IR 05000352/1990013
| ML20042G399 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/07/1990 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042G391 | List: |
| References | |
| 50-352-90-13, 50-353-90-12, NUDOCS 9005140194 | |
| Download: ML20042G399 (51) | |
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U.S. NUCLEAR REGULATORY COMMISSION
' REGION I Report No.-
90-13 90-12 Docket No.
50-352 50-353 I
License No.
NPF-39 l
NPF-85 l
Licensee:
Philadelphia Electric Company l
Correspondence Control Desk P.O. Box-195
Wayne, Pa 19087-0195
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Facility Name:
Limerick Generating Station, Units 1 and 2
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Inspection Period:
March 6 - April 9, 1990 L
Inspectors:
T. J. Kenny, Senior Resident Inspector i
L. L. Scholl, Resident Inspector
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M. G. Evans, Resident Inspector i
G. C. Smith, Senior Physical Security Inspector
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b0 Approved by:
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Lawrence T. Doerflein, Chief, Da'te
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Reactor Projects Section;2B
i Summary: - Routine inspections by the resident inspectors consisting of (a). plant
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tours, (b) observations of maintenance and surveillance testing,-(c) review of
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LERs and periodic reports, (d) review of operational events, (e) system walkdowns
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and.(f) record retention and document control.
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During this inspection period:
' A violation was identified for inadequate document control. Addi-
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tional discrepancies in the areas of record retention and document I
control, including inadequate corrective action in response to Quality Assurance audit findings were identified (section 10).
An evaluation of PEco's Self Assessment Capability was performed
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(section 12).
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DETAILS I
1.0 Persons Contacted
.j Within this report period, interviews and discussions were conducted with.
members of PECo management and staff as necessary to support inspection.
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activity.
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2.0 Operational Safety Verification
The inspectors conducted routine entries into the protected areas of the
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plant, including the control room, reactor enclosure, fuel floor, and
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drywell (when access is possible).
During the inspection, discussions I
were held with operators, health physics (HP) and instrument and control
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(I&C) technicians, mechanics, security personnel, supervisors and plant
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management.
The inspections were conducted in accordance with NRC i
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Inspection Procedure-71707.and affirmed PECo's commitments and compliance with 10 CFR, Technical Specifications, License Conditions and Administ-i rative Procedures, j
2.1 Inspector Comments and Findings (71707)
l At the start of the inspection period both Units were operating at 100% power.
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On March 8, the Unit 2 High Pressure Coolant Injection (HPCI) system.
was declared inoperable because the air.line to the HPCI turbine
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steam supply drain valve (HV-055-2F028) broke at its fitting, causing the valve to close.
Emergency repairs were made and the system declared operable within five hours. The cause of the event was most likely accidental contact of the air line by maintenance per-sonnel working in the area.
The NRC was notified via the ENS.
On March 9, the 'B' shunt trip breaker on the Unit 2 Reactor Protection System (RPS) Uninterruptable Power Supply (UPS) tripped on underfrequency, causing the loss of the '28' RPS UPS power supply.
i Loss of this power supply caused various isolations including, dry-well chilled water, reactor enclosure cooling water to the recir-culation pumps and the reactor water cleanup system. The RPS UPS breakers were reclosed and all isolations were reset within one hour.
It is believed that the breaker trip occurred when a main-tenance worker accidently bumped the RPS panel containing the under-frequency relay while changing a ' light bulb in the static inverter y
room.
The NRC was notified via the ENS.
On March 12, the Unit 2 HPCI system initiated, without injection, and various sample lines isolated when valving in a reactor vessel
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e pressure instrument following a calibration and functional test.
Valving the instrument back in resulted in a pressure spike on a reference leg common to a number of level transmitters and caused a spurious channel 'B' low low level signal. The HPCI system started but the injection valves did not open due to the spurious signal.
The HPCI pump ran for a few minutes on minimum flow until secured by the operators. There is a caution in the procedure for valving these instruments back in slowly.
The I&C techn R' u attempted to
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do this, however, the pressure spike was still rect.tved.
To improve performance in this area, PECo plans to discuss the importance of supervisory involvement when valving instrumentation with I&C per-
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sonnel and procedures will be revised to include an additional sign-off step alerting the shift supervisor of the potential for in-strument: transients due to valve manipulations. The NRC was notified via the ENS.
On March 14, the required firewatch was not established when the fire protection systems for both trains of the Standby Gas Treatment System charcoal filters were blocked. On March 15, the required firewatch was not established when the fire protection system for inside both Control Room Emergency Fresh Air System (CREFAS) char-coal filter housings were blocked, The cause of both events centered around inadequate communications among the_ shift personnel, Cor--
rective actions included a memorandum from operations management stressing the shift supervisors ultimate responsibility for estab-lishing firewatches and the personnel involved were counselled.
The inspector found the licensee's corrective actions adequate.
On March 14, Unit 1 reactor power was reduced to 80% because feed-
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water copper level had increased to 0,35 ppb, The unit remained at 80% reactor power until copper level decreased to 0,24 ppb on March 23, Reactor power was then increased to 100%,
On March 25, Unit 2 reactor power was reduced to approximately 20%
of rated thermal power and the main turbine was taken off line due to an Electrohydraulic Control (EHC) fluid leak on the #2 main
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turbine control valve. On March 28, prior to completing the leak i
repairs, the unit was manually scrammed from 20% power due to rapidly'
increasing condensate and reactor water conductivity levels,
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On March 30, a loss of Unit 2 Shutdown Cooling occurred due to the loss of an RPS/UPS power supply caused by a transformer fire in' the
'28' inverter. The inverter was bypassed, the bus re-energized and shutdown cooling reestablished within 17 minutes. The resultant reactor coolant system heatup was less than 1 degree Fahrenheit (F).
The NRC was notified via the ENS.
i Following repair of the EHC leak and the condenser tube leak on Unit 2, a reactor startup was begun on April 2 and criticality was achieved on April 3.
Following a hold period for copper levels to decrease, the unit was increased to 100% power on April 7.
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On April 5 and 6, control room ventilation was manually shifted to the " Chlorine Isolation" mode following a "High Toxic Chemical
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Concentration Alarm." Control-room personnel donned self contained breathing apparatus and observed that the toxic gas monitor alarm channel 'B' indicated high ethylene oxide. Air samples of the'
control room and the control room air intake plenum were' normal.
Following the first isolation on April 5, the
'B' channel was dec-lared inoperable.
During calibration testing of the channel on April 6, the second isolation occurred..On April 9, the detector was replaced and the 'B' toxic gas monitor declared operable, i
At the end of this inspection period both reactors were operating ~ at L
100% power.
3.0 Update / Closeout of Open Items (92701)
Unit 2 (Closed) Unresolved Item 50-353/88-99.
Three Mile Island Action Item III,A.I.2.:
Upgrade Emergency Support Facility.
This item was last updated in Inspection Report 50-353/88-27, The inspec-tor examined the Technical Support Center (TSC) and verified that the Unit 2 drawings and procedures required to support TSC activities were in place. The inspector reviewed Hot Functional Tests 2HF-050, " Plant Moni-toring System, Plant Variable Display Test" and 2HF-051, " Plant Monitoring System, Regulatory Guide 1.97, Reasonableness Test,"'results approved January 16, 1990.
The Unit 2 Safety Parameter Display System (SPDS) was declared operational on January 16, 1990, upon successful completion of the SPDS validation testing and results approval.
This item-is closed.
4.0 Surveillance /Special Test Observations-(61726)
.During this-inspection period, the inspector reviewed in progress surveil-lance testing as well as completed surveillance packages.
The inspector verified that surveillances were performed in accordance with licensee approved procedures, plant technical specifications, and NRC Regulatory Requirements. The inspector also verified that instruments used were within calibration tolerances and that qualified technicians performed the surveillances.
Unit 1 ST-2-026-594-1 Radiation Liquid Effluent Monitoring - RHR Service Water and Service Water Systems Effluent Line Source Checks l
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ST-6-052-232-1 B Loop Core Spray Pump, Valve and Flow Test Unit 2
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ST-6-055-200-2 High Pressure Coolant Injection Valve Test j
ST-6-107-450-2 Emergency Core Cooling System and Reactor Core Isolation Cooling System Lineup, Operational Conditions 1, 2 and 3 ST-6-107-885-2.
Thermal Limits Determination for Two Recirculation Loop Operation No deficiencies were identified.
5.0 Maintenance Observations (62703)
The inspector reviewed the following safety related maintenance activities to verify that repairs were made in accordance with approved procedures, i
and in compliance with NRC regulations and recognized codes and standards.
l The inspector also verified that the replacement parts and quality control utilized on.the repairs were in compliance with the licensee's QA program.
No deficiencies were noted.
.i 8909092 Unit 1 Equipment Pit Draining and Decontamination 8983488 D-13 Emergency Diesel Generator (EDG) 18 Month Inspection i
8905401 Repair' Air Leak on 0-13 EDG Air Receiver 901919 Repair Bolting to D-13 EDG Exhaust Piping N/A Unit 2 RPS Static' Inverter Troubleshooting The D-13 Emergency Diesel Generator was-removed from service on March 26 to perform the routine 18 month inspection and to complete various minor corrective-maintenance items. The work was performed in accordance with I
approved' preventive maintenance procedures and work instructions. The
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maintenance foreman closely supervised the mechanics and ensured quality
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control hold points were observed and properly documented. When improper clearance was encountered on the engine-blower assembly, vendor assistance was obtained. -The maintenance foremen closely supervised the vendor
personnel actions and were instrumental in effecting the proper resolution.
d The inspector found the diesel gener'ator maintenance to be well controlled.
The work was completed on April 3 and retesting commenced on April 4.
I The diesel was declared operational on April 7.
A detailed review of the maintenance program is being performed by the l
resident inspector staff and the results will be documented in a future
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6.0 Radiological Controls On March 16, 1990, a bag of trash was discovered on the Unit 1 Reactor Building 313 foot elevation (near the reactor water cleanup hold pump rooms) with a dose reading of 100 mr/hr on contact and 8 mr/hr at 18 inches.
The bag was located in a non-posted area.
The area around the trash bag was immediately posted as a radiation area and the bag was appropriately labeled.
The inspector questioned a licensee health physics representative regarding circumstances surrounding this bag.
The licensee's investigation-revealed that a decontamination (decon) effort had been performed at a floor drain on elevation 313 foot on March 7, 1990.
The floor drain had backed up while draining the fuel floor equipment pit. Apparently due to the decon effort being performed late in the day, the health physics (HP)
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personnel rushed to complete +.he assignment and the dose rates on a group of rags and Scotch Brite were tissed. The HP technician stated he had asked radwaste to pull the trash (prepare trash bag for HP to measure dose rate and label) from the waste receptacle that afternoon.
However, the bag was not pulled by radwaste, because the department had no one scheduled for afternoon shift. Subsequently, the bag remained on the 313 foot elevation until March 15 when radwaste pulled the trash.
However, at this time health physics was not informed that the bag had been pulled and was ready to be labeled. On March 16, an HP technician, en routine walkdown, discovered the bag and took appropriate action.
During the time the trash bag was on elevation 313 foot, a weekly radiation and contamination area survey was performed by an HP technician.' The survey did not specifically show dose rates on the bag, however, they did show general area dose rates in normally traveled areas past the bag to not have increased above the nominal 2 mR/hr. Therefore, the licensee concluded that-dose to personnel from this bag was minimal.
The inspector questioned the HP representative regarding why radwaste did not take a dose reading of the bag when it was pulled on March 15. The representative stated that the current procedure only requires radwaste-to pull trash bags and inform HP of the location of the bags.
The. inspector also questioned a licensee maintenance representative regarding the floor drain back up and if a procedure was used for draining the equipment pit. The representative stated that t. Troubleshooting Con-trol Form (TCF) was being used for draining the pit and that the floor drain back up resulted in only a minor spill of water.
The inspector reviewed the TCF and found it to be appropriate for controlling the work.
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Corrective actions included implementation of a Radchecker Program
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(procedure RW-160) by which Radwaste personnel are required to perform
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preliminary radcheck for contact radiation on each bag of waste.
Training of the. personnel on RW-160 is in progress.
Personnel involved in this incident were counselled on the importance of attention to detail and
communication of job status to fellow workers and supervision.
And, a letter stressing the importance of attention-to detail during routine HP survey surveillances was issued to all HP technicians. The inspector found PECo's corrective actions appropriate and had no further concerns.
7.0 Emergency Service Water Microbiologically Induced Corrosion Emergency Service Water (ESW) system fouling has been an issue of concern at Limerick Generating Station (LGS) since prior to commercial operation of Unit 1.
During the second refueling outage for Unit 1, sections of the
'B' loop of ESW-piping were replaced due to aging (corrosion degradation)
of the pipe, in order to ensure sufficient system flows to support two
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unit operation.
Samples of the deposits obtained from the ESW piping were analyzed. The results indicated that the fouling problem was caused by general iron corrosion products and not from silt / mud deposition, micro-biological fouling or microbiologically induced corrosion (MIC).
Several actions were taken to ensure the ESW system would continue to meet its required demands and support operability including quarterly flow balancing of the ESW system and periodic inspution of piping and components.
In July 1989, LGS experienced the first through wall failure on ESW pipe.
A pin-hole leak was discovered on the three inch line that supplies the Unit 1 HPCI room unit coolers.
In August 1989, a section of pipe approxi-mately four feet long was removed to effect repairs. The pipe was then cut into two samples and sent out for failure analysis.
Nalco Company inspected the segment with the failure, and an independent consultant, Heat Exchanger Systems (HES) inspected the 'other.
In both samples, the corrosion mechanism was general corrosion (not MIC) with the exception of j
the immediate area encompassing the failure. A detailed report indicated the failure was that of a MIC attack at a weld backing ring.
The backing ring, used to ease the field welding process, provided a crevice for organisms to colonize. The organisms are anaerobic in nature.
Once be-neath the backing ring and covered by a small layer of sediment / corrosion products they thrive. The failure or the pipe was characteristic of a MIC attack in that once a perforation occurred the oxygen content increased and microbiological activity was inhibited.
The organisms tend to tunnel parallel to the pipe surface with significant damage to the underlying metal, however, only a pin hole surface flaw is observed. At Limerick, backing rings were used on most field welds (straight to straight pipe)
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i pipe three inches in diameter and larger.
Analyses performed at the Peach Bottom Atomic Power Station for similar through wall failures indicated that the failures they experienced did
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not affect system operability, including seismic concerns.
However, since
the corrosion mechanisms at Peach Bottom and Limerick are different (general corrosion versus MIC) further analysis and testing will be
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required to fully analyze the structural impact of MIC on the pipe.
PEco is currently developing an action plan to address this issue.
The in-spectors found PEco's actions appropriate and will continue to follow
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this issue as part of the routine resident inspection program requirements.
8.0 Review of Periodic and Special Reports (90713)
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Upon receipt, the inspector reviewed periodic and special reports. The review included the following: inclusion of information required by the NRC; test results and/or supporting information consistent with design predictions and performance specifications; planned corrective action for resolution of problems; and reportability and validity of report infor-mation.
The following periodic report was reviewed:
Monthly Operating Report - February 1990 The-inspector had no questions regarding this report.
9.0 Licensee Event Report Followup (90712)
The inspector reviewed the following LERs to determine that-reportability requirements were fulfilled, that immediate corrective action was taken, that corrective action to prevent recurrence was accomplished and that continued operation of the facil.ity was' conducted in accordance with Technical Specifications (TS) and did not constitute an unreviewed safety question as defined in 10 CFR 50.59.
In accordance with the above inspec-tion module the-inspector considers the following reports closed. The inspector had no further comments or questions except as noted.
'LER Number Subject / Comments 1-90-003 A High Pressure Coolant Injection (HPCI) system isolation valve inadvertently isolated during performance of a surveillance test.
The valve closed when the Instrumentation and Controls (I&C) technicians tripped one channel of the isolation logic as directed by the test procedure, without detecting that the other channel of the isolation logic had inadvertently tripped. The logic on this channel was in the tripped condition
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because the Rosemount trip unit intermittently failed
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in'the energized tr.ipped condition due to degradation e
of the Darlington output transistor inside the trip
unit.. The trip unit was subsequently replaced.
The root cause of the trip unit failure is under investi-gation and-a supplement to this LER will be issued, j
1-90-004 Missed primary coolant and gaseous effluent sampling l
analysis'during reactor power changes of more than 15%
j of rated thermal power (RTP)'in one hour.
The missed
sampling and analysis were caused by a procedural defici-i ency which led to inadequate communication between shift i
e personnel. This event occurred on July 8,1989 but was
not identified until February 9,1990. A similar event occurred on September 10,1989 (LER 1-89-052) at which
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time appropriate corrective action to prevent recurrence
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was taken, l
1-90-005 Failure to perform a TS required firewatch inspection-ll within one hour due to personnel inattentiveness.
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Appropriate corrective action was taken including rein-j struction of firewatch personnel on the importance of being thorough and vigilant while on firewatch duty.
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A 1-90-006 The capability to activate the public alert notification
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(voluntary) system (sirens) by the local counties within the Emergency Planning Zone was lost due to equipment 9i problems and personnel error.
In addition, it was noted.
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that no procedure existed for, and only limited personnel
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were capable of, operating the sirens from the Limerick
Station.
Corrective action included generation uf an implementing procedure for siren actuation from the=
Technical. Support Center and formal training.
i 1-90-007 Setpoints for a Main Steam Line Radiation. monitor were set outside required limits due to the issuance of an incorrect background radiation measurement (BRM).
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l personnel error resulted in the Unit 2 BRM being issued instead of the correct Unit 1 BRM.
Corrective action-included unitization and color coding of the BRM log i
book.
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Records Retention and Document Control Programs (39701, 39702)
The inspector reviewed PECo's Record Retention Program for the Limerick l
Station to verify that appropriate records are being retained, controls
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for records storage have been established, and stored records are readily
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The inspector also reviewed PECo's Document Control Program
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to. verify that' adequate measures have been established to control the issuance of documents affecting quality including changes to these docu-
ments.
The inspector specifically looked at the controls for. Technical
Specifications, Administrative and Implementing Procedures, and drawings.
j During the performance of the inspection, the inspector reviewed the
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references and. procedures listed in Attachment 1 to this report.
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addition, the inspector held discussions with various PECo representatives
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regarding the Records Retention and Document Control Programs. To verify satisfactory' implementation of the programs, the inspector requested re-trieval of various' records including Maintenance Request Forms, completed
check off lists and modification packages, and inspected various " controlled" j
procedures in the library of the construction building.
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i 10.1 Record Retention
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At Limerick, all documents are considered to require." Lifetime"
retention. The PECo vault is located inside the protected area and j
is used ~for short term temporary storage of documents prior to ship-ment to the final storage facility near Pittsburgh, Pennsylvania.
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In addition, the Bechtel vault is located on-site outside of the protected area.
Records related to the construction of Unit 2 are
stored within this vault and are currently being turned over to
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PECo for. final storage.
This turnover process is expected to be complete in September 1990.
Overall, the inspector determined that PECo is retaining appropriate records and that stored records are currently retrievable.
However, the inspector noted several areas of concern which are discussed below.
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During review of the Limerick procedures governing record
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retention, the inspector noted that the entire process of
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moving a record from the record user to the record's final i
storage location was not thoroughly documented.
The inspector noted eleven boxes of completed surveillance i
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test (ST), procedures stacked on the floor in the ST'Coordi--
nator's area waiting to be moved to the PECo storage vault.
These boxes are required to be temporarily stored in steel
file cabinets or on shelving in' containers for protection, per A-46.
The inspector noted approximately 35 boxes of procedures
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including STs and preoperational test procedures stacked on the floor around the desks in the Document Administration Center (DAC) on the first floor of the Startup Building.
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Several of the boxes had been in this. location since January 1990. These documents are required to be stored in fire resistant cabinets per procedure RMOSI-1 or in the PECo vault.
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The inspector noted that the quarterly inspection of the PEco
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vault required by procedure RMOSI-6 was not being properly performed.
The purpose of the inspection is to verify that
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-the vault and the records temporarily stored within the vault are in good condition, and that the records are retrievable.
The inspector noted that responsibility for the periodic l
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testing of the Bechtel vault fire detection system and Halon system had not been turned over to PECo, when Bechtel employees who previously had responsibility for this testing left the i
site.
t The inspector discusseo the philosophy'of considering all
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records at Limerick as requiring Lifetime retention with several.PECo representatives from Limerick and Chesterbrook,
.The inspector noted the potential problems which could be-encountered when attempting to retrieve records from the.
system after 20 or more years of storing everything. The PECo-representatives acknowledged these concerns and stated that they are currently reviewing alternative record storage
< methodologies. Current plans are to have'a new records storage; system in place by the end of.1992.
The inspector noted during review of the QA audit of LGS-
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Nuclear Records Management dated July 22, 1988, that several of the aboye issues were also identified by QA.
The response
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to the issues was untimely, (approximately 15 months for final resolution), and the' corrective-action apparently inadequate.
The issues identified by the inspector were promptly acted upon by PECo management. All boxes were moved to appropriate
storage locations. The Administrative Superintendent is currently revising several Administrative procedures to more thoroughly describe the record retention and document control (discussed below) programs and is developing a-permanent solution.to the recurring box storage problem.
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10.2 Document Control The inspector determined that procedures exist for control of l
the issuance of documents affecting quality. However, during L"
a random sampling of the status of the " controlled" procedures in the Construction Building the inspector noted several i
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discrepancies. The inspector noted obsolete procedure revisions, missing procedures, misfiled procedures,- and a missing volume of the Unit I and Common ST-6's with no sign out card. The inspector brought these findings to the attention of PEco management.
Prompt action was taken to begin a review of all controlled documents on site in order to identify the extent
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of the problem and initiate corrective action..Similar -
l discrepancies were noted in all areas with the control room i
having the least number of discrepancies.
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The Code of Federal Regulations, 10 CFR 50, Appendix B,
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Criterion VI states in part that measures shall be established to control the issuance of procedures, including changes thereto, which prescribe all activities affecting quality and that
these procedures, including changes, are distributed to the l
location where the prescribed activity is performed.- These a
requirements are implemented by administrative procedure'A-2,
" Control of Procedures and-Certain Documents." The defici-i encies described above are considered a violation of
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procedure A-2 and criterion VI (50-352/90-13-01).
Based upon the results of this inspection and previously identified document control discrepancies (violations 50-353/89-81-01, 50-352/87-05-01 and 50-352/87-19-01 and IR 50-352/90-02,-
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section 2.2), it appears that inadequate importance has been
focused on the document control and record retention tasks.
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11.0 Security Allegation-
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On March 13, 1990, the Resident Inspector received an anonymous allegation.
The alleger stated that a representative of the licensee's proprietary.
security organization had overridden a determination;made by one of the r
contractor's surveillance testing personnel on March 9, 1990, concerning e
the outcome of a. test (ST-7-084-36) on a portion of a security system.
The alleger contended that, while the contractor's tester considered the equipment-to have failed the test, the licensee's representative found-
the equipment to be acceptable and told those involved in the test to
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document that.the equipment met the testing acceptance criteria.
The alleger further stated that, because the test was documented as being successful a previously established compensatory measure that had been taken while the equipment was being worked on, was removed. The alleger indicated that about three days later the matter was brought to the attention of another licensee representative, who re-established the compensatory measure.
The alleger also stated that no report was made to the NRC concerning this matter and that because of several similar previous occurrences, five testers had. requested to be removed from-surveillance testing duties and returned to the security force, even though the te sting duties commanded higher pay. An anonymous allegation describing similar circumstances was received in Region I on March 20, 1990. The Region I Allegation Review Panel determined that both allegations pertained to the same test.
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On March 30, 1990, a regional security inspector was dispatched to the station'to follow up on this allegation. The inspector reviewed the testing program and procedures, the documented results of the test in question and interviewed representative of the licensee and the security
force contractor.
Because of the. anonymity of the alleger, he could not
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be contacted for an interview.
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The inspector found that ST-7-084-36 was conducted on security-related equipment on March 9, 1990, after work had been performed on the equipment to enhance its performance. During the test, a licensee representative who was in the Central Alarm Station, commented that, while the performance-of the equipment could be better, it was sufficient to meet the acceptance criteria o.f the test. One of the individuals' involved in the test, who was in the field and-could not monitor the equipment's performance, heard the licensee's comment on a two way radio being used during the test and indicated that he believed the acceptance criteria had not been met. The licensee's representative offered to explain his rationale in accepting the test to the individual in the field, but_the individual declined the offer.
The test was completed and.the test documentation was signed by
all individuals responsible for the test. Although two comments appeared on the test documentation, neither indicated that the equipment was not j
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acceptable.
The previously established compensatory measure was removed.
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On March 12, 1990, the individual who was in the field during the conduct of ST-7-084-32 brought the matter to the attention of another security representative of the licensee.
The representative duplicated the test, _
l to the extent practical, and determined that-the equipment's performance was marginally acceptable.
Because there was no technical assistance available at that time (this occurred on the second shif t), he conser-vatively re-established the compensatory measure. When technical assis-tance was available on the following day, the matter was again reviewed.
During-this review the licensee's security group decided that the issue could be resolved by using another piece of equipment, in conjunction with the equipment in question. When that action was taken, the question regarding the acceptability of the first piece of equipment was eliminated.
-The inspector's review of the surveillance test criteria and documentation of the test, together with the interviews conducted, resulted in the conclusion that the original surveillance test was appropriately determined to be acceptable even though there was a potential for better equipment performance (i.e., the equipment met the NRC's performance requirements).
The inspector also found that two other contract security officers, who participated in the original test and were in a position to monitor the performance of the equipment also believed that the test was satisfactory.
Given the forgoing, no report to the NRC was required.
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The inspector also found that four of the contract security officers had'
, requested to be removed from their duties as surveillance testers in the
- recent past, as a result of several similar occurrences.
However, three of the four requests were retracted after the licensee and the contractor's management met with the assigned testing personnel to reinforce the licensee's position that personnel involved in testing should document
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.any disagreement regarding the outcome of a test in the test procedure.
(The fourth request was not related to this type of issue.) As a result of these types.of issues, the licensee developed and implemented a formal prograr requiring documentation and review by a technically qualified group when there is any question about the acceptability of security-systems' and equipment performance.
The inspector reviewed this program
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and found it acceptable to resolve this-kind of issue in the future.
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While the inspector generally substantiated the facts presented in-the allegation, he found that no violation of NRC requirements had occurred,
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that the licensee had been responsive to the issue when it was raised and that the licensee had acted responsibly in implementing a review program to reduce the probability of such issues from recurring. The inspector had no futher questions on this matter.
12.0 Evaluation of PECo Self-Assessment Capability (40500)
The resident inspectors reviewed PEco's activities and plant operation since the last Systematic Assessment of Licensee Performance (SALP) to ascertain continuing trends and to identify any new strengths and weak-nesses in PECo's operation of Limerick. During this assessment the resident inspectors reviewed Licensee Event Reports (LERs), the last SALP, Inspcction Reports, Monthly Operating Reports, Quality Assurance Audits and NRC Violations in order to compile the assessment.
The following is the results of this inspection, as well as PECo's own assessment of their-performance.
On March 13, 1990, a meeting was held at Limerick for PECo to present their self assessment to the NRC.
(Attachment 2 is the list of Meeting
. Attendees and Attachment 3 is PECo's presentation) After the PECo presen-tation, PECo's self essessment was compared to the NRC evaluation of the identified strengths and weaknesses which had been developed prior to the l
meeting. This comparison resulted in the following:
The licensee addressed all of tha NRC's identified weak areas and
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l identified improvement measures to be followed in order to strengthen these areas.
There was noted improvement in the two areas that were identified
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in the last SALP as requiring increased management attention:
Engineering off-site support to the site and emergency planning.
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New areas of concern highlighted were:
the unsatisfactory grades
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J on the requalification of licensed operators examination conducted by the NRC on January 29 - February 2,1990; the recently identified-concerns in plant security system maintenance; and the high percen-tage'of LERs attributed to personnel error (nine out of 25).
'
Strengths of the licensee's program appear to be consistent with
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the strengths noted in the last SALP.
These strengths include good
- st.lf assessment, critical assessments of root causes, excellent operational history with absence of plant trips, minimal number of.
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NRC. violations and management's desire to operate a safe facility
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as evidenced by prompt correction of identified concerns and problems in a safe and efficient manner.
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At the close of the meeting, NRC management reiterated the need to closely follow personnel. error concerns and the continued vigilance over the entire operation of the facility in order to correct short comings and enhance the strengths noted.
13.0 Exit Interview (30703)
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The NRC resident inspectors-discussed the issues in this report with the licensee throughout the inspection period, and summarized the findings at an exit meeting neld with the plant-manager, Mr. M. J. McCormick, Jr. on April 6, 1990. No written inspection material was provided to licensee
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representatives during the inspection period, i
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ATTACHMENT 1 L
i RECORDS RETENTION AND DOCUMENT CONTROL Reference Documents i
ANSI /ASME N45.2.9-1979, Requirements for Collection, Storage, and Maintenance
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of Quality Assurance Records for Nuclear Power Plants ANSI N18.7-1976, Administrative Controls and Quality Assurance (QA) for the Operational Phase of Nuclear Power Plants Limerick Generating Station (LGS) Technical Specifications, Section 6, Adminis-
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trative Controls 10CFR50, Appendix B-LGS Final Safety Analysis Report, Section 17.2.17, Quality Assurance Records Regulatory Guide 1.33, QA Program Requirements (Operation), Revision 2, February 1978 Documents Reviewed Administrative Procedure (A)-2, Control of Procedures and Certain Documents, Revision 5
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A-6, Control and Distribution of Drawings, Manuals, and Drawing Logs, Revision 2 A-29, Control of Revisions of License Documents, Revision 2
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A-46, Maintenance of Plant Quality Assurance Records, Revision 2 RMOSA-1, Administrative Procedure to Control Records Management and Office
~ Services Section (RMOS) Procedures, Revision 5 RMOSI-1, Creating PEco's Record Copy of Submitted Nuclear Related Documents, Revision 6 RMOSI-2, Retrieving Information from the Nuclear Records Management System (NRMS), Revision 4 RMOSI-6, Utilizing PECo Storage Vault by the Limerick Generating Station Document Administration Center (DAC), Revision 7
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RMOSI-7, Periodic Verification of Correctness of Controlled Copy Sets of LGS i
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Procedures, Revision 2
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f RMOSI-8, Duplication and Distribution of LGS Procedures, Revision 3 l
RM051-9. Receipt, Distribution and Control of Instruction Manuals at LGS,
Revision 2
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[
-RMOSI-10, Processing and Control of Limerick Generating. Station Quality Assured
]
L Operating Charts and Recordings,. Revision 3'
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RMOSI-11, Receipt and Control of Drawings and Drawing Logs at LGS,-Revision 4 l
Nuclear Records Management System, Nuclear Related Document Register, January l
P 1990
Routine Test, RT-2-022-600-0, NRMS Vault Fire Detection Instrumentation-
,
Functional Test, Revision 0
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-Quality Assurance' Department Audit Report AL88-71 PR, LGS Nuclear Records
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ManagementnJuly 22, 1988 t
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ATTACHMENT 2 MID CYCLE SALP - MARCH 13, 1990
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LIMERICK GENERATING STATION I-ATTENDANCE LIST PECo G.- J. Madsen, Regulatory Engineer J..T. Smugeresky, Project Manager F. A. Cook, Section Manager G. A. Hunger, Jr... Director-Licensing J. F. O'Rourke, Manager-Limerick Quality Division e
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i L. B. Pyrih, Manager, Engineering Division K. B. Weisbend, Plant Division-Engineer B. Tracy, Test Engineer D.-8. Neff, Licensing Engineer V. J. Cwietniewicz, Superintendent-Training J. Doering, Project Manager i
E. P. Fogarty, Manager, Nuclear Support
.C. L. Adams, Director, Emergency Preparedness P. J. Duca, Jr., Support Manager G. M. Leitch, Vice President M. J. McCormick, Jr., Plant Manager R. C. Brown, Site Emergency Preparedness Supervisor K. W. Meck, Reports Supervisor
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NRC
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J. Wiggins, Deputy Director A. R. Blough, Branch Chief L. Doerflein, Section Chief T. Kenny, Senior Resident Inspector L. Scholl,. Resident Inspector M. Evans, Resident Inspector J.' Nakoski, Reactor Engineer C. Gordon, Emergency Prepatedness Specialist R. Clark, Limerick Project Manager E. Trottier, Project Manager State of Pennsylvan,ia A. K. Bhattacharyya, Nuclear Engineer
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d ATTACHMENT 3
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AGENDA
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1. OVERVIEW G. M. LEITCH
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2..QRTLY. SELF-ASSESSMENT RESULTS M. J. McCORMICK-3. OVERVIEW OF TRAINING PROGRAMS V. J. CWlETNIEWICZ 4. SECURITY P.J.DUCA 5. EMERGENCY PREPAREDNESS P. J.- DUCA
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O. ADAMS
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6. ENGINEERING SUPPORT L. B. PYRIH
7. QUALITY ASSURANCE ASSESSMENT J. F. O'ROURKE 8. SUMMARY REMARKS G. M. LEITCH 9. OPEN DISCUSSION
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INTRODUCTION
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SPEAKERS j
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i GENERAL COMMENTS
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UNIT 1 OPERATION SUMMARY
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.. UNIT 2 STARTUP/
OPERATION SUMMARY CURRENT PLANT STATUS
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1 INTRODUCTION
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o SELF ASSESSMENT PROCESS i
o PLANT DIVISION OVERVIEW
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- NEW INITIATIVES
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- ACCOMPLISHMENTS i
- WATCH AREAS
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o SUMMARY & CONCLUSIONS
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SELF ASSESSMENT PROCESS
1. ADEQUACY OF UNIT 1, UNIT 2, AND COMMON SYSTEMS FOR SAFE AND RELIABLE OPERATION 2. CONTROL ROOM OPERATIONS AND PROFESSIONALISM 3. TEAMWORK AND COMMUNICATIONS
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4. ENGINEERING AND MAINTENANCE SUPPORT SERVICES 5. ORGANIZATIONAL INTERFACES ( ONSITE AND OFFSITE )
F 6. PLANT CONFIGURATION CONTROL l
7. PROCEDURAL ADEQUACY AND EFFECTIVENESS l
OF IMPLEMENTATION l
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l 8. REVIEW OF AUDITORS IDENTIFIED ISSUES /
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WHY NOT SELF IDENTIFIED
ASSURANCE OF QUALITY OVERALL
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I OPERATIONS SECTION o NEW INITIATIVES
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-SR. SHIFT PERSONNEL INTO LINE RESPONSIBILITY
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- EQUIPMENT STATUS CONTROL
- PLANNING AND SCHEDULING INTERFACE
o ACCOMPLISHMENTS
- EXTENDED QUALITY RUNS /NO SCRAMS
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- TRANSITION FROM 1 UNIT TO 2 UNIT
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OPERATIONS IN A PROFESSIONAL MANNER i
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o WATCH AREAS
- MANAGEMENT INATTENTION TO ROUTINE PROGRAMS
- ADEQUACY OF CORRECTIVE ACTIONS
- REQUAL PROGRAM FOR LICENSED OPERATORS
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L MAINTENANCE SECTION
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o NEW INITIATIVES
- 13 WEEK ROLLING SCHEDULE
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- WORK TEAM DEVELOPMENT
- PLANNING AND SCHEDULING o ACCOMPLISHMENTS l
- ROOT CAUSE ANALYSIS ( HPES )
- SUPERVISOR SELECTION-ACADEMY
- MRF COMPLETION RATE / DAY IMPROVEMENT o WATCH AREAS
- NEW ORGANIZATIONAL CONCERNS /
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( IBEW )
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- CORRECTIVE MRF BACKLOG /
UNIT 1 (OUTAGE-NONOUTAGE)
- OVERDUE PM MRF INDICATOR
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LIMERICK UNITS 1 & 2 L
CM BACKLOG INDICATOR MRF'S GREATER THAN 3 MONTHS OLD i
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L PERCENTAGE
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-+H INPO MEDIAN O
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ilMERICK UNITS 1 & 2 i
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PM OVERDUE INDICATOR'
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INPO MEDIAN t
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BEST QUARTILE i
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lNDICATOR FOR UNIT 1 E INDICATOR FOR UNIT 2.
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+ INPO MEDIAN O
INPO BEST QUARTILE
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SERVICES SECTION t
o NEW INITIATIVES
- DECREASE UNIDENTIFIED AND TOTAL LIQUID RADWASTE
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- MINIMlZE DISCHARGE OF LIQUID RADWASTE DUE TO EHC CONTAMINATION
,;
o ACCOMPLISHMENTS l
- LOW RADIATION EXPOSURE /
PERSONNEL CONTAMINATIONS
- NO FUEL FAILURES
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- GOOD CHEMISTRY PERFORMANCE l
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INDICATORS l
L o WATCH AREAS L
- UNIT 1 CONDENSER LEAKS
- CONDENSATE DEMIN RUN LENGTHS
- SURFACE AREA CONTAMINATION
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( W/ REDUCED STAFF )
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TECHNICAL SECTION
o NEW INITIATIVES RELOCATION / REORGANIZATION
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NED/ LGS SYSTEM ENGINEER WALK
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SYSTEM DOWN TOGETHER o ACCOMPLISHMENTS LOW NUMBER OF TCA'S
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INTERIM MODIFICATION PROCESS
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r o WATCH AREAS SNM ACCOUNTABILITY
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REACTIVITY MANAGEMENT
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I SUMMARY AND CONCLUSION
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o OVERALL PERFORMANCE - SUPERIOR o MANY NEW INITIATIVES / UNDERWAY l
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o WATCH AREAS IDENTIFIED AND MONITORED
o LER TRENDS
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o COMMITMENT TO MAINTAIN QUALITY OF OPERATIONS (THROUGHOUT ALL PROGRAMS WITH TIGHTER BUDGETS)
o NRC / PECo HAVE MUTUAL GOALS
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LGS NUCLEAR TRAINING SECTION
TOPICS INPO
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EMERGENCY RESPONSE ORGANIZATION
(ERO) TRAINING SIMULATOR CERTIFICATION
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L LICENSED OPERATOR REQUALIFICATION
(LOR) PROGRAM
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ROOT CAUSE ANALYSIS PREVIEW
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NUCLEAR TRAINING SECTION (NTS)
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INITIATIVES FOR 1990 ASSESSMENT OF NTS PERFORMANCE
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INPO I
o ACCREDITATION RENEWED (1/90)
j NON-LICENSED OPERATOR REACTOR OPERATOR SENIOR REACTOR OPERATOR / SHIFT SUPERVISOR LICENSED OPERATOR REQUALIFICATION SHIFT TECHNICAL ADVISOR
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TECHNICAL STAFF & MANAGERS i
O ACCREDITATION TEAM VISIT (2/12 - 2/16/90)
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I&C ELECTRICAL MAINTENANCE
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j MECHANICAL MAINTENANCE
HEALTH PHYSICS l
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CHEMISTRY l
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o AWAITfNG DRAFT REPORT g
l-CONCERNS IDENTIFIED:
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1. MAINTENANCE INITIAL TRAINING-EXAM QUESTIONS MORE STRIGENT THAN OBJECTIVES 2. MAINTENANCE CONTINUING TRAINING-REVIEW AMOUNT OF TRAINING PROVIDED IN CERTAIN AREAS o POSITIVE FEEDBACK ON PROGRAMS
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L EMERGENCY RESPONSE i
l ORGANIZATION TRAINING
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o TRAINING FOR MCR EMERGENCY DIRECTORS-CLASSROOM FOLLOWED BY " TABLETOP" USING SIMULATOR l.
o EP DRILLS WILL BE PERFORMED USING SIMULATOR COMMENCING 3/15/90
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o MINI DRILLS SUPPORTED BY NTS
- o TRAINING PROGRAM PLAN FOR ERO PERSONNEL APPROVED
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SIMULATOR CERTIFICATION
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FUNCTIONAL FIDELITY o 30 (OF 61) TESTS PREPARED
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o 30 (OF 61) TESTS PERFORMED PHYSICAL FIDELITY o COMPARISON OF SIMULATOR PANELS TO MCR PANELS IS COMPLETE
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o 35% OF HUMAN FACTORS ENHANCEMENTS
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COMPLETED IN SIMULATOR
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CONFIGURATION MANAGEMENT SYSTEM o FULLY IMPLEMENTED
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o IN USE TO TRACK MODS, DISCREPANCIES, ETC.
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SUMMARY o PERFORMANCE TESTING (PT)
COMPLETED BY 6/90
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o PHYSICAL FIDELITY CHANGES ARE ONGOING
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LOR PROGRAM - ROOT CAUSE ANALYSIS PREVIEW o PURPOSE lDENTIFY DEFICIENCIES & WEAKNESSES ASSOCIATED l
WITH LICENSED PERSONNEL PERFORMANCE t
DURING THE 1990 ANNUAL EXAMS.
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o ANALYSIS METHODS
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BARRIER ANALYSIS CHANGE ANALYSIS ROOT CAUSE TREE TECHNIQUE o CAUSES IDENTIFIED
PWARY FACTORS o !!dUFFICIENT MANAGEMENT ATTENTION TO STAFF LICENSE TRAINING
o PERSONNEL MEETING MINIMUM STANDARDS -
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NOT IMPROVING o TIME VALIDATION INADEQUATE o COMMUNICATIONS NOT EMPHASIZED OUTSIDE SIMULATOR o PERFORMANCE STANDARDS NOT EMPHASIZED
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IN WEEKLY TRAINING
' SECONDARY FACTORS i
o TWO MONTH PERIOD WITHOUT TRAINING
PRIOR TO EXAM
o EXAM BANK QUESTIONS / ANSWER SOLICITATION o T-200 SERIES PROCEDURES / HUMAN FACTORS o SYSTEM MANIPULATIONS / CONSISTENCY OF OPERATION PREPARED TO DISCUSS THE ROOT CAUSE ANALYSIS
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WITH NRC ON 3/15/90
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NTS INITIATIVES FOR 1990
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SYSTEM ENGINEER PROGRAM
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o PHASE Ill OF TECHNICAL STAFF
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DEVELOPMENT PROGRAM o FIRST SESSION TO START 7/90 EP DRILLS ON SIMULATOR o REQUIRED SEVERAL MODS
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o INTENSIVE PREPARATION EFFORTS l
l LIMITED LICENSE SRO PROGRAM o FUEL HANDLING DIRECTORS FOR UNIT 1 OUTAGE
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r ASSESSMENT OF NTS PERFORMANCE i
OBSERVATIONS
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o ACCREDITATION RENEWAL / POSITIVE FEEDBACK FROM ATV o CANDIDATES (9/9) PASSING GFE o STRONG INTERFACE WITH & SUPPORT FROM PLANT ORGANIZATION o GOOD PERFORMANCE OF UNITS 1 & 2-l J
KEY AREAS.FOR 1990
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o ENHANCEMENT OF LICENSEHOLDER l
PERFORMANCE IN LOR
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o STEADY STATE STAFFING GOALS
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o ACCREDITATION RENEWAL FOR REMAINING PROGRAMS
SUMMARY STATEMENT OVERALL PERFORMANCE IS STRONG, BUT SPECIAL
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ATTENTION & EFFORTS WILL BE NEEDED IN L
THE LOR PROGRAM TO ENSURE CORRECTIVE L
ACTIONS ARE EFFECTIVE IN ENHANCING l
LICENSEHOLDER PRFORMANCE.
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STAFFING
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PREVENTATIVE MAINTENANCE i
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PROGRAM
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LIMERICK UNIT 1 & 2
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COMPENSATORY POSTING HOURS
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1400 1200
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1000
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400 STE ADY STATE BUDGET 200
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D J
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A 1990
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E HOURS STEADY STATE BUDGET
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i CURRENT CAPABILITY
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EMERGENCY RESPONSE
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TRAINING
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ENHANCEMENTS
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b ACTION PLAN
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EMERGENCY PREPAREDNESS l-ACTION PLAN SUMMARY i
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o PROGRAM DEFINITION i
o COMMITMENT TRACKING o MEDICAL / ACCOUNTABILITY / EVACUATION i
o ERO DESIGNATED / TRAINED / READY i-o ERO TRAINING / QUALIFICATION
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NUCLEAR ENGINEERIN'G
SELF-ASSESSMENT e Level of Effort Support (12/89 - 2/90)
t e Engineering Work Requests
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- 17% decrease in Backlog
- Improving Trend i
e NCR Dispositioning
- No change in Backlog
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- No adverse Trend e Engineering Review Requests
!-
- Slight increase in overdue i
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- Watch Area
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l e Mod Support o Unit 1 Outage Mods
- 7 of 24 Mods did not achieve Rev A milestone of 1/20/90
- 2 of 24 Mods will not make Rev 0 milestone of 4/13/90
- As Building
- Backlog of As Building Drawings restraining closure of I
Mods and NCR's-
- Action Plan being developed to restructure As Building Program
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NED/ LGS INTERFACE l
0 Key lasues from Root Cause Analysis
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e NED's lack of appreciation of Station needs e Loss than adequate teamwork between NED
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and LGS e Failure of both NED & LGS Managers to
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i establish clear and mutual expectations e Actions:
e Meeting of Vice Presidents on 1-22-90 i
e Meetings of Vice Presidents & Senior l
Managers of NED & LGS
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- 2-7-90 - Team Building, discussion of Issues and assignment of Teams to develop Action Plans
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- 2-28-90 - Review & Approval of submitted Action Plans, Resource Requirements & Schedules
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e Next action is Presentation to NRC and implementation l
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- Improve NED Work Processes and Products
- Establish a Quality-Oriented and Customer-Focused Culture
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- Quality improvement Kickoff Meeting 2/21/90 l
- All NED Managers and Supervisors plus selected
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- Plans for the Year and Quality Expectations e Management Overview Meeting 3/7/90
- Course outline and samples of Personal Quality l
Training to be given to all employees
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- Sustaining Sponsorship
- 1990 NED Goals e Schedule for Training being established e Employee Recognition Activities begun 2/27/90 o NED Newsletter to address Quality Issues and Employee
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Recognition under development Ota6Nvtew ADC (3/12/90)
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- NRC REVIEWS OF AUDITS
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- RESOLUTION OF ISSUES WITH PLANT PERSONNEL.
- PLANNING -AND REVIEW OF MRFs
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