ML20204C686
| ML20204C686 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Peach Bottom, Salem, Nine Mile Point, Indian Point, Pilgrim, FitzPatrick, 05000471, 05000472  |
| Issue date: | 11/09/1978 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 7811290288 | |
| Download: ML20204C686 (9) | |
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. KmG OF PRUSSI A, PENNSYLV AM A 1H06 November 9,1978 MEMORANDUM FOR:
Norman C. Moseley, Director Division of Reactor Operation Inspection, IE FROM:
Boyce H. Grier,- Director, R1
SUBJECT:
LICENSEE REGULATORY PERFORMANCE EVALUATION The cdditionci infermetion on this subject requested by your memorendum d=ted 1
November 6,1978, is enclosed.
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.eg vQ Boyce H. Grier Enclesure:
Director As stated 1
cc w/ Encl:.
J.. G. Davis E. L. Jordan I
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4 ENCLOSURE i
1.
please sucolement your Fitzpatrick resconse to address the present 1
regional position regardina deficiencies with emergency diesels and the radwaste system.
If s1gn171 cant deT1clencies ex1st, what olans are there for uograding?
- The emergency diesels experienced a number of difficulties, primarily during the period prior 'to operating license issue in July 1975.
Eight significant diesel related licensee events were reported in the year prior to operating licensee issue.
Two such events have been reported in the more than three years since issue of the-operating license.- We consider that the licensee actions to correct the diesel problems have been proper and effective.
The licensee's radwaste processing capacity and systems' controls have' not presented serious noncompliance problems.
We therefore conclude that from the regulatory viewpoint, no significant radwaste system problems exist.
2.
Indian point a.
please sucolement your Indian Point resoonse to address the comment, " trend toward more insoections with less comoetent inspectors is dangerous."
We believe that the statement " trend toward more inspections with less competent inspectors is dangerous" is a reflection of the " project vs specialist" issue.
We as ume the comment was made by a " specialist" inspector who was becoming concerned when a " project" inspector was encroaching into his area.
l b.
Is.Recion I makina more insoections, usino less comoetent 1
insoectors? Are the insoections which are being done sufficient in technical deotn?
i At the time of the Hay Survey and for some time prior, the qualification and experience level of RI inspection personnel was at a peak, i.e., very experienced inspectors were available in the region.
There'was no large influx of new inspectors.
The depth of our inspections at these plants was and still is consistent with our inspections at other facilities.
At present, our RO&NS Branch inspector experience level is minimal but the inspector competency level is consistent with past experience and regional requirements.
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2 c.
How is the region assurino insoection adecuacy durina a time when many new inspectors are beino trained?
Our new inspectors are inspecting only under the guidance of an experienced inspector, with the experienced inspector reviewing all findings.
We are limiting a new inspector to inspection of a small group of related inspection modules.
Our experienced inspectors and Branch supervision will certify that a new inspector is competent to independently inspect specific modules only after sufficient experience has been attained and competent performance has been demonstrated.
Independent inspection is not permitted until competence has been certified.
d.
Your memorandum of December 13, 1977 forecast imorovements in licerisee management controls and effectiveness by the end of 1978.
Have these imorovements actually occurred?
Are additional imorovements in licensee performance in these areas warranted?
If so, wnat olans do you nave for further NRC actions?
The forecasted improvements in licensee management stated in our December 13, 1977 memo are being realized at both Unit 2 and Unit 3.
As time progresses, we are seeing also a better working relationship between the two licensees at this site, probably due to the establishment of a technical liaison in each licensee's plant staff to monitor developments in the other licensee's plant.
As to whether additional improvement.s are warranted in specific areas, we feel that improvements are always possible in one area or another, but at this time, we cannot identify any specific area in which a condition exists which requires more than routine attention.
We recently assigned a resident reactor inspector to this site (October 1978).
The resident inspector monitors the performance of both licenses.
His inspections will be supplemented by those of Regional office inspectors.
If indications of de-terierating performance appear, appropriate action will be taken.
3 3.
Please suoplement your Millstone resconse by addressing the cresent regional cosition regarding the reliability of the cas turbine and
._the adecuacy of the sizing of the radwaste systems.
If deficiencies exist, what plans are there for uograding?
The Millstone Unit I Emergency Gas Turbine is redundant to the Emergency Diesel Generator.
Responsibility for monitoring the gas turbine performance and reliability is assigned to a plant engineer.
Past problems experienced with the governor assembly have been corrected with the installation of a preamplifier between the speed pick up and the governor.
Additional problems experienced with an electronic speed switch unit resulted in control room alarms, when the problem occurred with the unit in standby.
These failures were found to be temperature related and measures were taken to provide additional cooling to the speed switch while a suitable replacement is being selected.
Technical Specifications address actions required in the event of an inoperable gas turbine.
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Radwaste systems at Millstone have been upgraded, in the areas of solid and liquid radwaste and with the installation of an augmented offgas system.
Existing Unit I liquid radwaste capacity has been doubled, an additional concentrator has been added and the solidifi-cation process has been improved.
The licensee also plans an additional building for truck loading of solid radwaste.
Vendor services are used routinely to. facilitate utility needs.
System capacity is considered adequate for present needs.
4 The detailed insoector comments on the Hay Survey attributed con-siderable credit in the case of Fitzpatrick for the manacement chance to PASNY.
In view of this, clease address frem a regional management viewooint the Dresent Niagara Mohawk corocrate manacement controls and station management at Nine Mile Point.
The subjective " consensus" opinion rated the Fitzpatrick facility higher than Nine Mile Point, but it also indicated that Nine Mile Point was above the minimum acceptable value in all categories ra ted.
It;,is interesting to note that the narrative statements on
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Nine Mile Point indicate that the facility has experienced BWR operators, a' stable staff, a conservative approach to operations, and that the plant was operated by former fossil plant people who have not yet become nuclear people.
The contradiction presented by the last of that series of statements is indicative of an impression
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.ubstantially -before the rating period, and it is possible that the nine Mile Point ratings were biased in the low direction by such impressions.
In any event, we believe that Nine Mile Point operates safely, and in substantial and acceptable conformance with federal safety requirements.
5.
'Regarding Peach Bottom - have the changes discussed in your December 13, 1977 memorandum resulted in sionificant imorovement?
Please discuss.
Is this plant the least safe plant in Region I?
Does it have the coorest management?
Please discuss.
There have been improvements at Peach Bottom.
We do not categorize that site as being "the least safe in Region I" or as "having the poorest management."
Licensee management has been responsive to our concerns and has taken action on them.
Our December 13, 1977 memorandum is updated below to reflect current conditions.
(1)
From the data evaluated, the Peach Bottom facilities accear to exhibit performance wnich deviates from the norm.
Provide your analysis as to why the performance of Peach Bottom acoears to stand apart from the other facilities.
The two 1100 MWe BWR facilities are a major step up in size from the small High Temperature Gas Cooled reactor which was
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the company's only previous nuclear power plant.
In the past, frequent personnel errors had occurred at Peach Bottom with little indication of action being taken by the licensee.
The licensee seemed disinclined to take disciplinary action against employees.
There were inspection concerns regarding employee attitude and performance.
It is our present evaluation that the. facility operators are competent and professional, and there does appear to be an improvement in employee attitudes.
The licensee still appears disinclined to take disciplinary action against employees but has taken other measures which we feel have impacted upon this area including an increase in the operating staff and rescheduling of staff
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training..Previously, training periods had been scheduled consecutive to the normal work shift.
They are now scheduled t
at a separate time..The staff increases and separate training periods do decrease the potential for development of an overworked staff condition.
Effectiveness of licensee actions in this area will be more fully evaluated during the next refueling outages.
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5 An upgraded facility QA program was approved by the NRC in November 1977.
An implementation inspection several months later found that all implementing procedures had not been developed and placed into use, but that progress was acceptable.
There have been inspection concerns expressed about the QA program at this facility, with non-uniformity relative to other facilities and less than full commitment to ANSI standards being specific areas of concern.
Those concerns were addressed to the NRC:NRR office which conducted the QA program. review, and the existing QA plan was subsequently accepted by the NRC.
- No correlation of inspector QA concerns to safety defects has been established.
l It is our current evaluation that managemen' review of facility events has been considerably improved at Peach Bottom.
Both the.on-site and off-site review groups appear to be performing
.l careful and proper analyses.
We are not now having problems with inadequacies in this area.
The licensee has actively pursued the correction of design probl er; such as a pump start on one unit initiating an ECCS actuation signal on the other units (circuitry modifications i
appear to have corrected that problem).
We feel that present
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facility actions in this area are timely and proper.
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There was concern about this licensee's responsiveness to NRC input.
Our concern was discussed with licensee corporate management in 1977.
Substantial improvement has occurred.
Site management and corporate management have actively pursued resolution of concerns about electrical equipment qualification.
The previously mentioned action on staffing, work hours, and review of facility events are also positive indicators of licensee responsiveness.
This does not mean that areas cf concern do not still exist.
We are now concerned, for example, because it does not appear that this licensee will upgrade his 4
security requirements to meet 10 CFR 73.55 in the specified time frame.
This concern has been discussed with the licensee and NRR.
In the area of facility maintenance, the establishment of the Assistant Maintenance Engineer position has been followed by improved equipment' reliability and operation.
Three of the 1
6 ten additional positions authorized in the Instrumentation and Controls area have been filled.
Facility cleanliness is receiving increased attention and is improving.
We feel that the improvements in this area are modest, but preliminary, and that the licensee is taking steps which will improve long term reliability and safety of operations.
Licensee health physics has also been an area of concern.
Overexposures have not been a problem, but deficient practices were. identified in procedure adherence, personnel monitoring, radiation area door locking, radiation area posting, communica-tion and radiation surveys.
The frequency of occurrence of problems with health physics practices has decreased substantially, and we no longer consider this to be on area requiring above normal licensee or IE attention.
(2)
Do you believe that the Peach Bottom facilities have an abnormal oerformance record?
We believe that there have been significant regulatory problems at peach Bottom, and.that those problems have been handled effecti vely.
This is true of many facilities.
We do not consider the recent preformance of this facility to be " abnormal".
(3)
Do you believe the indicated performance of the peach Bottom facilities demonstrates the Peach Bottem facilities are less safe than the other facilities?
Please exclain vour answer.
It.is our belief that the factors evaluated as defects in management review of events, operator actions, quality assurance, radiation protection, staffing, and attitude resulted in safety assurance which was less than that which could, and should, have been achieved at' Peach Bottom.
However, we do not have' definitive data showing that Peach Bottom has been less safe than other facilities.
We also feel that the licensee actions taken over the past 12-15 months have provided greater assurance of safety, and that operational safety at the facility is not significantly different from other Region I BWR's.
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(4)
If you believe the Peach Bottom facilities are " poor oerformers,"
i please describe the corrective measures you have taken or olan
.to take.
We do not consider Peach Bottom to be a " poor performer".
The items identified in the preceding paragraphs were discussed with licensee management, including discussion with the Corporate President in two 1977 management meetings covering our major concerns.
We.are paying particular attention to these areas in our inspection efforts.
So far, we are satisfied with the overall progress and results.
6.
Regarding pilarim - has there been imorovement in the instability 4
_ caused by changes in clant and uocer manacement?
Please discuss.
The stability of the operating organization has improved.
The plant superintendent now has been in that job over two years.
We 1
regard the changes in upper management at BECO to have affected the plant primarily by assignment of the Nuclear Operations Manager.
We believe that assignment has been followed by improved corporate management knowledge, awareness and support of the facility.
plant management changes have been a cause for concern because of the consequent gaps in management continuity.
Additional changes in managers below the superintendent level occurred in 1978.
The plant superintendent'provided continuity during these changes.
In our discussions with the licensee, he has stated that his plant management has been considerably improved by these changes.
Inspection efforts have not indicated otherwise, and the facility seems to be on a slow but positive path toward improved safety and performance.
7.
Regarding Salem - even though control room desian and ooerator controls have not caused any carticular oroolems uo to now, is this considered by regional management to be a cotential safety croblem?
Please discuss.
We do not consider the control room design or the operator controls at this facility to be a potential safety problem.
Although the layout is not identical to that normally supplied by the NSSS, the operators are trained to operate the plant utilizing the Salem control room scheme and are licensed by NRC on the Salem control board.
The operatorfrequalification training program recognizes the design differences between the Salem control room scheme and
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8 that of the NSSS.- Specific requirements are imposed in the NRR accepted program to provide operators with additional training on the Salem control' board for emergency and abnormal procedures when simulator training is carried out on the NSSS control board scheme for requalification purposes.
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