ML20214D012

Forwards Listed Appraisal Plans to Be Implemented by Util in Response to Rc Young 840618 Order Modifying License Effective Immediately,Including Plan for Review of Plant & Sys Operating Procedures

ML20214D012
Person / Time
Site:	Peach Bottom
Issue date:	08/15/1984
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20214C938	List: ML20214C936 ML20214D012 ML20214D073 ML20214D123
References
FOIA-87-185 EA-84-039, EA-84-39, NUDOCS 8705210179
Download: ML20214D012 (17)

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PHILAD ELPHI A ELECTRIC COMPANY -

23ol MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 12:51 e415p smetos L. caumorr n.Ul.c",',U',3.

. August 15, 1984

' Docket Nos. 50-277 i

.50-278 EA No. 84-39' Dr. Thomas E. Murley, Administrator Region I Office of Inspection and Enforceme'nt U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Dr'. Murley:

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I By. letter dated June 18, 1984, R.C. DeYoung,-NRC,'to l

V.S. Boyer, PECo, Philadelphia Elestric Company received an Order Modifying License Effective Immedfately.

Section IV.to the Order.

requested submission to your offlee for review and approval, appraisal plans relating to our Peach Bottom Atomic Power Station.

1 The enclosed attachments to this letter present the.

three appraisal plans to be implen.cated by Philadelphia Electric Company, in response to the Order, upon your approval.

Attachment A,

" Appraisal-Plan for-the Review of Philadelphia Electric Company's Process for Performing Safety Evaluations and Reviews of. Procedures for.the Peach Bottom Atomic i

Power Station," presents a plan for' appraisal'in accordance with Item 1 to Section IV of the Order.

Attachment B,

" Appraisal Plan for~the-Review of Peach Bottom Atomic. Power Station's Plant and System Operating.

Procedures," presents a plan for appraisal in accordance'with Item 2 to Section IV of the Order.

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Dr. Thomas E. Murley-August 15, 1984 Page 2 Attachment-C," Appraisal Plan for the Review of Philadelphia Electric Company's' Program for Ensuring-Qualification of Personnel Reviewing and Approving Operating Procedures," presents a plan for appraisal in accordance with-Item 3 to Section IV-of the Order.

In accordance with the Resolution of Appraisal Findings of each appraisal plan, the resolution of the findings and recommendations of each appraisal plan will be submitted to the NRC within 90 days of the-issuance of each Appraisal Team's report.

Should you have any questions or require additional information, please'do not-hesitate to contact us.

Very truly yours, s'

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Attachments

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R. C. DeYoung, Director A. R. Blough, Site Inspector 4:.

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ATTACHMENT A PHILADELPHIA ELECTRIC COMPANY

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PEACH BOTTOM ATOMIC-POWER STATION UNITS 2 AND'3 DOCKET NOS. 50-277 AND 50-278 4

A _P P _RA_I S_ A_L_ _P_L_AN FO_R_T_H_E REVIEW OF PHILADELPHIA ELECTRIC COMPANY'S PROCESS _FOR PERFORMING SAFETY EVALUATIONS AND REVIEWS 4

I OF__P_ ROC __E DU_RE_S_F_O_R_T_H__E __P _E A_C_H_ _ B_OT_T_O_M_ _ A_T_O_M_I C___PO_WE August 1984 k

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ATTACHMENT A APPRAISAL' PLAN FOR THE REVIEW OF PHILADELPHIA ELECTRIC COMPANY'S PROCESS FOR PERFORMING _ SAFETY EVALUATIONS.AND REVIEWS OF PROCEDURES FOR THE PEACH BOTTOM ATOMIC POWER STATION August 1984 i

Introduction

_The Nuclear. Regulatory Commission's (NRC) Order j

- Modifying' License Effective Immediately, issued' June 18, 1984 which addresses the Peach Bottom Atomic Power Station, ; Units 2 and 2,~ requires-that an Appraisal' Plan be submitted'to the NRC for _ approval for the review of the Philadelphia Electric Company's process for performing safety evaluations and reviews of procedures pursuant to 10CFRSC.59'to determine.if the' process

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is currently effective or if improvements are needed.

The NRC requires that this plan describe:

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1) - the qualifications of the appraisal. team members, and a discussion of their degree of independence,-regarding areas reviewed;

2) the methods of performing the appraisal and documenting the results;

2) the schedule for completion of appropriate milestones; and

4) the methods for resolving appraisal findings in a timely manner.

Appraisal Team The Appraisal Team will consist of employees of an outside consultino company who are technically and administratively indepence~nt of the current procedures and methods for per forming safety-evaluations and - procedure reviews

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at the Peach Bottom' Atomic Power-Station.

This Appraisal Team

. will consist of personnel having. extensive experience in nuclear plant operations, development of procedures for BWR plants and plant administrative controls.

The resumes of these personnel p, "^< '

will be available for review if desired.

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ATTACHMENT A Page 2 Meth9 _9$_0EPiaisal d

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The Appraisal will consist of 2 Phases: ~ Assessment and Evaluation.

The Assessment Phase will consist of the following

' elements.

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1.

Existing Controls - This element will examine and 35319z3 plant management controls, procedures, and 4

directives related to.a)-safety evalu\\ ions for-plant changes, b)-safety evaluations for-procedures and procedure changes and c) review process'for plant procedure changes.

This information will be

-used to determine whether appropriate procedures and controls exist,-and if they are adequate.and useful.

D. we 2.

Implementation - This element will exam' e and a5alyze a representative cross section of safety Sysu 4ci d evaluations and procedure reviews / approval results that have been performed over. the last. few months.

This information will:be used to determine if management controls, procedures and directives-are 4

l implemented and to determine the completeness and-1 accuracy of the documents that attest to the implementation.

3.

Interviews - This element will involve interviews 61 personnel who perform ' functions essential to the preparation of safety evaluations and procedure reviews / approval.

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e The Evaluation Phase includes the integration and evaluation of the information determined during the Assessment Phase.

The Evaluation Phase will be comprised of 2 elements, - 1).

Statements of Effectiveness and, 2) Improvement Recommendations (if needed).

1.

Statements of Effectiveness - For each significant'

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ilemeht 61 EEEigiEEEt 6ont ol, procedural adequacy, 1

or implementation technique, a Statement of Ef fectiveness will be assigned.

The statements will be classified as adequate or inadequate.

The judgements of adequacy will, be based on technical i

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ATTACHMENT =A-Page_ 3 specification requirements and generallyLaccepted professional management / administrative: standards,-

including those derived from. analysis of NRC Performance Appraisal Inspection Reports.

2.

Improvement Recommendations -

In each instance.

l wEeii iE iIimi5t 5I i nE55ess'is determined to be-inadequate, suitable recommendations' will be developed.'

These recommendations will constitute i

the. actions necessary to resolve findings.

In general, such' resolutions will' include;the actions necessary to achieve an adequate evaluation of any element previously rated inadequate.

1 gghggy}g Upon approval of this Appraisal Plan by.the Regional Administrator, Region I, of the Nuclear Regulatory Commission, i

this Appraisal Plan will be implemented in accordance with the following schedule.

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2 Completion of Assessment Phase 10 weeks lh he*

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Completion of Evaluation Phase 14 weeks Submittal of Final Report 18 weeks 4,;

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75 The Statements of Effectiveness (findings) and I

g.bg Improvement Recommendations will be transmitted: simultaneously to I

44 the Philadelphia Electric Company and the Regional Administrator, pr Region I of the Nuclear Regulatory Commission.

These. findings

,r and recommendations will be evaluated tur the appropriate

',pV',.-r#,)f organizations within the Philadelphia Electric-Company.

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9 The resolutinn of these findings and recommendations will be og' d#p s'uEmitted to the NRC within 90 days or tne issuance of the

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Appraisal Team's report.

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ATTACHMENT B PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 A_P_P_RA_ I. S AL__PL_AN FOR__T_H__E__REVEIW OF

_P E ACH___BO_T_T_O_M__A_T_O__M_I C_ __POWE R_S_T_ AT_I O_ N_' S PLANT AND_ SYSTEM _ OPERATING _ PROCEDURES ~

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ATTACHMENT =B APPRAISAL. PLAN FOR THE REVIEW OF PEACH BOTTOM ATOMIC POWER STATION'S PLANT AND SYSTEM OPERATING PROCEDURES-August 1984 Intigduction' The Nuclear Regulatory Commission's (NRC) - Order -

Modifying License. Effective Immediately, issued June 18,11984, requires an appraisal plan be submitted for _ approval by the' NRC for verifying that existing. Peach Bottom Atomic Power Station Units 2 & 3' plant -and system operating procedures.1) are-consistent with technica1' specifications, technical specification bases, and those sections of the Final Safety Analysis Report' j

(PSAR) concerning systems necessary to mitigate _ Design Basis Accidents, and 2) do notJinvolve unreviewed safety questions.

The NRC requires that this plan describe:

(1) the qualifications of the appraisal' team members and a discussion of their degree of independence, regarding areas reviewed; i

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(2) the methods of performing 'the -appraisal and: documenting the results; (3) the schedule for completion of appropriate milestones; and l-(4) the methods for resolving appraisal findingsLin a timely manner.

Appraisal Team The Appraisal Team will be directed by a Philadelphia c*'*

Electric Company employee who has a Bachelor's near. in_

ge m Enaineering or the Physical Sciences and has at least three years

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of professional level experience-in nuclear services, uuvrear pg,,

plant operations or nuclear engineering.

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ATTACHMENT B Pagh 2 N

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r-LThe other team members will consist of employees of art

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outside consulting company naving the qualifications described in

' Attachment A The Appraisal Team members are independent ; f rom -

The Peach Bottom Atomic Power Station staf f and are not responsible for the preparation, approval, or use of the-procedures that will be reviewed..

Methgd_gf_Appgaisal

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There are an estimated 4000-station-procedures in 24 categories at-the Peach Bottom Atomic Power Station.

These categories are itemized below.

1.

Administrative Procedures (A) 2.

Chemistry Analytical-Procedures (CA) 3.

Emergency Procedures (E) 4.

Emergency Plan Procedures (EP) 5.

Fuel Handling Procedures (FH) 6.

General Plant Procedures (GP) 7 Health Physics Analytical Procedures (HPA)

8.. Health Physics Chemistry Operating Procedures (HPO/CO) l 9.

Maintenance Procedures (M).

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Operational Transient Procedures (7P) 11.

Radiochemical Analytical Procedures (RCA) 12.

Reactor Engineering Procedures (RE) 13.

Systems Procedures - (S) 14.

Special Event Procedures (SE) 15.

Surveillance Test Procedures (ST) 16.

Surveillance Test-Emergency Plan Procedures (ST/EP) 17.

Surveillance Test-Inservice Inspection Procedures- (ST/ISI) 18.

Surveillance Test-Local Leak Rate Procedures (ST/LLRT) 19.

Routine Test Procedures (RT) 20.

Plant Protection Procedures (PP) 4 21.

Prefire Strategy Plan Procedures (F) 22.

TRIP Procedures (T) 23.

Modification Acceptance Test Procedures (MAT) 24.

Special Procedures (Special)

The Appraisal will consist of 3 Phases; S c_r_e e n i n g,

-Evaluation and Detailed Review.

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The Screening Phase will involve the development of a list of requiffE~ents tor th6 analysis of plant and system operating procedures.

The list will be established by the combination of the requirements contained in the Technical l

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ATTACHMENT B Page - 3 i

Specifications and-the FSAR.

The Screening Phase vill consist of-the following elements.

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1. -

Procedure Presentation' JThe Technical 5peEllicitIohi 353 the FSAR will be reviewed to~

i determine actions, set pointsj Limits, cautions, sequences and parameters which establish safe.

I conditions.

Based. on the criteria -presented below, the Appraisal. Team members will extract from the -

Technical Specifications and the rsax Inrormation which should be included in Plant or System operating procedures to fulfill the requirements or as m tinna of..the. Technical Spectri_ cations and-the~

FSAR.

For the purpose of this appraisal, T ch -

infbrmation 'is labeled a Procedure Presentation item.

A Procedure Presentation: item can be a value, condition, action, caution or sequence that is included in a _ procedure as a ~ precaution, a-limit, a set point,_or an action step.

The criteria used to' determine whether'information is a Procedure. Presentation _ item are'the following:

I a.

The information establishes conditions that Operations, Supervision, and Shif t Operations Personnel must know for safe operation.

b.

Information that warns shift Operations Personnel of off normal conditions.

Information that establishes the equipment in c.

Systems in operation or available to be in operation to meet the limiting conditions for operation.

d.

Information necessary to monitor the-automatic-action of system and equipment controls for-normal operation.

Information necessary to verify the action e.

and/or response of automatic controls for i

ATTACHMENT B ~

Page 4 protective devices when abnormal or emergency-conditions occur.

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Information to guide shift operations personnel in the performance of. plant operations and system evolutions to maintain system, parameters, and equipment.

configurations within established safe boundaries.

2.

Screening List - The information derived from the-Pf6ci3ufe Piisentation element will be presented. in a list that tabulates.the.information by plant system and by general plant application for information not categorized by system.

3.

Procedure Analysis - The Screening List will be Uii3 EP EEE K5pfaisal Team to_ determine wnetner the Pr6Ei3ure Presentation __ilems_have'been included in~

appr9arlate plant or system operating procedure.

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In the course of the procedure analysis,- the Appraisal Team will note, on the list, any-Procedure Presentation itet: that do not match the value of the information, or do not appear. to be properly used or properly stated in the procedure.

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_The Evaluation Phase will consist-of carefully ~

scrutinizing the Screening List in order to determine whether or

}ruit there is a procedure omission or a procedure deviation.

1.

Procedure Omission - When items requiring Procedure PrisenE3EI55 5fe not found to be included in the.

plant and system operating procedures, the' item i

will be scheduled for a detailed review.

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-Procedure Deviation

-When items are determined to l

Bi IE E55EIIEE with, inconsistent =with, or_ vary significantly from the values,. terms or status of the Procedure Presentation item, they will be scheduled for a detailed review.

If a Procedure Presentation item appears to be improperly cited or improperly applied in a procedure, or. appears in an

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ATTACHMENT B Page 5 i

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inappropriate procedure, that item will be scheduled for a detailed review.

The Detailed Review Phase will be completed on the 2 types of potentially advFf ou -..GTEions~~Tprocedure omission and procedure %-ion) which may be identified in the Evaluation l

Phase.

The Detailed Review Phase will' consist of the following elements.

1.

Procedure Review -When a Procedure Presentation Itim 36ei 66t Eave a corresponding procedure application, a more exhaustive review of the most likely operating procedures to contain this.

information will be conducted.

If a Procedure Presentation item is found in another procedure, the detailed review will be terminated for that item.

If the Procedure Presentation item is not located in this manner, the next element in this phase is mandated.

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Procedure Research - This element will be conducted 23r I55tiEcii wheie a value, sequences, or limits in the procedures differ from the values, sequences, or limits of the Technical Specifications or FSAR.

This'research would reveal whether the preceanres currentIV in use may constitute an unteviewed safety questions. ^

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Upon approval of this Appraisal Plan by the Regional Administrator, Region I, of the Nuclear Regulatory. Commission, this Appraisal Plan will be implemented in accordance with the following schedule.

Milestones Time after Receipt _of_ Approval Team Orientation and Assignments 2 weeks Completion of Screening Phase 6 months Completion of Evaluation Phase 8 months Completion of Detailed Review 3

T Phase 11 months

1. 4 Submittal of Final Report-12 months "Y

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Any suspected inconsistencies-between the procedures and i

the. requirements of the Technical Specifications and the Final Wa# L #"

Safety. Analysis Report which could af fect the safe operation of h,~

the plant will be brought _ to the attention aof the. Plant Operations Review Committee (PORC) by the Apprais'al Team Leader.

If the PORC determines that an'unreviewed' safety question exists, 4s+J* f*E i

the Regional Administrator, Region I, o'f the Nuclear Danulatory 4 r)L- '

i JCommission will be notified by the Acoraisal Team-Leader and the chairman of the PORC will notifv Electric Production'Denartment (inagement.

Discussion of the unreviewed safety' question add.

pI~anned corrective -action will'be documented in the PORC meeting

minutes, i

e Other inconsistencies between the. procedures and' the requirements of the Technical Specifications and the FSAR which

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do not affect the safe operation of the plant will be documented gpf neri+ '

in a final. report of the Appraisal Team along with recommendations regarding the resolution of these O 'l,,,D.

inconsistencies.

The Appraisal Team's report will tm transmitted -

p s. ly simultaneously to the Philadelphia Electric Company.and the Regional Administrator, Region I, of the Nuclear. Regulatory

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Commission.

The resolution of these findings and inconsistencies wF will be submitted to the NRC within 90 days of the issuance of -

the Appraisal Team's report.

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ATTACHMENT C PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 A__P PRA__I S A__L__P_L AN FO_R_T_H_E_R_EV_I E_W O__F EglL3pELEyl3_gg{gTR{g,gOgg3N]ig i

PROGRAM FOR ENSURING QUALIFICATION OF PERSONNEL REVIEWING AND APPROV_ING OPERA _T__ING___P_R_OCEDU_RE_S August 1984 G

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ATTACHMENT C APPRAISAL PLAN FOR THE REVIEW OF PHILADELPHIA ELECTRIC COMPANY'S

~ PROGRAM FOR ENSURING QUALIFICATION OF PERSONNEL REVIEWING AND APPROVING OPERATING-PROCEDURES August 1984 Introduction The Nuclear Regulatory Commission (NRC) Order Modifying License Effective Immediately, issued June 18, 1984, which addresses the Peach Bottom Atomic Power Station, Units 2 & 3, requires an Appraisal Plan be submitted to the NRC for approval for the review of the Philadelphia Electric Company's program for ensuring that_emplovees involved in the review and approval of g

the operprind procedures at the Peach Bottom Atomic Power Station remain cognizant of the licensing bases.

The NRC requires that this plan describe:

1) the qualifications of the appraisal team members, and' a discussion of their degree of independence, regarding areas reviewed;

2) the methods of performing the appraisal and documenting the results;

3) the schedule for completion of appropriate milestones; and

4) the methods for resolving appraisal findings in a timely manner.

Appraisal Team The Appraisal Team will consist of emolovean

^F the Philadelphia ElectrTU CUMpany.

Each team member has a Bachelor's Deg' fee in Engineering or the Physical Sciences _ and has at least

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three years of professional level experience in nuclear services, nuclear plant operation, or nuclear engineering.

The Appraisal Team members are technically and administratively independent of the current procedures and I

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ATTACHMENT-C Pcge 2-methods.for-reviewing and approving operating-procedures.at.the I

Peach Bottom Atomic Power Station..

. Method of Appraisal The appraisal will consist of 2_ phases:. Assessment and-Evaluation 2, The Assessment. Phase wil,1 consist of the following elements.

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Qualifications - This element will' examine' qualifications of individuals involved in the review and approval of operating: procedures.

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Training - This element will examinefthe program to educate the individuals involved in the' review and e

approval of operating procedures about licensing i

bases.

3.

Retraining - This element will examine the methods to~ inform individuals involved in the review and l

approval of operating procedures about-changes.to the licensing bases.

The Evaluation Phase includes ~the integration and evaluation of the information determined during the Assessment-Phase.

The Evaluation Phase will be comprised.of 2_ elements, Statements of Effectiveness and Improvement Recommendations.'

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Statements of Ef fectiveness - For each 'significant element of the qualification, training and retraining programs, a Statement of Effectiveness will be assigned.

The statements.will. twt-classified as adequate.or inadequate.

2.

Improvement Recommendations - In each instance where an element of the process is determined to be inadequate, suitable recommendations will be developed.

These recommendations will constitute the actions necessary to-resolve findings.

In.

general, such resolutions will include the actionsi I

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AhTACHMENT'C Page[3 necessary to achieve an adequate evaluation-of any element previously rated inadequate.

Schedule

'Upon approval of this Appraisal Plan-by the Regional Administrator, Region I, of the Nuclear Regulatory Commission,.

this Appraisal Plan will be implemented in accordance with the following schedule.

Milestones Time af ter Receipt of Approval Completion of Assessment Phase 4 weeks f- (g [g Completion of Evaluation Phase 8 weeks Submittal of Final Report 12 weeks Resolution of Appraisal Findings The Statements of Ef fectiveness (findings) and Improvement Recommendations will be transmitted simultaneously to

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the Philadelphia Electric Company and the Regional Administrator, Region I, of the Nuclear Regulatory Commission.

These findings and recommendations will be evaluated by the appropriate organizations within the Philadelphia Electric Company.

The resolution of these findings and recommendations will be submitted to the NRC within 90 days of the issuance of the Appraisal Team's report.

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