ML20236C643

Forwards Memo Prepared for Secretary of Natural Resources Re Observation of Util Operation of Plant During Integrated Assessment Team Insp

ML20236C643
Person / Time
Site:	Peach Bottom
Issue date:	03/07/1989
From:	Magette T MARYLAND, STATE OF
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8903220250
Download: ML20236C643 (8)

Text

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Maryland Department of Natural Resources Tidewater Administration Tawes State Office Building 580 Taylor Avenue Annapolis, Maryland 21401 William Donald Schaefer Torrey C. Brown, M.D.

Governor Secretary March 7, 1989 William F. Kane, Director Division of Reactor Projects United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

Dear Bill:

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On behalf of the State of Maryland I would like to thank you l

for the opportunity to participate in the Integrated Assessment Team Inspection of the Peach Bottom Atomic Power Station.

The information I gathered and the insights I gained will be very important in determining the State's position concerning restart.

I was pleased to have the opportunity to work with your inspection team.

1 I have enclosed a copy of a memorandum I prepared for the l

Secretary of Natural Resources concerning the inspection.

This memorandum addresses my observations concerning strengths and weaknesses of PECO's operacion of Peach Bottom as observed during l

the IATI.

As we have discussed, my principal outstanding concern l

is with the modifications which have been installed during the current outage and the ability of PECO's quality control inspections to assure that these modifications were properly installed.

My concerns are described in more detail in the memorandum.

I look forward to continuing to work with the NRC and PECO in ensuring that the remaining outstanding issues are adequately addressed.

Sincerely, W

/

Thomas E.

Ma -

e, Manager Nuclear Prog ams 1

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cc: James C. Linville, NRC Corbin A. McNeill. PECO, 8903220250 890307 i

PDR ADOCK 05000.277 gb o

PDC 1

Tdephone:

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DNR TTY for Deaf: 301-974-3683 1

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TOR R EY C. B R OW N, M.D.

JOHN R. GRf FFIN ST ATE OF M ARYLAND DEP ARTMENT OF N ATURAL RESOURCES TIDEWATER ADMINISTRATION TAWES STATE OFFICE SUILDING A NN APOLIS 21401 MEMORANDUM' March 6, 1989 l

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.l TO: Torrey C. Brown, M.D.

l Thomas E. Magette. (Qv["

FROM f

SUBJ: NRC Team Inspection of Peach Bottom l

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From February 5 through February 17, 1989 the.NRC conducted an Integrated Assessment Team Inspection (IATI) of the Peach.

-l Bottom Atomic - Power Station.- _

~I ' participated' in this. inspection J

on behalf of the State.

The-purpose of this memorandum is to 1

briefly describe.my impressions of the inspection.

Since being shut down by the NRC in' March 1987 the Philadelphia Electric' Company (PECO) has made many changes'in the operation and, management of both the company and Peach Bottom.

During the shutdown the NRC'has conducted-several inspections to evaluate the status and adequacy of 'PECO's corrective actions.

The purpose of the IATI was to review the' adequacy of changes not previously inspected or which require follow-up1 inspection,;

determine if improvements are effective and appear long lasting, and determine if PECO is prepared to support restart and safe-operation of Peach Bottom.

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I had two objectives during the IATI.

The first w

same as the NRC's, i.e.,

to evaluate the effectiveness of the corrective actions taken by PECO.

This - was done both. by participating directly in the inspection activities ~of the NRC and by my own independent ' inspection acitvities.

My !second -

objective was to evaluate how the NRC conducted its inspection and how it reached conclusions.,

Because we could never-duplicate the inspection resources of the NRC,'either in. terms ~of l

expertise or manpower, we are obviously interested in the results

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of their inspection.

Furthermore, because they are the.

regulatory. agency which will ultimtely determine if and when restart is permitted ~,

we are - equally. dependent-on.their conclusions.

It is therefore important for.us to understand how they reached their conclusions so that we can.have confidence in their results.

j TTY FOM DEAF - S ALTIMORE 269*2409. WASHINGTON METRO S45 0450 q

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.4 The inspection.was conducted by ;15 NRC experts from. their Region'I and headquarters. of fices.

The i team '. reviewed the.

~following areas:

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Station and Corporate. Culture q

Operator Resource Development'

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Operations Site Management ~

Corporate Oversight.and Quality. Assurance Engineering Surveillance and Maintenance Health Physics-Security

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The results of.' the ' inspection will' be described in an NRC Inspection Report which will be published on March 7, 1989.

InL 1

general, the, inspection team concluded - that' PECO's corrective J

actions-are in - place' and being ~ effectively implemented and that 1

PECO has demonstrated that it is ready and able,to operate Peach-Bottom safely.

PECO's performance-as compared to'.its last l

Systematic Assessment of Licensee Performance (SALP) was determined to be ' improving.

The NRC. also identified several l

items which will require correction prior to' approval'for j

restart.

4 I am satisfied that the inspection was adequate.to,the task-of evaluating the effectiveness of PECO's corrective actions.

It was my observation ~that-the NRC inspection: team was highly competent, well focused on the areas 'to be inspected, and agressive in evaluating PECO performance.

While there are' limits i

on how ~much can be evaluated in any inspection ~, the IATI ' was ~

sufficient to judge PECO's readiness for operation in - ' the categories listed above, j

I am also in agreement with the conclusions reached' byf the inspection team.

PECO has significantly improved the ~ operation of Peach Bottom.

In addition to improving, PECO's performance as l

measured against an absolute standard for ' safe operation. of the-plant is also acceptable.

PECO has agreesively worked-to upgrade performance, programs and hardware for the past year, and the I

results are apparent.

There is, noneth'eless, still room for h.

significant improvement.

As noted above, there are also problems which must be addressed prior to restart.

Among the most. notable improvements I observed at Peach Bottom were improved operator attitudes,

' reduction' of contaminated areas within the plant, improved communication between departments, and the addition of the Shift' Manager position as the senior manager'on shift in the control room.'

The most important change 'within the company is. the change in-corporate ' management which has occurred since the shutdown.

I have listed these and other strengths ~ I. observed in an attachment.. 'This list agrees ' very well with the NRC's list of strengths.

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As noted above, some weaknesses significant enough to require correction prior to restart were also identified.

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were olso some problems identified which will require long term solutions.

Some of these, e.g.,

establishment of off-shift i

career alternatives for licensed operators, will not be l

corrected prior to restart.

Those weaknesses I consider to be i

most significant, both restart and long term, are listed in an i

attachment.

My most serious concerns at present are with plant j

modifications and associated quality control.

I have two i

concerns relative to modifications:

the first is with those i

modifications made to the plant during the present outage. The

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second is with PECO's modification process.

l Several improperly installed modifications were discovered

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during a Quality Assurance audit conducted by PECO.

Review of these modifications indicated problems at virtually every step of the process - design, construction, inspection and testing.

Some of the improperly installed modifications identifed by PECO have l

been corrected and were inspected during the IATI.

Others will be corrected prior to restart.

Correcting the specific problems I

identified by the audit, however, may not completely address the I

problem (the Quality Assurance audit was based on a relatively I

small sample of recently installed modifications).

I believe l

these problems are indicative of a generic problem with the

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modification process.

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PECO has conducted an analysis of the root cause of this l

problem.

Hopefully, this analysis will also address the scope of the problem.

The root cause analysis was in draft form at the l

conclusion of the IATI, and thus was not reviewed either by myself or the NRC.

I believe this report should be finalized, l

reviewed by the NRC and the state, and any necessary corrective i

actions implemented prior to restart.

These steps are necessary to ensure that all problems with recently installed modifications are identified and corrected.

In at least one case involving improperly installed instrument air

tubing, there is no evidence that post-construction quality control inspections were ever conducted.

PECO has committed to reinspect all similar tubing which was modified during the outage.

This is certainly a positive move on their part, but may not be adequate to ensure that all improperly installed modifications are identified and corrected.

I will pursue this issue with both PECO and the NRC.

The second problem concerning modifications involves the process under which the problems occurred.

PECO has taken several steps to correct these problems on a programmatic basis.

Among these are the creation of the " MOD team."

The MOD team is composed of representatives of all departments involved in a modification to ensure that potential problems are identified at the design stage.

This proactive move to prevent problems before they occur is a very positive step.

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i PECO is also taking other steps to improve this process, i

including supplemental training for quality control inspectors I

and improved criteria for modification acceptance tests.

These arm also positive steps.

There is already evidence that PECO's 1

improvements are starting to pay off, particularly the use of the MOD teams.

However, I do not believe the evidence is sufficient to conclude that PECO has demonstrated the effectiveness of this process.

Demonstrating the effectiveness of these changes should not be an impediment to restart because the effectiveness of these changes can be better judged the next time PECO goes into an j

outage and has several modifications to install.

Thus, this is another area where long term confirmation of effectiveness is necessary.

I will also continue to pursue this with the NRC.

One other area where PECO still needs to show significant improvement is in the general area of its Quality Assurance program.

The present Quality Assurance structure was established during PECO's major nuclear reorganization and' is still characterized by some growing pains.

It is not yet clear to me that the new program is completely effective.

The NRC has also identified this area as needing additional attention.

Success in this area will be crucial to PECO's overall recovery at Peach Bottom.

I will continue to monitor both PECO's improvement in this area, as well as the NRC's evaluation of that improvement.

In conclusion, I believe that PECO has now demonstrated that j

they are capable of and ready to operate the Peach Bottom Atomic Power Station in a manner that does not pose an unacceptable threat to the citizens and environment of Maryland.

While there remain a few issues that must be addressed prior to restart, no significant impediments to restart remain.

I further believe that the recent IATI provided a solid foundation for reaching this conclusion.

With the conclusion of this inspection, the following steps must be addressed prior to restart:

PECO must address the outstanding issues Corrective actions must be reinspected as necessary Advisory Committee on Reactor Safeguards must conduct its review The NRC Staff must make a final recommendation on restart The NRC must vote on restart

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cc:-James W.

Peck Paul Massicot James M.

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STRENGTHS'

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• INCREASED PROFESSIONALISM IN ALL DEPARTMEliTS

• IMPROVED OPERATOR ATTITUDES

• IMPROVED MANAGEMENT 1

INCREASED MANAGEMENT ONSITE 1

• PLANT HOUSEKEEPING / REDUCTION OF CONTAMINATED AREAS-

• COMMUNICATION BETWEEN DEPARTMENTS

• CONTROL ROOM STAFFING / OPERATOR WORKLOAD

• SHIFT MANAGERS ******

• ELIMINATION OF PREVENTIVE MAINTENANCE BACKLOG FOR UNIT 2 I

• MAINTENANCE TRACKING SYSTEM

• MANAGEMENT ACCESSABILITY-

• USE OF " MOD TEAM" FOR PLANNING MODIFICATIONS

• ALARA - PLANNING AND CORPORATE SUPPORT FOR

• IMPROVED WORKING RELATIONSHIP BETWEEN HP AND OTHER DEPARTMENTS

• IMPROVEMENTS IN SECURITY

• REDUCTION OF RADWASTE VOLUME

• PROCEDURE FOR SELECTION OF FUTURE SUPERVISORS l

• TRAINING COURSE: " SUPERVISION OF WORK PRACTICES" l

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A WEAKNESSES

'l QUA'ITY CONTROL INSPECTIONS / INSPECTORS / PROCEDURES' L

PROBLEMS WITH MODIFICATIONS' INSTALLED

. MATURITY OF NUCLEAR QUALITY' ASSURANCE ORGANIZATION 1

• LACK'OF CLEARLY DEFINED ACCEPTANCE CRITERIA FOR MATS 1

OPERATOR' MISTRUST OF MANAGEMENT j

• REMNANTS OF "OLD PECO" ESTABLISHMENT.0F.OFF-SHIFT CAREER ALTERNATIVES FOR OPERATORS

• INCONSISTENT TECHNICAL PROFICIENCY AMONG HP TECHS

• LACK OF OPERATING PLANT. EXPERIENCE FOR SOME'HP.TECHS*

• UNRESOLVED ISSUES FROM NRC ELECTRICAL INSPECTION l

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