ML20137B042
| ML20137B042 | |
| Person / Time | |
|---|---|
| Site: | Limerick, 05000000 |
| Issue date: | 06/06/1985 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20136E841 | List: |
| References | |
| FOIA-85-668 NUDOCS 8511260167 | |
| Download: ML20137B042 (3) | |
Text
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.. , h "8 UNITED STATES
- - , NOCLEAR REGULATORY COMMISSION I y 'd REGION I In .f $21 PARK AVENUE
/ ,KsNo or PRUsssa. PENNSYLVANIA 19406 June 6, 1985 MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM: Thomas E. Murley, Regional Administrator
SUBJECT:
/ LIMERICK NUCLEAR GENERATING STATION UNIT 1 FULL POWER LICENSE RECOMMENDATION In a memorandum dated October 25, 1984, I recommended issuance of a low Power Operating License for Limerick Unit 1. This recommendation was based on an extensive evaluation conducted by the Region I staff which addressed the lice'nsee's performance during plant construction and assessed the licensee's readiness for initial operation. Since issuance of License NpF-27 on October 26, 1984, Region I has continued to monitor the progress made by the licensee
' in implementing its preoperational and startup test programs and has evaluated the licensee's performance in the safe operation of the facility at less then 5 pe,rcent power. Region I's activities have included the daily observations of licensee performance by the resident inspector and routine inspections by the Region-based staff. Further, a comprehensive operations assessment team
' inspection was conducted in January 1985. This team consisted of five inspec-tors, all experienced in the inspection of operating boiling water reactors.
Over 225 inspection hours were consumed onsi.te observing in process operations, interviewing station personnel and reviewing management control programs related to operational, maintenance and surveillance activities. The overall conclusion of the team was that, in general, adequate management controls had been established and implemented to support full power operation. Weaknesses identified by the team have been adequately dispositioned by the licensee and ~
. accepted by Region I.
Region I has determined that the licensee adequately and effectively imple-mented its testing programs by usin'g technically sound procedures, by properly performing tests and by reviewing test results thoroughly. Those portions of the test programs required to be completed prior to exceeding 5 percent power
- were completed by the end of March 1985. Additionally, the. licensee success- ,
fully tested the main turbine and generator, reliably producing up to 20 MW of electrical power by April 16, 1985. Region I's review of testing and test results have indicated that no significant programmatic or hardware problems
. exist and that the licensee has maintained a proper safety perspective through-out the test program.
Regarding plant operations, we have determined that the licensee's overall approach to this area has resulted in the safe operation of the plant. We noted, however, that the licensee initially experienced problems regarding errors being made by operators and technicians. These erra s occasionally B511260167 851031 4 PDR FOIA SHOLLY85-668 PDR [7 )b
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Harold.R. Denton 2 rendered trains of safeguard systems inoperable or caused the inadvertent actuation of these systems. Although we observed that no single event repre-sented a significant breakdown in the effectiveness of a licensee program 4
or a significant degradation in reactor safety, Regio 9 I was concerned that a trend appeared to be developing which required prompt licensee attention.
Consequently, we met with the licensee on February 22, 1985 to discuss our concerns and in response to that meeting-, the ifcensee submitted a compre- -
hensive corrective action program (Enclosure 1). The licensee's corrective action program addressed three principal areas for improvement. The areas included hardware modifications to reduce man-machine related events; actions 1
to address personnel errors, including additional training and a station wide Operator Excellence Program; and programmatic improvements to provide more direct management control of operations. The corrective actions taken by the licensee in this area appear to have been effective as indicated by the recent decrease in the number of reportable events related to personnel error (Enclosure 2). -
In my memorandum of October 25,1984, I referred to an ongoing investigation being performed by the NRC Office of Investigations into falsification of guard training records by the guard force contractor. Subsequent to issuance of the Low Power License, the investigation was completed and our review of its results indicates that PECO management was not a party to this fa'lsifica+. ion.
However, the results of this investigation have been referred to the Depar'tment of Justice for a review for potential criminal prosecution. Additionally, the licensee has informed us of an instance of a guard force sergeant directing that the results of a surveillance test be falsified. This person was subse--
l quently released from employment at Limerick. OI is currently reviewing this l matter, however, to date it appears that the licensee was not involved.
l Inspections of the licensee's implementation of its Security Program performed i
' since issuance of the Low Power License consistently demonstrated that the quality of guard force supervision and the level of involvement of licensee --
corporate and site management in the daily activities of the security contrac-tor were inadequate. Accordingly, an enforcement ccnference was conducted on March 11, 1985 with senior licensee and contractor management to discuss our concerns. Further, to emphasize these concerns, a proposed civil penalty was s issued on May 30, 1985. In response to the concerns expressed at the enforce-ment conference, the licensee implemented a program of corrective actions.
- Those actions taken or planned include both short and long term security ,
contractor program improvement measures. Short term measures include improved key and weapon controls, closer monitoring of guard qualifications, upgraded procedures for guard posts, improved conduct of surveillance tests and opera-tion of the central alarm / secondary alarm station, and installation of upgraded communications equipment. Long term actions include steps to reduce security -
contractor personnel turnover, improve overall security force awareness
- training, and development of contractor corporate and site performance analysis groups. In addition, PECO improvements include additional licensee site security specialist positions and additional site and corporate quality assurance monitoring of the security contractor. The effectiveness of these O
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' Harold R. Denton
, 3 corrective actions was assessed by Region I during an April 1985 inspection. It was determined that the licensee had implemented all of the short term improve-4 ments and that adequate progress had been made toward implementation of the long term improvements. In particular, there was increased involvement of licensee management in oversight of and interfacing with the contractor guard force; additional on-site licensee staffing was provided to monitor the contractor activities; and several administrative safeguards were implemented _
to maintain the integrity of all security records. Region I will continue to monitor the licensee's security activities to verify continued improvement.
- t Our reviews indicate that the licensee has demonstrated the ability to operate this facility safely and to remain in conformance with NRC requirements. In conclusion, I have determined that Limerick Unit I has been tested and operated in accordance with Operating License NPF-27, the FSAR and NRC regulations. ;
Therefore, I consider Philadelphia Electric ready for operation of this facility to its licensed full power rating. -
AV -
Thomas E. Murley .
Regional Ariministrator
Enclosures:
- 1. M.J. Cooney Letter to R.W. Starosteckt dated April 2,1985 - /de. M. h ##*E 3## *
- 2. Licensee Event Reports, October 1984 through May 7, 1985 cc: (w/ encl)~
W. Dircks, EDO J. Taylor, IE J. Davis, NMSS - -
H. Thompson, NRR ..
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U 4C L O 5 0ild 1 PHILADELPHIA ELECTRIC COMPANY -
2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (21s)sas so2o "i* U."."
April 2, 1985 Re: Docket Nos. 50-352 t 50-353 Mr. Richard W. Starostecki, Director Division of Projects and Resident Programs U. S. Nuclear Regulatory Commission -
Region I 631 Park Avenue King of Prussia, Pa. 19406
Dear Mr. Starostecki:
SUBJECT:
Reportable Events at Limerick Generating Station
REFERENCES:
- 1) R. W. Starostecki letter to S. L. Daltroff, dated February 11, 1985; Re: Inspection Report No. 50-352/
84-65 and 50-353/84-14.
- 2) M. J. Cooney Letter to R. W. Starostecki dated February 11, 1985; Re: Response to Reference 1. ..
Your letter of January 11, 1985, reference 1, contained -
an item of concern with regard to the number of personnel errors which you felt may be indicative of an adverse trend. You 2 further pointed out that, although these errors have not resulted -
in any immediate safety problems, the matter warrants management -
attention on the part of Philadelphia Electric Company. Our response to this concern was contained in reference 2.
- Philadelphia Electric Company senior management met with NRC Region I staff on February 22, 1985 to discuss Philadelphia Electric Company's investigations and corrective action programs to minimize future reportable events, in particular personnel errors. The remainder of this letter describes those programs.
The details of the programs were presented to you at the meeting on February 22, 1985. Philadelphia Electric Company believes that these-corr.ective action programs have been effective in
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y.r'. Richard W. Starostocki Page 2 reducing the number of rcportable events as evidenced by the reduction that has occurred over the last few weeks.
Recognition of LER Trend In late November,1984, the Station Superintendent became concerned with the adverse trend in reportable events, particularly those involving personnel error. Although the station staff was involved in investigating these reportable events and identifying the appropriate corrective actions to prevent recurrence, he requested that the Nuclear Safety Section's Limerick Independent Safety Engineering Group (ISEG) evaluate these reportable events and develop corrective action recommendations to address common root causes.
Senior management was advised of the adverse trends.
The number of Suspected Licensee Event Reports (SLERs) was reported weekly beginning in early December to the Vice President
- Electric Production Department and to the Senior Vice President
- Nuclear Power. It also was reported by the Station ISuperin,tendent to the Nuclear Review Board (NRB) at its meeting on December 14, 1984. The NRB Chairman requested that the analysis performed on SLERS by the Nuclear Safety Section's Limerick ISEG be presented to the Nuclear Review Board.
Independent Safety Engineering Group Investigation '
One of the Limerick ISEG's functions is to examine i
Licensee Event Reporrs (LER's) and other design and operating experience information in order to identify areas for improving ,,
safety and to provide independent verification that activities are performed correctly and that human errors are reduced as much as practical.
investigate eachASLER. list of 37 questions was developed to Thfs list was developed out of a list of 70 questions contained in " Human Error Reporting Forms" developed by the Institute of Nuclear Power Operations in 1982 as a pilot program to investigate human errors. All SLER's from the time of receipt these 37ofquestions. the license to the end of 1984 were examined using Each event was examined to determine root cause, and these root causes were classified in a system consistent with the LER reporting guidance from the NRC.
However, for each of the 5 major cause categories (personnel error, design manufacturing construction / _ustallation deficiency, external causes, procedure deficiency and other) subcategories were of errors, developeddeficiencies in order andtocauses.
provide better trending of the types These major categories and i
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l subcategories are consistent with the cause codes contained in a tracking and trending program being developed for application at Limerick and at Peach Bottom. This Quality Assurance Tracking ,
and Trending ' System is in the process of being computerized and ;
implemented.
The analysis performed by the Limerick ISEG was _
submitted to the Limerick Plant Operating Review Committee and to the Nuclear Review Board for its review. The attachment to our letter to you on February 11, 1985 (reference 2) provided a breakdown of SLER's in accordance with the categories and subcategories of the causes, and a detailed breakdown of the
, actual causes within each one of the subcategories. This attachment was an update of the tables in the ISEG report l presented to the Plant Operating Review Committee and the Nuclear Review Board. At the meeting of February 22, 1985, an updated listing of the cause of personnel errors and a detailed breakdown of these personnel errors were discussed. This update is provided as Attachment 1 to this letter.
Included.in the Limerick ISEG analysis were 8 -
recommendations. -!These recommendations and the status of their r
implementation we're discussed at the February 22, 1985 meeting.
Attachment 2 to this letter contains a listing of those recommendations and the status of their implementation.
6 The Limerick ISEG analysis is based on SLER's. Upon further investigation by plant staff, an SLER may be determined to be not reportable as an LER. Thus, the numbers of personnel errors and the numbers of other types of deficiencies identified" l in the Limerick ISEG's analysis and summaries do not correspond with the number of LER's submitted. ,
2 At the time of the meeting on February _ 22, 1985, 57 .
- LER's had been submitted. Of these, 23 were classified as '
personnel errors. The ISEG's analysis agreed on 18 of the 23 '
classified as personnel error. The five other events the ISEG classified as either design deficiencies or procedural deficiencies. At the time of the meeting an additional 13 SLER's had occurred. The Limerick ISEG's investigation of these SLER's identified 3 with personnel errors. Of the 21 personnel errors, as classified by the Limerick ISEG, 8 involved licensed operators, 4 involved unlicensed operators, 1 involved a
. chemistry supervisor, 1 involved a maintenance worker and 7 involved I&O technicians. Seventeen of the personnel errors
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, Mr. Richard W. Starostecki y..,, Page 4 t
involved workers, and the other 4 per'sonnel errors involved first level supervision. There has not been total agreement between the Limerick ISEG's classification of root causes and the classification reported in the LER. The' variation is about 10%.'
We believe this is healthy and causes close examination of the root causes where differences appear. These differences also ;
illustrate the independence of the Limerick ISEG's views. !
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l Following a presentation of the Limerick ISEG's analysis to the Nuclear Review Board at its meeting on January 15, 1985, Philadelphia Electric Company management requested that the
- Nuclear Safety Section examine the significance of the LER's.
This examination, which was reported at the February 22, 1985 meeting, revealed the following.
Conservative Reporting o Three of the 57 LER's submitted occurred during initial conduct of surveillance testing, and a rationalization could have been made that these events were anticipated, and thus were not reportable because these tests were attempting to prove the initial operability of systems.
o Each reportable event has been reported as a single LER.
Examination of LER's submitted by other utilities reveals that one LER might describe several reportable evente associated with one plant upset.
New LER Rule ~
'o ' Thirty-nine of the 57 LER's submitted involved actuation of emergency safeguard features (prior to the new LER '
rule, which went into effect January 1, 1984, emergency ,
safeguard feature actuations were not reportable).
Actuation of emergency safeguard features does not '
degrade system performance. It merely provides confirmation that the system performs as designed.
o Eleven of the 39 LER's discus
- sed above, involving emergency safeguard feature actuations, involved personnel errors.
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- J!r.' Richard W. Starostecki Page 5
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Seriousness of Reportable Events o No event resulted in serious degradation of safety barriers.
o No event resulted in'the inability to:
- shutdown the reactor and maintain it in a -
safe shutdown condition
{ . - remove residual heat i
- control release of radioactivity
- mitigate the consequences of an accident.
Corrective Action Program The corrective action programs have addressed 3 areas:
- 1) modifications to eliminate recurring design deficiencies, 2) .
actions to address personnel errors, and 3) programmatic i,mprovements.
- 1) Design, Manufacturing, Construction / Installation Deficiencies Of.the 57 LER's submitted as of February 22, 1985, 23 had been classified as design, manufacturing, construction /
installation deficiencies. Six of these LER's were associated with Riley temperature switches inadvertently causing actuation of emersency safeguard features. Five of the LER's were associated with the breaking of tapes on chlorine detectors.
Three LER's were associated with the reactor enclosure
, differential pressure sensors being too sensitive to gusts of --
l wind. Three of the LER's were associated with ccmmon process and reference leg valving disturbances. These recurring design deficiencies were identified in the ISEG analysis and were the l subject of ISEG's recommendations. Three of these LER's were *
, associated with reactor protection system static inverters.
Deficiencies associated with these static inverters are being addressed by assuring internal components within the RPS inverter" cabinets are secure and by changing the source of the AC power supply to the RPS inverter to a power supply whose voitage levels i
are more stable than the previous power supply. A two week outage in early February permitted many modifications to be performed to eliminate these recurring design deficiencies.
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- 2) Personnel Errors Corrective actions with regard to personnel errors were accomplished through the following activities.
o Plant personnel were informed, via letters and group meetings, of the importance of following procedures and administrative controls and keeping shif t supervision informed of work being performed. In addition, plant I personnel were told they must take sufficient time to properly evaluate and perform tasks independently of schedule needs.
o Simulator training was augmented with feedback from a reportable event in which the cooldown rate of the -
reactor exceeded the technical specification rate. The simulator's logic for simulating cooldown of the reactor following a plant scram assumes normal decay heat levels. Operators had not received training with regard '
to reactor cooldown rate when sufficient quantities of i
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decay heat are not present, such as during initial. plant startup. The simulator training program has been
. changed to incorporate this experience.
o Requalification training for Senior Licensed Operators and Licensed Operators has begun to emphasize the final version of the Technical Specifications as issued with the Limerick 5% power license and to address the LER's that have occurred at Limerick. Many of the Senior Licensed Operators and licensed operators went through initial licensing training and examination without the ~
benefit of the Limerick 5% power license Technical Specifications since these Technical Specifications were issued just prior to the commencement of fuel loading. .
3 o Phase 2 training, as delineated in the Final Safety Analysis Report, is now completed for non-licensed .
operators. Non-licensed operators are now participating" in a continuing training program.
o Philadelphia Electric Company's disciplinary policy has been applied to individuals when deemed appropriate by the Limerick Station Superintendent. The basic i objective of any disciplinary action in Philadelphia Electric Company is corrective rather than punitive. It is to make the employee's aware that their actions are ,
improper and that, if not corrected, their future with l l
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Mr." Richard W. Starostocki Page 7 our company will be in jeopardy. Whenever a decision is made to take disciplinary action, many factors, such as the nature of the offense, the employees past record, and other variables must be taken into consideration.
The implementation of this objective is a discipline policy followed throughbut Philadelphia Electric Company based on the principle of progressive discipline in which repeated minor offenses are dealt with _
increasingly severe measures and in which serious offenses are dealt with more severely at the outset.
There are six steps in this disciplinary process. !
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- 1. Counseling i
- 2. Oral warning
- 3. Written warning
- 4. Reprimand ,
- 5. Suspension ,
- 6. Suspension with possible recommendation !
for termination j
2 The disciplinary actions taken with regard to employees !
involved in personnel errors at Limerick Generating Station have been to step 1, counseling, for all cases 1 but one, in which step 2, an oral warning, was provided.
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- o. An Operator Excellence Program was established in order to bring to the attention of all plant personnel the importance of minimizing reportable events, particularly reportable events associated with personnel error. This program also has as an objective the establishment of competition among groups at the station in order to see ~
which group would have the fewest errors. The group with the fewest errors would be provided some type of award. This is a one time program designed to immediately tackle the problem of personnel errors. It -
will subsequently be replaced with a program aimed at improving the professionalism of plant personnel. This ,
professionalism program is in the early stages of -
development, but its goal is to improve operations through pride and excellence.
- 3) Programmatic Improvements .
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. Mr. Richard W. Starostecki Page 8 The programmatic improvements instituted by the Station Superintendent include the following.
o A senior plant staff member has been assigned to personally investigate the cause of all SLERs. This investigation is to identify promptly the corrective actions that need to be implemented and to bring this information to the attention of the senior plant staff.
(The Limerick ISEG's investigation of these SLERs ~
remains independent of this senior staff plant member's investigation.) ,-
o The Plant Operating Review Committee is now reviewing the SLER's shortly after they occur in order to provide input as to the corrective actions and to judge whether proposed corrective actions are sufficient to prevent recurrence. ,
o A new procedure has been instituted which requires an operator to perform a daily check of the control room panels in order to determine if there are any readings or indications outside of Technical Specification
, requirements.
o A study was performed over several days by station staff as to the number of people in the control room during 4 each hour of the day. This study revealed that the
. number of people in the control room varied, with peaks occurring in late morning and early afternoon. The Station Superintendent has determined that the absolute numbers of these peaks are unacceptable and unnecessary.
The shift supervisors and shift superintendents have been instructed to control access to the control room. ~
. In addition, certain areas in the control room have been designated off limits for unauthorized personnel. Lines on the floor and rope barriers identify these areas. -
o A member of the plant staff performs a detailed review of control room logs several times a week to check if -
1 all actions that have been taken are in compliance with. I procedures and Technical Specficiations.
Results of Corrective Action Program There has been one reportable personnel error to date since the beginning of February,1985; however, there have been several LER's classified as design, manufacturing, construction / installation deficiencies, several classified as'
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. Mr'. Richard W. Starostecki Page 9 procedural deficiencies, and several classified as other deficiencies. Philadelphia Electric Company believes the i corrective action programs have halted the adverse trend in !
personnel errors. We expect that more design, manufacturing, construction / installation deficiencies and some procedural deficiencies will be uncovered and corrected during startup testing. We believe this is one of the objectives of the startup testing program.
V ,,t r y yours, I
Attachments cc: J. T. Wiggins, Resident Site Inspector See Attached Service List 99 9
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LIMERICK-ISEG.EVALDATION OF REPORTABLE PERSONNEL ERRORS
. . TABLE 1 - CADSES OF INCIDENTS 10/26/84 01/01/85 CauseJ to 12/31/84 to 02/16/85 Code Category Number Number A. PERSONNEL ERROR 16 7 (total) -(total)
A-1 Failure to follow procedures, rules, regulations............................... 5 1 A-2 Failure to use correct proceduro.......... -
A-3 Failure to properly identify equipment.... - -
A-4 Failure to properly commun'icate........... -
1 A-5 Failure to observe changing conditions.... 2 -
A-6 Failure to properly interpret information, results...................... 4 -
A-7 Failure to perform required inspections / tests......................... 4 -
AS U Failure to properly assess consequences of actions................... -
4 A-9 Other personnel errors.................... 1 -
' TABLE 2 - DETAILED BREAKDOWN OF CAUSES A. Personnel Error....................................., (22 total)
A-1: Failure to follow procedure, rules, regulations...... (7)
, a) Failure to notify shift before working. ......... (2) i b). Procedure not followed. ......................... ('3) l c) RWCU isolation while swapping.demineralizers. ... (1)
I d) Failure to comply with Tech. Spec.. time limits. . (1) l A-4: Failure to properly communicate...................... (1) -
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A-5: Failure to observe changing conditions. ........ ....
(2) -
A-6: Failure to properly interpret information............ (4)
A-7: Failure to perform required inspections / tests........ (4) a) Failure to properly follow j
Technical Specifications. ....................... (3) b) Incorrect evalua. tion of test results. ...........
(1) ,
A-8: Failure to properly assess consequences of actions. . (4) a) Fire doors left open. ........................... (1) b) Did not check Technical Specifications while working on EPCI pressure transmitters...... (1) -
.. c) Opened equalizing valve on refuel floor low Delta P Sensor. ............................. (1) d) Reactor Enclosure low Delta P isolation.......... (1) t asa
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, LIMERICK ISEG RECOMMENDATIONS AND STATUS
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- ~ 1. - Continue to pursue the resolution of instrumentation problems associated with common instrument process and reference legs.
Support work for permanent head chambers worked l during last orta7e. Work to be continued during future outact ps;iods until complete.
i Use of portable head chambers is an adequate
, interim solution.
, 2. Continue to pursue the resolution of problems associated with Riley temperature switches in the Reactor Water Clean-Up System -
portion of the Steam Leak Detection System. The investigation in
,, progress should be expedited to install necessary modifications as soon as possible, ie. , before low power testing is completed.
Modification completed to. correct problem.
- 3. Complete flow balancing on the Refuel Floor HVAC. This should resolve the low differential pressure problems on this system.
Deferred to refueling outage. Not presently part
! of secondary containment. Should not have been
- reported. .
- 4. Engineering should investigate the low differential pressure problems on the. Reactor Enclosure EVAC System that appear to be caused by outside wind effects on the outside air pressure sensors. Interim administrative controls should not be allowed to become the permanent solution. -
Modification completed to correct problem.
- 5. Engineering should investigate the problem of breaking sample tapes on the Chlorine Detectors in the Control Enclosure HVAC System.
This has been responsible for at least five main control l i room isolations during the period of this study, and several ether I alarms. This is an unacceptably high frequency for an operating plant and a permanent solution should be expedited.
Increaspd surveillance by dedicated techniciah reduceddfrequency of occurance to manageable ,
levels. Engineering solution.still bepng ,
investigated.
- 6. Emphasize to all plant staff, contractor, and vendor personnel that Shift Supervision must be informed of' all work to be performed on plant equipment.
Recommended action completed.
- 7. Re-emphasize to all plant personnel that all procedures and administrative controls must be followed.
Recommended action complered.
- 8. Review, as time permits , c. heck-of f lists for all' systems which have technical specifications for operability.
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- Enclosure 2 i s LIMERICK LERs s
. OCTOBER 26, 1984 through MAY 7, 1985 11/84* 12/84 1/85 2/85 3/85 4/85 5/85**
TOTAL EVENTS FOR MONTH _ 22 21 22 5 13 8 3 4 ;.
PERSONNEL ERRORS - TOTAL IQ $ ' 12 0 1 1
- 2 Barc Technician 5 4 7 0 2 1 2 Opera tor . 4 0 1 0 0 0 0 other 1 0 4 0 3 2 0 i
TECH SPEC RELATED - TOTAL 6 1 h 9 2 Q Q l' Procedure Error 3 1 3 0 2 0 Misunderstood TS/LCO 2 0 l' 3 - 1 0 0 0 0 l
I EQUIPMENT FAILURE - TOTAL 1 10 h $ h 1 J f RWCU isolation " Read" 0 5 1 1 0 0 0 Switch Spurious Signal Control Room Vent isolation 2 3 0 0 3 1 )
- Chlorine Analyzer Tape Break s '
othr 3 2 3 3 1 2 0 ,
MISCELLANEOUS 1 4 2 1 2 2 0 (0.g., Reactor Building isolation Due to High Winds) 4 Notes:
- 3 LERs with event dates during October 26 - 31, 1984 are includete in November date
- Through May 7, 1985 i'
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