ML20151G982

Ack Receipt of Comments on Util Plan for Restart of Plant. Comments Will Be Factored Into Review of Util Plan

ML20151G982
Person / Time
Site:	Peach Bottom
Issue date:	06/16/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Schaefer W MARYLAND, STATE OF
Shared Package
ML20151G963	List: ML20151G961 ML20151G982 ML20151H002
References
NUDOCS 8808010090
Download: ML20151G982 (1)

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18 JUN ISH The Honorable William Donald Schaefer Governor of Maryland i

Annapolis, Maryland 21404

Dear Governor Schaefer:

. Thank you for the comants on the Philadelphia Electric Company (PEco) Plan for Restart of Peach Bottom Atomic Power Station. Ve have forwarded your comments to PECo for their consideration in revising their plan. We note that your concerns are generally consistent with many of those which we have previously transmitted to PEco.

j We agree that people's actions and not the words of the restart plan will assure safe operation of the plant. After NRC completes its review and approves the restart plan, and after PEco has completed implementation of the approved restart plan and has completed their own assessment of readiness for restart (including an INPO evaluation), the NRC will conJuct an Integrated Performance Assessment Team inspection (IPAT). The purpose of this final major inseection j is to evaluate implementation of the restart plan to determine if there is -

reasonable assurance that tFe plant can and will be operated safely. As I stated to Secretaries Brown and Walsh when I met with them on March 22, 1988, the State of Maryland may have an observer at this inspection. We will keep Mr. Thomas Magette inform *d regarding this inspection.  ;

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, Your coments are being f actored into our review of tne PEco plan. Ve will i infor1n you of the results of our evaluation of all issues relevant to the shutdown order. ,

Once again, thank you for your thoughtful coments. We will continue to keep your staff informed of developments at Peach Bottom.

Sincerely, 1 h William T. Russell Regional Administrator ,

cc:

Mr. Thor.as Magette Dr. Max Eisenberg .

l Mr. David Carroll I

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• yllt Mr. William T. Russell Regional Administrator ' " ' * "

United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Dear Mr. Russell I am writing to provide the State of Maryland's initial comments on the Plan for Restart of Peach Bottesa Atomic Power Station, Revision I, published by the Philadelphia Electric Company on April 8, 1988.

My position remains that Peach Bottom should only be restarted if it will be operated in a manner that assures the protection of the health and safety of the public. I believe that with some modifications the Restart Plan can completely describe corrective  ;

actions needed at Peach Bottom. I do not believe, however, that l this or any other plan can assure safe operation of the plant.

Only people can do that. That is why we must focus our offorts l on ensuring that the Restart Plan is successf ully implemented, .

i once it has been revised.

1 have repeatedly asked the NRC to establish restart criterie against which to judge PECO's offorts. In his April 7, 1988 ,

I letter to me, NRC Chairisan 1,ando tech stated that the Restart Plan itself, once accepted by the NRC, represents restart r I

criteria. While I am willing to agree that an acceptable restart plan contains minimum standards which PECO must meet prior to restart, I an uncomfortable calling the plan restart criteria for  ;

two reasons. The first is that accepting the Restart Plan as l criteria does not address the issue of of fectiveness. One still must identify means for determining if and when PRCO has success-  !

fully implemented the tasks outlined in the Restart Plan. l In his letter, Chairman Zech also stated that PECO's most f difficult challenge will be addressing the attitude problem. The attitude problem also poses a formidable challenge to the >RC.

You must assure that PECO has successfully addressed this problem, as well as having successfully addressed the other elements of their Restart Plan, once approved. Af ter all, it is results, not plans, that ultimately are important. Reviewing the s *,i,., ..

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Mr. William T. Russell ,

May 26, 1988 Page 2 i

r ettectiveness of PECO's corrective actions is evsn more imprtant than identifying those aross requiring correction. Obviously some l of the changes at Peach Bottom are more important than others.

The offectiveness of these changes must be reviewed with i

1 particular care. The changes for which offective implementstion

- is most important, as well as most difficult to verify, are  !

listed in an attachment.

Several independent reviews of the effectiveness of PECO's cor-rective actions are u'iderway. In addition to the NRC's review, PRCO's of forts are being scrutinized by the Institute of Nuclear Power Operations and the Advisory Committee for Reactor 2 Safeguarc s. Satisfying the concerns of these reviewers will be a <

critical step for PECO. It will be important for each of these organizations to identify criteria against which to measure the '

j effectiveness of PECO's efforts. The State of Maryland intends to independently evaluate offectiveness, as well as monitor the 1

. other reviews. i The Restart Plan as submitted generally corrects the serious j deficiencies of the plan submitted last August. The attention i given to the responsibility of corporate management for the  :

problems at Peach Bottom, the correlation between the tasks listed and specific shutdown issues, and the focus on issues i directly related to restart are significant improvements. I find i that with few exceptions, concerns have been '

J my previous s addressed. There are still certain issues which are either not j addressed, or not addressed in adequate detail.

The most significant shortcoming of the Restart Plan is that it i fails to adequately address the issue of providing enough

! operators to ensure safe operation of the plant. It is clear that 1

the number of operators at Peach Bottom prior to the shutdown was i j inadequate. In the Restart Plan, PECO states that it will implement a plan to ensure that there are adequate numbers at restart. I do not believe that this is sufficient. The Restart

] Plan should explicitly address the number of operators necessary to operate the plant without rssorting to excessive otertime, and j, whether or not PECO presently has in its employ or on contract this many licensed operators. This issue is directly related to the problems which led to the shutdown, and it must be addressed I

prior to restart. I have attached to this letter a description of l other issues not adequately addressed by the Restart Plan.

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! This leads to my second concern with the NRC's definition of '

J restart criteria. Once the plan has been revised as necessary, the NRC has stated that "fulfilling the requirements of this plan l

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r Mr. William T. Russell t May 26, 1988 i Page 3 become the essential ' restart criteria'..." However, in spite j of oar extensive reviews, there is the possibility that the 1 activities outlined in the Restart Plan might be inadequate to i address certain problems. Our analyses of offactiveness may lead us to conclude that new corrective actions are required. Thus,

) completing the tasks outlined in the Restart Plan does not in

itself justify restart.  !

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! I as pleased that PECO seems to now have in place corporate ,

! of ficers who understand the ef fort necessary to ensure the safe operation of Peach Bottom. With the inprovements I have suggested, the Restart Plan can serve as the outline of necessary 1 changes. Effective implementation can ensure safe operation of  :

l Peach Bottom.  ;

Effectively implementing the approved Rastart Plan and receiving permission to restart will not be the end of the road for PECO.

Many of the changes now taking place at Peach Bottom will require i literally years to implement fully. Achieving the level of ,

{ excellence that the new PECO management insists is their ultimate '

objective for Peach Bottom will also take years. The State of Maryland will continue to review the progress towards these long ,

) term goals. We will continue to monitor PECO's progress towarde i

meeting long term commitments to the NRC and INPO. We will j continue to monitor the status of all outstanding technical l I issues, including resolution of the MARK I containment issues and I l emergency planning activities. Thus, I expect to work closely l

! with the NRC on activities at Peach Bottom for a long time. .

1 l j I hope you find these comments useful in your ongoing evaluation. .

J I am interested in your response to these comments, and I look l

{ forward to providing additional input on PECO's efforts to -

1 correct the problems at Peach Bottom. Please continue to direct

{ all information to Mr. Thomas Magette of the Power Plant Resterch

) Program, who is coordinating the State's review of all issues

concerning the shutdown of Peach Bottom. Also please continue to l

) provide concurrent notification to Dr. Max Eisenberg of the

Maryland Department of the Environment and Mr. David Carroll of my staff.

l j ,41 cerely, l0lHU 4 J Governor <}

i cc: Lando W. Each, J .

J Secretary Torrey C. Brown  ;

i Secretary Martin W. Walsh, Jr.  !

) David Carroll l I a

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ATTACHMENT 1 CHANGES REQUIRING MOST RIGOROUS REVIEW

1. Performance The most obvious symptom of problems at the Peach Sottom Atomic Power Station was inadequate performance, most particularly on the part of licensed operatsrs and their supervisors. Since the shutdown it has become clear that improved performance must be required not only of these individuals, but of substantial numbers of other PECO emplovees Ensuring that thers has been substantial impr. In performance of Peach Bottom employeen as well as PL ...a gemen t to the highest levels of the company should ,, .he highest priority of the NRC's review.

2. Shift Managers The most serious performance problems were in the control room. In an offort to improve supervision of the licensed operators, PECO has revamped the management of activities in the control room. The cornerstone of this new arrangement is the Shift Manager, a new position. Use of this system should be carefully evaluated to ensure that the desired changes in licensed operator performance, attitude, and morale have resulted. t

3. Self Assessment capability PECO has taken several steps to improve their internal evaluation processes to ensure that onca the plant is restarted they will be able to identity and correct deficiencies in performance long before they become as serious as they had by March 1987. This self assessment capability is critical, and the eff3ctiveness of PECO's  ;

changes must be carefully evslut.ted.

4. Management Training The "snagemenn Analyuis Company report identified j ineffective managers as one of the principal underlying l problems at Peach Bottom. It is crucial that managers  !

receive the training necessary to help them correct problems j with their own performance ss well as that of their subordinates.

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5. Corporate and Site Reorganization Shortly after tho shutdown of Peach Bottom, PECO realizen ' hat thei: nuclear power activities were in need of restructur.'ng and srganization. With the preliminary permission cf NRC, PECO has completed this reorganization. This reorganization is intended to contribute to the improvament of several aspects of operation, among them

• Communication between site and corporato sr.anagement

• Accountability of site and corporate management

• Improved (shortened and strengthened) chain of command

• More managers

• Scheduling and control of work onsite It is critical to ensure that reorganization has improved operation of Peach Bottom.

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ATTACHMENT 2 SPECIFIC COMMENTS ON THE PLAN FOR RESTART OF PEACH BOTTON ATOMIC POWER STATION

1. The Restert Plan should give the numb 6r of < operators 1 required for normal operation of the plant without excessive  !

overtime and describe how PECO will provide this mumber of operators, i 1

Major Activities 2-1.1.1, 2-1.1.2, and 2-1.1.3 describe PECO's commitment to assess operator availability, j accelerate operator training, and supplement opamator corp with contractor and co-ownor personnel. This should be augmented to include more detail, including the number of operators required, and specifically how PECO win provide these operators.

2. The Restart Plan should describe the role in the new organization of those individuals serving as Shift Superintendents at the time of shutdown.

1 It is not clear from the Restart Plan whether or not the former Shift Superintendents will be in supervisory positions under the new organization. PECO should avoid -

using these individuals to superviae personnel which have undergone rehabilitation training, or address how this could be done without compromising efforts to effset an ottitudinal change at Peach Bottom.

3. Face-to-face performance evaluations of all employees at  !

Peach uttom should be conducted prior to restart. l Major Activity 3-2.2.3 commits PECO to developing a plan for training managers in how to conduct face-to-face ,

evaluations. Face-to-face perforinance evaluations are l important in evaluating impr6vement in performance and j attitude. P.cause they have been conducted poorly if at all in the past, they should be conductea for all employees ,

prior to restsrt. The results of these evaluations are critical for assessing PECO's success in changing attitudes l sr ' improving perfor' nance.

4. . Jitional management t. raining should be conducted for supervisory personnel.

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Ma jor Activitle' 3-2.1.1 through 3-2.1. 4 and 3-2. 2.1 through 3-2.2.6 describe management training given some supervisory personnel at Peach Bottom. PECO ehould provide all supervisory personnel with management training or describe and justify the method used in selecting those individual: who received training. I

5. PECO should modify its personnel disciplinary guidelines to 1 identify infractions warranting immediate dismissal.  !

Major Activity 3-4.1.1 states that disciplinary guidelines i have been modified to identify infractions warranting l immediate suspension. These should be further strengthened to identify even more serious measures, such as immediate dismissal, when justified.

6. Opportunities for rotating operators off-shift should be identified and implemented prior to restart. ,

Maior Activity 2-2.1.1 concerns developing opportunities for apurators to rotate off-shift, and ultimately to enjoy career opportunities off-shift. While promotional opportunities can he developed over time, opportunities for licensed operators to have teuporary relief f rom shif t duty should be developed and implemented prior to restart. It is recognized that the overall number of operators nay limit these opportunities in the near future.

7. The Restart Plan should address the maintenance backlog, both preventive and corrective, and how it wJ 11 be reduced ,

to an acceptable level.

The maintenance backlog at Peach Bottom has received a great  !

deal of attention. Much of the outstanding corrective and ,

preventive maintenance should be completed prior to restart. l The Restart Plan should address commitmonts made to INPO concerning maintenanco, any maintenance tasks which will ba ,

outstanding at the time of restart, and the schedu'.e for completing all maintenance tasks.

8. The Restart Plan should address all outstanding conne'.tments i to NRC and INPO, and PECO's schedule for addressing them.

PECO has made several commitments to the NRC and INPO concerning corrective a;ctions identified in, for example, 1 NRC Inspection Report 3, Information Notices, and INPu  !

evaluations. While winy of these commitments go beyond l restart issues, it is important to ensure that PECO has an acceptable plan for addressing all issues, no matter how long tern, prior to restart. The Restart Plan should contain a plan and schedule for addressing these additional commitments.

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