ML20151H002
| ML20151H002 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/07/1988 |
| From: | Mikulski B, Sarbanes P SENATE |
| To: | Zech L NRC COMMISSION (OCM) |
| Shared Package | |
| ML20151G963 | List: |
| References | |
| NUDOCS 8808010101 | |
| Download: ML20151H002 (4) | |
Text
,
SAR8 ARA A. MIKULSKI.
2-i MARYLAND mited States $tnate WASHINGTON, DC 20510-2003 r
^
June 7, 1988 The Honorable Lando W.
Zech l
Chairman Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555 Dear Chairman Zech We are writing to express our continued concern about i
the restart of the Peach Bottom Atomic Power Station.
On May 26, 1988, Governor William Donald Schaefer provided the Nuclear Regulatory Commission (NRC) with the State of 4
Maryland's comments on the Philadelphia Electric Company's (PECO) April 8, 1988 "Plan for Restart".
We share the Governor's concerns and ask that each and every issue that i
he has raised be given a thorough and timely response.
Furthermore, we ask that the NRC formally recognize the State of Maryland's role of consulting and commenting on all i
aspects of the NRC's process of determining whether the Peach * ". tom plant is safe for restart.
1 3
As you know, we have asked the General Accounting Office to use Peach Bottom as a case example in determining a
the criteria NRC uses to allow a nuclear plant to restart after being shutdown to correct safety and management problems.
Governor Schaefer also has repeatedly asked the NRC to establish restart criteria against which to judge PECO's efforts.
The GAO has agreed to undertake the first phase of this study, and we ask that the NRC consider the j
results of the study before making their decision on the restart of Peach Bottom.
2 In addition to the GAO study, the NRC's Advisory Committee on Reactor Safety has agreed to review the plan 4
l for restart, and the Institute for Nuclear Power Operations (INPO) continues to review the status of the Peach Bottom plant.
We ask that the results of these studies be made available to all interested parties, including the State of-Maryland and the Harford County Council, and that the NRC establish an appropriate means of receiving public co.4ments l
on the results of these investigations.
i
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It is our understanding that PECO has invited the State i
of Maryland to have a representative on-site at Peach j
Bottom.
We are pleased that PECO's new corporate officers i
pgg8010101 geo739 CORREhhhNhENhkPDC
The Honorable Lando W.
Zech June 7, 1988 Page 2 seem to recognize the importance of the state's par-ticipation in the process to determine whether the Peach Bottom plant is safe to restart.
We request that the NRC permit the Maryland representative to accompany NRC inves-tigators when they visit Peach Bottom to verify that PECO has effectively implemented the corrective actions of the restart plan.
We believe that it is in the best interest of the people of Maryland that the NRC continue to hear what the State of Maryland has to say and to take it to heart.
Until each and every question about safety has been addressed, it would be irresponsible to approve the restart of Peach Bottom.
Thank you for your attention to our request and we look forward to your reply.
Sincerely,
- p Paul S.
Sarbanes Barbara A. Mikulski United States Senator United States Senator BAMicdt cc: The Honorable William Donald Schaefer
YCn Y.
STATE OF MARYLAND h/ d OmCE Of THE GOVERNOR
%Y n etev *Ene to WILLLM4 DONALD SCHAd,ts cooo 1
Awvous uArrtue i.o (Dl 974 Not
""*d,0 May 26, 1988 M5gmyg Di mwo lu (
444 NorfH CAh70L Sf ttif a w s
Mr. William T. Russell Nm oc no 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 Botton Atomic Power Station, Revision I,
published by the i.iladelphia Electric Company on April 8, 1988.
My position remains that Peach sttom 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 S. actions needed at Peach Bottom. I do not believe, however, that
'this or any other plan can assure safe operation of the plant.
Only people can do that.
That is why we must focus our efforts on ensuring that the Restart Plan is successfully implemented, once it has been revised.
I have repeatedly asked the NRC to establish restart criteria against which to judge PECO's offorts.
In his April 7,
1988 i
letter to me, NRC Chairman Lando Each stated that the Restart i
Plan
- itself, once accepted by the
- NRC, represents restart criteria. While I am willing to agree that an acceptable restart plan contains minimum standards which PECO must meet prior to restart, I am uncomfortable calling the plan restart criteria for two reasons.
The first Je that accepting the Restart Plan as criteria does not address the issue of effectiveness. One still i
muot identify means for determining if and when PECO has success-l fully implemented the tasks outlined in the Restart Plan.
In his
- letter, Chairman sech also stated that PECO's most dif ficult challenge will be addressing the attitude 'problog. The 1
attitude problem also poses a formidable challenge to the NRC.
(
You must assure that PECO has successfully addressed this
- problem, as well as having successfully addressed the other 7
elements of their Restart Plan, once ap proved. Af ter all, it is 6
results, not plans, that ultimately are :mportant.
Reviewing the C
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Mr. William T. Russell May 26, 1988 Page 2 effectiveness of PECO's corrective actions is even more important than identifying those areas requiring correction. Obviously some of the changes at Peach Bottom are more important than others.
The effectiveness of these changes must be reviewed with particular care.
The changes for which offactive implementation 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 underway. In addition to the NRC's review, PECO's efforts are being scrutinized by the Institute of Nuclear Power Opt. rations and the Advisory Committee for Reactor Safeguards. Satisfying the concerns of these reviewors will be a critical step for PECO. It will be important for each of these organizations to identify criteria against which to measure the effectiveness of PECO's efforts. The State of Maryland intends to independently evaluate effectiveness, as well as monitor the other reviews.
The Restart Plan as submitted generally corrects the serious d2ficiencies of the plan submitted last August. The attention given to the responsibility of corporate management for the proolems at Peach Bottom, the correlation between the t,esks listed and specific shutdown issues, and the focus on issues
., directly related to restart are significant improvements. I find that with few exceptions, my previous concerns have been addressed. There are still certain issues which are either not addressed, or not addressed in adequate detail.
l The most significant shortcoming of the Restart Plan is that it fails to adequately address the issue of providing enough i
operators to ensure safe operation of the plant. It is clear that the number of operators at Peach Bottom prior to the shutdown was i
inadequate.
In the Restart
- Plan, PECO states that it will implement a plan to ensus.e that there are adequate numbers at restart. I do not believe that this is sufficient. The Restart i
Plan should explicitly address the number of operators necessary to operate the plant without resorting to excessive overtime, and 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 addre,ssed prior to res' tart. I have attached to this letter a description of other issues not adequately addressed by the Restart {lan.
This leads to my second concern with the NRC's definitihn of restart criteria.
Once the plan has been revised as necessary, the NRC has stated that "fulfilling the requhements of this plan
Mr. William T.
Russell Mty 26, 1988 Page 3 become the essential ' restart criteria'..."
However, in spite of our extensive reviews, there is the possibility that the activities outlined in the Restart Plan might be inadequate to address certain problems.
Our analyses of effectiveness 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.
I am 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 improvements I
have suggested, the Restart Plan can serve as the outline of necessary changes. Effective implementation can ensure safe operation of Peach Bottom.
Effectively implementing the approved Restart 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 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 towards meeting long term commitments to the NRC and INPO.
We will
., continue to monitor the status of all outstanding technical issues, including resolution of the MARK I containment issues and emergency planning activities.
Thus, I expect to work closely with the NRC on activities at Peach Bottom for a long time.
I hope you find these comments useful in your ongoing evaluation.
I am interested in your response to these comments, and I look forward to providing additional input on PECO's efforts to correct the problems at Peach Bottom. Please continue to direct all information to Mr. Thomas Magette of the Power Plant Research Program, who is coordinating the State's review of all issues concerning the shutdown of Peach Bottom. Also please continue to provide concurrent notification to Dr.
Max Eisenberg of the Maryland Department of the Environment and Mr. David Carroll s f my staff.
Sincerely,
/S/
s Governor cca Lsido W. Ecch, Jr.
Secretary Torrey C. Brown Secretary Hartin W. Walsh, Jr.
David Carroll
ATTACHMENT 1 CHANGES REQUIRING MOST RIGOROUS REVIEW
- 1. Performance The most obvious symptom of problems at the Peach Bottom Atomic Power Station was inadequate performance, most particularly on the part of licensed operators 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 employees.
Ensuring that there has been substantial improvement in performance of Peach Bottom employees as well as PECO management to the highest levels of the company should be the 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, s
- and morale have resulted.
3.
Self Assessment Capability PECO has taken several steps to improve their internal evaluation processes to ensure that once che plant is rectarted they will be able to identify 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 offactiveness of PECO's changes must be carefully evaluated.
4.
Management Training The Management Analysis Company report identified ineffective managers as one of the principal underlying problems at Peach Bottom.
It is crucial that managers receive the training necessary to help them corrget problems with their own perfornance as well as that of \\their subordinates,
5.
Corporate and Site Reorganization Shortly after the shutdown of Peach
- Bottom, PECO realized that their nuclear power activities were in need of restructuring and reorganization.
With the preliminary permission of the
- NRC, PECO has completed this reorganization.
This reorganization is intended to contribute to the improvement of several aspects of operation, among them l
- Communication between site and corporate management
- Accountability of site and corporate management Improved (shortened and strengthened) chain of command
- More managers
- Scheduling and control of work onsite l
It is critical to ensure that reorganization has improved operation of Peach Bottom.
O i
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ATTACHMENT 2 SPECIFIC COMMENTS ON THE PLAN FOR RESTART OF PEACH BOTICK ATOMIC POWER STATION 1.
The Restart Plan should give the number of operators required for normal operation of the plant without excessive overtime and describe how PECO will provide this number of operators.
Major Activities 2-1.1.1, 2-1.1.2, and 2-1.1.3 describe PECO's commitment to assess operator availability, accelerate operator training, and supplement operator corp with contractor and co-owner personnel.
This should be i
augmented to include more detail, including the number of operators required, and specifically how PECO will 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.
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 supervise personnel which have i
undergone rehabilitation training, or address how this could be done without compromising efforts to effect an attitudinal change at Peach Bottom.
I 3.
Face-to-face performance evaluations of all employees at Peach Bottom should be conducted prior to restart.
Major Activity 3-2.2.3 comunits PECO to developing a plan for training managers in how to conduct face-to-face evaluations.
Face-to-face performance evaluations are important in evaluating improvement in performance and 1
attitude. Because they have been conductsd poorly if at all in the past, they should be conducted for all employees prior to restart.
The results of these evaluations are critical for assessing PECO's success in changing attitudes and improving performance.
4.
Additional management training should be conducted for supervisory personnel.
1 l
./
s Major Activities 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 should provide all supervisory personnel with management training or describe and justify the method used in selecting those individuals who received training.
5.
PECO should modify its personnel disciplinary guidelines to identify infractions warranting immediate dismissal.
Major Activity 3-4.1.1 states that disciplinary guidelines i
have been modified to identify infractions warranting i
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.
Major Activity 2-2.1.1 concerns developing opportunities for operators to rotate off-shift, and ultisately to enjoy career opportunities off-shift.
While promotional opportunities can be developed over time, opportunities for licensed operators to have temporary relief from shif t duty should be developed and implemented prior to restart.
It is recognized that the overall number of operators may limit these opportunities in the near future.
7.
The Restart Plan should addroso the maintenance backlog, both preventive &nd corrective, and how it will be reduced to an acceptable level.
1 The maintenance backlog at Peach Bottom has received a great deal of attention.
Much of the outstanding corrective and i
preventive maintenance should be completed prior to restart.
The Restart Plan should address cossaitments made to INPO concerning maintenanca, any maintenance tasks which will be outstanding at the time of restart, and the schedule for i
completing all sLaintenance tasks.
8.
The Restart Plan should address all outstanding cossaitments l
to NRC and INPO, and PECO's schedule for addressing theng PECO has made several cossaitments to the NRC and INPO 1
concerning corrective actions identified in, for example, NRC Inspection
- Reports, Information Notices, and INPO evaluations.
While many of these commitments go bhyond restart issues, it is important to ensure that PECO has an acceptable plan for addressing all issues, no matter how long
- term, prior to restart.
The Restart Plan should 1
contain a plan and schedule for addressing these additional
{
comstitments.
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. UNITED STATES 6
[
.t NUCLEAR REGULATORY COMMISSION L
8 WASHINGTON. D. C. 20555
' +,......
EDO. Principal Correspondence Control FROM:
DUE: 06/21/88 EDO! CONTROL: 0003755
. DOC DT: 06/07/88 FINAL REPLY:
San. Paul S.
Sarbanes Ssn. - Barbara A. Mikulski TO:
4 Chairman Zech FOR SIGNATURE OF:
ROUTING:
)
i EXPRESSES CONCERN ABOUT RESTART OF PEACH BOTTOM Stello t
i Taylor l
DATE: 06/10/88 Rehm Murley, NRR ASSIGNED TO:
CONTACT:
Murray, OGC RI Russell 4
SPECIAL INSTRUCTIONS OR REMARKS:
1 I
'I 9
4 i
- 0 i
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET i
PAPER NUMBER:
CRC-88-0531 LOGGING DATE: Jun 9 88 ACTION OFFICE:
EDO AUTHOR:
B.A. Mikulski& Paul Sarbanes AFFILIATION:
U.S. SENATE LETTER DATE:
Jun 7 88 FILE CODE: ID&R-5 Peach Bottom
SUBJECT:
Express concern about the restart of the Peach Bottom Atomic Power Station ACTION:
Signature of Chairman i
DISTRIBUTION:
OCA to Ack, RF, Cars, DSB SPECIAL HANDLING: None NOTES:
DATE DUE:
Jun 23 88 SIGNATURE:
DATE SIGNED:
1 AFFILIATION:
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