ML20236K436

Forwards Comments Prepared by Peach Bottom Working Group on Commitment to Excellence Plan.Commonwealth Reserves Right to Comment on Any Future Plan Revs

ML20236K436
Person / Time
Site:	Peach Bottom
Issue date:	10/28/1987
From:	Bacas C PENNSYLVANIA, COMMONWEALTH OF
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236K420	List: ML20236K418 ML20236K436
References
NUDOCS 8711090228
Download: ML20236K436 (5)

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Co M M c NWEALTH ' o F. PC N N SYLVANI A-OFricE OF THE GOVERNOR.

HARRISBURG CHARLES BACAS .I secactaav roa Poucy ANo PLANNING

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October 28, 1987 s

i ll William T. Russell Regional' Administrator '

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U.S. NucMar kegulatory Commission .

Region I , -;

631 Park' Avenue -j King of Prussia, Pennsylvania 19406 j

Dear'Mr.- Russell:

b Attached are-~the comments prepared by the Peach' Bottom I Wcrking Group on the Commitment To Excellence Plan; l The Peach Bottom Working Group isLOomprised of f

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representatives'of the Department-of:. Environmental- -

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Resources, Pennsylvania Emergency Management' Agency, Pennsylvania Energy Office, Office'of. General Counsul,:and' the Governor's' Office'of. Policy, Development...These comments

, are transmitted to the NRC,:with the understanding-that Pennsylvania wishes to reserve the'right(to comment'on any

-future Plan revisions. -'.

Sincerely,

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} 2 l thD OW l Charles Bacas l-i 2 Secretary for Policy and Planning i

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q g COMMONWEALTH OF PENNSYLVANIA A Orrict or THc GOVERNOR HARRISBURG l

DATE: October 21, 1987 l

TO: Secretary Charles Bacas I l

FROM: Roy Newsome I The attached comments focus on the Management i i

Analysis Company report (problem root cause assessment),  !

action plan task development, the action plan task list, and i emergency planning procedures. We-wish to go on record as 1 being concerned with those issues raised by the NRC, however, we chose not to duplicate these in our submission.

issues notThe Commonwealth is also concerned about several directly related to the plan. The first concerns the NRC's Systematic Assessment of Licensee Performance (SALP) process. The NRC recently implemented a Diagnostic Team Inspection to confirm weaknesses identified through SALP, yet this process did not identify the operator inattentiveness problem.  !

A second concern relates to the-Irrtitute for Nuclear Power Operators (INPO). This industry group was formed after the Three Mile Island accident to improve efficient operations and reduce event occurrence.- INPO sends evaluation teams to plants every 12 to 18 months, yet this group also failed to identify Peach Bottom problems.

It is imperative tKat'ths'NRC and industry develop adequate inspection procedures to. allow the timely identification of problems in the future. Pennsylvania looks forward to being an active' participant in any such efforts.

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COMMENTS ON 4 PHILADELPHIA ELECTRIC COMPANY's PEACH BOTTOM COMMITMENT;TO-EXCELLENCE ACTION PLAN-m_ i i

1. It appears, there wt.s a significant-omission in'the root.cause 1 analysis conducted by tthe: Management Analysis Company . (MAC) .

They failed to recognize the impact on Peach Bottom. Atomic Power- [i Station's (PBAPS)' Operating Staff and'other resources caused by '

the.startup and operationLof the' Limerick Generation Station '

Unit-1 (LGS-1).- PBAPS was substantially drained :and starved" for~

resources.as a result of the LGS activities.

As a result of-the intense and-protracted' operating license 1 hearings for LGS-1, PECO Corporate Management experienced _ H considerable pressure to develop an experienced,= professional Operating team for LGS-1.

However, in the absence of.a.long term broad based program to .

j hire, train and retain competent operating personnel,-the;needed .1 staff for LGS-1 was not available~when required. .PECO. , d Management dealt with this problem by removing most of.the~best operating personnel from PBAPS and reassigning them to LGS-1 and corporate support pocitions.

Following the reassignment of these key personnel, the.

performance of.the PBAPS Operations Department began a. process ~ 1 of progressive' deterioration. Because1PECO Management's-attention was focused on LGS-1 and relatedLactivities, they. -.

either f ailed to - notice or chose to ignore ,theJdeclining-performance of-the Operations Department'at PBAPS.

i These conditions contributed significantly to the poor ~atti,tude 1 of the management.and personnel at1PBAPS. l d

2. MAC's conclusions with regard to LGS appear.to be based on only nine interviews including the Plant ManagerLand sele ~ctedLSupport Managers. This11s probably toofew data pointseto' support a generalized conclusion of well being. - This analysis may' serve'  ;

to obscure potential problems.

This condition might call into questSon'MAC's' objectivity and~

independence in the conduct of their; inquiries. . Further,1the {

completeness and adequacy /of the Root Cause-Analysis might.be I questioned. ' 1

3. The staffing level for operations personnel,-licensed'and l non-licenseds~should be:such that,theLneed.for regularly.

scheduled' overtime is. minimized or. eliminated. < j l

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The staffing'should include,enough reserve. personnel to allow for-staff training and expected personnel absences during normal; plant operations without the'need--to resort to excessive overtime.

4. ' Periodic procedure review.at PBAPS is currently required ~on a' 1 five' year minimum frequency. The minimum frequency specified11n standard Technical Specifications forfmore modern;plantsLis tLo years. This is illustrative of cnhanced-regulatory policies, which have' evolved since PBAPS was licensed. On a~long' term basis PBAPS:should. identify any'similarcimprovements and include these in a modernized Standard Technical Specification for.the.

station.

5. Ref. 4.5.5-(a) The criterion'for actions which are included in category -1 (CAT-1)scurrently includes.a determination of procedure adequacy '

and procedure upgrade as.necessary. This should include and ensure adequate. retraining'of operating: personnel'on those procedures where revisions and upgrade lare required.

(b) Category-2 (CAT-2) action item (d) should be CAT-1, these policies and practices should not only be reviewed ~but,.also' implemented and their adequacy. verified. .This is necessary to verify that personnel use the policies and practices as the standard way of doing business. This comment-also-applies to CAT-2 action item (e).

6. Ref. 4.9 Was there a feedback provision and how many of 'he't tasks received feedback.

7. Ref. 4.11.6 How much time would these groups devote and how'often wouldithey-meet?

8. Ref. 4.13.2 The Bureau of Radiation Protection would like to attend the Sr. Vice-President's meetings'with theLNRC. The-Commonwealthof Pennsylvania.must be included on'the dis'tribution list:for periodic written reports from the PECO President.

9. (Page 5-4)

In development of open commitments the BWR Owner's. Group input-seems to be conspicuously missing. .

10. Ref. 5.1.3.11 & 12 Most items indicated CAT-2 should be' CAT-1.- The organizational structure for PBAPS accountability?should!be in. place and' demonstrated to be functional and effective prior to restart, l

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11. Ref. 5.1.3.7, 5.1.4.5 The Low Level Radioactive Waste Storage Facility at PBAPS is almost filled to capacity, even though both units have been shut down for the past 6 months, and thus generating minimal amounts ,

of waste. Thus a good working organization which has )

demonstrated positive results should be CAT-1. R

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12. Ref. 5.2.1.5, 5.2.1.4, 5.2.4.4  !

Communication of management expectations is all right, but implementation and adherence should be confirmed prior to restart.

13. Ref. 5.2.5.1 Working relationships between site work groups should be demonstrated to be satisfactory prior to restart. j l

14. Ref. 5.2.7.10, 5.2.8.3 j This should be CAT-1 with regard to operations Supervisors. The j training module should be available and operations supervisors, i as a minimum, should have completed the training prior to startup.

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15. Since PBAPS will h&ve all new shift managers, it is essential that they be familiar with Emergency Planning Procedures especially with regard to Emergency Actions Levels and communications with Pennsylvania Emergency Management Agency (PEMA) and the Bureau of Radiation Protection (BRP). )

16. During the next PBAPS annual retraining cycle, PEMA should be l given the opportunity to provide instructions regarding notification of Escalated Action Levels and Emergency Procedures with regard to off-site response in the event of a nuclear l emergency at the plant.

17. Most of the concerns / questions raised by NRC also concern BRP, but we held those back for fear of redundancy.

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