ML20065S579
| ML20065S579 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/16/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20065S539 | List: |
| References | |
| NUDOCS 8211010372 | |
| Download: ML20065S579 (8) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. D ALTROFF ELEcYnscen cTios August 16, 1982 Re: Docket Nos. 50-277 50-278 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki:
Your letter of July 15, 1982 forwarded the Systematic l
Assessment of Licensee Performance (SALP) report for Peach Bottom Atomic Power Station and was followed up by a meeting on July 27, 1982, to discuss the report findings and our prooosed corrective actions.
Philadelphia Electric Company appreciates the opportunity to have met with you to discuss our performance and to comment on your report findings.
We believe this annual opportunity to meet with the NRC management to discuss your views relating to our operation is beneficial and productive.
During our meeting we had the opoortunity to exchange viewpoints and comment on certain cortions of your report.
We also indicated proposed corrective actions for those areas where NRC exoressed concerns.
This report will formalize our proposed corrective actions as was reauested in your letter.
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A soecial advisory letter has been sent by appropriate Vice Presidents to each of their Supervisors working at Peach Bottom Station.
This letter emphasizes the Supervisors' l
responsibilities in maintaining a hiah level of work performance,
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particularly in the areas of health physics, housekeeping and safety.
In addition, special management meetings have been i
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R. W. Starostecki Page 2 scheduled with nersonnel to increase the awareness of each individual to the importance of following nuclear rules and procedures.
We believe that most'of the identified weaknesses are primarily in first line supervision and craftsmen support and are not programmatic.
The extremely long refueling / modification outages the past two years have significantly increased the site manpower requirements and have contributed to deficiencies noted in the SALP report.
Philadelphia Electric Company management-remains committed to addressing deficiencies and improving operations where required.
Following are our resoonses to specific NRC comments identified in the SALP report.
Plant Ooerations SALP Comment "Although decision making is usually at a level that ensures adeauate management review, shift-to-management communications have caused occasional oroblems in this area."
"Daf-to-day onshift supervision and control of operations needs to be more thorough and aggressive."
Response
A series of meetings were held last winter with operating shift and supervisory personnel to stress the importance of keeping olant management informed of plant status and activities and supervisory responsibility regarding control of operations in accordance with Technical Specifications.
These meetings were conducted by the Station Superintendent and the Operations Engineer.
There are two Senior Engineer level peoole on call at all l
times for notification and decision making.
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individuals carry " beepers" to provide promot response to l
operator cuestions or changes in plant status.
Plant l
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Mr.
R. W.
Starostecki Page 3 management requires shift-to-management communications with senior duty engineers, particularly on weekends and holidays.
The importance of notifying the senior duty engineers of plant conditions and exceptions will be stressed again during the next meetings with operating personnel.
SALP Comment "During the assessment period, the licensee improved his responsiveness to alarm conditions...
About 5 years ago a typical PECo. response would have been to assume annunciator failure without investigation."
Response
In recent years, Philadelphia Electric Company has taken a more conservative approach to inoperable annunciators and has limited the time that plant and eauipment operation is continued with alarm failures.
We would emohasize, however, that it has never been our policy to assume annunciator failure when an alarm is received without further investigation.
Other instrumentation is reviewed and the acceptability of the alarming parameter is confirmed before operation with a non-functioning alarm is continued.
We believe it was the intent of the SALP report to comment on our more conservative approach in responding to inoperable annunciators rather than a failure to investigate when an alarm is received, i
Radiological Controls SALP Comment l
"The licensee's Radiation Protection Program should receive increased emchasis..."
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Mr. R. W. Starostecki Page 4 Resoonse In order to improve performance and control of our Radiation Protection Program, we have developed an Action Plan to delineate specific steps to be taken in the health physics and radiation protection areas.
The Action Plan was developed using the following inouts:
a)
NRC Inspections and Health Physics Aporaisal b)
Special assessment audit of our health ohysics program conducted by INPO at the reauest of Philadelphia Electric Company.
c)
Philadelphia Electric Company management recommendations.
We believe the Action Plan is a comprehensive and effective means to improve our Radiation Protection Program.
Steps have already been taken to implement the items identified in the plan.
Bi-weekly updates and review of incomplete actions will ensure orompt attention to all items.
A copy of the Action Plan has been provided to the Peach Bottom NRC Resident Inspector for his information.
SALP Comment
... licensee management has not placed sufficient emphasis on overall radiation protection program or on ALARA."
Response
Philadelphia Electric Company has formally adopted the ALARA l
plan which has been in trial use since October, 1981.
Additional personnel have recently been assigned to implementing the ALARA effort.
ALARA was also a specific item addressed in the aforementioned letter from appropriate l
Vice Presidents to their Supervisors.
Further, suggestions from INPO and procedures utilized at other facilities are being examined for possible imolementation.
i SALP Comment
...a cualified Radiation Protection Manager does not, currently, supervise the radiation protection program."
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Mr. R. W. Starostecki Page 5
Response
Philadelphia Electric Company formally designated an individual cualified to the requirements of Regulatory Guide 1.8, September, 1975, " Guidelines for Radiation Protection Managers Qualifications" in a Technical Specification
-submitted on June 3, 1980.
Since our original submittal, we have provided two additional amendments to reflect organization and personnel changes.
In each case, an individual cualified to the requirements of Regulatory Guide 1.8 was designated.
Our most recent submittal, dated July 7, 1982, reflects the addition of a new supervisor at the senior staff level with responsibility for the plant's radiation and chemistry programs.
Although we recognize there was some delay in formally designating this individual as the Radiation Protection Manaaer, he has been acting in this capacity since January, 1982.
Prior to January, 1982, other cualified individuals filled this position.
Maintenance SALP Comment "The Licensee has difficulty coordinating outstanding maintenance actions.
Coordination is manual and, on occasion, not all needed or due maintenance is completed on eculpment when it is taken out of service for repair."
Response
i We are in the process of developing and implementing two new comouterized maintenance programs to provide better scheduling and tracking of maintenance activities.
The Project Resource Evaluation and Management Information System (PREMIS) program will schedule maintenance activities based on resources and priority of various tasks.
PREMIS will replace the outmoded PMS IV orogram which reauires a significant amount of manual input.
The Computerized History and Maintenance Program System (CHAMPS) will track and provide listings when maintenance is due on eculpment and will maintain a history of work when it is completed.
We expect these programs to be operable for use during the next Unit 3 refueling outage.
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,a Mr. R. W.
Starostecki Page 6 SALP Comment
...better first line supervision and control of maintenance is needed.
An example is the housekeeoing and contamination control problems associated with the recent Unit 2 outage..."
Response
In order to provide better first line supervision of maintenance activities, particularly in the area of housekeeping and fire protection, a program has been initiated to provide improved accountability.
Maintenance first line supervision must now complete a form which establishes work location, status of the area with respect to housekeeping and fire protection, and actions taken when appropriate.
These forms will be reviewed and inspections made to reinforce the importance of improved oerformance in these areas.
Housekeeping & Fire Protection SALP Comment "The Philadelphia Electric Company has a history of coor management attention to fire protection and housekeaping...
The problem recurs and does not appear to receive sufficient corporate management attention."
Resoonse Philadelphia Electric Company recognizes that housekeeping has been a Droblem at Peach Bottom and has taken special steps to improve our performance.
We also recognize that poor housekeeping can lead to potential fire safety problems, however, we do not feel this is sufficient to indicate poor management attention to fire protection.
On the contrary, during the SALP review period, there were numerous steps taken to improve our overall fire protection program at Peach Bottom including a significant increase in the number of smoke detectors, additional fire suooression systems, improved fire brigade training and eauipment, and additional oil containment curbs.
Management has always placed major emphasis on our overall fire protection program and will continue to do so.
We continue to take action to improve housekeeping.
Prior to the last refueling outage all site maintenance personnel were reminded of the importance of oood housekeeping
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Mr. R. W. Starostecki Page 7 practices.
The subject was also stressed at almost every daily outage meeting.
On one occasion, all work in the drywell was stopoed to correct unsatisfactory housekeeping.
Additional steps were taken during and after the outage to further improve housekeeping and fire protection practices.
These steps include the following:
a)
In May, 1982, the Station Suoerintendent held discussions with group supervisors to increase effective control of plant housekeeping.
As a result of these discussions contractor, maintenance, and constraction supervisors would inspect their respective work areas to ensure that housekeeoing quidelines were being followed.
Their findings were reported to their cupervision and the outage manager.
b)
A control point operating procedure is being written to address the actions to be taken by health physics technicians to provide better housekeeping and fire protection at control points.
c)
Shift supervision and health physics eersonnel increased their housekeeping inspections during periods of high activity.
d)
A letter dated July 15, 1982, from the Station Superintendent to all Peach Bottom personnel was distributed to emphasize the importance of following nuclear rules; particularly in the areas of safety, housekeeping, fire protection, and health physics.
Further, any individual violating the Nuclear Plant Rules will be restricted from the Protected Area cending l
an investigation and appropriate corrective measures.
e)
A Maintenance procedure was developed and implemented which requires each Subforeman to document the status of I
l his work locations as far as housekeeping and fire protection are concerned.
Corrective actions taken are I
also noted and these forms are reviewed by maintenance supervision.
Philadelphia Electric Company is committed to providing a safe, clean working environment for all Peach Bottom personnel.
We will continue to work to imorove housekeeping and fire protection.
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Mr. R. W. Starostecki Page 8 Security and Safecuards SALP Comment "The licensee's accepted Physical Security Plan is inconsistent with current standards in several areas."
Resoonse Although the SALP Report was not specific enough to address individual items, we recognize that some inconsistencies do exist.
However, comoensating measures have been taken where appropriate to provide a level of security consistent with current standards.
The current Peach Bottom Physical Security Plan was thoroughly reviewed and evaluated by the NRC.
Based on overall evaluation of our plan, our approach was determined to be acceptable to meet security standards.
If you have any auestions or wish to discuss any part of the SALP report further, please d6n't hesitate to contact us.
Very truly yours, 3
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Peach Bottom Site Inspector