ML20196E341
| ML20196E341 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/22/1988 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8803010046 | |
| Download: ML20196E341 (2) | |
See also: IR 05000277/1987030
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FEB 2 21ggg
Docket Nos. 50-277
50-278
Philadelphia Electric Company
ATTN: Mr. J.- W. Gallagher
Vice President
Nuclear Services
. 2301 Market Street
Philadelpnia, Pennsylvania 19101
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Gentlemen:
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Sut!-ct:
Combined Inspection Nos. 50-277/87-30 and 50-278/87-30
Yhis refers.to your letter dated January 11, 1988, in response to our letter
dated December 4, 1988.
Thank you for informing us of the corrective and preventive actions documented
in your letter. These actions will be examined during a future inspection of
your licensed program.
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Your cooperation with us is appreciated.
. Sincerely,
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i A [ William V. Johnston, Acting Director
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Division of Reactor Safety
cc:
Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station
John S. Kemper, Senior Vice President, Nuclear
Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
John F. Franz, Plant Manager, Poach Bottom Atomic Power Station
Troy B. Conner, Jr. , Esquire
W. H. Hirst, Director, Joint Generation Projects Department,
Atlantic Electric
Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations
W. M. Alden, Engineer in Charge, Licensing Section
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Doris Poulsen, Secretary of Harford County Council
Public Document Room (POR)
Local Public Document Room (LPOR)
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Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector
Commonwealth of Pennsylvania
0FFICIAL RECORD COPY
RL PB 87-30 - 0001.0.0
02/10/88
8803010046 800222
ADOCK 05000277
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Phi'.adilphia Electric Cm pany
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Region'I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP
Robert J. Bores, DRSS
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Anderson
2/a/88
2/D /88
0FFICIAL RECORD COPY
RL PB 87-30 - 0002.0.0
02/10/88
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PHILADELPHIA ELECTRIC COMPANY
2301 M ARK ET STR EET
P.O. BOX 8699
PHILADELPHI A. PA.19101
(215) 841 5001
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January 11, 1988
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50-278
Mr. William V. Johnston, Acting Director
Division of Reactor Safety
Region I
U.S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
D.C.
20555
SUBJECT:
Peach Bottom Atomic Power Station
Inspection Report No. 50-277/87-30; 50-278/87-30
Dear Mr. Johnston:
Your letter dated December 4,
1987 forwarded the subject
Inspection Report for Peach Bottom Units 2 and 3, and required a
response by January 4,
1988.
On January 7, 1988 W. M. Alden,
Philadelphia Electric Company, discussed with Mr. J. Linville,
NRC-Region I,
the need for an additional week to provide a
complete response.
Appendix A of your letter identified an activity which
did not appear to comply with the Commission's regulations.
This
apparent violation is restated below, followed by Philadelphia
Electric Company's response.
RESTATEMENT OF APPARENT VIOLATION:
10 CFR 50 Appendix R Section III.I.3.b. requires that fire
brigade drills shall be performed at regular intervals with each
fire brigade member participating in at least two drills per
year.
Section III.I.l.a. requires that initial and periodic refresher
training be provided to all fire brigade members.
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Mr. William V. Johnston.
January 11, 1988
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Contrary to the above, on October 20, 1987, it was determined
that at least 20 fire brigade members did not participate in the
required two drills per year and five members did not attend
either the initial or refresher training required for brigade
membership.
Also on October 20, 1987, it was determined that a
similar type of brigade training deficiency was identified in
1983 by NRC as a violation and was allowed to recur in 1984, in
1985 and in 1986 as evidenced by the QA audits of the fire
brigade training for those years.
This is a Severity Level IV violation (Supplement I).
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RESPONSE:
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Admission or Denial of Apparent Violation:
Philadelphia Electric Company acknowledges that it did not comply
with NRC requirements as stated in the Notice of Violation.
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Reason for Violation:
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This violation occurred because the responsibilities and
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procedures for tracking fire brigade members' qualifications,
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bringing deficiencies to the attention of station management and
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assuring their correction had not been established.
As noted in
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your letter, steps taken in the past to prevent recurrence of
similar violations were not effective.
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Extent or Significance of Violation:
Each operating shift must contain a fire brigade consisting of
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five qualified members, including a brigade leader.
At Peach
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Bottom a senior licensed operator on each operating shift serves
as brigade leader for his shift.
To be qualified as a brigade
member, individuals must have completed initial training and must
periodically complete refresher training.
One element of these
training programs is referred to at Peach Bottom as site-specific
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training, and is conducted on-site.
The other element is a
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general fire fighting course conducted at the Philadelphia
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Electric Company Fire School.
Brigade members also must
periodically participate in drills, practice sessions and fire
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protection meetings.
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14r . William V. Johnston
January 11, 3988
Page 3
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At least one of the fire brigade members on each operating shift
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was not fully qualified at the time of the inspection.
One
individual who had been a fire brigade leader for approximately 1
1/2 years has not attended initial training.
Two other
individuals who had been fire brigade leaders for approximately
nine months have completed the initial Fire School training, but
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have not completed the initial site-specific training.
Two fire
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brigade leaders and two other brigade members were overdue
(approximately one month) for site-specific refresher training;
however, each of these individuals had completed the Fire School
refresher training in accordance with the required schedule.
One
individual (auxiliary operator) who had been a brigade member for
apptcximately one year has corupleted the Fire School initial
training, but has not completed the site-specific initial
training.
As stated in the i.otice of Violation, several members
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are also overdue for drill participation.
The current extent of
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overdue drill status has not yet bee r: fully determined.
It is
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clear that having fire brigade members who hadn't completed
initial training and failure to keep brigade members up-to-date
on training and drill participation might have degraded fire
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fighting capability.
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Corrective Actions Taken an6 Results Achieved:
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Immediate corrective actions have been taken to ensure that the
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fire brigade consists of fully trained members.
The personnel
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who currently do not sarlsfy the Appendix R training requirements
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have been deemed ineligible for fire brigade membership, and will
remain so until the required training has been completed.
The
personnel deficient in initial and refresher Fire School training
have been scheduled to complete this training by April 30, 1988.
The individuals deficient in site-specific training have been
scheduled to complete thir. training by February 19, 1988.
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To compensate for the deficient training status of the normal
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fire brigade leaders on each shift
the following policy has
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been implemented.
Each Shift Manager, in the event of a fire,
shall tske one of the following actions:
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a)
Tha Shift Manager shall serve as brigade leader, if
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qualified, leaving the normal brigade leader (holding a
senior operatot license) in charge of the Control Room
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b)
The Shift Manager shall dispatch five qualified brigade
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members, one of whom shall be a senior plant operator
(non-licensed) that will act as the fire brigade leader.
Also, the normal fire Ltigade leador, who may be
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deficient in fire brigade t' raining but holds a senior
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Mr. William V. Johnston
January 11, 1988
Page 4
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operator license, will accompany them to provide
additional technical assistance; or
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c)
The Shift Manager shall dispatch five qualified brigade
members, one of whom shall be a senior plant operator
(non-licenscd) that will act as the fire brigade leader.
Also, the Shift Technical Advisor will accompany them to
provide additiona? technical assistance.
This policy shall remain in effect until all the normal fire
brigade leaders complete the required training.
As an interim
measure, individuals will be considered qualified as fire brigade
members if they have completed the initial training and refresher
training as required, regardless of their drill participation
status.
A review is in progress to determine the current status
of each fire brigade member with respect to drill participation.
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The personnel deficient in fire d..ll participation will
participate in the required number of drills by April 30, 1988.
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Corrective Actions to be Taken to Prevent Recurrence:
Responsioilities have been established to ensure that fire
brigade merciers ' training records are actively monitored.
The
station Training Section will increase its review of fire brigade
training records from annually to quarterly, and will have
overall responsibility for tracking fire brigade training and
drill attendance.
Merbers' training status and any requirements
which must be fulfilled in the next quarter will be reported
quarterly by the Training Section to the Operations Supporc
Engineer and Fire Protection Coordinator.
The station Training
Section will notify the Operations Support Engineer of pending
deficiencies so that they can be avoided.
If deficiencies arise,
the Operations Support Engineer will ensure that the individuals
who are deficient in fire brigade trainir.; are not used to
satisfy fire brigade staffing requirements until they are fully
qualified.
In the future, a person will not be considered
qu.clified to become a member of the fire brigade until
successfully completing the initial training.
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The restructuring of the Peach Bottom staff (as described in
License Amendment Application submitted to NRC on November 19,
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1987) will enable station management to be more involved in daily
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activities and more accessible to ensure timely impicmentation of
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corrective actions to prevent non-compliance.
This is being
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accomplished by further separating responsibilities and
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establishing additional management positions horizontally within
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the organization.
The organization under the Operations Support
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Engineer is a new facet of the restructured Peach Bottom staff.
This group was created to focus on administrative
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P.r. '.u;11am V. Johnston
January 11, _198E
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fire brigade training. -TDe creation of the Training
Superintendent position reporting directly to the station Vice
President wil! enhance the attention given to training
requirements for plant personnel.
These organizational
improvemer,ts will assure that priority attention is given to fire
t.rigade training.
If you have any questions or require additional
information, please do not hesitate to contact us.
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Very truly yours,
.5ddressee '?
cc:
W. T. Russell, Adm.inistrator, Regien I, USNRO
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T. ?. Johns:r., NRO Resident Inspector
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