ML20064A717

Comments on SALP Board Repts 50-277/89-99 & 50-278/89-99. Author Pledges Continued Mgt Support of & Attention to Rate of Improvement,Achievement of Goals & Performance of Routine Activities

ML20064A717
Person / Time
Site:	Peach Bottom
Issue date:	09/18/1990
From:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9009270214
Download: ML20064A717 (3)

Text

'lp;u; Qi* g3 y 's;

' ~ ~ ^ ~ ~ '~ ~

'-(" ~ : -,

^ ^- --- -- - ^ --

• • j eB e ej t

.l

, m,, ,

.- PHILADELPHI A- ELECTRIC COM PANY - J

' , %W NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.

WAYNE, PA 19087 5691 1 (215) 640-6000 D. M. SMITH '

einson vica pnestosNT

• MUCLE An September 18, 1990- j Docket Nos. 50-277-278 License Nos. DPR-44 l DPR l

1 .1 lU.S. Nuclear Regulatory Commission

• l Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Peach-Bottom Atomic Power Station, Unita 2 and 3

-Systematic Assessment of Licensee Performance

, Board Report No. 50-277/89-99;278/89 J Submittal of Written Comments u

y' .

l Gentlemen:' q NRC; Letter-dated AugJat 10' 1990--transmitted the NRC's

, I

. Initial' Systematic' Assessment of Licensee' Performance (SALP) Board. '

L 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 J j i met with NRC representatives on' August 29,11990 at the Peach Botton

, site toidiscuss.the SALP Board Report assessmentiand'our plans;to correct;the identified weaknesses. At-that' time-we indicated we would Q respond,in: writing to the SALP Board Report.. Accordingly, this letter- i 1 .provides'our: written comments by. summarizing,our-statements made at the August 29, 1990 meeting.

+

. . - Overall, we concur with the SALP Board'.s assessment of-Lactivities at-Peach Bottom. jWe. find that the Board Report recognizes--

f that we successfully implemented restart and power' ascension programs 1

L for-bothxunits, that we-have established a solid foundation of'self y . assessment programs:and'a management philosophy-of safety conscious a  : operations, and that our progress in strengthening our performance has been' positive. We also understand that in addition to the progress which has'bea 'ade, much work remains toward improving our 4' performance. ,

i=

9009270214 900918 -

PDR ADOCK 05000277 Q PDC 76'/0 .

E

///7

-s b- 0' -'

L !ErEch Bottom Atomic Powar Station, UnittlB: 2 and 3 S2ptGmb2r 18,.,1990

'J' SystGmatic AsOGcCO3nt of~Lican233 P3rformance Page-3 Board Report No.:50-277/89-99;278/89-99

~

Submittal of Written Comments-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 beer, rapid over the past year, but now we must' sustain the improvement j 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 routine activities. We will continue to sustain our ongoing self assessment processes and our management philosophy of safety conscious operation. '

i i

please If you have any questions, or need additional information,.

contact us.

Very truly yours,

// 7 ,

cc: T. T.~ Martin, Administrator, Region I, USNRC i J. J . Lyash, USNRC Senior Resident ~ Inspector, Peach Bottom

'I i

i i

l 1

i c: \

a i

I

f 0 *g 4 .  !

K Pe:ch Bottom Atomic Power StGtion, Unito 2 cnd 3 S3ptember 18, 1990 V Sy0tematic.As000sment of Lic:n3OO Performanc3 Page 2 i Board Report No. 50-277/89-99;278/89-99 Submittal of Written Comments  ;

A m

i In the Plant Operations area, we are continuing our efforts f 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 the training progren for Reactor Operator and Senior Reactor C7erator licenses to achieve our goals. Also, we have instituted a root cause  :

o analysis of the blocking problems and valve misalignments that ;<e i occurred at the station. The results of this analysis will b3 conver',ed into corrective actions to help improve the effectiveness of  !

pur process for equipment removal and return to service. Also, we  !

nave 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. '

In the area of Radiological Controls, we have completed the i 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 r the statements made by your regional staff at the August 29, 1990  :"

meeting that the Board recommenoation contained in the Initial SALP Report should'be revised to reflect that the root cause determination f 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 estab21shed specifications, we have acted promptly to resolve the 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 do not contain copper, which is one of the main contributors to crud-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 '

corrective actions that we are currently implementing in order to i imorove our performance. ,

L In the area of Engineering and Technical Support, an outside consultant has just completed our review of our Environmental ,

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 l that should improve our learning from safety system functional e j inspections performed by the NRC staff and performed by ourselves. We i

recognino that engineerine and technical support of the station has to

,, - ,----,,en--m-~ ,, , -. , , - ,-,-w- -g- , - , - --,.,,,n .-.y- -,-----,--~--y--.--- , . >