IR 05000352/1992099
| ML20059J674 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/05/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059J666 | List: |
| References | |
| 50-352-92-99, 50-353-92-99, NUDOCS 9311150008 | |
| Download: ML20059J674 (7) | |
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
LIMERICK GENERATING STATION REPORT NO. 50-352/92-99 & 50-353/92-99 I.
BACKGROUND The Limerick Generating Station SALP board convened on October 7,1993, to assess the
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nuclear safety performance of Limerick Units 1 and 2, for the period March 15,1992, to.
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September 25,1993. The Board was conducted pursuant to U.S. Nuclear Regulatory Commission (NRC) Management Directive (MD) 8.6 (see NRC Administrative Letter 93-02). Board Members were Richard W. Cooper (Board Chairman), Director, Division of Reactor Projects, NRC Region I (RI); Charles L. Miller, Acting Deputy Director, Division of Reactor Safety, NRC RI; Charles W. Hehl, Director, Division of Radiation Safety and
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Safeguards, NRC RI; and Michael L. Boyle, Acting Director, Project Directorate I-2, NRC
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Office of Nuclear Reactor Regulation. The Board developed this assessment for approval of the Region I Administrator.
The performance category ratings and the assessment functional areas used below are defined and described in NRC MD 8.6, " Systematic Assessment of Licensee Performance (SALP)."
II.
PERFORMANCE ANALYSIS - OPERATIONS Plant operations was rated a SALP Category 1 in the previous SALP period. This was based on strong, conservative plant operation by knowledgeable and professional operators, an aggressive approach to identifying and solving problems, and a reduction in personnel errors through management attention. Improvements were noted in the requalification training program; however, weaknesses existed in the Limited Senior Reactor Operator (LSRO)
training program.
Safe operating runs oflong duration for both units were achieved over the SA.LP period as a result of close operations management oversight and proactive problem identification and resolution. Operations personnel effectively implemented short-term compensatory measures r
for the generic boiling-water reactor (BWR) vessel level instrumentation problem, including
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increasing operator knowledge and capability of recognizing level anomalies. In addition, operations personnel were integrally involved in a comprehensive station assessment of the failed. fuel problem at Unit 2 that resulted in conservative changes in plant operation and
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preparations for shutdown for refueling that minimized personnel exposures. Additionally, i
plant operators were aggressive in identifying steam leaks in the plant, and facilitating repairs
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by support organizations, which further reduced personnel exposure.
Operators continued to exhibit outstanding command and control in response to plant challenges during this SALP period. Significant examples included prompt recognition and
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response to loss of level in the reactor cavity during a refueling outage as a result of a l
maintenance error; operator response to several Unit 2 events including several engineered safety features (ESF) actuations, a reactor scram, a turbine runback, and a recirculation pump runback; and a Unit I reactor scram and resultant feedwater transient that affected both units. The significance of this continued strength is made more noteworthy when considering
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the change, during the SALP period, to a 12-hour shift rotation. The lack of an adverse
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impact on plant operation was attributed to insightful monitoring through established performance indicators during the transition.
The licensee implemented a strong operator training program. This was exhibited by a high pass rate for initial examinations, improved LSRO training, and enhanced use of the plant
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reference simulator to train operators on special plant evolutions. The effectiveness of the latter training was demonstrated by appropriate operator response to events, such as feedwater transients, for which evolution-specific training was conducted.
During the SALP period, some personnel errors were observed in procedural adherence and in maintaining proper system configuration control. These problems were infrequent, singular in nature, and of minor safety significance. Although these problems were mostly related to the conduct of maintenance, the licensee appropriately involved operations personnel in a station initiative to assess the problems broadly for root cause and appropriate
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corrective action. This initiative was still ongoing at the end of the SALP period.
In summag, operations continued its strong performance over this SALP period. This was
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characterized by strong management involvement in daily plant operations; an effective, v/ ell-
formulated and implemented training program; excellent command and control in normal i
operation and event response; and proactive problem identification, root cause determination, l
and corrective action. Although some isolated, minor personnel errors occurred, operations
was significantly involved at the end of the SALP period in a rigorous assessment with other
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station departments to formulate and implement corrective actions.
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The operations area is rated a Category 1.
III.
PERFORMANCE ANALYSIS - ENGINEERING In the previous SALP period engineering was rated a Category 1. The engineering organization provided excellent initiatives to improve the safety and reliability of the plant and to increase the effectiveness of engineering in support of plant operations.
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Communications between the site and corporate engineering and technically competent personnel were considered as strengths. Weaknesses were identified and appropriate actions were taken toward improvement.
During this SALP period, proactive management involvement and support were evident in the implementation of the Nuclear Effectiveness and Efficiency Design Study (NEEDS)
mcommendations and other engineering activities. A technically competent professional engineering staff coupled with very effective external and internal communications were instrumental in the successful completion of important engineering tasks to enhance the safety of the plant. A strong corrective action program was evident. Weaknesses generally were addressed by engineering in a prompt manner with a few isolated corrective action-deficiencies.
As the NEEDS recommendations were implemented, the engineering organization continued
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to provide effective and efficient engineering guidance and direction to the plant. It also
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displayed excellent teamwork and good communications between corporate and site engineering in all phases of the plant design modification process. Good safety perspectives
and excellent engineering practices were demonstrated in such plant design modifications as the setpoint change for reactor enclosure blowout panels, the corrosion monitoring system for
the residual heat removal (RHR) heat exchanger, installation of additional control rod drive i
isolation boundary check valves, and the feasibility studies and conceptual design of the
emergency service water and RHR service water improvement programs. Daily engineering and management support for the plant outage activities was a strength which ensured prompt j
resolution of safety issues as they were identified. That interaction was further enhanced
with monthly meetings between plant engineering and centralized corporate engineering.
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Excellent technical expertise, project management skills, and experience were evident in the i
planning and implementation of major engineering projects to support the plant. A few i
examples were the Shoreham fuel transfer to Limerick, the integrated nuclear cable
.l management system, the as-built reconciliation program of mechanical piping, and the power i
rerate.
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't In summary, the engineering organization demonstrated a strong sense of commitment by providing excellent support to plant activities with a technically competent professional -
engineering staff. Effective external and internal communications were evident in the success
of important engineering tasks in support of the plant. Exceptions were minor, isolated and i
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promptly corrected.
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l The engineering area is rated as a Category 1.
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F IV.
PERFORMANCE ANALYSIS - MAINTENANCE
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During the previous SALP period the Maintenance / Surveillance functional area was rated as Category 2. Overall, the maintenance and surveillance programs were effectively implemented. Major maintenance tasks were well controlled. Nonetheless, problems with inattention to detail and procedural adherence were noted during several maintenance
activities. Management was not always effective in resolving issues related to repeated incidents of failure to adequately plan corrective maintenance tasks and to implement maintenance procedures.
Over this SALP period, maintenance and surveillance programs continued to be effectively
implemented. Station management involvement was proactive in implementing many positive -
initiatives. For example, maintenance management meetings were initiated to address procedural nonconformance issues. These meetings were expanded in scope to address both technical and administrative problems and resulted in improved maintenance department performance. A significant decrease in corrective maintenance backlog was achieved, and effective actions were taken to gain control of the equipment trouble tag. system. Plant
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management recognized the need to improve the_ quality of written instructions and procedures and is taking action to address this area.
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The Maintenance Department generally controlled and performed maintenance activities well, contributing to very high capacity factors on both units. Material condition for both units was good and each plant was well maintained. For maintenance activities that were required during plant operation, tracking of system unavailability indicated good overall performance, and for systems important to safety, trends were below established goals. A detailed review was conducted that verified adequate controls were established to ensure that parts and materials were appropriately qualified for the intended application. Maintenance generally coordinated its activities well with other departments such as operations, and site and corporate engineering. For example, the communication between maintenance, corporate engineering and other plants (through the BWR Owner's Group) to exchange data toward resolution of the dry grease problem in mechanical snubbers was very good.
There was one plant trip attributed to maintenance activities this SALP-period. An inadequately controlled excavation project resulted in the inadvertent grounding and loss of one of the offsite power supplies which eventually led to a feedwater transient causing a reactor scram on Unit I as a result of low reactor vessel level. This plant trip represented a weakness in management's implementation of the work control process, particularly with interdepartmental communications and understanding of job scope by work crews. Howevcr, timely and comprehensive event followup demonstrated management's commitment to performing detailed event investigations (i.e., root cause,' followup, and corrective actions)
leading to effective resolution of problems. Strong event followup in the maintenance area was a strength throughout this SALP perio,
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In general, management / supervisory oversight of work was good, the workforce was
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knowledgeable, and personnel usually followed procedures. However, personnel errors
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stemming from inattention to detail (an identified weakness last SALP period) and inadequate independent verifications continued throughout this cycle. Management formed an independent verification task force to address these problems. A review of radiological
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violations involving maintenance activities indicated some weaknesses in supervisory
oversight of the work, communications / coordination between maintenance and. Health Physics
oversight personnel, and procedural adherence early in the SALP period.
In summary, the overall performance in the maintenance area improved over this SALP-period. Station cnanagement involvement was proactive as demonstrated by the implementation of many positive initiatives. The implementation of these initiatives has led
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to some improved performance, especially in the last part of this SALP period. However, it is too early to fully assess the effectiveness of some of these initiatives in resolving identified
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weaknesses, and attaining long-term performance improvement.
The maintenance area is rated as Category 2.
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V.
PERFORMAhCE ANALYSIS - PLANT SUPPORT i
This functional area is new, representing a significant change from the previous SALPs. The Plant Support functional area covers all activities related to plant support functions, including radiological controls, emergency preparedness, security, chemistry, fire protection, and
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housekeeping controls.
In the previous SALP the Radiological Controls, Security, and Emergency Preparedness functional areas were rated as Category 1. Performance in radiation protection was
identified as a strength due to continued maintenance of exceptionally low radiation and
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contamination levels in the plant, coupled with the implementation of a strong ALARA
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program. However, weaknesses were identified in attention to detail and in implementation of some site practices and procedures in the radwaste area. The previous SALP noted that
there was a significant breach in radiation protection controls just after the period ended.
The effluent and environmental monitoring programs remained highly effective.
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Performance in the emergency preparedness area was excellent with no weaknesses noted.
Lastly, the previous SALP identified the security program as a strength.
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During the current SALP period, no significant extemal or internal exposures of personnel occurred. However, early in the period the NRC identified significant underlying -
i weaknesses in the radiation protection program. Specifically, communications between the i
radiation protection departments and other groups were not adequate, workers did not always
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adhere to radiation protection procedures and postings, and corrective actions for radiological
events were not effective in precluding recurrence. These weaknesses resulted in a number
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of radiological events, particularly during the first half of the period. The NRC findings
indicated that the licensee's control of significant radiological work activities was not always
effective. In depth licensee reviews initiated mid-period identified similar concerns.
l During the later part of the SALP period, a high level of management attention was directed
to the radiation protection program. For example, the licensee significantly improved the evaluation of radiological control events, as exemplified by an in depth evaludon of the January 1993 under ve rel contamination event. In addidon the licensee established and implemented a special radiation worker training supplement for the Unit 2 outage, revised
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and updated radiological controls procedures to address programmatic weakness, and l
enhanced communications and team work among radiation protection staff and plant work
groups. There was improved quality assurance oversight of program areas. NRC
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confirmation of the effectiveness of these program enhancements has been limited due to the lack of significant challenge to the radiation protection program later in the period. Isolated l
problems involving personnel adherence to radiation protection procedures near the end of the period indicated that the licensee's improvement efforts had not yet been entirely effective. Throughout the period, housekeeping was very good.
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Performance in the radioactive waste handling, storage, processing, and transportation areas (
remained strong and generally well managed. An effective radwaste quality assurance
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program and effluent and environmental monitoring program were implemented. Continued improvement was noted in the calibration techniques for the radiological effluent monitoring
system. However, a lack of coordination and communications between operations and chemistry persor.nel relative to out-of-service effluent monitors led to several occasions of
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missed samples while the monitors were out of service.
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The effectiveness of the emergency preparedness program was evidenced by excellent.
exercise performance with several strengths and no weaknesses, and strong operating crew i
performance during table-top walkthrough drills. Significant management involvement and l
support, a strong training program, and a through audit program were noted. However, late
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i in the period it was determined that the unintermptible power supply to the Technical Support Center had been inoperable for approximately a year, due in part to a lack of i
aggressiveness in pursuing corrective action.
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The overall effectivt.:ss of the security program continued to be excellent. Management attention and involvement continued at a high level, evidenced by further program improvements and enhancements. Maintenance support of security equipment was j
aggressive, resulting in timely repairs and minimal use of compensatory measures. Required program audits were effectively supplemented by frequent self-assessments.
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The fire protection program continued to be effectively implemented. The fire protection and brigade training programs were effective and comprehensive, resulting in a well trained i
staff. Fire systems and protection equipment were well maintained. Fire surveillances were being properly performed.
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Overall, the plant support functions continued to be effective and contributed to the safe plant performance. Although performance weaknesses were evident in the radiation protection area, significant management attention resulted in improvement over the period. However, isolated radiation protection procedure adherence problems continued near the end of the period. Continued strong performance in the emergency preparedness, security, house-keeping, and fire protection programs was noted.
The plant support area is rated as Category 2.
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