'f the !
licensee overall work flow and work control: >
(1) The licensee had no written detailed guidance for maintenance :
planners for post maintenance testing in CCI-200 As. a i result, post maintenance testing requirements are determined by ;
individual planners based on their knowledge of the equipment or
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syste A procedure called "Operations Unit Administrative Policy 85-4 dated September 23, 1985" was used to provide i However, their determination may be inconsis-
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further detai tent as a result of the lack of guidance in this are For major tasks such as equipment replacements, major refurbishments l or overhauls, the design bases for such equipment might not be '
demonstrated and analyze This could diminish the capability
or reliability of plant equipment, however, no instances were identified where th% had occurre l t
(2) The Operations Department makes the final determination as to which maintenance orders (M0's) will require operations testing (OPTEST). The inspectors reviewed a number of completed M0 packages and noticed that post maintenance testing, as recom-meded by Maintenance, was sometimes waived by Operations without ;
any documented justifications or analyse Nost OPTESTS were satisfied by using all or parts of certair Surveillance _ Test Procedures (STP's) and test results were sent to appropriate ,
system engineers whereas OPTEST forms were forwarded to the ;
r Nuclear Plant Documentations Group for recordkeeping. Procedure CCI-200J does not specifically differentiate betwen post main- .
tenance testing requirements _ and operations test The inspec- i tor further observed that the responsible system engineer was i not involved in the review of the MO packages:during planning, l and therefore was not a party to the determination'of what post !
maintenance activities were required. Currently, maintenance QC !
staffs are reviewing the M0 packages in the mechanical area for -
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information and if required, for additional hold points. How- i ever, QC was not involved in the reviewing of electrical'or I/C ;
packages for hold point !
(3) The inspector had the following additional observations in the I/C area:
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- Licensee management indicated that the turnover rate in the :
I/C area was high during the past few years. This was due ;
to a number of craf t personnel that had left the company, or were moving to other positions in the plant for cross i training or to secure a more stable' aon-shift workin ,
schedul *
Interviews with operations staff and QC management indi- I
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cated that the current QC inspectors have little or no prior plant I/C experience which would help assure meaning- ',
ful QC coverag '
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- Current craft supervisors (General and Assistant' General ;
Supervisor levels) were new in .their positions -and had :
little or no previous I/C experienc l
- The inspection team noted a total of more than 150 defici- .;
ency tags posted in the two unit control roo *
Interviews with operations staff personnel revealed that a j number of instruments in the control room had to be ;
reworked in the recent pas The inspection team noted that these concerns individually might !
not be significan They indicate past problems with turnover j and experience levels in the I/C department which appears to e have affected performance. Collectively, the last two findings !
listed above m;ght hinder the operators' ability to cope with i plant transient conditions or other design basis events, i
(4) The inspectors reviewed several completed Maintenance Order i Packages (M0P's) and noted the following observed strength; i
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The packages contained good work ~ descriptions of what was ;
completed in the fiel The team concluded that this !
information should facilitate turnover between shifts, pro-vide better communication among organizations that review '
the packages, and serve as good references for future work or equipment machinery histor !
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The packages provided the inspection team with evidence of l active QC involvement in establishing hold points and !
imposing stop work orders. The team reviewed QC inspection i records and noted that NCR's were written as required. The inspector noted NCR-7296, Class A, which was used to docu-ment any observations where plant as built does not agree with the desig The licensee was in the process of development and i:.iplementation of a comprehensive plan to improve plant configuration management. This NCR was beir; used as the vehicle to resolve configuration discrepancie This area will be monitored in future inspection . _ _ - . _ _ . - . . . - . ._- . . - . . . ~. - _, .-
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. l b. Communications ,
The inspection team observed.that the licensee.had established a num-ber of meetings to facilitate communications and work ~ awareness among~ l involved plant personnel. The following are descriptions of various 1 meetings that were taking place during the time that the inspection team was onsite:
(1) The 6:30 a.s. daily meeting: the purpose of this meeting was to distribute MR's to the appropriate shops with the emphasis on priorities. This meeting was attended by the following plant I staff: 1
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Ass stant General Supervisors (AGS)
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Senior planners in different areas (disciplines)
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Suptrvisors from Radiation and Safety Protection
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Senice QC inspectors ,
Operations Maintenance Coordinator (OMC)
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- i (2) The 8 a.m. daily meeting: the purpose of this meeting was to i provide briefings ta craf t General Supervisors (GS) and Depart- l ment Managers on everyday problem The following managers and '
their representatives attended this meeting: j
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GS for Mechanical
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GS for Electricel/ Instrumentation
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Lead Engineer - systems
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GS for Operations
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OMC Supervisor
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QC Supervisor
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Radiation and Safety Protection Supervisors
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Chemistry Supervisor
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All Department Managers (3) The 11 a.m. (Project 2) scheduling meeting (WW/F). this meet-ing was attended by planners to coordinate and schedule upcoming work planned for the next two week It covered . Preventive Maintenance, Corrective Maintenance, Surveillance Tests, Facilities Change Requests and other non-routine work- that was neede The following staffs attended this meeting:
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(4) The Forced Outage Work List (F0WL) meeting: this meeting was held every Thursday at 1 p.m. to develop and maintain a list' of i tasks that could be performed in the event'of a forced outag l Personnel attending this meeting were mostly outage -_ planners, ,
senior planners of respective crafts and the Operations Mainten- !
ance Coordinator (OMC). ;
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These meetings appeared to be effective in providing proper prior:t- :
ization of activities and 'in resolving emerging plant problem ~i
' Maintenance Work Order Backlog The inspector reviewed the. licensee monthly work that was completed and other information from the licensee's performance indicators. As of the end of the 4th quarter in 1987, the licensee had the following j
i backlog of work (both PM and CM): ,
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Mechanical Maintenance 5 weeks without delay i 6 weeks with delay- !
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Electrical Maintenance 2 weeks without delay ;
3 weeks with delay !
i I/C Maintenance 2 weeks without delay 5 weeks with de_ lay j Delays were typically due to t'.e awaiting of engineering resolution !
or to material unavailability because of required lead and processing time. Interviews with planners indicated that the final processing i organization for material procurement is located at _ the licensee' -
corporate headquarters in Baltimor This. office may not be - cog- E
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, nizant of the plant priorities possibly due to the lack of a formal feedback mechanism in the procurement process (See Attachment 2, ;
Pages 8-10). ! Troubleshooting Process and Management Control At the time of this inspection, the licensee had ~ no formalized pro- f cedure to provide detailed guidance for_'craf t personnel to perform :
troubleshooting. Craft management indicated to the inspector that if j maintenance problems were identified, they would use the FAS Teams i (Find Answers and Solutions) for quick response to problems. The . !
licensee also used the "System Quality Circle Experts" team concept j to sclve difficult maintenance problem ~s. In these cases, technical ,
experts from Nuclear Engineering . Services Division (NESD), Nuclear !
Maintenance Division (NMD) and Nuclear Operations Division _ (NOD) {
staffs and the appropriate system engineer would form a tem to fi,1d solutions and provide solutions to the Maintenance Department for- '
implementatio l
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Because there were no formalized troubleshooting. procedures, craft: ,
personnel were left with little guidance in the field. On January 22, ,
while the team was onsite, the Unit 2 reactor tripped as a result.of
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troubleshooting activities for a non-safety-related electrical inver- ,
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ter that powered the Unit 2 plant computer. Subsequent to this trip, the inspection team interviewed the involved craf t personnel, their ;
supervisors, and the responsible engineer. The team noted the fol-lowing weakness (50-317/88-01-02; 50-318/88-01-02) with the licen-see's troubleshooting practices: f a Craft workers were provided with a General Maintenance Order ;
(MO) and little other guidanc ,
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- No precautions or specific control of parameters and bounds dur- i ing troubleshooting were specified in the M0' * The licensee did not appear to have performed a detailed inves-tigation of the job documented in the M0 as required by CCI-117 ,
prior to wor *
Conservative steps such as checking for grounds or sneak -ir-cuits were not use * There were communication and interface problems with the vendor in the interpretation of vendor supplied informatio *
There were communication problems between Operations and Main-tenance personnel (Operations indicated that they did not know much about the nature of the tr'ubleshooting efforts being pursued on the morning of January 2c).
In addition to the above weaknes.,, the inspector also noted that schematic wiring diagram (Dwg 82-871-E) for inverters 2Y05 A, 8 and C (used by the electrician during troubleshooting) was not in agreement I with ths actual wiring in the inverter cubicl The insyctors also noted the licensee fusing and fuse replacement practices. The licensee investigation of the January 22 Unit 2 trip showed that out of the three fuses (A, B and C) on the inverters, only two of the fuses (B and C) were blown. It was later determined that the B and C fuses were of type fusetron, dual element time delay, Class K5 fuse type FRN-100, whereas the A fuse was of type NON-100, a one time fuse. It was not clear how and when the fuses were replaced. It appears that the licensee had no procedures or formal documents to administratively control the replacement of fuses by type (only by rating) at Calvert Cliffs for this type of applicatio _ _
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. Preventive Maintenance Program -j Procedure CCI-211E described the administrative requirements for the !
Preventive Maintenance (PM) program. This ' procedure was revised on !
January 26, 1988 during the course of this inspection. .The inspector i
- reviewed the procedure and interviewed licensee maintenance staff ;
involved with the PM program. The inspector had the following obser- i vations based on previous implementation of the PM program: !
(1) Trending Analysis, ,
Section V.E of the procedure specified that "Supervisors'should *
be alert for indications of conditions which may be detrimental to equipment performance. . . " . ~However, no' other detailed l descriptions were given on how the PM data were to be evaluated [
t- and what feedback mechanisms were utilized to inform the super- l visors of the evaluation results. From interviews with mainten- >
ance staff; involved with the PM program and the document control staff, the inspector determined that
- Section C of. the procedure addresses evaluation and trend- t ing of dat The senior engineer responsible for the trending program demonstrated to the inspector the computer software utilized to store and analyze data. The current i equipment monitoring program is based on the correlation of ;
vibration data and oil sample analysis results taken from ;
all ASME rotating equipment in the plant. A weekly summary j
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of equipment with suspect mechanical condition is submitted f to the General Supervisor of Operations, General Supervisor [
of Maintenance and the System Engineer. The System Engi- i neer has the responsibility for the followup and the reso- !
lution of all abnormal equipment condition l i
The inspector noted that while all vibration- data are [
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analyzed onsite, oil sample analyses are conducted by . a i a
local laboratory. The laboratory's responsibility for con-ducting the analyses in a timely manner was not formalize '
Prompt notification by the laboratory upon identifying a !
potentially serious abnormal condition was left to the '
initiative of the laboratory. It was noted that the licen- !
see needs to develop time requirements for conducting oil !
semple analyses and instructions for prompt notification
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upon the identification of abnormal finding !
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= Other PM data were collected, but there was no systematic method of storing such data and therefore only minimum PM-data were evaluated. The licensee was'in the process aof:
loading PM data in a PC computer, however, a systematic trending of- these' data.was not evident at the time of the inspectio .
- Completed MOs, however, are kept on reels and. tapes. Data can only be retrieved by MO numbers, and. not by equipment and system identification number This recordkeeping system did not provide the licensee maintenance staff with a readily. accessible path to obtain past maintenance his-tory for trending purpose (2) Scheduling and Performance Evaluation There wasL no dedicated staff assigned to oversee and integiate the PM program. Scheduling was manually tracked quarterly. .The inspector observed that certain PM tasks were missed and others were deferred, however, there ~ were no records to document that '
evaluations were performed for those missed and deferred PMs to include operability of the equipment involved (if appropriate).
(3) Preventive Maintenance for Manual Valves a The inspector reviewed procedures for maintenance of manual valves and found that the licensee had established PM procedures for general valves located in the following building Turbine building (PM 1, 2-102-M-A-2, R-1)
Auxiliar.v building (PM 1, 2-102-M-A2)
Containment building (PM 1, 2-102-M-R2)
The following generic steps were required for PM tasks on these valves:
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Grease all valves equipped with grease fittings l
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Check and adjust packing as necessary 1
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Visually inspect valves and note problems l
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Grease all sway strut ,
The inspector expressed the concerns that the procedures con-tained no detailed list (s) of valves to keep track of job
- progress. As a result
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Personnel performing PM activities might do PM on the wrong valves or miss the PM requirements on certain v-Ive The use of a general PM procedure may provide the potential for overgreasing of the valves or the use of incompatible materia Also, the general procedure would not control the exercis-ing of valves or the maintenance of required valve posi-tion Valves might be exercised or required valve posi-tions might be altere The licensee needs to review other PM procedures that might be too general in this respec (4) PM Program Redirection On January 26, 1988, the licensee issued a new PM procedure CCI-211F, which incorporated the following major changes:
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Overall responsibility of the PM program was assigned to the Manager of the Nuclear Engineering Services Departmen A defined process for evaluating, trending and reporting PM program results was stated and responsibility for this process was assigned to the Performance Engineering Uni A requirement for System Engineers to be notified of PM tasks that will not be completed as schedule The inspector reviewed the above revised procedure CCI-221F and had the following observations:
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The procedure states that: "The General Supervisor (GS)
of the responsible craft group reviews and determines the reason for the missed PM tasks", however, there was no requirement that the GS evaluate and document the opera-bility and reliability of equipment that had missed or deferred PM task PM tasks are currently processed as low priority work and therefore may not receive adequate management attentio Future achievement of good completion rates may be difficul There was no defined process to correlate the PM data and CM data for PM program optimization and re-adjustmen . .- . . ... .. ..- - - .. -- -- . - .- .
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(5). Summary The licensee's preventive . maintenance program was generally not -
systematic and lacked formalit Trending was being performed, but data were difficult to use as information was not readily- :
accessibl Although PM was scheduled and tracked, the ' impact j of missed and deferred PMs. on equipment operability was not being evaluated. Some PM procedures.needed additional detail or i clarification. The licensee appeared to be aware of the need to ;
strengthen this program and was in the process of program 1 redirection at the time of the inspection, Ov9rall Maintenance Summar The amount of detail contained in completed maintenance work packages showed good recording of the mainteaance performed and good QC over-sight. Coordination meetings provide the proper prioritization of-plant activitie However, troubleshooting and post maintenance !
testing gu' dance needed improvement in order to prevent adverse im- I pact on plant operations and assure that retesting sufficiently verifies operability of a component prior-to returning it to servic *
The PM program was comprehensive, however, its non-systematic, infor-mal approach in some areas potentially limits-its usefulnes . Engineering Support Activities !
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The inspectors performed a review of the engineering support provided by -I the Nuclear Engineering Services Division (NESD) to the Nuclear Operations ,
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Division (NOD) and to the Nuclear Maintenance Division (NMD) and of the interfaces that exist between NESD and N00 and between NESD and NMD to t extend this engineering support and to garner any appropriate feedback !'
regarding this suppor Engineering Support During the December 1985 reorganization, the licensee established the position of system engineer. The function of the system engineer was l to become the expert with regards to the system's design basis, .func- !
tion, operation, maintenance, modification, testing and regulatory .
complianc *
The expertise was to be developed through a formalized traindrig pro- !
gram that was under development at the time of the . inspection, and I through the system engineer's familiarization with the system. Part ;
of this familiarization process included obtaining a knowledge of .
applicable surveillances, maintenance and modifications planned and !
through documentation reviews. An overall familiarity with the system's layout and current operating status was to be obtained through system walkdown i
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Discussions with several operators and system engineers indicated that many o' the system engineers did not routinely walk down their assigned systems. The walkdown frequency appeared to vary froa weakly to quarterly, or longe It was difficult to ascertain how the system engineers maintain a current level of knowledge of the condition of their assigned systems without routinely walking down their entire systems. The inspectors found tnat apparently no guide-lines have been promulgated to the system engineers concerning system walkdor regt.irements or periodicity, b. Engineering-Operations Interface The inspectors examined the engineering support provided by NESD to N00 and the feedback provided by N00 through discussions with several operators and system engineers and through reviewing por. ions of the operations surveillance procedures and test results, including post maintenance tests, that were applicable to tha Units 1 and 2 salt water systems in 198 The surveillances reviewed included the followino:
STP-0-56A-2, Revision 9, "ESFAS Equipment Response Time" STP-0-65-1, Revision 30, "Quarterly Valve Operability Verifica-tion - Operating" STP-0-65-2, Revision 30, "Quarterly van Operabiltiy Verifica-tion - Operating" STP-0-66-1, Revision 18, "Quarterly Valve Operability Verifica-tion, Shutdown" STP-0-66-2, Revision 23, "Quarterly Valvo Operability Veri . ica-tion, Shutdown" STP-0-73-1, Revision 24, "ESF Enuipment Performance Test."
The inspectors found that the NESD/N00 interfaccr with regard to the I development, revision, performance and review of operations surveil-lances were generally minimal, though sometimes dependent upon the l system engineer involve l System engir vs c'o not directly revise or review operations surveil-lance proc is tha r#fect or test their system Rather, they i must re - the pr* - 's group of N00 to make any nece sary I changes sw. tem o. 'rs do not review these modified proce-du,as * uired changes were properly incorporate l
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An instance in which this methodology led to discrepancies in the
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programmatic and the procedural changes required was the development of the second 10 year inservice testing (IST) program for pumps and
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valves including their associated surveillance procedures necessary r to conduct the IST program. The second 10 year IST interval started on April 1,1987 and June 30, 1987 for Units 1 and 2, respectivel CFR 50.55a(g)(4) and -(5) required the licensee to update the-IST ,
program on Apri1 1,1987 to the 1983 Edition of the ASME Boiler and '
Pressure Vessel Code and to submit to the NRC any IST programmatic relief requests within twelve months of the end of the previous 10 year IST interval. The licensee submitted the second 1C~ year IST program with all requested reliefs on February 26, 198 The second 10 year IST program was developed under contract for N0D by the General Physics Corporatio Thougn N00 apparently has no significant ASME ~ Code expertise, this program was not reviewed by )
NESD though significant ASME Code expertise can be found in Design Engineering and in Performance Engineering. NESD interface with NOD ,
concerning the IST program was limited to N00's use of the licensing '
unit of NESD as a conduit to submit the IST program to the NRC for revie ,
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The inspectors found the following_ problems -while reviewing the IST l
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surveillance procedures provided to test the salt water system: !
i (1) Article IWP-3210 of the 1983 Edition of the ASME Code specifies '
that the allowable upper limits. (alert and action limits) for the ranges for pump flow rate and pump differential pressure, ;
as measured during the IST surveillances of ASME Code Class 1,2 i and 3 pumps shall be 102 percent and 103 percent, respectively, of their applicable flow rate and differential pressure refer- l ence values. Without requesting ASME Code relief, the licensee l had been utilizing less conservative alert and action limits of l 105 percent and 107 percent respectivel The licensee had stated in the February -26, 1987 IST program [
submittal that they were using these values- and that this use -
reflected "the approved relief request from the first ten year program [NRC Safety Evaluation dated February 8,1982) and meets '
with ASME Code ,2ouirements per IWP-3210." However, the relief approved for the first 10-year interval dealt only with pump .
differential pressere and did not consider flow rat Further- ;
more, reliefs granted for a previous 10 year interval do not l
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extend into the following 10-year interval, but must be again :
requested and - approved to still be applicable. Lastly, these increases in the ale, t and action ringe upper limits for flow '
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rato and differential pressure apparently did not comply with the requirements of Article IWP-3210 of the 1983 Edition of the ASME Code ~, thus, if these values were to be used after April 1,1988 without a Code relief previously requested from ,
the NRC, the licensee would be' in apparent noncomplicance with the provisions. of 10 CFR 50.55a(g)(5)(iv). The inspectors requested the licensee to submit the appropriate - Code relief l request before. April 1,-1988 if they intend the continued use of
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these alert and . action range upper limit .-
(2) The IST of the # 11,12 and 13 salt water pumps (Unit 1) is per- ,
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. formed through the use of the surveillance test ~ procedure STP-0-73-1, Revision 24, "ESF Equipment Performance Test." . Pump performance is evaluated by either setting the pump flow rate to ,
its. reference -value and determining differential pressure or by i establishing the differential pressure at its reference valuc .j and measuring flow rat In either case,:the lack of precision j in the installed pump discharge pressure gauge (2 psi incre- 1 ments, thus a 1 psi er"or) is significant enough (a change of l 1 psi corresponds to a ' low rate change of 700 to 1000 gpm) that i the error inherent in reading this pressure gauge spans a large
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portioi; of the entire action range. Thus, acceptable IST pump i performance readily could be judged as unacceptable ~or unaccept- i able performance could be found to be acceptabl This is .
unresolved item.50-317/88-01-03; 50-318/88-01-03). E
To reduce the precision error in this differential . pressure !
determination, it appears that some surveillance procedural [
modifications may be necessary, such as:
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(a) the use of a more precise pressure gauge for this test, or t
(b) replacer,ent. of the graph in STP-0-73 of bay level versus ;
pump sv. tion pressure with a table of bay levels, in tenth ;
of a foot increments, with their corresponding pump suction
, pressure. values. Bay level provides the value for the pump .
suction pressure used to calculate the pump differential 1 pressure. The values of suction pressure used in previous ;
!. performances of this surveillance have varied by as much a f 0.2 psi, approximately 400 gpm flow rate, for identical bay !
level l
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i If NESD had been involved with the development or review of the !
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IST program and of its applicable surveillances or the syste engineer had conducted a thorough walkdown of the system and'the j app icable surveillance procedures, difficulties created in this- l surveillance due to the lack of pressure gauge precision could l have been identified and averte .i
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Besides not reviewing the changes .to operations surveillance test procedures, many of the system engineers do not review all of the surveillance test results that are applicable to__ their system Without this information . trending of. component and-system performance by the system engineer is difficult to accom-plis However, the -Operations Sarve111ance Coordinator (OSC)-
has established a policy of -notifying the' system engineer by memorandum of out-of-specification conditions or equipment fail-ures that were discovered during the performance of operations '
surveillances., This notification is an improvement by .the OSC over prior feedback practices between N00 and NES In addition to the above examples, further itens concerning NESD/N00 interface and support reviewed by the inspectors included the lack of '
lists of electrical loads powered from non-vital instruments buses and the reduction in the . required value for_ salt water pump flow rat (1) In reviewing the January 22, 1988 Unit 2 trip that occurred ;
following the inadvertent deenergization .of the #22 instrument bus, the inspectors .found that NESD had not developed lists of loads powered from the non-vital instrument buses. These lists were previously requested by N00 personnel to facilitate the development of abnormal operating procedures. N00 was informed i that they could not be provided until late 1988 at ti.e earlies '
Thus, the plant operators are placed in the disadvantageous ,
position of not knowing what components or systems (i.e. , main feed) would be lost if one of these buses was deenergized due to a m sualty or to maintenanc ;
(2) To comply with the new IST requirements of Article IWP-3210 of the 1983 Edition of the ASME Code for pump flow rate and differ- ;
I ential pressure comparisons, NJD temporarily changed STP-0-73-1, ;
"ESF Equipment Performance Test" and performed these modified :
Unit I surveillance: on June 22 and July 3,1987. The licensee i determined that the flow rates for their reference differential i pressures were lower than anticipated. Section 9.5.2.3, "Salt ;
Water System," of the Updated Final Safety Analysis Report :
(UFSAR) states that the required flow is approximately 20,000 ,
gpm for a 'oss of coolant accident (LOCA). The fiow rates '
measured were considerably below this value with the lowest flow 3 rate measured at 16899 gpm for #13 salt water pump on July l
The UFSAR flow rate of approximately 20,000 gpm was based on l Bechtel's original design evaluatio r alculations for Calver ;
Cliff: for salt water system flow u the service water heac :
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exchangers during a LOCA prior to the initiation of recircula- 1 tion. In these calculations, Dechtel assumed a salt water flow of 20,000 gp j l
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In response to these lower salt water flow rates, the licensee requested Bechtel to recalculate the minimum salt water flow' i rate required through removing assumed conservatism The result was 17730 gpm. This value is- said to include' an_ instru- !
ment error of 900 gp t
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On August 19, 1987, .the general - results of these calculations ,
were presented to the POSRC (Meeting # 87-84). 'POSRC authorized the immediate use of these values by N00 in STP-0-73 and appar- i ently directed NESO to institute a Facility Change Request (FCR !
- 87-83) to revise. the salt water flow' rate specified in the -j UFSAR. The licersee has incorporated and used these latter flow !
rate values in subsequent performances of STP-0-73 though n work has occurred on FCR-# 87-83 and no additional evaluations, such as an unreviewed safety ' question determination or a com-
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parison to the flow cates measured during pre-operational test-- ;
ing, apparently have been performe l The mechanism of this change as used by the licensee appears to j indicate that USFAR system descriptions, Ach as flow require- l ments for design basis events, can be altered without the per- i
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formance of a formal unreviewed safety question determinatio .
This concern was identified to licensee engineering managemen !
Further, the reduction in the salt water flow requirements will be considered for further review and action by the Office of Nuclear Reactor Regulation through the normal performance of its licensing and facility design safety function (
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4 The inspectors examined the interfaces between NESD and NMD through discussions with several maintenance technicians and system engineer '!
The inspectors found that the system engineers have a general famili-- .
arity with planned maintenance (PM) procedures for their associated .;
system In addition, changes to PMs, though written by NMD, are .now l reviewed by the system engineers to determine if these changes must :
be submitted to POSRC for approval . This is a -recent policy change I that was implemented through a January 11, 1988 Plant and Project- i Engineering memorandum to all system engineers written to reflect a l
recent NESD/NMD agreemen l
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I With regards to non-routine maintenance and repairs, the inspectors !
determined that generally the system engineers were not knowledge- i able of these items with the ' exception of high priority issues about :
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which they were specifically notified by NMD. The system engineers .j
, are not routinely routed nor routinely review maintenance orders :
j (MOs). Many of the system engineers do not routinely. review the com- 1
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puterized MO lists for their assigned systems. The frequency of ;
review of ten varied from q.arterly to semi-annuall This listing l
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is readily available from a computer with terminals located inside the protected area and inside the engineering facilit When reoisested for a _ listing of all MDs worked.on the Unit 1 salt water system in 1987, several NESD personnel were unable :to produce this listing until the last day of the inspection due to an unfamiliarity with the computer program. This precluded the inspectors from-exam-ining .the NESD/NMD interfaces demonstrated in 1987 in response to equipmeat malfunctions in the Unit 1 salt water syste Nuclear Engineering Services provides overall techs wal support to site operations and maintenance. The engineering department consists of Design Engineering, Plant and Project Engineering and Technical Services Engineering. Each group is headed up by a General Super-visor. While the engineering department went- through a major reor-ganization approximately two years ago, changes in the organizational work load continue to be implemented in order to achieve optimum work load distribution, especially in the plant projects engineering and major projects engineerin Based on discussions with principal engineers, the licensee iden-tified two areas of concern: Excessive work load assigned ;o system engineers. This problem is being addressed by the reassignment of responsibility for
, major facility change requests from .the system engineer to the project engineer ' Backlog in updating critical drawings (P&ID's are considered critical and are updated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the issuance of a drawing change request (DCR)). All other drawings are being updated by twenty two contractor _ draftsmen . as a part of a-
, special program to be concluded by March 31; 1988. There are no long term plans to centinue with the update program to address
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future DCR's. The licensee will rely on existing ~ staff to change and update drawings as work is accomplished.
, processing of Facility Change Requests The inspector noted that the successful development of completed plant n;odification packages, identified as Facility Change Requests (FCR's) by the licensee is based on a close working relationship amongst all engineering servicts and interfacing with operations and .
maintenance departments. The governing procedure in this area, CCI-126 H, Administrative Control of Facility Change Requests, -
reviewed by the inspector in draft format, has been issued for final ,
comment. -The procedure details respons;bilities for the design, ;
installation, testing, and turnover of FCR's based on a team building
.- concept, requiring close working relationships between engineering, maintenance and operations department ;
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The inspector reviewed selected sections of the following work packages:
- FCR 80-1010, Reactor Vessel' Level-Indication
- FCR 85-1048, Main Steam Isolation Valve Changeout These modifications were accomplished in accordance with a previous revision of proceedure CCI-126, in which -responsibilities for manag-i ing the project were not clearly defined. While no problems concern-ing the above FCR's were noted by the inspector, the final status for installation and close out of FCR 80-1010 was not clear fri m the modification packag e. Control of Technical Manuals -
- Technical Manuals were controlled by the Technical Librarian in accordance with licensee procedure CCI 1220. . The inspector verified '
through interviews of systems engineers that the' requirements of the '
subject procedure were generally met and technical manuals were properly reviewed for accuracy upon receipt from the vendor f. Independent Design Reviews
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The inspector verified that the Design Engineering Section Procedures DESP-6, Calculations and DESP-7, Design and Design Review, met the intent of ANSI N45.11 and established the requirements for the per-
formance of design reviews by the use of alternate ' calculative methods. The checking process was being implemented by three qualif-ied engineers. The inspector reviewed the calculation review records for the following design verifications or design changes;
M87-21, High Pressure Safety Injection Pumps Flow, to determine if sufficient NPSH was available at the suction of the HPSI pumps,
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M87-17, Component Cooling Water Pumps, to calculate shaft stresses based on loading conditions, and
FCR-87-45, Low Pressure Safety Injection Pump, to verify vent line rigidity requirement The inspector concluded that the ir. dependent design review program
- was effectively implemented by the license !
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. Summary The System. Engineer's position as the key person for system knowledge did not yet appear to be functioning as intended as evidenced by their limited review of surveillance test results and ongoing main-tenance work as well as non-standard walkdown practices. 'There was insufficient Engineering involvement in surveillance testing and IST program changes for pumps and valves, particularly. for the salt water syste Although the independent design review process appeared effective, one change involving decreased salt water system flow rate may have insufficient evaluation of whether it involved an unreviewed safety question and comparison with o-iginal pre-operational- testing dat . Surveillance Testing The surveillance test program was reviewed to verify that the licensee had developed, maintained, and implemented written procedures and administra-tive policies necessary to ensure the operability of safety related sys-tem Approved Surveillance Test Procedures (STPs) were reviewed for technical adequacy and to verify that test acceptance criteria included specific Technical Specifications (TS) and Inservice Inspection and Test-ing requirement Several surveillance tests were witnessed to verify proper conduct, documentation, and resolution of identified problem Discussions were held with operators, technicians, engineers, planning personnel, and first-line supervisors to determine their understanding of and involvement in the test program, Surveillance Test Program Implementation Implementation of the Surveillance Test Program is described by Calvert Cliffs Instruction (CCI) 104H, Surveillance Test Prog ra Additional guidance associated with implementation of this program is contained in CCI 101J, Review And Approval Procedures For Proposed Calvert Cliffs Procedures, and GS0 Standing Instruction 86-1, Sur-veillance Testin CCI 104H outlines tha administration of the program and station per-sonnel responsible for ensuring that the program is implemented .
effectively and correctly. This instruction also describes the pre- l paration, review and approval, scheduling, performance, and results review of Surveillance Test Procedures (STPs). Details for process- .
ing changes and revisions to STPs are described in CCI 101 The inspector discussed the implementation of this program with the Surveillance Test Coordinators and Scheduling Coordinctors for Opera- i tions/ Inservice Inspection, Maintenance, Electrical and Controls, l Fire Protection, and Engineerin The STP schedules for several-mcnths were reviewed to verify TS required frequencies were me l
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Through interviews of station personnel and review' of the STP program i and several STPs, the inspectors identified two concerns. These are:
a lack of specific guidance on a formal method to _ ensure that tem-porary _ changes to procedures are incorporated into_ future test per-formances and revisions and, the distinctions between intent and ,
non-intent changes to procedure !
When temporary changes need to be made 'to an STP they are written into the body of the procedur CCI.104H provides a PM/STP Feedback Sheet which is attached to all Maintenance and Electrical and Con- i trols (E&C) STPs. The information required on this sheet includes ;
any temporary changes which were made and suggestions to improve the .i procedure. These feedback sheets are forwarded to the Maintenance !
and E&C Scheduling Coordinators who must ensure that the changes, if q permanent, are made to the test copy of any ' subsequent- performances- !
before a revision is issue They also must ensure that these j changes are incorporated into the next procedure revisio This has ;
been accomplished by putting a copy of the feedback sheet 'into th l master test file. Operations /ISI and Fire Protection STPs, however, !
have no feedback sheets or other formal. method of assuring that i changes are carried into future performances and revision !
An example of this was identified during reviews of several sequen- '
l tial performances of STP 0-73-1, ESF Equipment Performance. During the period between September 21, 1987 and December 23, 1987, sub-stantial changes were made to the portions of the procedure which -
tested the Salt Water pump These changes were inconsistently and !
in some cases incompletely carried in the body of the procedure :
through this period. The memory of the Surveillance Test Coordinator >
has been relied upor. to verify that any changes are included. During !
discussions of this matter with operations personnel, the inspector I was informed that other operations procedure changes are tracked by the use of CCOM Change Reports. CCI 300H, Calvert Cliffs Operating ;
Manual (CCOM), describes the use of Plant Operating Procedures, Oper- !
ating Instructions, Emergency Operating Procedures, and Abnormal Operating Procedures. When changes are necessary to these oroced- l
, ures, a CCOM Change Report Form is complete These changes are i numerically identified ar.d are therefore traceabl The form also j provides a space for specifying . if the change is permanent or one - -l time onl The inspector found the use of this form to be an effec- I tive control of changes to operations procedure I
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The inspector also noted that CCI 104H provides a brief description l of changes to procedures, specifically, those that alter the proced- !
ure intent and those that do not. No guidance is given for deter- '
mining if a change changes the intent of the procedure. During dis- !
cussions with several shift supervisors, the inspector questioned the ;
instructions given to determine procedure intent. Personnel expressed !
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varying opinions of what constitutes an intent _ change and how : to determine procedure intent. This situation is' complicated by the fact that, in general, STPs do not contain an objective or purpose paragraph in the beginning of the procedur Shift Supervisors-generally rely on a detailed review of the procedure and the appli-cable TS requirement to determine procedure . inten , Surveillance Test Observations
- During the inspection period, the inspectors observed performance af several STPs. The inspectors verified procedure adherence, complete and accurate documentation, and adequate resolution of problems encountered during test performance. Personnel were found - to have 1 adequately reviewed the tests, to be knowledgeable of' systems tested and procedural requirements. No concerns were identifie Surveillance tests witnessed included:
- STP-0-05, Auxiliary Feedwater System Test -
STP-0-6-2, Reactor Protective System - Startup Test
STP-0-8-0, No. 11 Diesel Generator Testing
STP-0-29-2, Control Element Assembly Partial Movement ,
STP-0-33-1, Radiation Monitoring System Functional Test
- STP-0-47-1, Main Steam Isolation Valve Partial Stroke Test ,
STP-0-71-1, Staggered Test of 'B' Train Components Review of Completed Surveillance Test Procedures a
Several completed STPs were reviewed from each disciplin The inspector verified that the tests were conducted in conformance with TS, ISI, and procedural requirements; had received the proper reviews; were performed at the required frequencies; and that Lappro- i priate action was taken for deficiencies identified. The following l concerns were identifie i
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STP-0-7-1, Engineering Safety Features Logic Test, ' performed on October 8,1987, contained steps which could not be performed due to plant configuration. At this time, the #13 Salt Water Pump and two Hydrogen Purge motor-operated valves were out of service. Steps 1 I
involving this equipment were inconsistently marked to indicate that 1
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, they were not performed, Some were left blank, some marked N/A (Not Applicable), others marked T/0 (Tagged Out). In several other' pro-cedures it was noted that temporary procedure changes were processe Similar inconsistencies were found in STP-0-65-2, Quarterly Valve Operability Verification, performed on June 30, 1987 and STP-0-73-1, ESF Equipment Performance Test, performed on December 23, 198 CCI 104H and 101J do not contain instr..ct. ions on actions to be taken when I plant configuration precludes test step performanc When ques- i tiened, station personnel cited the above ment'oned alternatives when I it is impossiole to perform a ste I
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STP-0-5-1, Auxiliary Feedwater-System, performed on October 30, 1987, is the monthly verification of Auxiliary Feedwater System '(AFW)
operabilit During performance of this. test, it was identified that the 11 and' 12 AFW pumps were not putting out the required flo It was' determined that a check valve-(1-AFW-202) on the 13 AFW recir-culation line was' leaking by' and causing the flow readings for the 11 and 12 pumps to be low. The licensee. elected to isolate this leak for the test by closing a normally locked open valve (1-AFW-186)
upstream of this leaking check valve. This. alignment had the poten-tial for' degrading No. 13 AFW pump operability in -that, in certain accident and transient situations, this. pump operates in the recir-culation mode in standby. .With valve 1-AFW-186 closed, there might not be sufficient capacity in -the pump minimum flow line to prevent overheating during extended operation in 'this mode. This evolution was performed and the. required data obtained without processing a temporary change. Technical Specifications 6.8. and CCI 101J, Review and Approval Procedures- for Proposed Calvert Cliffs Proced-ures, Section V.B.2 requires that when a temporary procedure change is necessary that, before the evolution is performed, the changes be written into the procedure and reviewed by two members of station management, one of whom niust hold a Senior Reactor Operator's License on the affected uni This review is to be documented next to the applicable steps with the reviewing personnel's initials and dat In this example, procedure steps for closing the locked valve were not added to the procedure and did not receive the required review This i; a Violation (50-317/88-01-04 and 50-318/88-01-04).
The inspector reviewed the turbine building operatorr' logs for' the day of this test to determine if the 1-AFW-186 was returned to its'
normal positio No entries relating to this valve were found. Also, a locked valve deviation sheet was not filled out prior to changing the valve position. However, STP-0-93-1, Locked Valve Verification, was performed on November 5,1987. This valve was verified to be locked open on this dat Additional examples of inadequate temporary changes to procedures were identified in the June 30, 1987 and September 23, 1987 perform-ances of STP-0-65-2, Quarterly Valve Operability Verification. Many changes wera made to the procedures, including addition and deletion of steps, wh;ch did not receive the second review until af ter the test had t'een completed. These are additional examples of the above violatio TS 6.8.3.a and CCI 101J also require that these temporary changes made to procedures be reviewed by the Plant Operations STfety Review Committee (p0SRC) within fourteen days. The inspector noted that these reviews have indeed been completed as required. However, it is station practice to have the STP with changes orally presented to
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POSRC instead of distributing copies of the completed procedures with changes.. Because of this practice, l:
it is possible for procedures with inadequate or inappropriate changes to be reviewed and approved by POSRC without being aware of such changes,
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Finally, the inspectors were concerned over the amount of iterations necessary until the correct baseline ficw values ' for the AFW pumps were determined.' The original baseline data for the AFW pumps was ,
taken in June 1987 using the monthly STP-0-5-1 and 0-5-2 with added steps to measure flow on the common recirculation line back to th Condensate Storage Tank (CST). System configuration for the turbine driven AFW pumps during this test had one pump running and the other pump idling. Through a series of iteraticas with tripping the idling ,
turbine driven pump and closing 1-AFW-186, it was discovered in 0ctober 1987 -that the initial baseline flow data were incorrec ,
This scenario indicates poor initial system configuration control and test data evaluation, Suemary The Surveillance Test Program was generally found to be adequat !
STPs were technically sound and were scheduled and performed ade-quatel However, there is a need for more attention to details in .
the documentation, changes, and review of the completed surveil- :
. lance Also, more detaileu guidance needs to be provided for- ,
personnel to more adequately and uniformly fulfill the requirements ;
and intent of the test progra '
.: Licensee Overview Activities Plant Operations and Safety Review Committee (POSRC)
i (1) The inspector reviewed administrative procedures.and guidance to :
verify that the POSRC was in conformance with regulatory requirement with respect to composition, duties and responsi- ,
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l bilies. A sample of POSRC meeting minutes was reviewed to ver- ;
ify meetings were conducted per administrative and regulatory l requirements. The number of meetings held Ly POSRC in 1986 and 1 1987 was verified to satisfy regulatory requirements. POSRC met ,
112 times in 1986 and 119 times in 198 j Inspectors attended three POSRC meetings, 88-03, 88-04, an I 88-05. Two of these meetings were scheduled to conduct norrni
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POSRC business and the third was to perform a Post Trip Revie The inspector interviewed the POSRC chairman and several POSRC member Documents reviewed during this inspection are listed in Attachment l
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(2) Findings s
Based upon the above _ review the following observations were made:
- The Manager - Nuclear _ Operations is the chairman of the i POSRC per lechnical Specifications.(T.S.). The .POSRC function is to advise the Manager-Nuclear Operatior:s on all .
matters related to nuclear safety. These-two T.S. require-ments may conflict if the POSRC Chairman directs the meet-ing to the extent that POSRC recommendations to the Manager
- Nuclear Operations simp;y ' reflect. his/her own point of view. To alleviate ' this -concern, Calvert Cliffs Nuclear Power Plant (CCNPP) POSRC. rotates among the members the role of facilitator, who conducts the meetings. The Chair-man acts only as an observer to the meeting, offering casual comments. POSRC started using a facilitator to con-
- duct its meetings at the beginning of 1988. This is viewed as a potential strength by helping to assure that an inde-pendent assessment on matters related to nuclear safety is provided to the Manager-Nuclear Operation
The POSRC was observed to provide detailed interdiscipli-nary reviews of various safety concerns brought to its attention. Included in this observation were POSkC reviews '
of the proposed Licensee Event Report (LER) for the loss of load trip for Unit 2 on December 21, 1987; the temporary modification of the Auxiliary Feedwater (Ahl) Logic r Cabinet; and the Post Trip Review following the
January 22,1988 Unit 2 tri The POSRC review of these t subjects appeared comprehensive and thoroug *
The POSRC has implemented a good program for assigning responsibility and following up on action itens it idcnti-fie Due dates were observed, actions were complete and thorough and POSRC involvement was eviden *
The POSRC meetings observed by the inspector were well
- attended with representatives from all major ' disciplines.
, In addition to the required membership, it was noted that i the General Supervisor - Quality Assurance took an active i part in the meetings. The licensee was planning to for- ,
mally increase the size of the POSRC by two members, one of ;
, which will by the General Supervisor - Quality Assuranc !
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It appeared that some items were not as well researched and coordinated as they could have bee Two examples where better preparation and coordination by the resonsible individual were needed, were with the proposed LER for Loss of Load for Unit 2 and the AFW temporary modification procedure. Because the POSRC does a thorough review of subjects brought to its attention, these subjects were reviewed in suf ficient detail during the meetings observed by the inspecto b. Off Site Safety Review Committee (OSSRC)
(1) Program Review and Implementation The inspector reviewed the administrative program which defined the composition, functions and duties of the OSSRC for conform-ance with regulatory requi retr ent s . The previous two years of OSSRC meeting minutes were reviewed to verify and evaluate:
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The adequacy of OSSRC reviews of all audits, LER's, regu-latory viol,tions, Technical Specifications (T.S.) changes, proposed modifications, tests or experiments, design deficiencies and POSRC minutes and report The committee's composition with respect to the disciplines and expertisa required by T.S., as well as meeting the quorum requirements of the A sample of audits conducted under the auspices of the OSSRC wa:
reviewed in order to evaluate the quality and depth of the audits and their conformance with T.S. requirement OSSRC members, including the past and present OSSRC Chairmen and the Vice President - Nuclear Energy, were interviewed to determine the effectiveness of the OSSRC in neeting its responsibilitie The documents reviewed are listed in Attachment 4 (2) Findings The OSSRC has recently made some changes to the way they are organized and conduct business. Most of these changes and pro-posed changes appear to be positive, however, at the time of this inspection it was to premature to assess their effective-nes Those changes or proposed changes which appear positive -
are:
- The present OSSRC chairman is an offsite member. Until his appointment, it was planned to rotate the chairmanship among the onsite members, i
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- All QA audits are performed under OSSRC approval. An OSSRC !
member is assigned responsibility for monitoring each audit ?
performed. Prior to~the audit, the audit. team contacts the -
responsible OSSRC member to discuss the audit and obtain
~any additional guidance the member may. have to offer. At i
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the conclusion of the audit,-th'e OSSRC member is briefed on the audit findings. In addition, the OSSRC member prepares an audit summary evaluation of the completed audit repor It was noted that some OSSRC members do a more thorough review than other member The mixed performance of OSSRC ;
members in this oversight function potentially can affect ,
the overall quality of the auditing activit ;
- The audits reviewed showed a marked improvement over the j past two years in.the quality of the audit and the expli-citness of the findings. The audit findings noted by the ;
inspector focused on safety significanc This was a 1 result of OSSRC challenging the QA group to be more direct ,
in their audit i
- OSSRC recommended that an independent Safety System Func- :
tional Inspection (SSFI) of the Auxiliary Feedwater System ;
be performed. This was completed in 1987 and based on the :
results, the OSSRC recommended a second SSFI be performed i in 198 (See Section 6.c below for further details).
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The OSSRC met six times in 1986 and eight times in 198 [
Four meetings are scheduled each year, the rest of the !
meetings were on a "as required" basi The ' new OSSRC Chairman plans on having six scheduled meetings per year {
to allow a more thorough review of the items and provide !
more training to the offsite member All scheduled '
meetings were well attende j
The new OSSRC Chairman has proposed adding two new offsite !
members to the committee - one of the new members would be l a member of another nuclear power plant, j
c. Safety Sy3 tem Functional Inspection (SSFI) l I
! In ti,e f all of 1987, the licensee conducted an independent SSFI of j
, the Auxiliary Feedwater Syste This was a joint inspection, con- i
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sisting of eight licensee and three contractor personnel, which took l
- ten weeks to complete. The inspection resulted in 44 observations l which were reduced to 17 Findings and 11 Recommendation. Results of !
the inspection were presented at the POSRC, the 055RC and the Vice ;
1 President - Nuclear Energy. POSRC identified six open items requir- :
ing immediate attentio ;
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The SSFI activity was considered to be a strength for the following reasons:
- It demonstrated good licensee initiativ * It was a systematic arid well planned effor The applied inspection resources were extensive and resulted in a detailed review of the AFW syste * 1.icensee personnel worked in a joint team with an experienced contractor as a learning exercise to develop in-house- capabil-ities for future SSFI effort * Findings -with potential immediate safety significance were promptly considered -by POSRC to determine their - impact on
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operabilit * l.icensee management and design engineers were thoroughly briefed on finding Although the SSFI had been handled well at the. time of the inspec-tion, it was too early to assess long term followup and closecut of findings. Because of the insights into system design / modification /
testing interface problems and inconsistencies identified by the SSFI, the licensee was planning on performing a second SSFI in 198 d. Quality Audit Unit (QAU)
The QAU has responsibility for generating the audit schedule, coor-dinating each audit with the OSSRC, performing the audit, and pre- t senting audit findings to the appropriate Department Manager and the !
OSSR During the past year the QAU had initiated an evaluation pro- t gra These were voluntary independent audits performed at the {
request of the Department's Manager - for his Department. Findings ;
were written as recommendations and sent to the Manager. The Manager !
had the option of accepting or rejecting the recommendations. The j Vice President - Nuclear Energy received copies of all recommenda- t tions, j
The inspector reviewed several audits, audit findings, evaluation and i recommendations (listed in Attachment 5) and found them to .be :
thorough and well writte The findings and recommendations were i clearly stated and meaningful. One problem noted was the lach of an i automated tracking system to monitor commitments made on open item j The QAU has begun trending audit results. These trends are periodi- l cally presented to the OSSR ;
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. Communications Meeting Approximately four to five times a year the licensee holds meetings with all of the upper level plant staff including engineer At these meetings topics of current interest to the employees are pre-sented by upper licensee managemen The inspector monitored the meeting held on January 29, 1988. Presentations were made by the President, Vice President - Nuclear Energy, the Managers of Opera-tions and Nuclear Engineering and a specialis The subjects were current, candid and open to discussio Summary The POSRC activities observed were considered to be effective based on the level of detail of the reviews conducted, membership attend-ance at meetings and the tracking system for action item Recent initiatives to strengthen the OSSRC and imprcve its independence were considered to be pnsitiv The voluntary independent audit function and the Safety System Functional Inspection both appeared to be good licensee initiative . Organization and Interfaces The inspector examined two aspects related to the management of CCNP The inspector considered the structural components of the organization and the interfaces those components have with each othe The inspector utilized a model or framework for viewing the organizatio This model considered six structural components as follows: Communication system Decision Making system Accountability system Reward / Recognition system Reporting Relationship system Cultural / Behavioral Norms system Attachment 2 goes into some depth in discussing management structure and interfaces, presenting several exemples found during the inspection. Below is a brief summary of some of the highlights found in that Attachment, Ccemunication System The managers, supervisors, and key employees utilize both formal and informal communication system Such dual communication systems are entirely appropriate and are found in all organizations Of impor-tance to NRC is that the formal communication systems work well, especially as they relate to safety of plant operation, and chat the informal systems do not interfere with effective operations and do not hinder the accountability tracking system so important to deter-mining root cause of safety related problems. There is some evidence that due to the managerial structural design of the organization
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(interface between Departments) communications is not always as efficient or effective as employees or management desire. In addi- ;
tion, due to the physical design of the plant (inside vs. outside the fence) certain organizational components (System and Design Engi-neers) have experienced difficulty meeting with other plant personnel and hence effectively communicating. Licensee management recognizes some of these problems and was implementing programs to improve communications. They included several efforts such as-the following:
.(1) The 1987 Opinion Survey was an illustration of management desire to learn about employee concerns in an- effort to improve rela-
tionship (2) Team building and conflict / hostility resolution training for managers / supervisors was an example of positive interest .and
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effort to deal with issues brought out in the Opinion Survey, i.e. , more collaborative decision makin (3) Establishment of various regular formal meeting opportunities among key staff from the different Departments and work units, i.e. , maintenance management meeting at 6:30 AM, the daily 8 AM staf f meeting, etc.
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(4) A plan to move certain System Engineering functions "inside the fence" so they will be closer to -the customers they service, Decison Making System The inspector found that licensee management was attempting to bring ,
about a culture of collaborative decision making to the lowest levels '
of the organization. Such a culture appeared appropriate for opera-tion within a matrix organization and within an industry concerned with operat.ing a technology with a large variety of interrelated systems, as that found at CCNP Examples of such collaborative :
decision making were found in the following-l (1) Formalization of the Project Management / Matrix Management system )
in the Department of Engineerin i l
, (2) The restructuring of the "hark Planning Committee" from top management to mid-level managemen .
(3) The POSRC group whis makes its recommendations for a decision to the Manager, Nuclear 0perations rather than having the
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c. Accountability System The Nuclear Division utilized specific performance objectives for each manager / supervisor based upon the goals outlined in the Nuclear Program Plan (NPP). These performance objectives, in conjunction with the Perf ormance Appraisal system, hold individuals accountable for implementing the goals of the Nuclear Divisio Review of :
Managers' Performance Objectives indicated a positive relationship between objectives and the NP Interviews with managers and super-visors indicated that they were indeed held accountable for accom-plishing their object:ye d. Reward /Recoonition Systems ;
Licensee management seems to utilize both formal as well as informal positive rewards as methods of recognizing performance. Some of the formal approaches utilized are employee of the month, various safety awards, positive feedback notices on bulletin boards, training plaques, cash bonuses, et The inspectors noted that informal recognition was used freely by both the Managers and General Supervisors. At various meetings, inspectors noted a good use of positive public recognition between ,
participants for work efforts. An example was that of a supervisor publicly thanking another for some special effort. Such recognition was noted at several meetings. Non public recoonition was also noted j when the Manager, Nuclear Operations privately and personally recognized one of the key members of the POSRC meeting af ter a dis-cussion and analysis of a plant tri e. Reporting Relationship System 4 Although the licensee organization does have a formal organization chart indicating formal lines of reporting, the inspector noted that the Division works in a matrix environment. Such an environment can leave unclear lines of reporting and responsibility. The inspector i found this to be true in particular areas such as in the Engineering and Maintenance Department The inspector noted that the current '
draf t of the matrix management structure and responsibility descrip- l'
tion of those participating (engineers, etc.) seemed to create con-fusing reporting relationship '
Project management program charts were found to be excellent communi- t cation tecl The printed reports clearly communicated responsibil-ities, time constraints, and demands on resource The charted schedules reassured those involved in the project of their roles and when they were expected to execute the .
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I The inspector noted some confusion in understanding work roles'among ;
various groups of employees, namely among groups in the Engineering j Department, Procurement Unit, and Maintenance Department. This con- f fusion resulted:in difficulty in establishing meaningful priorities i and- getting certain work l accomplished. Additional clarification o !
work role perception by the individuals serving in a position and by those he/she interfaces with is needed. The inspector also reviewed i the draf t "Working Relationship Policy." It' was considered to be a j positive effor However, it did not clearly- indicate specific t
, delegation of authority of the VP, although in interviews with ;
Managers and General Supervisors there was general recognition that !
the Manager, Operations was in charge when~the VP was absen !
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Some clarification of the above issues appears to be neede !
- Cultural / Behavioral Norm System
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The inspector noted the effort of-licensee management-to enhance the work culture of CCNPP. It appeared that a positive work -ethic pre-vails and that employees have a strong desire tc- improve the Nuclear i Di.vi si on. Collaborative management, as a desired behavior style, was
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beginning to be accepted and was considered desirable by supervisors and staff. The emphasis on effective equipment operation rather than .
generation goals appeared to be accepted as desirable by employee l
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, Collectively, several positive management activities were considered !
j to be licensee strengt These included the following actions !
- recently completed or in progres j
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Use of an opinion survey to assist in identifying potential !
problems and perception (
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Team building / conflict resolution training and exercise i
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The number and diverse types of meetings that were being i utilized to enhance communication l t
Measures taken to implement collaborative decision making there- i
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An effective accountability system in combination with a good {
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formal and informal reward / recognition syste j
Recent management emphasis on improving plant material condi-tions with some corresponding deemphasis on generatio l
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8. Exit Meeting Meetings were held with senior facility management personnel periodically during the course of the inspection to discuss the inspection scope and findings. Key supervisory and management personnel contacted during this inspection and present at the exit meeting are listed in Attachment A summary of inspection findings was further discussed with the licensee at the conclusion of the inspection on January 29, 198 .
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ATTACHMENT 1 Persons Contacted The following is a list of key supervisory or management personnel contacted during this inspection and present at the exit meetin There were other technical and administrative personnel who wers also contacte Baltimore Gas and Electric Representatives E. A. Crooke, President and Chief Operat'ng Officer J. A. Tiernan, Vice President, Nuclear Energy J. R. Lemons, Manager, Nuclear Operations W. J. Lippold, Manager, Nuclear Engineering Services R. M. Douglass, Manager, Quality Assurance and Staff Services L. B. Russell, Manager, Nuclear Maintenance R. P. Heibel, General Supervisor, Nuclear Operations N. I. Millis, General Supervisor, Radiation Safety, Nuclear Operations L. A. Sundquist, General Supervisor, Quality Control and Support, Nuclear Operations P. E. Katz, General Supervisor, Design Engineering, Nuclear Engineering Services M. E. Bowman, General Supervisor, Technical Services Engineering J. T. Carroll, General Supervisor, Quality Assurance S. E. Jones, Jr., General Supervisor, Planning and Support, Quality Assurance W. J. Whitaker, General Supervisor, Mechanical Maintenance M. F. Roberson, General Supervisor, Quality Control and Support Services, Nuclear Maintenance R. L. Wenderlich, General Supervisor, Electrical and Controls, Nuclear Maintenance R. P. Sheranko, Project Manager R. J. Smialek, Assistant General Supervisor, Radiation Control and Support, Nuclear Operations J. R. Hill, Operations Training Supervisor, Quality Assurance and Staff Services J. R. Lohr, Assistant General Supervisor, Nuclear Operations C. R. Mahon, Principal Engineer, Primary Systems Engineering, Nuclear Engineering l R. R. Allen, Principal Engineer, Performance Engineering, Nuclear Engineering '
A. B. Anuje, Supervisor, Quality Audits, Quality Assurance and Staff Services W. R. Cartwright, Engineer, Nuclear Operations R. M. Somers, Assistant to the Vice Presidenc S. R. Cowne, Senior Licensing Engineer l K. M. Romney, Senior Engineer, Audit Unit, 0ASD l l
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ATTACHMENT 2 ,
Additional Details Regarding Review of Organization and Interfaces The inspector examined two aspects of the Calvert Cliffs Nuclear Power Plant (CCNPP), the organizational structural components and the interfaces of these ,
structural components. An assessment of effectiveness of management was con- i sidered but a thorough evaluation of this aspect of the operation of the ,
Division was not mad l In January 1986, BG&E underwent a major reorganization. The CCNPP was reorgan- '
ized into the Nuclear Diviston (NED) led by a Vice Presiden Under the VP, four Managers of major departments Operations (0P), Nuclear Engineering Ser- .
vices, (NES), Quality Assurance and Staff Services (QA & SS), and Nuclear Maintenance (NM)) were established. Reporting to each of these Department Managers were General Supervisors responsible for particular area This change placed stress on the new organizatio Examples cf stress areas were: : Relocation of an engineering group from Baltimore to the Calvert Cliffs area.
. The establishment of new work roles and work relationships among the newly constituted work groups, The establishment of new or modified policies / procedures for various work groups at well as the Division, i Equipment outages and other plant problems which occurred during the early period of reorganizatio During the first eighteen months of NED's operation, management (VP and Depart-ment Manager level) concentrated on formalizing the new organizational struc-ture and resolving the technical problems associated with the plan ' CCNPP Opinion Survey i
In an effort to sense the "pulse" of employee perceptions of Division operations, an "All Employees Dpinion Survey" was conducted in August 1987, by the Psychological Services Department located at the corporate leve ,
This comprehensive survey designed specifically for CCNPP elicited candid i opinions from all employees about their personal perceptions of management, plant operations, et The survey was analyzed and results sent to
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management in the beginning of October 1987. The results were issued in *
!. the form .of statistical data as 'well as antitotal data for individual l units and the Division as a whole. The results of this survey were viewed =
in the context of the "environmental". conditions- at the time the survey was administered. At that time, the plant was experiencing a major outage '
i and a major maintenance work and overhau In addition, the Nuclear
- Division had recently received regative reports from NRC regarding EQ violations.
l The major views expressed in this opinion survey were as follows:
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- Employees would like to see an increase in coordination between l various function They generally felt that work group members did l not plan or schedule work well together. The Engineering Group
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specifically. indicated dissatisfaction with integrated' priority .
setting systems between groups. .-(The other departments did not feit] !
as strongly about this issue as Engineering.)
- Employees indicated a strong desire for increasing their technical .
skill and knowledge, and a strong desire for advancement possibilit Employees generally perceived that their job did not provide chances for advancement, that they did not have influence over their jobs, and that work life was controlled behind closed doors. Employees ;
indicated a strong motivation for improvement of their skill and knowledge but perceived that the company did not place enough emphasis on training and development and that the company did not help keep technical skills curren hese perceptions were not
! univursally shared as the Engineering Group felt the strongest about a lack of training and development.
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Employees expressed their feelings about the recent reorganization of I the NE They felt management should explain it better -- the pur-
! pose and how it will wor Employees saw the organization under l increased stress compared to the previous organization. Employees i l were concerned and wanted to improve operations, they saw, a need for l increased concern for. operational substance and less concern for out-l side "image" making. The survey generally indicated that the NED l employees were a group of positively committed highly motivated and i
interested employees who wanted to sform their tasks well, had a .
strong desire for professional advancement, and an interest in
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Management has utilized the results of this survey to improve human !
resource as well as plant operational conditions in the Nuclear j Division. The company is making a concerted effort to involve people i in a more collaborative approach to management and decision making in l all areas of the plan,t, b,eginning with the Department Managers. An i
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example of this was the reformatting of the "Work Management' Commit-tee" from that of VP and the four Department Managers to one made up of the General Supervisor level of management [ Operations, Design Engineering, Plant and Projects Engineering, Planning and Support, Mechanical Maintenance, and Electrical and Controls.] This newly constituted (January 1988) committee will be given-the responsibility and authority to make decisions related to priorities of work-in the plant. The inspector understood that the committee will also be held-accountable for the decisions it make The following lir 3 several other major activities management has insti-tuted to improve the human resource and plant operations: The' VP revised and issued Power Availability Goals for CY 88. These noals did not specify the amount of power to be generated. The VP and other managers explained that the reason for this was to empha-size improvement of plant material condition This goal has become part of the Division's Nuclear Program Plan and has been translated into specific Performance Objectives for Managers and Supervisor This goal has established the "philosophy" of the ' organization, that being to provide . safe plant operation and to maintain equipment so the plant will be able to reliability produce power in the 1990's and beyon To this end the plant planned an outage during February /
March 1988. At that time, maintenant.e work was to be performed on several of the major systems. Such goals and related actions indi-cated a proactive approach in regard to safety and optimal plant operation on the part of managemen The VP and Departmental Managers recognized the need to improve interdisciplinary collaboration among themselves as well as all levels below. To this end a variety of formal and informal manage-ment structures have been established as well as training activitie Among these were:
Reconstituting the Work Management Committee as described abov *
Establishing quarterly planning and problem solving meetings of the VP and Department Manager *
Defining and formalizing the matrix management (Project Manage-ment) structure in the Nuclear Engineering Services area. This includes the creation of an expanded role definition of the .
system engineer, the development and implementation of a Project Management training course, and the responsibility charting of key interface group _ _ - _ _ _ -
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Establishment of a daily general staff meeting (8 AM Meeting)
led by the GS Operations. The purpose of this meeting is to overview plant operations. among and between the General Super-visory management level so that daily activities ~ arc coordi-nated. Several of these meetings were attended by the inspector who observed a significant amount of preparation and discussion by participant *
-Establishment of a maintenance scheduling meeting three days per week (11 AM meeting Mon. , Wed. , Fri .) at which time-0P, NES, QA,
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and Maintenance discuss current work schedules and status of maintenance projects. Again t:te individuals involved appeared prepared for the discussion / decisions require *
Establishment of. the Thursday PM General Management Meeting at which time there is an updating of key activities, review of major pr>jects in progress, discussion of budget, goals and objectives, schedule review and status up date. Participants were well prepared, a printed agenda was distributed and open cross discussion was hel . Delegation of Authority During a previous inspection by MRC, some question was raised by NRC relative to who has delegated authority for CCNPP's effective functioning in the absence of the Vice President. Interviews ' with all Department Managers indicated unanimous agreement that the Manager, Nuclear Opera-tions is in control (control seems to mean that of "operations" but, it was not clear from these interviews,- if the Manager, Nuclear Operations has full delegated authority for all the functions of the V Does . he assume general authority over the other Department Managers?) during. the absence of the VP. CCNPP has addressed this question by revising its
"Working Relations Policy - CCNPP" (Corporate Study 11-82-A, Draft Revision #4, January 1987). The inspector found that the document did not clearly describe the VP's delegation of authority to the Manager, Nuclear Operations. The document, furthernore, did not indicate specific delega-tion of authority for the other Department Managers. The inspector pointed out that CCNPP should consider specifying delegation of authority for the VP as well as the Department Managers in this documen . Establishing Performance Goals BG&E utilizes a modified Management by Objectives system. BG&E has an annually developed Corporate strategic plan. The CCNPP has translated this plan into a Nuclear Program Plan. The Nuclear Program Plan (NPP)is broken into two parts - a yearly plan and a long range plan.
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The NPP is revised each year and developed by the VP and Department Managers with input from sub units as well as the Corporate level. A )
l comparison of the Corporate plan and the NPP indicates a direct correla-tion. The yearly plan for 1988 had five major goal areas each consisting of numerous specific sub goal From the NPP, specific Performance Objectives are developed for the _VP, each Department Manager, and each General Supervisor. These Performance Objectives become one of the major factors in an employees' yearly Performance Appraisal . Beginning in January of each year, all managers and supervisors develop Performance Objectives which they will be held responsible for completing that yea Individual supervisors and managers appeared to take their Performance Objective plans seriously, thus the NPP is also taken seriously. Meeting their goals was one of the important factors in earning a reward / bonus at the end of the year. Thus, BG&E rewards managers for performance. A spot check of each of the Department Managers and several of the General Super-visors and supervisors showed that they were currently developing their Performance Objective plans. Of those plans reviewed, there was a direct correlation of Performance Objectives with the NPP. According to the proper functioning of a Management By Objectives System, CCNPP appears to be utilizing the most effective method for "getting" work accomplishe . Communications and Planning Interfaces Planning and attending meetings is an important time consuming activity at CCNP Various groups of managers, supervisors, professionals and support personnel gather periodically during the day / week at a variety of meetings to conduct planning / scheduling activities. These meetings pro-vided opportunities for various functional groups to interface and
"workout" common problems. Management recently created several of these r
"meetings" in an effort to bring about more coordination and to encourage more collaborative decision making. Such interface is conducted on a formal as well as informal basis. Generally, CCNPP utilizes a combination of two formal approaches, formal reports and meeting The inspector attended numerous meetings and observed a good flow of information. Participants were encouraged to communicate, although there was not too much cross talk. Meetings were run efficiently, were usually short and to the poin Support personnel were usually prepared with appropriate schedules, data and reports. There was a positive attitude .
among those in attendance. After meetings adjourned participants usually continued informal discussion of issues. This might cause a potential problem in that these "private" discussions did not become matters of awareness for other group member . _
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Attachment 2 6
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Planning was also carried out within specific departments which have established specific planning units. These planning units must interface with their counterparts in other departments as well as' with line employees (i.e., Maintenance Planning with System Engineers). One- of the major issues of concern regarding interfacing -between various work units was that of establishment of priorities between and in some cases within .
Department Inspectors found that what might be a high priority for Maintenance might be considered a lower priority for Engineerin The various planning meetings referred to above attempt to clari fy and ameliorate such differences, but these meetings may not be sufficient, may only satisfy particular concerns associated with the charter of the meet-ing group, or may be the inappropriate communication vehicle for setting priorities. Several examples of conflicting priority setting are pointed out in this report (the procurement process is one example, preventive maintenance may be another).
Another example was between the Maintenance and Engineering units. One of the major results of the January 1986 Reorganization was the removal of the Maintenance function from Operations to a new Maintenance Departmen To coordinate maintenance activities with the OP Department, a Naintenance Coordination function was established within OP. The OP/MC group reports to the GS of Operations. This group sets its maintenance priorities by scheduling daily maintenance meetings with other departments (at the 6:30 AM meeting and other meetings), chairs monthly review group meetings, plans future work, prepares FCR's, etc. The reorganization also estab-lished within the Maintenance Department a Planning Coordination unit whose role was to interface with OP and Engineering. Most safety related maintenance jobs must be approved by Engineering, specifically the Plant and Project Engineering Unit (Systems Engineers a new unit formed at the time of reorganization). Systems Engineers usually must coordinate with the Design Engineering unit. This arrangement may cause delays in accom-plishing maintenance work due to inter and intra group coordination prob-1 eras . This may occur because these various groups have different repor-ting relationships as well as differing prioritie Furthe rmore , each group S3s its own particular technical discipline / background. Because of-these conditions, each group perceived their role dif ferentl It is understandable, then, that a complaint generally heard was that "engineer-ing does not fully understand the special problems associated with maintenance."
Management appears to be aware cf some of these problems and was taking action to improve conditiens. The Engineering Department was defining and .
formalizing the matrix management (Project Management) structure in the Nuclear Engineering Services area. This included the creation of an expanded role definition of the system engineer, the development and implementation of a Project Management training course, and the respon-sibility charting of key interface groups.
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This program was just getting underway. This effort appeared to be a positive initiative although the "Expanded Job Description of the System Engineer" and the responsibility charting in the Project Management Course appeared confusing and bureaucratic. Management was aware problems did exist in their approach and were working at improvements. Management had provided team building training among the VP and Departmental Management group, and was providing conflict resolution training (Hostility Training Program) with lower level supervisor The company was also conducting a training course for the eighty key individuals involved in project managemen . Procurement Interface Problems During interviews with Department Managers, General Supervisors, and other employees, a consistent complaint was heard concerning ordering and receiving part Most of the complaints came from either the OP or Maintenance function Complainants indicated that parts were often not received in a timely fashion, thus holding up repair and maintenance work. A review of the Daily Maintenance Scheduling Log indicated some delay in repairs due to parts on orde The "Managers Key Operations and Maintenance Project List" (1/21/88) indicited, for example, that material for seismic support structure was not usable, and new material was ordered with a tight delivery schedule for pre-outage work. However, no purchase order had been cut as of January 22,1988 (several days af ter this situation was identified). The requisition appeared to be waiting for approval by the Design Engineering uni The required delivery date was February 10, 198 The Procurement Manager did not expect the material to be delivered by February 10, 198 The data from this example indicated a potential proble Inspection was made of the procurement process as it relates to safety related items. A functional review was made of the "Process and Contracts Coordination Unit" (PCCU) and the interface this function has with the Engineering Department and other appropriate unit The PCCU has three major functions:
Buy items it is allowed to buy (some of the procurement function is controlled out of the Corporate level office in Baltimore).
Coordinate with other organizational units items PCCU cannot bu These are generally safety related item * Coordinate service contracts, t
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Attachment 2
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The Fianager of PCCU perceived he had several major roles. Among these were to communicate CCNPP procurement concerns with Baltimore, to follow-up on Baltimore concerns, to communicate to the end user the status of requests, and to communicate priorities to Engineering. Below is a description of the procurement process related to safety related item (See diagram).
Safety related items may be purchased under either of three route Blanket procurement --
pre-established blanket orders with pre-certified / bid vendor The Design Engineering unit pre-approves safety related items to be purchased under the blanket orde Generally blanket requests are converted into purchase orders by the PCC Other safety related orders are either procured through "local pro-curements" or through "requisitions". Such orders must be reviewed and approved by a Design Engineer first and then by the Purchase Quality Unit (PQU), After review by the PQU, the request is sent to Purchasing in Baltimore who cuts the purchase order and buys the item requeste When the Design Engineer Unit receives the requisition, the Engineer-ing Procurement Cootdinator (EPC) (there are two such coordinators who service the entire plant) reviews the work and sends it to the appropriate Design Engineer for review and approval. After the Design Engineer complete his task the request is returned to the EP The Engineering Procurement Coordinator then sends the request to the Purchasing Quality Unit (PQU) which reviews, approves, and sends the request directly to the Baltimore procurement office where it is converted into a purchase orde A feedback communication interface problem exits. The EPC does not communicate the status of the requisition to the PCCU. The PQU does not communicate the status of the requisition to the EPC or PCC The PCCU learns of the requisition status only after Baltimore cuts a purchase order. This process may take several weeks. (See diagram).
Thus this procurement process does not appear to be functioning well for the following reasons:
(1) The PCCU and in turn the original requester do not know the status of the requisition af ter it leaves PCCU's control until the final purchase order is made. This process can take several weeks to complete. The Design Engineer and the PQU both do not supply feedback data to the level above -- PQU to DE; DE to TCC When feedback is supplied it is done on an in formal
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Attachment 2 9
. SAFETY RELATED ITEMS PROCUREMENT PROCESS Safety Related -yes Requisition
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Blanket Local Requisition !
Procurement !
Order _ ,
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DESIGN ENGINEERING Reviews & Approves
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PURCHASE QUALITY UNIT ,
Reviews & Approves ;
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PURCHACING & MATERIALS !
MANAGEMENT - BALTIMORE Initiates Purchase Order l and Buying Process i
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Attachment 2 10 !
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basis. No formal system is in place in which feedback ' data-goes
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, to the level above. Tha PCCU learns of the completion of the DE and PQU review / approval only after the request is made into a "
purchase order by Baltimore. Baltimore sends f a Purchase order summary report listing to PCCU monthly. This frustrates .the PCCU manager as he perceives his role as a communicator to the cus- t temer of the status of the requisitio .
(2) The Engineering Procurement Coordinators are- required to inter- !
-face -with the various Design Engineers, requesting them to review and approve requisition There are two Coordinators handling all request As of 12/15/87 there was a backlog of !
352 requests in Engineerin (See diagram) The Design Engineer considers the review and approval of purchase requests as a "collateral duty" which "interrupts the normal" duties of
, wor The Design Engineer is also requested to review .and approve work requests from others, such as, System Engineers and ,
Draftsme Each of the engineering disciplines -- mechanical,- "
electrical, I&C, civil, etc -- does not have dedicated design ;
engineers responsible for the processing / review of purchase :
requests. Currently an informal relationship exists between and '
among the various coordinators and engineers. Hence, when the *
sarvice time to review and approve requests was extended beyond reasonable time frames, many routine requisitions became high priority items.
1 The organizational interfacing associated with this ' aspect of !
the procurement process appears to be inefficient and ineffec- l tive. Each group feels ineffective and blames another for their ;
problem Procurement Coordinators are frustrated over the lack l
-; of formal feedback systems and their inability to service their i customer Design Engineers do not perceive their role.as giv- l ing high priority attention to safety related procurement requests; furthermore Design Engineers consider such requests as taking time away from other duties. Thus they have a nigh back-log. The Maintenance Dep&rtment is unable to make repairs for
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lack of parts. In effect the Maintenance Department is con-
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sidered ineffective by their customers, because they cannot make timely repairs. The Procurement unit is considered a "black j hole" by Maintenance, the Engineering unit considers themselves
- over worked and unappreciated for the many demands placed upon
- them. All this results in Operations being hindered for lack of ,
well maintained equipmen I
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Attachment 2 11
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Although this is merely one example of poor organizational interface caused by an inadequate communication system, it may not be the only example within the CCNPP. There is some evi-dence that the Maintenance Request and Maintenance Order process also does not adequately provide, for example, feedback of results by Operations to those performing maintenanc The relationship between Maintenance and the System Engineer units may not adequately provide for effective communication as indi-cated elsewhere in this repor As a result of lack of certain formal communication systems, individuals involved have created a network of informal communi-c.ation patterns. As a survival technique such informal systems appear to have been effective until now, b's t BG&E should not continue to rely on such informal networks especially, since accourcability should be require It should be noted that management was implementing a project management system as well as communication training program These initiatives are tangential to the direct problem cited i here but could have an indirect positive impact on this proble l (See Systems Engineer section for further discussion). ' Systems Engineers As a result of the 1986 reorganization, a Systems Engineer group within the Engineering Department was created. Many of these engineers were brought to the CCNPP from the Corporate office in Baltimor The term System Engineer seems to offer some confusion. "Systems Engineers" I are made of small work teams or units of professionals consisting of a l Principle Senior Engineer, an Engineer, an Assistant, Technical Assistant, and support staff. This team is responsible for engineering related work for one or more systems within the plant. They are considered "jack of all trades" being responsible for mechanical, electrical, controls, et related to daily operations and overall engineering. Thus, when staff refer to the Systems Engineer they appear to refer to this tea To I clarify the job of a system engineer, on January 19, 1988 an "Expanded Job i Description of the System Engineer" was issued in draft form by the l Engineering Department. (This job description was concurred in by the VP and other Department Managers). According to this job description the l definition of a system engineer is: !
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Attachment 2 12
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A graduate engineer or equivalent or an engineering analyst in Plant and Project Engineering who is assigned responsibility for maintain-ing expertise in assigned systems, and for serving as a focal point and team leader for system problem resolution and system improvemen The System Engineer may also be assigned similar responsibilities for components or other areas of responsibility which cross system line The inspector did not find any specific position descriptions for a
"systems engineer" except for tho general joc description referred to abov Interviews with Management indicated that in the early period of reorgan-ization, a few systems engineers were dissatisfied with .noving to CCNPP and left the company. During the first two years of operation, system engineer units spent time defining their work roles and relationships as well as learning about the systems for which they are responsibl Interviews with individuals in the maintenance area indicated dissatis-faction with systems engineers knowledge of plant systems in that sy ster.)
engineers did not have knowledge of the system for which they are respon-sible. Several systems engineers con fi rmed this impression. System engineers have received little inhouse and outside training on internal systems and project managemen Company management previously indicated to the NRC that they were aware of the systems engineer problem and would develop a training program designed to improve their understanding of plant systems and project managemen The Technical Training Staff was in the process of developing this program and had implemented several parts. They completed a task analysis of the job which had been translated into an "expanded job description for sys-tems engineers."
The training plan recommendation were to be brought to management for l approval in February 198 It consisted of a three part program as l follows: Orientation - utilizing a series of self study guides designed to ,
familiarize participants with plant sy s tems . This orientation was !
planned to be two weeks in lengt l Initial Training --
consisting of classroom instruction modules, qualification manual guide instruction, etc. This part was to consist of 12 weeks of training in one year and 564 hours0.00653 days <br />0.157 hours <br />9.325397e-4 weeks <br />2.14602e-4 months <br /> of training over an 18 month period. Training was to be performed by both inhouse and vendor trainers. As part of these efforts, a Project Management course had been designed, the pilot session was held during the second week of January 1988. Five more sessions of this course were ;
scheduled for CY 8 '
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Attachment 2 13
. Continuing Training. Continuing Training in technical and adminis-trative subjects was to be provided on an as needed basis to ensure i that the technical staff is well maintained and improves their job proficienc Such training was to be performed onsite/offsite by BG&E and vendor personnel. This training was to also consist of required reading /self study material The licensee's staff proposed to fully implement the System Engineer training program on September 1, 198 This would be the first consolidated training program for system engineers for CCNP . Management Information System Management had recognized a need to create an integrated Management Infor-mation System for the entire Division. The concept of this MIS is to con- ,
solidate all information under one computerized data based system. This ,
system is to provide for a comprehensive integrated computerized informa- l tion processing network that will support the CCNPP. Such a system would provide the various sub-components within the organization with access to data. The VP was creating a new Project Manager position, reporting directly to him, which will have lead in creating the system. By February 1988, a project team was to be selected consisting of key representatives from OP, Maintenance, Engineering, QA, Information Systems and an outside !
consultant. This group was to speak for their respective departments to ensure department needs were considered in the system. By June 1988, l Phase II was planned to begin which will consist of implementing the Plan over a 5 year phase in perio Although this activity was in the early planning stages, the system was to be based upon an Equipment Identification Number (EIN). Creating standard names / language for equipment was to be established. The EIN was l to be tied to engineering data to create a technical / data bas The sys-
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tem data base is to also include various administrative services -- train-ing, procurement, personnel, etc. Thus, a complete tracking of equipment, work, people and dollars is to be accomplishe This project appears to be an important initiative. NRC will continue to monitor progress of this projec . Turnover in I&C Section The I&C and Electrical sections report to the Manager, Nuclear Mainten-ance. I&C Technicians in this group have historically experienced higher ,
than usual employee turnover rates. This has resulted in a certain e nount '
of lower productivity in the I&C group -- I&C work not being performed in a timely fashion -- and a low average experience level of I&C employee ,
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Attachment 2 14 f
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According to information supplied by the licensee s iPersonnelj 0epartment, the attrition rate of Control Technicians - Nuclear during the first six ,
J months of 1987 shows an overall rate of 7%. Of the 30 employees in this ;
group, two transferred within the CCNPP, none of those who lef t I&C left the company. Although.the data _were not reviewed-by the inspector, licen- i see management indicated the 7% rate was lower than past years and that a ;
larger percent of past turnover reflected individuals . leaving the fir '
(
Some I&C Technicians expressed dissatisfaction with their previous General ;
Supervisor. (Management has recently employed a new General Supervisor -
apparently more acceptable to the employees concerned.) Everyone inter-viewed accepted the fact that a problem does exist in this are The .
problem appeared to be related to a perceived lack of career paths by [
individuals currently hired (many of these were ex-Navy). Management was !
aware of this problem and had implemented several steps to improve the !
situation.as outlined belo ?
i Management had conducted exit interviews with I&C personnel as well as l others in the plant. Data indicated that the plant hired highly intelli- l gent high potential individuals in the I&C area, but they had not com- l pleted an undergraduate degre Most were recent ex-Navy I&C technicians !
having been trained by the Navy. Many of those who left CCNPP cited a i desire for a college education leading to a technical college / engineering degree. Such an undergraduate degree program was not available in the Calvert Cliffs geographic area, conducted in the evening, except for one , i at Johns Hopkins Universit ;
i As a solution to the problem of high turnover in the these sections, !
management had planned and/or implemented several activities. (Some of i
, these activities are also an attempt to improve the general educational !
- level of employees within CCNPP and provide general career growth.) l l Formal Degree Programs 4 f
PG&E established an educational program with V of Maryland, and other i utilities (Louisiana Power and Light, S. Carolina Gas and Electric, ,
and Wisconsin Power) and other colleges in the area. The program leads to a BS degree in Nuclear Science. The original objective was ;
- to train GP employees to meet Shif t Technical Advisor standards but i was changed to meet all aspects of Engineering -- I&C, radiation '
safety, etc. Nine courses, three currently developed and implemented ;
and six under development, provided a technical and scientific core i
- curriculum totaling 120 semester hour Courses are taught using {
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CAI/CMI (Computer Assisted Instruction / Computer Managed Instruction) }
in conjunction with a textbook and instructor tutorin Additional !
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Attachment 2 15 ;
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courses are taught through the U. of Maryland's Open University pro-
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gram in a "seminar" format -- requiring readings, projects, and live ;
instructors. Lower level courses (first two years of college) are !
provided by Charles County Community College. These consist of math, ,
science, physics, chemistry, et These courses lead to an AA de0re Employees not desiring to enter the Nuclear Science degree program may complete their college studies at this tim The above two programs are paid ' through the company's Educational :
Assistance Program. The EAP is specified in BG&E policy. The' policy is extremely . liberal, paying for full course tuition if the employee passes the course. Books and incidental expenses are the employees responsibilit The above program relates .to the I&C turnover issue as it 1) offers employees an opportunity to receive a degree, and 2) offers them an !
opportunity to move into the engineering career-fiel t
- Inhouse Technical Prog.am !
CCNpP has developed an inhouse INP0 approved training program for technicians, . including I&C. Graduates of this program are given ;
recognition with a plaque mounted in the shop area. For one to move to an engineering position, they must complete the college programs described above and the inhouse technical training program. The Training Department's plan is to get the Engineering Department to recognize that the combination of the degree program and inhouse *
technical program is equivalent tn an engineering - degree. Getting -
acceptance for these programs is ar. issu The Training Manager ;
indicated that there is precedent for this in the Nuclear Division as :
company "policy" indicates that anyone going through the Nuclear Navy Power Officer Training Program is equal to an engineer for employment purposes. The Navy program does not require a degree, Journeyman and Apprent!ce Programs A journeyman program is also in existence designed especially to i satisfy the Navy trained individuals on board. This two ye:r program )
utilizes three months of formal training / lab training and OJT, even- l tually leading to a fully qualified technician positio The company also was developing and/or has an INP0 approved appren-tice training program and Job Qualification Card program for elec-trical and controls Technicians as we* as other maintenance disci-plines. This program will encourage local high s%ool graduates and new recruits to enter into the electrical and centrols technician career field. The development of the apprentice program was one of the Performance Objectives for CY 88 of the Training Manage l
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Attachment 2 16
. Other Local Programs BG&E was trying to encourage local citizens to become employed as I&C Technicians. In this way, they feel that there will be more likeli-hood the I&C Technician will remain in the geographic area. To this end management indicated that CCNPP was designing a program with the local high school. This program will present graduating local high school students scholarships to New River Community College, Dublin, V Scholarships will be offered to those local high school stu-dents who may be developed into good I&C technicians and eventually employed by CCNP Participants would receive a two year degree in the Electrical Technical Program (AA degree in Applied Science Electrica:/ Electronics Technician). Upon completion of this program they would be eligible for the V of Md self study program offered by the company leading to a BS degree. Participants would take the inhouse technical training program in electrical and control Another effort was the development of a work study program with local high schools in which the public schools would set up, within their vocational curriculum, a course of study in clectrical and control ,
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CCNPP would in turn cooperate with the schools by offering job oppor-tunities, thus students will gain practical experience by working at CCNP To help lessen the problem of relocation of ex-Navy families the company in conjunction with the "spouses club" had established an orientation program. During employment interviews the Club takes the spouse on a tour of the Calvert Cliffs area and provides some orien-tation and settlement assistance. The club also provided social activities, etc. for all personnel. All personnel in the plant may joi From the above, it is evident that BG&E is making a concerted effort to improve the high turnover situation as well as provide specific inhouse training for employee . .. .
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ATTACHMENT 3 POSRC DOCUMENTS REVIEWE0
- CCI-1031, 7/8/87, Organization and Operation of the Plant Operations and Safety Review Committee
- Calvert Cliffs Nuclear Power Plant Plant Operations and Safety Review Manual, March 27, 1986
- The followir.g - POSRC Meeting Minutes 86-99 12/01/86 86-109 12/19/86 86-100 12/03/86 86-110 12/22/86 86-101 12/05/86 86-111 12/24/86 86-102 12/08/86 86-112 12/29/86 86-103 12/08/86 87-116 12/16/87 86-104 12/10/86 87-117 12/21/87 86-105 12/10/86 87-118 12/23/87 86-106 12/12/86 87-119 12/30/87 86-107 12/15/86 88-01 1/06/88 86-103 12/17/86 88-02 1/13/88
LER; Loss of Main Generator Permanent Magnet Generator; Calvert Cliffs, Unit 2; 12/21/8 I
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ATTACHMENT 4 OSSRC DOCUMENTS REVIEWED
- List of Principal and Alternative Off-Site Safety Review Committee, 8/29/86
- Memorandum 11/27/85, from Vice President - Supply to OSSRC Principal and Alternative Members
- OSSRC Manual
- The following OSSRC Meeting Minutes 86-01 3/27/86 87-01 2/06/87 86-02 6/26/85 87-02 4/06/87 86-03 7/25/86 87-03 5/08/87 86-04 9/19/86 87-04 5/12/87 86-05 9/25/86 87-05 6/21/87 86-06 11/21/86 87-06 6/25/87 86-07 12/18/86 87-07 9/24/87
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O ATTACHMENT 5 QAU DOCUMENTS REVIEWED
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QAP 20, Rev. 18, Training
- QAP 26, Rev. 38, Control of Conditions Adverse to Quality
QAP 28, Rev. 24, Control of Items Covered by the Quality Assurance Program
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"1988 Evaluations" Schedule
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Evaluation, 11/21/86, Supervisory Review of Maintenance Orders
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Evaluation, 7/22/86, Wide Range Noble Gas and Main Steam Radiation Monitor Operability
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Audit 86-38, 12/03/86, Offsite Safety Review Committee Activities Audit
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Audit 87-03, 3/27/87, Surveillance Testing
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Audit 87-20, 10/14/87, Audit of POSRC Activities
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Audit 87-09, 5/22/87, Nuclear Engineering Services Training
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Audit 87-35, Draf t, Of fsite Safety Revf ew Committee Activities Audit
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Quality Audits Units Recommenda? ion Sheet, 86-38-R01
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Quality Audits Unit Recommendation Sheet, 86-38-R03
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Quality Audits Unit Finding Sheet, 87-35-01
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Quality Audits Unit Recommendation Sheet, 87-18-R01
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Audit 86-01, 3/6/86, Corrective Action Systems
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Audit 86-25, 10/31/86, Corrective Action Systems
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Audit 87-01, 7/17/87, Corrective Action Systems
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Audit 87-27, 10/29/87, Corrective Action Systems