IR 05000352/1999003

Insp Repts 50-352/99-03 & 50-353/99-03 on 990413-0524.No Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support.Also Inspected, Radiological Protection,Security & Inservice Insp

ML20196G730
Person / Time
Site:	Limerick
Issue date:	06/24/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196G709	List: IR 05000352/1999003 ML20196G704
References
50-352-99-03, 50-352-99-3, 50-353-99-03, 50-353-99-3, NUDOCS 9907010254
Download: ML20196G730 (32)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No <

50-353 License No NPF-39 NPF-85 Report Nos.' 99-03 99-03 Licensee: PECO Energy Correspondence Control Desk P.O. Box 195 Wayne, PA 19087-0195 )

- Facilities: Limerick Generating Station, Units 1 and 2

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Location: Wayne, PA 19087-0195 Dates: April 13,1999 through May 24,1999 Inspectors: A. L Burritt, Senior Resident inspector F. P. Bonnett, Resident inspector A. Lohmeier, Senior Reactor Engineer, DRS G. Smith, Senior Security Specialist, DRS C. Cahill, Reactor Engineer, DRS D. Dempsey, Reactor Engineer, DRS W. Maier, Reactor Engineer, DRS G. Morris, Reactor Engineer, DRS R. Ragland, Radiation Specialist, DRS C. Sisco, Operations Engineer, DRS l

Approved by: Curtis Cowgill, Chief Projects Branch 4 Division of Reactor Projects )

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9907010254 990624 PDR ADOCK 05000352 G PDR i

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EXECUTIVE SUMMARY Limerick Generating Station, Units 1 & 2 NRC Inspection Report 50-352/99-03,50-353/99-03 This integrated inspection included aspects of PECO Energy operations, maintenance,

- engineering, and plant support.: The report covers a six-week period of resident inspection and region-based inspection in the radiological protection, security, inservice inspection, and contractor oversight area Operations e Control room and refueling platform operators conducted shutdown and refueling activities well. Operators made effective use of procedures and peer-checking during the outage. PECO management's oversight of the outage provided effective support for station and contractor personnel and ensured that the outage was conducted safel (Section 01.2)

e The control room staff's response to the complete loss of feedwater event and automatic reactor shutdown from full power was excellent. The operators successfully dealt with the several equipment failures that challenged them following the automatic reactor shutdown. PECO's review and interim corrective actions were adequate to support safe restart of Unit 1. (Section O4.1)

Maintenance e The Limerick Generating Staten t Init 2 inservice inspection program for the first 10 year interval was conducted as per t.,, ualuirements of Sections V and XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code. Acceptable procedures and calibrated equipment were used by qualified and certifed personnel to conduct the various types of examinations. Inspection results were comprehensively documented. (Section M1.3)

e The baseline uhrasonic testing (UT) inspection of the core shroud was performed in accordance with a core shroud inspection plan submitted in response to Generic Letter (GL) 94-03. The UT examination of the core shroud circumferential welds found several indications in circumferential welds. Analyses of the effect of indications indicated that operation until the next refueling outage (2R06) was acceptable. (Section M1.4)

e The non destructive examination vendor oversight plan was comprehensive and effective. (Section M7.1)

Enaineering

• PECO provided good oversight of engineering calculations performed by contractor ,

Safe shutdown cable ampacity calculations were well organized, and the methodology l was consistent with established industry practices. (Section E1.1)

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Executive Summary (cont'd)

e PECO provided good oversight of contractor activities involving sprinkler modification The reviewed sprinkler modifications were well organized and the methodology was .

consistent with established industry practices. The calculations were appropriate to reflect the as-built system condition. (Section E1.2)

e The Darmatt KM1 design, installation and engineering dispositions were thorough and complete and PECO provided good oversight of the vendors' activities. (Section E1.3)

e PECO provided appropriate oversight of the vendors' activities involving, control room recorder replacements, reactor protection system instrument relocation during the main turbine retrofit ar.d main steam relief valve replacement. (Section E1.4) -

o The quality assurance inspectors were very knowledgeable about the Darmatt KM1 fire barrier system installation and inspection requirements. The quality assurance inspectors provided good quality assurance oversight of the vendor installed produc (Section E7.1)

L Plant Support -

e . Radiological controls for Limerick Unit 2 fifth refuel outage were effectively planned and implemented and focused on jobs with elevated exposure estimates. (Section R1.1)

e Self assessments and corrective action programs, were effectively used. PECO l identified, evaluated, and resolved radiological control issues as evidenced by the l conduct of multiple self-assessments and audits to satisfy the radiation protection program review requirements. (Section R7)

e PECO was conducting security and safeguards activities in a manner that protected public health and safety in the areas of access authorization, alarm stations, communications, and protected area access control of personnel and pwekages. This f- portion of the program, as implemented, met the commitments and NRC requirement (Section S1)

e PECO security facilities and equipment in the areas of protected area assessment aids, l

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protected area detection aids, and personnel search equipment were determined to be well maintained and were able to meet the commitments and NRC requirement (Section S2)

e Security and safeguards procedures and documentation were being properly implemented. Event logs were being properly maintained and effectively used to !

analyze, track, and resolve safeguards events. (Section S3)

e The security force members adequately demonstrated that they had the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their position. (Section S4)

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Executive Summary (cont'd)

e Security force personnel were being trained in accordance with the requirements of the Training and Qualification Plan, training documentation was properly maintained and

, accurate, and the training provided by the training staff was effective. (Section SS)

e The level of management support was adequate to ensure effective implementation of the security program, and was evidenced by adequate staffing levels and the allocation of resources to support programmatic needs. (Section S6)

e The review of PECO's Security and Safeguards audit program indicated that the audits were comprehensive in scope and depth, that findings were reported to the appropriate level of management, and that the program was being properly administered. In addition, a review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and reso:ve potential weakness. (Section S7)

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EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

' TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v i

l Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 .

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- l . Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 : Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 . General Comments ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Unit 2 Refueling Outage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 t 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . 3

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O2.1 Facility Tours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 02.2_ Engineered Safety Feature (ESF) System Walkdowns . . . . . . . . . . . . 3

! 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 04.1 Automatic Shutdown From Full Power - Unit 1. . . . . . . . . . . . . . . . . . . 3 L ll. Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 l M1 - Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M1.1 . General Comments on Maintenance Activities . . . . . . . . . . . . . . . . . . . 5 M1.2 General Comments on Surveillance Activities . . . . . . . . . . . . . . . . . . . 5 i

M1.3 Inservice inspection (ISI) Program Review . . . . . . . . . . . . . . . . . . . . . . 6 M1.4 - Core Shroud Ultrasonic Examination . . . . . . . . . . . . . . . . . . . . 8 L M7- Quality Assurance in Maintenance Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i

! M7.1 Oversight of Vendor NDE Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 j

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M8- Miscellaneous Maintenance lasues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l

M8.1 (Closed) LElk 2-99-002 Various ESF Actuations Due to Loss of

. Power to 2A RPS/UPS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l li . Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 E1 Conduct of Engineering . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . 10 E1.1 Engineering Oversight of Vendor Supplied Cable Ampacity Derating L Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 L E1.2 ' Engineering Oversight of Contractor Designed and installed Sprinkler Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 E1.3 Engineering Review and Closeout of Contractor Designed and Installed Datmatt KM 1 Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 E1.4 Engineering Oversight of Miscellaneous Contractor Designed and installed Engineering Modifications . . . . . . . . . . . . . . . . . 13 i

E7 Quality Assurance in Engineering Activities . . . . . . . . . . . . . . . . . . . . . . . . . . 13 E7.1 Quality Assurance inspection of Vendor installed Darmatt KM1 Fire Barrier System . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 IV. Plant Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

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R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 14 R1.1 Unit 2 Refuel Outage Radiological Controls . . . . . . . . . . . . . . . . . . . . 14 R7 Quality Assurance in Radiological Protection and Chemistry Activities . . . . . 15 R8 Miscellaneous RP&C lssues . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . 16 R8.1 (Closed) IFl 98-03-02 " Electronic Dosimeters Not Commensurate with Radiological Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 R8.2 (Closed) IFl 98-03-03 " Advanced Radiation Worker (ARW) orogram . 16 l R8.3 (Closed) IFl 98-03-04 " Temporary Technician Qualifications . . . . . . . 16 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . 17 S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . , . . 18 S3 Security and Safeguards Procedure 5 Q1d Documentation . . . . . . . . . . . . . . . 19 S4 Security and Safeguards Staff Knowiedge and Performance . . . . . . . . . . . . . . ig SS Security and Safeguards Staff Training and Qualification . . . . . . . . . . . . . . . 20 S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 S7 Quality Assurance in Security and Safeguards Activities . . . . . . . . . . . . . . . . 21 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

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X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

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ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 LIST OF ACRONYM S U SED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 t

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ftenort Details 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; rod pattem adjustments, and the following plant even *- April 20 Unit i reactor automatically shutdown on low reactor level due to a total loss of all feedwater to the reactor. Operators restored reactor level and stabilized the unit using the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems. Operators placed the unit in a cold shutdown (<200*F) conditio e April 23 Operators placed the mode switch to Startup and made the reactor critical i in the early moming of April 2 Unit 2 began this inspection period operating at 81% power in end-of-cycle coastdown operations. Unit 2 operators shutdown the unit on April 16, to begin the fifth refueling outage .

On May 23, operators placed the mode switch to Startup and made the reactor critical in the early moming of May 2 I, Operations 01 Conduct of Operations'

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01.1 General Comments (71707)

PECO Energy (PECO) conducted at power activities at Limerick Units 1 and 2 safel 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 comprehensive. Operators implemented effective controls for work activities using conservative decision makin .2 Unit 2 Refuelina Outaae Insoection Scope (71707. 60710)

The inspectors observed and assessed the implementation of the Unit 2 refueling i outage. The inspectors observed shutdown and startup activities in the main control l room and fuel handling operations to ascertain whether the activities were performed per  ;

approved procedures. The inspector also reviewed whether plant conditions were being ,

i 1 Topical hoodings such as o1, MB, etc., are used in accordance with the NRC standardized reactor inspection report ,

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outline. Individual reports are not expected to address all outline topic .

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maintained in accordance with Technical Specifications. The inspector observed plant management's oversight of the staff and contractor personne Observations and Findinas The refuelin'; cutage began on April 16. Major activities to be accomplished during the outage induded:

o replacement of low pressure emergency core cooling system (ECCS) suction strainers in the suppression pool;

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e replacement of two-stage Target Rock safety relief valves (SRVs) with three l stage Target Rock SRVs in the drywell; i .e completion of an altemate decay heat removal modification; and e a major retrofit of the main turbin The inspectors observed activities throughout the outage and made the following

observations. The control room atmosphere was professional, reactor engineering provided appropriate oversight during reactivity changes and shift supervision effectively controlled station activities. Operators used appropriate instructions and system *

operating procedures. The inspector observed good peer-checking, self-checking, and attention to detail techniques on the part of the operators. Well-planned pre-evolution shift briefings were conducte The fuel handling director (FHD) controlled refueling activit; ass in accordance with approved procedures. The inspector observed generally good oversight by the FHD of fuel shuffle and local power range monitor replacement activities. One error occurred on May 7, when the refueling platform operator inadvertently bumped two fuel bundles when lowering a fuel bundle into the core. No damage occurred to the fuel bundles and PECO verified the ;ntegrity of the fuel bundles with the fuel vendor. This issue was entered into the performance enhancement program (PEP 10009814). The inspectors reviewed

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PECO's analysis regarding fuel bundle integrity and had no question The inspector observed that station senior managers maintained proper oversight of the station staff and contractor personnelincluding routine in-plant observation of activitie The inspector determined that PECO staff maintained plant conditions as required by Technical Specifications throughout the outag Conclus1901 Control room operators conducted the startup and shutdown activities well, and the refueling platform operators generally performed their refue!ing activities well. Operators made effective use of procedures and peer-checking during the outage. PECO management's oversight of the outage provided effective support for station and

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02 Operational Status of Facilities and Equipment 02.1 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

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parameters, support system availability, and current system operational status were consistent with Technical Speafication (TS) requirements and Updated Final Safet Analysis Report (UFSAR) descriptions. System operability and material conditions were

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' noted to be acceptable in all cases. The inspectors did not identify any substantive -

concems or deficiencies as a result of these walkdown .2 Enoineered Safety Feature (ESF) System Walkdowns (71707)

The inspectors used Inspection Procedure 71707 to walk-down accessible portions of the following ESF systems:

e Low Pressure Coolant injection (LPCI) System - Unit 2 (Drywell)

e Reactor Core injection Cooling (RCIC) System - Unit 2 o High Pressure Coolant injection (HPCI) System - Unit 2 Equipment operability, material condition, and housekeeping were acceptable in all cases. The inspectors identified no substantive concems as a result of these walkdown Operator Knowledge and Performance-04.1 Automatic Shutdown From Full Power - Unit 1 Insoection Scoos (71707)

The inspector observed PECO's response to the automatic shutdown at Unit 1. The inspector attended meetings and reviewed PECO's initial evaluations to various issues identified during the event. The inspector observed that PECO addressed each issue sufficiently to allow the re-start of Unit , , Observations and Findinas On April 20,1999, Unit 1 automatically shutdown from 100% power due to a low reactor water level condition. All three reactor feed pumps (RFPs) stopped automatically due to a loss of suction pressure which created a complete loss of feedwater and resulted in a low reactor water level condition. The low suction pressure condition was created by all

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. eight of the condensate deep bed domineralizer effluent valves simultaneously going shut Reactor level decreased beyond the Level 2 setpoint (-38") which caused the

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- automatic initiation of the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems. Operators restored and maintained the reactor at a

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normal level using the HPCI and ROIC systems. The operators confirmed that all automatic protective functions and isolations associated with the scram functioned as ,

designe The operators encountered several equipment malfunctions during the event, including:

e one of the two in-series recirculation pump trip (RPT) breakers failed to trip automatically, was found smcking, and operators had to remotely open the breaker from the main control room; e the main condenser mechanical vacuum pump failed to start on demand due to a circuit breaker problem; ,

e operators found an auxiliary steam valve mispositioned and were unable to align auxiliary steam to supply steam to the main condenserjet air ejectors; e the HPCI vacuum pump tripped several times causing condensation build-up in pump casin Overall, unit operators responded well to the event. When the mechanical vacuum pump failed, main condenser vacuum decreased, and the operators closed the main steam isolation valves. Subsequently, operators controlled reactor vessel pressure and reactor water level with the HPCI and RCIC systems until the condensate and feedwater

. systems were restored. The inspector determined that the control room staffs performance was excellent throughout the even PECO's evaluation of the event determined that the cause of the loss of feedwater event was an electrical power loss that affected all of the condensate deep bed demineralizer inlet valve position indications. The Programmable Logic Controller (PLC) in the valve control circuit commanded the effluent valves to close when the position indication from the inlet valves was interrupted by a spurious opening of a circuit breaker. During the j investigation, PECO initiated three Performance Enhancement Program (PEP) entries 1 (10009762,10009727,1000g741) to further evaluate and determine appropriate long term !

corrective actions. Interim corrective actbns included opening and de-energizing all 1 domineralizer outlet valves to prevent a partial loss of electrical power from causing the l loss of the feed and condensate system. The inspectors reviewed PECO's actions and concluded they were acceptabl The inspectors determined that PECO's meetings and briefing sessions were thorough, focused on safety, and prov oed a comprehensive review regarding the various issues from the event. PECO was unable to determine the precise cause of the spurious opening of the circuit breaker that initially caused the event and the cause of the one !

RPT breaker failing to trip prior to replacing the affected circuit breakers. At the end of l the inspection period, the PECO evaluation of the cause of the breaker failures was still

ongoing. The inspector also determined that PECO appropriately addressed all of the issues prior to restart of the uni l l

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The control room staff's response to the complete loss of feedwater event and reactor scram from full power was excellent. The operators successfully dealt with the several equipment failures that challenged them following the automatic reactor shutdow PECO's review and interim corrective actions were adequate to support safe restart of Unit 1, i

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M1.1 General Comments on Maintenance Activities (62707)

The inspectors observed selected maintenance activities to determine whether approved procedures were in use, technical specifications were satisfied, maintenance was j performed by knowledgeable personnel, and post-maintenance testing was appropriately l complete The inspectors observed portions of the following work activities:

• Unit 2 - Safety Relief Valve Replacement - April 23

• Unit 2 - 2A Residual Heat Removal (RHR) pump removal - April 23; e Und 2 - Low Pressure ECCS pump Suction Strainer Replacement - April 28; e Unit 2 - Control Rod Drive Replacement - April 29; e Unit 2 - Local Power Range Monitor Replacement - May Observed maintenance activities 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 M1.2 General Comments on Surveillance Activities (61726)

The inspectors observed selected surveillance tests to determine whether approved procedures were in use, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by knowledgeable personnel, and test results either satisfied the acceptance criteria or were properly dispositioned.

l The inspectors observed portions of the following surveillance activities:

• Unit 2 - ST-1-092-113-2, D23 Diesel Generator 4kv SFGD Loss of Power LSF/SAA and Outage Testing - April 19; e Unit 1 - S51.8.H, Use of Dedicated LPCI Pumps for Shutdown Cooling (Shutdown cooling piping flush portion)- April 21; i e Unit 1 - ST-2-043-800-1, Recirculation Pump Breaker Arc Suppression Response

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e Unit 2 - ST-1-092-112-2, D22 Diesel Generator 4kV SFGD Loss of Power LSF/SAA and Outage Testing - May 11; e Unit 2 - ST-6-049-230-2, RCIC Pump, Valve, and Flow Test - May 24; e Unit 2 - ST-6-055-230-2, HPCI Pump, Valve, and Flow Test - May 24 Observed surveillance tests were conducted well using approved procedures, and were completed with satisfactory results. Communications among the various work and support groups were good, and supervisor oversight was goo , M1.3 Inservice insoection USI) Proaram Review Insoection Scope (73753)

The inspectors reviewed the status of the first 10 year interval of the LGS Unit 2 inservice inspection (ISI) program to verify compliance with the requirements of Sections V (Nondestructive Examination (NDE)) and XI (Inservice Inspection of Nuclear Power 1 Plant Components) of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PVC) . Several activities were observed by the inspectors, including those using visual (VT), magnetic particle (MT), ultrasonic (UT), and radiographic (RT) examination methods, Observations and Findinas Completion of the First 10 Year Interval of the Limerick Unit 2 ISI The inspectors found that the first 10 year interval ISI program was consistent with the -

requirements of ASME B&PVC Section XI, Artic!e IWB-2412, Inspection Program B, with respect to the completion of the required sample size for each inspection category, and documentation of relief requests and the respective NRC respons Review of Insoection Results Documentation The inspector reviewed the documentat:on of twenty-four (24) VT, MT, UT and RT examinations performed during the current refueling outage and determined that it was consistent with ASME Code requirements. The examinations covered the "A" RHR valve replacement weld, reactor pressure vessel (RPV) top and bottom head weld, RPV bolting examinations, and "B" core spray pump weld. Documentation of the examinations was comprehensive and included the procedure designation, the ultrasonic calibration data, the welds or material examined, the location of the examination, and the finding The inspectors noted the inspection results were appropriately reviewed, and signatures of the examiners and reviewers were found on the examination summary sheets. The i inspectors verified the qualification and certifications of the. technicians and reviewers ;

were in accordance with ASME and PECO quality assurance requirement ;

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Observation of Non-destructive Examinations The non-destructive examination (NDE) activities observed by the inspectors were found to be acceptable. NDE procedures were adequate for the component examinations that were conducted, and met ASME Code requirements. NDE contractor procedures were reviewed and approved by PECO and the authorized nuclear inservice inspector at the site. Work packages contained the appropriate procedures, drawings, and authorizations, and NDE technicians complied with the implementing procedures. The inspectors verified that the nine NDE personnel involved in the observed examinations were qualified and certified in accordance with ASME and PECO Quality Assurance Program requirements, including American Society for Non-Destructive Testing Recommended Practice No. SNT-TC-1 A. The examination data and evaluations for the activities that the inspectors observed met ASME Code and PECO ISI program requirements. No reportable indications were found from any of these examination Observations of ISI inspections included visual examination of reactor internals using i video tapes, ultrasonic testing of feedwater (FW) loop A pi.oing outside the dry-well, magnetic particle testing of the FW6 pipe-to-elbow weld, and VT of a RCIC system stru The inspectors noted that the NDE examiners followed the approved inspection procedures. The !aspectors also verified the NDE examiners' qualifications and certifications were in accordance with ASME and PECO quality assurance requirement Through review of ISI program report summaries, the inspectors also verified that PECO adequately performed augmented ISI of high energy main steam and feedwater pipe welds located between the inboard and outboard containment isolation valves in accordance with commitments contained in Section 6.6.8 of the UFSA Epdioar,achic Examination of A'temate Decav Heat Removal Modification Welds The inspectors reviewed the results of radiographic examination of two flange-to-pipe i welds for the attemate decay heat removal (ADHR) modification. This modification was

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designed to provide for decay heat removal from the RPV and spent fuel pool (SFP)

during the common residual heat removal (RHR) system shutdown cooling supply local leak rate test. The radiography was conducted by General Electric (GE) personnel with oversight by LGS NDE examiners and careful involvement of health physics (HP) and plant control room personnel during the radiographic procedure. Examination of radiographic film indicated acceptability of the weld in accordance with ASME Section lil, V, and X c. Conclusions The Limerick Generating Station Unit 2 inservice inspection program for the first 10 year interval was conducted as per the requirements of Sections V and XI of the ASME B&PVC. Acceptable procedures and calibrated equipment were used by qualified and certified personnel to conduct the various types of examinations. Inspection results were comprehensively documented.

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M1.4 Core Shroud Ultrasonic Examination a.' inspection Scooe (73753)

The inspectors reviewed results of the baseline UT inspection of the core shroud performed in accordance with a core shroud inspection plan developed in response to

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Generic Letter (GL) 94-03, "Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling Water Reactors", Reporting Requirement 2, and Requested Licensee Action 3, (development of an inspection plan). The inspector reviewed the results of the core shroud UT inspechon implemented during the outage, and the actions taken by PECO as a result of the finding Observations and Findings The inspector found that PECO satisfied GL 94-03 Reporting Requirement 2.(a)(b) in theirletter of January 12,1999. The letter described PECO's plan for the core shroud i baseline examination during the outage. The LGS Unit 2 core shroud has been in service for more than eight (8) years and Unit 2 has been identified as a Category B plant. For Category B plants, BWRVIP-01 recommends a limited inspection of sufficient length of specific core shroud circumferential welds to allow determination cf the weld structural integrity. These are circumferential welds H3, H4, H5, and H7.11 the cumulative weld length of flaw indication is greater or equal to 10% of the examined weld length, the scope of the inspections would be expanded to include welds H1, H2, and H-

, 6. The baseline examination of core shroud circumferential welds H3, H4, H5 and H7 revealed several indications at welds H3, H4 and H5. The extent of the indications exceeded 10% of the examined length. Therefore, the inspection scope was expanded i to include wolds H1, H2, and H The percentage of each "H" level scanned varied from 57.41% (H1) to 63.79% (H4) of the weld circumference, at both inner and outer shroud diameters. The percentage of the scanned length having indications varied from 0% (H7) to 61.4% (H3), while the maximum depth varied from 0.05 inches (H5) to 0.43 inches (H1). The most significant indications were in weld H4 (located in the region of highest fluence). There were indications in 40.85% of the weld examine i l

The evaluation of the results was performed by Structural Integrity Associates, Inc. The I evaluation was based on the limit load of the core barrel structure taking into account the i distribution of un-flawed material around the circumferential weld. In addition, the evaluation considered the results of linear elastic (LEFM) or elastic plastic fracture mechanics (EPFM) fracture of the flawed material. The flaw sizes were appropriately ,

enlarged in the analysis to account for the predicted flaw growth until the next refueling j outage. The goveming limit load safety factor was determined for H3 to be 6.51 versus the allowable 2.77; the safety factor for H4 was 13.16 versus the allowable 2.7 !

< . For H4, an LEFM evaluation determined the safety factor to be 3.67 versus the allowable i 2.77. On this basis, the core shrouds were determined to be operable to the next

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refueling outage 2R0 ..

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Reinspection wiil be made during the next outage to determine and evaluate the extent and effect of indication growth. The inspectors found the flaw evaluation approach to be consistent with the guidelines recommended for BWR core shroud and inspection and flaw evaluation by the Boiling Water Reactor Vessel and Intemals Project (BWRVIP) in

' Electric Power Research Institute (EPRI) report TR-10707 Conclusions The' baseline ultrasonic (UT) inspection of the core shroud was performed in accordance with a core shroud inspection plan submitted in response to Generic Letter (GL) 94-0 The UT examination of the core shroud circumferential welds found severalindications in circumferential welds. Analyses of the effect of indications indicated that operation until the next refueling outage (2R06) was acceptabl M7 Quality Assurance in Maintenance Activities M7.1 Oversiaht of Vendor NDE Activites Inspection Scope (73753)

The inspectors reviewed the NDE vendor oversight plan for LGS, including the procedure for oversight of vendor NDE activities, and observed oversight of the vendor NDE activity during ISI activities, Observations and Findinas The inspector reviewed the LGS NDE vendor oversight plan for the outage and found appropriate emphasis was placed on oversight of NDE vendor performance. The plan provided for continuous coverage during critical activities, such as the core shroud, jet pump, and core spray UT and VT examinations. The oversight was conducted in accordance with MAG-CG-418, " Oversight of Vendor NDE Activities." Features of the program included review and approval of procedures, verification of certifications, and witnessing or re-examining approximately 10% of the performed ISI examination During tours of the facility the inspector noted that the PECO staff was providing oversight of activitie The inspectors reviewed Quality Assurance Assessment Report LAR-98-009 and found that the quality assurance program complied with the Technical Specifications, the ASME Code, and the ISI program requirements, that the oversight program was effective, and that it included self-assessments and corrective actions for identified deficiencie Gonclusions The non destructive examination vendor oversight plan was comprehensive and effective.

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M8 ' Miscellaneous Maintenance lasues (92902)

M8.1 (Closed) LER 2-99-002 Various ESF Actuations Due to Loss of Power to 2A RPS/UPS

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u.Various safeguards actuations occurred due to the loss of power to the 2A reactor protection system (RPS) distribution panel on April 19,1999. The event occurred during the Unit 2 refueling outage while planned maintenance work was being performed on the 2B RPS channel. A RPS scram and several automatic primary containment and reactor vessel isolations were initiated when the 2B RPS channel de-energized as a result of the 2A RPS distribution panel (2AY160) de-energizing. - The 2AY160 panel de-energized when a loose bus-bar connection lost continuity for a sufficient time to activate .

the RPS system relays. PECO determined that the loose connection was the result of a -

marginal connection during initial installation combined with subsequent thermal cycling of the copper stud during normal operation.: No preventive maintenance had been performed on any of these connections for Unit 1 or 2. For corrective action, PECO repaired the connection, inspected the integrity of the 2B RPS channel and performed thermography inspections on the Unit 1 RPS distribution panels. For long term 3 corrective actions, PECO initiated a routine thermography inspection of the RPS breaker i bus-bar connections in the preventive maintenance program. No violations of NRC requirements occurred during this incident and this item is close . Engineering t

E1 Conduct of Engineering )

E Enaineerina Oversiaht of Vendor Suoolied Cable Amoacity Deratina Calculations Inspection Scoce (37550)

The inspectors reviewed several vendor supplied ampacity derating calculations,

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interviewed PECO and contractor personnel, and walked down portions of the fire barrier cable modifications to determine the adequacy of the engineering oversight of the vendor supplied engineering products, Observations and Findinos PECO has implemented several raceway encapsulation modifications as part of the Limerick Thermo-Lag Reduction Program. These modifications include the upgrade of some existing Thermo-Lag barriers, replacement of Thermo-lag with Darmatt KM1 encapsulation, or a combination of both Thermo-Lag and Darmatt KM1 encapsulatio As a result of the different fire barrier thermal characteristics, some revisions to the safe shutdown cable ampecity calculations were require The inspectors reviewed calculations LE-0101, "Ampacity Derating of Cables in Thermo-Lag Enclosed Raceways," and LE-0100, "Ampacity Derating of Cables in Darmatt KM1

- Enclosed Raceways," that were performed by Duke Engineering and Services. The inspectors found that the ampacity derating methodology was consistent with the i

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p actices established in the National Electric Code (NEC) and Electric Power Research Iristitute (EPRI) standards. The calculations were well organized and generally well ruviewed and implemented by PEC The inspector found that the thermal characteristic of the inconel reinforced ' silicone f abric used to protect the insulating material from physical damage was not specifically 5 avaluated in the ampacity derating calculations performed under LE-0100, "Ampacity j Derating of Cables in Darmatt KM1 Enclosed Raceways." However, the PECO Project !

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Engineer adequately demonstrated that it was enveloped by the other design -

assumptions and the Darchem ampacity dorating tests.-

The inspectors also reviewed LG 97-03548, " Replacement of Thermo-Lag with Steel i Tray Covers." Although not well documented, the original ampacity derating for Thermo-Lag bounded the steel enclosed doratin Conclusion )

PECO provided good oversight of engineering calculations performed by contractor Safe shutdown cable ampacity calculations were well organized, and the methodology I was consistent with established industry practice E1.2 Enaineerina Oversiaht of Contractor Desianed and Installed Sorinkler Modifications Insoection Scooe (37550)

The inspector reviewed sprinkler modifications, interviewed PECO and contractor personnel, and walked down portions of a sprinkler modification to determine the adequacy of the engineering oversight of the vendor supplied engineering product Observations and Findinas As part of the Limerick Thermo-Lag Reduction Program, additional sprinklers were required to be added to the existing systems due to obstructions caused by raceway encapsulation, multiple layered cable trays or ventilation ductwork. This modification installed new intermediate branch lines with sprinklers, which connected to the existing preaction sprinkler systems. The preaction sprinkler system, along with the one hour fire rated barriers, ensure that one train necessary to achieve and maintain safe shutdown remains free of fire damag The inspector reviewed the assumptions and the methodology used by the vendor, Sargent and Lundy, for calculations 1999-00338,1999-00285 and 1999-00284 and found them to be orderly, reasonable and consistent with the guidance specified in National Fire Protection Association (NFPA) 1 The inspector walked down portions of the modifications and compared the design specifications to the as-built conditions. The inspector found that the design

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specifications and the as-built conditions were in agreement. The inspector found that PECO provided good oversight of the vendor design calculations and installatio Conclusion PECO provided good oversight of contractor activities involving sprinkler modification The reviewed spd.1kler modifications were well organized and the methodology was consistent with established industry practices. The calculations were appropriate to reflect the as-built system cond'tio E1.3 Enaineenng Review and Closeout of Contractor Desianed and Installed Datmatt KM1 Systems a. ' Inspection Scone (37550)

The inspector reviewed Modification P00736-1&2, interviewed PECO and contractor personnel, and walked down portions of the modifications to determine the adequacy of the engineering oversight of the vendor supplied engineering product Observations and Findinos This modification installed Darmatt KM1 material to protect safe shutdown cables in Junction boxes 1DJ036,2BJ012,1DJ037 and associated conduits 1DA104,1DA106, 1DC010,' 1DC011, 2BA104 and 2BC004. The inspector found that the design, installation and engineering dispos:tions were thorough and complet .

The inspector found that the dead load calculation found on LS-0202, sheet B3, did not i include the most limiting allowable weight for the seismic loading. The installation I specified in the calculation called for 4 layers of Darmatt KM1 at a weight of 12.6 pounds per square foot (psf). The inspector found that the manufacturer specified weight for this ;

configuration could be as much as 13.8 psf. PECO evaluated this discrepancy and found that it had a negligible effect on the design margin. Additionally, PECO reviewed i other modifications for the extent of the condition and found that they were satisfactor l The inspector found that PECO's extent of condition review was adequate and that ;

PECO provided good oversight of the vendors' design calculations, engineering l dispositions and installatio , Conclusion The Darmatt KM1 design, installation and engineering dispositions were thorough and complete and PECO provided good oversight of the vendors' activitie !

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. E1.4 Enaineerina Oversicht of Miscellaneous Contractor Desianed and Inste!!ad Enaineerina

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Modifications Insoection Scope (37550)

l-L The inspectors reviewed several Unit 2 modification packages including control room recorder replacements, RPS input changes for the main turbine retrofit and the main steam relief valve replacement. Additionally, the inspectors interviewed PECO and contractor personnel and walked down accessible portions of the modifications to

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determine the adequacy of the engineering oversight of the vendor supplied engineering products - Observations and Findinas The inspectors found that the development and the review of these modifications were !

professional and extensive. -.The inspectors interviewed the system engineers responsible for the main steam relief valve replacement and found that they were very knowledgeable about the modifications and the vendors' interaction. This effort required l extensive coordination by PECO between the valve vendor (Target Rock), and the testing facility (Wyle Labs).

The inspectors reviewed the seismic qualification report, No. 5166-RP-03 and the electromagnetic interference report No. S1273-RP-04 for the control room recorder replacements and found that PECO was competent at the integration and oversight of these vendors' activitie As part of the turbine retrofit project, MOD P00580, Siemens Power Ccrporation redesigned the high pressure turbine rotor and inner casing. This modification required relocating instrumentation used by the reactor protection system. The inspectors reviewed modification LG 98-01261 and the supporting General Electric design i

documentation, NEDC-318g7P-1, and found that PECO provided good oversight of the vendors' activitie Conclusion *

PECO provided appropriate oversight of the vendors' activities involving, control room l recorder replacements, reactor protection system instrument relocation during the main turbine retrofit and main steam relief valve replacemen E7 Quality Assurance in Engineering Activities i

E7,1 Quaisty Assurance inspechon of Vendor installed Darmatt KM1 Fire Bamer System l

Inspection Scope (37550)

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The inspector interviewed several Limerick quality assurance (QA) inspectors and l observed the inspection of a vendor installed Darmatt KM1 fire barrier system segment l

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to determine the adequacy of the quality assurance oversight of the vendor-installed

. produc b.' Observations and Findinos The QA inspectors were very knowledgeable about the Darmatt KM1 fire barrier system installation and inspection requirements. The inspector observed a QA inspector inspect segment 13B of fire barrier 4304 and determined that the individual was thorough and -

followed all of the applicable inspection criteria established in ECR No. LG 98-02171, i Rev. 3, Attachment A, "Darmatt Application Verification Checklist." The QA inspector identified one minor deficiency that was corrected by the vendor. The installation was again inspected and no additional deficiencies were noted, Conclusion The quality assurance inspectors were very knowledgeable about the Darmatt KM1 fire l barrier system installation and inspection requirements. The quality assurance inspectors provided good quality assurance oversight of the vendor installed produc IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Unit 2 Refuel Outaos R+1;cIc-sical Contmig Inspection Scope (83750)

A review was performed of radiological controls implemented for outage wor Information was gathered by a review of radiation exposure goals, selected initiatives to maintain radiation exposures as low as is reasonably achievable (ALARA), through discussions with cognizant personnel, through a review of radiological posting practices, and a review of high radiation area access controls, Observations and Findinos The initial exposure goal for maintaining radiation exposures as low as is reasonably ,

achievable (ALARA) was wet at 200 person-rem for the for the Unit 2 refueling outag '

Based on lower than expected dose rates, PECO lowered the target goal to 150 person-rem and was on track to meet that goal. Interviews with cognizant personnel and reviews of documentation determined that there was early involvement in planning for

- Jobs with elevated exposure estimates, high dose rates, and radiologically complex wor Examples of radiological controls and ALARA inidatives implemented for the outage included the following:

e installation of temporary lead and water shielding in the Unit 2 drywell to reduce general area and job specific dose rates;

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e Installation of a clean-out port in the Unit 2 Drywell equipment drain piping to allow for hot spot flushing; e.- - Placement and frequent change-out of removable " sticky pads" in high traffic areas to limit the potential spread of contamination; e Movement of the reactor moisture separator end dryer underwater to minimize personnel dose and the potential spread of contamination during reactor vessel disassembly; and e improvements in worker awareness through site wide publications, worker briefings, first line supervisor training, and plant posting Tours through the plant showed that radiological boundaries were well defined and clearly posted. Health physics technicians interviewed were knowledgeable of on-going and planned work and of required radiological controls. ALARA reviews wera thorough and health physics briefings were commensurate with the complexity of planned wor High radiation area access controls were appropriate and in conformance with aplicable requirements. Departmental personnel demonstrated a thorough knowledge of high radiation cor.irol .Q.pncbsions Radiological controls for Limerick Unit 2 fifth refueling outage were effcetively planned and implemented and focused on work activities with elevated exposure estimate R7 Quality Assurance in Radiological Protection and Chemistry Activities Inspection Scope (86750)

A review was performed of the use of self assessments and corrective action systems for the identification and resolution of radiological control deficiencies. Information was i gathered through selected reviews of quality control surveillances, the 1998 Radiation !

Protection Program Annual Self-Assessment, selected performance enhancement program (PEP) issues, and through discussions with cognizant personne Observations and Findinas i

A combination of self-assessments e.nd quality assurance audits were performed to meet the requirements for an annual review of radiation protection program content and implementation as required by 10CFR20.1101(c). The 1998 Radiation Protection Program Annual Self-Assessment provided a concise summary of program strengths,

. opportunities for improvement, weaknesses, and watch areas. Self-assessments were conducted on a monthly basis and the results were used to produce semi-annual 1

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Radiation Protection Integrated Reports that identified performance trends in individual program area j

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. Quality assurance surveillances were routinely performed and added value by providing a detailed review of selected program elements. For example, Quality Surveillance Report LSR-99-0009 included a review of personal contamination reports that led to the

, identification of weakness in procedural guidance and implementation with regard to documentation of calculated skin dose Deficiencies and opportunities for improvement were placed into'the performance enhancement process for evaluation and resolution. A selected review showed that appropriate evaluations were performed and that timely corrective and preventative actions were implemented to resolve identified deficiencie Conclusions Self assessments and corrective action programs were effectively used. PECO identified, evaluated, and resolved radiological control issues as evidenced by the conduct of multiple self-assessments and audits to satisfy the radiation protection program review requirement R8 Miscellaneous RP&C lasues R (Closed) IFl 98-03-02 " Electronic Dosimeters Not Commensurate with Radiological Conditions." This inspector follow-up item was opened after it was identified that electronic dosimetry alarm set-points were not commensurate with radiological conditions and were not established to optimize exposure control. A follow-up review showed that a technical analysis of RWP doses had been performed and electronic dosimeter alarm' set-points had been adjusted based on the analysis. This item is close R8.2 (Closed) IFl 98-03-03 " Advanced Radiation Worker (ARW) program." This inspector follow-up item was opened after it was identified that some ARWs could not readily demonstrate knowledge of contaminated arealitem limits. A follow-up review showed that continuing training for ARWs was expanded from four hours to eight hours; weekly quizzes were introduced to reinforce ARW knowledge and skills; and ARW monitoring cards were distributed to ARW supervisors and HP Technicians. Four ARWs randomly selected for interviews successfully demonstrated knowledge of contaminated arealitem limits. This item is close R8.3 (Closed) IFl 98-03-04 " Temporary Technician Qualifications." This inspector follow-up item was opened after it was identified that HP technicians from other utilities were not required to demonstrate competency in health physics fundamentals similar to contractor technicians. A follow-up review showed that the practice of waving health physics fundamentals training / proficiency testing was limited to technicians from accredited utility '

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training programs. This item is close !

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81 . Conduct of Security and Safeguarda Activities Inspection Scope (81700)

Determine whether the conduct of security and safeguards activities met PECO's commitments in the NRC-approved security plan (the Plan) and NRC regulatory requirements. Areas inspected included: Access Authorization program; alarm stations;

. communicatums; and protected area (PA) access control of personnel and packages, Observations and Findings Access Authorization Program. The Access Authorization (AA) program was reviewed

.to verify implementation was in accordance with applicable regulatory requirements and Plan commitments. The review included an evaluation of the effectiveness of the AA procedures, as implemented, and an examination of AA records for 15 individual Records reviewed included both persons who had been granted and had been denied

. access. The AA program, as implemented, provided assurance that persons granted

- unescorted access did not constitute an unreasonable risk to the health and safety of the public. Additionally, access denial records and applicable procedures were reviewed to

' verify that appropriate actions were taken when individuals were denied access or had their access terminate Alarm Stations. Operations of the Central Alarm Station (CAS) and the Secondary Alarm

. Station (SAS) were reviewed. Both alarm stations were determined to be equipped with

. appropriate alarms, surveillance and communications capabilities, interviews with the

alarm station operators found them knowledgeable of their duties and responsibilitie Observations and interviews also verified that the alarm stations were continuously manned, independent and diverse so that no single act could remove the plant's capability for detecting a threat and calling for assistance and the alarm stations did not contain any operational activities that could interfere with the execution of the detection,

- assessment and response function Communications. Document reviews and discussions with alarm station operators determined that the alarm stations were capable of maintaining continuous intercommunications, continuous communications with each security force member (SFM) on duty, and alarm station operators were testing communication capabilities with the local law enforcement agencies as committed to in the Pla Protected Area (PA) Access Control of Personnel and Hand-Carried Packaoes. On May 11 and 12,1999, during peak activity periods, personnel and package search 1 activities were observed at the personnel access portal. Positive controls were j determined to be in place to ensure only authonzed individuals were granted access to I the PA and that all personnel and hand-carried items entering the PA were properly searche ;

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18 Conclusions PECO was conducting security and safeguards activities in a manner that protected

-~ public health and safety in the areas of access authorization, alarm stations, communications, and protected area access control of personnel and packages. This portion of the program, as implemented, met the commitments and NRC requirement Status of Security Facilities and Equipment inspection Scope (81700)

Areas inspected were: PA assessment aids, PA detection sids, and personnel search equipment.- Observations and Findinas Assessment Aids. On May 12 and 13,1999, the effectiveness of the assessment aids was evaluated by observing the PA perimeter on closed circuit television (CCTV), in the CAS and the SAS, respectively. The evaluation of the assessment aids was accomplished by observing, on CCTV, an SFM performing a perimeter patrol. The assessment aids generally had good picture quality, view and zone overla Additionally, to ensure Plan commitments were satisfied, PECO had procedures in place requiring the implementation of compensatory measures in the event the alarm station operator was unable to properly assess the cause of an alar PA Detection Aids. On May 11 and 12,1999, while observing the assessment aids, testing was also observed of selected intrusion detection zones in the plant protected area. The appropriate alarm was generated in each zone for each test. Through observations and review of the testing documentation associated with the equipment repairs, it was verified that repairs were made in a timely manner and that the equipment

' was functional and effective, and met the commitments in the Pla Personnel and Packaoe Search Eauipment. On May 11,1999, both the routine use and the daily operational testing of PECO's personnel and package search equipment were observed. Personnel search equipment was being tested and maintained in accordance with PECO procedures and the Plan and personnel and packages were being properly searched prior to PA acces Observations and procedural reviews determined that the search equipment performed in accordance with PECO procedures and Plan commitment c, Conclusions PECO security facilities and equipment in the areas of protected area assessment aids, protected area detection aids, and personnel search equipment were determined to be i well maintained and were able to meet the commitments and NRC requirement i

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83' Security and Safeguards Procedures and Documentation i Inspection Scone (81700F

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Areas inspected were: implementing procedures and security event logs, Observations and Findinos Secunty and Proaram Procedures.- Review of selected security' program implementing procedures, associated with personnel search, vehicle search and equipment testing verified that the procedures were consistent with the Plan commitment Secunty Event Loos. The Security Event Logs for the previous twelve months were reviewed. Based on this review, and discussion with security management, it was determined that PECO appropriately analyzed, tracked, resolved and documented safeguards events.- Conclusions

- Security and safeguards procedures and documentation were being properly implemented. Event Logs were being properly maintained and effectively used to analyze, track, and resolve safeguards event ' Security and Safeguards Staff Knowledge and Performance a. - Insoection Scope (81700)

Area inspected was security staff requisite knowledg Observations and Findinos Secunty Force Reauisite Knowledae. A number of SFMs in the performance of their routine duties were observed.- These observations included alarm station operations, personnel and package searches, and exterior patrol alarm response. Additionally, SFMs were interviewed and based on the responses to questioning, it was determined that the SFMs were knowledgeable of their responsibilities and duties, and could effectively carry out their assignment ,

Response Capabilities. Review of documentation of contingency response drills and critiques disclosed that PECO is appropriately exercising this portion of the progra The review also disclosed that PECO is using lessons learned from the drills to modify and refine the response plan to improve its effectiveness. Implementation 9f the planned changes to the response plan is expected to be complete prior to the Operational sSafeguards Response Evaluation that will be conducted in September 199 .

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i c. Conclusions The SFMs adequately demonstrated that they had the requisite knowledge necessary to

[ effectively implement the duties and responsibilities associated with their positio SS Security and Safeguards Staff Training and Qualification a. Insoection Scope (81700j l

Areas inspected were security training and qualifications and training record ]

b. Observations and Findinas l Security Trainina and Qualifications. On May 11,1999, Training and Qualification (T&Q)

records of 6 SFMs were reviewed. The results of t' mview indicated that these 3 personnel were trained in accordance with the approved T&Q plan. In addition, on May {

12,1999, observation of a training evolution at the firing range was conducted. The j training was conducted in a very professional manner, with a strong emphasis on safety.

l Trainina Records. Through review of training records, it was determined that the records were properly maintained, accurate and reflected the current qualifications of the SFM c. Conclusions Secur;ty force personnel were being trained in accordance with the requirements of the T&Q Plan. Training documentation was properly maintained and accurate and the training provided by the training staff was effectiv S6 Security Organization and Administration a. Inspection Scope (81700)

Areas inspected were management support and staffing levels.

b. Observations and Findinas Manaaement Support. Review of program implementation since the last program l Inspection disclosed that adequate support and resources continued to be available to ensure effective program implementatio Staffina Levels. The total number of trained SFMs immediately available on shift met the requirements specified in the Plan and implementing procedures.

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Areas inspected were: audits, problem analyses, corrective actions and effectiveness of management controls, Observations and Findinos Audits Surveillances conducted as part of the 1999 Quality Assurance (QA) Security Program Audit were reviewed. Review of the audit checklists and the surveillances that had been conducted as part of the security audit and review of the annual Fitness-for-duty (FFD) audit disclosed that the audits were comprehensive in scope and dept Problem Analyses. A review of data derived from the security department's self-assessment program indicated that potential weaknesses were being property identified, tracked, and trende Corrective Actions. Review of corrective actions implemented by PECO, in response to the QA audits and self-assessment program, disclosed that all corrective actions had been implemented and were effectiv Effectiveness of Manaaement Controls. PECO had programs in place for identifying, analyzing and resolving problems. They include the performance of annual QA audits, a departmental self-assessment program and the use of industry data, such as violations of regulatory requirements identified by the NRC at other facilities, as a criterion for self-assessmen Conclusions The review of PECO's Security and Safeguards audit program indicated that the audits were comprehensive in scope and depth, that findings were reported to the appropriate level of management, and that the program was being properly administered. In addition, a review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and resolve potential weakness.

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V. Management Meetings X1 Exit Meeting Summary The inspectors presented the resident inspection results to members of the PECO management at the conclusion of the inspection on June 2,1999. PECO acknowledged the findings presented. The inspectors asked whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie The inspectors met with PECO representatives at the conclusion of the radiological program and inservice inspections on May 7,1999, and the security inspection on May 14,1999, and the contractor oversight inspection on May 21,1999. The purpose and scope of the inspections were reviewed, and the preliminary findings were presente PECO acknowledged the preliminary inspection findings. No proprietary information was identified by PEC ,

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INSPECTION PRCCEDURES USED IP 37550: Engineering Inspection

'IP 37551: Onsite Engineering IP 61726: . Surveillance Observation IP 62707: ' Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP73753 _ Inservice inspection IP 81700: Physical Security Program for Power Reactors

. IP 83750 Occupational Radiation Exposure IP 90712: In-office Review of Written Reports IP 90713: Review of Periodic and Special Reports IP 92904: Followup - Plant Support IP g3702: Prompt Onsite Response to Events at Operating Power Reactors PARTIAL LIST OF PERSONS CONTACTED Licensee (in alohabetical order)

T. Anderson, NDE Specialist, Level lli R. Bixler, Corporate Security investigator R. W. Boyce, PECON NQA M. Brisan, Nuclear Quality Assurance K. Concannon, Access Authorization Supervisor F. A. Cook, Senior Manager, Design Engineering M. Gallagher, Plant Manager J. Grimes, Director, Site Engineering C. Heimbach, Security Analyst T. Hinkle, Engineer, inservice inspection H. McNally, Security Manager B. ' Oliver, Engineer, Nuclear Maintenance Division D. Schmidt, Engineer, Site Engineering

- R. Smith, Engineer, Nuclear Quality Assurance J. Smugeresky, Outage Director T. Tonkinson, Engineer, Experience Assessment J. Von Suskill, Vice President, LGS Site B. Whitman, Security Analyst NRC On alohabetical order)

A. Burritt, Senior Resident inspector P. Bonnett, Resident inspector C. Cahill, Reactor Engineer A. Lohmeier, Senior Reactor Engineer G. Smith, Senior Security Specialist

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-352;353/98-03-02 IFl Electronic Dosimeters Not Commensurate with Radiological Conditions. (Section R8.1)

50-352;353/98-03-03 IFl Advanced Radiation Worker (ARW) program (Section R8.2)

50-352;353/98-03-04 IFl Temporary Technician Qualifications (Section R8.3)

50-353/2-99-002 LER Various ESF actuations due to the loss of power to the 2A RPS/UPS distribution panel caused by a loose bus bar connection in the RPS breaker pane (Section M8.1)

Discussed None

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LIST OF ACRONYMS USED

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AA 1 Access Authorization ADHR- Alternate Decay Heat Removal ALARA As Low As is Reasonably Achievable

'ARW ~ Advanced Radiation Worker

.ASME ' American Society of Mechanical Engineers B&PVC Boiler and Pressure Vessel Code-CAS Central Alarm Station .

CCT Closed Circuit Television CFR Code of Federal Regulations -

EPRI Electric f ower Research System-

-ESF Engineered Safety Feature FFD Fitness-for-duty FW Feedwater q GE > General Electric i GL = Generic Letter HP Health Physics HPCI High Pressure Coolant injection IFl Inspection Follow-up item IR Inspection Report ISI inservice Inspection LEFM Linear Elastic Fracture Mechanics LER Licensee Event Report LGS Limerick Generating Station MT Magnetic Particle Test NDE Nondestructive Examination NEC National Electric Code j NFPA National Fire Protection Association NQA Nuclear Quality Assurance NRB - Nuclear Review Board NRC Nuclear Regulatory Commission ]

PA Protected Area l PECO FECO Energy  ;

PEP Performance Enhancement Process l

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PLC - Programmable Logic Controller QA Quality Assurance QAl Quality Assurance Inspector RCIC ' Reactor Core Isolation Cooling RHR Residual Heat Removal RP&C Radiological Protection and Chemistry

RPS Reactor Protection System RPV Reactor Pressure Vessel RT Routine Test -

RWP Radiation Work Permit SAS Secondary Alarm System SFM Security Force Member

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26-SFP- Spent Fuel Pool -

- ST Surveillance Test T&Q Training and Qualification the Plan NRC-approved Physical Security Plan TS Technical Specification UFSAR Updated Final Safety Analysis Report UT Ultrasonic Test VT VisualTest

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