IR 05000277/1989081
| ML20235Z250 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/06/1989 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235Z246 | List: |
| References | |
| 50-277-89-81, 50-278-89-81, IEB-88-007, IEB-88-7, NUDOCS 8903150255 | |
| Download: ML20235Z250 (127) | |
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{{#Wiki_filter:.. ._ _ - _ - _. -, U. S. NUCLEAR REGULATORY COMMISSION
REGION I
, Docket / Report No. 50-277/89-81 License No. DPR-44 50-278/89-81 DPR-56 Licensee: Philadelphia Electric Company Philadelphia, Pennsylvania Facility Name: Peach Bottom Atomic Power Station Inspection at: Delta, Pennsylvania Dates: February 3 - 17, 1989 Inspectors: See Appendix E Approved by: FN kMff J/O'. Li nvill e, Ch 4f/, date/ eac' tor Projects ection 2A, @DivisionofReactr' Projects, ' ' Team Leader Summary Areas Inspected: Integrated Assessment Team Inspection 1171 hours of direct inspection (including 691 hours Unit 2 and 481 hours Unit 3; and 71 hours of deep backshift) to assess the effectiveness of the restart plan corrective actions and the degree of readiness of licensee management controls, programs, and personnel to support safe restart and operation of the plant. The scope of the inspection is further detailed Section 2.2.
I Results: The Team concluded that licensee management controls, programs l and personnel are generally ready and performing at level to support safe ' i startup and operation of the facility.
Results are further summarized in j.
sections 1.0 (Executive Summary) and 2.3 (Summary of Findings).
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_ _ _ _. - _ _ _ _ _ _ _ - - _ - - - - L SUMMARY Following an extensive period of declining performance at the Peach Bottom Atomic Power Station (PBAPS) and an inability _of Philadelphia Electric Company (PECo) management to reverse this trend, in March 1987 the NRC received information that control room operators had been observed sleeping while on duty and were otherwise inattentive to their license obligations.
Shift and plant management either knew or should have known these facts and either took no action or inadequate action to correct this situation.
Lacking reasonable assurance that the facility would be operated in a manner to assure that the health and safety of the public would be , protected, the NRC ordered the licensee to shut down its one operating PBAPS unit on March 31, 1987, and maintain both units in a cold shutdown condition. The Order also required that a comprehensive plan be developed to assure that the facility would be operated safely. -On - October 19, 1988, the NRC approved the licensee's restart plan. On February 2,1989, the licensee reported that subject to resolution of certain identified issues, PBAPS was ready for startup and safe operation.
In order to assess the status and results of PECo's corrective actions, the NRC performed an independent review of the effectiveness of the licensee's management control, programs and personnel during the Integrated Assessment Team Inspection conducted February 3-17, 1989.
The team consisted of an SES-level manager, a team leader and members , of the NRC Region I and Headquarters staff. The inspection team also included an observer representing the Commonwealth of Pennsylvania and one representing the State of Maryland. These observers had access and input to all aspects of the inspection as provided by the established protocol. The areas reviewed during the inspection included site management / operations, licensed operator resource development, station culture, corporate oversight, radiological controls, maintenance / surveillance, engineering / technical support, and , security. The team reported directly to the Regional Administrator of ' l Region I.
Overall, the team concluded with high confidence that PECo management i I controls, programs, and personnel were generally ready and performing l at a level to support safe startup and operation of Peach Bottom Unit 2.
The team also concluded that the corrective actions implemented as stated in the Plan for Restart of PBAPS were generally effective in addressing the four root causes.
Further, although the team identified I certain items which require licensee actions or evaluations, there were no fundamental flaws found in the licensee's management structure, performance, I I programs or implementation that would inhibit its ability to assure reactor or.public safety.
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l 2.0 INTRODUCTION f This report details the findings, observations and conclusions of the NRC's Integrated Assessment Team Inspection (" team") conducted at the Peach Bottom Atomic Power Station on February 3-17, 1989.
The results of this team inspection are to be considered during the NRC staff's deliberations as it reaches its decision regarding a restart recommendation.
2.1 Background Peach Bottom has experienced a deteriorating performance history
in recent years as documented through in>pactions, Systematic ' Assessment of Licensee Performance (SALP) reports, and enforcement actions. There was a complacent attitude toward procedural compliance in plant operations, and management involvement and effectiveness toward improving operations activities was not evident.
In March 1987, the NRC received information that control room operators at Peach Bottom had been observed sleeping while on duty in the control room, reading materials not directly job related, and being otherwise inattentive to licensed duties. The NRC confirmed this information during the initial phase of an investigation and determined that all levels of plant management at that time either knew or should have known of these facts and took either no action or inadequate action to correct this situation. As a result, the NRC staff no longer had reasonable assurance that the facility would be operated in a manner to ensure that the health and safety of the public would be protected. The NRC issued an Order to PECo on March 31, 1987, suspending power operations of the Peach Bottom Units.
Subsequently, the NRC determined that the inattentiveness described in the Order had occurred over an extended period of time and was pervasive, and that the failure by site and corporate management to identify, investigate, and correct these conditions and report them to the NRC demonstrated a significant lack of management attention to, and control of, operations at Peach Bottom.
The Order issued to the licensee addressed concerns including failure of both the line organization and the quality assurance program to identify conditions adverse to safety. Additionally, prior to further proposing operatiori of the Station, the licensee was required to provide for NRC approval, a detailed and comprehensive plan to assure that the facility would be operated safely and comply with all requirements.
In response to the Order, the licensee identified four principal root causes of the issues that led to the shutdown of Peach ! Bottom and proposed a plan for restart that included discrete tasks to correct these root causes.
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3 i l During the extended shutdown, PECo has initiated numerous i management and organizational changes, conducted extensive training, implemented complex plant modifications, and made i various program improvements. During this same period the NRC has performed numerous inspections to determine the status and adequacy of the improvements. The objective of the IATI was to review the adequacy of issues which required follow-up , inspection, determine if improvements made are effective and i appear long lasting, and determine if PECo is prepared to support the restart and safe operation of Peach Bottom.
2.2 Scope of Inspection The team inspection was performed to provide an independent, in-dapth assessment of the degree of readiness of licensee management controls, programs, and personnel to support safe L restart and operation.of the facility. The inspection team performed an integrated evaluation of various functional areas as detailed below.
Within these areas, the inspection consisted of interviews with licensee personnel, observations of plant activities, and selective examinations of procedures, records, and documents by the inspectors. The team also directly observed on going plant activities on all shifts from February 5-8, 1989.
The team focused on the following: Shutdown Order Root Causes -- Site Management / Operations -- Licensed Operator Resource Development / Training -- Station Culture Corporate Oversight / Safety Assessment / Quality -- Verification Other functional areas -- Radiological Controls -- Maintenance / Surveillance Engineering / Technical Support -- -- Security The f'11owing attributes were also considered and examined in the team 1r.spection: -- Development and implementation of management goals / objectives and how they are understood / implemented at various levels of the licensee's organization; i _ _ -.
m [.', L " , _ l 4' Planning / controlling, r'outine activities along 'with --- effective, program implementation; -- Level ~of understanding by. workers / supervisors of potential' impact of day-to-day actions on nuclear-safety; Attitudes of licensee personnel with respect to -- nuclear safety; -- Involvement by senior management in day-to-day operation of the plant including visibility of-senior site-and corporate management; Effectiveness of training, direction,~ guidance ~and -- supervision by first-line supervisors; ' Adequacy of staffing.in light of planned -- accomplishments;. Role of QA/QC in monitoring activities and how.
-- their reports'are used by plant management; . Role of licensee in working with and overseeing -- contractor personnel; Effectiveness'of safety review committees; and, --- -- Communications / problem solving process.
'- 'The team reviewed the following generic /long term problem areas and issues: -- Stability and effectiveness of the management team; Timeliness and effectiveness of corrective actions -- (including management attention to ensure resolution and escalation to senior management if necessary); Interfaces, communication and cooperation among -- operations, maintenance, quality assurance, security, engineering and health physics personnel; Quality of plant procedures and procedure changes -- generated as a result of rewrite projects and plant modifications; Status of the maintenance backlog; -- Overall material. condition including housekeeping.
-- and decontamination effort-of the plant; -- Overtime controls in all functional areas;. Validity of licensee interpretations of Technical -- Specifications and other regulatory bases; Worker and management support of radiological -- controls, especially ALARA; Worker perception of the following items: -- (1) management policies (ii) management and supervisory involvement and effectiveness x______ __ - - _ _ _ _ _ - _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _
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5 ) ,!' ! l l l Worker morale and attitudes; and,. ) -- Licensee internal tracking systems and validity of ! -- closecuts.
2.3 Summary of Results 2.3.1-Overall Summary The team concluded, with high confidence, that licensee management controls, programs, and personnel are generally ready and performing at a level to support safe startup and operation of the facility.
Technical items requiring resolution or completion prior to restart are being addressed and tracked by the.
licensee. The team identified a relatively small number of additional items for which licensee actions . or evaluations appear appropriate. During the ' inspection, the licensee made acceptable commitments in these areas. 'There are currently no fundamental flaws in the licensee's management structure, management performance, programs, or program implementation that would inhibit its ability to assure reactor or public safety during plant operation.
The inspection generally confirmed the results of the report for June 1,1987 through July 31, 1988, as well as validated the general.SALP conclusion that , performance was improving at the end of the SALP period.
Further, licensee performance appeared to be consistent or improving in all functional areas examined during the IATI, with the current level of achievement for overall safety performance equal to or better than that described in the SALP.
For security and safeguards, the performance is noticeably improved.
The inspection generally confirmed the effectiveness of Restart Plan and other various licensee self-improvement programs, including the licensee's self-assessment process. The team identified relatively few issues that had not been previously identified by the licensee.
In the interest of continually improving its self-assessment process, the licensee should evaluate those cases where the NRC either identified new issues or assigned a higher sense of priority than identified by the licensee.
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E Based on a review of the management structure, staffing, goals, policies and administrative controls, the team concluded that the licensee has an acceptable organization and administrative process, with adequate management and technical resources:to assure that the plant.can be operated in a safe and reliable manner during normal and abnormal conditions. _Further,_this performance-based inspection provided an. integrated-look at overall management effectiveness in ensuring high standards.of nuclear safety..The overall ' conclusions of this' inspection confirm facility .. ' management effectiveness, especially its ability.to -- perform self-assessment functions, to improve performance, and.to raise nuclear safety awareness and attitudes throughout the organization.
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Summary of Results by Functional Areas Within each functional area, conclusions were reached including the identification of various strengths and
weaknesses..-These strengths and weaknesses are summarized below.
The basis for these. items, as well' as the many sigr.ificant observations made by the team, are explained in Section 3 of this report.
2.3.2.1 Site Management / Operations Strengths ' Shift Manager leadership.
-- _MBWA program success by noted improvements in -- . plant material condition.
Shift communications within the shift and between -- shifts.
Operational event and problem follow-up'by shift -- and operations management.
Quality of the new system operating procedures.
-- Control of overtime.
-- Weaknesses Some key new system operating procedures initially -- scheduled for completion after restart.
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. 2.3.2.2 Licensed Operator Resource Development Strengths -- None Weaknesses > -- Alternate. career paths and educational plans not formalized or promulgated.
2.3.2.3 Cultural Change i Strengths Effective shift crew teamwork, communications, and' -- f interaction within the shift crew and with other personnel.
Management guidance to operations personnel -- provided as expectations in the Operations Management Manual / Operations Manual.
-- Support by management of Organization i Development / Human Resource activities.
-- Regularly scheduled operations meetings designed to enhance communications, specifically Shift Management Meetings and Shift Team Meetings.
-- Accessibility and openness of all levels of management.
-- Willingness of shift crew.to question suitability of direction provided by shift crew supervision, and shift crew supervision openness to such questioning.
Weaknesses -- Lack of trust in site and operations management due to: o Perception that management may not meet its commitments with respect to career paths and rotational and permanent off-shift assignments.
o lack of timely response to shift crew recommendations on various operations concerns and personnel issues.
o Quality and timeliness of communications and feedback loops.
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l- -- Inconsistency among shift crews in.the . implementation.of some policies.such'as. vacation schedules and-performance evaluations.
Need for effective direct organizational link' -- -between shift crews and' Superintendent for . Operations to provide for clearer guidance and more effective and. responsive feedback.
Timeliness of follow-up Interaction Training for -- licensed and non-licensed operators... Incorporation of parts of PFE/PE training into -- operator-progression training.
2.3.2.4-Corporate Oversight Strengths -- On. site involvement and presence of senior .' management. including the EVP-N in virtually.all-major activities.
-- Positive attitude that has'been' fostered by-corporate management.in station personnel as seen in personal interaction skills, generally being in control of situations and open mindedness toward sharing information and.in critiques.
Enhanced tools to support management self.
-- assessment of issues (MOIL, CTP, OEAP).
. -- Comprehensive scope of NQA audits providing feedback to management regarding identified problems.
-- _ Technical monitoring provides real' time assessment of ongoing activities.
Effectiveness of ISEG root cause analysis.
-- Weaknesses QC installation / inspection procedures need -- improvement.
More focus needed by some auditors on quality and -- safety as indicated by the IST audit.
-- No electrical or I&C expertise on ISEG.
-- Failure of QC to identify deficiencies in tubing installation and support.
< 1989 NQA master audit plan and schedule not yet -- approved.
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2.3.2.5 Radiological Controls Strengths Reduction of contaminated areas and' good -- housekeeping including aggressive goals.
Improved i use of engineering controls such as tents and l containment to reduce contamination spread.
Operational HP interface with other groups -- continues to improve.
-- Corporate and plant management support of ALARA including goal setting and planning.
New aggressive HP technician management chain from -- first line supervisory personnel to Superintendent.
High radiation area controls.
-- Improvement in radiological occurrence report -- closecut timeliness.
Weaknesses -- HP technicians lack Peach Bottom operational power experience.
Radiological occurrence reports continue to -- reflect poor radiation worker practices and contamination controls.
2.3.2.6 Maintenance / Surveillance Strengths -- Particularly effective surveillance scheduling and tracking system (STARS).
Problems resolved by engineering (system / test) -- personnel indicate they are knowledgeable of their systems.
Professionalism of technical personnel includi,1g -- system / technical engineers, I&C Technicians and maintenance craft.
Weaknesses -- Some weak surveillance test procedure acceptance criteria.
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- -. . , . \\ h 10' ,2.3.2.7' Engineering / Technical: Support ,, Strengths - Modification-team approach that" includes the -- . integration of plant. personnel with design i~ engineers during modification-design and revision process.
. Timely revision of_ control room P& ids.on red line.
-- drawings to show complet'ed; modification works.
'Use of double verification / independent =-- verification on MATS and system engineer understanding of the. intent and expected-practices.
Weaknesses.
-- -Lack-of clearly defined acceptance criteria-on MATS.and, poor application of. design basis to-modification acceptance-testing.
2.3.2.8f : Security / Safeguards. Strengths Security responsiveness to NRC questions.
-- Oversight and knowledge of Nuclear Security -- Specialist.
-- Improved attitudes of security force. members.
-- Good integration of security into the shift team.
Weaknesses -- Security procedure-concerning hand search of hand carried items after alarming explosive detector.
Security and HP interfaces.
-- ' 2.4 Licensee Commitments During the team inspection, the licensee made certain commitments to the inspection team. These commitments relate to licensee V- .: ... . _ _ __-
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l corrective or enhancement actions planned in response to team findings or concerns..These commitments, summarized below, are discussed in more detail in subsequent sections of this report as shown in. parentheses.
Commitments were confirmed during theLexit interview. The status of these issues will be-reviewed by the NRC prior to restart of the plant as appropriate.
2.4.1 . Prior to restart ensure new system operating (S0) procedures that are important to safe operation are.
implemented prior to startup or system operations.
(Section 3.1.6) 2.4.2 Prior to. restart provide your plans and schedule for improving the permit and blocking rules.
(Section 3.1.7) 2.4.3 prior to restart complete response to LaSalle BWR Power Oscillations NRC Bulletin 88-07. (Section 3.2.7) 2.4.4 .By May 31, 1989 provide schedule for development and
- implementation of revision 4 of the Emergency' Procedure Guidelines. (Section 3.2.9)
2.4.5-Beginning in July 1989 and continuing for two years, provide semi-annual human resource status reports on , l progress towards meeting operator resource developmerit and cultural'related commitments.
o Career paths and off-shift rotational assignments for operations staff. (Section 3.2.3 and 3.3.4.2).
o More comprehensive operations newsletter which would include explanations for decisions on policies and programs that affect operations - staff, status on resolving issues, concerns, recommendations, and other pertinent information.
(Section 3.3.3) o Improvement on quality and timeliness of communications and feedback loops. (Section 3.3.3) o Improving consistency between shift crews in implementation of policies. (Section 3.3.4.1) o Increasing the number of licensed operators towards the goals of 42 on shift and 85 total licensed experienced personnel (Section 3.2.3).
o Implementing interaction training for licensed operators and non-licensed personnel. (Section 3.3.2) o Incorporation of parts of PFE/PE training into operator progression training. (Section 3.3.2) _- - - - - -- - - _ - - _-. _ ___
_ _ _ _ ------ . 112 - 2.4.6 Prior to restart provide to the NRC a revised commitment' .regarding the schedule for implementation.of follow-up Interaction Training for licensed operators and non-licensed - personnel and for incorporation of parts' of PFE/PE training into: licensed operator progression ~ training.
' (Section 3.3.2) 12.4.7-Prior to restart provide to the appropriate HP technicians orientation and training in.the area of Peach Bottom' power . operations experience and radiological expectations.
(Section 3.5.2) 2.4.8 . Prior to restart review torque switch settings.for.
Limitorque motor operated valves settings below the vendor recommended values. (Section 3.6.2.8) " ja : 2.4.9: Prior to. restart provide the results of a review of-instrument air tubing and support installations and show that the root cause of analysis of modifications . adequately encompasses the installation deficiency.
is (Section'3.7.3.1) 2.4.10 Prior to restart demonstrate the operability and maintainability of the' Emergency Cooling Water System.
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3.0 DETAILS OF INSPECTION 3.1 ' Site Management / Operations 3.1.1-Scope of Review i The team assessed the organizational structure including site management effectiveness currently in place at Peach-Bottom Atomic Power Station. Areas reviewed included: -(1) interviews with operations personnel,. both licensed and non-licensed, as well as operational staff and management;- (2) around the clock shift coverage to ascertain operations conformance with operating and administrative procedures; (3) review of procedures to assure conformance with NRC requirements. 'The team also attended management and staff- - meetings, as appropriate,-to determina how present and future. licensee plans are applied to Peach Bottom operations.
During the course:of plant tours, event follow-up, interviews with personnel and meeting attendance, the team emphasized management leadership, conduct of operations, Plant Operations Review Committee, procedure compliance and adherence, staffing-and overtime controls, operator attentiveness and attitude, operator insight and worker perception of management policies, involvement, effectiveness and their resulting impact on; reactor safety.
, j ! 3.1.2 Management Team / Leadership ] The team assessed the organizational structure in place at the Peach Bottom Atomic Power Station (PBAPS).
Interviews'
were conducted with station management including Shift ' Managers, Assistant Superintendent of Operations, Superintendent of Operations and Plant Manager. The administrative process i currently in place to coordinate and control the activities and i action affecting the safe operation of the facility was also - assessed.
! The team attended several management meetings to assess the j interactions of managers and the effectiveness of the ' policies and procedures being implemented. The management overview in the areas of. policy setting, awareness of current plant activities and continual oversight of policy changes that were incorporated by PECo in the " Plan for Restart of PBAPS" were found to be effective by the team.
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1 .The team interviewed managers,' supervisors and operational staff members to determine current attitudes regarding operator morale, current shift rotation, promotional-opportunities, communications within and outside of- , ' ' operations, training, and general overview of the current ' . operational philosophy. The results of these interviews are . discussed in section 3.3.
After the Shutdown. 0rder' of March. 31,1987, the licensee-replaced management throughout the station and in corporate headquarters. Dr.e of the changes was the institution of ~ Shift Managers to' replace the Shift Superintendents. The Shift Managers 1were observed during three days of continuous shift observation of shift operations. The Shift Managers-demonstrated good leadership and managerial skills. Evidence'of this~ 1ncluded team building among shift workers, procedural adherence,.and ' '
- communications within the shift and with other departments'
interfacing with the shift operational personnel.
The licensee has.also' incorporated a system of Management by Walking Around (MBWA). The MWBA process' includes tours by managers of'different departments who record and report their-observations. Observations include work ethics of.those working'on plant components, plant housekeeping, radiological protection, industrial safety, and other' important observations.
The' team reviewed MBWA reports for six months. As time prog-ressed, the comments within these reports ranged from general-comments, that were very broad in perspective, to finite state-ments, that were more specific. This trend-indicates that plant conditions have improved by this management method. The team also noted the improved material condition of the facility.
Improvements in housekeeping and radiological cleanliness were evident throughout the entire plant.
,, 3.1.3 Conduct of Operations The team reviewed the Operations. Management Manual and Operations
Manual which were issued in August 1988.
These documents describe the organization, accountability, responsibilities, and communications for the operations department. These manuals specify in detail how the conduct of operations is to be performed at pBAPS.
The interviews with the operators revealed that this document is perceived, by the operators, to be very useful in informing them of their exact duties for day to day safe operation.
Each operations staff member received a personal copy of the manual.
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During the shift coverage and individual interviews, the. team noted that there.was doubt in the minds of the Shift Managers,
- Shift Supervisors, and control room operators regarding the specific' duties of the Superintendent of Operations and the Assistant. Superintendent of Operations. A memorandum dated December. 23,'1988, was issued by the Plant Manager to' clarify.
.these individuals' duties. However, some confusion still exists which could have an impact on the conduct of operations'. This.
issue is addressed further.in. sections 2.3.2.3 and 3.3.4.1.
3.1.4 Plant Operations Review Committee (PORC)' , Team members attended portions of several PORC meetings to assess the adherence with Technical. Specification and administrative procedural requirements regarding PORC review of. required material. Although no specific deviations of PORC activies from.the specified requirements were identified. the Team noted that there appeared to be a consistent reliance on . - alternate members and alternates to the Chairman to establish quorums'for meetings.
There was also much rotation of the designated attendees for. successive meetings. These conditions .have the potential to detract from the continuity of PORC consideration of issues.
Similar conditions were previously noted by the licensee's Performance Assessment Division in an-April 1988 report to the PORC Chairman. Based on the. discussion at the. station review meeting the-licensee appears to be reassessing the effectiveness of its action in response to the PAD assessment 3.1.5 Shift Staffing and Overtime Controls Team members compared the shift staffing with the required complement as described in Technical Specifications. The members also noted that each shift had more than the required number of operator licenses to operate the facility (see section 3.2 for more details).
l The overtime controls were reviewed by the team to ascertain licensee compliance with the current NRC guidance concerning operator overtime. The team determined that the ovartime policy was being followed and that no operators had exceeded the guidelines.
The actual number of work hours in the documents reviewed, was limited to 16 hours in any one 24 hour period, and i i the most overtime worked on a weekly basis was twelve hours.
The station policy for operators is being changed to limit operator overtime to eight hours per week or 400 hours per year.
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_ __ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ __ _ _ - _ - ' '15 The team observed shift operations during a continuous period of three days. The team conducted interviews with'the operations' department managers,-licensed and non-licensed operators, and' operational staff in order to determine if the necessary procedures,- policies.1nd practices are in place in order _to operate PBAPS safely.
The team conducted tours of the~ facility and visited the operating stations throughout the facility, including the control room.
The team concluded that the. plant was being operated in a professional and safe manner, and that procedural adherence was evident. The team also noted that the plant labelling program has resulted in a positive method-for system, component, and valve identification for new operator training and system blocking for maintenance.
During this inspection,-six team members were assigned to ' ' observe the day, afternoon and. night shift operations for a continuous period of three days. The team held discussions-Lwith shift managers, shift supervisors, control room licensed operators'and non-licensed operators. The team members also accompanied the operators performing their ~ activities including normal operations and system surveillance.
The shift turnovers were orderly, with all pertinent information discussed. The control room wa: maintained in a professional manner by operators that acted with proper demeanor in accordance with the Operations Manual, Operations Management Manual, and administrative procedures.
Logs were kept by all operators in an orderly manner.
Log entry detail was sufficient to provide a historical record.
~ Shift meetings were conducted by the Shift Managers, with the non-licensed operators and the control room. operators and Shift Supervisors in two separate meetings. At these meetings the plans were described for impending shift plant evolutions, including problem areas and current operating conditions. The Shift Managers also relayed information pertinent to overall plant status that were of interest to all shift personnel. Several events were observed during the course of shift coverage and were handled in accordance with the operating procedures; however, several discrepancies were noted (sectiot, 3.1.8).
The observed surveillance are discussed in section 3.6.1.
Communications between shift members and other departments were performed very well. The inspectors did not observe any conditions that were contrary to good operating practices as established by NRC requirements or Operations Management and Operations Manuals.
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During operator interviews, the team members noted that some policy inconsistencies had been present. These include pay for shift turnover time and required reading. However, after discussions with operations management and a sampling of control room operators, the team determined that operators were paid for shift turnover, if they requested it.
Payment of overtime while performing required reading was an isolated incident and the practice was stopped by the Shift Managers.
(J. 6 Operating Procedures and Procedural Adherence The team reviewed operating procedures and operations department procedural adherence and compliance.
Included in this review was the status and assessment of the new, system operating (50) procedures. These new S0 procedures replace the previous S procedures. At the time of-team inspection, 18 of the 57 S0 procedures had been implemented.
The team assessment of the licensee 50 procedure rewrite project included a review of the following items (see Appendix C): -- Procedure Writers' Guide, -- Schedule of 50 procedure implementation, -- Walkdown of emergency service water (50 33) emergency cooling water (S0 48), and standby liquid control (S0 11) system procedures, 50 review and verification process, and -- Interviews and discussions with operations -- support personnel, procedure writers and operators personnel.
The team also raised two concerns regarding the new S0 procedures: (1) the schedule for completed implementation of all plant systems is late May 1989; and, (2) initial operator training in or knowledge of the procedures.
Two systems that are scheduled for procedure implementation after startup are HPCI and RCIC.
The team performed a walkdown of the S procedures for the RCIC. No unacceptable conditions were noted. The team observed implementation of various diesel generator S0s (see Appendix C). Overall, the operators adequately implemented the procedures.
However, the operators demonstrated a misunderstanding regarding 50 procedural references that either still exist as old S procedures or that do not exist as approved procedures.
In discussions with operations personnel, it was noted that although some training had been given, it was not complete or specific.
In further discussions with operations management, the team pointed out the need for operators to be kept informed of these tpgrades. The management concurred and has agreed to _ _ _ _. _ - _ _ _ _ _ -
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. correct the problem by disseminating a required reading list of-changes (see section 3.2.5).
The team concluded that the schedule for S0 procedure implementation was a weakness. The licensee agreed to change the schedule to ensure 50-procedures are available .for-system operation _ prior to restart (see section 2.4.1).
The. team observed operating procedure compliance by both non-licensed and control. room licensed operators. This E included use of both the new S0 procedures and the old S procedures. Overall conclusions were that. operators effectively use operating procedures. No specific concerns were noted.
.- There~were.a.few weaknesses noted in one of the Standy Liquid Control S0 procedures' evaluated. The prerequisites section refers-to several S0 procedures which do not.yet exist because the>old S procedures for these systems have not yet.been rewritten.
Steps 4.7 and 4'.14 of 50 11.1.A-2 direct operation of a poison . tank temperature ' controller (HS-2-11-121). The component this .apparently refers to is labelled Tank Heater Manual Switch and numbered 11-1-1.
Step 4.141also has the tank' tensperature gauge incorrectly labelled as 046 vice 048. Step 4.9 directs raising tank temperature to 150 degrees F, but is followed by a note to maintain temperature between 100 and 120 degrees F.
The temperature gauge on the tank'(TIC-2-11-048) is only graduated to 120 degrees' F though apparently someone attempted compliance, - with the procedure by hand scribing on the gauge face in pencil, additional graduations to 150 degrees-F. These discrepancies-were discussed with licensee personnel and corrective actions were initiated.
Based on this review, the. team concluded that the.S0 procedures are an improvement over the previous-S procedures. The 50 procedures are well written and have better human factors elements. Operators appear to be satisfied with S0 procedure usability to operate plant i systems. Specific concerns with S procedure adequacy were related to system lineup after implementation of the shutdown procedure. Upon system startup, the valve lineup may be incorrect.
The concerns are further discussed in section 3.1.8 of this report.
The S0 procedures are generally considered to be an improvement over the S procedures. They appear to be more detailed and provide more explicit guidance to the operator.
The checkoff list correctly identified all valves as labelled in the plant even though the Piping and Instrument Drawings (P&ID) print showed three valves mislabelled.
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Overall, the new S0 procedure usability and quality are , considered to be a strength.
3.1.7 Tagouts and Operator Aids As a result of the interviews with the operators, the team determined that the operators were not completely satisfied with the current blocking system at PBAPS. A review of the blocking system determined that the system was cumbersome and there were inconsistencies in its application. The team noted that in several cases "Information Tags" were being used as "Do Not Operate Tags" by writing on the tag "Do Not Use".
The inspector also noted that the "Special Condition" tag and " Temporary Clearance" attachment were being used in order to perform operations of components within a blocked system. Use.
of these tags is permissible by the current system but the time duration of the issuance of these tags is indefinite for the former and seven days for the latter. This practice permits operation of components and does not document, to the operator, the current component position, or the component position at the end of the working day.
During discussions with station management, the team was informed of a company initiative to improve the blocking and tagging-system for pECo.
The Operations Superintendent of Limerick Station has been named to head the task force. The licensee agreed to provide the plans and schedule for improving the permit and blocking rules. (Section 2.4.2) Operator aids are used throughout the station.
They are in the form of simplified diagrams of the system and are positioned next to the system controls.
These diagrams are controlled documents and are H t up to date by the document control group. These diagrat allow the operator to trace out the system being operated prior to its operation and give information for controlling the system.
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3.1.8 Event Follow-up Unit 2 Seal Steam System Startup problems During the afternoon shift on February 5,1989, the licensee determined that the startup of the seal steam system per procedure S.6.3.2.A could not be performed because three valves were out of the positions required by check-off-list (COL) S.6.3.2.A-2.
The licensee determined the COL had been performed on January 22, 1989, and condenser vacuum was established. On January 26, 1989, feed pump testing was suspended and the vacuum was broken per S.11.2 Q.
When the shift supervisor determined that the system was not correctly aligned, he ordered a complete system COL to be performed.
Further licensee follow-up determined that the COL performed on January 22, 1989 had corrections to valve numbers and other minor errors. These nonconformances were corrected in accordance with procedures and were reviewed by an SRO and a i ' PORC member. Also, the licensee determined that system shutdown per S.11.20 did not specify which valve to close. When system startup was attempted on February 5, 1989, the system was not , aligned as required by COL S.6.3.2.A-2.
The licensee initiated l procedure changes and held a critique.
The team was on shift when this problem occurred. The team reviewed the shift's immediate corrective actions to determine system status. The team concluded that these actions were timely and effective.
The team also attended the critique on February 6,1989 and reviewed operations incident report number 2-89-05.
Licensee corrective actions included forwarding changes made to "S" procedures to be included in the "S0" procedure rewrite project, providing a description of the event in the operations newsletter and resolving the COL nonconformance issue.
During the review of this event, the team learned of a similar event that occurred in the hydrogen seal oil system on November 30, 1988.
The seal oil system was shutdown and subsequently started up.
Inconsistencies with the shutdown and startup "S" procedures resulted in three valves out of position. Consequently, damage occurred to one of the system pumps.
The licensee revised the "S" procedures and included feedback to the "S0' procedure rewrite group.
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! The team concluded that the licensee adequately responded to these two events. Review of S procedure adequacy and the S0 procedure rewrite project is discussed in section 3.1.6 of this report.
Unit 2 Shutdown Scram on February 7, 1989 At 12:51 p.m., on February 7, 1989, a high pressure scram occurred on Unit 2 while in a-cold shutdown condition.
Surveillance testing (ST) was in progress on the Unit 2 B high pressure scram instrument PISH-2-2-3-55B per ST procedure SI2P-2-55 BICO (see section 3.6.1.4).
An apparent leaking instrument isolation valve combined with an isolated reference leg due to modification work resulted in a trip of the A high pressure scram instrument. This resulted in a full scram signal; however, no control rod motion occurred as all rods were already fully inserted.
The licensee implemented T-100, " Scram" and T-99, " Post Scram Restoration". The licensee reviewed the cause of the full scram condition, made an ENS call at 2:00 p.m., depressurized the reference leg and reset the scram signal at 2:05 p.m.
At 3:15 p.m., the oncoming shift supervisor noted that condensate long path valve M0-2-2-38A had dual (open/ closed) position
- indication.
Further licensee follow-up noted that the condensate pump minimum flow valve was in manual and did not open when the long path valves closed.
In addition, the licensee noted that step 5-2 of T-100 required verification of the Group II isolations. At 4:57 p.m., a second ENS ~ call j was made to report this Group II C containment isolation ' valve's apparent failure to close, as required at an indicated 600 psig reactor pressure.
This event occurred during the team's shift coverage. One team member was observing the ST at the instrument rack (see section 3.6.1.4) and another team member was in the control room. The team observed shift follow-up in determining the cause of the scram. The shift initially was unaware that the associated reference leg was isolated for modification work. Their initial assessment was a leaking excess flow check valve. After about a half an hour, the shift ! correctly determined that the isolated reference leg combined with a leaking isolation valve caused the scram.
Additional team follow-up included review of the associated procedures, the computer alarm typer, control room logs, instrument recorders, and the draft and final operations , l incident report number 2-89-06.
Members of team also ' attended portions of the incident critique.
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reviewed motor operated valve testing for MO-2-2-38A (see section 3.6.2.8).
The team identified two concerns: (1) initial slowness of the shift to determine scram cause, and (2) unawareness of the MO-2-2-38A valve failure to close.
Licensee review of these concerns was performed and included in the incident report.
Slow shift follow-up as to the cause of the scram was compounded by the fact that the test approval was received three days prior to actual test performance and that modification work that isolated the common instrument reference line was subsequently initiated. Thus, the shift was unaware that the reference leg was isolated. The failure of the crew to detect the failure of MO-2-2-28A to isolate was caused by the lack of an accompanying alarm and an excessive number of people in the control room during the event.
In addition, the crew was pursuing another problem involving identification of a broken wire found in the E-22 4KV bus room.
Licensee corrective actions proposed in the incident report included the following: determine and repair of leaking instrument valve, - -- -- review instrument valves' equipment history for preventive maintenance, re-instruct I&C technicians on operation of -- instrument valves, test MOVs of M0-2-2-38A and B, including checking -- torque switch settings, revise of the condensate procedure S.7.1.0 for -- automatic minimum flow operation, inspect of 2C condensate pump and motor -- include this event in operator training and in -- particular that the shift missed the MO-2-2-38A valve isolation perform of a HPES evaluation -- review for a possible modification for a 60 psig -- alarm for the condensate long path isolation.
The team concluded that the licensee had performed effective follow-up for this event. Adequate corrective actions were documented in the incident report.
The NRC will follow-up on these corrective actions in a future inspection.
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1 3.1.9 Conclusion The team concluded that the licensee has established a strong site management team which is actively involved in improving the performance of the site staff and the material condition of the facility.
The leadership provided by the Shift Managers has been instrumental in improving the communications within the shift crews and between the shift crews and other site groups.
The guidance provided to the operating staff about their roles and accountabilities by the Operations Management and Operations Manuals is clear and well understood.
Overtime is being minimized and effectively controlled.
The new system operating procedures provide for better control of equipment, and the licensee has committed to complete implementation of those required for safe operation to support restart. Through eifective event critiques, the operating staff has demonstrated its self assessment capability to identify problems and initiate appropriate currective action.
3.2 Licensed Operator Resource Development 3.2.I Scope of Review The team reviewed the current staffing of licensed operators to determine whether the current assumptions and conclusions made in the SER are still valid.
In addition, by conducting interviews with licensed operators and management, the team determined whether alternate career paths and educational opportunities are being made available or planned for the licensed operators. The pipeline for the development of new reactor operators was also reviewed to determine if the commitment to staffing levels could be met and allow operators to pursue alternate careers.
To support this goal, the ability of the licensee's training organization to support the commitment to staffing levels was also assessed. The team evaluated the knowledge level of the licensed operators relative to recent modifications, industry events and procedure changes. Through direct observation and interviews determine whether the operators are following procedures and modifying procedures before they are followed if the operator knows that the procedure is not correct.
3.2.2 Recruiting Pipeline for Operators In order to have personnel available to support a license class for reactor operators, the licensee must have an ! _ _ _ _ _ _ _ - _ _ - _ -
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adequate supply of experienced non-licensed operators to ~ rely upon. The progression cycle to become a licensed operator is Helper, Auxiliary 0perator (AO), Assistant Plant . Operator (AP0) and Plant Operator (PO). An operator.then enters license reactor operator training and becomes an Assistant Control Operator (ACO), qualifies as a Chief Operator (CO) and then enters license senior operator training and becomes a Shift Supervisor. The licensee had hired thirty-five persons with a minimum of-two years of post high school. technical education, U.S. Navy nuclear training or equivalent education and work experience over the last two years. The licensee is not planning to hire any new personnel until the results of.the progression training for the. current-individuals are available at the end of.1989.
After the licensee evaluates the results of the current progression training, the licensee will evaluate the' additional number of persons that must enter the pipeline to support'
staffing levels and career development opportunities.
Based on the number of persons hired and in the pipeline, the. team concluded that the licensee does have adequate staff in the pipeline to provide additional reactor operators for the facility and achieve the staffing' goal developed. The licensee plans to evaluate the results of L the training. program to assure that the staffing level can 'be achieved and maintained.
3.2.3 Staffing The licensee plans to staff six shifts of licensed operators with each shift consisting of a Shift Manager, two Shift Supervisors and four Reactor Operators (RO).
For the six shift rotation plan, 18 Senior Reactor Operators (SRO) and 24 R0s.are the desired goals for the shift complement. The actual number of individuals may be less than the above due to unforseen circumstances, but the intent of the licensee is to have 42 licensed operators to support shift operations.
The currently available licensed operators to man the operating shifts are as follows: 6 Shift Managers -- 12 Shift Supervisors -- 24 Reactor operators (11 licenses limited to cold -- conditions). One R0 may be' added after retaking an examination this spring.
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1 The-licensee has no more than two R0s that have limited licenses per shift team. Thus, the Technical Specification.
requirements for licensed operators will be assured until the operators with limited licenses can satisfy all their license requirements (Number of reactivity manipulations and time.on shift at greater than 20% power). The currently available licensed operators will meet the requirements for shift' l operaticns. However to meet the other goals that are described ' below,. additional licensed operators must be developed.
The licensee has'a goal to achieve 85 license experienced personnel on site as well as to provide career paths for operators. To achieve this goal the licensee requires additional licensed operators. The discussion on career path is found in section 3.2.6.
The licensee currently has a-senior license . operator class ongoing with 7 SR0 candidates to be completed in ' September 1989. These candidates are replacement Shift Manager candidates'. In order,to make available current R0s to enter an SRO license class, the licensee must first obtain additional-R0s. The licensee will start a R0 license class in February 1989 with a completion date of December 1989.
The number of candidates in the RO class was determined by the availability of senior qualified P0s. The licensee determined that in order to safely start up both units, experience available in-the P0s must be maximized. In addition a P0 class will start in February 1989 which will enable another. class of R0 candidates to begin in Septerr.ber 1989 with a completion date of June 1990. The licensee-was also planning to start an SRO class in September 1989 and finish in April'1990, which would allow for the replacement of shift supervisors.
In adition the licensee is maintaining classes for additional AP0s and P0s in the period to support additional licensed operator classes in late 1990.
The team also investigated the availability of instructors to maintain licensee training needs. The training organization is not fully staffed. The licensee does have instructor positions available in the licensed operator training program.
In the long term, these positions are planned as positions available for off shift assignments for previously licensed operators, but currently are not filled because available licensed operators are required to support shift operations.
In the short term the facility may fill these with contractor personnel.
In any event, the currently staffed training organization can support two licensed operator (or shift technical advisor) classes at any one time. The current training schedule may result in portions _ _ _ _ _ _ _ _ _ - - - _ _ - - _ _ _.
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of three licensed operator classes (2 R0 and 1 SRO) and perhaps an STA training course ongoing at the same time.
The facility training staff may not txe able to support such a schedule.
The licensee may have to delay the start of the SR0 class by approximately three months and may have to make adjustments to the STA class, if required, based on the availability of qualified instructors.
The team concluded that the modifications to the schedule will have a minimal impact on the ability of the licensee to achieve the goals for licensed operators.
The team concluded that the licensee can meet Technical Specification staffing requirements and has aggressive plans to provide additional licensed operators to achieve their goal of 42 operators for shift activities, 85 license experienced personnel on site and for career development.
Licensee plans and analysis assumptions for operator progression assume 100% success rate which may not be realistic. The team assumed 85-90% success rates in independent assessments and still concluded that the licensee's goals are achievable. However, off-shift rotational assignments may be delayed in some instances due to a lower success rate. The team concluded that no additional operators would be available for relief of the current licensed. shift supervisors until the SR0s were licensed from the class completed in 1990. The current class of SR0s are planned for the Shift Manager position not the shift supervisor position. Current shift R0s would not have opportunity for off shift rotation until R0s were graduated from the class to be completed in December 1989.
These replacements principally allow on-shift R0s to enter senior licensed operator training, but may allow individual R0s to enter off shift assignments depending on the plans of the two R0s on extended assignment from General Electric.
The current shift R0s will not have the opportunity for off shift rotational assignments until mid 1990. The team also concluded that the SR0 class currently scheduled to start in September 1989 requires rescheduling to January 1990 to assure that the licensee can maintain the goal of 42 licensed operators on shift and have a training schedule that is compatible with the available training resources.
Based on the above, the licensee has committed to provide semi annual reports of the progress made in the area of licensed operator staffing levels, including the pipeline personnel. This will enable the NRC to confirm licensee plans and commitments relative to licensed operator staffing levels. (see Section 2.4.5) _ _ _ - _ _ _ _ _ _.
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l 3.2.4 ' Alternate Career Paths The licensee in its submittals to the NRC described many alternate career paths and off shift assignments for operators including blocking coordinator, electrical supervisor, operations support superintendent, training, quality assurance, outage planning, and other site.and corporate support functions.
The licensee hired a contractor to design and develop a career path program for shift operations personnel at Peach Bottom. The contractor issued a report on its effort and licensee management is evaluating the recommendations provided.. To date, the licensee plans and policies are not formalized to identify to the shift operations personnel'the career paths.available to them. The licensee had also indicated that they-are committed to supporting the career. advancement of i.
licensed operator personnel into positions requiring college degrees ~and were investigating with a~ local university to provide this opportunity for operators. To date the licensee has not yet formalized the college programs.
The licensee has plans to formalize these plans in the spring. The licensee had- . verbally. informed shif t operation personnel of its plans and issued a PBAPS Operations Section Newsletter dated February 10, 1989, indicating that alternate career paths will be available in the future.
The team concluded that the licensee has plans for providing career paths for operations personnel. Because of the limited , number of-licensed personnel to support operations, the licensee will not be in a position to offer alternate career paths until additional licensed operators become available. This is not expected to occur until mid 1990.
In the-interim the licensee can make available college programs to enable operators to further enharce their education. The licensee is developing plans in this area.
The licensee's plans for career development assume that operators will progress from helper to shift supervisor.
There will be some individuals who will not be able to progress to the shift supervisor level. The contractor study recognized this potential problem and provided recommendations in this regard to also further provide career paths, for these individuals to be able to get'off shift work. The team noted that the licensee was still evaluating the contractor report and will address this issue as part of the licensee evaluation process.
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J .Because licensee actions to enhance career development are ' still in the planning phase, with commitments made to the-licensed operating staff only verbally and in newsletters, licensee senior management committed at the exit interview, to provide a semi annual. progress report on licensee accomplishments .in the area of career enhancement in response to team concerns.
(see section'2.4.5).
3.2.5 Required Reading The inspector reviewed licensee activities in the development of required reading for licensed operators. Required reading was enhanced at Peach Bottom.in May 1988. Required reading is
controlled by the Operations Manual and is one of the tools-available to make operators aware of important job related information.
Required reading is the responsibility of the' , Operations Support. Engineer and is planned to be issued once per ' . training cycle.
Included as a part of required reading is a ' signature sheet wherein each person acknowledges that they have read the required reading materials. The licensee is keeping records of the response to the required reading and has set performance standards that 95% of the operators complete the required reading within a ;specified time and not rely on a notification program to denote those persons who are in ar ears on'the required reading. The licensee is also currently evaluating whether information contained in the required reading should be included as_part of material testable during requalification exams.
The types of'information which may be issued as required reading includes new operating procedures or procedure revisions, changes.
to the Operators Manual, plant modifications, incident reports,. industry events, and industrial or radiological safety information.
The team discussed with cperators how they received information ! on the~LaSalle flow oscillation event, modifications on Alternate Rod Insertion (ARI), and modification 1660 to install a safety grade nitrogen accumulator in the drywell.
Based on these discussions, the operators indicated that part of the LaSalle flow oscillation event and modification 1660 were included as part of required reading and the operators were aware of the material. The LaSalle event was also discussed in the simulator and training on the ARI modification has not yet been provided to the operators. The team noted that the new required reading program was a recent iniative and appeared to be functioning adequately.
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3.2.6 Operator Training in Modifications The inspector discussed with operators the training received in plant modifications. The operators indicated that training occurred either in required reading, in discussions with other plant personnel, or during the requalification training program.
The modification training is usually performed after the modification is completed in the plant. Training is provided for a few modifications before the modification is installed such as the reactor vessel level modification. This is because.the modification impacted operation during the installation. The operators expressed concern that they were involved with modifications at the end of the process. They would like to get more pre-installation knowledge mods being installed before installation so that they can assure that the modification will be properly implemented into operations. As discussed in section 3.7.3.1 the new Mod Team process will get operators, involved in the early stage of the modification process. The mechanism for training operators on modifications is principally a Shift Training Bulletin prepared by the System Engineer.
3.2.7 Licensee Activities Associated with the Lasalle Event BWR Power Oscillations (Bulletin 88-07) The team reviewed the licensee activities associated with responding to NRC Bulletin 88-07 Supplement 1 BWR Power Oscillations. The team reviewed documents listed in Appendix C.
Based on team review of the documents the facility has not yet fully implemented the bulletin requirements in procedure OT-112 in that the procedure does not direct the reactor operator to manually scram the reactor if thermal hydraulic instability occurs while in region A,B or C.
Evidence of thermal hydraulic instability consists of APRM peak to peak oscillation of greater than 10%, periodic LPRM upscale or downscale alarms or as indicated in SIL 380, Revision 1.
The OT does not address the APRM oscillations or the LPRM alarms. The licensee indicated that the modifications would be made in the revision of the OT which was currently being performed. This inspection was a partial NRC review of the licensee activities to respond to the bulletin and further NRC review is required, especially the facility documents pertaining to single recirculation loop operation. The Bulletin remains open and must be closed prior to any restart.
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3.2.8 : ' Procedure Changes-i Based on interviews with reactor operators and observations 'inLthe field, the team determined whether the operators were following procedures and when procedures could not be followed l whether the required procedure changes were made before the - procedure was used.
.. The team noted that there was a clear philosophy in the .0perations Department to follow procedures.
The Superintendent of Operations in his newsletter to the l.
station dated January 27, 1989 reiterated his perspective on-procedures and procedure compliance. The operators were observed during. the shift work coverage to follow procedures and were not hesitant to'make a procedure change when a change was required.
Based on the above, the team ' determined that the station has awareness in the importance 'of' complying with procedures and are applying that policy.
.The' licensee has recently improved communication between the Operations Departm.ent and the Training Department by use of a Operations / Training Management. Committee which plans to meet every two weeks. One of the_ purposes of the committee is to- ' determine the'best method of training,for a specific issue. The committee would du ?rmine whether required reading, night orders, requalification tre sning in the class room or simulator is the best way to conduct the training and also determine if the training needs to be-factored into the replacement training program. The committee has on their agenda for the February 27, 1989 meeting, the issue of determining the method to train the.
operators.on the new S0 procedures.
Thus, the licensee has plans'to address this issue.
3.2.9 Transient Response Implementing Procedures (TRIP) The team reviewed the status of the licensee efforts to revise the TRIPS to implement revision four of the General Electric Emergency Procedure Guidelines.
In addition, the team reviewed the licensee's actions taken in response to the NRC Inspection 277/88-200 and 278/88-200 as documented in licensee letter dated January 26, 1989, concerning the Plant Specific Technical Guidelines (PSTG) and containment pressure control by use of the standby gas treatment system.
l The licensee is addressing the specific concerns identified in the previous NRC inspection and is revising the T-200 procedures and reverifying these procedures.
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__ _ _- 31-The licensee's schedule.for implementing revision four of the Emergency Procedure Guidelines may be impacted by; l several issues or events. These include activities ' associated with the NRC's Station blackout' rule, NRC workshop; ~ meetings scheduled for March 1989 on. emergency operating procedures, a recent NUREG/CR on flow chart development and a l' desire to coordinate flow chart _ format with the Limerick Nuclear l Generating Station. As a result,-the facility was requested ~ ' to submit by May 31,--1989,' the schedule for implementing revision four of the Emergency Procedure Guidelines'..The team encouraged the licensee to be aggressive in' implementing o revision four of the emergency procedure guidelines. (see Section 2.4.4.)- The licensee is planning to issue a procedure on providing capability to vent. containment during a station blackout and has also requested engineering to provide a modification to f:'rther enhance this capability. Thus the facility is prog-ressing in response.'to the previous NRC inspection report in this area.
The. inspector. discussed the PSTG concept with the licensee and provided clarification on what was an acceptable PSTG.
Licensee plans will be modified to assure that a document exists which is in format identical to the. emergency procedure guidelines with Peach Bottom specific data included in'the ' document.
The one additional concern that the facility needs to address is having a unit specific TRIP procedure rather than a joint TRIP procedure for Units 2 and 3.
The licensee is developing separate unit procedures for S0 procedures. The team expressed a concern that unit specific TRIP procedures should also be developed to minimize the potential for operator error.
Licensee plans in this area were not firm.
In conclusion, the lhensee is aware of issues and progressing on the resolution of the issues in implementing revision four of the emergency procedure guidelines.
i 3.2.10 Conclusions The li.censee identified in the restart plan that one of the root causes for the shutdown order was that the company failed.
to initiate timely licensed operator replacement training programs.
The team concluded that the licensee is taking steps in this !
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regard, but the results of these steps will only be seen'in the future. The licensee has the number of licensed operators needed to support safe operation but will not see the results of the L replacement training program until mid 1990 when the currently licensed operators can begin to come off shift work and pursue alternate career paths in the PECO organization.
Licensee policies on alternate career paths are not formally documented but only verbally discussed and contained in ' newsletters. The team has confidence that the licensee will carry out the plans as stated and that the plans discussed with the licensee are consistent with those formally stated in the restart plan. However, due to changing conditions and depending on the success rate of the training programs, licensee accomplishments in these areas Jnay not achieve current expectations.
Therefore, the team concluded that the licensee necded to provide a periodic report of the progress on staffing and career development to the NRC.
Licensee senior management agreed to provide such information every six months over a two year period beginning July 1, 1989.
Based on the commitment to provide this information, the team concluded that licensee activities in this area are adequate.
3.3 Cultural Change 3.3.1 Scope of Review The team assessed the changes in station culture since the Shutdown Order and evaluated policies, programs, and processes that have been put in place to effect these changes. To accomplish this, interviews (see Appendix B) were conducted with operations personnel, other station personnel who have key interfaces with operations personnel and organizational development and human resource staff and consultants.
These PECo personnel included managers (corporate and site), supervisors, and staff. Members of the team also attended relevant meetings and reviewed pertinent documents.
The observations and interviews of a cross-soction of personnel at all levels of the organization provided information on human resource policies, communications processes, teamwork activities, results and effectiveness of organizational development interventions, including specialized training programs, and changes in the attitudes and culture of station personnel.
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_ _ - _ _ __ _- . 33' < l 3.3.2 7 Teamwork-Activities and Specialized Training. Programs-The team evaluated the effectiveness of teamwork activities and _ specialized training programs for enhancing culture change by interviewing both recipients and providers of' these' initiatives, by observations (see section 3.1), by attending meetings,_and by reviewing syllabi and program =
- plans.~
~ Teamwork and' specialized training programs are provided to all levels of-the organization by the plant and corporate . organizational development staffs whose activities _ include: team building' sessions within and between -- work groups and with all managerial levels, assistance with interface meetings between -- work groups, . assistance and feedback on the structure'and -- conduct of meetings, l . individual consulting / coaching, -- assistance and feedback at simulator team -- training, assistance-with the development and- --. implementation of specialized training l' programs / workshops, incorporation of an organizational ' -- development activity in site management staff meetings, and assistance to the PB-TEAM (Peach- -- Bottom-Together Employees And Management).
. Interviews with a cross section of personnel at all levels of the organization confirmed that team building efforts-have been effective in the day-to-day operations.of the plant. Building on many of the skills gained from People the Foundation of Excellence (PFE), Managing for Excellence (MFE) and Personal Effectiveness (PE) training programs the shift crews function as cohesive teams for the most part, characterized by a clear understanding of each other's roles ) and responsibilities, pride in their shift crew team, and confidence that problems can be discussed and resolved. The Shift Manager, as the leader of the team, significantly adds to the smooth functioning of the shift crews as teams, by reinforcing team skills and communications, and through his leadership abilities.
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Interviews with-_non-operations staff indicated.that the team concept' has extended to.their interactions with operations staff. Non-operations personnel who interact'with operations, Le.g., health physics and security personnel. rotate with the.
operations shift crew, and this has led to enhanced communi-cations and a greater. appreciation of each other's roles and - responsibilities.
This improved. interface with operations staff has also been reported by non-operations personnel who.do not rotate with the shift crew but who frequently interact with' operations.
> L Severa specialized-training programs have been developed and ' .impleat 4ca or will be implemented to support culture change.
These p vgrams were designed to promote the team concept and~ enhance communications by requiring that personnel from different work groups participate in the training programs at the same time. Thiszwill help ensure that there is consistency in the~ < acquisition ~of' skills, knowledge and in application throughout . the nuclear group.
For example,'on the supervisory level, there t are training programs that are being provided across all work groups such as'the Management Action Response Checklists (MARC)_ employee relations training designed to provide consistency in the handling of grievances, in_ counselling and disciplining employees, and in making selection / promotion recommendations.
MARC training.also provides an orientation to company policies, r: procedures and rules.
Interaction Management (IM). Training-provides supervisory level employees with the needed. skills to
effectively interact with subordinates and peers in a variety!of-situations. An Interaction Management Support (IMS) program is designed to provide managers with skills'to support and ' reinforce the newly acquired skills of the participants from IM Training, r On the staff level, specialized training is designed to provide a follow-up to the PFE, PE, and simulator team training to reinforce the positive changes resulting from those training.
programs and to build on them.
The Interaction program will be provided to the non-licensed and licensed operators and will focus on reinforcing interpersonal skills and team cohesiven.ess.
An Interaction-type training program will also be provided to-non-operations /non-supervisory staff so that all staff become - familiar with the interpersonal skills and communications processes that are indicative of the new culture and the team concept.
In addition, Progression Training for non-licensed and licensed operators who have not had PFE or PE training will be supplemented with appropriate parts of PFE and PE training.
, This program will accommodate new and transferred operators entering the Progression Training cycle and will orient them to the new cultural behaviors.
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35 l Another example of promoting a team concept at Peach Bottom is the PB-TEAM program. The purpose of this program has been to make suggestions to management on improving conditions in the plant and on improving employee morale.
Members are volunteers and are employees of different station work groups. Activities include charitable efforts such as a food drive and donating income from a T-shirt sale to the Make-A-Wish program, a'n employee recognition program, writing a visitor's guide, establishing a task force on professionalism, and sponsoring a station-wide picnic.
Interviews indicated that, for the most part, staff perceived'the PB-TEAM as a positive program. The program helps to improve employee morale as well as providing good public relations in the community.
Teamwork activities and specialized training programs to support culture change have been a focus of PECo attention and resources since the shutdown.
PFE, MFE, PE, and simulator team training were the initial training programs and were targeted toward the operations staff in order to promote changes in attitude and for " rehabilitation" purposes.
In addition, a variety of actions, activities, and programs in support of culture change were focused on the supervisory / managerial staff across the Nuclear Group.
An organizational development staff was hired on a consulting basis to develop and implement the above mentioned programs. Recognition of the importance of this activity continuing over the long term is reflected in the incorporation of a new Organizational Development and Human Resources Department reporting directly to the Executive Vice President-Nuclear.
In addition, the consulting organizational development staff is being replaced with permanent PECo organizational development personnel. This is a strength of the new PECo organization.
As mentioned earlier in the report, the major focus of organizational development activities has been on the supervisor / manager level, and specialized training programs have begun to be implemented for them. A similar follow-up has not yet been implemented on the staff level.
The team considers the lack of timely follow-up training to the PFE and PE to be a weakness.
Although, there have been significant improvements in the attitudes and functioning of the shift crew, interviews indicated follow-up training is needed in order to reinforce these new skills, and to provide similar skills to non-operations staff and to new operators. The Interaction training program and the Progression training program should be implemented as soon as possible.
See section 2.4.6.
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1 3.3.3 Communications Processes The team' reviewed communications processes at the Peach Bottom Atomic Power Station and throughout the Nuclear Group of.the Philadelphia Electric Company.
Documents and schedules provided by the licensee indicated that a number of-meetings are regularly scheduled that involve both station personnel and a combination of station personnel and the corporate nuclear group. There are offrite meetings of 100 nuclear group managers and meetings involving the Executive Vice President-Nuclear and the' 30 top nuclear group managers.
Station personnel are involved in daily station planning meetings, Shift Management meetings, shift crew meetings led by the Shift Manager, and a number of other regularly scheduled meetings.
Interviews with both station and corporate personnel indicated that each of these meetings has an important-function, that they are effective, and that thy are useful.
Shift Crew meetings and Shift Management meetings are considered by participants to be especially effective in communicating the details of day-to-day station business and as a focus for discussing special issues and concerns.
The. team concluded that most of the meetings that are in place at both the corporate and station level are useful and effective vehicles for communication.
In recent months, the need for shift crews to be evaluated at the simulator made it difficult to hold regularly scheduled shift crew meetings and shift management meetings. Those interviewed indicated that this made communication difficult and were very positive about the need to resume these meetings now that the simulator evaluations have been completed. This opinion was expressed by personnel at all station levels and points out the necessity of ensuring that such meetings continue to be held.
Interviews also indicated that, in general, station management is accessible, from Shift Managers up to and including the Vice President, Peach Bottom.
Station personnel also believed that they could speak openly with corporate management when opportunities presented themselves, e.g., at all hands meetings.
Peach Bottom management has also provided a line of communication that allows station personnel to raise issues and concerns anonymously.
This program, "Tell It To The VP", has been used by a number of people and those interviewed generally ! - ___ __ _ _-__ _ - _
.. . .
believed it to be a good way to air problems and to receive attention at a high management level.
Management, both station and corporate, are visible and communicate with station personnel while participating in the Management by Walking Around Program (MBWA). A number of documents were provided by the licensee as examples of reports of observations . made while participating in the MBWA program.
Station personnel also commented that they appreciated seeing upper management in the plant and having the opportunity to speak to them while at their work stations. Some personnel believed that this program is somewhat responsible for reinforcing the idea of good plant housekeeping.
Personnel involved in station operations stated their { willingness to question management or challenge decisions when they were in disagreement with some aspect of the decision.
In addition, they stated that management was open ' to this type of questioning.
Interviews with managers at all levels confirmed that this type of exchange was expected and accepted.
The team concluded that the accessibility of management is a positive force for reinforcing the new culture at Peach Bottom, as is the willingness to question and the openness with which the questions are accepted.
The MBWA program is , i viewed in a generally positive way and should be continued " as a good practice that will also reinforce the new culture at Peach Bottom.
l There are also a number of newsletters distributed at both l-the station and the corporate level.
The Operations Newsletter, for example, provides information that is pertinent to the staff. Other newsletters provide information on daily operations and special issues relevant j to station personnel, All personnel interviewed cited examples of improved working relationships with other groups. This improvement was noted by both those who work in the control room and those who work outside, such as maintenance, health physics, and instrumentation and control.
This kind of working relationship had been of particular concern prior to the ., shutdown of the peach Bottom plant.
The team considers this improved working relationship across station work groups to be one of the best indicators of a new station culture.
Every effort should be made to ensure this continued working relationship.
Special training programs designed to reinforce this aspect of station culture are addressed in Section 3.3.2.
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, When station-personnel were asked how the new operations !: culture was communicated and reinforced by the Superintendent of Operations, most cited the Operations Manual / Operations Management Manual. A number of comments'were offered about the high quality and-usefulness of this document.
They also mentioned that.the manual: is a document that is updated to reflect current station practices and policies.
The team concluded that the Operations Manual / Operations Management Manual is.an effective method of communi-cating expectations to the operations staff and'the management's plan to make the manual a living document is-appropriate.
The communications processes that are in place ac Peach Bottom are valid methods for conveying information.
However, the team's conclusion, based on interviews at all levels of personnel at Peach Bottom, is that a: lack of trust .in management still exists on the part of the operations.. staff-- .and station personnel. This.is~due to a number of factors such as: station history combined with.recent instances, failure to-provide decision rationale, lack of timely response on issues-and concerns, and the quality and timeliness of communications and-feedback loops.
Some information has been,provided about promised career paths but not enough to satisfy the. staff that these commitments will be' met.
(This particular issue is discussed further in section 3.3.4.)
Management needs to explain.the decision rationale for policies and programs that affect staff, and update status on resolving issues, concerns, and recommendations that the staff considers important.
For example, little or no.information has been ' disseminated on the use of an assessment center for evaluating candidates for potential-supervisory positions.
This program is> described in section 3.3.4.
This is an important step.in the continued reinforcement of the'new ' station culture because it indicates management's trust in the staff to deal with such.information in a reasonable way.
Details of the licensee commitment are addressed in section 2.4.5.
3.3.4 Human Resource Policies and Practices l ' 3.3.4.1 Performance Appraisals ) The team interviewed corporate and station management and station personnel at all levels and across disciplines, i.e., health physics, quality assurance, maintenance, non-licensed and licensed operators, with respect to performance appraisals. All of those interviewed stated that they had received at least two
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performance appraisals since the shutdown. Those in management positions indicated that their appraisals included criteria for appraising them as managers. The consensus was that the performance appraisals were fair and that they were a learning experience because they provided personnel with an understanding of where they could improve performance and how to use their strengths. The majority stated that they understood their role in the performance appraisal process and that they had received the letter from'the Vice President of Peach Bottom explaining that role. However, even those who did not recall receiving the letter indicated that they understood that performance appraisals were a two way process whereby they could both learn from the experience and use the information gained from the appraisals in a constructive way.
Those in management posith ns stated that the training they had, received in conducting performance appraisals was useful.
In addition, there was an informal one-day seminar with one of the Organization Development consultants to provide additional information on how this process should be conducted. Two general weaknesses in the performance appraisal system were identified in the interview process.
First there was a lack of consistency in performance appraissis between some shift crews.
For example, performance that may give an individual a high rating in one shift crew may result in an average rating in another. When questioned further, those interviewed stated that there were performance criteria but no performance standards against which to rate them.
Shift Managers indicated that this was an open item on their agenda and they hoped that it could be resolved with the resumption of Shift Management meetings. Once again, this points to the value of this particular type of meeting as a forum for resolving intra-shift crew issues.
The Executive Vice President-Nucicar indicated that the lack of performance standards is recognized as a deficiency throughout PECo and that the Human Resources group will be addressing the problem. A second weakness concerned the Shift Managers' appraisals.
Several were conducted in a short time so that very limited information was conveyed.
In addition, Shift Managers' performance criteria were changed without notification of the change. This was confirmed by the individual who had made that change.
It was his belief that the Shift Managers knew what was expected of them.
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One of the fundamentals of a good performance appraisal process is that both parties, the. appraiser and the recipient of that appraisal, know in advance what the criteria or performance elements are and that there are performance standards that apply'to-all personnel who perform the same duties or tasks.
In addition, little meaningful communication with respect to a persons' job performance can be accomplished in a very short appraisal . interview..The licensee's commitments with respect to these issues are addressed in section 2.4.5.
3.3.4.2 Career Paths and Rotational Assignments One of the root causes of management and personnel problems identified by Organization Development consultants after the Shutdown Order was the lack of career paths for shift personnel.
That is, operations personnel who worked shifts were essentially committed to that type of work as long as they remained at Peach Bottom. After the shutdown, the management of PEco and Peach Bottom made commitments to operations personnel with respect to-both career paths and rotational assignments.
Specifically, when enough operators could be hired and/or licensed as control room operators, those who worked. shifts in the control room would ,. i3 have the option of choosing other career paths within the company, such as training instructors, outage planners, and permit writers.
Another option that was to be. offered was that of rotational-off-shift assignments. These assignments could vary from a.few months to several years.
None of these plans have been implemented as yet. Many of those interviewed understand that they cannot be implemented until there are enough control room operators to replace those who wish to pursue other career paths within'the company.
Even with this understanding, however, there is a general mistrust on the part of operations personnel that management will ever meet these commitments.
The reasons for the mistrust are twofold.
First, the hiring and ! I licensing of new operators is taking longer than anticipated.
l Second, management has apparently not done an effective job of l communicating the status of the issue or its potential resolution.
During the inspection, an issue of the Operations Newsletter was I distributed. While it stated that there were still plans to implement this program, it did not elaborate on this statement.
It merely listed the possible positions that could become available.
Not even an estimated schedule was provided. As previously mentioned, the quality of communications, especially as they i.
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Reasons for decisions' and delays need to be communicated when appropriate.
Personnel.would prefer to see an approximate' schedule with a caveat that there could be delays, than to see statements that say nothing is cast in concrete. The issue of alternate career paths is also discussed in section.3.2.6 on Operator Resource Development. The licensee's commitments regarding this issue ' are addressed in section 2.4.5.
'3.3.4.3 Disciplinary Guidelines and Grievance Process One of the characteristics of the pre-shutdown culture was the lack of clearly defined management guidelines with respect to the implementation of disciplinary guidelines and the grievance process.
The licensee undertook a number of
actions to1 respond to this issue. including a review and . revision of these policies; development of a training ' program for all supervisors and managers on the effective, consistent, and equitable implementation of these policies and other work rules; and. communicating.the new policies to the staff in a manner that would help to ensure that they have received the information. The team noted that a review and revision has been completed, that-supervisors and managers are being trained (via the MARC Training described in section 3' 3.2 of this report) on the implementation of . these policies and in carrying them out in a fair, consistent and equitable way.
However, interviews indicated that there is some confusion as to whether the guidelines and grievance policies were disseminated.. As part of the licensee's commitment to improve communications and feedback loops (see section 2.4.5), it plans to distribute the new policies in a way that helps to ensure that every staff l-person has received them and has had an opportunity to get clarification, if needed.
3.3.4.4 The Assessment Center A negative finding in the root cause assessment of the PECo culture was a lack of managerial skill as applied to organizational and people management. Many of the activities and actions implemented since the shutdown described in other sections of this report have been in response to this recognized major weakness. One initiative being developed to help ensure competent, qualified supervisors, is the assessment center-based selection system. As described to the team in interviews and in _ _ _ _ _ _.. _. -_ __
_ _. - < 42-i descriptive materials,: future applicants.for supervisory positionsiin' maintenance, health physics,. operations, and other departments will be evaluated through an assessment program designed for the target positions that is-job performance based.
Candidates for supervisory positions will be selected on the basis of. assessment center evaluations and seniority.
The team concluded that the assessment center selection system, as described, is a valid method for evaluating personnel forfsupervisory positions.
3.3.5 Conclusions The team concludes that there.have been significant positive changes in the Peach Bottom culture. This. conclusion is based on the evaluation as described above.
Improvement in the culture is reflected in the atcitude toward safety, quality, and professionalism; by the variety of e communications processes; by the cohesiveness of the shift crews; by the acceptance of the team concept both within and-across station work groups; and by the continuing commitment to support organizational development efforts-and specialized training' programs.
However, there are some aspects of the station culture that-need to be strengthened. These include the. quality and timeliness of communications and feedback loops, consistency-among shift crews in carrying out policies, and the ' , implementation of Interaction and Progression Training programs.
Licensee commitments in this area are considered to be appropriate and-are' identified in section 2.4.5.
.3.4 ' Corporate Oversight 3.4.1 Scope of Review One of the root causes identified by the licensee for the conditions that led to the shutdown of Peach Bottom was that corporate management failed to recognize the severity of the problems and did not take significant corrective actions.
The licensee established responsive corrective action objectives to (a) increase the control, accountability, and corporate direction of the Nuclear Organization, (b) strengthen self assessment and problem resolution capabilities, g' and (c) strengthen the independent assessment process. These program changes, as described in the licensee's restart plan, l were reviewed by the staff as reported in its Safety Evaluation
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Report dated October 19, 1988. The team assessed the functioning of the licensee's management' organization as it relates to providing.for the corporate oversight of activities at the Peach Bottom Atomic Power Station. -This assessment considered the functions of the Nuclear Performance Management program, the Nuclear Review Board,.and Operational Event Assessment Program, the Commitment Tracking Program and Nuclear Quality Assurance, ' as they relate to the handling of a selected group of issues.
-The inspection of these: issues included adequacy of: organizational interface, line. organization self assessment and independent-oversight assessment. Numerous meetings have been established at all levels of the management organization to communicate, to plan and to execute the work of the organization. Observations of selected meetings were made by team members to augment findings and conclusions regarding effectiveness of the organization, - management controls and communications. The. Team members interviewed a cross section of management at many of the levels of station'and corporate management to determine if the overall ! attitude and the level of performance with respect to safety has improved.
The scope of the review:for Nuclear Quality Assurance was to assess the effectiveness of the organization for Peach l - Bottom through a performance oriented inspection of the ' licensee's organization, procedures,. staffing, audits and surveillance.
Particular focus was given to the' licensee's self assessment and evaluation capabilities from the effectiveness of the ISEG and HPES.
This assessment included interviews and meetings with station personnel from supervisors to senior management. Observations were made to assess the general processes for dispositioning issues and the relationship of group actions including interfaces with other involved groups. The team members reviewed documen-tation defining the mission of selected programs and organi-j; zational groups and compared findings with the treatment given to the selected issues to determine consistency. These observations and interviews provided the team with insight into the licensee's staff assessments regarding the adequacy of resources to achieve assigned objectives, clarity of their scope of responsibility and mission definition, and their overall morale and attitude toward safety.
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3.4.2 Nuclear Dedicated Organization / Management Authorities and Accountability The NRC staff noted in the SER tha't the licensee has revised its organizational structure such-that a completely self contained corporate Nuclear Group was created'which has responsibility for the Peach Bottom Station and the Limerick-Generating Station..This major corporate reorganization was implemented by the licensee in' January 1988 in accordance with an.NRC Temporary Waiver of. Compliance from the organizational structure previously described in the Administrative Controls' section.of the Technical Specifications. Additional changes.in senior management personnel occurred'in the spring of 1988 and' this organizational structure change was approved by amendment to the Technical Specifications in June 1988. The discussion that follows does not describe in detail the entire organization, !
s focusing'instead on that portion ~that affects the areas being evaluated during this inspection.
The team noted that the licensee has reduced the number of management levels from the first line supervisors to the' Executive Vice President-Nuclear (EVP-N) and has established a corporate management position on site, the Vice. President-Peach o l Bottom Atomic Power Station. The EVP-N has the Vice Presidents for Peach Bottom and Limerick, the General Manager-Nuclear Quality Assurance, and the Vice Presidents for Nuclear Engineering and Nuclear Services reporting directly to him. The station Vice ' Presidents are located on the Peach Bottom and Limerick sites while the Vice President for Nuclear Engineering and Nuclear l Services and the General Manager-NQA are located in the corporate offices in Philadelphia.
The corporate offsite safety committee, the Nuclear Review Board, and the Organization and Management Development (OMD) group report directly to the EVP-N.
The plant staff on site safety review committee, the Plant Operating Review Committee i <. (PORC), reports directly to the Plant Manager. The reporting l' " relationships are appropriate based upon these organizations' mission and responsibilities. Details on these groups are found in section 3.4.6 of this report for the NRB, section 3.1.3 for i PORC and section 3.3 for OMD.
The Vice President Nuclear Engineering has four managers reporting to him through the Manager-Nuclear Engineering.
These are the Managers for Engineering, Project Management, Engineering Design, and the Construction Superintendent for Limerick Unit' 2.
The Vice President-Nuclear Services has four managers reporting to him for Nuclear Maintenance, l-Nuclear Support, Nuclear Training and Nuclear Administration.
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The General Manager-NQA is a member of the senior nuclear management team. He has five managers reporting to,him-including those for the Peach Bottom and Limerick Station.
,_ Quality Groups which are located on site, the Independent L Safety Engineering Group part of which is currently-located L on site, and the Performance Assessment and Quality. Support' groups. located in the corporate offices.
The Peach Bottom' Station Ve President has three managers-reporting to him: the Plant Manager, the Project Manager and the Support Manager. The' site Training Superintendent also reports to him. This station organization represents a substantial-change from the previous organization. 'It was instituted to shorten the chain of communication of.. station L concerns to corporate management,.to narrow the span of control and responsibility of the Plant Manager by providing L managers for other functional areas, to implement the concept of the Shift Manager for improved control of shift activities and to provide additional personnel resources to deal with current needs.
The team concluded'that.the current overall organizational structure provides for much improved distribution of responsibilities and accountabilities. The evidence for I? 'this. conclusion is based in part on the team's. observation of work conducted in meetings at' various levels of the organization dealing with areas as diverse as modifications, the startup Master Open Items List (MOIL), the NRB and PORC, the shift turnover meetings, the Vice President's weekly staff meeting and the monthly EVP-N station review meeting.
The basis for this conclusion also includes information - provided in the NQA audit-and investigation reports, the station status reports and the station performance indicator reports. The licensee plans to make further changes in the organization as needs evolve in the future.
3.4.3 Corporate Management Team and Accountability of On Site Employees The team also concluded that the improved specification and redistribution of organizational functional responsibilities and increased depth of management greatly improves the licensee's capability to support safe and reliable operation of the facility. The evidence for his conclusion thus far is based on observations of senior management's leadership and effectiveness in creating a much improved climate for more open, straightforward communication, an improved sense of accountability-and improved performance in the functional areas described throughout this report.
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I 3.4.4- . Nuclear. Performance Management Program The NRC staff noted in its SER that the licensee had committed to establish a program that would define performance goals and standards for each nuclear line organization' and develop per-formance indicators to compare realized performance against the goals.
The team observed that such statements of the vision,. mission, objectives and goals have been prepared and are visible in posters , distributed throughout the on site offices. The statements are particular to the Nuclear Group and to each of the five Nuclear Group organizations.
For example, the Nuclear Group's statement for 1988 expresses its vision and mission as to be recognized . and respected as a leader in the' nuclear -power industry and to generate electricity safely, reliably, economically in the pursuit of. excellence. The objectives relate to providing the necessary' management direction, staffing and resources, the corporate reorganization, the restart of Peach Bottom, and open candid and cooperative relationship between PEco and outside agencies, the promotion of cultural change and craft training programs.
Over a dozen quantitative performance indicators are also included which include operations.and radiological safety-issues.
Similar statements exist for'the Peach Bottom Station, 'NQA and the Nuclear Engineering and Nuclear Services Divisions.
-The progress in meeting these goals was reported to senior management in quarterly progress reports during 1988.
The licensee's-development of performance monitoring has resulted in a' comprehensive set of indicators which reflect performance in virtually all station activities. The data for.these indicators are prepared by the various levels of management and are reviewed monthly in the EVP-N station review meeting.
Team members attended this meeting on February 13, 1989, and observed the licensee's discussion of performance indicator results based on the 125 page document prepared for that meeting. The meeting was conducted in a very professional manner. All attendees were well prepared and responsibility and accountability for the many areas addressed was clearly understood.
The information provided by the performance indicator report in connection with the preparation and accountability of attendees facilitated an efficient focus on performance and supported I management reinforcement or redirection as needed.
The issues tracted by performance indicators as reported in the monthly station review meeting on February 13, 1989, were _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
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L numerous and included the status of' maintenance, modifications, surveillance and routine testing, open items for startup and.
engineering activities. Additional key indicators also. included collective radiation exposure, number of personnel: contaminations, s volume-of radwaste, plant contaminated surface area, temporary plant alterations, commitment tracking program items, NQA
findings, QC inspection, LERs, station personnel overtime, L staffing status and INP0 accreditation renewal.
.A quarterly ' management. summary report is also prepared to communicate ' F performance indicator results.
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The team concluded that the Nuclear Performance Management ' Program,'particularly the performance indicator reporting-program, is a useful tool for management self assessment. ~This conclusion is based on the comprehensiveness of the data included in the program and the facilitation of management focus on performance that the data permits, particularly in the monthly station review meeting ~. 3.4.5-Nuclear Review Board (NRB) The NRB is an independent advisory group responsible for the review, audit and evaluation of both technical and organizational matters pertaining to the safe operation of- 'the Peach Bottom plant as well as the licensee's other nuclear facility. The NRB reports directly to the Executive Vice President-Nuclear (EVP-N).
In addition to its periodic reports to the EVP-N, the NRB Chairman meets with the Nuclear Committee of the Board (NCB) on at least an annual basis. Membership on the NRB is composed of six senior licensee management personnel and three qualified individuals from external organizations.
The team reviewed the NRB Charter'(revision 11) and associated procedures, Technical Specification 6.5.2, and meeting minutes from March 3,.May 5, July 14, September 1, November 3 ano 9, 1988, and January 5, 1989. Several team members had previously attended the majority of these meetings.
The NRB was reconstituted and revitalized early in 1988 by elevating the direct reporting relationship to the EVP-N, by broadening the represented organizational areas and expertise, and by enhancing the meeting processes and scope ' of review. The current membership is stable and has not ! been changed in the last year. Only one member holds line , . _... _ _ _ _ _ _. _ _ _ _ _. - _ _... _ _ _ _._
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= l .. E i responsibility for operation of the station. The team was provided with biographical information indicating.the experience of the current members and concluded that the~ members meet the Technical Specification requirements and that the NRB collectively possesses a broad based level of. experience and competence...The three non-licensee members bring a particularly useful perspective and questioning attitude'to NRB deliberations. NRB currently conducts meetings'approximately once per. month alternating between the Limerick and Peach Bottom sites. -The:resulting ' bi-monthly meeting frequency at Peach Bottom in 1988 is'well-within the' Technical Specification requirements.
A strong.NRB. involvement in station' activities is evidenced by the scope and depth of recent meetings, the high level of . support provided by all Nuclear Group departments and in . scheduled plant tours..Some prominent personnel that attend 'NRB meetings are Plant Managers, Superintendents, Shift Managers, and Nuclear Engineering Division, Nuclear Support-and NQA personnel. Minutes of the meetings are very thorough and well prepared. The NRB relies on NQA for the conduct of the audits and for the review of safety evaluations-required by. Technical. Specifications.
Reports on these activities are made by NQA representatives at the NRB meetings.
f ' The NRB systematically categorizes and tracks items of concern as " agenda items",'"open items", er " items of continuing interest". Open items are handled in accordance with an established NRB procedure and are tracked until.
closed. Actions required of other responsible organizations to resolve an open item may be entered into the Commitment Tracking System for follow-up. A summary report of each meeting is submitted to the EVP-N and is distributed to the CEO and to other senior managers.
The team noted that the NRB reviews have been thorough and focused on improving performance in areas important to safety.
Several examples of persistent NRB attention over several meetings to particular issues include the residual heat' removal. system (RHR) and the emergency cooling tower (ECT).
The issue of overall RHR system reliability has evolved from NRB consideration of individual component performances in 1987. At the November 3, 1988, discussion of the RHR pump motor bearing problem, the NRB noted past RHR system problems ___ _-______ ___ -
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such as pump impeller wear ring failure, heat exchanger. floating.
head leakage and motor end turn surge ring clip failure. The NRB requested a further presentation that would address system- - problems in an integrated manner to provide an indication of.
overall system reliability.
The RHR system engineer reviewed the current status of. the. individual concerns in the January - 1989 meeting and concluded that the RHR system has a proven operability record and that there is a better working knowledge : , of the system. Although further follow-up on several items tis- _ required to respond to q'uestions raised in.the meeting. the. team . concludes that NRB concern has enhanced the overall attention given to the-RHR system as an integrated system.
, u The issue of ECT functional testing has been addressed by the =;RB in prior years (see section 3.7.8)'. The.
reconstituted NRB addressed the issue in its. March and May 1988 meetings. Upon receiving attention by the EVP-N it was-sugg'ested that the Unit 2 and Unit 3 emergency cooling water systems should be tested, not just the Unit 3 system as had been previously recommended. At its November 1988 meeting the NRB. recommended that a safety evaluation addressing the ~ proposed system test be prepared. ~In the view of the team, this. demonstrated the NRB'.s sensitivity to ensuring'that.the requirements of 10 CFR 50.59 and TS 6.5.2 would be met.
In the January 1989 meeting it was reported that the test conducted in December 1988 was not successfully completed because of ESW booster pump problems and the apparent need for modifications to the pump structure. This issue will be resolved prior to restart as discussed in section 3.7.4 of this report. However, the team' concludes that the NRB's attention to the concern, in conjunction with that of the EVP-N, NED and the plant staff, has been effective in identifying a discrepancy between the prior performance capability of the ESW system in its ECT mode and its design basis.
Baseri an meeting attendance, review of recent meeting minutes, NRB reports to the EVP-N and ether considerations as noted above, the team concludes that the NRB is functioning effectively to provide ar, independent assessment of safety related activities.
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50 3.4.6 Nuclear Committee of the Board (NCB) The NCB has been established to advise and assist the PEco Board of Directors in its responsibilities for oversight of nuclear operations. The NCB consists of non-employee directors from the company's Board of Directors and one or more experienced outside advisors. The NCB's purpose is to strengthen the independent assessment capability so that executive company management and the' Board of Directors receive timely information about nuclear operations. As noted in its safety evaluation report the NRC staff recognizes that the NCB goes beyond regulatory requirements.
The team reviewed the NCB mission statement and minutes of recent meetings. The NCB is a standing committee of the board with no more than five non-employee members and meets at least on a quarterly basis. The NCB receives all minutes of.the NRB and meets periodically with the chairman and/or members of the NRB. The NCB also receives other information including the monthly plant key indicator report and the monthly letter report from the EVP-N.
A review of the minutes of meetings indicates that the NCB was briefed on a broad scope of issues which are consistent with those discussed in the plan for restart and the NRC staff's safety evaluation report on the plan, the NRC's SALP report, and NRC Inspection Reports and INPO correspondence.
These briefings were carried out by the licensee's nuclear group management team down to the superintendent level.
Meetings were held one or more d.ays per month through much of 1988.
On this basis, the le 3. appears to be well informed regarding the scope and sign.ficance of safety related activities at the Peach Bottom Atomic Power Station and the NRC staff reaffirms the finding in the SER that the NCB is a useful adjunct to the board of Directors.
3.4.7 Commitment Tracking /0porational Experience Assessmen+, Programs (CTP/0EAP) The licensee has enhor.ced several management self-assessment [ tools by consolidating and strengthening its programs to ' track the status of commitments made to outside organizations and by strengthening its program to capture outside operating experience information and communicate it to the appropriate organization.
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. , l The licensee.has developed procedural guidance for the commitment tracking program (CTP) as. set forth in an Interim ll Nuclear Group Administrative Procedure (NGAP), which was effective on July 1,1988.. This NGAP, establishes the responsibilities, and authorities, process and organizational interfaces for the program. An , . Administrative Guideline, AG-18, provides further guidance for the detailed administration of-the program.
The CTP is designed to track the status of PECo commitments made 'to..or imposed by external organizations such 'as the NRB, EPA, state and local agencies, ANI, INP0 and JUMA and internal organizations such as.the NRB, ISEG, NQA and OEAP.
An overall status of commitments is provided to the' corporate departments on a monthly basis by the corporate - CTP coordinator. A biweekly report is provided by the station CTP coordinator. The program provides for the review of documents, identification'of commitments, their dssignment to a responsible individual and a schedule for response.
This information is communicated periodically to the responsible management including the EVP-N for selected categories of issues in the monthly Station Review Meeting.
The team reviewed CTP records for a selected group of NRC - documents which included Bulletins, Information Notices, Generic Letters and correspondence. The computerized data base for the CTP is,the company wide Quality Assurance Tracking and ' Trending System (QATTS). The use of the filing index and cross reference system requires considerable familiarity with the details of the system.
Nevertheless, the team found that the selected group of-Bulletins, letters, etc., had been tracked as generally intended by the system.
Specifically, it was determined from the CTP file on NRC Bulletin 88-07 that all licensed operating shift personnel had been briefce on the. subject power oscillations within the time required by item 1 of the Builetin. Several instanc::s of delay in the initial entry of data into the system were observed. Several exaraples were also observed of CTP effectiveness in precipitating revisions to overdue commitment schedule dates; however, this did not always c occur in a timely manner.
It war noted that neither the NGAP nor the AG includes specific tir,,eliness criteria for updating overdue commitments.
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' A significant, discrepancy in the reported number of open CTP items was noted when the monthly corporate report and.the site report data for the end of January 1989 were compared.
' The licensee's NQA Performance' Assessment _ Division'(PAD).
performed an evaluation of the CTP/0EAP in December 1988 which1 identified a number of similar problem areas in addition to those'noted above.
Discussions with the Nuclear-Services Licensing Section indicated that several working- -group meetings had been held and that anLaction plan had been developed to respond to the PAD identified' concerns.
~ The team concluded that the CTP is an enhanced effort to - track the_ status of commitments and that it appears.to have the essential basic capabilities and characteristics to- ' function in a useful' manner. _The timeliness, efficiency and user friendliness of the system can be improved significantly by resolution of the issues discussed above.
The team concludes that the licensee should continue its.
efforts'in this regard to further. support self assessment.
The. licensee.has also developed procedural guidance for the - Operating, Experience Assessment Program (0EAP) as set forth on NGAP which was effective on June 15, 1988, and in AG-35 for.further detailed guidance. The OEAP.is designed to capture operating experience information applicable to Peach
- Bottom from external sources such as INPO, NRC Bulletins
, 'Information Notices and-Generic Letters, four categories of General Electric letters, other supplier and architect / engineer reports and from internal sources such as Limerick LERs and Network items.
Each OEAP item is - evaluated and, if applicable, is sent to the site for assignment. When the site evaluation is complete and any needed corrective actions such as procedure changes, traini;g, plant modification have been completed, the evaluation is documented, reviewed by the OEAP coordinator anc closed out on the OEAP. tracking system. The OEAP and > CTP share the same QATTS data base for Peach Bottom. Upon completion of this review any required corrective actions are entered into the data base as CTP items. The status of DEAP items is reported to management in the same report as CTP items.
A review of selected NRC Bulletins, Generic Letters and Limerick LERs revealed that the OEAP assessments were completed and recorded.
Several OEAP actions were noted to l .. _ _ _ _ - _ _ - _ _ - _ _ _ - _
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either be initiated several months-after' receipt of.the incoming document or confirmed.to be complete several months after completion of the original responsive action. As discussed above.for the CTP, the PAD assessment ~found similar instances in its evaluation of CTP/0EAP and the licensing section is pursuing a corrective action plan in l.
response to those concerns.
" The. team concludes, similarly for_CTP, that.OEAP. appears to-function in a useful manner. However, this functioning can ' be: improved significantly by resolution of the issues discussed above and the licensee should continue its efforts in this'. regard.
3.4.8 Nuclear Quality Assurance (NQA) The team assessed the. nuclear quality assurance (NQA) . independence, assessment' capability and' effectiveness to assure quality for Peach Bottom.
Interviews.were conducted with corporate NQA, managers, site superintendents, auditors, QC inspectors,, technical monitors and evaluators. Ongoing work was witnessed, audited areas were assessed to determine audit adequacy, and procedural controls.and coverage were assessed. Organization independence, staffing, self-assessment and feedback to management capability were given particular attention during the team assessment.
.The team concluded that the overall NQA function, although still developing and in need of several improvements, was adequate to support restart. Specific strengths and weaknesses of NQA are discussed in the paragraphs that follow.
3.4.8.1 Organization The NQA organization is described in an organization chart dated January 25, 1989, as approved by the company president and Chief Executive Officer. The team found the organization to be structured and staffed as described in the chart with the exception of the manager of tne Independent Safety Engineering Division who had transferred out of NQA.
The Peach Bottom site' group was in place since the site group could receive management support from the general manager or his designee, the team concluded that the vacancy was acceptable for the interim.
Disenssions with managers ind!.cated that additional minor orgsnilational adjustments, changes (and improvements) were ceiug planned.
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l However, the team concluded that the basic organization as ' structured provided an acceptable organization to effectively implement the Peach Bottom quality commitments.
The NQA general manager was observed to have ready access to the Executive Vice President-Nuclear.
The NQA organization was also observed to have adequate independence to carry out the quality plan for Peach Bottom.
The team concluded that the NQA organization was acceptable to support restart.
3.4.8.2 Procedures The. team found that the Nuclear Quality Assurance Procedures
Manual, dated December 16, 1988, provided an adequate framework to implement the work of the Peach Bottom Quality Division.
Where sampled, the team determined that the procedures were being implemented.
However, problems were identified with QC inspection procedures as discussed below.
During the course of the inspection, several samples were taken to check the adequacy of the existing ~ QC inspection procedures.
The samples taken noted areas where the QC inspection procedures lacked coverage including acceptance criteria.
The NQA Manager had previously recognized in late 1988, that inadequacies existed in the QC inspection procedures and that these procedures needed improvement.
Efforts were initiated to upgrade the Peach Bottom inspection procedures by utilizing the Limerick Unit 2 inspection procedures as a base to work from for the upgrading effort. This work is in progress; however, no target completion date was provided to the team for implementing the inspection procedure improvements. Based on apparent inadequacies in the existing QC inspection procedures, the team concluded that additional management attention would be necessary to assure the quality of QC inspections.
During a meeting the NQA Manager stated that management attention was being provided to assure the adequacy of QC inspections. The team concluded that although the licensee had introduced compensation 0 measu-es to assure the adequacy of QC inspections, the existing QC inspection procedures were considered a weakness in the licensee's inspection program. (277/89-81-01; 278/89-81-01).
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3.4.8.3 Staffing The team verified that position descriptions were available for the site NQA staff down through the responsible senior l engineer level.
Position descriptions were available for levels below the senior engineer for all of the Peach Bottom Quality Division with the exception of the Quality Support . ' Section.
The Quality Support Section Superintendent stated that the position descriptions for his section were being prepared. The position descriptions were also available for review by the employees. The Peach Bottom Quality Division Manager stated that performance reviews had been given to all his employees and are scheduled to be given quarterly in the future.
The Quality Division staff included 66 people at the time of the inspection. The Peach Bottom Quality Division Manager stated that the budget is based on 40 people in the steady state condition with an additional 35 people authorized for outage work.
The Quality Control Section had 43 people; however, the Quality Control Section Superintendent stated that the number of inspectors will be reduced at the end of the current outage to approximately 30 people as the outage workload diminishes.
The Superintendent stated that 19 QC personnel are permanent PECo employees, the remainder are contractor employees. The Quality Control Section was the largest section in the site Quality Division. Through interviews with members of the QC staff and a check of qualifications, the team concluded that the QC section staffing was adequate to perform its intended mission.
The intended reduction in the QC staff after the current outage appeared to be in order based upon the projected reduction in workload.
The Quality Assurance Section (an auditing section) has eleven people.
The section is authorized twelve people.
The Superintendent stated that he is actively recruiting to fill the vacancy with a person with health physics /ruJvaste experierce.
The Quality Assurance Section Superintendent stated that he is a professional engineer with approximately eleven years prior experience; he had been at Peach Bottom for approxirac.tely two years.
The qualifications and experiences of the auditors was assessed.
Seven of the auditors were cor, tractors, two of which were degreed
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1' . ' L engineers both of which were' stated to be engineers in training.to become;-a professional engineer..One auditor-had approximately eighteen years.of QA/QC experience, one had approximately thirteen years QA/QC experience and'of the L remaining, each had.less than six years QA/QC experience.
One of the auditors was.a former licensed reactor operator
at another BWR facility.
The auditor had not been provided-plant. specific training on the Peach Bottom simulator.
The team concluded that the Quality Assurance Section audit staff appeared to be' qualified and staffed to adequately implement the NQA auditing mission for Peach Bottom.
The Technical Monitoring Section has a staff of five people.
The Superintendent is a degreed engineer and has completed his engineer in training examination to become a 'e professional > engineer. He has completed training at GE ~ including' BWR. fundamentals,' systems and simulator training.
One'of the. technical monitors was a shift supervisor at ' 'another BWR, one received operator training at another. BWR, one received Navy reactor training and operator training at a -PWR, and one received Navy health physics / chemistry training and had various work experiences' including being a pipe fitter.
The team noted that there were no detailed qualification requirements for technical monitors, e.g., requirements for vision. During the course of the inspection the Technical Monitoring Superintendent stated that the vision requirements would be established to be equal to that of the licensed reactor operators. The Peach Bottom Quality-Division Manager stated that the technical monitoring qualification requirements would be completed and in place by April 1, 1989.
The team further noted while observing a technical monitor performing control room monitoring that the technical monitor had received no plant specific simulator training to prepare the technical monitor for performing monitoring of Peach Bottom' reactor operations.
The team viewed the absence of this training as a weakness.
.' The team concluded that the technical monitoring staff was a positive initiative to develop an NQA real time performance oriented monitoring capabilf ty.
The organization and staff are new in their function and are ceveloping. The team , l - _ _ - - _ _ _ _ _ - _ _ _ _. _ _ _ - _
_ _ _ _ _ - ____ ___- _ - . .57 t' concluded.that management commitments are needed to provide technical monitors with appropriate plant specific training to assure maximum effectiveness for the. technical monitoring- ' function. Overall, the team' concluded that1for the interim ~ the staffing was adequate. As experience is gained with the-technical monitoring mission, the staffing level will need to be reassessed.
The Quality Support Section technical. staff included six people. The superintendent: stated that two of the technical staff were leaving and that he was posting for an. electrical and mechanical engineer. This section provides support for the Peach Bottom Quality Division 'with staff involvement which includes procedure reviews, procurement reviews, auditing, handling quality concerns and budgeting for the . division.
Two of the engineers have 20 years of work experience and another ten years'of work experience. The Superintendent stated that the NQA goal was to complete a procedure review within ten days.
Based upon a sample audit of the section's performance.in completing procedure' reviews, the team concluded that the staffing for-the Quality. Support section appeared adequate to accomplish its mission.
Overall, the team concluded that the staffing for the Peach Bottom Quality Division was adequate to support restart.
3.4.8.4-Corrective Actions The team reviewed on the licensee's corrective action tracking, trending and performance indicators. The team-found that this information was being routinely provided to managers. The NQA Monthly Status Report for December 1988 showed the average age of open nonconformances to be less than l four months and trending downward.
Evidence existed that K management attention was being routir,ely focused on assuring corrective action.
Based upon this the team concluded that the itcensee's corrective action processes were adequate to support restart.
' 3.4.8.5 Audits The team was advised that the Nuclear Quality Assurance Interna! Master Audit Piar, bad been approved at the site I level but had not been approved at the general ramager !
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r level. The Peach Bottom Quality Division Manager stated that audits were being implemented, although the plan had not been formally approved by the General Manager as of the time of the exit meeting.
The audit' plan.'is a new initiative for.the licensee. The plan integrates the entire NQA audit effort for the company.- The team was provided a copy of the plan'at.an NQA staff meeting held at Chesterbrook,'PA,.on February 9,1989. ' The audit plan was' stated to provide for maximizing the use of performance-based auditing techniques and provide for a system of comprehensive, in-depth, vertical investigative reviews of entire proct:ss areas. The integrated-effort was stated to provide also for efficient use of the audit . staff to accomplish the NQA mission. The audit plan encompasses Peach Bottom, Limerick and corporate.
The Master Audit Schedule is an integrated two year audit schedule. During a review of this schedule, the team identified that one corrective action , audit required by Technical Specification 6.5.2.8.C, was missing from the. schedule for' Peach Bottom.
However, discussions with the f each Bottom superintendent for auditing identified that the required corrective action audit was being planned as audit PB.1-1. 'He stated the he would initiate a schedule correction.
The team concluded that additional review of the schedule appeared to be needed before formal issuance. The team verified that the audit schedule was being implemented.
The audit plan calls for 46 yearly Peach Bottom audits. The plan also specifies 25 corporate audits. The NQA goals specify that 50% of all the audits are to be performance-based and are to include observations of processes in progress.
Further, the goals call for 15 ~ technical based audits over the two year cycle. The team concluded that the master audit plan was a positive u management initiative to improve both the company's and Peach Bottom's quality. The team, however, also noted a weakness existed in failing to issue the plan and schedule at the beginning of the year.
The team selected several areas and requested to see audits that the licensee had conducted to assess the adequacy of the licensee's audits to provide feedback to management regarding potential problems. Audit No. PA 88-504-IST conducted November 7 to 18, 1988, resulted in two NQA corrective action request (CARS) and two recommendations.
The audit appeared to be in-depth and identified technical details requiring corrective action.
The audit recognized tnat the IST program implementing plan was under development .. -- - _ _ _ -. _ - _ _ - _ - - _ - - - - _
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and that the licensee had advised the NRC staff that revised ! .and new procedures will be available by May-1,~1989, thereby allowing full implementation of the revised IST. program.
- The' team reviewed the implementing-plan work'and noted that approximately 29 check valves required disassembly.in order-- .to verify their operability. The audit did not identify ~ that these valves either had not been tested or wouldinot be.
. tested until the-next' refueling outage,.approximately 15'to- -18' months after. restart. The team concluded that.the scope.
. of the audit should have-identified. this; issue to management since the. operational readiness of these safety related.
' valves may not have been known.. The team concluded that the safety perspective of the audit' team was.somewhat narrowly focused. During discussions with the NQA_ General-Manager.
regarding auditing perspectives, he-indicated his intent-to attempt to broaden the focus'of the NQA auditors.
Regarding the 29 valves the licensee-subsequently provided additional rationale for, interim acceptability of the operational readiness ~ of the valves.
' Another. area selected for review was modifications. Audit PA 88-513 conducted from September 19, 1988 to February 2, l 1989, was conducted to evaluate the completion status of modifications at PBAPS Unit 2.
This audit identified eleven CARS. Unlike the above discussed audits, management initiated the use of root cause analysis. methodology in an effort to determine and understand all of the problem root causes, in addition, to assuring that all of the root causes will be identified. The team identified several problem areas with modifications during-.the inspection. The team noted that the licensee's root cause ana' lysis efforts were identifying similar problems.
Based upon this finding, the
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team concluded that the licensee now has in place the tools ! to assure that problems are identified by the licensee's self assessment processes for corrective action.
Based upon the overall audit program being implemented and improvements being made the team concluded that the licensee's program is acceptable to support restart. The team further concluded that expanded use of root cause analysis methodology is warranted for' selected audits to assure that all the root causes for problems are identified.
Management needs to assure that auditors focus broadly on effectiveness'and safety in addition to technial detail.
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3.4.8'.6 Surve111ances The Peach Bottom _ Quality Division's. Technical Monitoring Section provides real time surveillance and monitoring of-
on going plant activities. The technical monitoring-schedule specifies 22 areas to.be covered, for example, shift operations, control room performance and security. The schedule assigns two monitors to the area of shift coverage and specifies a frequency lof five real time monitoring observations per week. :The team noted that corrective action for identified problems was being developed-and tracked. The team also witnessed technical _ monitoring.being performed in the control room.
The team concluded that this NQA initiative was a positive quality improvement.
-The team noted another NQA improvement initiative was to require at least 50% of the NQA audits to include real time observation of processes'in progress. The team concluded.
that this.was a positive improvement for assuring quality at Peach' Bottom.
The team concluded that overall improvement in the area of surveillance of ongoing plant activities has been.made for Peach Bottom.
3.4.8.7 Independent Safety Engineering Group (ISEG) The ISEG performs independent examinations of information which may. indicate areas.for improving facility safety and makes recommendations regarding means of improving safety.
The team reviewed the ISEG charter, interviewed the NQA Manager, members of the ISEG staff for Peach Bottom and reviewed the ISEG reports.
The current Peach Bottom ISEG staff consists of a supervisor and three engineers. One additional engineer was shown on the organization chart.
However, he has not been available for ISEG work for approxi-mately six months since he was in SRO training. The current staff including the site supervisor contains two mechanical engineers, one nuclear engineer and a chemical engineer. The team noted the absence of electrical and instrumentation expertise in the ISEG staff for Peach Bottom.
The NQA Manager stated that it was intended to recruit for electrical and instrumentation expertise for the Peach Bottom ISEG. The site ISEG supervisor reports to the corporate ISEG Manager. However, this manager has transferred to another position and the corporate staff is being phased out. Currently the site ISEG supervisor reports to the General Manager, NQA.
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An interface agreement signed by the Executive Vice President on August 19, 1988, and issued to Nuclear Group Division Managers, provides ISEG adequate independence and authority to accomplish-its mission.
ISEG report recommendations are required to be responded to within 30 days. The ISEG recommendations are tracked on QATTS (an NOA computer tracking and trending system).
Commitments-for-future action to be taken are tracked..A computer print out from QATTS was verified to contain ISEG recommendations and.- close out status. Two corrective action reports (CARS) issued to the station's operating and technical departments were noted to be tracked by corporate NQA.
Surve111ances performed by ISEG that resulted in recommendations were not being tracked; however, the team was advised that all future surveillance would be tracked.
The team assessed the tracking and trending of ISEG recommendations and concluded that with the inclusion of surveillance, the tracking and trending was adequate to assure input of ISEG findings into the corrective action process.
The ISEG staff at Peach Bottom have been trained to perform root cause analyses on identified problems..The ISEG site staff has also assisted other departments in root cause analysis work.
Examples of the use of root cause analysis
- work were noted by the team during the inspection. The team concluded that the root cause methodology being used and promoted by ISEG was a valuable self assessment tool.
The site ISEG reviews 10 CFR 50.59 safety evaluations for the Nuclear Review Board (NRB) under procedure ISED-I-2, Rev. 1, Implementing Procedure for Review of Safety Evaluations. This review is not a comprehensive technical review.
The ISEG is tasked with concluding whether or not a change involved an unreviewed safety concern.
The ISEG supervisor stated that these reviews are performed in offices and none have identified an unreviewed safety concern.
The team raised a concern that ISEG made no in plant assessment regarding the changes. The ISEG supervisor stated that future reviews would on a sampling basis include in plant assessment of the 10 CFR 50.59 reviews.
The ISEG ! supervisor stated that the ISEG site staff currently spends j l about 5% of their time in the plart, primarily in the < control room. The team concluded that the ISEG in plant ] focus was relatively narrow.
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___ [ hE \\ gg The. team concluded that the site ISEG group had adequate L independence to accomplish its mission.
Improvements in tracking surveillance' recommendations are needed and were.
committed to be made. A weakness exists in the staff due to ~ the absence of' electrical and instrumentation and control expertise. This was stated to be a recruiting priority by the NQA Manager. The root cause analysis expertise of the ISEG is a definite strength in the licensee's self assessment capability.
l 3.4.8.8 Human Performance Evaluation System.(HPES) The HPES is a methodology to identify, evaluate and correct situations-that cause human performance problems such as errors, near misses and potential problems. The licensee formalized the current HPES in July 1988 by issuing.
procedure A-125, " Procedure for the Human Performance l Evaluation System", Revision 0.
The HPES has a coordinator
assigned who has been trained to perform HPES investigations and root cause analysis..The coordinator.is both experienced and knowledgeable in station operations. The coordinator was involved in investigating 32 potential problem issues in 1988., published ten reports and stated that an additional five reports are pending issuance. The coordinator' reported until recently to the corporate HPES coordinator. However, this person changed jobs and the ' corporate position is not being refilled.
Currently the HPES coordinator reports directly to the General Manager, NQA.
The General Manager, NQA stated that it was planned that when the site -Independent Safety Engineering Division
- Manager position is filled, the HPES Coordinator would report to that person.
'HPES investigations are conducted by trained HPES evaluators.
There exists a pool of 16 trained evaluators, including five in ISEG'and four STAS. The coordinator stated that manage-ment had removed the four STAS from taking further HPES evaluator assignments. The coordinator stated that more HPES evaluators were needed.
An event report, 88-026, that occurred on June 8,1988, was reviewed.
The event was reviewed in a previous NRC inspection and involved a plant operator installing a safety ground in a load center. While installing the ground, the cable contacted a bus bar causing a large arc. The report identified seven causes and five proposed corrective actions.
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.was submitted t'o plant management;.'however, no action has been-taken on the recommendations. Neither.has management approved, the report..The coordinator stated that HPES did not input into
- one of the formal tracking systems utilized for management tracking and trending of corrective actions.' The HPES coordi-nator stated that he has experienced a. lack of management attention to HPES reports in general.
Another example of HPES involvement was a. February 7, 1989,. scram event associated with a 600 psig interlock.and valve MO-38..The HPES coordinator had completed his part of the HPES evaluation; however, stated that he'needed HPES' evaluator input from instrument and control people. He stated that he had not at the time been effective in getting anyone assigned to perform that portion of the HPES evaluation. Subsequent to discussions with the General: Manager of.NQA, it was stated that an additional 40 people were scheduled to receive HPES evaluator training in late March of 1989.
It was stated that this additional pool of evaluators should aid in resolving the problem of making available-trained evaluators.
The HPES coordinator verified that four HPES training sessions-(one hour each) had been conducted for the technical-staff during the second quarter of 1988.- The coordinator verified that there was no general employee training for explaining the HPES system to all employees.
There were several posters displayed about HPES. ~The team interviewed employees including several managers regarding their knowledge-of HPES and found in general that either-HPES was not known or little was known about HPES by plant employees.
The team concluded that HPES'had a large potential.for improving safety. However, to make the HPES a viable program for Peach Bottom, management attention was needed to support the program. The program needed publicity, employees needed to be trained regarding use of the HPES system, a larger pool of trained HPES evaluators was needed, the controlling procedure needed updating and improvement, and management controls needed to be implemented to assure that prompt action is taken on HPES findings and proposed corrective actions.
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-3.4.9 Conclusions The team concluded that corporate management is actively , involved in. assessing facility performance through both line and independent oversight channels.. Through his presence'at numerous station meetings, the Executive Vice President, Nuclear, demonstrated an' acute awareness of facility problems. 'The development of numerous information systems-such.as the Performance Management Program,.the Master Open items List and the Commitment Tracking Program has provided . corporate managers with effective tools for keeping abreast of facility' status and program developments.
Independent-review committees have played an active role in resolving long-standing technical issues and in assuring effective communications;within the new organization.
- 1 While the new Nuclear Quality Assurance Department is still developing, consol_idation of the previously fragmented quality assurance and quality control groups under a single General Manager has resulted in'a strong independent self assessment capability as indicated by comprehensive audits and effective root cause analyses by the Independent' Safety Engineering Group. The formation of an operationally JF oriented technical monitoring group has provided for a real-time assessment of in process activities.
Improvements are needed to focus some auditors on safety and quality, to provide adequate quality control inspection procedures, to finalize the 1989 audit plan and schedule,. and to assure appropriate technical expertise on the Independent Safety Engineering Group.
'3.5 Radiological Controls 3.5.1 Scope of Review The team evaluated the performance of the licensee's radiological controls program, with emphasis on those functional areas important to startup-or with previously identified weaknesses.
Team evaluation methods included tours of radiologically controlled areas, observation of ongoing work, interviews of personnel, and review of selected documentation.
Functional-areas reviewed included organization, management and staffing, training, work / exposure control, ALARA, facilities and equipment, i ( _ _ - - - - _ _ _ _ _. - - - - _ - _ -
. _-____ _ - - _ - _ - ,, l-65 3.5.2 . Organization, Management', and Staffing The licensee's health physics (HP)~ organization has been 'significantly modified since the Shutdown Order.
Seven first-line supervisor positions were created and. filled in the applied HP section...This represents a significant improvement as compared to the previous organization.. Other changes included the complete rewrite and upgrade-of station HP. procedures and the filling of-the applied HP Supervisor, the Senior. Health Physicist, and the Superintendent, Plant Services positions with~new personnel.
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Team. inspection effort was directed towards assessing the- " continuing. effectiveness of these changes and the ability of' the current organizationLto support startup.
Several-licensee strengths were noted. One was " Management by t Walking Around" (MBWA). tours of the radiological work areas.
'These tours are routinely conducted and appear effective in ' improving radiological housekeeping. -Overall posting and labelling of radiological areas and materials was . significantly improved.
' HP technician staffing levels are a'dequate to support power operation. The applied HP group includes seven'first-line supervisors, 38 fully qualified PECo technicians, and 16 junior PECo technicians. Contractor staffing levels include approximately 32 fully qualified technicians and 19 junior-technicians. Although contractor technician levels are currently being reduced,.the licensee anticipates retaining approximately 16 fully qualified technicians through startup. The licensee has also recently hired a Certified Health Physicist to work for the support HP group.
Interviews of HP technicians and supervisors indicate that working relationships with other work groups such as-maintenance, operations and I&C have improved. HP technicians assigned to operations as the " shift HP technician" now rotate with the operations shift to improve team-building. The level of communications with and support from the corporate Radiation Protection Section shows significant improvement.
Continuing improvement in the timeliness of closecut of radiological occurrence reports (ROR) was noted.
There were also areas for further licensee improvement identified.
Discussion with the HP staff identified that a - _ _ _____- _ __
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subset of the station's HP technicians have no operating power plant experience. This subset includes certain of the contractor technicians and the current group of PECo "C" technicians that were hired subsequent to the shutdown.
Discussion with the licensee identified that although the need for specific training and orientation for this subset had been discussed, no final decision to provide it had been made.
The team noted that changes in radiological conditions subsequent to plant restart would be significant. The licensee agreed to provide an " operational experience orientation," to the subject technicians (see section 2,4.7).
This item will be reviewed prior to restart (277 and 278/89-81-02).
Documentation of work area tours by first-line supervision does not always include corrective actions taken for identified deficiencies.
The licensee's program for root cause analysis and trending of RORs is still under development.
Improvements in this area were noted during the time period of the inspection. There is currently no opportunity for technician rotation among the three HP groups (applied, support, and radiological engineering).
HP technicians consequently have a more limited scope of the HP area than technicians at sites that provide,the opportunity for rotation or cross-training. The licensee stated that training for certain tasks outside their normal responsibility (whole body counting operation and respirator fit-booth operation) was being added to the progression training for applied HP technicians.
Field observation of Security /HP interface identified the need for improving communication between these two groups.
While observing decontamination activities in a vital area, , the team noted multiple entries to the room by the security ! force in response to recurring door alarms. The room was also a posted contamination and airborne activity area and required a full set of protective clothing and a respirator for entry. The team noted the recurring (up te seven in one day) security group entries to the contaminated / airborne activity area represented an ALARA concern.
Despite this concern, no action or communi-cation among the HP and security groups had taken place to evaluate the situation and determine potential alternatives to the entries. When interviewed, the cognizant area HP supervisor was not aware of the recurring alarm situation. Once identified, licensee corrective action included moving the contamination control boundary away from the room door to allow the door to
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close more quickly. A surveillance test was also performed on the door alarm and identified deficiencies in alarm operation.
-The licensee also stated that either the Radiation Protection Manager or his assistant will be attending the monthly operations / security interface meeting to improve communications between the two groups.
3.5.3 Training The team reviewed the status of licensee training programs for HP technicians and radiation workers by discussion with cognizant training staff personnel, review of selected ' lesson plans, and review of recent licensee audits of the General Employee Training (GET) and HP technician training programs.
- 3.5.3.1 HP Technician Training The licensee has recently taken several corrective actions in response to NRC concerns associated with the HP technician training program.
A. " diagnostic" test, covering 15 separate HP functional areas, was administered to the HP-technicians in June 1988.
Those functional areas identified as weaknesses were then added as priority training areas to the HP technician cyclic training program. Training on several of these areas has been completed. The licensee eventually plans to cover all 15 functional areas.
The licensee is also currently revising course outlines and lesson plans for HP technician progression training from "C" to "B" to "A" technician.
The revised plans are job-task oriented and are being developed with input from and review by the station HP group.
In an effort to independently evaluate HP technician knowledge level, the team interviewed selected HP technicians and questioned them concerning procedural requirements and radiological definitions and limits.
Several significant areas of technician weakness were identified, and included federal exposure limits, technical specification high radiation area control options, and gross alpha and beta MPC values.
The licensee stated that all technicians would be briefed on the specific areas of knowledge level weakness identified during this review.
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. .The' team concluded that~although field weaknesses in technician knowledge level were noted, the licensee is already actively improving the HP. technician training program.
Licensee performance in this area will continue to be reviewed in future inspections.
3.5.3.2 Radiation Worker Training Recent NRC inspections have also identified weaknesses in the radiation worker training program. The team reviewed a licensee audit of the General-Employee Training (GET) program (Radiological Assessment Report 88-06) performed in July 1988. The audit was comprehensive and identified eight recommendations for improvement of the overall radiation-worker training /requalification training program.
Discussion with the licensee's training staff indicates the - . recommendations have either been implemented or are in the '
- process of implementation.
. The ' licensee also stated that effort is underway by the Limerick, Peach-Bottom, and corporate training staffs to develop a common, PECo-wide radiation worker training program. The scheduled date for completion of the lesson plans is June 1989. The licensee stated that the common program would incorporate recent improvements and recommendations identified during recent audits. Review of
- 1icensee development and implementation of the radiation worker training program will be' performed during subsequent inspections.
3.5.4 Control of Work / Exposure Control
- The team reviewed the licensee's program for identifying and controlling radiological work hazards by discussions with personnel, observation of field activities, review of selected radiation work permits (RWPs) and associated radiological surveys, and review of locked high radiation area (HRA) key accountability records.
Within the scope of the above review, several areas of improved licensee performance were noted.
Locked HRA key issue and accountability controls have improved and the controlling procedure was being complied with. An increased use of engineering controls (tents, catch containments) to limit the spread of contamination was noted. Overall dose accountability (i.e., the ability to correlate station - _ _ _ - _ _ __ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - - _ _ _ - _ _ _ _ - _ - - _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ - -
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l exposure to specific RWPs) h'as improved.
RWPs and related surveys were adequate to identify and control _ radiological- ~ hazards..A new HP computer information system (the ADEPT system) has been developed which includes significant.
improvements over the previcus' dosimetry system. These improvements include tie-in. to the work control system for .RWP writing and the capability for on-line verification of worker qualifications prior to access. The team identified 'that the on-line access function of this system is still in.
, the trial implementation stage:and additional training is ' required prior'to full implementation.
Several areas for additional licensee improvement were also identified.
Review of RORs identified that significant radiation worker procedural deviations, RWP noncompliance, ' and contamination control concerns continue to occur.
1Several examples of poor radiological work practices were also noted by the team during the inspection period (section-3.6.1.4).
The licensee acknowledged this concern and stated - that a module on radiation work practice awareness had been . included.in recent training that was provided to all plant supervisors.
The. licensee also stated that HP technicians had been. instructed to be observant for poor work practices-and correct them in the field, as they occur.
Licensee efforts in this area wi11' continue to be reviewed during subsequent inspections.
Counting of. selected air samples and smears for gross alpha activity is performed by the Chemistry group in accordance with procedure RT 7.6.7, " Analysis of Routine Samples for Alpha Activity." Review of this procedure identified deficiencies such as the licensee's equation for minimum detectable activity (1.00 x standard deviation of.the background counting rate) is less conservative than the equation recommended by the NRC (4.66 x standard deviation of the background counting rate), and no corrections for air sample filter dust-loading or self-absorption are made during alpha counting.
The team also noted that coordination among the principally involved groups was not as effective as it could be.
Specifically, the chemistry group received no specific l direction from the HP group as to which samples to count for gross alpha activity. Additionally, the radwaste group did not communicate to either HP or chemistry the results of their annual waste stream analyses. These results identify
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l l ', i: transuranic present in the waste streams and are typically . - reviewed by the HP group to identify trends or changes. -The licensee stated that the above concerns would be addressed.
This area will be reviewed during 'a subsequent inspection.
The licensee has recently procured several AMS-3s (airborne monitoring system) to provide real-time alarm indication for airborne' radioactivity.. Tours of the various areas where the AMS-3s are in use identified that although background levels L are_ typically 1000 counts per minute.(cpm) alarm setpoints ? ifor the'AMS-3s are' set at 6000 cpm. The licensee stated the alarm setpoints were set at this-level in anticipation of the high radon levels that frequently occur in the plant.
The team noted that'although the current setpoint is adequate, a more aggressive approach typically includes trending of background. radon levels with modification to the alarm setpoints only as.necessary. The licensee stated this > area would be reviewed.
3.5.5 ALARA' Team review of the licensee's ALARA program consisted of discussion with cognizant personnel, review of the.1989 exposure goals, and review of selected pre-job ALARA reviews l-and post-job history files. Several program improvements were noted. The licensee has set an aggressive station exposure goal of 1000 manrem for 1989, a year which includes a refueling outage for Unit 3.
The level of involvement in vthe goal setting process by the corporate group and support of the goal by station management represents significant improvement over previous performance.
Several ALARA program improvements have been recently instituted by the corporate radiological engineering group.
One of these is 'early involvement of the corporate group in the design modification review process, with representation as required on the modification team. Another is development of a program to institute exposure bonus / penalty clauses in vendor work contracts to improve vendor ALARA . performance. This program was used during the Unit 3 local pcwer range monitor and steam dryer work evolutions and resulted in significant exposure savings.
Finally, the level of station management attendance at the Station ALARA Committee represents an improvement as compared to previous years. The team observed, however, that attendance by upper-level management in the maintenance group was not as frequent as the other groups.
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The team' identified the need for improved documentation in' ALARA post-job reviews and -job history files.
Review of selected ALARA post-job reviews-identified that the root causes for exposure and man-hour under or overestimating were not clearly identified.in the. review. The team also noted that. job history files did not contain the basic assumptions (manhours and doserates) that went into calculating the initial exposure estimates.
, The licensee acknowledged the above concern.and stated that' additional effort would be directed towards improving ALARA post-job reviews and the level of documentation in ALARA job history files.
3.5.6 Facilities and Equipment The team reviewed licensee counting facilities and supplies of portable survey instrumentation to support operation. No deficiencies were identified. Adequate counting instrumentation was'available in the countroom'to provide gross and isotopic identification of radionuclides. Review of portable survey instrument inventories identified the licensee has an adequate supply of-calibrated instruments to support operation. All in-use instrumentation observed was within the instrument calibration period.
The licensee has initiated an aggressive program to reduce the extent of plant contaminated areas.
In June-1987, approximately 40% of the combined Unit 2 and 3 radiologically controlled area was contaminated-to varying levels.
Currently, this percentage has been' reduced to approximately 10% of the Unit 2 and common areas, and 17% of the Unit 3 areas excluding drywells.
The licensee plans to decontaminate Unit 3 areas to approximately 10% after the completion of ongoing modifications and maintenance.
The overall licensee goal is to maintain the plant with approximately 10% as contaminated area.
Implementation of 'this program was noted as a licensee strength.
3.5.7 Conclusions The team determined that significant improvements in the radiological controls program hac occurred across all areas ' reviewed and that the program is adequate to support plant startup and operation. One weatness noted was lack of operational plar.t experience in a subset of the station Hp technicians. The licensee agreed to correct this prior to restart. Several additional rainor weaknesses were noted which do not require resolution prior to restart.
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3.6 Surveillance / Maintenance 3.6.1 Surveillance 3.6.1.1 Scope of Review ' The team assessed the surveillance testing (ST) program to determine the licensee's effectiveness in implementing the program. The organization which implements the ST program was reviewed. Related administrative procedures, the ST tracking system and procedures generation methods were analyzed. Monitoring of actual performance of and review of ST procedures was completed to ensure compliance with procedures and Technical Specifications (TS). Operations, I&C, and system engineering personnel were monitored during field ST performance. The training of these personnel was reviewed to ensure their qualification for the tasks being performed.
ST acceptance criteria were reviewed to ensure clarity and compliance with TS requirements. Compliance with procedures and the usability of procedures was also observed. The approach taken when an ST does not meet the acceptance criteria was reviewed.
Recent temporary changes to STs were reviewed to ensure that the change system is working effectively.
3.6.1.2 Organization The ST program is administered on site by the Technical Department.
Recently, this department was reorganized into three groups. The Systems Group includes the system, test and reactor engineers. The projects group coordinates the surveillance testing and other programs, such as Inservice Testing (IST). The Regulatory Group implements tracking systems and on site licensing issues.
The Systems Group was observed to have good engineering ability, but was lacking in operational experience. These engineers have a good under-standing of the plant systems and components.
Specialized i training has been provided as it becomes available to enhance ' their knowledge of the systems. The site specific simulator has been used to provide these individuals with overall plant and j system operating experience. The Projects Group was observed to
be well staffed and able to handle the asMgned o 61oad. The regulatory group handles the Operational Event Assessment Program and the Commitment Tracking Program (CEAP /CTP). The OEAP and CTP were also discussed in section 3.4.7.
The team noted that the licensee issued action items to different site personnel to ensure that open items are trocked and resoluticn is obtained.
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.The site personnel involved in performing STs cross most of the organizational boundaries.
The personnel from technical support, ' operations, and maintenance engineering were observed'to function well as a team.
3.6.1.3 Scheduling ' A surveillance coordinator tracks and schedules;ST requirements.
Recently, another scheduler has-been hired to-Lassist this coordinator. The tracking system (STARS) is computerized and well controlled.
Each ST and the testing interval is logged into the system. The tracking system is divided into four quarters, each having thirteen testing weeks. Each ST is scheduled to be performed during a one week interval. A list is distributed prior to an upcoming week so that departments can plan their activities. A: schedule is provided to the operations department for tests to be performed for a given. week. The schedule is further subdivided.into the three operating shifts and defines ST responsibilities for each shift to complete.
The STs that require support from other site organizations ~are usually ~ completed on day shift.
If the-ST coordinator does not receive a completed.ST within the required one week interval, the 1.25 times the interval grace period as allowed by TS is entered and the ST goes onto a late list..This list is distributed to the site departments.
The ST coordinator tracks these late STs.
If ithey are not performed within three days of the end of the grace period, the coordinator goes directly to.the supervisor, responsible, and requests test completion.
If it does not appear that the ST can be completed, the appropriate documen-tation is initiated in order for operations to consider system / component inoperability implications.
If an ST fails,.the shift takes the action required by TS and the failed ST is forwarded to the ST coordinator. The ST is entered into the tracking system as a failed test and is not removed from this list until a satisfactory ST has been completed.
3.6.1.4 Surveillance Test Observations i Selected STs were observed by the team in progress.
ST procedure usability and technical acceptability was reviewed.
Procedural compliance and qualifications of the personnel conducting the test were also reviewed. When an ST is scheduled to be performed, it is given to the shift I ! !
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_ _. . _ _ _ _ _ _ _ _ _ - 74-supervisors on a daily list. The personnel performing the test come to the contrcl room-in order to get the required ~ permission and signoffs~by the affected unit reactor operator and the shift supervisor. The team observed good operations personnel interaction with the systems engineers, test engineers and I&C technicians.
Selected STs were observed by team members and are listed in Appendix C.
Specific ST comments are listed below: ST 8.1, Emergency Diesel Generator (DG) Full Load Test.
-- The test was conducted an the E-2 DG and was completed in accordance with the procedure. An engineering deficiency was re-identified.during performance of this ST. This was previously identified as NRC unresolved item 277, 278/87-29-03. After the DG is secured, 11ubricating oil from the upper crankcase migrates down the ' upper cylinder liner and collects on the upper piston rings. Due to leakage around the piston rings, the oil migrates further down the cylinder. wall and into.the exhaust ports. 'The oil then flows to the low point in the exhaust header, which is at the flanged header connection to the turbocharger manifold.
The connection is made up using a flexitallic gasket and leaks when the machine is cold. This allows the oil to drip and collect on the motor casing. When the machine starts, the exhaust blowby may cause a short duration fire. This continues until the flange heats up and expands to stop the leak. This has been more prevalent on the E-2 DG and is a recognized problem with Fairbanks-Morse DGs. The licensee.is planning on making a modification that has proven successful at the North Anna Station. The machine will be air cranked after shutdown to allow the piston rings to force che accumulated oil back to the upper crankcase and into the sump. Unresolved item 277/87-29-03; 278/87-29-03 is considered closed.
Licensee actions for possible modifications will be reviewed in a future inspection.
-- ST 8.2-2A, Station Battery Weekly Inspection. The technician performing this ST appeared knowledgeable of , the procedure and performed in a competent manner.
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The general area around the battery was clean and free of extra nous debris.
The battery terminals were also clean an showed no evidence of corrosion. Battery voltages were measured across the battery teminals. This was done i N A . - - _ ._______ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ _
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'by measuring voltage at fuse panel 2AD019 for battery 2AD001. -The technician stated that measuring directly across the terminals was not feasible due to the short length of cord available on the voltmeter. All values tested were found to be within the specifications.
Although this panel appears to be a suitable point for measuring, it is not mentioned in the procedure. The . licensee indicated its intention to revise the procedure to clarify the voltage measuring point.
.SI 2D-14-43-A1CQ, Core Spray Sparger D/P Calibration -- Check. This procedure was performed in a competent manner. One concern was that the technician only wore gloves for the initial hookup of the test equipmert into the potentially contaminated CS system.
Further adjustments and removal of the equipment were performed using bare hands. This is an example of the weakness discussed in section 3.5.4.
SI 2P-2-55-BICO, Reactor Pressure Loop Calibration -- Check. A shutdown reactor scram with no control rod motion was observed to occur during performance of this ST (see section 3.1.8).
This procedure checks the calibration of each reactor high pressure scram instrument.
I&C personnel discussed the ST with the unit 2 operator and the shift supervisor, and were given permission to perform it on the "B" pressure transmitter. Step 6.1-of the procedure was ambiguous because it referred to special procedure (SP) 360 in a manner that did not clearly indicate whether SP 360 was in effect for Unit 3 as well as Unit 2.
The RO originally interpreted it one way, then after further review, decided that SP 360 applied to Unit 3 and did not affect this procedure on Unit 2.
The team concurred with this determination.
The isolation of the detector, tie in of the test instrumentation, and controlled pressurization of the instrument was in compliance with the procedure.
The trip set point of the instrument was within specification as was the trip function of the B reactor protection scram logic, which produced a half scram
condition. The pressure dctector isolation valve { 1eaked by its seat as the detector was pressurized.
The configuration of the sensing lines leading back to the reactor vessel was not reviewed by the operations ! staff prior to allowing the ST to be performed.
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manual sensing line isolation valve upstream of the excess flow check valve was shut and tagged due to system modifications.
This caused the entire sensing line to pressurize because the closed isolation valve prevented venting to the reactor vessel.
The operators were expecting the "B" half scram condition when it occurred. Within a minute the operator received the high reactor pressure alarm and then the full scram condition caused by the unexpected pressurization of the "A" high pressure reactor scram detector. The event surprised the operators who initially thought that the instrument line' excess flow check valve must have caused the blockage of the sensing line.
It was not until approximately one half hour after the scram that it was realized that the sensing line blocking valve was tagged shut. This scram wou'd not have occurred if the instrument line blocking valve had been open. Additionally, a backup valve to the detector isolation valve is not required to be shut during this surveillance and consequently was not used to prevent the leakage.
ST 7.1.1-2, Standby Liquid Control (SLC) Solution -- Analysis.
Parts of this procedure contain relatively broad instructions, but their intent appears to be well understood and the conditions were met. The procedure did not address any precautions to be taken with regard to handling of boron.
The SLC tank contained a warning label which specified that gloves, safety glasses and an apron be worn. The technician only wore safety glasses. During sampling, some of the sample solution spilled on his hands. The team brought up the discrepancy between the tank warning label requirements and sampling practices.
The licensee stated that the new boron solution was less hazardous and required only gloves and glasses.
The licensee responded by correctly rel-helling the tank.
In addition, the procedure is being revised by the licensee to include a precaution statement consistent with the tank warning label calling for the use of safety glasses and gloves.
The inspector noted that the chemistry lab was clean and orderly. All prepared reagents were found to be in date. The chemistry technicians conducted themselves in a professions 1 manner at all times.
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_ _ _ _. _ - _ - _ - - " I The ST contains a note cautioning against the use of glassware during sampling and analysis due to the potential effect of boron contamination of the sample from glass. Plasticware was used throughout the procedure except in step 2.2.1 where a glass pipette was use to transfer the sample being analyzed. The procedure requires titrating in 0.01 ml increments when 'n the 6-7 pH range. The technician performed the entire titration in drop by drop (approx 0.04 ml) increments through the endpoint. Data sheet 7.1.1-2-1 contained no acceptance criteria for determining the . maximum allowable dispersion of two identical analyses.
When questioned, the technician stated that if the , dispersion were large enough he would doubt the validity of the analysis. However, he wasn't sure what "large enough" - was.
The licensee indicated its intention to revise the ST to include acceptance criteria as well as address the use of a glass pipette. The 0.01 m1 increment was correct and technicians will be trained on this method of adding reagents.
ST 6.18.2, Operational Test of A0-35028. A0-3502B is -- the. torus to reactor building vacuum breaker isolation valve.
It is an energized-to-shut, normally shut, fail open valve. The licensee encountered several difficulties during the ST. The reactor operator was unaware that unlike most valves, the control switch must be continuously held in the open position to open the valve (releasing the control switch immediately causes the valve to shut).
Neither the procedure nor the valve controller makes this fact known to the operator. Consequently, the operator attempted to cycle the solenoid several times without fully opening the valve. He eventually sought help and was informed of the problem. The valve was then successfully cycled. The licensee stated that the procedure would be revised to include a note advising the operator of the valve's operating characteristics.
The inspector noticed that the seismic nitrogen bottle was being depleted during valve cycling even though the normal air supply to the valve operator was on line.
The licensee was questioned about this phenomena and ' conducted an investigation. Their preliminary results indicate that this condition is acceptable because the 'I __.___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _
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E , ' y ' design criteria, only require cycling the valve a smal'1 number of times and the nitrogen is mostly intended for-maintaining the valve shut, for which negligible = air-is- , L consumed.. Additionally,-the bottle pressure is checked on , ' a daily basis and the bottle is replaced at 500 psi. The i licensee is conducting an in-depth. engineering evaluation L of this issue (primarily in response.to Generic Letter ! i 88-14) to determine all applicable requirements and the.
l l system's ability to satisfy them.
This~ issue was already being tracked as NRC unresolved' item 277, 278/89-01-01'. ST 21.8, Core Spray (CS) Pump Capacity for IST. This-l -- test is performed after an outage or system maintenance i r- .to obtain new IST pump curves. The procedure takes pressure and flow readings at various points, including i pump shut off head, 2/3 of rated, rated and runout ! flows.. The data collection was observed to be well l ' coordinated and properly completed.
The inspector observed systems engineers lifting leads to bypass the opening function of the minimum flow recirculation
- valves to allow closure.of the valve to get shutoff head information.
The proper use of double and . independent verifications was observed.
aST_. 21.5-2; Emergency Service Water (ESW) Flow Test ! -- Through ECCS Coolers. This ST was performed over.two ! shifts by a team of five test engineers., Pre planning discussions among the test engineers was' observed and .: the responsibilities of the engineers involved were ! evident. A temporary change (TC) was required and was . completed properly and in a timely fashion. While performing the. test a RCIC room cooler ESW isolation
valve did not open as required and a troubleshooting - request was' prepared. The troubleshooting was successful.
! The inspector witnessed portions of and discussed the test I with the. test engineers. The test engineers were know-ledgeable of all areas questioned.
j In addition, the team reviewed the following STs for
acceptability.with respect to Technical Specification (TS) i and administrative procedures: ST 4.13 A&B, Core Spray (CS) Vent Line. This ST I -- verifies the operability of the CS line accumulator i i I mm_ _ _ _ _ _ _ _ _ _ _ _ _ = _ - --
_ _ - - _ u . i 79) ! l I limit switch.
This switch provides a control room ' alarm.if water drains from the system. A solenoid j ' valve is also actuated which allows the condensate system to refill the pump discharge piping. The.ST " -includes a section to be completed if the alarm does.
not' function. The ST states how to vent and drain the accumulator but did not give any' specific. instructions for tFa performance of this operation.
Failure to properly vent and fill-the accumulator could lead to malfunctioning of the keep fill. systems and damage to the CS piping during automatic initiation due to water hammer effects. The licensee committed to changing the procedure to incorporate these instructions. The team also noted that the alarms for low accumulator level are referred to by the. licensee's former panel numbering method. The licensee presently is using an alpha-numeric row / column designation for annunciated alarms.
Procedure changes are needed.to ensure that the currently accepted identification systems for annunciators is reflected in ST and operating procedures.
The licensee stated that this will be included in the ST rewrite project.
-- ST 6.6, Monthly CS Pump and Valve Operability. The team determined that the licensee had weak acceptance criteria for determining pump operability on a monthly basis.
This conclusion was based on the fact that no performance data, such as discharge pressure, flow or motor .currer'., were specifically taken on the pump to ensure that it would be able to perform its designed safety. function.
Data are needed so that they can be compared.to a known acceptable range.
Instead, the licensee monitored the position of the minimum flow recirculation valve as an indication of flow. The licensee indicated that they would change their monthly pump operability procedures to better define acceptance criteria that ensure the operability of the pumps.
ST 6.6F, Quarterly CS Pump Full Flow Test. The procedure -- development was discussed with the licensee's IST engineer and found to be satisfactory.
TS require that each pump supply 3125 gpm at a vessel pressure of 105 psig. The licensee uses the full flow test line to increase pump flow to the maximum (greater than 3125 gpm), takes flow and pressure data, and plots the point on a pump curve included in the procedure. The pump curve was found to be generated by data collected from an IST ST run after pump or system work has been conducted.
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L ' 4' _-80~ ST 6.8 and 6.9, Monthly RHR Pump.0perability Test.
For -- .the 2A RHR pump, data to verify operability were taken: at the TS required-flow rate of_ 10,900 gpm. There were no specific data for the other three RHR pumps, or the , I four Unit 3 RHR pumps. The licensee is evaluating.this situation and will develop a resolution prior.to startup.
l ' ST 6.8F and 6.9F, Quarterly RHR Full Flow Test.
In -' -this-instance the pumps are run with the test valve open and data are collected. The data-are specific for 11',000 gpm. The differential pressure acceptance criteria are given in a bar chart format. The inspector asked why this presentation of acceptance criteria for RHR pumps was different than the curve format used in the core spray tests. 'It was' explained >that the core spray system test valve is a gate valve-and the RHR system valve is a globe valve. Because of this the RHR valve can be throttled to achieve a given-flow. ~The CS valve when throttled causes excessive vibrations and is therefore opened fully during full flow testing. The team had no further questions.
ST 4.10-4, Reactor Vessel Level Instrument. Functional -. Check. This ST is performed as a functional check of Jthe reactor vessel instruments, which cause a low level scram.
The team reviewed the completed ST and questioned the acceptance criteria.
In this test, water level is lowered 3 inches and data is taken on the level instruments.
Level is then raised six inches and another set of data are taken. The TS requires that a corresponding level change be observed. The procedure is written to verify that the level indicator decreased on the lowering of level and increased on the raising of level'. The low level instruments that are required to be checked do not feed an indicator in the control room. The TS bases for this check are to ensure that the instruments have not-failed as is. The team found the ST acceptable to verify the TS requirements.
ST 13.9, Secondary Containment Capability Test.
It was -- noted during the review that the procedure did not have clear acceptance criteria for air flow through the standby gas treatment system (10,500 CFM) as specified in TS.
The team discussed this with the systems engineer und found that he had identified the same issue and had a procedure change ready for presentation to PORC.
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Simulated Automatic Initiation Testing. The licensee -- uses overlap testing to meet the TS requirement to simulate an automatic primary' containment isolation and ECCS initiation for which this type of testing specified.
Testing for a satisfactory isolation / function from the actuation signal detector to completion of the isolation / initiation is not completed in one test.
Several overlap-ping tests are used to complete the total test.
The licensee has established individual STs for each of these TS requirements. These STs listed the other ST which together meet the functional test requirements. The acceptance criteria for completion of these STs is not listed, and should be the satisfactory completion of each separate ST.
The licensee indicated these procedures would be changed to include a complete list of all STs required and a sign off that each has been completed.
ECCS and DG surveillance testing required when -- components are declared inoperable. The inspector reviewed several STs dealing with the C5 subsystem, LPCI pump and subsystem, and DG inoperability. The STs that meet the required testing are not specified in a form that is useable to operations shift management.
Further, shift management does not have a clear method of documenting the testing that is necessary when a TS Limiting Condition for Operation (LCO) is entered or the time requirements for conducting the STs. The licensee is considering providing shift management with a list of surveillance that meet the required testing.
In addition, operations is pursuing the development of an LCO required ST tracking system. The team found no instance where the licensee failed to meet a TS LCO requirement.
It was noted that the TS for ECCS and DGs are outdated in that they require testing of systems when one component / subsystem is declared inoperable.
For example if one DG is inoperable, all low pressure ECCS pumps at both units are run to demonstrate operability as are the other three DGs. This type of testing is undesirable since it is excessive. The alternative is to verify that all components in other systems or subsystems are operable by reviewing the ST records.
This was a previous NRC open item and the licensee has initiated actions to request a TS change.
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_ - _ - - _ _ _ _ - _ _ _ - -. -- _ _ _. _ -- _ . _ _ _ __ -_ ' , -82 3.6.1.5 Administrative Procedures The administrative procedure for the generation of STs was reviewed. A weakness noted was in the area of development of acceptance criteria. There was no clear and concise method for determining what the criteria should be and then no method for having this determination reviewed for adequacy. The licensee is considering an upgrade to this procedure to.give better instructions and specify a supervisory check of new criteria.
3.6.1.6 ST Program Adequacy and Root Cause Analysis The team reviewed a contractor's report to the licensee and an internal licensee root cause_ analysis of ST problems. The licensee contracted Advanced Science and Techno' logy Associates (ASTA)-to perform a review of their ST program. ASTA provided a report on their review on September 21, 1988. ~The criteria used for the review included verification that the ST referenced the proper TS, and accomplished the intent of and had ,' acceptance criteria to support the TS. The.results indicated 54 STs did not meet the agreed upon criteria specified above.
For 140 STs it was questionable if they met the criteria. The team reviewed the documentation provided to the licensee on these items. Generally the.
deficiencies were minor in scope and included incorrect TS references and typographical errors. Other deficiencies show that specific TS acceptance criteria were not noted in the body of the ST. These items are tracked by the licensee.
An additional 11 specific TS were found not to be covered in any ST. These include missed daily and shift checks, two monthly instrument checks and several other TS requirements. These were previously reported to the NRC.
ASTA made recommendations to correct these deficiencies. One specific recommendation was to better identify the complex relationship of overlapping STs which meet requirements such as logic system functional tests. This deficiency was also discovered during this inspection. The licensee is correcting these problems.
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Based on the LERs and the ASTA findings, the licensee's ISEG performed a root cause analysis of the ST program.
This analysis turned up two main root causes and one contributing factor. Controls on procedure generation are less than adequate, controls on procedure revisions are less than adequate, and . review of the ST program is less than adequate.
n The licensee bases these root causes on the following: 1) TS changes have been made without the corresponding ST being generated; 2) modifications have been made without regard to their effect on STs; and, 3) there has not been a review process to ensure adequacy of STs in compliance with TS.
The ISEG recommended the following: 1) ensure that j each ST has a sponsor who is responsible for the ' technical adequacy of the procedure; 2) new TS shall be reviewed for ST conflicts; 3) a formalized TS/ST cross reference should be established; 4) the flags used on steps to identify TS (*) and IST (I) requirements may be confusing and need to be clarified; and, 5) a detailed review of STs and TS.
The inspector discussed the following methods to implement these recommendations with the licensee: 1) make the system engineers responsible for the STs on their systems; 2) incorporate a review of any needed TS changes into the process of submitting a TS amendment; 3) complete the current effort to compile a TS/ST cross reference; 4) review the method of incorporating acceptance criteria into STs; and, 5) complete a long term detailed review of STs for human factors concerns by 1991. The licensee will be formally presenting their corrective actions in a revision to LER 2-88-24.
l The licensee completed walkdowns of 18 STs on October 14, 1988.
Several procedural deficiencies were noted, which were minor in nature. One instance was that the flow from the diesel fire pump was not being measured during an ST which appears to be an acceptance criteria deficiency. These deficiencies were corrected.
3.6.1.7 Conclusions The licensee's ST program adequately implements the TS.
Adequate personnel with technical knowledge are available to support plant operations.
The procedures are suitable to complete the TS requirements.
The system engineers and operations department personnel must continue to question the acceptance criteria for STs to ensure that all TS requirements are met.
The .......
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licensee has agreed to increase the-sensitivity to the acceptance criteria with these personnel. NRC unresolved items (277/88-34-04; 278/88-34-04, 277/88-35-01; 278/88-35-01,'277/88-28-02; 278/88-28-02) that are related to the ST program are closed.
3.6.2 Maintenance 3.6.2.1 Scope of Review This portion of the inspection focused on the ability.
of the licensee to conduct safety related maintenance.
In process work was evaluated to make this determination. The qualification of maintenance personnel to perform assigned tasks was assessed.
Administrative procedures, management policies and goals were reviewed to ensure that adequate controls are in place.
Several recent equipment failures were reviewed to ensure that adequate root cause analysis was' performed. The method of generating procedures and the qualifications of the writers were assessed.
The planning and tracking method for and backlog of items was reviewed.
3.6.2.2 Organization and Staffing Team discussions were held with various people in the maintenance organization. These people were informative and well versed in their duties, goals and reporting chain in the organization.
Presently, the Maintenance Superin-tendent reports directly to the Plant Manager.
The persons reporting to hin are in the electrical / mechanical maintenance and I&C areas. The staffing levels appear to be adequate to achieve the goals of the department.
The licensee has removed two supervisory positions from the chain of command, between the Plant Manager and craft personnel.
The positions eliminated are an assistant maintenance superintendent and an assistant craft foremen. The licensee stated that this allows for better definition of responsibility at all levels.
The assistant foremen hcve been temporarily upgraded to foremen. This was done to increase the ratio of supervision to craft personnel. The development of a general mechanic training program is in the planning process. This would give all mechanics the basic knowledge in required trades, including electrical areas. The licensee will still maintain personnel qualified to perform specialized electrical tasks, welding and machining.
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The planning and scheduling branch of the department has been recently created.
These people schedule, track and prepare all the Maintenance Request Forms (MRF) needed on site. The MRF group consists of personnel on a one year rotational assignment from Quality Assurance and Health Physics so that planning-for a job in these areas can be done simultaneously.
3.6.2.3 Goals and Policies The department has numerous' indicators that are used to track the performance of maintenance. These include the number of overdue preventive maintenance (PM)- items, the percentage of corrective maintenance (CM) items that are older than three months, and the ratio of PM to total maintenance.
The team observed that these indicators are provided to the maintenance superintendent, station management and corporate management. Other goals that are tracked include radiation exposure, personnel contamination and maintenance caused occurrences.
The licensee published their 1989 maintenance strategy - in February 1989. The purpose of this document is to outline'the goals and to improve the maintenance
process in nine areas, most notably work process control and package production, and productivity measurements and work standards. The definition of what is to be accomplished for each of these items is clearly identified.
3.6.2.4 Interfaces Various interfaces within the department and with other station and corporate offices were observed during the inspection. Actual MRFs were observed during processing, and the coordination with the operations and health physics departments was observed to be satisfactory. Adequate coordination of items that could potentially affect equipment was observed between maintenance and the technical department using the OEAP/CTP.
It was observed that maintenance also provides input to the technical department on items j that should be placed on NPRDS.
QC involvement in ' procedure development and ongoing work items was observed.
Commendable interdepartmental interfaces were observed in the areas of failure tracking and _
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i analysis, preventive maintenance and planning sections.
Involvement of corporate and station engineering with the M0 VATS maintenance engineers was observed to be effective during actual testing. --The team verified that Engineering Work Requests are being generated on site to ask for corporate engineering support.
An "all hands" meeting of the maintenance. engineering-staff.was attended. A presentation was made covering the proper method of presenting material to PORC. The department goals and performance indicators were.
discussed.
Items that would require support prior to taking the mode switch to startup were discussed, including the em'ergency cooling tower and loss of off-site power test.
Issues raised by the NRC electrical team inspection (277, 278/89-07) were also discussed.
3.6.2.5: Control of Work Corrective MRFs are generated in one of two ways. A component failure is identified by operations.or an Equipment Trouble Tag is initiated by anyone who sees a problem. The identification of-potential work items by the operations staff.is documented in the systems status turnover sheet. The shift manager is responsible for determining which items are of the most-importance to plant operation and for placing these items on a " Hot List".
This list is reviewed during.the morning meeting in the control room, which is attended by most departments on site.
Once it is decided' that the' work is in fact on -the priority list, it is scheduled by maintenance personnel during their morning meeting. The licensee has instituted a new , integrated tracking schedule (TRIPOD) which will take the inputs from each group, and through a meeting verify or change the priority of work items. Individual shop foremen get a daily working list and were observed to be using and following them in the field.
A weakness was identified in the maintenance team inspection report (NRC Inspection 277,278/88-17) dealing with the identification of Technical Specification (TS) Limiting Condition for Operation . (LCO)' time restraints. The operations department is ! ' currently keeping an LCO log for each unit and common i systems.
Use of this list is outlined in the Operations Management Manual and was found to be adequate to document the entry into an LCO. The use of J the " Hot List" combined with the morning and TRIPOD ! meetings was found to be adequate to identify and track ' l, work which could be related to an LCO.
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- The MRFs are generated by ma'intenance planning using the computerized history and maintenance planning.
system (CHAMPS) system. A MRF is' divided into'seven sections. Section 1-is the initiation portion, which-discusses the component / system in question. Section 2= is the investigation section which lists specifics about the component / system as.to.the.QA category, ASME-- class, electrical class',' environmental qualification class and the need for a specific procedure.
Section'3 ' lists the planned activities to correct a problem,
- which could include simple instructions to correct a leak, instructions to perform an attached, more complicated procedure called a work instruction,'or instructions to perform a PORC' reviewed and approved maintenance procedure.
Section 4 lists the blocking . permits used to isolate a component / system to allow work including.a signature by shift management that the blocking permit has been set and that work can: commence. Section 5 describes the defect, cause of failure, corrective actions taken and'the work performed, including comments and-signatures of craft 'and supervisory personnel verifying completion of work and inspection by QC.
Section 6 provides the turnover after maintenance is complete including verification of-L required operation and acceptance by shift management.
Section 7 documents staff review-including any possible'
-trending or updating.that might be required.
' The inspector attended several planning meetings dealing with outstanding work items and operational-verifications.
These meetings were specific to restart items for a specific system.' The operations department was represented and gave input'for prioritizing these-items.
3.6.2.6 Post Maintenance Testing Post maintenance testing is taken into account on the MRF which is generated by maintenance planning prior to the job. The testing that the planner considers
adequate is documented in section 3.
This section could contain' cycling and/or performance of actuator ! testing or local leatrate testing on a valve.
The team
! verified that if as-found local leakrate testing is required this is specified in section 3 as well.
When the MRF is returned to the control room after work is complete, shift management decides if additional testing is required to verify operability.
If none is
required, shift management signs the MRF completing acceptance of the component / system.
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j i J testing'is required, it is documented on an operational . verification. form (OVF). The OVF is performed if.at all possible. :If the OVF can not be completed at that . time, it is sent along with the MRF.to the group that' is. responsible for-the testing. When'the OVF is completed, .snift management signs off the OVF and MRF,- and both are-forwarded for closure to maintenance planning.
3.6~2.7 Maintenance Backlog . The ' team reviewed.the tracking systems used to monitor.
status of outstanding MRFs for corrective and.
preventive maintenance items.
The licensee uses a quarterly rolling schedule to track corrective maintenance.that is not required to support restart.
The quarter is broken down into weekly increments and work is scheduled into these increments.
Each week allows work to be. completed on systems or subsystems so that the work'will not affect other systems.
The licensee uses a five day look ahead schedule to track the items.that must be completed prior.to restart.
For Unit 2, there are approximately 400 MRFs that still-require work and approximately 1000 outstanding OVFs.
Preventive maintenance items that are required to be completed during an upcoming quarter are provided to.- maintenance planning by maintenance engineering.
These items are then scheduled into the rolling window.
<. schedule..At present there are'no outstanding PMs to be completed prior to Unit 2 startup.
The maintenance team inspection raised questions about deferred CM and PM. items. The CM currently listed to be completed prior to Unit 2 restart has been~ compiled by maintenance and operations.
Operations decided what maintenance has to be completed prior to startup.
PM that is deferred is reviewed by the maintenance engineer prior to deferral.
3.6.2.8 Work Reviewed The team reviewed ongoing work items and associated MRF packages. A complete list is presented in Appendix C.
In several cases the team monitored the performance in the plant. Work items with specific comments follow: l' l l - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _. - _
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MRF 8811954, Replace spectrum breaker for unit 2 -- torus to drywell vacuum breaker air operated valve.
The operations procedure which removes and reinstalls the breaker was specified and attached.
Maintenance Procedure M-56.1 which performs maintenance on 480 V breakers was specified. The inspector reviewed this procedure and the attached breaker overload calibration sheets.
No deficiencies were noted and the personnel involved were extremely helpful.
MRF 8863872, Watertight doors. A firewatch was -- posted on both sides of the' watertight door as required. The lead man appeared to be knowledgeable of the work involved including all RWP requirements.
MRF 8461272, DC MCC Breaker Inspection.
Procedure -- M-57.8 was being followed to perform the inspection. One step of the procedure directed the workers to examine relay 49, but no relay was so marked in the breaker.
In reply, the supervisor produced a Cutler-Hammer drawing of the breaker which correctly identified this relay.
MRF 8901104, 8901244, Motor Operated Valve -- Analysis and Testing System (MOVATS) testing of Condensate Long path. Recirculation Valves MO-38A and 388. An isolation signal received while in long path recirculation caused valves MO-38A and 38B to go shut (see section 3.1.8).
Having a. shorter stroke time, M0-38B shut.first. M0-38A did not subsequently fully seat. An investigation by the licensee deter-
mined that after M0-388 shut, M0-38A was forced to shut against the full differential pressure of the 2C condensate pump and failed to shut.
Due to a problem in long path recirculation procedure S.7.1.0, this event also caused the condensate pump flow to drop 1900 gpm, below its 3000 gpm min flow specification.
The procedure has since been changed to require placing short path recirculation flow controller CV-2110 in automatic.
The condensate pump was monitored for possible degradation and none was found.
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,: L The licensee remeasured the MO-38A and 38B thrust settings using'MOVATS and a new system called I ' Valve Operator Test and Evaluation System (VOTES).
Where MOVATS uses-spring pack deflection as an indication of valve thrust and is calibrated with
a load cell while stroking the valve in the open direction, VOTES measures valve yoke tension by means of a directly attached strain guage which.is - calibrated by measuring valve stem compression during valve closure.
M0-38A and 38B'are specified to be set at 21'000 , pounds force (1bf) which is what MOVATS measurements yielded.
VOTES data however, indicated the thrust as 13,000.lbf. A full differential pressure test was conducted on M0-38A with the torque setting adjusted to produce a thrust of 21,000 lbf as measured by VOTES.
At this new setting, the valve seated correctly. The test was rerun on MO-38B (with 38A fully' shut) with _ essentially identical results.
Raising torque setting.
to yield the specified. thrust as measured by V0TES again produced proper valve operation against full differential pressure.
The licensee'then brought in MOVATS representatives and reperformed-the tests. This time, the MOVATS sensors on the valves'were first recalibrates. The calibration showed that the conversion factor between motor torque and-valve thrust had changed significantly.
This was apparently an unexpected effect. Test results using the new conversion factor. yielded close correlation between M0 VATS and V0TES data.
The. licensee performed static (without flow / differential pressure) testing on motor operated valves after the extensive rebuilding effort.
These results showed that on some valves the actual MOVATS results were better than the vendor data. Because of this the licensee reduced the torque setting on some valves to below the vendor required ranges. This was done to reduce the wear on the valves. The effects of lowering these settings on the valve operability under a differential pressure condition were not considered.
Due to the failure described above the licensee is reviewing any valve whose torque switch setting is below the vendor data, and is performing flow / differential pressure calculations to determine their
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1 acceptability. The' licensee suspects that. torque switch settings will have to be changed on'some valves.
This item is unresolved pending licensee'and NRC review ~ prior to restart (277/89-81-03; 278/89-81-03). (see Section.2.4.8) ' 3.6.2.9 Maintenance Engineering.
The team discussed several different topics with- .the maintenance-engineer and other people in his organization. The maintenance engineer has been in his current position for approximately one; month and is still getting familiar with the persons who-work for him..Recently the component engineer position was created. These people will act as specialists for components on site. They are intended to reduce-the use of corporate-maintenance personnel, under normal conditions.
If a need to have extensive specialist help arises, these engineers will. coordinate this-with corporate and vendor personnel.
- The maintenance planners will specify if an engineer should be.directly involved.in a1 specific MRF by using a code. The MRFs.that require engineer support are taken off the computer daily.
Presently there are approximately twenty of these - ) outstanding.
Thef failure tracking system was' described to the team. These persons review each MRF and determine if a failure has occurred and if a failure analysis report-(FAR) need be completed. This decision is reviewed by the supervisory engineer.
The inspector reviewed two'of these FARs: FAR F88008M054, failure of GE magne blaste -- circuit breaker prop spring, completed on June 13, 1988.
-- FAR F88011M009, failure of standby gas treatment 24 inch butterfly valve.
In both cases the root cause analysis was proper I and the recommendations provided to correct these ) problems were well defined and should correct the i deficiencies.
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' t-This group also. reviews'old MRFs and NPRDS items to' check for. recurring problems or applicability to Peach Bottom..This'is done-by running a search on the MRF computer to.see what type of maintenance has been performed on a specific component.
If a recurring problem is noted the Maintenance Engineer is notified using a form
- which requires that a resolution be provided.
Several of these forms were reviewed and the-resolutions seemed to be technically adequate.
The method by which the preventive maintenance program was developed and implemented was
discussed.. The program appears ta be adequate to ~ ' schedule and track the required items. The Maintenance Engineer is presently' trying~ to bring all preventive and diagnostic maintenance programs such as ISI, IST, vibration and oil analysis, and ' infrared inspection under his control. This.would centralize the tracking and evaluation processes needed.
3.6.2.10 Conclusion The licensee's' staff can function to schedule, perform ! and control maintenance activities. The maintenance ' department appears to interface well with 'other-organizations and understands their goals and perfor-mance indicators. :The backlog. of corrective and preventive maintenance items has been significantly-reduced and the control now in place should not allow a large backlog in the future. The observations-conducted for ongoing MRFs demonstrate that the maintenance crafts are well trained and understand their functions. Management commitment to the , maintenance effort is evident.
3.7 Engineering / Technical Support 3.7.1 Scope of Review The team assessed the effectiveness of engineering support activities regarding the ability to enable safe operation of the facility.
The team placed primary emphasis on the evaluation of ongoing activities at the site concerning design, review, planning, installation, and testing of design modifications.
The team selected a sample of the in progress and recently completed modifications, and reviewed ! the modification packages to assess the quality of the work and its review, walked down the installed hardware, and _ - _ _ _ _ - _ _
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' interviewed the-involved personnel.
In addition to ' modifications, the team evaluated engineering support activities regarding the' day-to-day design issues at the-site, e.g., temporary modifications and setpoint change , '- control.
Finally, the. term evaluated,the working relationships between the various organizational elements i involved in engineering support activities.
3.7.2 Site Organizational Approach to Engineering Support 3.7.2.1 Modification (Mod) Team Since November 1988, Peach Bottom has applied a team approach to the modification process, which is described in plant administrative procedure, A-14, Plant Modifications.
Each Mod Team is-led by a site engineer, either a modification group engineer or a system engineer, and has representation from applicable site organizations, i.e.,; Operations, Maintenance, I&C, etc., and from the engineering organization,-normally the Nuclear Engineering Department' (NED).
Each modification has a Mod Team, and the members of-the team vary according to the nature of the modification.
'Although the responsible organizations retain their-functional responsibilities, the Mod Team enables site perspectives-on the design approach, operating methods,. alarms, maintenance, and testing to be addressed throughout the modification process and enables the site to benefit frem the' design engineer's understanding of the design basis - and design constraints.
The team attended Mod Team meetings, reviewed min'utes of Mod -{ Team meetings, and discussed the results of these meetings l with Mod Team members.
For example, when the-team attended the third Mod Team meeting for Modification 5095, its purpose was to review and discuss'information associated with the upgrade to the electrical power supply for the ECT level control system.
Representatives from design, operations, construction, and systems engineering participated.
The discussions appeared productive, with a wide range of expertise presented. The team discussed the modification with the systems engineer and observed that the systems engineer actively participated in the Mod Team Meeting. The team noted that the lack of a clearly defined interface between NED and Peach Bottom procedures caused confusion at times during the meeting.
In addition, the discussions were abnormally involved in trying to fit modification activities into a tight schedule.
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. 94, The team noted design changes resulting from the Mod Team approach, including revised alarm annunciators to resolve . operator concerns, revised piping layouts to resolve maintenance ~ accessibility concerns,'and revised logic circuits to resolve testing concerns.
Unfortunately, due to the recent adoption of the Mod Team approach, these design changes occurred during the installation phase and required rework, but such changes will likely be part of.the initial . design in subsequent modifications. The team concluded that the Mod Team approach and the synergy.that results represented c strength that has resulted and should continue = to result in better designed modifications, more able to support safe plant operation.
3.7.2.2 System Engineers The, system engineers play a pivotal role in modifications '- and the engineering support of plant activities.
Regarding modifications, the system engineers have the primary responsibility for writing and performing the Modification. Acceptance Tests (MATS), the testing done by the plant staff.
following completion of installation activities.
In addition, the2 system engineers are involved in.the initiationiof modifi--.. cations, the review of~ modification safety evaluations prior to PORC approval, and the Mod Team (frequently as the leader).
Regarding routine engineering support activities, each system engineer is responsible for several plant systems.
For these systems the system. engineer is' the focus for operational, design, testing, and maintenance problems. The system engineer initiates modifications and writes Temporary Plant Alterations, setpoint changes, and special test procedures to resolve the problems. The system engineers review system performance trends and expected operating.
modes, review procedure changes, walk down the equipment, and perform some routine testing associated with their continuing overview of their assigned systems. Significant training resources have been allotted for extensive system engineer. training, which will include system design and operation, simulator review, and engineering skills; completion will take six months.
The team reviewed MATS associated with the above modifications, Temporary Plant Alterations, and Setpoint Change Requests.
The team had concerns in the MAT area, which are discussed below. Generally, the team concluded that some of the system engireers were enthusiastic and
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generally knowledgeable about their system..The technical quality of their work was good, and _there were numerous examples of-positive impact that the system engineers had on the_ condition and capability of their systems.- However, the team noted that the system engineers were somewhat inexperienced as more than. half of the degreed engineers have less than two years experience. Also, within the Technical Department the three' supervisors of system engineers each have at least ten system. engineers _to _ supervise, in addition to collateral duties such as maintaining a staff SRO. license and being a PORC member.
'The team concluded that there were no imminent. problems with this organizational structure and that plant' management should continue to review the ability of the supervisorssto-oversee and train the. system engineers.
< Based on the team's review of MATS and the observation of an in progress MAT on Modification 2590 (revised Cardox controls for. diesel generators), the team noted commendable l test controls regarding the lifting of electrical ' leads and l fuses and the installation of jumpers.
Specifically, the system engineers consistently applied the concepts of double verification (DV), i.e.,-both-test personnel jointly confirm the correctness of an action prior to its initiation, and ! independent verification (IV), i.e., two test' personnel < separately and independently confirm the proper equipment ' condition following an action. Also, the MATS 1had second signatures noted for DV and IV, and all questioned personnel understood the intended actions correctly and performed the actions accordingly.
3.7.2.3 Modification Group The Modifications Group performs the field engineering, installation, and electrical testing of the modifications.
Although the group is currently an organizational part of the Peach Bottom station, plans are underway to have the Modification Group become part of NED. The team reviewed the group's interaction with other parts of the station organization and concluded that this interaction was good.
l The team interviewed the section supervisors regarding their L functions, walked down_ portions of completed modification work, reviewed modification packages, and attended group meetings. A problem with the safety related tubing installed during Modification 1316 is described below.
The team concluded that the emphasis placed on updating control room copies of piping and instrument drawings l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _______;
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(P& ids) following completion of installation work but prior to testing represented a strength. Such expedited-recognition of changes on control. room drawing copies should better enable operators to respond to activities in the plant' Specifically,-when field work is completed,-the . as-built configuration is shown on a P&ID revision marked as , a red line drawing and placed in the control room drawing.
files within two days. Two drafting personnel-are employed onsite to expedite this process, and' verifications and checks are incorporated into the change process. The team noted the numerous red line drawings in the control room and the operators'. reliance on them. The team confirmed that modifications walked down had been recorded in red line drawings.
The team attended two modification status meetings-within .the Modifications Group and.found the meetings to be j effective.
During the meetings the applicable working " groups were represented, the status information was current.
and well organized,_and the interaction between groups was l productive.
I a The team noted that document _ control of uork packages, i including inspection records, was thorough and provided for -
daily returns of work packages being utilized in the field, , frequent audits by document control. personnel, segmentation .; of the work packages into color coded parts,_and review by l quality control and installation personnel of the completed i . documentation prior to closecut of the work package.
It , appeared that some of these actions had been recent ' corrective actions to previous document control problems.
3. 7. 3. Modifications (MOD) Reviewed The team reviewed the safety evaluations of all the following modifications and reviewed the field installations , of these modifications, except' modification 1505, which was I inaccessible. A sample of the drawings and supporting i documentation was reviewed.
MOD 865 Alternate Rod Insertion (ARI) MOD 1316 Safety grade instrument gas supply for valve operation * MOD 3497 New reactor vessel level instrumentation *
MOD 1505 Flow switch in the Standby Gas Treatment System (SGTS) fan discharge MOD 1660 Safety grade nitrogen accumulators in drywell* MOD 5095 Pump and transmitter vents, safety grade
power supply,.and level control system for ' Emergency Cooling Tower , i _ _ - - - _ - _ _ _ _ - - - - _ - - - -
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L L Those modifications identified by.an asterisk were' covered by QA Audit PA 88-513, of modifications between November 1,-1988 and February 2, 1989. The audit had findings in eleven' areas, and a Root Cause Task Force has been established to ensure a programmatic review of the finding resolutions.
Each of the findings has been entered into the PECo Master Open Item List to . ensure proper closecut' prior, to restart.
It should be noted that due.to the extended duration of the
modification process (design work on modification 865 began in 1984),-the design and review-processes used varied depending on the programs applicable at that time. Most installation and testing work occurred during the past two years.
3.7.3.1-The team identified problems regarding'the tubing supports installed as part of modification 1316, which'will provide a safety grade supply of instrument gas to '17 air operated isolation valves associated with' purge and exhaust lines into the primary containment. When completed, the ' instrument gas will come from the bulk nitrogen facility outside the reactor building and be supplied via piping and tubing to the valves. This will' permit removal of the bottled; gas in safety grade moorings at each valve location.
' During the current outage on Unit 2, the valve connections and the bulk connection through the reactor building wall were completed.
Specifically, the team found-that the. tubing to the torus. supply valve (AO-25218).was installed in an inadequate support, such ,that its ability to withstand seismic forces was questionable.
The tubing was installed inside new Unistrut, U-shaped metal pieces, that had been attached to a previous nonsafety grade Unistrut support fastened into an approximately 3 ft. by 6 ft.
right angle attached to the floor and the wall. There appeared to be a lack of' rigidity in the plane parallel to the wall.
PECo agreed with the team's concern and initiated Non-Conformance Report (NCR) P89-115 to evaluate and correct the problem.
Additional PECo and NRC review of the tubing installations identified additional problems, including missing tubing clamps, loose tubing clamps, and tubing bent onto sharp edges of Unistrut, which were added to the NCR.
The team reviewed' specification M-2828, which addressed the tubing support installation, and found it lacking sufficient detail to adequately control the tubing installation.
For ' example, M-2828 specified tubing clamp spacing but not torquing , i requirements, and M-2828 limited Unistrut spans to five feet but left the acceptability of a 4 ft. by 4 ft. right angle unclear.
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PECo attempted to retrieve the quality control inspection records associated with the 17 valves, but could find records for only 13 valves, not including the torus supply valve.
The retrieved records showed that inspections had been performed between April 1987 and November 1987, but the inspection records did not clearly address the specifications or acceptance standards used for inspection of the tubing supports.
The Manager, Nuclear Quality Assurance (NQA) stated that to resolve concerns with tubing supports, all Unit 2 tubing installed under modifications back to initial construction would be rein-spected prior to Unit 2 restart to verify acceptable installation (see section 2.4.9).
This item is unresolved pending completion of the licensee review (277/89-81-01; 278/89-81-01). The Manager, NQA stated that PECo had previously found problems with missing inspections and missing documentation, that PECo-had initiated corrective actions, and that a major upgrading of quality control activities was in progress.
Specifically, QA Audit PA-88-513 had a finding concerning the adequacy of quality control, which is listed on the Master Open Item List (MOIL) for closeout prior to restart. Along with the possible addition of tubing supports, the Manager, NQA noted that following significant auditing and reinspection efforts, only one area (flexible hoses in the drywell) was found in which programmatic shortcomings had permitted a safety significant problem to go undetected.
The Manager, NQA stated that based on the corrective actions to date the quality control inspections currently being performed have acceptable levels of quality assurance and that continuation of quality control activities was acceptable.
The team noted the improvements in document control to ensure quality control inspections are performed-and documented prior to turnover of the modification to the plant for testing.
3.7.3.2 The team concluded that the design basis was not being properly applied to all modifications and that this problem was evident at the site in the MATS. To some extent PEco had previously noted this weakness and taken corrective action.
For example, in September 1988 NED administrative procedures were revised to require that modification output l documents from NED, e.g., Engineering Work Letters (EWLs), include the expected acceptance testing and the acceptance criteria. The team noted examples of recent EWLs with , testing acceptance criteria.
Further, the Mod Team approach described above enables better interaction between NED and , Peach Bottom regarding the acceptance testing and its ' l acceptance criteria.
Notwithstanding the above, the team noted l continuing problems as evidenced by the following: ! L '
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, ' i i ! . J 99- 'j
Modification 1505 revised the design of the Standby' Gas -- Treatment System (SGTS) to provide a flow switch to start the backup fan if the-discharge damper failed closed on the primary fan. The existing differential pressure sensor had been found unable to determine closure of the damper-and could have resulted in the.
SGTS becoming inoperable.
Prior to installation, the' flow switch had been calibrated electrically in the-I&C lab.
1The MAT spectfied that the damper be slowly closed to verify that the backup f an started. The MAT specified that the fan discharge flow at which the flow switch.
initiated the backup fan be measured; however,- it-specified that this was "(for info only)".
During'the actual test the flow switch was unable to detect a fully closed damper, and the modification was determi.ned toLbe ur, acceptable-A revision to the . modification was in progress to start both fans during an automatic SGTS initiation.
When questioned about the flow measurement, the system engin'eer and his supervisor stated that the MAT was intended to confirm that the flow. switch functioned properly in starting the backup fan and that the I&C calibration of the flow setpoint had properly-determined the flow actuation setpoint..The team disagreed and stated that-the-flow measurement-represented the primary acceptance criteria for the test.
PECo noted that all MATS are summarized in a MAT-Report and approved by PORC, and that the flow measurement actuation point would have been reviewed at this point had the flow switch actuated.
= When questioned about the design basis for the flow ! I switch actuation setpoint, the design engineer stated that there had been no specific basis for the setpoint and that the flow switch had been designed simply to j detect a closed damper. The team disagreed with this approach and stated that there should have been a l specific design basis for the flow switch such that operability of the SGTS would have been assured at flows as low as the backup fan initiation setpoint. The EWL on , this modification' had been issued prior to September 1988
and had not addressed the testing or acceptance criteria.
-- Modification 865 installed a means of alternate control rod insertion in accordance with 10 CFR 50.62 by means of solenoid operated valves in the scram air header to block the air supply and vent the air header to the control rod drive hydraulic control units.
During the _ _ - _ _ - _ - _ _ _ _ _ - _ _ _ ._ \\
- - - _ -. - _ - _ - i.
100-L' MAT testing the system engineer noted that although the control rods inserted acceptably, the air operated-vent _ and drain valves for the scram discharge volume (SDV) did not close as would have been expected when the . scram air header was vented. The MAT did not specifically address the vent and drain. valves, and there' were no acceptance criteria for them.
PECo review found thatLthe solenoid valves had been installed downstream of the line to the SDV vent and drain valves, such that the air pressure to the. vent and drain valves was maintained.
The NED design engineers stated that the regulation did not address the vent and drain valves, and the valves'were overlooked during the design work for the modification.
Although the modification had been initiated in.1984, the- ,' ' EWL had been revised recently and included proposed testing and acceptance criteria without mention of the.SDV valves.
This oversight had not been found by PORC during its approval of the' safety evaluation and the MAT. The team concluded
- that discovery of the problem during the MAT but outside of the prescribed test represented good inquisitiveness and evaluation by the system engineer, but it also represented
. . a design engineering error.that w*ts not found by the licensee duringithe review and approval process.
To ensure that other potential problems in' modifications were adequately tested in the MATS.during the Unit 2 shutdown, the system engineers' reviewed the applicable.
modifications and evaluated each MAT to ensure-that the testing approach had been correct and that the acceptance test would have properly detected any design errors. The evaluation found some instances where the test results should have been better documented and corrective actions were taken, but found no technical inadequacies. The team reviewed the evaluation on a modification by modification basis with system engineering supervision and concluded that the MATS represented an adequate level of assurance that the modifications were designed and installed acceptably.
The team concluded that PECo should continue its efforts to upgrade the assurance that the design basis of Peach Bottom is applied to the design, installation, and testing of modifications. The team noted that the PECo Configuration Control Management Program was underway and that PECo had made a presentation to the NRC regarding the program in November 1988.
_ _ - _ _ _ _ _ -. -- $
- - - -- _ _ - - - - - _ - - _ _ - - _ - - - _ _ - - - -. _ 101 3.7.3.3 The team concluded that the format of MATS did not clearly identify the acceptance criteria of the MAT.
Plant administrative procedure A-89, Modification Acceptance Tests specified that acceptance criteria be included in each MAT, but the format for such acceptance criteria was not ' addressed. Accordingly, the acceptance criteria were not specifically identified as such and were included in the MAT along with the detailed steps of-the test procedure.
The reviewed MATS were frequently comprised of thirty to forty pages of testing steps. Accordingly, the team concluded that this lack of identification and emphasis on acceptance criteria could have enabled the acceptance criteria problems noted above to have been overlooked during the review process.
PECo agreed to revise the MAT format such that acceptance criteria are specifically identified in a separate section in each MAT.
Procedure A-89 was being revised and the team reviewed a draft of the A-89 revision and concluded that the revision addressed the above issue.
3.7.4 Emergency Service Water (ESW) System The ESW system provides a reliable supply of cooling water to selected safety equipment.
The system is designed to meet Seismic Class I criteria and operate under flood conditions with a loss of offsite power. Two, one hundred percent capacity pumps provide cooling water to the diesel generators and to safeguard equipment room coolers upon loss of normal service water. Pump suction is normally from Conowingo Pond, with ESW discharge back to the pond. During flood or dam failure, the Emergency Cooling Water (ECW) system functions as the ultimate heat sink.
, The ECW system, in conjunction with the high pressure service water (HPSW) and ESW pumps, provides an on-site heat ! sink so that the reactors can be safely shut down in the unlikely event that Conowingo Pond is unavailable.
The ECW system is also designed to meet Seismic Class I criteria and operate with loss of offsite power.
i The system has a three cell (50% capacity each) emergency cooling tower (ECT), a reservoir, an ECW pump, and two ESW booster pumps.
Return water from HPSW is pumped directly to the emergency cooling tower, and water from ESW is directed l to the tower via an ESW booster pump. The HPSW/ESW pump l structure bay level is controlled by gravity drain from the I reservoir.
ESW pumps are backed up by the ECW pump.
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_ _ - _ _ _ _ _ _ _ _ _ _ _. - - _ _ _ _ __ _. _- _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - - _ _ - L I; ] 102' However, to consider the ECW pump operable as an equivalent L ESW pump,.the Technical Specifications require at least one ESW booster pump and.two emergency cooling tower fans to be . operable.
The' team compared a sample of components, equipment, and-instrumentation and controls on COL 48.1.A ECW (Units 2 and
3) with the P&ID, M-330.. Similarly, COL 33.1'. A-3 ESW (Unit i 2 and common) was compared with P&ID M-315..No discrepancies were found.
During a field walkdown, the ESW/ECW systems engineer: discussed problems that had occurred with pipe movement and supports on the ECW system. This was reviewed in'a previous ~NRC Inspection.
Instrumentation has been installed to
- measure-pipe movement during-system operation. The pipe and
'_ supports appeared to be in good condition. The Systems . Engineer = indicated that he walked these systems down on a weekly basis. This was considered a good practice by the - team.
The team noted that housekeeping appeared to be a priority item. No trash, fire hazards, or other materials were observed in the areas.
Pumps and valves appeared to be maintained with no~ packing leakage observed.
Labelling on pipes and other components was clear.
-During the walkdown, the team noted the, following ESW/ECW.
equipment to be either out of service or tagged: Unit 3 Bay. Level A, LI-3804A&B -- -- Sluice gate M0-3233A -- Sluice gate M0-2213 -- Sluice gate M0-3213 -- Discharge to cooling tower, MO-3803 -- Bay inlet MO-3804A & B Unit 3 ESW isolation M0-3972 -- ECT fan out of service due to high vibration -- As part of the walkdown, the team reviewed system operating (50) procedures. The S procedures had been completely rewritten for both the ESW and the ECW systems. The new procedures had not been formally issued. A modification on Unit-3 impacted a check-off-list and the licensee is waiting until the check-off-list can be revised before issuing the new procedures.
The team reviewed both the new (not issued) and current procedures and noted improvements in the new . ! procedures.
Procedures reviewed are listed in Appendix C.
Several comments were provided to the procedure group based upon this review.
No problems were identified.
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_ _ - _ _ - _ _ - _ _ - - - __ _ _ _ _. _ _._ . _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - 103-The team compared Technical Specification surveillance. requirements with the licensee's surveillance tests.
It was noted that Technical Specifications may not adequately address the ECW-system operability'. This conclusion was based upon a recent-( test (SP-630) and-studies. performed by the licensee. The licensee ' is aware of this problem. A Technical Specification amendment request has been made which should provide,for better surveillance testing.
Because of problems reported by the licensee,-the team-reviewed the operability status of the ESW and ECW systems.
Emergency Cooling Tower fans B and C are out of-service awaiting maintenance to correct a vibration problem. The A-fan was_recently repaired. Technical Specification 3.9.C(3) states.that to consider the ECW pump operable as an - equivalent ESW pump, at least one ESW booster pump and two ECT-fans must be operable. Both the Technical ' Specifications and the FSAR indicate that two fans are required.
An engineering evaluation concluded that the ESW booster pumps will operate if only one ECT ' return valve MO-501 is open. With two' valves open-the pumps trip on low pressure.
. L The FSAR and Technical Specifications indicate that two f cells (fans) are available. The problem of the ESW booster pumps tripping on low pressure has been recognized for a long time by the licensee.
, The licensee. initiated modifications (MOD 5095) to the ECW system during the week of January 16, 1989.
Vents-will be installed to vent the ESW/HPSW pump structures and level ' instrumentation. These vents are required for proper ECW safety operation. A second modification involves replacing the non-seismically qualified power supply to the level control system with a seismically qualified power supply.
l The third modification, which can be completed after startup is to replace the level controllers.
< l Another modification (MOD 2106) was initiated on Unit 3 to l' replace the ESW system piping with a more corrosive
resistant pipe material has been completed, except for testing. A similar modification for the ESW piping in the ECCS rooms (MOD 2371) on Unit 2 was completed during a past outage. The remainder of ESW large bore piping on Unit 2 is planned for replacement next outage.
The ESW piping on Unit 2 is tested monthly to ensure flow to the coolers.
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_ - _ - _ _ - _ _ _ _ . I 104- ,y.;. As/part of the system status review the team examined a - draft NED engineering analysis of the ECW system which . formed,the basis for a four hour ENS call to the NRC on , February 2,.1989. The study concluded that the ECW system . could not perform its design function. With respect to'the ESW booster pump the study recommended ESW flow to the'ECT through one cell rather than two, with HPSW flow through. two' ' cells.
Procedure A-131 was used to_ document the possible inoperability of the ECW system'as a reportable event on ~ January 5,.1989.
Based upon the licensee actions to correct
- the design and operability problems the team questioned the delays in making the four hour ENS call.
Further. evaluation of the timeliness of reporting will be made after the LER is received. The team also examined a draft ISEG report PB-88-10, Supplement 1, which arrived at the same' conclusions as NED. The ISEG report noted several long . standing problems with the ECW system including the ESW
booster pump problem.
The team reviewed LER 3-88-11 dated December 21, 1988, which ' discussed a one inch diameter hole discovered in the HPSW pump bay structure. An error was noted by the team in the event l analysis. The LER stated that when the water level reached about 109 feet (four feet below the hole) the pump ' - bay would be isolated'as described in. Special Event' Procedure 1SE-4." Flood". The team noted that SE-4 calls for
pump bay isolation-at 116 feet which'is three feet above-the ahole.
The' licensee initiated actions to correct the LER. A revised LER 3-88-11, revision 1, February 17, 1989, was reviewed by.the team.
Final actions taken to correct the licensee identified problems with the ECW system will be evaluated by the NRC when they are completed. A test to demonstrate system operability is.to be-completed before restart. The team believes the licensee is giving these problems priority attention at the present time and must continue in this effort. The ECT/ECW system's capability to function as designed is unresolved and must be demonstrated prior to restart. (277/89-81-04; 278/89-81-04). (see Section ' 2.4.10) 3.7.5 Conclusions The team concluded that PECo engineering activities had acceptably supported the shutdown and are capable of supporting safe reactor operation. A problem regarding the seismic design adequacy of a tubing support will be resolved prior to restart , by PECo reinspection of all Unit 2 tubing supports installed _ _ - -- - -_ --_ - - - - - - - - -- ,
. - _ - _ . .
> 105 l i under modifications-and by subsequent repairs.
In addition, the licensee committed to show that their root ccuse analysis work-on the modification audit adequately encompasses this p.roblem.
PECo resolved a team concern on modification acceptance testing by reviewing the planned and completed testing to verify- . that the testing was adequate..The team concluded that the recently instituted Mod Team approach was a. strength that had resulted in and should~ continue to result-.in better designed-modifications..The establishment of system engineers'within the plant's Technical Department'has provided a. coordinated, focused method for overseeing the engineering' support activities by system, and the system engineers have already had positive impacts.on.their. systems. Overall, the team concluded that engineering activities.have been acceptable and that improvements in progress within the engineering programs should enhance PEco's ability to support safe reactor operation.
'3.8~ Security / Safeguards 3.8.' Scope of Review Security / safeguards was assessed: 1) by observing security force personnel during team member ingress to the protected area; 2) during plant tours; and 3) while observing operations, maintenance, I&C, and health physics activities.
The third area was used to determine the effectiveness of interaction between security and other on site organizations. A programmatic inspection of security was not performed because an in-depth security team inspection was conducted from January 23-27, 1989 (see NRC Inspection 50-277/89-80; 50-278/89-80).
3.8.2 ' Protected Area Search Observations During team member entries into the protected area, the quality of searches performed on personnel and hand carried items was assessed. One morning during th.e inspi.ction, a long line into the protected areas was encountered.
Several inoperable l explosive detectors caused the delay. The Nuclear Security Specialist (NSS) explained that surveillance tests (STs) on.
security equipment is now being performed around the clock due to the recent addition of nine additional ST qualified personnel.
The ST for the explosive detector was performed at about 4:00 a.m., and several explosive detectors were declared inoperable.
Since there were only several I&C personnel on site at that time who were performing more critical work, the explosive detectors could not be repaired before the 7:00 a.m. rush. To prevent a recurrence of this problem, the ST is now being performed on day shift, as opposed to night shift.
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- _ - _ _ _ _ _ - _ _ _ _ _ - - _ - _ _ _ _ _ - _ - - - _ _ ._ _ __ - _ - _ - - 106 During entry into the protected area, an individual alarmed ~ the explosive detector. A search of the individual and his . hand carried items-was performed in accordance with security procedures. -However, the search did not include a physical search of the. individual's briefcase other tha'n by X-ray.
This weakness was pointed out to the NSS and he agreed. The L post orders were changed to add that a hands-on search, in L addition to an X-ray search, will be conducted on all hand carried items 'if an explosive alarm is generated. The
- governing' security procedure will be changed when the procedure is restructured.
During a. pat-down search of a team member, the guard stated that he was aware of the new NRC rule that prohibits licensee personnel.from providing advance warning of an NRC-inspector's presence.on site. The guard force has apparently.been briefed on this rule.
In addition, the NRC rule will become a nuclear plant rule.
,0verall, personnel and hand-carried items were well searched in a professional manner. Guard force personnel were knowledgeable.
In most cases, security search equipment and security force manpower were adequate to preclude substantive-delays. The only negative observation was a weakness to physica11y' search a hand carried item after alarming an explosive detector.
3.8.3 Plant Tour Observations During plant tours by various team members, several observations were noted. The first day of the inspection.an individual that previously;had vital area access was. denied entry into a vital area.
In January 1989, any person that had access to certain vital areas was denied access to these areas. This action was in response to a Plant Manager concern that too many people had access to these vital areas when they did not need to enter. All personnel who believed they required entry to these vital areas submitted a written request that was reviewed and approved if necessary.
Since the individual was not on site in January 1989,-he was not aware of the 'hange.
However, after a call to security was c made, he was quickly re granted access to these vital areas.
On two separate occasions early in the inspection, the security computer was out of service, causing access to vital areas to be impeded.
The NSS explained that the computer outages were planned.
In response to an NRC Information Notice, the -_ =- __-_-_-__ -___ - __- - - - L l , 107 l power supply switch to the security computer was being relocated into a vital area..In order to complete the_ modification, power - -had to be shut'off several times. -The licensee provided coverage at various areas in accordance with their security procedures.
n The. modification was completed and no'further computer problems L were-noted.
L: During a. tour of the. reactor building, a team member noted an.
alternate path into a vital area (VA) that may-not have been.
monitored by security. An individual potentially could pass through two doors and gain access'to the VA without checking'in with, or being noticed by the posted security guard. The NSS' agreed with the' observation. To correct the situation, the post . orders were changed to have the guard monitor the alternate access point.
In addition, the inner door is now normally kept locked and posted with a sign to notify security prior to . unl ocking.
Through discussions with guards posted in the power block, iteam members agreed that guards were enthusiastic-and diligent-about their jobs. The guards were aware of conditions in their . posted areas and were. familiar with their post orders.
Overall, guard force attitude has shown improvement during
- the past year. -Guards are knowledgeable and familiar with their post orders. One minor weakness was observed concerning a possible unmonitored alternate path into the. drywell.
s 3.8.4 Security Interface During observation of health physics practices, a team ." member noted an interface problem between security and health physics. See section 3.5.2 for a description of the problem.
More effective communication between HP, radwaste and security could have prevented guard force members from making numerous ! (seven) unnecessary entries into a contaminated and airborne area. The door was alarming spuriously, and therefore, security , guards needed to enter the room to conduct a search.
The numerous alarms were caused by door hardware problems, holding the door open, proximity of the step-off pad to the door and a problem with the area multiplexer circuit.
This door problem was identified in early February 1989 by security, but they failed to recognize the problem involved in getting a guard into the roor... In addition, HP or the guards could have elevated the problem to management so a better way of responding to the door could have been implemented.
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- - . _ - _ - _ _ _ _ _ _ - _ - . 108 . The inspector attended a security, HP,.and operations- . interface meeting at which the above topic was discussed.' .Until the multiplexer circuit is fixed, short.. term-corrective actions discussed at the-meeting.were: 1)I&C performed maintenance on.the door; 2).the step-off pad was relocated; and,~3) a letter was issued to all site personnel reminding-them of security door practices. The interface' meeting also discussed otherlimportant topics and was.
attended by the Shift Manager,-Assistant Superintendent of-Operations, NSS, Shift Security Assistant, Security-Contractor Regional VP, and'an HP first line supervitor.
The inspector noted that higher level HP management was not present.
The lNSS stated that higher level HP management has committed to attend future meetings. ~ However, the meeting-was effective and useful.
Overall, interface between' security and other on site groups was good, except for one observation concerning a door. The' inter-- face meeting was. effective,.but higher' level HP management needs to. attend.
3.8.5 Conclusions-Although the: scope of the inspection in this area was limited to observations during facility tours and security interfaces with other groups-in the organization, the team concluded that the security group has been effectively integrated into the shift organization. The new Nuclear.
.. Security Specialist is providing aggressive' leadership for-the' group'and he is actively involved in site interface meetings. Guards were enthusiastic and knowledgeable . particularly with respect to new NRC access not.fication i requirements.
Identified problems with access search.
requirements and health physics department interfaces were thoroughly investigated and corrected.
4.0- UNRESOLVED ITEMS L Unresolved items are discussed in sections 3.5.2, 3.6.2.8, 3.7.3.1 and 3.7.4 of this report.
5.0' MANAGEMENT MEETINGS' The entrance interview was conducted on February 3,1989. Attendees 'are listed in Appendix A.
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- ._- -- _ _. _ _. _ - - _ _. - - _ _ _ _ _ _ _ __ r 109 The team leader' held meetings with senior facility management daily during the inspection to discuss the inspection scope and preliminary findings.
Licensee managers contacted during the course of the inspection are listed in Appendices A, B, and D.
Many other persons at all levels of the organization were also. contacted or interviewed.
Those persons subject to formal team interviews by protocols are listed in Appendix B.
The scope and findings of this inspection were discussed with licensee representatives during the exit interview at the conclusion of the inspection on February 17, 1989.
Exit interview attendees are listed in Appendix D.
No written inspection material was provided to the licensee during the inspection. The licensee indicated that no proprietary material was presented for review during this inspection.
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110-APPENDIX A-Entrance Interview Attendees February 3, 1989 .Name Title-NRC J. Linville Projects Section Chief, Team Leader D. Florek Senior Operations Engineer .T.
Weadock~ Radiation Specialist I. Schoenfeld Human. Factors Analyst, NRC Research' T. Kenny Senior Resident Inspector, Limerick Generating Station D. Caphton.
Senior Technical. Reviewer, Division of Reactor Safety G.' L Meye r. Senior Resident. Inspector, Hope. Creek W.'Schmidt Senior Resident-Inspector, 'FitzPatrick R. Martin Project Manager, NRR T. Johnson Senior Resident. Inspector, PBAPS W. Kane Director, Division of Reactor Projects J. Williams Project Engineer J. Gadzala Reactor Engineer R. Urban Resident. Inspector, Peach Bottom L. Myers Resident Inspector, Peach Bottom ' PECo .J. Austin Modifications Superintendent, PBAPS D. Meyers Support Manager, PBAPS G. Daebeler Technical Superintendent, PBAPS J. Franz Plant Manager, Peach Bottom - F. Polaski Assistant Superintendent, Operations, PBAPS D. Smith Vice President, PBAPS C.-McNeill Executive Vice President G. Rainey Superintendent Maintenance I&C, PBAPS D. LeQuia Superintendent Plant Services, PBAPS A. Wyatt Security, PBAPS G. Bird Nuclear Security Specialist, PBAPS C. Anderson Staff Engineer, PBAPS P. Wright Technical Group, PBAPS T. Cribbe Regulatory Engineer, PBAPS D. Foss Licensing Supervisor, PBAPS M. Ryan Senior Engineer Technical Support, PBAPS D. Wheeler Results Engineer, PBAPS T. Mitchell Engineer, Operations Support, PBAPS
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__ __ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _, p [r x 111 p ' 'D. McRoberts Shift Supervisor, PBAPS R. Sheetz-Shift Supervisor, PBAPS T. Niessen Shift Manager, PBAPS B. Clark.
Superintendent Administration, PBAPS J. Rogenmussen ~ Maintenance, Special Projects, PBAPS 'S. Grosh' Personnel Administrator, PBAPS .E.-Till.
Training Superintendent, PBAPS W.. Thomas Organization Development, PBAPS 'R. Krieger Fire Protection, PBAPS _ J. McGrath Nuclear Information' Management Project S.' Lamb ^ Organization Development Staff (MAC), PBAPS K. Cook Director, Management & Professional Development, PECo ! -J. Forish-Manager, Human Resources & Organization Development, PBAPS G. Lengyel Maintenance. Engineering, PBAPS D. McGarrigan . Superintendent-QC, PBAPS - HH.~ Lamb.
Organization Development H. Watson, ' Chemistry, PBAPS A. Diederich Nuclear Engineering, PBAPS E. Fogarty.
Manager Nuclear. Support,-PBAPS G. Phail.
Restart Support, PBAPS M. Miller- . Restart Support, PBAPS J. Basilio - PBAPS Licensing - PECo Team Leader R. Kankus VP Staff Engineer, PBAPS R. Cochran Configuration Management
G.-Burdsall -_ Configuration Management J. Kernaghan Maintenance Engineering /PM's V. Nilekan Maintenance Staff Support J. McElwain Maintenance /I&C, PBAPS l -- J. Davenport Maintenance /I&C, PBAPS-J. Hesler Radwaste Supervisor, PBAPS M..Hammond Senior Engineer / Maintenance, PBAPS D. Potocik Senior Health Physicist, PBAPS B. Lees Manager Electrical Engineering Others S. Maingi Nuclear Engineer, State of Pennsylvania R. Reichuel Engineer, Delmarva Power M. Phillips Senior Engineer, Public Service Electric and Gas .H. Abendroth Senior Engineer, Atlantic Electric T. Magette Manager, Nuclear Programs, State of Maryland . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _. _ _ _ _ _ - _ _ _
- _ - _ - - _ _ _ _ _ _ - _ - _ _ - - _ - _ _ _ _ _ _ _ _ - _ . . . 112 ll L.
APPENDIX B l.
Persons-Interviewed LCorporate and Site' Management ~. Organizational Development.
.. C. McNeil S. Lamb D. Smith W.. Thomas J.. Franz ~J Fontaine . 'J. Cotton K. Cook F.. Polaski - J. Forish B. Bilanich ' Shift Managebs- -Shift Supervisors G.' Gellrich' A. Clark T; Niessen-B. Stambaugh S. Mannix 0. Woodrow
T.~Wasong-D. MacRoberts-J. Clupp D.'. Warfel Reactor Operators Non-Licensed Operators J. Deni' S. Cohn B. Saxman D. Howard M. Sheridan M. Erdman R. Maldonado EJ. Ballantyne D. Mayberry.
L. MacEntee-G. Angle W. Eagles . T. Winters-S. Hart D. Hommel 'Others E.~ Martin (QA) K. Cepull (Maint) T.. Kirkpatrick (HP) A. Donell (QA)- H. Hoffman (Maint) _ _ _ _ - _ _ - _ _
- _ - _ _ _ - _ - _ _ - _ _ _ _ _ h
, 113-APPENDIX C Activities Observed / Documents Reviewed Surveillance Test Observations o ST 8.1, Diesel Generator (DG) Full Load Test for the E-2 DG , o ST 8.2-2A, Station Battery Weekly Inspection ' o SI 2D-14-43-AICQ, Core Spray Sparger D/P Calibration Check.
o .TL-11-00701T, Calibration of Barton Indicating Switches o' SI 2P-2-55-BICO, Reactor Loop Calibration Check o ST 7.1.1-2, SLC Solution Analysis o ST 6.18-2, Operational Test of A0-2502B o ST 21.8, Core Spray Pump Capacity Test o.
ST 21.5-2, ESW Flow Test Through ECCS Coolers for ISI . o ST 4.11-3,_LPCI Line Vent Accumulator Level Switch Functional o ST 8.7,. Emergency Transformer Daily Surveillance, Rev. 3-L ' 'ST 13.21', Emergency Cooling Water Pump, Emergency Cooling Tower Fans, o ESW Booster Pump Operability, Rev. 12 o ST 13.23, ECW Pump, MO Valve Functional (ISI), Rev. 7 o ST 13.24 ISI ESW Check Valve Functional 33-2-513, 514, 516, Rev. 4 o ST 13.25-3, ISI Exercise of ESW Air Operated Valves - Unit 3, Rev. 6 ST 7.5.2.G, Emergency Service Water Monitor Quarterly Testing, Rev. 4 o o ST 7.5.2.H, Emergency Service Water Monitor Calibration, Rev. 4 o' ST 13.16.2, Functional Test of HPSW Pump Bay Level Controllers LC-2804 A&B, Rev. O, dated 10/17/88 o ST 13.16-3, Functional Test of HPSW Pump Bay Level Controllers LC-3804 A&B, Rev. O, dated 10/17/88 o ST 21.5-2, ESW Flow Test Through ECCS Room Coolers, RHR Seal Coolers, and. Core Spray Motor Oil Coolers - Unit 2, Rev. 1 Maintenance Observations o M-56.1 and MRF 8811954, Spectrum Breakers o MRF 8811927, Pump Discharge Valve o MRF 8812082, Unit 2A CS Check Valve o MRF 8812717, Unit 2 A RHR Testable Check Valve Solenoid Valve Air Supply o MRF 8863872, Watertight Doors o MRF 841271, DC Breaker Inspection o MRF 8901104, MOVATS M0-38A o MRF 8901244, MOVATS MO-38B Operations Procedures and Activities Observed / Reviewed o Operations Management Manual o Operations Manual o Three months of Incident and Upset Reports o-Six months of Management By Walking Around (MBWA) Reports o Various Logs and Shift Turnover Sheets
Administrative Procedures ___-____-_-__- __
_ _ _ _ _ _. _ _ _ _ _ - _ _ _ _,.. _ _ _ _. _ _. _ _ _ _ _ _, _ . 114 o Technical Specifications (Units 2 and 3) o S.6.3.2.A, Normal Seal Steam Startup on Unit 2 on 2/5/89
o S.6.3.2.A, COL, Steam Sealing System on Unit 2 on 2/5/89 o S.11.2.C, Mechanical Vacuum Pump and Steam Packing Exhaust Startup on Unit on 2/5/89 o S.7.6.L, Reactor Feed Pump Turbine Overspeed Test on Unit 2B on 2/5/89 o S.6.3.3.B, Makeup to Reactor Feed Pump Turbine Lube Oil Reservoirs, on Unit 2 on 2/5/89 o PD and A0 Walkaround on 2/6/89 and 2/7/89 o Shift Manager, RO, SR0 and C0 Turnovers on 2/5/89 o Overtime Records o APO Walkdown of New S0 COLs for RCIC System on 2/9/89 .o SO 11.7. A-2, Standby Liquid Control System Chemical Addition on 2/13/89 o S0 52.A-1.A, DG Manual Startup from the Control Room for E-4 DG on 2/10/89 0: .50 52.B.2.A, DG Shutdown for E-2 DG on 2/10/89 o Plant Operator.Round Sheets - Cooling Tower, for 2/2/89 o S.9.4.2.A Startup of the Emergency Service Water System,.Rev. 3 o COL S.9.4.2. A.3, Rev. 2, Normal Operation of Emergency Service Water System o S.9.4.2.B Shutdown.of the Emergency Service Water System, Rev. 2 o S.9.4.2.C Set-Up for Auto-Start ESW System, Rev. 1 o S.9.4.2.D High Radiation In ESW Effluent, Rev. 1 o S.9.4.2.E, Operation of the ESW Chemical Treatment System, Rev. 1 o S.9.10.A, Set-Up for Normal Standby Operation of the Emergency Cooling System, Rev. I o S.9.10.B, Startup of the ECW System, Rev. 7 o S.9.10.C, Shutdown of the ECW System, Rev. 5 o S.9.10.0, Make Up to the ECW System Reservoir, Rev. 2 o S.9.10.E, Routine Inspection of the ECW System While in the Standby Condition, Rev. 2 o S.9.10.F, Routine Inspection of the ECW System While the System is in Operation, Rev. 2 o S.9.10.G, Decreasing Water Level in the ECT Reservoir, Rev. 2 o S.9.10.H, Using ECW Pump as an Alternate ESW Pump, Rev. O, dated 7/.15/88 o S0 33.1.A, ESW Set Up for Automatic Operation, Rev. O o COL 33.1. A-2 ESW Normal Operation o S0 33.2.A ESW System Shutdown o SO 33.7. A-2 ESW System Effluent High Radiation (Unit 2), Rev. O o S0 33.7.A-3 ESW System Effluent High Radiation (Unit 3), Rev. O o 50 33.7.B-2, ESW System Backup to RBCCW Heat Exchangers (U/2), Rev. O o 50 33.7.B-3, ESW System Backup to RBCCW Heat Exchangers (U/3), Rev. O o SO 33.8.A, ESW System Routine Inspection, Rev. O o SO 33.8.B, ESW System Routine Inspection, Rev. O o A0 33.1, A ESW Pump Remote Operation from Alternate Control, Ray. O o A0 33.2, Startup and Normal Operation of the ESW System, Re- " o-50 48.1.A ECW System Alignment for Normal Standby Operation, ,e
o S0 48.1.B ECW System Startup, Rev. O i _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
__ __ -_ . _ _ _ _ _ _ _ _ - _ _ __ - i 115 o-SO 48.2.A, ECW System Shutdown, Rev. O .50-48.7.A, ECW System Makeup to Tower Using a HPSW Pump, Rev. 0 o o S0 48.7.B, Decreasing the Water Level in the ECT Reservoir, Rev. O SO 48.8.A, ECW System Routine Inspection During Standby, Rev. O o o SO 48.8.B, ECW System Routine Inspection During Operation, Rev. O A0 48.1, ECW System Makeup to Tower Using the ESW System, Rev. 0 o ' o A0.48.2, Using the ECW Pump As An ESW Pump, Rev. 0-o SE-3, Loss of Conowingo Pond, Rev. 4 o SE-4, Flood, Rev. 8 o.
Deep Backshift Inspection: i Sunday, 2/5/89 - 2:00 p.m. to Midnite l' Monday, 2/6/89 - Midnite to 5:00 a.m.
Tuesday, 2/7/89 - Midnite to 5:00 a.m.
Wednesday, 2/8/89 - Midnite to 5:00 a.m.
l Sunday, 2/12/89 - 10:00 a.m..to 6:00 p.m.
o GP-2, Normal Plant Startup Rev. 49, PORC 2/2/89 .o 'GP-3, Normal Plant Shutdown Rev. 40, PORC on 2/2/89 o GP-9-2,' Fast Reactor Power Reduction Rev. 4, PORC 2/2/89 L o GP-9-3, Fast Reactor Power Reduction Rev. 4, PORC 2/2/89 ' ST-3.10.B, Core Stability Monitoring, Rev 0, PORC 2/2/89 o o OT-112, Recirculation Pump Trip, Rev. 5, 1/27/89 Meetings Attended l-o Incident Critique on Unit 2 Seal Steam System Problems on 2/6/89 o Shift Turnover Meetings on all shifts and on various days o Incident Critique on M0-38A Problems on 2/9/89 o Daily Plant Status Meetings in the Control Room on various days o Unit 2 Outage Meeting on various days o PORC Meetings on 2/7 and 14/89 o Station Review Meeting on 2/13/89-o Master Open Items List Meeting 2/8/89 o Vice President Staff Meeting on 2/8/89 o Shift Crew Team Meeting on 2/8/89 o NQA Staff Meeting on 2/9/89 o Maintenance Staff Meetings on various days o Station ALARA Council Meeting 2/8/89 o Radiation Protection Staff Meetings on various days MOD Packages / Engineering Documents / Drawings o MOD 865 - ARI o MOD 1316 - Safety Grade Instrument Gas Supply o MOD 1457 - Reactor Water Level Instrumentation o MOD 1505 - SGTS Flow Switch o MOD 1660 - MSIV/SRV Nitrogen Accumulators o MOD 5095 - Package, Safety Evaluation and Design Input Document o Draft Engineering Report, Integrated Cooling Water Test Special Procedure - 630 Event Analysis and Operability Determination Peach Bottom Atomic Power Station, dated February 10, 1989 o A-131, Deportability Evaluation Form, dated 1/5/89, associated with inoperable pump bay level control system - -____ _ _-__-___-_-_ _ -__--_ - - _ _ _
_ _. . 116 o ISEG Report, PB-88-10, Supp. 1, Review of PBAPS Integrated Test of the Emergency Cooling System, dated 2/3/89 o Engineering Report, PBAPS Independent Assessment of ESW Pump and Service Water Structure Wetwell Concerns Identified While Performing SP-630, dated 1/9/89 o Licensee Event Report, 3-88-11, dated 12/21/88, A Hole of Unknown Origin in the HPSW Pump Room Floor Resulted In the Plant Being Outside of its Flood Protection Design Basis o FSAR Section 10.9, Emergency Service Water System o FSAR Questions and Answers: 2.4, 2.5, 2.6, 2.7, 2.8, 2.9, and 2.10 o Technical Specification Amendment Application dated 1/4/88 for the ESW and ECW Systems o Technical Specification 3.9.C/4.9.C, 3.11.B/4.11.B and 3.12/4.12 with Bases o P&ID M-330, Emergency Cooling System o P&ID M-315, Sheets 1-4, Emergency Service Water and High Pressure Service Water Systems o P&ID M-3801, C. W. Pump Structure Vents o P&ID M-541, Plumbing & Drainage Circ Water Pump Structure Plan and Details o NRB Meeting #236 - Minutes and Notes on SP-630 Test o Safety Evaluation for Special Procedure, SP-630, Rev. O, dated 12/7/88 o SP 630, Integrated Test of the Emergency Cooling Water System, Rev. 1 Nuclear Quality Assurance o Nuclear Quality Assurance Charters, Accountabilities, Functional Organizational Charts (Note: Manual contains individual charters with various dates) o Nuclear Quality Assurance Procedures (Manual index is dated 12/16/88) Corporate Oversight Minutes of NRB meetings held on 3/3, 5/5, 7/14, 9/1, 11/3 and 9, 1988 and 1/5/89
Summaries of NRB meetings to the EVP-N for the 7/14, 9/1, 11/3, 1988 and 1/5/89 meetings l NRB Charter and Procedures, Rev. II NQA Audit Report AP 88 - 29 PR on PORC PAD Report PAP 88-02 on PORC
Mission Statement of NCB, through 11/28/88 Minutes of NCB meetings held on 4/7, 8, 11, 5/3, 20, 6/14, 7/14, 15, 19, 8/26, l 9/20, 10,12, 24
i OEAP/CTP Bi-weekly status report, 2/2/89
CTP monthly status report, 1/31/89 ' NGAP - 002.X on CTP AG-18 on CTP OEAP/CTP report of 12/30/88 PAD recommendation on QUATTS/CTP, 1/18/89
NGAP NGS-0XX.Y on OEAP , l AG-35 on OEAP _ _ _ _ _ _ _ - _ _ _.
, _ _ _ - - - - _ _ _ - - _ _ .
! l-I-117 l - Quarterly Management Report - Performance Indicator Summary for fourth quarter 1988 Station Review Meeting handouts from 2/13/89 ! . _ _ _ - _ - _ _ -. - _ _ - _ _ _ _. _ _ -
, - - _ _.
, , ,, 118 " ' ' APPENDIX D L ' Exit Interview Attendees-February 17, 1989 Name Title NRC I G. Meyer Senior Resident Inspector, Hope Creek.
D. Caphton Senior Technical Reviewer, DRS R. Martin Project Manager, NRR T.' Johnson-SRI, PBAPS B. Boger-Assistant Director, NRR-W.
Kane Director, Division of: Reactor Projects (DRP) 'J.
Linv111e' Section-Chief, DRP E. Wenzinger, Sr.
Branch Chief,'DRP T. Kenny Senior Resident Inspector, Limerick Generating Station H. Williams D. Florek .' Project Engineer, DRP Senior Operations Engineer A. Weadock . Human Factors Analyst Radiation Specialist I. Schoenteld W. Schmidt SRI, FitzPatrick R. Urban Resident Inspector, PBAPS L. Myers' Resident Inspector, PBAPS J. Gadzala Reactor Engineer, DRP PECo ' D. LeQuia Superintendent, Plant Services, PBAPS G. Rainey Superintendent, Maintenance, PBAPS D. Meyers Support Manager, PBAPS K. Powers Project. Manager, PBAPS D. Smith Vice President, PBAPS C. McNeil Executive Vice President-Nuclear J. Franz Plant Manager, PBAPS J. Cotton Superintendent, Operations, PBAPS G. Daebeler Superintendent, Technical, PBAPS D. Helwig General Manager, NQA G. Hunger, Jr.
Director, Licensing J. Basilio Licensing, PBAPS J. Cockroft Superintendent, Quality Assurance, PBAPS J. Austin Superintendent, Modifications, PBAPS G. Bird Nuclear Security Specialist, PBAPS l . _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
. _ _ - _ - - ._ _ _ - _ _ _ _ __ - _-_-. . . .
L , 119: L:, t PECo-(continued) T.-Cribbe Regulatory Engineer, PBAPS
T. ' Niessen,~ Jr.
Shift Manager, PBAPS J. Clupp, Jr.. Shift Manager, PBAPS 'J. Diederich-Manager, Peach Bottom Projects, Nuclear Engineering N. McDermott-Manager,'Public Information ' R. Kankus Staff Engineer, PBAPS .. . K. Cook-Director, Management Professional Development- - Others S. Maingi Nuclear Engineer, Pennsylvania . T. Magette Maryland Department of Natural Resources-R. Reichel-Delmarva Power. . B. Gorman-Public Service: Electric and Gas.
- H. Abendroth Atlantic Electric l
l ) ) ' - _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
mn - .. 120 i APPENDIX E IATI Team Composition Senior Manager: W. Kane,. Director, Division of Reactor Projects.
' Team Leader: J. Linville,. Chief, Reactor Projects Section - 2A ' Assistant Team Leader: T. Johnson, Peach Bottom Senior Resident c Inspector Specialist Inspectors: Site Management: T.' Kenny,' Limerick Senior Resident Inspector Licensed Operator D. Florek, Senior Operations Engineer.- Resources: l- . Station Culture: I. Schoenfeld,. Human Factors Analyst ' ' i D.~Morriseau,. Human Factors Analyst E ' Corporate Oversight R. Martin, Peach Bottom Project Manager I Nuclear QA: . .D. Caphton, Senior Technical Reviewer Radiological Control: A. Weadock, Radiation Specialist . a l Maintenance /!. L. Myers, Resident Inspector, Peach Bottom , W. Schmidt, Fitzpatrick Senior Resident Inspector Surveillance: . J. Gadzala, Reactor Engineer Engineering / Technical G. Meyer, Hope Creek' Senior Resident .- Support: Inspector H. Williams, Project Engineer Security:. R. Urban, Resident Inspector, Peach Bottom ' Administrative Assistant: B. Miller, Peach Bottom Clerical Aide ! i ! ! ' m.______ ___. _ _ _ - _ __ _ _ _ _ _. _ I }}