IR 05000277/1989099
| ML20062B826 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/11/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20062B823 | List: |
| References | |
| 50-277-89-99-01, 50-277-89-99-1, 50-278-89-99, NUDOCS 9010260158 | |
| Download: ML20062B826 (35) | |
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f;NCLOSURE1
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FINAL SALP REPORT U. S. NUCLEAR REGULATORY-COMMISSION i
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REGION I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE I
REPORT F >S.
50-277/89-99
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50-278/89-99
l PHILADELPHIA ELECTRIC COMPANY PEACH BOTI'OM ATOMIC POWER STATION i
UNITS 2 AND 3 i
ASSESSMENT PERIOD: JULY 1,1989 - MAY,31,.1990 BOARD MEETING DATE: July 16,1990 t
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l SUMMARY *
Peach Bottom Atomic Power Station July 1,1989 - May 31,1990 Annualired Eunctional Area lions Hours
% of Time A. Plant Operations 2324 2535
B. Radiological Controls 523 575
C. Maintenance / Surveillance 742 817
D. Engineering / Technical 635 692
i Support E. Emergency Preparedness 133 145
F. Security and Safeguards 193 210
G. Safety Assessment /
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Quality Verification 709 773
TOTALS 5263 5747 IO0 Excludes direct inspection hours associated with the AEOD human factors
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oriented event review.
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TABLE 2
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I ENFORCEMENT SUMMARY l
Peach Bottom Atomic Power Station
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July 1,1989 - May 31,1990
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Number / Severity of Violations i
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l Functional Area Irvel III level IV
l A. Plant Operations
4 B. Radiological Controls
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Support E. Emergency Preparedness F. Security
G. Safety Assessment /
Quality Verification
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TOTALS
7 Note: The three violations listed in the Severity level Ill column were collectively
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evaluated as a Severity level 111 problem and one enforcement action issued.
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TABLE 3 l
LICENSEE EVENT REPORTS *
Peach Bottom Atomic Power Station July 1,19 May 31,1990
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Number by Cause"
Functional Area A
B C
D E
X Subtotal l
A. Plant Operations
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12
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B. Radiological Controls
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C. Maintenance / Surveillance
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22
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6 D. Engineering / Technical
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F. Security"*
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G. Safety Assessment /
Quality Verification
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TOTALS
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Review of the events included in the above table for common problems and causal factors indicates that weaknesses in the licensee's surveillance test scheduling program account for a large percentage of the reports submitted in the Maintenance /Sarveillance functional area, This isriue is discussed in detail in Section Ill.C.
LERs 2-89-13 through 33; 2-90-01 through 2-90-05; 3-89-01 ' through 12; 3-90-01-
through 3-90-03
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Cause Codes: A. Personnel error B. Design, manufacturing or installation C. Unknown or external cause D. Procedure inadequacy E. Component failure
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X. Other Security Event Reports are discussed separately in Section Ill.E.
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ATTACHMENT 1
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SALP CRITERIA
Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phase. Functional areas normally represent areas significant
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to nuclear safety and the environment. Some functional areas may not be assessed because of i
little or no licensee activities or lack of meaningful observations in that area. Special areas may
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be added to highlight significant observations.
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The following evaluation criteria were used, as applicable, to assess each functional area:
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o assurance of quality, including management involvement and control o
approach to the resolution of technical issues from a safety standpoint
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o responsiveness to NRC initiatives
o enforcement history o
operational and construction events, including response to, analyses of, reporting of, and corrective actions for
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o staffing, including management
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o effectiveness of training and qualification program On the basis of the SALP Board assessment, each functional area evaluated is rated according
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to three performance categories. These definitions of these perfoi,nr.ce c:tegories are given below.
Category 1.
Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriate.
Category 2.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that mxded to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at normal levels.
i Category 3.
Licensee management attention to and involvement in the~ performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not
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sigmfacantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be
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increased above normal levels.
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The SALP Board may assets a functional area and compare the licensee's performance during a portion of the assessment period to that during an entire period in order to determine a performance trend. Generally, performance in the latter part of a SALP period is compared to
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I the performance of the entire period. Trends in performance from period to the next may also be noted. The trend categories used by the SALP Board are as follows:
Improving:
Licensee performance was determined to be improvh g near the close of the
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asses: ment period.
Declining:
Licensee performance was determined to m lining near the closs of the
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assessment period and the licensee had not satit..orily addressed this pattem A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely change in the performance category in the near future.
For example, a classification of " Category 2, Improving" indicates the clear potential for
" Category 1" performance in the next SALP period.
It should be noted that Category 3 performance, the lowest category, represents acceptable, although minimally adequate, safety performance. if at any time the NRC concluded that a licensee was not achieving an adequate level of safety performance, it would then be incumbent
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upon NRC to take prompt appropriate action in the interest of public health and safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP
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process.
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UNITto sTAtts
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NUCLEAR REGULATCRY COMMISSION
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Riol0N 1 ENCLOSURE 2 i
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$
476 ALL840 ALE ROAO
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KING OF PRUBS4A.PENNSVLVAWIA SMal
l AUG 101990
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Docket Nos. 50 277/DPR 44
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50 278/DPR 56 i
Philadelphia Electric Company
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Correspondence Control Desk
ATTN: Mr. Dickinson M. Smith Senior Vice President Nuclear P. O. Box 195 Wayne, PA 19087 0195 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Board Report Number I
$0 277/89-99; 278/89 99
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A NRC SALP Board, conducted on July 16,1990, reviewed and evaluated the performance of activities at the Peach Bottom Atomic Power Station for the period of July 1,1989 through May 31,1990. The enclosed initial SALP Report documents the results of this assessment. We will
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contact you soon to schedule a meeting to discuss the SALP evaluation.
At the SALP meeting you should be prepared to discuss our assessment, and your plans to continue to improve performance, ne meeting is intended to be a candid dialogue wherein any comments you may have regarding our report are discussed. Additionally, you may provide uritten comments within 20 days after the meeting.
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Your cooperation with us is appreciated.
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Sincerely,
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T. Martin Regional Administrator Enclosure: SALP Board Report No. 50 277/89 99; 278/89 99
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C. A. McNeill, President and Chief Operating Officer D. B. Miller, Vice President, Peach Bottom Atomic Power Station D. R. Helwig, Vice President, Nuclear Engineering and Services J. F. Franz, Plant Manager, Peach Bottom Atomic Power Station E. J. Cullen, Jr., Esquire, Assistant General Counsel
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G. *A. Hunger, Jr., Director, Licensing Section E. P. Fogarty Project Manager, Peach Bottom Atomic Power Station R. J. Lees, Chairman, Nuclear Review Board A. A. Fulvio, Regulatory Engineer, Peach Bottom Atomic Power Station J. Urban, General Manager, Fuels Department, Delmarva Power W. H. Hirst, Director, Joint Generation Projects Dept., Atlantic Electric B. W. Gorman, Manager External Affairs, Public Service Electric & Gas Co.
T. B. Conner, Jr., Esquire (Without Report)
R. L. Hovis, Esquire (Without Report)
R. McLean, Power Plant Siting, Nuclear Evaluations J. H. Walter, Chief Engineer, Public Service of Maryland D. Poulson, Secretary of Harford County Council Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector Commonwealth of Pennsylvania K. Abraham, PAO (20)
Chairman Carr Commissioner Curtiss Commissioner Rogers Commissioner Remick i
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PHILADELPHIA ELECTRIC COMPANY
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NUCLEAR GROUP HEADQUARTERS
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955 65 CHESTERBROC$( BLVD.
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WAYNE, PA 19087 5691 I
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September 18, 1990
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Docket Nos.
50-277
50-278
License Nos. DPR-44
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L U.S. Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555 SUBJECT: Peach Bottom Atomic Power Station, Units 2 and 3 Systematic Assessment of Licensee Performance Board Report No. 50-277/89-99;278/89-99
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Submittal of Written Comments.
Centlement NRC Letter dated August 10, 1990 transmitted the NRC's Initial Systematic Assessment of Licensee Performance (SALP) Board
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Report which provided an assessment of our Peach Bottom Atomic Power i
Station for the period of July 1, 1989 through May 31, 1990.
We then met with NRC representatives on August 29, 1990 at'the Peach Bottom site to discuss the SALP Board Report assessment and our plans to correct the identified weaknesses.
At that time we indicated we would respond in writing to the SALP Board Report.
Accordingly, this letter provides our written _ comments by summarizing our statements made at l
the August 29, 1990 meeting.
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Overall, we concur with the SALP Board's assessment of activities at Peach Bottom.
We find that the Board Report recognizes that we successfully implemented restart and power ascension progrtas for both units, that we have established a solid foundation of sel.'
assessment operations, programs and a management philosophy of safety conscious
.and that our progress in strengthening our performancu has been positive.
We also understand that in addition to the progrrss which has been made, much work remains toward improving our performance.
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- POcch Bottom Atomic Pow 0r Staticn, Unito 2 cnd 3 S;ptcmber 18, 1990
' s-Systcmatic A300ccC:nt cf Lic;nOCO P0rformanca P0g3 2
< t Board R3 port No. 50-277/89-99;278/89-99
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Submittal of Written Comments
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In the Plant Operations area, we are continuing our efforts to achieve operating staffing goals we established for this year and to make available off-shift career paths for long time shift supervisors.
We currently have a sufficient number of candidates in
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the training program for Reactor Operator and Senior Reactor Operator licenses to achieve our goals.
Also, we have instituted a root cause analysis of the blocking problems and valve misalignments that have
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occurred at the station.
The results of this analysis will be converted into corrective actions to help improve the effectiveness of our process for equipment removal and return to service.
Also, we have initiated an effort to determine the underlying reasons with our personnel exhibiting inattention to detail.
We expect this analysis will identify corrective actions to address this problem.
The results of these analyses and the corrective actions will be shared with the NRC.
l In the area of Radiological Controls, we have completed the root cause analysis relative to noncompliance with radiological worker practices.
As we indicated to you during the SALP meeting of August 29, 1990, we would like to share the details of this analysis and the corrective actions with you.
Based on our activities, we concur with the statements made by your regional staff at the August 29, 1990 meeting that the Board recommendation contained in the Initial SALP Report should be revised to reflect that the root cause determination for radiation worker noncompliance with work requirements was completed during the SALP period.
Also, the Initial SALP Report indicates that conservative water chemistry goals and monitoring programs have been established and, when chemistry has exceeded
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established specifications, we have acted promptly to resolve the
I problem or initiated a power reduction.
In order to further improve reactor water chemistry, and thus improve fuel integrity in the long term, we are committed to making large capital expenditures for replacing the existing condensers in Units 2 and 3 with materials that i
do not contain copper, which is one of the main contributors to crud-
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l Induced localized corrosion of reactor fuel.-
In the area of Maintenance and Surveillance, we have
completed a root cause analysis on our deficiencies in our Surveillance Testing Program, and we have identified sixteen
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l corrective actions that we are currently implementing in order to
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improve our performance.
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In the area of Engineering and Technical Support, an outside consultant has just completed our review of our Environmental
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Qualification Program at Peach Bottom.
We will develop the appropriate corrective actions in response to this report and share this information with you.
Also, we have put into place a process that should improve our learning from safety system functional l
inspections performed by the NRC staff and performed by ourselves.
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We recognize that engineering and technical support of the station has to l
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P3cch Bottom Atomic Power Stcticn, Units 2 cnd 3 S:ptcaber 18, 1990 v ' -
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Board R; port No. 50-277/89-99;278/89-99 Submittal of Written Comments
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i be more proactive, and we are striving to achieve it.
We believe our new Nuclear Group reportability evaluation procedure has helped our
corporate support groups in their timeliness of station support.
l Lastly, we recognize that the rate of improvement has been
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rapid over the past year, but now we must sustain the improvement achieved and continue to improve, although the rate of improvement may be slower.
We pledge continued management support of and attention to the rate of improvement, achievement of goals, and performance of
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routine activities.
We will continue to sustain our ongoing self
assessment operation. processes and our management philosophy of safety conscious If you have any questions, or need additional information, please contact us.
Very truly yours,
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T. T. Martin, Administrator, Region I, USNRC cc:
J. J. Lyash, USNRC Senior Resident Inspector, Peach Bottom
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i ENCLOSURE 4
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Initial SALP Renon Revision Sheet i
Eagc Line New Rendt Should Read
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i Determine root causes and Meet with NRC to discuss the
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corrective actions needed for results of the root cause analysis long term improvement in and planned corrective actions for
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radiation worker adherence to improving radiation worker adherence
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requirements, and meet with to requirements.
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the NRC to discuss the results.
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Basis:
1.icensee actually completed the root cause *Jialysh during this assessment Ix:riod and has developed a corrective action plan for improving radiation worker adherence to requirements, t
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