ML20237E267
| ML20237E267 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/18/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20237E269 | List: |
| References | |
| NUDOCS 8712280242 | |
| Download: ML20237E267 (4) | |
See also: IR 05000277/1986099
Text
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18 DEC 1987
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Docket Nos.
50-277
50-278
Philadelphia Elect,-ic Company
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ATTN:
Mr. J. W. Gallagher
Vice President
Nuclear Operations
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP); Report
No. 50-277/86-99 and 50-278/86-99 - Amended Report
This refers to the assessment we conducted of the activities at the Peach
Bottom Atomic Power Station, for the period February 1,1986 through May 31,
1987. This report was discussed with you at a meeting on October 1, 1987
at the site in Delta, Pennsylvania. The list of meeting attendees is attached
as Enclosure 1.
In response to your written comments (Enclosure 2) on our
report, minor editorial changes to the enclosed amended report (Enclosure 3)
were made by my staff.
Our overall assessment was that facility performance was unacceptable in the
areas of plant operations and assurance of quality because of operator inatten-
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tiveness and management inability to identify and correct operator conduct in
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other areas. Your letter of November 9, 1987 addressed the corrective actions
taken and planned in other areas. We understand your actions in response to
the March 31, 1987 shutdown order and its causes are being addressed by other
correspondence.
No reply to this letter is required.
Your actions in response to the NRC
Systematic Assessment of Licensee Performance will be reviewed during future
inspections of your licensed facility.
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We appreciate your cooperation.
Sincerely,
Originni Signed By
UILLIL'.
T. IO3SZLL
William T. Russell
Regional Administrator
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OFFICIAL RECORD COPY
12/05/87
8712280242 871218
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ADOCK 05000277
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Philadelphia Electric Company
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18 DEC 1987
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Enclosures:
1.
Attendees at Peach Bottom SALP Management Meeting
2.
Response letter from PECo dated November 9, 1987
3.
Amended SALP Report
4.
Letter from NRC to PECo transmitting original Report dated
September 8, 1987
5.
SALP Board Report Errata Sheet
cc w/ encl:
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Dickinson M. Smith, Manager, Peach Bottom Atomic Power Station
John S. Kemper, Senior Vice President, Engineering and Production
' Thomas S. Shaw, Jr. , Vice President, Production
Troy B. Conner, Jr. , Esquire
W. H. Hirst, Director, Joint Generation Projects Department',
Atlantic Electric
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G..Leitch, Nuclear Generation Manager
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Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report) .
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Raymond L. Hovis, Esquire
Thomas Magette, Power' Plant Siting, Nuclear. Evaluations
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W. M. Alden, Engineer in Charge, Licensing Section
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Doris Poulsen, Secretary of Harford County Council
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
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Commissioner Carr
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Commissioner Rogers
K. Abraham, Public Affairs Office (14)
bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
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Robert J. Bores, DRSS
Director, DRS
T. Martin,.DRSS
J. Taylor, DED0
W. Russell
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J. Allan
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D. Holody
Management' Meeting Attendees
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DRP WISHLIST Coordinators . a/
M. Eisenber , Ph.D'
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R. Martin, RR
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OFFICIAL RECORD COPY
12/08/87:
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ENCLOSURE 1
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NRC/PECo SALP Management Meeting 10/1/87
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Peach Bottom (PECo)
D. Potocik
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Senior Health Physicist
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D. Smith
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Superintendent Operation PBAPS
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A. Fulvio
Technical ' Enginee r-PBAPS
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J. Mitman
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Senior Engineer-Radwaste PBAPS
G. Sprissler
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Supervising Chemist-Chem. Section
G. Munger Jr. -
Engineer-in-Charge Nuclear Safety Section
J. Davenport
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Supervising Engineer-Maintenance Department-PB
G. Stanek
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Executive Committee-IGA PB/Congowingo Division-
R. Costagliola -
Superintendent Nuclear Station Section
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Maintenance Department
W. Casey
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Superintendent Station Maintenance Division
Maintenance Department
J. Winzenried
Staff Engineer-PBAPS
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R. Bulmer
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Superintendent Nuclear Train Section
M. Cassada
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Director Radiation Protection
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G. Rainey
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Superintendent-Services Peach Bottom Station
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G. Dawson
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Senior Engineer Maintenance
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R. Andrews
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Training Coordinator-PBAPS
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F. Lear
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Licensing Section
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D. Oltmans
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Senior Chemist
J. Lamontagne -
PBAPS-Communications
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K. Wischelecker-
Senior Emergency Preparedness Coordinator
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R. Kankus
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Director-Emergency Preparedness
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Engineer-Administration, Peach Bottom
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B. Clark
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J. McElwain
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A. Donell
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R. J. Lees
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Assistant Chief Electrical Engineer
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R. Sweeny
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Investigator-Corporate Security
R. Deneen
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Director Corporate Security
R. Weindorfer
Director Nuclear Plant Security
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W. Birely
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Senior Licensing Engineer
L. Pyrih
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Chief Mechanical Engineer
C. Rush
Manager Engineering and Research
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R. Mulford
Staff Engineer-Mechanical Engineering Division
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W. Knapp
Director-Radioactive Waste Management Section
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P. Webster
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Senior Public Information Representative
J. Jones
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Assistant Manager Public Information
R. Moore
Superintendent Nuclear Operations QA
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M. Cooney
Manager-Nuclear Support
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D. Smith
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Manager, PBAPS
J. Kemper
Senior Vice-President Engineering / Production
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J. Austin Jr.
Presidert
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J. Gallagher
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Vice-President, Nuclear Operations
G. Leitch
Manager, Nuclear Generating Department
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W. Alden
Engineer-in-Charge-Licensing
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M. McCormick
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Manager-Maintenance Department
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SALP Management Meeting 10/1/87
Other Attendees
M. Murphy
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Senior Nuclear Engineer - PA DER /BRP
W. Hirst
Manager-Joint Generation - Atlantic Electric
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W. Dornsife
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Chief, Division of Nuclear Safety - PA DER
M. Phillips
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Senior Engineer,. External Affairs - PSE&G
E. Skeehan
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J. Parrott
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Councilwomen - Harford County Council
B. Risacher
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Councilwomen - Harford County Council
U.S. Ngciear Regulatory Commission (USNRC)
W. Kane
Director, DRP
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E. Wenzinger
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Chief, Projects Branch 2
J. Linville
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Chief, Reactor Projects Section 2A
R. Clark
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Project Manager
T. Johnson
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Senior Resident Inspector, Peach Bottom
R. J. Urban
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Resident Inspector, Peach Bottom
L. Myers
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Resident Inspector, Peach Bottom
J. Williams
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Project Engineer, NRC-RI
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ENCLOSUP.E 2 -
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PHILADELPHIA ELECTRIC COMPANY-
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2301 M ARKET STREET
P.O. BOX 8699
PHILADELPHIA; PA.19101
(215) 841 5001
JOSEPH W. G A LLA GHE R
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November
9,-
1987
Docket Nos.
50-277
50-278
Mr. William T. Russell, Administrator
Region I
U.S. Nuclear Regulatory Commission
Attn:. Document Control Desk
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
Dear Mr. Russell:
This letter is submitted in accordance
h your
request to provide written comments within 30 days after a
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
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the Shutdown Order dated March 31, 1987 because those issues have
been discussed at length in_other forums.
This approach
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permitted discussion of other important issues identifjed in the
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SALP Report.
This letter reflects an approach consistent with
that of the meeting.
Based on +he discussions at the meeting we offer the
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following comments:
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November 9, 1987
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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;
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conduct an individual operator attitudinal assessment
and counseling program to' screen operators for return
to restart;
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establish the Shift Manager position with degreed
engineers holding a senior operator license;
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provide temporary and permanent off-shift positions
for licensed operators and establish a more aggressive
operator training and recruiting program;
o
establish an operations technical support group to
reduce the administrative burdens on operators;
o
improve attitudes towards procedural compliance
through administrative training and performance
evaluations;
o
increase Quality Control monitoring of operations.
With regard to the human factors problems in the station
blackout and containment venting emergency procedures,
procedure revisions are in progress.
Revisions of the
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 tg.e LERs except three (2-86-24, 2-87-
1 and 3-86-17).
Our rat.lonale for different causes is
provided below for your consideration.
LER 2-86-24: Thecauseof'khisevent 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
introducing a short circuit into the system which resulted
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William To Russell
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November 9, 1987
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in a blown fuse.
The blown fuse was not a component failure
because it was designed to blew as it did.
LER 2-87-01: The cause of this event is identified in Table
6 as a personnel error.
We consider the cause of this event
to be a component failure.
The "C" Residual Heat Removal
(RHR) pump discharge check valve did not fully seat after
being closed at the completion of a local leak rate test
(LLRT).
The valve should have seated under the weight of
the valve disk and the head of stayfull water above in the
RHR piping, but for unknown reasons it did not.
The
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.
The operating shift was not attentive enough to the torus
water level to keep it from slightly exceeding the limit at
one point; however, we do not consider this to'be the root
cause of the event.
Although the corrective actions were to
add a step to the LLRT procedures to ensure that the check
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
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
the fire watch patrols (as explained in the LER).
Radiolocicel Controls:
Health physics problem resolution has improved significantly
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since the end of the assessment period through the use of a
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new Health Physics Deficiency Report (HPDR) system.
Additional personnel were assigned to HPDR resolution in
June 1987 and the backlog of HPDRs were essentially
eliminated by September 1987.
A revision to the HPDR
procedure to refine the system further is planned to be
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completed by December 1, 1987.
This revision will provide
an accelerated reporting mechanism to assure that plant
management is promptly informed of any procedural violations
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or poor radiation worker practices.
This approach should
strengthen overall radiological controls and improve worker
practices.
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A Radwaste Group headed by a Senior Engineer has been
established and is being staffed.
This group is dedicated
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November 9, 1987
Page 4
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to radwaste systems and 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
scheduled for the first Quarter of 1988.
By the
establishment of the Radwaste 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 Peach Bottom and Limerick Station personnel, including
management personnel, are being scheduled for this training.
This program will stress that the success 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.
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An ALARA Manual is being developed as a-long range means for
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coordinated improvement of the ALARA Program.
The manual
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William T. Russell
November 9,
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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 to increase
personnel sensitivity to radiation exposure through means
such as ALARA suggestions, posters, bulletin boards, special
or reinforced training and periodic radiation safety tall:s.
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Investigations to identify needed improvements in the
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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
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responsibilities of each, and the need for cooperation.
The
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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
has been developed at the PECo Barbadoes Training facility
covering health physics procedures and radwaste volume
minimization.
A full _ radiological. work area is simulated
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for practical training.
All new maintenance helpers and
current crafts will go through this program.
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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
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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
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power block, personnel must sign-in on a " general access"
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
each RWP area.
Early results of this program indicate that
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it will be effective in reducing total plant personnel
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exposure and significantly improving dose accountability.
Maintenance:
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
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prepared which will prevent future resin deposits.
We concur with your observation that the equipment
lubrication program is not being fully implemented.
This
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William T. Russell
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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 surveillance area,
and will continue our efforts to further improve the
surveillance program.
Fire Protection:
Modifications required to bring Unit 2 into compliance with
Appendix R will be completed prior to Unit 2 startup after
the current outage, and modifications required to bring Unit
3 into compliance with Appendix R will be completed prior to
Unit 3 startup after the current outage.
Emeroency 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
involve better coordination between the Emergency
Preparedr.ess 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.
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 made several improvements to better
implement emergency preparedness activities.
The Site
Emergency Planning Coordinator attends scheduled, periodic
meetings with senior plant staff at which emergency
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
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technical staff in the EOF and TSC.
These procedures will
be implemented for the 1987 annual exercise.
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An aggressive drill. program has been underway in 1987 with
participation by plant staff.
Pour site drills'have been
conducted through Septembe. with three' additional' drills
scheduled prior to:the annual exercise.
Additional group-
specific drills are also being conducted.
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An annual exercise has been schedule'd for December 8, 1987.
This exercise will incorporate' personnel newly assigned to
emergency response positions.
Security and Safeguards:
The number of new PECo plant security personnel has
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increased from three to seven since the end of the
assessment peri ~od.
These individuals are now providing 24-
hour coverage of the contract security force.
Fire watch duties have been. separated from the security
force dutieg so that each can be.better managed.
The
security contractor supervisor has been replaced with an
. individual with better management qualifications., Work
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hours limits for security fotse membersfhave-been reduced.
Security force post rotations have been increased and
cecurity force members have.been encouraged to call 1for
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relief if they feel that they cannot remain attentive.
They
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have been assured that they will not be penalized for taking
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
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are being pursued.
With regard 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
suspicious equipment failures are discovered has been
emphasized to the Shift Managers.
Furthermore, classes
addressing various safeguards-related incidents and
appropriate responses were conducted for more than eighty
members of the Peach Bottom operations staff and security
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force.
The review of several NRC I.E.
Information Notices
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and security reporting requirements was included in this
training.
Operations personnel are now participating in
security response drills.
This cooperative effort will
prove to be of significant value because merging the plant
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November 9, 1987
Page 8
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knowledge of operations personnel with the investigative and
search expertise of security personnel will improve our
response to potential threats.
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Assurance of Quality:
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Major organizational changes to strengthen both corporate
and site nuclear management will'be phased in with total
implementation prior to startup of either unit.
The
reorganization will strengthen and consolidate nuclear
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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
in a License Amendment Application to be filed with the
Commission later this month.
Licensino 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.
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comments into its review of LERs prior to approval.
A copy
of the assessment has been distributed to the Licensing
Section staff for review with instructions to incorporate
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the NRCs comments into LERs that they write.
Providing additional training to the Licensing Section staff
and revising the Licensing 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
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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 assessment will be discussed in detail and an
open dialogue will be established to ensure a clear
understanding of the NRCs 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
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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.
PECo concurs with your assessment that our update of the
diesel generator manuals has been untimely.
Priority
attention was not initially directed towards the
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William T. Russell
November 9, 1987
Page 9
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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 nave.been taken to expedite the
completion of the project.
1)
Milest'one 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-sections as they are completed,
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3)
The vendor has been encouraged by PECo management to
add additional manpower as necessary in order to
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ensure that the schedule is maintained or improved.
As of September 30, 1987, the vendor was on schedule for
submittal of a draft of the new manuals to PECo by December
11, 1987.
PECo review of the draft and final approval will
follow promptly.
The SALP 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
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 a more sound basis for
allocating-resources.
Secondly, there is a need to improve
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feedback to company management of licensing. issues requiring
their attention.- The Licensing Section will take steps to
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address this need.
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If you have any' questions, please-do not hesitate to contact
us.
,
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Very truly yours,-
&. f f
Lc
cc:
cAddressee-
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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