ML20206P032
| ML20206P032 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick, 05000000 |
| Issue date: | 08/12/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20206P036 | List: |
| References | |
| NUDOCS 8608270067 | |
| Download: ML20206P032 (11) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19gtgust 12, 1986 i215) 841 5001 eselsLDs L. DALTmorr Docket Nos. 50-277 g*lfyjg,,
50-278 4
i Dr. Thomas E. Murley, Administrator Region'I U.S. Nuclear Regulatory Commission G31 Park Avenue King of Prussia, PA 19406 Systematic Assessment of Licensee Performance SUBJECTi for Peach Bottom Atomic Power Station (SALP)
Assessment Period: ' April 1, 1985 to January 31, 1986
REFERENCE:
SALP Report.No. 50-277/85-98 50-278/85-98
Dear Dr. Murley:
Your letter dated June 6, 1986, forwarded the Systematic Assessment of Licensee Performance (SALP) Reports for the Peach Bottom Atomic Power Station and the Limerick Generating Station.
The purpose of this letter is to provide the Philadelphia response to the Peach Bottom portion of Electric Company (PECo)
The response to the Limerick SALP Report will the SALP report.
be filed separately.
Philadelphia Electric Company management appreciated the 12, 1986 at the opportunity to meet with the NRC staff on July Based Region I Office and to discuss the SALP Report findings.
on the discussions at the meeting, we have the following comments:
Plant Operations The SALP Board recommendations in the area of Plant Operations
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are as follows:
Address the apperent complacent attitude and stress 1.
procedure compliance.
8602270067 860812 PDR ADOCK 05000277 PDR G
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c Auguot 12, 1986 Dr. Thosas E. Murley Page 2 2.
Address the number and repetitiveness of reactor scrams and personnel errors.
Concerning these recommendations, the following actions are in various stages of implementation:
Leadership Training Program for supervisory personnel is 4
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underway.
An aggressive program is underway to qualify and license I
o reactor operators to provide extra operators for periodic losses due relief and to provide immediate replacements for to sickness, resignations, and retirements, s
Shift professional personnel will be supplemented with o
certified BWR engineers provided by the Nuclear Steam System Supplier.
These engineers will assist shift supervision during the coming period of training and qualification of-personnel directed towards meeting quota.
PECo is implementing a project management program for o
modifications which is using the concept of "Living This program will. provide better planning and Schedule".
scheduling which is expected to reduce pressures-and strains on plant operating staff during periods of outage.
Additional actions being taken to improve our performance in the area of Plant Operations are as follows:
A system engineer program is being implemented which 1.
provides an engineer for each of the principal. systems.
The engineer will monitor, arrange for preventative maintenance, and otherwise provide increased-surveillance and performance monitoring of the system assigned.
2.
A radwaste volume reduction program is being implemented.
Dry active waste will be.supercompacted
^
under contract with General Electric.
Additionally, a resin -aiuction process, provided by General Electric,
.mplemented in.tbn first quarter of 1987.
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3.
Computerized log keepirj ac.vities are being. pursued to provide additional rek.abit ceview of plant parameters in order to detect anamolies earlier.
h 4.
Refurbishing of the control room and its immediate environs will be expedited in the interest of improving the work environment and shift employee morale.
5.
The equipment blocking management system is in place at Limerick and is being put in place at Peach Bottom to 4
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Dr. Thomas E. hurley August 12, 1986 Page 3 reduce the time delay in obtaining olocks and to improve' the legibility of permits.
Operator training programs have been accredited by the 6.
National Acadcay for Nuclear Training.
The SALP Report noted that "at times the public address system tends to distract from centrol room formality".
A planned modification will provide for an upgrade of the plant One feature of the new system will be public address system.
separate page. buttons for the control roc.T. 'and the balance of the plant.
Depressing the general page button will page the not the control room.
Depressing the other page plant but button will page both the plant and control room areas.
Proper use of these two page buttons will reduce the number of non-operational related pages broadcast in the control room.
The number and repetitiveness of scrams reported against Peach Bottom is of concern to us.
The Independent Safety Engineering Group (ISEG) reviews. plant scrams and prepares event reports to determine root causes and recommend corrective actions to preclude recurrence.
As part of this involvement in scram analysis, the site ISEG is an active participant in the BWP. Owners' Group Scram Frequency As Reduction Committee's efforts to reduce unplanned scrams.
commented during the meeting, we are quite concerned that reactor scram signals generated in the course of performing outage work, in confined spaces under the vision and mobility constraints imposed by environmental conditions, are creating an impression of poor performance.
When the details of these events are analyzed, we believe it appropriate to ccnclude that they have minimal significance.
In reality, the'y were the result of bumping cables (which are highly sensitive to spontaneous pulse generation) while personnel were performing various tasks.
However, these and others like them are part of the LicWasee Event Report record and we are concerned that these types of events are not discounted.
Radiological Controls Board Recommendations For Licensee:
Complete long-term transportation related corrective 1.
actions discussed during the November 14, 1985 Enforcement Conference.
2.
Evaluate the effectiveness of the QA program relative tc transportation related problems.
l
August 12, 1986 Dr. Thomas E. Murley
.Page 4 Concerning Recommendation 1, all of the long-term transportation'related corrective actions have been These involved the arrangement of rigging cables completed.
for pallets, the cask trunion cup contamination problem, and increased QC inspections during loading operations.
requests an evaluation of the effectiveness The SALP Report of the QA program relative to transportation related programs.
The applicable fuel floor (Fue-1 Handling) and procedures have been revised to Health Physics (HPO/CO) clarify the actions relating to the Health Physics Quality Control and station personnel concerning radioactive As a result of the review of the material / waste shipments.
identified items, the Quality Assurance Division will be included in the review of fuel floor and Special Procedures relating to shipment of radioactive material / waste in order to include independent verification of appropriate procedure steps.
Additional actions being taken to improve our performance in the area of Radiological Controls are as follows:
The Health Physics Section at the station will be J
1.
reorganized with the adoption of a Radwaste Section to be responsible for the handling and shipping and volume reduction practices.
2.
As noted in the SALP report, the separation of Health Physics and Chemistry has been, and will. continue to be, an effective step to improve the operations of these activities.
Changes already made in the procedures and hardware I
3.
related to shipping low level waste should eliminate the problems with such shipments which had occurred during the SALP period, t
Programs are in place and will be strengthened to reduce 4.
the volume of radwaste being shipped to disposal sites.
These programs will include the use of a supercompactor for dry active waste and the installation of the Aztech system to reduce resin shipments and disposal.
Improved frisking has been accomplished by use of 5.
automatic friskers located at, key access points and
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plant exits.
.Dr. Thomne E. Murlsy August 12, 1986 Page S Maintenance Board Recommendations for Licensee:
Improve the control of vendor information.
Peach Bottom Procedure A-92, " Control of Vendor Manuals", was 1985.
In response to INPO placed into effect in December, recommendations, a major rewrite of this procedure is being performed which will substantially incorporate 'the concepts contained in INPO Good Practice MA-304.
In addition to the major revisions to Peach Bottom Procedure A-92, we are continuing with the vendor manual update program committed to in response to Generic Letter 83-28 (Salem As a result of this vendor manual update program, we ATWS).
have identified a number of enhahcements to the applicable Engineering & Research Department procedures pertaining to or aff,ecting the control of vendor manuals.
It is expected that these ERDP procedures will be revised to include these enhancements by June, 1987 in order to provide a fully integrated system for vendor manual control between Peach Bottom and the Engineering and Research Department.
Additional actions being taken to improve our perfsrmance in the area of Maintenance are as follows:
Maintenance training programs have been submitted to and 1.
evaluated by INPO as part of the Accreditation process.
of the On-the-job training has been formalized as part 2.
accreditation process and should improve performance of routine maintenance activities.
3.
Maintenance personnel have been assigned to the planning of non-outage work.
Pre-planning should result in reduced equipment out-of-service times and reduced radiation exposure.
4.
The daily meeting for planning and coordinating activities is continuing successfully.
the A major program is underway to clean up and-raint 5.
to improve the appearance of the facility, and to plant foster a positive attitude in the workplace among plant personnel that will encourage quality wor,k.
Dr. Thomas E. Murley August 12, 1986 Page 6 Surveillance Board Recommendations for Licensee:
Establish management policy and controls which reflect the relationship between surveillance. testing and equipment and system operability.
Peach Bottom Administrative Procedure A-43 (Surveillance Testing System) has been revised, approved and implemented.
The revised procedure addresses control and disposition of Discussions between grace period tests and overdue tests.
members of your staff and PECo are continuing on this issue.
m Additional actions being taken to improve our performance in the area of Survsillance are as follows:
Backfilling procedures have been revised to eliminate 1.
scrams due to backfilling instruments.
2.
In response to a weakness identified by NRC, the Surveillance Test Tracking Software Program is being revised in order to clearly identify to appropriate station management those tests which require prompt action to ensure timely completion.
Fire Protection Board Recommendations for Licensee:
Assess the results and evaluations of the radwaste building cable tray fire.
An in-house evaluation of this event was performed by the PECo Independent Safety Evaluation ~ Group (ISEG) Group and an independent evaluation was performed by a vendor.
The ISEG report, the vendor report, and PECo Electrical Engineering Division comments on the vendor report were transmitted to NRC via letter M. J. Cooney, PECo, to S.
D.
Ebneter, NRC, dated May 21, 1986.
Emergency Preparedness Board Recommendations for Licensee:
1.
Improve QA audit resolution and corrective action followup activities of emergency planning.
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August 12, 1986
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Dr. Themas E. Murley Page 7 I
2.
Promptly complete the actions required of the ~
Confirmatory Action Letter.
Concerning Recommendation 1, the Emergency Preparedness Section tracks open critique / drill items.
The QA Division will conduct a comprehensive audit by the end'of 1986 of the Emergency Preparedness program including emergency action levels and Emergency Preparedness Section tracking and resolution of critique and drill'open items.
Concerning Recommendatlon 2, all of the actions identified by the-Confirmatory Action Letter referenced in the SALP Report have been completed.
By March 31, 1986, eight members of corporate and station management-received formal training to
-qualify them as both Site Emergency Coordinator and Emergency Three additional members will also be considered Director.
qualified as of the same~ date when documentation of the required reading assignment is' received.
Although the number of personnel available to serve the subject positions may be adequate, training to qualify all Shift Superintendents and station Senior Engineers.is ongoing.
The corporate personnel designated as Site Emergency Coordinators, and the station Senior Engineers / Shift Supervision designated as Emergency Directors have been trained in the applicable event classification procedu,re (EP-101).
This obligation was satisfied by virtue of participation in either the standard Emergency Plant Training Program or the Cycle I Licensed Operator Requalification.
l Security and Safecuards Board Recommendations for Licensee:
1.
Provide closer day-to-day management oversight to assess the control of the contractor security force.
2.
Establish measures to anticipate demands for needed resources of the security organization.
A reorganization related to nuclea'r plant securd.ty is being implemented.
Initially a senior-level, experienced security manager is being transferred to the Electric Production staff to direct security operations at both nuclear plants.
This individual is currently visiting other utilities to review l
their programs and identify practices'which can further enhance our security performance.
Based upon these reviews, further reorganization is contemplated including increased PECo security personnel presence at both nuclear plants.
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August 12, 1986 Dr. Thomas E. Murley Page 8 Goals will be set and a timetable established to bring Security to a SALP rating of 1.
s Refueling /Octage Activities Board Recommendations for Licensee:
None.
We are pleased to find acknowledgement in the report that Philadelphia Electric Company demonstrated a consistent rating of " Category 1" in this area.
It should be noted that the responsibility and, authority of the outage manager has been strengthened to provide him more control of activities during an outage.
Training and Qualification Effectiveness Board Recommendations for Licensee:
None.
Training deficiencie's noted in the SALP Report concerned Emergency Preparedness Training.
Our comments regarding corrective actions taken to resolve these deficiencies are provided in the Emergency Preparedness Section of this response.
Five programs are in the INPO accreditation process.
Responses to the recommendations have been submitted and an Accreditation Board hearing is expected in late September or October, 1986.
is Feedback from plant events, particularly operator errors, being used to revise lesson plans and' Simulator Training Scenarios to improve training effectiveness.
Assurance of Quality Board Recommendations for Licensee:
Consider a management review to determine:
(1) the effectiveness of the several oversight groups and (2) the extent to which these groups are used to assure that performance improvements are achieved
August 12, 1986 Dr. Thomas E. Murley Page 9 The Nuclear Review Board (NRB) is an important organization used by PECo to review the effectiveness of the several oversight groups.
The NRB conducts regular, as well as special meetings, and is kept well informed of plant events.
The NRB is comprised of knowledgeable and experienced individuals from a wide range of areas and functions to review safety concerns and corrective actions.
The NRB has proven to be an effective mechanism for ensuring necessary improvements.
The SALP Report also noted that:
"QA oversight of surveillance testing activities was weak in that it did not identify weaknesses in the surveillance program such as the missed or partially completed surveillances, and the lack of procedures regarding actions to be taken relative to overdue Surveillance Tests."
PBAPS Administrative Procedure A-43 (Surveillance Testing System) has been revised to address overdue Surveillance The Quality Assurance Division will conduct an Tests.
additional audit of the ST program by the end of 1986 to include verification of the adequacy of this revised Administiative Procedure.
The SALP Report discussed Quality Control activities associated with Unit 3 fuel reconstitution.
All purchase orders associated with site based fuel related services are issued by Peach Bottom site.
The Quality Control organization is responsible for reviewing all purchase orders issued by the site for proper Quality Assurance requirements.
This review will provide QC with notification of upcoming fuel floor activities, thereby enabling QC to provide the proper coverage.
An Incident Review Committee, comprised mainly of operations personnel, has been established to review the results of investigations of significant events caused by personnel errors and to gain input with regard to appropriate corrective actions.
The Human Performance Evaluation System, as developed by INFO and several utilities, is in the process of being implemented.
Several people have received training in its use', and various mechanisms to inform the workers about this program are under development.
This program is expected to i
be implemented by the last quarter of 1986.
f
u 1986
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- gust 12, Ep Thomas E. Murley
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Licensing Activities Board Recommendations for Licensee:
None.
I The SALP report noted a decline in the licensee's usually i
timely response and resolution of licensing issues involving l
Technical Specification issues, and the need to give more l
attention to the significant hazards consideration
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determination (Sholly determinations) that is submitted for l
I While the
'each Technical Specification change request.
preparation of License Amendme,nt Applications require i
additional supporting analyses since the Sholly rule and the extensive review prior to submittal, we acknowledge that time needed to process an application should be reduced.
l Acquisition of technical information necessary for
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preparation of the application, and on site review of the draft document are two areas that need to be expedited in a
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l more timely manner.
A license amendment application summary report has been developed for monitoring the progress of application preparation.
The report will be updated bi-weekly by the Peach Bottom Licensing Engineer and submitted to his l
The l
management as part of the bi-weekly staff minutes.
report will clearly identify responsibilities and failures to l
j meet schedule milestones and permit management to focus on 4
those areas requiring more attention.
Additionally, the l
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Licensing Engineer who prepared the application will l
personally present the proposed application to the PORC for approval for all but minor license revisions.
This should.
i expedite the PORC approval process.
i While the format of the significant hazards consideration was f
we were revised in response to a finding in last year's SALP, advised in Generic Letter 86-03, dated February 10, 1986, to i
i improve the technical discussions supporting the hazards l
determination.
Since the hazards determination associated with the only application processed by the NRC since the February 10, 1986 letter was published in the Federal i
Register with few revisions, we conclude that our efforts to improve the quality of the applications is approaching NRC expectations.
We are pleased that the NRC's Project Manager 4
concurted during the SALP meeting that the quality of the License Amendment Applications has shown a noted improvement in recent months.
We will continue to emphasize the,
i importance of the significant hazards consideration in the preparation of future applications.
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Dr. Thomas E. Murley Auguot 12, 1986 Page 11 Should you have any questions or require additional information, please do not hesitate to contact us.
i Very trul
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T. P. Johnson, Resident Site Inspector k
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