ML20205A880
| ML20205A880 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/31/1988 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20205A868 | List: |
| References | |
| NUDOCS 8810260122 | |
| Download: ML20205A880 (88) | |
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I SAFETY EVALUATION REPORT ON THE PHILADELPHIA ELECTRIC COMPANY'S PLAN
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FOR RESTART OF THE PEACH BOTTOM ATONIC POWER STATION U.S. Nuclear Regulatory Coas,luion October 1988 8810260122 881031 R
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ABSTRACT On March 31, 1987, the U.S. Nuclear Regulatory Commission issued an order to shut down the Peach Bottom Atomic Power Station, Units 2 and 3, operated by the Philadelphia Electric Company, because the NRC no longer had reasonable assur-ance that the facility would be operated in a manner to ensure that the health and safety of the public would be protected. The associated issues included inattentiveness of control room operators to their licensed duties and the failure of plant and corporate managemer,t to properly identify and correct the problem.
In response to requirements of the shutdown order, the licensee identified the root causes of these problems and proposed corrective actions in the "Plan for Restart of Peach Bottom Atomic Power Station," as revised on April 8, 1988.
The NRC staff's evaluation of this plan and several supporting documents is presented in this safity evaluation report.
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TABLE OF CONTENTS Page 1
INTRODUCTION AND PURPOSE..........................................
1-1 1.1 Approach to the Restart Plan Review..........................
1-2 1.2 Other Related Activities.....................................
1-3 1.3 Public Comments..............................................
1-3 2
BACKGROUND........................................................
2-1 2.1 Performanc. Before the Shutdown..............................
2-1 2.2 Shutdown Order and Subsequent Events.........................
2-1 2.3 Philadelphia Electric Company Organization...................
2-6 2.3.1 Peach Bottom Site Group...............................
2-7 2.3.2 Nuclear Services Group................................
2-7 2.3.3 Nuclear Engineering Group.............................
2-7 2.3.4 Nuclear Quality Assurance.............................
2-8 2.3.5 Nuclear Review Board..................................
2-8 2.3.6 Organization and Management Development...............
2-8 3
C O R PO RAT E MAN AG EM EN T..............................................
3-1 3.1 Organizational Restructuring for Increased Control, Account-ability, and Corporate Direction of Nuclear Operations.......
3-1 3.1.1 Nuclear-Dedicated Organization..
3-1 3.1.2 Corporate Management Team and Accountability of Onsite Employees.....................................
3-2 3.1.3 Management Authorities and Accountability.............
3-2 3.2 Improved Self-Assessment and Problem Resolution Within the Nuclear Organization.........................................
3-3 3.2.1 Philosophy for Assurance of Quality...................
3-3 3.2.2 Nuclear Quality Assurance 3-5 3.2.2.1 General Manager-Nuclear Quality Assurance......
3-5 3.Z 2.2 Shift Inspectors...............................
3-5 3,2,3 Operating Experience Assessment Program...............
3-6 3.2.4 Commi tme nt Trac ki ng Prog ram...........................
3-7 3 2.5 Nuclear Performance Management Program.......
3-7 3.2.6 Restart Readiness Self-Assessment.....................
TABLE OF CONTENTS (continued)
Page 3.3 Company Management Oversight of Nuclear Operations.............
3-8 3.3.1 Nuclear Review Board (NRB)..............................
3-8 3.3.1.1 Membership.....................................
3-8 3.3.1.2 Role and Relationships.........................
3-8 3.3.2 Nuclear Committee of Board of Directors.................
3-8 3.3.2.1 Membership.....................................
3-9 3.3.2.2 Role and Reletionships.........................
3-9 4 STATION MANAGEMENT LEADERSHIP.......................................
4-1 4.1 Establishment of Management Team...............................
4-2 4.1.1 Onsite Management Team...................................
4-2 4.1.2 Operations Organization.................................
4-4 4.1.3 Overall Evaluation of the Management Team...............
4-5 4.2 Supervision and Management Accountability......................
4-6 5 LICENSED OPERATOR RESOURCE DEVELOPMENT..............................
5-1 5.1 Current Resourcer...............................................
5-2 5.2 Fu t u re S t a f f i n g Le v e l s.........................................
5-3 5.3 Offshift Rotation and Alternate Career Paths...................
5-5 5.4 Overall Conclusions............................................
5-6 6 CULTURAL CHANGE.....................................................
6-1 6.1 Identification and Communication of Cultural Ya'ues............
6-1 E.2 Managemant Training and Team Building for Cultural Change......
6-2 6.2.1 Managing for Excellence Evaluation......................
6-2 6.2.2 Shift Team Evaluations..................................
6-3 6.3 Employee Training and Communications for Cultural Change.......
6-5 6.4 Human Resource Practices, Policies, and Proorams of Hanagement.....................................................
6-6 6.4.1 Personnel Evaluations...................................
6-6 6.4.2 D i s c i p l i n a ry P o l i cy.....................................
6-6 6.4.3 Career Paths............................................
6-8 6.4.4 Shift Rotation..........................................
6-9 6.4.5 Control of Overtime.....................................
6-9 7 C C N C LU S I O N..........................................................
9 TABLE OF CONTENTS (continued)
.Pagg APPENDICES A CHRONOLOGY B BIOLIOGRAPHY C PUBLIC COMMENTS AND NRC RESPONSE FIGURES 2.1 Corporate Reporting Structure for the Nuclear Organization.....
2-9 2.2 Nuclear Quality Assurance......................................
2-9 2.3 Site Organization..............................................
2-10 2.4 Nuclear Engineering and Nuclear Services.......................
2-10 2.5 PEco Organization on March 31, 1987, for Peach Bottom..........
2-11 2.6 PEco Organization in September 1988 for Peach Bottom...........
2-11 4.1 Plant Manager Organization Chart...............................
4-11 4.2 Sh!ft Operations Management Organization Chart.................
4-12 TABLE 4.1 Plant Manager's Staf f and Site Kmnagement Positions............
1 INTRODUCTION AND PURPOSC The Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, operated by the Philadelphia Electric Company (PECo, the licensee), is a 1098-megawatt electric boiling-water reactor designed by the General Electric Company and located about 19 miles south of Lancaster in York County, Pennsylvania. Units 2 and 3 were licen ed to operate in 1973 and 1974, respectively.
In March 1987, the Nuclear Regulatory Commission (NRC) received information that control room operaters at Peach Bottom had been observed sleeping while on duty in the control room, reading materials not directly job related, and being otherwise insttentive to licensed duties.
The NRC confirmed this irforn.ation during the initial phase of an investigation and determined that all levels of plant manag6 ment at that time either knew or should have known of these facts and t:0i either no action or inadequate action to correct this situation. As a result, the NRC staff no longer had reesonable assurance that the facility would be operated in a manner to ensure that the health and safety of the publi: would be protected and issued an order to PEco on March 31, 1987, sus-pending operations of the Peach Bottom station.
Subsequently, the NRC determined that the inattentiveness described in the order had occurred over an extended period of time and was pervasive and that the failure by site and corporate management to identify, investigata, and correct these conditions and report them to the NRC demonstrated a significant lack of management attention to, and control of, operations at Peach Bottom.
Tne order issued to the licensee required, among other things, that before the licensee prcposed to again operate either unit above the cold shutdown con-l dition the licensee would provide for NRC approval a detailed ano comprehensive plan to ensure that the facility would be operated safely and would comply with all requirements.
In response to the urder, the licensee eventually identified four principal root causes of the issues that led to the shutdown of the Peach Bottos units and proposed a plan for restart that included discrete tasks to correct these a
root causes of the proulem.
In this safety evaluation report (SER), the staff evaluates the adequacy of the licensee's response to the requirement of the shutdown order, as set forth in the plan for restart, lhe staff has based its findings on several sources of information including that provided in Sections I and II of Revision 1 of the plan for restart, submitted on April 8, 1983, and in responses to NRC requests for additional inforeation, submitted by letters on July 22, August 15 (two),
22, and 23, and September 7 and 20,1988.
The staff gained more information from the numerous enforckment conferences that were conducted with previously and currently licenseo personnel at Peach Bottom station and a number of onsite inspections and audits, which will be documented in respective inspection re-
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1.1 Approach to the Restart Plan Review The NRC's approach to the review of issues associated with the Peach Bottom i
shutdown involves several major programmatic elements.
These elements include enforcement actions, as discussed in Section 2.2 of this SER; the review of PECo's program plan for restart, as addressed throughout this report; the NRC inspection program, as discussed in Section 1.2 below; consideration of com-ments made by the State of Maryland and the Commonwealth of Pennsylvania; and the involvement of the public as discussed in Section 1.3 below.
When a nuclear facility is shut down for safety reasons, the NRC's criteria for consideration of restart require that specific corrective actions be satis-i factorily implemented before the plant can be permitted to restart, in the i
case of Peach Bottom station, the shutdown issues were identified in the NRC's I
shutdown order of March 31, 1987, and in the accompanying notice in the Federal Register (52 FR 11386). These issues are itemized in PECo's restart plan and are listed in Section 2.2 of this report.
The NRC required PECo to identify the root causes of the issues that led to the shutdown as well as the appro-i priate corrective actions to address the root causes.
These corrective actions involved substantial changes in personnel, organizational interactions, and procedural implementation at all levels of the PECo organization.
PECo's plan j
for restart defines the needed changes. Once the NRC has accepted this plan as satisfactory to bring about the needed changes, fulfillment of the requirements t
1 of this plan becomes the essential restart criteria.
The staff's acceptance of f
PEco's plan for restart is conveyed by this report.
This SER gives the results of the staff's evaluation of the licensee's pro-grammatic response to the shutdown order as set forth in the licensee's plan i
for restart. The staff will determine the effectiveness of the implementation 1
of the plan and if it is having the desired effect in correcting the problems that have been identified at Peach Bottom.
This is done primarily through the staff's inspection program, including the monitoring of future performance l
trends.
The licensee's plan for restart identified nine shutdown issues from the shr.-
down order. The licensee then identified four root causes for these issues.
The licensee developed corrective action objectives to be attained to resolve each of the four root causes and also developed specific corrective actions to meet each of the objectives.
The relationship between the shutdown issues, the root causes, the corrective action objectives, and the corrective actions is provided in appendices to the licensee's restart plan. The schedular status of implementation of the corrective actions is provided periodically.
The staff's objectives in reviewing the licensee's restart plan are (1) to establish that j
the licensee's identification of the root causes is appropriate, (2) to estab-d lish whether or.not the scope of the corrective action objectives and tasks is adequate to address the root causes, and (3) to establish whether the comple-tion dates for the corrective actions and major activities are consist 3nt with l
NRC staff requirements for restart, i
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i The NRC established the Restart Assessment Panel to review the licensee's re-start plan. The panel includes members from the NRC's staff in Region I and l
from the Office of Nuclear Reactor Regulation staff.
The format of this re-port" is consistent with the format used by the licensee in its plan for re-t start. Therefore, Sections 3, 4, 5, and 6 of this SER deal respectively with i
the root causes attributed to the corporate organization, as described in J
Section I of the restart plan, and with the root causes attributed to station i
management, operator resources development, and cultural changes, as described i
in Section II of the restart plan.
1.2 Other Related Activities i
In addition to the enforcement actions and the staff's review of the restart i
plan, the staff also has numerous other activities under way with regard to
(
l Peach Bottom station.
l These activities include the preparation of a report on the results of thr.
staff's systematic assessment of Itcensee performance (SALP) for the period of May 31, 1987, to July 31, 1988.
In addition to pursuing the program of.aegular i
inspections, the staff is conducting inspections of licensee activities in several specific areas.
These include inspection of the maintenance p'ogram, the emergency operating procedures, and plant security and safeguards. An 4
integrated performance assessment of the licensee's response to shutdown-
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related issues also will be performed to determine the licensee's overall f
readiness for restart. The results of these inspection efforts will be re-ported in separate inspection reports.
The results of these other related activities 1 5o will be considered in the
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l staff's basis for making a recommendation on s tart of the plant.
1.3 Public Comments i
I The staff was concerned that members of the public had views or concerns on the f
issues to be addressed in any restart decision that had not otherwise been ad-dressed in correspondence to the NRC.
To ensure that all members of the public i
had an opportunity to comment on the licensee's restart plan, the staff held meetings to receive comments from members of the public in the vicinity of the Peach Bottom site.
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Public comments and the staff's response to them as they relate to issues assoc-l iated with the shutdown are discussed in Appendix C to th*,s report, f
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- The :taff has added Appendices A, B, and C, which provide the chronology of cor-f respondence between the NRC and the licensee, the bibliography, and public com-ments +nd NRC response to the comments, respectivel-y.
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t 2 BACKGROUND 2.1 Performance Before the Shutdown Enforcement history before March 1987 identified instances of inattention to duty or failure to adhere to procedures on the part of licensed operators in the control room at Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.
These instances and the resulting shutdown order were published in the Federal Register (52 FR 11386) and are summarized below.
On June 10, 1985, an NRC inspector observed a reactor operator on duty appar-ently asleep or otherwise inattentive to his duties. An enforcement conference was held concerning this matter on June 21, 1985.
On June 6, 1986, the NRC issued its report of the systematic assessment of licensee performance (SALP) for Peach Bottom and concluded that management in-volvement and effectiveness in improving operations activities was not evident.
The report stated that inadequate management involvement was indicated by poor dissemination of management goals and policies, poor communications between l
different departments and divisions, and management's focus on compliance rather than acknowledgement and correction of the root causes of problems.
Further, the report concluded that a complacent attitude toward procedural compliance in plant operations was evident.
r On June 9, 1986, the NRC issued a Notice of Violation and Proposed Civil Pen-alty for several violations that resulted from errors by licensed operators.
These personnel errors indicated a pattern of inattention to detail, failure to adhere to procedural requirements, and a generally complacent attitudt by operations personnel toward performance of their duties.
This NRC assessment I
was emphasized in a letter dated June 12, 1986, from the NRC's Executive Director for Operations to the licensee's Chairman of the Board and Chief Executive Officer.
In addition to this civil penalty, three previous civil penalties had been issued for violations to the Technical Specifications that involved personnel errors.
2.2 Shutdown Order and Subsequent Events On March 24, 1987, the NRC's Region I office received further information that i
operators at Peach Bottom had been observed sleeping while on duty in the con-trol room and were otherwise inattentive to their license obligations. The NRC i
determined that all levels of plant management at that time either knew or should have kr.own of these facts and took either no action or inadequate action tc correct this situation. As a result, the NRC no longer had reasonable assur-I ance that the f acility would be operated in a safe manner and ordered Peach Bottom Unit 3 to be shut down and both units to be maintained in the cold shut-L down condition pending further order.
t The order *.nstructed the licensee to provide for NRC approval a detailed and comprehensive plan and schedule to ensure that the facility would be operated safely before the NRC would consider a proposal for restart.
O The licensee provided its "Commitment to Excellence Action Plan" on August 7, 1987, in response to the NRC order.
This commitment-te excellence (CTE) plan identified four principal root causes of the problems and areas wherein changes were being made to address the concerns as well as a proposed list of tasks and associated schedules to resolve these concerns.
The CTE plan stated the root causes as poor leadership by plant management failure to initiate timely licensed operator replacement trtining programs a station culture, which had its roots in fessil and pre-Thre? Mile Island operations, that had not adapted to changing nuclear requirements slowness on the part of corporate management to recognize the developing e
severity of these problems and take sufficient corrective action Areas identified by the licensee wherein changes were being made included plant management changes licensed operator attitudinal assessment and training additional licensed operator resources site-wide attitudinal change a
procedure upgrade and compliance e
quality assurance program improvemen ts management involvement and communications e
The staff subsequently requested additional information about the CTE plan in letters dated August 24 and September 11, 1987.
The licensee responded to these in its submittal of September 28, 1987.
The staff reviewed the licensee's response of September 28, 1987, and identified several major concerns, whicn it expressed by letter dated October 8, 1987.
The staff concluded that the licensee had not addressed a fundamental concern regard-ing the previous inability of the licensee to self-identify problems, and im-piement timely and effective corrective action.
The staff also concluded that the CTE plan did not contain sufficient information to establish the relation-ship between the specific root causes and the actions proposed to address them.
On the basis of these concerns, the staff deferred further review of the CTE plan pending receipt of a revised plan that addressed the expressed concerns.
In the fall of 1987, the licensee undertook a major reorganization of its site and corporate staff (shown in Figures 2.1 through 2.6 at the end of Section 2).
The revised organizational structure associated with this reorganization was reflected in an application dated November 19, 1987, for amendment to the Tech-nical Specifications with regard to administrative controls.
The revised organt-ntional structure was subsequently approved in amendments to the Technical Specifications as issued on June 22, 1988.
Figure 2.5 shows the structure exist-ing at the time of the shutdown and Figure 2.6 shows the revised structure.
The licensee, in a submittal dated November 25, 1987, stated that it had com-pleted an indepth analysis of (1) its corporate organization and systems for FBAPS Restart SER 2-2
management and support of its nuclear operations and (2) its ability to iden-tify its own problems and to take prompt corrective actions. This submittal included the first of two sections of a revised corrective action plan entitled "Plan for Restart of Peach Bottom Atomic Power Station,"Section I, "Corporate Action" (restart plan). The revised plan reflected the new organization and responded to the concerns expressed in the staff's letter of October 8,1987.
4 Specifically, the root cause with regard to self-assessment was restated as follows:
"Corporate management failed to recognize the developing severity of the problems at PBAPS and thus, did not take sufficient corrective actions."
The revised plan also responded to the staff's concern with regard to establish-ing a connection between the root causes and their corrective action tasks.
Specifically, the licensee listed nine shutdown issues from the shutdown order and correlated these issues with the four root causes, the corrective action objectives to address the root causes, and the corrective actions and major acti-vities required to implement these objectives.
The shutdown issues are listed below with the appropriate designation of the restart plan given in parentheses.
The shut.'ewn issues and the previously discussed correlation are shown in Appen-dices C and A to Sections I and II, respectively, of the restart plan.
Shutdown Issues Operations control room staff periodically slept or have otherwise been inattentive to licensed duties.
(50-1)
Pattern of inattention to detail, failure to adhere to procedural require-ments, and a generally complacent attitude by the operations staff toward performance of their duties.
(50-2) 4 Management at the shift supervisor and shift superintendent level have either known and condoned the facts (50-1) or should have known of these facts.
(50-3)
Plant management above the shift superintendent position either knew or should have known the facts (in 50-1) and either took no action or inade-quate action to correct this situation.
(50-4)
The licensee must have and implement procedures tu ensure that activities affecting quality, including operations of the facility, are satisfactorily accomplished.
The Peach Bottom quality assurance program has failed to identify this condition adverse to safety, (50-5)
The licensee, through its enforcement history and from what has been developed by the ongoing investigation, knew or should have known of the unwillingness or inability of its operations staff to comply with Ccmmis-sion requirements, and has been unable to implement effective corrective action.
(50-6)
Lack of adequate management involvement:
noor dissemination of management goals and policies.
(50-7)
Lack of adequate management involvement:
poor communications bet een different departments and divisions.
(50-8)
Lack of adequate management involvement:
focus on compliance rather than acknowledgement and correction of the root causes of problems.
(50-9)
The first section of the restart plan addresses the corporate-level actions and the related root cause.
The licensee submitted the second section of the restart plan on February 12, 1988; it addresses the other three root causes.
On January 11, 1988, the president of the Institute of Nuclear Power Opera-tions (INPO) provided a report on the Peach Bottom restart issues to the PECo Board of Directors.
INPO requested that the letter and accompanying report be provided to the NRC as well as to others.
By letter dated January 29, 1938, the president of the Philadelphia Electric Company provided the INP0 report to the NRC.
By letter dated March 4,1988, the staff requested that it be provided with any information that the licensee would give to INPO concerning the restart issues.
The staff also requested that the licensee inform the staff of the results of forthcoming INPO evaluations of station and corporate readiness for restart.
Changes in the licensee's senior management personnel took place in March 1988.
The Chairman of the Board / Chief Executive Officer and the President / Chief Oper-ating Officer retired from the company. The Senior Vice President-Nuclear moved over to take charge of the completion-of-construction effort at the licensee's Limerick Generating Station, Unit 2.
These people were replaced by a new Chair-man, President, and Chief Executive Of ficer, Mr. Joseph Paquette, and by a new Executive Vice President-Nuclear, Mr. Corbin McNeill.
In joint response to these changes and to certain recommendations made in the INPO report, the licensee submitted Revision 1 to the plan for restart on April 8, 1933.
The staff issued requests for additional information on the revised restart plan on June 1, 1988.
The licensee responded to these requests, as well as to issues raised by the State of Maryland, by letters dated July 22, August 15 (two let-ters), August 22, and August 23, 1988.
The licensee indicated that it was con-tinuing with its development of responses to issues raised by the Commonwealth of Pennsylvania.
On August 9 and 10, 1988, the NRC issued enforcement actions to individuals that comprised the shift operations staff at Peach Bottom at the time of the shutdown order and to PEco, respectively.
The decision to initiate enforcement action against PECo and its employees was based on the results of a report prepared by the NRC Office of Investigations in December 1967.
This report included the findings of an extensive investiga-tion conducted by the PECo Claims Security Division that was provided to NRC in August 1997. Af ter considering the information from these investigations, a meeting was held with PECo on December 22, 1937, to obtain additional informa-tion to assist the staff in determining whether and, if so, what kind of enforce-ment action was appropriate.
This meeting focused primarily on the basis for PECo's retaining certain of its operators in light of PEco's own investigation and on those corrective actions PECo was taking to address operator inattentiveness.
Thereafter, enforcement ce-" +ences were scheouled with each of the current and forcer licensed operator a member of the Peach Bottom operations staff v*
O shift work complement at the time of the shutdown or shortly before. These conferences were held beginning in February 1988 after the operators had com-pleted their retraining so that the staff could consider the effectiveness of each person's rehabilitation before the NRC made an enforcement decision. The staff gave serious consideration to the full range of enforcement actions for the operators, including revoking their licenses.
In considering the question of enforcement actions against these people, the staff did not need to consider revocation of the licenses for the shift superintendents who were the senior licensed individuals and supervisors on shif t because PECo had already removed them from licensed duties. Consequently, their licenses were terminated by ac-tion of the Commission's regulations.
In addition, one of the operators resigned from the company and two others decided not to continue with licensed duties.
These enforcement conferences were completed in May 1988.
The staff did not believe that the remaining operators should have their li-censes suspended for the following reasons:
(1) These operators had undergone an extensive rehabilitation program designed to ensure that they had a better understanding of their individual responsi-bilities under their NRC licenses and to ensure that such conduct does not recur.
(2) During the enforcement conference, each of the operators was candid and forthcoming in his statements, admitting to some form of inattentiveness to the extent it violated his license and admitting for the most part, notwithstanding opportunities to blame facility management, that he was individually responsible.
(3) Although the operators were individually responsible, the PECo corporate, plant, and shift management certainly bears a large responsibility for the climate which permitted pervasive inattentiveness to exist.
(4) The technical knowledge and texperience of the licensed operators is high, such that r.taining some licensed operators, subject to successful rehabilitation, would be in the interest of reactor safety.
(5) The rehabilitation of selected operators appears to have been successful.
For these reasons, the staff recommended, and the Commission supported, the decision not to revoke the operators' licenses.
Nevertheless, further enforce-ment action in the form of civil penalties was appropriate for all but the newest operators (1) to stress that improper actions and poor attitudes of the operators, with the potential for affecting safe operation of the facility, will not be tolerated and (2) to emphasize their individual responsibility to the NRC.
Civil penalties were included for former operators bqcause (1) the action occurred when they were licensed, (2) the purpose of the penalty is not only to address individual performance but to deter others, and (3) some of the individuals may be involved in nuclear activities in the future.
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i With regard to enforcement action against PECo, the staff considered the following:
(1) The plant was shut down by NRC order, has remained shut down despite var-4 tous submittals of corrective actions, and will remain shut down until the NRC has reasonable assurance that appropriate measures have been taken to prevent recurrence.
(2) The shutdown order and its associated shutdown costs (reported by PECo in its last annual repcrt to be $58 million for 1987) should have sent a clear message to PECo, as well as to all other licensees, that the NRC will not tolerate such consuct and will apply its enforcement authority, 4
when warranted, to ensure that such conduct does not occur.
(3) There have been significant personnel and management changes at several J
1evels within the company.
The civil penalty action was taken to highlight to PEco and other licensees the consequences of the failure of corporate management to be aware of conditions l
such as those at Peach Bottom and the failure to take appropriate corrective action, particularly in light of the pervasiveness of the conditions and PEco's prior enforcement history. These failures constitute a very significant regula-l tory concern and are considered the primary cause of the events that contributed to issuance of the shutdown or.;r.
In the staff's view, available sanctions such as civil penalties should be used so that this licensee, as well as other licensees, will recognize that in addition to the cost of corrective action for i
violations, civil penalties will be added to increase the cost associated with significant safety deterioration so as to increase the deterrent value.
l 2.3 Philadelphia Electric Company Organization i
Since Peach Bottom station was shut down on March 31, 1987, the licensee has been developing and implementing management and technical programs to address the NRC concerns that led to the shutdown. The '?cen.*o responded to these concerns in its restart plan, which is described below.
The licensee has revised its corporate organizational structure to provide an i
organization dedicated only to nuclear power activities (the nuclear organiza-tion) with direct management authority and responsibility over all aspects of l
nuclear operattuns, engineering, maintenance, and construction. The new nuclear organization will be headed by an Executive Vice President-Nuclear with nuclear responsibilities only.
This nuclear organization has been formed by separating nuclear engineering, maintenance, and other support activities for nuclear operations from corresponding support activities for fossil and hydro produc-tion and by reassigning the resources for these activities to the new nuclear organization.
The former positions of Senior Vice President-Nuclear Power, l
Nuclear Production Manager, Superintendent-Nuclear Generation Division, Super-intendent-Nuclear Services, and Manager-Nuclear Plant have been abolished and the functions under these positions have been reassigned within the new organi-zation under the Executive Vice President-Nuclear. A comparison of the former organizational structure with the current structure can be made using Figures 2.5 and 2.6.
Figures 2.1 through 2.4 show the current corporate and site i
organizational structure.
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e There are three staff organizations and five line organizations that report to the Executive Vice President-Nuclear, as shown in Figure 2.1.
The five line organizations have responsibility for the Limerick Generating Station, Unit 2 construction, the corporate Nucitrar Engineering and Nuclear Services groups, and the operating site groups at Peach Bottom and Limerick.
The three licensee staff organizations have responsibility for the corporate Nuclear Review Board (NRB), Nuclear Quality Assurance (NQA), and Organization and Management Development.
2.3.1 Peach Bottom Site Grcup The licensee has established a corporate office of Vice President-Peach Bottom Atomic Power Station (VP-PBAPS) at the site.
This office has overall control of the conduct of activities of organizations at the Peach Bottom site.
There are four line organizations that result from the reassignment of previous func-tions as well as the addition of new functions. These are plant, support, projects, and training as shown in Figure 2.3.
The PBAPS site organization is discussed further in Section 4 of this SER.
2.3.2 Nuclear Services Group The Vice President-Nuclear Services is responsible for nuclear service activi-ties that support both the Peach Bottom and Limerick stations.
The Vice President-Nuclear Services, as shown in Figure 2.4, is responsible for the support, maintenance, training, and administration groups.
The Manager-Nuclear Support is responsible for licensing, fuel management, radiation protection, radioactive waste nianagement, nuclear plant chemistry, emergency preparedness, nuclear plant security, and the Operating Experience Assessment Program.
The Manager-Nuclear Maintenance is responsible for the supplemental craft maintenance support that serves the mainter.ance organization at the nuclear fact 11 ties.
These activities include mobile mechanical maintenance, mobile electrical maintenance, and cer,tralized maintenance services.
The Manager-Nuclear Training is responsible for two branches:
the Nuclear Training Section, which is responsible for licensed, accredited, and general employee training, and the Barbados Training Center, which is responsible for craft training for maintenance and construction workers.
The Manager-Nuclear Administration is responsible for coordinating and monitor-ing activities that support the nuclear organization, including personnel administration, budget and cost control, computer applications, and nuclear records management.
2.3.3 Nuclear Engineering Group The Vice President-Nuclear Engineering is responsible for the management of engineering activities that support the Peach Bottom and Limerick stations.
Reporting to the Vice President-Nuclear Engineering through the Manager-Nuclear Engineering, as shown in Figure 2.4, are the Meager-Engineering, Manager-Project Management, Manager-Engineering De i s, and the Ccnstruction Superintendent, Limerick Generating Station (LGS), Unit 2.
The Manag, u ' gineering is responsible for engineering designs, anal-yses, stu.a only ance, and expertise, as required, to support the safe and effective son.:
., of PEco's nuclear units.
The Manager-Project Management is responsible for the management of engineer-ing projects for each station to ensure that all engineering work is defined, planned, scheduled, budgeted, implemented, and technically supported and eval-uated in a timcly and cost-effective manner.
The Manager-Projects Management works with each station's project manager to coordinate each station's imple-mentation of engineering projects.
The Manager-Engineering Design is responsible for providing conceptual design support, engineering design, and drafting services to support the development and implementation of nuclear plant nodifications.
The Construction Superintendent, LGS, Unit 2, is responsible for planning, sched-uling, coordinating, directing, and controlling the safety, quality, timeliness and cost effectiveness of all work associated with LGS, Unit 2, until fuel loading.
2.3.4 Nuclear Quality Assurance The General Manager-Nuclear Quality Assurance (NQA) is responsible for maintain-ing an effective Nuclear Quality Assurance Program.
The Manager-Peach Bottom Atomic Power Station Quality, Manager-Limerick Quality, Manager-Quality Support, Manager-Performsnce Assessment, and Manager-Independent Safety Engineering Group (ISEG) report to the General Manager-Nuclear Quality Assurance.
Three of the groups, PBAPS Quality, LGS Quality, and Quality Support, perform func-tions related to ensuring ccmpliance with regulatory requirements including 10 CFR Part S0, Appendix B.
The other two groups. ISEG and Performance Assess-ment, provide independent assessments and oversight of operations, respectively.
l The NQA organization, as di; cussed further in Section 3.2.2 of this SER, has thus been expanded beyond being concerned only with typical quality assurance activities.
2.3.S Nuclear Review Board The Nuclear Review Board (NRD) is responsible for reviewing and auditing tech-nical and managerial areas.
Its composition has been revised to include out-side nuclear executives.
The NRB is discussed further in Section 3.3 of this SER.
2.3.6 Organization and Management Development The Organization and Managernent Development Division, reporting to the Executive Vice President-Nuclear has been established to assist managers in improving the effectiveness of their organizations and to develop management resources. This group is discussed further in Section 6 of this SER, PBApS Restart SER 2-8
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3 CORPORATE MANAGEMENT I
l The licensee stated that the root cause of the failure of corporate responsibil-ity was that "coroorate management failed to recognize the developing severity of the probleas at Peach Bottom Atomic Power Station (PBAPs) and thus, did not take sufficient corrective actions." To address thts root cause, the licensee identified the following three corrective action objectives:
(!) Change the organizational structure to increase control, accountability, I
and corporate direction of nuclear operations.
i (2) Develop the management *ystems and rnanagerial skills that will strengthen self-assessment and problem resolution capat,llities within the nucitar 7
organization.
(3) Strengthen the independent assessment process to increase upper manage-ment's involvement in timely problem solving.
The staff evaluated these corrective action objectives and the corrective Mtions identified by the licensee to meet the objectives to determine if they constitute an adequate basis, from a corporate management standpoint, to support plant re-start and continued safe operations. This evaluation of corporate management i
effectiveness involved an assessment of whether the plan fe, restart provides t
reasonable assurance (1) that the aopropriate general management processes are occurring and are effective such that management is adequately involved in program direction, (2) that adequate levels of personnel accountability are attained, and (3) that a commitment to safety exists in the organization, i
3.1 Organizational R; structuring for increased Control, Accountability, i
and Corporate Ditection of Nuclear Operations To meet this objective the licensee identified the following four corrective actions: (1) development of a nuclear-dedicated organization, (2) reorganiza-tion of the corporate management team to include an ensite corporate officer, (3) establishment of accountability of onsite ertployees and, (4) clarification ar.a documentation of management authorities and accountability.
3.1.1 Nuclear-Dedicated Organization i
l The licensee has implemented a revised corporate structure that differs from the former structure wherein a senior corporate executive had responsibility l
for nuclear power generation activities as well as other company power-generation activities. The former structure involved a company-wide matrix
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for nuclear operations. The present structure reflects a vertical integration of functions wherein the responsibility for all nuclear power activities is i
focused under the office of the Executive Vice President-Nuclear who reports
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The' revised organizational structure has been implemented as discussed in the licensee's activity item status report and in related Amendments 132 and 135 to the facility Technical Specifications for _ Units 2 and 3, respectively.
The licensee has identified the functions for each part of the organization in the restart plan, specifically as shown in summary form by Figures 3, 4, 5, and 6 and Appendix A of Section I of the r? start plan. Other tasks involved the assignment of personnel to management positions, documentation of management and operating policies, development of organizational mission statements, a review of corporate personnei policies with respect to management authorities, and documentation of interface responsibilities on personnel management issues have been completed. Team building meetings have been held in support of these activities and to develop a transitional management plan.
The licensee's tran-sitional management process is dir3cted at tracking the progress of the reorgan-ization and resolving transitional issues in a timely manner.
These corrective actions are in response to shutdown issues SD-7, 50-8. and 50-9, which involved lack of adequate management involvement in dissemination of goals and policies, in communications between different organizations, and in focusing on root causes of problems.
The staff concludes that the licensee's response, if effetively 1nplemented, provides an adequate assurance of mancgement involve-ment at.J personnel accountability in the establishment of a nuclear-dedicated organization.
3.1.2 Corporate Management Team and Accountability of Onsite Employees The licensee has eliminated two management positions in the reporting chain and has added the corporate management position of Vice President-PBAPS who will be located on site.
Regular staff meetings have been established with the Executive Vice President-Nuclear and those organizations that report to him, which include the Vice President-PBAPS.
The Vice President-PBAPS will have full authority j
with regard to the work of all site orgar,1zations and all regular site employees except for those involved in independent assessment and oversight. The indepen-dence of these personnel as well as the accountability of the corporate Nuclear Maintenance Division to the Vice President-PBAPS are acceptable.
l These corrective actions are in response to shutoown issues SD-6 and S0-8, which involved management's responsibility to be aware of comp
- tance of its staff with regulatory requirements and with managen'snt involvement in communications between different organizations.
The staff concludes that establishment of this senior onsite corporate management position in the manner defined increases management involvement in program directiun because it provides a sink between site activ-ities and other levels of corporate senior management and between site activities and related corporate support activities.
The staff also concludes that specifi-i cation of sne responsibilities and relationships of the Vice President-PBAPS as discussed above improves the accountability of personnel and organizations.
The i
position of Vice President-PBAPS is also discussed in Section 4 of this SER.
3.1.3 Management Authorities and Accountability l
Whereas the corrective action discussed in Section 3.1.1 abovt was to describe functional responsibilities for organizations, this corrective action was developed by the licensee to describe functional responsibilities and l
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transitional interface agreements for nine program areas that include the Operating Experience Assessment Program, the Commitment Tracking Program, configuration mai.agement, systems and project engineering, materials management, budget and cost control, and the Independent Safety Engineering Group (ISEG).
The lice 1see also is developing position descriptions that reflect mission statements and interface agreements.
This corrective action is in response to shutdown issues SD-7, SD-8, and SD-9, which involved inadequate management involvement in dissemination of goals and policy, communications between different departments and divisions, and focuss-ing on the root causes of problems. The staff concludes that, if effectively implemented, the establishment, documentation, and communication to the person-nel involved in the implementation of these programs of the functional responsi-bilities and position descriptions will increase the effectiveness of these programs.
3.2 Improved Self-Assessment and Problem Resolution Within the Nuclear Organi zation To meet this objective the licensee has made the following changes to provide its management with the structures and systems necessary to effectively monitor the three key areas of safety, quality, and organizational performance. The terms "nuclear employee" and "nuclear management" as used in this SER refer to those personnel dedicated to the licensee's nuclear power plant activities.
3.2.1 Philosophy for Assurance of Quality The licensee has developed a ten poi,nt program expressing its philosophy in regard to the assurance of quality.
Six of the ten points address the responsi-bility of nuclear line management.
(1)
Line management is responsible for ensuring the quality of the operations and services which it provides.
(2) Line management establishes performance goals to achieve excellence as well as the indicators to be used in assessing the performance of its organizations.
(3) Line management communicates regularly about the quality of operations with each other, its employees, and other company organizations through field visits, meetings, retreats, and written reports.
(4) Line management monitors the performance of its organization 'arough direct observation and involvement in ongoing activities and ensures corrective action when c5ere is a variance between actual performance and the indicators used to assess performance.
(5) Line management reoor.s on its performance with respect to established goals.
(6) Line management is responsible for effectively closing out all open items on a timely basis.
1 Two of the ten points address the responsibilities of nuclear employees and of l
nuclear management reporting directl. to the Executive Vice President-Nuclear:
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.. n (1) Every nuclear employee is-responsible for identifying and reporting observed quality problems / deficiencies in a timely manner.
(2) Each individual reporting to the Executive Vice President-Nuclear is respon-sible for ensuring that effective problem / deficiency reporting programs are in place for employees to use, t
Two of the ten points address the responsibilities of the Nuclear Quality Assurance (NQA) organization:
(1) The NQA organization is responsible for monitoring and assessing the per-formance of the other nuclear organizations and providing independer.t audit reports and evaluations to line management and upper management.
(2) The NQA organization is responsible for moai+.oring and assessing the ef-fectiveness and timeliness of followup actions in regard to open items.
The licensee has committed to implement and support this philosophy as follows:
(1) Publish the philosophy in the company and site newspapers, display it on appropriate corporate and site bulletin boards, and refer to it in written and oral communication with nuclear employees.
(2) Establish a nuclear performance management program to achieve and maintain excellence (see Section 0.2.5 of tSis SER).
(3) Provide effective feedback information systems to ensure tha.t line manage-ment is aware of the quality performance level of its organizations.
(4) Communicate management expectations for--and management's assessment of--quality performance during face-to-face employee performance reviews.
(5) Develop formal systems and informal programs for reporting problems related to quality.
The staff concludes that publication and implementation of this philosop% for the assurance of quality, as committed to by the licensee, provides an accept-able program for critical self-assessment and problem resolution within PECo's nuclear organization.
3.2.2 Nuclear Quality Assurance l
The functional relationship of the Nuclear Qualf ty Assurance (NQA) organization is shown in Figures 2.1 and 2.2 of this SER.
The NQA organization has been strengthened by (1) elevating the reporting relationship to the Executive
(
Vice President-Nuclear level and (2) integrating previously separate quality assurance / quality control (QA/QC) organizations into one centralized QA organi-
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zation and program managed by the General Manager-NQA.
QA/QC activities at each site are under the direction of the site Quality Manager.
i The Manager-Quality Support is responsible for quality support of such activities as manuals and procedures, vendor audits and surveillance, QA/QC training, pro-curement controls, and oversight of the activities of the Nuclear Engineering PBAPS Restart SER 3-4 t
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and Nuclear Support groups.
Each of these three managers is responsible for n.lentifying functional and programmatic deficiencies, tracking these deficiencies until they are fully resolved, and performing trend analyses, i
The scope of NQA audits has been expanded to include comprehensive technical and performance-based audits in addition to audits of the adequacy and effec-tiveness of the QA prograi.
Technical experts from outside the NQA organiza-r tion are used, as necessary, to assist the experts in the NQA organization ir.
t the performance of these audits.
NQA personnel will thus be able to focus on the adequacy and appropriateness of the technical activities of the various nuclear organizations.
Trending and evaluation of the results of the inde-pendent QA/QC activities will highlight sigt.ificant areas of concern for line management's attention.
Periodic status reports on overdue closecuts on audit findings, together with quarterly trending reports, will be distributed to l
PECo's nuclear management to keep it informed of problem areas.
The Performance Assessment Section, responsible for assessing organizational performance and providing independent evaluations of the effectiveness of PECo's nuclear program, has been added to the NQA organization.
These assessments and evaluations will be based cn information such as nlatt performance trends, QA/QC reports, ISEG reports, trend analyses, direct observation of plant conditions and activities, internal evaluations similar to those performed by the Institute of Nuclear Power Operations (INPO), and special investigations and reviews.
The ISEG function also has been added to the NQA organization.
The ISEG is responsible for performing independent reviews of plant operations, reviewing operating experiences that may indicate the need for improvements, recom-;nding needed improvements, advising management on the overall quality and safety of operations, and meintaining independent oversight of tne adequacy and ti. celi-ness of actions taken by line management in response to the Operating Experi-ence Assessment Program (see 3ection 3.2.3 of this SER).
The NQA organization is consistent with 10 CFR Part 50, Appendix B, and is an improvement oecause it reports at a sufficiently high level in the management chain so that it should i
be free of undue cost and schedule pressures and should be able to effect cor-i
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rective actions for conditions adverse to quality.
The integration of the i
separate QA/QC organi.tations into NQA should increase the visibility of NQA and er'_nce its functionability.
Therefore, the NQA organitation is acceptable to t i staff.
3.2.2.1 General Manager-Nuclear Quality Assurance The General Manager-NQA reports directly to the Executive Vice Pr>sident-Nuclear.
He is one of the six PECo members of the Nuclear Review Board (NRB).
Repor ting to him are the Assistant General Manager of NQA, the m:nagers of the PBApS and LGS Quality Divisions, the Manager of the ISEG, the Manager of Quality Support, i
ano the Manager of the Performance Assessment Division.
i Figure 6 in Section II of the restart plan shows the functional responsibilities l
of these managers.
The reporting relationship of the General Manager-NQA and i
the functional responsibilities assigned to him are acceptabla to the steff.
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. As one of the. steps to strengthen the site QA program, the licensee proposed to increase QC monitoring of shift activities.
Recognizing that line management has primary responsibility for monitoring operating activtties, the licensee discontinued continuous QA/QC monitoring of operating activitias after the shift managers and their operating teams completed tr&ining and had demonstrated pro-ficiency on shift.
The licensee has committed that QA/QC monitoring'of operations will be conducted randomly so that all shifts and shift crews will be periodically monitored with the appropriate level of coverage determined by the General Manager-NQA and the site Quality Manager, depending on the level of shift activity and performance.
This funccion is independent of the line organization, goes beyond the regulatory requirements of Appendix B, and is acceptable to the staff.
i 3.2.3 Operating Experience Assessment Program The licensee has strengthened its Operating Experience Assessment Program (0EAP).
4 The OEAP Manager, reporting to the Manager-Nuclear l Support, is responsible for i
implementation of-the program, including the following activities:
(1) receiving ano screening information from both external sources (e.g., ser-vice information letters, significant event reports, significant operating i
experience reports, NRC information notices and bulletins, and significant i
2 event notifications) and internal sources (e.g., licensee event reports and q
ISEG event reports)
(2) forwarding appropriate information to involved line organizations and independent assessment groups (3) consulting with involved line organizations to clarify, research, and eval-uate the implication, of information received; determine the need for new or corrective actions with respect to proceduros, design, or practices; and determine lead responsibility for that action (4) transmitting action requirements to the functional managers responsible for implementing the actions i
l (5) ensuring that copies of relevant information are received by the nuclear t
training, emergency planning, and other organizations that need this j
i information i
(S) maintaining the OEAP tra: king program (7) preparing monthly status reports, flagging overdue items and areas of f
concern (8) annually assessing the effectiveness of the OEAP 1
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The ISEG is responsible for maintaining independent oversight of the adequacy and timeliness of the actions taken by line managers in response to OEAP. items.
Item I.C.S of NUREG-0737, "Clarification of TMI Action Plan Requirements,"
provides guidance regarding procedures for feedback of operating experience to I
plant staff. PEco's OEAP is responsive to the NUREG-0737 guidance in this area i
and is, trerefore, acceptable to the staff.
Implementing procedures would be expected to provide more detail regarding OEAP functions.
t 3.2.4 Commitment Tracking Program The licensee has developed a strengthened Commitment Tracking Program (CTP) to ensure integrated commitment tracking and effective, timely management of i
corrective action programs.
Commitments made to NRC, INPO, and other organi-zations as well as those made by the licensee's NRB, ISEG, and NQA organization and under the OEAP will be tracked.
Responsibility for implementing the CTP rests with the Licensing Manager in the corporate Nuclear Services group. As discussed in Sections 3.5 and 5.2 of Section I of the restart plan and in the
-licensee's letter dated July 22, 1988, line management is responsible for the r
making and completion of commitments.
The Licensing Manager provides support i
to line management, which includes tracking the status of commitments and pro-viding management reports on the status of eacn organization's commitments.
The Superintendent-Technical has adcinistrative responsibility for the CTP at the site.
The CTP will consolidate the past commitment tracking efforts of various licenae orgrnizations. The program has been defined by the Executive Vice President-Nuclear, and an administrative procedure has been developed to implement the program as of July 1,1988.
The licensee cites the benefits of the CTP as establishment of a single point of line accountability, facilitation of commit-i ment plan and schedule development, proactive management review of commitment activity, and facilitation of problem resolution at the lower management levels.
j The staff concludes that the CTP is a useful tool for enhancing management processes in that it provides a systematic approach to commitment tracking, strengthens accountability, and will provide opportunitics for management involvement up to the Executive Vice President-Nuclear in commitment 'nanagement.
t 3.2.5 Nuclear Performance Management Program The licensee has committed to establish a nuclear performance management program to achieve and maintain excellence.
This program will include performance goals for excellence as well as technical and operational performance standards for each nuclear line organization.
Performance indicators for tracking and report-ing actual performance against the performance goals and standards wiYi also be r
established.
The Executive Vice President-Nuclear is responsible for having this program implemented throughout the nuclear organization by April 1989.
Measurement of performance against the established performance goals and stan-dards will be tracked and reported to management.
The timeliness and effective-ness of required corrective action at each managemc7t level will be monitored I
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and emphasized in the performar;' ippraisal process. The NQA organization will assess the effectiveness of the pr
~ ar,d report the results to the involved line management and the Executive Vice >,.: dant-Nuclear.
Although not required by NRC and not required for implementation before restart, this program represents a good initiative by the licensee.
The NRC will review its effectiveness during inspection activities.
3.2.6 Restart Readiness Self-Assessment As noted above, the licensee has implemented programs to improve its self-assessment capabilities.
The licensee's self-assessment of its readiness for restart will constitute an early test of these capabilities.
The staff will evaluate the licensee's report in this regard and will report the results of its evaluation in conjunction with its own evaluation of readiness of the Peach Bottom plant for restart.
3.3 Company Management Oversight _of Nuclear Operations To meet this objective of strengthening the independent assessment process, the licensee has revised the Nuclear Review Board (NRB) charter and reporting rela-t ;nship and has established a Nuclear Committee of the Board of Directors.
3.3.1 Nuclear Review Board 3.3.1.1 Membership The NRB consists of nine menbers, six PECo personnel and three recently added outside consultants.
The Peach Lottom Technical Specifications state that the qualification requirements for members of the NRR shall be an academic degree in an engineering or physical science field and a minimum of 5 years of technical experience, of which a minimum of 3 years shall be in one or more specified areas.
The staff conclude: that the incumbent members meet these qualifications.
3.3.1.2 Role and Relationships The NRB is a group of individuals independent of plant operations charged with providing an independent review of safety-related activities.
The specific re-sponsibilities are described in the Peach Bottom Technical Specifications.
The NRB reports directly to the Executive Vice President-Nuclear and submits copies of reports to the Chief Executive Officer of PECo.
In addition, the Chairman of the NRB will meet directly with the Chairman of the Nuclear Committee of the Board and will report to this board at least annually.
The staff reviewed the provisions for the NRB and finds that they meet the guidance for independent review as described in Section 13.4 of the Standard Ra/iew Plan (NUREG-0800) and are acceptable.
3.3.2 Nuclear Committee of the Board of Directors PBAPS Restart SER 3-8
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3.3.2.1 Membership The membership of the Nuclear Committee of the Board of Directors (NCB) will consist of not more than four nonemployee directors from the FEco Board of
-Directors and one or more outside consultants to serve as advisors to the com-mittee. The licensee has identified the consultants, and the staff considers them qualified to perform this function.
3.3.2.2 Role and Relationships PEco has established the NCB as a standing committee of the Board of Directors.
As such, it reports to the Board of Directors.
Its role is to advise and assist the Board of Directors in its responsibilities for oversight of the company's nuclear operations. The NCB will receive information by directly m;eting with l
the vice presidents of Peach Bottom and the Limerick Generating Station, other department managers, and the Chairman of the NRB and will receive information from and monitor the NRB, the Nuclear Quality Assurance Organization, and the Plant Operations Review Committee.
The staff reviewed the provisions for the NCB and concludes that the NCB, as an organizational group, goes beyond NRC regulatory requirements.
The staff considers it a useful adjunct in keeping the PEco Board of Directors informed about the nuclear activities of PECo.
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4 STATION MANAGEMENT LEADERSHIP The licensee's analysis of the root cause of poor leadership by plant management, as discussed in Section II of the restart plan, follows:
Leadership skills at PBAPS [ Peach Bottom Atomic Power Station] were in-adequate to develop employee understanding of and willingness to comply with high nuclear standards. Plant management's goals and performance expectations had not been communicated effectively to Peach Bottom em-ployees; organizational and individual accountabilities had not been clearly established; and little effort had been made to establish a team approach to site work r,lanning and implementation.
In general, there were poor communications among site work groups, and between the station and off-site work groups. Much of the communication downward in the organi-zation was handled by.aemos and there was a lack of open two-way com-munications between station management and employees.
This lack of adequ-ate leadership skills had resulted in poor morale in general.
The oper-ators,whowerealsofeelingtheresultsofthesecondrootcause[ failure to initiate timqly licensed operator replacement training programs], had developed serioJs attitude problems evidenced by their lack of profes-sionalism in the contrcl room and by the hostility which they occasionally express 6J toward other work groups, upper management, and visitors.
The licensee has developed the two corrective action objectives given below to aodress the lack of site leadership.
(1) establish a PBAPS management team with strong leadership and man.agement skills (2) increase the number of site management positions to ensure effective supervision and accountability for each function The Itcensee proposed to identify individuals with strong leadership and management skills to staff each superintendent-level position and above to imnlement the first objective.
The licensee stated it would conouct a search, internally or externally, as appropriate, to identify and select luslified candidates to staff positions at the superintendent level and above.
The licensee proposed to develop an organizational structure to provide in-creased management direction, control, authority and accountability for site work activities to implement the second objective.
The licensee planned the following major activities to accomplish this tash:
identify work functions that should be removed from the responsibility of the plant manager to allow increased plant w ager focus on day-to-day plant operations, while simultaneously prov';ing additional dedicated management attention to areas such as oute e management and station sup-j port PBAPS Restart SER 4-1
establish a revised site organizational structure based on this analysis clarify and document functional accountabilities for each superintendent-level organization within the revised site organizational structure The staff reviewed the qualifications and training of the Peach Bottom station management personnel against the staff guidance in Regulatory Guide (RG) 1.8, "Qualifications and Training of Personnel for Nuclear Power Plants" (Rev. 2, April 1987). This guide erdorses ANSI /ANS-3.1-1981 or ANSI /ANS-N18.1-1971 for different personnel positions (see Regulatory Positions C.1 and C.2 in RG 1.8).
The licensee has committed to ANSI N18.1-1971 except for the positions of senior health physicist and shift technical advisor.
f 4.1 Establishment of Management Team To meet the first objective of establishing a management team with strong lead-ership and management skills, the licensee restructured the site organization.
4.1.1 Onsite Management Team l
Figure 2.3 is a functional organization caart of the reorganized onsite manage-rnent team with four positions reporting to the Vice President-P8APS. The four positions 3re Plant Manager, Project Manager, Support Manager, and Training
^
Superintendent. The staff reviewed the qualifications and training of PBAPS managers as given in Appendix B of the restart plan, with a special emphasis on the operations organization (see section 4.1.2 of this SER), to ascertain that r
the qualification and experience of each meet the l' ensee's first objective to e3t0blish a Peach Bottom management team with strong leadership and management s til l: snd satisfy the guidance of RG 1.8 and licensee commitments.
I Vice President-Peach Bottom Atomic Power Station On May 4,1987, the licensee appointed Dickinson M. Smith, Rear Admiral, U.S.
i Navy (retired) as Manager-PBAPS. During his 25 years of Navy nucl e r experi-t ence, Mr. Smith served as Chief of Staff, Allied Command Atlantic, where he i
I directed an international military staff of 450 personnel.
Previously he was l
Senior Military Commander in the Philippines, managing the largest U.S. Naval i
installation overseas with a total military and civilian work force of 35,000.
Mr. Smith has introduced several major improvements in site management and organizational communications such as methodol^gy for employees to report con-cerns, the "Tell it to the Manager" program, and regular meetings with person-nel. Af ter the corporate reorganization in October 1987, Mr. Smith assumed the responsibilities of the newly created position of Vice President-Peach Bottom Atomic Power Station.
t On the basis of its review of Mr. Smith's qualifications, the staff concludes that he has sufficient lerership and management skills to meet the criteria of l
the first objective.
Further, his education, experience, and training meet the g
staff guidance in RG 1.8 for a manager.
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4 LAnt_Managel P
To staff the redefined position of Plant Manager-PBAPS, the licensee selected John F. Franz, who, as Manager-Limerick Generating Station (LGS), provided leadership to the management team that achieved high ratings in the NRC's sys-tematic assessment of licensee performance (SALP) for Limerick. Mr. Franz has 25 years of experience, including a variety of supervisory positions at Peach Bottom before 1976, 9 years as Superintendent-0perations, LGS, and nearly 2 i
years as Plant Manager, LGS. He has held NRC senior reactor operator (SRO) licenses for Peach Bottom Units 1, 2, and 3 and LGS Unit 1.
On the basis of its review of Mr. Franz's qualifications, the staff concludes that he has sufficient leadership and management skills to meet the criteria of the first objective.
Further, his education, experience, and training meet the staff guidance in RG 1.8 for a plant manager.
I I
Project Manager l
The site Project Manager position has been filled by Kenneth P. Powers, who has over 20 years experience in engineering, craft supervision, quality control, cost engineering, and planning and scheduling, as well as Navy nuclear shipyard service. Thirteen years of his experience have been in the commercial nuclear industry, including seven years with Bechtel, where he was assigned for over l
four years as Project Field Engineer at LGS.
There, he led an organization of 1,000 professional personnel through fuel loading and initial operations.
Earlier in his career, while working for United Engineers and Constructors, he served as Project Engineering Manager at Seabrook Nuclear Power Station from l
pro-reactor pressure vessel hydrostatic testing through hot functional testing.
l He had demonstrated ability in planning, organizing, and leading complex j
organizations to achieve their stated goals.
On the basis of its review of Mr. Powers'~ qualifications, the staff concludes that he has leadership and management skills to meet the criteria of the first l
objective.
Further, his education, experience, and training meet the staff guidance in RG 1.8 for a technical manager.
(
l Support Manager David R. Meyers is the Suppo-t Manager at Peach Bottom.
He has leadership i
skills gained during his 23 years of experience in PEco's Electric Production l
Department. Mr. Meyers has hew supervisory and managerrent positions since 1973.
In 1974 he became Assistans Superintendent at PECo's Delaware Station j
where he served until accepting the p sition at Peach Bottom. He was Vice Chairman and Chairman of the Pennsylvania Electric Association's System Opera-tion Committee in 1982-1983 and 1984-1985, respectively.
5 On the basis of its review of Mr. Meyers' qualifications, the staff concludes l
that he has leadership and management skills to meet the criteria of the first objective.
Further, his education, experience, and training meet the staff i
guidance in RG 1.8 for technical support personnel.
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Training Superintendent
-The licensee assigned Ernest A. Till as Training Superintendent.
During 1986
'and 1987, Mr. Till served as Nuclear Training Manager for Illinois Power Com-pany, where he instituted major changes in the training department to ensure the success of general and INPO accredited training programs. Mr. Till has brought a wide range of professional experiences to.his new position, including 33 years of service as a career Naval officer assigned to command positions in the nuclear field and 3 years as Director of the Mathematics and Science faculty at the U.S. Naval Academy in Annapolis, Matyland.
J On the basis'of its review of Mr. Till's qualifications, the staff concludes
[
that he has sufficient leadership and management skills to meet the criteria of i
~
the first objective.
Further, his education, experience, and training meet the r
staff guidance in RG 1.8 for technical support personnel.
l j
4.1.2 Operations Organization The Operations organization consists of Superintendent-0perations, Assistant i-Superintendent-0perations, Operations Support Engineer, shift managers and the shift crew.
The Superintendent-Operations reports to the Plant Manager who, in turn, reports to the Vice-President, PBAPS.
Figure 4.1 is an organization j
chart for the Plant Manager. The following is an evaluation of the qualifica-
^
tions and experience background of the key management personnel at the site.
Superintendent-0perationc John B. Cotton was appointed Superintendent-0perations in November 1987 upon successful completion of his SRO examination for Peach Bottom. Mr. Cotton later received his SR0 license at Peach Bottom.
Before accepting this post-tion, Mr. Cotton served as Superintendent-Plant Services, PBAPS.
He has had 15 years of experience with PECo, including 6 years as Maintenance Engineer at LGS, where he was SRO-licensed.
During his 5 years as a U.S. Naval officer, l
Mr. Cotton completed Navy nuclear power training and performed in a variety of supervisory roles.
Assistant Superintendent-Operations t
Frederick W. Polaski, who has over 16 years of experience as an engineer with PECo, has been assigned by the licensee as Assistant Superintendent-Operations.
He has held positions of increasing responsibility in nuclear operations since i
he joined PECo in 1972.
Mr. Polaski assumed the duties of Operations Engineer at Perch Bottom in April 1987, following the shutdown. Before that assignment, he had s'rved as Outage Planning Engineer for 4 years. Mr. Polaski holds an e
NRC SHO license at Peach Bottom.
On the basis of its review of the qualifications of Messrs. Cotton and Polaski, the staff concludes that they have sufficient leadership and management skills to meet the criteria of the first objective.
Further, theiv education, ex-perience, and training meet the staff guidance in RG 1.8 for an operations manager.
I i
)
.o Operations Support Engineer The Operations Support Engineer is Thomas M. Mitchell, who is on loan to PECo from the Institute of I;uclear Power Operations (INPO). At INPO, he served as As;istant Manager, and Manager of the Radiological Protection Department, and as Secretary of the Corporation and Staff Assistant to the President.
He has 10 years of experience in nuclear engineering and certification as a health pnysicist (power reactors). He has a B.S. degree in nuclear engineering and an M.S. degree in mechanical engineering.
On the basis of its review of Mr. Mitchell's qualifications, the staff concludes that he has sufficient leadership ar,d management skills to meet the criteria of the first objective.
Further, his education, experience, and training meet the staff guidance in RG 1.8 for technical support personnel.
Shift Managen The newly created positions of shift managers complete the operations management team These positions have been filled by six licensed senior reactor operators.
They each hold a degree in engineering and have had 6 to 14 years of experience with PECo in a variety of technical and supervisory roles.
Each of the shift managers has completed "Managing for Excellence," which is a 4-week intensive tanagement training program specifically designed to enhance managerial skills for this new position.
They have demonstrated their leadership ability by building shif t teams that have a high degree of cohesion and proficiency, as demonstrated, te the satisfaction of NRC evaluators, by the performance of these teeins during simulator training (see Section 6.2.2).
On the basis of its review of the qualifications of the six shif t managers, the staff concludes that the, have sufficient leadership and management skills to meet the criteria of tb > first objective.
Further, their education, experi-ence, and training meet the staff guidance in RG 1.8 for supervisors requiring NRC licenses.
4.1.3 Overall Evaluation of the Management Team The licensee has assembled a sufficiently strong leadership team to provide new direction at Peach Bottom station. All five senior site managers (the Vice President, Plant Manager, Project Manager, Support Manager, and Training Super-intendent) have demonstrated recurds of successful leadership and achievement across a broad spectrum of relevant backgrounds.
Three cf the five (the Vice President, Project Manager, and Training Superintendent) were hired from out-side PECo and ccntribute new managerial perspectises frcm other organizational cultures.
The Operations organization at Peach Bottom has been similarly infused with management talent, as have other management positions in the expanded site organization. Of the top 16 PBAPS line managers at the superintendent level or above, 7 have been brought in from outside PECo, 2 have been transferred from LGS, 4 have been assigned from the corporate organization, and 3 have come from within the Peach Bottom organization.
Collectively, these managers provide a PBAPS Restart SER 4-5
sufficiently strong leadership team with a balanced combination of new perspec-tives and adequately solid continuity and a common mandate to establish a pro-per site culture.
On the basis of its review of the qualifications of personnel, the staff con-cludes that the licensee has established a site management team with strong leaders $ip and management skills.
The team has the necessary managerial ar.d technical resources to provide assistance to the plant staff for normal and emer-gency operation.
The staff concludes that these staffico changes adequately address the objective to establish a Peach Bottom managen.ent team with strorig leadership and management skills and, therefore, are acceptable. The staff fur-ther concludes that these personnel meet the guidance of RG 1.8 and the standards of ANSI N18.1-1971.
4Property "ANSI code" (as page type) with input value "ANSI N18.1-1971.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..2 tupervision and Management Acccuatability The licensee provided detailed information in Appendix E to Section II of the restart plan and a summary in Secticn 2.2.2 of the same document. The staff reviewed the information to detercine if it met the second objective to in-crease the number of site management positions to ensure effective supervision and actuuntability for each function.
The staff also reviewed the licensee's new opers. ting organization and plant staffing plan against applicable portions of staff guidance in Sections 13.1.2 and 13.1.3 of the Standard Review Plan (NUREG 0600), with special erphasis on supervision and management accounta-actions and the staf fy is a sumniary description of the licensee's corrective bility.
The followin s evaluatien of those actions.
As part of the licensee's corporate analysis preceding the nuclear reorganiza-tion, the distribt. tion of work within the corporate matrix organization in existence at that time was reviewed by the licensee to determine which work functions should be reassigneo to the emerging nuclear organization. At the site level, each work functicn was analyzed to determine if it was a necessary part of the nuclear Plant Manatwr's responsibilities for day-to-oay plant operations or if it could be reassigned to other site organizations responsible i
for support activities.
This snalysis resulted in the establishment of a nuclear-dedicated corporate organization and a revised site organization that provides more focused management, direction and accountability for plant opera-tions, outage planning and management, and other station support activities.
Table 4.1 prcvides a comparison of Plant Manager's staff and site management positions at Feach Rottom at the time of the shutdown order (March 1987) and af ter the reorganizations (April U80).
In the new site organization, ths.e are now 54 management positions at the senior engineer level or above (as corrpared with 23 such positions before the reorganization) to provide dedicated management attention to each site function and to ensure increased supervision of site personnel.
In addition to increased manageroent accountability, there also is more employee accountability in the revised organization. All permanent and contract em-ployees assigned on a regular basis to Peach Bottom work locat ons are account-i able through their PECo or contract managetent reperting chains to the Vice PBAPS Restart SER 4-6
' esion 't-PBAPS, enept fcr
",e person involved in indep<, dent e,ar m?tt and ove. ight
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r t M.3 octure enables the lice res. ent-PBAPS to have
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g, airncting, coor, cat.iag,.2t1 con-
' ei lia all
..*2 activitie-
- n the top mar, cement porti.ig ; ructurc and div'sion of func-
'n-dift.es 4e sis. arpW Jun.
Cigure 4.1, which shows the
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.ormation about the recorting
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i g al.,e a t s t '
ne supeHntendent
%s snizat m are rc<pensible for operating the sta-tt t
' ai.lv, e1/ s c iently, cnd
. cn o'isnce with all applicable t
,s The rvvi ed definition of functional responsibilities
..,.i ' emp h a r es tne day-to-day aperations of the station ard e l '-
- r. ' tne Plant Manager' r f;rmer r ;ponsibilities for outage plan-ni. 4 gement, modifications, personnel administration, security, and activities that have been assigned to the Project and Support o tt. s 4.
oro=
- t., o n s.
The ", ant Manas.9* arves as PBAP.'. Emergency Director in accoi-da-the PBAPS Emergency laa.
Pi sv.. sly, there were two superintendents reporting to the Manager-PBAPS: with the reorganizat an, there are now four superintendents.
Superintendent-Operatio a is responsible for shift operations, including supervision of shif t manaprs and shift technical advisors; for operations support, including blocking coordination; shift training; and administration.
Superintendent-Maintenance / Instrumentation and Control (I&C) is responsi-ble for developing and implementing preventive, predictive, and corrective maintenance programs for station mechanical, electrical, and I&C equipment.
Superintendent-Plant Services is responsible for providing on-site plant chemistry, health physics, and radwaste management services in support of plant operations.
Superintendent-Technical is responsible for providing plant technical sup-port; reactor system and test engineering; fire protection; site coordina-tion of tha Licensee Event Report Program, the Commitment Tracking Program, and the Operating Experience Assessment Program; and site interfaces with Federal agencies, states, and industry.
The licensee's restart plan describes the structure and accountability of the new organuations under all four site managers (Plant Manager, Project Manager, Support Manager, and Training Superintendent). Although the staff performed a general review of these organizations, staf f emphasis was directed toward the Plant Manager's organization, particularly the operations staff under the Superintendent-Operations.
Fiiure 4.2 shows the management structure for shift operations.
The licensee established and filled the new position of Assistant Superintendent-0perations to assist s.ke Superintendent-0perations in day-to-day shift operations manage-ment and admii3stration and to ensure that one of these two senior operations managers is rout!nely available to operations nersonnel on shift.
The licensee established the position of shift manager (one for each of six shifts), reporting to the Assistant Superintendent-0perations, to provide a higher level of management authority on each shift so that the past problems of operators being isolated from management could b" avoided.
The shift man-agers serve as the Plant Manager's direct representatives on shift and have the authority to control shift operatiuns.
They coordinate and direct the activi-ties of health physics, cheristry, maintenance, instrumentation and control, security, and construction periotinel as well as vendor personnel and other site personnel during their shift as these activities relate to operating the plant.
The shift managers directly supervise the shift supervisors and shift technical advisors (STAS).
The licensee established the posittor, of the floor foreman who is responsible for coordinating and monitoring the activfties of the non-licensed operators and overseeing such areas as watchstanding performance, attentiveness to duty, training, and overtime.
The floor foreman reports to the shift supervisors.
The licensee established the position of Operations Support Engineer to hea; the new Operations Support organization.
The Operations Support Engineer reports directly to the Assistant Superintendent-Operations.
The Operations Support organization was developed to support the daytime shift organization by relieving operators and shift management of some of their administrative burden and ensuring coordination of all work associated ulth control room activities.
Reporting to the Operations Support Engineer is the Operations Support Super-intendent, another new position.
In addition to other support duties, this person is responsible for overseeing training and administrative matters for the shift supervisors.
The blocking coordinator reports to the Operations Support Superintendent.
The new blocking coordinator position, available to licensed SR0s on a rotational basis, was established to ensure the efficiency and safety of the blocking permit process.
The blocking coordinator will supervise a grcep of licensed operators temporarily assigned to the processing of blocking permits for 2 to 3 months at a time. This arrangement will provide off-shift rotational opportunities to licensed SR0s and R0s.
At the time of restart, each of the six shifts is to be staffed by a shift man-ager, two shif t supervisors, three R0s, an STA, and a number cf non-licensed operators. This shift complement reflect) an increase of one additional shift supervisor beyond the requirements of the Technical Specifications and provides additional supervisory direction for shift operations activitias and backup relief to the lead shift supervi,or. One shift supervisor will remain in the control room; the other will be available to go where needed to 1bserve, super-vise, and direct activities throughout the rest of the plant.
A fourth licensed R0 is to be added to the team as additional licensed-operator reseurces become available.
Thus, each shift team will be augmented to provide greater flexibility for relief and rotation of operators and increased resources to handle unusual occurrences.
The licensee believes that these changes, com-bined with an increased reserve of licensed operators, will be sufficient to ensure that any overtime will be managed effectively.
The control of overtime is discussed in Section 6.4.2.5.
The licensee also changed the shift rotation schedule from reverse rotation to forward rotation.
Tha schedule change was a result of licensee analysis per-formed by a task force of operators and management.
The licensee management included operators in the task force to ensure that any change in shift policy would have a positive effect on morale.
Early feedback from the operations staff indicates that the change in the shift rotation schedule has had a positive effect.
The new nuclear organization eliminates the company-wide matrix under which the licensee formerly provided engineering, maintenance, and construction support for its nuclear operations.
Yhe new site organization provides single point accountability and control for site operations under the Vice President-PBAIS.
The licensee analyzed each site function to determine if it was a necessary part of the nuclear Plant Manager's responsibilities for day-to-day plant operations or if it could be renssigned to other site organizations responsible for support activities.
This saalysis resulted in a revised site organization (expanded from 23 to 54 management positions at the senior engineer level or above) that provides more focused direction and accountability for 11 ant oper-ations, outage planning and management, and other station support activities, including contractor activities.
The revised organizational structure also provides for a sufficiently strong corporate management presence on site, shortens and strengthens the nuclear operations chain of command, and strengthens interactive communications between members of the station organization and the management personnel of offsite support organizations.
The responsibilities and authorities of the personnel involved in the many dis-ciplines required to safely operate a nuclear plant have been allocated among several upper-management positions to ensure more concentrated attention to those activities while establishing a direct line of accountability to the Vice President-PBAPS and ultimately to the Chief Operating Officer.
The revised site organizational structure will assist the Plant Manager in focus-ing his attention on safe and reliable operations by designating separate manage-ment and accountability authority for outage plarning and site support activities, thus relieving the Plant Manager of these duties.
The reassignment of outage planning and site support functions also will assist in focusing management attention in these areas.
A site-dedicated training function has been established to ensure more attention and responsiveness to site training needs, and the corporate Nuclear Training Division is intended to provide technical direction and support.
9<.
I i
Sufficient changes have been made to the Peach Bottom Operations organization to provide additional managerial and supervisory focus on shif t control room
-operations and floor activities. The addition of the shift manager position also addresses the past problem of the isolation of operators from management.
The new daytime Operations organization relieves operators of some of their administrative burden, while ensuring effective coordination of all adminis-trative work associated with shift control room activities.
Additional reactor operator coverage on each shift, once more licensed person-nel become available, will provide more flexibility for relief and rotational assignments and increased resources to handle any unusual occurrences on shift.
On the basis of its review of the information in the restart plan, the staff concludes that the licensee has sufficiently increased the number of site man-agement positions to provide for effective supervision and accountability for each funct1on and to meet the criteria of the second objective.
The staff further concludes that the licensee's operating organization is acceptabie and meets the applicable requirements of 10 CFR 50.40(b) and 50.54(j) through(m).
The licensee has described the assignment cf plant operating responsibilities, the reporting chain up through the Chief Executive Officer of the company, the proposed size of the regular plant staff, the functions and responsibilities of each major plant staff organization, the proposed shift crew complement for two-unit operation, and the qualification requirements for members of its plant staff.
The licensee also provided the resumes for its management and principal supervisory and technical personnel.
Therefore, the staff concludes that the licensee's new operating organization and plant staffing plans are acceptable.
Ptant Manager Staff Engineer I
I I
I Superintendent-Supe ent-Maintenance Superintendent-Superintendent-Technical Operations Instrument a g,
Controls I
i Assistant assistant Eng W -
Eng b rN -
Superintendent-Assistant Superintendent-Radwaste Technical Operations Superintendent-Instrument &
Mainte Controls Engmer-Senior Engineer-Maintenance l&C EngW Chemist Regulatory Tp at Engineer Senu supervoor-Supervisor Shrt Managers Health u m enance mC Phreicist Figure 4.1 Plant Manager organization chart PBAPS Restart SER 4-11
Superintendent-Operations Assistant Superintendent-Operations I
I SNft Operations Manager Support Ergineer
' 1&L Teena u Staff m
Utig Shift SNft Su p Manager Superintendent-Operations Support I
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I Reector Reactor Utlity g
Reactor g4 gg Operations @Y Operssor %f Coorensaw W gn, Figure 4.2 Shift operations management organization chart PBAPS Restart SER 4-12
e.
l Table 4.1 Plant Manager's staff and site management positions March 1987 April 1987 PBAPS Plant Manager's Staff 1 Plant Manager 1
Plant Manager 1
Superintendents 2
Superintendents 4
Staff engineer 1
Staff engineer 1
Senior engineers 8
Senior engineers 10 Shift managers
_6 Totals 12 22 PBAPS Site Management Positions!
Additional PBAPS line management reporting Plant Manager's staff matrixed management 2 through the nuclear organization 2 Manager 1
Superintendents 3
Vice President-PBAPS 1
Superintendents 2
Assistant super-Managers 4
Staff engineer 1
intendents or Superintendents 10 Senior engineers 8
equivalents 3
Staff Engineer 1
Senior engineers Assistant superintendents 6
or equivalents 5
Senior engineers or equivalents 26 Shift managers 6
Totals 12 11 54 1 Management staff is defined as those positions included in the company's Management Salary Plan.
i 2 Does not include site quality organization management staff.
5 LICENSED OPERATOR RESOURCE DEVELOPME4T Chapter 3 of Section II of the restart plan addresses corrective action objec-tives, corrective actions, and associated major activities to eliminate or miti-gate the root cause of the licensee's failure to initiate timely licensed oper-ator replacement training programs.
The licensee's analysis of this root cause is as follows:
There were not enough reserve licensed operator personnel or new replaco-ments ready to take over as the existing work force transferred, retired, or resigned. Although shift coverage met safety requirements and Tech-nical Specifications, there was an inadequate supply of licensed operator personnel to provide flexibility for relief or rotational assignment.,
handle the shift administrative workload effectively, or assure direct supervision of floor activity.
Many licensed operator personnel were complaining about the negative im-pact on their family lives created by having to work extensive overtime.
They were also seriously concerned about the lack of opportunities to pursue alternative career paths or to have some relief from shift work at some point in their career progression with the company.
To address this root cause, the licensee established the following corrective action objectives:
(1) Ensure an adequate reserve of licensed operators to provide flexibility for relief and rotational assignments and add additional supervisory and reactor operator coverage beyond the safety requirements on each shif t.
Specifically, ensure availability of sufficient numbers of qualified licensed oper-ators to restart Peach Bottom station develop and initiate plans to create and maintain an adequate re;erve of licensed personnel ready to fill temporary and permanent vacancies staff, on a rotating basis, a blocking and support group to reduce the administrative burden on the control room shift (2) Ensure that shift peraonnel have opportunities to pursue alternate career paths and to have relief from shif t work during their career pregression at PECo. Specifically, develop additional career paths for shift personnel davelop educational programs for operator personnel who wish to prog-ress into technical and/or management positions PBAPS Restart SER 5-1
The staff analyzed the corrective actions proposed and/or implemented by the licensee. This analysis is presented in the sections that follow.
5.1 Current Resources The following lists give the current licensed operator positions at Peach Bottom station and present staffing:
Senior Reactor Operater Licensed Personnel 1 superintendent-Operations Current schedule:
in place 1 assistant superintendent-Operations Current schedule:
in place 1 operations support engineer Current schedule:
in place 6 shift managers Current schedule:
in place 2 backup shift managers Current schedule: One with an inactive license is in place.
One with a license that is restricted to operation during cold shutdown and refuel modes only.
12 shift supervisors Current schedule:
in place 12 plant staff and/or licensed engineers Current schedule:
10 plant staff senior reactor operators with inactive licenses are in place.
Reactor Operator Licensed Personnel 24 operators Current schedule:
25 are in place:
14 are licensed to operate during all modes and 11 are restricted to operate during the shutdown and refueling modes only.
The licensee analyzed the number of licansed operators required for safe restart.
Although the number currently available meets the requirements of the Technical Specifications, the licensee determined that augmenting the licensed operator staff with people from outside PECo would be beneficial in order to release additicnal Peach Bottom reactor operators for senior reactor operator training and to provide assistance with the processing of blocking permits.
The current sca ffing levels are sufficient to fill the Superintendent-Opera-tions, the Assistant Superintendent-Operations, and the Operations Support Engineer positions.
Current staffing levels also support the complement of six shift crews with each crew composed of one shift manager, two shift supervi-sors, and three reactor operators.
The licensee currently has 14 rear. tor operators with licenses applicable to all modes of operation and 11 reactor operators with licenses restricted to the cold shutdown and refueling modes of operation.
There are 6 shif t managers and 12 shift supervisors.
The 11 reactor operators with licenses restricted to the cold shutdown and refueling modes of operation require additional training to have their licenses converted to allow operation in all modes. The staff will review the work hours of the operators and the effectiveness of training during the startup period.
The current staffing levels for licensed personnel described above satisfy the guidance of American National Standards Institute ( ANSI) Standard N18.1-1971 as endorsed by Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants" (Rev 2, April 1987), 10 CFR 50.54(m), and the facility Technical Specifications for the startup and operation of a single unit. On the basis of its review, the staff concludes that the licensee satisfies the requirements for safe startup and operation of a single unit.
Startup and oper-ation of both units will be possible only after more operators holding unre-stricted licenses are available.
5.2 Future Staffing Levels The licensee has committed to establishing a staff of at least 42 active licensed members for twonnit operation.
The breakdown of this goal is:
6 - shift managers (SRO) 12 - shift supervisors (SRO) 24 - reactor operators As noted in Section 5.1, this goal is satisfied, except that 11 of the reactor operators have licenses restricted to the shutdown and refueling modes of oper-ation.
The licensee also has committed to having licensed operators with either active or inactive licenses at the site.
These adoitional licensed operators will be available in the future as staffing permits; the licensee projects them to be in place by 1991.
To ensure adequate reserves of licensed operators, the licensee has proposed corrective actions to (1) develop and initiate plans to create and maintain an adequate reserve of licensed personnel ready to fill temporary and permanent vacancies and (2) staff a blocking and support grrup, on a rotating basis, to reduce the administrative burden on the control room shif t.
The major activi-ties associated with these corrective actions are listed below.
develop higher entry standards and appropriate compensation schedules for
+
the recruitment and hiring of future candidates for licensed operator pos-itions develop and initiate a plan for additional operator training programs to provide an ongoing reserve of licensed operators accelerate the operator training program to increase the number of avail-able licensed operators more quickly PBAPS Restart SER 5-3
[
~
develop a plan to identify and train qualified personnel to staff a blocking and support group clarify and document the responsibilities of the work control group a
The licensee has taken several actions to accelerate the recruitment and train-ing of candidates for licensed operator training.
These actions include:
(1) Existing personnel policies and compensation practices related to the bir-ing of new employees were reviewed to determine what changes were needed to permit nuclear personnel to be hired more promptly and at other than entry levels.
Following the review, both the written policy and compen-sation practices were apprcpriately changed.
(2)
In July 1987, higher standards of screening for candidates for the licensed ope" tor progression w ue hopted to include a minimum of 2 years of post-hig -:;chool technical education, U.S. Navy nuclear training, or equivalent education and work experience.
Successful candidates are paid more money at the startins level. The hiring procedures have been revised to include three new provisions:
(a) a review by the site vice presidents is con-ducted to establish budgeted positions critical to the operation at each nuclear plant; (b) an "open posting" is maintained for these critical pos-itions so that the licensee's ability to expand forces and/or replace losses will be maximized; and (c) any requisitions for employment in these critt-cal areas are expedited by simultaneous processing of potential candidates for transfer frcm within the company and newly hired people from outside the company.
(3) The licensee's Personnel and Industrial r lations organization was requested e
to recruit and hire additional licennd operator candidates in accordance with these revised requirements.
Fif teen employees (14 newly hired people with Navy nuclear experience and 1 internal PECo transfer) were recruited in the summer of 1987 and successfully passed a plant operator screening test.
They are completing qualification as auxiliary operators at Peach Bottom.
The licensee also is hiring 20 additional employees in 1988 to enter training as helpers.
(4) An accelerated license training program for experienced Peach Bottorr plant operators started in August 1987.
This led to the licensing of additional operators who are restricted to operation in the shutdown and refueling modes in the summer of 1988.
A continuing series of licensed operator training classes will be conducted to fill new licensed operator positions, maintain an adequate reserve of licensed personnel ready to fill ternporary and permanent vacancies, provide career path opportunities, and manage overtime of operators effectively.
(5) For the short term, the licensee had a tean of three Hope Creek licensed personnel, provided by Public Service Electric and Gas Co., to assist in processing blocking permits which had previously consumed significant amounts of time and attention of control room operators.
The operators on loan from Hope Creek did not perform licensed duties and were released when additional licensed operators were available to work at Peach Bottom.
(6) An adequately staffed training department is needed to supoort initial training of operators and continuing requalification training.
The licensee recognizes that effective and timely training of all nuclear personnel is a critical element in improving self-assess &.nt and problem-resolution capability within the nuclear line organizations. A corporate training
~organization reporting to the Vice President-Nuclear Services has been established.
The onsite training organization has been estabitshed as a superintendent-level position reporting directly to the Vice President-Peach Bottom.
The Training Superintendent will also work with the corpoiate training organization.
The licensee's plans for recruitment, hiring, training, and licensing of oper-ators represent a co:unitment to establishing a large body of trained and train-able operators.
The plans allow for increased hiring flexibility with higher initial standards for entry at a higher starting wage.
These plans should increase the licensee's ability to recruit qualiffed employees.
To evaluate the aptitude of the applicants, the licensee administers a new-employee screen-ing test. Additionally, a candidate who is enrolled in a licensed operator training program is screened during this program to verify that he/she is ready for licensing.
This screening is intended to ensure that candidates for license application are adequately qualified.
Or the basis of its review, the staff concludes that the licensee's plans to increase its licensed operator staff are appropriate because of revised recruit-ment practices, accelerated training programs, management restructuring of the training organization, and management commitment to the goal of increased staffing.
5.3 Offshift Rotation and Alternative Career Patt..
The licensee has proposed corrective actions to develop (1) additional career paths for shif t personnel and (2) educational programs for operator personnel who wish to progress into technical or management positions.
The major activi-ties to support these corrective actions are listed talow.
duvelop a#
ional career path and rotational offshift assignment oppor-tunities within the shif t job progression for non-degreed personnel.
develon additfonal opportunities for lateral transfers and/or promotions for shift personnel into other functional areas where additional operating experience would be beneficial research available options and recommend a program leading to a bachelor's degree in engineering for licensed operators research Available options and recommend a program leading to a certifi-cate in nuclear science for operator personnel To implement some of the corrective actions ind majur activities, the licensee has established additional career path opportunities for licensed md non-licensed operator personnel by the new structure of the Operations organization described in Chapter 2 of Section !! of thri restart plan.
The new position of PBAPS Restart SER 5-5
4 operations support superintendent establishes an additional career progression opgortunity for licensed personnel beyond operating shift assignments. The new position of blocking coordinator provides licensed operators with an additional offshift assignment possibility.
The shift managers will also rotate to and from other management positions every 3 to 5 years to increase their under-standing of other organizations.
As more licensed operators become available for shift assignments, the licensee plans to open other career path opportunities for licensed operators who choose to accept offshift assignments in training, quality assurance, outage planning, and other site and corporate support functions that would benefit from the addi~
tion of more staff with operating experience.
The licensee has stated its commitment to support the career advancement of li-cersed operator personnel into positions requiring college degrees. A special program at a iocal university is being investigated for licensed operators who wish to earn a bachelor's degree in engineering.
The licensee intends to pro-vide suppirt in terms of tuition end paid leave for selected personnel who wish to pursue this educational opportunity.
The licensee is also investigating a continuing education alternative with the University of Maryland off-campus program in nuclear operations technology.
Both programs will offer licensed operators the opportunity to progress into plant and corporate management or professional assignments, including the position of shif t manager, f
The current plans for offshift rotation and career advancement depend greatly on the continuing development of available licensed personnel to take their places on the crews.
The licensee's plans to develop licensed personnel are adequate to satisfy these goals; however, attrition of licensed personnel and failure by candidates in training to become licensed will directly affect these I
goals.
On the basis of its review, the staff concludes that these actions are suffi-cient to meet the objectives of providing opportunities for offshift rotation and career advancement paths for licensed personnel.
5.4 Overall Conclusions On the basis of its review, the staff concludes that the licensee satisfies current requirements for shif t staffing per 10 CFR 50.54 and the facility Tech-nical Specifications for the startup and operation of one unit. Also, the licensee's plans for resource development are adequate to increase the number of licensed operators to allow two-unit operation.
6 CULTURAL CHANGE Chapter 4 (Section 4.2) and Chapter 5 (Section 5.3) of Section II of the plan for restart address the root cause stated as "the station culture, which had its roots in fossil and pre-TMI [Three Mile Islan?1 sperations, had not adapted to changing nuclear r6quirements." In evaluating sr.e licensee's respon es to this issue, the staff has used the knowledge gaf w] from the extensive body of theoretical and applled research in the fields of management and organization develoraent.
The staff also has relied on it) s:tperience in assessing utility nianagement as part of the licensing function of the NRC.
To address this root cause, the licensee has established the following four corrective action objectives:
(1) identify and comniunicate the cultural values wh ch yECo and PBAPs manage-ment are committed to supporting in the pursuit of nuclear excellence (2) provide training and team building support for management to live by these values (3) provide training and communication processes which support employee com-mitment to these values (4) ersure that management policies, programs and control systems support these cultural valuesSection I of the plan for restart (Sections 3.8 and 5.2) addresses aspects of corporate management's failure to recognize the developing severity of tne pro-blems at Peach Bottom; thus, not taking sufficient corrective actions.
The licensee has proposed to develop the management systems and managerial skills that will strengthen self-assessment and problem-resolution capabilities within the nuclear organization as one of its objectives to correct this problem.
The corrective actions being performed ;r planned to meet each of the specific corrective action objectives are evaluated in the sections that follow.
6.1 Identification and Communication of Cultural Values The licensee's management states in its restart plan that it is building nuclear cultural values on the themes of:
individual accountability for performance individual responsibility for safety and assurance of quality teamwork open and candid communications striving for excellence in all aspects of nuclear operational and organi-a zational performance PBAPS Restart SER 6-1
o O
To support these themes, licensee menagement has developed a va n ty of written communications as described in Sections 4.2.1 and 5.3.1 of Sectica II of the restart plan.
These communications include the nuclear group vision, mission ste% ment, and cbjcctives
+
plant objectives and goals to support auclear group objectives nuclear group management philosophy for assurance of quality
+
A variety of methods have been used to impart the contents of these communica-tions to all employees:
the written communications have been published in com-pany newspapers, they have been discussed at meetings, they have been included in general employee training, and they have been posted en bulletin boards.
In addition, Section 2.3 of Section I of the restart plan indicated that the Manager-Organization and Managtment Development Division will assist the nuclear management team to establish and implement specific objectives for change in terms of management and work bohaviors (i.a., cultural change) and to monitor progress toward meeting those objectives.
In supplementary communications, the licensee provided additional information on the process to be used to ensure the assimilation of the nuclear group's vision, mission, and values throughout
+he organization.
Behaviors identified as indicative of the nuclear group's vision, mission, and values will provide the basis for ensuring their assim-ilation.
This process will be initiated in early 1989. Another program to support cultural change is the program, "Managing Organizational Change" (MOC) implemented across the entire nuclear group and whose objective is to develop implementation strategies for moving the organization toward its desired cul-tural values.
The staff finds that the mitural values as described in the ple) for restart and in supplementary information have been identified and communicated.
6.2 Management Training and Team Building for Cultural Change 6.2.1 Managing for Excellence Evaluation The staff's review of Section I of the restart plan (Sections 3.8 and 5.2) and Section II of the restart plan (Sections 4.2.2 and 5.3.2) indicates that the licensee has initiated a number of activities related to management training and management team building.
The training activities include formal training (e.g., the "Managing for Excellence" (MFE) course), individual coaching / con-sulting by organizational development personnel, training in working with personnel management policier and managing meetings, and management modeling and visits to well-managed plants.
In supplementary communications, the li-censee provided additional information and i hyllabus of the manager /suptrvisor training program that will proceed from the MFE course and will focus on improv-ing organizational performance. Other training activities will be developed after the results of a training needs assessment survey have been considered.
The team-building activities include formal training, for example, the MFE course, the simulator team training, and the "Personal Effectiveness" (PE) course for non-operations department first-and second-line supervisors; inter-group meetings; a variety of site management meetings to discuss program de-velopment, progress, plans, and priorities, pBAPS Restart SER 6-2
On the corporate level, the licensee established 9
'zation and Management Development Division; this division has two secti....
J Organization Develop-ment and (2) Management and Professiona.1 Development.
ihis division is respon-sible for providing processes by wh:ch nuclear managers can identify blocks to goal achievement, develop strategies to move from the present sti.te to the desired state and monitor the progress of ti.. transition, and also to assist managers with monitoring and assessing the ' people manapment" aspects of or-ganization performance. A key element in this process is helping nuclear man-agers to specify the changes desired in terms of management and employee work behaviors and commurications and to routinely assess progress toward achieving the desired organizational values, performance, and culture.
This division is also responsible for developing the management potential of technically compe-tent individuals who currently do not fill management -.is and to assess man-agerial skills and abilities of present managers and
, ade their knowledge, skills, and competencies through a variety of trainit activities.
In addition to evaluating the plan for restart, the staff observed the MFE course and simulator team training course and interviewed several shift man-agers. The staff found, as stated in Inspection Report 50-277/278-88-10, that the training programs were effective in building basic managerial skills, inter-personal communication skills, and team work skills.
Furthermore, interviews with the shift managers confirmed earlier staff o5servations of the MFE course that the shift managers appear to be thoroughly committed to their new roles and to creating a healthy operational environment by promoting safety, quality, and scheduled in that order of priority.
The staff finds that the actions undertaken or proposed in the plan for restart are acceptable and should respond to staff concerns cited in Inspection Report 50-277/278-88-10 about the need for managers to reinforce the new behaviors, support improved communications, and promote understanding of personnel, manage-ment, discipline, and administrative policies.
However, the NRC staff will periodically monitor the training programs to determine whether they continue to be effective and whether management will continue to reinforce the new culture.
I 6.2.2 Shift Team Evaluations As a component of initiating a cultural change in the operations staff, the licensee formed new operat.ing crews under the leadership of the shift managers.
These crews were given training on a team basis to integrate the benefits of previous training in communications, attitude skills, and management into shift operations.
The NRC assessed all operating shift crews and the shift managers to measure-the following eight areas:
(1) overall Crew interaction (2) knowledge and use of Peach Bottom procedures (3) knowledge and use of Technical Specifications (4) crew communications (5) operator responsibility PBAPS Restart SER 6-3
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(6) supervisory ability (7) shift managers' abilities to supervise and lead the operating crews (8) shift managers' implementation of the emergency plan This assessment was performed to evaluate how effectively the shift manager and operating crews had been trained in the above areas to ensure that the operat-t ing crews performed acceptably for the safe restart of the Peach Bottom reactors.
L The staff reviewed the fidelity of and the similarity of the Limerick simulator to the controls at Peach Bottom; and, on the basis of this review, the staff i
determined that the Limerick simulator was suitable for assessment of the Peach Bottom operating crews, if the assessment areas would be limited to those described above.
(
The training staff at Peach Bottom provided the NRC staff with copies of the simulator training scenarios and an evaluation of hcw compatible these scenar-e los were for use on the Limerick simulator.
Information also was provided on the cause and effect of simulator malfunctions.
The NRC used the simulator training scenarios end other information to develop scenarios for the crew eval-r uations. A typical scenario contained at least one of each of the following events: a normal evolution, a component failure not expected to carie a scram, an instrument or controller failure not expected to cause a scram, and a major failure causing a transier.t.
The training staff at Peach Bottom provided the NRc with its team training learning objectives, its evaluation checklist, the.eministrative procedures that define the conduct of operations, and position descriptions for the shift l
manager and the other members of the operating crew.
From the information pro-vided, NRC operator licensing examiner experience, and other sources, the staff developed performance -*indards for making the assessments.
j Each operating crew was evaluated, in real time, during its performance of two i
simulator scenarios that the NRC staff had prepared.
i At the completion of the assessments in January 1988, the staff found that all
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shift operating crews satisfied the performance standards in all areas :5sessed.
L The shif t managers were effective in their roles as crew supervisors and lead-ers. They called the operators' attention to plant conditior.s, when appropri-ate; conducted shift briefings on existing conditions and planned actions; cor-rectly implemented the emergency plan, when warranted; and coordinated support from other organizations, as necessary. The performance standards, the assess-ments and their results are documented in Inspection Report 50-277/278-87-35.
Subsequent NRC evaluations of the shift operating crews were performed during i
August and September 1988 at the Peach Bottom simulator.
During these evalua-l tions, some performance deficiencies were found in the use of the plant trans-i ient response procedures, performance of surveillancs procedures, and in the implementation of the emergency plan. The licensee has committed to additional training to correct these deficiencies.
The staff will perform additional assess-ments to determine the ef fectiveness of this training.
The results of the additional assessments will be needed to make a final assessment of readiness for restart, i
6.3 Employee Training ard Communications for Cultural Change The staff's review of Section II of the restart plan (Sections 4.2.3 and 5.3.3) indicates that the licensee has undertaken a wide variety sf activities related to employee training and communications to effect cultural change.
The major activities include a 6-week attitude assessment and training nrogram for licensert operators - the course, "People - The Foundation of Excellence" (PFE); an 8-day shift team training at the simulator; a 2-week attitude training program for non-licen.ad operators - the course, "Personal Effectiveness" (PE); an employee /
management communication program, "Tell It to the Vice-Dresident;" an employee involvement program (referred to as PB-Team): an organizational survey - the "Prcductivity/ Quality Profile" and feedback process; all-employee me tings; o d an emphasis on management by walking around (MBWA).
In addition to evaluating the plan for restart, the NRC staff observed parts of the PFE and the simulator team training courses and interviewed several operators who had completed this training, as well as individuals responsible for develop-ing the training programs and individuals responsible for selecting the operators f
who would participate in the program.
The staff's eve M tions, based on these observeLions and interviews, are given in Inspection Report 50-277/278-83-10.
The stvff determined that the training programs were effective in providing operators with personal insights, interpersonai skills, and effective team work and communication skills.
In addition, the interv % s confirmed that oparators apparently understood the consequences of inattentiviness to duty and it: cffect on plant safety and, furthermore, unde ntood their oialigations to their in-dividual license to actively monitor plant conditions, etc.
To support the knowledge and insight gained from the formal training course, 4
the licensee has developed a followup training program entitled "Interaction" that will include appropriate elements of the pFE and MFE courses.
In audi-tion, progression training for operators will include approprirte elements of tre PFE and MFF courses. Analysis and review of the knowledge and interper-sonal skills and abilities needed at each level of progression will help deter-mine which elements of the formal training course should be included in the progression training. The process will accommodate new and transferred oper-ators entering the progression cycles.
The analysis and review will begin in the fourth quarter of 1988; a target period to begin phased-in implumentation of the appropriate curriculum elements for each level in the prog-ession is the second quarter of 1969.
This process will ensure proper coverage of interper-sonal skills trainitg for all current and future operators.
To support the phased-in implementation of interpersonal and professional ef fectiveness train-ing in the progresstun, continuing, and raqqalification training cycles, i a-supervisory plant personnel outside the operatic.1s chain will participate.n a program similar to the followup training.
This program will add to the frame-work, language and : kill: " support of c0tural change.
The licensee intends to begin implementing this training in the second quarter of 1989 I
1 On the basis of its review of the plan for restart and on its observations and interviews, the staf f firids that many of the activities undertaken to support employee training and communications for cultural change have been appropriate.
Furtherm ue, the licensee's actions to follow up on the initial training pro-grams and to include elements of such programs in progression training should help to ensure that the requisite cultural changes will occur.
Because the training programs and communications activities are significant actions devel-oped in direct response to the issues raised in the shutdown order, the NRC staff will monitor activities over a period of time to determine that these activities have produced positive results.
6.4 Human Resource Practices, Policies, and Programs of Management 6.4.1 Personnel Evaluations In Section II of the restart plan (Section 5.3.4), the training course for man-agers and supervisors is outlined; the course will preside instruction o.1 all phases of performance appraisal, including writing performance statidards and effective performance evaluations, effective praise and reprimand, and practice in writing and presenting clear goals.
In supplementary information, the licensee has stated that, before restart, managers and supervisors will be trained on how to conduct face-to-face performance appraisals.
The training, which was developed by staff of the Management and Professional Development Section, is being conducted by outside consultants.
The NRC staff finds the licensee's response acceptable.
The licensee also has stated that all employees at Peach Bottom will discuss their performance face to face with their immediate supervisors.
In the dis-cussion., performance standards will be established for each employee.
In addi-tion to reviewing employee performance annually, as is required, the plant manager will review performance face to face at nominal 6-month intervals with each emplovee reporting directly to him; the plant manager will provide more frequent opportunities for reviewing the performance of management staff and for taking corrective actions required in a timely manner. Management personnel have been instructed to discuss performance with their employees as often as needed.
In supplementary information, the licensee has provided a copy of a written message from the site Vice President that was sent to all employees to assist them in understanding their role in the performance appraisal process. The o.essage emphasizes how important it is that employees understand the purpose of perfor-mance appraisals, the value of an employee preparing for appraisals, the employee's contribution to the appraisal, and the employee's understanding of what is expected in the future.
The staff finds that the licensee's activities in the area of strengthening its performance appraisal system are acceptable.
6.4.2 Disciplin.ry Policy In Section II of the restart plan (Section 5.3.2), the licensee has committed to revise disciplinary policy to ensure that its management will be provided with the appropriate authority to require employee performance standards con-sistent with nuclear requirements. The licensee has stated that training on these revised disciplinary policies and work rules will be completed for the plant manager through shif t-nanager levels before Peach Bottom restarts.
l training was developed by the Director of Management and Professional Develop-ment of the nuclear group and by the personnel administrator at Peach Bottom.
The personnel administrator will conduct the training.
The staff finds this response acceptable.
The licensee also has stated that the new disciplinary guidelines and proce-dures will be issued to all employees in the handbook, "You and Your Company."
The handbook is being revised and will be reissued to all employees.
The handbook is being revisad and will be reissued to all employees.
Supple-mentary information provided by the licensee states that when the revised handbook is distributed, employees will be required to sign a statement that they have received the handbook.
In addition to the handbook, all employees have been given copies of the revised disciplinary guidelines and grievance procedures. The licensee has provided a copy of the memorandum from the Vice-President, PBAPS, to the senior staff that transmits these guidelines and procedures. The memorandum directs the senior staff to (1) provide all per-sonnel with the material, (2) ensure that employees are familiar with the grievance procedures, and (3) direct any questions on the policies to the PBAPS Personnel Achinistrator.
In this supplementary information, the licensee has also committed to keeping track of the employees' questions directed to the plant personnel administrator for a period of 90 days following the distribu-tion to assers the employees' understanding of the procedures and guidelines and determine the need for document revision.
The staff finds that these are acceptable measures for ensuring that disciplinary policy is disseminated among Peach Bottom employees.
i The licensee also has described the tracking procedure that has been developed to ensure that each step in the grievance process has been performed and the generic schedule to ensure timely resolution of grievances.
The handbook, "You and Your Company," also instructs nmployees te direct questions or concerns ragarding grievances to their immediate supervisors.
The revised nuclear group grievance procedures require first-level supervisors to respond to employee concerns within 20 days.
If this time period is not met or if the employee finds the response unsatisfactory, the employee can present the concern to suc-cessively higher levels of supervisors up to and including the department head; for example, for operations, this would be the Vice President-Peach Bottom Atomic Power Station.
Each level is required to respond in a timely manner, not to exceed 20 days.
The employee is responsible for keeping track of the grievance up to this point.
If the employee's concern is still not resolved.
the employee can present a formal grievance to the licensee's Personnel and Industrial Relations Department.
The Manager of Industrial Relations tracks each grievance submitted to the Personnel and Industrial Relations Department i
by maintaining a file that indicates its status.
This file is periodically reviewed by the licensee's Manager of Industrial Relations to ensure timely i
resolution of grievances.
The licensee also has stated that a consultant has been retained to review the licensee's industrial relations protocols.
This effort is expected to be com-pleted in November 1988.
The comprehensive review will result ir a revised set of protocols that will form the basis for discipline and grievance-handling procedures for the plant. Managers and supervisors will be trained in 1989, after the protocols have been developed.
The licensee has made a commitment to P
provide the results of the review before restart'.
This process and its track-ing system should be followed over time by the licensee to ensure its continued implementation.
6.4.3 Career Paths The licensee discussed a number of long-and short-term program activities for management and professional development in Section II of the restart plan (Sec-tion 3.8.2).
Planned off-shift rotations were part of the licensee's review o' its career path program for operators.
The licensee stated that operations personnel going on rotation will be assigned to positions where their opera-tions experience will add to the organization's capabilities, This job rotation is designed to increase the experience level of the entire PECo nuclear group.
In a similar light, shift managers will rotate approximately every 4 years, bringing their control room experience and supervisory training to other parts of the organization. The licensee states that this will help other work groups understand operations requirements, increasing the ability of shift managers to work well with operations personnel and support operations activities.
I The staff finds these mechanisms constitute acceptable means for providing both operations and managerial personnel with the tools to pursue career paths
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throughout the Peach Bottom organization.
The licensee also has provided the training syllabus for the 27-day course, "People - The Foundation of Excellence" (PFE), which was given to the currently Itcensed operators and shift technical advisors at Peach Bottom.
The course is divided into four units of study that incorporate fundamental core elements of supervisory and leadership training.
The course begins with training in per-sonal insight and hterpersonal skills and builds up to, and concludes with, group dynamics and conflict management. The licensee states that these aware-ness skills constitute the basic building blocks of supervisory behavior and leadership skills required for executing licenced operator responsibilities and, ultimately, shift supervisor responsibilities.
The staff has reviewed this syllabus and has observed the training in progress at Peach Bottom during its interim and final inspections of the rehabilitation program. The staff has concluded that this training provides interpersonal and self-awareness skills that would prove of value to operators, both In their current positions and in career paths they may pursue throughout the organiza-tion.
In its restart plan, the licensee has also identified a number of short-term and long-term plans for career development that include assessments of manag-erial skills and abilities, development of technical personnel for promotion to supervisory and management positions, an improved nuclear performance appraisal program, and the establishment of individual development plans.
The staff finds these methods for developing career paths acceptable.
- However, the staff expects to review the mechanisms both in its inspections before restart and over a longer period of time to ensure the licensee continues to implement them.
6.4.4 Shift Rotation In Section II of the restart plan (Section 2.2.2), the licensee states that the shift rotation schedule has been switched from a reverse or backward rotation to a forward rotation. This change was made as the result of an analysis by a task force of operators and management and was facilitated by Circadian Tech-nology, Inc.
This consultant also.had a role in the PFE training course for operators.
During the staff's interviews with operators as part of the interim and final inspections of the rehabilitation program, operators stated that they vere generally satisfied witn the change in the direction of the shift retation i
ard reported that they felt less fatigued.
A number of those interviewed indi-cated that they learned several coping mechanisms for dealing with the fatigue inherent in shift work.
The staff finds forward rotation an acceptable mechanism for reducing the fatigue associated with shift rotation.
This type of rotation has been ex-tensively researched by a n eber of specialists in circadian rhythm technology and has generally been found to be less fatiguing over long periods.
6.4.5 Control of Overtime Section II of the restart plan (Section 2.2.2) ar.d supplementary information provided by the licensee state that the licensee has as its goal to minimize the use of overtime through a number of initiatives that are currently in prog-ress.
These initiatives are as follows:
(1) The licensee plans to staff the Peach Bottom operations groups with seven licensed operators on a six-shift rotation basis.
This exceeds the shift staffing required by the licensee's Technical Specifications, which is two SR0s and three R0s.
(2) The licensee has made a long-term commitment to increase the number of licensed operators at Peach Bottom.
(3) Staffing and work assignments for plant personnel will provide adequate coverage so that routine use of overtime becomes unnecessary. The objec-tive will be to have shif t operations personnel work an 8-hour day, 40-hour week while the plant is operating.
However, overtime work may be required on a temporary basis during periods of extended shutdown for refueling or during periods when major modification or maintenance is taking place.
(4) The licensee submitted a proposed revieicn to the Peach Bottom Technical l-Spet'fications on September 7, 1988, designed to ensure control of the over+.ime worked by R0s and SR0s.
The licensee has stated that the pro-posed revision is incorporating the guidance in the NRC's current recom-mendations on the overtime issue as contained in its proposed updated policy statement. The licensee also has stated that the increase in staffing, basic changes in work distribution philosophies, performing maintenance on all threo shifts rather than on day shift only, and scheduling routine maintenance throughout the year instead of waiting PBApS Restart SER 6-9
- o e i
until outages to perform such tasks should eliminate the need for exces-sive overtime.
The blocking work group is also tasked with reducing the overtime demands on operators.
The staff finds these methods acceptable for reducing unnecessary and excessive overtime.
However, the staff will review the licensee's proposed revision to its Technical Specifications to ensure that appropriate controls are established, i
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t 7 CONCLUSION
.i In Sections 3, 4, 5, and 6 of this SER, the staff evalutted the licensee actions to correct the four root causes of the conditions that led to the issuance of the NRC order of March 31, 1987, requiring that the Peach Bottom facility be shut down. The staff concluded that the root causes identified by the licensee, listed below, adequately characterize the problems leading to the order.
(1) Failure of'the Corporate Organization To Identify and Correct the Problems i
at Peach Bottom:
Tite licensee has restructured the organization to focus management involvement on nuclear operations, put in place new key senior 1
executives with demonstrated success in managing similar organizations, and strengthened its self-assessment and independent assessment capabili-ties. The staff concludes that these measures appropriately address the root cause.
(2) Inadequate leadership at the Peach Bottom Site:
The licenseo has a new site management team from both inside and outside the licensee organization with strong leadership and managemer,t skills and has restructured the site i
organization to provide effective sapervision and ensure accountability for all functions. The staff concludes that these ue&sures ate acceptable i
to address the root cause.
I (3) Failure To Initiate a Timely Licensed Operator Replacement Training Program:
L The licensee has raised the entr,-level standards and starting salary to
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ensure a sufficient number of qualified applicants for licenses and has,
i provided for short-term and long-term rotational and developmental posi-tions for licensed operators. More operators have been licensed since the order was issued than the number with licenses that had expired. The staff j
concludes that the licensee's plan to develop adequate licensed operator resources is acceptable.
In addition, when t.-aining activities are con-
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pleted for a sufficient number of the operators currently holding restricted I
licenses, then the licensee will have a sufficient number of operators to operate the second unit.
l (4) A Station Culture That Had Not Adapted to Post-TMI Changing Nuclear hequirements:
The licensee has identified and communicated new cultural values; has provided licensed operator anc' management training and fos-tered team building to support these values; and has developed management policies, programs, and control systems to support these values. The staff concludes that licensee actions to improve the culture are appropriate to
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address the root cause.
t On the basis of its review and evaluation, the staff concludes that the revised l
plan for the restart of Peach Bottom Atomic Power Station submitted on April 8, i
1988, as clarified by supplemental information listed in Appendix B, meets k
Requirement V.C. of the March 31, 1987 Order Suspending Power Operations and Order To Show Cause that the licensee submit a detailed and comprehensive plan l
.and schedule to ensure that the facility will be operated safely and comply PBAPS Restart SER 7-1 l
l l
.____,_,,_.__-_,.__,___..______-___a
with all requirements including station procedures.
The NRC staff will con-tinue to monitor the effectiveness of the implementation of this plan by the licensee.
For example, the NRC staff will conduct an integrated assessment team inspection after the licensee has certified to the NRC the readiness of the Peach Bottom facility for restart based on a self-assessment and a scheduled evaluation by the Institute of Nuclear Power Operations.
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L APPENDIX A CHRONOLOGY June 12, 1986, letter, V. Stello, NRC, to J. L. Everett, III, PECo, regarding NRC assessment at Peach Bottom Atomic Power Station.
March 31, 1987, V. Stello, NRC, to PEco, Order Suspending Power Operation and Order to Show Cause.
April 6,1987, J. S. Kemper, PECo, to T. E. Murley, NRC,
Subject:
Order Sus-pending Power Operation, Peach Bottom Atomic Power Station Units 2 and 3.
l April 20, 1987, J. L. Everett, PECo, to V. Stello, NRC, regarding the order tn show cause issued March 31, 1987.
August 7,1987, letter, J. H. Austin, PEco to W. T. Russell, NRC, transmitting the "Commitment to Excellence Action Plan."
August 24, 1987, letter, W. T. Russell, NRC, to J. H. Austin, PEco, requesting additional information to CTE plan.
September 11, 1987, letter, W. T. Russell, NRC, to J. H. Austin, PECo, request-ing additional information to CTE plan.
September 28, 1987, letter, J. H. Austin, PEco, to W. T. Russell, NRC, resr.and-ing to requests for information to CTE plan.
October 8, 1987, letter, W. T. Russell, NRC, to J. H. Austin, PEco, noting con-cerns and suspending staff review.
November 19, 1987, letter, E. J. Bradley, PEco, to T. E. Murley, NRC, trans-mitting application for amendment of operating Itcenses OPR-44 and DPR-56 to l
reflect organization changes.
November 25, 1987, letter J. H. Austin, PEco, to W. T. Russe'1, NRC, submitting i
"Plan for Restart of Peach Bottom Atomic Power station,"Section I, "Corporate Plan."
December 11,1987,. letter, V. Stello, NRC, to J. H. Austin, PEco, transtaitting performance assessment, December 18, 1987, letter, W. T. Russell, NRC, to J. W. Gallagher, PECo, for-warding the amended Systematic Assessment of Licensee Performance Report for February 1, 1986 through May 31, 1987.
c F
Appendix A
December 24, 1987, letter, W. T. Russell, NRC, to J. H. Austin, PEco, discussing restart plan review,Section I.
L January 29, 1988, letter, J. H. Austin, PEco, to W. T. Russell, NRC, tran W t-i ting a report by the Institute for Nuclear Power Operations January 11, 1988.
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February 12, 1988, letter, J. Everett, PEco, to W. T. Russell, NRC, transmitting "Plan for Restart of Peach Bottom Atomic Power Station",Section II, "PBAPS Action."
March 18, 1988, letter, J. F. Paquette, PEco, to W. T. Russell, NRC, on appoint-ments of PECo personnel.
April 8, 1988, letter, J. F. Paquette, PECo, to W. T. Russec, (MC, transmitting Revision I to Sections I and II of the plan for restart and a schedule of major activities in the revised plan.
April 8,1988, letter, C. A. McNeill, PECo, to W. T. Russell, NRC, information regarding Peach Bottom quality control shif t operations monitorinf.
May 18, 1988, letter, C. A. McNeill, PECo, to W. F. Kane, NRC, transmitting Inspecticn Repert 50-277/278-G8-10 for the routine resident safety inspection from March 12 to April 22, 1988.
May 31, 1988, letter, J. W. Gallagher, PEco, to R. M. Gallo, NRC, transmitting additional information regarding trainir,g of plant operators on changes to plant procedures.
June 1, 1988, letter. W. T. Russell, NRC, to C. A. McNeill, PECo, requesting additional information.
June 22, 1988, letter, R. E. Martin, NRC, to W. M. Alden, PECo, transmitting license amendments on the organizational structure.
July 8,1988, letter, V. Stello, NRC, to J. F. Paquette, PEco, regarding performance assessment.
July 22, 1988, letter, C. A. McNeill, PECo, to W. T. Russell, NRC, responding i
to request for information regarding plan for restart.
August 9,1988, letters, J. M. Taylor, NRC, to 36 individual PECo employees, issuing enforcement actions.
I August 10, 1988, letter, J. M. Taylor, NRC, to J. F. Paquette, PEco, issuing enforcement action to PECo.
August 15, 1988, letter, J. A. Basilio, PEco, to R. Martin, NRC, providing additional information regarding plan for restart.
1 August 15, 1988, letter, C. A. McNeill, PECo, to W. T. Russell, NRC, describing PEco's restart self-assessment program.
l I
Appendix A
)
August 22, 1988, letter, J. A. Basilio, PECo, to R. Martin, NRC, providing additional infotmation regarding plan for restart.
August 23, 1988, letter, J. W. Gallagher, PECo, to W. T. Russell, NRC, provid-ing copies of the restart power testing program.
September 7, 1988, J. W. Gallagher, PECo, to W. T. Russell, NRC, transmitting "Peach Bottom Atomic Power Stattor. Restart Power Testing Program."
September 8,1988, letter, J. F. Paquette, PEC9, to J. Lieberman, NRC, trans-mitting reply to notice of violation and proposed imposition of civil penalty.
Se.ntembe r 20, 1988, J. A. Basilio, PECo to R. E. Martin, NRC, transmitting additional information regarding the pion for restart.
October 10, 1988, letter, J. A. Basilio, PECo, to R. E. Martin, NRC, providing information in response to issues raised during meeting of Scptember 29, 1988.
Appendix A
l o,
APPENDIX B BIBLIOGRAPHY ANSI N18.1-1971 American National Standards Institute, Selection and Training of Nuclear Power Plant Personnel; March 8, 1971 ANSI /ANS-3.1-1981, ANSI /American Nuclear Society, American National Standard for Selection and Training of Nuclear Power Plant Personnel; January 17, 1978.
Federal Register, Vol. 52, No. 67, p.11386 (52 FR 11396), Philadelphia Electric Co., Peach Bottom Atomic Power Station, Units 2 and 3; Order Suspending Power Operation and Order to Show Cause; U.S. Nuclear Regulatory Commission; April 8, 1987.
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Appendix B i
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APPENDIX C PUBLIC COMMENTS AND NRC ltESPONSE F
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FBAPS Restart SER Appendix C i
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o TABLE OF CONTENTS Page C.)
INTRODUCTION.................................................
1 C.2 L I S T O F C 0KM E N T E R S...........................................
1 C.3
SUMMARY
OF COMMENTS.......................,..................
2 C.4 NRC RESPONSE TO COMMENTS....................................
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PBAPS Restart SER iii Appendix C t
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APPENDIX C PUBLIC C0HMENTS AND NRC RESPONSE C.1 INTRODUCTION Meetings were held on the dates and locations noted below to provide the public the opportunity to comment on the revised "Plan for Restart of the Peach Bottom Atomic Power Station," which was submitted to the U.S. Nuclear Regulatory Com-mission (NRC) on April 8,1988. This appendix summarizes those comments and provides the NRC responses to them. Comments were provided at public meetings on September 24 and November 4, 1987, on the licensee's earlier plan, which was superseded by the revised plan for restart.
The NRC staff has not responded to the earlier comments, except indirectly if they were similar to those summar-ized in this appendix.
Fawn Grove, Pennsylvania May 16, 1988 Pylesville, Maryland May 16, 1988 Quarryville, Pennsylvania May 17, 1988 Many comments were similar in nature and were thus grouped into appropriate categories to be covered by a single response.
For individual comments that covered multiple categories, the reader is directed to various section.s in this safety evaluation report (SER) for a complete response.
The summarized com-ments do not reflect judgment on what was said by the commenters; they merely attempt to capture what was said in language close to that used by the individ-ual commenters.
Identical comments made by the same people at more than one meeting are treated as one comment and are only listed once.
Section C.2 lists the names of the commenters and their residences.
The com-menters are numbered in order of appearance and in the order of the meetings as listed above.
Section C.3 provides a summary of the comments with a key to the response number for each comment. Section C.4 provides the staff's responses to specific comments.
C.2 LIST OF COHMENTERS Fawn Grove. Pennsylvania, May 16, 1988 1
Margaret Dardis, Newtown, Pennsylvania i
2 Allan Young, Middletown, Pennsylvania l
3 David Grove, New Park, pennsylvania 4
John Tucker Dallastown, Pennsylvania 5
Francis Boltz, Sr., Fawn Grove, Pennsylvania 6
Jack Winzenried, Delta, Pennsylvania 7
Bob Hughes, Fawn Grove, Pennsylvania 8
Judy Williams, Delta, Pennsylvania PBAPS Restart SER 1
Appendix C
Pylesville, Maryland, May 16, 1988 9
Ernest Eric Guy 11, Nottingham, Pennsylvania 10 George. Field, Street, Maryland 11 Joanne Parrott, Harford County, Maryland 12' Jean Ewing Darlington, Maryland 13' Ginna Bennett, Havre de Grace, Maryland 14 John Casey, Bel Air, Maryland 15 J. Michael Pratt, Virginia 16 David Watson, Street, Maryland 17 Rev. Jeffrey D. Wilson, Street, Maryland 18 Patricia Jeanschild, Delta, Pennsylvania 19 Kenneth J. Trzeinski, Street, Maryland 20 Pat Birnie, Columbia, Maryland 21 Pat Lane, Baltimore, Maryland 22 Greg Skinner, Norrisville, Maryland 23 William G. Shimek, Darlington, Maryland 24 Ernest Eric Guy 11, Nottingham, Pennsylvania 25 Stan Kohler, Pylesville, Maryland 26 Barbara A. Risacher Harford County, Maryland 27 Bryan Merryman, New Park, Pennsylvania Quarryville, Pennsylvania, May 17, 1988 28 Fred Moser Quarryville, Pennsylvania 29 Bernard Raftovich, Holtwood, Pennsylvania 30 Wayne Dobson, Douglassville, Pennsylvania 31 Leonard Peoples, Quarrysille, Pennsylvania 32 Edward Bailey, Conestoga, Pennsylvania 33 Eric Epstein, Harrisburg, Pennsylvania 34 Frances Skolnick, Lancaster, Pennsylvania 35 Ernest Eric Guy 11, Nottingham, Pennsylvania 36 Robert Hughes, Fawn Grove, Pennsylvania 37 H. Eugene Carrigan, New Providence, Pennsylvania 38-Richard Ryan, Quarryville, Pennsylvania 39 Mary Corthouts West Lampeter, Pennsylvania 40 Rodney Lingo Holtwood, Pennsylvania 41 Margaret Dardis, Newtown, Pennsylvania 42 Susan E11enberg, Holtwood, Pennsylvania 43 Donald Kemper, Quarryville, Pennsylvania 44 Phyllis Gilbert, Philadelphia, Pennsylvania 45 Mitzt Samples, Little Brittan, Pennsylvania 46 Marie Inslee, Downington, Pennsylvania C.3
SUMMARY
OF COMMENTS 4
Commenter Comment 1
Wants public debate on startup issues.
C.4.1 2
Should not start up with present management in control.
C,4.2 Alleges past history of inadequate welder examinations.
Appendix C
[-
Alleges poor welding practices.
C 4.6 Alleges inadequate shielding was provided for welders.
C.4.6 3
In favor of restart.
C.4.2 4
Believes new management is capable of safely operating C.4.2 plant.
5 Feels confident of new management.
C.4.2 6
Believes new management and personnel will operate C.4.2 plant safely.
7 In favor of restart.
C.4.2 8
Confident of new management.
C.4.2 9
Desires information on accidental releases of radiation at Peach Bottom (amounts), and what is "safe."
C.4.7 How do cancer, stillbirth, and birth defect rates near Peach Bottom compare with national averages?
C.4.8 Concerned that monetary issues at plant will take back seat to safety.
C 4.11 How does warm wat r affect fish in the Susquehanna River?
C.4.9 10 Does not feel management change has had any effect.
C.4.2 11 Wants INPO [ Institute of Nuclear Power Operations) evaluation C.4.11 before startup.
Alleges improprieties concerning security guards (sleeping at their posts, drinking alcohol, long hours, inadequate staffing, inadequate breaks, poor factitties, etc.)
C.4.5 Alleges Susquehanna River water quality reports were altered to downgrade radiation levels.
C.4.13 Alleges contaminated items were stored in faulty containers.
C.4.19 Concerned about quality of maintenance actions being per-formed by PECo personnel in light of the illicit drug activity at the plant.
C.4.4 Concerned about lack of fire drills with local fire-fighting C.4.14 companies.
Appendix C
lt What is probability of r.ontainment failure in event of core melt - 90 percent?
C.4.15 Mark I containment is not safe.
C.4.15 Concerned about cracks in the concrete, piping, and welds.
C 4.11 Concerned about cost of cleanup of the plant after decommissioning.
C.4.16 13 Concerned about dangers of plutonium and cost of cleanup.
C.4.16 14 Confident of PEco management.
C.4.2 15 Management is committed to do a good job.
C.4.2 16 Peach Bottom problems need further attention by NRC and PECo to correct and prevent recurrence.
C.4.3 Drugs still a problem.
C.4.4 Concerned about Mark I containment.
C.4.15 17 Confidence in PEco has been restored.
Delaying startup further would demoralize employees and reverse gains made.
C.4.3 18 Alleges some PEco employees are not fit to operate plant (brag about heavy drinking and taking drugs). Poor attitude toward work exists.
C.4.4 19 What assurance is there that management will not deteriorate in the future?
C.4.2 20 Wants adjudicatory hearing to address restart issues.
C.4.1 l
Peach bottom has unsafe design and should not restart unless redesigned.
C.4.12 l
l New emission monitoring device should be installed with public access to monitoring information.
C.4.7 Wants comprehensive health studies around Peach Bottom.
C.4.8 Nuclear plants are not economical.
C.4.17 Doubts ev4cuation possibility.
C.4.18 Concerned about radwaste storage. Wants spent fuel trans-ferred to dry cask storage.
C.4.19 21 Concerned about amounts of radwaste.
C.4.19 Concerned about Mark I containment.
C.4.15 I
Appendix C
Generic problems are addressed too slowly, thus causing lack of faith in NRC.
C.4.20 22 More emphasis needs to be placed on training with local fire agencies.
C.4.14 23 Concerned about Mark I containment.
C.4.15 24 Duplicate of comments by commenter 9.
C.4.7, 8.11,9 l
25 Wants assurances of per:,onnel reliability, no futura l
mechanics 1 failures, and no spurious radioactive releases or else do not start up.
C.4.3 26 Wants Mark I containment issue resolved before startup.
C.4.15 Desires PECo response to INPO letter regarding unanswered General Electric service letters and outstanding work orders.
C.4.10 Wants Advisory Committee on Reactor Safeguards to do safety analysis of Peach Bottom before restart.
C.4.12 27 Encouraged by now management's commitment to safety.
C.4.2 l
28 In favor of restart (cites employment, taxes, and C.4.2 recreation provided by plant.
Ecologically sound.)
l 29 Plant was shut down because of poor management. This has C.4.2 been corrected.
Plant should now restart.
l 30 Sees positive changes in management and employee attitudes.
C.4.2 l
31 Restart plan is adequate and should be accepted.
C.4.2 l
32 PECo etcployees have genuine commitment to excellence.
C.4.3 33 Concerned about INPO letter of October 1987, especially laci, of accountability and excessive open maintenance items.
C.4.10 I
Concerned about INFO president's criticism of January 11, l
1988, of PEco's management and reorganization plan.
C 4.2 Concerned about drug use at plant.
C.4.4 Illegal to consider economic benefits to community in considering restart.
C.4.17 Peach Bottom is not needed.
C.4.17 Concerned about security practices at plant (long hours for guards, no meal breaks, no rotation, etc.).
C.4.5
']
Appendix C l
l
Wants hearings on restart issues.
C.4.1 34 Concerned whether PEco has resources to carry out restart C.4.10 plan.
Concerned that NRC is too cozy with nuclear industry to regulate it.
C.4.20 Plan does rot address containment, spent fuel reracking, and adequacy of offsite radiation monitoring equipment.
C.4.21 Wants hearings on proposed amendments of the Technical Specifications.
C 4.1 What are NRC's restart criteria?
C.4.22 35 Duplicate of comments by commenter 9.
C.4.7, 8,9,11 36 Environmental monitoring at plant began in 1966 and results C 4.7 are available in library.
Personnel changes will improve operation at Peach Bottom.
C.4.3 37 PECo has vested interest in Peach Bottom and would not want C 4.2 an accident destroying it and its customers.
1 i
Peach Bottom is needed to prevent acid rain and minimize C.4.17 need to import oil.
38 In favor of restart.
C.4.2 39 Concerned about plant being on a geological fault that had two earthquakes in last 10 years.
C.4.23 40 In favor of restart.
C.4.2 41 Concerned about provision of the evacuation plan to use schools as shelters (dism1> sing the children) in violation of Pennsylvania guidelines.
C.4.18 42 In favor of restart.
C 4.2 43 In favor of restart.
C.4.2 44 Wants evidentiary hearings on restart.
C.4.1 Concerned about Mark I containment.
C.4.15 Concerned about nuclear waste.
Appendix C
t Concerned about provision of the evacuation plan to use schools as shelters (disraissing the children) in violation of Pennsylvania guidelines.
C.4.18 Wants independent safety investigation before startup.
C.4.12 45 Concerned about plant decommissioning.
C.4.16 46 Nuclear power is unsafe.
C.4.12 C.4 NRC RESPONSE TO COMMENTS Comenter Comment C.4.1:
Requests For Public Hearings 1
Wants public debate on startup issues.
20 Wants adjudicatory hearing to address restart issues, i
33 Wants hearings on restart issues.
34 Wants hearings on proposed amendments of the Technical i
Specifications.
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i 44 Wants evidentiary hearings on restart.
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Response
Numerous meetings have been held with the licensee, State and local governmen-tal groups, and the public since the shutdown of Peach Bottom station to pro-vide all interested parties an opportunity to comment on the deliberations on the station.
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The Commonwealth of Pennsylvania and the State of Maryland providec comments dated July 12 and May 26, 1988, respectively. These comments were forwarded to the licensee for consideration, and the licensee's submittal of July 22, 1988, l
provided an itemized response to the State of Maryland's coments.
In addition to its comments, the Commonwealth of Pennsylvania has chosen to l
intervene in certain of the PBAPS proceedings by filing a "Petition To Inter-i vene, Request for Hearings and Coments Opposing No Significant Hazards Con-sideration" on January 22, 1988. This petition concerned the licensee's appli-l cation for amendment of the factitty's Technical Spectrications in regard to I
the administrative controls on the licensee's organizational structure. The Commonwealth supplemented this petition on August 24, 1988, which included seven contentions. The Comonwealth and the licensee have recently agreed to a postponement of a formal response to these contentions, before the Atomic Safety and Licensing Board appointed for this matter, until November 7, 1938, pending the potential resolution of these issues by the partin before that date.
Appendix C L
l Commenter Comment C.4.2: Adequacy of Management 2
Should not start up with present management in control.
3, 7, 28, In favor of restart.
38, 40, 42, 43 l
4 Believes new management is capable of safely operating plant, j
5 Feels confident of new management.
6 Believes new management and personnel will operate plant safely, 8
Confident of new management.
10 Does not feel management change has had any effect.
l 14 Confident of PEco management.
15 Management is committed to do a good job.
19 What assurance is there that management will not deteriorate in the future?
27 Encouraged by new management's commitment to safety.
29 Plant was shut down because of poor management. This has been corrected.
Plant should now restart.
30 Sees positive changes in management and employee attitudes.
l 31 Restart plan is adequate and should be accepted.
33 Concerned about INPO presiden;'s criticism of January 11, 1988, of PEco's management and reorganization plan.
37 PECo has vested interest in Peach Bottom and would not want an accident destroying it and its customers.
Response
Several versions of the PEco plan for restart have all addressed management.
The INP0 report of January 11, 1988, was highly critical of an interim version of the plan for restart, and INP0's conclusions and recommendations were simi-lar to concerns raised by the NRC during its review of the several versions of the plan.
l The initial corrective action plan was submitted by the licensee in August 1987 and was followed by an NRC staff position in October 1987 that stated that the plan failed to address a fundamental staff concern.
In November 1987, the li-censee submitted Svetion I of its revised corrective action plan for restart in PBAPS Restart SER 8
Appendix C i
i 4
tesponse to the issue raised by the staff.
In February 1988, the licensee com-pleted the plan with the submittal of Section II, which addressed actions speci-fic to the onsite organization and the plant.
2 The licensee's actions in response to the INPO report were discussed in its 3
letter of April 8,1988, which submitted Revision 1 of the nian for restart.
The licensee indicated that it had incorporated the second and third recommen-l dations of the INPO letter into the revised plan. These recommendations dealt i
with minimizing actions that bypassed or undermined line manag$ ment and with es',ablishing accountability for the unsatisfactory situation that had developed I
4 over a period of years.
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The licensee also stated in this letter that an independent consultant had been 4
retained to respond to INPO's first recommendation that a detailed analysis of the licensee's internal investigation material De developed.
i By letter dated March 4, 1988, the staff requested that any information the l
licensee provided to INPO in.esponse to the issues in the INPO report also be provided to the NRC and that the NRC be apprised of the results of INPO evalua-J tions before restart, t
The NRC will complete its evaluation of Peach Bottom's readiness for startup i
{
only after all appropriate information, including the rasults of the INPO evalu-i ations, have been provided by the licensee.
Since the staff is concluding that the licenset's plan for restart is acespt-f able, subject to the conditions stated in this report, no further response is provided to the comments listed above that generally expressed satisfaction
}
with the status of Peach Bettom.
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l Commenter Comment C.4.3:
Readiness for Restart
(
t 16 Peach Bottom problems need further attention by NRC and PECo to correct and prevent recurrence.
17 Confidence in pECo has been restored. Delaying startup further would demoralize employees and reverse gains made.
25 Wants assurances of personnel reliability, no future mechanical f
failures, and no spurious radioactive releases cr else do not j
start up, t
32 PEco employees have genuine commitment to excellence.
36 personnel changes will improve operation at Peach Bottom.
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Response
l The issues identified by the NRC as restart items have been or will be evalu-
[
ated by the NRC to verify that they have been adequately resolved.
The NRC
[
plans to perform a systematic assessment of licensee performance and conduct an l
Appendix C
integrated assessment team inspection to evaluate the effectiveness of the li-censee's corrective action programs and the readiness of the plant equipment and personnel to resume power operation before it makes any decision on restart.
The NRC will complete its evaluation of Peach Bottom's readiness for startup only af ter it has received all appropriate information and plan revisions from the licensee and has reviewed all followup inspection results.
Commenter Comment C.4.4:
Fitness _for Duty 11 Concerned about quality of maintenance actions being performed by PECo personnel in light of the illicit drug activity at the plant.
16 Drugs still a problem.
18 Alleges some PEco employees are not fit to operate plant (brag about heavy drinking and taking drugs),
Poor attitude toward work exists.
33 Concerned about drug use at plant.
Resyonse:
The NRC expects management at all nuclear power plants to aggressively imple-ment effective fitnost-for-duty programs.
PECo is responsible for ensuring the fitness for duty of all employees at Peach Bottom.
The basic fitness-for-du;y program at Peach Bottom includes those elements that are expected to be imple-mented at all operating nuclear power plants. These include worker training in drug awareness and company policy, supervisory training in observation of behavior, an employee assistance program, and drug testing on a preemployment I
and for-cause basis. On the basis of the results of the program and an NRC l
inspection of the program, the staff concludes that the licensee has imple-mented an adequate program at Peach Bottom to detect and correct drug abuse.
In addition to implementation of industrywide programs, such as preemployment and for-cause drug testing, the licensee has taken additional steps at Peach Bottom, includirg annual and random drug testing, undercover investigations, searches of the plant by trained dogs, and a policy that encourages confiden-tial reporting of drug involvement by concerned coworkers.
The NRC will con-tinue to monitor activities at Peach Bottom to ensure tnat responsible actions are taken when r.anagement becomes aware of any case of drug involvement.
A
)
proposed rulemaking being developed by the NRC btaff would further strengthen the ability of PEco and other utilities to identify and correct drug abuse problems by prescribing sanctions against those individuals possessing or using drugs while on the job at nuclear power plants.
Regarding concerns about the quality of maintenance performed in light of the drug activity at the plant, the licensee has an extensive quality as:urance program to identify and correct poor or improper maintenance actions irrespec-tive of their cause. This detailed program serves as a double check on main-tenance work te minimize the possibility that an improperly maintained item is left une rrected to degrade the performance of a safety-related system.
Addt-tionally, as discussed further in this appendix, to analyze the quality of the PBAPS Restart SER 10 Appendix C
~
maintenance effort of the licensee's employees, an NRC inspection team has com-pleted a programmatic review by evaluating maintenance and postmaintenance test-ing records, witnessing selected maintenance and postmaintenance testing activ-ities, and inspecting the physical cea.f ttion of equipment in the plsnt.
Commenter Comment C.4.5:
Secu r,t_ty t
11 Alleges improprieties concerning security guards (sleeping at their posts, drinking alcohol, long hours, inadequate staffing, inade-quate breaks, poor facilities, etc.)
33 Concerned about security practices at plant (long hours for guards, no meal breaks, no rotation, etc.).
Responsa:
These and several previous concerns regarding the guard force at Peach Bottom have been investigated by the NRC in the past and have been partially substan-tiated. During certain periods in the past, security force staffing was insuf-ficient to permit the desired frequency of post rotation and relief.
The staffing shortage resulted in substantial overtime so that security personnel typically worked 60 to 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> a week.
Although the problem has not been fully resolved, the licensee has made signi-I ficant inroads in correcting it.
Staffing has been increased by 50 percent in the past year. The security force now rotates guards on posts at 2-to 3-hour intervals, and overtime for the security force is now averaging less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> a week per individual (watchmen and armed guards). A policy to reduce overtime has been implemented.
The licensee has transferred or reassigned its two senior security managars at Peach Bottom and has recently switched to a new security contractor, During an NRC security inspection conducted during the week of July 25-29, 1988, the staff noted that staffirg problems still exist.
The NRC informed the lic-r,nsee of its continuing concerns and intends to conduct an additional security inspection to assess the effectiveness of corrective actions before it makes a decision on startup.
Commenter Comment C.4.6: Welding 2
Allages past history of inadequate welder examinations.
2 Alleges poor welding practices.
2 Alleges inadequate shielding was provided for welders.
Response
NRC inspectors conducted two programmatic safety inspections at Peach Bottom during March 14-18 and May 9-20, 1988. These inspections focused on welding and nondestructive testing associated with a recently completed pipe replace-ment program.
In addition, the NRC conducted another inspection on June 14 and 15, 1933, to investigate an unrelsted allegation regarding weldisq.
PBApS Restart $ER 11 Appendix C
9 L
During the two programmatic safety inspections, the inspectors observed welding in progress,. visually inspected completed welds, and reviewed work and material
. certification packages for selected welds. The inspectors then conducted onsite independent measurements to verify the adequacy of the licensee's nondestructive examination program.
Testing included x-ray alloy analysis, dye penetrant exam-l ination, visual examination, ferrite examination, and altrasonic testing. No violations were identified on any weld tested. The plant's. quality assurance (QA) progrm was evaluated by a review of licensee audit and surveillance reports.
The inspectors concluded that the Itcensee had significantly increased its effort in this area through meaningful and indepth reviews of contractor activities.
Inspection Reports 50-277/88-08, 50-278/88-08, and 50-278/88-14 contain the results of the inspeccions.
s The inspection on June 14 and 15, 1988, revealed improper welds ori some reactor water cleanup (RWCU) system piping, but the cause was not inadequate pipe fitup as alleged. All the welds had been previously identified by QA personnel and I
subsequently were repaired. During this inspection, the inspectors also learned that as a result of an unrelated review, two welders were found welding on small-bore pipe for which they were not qu.,1fied.
The welds were removed and rewelded by properly qualified welders.
The licensee reported this incident in a nonconformance report.
In another unrelated instance, a welder was found velding with a metal electrode on which he was not qualified.
The licensee also reported this incident in a nonconformance report.
Thus, 3 of approxi-mately 900 welders were found unqualified for specific tasks that they were performing.
The inspectors concluded that no violation or safety issue existed. Although some conditions were substantiated by the inspector (e.g., rejection of welds l
in the RWCU system and unqualified welders), these situations had been identi-fled by the licensee's QA program and appropriate corrective action had been taken.
Commenter Comment C.4.7.
Environmental Monitoring 9
Desires information on accidental releases of rec'iation at Peach Bottom (amounts), and what is "safe."
4 20 New emission monitoring dev4,e should be installed with public access to monitoring information.
36 Environmental monitoring at plant began in 1966 and results are i
available in library.
Response
Environmental radiation monitoring in the Peach Bottom viciriity began in March 1960 as part of the preoperational tests for Unit 1 (now decommissioned). The monitoring program has continued to the present and was expanded with 4,'te advent of Units 2 and 3.
Twelve environmental sampling stations were set up in loca-tions ranging from local areas, which included the plant site, Del.a. Holtwood, and Conowingo Dams, and Wakefield, to more distant areas, which included Phila-delphia and Hackett Point Bar.
PBAPS Restart SER 12 Appendix C s
m
This environmental program is designed to monitor various types of pertinent materials in the food chains of both animals and humans. Samples are taken of the atmospheric, terrestrial, and aquatic environments, using those media that are sensitive indicators of changes in the environmental radioactivity such as particulate matter in air, water, soil, and sediment, as well as those that could enter the human food chain such as potable water, milk, vegetation, and fish. The program also monitors the general levels of radioactivity in the environment.
Dose assessment began in May 1971 at eight locations and was later expanded to 35 locations.
Periodic reports of the data are provided and are available to the public.
The general levels of radioactivity at the site and in the surrounding regions were found to be generally low at the beginning of the survey period, but rose rapidly in 1961 because of weapons testing, and continued at a relatively high level into 1963.
From late 1963 through 1967, dispersion and decay generally reduced activity levels to the 1960 levels. Radioactivity levels again rose in 1968 through 1971 because of additional weapons testing in various parts of the world, then decreased again in 1972 and 1973.
In contrast, releases from Peach Bottom, even though local to the monitors, were essentially undetectable by the general radiation monitors and produced no measurable lasting radioactive de-posits.
This brief history should provide a helpful background for examining the actual data contained in the periodic reports.
The Commission conducts a separate, independent dose monitoring program around Peach Bottom and other reactors. The data are published quarterly in NUREG-0837, "NRC TLD Dire.ct Radiation Monitoring Network." Data for Peach Bottom are avail-ab'e since 1982. Ooses measured by the NRC (which are averaged over 3 months) during releases at Peach Bottom have been indistinguishable from natural back-ground radiation.
Commenter Comment C.4.8:
Health Effects 9
How do cancer, stillbirth, and birth defect rates near Peach Bottom compare with national averages?
20 Wants comprehensive health studies around Peach Bottom.
Response
Due to the ceneral nature of the comment a specific response which focuses on any specific aspect of the Peach Bottom plants' operation cannot be prepared.
However, the staff notes that in addition to its routine monitoring around all of the nuclear power plants in the Commonwealth of Peni.sylvania, the Pennsyl-vania Department of Health, Division of Epidemiological Research is currently conducting a comprehensive health study in the vicinity of Peach Bottom. Among the items being evaluated are the rates of new cancers, stillbirths, and birth defects.
The study is expected to be completed in the near future.
The staff is not aware of any well founded studies which indicate a significant increase (or decrease) in infant mortality or the incidence of cancer related to the operation or the recent shutdown of the Peach Bottom plant.
F3APS Restart SER 13 Appendix C
The effects of radiation on living systems have been studied for decades by individual scientists as well as by select committees that have been formed to objectively and independently assess the risk from radiation. These studies were considered in the development of the public health and safety limits that apply to the Peach Bottom plant, as well as to other nuclear power plants. The studies have not detected a statistically significant increase in cancer for doses and dose rates normally encountered in the vicinity of nuclear power plants.
However, as a prudent measure, the NRC staff assumes that there is a linear relation between cancer and low doses of radiation. NRC limits are selected so that the statistical probability of risk is extremely low.
Commenter Comment C.4.9: Warm Water Effects on Fish 9
How does warm water affect fish in the Susquehanna River?
Response
Because the effects of thermal discharges on aquatic life have been extensively discussed in the literature, a detailed answer would be too lengthy. A suit-able reference is Heated Effluents and Effects on Aquatic Life With Emphasis on Fishes: A Bibliography by E. C. Raney, 8. W. Menzel, and E. C. Weller.
Two of the more important points are that thermal discharges are not as detrimental to aquatic life as originally thought, and many aquatic organisms, particularly fishes, are capable of sensing and avoiding lethal temperatures if given a chance to do so.
To ensure protection cf the river and compliance with river water quality cri-teria, the Fennsylt
, Department of Environmental Resources regulates the quantity and qualit;,
' the waste water discharged from the station, including heat dissipation.
Cocling towers are used at Peach Bottom to dissipate a large amount of its heat to the atmosphere to comply with these regulations.
Environ-mental studies done at Peach Bottom before the plant was initially permitted to operate have documented the minimal effect on aquatic life resul ting from thermal discharges within the allowed limits.
Commenter Comment C.4.10:
INP0 Evaluations 11 Wants INP0 evaluation before startup.
26 Desires PECo response to INPO letter regarding unanswered General Electric service letters and outstanding work orders.
33 Concerned about INPO letter of October 1987, especially lack of accountability and excessive open maintenance items.
3d Concerned whether PECo has resources to carry out restart plan.
Re_sponse:
The large number of opan maintenance items is not unusual for a plant in shut-down. During periods of operation, any plant accumulates a backlog of out-standing maintenance items that can or must be deferred until an outage. When a plant shuts down for a major outage, additional preventive maintenance items PBADS Restart SER 14 Appendix C I
a that must be completed during the outage are added to the backlog. This occurs for any type of plant regardless of its power source. Moreover, potential pro-blems identified to the utility by the NRC or INP0 that require maintenance ac-tions to investigate and correct frequcntly add to the backlog.
For example, a generic industry problem v ".h a particular type of valve (of which there may be several hundred in the plant) could lead to several hundred maintenance items.
During an outage, r intenance activities woild be scheduled so that tasks on safety-related equipment would 9 ve a high priority. Consequently, some open maintenance items on non-safety-related equipment (having a lower priority) may be deferred until a subsequent outage.
Therefore, these low priority ite is also contribute to the backlog. Additionally, the maintenance backlog is fur-ther influenced by the inability to complete testing on a refurbished component because of existing plant conditions (certain testing requires the plant to be operating).
In its review of the PEco restart plan, the NRC is paying particular attention to the maintenance backlog as part of the plant readiness criteria, including equipment operability and sufficient me.intenance resources.
In addition, the Commission issued its Policy Statement on Maintenance of Nuc-lear Power Plants on March 23, 1988.
This policy statement identifies the acti-vities that form the basis of an adequate maintenance program and provides guid-ance to the industry on improving maintenance programs.
The NRC also will review the Peach Bottom maintenance program in light of this policy statement.
An inspection team completed a programmatic rcview by evaluating maintenance and postmaintencnce testing records, witnessing selected maintenance and post-maintenance testing activities, and inspecting the physical condition of equip-ment in the plant.
Commenter Comment C,4.11:
priority of Safety Concerns 9
Concerned that monetary issues at plant will take back seat to safety.
12 Concerned about cracks in thu concrete, piping, and welds.
Response
Current programs require licensees to identify and monitor the condition of reactor system components vulnerable to corrosion or embrittlement. These pro-grams are required to ensure that any dearadation of components is detected and evaluated, if necessary, plant modifications may be required to ensure that operation of the plant will be within the previously approved design envelope.
Although the NRC recognizes that repair / replacement costs for some components may be substantial, its primary emphasis and concern is to ensure that necessary plant modifications restore the plant condition to the original design basis so that operation of the plant does not endanger the health and safety of the public.
PBAPS Restart SER 15 Appondix C
r Commenter Comment C.4.12:
Safety Investigations 20 Peach Bottom has unsafe design and should not restart unless redesigned.
26 Wants Advisory Committee on Reactor Safeguards to do safety analysis of Peach Bottom before restart.
44 Wants independent safety investigation before startup, i
46 Nuclear power is unsafe.
i
Response
The General Accounting Office (GAO) is studying the Peach Bottom case. The NRC staff will consider all information relevant to a Peach Bottom restart decision, includino information.provided by GAO, that is available at the time such a decision is made.
In addition, the Advisory Committee on Reactor Safeguards plans to conduct deliberations on the Peach Bottom restart during meetings that-will be open to the public.
The opportunity for public comment and other aspects of the conduct of these meetings will be provided in the Federal Register notice announcing the time and dates of such meetings.
Commenter Comment C.4.13: Water Quality 1
11 Alleges Susquehanna River water quality reports were altered to downgrade radiation levels.
Response
1 During an interview between PECo and the alleger, it was determined that the allegation regarding Susquehanna River water quality reports was based on infor-mation received second hand from a contractor employee last employed at Peach Bottom in 1976.
Specific.information on or any first-hand knowledge of such activity or any indication that it is continuing could not be provided.
Lack-ing any details of the allegation and considering the time period in which it was alleged to have occurred, no further investigation is considered appropriate.
Commenter Comment C.4.14:
Fire Protection 11 Concerned about lack of fire drills with local fire-fighting companies.
22 More emphasis needs to be placed on training with local fire agencies.
i
Response
PEco's Peach Bottom Fire Protection Program has received extensive NRC review and approval. The program identifies numerous fire protection features that minimize the potential for. fires, ensure timely and effective fire-fighting capability, and ensure safe shutdown of the plant in the event of a fire.
These capabilities do not rely on support from the local fire department. The PBAPS Restart SER 16 Appendix C
- . J.
I five-man fire brigade is trained to handle most station fires without support from the fire department.
The local fire department will be requested to re-spond if its support is deemed necessary.
To ensure that local fire departments can effectively support station fire-fighting efforts, they are provided with annual tra!ning in accordance with the PBAPS Emergency Plan. This training was last conducted on August 22 and 24,1988.
Commenter Comment C.4.15:
Containment 12 What is probability of containment failure in event of core melt -
90 percent?
12 Mark I containment is not safe.
4 16 Concerned about Mark I containment.
21 Concerned about Mark I containment.
A 23 Concerned about Mark I containment.
26 Wants Mark I containment issue resolved before startup.
44 Concerned about Mark I containment,
Response
The containment structure is designed to prevent the release of substantial quantities of radioactivity in the event of any one of a number of postulated accidents which are referred to as design basis accidents. Our safety research on reactor accidents has provided us with a number of insights. Among these are that the Mark I containment design provides a significant safety margin for accidents even worse than the design basis accident, and that such severe ac-l cidents have a low probability of occurrence.
I The NRC believes that the BWR Mark I plants are safe and that they pose no j
undue public health r'esk.
Nevertheless, the NRC is pursuing a vigorous program to reduce even further the already very low likelihood of occurrence of a severe accident and to improve the capability of plants to mitigate the con-sequences of such accidents.
The NRC's most recent program in this regard was begun several years ago and a final report with recommendations by the NRC staff is expected in the near future.
Commenter Comment C.4.16:
Decommissioning
)
12 Concerned about cost of cleanup of the plant after decommissioning.
13 Concerned about dangers of plutonium and cost of cleanup.
45.
Concerned about plant decommissioning, f
i PBAPS Restart SER 17 Appendix C
_______m_._...,
. - e 2
Response
Section 50.54(bb) of Title 10 of the Code of Federal Regulations _(10 CFR)'
t requires that no later than 5 years before the expiration of the reactor oper-ating license, licensees of operating nuclear power reactors shall submit writ-ten notification to the Commission, for its review and preliminary approval, of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of l
the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository.
Final Commission review will be unc'ertaken as part of any
(
proceeding for continued licensing under 10 CFR Parts 50 or 72.
The licensee must demonstrate to the NRC that the elected actions will be consistent with NRC requirements for licensed possession of irradiated nuclear fuel and that the actions will be implemented on a timely basis.
The issue of spent fuel repositories is discussed elsewhere in this appendix.
.Commenter Comment C.4.17:
Economics and Need for Power 20 Nuclear plants are not economical.
33 Illegal to consider economic benefits to community in considering l
f 33 Peach Bottom is not needed, 37 Peach Bottom is needed to prevent acid rain and minimize need to import oil.
Response
The NRC staff does not routinely evaluate issues such as need for power, alter-nate energy sources, or economic benefits in connection with the continued auth-orization of operation of operating nuclear power plants unless such issues arose that would require an environmental impact statement pursuant to 10 CFR 51 or a consideration of a backfit issue pursuant to 10 CFR 50.109.
To date the staff's consideration of the Peach Bottom issues, as discussed in this SER, have not involved such issues.
The staff does recognize, however, that such l
economic issues may typically be considered by local public utility commissions.
Commenter Comment C.4.18:
Emergency Planning 20 Doubts evacuation possibility.
l 41 Concerned about provision of the evacuation plan to use schools as shelters (dismissing the children) in violation of Pennsylvania i
guidelines.
t 44 Concerned about provision of the evacuation plan to use schcals as shelters (dismissing the children) in violation of Pennsylvania l
guidelines.
PBAPS Restart SER 18 Appendix C
e
Response
Evacuation is one element colisidered in emergency planning. Although it is highly unlikely that. evacuation would be required, the NRC requires that such a contingency-be considered in developing emergency plans.
The Peach Bottom emergency plan was prepared using 'a variety of sources as guidance including NRC accaptance criteria primarily based on lessons learned
'from TMI-2.
Experience gained in developing and demonstrating previous Peach Bottom emergency plans and the PECo Procedures for Electric Service Restoration in Major Emergencies has been incorporated into this emergency plan.
Close cooperation with State and county civil agencies has been established so that State, county, and facility emergency plans are compatible.
PECo has written agreements with Pennsylvania and the count'es of Chester, t.ancaster, and York as well as memos of understanding with Maryland and the counties of Cecil and Harford.
If a situation requiring sheltering or evacua-tion should occur, the utility's responsibility is to p: ovide notification, supply continuing information, and make recommendations to the State and coun-ties at risk.
It is the State and county plans that cover alerting of the gen-4 eral public in the affected area and give details for protection of this popula-tion, including provisions for protective actions such as sheltering or evacua-ting personnel from affected sections.
These plans in general call for sirens, police patrol cars, and other emergency vehicles with public address systems to warn and evacuate appropriate sectors within the plume exposure emergency plann-ing zone (EPZ).
The Pennsylvania Emergency Management Agency plan recognizes that the safety of school children is the key factor in any protective action.
Its plan calls for school children whose schools are located outside the EPZ to be retained in the schools they attend, or if located inside the EPZ, to be evacuated to host schools.
The children will be retained in the school until i
they are picked up by their parents or guardians.
tehnd children will not be sent home at any tims when an evacuation is in progress.
In any case, the responsibility for any protective action for the public, including evacuation, lies with the State.
Training on the Peach Bottom emergent / plan is provided to emergency organiza-tion personnel who are assigned to 'asitions on the basis of experience during normal operations. Training by 1*:ture, drills and exercises is used to famil-iarize personnel with specific e argency responsibilities.
Training and educa-tion are applicable to PEco pr,onnel, supporting agencies, private citizens, and news media personnel.
PI 2 conducts periodic exercises to test plan effec-tiveness that are monitored c/ the NRC.
State and local agencies also carry out field practices of their emergency plans to evaluate their ability to carry out evacuations.
These exercises are observed by the Federal Emergency Manage-ment Agency (FEMA).
Provi ions within the emergency plan provide for periodic review and reviston of the emergency plan.
The plan and associated procedures are reviewed annually to consider their effectiveness and organization; results of drills, exercises, and training; and new or revised regulations.
Results obtained from past exercises have demonstrated the ability to implement protec-tive actions, including evacuation.
PBAPS Restart SER 19 Appendix C
o Commenter Comment C.4.19:
Radwaste 11 Alleges contaminated items were stored in faulty containers.
20 Concerned about radwaste storage. Wants spent fuel transferred to dry cask storage.
21 Concerned about amounts of radwaste.
44 Concerned about nuclear waste.
Response
The "faulty containers" refer to drums that were stored outdoors on pallets near the diesel generator building in a tented area. These drums were in a temporary storage area awaiting offsite disposal. They contained low-level oil solidified with Environstone, which is a cement-based solidification 3 gent.
The average dose rate from each was approximately 0.2 millirem /hr on contact.
All of the containers were properly covered with lids, and although a number had some rust, they did not pose a radiological hazard.
The NRC initiateri a rulemaking proceeding on October 25, 1979, to assess gene-rically the degree of assurance that radioactive waste can be disposed of safely, to determine when such disposal or offsite storage will be available, and to determine if radioactive wastes can be safely stored on site past the expiration of existing facility licenses until offsite disposal or storage is available.
This proceeding became known as the "Waste Confidence Rulemaking." The Commis-sion's decision is summarized in the following findings:
(1) The Commission found reasonable assurance that safe disposal of high-level radioactive waste and spent fuel in a mined geologic repository is techni-cally feasible.
(2) The Commission found reasonable assurance that one or more mined geologic repositories for commercial high-level radioactive waste and spent fuel will be available by the years 2007-08, and that sufficient repository capacity will be available within 30 years beyond the expiration of any reactor operating license to dispose of existing commercial high-level radioactive waste and spent fuel originating in such reactor and generated up to that time.
(3) The Commission found reasonable assurance that high-level radioactive waste and spent fuel will be managed in a safe manner until sufficient repository capacity is available to ensure the safe disposal of all high level radioactive waste and spent fuel.
(4) The Commission found reasonable assurance that, if necessary, spent fuel generated in any reactor can be stored safely and without significant on-vironmental impact for at least 30 years beyond the expiration of that reactor's operating license at that reactor's spent fuel storage basin, or at either onsite or offsite independent spent fuel storage installations.
PBAPS Restart SER 20 Appendix C
T
.. e (5) The Commission found reasonable assurance that safe independent onsite or offsite spent fuel storage will be made available if such storage capacity is needed.
In keeping with its commit *ent to issue rules providing procedures for consider-ing environmental effects
' extended onsite storage of spent fuel in licensing proceedings, the Commissir issued changes to 10 CFR Parts 50 and 51.
Ii adopt-ing changes to 10 CFR 50. 4, the Commission established procedures to confirm that there will be ader. 4te lead time for whatever actions may be needed at individual reactor site, to ensure that the management of spent fuel following the expiration of the reactor operating license will be accomplished in a safe and environmentally acceptable manner. Accordingly, no discussion of any envi-ronmental impcct of spent fuel storage for the period following expiration of the license or amendment applied for is required in connection ith the issuance or amendment of an operating license for a nJCle&P reactor.
For a more extensive discussion of these rulemaking's,. see the Federal Register (49 FR 34658, August 31, 1984).
Commenter Comment C.4.20: NRC 21 Generic problems are addressed too slowly, thus causing lack of faith in NRC.
34 Concerned that NRC is too cozy with nuclear industry to regulate it.
Response
Among its responsibilities, the NRC is charged with ccnducting research in sup-port of the licensing and regulatory process.
Thio function is performed through evaluation of operating experience and confirmatory research.
Regulations are proposed on the basis of the information obtained from this process. Although a specific rule issued by the Commission may, according to the current body of scientific and techn kal knowledge, be viewed as the most sound, future operat-ing experience or research may show otherwise.
In evaluating the growing body of operating experience and technical knowledge, the Commission weighs the cost of a rule change against the benefits that change would produce.
In many in-stances, additional operating experience or research (requiring additional time) is needed to establish the basis for a rule change. When existing rules (or generic issues) have allowed extended safe operations with an acceptable level of risk, a significant body of evidence must be produced to warrant a change.
The NRC staff would not agree that the actions taken with respect to Peach Bottom, which as detailed in Section 2 of the SER include the shutdown of the plant for over a year and enforcement actions against PEco and certain of its employees, support the proposition that NRC is "too cozy with the nuclear in-dustry to regulate it."
PBAPS Restart SER 21 Appendix C
4 i'
Commenter C'omment C.4.21:
Spent Fuel Reracking a
34 Plan does not address containment, spent fuel veracking, and ade-1 quacy of offsite radiation monitoring equipment.
Response
The spent fuel reracking issue is not directly related to those issues addressed by the NRC's shutdown order of March 31, 1987,_ and, therefore, is not addressed by the licensee's plan for restart.
Nevertheless, it is noted that the cur-
~
rently installed capacity will last until 1995, with.a reserve full-core dis-charge, for Unit 2, and until 1996, with a reserve full-core discharge, for
-Unit.3 when in progress modifications are completed in early 1989.
Containment and offsite radiation monitoring are responded to under the categories covering concerns about the containment and environmert.al radiation monitoring, respectively.
Qoymenter Comment C.4.22:
Restart Criteria 34 What are NRC's restart. criteria?
Response
The staff's review of the issues associated with the shutdown of Peach Bottom that includes-the staff's approach to enforcement actions, the staff's review of PEco's response to the shutdown issues, and other activities involved in any determination of readiness for restart are. discussed in Sections 1 and 2 of this SER.
Commenter Comment C.4.23:
Seismology 39 Concerned about plant being on a geological fault that had two earthquakes in last 10 years.
R_e spon se:
Peach Bottom lies in an area that has experienced a moderate amount of minor earthquake activity. Most of the reported earthquakes have occurred in the Piedmont Province in which the site is located.
The closest fault is associ-ated with the Peach Bottom Syncline located approximately 1 mile south of the site.
Studies indicate that the Peach Bottom fault and similar nearby faulis have completely healed.
The most recent fault movement in the region is be-lieved to have occurred during Hesozoic time between 140 and 200 million years ago.
Records of the occurrence of earthquakes in southeastern Pennsylvania and the surrounding areas date back to the early 18th century. Many earthquakes have been reported since that time and some of these caused minor structural damage; however, none can be considered te be of great or catastrophic proportion. On the basis of the seismic history of the area, a maximum credible earthquake was selected against which the plant was designed.
This earthqrske is considered to be the largest shock in the region at the closest epicentral distance to the site consistent with geologic structure.
Class I (safety-related) facilities PBAPS Restart SER 22 Appendix C
e v-9 i
at the plant are designed to withstand ground accelerations that could result o
from a shock of about the same size as the earthquake of 1871 (Wilmington),
1883 (Harford County), or 1889 (southeast Pennsylvania) at the closest approach to the site of their related geologic structure.
Additional details on the geologic and seismologic characteristics of the area and the supporting studies and surveys can be found in Section 2.5 of the Peach Bottom Final Safety Analysis Report.
PBAPS Restart SER 23 Appendix C
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