ML20245F464

Forwards Zt Pate Providing Review of Interactions That Have Taken Place Between Util & INPO Since & Assessment of Util Response to Recommendation in Ltr,Per 880304 Request

ML20245F464
Person / Time
Site:	Peach Bottom
Issue date:	03/01/1989
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20245F362	List: ML20245F358 ML20245F464
References
NUDOCS 8905020387
Download: ML20245F464 (30)

Text

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Attachment 1 to Enclosure 1 PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA A, PA 19101 (255) 841 5005 JOSEPH W. G ALLAGHER vics passaount mucLaan osavacus March 1,1989 Docket Nos. 50-277 50-278 Mr. William T. Russell Administrator, Region I U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555

SUBJECT:

INPO Assessment of Philadelphia Electric Company's Response to Recommendations in January 11, 1988 letter

REFERENCE:

March 4,1988 Letter from W. T. Russell (NRC) to J. L. Everett, (PECO)

Dear Mr. Russell:

In the above referenced letter, it was requested that Philadelphia Electric Company apprise the NRC of the results of INPO evaJustions prior to restart of the first Peach Bottom unit.

In accordance with this request, I am forwarding a copy of the February 21, 1989 letter, with attachments, to Mr. Joseph F. Paquette, Jr. , from Mr.

Zack T. Pate which provides a review of the interactions that have taken place between PECo and INPO since the letter of January 11, 1988 and provides an assessment of PECo's response to the recommendation in that letter.

Sincerely, Y!A*gk cc: L. W. Zech, Jr.

V. Stel.'o R. E. Martin j a 1 E

i Institute of Nuclear Power Operations Suite 1500 I 1100 Circle 75 Parkway Atlanta, Georgia 30339 Telephone 404 953-36o0 February 21, 1989 J.F. PAOUETTE JR. !

FEB 2 21989 Mr. Joseph F. Paquette, Jr.

Chairman, CEO, and President Philadelphia Electric Company Correspondence Control Desk Post Office Box 7520 Philadelphia, PA 19101

Dear Mr. Paquette:

On January 11, 1988, INP0 sent a letter to Mr. Robert D. Harrison, Chairman of the Special (Nuclear Oversight) Committee of the Philadelphia Electric Company Board of Directors, concerning performance problems at Peach Bottom Atomic Power Station and with the Philadelphia Electric Company (PEco) corporate organization. That letter, which was critical of PEco management's handling of longstanding problems at the Peach Bottom site, was ultimately made public. l l

i The purpose of this letter is to review the interactions that have  !

taken place between PEco and INP0 since the January 1988 letter and to l provide an assessment of PEco's response to the recommendations in that letter.

Over the past year, there have been many interactions between PECo and INPO. Some of these have been at PEco's request; others have been initiated

{ by INP0. Attachment A provides a chronological listing of the key l

interactions. Of the 26 interactions listed, four are discussed in detail in attachments to this letter, as follows:

a. the INPO plant evaluation of Peach Bottom conducted in September 1988 - - Attachment B provides the significant results of that evaluation.

b. the PEco corporate evaluation conducted by INP0 in October 1988 -

' - Attachment C summarizes the results.

c. the INP0 re-evaluation of operations crew performaiice in the simulator in December 1988 - - Attachment D providas the results.

i d. the INP0 plant evaluation follow-up visit to Peach Bottom in 1

January 1989 - - Attachment E provides the results of that visit.

To: Mr. J. ' F. Paquette, Jr.

February 21, 1989 Page Two.

While Attachment A lists a large number of interactions over the past year, most are typical of visits that INPO makes to all its member utilities.

Those listed above are the most important and the most relevant to the issues described in the January 11, 1988 letter. As can been seen from Attachments B and C, a number of shortfalls in performance were identified during the INPO Peach Bottom evaluation in September 1988, and in the corporate evaluation that followed in October. Attachments D and E report the results-of our follow up to ensure that corrective actions were responsive and adequate.

The January 11, 1988 INPO letter provided three recommendations: for improvement at Peach Bottom. These recommendations dealt with the need for fundamental change in the corporate approach to nuclear operations and are restated below. INP0's assessment of the effectiveness of actions taken to resolve each recommendation is provided:

a. Recommendation I:

" Conduct a detailed analysis of the internal investigation material developed by PEco. Develop a report with an appropriate executive summary, findings, conclusions, and recommendations based on this analysis. Experience shows that a full recovery from a situation such as the one

- developed at Peach Bottom cannot be assured unless all the relevant facts are carefully analyzed. To our knowledge this has not been done."

Subsequent to receiving this recommendation, PEco retained an independent firm to conduct the recommended analysis. Based on a review of the independent firm's report, a review of the Peach Bottom restart plan, and discussions with PECo executives, the spirit and intent of this recommendation have been carried out.

b. Recommendation II:

" Review and minimize the actions being taken or planned that bypass or work outside (and tend to undermine) the line organization. It is recognized that some in the NRC may press the company to set up measures outside the line to l detect fut'ure problems. Strong management can achieve this.

in a balanced way, while preserving line integrity. If the approach is sound, NRC will accept it. In our view the present approach is not balanced, and perceived NRC Mesires are being used as a crutch." i

To: Mr. J. F. Paquette, Jr.

February 21, 1989

• Page Three.

PEco has taken many steps to strengthen, emphasize, and support the role of line management and to clarify the role of independent support groups in the operation of its nuclear facilities. These actions are described in the Peach Bottom restart plan.

h key area of concern to INP0 was the assignment of QC personnel to each shift to monitor shift operations and to ensure the operators remained awake. This practice was discontinued in favor of emphasis on the accounta-bility of line management for monitoring shift perform-ance.

In both the INP0 plant evaluation in September 1988 and the corporate evaluation in October 1988, independent assessment activities were found to be properly sup-portive of line management efforts and accountability.

Further actions to strengthen line management are i discussed below.

' c. Recommendation III:

" Major changes in the corporate culture are required.

The recently announced reorganization will not achieve this. Experience shows that the same managers, placed l l in a different organizational arrangement, are usually  !

unable (or unwilling)-to effect major changes in standards, accountability, etc. Acquiring and install-ing a single outsider as " Senior Nuclear Officer" in the existing (new) PEco organization is insufficient action

- to bring about the necessary change.

Coincident with the acquisition of sufficient outside talent to properly upgrade the PEco nuclear situation,

' accountability should be exercised for the unsatisfac-e tory situation that has been allowed to develop over a period of years."

Replacement of key personnel, organizational '

changes, acquisition of outside talent at many

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levels of the organization, and corrective actions from the restart plan have emphasized accounta-bility and fostered attitude change within the i

. company. It is evident to INPO and to other close observers that the company has made and is continu- a ing to make considerable progress in achieving the necessary cultural change. INP0 compliments PEco on its aggressive and wide-ranging actions to bring about this significant change.

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To: Mr. J. F. Paquette, Jr.

February 21, 1989 Page Four.

In summary, there' have been a large number of substantive interactions 3 between PEco and INPO since the January 11, 1988 letter. On balance, INPO-

" 1 considers that PEco has adequately addressed the recommendations contained in that letter and, further, that actions taken by the company to resolve the additional issues-rcised in subsequent INPO visits listed above have been responsive and effective.

INPO requests that copies of this letter, with attachments, be provide' d to each inember of the PECo Board of, Directors. In addition, in consideration ]

of the distribution given to the January 11,'1988. letter, we suggest that 1 this letter be shared with outside organizations as follows: 1

a. a copy, with attachments, be provided to Nuclear Electric Insurance Limited

b. a copy, with attachments, be'provided to each Peach Bottom co-owner

c. a copy, with attachments, be made available to appropriate senior management of the Nuclear Regulatory Commission for their review

-- These managers should include, as a minimum, the Chairman, the Executive Director of Operations, and the Regional Administrator (Region I).

Sincerely M.

Zack T. Pate President ZTP/ra Enclosures (as stated) j

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ATTACHMENT A .

j F. 10 LOGY I

DATI INTERACTION January 26, 1988 The PEco Industry Review Panel l met in Philadelphia with members of PEco senior management and the PEco Board of Directors.

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January 29, 1988 The INP0 President and group vice president for evaluation and assistance attended a special meeting of the Nuclear Comtdttee of the PEco Board i

of Directors.

l February 8, 1988 INP0 provided comments on Section II (plant action)  !

of the Peach Bottom Restart Plan as requested by PEco.

I February 10-11, An INP0 maintenance assistance and review team 1988 conducted a follow-up to a previous similar visit in November 198/.  ;

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l A panel of five industry executives formed by PEco on April 9,1987, to provide review of the facts leading to and surrounding the " sleeping on shift" situation that led to the NRC's shutdown order, review the recovery plan developed by PECo, and make recommendations for modifications and enhancements to the recovery plan.

L________________

Letter to.J. F. Paquette, Jr.

February 29-March An INP0 team conducted a special assistance visit 4, 1988 in the area of radiological protection as requested by PECo.

March 10, 1988 The Industry Review Panel for PEco was discontinued, having fulfilled its mission.

March 25, 1988 The PEco chairman, CEO and president, and executive vice president - nuclear visited INP0 for discussions and briefings related to the Peaci Bottom situation.-

April 14, 1988 PEco responded to INP0's January 11, 1988 )

i letter to Mr. Robert D. Harrison. The reply )

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described the corrective action planned and completed for each of the three principal recommendations in the January letter.

July 1, 1988 PEco provided INP0 a copy of the PECo Commitment to Excellence in Nuclear Operations statement, noting that it was still being refined.

July 25 29,1988 INPO conducted a special assistance visit at the PEco corporate office in the area of configuration management.

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t Letter to J. F; Paquette, Jr.

1 August 9-11, 1988 A second maintenance assistance and review team follow-up visit was conducted.

August 19, 1988 The Peach Bottom site vice president advised INP0 of actions taken by Peach Bottom to resolve the i remaining items from the INPO list of actions to be completed prior to startup developed after the 1987 INP0 plant evaluation.

i September 7-8, 1988 An INP0 accreditation assistance visit was conducted at the Peach Bottom site.

September 14, 1988 PEco responded to INP0's letter to the industry of.-

l March 30, 1988, on the Principles for Enhancing Professionalism of Nuclear Personnel.  !

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September 15, 1938 Two members of the PECo Board of Directors j Nuclear Oversight Committee visited INP0 for a '

general briefing on INP0 activities.  !

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September 12-23, INPO conducted a full plant evaluation at Peach 1988 Bottom.  ;

i September 29-30, INP0 conducted a special assistance visit to aid ,

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J Letter to J. F. Paquette, Jr.

1988 the Peach Bottom simulator instructors in i j

conducting effective training and evaluations for !

licensed operators.

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September 30, 1988 INP0 forwarded the simulator crew

. performance observations resulting from the

-September 1988 INP0 plant evaluation.

t October 3-7, 1988 INP0 conducted a corporate evaluation of Philadelphia Electric Company.

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October 7, 1988 The Peach Bottom site vice president forwarded to l 1

l INP0 copies of the accreditation self evaluation report of the Peach Bottom training program.

1 November 3-4, 1988 A follow-up training assist visit in the simulator training area was conducted.

, l December 5-9, 1988 INP0 re-evaluated the performance of four i

operations crews in the simulator.

i December 7-14,1988 An INP0 team evaluated the emergency response 4

organization readiness at Peach Bottom.

'l January 9-13, 1989 An INPO accreditation team visited Peach Bottom.

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l Letter to J. F. Paquette, Jr. )

January 16-20,1989 An INP0 follow-up team evaluated progress made in i correcting remaining key problem areas from the 1

September 1988 plant evaluation. l 1

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l RESTRICTED DISTRIBUTION

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PEACH BOTTOM (1988)

Page 2 EXECUTIVE

SUMMARY

The following beneficial practices and accomplishments were noted:

o improved state of preservation of unit 2, reduction in contaminated plant areas, i increased efforts to improve the reliability of motor-operated valves, and )

protection of plant systems and system components from corrosion by extensive j lay-up measures o human factors enhancements to support operations including installation of mimic bussing, color-coding, and other operator aids in the control room; and consistent application of detailed, easy-to-read labels on components and piping throughout the plant o the positive attitude and motivation exhibited by craftsmen and an improvement

in teamwork among most plant groups o achievement of low, cumulative radiation exposure in the replacement of the unit 3 recirculation piping by effective application of proven ALARA principles and lessons learned from replacement of the unit 2 piping i Improvements were recommended in a number of areas. The following are considered to be i among the most significant areas in need of improvement

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1. The ability of shift crews to respond to plant transients as demonstrated in the i simulator needs significant improvement. (OP.4-1) Examples include the following:

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a. Both crews observed had problems executing instructions in the transient response implementing procedures.

b. Both crews observed experienced difficulty operating key systems important to cooling the reactor,

c. Both crews observed had difficulty controlling reactor vessel water level when recovering from simulated events.

d. One crew failed to recognize several abnormal conditions.

2. Operations management and shif t supervision are not sufficiently aggressive in providing needed guidance, holding personnel accountable, and ensuring ef fective g action is taken to con ect operational and administrative problems. (OP.1-1)

Examples of this problem are as follows:

a. Shift operations crew performance in the simulator needs improvement.

See paragraph I above. a

b. Managers and supervisors need to ensure that some significant operational problems are promptly investigated and corrected.

Attachment B

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RESTRICTED DISTRIBUTION PEACH BOTTOM (1988)

Page 3

c. Implementation of the Operations Mansgement Manual and Operators Manual has been impeded by lack of clear direction, management follow-up,

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and personnel accountability.

d. Implementation of the permit and blocking system is impaired by lack of ,

clear direction and by insufficient management follow-up to ensure standards are met.

3. The ability of control room operators to readily and accurately determine plant

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status is impeded by problems with many of the administrative tools provided to -

control the status of plant systems and components. (OP.1-1, OP.3-1, OP.3-2, TS.3-1, TS.7-1) Problems were noted in the fo!!owing areas:

a. Administrative provisions of the permit and blocking system hamper the operators' ability to determine the status of all blocked components in the plant.

b. Control room piping and instrumentation drawings (P&lD) need to be annotated to reflect the installation of temporary plant alterations to support timely and appropriate response to plant casualties and to facilitate proper isolation when needed.

c. Control room P&lDs omit many installed valves and most ahigned valve numbers, thereby decreasing the operators' ability to determine and communicate plant configuration and needed changes, especially during off-normal plant conditions.

d. Operations narrative logs need to be consistently maintained to a level of detail sufficient to enable oncoming shift crews to accurately assess the estatus of the plant, including events in progress.

4. Higher standards of performance need to be effectively established or implemented in several areas. (OA.3-1) Examples include the following:

a. Some management personnel do not provide needed direction or hold personnel accountable to maintain a high level of shift operations crew performance. l

b. Some important plant events are inadequately investigated for root cause i and lessons learned; a threshold level for the initiation of internal event investigations based upon event significance needs to be established. l

c. Workers frequently use improper radiological protection practices; managers and supervisors infrequently monitor field work and sometimes mits opportunities to correct improper practices observed.

d. Standards for instructor use in evaluating operations crew performance in the simulator are needed. Lack of standards frequently results in performance evaluations that inadequately address performance weaknesses  !

and needed improvements; this significantly reduces the usefulness of  !

simulator performance evaluations as an effective training tool. ,

Attachment B

RESTRICTED DISTRIBUTION.

PEACH BOTTOM (1988)

Page 4

e. Improper industrial safety practices and working conditions are common.

Managers and supervisors rarely assess and correct improper practices and Conditions.

Findings and recommendations are listed under the performance objectives to which they '

pertain. Findings describe conditions that detract from meeting the performance objectives. Particularly noteworthy conditions that contribute to meeting performance objectives are identified as good practices and strengths. Good practices are considered sufficiently unique within the industry such that they would be useful to other utilities.

The recommendations following each finding are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations, the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues. Additional supporting details for selected findings are provided in Appendix II. -

As a part of each station evaluation, the evaluation team follows up on responses.to findings in previous reports. Findings with response actions that are incomplete, but progressmg on a reasonable schedule, are carried forward in Appendix ! to the report. In areas where additional improvements are needed, or where response actions have not been timely, a related finding that stands on its own merit is written. The finding (s) from the previous report to which the new finding is related are listed with the new finding.' For this report, there are six findings related to previous findings and five findings carried forward in j Appendix 1. .

The findings listed herein were presented to Philadelphia Electric Company management at an exit meeting on October 19,1988; findings, recommendations, and responses were discussed on December 5,1988, and the responses are considered satisfactory.

To follow the tiruely completion of the improvements included in the responses and the Appendix I items, and any SOER recommendations evaluated as not satisfactory, including each red-tab SOER recommendation received subsequent to this evaluation,(see Appendix II), INPO requests a written status report by June 30,1989. A final update will be requested six weeks prior to the next evaluation.

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Attachment B f

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^ 3 Page1 i EXECUTIVE

SUMMARY

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- The Institute of Nuclear Power Operations (INPO) conducted an evaluation of the corporate j support and monitoring of the nuclear stations from October 3 through 7,1988. j As a basis for the evaluation, INPO used the December 1987 Performance Objectives and Criteria for Cor> orate Evaluations; these were applied in light of the experience of INPO's q team members, . NPO's observations, and good practices within the industry. Information l

was gathered from discussions, interviews, reviews of documentation, and the evaluations of i

,, the stations.

Several beneficial practices and accomplishments were noted, including the following:

i o Implementation of an effective and comprehensive goals and objectives program 4

o Use of engineering work controls to provide timely modification packages for the j upcoming outage and timely engineering support as requested by the stations l l

i o Visible support by upper management for the ALARA program, resulting in radiation exposure reduction during major maintenance and modification efforts In addition, improvements were recommended in a number of areas. The following are considered to be the most significant areas in need of improvement:

1. Continue to improve the corporate support necessary to achieve operational excellence at both nuclear stations.

a. Cultural and behavioral improvements sought by senior management i during the past year need to be firmly established as part of conducting day-to-day business. (Finding 1.1A-1)

b. Additional operational experience and inquisitiveness are needed on the corporate staff to critically evaluate abnormal events and routine operations at the stations. (Finding 1.2A-2)

c. The permit and blocking program has caused personnel and equipment  :

safety problems at one station and administrative problems at both ,

stations for years. Aggressive corporate action has not been taken to  !

correct longstanding issues that inhibit implementation of an effective permit and blocking program. (Finding 1.2A-3)

d. The corporate staff needs to provide more assistance to improve performance of station activities in several areas (i.e., performance of operations shift crews, maintenance of acsedited training j programs, use of operating experience, proactive technical and materiel management support, and maintenance support). (F*mding 1.2A-4) .

Attachment C

Page 2

2. Monitoring and assessment of training activities at both nuclear stations by the corporate training organization are not effective in verifying that certain areas .

of the accredited training programs are properly maintained. (Finding 2.9C-1)

3. Important in-house operating experience information is inadequately shared between the stations, and industry operating experience information needs to be -

provided to groups within the corporate organization for review and use. (Finding i 1.2A-4)

In addition, the following two previously identified areas for improvement need strong and .

continuing emphasis:

1. Implement the planned margagement development program to prepare prospective managers for nuclear management positions and to provide necessary supervisory skills training and career paths for supervisors. (1987 - Recommendation 2.68-1) l

2. Implement the necessary controls to ensure effective configuration management of the nuclear stations. (1987 - Recommendation 1.2B-1). This includes establishment of a transition plan including action items and milestone dates for the transfer of design responsibilities and documents from the architect / engineer to the company. (Finding 1.2B-2)

Findings and recommendations are listed under the applicable performance objectives.

Findings describe conditions that detract from meeting the performance objectives.

Particularly noteworthy conditions that contribute to meeting performance objectives are '

identified as strengths. As a result, most of the findings highlight conditions that need improvement.

The recommenda; ions are intended to usist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations, the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.

INPO's goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant operation. The corporate findings and recommendations are based on apparent needs and on best practices, rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance. ,

The findings and recommendations listed herein were presented to management at an exit meeting on October 19,1988. Findings, recommendations, and responses were discussed on December 6,1988, and the responses are considered satisfactory.

To follow the timely completion of the improvements included in the responses, INPO requests a written status by June 30,1989. A final update will be requested six weeks prior to the next evaluation. In these status updates we request an assessment of the effectiveness of corrective actions taken for those key findings that are reflected above in the "most significant areas in need of improvement" be provided. .

i Attachment C

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l Institute of l

l 9@ Nuclear Power Operations Suite 1500 1100 Circe 75 Parkway Attanta, Georgia 30339-3064 Telephone 404953 3600 December 27, 1988 Mr. Corbin A. McNeill, Jr.

Executive Vice President, Nuclear Philadelphia Electric Company ,

Correspondence Control Desk {

Post Office Box 7520 '

l Philadelphia, PA 19101 '

Dear Mr. McNeill:

This letter documents the results of INPO's special assistance visit conducted at the Peach Bottom simulator from December 5 through 9, 1988, as requested by Mr. J. F. Paquette, Jr. The purpose of the visit was to evaluate shift crew performance in the simulator. .

l The results of the visit were discussed with appropriate members of the plant staff on December 9, 1988. Written material was not provided by the team at this briefing. In accordance with our policy, the team returned to INPO and discussed their thoughts with other experienced personnel and department management before providing these recommendations in writing.

Enclosed is a copy of our team's trip report. It is provided to you indercndent of INPO's evaluation program and is intended for assistance in enhancing nuclear plant operations.

The team noted improvement in the performance of the operating shift crews observed. Weaknesses were noted in teamwork for one crew.

l Attachnent D

j Mr. Corbin McNeill, Jr.

Page 2 I hope you find the information useful. Please do not hesitate to contact me, or have your staff contact Bo'o Link at 404/953-5452 on this matter.

Sincerely,

0. d. b^ r h Kenneth A. Strahm j Group Vice President Evaluation and Assistance KAS/ cap

Enclosures:

(as stated above) cc/w: J. F. Paquetta, Jr.

G. A. Hunger, Jr.

J. S. Franz Z. T. Pate A. C. Tollison, Jr.  ;

i Attachment D ,

- Instituu of Nuclear Power Operations 1

- om December 21 88 Memorandum To Ken Strahm . ,

Fmm: Bob Link l suoieTrip Report - Special Assist Visit to Peach Bottom Atomic Power Station Simulator I

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I. Background and Purpose A special assistance visit was conducted at the Peach Bottom ,

simulator from December 5 through December 9, 1988. The j purpose of the visit was to observe four operating shif t crews on the plant specific simulator conducting normal operationr pac responding to emergency situations.

observation of the operating shift crews in the simulator was conducted afttr satisfactory evaluation by Philadelphia  !

Electric Compa ny management as stated in a letter from Mr. J.

F. Paquette, J r. to Mr. Z. T. Pate dated December 2, 1988.

The observations were conducted at the Peach Bottom simulator l located at the simulator vendor's manufacturing facility in columbia, Maryland.

1 Team memphrs included the following individuals:

HAEA Title R. W. Link Team Manager G. K. Adkins Operations Evaluator S. M. Garchow Training Evaluator G. C. Tietz SRO Peer Evaluator (Assistant Superintendent Operations, Quad Cities)

Information used by the team members to prepare for the visit included the Peach Bottom Atomic Power Station October 1988 First Draft Evaluation Report, plant experience report, special assistance visit reports to assist simulator instructors dated October 4, 1988 and November 7, 1988, as well as the Peach Bottom emergency operating procedure flow charts. Additionally, the team members were briefed by the I original INPO operations and training evaluation team members.

Attachment D

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II. On-site Activities Team members arrived at the Pe6cn Bottom simulator vendor's i manufacturing facility around noon on Monday, Dscamber 5, )

1988. 'A 30 minute entrance meeting was conducted with Peach J

Bottom operations and training management to discuss the activlties planned for the rest of the week. Team members familiarized themselves with the control panels and reviewed the sequence of events for the simulator scenarios selected  !

by the INPO te&m for the next day's observation. Later, Peach Bottom operations Lanagement discussed operating crew composition, division of responsibility among crew members,

'- and the operating philosophy concerning the use of the emergency operating procedures.

The next four days consisted of observing four operating shift crews conducting normal operations and responding to emergency situations on the simulator. Each crew was observed during three scenarios in the evaluation mode over a four to five hour period starting at 0730 each morning. In the afternoon the team members re-constructed the scenarios using a common time line and compared observed crew performance against expected crew performance as specified in j the Peach Bottom procedures or operating philosophy. i Questions on observed activities were resolved through daily discussions between team members and the plant operations and training management. Additionally, team members reviewed the sequence of events for the simulator scenarios for the next i day with the simulator instructors on the simulator.

Plant personnel contacted while conducting the observations J are shown on Attachment A. A briefing was held on Friday, December 9, 1988, where team members presented verbal feedback to plant operations and training management on the operating crew performance.

III. summary The team noted improvement in the performance of the operating shift crews observed. However, while the .

I performance of one crew was generally in keeping with the high standards expected, significant weaknesses were noted in crew teamwork. During an anticipated transient without scram (ATWS), the crew exceeded the torus heat capacity limit and inadvertently allowed reactor water level to drop below the top of the active fuel due to miscommunications and improper monitoring of plant parameters.

t Attactnent D

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During the ATWS recovery phase, two crews stopped injecting water into the reactor at approximately -70 inches to ensure l the reactor vessel 100 degree per hour cooldown rate was not {

exceeded. Another crew, in a similar situation, continuously.

re-established reactor water level in a controlled manner to

. the normal operating band. The unexpected action of the first'two crews, (stopping all injection into the reactor).

was discussed with operations management who stated that the action was correct because the procedure caution that states, {

" Normal cooldown rates may be exceeded," does not apply during the recovery phase. Further discussions with the INPO Plant Analysis Department revealed that this action has not {

. been observed during other simulator evaluations and needs to be discussed with the Boiling Water Reactor Owners Group (BWROG) as.a generic issue. It was agreed that Peach Bottom.

operations management and INPO Plant Analysis Department would submit this issue to the BWROG for resolution. .

In summary, the performance of the operating shift. crews observed in the simulator was satisfactory. However, additional simulator training for the operating crew that experienced teamwork deficiencies noted above is recommended.

The focus of this training should be on the development of teamwork skills.

IV. Discussion and Recommendations for Improvement Discussion: During a turbine trip with anticipated transient ,

without scram (ATWS), several actions were taken by one j operating crew that do not follow best industry practice. 1 The follgwing observations were noted:

o Although the shift supervisor was aware reactor pressure and suppression pool temperature were approaching the torus heat capacity temperature limit, action to corrset the adverse trend was initiated at the limit and as a -

result the limit was exceeded.

I o While lowering reactor water level to reduce reactor power in accordance with the plant procedure, crew )

members monitored the wide range level instrument that reads downscale at -165 inches. As a result, reactor water level was allowed to decrease to -175 inches or approximately three inches below the top of the active fuel. Crew members were not aware that reactor water level had fallen below the top of the active fuel.

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Attactment D

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o During an ATWS condition, reactor water level is decreased to reduce reactor power level until the average power range meters (APRM)' reach the.downscale alarm ,

setpoint. Crew members were not monitoring tite APRMs, did not' observe when the downscale alarms initiated, and continued to lower reactor water level unnecessarily.

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This resulted in an inadvertent lowering of reactor water. l level below the top of the active fuel.

on several occasions crew members were' shouting to each other and one supervisor cupped his hands to make himself heard.

This resulted in confusion and miscommunication among crew

,, members. For example, drywell pressure was reported as 3.8 psig when the recorder was indicating 2.0 psig, torus water  !

temperature was reported as 169 degrees when it was actually i 149 degrees, and reactor water level was reported as -190 inches when it was 7 tually -90 inches. The shift supervisor uses parameter value, such as these to determine appropriate j operator action in the emergency operating' procedures. i i

Recommendation: Provide additional simulator training for the operating crew that experienced teamwork deficiencies resulting in exceeding the torus heat capacity temperature '

limit, inadvertent lowering of reactor water level below the top of the active fuel, and errors in reporting torus l temperature and reactor water level that were not corrected i I

by other team esmbers. During the training, emphasize the importance of the delineation of crew responsibilities in ,

order to improve' crew performance. J RWL/co? '

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Attachment:

A - Personnel Contacted 1

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Attacknent D 4

-_ _ _ _ _ _ _ _ _ - _ _ - - _ _ - a

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i Trip Report - Special Assistance Visit to Peach Botton Simulator l'

1 Supervisory Personnel Contacted (Also attended Friday briefing)

Name Title John Cotton Operations Superintendent Ernie Till Training Manager Rick Andrews Operations Training Superv.

Al Fulvio Senior System Engineer Denny McClellan Lead Simulator Instructor' Plant Per,sonnel Contacted OPERATIONS Shift Manager - 4 Shift Supervisor - 4 i

, Chief Operator - 4 )

A Control Operator - 4 Shift Technical Advisor - 4 TRAINING l l

Simulator Instructors - 3 l i

Off-Site Dose Calculation Assistant - 4 l

l Attachment D

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Institute of Nuclear Power w -

Operations Surte 1500 11oo Circle 75 Parkway -

Atlanta. Georgia 3o339-3064 '

Telephone 404 953-360o January 31, 1989

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1 Mr. Joseph F. Paquette: Jr.

Chairman, CEO and President Philadelphia Electric Company i

' Correspondence Contrcl Desk Post Office Box 7520 Philad hia, PA 19101 o e--

Dear M Paquette:

This letter forwards the results of INPO's plant evaluation follow-up visit conducted at the Peach Bottom Atomic Power Station from January 16 through 20, 1989. The purpose of the visit was to evaluate progress in key problem areas identified in the September 1988 INPO evaluation report.

The results of the follow-up visit were discussed with the plant staff on January 20, 1989. Written material was not provided by the team at that briefing. In accordance with~ our policy, the team returned to INPO and discussed their thoughts with other experienced personnel and department management before providing these recommendations in writing.

A copy of the team's trip report is snelosed as Attachment A. As noted in the "

SUMMARY

" ser, tion of the report, the team concluded that substantial and adequate oydrt'.I progress had been made in resolving the performance problems noted in the September 1988 evaluation report. The team noted significant improvements in the areas of teamwork, attitude, and professionalism among shift operations crew personnel and in control room discipline.

The trip report identifies several areas needing further improvement, including some, listed below, that need attention prior to startup. We do not intend to evaluate further progress in these areas prior to startup because of the nature of remaining actions. Rather, we request that PECo management assess the following areas and determine that progress is adequate to support i startup.

a. continuation of current efforts to upgrade the implementation of the permit and blocking system, including planned training on use of the system  !

b. strengthening the process for transferring operational information from shift to shift .

Attachment E l

f .

J. F. Paquette, Jr.

Page 2

c. updating piping and instrumentation drawings and 120/208 VAC rower distribution drawings for operator use in equipment isolation. .itid plant operation

d. removal or technical evaluation of temporary electrical attachments to welding receptacles Please call me at 404-980-3200 or Ken Strahm at 404-980-3214 if there are any questions.

Sincerely, L

ek T. Pate President Enclosure (As stated) -

cc/w: Mr. C. A. McNeill, Jr.

Mr. G. A. Hunger, Jr.

Mr. J. F. Franz Attachnent E

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Institute of i w

$ Nuclear Power Operations

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l on January 31,1989 Memorandum K. A. trahm,N To

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From- E. . se[n i sues ct TRIP REPORT - EVALUATION FOLLOW-UP VISIT TO PEACH BOTTOM ATOMIC POWER STATION I. BACKGROUND AND PURPOSE An evaluation follow-up visit to Peach Bottom Atomic Power Station was conducted on January 16-20, 1989. The purpose of the visit was to review the status of the station's corrective action on key aspects of performance discussed in the Executive Summary of the September 1988 INP0 evaluation report of the Peach Bottom l station, as follows:

o Operations management and shift supervision are not sufficiently aggressive in providing needed guidance, holding )

personnel accountable, and ensuring effective action is taken  ;

to correct operational and administrative problems. i l

o The ability of control room operators to readily and accurately i determine plant status is impeded by problems with many of the j

,atiministrative tools provided to control the status of plant systems and components.

1 o Higher standards of performance need to be effectively l established or implemented in several areas.

The team members were as follows:

E. R. Eckstein Team Manager '

W. E. Webster Assistant Team Manager E. P. Shankle Operations Evaluator D. J. Moss Radiological Protection / Industrial Safety Evaluator D. C. Winterich Operating Experience Evaluator II. ON-SITE ACTIVITIES During the visit, five of six operations shift crews were observed conducting normal day shift and backshift operations. In addition, specific maintenance activities and other evolutions were observed.

Attachment A of letter to J. F. Paeuetteo Jr.

' 1 i

J An entrance briefing was conducted during the first morning on site and a final informal briefing for the site vice president and plant ,

manager was conducted on Friday afternoon prior to the team's j departure from the site. Key personnel contacted during this visit I are listed in Attachment A.

1 III. SUMARY The team concl.uded that substantial and adequate overall progress has been made in the problem areas described above but that some additional efforts to implement planned corrective measures are

- needed to ensure the desired level of performance is attained. The following are significant changes that have been achieved since the September 1988 INPO evaluation: 1 1

o enhanced teamwork, attitude, and professionalism among the {

shift operations crews I o improved control room discipline

]

IV. DISCUSSIONS AND RECOMMENDATIONS FOR IMPROVEMENT Several areas were identified where additional emphasis is required.

These are discussed in the Recommendations paragraphs below. Many of these areas were recognized by the station and the additional effort  !

required is already planned. l PERMIT AND BLOCKING PR06B&B A. biscus2 ion 1

Significant improvement was noted in the implementation of the .

permit and blocking system. Further efforts are planned to complete development of the automated permit data base and hard I copy equipment status files for each unit. However, plant )

events related to the application of the permit and blocking system continue to occur. Root causes for these events include improper permit isolation boundaries, incorrect component j identification on a permit, and inadequate understanding of the work to be performed under a permit or of the effect of establishing permit boundaries. For example, in one instance, an inadequate isolation boundary established for work on the generator hydrogen seal oil system resulted in about 100 gallons of lube oil being spilled on the floor of the unit 2 Turbine Building. These events indicate a need for additional attention to detail in the administration of the permit'and blocking system and for increased sensitivity to the gafety-significance of the system.

)

-2 Attachment A of letter to A Fe_Paguetteo Jr.

i Recommendation i

Continue with current efforts to upgrade the implementation and management eversight of the permit.and blocking system including planned training on use of the system. Complete update of the permit manager data base and equipment status files. In addition, continue to investigate plant events related to the permit and blocking activities to determine root causes, identify programmatic weaknesses, and effect necessary corrective actions.- Emphasize to operations personnel the importance of attention to detail in implementing the permit i and blocking program.

TRANSFER 0F OPERATIONAL INFORMATION FRON SHIFT TO SHIFT i

B. Discussion '

In some cases, operational information is not effectively f transferred from shift to shift. For example, after placing )

the reactor building closed cooling water system in service,  !

operations personnel took several days to correctly diagnose a j leak in that system through a leaking relief valve on the i non-regenerative heat exchanger resulting from an unusual system line-up. Resolution of an identical leak a month earlier was fully discussed in the unit reactor operator's log, yet the information exchange from shift to shift was insufficient to preclude recurrence of this abnormal condition. In another case, the unit 2C air compressor was placed in service after having failed its routine air capacity check the previous day.

The shift reactor operator and shift manager were not aware of

,the failure even though it was entered in the unit 2 reactor operator log.

1 Recolonendation  ;

Strengthen the process for transferring information among operations crews. Emphasize to operators the need to thoroughly

, review narrative logs prior to assuming shift duties. Continue recent efforts to upgrade the quality of narrative log entries.

Use other available tools such as turnover sheets, information tags, and the equipment status file to document abnormal system lineups and equipment problems.

PLANT INCIDENT INVESTIGATION PROCES$

C. Discussion Progress has been made in developing a program for thq, identification and investigation of plant incidents in the '

operations aren, but implementation of the program is still in progress. Although the corrective actions resulting from.

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investigations that have been conducted have been assigned to responsible individuals action items do not have due dates, are not being tracked to completion. Incidents outside the operations area are not uniformly investigated.

It is recognized that.a procedure has been drafted to specify when and how investigations of site incidents should be

~

initiated.

Recommendation Issue guidance, applicable to all departments, that establishes:

the requirements for the site event investigation process.

This guidance should encompass the various existing event investigation and reporting systems, and require formal tracking and closure of action items resulting from the investigations.

_ PLANT STATUS CONTROLS .

D. Discussion Progress has been made in improving control ~ room piping and instrumentation drawings as a plant status control tool by the inclusion of valve numbers from the critical equipment monitoring system (CEMS). However, 120/208 VAC power _

distribution drawing errors or omissions create a potential for human performance problems during equipment isolation and troubleshooting. Further action .is also needed to incorporate temporary electrical loads connected to welding receptacles into the station temporary plant alteration (TPA) program to gnsure such loads are properly analyzed for their potential affect on the station's electrical load study.

Recommendation Complete the updating of piping and instrumentation drawings to  !

incorporate CEMS-assigned valve numbers. Complete the planned  !

update of 120/208 VAC power distribution drawings to eliminate known errors. Complete the incorporation of temporary electrical attachments to welding receptacles.into the station ,

TPA program.

CONTAMINATION CONTROL E. Discussion Improved station radiological work practices were noted during-a variety of maintenance and other activities involving potentially contaminated material. Nevertheless, the total number of personnel contaminations occurring'each month has not significantly improved and remains among the highest in the industry. A recent report prepared for management by health

.4.- Attachment A of letter to.

J. F._Paouet_te, Jr.

4 physics personnel ~ indicated that 60 percent of the contaminations were due to improper radiological work practices. Additional actions are needed at both the individual worker level to improve work practices and at the first-line supervisor level to ensure proper practices are being enforced.

Recommendation Continue to implement previously identified corrective actions to reduce personnel contaminations as follows:

o improved supervisory awareness and monitoring training o improved general employee training o escalation of worker counseling to more senior management levels o improved use of work area containments o identification and elimination of contamination sources l

1 1

5 Attachment A of letter to J. F. Paquette. Jr.

TRIP REPORT - FOLLOW-UP VISIT PEACH BOTTOM ATOMIC POWER STATION Key Personnel Contacted C. McNeill Executive VP, Nuclear D. M. Smith Peach Bottom Site VP J. F. Franz Peach Bottom Plant Manager J. Cotton Superintendent, Operations G. Rainey Superintendent, Maintenance D. Lequia Superintendent, Services G. Daebeler Technical Superintendent K. Powers Peach Bottom Project Manager Plant Personnel contacted (number centacted by position) -

Shift manager 5 Shift supervisors 5 ~

Unit reactor operators 10 Non-licensed operators 3

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Attachment A

,, , Attachment 2 to Enclosure 1 Maryland Department of Natural Resources Tidewater Administration Tawn State Office building 580 Taylor Avenue Annapolls Maryland 21401 Willi 4:n Donald Schaefer Torrey C. Brown. M.D.

carmm secreter March 7, 1989 l William F. Kane, Director Division of Reactor Projects United States Nuclear Regulatory Commission

• Region I 475 Allendale Road King of Prussia, PA 19406 Dear Bills on behalf of the State of Maryland I would like to thank you for the opportunity to participate in the Integrated Assessment Team Inspection of the Peach Bottom Atomic Power Station. The l information I gathered and the insights I gained will be very )

important in determining the State's position concerning restart. l I was pleased to have the opportunity to work with your inspection team.

I have enclosed a copy of a memorandum I prepared for the Secretary of Natural Resources concerning the inspection. This memorandum addresses my observations concerning strengths and ,

J weaknesses of PECO's operation of Peach Bottom as observed during l the IATI. As we have discussed, w/ principal outstanding concern j

is with the modifications which have been installed during the current outage and the ability of PECO's quality control ]

inspections installed.

to assure that these modifications wene properly )

My concerns are described in more detail in the memorandum.

I look forward to continuing to work with the NRC and PECO in ensuring addressed.

that the remaining outstanding issues are adequately Sincerely, i

I l Thomas 5. Ma e, Manager Nuclear P Encl.

cc: James C. Linville, NRC  !

Corbin A. McNeill, PECO I

Telephone:

l DNR TTY for Deaf: 301 974 3683 . i i

1 T.. m , g , w w. ....

ETATE OF M A ATLAND T10EWA RA I eT TAwi$ STAf f OFFICE SuiLDING ANNAPOL18 9:4 61 MEMORANDUM March 6, 1989 TO: Torrey C. Brown, M.D.

FROM: Thomas E. Magette ,

SUBJ: NRC Team Inspection of Peach Bottom i 1

l From February 5 through February 17, 1989 the NRC conducted l an Integrated Assessment Team Inspection the Peach l Bottom Atomic Power Station. I participated (IATI) ofin this inspection on behalf of the State. The purpose of this memorandum is to briefly describe my impressions of the inspection. .,

Since being shut down by the NRC 1n 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 adequ.6cy of PECO's corrective actions.

The purpose of the IATI was to review the adotuacy of changes not previously inspected or which require follow-up 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.

I had two objectives during the IATI. The first was the same as the NRC's, corrective actions taken bytoPECO. evaluate the. effectiverftsa of the i.e., '

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 expertise or manpower, we are obviously-interested in the results of their inspection. Furthermore, because they are the regulatory agency which will ultiately 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.

i YTY FOR DEAF = SALTIMeeB ses geOS. WAGMtW4Tett WETWO 58 bad 454

The inspection was conducted by 15 NRC experts from their Region I and headquarters offices. The team reviewed the following areas Station and Corporate Culture operator Resource Development operations site Management Corporate Oversight and Quality Assurance Engineering Surveillance and Maintenance Health Physics i Security The results of the inspection will be described in an- NRC Inspection Report which will be published on March 7, 1989. In general, the inspection team concluded that PECO's corrective actions are in place and being effectively inglemented and that PECO has demonstrated that it is ready and able to operate Peach Bottom safely. PECO's performance as compared to its last j 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  !

restart. ' '

l 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 l 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 by the inspection team.

PECO has significantly improved ' the operation of Peach Bottom. In addition to improving, PECO's performance as measured against an absolute standard for safe operation ' of the plant is a:.so acceptable. PECO has aggressively worked to upgrade performance, programs and hardware for the past year and the results are apparent. There is, nonetheless, still, room for 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. ,

4

. 1 As noted chovo, come wcoknosseo significant onough to require correction prior to restart were also identified. There were also momw poblems identified which will requirw long term solutions. Some of these, e.g.,

career alternatives for licmasedestablishment'of o erators~, will off-shift corrected prior to restart. not be j Those wea nesses I consider to be moat' significant, both restart and long team, are listed in an attachment. l My most serious concerns at present are with plant modifications and associated quality control. I have two concerns relative to modifications: the first is with those modifications made to the plant during the present outage. The second is with PECO's modification process.

Several improperly installed modifications were discovered 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.

been corrected and were inspected during the IATI. Others will .

be corrected prior to restart. Correcting the specific problems identified problem by the audit, however, may not completely address the small sample(the_-ofQuality Assurance audit was based on a relatively j recently installed I believe those problems are of modifications)lem

. i indicative a generic prob with the I modification process.

PECO has conducted an analysis of the root cause of this problem.

the problem. Hopefully, this analysis will also address the scope of The root cause analysis was in.-draf t- form at the conclusion myself or theof NRC.

the IATI, and thus was not . reviewed either 'by I believe this . report should be finalised, reviewed by the NRC and the state, and any necessary corrective actions implemented prior to restart. These steps are necessary.

to ensure that all problems with recently installed modifications l are identified and corrected.  !

In at least one case involving instrument air tubing, there is no improperly installed 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.

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

The second problem concerning modifications involves the process under which the problems occurred. PEC0 has taken several steps to correct these problems on a programmatic basis.

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

i

PECO is also taking other/ steps to improve this process, including supplemental training for quality control inspectora and improved criteria for modification acceptance testa. These are also positive steps. There is already evidence that PECO's i 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 offactiveness of this process.

j Demonstrating the effectiveness of these changes should not f be an impediment to restart because the effectiveness of these 1 changes can be better judged the next time PECO goes into an outage an.d 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.

1 One other area where .PECO still needs to show significant improvement is in the general area of its Quality Assurance j program. The present Qua!Aty Assurance structure was established i during PECO's major nucicer reorganization and" is still I characterized by - some growing pains. It is not yet clear to me that the new program is completely effective. The NRC has also 1 identified this area as needing additional attention. Success in this area will be crucial to PECO's overall racovery 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 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 j remain a few issues that must be addressed prior to restart, no l significant impediments to restart remain. I further ' believe that the recent IATI provided a solid foundation for reaching this conclusion. I with the conclusion of thie 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 Tt.e NRC 8taff must make a final recommendation on restart The NRC must vote on restart e

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' Paul M14ssicot James M. Teitt i

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. STRENGTHS

• INCREASED PROFESSIONALISM IN ALL DEPARTMENTS IMPROVED OPERATOR ATTITUDES

• IMPROVED MANAGEMENT

• INCREASED MANAGEMENT ONSITE PLANT HOUSEKEEPING / REDUCTION OF CONTAMINATED AREAS COMMUNICATION BETWEEN DEPARTMENTS CoiCROL ROOM STAFFING / OPERATOR WORKLOAD

• SHIFT MANAGERS ****** i ELIMINATION OF PREVENTIVE MAINTENANCE BACKLOG FOR UNIT 2 .)

~* '

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

• TRAINING COURSE: ' SUPERVISION OF WORK PRACTICES" i a

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. WEAKNESSES QUALITY CONTROL INSPECTIONS / INSPECTORS /PROCEDURCS

• PROBLEMS WITH MODIFICATIONS INSTALLED MATURITY OF NUCLEAR QUALITY ASSURANCE ORGANIZATION

• LACK OF CLEARLY DEFINED ACCEPTANCE CRITERIA FOR MATS

• OPERATOR MISTRUST OF MANAGEMENT

• REMNANTS OF "OLD PECO"

• ESTABLISHMENT OF OFF-SHIFT CAREER ALTERNATIVE 8 FOR OPERATORS

• - INCONSISTENT TECHNICAL PROFICIENCY AMONG HP TECHS LACK OF OPERATING PLANT EXPERIENCE FOR SOME EP TECHS*

• UNRESOLVED ISSUES FROM NRC ELECTRICAL INSPECTION i

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R p ang'o Attachment 3 to Enclosure ~

g UNITED STATES 1

[ g NUCLEAR REGULATORY COMMISSION

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Ms. Jean S. Ewing MAR 2 019W Peach Bottom Alliance 1

3300 Jourdan Avenue Darlington, Maryland 21034 \

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Dear Ms. Ewing:

j Your letter to Chairman Zech dated March 2,1989, has been refairred to me for reply. In your letter, you expressed your opposition to the restart of the Peach Bottom Atomic Power Station. The bases you provided in support of your opposition are related to recent NRC staff recommendations for Mark I containment improvements and your concern over radioactive waste disposal.

A Comission decision on whether restart of the Peach Bottom station should be authorized has not been made. A Conunission meeting to consider the question is tentatively scheduled for April 1989. The Commission will consider the views of the staff, the licensee, the Advisory Conunittee on Reactor Safeguards s (ACRS), and the conenents provided by members of the public during the various

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public meetings held in the vicinity of the plant in arriving at its decision on the question. 1 1

i The staff's recommendations on Mark I containment improvements are part of the NRC's overall approach to beyond design basis accidents. These recommendations relate to the performance of the containment in response to low probability q events beyond the already existing design basis performance capabilities of j the containment design. The Mark I design meets current regulatory requirements and the Comission has detennined that such a design does not pose '

an undue risk to the public health and safety. Accordingly, this issue need not be resolved prior to a restart decision. The issue is before the Comission and any required modifications at Peach Bottom will be performed in tecordance with their decision.

Regarding your concarn over radioactive waste disposal, we agree that there is a need to resolve the issue. The Congress and the U. S. Department of Energy '

(DOE) have been working on the matter for a number of years. The Nuclear Waste Policy Act of 1982 and the Nuclear Waste Policy Amendments Act of 1987 provide guidance for the work to be done by the DOE and the NRC. The DOE will be responsible for the selection, design, and construction of a nuclear waste repository. The NRC will be responsible for the safety review work. The preliminary design work is currently in progress. Detailed schedules for procedures to construct the repository have been defined. The schedule indicates an NRC decision concerning the Construction Authorization in 1998 and an NRC decision on the Operating License in the year 2003.

Sincerely, j

O omas E. Murley, Director ffice of Nuclear Reactor Regulation J

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