ML20154B001

Forwards SALP Input Covering Apr 1985 - Jan 1986 for 860324 SALP Board Meeting.Overall Category 2 Assigned in Area of Licensee Performance

ML20154B001
Person / Time
Site:	Peach Bottom
Issue date:	02/25/1986
From:	Gears G Office of Nuclear Reactor Regulation
To:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8603040199
Download: ML20154B001 (10)

Text

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Docket Nos.: 50-277 50-278 MEMORANDUM FOR: Samuel J. Collins, Chief Project Branch #2 Division of Reactor Projects Region 1 THRU: Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing FROM: Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Licensing

SUBJECT:

NRR SALP INPUT - PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 Attached is NRR's input-for the March 24, 1986 SALP Board meeting for the Peach Bottom Atomic Power Station, Units 2 and 3. As discussed in~

the attachment, our evaluation was conducted according to NRR Office Letter No. 44, dated January 3,1984 and NRC Manual Chapter 0515, Systematic Assessment of Licensee Performance.

Originsi clenid by]

Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Attachment:

As stated cc w/ enclosure R. Bernero T. Johnson (Sr. Resident Inspector)

DISTRIBUTION:

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NRC PDR PD#2 R/F Glainas, AD GGears SNorris OFFICIAL RECORD COPY DBL *PD#2 fiBQPDi2 DBL: QJ2:D SN r s:nc GGelts Q. 6f 2/jy86 2/g/86 17,/86 e603040199 860225 ADOCK 05 [7 gDR

,4N UNITED STATES 8 %o NUCLEAR REGULATORY COMMISSION 4

a WASHING TON, D. C. 20555 Docket Nos. 50-277 and 50-278 FACILITY: Peach Bottom Atomic Power Station. Units .' and ~

LICENSEE: Phi 1adelphia Elettric Com,3 a n s NRR PROJECT MANAGER: Gerald E. Gears

1. INTRODUCTION This report presents the results ot an evaluation of the Itcensee.

t Philadelphia Electric Company, in the functional area of licensing activities. It provides NRR's input to the Peach Bottom SALP revieh process as described in NRC Manual C! . a u t er 051e. The review covers the period April 1, 1985 to January 31 1986.

The approach used in this evaluation was to colect a number of licensing actions which involved a signif icant amount of staff effort or which were related to important safety or r equl atory tesues for the period from April 1, 1985 to January 31 1995. In most cases, the staff applied the evaluation criterion for the performance attributed based on their first hand e:: p er i enc e with the licencee or with the licensee's submittals. Each organization within NRR t h a t- was responsible for developing a safety evaluation was obligated to provide a SALP input in accordance with NRR Office Letter No.44 This input was accumulated and used direct 1y. However. for certain licensing actions. an evaluation by the Frojuct Menager was also factored in. Individual SALP evaluationc w. , sembled toto a matri:'

as shown in Appendi: A. This matri: was t2ed to ccmbination with appropriate weighting for the importance ;f the 'icencing iGsue to develop the overall evaluation of the licensee's performancc.

This approach is consistent with NRC Nni c a l Ch a p t er 0516 which specifies that each functional area ev al ua t M will be assioned a pertormance category based on a composito ,t i .umb er of attrtbutes.

The single final rating is to be tempe ed wt'h i. j;ement a- to the significance of the individual eleent .

2.

SUMMARY

OF RESULTS Dased on the approach described to the Introduction, the performance of Phi 1adelphia Electric Company for its Peach Bottom iaca11ty an rated Category 2 for licensing activities. Thie is a change from the previous evaluated period in which the licensee was rated Category 1.

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3. CRITERIA ,

Evaluation criteria as given in NRC Manual Chapter 0516, Table 1, were used in this evaluation. Weighting was used to temper the evaluation of individual licensing issues depending upon their importance to safety.

4. PERFORMANCE ANALYSIS This evaluation represents the integrated inputs of the Project Manager and those technical reviewers who expended significant amounts of effort and /or prepared a Safety Evaluation for the Peach Bottom facility. The composite rating also reflects the comments of the NRR t Senior Executive assigned to the Peach Bottom SALP assessment. A written evaluation was circulated to NRR management for comments, which were considered in the final draft.

The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period. These actions ,

included license amendment requests, exemption and relief requests, responses to Generic Letters, TMI and Salem (AIWAS) items, and other actions. Fifty-six (56) licensing actions were completed. Active actions during this period are classified in Attachx.ent A.

In addition to those specific issues, the licensee was evaluated for the overall performance in many day-to-day issues which arise, d

S. ASSESSMENT OF PERFORMANCE ATTRIBUTES This evaluation of the licensee's performance was based on the consideration of the seven at tr ibu tes specified in NRR Manual Chapter  !

0526. These are:

-Management involvement and Control in Assuring Quality (

-Approach to Resolution of Technical Issues from a Safety Standpoint *

-Pesponsiveness to NRC Initiatives ,

-Enforcement History

-Reporting and Analysts af Reportable Events

-Staffing (including Management)

-Training and Qualification Ef fec t t venew In addittun, this evaluation includes an assessment of the licensee's housekeeping practices. ,

p 5.1 Management involvement and Control in Assuring Quality During this rating period, the licensee's headquarter management has demonstrated an active role in licensing-related activities.

Strong management involvement has been especially evident where issues f have potential for substantial safety impact and extended shutdowns.

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1 This was especially evident in the Unit 3 refueling and pipe i inspection program and reracking of Unit 2 and Unit 3 spent fuel 1 pools. These efforts have represented substantial efforts for both the licensee and NRC's staff and management during this ten month assessment period. Management screening of submittals in these areas was apparent since the submittals were c o ns i s ?.e n t l y clear and of high quality. -Doth of these efforts show evidence of prior planning, excellent assignment of priot ities and stated, defined procedures for control activities.

However, there are two areas indicating the lack of management attention: timely resolution of NRC initiativos and sporadic quality of Sholly evaluations. Although good effort has been made to initially respond to NRC initiatives in a timely fashion, there appears to be a discernible trend during this report period toward '

significant delays in followup responses. Three oxamples are Appendix

! J Technical Specifications (TSs), purge / vent valves TSS,and diesel i generator fuel oil TSs. Concerntng Sholly evaluations, there has been a noticeable improvement since the last evaluation period, but overall quality is still highly variable. Additional management attention is required to improve the overall quality in the Peach Gottom Sholly j process.

In summary, there was evidence of prior planning and assignment of

• priorities in major licensing actions, reviews were thorough and l- technically sound. There was evidence of frequent interfacing between appropriate licensee headquarter staff and the site. The licensee has shown evidence that records are generally complete, well maintained and available. However, there continues to be long delays in the submittals of several long-standing NRC initiatives. Finally, the

quality of Sholly evaluations still requires i mp r o ve nien t s .

Based on the above co ns Ider a t io ns , the over )1 rating for this attribute is Category 2.

i 5.2 Approach to Resolution of Technical Insues From a Safety Standpoint a

The licensee's submittals gener a l l y showed an understanding of issues, a conservatism in the;r technical presentatiors. and viable and generally sound approaches. Resolutions of issues affecting continued operation of the plant or restart were generally timely.

However, there are other areas where the resolution of cututanding issues has not been timely. NRC initiated issues of long-standing nature include Appendix 3 TSs and purge / vent valves TSs. Although

{ the technical approach to resolution of most issues has generally been good, the lack of timelv resolutions of certain issues has resulted in i the continued backlog of long-standing open items. Based upon the 4 above, the rating for this attribute is Category 2.

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5.3 Responsiveness to NRC Initiatives The licensee generally responded to NRC initiatives in a timely fashion. As reflected in the individual SALP ratings for the multi plant actions, the licensee has few outstanding regulatory issues and resolution has been initially acceptable in most cases.

This is especially true in regards to the licensee's effort concerning the resolution of IGSCC cracking. However, this assessment must be tempered by the fact that there are still long-standing items which require the licensee's responses before they can be closed out (e.g.,

Appendix J TSs, purge / vent valves TSs). Also there has been a general trend in delayed follow-ups on certain actions which further contributed to the backlog of actions associated with Peach Dottom.

In summary, when considered against the evaluat ion cr i ter ia for this attribute in NRC Manual Chapter 0516, the licensee's initial responses have been generally timely; however, several long-standing actions and issues are still unresolved due to lack of 4itensee's input.

Based on the above considerations, the rating for this attribute is Category 2.

5.4 Enforcement History The NRR Project Manager participated in two Enforcement Meetings held at Region 1. Based upon these events plus the Project Manager's review of the Peach Bottom inspection Reports for the review period, major violations at Peach Botton are rare and evidence at the Enforcement Meetings appear to indicate that violations result from minor programmatic breakdowns. Corrective actions are usually timely and effective in most cases. However, when actions required licensee's follow-up with NRR (e.g., a TS change), delays in such follow-ups have been evidenced.

Based upon the above, the rating for this attribute is Category 2.

5.5 Reporting and Analysis of Reportable Events (This input is being developed by the ORAS staff in NRR. Their analysis is currently Deing prepared and will be se r. t to the Region under separate cover but in sufficient time to be used by the SALP Board members at the March meeting.)

5.6 Staffing (Including Management)

During this rating period, an effort was made to increase the effectiveness of the Philadelphia Electric licensing staff to accommodate both the Peach Bottom fscility and Limerick Generating station which was recently licensed to operate. These changes have resulted in the continued high techntcal quality of most Peach Bottom submittals. However, the problems of delays and backlogs as discussed above appear to indicate that there may be problems in the staffing area.

Key management positions have been identified with defined authorities and responsibilities, but staffing, although technically competent, appears not to be adequate at times due to difficulties with backlogs.

Based on the above considerations, the rating for this attribute is l Category 2. ,

5.0 Training and Qualification Effectiveness ,

We have no basis for evaluating this attribute during this report period.

5.9 Housekeeping Observations made while visiting the site on various occasions during this rating period indicate that the licensee's housekeeping practices are adequate. Areas within the plant facility as well as the outside grounds were generally clean and free of combustibles.

Plant personnel appeared to conduct themselves in a professional manner.

Based on the above considerations, the rating for this attribute is Category 2.

6.0 Co nc. l u s i o n An overall performance rating of Category 2 has been anstgned in the licensing area. ,

Sec t ion 042 o f the Manual Chapter 0516 defines the meaning of rating the licensee's performance Category 2 as follows: "NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved."

We believe that no less management ef for t on the par t of the l 2

licensee should be exerted in licensing activities. We suggest that more management involvement may be needed to improve response time while maintaining quality. We also conclude that no less NRC attention in the licensing category would be a propriate.

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FEACH PCITDM AT0!C F0WEP STAT 10N-5 ALP REF0PI SALP CATE60RIESe TYFE TC TITLE OF ACTIC1 5E C09t1 CAT.! CAT 2 CAT 3 CA1.4 CAT.5 U!.6 NL*.iEF CATE 12tt-;! ant s:tient F 42522 3 FA50 % WALL :E3!Eh. IE!-20-11 65/66 lit n 53017.9 ITEM 3.1.'i- FCST MAIN. TEST. CF3. TO IS 85/h /29C 1 1 I ft 53417.9 ITES !.2-F031 TP:P FEVIEW-:A1A51NF0 CAF.E5!06702C 3 2 R 5:316,7 ITEP 3.2.3-F;5i ?AI'ii. TEET.-CMS TO T3 55! W 25: 1 1 i ft 55606 INS. OF EWR FIFik$ ACC. TO EL.94-!!(PE2155/0i!06C R 5560' !hs. OF PWR FIFIN3 ACC. 10 EL.Ee titFP3t25/(*!3(C ft *'337.5 DIEEEL EENEFATEF 15, 95!09/Q60  !  ! 1 ft 56552.5 FEC0!!1ER CAFailLITY 55/0er !*C I fl 5657i P: FINS INSF. FR05. FOR E5 EEFUELIN3(FB3)S5!09:YC 1 1 1 f! 57162.3 MU F ! DF Weit VA:.EFEAK.(3L E3-(9) 25/06!(3C  !

r. 5 M O.! h5T!FICAi!0N F0F INTERIM SFES At! REV.CE5/12/23C 2 E 2

!! 6CEE7.5 FOLLCW-L'P CN ITE5 :.2tEL.93-291 E5't!'230 Flant t;e:tfit a:ttens P 543i7.E T5 CHAhEE TO IELETE EFILELL A!R ttCNl TOP B5/06/16C 2 1 P 54900.1 FEV. OF FR0?05ED T5 CN AIR SUCFLY 9'/07/14C P 55157.5 IS CWiEE IN'/CL'.'!NS MAN:EEPENT FECFS. 95!07/0!C 2 2 P 5'174 3ET FUNF INTFUMENT NCLE CPAtkS (UNIT E95/06/06C P 554 a 1 FEVIEW C~ SECOMI TEN 4 EAR 151/151 FF06. 65!10/1:C P $5576 CFACtS IN P!5ER SAFE EN:3 (UNIT 21 85!06/0sC P 5:57- CFACLE IN RISE 2 SAFE END5(UNIT 31 96/01/31 1 1 I P 56'd .1 AI:-lTWAL 151 FELIEF REC' JEST (IST 10 YP)S!!05/16C 1  !

P *shE.3 FE gicF WATEF LEVEL INiif. LCO T5 85/06/12C 2 2 P 56 % ?.50 TS C m iES REL. TO RETS (EEVISION !!  !'!0?i100 2 1  :

P 57217 AMEGA TD C)CLE 7 FELCA2 Ntli 31 S H 7/030 2 2 P 575it.7 EP.EMESC* S'EF AFEME55-SCHEDAAR CMMGE 6:/0710:C

• 5'597,9 N0*>:Cai!Cti CF 0FC!;3I6/16'351-FEV.2 65.'02 'C 5C P 5012 SF,31 FLEL FCOL E s t!!0N S$':!/!!  !  ! 2 '.

F 5H51.2 15n1 CHANEIS IN73LVI% P!F453:NG SCEP595'10/3:C 1 1 1 2 2 F Sh 4 5 FU:EE A C VEMI V R V! ST0F'S 95/IC/240 2 P 'h45.7 (CNiFi FECM UFES.RE-AP?.F (CAFFEfi 95fl0!!00 1 1 1

• 5%49.? EHEF9y cP5?F5E(5 85!!0!!9C 2 2 2 P Si?!? E9EFS. T3 DN LSCl PJ'P FLOV 95!!!/13C 2 2 2 I",1 a:tites i Si23.' T3 CHANIES CL V. 5 !!.t.1.16 95/06!ctC  ? 2 2 33f atSt&$t3 89T15 tt20$2tt338 tr;3sas32E ff EAE?FT33SSSSStrf t3333Sg;3333132 834 R23 t1333133333 233223332 3 33 32 28 32 23123233 333333 33338 2828 CTLCLtATED AVE 8, AGES 1.611111 1.45 !.411764 2 EPP ERE e SectrJed values re;resett tagat receiver by the Proje:t Mara;er.

Information to be Added to Section 5 of SALP Report

" Supporting Data and Summary"

1. NAR/ Licensee Meeting / Site Visits Site visits: June 12, 1985. November El. 1985 Meetings: 05/13/85: SALP Board Meeting <

05/30/85: " Energy Absorcers" l 06/14/85: SPDS 09/05/85: Unit 3 Pipe Cracks 09/17/86: Unit 3 Core Sprav Sparger CracL5 10/01/85: Unit 3 Cracks in Safn Ends ,

10/31/85: N-1 Safe Ends 12/19/85: Cracks in Shroud Head Holts and Wear Hinqu r

2. Commission None

3. Scheduler Extensions Granted 08/05/851 submittal of DCRDR Summary Report

4. Relief Granted

• 05/14/85; ISI Relief

5. Exemptions Granted None

6. License Amendments Issued Amendment Nos.109,112 issued June 6, 19G5; appcoves miste1Laneous ,

Ts changes Amendment Nos. 110,113 issued July 17. 19851 approves 50.7a L 50.73  ;

reportkog requirements l Amendment Nos.111,115 issued Oc t ober 2. 1903; approves correction  !

of set potnts and Emerg. Plan Test Freq Amendment No. 114 issued August 23.1903; Unit 3 Reload Amendment Nos.112,116 issued November 19.19653 approves changes to coolant leakage detection systemn ,

Amendment Nos.113,117 issued November 19. 1906; Nureg-0737 Ibs e Amendment Nos.114.118 issued November 22,190S; administrativo >

control TGu Amendment Nos.115.119 issued December 10, 19053 revnsed certain portions of RETS I

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7. Emergency / Exigent Technical Specifications .

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