IR 05000277/1989011

Insp Repts 50-277/89-11 & 50-278/89-11 on 890405-11.No Violations Noted.Major Areas Inspected:Implementation of Unit 2 Restart Power Testing Program,Including Review of Program & Verification Re in-plant Program

ML20245H881
Person / Time
Site:	Peach Bottom
Issue date:	04/20/1989
From:	Conte R, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245H875	List: IR 05000277/1989011 ML20245H871
References
50-277-89-11, 50-278-89-11, NUDOCS 8905030560
Download: ML20245H881 (7)

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U.S. NUCLEAR REGULATORY COMMISSION 1

REGION I

Report No /89-11 50-278/89-11 Docket No and 50-278 License Nos. DPR-44 and DPR-56 Licensee: Philadelphia Electric Company P.O. Box 7520 Philadelphia, Pennsylvania 19101 j Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: April 5-11, 1989 Inspector: dM ,/ 2 --

f6 h9 DonaldJ.F1gsk,Sr.OperationsEngineer 'l Date Approved by: mc O Richard Conte, Chief, BWR Section Date Inspection Summary: Inspection on April 5-11, 1989 (Inspection Report Numbers 50-277/89-11 and 50-278/89-11)

Areas Inspected: Routine unannounced inspection of the implementation of the Peach Bottom Atomic Power Station Unit 2 Restart Power Testing Program to ,

include a review of the program and verification that the in plant program was consistent with licensee commitment Results: The licensee program and implementation of the program is consistent {

with the licensee commitment PDR ADOCK 05000277 Q PDC

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i REPORT DETAILS l 1.0 PERSONS CONTACTED J

Licensee G. Bird, Nuclear Security Specialist

• J. Cotton, Superintendent of Operations

• D. Cribbe, Regulatory Engineer

• A. Donell, Superintendent Quality Services W. Eckman, Lead Auditor QA J. Franz, Plant Manager

• G. Hanson, Regulatory R. Hirzel, Superintendent Technical Monitoring J. Humphries, ISEG R. Kankus; Staff Engineer D. Lequia, Superintendent Plant Services

• G. Lipscy, Restart Power Testing Manager T. Netzer, Superintendent Planning, Scheduling and Reporting F. Polaski, Assistant Superintendent Operations K. Powers, Project Manager

• Pratt, Manager Quality G. Rainey, Superintendent Maintenance and Instrument and Control  !

C. Schwarz, Shift Supervisor 4 A. Wasong, Shift Manager N. Yost, Shift Supervisor <

U.S Nuclear Regulatory Commission

• R. Urban, Resident Inspector

• Denotes those present at the Exit Interview held on April 11, 198 .0 PURPOSE AND SCOPE OF INSPECTION The purpose of the inspection was to determine if the licensee has implemented the Restart Power Testing Program dated February 3, 1989 as accepted by the NRC in a letter dated March 17, 1989. The inspection consisted of review of the documents indicated in Attachment A and interviews of licensee representatives directly involved in the Restart Testing program implementation and performance of the self assessment at the various testing condition .0 PROGRAM ADMINISTRATIVE REVIEW The inspector reviewed special procedures SP 1166 and SP 1167 to determine if the program controls were adequate and consistent with licensee commitment Based on the review of the procedures and interviews the inspector concluded that the licensee program controls were consistent with the licensee commitments. The licensee agreed to modify procedure SP 1166 to clarify the method that failed routine test results would be identified to the Test Review

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i Group, to. clarify the limitations of reactor power at the test conditions, and j clarify the purpose and charter for the Test Review Group. These modifications

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to the procedures were being included within the current in process revision I of the procedur .0 IMPLEMENTATION  :

4.1 Verification of Plant Equ'pment Operation The inspector verified that the facility has' developed a test logic to '

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assure that the equipment is operating-as required-and that the test conditions are consistent with the test conditions specified in the program. Included within the testing program are modification acceptance tests (MAT), routine tests, surveillance tests, and special tests. The inspector sampled a number of test procedures and found them to-be

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acceptable. The inspector also questioned the status of the review of the j MAT procedures'for acceptance criteria. During the IATI inspection the ]

NRC identified weaknesses in the acceptance criteria.of the MATS. The inspector concluded that the facility has reviewed the MATS to be performed during the restart power testing program to assure that the steps are appropriate to determine the successful operation of the equipment in question. The facility has not specifically revised the format of the MAT to separate out the acceptance criteria as will be the case in all future MAT Test results will be reviewed by the normal in plant organizations as wel, as by the Test Review Group. Adequate performance by the plant equipment will be included as part of the facility evaluations to determine whether to proceed to the next testing conditio .2 Verification of Plant personnel Performance The inspector verified that the facility has developed performance standards and criteria for evaluating performance of personnel during the restart power testing program. Standards were developed for operations, i maintenance, technical and services. Evaluations will be made during the testing program to evaluate personnel performance both by the line organization as well as by independent organizations. Training has been  ;

provided to the individuals who will perform the performance evaluation Performance indicators have also been developed for tracking personnel performance. During the inspection the inspector noted that the facility '

had not yet established the performance indicator for surveillance tests with unsatisfactory results. The Restart Program Manager also was aware t of this situation and was working to get this perfortrance indicato included on the list of performance indicators. This was finalized during  !

the course of the inspection.

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The inspector interviewed a sample of line manage's r (Operations, I Services Maintenance and Instrument and Control) as well as independent organization individuals (Technical Monitoring, Quality Services, Quality Assurance and Independent Safety Engineering Division) to determine how ,

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l-4-i the performance assessments will be accomplished. The individuals interviewed were all aware of their responsibilities in the assessment !

process and had developed approaches tailored to their individual organizations. The inspector did note that an assessment by the Shift j{

Managers using the performance criteria was not planned, since they were considered to be a part of the organization that was being assessed. The inspector questioned this and the licensee agreed that input from the Shift Managers will be considered during the assessment process j especially in the area of interfaces with other work groups. Based on the /

above, the performance assessment approaches were found to be acceptable i to the inspecto I The inspector also reviewed the results of the Performance Assessment '

Division Pre-startup assessment. This assessment was identified as to be a part of the independent assessment in the restart power testing program. The conclusion reached was that no issues or items were ,

identified that would adversely impact the startup readiness of Unit ]

The inspector had no additional questions on the results of this !

assessmen l

In addition to the licensee organization assessments an industry observer j will provide his own independent evaluation of personnel performance. A j Senior Reactor Licensed Operator from the Hope Creek Generating Station, j who has also been trained in the observation criteria, will be an active "

member of the assessment process during the power ascension testing progra i l

The inspector noted that the licensee independent organizations had developed a coordinated overall plan to perform their assessments. This '

assured that maximum coverage of the restart testing activities occurred and minimized the amount of duplicative independent assessments of the same activit .3 Management Self-assessment Process The inspector interviewed a sample of line managers (Operations, Maintenance and Instrumentation and Control, Services), independent organization individuals (Technical Monitoring, Quality Services, Quality Assurance and Independent Safety Engineering Division) and Managers from the Management Oversite Team (Plant Manager, Project Manager and Manager Quality Assurance - Peach Bottom) to determine if the self assessment process for restart has been implemented. Based on the interviews the inspector concluded that the individuals involved in the self assessment process were aware of their responsibilities and have developed methods to perform the self-assessment. The inspector further concluded that the self-assessment process for restart is essentially the elements of the licensee's normal assessment approach with the difference being a more formally documented end product to support the restart power testing commitments. In addition the inspector concluded that the management philosophy prevalent on site is to assure that the plant and personnel

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-5-are performing acceptably prior to requesting that the NRC release the plant from a test hold condition. The desire to aintain the schedule for the restart testing program is secondary to achieving the desired acceptable level of performanc .4 Operator Training The inspector verified that the licensee has developed a program to use the restart testing period as a training tool for the conversion of cold licenses to lat licenses and as a refresher training for the other licensed opentors. The licensee is providing the cold licensed operators l time to perform the required reactivity manipulations and time at greater I

than 20s power during the restart testing program. The hot licensed operators will also be provided refresher training during the restart program. The licensee is also attempting to divide the performance of specific plant evolutions among the operators and operating crews to maximize the training benefit for the operators. To achieve thie end the licensee has developed a tracking system to document the major plant transients, specific plant evolutions, and surveillance tests performed t

I by each operators. This tracking system will help in the scheduling of plant activities and the selection of individuals to perform the activity. Based on discussion with operations shift personnel the inspector determined that the shift personnel were not fully aware of the tracking system. The licansee plans to provide this information to the shift personnel but had not completed this at the time of this inspectio .5 Conclusion The inspector concluded that the licensee has a Restart Testing Program that is consistent with the plan submitted to the NRC. The facility has essentially implemented the plan and have or will have completed all the actions to carry out the plan when require i 5.0 Exit Interview At the conclusion of the inspection of April 11, 1989 an ex1t meeting was conducted with those persons indicated in paragraph 1.0. The inspection scope and findings were summarized. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

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l DOCUMENTS REVIEWED Restart Power Testing Program Management Oversite Team Notebook, training provided March 23, 198 Operations Management Manual, Revision 1 A-3 Temporary Changes to Procedures, Revision 10, dated September 15, 198 A-23 Generation of Special Procedures, Revision 3 dated January 20, 198 A-43 Surveillance Power Testing System, Revision 22, dated January 23, 198 A-47 Procedure for the Generation of ST Procedures, Revision 2, dated May 9, 198 A-86 Corrective Action, Revision 9, dated December 5, 198 A-131 Identification and Evaluation of Potential Deportability Items, Revision 0, dated November 11, 198 !

NQA Independent Assessment Plan PBAPS Power Ascension, dated March 22, 198 Performance Assessment Division PBAPS Unit 2 Pre startup Assessment, PAP 89-01 dated April 5,198 PBAPS Unit 2 Power Ascension Schedule Revision 0, dated March 31, 198 Restart Power Testing Performance Criteria and Evaluation Guidelines, dated l March 3, 198 "

Surveillance / Routine Test Matrix for enhancement of operator trainin SP 1166 Program Control For Restart Power Testing-Post Cycle Seven, dated March 30, 198 l SP 1167 Unit 2 Post Cycle Seven Restart Power Testing, dated March 20, 198 SP 1230 Recirculation Runback, dated March 9, 198 SP 1231 Recirculation Pump Trip, dated March 9, 198 SP 1232 FeedPump Trip, dated March 1, 198 SP 1248 Unit 2 Post Cycle Seven Restart Criticality, Revision 0 PORC approve MAT 1178 Replacement of HPCI Turbine Exhaust Line Drain Steam Trap MAT 1352A HPCI Function from Auxiliary Shutdown Panel l

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MAT 1695 Replacement of Reactor Feed Pump Minimum Flow Recirculation Valves MAT 1744 MSL Drain to Main Condenser ST 10.16 HPCI Function from Alternate Control Panel RT 6.7 Reactor Feed Pump Turbine Test l

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