IR 05000277/1988028
| ML20205J821 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/18/1988 |
| From: | Dev M, Drysdale P, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20205J806 | List: |
| References | |
| 50-277-88-28, 50-278-88-28, NUDOCS 8810310494 | |
| Download: ML20205J821 (21) | |
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'U.S. NUCLEAR REGULATORY C0pt4ISSION
REGION I
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Report.Nos. 50-277/88-28 l
50-278/88-28 Docket Nos. 50-277
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License Nos. DRP-44 f
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Licensee: Philadelphia Electric Company l
2301 Market Street Philadelphia, Pennsylvania 19101 j
Factitty Name:
Peach Bottom Atomic Power Station, Units 2 and 3
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Inspection At: Delta, Pennsylvania (
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Inspection Conducted: August 29 - September 2. 1988 l
Inspectors:
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/0//3/fF p M. Dev, l reactor Engineer, date
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Di is n of Reactory Safety (DRS)
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P. Drysd)Te, Reactor Engineer, DRS date
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A.Finkel,SeniorR4ctorpngineer,DRS date l
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b W. Oliveifa, Reacto. Engineer, DRS date l
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Reviewed by
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Norman J. Blumberg, Chief date
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Operational Prog Sec on, OB, DRS I
Approved by:
/ 0//g/gg Robert M. Gallo', Chief date '
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Operation Branch, DRS Inspection summary:
Routine unannounced inspection on August 29-September 2.
l Tis 8 (Report Nos. 50-F/7/88-28 and 50-278/88-28)
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Areas Inspected:
Review of the licensee's operating procedures, non-licensed
operators training, and on site and off site review committees. Also reviewed
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were selected corrective action items of the licensee's Plan for Restart of
Peach Bottom Atomic Power Stations Units 2 and 3, Sections I and II.
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8310310494 891021 (
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Results: The licensee management reorganization and administrative controls at Peach Bottom Atomic Power Station (PBAPS) appeared effective.
The station's non-Itcensed operators training program has been revised and is being updated.
Operating procedures are being revised, updated or rewritten as necessary to comply with the plant restart corrective action commitments.
Creation of the Nuclear Committee of the Board of Directors (NCB) is considered a positive i
trend in the improvement of the licensee's independent self-assessment program.
The inspectors observed weaknesses in the areas of procedures control, documentation and communication. Administrative Procedure A-20 did not clearly
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delineate responsibility and authority for the control of Alarm Response Cards
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(paragraph 3.2.1).
The non-licensed operators training curriculum had not incorporated instruction and examination material related to radwaste control
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room operation in accordance with training procedure NTS-I-301. As such, two
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of the training modules reviewed were four years old and had not bee.1 updated (paragraph 4.3).
The station response to selected NRB concerns lacked adequate documentation to support the completion of plant management review and timely resolution (paragraph 5.2.3).
A concern regarding procedural adherence was identified when an auxiliary operator did not inform the chief operator of the
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deviation in the Routine Test (paragraph 3.2.2.C).
Previously, in the PBAPS
shutdown order, the NRC cited similar concerns related to failure of the operations personnel to adhere to procedural requirements, and poor communication among different plant entities.
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OETAILS 1.0 Persons Contacted Philadelphia Electric Company (PEco)
Peach Bottom Atomic Power Station (PBAPS)
A. Andrews, Supervisor of Operations Training
- B. Clark, Superintendent - Administration
- J. Cotton, Superir.cendent - Operations
- T. Cribbe, Regulatory Engineer H. Diamond, Restart Manager
- J. Franz, Plant Manager
- H Ghodrat, Procedure Control Group Supervisor
- G. Hansen, Regulatory Engineer
- R. Kankus, Staff Engineer
- T. Mitchell, Operations Support Engineer
- F. Polaski, Atsistant Superintendent - Operations
- D. Smith, Vice President, PBAPS E. Till, Superintendent, Training Division U. S. Nuclear Regulatory Commission (USNRC)
- T. Johnson, Senior Resident Inspector
- J.
Linville, Jr., Chief, Projects Section No. 2A, DRP
- Denotes those attending the preliminary exit meeting on September 1,1988
- Denotes those attending the exit meeting on September 2, 1988
The inspectors also contacted other administrative and technical personnel during the inspection.
2.0 Ge n e ra',
2.1 Background Pursuant to the Nuclear Regulatory Commission (NRC) order of March 31, 1987, to shutdown the operation at the Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3, the Philadelphia Electric Company (PEco), licensee, submitted a comprehensive plan and schedule to the NRC assuring safe operation of the facilities in full compliance of the regulations.
Subsequently, the licensee identified four root causes relating to declining performance at PBAPS as discussed in the licensee's plan for restart.
In order to address the NRC order, the licensee planned and implemented corrective actions. The shutdown issues, the root cause analyses, and the associated corrective actions have been discussed in the licensee's Plan for Restart of Peach Bottom Atomic Power Station listed in Attachment 1.
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-4-2.2 Inspection Objective The objective of this inspection was to evaluate certain licensee activities and programs related to the preparation for restart of PBAPS, Units 2 and 3.
Specific inspection activities were carried out in the following functional areas and are discussed in detail in this report.
- Non-Licensed Operators (NLO) Training
- Plant Ope,. hg Procedures
- 0ff-Site Review Committee Activities The inspectors also reviewed the implementation of selected corrective action commitments, delineated in the licensee's restart plan, that are associated with the above functional areas.
The results of these reviews, and reviews of other action items, are detailed in paragraph 7.0 of this report.
2.3 Suwnary of Conclusions and Findings The licensee ha; reorganized the PBAPS administratiori and has redefined responsibilities and authorities of key individuals and organizations. A Vice President has been assigned primary responsibility for all activities at PBAPS.
ine Quality Assurance (QA) organization at the site has also been restructured.
There is now a QA manager at the site who is responsible for QA staff activities, which include audits, surveillances and monitoring of operations and inspections.
Present staffin? M non-licensed operators is adequate ar,d has been accompli ' a tith the available pre-shutoown personnel.
The company has prt, 'sd retraining and indoctrination to every employee, emphasizing quality in work performance.
The employees have been made aware o' the company's policies on the individual accountability and r2sponsibility. An overall positive trend in employee attitudes was observed during this inspection.
The inspectors also observed some other changes: (1) As part of the station reorganization a training superintendent has been hired to improve training activities at PBAPS; (2) Construction of a new training facility has been planned and budgeted; (3) The creation of a new floor fo tiw sosition has improved operational activities; and (4) The Board or 'J rdctors of the Philadelphia Electric Company created a Nucle 4-Committee of the Paard of Directors (NCB).
In conjunction with the Nuclear Review Board and the Nuclear Quality Assurance Organization, the NCB has been functioning to improve the company's self assessment and evaluation program relating to significant nuclear operational issue.-
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The licensee is pursuing an effo-t to revise, rewrite and update the plant's administrative and operating precedures, as necessary, and is implementing corrective action commitments related to the plant's shutdown issues.
The management response to the inspector's concerns id0ntified during this inspection was prudent and prompt.
For example, when an inspector informed the plant management that a test had not been performed as specified by procedure, the plant manager immediately issued a written instruction and discussed the problem with operations personnel. He emphasized procedure compliance and control of the test activities to preclude recurrence of pre-shutdown behavior.
The inspectors observed certain weaknesses in the areas of procedures control, documentation and communication. Administrative Procedure A-20 does not clearly delineate responsibility and authority for the control of Alarm Response Cards.
No administrative procedure has been established for the control of the station non-technical specification Routine Test (RT) activities.
In addition, the non-licensed operators training curriculum does not incorporate in-struction and examination materials related to the radwaste control room operation in accordance with the requirements of training procedure NTS-I-301. The inspector also noted that station response to the NRB's open items lacked adequate documentation to support the completion of plant management review and timely resolutions.
Lack of procedural adherence was evident when the auxiliary operator failed to document and inform his supervisor of the deviation in the routine test he had performed.
The above weaknesses are discussed in details in applicable paragraphs of this report.
3.0 Plant Operating Procedures (Module 42700)
3.1 Scope The scope of this inspection was to evaluate the adequacy of tte licensee's ope' rating procedures and to verify proper control and maintenance of these procedures.
3.2 Program Implementation and Find _ings The Document Control / Procedure Control (DCPC) organization is responsible for maintaining, updating, and distributing procedures, as required by Administrative Procedure A-20.
The inspec+or reviewed selected procedures, procedure interfaces, and witnessed procedure implementation during conduct of the licensee's tests and verifications.
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-6-3.2.1 Document Control During the walkdown of selected procedures (reference
. paragraph 3.2.2 sections A, B, and C), the inspectors identified areas of inconsistencies in Administrative Procedure A-20. Organizations assigned responsibilities within A-20 were not performing their tasks in the belief that the task was not within their responsibility. An example of this was identified by the inspectors during the walkdown of the use and control of the alarm response card (ARC) updating program described in A-20 (see Paragraph 3.2.*.8).
The assigned ac.tions for the updating and removal of the ARCS were not followed by appropriate personnel as described in the A-20 procedure.
This concern was discussed with the licensee's management who initiated the revision to Administrative Procedure A-20.
The licensee stated that a review of the A-20 procedure would be performed and a walkdown of the procedure would be initiated by the responsible assigned organization.
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licensee also stated that they will prepare an l
Administrative Procedure defining the use of the Routine l
Test Procedures.
Whether procedure A-20 can be implemented as written l
Sppears not to have been verified by the responsible l
organization prior to issuance. The method that the l
licensee uses to verify that their administrative l
procedures function as written is an unresolved item (50-277/88-28-01 and 50-278/88-28-01).
3.2.2 Procedure Walkdowns The inspector reviewed selected Administrative
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(A) procedures, System (S) procedures and Routine l
Test (Ri1 procedures to determine their adequacy, and l
the effec.tiveness of the performance of the procedures.
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Control Room Procedure Control
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Dur,.ig the inspection and verification of physical I
condition of control room procedures, the inspector noted that several $ procedures were torn or separated from their binders.
None of these procedures were found to be illegible, however, several procedures were found to have identifying procedure and revision numbers missing from page corners and edges. Many binders contained procedure pages that were several years old and had become worn through extended use.
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This concern was discussed with the licensee and the DCPC voup took immediate action to correct it.
The DCPC group further agreed to develop a checklist for auditing control room procedures to identify and correct such problems on a regular basis.
Some control room personnel were interviewed by the E
inspector on the use and control of these procedures.
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in these areas.
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Review of Selected Alarm Response Cards The plant alarm response card (ARC) system in use in the control room has existed for many years in a 5x8 card file.
Each 5x8 card lists the procedure for the control room operator (s) response to all alarms which are annunciated in the control room. At the time of this inspection, the ARC system was being revised to provide alarm response procedures with a new format, and to replace the 5x8 cards with looseleaf books.
However, the licensee had not yet defined the use of the updated control room Alarm Response Procedures versus the superseded 5x8 cards.
Discussion with control room personnel indicated that they were not adequately informed or given direction for the use of the updated documents. The cognizant DCPC staff stated that upon completion of the alarm response procedure update, and after its implementation, tb-5x8 cards would be removed and proper instruction for use of the new documents would be providd it. centrol room personnel.
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Routine Test procedures (RT)
The inspector discussed the conduct of typical RT procedures with cognizant operations personnel. These individuals appeared knowledgeable of the process by which RTs were being issued, performed, controlled, and documented.
The inspector noted that even though there was currently no administrative procedure governing the use of RTs, plant policy required all RTs to be controlled as Surveillance Tests (ST).
During the walkdown of routine test procedures (non-technical specification related), the inspector identified concerns about the lack of an administra-tive procedure to control the station equipment routine tests, and the effectiveness of personnel performing them.
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-8-The inspector witnessed the performance of RT-1.6.12 by an Auxiliary Operator (AO).
This test involved a non-safety related oil tank sump pump operability check and was conducted on a weekly basis.
The inspector noted that the A0 was properly briefed by the Chief Operator (CO) prior to performance of the test. The RT required the pump switch to be returned to its "AUT0" position upon completion of the operability check.
However, the A0 returned the switch to its "0FF" position and explained that the switch was always left in the "0FF" position to avoid an inadvertent discharge of oil to the river. The A0 did not note the abnormal switch posittor, on the test procedure, nor did he subsequently inform the CO or the Shift Supervisor.
The inspector discussed his concerns with the CO that the A0 did not follow the procedure or identify the abnormal switch position.
The completed RT was forwarded to the Shift Supervisor for approval without any mention of the pump switch not being left in the position specified by the procedure.
The inspector informed the Shift Supervisor of the problem, who initiated a Temporary Procedure Change (TPC) but did not discuss the situation with other
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operations personnel. The inspector also informed the Shift Technical Advisor (STA) and discussed the submittal of TPCs for other RTs which have a similar condition.
The inspector notified the plant manager of a particular lack of response from the operations personnel to immediately identify, communicate, and
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correct this situation.
He responded promptly and appropriately with written notification, and briefings to all operations personnel regarding procedure compliance and the proper reporting of procedure deviations. Management control of routine test activities is an unresolved item (50-277/88-28-02 and 50-278/88-28-02) panding response from the licensee identifying corrective actions to be taken.
The inspector subsequently learned that a procedure change request was submitted for this RT by another A0 in February, 1988. The cognizant group oid not take followup action to revise the procedure accordingl _ _ _ _ _ _ _ _ _
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-9-3.3 Conclusions Although initial staff sensitivity to the need to address a procedure deviation was lacking, the management action to issue instructions and brief operations personnel on the conduct of routine tests, proper test documentation, and reporting of a related i
deviation identified by an NRC inspector, during this inspection, was I
prompt and appropriate. Admininstrative Procedure A-20, however, was determined to be incomplete, in that the procedure did not clearly establish organizational responsibility for control and update of the control room alarm response cards. The licensee also committed to prepare an Administrative (A) procedure describing the use and control of routine test procedures.
4.0 Non-Licensed Operator Training (Module 41400)
4.1 Scope The effectiveness of the implementation of the licensee's non-licensed operator training (NLOT) was assessed by:
Reviewing the documented NLOT program.
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Observing activities perfermed by the non-licensed operators
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(NL0s).
Following up status of selected NLOT corrective actions (CAs) in
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the 91an to Restart,Section II (see paragraph 7.0).
4.2 Non-Licensed Operator Training Program The Peach Bottom Atomic Power Station INPO accredited training program for NL0s, which includes Plant Operators (P0s), Assistant Plant Operators (AP0s) and Auxiliary Operators ( A0s), is conducted in accordance with administrative procedure A-50 and ANSI N18.1-1971, Revision O.
The inspector also reviewed several training procedures during the inspection. All documents reviewed and referenced are listed in Attachment 1.
Organizationally, the Site Training Superintendent is accountable to the Vice President, PBAPS for providing site NLOT under the direction of corporate Nuclear Training to meet regulatory requirements and commitments.
The PBAPS Training Section implements and maintains the current NLOT program with the assistance of Operations.
Their assistance includes monthly Interface Committee meetings to review lesson plans, and to provide subject matter expertise and continued assessment (feedback) of the NLOT program.
Operations also conducts the on-the-job training (SJT) part of NLOT.
Upon satisfactory completion of the DJT, an A0 or APO is given qualification tests by the Training Section of the Generation Division for promotion to the next higher position (see paragraph 4.3).
As described by the super-
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-10-intendent of the Nuclear Training Section (corporate), the Training Section of the Generation Division will continue to administer the qualification tests until the corporate Nuclear Training Section develops the capabilit/ to conduct independent assessments which include qualification tests for the NLOT program.
The majority of the NLO training staff are contractors who lack PBAPS plant specific experience.
The PBAPS management recognizes this weakness and is taking corrective action.
One action is to supplement the training staff with senior P0s on a part time basis.
In December, 1987, the Floor Foreman positions were established in Operwtions and filled by senior P0s. One of their major responsibilities is to assure that the progression of training of NLO shift personnel is being implemented and monitored. The foremen recommend to the shift manager those NL0s who are ready for their qualifying exams. They also review les:on plans and attend the monthly interface meetings betwean the Operations and the Training Sections.
Design and construction of a new training center has been authorized and the training center is expected to be operational in March, 1990.
The training center will repla e the on-site trailers and a butiding located 25 miles from the site.
The new operations management manual, administrative and NLOT procedures, and the personnel training records were reviewed by the inspector.
NLOT procedures are being revised to reflect the corrective actions (CAs) and commitments for restart (see paragraph 7.0).
Individual NLO training records reviewed ware found current and organized.
4.3 Observations of Non-Licensed Training Activities Two AP0s, and an A0 in training for APO, were observed removing breakers in accordance with procedure 58.3.0.
The APO's actions to correct an error in the blocking permit to remove the breakers and the training given to the A0 were indicative of the effectiveness of the licensee's NLOT program implementation.
During interviews, the inspector determined that several AP0s had taken the qualifying exams for PO in accordance with procedure A-50.
There are two four year old exams (A and B) used for qualifying APO to P0.
The two exams have never been updated to include such training as radwaste control room operation, an important task required of all P0s.
Paragraph 7.1.4 of training procedure NTS-I-301 requires that the instructor construct test questions or estabitsh other measures that represent the tasks and objectives of the course. A memorandum was sent in mid August, 1988, from the Senior Training NLO instructor to the Training Section of the
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-11-Generation Division stating that the two NLO exams needed to be updated. The response, dated September 1, 1988, requested that the Site Training Section submit recomeendations for updati g the NLO exams.
The NLO exam deficiencies are collectively considered an unresolved item pending revision and upgrade of the NLO exams (50-227/88-28-03 and 501278/88-28-03).
During interviews, the inspector discussed with each NLO the training programs mentioned in the licensee's Restart Plan specifically,
"People, Foundation of Excellence." The responses were positive and reflected in the work observed, except in the case of procedural nonadherence discussed in paragraph 3.2.2.C above.
No violations were identified.
4.4 Conclusions Management plans for improving the NLOT program have included provisions for a new training center, revision of NLOT procedures, and improved site specific training of the cont-acted training staff.
However, the licensee has not aggressively pursued upgrading of NLO exams to ensure that NL0s are adequately trained and qualified.
5.0 Off-Site Review Committee - Nuclear Review Board (NRB) (Module 40701)
5.1 Scope The scope of this inspection was to ascertain if the functions of the Peach Bottom Atomic Power Stations (PBAPS) Nuclear Review Board were performed in accordance with the regulatory requirements and the licensee's plans and procedures listed in Attachment 1, 5,2 Program Review and Findings 5.2.1 The licensee's Charter of Nuclear Review Board (NRB)
establishes an offsite review board whose purpose is to review, audit and evaluate both technical and organiza-tional matters pertaining to the safe operation of PBAPS Units 2 and 3.
The NRB is responsib'e to identify actual and potential problems and to initiate prompt and effective corrective actions.
The NRB is composed of senior level individuals with diverse technical and nuclear plant operational backgrounds and acts as an advisory group reporting to the Executive Vice President - Nuclear, on a regular basis.
In addition, the chairman of the NRB meets directly with the chairman of the Nuclear Committee of the Board of Directors (NCB) and reports to the NCB annually on NRB activities, inclading significant nuclear plant operational issues.
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-12-The inspector attended an NRB nieeting on September 1,1988.
During this meeting, two shift managers provided their overall assessment of the operation staff's concerns and understanding of the Philadelphia Electric Company's current policies resulting from the NRC order to shutdown the Peach Bottom Atomic Power Station.
These concerns were mainly of a financial and administrative nature. The NRB members acknowledged that necessary administrative and organization changes have taken place, and stated that improvements in staffing and direct management involvement in the plant operational activities are being exercised.
The Vice President - PBAPS reported to the NRB on his assessment of overall readiness including the status of the
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PBAPS Unit 2 restart.
The NRB members reviewed the licensee's resolution of INPO open items, including implementation of corrective actions related to readiness to restart, The inspector verified certain aspects of the licensee's response to INPO concerns, such as procedures update, and effectiveness of the new shift tesm. They were
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found satisfactory.
5.2.2 tsB Audits The NRB has delegated responsibility to the QA audit group to conduct periodic audits of PBAPS Units 2 and 3 l
operation.
These audits implement the requirements of the Quality Assurance Plan in accordance with the plant Technical Specifications paragraph 6.5.2.8.
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reviewed selected QA audit reports (Ref. Attachment 1) and the audit schedule, and determined that the audits were conducted per schedule by qualified and trained individuals. Audit plans and scopes were adequately reviewed and concurred in by the NRB in accordance with the requirements delineated in procedure NRB-3, Audit.
The inspector also noted that audit scopes and objectives were fully met; audit findings were comprehensive; and audit results were forwarded to the NRB for review. The inspector verified that appropriate actions were taken by the NRB, and that required corrective actions were implemented on a timely basis by the cogni: ant organiza-tion.
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-13-5.2.3 NRB Action Items The inspector reviewed NRB previous minutes of meetings (Ref. Attachment 1) and discussed with the NRB Chairman the status of selected NRB action items assigned to cognizant plant organizations.
Such action items are tracked through the licensee's commitment tracking program.
A followup was conducted to verify the station's corrective actions to resolve the NRB issues.
The inspector noted lack of documentation to verify the station management response to the NRB issues.
For example: items 87-198-04, Fuel Oil Sampling Program; 87-202-01, Diesel Protective Relays; 87-205-07, IE Notices 86-81 and 86-09; 87-210-11, Relay Preventive Maintenance Program; and 88-215-02, Functionality and Monitoring of Circuit Breaker Cell Micro-Switches did not have supporting documentation to verify the adequacy and effectiseness of the corrective action implementation.
This item is considered an unresolved issue pending verification by the licensee of
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the actions for resolution of the NRB concerns (50-277/88-28-04 and 50-278/88-28-04).
5.2.4 Other Committees i
A.
Nuclear Committee of the Board of Directors (NCB)
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The Board of Directors of the Philadelphia Electric
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Company (PECo) has established a Nuclear Committee of the Board of Directors (NCB).
The NCB provides general oversight of all nuclear and nuclea*-relate 4 operations, and reviews and reports to the bard o:::
(1) safety, reliability and quality of nuclear l
operations (2) effectiveness of management of nuclear operations and (3) effectiveness of management systems for self-identification of problems and prompt and
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complete corrective action.
Specific duties of the
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NCB include review of NRC, INPO and ANI
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communications; review of significant incidents; review of monthly plant "tey-indicator" trends; and inspections of the plant on a periodic basis.
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inspector discussed with the NRB chairman the interfaces of the NRB and NCB committees. The NCB members were appraised of the NRB's evaluation of the
restart activities at PBAPS prior to the NRB meeting on September 1, 1983.
In addition to the NRB, the NCB interfaces with the Nuclear Quality Assurance (NQA) group.
The NCB
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-14-monitors and evaluates results of NRB and NQA independent assessments of PBAPS operational activities, and then presents the assessments to the PEco Board of Directors. Since the NCB has been in effect for less than a year, its overall effectiveness is yet to be evaluated.
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Plant Operations Review Committee (PORC)
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The licensee's Administrative Procedure A-04 and Administrative Guide AG-12 (Ref. Attachment 1)
describe the functions and responsibilities of the PBAPS Plant Operations Review Comnittee.
Currently, these procedures are being rewritten and revised by plant management to comply with the licensee's Plan for Restart of PBAPS, dated April 8, 1988. The
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inspector reviewed several previous PORC minutes of
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meetings and attended a PORC meeting.
The activities
undertaken wera consistent with the requirements established in the plant procedures and Technir.al Specifications.
Followup action and discussions with licensee management were held to verify the adequacy of the PORC review process conducted by the cognizant groups.
The process was found to be satisfactory.
5.3 Conclusions Administrative controls, duties and responsibilities of the licensee's offsite review committee (NRB) are adequately defined and implemented in accordance with the plant Technical Specifications, licensee's policies, QA Plans, and administrative procedures (Attachment 1).
Composition of the NRB at:d its subcornmittees, riember
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qualification, and meeting frequency were found to be satisfactory.
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Based on the review of NRB meeting minutes, discussions with l
cognizant NRB members and licensee management, and attendance at the NRB meeting, the inspector determined that NRB functions and activities were adequate.
The irspector noted, however, that there is a lack of adequate documentary evidence supporting the station j
management review and the timeliness of the response to NRB action items (Paragraph 5.2.3).
i 6.0 QA/QC Interfaces The licensee has restructured the QA organization by integrating previously separate quality assurance and quality control organizations into one centralized organization. Accordingly, the QA program is managed by the General Manager - Nuclear QA, who reports to the Executive Vice President-Nuclear as an integral part of his Senior Management Team. A QA l
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-15-i Manager position at PBAPS has been created and is currently functioning.
He is responsible for all quality control and quality essurance activities at PBAPS.
In addition to the QA Manager - PBAPS, the Manager -
Independent Safety Engineering Group, the Manager - Performance Assessment, and the Manager - Quality Support, are also involved in PBAPS quality programs. All report to the General Manager-Nuclear QA.
These quality managers are assigned distinct responsibilities to perform audits, trending and evaluation of independent quality assurance and quality control activities.
They siso assess organizational performance, conduct independent reviews of plant operations and improvements, revie-!
preparation of NQA manuals, and conduct vendor related interfaces and activities as delineated in the licensee's QA program.
The NRB has delegated responsibility to the QA audit group to conduct periodic audits of PBAPS operations as described in paragraph 5.2.2.
Based on the review of QA audit documentation and discussions with cognizant QA audit personnel, the inspector noted that they have established a goal to include performance based attributes in at least 50%
of their audits.
These audits are further supported by performance based QA surveillance and monitoring.
6.1 Conclusions Based on discussion with the station cognizant QA staff and management, and review of the QA audits, the inspector determined that the QA action to review and verify the licensee's corrective actions pertaining to the PBAPS Plan for Restart was adequate.
The current QA reorganization consolidating station QA and OC in one centralized organization with adequate staffing appeared to have improved station 0A/QC interfaces.
7,0 Status of Plan For Restart of Peach Bottom Atomic Station Corrective Action The following corrective actions (CAs) were reviewed for conformance with the licenset. ;0mmitments as defined in their "Plan For Restart of Peach Bottom Atomic Power Station,"Section II, Revision 1, dated April 8, 1988.
CA3-3.3.1: Conduct the Personal Effectiveness course for all current pBlTS non-licensed operators A licensee representative stated that there are some NL0s that have not taken the course.
The CA remains open until these NL0s complete the course,
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CA3-3.4.1: Develop a fellow-up training program and obtain
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management approval A training course entitled "Interaction" was developed and approved on August 1, 1988. The
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CA is closed and the course is being scheduled.
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CA3-4.4 Review and revise Station Procedures as required
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The licensee issued their methodology for restructuring
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procedures on October 5, 1987.
Task schedules and assign-ments were assigned to management personnel during the latter half of 1987. The assignments were documented in a Procedure Upgrade Task Status Summary Report which is reviewed by licensee management on a routine basis.
The
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inspector verified that the assignments listed in the Procedure Upgrade Task Status Summary Report have been assigned as Itsted and completed.
CA3-4.4.7 - Review and revise as appropriate the station Xdm'inistrative (A) Procedures Of the 13 Administrasive (A) procedures that were revised, the inspector reviewed the following 3 procedures:
A-01, Administrative Procedure Preparation, Revision
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7. July 6, 1988.
t A-02, Specification Control Procedure for Control
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of Drawing 1.ogs, Revision 14, May 4, 1988.
i A-20, Generation, Revision and Implementation,
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of Operating Procedures, Revision 5. April 5, 1988.
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I The inspector determined that the above procedures were written as described in this procedure guidance manual.
CA3-4.4.7 - Review and revise as appropriate the System
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[ krocedures t
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The licensee has completed their evaluation on upgrading of
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their System (S) procedures and their General Plant (GP)
l procedures that they determined were required for restart.
l The results of their evaluation has been documented in their memos dated July 24, 1987 and August 9, 1987. Their l
System (5) procedures have been reviewed and are considered
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technically accurate and usable for plant op rations.
However, the licensee pla n to rewrite, as necessary, in
order to provide an associated check-off list and a human (
factors review to make thee easy to use. The inspector
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i reviewed the upgrading program and verified that these I
procedures were following the guidance identified in their oparations writers manual.
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CA3-4.4.7 Review and revise as appropriate the Reactor Engineering (RE) Procedures A licensee memo dated August 19, 1987 identified the scope and technical review requirements for assessing the status of RE Procedures.
In applying their criteria for this review (Letter, P.J. Duca to File, Evaluation Methodology
for Determining if Restructuring and Revision of Procedures is Required, dated July 16,1987) the licensee established
three categories of actions:
Category 1 - Required prior to start up.
Category 2 - Not required prior to start-up, but action plan identified for completion.
Category 3 - Not required prior to start-up, no action plan.
The results of the Technical review were presented in the August 19, 1987 memo. The inspector verified that the majority of Category 1 procedures had been completed and
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were being implemented for plant operations. Of the 9 Reactor Engineering procedures issued only 5 had to be revised. The inspector verified that the licensee has
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completed the review and revised these 5 procedures.
CA3-4.4.7 Review and revise as appropriate the Routine Test (RT) procedures The Routine Test (RT) procedure upgrade program is not completed as yet.
The inspectors concern regarding the RT procedures is discussed in paragraph 3.2.2 C of this report and the lack of an Administrative (A) procedure
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that addresses the use of the RTs is discussed in paragraph 3.2.1 of this report.
l Based on the above observations, the review of routine test procedure controls remains open.
l 8.0 Unresolved Items
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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or violations.
Unresolved items are discussed in paragraphs 3.2.1, 3.2.2.C, 4.3 and i
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5.2.3.
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- o-18-9.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance interview on August 29, 1988.
The findings of the inspection were discussed with licensee representatives during the i
course of the inspection and were presented to the licensee manageme.a.t at the exit interview on September 1, 1988. A subsequent exit interview on September 2, 1988 was conducted to inform the licensee of the status of certain followup items from the previous day (see paragraph 1.0 for attendees).
At no time during this inspection was written material concerning inspection findings provided to the licensee.
The licensee also did not indicate that any proprietary infortnation was involved within the scope of this inspectio ______ _____
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ATTACHMENT 1 DOCUMENTS REVIEWED f
Administrative Procedures (Sections 3, 4 and 5)
A-01 Administrative Procedure Preparation, Revision 7. July 6,1988 A-02 Specification Control Procedure For Control of Drawings Logs, Revision 14, May 4, 1988 A-04, Plant Operations Raview Committee Procedures, Revision 23, (Draf t)
A-20 Generation, Revision and Implementation of Operating Procedures,
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Revision 5, April 5, 1988.
A-50 Training Procedure, Revision 12 Administrative Guidelines (Sections 3 and 5)
I AG-12, PORC Administration, Revision 2
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AG-14 Guideline For Control of Post-PORC Procedures, Revision 2 l
Test Procedures (Section 3)
RT-1.6.12 Yard Oratnage Sump Pump Operability and Ottty 011 Storage Level i
Test, Revision 0
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RT-1.9.1 Heating and Ventilation Filter Inspection, Unit 2 and 3 RT-8.7.2 Functional Test of Feedwater Heater Level Switches, Unit 2 Training Procedures (Section 4)
Training procedure TP-430, Training Impact, Revision 0 i
Training procedure NTS-I-301, Test Construction, Revision 0 f
Other Procedures and Reference Docur'nt (Sections 3, 4 and 5)
Charter of Nuclear Review Board (PBAPS), Revision ll, May 13, 1988 f
NRB-1, Review Practices, Revision 6, May 13, 1988 l
l NRB-2 Determination of Unreviewed Safety Question, Revision 1,
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May 13, 1938
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l NRB-3, Audits, Revision 2, May 13, 1988 l
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Attachment 1 Plan for Restart of Peach Bottom Atomic Power Station Units 2 and 3 Sections I and II, dated April 8, 1988.
Generic procedure 58.3.0, Removing and Returning to Service of 480VAC and 250VDC Motor, Revision 6 Audit Reports (Sections 4 and 5:
AP-88-10-TR, Licensed Operators Replacement and Requalification Training, January 15-March 4, 1988 AP-87-175-ISI, Visual Non-Destructive Examination and Functional Testing, November 16-December 30, 1987 AP-87-176-PR, Corrective Action Prrgram, November 30-9ecember 29, 1987 AP-87-177-PL, Fire Protection, November 23-December 18, 1987 AP-87-TR, Non-Licensed Operator Training /Requalificatit n AP-87-157-SD, PBAPS Permit and Blocking NRB Identified Open Items (Section 5)
86-192-02, Blocking Related Errors 87-200-07, Permit and Blocking Process 87-202-01. Diesel Protective Relays 87-205-03, Emergency Diesel Ventilation Supply Air 87-205-05, RHR and Core Spray Motors 87-205-07, IE Information Notices 86-81 and 86-09 87-208-01, Permit and Blocking 87-208-02, Control for Moving Mode Switch 87-198-04, QA Audit AP 86-97 HPC 86-185-02, loss of Electric Supply 87-210-08 Testing and Monitoring for Water in Diesel Fuel 88-215-02, Circuit Breaker Cell Micro-Switches 88-220-04, Voltage Control of RP5 M-G Set
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Attachment 1 NR8 Minutes of Meetines. (Section 5)
Meeting Report No. 200, March 12,1987 Meeting Report No. 202 May 7, 1987 Meeting Report No. 205, July 9,1987 h eting Report No. 208, September 3, 1987 Meeting Report No. 210, "ovember 5, 1987 Meeting Report No. 217 Aarch 3, 1988
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Meeting Report No. 216, June 23,1988 l
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