ML20010H387
| ML20010H387 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/30/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| References | |
| NUDOCS 8109240411 | |
| Download: ML20010H387 (38) | |
Text
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a:+9-Evaluation 37
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Report .
June,1981 i
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9W EVALUATION t
of PEACH BOTTOM ATOMIC POWER STATION I
l Philadelphia Electric Company i
June,1981 j
PEACH BOTTOM (1980)
Page1
SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Philadelphia Electric Company's (PECOs) Peach Bottom Atomic Power Station during the weeks of December 8 and15,1980. Peach Bottom consists of two 1098 megawatt (electrical) General Electric boiling water reactor plants. It is located on the Susquehanna River near Delta, Pennsylvania. The plant was placed in commercial operation in July 1974.
1 PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant operating safety, evaluate management systems and controls and identify areas needing improvement.
The evaluation was based on preliminary INPO criteria, and information was assembled from discussiens, interviews, observations and reviews of plant documents. Emergency preparedness was not included in the scope of the evaluation, nor were corporate activities, except as an incidental part of the ;
station evaluation.
The evaluation team examined station organization, training and qualifications, operations, maintenance, radiological and chemical activities and site technical l support. Performance evaluations were based on best practices. Report recommendations, therefore, are not limited to minimum safety requirements.
DETERMINATION Within the scope of this evaluation, the team determined that the plant is baing ,
safely operated. The following beneficial practices and accomplishments were noted:
o There is an excellent training program for operators. It includes class-room instruction and supervised development starting at the entry level.
o The knowledge and experience level of station personnel is high. Morale appears good.
o There is a positive attitude among station and corporate management personnel toward improvements in station operation and management.
o An effective system is in use for identifying and processing safety-and reliability-related information within the station staff.
PEACH BOTTOM (1980)
Page 2 ,
Improvements were recommended for the following conditions:
o Clas:Toom, office and shop facilities are overcrowded and scattered '
throughout the site. This situation is not supportive of effective plant administration. -
i o There is a tendency for the station staff to use informal administrative =
controls for extended periods of time, rather than incorporate them into -
formal procedures.
o Insufficient management attention is given to ensuring the continuing _
E effectiveness of administrative programs at the station.
2 o The design modification program does not include effective controls to ensure proper training of operators nor to ensure timely review of as- 2 built deviations from approved plans.
Recommendations are intended to augment PECO efforts to achieve the highest -
standards in its nuclear operations. PECO responses to the report are considered ,
appropriate to the findings presented. In taking corrective action, PECO should consider possible generic significance of findings and recommendations. j Specific evaluation findings are in the accompanying DETAILS, and information u of an administrative nature is in the ADMINISTRATIVE APPENDIX. These findings were presented at an exit meeting at the plant on December 18, 1980, ,
and were further discussed, along with PECO responses, on March 13,1981, in a g meeting with PECO management. _
d The evaluation staff appreciates the excellent cooperation received from all levels of the Philadelphia Electric Company. Peach Bottom station personnel were prompt and courteous in responding to our requests.
E. P. Wilkinson President ;
M E
S m
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1 PEACH BOTTOM (1980)
Page 3 PHILADELPHIA ELECTRIC COMPANY
RESPONSE
SUMMARY
Philadelphia Electric Company is dedicated to operate the Peach Bottom Atomic Power Station in a safe manner and is pleased that INPO's review found our practices and accomplishments meet this goal. Philadelphia Electric Company is likewise pleased that the comprehensive QA program being utilized was found to meet all of the INPO criteria.
Philadelphia Electric readily accepts INPO's recommendations directed towards achieving a higher standard of performance in our nuclear operation and will consider the possible application to these findings and recommendations in other areas of our operation.
Construction for a new building at Peach Bottom which will increase office, classroom, and maintenance facilities is planned to start in September,1981.
This additional facility addresses specific INPO comments relating to the need for improved spare parts storage, housekeeping, and a shoruge of classrooms for employee training. This new building will relieve overcrowding and scattering of personnel with a resultant improvement in plant administration.
Although INPO found that our training programs are being conducted on schedule, we concur with the recommendation that the size of the training staff be increased to improve instructor effectiveness. A superintendent of Nuclear Training has been appointed to evaluate training requirements related to programs, staff personnel, and faci'ities. Philadelphia Electric recognizes the importance of highly qualified personnel in the operation of the power plant and is committed to the development of a nuclear training program which meets the highest standards.
Where appropriate, expected implementation dates have been indicated for INPO recommendations. We welcome INPO's review and audit of the implementation of their recommendations.
PEACH BOTTOM (1980)
Page 4 DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each section is headed by a
^
summary describing the scope of the evaluation and the overall finding in that area. The summary is followed by the specific findings, recommendations and utility responses related to each of INPO'S evaluation procedures. The evalua-tion procedures used are listed in the ADMINISTRATIVE APPENDIX.
ORGANIZATION AND ADMINISTRATION In this area, the organization structure, personnel qualifications, administrative controls, and the programs for management objectives, quality assurance, information handling, industrial safety and equipment surveillance were evalua-ted.
The plant appears to be organized and administered effectively to support continuing safe operation. Senior management and supervisory personnel at the station and in supporting corporate offices are highly qualified and are actively involved in plant operational matters. It is evident that Peach Bottom has responded in a very positive manner to the organization and administration lessons learned from the Three Mile Island accident. There is, however, need for improvement in the management objectives program, the plant organization, administrative controls, information handling programs and industrial safety.
The majority of the improvements are related to defining formally the policies and practices used in operation of the plant. The recommended improvements are discussed in detail below.
OBJECTIVES (INPO Procedure OA-101, Revision 1)
The evaluation team examined the methods used to establish and promulgate management objectives and the methods used to track progress so that timely completion of objectives is ensured. The team also examined the objectives in use to determine if they provide substantive guidance to managers and supervisors, and if they support the plant mission and higher level company objectives. The degree to which the objectives are used to guide day-to-day activities was examined.
Station management has established a set of Peach Bottom objectives which address significant management concerns at the statio.i and which support corporate goals pertinent to Peach Bottom. Short range planned actions are included for several of the longer term objectives so that progress tracking can be done objectively during the planning year. The annual performance appraisal system for senior engineers (department managers) and above includes a com-mendable feature which compares actual progress toward objectives to planned progress. One feature of the program, however, was identified as needing improvement.
PEACH BOTTOM (1980)
Page5 Finding (Ref. Criteria B and C)
Station goals and objectives are distributed and used only at the senior engineer level and above. Personnel below the senior engineer level are not generally aware of station management objectives. Supervisors at these levels are not held acc~o untable for understanding and supporting their own department objectives and the plant mission.
Recommendation Steps should be taken to ensure that all personnel at the station are informed of management objectives that may affect their work and of significant progress toward achieving them. Consideration should also be given to extending the goals and objectives program to include lower levels of supervision.
Response
The goals and objectives applicable to Peach Bottcm personnel will be disseminated through first line supervision for their information. Existing 1980-81 goals will be disseminated by May 1981.
ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)
The evaluation team examined the plant organization to determine if it supports safe and efficient operation of the station. The team looked into the responsi-bilities, authorities, and accountabilities of staff positions to determine if they
- are clearly defined, well understood, compatible with each other, and if '
excessive burdens were placed on any individuals. They also reviewed the staffing levels to determine if sufficient qualified people are available to provide backups for management personnel and to prevent excessive overtime. Methods used to evaluate the performance of individuals at the station were also examined.
Peach Bottom relles on large numbers of personnel who do not report to the station superintendent, but to other divisions and departments in the Philadelphia Electric Company. This organization structure seems to function well for the staff of about 500 personnel assigned full-time at the station. It is also effective in making the extensive resources within the company available at Peach Bottom as needed. An excellent personnel appraisal program, tied to annual salary adjustments, is in use at the senior engineer level and above. In addition to appraisal in several general performance areas, this program includes a review of actual progress toward achieving planned objectives. Improvements are needed in this area, however, principally in improving the definition of the organization structure and improving personnel performance appraisal procedures below the senior engineer level.
- 1. Finding (Ref. Criterion A)
The organization chart shows that the security, administrative, QA/QC and training organizations all report to the QA Engineer. In practice, the security group reports to the Assistant Station Superintencent, and Y the training and administrative groups report to the Administrative Engineer.
m
PEACH BOTTOM (1980)
Page 6 NOTE: This finding also applies to INPO Procedure TQ 211, Criterion A, --
and is not repeated in that section. -
Recommendstica The organization chart should be corrected to reflect the actual report- d ing lines desired at the plant.
Response _
3 The organization chart has been revised to reflect the actual reporting lines, and will be maintained current.
N NOTE: Findings 2 and 3 also apply to INPO procedures TQ-211 (Criterion C),
OP-303 (Criterion B), MA-401 (Criterion C) and RC-501 (Criterion E) which -
pertain to position descriptions and performance evaluations for training, opera-tions, maintenance and radiation protection. These findings are not repeated in =
those sections.
- 2. Finding (Ref. Criterion B) -
Position descriptions which define authority, responsibility and account-ability have not been prepared for many positions at the station. There __
are some position descriptions in existence, but these are based primarily ,
on regulatory requirements rather than on job analyses. It was noted j that a 1980-81 objective for each senior engineer on the plant staff is to -
prepare position descriptions through the supervisory engineer level. ,
This has been initiated.
Recommendation -
Position descriptions which describe the authority, responsibility and -
accountability of assigne) maividuals should be prepared for each authorized position at Peach Bottom. INPO is coordinating an industry-wide job analysis project for certain operator, maintenance and techni- g-cian positions and their immediate supervisors.
Response
Philadelphia Electric Company will prepare position descriptions to y define authority, responsibility, and accountability for all exempt posi- -
tions, and for other positions not included in the industry project by March 1982. When the results of the industry-wide job analysia are _
available, Philadelphia Electric will prepare descriptions for the remain- -
ing positions at the station. A scheoule will be established for these positions when the industry-wide project is completed.
- 3. Finding (Ref. Criterion C) ,
Several classifications of Nc-exempt employees do not receive periodic performance appraisals. Most d the appraisals which are performed are _
based on general performance factors and not on position description requirements.
Recommendation The performance appraisal program should be expanded to cover all -
personnel at Peach Bottom and should be revised so that the evaluations are based on position descriptions. =
Response
The performance appraisals will be expanded to include exempt and non- -
exempt personnel. Appraisals will be performed on an ennual basis and D
PEACH BOTTOM (1980)
Page 7 based on position descriptions. The full program except for positions included in INPO's industry-wide job analysis project will be implemented by March 1982. Personnel in positions included in the INPO study will also be evaluated annually according to general performance factors until position descriptions are developed from the INPO job analysis.
ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Revision 1)
The station administrative procedures were examined to determine if clearly defined controls are in effect and if adherence to these controls is maintained.
Finding (Ref. Criterion E)
Close adherence to the requirements of administrative procedures is ..:t being uniformly required. During the evaluation period, sev("al in-stances of failure to conform to written procedures were observed. In some cases, unnecessarily restrictive or complex administrative require-ments seemed to be leading to compliance errors. There is no formal program for monitoring procedural adherence on a routine basis.
Recommendation Station administrative controls should be reviewed to identify and eliminate unnecessary requirement 3. A program should be established to objectively evaluate, periodically, whether administrative controls are being properly used, and cor,rective action should be required for problems identified. Adherence to procedures should be required.
Response
A survey is being initiated to identify requirements in the administrative procedures which are unnecessary or difficult to accomplish. During the next periodic review of each administrative procedure, a special review to determine what unnecessary requirements or unduly complex require-ments are included in these procedures will be made and such require-ments will be eliminated or modified accordingly. Additionally, all administrative procedures concerning plant modification, corrective maintenance, purchasing and fire protection will be reviewed against this criteria by December 1981. Proper implementation and adherence to administrative procedures requirements will be periodically re-emphasized and verified by management.
QUALITY PROGRAMS (INPO Procedure OA-104, Revision 4)
The quality assurance (QA) program was reviewed to determine if an approved program is ia place which covers all aspects of plant operations, if the program is adequately staffed and if the organizational relationships ansure independence
m PEACH BOTTOM (1980)
Page 8 -
of the quality assurance staff from production responsibilities. The effective- -
ness of the quality assurance program was not within the scope of current evaluation criteria and was not evaluated. 5 Finding A comprehensive quality assurance program is in effect. All criteria in this procedure were met. _
m INFORMATION PROGRAMS (INPO Procedure OA-105, Revision 1) _
The team examined the methods used to process and evaluate operational safety and reliability information to determine how such information is identified and -
if the review process ensures that appropriate actions are determined and -
completed in a timely manner.
Finding (Ref. Criteria A and D)
The system for processing safety and reliability related information at -
the station has been developed and implemented on an informal basis.
Although it is effective, it has not yet been formalized into a written procedure. For this reason, no periodic monitoring of program effective- -
ness has been established, i Recommendation A procedure should be prepared to prescribe the method used to process operational safety and reliability information. The program description =
prepared by plant management during the evaluation would be a good -
base for such a procedure. It should includ requirements for periodic -
review of system effectiveness. -
Responce A " Document and Routing Manual" for use by the clerical and technical -
staff is in preparation. This manual will be completed by December 1981, and will ensure that identified documents are routed and processed in a systematic manner. Provisions will be included for periodically determining program effectiveness.
INDUSTRIAL SAFETi -
(INPO Procedure OA-106, Revision 1)
The team examined the industrial safety program to d'etermine if management is l-clearly committed to industrial safety, if the program is supported at alllevels of the station staff and if the program is effective in minimizing safety hazards j and accidents. '
It was evident that a substantial industrial safety program exists at Peach -
3 Bottom and a considerable amount of support is received from corporate offices.
r industrial safety personnel are involved in reviewing work methods and .
housekeeping, reviewing tooling and equipment for safety considerations, de-m veloping and conducting a wide variety of safety-related training and working closely with station personnel on safety matters. The program, however, does d
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4 PEAR 9 BOTTOM (1980) . . .
Page 9 2
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s not adequately emphasize involvement of all individuals in day-to-day promotion of safety. .
1 Finding (Ref. Criterion A) . .
. '1 Station management has not issued a policy statement to all personnel s v , .: . ,
outlining its commitment to the industrial safety program. 6 Recommendation p - , Jb
~
A policy statement reflecting management's commitment to an effective .
industrial safety program should be prepared and given wide distribution %
at the plant. The statement should encourage active participation of all s employees in industrial safety matters. .,
Response , _ _
Management believes that commitment to an effective industrial safety -
y program is demonstrated through many activities. To enhance this 9
~
program, a policy statement, such as that described above, will be prepared and distributed by August 1981. This policy statement will be <
incorporated and distributed with the handbook as described in OA-106, Criterion D. [' -
- 2. Finding (Ref. Criterion D) ~
p..
The company has not formally published and distributed the work '
practices and safety considerations for Peach Bottom to employees at * -
the station. There have been several handouts prepared, incNding a '
. 2 radiation safety handbook, but they have not been given to all employees -
and have not been in a form which encouraged retention for continuing . ..
I ;
reference. ,. f.
Recommendation . .. .
An industrial safety handbook should be prepared and distributed to all '
employees. On a continuing basis, new employees should be provided a : .
i' copy. The handbook should include work practices and safety informa- . 1 -
tion applicable to Peach Bottom. Consideration should be given to
Response
including the policy statement discussed above in the manual. , .,,-*j .-
A revision of our radiation safety handbook will be made which will : /' -
include industrial safety material. This will be completed by December 1981. The revised handbook will be distributed so all current and new . 7) employees at the station will receive a copy. ,. ,' .
.7
)
SURVEILLANCE PROGRAM + -
(INPO Procedure OA-107, Revision 1) -
The team examined the surveillance program to determine if adequate proce- '-
dures, which include acceptance criteria, are in use. They also evaluated the .
, ~..
methods used to schedule surveillance tests, control operations so safety is not adversely affected during testing and identify and resolve deficient conditions identified during testing. - -
Finding D
4 The surveillance program is functioning effectively. It meets all INPO criteria. ?
4."
PEACH BOTTOM (1980)
Page 10 PERSONNEL QUALIFICATIONS (INPO Procedure OA-108, Revision 1)
The team examined the methods used to establish qualification requirements '
for each job position and to ensure that positions are filled with qualified personnel.
- 1. Finding (Ref. Criterion A)
Written qualification requirements are not available for many positions.
The qualification requirements which do exist are often based on regulatory requirements r2ther than on job analysis of the position.
Recommendation Qualification requirements should be developed for each position at the station based on the author ties, responsibilities and accountabilities i
assigned to the position. This work should be coordinated with the position description effort discussed in the organization structure area.
Response
Qualification requirements for all positions will be established as part of the position description effort discussed in Finding OA-102, Criterion B.
The scheduled completion dates are the same.
- 2. Finding (Ref. Criterion B)
The on-site technical support staff is not manned to the authorized level with qualified personnel. Six engineering positions are currently unfilled; six other positions are being filled by contract individuals or junior technical assistants who do not hold engineering degrees.
Recommendation Philadelphia Electric Company should review its qualification and staffing policies and take action as appropriate to fill staff vacancies.
Response
Philadelphia Electric Company has reviewed its qualification and staff-ing requirements as recommended, found them adequate and expects to fill positions to authorized levels by December 1981.
PEACH BOTTOM (1980)
Page 11 TRAIFJ In this area, the team evaluated organization and administration of the training program, training resources'and effectiveness, and programs fde training licensed -
and non-licensed operators and shift technical advisors.
Philadelphia Electric Company has a comprehensive and extensive training program established for operations personnel at the Peach Bottom station. This program includes formal classroom training for all operating positions from entry level through senior licensed positions. The program is well-defined and _
structured to include formalized on-the-job training with qualification check lists or task assignments. The company has recently constructed its own control room simulator for the Limerick station and has begun using it to support Peach Bottom operator training. Although most criteria against which the training organization was evaluated were met, there are conditions where improvements are warranted.
TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)
In 'his t area, the team examined the on-site training organization and the administrative guidance used by the organization to develop, implement and evaluate training activities and programs used for the qualification of plant operations personnel.
Finding (Ref. Criterion B)
Although training programs are being conducted on schedule, the size of the training staff does not permit adequate instructor preparation, lesson material development, program improvement and professional develop-ment by the training staff. This shortage of personnel is adversely affecting the quality of the instruction program.
Recommendation A review of manpower needs for the training staff should be performed.
Staffing levels should be adjusted as appropriate, based on the review.
R w onse A Superintendent of Nuclear Training has been appointed to evaluate the nuclear training requirements relative to programs, staff personnel and facilities. The current organizations providing nuclear training are being examined to determine manpower needs, both staff and contractor personnel, and to improve the overall quality of the nuclear training program. This review will be completed by October 1,1981. The staffing levels and progeam adjustments which are determined to be needed by this review will be attained by October 1982.
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PEACH BOTTOM (1980)
Page 12 TRAINING RESOURCES (iNPO Procedure TQ-221, Revision 2)
In this area, INPO examined the training facilities, equipment and materials available to support the delivery of trsining programs for plant perse: nel.
Finding (Ref. Criteria A and D)
There is a shortage of classrooms for the training which is routinely scheduled. The available classrooms are small, cluttered, and frequently noisy. The heating, ventilation and lighting systems do not support efficient instruction. There is also a shortage of adequate training support facilities such as offices, reference and study areas and file space.
Recommendation Training classroom and support facility requirements should be evaluated in light of current and projected training activities. The plans now in progress for expansion of the administrative building should be reviewed to ensure that problems identified by the evaluation will be corrected when the building is completed.
Response
Plans for expansion of the administration building are in review to ensure that facilities required will be adequate to meet the training require-ments. Interim measures, such as increased use of Unit No.1 Adminis-tration Building for classroom presentations and improvement of the quality of the Unit 1 facility are being implemented. Permanent Unit 1 training facility improvements and fixtures acquisition will be completed by September 1981.
TRAINING EFFECTIVENESS (INPO Procedure TQ-231, Revision 2)
The team examined plant management and training organization practices relating to evaluation of training program effectiveness, auditing of training cetivities and ev4uation of instructor and trair.ee performance in training programs.
Finding (Ref. Criterion A)
Although several training programs are administered at the station, management does not require formal, periodic evaluations of the effee-tiveness of each training program. Feedback to the training department is not used effectively. The absence of good comr.iunication has resulted in a lack of both understanding and sharing of common goals by personnel in the training and operaticas organizations.
Recommendation A program of formal, periodic evaluations of training effectiveness should be established.
Response
In order to ensure effectiveness, a formal program of interviews will be routinely scheduled with operating, health physics, I&C and maintenance personnel and their supervisors to assess the individual's ability to
PEACH BOTTO11(1980)
Page 13 perforn, the task assigned after assuming job responsibilities. These interview:: will be held approximately two months after qualification or assignment to the position.
NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)
The team examined the training program and training practices used to initially qualify non-licensed operator candidates and to maintain and improve the qualifications of existing non-licensed operators.
Finding All criteria in this procedure were met.
LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)
In this area, INPO examined the training program and training practices used to initially qualify licensed operator candidates to operate the nuclear plant reliably and safely.
Finding All criteria in this procedure were met.
LICENSED OPERATOR REQUALIFICATION PROGRAM (INPO Procedure TQ-244, Revision 2)
In this area, INPO examined the qualification program and training practices used to maintain and improve the qualifications of licensed personnel.
Finding All criteria in this procedure were met.
PEACH BOTTOM (1980)
Page 14 SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-245, Revision 1)
In this area, INPO examined the qualification program and training practices used to initiany qualify shif t technical advisor (STA) candidates and to maintain and improve the qualifications of the STA.
Finding All criteria in this procedure were met.
x
- _____ - ____ ~_-_____ _______________ ____ __ __ _______ __ _ _ _ _ _ _ _ _ _ _
PEACH BOTTOM (1980)
Page 15 OPERATIONS Operations personnel were lnterviewed at the field level up to the Operations C.ngineer. In addition to interviews, observations were made during shift turnover and during the shift.
In several areas of plant operation, effective practices have been implemented, such as shift turnover, blocking (tagging) practices and the use of shift meetings.
Although most criteria were met, several areas for improvement were identified.
CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-301, Revision 1)
The team examined the conduct of shift operations to verify that operator activities are related to plant operation, if cleanliness and order exist in the control room, if log keeping is timely and accurate and if out of tolerance instruT.entation is identified to the operators.
Finding (Ref. Criterion B)
Access to the control room is not sufficiently limited. Frequently, numbers of personnel enter the control room, creating excessive back-ground noise and distracting the operators.
Recommendation A review should be conducted to determine what activities must be performed in the control room. Access to the control area should be restricted to only those persons needed to perform the required activ-ities. Consideration should be given to setting up limited areas in the control room where administrative duties may be accomplished with minimum interference in the control area.
Response
Control room access is now limited to those individuals who require entry to conduct business. Measures will be taken to ensure that shift supervision and control room operators exercise their authority to limit access. Philadelphia Electric Company is examining the appropriateness of relocating activites associated with issuance of keys, firewatch signs 1 and safety permits. These actions will be completed by June 1981.
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PEACH BOTTOM (1980)
Page 16 TAGOUT PRACTICES _
(INPO Procedure OP-302, Revision 1)
In this area, the team examined the formal tagout procedure to verify that it is _
highly respected and understood by the plant staff, if Senior Reactor Operator (SRO) approvalis required for removal of safety related equipment from service, if double verification of safety related manual valves without control room indication is required, if a second verification of tagged equipment takes place, if tag coloring and numbering is not confusing and if the clearance log is periodically reviewed.
Finding (Ref. Criterion C) -
Double verification of safety related manual valves without control room ,
indication is not required for blocking or surveillance tests. It is noted that this item is already being addressed by the plant staff. '
Recommendation Procedures should be revised to require double verification of important =
manual valves which are reposi:.ioned durirg maintenance or testing.
The valves being addressed here cre safety-related manual valves -
without control room indication. This second check on component position does not necessarily have to be performed in the tagout program; it could be accomplished in other programs such as surveillance testing or system valve alignment. _
Response
2 An administrative procedure is now in force which provides for double verification of critical valves when a system is removed from service. .
On return to service, double verification is performed on all affected =
valves. Administrative guidance is also in place for double verification of surveillance testing activities. To reinforce these administrative requirements, all individual surveillance tests are being revised. j OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-303, Revision 1)
In this area, the team examined the operations organization and administration to verify if a well defined and understood organizational structure exists, if ,
department management nas adequate authority to accomplish assigned tasks, if adequate administrative support is provided to maximize productive time for personnel operating the plant, if all instructions are issued in a business-like manner, if administrative programs are established for activities affecting employees and if position descriptions are available and utilized for all person-nel.
Finding (Ref. Criterion E)
Some of the control panels have hand written instructions on them.
There is no administrative control over these instructions, and they are not reviewed periodically to determine if they are valid.
Recommendation i
Implement administrative controls over all written instructions posted on control panels and perform a periodic review to determine their validity. l
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PEACH BOTTOM (1980)
Page 17
Response
Administrative requirements will be developed by May 1981, which require authorization and periodic review of information tags and other operator aids which are posted on control panels or equipment.
USE OF PROCEDURES (INPO Procedure OP-304, Revision 1)
In this area, the evaluation team examined the use of procedures to verify if management policies exist for use of procedures, if procedures are being utilized, if peocedures are written clearly, if instructions in emergency proce-dures allow quick and appropriate responses to situations and if a system for revising and controlling procedures is in effect.
Findmg (Ref. Criterion C)
Emergency and operational transient procedures are available in the control room. However, interviews with operations persor.nel indicate that location of the proper procedures during a transient or an emer-gency is cumbersome in that procedures must be located by reference to a lengthy index.
? Recommendation Identify and require the immediate operator action for emergency and operational transient procedures to be committed to memory. Also develop a system for rapid retrieval of these procedures.
Response
Peach Bottom is presently rewriting its emergency procedures in a symptomatic fashion rather than an event oriented fashion in concert with the BWR Owners Group. This new format should permit the operators to more easily memorize and retrieve tha necessary parts of these procedures. In addition, a method to improve operator access time to the emergeacy and operational transient procedures immediately following a transient will be provided by May 1981.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 1)
In this area, the team examined the plant status controls to verify if management-approved policies exist which give guidance in the area of plant status controls, if operability status of equipment is properly controlled, if a senior licensed individual is assigned responsibility for plant status controls, and if special situations such as outages and post accident recovery have provisions for adequate plant status controls.
Finding (Ref. Criterion E)
On occasion, it was observed that the reactor operator was not aware of testing and equipment status changes during the shift. The shift
PEACH BOTTOM (1980)
Page 18 supervisor had given permission to perform these tasks, but no one had informed the reactor operator.
Recommendation Develop a system which ensures that the reactor operator is aware of all testing, maintenance and any other changes in unit equipment status prior to occurrence.
Response
New administrative controls have been instituted which require that individuals who perform surveillance tests advise the affected control room operator upon start und completion of testing. This information is entered on a newly established Equipment Status Log which may clso be used to record other safety-related activities.
OPERATIONS FACILI"'IES AND EQUIPMENT (INPO Procedure OP-306, Revision 1)
In this area, the evaluation team examined the operations fuilities and equip-ment to verify if equipment is accessible for operation, if programs are effected to maximize equipment availability, if the working environment contributes to overall efficiency and safety of plant operations, if communication equipment is adequate and if watch stations are adequate.
- 1. Finding (Ref. Criterion C)
Access to the control panel area in the control room is not adequately restricted.
Recommendation Limit access to the immediate control panel area to those who have a valid need to approach the panels. Establish access controls to ensure that no individuals approach the panels without permission from an on-duty control room operator.
Response
Steps will be taken to physically outline those control panel areas which should be kept clear for operator use. Measures will be taken to ensure that control room operators exercise their authority to limit access to these areas to on-duty operations personnel and others who need access to the control panels. These actions will be completed by May 1981.
- 2. Finding (Ref. Criterion D)
The plant paging system incorporates flashing lights in high noise areas for evacuation. Though this is a good practice, there are a few areas in the plant where the page cannot be heard and flashing lights cannot be seen.
Recommendation Develop a surveillance program to ensure that the plant paging system can be heard in all areas, unless high ambient noise levels preclude audible communication. In these areas, flashing lights should be provided.
Response
The effectiveness of the paging system hcs been hampered by both equipment failures and unauthorized tampenng. Routine safety meet-ings and general employee training are now being used to emphasize the
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PEACH BOTTOM (1980)
Page 19 safety significance of the paging system to all persons at the site. A quarterly operational test will be performed to ensure that persons in any area can be notified of an evacuation. These will begin in the second quarter of 1981. Deficiencies identified during the test will be cor-rected. Design changes or other corrective actions will be taken to correct recurring deficiencies so that reliable evacuation notincation is ensured.
- 3. Finding (Ref. Criterion E)
Some personnel assignments are not consistent with the formal training which they receive. The auxiliary operator's training is principally related to the turbine side systems. He is, however, routinely assigned some tasks in the reactor building.
Recommendation Ensure field operators are properly trained for stations to which they are
' assigned.
Response
Action will be taken to modify the training programs or restrict operator assignments such that the training, qualification and assignments of operators are compatible. These actions will be completed by June 1981.
WATCH TURNOVER (INPO Procedure OP-300, Revision 1)
In this area, the team examined watch turnover to verify if procedures specify turnover requirements for all operating shift positions; if watch turnovers include mechanisms to communicate pertinent information regarding equipment status, operations or testing in progres3; and if pertinent logs are reviewed.
Watch turnover is handled in a professional manner and appears to be effective.
The shift meeting, which is held approximately twenty to thirty minutes into the shift, is a good mechanism for shift communications. There was one finding.
Finding (Ref. Criterion B)
Jumper logs are not reviewed for status changes during watch turnover.
Recommendation As part of the watch turnover procedure, any change in status of jumpers should be reviewed.
Response
Our practice will be changed to require operators to log the removal or installation of jumpers which are applicable to a particular watch station, either on the shift turnover checkoff list or a separate log sheet, in adctition to the permanent jumper log. Oncoming operators shall review the recently installed jumper changes and ensure logging of jumper changes during their shift. This practice will be in effect by May 1981.
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PEACH BOTTOM (1980)
Page 20 _-
MAINTENANCE _
s The maintenance organization, preventive maintenance programs, maintenance ,
procedures and administrative systems for controlling and documenting main- --
tenance work were examined in light of current INPO criteria. The methods used to control test equipment and the overall adequacy of maintenance ,
facilities and equipment were Mso evaluated. Although not part of the -
maintenance organization at Peach Bottom, instrumentation and control (I&C) maintenance activities were included in the scope of the evaluation. -
The Peach Bottom organization for maintenance is somewhat unusual in that '
maintenance personnel,I&C personnel and station management all report admin-istratively to different divisions in the company. The organization, however, is working effectively, and the availabDity of the company's substantial main-tenance resources is a definite asset. Recommendations for improvements were --
made in five specific performance areas.
s MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 2) Js The maintenance and I&C groups were evaluated to determine if these groups _
are organized to accomplish required maintenance tasks. Particular attention -
was given to the interfaces between these groups and plant management. Other --
areas of interest included the availability of position descriptions, delegation of --
responsibilities and authorities, administrative programs, budget controls, safety and communications programs and the administrative / clerical work load on department personnel. The following determination was made: 5 3
Finding All the criteria _ in INPO Procedure MA-401 are being met with the -
exception of the availability of position descriptions, which is addressed ]
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under the Organization Structure area (INPO Procedure OA-102).
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k PREVENTIVE MAINTENANCE $
(INPO Procedure MA-402, Revision 1)
In this area, a review was made to determine if preventive maintenance (PM) activities are being performed and whether or not a v.all-defined and effective -
program is in place. The administrative procedure governing the program and the station organization established to implement it were also examined. Other areas of interest included criteria used to define the equipment included in the program, the use of equipment history files in conjunction with the program, the adequacy of individual PM procedures for safety-related equipment and in- ~
spection frequencies. ,
A considerable amount of preventive maintenance is being performed on both ,
safety-related and critical balance-of-plant equipment at Peach Bottom. As part of an effort to improve the control and administration of the program, the
PEACH BOTTOM (1980) -
Page 21 company has recently designated a preventive maintenance engineer, who reports to the Engineer-Maintenance. A new preventive maintenance co- -
ordinator positior. has also been defined to assist the preventive maintenance engineer, particularly in determining scope and frequency of preventive main-tenance activities. Specific needs for improvement were noted in the following areas. 3 Finding (Ref. Criteria A, B & C) ._
The administrative procedure governing the Preventive Maintenance m Pror, ram (A-25, Rev.1) does not adequately define the objective, scope ar.a adjustment features of the program. It should be noted that the development of a more comprehensive program had previously been identified by station maintenance u one of the Peach Bottom goals for _
1980-81, and a revision to A-25 had been drafted. This revision was in the review and approval process, and thus was not evaluated to deter- g mine if Criteria A, B and C would be met. *
]
Recommendation M Management should continue development of a comprehensive program description and administrative control procedure for the preventive -
maintenance program. The content of the program should include the elements of Criteria A, B and C.
Response --
Peach Bottom has had an informal preventive maintenance program for many years, including a formal lubrication program which has been quite '
successful in avoiding maintenance caused by improper lubrication. As -
indicated, one of the Peach Bottom goals for 1980-81 is to provide elements of a complete formal program. The formal preventive mainte- _-
nance program will be fully implemented by December 1982. 7 ii
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MAINTENANCE PROCEDURES 7 (INPO Procedure MA-403, Revision 2) i In this crea, a review was made to determine the existence and adequacy of maintenance procedures and vendor manuals for safety-related and critical 5 65 balance-of-plant work activities. Procedures and manuals were examined to determine the types of activities covered, scope, level of detail, review and approval cycle, document control requirements and methods of revision. An evaluation was also made of the effectiveness of procedures in controlling and documenting work and inspection activities.
The procedures being used for maintenance are generally high in quality. One _=
reason for this appears to be the debriefing meetings which are held following ,
complex jobs. These meetings provide direct feedback from the craftsmen ,
involved to the Maintenance Engineering personnel who wrote the procedures. -
This is an excellent practice. In evaluating maintenance procedures, the -
following determination was made: -1
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PEACH BOTTOM (1980)
Page 22 Finding (Ref. Criterion A)
While approved procedures exist for most work ac+ivities, some main-tenance and instrument and control work is parformed using vendor manuals that are 7i sipproved or controlled. Maintenance engineering perNnnel were aware of this lack of control and are incorporating instruction manual inforn'ation into procedures to ensure n2cessary reviews and controls. No sin...ar effort is underway in the Instrument and Control Department.
Recommendation The Maintenance Engineering Department should complete revisions to controlled procedures to incorporate required vendor manual infor-mation. The Instrument and Control Department should review work activities and institute review and control of those vendor ramis that will be 'med in the performance of safety related or critical _alspee-of-plant work.
Response
Maintenance Engineering Department procedure revisions will be com-pleteo in a priority sequence based on frequency of usage and reliance on technical manual material. Higher priority revisions will be completed
[
by the end of 1981. All necessary revisions will be completed by the end of 1982.
I&C , vendor manuals are updated with new and revised information when
- it is received. A reference-marked set of updated manuals will be
' established by May 1981. A procedure will be implemented to require use of only this marked set of manuals or authorized current extracts from these manuals.
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WORK CONTROL SYSTEM (INPO Procedure MA-404, Bevision 1)
A review was made of the administrative mechanism used for identifying and reporting equipment problems. An evaluation was perfcrmed to determine if the work control system was dfective for planning and documenting the completion of maintenance work. Specific areas of interest included the administrative procedure for requesting corrective maintenance and those provisions in the system related to planning, authorizing and documenting the work.
e Finding All of the criteria in this procedure are being met.
l PEACH BOTTOM (1980)
! Page 23 ,
M AINTEN ANC" HISTORY (INPO Procedtre M A-405, Revision 2)
A review was made to determine if complete, functional maintenance history records are being retained and used in evaluation of equipment performance.
Specific areas of interest included the amount and types of equipment included - (
in the program; type, level of detail, traceability and retrievability of records; methods used for review and evaluation of maintenance histories; and assignment of responsibility for implementing the program. The following determination was made: , '.
Finding (Ref. Criteria B, C, D, B) r4 While a variety of records are being tetained by various groups within the Maintenance Division and the Test Branch, no uniformly applied program for recording and evaluating maintenance history information has been established. e '
Recommendation A formal maintenance history program should be established and utilized -
to evaluate and trend equipment performance. History information shoulc at;o be used to adjust the Proventive Maintenance Program. /
Reconse ,
As indicated in the MA-402 response, a formal preventive maintenance program will be fully implemented by December 1982. Elements of this '
program will address the methods of documentation, traceability, re- * '
trievability and evaluation of equipment maintenance histories. The periodic review and evaluation of maintenance history will integrate and ;-
1se inputs such as NPRDS and LER data, the records retention / retrieval system capabilities (currently under development), test data and trending plots. Maintenance history features will be described in the approved preventive maintenance program.
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/
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION '
(INPO Procedure MA-406, Revision 1)
In this area, a review was made to determine the adequacy and effectiveness of ,
)8 methods used for calibration and control of test equipment and instrumentation.
Specifically, methods used for identifying, calibrating, storing, issuing, trand 4 porting and using meesuring and test equipment were examined and compared to
- INPO criteria. Procedures establishing and governing the calibration pregram .
and existing calibration records were also reviewed. The following deter- f4 mination was made: ,
Finding hef. Criterion G)
While a generally effective program has been established for calibration g(
and control of test devices, inadequate coritrols exist for issue of such devices by the station Test Branch.
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F PEACH BOTTOM (1980)
Page 24 s
Recommendation The Test Branch should establish additional controls for custody and issuance of test equipment.
< Response bince the evaluation, the areas where test equipment is stored have been placed under control of a member of supervision during normal wcrking
- hours. These areas are now locked at all other times.
a MAINTENANCE FACILITIES AND EQUIPMENT (INPO Precedure MA-4Gd, Revision 1) 9 In this area, a review was made to determine the adequacy and condition of k maintenance facilities and equipment. The location, size and condition of office, .'
'vork and storage space were examined, along with the number, type, condition and location of maintenance tools and equipment. Work and storage facilities s-and equipment were found to be adequate, except as noted below.
r p 1. Finding (Ref. Criterion C) 0 Office and work space for Mechanical Maintenance groups is not
- adequately sized and arranged to accommodate orderly, efficient work ut and storage. Lack of tool storage space in the mechanical shop, the scattered location of various craft work areas and overcrowding in the Meenanical Maintenance Foreman's office lead to reduced efficiency and
= hinder effective supervision. The need for additional space was already m recognized by Maintenance group personnel.
Recommendatiou Overcrowding in the foreman's office should be alleviated as soon as
- - practical. Additich work and starage space should be provided for ma'ntenance group activities as part of the planned administration b building expansion program.
s Response i As noted, the company has recognized the need for additional work, ,
e storage and office space to eliminate overcrowded conditions. Sufficient a space will oc provided in a new administration builcing. Improved storage and control of tools is a part of this plan. This addition is scheduled for completion by November 1982.
h Fir. ding (Ref. Criterion E)
E 2.
B The mechanical shop and tool storage area on the ground floor of the f Administration Building was not mstintained in a clean, orderly manner. ,
b Good housekeeping practices were not bein" used, i Recommendation K Improved storage facilities should be provided in the shop for frequently g used spare parts. Housekeeping should be improved in the shop and tool a,
storage area. The responsibility for shop house <eeping should be -
specifically 1ssigned.
Response
N The overcrowded shop conditions, dispersed group end supervisory work n locations complicate good housekeeping, practias in the shop and tool g storage area. An on-site individual in the Maintenance Division has been assigned specific responsibility for this improvement. Fer the long term, g
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PEACH BOTTOM (1980)
Page 25 the expansion of the shop facilities tv November 1982, along with centralized trade grorp supervision, will materially assist in maintaining proper housekeeping.
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53 PEACH BOTTOM (1980) 1 Page 26 m
A RADIATION PROTECTION AND CHEMISTRY ]
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organization, administration, facilities and equipment were examined in light of 2 current INPO criteria. The content of certain technical pregrams was also -
evaluated. Those programs were ALARA, dosimetry, contamination survell-lance, radwaste, survey equipment control and calibration and chemistry. _'"
Organization and administration appeared to be effective. No significant safety 2 concerns were noted in any of the areas; however, the need for improvement was q present in the areas of ALARA, radwaste management and survey equipment g control and calibration. =q f -
RADIATION PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINIS- C TRATION (INPO Procedure RC-501, Revision 1)
Manpower, organizational structure, authority and training were evaluated to '
determine if they are supportive of good health physics and chemistry programs.
Procedures by which these programs are administered were also reviewed to determine if they provide sufficient guidance to ensure continuity in the conduct _
of day-to-day operations. ._
The recent formation of an independent Health Physics and Chemistry (HP&C)
Department, with the HP&C Engineer reporting daectly to the Assistant Plant _
Superintendeat, ir. considered a positive indication of the importance company _
management p19eas on this area.
Finding With the exception of Criterion D, which is addressed imder the Organi- -
zation Structure ares (INPO Procedure OA-102), all criteria in this procedure were met. J d
4 ALARA PROGRAM E
(INPO Procedure RC-502, Revision 1) i
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This area was evaluateo . ) determine if the company is making a substantive 4
effort to maintain exposures as low as reasonably achievable (ALARA). Those aspects of an ALARA progrem specifically addressed were issuance of a senior management policy statement, assignment of responsibility fer implem antation, T comprehensiveness ac.d mechanisms for setting goals and measuring the success E
of the program. =
A number of good ALARA practices were observed during the evaluation, and discussions with plant personnel revealed that ALARA is an e.ccepted principle at E i
the plant. The evaluation identified several aspects of the ALARA program that need to be formalized. In most cases, these items had already been identified, g and action was being taken to formMize the requirements.
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PEACH BOTTOM (1980)
~
Page 27 Finding (Ref. Criteria A, C, D & E)
- There is no management policy statement regarding the implementation
- of ALARA concepts. There is no formal ALARA program approved by management. Therefore, there is no system for establishing ALARA
- goals or ensuring that all areas of design, operation, maintenance, and training are reviewed for ALARA considerations.
- Recommendation
" The company should establish a highly visible policy showing an intention to keep exposures as low as reasonably achievable.
Response
The concept of minimizing radiation exposure has been a part of the radiation protection program at Peach Bottom since the beginning of operation. The station is in the process of developing a formal program which will address improved ALARA considerations in the operation, maintenance and training areas. This formal program will be in effect by Januaif 1982. In addition we will revise the policy statement in the
"_ company radiation handbook (Refer to Finding OA-102, Criterion D) to reflect Philadelphia Electric Company's commitment to the ALARA concept by December 1981.
I I
s PERSONNEL DOSIMETRY
- (INPO Procedure RC-503, Revision 2)
V Personnel dosimetry practices were evaluated to determine if exposures are being accurately determined and the records and reports of individual exposures are complete and available to those individuals needing the information.
Finding All criteria in this procedure were met.
RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 2)
The evaluation team examined practices used to ensare that workers remain fully informed of radiological conditions in work areas and evaluated the policies for control of contamination to determine if they are consistent 'vith good ALARA practice.
The plant has an adequate program for conducting routine surveys and the bagging and tagging of contaminated equipment appeared good, b Finding All of the criteria in tinis procedure were met.
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PEACH BOTTOM (1980)
Page 28 WASTE AND DIE 055M1GE CONTROL (INPO Procedure RC-505, Revision 2)
This area was evaluated to determine if there is a system of controls that will minimize the generation of radwaste, reduce the likelihood of having an inadvertent release, detect the presence of contaminction in systems where it should not be and ensure that all activities related to this area are effectively coordinated among departments involved in radwaste handling.
?inding (Ref. Criterion F)
In general, management should strive to improve the overall effective-ness of the radwaste program through continual emphasis on volume reduction and by ensuring that activities affecting the radwaste program are coordinated with the various departments involved in radwaste management.
Recommendation Overall goals for the radwaste program should be established, and the assignment of radwaste responsibilities of the various departments should ensure that the goals will be met.
There should be continual emphasis on identifying the sources of radwaste and evaluating how these sources may be eliminated, on identi-fying the cause for personnel exposures associated with radwaste end on monitoring the overall efficiency of the radwaste program.
Response
In order to further evaluate sources of and emphasize reduction of solid radwaste inputs, an individual will be assigned this responsibility.
Recent efforts in th's area include significant reduction of resins applied to both condensate and Reactor Water Clean Up (RWCU) demineralizers, where water chembuv oermits, and development and demonstration of a process to dispose of targe volumes of oily liquid radwaste. Newly implemented procedures and the use of a radwaste quality control inspector in the handling and packaging of solid radwaste will lead to improvements in the overall operation. Identification and reduction, where possible, of the causes of personnel exposure related to radwaste operations will be incorporated in the formal ALARA program addressed in the response to Finding RC-502, criteria A, C, D and E.
RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedare RC-506, Revision 2)
This area was evaluated to determine if the program in use at Peach Bottom will ensure that survey instruments provide accurate measurements, if instruments are available and in good condition when needed and if instruments found to be out of calibration are not used in a manner that causes any significant exposure.
The program was generally c"ective, but one area was identified where improvements should be made.
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7 PEACH BOTTOM (1980) S Page 29 i
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- 1. Finding (Ref. Criterion C)
Procedures do not require a source check of survey instrumer.ts at least daily, prior to first use. A Recommendation C A procedural requirement should be established to source check survey f
- instruments at least daily, prior to first use.
Response
A mechanism will be established by June 1981, to have instruments source checked on a daily basis or prior to first use. _
I
< C a
PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2) A This area was evaluated to determine if the plant staff has established a chemistry control program based on the needs of the particular plant and 4 whether they are adhering to the program. The team also evaluated how well j the staff is staying >: breast of the latest knowledge regarding corrosion mecha- ._.
nisms and how best to prevent corrosion. E-F Finding ,
All the criteria in this procedure were met. ;
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w HEALTH PIIYSICS FACILITIES AND EQUIPMENT 7 (INPO Procedure RC-509, Revision 2) -
This area was evaluated to determine if there are adequate quantities of instruments, equipment and supplies to support health physics and chemistry activities. Work stations were also evaluated to determNi e if they are safe, if they promote efficiency and whether instruments normally used are environ-mentally protected. >
w Finding All of the criteria in this procedure were met. +
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PEACH BOTTOM (1980)
Page 30 IPESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
This area was evaluated to determine if engineering controls are applied to air 5orne hazards and if the respirator program is r4unte. The program for identifying airborne hazards ar.d the type eqttipment avdinb); were reviewed, as was the companfs policy :marding the level of airbctne activity at which respirators are required to be worn.
Finding All of the criteria in this procedure were met.
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PEACH BOTTOM (1980)
Page 31 TECHNICAL SUPPORT This portion of the evaluation examined the technical support activities on site and the plant modification p'rogram.
ON-SITE ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 1)
The team exa nined the activities under the jurisdiction of the Technical Enginee% plus plant modification activities, to determine if an effective organW. ion is in place and if interfaces between engineering groups provide for prompt disposition of engineering problems. The following specific areas ware ev&(.ed: methods used to control design changes, evaluation of plant incidents and operating experiences to determine appropriate followup actions, plant performance monite-ing, in-service inspection and integrated leak rate testing.
Engineering support activities appear to be generally responsive to the needs of the plant. The modification process is well-defined, but there is need for improvement in completing operations-related portions ef design change pack-ages. A shortage of engineering personnel was noted and is discussed under Personnel Qualifications in the Organization and Administration area. Although n
INPO Procedure TS-702 is not specifically concerned with adequacy of engi-neering facilities, it was noted that tL;e at Peach Bottom were overcrowded, noisy and not equipped to support the number of engineering personnel a.ssigned. -
Finding (Ref. Criterion 3)
Plant modifications are often not being completed in a timely manner.
The modification program requires affected drawings and procedures to be revised and operations personnel trained prior to placing modifi-cations in service. However, in many cases, the required paperwork revisions and training were not completed until after a modification was placed in service. Appendix G, recently added to Administrutive Procedure A-14, Plant Modificati. is not being implemented as in-tended. In addition, the mechanisni tor ensuring proper engineering and Plant Operations Review Committee review of as-built deviations from approved modification plans is not being consistently used to ensure that actual modifications are acceptable.
Recommendation Tne requirements of Appendix G to Procedure A-14 should be followed for all modifications. Techniques used to ensure that operators are knowledgeable of plant modifications r nd their affect on operations ;
should be reviewed and improved. An iro. roved control method should be developed to ensure proper review of as-Duilt changes tc approved designs. More timely feedback of as-bult d;anges into the design review process should be required.
Response
The requirements of Appendix G to Procedure A-14 are now being implemented. We will continue to review and improve upon the provisions presented in Procedure A-14. Our Engineering Divisions will either revise or generate appropriate procedures and mechanisms to
PEACH BOTTO31(1980)
Page 32 ensure that changes to designs which may have safety implications will be re-reviewed for safety significance. Feedback, as required, will '3e provided to the site so that required subsequent review and approval of as-built changes to, approved designs can be performed. These proce-dures and mechanisms will be in effect by July 1981.
s e
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PEACH BOTTOM (1980)
APPENDIX Page1 ADMINISTRATIVE APPENDIX I. LISTING OF A!1EAS E'1ALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-105 Information Programs OA-106 Industrial Safety
< OA-107 Surveillance Program OA-108 Personnel Qualifications TRAINING TQ-211 Training Organization and Administration TQ-221 Training Resources TQ-231 Training Etfectiveness TQ-242 Non-Licensed Operate Training .
TQ-243 Licensed Operator Training TQ-244 Licensed Operator Requalification Training
- TQ-246 Shift Technical Advisor Training OPERATIONS OP-301 Conduct of Shift Operations OP-302 Tagout Practices OP-303 Operations Organization and Administration OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-309 Watch Turnover MAINTENANCE M A-401 Maintenance Organization and Administration MA-402 Preventive Maintenance MA-403 Maintenance Procedures M A-404 Work Control System MA-405 Maintenance History M A-406 Control and Calibration of Test Equipment & Instrumentation MA-408 Maintenance Facilities and Equipment
PEACH BOTTOM (1980)
APPENDIX Page 2 RADIATION AND CHEMISTRY RC-501 Radiation Protect. ion and Chemistry Organization and Administration RC-502 ALARA Program RC-503 Personnel Dosimetry RC-50/. Ra.fiation Surveillance and Control RC-504 hate and Discharge Cor.t;o1(Liquid)
RC-506 Radiological Survey Eqdpment Control and Calibration RC-508 Process Water Contro15 RC-509 Health Playsics Facilities and Equipment RC-511 Respiratory Protection Program TECHNICAL SUPPORT TS-702 On-Site Engineering Support 3
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PE ACH BOTTOM (1980)
APPENDIX Page 3
- 11. PHILADELPHI A ELECTRIC COMPANY PERSONNEL CONTACTED Senior Vice President - Nucl~ ear Vice President - Electric Production Manager - Electric Production Super'ntendent - Generation Division / Nuclear Superintendent - Quality Assurance Division Superintendent - Maintenance General Supervisor - Quality Assurance Site Supervisor - Quality Assurance Pecch Bottom Station Superintendent Operations Engineer Shif t Supervisors Radwaste Supervisor Chief Control Room Operators Control Room Opecators Plant Operators - Nuclear Plant Operators Auxiliary Operators Operator Trainees '
Engineer - Technical Results Engineer Surveillance Test CoorJinator
, Instrument and Control Engineer Assistant Instrument and Control Engineer Test Engineers Modification Coordinator h Assistant Modification Coordinator Health Physics and Chemistry Support Engineer g Health Physics Engineer ALARA Coordmator Technical Assistant - Dosimetry Respiratory Protection and Radioactive Materials Coordinator Radiation Protection Specialist Health Physics Supervisor Chemistry Engineer Technical Assistant - Radiochemistry Technknl Assistant - Health Physics and Chemistry Instrumentation Engineer - Administrative Quality Assurance Engineee Training Cooroinator
- Assistant Training Coordinator Susqueham.a Maintenance Area Supervisor Electrical Maintenance Supervisor Mechanical Maintenance Foreman A Assistant Foreman - Pipeiitters Branch Engineer - Susquehanna Test Branch .-
- Safety Committee Chairman Safety Committee Assistant Chairman Senior Safety Representative Safety Representative
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