ML20236H710

Forwards Comments on Facility Commitment to Excellence Action Plan,Published by Util on 870807.Primary Concern to Ensure That Facility Operated in Manner to Protect Health & Safety of Public.Util Should Provide Backup Communications

ML20236H710
Person / Time
Site:	Peach Bottom
Issue date:	10/15/1987
From:	Schaefer W MARYLAND, STATE OF
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236H696	List: ML20236H694 ML20236H710
References
NUDOCS 8711040292
Download: ML20236H710 (9)

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, STATE OF M ARYLAN D OFFICE OF THE GOVERNOR

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• WILLtAM DON ALD SCHAEFER IN REPLY REFER TO:

GOVERNOR l

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October 15, 1987 l

Mr. William T. Russell Regional Administrator United States Nuclear Regulatory Commission Region I 631 Park Avenue .

King of Prussia, PA 19406

Dear Mr. Russell:

I am writing to provide the State of Maryland's initial comments on the Peach Bottom Commitment to Excellence Action Plan, published by the Philadelphia l Electric Company on August 7, 1987. I f

My primary concern is to ensure that Peach Bottom is operated in a manner that assures the protection of the health and safety of the public. The shutdown order in fact requires that PECO provide a plan which' assures that Peach Bottom will be operated safely before proposing that the plant be restarted. While the Action Plan outlines many activities which I believe are necessary for safe operation of the plant. the program described therein is not sufficient to assure safe operation. It therefore does not meet the requirements of the shutdown order.

The Action Plan as presently constituted has several shortcomings:

• It does not properly account for the role of corporate management in the I problems leading to the shutdown.

• It does not properly categorize all tasks which should be addressed prior to restart.

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It does not list taske to correct all problems identified in the MAC Report. l

• It does not adequately describe the correlation between the tasks listed and safe operation of Peach Bottom.

• It does not provide adequate detail for evaluating the tasks listed.

8711040292 871030 PDR ADOCK 05000277 P PDR ,

i ST ATE HOUSE, ANNAPOLIS, MARYLAND 21404 QENERAL INFORMATION (301) 974-3901 TTY FOR DEAF E3ALTIMORE AREA 974 2009 C.C. METRO 565-0450

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- Mr. William T. Russell October .15, 1987 Page 2 i

Because no plan can truly provide assurances that the plant will be operated aafely, I firmly belive that the results of implementing the Action Plan should

{, be evaluated prior to restart. This is especially necessary because past PECO promises to improve the operation of Peach Bottom have proven meaningless. It is this last point which has yet to be fully addressed.

The report prepared by the Management Analysis Company (MAC Report), Appendix A to the Action Plan, contains a strong indictment of the corporate management of the Philadelphia Electric Company concerning the operation of the Peach Bottom Atomic Power Station. The extent to which corporate management is responsible for shortcomings at the site is not adequately addressed in the task list in the Action Plan. In fact, this problem is not even given appropriate weight in the root causes identified in the MAC Report. According to the MAC Report, the fourth root cause of the problems at Peach Bottom is:

"The slowness of corporate management, above the plant level, to recognize the severity of the root causes described above and to insist on stronger, more timely and appropriate corrective actions."

The above statement understates the severity of the problem. The MAC Report itself contains the justification for holding corporate management more directly responsible for these problems than is implied by this root cause. The first three root causes cited in the MAC Report have been problems at Peach Bottom for several years, yet corporate management either failed to recognize chem or failed to correct them. Corporate management has been supplied with extensive evidence, in the form of SALP Reports, INPO Evaluations, NRC l

Inspection Reports, and Notices of Violation, that there were problems at Peach l Bottom requiring immediate high level attention. The " fossil way of business" cited in the MAC Report should never have been tolerated. It should have been insnediately recognized and corrected. And yet the problem has continued to persist. That it was allowed to persist is the fault of corporate management.

The MAC Report calls for a " Comprehensive attitudinal change of all involved personnel, including management. . ." The importance of this attitudinal change at the corporate management level should not be underestimated. Unfortunately, most of those issues which directly relate to corporace management have been placed in Category 2 or 3 in the Action Plan. I do not believe this places appropriate emphasis on these issues. In particular, those tasks involving the trending of plant indicators, communications between corporate mansgement and the site, and manager training should be completed prior to restart.

In addition to improperly categorized tasks, the Action Plan does not contain taske necessary to address certain corporate management shortcomings. It is clear from the MAC Report that communication between corporate management and site management has been woefully inadequate. It is also clear that the roles of corporate and site managers in activities at the site have not been well defined. This has undoubtedly contributed to the lack of improvement at the site following past corporate management commitments to change. The Action Plan does not adequately clarify the roles of Nuclear O pera tions , the Electric

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l Production Department, and site management in operations. How, if at all, have the roles of corporate and site management c. hanged? The question, "Who is in  ;

charge here?" remains unanswered.

Because most of those issues which directly address the role of corporate i management have either not received the appropriate level of commitment or have j been omitted from the Action Plan, it is difficult to accept that the necessary ;

change in attitude on the part of corporate management has occurred. The emphasis on results rather than plans thus becomes even more important.

The Action Plan places a great deal of emphasis on correcting problems with site management. It is clear from the MAC Report that significant changes in site management are in order, and it contains several recommendations aimed at ,

correcting site management deficiencies. It is these recommendations that go j directly to the heart of the operator inattentiveness problem.

Operator inattentiveness became a problem at Peach Bottom because of poor line management and inappropriate personnel policies. It is true that opera t or inattent ueness was a symptom of more fundamental problems within the Philadelphia Electric Company and those fundamental problems must be addressed.

It is equally -important, however, to prescribe solutions that directly treat this symptom. In order to do this, PECO will have to clearly define site management responsibilities and accountabilities, improve worker morale, infuse discipline into Peach Bottom staff, correct inadequate personnel policies, and provide adequate numbers of managers and workers. In order to protect the  !

health and safety of the public, they must be required to complete this mission prior to restart. i l

There are several tasks in the Action Plan designed to accomplish the above ]

objectives. Unfortunately, too many of these tasks are scheduled for j completion, or in some cases implementation, after restart. As is pointed out '

in the MAC Report, it is very difficult to effect attitudinal changes, especially on the scale required at Peach Bottom. Because it is so important to 1 ensure that attitudes have in fact changed, those tasks intended to address the I reasons workers at Peach Bottom were so disillusioned that they severely "

neglected their assigned duties, and the reasons management either tolerated or condoned their behavior, must be completed prior to restart.

1 The following topics should be addressed prior to restart: l

• The Shif t Manager concept j

• Management training

• Management accountability

• Providing adequate numbers of supervisors

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• Providing adequate numbers of operators j

• Reducing one management layer l

• Performance appraisals I

• Discipline and grievance policies

• Acceptability of present shift rotation 1

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. Mr. William'T. Russell-October'15,.1987 4

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With~ the ' exception' of ' management accountability, each of- these1; items is -

accounted , for in the Action ' Plan. In . many . cases, however, tasks should be -

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elevated' from category 2 or 3 to category 1. Those tasks in the. Action Plan designed ~ to address the. . MAC . Report recommendation to ". . . clarify specific a'ecountabilities ~ and . . authority - levels..." are .not adequate. . Additional

! attention should ba given to this' matter.

Within the . Action Plan one' section addresses c PECO's Emergency Preparedne ss ' ~

Frogram. It 'is. significant to note that all but one of . the tasks - identified 'in-this ~ section have been1 placed in category 2 or . 3. This is typical of the priority given .to emergency planning by the: Philadelphia Electric Company.- The

. State of Maryland has identified several shortcomings in PECO 's emergency planning activities,;many of which have. persisted for several years. Virtually.

all off these problems have been repeatedly brought to the attention of PEC0; i

however, solutions have not been forthcoming. Enumerated ' in an attachment are several items which.'should be addressed, and ,in some cases completed, by PECO prior to restart. i I have attached additional specific comments onL the Action Plan, as well as a list. citing Action Plan tasks which are improperly categorized, do not adequately address the appropriate problem, or for which we request additional:

information.

I hope you find these. comments .useful in your ongoing evaluation of the Action.

. Plan. I. will be providing more comments as additional' inf ormation , becomes available. I will also be' interested in -reviewing PECO's response to these and other. comments on the Action Plan. Please continue to direct all information to Mr. Thomas Magette of the Power Plant Reseach Program, who is coordinating the

~ State's review 'of all issues concerning. the shutdown ' of Peach Bottom. . Also please continue -to provide concurrent notification to Dr. Max Eisenberg of the l Maryland Department of the Environment and Mr. David Carroll of my staff.

.Sincerel ~

W, / 1 Governor 1

Attachments-l P

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1[,f ramacumCY PREPARIIMESS CetBERTS

1. Bac'Aup radio communications should be. provided between the Peach ' Bottom Emergency Operations Facility (EOF) and ' the State of Maryland, Harford l County and Cecil County Emergency Operations Centers (E00).

Communication' between these locations is presently accomplished by either -

i the ' prompt notification or conference telephone lines. While these are '

L dedicated telephone Llines, there has - been a problem with at least one . of these ~ lines in . virtually every emergency .. exercise. PECO's own . internal emergency ? planning audit ' identified - this problem as needing attention.

Providing a . backup in the form of radio communications has been identified as a logical solution. This task should be completed prior to restart.

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2.- The -PECO Media Center should be relocated outside the 10 mile plume zone.

The location of the Media . Center h4 s been identified repeatedly by federal-evaluators as- a problem because of its . pronimity to the site. The utility l v -of the Media Center is alrecdy compromi sed by fact that the State .'of

-Pennsylvania does not coordinate its press relations from this site. FECO H

has suggested moving the Media Center to Philadelphia, which would ' result in the State 'of Maryland establishing its Media Center in Pikesville. This .

i would further compromise . the goal of - coordinating public announcements..

PECO should . be required to find a site outside the 10 mile' plume zone. j accepteble to both the States of Maryland and Pennsylvania. : This task should be initiated prior to restart.

- 3. The EOF should be relocated outside the 10 uile plume zone.

The location of the EOF inside the 10 mile plume zone could compromise the health and safety of emergency workers travelling. to the EOF in the event of' an emergency. The present EOF is also inadequate to accomodate the number of occupant s expected , in the event of an emergency. The State of f Maryland is presently required to perform accident assessment in Baltimore because of the shortage of space in the EOF. Emergency. exercises have never i challenged the space in the EOF with the number of personnel that would be j present in the ca se of an emergency pricipally because of the partial participation by federal agencies. This task should be initiated prior to restart.

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4. PECO should provide backup communications for Maryland field teams.

1 No backup method for communication between Maryland field teams and the- 1 Accident As'sessment Center presently exists. In the event of failure of car I radios used by field teams, - the . only alterna tive for communica tion is l commercial telephones. Commercial telephones are not considered a reliabic j method of communica tion during an emergency. The State has repeatedly J raised this problem with PECO but has been unsuccessful in getting them to solve the problem. This task should be completed prior to restart.

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5. PECO should provide dose assessment hardware for use in accident assessment i

• by the State of Maryland.

The State of Maryland and PECO use the same computer model for dose projection. While PECO has cooperated in providing copies of the software, they have been unresponsive to requests for necessary hardware. PECO should j provide hardware capable of operation in the event of power failures. This i task should_be completed prior to restart.

6. PECO should provide an engineering liaison to the Maryland EOC in the event of an emergency and for all exercises.

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In order to enhance ' communication and translate technical jargon' for decision makers in the' State E00, PECO should provide a nuclear engineer.

In response to repeated requests to PECO for such an individual, PECO has claimed insufficient personnel to provide this assistance. This excuse is difficult to accept from a utility operating three nuclear units. Such an arrangement could not possibly be excessively burdensome to PECO. Such an arrangement currently exists with the Baltimore Gas and Electric Company for our emergency planning at the Calvert Cliffs Nuclear Power Plant. This task should be completed prior to restart.

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ADDITIOEAL ColEENTS ON TEE FEACK BOTTON COMEITIENT TO mailmsCE ACTION FMI In'the Action Plan, PECO describes several changes to the operations structure of Peach Bottom. One of these calls for the addition of a new position, the Operations Support Superintendent. This effort to reduce the administrative burden which is placed on the operators seems conceptually sound. It is not clear, however, how PECO intends to staff these positions. If it is their intention to use personnel who were Shift Superintendent s prior to the shutdown, there are several potential problems which should be addressed. These Shift Superintendents were removed from supervisory responsibility because of their role in the operator inattentiveness problem. PECO should address using these individuals to m ervise perconnel which have undergone rehabilitation i training and how thi eculd compromise efforts to effect an attitudinal change at Peach Bottom.

One of the criteria given in the Action Plan for establishing tasks as category 1 is.:

h. increase the number of candidates for licensed operator training.

Because operator overtime has contributed significantly to the problems which led to the shutdown, the number of operators, not just the number of candidates, should be increased prior to restart.

The Action Plan refers to Open Commitments and Open Items which have been developed from several sources. These Open Commitments / Items are being tracked separately and are not described in detail in the Action Plan. This separation prevents evaluation of all activities ongoing at Peach Bottom in support of restart activities. The Action Plan should be revised to incorporate these items.

The task list in the Action Plan is very extensive. What is missing from the Action Plan is a description of the relationship between this long list of specific tasks and the overall goal of assuring that the plant will be operated in a manner that protects. the health and safety of the public. It is apparent that this task list represents PECO's response to the recommendations in the MAC Report. In order to conclude that effectively accomplishing the tasks on this list will in fact result in improved operation, one must assume that the study conducted by MAC identified all problems in the operation of Peach Bottom and that their list of recommendations exhaustively addresses these problems.

This may or may not be the ca se . The Action Plan should contain a section addressing this problem.

In addition to not thoroughly justifying the task list, the Action Plan also fails to provide adequate detail for evaluating each of these tasks. It is important to review how PECO plans to accomplish each of these tasks. The '

Action Plan should be revised to include this information.

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• - etBERTS 05 TIE PEACE BOTTOM CONKITIENT TO EXCELLENG ACTION PLAN TASK LIST j Action Plan Task Comment 5.1.2.3 Should be category 1.

5;1.2.5 Credit should not be given for staff that are not implemented as category 1. ,

5.1.3.6 Should be category 1.

5.1.5.1 Should be category 1.

5.2.1.6 through These tasks are cited as addressing MAC  !

5.2.1.11 recommendation LM ' 6. They do not seen to address the problem of accountabil-ity and authority.

5.2.2 Should be category 1. Because of PECO's poor response to past enforcement actions, process for reviewing performance indicators should- be in place prior to restart.

5.2.3 Should be category 1. Implementing commitments made by corporate ,

management has been a major problem in the pa st. This must be corrected before the Action Plan can be successfully implemented.

5.2.5.2 Should be category 2.

5.2.6.8 through Should be category 1.

5.2.6.10 5.2.7 All tasks in this section should be reviewed with respect to category.

Inadequate management skills have plagued site management and are a fundamental part of the problem at Peach Bottom. Some management training should be completed prior to restart.

5.2.8.1 Should be category 1 l

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• 5.3.1'.19 Should be category 1. PECO should be

: required to complete this activity prior- to , restart because~ it has received inadequate attention in the past. Emergency Plan procedures have been revised as late as the day before exercises causing different ' parties to be using different procedures : during -l the exercise. j i

5.3.9.2 Should be category 1.

5.3.16.1 Should be category 1.

5.3.16.5 Should be category 1.

5.5.2.4 Should be category 1. -

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