ML20214L455
| ML20214L455 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/27/1986 |
| From: | Collins S, Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214L442 | List: |
| References | |
| 50-277-86-12, 50-278-86-13, NUDOCS 8609100157 | |
| Download: ML20214L455 (74) | |
See also: IR 05000277/1986012
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket / Report No. 50-277/86-12 and 50-278/86-13
Licensee: Philadelphia Electric Company
2301 Market Street
Philadelohta, Pennsylvania 19101
Facility: Peach lottom Atomic Power Station Units 2 and 3
Location: Delta, Pennsylvania
Dates: June 18 - July 3, 1986
Inspectors: T. Shediosky, Senior Resident Inspector, Millstone Unit 3
(Shift Inspector)
W. Bateman, Senior Resident Inspector, Oyster Creek (Shift
Inspector)
J. Beall, Project Engineer (Shift Inspector)
J. Williams, Resident Inspector, Peach Bottom
E. Kelly, Senior Resident Inspector, Limerick
T. Johnson, Senior Resident Inspector, Peach Bottom
R. Nimitz, Senior Radiation Specialist
G. Smith, Safeguards Specialist
Reviewed by
Inspection
h27f96
R. M. Gallo, Chief, Reactor Projects Section Date
Manager: No. 2A, Division of Reactor Projects
Approved by
Team S. J. Collins, Chief, Re&ctor Projects
At 8!37 8
Date
Leader: Branch No. 2, Division of Reactor Projects
Inspection Summary: Inspection No. 50-277/86-12 and 50-278/86-13
Areas Inspected: This special team inspection reviewed
licensee programs and their application in management effectiveness, plant
operations, maintenance, surveillance, radiological controls, assurance of
quality, fire protection and housekeeping, security, and event analysis.
Inspection efforts by the team totaled 640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br />.
Results: A violation associated with overdue surveillance testing program
application and oversight is discussed in detail 7.3. Outstanding items
requiring licensee response and inspector followup are summarized in
Attachment 2 to this report.
8609100157 860902
PDR ADOCK 05000277
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TABLE OF CONTENTS
Page
1. Background............................................ I
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2. Inspection Process.................................... 1
3. Inspection Summary.................................... 2
4. Management Effectiveness.............................. 3
5. Plant 0perations...................................... 4
5. 1 Operations Program............................. 5
5, 2 Operating Procedures........................... 6
5. 3 Operations Staffing............................ 7
5. 4 Operating Logs................................. 8
5. 5 Control of 0vertime............................ 9
5. 6 Control and Oversight of Activities...... ..... 9
5. 7 Personnel Attitude Towards Nuclear Safety...... 10
5. 8 Plant Paging System............................ 11
5. 9 Response To Off Normal Conditions.............. 11
5.10 Verification of Coupling Control Rod Drive
Mechanimi 30-15 With Its Control Blade
(Unit 0)..................................... 12
5.11 Summary.............. ......................... 12
6. Maintenance................................. ......... 13
6. 1 Maintenance Program............................ 13
6. 2 Maintenance Activities......................... 22
6. 3 Maintenance Staffing..........................<. 30
6. 4 Maintenance Interfaces and Communication....... 32
6. 5 Personnel Attitude Towards Nuclear Safety...... 39 3
7.
6. 6 Summary..... ......................
Surveillance..........................................
........... 41
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7. 1 Surveillance Prcgram........................... 42
7. 2 Surveillance Activities........................ 42
7. 3 Control and Oversight of Activities............ 43
7. 4 List of Tests 0bserved......................... 44
7. 5 Summary........................................ 44
8. Radiological Controls................................. 44
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8. I Genera 1........................................ 44
8. E Organization and Staffing...................... 45
8. 3 Training and Retraining........................ 45
8. 4 Audits......................................... 46
8. 5 Job Planning and Work Contro1.................. 47
8. 6 Control and Oversight of In-Field Work......... 47
8. 7 Procedures..................................... 48
8. 8 Communication.................................. 48
8. 9 ALARA.......................................... 49
8.10 Corrective Action Program...................... 50
8.11 Overtime.(Health Physics)................. .... 50
8.12 Goa1s.......................................... 50
8.13 Summary........................................ 51
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Table of Contents 2
9. Assurance of Quality.................................. 51
9. 1 QA/QC Program................................... 51
9. 2 QA Activities................................... 52
9. 3 QC Activities................................... 53
9. 4 Procedural Controls............................. 53
9. 5 Other Quality Activities........................ 54
9. 6 Summary......................................... 56
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10. Fi re Protection and Housekeeping . . . . . . . . . . . . . . . . . . . . . 57
10.1 Housekeeping and Plant Conditions............... 57
10.2 Fire Protection Activities...................... 58
10.3 Summary......................................... 62
- 11. Security.............................................. 63
l 11.1 Shift Inspector Observations.................... 63
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11.2 Security Specialist Observations................ 64
11.3 Summary......................................... 65
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12. Event Analysis........................................ 65
12.1 Unit 2 Loss of Emergency Service Water (ESW).... 65
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12.2 Group IIA Primary Containment Isolation
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of Reactor Water Cleanup System (Unit 3)...... 68
13. Management Meetings and Exit Interview
Attachment 1 - Persons Contacted........................... 70
Attachment 2 - Licensee Response Items and Inspector
Follow Items.............................. 71 +
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DETAILS
1.0 Background
On April 22, 1986, NRC Region I completed a System Assessment of Licensee
Performance (SALP) Board evaluation of Peach Bottom Atomic Power Station
for the period of April 1,1985 through January 31, 1986. That assessment
indicated that the licensee's performance had declined in the areas of
plant operations, maintenance, and licensing activities. Additionally the
area of assurance of quality was rated a category 3. This inspection was
conducted in order to better understand the nature of the licensee's efforts
in these areas and in areas where performance has been cyclic. The team
attempted to obtain a more complete understanding of the underlying reasons
for the licensee's performance discussed in the SALP report and to ascer-
tain whether they could have an adverse impact on the safety of plant
operations.
2.0 Inspection Process
The inspection consisted of a continuous review of plant activities by
three on-shift inspectors, followup inspection of shift-identified items,
dedicated reviews of licensee programs and their application in the areas
of plant operations, maintenance, surveillance, radiological controls,
assurance of quality activities, fire protection and housekeeping,
security activities, and a review of selected plant events which occurred
during the inspection period. The Team Leader met periodically with
licensee management to inform them of preliminary inspection findings and
observations.
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During the first nine days of the inspection the team consisted of the f
team leader, inspection manager, three shift inspectors, a technical !
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assistant (the Peach Bottom Senior Resident Inspector), a maintenance
inspection specialist (Limerick Senior Resident Insnector), and a resident
inspector. The shift inspectors provided 24-hour inspection coverage
seven days a wetk until June 27, 1986. The resident inspectors occasion-
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ally functioned as a shift inspector during this period. A security
specialist and a radiation specialist joined the team during the period of
June 23, 1986 through June 27, 1986. An exit interview was held at the
! conclusion of the inspection on July 3, 1986. Management observations were
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not discussed at the exit interview, although many of the topics were
discussed with senior licensee management during the inspection.
l The inspectors used the following evaluation criteria during their
j reviews:
1. Are management goals and objectives developed and implemented? Are
they understood by all levels of the licensee's organization?
2. Is there adequate planning and control of routine activities?
3. Do workers and their supervisors have a proper attitude toward
nuclear safety? Do they understand the potential impact of their
day-to-day activities on safety? ,
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4. Is senior management involved in the day-to-day operation of the
plant?
5. Is training, direction, guidance, and supervision by first line
supervisors effective?
6. Is staffing adequate in light of planned work?
7. How do the QA and QC program, and other management assurance of
quality tools monitor plant activities? How are reports by these
groups used by plant management?
8. How does the licensee work with and oversee contractor personnel?
9. Are the safety review committees effective?
3.0 Inspection Summary
The team found no evidence that the plant was being operated unsafely.
The team identified strengths and weaknesses similar to the 1986 SALP
report, with several exceptions: surveillance, maintenance, procedural
adherences and inattention to detail. The surveillance program was weaker
than observed during the SALP period. The maintenance program was
stronger than observed during the SALP period. Also, procedural adherence
and attention to detail during the review period were strong in the area of
operations which was in contrast to the longer term observations during the
SALP period.
The operators were knowledgeable, conscious of nuclear safety, had a
positive attitude, and performed in a consistently professional manner.
Weaknesses were noted with respect to log keeping, the administrative
workload on the Shift Superintendent and definition of onshift personnel '
duties and authorities. Overall plant housekeeping and the facility
upgrade program were considered a strength.
Maintenance activities observed during the inspection were also performed
well. The Maintenance Division organization is well staffed and trained.
A strong sense of pride among the craftsmen was observed. However, the
- plant staff maintenance group is understaffed in relation to the increased
demands of preventive maintenance, equipment history and trending.
The conduct of testing, use of surveillance procedures, and test review
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were good. The ability to implement and oversee the surveillance program
l was weak in that several safety system tests were found to be overdue (past
!- the Technical Specification surveillance interval) even though this problem
had been the subject of a previous violation and short-term corrective
actions. This finding constitutes an example of program implementation and
- accountability focused at an inappropriate level within the organization.
Additionally, quality audits conducted in this area failed to identify this
long-standing problem due to a concentration on program compliance with
procedures.
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Weaknesses were noted in the radiological controls area including
communications, training, staffing and the lack of an aggressive approach
to the planning and control of infield work activities. These findings
are particularly significant in light of the program challenges to be
brought on by the 1987 unit refueling and pipe replacement outages.
Selected reviews indicate that QA/QC implementation is focused toward
meeting program requirements. Weaknesses were noted in the qualifications
of auditors and the depth of QA audits in the health physics and surveillance
areas. OEAC and ISEG activities are considered a licensee strength. The
PORC and NRB are functioning well administratively, however, improvements
are required to ensure that operational quality is achieved and
maintained. The observation of NRB activities indicates that the board
may be deficient in the area of operational expertise.
Past security weaknesses have been noted by the licensee. However, no
formal written plan to improve the security area and assess the potential
impact of planned 1987 outage activities currently exists even though this
functional area has been assessed category 3 in the two previous SALP
periods. The licensee appears to have difficulty in achieving timely and
effective corrective action and is overly conservative in the approach
to co-control of the security contractor. The failure to implement and
properly focus oversight of aggressive corrective action programs
continues to be a weakness.
The licensee is currently implementing and tracking an overall site plan
to address identified hardware and program shortcomings. An initial
review of this plan in conjunction with discussions with site and
corporate representatives indicates that implementation and oversight is
focused on the site manager and that no corporate official has direct
responsibility or authority for program evaluation and assessment of
effectiveness. Additionally, direct assessment of program status is
performed only monthly in conjunction with mandated reporting to a
corporate executive. Targeting oversight of this type of program at the
site level seems inappropriate and a strong commitment to program imple-
mentation appeared to be lacking as evidenced by overdue program items and
l the absence of direct corporate management involvement.
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4. Management Effectiveness
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Licensee first line supervisors were strongly involved in station
activities and were considered effective during the inspection. The team
, noted that the first line supervisors were supported by their staffs who
! demonstrate a desire to complete work in a safe manner. Some areas have
shown recent improvement including establishment of management goals and
policies and overall plant housekeeping. Further dissemination of goals
and policies below the supervisor level is required. Extensive painting
and lighting efforts are underway to enhance the plant staff's ability to
maintain cleanliness.
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Previous NRC concerns have been confirmed during this inspection and in
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some cases additional problems have been identified. For example,
licensee followup on commitments and previously identified issues has
been a concern that was demonstrated, during the inspection, to be weaker
than previously understood. Specific areas of concern are security
i program corrective actions, surveillance program oversight and progress
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relative to the Peach Bottom Improvement Program. Specifically, the
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security area was rated category 3 for the-current and previous SALP
periods yet no documented improvement program was available and
management involvement was considered almost nonexistent. Surveillance
program implementation concerns were addressed to the licensee in
February 1986. The licensee's April 1986 response indicates a strong
management commitment to correct NRC identified concerns. However,
l during this inspection a lack of management attention or concern for the
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problems was evidenced by the existence of a large number of overdue
surveillance tests and general confusion regarding management of the
. program.
, The Peach Bottom Improvement Program, formulated in. response to the
December 1985 INPO evaluation, provides a detailed description of the
. required action as well as an updated status of individual actions. NRC
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discussions with the Plant Manager and the corporate engineer tracking
individual item status indicated that minimal senior management attention
or direction is being applied toward completion of improvement plan tasks
j and that was applied only when it was needed to update the PECo Chief
. Executive Officer. The focus of program oversight of the PBAPS Manager
- may be inappropriate given the breadth and demands of program t
implementation.
The failure to implement aggressive corrective action programs even after
problems have been identified indicates that Peach Bottom will have a
difficult time being able to correct station problems before they become
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apparent to third party review. Furthermore, it is apparent that only
minimal efforts are being made in the area of self-identification of
problems. In some areas, such as the expertise of NRB members and NRB
j' lack of involvement in operational activities, the licensee representatives
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demonstrated positive responsiveness to NRC concerns but in other areas,
such as oversight of the surveillance and security programs, licensee
- response appears almost totally without direction.
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5.0 Plant Operations
Operating activities were observed by NRC shift inspectors during the 1
l. period from June 19 through June 27, 1986. The areas observed included ;
control room activities such as the conduct of watchstanding, shift
i relief, operators response to abnormal plant conditions, surveillance
, testing, coordination of maintenance activities and logkeeping.
l Inspections of the plant were conducted by team members during this
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period. Limiting Conditions for Operation stated in the Operating
License Technical Specification were verified and licensee response
actions were monitored.
5.1 Operations Program
The facility is operated by a staff of plant personnel working in a
six (6) shift rotation. Its members hold NRC Senior Reactor
Operator Licenses, or NRC Reactor Operator Licenses; there are also
unlicensed plant operators. These individuals are supported by a
staff of engineering, technical and clerical personnel.
The Shift Superintendent is the senior member of the operating
shift. Both he and the Shift Supervisor hold Senior Operator
Licenses. These two individuals are responsible for directing the
operation of both Peach Bottom Unit 2 and Unit 3 reactors. Their
duties were found to be clearly stated in Administrative Procedure
A-7, " Shift Operations", Revision 21, dated November 21, 1985.
The inspectors determined that the on-shift operations staff met the
requirenents of Technical Specification 6.2.2 for the numbers of
personnel and types of licenses. However, the station and corporate
organization has been changed from that represented in Technical
Specification 6.2 figures 6.2-1 and 6.2-2. In each' case,
responsibilities of critical individuals have been split among two
others or non-nuclear production personnel have been relocated.
Specifically, in changes to the Station Organization, the Assistant
Superintendent has been replaced with a Superintendent of Plant
Services and a Superintendent of Operations. The Station
Superintendent is now titled the Station Manager. In the corporate
offices the Manager of Electric Production has been replaced by the
Manager of Nuclear Production and reports to the Vice President
Electric Production. The Superintendent, Nuclear Generating Division
and the Superintendent, Quality Assurance Division report to the
Manager of Nuclear Production. The responsibility for non-nuclear
production rests in a second organization reporting to the Vice
President Electrical Production. A Technical Specification change
request has been submitted to the NRC Office of Nuclear Reactor
Regulation and is under review.
Since the Station Manager must report through two other individuals
within the corporate organization before reaching the first corporate
officer, the Vice President Electric Production, the inspectors were
concerned that the needs of the station may not reach the proper level
within Philadelphia Electric Company. The reporting chain was examined
by the NRC inspectors and there was no evidence of a problem. The
Superintendent, Nuclear Generating Division is presently spending the
majority of his time at the Peach Bottom Station. He is responsible
for both Peach Bottom and the Limerick Station.
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The team recommends that the licensee monitor this situation and
ensure that the Station Managers of both the Peach Bottom and
Limerick Stations have clear and frequent access to a corporate
officer, having the authority to direct additional support and
funding when needed and not otherwise available through routine
channels.
An additional finding of the NRC team is the large number of people
supporting the facility on-site in engineering, operations and
maintenance who organizationally do not report through the Station
Manager. This matrix type of organization results in the Station
Manager not having direct control over several divisions performing
safety-related work on a full time basis. Since these workers may
not routinely work with station procedures and personnel site manage-
ment should be sensitive to the increased potential for coordination
and work control problems. The team's interface with these workers
found them to be skilled and highly motivated.
5.2 Ogerating Procedures
Plant operations is supported through administrative and technical
operating procedures. As part of the shift inspections, the NRC
personnel verified that the applicable procedures were in use. They
noted that, in general, procedures were technically adequate to
accomplish the intended activity. Sets of operating procedures,
located on carts, could be relocated in the control room for ease of
operations.
During the period of time the NRC team conducted its inspections an
unplanned plant shutdown was made of Unit 2 for maintenance and
repairs. The unit was returned to full power after a reactor
startup and second shutdown to replace faulty intermediate range
neutron monitoring detectors. Unit 3 remained at power, however load
reductions were made in response to condensate demineralizer
problems. These activities were monitored by the team which found a
strong practice by the operators to use the plant procedures.
The plant has implemented the symptomatic emergency operating or
Transient Response Implementation procedures (TRIP). These proce-
dures are in the form of logic chart diagrams and are located con-
veniently near the center of each unit's control area. The logic
diagrams were reviewed and found to be clear and easy to read. The
inspector confirmed that they were available during simulator
training classes. The operations staff presently uses the Limerick
simulator.
A good practice was noted in having copies of some annunciator alarm
cards posted in the plant. Cards containing the Emergency Diesel
Generator local control panel alarm response procedures are
available at each engine.
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5.3 Operations Staffing
The inspectors determined that each operating shift was staffed with
at least the minimum shift crew composition stated in Technical
Specification 6.2.2.a and shown in Figure 6.2-2. The specification
meets the requirements of 10 CFR 50.54.m.2.-i. Additional licensed
personnel were available for the Unit.2 reactor startup as required
by Technical Specification 3.3.B.b and 6.2.2.c as the startup-was
conducted with the plant Rod Worth Minimizer (RWM) bypassed because
of a faulty rod position indication reed switch.
Because the operators are generally in a six shift rotation, off-shift
personnel are normally available during the weekdays. When available
.these additional personnel allow a third Senior Licensed Operator to:
be stationed; he has the title of Outside Shift Supervisor and is given
duties partly administrative in nature but not physically restricted-
to the Control Room as is the Shift Supervisor. In addition, a fourth
Licensed Operator is assigned to process maintenance requests on
weekdays, relieving the on-shift personnel from this duty and
allowing that operator to devote attention to processing maintenance
requests. As a result, extra time can be devoted to verification of
Technical Specification Limiting Conditions for Operation, to research
system alignments for installation of safety tags and to determine
retest requirements. However, because of personnel limitations these
two positions are not normally filled on back shifts. Their presence
on shifts was observed as a notable strength. NRC team members have
observed them providing a meaningful contribution to' shift performance.
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i. During routine power operation, the NRC Licensed Reactor Operator
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assigned to the-controls of Unit 2 or 3 was available to devote his
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entire attention to that plant. A third Licensed Operator, the
Control Operator, and the two Senior Licensed Operators share their
r' attention between the two units and the performance of
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administrative functions.
The on shift NRC personnel monitored the performance of the licensed
personnel and found the positions filled with knowledgeable and
experienced personnel. The Control Operator and the two Senior
Licensed Operators remained appraised of plant conditions for both
units. At about 1:30 p.m., on June 24, 1986, the NRC inspectors
observed that the two Senior Licensed Operators and the Control
Operator responded quickly to an isolation of the Unit 3 Reactor
Water Cl.anup System. At the time, Unit 3 was at full power and
Unit 2 was shut down for an unscheduled maintenance outage. The
inspector observed that because of the activities at Unit 2, little
attention was applied to Unit 3 prior to the isolation. At the time
of the isolation, the operators re-focused their attention on Unit
3. Their response was appropriate to the situation and is a noted
strength.
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The Control or " Chief" Operator holds an NRC Reactor Operator
License and has responsibilities for both units. Since the Control
Operator is more experienced than the Assistant Control Operators and -
is relied upon by the Unit Assistant Control Operators for assistance
and relief, the concern exists that he may direct the licensed
activities of the Unit Reactor Operators, as defined in 10 CFR
55.4(e). This item will be reviewed in a future inspection
(277/86-12-01; 278/86-13-01).
An appropriate solution may be providing each unit with an
additional Control Operator and upgrading the " Chief" Operator to
hold a senior license.
During the peried of the NRC shift inspection, there were no
occurrences at either unit which were not adequately handled by
licensed operators. However, because of an unscheduled maintenance
outage of Unit 2, there were long periods of time during which only
the one Licensed Operator was available to directly monitor Unit 3.
The Unit Reactor Operators shift between Unit 2 and 3 with each
watch rotation. The other shift personnel, the Control Operator,
Control Room Shift Supervisor and Shift Superintendent share their
attention between the two units. The use of a common operating
staff may introduce an additional amount of fatigue during periods
of maintenance outages. Since the same staff may be dealing with
one reactor at power and another in an outage, for an extended
period of time, the potential exists for the attention to detail
required for successful operation to be reduced because of the size +
of the operating staff,
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5.4 Operating Logs
The inspectors determined that operating logs are kept by each
member of the control room shift. However, some of the logs are
sketchy and have few entries. The logs individually did not reflect
the level of effort actually applied by the shift personnel. However,
when all control room logs are reviewed in total, a complete plant
status can be obtained.
The log books had to be reviewed with shift turnover checklist
forms A-7 Appendix 5, to adequately appreciate plant conditions and
evaluations. Of the various logs, the Shift Superintendent's log
was the most informative and best kept and reflects the knowledge of
those individuals. However, because it is not addressed by
procedure A-7, it is considered to be an informal log, not signed
and sometimes kept in pencil.
Licensee attention is needed to improve these records such that
they reflect the professional manner in which personnel actually
perform their duties. This will be reviewed in a future inspection
(277/86-12-02; 278/86-13-02).
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5.5 Control of Overtime
Procedure A-40, " Working Hour Restrictions", Revision 3, dated
October 23, 1985, establishes controls for overtime and implements
the criteria of NUREG 0737,Section I.A.1.3. The inspector
determined that the Operations Department uses a rotation system to
allocate overtime among its personnel. A review of the amount of
overtime worked indicated that although individually they were not
excessive, the licensee has been compensating for personnel shortages
in approving overtime. Also, because of supporting two units with a
common operating staff, the opportunity to work overtime appears to
continue year round. Individuals actually working the overtime may
be subject to the personnel fatigue issue addressed above.
In a second observation, Procedure A-40 restricts its application to
the (22) systems and components stated in Section 2.2 and limits its
scope to Peach Bottom Station personnel only. In failing to make a
global restriction, the licensee may be allowing interpretations
which may lead to personnel errors in safety-related systems.
5.6 Control and Oversight of Activities
The inspectors found that the Senior Licensed shift personnel were
knowledgeable of plant conditions and maintained control over plant
activities. Both the Shift Superintencent and Shift Supervisor were
observed to review the control boards and logs for each unit at the
beginning of each shift. The Shift Superintendent conducted a
briefing for all personnel early each shift. Ihese meetings were +
attended by NRC
organizations inspectors
and station who observed
management that representativos
were present. The shift from support f
briefing is considered a strength.
The Shift Superintendent appeared to be the center for much of the
communications with station management and support organizations and
was also responsible for scheduling the activities of these organiza-
tions. As a normal weekday practice, a Station Management meeting
is held to discuss the status of each unit, to identify new problems
and lay out an overall course of action. The day Shift Superintendent
provides most of the information for this meeting from the data gathered
since coming on shift. The information is received and acted on by
the Station Manager and department head level personnel. A second
meeting providing management coordination is held later in the morning.
Again, the day Shift Superintendent plays a major role in providing
plant infcrmation and activity coordination control.
The Shift Superintendent appears to have been assigned responsibility
for these meetings because, since watch relief, he has been kept up
to date on plant status. The time needed to prepare for and partici-
pate in these two meetings may detract from the Shift Superintendent's
principal responsibility of shift oversight for safe reactor
operations. Although Unit 2 was shut down for an unscheduled eight
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day maintenance outage during this NRC inspection, the licensee did
not establish an on-shift management representative. Therefore, the
Shift Superinter. dent was faced with the responsibility of information
dissemination and activity coordination for both units. This may have
an adverse impact on reactor safety. Licensee action is required to
address the potential for overloading the Shift Superintendent with
administrative duties better assigned to other staff members. This
will be reviewed in a future inspection (277/86-12-03; 278/86-13-03).
The inspectors observed that on-shift personnel carried out their
duties as described in Procedure A-7, " Shift Operations". In every
case during the inspection the NRC team members found the Shift
Superintendent and Shift Supervisor knowledgeable'of plant status
and equipment problems.
5.7 Personnel Attitude Towards Nuclear Safety
During the conduc't of the NRC on-shift inspections discussions were
held with licensed and non-licensed shift personnel. In every case
the licensee's operating staff was found to have a o.od attitude
toward nuclear safety. Individuals were interestec in their
assignments, took pride in the plant and enjoyed their work. For
example, while making rounds with Plant Operatoes the isspectors
noted that they were conscientious toward investigatirg plant
conditions. One operator repeatedly exceeded the requirements for
his inspection tours because it was his first snift after several
days off and he wished to re-establish his knowledge of plant condi-
tions through observations. Plant Operators were interested in deter- t
mining the source of any small leak and checking runnirg equipment.
The inspectors noted that observations by operators were made i
consistently and naturally.
Shift Supervisors were observed to insist on strict adherence to
procedures and involved themselves in evaluations of the units.
Shift personnel were also strongly supportive of station management.
However, some held the opinion that because of its financial
importance to Philadelphia Electric and its close location to the
corporate office, the Limerick project has drained resources from
the Peach Bottom Station. There was a general perception that
historically the site was managed from the corporate office, but
recent line organization changes were viewed as a positive approach
to this issue.
- Personnel have recently taken a strong interest in placing trouble tags
on deficient plant equipment and control panel information tags where
needed. The Equipment Trouble Tags identify the different equipment
and act as a precursor to a Maintenance Request Form (MRF). The
information tags act as an operator aid. They are applied
'
. liberally, but subject to monthly audit to determine their
continuing need or other corrective action. One weakness of the
Information Tag System is that since there are no serial numbers or
.
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11
tracking log, all the tags may not be located during an audit and
correction of a significant problem may be overlooked. This item will
be reviewed in a future inspection (277/86-12-04; 278/86-13-04).
The inspector reviewed the information tags placed on the core spray
and RHR testable check valve bypass valve on both units. On March
23, 1986, the bypass valves were disabled to provide proper
electrical separation for 10 CFR 50, Appendix R. SP-920 was
implemented to perform this disabling. The inspector reviewed the
information tags, SP-920 and a related April 17, 1986 memo, and
discussed this item with licensed operators. No unacceptable condi-
tions were identified.
Station management appears to have a positive attitude toward
nuclear safety. This is reflected by the June 18, 1986, shutdown of
Unit 2 due to a piping leak in an Emergency Service Water supply to
an Emergency Core Cooling Room Cooler. Also, the licensee
management conscientiously carried out Local Leak Rate Testing of
containment isolation valves after maintenance as simple as valve
motor operator reairs.
5.8 Plant Paging System
During the period, .i observation was made by all the inspectors
regarding def'ciencias with the plant paging system. The major
deficiency involves lack of control room priority on the system such
that control room announcements are often interrupted by relatively
meaningless pages. This situation has the potential to severely a
limit control room communications to the plant site. The other i
deficiency involves abuse of the paging system to include such !
childish acts as making obscene sounds, playing music, and using the
tones associated with each digit to sound out nursery rhymes. The
licensee has been aware of the paging system deficiencies for some
time but has not implemented effective changes to correct them. This
item will be reviewed in a future inspection (277/86-12-05;
278/86-13-05).
5.9 Response to Off-Normal Conditions
During the course of the inspection the operators were observed
responding to various off-normal conditions. In each case actions
were taken appropriately and the alarm cards were utilized. A loss
of Emergency Service Water to ECCS room coolers on Unit 2 is reviewed
in detail 12.1 of this report. A primary containment isolation group
IIA occurred on Unit 3 and is reviewed in section 12.2 of this
report.
On Thursday, June 26, 1986, an alarm indicating that the Unit 3
Reactor Building SE Airlock Seal was broken and secondary containment
was not intact was received. The inspector checked the alarm card and
.
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12
determined that the operators responded properly. The licensee
determined that the doors were working properly but a time-delay
relay in the alarming circuitry was faulty. The relay was changed.
Upon checking the air lock doors the operator found the alarm did not
initiate. On June 30, 1986, the Test Engineers investigated the
problem and found a blown fuse. The circuit was tested satisfactorily
on June 30, 1986.
Licensed operator knowledge of response to off-normal, annunciator
alarms is considered a strength.
5.10 Verification of Coupling Control Rod Drive Mechanism 30-15 with Its
Control Blade (Unit 2)
The licensee has been unable to verify the integrity of the coupling
between the Unit 2 Control Rod Drive Mechanism (CRDM) 30-15 and its
Control Blade through conventional methods as the drive mechanism
does not reach the number 48 position. Although the drive mechanism
passed its functional tests including the coupling integrity test at
the beginning of the present operating cycle (Number 7), during
subsequent tests the drive could not be withdrawn to position 48.
This had also occurred once during cycle number six on March 10,
1984. At that time the licensee diagnosed the problem as a faulty
position indicator probe. The control blade was replaced in
September 1985 during the reload number six refueling outage. The
drive mechanism passed a functional test on March 24, 1986, but has
failed subsequent tests.
The inspector observed the implementation of a Special Procedure
884, " Operational Verification of Control Rod 30-15 During Unit 2 '
Cycle 7", Rev.1, dated Feberuary 5,1986, during a plant startup on
June 26, 1986. Procedure Section II.A was completed and data was
reviewed for rod withdrawal to notch position 26. Traversing Incore
Probe (TIP) traces at location 32-17 tracked control blade
withdrawal. The inspector also reviewed the licensee's safety
evaluation dated October 18, 1985, letters dated October 17 and
December 5, 1985, clarifying engineering analysis and a General
Electric Safety Analysis dated July 1985. Nuclear Review Board
Meeting Minutes, Number 173, also addressed the problem and proposed
corrective actions.
There were no unacceptable conditions identified.
5.11 Summary
The NRC team determined that the station is operated by well quali-
fied individuals with a positive attitude toward their positions and
for nuclear plant safety. However, there does appear to be a need
for additional support within each operating shift to insure that
adequate attention to detail is exercised in the operation of each
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13
unit. The-licensee should be aware that long periods of extended
work hours as that which may occur during an outage may result in
fatigue resulting in personnel errors affecting either unit.
The control room operating logs need to be improved to reflect the
professional manner in which personnel are actually performing their
duties.
There needs to be an effective management representative assigned to
assist the Shift Superintendent and coordinate the efforts of various
support organizations. This is particularly true during an outage on
a round-the-clock basis.
The duties, responsibilities and accountability of on-shift personnel
needs to be clearly defined and disseminated throughout the organi-
zation
6.0 Maintenance
6.1 Maintenance Program
Plant maintenance programs were reviewed to determine their effect
on safe plant operation. NRC inspectors witnessed the performance of
maintenance work, discussed maintenance-related activities and
administrative controls with appropriate personnel, and assessed
staffing and management involvement in the maintenance area.
Interviews were held with Maint<c. qce Division supervision and
tradesmen, plant staff assignec 's the Engineer-Maintenance, and t
interfacing organizations such s Engineering and Research, control Q;
room operators and Construction Division. The backlog of E
maintenance work was evaluated, adherence to overtime guidelines was
reviewed, and QA/QC involvement in maintenance activities was
assessed. Also evaluated was the control of contractors utilized to
perform maintenance, the adequacy of engineering support, the status
of outstanding preventive maintenance work, and outage planning.
6.1.1 Maintenance Request Forms (MRF)
The licensee uses a computerized system for history and
maintenance work planning (CHAMPS). The current data base
extends to February 1984 (with plans to eventually retrofit
data back to 1980) and includes current totals of approxi-
mately 20,000 MRFs for Unit 2 and 10,000 for Unit 3 in
various stages of completion. About 15-20% of the total
data represent cancelled MRFs due in part to duplication or
errors in initiating a MRF. Duplication is attributed to
equipment and component tagging problems which are being
addressed in the long term by the licensee, as well as
inefficient work coordination among different work groups
which has recently been improved via daily coordination
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14
meetings. The actual MRF history data base usable at Peach
Bottom for trending and equipment failure analysis is 9200
Unit 2 and 4500 Unit 3 MRFs.
Outstanding MRFs are traceable to a point in the MRF system
used to process work. That point may be at Section 2
(Staff Investigation and Approval) through Section 7
(Operation Verification Results) of the MRF. This range
encompasses identification of a problem by plant staff to
completed post-maintenance testing. Administrative
closecut of the document and entering into the history file
(accounting for 2100 outstanding MRFs) is handled by a
single clerk in the staff of the Engineer-Maintenance.
The progress of a MRF prior to actual work includes
workgroup reviews, refinements, and approvals up to and
including completion of Section 5, whereupon permits are
written, blocks established on equipment, and work is
turned over to the responsible work group. Comoletion of
Section 6 of the MRF signifies physical work U mpleted.
There are relatively few MRFs currently under his category.
Snapshots of current work status sti.tistics are therefore
significant with respect to a section-by-section <: count.
The current statistics reflect planned MRFs for f ture unit
outages, including preventive maintenance and Con,truction
Division work, accounting for over 700 MRFs outstanding on
each unit.
Interviews with personnel from different licensee organiza-
tions (i.e., maintenance and operations) suggest one f
L
problem contributing to a backlog of outstanding MRFs is
that there is a lack of licensed operators qualified and
available to write permits and turn over plant equipment to
Maintenance for work (completion of Section 5). The
inspector did observe that a Control Operator was not
typically staffed on the swing and mid-shifts, nor on the
week-ends, to prepare permits and direct blocking of equip-
ment and systems. Further, during the Unit 2 shutdown
begun on June 18, 1986, to repair an ESW piping leak, a
decision was made to staff the mid-shift with a maintenance
crew to support the mini-outage work. However, permits
were not prepared to enable that work until the next day
since a licensed control operator ("MRF-doctor") was not
provided on the shift to write the permits. Review of
current outstanding MRF statistics indicate approximately
1400 MRFs in the system awaiting completion of Section 5
(permits issued), although more than half (800 MRFs) are
pre planned outage work including preventive maintenance.
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Outstanding MRF statistics, when examined in finer detail,
suggest problems other than just with Section 5 and the
ability to provide permits. The MRF system provides for
monitoring and accountability of work but additional
staffing in other areas to plan, screen, and close out
completed work may also be needed. No examples of
incomplete safety-related corrective maintenance were found
by the inspector. A CHAMPS sort of outstanding MRFs through
Section 6 for which the responsible work group were
Maintenance Division electricians was reviewed by the
inspector and discussed with the plant staff's Assistant
Engineer-Maintenance. Although the indicated backlog was
125 MRFs, closer investigation revealed that 70 of those
were either being worked (40) or were on hold for a
technically sound reason. Of the 55 which were potentially
available to be developed towards working status, none were
safety-related corrective maintenance.
The inspector concluded that the licensee had an accurate
perspective e outstanding maintenance workloads and
safety-relat i maintenance was not being delayed. The
current initiatives towards job planning in the Maintenance
Divistor, the neily established work coordination meeting,
clearer in plant tagging and identification, and additional
plant staffing 1 the Station's Operations and Maintenance
Groups snauld serve to reduce and more evenly distribute
the statistics associated with the MRF system.
6.1.2 Preventive Maintenance (PM)
!
'
The inspector interviewed the engineer on the plant staff
assigned to the PM program which has only recently been
formally developed. A list of 22 new maintenance procedures
to be developed by Maintenance Division engineering was
identified on May 2, 1986, and included were environmental
qualification - PM procedures and other PM procedures such
as diesel generator air start and thermostatic control valve
rebuilds. Prior to this memorandum, PM was accomplished
using existing Maintenance Division corrective maintenance
procedures with appropriately initialled steps. The only
procedure developed of the 22 identified above was a draft
of M-52, Rebuild of the Diesel Thermostatic Control Valve.
The inspector reviewed Procedure M-52 and found no unaccept-
able conditions.
Discussions with licensee personnel indicate that a con-
tractor is currently working on a PM program for 15 iden-
tified systems, and based on equipment history and exper-
ience, will recommend equipment for detailed PM. As
___ -- - .____- _ - _ . . _ _ _ _ -
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addressed in detail 6.1.1, there are an extensive number
of PM MRFs in CHAMPS which are awaiting to be worked. As
an example, for Unit 2 (and common' plant) maintenance, there
are 1500 PM MRFs associated with future outage time, and
300 awaiting non-outage opportunities. Although the inspec-
tor did not observe actual PM in progress, nor did he review
the detailed scope of outstanding PM work, the recent initi-
atives to formalize the program and develop specific PM
procedures have just begun. Staffing in the Engineer-
Maintenance group is not currently sufficient to implement
the full intent of the envisioned PM program.
6.1.3 Training Programs
The inspector visited the Maintenance Division's training
facility located at a decommissioned power station,
Barbadoes Island, in Norristown, Pennsylvania. The
inspector toured the facility on June 27, 1986, interviewed
the Training and Testing Group Foreman, senior craft
instructors, the nuclear training instructor and other
personnel, and reviewed selected lesson plans.
The licensee has implemented an excellent mechanism for
feedback from both the tradesman and his supervisor regard-
ing in progression (i.e. helper up-through 1st Class) skill
training conducted at Barbadoes. The inspector reviewed a
number of evaluation forms provided to the full-time
instructor devoted to feedback. The evaluations covered t
training for 3rd Class machinists, electricians and N
steamfitters, and. helpers. Each evaluation addressed the I
'
adequacy and importance of training in 10 or more specified
tasks assigned to that class of tradesman. The tasks were
rated by both the trainee and his supervisor: Electricians
placed high importance in the area of Limitorque valves; a
finding also confirmed by interviews with qualified 1st
class electricians and supervisors as a major portion of
electrician work load. On the other hand, the importance
of industrial or personnel safety is stressed in helper
training. Maintenance Division trainers are using this
feedback,to evaluate the progress of craftsmen in progress-
ion, as well as refinements in the training curricula.
A formalized on-the-job training (0JT) program was approved
for use in December 1985. A total of 85 Maintenance Division
instruction evaluators were certified to administer the
program; 25 are presently stationed at Peach Bottom. The
OJT is administered to first-class tradesmen, who are the
assigned job leaders when maintenance work is performed.
The program consists of documented self-study preparation,
on-the-job discussion, and actual job performance under the
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17
guidance of one of the certified instructors / craftsmen.
The inspector reviewed the prepared guides for specialized
tasks in four disciplines; electricians,' machinists, pipe-
fitters and riggers. The formalized tasks for electricians
are currently covered by 12 guides which address mainte-
nance on circuit breakers, motor operators, and refueling
platform preventive maintenance. Steam-fitters have
specific OJT which addresses topics such as safety-relief
valves, MSIV pneumatics and vacuum breakers. The inspector
also discussed the feedback to-date on the existing 0JT
program and noted that recent Limerick maintenance on MSIVs
and main steam SRVs had incorporated DJT which was docu-
mented and will be factored into future Peach Bottom work.
The inspector interviewed an electrical instructor and
reviewed associated lesson plans for tradesmen in progression
(i.e., 2nd and 3rd class electricians). The instructor had
18 years of maintenance experience, 12 as a 1st class elec-
-
trician and approximately 7 years at Peach Bottom. The
classroom training was described as a total of 37 lessons
(roughly one lesson per day) for 3rd class electricians; 4
hours of lectures and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in the laboratory. Classes
are held to a total of 4 stedents, for optimum instructor
attention, particularly in the lab sessions. Lesson plans
are currently being prepared under a formalized system,
with a Maintenance Division goal of completing over 400
plans in the areas of electrical and mechanical training by
January 1987. The instructor's lesson plans were observed +
to contain vendor manual information and were supplemented k
by prepared guides provided by a contractor including the 0
use of videotapes. A four part text on electricity was
also part of the training, and home assignments were incor-
porated from those texts.
Lab projects are part of the training at Barbadoes. An
example is two Limitorque valves which are set out in the
facility for teardown and rebuild work. A large portion
of electrician and machinist workload, even at non-
nuclear plants such as Eddystone, involves work on Limi-
torque valves. Electricians in training are taught
specific Limitorque tasks such as resetting torque switch
contacts and logic troubleshooting. The inspector reviewed
a formal lesson plan for 2nd class machinist covering
Limitorque valve operators which was approved on
February 7,1986. The plan contained detailed 't. formation
enabling disassembly and reassembly of Limitorque models
SM800 and SMB000. The operating principals, spring setting
procedures, and pertinent inspection techniques were ade-
quately addressed. The lesson is supplemented with hands-on
familiarity (in the training facility) of the motor-end,
declutching lever, handwheel and drive sleeve assemblies.
a
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18
Also covered are topics such as lubrication, common
problems and experiences, ordering of parts, and relation-
ships between the motor and pinion gears'and Belville
springs. The lesson plan was found to be comprehensive.
The inspector reviewed the Training Group's method of using
course feedback and other actual plant experience to modify
or re-structure training on certain topics. Examples
include:
--
Requests for training from Maintenance Division super-
visors at Limerick and Peach Bottom on specialized
techniques associated with Limitorque valves.'
--
Course Request Sequence No. 13 dated November 1985
from the licensee's Operating Experience Assessment
Committee (0EAC) associated with NRC IE Information
Notice 85-22, Failure of Limitorque Motor Operated
Valve. This request was determined to be already
covered via a Limitorque Bulletin SN i-828 which is a
handout provided in Training Lesson . ' on valve
operator.
--
Course Request Sequence 25 dated May 30, 1985 regarding
NRC IE Notice 85-43 concerning rac'iograpiy events.
This information was incorporated into tne Helper
training program.
--
Operating Experience No.1550 from the CEAC regarding
-
a COLT diesel generator problem with piston bushings i
experienced in November 1985, which will be incorporated
into specialist training.
--
Operating Experience No. 382 received from the OEAC
based on an INPO SOER dated May 2, 1985 addressing
trips caused by vibration fatigue of control air lines.
This experience is currently being evaluated by the
Training Group.
The inspector concluded that operating experience was being
reviewed and provided to the Maintenance Division Training
Group, and was being incorporated into lesson plans as
appropriate.
The inspector also discussed specialized training which has
been provided to Peach Bottom site maintenance personnel.
An example included a course consisting of two, 21s-day
onsite sessions given at Peach Bottom on April 28 - May 2,
1986 by the diesel generator vendor, Fairbanks Morse. The
course supplements the basic general machinist training,
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and was provided based on field supervision requests,
approved under Course Request Sequence No. 43 dated
February 10, 1986. This course was previously taught at
Limerick site in December 1985. Feedback from personnel
attending the Fairbanks Morse course included the need for
more hands-on instruction, a clearer vendor manual to
follow and more than 2 days of study. Each student
received a detailed Fairbanks Engine manual, and a 20-
question test at the conclusion of the course. The course
outline addressed industry experiences with COLT diesel
engines such as INP0 significant event reports.
Future training is scheduled in a number of specialized
areas, and is being coordinated by the Nuclear Training
Instructor, who is to be permanently assigned to the Peach
Bottom site by September 1986. The inspector discussed the
continuing training program with the Nuclear Training
Instructor, who described topics in 26 machinist tasks
covering areas such as seals, bearings, and control rod
drive rebt Ids. A course in RWCU pump maintenance, MCT-08,
was given n February 28, 1986. Twc 5-day courses are
scheouled at GE-San Jose in October 1936 to be attended by
6 riggers and liachinists (as well as by training instruc-
tors) adoress og refueling floor maintenance. And, a 2-day
vendor solid state technology course covering circuitry and
troubieshooting is planned to be provided to 30 1st class
electricians.
The inspector also reviewed a course request which was 1l
approved on February 20, 1986, and which has resulted in I
expanded emphasis in machinist and pipefitter training !
addressing torquing sequences on all types of joints.
The training will improve controls over packing and gasket
compression, overstretched bolts, and joint tightness.
The expanding training is being incorporated into lesson
plans and will be included in training examinations as a
skill to be demonstrated.
The inspector discussed pertinent topics which are addressed
in Helper training with an instructor. The Helper is an
entry level in the Maintenance Division, and a principal
focus of helper training is worker safety. This was con-
firmed by reviewing the feedback from a recent Helper class
of 30 trainees (and their supervisors) conducted from
November 20, 1985 through March 17, 1986. The Helper class
instructers are experts from the training group as well as
senior tradesmen who are detailed from the sites to
Barbadoes,
i
__ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ .___
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.
The licensee has recognized the continued need to recruit
and train entry-level maintenance workers, and this is
evidenced by the current class of Helpers at Barbadoes and
by the 28 Helpers currently assigned at Peach Bottom
Station.
Finally, the inspector reviewed QA Audit Report AP 85-101
conducted at Peach Bottom site, Barbadoes Training Center,
and PECO main offices on November 1-27, 1985. The audit
covered training and qualification programs for Maintenance
Division craftsmen, and concluded that associated adminis-
trative controls were adequate and effectively implemented.
Selected findings were reviewed by the inspector, and found
to be properly addressed where required by the licensee.
None of the identified deficiencies were considered by the
inspector to be significant, and all had been closed by
the licensee at the time of this inspection.
6.1.4 Work Hours Control
Controls on working hours of Maintenance Division personnel
performing safety-related activities are outlined in Pro-
cedure MA-23. The inspector reviewed Revision 3 to MA-23
approved on February 18, 1986, and discussed the trending
and control of overtime at Peach Bottom with the Maintenance
Division Supervising Engineer. MA-23 requires an approved
Overtime Deviation Report for projected maintenance work in
excess of:
- --
16 consecutive hours h
'
--
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period
--
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period
--
17 consecutive / days
The NRC guidelines apply to workers performing safety related
maintenance. However, the licensee tracks work hours for
all Peach Bottom Maintenance Division workers, including
supervisors and engineers, on a daily basis. Overtime hours
are limited for all maintenance work (safety and non-safety
related). The work foremen are required to monitor their
assigned tradesmen, included those who are periodically
assigned to Peach Bottom activities from the general pool
and mobile groups out of Oregon Avenue Headquarters. Also,
travel time, as well as, time worked at locations other
than Peach Bottom (e.g. non-nuclear sites such as Muddy
Run, Eddystone, and substations) is accounted for in meeting
the requirements of MA-23. Permission to work overtime is
granted by responsible foremen, in accordance with Maintenance
Division work rules, and deviations from the above limits
must be justified, documented, and approved.
1
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The inspector reviewed all approved deviations from the
overtime guidelines since January 1986. There were 30-35
Overtime Deviation Reports for each month in-the first
calendar quarter of 1986, during which the Unit 3 outage
was completed. Deviation reports documented for the second
calendar quarter of 1986 during the months of April (24),
May (9), and June (16) were averaging 16 instances per month
or half of the previous quarter. Each deviation from the
. limits was justified with a narrative prepared by the super--
vising foreman. Many of the deviations were multiple suc-
cessive reports for one indi.vidual since, one that tradesman
would exceed a limit, it would typically take 2-3 days (and
therefore 2-3 reports) to " work out of" the restriction
even while working straight 8-hour days. _ Many of the devia-
.
tions were justified after the foreman had offered other
appropriate workers the overtime in accordance with Main-
tenance Division work rules which provide for equal oppor-
tunity and a spread of the hours among qualifiea tradesmen.
The inspector reviewed documented work hours for 14 1st
Class and 4 2nd and 3rd Class machinists for the month of
June 1986, as well as,.for 7 helpers. No violations of the
work-hour restrictions were identified. The inspector
observed the use of "Six 10's" or six consecutive 10-hour
days among the helpers. THe 60-hour schedule is effective
for job planning and also meets all.of the overtime
criteria.
The computerized printouts for all Maintenance Division
personnel are reviewed daily by a Technical Assistant and 4
the printouts provide running totals for.all personnel
'
assigned to Peach Bottom and are highlighted in each re-
stricted category (24-and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, and 7. days). The
inspector concluded that the licensee was consistently
tracking work hours of all Maintenance Division personnel,
that work hours were being controlled by immediate craft
supervision,'and that Maintenance Division management were
aware of the use of overtime among workers. Documented
, deviations were found to be appropriately justified and not
j used unnecessarily or excessively. The inspector also dis-
i
cussed the past 12 month history of overtime utilization
! within the Maintenance Division staff assigned to Peach
! Bottom. Overall overtime hours on-site averaged 29%,
! although that number was higher for mobile Maintenance
! Division workers (36%) than for permanent station personnel
l (22%). The higher averages can be attributed to continuous
l outage activities during that period and, as mentioned
before, are higher for the mobile personnel because of
travel time and other non- nuclear assignments. Also, in
, most nuclear mobile jobs, non-safety related work such as
J
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__.
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22
turbine balancing and transformer maintenance accounts for
much of the time. The Maintenance Division has established
a management goal of controlling the use'of overtime, and
foremen and first- line supervision have been held accoun-
table for meeting the guidelines of MA-23 and spreading
overtime work hours more evenly amongst craftsmen such that
the Division's objective of overall 20% overtime is
achievable by the end of 1986. Finally, discussions with
craftsmen and their immediate sub-foremen supervision
regarding use of overtime identified no instances where
worker fatigue was in question, or where the quality of
safety-related maintenance was being impaired due to
excessive work hours.
The control of overtime hours, particularly on drywell and
other high-radiation maintenance activities, should also
serve to reduce cumulative radiation exposure goals. The
inspector reviewed an April 8,1986 memorandum from the
Peach Bottom ALARA Review Committee Chairman to station
management and supervision concerning the 1986 proje ted
man-rem exposure goal for maintenance workers, whica was
1175 man-rem and represented 71% of the total site e>.posure
expected. The inspector discussed ALARA goals with the
Chairman and reviewed work experience data on exposurt-
history for maintenance. These data represented actual
documented worker exposure and were observed to be useo in
job planning for the Unit 2 IRM replacements. The expected
man-rem for an IRM replacement was observed to be within t
10% of that actually realized during the work. The
inspector concluded that ALARA concerns were being factored f
into maintenance planning, and that ALARA estimates based
on previous history were accurate. The cumulative exposure
goal was therefore quantifiable and, even for a two unit
station with significant contamination challenges which
extend the time required to perform maintenance, capable of
being achieved barring unforeseen outages or equipment
failures. However, interviews with tradesmen and
non-supervisory maintenance personnel indicated that these
goals regarding overtime and exposure control were not
generally understood although their effect had been
recognized.
6.2 Maintenance Activities
6.2.1 Snubber Replacement
During a tour of the Unit 2 drywell on June 18, 1986, at
the time of the outage to repair a leak in the Emergency
Service Water system piping, the licensee identified
deficiencies with two safety related hydraulic snubbers.
The snubbers and the deficiencies were as follows:
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23
(1) Snubber 6DDNLS13 in the feedwater system had a
displaced paddle bearing, and
(2) Snubber 1GGS33 in the main steam system had a low oil
level.
Both these snubbers were removed to perform testing to
verify their operability. The inspector witnessed a
portion of the testing performed in accordance with
Procedure M65.4, Hydraulic Snubber Testing (With Load
Cell), Rev. 10. As part of the inspector observation
activities, interviews with the technician, QC inspector,
and QA auditor were conducted.
The licensee has a snubber testing machine that is capable
of testing hydraulic snubbers with a bore size up to six
inches. They presently do not have the equipment to test
mechanical snubbers but have plans to purchase a machine
with this capability. The two deficient hydraulic
snubbers were tested using the in-house equipment. The
technician who perfo red the testing was knowledgeable of
the procedure used, tr.e test equipment, and technical
aspects of hydraulic snut bers. The QC inspector also
appeared experiencea in *nubber testing. The QC inspector
verified that the instrumentation associated with the
testing was properly calibrated, the test procedure was
the latest revision, and the procedural requirements were
followed. A QA auditor 5,erformed a surveillance of the +
snubber testing as part of an overall maintenance hL
surveillance activity. dis questions and observations
seemed adequate. The NRC inspector performed similar
observations and did not identify any discrepancies. A
procedural problem developed when setting up the testing
machine prior to any actual testing. In particular,
paragraph II.0 of M65.4 requires an adjustment of two
pressure regulators to establish a driving force on the
snubber testing ram. This paragraph refers to Appendix B,
Table 2, to determine the correct pressure setting for the
,
size snubber tested. The technician pointed out that the
- system pressure values listed in the table were excessive,
.
'
and, if applied, could damage the snubber being tested.
When questioned as to his logic, the technician explained
that the pressure gauges in the testing machine had been
recently replaced and had different zero readings than the
previous gauges, in that the gauges are not considered
official gauges within the scope of the calibration
program but are used for establishing an approximate
pressure to drive the ram. The gauges used to establish
the pressure values in Appendix B, Table 2 apparently read
some value other than zero when the pressure regulators
-. _-. _ ._. - .- __- _ . _ _ .
$
24
were backed off. This value was reportedly about 200 psi.
It was not clear why the gauges behaved in this fashion
but their behavior was compensated for when the Table 2
values were established. The replacement gauges read
about 75 psi when the pressure regulators were backed off,
llad the technician applied the full pressure as required
in Table 2 to the ram, it would have been in actuality 125
psi more than desired and could have resulted in snubber
damage. The technician stated that procedure M65.4 was
undergoing revision but he was not sure if this aspect of
the procedure was being addressed in the upcoming revision.
The technician's understanding of his job, which prevented
possible snubber damage, is commendable. Subsequent to
the identification of this procedural problem, a temporary
procedure change was effected that resolved the problem.
The snubbers were then tested and both failed the bleed
rate portion of the test and were, therefore, declared
inoperable. They were replaced prior to restart. An
inspection of the snubber that had a low oil level
disclosed evidence that this snubber may have been used as
'
a step, the hydraulic oil reservoir fluid port plug was
missing, and the loss of fluid was attributed to a leaky
connection between the valve block supply tube and the
reservoir. An inspection of the second snubber with the
displaced paddle bearing, indicated that the bearing
staking was not adequate.
Section 4.11.D.6 of the Technical Specifications (TS) i
requires that the licensee perform an engineering i
evaluation of inoperable snubbers to determine the failure ;
mode and if the attached system or component was adversely
'
affected. The NRC inspector reviewed the licensee's
'
written evaluation, File: Equip 1-25-1 (Snubbers), and
found that it contained a correct description of the
t failure modes and an explanation that a snubber's failure
1
to meet the bleed rate criteria would not create an
obstruction to thermal growth of the piping because bleed
rates only take effect after lockup activation. The
overall evaluation was reasonable and thorough. TS 4.11.0.2 requires that when two snubbers are found
inoperable, the time interval for surveillance checks of
t similar type snubbers must be once every six months.
! Because the licensee was already on a six month inspection
frequency for inaccessible snubbers (drywell), these two
i snubber failures did not change the inspection frequency
l for inaccessible snubbers.
I
!
_ _ _
, _ _ _ _ _ _ . . _ . _ _ _ , _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ , _ , __ . . , _ _ _ , _ _
o
25
The NRC inspector raised a concern regarding the use of
the gauges on the snubber testing machine to establish
values used in the test procedure. As stated earlier the
gauges do not read zero when installed in the machine and
when the gauges are replaced, the zero readings also
change, thereby invalidating the affected procedural
values. This situation could be eliminated by using the
calibrated load cell readings to establish ram driving
pressure. The licensee responded to this concern by
stating procedure M65.4 is undergoing a revision that
will, in part, resolve this problem. The NRC will review
resolution of this issue in a future inspection
(277/86-12-06; 278/86-13-06).
6.2.2 ESW Repair - Welding and NDE
On June 18, 1986, Unit 2 shutdown to repair a leak in an
Emergency Service Water 3" line to the "A" Residual Heat
Removal room 2AV25 cooler. The leak was reportedly caused
by localized pitting corrosion. The NRC inspector
witnessed various activities associated with the repair of
the leak and reviewed associated documentation.
The problem was identified on MRF No. 8604631. The repair
action was to weld a Thread-0-Let onto the pipe with the
placement of the Thread-0-Let such that the hole in the
ESW pipe would be within the boundary established by the
Thread-0-Let. A plug would then be screwed into the <
Thread-0-Let to form a pressure boundary. The hole in the #
ESW line was not worked on in any way. Prior to welding !
the Thread-0-Let onto the pipe, two significant
preparatory steps had to be taken: The first involved
establishing a freeze seal on the ESW line and then
draining the line, and the second involved performing NDE
of the pipe wall around the hole to ensure sufficient
j material thickness. The NRC inspector observed the
- contractor freeze seal operation and determined it to be
- in compliance with Procedure M94.2, Pipe System Freeze
- Sealing, Rev. 1. In addition, the inspector observed MT of
!
the pipe material around the hole to ensure no material
defects existed and UT thickness determinations of the pipe
'
wall around and away from the 1/4 inch diameter hole to
ensure sufficient base material thickness. The NDE
! technicians were not QC personnel but were attached to the
i plant inservice inspection group that reports to the
i maintenance division and were qualified to ASNT-TC-1A level
II. The NDE was performed ir. accordance with procedures
and the pipe material around the hole was determined to be
free of defects.
I
!
i
.
.,
.
26 \
There were no criteria established by engineering, that
the NDE technicians were aware of, that addressed material
thickness requirements versus distance from the centerline
of the hole to ensure the Thread-0-Let connecting weld
would be made to adequate base material. In addition,
there was no engineering review of the thickness data
prior to making the Thread-0-Let weld. The evaluation was
made on the spot by the NDE technicians using a design
minimum wall thickness value stated in the repair
procedure. The NRC inspector felt some engineering
evaluation of the UT data prior to making the weld would
have been appropriate. When specifically questioned about
this, the licensee stated that it was understood that the
NDE technicians would stop the job and involve engineering
if any of the wall thickness readings were less than the
minimum wall thickness specified in the repair procedure.
Because none of the readings were less than the minimum
value, engineering was not involved.
Subsequent to the NDE, two welders attached the
Thread-0-Let to the pipe using the GTAW process for the i
root pass and SMAW for the balance of the " full
penetration fillet weld". The NRC inspector reviewed the
WPS's for both processes and the welder qualifications.
These were satisfactory. The inspector observed that the
E-7018 electrodes were kept in an operating warming oven
prior to use and that a het work permit existed as well as
did a fire watch. Upon completion of the repair, the
inspector reviewed the work package and found it to
contain all of the required documentation and signatures. :
In summary, the inspector's observations led him to
conclude that craft involvement in the ESW leak repair.was
performed in an efficient and professional manner. The
organization of the initial work package to get the job
started and finally to complete the job, was
comprehensive.
6.2.3 Coordination Meeting
The licensee has instituted a daily coordination meting
chaired by plant operations staff during which planned
activities are discussed. The treeting was begun
approximately two months ago, and has proved to be a
valuable planning instrument whereby maintenance (among
other) activities are prioritized and potential problems
surfaced and resolved. The inspector attended several of
these daily meetings, and noted that appropriate personnel
were present including ALARA and HP representatives, as
.
27
well as other plant support groups such as Catalytic
contractors, Construction Division personnel working
modifications, and technical engineers.
The meeting is centered about a computerized summary
five-day schedule, is conducted by an Assistant Operations
Engineer, and also attended by the Operations Shift
Superintendent. The inspector noted that a large amount of
discussion time was devoted to the availability (or in many
cases unavailability) of blocked systems ready to work by
maintenance tradesmen. Appropriate Maintenance Division
sub-foremen were present and knowledgeable of the status of
subject MRF items. After the coordination meeting, the
sub-foremen remained to discuss that day's workload with
the plant staff Assistant Engineer - Maintenance.
6.2.4 Status Reports to Management
The inspector reviewed bi-weekly status reports prepared
by the Supervisor of Engineering within the Maintenance
Division group at F ich Bottom. The reports for June 1986
provide good status of work, problems and efforts at the
site to Mainterance Div.sion management at Oregon Avenue
headquarters, including *
--
The major painting effort on-site 21% complete.
--
A proposal for wireless communications for the fuel *y
floors and under-vessel maintenance.
'
--
Results of snubber inspections, CR0 pump, radwaste
demineralizer and, M-G set fan repairs.
--
Status of items associated with the Unit 2
mint-outage in June 1986 such as the ESW pipe leaks,
valve packing leaks and the IRM replacements.
--
Procedural revisions, ISI program status, suggestions
solicited from Division personnel regarding snubber
maintenance.
--
Meetings planned, such as with Mechanical Engineering
regarding scaffold controls.
The inspector discussed these issues with various
maintenance personnel, observed certain of the completed
work or work in progress, and found the information in the
reports to be accurate and useful in keeping Maintenance
Division management informed.
.
28
6.2.5 IRM Replacements - Work Planning
The inspector attended a pre work planning meeting held on
June 23, 1986, to discuss the replacement of two Unit 2
IRMs. The meeting was conducted by plant management with
appropriate support groups represented such as ALARA,
maintenance foremen, test engineers and I&C technicians.
The licensee incorporated experience recently gained at
Limerick Station in replacing the IRMs, primarily
associated with radiological hazards and fiberglass
sheathing for insulation of the detector cable.
Based on recommendations by personnel familiar with the
Limerick replacements, the licensee instituted a temporary
procedure change (TPC) to Maintenance Division procedure
4.5, IRM Replacement. The inspector observed the
development of the required changes, and noted good
cooperation and communication between plant staff and
Maintenance Division engineers. However, problems were
later noted with M-4.5 regarding direction given to
Susquehanna Lab I&C technicians during detector cable
reconnection. Although the maintenance " traveller" or
sign-off sheet associated with the reconnection step in
M-4.5 was the responsibility of the lead work group (in
this case machinists) to verify, the reconnection was not
performed under an I&C procedure. Further, during the
actual IRM replacement, the licensee did not use the
TPC-version of M-4.5, but instead incorrectly reverted to -
the original revision because of as-found radiological 8
conditions. The procedural deviation was identified by P
the licensee, resulted in no significant safety problems,
and is being addressed via personnel counselling and
procedural revisions.
6.2.6 ESW Pipe Repair - Engineering Support
The inspector evaluated the engineering review of a leak
in a 3-inch vertical piping supply to the Unit 2 "A" RHR
room cooler discovered on June 18, 1986. The leak was
upstream of the cooler's air-operated isolation valve, and
was therefore unisolable. A hole approximately 1/4-inch
in diameter was found and attributed to a localized
deep pit corrosion. Mechanical engineering evaluation of
the piping leak affirmed the as-found condition as similar
to previous emergency service water (ESW) piping corrosion
discovered in August 1984 and February 1985 during
cleaning of the pipe.
.
_
.
29
The inspector observed preparations to repair a room cooler
piping leak using a free e seal upstream of the leak in
accordance with Maintenance Procedure M-94.2 and applicable
work instructions. The inspector also reviewed ultrasonic
measurements taken on the ESW lines to all RHR room coolers
which confirmed adequate wall thickness in excess of the
0.1124 inch minimum value:
RHR Room Coolers Pipe Wall (Inches)
A 0.12 - 0.20
B 0.23 - 0.28
C 0.17 - 0.23
D 0.19 - 0.26
These data were presented in PORC Meeting 86-81 attended
by the inspector on June 20, 1986. A mechanical
engineering representative was present to confirm the
licensee's engineering evaluation of the repair and the
overall integrity of all ESW piping. A deep pit was
attributed to be the cause of the leak, although the
possibility was recognized for future instances of
localized cotrosion pitting which would be undetectable
unless they break through. A modification was requested
(similar to an existing change on Unit 3 ESW system) to
add isolation valve's in the branch lines to each RHR room.
The PORC concluded that, pending completion of a hydro
test on the repaired piping, the ESW system on Unit 2 was +
hr.
The inspector attended Nuclear Review Board (NRB) Meeting
No. 188 held that afternoon at PECo corporate offices.
The NRB heard a well prepared presentation by Mechanical
Engineering of the current leak as well as past experience
with the ESW system. The chemical treatment program
currently in effect was described to reduce pitting and
general corrosion by 50%. The NRB questioned the cause
and duration of the leak, and based on the UT data,
eliminated the presence of a generalized thinning problem.
The NRB concluded that future leaks could occur, since
cor m ion pits already present in the carbon steel pipe
woula not be eliminated by the chemical treatment.
The NRB questioned the duration of the leak, prior to
being found via a room flood alarm, and why it had not
been found by an operator on his plant rounds. The
Manager of Nuclear Production could not explain how
frequently the RHR room spaces were inspected and, based
on a request from NRB members, committed to consideration
of an explicit item in the operator round sheets to
observe for potential leakage in the room to detect
~. - - -- --. -- - . - . . - . - _ -. - - .- . .
!
. +
30
4 possible future leaks. The NRB meeting lasted-
- approximately one hour, with appropriate senior PECo
management attendance. The NRB concluded that the weld
repair of the leak was adequate, that ESW system integrity
-
was acceptable, that the system was operable, and that
i' Unit 2 could be restarted. NRB meeting attendees seemed
to focus primarily upon the engineering aspects of the ESW
event. This may have been a function of board expertise-
makeup with only one true operational area representative <
present. !
6.3 Maintenance Staffing ,
, >
. The Maintenance Division consists of 1153 personnel stationed at
various PEco stations (nuclear and non-nuclear), the Oregen Avenue
1 Philadelphia headquarters, and various mobile groups such as for
i equipment balancing, turbine work, battery and transformer '
i expertise. The organization reports to a Superintendent, Maintenance
Division, who is distinct from power plant supervision but who does
in-turn report through a manager to the same vice president as docs
l Peach Bottom station management.
4
The Peach Bottom Maintenance Division staff dedicated to and
! stationed at the site is adequately staffed and consists of: 72
i
tradv .aen; 38 first-line supervisors at the sub, assistant and
foreman level; 28 helpers; and engineering support staff of ten
engineers and technical assistants, and, three supervising
engineers. The tradesmen include 13 electricians, 17 machinists, 18
'
pipefitters, six welders, 13 riggers, and other tradesmen. The '
,
group also uses four shift-assistant foremen to coordinate witt, u
! control room and effect the transfer of requests for permits and I
- blocks and maintenance ready to work. The shift foremen were
i
t
observed to be highly experienced at Peach Bottom (on the order of
10-15 years), respected by their peers and co-workers, and effective
'
l at getting the support of maintenance tradesmen in troubleshooting
!
and completing work. -
'
<
- The Maintenance Division currently employs approximately 90-100
Catalytic, Inc. contract electricians, painters, carpenters, and
.
, laborers. The majority of those contractors have had significant
. experience at Peach Bottom, and are used for standard work such as
erecting scaffolding, painting, preventive maintenance on the
l travelling screens, and certain work under the direction of a vendor
representative, but supervised by a permanent PECo sub-foreman.
l. Although the permanent station staff does presently have a shortage '
j of electricians which has been supplemented via the Catalytic
i
contractors, the station also is supported by mobile Maintenance
Division personnel and the specialty groups based out of the Oregon
4
Avenue shop. Therefore, the ability to draw upon that mobile
resource is a significant strength in addressing unexpected
C
ww.-<. . -w-----._- , - - - - - - - - - - - - -+-a
.
31
equipment failures and scheduled outage maintenance. An example
observed during this inspection was the Unit 2 main transformer
problems and mini-outage work, all of which was supported in a
timely manner by maintenance crafts.
The licensee has also recognized the need to qualify and staff the
Division for the future as evidenced by the 28 helpers assigned to
Peach Bottom and the training programs for tradesmen in progression
which is discussed in detail 6.1.3.
Staffing in the plant groups assigned to the Engineer-Maintenance
appears to be thin, with a need for technicians or technical
assistants to handle the administrative workloads associated with the
CHAMPS system. The inspector discussed the utilization of
n'aintenance trending with the Assistant Engineer - Maintenance. The
licensee recently established a program to perform maintenance
history searches using MRF and NPRDS data and formalized failure
reports. Although there are approximately 30 instances logged which
are being researched, only five were actually completed and available
for review. The inspector reviewed a railure investigation report
for the E-4 emergency diesel generato. fuel oil leak that occurred in
November 1985. The report was an excellent example of detailed
failure analysis including investigative fallowup of causes and
failuro mode and recommended corrective antions. The report has also
since been used as a valuable reference by plant personnel. However,
because of a lack of available manpower in the plant uaf f group, the
failure reports have not yet been formally produced. Further, the
time and expertise on the CHAMPS and other data bases required to t
obtain equipment maintenance histories has precluded preparation of k
such reports. M
The instance involving equipment history was the steam packing leak
experienced on the Unit 2 RCIC inboard isolation valve M0-2-13-015.
In response to the inspector's request, a history of maintenance MRFs
on the valve was obtained which was timely and useful in determining
equipment qualification considerations. But, since failure analysis
reports are completed at the discretion of the Engineer - Maintenance
or in response to other requests, no report had been generated as of
the end of this inspection on the RCIC packing leak and its apparent
effect on the failure of the main steam line drain valve M0-2-02-074
installed directly beneath the RCIC valve. The inspector entered the
Unit 2 drywell and observed the condition and repair of both of the
above valves. The inspector discussed the condition of the Limitorque
contacts for the 074 valve with tradesmen repairing the valves. The
contacts were corroded and apparently shorted-out by the packing leak-
age from above via a broken electrical conduit. The inspector reviewed
the environmental qualification data sheets for both valves, and noted
that the 074 valve was qualified for six days of post accident opera-
tion at 100% relative humidity, as well as boric acid and water spray.
The inspector discussed the failure cause of the 074 valve with
Electrical Engineering personnel, the plant Engineer - Maintenance
.
32
and the Maintenance Division Engineering Supervisor. The capability
of the valve to withstand direct water impingement was questioned
and, pending a failure analysis for the valve, is unresolved
(277/86-12-07).
6.4 Maintenance Interfaces and Communication
6.4.1 Blocking and Permit Coordination
The inspector interviewed licer. sed Chief Operators stationed
in the control room who are qualified to prepare blocking
permits. The inspector also reviewed the prioritization of
work which is available for maintenance and that requires
cumpletion of MRF Section 5 to turnover equipment from
Operations to Maintenance personnel. Finally, the
inspector accompanied the Maintenance Division Shift
Assistant Foreman who is the working interface between
Operations and Maintenance Groups and who provides a direct
conmunication between the control room and the tradesmen,
F rticularly on the backshifts, to initiate maintenance
coubleshooting and work. A discussion of the role of the
Cr.ief Operator with respect to outstanding MRFs is
conteined in Detail 6.1.1.
The icensed operators available to prepare blocking and
permits are apparently in shortage, and the licensee has y
not been successful in consistently staffing an extra Chief ~
Operator (CO) as a "MRF-Doctor" on backshifts or weekends. e
The inspector noted that, for day shift during the Unit 2 i
mini-outage, this inspection, an extra C0 was provided to (
coordinate preparation of permits. However, on the back-
shifts and weekends even during the mini-outage, no extra
C0 was present. Permits required during those off-normal
hours must be prepared by the control room C0 or a super-
visor whose duties are towards the operating unit (s). While
the inspector found no evidence of safety-related correctiva
maintenance which was neglected because of this shortage of
C0's dedicated to permit preparation, there were observed
delays over the backshifts in initiating mini-outage work
until permits could be provided on the next available day
shift. On the other hand, the inspector found on one
occasion that there were on the order of 25 permits already
prepared which awaited between timing or plant conditions
to work (i.e., priorities were low or jobs scheduled for
weekends or work restricted by Technical Specifications).
Also found were an equal number of permits previously writ-
ten but filed ir. the control room which required a plant
outage to work. Therefore, the statistics of backlogged
MRFs requiring a permit do not indicate a complete story
concerning constantly changing priorities in the centrol
-
0
33
room. Safety related work and significant short-notice
plant equipment problems do routinely receive immediate
priority attention.
Improved work coordination and job planning is observed to
be bringing a manageable amount of work to the attention of
the C0 for permits. But, reduction of the backlog of MRFs,
support of the developing PM program, and the ability to
deal with unscheduled mini-outages will require licensee
attention to better staffing the blocking coordinator
position. The inspector observed a currently vacant back-
.oom adjacent to the control room, and discussed this with
the licensee as a possible location for more efficient per-
mit preparation and coordination. Licensee supervisors in
Operations and Maintenance were interviewed and all were
found to be cognizant of the problem in consistently staffing
the permit coordinator position.
The inspector interviewed and accompanied several Maintenance
Division Shift Assistant Foremen on both day and swing-
-
shifts. The shift foreman is a position resulting from
NRC NUREG-0737 requirements for a craft representative .
on-shift at all times. The four individuals assigned to
th's position at Peach Bottom were found to be well-
respected by their peers in all site groups, and to have a ,
significant amount of Peach Bottom work experience. The
shift foreman attends shift turnover meetings and is a
central contact for plant management concerning maintenance +
problems and work status during backshifts. The indivi- k
duals filling these positions at Peach Bottom were observed U
to be efficiently utilized in coordinating maintenance
activities, such as the Unit 2 IRM replacements and Unit 3
Recirculation MG-Set lube oil troubleshooting. This posi-
tion is a strength and contributes towards good communica-
tion between control room operations and in plant Mainte-
nance Division foremen and tradesmen.
6.4.2 Outage Planning
The inspector interviewed the Outage Planning Engineer and
i
'
discussed the recent 14-month Unit 2 pipe replacement out-
age and the 8-month Unit 3 refueling outage which covered a
combined timeframe of April 1984 through March 1986. The
inspector also reviewed plans for the upcoming Unit 2
outage scheduled in February 1987. Delays in the previous
outage work were attributed to unanticipated problems such
as core spray sparger repairs. Improved planning techni-
ques have been implemented, including the use of area
coordinators for drywell, fuel floor, reactor systems and
balance of plant work. The licensee uses a computerized
l
'
I
1
.
-
34
planning software program, PREMIS, to schedule and track
planned maintenance work for the April 1987 Unit 2 outage.
The inspector reviewed a Unit 2 outage planning performance
monitoring printout dated June 26, 1986. The status of
outage work was broken down by principal work group (i.e.,
Maintenance, Construction and E&R Lab Divisions) and in the
four plant areas. Work was further subdivided into five
segments for manageability as well as by one of three
status codes. The inspector observed 2648 total MRFs, over
half of which are scheduled on PREMIS (and CHAMPS) for
-
Unit 2 outage work assigned to the three principal work
groups. These statistics include approximately 1500
preventive maintenance items and 600 corrective maintenance
activities assigned to the Maintenance Division. The
inspector concluded that the licensee is plaaring and
tracking work status sufficiently in advance of the Unit 2
outage.
The inspector noted through discussions with the Outage
Planning Engineer that improvements were underway in work
planning based on the past recent outage experience. The
problem of being in an outage constantly for two years on
either of the units was being addressed by E&R engineering,
Maintenance Division and plant staff programs. The Outage
Ergireer's staff of 20 personnel currently includes an ade-
quate number of engineers, technical assistants, coordinators
and clerical aids. Additional support is provided by
Engineering & Research projects section engineers who are 5
developing work priorities and schedules for the upcoming i
Unit 2 outage. Finally, the Outage Engineer stated that he (
would be attending the INPO sponsored outage planning
manager's workshop in September 1986. The inspector con-
cluded that the licensee's recent improvements in approach-
ing outage planning, and the extensive experience of and
peer respect given to the Outage Engineer who has been
working at Peach Bottom as both a refueling floor
supervisor, reactor engineer, and in his current position
since September 1983, are a significant strength.
l 6.4.3 Quality Assurance and Quality Control
!
The inspector interviewed corporate supervising engineers,
the Peach Bottom site supervisor and engineers, and various
personnel in the QA and QC organizations. QA audits and QC
inspections were reviewed in the area of maintenance, and
findings were evaluated for significance and licensee
management response.
l
l
l
.
35
6.4.3.1 Quality Assurance Audits
QA audits and surveillance in the area of main-
tenance were reviewed by the inspector. A total
of 14 audits were conducted in 1985, and 7 were
conducted in 1984. The inspector noted that there
were no outstanding responses to QA findings in
the maintenance audits, and that the audits were
sufficiently detailed so as to understand the
concerns raised by QA. Further, Maintenance
Division management attention to QA findings was
appropriately documented by memorandum for the
Superintendent of the Division, were timely and
responsive. The audits covered a ,ariety of
safety-related activities including: the control
of heavy loads, snubber maintenance, annual diesel
generator overhauls, RHR valve and HPCI turbine
work, CRD replacements, recirculation piping
repairs, ISI programs and maintenance training.
The QA audits also addressec che status of asso-
ciated NRC findings includi, violations, open
items, and Information Notices.
QA Audit Report AP 85-109 was c aducted at Peach
Bottom from 12/12/85 through 1/13/86 to assess ,
the valve maintenance performed during the
Unit 3 refueling outage. The inspector reviewed
the results of the QA audit concerning response +
to certain containment isolation valves, which h
addressed proper MRF processing, parts and mate- E
rial procurement and control of weld filler mate-
rial. The QA auditor concluded that programmatic
controls applied towards the valve maintenance
were adequately implemented.
! QA also performs surveillances in accordance with
prepared checklists. The inspector noted that
three surveillances of maintenance activities
were conducted in 1984, none in 1985, and one
to-date in 1986. The inspector reviewed QA Sur-
l veillance SP 86-01 conducted on 1/28-2/4/86 for
l the E2 diesel generator drive air blower repair.
'
The surveillance checked for 12 distinct items
such as properly calibr,ated tools, appropriate
l MRF documentation and procedures, the presence of
l certified QC inspectors and established fire
I watches if necessary, adequate permits and tagging,
l completed QC hold and witness points, and post-
- maintenance operational verification. The sur-
! veillance identified no deficiencies, and concluded
'
l that adequate work controls were established with
l
r-
.
36
effective QC inspection. Responsible QC and Main-
tenance Div sion management were made aware of
the surveillance findings. The inspector also
noted acceptable QA findings related to: four
3-hour post-maintenance run-in tests were compre-
hensively performed by the vendor. Fairbanks-
Morse; QC provided 24-hour coverage of the repair
and performed in-line inspections which assured
that quality was maintained at the work area; and
PORC approved procedure changes were being used.
The inspector reviewed a QA Division Activities
, Summary Report for the period May 23 - June 5,
1986, and discussed the report with the Peach
Bottom QA Supervisor. The QA Supervisor has been
assigned to that position at the site for four
years, and has had previous Maintenance Division
experience The inspector concluded that the QA
group at Peach Bottom is assessing significant
! .intenance activities, identifying findings which
e receiving appropriate Maintenance Division
management attention, and assuring that quality
work was being maintained in accordance with pro-
grar. controls.
6.4.3.2 Quality Control Inspections
QC performs planned inspections and random moni- e
toring of maintenance activ~ities, and the results 1
of these inspections are provided to senior i
licensee management via monthly memoranda from
the Superintendent of the QA Division and by
using the computerized QA Trending and Tracking
System (QATTS).
QC is an integral part of the performance of main-
tenance, since QC input in Section 4 of the MRF
,
is required prior to preparing permits and initi-
l ating work. The total number of MRFs reviewed by
,
QC for proper administrative controls, work class-
l
ification and QC hold and witness points was 531
- from January through May, 1986. Included in that
total are Final MRF Section 7 reviews by QC
following completion of the maintenance. QC
inspectors focus on maintenance and associated
,
'
activities in radwaste, housekeeping, fuel hand-
ling and receipt inspections. QC hold and witness
points are permanently incorporated in Maintenance
Division Procedures, and may also be added during
the pre-work MRF Section 4 review by QC.
.
37
The inspector reviewed the monthly report for May
1986 of QC inspection and monitoring at Peach
Bottom. QC results are expressed in percentages
of acceptable inspections, and of a total 142
inspections performed in May, 92% were satisfac-
tory. The report used QATTS data to trend QC
inspection findings, which increased from 80%
satisfactory in March 1986 to the present per-
centage. Computer generated trend plots of
satisfactory findings over the past 12 months are
produced in the monthly reports using linear
regression analysis. A steady trend (no change)
over the past 12 months depicted a mean
successful inspection frequency of 90%. QC also
performs random monitoring of activities and is
experiencing current satisfactory results
approaching 90%, with an improving trend over the
past 12 months. The improvement was attributable
import to separate tracking of housekeeping
findings which had been previously included in
monitoring statistics. Specific maintenance
coverage by QC over the 3-month period .
March-May,1986, showed 96-100% satisfactory
results. Maintenance inspection statistics over
the past year exhibit an improving trend between
upper and lower confidence levels of 82-96%
acceptability.
,
,
The inspector reviewed a QATTS sort of 466 total
l QC reports in 1986 (to the present) addressing y
, m.aintenance activities, of which 443 or 95% were
l
satisfactory. The inspector also reviewed the
,
QATTS description of the 23 unacceptable finding,
of which two remain open regarding a deficient
reactor recirculation pump seal flange and an
equipment failure due to normal wear. Selected
findings were reviewed, discussed with QC per-
sonnel, and found by the inspector to be repre-
sentative of a broad sampling of maintenance
including snubber installation, motor operated
i valve repairs, torquing sequences and tool
! control. The inspector reviewed a more extensive
l QATTS sort of 2197 total QC inspections performed
l in 1985 for maintenance activities, and found an
l overall success frequency of 88%. Of the 263
documented unsatisfactory findings, 3 remained
open as of this inspection awaiting engineering
evaluation or documentation.
I
l
l
l
.
38
The inspector discussed QC findings, program fea-
, tures and staffing with Peach Bottom QC personnel.
The workload in QC increases to in excess of 75%
maintenance inspections and monitoring during
outages, as have occurred at Peach Bottom for the
past two years. The site QC group has also been
more involved in housekeeping inspections during
the past 6 months. The group has used QATTS with
data retrofit back to January 1985. Staffing
included four engineers including supervision,
and 15 QC inspectors of which approximately 10
are contractor provided by Catalytic and certified
to ANSI Level II. The QC group has also used a
licensed operator and health physicist (on-loan)
at times, and corporate supervision is visibly
involved in site activities. The corporate QC
supervisor is consistently present onsite, accor-
ding to interviews with QC personnel, 2-3 days
per week and has experience in Maintenance
Division prior to QC assignment. During ESW pipe
repairs and IRM replacement maintenance observed
as part of this team inspection, QC involvement
in work planning and performance was evident.
The inspector concluded that QC is extensively
involved in consistent evaluation of maintenance
activities, that findings are being tracked and
trended for presentation to licensee management, 4
'
and that a high percentage of QC inspection
(90-95%) has resulted in satisfactory findings, h
with relatively few remaining unresolved defic-
iencies. The coverage and data analysis provided
by QC for maintenance activities is a strength.
6.4.4 Engineering Support
Corporate E&R engineering support of plant maintenance was
reviewed on a limited basis. The evaluation is based on
discussions with mechanical and electrical engineering per-
sonne] from corporate Philadelphia offices, Peach Bottom
site maintenance staff (which also include engineers), and
inspection observations of the ESW pipe repair (addressed
in Detail 6.2) and the Unit 2 RCIC MO-2-13-15 valve packing
leak (addressed in Detail 6.1.1).
The ESW pipe repair received prompt and thorough engineer-
ing evaluation, which was based on site visits by a respon-
sible system engineer, and PORC and NRB evaluations of the
repair.
.
'
39
The Unit 2 RCIC valve packing leak was evaluated to
initially result in temperatures of approximately 300 F at
the valve motor which reduced its qualified life consider-
ably based on thermal aging. The inspector reviewed a more
refined calculation of space temperature increases near the
motor predicted to be 192 F. The inspector discussed that
calculation with the responsible mechanical engineer and
found the assumptions and methodology to be reasonable and
well-thoughtout using space cooler ventilation character-
istics. However, a finalized version of the calculation was
not available at the time of this inspection and the
thermal aging prediction had not yet been performed.
Excellent engineering support was observed within the Main-
tenance Division engineering group assigned to the Peach
Bottom site. The group includes a supervisor, 3 engineers
and 6 technical assistants who assist in procedure genera-
tion and revision, equipment failure analyses, and coordina-
tion with vendor support for maintenance problems.
In addition to the plant staff technical engis ering staff
which does not typically support maintenance activities,
the licensee utilizes a contract staff of 32 Bachtai startup
engineers to assist in various maintenance activicies. The
plant Engineer-Maintenance relies upon support frcm this
contractor and others to implement various programs associ-
ated with maintenance. The Engineer-Maintenance has rela-
tively few engineers on his staff (four) and relies on tech- t
nical assistants to perform equipment maintenance trouble- i
shooting, failure. history, PM and spare parts work and other (
coordination requiring engineering input.
E&R corporate engineering is apparently adequately support-
ing site maintenance. Although modifications were not
evaluated as part of this inspection, a measure of corporate
engineering support is the 70 completed modifications
installed and field tested on Units 2 and 3 since January
1986, and the 124 approved modifications to be installed
during the Unit 2 1987 refueling outage.
6.5 Personnel Attitude Towards Nuclear Safety
Maintenance Division tradesmen interviewed were knowledgeable of the
distinction between safety and non-safety related work and systems.
The inspector noted a strong sense of pride among Maintenance
Division personnel regarding the quality of their work. This
observation held consistent frnm interviews with superintendents and
supervision, engineering support, foremen and tradesmen, and other
support groups such as training. The inspector also identified a
. . - . . _ _ _ _ _ - __
.
40
clear accountability for the quality of maintenance work, particu-
larly between the first-class tradesmen and immediate supervision at
the foreman level. The accountability extended to the mobile Main-
^
tenance Division groups including the general pool and other
specialty groups based out of the Maintenance Division Oregon Avenue
Shop in Philadelphia. Although there are a relatively large number
of employees (1153) and only approximately 100 personnel permanently
assigned to Peach Bottom, the mobility and experience level of the
Maintenance Division is a strength. Most personnel interviewed had
greater than ten years of experience, with much of that experience at
Peach Bottom. Further, because personnel in the Maintenance Division
can and are moved about the PECo system at various power plant
locations (nuclear and non-nuclear), tradesmen and supervision are
aware of individual abilities and performance. This mobility allows
for better accountability and work planning.
Maintenance Division management are aware of workload status,
individual performance, and the overall quality of plant systems.
Perceived or identified prcblems are pursued, such as recent SALP
findings in the area of . intenance and the backlog of maintenance
work. Supervision from ie superintendent level to the foreman
level were aware of these problems, and were observea to be engaged
in solutions to tho.;a proble:s. Examples include the continuing
effort to better quantify t; i status of outstanding MRFs, the
dissemination of Fairbanks Parse Service Information Letters, and
routine in plant inspections of equipment and area ccnditions and
housekeeping. The inspector accompanied the Maintenance Division
Supervising Engineer, the plant staff Engineer - Maintenance, and 3
the corporate QC supervisor en a plant walk-through to inspect h
selected areas based on existing housekeeping concerns and equipment M
problems. These included the Unit 2 refueling floor and the fan
spaces for the recirculation motor generator sets. Supervision were
observed to be knowledgeable of present plant problems and effected
quick solutions to those problems. The inspector raised a concern
for the potential of a siphon developed on the spent fuel pool due
to a hose associated with hydro-lasing and the installation of new
fuel storage racks. In immediate response to that concern,
Construction Division personnel and the supervising tradesman on the
refuel floor were summoned to the area, discussed the portable hose
condition, and agreed to shut a suction valve which would prevent
the possibility of a siphon.
The licensee has also instituted a deficiency correction program
utilizing Bechtel's startup contract engineers who completed a plant
walkthrough during the past month which identified approximately
1000 housekeeping and equipment conditions requiring correction.
The inspector observed these items during plant tours which were
identified using equipment trouble tags. This effort will' result in
a significant upgrade in overall physical plant conditions.
. , -
-_ _. _ _ _ .
.
1
41
-
Maintenance Division personnel exhibited an open and candid approach
towards the inspector's questions, and were cooperative and '
interested in the areas evaluated during the review of maintenance
activities. Some maintenance tradesmen interviewed expressed a
frustration with the increasingly longer amount of time required to
finish a job, and attributed that protracted effort to increased
, paperwork demands and detailed procedures. Some tradesmen also
j expressed a concern for a lack of feedback on work performed-(i.e.,
i-
the status or success of a job) and development of procedures
requiring their input.
6.6 Summary
The Maintenance Division was found to be a well staffed and trained
-
resource at Peach Bottom. Training, including OJT and feedback, and
experience levels of tradesmen is high, with many in excess of 10
years at Peach Bottom. The Division management is knowledgeable,
1
'
well-informed and interested in solving and worker safety clearly
stressed. A strong sense of pride among tradesmen and other division
personnel was evident, as was accountability for work quality to
. first line sub-foreman and higher supervision. Overtime hours are
l consistently tracked and controlled with NRC guidelines, with a
maintenance goal established and evident to limit and more-evenly
spread overtime to 20% for assigned Peach Bottom crafts. Contractors
,
are also carefully used and integrated into the permanent site staff.
The plant staff of the Engineer - Maintenance is not as adequately
staffed, and increased program demands in the areas of PM, CHAMPS *
processing and equipment history and failure analyses will strain 'h
those resources, particularly during outages. The statistics of L
- outstanding MRFs in the system suggest a need for a better
coordination, planning and staffing in the interface control room
! position to coordinate blocks and permits.. The Maintenance Division ,
!~
Shift Assistant Foreman position appears to be working well towards
i
focusing proper maintenance attention of priority plant problems.
Management goals towards improved work planning are evident in the
i outage planning function and Maintenance Division Assistant foreman
J assigned as planners. However, not all management goals are clearly
i
i
understood at the tradesman level, suggesting a possible need for ,
better feedback to Maintenance Division crafts.
l 7.0 Surveillance
Surveillance testing activities were reviewed by the shift and supporting
inspectors. Observations of tests, or parts of tests, were conducted to
[ assess performance in accordance with approved procedures and LCO's, test
results (if completed), removal and restoration of equipment, and
f
I
- ,
-
_ , , - - . , , - . _ - . , - - , - , -
- . . - _ - - - - - . . . . - - - . - - - - --
,
.-
42
deficiency review and resolution. In addition, a review of the
surveillance test (ST) program including management controls was
performed.
7.1 Surveillance Program
The surveillance program is controlled by Administrative Procedure
A-43, " Surveillance Testing System" (Rev. 17, September 30,1983).
A-43 assigns responsibility for the preparation and maintenance of a
master test schedule to the ST Coordinator. The schedule is
maintained in the form of a computer database which can display
status, print copies and receive updated information. The ST
Coordinator inputs current plant conditions and obtains a printout
which identifies STs, broken down by group responsibility, which are
due to be performed during the following week.
!
Current copies of the-STs are given to the cognizant engineers prior
to the week due. The STs are performed by lab or shift personnel
and are reviewed by shift supervision to determine if the test
results are satisfactory, or if the unit has entered an LC0 due to a
test failure, or if other. followup action is appropriate. Following
.
additional review by plant staff, the completion of the STs is
entered into the database. The performance of the ST program was
found to be adequate in that the system was found to consistently
identify the STs coming due under current plant conditions and
provided the cognizant engineer up-to-date procedures with
sufficient lead time to schedule the tests.
Nodeficierifeswereidentified,howeverdetail6.3documentsa
related con'cern. 1;
7.2 Surveillance Activities
During the course of the inspection, numerous STs, or parts of STs,
were monitored by the shift inspectors. A list of the observed STs
is included in Section 7.4 of this report. The operators reviewed
the ST procedures and consulted with them during the course of the
tests. Minor deficiencies, such as a broken support bracket and a
small flange steam leak during ST 6.5 HPCI Pump, Valve, Flow,
Cooler, were noted and entered into the MRF system for repair.
HPSW pump 3A did not meet the acceptance criteria for discharge
pressure vs. flow rate during the performance of ST 6.10-3, "HPSW
Pump and Valve, Operability and Flow Rate Test". The Control Room
gauges indicated that the discharge pressure was too high at the
required rate of flow. Shift supervision declared the pump
inoperable; this placed the unit in a 30 day LC0 since with HPSW 3C
out of service for repairs only HPSW pumps 3B and 3D remained
operable. Subsequent testing identified the problem to be an
inaccurate control room gauge, which read 40 psig high. The gauge
.
43
was labelled to indicate the deficiency, a MRF to recalibrate the
gauge was requested, and HPSW pump 3A was declared operable thus
exiting the LCO.
No deficiencies in surveillance activities were identified.
7.3 Control and Oversight of Activities
The control and oversight of the ST program was identified as a
weakness in Inspection Report 50-277/85-44; 50-278/85-44 in that
management controls might not be adequate with respect to overdue
STs. In an April 9, 1986, response the licensee committed to
certain immediate actions to address the concern and also committed
to implement changes to the controlling Administrative Procedures
within 90 days.
The inspector reviewed the list of late (beyond " grace date") tests
dated July 1, 1986. Changing plant conditions and processing lag
time may cause some completed tests to appear missed, but the Peach
Bottom list reviewed by the inspector with 325 missed tests appc red
excessively large. Of the 325 items, 69 were STs, tied to TS
requirements. Another 16 missed STs involved emergency drills or.
- f Unit 2 and extend back to the first quarter of 1985. .
In response to the inspector's concerns, the licensee took action tu
'
determine the surveillance status of certain key systems (Unit 2 B
Core Spray, A RHR, and HPSW systems; Unit 3 A RHR system) and RPS
.
trip functions (Unit 2 turbine stop valve closure and turbine control
_
e
valve fast closure; Unit 3 turbine stop valve closure). Documentation $
was found for the testing of the Unit 2 Core Spray and the Unit 3 A i,
RHR systems, but the licensee determined that the other STs had not
been performed. The licensee subsequently completed the remaining
five STs satisfactorily on July 1-2, 1986. Failure to complete these
five missed STs is an apparent violation of Technical Specifications 4.5. A.3 (Unit 2 A RHR), 4.5.B,1 (Unit 2 HPSW), and Table 4.1.1 (Unit
2 turbine stop valve closure and turbine control valve fast closure;
Unit 3 turbine stop valve closure). (277/86-12-08; 278/86-13-08).
The inspector reviewed the most recent QA audit of the ST program to
'
determine if the issue of overdue or missed tests was being followed
by the QA group. The QA audit, performed in March 1986, reviewed
205 completed STs but did not note whether or not the tests had been
performed on time.
-
The ST Coordinator prepares two lists of late tests which are
provided weekly to cognizant engineers and station management. One
list identifies the tests which are late (but still within the
" grace period") and the other list identifies the tests which were
missed (beyond the " grace date"). The volume of missed tests (325
in the July 1,1986 list), the duration of the overdue periods (some
- - -. . _
a
44
.
back to 1985), and the potential significance of certain missed
tests (e.g., ECCS trains and RPS trip signals) indicates that the
current system of control and oversight of the test program is not
effective. This finding is consistent with and an expansion of the
finding contained in Inspection Report 50-277/85-44; 50-278/85-44
and indicates that corrective actions to date have not addressed the
identified weakness.
7.4 List of Tests Observed
Portions of the following surveillance testing activities were reviewed:
ST 1.3-3, Unit 3 PCIS Logic System Functional Test
ST 6.4, MSIV Closure Timing and Closure Timing Adjustment, Unit 3
ST 6.5, HPCI Pump, Valve, Flow, Cooler, Unit 2
ST 6.10-3, HPSW Pump and Valve Operability and Flow Rate Test -
Unit 3 Only
ST 8.1, Diesel Generator Full Load Test
ST 9.1-2X, The Surveillance Log
ST 9.1-2Y, The Surveillance Log
SY 9.1-2Z, The Surveillance Log
ST 9.1-3X, The Surveillance Log
ST 9.1-3Y, The Surveillance Log
ST 9.1-3Z, The Surveillance Log
ST 9.2, Control Rod Exercise, Unit 3
ST 9.7, MSIV Partial Closure and RPS Input Functional Test, Unit 3
ST 9.17-3, Reactor Coolant Leakage Test - Unit 3 Only.
e
7.5 Summary :
'
t '
The team reviewed the in place ST program, the conduct of testing
activities, and the control and oversight of the testing program.
The ST program was found to adequately identify and schedule testing
activities. No deficiencies were noted in the performance of tests;
personnel used approved procedures, compared test results to valid
acceptance criteria, and made appropriate determination with respect
to system operability. The control and oversight of the testing
program by management was found to be a significant weakness. The
. improper focus of ST performance accountability and oversight has
resulted in many missed tests including STs on ECCS systems and RPS
functions.
8.0 Radiological Controls
8.1 General
Radiological controls activities in the station were observed during
the inspection by the shift inspectors and a specialist inspector.
The review areas include program documents, discussions with
- radiological controls and other station personnel, attendance at
l licensee planning meetings, and observation of radiological controls
l
<
45
practices during ongoing work. The training and qualification
program for contractor and permanent radiological controls personnel
was also reviewed.
8.2 Organization and Staffing
The licensee's radiological control organization has undergone two
recent reorganizations. A reorganization early in 1985 of the
combined health physics / chemistry group resulted in the establishment
of separate health physics and chemistry groups. A reorganization of
the health physics group in mid 1985 resulted in the establishment of
a separate ALARA sub group. The health physics group currently
consists of three sub groups: a technical sub group, an applied
sub group, and the recently established ALARA sub group.
These changes within the health physics group were performed to
address NRC and INP0 identified concerns. One of the concerns was
that a substantial number of contractor personnel (about 40
technicians) were being used in authorized licensee permanent
pc itions due to, among other items, the lack of adequately trained
a ' qualified licensee technicians. Licensee technicians currently
in training and once trained are anticipated to reduce reliance upon
centr.: tor personnel for non-outage routine activities. The
licer. ee is actively attempting to reduce the number of contractor
techn cians commensurate with the completion of training for the
newly hired personnel.
More recently (January 1986), the licensee has performed an evalua- +
'
tion of the organization and staffing needs of the Health Physics 8
Group. The evaluation has identified that the current organization E
needs improvement in order to adequately implement the responsibil-
ities of the group. The evaluation also recommended that about 30
- individuals (management and non-management) be obtained to fully
j staff a recommended (expanded) organization. Licensee senior manage-
'
ment is currently reviewing the recommendations. Reviews during this
inspection indicate some problems (e.g., lack of timely review of
l events and lack of adequate oversight of in-field radiological
i activities) that appear to have resulted at least in part from
insufficient staffing.
!
Areas requiring further licensee attention include timely completion
j of the review of the health physics group organization and staffing,
i- and implementation and tracking of the needed changes to ensure
effective conduct of the health physics group responsibilities.
(277/86-12-9; 278/86-13-9).
i
8.3 Training and Retraining
The licensee has established and implemented an initial and continu-
ing training program for radiological controls technicians (health
physics and chemistry). Both the health physics and chemistry
l
!
l
-.
C
'
46
technician training programs were accredited by INP0 in May 1985. An
initial training and qualification program for contractor health
physics personnel is also in place. Record reviews indicate that
both contractor and licensee health physics technicians attended the
continuing training programs. Licensee personnel responsible for
implementing these' training programs were considered conscientious.
The contractor health physics technician training program did not
include an initial " diagnostic" exam for use in determining the
adequacy of a technician's knowledge prior to placement in the six
day initial contractor technician training. Also, the qualification
process did not adequately address " practical factors" qualifica-
-
tions. The need for this latter item is considered a program
weakness.
No program is in place to provide timely training of health physics
technicians in current health and safety significant matters (e.g.,
.
procedure changes, industry events) prior to them performing work
associated with these matters. This lack of timely training and
overall progressive approach to the Health Physics area leads to a
" business as usual" approach to in-field work resulting in -
inadequate program applications.
Training and qualification of contractor chemistry technicians is
implemented through the chemistry department; however, the program
is not formally described. .
The training program for professional level health physics personnel -
is described in memoranda but has not been-fully established and hL
implemented in that topic lesson plans for about 50% of the
described topics were not written and presented. The training
program for professional level health physics personnel continues to
need management attention.
] The licensee General Employee Training program has recently been
certified in accordance with INP0 guidelines. HP training will be
reviewed in a future inspection (277/86-12-10; 278/86-13-10).
8.4 Audits
The licensee is implementing the technical specification required
audits of radiological control program areas. Audit findings were
i
tracked and closed in accordance with Quality Assurance Manual
requirements.
,
'
Review of radiological controls program area audits from 1984 through
1986 indicate that individuals with little o'r no background or know-
,
ledge in the area they were auditing were used as auditors (e.g.,
i
September 1984 Health Physics Operations and Dosimetry Audit). In
addition, the depth of the audit is considered less than adequate to
l
_ _ , _ . . _
.
.
47
evaluate the acceptability of program areas audited relative to appli-
cable regulatory requirements or standard industry practice. Although
some improvements were noted in later audits, additional improvements
appear warranted to fully utilize audits as a management tool to
assure quality and maintain a current Health Physics program.
Assessments of site radiological controls activities (e.g., respiratory
protection) are performed by the corporate radiological control group.
However, the corporate audit / assessment program is not formally estab-
lished and written reports of findings are not provided to the site.
Additional licensee action is required to formally establish the
corporate radiological controls assessment program (277/86-12-11;
278/86-13-11).
8.5 Job Planning and Work Control
The licensee has upgraded the job planning and work control in the
area of radiological controls. Health physics field operations and
ALARA personnel routinely attend the recently initiated daily work
planning meetings. The health physics group uses information cbtained
at this meeting and a published five day review schedule to plcr and
staff for upcoming work. The meeting and review schedule have improved
the group awareness of upcoming work and minimized reactivt action >
by the group. Some problems still exist in this area in that perscenel
are requesting Radiation Work Permits that are not used cr are not
used within a period of several days resulting in the need for addi-
tional surveys by health physics personnel. This may result in need-
less additional exposure. Reviews of this concern should be initiated
and appropriate administrative controls (as necessary) established to '
minimize this problem. This will be reviewed in a future inspection 4
(277/86-12-12; 278/86-13-12).
'
The health physics group (ALARA) is involved in reviews and planning
for long range work. However, the interface with planning and
scheduling is not clearly defined in the licensee's program. Addi-
tional licensee action is needed in this area.
8.6 Control and Oversight of In-Field Work
- The licensee has initiated action to improve oversight and control of
in-field work in response to NRC and INP0 identified concerns. The
licensee's recent evaluation of the organization and staffing of the
health physics group has recommended organization changes and additional
management staffing to improve oversight and control of in-field work.
!
The first line supervisor for health physics operations has recently
been tasked with the requirement to spend at least four hours per day
,
in the field reviewing on going activities. However, there has been
I-
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l
_ _ . _ _ _ - _
,. _ - - _
..- .. . -. - - . . - . .- -
,
1-
., ,
.
48 -
i
i-
no; clear direction to the individual as.to what minimum activities
- should be reviewed or a clear feedback mechanism established to
- review and disposition findings in a timely and effective manner.
1
I
Some positive aspects were noted. ~For example, during this inspection,
the licensee performed generally good radiological controls planning
and preparation for the replacement of two IRMs in Unit 2. Meetings-
were held between involved groups in order to address problems identi-
,
fied at Limerick during similar IRM replacements. Procedure changes
were made specifically to improve radiological controls and address
the problems. However, the improved planning was overshadowed by'
i deficiencies in the oversight of the work practices resulting from
-
health physics technician failure to perform all' appropriate proced-
urally required radiation surveys ~during the work.
i Deficiencies were identified in the oversight and control of a nuinber
i of radiological work activities reviewed. For example, inadequacies
e
in the Radiation Work Permit controls and in-field activity oversight
i for plant clean-up resulted in improper placement of airborne radio-
activity samplers during on going wrk activities.
t
Deficiencies were identified in the oversight of work and activities
4 by the Health Physics Technical Group. Examples include inadequate
j evaluation of the' radiological envire ment-to be entered by spent
- fuel pool divers and inadequate evalui, tion of the calibration of
, radiation survey instruments and personnel dosimetry to be used by
- the divers. Also, deficiencies identified in oversight and control
1
of the calibration of airborne radioactivity sampling equipment, it
l was not apparent that some in-field air sampling equipment in use was
This will be reviewed in a future inspection
.
. properly calibrated.
(277/86-12-13; 278/86-12-13).
'
l
- 8.7 Procedures
l
The licensee has established and implemented a Radiation Protection
l Plan and procedures for implementing the plan at the station level.
[ Various supervisors in the health physics group have issued memoranda
l and " guidelines" to interpret and supplement existing site health
'
physics procedures. Topics discussed in these memoranda and guide-
lines included dosimetry placement, exposure controls, and airborne
radioactivity sampling. The licensee has no effective administrative
'
controls in place to ensure all appropriate personnel have read,
l understood, and implement the memoranda and guidelines. In some
i
cases it appears that the guidelines can be considered as procedures
[ and should be established, implemented, and maintained in accordance
l with Technical Specification requirements. Licensee action is needed
to review the guidelines and incorporate them into appropriate
j station procedures. (277/86-12-14; 278/86-13-14).
I
!
!
___ . _ . _ _ _ _ . _ _ _ __ _ _ _ _ .-. _ _ _ _ _. _ _ _ _ _ _ _-
a
.
49
The corporate radiological controls group has not fully established
procedures to define their activities (e.g., site audit assessment
program). Actions are in progress to establish and implement corporate
program procedures.
8.8 Communication
Inter and intra health physics group communications were generally
adequate. However, the need for some improvements was identified.
Principal health physics supervisors attend the daily morning meetings.
The health physics supervisor for operations meets weekly with the
technician staff in the health physics " break room" to discuss
current health physics activities. The acoustics of the health
physics " break room" were poor. Turbine building noise in conjunc-
tion with crowded conditions provided a less than adequate forum for
discussion of health physics issues.
Discussions with some technicians indicated some problems relative to
communication from " top down" in that problems are brought to super-
vi.C m's attention but no " feedback" is provided on the problem (e.g.,
02/ "' analyzer calibration check). Some health physics technicians
expressed morale concerns due ir, part to inadequate communication
concern .
he licansee's Senior Health Physicist has scheduled meetings with
his st&ff and with representatives of health physics technicians.
The meeting serves as a forum to discuss status of goals and issues
brought up by technicians.
Additicnal licensee action may be required to address the adequacy of 4
communications between health physics supervisory / management
personnel and the technician staff. This item will be reviewed in a
future inspection (277/86-12-15; 278/86-13-15).
8.9 ALARA
The licensee has made a number of notable improvements in the ALARA
program to provide for upgraded ALARA oversight of radiological work.
Examples include establishment of a separate ALARA group, establish-
ment of program procedures, improvements in training, and utilization
of computers. Observation of ALARA activities indicate the initiatives
have made some apparent improvements in the effectiveness of ALARA
oversight of on going activities.
Although ALARA program improvements have been made, some deficiencies
were identified involving the establishment of necessary program pro-
cedures and controls. For exar.ple, procedures are not in place for
performing cost benefit analysis, interfacing with planning and
scheduling, controlling of work requests to ensure adequate lead time
for ALARA review, and the review of design change modifications.
Procedural guidance far performing ALARA reviews of on going work
_, _ _ _ __
.
d
.
. '
50
were considered inadequate due to a lack of defined criteria for
initiating reviews. The licensee was using an informal criteria (25%
excess exposures, man-hours, or dose rates) to select jobs for ALARA
review.
Licensee action is needed to address the need for specific procedures
for ALARA goal setting, tracking and the review of goals. Examples
of possible goals include man-rem and area contamination. This is
considered a program weakness. (277/86-12-16; 278/86-13-16).
8.10 Corrective Action Program
The licensee is currently revising the program for identification,
tracking and resolution of radiological controls deficiencies. Find-
ings identified during this inspection (e.g., five instances of the
same contractor being contaminated on the refueling floor) establish
the need for program improvements, particularly in the area of timely
disposition of findings.
The licensee has obtained radiological controls deficiency programs
from other utilities and is modifying its program to include some
attributes of the programs. A draft program procedure addressing the
.
corrective action program area has been written and is currently being
reviewed.
8.11 Overtime (Health Physics)
The licensee has established administrative controls to limit overtime i
consistent with NRC guidelines for licensee radiological control per- i
sonnel. However, the program was not effectively applied to contractor 9
health physics technicians. The contractor site coordinator was
unaware of all licensee administrative requirements in this area.
Although no apparent instances of exceeding overtime guidance was
identified, due primarily to a lack of available overtime for con-
tractors, licensee action is required to ensure overtime administra-
tion controls are effectively applied to contractors.
8.12 Goals
The electric production department has established goals. These
goals have been translated as appropriate into group supervisor goals.
The goals provided to health physics group supervisory personnel were
considered in some cases non-challenging and limited.
Licensee action is required to improve the goals program for the health
physics group in order to upgrade performance, consistent with current
industry standards. A tracking and monitoring program for health
physics goals is presently not established.
, _
. ._. - --, . - -
--
,
51
The licensee has established an improvement plan to improve Peach
Bottom performance. The goals (i.e., all intermediate and final
milestones) for this plan have not yet been assigned to responsible
parties.
8.13 Summary
The licensee has acknowledged the need to upgrade the health physics
program at Peach Bottom. Action has been taken to upgrade the
program in that an action plan is currently being finalized to
address NRC and INP0 identified deficiencies. The licensee plans to
place the plan on a computer for effective tracking of intermediate
and final milestones.
In consideration of the 1987 outage schedule, licensee action is
required to review the scope of the action plan to ensure adequate
resources are available to implement the action plan and effect -
needed program improvements prior to the outage. The establishment
of clear communications within the site organization and the
utilization of corporate group as a resource needs to be included
within the action plan scope.
9.0 Assurance of Quality
The scope of this inspection included an overview of QA and QC activities,
a review of QA audit and surveillance findings, a review of QC inspection
and monitoring findings, and an observation QA/QC activities during plant
. operations. In addition, other plant and oversight groups functioning to t
assure quality were reviewed. These groups include the on-site Plant $E
Operations Review Committee (PORC), the off-site Nuclear Review Board (NRB),
the on-site Independent Safety Engineering Group (ISEG), the corporate
Operations Experience Assessment Committee (OEAC), and plant and corporate
management. Procedural controls, adherence to procedures and programs to
assure quality of control room activities were reviewed.
9.1 QA/QC Program
The Quality Assurance (QA) organization includes the Electric
Production Department QA (EP-QA) and the Engineering and Research
Department QA (ER-QA). These QA organizations are described in the
Peach Bottom QA Plans Volumes I and III.
EP-QA includes a site QC group, a site QA group, and an engineering
group. The ER-QA includes an off-site QA section, an on-site QC
section for construction, and a QC section for the Testing and Lab
Division.
.
Reviews of QA and QC activities conducted in accordance with QA Plan
Volume I and III requirements and implementing procedures were performed.
.
52
9.2 QA Activities
QA performs audits and surveillances of quality affecting activities.
These audits and surveillances are documented in formal findings as
deviations or nonconformances, and are responded to and tracked by
the QA trending and tracking system (QATTS).
The inspector reviewed recent EP-QA audit and surveillance findings
in the following areas: shift operations, fire protection, and
health physics. Weaknesses were nated in health physics audit area
(see section 7.4) and the surveillance area (see Section 6.3). Audits
and surveillances of the shift operations area meet program require-
ments, however, the scope and findings of the audits are oriented
toward compliance with administrative requirements such as equipment
tagging and not toward verification of safe reactor operation.
With respect to fire prote'ction audits, a commitment was made to the
NRC regarding receipt inspection of certain fire protection items.
While EP-QA has implemented this commitment, ER apparently has not
resolved a 1984 audit finding regardir: the commitment to the NRC.
Interviews with QA personnel during tb s inspection, indicate a lack
of adequate communication between EP-QA and ER.
Audits identified concerns which are not reviations or nonconformances
but which are of significance. Tnese typus of concerns are expressed
formally in audits as recommendations. Tnese recommendations are not
tracked after the audit is issued nor is anyone required to respond
to them. The lack of a disposition for tt.e recommendations is a weak- *
ness in the QA program as many issues are not necessarily enforceable h
but should be addressed to improve overall plant operation. There b
appears to be a perception that corporate is not fully utilizing QA
as a management tool vs. ensuring that program requirements are met.
This will be reviewed in a future inspection (277/86-12-17;
278/86-13-17).
In addition, QA did not have a requirement until October 1985 to
obtain commitment dates for responses to audit findings. Subsequent
to October 1985, QA has obtained commitment dates for all new
I findings and the old findings predating October 1985, indicating a
l substantial effort by the site QA department toward trending and
l tracking of findings.
!
Based on interviews with QA personnel, the inspector concluded that
morale may be low in site QA audit group. The basis for this low
morale appears to be salary related.
EP-QA performs daily reviews of control room activities including
shift turnover, log reviews, operator discussions and system checks.
Although not required by the QA Plan, the review is normally performed
by an auditor who is a former licensed operator. The inspector
verified that this review was being performed and held discussions
l
,
i
, _ . _ . --
..
.
53
with the auditor. The QA auditor was knowledgeable of plant opera-
tions. However, the inspector noted that no formal surveillance plan
nor checklist exists for this daily review. Licensse action is needed
to formalize the control room review activities. (277/86-12-18;
278/86-13-18).
9.3 QC Activities
QC performs monitoring and inspection of quality affecting activities
as required by the QA Plan. Findings are documented and tracked using
the QATTS. QC inspection hold and witness points are part of the
specific implementing procedures. Detailed Monitoring Checklists
(DMC) are prepared by QC. QC performs reviews of maintenance, house-
keeping, health physics, shift operations, and radwaste.
The inspector reviewed selected implementing procedures for QC hold
and witness points, observed QC in the field, and reviewed the results
of completed QC DMCs. Implementation of QC activities is performed
by a group of 26 on-site people of which half are contractors. The
licensee F s a hiring and training program to replace the contractors
with perm ent PECo employees.
The inspector .eviewed selected QC DMCs with particular emphasis in
the area of ccqtrol room and shift observations. There are DMCs for
shift turnove , permits and blocking, valve control, log keeping,
equipment control status, and operator rounds. The QC group staff
includes a former qualified non-licensed operator and a recently
qualified STA to perform monitoring of control room activities. +
QC performs an informal daily review of control room activities as $
verified by inspector observations. Licensee action is needed to O
'
formalize the review of control room activities. QC accompanies the
weekly plant equipment status tour with maintenance, construction and
-
plant operations. The inspector accompanied the weekly plant tour on
June 26, 1986 (see section 5.5). In addition, the licensee has
instituted a Strive for Excellence Evaluation (SEE) Program. As part
of the SEE Program, QC performs a weekly inspection of plant operations
and communicates the result of this inspection to plant management.
9.4 Procedural Controls
'
The inspector reviewed plant procedures against the requirements of
NRC Regulatory Guide 1.33-1972 with special emphasis on procedures
for combating emergencies. After discussion with the licensee, it
was determined that the following procedures required by Regulatory
l Guide 1.33, Appendix A, paragraph F were not included as plant
procedures:
r
l
l
--
Loss of Instrument Air,
.
--
Loss of Service Water / Loss of Emergency Service Water,
!
,
. _ - _ _ , . , , , _ _. . . , , ,.-.7 . - . . -
.
'
54
--
Loss of Component Cooling System and Cooling of Individual
Components.
--
Mispositioned Control Rod.
Licensee action is needed to provide appropriate emergency
procedures in these areas.
In addition, a review of the plant administrative procedures
revealed that no administrative procedure exists for review and
approval of Routine Test (RT) procedures as required by Regulatory
Guide 1.33, Appendix A, paragraph A. The inspector was informed
that a QA audit in August 1984 had identified this problem in a
noncompliance report (NCR #AP84-43-01). Plant management appears
reluctant to correct this deficiency. Since the 1984 NCR was -
written, approximately 66 new or revised RT's have been issued
associated with safety related systems or components. The inspector
determined that RTs have been written which appear to be more
appropriately classified as other types of procedures such as
HP0/COs, REs and CAs. The Regulatory Guide requirement for review
and approval of procedures has been properly implemented for all
other procedures. Licensee action is needed to define the scope of
RTs and administratively control their preparation and issuance.
Missing emergency procedures and administrative control of RTs are
unre'olved
s (277/86-12-19; 278/86-13-19).
9.5 Other Quality Activities
9.5.1 Plant Operations Review Committee (PORC)
,.
The following PORC meetings were attended by the
inspector:
--
Special meeting on June 19, 1986, to discuss Unit 2
ESW repair procedures.
--
Special meeting on June 20, 1986, to determine the
Unit 2 ESW operability (see detail 6.2.6).
Regarding the June 19, 1986, meeting the inspector verified
that Technical Specification requirements for the required
quorum attendance were met. The meeting agenda included
the review of a work instruction concerning the inspection
and repair of an Emergency Service Water supply line to the
Unit 2 "A" Residual Heat Removal pump room. The meeting was
characterized by frank discussions and questioning of cause
and corrective actions. In particular, attention was given
to confirming the referenced repair procedures. Individual
members' opinions were encouraged.
I
.
.
55
9.5.2 Nuclear Review Board (NRB)
The NRB is the off-site overview committee that reports to
the Vice President, Electric Production. The NRB convened
a special meeting on June 20, 1986, to review the Unit 2
ESW repair and operability of the system. The inspector
attended this meeting at the PECo corporate office (see
detail 6.2.6).
Technical Specification 6.5.2 requires that NRB provide
independent review and audit of nuclear power plant
operations. The NRB Charter, Revision 8, and NRB-1,
Review Practices, Revision 3, further details these
requirements. A review of the NRB membership shows an
apparent weakness may exist with respect to operations
experience, and therefore NRB in-depth review of operations
activities. Discussions were held with the NRB Chairman
with respect to this finding. The NRB Chairman stated that
this item will be reviewed at the next NRB meeting (July
1986).
9.5.3 Independent Safety Engineering Group (ISEG)
ISEG is an on-site independent assessment group that
reports to the corporate Nuclear Safety Section. The ISEG
function includes investigations of events, reviews of
violations, reviews of operating events, and other duties
as specified in the Nuclear Safety Section charter dated, -
August 19, 1983. '
t
'
ISEG reviews control room activities daily (Monday through
Friday) as required by Nuclear Safety Section Procedure
NSS-I-2, Rev. 2, January 21, 1985. Items that are
independently reviewed include: Out of service equipment
versus Technical Specification LCOs and FSAR design basis.
Results are brought to the attention of the shift and
plant management. ISEG is currently staffed with one
supervisor, two engineers, and two individuals part-time.
The inspector verified that the reviews are being
performed.
ISEG is performing studies and participating in a program
on scram reduction in accordance with INP0 and GE owners
groups. The inspector reviewed these studies and
discussed them with ISEG engineers. These studies have
determined that eleven scrams have occurred at Peach
Bottom due to feedwater control system malfunctions.
Engineering has been requested to provide recommendations
concerning a new fault tolerant system.
_ _ _ _ _
.
.
56
9.5.4 0perating Experience Assessment Committee (OEAC)
The OEAC is a technical review group established to
provide a broad interdisciplinary review of significant
internal and external operating experience informatt.n
pertinent to the safe operation of Peach Bottom and
Limerick. The information reviewed includes: INP0
Significant Operating Experience Reports (S0ERs) and
Significant Event Reports (SERs); Service Information
Letters; NRC Bulletins, and Information Notices, and
Inspection Reports; and, Plant upset reports and operating
problems. The OEAC provides reenmmendations to management
on improving operations, procedures, training and
maintenance by means of verbal and written reports or
meeting minutes.
The inspector reviewed the OEAC Charter, dated May 23,
1984, selected OEAC meeting minutes, talked to tne OEAC
Chairmar. and attended the June 25, 1986, OEAC meeting.
The OEAC meets monthly, alternating the meeti: s at
Limerick and Peach Bottom. Open items are tr .ked and
followed up on. The inspector concluded that the meeting
was an appropriate exchange of information. The .resence
of training department at the OEAC meetings is a trength.
9.5.5 Human Performance Evaluation System
The inspector inquired as to the licensee's intentions in e
participating in the INP0-Human Performance Evaluation i
System program. The program is intended to assist I
,
licensees in the reduction of human error by encouraging
personnel to report actual or potential situations whicn
keep a person from outstanding performance. A licensee
representative informed the inspector that the program is
under review. It is recommended that a decision to
implement this program be tied to a commitment to provide
experienced, credible staff staff for its implementation.
9.6 Summary
The implementation of QA/QC activities meet program requirements.
Weaknesses were noted in the depth of QA audits of the health physics
and surveillance programs. ISEG, QA and QC are currently reviewing
control room activities although licensee action is required to
formalize these programs. PORC and NRB are administratively functioning
adequately and members demonstrate a good questioning approach. The
NRB membership may be weak in the area of plant operations experience.
The OEAC activities and the licensee's pursuit of the HPES are con-
sidered a strength.
.
-
57
10. Fire Protection and Housekeeping
10.1 Housekeeping and Plant Conditions
Housekeeping was evaluated by all NRC team inspectors during routine
tours of the plant on all shifts and was found to be acceptable. It
was noted that a major painting effort was in progress in response
to an INP0 initiative and that the painting process on previously
unpainted concrete involved surface preparation in accordance with
manufacturer's instructions.
The present state of housekeeping at Peach Bottom is in stark
contrast to the poor conditions that existed at the end of the past
outage. Both inside the power block and on the outside grounds, one
notices little or no trash, few if any tripping or slipping hazards
on the walkways, a minimum use of temporary materials such as
scaffolding, the proper storage of gas bottles, empty trash
receptacles, very little graffiti, and internally clean electrical
cabinets. PECo employees appeared to take pride in the cleanliness
of the facility as evidencer by an individual who introduced himself
to the inspectors during th ,'r tour of the Unit 3 refueling floor -
and proceeded to express his appreciation for the progress made by
his employer to clean H s work ,rea. This cleanup effort involved
recovery of a substantial amota of previously contaminated floor.
There were a few areas where hcusekeeping could use improvement.
These involved the Unit 2 refueling floor, portions of the Emergency
Diesel Generator (EDG) building, and the 116' elevation in the *
turbine building. In particular, work on the high density spent $
fuel storage racks is in progress on the Unit 2 refueling floor E
which has resulted in additional clutter and some inadequate
housekeeping problems with loose tools, a maze of hoses and cables
that should be better organized, filled trash bags, and a general
state of disarray of the items on the floor. Plant Operations is
aware of the Unit 2 refueling floor situation and has notified
Construction of their concerns. Construction has been reluctant to
accumulation of ' lubricating oil under the turbocharger end of all
four EDG's and an accumulation of fuel oil under the injectors above
the exhaust manifold of all four EDG's. The licensee addressed this
problem after the NRC inspector brought it to his attention. The
problem on the 116' elevation in the turbine building involves an
accumulation of 55 gallon drums that are filled with fluids
requiring processing. The storage of these drums appears to be
organized and the quantity, based on discussions with various plant
personnel, varies but never decreases to the point where there does
not appear to be anything less than a major storage area for 55
gallon drums. The licensee stated the drum storage is necessary and
feels it does not represent a problem. Long range plans involve
moving the drums and the associated processing equipment to the low
level radwaste storage building.
.
58
1
F
During routine reviews the inspectors observed that both extension >
and step ladders were not properly stored after use. 'The licensee
should make an effort to properly store these items after use to
eliminate the possibility of damaging safety related equipment
should they fall or be knocked over.
10.2 Fire Protection Activities
Fire protection activities at Peach Bottom were inspected and found
to be in conformance with Technical Specification requirements. The
following paragraphs discuss the specific areas inspected and the
resultant observations:
10.2.1 Shift Inspector Observations
During routine tours of all areas of the plant and outside
areas, inspections were made of fire extinguishers, hose
stations, and fire doors. Without exception, all fire
extinguishers and hose stations were found to be
accessible and had been routinely inspected for
operability. All fire doors were found to be closed and
in working order.
Technical Specification (TS) required fire watches were
observed to be touring the plant in accordance with the
route specified on their tour sheet. Fire watch personnel
were evident by their unique uniform of blue coveralls and
white hard hat. A total of two roving fire watches per _
shift were in effect to meet TS requirements. Most of the ,
yd
areas required to be toured are the subject of licensee E ,
exemption requests with NRC Licensing and are expected to
be deleted from the tour after resolution. Other non-TS
fire watches were stationed to meet hot work
requirements.
Training for fire watches was found to be a function of
the type of fire watch, i.e., a TS fire watch receives two
days of classroom training whereas a non-TS fire watch,
for such activities as hot work, gets no training but is
required to read administrative procedures A-12 and
A-12.1. A non-TS fire watch is generally a craft worker
assigned to the Maintenance and Construction Department.
10.2.2 Appendix R Status
Fire protection management personnel were questioned
regarding the completion status of 10 CFR 50 Appendix R
modifications. They stated that all work in both units is
expected to be complete by the end of the 1987 refueling
- outage which includes the physical work, development and
implementation of procedures, and training. It was
!
l
I
~
.
59
explained that there are still several exemption requests
undergoing review by NRC Licensing, which, if ruled upon
unfavorably, could affect the end date for completion of
Appendix R activities.
The frequency and type of training and drills for the fire
brigade were reviewed and found to be in compliance with
Appendix R and TS requirements.
10.2.3 Administrative Procedure Review
The following fire protection related Administrative
procedures were reviewed and compared to TS requirements to
ensure their adequacy:
--
A-12, Ignition Source Control Procedure, Rev. 4.
--
A-12.1, Procedure for Controlling Technical
Specification Firewatch and Firewatch Patrols,
Rev.6.
--
A-12.2, Control of Combustibles, Rev. 3.
--
A-12.3, System Impairments, Rev. O.
Although the administrative procedures are not intended to
duplicate the TSs, they are designed to control in-house
activities required to implement TS requirements. Review .
of the A-12.1 procedure noted that the requirements for 'l
posting a fire watch as a function of fire barrier pene- (
tration functionality were not complete.
'
In particular
paragraph 3.14.D.2 was not included in the A.12.1 proce-
dure. The NRC inspector pointed this out to the licensee
who agreed it should be included in the A-12.2 procedure,
and the most likely reason it was not, was due to failure
to update A-12.1 after a TS amendment that added the
requirement. The licensee stated, that in actual practice,
the requirement is implemented. At the end of the inspec-
tion, the licensee had initiated a complete revision of
A-12.1 to update this procedure. The inspectors will
follow up to ensure incorporation of TS paragraph
3.14.D.2 into A-12.1.
On June 26, 1986, at 4:15 a.m., while touring the Unit 2
Reactor Building 135 foot elevation, the inspector noted a
truck parked inside the building. The inspector informed
the Shift Superintendent who investigated and took action
to station a fire watch and guard at the truck. The
inspector questioned the licensee on the hazards involved
with the truck in the Reactor Building. The licensee
reviewed the hazards and determined that Procedure A-12.2,
.
~
.
60
" Control of Combustibles", would be revised to require a
fire watch whenever a vehicle is in the power block. The
inspector will follow the licensee's actions (277/86-12-20;
278/86-13-20).
10.2.4 Carbon Dioxide Fire Protection Systems
An inspection was performed of the Emergency Diesel
Generator (EDG) Cardox System. This inspection noted thit
all the equipment associated with the EDG Cardox System
including the tank, gauges, valves, piping, ejection
nozzles, pipe supports, electrical equipment, and
protective steel for Cardox piping passing through one EDG
bay into another was correctly installed and in working
order. The volume of CO2 in the storage tank exceeded TS
requirements and a review of the Operations Tour Sheets
and procedure S.13 indicated that there is adequate
control to assure the volume of C02 in the tank will not
drop,below TS limits. A similar inspection, although not
as thorough, was conducted on the Cardox systems that
service the HPCI rooms and the control, cable spreadi g,
and computer rooms. These Cardox systems are located on
elevation 116' of the turbine buildings. Again, all
hardware inspected was found to be in working order and
the weight of CO2 in the tanks exceeded TS requirements.
The Operations Tour Sheet and procedure S.13 review,
however, disclosed what appears to be a TS interpretation
problem. In particular, it is not clear as to the TS
requirements for the minimum weight of CO2 required. The i
TS states 11,000 pounds of CO2 is required for the cable h
spreading, computer, and control rooms and 2400 pounds is
required for each HPCI room in order for the Cardox
systems to be operable. This requirement is interpreted
by the licensee to mean that the minimum weight of CO2
required by TS is 11,000 pounds. Their logic is based on
the probability that there will never be simultaneous
fires in the HPCI room and in either the cable spreading,
computer, or control rooms. PECO's interpretation of the
TS has resulted in the Operations Tour Sheets and the S.13
procedure controlling the minimum weight of CO2 to a value
of approximately 13,200 pounds. The NRC inspector
questioned the licensee's interpretation of the TS and
contacted NRC Licensing for assistance. An interpretation
was not available prior to the end of this inspection.
The weight of CO2 required to be in the Cardox system to
support operability will ne reviewed following an
!
'
interpretation of the TSs by NRC Licensing. This will be
reviewed in a future inspection (277/86-12-21;
278/86-13-21).
.
'
.
61
10.2.5 QA Audits
Annual QA audits of fire protection for 1984 and 1985 (the
1986 audit had not been performed) and a routine 1986 QA
surveillance of fire barrier penetration inspections were
reviewed. The particular documentation reviewed included:
--
Audit No. AP 85-99 PL, Fire Protection Plan and
Procedures, dated 12/4/85.
--
Audit No. AP 84-80PL, Fire Protection Plan and
Procedures, dated 12/13/84.
--
Surveillance Check Report SP 86-06 ST, Surveillance
of Fire Barrier / Penetration Seal Inspection, dated
3/27/86.
The audits were found to be sufficiently broad in scope,
and when compared to deternine how similar they were, were
found to exhibit enough C fferences to conclude that they
were capable of resultir.a in adequate audits of fire
protection. As evidenceo by several meaningful findings,
it was apparent the auditors made effective use of their
audit plans. One of the 19C'. audit findings identified a
failure of both Electric ProJuction and Engineering and
Research to meet a managemer.t commitment to the NRC to
receipt inspect fire protection items. Electric
Production (EP) responded by correcting the problem but $
Engineering and Research (E&R) as of the 1985 audit, still %
had not corrected.the problem. A review of the (
correspondence associated with this issue indicates E&R
has been extremely slow in making and implementing
necessary procedural changes. Part of the reason for this
may be that EP management made the commitment to the NRC
for both EP and E&R without prior discussion and
agreement. There are, indications that a closer working
relationship between the two entirely separate on-site QA
groups should be fostered by EP and E&R management.
The inspector noted that several significant concerns were
identified by the auditors that were not discrepancies
which could be classified as findings. These are included
in the " Recommendations" section of the audit report. The
NRC inspector learned that these issues are not tracked
nor are they required to be responded to. This appears to
be a weakness that detracts from the overall effectiveness
of the quality program at Peach Bottom. In discussions
with QA personnel, it became apparent that recommendations
are not made lightly and generally represent potentially
significant issues that should be addressed in a timely
manner and in writing by the responsible party.
.
62
The QA surveillance of the fire barrier / penetration seal
inspection disclosed an issue involving potential TS
noncompliance. In particular, present TSs require that
100% of all penetration seals be inspected once every 18
months. However, the licensee submitted a request to NRC
Licensing approximately ten months ago to change the TSs
to be consistent with Standard TSs that require a 10%
inspection of each type of penetration seal once every 18
months. At present, the TS change has not been granted,
the licensee is close to the end of the 18 month surveil-
lance period plus a 25% grace period, and they have
inspected to the requirements of the proposed TS change.
The NRC inspector followed up this issue and determined
that NRC Licensing has made a commitment to PECo to approve
the proposed TS change prior to the time when the
licensee would be in violation of their current require-
ments. The inspector had no further questions on this
issue.
10.3 l mmary
In summary, housekeeping has changed from a weakness to a
strength at Peach Bottom. The few exceptions noted indicate
that PECo management must remain committed to the present
level of effort to prevent gradual deterioration. Additionally, ,
it appears that management needs to reinforce to all involved
in performing work at the plant site, that Operations concerns
for sloppy housekeeping must be addressed by positive action, +
, not debate over whether or not a housekeeping problem exists.
In summary, the fire protection program at Peach Bottom
meets TS requirements. PECo's implementation of Appendix R
requirements is well underway and is scheduled to be
l complete prior to the end of the 1987 refueling outage.
- Procedures reviewed noted a potential administrative
problem involving failure to incorporate a portion of a
- TS amendment into the appropriate procedure. This may be
l
an isolated case, however, the licensee shculd review their
I processes to incorporate new requirements into existing
procedures to determine and correct the weakness that
l
.
resulted in this one example. The example of the truck in
the Reactor Building being a previously unaddressed hazard
indicates the licensee needs to increase their overall
l
awareness of hazards not addressed by procedure. EP
Quality Assurance appears to have a well defined audit and
surveillance program. However, it appears QA could be more
effective if their program required a written response to
l their audit recommendations. The fact that E&R did not
l respond in a timely fashion to implement action to receipt
._. -. .
'O
.
- -
63
inspect fire protection equipment indicates the licensee
needs to resolve an apparent lack of spirit of cooperation
between EP and E&R.
11.0 Security
11.1 Shift' Inspector Observations
The NRC inspector toured the protected area fence with a member of
the security force. The tour was made at dusk and continued into
darkness so that an assessment of the lighting could be made. The
following observations were made during the tour:
--
The lamps that light the area on either side of the protected
area fence were observed to occasionally turn off. This
reportedly occurs when a sensing device determines the
temperature in the light to be too hot. Along one portion of
the protected area fence, at least one light was out and
another was erratic because of this temperature control.
Although this particular area of the fence was not totally
dark, it was heavy with shadows and it was questionable as to
whether or not there was enough light for adequate performance
of the TV monitors.
--
The exclusion area on either side of the protected area fence
was, without exception, clear.
--
The security activities'at Peach Bottom are subcontracted to ;
Burns Security. There is a fairly high turnover rate in the
security force as demonstrated by an individual with 8-1/2
months of experience being about in the middle of the seniority
,
list.
--
Although the turnover rate may be higher than what might be
considered normal, the department training appears to be good.
This may be attributable, in part, to the licensee's program
wherein a progression is established such that an individual
initially starts out as a fire watch, then progresses to a
watchperson, and then progresses to an armed guard. Although
l this progression is not always followed, it results in those
l who do follow it, being more knowledgeable about the Peach
'
Bottom site.
--
There is no evidence of on going problems with PECo or
contractor personnel coming to work under the influence of
drugs or alcohol. The inspector noted that based on the
- physical arrangement in the security building, however, it is ,
not likely that a guard would be able to detect alcohol on an
individual's breath. This arrangement does not preclude the
detection of aberrant behavior.
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--
Security equipment is generally considered adequate and the
arsenal has been recently upgraded in response to nationwide
concerns for terrorism. Historicaliy, there have been problems
with the security computer system which reportedly will be
addressed by the overall security system upgrade plans.
--
There is a drug and alcohol screening program for all members
of the security force. It involves an announced test as part
of initial employment screening and a once per year test at the
time of the annual pnysical. In addition, an unannounced test
of each security shift is performed annually.
Subsequent to this tour, the inspector made routine observations of
'
security activities and concluded that most routine activities are
performed as required. One exception to this was noted to be poor '
practices of the Secondary Alarm System (SAS) operator. On one
occasion, the SAS operator was observed to be distracted in conver-
sation with the shift clerk, on other occasions more than one guard
was in the SAS and all were involved in conversations and not paying
attention to the TV monitor screens. Presently, the SAS is not a
separate enclosed isolated room, it is an open area just inside the
Unit 3 entrance to the Control Room. By virtue of its location and
openness, it is not surprising the SAS operator is occasionally s
distracted. In discussions with the licensee about this problem, the
licensee stated that plans are being implemented to relocate the
SAS and make it a separate enclosed isolated space which will help to
resolve this problem.
11.2 Security Specialist Observations
The licensee's security program had been rated as Category 3 for the
last two SALP periods. The problems identified during those periods
appear to share the same general root cause: Inadequate licensee
management attention to, and control of, the security contractor.
During the latter portion of the most recent assessment period, some
improvement in the overall performance of the licensee's security
management staff and that of the security force contractor was
demonstrated. Licensee actions include the hiring of a Nuclear
Security Specialist to assist the Administrative Engineer and Plant
Manager in responding to the needs of the security program, and the
security force contractor had proposed an enhanced training program
for its personnel designed to respond better to the needs of the
licensee.
During this inspection, the licensee identified, and the inspector
verified, the following actions that have been implemented to
upgrade and strengthen the security program:
--
All security force members have been trained in the enhanced
training program.
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The alarm station operator positions have been upgraded to
supervising positions and all contract security supervisors
have received specific supervisory training.
--
The licensee now conducts weekly meetings with outside and
district contract security management to review problems and
program status. The inspector attended such a meeting on June
, 26, 1986, and noted that while the added communication between
the licensee and security contractor was beneficial, the
effectiveness of the meetings could be increased with the
attendance of a member of licensee's management to provide for
direct feedback and who would be in a position to ensure more
prompt action in making decisions and resolving problems.
In addition to the above, prior to the end of 1986, the licensee
plans to add a Nuclear Security Specialist to its on-site security
organization, and a corporate security representative will be
assigned to oversee site activities and report directly to corporate
security. The Nuclear Security Specialist will be used to previde
additional licensee oversight of the security contractor and che
corporate security representative will provide an on going ( dit of
the site security program.
11.3 Summary
In summary, although licensee actions to address previous problems *
have been initiated at the time of the inspection, the licensee had
not developed a firm written program to assign responsibilities, g
establish and implement goals and objectives which provide direction ~ ,
and accountability, and measure progress in upgrading the security h
'
program. This is considered an additional example of incomplete and
inappropriate application of licensee corrective action programs.
12.0 Event Analysis
12.1 Unit 2 Loss of Emergency Service Water (ESW)
12.1.1 Sequence of Events and Licensee Actions
With Unit 2 operating at 100%, at approximately 7:20 a.m.,
on June 18, 1986, the RHR room 2A flood alarm occurred.
Plant operators were dispatched to check the 2A RHR room,
and at 7:40 a.m., the APO reported that the 3 inch ESW
line to 2A RHR room cooler 2AE58 was leaking, and that 10
inches of water were in the room. The leak was stopped at
8:07 a.m., by closing ESW valves 502, 503 and 506. This
action resulted in isolating all ESW to ECCS room coolers
including:
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Four RHR room coolers (two per room),
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Four core spray room coolers (two per room),
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HPCI room coolers (two per room),
--
RCIC room coolers (two per room),
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Four core spray pump motor coolers, and
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Four RHR pump seal coolers.
The licensee stationed an operator to open the ESW
isolation valves if the room coolers were needed. The
room coolers are designed to provide adequate ventilation
cooling during safety related equipment operation.
The licensee immediately initiated a plant shutdown due to
loss of all ESW to ECCS components. At 8:22 a.m., the
licensee declared an Unc.ual Event based on a threat to
the normal level of plaa', safety, and the Emergency Plan
was implemented. At 10:00 a.m., a maintenance pipe fitter
placed a temporary patch on the ESW line and ESW was
restored to service. i.t 10-05 a.m., with Unit 2 at 32%
power, a manual scran was iaitiated per procedures to
complete the shut down. At 10:10 a.m., the ESW was
verified not to be leaking and the Unusual Event was
terminated.
The subsequent repair of the ESW leak and related NRC I .'
activities is discussed in section 5.2 of this report.
Unit 2 was restarted on June 23, 1986.
12.1.2 NRC Review of Event
12.1.2.1 Control Room Activities
At the time of the 2A RHR room flood alarm, the
resident inspectors were in the control room
and observed the control room licensed operators
followup of the alarms and alarm card #C203A-25.
The inspector noted that the flood alarm
setpoint is six inches.
The Auxiliary Plant Operator verbal reports to
the control room was monitored as well as shift
supervision determination of leak isolation.
The inspector reviewed P&ID M-315, ESW and HPSW,
Rev. 19. The control room operators determined
that the leak was not isolable locally in the 2A
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RHR room, and that in order to stop the leak,
-header isolation valves (502, 503, 506) in the
RBCCW room had to be closed. _The inspector
noted that the licensee made a prudent decision
to station an operator at the isolation valves
in the event safety system room coolers were
needed.
At about 8:15 a.m., plant management arrived in
the control room. The inspector monitored the
licensee decision to declare an Unusual Event as
required by EP-101, Classification of
Emergencies, Rev. 15 and EP-102, Unusual Event
Response, Rev. 12. The Unusual Event was
declared because isolation of all ESW to the '
Unit 2 ECCS room coolers was a threat to the
normal level of plant safety. The inspector
monitored the NRC ENS phone call as well as
other notifications that were made.
The inspector monitored the plant shut down per
GP-3, Normal Plant Shutdown, Rev. 33. The
inspector reviewed TS 3.5.H which requires that
when both pump room coolers are inoperable, the
associate ECCS pump must also be considered
inoperable. Thus, the licensee was required to ,
declare all ECCS pumps inoperable due to loss of
ESW supply to the room coolers. The ECCS pumps =
could have been utilized however, and as
previously noted an operator was stationed to fd 1
open the ESW isolation valves, the room cooler
supply, if needed.
The inspector reviewed the licensee'.s Upset
Report regarding this event dated June 27, 1986.
The Upset Report was determined to be factual
and complete. The inspector noted that Unit 3
had implemented a plant modification (MOD 1557)
i which added manual isolation valves on each pair
'
of room coolers during the 1985-86 refueling !
outage. M00-1557 is scheduled for completion in
Unit 2 during the 1987 refueling outage.
i
The inspector concluded that the control room
, response to the leak was tim.Ly and appropriate.
j
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Adequate implementation of one emergency plan
procedures and plant shutdown procedures was
j noted. The time from the annunciator alarm to
starting the plant shut down was 47 minutes, and
l the time to a hot shut down condition was I hour
,
and 58 minutes.
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The inspector noted two problems during
subsequent followup to the event:
--
There currently exists no emergency or
other type procedure for loss of ESW. This
issue is further discussed in section 8.4
of this report.
--
The licensee inspects the 2A RHR room daily
as required by ST 7.8.5, Unmanned Vital
Area Visual Inspection, Rev. 1. This
inspection is primarily for security plan
purposes and a leak may not have been
detected. The licensee also noted this
deficient condition, and has implemented a
once per shift inspection of each ECCS room
by the non-licensed operators.
12.2 Group IIA Primary Containment Isolation of Reactor Water Cleanup
System (Unit 3)
The inspector observed operator response to an isolation of the Unit
3 Reactor Water Cleanup System (RWCU). The isolation occurred at
1:30 p.m., June 24, 1986, when the plant was at full power.
Preparations were being made for a startup of Unit 2 and most of the
attention of shift supervision was being directed to those details.
The Unit 3 Control Operator announced the event and was immediately +
assisted by the Shift Superintendent, Shift Supervisor, the " Chief" ho
Control Operator, and the Shift Technical Advisor. The event was
caused by a loss of power to instrument loops monitoring
demineralizer influent temperature and pump vibration. Although the
control circuit properly tripped the running pumps and isolated the
system, there was no indication or annunciation of an out of
specification parameter causing the isolation, in accordance with
plant design. The operators received appropriate assistance from
the Outside Shift Supervisor who quickly identified the power supply
circuit and personally investigated its status within the plant.
After determining the cause and reporting to the Shift Superintendent
power was restored and the RWCU system returned to service. During
this event the operators demonstrated excellent communications in
that all control room personnel were kept appraised of plant status
and actions being undertaken. Operating and off-normal procedures
were in use throughout this event. Appropriate notification was made
to the NRC in accordance with 10 CFR 50.72.
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13. Management Meeting and Exit Interview
A verbal summary of preliminary findings were provided to the Senior Vice
President-Nuclear Power and other licensee representatives (listed in
Attachment 1) including the Manager, Peach Bottom Station at the conclu-
sion of the inspection on July 3,1986. During the inspection, licensee
management was periodically notified verbally of the preliminary findings
by the NRC Inspection Team Manager and leader. A management overview of
the inspection findings was also presented to the Vice President-
Electric Production at NRC Region I offices on July 22, 1986. No written
inspection material was provided to the licensee during the inspection.
No proprietary information is included in this report.
Attachment I lists licensee supervisors and managers who were contacted
or interviewed during the course of the inspection. Attachment 2 lists
12 outstanding items to be responded to by the licensee, and 11 items
which will be followed-up on by future NRC inspections.
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ATTACHMENT 1
INSPECTION REPORT 50-277/86-12/86-13
PERSONS CONTACTED
The following is a listing of licensee personnel supervision were contacted
during the inspection. Other licensee employees, contractors and vendor
representatives were contacted during the course of the inspection.
V. S. Boyer, Senior Vice President, Philadelphia Electric Company (PECo)
S. L. Daltroff, Vice President, Electric Production
M. J. Cooney, Manager, Nuclear Production
G. M. Leitch, Superintendent, Nuclear Generation Division
W. T. Ullrich, Superintendent, Limerick 2 Project
R. H. Moore, Superintendent, Quality Assurance Division
M. J. McCormick, Jr., Superintendent, Maintenance Division
R. S. Fleischmann, II, Manager, Peach Bottom
G. A. Hunger, Jr. , Engineer In Charge, Nuclear Safety Section
W. J. Knapp, Jr., Director, Radiation Protection Section
W. F. Casey, Superintendent Station Section, Maintenance Division
J. E. Winzenried, Staff Engineer, PBAPS
J. B. Cotton, Superintendent, Plant Services, PBAPS
D. C. Smith, Superintendent, Operations, PBAPS
A. E. Hilsmeier, Senior Health Physicist, PBAPS
J. F. Mitman, Engineer, Maintenance, PBAPS
A. A. Fulvio, Engineer, Technical, PBAPS
S. R. Roberts, Engineer, Operations *
F. W. Polaski, Engineer, Outage Planning
S. A. Spitko, Engineer, Administration f('
O. L. Oltmans, Senior Chemist
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ATTACHMENT 2
INSPECTION REPORT 50-277/86-12 AND 50-278/86-13
'
LICENSEE RESPONSE ITEMS AND INSPECTOR FOLLOW ITEMS
I. Licensee Response Items
The licensee is requested to respond to each item, describing tne planned
action and the estimated completion date.
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)
2. Improve control room logs and records such that they reflect the
professional manner in which personnel actually perform their duties.
(277/86-12-02; 278/86-13-02)
3. Address the potential for presently assigned S. ft Superintendent
administrative duties detracting from plant operation oversight
responsibilties. (277/86-12-03; 278/86-13-03)
4. Address the concern that not all information tags nay 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)
5. Address and correct paging system deficiencies and abuse.
(277/86-12-05; 278/86-13-05) t ,
6. Conduct failure analysis of MO-2-02-074 and compare results with the
valve's environmental qualification analysis. (277/86-12-07)
l 7. Address the status of the review of health physics group
'
organization and staffing, and plans to address findings.
(277/86-12-09;278/86-12-09)
8. Improve training program for health physics technicians.
l (277/86-12-10; 278/86-13-10)
l
9. Address the need to formally establish the corporate radiological
controls assessment program (277/86-12-11; 278/86-13-11)
! 10. Address concern that needless exposure results from conducting radia-
tion surveys to support Radiation Work Permits which are not used or
l are not used with a period of several days such that additional surveys
are required. (277/86-12-12; 278/86-13-12)
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11. Address concern that oversicht and control of work and activities by
the Health Physics Technical Group is inadequate. (277/86-12-13;
278/86-13-13)
12. Address the practice of using infornial health physics " guidelines"
and not incorporating them into appropriate controlled station
procedures. (277/86-12-14; 278/86-12-14)
13. Address the need for procedures for ALARA goal setting and
tracking. (277/86-12-16; 278/86-13-16)
14. Establish tracking system for the resolution of QA audit recommenda-
tions. (277/86-12-17; 278/86-13-17)
15. Formalize QA control room review activities. (277/86-12-18;
278/86-13-18)
16. Define the scope of RTs and administrative 1y control their
preparation and issuance; and address the missing emergency
procedures to meet regulatory requirements. (277/86-12-19;
278/86-13-19)
II. Inspector Follow Items
These items will be reviewed during subsequent NRC inspections.
1. Review revision to Procedure M65.4 with respect to using gauge valves
on the snubber testing machine. (277/86-12-06; 278/86-13-06) +
Review adequacy of licensee actions to enhance communications between
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2.
health physics supervisory / management personnel and the technician
staff. (277/86-12-15; 278/86-13-15)
3. Review revision to Procedure A-12.1 to ensure incorporation of the
requirements of TS 3.14.D.2. Review revision to Procedure A-12.2 to
ensure that a fire watch is required whenever a vehicle is in the
power block. (277/86-12-20; 278/86-13-20)
4. Review adequacy of CO2 weight required in the Cardox system to assure
operability. (277/86-12-21; 278/86-13-21)