ML20138D358
| ML20138D358 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/09/1993 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302170297 | |
| Download: ML20138D358 (8) | |
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O PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUA'RTERS 955-65 CHESTERBROC < BLVO.
WAYNE, PA'19087 5691 (2ts) sao sooo g
S E NIO R VICE PR S atDENT
- MUCLE AR February 9,1993 Docket Nos'. 50-277 50-278 License Nos. DPR DPR-56 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Initial Systematic Assessment of Licensee performance, Report Nos. 50-277/91-99: 50-278/91-99, Submittal of Written Comments Gentlemen:
NRC letter dated December 31, 1992, transmitted the initia'l Systematic Assessment of Licensee Performance (SALP) for Peach Bottom Atomic' Power Station (PBAPS) Units 2 and 3 for the period of August 4,.1991, through October 31, 1992. - A meeting was subsequently held with the'NRC on January 20, 1993, during which we reviewed our accomplishments during the SALP period and our plans to continue improving performance.
This letter provides our written comments on the initial SALP Report as requested by the-Dec. 31, 1992 NRC letter.
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i We concur with the SALP Board's assessment of' activities at PBAPS in the areas of Maintenance and Surveillar.ce Emergency Preparedness, Nuclear.
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Security, Engineering ani! Technical Support, and Safety Assessment / Quality-L Verification. However, as discussed in our January 20, 1993 meeting, we-1 request that two of our SALP ratings be reconsidered. ' Specifically, we respectfully request that you consider upgrading the SALP rating in Plant Operations from a two to a two with an improving trend und the SALP rating in Radiological Controls from a 2, improving to a one.
The following provides the basis for our request.
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February 9,:1993-3
', ? PBAPS Units-2 and 3,cInitial SALP.
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-Report Nos.150-277/91-99::50-278/91-99, Submi,ttal of Written Comments.
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..u Plant Operations Operations has c~onsistently taken prudent actions during plant transients and when doubts about the condition of plant equipment;have arisen. During the July 4,- 1992 transformer fire event arid throughout all of the emergency planning drills,.their knowledge and use of Emergency procedures was outstanding.
Early in the SALP period when an industry.
concern over level transmitters was identified, the start up'of both units.
was delayed until the concern was fully resolved.-.lhis prudent action has continued; recently when the status of several motor operated valves was in question both units were voluntarily kept shutdown untii thorough safety assessments could'be performed.
.While maintaining this safety perspective, operations staffing has
-significantly increased.- Eleven new nuclear plant' equipment operators were adJed.
In addition, ten existing personnel have become qualifid as Senior q-Reactor' Operators (SRO) and seven plant operators have entereu reactor operator training.
The increased staffing and qualification levels have enabled operations to initiate new prograus and improve the morale of shift teams. A third shift supervisor'(SSV) has been'added to each shift team which allows enhanced supervision of the non-licensed operators. Further, new staffing levels have provided additional career opportunities.
The recent shift outage reorganization has allowed the crcation of the refuel outage team with six shift supervisors and a shif t manager. This team was highly successful during the recent Unit 2. refueling-outage; completing the outage with a significant reduction in opera or caused License Event Reports (LERs).
During the entire SAlf ariod, from Aug. 4, 1991 to Oct. 31, 1992 the number of-LERs caused by operator' error decreased-
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to one-third of the previour SALP period level'.
i To accommodate these new people and to improve the working conditions for the plant-operators new facilities were constructed.
PECo spent considerable resources,in remodeling the plant operator's office and the main control room offices.- The new plant operator's office includes several work stations with com)uters, controlled plant procedures and drawings, and L
a kitchen. Further, t1e main. control room has been remodeled to optimize performance.
These changes are an example of management's-commitment to improving operations and have had a positive impact on the professionalism, teamwork and morale of the operations staff.
Other examples of an improved culture and focus among the operators are as follons. The operators are open with management anc have arovided candid' oainions about the operation of PBAPS. The operations staff las increased' t1e number of self identified event reports from 198 in 1990 to 337 in 1991 to 472 in 1992 because they believe management will listen and-respect their input.
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Report Nos..
PBAPS Units 2 and 3, Initial SALP-l February 9,:1993:
50-277/91-99: 50-278/91-99,-
Page 3-
-Submittal of Written Comments b
PECo believes that the improvements broughtLabout by these initiatives have been reflected in improved performance over the' SALP period.- further, the cultural' changes we have achieved are significant because they put into place the foundation for future successes.. Therefore,-we respectfully request that you consider-upgrading our rating to include an improving trend lin this area.
Radiological Controls The Radiological. Controls SALP area is divided-into Rar'iological Protection, Chemistry, Radioactive Waste and Transportation,-Radiological.
Environmental Monitoring, Confirmatory Measurements and Effluent Control.
In each of these areas management attention to and. involvement in nuclear safety activities has resulted in a superior level of performance.
In Radiological Protection, we have improved rad worker practices and-undertaken an aggressive personnel exposure reduction program.
Both;of these programs have been outstanding successes. As shown in Graph I, personnel contamination reports were reducec from 804 in 1991 to 208 in 1992. This is about one. half of the national average. Graph-II; presents the reductior. in. personnel exposure from 934 manrem in 1991 to~ 503 manrem
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and the reduction in the station's average exposure from before 1989 and after 1989.
The success in reducing exposure is a long term achievement resulting from excellent planning and management initiatives and direct line management involvement in radiological controls. Both the contamination reports and the station's average exposure place PBAPS near-the top 25% of all BWRs.
Peach Bottom is one of the nation's least contaminated BWRs with 94%-.of the entire station uncontaminated. These improvements are the result of l
aggressive housekeeping practices and strong contamination control. Health Physics (HP) technicians visited and evaluated seven other utilitics to improve our own radiological controls.
Philadelphia l Electric: initiated and' hosted a first of its kind Regional ALARA Conference which included-L participants from the NRC, Brookhaven National Laboratories, INPO and the -
industry.
L In Chemistry, we have achieved a-thr_ee fold reduction in liquid releases (Graph III)_ and reduced reactor conductivity by. a factor of-two and half (Graph IV). The 1992 INP0 performance indicator for chemistry index had.a BWR median of 0.33.
P3APS achieved a index of- 0.24 or below for 1992.
The PBAPS index exceeded the INPO 1995 Industry goal of 0.30 and_ made PBAPS one of-the best performers in the nation relative to the chemistry index.
The NRC recognized these achievements in chemistry and in the SALP stated:.
" Performance in the areas of~ effluent controls'and the REMP continue to be.
excellent".
In Radwaste, during.the past 5.yeurs PBAPS has made over.1700 shipments without a single violation or'radwaste shipping incident. This' record.was acaieved while reducing the backlog of radwaste inventory ten fold. This reduction is part of a strategic plan developed in anticipation of burial site closings.
These achievements were noted in the SALP: "Overall=
- [radwaste] performance emained excellent", and are' indicative of the
-excellen; planning and effort in the Radiological Controls area.
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PBitPS Unit's 2 and 3, Initial. SALP February 9, 1993-w ;
Resort Nos.:50-277/91-99: 50-278/91-99, Pcge 4 i;
Su3mi.ttal of Written Comments :
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These achievements in Radiation Controls-have been sustained over a-number of-years and are the result of management attention and outstanding planning.- 10 further enhance performance in this area, we are instituting an advanced rad worker program and additional'dnse. reduction plans.. We wi 1 also'be improving our drywell shielding packages and are investigating the use of robotics to lower station exposure. We believe these initiatives,..
9 coupled with our outstanding performance in the other radiological control areas are indicative of superior performance. Therefore, we respect fully.
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request that you consider upgrading the rating in this area.
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If you have any questions or need additional information please contact.
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Very truly yours, f
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T. T. Martin, Administrator, Region I, USNRC J. J. Lyash, USNRC Senior Resident-Inspector, PBAPS W. P. Dornsife, Commonwealth of Pennsylvania v
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'89 -'92 AVE = 635 MANREM
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UNIT 2 AND 3 AVERAGE 4
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Graph IV-All Data Taken at > 10% Reactor Power.
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