ML20237E267

Forwards Amended SALP Repts 50-277/86-99 & 50-278/86-99 for Period of Feb 1986 - May 1987.Facility Performance Unacceptable in Area of Plant Operations Due to Operator Inattentiveness & Mgt Inability to Take Corrective Actions

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: ML20237E267 ML20237E351
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

SALP PB 86-99 LTR - 0001.0.0

12/05/87

8712280242 871218

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ADOCK 05000277

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Philadelphia Electric Company

2

18 DEC 1987

a

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) .

]

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

J

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

\\

g ?\\g

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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12/ /87

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12/ll/87 12/[7/87 .12/q/87

OFFICIAL RECORD COPY

SALP PB B6-99 LTR - 0002.0.0

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

{

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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PBAPS Site QC Supervisor

A. Donell

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PBAPS Site QA Supervisor

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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PBAPS, Technical Advisor - GE

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

Washington, DC

20555

SUBJECT:

Peach Bottom Atomic Power Station

Systematic Assessment of Licensee

Performance (SALP) for the period

February 1, 1986 through May 31, 1987

Reference: 'SALP Report Nos. 50-277/86-99; 50-278/86-99

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

(

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;

o

conduct an individual operator attitudinal assessment

and counseling program to' screen operators for return

to restart;

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o

establish the Shift Manager position with degreed

engineers holding a senior operator license;

o

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

,

since the end of the assessment period through the use of a

!

new Health Physics Deficiency Report (HPDR) system.

Additional personnel were assigned to HPDR resolution in

June 1987 and the backlog of HPDRs were essentially

eliminated by September 1987.

A revision to the HPDR

procedure to refine the system further is planned to be

.

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

,

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.

.

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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Page 5

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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

,

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

.

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

Page 6

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

,

force.

The review of several NRC I.E.

Information Notices

)

and security reporting requirements was included in this

training.

Operations personnel are now participating in

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.

,

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

)

complete an "LER checklist" when they draft LERs to ensure

i

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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. . . .-.

o-

,,

.

William T. Russell

November 9, 1987

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Page 10

.

licensing issues by providing a more sound basis for

allocating-resources.

Secondly, there is a need to improve

1

feedback to company management of licensing. issues requiring

their attention.- The Licensing Section will take steps to

j

address this need.

l

If you have any' questions, please-do not hesitate to contact

us.

,

i

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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