ML20154B975
| ML20154B975 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/25/1986 |
| From: | Gears G Office of Nuclear Reactor Regulation |
| To: | Bernero R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8603040526 | |
| Download: ML20154B975 (10) | |
Text
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9 Docket Nos.: 50-277 50-278 FEB 2 51986 NOTE 70: Robert Bernero, Director Division of BWR Licensing THRU:
Daniel R. Muller, Director BWR Projec+ Directorate #2 Division of BWR Licensing FROM:
Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Licensing
SUBJECT:
NRR INPUT TO PHILADELPHIA ELECTRIC COMPANY-PEACH BOTTOM ATOMIC STATION, UNIL 2 AND 3 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
The Philadelphia Electric Company SALP Board meeting is scheduled for March 24, 1986 at Region 1.
Attached is our SALP. input for this meeting.
If you have any comments, please give me a call at x24993.
Crialcal signalby, Gerald E. Gears, Project Manager--
BWR Project Directorate #2' Division of.BWR Licensing
Attachment:
As stated
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DISTRIBUTION:
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Docket Nos. 50-277 and 50-278 FACILITY: Peach Bottom Atomic Power Station. Units 2 and 3 LICENSEE: Philadelphia Electric Company NRR PROJECT MANAGER: Gerald E.
Gears 1.
INTRODUCTION This report presents the results of an evaluation of the licensee, Philadelphia Electric Company, in the functional area of licensing ac t i vi t i es.
It provides NRR's input to the Peach Bottom SALP review process as described in NRC Manual Chapter 0516.
The review covers the period April 1,
1985 to January 31, 1986.
The approach used in this evaluation was to select a number of licensing actions which involved a significant amount of staff effort or which were related to important safety or regulatory issues for the period from April 1,
1985 to January 31, 1986.
In most cases, the staff applied the evaluation criterion for the performance attributed based on their first hand experience with the licensee or with the licensee's submittals.
Each organization within NRR that 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 directly. _However, for certain licensing actions, an evaluation by the Project Manager was also factored in.
Individual SALP evaluations were assembled into a natri::
as shown in Appendi::
A.
This matrix was used in combination witn appropriate weighting for the importance of the licensing issue to develop the overall evaluation of the licensee's performance.
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This approach is consistent with NRC Manual Chapter 0516 which specifies that each functional area evaluated will be assigned a performance category based on a composite of a number of attributes.
The single final rating is to be tempered with Judgement
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as to the significance of the individual elements.
2.
SUMMARY
OF RESULTS Based on the approach described in the Introduction, the performance of Philadelphia Electric Company for its Peach Bottom facility is rated Category 2 for licensing activities.
This is a change f rom 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 0316, Table 1,
l were used i n this evaluation.
Weighting was used to temper the evaluation of individual licensing. issues depending upon their importance to. safety.
4.. PERFORMANCE ANALYSIS
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This evaluation represents the-integrated inputs of.the Project j
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 Senior-Executive assigned to the Peach Bottom ~SALP assessment.
A 4
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 (ATWAS) items, and other actions.
Fifty-six (56) licensing actions were completed.
Active actions during this period are classified in Attachment A.
i In addition to those specific issues, the licensee was evaluated for the overall performance in many day-to-day issues which arise.
f 5.
ASSESSMENT OF PERFORMANCE ATTRIBUTES This evaluation of the licensee's performance was based on the consideration of the seven attributes specified in NRR Manual, Chapter 0526..
These are:
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-Management Involvement and Control in Assuring Quality 1
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-Approach to Resolution of Technical Issues from a Safety Standpoint
-Responsiveness to NRC Initiatives 1
-Enforcement History
-Reporting and Analysis of Reportable Events
-Staffing (including Management)
-Training and Qualification Effectiveness In addition, this evaluation includes an assessment of the licensee's housekeeping practices.
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5.1 Management Involvement and Control in Assuring Quality 4
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 i ssues j
have potential for substantial safety impact and extended shutdowns.
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This was especially evident in the Unit 3 refueling and pipe inspection program and reracking of Unit 2 and Unit 3 spent fuel 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 consistently clear and of high quality.
Both of these efforts show evidence of prior planning, excellent assignment of priorities and stated, defined procedures for control activities.
However, there are twc areas indicating the lack of management attention: timely resolution of NRC initiatives 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 repor t period toward significant delays in followup responses.
Three examples are Appendix J Technical Specifications (TSs), purge / vent valves TSs,and diesel generator fuel oil TSs.
Concerning 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 Bottom Sholly process.
In summary, there was evidence of prior planning and assignment of priorities in major licensing actions, reviews were thorough and 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 improvements.
Based on the above considerations, the overall rating for this attribute is Category 2.
i 5.2 Approach to Resolution of Technical Issues From a Safety Standpoint The licensee's submittals generally showed an understanding of issues, a conservatism in their technical presentations, and viable and generally so,und approaches.
Resolutions of issues affecting continued operation of the plant or restart were generally timely.
However, there are other areas where the resolution of outstanding issues has not been timely.
NRC initiated issues of long-standing nature include Appendix J TSs and purge / vent valves TSs.
Although the technical approach to resolution of most issues has generally been good, the lack of timely resolutions of certain issues has resulted in the continued backlog of long-standing open items.
Based upon the above, the rating for this attribute is Category 2.
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 j
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 3 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 Bottom.
In summary, when considered against the evaluation criteria 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 licensee's input.
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l 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 I
review of the Peach Bottom Inspection Reports for the review period, major violations at Peach Bottom are rare and evidence at the Enforcement Meetings appear to indicate that violations result from minor programmatic breakdowns.
Corrective actions are usually timely I
and effective in most cases.
However, when actions required licensee's follow-up with NRR (e.g.,
a TS change), delays in such l
fnllow-ag= have been evidenced.
Based upon the above, the rating for this attribute is Category 2.
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5.5 Reporting and Analysis of Reportable Events (This input is being developed by the ORAS staff in NRR. Their analysis is currently being prepared and will be sent to the Region under separate cover but in sufficient time to be used by the SALP Board members at the March meeting.)
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i 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-facility and Limerick Generating station which was recently licensed to' operate. These changes have i
resulted in the continued high technical quality of most Peach Bottom i
submittals.
However, the problems of delays and backlogs as discussed above appear to indicate that there may be problems in the staffing area.
l 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 Category 2.
i 5.8 Training and Qualification Effectiveness i
We have no basis for evaluating this attribute during this report period.
i 5.9 Housekeeping 4
1 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.
P,lant pert anel appeared to conduct themselves in a professional-m'a nne r.
Based on the above considerations, the rating for this attribute is
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Category 2.
6.0 Conclusion 4
An overall performance rating of Category 2 has been assigned in the licensing-area.
1 Section 042 of 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
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attention and involvement are evident and are concerned with nuclear-safety; licensee resources are adequate and reasoncaly effective such j
that satisfactory performance with respect to operational safety or construction is being achieved."
We believe that no less management effort on the part of the 2
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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 appropriate.
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FEACH BDITDM AT0F.!C POWER STATIDN-SALP REPORT SALP CATEGORIES TYPE TAC TITLE OF ACTICN SE COP?LT CAT.1 CAT.2 CAT.3 CAT.4 CAT.5 CA!.6 M?.iEF LATE Malti-claat artient M
42922.3 r.ASONRY WALL DES!EN. IEP-E0-!!
B5!O6/14C M
53027.9 ITEM 3.1.3-POST MAlii. IESI. CHS. TO TS B5/0il22C 1
1 1
0 53617,9 ITEM 1.2-F03T TRIP REVIEW-DATAi!NF0 CAF.E5!06/02C 3
2 M
53966,7 ITER. 3.2.3-FCSi PAlhi. TEST.-CHS TO TS 65! W 23C 1
1 1
71 55606 INS. CF EWR FIPIKE ACC. TO GL.94-!!(PE2195/06/06C M
55607
!NS. OF BW2 P! FIN 3 ACC. T3 EL.64-!!(FE3195/09/30C F.
55237,9 DIESEL EENEFATOR TS.
95/09/06C 1
1 I
il 56532.9 FECDP.!!NER CAFAEl_ITY B5/06/19C 2
M 5667i PIFIN5 INSF. FR05. FOR E5 REFUELIN3!F53)S5/09/30C 1
1 1
M 57162.3 MAFf I DFii!!LL VAC.5 FEAT.GL 23-05) 05/(6/06C 1
r.
59490.1 JUS!!FICATION F0F INTEFIM SPLS AND REY.CE5/12/23C 2
2 2
M 60227.9 FOLLOW-UP CN ITEM :.2(5L.93-23)
E5'!!!23C Flant see:ific a*tiens P
54317.E TS CPAhEE 10 CELETE DHWELL AIR MCh:IOS 95/05/16C 2
1 P
54900 1 FEV. OF PFC?0SEC TS CN AIR SUFPLY 55!07/14C P
55!57,5 IS ENNEE INVCLVING MANAEEPENT RECF5. 95!07/0!C 2
2 P
55174 JET FU"F INTFU9ENT NOC?LE CFACLS (UNIT E95!06/06C P
55400 1 FEVIEW 0F SECOND TEN ' TEAK ISI/IST FROG. 25/10!!5C P
55576 CM C)S IN PISER SAFE ENOS (UNIT El 85!0e!06C P
555 %
CFACES IN RISEP SAFE ENDS! UNIT 31 95/01/31 1
1 1
P 56940,1 ALOIT!0f!AL ISI RELIEF REC"EST(IST 10 YF)Si!05!!4C i
1 P
56?42,3 FEACIDE WATEF LEVEL INSif. LCD TE 95/06/12C 2
2 P
5694?,50 TS CFAN3ES REL. TO RETS (REVIS10N 11 8!!0?/10C 2
1 1
P 57357 ALLENDA TC CiCLE ' FELO G Uhli 3)
S5!07/03C 2
2 1
P 57556,7 EMEFEE!;Cv PFEFAFEINESS-SCHEDULAR CHAN5E E5/07/Olt P
57E97,9 MCSIC;T!0!.3 CF 0FLEFS(t/14!!5)-REV.2 25!09'(5C i
P 59012 SPENT FCEL PCOL E!EACEID4 95!!!/11 1
1 2
j P
5?291,2 TSf st CHANGES INVOLVI!tS EfFASS!h5 SCRA"595'10/3:C 1
1 1
P 59414,5 PUFEE A O VENT VA'_VE S10FS 85/10/24C 2
2 2
P 59446.7 CCNTR1 ROOM UFERADE-APP.R (CAFFEIi 25/10!!00 1
1 1
P 59449,9 ENEFEY APSOPSERS 95!!0/29C 2
2 2
P 59779 EMERS. TS O!! LFCI PUND FLOW 95!!!/13C 2
2 2
Tri attitts T
54E!!,9 TS CHAN3ES CE RWL 1 II.E.3.16 95!0$!06C 2
2 2
34333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333 CALCULATED AVERAEES 1.611111 1.45 1.411764 2
ERR ERR e Recorded values represert input received by the Proje:t Manager.
Information to be Added to Section 5 of SALP Report
" Supporting Data and Summary" NRR/ Licensee Meeting / Site Visits 1.
Site visits: June 12, 1985, November 21, 1985 Meetings:
05/13/85:
SALP Board Meeting 05/30/85:
" Energy Absorbers".
06/14/85:
SPDS 09/05/85:
Unit 3 Pipe Cracks 09/17/86:
Unit 3 Core Spray Sparger Cracks 10/01/85:
Unit 3 Cracks in Safe Ends 10/31/85:
N-1 Safe Ends 12/19/85:
Cracks in Shroud Head Bolts and Wear Rings 2.
Commission None
- 3. Scheduler Extensions Granted 08/05/85; submittal of DCRDR Summary Report 4.
Relief Granted 05/14/85; ISI Relief l
5.
Exemptions Granted None
- 6. License Amendments Issued Amendment Nos.109,112 issued June 6, 1985; appecves miscellaneous Ts changes Amendment Nos.110,113 issued July 17, 1985; approves 50.72 & 50.73 reporting requirements Amendment Nos.111,115 issued October 2, 1985; approves correction of set poincs and Emerg. Plan Test Freq Amendment No. 114 issued August 23,1985; Unit 3 Reload Amendment Nos.112,116 issued November 19.1985; approves changes in coolant leakage detection systems Amendment Nos.113,117 issued November 19, 1986; Nureg-0737 TSs Amendment Nos.114,118 issued November 22,19858 administrative i
control TSs Amendment Nos.115,119 issued December 10, 1985; revised certain portions of.REIS 7.
Emergenty/ Exigent Technical Specifications None 8.
Orders Issued
None
- 9. NRR/ Licensee Management Conferences None I
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