IR 05000353/1989081
| ML20248G692 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/27/1989 |
| From: | Crescenzo F, Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248G662 | List: |
| References | |
| 50-353-89-81, NUDOCS 8910100341 | |
| Download: ML20248G692 (27) | |
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_; c U. S. NUCLEAR REGULATORY COMMISSION
REGION I
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' License: NPF-84 Docket: 50-353- Report: 50-353/89-81 n
Licensee: Philadelphia Electric Company 2301 Market Street Tih11adelphia, PA 19101
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Inspection At: Limerick Generating Station, Unit 2 Limerick, Pennsylvania
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Inspection Team: Frank Crescenzo, Senior Resident Inspector, Shoreham , \ ,e <
Paul Kaufman, Project Engineer, DRP '
Peter Drysdale, Reactor Engineer, DRS k Richard Urban, Resident Inspector, Peach Bottom-Prepared by:
F. Crescenzo, SRI, Shoreham '
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'Date Approved by: k OQw L1 ffi L. Doerfidin, Chie , Projects 'Date
.Section 2B Purpose: The inspection was conducted to assess the. readiness of the licensee to safely conduct power operations of the Limerick facility considering near term full power licensing of the Unit 2 reacto Conclusion: One apparent violation of NRC requirements was noted during inspection of. the licensee's surveillance prograrr. The licensee verbally committed to resolve the problem with improperly implemented procedure changes prior to critical operations of the Unix. 2 facility. The team otherwise found-the licensee's operational programs to be adequately prepared and implemented to safely operate both units through rated design condition j
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8910100341'890927 FDR O-ADOCK 05000333 PDC
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TABLE OF CONTENTS 1.0 Executive Summary 1.1 Purpose and Scope.................................. 2 1.2 Areas examined..................................... 2 Summary of Findings................................. 2 2.0 Operations Activities 2.1 Organization and. Staffing.......................... 2 2.2 Operating Procedures....,.......................... 5
- 2.3 Administrative Controls............................ 6 2.4 Control Room Observati ons . . . . . . . . . . . . . . . . . . . . . . . . . . 7 2.5 Quality Assurance of'0perations.................... 9 2.6 Facility Tours..................................... 10 2.7 Conclusions........................................ 10 3.0 Maintenance 3.1 - Maintenance Review Scope and Criteria. . . . . . . . . . . . . . . 11 3.2 Maintenance Organization and Staffing............,.. 11 3.3 Work Controls and Planning.......................... 11 3.4 Implementing Procedures............................. 12 3.5 Maintenance Work Observation........................ 13 3.6 Quality Assurance of Maintenance.................... 14 3.7 Conclusion.......................................... 15 40 Surveillance 4.1 Program 0verview.................................... 15
- 4.2 Compliance Tracking................................. 16 4.3
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Procedures.......................................... 17 4.4- Observation of Surve111ance......................... 18 4.5 Quality Assurance of Survei11ance.................... 20 4.6 Conclusions.......................................... 20
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5.0 Technical Support Scope............................................... 20 5.2 Onsite Plant Technical Group....................... 21 5.3 Nuclear Engineering Department Site Support........ 22 5.4 Plant Modification Group........................... 23 5.5 Quality Assurance of Technical Support............. 24 Conclusions........................................ 24 6.0 Management Meetings..................................... 25 l
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'2 1.0 EXECUTIVE SUMMARY
. P_urpose and Scope The inspection was conducted to determine the licensee's readiness to operate a dual reactor facility at Limerick
' Generating Statio Limerick Unit I was granted a full power operating license in August 1985, and is currently operating in its third fuel cycle. The licensee has safely operated Unit 1 substantially.in compliance'with NRC regulations. Limerick Unit 7 2 was granted a low power operating license on July 10, 1989.
E The operational programs in place for Unit I have been expanded or modified to include startup and operation of Unit Accordingly, the scope of this inspection was skewed towards those functional areas most itkely to be challenged by the burdens of an additional operating reactor unit. The scope was further focused to assess the overall readiness of the programs for. dual unit operation .2 -Areas Inspected
- The team reviewed the. functional areas of Operations, Maintenance, Surveillance and Technical Suppor .3 Summary of Results One violation was noted in the area of Surveillance. A broader concern relating to the adequacy of the Unit 2 Surveillance Procedures was identified as a result of this violation (see section 4.3). The licensee committed to resolving this issue prior to initial criticality of Unit Excepting resolution of this issue, the team concluded the licensee was adequately prepared for startup and operation of Unit 2. Certain concerns of minor safety significance were identified to licensee. These dealt with cumber-some administrative programs (section 2.3), licensed shift management (section 2.4), and prioritization of maintenance (section 3.4).
2.0 OPERATIONS ACTIVITIES 2.1 Organization and Staffing:
Operations department organization and staffing were assessed for readiness to operate Unit 2. No discrepancies were noted and these areas were determined to be adequat The commitments described in chapter 13 of the Final Safety Analysis Report (FSAR) and the requirements of Technical Specifications sections 6.2.1 and 6.2.2 were used as reference standards during the revie _ _ - . _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _ _ _ _ - _ _ _ _
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i The minimum' shift composition is described in Technical Specification Table 6.2.2-1. Operational conditions 1, 2, and 3 ;l
require two Senior Reactor Operators (SRO), two Reactor Operators
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(RO), two non-licensed operators and one Shift Technical Adviso I The inspector noted that shift complement requirements for operation of Unit 1 alone are nearly' identical to the requirements for simultaneous power operations of both unit Administrative procedure A-7, " Shift Operations," figure 4, describes the control room complement currently in place- at Limerick Generating Station. Actual shift complements require two additional licensed operators above minimum levels. required by Technical Specifications. These positions are the Duty Floor Supervisor and the Duty Chief Operato The Duty Floor Supervisor maintains an active Senior Reactor 0' Operator (SRO) license and is normally responsible for directing non-licensed activities of floor operators (non-licensed) outside the controls area. This person is also available to relieve or augment the Duty Control Supervisor (Shift Supervisor) in direction of licensed activities and typically spends a large -
percentage.of his shift in the control room. On-shift personnel qualified for these positions rotate on a weekly basis. In this manner, both SR0s maintain current knowledge of control room operations and activities. These positions (Floor Supervisor and Control Supervisor) are both supervised by the Shift Superintendent who also maintains an active SRO license and holds ultimate license responsibility for the shif The Duty Chief Operator maintains an active Reactor Operator (RO)
license. This person is normally responsible for operating control room panels common to both units and for assisting the Duty Control Supervisor in administrative functions. The Chief Operator will also provide temporary relief for the Unit Operators and under transient or accident scenarios is responsible for operation of the affected unit's Emergency Core Cooling System (ECCS) panels. The Unit Operators and Chief Operators are equally qualified and rotate through the three R0 positions on a weekly basi In this manner, on-shift R0's remain current in all three positions and in operation of both unit There -is an additional non-licensed Technical Assistant Operator (TAO) assigned to each shift. The TA0 is not described in either the Technical Specifications or Administrative Procedure A-7 but is described in the Operations Manual. This person is available to perform routine administrative functions of a technical nature and, under accident scenarios, is responsible for assisting the Shift Technical Advisor in dose assessment calculation _ _ _ _ - _ _ _ _ _ _ - _ - _ _ - _ _ _ - _ - _ _ _ - _ - _ _
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.: a b' 4 The current staffing levels comprise six shift complements fully staffed in accordance with procedure A-7 described above. This totals eighteen each Reactor and Senior Reactor Operator licenses
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assigned to. shift rotation. There are three additional SRO licenses assigned.to the operations department. Two of these assist the startup and power ascension-test program for Unit 2; the . third is assigned as the blocking permit coordinator on a six month rotational basis. -There are four additional R0 licenses of record; however, only one of.these is available for shift rotation. This person assists the blocking permit coordinator and is also on a six month rotational basis. -There are eighteen staff SR0 license The licensee is awaiting the results for six operator license candidates who were administered NRC examinations in June 198 The licensee is also planning to begin a new R0 class for 11 personnel and an SRO upgrade class for 2 personnel beginning in
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-September 198 ~The inspector noted the weekly average overtime for licensed operators was approximately 25% during June and July 1989. Administrative procedure A-40, " Procedure for Working Hour Restrictions," defines
" heavy" overtime as 25% and further cautions that heavy overtime should be avoided for safety related workers. This finding was
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discussed with the operations manager. It was explained that heavy overtime was required to complete the Unit 1 outage concurrent with startup preparations on Unit 2. The licensee does not anticipate routine use of heavy overtime in the future. The overtime goal for the coming year is 8% and there are no plans to conduct dual unit outages in the next several years. The inspector found this an acceptable explanation for the heavy overtim The inspector reviewed the operational experience of the staf Unit 1 is currently operating in its third fuel cycle. All licensed personnel and most non-licensed personnel currently on shift have significant experience operating Unit Most licensed personnel and all R0s on-shift participated in the startup program for Unit The licensed staff was responsible for control room operations during pre-operational (pre-op) testing of Unit Three of the six Shift Superintendents have significant experience on the Peach Bottom facility which is a dual unit Boiling Water Reactor operated by the license The inspector found the operations department organization consistent with FSAR commitment Staffing exceeds minimum levels required by Technical Specifications. Use of heavy overtime is expected to decline with operation of Unit 2. The operational experience of the staff is significant. The current staffing levels have successfully operated through 2 fuel cycles on Unit 1 ano have adequately integrated operation of Unit 2 during pre-op testing and fuel loa Organization and staffing of the operations departmer.t are adequate to support dual unit operation _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _
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5 2.2 Operating Procedures The inspector reviewed the control room operating procedures. .The review was focused on determining their adequacy to incorporate Unit 2, including design differences and human factors elements. No inadequacies were note Administrative procedures A-93, " Preparation of General Operating '
Procedures," A-20, " Preparation of System Operating Procedures,"
A-22, " Preparation of Operational Transient, Off Normal, Event and Special Event Procedures," and A-74, " Preparation of Transient Response Implementation Procedures (TRIP)," were used as reference standards during the revie The inspector noted good human factors design of the procedure layout A standard color coding system has been in place to distinguish the two units. This system requires procedures for Unit 1 and common systems to be printed on yellow paper. Unit 2 procedures are printed on green paper. White colored documents provide' instructions for both units. The color code is consistent throughout the_ facilit There are two complete sets of operating. procedures sufficient to operate both units'in the control-room. Many procedures are broken down into three distinct sections. A white colored procedure provides common operating instructions for systems identical to both unit The operator'is expected to mentally distinguish component designators between the units. This is an easy task since most component desig-nators are. identical except for a single' digit to indicate the uni The inspector noted that these procedures have been in place since licensing of Unit The white procedures are accompanied by two, unit specific, color coded appendices containing initial system alignments. These appendices are clearly labeled " Unit 1 (2) only",
and require the operator to sign or verify component status. Where systems vary between the units, the' operating procedures are completely unitized,. color coded, and have no common instruction There are very few such procedures as the two units are physically identical in nearly all respect The symptom based emergency operating procedures (TRIP) are completely unitized although they are essentially identica The inspector performed detailed reviews of selected procedure No inadequacies were noted. Unit design differences were properly incorporated. The common procedures appeared adequate in level of detail and clarity of instruction. The operators need only insert a
"1" or "2" into most component designator The inspector also discussed the adequacy of the operating procedures with certain members of the operating shifts. The operators were comfortable with the adequacy of the unit distinction process.
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6-i None could recall errors made due to unit confusion caused by procedural inadequac '
The inspector found the operating procedures adequate to support safe operation of both units. The procedures have always incorporated references to the dual unit facility. Unit I has been adequately operated using these procedures. The process for distinguishing units and for compensating the few physical differences appears adequat The operators are satisfied with the quality of the procedure .3 Administrative Controls The inspector reviewed administrative controls applicable to control room operations. The programs were found to be adequate; however, program descriptions were fragmented throughout several layers of station procedures and/or program description The specific programs reviewed included Shift Operations, Permits and Blocking, Temporary Circuit Alterations, Limiting Condition for Operation (LCO) tracking, Reporting Requirements, and Operations Verification Program. The inspector reviewed the applicable adminis-trative procedures, guidelines, program descriptions, and standing !
orders which described conduct of these programs. The inspector observed control room activities and interviewed shift operators on administrative activitie The inspector found the administrative programs adequately addressed both units. Generally, unit distinctions are not necessary as the administrative programs, by nature, are site specific rather than unit specific. Where distinctions are required, these are usually done via numbering designators rather than the color coding found in operating procedures. Examples of these are the blocking permits and operations verifications which are not color coded but have 01, 02 number designators. The licensee is evaluating changes to these programs to incorporate color coding. No inadequacies related to unit distinctions were noted by the inspector. The operators also expressed that the system was adequate and could not recall incidents where unit confusions had caused administrative error The inspector noted there were several administrative documents by which operations activities were conducted. These included the I Administrative Procedures, Administrative Guidelines, Policy State- '
! ments, Corporate Administrative Guidelines, Operations Department Manual, Standing Orders, Night Orders and Blocking Permit Manua The licensee maintains that the Administrative Procedures ("A" procedures) are the " Official" program descriptions. The inspector found, through discussion with operators, that activities were more likely conducted per other documents, primarily the Operations
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Department Manual. The inspector noted the' lower tier program descriptions, which are approved by the department manager, were consistent with the broader requirements of the "A" procedures. The i inspector also noted that operators were knowledgeable of the require-ments of "A" procedures as well as the lower tier descriptions. The inspector commented to the licensee that consideration should be given to consolidating the several descriptions into fewer working document No other inadequacies or concerns were noted. The administrative programs were found adequate for dual unit operation .4 Control Room Observations The inspector observed activities conducted in the control room. No inadequacies or violations were observed. It was noted that the day-shift Superintendent devoted considerable time to activities outside the control roo Procedures A-7, " Shift Operations," A-9, " Plant Communications," Unit Technical Specifications, and the Operations Department Manual were used as reference standards during the observations. Applicable system Operating, Alarm, and Surveillance procedures were referred to during observation of specific control room activitie Unit I remained at or near rated full power conditions throughout the-inspection. Unit 2 remained in cold shutdown. Activities on Unit 2 were focused on completion of Instrument and Controls (I&C) surveil-lances and system checkoff lists, in anticipation of unit startu The inspector monitored routine activities of the Shift Superintendents (SSupt.). The SSupt. maintains ultimate site authority and respon-
.sibility over licensed activities occurring on his shift. The SSup does not routinely direct licensed activities, but rather delegates this to the duty control supervisor (referred to as the Shift Supervisor). The SSupt., more often, is involved in overall site direction of shift activitie The Technical Specifications require the SSupt. to be on site, but not necessarily in the controls area. The inspector noted the dayshift SSupt. routinely attended meetings which occurred outside the control room. These included the oncoming shift brief, daily production planning meetings and various reactive planning meeting These meetings appeared to occupy approximately 30-40% of the dayshift SSupt.'s shift activitie The inspector found it appropriate for the SSupt. to attend the. shift brief meeting. The SSupt. presides over this meeting and is most qualified to address current plant conditions, license requirements, and to assess how these conditions might conflict with planned P
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8 activities for the next three shifts. The inspector found the other meetings may distract the SSupt's attention from licensed activities occurring in the control room. The additional meetings focused on longer term station activity planning. The SSupt. did not normally preside over these meetings, but provided operations department inpu Activities discussed were generally not applicable to licensed activities occurring in the immediate future (subsequent 1-2 shifts).
The inspector commented to station management that distraction of the SSupt's. attention to licensed activities should be minimize The licensee informed the inspector that a major reason for the additional activity was due to the added workload associated with Unit 2 startup and that this was not the normal routine. The inspector noted that the onshift SSupt. was adequately aware of plant conditions or shift activities at all times and that the utility shift SSupt would usually be present in the control room during absence of the on-shift SSupt. The inspector further found the SSupts. to be highly experienced and competent shift manager For these reasons the inspector did not consider this a finding of significant concer The inspector observed activities of the Shift Supervisor and Floor Superviso On one occasion, the Shift Supervisor appeared to be overburdene This was due to his having to manage minor operational problems with Unit I and also to complete administrative duties for Unit 2 work activities. The inspector noted the supervisor properly prioritized problem resolution consistent with Technical Specification The inspector noted that in addition to licensed responsibilities, the Shift Supervisor is burdened with large amounts of administrative functions. This was particularly true during the first three days of this inspection when the utility shift was offsite for trainin Normally, the utility shift performs many of the administrative functions of work controls and the on-shift supervisor is responsible for final work releas This observation was brought to the attention of station managemen The inspector commented that the Shift Supervisor, at times, appeared to present a bottleneck to planned station activities due to his workload. The inspector was told this was an isolated instance where workload had peaked and manpower was short. The inspector otherwise found the shift supervisor to be effective in safely directing shift activitie The inspector monitored routine activities of the Unit and Duty Chief Operators. No inadequacies were noted. The Unit Operators were found to be knowledgeable of plant conditions, equipment out of service, and planned shift activities. The operators were not overburdened with activities or otherwise distracted from license i
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duties. The inspector observed control manipulations of the Reactor Water Cleanup and Station Ventilation Systems. The inspector observed {
Unit Operator responses to off normal conditions following an unplanned J trip of the Unit 2 Group VI isolation logic and a Unit 1 annunciator for steam leak detection logic. The operators properly referenced procedures and prints to diagnose the problems. Good communications among control room operators was note Two periods of backshift operation were observed during the inspectio No inadequacies were noted. No instances of unprofessional or distracting activities were noted. The inspector noted control room activities during the backshift periods were significantly less hectic than dayshif The inspector concluded that the operating staff in the control room is ready for power operations of a dual unit facility. The staff demonstrated a professional and competent approach to operation Licensed operators were observed to comply with procedural and administrative requirements and appeared oriented to safety and license requirements. The licensee should consider improvements to reduce distractions of the SSupt. and the administrative burdens of the Shift Supervisor on dayshif .5 Quality Assurance of Operations The inspector reviewed programs for Quality Assurance monitoring of operr.tions activities. No inadequacies were note Quality Division monitoring guidelines PA-01, " Power Ascension Testing," HF-01, " Hot Functional Testing" and the audit plan for the Unit 2 startup test program were reviewed. A sample review of recent audit and surveillance findings was also completed. The inspector interviewed the site quality assurance manager, the technical monitoring supervisor and the audit group superviso The technical monitoring group is responsible for conducting surveillance of operations activitie Surveillance is not limited to control room activities, but includes monitoring of floor and other shift personnel (health physics, rad-chemistry). There are eight inspectors in the monitoring group. The inspector reviewed the training and qualifications of these inspectors and found them adequat One inspector holds a vendor SRO certification and three others have previous Navy nuclear experience. All have participated in Boiling Water Reactor systems training. The technical monitoring group is required to conduct 25% of inspection activities during backshif Around-the-clock QA coverage will be provided throughout the startup and power ascension program. The audit group has planned audits consistent with the PATP plateaus.
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l The inspector found the audit and surveillance reports adequat Findings were well documented, in clear and concise format Findings appeared to be substantive rather than compliance oriented
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or administrative.
L l -The inspector found the QA program adequate to assess operations.
l A qualified staff of inspectors and . auditors is available for shift
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monitoring. No~ discrepancies or inadequacies were note .6 Facility Tours 1 The inspector conducted tours through the Unit 2 facility. No l_
inadequacies were note Procedures A-12, " Ignition Source Control Procedure," and A-30,
" Plant Housekeeping" were used as references during the tours. The tours included .the service / circulating water structure, turbine building, -reactor enclosure, drywell, diesel building, and refueling floo The inspector found no discrepancies during the tours. Housekeeping was' adequate. No stray materials were found which were not clearly labeled as required for maintenance activities. Very few scaffolds were found and, of those still installed, all were properly labeled to indicate safety reviews had been conducted. The inspector noted labeling of Unit 2 to be excellent. All component labels contain descriptions as well as digital bar codes. The inspector closely examined a diesel generator and did not find any unlabeled compenents which might require manual operations. The inspector also noted that entrances to spaces are clearly labeled with descriptions and bar codes for the major components contained withi .7 Conclusions The inspector found the operations department well prepared to support safe dual unit operations. The staffing and organization exceed regulatory requirements. The operating staff has significant experience on Unit 1 and the Peach Bottom reactors. Adequate plans exist to compensate for licensed operator attrition over the next few years. Operations and administrative procedures in place for Unit 1 have been adequately upgraded to include dual unit operation. The operating str.ff appeared competent and sufficient to support dual unit operation Plans and resources for quality assurance monitoring of operations appear adequate. Facility housekeeping was adequate, i
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11 I 3.0 MAINTENANCE 3.1 Maintenance Review Scope and Criteria-Planning, control, and performance of maintenance activities were reviewed to determine readiness for operation of Limerick Unit Assessment in, this area was based on sampling of work in progress, staffing resources, Quality Assurance (QA) involvement, and interviews with maintenance personnel. The criteria used during the inspection were the Limerick. Unit 2 FSAR and 10 CFR 50, Appendix .2 Maintenance Organization and Staffing Limerick's maintenance _ organizational structure and chain-of-command is described in administrative procedures and depicted on organization charts. Position guidelines detail the responsibilities of each position and all positions are filled. Maintenance Division work includes activities performed.on both mechanical and electrical components. The Instrument and Control (I&C) Division performs work on I&C equipment. The Maintenance and I&C Divisions are under the Maintenance and I&C Superintendent. The superintendent is supported by the maintenance and I&C engineering groups contained within the respective divisio To assess the adequacy of maintenance staffing resources the inspector reviewed overtime information and the backlog of maintenance request forms (MRFs).
The yearly average overtime for maintenance in 1988 was approximately 15 percent. The total backlog of corrective maintenance MRFs as of August 1, 1989, was 279. A review of the higher prioritized MRFs was conducted to determine if any would impact power operation. No corrective maintenance MRFs were identified that would restrict power operatio Review of the licensee's maintenance organization concluded that manpower resources are adequate to support dual unit power operation .3 Work Controls and Planning Programmatic controls for maintenance activities on Limerick Unit 2 are the same for Unit 1. These are described in administrative procedure A-26, " Procedure for Plant Maintenance Using the Maintenance Request Form (MRF)," and the Computerized History and Maintenance i
Planning System (CHAMPS). The maintenance engineer is responsible for the overall administration of the MRF program.
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l CHAMPS'is a computerized system used to coordinate and track inter-
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related plant activities such as maintenance and operations. CHAMPS is used to generate a planned 5-day Schedule.of maintenance activities to be~ performed.
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Daily planning meetings consisting of Maintenance Planning, Quality Control, Health Physics, and Operations personnel provide coordination for control of scheduled maintenance activities and- for the necessary support-from the various station groups. The daily meetings were found effective'in supporting maintenance' activities and operations.
I Administrative Guideline AG-45," Work Package Planning Guideline,"
identifies the lines of responsibility and coordination of activities for planning a MRF work package. The Maintenance /I&C Engineering-Technical staff assigns the priorities to the MRFs. Technical staff interfaces with operations, system engineers, and the probabilistic risk assessment coordinator to obtain additional guidance on estab-11shing priorities, if required. The 5-Day Schedule is the pritaary mechanism used for scheduling maintenance activitie To improve the work planning process and reduce the number of interfaces, the licensee intends to consolidate all maintenance planning and scheduling activities into one centralized planning and scheduling organization. The licensee expects to accomplish this within the next yea The inspector concluded that methods used to plan and control maintenance activities are being performed satisfactoril .4 Implementing Procedures The preventive maintenance (PM) program is described and documented in administrative procedure A-25.1, " Preventive Maintenance Program."
Specific preventive maintenance activities are accomplished in accor-dance with the various preventive maintenance procedure If inadequacies to procedures are identified while conducting a
. maintenance activity, a form contained in the MRF package is filled out by the craft identifying the deficiency. This type of feedback mechanism is beneficial in improving the maintenance proces The inspector found, through observation of maintenance activities, that approved maintenance procedures were effectively being implemente Based on these observations and review of the administrative guidelines the inspector concluded that the procedures are appropriate to control and perform maintenance activities.
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The inspector noted that work prioritization categories "1" through
"6" denoted in procedure A-26, do not clearly correspond to safety-significance. Priority level determination guidance is contained in Administrative Guideline AG-42, "Probabilistic Risk Assessment Appli-cations in Plant Maintenance." However, the guideline does not clearly -
correlate numerical priorities to safety considerations. The inspector did not identify any MRFs which were incorrectly prioritized, based on the various procedures, guidelines and discussions with key maintenance personnel. The inspector discussed with the licensee that consideration be given to revising the procedures to clearly indicate safety significance associated with MRF numerical prioritie The licensee acknowledged the inspectors comments and agreed to review this are .5 Maintenance Work Observation The inspector observed in process work activities of selected safety-related and non-safety-related corrective and preventive maintenanc The inspector assessed whether maintenance activities were being-conducted in accordance with station administrative and maintenance procedures. No inadequacies were note The inspector observed corrective maintenance activities being' per-formed on Unit 2 Reactor Water Cleanup demineralized bypass motor operated valve HV-044-2F044. The valve was leaking water from the leak-off plug area. The mechanics responsible for the job were knowledgeable, organized, and aware of the overall maintenance i requirements. Health Physics involvement consisted of taking wipe
samples. The entire maintenance activity was adequately planned, supervised, and monitored by the first-line-supervisor. Departmental interfaces were found acceptabl The inspector observed preventive maintenance (PM) activities on Unit 2 480 volt magnetic starter for cooling water pump 2BP210. The PM activities were controlled by procedure PMQ-093-004, " Preventive Maintenance Procedure ~for 480VAC Magnetic Starters." The procedure contained specific Quality Control (QC) inspector witness hold points.
i- All required testing equipment was properly calibrated and verified by QC prior to conducting the PM tasks. The inspector noted that witness hold points were adhered to and that QC inspections were conducted when require >
The inspector noted the following strengths while observing in process maintenance activities:
1) The MRF packages contain specific area and elevation maps to assist the craft in rapid location of the item to be worke _ _ - _ _ _ _ - _ - _ _ - - _ - - - . - - - - _
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2)' To differentiate MRF packages between units, the folders are color coded according to unit, green for Unit 2 and yellow -
for Unit I and Commo ) System and component labeling and color coding was extensiv This type of human factoring is an aid to the craft and assists in reducing personnel errors and increases safet ,
' The inspector determined that maintenance work activities were properly controlled and performed effectively in accordance with station procedures and requirement .6 Quality Assurance of Maintenance MRFs classified as Q-list, American Society of Mechanical Engineers (ASME), Important to Nuclear Safety (INS), Fire Protection, Class IE or Environmentally Qualified (EQ) are routed to QC for review and approval. QC reviews the MRF and enters any applicable inspection requirements or comments before the craft performs any maintenance activitie The inspectors observed QC involvement on the 480 volt magnetic starter preventive maintenance task being conducted by electricians per PM Procedure PMQ-093-004. The procedure contained specific QC
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witness hold points which were adequately verified by the QC inspecto QA was found active in identifying weaknesses and problems in the
, maintenance area as evidenced by a recent audit (LA89005) which was completed in June 1989. The audit assessed the maintenance
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organization's performance as it related to work on safety related pumps, valves, turbines and safety relief valves. The QA audit resulted in two Corrective Action Requests (CARS) being issued. The CARS identified one case of a job leader conducting a peer inspection function outside the scope of his craft without proper training and several cases of measuring and test equipment not signed out by maintenance personne The NRC Maintenance Team inspection, which was conducted in February 1989, identified that QC witness points in certain maintenance procedures were deleted without specific guidance. The licensee's corrective actions to resolve this issue consisted of issuing Guideline No. 28. The guideline established a formal method for the determi-nation of QC witness points. The inspector concluded that Guideline No. 28 provides the added guidance needed to control QC witness points within maintenance procedure The CARS, recent QA audit, and QC inspections of in process work activities shows that quality oversight of maintenance is adequate and effectiv _ - _ _ - - _- _ _ _ - - ._ _ __ .-__ __-_--- _ - _ ..
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3.7 Conclusion In summary, maintenance activities are being properly implemente Programs in place for Unit I have been adequately adapted to include dual unit activities. The inspector concluded that maintenance programs are prepared to support safe operations of the dual unit facilit .0 Surveillance 4.1 Program Overview The surveillance test (ST) program is administered on site by the Technical Section. The Technical Engineer has overall responsibility for the administration of the ST program. The Technical Engineer delegates the responsibility for the program's daily activities to a Surveillance Test Coordinator (STC). The STC is responsible for all scheduling, documentation and filing required for the ST program. Additionally, the ST program is subdivided into organizational groups headed up by a Responsible Supervisor who is the immediate supervisor of the group responsible for the performance of ST The ST program is controlled by three administrative' procedure A-43, " Surveillance Testing Program," A-47, " Procedure for Preparation and Control of Surveillance Test Procedures," and A-223, " Procedures for Verification and Documentation of Performance of Surveillance Requirements by Other Than Surveillance Test."
An engineer was assigned to form the Unit 2 ST program. Basically,
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all Unit 1 STs were copied into a Unit 2 data base. Unit 1/ Common STs were removed from the data base. These common STs were then-reviewed to determine their impact on Unit 2 and whether or not they should be split into separate procedures. Each of the. remaining STs in the Unit 2 data base were made compatible with Unit 2 system Technical Specifications and component nomenclature. Once cor.plete, the Unit 2 ST program was formed, with only minor tuning require For the near future, the individual responsible for forming the Unit 2 ST program will continue to assist the STC with the Unit 2 ST progra Once Unit 2 is fully operational, the entire ST program is planned to be assigned to the STC, and possibly two assistants. The inspector concluded that the ST program for Unit 2 had been in place and functioning for some time. A proven system for Unit I was duplicated for Unit 2 and a sufficient amount of extra personnel are in place to run the SY progra _-____-_ _-___-_ __- _ _________
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4.2 Compliance Tracking Program The STC tracks and schedules STs with the computerized Surveillance Test and Records System (STARS). Each ST and their test intervals are stored in STARS and are scheduled to be performed during a one week interval as outlined in the weekly master test schedule. The master test schedule and a copy of the latest revision of each ST on the master test schedule are issued to each responsible Lupervisor the week prior to ST performanc If the STC does not receive the completed ST by the due date, the grace period allowed by Technical Specifications is entered and the ST is placed on a late list. This list is distributed to appropriate responsible supervisors and the STC tracks these late STs. Each day that the test is not performed during the grace period, a form is sent to the responsible supervisor requiring the reason that the ST has not yet been performed and his or her signatur Once an ST is completed, it is forwarded to the STC so that the appropriate success or failure code can be entered into STARS. This code will determine when a portion of, or the entire ST will be required to be performed again. Once reviews and processing of STs are complete, tney are forwarded to Nuclear Records for permanent record retentio The inspector questioned how partially completed STs were tracked, how the licensee prevented the use of out-of-date STs, how temporary changes to STs were handled, and if an ST/ Technical Specification (TS) cross reference existed. When an ST is partially performed, the
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ST is manually entered into a logbook by the STC; these STs are then tracked until completion. When an ST is revised, the STC is notifie The STC checks the master test schedule to determine if the ST is l currently issue If it is, the STC notifies the responsible supervisor so that the current revision can be use If a temporary change to an ST becomes a permanent revision, the licensee relies on the procedure revision process to ensure that the new revision is available the next time the ST is performed. The licensee also indicated that the person performing the ST could be relied upon to remember that there was a procedure change the last time the ST was performed. However, the inspector pointed out that a frequently occurring ST (weekly) may net Le revised and issued before its next performance. Additionally, a person other than the normal performer of the ST may be executing the ST and would be unaware of the previous procedure change. The licensee indicated that they would examine their program in this are Finally, the inspector was shown a very detailed computerized ST/TS cross reference for both units. Additio-nally, the licensee has a Unit 1 TS book and a Unit 2 TS book with all the ST procedure numbers written in the margin next to each TS requirement.
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l, a The STARS computerized tracking program is sufficient to ensure the -
ST program is carried 'out effectively. One weakness was identified concerning revisions to frequently occurring STs. The licensee is I
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4.3 Procedures 1 :
The inspector performed a desktop review of the following STs that ,
were completed on the dates specified: l t
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ST-6-044-202-2, "RWCU Valve Test," Rev. 2, l
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05/03/89, completed on 08/02/8 ;
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ST-6-043-390-3, " Reactor Recirculation Pump Idle l Loop Startup Temperature," Rev. O, 08/15/88, I completed on 08/02/8 l
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ST-6-095-901-2, " Divi sion I, 125/250 VDC Safeguard 'l Battery Weekly Inspection," Rev. 1, 12/12/88, completed on 08/02/8 .
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ST-6-047-200-2, "SOV Valve Exercise Test," Rev. 1, I 08/01/89, completed on 08/03/8 ST-6-043-200-2, " Reactor Recirculation System ,
Quarterly Valve Test," Rev. 2, 06/13/89, performed i on 08/03/8 l l
The inspector reviewed the above STs for completion (signatures),
use of temporary changes, adequacy of acceptance criteria, and l conformance to administrative procedure l i
During review of ST-6-047-200-2, Rev. I and ST-6-043-200-2, Re )
2, the inspector found both of these procedures to be out of date in the controlled ST procedure books within the Technical Support !
Cente Procedure A-2, " Control of Procedures and Certain Documents," l Rev. 4, 08/19/86, requires procedures in cont olled books to be up to 1 date. ST-6-047-200-2 was only several days out of date, but ST-6-043-200-2 was almost two months out of de:e. Upon further review of ST-6-043-200-2, Rev. 2, the inspector found the revision bars in !
the margins to' be identical to Rev.1, which mau it difficult to l determine what was changed between Rev. I and Rev. This error also does not agree with guidance outlined in procedure A- Finally, the inspector found one of the data pages in ST-6-043-200-2, i Rev. 2, to be in error. The upper part of the page was printed twice, and therefore, the lower part of the page was missing. Information missing was the signoff line for the person calculating the ALERT limits and part of the formula to calculate these limits. Review of i ST-6-043-200-2 performed on 08/03/89 did not contain the person's j l
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.-initials who performed the calculations, and was missing part of the limit calculation formula. . However, the inspector found that the
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- ALERT. limits were correctly calculated, and all valve stroke times 4 were acceptabl The inspector determined that the page error occurred probably when
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the official record copy document was printed out-from the computer since the data contained in the computer was correct. The licensee was questioned whether this ST was reviewed against the PORC-spproved-
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copy for-accuracy. -The licensee stated that. procedures are usually reviewed' prior to distribution, but for some reason ST-6-043-200-2
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was not reviewed._ The inspector determined'that the Unit 2 S coordinator failed to correct the procedure, and two individuals performing the ST also did not notice the erro The Code of Federal Regulations,10 CFR 50, Appendix B, Criterion VI states in part that measures shall be established to control the issuance of procedures,-including changes and that these procedures, including changes, be reviewed for adequacy and approved for release'
by authorized personnel.- The above deficiencies are collectively an apparent violation (50-353/89-81-01).
The inspection team determined that the licensee should perform a review of this problem area prior to Unit 2 startup. The specific areas of concern are:
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The licensee's procedure distribution system, including the number of~out of date procedures in controlled procedure books, and the number of controlled procedure
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The errors found with revision bars in the S The review process for revised procedures prior to duplication and distribution around the sit At the exit interview, the licensee committed to review and resolve these concerns prior to Unit 2 initial criticality, 4.4 Observation of Surveillance The inspector observed performance of the following Unit 2 STs, either completely or in part, on the dates specifie ST-1-LLR-101-2, " Steam to RCIC Turbine," Rev. O, 01/06/89, performed on 08/02/89.
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ST-2-061-401-2, " Reactor Coolant System Leakage Detection System - Drywell Equipment Drain Tank Level and Flow Calibration / Functional," Rev. 1, 05/08/89, performed on 08/02/8 .
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ST-2-036-640-2, " Loose Parts Monitoring System Channel Functional Test," Rev. 1, 05/24/89, performed on 08/02/89,
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ST-2-041-423-2, "RPS and NSSSS-Main Steam Line Radiation - High; Division IIB, Channel B2/D Calibration / Functional Test,"_Rev. 1, 07/18/89, performed on 08/03/8 ST-6-047-200-2, "SDV Valve Exercise Test," Rev. 1, 08/01/89, performed on 08/03/8 ST-6-043-200-2, " Reactor Recirculation System L Quarterly Valve Test," Rev. 2, 06/03/89, performed on 08/03/8 ST-2-013-600-2, " Radiation Monitoring - Reactor Enclosure Cooling Water System Nonitor Functional Test," Rev. O, 05/23/88, performed on 08/03/8 The inspector reviewed ST procedure useability, technical accept-ability and adequacy of acceptance criteria. Procedural compliance and qualifications of the personnel performing the STs were also reviewed. The inspector also assessed interactions between various group Personnel performing STs reported to the control room and received permission and sign-offs from the Unit 2 reactor operator and/or the shift supervisor. The inspector observed good interaction between operations personnel, I&C technicians, and system and test engineer The inspector noted a strength, in that, an I&C technician was always in the control room in constant communication with I&C technicians in the field who were performing STs that could affect the reactor protection syste In the field, the inspector determined that observed STs were usable, technically correct, and acceptance criteria were adequate. No instances were noted in which an ST was stopped in order to obtain a temporary change. Procedures were followed step oy step, and personnel performing the STs were knowledgeable of questions aske The inspector noted an inconsistency in the way 1&C STs were written versus all other types of STs. Each procedural step in non-I&C STs has a line for initials. The purpose of the sign-off is to show that the step was performed and to allow the performer to easily follow the procedure in order. The inspector noted various I&C technicians marked through the procedural step with their pen to keep track of their place in the procedure. The inspector did note that steps requiring data recording or important steps affecting safety related components contained sign-off lines. Even though
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the I&C ST appeared to be older than other STs, they were still in compliance with A-47, " Procedural Control of Surveillance Test
. Procedures."
4.5 Quality Assurance of Surveillance The inspector was provided a list of recent operational and
,, surveillance audits performed by the Nuclear Quality Assurance (NQA)
department. Audit LA 89004 of the station's local leak rate testing program was performed from February 8 through April 18, 1989. No unsatisfactory findings were identified, but two recommendations were proposed. The inspector determined both to be relatively minor in nature. NQA surveillance LS 89010 was recently conducted on motor operated valves STs versus Technical Specifications. The inspector did not identify any problems identified by this NQA surveillanc 'The inspector determined that NQA found no major problems with the surveillance program. The inspector determined NQA department activity'to be acceptabl .6 Conclusions The licensee's ST program for Unit 2 has been in place for some tim As of- the end of July 1988, out of a total of 1141 STs, approximately 80% of them had been performed. Therefore, the licensee has been operating a dual unit ST progra The licensee's program adequately implements TS, and personnel have adequate technical knowledge to support dual unit operation. The tracking program (STARS) is functioning well and STs are generally usable, technically correct, and acceptance criteria appear adequat There are no major NQA findings or previous NRC inspection items that affect the ST progra Pending acceptable NRC review of the licensee's corrective actions in regard to deficiencies identified in section 4.3, the licensee will be able to'startup Unit 2 safely, and operate a dual unit facility 4 with an acceptable ST progra .0 Engineering and Technical Support 5.1 Scope This portion of the ~ inspection focused upon the existing level of corporate engineering services to site groups, and the capacity of the existing site Technical Group to perform its prescribed functions with the additional responsibilities of two operational reactors. A listing of the procedures and program descriptions utilized during this inspection is displayed in Attachment A.
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(, 21 5'.2 Onsite Plant Technical Group The' onsite. Plant Technical group is organized under the Plant Technical Superintendent'and the Technical Engineer. There are three major-sections within the technical group (Projects / Programs, Performance, and Regulatory) each under the supervision of a. Lead Engineer. The inspector reviewed the current projects and programs administered b .- the technical group and assessed the level of staffing and the organi-zational structure to conduct two-unit technical support; to communi-cate effectively with the NED site support group; and its capabilities for implementing resolutions to technMal concerns ongoing in two unit Administrative Procedures (APs) were reviewed in detail to ensure the required controls have been incorporated'in the procedures which-reflect the appropriate level of attention required for two-uni operation. Thirteen APs (see Attachment A) applicable to the technical .
group have been revised within the past month to incorporate the requirements and needs of two units. The inspector also reviewed various other administrative documents which define responsibilities and functions of the plant technical group. These are:
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AG-39, " System Engineer Responsib111 ties", and AG-19, Attachment 1, " Technical Engineer System Responsibility List"
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AG-21, " Plant Incident Tracking System"
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Position Description For System Engineer
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" System Engineer Training at Peach Bettom and Limerick"
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" Technical Group Organization and Practices" The inspector reviewed Technical Group personnel system assignments, system engineer notebooks, system engineer walkdown checklists, the procedure problem identification system (PPIS), the plant differences list,. the Quarterly Performance Report, and the plant incident tracking system (PITS) file. The system engineer walkdown checklist is utilized to perform weekly system inspection tours and is intended to indicate that a walkdown inspection has been performed on both units. This checklist records the routine test (RT) used for the walkdown of systems from which operational performance data is taken. The Unit 1 RTs are also being used on Unit 2 systems since the Unit 2 RTs are not yet issued, and performance data is not yet obtainable from Unit ,
Only those procedure sections which do not require data are used on i Unit 2 system _ - _ _ - - _ _ - _ - _ _ _ _ _ _ - _ _ -
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L The plant system performance monitoring program was reviewed. The inspector noted'that data is only being captured and recorded for Unit 1 (the program does not report performance of plant systems at
<80% power). Unit 2 systems are still undergoing the installation of monitoring equipment. The projects / performance lead engineer expects that it will be several months before performance' data is reported, tracked, and trended in Unit 2, since ccmmercial operation is not anticipated before February 199 .3 NED Site Support Engineering The Nuclear Engineering Department (NED) site support engineering group has had 10 technical personnel at Limerick for two months prior to this inspection (1 supervisor, 5 mechanical, and'4 electrical).
This group has been acting as the direct liaison between site groups and the corporate NED offsite office The workload of this group currently consists primarily 'of Engineering Work Requests (EWRs) (60%),
Non-Compliance Reports (NCRs) (25%), and Minor Modifications (15%).
This work is split in roughly equal amounts of support requests for each unit. Since the group's work is evenly split between Unit I and Unit 2, the additional number of systems remaining for turnover to the plant is not expected to add significantly to the existing work-load. The present staffing level is considered to be adequate to assume complete responsibility for onsite engineering services for two unit operatio With the recent placement of NED personnel onsite, a faster turnaround of engineering support to site requests for assistance has been possible. Plant events and concerns such as Licensee Event Reports (LERs), equipment qualification (EQ) matters, system / component design questions, are handled more effectively with improved communications between onsite and offsite organizations. This level of support is considered essential for two-unit operation at Limerick. NCRs are handled similar to EWRs with almost all NCRs processed directly onsit Minor modification design work is also being assumed by the NED site support group. This facilitates a more efficient modifications program by accomplishing work locally and permitting modification packages to be prepared more rapidly. Information is more immediately available to the offsite engineering staff. Major Modifi~ cations are not-currently being handled onsite since the offsite corp' orate NED activities still have this responsibility. The actual design engineering function is often contracted to the original architect-engineering firm; however, NED remains primarily cognizant over the entire design process. The NED is planning to assume all responsi-bility for " red 11ning" controlled Category I drawings in the control room which is currently being performed by the Plant Modifications Grou f
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The Limerick Projects Group is also a~ site based' NED activit It provides the horizontal matrix element which interfaces at the; project-level- across all line organizations under the Limerick site support group. The group provides for tracking of EWRs, NCRs, and Engineering Review Request Forms (ERRFs) for both' units- (since April 89) in, the Nuclear Engineering Task Tracking (NETT) System L Performance report. The NETT report is presented biweekly'to PECo
" senior corporate managers. It tracks new, backlogged, and overdue (by age) EWRs, NCRs,'and-ERRFs, and trends each category separately
'in each unit, This effort is completely underway for both units:and the remaining systems still carried by the startup group will.not
' increase.the NED project's workload fo'r compiling this repor .4 Plant Modification Group-This group has plant project level responsibility for ensuring.that all aspects of plant modifications are properly and completely-implemented in the plant. Administrative Procedure A-14, " Procedure
? for Control _of Plant Modifications," describes the measures necessary for control of modifications _to both safety related and non-safety related systems and component The inspector reviewed the modifications tracking program, the
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configuration control program, and the Bechtel interface handled by
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the modifications grou The modifications group has assigned numbers to each modification such that each package has a unique number suffix which identifies the individual plant. When a modification package is produced for one plant, a separate package with a different suffix-number for the opposite. plant is assembled so.that the work can be controlled separately. Modifications are usually performed during an outage so the packages are not worked concurrentl The Architect Engineer (Bechtel) still maintains t k t trolled sets
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of Category'I drawings for_ plant systems. These f:awirls are uniquely identified in the title block which lists the 0-licable unit numbe After a system modification falls under the e vol on Plant Operations, the modifications group will perform redlining of main control room drawings to indicate that a system has been modified and that a drawing revision is pendin When a modification has been performed and a drawing revision is left outstanding, the modifications group will issue an Interim Drawing Change Notice (IDCN) to attach to control room drawings until the. revised drawing is issued.
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The inspector reviewed the " LGS 1989 Unit 1 Audit Schedule" and'
observed that the schedule includes audit activities- for all of
' Unit 1 and selected systems for Unit 2 which have been turned I over to the plant. When all systems have been turned over, both units will be included in the schedule. The areas of audit are identical on both units. As the remainder of Unit 2' systems are '
turned over to the LGS plant organization, audit responsibility will be transferred to the Unit 1 QC group. Unit 2 QC personnel will also be absorbed into the Unit 1 organization so that present staffing levels will not be stressed by the additional workloa The Consolidated Open Items List- (COIL) has been in existence at LGS for over nine months to track outstanding items carried over during the turnover of plant systems from Bechtel (installation)
'to Startup (testing) to the plant (operation). This list carries and tracks the resolution of any issue related to the transfer of Unit 2 system responsibility. .This inspection accomplished a review of COIL items related to outstanding plant differences and noted that there are none at this time.
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5.6 Conclusions A review of the plant technical groups and NED site support group indicates that plant engineering and techaical services are functional'ly capable of supporting Unit 2 startup and power ascension to commercial operation. Eventual two-unit operation is not expected to impose significantly more work upon the existing organizations. Additional staffing or reorganization within the technical groups is not necessary before Unit 2 is in full operatio The long-term plan for the assumption of all engineering and technical support by NED and the LGS Plant groups will be ongoing until 1991 and will be developed according to the future needs of the overall site operatio The areas reviewed during this inspection indicate that most of the Unit 2 systems have been turned over to the plant organization and technical cognizance is already being assumed by the technical grou Although operation of the Unit 2 plant is expected to increase the requests for technical assistance required for the operations department, the present organi.Tation has demonstrated its capability to handle twice the load experienced for Unit 2. Unit 2 is not
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expected to generate the amount of technical supportLrequired for Unit 1. The technical group was found to be. adequately staffed, trained and experienced to provide the level of technical support required for the two-unit operatio .0 MANAGEMENT MEETINGS An-entrance interview was conducted with station management on-July 31, 1989 to discuss the purpose and scope of the inspectio An exit interview was conducted on August 4,'1989 to review L preliminary. findings of the inspection team. At the exit interview, the licensee committed to resolve the apparent violation described in paragraph 4,3 prior to criticality of Unit .
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Attachment A Documents Reviewed for Technical Support Nuclear Engineering Dept. Procedure Interim Guidance (NED IG) 3.8-7, " Procedure for Processing Engineering Review Requests (ERRFs)"
Nuclear Engineering Dept. Procedure 3.4, " Design Control" Nuclear Engineering Dept. Procedure 3.6, " Preparation and Review of Engineering Drawings for Nuclear Plant Modifications" Nuclear Engineering Department Procedure 3.11, " Procedure for Processing Engineering Work Requests (EWRs)"
Administrative Guideline AG-19, " System Engineer Responsibilities"
/ administrative Guideline AG-21, " Plant Incident Tracking System (PITS)"
Administrative Guideline AG-49, " Reporting of Unit-1/ Unit-2 Differences" Organization Chart, Limerick Generating Station, 6/1/89 Organization Chart, PECo Nuclear Engineering Department, 7/1/89
" Technical Group Organization and Practices" Nuclear Engineering Task Tracking (NETT) "Open ERRF Report" 7/29/89 NETT "Open EWR/NCR Report" 7/27/89 NETT "Open JC0 Report" 7/27/89 Administrative Procedures:
- A-4, "PORC Procedure"
- A-5, " Procedure for Safety Evaluations"
- A-6, " Control and Distribution of Drawings, Manuals, and Drawing Logs"
- A-8, " Procedure for Control of Locked Valves and Devices"
- A-14, " Procedure for Control of Plant Modifications"
- A-42, " Procedure for Control of TCAs"
- A-45, " Preparation of Reactor Engineering Procedures"
- A-46, " maintenance of QA Records"
- A-61, " Plant Labeling Program"
- A-80, " Inservice Inspections"
- A-129.2, " Classification and Engineering Evaluation of Items and Offsite Services"
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