IR 05000352/1999001
| ML20205C276 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20205C274 | List: |
| References | |
| 50-352-99-01, 50-352-99-1, 50-353-99-01, 50-353-99-1, NUDOCS 9904010138 | |
| Download: ML20205C276 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No l License No NPF-39 NPF-85
t Report No l 99-01 Licensee: PECO Energy Correspondence Control Desk P.O. Box 195 Wayne, PA 19087-0195 l Facilities: Limerick Generating Station, Units 1 and 2 Location: Wayne, PA 19087-0195 ,
l l Dates: January 12,1999 through March 1,1999 l
Inspectors: A. Burritt, Senior Resident inspector F. Bonnett, Resident inspector
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l Approved by: Curtis Cowgill, Chief I Projects Branch 4 Division of Reactor Projects
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9904010138 990326 PDR O .
ADOCK 05000352l PDR
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e EXECUTIVE SUMMARY Limerick Generating Station, Units 1 & 2 NRC Inspection Report 50-352/99-01,50-353/99-01 This integrated inspection included aspects of PECO Energy operations, engineering, maintenance, and plant support. The report covers a 7-week period of resident inspection and region-based inspection in the radiological environmental monitoring program (REMP) and fire protection area Ooerations e The shift manager demonstrated an excellent questioning attitude during his review of the results of troubleshooting activities for a faulty steam jet air ejector radiation monito Operators declared the instrument inoperable which led to further engineer review that resulted in fully diagnosing the radiation monitor problem and appropriate repair (Section O4.1)
- PORC performed a thorough and probing review of the safety evaluation addressing a plant condition that potentially rendered all hydraulic control unit accumulators inoperable. The PORC resolved to submit a Technical Specification change request to clarify the Technical Specification requirements. (Section O7.1)
e Operstions pcrsonnel left the RCIC steam line warmup bypass valve partially open in November 1GJ8, causing the valve to be inoperable. The redundant containment isolation valve was also open and inoperable at the same time for short durations due to planned maintenance. This Severity IV violation, of TS 3.6.3, is being treated as a Non-Cited Violation, consistent with Appendix C cf the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PEP 10009263. PECO's corrective actions adequately addressed this issue. (Section 08.1)
Maintenance e F ECO's actions to perform an internal valve inspection to confirm operability of HV-087-120B, a primary containment isolation valve, demonstrated conservative decision making and a focus on early identification and resolution of equipment problems. (Section M1.3)
Enaineerino e The initial PECO evaluation of the mis-operation of the 2B core spray full flow test valve l was narrowly focused. PECO evaluated the torque switch that failed, but did not initially consider other potential issues when a valve is operated in a manner to indicate closed, but is not fully closed. PECO engineers did not assess the effect on containment j isolation or potential generic implications to other susceptible valves. Also, PECO did l not identify that actions taken to address a similar event in 1993, were ineffective in that they relied on operator practices, which were not translated into procedures and had eroded over time. Appropriate analyses and corrective actions were implemented subsequent to discussion with the inspectors. (Section E1.1)
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Plant Suooort e The licensee's contractors effectively performed sample collection activities according to the procedures and sample schedule, conducted the land use census, and maintained and calibrated the automatic sampling equipment. The licensee provided program
. oversight and met the reporting requirements in the ODCM. The radiological environmental monitoring program was effectively implemented in accordance with regulatory requirements. (Section R1.1)
e Communication and inter-departmental coordination enhanced the licensee's overall performance. Instrument and Controls together with Health Physics Support calibrated and maintained the meteorological monitoring instrumentation, and improved instrument reliability. The self- assessment identified areas for improvement. The licensee appropriately addressed and corrected each issue. The meteorological monitoring program was effectively maintained and implemented in accordance with regulatory requirements. (Section R1.2)
e The environmental and quality assurance laboratories conducted the QA/QC programs in accordance with the appropriate procedures. The licensee provided effective program oversight by monitoring the progress and quality of both the environmental and the
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. quality assurance laboratories. The quality assurance program was effectively maintained and implemented in accordance with regulatory requirements. (Section R7.2)
- Effective administrative controls had been established for the hot-work that was accomplished in the skimmer surge tank pit. Proper storage of combustibles were in place. Good control of hot-work activities were evident. (Section F1.1)
' e The fire protection equipment conditions and housekeeping of the plant were good. The licensee maintained effective control of combustible materials. Roving fire watch personnel were knowledgeable of station procedures for reporting fires, roving fire watch duties, and responding to fires. Eight hour emergency light operation was goo Observed fire protection systems were capable of providing protection against fire and were consistent with the defense-in-depth principle. (Section F2.1)
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o The pathways for safe shutdown activities performed by operators were generally illuminated in an acceptable manner, staged equipment needed by the operators was accounted for and adequately surveilled. Safe shutdown procedures were adequate to support safe shutdown activities of the plants. (Section F2.2)
- Fire brigade members were current on all required training and annual physical examinations and the training program met NRC requirements. (Section F5.1l l
e The fire protection quality assurance audit appropriately reviewed fire protection program attributes and compliance with program requirements. The fire protection audit findings
' were appropriately addressed and timely corrective actions had been taken for identified deficiencies. (Section F7.1)
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i TABLE OF CONTENTS
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EXECUTIVE SUM MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 l
I TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l
1. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 O1 Conduct of 0perations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 01.1 General Com ments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 O2 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . 2 O2.1. Facility Tours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 04.1 Steam Jet Air Ejector Radiation Menitor Inoperable - Unit 1 . . . . . . . . 2 07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 07.1 Reactor Manual Control System Safety Evaluation Review . . . . . . . . . 3 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 08.1 (Closed) LER 50-353/2-98-008, Two RCIC PCIVs Simultaneously inoperable from Different Causes - Unit 2. . . . . . . . . . . . . . . . . . . . . . . 4 l l l . M aintenance .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1.1 General Comments on Maintenance Activities . . . . . . . . . . . . . . . . . . . 6
' M1.2 General Comments on Surveillance Activities . . . . . . . . . . . . . . . . . . . 7 '
M1.3 Troubleshooting and Repair of Drywell Chilled Water Valve HV-087-1208
- U nit i . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......... . ....... 7 j 111. Engi nee ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . 8 ;
E Primary Containment Isolation Valve Operator Issue . . . . . . . . . . . . . . 8 IV. Plant S upport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 10 1 R1.1 Implementation of the Radiological Environmental Monitoring Program
....................................................... 10 R1.2 Implementation of the Meteorological Monitoring Program . . . . . . . . 10 R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 R Quality Assurance Audit Program . . . . . . . . . . . . . . . . . . . . . . . . . 11 R7.2 Quality Assurance of Analytical Measurements . . . . . . . . . . . . . . . . 11 R8 Miscellaneous RP&C lssues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 F1 Control of Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 F Fire Risk Evolutions ......................................13 F2 Status of Fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . . . . . 13 !
F Facility Tour . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 F2.2 Walkdown of Safe Shutdown Methodologies . . . . . . . . . ..... . . 15 F Fire Brigade Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 iv
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F6 Fire Protection Organization and Administration . . . . . . . . . . . . . . . ........ 17 F Transition of Fire Protection Group into Site Engineering. . . . . . . . . . 17 F7 Quality Assurance in Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . 18 F7.1 Audits and Surveillances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 V. M anagement Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19 PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 LIST OF ACRONYMS USED . ........ ... ........ . ......... ... .. 21 l
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Report Details
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Summary of Plant 11taigg Unit 1 began this inspection period operating at 100% power. The unit remained at full power throughout the inspection periM with rninor exceptions for testing, rod pattem adjustments, and the following plant event e February 13 Operators reduced reactor power to 65% to perform a deep /ahallow rod pattem adjustment and to perform control rod scram time testing. Power was increased to and held at 98.5% on February 14 due to thermal limit constraints. Reactor engineering resolved this problem and 100% power was achieved on February 1 ,
e February 28 Operators reduced reactor power to 31% due to a 18 drywell chilled water cooling water supply valve failing to stroke closed during its quarterly surveillance test. The inspection period ended with operators restoring the unit to full power following valve repair Unit 2 began this inspection period operating at 100% power. The unit was operating at end-of- - )
cycle (EOC) with all control rods full * md maintaining full power with an extended core flow strategy. The unit began coastdowr. .,eiations on January 21 when operators increased l reactor recirculation flow to the maximum allowable limit (110%). Major load drops are described below. Unit 2 was operating at 96% power at the end of the inspection period, e January 29 Operators reduced reactor power to 70% to allow for control rod scram time testing, then increased reactor power to 85%. The No. 6 feedwate heaters (FWHs) were removed from service in accordance with the EOC coastdown strategy as described in procedure GP-5, " Power Operations."
Operators retumed '.he unit to 100% power on January 3 '
e February 12 Operators reduced reactor power to 90% to remove the No. 5 FWHs from service in accordance with the EOC coastdown strategy. Operato s retumed the unit to 100% power on February 1 l
- February 27 Operators reduced reactor power to 70% to isolate a steam leak in the iJnit 2 condenser area. Power was immediately restored to full output following the activit ,t
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1. Operations 01 Conduct of Operations'
01.1 General Comments (71707)
PECO Energy (PECO) conducted activities at Limerick Units 1 and 2 safely and reliabl Routine operations, surveillance, and other plant-related activities were performed as per station procedures, in a deliberate manner with clear communications, and with effective oversight by shift supervision. Control room logs accurately reflected plant activities and shift turnovers were comprehensive. Operators implemented effective controls for work activities using conservative decision making. For example, operators appropriately -
questioned the impact of de-energizing the reactor manual control system for repairs on control rod scram accumulator operabilit Operational Status of Facilities and Equipment O2.1 Engility Tours (71707)
The inspectors routinely conducted independent plant tours and walkdowns of selected portions of safety-rclated systems during the inspection period. These activities consisted of the verification that system configurations, power supp%s, proc.ess parameters, support system availability, and current system oparatior,al status were
- consistent with Technical Specification (TS) requirements and Updated Final Safety Analysis Report (UFSAR) descriptions. System operability, material condition, and general area material condition and housekeeping status were noted to be acceptaole in all cases. The inspectors did not identify any substantive concems or deficiencies as a result of these walkdown C1 Operator Knowledge and Performance J4.1 Steam Jet Air Elector Rcdiation Monitor Inocerable - Unit 1 Insoection Scope (71707)
The inspectors observed shift management's oversight and control of troubleshooting activities for the Unit 1 steam jet air ejector (SJAE) radiation monitors that were indicating erratically. The inspectors assessed the operations staff operability consideratio i
! Observations and Findinas Between January 22d and 29*,1999, the Unit 1 SJAE radiation monitors were indicating erratically. The radiation monitor functions to detect noble gas activity indicative of a fuel 1 Topical headings such as o1, MB, etc., are used in accordance with the NRC standardized reactor inspection report outline. . individual reports are not expected to address all outline topic l
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failure in the atmosphere drawn from the main condenser. The readings on radiation monitors in the main control room randomly oscillated between 50 and 200 mr/h Although the radiation readings were not at a level indicative of a radiation problem, the 1 operation staff appropriately questioned the components operability. Therefore, the shift I manager declared the monitors inoperable placing the unit in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shutdown limiting condition of operation (LCO).
Troubleshooting efforts by chemistry and l&C technicians found water that had accumulated in the rediation monitor. The water was removed, however, the monitor was indicating lower activity levels than expected. Further, the engineering staff l determined that the radiation monitor would remain operable if the drain-pot for the 1 offgas recombiner aftercondenser air cooler remained full of water. This would require ;
l&C technicians verifying and/or refilling the drain pot, as necessary, every four hour ;
The shif manager was not assured that the troubleshooting efforts had entirely resolved the problem with the radiation monitors. In declaring the radiation monitors inoperable, the shift manager back-dated the LCO start time to the previous day when indicated j radiation levels were unexplainably lower than expected following troubleshooting ac+ivitie The angineering staff performed further review of the systems operation and found that a j level control valve associated with the drain-pot for the offgas recombiner aftercondenser i air cooler was not controlling the drain pot level appropriately. The iadiation monitor's condensate drain line is inter-connected to the drain pot. The level control valve was j allowing the drain pot to empty of water which created an unintended dual sample path l between the normal sample path and the drain line for the radiation monitor. The second flow path caused dilution of the measured process stream leading to the lower radiation readings. The valve was subsequently repaired and stable radiation monitor operation at l the appropriate radiation level was observed. Engineering determined that since the
. radiation monitor was not properly sampling offgas flow, the condition was a functional failure according to the maintenance rul Conclusio The shift manager demonstrated an excellent questioning attitude during his review of the results of troubleshooting activities for a faulty steam jet air ejector radiation monito Operators declared the instrument inoperable which led to further engineer review that resulted in fully diagnosing the radiation monitor problem and appropriate repairs.
y 07 Quality Assurance in Operations O7.1 Reactor Manual Control System Safety Evaluation Review Insoection Scoce (71707)
The inspectors observed the Plant Operations Review Committee (PORC) activities, to address operability of the control rod scram accumulators with the reactor manual control system (RMCS) de-energized. The inspector reviewed the safety evaluation prepared to
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address the issue and observed the PORC meeting interactions to evaluated PORC effectivenes . Observations and Findinos PORC reviewed a safety evaluation conceming the operability of the RMCS syste The Unit 2 RMCS had been providing an " activity controls disagree" signal during control rod withdrawals while performing scram time testing on January 30. Troubleshooting
- activities determined that it was necessary to down-power the RMCS to effect repairs. A function of the RMCS is to continuously monitor control rod scram accumulator pressure and level. The operations staff raised the question conceming whether all scram '
accumulators were operable with the RMCS de-energize The system engineers prepared a detailed engineering change request (ECR) package and 10 CFR 50.59, safety evaluation. The package was of high quality and explained -
that accumulator pressure could be obtained locally at each hydraulic control unit,
! whereas, the level detection was not required for accumulator operabilit The PORC members reviewed the ECR package thoroughly, asking probing question of the engineers. The PORC concluded that a Technical Specification change request should be submitted to change the TS and alleviate future operability issues. The inspector reviewed the ECR and agreed with the PORC conclusion ,
l Conclusiong PORC performed a thorough and probing review of the safety evaluation addressing a plant condition that potentially rendered all hydraulic control unit accumulators inoperable. The PORC resolved to submit a Technical Specification change request to clarify the Technical Specification requirements.
i 08 Miscellaneous Operations issues l
08.1 (Closed) LER 50-353/2-98-00E. Two RCIC PCIVs Simultaneout,1v inoperable from Different Causes - Unit 2 Inspection Scope (92901)
l The inspector reviewed the Licensee Event Report (LER), the performance
, enhancement program evaluation (PEP 10009263), and had discussions with plant staff l regarding the results of PECO's evaluation for the reactor core injection cooling (RCIC)
system event. The inspector also reviewed plant procedures and various sections of the UFSAR and Individual Plant Examination of Extemal Events (IPEEE) to assess the l significance of the event and assess the corrective actions implemente l l
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. I b.' Observations and Findinas On December 8, while operators were isolating the RCIC system for scheduled maintenance, the operators noted that the steam line did n ~ l depressurize belc v 530 psig. The operators found that the steam line warmup bypass valve (HV-049-2F076)
was partially open although the control panel indication indicated that the valve was closed.
l Component engineers determined that valve 2F076 in this configuration was incapable 1
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of responding to an automatic isolation signal due to the control circuit limit switch being 1 in the " dead zone." The " dead zone" occurs in a portion of the motor operated valve's (MOVs) travel when the valve is not fully closed and the closed (green light only) l l indication exists. If a valve is operated from the control panel and it is stopped in this l l configuratica (typically 5 to 25 percent open), the automatic isolation function of the valve i
! would not occur and operator action would be required to restart valve motion. PECO personnel determined that the valve had been in this condition since November 13, when the system was restored following maintenance.
L PECO's investigation could not positively identify the cause for the 2F076 valve being partially opened in the dead zone. The cause was attributed to either a control circuit anomaly or (most likely) a personnel error which resulted in the valve being left partially open but with closed indication. PECO performed diagnostic testing of the valve and control logic. No anomalies were identified and the failure could not be reproduce Operator interviews were inconclusive due to the time that had elapsed between the
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PECO's corrective actions included revising the pre-warm procedures for the RCIC and ,
high pressure coolant injection (HPCI) systems to include a step to ensure the steam line '
warm-up bypass valves indicate open by requiring operator verification of the dual light indication when the valves are not fully shut. The operations staff was also briefed on I I
the event and valve operating characteristics, including " dead zones," were incorporated into operator requalification trainin ;
On December 13, PECO further identified that the RCIC inboard steam isolation valve (HV-049-2F007) had been simultaneously rendered inoperable and open on three occasions for planned activities between November 13 and December 9. One troubleshooting and two testing activities disabled the 2F007 valve for periods of 29,10 and 8 minutes. This simultaneous inoperability of the inboard and outboard PCIVs alone could have prevented fulfillment of the safety function of the PCIV system required in TS 3. The inspector reviewed significance of both PCIVs being disabled in the event of an i accident. The function of the PClVs is to isolate the supply steam to RCIC in the event of a steam line break. Normally, the RCIC system would remain available throughout a loss of coolant or other design based accident. The inspector determined that, assuming reasonable operator actions using existing procedures, any postulated event was bounded by the main steam line break analysis. Further, the TS LCO bases allows the
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operators up to four hours to isolate the steam line with one or both of the PCIVs open and inoperable. Each of the three occurrences where the inboard PCIV was inoperable (the longest being 29 minutes) was during a planned activity and was controlled to be within the allowed TS outage time. Lastly, the IPEEE assigned a low risk of such an event occurring with the RCIC system in a normal standby alignrnen TS 3.6.3 requires, in part, when a primary containment isolation valve is inoperable, then I within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> isolate the affected penetration. The inspector concluded that in the - }
period November 13,1998 through December 8,1998, the Unit 2 RCIC steam line I warmup line bypass valve was inoperable and this RCIC penetration was not isolated within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This failure to comply with TS 3.6.3 is a violation of NRC requirement This Severity IV violation is being treated as a Non-Cited Violation (NCV 50-353/99-01-01), consistent with Appendix C of the NRC Enforcement Policy. This violation is in the ,
licensee's corrective action program as PEP 1000926 I 1 Conclusions Operations personnel left the RCIC steam line warmup bypass valve partially open in l November 1998, causing the valve to be inoperable. Tne redundant containment isolation valve was also open and inoperable at the same time for short durations due to
planned maintenance. This Severity IV violation, of TS 3.6.3, is being treated as a Non- !
Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PEP 10009263. PECO's i corrective actions adequately addressed this issu i
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ll. Maintenance M1 Conduct of Maintenance I M1.1 General Comments on Maintenance Activities The inspectors observed selected maintenance activities to determine whether approved procedures were in use, details were adequate, technical specW + ans were satisfied, maintenance was performed by knowledgeable personnel, and p.+ maintenance testing was appropriately complete ;
The inspectors observed portions of the fol owing work activities:
e Unit 2 - Skimmer Surge Tank Modification, January 19; e Unit 2 - D24 Jacket Water Leak Repair, January 19; e Unit 2 - D24 Woodward Governor Replacement - January 21; e Unit 1 - VOTES of HV-051-1F0248, Full Flow Test Valve - February 9; e Unit 2 - Replacement of the Activity Control Card in the Rod Drive Control System
- February 9; e- Unit 2 - VOTES of HV-052-2F0158, Full Flow Test Valve - February 11; e Unit 2 - D-21 18-month Overhaul - February 22 - 26;
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Pre-planned maintenance activities were appropriately conducted and controlle Emergent work items were appropriately addressed with a focus on early identification and resolution of equipment problems. Observed maintenance personnel utilized good self-check techniques, operations personnel utilized good self-check techniques, communication techniques and verification duiing post maintenance testin M1.2 General Comments on Surveillance Activities (61726)
The inspectors observed selected surveillance tests to determine whether approved procedures were in use, details were adequate, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by knowledgeable personnel, and test results satisfied acceptance criteria or were properly dispositione i The inspectors observed portions of the following surveillance activities: I l
e Unit 2 - ST-6-092-114-2, D24 24-hour Endurance Run - January 22; e Unit 2 - ST-6-092-313-2, D23 Slow Start Test - February 9; e Unit 2 - ST-2-041-426-2, NSSSS - Main Steam Line Flow - High, Channel C, Calibration / Functional Test - February 10; e- Unit 1 - ST-6-051-232-1,1B Residual Heat Removal Pump, Valve, & Flow -
February 10; e Unit 2 - ST-6-052-232-2, B Loop Core Spray Pump, Valve, & Flow - February 12; e Unit 2 - ST-6-052-231-2, A Loop Core Spray Pump, Valve, & Flow - February 24; e Common - S78.8.A, Manual Initiation of Control Room Radiation cr Chlorine / Toxic Chemical isolation - February 24; e Unit 2 - ST-6-092-111-2, D2124-hour Endurance Run - March Observed surveillance tests were conducted well using approved procedures, and were completed with satisfactory results. Communications between the various work and support groups were good, and supervisor oversight was goo M1.3 Troubleshootina and Repair of Drvwell Chilled Water Valve HV-087-120B - Unit 1 (62707) Inspection Scope Between February 28 and March 1 the inspector observed activities associated with troubleshooting and repair of HV-087-120B, an outboard drywell chilled water primary containment isolation valve. The inspector assessed the resolution of this malfunctioning motor operated valv Observations and Findinas The inspector determined that PECO demonstrated a good safety awareness during the troubleshooting and repair of the outboard drywell chilled water valve. On February 27, the outboard PCIV, HV-087-1208, failed to stroke closed during the performance of the
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i quarterly chilled water valve test (ST-6-087-200-1). Maintenance technicians found a build up of hardened grease and light scoring on the valve stam. PECO reduced power to establish plant conditions to perform an intemal valve inspection. Valve intems were found satisfactory and PECO replaced the valve stem and stem nut as a precautio Post-maintenance testing was satisfactory and the valve was returned to operable statu ' Conclusion j l
PECO's actions to perform an internal valve inspection to confirm operability of HV-087-1208, a primary containment isolation valve, demonstrated conservative decision making and a focus on early identification and resolution of equipment problem lil. Engineering j
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i E2 Engineering Support of Facilities and Equipment i
E2.1 Primary Containment Isolation Valve Ooerator issue Inspection Scope (37551) i The inspector reviewed the evaluation, resolution, and corrective actions to address the failure of the 28 core spray full flow test valve during a surveillance tes Observations and Findinas During the performance of ST-6-052-232-2, "3 Loop Core Spray Pump, Valve, and Flow Test," the full flow test valve (H~t-052-2F0158) failed to stroke completely closed. The torque switch, in the valve operator, faulted stopping valve motion prior to the valve being completely shut. The reactor operator (RO) noted that indicated system flow remained at full flow although the valve indicated full closed.
l The inspector observed the maintenance and post-maintenance testing (PMT) of the torque switch. Technicians replaced the torque switch and sent it to the corporate laboratory for failure analysis. The PMT was completed satisfactorily. Engineering appropriately determined that the event was a maintenance ru!e functional failur The inspector noted that the engineering response focused primarily on the torque switch failure and did not question the full flow indication that the RO observed with the valve indicating full closed. The inspector was concemed that a potential valve condition existed for safety-related throttle valves, in which the valve could indicate closed but not be fully in the closed position The full flow test valve is a primary containment isolation valve (PCIV) that has an automatic isolation function. The inspector determined that the PCIV can be rendered inoperable if the valve is throttled such that the valve operator control circuit is in the " dead zone."
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The " dead zone" occurs in a portion of the motor operated valve's (MOVs) travel when l
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l the valve is not fully closed and the closed (green light only) indication exists. If a valve is operated from the control panel and it is stopped in this configuration (such as with a throttle valve), the automatic isolation function of the valve would not occur. Operator action would be required to restart valve motio i The licensee stated that they were aware of the " dead zone" issue and had developed an engineering change request (ECR)in 1994 to eliminate the problem in all of the PCIVs. The inspector noted, however, that all of the PCIVs that were throttle valves (such as the HPCl/RCIC steam line warmup valves and the core spray /RHR full flow test valves) were deleted from the ECR because they did not meet the criteria established in !
the generic letter (GL)-89-10 MOV program. No other corrective actions were evident to correct the " dead zone" concern for this style MOV. Further, the inspector found a 1993 nonconformance report that had identified the 2A core spray full flow test valve having been operated in the " dead zone." The NCR dis-positioned the valve performance as
"use-as-is" with the provision that operators must always open and leave throttle-valves with dual (open and closed) indication showing on the main control pane The inspector determined that PECO had been relying on operator action to compensate for the PCIV material deficiency since 1993. The inspector also determined that the corrective actions implemented in the NCR were ineffective. Although the " dead zone" issue was incorporated into the UFSAR, it was not effectively institutionalize or translated into operating and surveillance test procedures. Also, the operator practice of operating PCIV throttle valves with dual indication had eroded over time (refer to Section 08.1).
The inspector discussed the concem with PECO system and component engineers who agreed that the corrective actions taken to address the 1993 NCR were ineffectiv PECO revised appropriate HPCI, RCIC, RHR and core spray operating and surveillance I procedures to provide a caution regarding the " dead zone" and ensuring valve operation l with dual indication. Further, engineering assessed all other throttle valves that were l removed from the ECR scope and determined which valves display operating characteristics that could potentially place a full flow test valve in the " dead zone" during dynamic surveillance testing. The valves identified will be adjusted during a future outage windo c. Conclusion The initial PECO evaluation of the mir-operation of the 2B core spray full flow test valve :
was narrowly focused. PECO evaluated the torque switch that failed, but did not initially 1 consider other potential issues when a valve is operated in a manner to indicate closed, but is not fully closed. PECO engineers did not assess the effect on containment ;
isolation or potential generic implications to other susceptible valves. Also, PECO did .
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not identify that actions taken to address a similar event in 1993, were ineffective in that j
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they relied on operator practices, which were not translated into procedures and had eroded over time. Appropriate analyses and corrective actions were implemented subsequent to discussion with the inspectors.
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IV. Plant Support -
R1' Radiological Protection and Chemistry (RP&C) Controls
! R l_molementation of the Radioloaica! Environmental Monitorina Proaram
- Insnadian Scoce (84750-2)
The implementation of the REMP, relative to program oversight; sample collection i methodology; material condition, operation, and calibration of automatic sampling .
equipment; Land Use Census; and :orting requirements, was evaluated for the period between January 1998 and January 1999.
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I l : Observations and Findinos The automatic air sampling equipment were operable and calibrated. The glass fiber filters and the charcoal cartridges were exchanged according to the sampling
. procedures. . Methods to minimize the chance of cross contamination were incorporated l Into the procedures. The automatic water compositors were operable and the milk l samples were collected from the locations described in the Offsite Dose Calculation
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! Manual (ODCM). Sampling was performed according to the procedures and the l schedule. Missed samples were reported in the 1998 annual REMP report, as required l by the ODCM. The land use census for 1998 was performed in detail and within time j frame required in the ODCM. No significant changes in land use were noted. The
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annual report for 1998 provided a comprehensive summary of the results of the REMP around the site and met the TS reporting requirements. The Program Lead provided
! program oversight by performing periodic inspections of contract personnel and reviewing the sample data daily to ensure the program is implemented effectivel t i
i j Conclusions
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i The licensee's contractors effectively performed sample collection activities according to !
the procedures and sample schedule, conducted the land use census, and maintained and calibrated the automatic sampling equipment. The licensee provided program oversight and met the reporting requirements in the ODCM. The radiological environmental monitoring program was effectively implemented in accordance with regulatory requirement R1.2 Imolementation of the Meteoroloaical MonitorinaProaram Inspection Scooe (84750-2)
The implementation of the Meteorological Monitoring Program, relative to maintenance j and calibration of the monitoring instrumentation, channel checks, and functional checks, was reviewed for the period between January 1998 and January 1999. An evaluation of the licensee's self-assessment was conducte '
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11 Observations and Findinas Daily and weekly surveillance tests (ST) were performed as required by the proceduret and ODCM. The STs provided preliminary information about the reliability of the meteorological equipment. Where there were concems, corrective actions were timel Semiannual STs (calibrations) were also performed as required by the ODCM with the coordination of Instrument & Controls (l&C) and Health Physics (HP) Support. The calibration methodology was appropriate and the calibration results were within the acceptance criteria. No instrument failures had occurred during 199 In February 1998, HP Support initiated a self-assessment to identify and address !
improvement opportunities for the monitoring instrumentation on both meteorological monitoring towers. Together with l&C, HP Support conducted a study from February to December 1998 which revealed causes for certain instrumentation outages, the need to replace cables and the tower boom, and to retire in place chart recorders and correct the problems of the ODCM required recorders. The evaluation provided opportunities to minimize the time required for an instrument to be out o' service. Corrective actions and follow up indicated an overall improvemer.t in the monitoring instrumentation and strip chart recorder reliabilit Conclusions Communication and inter-departmental coordination enhanced the licensee's overall performance. Instrument and Controls together with Health Physics Support calibrated and maintained the meteorological monitoring instrumentation, and improved instrument reliability. The self-assessment identified areas for improvement. The licensee appropriately addressed and corrected each issue. The meteorological monitoring program was effectively maintained and implemented in accordance with regulatory requirement R7 Quality Assurance in RP&C Activities R Quality Assurance Audit Proaram Three Quality Assurance (QA) surveillances of the sampling program for the REMP were performed. The 9urveillances were detailed in scope and provided a preliminary .
assessment the REMP. The QA audit is scheduled for 1999. No audits of the REMP or I MMP had been performe R7.2 Quality Assurance of Analytical Measurements , Inspection Scope (84750-2) i The implementation of the QA/QC program of the contract laboratories, including the interlaboratory Comparison (cross-check) Program and the licensee's oversight of the laboratories, was reviewed for the period between January 1998 and January 199 !
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12 Observations and Findinas t
The quality. assurance program consisted of measurements of blind duplicate, spike, and t
split samples. The program also included participation in the in the EPA Cross-Check Program and the Interlaboratory Comparison Program provided by a vendor laboratory (Analytics, Inc.). The licensee monitored the progress and quahty of both the i environmental and the quality assurance laboratories. Each sample result was rev'eved for accuracy and precision. Any results that were suspect were investicated and l resolved. The results of these programs were within the established acceptance criteria.
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All the results were reported in the 1998 annual REMP report, as required by the ODCM.
. Conclusions
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The environmental and quality assurance laboratories conducted the QA/QC programs in accordance with the appropriate procedures. The licensee provided effective program oversight by monitoring the progress and quality of both the environmental and the quality assurance laboratories. The quality assurance program was effectively maintained and implemented in accordance with regulatory requirement R8 Miscellaneous RP&C lasues (92904)
- (CLOSED) IFl 98-02-12
- RM-21 A Comouter Uoarade and Chart Recorder Reo!acement
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The licensee had identified reliability problems with the RM-21 A, the primary source of l
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meteorological data retrieval. In some instances, portions of meteorological data sent to the RM-21 A were lost. - Although, the data was recorded by the strip chart recorders and
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data loggers, the recorders were not reliable.
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The licensee conducted a self-assessment to identify and address improvement opportunities for the monitoring instrumentation for both meteorological monitoring
- towers between February and December 1998. As a result, the licensee improved the reliability of the chart recorders and data collection capabilities. (See Section R1.2 of this report for details.)
in September 1998, the licensee initiated Engineering Change Request (ECR) 98-02266 to upgrade the RM-21 A computer by January 2000. The ECR included a complete
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transfer of all the historical and current meteorological data, and the collec'. ion and l
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storage capabilities from the RM-21 A computer (including the radiation monitoring system information) to the Plant Monitoring System, which is year 2000 compliant. The transfer will not interfere with the data collection or storage capabilities. The ECR
. detailed hardware and software verification and validation. The licensee has completed one half of the plan which included the 50.59 avaluation, the Updated Final Safety Analysis Report changes, the Design Basis Document, and the Solution Requirements Specification. The Meteorological portion of the project will be completed by the end of the second quarter 1999. This item is close l
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] d 13 j F1 Control of Fire Protection Activities ,
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F1.1 Fire Risk Evolutions Insoection Scope (64704) -
The inspectors reviewed the administrative processes for controlling and evaluating fire I hazards, including limiting the interaction of combustible and flammable materials with ignition sources. This review was conducted to verify that adequate guidance and proper authorization requirements existed for identifying and limiting fire risk for hot-work being accomplished in the skimmer surge tank pi Observations and Findings The inspectors reviewed hot-work activities associated with hot-work permit number C0183643 05 01, " Skimmer Surge Tank Pit," and implementation procedure AG-CG-012,
" Hot Work Guidance," revision O. The inspectors found that the administrative process for controlling ignition sources included the use of a permit system for authorization to perform hot-work activities. The authorization to perform the task was granted by the work group supervisor overseeing the job task. Prior to authorizing the hot-work activity, fire protection personnel appropriately inspected the hot-work area to identify potential fire protection problems and to ensure that appropriate fire watches were provided. The inspectors found that the hot-work procedure was properly implemented in the field and l that the guidelines in the hot-work permit were being followed. Review of the hot-work log revealed no discrepancies.- Additionally, the inspectors found that the licensee had instituted a " Combustible Material Log" to monitor and control transient combustibles into and out of the work are The inspectors determined that the administrative process provided a comprehensive review of the above hot-work activity and should have identified any potential interaction .
of combustible and flammable materials with ignition source Conclusions Effective administrative controls had been established for hot-work accomplished in the skimmer surge tank pit. Proper storage of combustible materials were in place. Good control of hot-work activities were eviden F2 Status of Fire Protection Facilities and Equipment F2.1 Facility Tour Inspection Scooe (64704)
The inspectors toured the Limerick Generation Station (LGS) site and inspected fire suppression and detection systems / components. The inspectors also inspected the l
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material condition of fire fighting equipment, emergency lighting unit (ELU) operation, fire l door latching, and roving fire watch tumover and tou !
b. Observations and Findinas The inspectors found that the fire protection equipment material condition was good and that combustible fire-loading was properly maintained in those areas inspected. Fire ,
brigade members' protective clothing and gear was found in good condition and l adequately organized in the various site fire brigade lockers. The inspectors determined '
that housekeeping in areas containing safety-related and nonsafety-related equipment was good. Proper combustible material control was observe l I
The inspectors verified that the fire suppression system pressure was adequate. Fire hoses did not exhibit any cracks of fraying and all observed nozzles were properly rate The inspectors found that gauges on fire equipment including some fire extinguishers and carbon dioxide tanks registered in their appropriate ranges. The inspectors verified
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that all observed fire extinguishers were current with monthly surveillances. Although the !
inspectors noted four fire extinguishers' surveillance tags had not been punched for December, the licensee provided surveillance information that showed that the l extinguishers had been surveilled. The licensee submitted a performance enhancement program (PEP) 10009362 to determine why the tags where not punched and resolve the issue. The inspectors noted appropriate smoke detection, fire detection, and alarm
.. panels were installed throughout observed areas at the site and proper surveillances were conducted to ensure operability. The inspectors observed that fire doors latched properly in most cases. When fire doors did not latch properly, the inspectors noted that the licensee had appropriately tagged the doors and placed them in their corrective action program for repair. There were no instances observed where access to fire suppression devices was restricted by any materials or equipmen During observation of the fire watch turnover, the inspectors noted that appropriate information was provided to the security guard coming onto duty to begin his roving fire watch activities. The inspectors found that the roving fire watch toured appropriate areas of the plant in a timely manner, looked for appropriate indications of fires, failed
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equipment, and obstructions of fire protection equipment during his tour. The roving fire watch was knowledgeable regarding station policy on reporting fires, roving fire watch duties, and responding to fires. The inspectors determined that the roving fire watch was l- knowledgeable of his duties and responsibilities regarding the fire protection program.
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The inspectors found that recent actions by the licensee had been implemented at LGS l to improve the effectiveness and operation of eight hour emergency lights for l- access / egress routes of safety-related equipment areas. The licensee demonstrated
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emergency light operability and illumination pattems on sixty-five selected ELUs during the plant tour. All emergency lights properly illuminated when the test button was depressed. The inspector verified that a new emergency light method had been implemented by procedure RT-7108-300-0, " Appendix R ELU 8 Hour Capacity Verification Test," revision 6, and did not test the emergency li0ht unit battery to destructio r:
The inspectors performed a detailed walkdown of the suppression and detection systems in the cable spreading rooms of unit 1 and unit 2. The independent plant examination of
. extemal events (IPEEE) identified the cable spreading room as a risk significant fire l area. The inspectors compared the installed configuration of the suppression and detection systems with their associated drawings and found no discrepancie Appropriate surveillances were conducted on the wet pipe system and the smoke detection system to verify operabilit The inspectors performed a limited walkdown of the Primary Containment Instrument i Gas (PCIG) system and found that the material condition of the observed components l was good. The inspectors also reviewed the surveillances conducted on important I components of the PClG system and found that adequate surveillances had been conducted on air compressors and nitrogen tmiks to support safe shutdown activities if l necessar Conclusions The fire protection equipment conditions and housekeeping of the plant were good. The licensee maintained effective control of combustible materials. Roving fire watch l personnel were knowledgeable of station procedures for reporting fires, roving fire watch l
duties, and responding to fires. Eight hour emergency light operation was good.
l Observed fire protection systems were capable of providing protection against fire and l were consistent with the defense-in-depth principle.
r F2.2 Walkdown of Safe Shutdown Methodolooies L Inspection Scope (64704)
The inspectors reviewed and walked down two safe shutdown methodologies to determine if they were adequate to complete safe shutdown activities if necessar Observations and Findinas The inspectors performed a walkdown of procedures SE-8-1, " Safe Shutdown Method A," revision 6, for unit 1 and SE-8-2, " Safe Shutdown Method B," revision 8, for unit 2, with particular attention paid to ELUs, staged equipment, and operator actions to facilitate safe shutdown activitie The inspectors found that all tested ELUs appropriately illuminated as stated previously in report section 2.1. The inspector determined that, in general, pathways to operate specific equipment in the procedures was acceptable. The exception was in the area of the D124-R-G,480V MCC panel where an operator would have to operate a breaker handle. Emergency lighting in this area was marginal. However, the inspector determined that other emergency lights in the area would have provided sufficient
. lighting for the operator to operate the breaker handle on the motor control center (MCC)
panel. The licensee recognized the marginal lighting in this area and had drafted a
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L, modification to provide additional lighting to this panel. The inspector found these I
actions to be acceptabl The inspectors verified that staged equipment was located as stated in the procedures, and that the equipment was easily accessible to the operators to conduct cold shutdown activities. The inspector found that a monthly surveillance was conducted to ensure that all tools, jumpers, and pneumatic hoses were accounted for in staged tool boxe Flashlight batteries were surveilled frequently to ensure their operatio Based on the above, the inspector determined that these safe shutdown procedures l would enable operators to perform safe shutdown actions during fire conditions.
l l Conclusions The pathways for safe shutdown activities performed by operators were generally illuminated in an acceptable manner, staged equipment needed by the operators was I
accounted for and adequately surveilled. Safe shutdown procedures were adequate to l
support safe shutdown activities of the plants.
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F5.1 Fire Briaade Trainina
! Insoection Scooe (64704)
l The inspectors reviewed the training program requirements and the training provided for fire brigade members to verify that members had completed all required training for qualification and dut Observations and Findinas The inspectors verified that nine fire brigade members randomly selected for review had l
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successfully completed the required training courses, drills, respirator training and passed their annual medical physicals. No deficiencies were identified.
i The inspectors found that initial and continuing training programs appropriately
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emphasized potential fire hazards and precautionary measures, supported brigade
! member readiness, and complied with NRC requirements and the LGS licensing basi Conclusions
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Fire brigade members were current on all required training and annual physical examinations and the training program met NRC requirement W a
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F6 - Fire Protection Organization and Administration '
~ F Transition of Fire Protection Group into Site Enaineerina Inspection Scoce (64704)
The inspector reviewed the LGS transition plan to reorganize the fire protection group into site engineering. This was accomplished to determine how the transition would occur and if the fire protection group would maintain / improve its' effectiveness to identify and resolve fire protection issues, Observations and Findinas
- Recently, LGS began the transition of the fire protection group into the site engineering organization. Through discussions with station personnel and review of the LGS transition plan, the inspectors gained insight into how the absorption of the fire protection
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group into site engineering would occur instead of a stand alone organization, the fire protection group will report directly to site engineering. The inspector found that this newly organized engineering group would continue to properly address current, emerging, and steady state fire protection and safe shutdown issues / activities. With the fire protection group implemented into site engineering, fire protection issues would receive the same attention as other engineering activities in the organization. The
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following tasks are needed to complete the transition:
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establish fire protection program ownership in site engineering;
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move fire protection system manager to site engineering:
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move fire protection, safe shutdown design change process, and design authority activities to site engineering;
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move large, special fire protection and safe shutdown projects / emerging issues to l site engineering; l -
transfer technical portion of fire protection program administration and combine with design engineering function in site engineering; and
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maintain fire barrier engineering functions with current hazard barrier program in site engineerin The inspector had no further questions on this matte ! Conclusions l PECO has developed a transition plan to accomplish the reorganization of the fire protection group into the site engineering organization.
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- F7 Quality Assurance in Fire Protection Activities i
- F Audits and Surveillances a.' Insnadion Scone (64704)
The inspectors reviewed the quality assurance audit reports completed to satisfy the
- Updated Final Safety Analysis Repo1 (UFSAR) requirements. The inspectors orified that audits adequately evaluated the effectiveness of fire protection measures, equipment, program implementation,- and problem identification and resolutio Observations and Findinas The inspectors reviewed the most recent quality assurance audit report number PAR-98-007, " Triennial Fire Protection Program Assessment," revision 10, conducted from June 10,1998, through July 2,1998, and several quality assurance surveillance report The inspectors determined that these documents demonstrated good problem identification and clearly communicated findings in the reports. The inspectors noted that the audit scopes. findings, and observations were good and met the requirements of the program. The inspectors verified that proper revisions and actions were taken to effectively resolve any identified deficiencies. Corrective actions were found to be implemented for resolving these deficiencies in a timely manne Conclusions The fire protection quality assurance audit appropriately reviewed fire protection program attributes and compliance with program requirements. The fire protection audit findings ,
were appropriately addressed and timely corrective actions had been taken for identified J deficiencie V. Management Meetings ;
X1 Exit Meeting Summary The inspectors presented the resident inspection results to members of the licensee management at the conclusion of the inspection on March 5,1999. The licensee acknowledged the findings presente The inspectors met with licensee representatives at the conclusion of the radiological environmental monitoring program (REMP) and fire protection inspections on January 19,1999 and January 26,1999, respectively. At that time, the purpose and scope of the inspections were reviewed, and the preliminary findings were presented. The licensee acknowledged the preliminary inspection finding . The inspectors asked the licensee whether any material reviewed during the inspection should be considered as proprietary information. No proprietary information was identifie g
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l INSPECTION PROCEDURES USED -i i
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! IP 37551: Onsite Engineering l l lP 61726: Surveillance Observation IP 62707: Maintenance Observation
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IP 64704: Fire Protection Program j l IP 71707: Plant Operations j l _ lP 71750: Plant Support Activities ~
t IP 90712: In-office Review of Written Reports
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IP 90713: Review of Periodic and Special Reports
!- IP 92904: Followup - Plant Support i IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
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PARTIAL LIST OF PERSONS CONTACTED Licenseelin alohabetical order)
M. Alderfer, Sr. Manager / Plant Engineering M. Alfonso, Chemistry Manager P. Berry, Manager HP Support R.' Bickhart, LGS QA Assesor R. Broderick, Tech., l&C Team 5 -
P. Callahan, l&C Lead Instrument Technician -l F. Cook, Senior Manager / Design Engineering
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C. Cooney, Engineering / Civil Branch L E. Frick, Chemistry Radiochemist J. Grimes, Director of Engineering W. Harris, Radiation Protection Manager J. Hunter, LGS QA Manager
- M. MaGuire, TA- Fire Protection A. Marie, Branch Manager NED-H. McNally, Manager / Nuclear Security S. Minnick, System Manager / Fire Protection J. Risteter, System Manager G. ' Rocker, Ops Support / Fire Protection Program Administrator G. Stewart, Engineer-Expert Assessment D. Wahl, REMP Program Lead l B. Whitman, Supervisor / Security NRC (in alohabetical order)
F. Bonnett, Resident inspector A. BumM, Senior Resident inspector C. Cahill, Reactor Engineer I
E. Kelly, Chief, Engineering Support Branch L. Peluso, Region i inspector K. Young, Region I inspector
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ITEMS OPENED,' CLOSED, AND DISCUSSED
l Opened / Closed 50-353/99-01-01 NCV Two RCIC PCIVs Simultaneously inoperable from Different Causes - Unit 2 (Section 08.1)
l Closed 50-352;353/98-02-12 IFl RM-21A Computer Upgrade and Strip Chart Recorder
- Replacement (Section R8)
50-353/2-98-008- LER Two RCIC PCIVs Simultaneously Inoperable from Different Causes - Unit 2 (Section 08.1)
Discussed None
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LIST OF ACRONYMS USED
CFR Code of Federal Regulations ELU Emergency Lighting Unit Gl Generic Letter HPCI High Pressure Coolant injection IFl Inspection Follow-up Item IPEEE Individual Plant Examination of Extemal Events IR inspection Report LCO Limiting Condition For Operation LER Licenset. Event Report LGS Limerick Generating Station MCC Motor Control Center MMP Meteorological Monitoring Program NCV Non-Cited Violation NED Nuclear Engineering Department NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PCIG Primary Containment instrument Gas PECO PECO Energy PEP Performance Enhancement Process PORC Plant Operations Review Committee QA Quality Assurance REMP Radiological Environmental Monitoring Program RCIC Reactor Core it,olation Cooling RHR Residual Heat Removal RP&C Radiological Protection and Chemistry ST Surveillance Test TS . Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item
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