IR 05000277/1985098
| ML20215C170 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick, 05000000 |
| Issue date: | 12/09/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8612150049 | |
| Download: ML20215C170 (4) | |
Text
July 11, 1986
SUBJECT:
Assessment Period:
April 1, 1985 to January 31, 1986 (SALP)
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REFERENCE:
SALP Report.No. 50-277/85-98 50-278/85-98
Dear Dr. Murley:
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Your letter dated June 6, 1986, forwarded the Systematic Assessment of Licensee Performance (SALP) Rep The purpose of this letter is to provide the Philadelphiaresponse Electric Company (PEco)The response to the Limerick SALP Report will the SALP report.
be filed separately.
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Philadelphia Electric Company management appreciated the 12, 1986 at the opportunity to meet with the NRC staff on July Based Region I Office and to discuss the SALP Report findings.the meeting
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on the discussions at comments:
Plant Operations The SALP Board recommendations in the area of Plant Operations i
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are as follows:
Address the apparent complacent attitude and stress 1.
procedure compliance.
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August 12, 198'6
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Dr. Thomas'E. Murl-f Pago 3
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reduce-the time delay in obtaining blocks and to improve the legibility of permits.
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Operator training programs have been accredited by the 6.
untional Academy for Nuclear Training.
The SALP Report noted that "at times the public address from control room formality".
A system tends to distract planned modification vill provide for an upgrade of the plantOne fea public address system. separate page buttons for the control room a Depressing the general page button will page the the plant. not the control room.
Depressing the other page plant but button will page both the plant and control room areas.
Proper use of these two page buttons will reduce the number of non-operational related pages broadcast in the control
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room.
The number and repetitiveness of scrams reported against The Independent Safety Peach Bottom is of concern to us. reviews plant scrams and prepares Engineering Group (ISEG) reports to determine root causes and recom i
i event As part of this l
corrective actions to preclude recurrence.in scram analysis, the site ISEG
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involvement in the iBWR Owners' Group Scram Frequency participantReduction Committee's efforts to reduce unplanned scrams.
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commented during the. meeting, we are quite concerned that reactor scram signals generated in the course of performing in confined spaces under the vision and mobility outage work, constraints imposed by environmental conditions, are creating When the details of these an impression of poor performance. events are an&lyzed, we bel In reality, they were that they have minimal significance.
the result of bumping cables (which are highly sensitive to spontaneous pulse generation) while personnel were performing However, these and others like them are part
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record and we are concerned that of the Licensee Event Report these types of events are not discounted.
Radiologica) Controls Board Recommendations For Licensee:
Complete long-term transportation related corrective
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1985 actions discussed during the November 14, Enforcement Conference.
Evaluate the ef fectiveness of the QA program relative to 2.
transportation related problems.
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Auguot 12, 1986 Dr,. Thomao E. Murloy Pago 4
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Concerning Recommendation 1, all of the long-term transportation related corrective actions have been These involved the arrangement of rigging cables for pallets, the cask trunion cup contamination problem, and completed.
increased QC inspections during loading operations.
The SALP Report requests an evaluation of the ef fectiveness of the QA program relative to transportation related The applicable fuel floor (Fuel Bandling) and Bealth Physics (EPO/CO) procedures have been r programs.
Control and station personnel concerning radioactiveAs a result of the material / waste shipments.the Quality Assurance Division will be included in the review of fuel floor and Special Procedures identified items, relating to shipment of radioactive material / waste in o to include steps.
Additional actions being taken to improve our performance in the area of Radiological Controls are as follows:
the station will be The Health Physics Section at reorganized with the adoption of a Radwaste Section to 1.
be responsible for the handling and shipping and volume reduction practices.
the separation of Bealth As noted in the SALP report, Physics and Chemistry has been, and will continue to be, 2.
an effective step to improve the operations of these act.ivities.
Changes already made in the procedures and hard 3.
problems with such shipments which had occurred during I
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the SALP period.
in place and will be strengthened to reduce the volume of radwaste being shipped to disposal sites.
Programs are 4.
include the use of a supercompactor These programs willfor dry active waste and the installation of th system to reduce resin shipments and disposal.
I Improved frisking has been accomplished by use of automatic friskers located at key access points and 5.
t plant exits.
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August 12, 1986 Dr. Thomas E. Murloy Pogo 5
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Maintenance i
f Board Recommendations for Licensee:
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Improve the control of vendor information.
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t Peach Botton Procedure A-92, " Control of Vendor Manuals", was
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in December, 1985.
In response to INPO placed into effectrecommendations, a major rewrite of this procedure is bein
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performed which will substantially incorporate the concepts contained in INPO Good Practice NA-304.
In addition to the major revisions to Peach Botton Procedure A-92, we are continuing with the vendor manual update program committed to in response to Generic Letter 83-28 (Salem As a result of this vendor manual update program, we have identified a number of enhancements to the applicable ATWS).
Engineering & Research Department procedures pertaining to oris expected th It affecting the control of vendor manuals.
these ERDP procedures will be revised to include these enhancements by June, 1987 in order to provide a fully
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integrated system for vendor manual control between Peach Bottom and the Engineering and Research Department.
Additional actions being taken to improve our performance in the area of Maintenance are as follows:
Esintenance training programs have been submitted to and evaluated by INPO as pa,rt of the Accreditation process.
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On-the-job training has been formalized as part of the
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accreditation process and should improve performance of 2.
routine maintenance activities.
Maintenance personnel have been assigned to the planning in Pre-planning should result 3.
of non-outage work.
reduced equipment out-of-service times and reduced j
radiation exposure.
The daily meeting for planning and coordinating
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activities is continuing successfully.
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A major program is underway to clean up and paint t 5.
plantfoster a positive attitude in the workplace among plant l
l personnel that will encourage quality work.
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Surveillance Board secommendations for Licensee Establish management policy and controls which system operability.
Peach Botton Administrative Procedure A-43 (Surveillanc Testing System) has been revised, approved and implemented.
The revised procedure addresses control and disposition of Discussions between grace period tests and overdue tests. members of your staf Additional actions being taken to improve our performance in the area of Surveillance are as follows:
Backfilling procedures have been revised to eliminate
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scrams due to backfilling instruments.
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the In response to a weakness identified by NRC, Surveillance Test Tracking Software Program is being 2.
revised in order to clearly identify to appropriate those tests which require prompt station management action to ensure timely completion.
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i Fire Protection
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Board Recommendations for Licensee:
i Assess the results and evaluations of the radwaste build ng cable tray fire.
was performed by the An in-house evaluation of this eventSafety Evaluation Group (ISEG) Gro t
The ISEG PECo Independentindependent evaluation was performed by a ven the vendor report, Division comments on the vendor report were transmitted to report, to S. D. Ebneter, NRC, NRC via letter M. J. Cooney, PECo, dated May 21, 1986.
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Board Recommendations f or Licensee t resolution and corrective action 1.
Improve QA audit
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followup activities of emergency planning.
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August 12, 1986 Dr. Thomas E. Murle,
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2.
Promptly complete the actions required ot the Confirmatory Action Letter.
Concerning Recommendation 1, the Emergency Preparedness section tracks open critique / drill items.
The OA Division will conduct a comprehensive audit by the end of 1986 of the Emergency Preparedness program including emergency action levels and Emergency Preparedness Section tracking and resolution of critique and drill open items.
Concerning Recommendation 2, all of the actions identified by the Confirmatory Action Letter referenced in the SALP Report have been completed.
By March 31, 1986, eight. members of received formal training to corporate and station management qualify them as both Site Emergency Coordinator and Emergency Three additional members will also be considered Director.
qualified as of the same date when documentation of the required reading assignment is received.
Although the number of personnel available to serve the subject positions may be training to qualify all Shift Superintendents and adequate, station Senior Engineers is ongoing.
The corporate personnel designated as Site Emergency Coordinators, and the station Senior Engineers / Shift Supervision designated as Emergency Directors have been trained in the applicable event classification procedure (EP-This obligation was satisfied by virtue of 101).
Training participation in either the standard Emergency Plant Program or the Cycle I Licensed Operator Requalification.
Security and Safeguards Board Recommendations for Licensee:
j Provide closer day-to-day management oversight to assess 1.
the control of the contractor security force.
Establish measures to anticipate demands for needed 2.
resources of the security organization.
l A reorganization related to nuclear plant security is being l
Initially a senior-level, experienced security implemented.is being transferred to the Electric Production staff manager both nuclear plants.
This to direct security operations at is currently visiting other utilities to review individual their programs and identify practices which can further Based upon these reviews, enhance our security performance.
further reorganizaticn is contemplated including increased PECo security personnel presence at both nuclear plants.
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August 12, 1986 Pogo 8 Dr. Thoman E. Murio)
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Goals will be set and a timetable established to bring
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Security to a SALP rating of 1.
Refuelino/Cutage Activities None.
Board Recommendations for Licensee:
that We are pleased to find acknowledgement in the rating of " Category l' in this area.
the responsibility and authority of It should be noted thatthe outage manager has been strengthen ide him more control of activities during an outage.
Training and Qualification Effectiveness None.
Board Recommendations for Licensee:
d Training deficiencies noted in the SALP Report concerneOur comme Emergency Preparedness Training.
corrective actions taken to resolve these deficiencies provided in the Emergency Preparedness Section of this response.
Five programs are in the INPO accreditation process.
d an Responses to the recommendations have bee October, 1986.
is Feedback from plant events, particularly operator errors, being used to revise lesson plans and Simulator Training Scenarios to improve training effectiveness.
f pssurance of Quality Board Recommendations for Licensee:
review to determine:
Consider a management
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groups the effectiveness of the several oversight (1)
and to which these groups are used to assure that performance improvements are achieved the extent (2)
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August 12, 1986 Pcgo 9
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, Dr. Thomac 5. Murloy
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is an important organisation The Nuclear Review Board (NRS)
used by PBCo to review the effectiveness of the severalThe special meetings, and is kept well informed of plant events.
oversight groups.
The NRS is comprised of knowledgeable and expe The NRB has review safety concerns and corrective actions.
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l proven to be an effective mechanism for ensuring necessary
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improvements.
"QA oversight of The SALP Report also noted that:
it did not surveillance testing activities was weak in that identify weaknesses in the surveillance program such as the missed or partially completed surveillances, a Surveillance Tests."
PBAPS Administrative Procedure A-43 (Surveillance Testing System) has been revised to address overdue Surveillance The Quality Assurance Division will conduct an additional audit of the ST program by the end of 1986 to Tests.
include verification of the adequacy of this revised Administrative Procedure.
The SALP Report discussed Quality Control activities All purchase associated with Unit 3 fuel reconstitution. ord The Quality Control issued by Peach Bottom site.
d organization is responsible for reviewing all purchase or ers issued by the site for proper Quality Assurance requirements.
This review will provide QC with notification of upcoming
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fuel floor activities, thereby enabling QC to provide the proper coverage.
Review Committee, comprised mainly of operations
I personnel, has been established to review the re An Incident errors and to gain input with regard to appropriate l'
corrective actions.
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as developed by INPO The Human Performance Evaluation System, and several utilities, is in the process of beingSeveral people this use, and various mechanisms to inform the workers aboutThis progra implemented.
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program are under development.be implemented by the last qu l
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Licensine Activities mone.
soard Recommendations for Licenseet The SALP report noted a decline in the licensee's us Technical Specification issues, and the need to give more attention to the significant hasards considerationthat is submitted for determination (Sholly determinations)
While the each Technical Specification change request.
preparation of License Amendment Applications requ
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extensive review prior to submittal, we acknowledge that
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time needed to process an application should be reduced.
Acquisition of technical information necessary for preparation of the application, and on site review of th
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more timely manner.
A license amendment application summary report has been developed for monitoring the pregress of applicationThe report w preparation. Peach Bottom Licensing Engineer and submitted to his The management as part of the bi-weekly staf f minutes. re meet schedule milestones and permit management to focus on Additionally, the those areas requiring more attention.
Licensing Engineer who prepared the application will personally present the proposed application to the PORC for This should approval for all but minor license revisions.
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expedite the PORC approval process.
While the format of the significant hazards consideration was revised in response to a finding in last year's SALP, we were
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1986, to advised in Generic Letter 86-03, dated February 10, improve the technical discussions supporting the hazardsSi detenmination.
with the only application processed by the NRC since the letter was published in the Federal February 10, 1986 Register with few revisions, we conclude that our efforts to
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I improve the quality of the applications is approaching NRC We are pleased that the NRC's Project Manager expectations. concurred during the SALP meeting that the quality of the License Amendment Applications has shown a noted improvement
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We will continue to emphasize the in recent months.
importance of the significant hazards consideration in the preparation of future applications.
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Dr. Thomas E.
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I Should you have any questions or require additional information, please do not hesitate to contact us.
Very trul yours,
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s T. P. Johnson, Resident Site Inspector cc:
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ENCLOSURE 6
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ATTENDEES Philadelphia Electric Company J. Spencer, Superintendent, Plant Services, Limerick Generating Station
- J. Franz, Plant Manager, Limerick Generating Station G. Leitch, Superintendent, Nuclear Generation S. Daltroff, Vice President, Electrical Production M. Cooney, Manager, Nuclear Production T. Doering, Superintendent, Operations, Limerick Generating Station W. Texter, General Supervisor, Quality Control R. Deneen, Director, Security P. Weindorfer, Assistant Director, Security W. Knapp, Director, Radiation Protection C. Mangans, General Supervisor, Quality Assurance R. Dubiel, Sr. Health Physicist, Limerick Generating Station J. Gallagher, Manager, Engineering W. Casey, Superintendent, Station Section
, R. Fleischmann, Manager, Peach Bottom Atomic Power Station J. Basilo, Administrator, Engineering, Limerick Generating Station G. Hunger, Jr., Engineer-in-Charge, Nuclear Safety Section R. Logue, Superintendent, Nuclear Service R. Bulmer, Superintendent, Nuclear Training D. DiPacco, Sr. Engineer, Quality Assurance, Limerick Generating Station E. Gibson, Engineering, Quality Assurance, Limerick Generating Station W. Alden, Licensing C. McDermott, Manager, Public Relations W. Birely, Licensing Engineer, Peach Bottom Atomic Power Station J. Nagle, Licensing Engineer, Limerick Generating Station Nuclear Regulatory Commission R. Starostecki, Director, Division of Reactor Projects S. Collins, Chief, Projects Branch No. 2, Division of Reactor Projects R. Gallo, Chief, Reactor Projects Section 2A, Division of Reactor Projects T. Murley, Regional Administrator, Region I T. Johnson, Senior Resident Inspector, Peach Bottom Atomic Power Station E. Kelly, Senior Resident Inspector, Limerick Generating Station H. Williams, Resident Inspector, Peach Bottom Atomic Power Station S. Kucharski, Resident Inspector, Limerick Generating Station K. Abraham, Public Affairs Officer, Region I R. Keimig, Chief, Safeguards Security, Div. of Reactor Safety and Safeguards W. Johnson, Deputy Director, Division of Reactor Safety R. Martin, Project Manager, Nuclear Reactor Regulation J. Beall, Project Engineer, Division of Reactor Projects J. Wiggins, Chief, Materials & Processes, Division of Reactor Safety L. Bettenhausen, Chief, Operations Branch, Division of Reactor Safety Other D. Ney, Pa. Dept. of Environmental Resources, Bureau of Radiation Protection R. Wolf, Staff Writer, Philadelphia Inquirer i
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