IR 05000352/1999005

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Insp Repts 50-352/99-05 & 50-353/99-05 on 990713-0816.One Violation Noted & Being Treated as Ncv.Major Areas Inspected:Operations,Maint,Engineering & Plant Support
ML20216F817
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 09/16/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216F785 List:
References
50-352-99-05, 50-353-99-05, NUDOCS 9909240123
Download: ML20216F817 (16)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No License No NPF-39 NPF-85 Report No Licensee: PECO Energy Correspondence Control Desk P.O. Box 195 Wayne, PA 19087-0195 Facilities: Limerick Generating Station, Units 1 and 2 Location: Wayne, PA 19087-0195 Dates: July 13,1999 through August 16,1999 Inspectors: A. L. Burritt, Senior Resident inspector F. P. Bonnett, Resident inspector C. E. Sisco, Operations Engineer, DRS N. T. McNamara, Emergency Preparedness Specialist, DRS L. M. James, Reactor Engineer, DRS C, R. Welch, Reactor Engineer, DRS  ;

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

l 9909240123 990916 PDR ADOCK 05000352 G PM

EXECUTIVE SUMMARY Limerick Generating Station, Units 1 & 2 NRC Inspection Report 50-352/99-05,50-353/99-05

- This integrated inspection included aspects of PECO Energy operations, engineering, maintenance, and plant support. The report covers a five-week period of resident inspection and region-based inspection in the maintenance and emergency preparedness area Operations

  • The operations staff responded well to several challenges caused by extended high environmental temperatures and to an inadvertent single control rod automatically inserting into the core. (Section 04.1)

(ADS) was inoperable longer that the ADS technical specification allowed outage time i during maintenance activities which isolated the backup nitrogen supply. This Severity IV violation is being treated as a Non-Cited Violation (NCV 50-352,353/99-05-01),

consistent with Appendix C of the NRC Enforcement Policy. This violation is in PECO's corrective action program as PEP 10009911. (Section O8.1)

  • The inspectors determined that PECO identified that maintenance activities on the

' backup nitrogen supply to the automatic depressurization system rendered the ADS system inoperable because an on-shift operating crew had a good questioning attitude and engineering performed a thorough investigation. (Section 08.1)

Maintenance

  • The quality of maintenance activities observed was appropriate. Maintenance technicians conducted thorough pre-job briefings and coordinated activities with operators prior to beginning work. Maintenance staff was appropriately trained and j knowledgeable of assigned tasks. Procedures and work orders were used appropriately i and supervisory oversight of field activities was noted. (Section M1.1)

Plant Suooort

  • - The PECO corporate and Limerick emergency preparedness staff improved their process for tracking and trending corrective actions. They consistently identified issues or deficiencies, properly tracked concerns, and closed corrective actions in a timely manner The emergency preparedness self-assessment program has improved since the previous Limerick inspection and improvements to the program are continuing to be made. (Section P1)

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  • Equipment inventories, communication tests, and siren tests were performed in accordance with PECO's Emergency Response Plan. Improvements were made in the maintenance of offsite sirens, meeting the requirements of PECO's Emergency Response Plan and the guidelines of the implementing procedures. (Section P2)
  • PECO conducted emergency response training and drills as required. The inspector concluded that training for the Emergency Response Organization was effectively implemented. Shift operators successfully demonstrated the ability to properly classify emergency events using the new emergency action level scheme that was recently approved by the NRC. All required medical, radiation monitoring and fire drills were conducted in accordance with the Emergency Response Plan. (Section PS)
  • PECO has completed upgrading its emergency response equipment and is Year 2000 (Y2K) compliant. (Section P8.1)

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TABLE OF CONTENTS EXEC UTIVE SU M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TAB LE OF C ON TE NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Operation s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Com ments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 04 Operations Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 j 04.1 Operator Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 08- Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . ........2 l 08.1 (Closed) LER 1 -99-004 . . . . . . . . . . . . . . . . . . . . . . . . . . .........2 I I . M aintena nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1 M1.1 General Comments on Maintenance Activities . . . . . . . . . . . . . . . . . . . 2 M1.2 General Comments on Surveillance Activities . . . . . . . . . . . . . . . . . . . 4 M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . 4 M3.1 Surveillance Testing Events . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1 M8 Miscellaneous Maintenance lssues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M8.1 (Closed) Violation 50-352/353-98-06-01 . . . . . . . . . . . . . . . . . . . . . . . . 5 M8.2 (Closed) LER 1-99-007 .......................... .......... 5 M8.3 (Closed) LER 1 -99-008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M8.4 (Closed) LER 2-99-005 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Ill . E ngineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 E (Closed) LER 2-99-004 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 IV. Plant S u pport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 P1 Conduct of Emergency Preparednese (EP) Activities . . . . . . . . . . . . . . . . . . . . 6 P2 Status of EP Equipment, Instrumentation and Supplies . . . . . . . . ......... 7 P5- Staff Training and Qualification in EP . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . 8 P6 EP Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 P'7 Quality Assurance (QA) in EP Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 P8 Miscellaneous EP Issues . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . 10 P Year 2000 (Y2K) initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 X1 Exit Meeting Summary . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

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LI ST OF ACRONYM S U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 iv

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Report Details Summary of Plant Status Unit 1 and Unit 2 began this inspection period operating at 100%. Both units remained at full power throughout the inspection period with exceptions for testing and rod pattern adjustment l. Operations 01 Conduct of Operations'

01.1 General Comments (71707) 1 PECO Energy (PECO) conducted at power activities at Limerick Units 1 and 2 safely, including several high electrical demand periods during extended hot weather condition 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 I shift turnovers were comprehensive. Operators effectively controlled work activities using conservative decision makin .I 04 Operations Knowledge and Performance 04.1 Ooerator Challenaes (71707) Inspection Scooe The inspector reviewed the response to several events that challenged the control room operators. These events were the result of high plant area temperatures and a failed component during testin Observations and Findinas As a result of hot weather conditions, several plant area temperatures were elevate These high area temperatures repeatedly challenged plant equipment and resulted in operators making several entries into the station's emergency procedures, in addition, the operator's heightened awareness to temperature related problems contributed to early identification and prompt resolution of an increasing trend in drywell temperatur The operators appropriately responded to these condition On August 3,1999, Unit 2 operators responded appropriately to an unplanned single control rod insertion. When the operator inserted a manual half-scram as directed by procedure ST-6-071-307-2, "B Reactor Protection System (RPS) Manual Sc am Functional Test," a failed fuse in the redundant RPS trip system resulted in control rod ,

42-19 automatically inserting into the reacto Topical headings such as o1, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic )

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2 Conclusions The operations staff responded well to several challenges caused by extended hot weather conditions and to an inadvertent single control rod automatically inserting into the cor Miscellaneous Operations issues (90712)

0 (Closed) LER 1-99-004: Automatic Depressurization System (ADS) Inoperable During Planned Maintenance. PECO identified that on three occasions, technicians isolated a portion of the backup nitrogen supply to the ADS valves for planned maintenance and rendered the ADS valves inoperable. The backup nitrogen supply provides adequate motive force to maintain the ADS valves open for alternate shutdown cooling following an accident. During maintenance on June 6,1999, PECO restored the ADS valves to an operable condition prior to the end of the technical specification allowed outage time. On the two earlier occasions, PECO did not restore the ADS valves to an operable condition before the allowed outage time had been exceeded. As a corrective action, PECO rescheduled all preventive maintenance for the backup nitrogen supply to be performed during refueling outages when the ADS valves were not required to be operable. The inspector performed an "in-field" review of this issue and determined that a violation of technical specifications had previously occurred. This Severity IV violation is being treated as a Non-Cited Violation (NCV 50-352,353/99-05-01), consistent with Appendix C of the NRC Enforcement Policy. This violation is in PECO's corrective action program as PEP 1000991 The inspectors determined that PECO identified this issue because an on-shift operating crew had a good questioning attitude and engineering performed a thorough investigation. The inspectors noted that it was not obvious that isolation of a portion of the backup nitrogen supply rendered the ADS valves inoperable per technical specifications. It was after operations personnel questioned some anomalous I

indications during maintenance performed on June 6,1999, and engineering did an investigation, that PECO determined the backup nitrogen supply was required for operablity of the ADS valves. PECO identified the two earlier occurrences as part of their engineering investigatio II. Maintenance  !

M1 Conduct of Maintenance M1.1 General Comments on Maintenance Activities (62707) Inspection Scope The inspectors observed selected maintenance activities to determine whether approved j procedures were in use, technical specifications were satisfied, maintenance was j performed by knowledgeable personnel, and post-maintenance testing was appropriately !

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l The inspectors observed portions of the following work activities:

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l e Unit 1, D12 Emergency Diesel Generator (EDG) 18-month Overhaul- July 13 -

19; l e Unit 1, D11 EDG 18-month Overhaul- August 2 - 6; I

e Unit 1, Hydraulic Control Unit 18-47 leak repair - August 3; l

! e Unit 2, TRT 99-486 - Troubleshooting of buzzing turbine control valve relay in the reactor protection system - August 10; i- e Unit 1, TRT 99-490 - Troubleshooting Generator Field Ground in the D11 EDG - i l August 13-1 j l l

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The inspectors also performed an in-depth review of several preplanned maintenance activities and emergent activities performed by the Fix-It-Now (FIN) *.eam. The maintenance activities involved the bailey positioner on the B recirculation motor generator, Agastat relays on the reactor core isolation coolng system, D12 jacket water standby pump, standby liquid control pump C Relief Valve, and a fire door. The '

inspectors assessed the overall quality of the maintenance activity. The inspector l observed pre-job briefings for thoroughness, maintenance personnel for procedural

! adherence, and management oversight of field activities b. Observations and Findinas The inspectors found the work permits, equipment tagouts, and procedures to be

! adequate to perform the planned task and noted good procedural adherence during the activities. Required personnel, including health physics, quality assurance, and operations, appropriately participated in the maintenance activities. Peer checking and verification was evident on each maintenance activity observe The inspector observed that maintenance technicians carefully reviewed work plan For example:

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maintenance technicians identified minor errors in the work order and corrected the work order prior to beginning maintenance activitie e in preparation for implementing two work orders to replace Agastat relays and perform post-maintenance testing for the replaced relays, the team of maintenance technicians developed a work sequence to integrate the work activitie The FIN team was a multi-disciplinary team whose activities include preplanned, short duration work activities (minor maintenance) and emergent work activities. The inspector found FIN team activities appropriately implemented. Procedures were observed to be used at the work area. The inspector verified that the FIN team utilized the same procedures and processes that were in place for " normal" maintenance activities. The inspector concluded the FIN team was successful in the resolution of emergent plant issue i

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' Conct 4qn_s The quality of maintenance activities observed was appropriate. Maintenance technicians conducted thorough pre-job briefings and coordinated activities with operators prior to beginning work. Maintenance staff was appropriately trained and knowledgeable of assigned tasks. Procedures and work orders were used appropriatel Supervisory oversight of field activities was noted.

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 j specifications were satisfied, testing was performed by knowledgeable personnel, and test results either satisfied the acceptance criteria or were properly dispositione l i

The inspectors observed portions of the following surveillance activitieu e ST-6-092-318-1, D14 Diesel Generator Fast Start Operability Run - July 27;

  • ST-6-092-313-2, D23 Diesel Generator Slow Start Operability Run - August 10;
  • ST-2-092-323-2,4kV Emergency D23 Bus Under-voltage Check - August 1 The 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 good.

M3 Maintenance Procedures and Documentation M3.1 Surveillance Testino Events (61726) Insoection Scope l

The inspector reviewed two events that occurred during surveillance testing. The events l included an inadvertent start of the 2A residual heat removal (RHR) pump and of the 'C' l emergency service water (ESW) pum !

l Observations and Findinos i I

On July 28,1999, an inadvertent start of the 2A RHR pump occurred during the performance of l&C test ST-2-088-321-2, " Remote Shutdown System RHR Operability Test." PECO determined that the inadvertent pump start occurred due to lack of procedural detail in the surveillance test procedure. The procedure permitted manipulation of the remote shutdown panel emergency transfer switch without removing

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the installed test equipment. Technicians left the test equipment in place while l attempting to clear a high resistence condition across electrical contacts of the I emergency transfer switch. The test equipment createdan unintended electrical path I resulting in energizing the pump start relay when the transfer switch was returned to the normal positio On June 17,1999, an l&C technician caused an inadvertent start of the 'C' ESW pump when connecting test equipment at the D23 emergency diesel generator (EDG). A signal generator, used to calibrate speed detection instrumentation, was not removed after calibrating the test equipment. This introduced a simulated speed signal into the EDG control circuits completing the ESW pump start logic. PECO determined that personnel error and lack of procedural detail were the causes of this event. The inspector determined that this event did not adversely impact the ability of the EDG to perform its safety function and was not a violation of NRC requirement The inspector determined that although these two events were minor, they are similar to three events, involving lack of procedural detail, reported in NRC Integrated Inspection Report 50-352,353/99-0 Conclusions Two inadvertent starts of emergency core cooling system pumps were caused by a procedure deficiencie M8 Miscellaneous Maintenance issues (92902)

M8.1 {f&ged) Violation 50-352/353-98-06-01: Performance Monitorina Criteria The inspector reviewed PECO's corrective actions contained in their letter of September 18,1998, expert panel meeting minutes, and revised maintenance rule scope and performance monitoring documents. Based on this review, the inspector determined that acceptable performance monitoring criteria were established for the safety relief valves I and the fuel pool cooling and clean-up systems. PECO revised an additional 23 plant systems performance monitoring criteria as a part of their corrective actions. The inspector determined that PECO actions were acceptable. This violation is close M8.2 (Closed) LER 1-99-007: Inadvertent Emergency Service Water Pump Start During Test Equipment installation. This issue was discussed in Section M3.1 of this report. This LER is close M8.3 (Closed) LER 1-99-008: Unit 1 High Pressure Coolant Injection (HPCI) System Failed to Start During Performance of a Surveillance Test on June 23,1999. This issue was discussed in Section M1.3 of NRC Inspection Report 50-352,353/99-04. This LER is close l M8.4 (Closed) LER 2-99-005: Primary Containment isolation Valve (PCIV) Isolation, ESF Actuation due to a Failed Fuse. A fuse failure resulted in a several PCIV closures. The inspector's in-office review determined that this event was not a violation of NRC l requirements. This LER is close I I

lit. Engineering )

E8 Miscellaneous Engineering issues (92902)  ;

l E (Closed) LER 2-99-004: Thirteen Main Steam Safety Relief Valves (SRVs) Failed to j Meet the 1% Setpoint Tolerance due to Setpoint Drift. The inspector performed an "in- l office" review of this LER which documents the 'as found'setpoint testing results for all fourteen two stage SRVs removed during the 1999 Unit 2 refueling outage. The setpoint drift issue has been a recurring problem with two-stage SRVs and was the subject of a !

non-cited violation in NRC inspection Report 50-352, 353/98-05. As part of the '

corrective actions for that violation, PECO replaced all two-staged valves with three-staged SRVs during the 1999 refueling outage at Unit 2. Since replacement of the valves during the 1999 refushg outage was planned corrective action for the previous violation, no additional action is warranted. This LER is close IV. Plant Support

P1 Conduct of Emergency Preparedness (EP) Activities Effectiveness of PECO's Controls in Identifyina. Resolvina and Preventina Problems ,

Related to Emeraency Precaredness Insoection Scope (82701)

I The inspector reviewed PECO's corrective action systems, trending reports, and self-assessments to evaluate the effectiveness of PECO's controls in identifying, resolving and preventing problems related to emergency preparedness. The evaluation included a review of action items generated as a result of the 1998 and 1999 emergency drills, exercise critiques, self-assessments and audit finding Observations and Findinas The EP staff utilized two corrective action systems whicli were common corrective action databases for both Limerick and Peach Bottom: (1) the Performance Enhancement Process (PEP); and (2) the Action Request (AR) process. Since the previous NRC Limerick EP inspection, the inspector noted significant changes were made in both the use of the corrective action systems and how findings were characterized and correcte The inspector reviewed several open PEPS and ARs and determined that better utilization of the corrective action systems resulted in a better process for identifying,

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recording and correcting EP findings in a timely manner with appropriate management oversight. Six closed PEPS and ARs were reviewed and the inspector determined the corrective actions were adequat !

In 1999, PECO implemented a trending program to identify repeat issues and assess j any adverse trends. In addition, the EP staff developed an internal database for tracking j program recommendaticns that enhanced the emergency response progra !

l The EP self assessment process improved in 1999 in that specific critena were j established, expectations of the program were described, and the assessments were more intemally oriented. Based on PECO findings, they have an open PEP to improve, revise, and implement a satisfactory self assessment process. PECO reassessed their self assessment process and developed a report format which described the results and conclusions of their assessments. Additionally, related procedures are being updated to l reflect the changes in the self assessment prograns 4 c. Conclusions The PECO corporate and Limerick emergency preparedness staff improved their process for tracking and trending corrective actions. They consistently identified issues or deficiencies, properly tracked concerns, and closed corrective actions in a timely manner. The emergency preparedness self-assessment program has improved since the previous Limerick inspection and improvements to the program are continuing to be mad P2 Status of EP Equipment, instrumentation and Supplies a. Insoection Scooe (82701)

The inspector reviewed 1998 and 1999 emergency facility equipment surveillance test records, facility inventories and communication test records for regulatory complianc Also, a monthly siren test was observed and siren surveillance test records were reviewed for completeness and accuracy, b. Observations and Findinas Emergency facility inventory records were complete and well organized. Inventories were conducted in accordance with the Emergency Response Plan (ERP). Monthly communication tests were performed in which the Emergency Response Organization (ERO) electronic pagers were tested for functionality and for determining mobilization accountabilit During a previous inspection (50-352;353/98-08), the inspector noted repetitive month to month offsite siren failures and that these repairs were not re-tested until the next month's test. During this inspection, the inspector noted improvements in the maintenance of offsite sirens, some of which included: (1) new repair contractor was hired in May 1999; (2) maintenance procedures were being developed; (3) trending

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records were established; and (4) failed sirens were immediately investigated, repaired and retested in a timely manner. The insp3ctor reviewed the monthly records for 1999 and found that 95% of all sirens tested were found to be operable and there were no adverse trends in repeat siren failure gn

.Q_o_n_clqions Egip eut inventories, communication tests, and siren tests were performed in accordance with PECO's Emergency Response Plan. Improvements were made in the maintenance of offsite sirens, meeting the requirements of PECO's Emergency Response Plan and the guidelines of the implementiag procedure P5 Staff Training and Qualification in EP a. Insoection Scooe (82701)

The inspector reviewed EP training records, training procedures, and the ERP's training requirements to evaluate PECO's ERO training progra b. Observations and Findinas The inspector determined through a review of training lesson plans and record reviews that the required EP training was being conducted in accordance with the ERP and applicable training procedures. The inspector selected a number of training records for individuals in the ERO and found their individual qualifications were curren The 14UMARC Emergency Action Level ( EAL) scheme was recently adopted by PECO-Energy and was approved by the NRC in May 1999. The EALs are used for classifying emergency events. The inspector observed a shift operator training drill in which the NUMARO EALs were used and noted the operators were able to swiftly and accurately make the emergency declarations with little assistance from the EP staf The inspector verified that the required medical, radiation monitoring, and fire drills were being conducted as require c. Conclusions PECO conducted emergency response training and drills as required. The inspector concluded that training for the Emergency Response Organization was effectively implemented. Shift operators successfully demonstrated the ability to properly classify <

emergency events using the new emergency action level scheme that was recently approved by the NRC. All required medical, radiation monitoring and fire drills were conducted in accordance with the Emergency Response Pla .

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a. Insoection Scope (82701)

l The inspector reviewed EP group staffing and organization to determine if consolidation of the PECO corporate office, Limerick, and Peach Bottom EP programs adversely affected the EP progra b. Observations and Findinas in March 1999, PECO consolidated their corporate office, Limerick, and Peach Bottom ,

EP programs for commonality. Based on record and procedure reviews and discussions with individual staff members, the inspector concluded that the consolidation did not ;

adversely affect the overall management of the program. Changes to the program and ;

staff reorganization are expected to be completed by December 199 ]

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Consolidation of the PECO corporate office, Limerick, and Peach Bottom emergency preparedness programs did not adversely affect the emergency preparedness progra P7 Quality Assurance (QA)in EP Activities a. Insoection Scooe (82701)

The inspector reviewed Audit Report No. LAR-98-014, of the Limerick / Peach Bottom / Corporate EP Program, conducted in 1998. The inspector also reviewed the !

audit plans and checklists, and interviewed personnel from Nuclear Quality Assurance (NOA) regarding the process for conducting a program audi ,

b. Observations and Findinas Recently, NQA revised their audit process to conduct the audit throughout the year and generate audit reports on a quarterly basis to document the observations and finding The inspector noted that audit report No. LAR-98-014 contained strengths, weaknesses, l recommendations, and the report clearly demonstrated the bases for the audit

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conclusions. This was an improvement from the previous Limerick EP inspection. The i inspector determined that the audit report had met the requirements specified in 10 CFR 50.54(t).

The inspector verified that offsite officials were sent copies of the audit report section pertaining to PECO's interface with offsite agencies, and that the reports were distributed to the appropriate PECO managemen l

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10 Conclusions The inspector noted significant improvements in the PECO audit process since the previous Limerick emergency preparedness inspection. The 1998 audit report of the PECO emergency preparedness program met the requirements specified in 10 CFR 50.54(t).

P8 Miscellaneous EP lasues P8.1 y_ par 2000 (Y2K) Initiatives Inspection Scope The inspector reviewed documentation for determining if the EP program equipment was Y2K complian Observations and Findinas The inspector discussed the Y2K initiatives with the EP Manager and determined through record reviews that the pager and siren system and associated computers used for emergency response were upgraded, as needed, and were now Y2K complian Conclusions PECO has completed upgrading its emergency response equipment and is Year 2000 (Y2K) complian 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 September 8,1999. 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 A routine safety inspection of the emergency preparedness program was conducted by N. McNarnara during the period of July 26-August 4,1999. An exit was conducted on August 4,1999 to discuss the findings of the inspectio i l

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities i

IP 82701: ' Operational Status of the Emergency Preparedness Program l lP 90712: In-office Review of Written Reports IP 90713: Review of Periodic and Special Reports ]

l IP 92902 ' ' Followup - Maintenance  !

ITEMS OPENED, CLOSED, AND DISCUSSED Opened / Closed NCV 50-352, 353/99-05-01 Automatic Depressurization System (ADS) Inoperable During Planned Maintenance. (Section 08.1) l

' Closed VIO 50-352/353-98-06-01 Performance Monitoring Criteria (Section M8.1) '

I LER 50-352/1-99-004 Automatic depressurization system (ADS) inoperable dunng J planned maintenance without meeting the applicable Technical q

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Specification action. (Section 08.1) l LER 50-352/1-99-007 Inadvertent emergency service water pump start during test equipment installation. (Section M8.2)

.LER 50-352/1-99-008 Unit 1 HPCI system failed to start during performance of a surveillance test. (Section M8.3)

LER 50-353/2-99-004 Thirteen main steam SRVs failed to meet the 1% setpoint tolerance due to setpoint drift. (Section E8.1)

LER 50-353/2-99-005 Primary Containment Isolation Valve Isolation, ESF Actuation due to a Failed Fuse. (Gection M8.4)

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LIST OF ACRONYMS USED ADS Automatic Depressurization System AR Action Request CFR Code of Federal Regulations

.DVM Digital Voltage Meter EAL Emergency Action Levels EDG Emergency Diesel Generator f

EP Emergency Preparedness

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ERO Emergency Response Organization ERP Emergency Response Procedure ,

ESF Engineered Safety Feature ,

ESW Emergency Service Water HPCI High Pressure Coolant injection LCO Limiting Condit )n For Operation LER Licensee Event Report I LGS Limerick Generating Station MCR Main Control Room NCV Non-Cited Violation NMD Nuclear Maintenance Division NRC Nuclear Regulatory Commission PCIV Primary Containment isolation Valve PECO PECO Energy PEP Performance Enhancement Process PJM Pennsylvania, New Jersey, and Maryland PORC Plant Operations Review Committee QA Quality Assurance RHR Residual Heat Removal RPS Reactor Protection System RSD Remote Shutdown RPV Reactor Pressure Vessel RT Routine Test j SAs Self-assessments l SER Safety Evaluation Report SRV Safety Relief Valves ST Surveillance Test T&Q Training and Qualification TRM Technical Requirements Manual TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation

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