ML20071A589

Evaluation of Peach Bottom Atomic Power Station,1982, Re Plant Safety,Mgt Sys & Controls & Improvement Items

ML20071A589
Person / Time
Site:	Peach Bottom
Issue date:	12/31/1982
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
To:
Shared Package
ML20071A565	List: ML20071A589
References
NUDOCS 8302240259
Download: ML20071A589 (45)

Text

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Peach Bottom J Atomic Power

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_j EVALUATION of PEACH BOTFOM ATOMIC POWER STATION I

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PEACH BOTTOM (1982)

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SUMMARY

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- INTRODUCTION The Institute of Nuclear . Power Operations (INPO) conducted an evaluation - of Philadelphia Electric Company's (PECO) Peach Bottom Atomic Power Station during m the weeks of September .13 and 20,1982. The station is located on the Susquehanna River near Delta, Pennsylvania, and consists of two 1065 Megawatt (electrical) General Electric boiling water reactor plants. The plants began commercial operation in 7

4 July 1974.

3- PURPOSE AND SCOPE i

T INPO conducted an evaluation of site activities to make an overall determination of

_] plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-m vations, and reviews of documentation.

The INPO evaluation team examined station organization'and administration, oper-

", ations, maintenance, technical support, training and qualification, radiological pro-

{ tection, and chemistry. The team also observed the actual performance of selected

.a evolutions and surveillance testing. Corporate activities were not included in the scope of the evaluation, except as an incidental part of the station evaluation. As a basis for .

1 the evaluation,INPO used performance objectives and criteria relevant to each of the j' areas examined; these were applied and evaluated in light of the experience of team members, INPO's observations, and good practices within the industry.

f INPO's goal is to assist member utilities in achieving the highest standards of

. excellence in nuclear plant operation. Tl:e recommendations in each area are based on best practicer; rather than minimum aceptable standards or requirements.' Accord-ingly, areas where' improvements are recommended are not necessarily indicative of

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unsatisfactory performance.

DETERMINATION e

1 Within the scope of this evaluation, the team determined that the station is being safely ip a operated by well-qualified personnel.

The following beneficial practices and accomplishments were noted:

J Industry operating experience is utilized effectively.

.nnovative preventive maintenance efforts have -improved the performance of j

snubbers, safety relief valves, and major valves in the drywell.

.j Shift technical advisors are used effectively and respected by the operating a organization.

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• The number of continuously activated annunciators is minimized.

Maintenance and ' test personnel demonstrate a high level of experience and m- competence.

Improvements were recommended in a number of areas. The following are considered to be among the most important:

3 J Additional emphasis is needed in control of station chemistry.

e The accumulation of solid low level radwaste and the potential for spread of low level contamination off site should be reduced.

a Stronger management involvement is needed in site training activities and

} interfaces with off-site training activities.

The quality of, use of, and adherence to procedures needs improvement.

,]- Supervisory involvement in daily activities needs improvement.

+w In each of the areas evaluated,INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of

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this evaluation are listed in APPENDIX II.

1 Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to J which they pertain. Particularly ' noteworthy conditions that contribute to ' meeting PERFORMANCE OBJECTIVES are identified as Good Practices. Other findings

• describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It "j - would not be productive to list as Good Practices those things that are commonly done properly in the industry since this would be of no benefit to PECO or to INPO's other

q. member utilities. As a' result, most of the findings highlight conditions that need j-improvement.  ;

The recommendations following each finding are intended to assist the utility in ongoing 7 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.

As a part of the second and succeeding evaluations of each station, the evaluation team '

will follow up on responses to findings in previous reports. Findings with response actions scheduled for ' future completion have been carried forward in APPENDIX I to 3 this report. In areas where additional improvements were needed, a new finding that J. stands on its own merit has been written. Thus, this report stands alone, and reference, to previous evaluation reports should not be necessary.

I The findings listed herein were presented to PECO management at an exit meeting on N. September 23,1982. Findings, recommendations, and responses were reviewed with 3 PECO management on November 3,1982. Responses are considered satisfactory.

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• To follow the timely completion of the improvements included in the responses, INPO  ;

requests a written status by July 15,1983. Additionally, a final update will be requested '

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. Six weeks prior to the next evaluation.

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.The evaluation staff appreciates the cooperation received from alllevels of PECO.

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PHILADELPHIA ELECTRIC COMPANY Response Summary n

L Philadelphia Electric Company- remains dedicated to operating the Peach Bottom

- Atomic Power Station in the safest, most efficient manner possible. Our goal remains

!') the achievement of . the highest standards of excellence in nuclear power plant j- operation. We are proud of our accomplishments in operating the Peach Bottom Atomic Power Station, which the INPO evaluation team has recently verified to be safely

q. operated by well-qualified personnel.

Philadelphia Electric readily accepts the INPO evaluation team's recommendations and q will direct our efforts to further improvement in the areas addressed by the team.

b Numerous activities have already been initiated that address areas identified by the INPO team as requiring improvement. A new building has recently been completed, and p construction has started on an administration building. These additional facilities have j reduced the overcrowding and consolidated the maintenance activities. Conditions will improve further when the new administration building is available.

n l[ A radioactive waste task force has been investigating the radioactive waste areas and has initiated a program to reduce the accumulated low level radioactive waste in the

. plant. A~ formal ALARA program is included in the :: cope of the task force. A

' preventive maintenance program is being implemented that contains a computerized J . history and scheduling system along with tracking and reporting capabilities. This system will provide station management with the information necessary to implement q some of the improvements referenced in the body of this report.

The station procedures are continually being evaluated and upgraded as a direct result of a previous INPO recommendation. Supervisory personnel will place additional l- emphasis on the use of and conformance to procedures.

[ Philadelphia Electric Company recognizes the importance of highly qualified personnel R in the operation of the nuclear power plant 'and is committed to the further I, development of its nuclear training programs to maintain high standards.

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PEACH BOTTOM (1982)

[U s Page 4 M ORGANIZATION AND ADMINISTRATION-e STATION ORGANIZATION AND ADMINISTRATION L' PERFORMANCE OBJECTIVE: Station organization and administrative systems should i ensure effective implementation and control of station activities, e

1 Finding The quality of some procedures needs to be upgraded. Incomplete

?,v (OA.1-1) or inaccurate procedures were identified in several areas.

Recommendation Review plant procedures for adequacy and accuracy. The review should include adequacy of initial conditions and precautions, level of detail, and technical accuracy of information.

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Response A program has been initiated to impress upon employees the importance of identifying procedure deficiencies and following

{u through on initiation of appropriate revisions. A check-off list will be provided to the reviewers of the station procedures. The Plant

• 1 Operations Review Committee (PORC) will intensify its review of 3

the procedures. Chemical analysis procedures will be reviewed for accuracy, adequacy, and completeness by April 1,1983. Others will be reviewed as part of the periodic review process.

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Finding More rigorous adherence to procedures is needed. A number of

. (OA.1-2) instances of failure to follow procedures were observed.

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Recommendation Implement clear standards for procedure adherence. Require L

supervisors to take an active. role. in assessing and improving procedure ' adherence through direct observation of evolutions.

Encourage feedback from procedure users to improve procedures.

h Response A program will be initiated to encourage and reinforce require-l ments to use procedures so that activities are performed correctly.

, and procedure problems are identified and corrected. Station j

management will initiate the program with a letter to the supervi-f sors stressing their responsibilities and cooperation. Additionally, g, training will address this area of responsibility. An Administrative l, Procedure (A-82) is currently being written that will address the W identification and resolution of significant problem areas. It will l provide for the identification of deficiencies in procedure use at

" the senior management level so appropriate corrective measures g' may be taken. These actions will be complete by July 1,1983.

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PEACH BOTTOM (1982)

' Page5 INDUSTRIAL SAFETY i

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PERFORMANCE OBJECTIVE: Station industrial safety programs should achieve a high

e. . degree of personnel safety.

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Finding The industrial safety program does not ensure identification and C (OA.5-1) prompt correction of deficiencies. A number of unidentified safety L deficiencies were noted. Deficiencies identified during accident investigations and the annual fire-safety ins, action are not always

-r corrected in a timely manner.

' j; Recommendation Implement a program to routinely assess industrial safety prac-tices, ensure timely correction of deficiencies, and improve the

. safety awareness of personnel at the plant.

-L Response The Personnel Department - Safety Division, in concert with 7 Electric Production, will develop a program to meet the INPC

- recommendations. This will be completed by March 1,1983.

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" OPERATIONS

%d v OPERATIONS ORGANIZATION AND ADMINISTRATION

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N PERFORMANCE OBJECTIVE: The operations organization and administrative systems should ensure effective control and implementation of department activities.

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L Finding The following Good Practice was noted: The shift technical advi-(^ (OP.1-1) sors (STA) have been integrated into -the shift organization and

=%-nad technical responsibilities in an effectivn manner.

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g The STA responsibilities include the following:

b a. equipment trending and analysis resolution of procedural problems Q M b.

c. troubleshooting of operational problems r

d. interfacing with plant training as a source of operdtional

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e. investigation of nonconformance reports

f. providing technical assistance to the engineer-operation U

b PLANT STATUS CONTROLS n

L PERFORMANCE OBJECTIVE: Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and p equipment sre controlled in a manner that supports safe and reliable operation.

j Finding Shift relief methods for the plant and auxiliary operators need

, (OP.3-1) improvement. T:te shift relief is informal with plant status often

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given from memory. This does not always ensure an adequate exchange of information.

- Recommendation Jmplement shift relief checksheets for plant and auxiliary opera-tors to guide the process. Operators should be instructed in the proper use of relief procedures and the importance of maintaining shift continuity. Management should periodically assess the ade-quacy of the process. INPO's Good Practice OP-201, " Shift Relief and Turnover," could be of assistance in this effort.

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, PEACH BOTTOM (1982) p Page 7 4 Response A shift relief checklist will be' developed for plant and auxiliary I

, operators and will be executed by the outgoing shift, reviewed with

! oncoming shift personnel, and then provided to shift supervision at i ie .the shift meeting. These changes, including management assess-

{"> ment and instruction of operators in proper relief procedures, will be implemented by February 1,1983.

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r-Finding A periodic. review of Maaleing tags is not performed. Some lr- (OP.3-2) improperly placed tags were found in the plant.

h" Recommendation Establish a program to periodically review blocking tags attached to components in the plant. The review should include the

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a. applicability and need for outstanding tagouts

b. a check of condition of posted tags 4

, c. verification of proper attachment of tags and position'of tagged equipment

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7 d. a check for the presence of unauthorized tags

b. Response An audit will be performed of all outstanding accessible blocking tags after each major refueling outage. An audit of blocking tags will be performed by auditors from the methods division at a

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frequency not less than once every six months. These audits will.

address items a. through d. of the recommendation.

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Finding Uncontrolled notes, graphs, portions of precedures, and drawings of p (OP.3-3) a. temporary nature used as operator aids are attached to control i panels at various plant locations. A method is needed for approv-

" ing, reviewing, and updating this temporary information.

Recommendation Review presently posted operator aids for. appropriateness and <

b accuracy. Establish guidelines for the approval, posting, and peri-odic superviscry review of all posted operator aids.

Response 'The shift superintendent will be required to approve all operator aids that are posted for purposes for enhancing operation. Infor-7 mation currently posted will be reviewed by shift supervision and b approved or removed. Posted information will be re-evaluated on a l-i quarterly . basis. This program will be implemented by January 1, 1983.

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Page 8 P OPERATIONS PROCEDURES AND DOCUMENTATION PERFORMANCE OBJECTIVE: Operational procedures and documents should provide

. appropriate direction and should be effectively used to support safe operation of the

'.2 plant.

u f Finding Administrative controls are needed for information tags used in the

( (OP.5-1) plant. Some of these tags are outdated, and others are used improperly to supplement controlled operating procedures.

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Recommendation Implement a program for the use and periodic review of informa-tion tags in the plant. The program should include the following:

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a. guidelines concerning information to be provided on the

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' b. review and authori7ation of tags prior to placement u:

c. proper tag placement in the plant

d. periodic checks to ensure tag information is current Response The shift superintendent will be required to approve all information tags that are posted for purposes of enhancing operation. Tags v currently posted will be reviewed by shift supervision and approved or removed. Posted tags will be re-evaluated on a quarterly basis.

y This program will be implemented by January 1,1983.

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9 OPERATIONS FACILITIES AND EQUIPMENT L

PERFORMANCE OBJECTIVE: Operational facilities and equipment should effectively support plant operation.

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,.. Finding Some plant valves, piping, and components are not labeled with j (OP.6-1) clear, permanent, and distinguishable markings. There is a pro-u gram to accomplish this task, but it is actively pursued only on equipment that is part of the Critical Equipment Monitoring System (CEMS).

!t Recommendation Place increased emphasis on the program for labeling selected r components, valves, and piping. Place priority on safety-related g

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Response Valves will be identified with tags in conjunction with the imple-11 mentation of CEMS. Priority will be as follows:

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a. locked valves

b. valves in drywell(when accessible)

c. one system per month thereafter (ECCS first) c Guidelines will be established to-identify which components (or

[7 assemblies) must be marked. An individual will be assigned to

. (_ coordinate this activity. The equipment list will be used to identify and describe the equipment. Piping will be similarly r~ identified after the valves and components have been completed.

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High radiation doors will be identified with a sign indicating high radiation, the equipment within the room, and the key that controls

.g access. The target date for c0mpletion is January 1,1984.

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!p MAINTENANCE IL

,. , PLANT MATERIAL CONDITION

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) L2 PERFORMANCE OBJECTIVE: The material condition of the plant should be main-tained to support safe and reliable plant operation.

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Finding The material condition of the plant reflects a need for additional ir- (M A.2-1) attention to the identification and correction of deficiencies. A number of material deficiencies identified during the evaluation

}- were not documented in the work control system. Among the 7

deficiencies observed were numerous fluid system leaks, off-scale

. gauges, and inoperable equipment indicating lights.

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Recommendation Implement measures to improve the matarial condition of the plant 1 including identification of observed plant deficiencies, cross refer-w ence of identified deficiencies to Maintenance Request Forms (MRF), and removal of deficiency identification upon completion of e- corrective action. INPO Good Practice MA-301, " Plant Material

l. b, Deficiency Identification," could be of assistance in this effort, Response Station management will direct the operators to be' more responsi-ble for the cleanliness and maintenance of their assigned areas.

s _- The operators will be further trained to identify problem areas and follow up with paperwork-to resolve the problem.' Operators will

-rq also be instructed to tag deficient equipment to indicate corrective h

i action has been initiated. These measures .will be complete by March 1,1983. Plant management will tour the facility more frequently to ensure conformance.

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v r3 PREVENTIVE MAINTENANCE PERFORMANCE OBJECTIVE: The preventive maintenance programs should contribute to optimum performance and reliability of plant equipment.  ;

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Good Practice The following Good Practice was noted: When snubbers are in- l

% (M A.5-1) . spected in accordance with technical specification requirements, 'l b they are refurbished as a preventive maintenance measure. Cor-rective maintenance has been significantly reduced since imple-

~ mentation of the snubber test and refurbishment program in April 1980. For snubbers refurbished under this program, there have been no failures necessitating corrective maintenance or additional surveillance testing. Comprehensive documentation is used to

['; track each snubber from initial installation through its lifetime in L, the plant.

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PEACH BOTTOM (1982) iL Page 11 MAINTENANCE PROCEDURES AND DOCUMENTATION  ;

PERFORMANCE OBJECTIVE: Maintenance procedures should provide appropriate di-

,- - rections for work and should be used to ensure that maintenance is performed safely ,

, L .l I and efficiently.

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x Fin.ing (MA.6-1)

A program is needed to review and control vendor manuals used in site maintenance and testing. Vendor manuals and revisions are not subjected to a technical review and approval process prior to r use in maintenance and testing activities.

1 4' Recommendation Implement a program to ensure that vendor manuals referenced in 7

maintenance and testing procedures for Q-listed systems receive ij an appropriate safety and technical review and are formally

'- approved for use. The. program should also ensure that vendor manuals referenced in maintenance and testing of selected non-Q systems and components are formally reviewed and approved for g;

use.

r Response Those manuals important to maintenance and testing of Q-listed

}. systems will be identified by June 30,1983. These manuals will be prioritized to provide a bagis for review and updating. Philadelphia Electric Company will investigate using the appropriate vendors in -

performing this review. A plan for review and updating Q-listed v system manuals will be developed by September 1,1983.

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MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Facilities and equipment should effectively support the-u performance of maintenance activities.

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Finding Control of measurement and test equipment (M&TE) used by the (MA.8-1) test branch needs improvement. Some M&TE overdue for calibra-tion was stored on the ready-for-use shelves. Test personnel

[- frequently leave M&TE in uncontrolled and unprotected work L locations throughout the plant. M&TE enntrols have been estab-lished for contractors, maintenance, and construction branches; however, they have not been fully implemented for the test branch.

Recommendation Implement controls within the test branch similar to those estab-lished for other branches governing the issue and return, removal from service, and inventory of M&TE.

s Response The test branch has reviewed its measurement and test equipment control program and developed improved practices within present

- space constraints. Final program upgrade will be completed when i

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i [^' the new et.atralized M&TE area becomes available as part of the

L administration building project scheduled for completion November 1,1983.

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u Finding Storage and control of coded and non-coded items in shops and site r1 (M A.8-2) warehouses need improvement. Examples include the following:

b a. The temperature, humidity, and cleanliness of storage n areas are not properly controlled.

I '.i L b. Equipment that has exceeded shelf life is not replaced in a timely manner.

f Q c. "Q" and "non-Q" materials are not adequately segregated.

c Recommendation Implement a materials control program to provide for proper

(; segregation of "Q" and "non-Q" material. Provide storage areas meeting material requirements 4or temperature, humidity, and

- cleanliness. Incorporate all applicable materials and components in L- the shelf-life program. Improve the existing program for reorder-E- ing material to prevent depletion of stock below prescribed levels.

F Response An investigation will be conducted to identify deficiencies in b] warehousing and to determine appropriate corrective action includ-l ing the appropriate use of satellite storerooms. This investigation will be completed by April 1,1983. Appropriate corrective action Hl' will be initiated for identified deficiencies including ' hose refer-enced above.

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L Page 13 p TECHNICAL SUPPORT

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7., OPERATING EXPERIENCE REVIEW PROGRAM L- PERFORMANCE OBJECTIVE: Industrywide and in-house operating experiences should be evaluated and appropriate actions undertaken to improve plant safety and reliability.

SOER STATUS

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The status of Significant Operating Experience Report (SOER) recommendations is as

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Number of Recommendations Action Taken

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87 Satisfactory

c, 44 Not applicable 15 Pending The following recommendations are pending actiom L SOER Number Recommendation Number

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81-2 2 80-6 9 x.- 81-13 6,12 82-2 1, 5, 6 tr: 82-9 1,2,3,4,5,6,7,8 ll .

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An update on the status of each recommendation listed in the "pending action" category

.r shown above is requested in the six-month follow-on response to this report. in

. addition, the status of each immediate action (red tab) SOER recommendation received

{ i subsequent to this evaluation should be included in the six-month follow-on response. A tabular summary, similar to that above, is requested.

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!r, P PLANT MODIFICATIONS F

PERFORMANCE OBJECTIVE: Plant modification programs should ensure proper re-ll_:

view, control, implementation, and completion of plant design changes in a safe and w timely manner.

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[ FindiN A number of jumpers and lifted leads have been installed for long l (TS.4-1) periods of time without being processed as permanent design p changes. It is recognized that modification requests have been j submitted for the resolution of some of these jumpers and lifted leads.

P Recommendation ' Review the jumpers and lifted leads currently installed to deter-W mine which should be processed as permanent design changes.

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,O Establish'a program for a periodic review of jumpers and lifted

b. leads. This program should ensure the removal of jumpers and lifted leads no longer needed and the initiation of modification requests for those that should be permanent modifications.-

k' Response The plant will review all long-term outstanding jumpers and lifted leads by June 30, 1983. Corrective action within the capabilities f;f of the plant staff will be completed by September 1983. Those v jumpers and lifted leads that require engineering modification for resolution will be identified, prioritized, and tracked to comple-tion.

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Finding Jumpers and lifted leads are installed in operating systems without J' (TS.4-2) an iWnt technical design review.

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, Recommendation Perform an independent technical design review of the jumpers and .

lifted leads currently installed. Establish a method for performing an independent technical design review of jumpers and lifted leads

~; prior to or promptly after placing the affected systems back in service.

V Response An . Independent technical design review of currently installed E. jumpers and lifted leads has been completed. The Jumper Log C Procedure (A-42) will be revised by July 1,1983 to . require independent technical design review of jumpers and lifted leads by Jr? the shift techn.ical advisor or other technically qualified personnel.

Q This will normally be acconsplished prior to installation, but in any case within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of installation.

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n PLANT EFFICIENCY AND RRLIABILITY MONITORING in

1. PERFORMANCE OBJECTIVE: Performance monitoring activities should optimize plant

thermal performance and reliability.

r-Finding The following Good Practice was noted: The Acoustic Monitoring (TS.6-1) Program has made a significant contribution to improving plant

[7 reliability. The monitoring of safety relief valve (SRV) pilot valve L condition and the capability to identify valve packing gland leakage on other major valves in the drywell has been effectively utilized for the following:

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a. scheduling SRV maintenance based on pilot valve condi-tion r, b. reducing coolant leakage by permitting selective back-seating of drywell valves while monitoring motor operator

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current to avoid over torquing r-u.

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' TECHNICAL SUPPORT PROCEDURES AND DOCUMENTATION

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.j PERFORMANCE OBJECTIVE: Technical support procedures and documents should L provide appropriate direct',n and should be effectively used to support safe operation of the plant.

4 Finding Site reos drawing changes are not always acted upon in a

- (TS.7-1) timely h. o. Some drawing change requests have been open for more than a year.

_ Recommendation Place increased emphasis on closing out the present open requests for drawing changes. Establish a method for ensuring timely action on drawing change requests in the future.

Response A task force of twelve designers with dedicated supervision has f[ been developed within the engineering design division to process drawing change requests and update as-built drawings in a timely r.~ manner. Single line electrical schematics and piping and instru-ment diagrams are assigned the highest priority because of their importance to plant operations.

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' f- TRAINING AND QUALIFICATION -

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. r, TRAINING ORGANIZATION AND ADMDUSTRATION L

, PERFORMANCE OBJECTIVE: The training organization and administrative systems

- should ensure effective control and implementation of training activities, a

l Finding Training department administrative policies and controls need to (TQ.1-1) be expanded to innprove departmental perforinance. Opportunities l[C' for improvement exist in coordination of vendor activities, de-velopment of instructors, documentation of training activities, and

'- the clarification of training department personnel responsibilities.

I' Recommendation Review the department goals and objectives to identify deficien-cies in administrative policies and controls. Develop and imple-i ment appropriate policies to correct identified deficiencies includ-J ing consideration of the items noted above.

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Response A departmental training procedure describing responsibilities, in-terfaces, control of vendor activities, budgetary responsibilities, instructor development, and training program approval is being developed. A training section organization chart and job :lescrip-tion of key positions will be included. A revision to Procedure A-50 will be made so that the two procedures are supportive.

These activities will be completed by April 1,1983.

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! NON-LICENSED OPERATOR TRAINING AND QUALIFICATION'

!a PERFORMANCE OBJECTIVE: The non-licensed operator training and qualificatica i program should develop and improve the knowledge and skills necessary to perform f assigned job functions.

'- Finding The non-licensed operator on-the-job training program does not (TQ.2-1) cles-ly identify the knowledge and skills necessary for qualifica-

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Recommendation Conduct a review of the on-the-job training program for non-

- licensed operators and implement appropriate measures to improve the effectiveness of the program. The following elements should be included:

a. tasks to be performed, observed, simulated, or discussed

b. identification of individuals or classifications of indi-

" viduals qualified and responsible for conducting on-the-job training

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I c. guidelines for skills and knowledge required on systems,  !

L. components, and procedures r- d. identification of individuals or classifications of indi- -

[* viduals qualified and responsible for conducting final checkouts

e. assurance that the trainee has demonstrated competency in specified tasks prior to job assignment

- [- Response The on-the-job training for non-licensed operatcrs is.being im-L proved in two ways: (1) the skills manual for each position is being revised to be more definitive of the requirements to be met, and m (2) those personnel qualified to conduct on-the-job training and to i sign trainee manuals will be designated. These actions will be complete by June 1,1983.

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LICENSED OPERATOR TRAINING AND QUALIFICATION ,

e PERFORMANCE OBJECTIVE: The licensed operator training and qualification program

" should develop and improve the knowledge and skills necessary to perform assigned job functions.

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Finding Improvements are needed in the administration of the licensed r- (TQ.3-1) operator requalification examinations. Specific areas needing

• , improvement are diversity of examination content, timeliness of administering examinations, and implementation of remedial train-ing.

I- Recommendation Improve the identification and implementation of remedial ttaining and the timeliness of administering requalification examinations.

{ Develop a program to diversify examination content to ensure u objective assessment of operator knowledge.

Response Licensed operator requalification examinations will be prepared so that a diversity of examination content is provided. Examinations will be scheduled and- graded such that required accelerated l_ retraining will be identified in a timely manner. The program will

( be completed before the 1983 requalification testing is initiated.

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II MAINTENANCE PERSONNEL TRAINING AND QUALIFIC'ATION

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PERFORMANCE OBJECTIVE: The maintenance personnel training and qualification ip program should develop and improve the knowledge and skills necessary to perform

( essigned job functions.

Finding Plant-specific training programs are needed for maintenance per-A-

(TQ.5-1) sonnel permanently assigned to Peach Bottom. The generic task-analysis-based programs currently implemented for the various a -

maintenance positions do not cover areas such as overall plant

%. operations and plant-specific syste'ns and equipment.

r- Recommendation Expand the on-site maintenance training programs to include plant-

). "

specific toples such as overall plant operations and plant systems and diuipment.

l INPO documents " Guidelines for Mechanical Maintenance Personnel Qualification" (GPG-05), " Guidelines for 1 Electrical Maintenance Personnel Qualification" (GPG-07), and a " Guidelines for Instrument and Control Technician Qualification" (GPG-08) could be of assistance in this effort.

1 Response The maintenance training program will be expanded to include familiarization training in plant systems and operations for mainte-

- nance personnel permanently assigned to Peach Bottom. This will be done by January 1,1984.

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PEACH BOTTOM (1982)

Page 19 RADIOLOGICAL PROTECTION

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m RADIOLOOICAL PROTECTION ORGANIZATION AND ADMINISTRATION

" PERFORMANCE OBJECTIVE: The organization and administrative systems should ensure effective control and implementation of the radiological protection program.

Finding Station personnel do not always comply with radiological protee-r (RP.1-1) tion procedures and requirements. The following examples were observed:

[.

. a. radiation exposures were not minimized as described by

station procedure HPO-10

b. improper placement of whole-body dosimetry devices U c. failure to read pocket ion chambers in high radiation areas n

d. failure to follow posted instructions for the use of the portal monitor when exiting the station Recommendation Emphasize to all station personnel the necessity for adhering to s radiological protection procedures and requirements. . Require supervisory personnel, especially those in maintenance and opera-P tions, to take an active role in enforcing these requirements. The u need to adhere to proper radiological protection practices should be stressed in station training.

r, Response The plant superintendent has re-emphasized to all site personnel

• the necessity of complying with the radiological protection proce-dures and requirements. Supervisory personnel .. ave been in-

' structed to take a more active role in the enforcement of these

-. nuclear rules and will be held accountable for those personnel reporting to them. Infractions are considered serious and are cause r for immediate application of the company's discipline program.

I This could include denial of access to the power plant until an investigation of the infraction has been concluded and appropriate

... action taken. Additionally, the importance of following the radiological procedures will be more strongly addressed in the

- general employee training program.

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• t PEACH BOTTOM (1982)

Page 20 j Finding Improvements are needed in the review of radiological incidents.

L (RP.1-2) Health Physics Investigation Reports are not routinely reviewed by .

management to determine the cause of problems. Corrective actions often address only the symptoms.

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Recommendation I;nplement a system to ensure that results of IIealth Physics

, Investigation Reports are trended and evaluated by management to prevent recurrence of similar radiologicalincidents. l Response A Corrective Action Program already implemented will investi-gate, evaluate, and trend these incidents and effectively address 1 .. the causes of problems.

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J GENERAL EMPLOYEE TRAINING IN RADIOLOGICAL PROTECTION

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PERFORMANCE OBJECTIVE: General employee training should ensure that plant

- personnel, contractors, and visitors have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

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'" Finding Employees are not required to demonstrate practical abilities such

- (RP.3-1) as donning and removal of protective clothing, proper fMiig techniques, and use of steroff pads, during general employee

- training.

" Recommendation Expand the general employee training program to include demon-stration of practical abilities in radiological protection for all personnel who work in radiologically controlled areas at the .

station.

1. Response The general respiratory training (GRT) program, which is the training program that addresses the use of anti-contamination

f. clothing and the use of respirators, will be expended to include a L practice session demonstrating donning anti-contamination clothing and undressing across step-off pads and multiple step-off pads.

This will be accomplished by June 1,1983. Proper frisking techniques will be demonstrated by all individuals in the general

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employee training program. This will be accomplished by

,. January 1,1983.

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m PEACH BOTTOM (1982)

Page 21

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INTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: Internal radiation exposure controls should minimize l m internal exposures. l 1

Finding Personnel are not always whol; '.x,dy counted at the frequency l specified by station procedures. As a result, the effectiveness of if (RP.5-1)

U the internal exposure control program is not adequately monitored. l Some personnel who perform work in areas with the potential for

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the inhalation of airborne radioactivity have not been whole-body counted for several years.

- Recommendation Ensure that personnel are whole-body counted as required by station procedures.

Response Individuals on site will be classified according to their potential (work locations, functions, etc.) for inhaling airborne contamina-J tion. This classification will then be used to establish frequencies -

for whole-body counting with appropriate shorter intervals assigned

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for high potential work groups. This will be completed by

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, February 1,1983. A printout of the scheduled whole-body counts will be made on an individual basis and monitoried similar to the

., GET/GRT " deficient" list by May 1,1983. Enforcement will also be similar in that the deficient employee's badge will be pulled t after an appropriate grace period.

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Q PERSONNEL DOSIMETRY l

'l PERFORMANCE OBJECTIVE: The personnel dosimetry program should ensure that radiation exposures are accurately determined and recorded.

L Finding The personnel dosimetry program needs to be strengthened to ensure that radiation exposures e9- to individuals as a result

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(RP.8-1) of badge Aw.g evaluations are accurately determined and recorded. In some cases, these radiation exposure determinations

- are not sufficiently documented or contain clerical errors that affect the recorded exposures.

4_ Recommendation Improve the program for determining radiation exposures and documenting the results in these instances.

e

{ Response The responsibility for investigating and determining the proper

! dose to be assigned to an individual has been assigned to qualified

', , . health physics personnel. The evaluation, documentation, and assigned dose are reviewed and approved by the dosimetry group supervisor.

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PEACH BOTTOM (1982)

' - Page 22 i~ RADIOACTIVE CONTAMINATION CONTROL

<L PERFORMANCE OBJECTIVE: Radioactive contamination controls should minimize the m contamination of areas, equipment, and personnel.

- Findirc Personnel monitoring practices for the detection of skin and (RP.9-1) elothing contamination need to be upgraded to prevent the spread .

- of contamination .o clean areas of the plant and off site. On a few occasions, workers were found to have significant levels of con-tamination on their skin or clothing at the security building exit.

[; In addition, workers wiu had not entered posted contaminated areas have been found with skin or clothing centamination.

Recommendation Enforce the existing procedure that requires whole-body monitor-ing at the exit of contaminated areas. In those cases where monitoring cannot be done at the exit of a contaminated area, j ensure that monitoring is accomplished at the closest monitoring

'J station. ,

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Response Permanent friskers have been stationed througout the plant to  :

c faellitate thorough whole-body frisks by all personnel who have exited contaminated areas. Those friskers in high background ,

- areas have been identified to engineering for installation of shield-ing. Until shielding is provided, signs will be posted by January 1,

" 1983 to direct personnel to the nearest frisker in a low background area. The main exit from-the power block will be supplied with new, highly sensitive portal monitors by February 1,1983. GET N will further stress the need for employees to perform the necessary whole-body frisks. The Corrective Action Program will further

- ensure that those who do not respect the program will be dealt with appropriately.

) '

m Finding Personnel dcin and ' clothing contaminations are not always re-(RP.9-2) ported, investigated, and tracked to identify and correct causes.

- Present reporting methods primarily serve to document decontami-nation results.

Recommendation Implement a program that requires notification of health physics personnel of all skin or. clothing contamination incider.ts and

- ensures that records are kept of these incidents. A review of these incidents should be performed by health physics management to

• determine and correct the causes of problems.

Response Personnel found to be contaminated will be required to report to

,- health physics. These contamination incidents will be clocumented and investigated, and the cause determined and corrected.

u PEACH BOTTOM (1982)

Page 23

F Finding Doors at the boundaries of potentially contaminated areas and L (RP.9-3) airborne radioactivity spaces are sometimes left open. The roll-up doors in the radioactive waste building and turbine building were m

open for extended periods of time when the potential existed for

, the release of airborne radioactivity to the environment.

! -. Recommendation Implement a program to ensure that doors at the boundaries of potentially contaminated and airborne radioactivity areas are closed except when required to be open for plant operations.

Response Signs will be located at these doors to prov'de direction that the

[ doors must be kept closed at all times exc ept when necessary for transporting equipment or material. Additionally, no compacting of waste will be permitted when the radwaste building roll-up door is open. These actions will be accomplished by February 1,1983.

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~1 Finding The method used to measure loose surface radioactive contamina-(RP.9-4) tion levels on items to be released off site is not sufficiently sensitive to detect contamination levels at plant limits.

Recommendation Re-evaluate the method used for determiningloose surface radioae-tive contamination levelt on items to be released off site. Based on the results of this evaluation, implement changes to ensure that i_ plant release limits are met.

Response Dise smears instead of large area cloth swipes will be used in making such determinations in the future. This method for determining loose contamination will provide increased sensitivity and ensure that plant release limits are met. This method will be implemented by February 1,-1983.

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PEACH BOTTOM (1982)

Page 24

=

CHEMISTRY

, CHEMISTRY ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: 'Ihe orguization and administrative systems should ensure effective implementation and control of the ehemistry program.

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Finding Chemistry data are not reviewed and evaluated for trends and

,, (CY.1-1) problems in a timely manner by chemistry supervision. Trend plotting of chemistry data is typically done two weeks or longer after it is generated.

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Recommendation Establish requirements for more frequent review and trend evalua-E tion of chemistry data by chemistry supervision.

I Response Chemistry and counting room data are plotted e ch working day.

The plots incorporate action levels to flag data that are outside of lj I desired ranges. Weekly review of the data to determine trends is being performed by chemistry supervisory personnel.

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m CHEMISTRY PERSONNEL QUALIFICATION PERFORMANCE OBJECTIVE: The ehemistry qualification program should ensure that

- chemistry personnel have the knowledge and practical abilities necessary to implement chemistry practices effectively.

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Finding The chemistry technician training program does not ensure an

_; (CY.2-1) adequate understanding of system chemistry parameters. For example, some technicians did not understand the reason for

- chemistry limits or the significance of changing chemistry para-meters.

LJ Recommendation Upgrade the chemistry technician training program to ensure that i ,

technicians have an adequate understanding of system chemistry 1- parameters, l

Response Chemistry technician . training is currently under review to ensure

that technicians are given adequate training in the systems moni-tored and applicable chemistry parameters. Any changes deter-p mined to be required will be incorporated by June 1,1983.

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t PEACH BOTTOM (1982)

- Page 25

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CHEMISTRY CONTROL

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PERFORMANCE OBJECTIVE: Chemistry controls should ensure optimum ehemistry 4 -

conditions during all phases of plant operation.

Finding Several problem areas were noted -in the storage of laboratory (CY.3-1) ehemicals. Examples include the following:

a. Flam.nable chemicals in the chemistry laboratory are not n stored in fireproof storage cabinets.

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b. Quantities of old chemicals that are not used by the

- chemistry group are stored in the chemistry laboratory.

L c. Hazardous chemicals are stored in an area that does not have drains, eye wash, or safety shower.

_; Recommendation Provide improved storage of laboratory chemicals. The following National Fire Protection Association Standards could be of assis-

, tance:

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a. Pamphlet 30, " Flammable Liquid Storage"

b. Pamphlet 49, " Hazardous Chemical Storage"

c. Pamphlet 491m, " Hazardous Chemical Reactions" Response Alllaboratory chemicals stored in the plant have been inventoried, and all flammable and hazardous chemicals are properly stored. A review of the flammable and hazardous chemicals will be con-ducted to determine those that are not needed. Those that are not J needed will then be properly disposed of. 'Ihese actI9ns will be

% completed by November 30,1982. Hazardous chemicals will not be

! stored in areas without eyewashes or safety showers. Chemistry a supervision will perform an inventory and review of storage areas on at least a yearly basis to ensure that the above practices are

- continued.

{ Finding The storage, issue, use, and disposal of trichlorethane is not

t. (CY.3-2) properly controlled. Containers of trichlorethane were observed at several uncontrolled locations in the plant. In addition, controls that had recently been implemented to prevent this chemical from being added to the condensers were not being enforced.

, Recommendation Establish tighter controls on the storage, issue, use, and disposal of '

trichlorethane.

PEACH BOTTOM (1982)

- Page 26 Response A survey of-the plant will be performed to identify and dispose of l

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trichlorethane containers that were in the power block prior to the institution of recent controls. . Controls preventing the addition of

- this chemical to the condenser will be re-emphasized. This will be completed by February 1,1983.

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'M Finding Several on-line ' Amistry monitors are not calibrated using stan-(CY.3-3) dards or are nonfunctional. On-line monitors are not routinely

. used to evaluate plant conditions.

L Recommendation Establish a program for calibration, maintenance, and use of plant

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on-line chemistry monitors. This program should include the repair or replacement of nonfunctional monitors. On-line monitors should be used routinely to evaluate plant conditions.

Response Readily correctable on-line chemistry monitor problems will be corrected and all functional monitors will be incorporated in a calibration program. All other monitors will be modified or

_. replaced and will be included in the calibration program. These

, actions will be completed by June 1,1983, and the on-line chemis-

.J try monitors will be used to evaluate plant conditions.

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." Finding Plant data indicate that copper is being deposited in plant feed-

~ (CY.3-4) water heaters. Similar data for other metals such as iron, nickel, and chromium are not available for evaluation.

.a Recommendation Accurately measure the concentration of copper and other metals p in the condensate, feedwater, and reactor coolant systems. Use L this data to identify problems in system components such as condensate demineralizers and feedwater heaters. Evaluate the possible effects on the plant of high metallic concentrations.

Formulate plans for corrective action as necessary.

Response A study of the metal content in the condensate, feedwater, and

{ reactor coolant systems and its effect on heat cycle and reactor

(. component performance will be undertaken. The results will be used to determine if any changes to equipment operation, mainte-nance, chemistry monitoring, or chemistry treatment is necessary.

A status report on this study will be available by July 1,1983.

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PEACH BOTTOM (1982)

- Page 27

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Finding High oxygen concentrations at the condensate pump discharge (CY.3-5) hdicate excessive air inleakage into Unit 3 "C" cor. denser or "A" condensate pump. This condition has existed since early 1982.

Recommendation Determine the source of air inleakage and take appropriate corree-

" tive actions.

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Response One leak has been identified on Unit 3. Further investigation is

_ planned at low power levels and during future outages to minimize personnel exposure.

r-Finding Some plant systems are routinely operated outside of the vendor-

] (CY.3-6) recomrcended chemistry limits. Examples of these systems and m parameters include the following:

a. auxiliary boiler (sulfite, phosphate)

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b. plant closed cooling water system (sodium nitrite)

c. feedwater system (copper)

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Recommendation Ensure that out-of-specification chemistry conditions are identi-fled and corrected in a timely manner.

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Response A fee &ack mechanism has been developed to initiate re-analysis

-- after chemicals are added. The results of this re-analysis will be used to ensure that cheralstry is maintained within specifications.

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'g Finding There is oil 'nleakage into various plant chilled water systems.

(CY.3-7) Sources have not been determined, nor have plans been formulated to correct this problem.

J Recommendation Determine the sources of oil inleakage into the chilled water systems, and formulate plans for corrective action.

c Response A small leak did exist on the Unit 2 drywell chilled water system during a recent shutdown period. The oil was removed and the leak

, was fixed. Sampling to detect oil is now performed on a weekly basis on all chilled water systems and the results are reported, tracked, and corrective action taken as necessary.

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I PEACH BOTTOM (1982)

L Page 28 F LABORATORY ACTIVITIES PERFORMANCE OBJECTIVE: Laboratory and counting room activities should ensure accurate measuring and wiirg of chemistry parameters.

Finding The quality control program for the chemistry laboratory needs to

.[ (CY.4-1) be improved to ensure that analyses are performed with the i LJ required c% gree of accuracy.

4 Recommendation Upgrade the chemistry quality. control program including consi-l deration of the following items:

.- a. increasing the frequency of split samples

b. ensuring that split sample concentrations are comparable l to routine plant samples l_

. c. using spiked samples to test the performance of analysts

d. using expiration dates on reagents, standards, and cht,mi-l cals l"

e. trent'ng and evaluating quality control data

.- f. performing frequent analyses of standards in conjunction with sample analyses Response Split sample frequency will be increased. Split sample concentra-tions will be comparable to routine plant samples. Controls of

- standard and chemical reagents will be instituted to ensure that those with expired dates are not used. This program will be

!- initiated by June 1,1983.

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The method used for chloride analysis does not have the accuracy Finding)

(CY.4-2 and precision to measure concentrations at limits specified in plant Procedures.

1G Recommendation Evaluate state-of-the-art methods for chloride analysis and in-

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corporate a method that provides the required ae turacy and precision when analydng in the low parts-per-billion ranga.

lr- Response A new specific electrode has been purchased and installed. The

'l. electrode is designed to provide acceptable accuracy and precision

' measurements. Testing is now in progress and a pr'ocedure will be implemented by March 1,1983.

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PEACH BOTTOM (1982)

Page 29

.p Finding A preventive maintenance program is needed for laboratory instru-

.L (CY.4-3) ments. The following are examples of equipment that should be

-included:

a. millivolt meters

b. pH meters

_. c. spectrophotometers

d. atomic absorption spectrophotometer Recommendation Develop and implement a preventive maintenance program for

_ laboratory equipment. This program should incorporate the pre-ventive maintenance sections from instrument technical manuals.

a Response A preventive maintenance program for laboratory instrumentation will be developed and implemented by June 1,1983.

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CHEMICAL AND LABORATORY SAFETY

^

PERFORMANCE OBJECTIVE: Work practices associated with chemistry activities should ensure the safety of personnel.

- Finding Safety equipment such as lab coats, gloves, and safety glasses are (CY.5-1) not routinely used when working with hazardous chemicals.

Recommendation Establish and enforce requirerrants that define the protective -

equipment to be used when v.orking with hazardous chemicals.

l Response The importance of using safety equipment such as lab coats, Ir- gloves, and safety glasses has been impressed upon all laboratory

{ personnel. Additional equipment 'as been provided where appro-priate. Standard laboratory practices will require the use of safety equipment.

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1 F PEACH BOTTOM (1982)

[ APPENDIX I Page1  ;

APPENDIX I-l I Summary of Outstanding Response Action from Previous Evaluation (1980) l

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, ORGANIZATION STRUCTURE 1

F (INPO Procedure OA-102, Revision 2)

2. Finding (Ref. Criterion B)I _ .

1

. f-Position descriptions which define authority, responsibility and account-

! j- '

ability have not been prepared for many positions at the station. There are some position descriptions in existence, but these are based primarily on regulatory requirements rather than on job analyses. It was noted

. [' that a 1980-81 objective for each senior engineer on the plant staff is to L prepare position descriptions through the supervisory engineer level.

This has been initiated.

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Recommendation

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Position descriptions which describe the authority, responsibility and accountability of assigned individuals should be prepared for each

- authorized position at Peach Bottom. INPO is coordinating an industry-wide job analysis project for certain operator, maintenance and techni-i" clan positions and their immediate supervisors.

Response

1

(., Philadelphia Electric Company will prepare position descriptions . to

!L define authority, responsibility, and accountabilf ty for all exempt post-tions, and for other positions not included in the industry project by March 1982. When the results of the industry-wide job analysis are available,' Philadelphia Electric will prepare descriptions for the remain-ing positions at the station. A schedule will be established for these

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- positions when the industry-wide project is completed.

Status

~ Position descriptions are being prepared as described in the response.

All position descriptions will be completed by December 31,1982.

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PERSONNEL QUAIJFICATIONS ,

- (INPO Procedure OA-108, Revision 1) il .

U 1. Finding (Ref. Criterion A) .

Written qualification requirements are not available for many positions.

The qualification requirements which do exist are often based on ,

u regulatory requirements rather than on job analysis of the position.

Recommendatiun

?r Qualification requirements should be developed for each position at the

'L station based on. the authorities, responsibilities and accountabilities assigned to the position. 'This work should be coordinated with the

,- position description effort discussed in the organization structure area.

4

Response

Qualification requirements for all positions will be established as part of n the position description effort discussed in Finding OA-102, Criterion B.

The scheduled completion dates are the same.

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[ PEACH BOTTOM (1982) '

' APPENDIX 1 i

Page 2 Status Position descriptions, including qualification requirements, are being

!p prepared as described in the response. All position descriptions will be

j; completed by December 31,1982.

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< 3. Finding (Ref. Criterion E) . l

- Some personnel assignments are not consistent with the formal training which they receive. ' The auxiliary operator's training is principally (p related to the turbine side systems. He is, however, routinely assigned i g~

eome tasks in the reactor building.

Recommendation

,p Ensure field operators are properly trained for stations to which they are assigned.

({

Response

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Action will be taken to modify the training programs or restrict operator 4 assignments such that the training, qualification and assignments of l

_1 operators are compatible. These actions will be completed by June 1981.

! The action identified in the response is now scheduled to be completed (l '

by July 1,1983. ,

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- TRAINING. RESOURCES

(INPO Procedure TQ-221, Revision 2)

r-b Finding (Ref. Criteria A and D)

There is a shortage of classrooms for the training which is routinely

>,- scheduled. The available classrooms are small, cluttered, and frequently noisy. The heating, ventilation and lighting systems do not support f,

F- efficient instruction. There is also a shortage of adequate training i, support facilities such as offices, reference and study areas and file j space. .

h. ): Recommendation l Training classroom and support facility requirements should be evaluated f in light of current and projected training activities. The plans now in

{ progress for expansion of the administrative building should be reviewed l to ensure that problems identified by the evaluation will be corrected h when the building is completed.

Response

- Plans for expansion of the administration building are in review to ensure

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that facilities required will be adequate to meet the training require-ments. Interim measures, such as increased use of Unit No.1 Adminis-a tration Building for classroom presentations and improvement of the quality of the Unit 1 facility are being implemented. Permanent Unit 1 m training facility improvements and fixtures acquisition will be completed

. . - by September 1981.

" Stattu Action will be complete when the new administration building is com-7- pleted in January 1984. The building is under construction.

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PEACH BOTTOM (1982) 2 APPENDIX I Page 3 4~ PREVENTIVE MAINTENANCE (INPO Procedure MA-402, Revision 1)

.c.

il Pinding (Ref. Criteria A, B & C) _ _

The administrative procedure governing the Preventive Maintenance

_ Program (A-25, Rev.1) does not adequately define the objective, scope ,

and adjustment features of the program. It should be noted that-the

o. . development of a more comprehensive program had previously been

-identified by station maintenance as one of the Peach Bottom goals for

r 1980-81, and a revision to A-25 had been drafted. This revision .was in

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the review and approval process, and thus was not' evaluated to deter-raine if Criteria A, B and C would be met.

r Recommendation ii Management should continue development of a comprehensive program L- description and adminbtrative control procedure for the preventive maintenance program. The content of the program should include the elements of Criteria A, B and C.

o Response Peach Bottom has had an informal preventive maintenance program for e many years, including a formal lubrication program which has been quite successful in avoiding maintenance caused by improper lubrication. As indicated, one of the Peach Bottom goals for 1980-81 is to provide

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_. elements of a complete formal program. The formal preventive mainte-nance program will be fully implemented by December 1982.

- Status The station preventive maintenance program has a Computerized History

'n and Maintenance Planning System (CHAMPS) installed. Tho software is

. presently being verified and data is being loaded into tra Engineering Data Base. Scheduled preventive maintenance, as deterr.sined by equip-ment priorities, is being identified on forms for input into the system.

The system is expected to be functional in January 1984.

f MAINTENANCE PROCEDURES b- (INPO Procedure MA-403, Revision 2)

r- Finding (Ref. Criterion A)

(' While approved procedures exist for most work activities, some main-tenance and instrument and control work is performed using vendor

- manuals that are not approved or controlled. Maintenance engineering personnel were aware of this lack of control and are incorporating instruction manual information into procedures to ensure necessary reviews and controls. No similar effort is underway in the Instrument T' and Control Department. i L Recommendation The Maintenance Engineering Department should complete revisions to ,

controlled procedures to incorporate required vendor manual infor- l mation. The Instrument and Control Department should review work l

' activities and institute review and control of those vendor manuals that g will be used in the performance of safety related or critical balance-of- <

plant work.

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F PEACH BOTTOM (1982)

APPENDIX I Page 4

Response

Maintenance Engineering Department procedure revisions will be com-pleted in a priority sequence based on frequency of usage and reliance on technical manual material. Higher priority revisions will b completed

w by the end of 1981. All necessary revisions will be completed by tha end ofl982.

I&C vendor manuals are updated with new and revised information when it is received. A reference-marked set of updated manuals will be N.. established by May 1981. . A procedure will be implemented to require i use of only this marked set.of manuals or authorized current extracts

-- from these manuals.

Status

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Initial response indicated Maintenance Engineering Department higher priority revisions would be completed by the end of 1981 and that all necessary revisions would be completed by the end of 1982. Higher

" priority precedures are approximately 75 percent complete. It is y expected that all procedures will be completed by December 'el,1983.

MAINTENANCE HISTORY L -- (INPO Procedure MA-405, Revision 2)

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Finding (Ref. Criteria B, C, D, E)

While a variety of records are being retained by various groups within .

the Maintenance Division and the Test Branch, no uniformly applied

- program for recording and evaluating maintenance history inform . tion has been established.

Recommendation A formal maintenance history program should be established and uti'.lzed

to evaluate and trend equipment performance. History information

.J should also be used to adjust the Preventive Maintenance Program.

Response

P~ As indicated in the MA-402 response, a formal _ preventive maintenance program will be fully implemented by December 1982. Elements of this program will address the methods of documentation, traceability, re-trievability and evaluation of equipment maintenance histories. The

b. periodic review and evaluation of maintenance history will integrate and U use inputs such as NPRDS and LER data, the records retention / retrieval system capabilities (currently under development), test data and trending plots. Maintenance history features will be described in the approved preventive maintenance program.

Status

- The station maintenance history program uses the CHAMPS system, which has been installed. The program software is being verified and

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data is being accumulated in the Engineering Data Base. History information on preventive and corrective maintenance activities will be accumulated as . art of the CHAMPS history documentation. It is L.- expected that implementation will be achieved in January 1983.

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PEACH BOTTOM (1982)

APPENDIX I '

Page 5 l MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedura MA-408, Revision 1)

1. Finding (Ref. Criterion C)

- Office and work space for Mechanical Maintenance groups is not

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adequately sized and arranged to accommodate orderly, efficient work and storage. Lack of tool storage space in the mechanical shop, the t scattered location of various craft work areas and overcrowding in the Mechanical Maintenance Foreman's office lead to reduced efficiency and p hinder effective supervision. The need for additional space was already recognized by Maintenance group personnel.

[- Recommendation

_ Overcrowding in the foreman's office should be alleviated as soon as practical. Additional work and storage space should be provided for

- maintenance group activities as part of the planned administration building expansion program.

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Response

As noted, the company has recognized the need for additional work, storage and office space to eliminate overcrowded conditions. Sufficient

- space will be provided in a new administration building. Improved storage and control of tools is a part of this plan. This addition is scheduled for completion by November 1982.

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Status A plan has been developed and construction has started on the new a facilities to improve work, storage, and office spaces. The initial estimate indicated completion of improvements would be November

- 1982. The revised estimated date for completion and occupancy of the new facilities is January 1984.

2. Finding (Ref. Criterion E)

" The mechanical shop and tool storage area on the ground floor of the l Administration Building was not maintained in a clean, orderly manner.

' Good housekeeping practices were not being used.

,_. Recommendation Improved storage facilities should be provided in the shop for frequently p used spare parts. Housekeeping should be improved in the shop and tool stor ge area. The responsibility for shop housekeeping should be

[ specifically assigned.

_ Response The overcrowded shop conditions, dispersed group and supervisory work l- locations complicate good housekeeping practices in the shop and tool storage area. An on-site individual in the Maintenance Division has been

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assigned specific responsibility for this improvement. For the long term, i_ the expansion of the shop facilities by November 1982, along with centralized trade group supervision, will materially assist in maintaining

- proper housekeeping.

Status f A plan has been developed and construction has started on the new l

facilities to improve work, storage, and office spaces. The initial estimate indicated completion of improvements would be November

_- 1982. The revised estimated date for completion and occupancy of the new facilities is January 1984.

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PEACH BOTTOM (1982) ,

4 APPENDIX I Page 6 I ALARA PROGRAM ..

(INFO Procedure RC-502, Revision 1) l Finding (Ref. Criteria A, C, D & E)

- There is no management policy statement regarding the implementation

of ALARA concepts. There is no formal ALARA program approved by

management. Therefore, there is no system for establishing ALARA (u goals or ensuring that all areas of design, operation, maintenance, and training are reviewed for ALARA considerations.

i- Recommendatiori

) The company should establish a highly visible policy showing an intention

• to keep exposures as low as reasonably achievable.

!, Response

. The concept of minimizing radiation exposure has been a part of the

a radiation protection program at Peach Bottom since the beginning of

! operation. The station is in the process of developing a formal program l7 which will address improved ALARA considerations in the operation, lj maintenance and training areas. This formal program will be in effect by January 1982. In addition we will revise the policy statement in the

- company radiation handbook (Refer to Finding OA-102, Criterion D) to reflect Philadelphia Electric Company's commitment to the ALARA concept by December 1981.

Status The formal ALARA program is not fully implemented. This formal

'm program will be in effect by March 1983.

WASTE AND DISCHARGE CONTROL (INPO Procedure RC-505, Revision 2)

Pinding (Ref. Criterion F) v In general, management should strive to improve the overall effective-ness of the radwaste program through continual emphasis on volume

!9 reduction and by ensuring that activities affecting the radwaste program l; _

are coordinated with the various departments involved in radwaste j management.

m Recommendation

, Overall goals for the radwaste program should be established, and the assignment of radwaste responsibilities of the various departments should ensure that the goals will be met.

..; There should be continual emphasis on identifying the sources of 1 radwaste and evaluating how these sources may be eliminated, on identi-

'~ fying the cause for personnel exposures associated with radwaste and on monitoring the overall efficiency of the radwaste program.

l~ Response

! In order to further evaluate sources of, and emphasize reduction of solid l radwaste inputs, an individual will be assigned this responsibility. Re-cent efforts in this area include significant reduction of resins applied to both condensate and Reactor Water Clean Up (RWCU) demineralizers, where water chemistry permits, and development and demonstration of a process to dispose of large volumes of oily liquid radwaste. Newly y ..

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PEACH BOTTOM (1982)

_ APPENDIX I Page 7 implemented procedures and the use of a radwaste quality control inspector in the handling and packaging of solid radwaste will lead to

- improvements in the overall operation. Identification and reduction, where possible, of the causes of personnel exposure related to radwaste

" operations will be incorporated in the formal ALARA program addressed in the response to Finding RC-502, criteria A, C, D and E.

Status

. A committee has been established to evaluate and make recommenda-tions to address the management of radioactive waste at the station. A formal radioactive waste reduction program will be fully implemented by June 1983.

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I PEACH BOTTOM (1982)

APPENDIX II Page1 APPENDIX H Performance Objectives Reviewed-

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ORGANIZATION AND ADMINISTRATION

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OA.1 Station Organization and Administration  !

Station organization and administrative systems should ensure effective imple-

- e mentation and control of station activities. I i

t -- OA.2 Mission, Goals, and Obhetives

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Station mission,' goals, and objectives should be established and progress  ;

a monitored through a formal program. '

r- OA.3.1 Management Assessment  ;

L Management should assess and monitor station activities to ensure effective.

_ performance of all aspects of nuclear plant operation.

-- OA.3.2 Quality Programs 9 Quality programs should ensure the effective performance of activities im-

portant to nuclear safety.

- OA.4 Personnel Plannin:t and Qualification L' Personnel programs should ensure that station positions are filled by individuals

_ with proper job qualifications.

2 OA.5 Industrial Safety l q Station industrial safety programs should achieve a high degree of personnel safety.

- OA.6 Document Control Document control systems should provide correct, readily accessible infor-mation to support station requirements.

OA.7 On-site Nuclear Safety Review Committee Review of station nuclear activities by a knowledgeable interdisciplinary group should ensure achievement of a high degree of nuclear safety.

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APPENDIX II ,

Page 2 t OPERATIONS v

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l OP.1 Operations Organization and Administration.

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The operations organization and administrative systems should ensure effective

- control and implementation of department activities.

OP.2 Conduct of Operations

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Operational activities should be conducted in a manner that achieves safe and 4

a- reliable plant operation.

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• OP.3 Plant Status Controls

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Operational personnel should be cognizant of the status of plant systems and i- equipment under their_ control, and should ensure that systems and equipment J

. are controlled in a manner that supports safe and reliable operation.

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OP.4 Operations Knowledge and Performance

._ Operator knowledge and performance should support safe and reliable plant operation.

OP.5 Operations Procedures and Documentation

- Operational procedures and documents should provide appropriate direction and should be effectively used to support safe operation of the plant.

OP.6 Operations Facilities and Eculpment

.J Operational facilities and equipment should effectively support plant operation.

MAINTENANCE MA.1 Maintenance Organization and Administration s

The maintenance organization and administrative systems should ensure effec-tive control and implementation of department activities.

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MA.2 Plant Material Condition

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The material condition of the plant should be maintained to support safe and reliable plant operation.

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MA.3 Work Control System The control of work should ensure that identified maintenance actions are m properly completed in a safe, timely, and efficient manner.

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I PEACH BOTTOM (1982)

l. APPENDIX II Page 3

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MA.4 Conduct of Maintenance

- Maintenance should be conducted in a manner that ensures effielent and '

effective plant operation. -

MA.5 Preventive Maintenance The preventive maintenance programs should contribute to optimum perform- l ance and reliability of plant equipment.

MA.6 Maintenance Procedures and Documentation

- Maintenance procedures should provide appropriate directions for work and should be used to ensure that maintenance is performed safely and efficiently.  ;

MA.7 Maintenance History  ;

The maintenance history should be used to support maintenance activities and optimize equipment performance.

MA.8 Maintenance Facilities and Equipment  ;

_ Facilities and equipment should effectively support the performance of mainte-nance activities.

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TECHNICAL SUPPORT m TS.1 Technical Support Organization and Administration The technical support organization and administrative systems should ensure effective control and implementation of department activities.

u TS.2 Surveillance Testing Program

- Surveillance inspection and testing activities should provide assurance that equipment important to safe and reliable plant operation will oerform within

, required limits.

TS.3 Operations Experience Review Program -

Industrywide and in-house operating experiences should be' evaluated and appro- i

[" priate actions undertaken to improve plant safety and reliability.

TS.4 Plant Modifications Plant modification programs should ensure proper review, control, implementa-

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tion, and completion of plant design changes in a safe and timely manner.

TS.5 - ' Reactor Engineering On-site reactor engineering activities should erare optimum nuclear reactor q operation without compromising design or safety limits, i

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1 1, . . i r- PEACH BOTTOM (1982) l' '

APPENDIX II Page 4 l

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TS.6 Plant Efficiency and Reliability Monitoring i i

Performance monitoring activities should optimize plant thermal performance

] and reliability.

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TS.7 Technical Support Procedures and Documentation t i F' Technical support procedures and documents should provide appropriate direc-

[ tion and should be effectively used to support safe operation of the plant.

w TRAINING AND QUALIFICATION j TQ.1 Training Organization and Administration

- The training organization and administrative systems should ensure effective control and implementation of training activities.

L TQ.2 Non-Licensed Operator Training and Qualification

'!_ The non-licensed operator training and qualification program should develop and  !

improve the knowledge and skills necessary to perform assigned job functions. l 4

TQ.3 Licensed Operator Training and Qualification ge

-. The licensed operator training and qualification program should develop and I improve the knowledge and skills necessary to perform assigned job functions, i

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TQ.4 Shift Technical Advisor Training and Qualification I

The shift technical advisor training program should develop and improve the i knowledge and skills to perform assigned job functions.

TQ.5 - Maintenance Personnel Training and Qualification The maintenance personnel training and qualification program,should develop  !

and improve the knowledge and skills necessary to perform assigned job

_ . functions.

TQ.6 Technical Training for Managers and Enginecrs The technical training program for engineers and managers should broaden

, . overall knowledge of plant processes and equipment as a supplement to position-specific education and training.

i TQ.7 General Employee Training

_. The general employee training program should develop a broad understanding of employee responsibilities and safe work practices.

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PEACH BOTTOM (1982)

APPENDIX II Page 5 TQ.3 Training Facilities and Equipment

- The training facilities, equipment, and materials should effectively support training activities.

RADIOLOGICAL PROTECTION r RP.1 Radiological Protection Organization and Administration

[' The organization and administ.ative systems should ensure effective control

_ and implementation of the radiological protection program.

RP.2 Radiological Protection Personnel Qualification The radiological protection qualification program should ensure that radiolog-a Ical protection personnel have the knowledge and practical abilities necessary to effectively implement radiological protection practices.

RP.3 General Employee Training In Radiological Protection General employee training should ensure that plant personnel, contractors, and visitors have the knowledge and practical-abilities necessary to effectively

- implement radiological protection practices associated with their work.

RP.4 External Radiation Exposure External radiation exposure controls should minimize personnel radiation ex-

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- posure.

RP.5 Internal Radiation Exposure l Internal radiation exposure controls should minimize internal exposures.

a RP.6 Radioactive Effluents Radioactive effluent controls should minimize radioactive materials released to the environment.

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RP.7 Solid Radioactive Waste Solid radioactive waste controls should minimize the volume of radioactive I waste and ensure safe transportation of radioactive material.

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RP.8 Personnel Dosimetry The personnel dosimetry program should ensure that radiation exposures are

" accurately determined and recorded.

[ RP.9 Radioactive Contamination Control u

-Radioactive contamination controls should minimize the contamination of 1 areas, equipment, and personnel

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I PEACH BOTTOM (1982) l- APPENDIX II Page 6 CHEMETRY CY.1 Chemistry Organization and Administration

_' The organization and administrative systems should ensure effective imple-mentation and control of the chemistry program.

CY.2 Chemistry Personnel Qualification

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The chemistry qualification program should ensure that chemistry personnel have the knowledge and practical abilities necessary to implement chemistry

- practices effectively.

CY.3 Chemistry Control

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Chemistry controls should ensure optimum chemistry conditions during all

_j phases of plant operation.

CY.4 Laboratory Activities l~ Labora, tory and counting room activities should ensure accurate measuring and

,.- reporting of chemistry parameters.

CY.5 Chemical and Laboratory Safety

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Work practices associated with chemistry activities should ensure the safety of personnel.

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