IR 05000352/1993029
| ML20059D815 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/22/1993 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059D809 | List: |
| References | |
| 50-352-93-29, 50-353-93-29, NUDOCS 9401100092 | |
| Download: ML20059D815 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No ;
Docket No i License No NPF-39 i NPF-85 i
Licensee: Philadelphia Electric Company .{
Correspondence' Control Desk :l P.O. Box 195 l Wayne, PA ~ 19087-0195 l r
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Facility Name: Limerick Generating Station, Units 1 and 2
Inspection Period: November 2, through December 13, 1993 i
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Inspectors: N. S. Perry, Senior Resident Inspector !
T. A. Easlick, Resident Inspector
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Approved by: ,, / S!fJ Clifforc JL A'nd6rson, Chief Date j Reactor Projects Section No. 2B !
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l 9401100092 931228 PDR ADOCK 05000352 G PDR ,
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EXECUTIVE SUMMARY Limerick Generating Station Report No. 93-29 & 93-29 Plant Operations An independent verification task force, formed by plant management, concluded that based on the number of events and the organizations involved, there is not a broad problem in the performance of independent verifications and double verifications. The only areas where there were recurrences of a deficient independent verification involved restoration of breakers and throttled valves (Section 1.3).
Maintenance Observed troubleshooting and corrective maintenance performed on the Dll emergency diesel generator, following observed smoke and flames on the exhaust manifold during a test run, were performed in a professional manner and in compliance with station procedures (Section 2.1). A periodic maintenance management meeting, attended by the inspectors, provided an opportunity for maintenance foremen to identify a number of problems and to have actions immediately put in place to address each of them (Section 2.2). A Rosemount transmitter, found out of calibration, in the high pressure coolant injection system, was appropriately included in PECo's Enhanced Surveillance Monitoring Program, and was ,
identified as a potential problem transmitter, prior to the calibration test (Section 2.4). l Engineering Overall response was good, and actions taken were prompt, for a PECo identified problem with the technical specification value for specific gravity of the vital batteries (Section 3.1).
Plant Support Radiological protection and security activities observed were found acceptable (Section and 4.2).
Safety Assessment and Ouality Verification A review of the Independent Safety Engineering Group (ISEG) indicated that ISEG has made positive contributions to the Limerick organization, and provides quality recommendations to the plant staff (Section 5.1).
Miscellaneous Three non-cited violations were identified in this report. The first two concerned the failure to drain portions of the spray pond network piping after use and a related failure to report this incident in an LER within 30 days (Section 6.1). The third concerned a failure to adequately perform a detailed review of a surveillance test (Section 7.0).
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TABLE OF CONTENTS EXECUTIVE SUMMARY ...................................... i 1.0 PLANT OPERATIONS ................................... I Operational Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I Event Reports ..................................... I Independent Verification Task Force . . . . . . . . . . . . . . . . . . . . . . . . 2 2.0 MAINTENANCE ....................................... 3 Maintenance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Maintenance Management Meeting . . . . . . . . . . . . . . . . . . . . . . . . . 4 Shoreham Fuel Shipments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 IIPCI Rosemount Transmitter . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3.0 ENGINEERING ........................................ 6 Vital Battery Specific Gravity . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 4.0 PLA NT S U PPO RT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Radiological Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Sec uri ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4.2.1 Protected Area Access Changes . . . . . . . . . . . . . . . . . . . . . . 7 5.0 SAFETY ASSESSMENT / QUALITY VERIFICATION . . . . . . . . . . . . . . . . . 7 Independent Safety Engineering Group ...................... 7 6.0 REVIEW OF LICENSEE EVENT AND ROUTINE REPORTS . . . . . . . . . . . 9 Licensee Event Reports (LERs) . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Routine Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 7.0 FOLLOWUP OF PREVIOUS INSPECTION FINDINGS . . . . . . . . . . . . . . 11 8.0 M ANAG EMENT M EETINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Ex i t I n t erviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 , Additional NRC Inspections this Period . . . . . . . . . . . . . . . . . . . .. . 13 SALP Management Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
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DETAILS PLANT OPERATIONS (71707)'
The inspectors observed that plant equipment was operated and maintained safely and in conformance with license and regulatory requirements. Control room staffing met all requirements. Operators were found alert, attentive and responded properly to annunciators and plant conditions. Operators adhered to approved procedures and understood the reasons for lighted annunciators. The inspectors reviewed control room log books for trends and activities, observed control room instrumentation for abnormalities, and verified compliance with technical specifications. Accessible areas of the plant were toured; plant conditions, activities in progress, and housekeeping conditions were observed. Additionally, selected valves and breakers were verified to be aligned correctly. Deep backshift inspection was conducted on November 11,16,19, and 26 and December 5,10, and 11,199 .1 Operational Overview At the beginning of the inspection period Unit I was in its end-of-cycle coastdown at 98% of rated power. Early in the inspection period, power was reduced to 95% of rated, to facilitate the removal of the number 5 feed water heaters. Following the removal of the heaters, the unit was returned to 100% power and continued to coast down due to fuel burn-up. On November 29,1993, power was reduced to 50% of rated for cleaning of the IC main turbine condenser water box, and preventive and corrective maintenance on hydraulic control units (HCU), for the rod control system. Unit I returned to 90% power on December 3,1993, and continued coasting down for the remainder of the inspection perio Unit 2 operated at full power throughout the inspection period, except for minor power reductions for rod pattern adjustments and surveillance testin .2 Event Reports On November 15, 1993, PECo made a Four-hour report to the NRC pursuant to 10 CFR 50.72. The report concerned a reactor water cleanup (RWCU) system isolation due to a valid high regenerative heat exchanger room temperature of greater than the isolation setpoint
of 122 F. The RWCU primary containment isolation valves isolated and the operating RWCU pumps tripped, as expected. Soon after the system isolation, the steam leak detection alarms cleared and the system remained isolated per procedures, while troubleshooting of the system continued. The cause of the elevated room temperatures was identified as an inadvertent lifting of a pressure relief valve (PSV-109), on the regenerative heat exchange The relief valve was replaced and the RWCU system was restored to operation without l
j incident. The inspectors had no further questions concerning this even {
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'The NRC Inspection Procedures used as Fuidance are listed parenthetically throughout this repor l o
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I 2 Independent Verification Task Force In July 1993, plant management formed an independent verification task force to evaluate problems with the performance of independent verification of restoration (IVOR) and double verification of restoration (DVOR), and to make recommendations to plant managemen During this inspection period a task force meeting was held and attended by the inspectors; representatives from all the plant departments were present, and the discussions included the conclusions and recommendations of the previous task force meeting. They concluded that based on the number of events and the organizations involved, there is not a broad problem in the performance of IVOR and DVOR. There are a large number of actions performed where a verification is performed and there are only a small number of events where the verification failed. The only areas where there were recurrences of a deficient IVOR involved restoration of breakers and throttled valves. The other events involved isolated issues. Although the restoration and verification process together appear to be effective at ensuring proper equipment configuration, there are several enhancements to the verification process that can be made that will improve the accuracy of the original work and improve the verifications. Based on discussions, there appears to be a lack of consistent understanding of the basis for the verification of quality process. Procedure A-C-33, Nuclear Group Process for Verification of Quality, provides a definition of the verification process and is focused on the quality-to-the-line process. Several individuals concluded that there is a need for a clear, concise definition of when a verification is needed. A portion of this definition is provided in A-C-33; however, not all of the organizations that use verifications implement the process as described in the procedure. This has created some confusion at the procedure writer and worker levels of why the verifications are performe Following the discussions of the task forces' conclusions, recommendations were made and responsible plant managers / directors were tasked with the implementation of these recommendations. An implementation schedule was also agreed to at this meeting. The recommendations included but were not limited to the following: Communicate to individuals within the responsible organization the basis for the event investigation corrective actions process. The process is used for correcting causes of errors and establishing a work environment that promotes improvement. Explain the difference between learning from errors and performance counseling (identification of errors is treated non-punitively). Communicate to individuals within the responsible organization the expectation to identify errors found during restoration (near miss) and verification activitie . Review procedure A-C-33 and determine if the definition and criteria are appropriate for use in responsible functional areas. Identify recommended changes / improvements.
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3 Communicate the basis of the verification process, as established in procedure A-C-33, to individuals within responsible organizations. Incorporate the basis into appropriate training programs. Communicate to individuals within responsible organizations the expectation for high quality performance and for getting the job done right the first time. This is intended to obtain reaffirmation of their commitment.
The inspectors found the meeting very open and productive. Further actions taken will be reviewed by the inspectors to ensure that independent verifications meets established requirements and commitments. MAINTENANCE (62703) Maintenance Observations The inspectors reviewed the following safety-related maintenance activities to verify that repairs were made in accordance with approved procedures and in compliance with NRC regulations and recognized codes and standards. The inspectors also verified that the '
replacement parts and quality control used on the repairs were in compliance with PECo's Quality Assurance (QA) progra ,
The following maintenance activities were reviewed:
On November 5,1993, the inspectors observed planned maintenance on the D14 emergency diesel generator. The activities included troubleshooting after the start failure (Section 6.1).
The inspectors observed good procedure adherence and found the workers very knowledgeable of the diesel air start system.
During the week of November 29,1993, preplanned maintenance was performed on the Unit 1 HCUs for the rod control system. This activity was previously performed without incident on August 27,1993. The inspectors observed portions of the maintenance activities, and concluded that they were adequately preplanned and coordinated with operations, engineering, and health physics personnel. Personnel involved were found to be very knowledgeable of the activities.
On November 30,1993, the Dll emergency diesel generator was run for it's monthly operability run per surveillance test (ST)-6-092-311-1, Rev. 28. Shortly after the engine was ,
loaded, a plant operator observed smoke and flames between the number 6 and 7 cylinders, j on the exhaust manifold. He immediately contacted the control room and notified them of the problem. The engine was unloaded and shutdown from the control room, within minutes of the call The plant operator observed that the flames were extinguished as soon as the engine was shutdow ___ The inspectors were notified of the event by the Shift Manager and accompanied him to the initial meeting of the plant staff, to discuss the event. Present at this meeting were the Director of Maintenance, system managers, the plant operator involved with the diesel ST, and other PECo maintenance staff members. The group immediately reviewed all the facts concerning the event and discussed all possible causes for the fire. A comprehensive troubleshooting plan was then developed and implemented. The inspectors observed troubleshooting activities and the corrective maintenance that was done. A troubleshooting control form (TCF) was used in accordance with administrative procedure (A)-41.1, Troubleshooting Plant Equipment.
PECo determined that the flames were caused by an oil accumulation on the exhaust manifold, resulting from a lubricating oil leak from the engine cover above the manifold.
The cover bolts were tightened and the leak stopped. The Dil diesel generator completed its monthly ST run and was declared operable.
As part of the corrective actions for this event, the engine cover bolts were verified torqued on the other seven diesel generators, and inspections were performed to identify any similar problems (none were identified). Additionally, the operations staff has been instructed by plant management to perform a complete wipe-down of the engine prior to, during, and after each diesel run. The inspectors noted that this new practice has been effective in reducing the amount of excess oil on the engine .
In conclusion, the inspectors found the activities concerning the identification of the problem, its troubleshooting, and the corrective maintenance of Dil, were performed in a professional manner and in compliance with station procedures. The inspector had no further concerns with this event. Maintenance Management Meeting On November 9,1993, the inspectors attended a periodic maintenance management meeting.
The meeting was well attended by maintenance management and representatives of planning; training and the Independent Safety Engineering Group (ISEG) were also present. The format of the meeting was structured around each of the maintenance team foremen. The foremen were given an opportunity to discuss strengths, weaknesses, problem / watch areas, and action items to correct any identified problems.
The discussions were always open and very candid. A number of problems were identified by the plant foremen and actions were immediately put in place to address each of them.
The meeting began with a working lunch and continued the rest of the afternoon (approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). This is a large expenditure of plant resources and demonstrates the commitment PECo management has to continue to improve plant maintenance. The inspectors will continue to monitor these meetings and the resulting action item .3 Shoreham Fuel Shipments During this inspection period, additional fuel from Shoreham was received. As of the end of the inspection period,17 of a total of 33 shipments were successfully completed. The inspectors observed portions of the activities conducted at Limerick and concluded that the activities were well controlled and completed. Additional information can be found in NRC Combined Inspection Report 50-352/93-32,50-353/93-3 , HPCI Rosemount Transmitter The Unit 2 high pressure coolant injection (HPCI) system was removed from service on November 28,1993, to perform planned maintenance. On November 29, as part of the planned work, routine test (RT) 2-100-007-0, Rosemount Transmitter Calibration Data Drift Analysis was performed on HPCI high steam flow transmitter PDT-055-2-N057D. This test, which included an Operability Acceptance test (OAT), identified that the low side upper range limit (URL) was unattainable and that the transmitter failed to pass the OAT. The transmitter was declared inoperable. The HPCI isolation valves were already closed for the maintenance activity and the trip unit was placed in the tripped condition in accordance with technical specifications. The procedure then required that plant engineering review the results of the test to determine whether or not the transmitter could remain operable.
A review of the situation by the Shift Manager on November 30, identified that the event was potentially reportable. If this condition had been found while the HPCI system was operable, TS would have required isolating the HPCI steam line primary containment penetration, thus rendering the HPCI system inoperable. This condition alone could have prevented this single train system from performing its intended safety function. Based on the assumption that the transmitter was actually inoperable, PECo made a Four-hour report to the NRC on November 30, in accordance with 10 CFR 50.7 !
Conduct of the RT on this transmitter was part of PECo's Enhanced Surveillance Monitoring i Program in response to NRC Bulletin 90-01, Supplement 1, less of Fill-Oil in Transmitters Manufactured by Rosemount. The program analyzes calibration data, taken from routine j surveillance testing, and operational data comparisons to identify symptoms of fill-oil leakage. The data is then analyzed against the drift limits documented in Rosemount ,
Technical Bulletin No. 4. The result of the analysis is a determination if the performance of i the transmitter is acceptable. If the analysis shows degraded performance, an operability l performance test is performed that includes an expanded span (to 130%) response tes ;
i Engineering review of the transmitter's as found calibration data determined that the )
transmitter was in calibration for its operating range, and satisfied the acceptance criteria for i the TS surveillance requirement (ST-2-055-406-2), and was therefore, operable. The transmitter failed calibrate in the expanded range, but this would not have affected the transmitter in performance ofits TS functio Based on the operability determination for the transmitter, the Four-hour notification made on November 30, was retracted by PECo on December 7,1993. The issue was discussed with the inspectors, who concluded that the event was not reportable. Prior to completion of the HPCI outage, the transmitter was replaced and a satisfactory calibration was performed.
The faulty transmitter was sent to Rosemount to determine if, in fact, there was a fill-oil leak. The inspectors had no further questions concerning this issue. ENGINEERING Vital Battery Specific Gravity During this inspection period, the inspectors were informed that a recently completed vendor audit of the vital battery manufacturer found that the full charge specific gravity for a cell was changed from 1.210 to 1.215 in the mid 1980s. Apparently, the vendor thought the change was insignificant, so PECo was not informed of the change. PECo engineering personnel determined that the TS value was not conservative due to the change, in that the TS limit calls for a maximum of .015 below the manufacturer's full charge specific gravity for operability. Operations personnel were immediately notified of the change, and procedures were revised. Additionally, a comprehensive review of surveillances completed determined that the batteries are operable, and no data could be found to indicate that the batteries ever exceeded the TS limit and would therefore have been inoperable. Based on this review, plant management concluded that the event was not reportable. However, licensee personnel committed to notify the industry through various communication methods.
The inspectors reviewed the actions taken and concluded that overall response was good.
Actions taken were prompt and there was good assurance that the batteries were never in an inoperable condition. PLANT SUPPORT (71707) Radiological Protection During the inspection period, the inspectors examined work in progress in both units including health physics (HP) procedures and controls, ALARA implementation, dosimetry and badging, protective clothing use, adherenx to radiation work permit (RWP)
requirements, radiation surveys, radiation protection instrument use, and handling of potentially contaminated equipment and materials.
The inspectors observed individuals frisking in accordance with HP procedures. A sampling of high radiation area doors was verified to be locked as required. Compliance with RWP requirements was reviewed during plant tours. RWP line entries were reviewed to verify that personnel provided the required information and people working in RWP areas were observed as meeting the applicable requirement _ _ _ .
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, Security Selected aspects of plant physical security were reviewed during regular and backshift hours, to verify that controls were in accordance with the security plan and approved procedure This review included the following security measures: guard staffing, vital and protected area barrier integrity, and implementation of access controls including authorization, )
badging, escorting, and searche .2.1 Protected Area Access Changes l l
j On November 29,1993, the plant security access was moved from the first floor of the Graham Leitch Building, to the newly renovated Technical Support Center (TSC) Buildm l This move, part of the Limerick Generating Station, Master Site Plan, will make the TSC/ Security Building the primary entrance and exit for the plant. The main health physics l control point will be moved to a renovated area on the first floor of the Graham Leitch ,
Building, previously used by security, also in accordance with the Master Site Pla l
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The inspectors observed plant personnel using the new security facility early on the morning of November 29. Additional security guards and security management personnel were j
present to ensure that plant staff were able to access the site without any difficulties. The opening of the facility was well organized, with no problems observed by the inspectors. A .
followup inspection was conducted by NRC Region I security inspectors on December 1, 1993, and is documented in NRC Inspection Report Nos. 50-352/93-31; 50-353/93-3 .0 SAFETY ASSESSMENT / QUALITY VERIFICATION (40500) Independent Safety Engineering Group
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I Limerick's onsite ISEG, required by section 6.2.3 of TS, is composed of five, dedicated, l
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full-time engineers, including the ISEG Manager. The ISEG independently evaluates activities associated with the operation and maintenance of the nuclear units to ensure the appropriate level of nuclear safety is maintained, and makes observations and recommendations to enhance the level of nuclear safety. The ISEG evaluates plant events, industry events, requests from plant and other organizations, plant activities, programs and practices, organizational changes, and any other topic they may be directed to evaluate by internal or industry data, to determine if the level of nuclear safety is appropriate and can be economically enhanced. Listed below are some positive examples that illustrate ISEG's performance and contribution to safet * ISEG provided an assessment of Limerick short-term compensatory actions required by NRC Bulletin 93-03, Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs, including real-time feedback by reviewing documents and attending meeting ,
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- ISEG reviewed Limerick's response to NRC Bulletin 93-02, Debris Clogging of ECCS Suction Strainers. ISEG concluded that Limerick did not have any condition requiring remedial action; however, they recommended that the plant staff evaluate whether a periodic inspection of ECCS suction strainers is warranted as part of the Preventative Maintenance Progra * ISEG reviewed the Unit 2 Refueling Outage Schedule using the ISEG: Guideline for )
Review of Outage Schedules, a relatively new shutdown risk assessment process. The results of the ISEG review were then compared to the Outage Risk Assessment and
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Management (ORAM) computer program developed by EPRI, and both were used to greatly increase the visibility of the higher risk outage evolutions to reduce shutdown ris * ISEG reviewed corrective actic,n effectiveness at the Limerick Generating Station during the past two years. ISEG formed a team of three ISEG engineers and one Chesterbrook Quality Division Assessor to provide recommendations to the station to l improve the effectiveness of developing and implementing corrective action l The ISEG reports are well done and in a form that is useful to the line organizatio Recommendations are sound and properly justified. ISEG produces: 1) Review Reports; 2)
Annual Summary Assessment Reports; 3) bi-weekly reports to PORC; and 4) routine reports ,
to the Director, Nuclear Quality Assurance (NQA) and the Nuclear Review Board (NRB).
The written reports, for each topic evaluated, are in accordance with the ISEG Guidelines :
and the current ISEG Interface Agreement. ISEG recently implemented two initiatives l concerning their report preparation. Draft reports are now reviewed by each engineer in the j group, prior to issuing them to the staff for comment. This has proven to be very helpful l and takes advantage of the knowledge and experience of all the ISEG members when i preparing reports. Additionally, draft reports will be reviewed on a trial basis by the Peach I Bottom ISE ISEG at Limerick has been given direction from D. M. Smith, Senior Vice President, that
"almost without exception, reports should have recommendatioris." The inspectors have observed that ISEG has made positive contributions to the Limerick organization, and does provide quality recommendations to the plant staff. These recommendations are also tracked in the Plant Information Management System (PIMS) with evaluation due dates and responses required from the line organization. The recommendations are then tracked until ISEG verifies completion of all actions. Additionally, ISEG can recommead Corrective Action Requests (CARS) by referring a potential CAR item to the Limerick Quality Division for evaluation and initiation in accordance with station quality procedure The line organization proactively requests ISEG to investigate issues and provide them feedback. At the request of engineering, ISEG compiled a list of causal factors related to problems with raw water safety systems (i.e., ESW, RHRSW). The Raw Water Task Force used this list as a check against the adequacy of existing and pending raw water corrective
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actions. At the request of the Director, NQA, ISEG obtained the BWR Owner's Group information related to the industry issue on non-condensible gases in the reactor vessel level indication reference legs, This information was then used to assess the acceptability of the i information conveyed to Limerick's operations personnel, and their understanding of this issue. Additionally, the NRB asked that ISEG review previously identified problems in the i
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area of radiation protection, in order for the NRB to perform a thorough self-critique of their actions, related to radiation protection at Limerick. The inspectors noted that requests from other groups for investigations are evaluated, and received the same priority as any other topic ISEG selects for review. This ensures that ISEG's review process is not driven by the J
line organizatio Based on observations of the day to day activities of ISEG and interviews with its members, the inspectors concluded that ISEG is respected by the line organization. Recommendations ,
are tracked and implemented, as stated above, and ISEG opinions are welcomed by the staf As required by TS, ISEG is responsible for maintaining surveillance of unit activities to i provide an independent verification (not responsible for sign-off function) that these activities are performed correctly. ISEG provides a report of activities each month to the offsite Director, NQA ISEG is independent of the line organization, but does report to a traditional QA organization. During the preparation of written reports on assessments of site activities, ISEG routinely presents draft reports to the affected organizations for confirmation that the facts discussed in the draft report are correct. ISEG identified a concern that recent comments received on draft reports have been more of an editorial nature, and not limited to factual inaccuracies. ISEG has raised this issue to plant management to increase their sensitivity, and plans to reissue the Interface Agreement For ISEG to the plant staff. This will reenforce the need for ISEG to remain independent of the line organizatio .0 REVIEW OF LICENSEE EVENT AND ROUTINE REPORTS (90712,90713) ,
i Licensee Event Reports (LERs)
The inspectors routinely reviewed LERs and performed followup inspections to PECo's actions regarding the disposition of corrective initiatives. The inspectors reviewed the following LERs and found that the events were described accurately, PECo had identified the root causes, implemented appropriate corrective actions and made the required notification LER/SPECIAL REPORT l-93-013, Combined LER and Special Rept 1 Concerning the :
Failure of the D14 Emergency Diesel Emergency Diesel Generator to Start During its Monthly Operability Test Run. Event Date: October 26,1993, Report Date: November 24, 199 i This report concerns the failure of the D14 Emergency Diesel Generator (EDG) to start
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during performance of its monthly operability test run. During this test run, one of the two redundant starting air systems (ID2) was inoperable due to a leaking solenoid valve, and the IDI starting air system was used to attempt to start the D14 EDG. The D14 EDG did not
start when operations personnel placed the D14 control switch to the start position, and D14 was declared inoperable. At the time this report was issued, the cause of the D14 failure to start was still under investigation, but was believed to be due to a misaligned ID1 air start system distributor. PECO was also required to submit an LER, because the D14 EDG may have been inoperable when the redundant ID2 air start system was out of service, coincident with the misalignment of the IDI air start system distributor, and the associated TS Actions were not implemented within the required time period. This event is currently under review by NRC Region I inspectors, the results of which will be documented in NRC Inspection Report Nos. 50-352/93-30; 50-353/93-30.
LER l-93-014, Condition prohibited by Tech. Spec. (TS) in that the Spray Pond was inoperable due to a missed TS Surveillance Requirement as a result of personnel error, Event Date: October 5,1993, Report Date: December 10, 1993.
This LER reports a condition prohibited by TS in that a required surveillance was not performed within the allotted time. On October 4,1993, the 'A' spray pond network piping was in service, and the piping above the frost line was not drained after being used, as required by TS Surveillance Requirement (SR) 4.7.1.3.c. TS SR 4.7.1.3.c required the draining to be completed within I hour after use, to prevent potential freezing in the pipin I The associated TS Action requires that, with the spray pond declared inoperable, due to the SR not being met, both units be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Operations personnel failed to take the appropriate actions, due to personnel error; operators did not adequately i identify that the draining operation was required. The piping was appropriately drained on i October 5,1993, after operators determined that the TS SR had not been met. Safety significance, in this instance, was minimal since ambient temperatures remained well ab(we freezing temperatures at all times.
Corrective actions included reviewing the event with operators and system managers concerning situations when the piping must be drained. Appropriate procedures were revised to heighten awareness for draining the piping as required. Additionally, a TS Change Request was previously submitted to the NRC that would require draining the spray network
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piping above the frost line only when the ambient temperature is below 40 degrees F.
Plant personnel initially concluded that the event was potentially reportable as a condition prohibited by TS. Further review by plant management resulted in a conclusion that the event was not reportable based on a technical interpretation of the TS SR. The inspectors concluded that the event was reportable as a condition prohibited by TS, and notified plant management that the LER was required by 10 CFR 50.73. Plant management agreed with that conclusion and submitted the LER on December 10,1993. 10 CFR 50.73 requires that the report be submitted within 30 days after the discovery of the event; for this event, the discovery date was October 5,199 _ _
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These two issues; the failure to drain the piping and comply witl the TS Action statement and the failure to submit a required report within the allowed time, were of minor safety significance. Further, each issue meets the criteria for enforcement discretion of Section VII of the NRC's Enforcement Policy and will not be cite LER l-93-015, LER Concerning an Unplanned Isolation of Several Primary Containment isolation Valves, an Er.3 ineered Safety Feature Actuation, due to Personnel Erro Event Date: October 29,1993, Report Date: November 24,199 The inspectors found that LER 1-93-015 met the requirements of 10 CFR 50.73. The inspectors had no further questions regarding the above event .2 Routine Reports Routine reports submitted by PECo were reviewed to verify the reported information. The following report was reviewed and satisfied the requirements for which it was reporte Station Monthly Operating Report for October 1993, dated November 9,1993 FOLLOWUP OF PREVIOUS INSPECTION FINDINGS (92702)
l (Closed) Unresolved Item (50-352/93-25-01). This unresolved item concerned an instance l where operators signed off a procedure as completed and reviewed without identifying l missing required data.
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Investigation by plant personnel concluded that the required readings were taken, but that some readings were not recorded in the surveillance procedure as required. Further, the ~
licensee verified that the parameters were within required limits at the time, although the were not recorded. Therefore, plant management concluded that a violation of TS did not i
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l occur and the event was not reportable. Apparently, the operator inadvertently failed to record all of the data due primarily to multiple interruptions during performance of the tas Additionally, the operator failed to perform an adequate review of this section of the procedure prior to turning it in.
j PECo administrative procedure (A)-7, Appendix 1, Shift Operations Personnel Duties,
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Revision 8, requires the appropriate supervisor to perform a detailed review of all surveillance tests to ensure correct completion. The completed procedure received two additional vviews that failed to recognize that the readings were not recorded. Plant management concluded that this occurred due to additional task interruptions and that the ,
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l procedure was reviewed by a supervisor other than the normal supervisor who reviews the procedures. Additionally, it was concluded that the format of the procedure needed to be improved to aid in the review process. Corrective actions included counselling the operators involved and discussing the event with all operators. Plant management is also evaluating incorporation of various procedural format improvement l l
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Failure to adequately perform the detailed review, was in violation of the PECo Il administrative procedures, however, the inspectors concluded that this issue was of minor safety significance, the corrective actions taken and planned were adequate, and that this -l event received an appropriate level of attention. Based on this, the criteria for enforcement l discretion of Section VII of the NRC's Enforcement Policy were met and the violation will l not be cite :
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The inspectors had no further questions regarding this event and the unresolved item is l close (Closed) Violation (50-352/93-22-01 and 50-353/93-22-01). This violation resulted from an ,
instance where a radwaste technician exited the RCA without properly frisking through a j portal monitor, as required by appropriate personnel radiation protection posting !
l For this instance, plant management concluded that the technician ignored the posted i requirements to use a portal monitor, and that sufficient procedural controls and management j expectations exist to prohibit exiting the RCA without frisking for contamination. A review ;
found no discrepancies that would be indicative of a generic concern. Corrective actions included releasing the technician from employment, reinforcing expectations and L requirements for frisking through notices to plant personnel, and the entrance / exit :o the ;
RCA at the main control room is being renovated to provide only one entrance and exit point ;
to and from the RC :
The inspectors reviewed various announcements to plant personnel concerning proper frisking :
and adherence to postings. Additionally, the inspectors observed that the renovation to the >
main control room access point was well under way at the conclusion of the inspection .
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period. The inspectors had no further questions regarding this violation and the item is close l l MANAGEMENT MEETINGS I Exit Interviews The inspectors discussed the issues in this report with PECo representatives throughout the inspection period, and summarized the findings at an exit meeting with the Plant Manager,
, Mr. R. Boyce, on December 13, 1993. PECo personnel did not express any disagreement with the inspection findings. No written inspection material was provided to licensee representatives during the inspection perio . -
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- Additional NRC Inspections this Period
- Five Region-based inspections were conducted during this inspection period. Inspection i results were discussed with senior plant management at the conclusion of the inspection l
Dalc Subiect Insoection N Izad Insoector 'l
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11/05/93 Requalification 50-352/93-27 - Florek !
Training 50-353/93-27 .
11/19/93 MOV Followup 50-352/93-28 Kenny 50-353/93-28 11/29/93 Diesel Generator 50-352/93-30 Lazarowitz !
(D14) 50-353/93-30 l
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12/01/93 Security 50-352/93-31 Della Ratta :
50-353/93-31 r 12/03/93 Radiological 50-352/93-32 Nimitz Controls 50-353/93-32 ;
I f SALP Management Meeting On November 18, 1993, members of the NRC Region I staff met with PECo representatives, ;
at the Limerick Training Center, to discuss the Limerick Systematic Assessment of Licensee .;
Performance (SALP), issued November 5,1993. The SALP report covered the period from ;
March 15,1992, to September 25,1993. The purpose of the SALP report and the meeting !
was to recognize PECo's strengths and weaknesses and to promote the continuation of the Limerick Generating Station's record of strong nuclear safety performance. Additionally, ;
this meeting provided PECo with a formal opportunity to clarify and correct inaccuracies in the NRC's understanding of their performance. This meeting was open to public ;
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