ML20151D022

Responds to Raising Number of Concerns Re Plant. Decision to Permit Restart Will Not Be Made Until Commission Convinced That Previous Problems Corrected & That Operation of Facility in Safe Manner Assured

ML20151D022
Person / Time
Site:	Peach Bottom
Issue date:	04/07/1988
From:	Zech L NRC COMMISSION (OCM)
To:	Schaefer W MARYLAND, STATE OF
Shared Package
ML20151D025	List: ML20151D022 ML20196D974
References
NUDOCS 8804130356
Download: ML20151D022 (5)

Text

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Docket File TMartin e

' fp uog'o UNITED STATES NRC PDR FGillespie i

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! o . NUCLEAR REGULATORY COMMISSION 3 i WASHINGTON, D. C. 20555 E00 3508  !

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o f TMurley/JSniezek l FMiraglia j

%,*****/ April 7, 1988 SVarga j CHAIRMAN 880ggr  :

l WButler REMartin/RClark U Brien I NRR Mailroom PDI-2 Reading i 0GC )

The Honorable William Donald Schaefer Stello Governor of Maryland r Annapolis, Maryland 21401 fae ussell, RI

Dear Governor Schaefer:

I am responding to your letter of February 12, 1988, in which you raised a number of concerns regarding the Pa=rh R 3 t t om A t onia:

Power Station. Specifically, you questioned whetler the Commission had adequately defined the problems at Peach Bottom and l whether we have 2eveloped suitable criteria to assess the readi- j ness of the plant to resume operations. J In the Commission's view, the problem at Peach Bottom is wel? I defined. The NRC shutdown order, our reports on routine inspec- l 4 t'ons, and the Systematic Evaluation of Licensee Performance I (SALP) reports all define waaknesses that must be corrected before a decision on restart can be made. The solutions proposed to correct those weaknesses must demonstrate that Philadelphia _ i Electric Company (PECo) is fully capable of opera, ting Peach Bottom within the confines o' the Commission's safety requirements befor' any Commission decision can be made to allow restart of the ,

facility.  !

It is important to recognize that it is the responsibility of PEco, not NRC, to formulate programs that address the weaknesses  ;

that have been identified at the plant. In partici!1ar, PECo must l demonstrate that it has provided strengthened line management to -

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ensure safe opera' ion of the facility, strong independent over- l sight of operating activities to ensure that problems are quickly identified and effectively corrected, and an operating environment that fostr- safe, professional operation of the facility, i PECo's fi.. recovery plan did not satisfy NRC's concrirns. In response to our finding, PECo provided additional, revised ,

material in November 1987 and February 1988. We are still  !

evaluating these submittals. You have already provided us with  !

your comments on the licensee's earlier action plan, and we will l be pleased to consider any further comments you may have on their  !

revised plan.

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2 When a facility such as Peach Bottom is shut down for safety reasons, the NRC does have in mind specific corrective actions i

that must be satisfactorily implemented before the plant can be i permitted to restart. Substantial changes are needed in per-  ;

sonnel, organizational interactions, and procedural implementation ,

at all levels of the PECo organization. PECo's recovery plan is the blueprint for the needed change. Once accepted by the NRC as a satisfactory plan of action to bring about the needed change at Peach Bottom, fulfillment of the requirements of this plan become the essential "restart criteria" that you are requesting. The NRC uses the utility recovery plan as a basis when evaluating restart readiness. The NRC staff determines the effectiveness of the recovery plan's implementation and whether it is having the

,esired effect in correcting the problems you have described in

. your letter, j i

Underlying the problems at Peach Bottom is the attitude problem l that existed from the corporate level to the control room. PEco has the responsibility to address this problem, and we expect this- l will be PECo's most difficult challenge. The Commission has  !

already expressed its views on this matter at the public meeting i on September 14, 1987, when PECo presented its initial recovery '

plan to the Commission. The recent appointment of a new Chief Executive Of ficer and Executive Vice President, both with nuclear ,

utility backgrounds, should make a major contribution to bringing j about the changes that are necessary before the Commission will  !

allow restart of Peach Bottom.

f However, there are no laws, regulations, or other standards that address individual attitudes. Attitudinal problems do not lend themselves to measures of performance based on objective j standards. The NRC must have confidence, based on direct 1 j observation of licensee performance at every level of the  !

, organization, that management and supervision both at the I corporate of fice and at the f acility are commi tted to, and require, high standards of professional performance from its employees. Over the next several months as our inspectors, technical reviewers, managers, and the Commission itself continue to interact with representatives of PECo, we will not only evaluate the plant hardware and procedures, but also the in-dividuals with whom the safe operation of the facility may once again be entrusted.  !

We also share your concern about the issues raised in the recent letter from Mr. Zack Pate of the Institute of Nuclear Power Operations (INPO) to the PECo Board of Directors. We note that Mr. Pate's concerns involving poor performance at Peach Bottom I l

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encompass a number of issues which have already been identified and are being reviewed by the NRC. As an example, improper actions by operators which led to the shutdown have been the basis of ongoing NRC enforcement conferences with the involved licensed operators and their former supervisors. In our deliberations, we will insure that PECo addresses each of the issues raised by Mr.

Pate prior to any decision on restart of Peach Bottom.

Ultimately the Commission will decide whether the Peach Bottom plant will be allowed to restart. We will make that decision based on a careful review of the licensee's recovery plan and the staff's evaluation of its implementation. Prior to reaching any decision on restart, the Commission will be briefed by the staff in a public meeting. Based on that briefing, the Commission will make its decision with respect to restart of Peach Bottom. I can assure you that a decision to permit restart will not be made until the Commission is convinced that previous problems have been corrected and that there is reasonable assurance that PEco can operate the facility in a safe manner and in accordance with applicable NRC regulations.

Please be assured that we will continue to take into account the concerns of the State of Maryland with respect to the restart process at Peach Bottom.

Sincerely.

-de OJ. W N*

Lando W. Zeo,, Jr

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i, UNITED STATES NUCLEAR REGULATORY COMMISSION O :j WASHINGTON, D. C. 20555

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FROM: Dt E: FDri r.ONTROL: 007508 7, ._j

,7% 7M nrir DT: o?/12/83 WILLI AM DONAl D TCHAFFFR / gjfp FINAL RFPLY:

GOV. OF MARYLAND

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TO:

CHAIRMAN 7ECH FOR SIGNATIIRF OF: ** PRIORITY *+ SFCY NO: RR-119 CHAIRMAN ZECH DESC: ROIITINO:

QUESTIONS CONCERNINii SAFF OPERATION OF PEACH STELLO BOTTOM T AYl.OR

_ __ RFHM eDATE: 02/1R/8A Ri l:.*:41 L . RI NRR CONTACT: MitRIEY Mi tRR AY , OGC (ASSIGNEDTri 3 5SPECIAL INRTRUCTIONS OR RFMARMS:

0 NRR RECEIVED: FEBRUARY 19, 1988 ACTION: -- DRPR:VARGA .,

NRR ROUTING: MURLEY/SNIEZEK MIRAGLIA MARTIN GILLESPIE tOSSBURG

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OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET 3 PAPER NUMBER: CRC-88-0119 LOGGING DATE: Feb 17 88 I t

ACTION OFFICE: EDO f l

AUTHOR: W.D. Schaefer i AFFILIATION: MD, GOVERNOR LETTER DATE: Feb 12 88 FILE CODE: ID&R-5 Peach Bottom

SUBJECT:

Tssues surrounding Peach Bottom ACTION: Signature of Chairman DISTRIBUTION: RF, GPA/SLITP to Ack SPECIAL HANDLING: None NOTES:

DATE DUE: Feb 29 88 ,

t SIGNATURE: . DATE SIGNED:

AFFILIATION: l

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suinoet o s<t February 12, 1988 e w asr ,,rstoTs't,'r'rl astuostu g g,rg us Notogagt Mr. Lando W. Zech, Jr., Chairman *** No'g/gfgjig Nuclear Rcquiatory Commission ac2: oa ms 1717 H Street, N.W. voo my in >3e Washington, D.C. 20555

Dear Chairman Zech:

As you know, members of your staff briefed me and members of the Maryland Congressional Delegation last week on the issues surrounding the Peach Bottom Nuclear power plant.

I am, quite frankly, more concerned now about the situation at Peach Bottom than I was before the briefing.

I am sure you agree with me that we have an obligation to protect the public safety. More than any other form or energy, nuclear power requires absolute public confidence. The consequences of a mistake are too great.

Although we maintain a careful review of the power plants in and around the state, Maryland has no formal standing t

. in the review process. Ultimate responsibility for the safe operations of Peach Bottom, as with any nuclear power plant, rests with the NRC.

What troubled me most was not what I heard but what was missing from the briefing. I had hoped to hear your plans for ensuring that the long-standing problems at Peach Bottom would be corrected prior to restart. What I heard instead were vague categories, not a specific plan of action.

Determining what restart criteria to use in judging

_w hether or not_Pjach Bottom can resume operat_i_ols__is.

Jerital and was not adequately addressec. Categories like "acceptable maintenance backlog" or "effective quality assurance program" cannot substitute for specific criteria. How will you know if a quality assurance 3

program is effective? What is an acceptable maintenance backlog? These are questions, like so many others, that must be answered now. How can I, as Governor, tell the people of Maryland that we are on the right track at Peach Bottom if we can't even define the problem, if we don't have a good yardstick by which to measure Peach Bott A rmance2_-- -

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Mr. Lando W. Zech, Jr., Chairman February 12, 1988 Page Two i

I What is most disappointing is the lack of direction in correcting the personnel problems that are at the root of A all Peach Bottom's dilficultie ]s. There is a perYagive attitude problem that runs trom tne contY31~ room at Peach BottTm~to'the boiird room at Philadelphia Electric. If there was any doubt as to just how pervasive this attitude problem is, those doubts were dispelled with the release of the recent letter from Zach Pate of the Institute of Nuclear Power Operations (INPO) to the PECO board of directors.

Much of the information in this letter leads me to believe that the plant should have been closed sooner.

But if the NRC was not aware that the personnel probrems throughout~PECO had deteri~otated to the, point where c~65tinued~ operation _of_the_ plant _was literally a threat-to the~ health and safety of the public, how will.

you know when this attitude problenjias been cor~recEed?

I am shocXEd Ey thW acti~ons and statements of the highest i officers of the corporation as documented in Mr. Pate's letter. It has been suggested that rehabilitation of the licensed operators is not possible. Frankly, I believe that changing the attitudee of operators will be easier than changing the attitudes of some corporate officers.

You must determine how to correct the'at~tl~tude problem, and verify that the corrections are effective. Simple assurances are not enough.

The NRC should identify specific restart criteria, make them publicly available, give interested parties such as the State of Maryland the opportunity to comment on them, and finalize them prior to proceeding any further with its review of Peach Bottom. As a start towards identifying specific criteria PECO should be required to improve its scores in the NRC's SyEtsmatic Assessmeht 6f LTcensee_Eerformance. The improvements sh'6u1T~be quantff~Ied. The NRC's inspection program should also be used to evaluate improvements in

performance. Inspections conducted liiinWthe shutdown

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have continued to identify numerous violations of NRC rules. The NRC should require PECO to meet

' 4 Lefiniti Ja_inspretioILgo_a_1s, such as completing a specific period prior To restart (for exarple 6 months) without being cited for a violation.

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r Mr. Lando W. Zech, Jr., Chairman February 12, 1988 Page Three Some of the most useful information for assessing PECO's performance has come from independent sources such as INPO. It is essential that such independent reviews continue to be performed. The role of these parties should be formalized as part of the review process. All subsequent PECO plans should be reviewed by and revised to the satisfaction of INPO before they are submitted to the NRC.

I cannot emphasize enough the importance of the recent INPO letter in identifying the unabated continuation of

e. problem which we had been led to believe was at least in the process of being corrected. I am fully aware that it is unprecedented for this information to have been made public, but it is clearly crucial that it was. I am writing Zach Pate directly to urge that all INPO reports on Peach Bottom during the shutdown and for one year beyond the restart also be made public. I urge you to join ne in this reque_st.

Finally, I was very glad to hear Dr. Murley affirm that the NRC will involve the State of Maryland in its review as extensively as possible. This commitment is essential to me. I assure you that we are keenly interested in participating in this process, and will cooperate with you and your staff in every way possible.

I look forward to hearing from you in the near future.

Sincerely,

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Governor cc: Maryland Congressional Delegation l

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