IR 05000352/1986022
| ML20213G902 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/27/1986 |
| From: | Eapen P, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20213G892 | List: |
| References | |
| 50-352-86-22, NUDOCS 8611180394 | |
| Download: ML20213G902 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/86-22 Docket No.
50-352 License No.
NPF-39 Licensee:
Philadelphia Electric Company 2301 Market Street
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Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station Inspection At:
Limerick, PA inspection Conducted:
September 22-26, 1986 (
Inspetlors:
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W. Oliveira, Reactor Engineer
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fo/t7/8C Approved
Dr. P.'K. Eapen/ Chief, Quality Assurance
' ddte Section, OB, DRS Inspection Summary:
Routine unannounced inspection conducted on September 22-26, 1986 (Inspection Report No. 50-352/86-22; Areas Inspected: Non-Licensed Staff Training, and a previously identified NRC item.
Results: No violations or deviations were observed.
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8611180394 861030 PDR ADOCK 05000352 G
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DETAILS 1.
Persons Contacted R. Alejnikov, Modification Coordinator R. Balmer, Superintendent of Nuclear Training Section (NTS)
- R. Costaglia, Supervisory Engineer, Maintenance Division P. Cox, Test Engineer, Operations
- J. Doering, Superintendent Operations P. Duca, Technical Engineer
- C. Endriss, Regulatory Engineer
- E. Firth, NTS Training Coordinator
- J. Franz, Plant Manager M. Held, Quality Control Inspector D. Lerch, NTS Instructor J. Moore, Quality Assurance (QA) Auditor J. O'Mara, Maintenance Supervisor J. Rainey, Testing & Laboratories (TL) Supervisor
- J. Rube.rt, QA Supervisor
During the course of the inspection, the inspector also contacted other technical and administrative personnel.
United States Nuclear Regulatory Commission
- E. Kelly, Senior Resident Inspector S. Kucharski, Resident Inspector
- Denotes those who attended the exit meeting on September 26, 1986.
2.
Follow Up of Previously Identified Items (Closed) Inspector Followup Item 84-31-07:
A-46, " Procedure for Mainten-ance of Plant Quality Assurance (QA) Records" was not referenced in any procedure where the generation of QA records was addressed.
All procedures except three, where A-46 should have been referenced have been corrected. The remaining three procedures are being revised to reference A-46.
This item is closed.
3.
Non-Licensed Staff Training 3.1 Introduction The effectiveness of the implementation of the licensee's non-licensed training program was assessed by reviewing the following
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activities in the operations, maintenance, instrument and control (I&C), engineering and modifications, and quality assurance (QA)
areas.
- Shift turncver for Non-Licensed Operators (NLO).
- NLO activities such as: reactor and turbine building rounds, daily surveillance in accordance with Surveillance Test (ST) procedure ST-6-107-885-1 " Thermal Limits Determinations", D14 Diesel Generator Operability Test Run; and Fire Brigade.
- On the job training (0JT) and qualification of an I&C
+echnician, non-licensed operators, and health physicist (HP).
Maintenance activities including Preventive Maintenance for " Magnetic Starters" by electricians, and re-installing the D14 Diesel Generator Air Compressor.
- Engineering activities, such as: Modification & Design Change Package (MDCP) 85-0844 Test Switches for CACS (H2/02 Analyzers), Trouble shooting the RPS Relay C714-K88, and follow-up actions regarding the initiation of the main control room HVAC isolation.
Training plans for NL0s, HP, Chemistry Technicians (Chem Techs), Technical Staff and Manager (Engineer), and Instructor Certification.
- Training records of seven NL0s, two STAS, three engineers, two I&C foremen, and five I&C technicians.
- Two quality assurance (QA) audit reports and three surveil-lance audit reports, and their respective corrective action responses.
- Factoring lessons learned from LERs, NRC Inspection Report, Information Notices, and IE Bulletins.
The selected activities were conducted in accordance with the licensee's procedures by personnel knowledgeable in the requirements of the procedures and technical specifications. Working level personnel and management were aware of the roles of QA, QC and personnel training in safety-related work activities.
Activities affecting non-licensed training were conducted in accordance with the licensee's commitments and procedures. -No violations or deviations were identifie.
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4.
Station Operations The training of NL0s, i.e., Auxiliary Operators (A0s), Assistant Plant Operators (AP0s), and Plant Operators (P0s), is conducted in accordance with procedure A-50, Revision 0, " Procedure for the Conduct of Station Training, and the NLO Progression Training Program Plan. The Training Coordinagor is responsible for developing, implementing and maintaining the program.
The Station Superintendent and the Nuclear Training Section a
Superintendent at the corporate level are responsible for monitoring, reviewing and approving the plant training program.
The Fossil Training Section provides support in the areas of company certification of NL0s.
The Modification Coordinator (M/C) forwards Modification Training Bulle-tins to the Nuclear Training Coordinator in accordance with procedure A-14, Revision 3, " Procedure for Control of Plant Modifications." A bulletin has been prepared and issued for MDCP 85-0884.
The NL0s use checklists to record their readings and observations. Most of the. checklists reviewed do not contain acceptance criteria. The automated Plant Electronic Notebook System (PENS), however, contains the acceptance criteria, and sorts and analyses the operator round parameter.
PENS is able to store 150 readings for each parameter. All parameter readings can be reproduced and plotted on the PENS plotter. The PENS automatically alerts the operator whenever a parameter is out of its normal operating range.
PENS other advantages include: the ability to view trends on the plots, and the inherent neatness associated with data.
The inspector observed the monthly 014 Diesel Generator Operability Test Run being conducted with a licensed plant operator (PON) and three NL0s.
The PON was also qualifying the NL0s in accordance with their Qualification Training Manual; Qualification Card 592.1P.
Also observed was an unannounced back shift fire drill. Assisting the NLO fire brigade team were a security guard and health physicist (HP).
The HP was suited up for the first time and had not received adequate fire fighting training to support the fire brigade. The licensee is developing a program to train. personnel assisting the fire brigade. This is an unresolved item pending the development and implementation of the fire fighting training for personnel assisting the fire brigade.
(50-352/86-22-01)
A Suspected Licensee Event Report (SLER) was prepared by a Shift Technical Advisor (STA) in training under the direction of a qualified STA.
SLER Involved the initiation of the Main Control Room HVAC Chlorine Isolation. The Control Room Emergency Fresh Air Supply (CREFAS) was initiated and tripped causing the annunciator to alarm. The CREFAS
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Problem was corrected.
The probable cause for the high chlorine detection was due to residual chlorine being blown into the HVAC intake plenum during a thunder storm. NRC was advised of the event and a LER will be prepared (see paragraph 6.).
5.
Maintenance Division Training is conducted in accordance with Maintenance Administrative (MA)
Procedure MA-9, Revision 5, " Procedure for Training and Testing of Main-tenance Division Personnel"; and MA-18, Revision 3, " Administrative Procedure for Indoctrination and Specialized Training of Maintenance Personnel." All entry level maintenance personnel regardless of past experience receive formal initial training in a Helper category at the Barbadoes Training Center (Norristown, PA), and plant specific on-the-job training (0JT). The helpers will take an exam at the end of two years to be eligible to pursue a trade and receive the necessary formal training and DJT for progression in the trade up to first class tradesmen.
Continued training (retraining) and training on specific equipment will be administered and conducted on a "as need basis".
The Superintendent of the Electric Production Department Maintenance Division issued a letter on February 25, 1986 to all Maintenance employees to " afford all employees the opportunity to improve their trade skills where they feel some concern." The inspector interviewed an assistant foreman who was taking advantage of the offer.
A site training coordinator is being selected. The selection method includes the Kepner Tregoe process followed by a presentation by each prospective candidate.
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6.
Testing and Laboratories Division The training program for the Division's Instrument and Control (I&C)
technicians is in accordance with the Testing and Laboratories (TL)
administrative procedure TL-02-50002, Revision 0, " Qualification and Training of Testing and Laboratories Division Personnel." The Division's General Superintendent is responsible for implementing TL-02-5002. The Section heads approve the training activities and their Branch engineers, or group leaders, determine the qualification and training requirements. The Training Coordinator is responsible for maintaining the training documentation outlined in TL-02-50002.
The procedure's qualification and training requirements include: Regulatory Guide (RG) 1.8, Revision 1, 1975, " Personnel Selection and Training"; and RG 1.58, Revision 1,1980, " Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel."
The inspector observed two technicians and a trainee trouble shooting the drift of certain LPRMs.
They were to gather data to determine the condition of the LPRMs and plot IV curves in accordance with TL-1-00482, Revision 1, " Checkout, Maintenance and Trouble Shooting of PRM Detectors." Each curve (voltage versus amperage) takes about 10-15 i
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minutes to plot. One technician had designed and constructed an instru-ment that would plot the curve within two minutes as well as reduce set up time.
The initial test was promising and quite accurate when compared to a curve plotted by the old method. The trainee performed some of the steps in the procedure under the direction of the technicians.
When the shift I&C technician went to reset the chlorine detector AITS-7816C after the initiation of a Control Room HVAC Isolation as previously discussed in paragraph 4., he noted that the detector cabinet door was open and proceeded to close the door. This caused a "hard down" scale indication (below zero) which is equal to no signal or no current to the indicator in the control room. A trouble shooting form was prepared and the shift I&C technician and an TL engineer investigated the problem. The engineer found that the wire hook up from the detector to a recorder from a previous test of the detector had been disconnected from the detector by the closing of the door. The hook up wire was connected to the same terminal as the control room indicator.
The closing of the door also disconnected the control room indicator.
Though the problem was corrected, the inspector pursued the question of proper tagging of any equipment under test since the detector was not conspicuously identified to be in a test mode. The inspector recognized that the test did not affect the function of the detector and the area was not well lighted to see the thin wire hook up.
With the assistance of the STA, the inspector found that procedure A-42, Revision 3,
" Procedure for Control of Temporary Circuit Alteration (TCA)" did not specifically address how to make a TCA noticeable to all concerned.
I&C supervision produced procedure A-42, Revision 4 which had not been distributed and later A-42, Revision 5 which had just been PORC approved.
Both revisions discussed in detail, including a checklist, the procedure for placing equipment in a TCA condition.
Follow up training is being scheduled in accordance with TL-02-50002. This is unresolved item pending completion of retraining and issuance of the revised procedure A-42.
(50-352/86-22-02)
7.
Nuclear Training Section The Limerick Training Branch is responsible to the Nuclear Training Section (NTS) for licensed operator training, STA. NLO training, Chemistry and Health Physics training, General Employee and Special Training, and the Techrital Staff and Manager training. The Superintendent of the NTS is however, responsible to coordir. ate all areas of training required for INPO accreditation.
This includes mechanical and electrical areas in the Maintenance Division, and the I&C technician area in the TL Division.
NTS provides the Maintenance and TL Division Training Coordinators with INPO guidelines and training experts to develop their training programs for INP0 accreditation.
An INP0 Board Review for accreditation of non-licensed staff training program is scheduled for October 16 and 30, 1986.
T'a licensee is expected to be accredited, and will have all these programs fully implemented by December 31, 198 F
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The Superintendent of NTS is Chairman of the Nuclear Training Review Committee which meets quarterly.
The Maintenance and TL Division Training Coordinators are members of the committee.
The status of the accreditation effort is maintained by the Limerick Accreditation Project Action Status List. A weekly " punch list" meeting updates the list.
The Limerick Regulatory Engineer provides the Training Coordinators with regulatory requirements or information, industry standards and events that may impact training (lessons learned). NTS receives INPO information and LERs directly. The last SALP report had an excellent breakdown of the LERs which NTS has reviewed and taken action. The inspector requested information regarding impact of LERs following issuance of the SALP and received a list of the LERs and their impact on training. While most of the LERs follow up actions were simply required reading, LER 86-020 concerning " Low Reactor Water Level Due to Personnel Error" was factored into the training program.
Lesson plans reviewed were in accordance with the procedure A-50.
One lesson plan was just developed because of the follow up action by NRC Senior Resident Inspector in Inspection Report 50-352/86-03 concerning LER 85-091, " Standby Liquid Control Outboard Isolation Valve."
The inspector reviewed the training records of operations, technical staff and I&C technicians. The records for Maintenance Division personnel are maintained in Barbadoes, and had been recently reviewed by NRC Inspectors, i.e., 50-352/86-20. The records were complete and in compliance with ANSI 18.1-1971.
8.
QA/QC Interface With Non-Licensed Training The Limerick site QA Supervisor reports to the General Supervisor of the Audit Section in the Electric Production Department QA Division.
Similarly the Quality Control (QC) Supervisor reports to the General Supervisor in the QC Section. QA audits are performed in accordance to QA Department Procedure (QADP)-5, Revision 13, " Procedure for Performance of QA Division Audits", and QA surveillances are performed in accordance with QADP-12, Revision 11, " Procedure for Performance of QA Division Surveillances."
The inspector reviewed Audit No. AL 85-87TR, "NLO Training and Requalifi-cation Program." The audit was detailed and covered the entire training program.
Six of ten findings had been closed. The open findings were being monitored. The inspector reviewed the preparation phase of the follow up audit with the lead auditor who was found to be well prepared.
Except for licensed operators and NLO training, the area of training was not separated into discreet subject area. The audit schedule showed 28 audits between July through December 1986 to be conducted by seven auditors.
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Surveillance audits are similar to QA audits except there are no formal audit plans or audit checklists and no exit discussions if no deficiencies are identified. A surveillance may include the observation of work-in-progress. Surveillance audits are prompted by special events, or requested by management. Audit SL86-15MEM, " Repair and Replacement of LGS Reactor Circulation Pump Seal (IA-P201)", for example, was an important event and NRC Resident Inspector was also present. The inspector reviewed three survaillance audits and found them to be in compliance with QAPD-12.
A QC inspector was present, who witnessed and signed off the hold points required by the preventive maintenance (PMQ) procedure 093-004, Revision 0, " Magnetic Starter."
9.
Potential Personnel Safety Issue The passageway along the battery rooms was without lighting for a short period of time. The inspector observed the security personnel trying to turn on the emergency lighting.
The inspector questioned the regulatory enginee.r as to why the emergency lighting system did not go on automati-cally. The reason given was that the space had been modified and the emergency lighting was connected to another power source instead of the normal lighting system. The licensee is committed to correct the person-nel safety issue.
10. Unresolved Items Unresolved Items are matters about which more information is required to ascertain whether they are acceptable items or violations. Unresolved items are discussed in paragraphs 2 and 6.
11. Management Meetings Licensee management was informed of the scope and purpose of the inspec-tion at the entrance interview on September 22, 1986. The findings of the
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inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the September 26, 1986 exit interview (see paragraph I for attendees).
At no time during the inspection was written material provided to the licensee by the inspectors. The licensee indicated that no proprietary information was involved within the scope of this inspection.