ML20149H193
| ML20149H193 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/17/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20149H192 | List: |
| References | |
| 50-277-97-99, 50-278-97-99, NUDOCS 9707240271 | |
| Download: ML20149H193 (8) | |
See also: IR 05000277/1997099
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ENCLOSURE
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
(SALP)
PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3
REPORT NOS. 50-277/97-99 AND 50-278/97-99
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- 1.
BACKGROUND
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The SALP Board convened on June 19,1997, to assess PECO Energy's (PECO) nuclear
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safety performance at the Peach Bottom Atomic Power Station during the period October
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15,1995, to June 7,1997. The Board was conducted pursuant to NRC Management
Directive (MD) 8.6, "Systernatic Assessment of Licensee Performance." Board members
were James T. Wiggins, (Board Chairman), Director, Division of Reactor Safety, NRC
Region I (RI), Larry E. Nicholson, Deputy Director, Division of Reactor Projects, Rl, and
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John F. Stolz, Director, Project Directorate 1-2, NRC Office of Nuclear Reactor Regulation.
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The Board developed this assessment for the approval of the NRC Region i Administrator.
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The performance ratings and the functional areas used below are described in NRC MD 8.6
(See NRC Administrative Letter 93-20).
11.
PERFORMANCE ANALYSIS - OPERATIONS
Performance in the area of Operations continued to be excellent. Strong management
involvement in day-to-day operation contributed to the excellent operation of both units
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during the period. Plant management demonstrated excellent monitoring and
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understanding of plant evolutions and material conditions. PECO effectively implemented
the improved technical specifications (ITS), including good controls over new surveillance
tests and other items formerly located in the plant technical specifications.
Routine evolutions were well-planned and implemented by the Operations department.
Shift turnovers were thorough and communications were very good. Clear documentation
of events and issues was noted in control room logs, action requests, and problem
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identification system documents. Operators maintained good plant equipment status and
properly controlled minor equipment problems. The action request system was effectively
used to document timely operability determinations for degraded equipment, and to identify
problems needing engineering support. Operators maintained an acute awareness of
degraded and out-of-service conditions, and provided proper priority and facilitation to
workaround issues.
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Operator human performance during the conduct of operations was excellent. The licensed
operator qualification training program remained good; with improved performance during
license examinations.- No operator errors contributed to reactor scrams or transients, and
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operators response to transients was very good, particularly during recovery from three
reactor scrams and from several partiallosses of offsite power. Some problems were
- noted that indicated the need for improvement in operator attention-to-detail. The
- problems included failure to recognize the impact of starting a reactor feed pump at low
flow during startup, inability to promptly determine spent fuel pool temperatureiand the
insertion of_ the wrong control rod one notch. Also, there were some auxiliary operator
- procedure adherence problems. The safety consequences of each problem was low, and in
each case PECO management recognized the personnel performance issues and took
prompt corrective actions to preclude repetition.
, The problem identification and corrective action systems continued to be effectively used
to address operations-related issues. Management strongly supported efforts to further.
improve corrective action process effectiveness by carefully addressing several self-
- identified areas for improvement within the program. PECO maintained a broad self-
assessment program. --The independent safety engineering group (ISEG), nuclear review
board (NRB) and plant operation review committee (PORC) continued to provide strong
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oversight of plant operational activities. These efforts properly maintained a focus on
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> safety as shown by the proper implementation of ITS.
In summary, performance in the area of Operations continued to be excellent. Routine
evolutions were generally planned and executed with care and precision. -The operators
responded to events and transients in an outstanding manner. Management provided
rigorous and sound safety oversight of most plant activities. Actions to reduce operator
attention-to-detail errors were effective. Oversight of station safety effectiveness
encompassed by ISEG, PORC, and NRB continued to provide excelient assessment and
focus or) sustained plant safety and equipment reliability.
The Operations area is rated Category 1.
111.
MAINTENANCE
PECO continued to maintain overall excellent plant equipment / material condition. Effective
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preventive and timely corrective maintenance activities have maintained the high degree of
equipment availability and reliability. While several plant transients were caused by
balance of plant equipment failures such as with the negative phase sequence current
relay, none of these failures was judged to be maintenance-preventable. Further, the staff
responded well to promptly identify, prioritize and correct degraded equipment conditions.
Exceptions were two instances where the initial attempts to correct high pressure coolant
injection (HPCI) steam admission valve opening timing and emergency diesal generator
(EDG) oscillation were unsuccessful and led to increased system unavailability. The
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material condition focus list effectively highlighted areas that needed further attention.
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In general, PECO conducted well planned on-line and outage corrective maintenance .
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- activities. The work control process was effectively used to plan and coordinate on-line
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maintenance activities. This effort included risk assessment of equipment outages and
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maintenance schedules to maximize plant safety margins. However, in one instance, the
effect of maintenance on the seismic qualification of relays had not been properly _
considered during work planning. The overall rework rate was low, and PECO launched an
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initiative to enhance tracking of this maintenance indicator. Over this period, post-
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problems.
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Maintenance personnel generally performed well, demonstrating good knowledge and good
use of procedures. For examplei mechanical, electrical, and instrumentation technicians
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. conducted well coordinated and effective periodic overhauls of emergency diesel
generators. Deficiencies noted during maintenance activities were identified and .
documented,'and PECO management took appropriate corrective actions. For example,
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severalissues of minor consequence were addressed well, including: removal of a wrong
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fuse during on-line maintenance causing a fully withdrawn control rod to scram; mis-
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calibration of the Unit 2 feedwater temperature instruments,.which effected thermal power;
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'and failure to properly document prior approval of overtime. Some issues related to control
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and qualification of contractors were noted. Specifically, those issues involved failure to
implement established installation procedures for scaffolding, and an impronerly soldered
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connection that caused the Unit 3 HPCI system to be inoperable. PECO responded
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effectively to those problems by enhancing the oversight of contractor work at the site.
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As discussed in the Engineering assessment, PECO's initial implementation of the
maintenance rule was problematic. However, the weaknesses found were offset by the
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high state of safety-related equipment reliability, and the adequacy of plant equipment
performance monitoring using non-maintenance rule processes. Further, good maintenance
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rule implementation following programmatic corrective actions provided a process that
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properly monitored systems and identified, tracked, and evaluated functional failures.
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. Surveillance testing showed sound performance, with an aggressive questioning attitude
applied to identify and correct equipment problems. Operators and technicians used good
communications and remained aware of plant conditions before, during, and after testing.
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Shift management was aware of changing plant conditions and of alarm status. Instrument-
' technicians routinely demonstrated a good questioning attitude as shown by their seeking
supervisory guidance after they found bus undervoltage relays out-of-calibration. PECO
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properly implemented a new testing method to ensure acceptable control rod performance
following replacement of the scram solenoid pilot valve diaphragms. Further, inservice
testing and inservice inspection programs were properly controlled and conducted,
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PECO continued to conduct maintenance and surveillance activities in an excellent manner,
supporting safe operation of both units. - Safety-related equipment was maintained in a high
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state of readiness. As equipment or human performance issues arose, PECO took
aggressive corrective actions to identify and correct the causes. The control and
supervision of contractors was not always effective.
The Maintenance area was rated Category 1.
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IV..
ENGINEERING
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Overall, engineering activities supported plant operations effectively. Station management
consistently provided an excellent level of oversight and attention to engineering activities
at the site, particularly through the work week management process. Engineering issues
were communicated well during daily meetings and the engineering backlog was well
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managed. Typically, the site organization responded expeditiously. to equipment problems
that required engineered solutions. For example, troubleshooting activities included the
appropriate engineering considerations. Also, the engineering organization responded
skillfully to a leak in the high pressure service water system and to fluctuations observed in
emergency diesel generator loading during routine testing. Self-assessment activities, as
complemented by reviews conducted by the Independent Safety Engineering Group, were
effective in monitoring and improving performance in the engineering area.
Engineering design and analysis activities associated with modifications during this period,
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including temporary plant alterations, were of excellent technical quality. .For example, a
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current program to evaluate modifications required to ameliorato high pressure coolant '
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injection system piping vibration included a thorough analysis of the r , stem conditions.
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.. Also, a reanalysis of the effects of a past plant modification on residus.1 heat removal (RHR)
system sequencing was comprehensive in' resolving some old design issues. However,
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problems occurred associated with some modification activities. For example, some of the
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variables that affected the core thermal power calculation by the process computer were
not well-understood or controlled by reactor engineering. In these cases, thorough safety
evaluations and operability determinations supported the safe' operation of the plant.
During the period, some problems were noted ' ass'ociated with the maintenance of the
licensing and design bases and with the translation of design information into procedures.
For example, the 10CFR 50.59 safety evaluation that supported a modification that
required holes to be cut into the turbine building walls lacked an adequate consideration of
the release path that resulted from those holes. In addition, a procedure that allowed the-
use of the standby gas treatment system in a mode outside its design introduced a new
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single failure vulnerability that was not detected during the development, approval or use
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of that procedure. Further, problems with the scope of periodic tests and test acceptance
criteria were found. For example, emergency diesel generator ventilation system capacity
was not verified through testing. Also, routine channel checks did not assess the
availability of the reactor feed pump automatic trip on high reactor vessel water level, and
the boroflex content of the spent fuel racks was not being tested per commitments in the
Updated Final Safety Evaluation Report (UFSAR). Further, the acceptance criteria for
electrical distribution system undervoltage relay settings were not consistent with the plant
licensing bases. The above problems served to underscore the need for the project the
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licensee committed to in response to the NRC 10CFR 50.54(f) letter.
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Also during the period, NRC noted that some important aspects of the licensee's
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maintenance ru!e program were not established correctly. Those aspects dealt, principally,
with the performance criteria selected for use in assessing the effectiveness of the
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preventive maintenance program applied to systems covered by the rule. Neither
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management oversight, nor independent assessment by Quality Assurance, ISEG, or the
safety review committees were effective in averting the weaknesses noted. Nevertheless,
NRC found that the material condition of the plant, particularly its safety-related
. equipment, remained excellent. However, NRC also noted a few balance of plant (BOP)
equipment problems that caused plant transients and challenged operators Continued
engineering focus on preemptive identification and correction of these transient initiators
was warranted.
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System managers continued to demonstrate an excellent level of knowledge associated
with their systems and their activities contributed to maintaining equipment reliability.
System managers and their supervisors responded well to several complex issues, such as
those associated with RHR sequencing, high pressure coolant injection turbine valve
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' operation, and emergency diesel generator load fluctuations. Design engineering personnel
also displayed very good technical knowledge. However, some minor personnel errors
occurred that were dealt with well by the site organization.
In summary, station management provided excellent oversight and control of engineering
activities throughout the period. Engineering analyses and evaluations were of excellent
technical quality and were typically comprehensive. Personnel engaged in engineering
activities were knowledgeable. Nevertheless, some minor errors occurred associated with
modification activities. Some problems with the maintenance of the design and licensing
bases and the translation of those bases into procedures were found that emphasized the
need for the licensee to complete its commitmonts made in response to the NRC 10CFR
50.54(f) letter. Also, some problems were found related to the establishment of the
maintenance rule program; however, those problems did not adversely affect the material-
condition of plant safety systems. Additional focus on the performance of BOP equipment
was appropriate to minimize plant transients that challenge the operators.
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The Engineering area was rated Category 2.
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V.
PERFORMANCE ANALYSIS -- PLANT SUPPORT
The occupational radiation protection program continued to be effectively implemented
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throughout the period. An effective internal and external radiological controls program was
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implemented with no unplanned exposume of note. With the exception of isolated
examples, PECO implemented very good radworker practices. Workers followed radiation
work permits and exhibited proper use of dosimetry and effective contamination control
practices. PECO identified a problem involving control of keys to high radiation areas and
took effective corrective actions.
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An effective ALARA program was conducted including identification and implementation of
lessons learned, implementation of bench marking initiatives, use of robotics, training of
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radiation workers, and effective planning and preparation for outage work activities
including planned and emergent work. Appropriate exposure goals for work activities were
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established and closely tracked. . PECO continued aggressive shielding and decontamination
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efforts. In addition to routine hot spot reduction, flushing practices, and modifications to-
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reduce unnecessary personnel exposure, PECO established a source term reduction team to
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. review station radiological conditions and recommend initiatives to reduce ambient.
radiation dose rates. PECO also completed the Unit 2 outage during this period in 19 days,
which served, in part, to significantly reduce the aggregate exposure for the station for the
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last two years.
PECO implemented an overall effective radioactive waste (radwaste) processing, reduction,
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handling, storage, and transportation program including effective implementation of the
revised Department of Transportation (DOT) and NRC radioactive material shipping -
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regulations. Some minor discrepancies with UFSAR conformance in the area of radwaste
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- processing were noted, and the training program required by the new DOT training rule (49
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CFR 172 Subpert H) was not well defined. PECO took action on the UFSAR matters and
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enhanced the training program description.
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Generally, PECO implemented good chemistry practices. ' For example, the chemistry
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department' responded properly to unexpected reactor coolant conductivity increases.
PECO took effective action to correct sampling process and analysis problems identified
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with the standby liquid control system samples,
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The effluent controls, environmental monitorino, and meteorological monitoring programs
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were effective. Audits were effective in assessing program strengths and weaknesses and
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the performance of the contract environmental laboratory was considered a strength.
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Material condition of equipment related to environmental and meteorological monitoring
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of slightly contaminated oil without consideration of non-gamma emitters in release
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calculations and the release of sewage without an evaluation. Further, lack of
configuration control for decontamination equipment resulted in detectable activity in the
monitored hot shop ventilation system exhaust.
' An overall effective security program was implemented. There was very good
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management support and effective controls for identifying, resolving, and preventing
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security problems. PECO identified that a number of individuals improperly obtained grand
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master keys that could open security doors at both Peach Bottom and Limerick and also
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. identified problems with control of safeguards information (SGI). PECO performed a timely
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and comprehensive investigation of these matters and took appropriate corrective actions.
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' The emergency preparedness (EP) program was effectively implemented and management
support for the program was evident. With the exception of minor discrepancies found in
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the technical support center, generally, the emergency facilities and associated equipment
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were well-maintained and operationally ready. Areas for program improvement included
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the quality assurance program for the emergency plan and implementing procedures,
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Performance during the November 1996, full participation emergency preparedness
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exercise was very good.
- Overall, fire protection procedures provided good guidance and controls to prevent fires,
maintain fire fighting capabilities and respond to any fires which may occur. The program
was effectively implemented.
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The overall material condition and housekeeping at the station was very good. PECO
cleaned and repainted rooms that exhibited degraded conditions and repaired the majority
of groundwater inleakage problems.
Overall, PECO implemented effective problem identification, root cause assessme nt, and
corrective action programs in the Plant Support area. Of particular note was a
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comprnhensive evaluation of the radiological controls program. Also, the radwaste
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prograin 9nd system validation relative to the UFSAR descriptions was appropriate,
in summary, PECO implemented an overall ve
upational radiological controls-
program including exposure control programs and w
oniation control programs. The
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radioactive waste processing, handling, storage and transportation program was very good.
Very good radioactive effluent control and radiological environmental monitoring programs
were implemented, but severalinstances of weaknesses associated with evaluation and
control of potential release paths were noted. An effective security program was
implemented at the site but problems were identified in the area of SGI control and key
control. An effective EP program was implemented. The fire protection and prevention
program waa effective. The self identification, root cause analysis, and corrective action
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programs were overall effective. Material condition of the station including housekeeping
was overall very good.
The plant support area is rated Category 1.
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PLANNED NRC INSPECTIONS
June 7,1997 - June 6,1998
PEACH BOTTOM ATOMIC POWER STATION
UNITS 2 AND 3
IP - NRC Inspection Procedure
Core Procedure - NRC inspection Program Mandatory inspection
TBD - To Be Determined
Target
Procedure
Number
TITLE
Date
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Inservice Inspection
- Core Procedure
09/29/97
Occupational Radiation Exposure (RADCON-Outage)
- Core Procedure
10/20/97
Occupational Radiation Exposure (RADCON-Visit 1)
- Core Procedure
04/20/98
Radwaste Treatment & Effluents & Environ. Monitoring (Visit 1)
- Core Procedure
10/27/97
iP 84750
Radwaste Treatment & Effluents & Environ. Monitoring (Visit 2)
- Core Procedure
06/01/98
Radioactive Waste Transportation
- Core Procedure
08/18/97
Physical Security Program (Visit 1)
- Core Procedure
09/02/97
iP 37750
Engineering Focus Inspection (including Followup to
- Core Procedure
10 CFR 50.54(f) response commitments)
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