IR 05000352/1985099
| ML20205T166 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick, 05000000 |
| Issue date: | 06/06/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML19302B346 | List: |
| References | |
| 50-352-85-99, NUDOCS 8606130067 | |
| Download: ML20205T166 (63) | |
Text
ENCLOSURE 2 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NO. 50-352/85-99 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION ASSES $ MENT PERIOD: DECEMBER 1, 1984 - JANUARY 31, 1986 00ARD MEETING DATE: MARCH 18, 1986 Ge0MjQ[ $
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r SUMMARY OF RESULTS A.
Overall Facility Evaluation Strong plant management and supervision were evident, and visibly involved, in plant operations during the assessment period. Site organizations are well-staffed to support plant operations. Trend analysis of reportable events during the period showed progressive improvement, indicative of licensee efforts to identify and correct problems.
Conduct of the startup test program was excellent, with management and QA/QC involvement instrumental in identifying and resolving tech-nical problems.
Tests were managed sn a safe and deliberate manner, PORC review of test results was thorr ;gh, and administrative holds were appropriately exercised when needed.
.During the assessment period, some p ant problems were caused by inadequate communications between licensed operators and shift super-vision, and between operators and I&C technicians. Although the problems were addressed, recent events indicate that continued management attention to establish clearer direction on independent verification and troubleshooting activities is still needed.
The licensee is very responsive to self identified safety problems and NRC concerns.
The licensee has instituted innovative and diverse corrective measures which include new procedures, design modifications, training initiatives and an Operator Excellence Program.
In the Security area, repeated instances of problems were identified by the NRC. The licensee has not demonstrated sufficient control over the Limerick security contract to obtain a higher standard of performance. Management attention and aggressive involvement are necessary to correct the underlying reasons for these problems since previous efforts appeared to have addressed the symptoms and were not successful in improving security activitie B.
Facility Performance Functional Category Category Recent Area last Period This Period Trend 12/1/83 - 11/30/84 12/1/84 - 1/31/86 A.
Plant Operations
1 Consistent (Note 1)
B.
Radiological
2 (Note 2)
Controls C.
Maintenance Not Evaluated
Consistent D.
Surveillance Not Evaluated
Consistent E.
Emergency
1 Consistent Preparedness F.
Security and
3 Consistent Safeguards G.
Preoperational &
1 (Note 3)
Startup Testing H.
Training & Quali-Not Evaluated
No basis fication Effective-ness I.
Licensing Activities
1 Consistent J.
Assurance of Quality Not Evaluated
No basis Notes:
1.
Assessed as Operational Readiness and Plant Operations last period.
2.
A high level of performance could not be confirmed since Radio-logical Controls Programs have not yet been significantly challenged.
3.
Progressive improvement was noted throughout the assessment perio IV Functional Area Assessments A.
Plant Operations (39%; 1733 hours0.0201 days <br />0.481 hours <br />0.00287 weeks <br />6.594065e-4 months <br />)
During this assessment period, resident and specialist inspections routinely reviewed plant operations, and a team inspection concluded that adequate management controls had been established and implemented regarding plant readiness for full power operation.
Senior resident inspectors from Peach Bottom and Susquehanna observed shift operations during testing and ascension towards full power operation. This is the first assessment of Plant Operations as a separate functional area. Operational Readiness was assessed during the previous two SALPs. A weakness previously noted involved a high incidence of personnel errors.
During the 14-month assessment period, nine unplanned automatic reactor trips occurred.
Four of the trips are attributed to design deficien-cies which had been previously evaluated by the licensee but were not corrected until after the scrams.
Five of the trips are attributable tc operator error. The unplanned trips that occurred early in the assestment period received prompt management attention and an Opera-tional Excellence Program was instituted which has been instrumental in preventing recurrence of the root causes of the earlier scrams.
Operators were instructed to better coordinate instrumentation tag-outs with I&C technical assistance. The licensee also undertook a plant outage, at his own initiative, to perform design modifications to address personnel error related trips.
The licensee effectively performs post-scram reviews, and corrective actions associated with unplanned scrams have been thorough.
In re-sponse to NRC concerns with the cool-down rate and full-in control rod position indications after one scram, additional simulator scen-ario training was devoted to scrams from low decay heat rate condi-tions. Also, a special procedure was developed to address post-scram rod position indication abnormalities as well as the use of various control rod displays and the process computer.
In this case, the licensee made effective use of procedures, training and hardware changes to ensure proper post-scram operator actions.
Licensed control room operators have exhibited a professional, open, cooperative attitude toward NRC concerns, and a dedication to safe plant operation.
Shift turnovers are professionally conducted and involve personnel from chemistry, health physics, I&C and maintenance departments.
Licensee management interfaces with control room super-vision in several daily meetings at which a shift superintendent is present.
Plant problems are promptly relayed to management by the operations shift.
Shift Technical Advisors are an integral part of shift operations in the control room and routinely monitor plant con-ditions, equipment performance, and provide an oversight function for
panel walkdowns and adherence to Technical Specifications.
Licensee initiatives in response to NRC findings this period have included expanding the scope of STA responsibilities aimed towards improve-ments in post-maintenance testing and control room log reviews. The correction of nuisance alarm indicators is systematically tracked and pursued through the corrective maintenance program.
A weakness identified by the NRC early in the assessment period was ineffective control of access to the main control room. The licensee undertook design and administrative actions to reduce control room congestion, and shift supervision has consistently exercised juris-dictional controls to limit noise and unnecessary personnel. The licensee also took steps in response to NRC concerns regarding operator attention to logkeeping, which has since been generally accurate, complete, and receives additional Shift Superintendent and STA review.
Operators have demonstrated an overall sound knowledge of Technical Specifications.
Technical Specification violations have occurred with control room habitability systems, the standby liquid control system outboard isolation valve, and control rod notch testing above the preset level of the RSCS and RWM.
Increased operator recognition of Technical Specification requirements resulting from changing plant conditions is rieeded.
Recurrent violations in this area have not
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been experienced due to the licensee's use of PORC Position Papers, Operator Aids, and augmented operator training in the requalification program.
Overtime guidelines were strictly enforced during the assessment period, even with the increased demands placed upon the operating staff due to startup testing. The licensee consistently provided extra licensed operators to support startup test evolutions. The licensee had 6 full shifts and 61 licensed individuals on site at the end of the assessment period.
Two sets of operator licensing exams were administered during the period. The first set of candidates had a high SR0 Failure rate (4 of 6), with a weakness in the use of TRIP procedures noted during simulator exams.
The second set of candidates were comprised mainly of staff engineers and resulted in a reduced failure rate (2 of 13),
but noted a recurrent weakness in supervising refueling operations.
On shift communication and coordination can be improved. There have been instances of inadequate communication between shift supervision and operators, one resulted in the simultaneous inoperability of two RWCU isolation valves. Operator use of transient (TRIP) procedures during' plant transients has been good with clear communication between shift supervision and licensed operators evident. Operators are pro-ficient in recovery from plant transients such as restarting idle
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recirculation loops. An instance occurred where a vessel level dis-crepancy between wide and narrow range indication at lower pressures during a reactor cooldown caused two scram signals. Operators had been cognizant of the pressure compensation effect but had not com-municated the discrepancy effectively during the reactor cooldown.
A lack of coordination between operators during a startup also caused a scram resulting from the failure to place a feedwater pump. in service as pressure was being increased.
Station organization and reporting chains are effectively structured.
The Superintendent of Operations has staff from the operations, chem-istry and technical engineering groups. The Technical Engineering group includes test engineers who are assigned systems responsibilities, and have been instrumental in supporting plant operations via equipment troubleshooting.
The Station Manager approached operational problems in a conservative fashion, imposing administrative holds on power operation when startup test results were in question such as the feedwater flow transmitter miscalibration, and initiating a plant shutdown when potential safety issues arose such as the crossover piping expansion joint failure and the main turbine control and intercept valve problems.
The Station Manager has been visible in plant, particularly in the control room during major plant problems and test evolutions, and usually leads a daily morning meeting in the control room with principal staff and the Shift Superintendent. The Station Manager has also been respon-sive to NRC initiatives, such as incorporation of certain NRC findings into the licensed operator requalification program, and maintains open and consistent communication with the NRC inspectors and managers from NRR and Region I.
LERs which were reported during the assessment period were subject to an ongoing review as part of NRC inspections for trends and root cause identification.
Causal analysis of LERs during this period is detailed in Section V.D.
A trend was identified early in the assessment period by the NRC with events caused by personnel errors, but had decreased towards the end of the period.
Plant operating experience and
"de-bugging" of procedures are reflected in the lowered incidence of personnel errors.
The plant fire protection systems and equipment were maintained in good working condition.
Plant cleanliness and housekeeping is con-sidered a strength in the licensee's management control system.
Transient combustibles are well controlled. The plant reflects a general absence of standing pools of water, oil or debris beneath equipment, spare or miscellaneous materials stored about the plant or excessive dust on components in pipe tunnels.
Floor coatings in the Reactor Enclosure building had been renewed and significantly improve.
The plant onsite review committee (PORC) was very active in startup testing, operating activities and special issues or station problems.
Frequently convened PORC sessions created a large demand on station management's time, but did not detract from safe plant operation and was not realized at the expense of other programs. The PORC was instrumental in improving the quality of plant operations during the assessment period.
In summary, staffing of licensed operators is at full complement and control room activities are well supported by technical personnel.
Strong management involvement in operations is evident, and resulted in a well-executed startup test program under the constraints of cooling water limitations, condenser leakage problems and licensing restrictions. Station management has been responsive to NRC concerns, performs critical self-evaluations, and solves identified problems with effective corrective action.
2.
Conclusion Rating: Category 1 Trend:
Consistent 3.
Board Recommendations None
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Radiological Controls (10%, 424 hours0.00491 days <br />0.118 hours <br />7.010582e-4 weeks <br />1.61332e-4 months <br />)
1.
Analysis During this assessment period, the licensee's Radiological Controls Program implemented Radiation Work Permit (RWP) procedures and experienced its first major challenges including: contaminated water leakage into Unit 2; a reactor water cleanup system resin spill; an unplanned offsite low level radioactive gaseous release; and, two contaminated Intermediate Range Monitor (IRM) replacements.
There were nine inspections performed in the area of radiological controls during the assessment period including Radiation Protection, Chemistry, Effluent Monitoring, Radioactive Waste Management and Transportation activities.
Routine reviews of this area focused on the licensee's organization, training, reactor shielding verifica-tion start-up testing, and implementation of the ALARA and Respiratory Protection programs. The startup test reviews, through TC-5, verified that adequate shielding was in place based on measurements taken inside and outside of the reactor, turbine and control enclosures.
The licensee was receptive to taking action on all identified fol-low-up items, in particular, for the post accident sampling and moni-toring systems. All identified concerns were corrected by their commitment dates.
The licensee demonstrated a thorough understanding of the technical issues and coordinated their efforts with corporate engineering representatives.
Review of the qualification and training program for radiation pro-tection staff found it to be in various stages of development and implementation. The technician qualification program defines the responsibilities, tasks, and qualification requirements. The licen-see was further refining their program by analyzing the tasks and associated procedures for each level of technician responsibility.
Training interviews by the NRC showed adequate knowledge by the licensee staff.
In addition, all the senior level qualified tech-nicians hired from Peach Bottom Station were tested to determine areas of weakness and establish a remedial training program for these technicians. The licensee is also coordinating an entry-level tech-nician training program with the Peach Bottom Station. The general employee training program for all radiation workers is well developed and implemented.
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1.1 Exposure Control Programs Review of external and internal exposure control programs found that the licensee implements a generally effective, well-defined program. The licensee demonstrated good control of work, assess-ment of whether an RWP would be required, and coordination of RWP procedures with Maintenance Request Forms. As discussed above, the first major challenges to exposure control programs were experienced during the period although none represented significant radiological hazards. Actions to contain contami-nation, investigate additional sources, and implement corrective and preventive actions were timely, thorough and appropriate to the situation. The licensee has experienced problems in effectively communicating radiation protection controls with some work groups.
For example, during the IRM replacement, the pre-job briefing was given to one crew, but not to the next shift's work crew which actually performed the work. On another occasion, a system was breached and the workers were using radia-tion surveys taken prior to the breach. The licensee conducted effective post-job critiques to examine the causal factors and to resolve identified problems.
A comprehensive review of the Respiratory Protection Program was performed during this assessment period after the licensee notified the NRC of their intention to take protection factors when estimating individual internal exposures. The licensee has improved in the respiratory protection area since the previous assessment period.
Engineering controls were avail-able and required to be used, prior to the selection of respira-tory protection, to reduce exposures. The licensee audited con-tractor facilities and procedures, and were performing quality control surveillances for those services being performed by con-tractors. The surveillances and audits found that the licensee was meeting the necessary requirements for protection factors.
1.2 Chemistry and Effluent Monitoring The licensee is meeting Technical Specification requirements for process and effluent sampling and analysis, and for reactor
coolant water quality, and has shown a management commitment to overall program development by developing a chemistry data base on a computerized system to maintain and trend plant system chemistry parameters.
Plant chemistry is organized under the Superintendent of Operations and this reflects the licensee's emphasis on reactor water chemistry and effluent water quality.
The group is managed by a senior chemist and has demonstrated analytical capabilities with, for example, use of an ion chromatograph. Condenser tube problems were experienced during the assessment period, but conductivity levels were closely trended and controlled within Technical Specification limits by good
secondary plant water treatment and radwaste management.
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NRC review of chemical and radiochemical startup testing did not
'l identify any deficiencies or unacceptable conditions. The licensee demonstrated the ability to meet reactor water quality specifications, effluent monitoring system performance as stated in the FSAR, and Technical Specification limits. Minor arith-metical and transcription errors were noted in two startup tests, one of which had been reviewed by the PORC. However, these were isolated instances and did not affect the test results.
Some problems were also identified with regard to sampling arrangements for radioactive waste processing and in sampling techniques in response to unidentified leaks. These problems were resolved when discussed with licensee management.
1.3 Radwaste Management and Transportation During this assessment period, the licensee developed and imple-mented the Radioactive Waste Management and Transportation Pro-gram.
Initial NRC review determined that the program develop-ment was significantly behind in schedule, considering opera-tional demands. The licensee acquired an experienced consultant to supervise all activities in radioactive waste processing operations, using a matrix management concept. A readiness plan was developed and submitted to the NRC in May 1985. NRC concerns were quickly resolved and considerable effort was expended to develop and/or revise appropriate radwaste pro-cedures.
Significant QA involvement during radioactive waste shipments was also noted, and is a management commitment for improving this program area.
Presently, the overall program has significantly improved, procedures are clear and technically accurate, training courses are thorough and well documented, and staffing is almost complete.
2.
Conclusion Rating:
Category 2 Trend:
A high level of performance could not be confirmed since
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radiological controls programs have not yet been signifi-l cantly challenged.
l 3.
Board Recommendations None
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o C.
Maintenance (5%, 214 hours0.00248 days <br />0.0594 hours <br />3.53836e-4 weeks <br />8.1427e-5 months <br />)
1.
Analysis During the assessment period, three inspections were performed which assessed maintenance activities. There was no maintenance functional area assessment in the previous SALP report, although administrative controls for maintenance were evident and found to be effectively implemented during that assessment period.
Inspectors observed maintenance activities on a routine and periodic basis, along with the review of selected design change and modifica-tion activities. Maintenance activities were also assessed by the Operational Readiness Team inspection. Additionally, corrective and preventive maintenance for high-low pressure interface valves in the RHR and core spray systems, and the licensee's commitments to NRC Generic Letter 83-28 with respect to post-maintenance testing were reviewed during this assessment period.
The overall corrective and preventive maintenance programs are func-tioning well. The use of a computerized Maintenance Request Form (MRF) has been a successful management initiative which assures proper equipment control prior to and following maintenance work. Generic problems and evaluations of completed maintenance are tracked through the licensee's computerized history and maintenance planning system (CHAMPS). However, maintenance information and trend analysis of the data was not sufficiently developed during this assessment period to verify the effectiveness of this system. Quality control involvement is evident 'n the maintenance process by the establishment of hold points in maintenance procedures and QC review of all safety-related MRFs. Additional QC involvement was begun for maintenance in non-safety-related areas including fire protection equipment, seismic class IIA hangers, ASME components and non-Q-listed equipment in close proximity to safety-related equipment. MRFs sampled during this assessment period revealed that the licensee is properly classifying maintenance work and that QC is extensively involved in these activ-ities.
A weakness had been identified by the NRC regarding a lack of summary data for licensee management overview of maintenance backlogs, work status and trends. The licensee implemented weekly status reports to senior station staff addressing the backlog of MRFs awaiting an outage.
The reports compare outstanding MRFs between the current and previous week, thus providing trend information. Maintenance activities are discussed in daily meetings held between plant supervision and main-tenance personnel, providing effective communication and coordination of work.
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A review of valve maintenance history and program application concludes that the licensee's preventive maintenance program assures a high reliability for operation and leak tightness for valves forming high-low pressure interfaces in the core spray and RHR systems.
The licensee has effectively used an equipment trouble tag (ETT)
system for in plant identification of equipment deficiencies, and to initiate MRFs for corrective maintenance. -The NRC has identified cases where an ETT had not been removed but the MRF had been closed-out, presenting a potential concern for control of system status.
The licensee has since been successful in requiring removal of the ETT when blocking permits associated with an MRF are cleared.
A backlog of ETTs had developed during startup testing but the licensee has taken steps to identify outstanding maintenance actions and pri-oritize their completion. The failure to control the removal of equipment from service for maintenance has not been a recurrent problem although isolated incidences do occur.
The development of preventive maintenance and spare parts programs are thorough and well thought-out.
Program development incorporated review by vendors, the Architect Engineer, industry sources and the licensee's system startup engineers.
The licensee also developed written engineering bases for Q versus non-Q spare parts determinations.
A repair of the HPCI turbine governor had initially used a Unit 2 replacement part per verbal authorization from a contractor.
In re-sponse to NRC concerns with the environmental qualification for the
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spare part, the original governor was refurbished and re-installed.
The NRC identified a lack of formal controls over environmental qual-ification (EQ) reports on mechanical and electrical equipment, and the licensee subsequently approved new procedures to control the issu-ance and revisions to EQ reports.
EQ requirements such as valve stem packing, seat ring and diaphragm replacements, were added to the CHAMPS computer, in response to NRC concerns, to automatically schedule and track replacement of shelf-life items.
Adequate controls over post-maintenance testing have been established through the use of an operational verification form (OVF), which is reviewed and authorized by shift supervision prior to return of equipment to service. One reportable event was attributable to inadequate post-maintenance testing, involving the inoperability of a fire protection sprinkler system due to valve positions not properly restored after a hydrostatic test by a contractor. An event involving a reactor scram was caused by improperly removing a level transmitter from service to perform maintenance. The licensee now implements an RPS instrument matrix to achieve proper equipment blocking.
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Relative to Generic Letter 83-28, the licensee has also committed to following the INP0 NUTAC Vendor Equipment Technical Information Pro-gram, including expanded participation in NPRDS, procedures to update vendor technical information, and administration controls to evaluate and implement vendor technical bulletins. The licensee's onsite ISEG is actively involved in the program.
Design changes and modifications made to the plant were found to be well-documented and controlled, with appropriate safety evaluations to support the change and updates of design drawings. Modifications performed during April-July 1985, and in response to license commit-ments, were found to be properly implemented. Procedures for post-modification acceptance testing are well defined. Modifications to HPCI and RCIC, the nitrogen vaporization skid, standby liquid control initiation logic and the reactor protection system inverters and power supply breakers have improved plant operation and reliability. The RPS modification should reduce the number of trips caused by power supply problems. Staffing in the site modification group is adequate to support work, and QA/QC are actively involved in the program.
The licensee has maintained an overall high standard of plant house-keeping throughout the assessment period.
The facility is free of debris which could adversely affect equipment maintenance. Adminis-trative controls have been established over temporary scaffolds and work structures in the plant, including a tagging system for marking authorized use along with a pre-installation review by Maintenance Division supervision to assure that scaffolds do not adversely impact equipment access or operation.
2.
Conclusions Rating:
Category 2 Trend:
Consistent 3.
Board Recommendation None
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D.
Surveillance (7%, 330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br />)
1.
Analysis This area received routine assessment and programmatic review by the team inspection for operational readiness.
There was no specific surveillance functional area assessment in the previous SALP report.
Early in the assessment period the licensee experienced a recircula-tion pump speed increase transient associated with instrumentation and control (I&C) personnel troubleshooting the recirculation flow control circuit.
I&C personnel did not obtain control room permission to perform the troubleshooting activities, indicating a lack of admin-istrative controls for the performance of troubleshooting activities.
In response, controls were established and augmented by training, however, additional problems have occurred. One involved the opening of both scram discharge volume drain valves; the other involved a scram on February 10, 1986, where a ground was created in the turbine EHC logic. Management controls on troubleshooting need to be better defined so that shift supervision is aware of activities being performed and proper equipment restoration is documented and independently verified.
The licensee has experienced problems controlling valve positions and system operability during surveillance activities.
The licensee reacts in a conservative and safe fashion to identified plant problems. Two instances of instrument calibration errors were discovered by testing that were promptly resolved with sound technical judgement. Jet pump flow monitors were found to be improperly com-pensated for column temperature and the licensee initiated a shutdown.
Another example involved miscalibrated feedwater flow transmitters which resulted in an underestimate of about 0.6% in computer-calculated core thermal power.
In both cases, the licensee's technical investi-gation and resolution were prompt and accurate.
Licensee management were immediately involved in the problems, and took conservative actions by reducing power and placing an administrative hold on further operations until the problems were clearly understood and safely resolved.
A concern involving mispositioned ESW system valves pointed to inade-quacies with the licensee's practices for determining the required positions of manual valves, since previous lineup verifications for ESW had not identified the incorrect valve position The control of equipment and systems released for testing has been observed to be good.
Inadequate communications and administrative
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control over test groups has, on occasion, led to problems. However, proper equipment blocking procedures and tagging processes have been diligently followed which have since prevented recurrence of these types of events.
Safety system logic initiations have been caused by manipulation of instrumentation valves during surveillance testing.
On two occasions, while backfilling a level indicator reference leg, a technician misaligned an equalizing valve which caused a LPCI injec-tion to the reactor vessel. The licensee added head chambers to level sensing lines which have prevented recurrence of the problem. The return of instrumentation to service caused a reactor scram, and the practice of backfilling and venting instrument sensing lines has since been jurisdictional 1y limited to I&C technicians and formalized by a written procedure. Critical instrument racks in the Reactor Enclosure are clearly marked with caution signs that describe those controls, and there were no scrams or safety system actuations for the remain-der of the period attributed to instrumentation valve manipulations.
The licensee has exhibited good control over surveillance testing by the use of procedures, Operations Aids, effective work group interfaces and coordinated scheduling. A dedicated test engineer schedules and tracks surveillances via the computerized Surveillance Test and Records (STARS) system. A test coordinator performs a daily review of opera-ting logs to assure that all required tests are scheduled and completed.
The licensee's record of adhering to required surveillance schedules has been good and, in those few cases where tests were missed, the licensee promptly identified, corrected and reported the events.
Problem identification and reporting has been stressed by station management and has been effective through the entire assessment period.
The temporary procedure change (TPC) process was identified by the NRC as being potentially prone to errors. The licensee instituted revised management controls over the process, in addition to the existing provisions of two authorizing signatures (one senior-licensed)
and retroactive PORC review within 14 days. These management controls have been effectively implemented in that the frequency and use of TPC's towards the end of the assessment period has decreased from that observed initially when many surveillances were being run for the first time.
The licensee's test engineers assigned to individual systems are cognizant of procedural changes, and procedures have had sufficient review cycle time to result in a well-developed and "de-bugged" set of surveillance procedure Licensee reviews of surveillance test results have identified potential safety problems that were subsequently corrected. One example involved a surveillance test of reactor protection system logic that was suc-cessfully passed but, because of questioning attitude of the shift superintendent, a binding problem was identified with the scram relay auxiliary contacts. The problem was brought to plant management attention, and corrective maintenance and PORC evaluations were promptly instituted in support of continued operation.
Personnel performing surveillance testing were found to be knowledgeable and well-trained regarding test activities, as well as for actions required if abnormal conditions were encountered. Testing was observed to be performed using properly calibrated test equipment and in accordance with approved test procedures.
The licensee has expended considerable efforts da the area of compen-satory fire watches for degraded fire barriers. The frequency of missed watches was reduced towards the end of the assessment period due to the licensee's oversight of the contractor who performs the watches. The licensee assigned a dedicated engineer reporting to the Regulatory Engineer who is responsible for fire surveillances.
In summary, controls over troubleshooting activities have been generally effective, but instances later in the period indicate a need to estab-lish clearer bounds on troubleshooting. Problems were identified with the manner in which independent verification is performed following surveillance testing. Technical investigations regarding I&C problems have been thorough and have been resolved by conservative management decisions. Controls over systems released for testing have, in most cases, been good.
Events involving inadequate communications and I&C valving errors were significantly reduced during the assessment period.
Surveillance test requirements have been met due to well-developed procedures, effective work group interfaces, use of Operator Aids, and coordinated scheduling using a computerized system. The few cases of missed surveillances were isolated instances that were found, reported and effectively corrected.
2.
Conclusion Rating:
Category 2 Trend:
Consistent 3.
Board Recommendations None
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E.
Emergency Preparedness (6%, 281 hours0.00325 days <br />0.0781 hours <br />4.646164e-4 weeks <br />1.069205e-4 months <br />)
1.
Analysis During the assessment period, NRC emergency preparedness activities included observation of the annual emergency preparedness exercise, an accountability and evacuation drill, a routine inspection to follow-up appraisal items, and a special inspection of the security force emergency preparedness (EP) training.
The licensee has recently been very responsive to NRC initiatives.
NRC inspection findings from the prior exercise identified 28 items needing improvement. The April 1985 exercise indicated that none of these items were repeated.
In addition, the scenario was provided to the NRC staff within.the time schedule recommended and was put together in a professional manner.
The training and qualification program was determined to be effective as indicated by the following:
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demonstration during the exercise of timely classification and notification, good command and control in each emergency response facility and prompt protective action recommendations;
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performance-based training given to the security force and demonstrated in the accountability drill, and; implementation of quality assurance / control checks.
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The licensee has, on their own initiative and in response to an alle-gation, made efforts to improve the Security Force EP training program.
The requirement for EP training was prioritized and received management attention.
Some employees, who had been responsible for the previous problems in this area, were terminated. Quality Assur-ance oversight for Security Force EP training was increased.
The results of the accountability drill on July 17, 1985 demons-trated that accountability and evacuation of Limerick Unit 1 personnel and evacuation of Limerick Unit 2 construction personnel can be conducted simultaneously and completed in a timely manner.
In January 1985, two NRC region-based inspectors conducted a follow-up inspection to evaluate progress made on open items identified during the Emergency Preparedness Implementation Appraisal conducted in June 1984.
It was evident during that inspection that the critical areas received an adequate level of management attention.
Outstanding items were resolved satisfactorily.
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Licensee responsiveness was enhanced by the hiring of a full time Emergency Preparedness Coordinator for onsite activities, and the PECO corporate staff also provided support and guidance.
In addition, high level management were present at the licensee's April 1985 exer-cise critique, further supporting the importance of the program. The corporate staff, as well as providing program support, currently main-tains an incident response center to assist during emergencies. This center was recently completed and successfully tested during the PBAPS exercise in the fall of 1985.
The overall emergency preparedness program has shown much improve-ment and was typified by the excellent performance of the licensee's emergency organization during the April 1985 exercise.
In preparation for a full-scale graded exercise in April 1986, the licensee held three practice drill sessions at the end of the assess-ment period, each with full plant staff involvement.
2.
Conclusion
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Rating:
Category 1 Trend: Consistent 3.
Board Recommendations None
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F.
Security and Safeguards (6%; 270 hours0.00313 days <br />0.075 hours <br />4.464286e-4 weeks <br />1.02735e-4 months <br />)
1.
Analysis During the assessment period in addition to routine safeguards in-spections, three special security inspections were conducted.
During February 1985, a routine physical security inspection found several program implementation problems and an enforcement conference resulted. Security force personnel had failed to follow procedures and, as a result, the licensee did not identify a breakdown in the security program. A civil penalty resulted for the licensee's fail-ure to exercise proper sup vision and oversight of the contract security force.
Senior licensee management made a commitment to NRC to pursue more effective oversight of the security force and the overall security program. To achieve this, a Nuclear Security Specialist was added to the licensee's on-site staff and the contractor added a corporate level performance analysis group and an on-site performance analysis group to its staff. These actions provided the licensee with increased control over the security organization, and some stabili-zation of the program resulted.
During the last quarter of the assessment period, the licensee iden-tified several problems with the " split plant barrier" between Unit 1 and the unfinished Unit 2, which included incomplete and degraded vital area barriers. An inspection conducted by the NRC revealed that the licensee took timely and sound compensatory security measures.
However, the length of time over which these problems existed prior to discovery calls into question the adequacy of the barrier installa-tion review and the resources applied thereto.
It also raises ques-tions about the ability of the security staff to provide adequate and continuing review of program implementation. With the resumption of Unit 2 construction, a greater awareness of and dedication to effec-tive implementation of the security program is required.
A high turnover rate in the security force and guards asleep on post or leaving their posts without authorization are evidence of job dissatisfaction and low morale. Yet, there is little evidence that the contractor was doing anything to alleviate these problems. Addi-tionally, the training program does not appear to instill in security force members a strong sense of purpose and an understanding of their role, responsibilities and importance.
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I
Six Security Event Reports were submitted in accordance with 10 CFR 73.73 during this period. Two events concerned the failure to follow procedures by the Central and Secondary Alarm Station operators (CAS/SAS). One event concerned a security force member being found asleep on post and another involved a bomb threat which was determined to be a hoax. Another event involved the finding of vital area barrier deficiencies discussed previously. The remaining report involved a security force member found off his post by the licensee's Station Manager.
In all cases the licensee's compensatory measures were timely and appropriate.
During the period, the licensee submitted changes to its Security Plan, Contingency Plan, and Training and Qualification Plan, under the provisions of 10 CFR 50.54(p).
Some portions of these changes were not considered acceptable as submitted, and required revision.
The licensee made the necessary revisions, resubmitted the changes, and the changes were then found acceptable under 10 CFR 50.54(p).
In general, the changes were of good quality and indicative of a thorough knowledge of NRC security objectives. The licensee's corporate security staff is responsible for ensuring that the Plans are maintained current and for coordinating changes when required. The corporate security staff has been effective in carrying out this responsibility and are always responsive to Region I concerns and comments regarding Plan changes. Communications with Region I staff were initiated by the licensee for more complex changes to preclude any misunderstandings.
All changes were appropriately marked to aid the NRC reviewer, how-ever, the summary which accompanied some of the changes could have been improved by more clearly indicating the overall intent of the change.
The licensee promptly responds to identified violations, however, the nature of the violations identified during this period are indicative of poor performance and suggest that the root cause of problems is either not adequately identified or not aggressively pursued. The licensee did not exercise proper oversight of its security contractor to obtain a satisfactory standard of performance from its personnel.
2.
Conclusions Rating:
Trend: Consistent 3.
Board Recommendation Licensee:
The above noted deficiencies are indicative of weak licensee over-
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sight of contractor activities and a lack of willingness to address long-standing identified program shortcomings. The licensee should i
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assess control and accountability of the contractor in conjunction with a determination of alternative schemes to improve performance in this functional area.
Increase upper level management attention to the security program and plant management oversight and control of the security contractor.
Improve the coordination among groups that support and interact with the security program, especially Unit 2 construction groups. Aggressively pursue with the security contractor means to improve job understanding, satisfaction and morale in order to obtain better performance from the security force members.
NRC:
Continue Supplementary Inspection Program.
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G.
Preoperational and Startup Testing (27%; 1193 hours0.0138 days <br />0.331 hours <br />0.00197 weeks <br />4.539365e-4 months <br />)
1.
Analysis During this assessment period, three inspections of preoperational testing activities and twelve inspections of startup testing activ-ities were performed as well as routine reviews inspector examined these areas on a daily basis.
In the previous assessment, preopera-tional and startup testing were rated jointly as a Category 2 with identified weaknesses in preoperational test control and system turn-over activities.
Startup testing had been noted as a strength.
1.1 Preoperational Test Program I
The preo)erational test program was completed by the licensee during t1e previous assessment period. NRC inspection during this assessment reviewed test results and test exceptions. The licensee satisfactorily completed their review and approval of
,
test results and resolved test exceptions that were identified during the program. Senior management involvement was instru-mental in the successful disposition of those test exceptions.
I As a result, the NRC's preoperational test inspection program was closed during this assessment period.
No outstanding issues remain in this area.
1.2 Startup Test program This assessment period covered startup testing activities from just prior to initial criticality though the completion of the power ascension test program.
Except for a short period of time during a portion of the heatup phase of testing, the licensee implemented an effective startup test program. Problems encountered during startup testing, which were identified as concerns by the NRC early in the program, were promptly corrected by the licensee.
Some examples of these were: (a) congestion and noise levels in the control room existed during the transition from the preoperational phase to the startup phase; (b) during a brief 2-week portion of the heatup phase, the licensee was placing more emphasis on testing rather f
than on review and approval of completed testing and test excep-tions; and (c) a violation resulted for not specifically follow-ing the administrative procedure for processing two test exceptions associated with Level 1 acceptance criteria. The licensee immed-iately placing more emphasis on timely review and approval of test results and test exceptions and continued to do so through-out the rest of the progra W
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Once the initial difficulties were resolved, the licensee's test program was effectively implemented. The licensee was observed to satisfy the FSAR and licensee cemitmeats regarding testing.
The licensee involved the entire station in the startup testing.
In addition to the operating shift and test personnel, staff system engineers observed their system perfortnance when tested and when their respective systems were expected to be challenged such as during the major plant transients of loss of offsite power test and the turbine trip testing.
Senior licensee manage-ment including the Station Manager routinely observed all major test evolutions.
Overall, the conduct of the startup test program was considered to be exemplary, with direct licensee involvement at all levels in test activities and a minimal adverse effect upon plant operations. The power ascension portion of testing from 5 to 100% power was completed in six months with three unplanned scrains at power and a minirnum number of open test exceptions.
Plant operating problems, such as water availability and chemistry were effectively dealt with and had no adverse t'rpact on completion of the startup test program. The program identi-fied technical issues which required a significant level of sophistication and precision to resolve, such as the miscali-bration of the feedwater flow transmitters.
The resolution of this issue indicated in-depth evaluation and attention to detail.
Certain positive attributes were observed and are in part responsible for the successful and safe conduct of the startup test program:
strong senior management involvement in the establishment of the startup testing program and day-to-day activities, conservative approach by management in the resolu-tion of test exceptions and problems, adequato numbers of experienced and trained startup test personnel, administrative and startup test proceduros based on other successful startup programs, extensive planning and coordination of startup acti-vities (this permitted the lic6nsee to perform planned startup test reactor scrams th parallel with reactor shutdowns due to plant problems), use of the plant simulator to test the proce-dure and train personnel, hjgh plant morale, responsive licensee actions to NRC concerns, performance of additional tests when data was not sufficient to justify pruceeding with the program, and feedback to plant procedures regarding lessons learned while performing startup tests. Two attributes warrant special note, QC perfnrmed essentially 100% surveillance of the startup test program and QA audited each of the testing conditions, QA was staffed with knowledgeable personnel who provided prompt feedback to the startup test program personnel to assure that the program was carried out as committed th the FSAR.
The other attribute
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l of note was the comprehensive' PORC review Of the startup test res91ts, The PORC was clearly not a " rubber stamp" review,
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Each test was reviewed and extensive discussion was required to
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satisfy the PORC that the test results and any test exceptions were acceptable and the plant was capab'le of safely proceeding into the next test condition.
-2.
Concloiston Rating:
4-Trend! Continuing improvement was noted throughout the period.
3.
, Board Recommendations
None
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- Training and__ Qualification Effectiv4 ness (NA)
1.
Analysis During the assessment period, training and qualifications effectiveness is being cons (dered as a separate functional arec fc'e the first time.
Training and qualification effectiveness centinues to be an evaluation criterion for each functional area.
The various aspects of this functional area have been considered and discussed as an integral part of the other functional areas and the respective inspection hours have been included in each one. Conse-quently, this discussion is a synopsis of the assessments related to training conducted in other areas.
fraining effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy. This dis-cussion addresses three principal areas:
licensed operat'or training, non-licensed staff training, and the status of INPG traiair,g accreditation.
Weakne.sses were noted during operator licensing exaainations this period which suggest a need for the following, training imptove,ents:
m etaphasis in the utilization of Transient Response (TRIP) procedures; Technical Specification familiarity and use, particularly for sultiple component failures; increased on-the-job training relative to refuel-ing ficor procedures and refueling equipment operation; and, improved communication among the candidates during the simulator portion of the exams. An overall strength noted was candidate familiarity with equipment and component location.
Linerick's full-scope simulator is performing well a6d is proving a valuable asset for transient training.
The performance of licensed operators in the control room has been observed by the NRC to be good. Operators are proficient in recotiering from plant transients and have demonstrated an overall sound knowledge of Technical Specifications as evidenced by daily discussions with NRC inspectors'. As discussed in Section IV.G, the licensee used the Limerick simulator as an effe.ctive tool to prepare personnel for plant response to several of the major test evolutions during the power ascension program. As a result, operating shifts were observed to be well prepared at; ring the conduct of testing such as initial turbine roll and the loss-of pnwer test. Also, operators effectively used the Transient Response (TRIP) procedures during major testing such as the turbine trips; this was notable in light of the weakness identified during the first set of license exams given. Another example of trairling which enhanced the startup test program was the licensee's pre-test practice at the remote shutdown panel for the shutdown test from outside of the control room.
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STA training was observed during the end of the assessment period to be in conformance with license commitments. The utilization of presently qualified STAS has been effective and is discussed in Section IV.A.
The current shift complement of STAS have had the benefit of startup test experience and are therefore knowledgeable of plant transient response.
Staffing levels in the fire protection area were acceptable, and a full time Fire Protection Assistant is assigned on-site.
Fire pro-
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tection staff were experienced and knowledgeable of program require-ments.
Fire brigade training deficiencies were observed in that some fire brigade members missed quarterly meetings and semi-annual drills.
The licensee took short-term and long-term corrective action to improve the effectiveness of the training program.
The general training program for all radiation workers is well developed and implemented.
The licensee further refined the radiation protection technician training program by analyzing the tasks and associated procedures for each level of technician responsibility. Training interviews by the NRC showed adequate knowledge by the staff.
In addition, the licensee tested all senior-level technicians to determine areas of weakness and establish a remedial training program. A train-ing program for entry-level Assistant Technicians is being coordinated with the Peach Bottom Station.
A measure of the effectiveness of the licensee's training programs was the relatively few number of unplanned scrams and unnecessary challenges to safety systems attributable to personnel errors during the assessment period.
Five of the nine unplanned scrams were caused by personnel error.
I&C technician errors in the last 8 months of the assessment period were reduced by a factor of 20 as compared with the first 6 months of the period. The frequency of such events (analyzed in Section V.D) was significantly reduced towards the end of the assessment period due, in part, to licensee management initia-tives in training.
Training interviews by the NRC indicated that Maintenance Division craftsmen and supervisors receive training on administrative controls applicable to their job classifications, as well as technical training on selected nuclear maintenance topics. Maintenance engineering personnel pursue a self guided indoctrination and familiarization program. Onsite on-the-job training is provided for junior technical assistants in the maintenance department.
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As no,ted in Section IV.F, the security force training program does not appear to instill in force members a strong sense of purpose and an understanding of their role and responsibilities.
The licensee's training programs are currently being audited for accreditation by INPO.
Self-evaluations for all ten INPO accredi-tation areas have been submitted to INP0; INP0 audits of the program were begun in February 1986; and accreditation is scheduled for com-pletion during the next SALP assessment period.
2.
Conclusion:
Rating: 2 Trend: No basis 3.
Board Recommendations NRC:
None Licensee:
Provide refresher training in refueling operations and core alter-ations in preparation for first refueling outage. Also, consider emphasis of training in Technical Specification LCOs, where multiple component failures may affect more than one system LC0.
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I.
Licensing Ahtivities (NA)
1.
Analysis This assessment is based on the licensee's performance in support of major licensing activities such as the Atomic Safety and Licensing Board and Appeal Board activities, issuance of Safety Evaluation Report Supplement (SSER), Nos. 4, 5, and 6, issuance of the full power license and execution of the startup testing program.
The licensee has sustained the high level of performance in the Licensing area that has been attained in the past two assessments with only one major exception.
Specifically, this was in the hand-ling of the safety-p'arameter display sy~ stem (SPDS) issue as discussed below. However, the licensee's response to staff inquiries in this area was vigorous and technically sound.
Overall, the licensee's strong points.are their approach to problems from a safety standpoint, responsiveness to'NRC concerns, the quali-fications,end depth of staffing and the reporting of events. Senior management control is widely apparent and particularly when a response to a problem is called for. An area where some weakness
< may be apparent is in the continual maintenance of a broad oversight to ensure that forthcoming schedular requirements, such as needed requests for amendment of the license and the requirements of con-ditions to the license, are recognized and responded to in a timely manner.
The licensee's management has been directly involved in almost all of the major licensing activities addressed in this assessment.
Notable examples of the positive contributions resulting from this involvement as well as several areas which could have benefited from additional attention are discussed below.
Management involvement in responding to the issues identified in SSERs 4, 5, and 6 was very productive in that for the majority of these issues the initial response was sufficient and further requests for information were not required to support the resolution of the issues.
For one of these issues, the potential effects of tornado missiles on the ultimate heat sink, the Senior Vice President for Nuclear Power was directly involved in the staff's visit to the plant c
site. Although several other issues, namely the Independent Design Verification Program (IDVP) item concerning pipe break jet impinge-
-ment loads and the remote shutdown, systems issues, required several l
in,toration.s, these issues were. responded to vigorously over a short period of' time upon clarification of the problem areas.
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Ma'nagement involvement in the preparation of the first two requests for amendments to the license was apparent in that the Superintendent for Plant Operations participated in a meeting to ensure that these applications contained adequate bases for the determinations on significant hazards and environmental impacts. Management involvement was also particularly evident in the development and implementation of a corrective action program in response to the relatively high rate of reportable events experienced in the Trly months of licensed operation. Management's control of communications was demonstrated while undergoing several changes in management responsibilities in response to the transition in plant status fron a construction /
preoperational state to an operating state. Coordination of the communications between the NRR staff and personnel in the Electrical Production Department, the Engineering and Research Department, which previously had the sole responsibility for dealing with NRR on issues, and the plant staff has been accomplished in a very effective manner.
The licensee's high degree of responsiveness to staff initiatives continued to be demonstrated for all but a few instances (e.g.,
remote shutdown system and safety parameter display system issues)
wherein the licensee allowed a substantial fraction of the available time for dealing with an issue to expire before submitting the response to the staff. The licensee has supported meetings and dis-cussions with the staff as frequently and in as much depth as required to reach a technically sound and thorough resolution. This was demon-strated on the tornado missile effects, IDVP, preservice inspection, remote shutdown, Detailed Control Room Design Review (DCRDR) and SPDS issues.
The licensee characteristically meets prior schedule commitments or advises the staff of the need and the basis for read-justment of schedules.
The licensee's corporate staff has continued to be maintained at a stable level. This is due in part to the relatively low turnover of key technical and managerial personnel, many of whom have been with the licensee throughout much of the Unit 1 operating licensing review.
The corporate staff level in Philadelphia has been ample to meet the needs of the licensing activities during this period. This has been demonstrated in meetings and discussions with the NRC staff wherein the staffing level has in virtually every instance been adequate to meet the objectives of the meeting.
Finally, as discussed in Section IV.A (Operations) and analyzed in Section V.C (LER supporting data), there have been 143 events reported during the assessment period. A relatively large (58) number of these events occurred during the first 2-3 months of the period, and 37 occurred prior to achieving initial criticality on December 21, 1984.
During the remaining-12 months of the assessment period, the rate at i
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which events were reported decreased significantly, due in part to the licensee's energetic corrective action programs. The frequency-of events was reduced by about two-thirds, and is considered to be average for.a new plant.
2.
Conclusions Rating: Category 1 Trend: Consistent 3.
Board Recommendations NRC: Conduct a meeting with the licensee to discuss ongoing PRA activities.
Licensee: None
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Assurance of Quality (NA)
1.
Analysis
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During the assessment period, the assurance of quality is being con-sidered as a separate functional area for the first time. Management involvement and control in assuring quality continues to be one evalu-ation criterion for each functional area.
The various aspects of quality assurance program requirements have been considered and discussed as an integral part of each functional area and the respective inspection hours are included in each one.
Consequently, this discussion is a synopsis of the assessments con-ducted in those areas.
As discussed in Section IV.G, QA/QC coverage of the startup test pro-gram was extensive. QA audits were performed for each test condition and QC personnel performed 100% surveillance of startup testing. The application of QA/QC in startup activities significantly contributed to the high degree of success of the test program.
QA and QC involvement is evident in the areas of modification and design activities, and radwaste shipping and transportation. Also, QC is directly incorporated into maintenance job classification and planning processes. QC review and approval is required for all safety-related maintenance actions for fire protection, ASME and se-lected non-safety work, and QC mandatory witness points are included as part of maintenance activities. The licensee utilizes Quality Assurance as part of corrective actions for NRC findings as evidenced by the audit of PORC-reviewed procedures for proper inter-disciplinary evaluation.
The licensee has implemented a system to analyze trends and determine root cause of quality problems in response to NRC concerns expressed in the previous assessment wherein a weakness was identified in the implementation of QA for plant operations. The weakness involved a lack of a comprehensive trending analysis which considered all exist-ing corrective action systems. The licensee's Electric Producticn QA Department developed a procedure in July 1985 to track and evaluate quality problems identified by not only licensee QA/QC programs but also other organizations such as INPO, ANI, NRC and the Joint Utility Management Association (JUHA).
The Quality Assurance Tracking and Trending System (QATTS) compiles findings in appropriate operational areas, performs trend analysis to define potential problem areas, and evaluates root cause and correc-tive action.
Information is graphically displayed in monthly reports to licensee QA management and quarterly reports which are distributed
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to upper level licensee management including the Vice President Electric Production. The QATTS exhibits findings for each respon-sible organization versus cause codes, and weighted findings against 10 CFR Part 50, Appendix B.
The system is relatively sophisticated but fairly new, and the licensee is revising the methods of data presentation via trend lines to make c,uality problems more readily apparent. The initial quarterly report covered the third quarter (July-September) of 1985 and utilized findings from a two year period dating back to October 1, 1983.
The organizations evaluated included Limerick and Peach Bottom Stations, the PEC0 Maintenance Division, Engineering and Research Department, and vendors. The effectiveness of QATTS has not yet been assessed by NRC inspections, although it is of interest to note that QATTS indicated that the cause of most findings were personnel errors which involve non-adherence to proce-dures.
The licensee's corporate Nuclear Review Board has been convened on-site on several occasions during the assessment period. The topics of discussion were the more significant safety issues experienced during the period. The licensee also utilizes the Independent Safety Engineering Group (ISEG) for oversight of plant operation and design, including post-scram reviews, attendance at PORC meetings, and the LER survey and trend analysis this period.
The onsite review committee (PORC) was active in review and approval of startup test results, plant operational activities, and special issues or station problems. The high level of activity during this assessment period resulted in frequently convened PORC meetings. The meetings created a large demand on station management and supervision time, but did not detract from safe plant operation and was not realized at the expense of other programs. The PORC has been instrumental in improving the quality of LERs, safety evaluations for modifications, and Technical Specification interpretations via PORC Position Papers.
Although not all of the above discussed programs have been reviewed for effectiveness by the NRC, there is clear evidence of the use of various methods to assure that quality is instilled in all facets of facility activities by licensee management.
2.
Conclusion Rating:
Trend: No Basis
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Board Recommendations:
NRC: Schedule a meeting with the licensee to discuss the use and effectiveness of the QATTS.
Licensee: None
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V.
SUPPORTING DATA AND SUMMARIES A.
Investigation and Allegation Review No investigations were conducted during the assessment period.
Several allegations were received from plant employees and a security program subcontractor, and were reviewed by NRC security specialists. One allegation that two guards left their post was substantiated, and enforcement action is under consideration.
Another allegation involved an alleged hole in a bioshield door which was unsubstantiated.
B.
Escalated Enforcement Actions 1.
Civil Penalties A fifty thousand dollar civil penalty was issued during the assessment period for cumulative violations of physical security requirements. Also, a violation is under consideration in con-nection with openings found in security vital trea barriers.
2.
Orders A Confirmatory Order was issued by NRR on August 16, 1985 restricting power levels to 5% rated. The Order effectuated an August 15 decision by the Third Circuit Court of Appeals staying the full power license pending appeals. The Order was lifted on August 21, 1985.
3.
Confirmatory Action Letters None C.
Management Conferences February 15, 1985 Corporate and Site Security Organization February 22, 1985 Operational Excellence Program March 11, 1985 Enforcement Conference - Oversight of Security Guard Force; Falsification of Training Records March 12, 1985 SALP Management Meeting September 25, 1985 Startup Test Program Status February 7, 1986 Enforcement Conference - Degraded vital area barriers
D.
Licensee Event Reports (LER)
1.
Tabular Listing Type of Events A.
Personnel Error
B.
Design /Manuf./Constr./ Install.
C.
External Cause
D.
Defective Procedure
E.
Component Failure
X.
Other
Total 143 LERs Reviewed LER Nos. 84-03 to 86-001 2.
Causal Analysis A detailed evaluation of LER quality using a sample of 30 LERs issued during the assessment period was made using a refinement of the basic methodology presented in NUREG/CR-4178.
In general, the LERs were found to be of above average quality based on the requirements contained in 10 CFR 50.73.
All 143 LERs which were reported during the assessment period (40 in 1984, 102 in 1985, and 1 in 1986) were also subject to an ongoing review as part of NRC inspections for trends and root cause identification.
Three sets of common mode events were identified, a.
Personnel Errors by I&C Technicians LER No.
Discussion 84-31 These events were caused by poor 85-03 communication by I&C technicians with 85-14 the on-shift licensed operators.
85-51 84-11 These events were caused by I&C technicians 84-30 and involve ESF actuations generated by 85-10 electrical grounds and shorts which occurred 85-11 during the performance of STs.
85-16 85-49
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LER No.
Discussion 84-07 These events were caused by I&C technicians 84-19 not properly venting and filling instrument 85-18 lines or other valving errors.
85-37 85-40 s
85-47 84-17 These events involve mental mistakes by I&C 84-24 technicians such as leaving a device with 84-32 the wrong setpoint (84-17), not resetting 85-20 a partial isolation during a surveillance 85-88 test (84-24), not checking an electrical print (84-32 and 85-20), and not recognizing the physical sensitivity of a relay (85-88).
The frequency of personnel errors was identified in December, 1984, was discussed with site management at that time, and was formally transmitted to the licensee as a regional concern in January 1985. Meetings were held at Region I with licensee management regarding plans for cor-rective action.
Licensee initiatives were successful in reducing the incidence of events caused by personnel error.
Specifically, there has been only one event (LER 85-88)
caused by I&C technician personnel error in the last 8 months of the assessment period as compared with 20 during the first 6 months of the assessment period, b.
Operations Inexperience (1) Procedure Deficiencies LER No.
84-04 Four hose stations not inspected due to omission from ST.
84-15 Inadvertent ESF actuation during ST due to valve omitted as isolation valve in procedure.
84-43 TS required data not taken on stroke time of suppression pool level instrumentation valve due to procedure deficiency.
85-02 RWCU isolation due to restoration procedure not ensuring adequate filling and venting of system.
85-15 Sprinklers inoperable due to administrative procedure deficiency which did not address post-modification restoration of TS required non-safety systems.
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85-22 MSIV leakage control system inoperable due to ST deficiency not reclosing breakers after test.
85-34 Inadequate sodium pentaborate volume due to ST calculation deficiency.
85-38 Inadvertent ESF during ST due to omission in restoration procedure leading to actuation upon power restoration.
85-58 TS required check for water in EDG day tanks overlooked due to omission in ST.
85-64 RWCU pump tripped due to airbound suction piping caused by inadequate ST which did assure adequate post-test vent and backfill.
RWCU was acting as TS required decay heat removal system due to both loops of RHR shutdown out of service.
85-32 RWCU isolation due to inadequate system startup procedure which did not adequately address an existing system configuration.
85-98 RWCU isolation due to omission in a procedure used to effect a modification to the SLCS.
The frequency of events caused by procedure deficiencies dropped sharply during the assessment period reflecting the gains in experience in employing procedures under varying plant conditions. There were 8 events caused by procedural deficiencies reported the first 5 months of the assessment period as compared with only 4 events during the last 9 months.
(2) Misunderstanding of TS Requirements 84-09 Service water rad sample not obtained within TS-84-27 required period.
84-16 Recirc pump start without TS-required pre-start ST.
84-44 Failure to demonstrate alternative means of decay heat removal as required by TS.
85-13 Partial loss of HPCI isolation ability due to transmitter not being placed in tripped condition as required by TS after being out of service for one hour.
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A3 85-78 TS-required ST not performed because cognizant individual failed to recognize that the plant conditions which triggered the TS requirement had been met.
85-84 TS-required manual rod block not inserted because cognizant individual failed to recognize that declaring the third (of eight) IRM inoperable triggered TS requirements.
85-91 TS-required containment-isolation provisions not met because cognizant individual failed to recognize that deenergizing the motor operated stop check in the SLCS would trigger the TS LCO.
The frequency of events caused by not meeting TS require-ments decreased during the assessment period due to gains in operating experience similar to the decrease in procedure deficiency caused events.
There were 5 instances of TS misunderstanding during the first 3 months of the assessment period as compared with 3 instances in the last 11 months of the assessment period. The more recent examples of TS misunderstanding differ from previous ones in that the earlier events involve not ur.derstanding TS requirements whereas later events involve not recognizing that changing plant conditions triggered additional TS requirements. This difference was recognized by the licensee in taking long term corrective actions in response to 85-78 and 85-84.
c.
Component Failure 84-08 85-50 These events involve an ESF actuation (CR 84-10 85-59 Emergency Fresh Air System) due to chlorine 84-28 85-63 analyzer tape break. The licensee attempted 84-33 85-81 numerous modifications and finally installed 84-46 85-85 a new system which is expected to be more 83-29 85-86 reliable.
The new system was not yet oper-85-30 85-92 ational at the close of the assessment 85-31 85-93 period.
85-42 85-97
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84-12 These events involve an ESF actuation (RWCU isolation)
84-26 due to defects in Riley Temperature Modules. Thre.
84-34 other identical events (85-25, 85-35 and 85-55) were 84-35 suspected to be due to similar defects.
Initially 84-36 the licensee was unable to identify the source of the 85-01 trips. Corrective actions included the installation 85-27 of circuit monitoring equipment which enabled 85-61 identification and repair of the device causing each 85-71 subsequent trip.
The incidence of these events decreased with 8 events in the first 4 months of the assessment period to 4 events in the last 10 months.
84-39 These events involve RPS and NSSSS actuation due to 85-07 voltage fluctuations. The licensee installed RPS 85-24 power supply circuit monitoring equipment, identified 85-26 and replaced the failing components, and determined the root cause to be excessive cabinet internal temperatures. The licensee modified the cabinets to increase air flow and lowered the local area temperature. No subsequent failures were experienced.
The decrease in reportable events due to repetitive component failures is due to the licensee's consistent emphasis on root cause identification and correction. An exception to this is the chlorine analyzer tape break which isolates the control room emergency fresh air system.
Poor original design and slow determination of the root cause indicate less than adequate management attentio TABLE 1 TABULAR LISTING OF LERS BY FUNCTIONAL AREA LIMERICK GENERATING STATION, UNIT NO. 1 Cause Code Area A
B C
D E
X Total A.
Plant Operations
38
9
81 B.
Radiological Controls
C.
Maintenance
1
5 D.
Surveillance
9
38 E.
F.
Security and Safeguards
G.
Outages
H.
Training And Qualification Effectiveness
I.
Licensing Activities
1 J.
Assurance of Quality
K.
Other
4
1
Totals
42
15
143 Cause Codes:
A.
Personnel Error B.
Design, Manufacturing, Construction, or Installation Error C.
External Cause D.
Defective Procedure E.
Component Failure X.
Other
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_
_
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TABLE 2 INSPECTION HOURS SUMMARY (12/1/84 - 1/31/86)
-
LIMERICK GENERATING STATION, UNIT NO. 1 Hours
% of Time A.
Plant Operations...........
1733
B.
Radiological Controls........
424
3 C.
Maintenance.............
214
D.
Surveillance.............
330
E.
Emergency Preparedness........
281
F.
Security and Safeguards.......
270
G.
Preoperational and Startup Testing Testing...............
1193
H.
Training and Qualification Effectiveness............
N/A N/A a
I.
Licensing Activities.........
N/A N/A
J.
Assurance of Quality N/A N/A
........
Total 4445 100
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_.._,-,,, _
,_ - - -,~.._,.._~.,,. _.
-,__,.,..___,-.__-_._m.
_.. - _ -, -....,
_ - - - - -,
- -. -.. -
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TABLE 3 ENFORCEMENT SUMMARY (12/1/84 - 1/31/86)
LIMERICK GENERATING STATION, UNIT N0. 1 A.
Number and Severity Level of Violations Severity Level No.
Severity Level 1
Severity Level 2
Severity Level 3
Severity Level 4
Severity Level 5
_1 Total
B.
Violations Vs. Functional Areas Severity Levels FUNCTIONAL AREAS II III IV V
DEV TOTALS A.
Plant Operations
6 B.
Radiological Controls O
C.
Maintenance
D.
Surveillance
E.
F.
Security and Safeguards
1 G.
Preop./Startup
1
5 Violation and Deviation Totals:
1
1
12
.
_, _ _, _,
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. _. -
.m
,
C.
Summary - Enforcement Data Inspection Inspection Severity Functional Report No.
Date Level Area Violation 85-01 1/2-4/85 IV Preoperations Failure to follow Blue Tag test procedures and QC inspection procedures regarding work on the circuits on DWG E-519 85-01 1/2-4/85 DEV Preoperations Failure to have Preop test IP 59.1 implement the test methods described in its FSAR test abstract.
85-02 1/1-31/85 IV Operations Tech. Specs. related equipment removed from service without proper authorization.
85-02 1/1-31/85 IV Operations Control room maintained in a vacuum without per-forming safety evaluation.
85-03 1/24-2/1/85 IV Operations MSIV-LCS inoperable due to operator oversight and incorrect surveillance test procedures.
85-06 1/16-2/7/85 V
Startup Failure to follow Admin-istrative Procedures in the processing of TER-22 and TER-29.
85-06 1/16-2/7/85 IV Startup I&C personnel operating
reactivity equipment without control room operator knowledge.
85-06 1/16-2/7/85 IV Startup Lack of control for troubleshooting activities.
85-08 1/17-21/85 IV Operations Failure to maintain RWCU containment isola-tion valves operable.
.
Inspection Inspection Severity Functional Report No.
Date Level Area Violation 85-12 2/4-8/85 III Security A total of five viola-tions have been cate-gorized as a level III and a $50,000 fine was imposed.
1.
Failure to control vital area keys after security shift is completed.
2.
Failure to change compromised vital area locks.
3.
Failure to report a security event to NRC.
4.
Failure to re-establish an ade-quate level of pro-tection for a degredated security system.
5.
Failure to certify watch persons prior to entry on duty.
85-16 3/16-4/30/85 IV Operations Failure to assure a multidisciplinary review of an ST at SUB-PORC.
85-43 11/1-14/85 IV Operations ESW Loop B discharge valves throttled and ESW Pump A discharge valve unlocked.
86-01 1/2-3/86 III Security One Severity Level III violation regarding openings in protected area and vital area barriers and security force members leaving assigned post TABLE 4 INSPECTION rep 0RT ACTIVITIES (12/1/84 - 1/31/86)
LIMERICK GENERATING STATION, UNIT NO. 1 Report / Dates Inspector Hours Areas Inspected 84-71 Specialist 191 Startup Test Program 12/5-31/84 84-72 Resident 157 Routine, daily inspections and 12/1-31/84 unscheduled backshift inspections 84-73 Specialist
Followup inspection of Emergency 12/4-5/84 Preparedness 84-74 Specialist
Startup Test Program 12/28/84-1/11/85 85-01 Resident
Special Inspection - Inoperability 1/2-4/85 of two containment isolation valves 85-02 Resident 213 Routine, daily inspections and 1/1-31/85 unscheduled backshift inspections 85-03 Specialist 227 Special announced operational 1/24-2/1/85 assessment team inspection 85-04 Cancelled 85-05 Specialist
Routine, unannounced inspection of 1/15-17/85 the safety related corrective /
preventive maintenance program 85-06 Specialist
Startup Test Program 1/16-2/7/85 85-07 Specialist NA Operator Licensing Exams 1/14-18/85 85-08 Resident
Special inspection - RWCU system 1/17-21/85 inoperability 85-09 Specialist
Routine, unannounced inspection of 1/22-24/85 system interactions l
,
l l
[
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Report / Dates Inspector Hours Areas Inspected 85-10 Specialist
Routine, announced inspection of 1/22-3/8/85 Emergency Preparedness Implementa-tion Appraisal 85-11 Resident 278 Routine, daily inspections and 2/1-3/15/85 unscheduled backshift inspections
,
85-12 Specialist
Routine, unannounced physical 2/4-8/85 protection inspection 85-13 Specialist
Routine, announced inspection on 2/25-3/11/85 Chemistry, Radiation Protection and Radioactive Waste Management 85-14 Specialist
Startup Test Program 2/20-3/13/85 85-15 Conference NA Enforcement Conference for IR 85-12 85-16 Resident 216 Routine, daily inspections and 3/16-4/30/85 unscheduled backshift inspection 85-17 l
Specialist 186 Routine, announced inspection of
,
4/2-4/85 observation of the licensee's emergency exercise 85-18 Specialist
Routine, unannounced inspection of 3/26-28/85 the preoperational test procedure results evaluation.
85-19 Specialist 186 Special, inspection of the 4/1-19/85 operation, maintenance testing and surveillance of the high-low pressure interface 85-20 Specialist
Routine, unannounced inspection of 4/1-4/85 the Startup Test Program test results 85-21 Specialist
Routine, unannounced safety 4/1-4/85 inspection of Radiation Protection 85-22 Specialist
Special Physical Security Inspection 4/17-22/85 l
l
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Report / Dates Inspector Hours Areas Inspected 85-23 Specialist
Routine, unannounced inspection of 4/23-26/85 the chemistry and gaseous radwaste systems 85-24 Specialist
Routine, unannounced inspection of 4/30-5/2/85 the Startup Test Program 85-25 Resident
Routine, daily inspections and 5/1-31/85 unscheduled backshift inspections 85-26 Specialist
Routine, announced inspection of 5/20-26/85 the Radioactive Waste Management Program 85-27 Specialist
Routine inspection in closing out 1/3-28/85 of outstanding items 85-28 Specialist
Routine, inspection of Radioactive 9/16-19/85 Waste Management Program 85-29 Specialist
Security Program management 7/8-12/85 effectiveness, physical barriers and detection aids 85-30 Resident 274 Routine, daily inspections and unscheduled backshift inspection 85-31 Specialist
Special, announced inspection of 7/17/85 an emergency preparedness account-ability and evacuation drill 85-32 Specialist
Routine, inspection of the Quality 8/5-9/85 Assurance program for power ascension 85-33 Specialist
Special, inspection of the Emergency 8/8/85 Preparedness training program for the security force 85-34 Specialist
Security drawings allegation 8/7/85 followup l
85-35 Specialist
Startup Test Program 8/11-23/85 l
85-36 Resident 278 Routine, daily inspections and 9/23-10/30/85 unscheduled backshift inspections l
,
Report / Dates Inspector Hours Areas Inspected 85-37 Specialist 145 Startup Test-Progrcm 9/3-20/85 85-38 Specialist
Startup Test Program 9/30-11/6/85 85-39 Specialist
Routine inspection of the fire 10/7-11/85 protection / prevention program 85-40 Specialist
Routine inspection of the radiation 10/7-11/85 protection program 85-41 Specialist NA Operator Licensing Exams 11/11/85 85-42 Specialist
Routine inspection of the Physical 10/28-11/1/85 Security 85-43 Resident
Special inspection - Emergency 11/1-14/85 Service Water System 85-44 Specialist
Startup Test Program 11/20-12/6/85 85-45 Specialist
Special inspection, followup on an 11/19/85 allegation to the Security Plan 85-46 Resident 209 Routine daily inspection /unschedule 12/1/85-1/10/86 backshift inspection 85-47 Specialist
Routine inspection of licensee's 12/2-6/85 action on previous NRC concerns 85-48 Specialist
Startup Test Program 12/16/85-1/3/86 86-01 Specialist
Special inspection for degradation 1/2-9/86 of physical security barriers 86-02 Specialist
Routine inspection of the Radiation 1/6-10/86 Protection Program 86-03 Resident 207 Routine daily inspection and 1/11-2/19/86 unscheduled backshift inspections
.
TABLE 5 UNPLANNED REACTOR SCRAMS LIMERICK GENERATING STATION, UNIT NO. 1 Power Date Level, Description Cause 1 Note 1 1. 12/21/84 SD Reactor trip on The "B" RPS static inverter loss of "B" RPS voltage regulator board channel power con-failed on (high current with "A" temperature), output channel surveil-voltage fluctuated, and lance testing.
feeder breaker to "B" RPS (LER 84-039)
panel tripped open on over voltage.
12/22/84 Startup -Initial Criticality 2.*1/31/85 3.5%
Reactor trip on Improper activity control low vessel level by not involving I&C in due to operator that operator failed to error valving back realize that instrument in-service a jet had common reference leg pump developed head with vessel level instrument follow-Instrumentation.
ing corrective maintenance.
(LER 85-021)
2/17/85 Startup 3. 4/23/85 SD Reactor trip on Inadequate instrument low vessel level valve tagout. Failure due to I&C error to open instrument while removing a equalizing valve and not reactor level recognizing the effect of instrument from a leaking vent fitting.
service. A sur-veillance test was being performed (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after tagout) on the other channel logic which generated a full scram signal.
(LER 85-046)
8/8/85 Startup Note 1 - Determined by SALP Board, may not agree with LER analysis.
- Scrams with Rod Movement
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,
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- _ - -
.- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -. -. -. - _ _ _ _ _ _ _
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Power Date Level Description Cause 4, 8/8/85 SD Operator inadvert-Personnel error compounded ently mispositioned by design change in that mode switch during switch had been replaced a startup into Run four months prior and was position (with easier to position.
MSIVs closed) caus-prior and was easier ing a reactor trip.
to position.
(LER 85-066)
8/8/85 Startup 5.*9/11/85 28*.'
Reactor trip on low Procedural inadequacy and i
sessel level during personnel error caused loss startup as a result of one of two on-line of reactor feed-condensate pumps due to water pumps trip-a spurious high suction ping on low suction strainer differential pressure. (LER pressure signal generated 85-073)
while placing a third i
condensate pump in service.
9/11/85 Startup 6.*10/15/85 Startup Reactor trip on Personnel error due to (800 psig)
low vessel level lack of coordination during startup between operators, because the oper-ator increased reactor pressure above condensate pump discharge pressure without starting a re-actor feed pump.
(LER85-083)
i 10/15/85 Startup 7.*12/8/85 65".
Reactor trip on Design deficiency in that high neutron flux GC SIL-362 was not imple-due to recircula-mented, and misratch tion pump motor-between actual speed and generator speed demand signal was not increase caused apparent when operators by control cir-attempted to balance cuit failure, signals.
(LER85-095)
12/10/85 Startup
__
_... -
.-
-
-
l
Power Date l.evel Description Cause 8. 1/2/86
Reactor trips on Design deficiency for 9. 1/3/86 low vessel level, wide versus narrow range twice within 90 vessel level instrumenta-minutes, because tion which feed turbine of indicated level trip versus RPS logic discrepancy respectively, between narrow and wide range instrumentation at decreased reactor pressure.
,
(LER86-001)
1/8/86 Startup
. _ _ - _
_. __
_ _ _ _ _ _ - -. _ _ - _.
_ _ _ _ - _ _ _ _ _. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
TABLE 6 PLANNED SHUTDOWNS AND REACTOR TRIPS LIMERICK GENERATING STATION, UNIT NO. 1 Power Date Level Description 3/1/85 Heatup Manual scram on completion of T.C. heatup in conjunction with commencing maintenance outage 4/17/85 NA Drove rods to Cold Shutdown to await full power license 9/12/85 17%
Manual scram from remote shutdown p'anel (STP-28.1)
9/16/85 21%
Scram on low level during loss of off-site power test (STP-31,1)
10/8/85 50%
Turbine Trip (STP-27.3)
11/14/85 75%
Turbine Trip (STP-27.3)
12/18/85 92%
Full MSIV Isolation (STP-25.3)
1/2/86 994 Turbine Trip (STP-27.4)
1/13/86 25%
Manual scram from 25% power to investigate Main Turbine Control valve #4 failure to close NOTE:
All planned scrams were part of the Startup Test Program except the scram on 1/13/86
~.
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i TABLE 7 NRR SUPPORTING DATA 1.
NRR/ Licensee Meetings January 10, 1985 Independent Design Verification Program Review February 7, 1985 DL Director's Briefing on Project Status March 5, 1985 IDVP Meeting on Jet Impingement Loads March 12, 1985 SALP Meeting and Licensing Activities Review April 22, 1985 Remote Shutdown System Redundancy December 17, 1985 TS Surveillance Interval Extension for Valve:
2.
NRR Site Visits December 20, 1984 Ultimate Heat Sink Protection from Tornado Missile Events August 20, 1985 PM visited Resident Inspector and plant staff September 25, 1985 PM Attended Management Meeting to Discuss Results of Initial Phases of Startup Test Program December 5, 1985 PM, Hydrologist and Plant Systems personnel toured site in support of affidavits on potential for flooding of plant (LER 85-80)
3.
Commission Briefings August 8, 1985 Consideration of Issuance of Full Power License 4.
Schedular Extensions Granted (Full Power License Conditions)
a)
Fire protection - install stairway to Unit 2 cable spreading room b)
Reactor Enclosure Cooling Water and Chilled Water Isolation Valves -
by first refueling outage c)
Hydrogen Recombiner Redundant Isolation Valves - by first refueling outage d)
Remote Shutdown System switches for pumps - by first refueling outage
.
59 e)
Refueling floor volume connection to Standby Gas Treatment System -
by first refueling outage f)
Scheduling of next full emergency preparedness exercise - by May 1986 hate:
Items a, b, c, and e were repeated in the full power license from the low power license whic was issued prior to this SALP rating period.
Item d was update.- ' rom the low power license.
5.
Reliefs Granted Relief pursuant to 10 CFR 50.55a(g) for Revision 5 to the Inservice Testing Program for Pumps and Valves as discussed in SSER No. 5.
Relief from certain ASME Code Section XI Preservice Inspection requirements as discussed in SSER No. 5.
6.
Exemptions Granted (Fyll Power Licensej a)
GOC-61, SGTS to Refueling Floor Area b)
GOC-56, Contairment Isolation Valves c)
CDC-19, Remote Shatdown Capability d)
Appendix J, Containment Airluck Testing e)
Appendix J, KSIV Leak Rate Testing f)
Appendix J, IIP Valve Leak Rate Testing g)
Appendix J, RHR Valve Leak Rate Testing h)
10 CFP. 50.44, Initial Containment Incrting i)
Appendti E, Scheduling of EP Exercise 7.
License Araenaments Issued Two reguests for amendment of the full power license Technical Specifica-tions wt:ra received but have not been acted on within the rating period.
Also, the following activities relevant to the issuance of a full power licensa occurred.
May 1985, SER Supplement No. 4 June 1984, SCR Supplement No. 5 August 1985, SER Supplement No. 6 May 2, 1985, ASLB Third Partial Initial Decision July 22, 1085, ASLB Fourth Partial Initial Decision 8.
Em,ergency Technica _l Sjecification Changes Granted Hone
9.
Orders Issued Numerous Orders were issued during this period by the ASLB and the ASLAB.
Perhaps the two most prominent orders issued were those issued by NRR on August 15 and 21, 1985.
In the August 15, 1985 Order, the Director, NRR, suspended operation above 5% power in view of the U.S. Court of Appeals for the Third Circuit's stay of effectiveness of the full power license.
In the August 21 Order, the Director, NRR, rescinded the August 15 order based on the Court's lifting of its stay.
10. NRR/ Licensee Management Conference February 7, 1985 Briefing of the Director, DL by the licensee and the staff on overall status of the project.
l
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Figure 1 Humber of Days Shutdown Limerick Generatino Station, Unit No. 1 Dec. 84
.
N 28 Days Shutdown I
.
i Jan. 85
.
1 Day Shutdown I
Feb. 85 I
17 Days shutdown
'
I
,
Mar. 85 31 Days Shutdown l
Apr.'85 13DaysShutbown I I
May 85 31 Days Shutdown I
Jun. 85 3D Days Shutdown
.
3,
-
Jul. 85 l
~
31 Days Shutdown
!
Aug. 85 16 Days Shutdown I
I Sep. 85
4 Days Shutdown I
Oct. 85 l
6 Days Shutdown l
Nov. 85 l
10 Days Shutdown l
,
D$c.'85 14 Days Shutdown
Jan. 86 13 Days Shutdown I
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