IR 05000352/2002010
| ML022030087 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/19/2002 |
| From: | David Lew NRC/RGN-I/DRS/PEB |
| To: | Skolds J Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-02-010 | |
| Download: ML022030087 (12) | |
Text
July 19, 2002
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - NRC INSPECTION REPORT 50-352/02-10, 50-353/02-10
Dear Mr. Skolds:
On June 20, 2002, the NRC completed a team inspection at the Limerick Generating Station, Units 1 and 2 Nuclear Facilities. The enclosed report presents the results of that inspection.
The preliminary results of this inspection were discussed on June 26, 2002, with Mr. W. Levis and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations, and with the conditions of your operating license at Limerick Generating Station, Units 1 and 2. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated and resolved within the problem identification and resolution program. However, the team identified that some elements of the corrective action program have not been fully effective in resolving errors associated with equipment clearance and tagging and component mis-positioning events. We acknowledge that your oversight committees identified similar findings and that increased management attention has been directed to this area.
Mr. John Skolds-2-In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (The Public Electronic Reading Room).
Sincerely,
/RA/
David C. Lew, Chief Performance Evaluation Branch Division of Reactor Safety Docket Nos:
50-352, 50-353 License Nos: NPF-39, NPF-85
Enclosure:
NRC Inspection Report 50-352/02-10, 50-353/02-10 Attachment 1: Supplemental Information
REGION I==
Docket Nos:
50-352, 50-353 License No:
50-352/02-010, 50-353/02-010 Licensee:
Exelon Generating Company, LLC Facility:
Limerick Generating Station, Units 1 & 2 Location:
Evergreen and Sanatoga Roads Sanatoga, PA 19464 Dates:
June 3 - 7, 2002 June 17 - 20, 2002 Inspectors:
Jimi Yerokun, Senior Reactor Engineer (Team Leader)
Michael Modes, Senior Reactor Engineer Josephine Talieri, Reactor Engineer Approved by:
David C. Lew, Chief Performance Evaluation Branch Division of Reactor Safety
ii SUMMARY OF ISSUES IR 05000352/02-10; 05000353/02-10; on 06/03 - 20/2002; Limerick Generating Station, Units 1 and 2; biennial baseline inspection of identification and resolution of problems.
The inspection was conducted by three region-based inspectors. No findings were identified.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems The team concluded that the implementation of the corrective action program at Limerick Generating Station (LGS) was adequate. The licensee was effective at identifying problems and putting them in the corrective action process. Issues were prioritized and evaluated appropriately and in a timely fashion. The evaluations of significant problems were of sufficient depth to identify likely root or apparent causes, and to address the potential extent of the circumstances contributing to the problem. Corrective actions that addressed the causes of problems were generally identified and implemented. However, the team identified that some elements of the corrective action program had not been fully effective in resolving component mis-positioning events and errors associated with equipment clearance and tagging. The team also noted that the licensees oversight committees identified similar findings and that increased management attention has been directed to this area.
Report Details 4.
OTHER ACTIVITIES [OA]
4OA2 Identification and Resolution of Problems (71152)
a.
Effectiveness of Problem Identification (1)
Inspection Scope The team reviewed the procedures describing the licensees corrective action process.
In September 2001, the licensee transitioned to the Exelon company wide corrective action program in which problems are entered as condition reports (CRs). Under the previous program, problems were entered as PEPs. The licensee considered the work control process to be a part of the corrective action process, and generally addressed minor equipment problems directly with an action request (AR). Team members attended daily management meetings where CRs were reviewed for initial screening and assignment to better understand the licensees threshold for identifying and entering problems into their corrective action process.
The team selected items from the licensees maintenance, operations, engineering and oversight processes to verify that the licensee appropriately considered problems identified in these processes for entry into the corrective action program. Specifically, the team reviewed a sample of maintenance and engineering ARs, operator log entries, control room deficiency and work around lists, maintenance orders, maintenance backlogs, and the disposition of selected repeat maintenance actions, engineering system and program health reports, installed temporary modification packages, quarterly CR reports and quarterly nuclear safety review board (NSRB) reports and nuclear oversight and departmental self assessments. Issues identified in these documents were reviewed to ensure underlying problems associated with each issue were appropriately considered for identification and resolution via the corrective action process.
The team also interviewed selected plant staff, security contract personnel and Exelon management to understand whether other processes were used to address problems.
Additionally, the team conducted a walk down of selected portions of the plant to independently assess whether visible problems were being adequately addressed.
The team reviewed the CRs and ARs listed in Attachment 1 to determine if the licensee was identifying and entering problems into the program at an appropriate threshold.
The items selected covered the period from June 2001 to the present and also covered the seven cornerstones of safety identified in the NRC Reactor Oversight Process (ROP).
(2)
Findings Based on the sample selected, the team determined that the licensee was identifying problems and entering them into the corrective action program at an appropriate threshold. The team found that problems identified in other licensee processes that met the threshold for a CR were entered into the corrective action program for resolution.
The licensees nuclear oversight and CR trend reports were also functioning as intended to help ensure licensee management was cognizant, and addressing, problem trends within the corrective action process. Furthermore, the team confirmed through discussions with plant personnel that the corrective action process was considered and utilized as the primary problem resolution process.
b.
Prioritization and Evaluation of Issues (1)
Inspection Scope The team reviewed the CRs and ARs listed in Attachment 1 to determine whether the licensee adequately evaluated and prioritized problems. The CRs reviewed encompassed the full range of licensee evaluations, including root and apparent cause evaluations. The CRs were selected to cover the seven cornerstones of safety identified in the NRC Reactor Oversight Process. In addition, the team considered risk insights from the licensees Individual Plant Examination (IPE) report to help focus the CR sample on risk significant plant equipment. The team also selected a sample of CRs associated with previous NRC non-cited violations (NCV) to determine whether the licensee was evaluating and resolving problems associated with compliance to applicable regulatory requirements. The team also reviewed the licensees evaluation of industry operating experience (OE) information for applicability to their facility. The team reviewed a sample of evaluations completed within ARs for equipment issues to determine whether the evaluations were reasonably completed within the AR process.
The team also reviewed the licensees assessment of equipment operability, reportability requirements, and the potential extent of the problem.
For each CR selected, the team considered the licensees prioritization for completing the evaluation and identifying corrective actions. The team assessed whether the licensee evaluated the problems in sufficient detail to determine the likely causes and identify corrective actions to prevent recurrence. The team reviewed the licensees consideration of the extent of the problems to determine whether the licensee adequately bounded the issues. The team also reviewed the licensees assessment of equipment operability and regulatory reporting requirements.
(2)
Findings The CRs reviewed were generally categorized at the correct significance level. The root cause evaluations reviewed were acceptable. The licensees evaluations of problems were determined to be of sufficient detail to identify the likely causes. The licensee completed detailed root and apparent cause evaluations for more risk significant problems. Additionally, the licensees proposed corrective actions reasonably addressed the causal factors. The team observed the licensees management review committee and concluded they appropriately provided additional oversight of evaluations for more significant problems.
c.
Effectiveness of Corrective Actions (1)
Inspection Scope The team reviewed the licensees corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The team also reviewed the licensees timeliness in implementing corrective actions and their effectiveness in preventing recurrence of significant conditions adverse to quality.
Furthermore, the team reviewed the backlog of corrective actions to determine whether there were corrective actions in the backlog that either individually or collectively were of risk significance to plant safety. The team also reviewed the Nuclear Safety Review Boards reports to evaluate the adequacy of their reviews in assessing corrective action issues.
The team attended meetings during when personnel designated as Corrective Action Program Coordinators (CAPCOs) conducted reviews of internal performance indicators of open evaluations and corrective actions to ensure that the corrective action program was being implemented properly.
(2)
Findings Based on a review of selected CRs and observation of management meetings during the inspection, the team concluded that licensee management adequately considered the potential safety significance of problems in determining the pace of corrective actions. The corrective actions were generally effective at correcting the identified problem and preventing recurrence. For more significant problems, the licensee performed effectiveness reviews some time after the corrective actions were completed to confirm the effectiveness of their corrective actions.
Notwithstanding, the team noted that errors associated with component mis-positioning events and equipment clearance and tagging continued to exist. The errors included inadequately written clearance orders, working on equipment under no clearance or a suspended clearance, failure to sign onto active clearances, improper execution of clearance orders, inadequate self and peer checking practices, and removal of clearance tags prior to completion of maintenance. For the period reviewed (June 2001 to April 2002), several of the errors resulted in a reset of the operations department event clock as documented in CRs 61128, 61179, 61223, 61246, 80967, 81251, 83768, 85477, 86645, 89119, 89618, 94445, 94586, 98499, 98778, 99531, 102019 and 105691.
The team noted that the Nuclear Safety Review Board commented on the declining trend in the human performance area, specifically in Operations, in its reports dated June 28, 2001, January 11, 2002, March 15, 2002, and May 30, 2002. To address the equipment clearance and tagging issues, the licensee had initiated CR 00094564, Increased Trend in C&T Office Performance Related Issues, in February 2002. In April 2002 the licensee initiated CR 00103192, Trend to Evaluate Cause of Inadequate Verification Practices, to address inadequate verification practices. During this inspection, the licensee initiated CR 00112368, Operations Human Performance Corrective Actions, to capture certain generic corrective actions which were not
previously documented in the formal corrective action program.
d.
Assessment of Safety-Conscious Work Environment (1)
Inspection Scope During the course of the inspection, team members interviewed plant staff to determine if conditions existed that would result in personnel being hesitant to raise safety concerns to their management and/or the NRC.
(2)
Findings No findings of significance were identified.
4OA6 Meetings, Including Exit On June 26, 2002, the team presented the inspection results to Mr. W. Levis and other members of the Limerick Generating Station management. Exelon acknowledged the findings presented. Exelon did not indicate that any of the information presented at the exit meeting was proprietary.
ATTACHMENT 1 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Partial List of Persons Contacted (Alphabetically)
J. Bauers, Manger, Training R. Braun, Plant Manager E. Callan, Director, Maintenance R. Dickinson, Manager, Nuclear Oversight T. Dougherty, Operations Superintendent P. Dunston, Human Performance R. Harding, Engineer, Regulatory Assurance D. Hocker, Regulatory Assurance Engineer M. Kaminski, Manager, Regulatory Assurance J. Karkoska, Emergency Preparedness Coordinator R. Landis, Operations Support Manager W. Levis, Vice President C. Mudrick, Director, Engineering S. Muntzenber, Engineer, Regulatory Assurance W. OMalley, Director, Operations J. Stone, Director, Work Management A. Winter, Corporate Corrective Action Program Coordinator LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None LIST OF DOCUMENTS REVIEWED Procedures LS-AA-125, Corrective Action Program (CAP) Procedure, Revision 2 RP-AA-1005, Condition Report (CR) Initiation, Revision 1 LS-AA-115, Operating experience Procedure, revision 0 Nuclear Oversight and Departmental Assessment Reports Nuclear Oversight Continuous Assessment Report, April - June, 2001 Nuclear Oversight Continuous Assessment Report, July - September, 2001 Nuclear Oversight Safety Assessment, NOSA-LG-01-04, October - December 2001 Nuclear Oversight Safety Assessment, NOSA-LG-02-1Q, January - March 2002 Site Wide Corrective Action Program (CAP) Self Assessment, May 1 - 3, 2002
Nuclear Safety Review Board Meeting Summaries Nuclear Safety Review Board Meeting Report, dated January 11, 2002 Nuclear Safety Review Board Meeting Report, dated March 15, 2002 Nuclear Safety Review Board Meeting Report, dated May 30, 2002 Nuclear Safety Review Board Meeting Report, dated June 28, 2002 Condition Reports CR 00060040 CR 00060306 CR 00061141 CR 00086271 CR 00076542 CR 00096363 CR 00089119 CR 00078605 CR 00096370 CR 00060030 CR 00061084 CR 00061113 CR 00095951 CR 00098292 CR 00061097 CR 00074816 CR 00075680 CR 00075708 CR 00095896 CR 00097926 CR 00099392 CR 00094199 CR 00094196 CR 00061096 CR 00099104 CR 00098780 CR 00092937 CR 00094200 CR 00061123 CR 00061152 CR 00061131 CR 00085623 CR 00061088 CR 00061093 CR 00061128 CR 00061179 CR 00061223 CR 00061246 CR 00072390 CR 00078558 CR 00080967 CR 00081251 CR 00083768 CR 00085477 CR 00086645 CR 00089119 CR 00089618 CR 00096103 CR 00094171 CR 00097166 CR 00094445 CR 00094586 CR 00098499 CR 00098778 CR 00099531 CR 00105691 CR 00101408 CR 00106694 CR 00104372 CR 00106541 CR 00103525 CR 00100575 CR 00101361 CR 00101357 CR 00100925 CR 00101596 CR 00101357 CR 00103525 CR 00111254 CR 00111527 CR 00111562 CR 00100158 CR 00102019 CR 00103799 CR 00101890 CR 00103192 CR 00105691 Action Requests (AR)
A1361572 A1349404 A1346673 A1347189 A1347932 Ai353947 A1357487 A1363777 A1333606 A1359424 A1328610 A1325615 A1362263 A1359101 A1367287 A1369223 A1346372 A1333966 A1360682 A1365089 A1331627 A1333462 A1356853 A1307902 A1321553 A1221675 A1361478 A1328163 A1354134 A1322632 A1360228 A1362633 A1347507 A1321577 A1348513 A1365877 A1352609 A1345936 A1368663 A1348928 A1354649 A1339522 A1345142 A1354528 A1367053 A1366883 A1346940 A1334368 A1324199 A1323608 A1321704 A1323752 A1323922 A1324701 A1330845 A1330960 A1331287 A1331843 A1331843 A1333083 A1333434 A1336433 A1346586 A1346921 A1349722 A1355406 A1356123 A1371768
Miscellaneous SO-2002-001 Rev. 0 - Human Performance Improvement Initiatives Operations Improvement Plan Action Items, 4/22/02 Revision MR a(1) System Report, Emergency Service Water Units 1&2 System Health Report, Feedwater, 3rd Quarter, 2001 System Health Report, Residual Heat Removal System, 2nd Quarter, 2001 System Health Report, Emergency Diesels, 3rd Quarter, 2001 System Health Report, Emergency Service Water, 3rd Quarter, 2001 Chapter 16 - Emergency Preparedness Areas - 1st Quarter 2002 Chapter 16 - Emergency Preparedness Areas - 3rd and 4th Quarter 2001 Chapter 3 - Operations - Annual 2001, April 2002 Non-Cited Violations NCV 50-353/2001-005-01, RCIC ST Risk Assessment Missed NCV 50-352, 353/2001-007-01, ESW Wetwell Screens, No PM (CR 00075213)
NCV 50-352/2001-012-02, TS VIO, ST Missed, EDG FO Water NCV 50-352/2002-002-02, TS VIO, U1 Batt Charger Inoperable, CR 00100013 LIST OF ACRONYMS USED AR Action Request CAP Corrective Action Process CAPCO Corrective Action Program Coordinator CR Condition Report IPE Individual Plant evaluation LGS Limerick Generating Station NCV Non-cited Violation NRC Nuclear Regulatory Commission NSRB Nuclear Safety Review Board OE Operating experience ROP Reactor Oversight Process SDP Significance Determination Process