IR 05000277/1987099

SALP Repts 50-277/87-99 & 50-278/87-99 for June 1987 - Jul 1988

ML20155J640
Person / Time
Site:	Peach Bottom
Issue date:	10/19/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155J638	List: IR 05000277/1987099 ML20155J635
References
50-277-87-99, 50-278-87-99, NUDOCS 8810260509
Download: ML20155J640 (45)

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ENCLOSURE SALP BOARD REPORT

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U.S. NUCLEAR REGULATORY COMMISSION AEGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECT:0N REPORT N /87-99 50-278/87-99 l

PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 l ASSESSMENT PERIOD: JUNE 1, 1987 - JULY 31, 1988 BOARD MEETING DATE: SEPTEMBER 15 AND 16, 1988 i

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SUMMARY OF RESULTS A. Overview On March 31, 1987, the NRC issued an order to Philadelphia Electric Company (PECo, the licensee) to shut down Peach Bottom Units 2 and 3 as a result of the previous SALP assessment and other pertinent in-formation. Thus, at the beginning of this assessment, both units were in a cold shutdown conditio The initial licensee response to the shutdown order did not acknowl-edge the depth and breadth of the problems within the licensee organ-ization. After considerable prodding by the NRC and other outside I organizations, the licensee provided a comprehensive response (April 8, 1988). This response included a reorganization to focus the attention of senior corporate management on the nuclear facilities and to strengthen oversight organizations, provided new managers and executives with demonstrated leadership skills at every level from the shift managers to the Chief Executive Officer, increased the num-ber of licensed operators, and worked to develop an attitude dedicated to excellence in nuclear operations with management systems and inde-pendent oversight provided to ensure success. It appears that the licensee has made considerable progress toward achieving these goals by focusing attention on the areas of operations, maintenance /

surveillance, and engineering / technical suppor Progress has been slower in other areas such as security in particula Although the licensee had been made aware of a problem in the area of security and safeguards before the end of the assessment period, performance continued to degrade throughout the period with inadequate oversight of the contractor organizatio The performance ratings during the previous assessment period (Febru-ary 1, 1986-May 31, 1987) and this assessment period (June 1, 1987-July 31, 1988) according to functional area and trend, if any, are given below.

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Functional Rating Rating Area __

Last period This Period Trend Plant Operations *

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Radiological Controls 2 2 Maintenance / Surveillance 2 2 Improving -

Emergency Preparedness 2 2 Security and Safeguards 2 3 Engineering / Technical 2 1 Support Safety Assessment /

Quality Verification + 2 i Training and Qualification **

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Effectiveness ***

Licensing Activities 2 +

Assurance of Quality * +

Performance was determi ed to be unacceptable as reflected in

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the issuance of the shutdown order (March 31, 1987); therefore, no SALP rating was appropriat **

Not evaluated as a separate functional area last period because the extent to which apparent weaknesses in supervisor training contributed to the inattentive control room behavior leading to the shutdown order was still under review at the close of the assessment period; no rating was assigne ***

This functional area has become part of the evaluation criteria for all functional areas and is no longer a separate functional area (see Section III).

+ Safety Assessment / Quality Verification is a new functional area ,

which combines the previous areas of Licensing Activities and :

Assurance of Quality.

As mentioned above, this assessment includes the eva

uation of Safety Assessment / Quality Verification as a new functional area. The topics asse sed in this new area include what was formerly covered under the functional areas of Licensing Activities and Assurance of Qualit Refueling and outage activities were evaluated as pait of the Engineering / Technical Support functional area for the first time during this assessmen; period. Fire protection is assessed in the functional i

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! area of Plant Operations since there was no special programmatic

. inspection in this area. Housekeeping is included in the area of i l Maintenance / Surveillanc !

l B. Other Areas of Interest j i

t Licensee Activities  !

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Peach Bottom Units 2 and 3 were issued operating licenses on

October 25,1973 (DPR-44), and July 2,1974 (DPR-56), respectivel l

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Unit 2 began commercial operation during July 1974 and Unit 3 l began commercial operation during December 1974. Units 2 and 3 :

4 are boiling water reactor (BWR) systems supplied by the General ;

1 Electric Compan The status of these two units at the time of :

this assessment (June 1,1987-July 31,1988) is given below, ;

4 as well as the management changes that resulted from the NRC ;

j shutdown orde i Unit 2 was defueled in the middle of a refueling outage at the

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beginning of the assessment period and remained in a cold shut- ;

down condition, as required by NRC order, during the entire j assessment. Core reload, which began June 22, was completed on ;

, July 1; core verification was completed on July 28, and the !

i vessel head was tensioned on July 31, 198 For the remainder i

, of 1987, refueling outage recovery efforts and reactor vessel '

j hydrostatic testing preparations were in progress. The mode j switch was placed in refuel and a hydrostatic test was performed ;

from February 21 through March 1, 1988. On May 18, 1983, the ,

j reactor vessel was disassembled to conduct an inspection of the l

! reactor vessel shroud access manways. After completion of these (

) inspections, the vessel was reassembled. For the remainder of I

! the assessment period, system maintenance outages, plant modifi- (

l cations, corrective and preventive maintenance, and system testing (

were performe (

l i Unit 3 also began the assessment period in a cold shutdown condi- ;

tion. Preparations for the recirculation pipe replactrrent outage i

, began during August 198 The pipe replacement outage began on !

! October 1, 1987, and by the end of the year core offload was -

) complete and pipe decontamination activities were under way, Pipe decontamination efforts were completed in January 1988, and !

the first cut of recirculation pipe occurred on January 26, 198 !

i Oy mid-March 1988, all recirculation and residual heat removal l j (RHR) piping had been removed. Replacement piping installation !

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was complete in early July 1988, and reactor vessel fill began !

i on July 5, 1988. The reactor vessel fill was complete on July l

l 9, 1988, and for the remainder of the assessment period, routine i outage work continue l l The shutdown order of March 31, 1987, had instructed the licensee to provide for NRC approval a detailed and comprehensive plan l

! and schedule to ensure that the facility would be operated safely

{ before the NRC would consider a proposal for restart. The l 5  :

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licensee submitted its "Commitment to Excellence Action Plan" on August 7, 1987 for NRC approval. On October 8, 1987, after a detailed review, the NRC informed PECo that the staff had identi-fied several concerns with the licensee's response to the root cause issue and that further review of the plan had been deferred pending receipt of a revised plan that addressed the expressed Concer In the fall of 1987, the licensee undertook a major reorganiza-tion of its site and corporate staf On October 23, 1987, a new individual assumed duties of Superintendent-Operation The Peach Bottom shift managers assumed shift leadership roles on October 25, 1987. In October 1987, PECo announced a planned corporate and site reorganization plan including a new Peach Bottom Plant Manage However, subsequent changes occurred and J. F. Franz, formerly the Limerick Plant Manager, assumed Plant Manager duties for Peach Bottom on January 4, 1988. The licensee '

also implemented the Nuclear reorganization on January 4,198 The licensee's new "Plan for Restart of Peach Bottom Atomic Power Station" was submittoa in two sections: Section I, Corporate Action, on November 25, 1987, and Section II, Station Action, on February 12, 198 The licensee also made the following additional corporate per-sonnel changes in March 1988: J. F. Paquette as President and Chief Operating Officer (eventually Chairman and Chief Executive Officer), C. A. McNeill as Executive Vice President - Nuclear, and D. M. Smith as Vice President-Peach Bottom Atomic Power Station. Following staff questions and changes in management a revision to the plan was submitted April 8, 198 . Inspection Activities Three NRC resident inspectors were assigned to the site during the assessment period. The total NRC inspection time expended during the 14-month assessment period was 7393 hours0.0856 days <br />2.054 hours <br />0.0122 weeks <br />0.00281 months <br /> or 6337 hours0.0733 days <br />1.76 hours <br />0.0105 weeks <br />0.00241 months <br /> on an annualized basis. Distribution of these hours by i

functional area and a summary of enforcement activities are l shown in Tables 1 and 2. respectively, in Section V of this assessmen Although both Peach Bottom units remained shut down by the NRC 1 ceder of March 31, 1987, during this assessment period NRC in-t spection teams evaluated the following areas during the times specified in parenthese * environmental qualification programs (June 1987)

emergency preparedness exercise (December 8,1987)

inservice testing program (November 1987)

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shift crew teamwork on the Limerick simulator (November 1987 to January 1988)

• licensed operator rehabilitation training (September 1987 to January 1988)

• Unit 3 pipe replacement nondestructive examination (May 1988)

• Peach Bottom maintenance program (July 1388) Other NRC Activities The NRC instituted a Peach Bottom Restart Panel to review the licensee's restart plan. Activities include periodic meetings with licensee personnel, development of a restart safety evalua-tion, and augmented monitoring of licensee activities and per-formance. The first meeting was held on August 13, 198 NRC senior management visits to Peach Bottom during the period include the following:

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NRC Commissioner K. Carr on December 15, 1987

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J. M. Taylor, Deputy Executive Director for Regional Operations; W. T. Russell, Regionsi Administrator, Region I; and S. Varga, Director, Division of Peactor Projects - I-II, on August 11, 1987

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T. E. Murley, Director, Office of Nuclear Reactor Regulation, and members of his staff on June 27, 198 III. CRITERIA

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Licensee performance is assessed in selectad functional areas, dependirtg on whether the facility is in a construction or operational phas '

Functional areas normally represent areas significant to nuclear safety l and the environmen Some functional areas may not be assessed because l of little or no licensee activities or lack of neaningful observations in that area. Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functional area:

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• assurance of quality, including management involvement and control l

• approach to the resolution of technical issues from a safety standpoint

• responsiveness to NRC initiatives e enforcement history I

• operational and construction events, including response to, analyses

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of, reporting of, and corrective actions for a staffing, including management

• effectiveness of training and qualification program However, the SALP Board is not limited to these criteria and others may have been used where appropriat On the basis of the SALP Board assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance catagories are given belo Category Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance subrtantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category Licensee management attention to and involvement in the per-formance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirement Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal level Category Licensee management attention to and involvement in the per-f3rmance of nuclear safety or safeguards activities are not sufficien Thi licensee's performance does not significantly exceed that needed to mee? minimal regulatory requirement Licensee resources appear to be straued or not effectively used. NRC attention should be increased above normal 'evel The SALP reprt may include an appraisal of the performance trend in a functional area for use as a predictive indicator if near-term performance is of interes Licensee performance during the last quarter of the assessment period should be examined to determine whether a trend exist Normally, this performance trend only should be used if both a definite trend is discernible and continuation of the trend may result in a change in per formance rating. The performance trend is intended to predict licensee performance duri:,; ;he first few months of the next assessment period and should be helpful in allocating NRC resource Determination of the performance trend should be made selectively and should be reserved for those instances when it is necessary to focus NRC and licensee attention on an area with a declining performance trend, or to acknowledge an improving trend in licensee performanc The trend, if used, is defined belo Improvin Licensee performance was determined to be ireproving near the

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close of the assessment perio Declinin t.icensee performance cas determined to be declining near the cT6se of the assessment period and the licensee had not taken meaningful steps to address this patter ,

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I PERFORMANCE ANALYSIS P,lant Operations (2355 hours0.0273 days <br />0.654 hours <br />0.00389 weeks <br />8.960775e-4 months <br /> - 32 percent) Analysis During the prev aus assessment period, the licensee's performance in this area of plant operations was rated as unacceptable as reflected by the shutdown order issued March 31, 1987. Control room operators were found to be inattentive to licensed dutie Shift management knaw of and condoned this behavior. Plant man-agement either knew or should have known and touk either no action or inadequate action to correct the situatio Corporate man 3gement failed to recognize this de: lining trend in Peach Bottom perfo:mance, Durilig the current astessment period, resident and specialist inspectors routinely reviewed plant operations during shut # vn and refueling mode conditions. The functional area of pit .

operations also was reviewed during operational simulator evaluations, operator rehabilitation training, the n.aintenan team inspsetion, and periodic licensed operator examinations, j In response to the shutdown order, the licensee made personnel changes in the operations line organization. A new operations Engineer, Superintendent-Operations, and Plant Manager were assigned. Later in the period, the Plant Manager was designated the 31te Vice President and the Limerick Plant Manager was assigned to Peach Bottcu as Plant Manager. Management oversight of operations activities has improced. Management has been involved in daily operations acaetings, in immediate followup of events, in providing oversight at event critique meetings, and in interface activities with other plant and site group The licensee implemented a shift manager concept in October 1987 as corrective action in response to the shutdown ordcr. The licensee replaced the shift superinteneents with individuals having more authority and a broader responsibility during normal operation The shift managers each hold a degree in engineer-ing and are senior reactar operators. The licensee activated the licenses for these shift managers and provided them with training, including the "Managing fo.- Extellence" course. The l

' selection process for this new position included an assessment of their managerisl aptitude and of the atT.itudinal readiness to esta'olish and maintain standards of excellence in nuclear opera-tions. Overall, the selection criteria used for these positions were found to be very high, contributing posisively to the potential success of the shift manager position and subsequently the success of the new operating crews headed by the shift man-agers. On the basis of the inspectors' observations, simulato evaluations, and interviews, the shift managers hsve provided i . 'fective oversight of shift operation They have demonstrated i good overall ability to command and control ard provide i 10

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effective leadership. The effective oversight of the1e shift ,

managers was evident during the Unit 2 hydrostatic test, response to shutdown plant transients, conduct of shift turnover and other periodic meetings, and functioning as the emergency director during drill Licensed operators attended a'6-week rehabilitation training pro-gram called "People - The Foundation of Excellence" (PFE). The NRC reviewed course materials, attended portions of the course, and interviewed licensed operators before and af ter course completion. Specific weaknesses that wer e noted early ir, the evaluation process were discussed with site canagement, and licensec management took action to correct these course short-comings. Although the NRC concluded that this program was effective, it further recognized that the program would require plant management reinforcement to ensure continued positive effect The WRC decided to assess the overall crew interactior., the knowl-edge and use of Peach Bottom procedures, the knowledge and use of Technical Specifications, crew communications, and operator ,

responsibility because the shift managers and operating crews -

were newly established. The objective of this assessment, which was performed at the Limorick simulator, was to evaluate the effectiveness of the shift managers and to ensure that all operat-ing crews exhibited acceptable performance for the safe restart ,

of Peach Bottom. Overall, the NRC cctcluded that each operating crew exhibited satisfactory performance for all areas assesse The crews responded very well to transients and demonstrated good knowledge and use of Technical Specifications and proce-dures. The shift managers were effective in their roles as crew supervisors and leader Because the Limerick Sin.ulator provided limited opportunity to evaluate the technical proficiency of . e licensed operators after an extended shutdown, subsequent evalua- ,

tions were performed at the new Peach Bottom simulator after the ,

end of the perio At the end of this assessment period, the lic.ensee had 18 senior '

reactor operators (SR0s) and 18 reactor operators (R0s) with active licenses on a six-shif t forward rotation, as well as 7 ,

R0s that had recently passed an examinatio Thes, there were (

43 licensed shif t operators at the end of this assessment compared with 36 at the end of the last assessment. The licensee had not clearly defincd to the NF.C staff its utimate goal for t licenses to assure that unplanned overtime is effectively con-trolled and that opportunities for short and long term rotation of licensed operators off shif t are provided.

i During this essessment period, three sets of operator and senior  !

operator license examinations were given at the facility. A total of 5 SRO and 16 RO candidates were examined with 5 R0

candidates failing the written and/or operating portion of tne

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examination. This is an overall pass rate of 76 parcent and is  ;

a decline from the overall pass rate of 93 percent achievad -

during the isst assessment period. After entering emergency

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procedures, some candidates were hesitant to use the procedures to respond to the plant conditions in a real-time manne Generic strengths found during the examination included the ability to lucate reference material ta the control room, including piping and instrumentation diagrams, and the acquired knowledge of off-rormal and operational transient procedures and

administrative procedure '

The licensee was generally conservative with regard to using the emergeitcy notification system (EN5) to immediately report to the NR LERs generally were of good quality and precise; however, some reports had poor event descriptions, some lacked informa-tion reflective of an adequate assessment, and a large number were late. The cause of these late and poor quality reports was a ecmnunication problem between plant and offsite organizations and an apparent lack of overall report accountability. Specific '

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deficiencies are described in Section V.D. of this repor A large number of shutdown cooling isolations occurred early in the assessment period. Although each event was reported and the root cause was analyzed, the licensee did not perform an overall root cause analysis and develop a corrective action plan until requested to cia so by the NRC. Once requested, this root cause analysis was adequately performe Some corrective actions have

, been taken and others are under further study. A reduction in the number of shutdown cooling isolations was seen in the latter

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part of the :.Aessment perio A significant improvement has been noted in the quality and

implementation of operations procedures. This can be largely

attributed to licensed operator awareness of the importance

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of procedures and compliance with them as taught during the pFE training course. In addition, many licensed operators have

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initiated procedural improvements. As a result, there were a I

reduced number of reportable events caused by licensed operatur failures to follow procedures. Nonetheless, continued manage-i ment attention is required to ensure completion of procedural revisions, and adherence to and sompliance with procedures at all level Weaknesses were noted in the licensee's permit and blocking (equipment control and tagout) system. Errors both in permit j preparation and application resulted in eighs reportable events, r

In addition, the process of temporary clearance of a permit has i

resulted in reportable events and, in one instance, in damaged

, valves in the shutdown cooling system, including damage to the Limitorque operators and breakers for these valve The licensee was still not ensuring that the required periodic ;

training was being completed by all fire brigade members. Fire 1

. brigade training has been identified as a weak area since 1983 i in NRC inspections and the licensee's own audits. Corporate management had previously committed to the NRC to improve the j i

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fire protection program to make up for deficiencies in safe shutdown component fire protection and training for the fire brigade. Furthur licensee attention is needed in this are Operations control of plant conditions during outages for both units was a strength. Operations personnel developcd t.nd imple-mented special procedures (SPs) to control these changing plant conditions. These SPs included the coordination and control of '

reactor water level during the Unit 3 pipe replacement outage, control of special maintenance conditions for both units, con-trol of the Unit 2 hydrostatic test, coordination and conduct of the Unit 3 chemical decontamination, and planned removal frcm service of the shutdown cooling system for maintenanc Improvements were noted in overall control room formality and physical appearance. During the shutdown, the licensee com-pleted extensive control room human factor enhancement modifi-cations. Operator demeanor and physical appearance was improved and a new code of "control room etiquette" was developed and implemented. There was a noted improvement in shift turnover, licensed operater attitudes, and overall inter-faces with other department No inattentiveness was note The control of overtime meets NRC requirement Non-licensed 3 operator shift turnover is now conducted outside the control room to minimize overall congestion. The licensee also is currently upgrading the control room office and other facilities.

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All of these physical, procedural, and attitudinal changes have resulted in an improved control room atmospher I In summary, the establishment of the shif t manager positions and personnel changes in operations line management appear to be i

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improvements but have not yet been tested in an operating environmen Training conducted to "rehabilitate" the operators was effective, but continued management reenforcement is required to ensure future success. The number of available licensed shift

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i operators increased. Failure to submit timely and complete LERs in some cases, failure to complete all required fire brigade

training, and events caused by equipment control deficiencias ;

were considered weaknesse . Performance ".ating This area was rated Category 2.

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The licensee should ensure that there is continued plant management reinforcement of the operators with the principles ;

of the PFE progra '

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The licensee should clearly define and implement a staffing plan for increasing licensed operator y

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The licensee should fully implement fire brigade training.

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The NRC should conduct additional licensed operator proficiency and shift crew performance evaluations at the Peach Bottom Simulato B. Radiological Controls (591 hours0.00684 days <br />0.164 hours <br />9.771825e-4 weeks <br />2.248755e-4 months <br /> - 8 percent) Analysis The previous performance rating in this area was Category The licensee had an effective environmental monitoring program and innovative chemistry control. Weaknesses in the radiation protection program had been observed as a result of understaffing of supervisors, poor followup on deficiencies, weak upper management leadership, poor policies and procedures, ineffective internal assessments, and hostile relations between department During this period there were five radiation protection inspec-tions, one radioactive waste management inspection, one non-radfological chemistry inspection, and a special maintenance team inspection. A management meeting was held in February 1988 to discuss radiological protection program concern Radiation Protection Most weaknesses in the previous assessment were resolved during this period. The health physics (HP) organization in the HP

, operations area was significantly expanded and restructure Six new shift foremen were added, reporting to the operations i supervisor. This action increar.ed oversight of activities in the plant on all shifts and weekends. A new operational HP supervisor was hired into the organization and has introduced

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f new approaches and expertise to this area, Job descriptions with clearly defined accountabilities are now available for

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these positions. These positive developments were affected somewhat by the extensive outage work, the reorganization, and two changes of upper department management.

j Several positions remained unfilled for an extended time, con-

tributing to delays in the development and implementation of new policies and procedures that were completely rewritten during

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i this period. Although the procedures are now clear and con-sistent, the busy outage schedule caused some problems with

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i implementation such as numerous failures to adequately surve Nonetheless, the licensee resolved these difficulties with increased training on the procedures for all personne Internal assessment was improved during this period. A cumber-some radiological deficiency reporti.g procedure was replaced with a procedure that focused more attention on performance

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improvement and root cause analysis. The licensee formed a

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corporate HP assessment group that completed several onsite reviews. Quality Assurance (QA) auditing became more effective as a result of changed QA procedures, training of QA personnel, and use of outside technical experts. For example, a QA audit

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i finding led to the development of more job-specific radiation worA permit requirements. In addition, the Nuclear Review Board became' actively involved in efforts to reduce incidents of skin and clothing contamination. Toward the end of this period, the licensee began sending its personnel to visit other sites so that !

they could benefit from the experiences at other nuclear utilitie [

Relations between HP and other sits departments such as opera- ,

tions and maintenance were dramatically improved toward the end j of the perio Frequent and cooperative interfacing at worker ;

and supervisor levels was observed. Corporate and plant manage- !

ment efforts to achieve a team approach to resolve problems on i the site were a major accomplishment this perio The licensee has not effectively used aggressive goals to im- l prove ALARA performance. The station goal for 1988 was set at !

3610 person-rem and the initial goal for recirculation pipe :

replacement (RpR) was selected as 1725 person-rem. Additional t programmatic weaknesses included failure to pursue worker sug- ;

gestions, an ineffective station ALARA committee, and minimal !

effort to create a positive worker attitude toward ALARA. The r new plant manager initiated action to resolve these weaknesses '

toward the and of the assessment period. This included improving :

supervisory attendance at the ALARA committee meetings and a .

clear demonstration of management commitment to ALARA. A  !

periodic ALARA newsletter, a poster campaign, and ALARA awards [

demonstrate this commitment. The RpR project was .iearing com-pletion with euposures much lower than anticipated at less than !

i 1300 person-re This excellent performance is attributea to a i

highly experienced contractor force and excellent oversight by i I the licensee. No major radiological problems were experienced l

during this project and the contractor ALARA program displayed ;

initiative and creativit (

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j The inservice training of HP technicians was weak as a result of !

l inexperienced instructors and poor facilities. Although a major j restructuring of the training department has occurred, its  ;

j effectiveness has yet to be observe l

t The licensee's approach to certain technical issues was sound;

, however, delays were sometimes noted. A new "total dose con-l trol" program was implemented. All personnel are now required to

pass through a general access control before entering the power

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block and log in on a radiation work permit so that dose can be tracked. In addition, good control of hot particles as well as t improvements in locked high-radiation areas was observed. The f

licensee also decontaminated a large portion of the plant and {

j eliminated a number of hot spots, which has resulted in more

accessible plant areas and a better worker attitude. This im- ;

i provement was the result of the licensee using highly qualified !

technical consultants as part of its commitment to excellence l program.

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Radioactive Waste Management and Transportation During this assessment period one inspection of the licensee's  !

solid radioactive waste (radwaste) program was performed, in- j cluding processing, preparation, packaging, and shipping. The  :

radwaste organization was recently reorganized and has responst- '

leilities for waste processing, classification, inventory mint- i mization, planning and engineering activities, and radwaste i packaging and shipping. Through this reorganization, the  !

licensee strengthened and clarified the responsibilities of the f group. Approximately 75 percent of the current staff was sup-  !

plied by contractors. Procedures were revised, updated, and  !

developed to support solid radwaste and shipping activities. The i licensee conducted a campaign to characterize, prepare for ship-  ;

ment, and dispose of accumulated solid radwaste (some of which  !

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had been on site since 1983). As a result, the licensee made an average of 22 radioactive materials shipments per month during the period of October 25, 1986, to February 12, 1988, effec-

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tively eliminating the onsite backlog. Implementation of the  ;

QA/QC program was adequate based on a review of audit !

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i Chemistry Control i

The licensee's capability to monitor chemical parameters in var-

{ ious plant systems with respect to Technical Specifications and other regulatory requirements was reviewed. The chemistry pro-  !

gram is administered by the senior chemist, who now reports to (

, the Superintendent-Plant Services, as a result of a reorganizatio i i Before the recent reorganization, the chemistry group was under j 1 the direction of Operations. Development of the database man- i

! agement system as part of QA/QC was excellent. The licensee i

has a good training program in the chemistry area. The results  !

j of the standard measurements comparison indicated an excellent ,

i level of agreemen l In summary, improvements were noted during this period in the 1 areas of staffing levels, internal assessments, and interdepart-i mental working relationships. However, the ongoing major outage j work and major reorganization affected progress. Resolution of ,

technical issues is sound but sometimes delayed. Improvement in  !

radioactive waste management was note The chemistry program (

continues to be texcellent. A weakness persists regarding ALARA [

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goal setting, and the effectiveness of recent changes in the i i training program for radiological controls will need to be '

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This area was rated Category l 1 -

i 3. Board Recommendation l

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C. Maintenance / Surveillance (2413 hours0.0279 days <br />0.67 hours <br />0.00399 weeks <br />9.181465e-4 months <br /> - 33 percent) Analysis The previous performance rating for maintenance was Category 2 with no significant weaknesses noted; the rating for surveil-lance also was Category 2. During that assessment period, equipment was maintained by an adequate staff and procedure Maintenance problems were well documented and licensee responses to NRC-identified weaknesses were adequate. Surveillance test-ing was successful in uncovering equipment problems during testing, and procedures, test conduct, and results review were goo Plant and line management oversight and control increased the assurance of timely test performanc During this period, overall maintenance and surveillance activi-ties were reviewed during routine NRC inspections. In addition, detailed inspections of maintenance and surveillance activities were conducted by two NRC teams. One team examined the Inservice Testing (IST) program and the other team conducted a performance-based pilot inspection of the. maintenance proces As part of the PECo nuclear reorganization, Maintenance and Instrumentation and Controls (I&C) Departments were combined into one section reporting to the Plant Manager. Staffing of the Maintenance /I&C Section with supervisory, engineering sup-port, craft, and technical personnel is adequate. However, numerous vacancies within the section were noted, mainly in the entry-level craf t and I&C position The nuclear reorganization, the upgrade of vendor technical manuals, and past procedural problems, have all been addressed by rewriting maintenance and I&C procedures. The I&C vendor technical manuals are now under the control of a central docu-mentation system, which is intended to correct the past problem of using out-of-date vendor manuals while performing maintenance on I&C equipment. Guidance available for the preparation of maintenance procedures is adequate. Control and distribution of procedures and drawings are well defined and implemente How-ever, a weakness was identified concerning the continuation of a 5 year review cycle for maintenance procedures. A 2 year cycle is currently the industry standard, a

The training, testing, and qualification program for maintenance and I&C personnel is currently INP0 accredited. The program appeared well documented and established. General, specific,

'

safety-related, and special training is provided to the work force. Formal continuing training is established for the I&C work force, but is not formalized for the maintenance craft work force. However the training for the I&C work force does not

include training for repairs on specific sophisticated radiation g protection equipment. Rigorous testing and qualification are

17

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e

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evident throughout the training process and are apparent during work activitie The Barbadoes Training Facility is a retired fossil plant that is being used for maintenance craft training. Numerous mock-ups are in placa and being used for generic conponent training pur-poses. However, specific training on the maintenance, overhaul, and rebuilding of the emergency diesel generators (EDG) was not evident. Only two craftsmen had the special 2-week hands-on EDG course conducted by Colt, Fairbanks, Morse. Therefore, while the E0Gs were being overhauled, two vendor representatives were required on site for guidance, and contractor personnel were needed on the work crew. More craft personnel are scheduled to attend the EDG course, and the licensee is investigating the purchase of an EDG for the Barbadoes Training Facilit Licensee corporate and plant management involvement in the main-tenance pro:ess was exemplified during an onsite monthly meeting, which includes discussing maintenance performance indicators and

.

trending efforts described in the Station Review Report. Plant

management has committed to ensuring that maintenance issues are

!

being addressed. A recent program was established to ensure

that industry-wide concerns reported by NRC, INPO, and other a

'

utilities have been properly addressed. Previously, some of these concerns, which were applicable to Peach Bottom, were not t

addressed. Management involvement to ensure quality also was l t evidenced by an innovative "predictive maintenance" program overseen by the Maintenance /I&C Section. The program utilizes computerized analysis to track and predict component failures in

,

safety-related and other systems. Included in the analyses are oil sampling, acoustic vibrations, and thermograph In the past, preventive maintenance (PM) and corrective mainte-nance (CM) were deferred without proper review. As a direct result, a large backlog of maintenance work items was generate !

During the assessment period, over 16,000 additional work items ,

i were written for both units. A major effort was undertaken by i the licensee to reduce the backlog to a manageable level. In l

"

,

addition, the licensee performed a review to identify and sched-ule all deferred work. By the end of the assessment period, the number of remaining open work items was approximately 2600 for Unit 2 and 7300 for Unit 3. To prevent recurrence of this large l backlog, the licensee initiated a program in which deferred work must be reviewed and approved by the Engineer-Maintenance for preventive maintenance and by the Superintendent of Operations for j

'

corrective maintenance. This program is form 411 zed by a procedure l for preventive maintenance and is controlled less formally by a i memorandum for corrective maintenance. The licensee plans to complete all preventive maintenance before restart. Post-maintenance testing of work performed is acceptable, but needs to be procedura11 ze _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _

_ . . .

< .

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The licensee has implemented improvements in overall plant house-c

"

keeping and material control. The numbs of contaminated areas has been reduced. Plant component labeling and painting also

"

have improved the overall plant appearance. However, the licensee noted a declining trend in plant housekeeping toward the end of the perio During the assessment period, maintenance and I&C workers were knowledgeable, performed work well, and showed a strong sense of pride regarding the quality of their wor First-line supervi-sors were routinely on the job site. Conflicts between craft and radiation protection personnel were reduced since the last l

.

assessment perio !

Numerous reportable events occurred during maintenance and surveillance activities, poor work practices inside control

!

cabinets resulted in several of these events. Reportable condi-tions included blocking and temporary clearance of blocking permits during maintenance as decribed in Section V.D. of this report.

]

] QA audits of significant reintenance activities were complete i and QA findings were given appropriate management attention. By i t

design of the maintenance request form system, quality control

!

(QC) is an integral part of maintenance activities. In the

, past, the quality trending reporting system identified problems !

within the maintenance and surveillance area, but did not assign j

responsibilities or closing dates for those identified problem The new trending reporting system has corrected this deficienc !

In addition, QA personnel escalate overdue assignments to plant :

management for action.

l Surveillance test (ST) performance, use of procedures, shift '

oversight and test control, and test results reviews were well done. Resolution of technical issues was evidenced by the licensee's discovery of plugged emergency service water (ESW)

-

piping to various emergency core cooling system components during a special surveillance test. As a result, ESW piping [

will be replaced before restart of Units 2 and Surveillance i records, including test results and documentation, were easily l recovered and readabl [

i A problem was noted with the method of tracking partially com- !

pleted ST The licensee's ST software program (STARS) cannot l completely differentiate between partially completed STs and :

fully completed STs. Manual tracking of partially completed STs t

,

was necessary to ensure completion. Although manual tracking j l'

appeared adequate, a violation was noted during the assessment j period in which a partially completed ST was never complete l

, The licensee has been responsive to this problem and has com- l

) mitted to upgrade its STARS program to correct the deficienc !

>

t i

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Several problems were noted with the licensee's inservice test-ing (IST) program. Interpretations of ASME Code Section XI requirements by the licensee were vague, incorrect, or inconsist-ent with the NRC staff positions. For example, test procedure acceptance criteria for high pressure service water pumps l allowed greater deviations in pressure and flow than allowed by the Cod In addition, improvements were needed to upgrade IST surveillance procedures when followup actions were necessary to resolve previously unacceptable component data. Clarity of acceptance criteria also needs to be improved in IST surveillance proceduras. Finally, the ability to recall test schedule ad-herence on a component basis needs improvement because ASME Code requirements for IST are integrated into a system-oriented sur-veillance program. The tracking system does not cross-reference by component, which could lead to a missed component tes QA audits on IST of pumps and valves were minimal and lacked technical depth. QA/QC involvem.et in general surveillance testing was gooa. QC personnel use detailed monitoring check-lists to ensure that STs are performed when scheduled. QC also performs independent verification reviews of instrument STs. QA audits are timely acd recommendations are communicated to management, i

l In summary, performance in the maintenance / surveillance area was effective. The reorganized Maintenance /I&C Section, along with rewritten maintenance. I&C, and surveillance procedures should further strengthen performance in this area. The training, testing, and qualification of personnel were good. Corporate and plant management involvement in the maintenance area was ample. Aggressive action in reducing and maintaining a low work item backlog will be necessary, QA/QC iversight of maintenance and surveillance was effective. Improvements are needed in the interpretation of IST ASME Code requirements IST surveillance i procedures, IST test schedule, and QA audits of IST activities, t i Performance Rating This area uas rated Category 2 and showed an improving tren s l ' Board Recommendation The licensee should adopt a program that will assure that the maintenance backlog is maintained at a manageable leve !

I D. Engineering / Technical Support (1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br /> - 15 percent)  ! Analysis

,

i The previous performance rating in this area was Category 2, and it was noted that licensee management was strongly oriented toward engineering and technical support. In addition, the licensee had integrated effective engineering support within ,

!

i 20  !

l

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each company disciplin Notable weaknesses that were not given attention were the oversight of the fire protection and site electrical load grow'h area The system engineer concept and its implementation continues to be a licensee strength. The system engineers were: involved in daily operational assessments of the plant systems they were responsible for. This includes system performance monitoring, system walkdowns, problem identification, maintenance followup, and post-maintenance testing. These system engineers demon-strated a good working interface with operations, maintenance, outage support, and corporate engineering personnel. Examples of this included identification of a configuration error in the control room radiation monitoring system, the planning and conduct of the Unit 2 hydrostatic test in February 1988, and the Unit 2 system maintenance outages and modification acceptance testing during 198 During this assessment period, refueling floor activities, such as vessel assembly and disassembly, core off-load and reload, and in-vessel inspections, were successful through the efforts of plant personnel as assisted by various engineering support groups. This assistance included support from the reactor engineering systems engineers, inservice inspection engineers, onsite maintenance engineers, and vendor (GE) engineering group Engineering support for the modification process resulted in the successful completion of a large number of plant modifications on both units. The corporate Nuclear Engineering Department performed adequate safety evaluations for these plant modifica-tions and the planning, procuremen+., and installation of rnodi-fications were effectiv Although the modification process was effective, weaknesses wen identified in the plant configuration control syste These weaknesses included the adequacy of the current design, modification implementation, and design versus as-built hard-ware. Weaknesses identified by both the NRC and the licensee included logic discrepancies in the diesel generator Cardox and core spray test loop, deficiencies in the control room panel seismic installation, and implementation of a modification that could have resulted in a loss-of-feedwater-heater event outside the design basis, t.icensee corrective actions were aggressive and included the development of a configuration control management program by a steering committee and imple-mentation through existing engineering and QA organization In the previous assessment period, Appendix R (Fire Protection)

deficiencies resulted in escalated enforcement. The licensee increased corporate and engineering management attention to the Appendix R issues and also committed additional resource These resources included forming an Appendix R task force and

. - - =

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the use of specialized consultant This increased effort and attention by management contributed to an improved Appendix R '

program that is maintainable and easily understood. The proce-dures that were developed are adequate, and the hardware is sufficient to perform the tasks involve Corporate technical and engineering ssyport of the Unit 3 pipe )

replacement outage was effective. The planning and implementa-tion of the pipe chemical decontamination resulted in a higher than expected decontamination factor and a lower overall dose for the pipe replacement outage. A well-staffed site engineer- I ing and project management organization for the pipe replacement project demonstrated effective planning and implementation that resulted in the successful completion of the pipe replacement.

The licensee used experienced contract personnel during the pipe '

'

replacement and ongoing work activities during this assessment period. The licensee's management demonstrated good control over the contractor activitie Licensee engineering and QA '

personnel involvement included required review of procedures, instructions, and radiographs and aa extensive QA audit and surveillance program. The licensee's identification of unac-ceptable radiographic indications and missing radiographs

'

during review of a subcontractor's work is a good example of the thoroughness of the licensee's efforts. The licensee estab-lished good management controls for the preservice inspection a

(PSI) of recirculation replacement piping. The licensee's PSI program exceeded applicable ASME Code and NRC requirements by j using a computerized ultrasonic testing system that records a ,

'

comprehensive baseline signal for reference in evahating future

pS1 result Management involvement in ensuring quality was evidenced by the significant commitments the licensee made in staff and resources j

'

to improve ESW piping systems for both units. However, during i

an NRC review of ongoing work in this area, a problem was noted with regard to construction division procedures, pipe spools

, for ESW were fabricated using sketches that were not part of the drawing control system and showed no evidence of approval prior to release. In response to this problem, the licensee indicated ;

I that it was of minor significance because subsequent QC inspec- l

l tions would identify deviations from the original desig '

Although this is an isolated incident it indicates a lack of a control of work process and insensitivity of corporate manage- ,

j ment to the significance of the issu In the environmental qualification (EQ) area, management involve-

. ment and responsiveness to NRC initiatives were adequate. Cer-tain minor specific deficiencies with EQ files were noted;

, however, the EQ file reviews disclosed that the equipment was ;

l qualified. The staffing and qualification in the EQ area also !

i was ample with the assignment of dedicated engineer '

) ,

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i

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l In summary, the lir nsee continu,rs to provide effective engineer- I ing and technical support for site activitie Strong support of the Unit 3 pipe replacement outage was evidenced. Other licensee-related strengths included: systems engineer concept, support of the modification process, support of refueling floor activities, and the Mark I containment progra . Performance Rating ,

This area was rated Category 1.

! Board Recommendation

Non ;

E. Emergency Preparedness (276 hours0.00319 days <br />0.0767 hours <br />4.563492e-4 weeks <br />1.05018e-4 months <br /> - 4 percent)  ;

)

i Analysis

!

t'

j The previous performance rating in this area was Category i The basis for this ra'.ing was satisfactory response capability i i in the 1986 annual exercise and satisfactory progress in most '

) areas identified in a previous confirmatory action lette L 1 During the current assessment period, the 1987 partial- >

! participation exercise was observed, four routine safety in- '

l

spections were conducted, four emergency response drills were r

'

observed, and changes to emere,ency plans and implementing i procedures were reviewe l A partial participation exercise was conducted on December 8, 1 1987, during which the licensee demonstrated a satisfactory l'

emergency response capability. The emergency response facility i

'

managers demonstrated effective direction and control; the tech- !

nical support center (TSC) staff provided effective coordination :

of activities and timely resolutions to most problems; and the !

, emergency operations facility (EOF) staff utilized field teams !

'

effectively. No significant deficiencies were identified al- !

j though several minor weaknesses were note : r

In each observed drill, the licensee demonstrated adequate emer- I gency response capability. The shift managers' use of emergency i procedures, event classification, and overall command and con- !

trol were effective. The most significant weakness identified l was slow staffing and activation of the TSC, partly caused by an ,

inefficient callout precedur i l t L

c y

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The NRC identified deficiencies in programmatic areas such as audits of the emergency preparedness program, ability to perform i corrective actions, and station and corporate emergency prepared-ness staffing and management. An NRC review of ' licensee audits in the emergency preparedness area between 1983 and 1985 indi-cated that audits were not broad enough in scope to meet the requirements of 10 CFR 50.54(t). Although two audits conducted in 1986, which met 10 CFR 50.54(t), identified program discrep-

-

ancies and recurring deficiencies, they were not properly dis-tributed to management. However, the 1986 audit did conclude that the emergency preparedness program was generally in a state l of readiness to respond adequately to an emergency. As a result i of these findings, the NRC issued a notice of violation to the ,

licensee for failure to comply with 10 CFR 50.54(t) audit  :

requirements. In 1987, the QA Department performed a compre-hensive audit of the emergency preparedness program and identi-fied many deficiencies, however they remained uncorrected at the I

time of the NRC inspection in February and March 198 >

During the April 1988 inspection, additional deficiencies were identified in the licensee's emergency detection and classifica-tion syste The emergency action levels (EALs) were not con-sistent with NUREG-0654 guidance because components and systems had not been identified, instrument readings were not given, and initiating conditions were not quantified. As a result, the EALs were often vague. The emergency preparedness training pro-i gram in place was adequate although some weaknesses were identi-fled regarding effectiveness of training of operators in the use of the EALs during walk-through examinations and EP exercise observation The causes for these programmatic weaknesses with audits, cor-

, rective actions, and EALS were inadequate staffing and a lack of  ;

management involvement. Responsibilities were poorly defined and

! accountability was not eviden It should be noted that al-l though outside of the assessment period, the licensee has i approved a policy that delineates the responsibilities for the emergency preparedness program as well as corporate and site ,

i interfaces. Additionally, a new emergency preparedness organi-ration has been approved. Onsite activities will be performed

!

by the Site Emergency Preparedness Coordinator (SEPC) who reports through the Support Manager to the Station Vice Prest- i dent. All other program elements will be performed by the '

i corporate staff. Program direction will be provided by the

corporate staff. A mechanism is in place to ensure accounta-bility of performance, as well as to ensure proper interface i between site and corporate staffs for the resolution of program j

! needs. The licensee has approved a change in the SEPC and is actively looking to install an individual with strong onsite  ;

l

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i

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, . _ _ _ _ _ - _ _ _ _ _ _, , , _ . _ _ . , , , , _ . , , -,m.-., , . ~ ~

_ . _ _ _ _ _ _ _ _ _ _ __ _ .______ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

't

e e

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experience as well as emergency preparedness experience as the new SEP '

late in the assessment period, significant changes occurred.in i the emergency preparedness program. The licensee completely  :

rewrote and restructured its emergency response procedures '

(ERPs). These ERPs are clearly written, adequately reflect the ,

concepts of emergency management, and clearly define responsi-bilitie Each ERP has a flow chart that ensures the procedures ,

j are properly followed and that also functions as a checklis ;

.

The licensee instituted a new emergency duty system to correct I weaknesses that it had identified in staffing and activatio [

The Itcensee integrated this system with its normal duty man-  :

agement system. The licensee also instituted a new system to i provide for a more timely callout of personnel. The licensee '

has revised the EALs and they are now consistent with guidance l of NUREG-0654 Systems and components have been identified, (

appropriate initiating conditions have been quantified, and the EALs are now generally clear and unambiguous. Other major changes  !

l include the incorporation of a new OSC to support plant emergency i operations. Many open items have been closed out and signifi-  !

I cant progress has been made toward closing those items that are [

i still ope t t

l

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In summary, the licensee has demonstrated a renewed commitment  !

to effective emergency preparedneu. Mar.agement involvement is f evident at all levels. Corporate policy has been established i

and organizational and program changes have been effected. The i j licensee has been responsive to NRC concerns and is continuing '

to make progress in these aiens. Management also has been effective in the latter portien of the period in identifying i

.

problems, determining the root cause, and taking appropriate  ;

!

actions. Altnough there are still program areas that need im-provement, particularly in corrective actions, the licensee has j

! identified the elements necessary to achieve effective result i

! Performance Rating f

y This area was rated Category j l

Board Recommer.dation

[

None, j Security and Safeguards (613 hours0.00709 days <br />0.17 hours <br />0.00101 weeks <br />2.332465e-4 months <br /> - 8 percent)

j Ana lysi s, l

The previous performance rating was Category That rating was f l largely bssed upon the licensee initiating actions to respond to l

NRC concerns about the security program that were expressed j

) dari.10 the previous two SALP periods. In fact, the licensee had 1 I

t

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made several significant changes, for exrnple, (a) a reorgant-zation, including the establishment of a Director of Nuclear Security with responsibility for the security programs at the licensee's nuclear plants; (b) assignment of a technical analyst to assist the Director; (c) establishment of eight positions for proprietary security assistants to monitor the security con-tractor's performance on a shift basis; and (d) t;ie assignment of two technical assistants to the licensee's senior onsite security representative for the Peach Bottom plant In addi-tion, capital resources were expended to improve security facilities, systems, and equipmen Five routine unannounced physical security inspections and one regulatory effectiveness review (RER) of the Peach Bottom secur-ity program were performed by the NRC during this assessment period. Routine resident inspections continued throughout the assessment perio During this assessment period, personnel performance-related aspects of the security program declined despite the apparent increase in corporate and plant management attention to the program and to changes that were instituted during the last assessment perioc. Early in the assessment period, numerous allegations from members of the contract security force were reported to the NRC regarding the program. The majority of these allegations related to insensitivity on the part of the licensee's security contractor to human factors and the resultant effect on the performance capability of the security force. It was alleged, for example, that members of the force were required to work long hours without a bre:k and without rotation of tedious assignments; were forced to work excessive overtime in order to retain their jobs; and were so frequently being recalled for work that it was affecting their personal lives. When the NRC reviewed these allegations, they were found to be generally vali Further, the NRC found that, in addition to the greater-than-normal security staffing requirements as a result of outage activities and maintenance, and upgrading of security systems and equipment that required posting of guards as compensatory meas-ures, the security force contractor also was under contract by the licensee to pr? vide staffing for firewatches necessitated by outage activities. The available staffing to meet both of these contractual obligations was minimal; therefore, the contractor resorted to the extensive use of overtime, which further exacerbated the problem by increasing terminations because of dissatisfaction with the forced overtime and poor working con-ditions. Additionally, the span of control for the contractor's security supervisors was increased as a result of the added workload associated with the firewatches, resulting in 'ittle time being available to ensure appropriate reliefs and rotaticns for those on dut Either the licensee did not recognize these problems or the problems were not escalated to a sufficiently high level cf

_______-_-_ _ _ _ -

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management to take appropriate action. In view of the changes inittsted in response to NRC expressions of concern during these previous SALP periods, as noted above, neither of these two pos-sibilities should have developed if the licensee was properly exercising its responsibility to oversee the program. The r proprietary security shift assistant posi'. ions that were estab-lisheo and filled were intended to providt- the nece.sary over-sight of the contractor on a shift basis, while the other ;

positions were intended to provide the licensee with an overview ;

of program effectiveness. Since apparently neither expectation was realized, the licensee's selection, training, and supervi- '

sion of these individuals and its understanding of its ritponsi-bility for continuous program oversight to ensure effectiveness were weak.

I

'

Even though the NRC's review of aforementioned allegations did i not identify any specific violations of NRC requirements, the poor morale and attitude existing among the security force create the potential for regulatory issues to develop, stemming from performance-related pro'lem o That concern was communi-cated to the licensee early in this assessment period and on

several occasions thereafter. In February 1988, allegations of poor personnel performance and program weaknesses were reported directly to tha licensee by a member of the security force. At that point, the licensee commissioned an investigation by its corporate Claims / Security Division to review the alleg.tion That investigation substantiated many of those allegations and provided the licensee with concrets evidence of the extent of the problems. A subsequent audit by the licensee's Nuclear Quality Assurance Division provided additional credibility to

the findings of the investigation. On the basis of those ;

I findings and further expressions of concern from the NRC during !

several management meetings, the licensee began to take decisive !

actions to correct the problem Corrective actions were initiated on the specific probitms !

identified in the licensee's investigations and audit. An

, extensive and comprehensive monitoring program was instituted to (

determine the performance capability of the entire security ,

.

'

force and to assess those areas where new or additional training '

was required. Actions were initiated to reduce human factors i

. problems. Organizational and personnel changes were made in an i

attempt to correct the previously fragmented and weak onsite !

<

management of the security program. The current security force contractor for the licensee's Limerick Generating Station was i l awarded the contract for the Peach Bottom plants. Contract l

,

langua;e was strengthened, performance incentives were included, '

and a comprehensive plan was developed by the licensee to ensure d

a smooth transition and an increased program effectiveness. In '

addition, the licensee commissioned its Independent Safety Engi- !

neering Group, with the assistance of independent consultants, i

!' to co9 duct a root cause analysis of the security program prob- ;

lem That analysis concluded that there exists: (1) unclear ;

i l

i n i

,

,

. . ,

!

. L scope and responsibilities for the program, (2) philosophical differences on what constitutes an appropriate performance level, and (3) a "hands-off" attitude toward the contractor and i

'

ineffective management of the security contract. The licensee ,

has developed and is implementing an action plan to address those finding ;

,

An NRC regulatory effectiveness review (RER) was conducted during !

this assessment period; relatively few problems were found at -

the Peach Bottom plants. An RER focuses mainly on security con- ,

j cepts, systems, and equipment. The licensee expended consider- l 4 able capital and human resources in preparation for the RER to i

.

repair, update, and improve its security systems and )quipment ;

I for the security program. On the basis of the results of the ,

i RER, it is, therefore, apparent that the licensee possesses, or l

? can obtain., the necessary technical security expertise to per- f form well when sufficient management interest and attention are ,

! focused on the task and management's involvement and commitment !

are highly visible to all employees, as was the case in prepar-

ing for the RE !

1 f

!~ In addition to the activities associated with the preparations i for the RER, the fitness-for-duty program being implemented by [

the licensee is another area in which management's involvement and conmitment are highly visible. Recent licensee initiatives I- in the area included assigning a full-time clai's/ security inves- 1

! tigator to the site; purchasing dogs trained to detect drugs for [

]' use in unannounced searches at the plants; maintaining an  !

excellent working relationship with local, State, and Federal '

law enforcement agencies; initiating a revised corporate drug policy to include random drug testing; and immediately reporting ( and following up on potential illegal substance abuse problem ,

i t j A total of 14 security event reports were promptly submitted to l 3 the NRC during this assessment perio These reports were clear i 1 and generally thorough. However, corrective actions wera not [

l always effective as evidenced by repetitive similar events t 5 involving performance-rtlated problems on the part of security i l force members,

i i

In summary, the licensee's performance declined during this l j assessment period despite the changes made during the la,t i

period to improve the program. The decrease is mainly attrib-  !

uted to a lack of effective oversight of the contractor and a i lack of aggressive senior management involvement and direction ;

i of the program. The result of the ineffective contractor over- I l sight left the liceasee with a high potential for performance- (

related problems in the security force. Mid,vay thrt,. ugh the !

period, the licensee began to recognize the problems, which are '

largely people- and performance-oriented, and initiated actions I l to correct them. An RER conducted during the period indicated *

! that the licensee has available the necessary security expertise ,

j to implement a security progran that is acceptable to the NRC.

4 i l

) 28 l

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l  !

- - - - _ - . - - - _ _ _ _ - . - - _ _ - - - - -.-.-- - - __ -- -- -

. _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _

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A concerted effort must be applied to correct the people- and performance-oriented problems. The licensee also continued its aggressive implementation of an excellent fitness-for-duty pro-gram during this period and is commended for its initiatives in that regard. Senior management's involvement in and commitment to that program are highly visibl Similar involvement in and commitment to the security program are necessary before and after the plants are restarted.

j i performanes Rating l

'

This area was rated Category .

l Board Recommendation

] The NRC should conduct a special team inspection to evaluate the licensee's self-assessment capability and its implementation of .

,

corrective actio '

G. Safety Assessmeat/ Quality Verification f

!

3 Analysis '

'

i I Assurance of quality has been considered a separate functional

! area in past SALPs in addition to being one of the evaluation .

., criteria in functional areas. This area has been expanded to l encompass activities including safety evaluations, previously

'

i evaluated in the functional area of Licensing. This discussion  :

is a synopsis of quality and safety evaluation philosophies I reflected in other functional areas. In assessing this area,

! the SALP Board has considered attributes that are key contrib-  !

! utors in ensuring safety and verifying quality. Implementation l

of management goals, planning of routine activities, worker i

) enthusiasm, management involvement, and training are example '

i'

!

'

Durir.g the previous assessment period, licensee performance in the Assurance of Quality area was rated as unacceptable as re-j flected in the issuance of the shutdown order. The problems t

'

noted, which were operator complacency and inadequate procedural l compliance, had continued and, in part, led to the shutdown '

order; however, the central reason for unacceptable performance l in this area was that plant management was unable or unwilling l to correct known deficiencies in operator conduct that had potentially significant safety consequence ,

!

Corporate management in its initial response to the shutdown 3

j order failed to recognize or accept responsibility for the de-  !

grading conditions at Peach Bottom. As a result, corrective i actions as addressed in the "Connitment to Excellence" action  !

plan were inadequate with regard to corporate oversight of and l

!

accountability for site activitie The licensee was respo'sive  :

i to this NRC concer Subsequent change- torporate structure i

1 29  !

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. _ _ _. . -

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and personnel and proposed changes in corporate attitude have been effective in addressing this root caus The licensee restructured the entire operations management  !

organization in response to the shutdown order. As discussed in Section IV. A, improvements were noted both in shif t oversight by the new shift manager and in operations and plant management l oversight by new personnel. Shift managers have been effective ;

'

in providing leadership to the shift personnel. The new opera- '

tions management has been involved in providing effective over-sight of daily operating activities; this oversight has included involvement in routine meetings, event followup, and interface 1 activities as noted in Section I !

l

The Itcensee has revised the Nuclear Review Board (NRB) charter ,

and procedures, including changes in NRB membership. Three +

s senior consultants have been added to the NRB. NRC inspector ,

attendance at several NRB meetings in the latter part of this

!

period seemed to indicate that these changes are positive. NRB

members are more probing in their analysis of problems. For example, the NRB has reviewed in detail the root causes of ,

personnel errors and contamination of personnel skin and clothin :

Each new shift manager has had an opportunity to address the NRB

without his operations management present.

! When a technical problem was identified, the licensee was aggres- !

, sive and thorough in evaluating potential similar effects on r other plant systems or components. Two examples are: (1) When  ;

) the licensee discovered that piping for the control room venti-t lation radiation monitor sensing line was installed incorrectly, '

!

'

the Nuclear Engineering Department initiated a program to ensure that all parameters that actuate safety signals are properly  ;

j sensed and (2) when the Itcensee noted that a steam plant modifi- l 1 cation reduced the margin of a transient analyzed in the FSAR [

(i.e., inadequate safety evaluation), the Independent Safety

]l Engineering Group (ISEG) reviewed the safety evaluations for  !

, non-safety-related modifications. On the other hand, licensee

, review to establish the root causes of multiple shutdown cooling -

'

isolations was initially weak and many LERS were late as noted

in Section I The Plant Operations Review Committee (PORC) has provided effec- !

i tive oversight of plant operations. A change in PORC membership, !

including a designated PORC Chairman, occurred during this t

assessment perio Examples of good PORC review and involvement l l include the review of plant conditions necessary to change oper- ,

ating modes for the Unit 2 hydrostatic test and the development ;

of formal technical specification interpretations through the l approval of PORC position l

, The involvement of licensee corporate and plan' management in '

J overall station performance is exemplified by a monthly meeting [

to discuss performance indicators and trending efforts as  !

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_ -_ _ _ _ __ . _ - _ _ _ _ _ _ _ - - _ . _ _

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.

described in the monthly station review repor Plant management has committed to ensure that NRC Jpen items and other related issues are being addressed. A recent program was established to ensure that industry-wide concerns reported by NRC and INPO and other concerns are identified and resolve Early in the period, senior management support and improvement of the quality verification effort were evidenced by the increased presence of QA and QC personnel at the site, emphasis on the observation of ongoing activities in both auditing and monitor-ing by the QA and QC organizations, reduction in the backlog of open corrective-action items, and the QC monitoring effort that was consistent with expected completion dates. Additional involvement and support by management were apparent in that licensee efforts related to the restart action plan were pro-gressing in an orderly fashion consistent with established prioritie Review of the licensee's procurement program identified a prob-lem regarding the suitability of rom,nercial grade items for safety-related applications. In response to this, the Nuclear QA Department conducted a comprehensive study to determine the type and extent of problems in the procurement process. A cor-rective action program that detailed specit.c actions to upgrade the procurement process was developed and previded to senior management. A major recommendation in this area, integration of the procurement process into the plant organization, resulted in the establishment of a site engineering group that reviews all new purchase orders. A procurement study and associated rec-ommendations indicate management involvement in and commitment to the improvement of the procurement process. The study and associated report reflect a positive trend in the performance of the QA Departmen The stop-work actions by personnel in the QC section and their continued involvement in corrective actions, including the inspection and testing of suspect items, demon-strate their decisiveness and technical competenc Involvement and oversight of nuclear engineering management and QA personnel during the Unit 3 pipe replacement outage were effective as evidenced by their comprehensive program, which consists of auditing, surveillance, and documentation review activities. This resulted in the successful completion of a complex project. However, a weakness was noted regarding the in-volvement of QA and QC personnel in the Unit 2 hydrostatic test in February 1988. Although the QA and QC personnel performed their required programmatic reviews, there was no review of open items that could potentially affect the operability of systems required for the hydrostatic tes The licensee's response in regard to this deficiency was positive once it was pointed out by the NRC inspector The licensee's response to regulatory initiatives including -

eric letters, unresolved safety issues, information notices,

__ _ _ _ _ . _ . __ __ _ _ _

t

• ,

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F

• ,

l i bulletins, and NRC unresolved and open items was technically l a adequate. However, early in the assessment period, corporate

'

and site management did not appear to be effective in ensuring that previously identified NRC issues are dealt with in a timely

, manner, later in the period, the licensee initiated sigaifi-

) cant actions to reduce the number of NRC open item The des-ignation of an individual responsible for coordinating open items and the assignment of accountability for each open item

, have resulted in a reduction of NRC open item In the latter part of the assessment perioo, the previously 4 separate QA and QC organizations were consolidated to form one j 2 QA organization. The transition to the consolidated QA Depart-ment was well planned so as to facilitate interdepartmental 1 cooperation and communicatio Reassignments were based on '

specific abilities and experience. Staffing allocations were i i decided on the basis of past experience, and additional person-

) nel were requested if deemed necessary. The inspectors observed I that the new QA Department, as evidenced by its current involve- ,

l ment and performance, is an improvement over the previous  !

]' organization !

i Oversight of the security force and security program was weak during the period. Numerous safeguards event reports attribut-

] able to inattentive guards, allegations of low guard morale, and k excessive overtime as well ac NRC and licensee assessments of

-

'

security were indicative of poor performance. The division of !

j responsibilities among corporate, site, and contractor security [

J management was not defined, licensee root cause analysis and !

j corrective action plans were performed at the end of the  !

1 assessment period. Toward the end of the period, the licensee

'

announced a new security contractor and replacement of site l

security manageme t

Early in the period, weaknesses were noted in oversight and QA ,

involvement in emergency preperednes Programmatic weaknesses s i in emergency plan audits, corrective actions, and emergency

.

action levels were caused, in part, by poor corporate oversight ,

) and site implementation. Late in the period, the licensee )

initiated significant actions to remedy these weaknesses in '

-

response to NRC concern ~

l During the period, licensing activities wre subordinated to I those activities associated with the shutdown order and the PECo I

reorganization. Traditional licensing activities were generally '

limited to license amendment applications already in progress

,

and followup of generic issues. The licensee has been respon-sive in regard to both the technical acequacy and the timeliness of its responses to these issues, anci & number of the issues

have been resolved because of this level of response. The ,

licensee's Itcensing staff appears to be benefiting from a j slightly improving trend in the level of resources and M N experiencing relatively little turnover. The licensee's 32 i L

i

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,

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,

technical staff appear ..r se both in resource levels and

'

experience. The licer me, .adf 3 very involved in site ac-tivities. Near the enc m en ,ariod as the licensee's new man-agement assumed its resh a,nniities, the traditional licensing functions regained much of their vigor. Thess functions appear to be carried out effectively 'n a fashion complementary to the licensee's efforts to manage restart activitie '.

,

i I l

The licensee has been aggressive in the area of fitness for dut The use, as a deterrent, of dogs trained to detect drugs during l l unannounced searches, the assignment of a full-time onsite  !

I security investigator, recent corporate management policy changes I including periodic testing, training of supervisors regarding

'

l l drug abuse and its detection, and timely communications with the t NRC are all indicative of the corporate polic ,

In summary, improvements have been noted in the area of safety i assessment, especially later in the period. These included changes in the corporate organization, improvement in oversight i] by shift and plant management, and changes in the NRB charter,

procedures, and membershi However, the licensee's self- ,

assessment capability was not sufficiently developed or focused 1 a to identify and correct weaknesses in the security and emergency  :

"

preparedness area l i

l Performance Rating  !

i

This area was rated Category j Board Recommendation f

.

The licensee should develop its self-assessment capability so that it can prevent the types of problems identified in the l emergency preparedness and security areas, i

i I

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. _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . __ _ _ _ _ _ _ _ _ _ _ _ _ - _ __ __ _ _ __ _ _ _ _ _ _ _ _ _ . _ _

,

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V. SUPPORTING DATA AND SUMMARIES Investigations and Allegations

'

The NRC Office of Investigations completed a special investigation of an allegation that licensed operators were asleep or otherwise inattentive to their duties while on shif Enforcement action was taken after the end of the period, as noted belo Twenty-three allegations were received during the assessment period in the following areas:

• radiation protection - 7

• security - 6

• fitness for duty - 5

• QA/QC concerns - 2

• industrial safety - 2

• operations - 1 One allegation in the area of radiation protection was judged a violation, but the other six were unsubstantiated. The majority of the security allegations pertained to concerns about personnel prac-tices such as excessive overtime, long hours at a guard post, harass-ment, and low morale as a res alt of unf avorable working condition These allegations resulted in an attempt by the licensee to rectify these unfavorable working conditions and the replacement of a con-tracto The fitness-for-duty (drug-use) allegations were unsubstan-tiate The two QA/QC concerns were unsubstantiated. Th6 industrial safety and the operations allegations are not resolved.

. Escalated Enforcement Actions A level III violation and $50,000 civil penalty were issued on July 29,1987 because of Appendix R fire protection violation A level II violation and $1,250,000.00 civil penalty (Enforcement Action 88-04) were issued on August 10, 1988 beenuse of the inatten-tiveness of control room operators and management's failure to detect and/or correct the problem. A total of 14 level !! and 22 level Ill violations were issued to 36 licensed control room operators on August 9, 198 Civil penalties were imposed on 33 of these 36 operator Although these enforcement actions were issued after the assessment period (July 31, 1988), they are included here for completenes Manatement Enforcement, and Other Conferences l

On June 17, 1987, a management reeting was held to discuss the l status of the actions in response to the NRC order, j

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i On June 23, 1987, NRC representatives attended the Harford County l (MD) Council meeting to discuss the status of the NRC orde '

On July 13, 1987, a management meeting was beld to discuss the licensing of General Electric engineer ,

t On July 15, 1987, a management meeting was held to discuss licensee i response to the NRC order, including tts recovery plan (Commitment to Excellence). j

'

On July 30, 1987, a management meeting was held to discuss licensing issues regarding containment and fire protectio On August 3, 19C', an enforcement conference was held to discuss the control room ventilation radiation monitoring system piping '

discrepanc '

l On August 26, 1987, a management meeting was held to discuss the status of the CTE Action Plan, i On September 9, 1987, a management maeting was held to discuss Unit !

3 pipe replacement activitie L l On September 14, 1987, an NRC C:mmission briefing on Peach Bottom f was hel :

L On September 24, 1987, public meetings were held in Harford County, i MD and York County, PA. to receive questions on the restart pla !

i On Octobsr'1, 1987, a SALP management meeting was held on sit l

!

On October 7, 1987, a manaaement meeting was held to discuss f radiological controls for the Unit 3 pipe replacement outag :

r On October 16, 1987, a meeting was held to discuss technical issues [

with the Harfor:1 County (MD) Counci !

On November 4,1987, a public weeting was helc' in Lancaster County, t PA, to receive ques * tons on the restart pla ;

On Novenber 20, 1987, a management meeting was held to discuss the status of the restart pla (

On December 3, 1987, the ACRS was briefed on Peach Bottom statu l On December 22, 1987, a mancgement meeting was held to discuss the j status of the restart pla On January 27, 1988, a management reeting was held to discuss the l status of the restart pla .

l l

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f .

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e On February 17, 1988, a management meeting was held to discuss the l 1 licensee's proposed QA organizational and programmatic changes

. associated with corporate and site reorganizatio ;

i-

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On February 2o, 1988, a management meeting was held to discuss hsalth physics and security concern ;

From January through May 1988, individual licensed operator enforcen.ent  !

j conferences ware hel !

'- i On March 31, 1988, a management meeting was held to discuss the  !

j status of the restart pla l J

'

On May 16 and 17, 1988, public meetings were held in Harford County, MD, and York and Lancaster Countics, PA, to receive questions on the

. revised restart pla ,

:

On May 19,1988, a management meeting was held to discuss questions  ;

on the restart pla l Cn Juce 9 and July 20, 1988, management meetings were nd d to dis-  :

cuss securt+y plan implementr.tton issuo l t Licensee Esent Reports  !

t Repon __Qua l i ty

,

[

!

1 By using the basic evaluation methodology presented in NUREG- l

1022, Supplement 2, the NRC found that the o n tall quality  !

of peach Bottom 11cc62ee event reports (i.ERs) is very goo '

Overall, LERs were thorough, detailed, and generally well  :

. I 1 written and easy to understand. The narrative sections typic- <

'

ally included specific details of the 4svent such a!, valve iden-  ;

t;fication numbers, model numbers, number of operable recundant  ;

i systems, and the date of completion of repaira to provide a good <

.

understanding of the event. The root causit of the event was  :

} clearly identified in most ca'ea, although e large number of  :

events initially had an "unknown" root uus LEls generally [

J presented the information on the event in an organized manner  !

'

! with separate headings and specific triormation in each section  ;

' hat led to a c ear understinding of the information,

. previous i sin,ilar occurrences were 3rcperly referenced in the LERs as '

i applicable. The licensee updated LERs in the assessment period  !

for various reasoits, including the completion of corrective l

, actions in the LERs and to extend commitment dates that were not l

,

w i i l 1 The 4 O s generally described all the major aspects of the event,  !

'

'

ineWJing component or system fatteres that contributed to the i event and the $1gnificant corrective actions taken or planned to  :

prevent recurrence. However, there wer9 some examples of poor  !

desetiption of events (especially those of complex events) such l

l

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,

,

---

,~-3- , -w , . - . - , - y ,- ,~,,17,,.-~,-+--.--,A, --e , , , , , - - - - , , - - - , - , -_.,m .._--.-,y----- -,-v-,-,_~--m---~ w---

.___- __________

,

. .

O as those in Unit 2 LER 88-05, which does not state which control room panels were affected and which systems were subject to fail-ure. Similarly, Unit 2 LER 87-32 does not state which plant sy tems could have been affected. In addition, lack of infor-mation resulted in poor event assessment sections in these LERs because they did not clearly state what rcdundant or mitigating systems were available and what the event progressions would

'iave been. This lack of an adequate description of the event and of the assessment of safety significance resulted in difft-culties in assessing and classifying event . Causal Analysis Number Percent ' Personnel Error 25 43 Design /Manuf./Constr./ Install, 8 14 External Cause 2 3 Procedure Inadequacy 9 15 Componen Failure 13 22 Ott.er ( t r.cluding unkrown) 2 3 TOTAL 59 100 l

A tabuistion of LERs by functiunal area is attached as Table LERs 02-87-07 through 02-98-20 for Unit : and 03-67-06 thrcugh 03-8G-07 f or Ur.)t 3 were received and "eviewed by the NRC during the assessment perio The 59 LERs that were submitted darfug the assessmant period

! were also subject to an ongoing review as part of N9C inspec-tions far trends and identification of root causes. The foi-lowing sets of common mcde events were identified:

• Twenty-f1',e LCRs were attributed to persannel error. These LCRs accountec for approxiaately 43 percert of the events repor'ed, an facrease over that repqrted during the pre- i

';ious assessment perio A review of the LERs indicates that son,e areas of tha plant are sub,iect to recurring problems. In particular, many repetitive events involved personnel errors associated with equipment blocking and tagouts, e;pecially of electrical equipment and contro) logie. The largs numben of similar events indicates thit actions taken to prevent recurrence were inaffectiv '

r

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37  ;

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o >. % .. -

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.

• Eight LERs were attributea to design, manufacturing, con-  !

struction, or installation problems. Areas of potential ,

safety concern are seismic qualification and design and installation of equipment. The fact that deficiencies hav E existed since initial construction that could have affe:ted large numbers and diverse types of equipment is signifi-  !

cant. A large number of these events were identified by  ;

<

the licensee, but others were identified as a result of NRC l inspector concern '

• Nine LERs were a result of procedural deficiencies. This  :

represents an increase over those during the previous t period, and can be partially attributed to the increased r sensitivity in regard to procedural compliance and actions .l taken to note and revise deficient procedure '

• Component failures. accounted for 13 LERs d.<ing the perio '

'

.

This represents a negligible decrease in component failures ,

over those experienced during the previous period. A  !

.

detailed review did not indicate any maintenance program, I procedure, ' performance problems that may have contrib-uted to the failure '

i

• Fourteen LERs involved the failure of fuses and other- [

electrical equipmen ;

I

• Twenty LERs were lat This indicates that the mechanisms l

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for identifying and tracking potentially reportable occur- i rences are inadequat j

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Table 1 Distribution of Inspection Hours Peach Bottom Atomic Power Station June 1,1987-July 31,1988 Hours Percent of Functional Area 14 Months Annualized Time Plant Operations 2355 2019 32 Radiological Controls 591 507 8 Maintenance / Surveillance 2413 2068 33 Emergency Preparedness 276 237 4 Secu ity and Safeguards C13 525 8 Engineering / Technical Support 1145 981 15 Safety Assessmer.t/ Quality -- -- --

Verification * ___

Totals 7393 6337 100

• Hours expended in the area of safety assessment / quality verification include other functional area Inspection hours include NRC Inspection Reports 87-16/16 through 88-27/27, but do not include those that will be documented in Inspection Report 88-24/2 >

.

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Table 2 Enforcement Summary *

Peach Bottom Atomic Power Station June 1,1987 - July 31,1988 Severity Level Functional Area III IV V Subtotal

..

Plant Operations 1 2 0 3 Radiological Controls 0 3 0 3 Maintenance / Surveillance 0 7 0 7 i Emergency Preparedness 0 1 0 1 Security and Safeguards ** 0 3 0 3 Engineering / Technical Support 0 0 1 1 Safety Assetsment/ Quality 0 3 1 4 Verification Totals 1 19 2 22

• Escalated enforcement against the licensee and licensed operators cccurred on August 9 and 10, 1988 (Section V.8). This was outside the assessment period and is not tabulate ** Potential violations from NRC combined inspecticn report 88-26/26 were under review and are not tabulate i

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Table 3 Licensee Event Reports Peach Bottom Atomic Power Station June 1, 1987-July 31, 1988 Number by Cause*

Functional Area A B C D E X Subtotal Plant Operations 9 2 2 5 9 1 28 Radiological Controls 1 0 0 0 0 0 1 Maintenance / Surveillance 14 1 0 4 4 1 24 Emergency Preparedness 0 0 0 0 0 0 0 Security and Safeguards ** -- -- -- -- -- -- --

Engineering / Technical Support 1 5 0 0 0 0 6 Safety Assessment / Quality 0 0 0 0 0 0 0 Verification Totals 25 8 2 9 13 2 59

• Cause codes: Personnel erroe Design, manufacturing or installation Unknown or external cause Procedure inadequacy Component failure Other

• • Security event reports we not tabulated and are discussed seoarately in Section II LER tabulations include LERs 02-87-07 through 02-88-23 for Unit 2 and 03-87-06 through 03-88-07 for Unit l l

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Table 4 History of SALP Reviews at Peach Bottom Atomic Power Station Categories and Review Periods 2/86- 4/85- 1/84- 3/83- 3/82- 7/81- 7/80- 5/79-Functional Area 5/87 1/86 3/85 12/83 2/83- 6/82 6/81 6/80 Plant Operations Unsat 2 2 2 2 2 2 Sat Radiological 2 2 3 2 3 3 2 Sat Controls Maintenance 2 2 1 2 2 2 2 Sat Surveillance 2 2 2 2 3 2 1 Sat Fire Protection / 3 2 2 2 3 3 3 Sat Housekeeping Emergency 2 2 2 2 1 2 2 Sat Preparedness Security and 2 3 3 1 1 2 2 Sat Safeguards Refueling /0utage N/A 1 1 2 2 2 1 Sat Activities Training and Not 2 N/A N/A N/A N/A 2 Sat Qualification Rated Effectiveness Assurance of Unsat 3 N/A N/A N/A N/A 2 Sat Quality Licrosing 2 2 1 1 2 1 N/A N/A Activities Technical 2 N/A N/A N/A N/A N/A N/A N/A Support NOTE: Unsat = unsatisfatory Sat = satisfactory N/A = not applicable