ML20236M761
| ML20236M761 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/09/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8711130274 | |
| Download: ML20236M761 (10) | |
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.g PHILADELPHIA ELECTRIC COMPANY p'
2301 MARKET STREET P.O. BOX 8699 -
'l PHILADELPHIA A PA.19101 -
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JOSEPH W. G ALLAGHER l
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November 9, 1987 j
Docket Nos.
50-277 i
H 50-278 i.
Mr. William _T.
Russell,/ Administrator
. Region I.
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station-Systematic Assessment of Licensee Performance (SALP) for the. period February 1, 1986 through May 31, 1987
Reference:
.;SALP Report Nos. 50-277/86-99; 50-278/86-99 l
Dear Mr. Russell:
1 This letter is submitted in-accordance with.your i
request to provide written comments within 30 days after a-J meeting between the NRC Region I SALP Board and Philadelphia
' Electric. Company management to discuss the subject SALP report.
Philadelphia Electric Company appreciated the opportunity'to meet with'the NRC on October 1, 1987.
This letter restates some key comments provided by Philadelphia Electric Company at the meeting and provides additional information.
Mr. James Linville of the NRC was notified on November 3, 1987 that additional time was needed to complete our written comments.
At the meeting, discussion was directed chiefly to issues other than those directly associated with the causes of the Shutdown Order dated March 31, 1987 because those issues have been discussed at length in other forums.
This approach E
permitted discussion of other important issues identified in the SALP Report.
This letter reflects an approach consistent with that of the meeting.
Based on the discussions at the meeting we offer the following comments:
h 8711130274 871109 PDR ADOCK 05000277
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. William T.
Ru,sDall November 9, 1987 Page 2 l
Plant Operations:
Changes in the onsite organizational structure and staffing, and an upgrade of personnel performance standards are completed or planned to improve the performance of the operating shift.
These include:
o establish commitment to excellence performance standards for operators; o
conduct an individual operator attitudinal assessment
-and-counseling-program to screen operators for return I
to restart; establish the Shift Manager position with degreed o
engineers holding a senior operator license; provide temporary and permanent off-shift positions o
for licensed operators and establish a more aggressive operator training and recruiting program; establish an operations technical support group to o
reduce the administrative burdens on operators; improve attitudes towards procedural compliance o
through administrative training and performance
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evaluations; J
increase Quality Control monitoring of operations.
o With regard to the human factors problems in the station blackout and containment venting emergency procedures, procedure revisions are in progress.
Revisions of the i
station blackout and containment venting procedures are scheduled.for completion by January 31, 1988 and November 30, 1987, respectively.
At the SALP meeting, the NRC requested that PECo review Table 6 of the SALP Report, " Listing of LERs by Functional Area and Cause Codes", and comment on the cause codes assigned to the LERs.
We agree with your assignment of cause codes for all of the LERs except three (2-86-24, 2 1 and 3-86-17).
Our rationale for different causes is provided below for your consideration.
LER 2-86-24: The cause of this event is identified in Table 6 as a component failure.
We consider the root cause of this event to be a personnel error because a test engineer used an electrical test meter in an improper manner, thereby 1
introducing a short circuit into the system which resulted i
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William T. Russell November 9, 1987 Page 3 l
in a blown fuse.
The blown fuse was not a component failure because it was designed to blow as it did.
LER'2-87-01: The cause of this event is identified in Table 1
6 as a personnel error.
We consider the cause of this event to be a component failure.
The "C" Residual Heat Removal' I
(RHR) pump discharge check valve did not fully seat after i
being closed at the completion of a local. leak rate test 1
(LLRT).
The valve should have seated under the weight of' j
the' valve disk and the head of stayfull water above in the RHR piping, but for unknown reasons it did not.
The 1
operating shift was taking actions to find the source of the in-leakage to the torus and to. control torus. water volume.
The torus water filter pump was being turned on and off for several hours to keep torus level within the required range.
3 The operating shift was not attentive enough to the torus i
water level to keep it from slightly exceeding the limit at l
one point; however, we do not consider this to be the root j
cause of the event.
Although the corrective actions were to
.j add a step to the LLRT procedures to ensure that the check a
valves are not leaking at the completion of the test, we do not consider the procedures to have been deficient or the test engineers to have been inattentive.
The valve leakage was an unusual and unanticipated incident which was not j
readily observable to the test engineers.
LER 3-86-17: The cause of this event is identified in Table 6 as "other."
The cause of this event is personnel error because the security force supervisors incorrectly assigned 1
the fire watch patrols (as explained in the LER).
Radiological Controls:
Health physics problem resolution has improved significantly since the end of the assessment period through the use of a new Health Physics Deficiency Report (HPDR) system.
Additional personnel were assigned to HPDR resolution in June 1987 and the backlog of HPDRs were essentially l
eliminated by September 1987.
A revision to the HPDR j
procedure to refine the system further is planned to be
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completed by December 1, 1987.
This revision will provide j
an accelerated reporting mechanism to assure that plant
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management is promptly informed of any procedural violations or poor radiation worker practices.
This approach should strengthen overall radiological controls and improve worker practices.
l A Radwaste Group headed by a Senior Engineer has been established and is being staffed.
This group is dedicated I
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William 1T. Russell
- November 9, 1987 Page 4 to radwaste systems hnd programs.
By the establishment of this. group, technical expertise and supervision is being focused on radwaste to reduce the volume of radwaste generated, improve radwaste facilities and procedures, and ensure accurate shipping documentation.
-PECo has recognized the need to use more specialized individuals to perform health physics audits and has taken steps to do so.. Qualified personnel from the corporate Radiation Protection Section are now assisting the audit teams.
Additionally, an audit of radwaste shipping for which the services of a specialist will be retained is schaduled for the first Quart *.r of 1988.
By t"e establishment of the Hadwaste Group and by improving QA audits, recurrence of shipping errors will be prevented and our ability to' identify and correct problems in this area will be greatly improved.
The Health Physics organization was restructured in August 1987 to create seven first line Health Physics Supervisor positions which have been filled.
These field supervisors are on a rotating shift to assure contact with all technicians and to standardize supervisory approach.
This reorganization will afford the Applied Health Physics Supervisor the freedom for more meaningful oversight of Applied Health Physics activities.
Coordination between the health physics organization and the maintenance, operations and outage planning groups is being improved by more thoroughly incorporating radiological control considerations into the planning phase of work activities.
A new training program, addressing the need for individual responsibility in health physics procedures, has been developed to promote teamwork and cooperation between health physics personnel and all station personnel.
Essentially, all Peacn Bottom and Limerick Station personnel, including management personnel, are being scheduled for this training.
This program will stress that the succese of the ALARA Program is highly dependent on strong commitment by Company management and supervision to require that ALARA is treated as an integral part of the planning and execution of each job.
An ALARA Manual is being developed as a long range means for coordinated improvement of the ALARA Program.
The manual u
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William T. Russc31' November 9, 1987 Page 5 will address such topics as goal setting, outage planning, dose reduction methodology and ALARA training.
A key feature of the upgraded ALARA Program will be t? increase personnel sensitivity to radiation exposure through means such as ALARA suggestions, posters, bulletin boards, sp3cial or reinforced training and periodic radiation safety. talks.
Investigations to identify needed improvements in the maintenance / health physics personnel interface have been performed.
Initial feedback was used by the Maintenance Department in a meeting with maintenance personnel which covered the maintenance / health physics interface, roles, and responsibilities of each, and the need for cooperation.
The Superintendent - Plant Services, and the Senior Health Physicist also held meetings with the health physics technicians to stress the need for cooperation with maintenance personnel.
A health physics training program j
has been developed at the PECo Barbadoes Training facility
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covering health physics procedures and radwaste volume i
minimization.
A full radiological work area is simulated l
for practical training.
All new maintenance helpers and current crafts will go thrcugh-this program.
An aggressive program of " total dose control" was implemented at Peach Bottom in July 1987.
The goal is to achieve total accountability of all personnel exposure.
A new plant access control facility was built at the main entrance to the power block.
All Radiation Work Permits (RWPs) are kept at the access facility and there is a RWP for all radiologically controlled areas.
Upon entering the power block, personnel ruust sign-in on a " general &ccess" RWP and on the RWP for any specific work area they intend to enter.
Individuals are also issued a personal " dose card" on which their dose is recorded upon entering and exiting 3
each RWP area.
Early results of this program indicate that l
it will be effective in reducing total plant personnel exposure and significantly improving dose accountability.
1 Maintenance:
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With regard to the two scrams apparently caused by inadequate post-maintenance inspection and testing, condensate system procedures were revised to require a flushing step, and a new maintenance procedure has been prepared which will prevent future resin deposits.
We concur with your observation that the equipment lubrication program is not being fully implemented.
This l
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William T. Russell November 9, 19.87 Page 6
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situation will be carefully reviewed, and a more practical and effective program will be established.
Station Operations Management and Station Maintenance Management will provide the necessary oversight to ensure that the program is developed, implemented and executed.
Surveillance:
We note your positive observations in the curvpillance area, and will continue our efforts to further improve the surveillance program.
Fire Protection:
. Modifications required to bting Unit 2 into compliance with j
Appendix R vill be completed prior to Unit 2 startup after
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the current outage, and modifications required to bring Unit i
3 into compliance with Appendix R will be completed prior to j
Unit 3 startup after the current outage.
Emergency Preparedness:
As a result of staffing problems recognized during the October 9, 1986 emergency drill, several corrective steps have been taken to assure the availability of a sufficient number of operators to participate in the drill.
These
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involve better coordination between the Emergency Preparedness Section and Station Management during the drill planning phase, the development of drill scenarios that consider staffing capabilities, and better_ consideration of shift schedules in the selection of the drill date.
I To improve the dose assessment function, procedural changes, additional training, and a rearrangement of personnel responsibilities are being implemented and will be in place for the 1987 annual exercise.
Station Management has mage several improvements to better implement emergency preparedness activitien The Site i
Emergency Planning Coordinator attends scheduled, periodic meetings with senior plant staff at which emergency j
preparedness concerns are discussed.
Emergency plan procedures must now receive review by the Emergency Preparedness Section before final approval.
Several emergency plan procedures have been improved since the October 1986 exercise.
The revised procedures have re-emphasized and detailed the responsibilities of key
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William T.
Russell November 9, 1987 Page 7 l
technical staff in the EOF and TSC.
These procedures will oe implemented. for the 1987 annual exercise.
An aggressive-drill program has been underway in 1987 with participation by plant staff.
Four site drills have been conducted through September with three additional drills scheduled prior to the annual exercise.
Additional group-
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specific drills are also being conducted.
1 An annual exercise has been scheduled for December 8, 1987.
This exercise will incorporate personnel newly assigned to emergency response positions.
Security and Sareguards:
The number of new PECo plant security personnel has increased from three to seven since the end of the assessment period.
These individuals are now providing 24-hour coverage of the contract security force.
1 Fire watch duties have been separated from the security I
force duties so that each can be better managed.
The l
security contractor supervisor has been replaced with an individual with better canagement qualifications.
Work hours limits for security force members have been reduced.
Security force post rotations have been increased and secLcity force members have been encouraged to call for j
relief if they feel that they cannot remain attentive.
They have been assured that they will not be penalized for taking I
such action.
The level of compensation has been increased for the security force resulting in a reduction in the personnel turnover rate.
Further. steps to reduce the turnover rate are being pursued.
With legard to the NRC's assessment that our response to a potential equipment tampering event was initially insufficient, we have taken several corrective steps.
The need to consider a broader operational response when l
suspicious equipment failures are discovered has been emphasized to thh Shift Managers.
Furthermore, classes addressing various safeguards-related incidents and appropriate responses were conducted for more than eighty i
members of the Peach Bottom operations staff and security force.
The review of several NRC I.E.
Information Notices and security reporting requirements was included in this training.
Operations personnel are now participating in i
security response drills.
This cooperative effort will prove to be of significant value becauce merging the plant
i Willirm T. Rassoll November 9, 1987 Page 8 knowledge of operations personnel with the investigative and search expertise of security personnel will improve our response to potential threats.
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i Assurance of Quality:
Major organizational changes to strengthen both. corporate and site nuclear management will be phased in with total
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implementation prior to startup of either unit.
The i
reorganization will strengthen and consolidate nuclear management and its engineering support and, at the same time, elevate Limerick and Peach Bottom operations within the corporate structure.
Non-nuclear operations and non-nuclear engineering will be assigned to a separate department.
The reorganization will be discussed in detail
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in a License Amendment Application to be filed with the Commission later this month.
Licensing Activities:
Licensing Section management has reviewed the NRC's most
.recent " Assessment of the Quality of Licensee Event Reports (LERs) - Peach Bottom Atomic Power Station" transmitted by letter dated July 10, 1987, and has incorporated the NRC's comments into its review of LERs prior to approval.
A copy i
of the assessment has been distributed to the Licensing Section staff for review with instructions to incorporate the NRCs comments into LERs that they write.
Providing additional training to the Liceasing Section staff and revising the Licencing Section LER procedure to provide more guidance on the content of LERs will improve the
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quality of future LERs.
To assure consistency and completeness in the preparation of LERs, a training session will be conducted (by a member of the Licensing Section staff) which the entire staff will attend in November 1987.
The NRC's LER asse8 scant will be discussed in detail and an I
open dialogue will be established to ensure a clear understanding of the NRCC interpretation of the LER content requirements (10 CFR 50.73(b)) to improve our LERS.
Licensing Section staff members are now being required to
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complete an "LER checklist" when they draft LERs to ensure that LERs are complete.
Additionally, an in-house training course, franchised by Effective Writing Associates, will be given to seven new members of the Licensing Section staff to ensure continued effective writing.
I PECo concurs with your assessment that our update of the diesel generator manuals has been untimely.
Priority I
attention was not initially directed towards the
William T. Rus' sell November 9, 1987 Page 9 upgrade / update of the diesel generator manuals.
During this assessment period, priority attention was directed toward the diesel generator manuals and a contract was established with the vendor for the project.
The process of preparing a procurement specification for the updated diesel generator manuals and negotiating a contract for the project required an extended period of time partly because of our desire to do more than.merely update the manuals.
Extensive improvements of the manuals were planned.
The new manuals will be a comprehensive multi-volume set which incorporates the maximum practical level of detail for parts lists, component technical literature, and operating and
-maintenance recommendations.-.It is intended to reduce our reliance on the vendor for detailed technical information and to assemble information which is currently located in several locations within the PECo file system into one location.
As a result, the preparation of the purchase order and negotiations with the vendor for its acceptance was an extensive task.
The following measures have been taken to expedite the completion of the project.
1)
Milestone dates have been established with the vendor for completion of key elements of the manual package.
2)
Periodic visits to the vendor's facility by the PECo responsible engineer are planned in order to monitor the vendor's progress and to perform in-line reviews of the manual sub-sectionu as they are completed.
3)
The vendor has been encouraied by PECo management to add additional manpower as necessary in order to ensure that the schedule is maintained or imp 1 weed.
I:s of September 30, 1987, the vendor was on cchedule for cubmittal of a draft of the new manuals to PECo by December
?.1, 1987.
PECo review of the draft and final approval will follow promptly.
The EALP report identified several examples of licensing issues.that have required an extended period of time to resolve.
The delays associated with these examples indicate the need to improve communications in two areas.
First, we believe there is a need to improve communications between the Company's licensing personnel and the NRC Project l
Manager by scheduling monthly reviews of all open licensing issues.
These monthly reviews will clarify priorities and identify existing constraints.
This routine, open line of communication will help to ensure timely responses to
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licensing issues by providing afmore. sound ~ basis for-i allocating resources.
Secondly, there-is a need to improve feedback.to company management of licensing issuesirequiring
.their1 attention.- The Licensing Section~will take steps to:
address this need.
u If you>have-any-questions, please do not hesitate to contact
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l Very truly yours, Li
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cc:
Addressee.
R. E. Martin, Peach Bottom NRC Project Manager R. J. Clark, Limerick NRC Project Manager T. P. Johnson, NRC Resident Site Inspector
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