IR 05000352/1999002
| ML20206N122 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/07/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206N114 | List: |
| References | |
| 50-352-99-02, 50-352-99-2, 50-353-99-02, 50-353-99-2, NUDOCS 9905170142 | |
| Download: ML20206N122 (18) | |
Text
! .
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No License No NPF-39 NPF-85 Report No ,
Licensee: PECO Energy Correspondence Contrm Desk ,
I P.O. Box 195 Wayne, PA 19087-01'35
)
Facilities: Limerick Generatir.g Station, Units 1 and 2 Location: Wayne, PA 19087-0195
Dates: March 2,1999 through April 12,1999
'
Inspectors: A. L. Burritt, Senior Resident inspector F. P. Bonnett, Resident inspector Approved by: Curtis Cowgill, Chief Projects Branch 4 Division of Reactor Projects l
!
9905170142 990507 PDR ADOCK 05000352-G PDR
r, O
l EXECUTIVE SUMMARY l Limerick Generating Station, Units 1 & 2 l NRC Inspection Report 50-352/99-02,50-353/99-02 This integrated inspection included aspects of PECO Energy operations, engineering, l maintenance, and plant support. The report covers a 6-week period of resident inspectio Operations l
l e The operations staff did not perform a recommended risk assessment rrior to removal of a train of the reactor enclosure recirculation system (RERS) from servh.e to perform non-critical maintenance. As a result, the combined effect of the RERS train j unavailability and a concurrent standby gas treatment problem was not evaluated for risk increase. In addition the removal of RERS approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to the start of maintenance work resulted in unnecessary system unavailability. (Section O2.2)
e During a plant tour an equipment operator identified that a portion of the isolation logic
- for the shutdown cooling mode of the residual heat removal system was de-energized.
l PECO determined the event was caused by an open circuit at a Grayboot connector as a result of over crimping. PECO performed a thorough analysis including destructive examination of other Grayboot connectors to conclude that a generic issue involving the connectors did not exist. (Section 04.1)
l l
Maintenance l
l e The 1B1D101 125vde battery replacement activity was well planned and execute Maintenance technicians were highly knowledgeable of all aspects of the battery activities. (Section M1.3)
e The inspector observed that the housekeeping and general area material condition had degraded, particularly in the vicinity of fire barrier upgrades. Corrective actions to resolve the deficiencies were appropriate. (Section M2.1)
l e LER 1-99-002 reported a failure to perform a required Technical Specification locked-valve inspection. The required component had been inadvertently deleted from the ;
surveillance procedure during a revision due to personnel error and an inadequate .
review. This Severity Level IV violation of Technical Specifications is being treated as a I Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy. This violation is in PECO's corrective action program as PEP 10009525. (Section M8.2)
ii
[.
l
'
.
Enaineerina e Overall PECO's identification of fire areas that contained unprotected emergency diesel generator control cables and the permanent resolution were very good. However, interim corrective actions and risk assessments were deficient as a result of the l operability determination not addressing the appropriate safety function. The l unprotected emergency diesel generator control cables represented a failure to maintain
'
the provisions of the Facility Operating License. This failure is a Severity Level IV violation which is being treated as a Non-Cited Violation consistent with Appendix C of l the NRC Enforcement Policy. This violation is in PECO's corrective action program enhancement process (PEP) evaluation 10008924. (Section E8.1)
l i
Plant Sucoort
!
e PECO did not evaluate the use of rubber matting on scaffolds in the vicinity of a fire ,
suppression system in a combustion free zone nor initiate a fire system impairment i resulting in a degraded and uncompensated fire barrier. PECO promptly rectified the
! deficiency when informed by the inspector. (Section F2.1) ,
I l e LER 1-99-001 reported that less than adequate administrative controls caused l l
'
safeguards information to be inappropriately saved to a computer's hard-drive. The safeguards information was left unprotected on the stand alone computer in the security
,
office area. This Severity Level IV violation of security requirements is being treated as a l
Non-Cited Violation, consistent with Appendix C of the NRC En'orcement Policy. This
,
violation is in PECO's corrective action program as PEP 10009463. (Section S8.1) l
, s
!
'
i I
l l
iii l
l l
\
]
.
.
TABLE OF CONTENTS Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... ................... 1 01 Conduct of Operations . . . . . . . . . . . . . . . ............................1 01.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . 1 O2.1 Facility Tours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O2.2 Removal of Risk Significant Systems from Service . . . . . . . . . . . . . 1 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 04.1 Equipment Operator Identifies Defective Relay (Gray-boot). . . . . . . . 2 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 08.1 (Closed) Violations 97-10-01 and 98-03-01 . . . . ................ 3 II. Maintenance . . ............................ ............ ............ ... 4 M1 Conduct of M aintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M1.1 General Comments on Maintenance Activities . . . . . . . . . . . . . . . ..4 M1.2 General Comments on Surveillance Activities . . . . . . . . . . . . . . . . . . 4 M1.3 Safeguards 1B1 Battery Replacement - Unit 1. ......... ... .. 5 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . .6 M2.1 Plant Housekeeping . . . . . . . . .... ..... ..... .. ........6 M8 Miscellaneous Maintenance issues . . . . . . .... . ............7 M8.1 (Closed) Violation 98-09-01. . . . . ........... ... ...... ...7 M8.2 (Closed) LER 1-99-002 . . ... .. .. . . .. . .. .....8 Ill. Engineering . . . . . . . . . ....... ...... .. . .. . ... . ...... ...... 8 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . ........ ...8 E (Closed) LER 1-98-018 . . ... ... . . . ...... . .. . . 8 IV. Plant Support . . ...... ... .... ........ . . .. ........ ... ... ... 10 S8 Miscellaneous Security and Safety issues . . ... ....... ....... . . 10 S (Closed) LER 1-99-001 . ........ . ...............10 F2 Status of Fire Protection Facilities and Equipment . ... .......... . . 11 F Fire System impairment . . . . . .. .... ............. . .... 11 V. Management Meetings . . . . . . . . . . . . . . . . ... . ... .. .. .. . . 12 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . ...... .... . .. . .. .12 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . .... .... ....... ... .. 13 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . ....... . . .. .. . 13 LIST OF ACRONYMS USED . . . . . . . . . . . . . . . . . ....... . . ..... .... .. .14 iv e
-
)
.
Report Details j l
Summary of Plant Status Unit 1 began this inspection period operating at 100% power. _ The unit remained at full power throughout the inspection period with minor exceptions for testing and rod pattern adjustment l
,
Unit 2 began this inspection period operating at 96% power in end-of-cycle (EOC) coastdown operations. The unit continued to coastdown throughout the inspection period and was operating at 82% power at the end of the inspection perio l l. Operations 01 Conduct of Operations'
01.1 General Comments (71707)
PECO Energy (PECO) conducted activities at Limerick Units 1 and 2 safely. 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 tumovers were comprehensiv Operational Status of Facilities and Equipment O2.1 Facility Tours (71707)
The inspectors routinely conducted independent plant tours and walkdowns of selected portions of safety-related systems during the inspection period. These activities consisted of the verification that system configurations, power supplies, process parameters, support system availability, and current system operational status were consistent with Technical Specification (TS) requirements and Updated Final Safety Analysis Report (UFSAR) descriptions. System operability and material conditions were noted to be acceptable in all case .2 Removal of Risk Sionificant Systems from Service Insoection Scope (71707)
The inspector assessed PECO's decision process for removing the reactor enclosure recirculation system (RERS) from service for pre-planned corrective maintenance with one train of the standby gas treatment (SBGT) system out of service and the other train potentially degrade i 1 Topical headings such as oi, M8, etc., are used in accordance with the NRC standardized reactor inspection report outlin Individual reports are not expected to address all outline topic .
.
2 Observations and Findinos The inspector observed that PECO removed the Unit 1 "A" train of RERS from service with one train of SBGT inoperable as a result of a condition that could have potentially degraded the redundant train. During testing, PECO technicians found a low charcoal adsorber level that created a bypass flow path around the SBGT charcoal bed. Prior to restoring this train to an operable status, or determining the root cause of the problem, one of the two RERS trains was removed from service for unrelated pre-planned repair Station administrative guidelines recommend that the overall effect on the performance ,
'
of key safety functions should be assessed prior to performing maintenance on risk significant systems such as RERS. The inspector observed that the recommended reviews were not performed. Also, the RERS train was removed from service about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to the start of maintenance which resulted in increased and unnecessary system unavailabilit The inspector discussed the issues with the operations support manager who took prompt action to address the inappropriate early release of safety-related, risk-significant equipment from service by briefing the operations crews. The additional issues will be included as critique items of work control for the associated work wee Conclusions The operations staff did not perform a recommended risk assessment prior to removal of a train of the reactor enclosure recirculatidn system (RERS) from service to perform non-critical maintenance. As a result, the combined effect of the RERS train unavailability and a concurrent standby gas treatment problem was not evaluated for risk increase. In addition the removal of RERS approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to the start of maintenance work resulted in unnecessary system unavailabilit Operator Knowledge and Performance 04.1 Eauioment Operator Identifies Defective Relav (Gray-boot) Inspection Scooe (71707) )
The inspector reviewed PECO's response to an event involving a portion of the logic for the shutdown cooling mode of the residual heat removal (RHR) system being inadvertently de-energized. The inspector attended meetings and observed the ,
implementation of corrective actions in the field to assess the thoroughness of PECO's ;
event review. .Also, the inspector reviewed PECO's basis for retracting the four-hour i NRC notificatio Observations and Findinas On March 9, an equipment operator (EO) identified that portion of the isolation logic for '
.
the shutdown cooling mode of RHR was de-energized. The EO, while performing
.
routine rounds in the auxiliary equipment room, found indicating lamp DS18 on the reactor protection system panel 10-C611 de-energized when it should have been energized. Operators attempted unsuccessfully to reset the logic. Further investigation revealed an open connection across a Grayboot electrical connector. A Grayboot connector is an environmentally qualified in-line wire quick disconnect used in some applications to eliminate the need for technicians to lift electrical leads from terminal boards during testin l&C technicians had recently completed replacing a relay in the affected circuit associated with the failed Grayboot connector. PECO determined that the failure occurred during the post-maintenance testing. Technicians replaced the connector and sent it to the corporate laboratory for failure analysis (including destructive examination).
The analysis determined that the wire connection had been over-crimped during the initial installation. The failure was attributed to the technician improperly setting the l-
'
crimping tool from its initial calibration setting. PECO removed six other Grayboot connectors to analyze them and determine if the problem was more wide spread. No similar problems were foun PECO initially reported the de-energized portion of the shutdown cooling logic to the NRC as an event that alone could prevent fulfillment of a safety function (10 CFR 50.72(b)(2)(iii)(B)). On April 8, PECO retracted the notification based on further evaluation of the licensing basis for shutdown cooling. PECO determined that the event alone did not render the shutdown cooling mode of RHR incapable of performing its design safety function. The inspector agreed with PECO's conclusions based on the contingency procedures and strategies in place to mitigate the consequences of this type of event, and because operators normally manipulate the shutdown cooling system manuall Conclusions l
l During a plant tour an equipment operator identified that a portion of the isolation logic for the shutdown cooling mode of the residual heat removal system was de-energized.
! PECO determined the event was caused by an open circuit at a Grayboot connector as a result of over crimping. PECO performed a thorough analysis including destructive examination of other similar connectors to conclude that a generic issue involving the connectors did not exist.
, 08 Miscellaneous Operations issues (90712)
l 08.1 (Closed) Violations 97-10-01 and 98-03-01: Accuracy of unified control room log. The inspector identified several problems demonstrating weak log keeping practices regarding safety-related equipment. The operators were not keeping the unified control room log current (including LCO entries) and excessively used back dating for many of the log entries. Following the first violation, PECO implemented increased supervisory log reviews; however, this corrective action did not prevent recurrence and resulted in the second violatio e
. - - -
.
a
,
The reasons for the violation and the corrective actions taken to prevent future noncompliance were contained in PECO's letter dated July 16,1998. The inspector reviewed these items and reviewed the control room unified log over several months to evaluate the effectiveness of the corrective actions. The inspector found the operators log keeping practices to be much improved. However, the inspector recently noted that some operators continue to back date log entries without explanation and did not record come items in the chronological sequence. These items are close II. Maintenance l
l M1 Conduct of Maintenance M1.1 General Comments on Maintenance Activities (62707)
l The inspectors observed selected maintenance activities to determine whether approved
! procedures were in use, details were adequate, technical specifications were satisfied, maintenance was performed by knowledgeable personnel, and post-maintenance testing
,
was appropriately completed.
l l The inspectors observed portions of the following work activities:
l e Unit 1, Safeguards 181 battery replacement - March 9 -13; l
'
e Unit 2, New Fuel Receipt and Inspection - March 5 - 12; e Unit 2, Welding New Downcomers Skimmer Surge Tank - March 5; e Unit 2, Replacement of Grayboot Connectors in NSSS - March 27; e Unit 1, D11 EDG transfer switch installation - April Pre-planned maintenance activities were appropriately conducted and controlle Observed maintenance and operations personnel utilized good self-check techniques, communication techniques, and verification during post-maintenance testing.
!
l M1.2 Gemral Comments on Surveillance Activities (61726)
l l 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 The inspectors observed portions of the following surveillance activities:
e Unit 2 - Special Test SP-192, Dynamic VOTES Test - HV-51-2F0248 - March 3; e Unit 2 - ST-2-051-106-2 Division ll RHR (LPCI) Logic System Simulated / Simulated Automatic Actuation (LSF/SAA) - Non-outage - March 4; e Unit 2 - ST-6-051-232-1,1B Residual Heat Removal (RHR) Pump, Valve, and Flow - March 4;
.
.
e Unit 2 - ST-2-049-101-2, RCIC LSF/SAA and NSSSS RCIC lsolation - March 11; e Unit 2 - S74.0.A - Operation of Transversing in-core Probe System - March 18; e Unit 1 - ST-6-051-233-1,1C RHR Pump, Valve, and Flow - March 18 e Unit 1 - ST-6-051-363-1, System 051 Inservice Inspection Valve Indication Verification Test - March 18; ,
o Unit 2 - ST-2-055-810-2, HPCI Response Time Testing - March 2 '
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 Safeauards 181 Batterv Reolacement - Unit 1 (62707) Insoection Scope
' The inspector observed portions of the 1B1D101 125vde battery replacement. The work activities included replacing the 60 battery cells and the inter-connecting hardware, and inspecting and cleaning of the battery rack. The inspector discussed the activities with several maintenance technicians to assess their understanding of the battery activitie The inspector also reviewed the operations log for appropriate TS LCO entrie Qbservations and Findinas During the week of March 8, maintenance electricians completely replaced the 181D101 125vde portion of the HPCI 250vde battery. The battery was maintained operable ,
throughout the evolution by jumpering the 15 cells to be replaced with a temporary l safeguards battery. The temporary battery was maintained in the same condition as the inservice battery, was mounted in a seismically qualified cart, and met the requirements of technical specification The inspector observed that general housekeeping in the battery room throughout the evolution was very good. The temporary battery cables were routed through an industrial cable guard on the floor, tools and other materials were properly stored, and the disconnected battery cables were properly isolated. The inspector also noted that the technicians knew the activity well and were very careful during the evolutio Portions of the seismically qualified battery rack were repaired after electricians identified pitting damage from a previous acid spill. Very good supervisory and engineering ;
oversight was also observed. The electricians coordinated with operations personnel l well and the battery replacement was completed without inciden Conclusion The 181D101 125vde battery replacement activity was well planned and execute Maintenance technicians were very knowledgeable of all aspects of the battery activitie r
,
C
M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Plant Housekeepina Inspection Scooe (71750) i The inspector assessed plant housekeeping and general area mat 6 rial conditio . Observations and Findinas During the inspection period the inspectors observed numerous housekeeping deficiencies that had the potential to impact safety-related equipment. The deficiencies were typically in the vicinity of, and as a result of, work activities to address deficient Thermolag fire barriers. Pre-outage staging of tools and equipment also contributed to the problems identified. Examples of some of the deficiencies included the following:
e A number of fire doors that would not completely close or latch properl e Operators were not aware that fire retardant drapes covered service water booster pumps, although pumps were not in operatio * Assorted grating and cable tray / panel covers were tied-off to safety-related
^
condui e Metal pins and other debris from fire barrier upgrades were on top of the recirculation pump trip (RPT) breaker cabinets in close proximity to ventilation louver e Large unrestrained rolling equipment, such as tool / storage boxes, equipment carts, and vacuums, were in the vicinity of safety-related equipmen e Ladders were stored such that they could fall and impact safety-related switchgea * Plywood and other large materials were laying on cables within cable tray e A fork lift was parked close to safety-related switchgea e Access to the Unit 2 post-accident sample station was blocked by a combination of scaffolding, a large equipment box, and other materials that could have delayed post-accident sampling, if necessary, e- Combustible material such as portable equipment with long electrical cords, electrical extension cords, and canvas tool bags were left unattended in
- combustion free zone !
l
,.
l The inspector discussed the deficiencies with appropriate PECO staff who promptly l resolved the specific issues. In addition, PECO management had the associated l housekeeping coordinators walkdown all areas of the plant. PECO management also
- provided increased presence in the plant to reinforce housekeeping expectations.
l Following this intervention by plant management the inspector noted housekeeping and
'
general area material condition had improve Conclusions -
l The inspector observed that the housekeeping and general area material condition had l degraded, particularly in the vicinity of fire barrier upgrades. Corrective actions to
,
resolve the deficiencies were appropriate, i
!
M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Violation 98-09-01: Procedure adherence error during dry cask shipping activities. The inspector identified that a supervisor, overseeing the loading of a spent fuel bundle into a shipping cask, failed to comply with the approved procedure and completely relied upon the judgment of a vendor contractor when difficulties were encountered during cask loading activities. Also, the inspector identified that the governing procedure, M-053-006, had not been adequately reviewed by PECO or contractor prior to the commencement of activities. PECO reviewed and documented the results of their evaluation in PEP 1000915 PECO determined that they and the supporting contractors did not effectively plan and prepare for the irradiated fuel shipment. The procedure was incomplete in several areas, did not incorporate the appropriate level of verification, and did not outline clearly the acceptance criteria for the activity. Furthermore, PECO did not understand the acceptance criteria of the activity and relied heavily upon the vendor to determine if performance of activities were acceptabl PECO's corrective actions included:
o revision of procedure M-053-006 to implement the lessons learned from the PEP; e at employee all-hand meetings, emphasis of safe and event free operations through worker attention to detail, the importance of accurate and correct procedures, and the importance of maintaining control of vendor oversight; e reinforced management expectations that shift management be notified promptly whenever significant problems are encountered on the refueling floor or other plant area The inspector determined that PECO's corrective actions were appropriate and noted improved performance during a recent maintenance outage (IM32). This item is close :
,
.
8 ,
M8.2 (Closed) LER 1-99-002: Failure to perform a Technical Specification surveillance required locked-valve inspection. Station personnel identified this event as a result of {
corrective actions implemented for a previous similar event. The locked-closed check for {
valve HV-087-124A had been inadvertently deleted from the surveillance test (ST)-6- )
060-460-1 (Primary Containment Isolation Capability Check) during a procedure l revision. Personnel error and an inadequate review caused this event. The discrepancy ]
!
was identified on March 3, and the valve was promptly verified to be locked-closed. The l last surveillance of the valve occurred on December 3,1998. PECO corrected the j procedure and sampled other similar procedures for the same type of problem finding no
]
other problems. PECO plans to review the procedure revision process and implement
]
enhancements to the process. Technical Specification 4.6.1.1.b requires that all primary <
j containment penetrations listed in Table 3.6.3-1 not automatically isolated be verified in l their proper position every 31 days. The failure to perform this verification within the specified interval is a violation of technical specifications. This Severity Level IV violation is being treated as a Non-Cited Violation NCV 352,353/99-02-01, consistent with Appendix C of the NRC Enforcement Policy. This violation is in PECO's corrective action
- program as PEP 1000952 . Engineering l
E8 Miscellaneous Engineering lasues (92903)
l E (Closed) LER 1-98-018: Fire Safe Shutdown Deficiencies 1 Insoection Scope (92903) ,
l On September 11,1998, PECO engineers determined that unprotected emergency diesel generator (EDG) speed and voltage control cables for remote operation could be susceptible to fire induced damage and disable local diesel operation necessary to l support a safe plant shutdown during some postulated fires. The inspectors evaluated l PECO's interim assessment, compensatory actions, and planned permanent resolutio Observations and Findinas During Thermo-lag reduction project reviews PECO engineers identified five separate fire areas that contained unprotected EDG control cables that might result in loss of the
- EDG credited for fire safe shutdown (FSSD) following the postulated fire. The affected l areas were located in the control structure and the Unit 2 reactor building. FSSD strategies for these areas rely upon three separate EDGs, depending on the location of the fire. The remote speed and voltage control cables routed through the areas of concern were not protected by appropriate fire retarding coverings or fuses so fire induced faults could potentially cause the failure of the control power fuses, disabling the EDGs. Additionally, repair efforts would be complicated by the local / remote transfer switch not completely disconnecting the faulted remote circuit )
.
PECO determined that the deficiencies were a result of incorrect original design assumptions. In addition, when similar problems were found in other areas, these deficiencies were not identified. A sampling review of other similar circuits was performed and no other deficiencies were identified. As an interim corrective measure, PECO verified that the effected areas were being inspected by a hourly firewatch. The unprotected cable deficiencies were added to the outstanding fire system deficiency list and operators were alerted of the problem via shift night orders. PECO installed sacrificial fuses and transfer switches to protect the local control circuits from being disabled by remote fires for two of the three EDGs during this inspection period. PECO plans to implement a revised FSSD strategy as part of the resolution for degraded THERMOLAG fire barriers. The revised strategies will be implemented in mid-May and eliminate the reliance on the third EDG to achieve FSSD, therefore no additional modifications are planned for that ED PECO failed to maintain the provisions of the approved Fire Protection Program as described in the Limerick UFSAR and is a violation of the Facility Operating Licens This Severity Level IV violation is being treated as a Non-Cited Violation NCV 352,353/99-02-02, consistent with Appendix C of the NRC Enforcement Policy. This violation is in PECO's corrective action program enhancement process (PEP) evaluation 1000892 The inspector determined that the interim contingencies to address the identified problems were deficient in that formal plans were not provided to operators to ensure local diesel operation could be maintained or restored. Based on the complexity and personnel hazards involved with potential troubleshooting and repair activities, PECO decided not to develop a prescripted strategy or procedure for temporary repair. The inspector was concemed that, in the unlikely event of the postulated fire, operators may not be able to identify and correct the faulted circuitry. Further, the interim action to heighten operator awareness of the issue had eroded as evidenced by operators being unaware of the problem when interviewe Although the permanent resolutions for each of the EDGs were appropriate, the complexity of the modifications necessitated a relatively long implementation period (5 to 8 months). A formal risk assessment was not performed to support the implementation schedule particularly important in light of not having a viable repair strategy in the unlikely event that the postulated fire were to occur. Furthermore, the inspector found extensive amounts of work ongoing in the fire areas of concern. The inspector was concerned that the normally low probability of a fire initiating event could be increased by these types of work activities resulting in increased plant risk associated with the fire event The inspector noted that the operability determination had not addressed local EDG operation, the applicable safety function. Fire protection requirements for certain postulated fires credit local EDG operation, although not required by Technical Specifications. Specifically, the inspector observed that for certain fire events, the operators may not be able to operate the diesels locally.
i
- - _ _ _ _ _ _ _ _ _
.
10 Plant management acknowledged the inspectors concerns and plans to review the nonconformance review process to ensure the guidance for addressing operability is 1 adequate. Through interviews and independent evaluation the inspector determined that
'
, there was a reasonable assurance of safety, based on risk insights and adequate
! defense in depth, to identify and suppress the postulated fires. Specifically, the defense in depth was provided by the compensatory fire watch that provided diverse detection and suppression capability coupled with the availability of installed automatic fire
'
detection and suppression system Conclusions l
Overall PECO's identification of fire areas that contained unprotected emergency diesel !
generator control cables and the permanent resolution were very good. However, interim corrective actions and risk assessments were deficient as a result of the operability determination not addressing the appropriate safety function. The i unprotected emergency diesel generator control cables represented a failure to maintain l
the provisions of the Facility Operating License. This failure is a Severity Level IV violation which is being treated as a Non-Cited Violation consistent with Appendix C of I the NRC Enforcement Policy. This violation is in PECO's corrective action program enhancement process (PEP) evaluation 1000892 IV. Plant Support 4 S8 Miscellaneous Security and Safety issues l
S8.1 (Closed) LER 1-99-001: Compromise of safeguards information. This event was caused l by less than adequate administrative controls for saving safeguards information on a computer's hard-drive. On February 17,1999, a security supervisor discovered an older version of the station's security plan saved on the stand-alone computer's hard drive located in the security department's office space. The security office, which is located I outside the protected area, is normally inhabited during normal working hours by security l personnel and is locked and patrolled every two hours during off-hours. The computer l was exclusively used for safeguards documents and was not connected to the local-l area-network. The information was not on the monitor's screen and was not immediately l recognizable in the file directory. The supervisor immediately took control of the I
information and deleted it from the computer's hard drive. PECO determined that the information had apparently been inadvertently saved as a backup file by the word processing program in April 1998. This program feature was intended to be disable PECO heightened the awareness of the security force regarding safeguard material. All security computers located in the security office were scanned to ensure no safeguard information files were stored on the respective hard drives. Further, the computer system was replaced with a laptop computer to afford the ability to secure it within an approved safeguards container when the user is finished using the computer.10 CFR 73.21 requires, in part, that each licensee shall ensure that safeguards information is protected against unauthorized disclosure. The failure to properly protect the safeguards information is a violation. This Severity Level IV violation is being treated as a Non-Cited
1 l
!
y
,
Violation NCV 352,353/99-02-03, consistent with Appendix C of the NRC Enforcement Policy. This violation is in PECO's corrective action program as PEP 1000946 F2 Status of Fire Protection Facilities and Equipment F2.1 Fire System imoairment Insoection Scope (71750)
The inspector observed rubber matting on the scaffolding in the Unit i reactor building that appeared to interfere with a fire suppression system that provides a water curtain ;
'
separating two fire areas. The matting also added combustible material within the combustion free zone (CFZ). The inspector discussed the observations with PECO staff and evaluated their followup action .
I Observations and Findinos The inspector identified that the scaffolding built in a CFZ in Unit 1 Reactor building 217'
elevation was covered with rubber matting. Although the scaffold had been constructed l using open grate decking to ensure that it did not interfere with the fire suppression j system in the CFZ, rubber matting was subsequently used for worker protection and
! comfort. The matting was not evaluated for combustibility and location, nor was a fire
'
'
system impairment initiated. The CFZ and water curtain maintain separation between the two fire zones to ensure that at least one train of equipment necessary for a fire safe shutdown would be available during postulated fires. The continuous fire watch required by PECO's fire system impairment process was not poste The inspector discussed his concerns with PECO staff who promptly removed the rubber l matting. Plant staff also verified that other scaffolds in use did not impair nearby suppression systems and initiated a performance enhancement program (PEP i 10009649) evaluation to further address the issue. The inspector determined that the l immediate corrective action were adequate and this was a minor violation not subject to formal enforcement. However, the inspector was concemed that the high level of work activity and time constraints involved with the resolution of degraded Thermolag fire barriers was causing the typically good performance in this area to decline.
i
' Conclusions PECO did not evaluate the use of rubber matting on scaffolds in the vicinity of a fire scopression system in a combustion free zone nor initiate a fire system impairment resulting in a degraded and uncompensated fire barrier. PECO promptly rectified the deficiency when informed by the inspecto :
l
)
!
l l
.
.
V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to members of plant management at the conclusion of the inspection on April 26,1999. The plant manager acknowledged the inspectors' findings. The inspectors asked whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie I
.
i
.
.
INSPECTION PROCEDURES USED
- IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 90712: In-office Review of Written Reports
. IP 92902: Follow-up Maintenance IP 92903: Follow-up Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened / Closed 50-352/99-02-01 NCV Failure to perform a Technical Specification surveillance required locked-valve inspection. (Section M8.2)
50-352,353/99-02-02 NCV Fire Safe Shutdown Deficiencies (Section E8.1)
50-352,353/99-02-03 NCV Compromise of safeguards information. (Section S8.1)
Closed 50-352,353/97-10-01 V!O Operations log did not accurately reflect conditions in the plant. (Section 08.1)
50-352,353/98-03-01 VIO Operations log did not accurately reflect conditions in the plant. (Section 08.1)
50-352,353/98-09-01 VIO Procedure adherence error during dry cask shipping activities. (Section M8.1)
50-352,353/1-98-018 LER Fire Safe Shutdown Deficiencies (Section E8.1)
50-352,353/1-99-001 LER Compromise of safeguards information. (Section S8.1)
50-352/1-99-002 LER Failure to perform a Technical Specification surveillance required locked-valve inspection. (Section M8.2)
Discussed None
.c
LIST OF ACRONYMS USED CFR Code of Federal Regulations EDG Emergency Diesel Generator EO Equipment Operator EOC End Of Cycle FSSD Fce Safe Shutdown HPCI High Pressure Coolant Injection IR inspection Report JCO Justification for Continued Operation LCO Limiting Condition For Operation LER Licensee Event Report NCV Non-Cited Violation NRC Nuclear Regulatory Commission PDR Public Document Room PECO PECO Energy PEP Performance Enhancement Process RCIC Reactor Core Isolation Cooling RERS Reactor Enclosure Recirculation System RHR Residual Heat Removal RPT Recirculation Pump Trip SBGT Standby Gas Treatment ST Surveillance Test TS Technical Specification UFSAR Updated Final Safety Analysis Report VIO Violation I
!