ML20214D123
| ML20214D123 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/20/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20214C938 | List: |
| References | |
| FOIA-87-185 NUDOCS 8705210216 | |
| Download: ML20214D123 (10) | |
Text
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PHILADELPHI A ELECTRIC COMPANY 2301 M ARKET STREET
- P.O. BOX 8699 PHILADELPHI A. PA.19101 t2is 84is% ctober 20,-1986 smoos t. oauaorr stec n$c"raSNeo=
Docket No. 50-277 50-278 Inspection Report Nos. 50-277/86 50-278/86-13 Mr. William F. Kane, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
REFERENCE:
- Letter, M. J. Cooney, PECo, to W. F. Kane, NRC, dated October 1, 1986
Dear Mr. Kane:
Your letter dased September 2, 1986 forwarded the results of the Diagnostic Team Inspection (Combined Inspection Report Nos.
50-277/86-12; 50-278/86-13) conducted at Peach Bottom Atomic Power Station during the period from June 18, 1986 to July 3, 1986.
We are pleased with your findings that the programs at Peach Bottom are fundamentally sound.
We believe that the plant is being operated safely.
We can understand your perception relating to our dependence on third partie,s to identify problems ~because__of findings made by your inspectors as well as comments made by INPO.
We do believe, however, that if'it were not for the current heiv workload which is directed towards correcting deficiencies stemming from plant staff involvement in pipe replacement and repair, that the staff would be in a more proactive mode relating to the i
identification of problems.
These pipe replacement and repair outages ran much longer than scheduled and required continuing staff involvement.
Also, we believe some of our perceived weaknesses in aggressively following up corrective action plans stem from these same causes.
To_strengtheitstaf_faf fecti_veness, we have engaged orofessional assistance to ass _i_si_witttorocram development and **
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_mL41AtLenance_du. ring this recovery period.
Further, witn regard to accountability and the assessment of program effectiveness, we have identified the need to improve management skills at both the senior and supervisory level.
It is expected that, with improve managerial skills, better accountability will result.
gg 4, g 7_j p3-8705210216 870514 N
PDR FOIA MORIART87-185 PDR 9(,- 4 t '
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Mr. W)lliam F.
Kane October 20, 1986 Page 2' Improvements in the formalization of our goal / task management system will focus responsibilities and accountabilities on groups and individuals.
Program deficiencies and degradation of effectiveness will be identified in a more timely manner.
To'a large extent, we believe our perceived weaknesses reflect slippages in our relative effectiveness when compared to other plants because of their continued improvement during these past years during which we remained effectively arrested because of the major modification work.
Your letter requested that Philadelphia Electric Company (PECo) respond to one Notice of Violation and sixteen Licensee Response Items.
Our response to the Notice of Violation was provided to you in the referenced letter.
The purpose of this letter is to complete our response to the Inspection Report by providing our response to the sixteen Licensee Response Items.
The delayed submittal o,f this portion of our response was discussed with Mr. Peter Eselgroth (NRC) and found to be acceptable.
The sixteen Licensee Response Items are restated below followed by our response to each item.
I.
Licensee Response Items 1.
Address the concern that the " Chief" Operator may direct the licensed activities of the Unit Reactor Operators, as defined in 10 CFR 55.4(e), without holding a Senior Reactor Operator license.
(277/86-12-01; 278/86-13-01)
A control room Shift Supervisor holding a Senior Reactor Operator license oversees the licensed activities of the Unit 2 and Unit 3 reactor operators.
The Chief Operator's duties, which may include communicating with the unit operators for the purpose of coordinating activities, are performed under the direction and supervision of the control room Shift Supervisor.
The control room Shift Supervisor is located in close proximity to the rgactor operators and the Chief O ierat~or'and-heds kept.fullp'
~
E apprise,d of all activit _ies in the control room.
Inordertostresstheimportanceoftherequi)ements specified in 10 CFR 55.4(e), a memorandum will be issued by station management directing that all reactor operators and senior reactor operators review 10 CFR 55.4(e).
This memorandum will be issued by October 31, 1986.
2.
Improve control room logs and records such that they deflect f
the professional mariner in which personnel actually perform their duties.
(277/86-12-02; 278/86-13-02)
The requirements for maintaining log books are specified in Administrative Procedure A-7 titled " Shift Operations"
Mr. William F. Kane
' October.20, 1986 Page 3~
A-7 was recently revised based on INPO Good Practices OP-205 to ensure proper use of log books.
3.
Address the potential for presently assigned Shift Superintendent administrative duties detracting from plant operation oversight responsibilities.
~
(277/86-12-03; 278/86-13-03)
To resolve this concern, PECo plans to provide certified-BWR contract engineers'until additional licensed operators O iy@r 4
are available.
PECo is evaluating the need for additional licensed operator support within each shift, especially during outages.
This evaluation involves a comprehensive determination of present and projected operations group needs based on realistic appraisal of upcoming work and training.
An accelerated training and qualification program has been instituted to provide additional licensed operators to fill vacant positions, to replace anticipated losses, and to provide for absences.
The administrative duties of the Shift Superintendent are currently being reviewed.
The results of this review are expected by November, 1986.
I 4.
Address the concern that not all information tags may be located during an audit due to absence of serial numbers, log, or other form of tracking system.
(277/86-12-04; 278/86-13-04)
To resolve this concern, a system will be developed for tracking information tags.
This system will be implemented by March, 1987.
5.
Address and correct paging system deficiencies and abuse.
(277/86-12-05; 278/86-13-05)
A planned modification will provide for a significant upgrade of the plant public address system.
One feature of the new system will be separate page buttons for the control room and the balance of the plant.
Depressing the general page button will page the plant bu' not the c
control room.
Depressing the other page 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.
This modification is expected to be completed by June, 1987.
e Additionally, a modification is being planned to install a computer controlled system which'can identify the paging units in use throughout the plant.
The. system can be used to identify the location of paging system abusers and will have the capability to silence specific units.
-.. - ~ ~. -
~ _
-, ~ _
m LMr.JWil'liam F. Kane
.OctoberL20;D1986
.Page'4-
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'6..
~. Conduct failu're analysis of"MO'-2-02-074: and compare'resultsL with the valve's environmental qualification analys'isi
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(277/86-12-07)
A failure analysis has been prepared 2forJthis.eventiand is.
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currently undergoing management revi'ew.- Preliminary n
-review indicates-that-the environmental qualification is satisfactory.
We expect the analysis report to be-
-available for NRC review by November 10, 1986.
L 7.-
Address.theLstatus.of-the review of health physics _ group l
organization and staffing, and plans to address findings.
~
(277/86-12-09; 278/86-12-09)
L l
A' study has been conducte'd of:the Health (Physics,
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j organization to determine additional' human resource requirements.
Additional personnel'will be.added to the?
I Health Physics organization.
Professional level-personnel with radiation protection experience are'being: recruited and when available will be assigned _to shift positions'in
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Radiation Protection.
Position Guides and procedures to 4
reflect the organizational changes will be upgraded to j
reflect the responsibility and the authority of'the Health-Physics organization.
This upgradingLis expected to-be i
f completed by July, 1987.
(
8.
Improve training program for health physics technicians.
l (277/86-12-10; 278/86-13-10) t' Our training program for Health Physics technicians has j
recently been accredited by INPO. - The Director, Radiation Protection Section, is reviewing theftraining programs for l
the Professional Health Physics personnel as well as the j
Health Physics technicians.
This review will determine the upgrading actions necessary for these training i
programs.
This review and upgrade is expected to be I
completed by March, 1987.
1 9.
Address the need to formally establish the corporate radiological controls assessment program.
l (277/86-12-11; 278/86.13-11) i l
The Diagnostic Team Report noted that " Assessments of site radiological controls activities (e.g., respiratory f
i protection) are performed by the Corporate Radiological 1 I
Control Group; however, the Corporate Audit / Assessment Program is not' formally established and written' reports of j
findings are not provided to the site".
To~ address this' the Director, Radiation Protection.Section, wilA-j
- concern, formally establish Radiation Protection Section routide f
1 audits and assessments of Peach Bottom programs and practices, including timely written reports of-the-4 periodic' assessments.
These audits and assessments are-expected to be established by December, 1986.
4 l
. Mr.2 William'P. Kane October 20,.1986 Page 5 I
10.
Address concern that needlessgexposure results from conducting radiation surveys.to support Radiation _ Work
[
Permits-which aresnot used:or are-not used withinfa: period l
of'several days such that additional surveys.areirequired.
-(77/86-12-12; 278/86-13-12)
Maintenance. planners have been established to prepare.
n complete work packages for daily. maintenance' work andufor i
items on forced-outage lists.
Principal functions of'the.
planners 1are to plan each job and assure that procedures, work instructions, drawings, parts, and-materials are.
L available, and to coordinate-with the HP/ALARA representative to obtain ALARA review-and initiate =RWP requests in advance..
A daily "10:00 a.m. meeting"chas been established.
A l
five-day schedule is, prepared and. updated at'this meeting for the purpose of coordinating the tasks-being performed 4-i by the various work groups.
i Further, PECo is anticipating establishment of mid-shift meetings between Maintenance, Shift HP, and Operations l
Shift Supervisor to consider blocking permits and RWPs for next shift.
p These-meetings and the improved planning will help to ensure that only needed radiation work permits are prepared.
y s
11.
Address concern that oversight and control of work.and activities by the Health Physics Technical Group-is j
inadequate.
(277/86-12-13; 278/86-13-13)
I As discussed in the item 7 response, the Health Physics j
organizational structure will be revised to enhance i
operational performance.
New Physicists will provide-i additional oversight.
During the restructuring, l
consideration will be given to ensuring that oversight and control of Health Physics work and activities are 4
adequate.
l!
4 12.
Address the practice of using informal health physics il
" guidelines" and not incorporating them into appropriate controlled station procedures.
(277/86-12-14; 278/86 l 14)
-)
1-The Diagnostic Team Report noted that "Various supervisors in the Health Physics-Group have issued memoranda and j
j
" guidelines" to interpret and'aupplement~ existing sith,
j health physics procedures.
Topics discussed in these memoranda and guidelines included dosimetry placement, exposure controls, and airborne radioactivity sampling.
The licensee has no effective admini trative controls in I
i 1
i
,,__ w
Mr. William F. Kane October 20, 1986 Page 6 j
i place to ensure all appropriate personnel have read, understood, and implement the memoranda.and guidelines."
j
~
The Teach Bottom Senior Health Physicist is di.recting1the upgiuding offthe station health 1 physics procedures.
During this upgrade, special attention is'being given to' incorporating the memoranda and-guidelines information-into the station health phys cs1 procedures..LUpgrading of:
these procedures is expecte3 to be completed by June, 1987.
l 13.
Address the need'for procedures for ALARA goal setting?and tracking.- (277/86-12-16; 278/86-13-16) 4 ALARA goals are currently set on a case-by-case basis.- In conjunction with the Health Physics' procedures upgrade j
discussed in item 12, procedures 1for ALARA goal-setting and tracking will-be developed.- These procedures are
~
expected to be completed.by June, 1987.
4 14.
Establish tracking system for the resolution'of-QA audit recommendations.
(277/86-12; 278/86-13-16)
I A new Quality. Assurance Division Procedure (QADP) for the issue and control of Audit Recommendations will be issued by December 15, 1986.
i 15.
Formalize QA control room review activities.
(277/86-12-18; 278/86-13-18)
The Quality Assurance Division, Quality' Control Section, includes Plant Operations in the QC Monitoring Program.
l Control room activities are currently being included as part of the formal scheduled Quality Control Plant' i
Operations Monitoring Program.
16.
Define the scope of Routine Tests (RTs) and administratively control their preparation and issuance, and address the missing emergency procedures to meet regulatory requirements.
1.
(277/86-12-19; 278/86-13-19)
A review and upgrade of Peach Bottom administrative-procedures is planned.
The need for incorporation of RTs into an administrative procedure will be assessed at that time.
This review and upgrade is expected to be completed by June, 1988.
Regarding the concern that there are procedures missisg '
i for combating emergencies and'other significant events as identified-in Regulatory Guide 1.33, we offer the following.
Rather than use. event oriented step-by-step-emergency procedures, Peach Bottom' utilizes the Transient j.
Response Implementation Plan (TRIP) procedures which 1
_Mr. Wil*liam F. Kane October 20, 1986 Page 7 I
provide the operators with methods for symptomatically addressing abnormal plant conditions.
Most of the Peach Bottom emergency procedures were phased out as the TRIP procedures were implemented (in accordance.with NUREG-0737) because events addressed by the emergency procedures-are now enveloped.by the TRIP procedures.
With the TRIP procedures in place,'all contingencies are cov_e' red and.
therefore there are no missing emergency procedures.-
i-l Should you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours,
/
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T.
P. Johnson, Resident Site Inspector l
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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OFFICE OF PUBLIC AFFAIRS, REGION I g
j 631 Park Avenue, King of Prussia, Pa.19406 Tel. 215 337-5330 No. I-87-56
Contact:
Karl Abraha-March 31, 1987 NRC STAFF ORDERS SHUTOOWN OF PEACH BOTTOM NUCLEAR POWER PLANT The Nuclear Regulatory Commission staff has ordered Philadelphia Electric Company to shut down its Peach Bottom Nuclear Power Plant at Delta, PA. The company is licensed by NRC to operate two units at Peach Bottom. One unit already is shut down for refueling and the other unit must be brought to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> under terms of the NRC order. Neither unit may be restarted without NRC approval.
In its order, signed by Victor Stello, Jr.,
Executive Director for Operations, the NRC staff said:
"On March 24, 1987, the NRC, Region I, received information that control room operators at peach Bottom had been observed sleeping while on duty in the control room and were otherwise inattentive to their license obligations. The information also indicated that this conduct on the part of operators was pervasive and has been occurring for some time, and that shif t supervision had knowledge of this situation.
On March 24,
- 1987, in response to this information NRC Region I initiated:
(1) 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inspection coverage of the Peach Bottom control room and (2) a special safety investigation of licensed activities.
The NRC investigation, which is still ongoing, to date has established:
"1.
At times during various shif ts, in particular the 11:00 p.m. to 7:00 a.m. shift, one or more of the Peach Bottom operations control room
{
staff (including licensed operators, senior licensed operators and shift supervision) have for at least the past five months periodically slept or have been otherwise inattentive to licensed duties.
"2.
Management at the Shift Supervisor and Shif t Superintendent level have either known and condoned the facts set forth in Paragraph one, or should have known of these facts.
"3.
Plant management above the shift supervisor position either knew or should have known the facts set forth in Paragraph one and either took no action or inadequate action to correct this situation."
F0 1 /1 - V 7~' W (more)
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'2 The NRC staff said that prior NRC inspections have identified other instances of inattention to duty or' failure to adhere to procedures on the part of licensed operators in the control room at Peach Bottom.
The or' der said:
"The NRC expects licensees. to maintain high standards of control room professionalism. NRC licensed operators in the control rooms at nuclear power plants are - responsible for assuring that the facility is operated safely and within the requirements of the facility's license, technical specifications, regulations and orders of the NRC.
To be able to-carry out these highly.
i important responsibilities, reactor operators must give their full attention to i
the condition of the plant at all times. - Operators must be alert to ensure that the plant is operating safely and must be capable of taking timely action i
. in response to plant conditions. All control room business must be conducted
- in such a way that neither control room operator attentiveness nor the pro-fossional atmosphere will be compromised.
Sleeping while on duty in - the
- control room demonstrates a total disregard for performing licensed duties 1
and a lack of appreciation for what.those duties entail."
NRC. regulations prohibit sleeping or otherwise inattentive operators.
Under the regulations the licensee must have and implement procedures to ensure that activities affecting quality, including operations of the facility are 4
satisfactorily accomplished.
The Peach Bottom quality assurance program has failed to identify this condition adverse to safety, i
"In light of the above, it. is apparent that ' the licensee, through its enforcement history and from what has been developed by the ongoing investiga-tion, knew or should have known of the unwillingness ~ or inability of its operations staff to comply with Commission requirements, and has been unable to j
implement effective corrective action.
Consequently, the NRC lacks reasonable assurance that the facility will be operated in. a manner to assure that the i
health and safety of the public will be protected. Pending the development of other relevant 'information, I am unable to determine that there is reasonable 1
assurance that -the facility will be operated in-a manner to assure that the health and safety of the public will be protected. Accordingly, I have deter-mined that continued operations of the facility is an immediate threat to the public health and safety. Therefore, I have determined that the public health, safety and interest requires that the licensee should proceed to place or main-j tain its units in a cold condition."
The order requires that, within seven days, Philadelphia Electric provide the administrator of NRC's Regional Office its plans ' to assure that the i
facility will comply with all requirements.
4 The Commonwealth of Pennsylvania and the State of Maryland have been informed of this enforcement action.
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