IR 05000277/1985099

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Forwards SALP Repts 50-277/85-99 & 50-278/85-99 for Jan 1984 - Mar 1985.Assessment of Activities Found Performance Acceptable.Improvement Needed Re Radiological Controls, Security & Mgt of Training Programs.Related Info Encl
ML20135B754
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/27/1985
From: Murley T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8509110170
Download: ML20135B754 (4)
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g AUG 2 71985 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. S. L. Daltroff Vice President, Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen: Subject: Systematic Assessment of Licensee Performance (SALP) Report Numbers 50-277/85-99 and 50-278/85-99 This refers to the SALP for the Peach Bottom Atomic Power Station, conducted by this office on May 13, 1985 and discussed with you and your staff at a meeting on June 12, 1985. The list of meeting attendees is attached as Enclosure 1. The NRC Region I SALP Report is provided as Enclosure 2.and covers the period January 1, 1984 to March 31, 1985. Your_ response dated July 9,1985, submitted pursuant to our letter of June 7,1985, provided comments on the SALP Report. These letters are provided as Enclosures 3 and 4.

Our overall assessment of activities at Peach Bottom during this period, found your performance to be acceptable. Improvement in two functional areas has resulted in high levels of performance in maintenance, licensing, and re-fueling / outage activities.

Our reviews during the assessment period conclude that some performance short-comings exist in the areas of radiological controls, and security and safeguards.

Additionally, management attention is warranted in the areas of control and oversight of contractors, and the effectiveness of training programs. We acknowledge your initiatives put forth in Enclosure 4, however, a review of the SALP history (provided in Enclosure 5) for Peach Bottom Units 2 and 3 indicates that.a noticeable long-term positive impact on performance has not been achieved in many areas. Management attention to tracking'and assuring the effectiveness of corrective action initiatives appears necessary to ensure improvement.

In the meeting on June 12, 1985, we discussed our assessment of your regulatory performance and received your comments on the SALP program and our assessment. We have considered your letter of July 9,1985, and found no major differences of opinion regarding our assessment.

While our overall SALP conclusions have not changed since our lette- of June 7, 1985 forwarded to you the SALP Report, we have amended section 5.5 and Table 5 regarding forced' outages and unplanned automatic scrams. We have also made 0FFICIAL RECORD COPY GALLO8/16/85 - 0001.0.0 

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8509110170 850827 E 08/16/85 ,'fE PDR A a G 3* DOCK 05000277 PDRj Ih 

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.. . *t Philadelphia Electric Company 2 minor editorial and typographical corrections that did not affect our assess-ment or conclusions. We consider that our meeting and subsequent interchange of information were beneficial and improved mutual understanding of your activities and_our regulatory program.

In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures will be placed in the NRC Public Document Room. No reply to this letter is required. Your actions in response to the NRC Systematic Assessment of-Licensee Performance will be reviewed during future inspections of your licensed activities.

Your cooperation is appreciated.

Sincerely, Original Signed By: Thomas . Regional Administrator

Enclosures:

1. SALP Management Meeting Attendees 2. NRC Region I Systematic Assessment of Licensee Performance, Peach Bottom Atomic Power Station, May 13, 1985 3. NRC Letter, to S. L. Daltroff, June 7, 1985 4. PECo Letter, (SALP Report Comments) to Region I, July 1,1985 5. Peach Bottom SALP History

REGION I== . ' SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Philadelphia Electric Company PEACH BOTTOM ATOMIC POWER STATION May 13, 1985 

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t 't SUMMARY PEACH BOTTOM ATOMIC POWER STATION - UNITS 2 and 3 Functional Area ' Hours % of Time 

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1. Pl ant Operations. . . . . . . . . . . . . . . . 1850 34.0 2. Radiological Controist..........s....... ......... 489 9.0 ' 3. Maintenance...........,.................. 442 8.0 4. Surve111ance............................ 170 3.0 5. Fire Protection.......................... 84 1.0 

! 6. Emergency Preparedness.................. 538 10.0 7. Security and Safeguards. . . . . . . . . . . . . . . . .

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195 4.0 

. Refueling / Outage Activities............. 1654  31.0 9. Licensing Activities.........'...........  *- -

T0TAL....................................... 5422 100% 

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* Hours expended in facility licensing activities are not included with direct inspection effort statistics.

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UNPLANNED AUTOMATIC SCRAMS AND FORCED OUTAGES PEACH BOTTOM ATOMIC POWER STATION , Unolanned Automatic Scrams 

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Unit \ Date Power Level (%) Cause 3 2/,9/84 100 x Power spike resulting from pressure surge associated with malfunctioning 

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 'N  main turbine control valves 3 7/11/8 100
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APRM high flux scram occurred following Itghtning strike on 500 KV bus tie line . 3 8/21/84 100 Low reactor water level caused by ! malfunction in feedwater control circuit 

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3 11/14/84 20 APRM high flux scram as the B - recirculation pump was restarted 3 3/1/85 25 \ Low main condenser scram due to loss 

  .\cf offgas system combined with high cendenser in leakage Forced Outages Unit Date Cause
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! 3 1/I4/84 Loss of condensate pumps'due to 

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! E I/28/84 RCIC testable check valve 

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i leek. N , N ~ l Z 2'18/84 MSIV and feedwater check valves-LLRT 2* 2/27/84 Control rod pattern adjustment 

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2* 3/2/84 -, Water box inspection and repair, and control rod pattern - 

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adjustment 

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3* 3/16/84 Water box inspection and repair, 

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and control rod pattern adjustment 3* 3/20/84 Control rod pat' tern adjustment \ 38 3/23/84 tmen

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TABLE 5(continued) . 

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Forced Outages (continued) 

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Unit.. Date' Cause N 3* 'N 4/20/84 Control rod pattern adjustment 

 \ N and condensate pump repair 2 4/28/84 Shutdown for sixth refueling  .

x outage 3 6/2/84 . RCIC valve and feedwater ' 

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heater repair; and weld ' cverlay of.the jet pump 

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3* 9/29/84 Load reduction for control rod adjustments, B and C circulation ' 

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pump work, B and C condensate pump wo'rk 3* 10/25/84 Load reduced to lower radiation levels in the.off gas 3 11/6/84 Repair valve packing leak in drywell 3* 11/24/84 Load drop for condenser water box work 3* 12/1/84 Load reduction for waterbox . leak 

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repair , 3* 12/10/84 Load drop to repair recombiner condenser tubes i 3* 12/15/84 Load drop for control rod ' adjustment . 

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     . x 3* 12/20/84' Load reduction to limit off gas
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x - l i 3* 1/5/85 Load reduction.to repair broken test tap on the 3A condensate 

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Ferced Outages (continued) l Unit \ ate0 cause I N . 3* 1/15/85 - Load drop due to the E4 diesel  ! N i and 39A RHR valve inoperability.

\c , The valve was returned to service 

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3 1/23/85 

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Generator taken off line to clean up an' oil leak which caused a ' generatol' field s ground.

3 2/1/85 Mini-outageforssurveillanca 

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testing and miscellaneous maintenance (main stieam isolation valves and leak testing).

3* 3/9/85 N Contro1 rod pattern adjustme'nt , and condenser tube leak repair'N 

* Load drops / reductions only
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T5-1 TABLE 5 (Revised) UNPLANNED AUTOMATIC SCRAMS AND FORCED OUTAGES PEACH BOTTOM ATOMIC POWER STATION Unplanned Automatic Scrams Unit Date Power Level (%) Cause 3 2/9/84 100 Power spike resulting from pressure surge associated with malfunctioning main turbine control valves 3 7/11/84 100 APRM high flux scram occurred o following lightning strike on 500 KV j bus tie line 3 8/21/84 100 Low reactor water level caused by malfunction in feedwater control circuit 3 11/14/84 20 APRM high flux scram as the B 

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recirculation pump was restarted 3 3/1/85 25 Low main condenser scram due to loss of offgas system combined with high condenser in leakage 

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Other Forced Outages and Forced Power Reductions Unit Date Cause 3 1/14/84 Loss of condensate pumps due to room flooding 2 1/28/84 RCIC testable check valve leak and drywell , airlock leakage 

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O e T5-2 TABLE 5(continued) Other Forced Outages and Forced Power Reductions (continued) Unit Date Cause 3 6/2/84 RCIC valve and feedwater heater repair; and weld overlay of the jet pump instrumentation nozzles 3* 1/15/85 Load drop due to the E4 diesel and 39A RHR valve inoperability.

The valve was returned to service prior to unit shutdown.

3 1/23/85 Generator taken off line to clean up an oil leak which caused a generator field ground.

  • Forced power reductions only

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TABLE 6 < NRR SUPPORTING DATA AND SUMMARY A.

This following is summary of significant licensing actions and other activities during the assessment period.

1. NRR/ Licensee Meetings - 4 i IGSCC (Pipe cracks) and pipe repair / replacement Backup EOF PEco-H. Thompson meeting Purge / Vent TS ,' 2. NRR Site or Component Officer Visits - 3 PM Annual Audit of SPDS Data Visit (1984 and 1985) 

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Regulatory Performance meeting 3. Schedules Extensions Granted - 2 , Annual Emergency Exercise Equipment Qualification l I ' 4. Relief Granted - 1 . . ISI 

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5. Technical Exemptions Granted - 1 Fire Protection i 6. License Amendments Issues - 35 7. Energency Technical Specification Chances. Issued - none 8. O'rders Issued - 1 , i Confirmatory Orders ort NUREG-0737, Supplement 1 (both units) 9. NRR/ Licensee Management Conferences * 

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The following assessment details the NRR licensing actions completed during this period. I 

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o Plant-specific actions (48 completed): Actions.in this ' O category which were used to provide input for this evaluation. * 

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Review of plant specific Appendix R technical exemptions 

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Coolant Leakage Technical Specifications (TSs) Reactor water cleanup and scram discharge volume TSs 

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TS on local leak rate testing Increased core flow TSs .g. Ib 

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Hydrogen chemistry test TSs 

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Requalification exam extension 

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Unit 2 reload 

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o 20 multi plant actions (16 completed): Actions in this category .which were used to provide input for. this evaluation , are: - 

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Environmental Qualification 

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Generic Letter 83-36 Purge / Vent Valve Operability I o 20 NUREG-0737_ actions 10 completed): Actions in this category which were use(d to provide input for this evaluation - are: 

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Inadequate Core Cooling Guidelines (I.C.I.2.A) I 

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SPOS (I.D.2) . 

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Post Accident Sampling (II.B.3)  ; 

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Failures of Relief Valves (II.K.3.16) l l l 

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 "q     ENCLOSURE 3
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neDONI h est PARK AV2NU3 K3p04 CF PftUSSI A. PEMMSYLVANI A 19404 ona** JUN 0 71985 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. S. L. Daltreff ' Vice President Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 I, . 1 Gentlemen: Subject: Systematic Assessment of Licensee Performance (SALP); . Report Numbers 50-277/85-99 and 50-278/85-99 

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The NRC Region I SALP Board conducted a review on May 13, 1985 and evaluated the performance of activities associated with Peach Bottom Atomic Power Station, Units 2 and 3. The results of this assessment are documented in the enclosed SALP Board report. A meeting has been scheduled for 2:30 p.m. on 

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June 12, 1985, at the Peach Botton Atomic Power Station, Delta, Pennsylvania to discuss this assessment. This meeting is intended to provide a forum for - ccndid discussions relating to this assessment.

At the meeting, you should be prepared to discuss our assessment and your plans.to improve performance where weakness was noted. You are specifically requested to be prepared to discuss those actions p'lanned or implemented I regarding NRC concerns in the security and ridiological controls areas.

Additionally, you may provide written comments within 20 days after the 

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mesting.

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'Your cooperation with us is appreciated.

Sincerely, , 

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ula  : ! Thomas E. Murle l Regional Adminis r.-. Enclosure: ' * As stated , 

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_ _ . . _ _ P'c, Pliiladilphia Electric Co pany 2 i ec w/ enc 1: V. S. Boyer, Senior Vice President, Nuclear Power John S. Kemper, Vice President, Engineering and Research R. S. Fleischmann, Station Superintendent Troy B. Conner, Jr., Esquire (Receives All 2.790 Information) Eugene J. Bradley, Esquire, Assistant General Counsel Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector Commonwealth of Pennsylvania 

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ENCLOSURE 4 s > 

. PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET

, P.O. BOX 8699 PHILADELPHIA. PA.19101 (215) 841 Soot 

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 . tic = c m oucnoa July.9, 1985 .

i Docket Nos. 50-277 50-278 Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park' Avenue King of Prussia, PA 19406 SUBJECT: 1985 Systematic Assessment of Licensee Performance (SALP) for Peach Bottom Atomic Power Station J REFERENCE: SALP Report No. 50-277/85-99

50-278/85-99

Dear Dr. Murley:

The report referenced above is the 1985 Systematic Assessment of Licensee Performance (SALP) report of our Peach , Bottom Atomic Power Station (PBAPS) facility for the period January 1, 1984 through March 31, 1985.

On June 12, 1985, a joint meeting of the NRC Region I SALP Board and Philadelphia Electric Company management was held at the Peach Bottom Atomic Power Station to discuss the findings , in the SALP report.

We are pleased to find acknowledgement in the report that Philadelphia Electric Company demonstrated a noticeable improvement in maintenance, fire protection and housekeeping.

Since the last SALP report, we have intensified our efforts in many areas, but have been hampered by the extended outage for replacement of IGSCC sensitive primary system piping.

~ Philadelphia Electric Company appreciated the 

, opportunity to meet with the NRC to discuss the SALP report and  I i
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s D'r. Thomac July 9, 1985 , Page 2 ' to comment' on the findings. Based on the discussions at the meeting, we have the following comments: Plant Operations The period during which Peach Bottom Atomic Power Station was evaluated included an extended outage to complete complex and , difficult pipe replacement modifications. Our current plans include completion of these modifications and plant startup in July, 1985. We anticipate that the completion of these major modifications will allow more of our efforts to be directed toward other areas which require further improvement.

As indicated in the SALP report, training plays an essential role in all areas of plant operations. We have improved in this area, with five training programs having been accredited by the Institute for Nuclear Operations (INPO). These training programs for non-licensed and licensed operators, requalification for licensed operators, and training of health physics and chemistry technicians were accredited by INPO in May 1985. We are committed to a continuous strengthening of our training program and we are confident that further improvement in the training area will increase ! the efficiency of plant operations.

, The SALP report recommends that Philadelphia Electric Company evaluate the causes of the forced outages and unplanned scrams with respect to plant operations, maintenance and testing activities. After further review of the outage summary (Section 5.5 of the SALP report), we believe that the data as presented in the report may not be accurate and may not agree with our records.

The SALP report summarizes the forced outages for the assessment period as follows: 

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Unit 2 - 5 forced outages including 2 power . reductions and one shutdown for refueling 

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Unit 3 - 19 forced outages including 14 power  ! reductions / load level drops l l l ! l  ! 

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The outage history, as summarized in the SALP repo~rt, is not

consistent'with the data published monthly in NUREG-0020, 

" Licensed Operating Reactors - Status Summary Report".

NUREG-0020 defines outage types as follows: 

 "... forced outage is an outage required to be initiated no later than the weekend following discovery of an of f normal condition. Those outages which do not fit the

definition of forced outage ... are scheduled outages...".

For purposes of r eporting data for incorporation into NUREG-l 0020, we use the definitions as stated above. Every shutdown a or load reduction is listed in the NUREG-0020 and defines the outage type as being either forced or scheduled. Because BWR's require occassional load reductions to accommodate control rod adjustments, some load reductions are not considered by us to be forced. Based on_our records, the outage history for the assessment period utilizing the definitions of NUREG-0020 should have been reported as follows:

Unit 2 Unit 3 , Forced Shutdowns ..................... 3 8 l Forced Load Reductions . . . . . . . . . . . . . . . 0 2 Total Forced Outages ................. I 10 ' Scheduled Shutdowns .................. 3 4 Scheduled Load Reductions ............ 3 9 Total Scheduled Outages .............. 6 13 

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With regards to the recommendation to evaluate the causes of forced outages and unplanned scrams, we believe we have adequate processes in place which do this evaluation.

  • Unplanned scrams from power are analyzed with our procedure GP-18. The. appropriate corrective actions to prevent

, j recurrence of a scram are identified in the associated upset report.

In addition, the Operating Experience Assessment Committee reviews causes of unplanned scrams and forced outages and i i ! 

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i Dr. Thomas E. Murlcy July 9, 1985 Page 4 . 

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recommends appropriate corrective actions to prevent ' recurrence of the events which caused the scram.

Radiological Controls The heavy traffic into the power block during this extraordinary outage placed a heavy load on our Health Physics programs and personnel. During the outage, we 

. increased our attention to the radiological protection area

' and also increased management involvement. However, the amount of attention and involvement appears to have been j insufficient to overcome the additional loads created by the outage.

The increased emphasis on the Radiological Protection Program i was instrumental in maintaining the Peach Bottom history of l no overexposures. During 1984, all exposures were less than {' 5 Rem. Additionally, during the 15-month pipe replacement outage, only 19 workers received doses in excess of 4 Rem and 

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there were no incidents Which resulted in significant i 

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internal organ burdens. The original scope of the pipe replacement outage work was accomplished within the ALARA estimate.

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' During the latter part of the outage, there were two incidents which had a potential for causing higher internal i and external exposures. These were caused by a breakdown in administrative controls. These controls were immediately i strengthened and were proved ef fective.

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' l We have also reorganized the health physics and chemistry j

areas in an effort to further increase management control.

Each group is now under the separate, individual direction of

a senior-level supervisor. The division of these two i'

activities will provide enhanced management control of both the radiological protection and the chemistry areas. l We have also developed guidelines to be used during future major modification outages. The guidelines include assigning ' Health Physics /ALARA Technical Assistants (TA's)-to each of the major work areas in the plant. These TA's will ensure ALARA considerations are properly reviewed and implemented.

, The TA will be responsible for ensuring that an appropriate 

:  RWP is used for each assigned job and for monitoring the

' assigned work area via periodic, frequent work area tours. A conference will also be organized by the TA prior to each job ! . 

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i D'r. Tho2na July 9, 1985 Page 5 covered by an RWP to aid in worker awareness. This area supervision will ensure that there is adequate Health Physics support to maintain an effective Radiation Protection Program. We are confident that these changes will preclude the radiological control problems evident during the Unit 2 outage.

Meanwhile we are considering the recommendation for a third party audit in this area to ascertain what further actions may be used to improve performance.

Security and Safeguards Another area which was af fected by the heavy workload due to the demanding tasks of the pipe replacement outage was the area of Security and Safeguards.

i During the outage, the capacity of the security computer to monitor alarms was heavily taxed. We noted these difficulties and made changes in the computer software which have improved operation. Additional computer changes are currently being designed which will further benefit the security activities.

With the completion of the Unit 2 outage, along with the subsequent decrease in power block traffic, many of the security areas discussed will no longer be problem areas.

During the SALP period, increases and changes to the contractor security organization were made which we believe will improve security personnel and hardware performance at Peach Bottom. The contractor security force has been strengthened by the addition of an Assistant Trainer and Assistant Supervisor to the contractor staff. Additionally, the contractor security organization has added a special

assistant to the PECo Site Security Supervisor for the monitoring of security related hardware.

Management commitment to better and more thorough oversight of contractors is being pursued. We also agree, as stated in the SALP report, that there is a possible need for an Assistant Site Security Supervisor at Peach Bottom. We have recently initiated an effort to fill this position. , l l 

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t D'r. Tho22c E. Murlcy July 9, 1985 Page 6 i Surveillance Although the SALP report confirms that our surveillance testing program is technically sound and well planned, weaknesses were reported in the implementation and review cycle of the surveillances.

In an effort to improve performance in the surveillance area, we are pursuing, along with other items, further and more efficient use of a computer for tracking the implementation and review cycles.

The SALP report also raised some concerns over the methods we used to track and compute "as found" leak rate values. The methodology used to obtain and account for "as found" leakage rate additions to the ILRT are currently being reviewed by Philadelphia Electric Company.

Fire Protection / Housekeeping Fire barriers were reported as being a continuing weakness.

We have acknowledged these weaknesses and have moved promptly to improve in this area. The Engineering and Research Department has instituted a Fire Protection Review Checklist to be used for all plant modifications in order to evaluate the impact of each new modification on the fire barriers.

Further, fire barrier and penetration seal identification signs have been installed to allow personnel to be more aware of fire barrier requirements at the plant.

The door closure problems have been investigated. Some of the closure problems have been attributed to the nearly completed penetration seal program. Now that the penetrations are sealed, rooms are significantly more air tight which causes a greater pressure differential across the door than previously existed. Since this new differential pressure problem across doors has been recognized, we are pursuing possible corrective modifications.

Emergency Preparedness Some problems were identified in the January, 1985 inspection and were included in the SALP report. One of these problems, as stated, concluded that the appendices to the emergency plan that contains the names and telephone numbers of 

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i Dr. Thomas July 9, 1985 Page 7 

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personnel to be contacted during an emergency were' seventeen months overdue for a review / update.

Each change to the body of a procedure requires that the revision number of the procedure be changed. .Only this , revision number was reviewed during the January inspection and not all of the documentation including the surveillance documentation was reviewed.

An internal review indicates that the telephone list was surveillance reviewed for correctness every quarter of 1983 and 1984 and at that time no changes which would require PORC approval (and thereby require a new revision number) were necessary.

Because the revision number of the emergency plan procedure was not changed, the inspector concluded that the quarterly update had not been accomplished, when in fact the quarterly update had been completed and documented every quarter during the previous twenty-four months by way of the surveillance tests.

We are presently in the process of revising the procedures to allow easy identification of the quarterly review of telephone numbers.

License Activities The SALP report recommends that we pay more attention to the structuring of our licensing staff in order to accommodate the additional efforts required by the Limerick facility.

We have recently increased our licensing staff and have added another senior-level engineer. The licensing staff was also reorganized to accommodate the Limerick plant under the separate supervision of a senior engineer.

We fully expect that the reorganization and the additional staffing will improve our response and resolution time of license issues for Peach Bottom.

. Conclusion Two areas stand out in the SALP report as requiring more attention than others: Radiological Controls and Security / Safeguards. The recommendations in both of these i e _- ._ - _ _ _ _ _ _ . . _ . _ _ . - _ _____ ._ _ _ _ . _ , _ . . _ 

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* - ' Dr. Thomac"E.,-Murlcy    July 9, 1985 i
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Page 8 areas include increased management attention and efforts to 

 ' ensure improvement. Philadelphia Electric Company is moving to correct these deficient areas and we are confident that the next assessment will confirm the corrected conditions, i
 , Shotild you have any questions or require additional
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Very truly yours, ,. 

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cc T. P. Johnson, Resident Site Inspector r J 

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as ~ PEACH BOTTOM SALP HISTORY-ENCLOSURE 5- 

        -FUNCTIONAL AREA RATING
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_ Radio- Fire i RIport Assessment- . Ope ra- . logical Mainte- Surveil- Emergency _ Protec-Date Pe ri od tions '- Cont ro l s nance lance Plannino tion' Secu ri ty Refuelino Licensino ., 

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 '9/81  7/1/80.- 6/30/81 - 2   2 2 1 '2~ 3  2- 1 N-10/82' 7/1/81 - 6/30/82- 2    3 2 2 2 3  2 2 1 9/83. 3/1/82 - 2/28/831 2    '3 2 3 1 3  1 2 2 5/84 3/1/83 - 12/31/83 2   2 2 2 2 2  1 2 1 a

8[85~ 1/1/84 - 3/31/85 ' 2' 3- 1 2 2 2 3. 1 -1 e s' 

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