ML20150B297
| ML20150B297 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/07/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20150B299 | List: |
| References | |
| NUDOCS 8807110464 | |
| Download: ML20150B297 (3) | |
See also: IR 05000352/1987099
Text
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47 JUL 1988
Docket No. 50-352/NPF-39
Philadelphia Electric Company
ATTN: - Mr. C. A. >kNeill
-Executive Vice President-
Nuclear
2301 Market Streer
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject: Sys+.ematic Assessment of Licensee Performance (SALP) Board Report
Number 50-352/87-99
- An NRC SALP bled has reviewed and evaluated the performance of activities at
the Limerick Gederating Station for the period of February 1,1987 through
April 30, 1988. The results of this assessment are documented in the enclosed
SALP Board Report. We will contact you soon to schedule a meeting to discuss
the SALP evaluation.
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At the SALP meetitg you should be prepared to discuss our assessments and your
plans to improve performance. The meet' g is intended to be a candid dialogue
wherein any comments you may have regarding our report are discussed.
Additionally, you may provide written comments within 20 days after the
meeting.
Your cooperation with us is appreciated.
Sincerely,
Originni Signed 37
ELIM T. P.US3M
William T. Russell
Regional Administrator
Enclosure: SALP Board Report No. 50-352/87-99
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88071104648%7h2ADOCK O
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PNV
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0FFICIAL RECORD COPY SALP LIM 1 87-99 - 0001.0.0
11/29/80
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. Philadelphia Electric Company 2
07 JUL 1988
cc w/ enc 1:
John S. Kemper, Sr., Senior Vice President - Nuclear
E. C. Kistner, Chairman, Nuclear Review Board
Graham M. Leitch, Vice President, Limerick Generating Station
J. W. Gallagher, Vice President - Nuclear Services
Troy B. Conner, Jr. , Esquire
Eugene J. Bradley, Esquire, Assistant General Counsel
W. M. Alden, Director, Licensing Section -
Dave Honan
K. Abraham, PA0 (13)
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
Chairman Zech
Commissioner Roberts
Commissioner Carr
Commissioner Rogers
bcc w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
Robert J. Bores, DRSS
Region I SLO
W. Johnston, DRS
G. Sjoblom, DRSS
J. Taylor, DED0
W. Russell
J. Allan
J. Lieberman, OE
D. Holody
Board Members
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RI:DRP RI:DRP RI:DRP R RA :RA
- Gramm/rhl * Wenzinger *Kane A lan Russell
6/ /88 6/ /88 6/ /88 y/h/88 f/ /88
- See previous concurrences
0FFICIAL RECORD COPY SALP LIM 1 87-99 - 0001.1.0
07/05/88
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Philadelphia Electric Company 2
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sc w/ enc 1:
John S. Kemper, Sr., Senior Vice President - Nuclear g
E. C. Kistner, Chairman, Nuclear Review Board
Graham M. Leitch, Vice President, Limerick Generating Station
J. W. Gallagher, Vice President - Nuclear
Troy B. Conner, Jr., Esquire
Eugene J. Bradley, Esquire, Assistant General Counsel
W. M. Alden, Director, Licensing Section
Dave Honan
X. Abraham, PA0 (13)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
Chairman Zech
Commissioner Roberts
Commissioner Carr
Commissioner Rogers
bcc w/enci:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
Robert J. Bores, DRSS
Region I SLO
W. Johnston, DRS
G. Sjoblom, DRSS
J. Taylor, DEDO
W. Russell
J. Allan
J. Lieberman, OE
D. Holody
Board Members
H. Eichenholz
1
RI:D F !9 RI:DRA RI:RA
Gramm/rhl k nger K Allan Russell
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6/Jd/88 / /88 1 1/$/88 6/ /38 6/ /88
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ENCLOSURE
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NO. 50-352/87-99
PHILADELPHIA ELECTRIC COMPANI
LIMERICK GENERATING STATION
UNIT 1
ASSESSMENT PERIOD: FEBRUARY 1, 1987 - APRIL 30, 1988
BOARD MEETING DATE: JUNE 8,1988
8807110470 880707
DR ADOCK 050 2
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TABLE OF CONTENTS
Page
I. INTRODUCTION ...... ................. 3
A. Purpose and Overview . . . . . . . . . . . . . . . . . 3
B. SALP Board Members . . . . . . . . . . . . . . . . . . 4
II. CRITERIA ..... . ................... 5
III. SUMMARY OF RESULTS . ................... 6
A. Overall Evaluation . ................. 6
B. Background Activities. . . . . . . . . . . . . . . . 7
1. Licensee. . . . . . . . . . . . . . . . . . . . . 7
2. Inspection. . .................. 9
C. Performance Summary. . ........ ....... 10
D. Unplanned Shutdowns, Scrams and Forced Outages . . . . 11
IV. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . 13
A. Plant Operations . . . . . . . . . . . . , , . . . . . 13
B. Radiological Controls ................ 16
C. Maintenance .... ................. 20
D. Surveillance . .. .................. 24
E. Engineering / Technical Support. ............ 27
F. Emergency Preparedness . . . . . . . . . . . . . . . . 31
G. Security and Safeguard: ...........,... 33
H. Safety Assessment / Quality Verification . . ...... 36
V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . 39
A. Investigations and A11egaticns . . . . . . . .... 39
8. Escalated Enforcement Actions ............ 39
C. Management Conferences . . . . ............ 39
D. Licensee Event Reports . . . . ............ 39
1. Report Quality. .............. .. 39
2. Causal Analysis . ................ 40
Tables
Table 1 - Inspection Hours Summary ................. 43
T&ble 2 - Enforcement Summary . . .................. 44
Table 3 - Licensee Event Reports .................. 45
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I. INTRODUCTION
A. Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an ~
integrated NRC staff effort to collect observations and data on a
periodic basis and to evaluate licensee performance. The SALP pro-
cess is supplemental to normal regulatory processes used to ensure
compliance to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating
NRC resources and to provide meaningful guidance to the licensee's
manacement to improve the quality and safety of plant operations.
An NRC SALP Board, composed of the staff members listed in Section B,
met on June 8, 1988 to review the collection of performance observa-
tions and data to assess the licensee's performance at the Limerick
Generating Station Unit 1. This assessment was conducted in accor-
dance with the guidance in NRC Manual Chapter 0516, "Systematic
Assessment of Licensee Performance." A summary of the guidance and
evaluation criteria is provided in Section 11 of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Limerick Generating Station Unit 1 for the period
February 1, 1987 through April 30, 1988. The summary findings and
totals reflect a 15-month assessment period.
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B. SALP Board Members
Chairman
W. F. Kane, Director, Division of Reactor Projects (DRP),
Members
W. Johnson, Director, Division of Reactor Safety
G. Sjoblom, Acting Director, Division of Radiation Safety and
Safeguards
W. Butler, Director, Projects Directorate I-2, NRR
R. Capra, Acting Chief, Projects Branch No. 2, DRP-
R. Gallo, Chief, Operations Branch, DRS
S. Collins, Deputy Director, DRP (Part Time)
E. Kelly, Chief, Technical Support Section, DRP
J. Linvillo, Chiof, Projects Section 2A, DRP
R. Clark, Project Manager, NRR
Others
T. Kenny, Senior Resident Inspector, Limerick Unit 1
L. Scholl, Resident Inspector, Limerick Unit 1
R. Gramm, Senior Resident Inspector, Limerick Unit 2
T. Johnson, Senior Resident Inspector, Feach Dottom
J. Williams, Project Engineer, DRP
J. Gadzala, Reactor Engineer, DRP
W. Pasciak, Chief, Effluents Radiation Protection Section, DRSS
T. Dragoun, Senior Radiation Specialist
R. Summ2rs Emergency Responsive Coordinator, DRSS
R. Keimig, Chief, Security and Safeguards Section, DRS
H. Gregg, Senior Reactor Engineer, DRS
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II. CRITERIA
Licenseo performance is assessed in selected functional areas. Each
functional area represents areas significant to nuclear safety and
the environment, and are normal programmatic areas. The following
evaluation criteria were used as appropriate to assess each '
functional area.
l. Management involvement in assuring quality
2. Approach to resolution of technical issues from a safety standpoint
3. Responsiveness to NRC initiatives
4. Enforcement history
5. Reporting, analysis and corrective actions for operational events.
6. Staffing (including management)
7. Training effectiveness and qualification programs
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Based upon the SALP Board assessment each' *ianctional area evaluated
is classified into one of these performance categories. The definitions
of these performance categories are:
Cate_ gory 1. Reduced NRC attention may be appropriate. Licensee
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management attention and involvement are aggressive and oriented
toward nuclear safety; licensee resources are ample and effectively
used so C'at a high level of performance with respect to operational
safety is aeing achieved.
Category 2 NRC attention should b; maintained at-normal levels.
Licensee ranagement attention and involvement are evident and
conce.ner with nuclear safety; licensee resources are adequate and
reason'aly effective such that satisfactory performance with respect
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to operational safety is being achieved.
Category 3. Both NRC and licensee attention should be ine-eased.
Licensee management attention or involvement is acceptable and
considers nuclear safety, but weaknesses are evident; licensee
resources appear strained or not effectively used so that minimally
satisfactory performance with respect to operational safety is being
achieved.
Trend: The SALP Board may dacide to include an appraisal of the
performanca trend of a functional area. Normally, this ti end
will only be used when both a definite trend of performance is
discernible to the Board, and the Board believes that
contir.vation of the trend will result in a change of performance
level.
Improv jin : Licen.see performance was determined to be improving
near the close of the assessment period.
Declini_ng: 1.icensee performance was determined to be declining i
near the close of the assessment period. !
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III. SUMMARY OF REST ' s
A. Oveiall Evalui ,
During the asse- .t period site performance has remained strong
despite additio... pressure associated with a major corporate reorgani-
zation. Site ranagement has been very effective in providing the
leade.- ship necessary te achieve this per'ormance, to maintain good
morale and to fo ,ter a strong safety perspective throughout the site
organization. The completion cf the reversal in oerformance in the
security area of two SALP periods ago, resulting in excellent
performance in the security area during the current assessment
period, is the result of strong site management with support from
corporate management.
While co: 2 rate support was evident for the security crea, in other
areas se:n as engineering and technical support, and emergency
preparedness inef fective c.orporate oversight and support has resulted
in a decline in performance. In the area of energency preparednes>
lack of corporate accountability and oversight extends back into the
previous assessment period. While the reorganization has resulted in
enhancements in oversight functions associated with the offsite Nuclear
Review Board and the unification of the previously fragmented quality
organization, further corporate management attention appears to be
necessary to assure accountability from corporate A.pport groups.
Strong performance has continued in plant operations, radiological
controls, maintenance and surveillance. In opera tions a strong team
of operators, operations roanagement, technical support and site
managers have produced a safe operating record. In spite of an
unanticipated outage extension, ALARA performance was effective and
total radiation exposures compared favorably with other newly licensed
BWRs this period. Corporate support for the radiological environ-
mental monitoring wus de.nonstrated in that activities in this area
were effectively carried out by contractors. Improvements are
evident in the site management of maintenance work backlogs and
control of contractors. Deficiencies in maintenance procedures are
being correcteJ and the conduct of maintenance and surveillar.ce is
typified by strict adherence to procedures. Safety review committees
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are used effectively.
Site management and supervision have been effective in maintaining a
positive attitude of teamwork at all levels of the orgcnization.
This is considered to be the principal factor in the continuation of
the overall strong performance exhibiter' in prior SAlP periods.
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B. Background Activities
1. Licensee
Unit 1 completed a 198-day continuous power run at the end of
the previous assessment, followed by a controlled shutdown to
repair three valves that were contributing to drywell leakage.
The unit began the assessment period at full power and remained
at _ power for the next three and a half months in an end-of-cycle
coastdown mode of operation towards the first refueling outage
which began on May 15, 1987.
The first Unit I refueling outage lasted 108 days. Major
activities consisted of: full core offload for refueling and
core alterations; a containment integrated leak rate test;
license condition modifications including tie-in of the standby
gas treatment system to the refueling floor; major cnrrective
maintenance to 20 control rod drives, rebuilding of feedwater
valves, the replacement of all 14 main steam safety relief
valves, and extensive preventive maintenance including tear-down
and overhaul of Reacter Core Isolation Cooling, (RCIC), all four
diesel generators and the main generator and turbine.
Startup from the outage began on August 26 and, following minor
repairs to High Pressure Coolant Injection (HPCI) steam supply
valves, the main generator was synchronized to the grid on
August 31. Power ascension occurred over the period September 1
through 7 to 83% power. An automatic scram occurred on
September 7 due to a turbine trip on high water level in a
moisture separator because of an isolated instrument air supply
to the moisture separator level centrols. Recovery from the
scram began the following day and full power was achieved by
September 17. Full power operation cont:nued for approximately
five days until an automatic scram occurred on September 19, due
to a turbine trip caused by rupture of a weld on an electre-
hydraulic control (EHC) system line to a main turbine control
., valve.
Recovery from the September 19 scram began the following day,
but the unit remained at 85% power for the foi:ow~;g two months
until November 21 while investigations proceeded to a solution
for the turbine EHC system vibrations. On November 21, 1987,
Unit I was returned to full power.
Full power operation continued for 126 consecutive days until a
fuel cladding leak was discovered on March 25, 1988 as evidenced
by increased steam jet air ejector radiation levels. The
licensee suspected the leak to be a form of crud-induced
localized corrosion. No detectable increase in offgas releases
was experienced, although coolant radioiodine activities
increased by a factor of about ten. Reactor power was
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maini:ained below 85% as a precautionary measure for the next
two weeks until a planned shutdown was begun on April 8
following 195 consecutive days at power since September 19,
1987.
The planned outage lasted 10 days and was for condenser tube
cleaning and circulating water system improvements. Feedwater
valve repairs, Intermediate Range Monitor (!RM) replacements and
several modifications were also accomplished. Unit 1 was
returned to power on April 22. At the end of the assessment
period Unit I was operating at reduced power because of the feel
leak.
Organizational changes at the station level and at corporate
occurred throughout the assessment, including reassignment of
the station manager to Peach Bottom and announcement of a new
station manager on January 1, 1988. The prospective station
manager remained in a special license familiarization training
program through the end of this assessment period, and is
expected to assume the duties of Limerick Unit 1 Station Manager
in August 1988.
The licensee announced a major corporate reorganization of the
company's Nuclear Operations and Support Services which became
ef fective or November 1,1987. Changes included creation of: a
Vice President for the Limerick Station, assumed by the former
Unit 1 Plant Manager; torporate Vice Presidents for r,ewly formed
Divisions of Nuclear Services and Nuclear Engineering; and a
Senior Vice President, Nuclear. The reorganization also involved
recenstituting the Nuclear Review Board (NRB) to include member-
ship of three senior executives outside of PEco. The sita
oroanizations operated in c transition for the latter part of
.-is assessment. The Vice President of Limerick remained in an
ace J station manager position tnrough the end of the assessment
period.
On February 2, 1988, the President and Chief Operating O'(icer
announced his retirement effective Maren 1, 1988. On February
16, 1988, a new Executive Director Nuclear from outside the
PECo organization was announced who subsequently
became a PECo employee and assumed the title of Executive Vice
President Nuclear on March 13, 1988. The company's Cnairman and
Chief Executive Officer announced his retirement effective April
13, the date of the licensee's annual board meeting. The Bot.,f of
Directors elected a new Chairman and Chief Executive Officer,
a former PECo Vice President who had recently been ?lected
President and Chief Operating Officer at another utility.
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2. Inspection
Two NRC resident inspectors were assigned to the site during the
assessment period. A new resident inspector was assigned in
December 1987 and a new senior resident in March 1988. The
total NRC inspection time expended during the 15 month assess-
ment period was 4,032 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> or 3,226 hours0.00262 days <br />0.0628 hours <br />3.736772e-4 weeks <br />8.5993e-5 months <br /> on an annualized
basis. Distribution of these hours by functional area is
depicted in Table 1. A summary of enforcement activities is
provided in Table 2.
During this assessment perioJ, the second year of commercial
operat.ons was reviewed as well as the Unit 1 initial refueling
outage. NRC inspec' ion teams evaluated restart from the
refueling outage in August 1987, the environmental qualification
programs in February 1988 and an emergency preparedness exercise
on April 6, 1988.
This report includes evaluation of Safety Assessment / Quality
Verification as a new functional area. The topics assessed in
this new area include Licensing activities as well as what
was formerly covered under the Assurance of Quality. Also,
Training and Qualifications is no longer a separate functional
area and is included.
Refueling activities were evaluated as part of the Er.gineering/
Technical Support . functional area for the first time during this
assessment period. Fire protection is assessed, ao in previous
assessments, in the functional area of Operations, since there
was no special programmatic inspection in this area. House-
keeping is irciaded in the area of maintenance. Security
concinued to receive increased inspection effort, as in previous
assessments, because of past identified weaknesses.
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C. Performance Summa _ry
Functional Category Category
Area last Period Ttis Period
(2/1/86 - 1/31/87) (2/175, - 4/55788)
'A. Plart
Operations 1 1
B. Radiological
Controls 1 1
C. Maintenance 1 1
D. Surveillance 1 1
E. Engineering / Technical 1 2
Support
F. Emergency
Preparedness 1 2
G. Security and
Safeguards 2 1
H. Safety Assessment /
Quality Verification 1
I. Training & Quali-
fication Effectiveness
1
J. Licensing Activities 2 ***
K. Assurance of Quality 1
- Not evaluated as a separate functional area last period
- Criterien for all functional areas, and no longer a separate area
- Now evaluated under Safety Assessmer.t
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D. Unplanned Shutdowns, Scrams and Forced Outages
Date & Root Functional
Power Level Description Cause Area
6/12/88 Defueled Reactor scram signal Inedequate Operations
during refuel outage procedure
with core offloaded due compounded
to radiography in by blocking
the vicinity of the deficiency
radiation monitors.
9/7/87 83% Automatic scram upon Drawing did Engineering
closure of the turbine not include
stop valves caused by individual
high level in a moisture tag nos. for
separator. Instrument instrument air
air valve was not root valves
properly positioned.
9/19/87 90% Automatic scram due to EHC weid Engineering
a main turbine trip failure induced
caused by the failure by new load due
of a pipe weld in the to EHC modift-
turbine electrohydraulic cations
control system. A leak
at the failed weld was
discovered and & plant
shutdown from full
power was in progress at
the time o) the scram.
4/9/88 <1% Automatic scram due to Personnel Operations
a high flux trip while error
power was in the inter-
mediate range during a
planned shutdown. A
half scram had been ,
manually inserted due
to IRM inoperability
and when power increased
due to moderator tempera-
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ture decrease a trip signal
l was generated by the 'C'
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(IRM) while set on range 2.
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Date &- Root Functional
Power Level Description Cause Area
4/9/88 0% Auton.atic Scram While
in cold shutdown Component N/A
an upscale spike failtire
occurred on the 'F'
channel IRM (Range 1)
due to the failure of
the detector. This
spike in conjunction
with a manually inserted
half scram (due to
inoperable IRMs) caused
a full scram. All rods
were fully inserted at
the time of the scram
thus no rod motion occurred.
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IV. PERFORMANCE ANALYSIS
A. flant Operations (1191 hours0.0138 days <br />0.331 hours <br />0.00197 weeks <br />4.531755e-4 months <br />; 29%)
Analysis
This area was rated Category.1 in the previous two assessments, with
a decreasing number of reportable events attributable to operator
error, low scram rates and good safety attitudes exhibited by the
operating staff. Exceptions were found in the management of fire
protection activities. Improvements were noted in the reduction of
unnecessary alarms and improved control room access controls.
During this assessment period the shift superintendent is a recog-
nized part of the station's management structure and the responsi-
bility vested in this role is evident by their visible leadership, a
l key in the achievement of a successful operating team not exclusively
l limited to operations personnel. Two new shift superintendents were
selected during this pericd as a result of a rigorous selection process
whereby promotions are peer-evaluated and are not solely the result
of seniority.
The licensee has placed a high priority on the perception and
attitudes of licensed operators. Operator feedback is of paramount
importance as evidenced by the shift superintendents' regular
briefing to Nuclear Review Board (NRB), the plant ir.cident review
committees, and the shift update notebook. Training has been pro-
vided to prepare operators to better deal with shift work such that
attentiveness is maximized and good morale is maintained.
Management's efforts have instilled a philosophy of safe operation.
One scram occurred because an operator did not react to IRM signals
during an full rod insertion shutdown for the 10-day condenser
outage. rograms devised to prevent scrams include color-coded
instrument panels in the auxiliary equipment room; A-day /B-day
surveillance test schedules; and a rigorous process for operational
condition change POI review.
l Access controls continued to be effective in limitine nonessential
l- personnel and noise in the main control room. However, due to the
design of Limerick's control room (common to both units), this is
still a concern because of Unit 2 construction and testing activities
which the licensee has recognized and continues to underscore in
shift meetings and turnovers.
L Communication techniques have been refined using administrative
guidelines, so that a marked reduction in reportable events attri-
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buted to breakdowns in communications is evident. Communications
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among the plant staff have been enhanced by publication of reports of
routine meetings and by tracking issues to completion through a
clearly accountable individual. Turnover between shift superinten-
dents is thorough. The shift superintendent is aided by detailed
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logkeeping and the use of a' marker to track operating problems. As a
result,-the status and disposition of all problems that develop
during the shift are addressed during shift turnover.
Extra licensed expertise was staffed for Unit 1 operation throughout
this period. This additional staffing has helped to maintain a gcod
safety record by effectively controlling overtime and is in antic'-
pation of Un;t 2 demands. Full-time day work positions were created
for shift superintendents as career paths outside of the control
room. The licensee has also provided for six month assignments (off
shift work) on a rotating basis. The licensee has recruited poten-
tial operators with two year associate degrees or previous reactor
experience. All nuclear plant operators (the most seninr nonlicensed
position) hold reactor operator licenses. An auxiliary snif t is
strategically used to augment peak day work tasks. A full time
position (the 13th SRO) on day shift is dedicated as a supervisor for
blocking and permit coordination. This individual has provided for
the successful removal and return to service of important plant
equipment, as well as elimination of a backlog of maintenance work,
better independent verifications, improved engineered safety feature
system blocks and ultimately, fewer reportable events.
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The shift technical advisor (STA) has been a key in operational
problem analysis, as reflected in post-scram evaluations and Upset
Reports. The first generation of Unit 1 STAS, who gained experience
during power ascension testing and Cycle 1 operation, have been
blended into other site organizations such as outage planning and
maintenance. This spread of operating expertise has been beneficial.
NRC review of the requalification program in March 1987 found
weaknetses with respect to simulator training scenarios, the
licensee's examination piecess and difficulties in the use of emer-
! gency operating procedures Training deficien:les and program
l weaknesses vere corrected by the licensee. Simulator training has
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proven valuable during several plant fe2dwater transients in which
operators quickly acted to prevent a scram.
In the last quarter of this assessment period, the position of the
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onsite fire protection engineer was filled with a qualified indivi-
! dual. The fire protection group was realigned and more clearly
defined as a station organization. A contract was initiated with a
specialist to resolve high priority sprinkler modifications and
improvements to the motor driven fire pump. Although both site and
corporate management were slow to recognize needed changes the newly
organized fire group new appears to have proper staffing, sepervision
and engineering support and represents a distinct improvement over
previous assessments.
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Better results were experienced with the use of a computerized system
- for blocking sequences prepared prior to use. The system reduced
errors, particularly for complex evolutions and outage work. Safe
accurate blocking sequences were provided during the refueling
outage, due in part to the assignment of an extra licensed supervisor
for blocking and permit coordination, as well as the practice of
independently verifying application and removal of blocks on safety
equipment. Few instances occurred during this assessment period
where blocking was not properly administered; however, the licensee
became immediately aware of these breakdowns due to good communica-
tions. The licensee has a'so devoted experienced licensed staff to
prepare Unit 2 blocks. Management commitment of.these resour ces
demonstrates recognition of the importance of removal and return to
service of safety equipment.
Summary
A strono operating team concept with effective leadership from shift
superintendents, integration of technical support organitations,
refined communications and explicit support from management have 4
produced a safe operating record. Advanced planning for Unit 2
startup is evident, while the impact on Unit I has been minimized.
Reductions in reportable events, low scram frequency, and continued
good personnel attitudes with ongoing re-organizational pressures
are products of the site management commitment to safe operation.
Previous fire protection concerns identified by the NRC have been
diagnosed and addressed by appropriata staffing and corporate
support, but more importantly by a recognition of a need to revise
the fire pr ogram. The need to apply resources to critical areas,
such as permits and blocking, has been quickly racognized. Formali-
zation during this assessment period of previously existing good
practices has sustained performance as standards are continually
raised.
Conclusion
Category 1
Trend
Board Recommandations
None
_ _ .
- _ _ _ _ _ _ _ ._ _ _ _ _ _ _ ._. . _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
16
B. Radiological Controls (429 hours0.00497 days <br />0.119 hours <br />7.093254e-4 weeks <br />1.632345e-4 months <br />; 11%)
Analysis
The previous assessment covered the first post-licensing period of
refueling and operation and was rated as Category 1. Weaknesses
were noted in the areas of ALARA, potential heat stress of workers
and review of design modifications, which were attributed to lack of
policy making at the corporate level. Minor weaknesses were noted in
monitoring non-radiological chemistry parameters. Also, post
accident sampling system reliability problems were identified.
1. In Plant Radiation Protection
During this assessment periou site management at all levels
continues to effectively plan and direct activities related to
radiation safety. The station manager personally emphasized the
importance of the Station ALARA Review Committee (SARC) with his
staff after poor attendance at SARC meetings was noted. The
Health Physics supervisors are directly involved in setting daily
priorities for rou+t;e HP surveillance and other technician
activities. During the refueling outage, senior HP technicians
were assigned to coordinate HP support in designated areas of
the plant. Other technicians were loaned to various work groups
such as maintenance to augment GET training of workers, act as
an interface for work scheduling, and ensuring incorporation of
ALARA into the early stages of job planning. Good management
oversight and control of the on-site contractor that collects,
transfers for laundering, and restocks protective clothing was
noteo.
In August 1987, the licensee committed to various improvements
,
in corporate involvement in radiological controls. Implementa-
l tion was not complete by the end of the current assessment
period. Resolution of technical and safety issues related i o
radio'.ogical controls is also sometimes delayed. An excellent
l Heat Stress program was not implemented until one year after
i problems became known. The Hot Particle program has been
unnecessarily delayed by a management decision to adopt the
'
program being developed at the licensee's Peach Bottom facility,
l which is progressing slowly. In the interim, indicators of the
l onset of a hot particle problem such as reactor coolant analysis
I
and personnel contamination reports are being monitored. The
l licensee's approach to technical issues from a safety standpoint
'
is very good although corporate technical support is lacking and
some implementation delays occurred.
-. _ -. - . . _ _
.. .
.
17
The on site program for the calibration and maintenance of
radiation survey meters is excellent and is conducted by compe-
tent contractor personnel. A "hot tool" crib is under construc-
tion that will censolidate into one location all contaminated
tools regardless of the ownership. However, the Radiological
Awareness Reporting remains weak, as emphasis is placed on
prompt correction of problems without the need for documentation
which denies management the data to detect adverse trends. This
is compensated somewhat by the very good communication that
exists between most departments and supervisory levels on site.
ALARA performance continues to be effective with challenging
goals selected by site management. Total exposure for the
period including the outage was about 174 person-rem. This
exceeded the original goal of 150 person-rem due to an unantici-
pated extension of the outage to deal with additional control
rod drive rebuilds and other undervessel work. However, the
total exposure compares very favorably with other newly licensed
BWR stations.
Training and qualification programs are very well developed and
make a positive contribution to the technical performance of the
station staff. The training and testing of contractor health
physics technicians hired for outage support is effective in
ensuring the required knowledge level of radiation safety pro-
cedures. An excellent program for the repair aro calibration
of sophisticated radiation monitoring equipment by Instrumen-
tation and Control (I&C) technicians was noted. This is
attributed, in part, to a rigorous training program for I&C
technicians which spans several years and only accepts personnel
possessing two year degrees.
2. Effluent Control and Environmental Monitoring
The licensee has effective oversight of effluent controls at the
site. Positions and clear lines of authority were established
in the chemistry and health physics support ;roup who sample and
analyze effluents, and implement the Offsite Oose Calculation
Manual (0DCM) respectively. Audits were found to be thorough
and comprehensive in scope. S+affing was generally complete
with little reliance on contractor personnel. There was
inadequate review of effluent data as indicated by errors in the
licensee's Semi-annual Effluent Release Report which were noted
as a result of a change in the computer group's technical staff
members who support the effort. Two LERs related to ef fluent
sampling were noted as attributable to personnel error, sug-
gesting a minor weakness in technician training.
\
--
_
.. . - _ . . _ _ _ _
. .
e
-
18
An effective Radiological Environmental Monitoring Program
(REMP) is being implemented by the licensee. Good corporate
management was demonstrated for this program in which all
activities are contracted. QA audits are thorough and of
sufficient technical depth to adequately assess capabilities and
performance of the REMP. Training for both licensee and
contractor personnel is effective.
3. Radiological Confirmatory Mecsurements
The licensee maintains good capability for determination of
radioactivity in gaseous and liquid effluents as demonstrated by
the comparison of measurements with the NRC Mobile Lab Clear
lines of authority and adcquate stcffing were noted as positive
attributes in management controls. QA audits are conducted at
regular intervals, are technically competent and meet stated
objectives. Procedures are generally adequate to meet program
needs but show indications that timely reviews fer accuracy and
content may not be done in a thorough manner. Example problems
include charcoal cartridge efficiencier tnat were not correlated
to flow and the absence of a requirement for use of a reducing
agent for iodine separation. Two LERs relevant to the chemistry
area occurred within ten days of each other and were attributed
to personnel errors.
4. Non-Radiological Chemistry
Lines of authority are clear and plant senior management support
appears strong as evidenced by recent acquisitions of laboratory
equipment. In spite of adequate staffing and state-of-the-art
measurement equipment, weaknesses in laboratory measurements
were identified in the licensee's capability to monitor chemical
parameters in various plant systems with respect to Technical
Specification, fuel warranty and other regulatory requirements.
These findings indicate inattention to detail in the laboratory
chemistry measurement program some of which were also identified
during the last SALP period.
Summary
During this assessment period, licensee management demonstrated the
ability to conduct routine radiological operations and conducs a
refueling outage while maintaining a high level of radiation safety
performance. In addition, program enhancements and policy improve-
ments were developed and implemented on site in spite of minimal
technical support and guidance from the corporate staff. The
licensee has been slow to respond to problems in areas such as worker
heat stress, hot particles, non-radiological chemistry laboratory
measurements and in providing corporate support to the site.
l
1
, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
. .
.
19
Conclusion
Category 1
Board Recommendations
Licensee
Increased attention should be focused on (1) development of a
program for hot particles; (2) weaknesses identified in the
non-radiological water chemistry measurement program; and (3)
improved corporate support for the site.
!
9
.
. ,
20
C. Maintenance (503 hours0.00582 days <br />0.14 hours <br />8.316799e-4 weeks <br />1.913915e-4 months <br />; 12*J)
Analysis -
This area was rated Category 1 in the previous assessment, with good
supervision of craft and engineering support noted, system status
control and post-maintenance testing as strengths, and excellent
equipment and plant reliability.
During this assessment period well organized and ef fectively managed
maintenance programs that are founded upon a teamwork concept were
evident. Quality workmanship resulted from excellent craft skill
levels, a large amount of specific equipment expertise, and increased
participation of foremen at the site. Several levels of site manage-
ment are routinely involved in oversight of work, including regular
plant tours and cognizance of plant c.onditions. Management goals
related to overtime, ALARA, reportable actuations and work backlogs
have clear accountability. Progress towards those goals has been
measured in the monthly site Vice President meetings. ,
Foremen and supervisors have been carefully selected, and growth
potential is evident in maintenance organizations by promotions
throughout the period. A culture of accountability exists, in part,
because of healthy organizational relations with other work groups.
The reorganization at the end of the period strengthened maintenance
groups on site, by better int 39 rating the previously sound technical
support functions, and has improved morale due to assignment of the
former Ma :ager of the Maintenance Division as Station Manager. A
self-assessment was conducted towards the end of the period and
action plans to improve various programs were underway.
,
Predictive programs were better developed as new technology (thermo-
l
graphy) and existing techniques (vibration analysis) were factored
l into a performance group formalized auring the last half of the
period. The group utilizes a preventive maintenance (PM) coordinator
'
and dedicated staff to assemble computerized data from testing,
failure data cnd other sources to perform trend analysis. Limited
use of the program has nonetheless identified potential problems for
,
l
investigation or increased maintenance. Priority has been placed
upon completing overdue PM's and maintaining a balance of preventive
l and corrective work as a means of assuring safe reliable operation.
, Also, deferred PM work has written justification and is still entered
! in historical records based on technical evaluation. Although the
Probabilistic Risk Assessment (PRA) has been kept updated and used in
,
limited fashion for licensing and design decisions, its potential for
l removal of equipment from service for PM work has not been fully
explored. ,
l
l
l
l
l
4 &
.
21
Important equipment has had planned overhauls during this period and
experienced good reliability as a result, A valve
repacking program, including live loading for all air and motor-
operated valves and manual valves with a failure history, was
implemented during the refueling outage and has been successful as
indicated by low unidentified leakage and few radiological hazards.
Problems 4:ith RWCU pump seal failures noted in previous periods were
significantly reduced as only one seal failed this period. No
unplanned shutdowns were attributable to maintenance activities.
However, control structure chiller availability was low and increased
vendor expertise and technical coordination were required. Main
condenser tube leaks and air inleakage, and circulating water system
problems also challenged the plant staff this period, and a planned
two-week shutdown was conducted in April 1988 to repair these and
otner problems.
One measure of management's influence in this area is the high level
of plant housekeeping maintained, as well as clear commitments to
industrial safety. Controls on scaffolding particularly following
the refueling outage were lax, but improvements were instituted to
more carefully consider erection near safety equipment and to promptly
. remove scaffolding when work was completed. Fluid leaks are not
widespread and are promptly repaired, control room and local alarm
panels have few chronically annunciated conditions, and access to
equipment is generally easy- A formally controlled lubrication
prugram is strictly maintained using grease pro.'dures and locally
posted instructions on proper lubricant and fill points. However,
control structure cniller availability was low and increased vendor
'
expertise and technical coordination were required. Main condenser
tube leaks and air inleakage, and circulating water system problems
also challenged the plant staff this period, and a planned two-week
shutdown was conducted in April 1988 to repair these and other
problems.
Conduct of maintenanct <, typified by strict adherence to procedures
and a teamwork approach such as on the refueling floor during the
outage. Professional courteous work relationships found throughout
other work groups extend to maintenance personnel as well. Dedicated
planners and licensed or Shift Technical Advisor (STA) experience
within the staff ensure that work is accomplished smoothly. Self-
critiques are regularly conducted using videotapes and involve
appropriate craft and management. The licensee has recognized the
continuing challenge of making the HP-maintenance worker interface
successful. Detailed workmanship and attention is evident in the
more challenging jobs performed.
i
l
l
I
l
L
_ _ - - - - - - _ - - _ _ - - - - - _ _ _ _
, ,
.
.
22
f
Procedures have been technically sound, but need better human
factors and conciseness. Improvements were being undertaken for
clarity, usability and incorporation of computer-drawn sketches,
diagrams and pictures. Site management has recognized this
problem. They are solving it by craft / foreman feedback in critiques
and validation of procedures using mockups. One reportable event-
was attributed to a procedual inadequacy in this erea.
An effective automated' system (CHAMPS) enables better management and
knowledge of job status at any time. A complex but well understood
administrative procedure governs work. Accurate controlling docu-
ments (maintenance request forms) allow for easily understood post
maintenance testing and comprehensive maintenance history. A very
low backlog of work is maintained. Backlog statistics are refined to
a number of meaningful measures such as: high priority non-outage
workable corrective jobs older than 60 aays and total number of jobs
completed but not yet entered to history older than three to six
months. In the latter category, an NRC violation resulted in a more
challenging goal and better equipment history available at the end of
the period. Trend analysis of this history identified a high failure
rate for feedwater minimum flow recirculation valves which were
repaired during the April 1988 outage.
Staf fing was improved by consolidation of maintenance groups as part
of the corporate the reorganization. The licensee s'apports a program
to train high school graduates to be technicians, including formal
education towards a two year college associate degree and an 18 month
plant systems course. Training is closely coordinated with craft /
Supervisor .'eedback and supported by a site maintenance training
representative. Special courses have been devised and plant specific
mockups are effectively employed.
Supervision and control of contractor maintenance is a recognized
i
problem, as evident in the undervessel damage incurred during the CRD
l rebuilds and by QA audits of selected outage jobs. The licensee has
already taken steps towards improving contractor workmanthip by
appointing a dedicated licensee foreman for outage undervessel work,
a supervisory engineer for reactor work during refueling, and better
screening and training of contractors.
Summary
In summary, several levels of management are effectively involved in
maintenance; equipment reliability has been excellent; maintanance
groups are well staffed, trained, and supported; teamwork and
accountability are evident; and self-assessments and root cause
analysis programs are maintaining a high quality program. Outage
demands and technical problems were successfully met and solved.
Repetitive failures rarely occur but nonetheless are quickly
recognized and presented to management for solution. Maintenance
personnel follow procedures, include pre-job ALARA-conscious
decisions, and respond capably to contingencies. Work planning is
e
c -
. _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ ..
L , .
.
. 23
extensive and better predictive capability is being developed.
Improvements are underway to make maintenance procedures more usable,
better control contract work, and manage work _ backlogs.
Conclusion
Category'l
Board Recommendations
None
%-
_ _ _ _ _ _ _
. .
.
24
D. Surveillance (549 hours0.00635 days <br />0.153 hours <br />9.077381e-4 weeks <br />2.088945e-4 months <br />; 14%)
Analysis
Surveillance was rated Category 1 during the previous assessment.
Testing successfully confirmed operability and identified equipment
problems, und benefited from involved supervision and good engineer-
ing support. Relatively few instances of missed tests occurred.
During this assessment period the success of the programs depended
upcn strong accountability to a surveillance test coordinator. Test
philosophy extends beyond compliance, including routine tests not
required by technical specifications but important for safety system
availability. However, the number of reportable events attributed to
personnel errors continued at approximately the same rate and there
were no reactor scrams caused by testing. Problems from previous
assessments were significantly reduced such as instrument valving
errors, missed fire watches, reactor water cleanup system isolations
and difficulties with toxic gas analyzers.
Survelliance Testing continues to be effective in identifying equip-
ment problems, especially with the emergence of performance monitor-
ing to trend equipment reliability and allow early prediction of
failures. A performance monitoring group was established with
dedicated staff in the technical engineering group. Trending is also
reported routinely to the PORC. Another useful trending initiative
is the plant electronic notebook system (PENS) which involves
computerized data entry from the dally surveillance log.
Staffing was sufficient to support surveillance testing as reflected
by strict adherence to test schedules and the ability to find
problems. Although half of the I&C technician staff are contractors,
these personnel have been at Limerick since preoperational testing
and exhibit good understanding and respect for station administrative
controls.
The licensee's sensitivity to scram potential is demonstrated by an
A-day /B-day logic channel test schedule: coded into the computerized
scheduling system and incorporated in administrative procedures;
stamped in red on procedures; and posted in the main control and
auxiliary equipment rooms. This disciplined approach to testing is
used to prevent coincident logic actuations and demonstrates good
control over testing.
The conduct of testing is founded on effective communications and
professional working relationships between test personnel and
licensed operators. Technical staff are assigned as test directors
and a licensed operator is routinely dedicated to complex testing
such as safeguards bus logic. This was evident during extensive
modit aation testing during the refueling outage. Inservice Testing
(IST) is similarly well-coordinated. Some managem7nt deficiencies
.
F
-- _
. .
.
25
were noted with the Containment Integrated Leak Rate Test (CILRT)
involving overuse of tags, an extensively revised procedure, building
access control, and communications with operators.
Areas where room for improvement exists are QC witnessing of
routine testing, and the control of temporary procedure changes.
Also, the daily surveillance log performed by operators to fulfill
channel checks failed (over two shifts) because of an unspecified
normal range to detect reversed thermocouple leads on a temperature
monitor that had been improperly restored following a surveillance.
A key aspect of programs is the computer based scheduling system
maintained by a dedicated test coordinator. Overdue tests are
quickly identified, as in one case where planning for weekend wo 9
loads identified an incorrect test date. The master test scheduie is
routinely checked by station supervision and plant management, and
has enabled recognition of problems. This planning enables good
management of an extensive test program.
Test procedures have proved to be usable, and were recently revised
with consistent human factor improvements. Independent verification
following testing is sound and successful, and provides a true
independent validation with a high degree of confidence in system
configuration. An exception was reported in LER 88-01 involving
undetected reversal of thermocouple leads. Test procedures implicitly
allow for sound communications between test personnel and contrcl
room operating staff, incleding a pretest briefing on expected alarms
and the impact on system oferability. A consistent technician
approach is to suspend tert activity when a procedural error or
equipment discrepancy is found until the problem can ce resolved.
The licensee has created an atmosphere wherein personnel routinely
exhibit attention to detail and involve their supervision when
activities are 'n question. Color coded instrument cabinets in the
auxiliary equipment room have reduced the potential for human error
associated with divisionalized testing. The licensee mirimized the
use of lif ted leads during testing and has virtually eliminated
inaccessible test points. Station management has communicated to
work groups that activities should be conducted with the idea of
eliminating system challenges.
Improved communications between test personnel and operators,
development and use of procedures that comply with human factors
guidelines, involvement of first line-supervision, and rout.Me use of
root CaJse analysis programs indicate a desire to find and correct
problems. Corrective action programs are persistent, as indicated by
frequent revisions to LERs to describe additional information
uncovered by investigations.
- -
. .
.
- 26
i-
Certification trdining during this assessment period has been effe:-
tive in plant staff and management understanding of the operation of
plant systems. Training during the period on human performance
evaluation techniques has been applied to a limited extent to the
surveillance test program to effect simple but effective solutions.
Less formal training has also been influential as evidenced by
creation of a shift superintendent update notebook to describe
ongoing technical issues,
e
Much of the quality oversight of surveillance is accomplished in PORC
meetings. A plant incident tracking system has been effective in
focusing c. the more safety significant issues that occur from
day-to-day. The licensee's QA and QC involvement in surveillance
testing has been minimal, ar.d has not provided assurance of the
effectiveness in activities in areas such as indapendent verifica-
tions.
Summary
Management's oversight of testing has been stro ig. Clear account-
ability for testing performance is ensured by t ie scheduling program.
Workers and technicians exhibit attention to de: ail and have the
benefit of dedicated technical support, includiig new developments in
trending. . The licensee has demonstrated an agg essive approach to
testing beyond mere compliance with requirements,.
Conclusion
Category 1
Board Recommendations
None
!
!
t
L_
_ . - _ _ __ __
-. ..
1P
. 27
E. Engineering / Technical Support (958 hours0.0111 days <br />0.266 hours <br />0.00158 weeks <br />3.64519e-4 months <br />, 24%)
-Analysis
This area was rated as Category 1 during the last assessment with
strengths.in the integration of technical expertise among all site
work groups, valuable contributions from test and field engineers,
and responsive professional. interaction with corporate engineering.
Considerable inspection effort was devoted to this area this period,
including team inspection of the environmental qualification program
and assessments of the interface between site technical organizations
and corporate engineering. Major licensee reorganizations occurred .
'
near the end of the period, involving both corporite and site
technical functions. A new Vice President devoted solely to nuclear
engineering was appointed in January 1988. Personnel appeared to be
generally receptive and optimistic regarding the changes.
There were two unplanned scrams from power which occurred within a
, month of startup from the first refueling outage and both were caused
by failures of balance-of plant equipment. The first was due to
erratic moisture separator water level control attributed to inst-
rument air. valves that had not been adequately verified as open. The
other scram occurred due to a ruptured control fluid line to the main
turbine control valves caused by resonant vibrations resulting from a
modification. The licensee displayed a sensitivity to scram poten-
tial by restricting the unit to 85% power for two months until a
solution to the vibrations could be achieved.
Site engineering support for the inservice testing (IST) of pumps and
valves was found to be well coordinated, staffed with technically
competent personnel and had a high degree of site management involve-
ment. The IST organization was a knowledgeable cohes.ive group that
closely interfaced with their maintenance department counterparts.
Site engineering interfaced with corporate engineering and requested
their assistance when needed. However, corporate engineering
guidance appeared to be 1 scking and did not appear to thoroughly
evaluate some issues. Examples included programmatic deficiencies
with document control, ill-defined organizational and personnel
'
responsibilities, and discrepancies between the licensee's criteria
and ASME Code Section XI. In response to past engineering support
deficiencies, corporate engineering is presently taking the lead in
efforts to improve IST based on NRC findings at Peach Bottom.
A special fire protection inspection in response to the licensee's
identified issue that an Appendix R postulated fire in the service
. water pipe tunnel area could disable all fcur emergency diesel
l generators (EDGs), resulted in escalated enforcement. Although an
l.
associated problem involving a deficiency in the EDG time delay
l
setting was identified by the licensee as early as June 1984, the
l
. . _ -
.. .
28
lack of separation of fire protection circuitry was not identified by
.the licensee until October 1987. This was an indication that
management attention may have been lacking. Pricr evaluations and
reporting involving interaction between safety and non-safety related
systems may also have been inadequate. Considerable NRC effort was
required to bring the problems to the surface. Once the Appendix R
problem was identified, the circuitry was promptly corrected.
Another identified weakness in corporate engineering support to the
site was found during audit of the environmental qualification (EQ)
program. Procedures adequately documented EQ packages, and were
generally well organized, however, some packages were not updated on
time resulting in three violations in the qualification of Rockbestos
cable. EQ maintenance and plant modification activities at the site
were found to be well supported. Established EQ related training
exists for individuals performing installation, modification, repair,
maintenance and procurement. Personnel have also participated in EQ
associated courses sponsored by industry and institutions. Personnel
were aware of regulatory requirements and of the licensee's commit-
ments to implement a fundamentally sound EQ program.
The NRC team evaluation of Unit I restart from the refueling outage
identified a weakness with the liberal use of temporary circuit
alterations (TCAs) to implement short-term modifications. Although a
past-identified issue. significant numbers of outstanding TCAs
existed throughout the period, many dating back to original fLei load
over three years ago. Application of TCAs had doubled over each of
the past three years, with appr3ximately 25% not restored or
permanently modified. While co porate engineering provided timely
engineered design packages to support major refueling outage license
condition modifications, the increasing number of TCAs indicated an
inability to support routine plant operation. In the latter half of
the assessment period the licensee initiated corrective action to
reduce the number of TCAs and assign high priorities to design
engineering for those TCAs (two thirds of total) awaiting permanent
modifications.
Reportable issues identified during the period pointed to engineering
or technical dif ficulties requiring more aggressive corrective
action, such as the inordinately large number of secondary contain-
I ment isolations. While various root causes could be assigned to
l these, the overriding issue involves blocking and tagging errors due
I to lack of identification of instrument air lines. This problem was
also the apparent cause of a scram in September 1987. Site technical
engineers completed an exhaustive walkdown of accessible air lines by
the end of the period. This concern was also raised by the Nuclear
Review Board but longer term solutions are still forthcoming. Past
chronic reportable events invoh ing chlorine and toxic gas detectors
received considerable technical attention. The toxic gas detector
problems were effectively addressed by logic changes and responsive
engineering; however, the chlorine detector problems persist and an
. ._ _.
,
-. ,
.
. 29
engineering solucion has been delayed. In certain other events (e.g.
LER 87-42 regarding RPS relays) the licensee demonstrated a-
philosophy to go beyond mere compliance with requirements.in pursuit
of the root cause.
Planning and technical support were excellent for the refueling
outage. Staffing in health physics, QA and QC were increased,
assuring better outage coverage, including detailed audits for
license conditions. Management concern for reactor safety was
evident by establishment of a refueling floor outage organization
with well defined lines of communication and by certain outage
conservatisms including the NRB's concern to assure backup decay heat
removal using fuel pool cooling systems during planned modifications
to emergency service water systems. Although management's decision
to secure ventilation systems on the refueling floor in August during
hot humid weather necessary to tie-in standby gas treatment caused
worker heat stress problems and rome ALARA ccncerns (see section
III.8), that philosophy was abandoned and contingencies were employed
after worker feedback was received. The licensee successfully
employed a modification coordinator (similar to test coordinators for
complex surveillances described in Section III.C) for critically
complicated changes, such as the SCTS tie-in, which involved many
work groups.
A high degree of technicci and management support of the ISI Program
was evidenced by the use of the General Electric Company "Smart UT"
which is an advanced system for recording and processing ultrasonic
examination data, and by the comprehensive QA coverage of ISI activi-
ties. The ISI Program is adequately staffed with well trained
personnel. QA staff responsible for ISI are knowledgeable and
competent to monito.- these activities.
The licensee has maintained an up-to-date PRA, primarily in antici-
pation of Unit I licensing questions. However, extensive use of the
study where it would seemingly contribute to Unit 1 operating
decisions such as preventive maintenance and modifications has not
been mat'e. Certain Unit 2 milestones such as tie-in of service water
systems 'ticularly for diesel preoperational testing) have been
well pla..cd and were presented to the NRC in advance of dual unit
operation. Also, engineering solutions to past problems such as PASS
reliability and interunit contamination of shared systems have been
effectively resolved and applied to Unit 2 as well.
Summary
In summary, although engineering and technical support for the first
refueling outage modifications was generally good, corporate support
in resolving some chronic operational problems associated with
(
chlorine detectors and in addressing specialized areas such as EDG
'
fire protection instrumentation and environmental qualification left
considerable room for improvement. Thus while long term preplanned
i
support for outage activities was effective, corporate support for
l routine operating activities was not always so.
t
I
,
me - w
_ _ - - _ _ _ _ _ _ _ _ _
.. .
.,.
30
'
Near the end of this evaluation period an increase in iodine
activity in the coolant was identified as due to' leaking fuel. Heat
flux restrictions to minimize further fuel degradation have caused a
power derating of the plant. Although the cause of the leakage has
not been fully detennined, a synergistic effect of zirconium cladding
fabrication variations and copper and iron impurities in the
feedwater may be responsible however, it is unusual for this to
result in cladding failure early in the life.of the plant. The
response, including corrective action, taken in response to this
event will be significant in the longer term operation of the
plant.
Conclusion
Category 2
Board Recommendations
Licensee: Meet with NRC to review the status of the identification
of the root cause of the fuel leak and the corrective actions being
taken.
_NRC : Increase attention to assure that licensee response to the
fuel leak is comprehensive
i
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_ .
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31
F. Emercengy Preparedness (121 hours0.0014 days <br />0.0336 hours <br />2.000661e-4 weeks <br />4.60405e-5 months <br />; 3%)
Analysis
During the previous assessment period, licensee performance in this
area was rated Category 1. This was based upon good exercise
performance and the licensee's own initiatives in routine emergency
preparedness activities.
During the current assessment period, one routine safety inspection
was conducted, one full participation emergency exercise was
observed, and changes to emergency plans and implementing procedures
were reviewed.
During the routine inspection performed in January 1988, several
significant areas of concern were identified. Deficiencies were
found in programmatic areas such as the ability to resolve exercise
critique items, implementing procedure revisions, performance of
related tests, and training of off site response personnel. NRC
review of licensee audit results revealed that some of these areas
were previously identified as deficient and in need of correction.
The open item tracking system used by the licensee Emergency
Preparedness Section identifies significant program deficiencies
outstanding for approximately two to three years that have not
received appropriate management attention and evaluation. Although
many of the individual deficiencies were not of major significance a
violation was issued for the licensee's failure to take corrective
' action on outstanding Emergency Preparedness Program deficiencies
identified by their own audit program.
The audits of the Emergency Plan, Emergency Plan Procedures, and
Corporate Procedures noted in the preceeding paragraph have been
conducted by the corporate organization with contractor support every
12 months. These audits were performed in adequate detail to provide
assurance that potential weaknesses were identified and discussed
with emergency preparedness management. However, two separate 1986
independent audits were perforned which identified recurrent program
deficiencies. The results of both audits were sent to the Director,
Emergency Preparedness. No action was taken by the corporate Emergency
Preparedness staff or other management to correct these identified
deficiencies. This led ; an NRC finding that formal distribution of
the 1986 audit results to appropriate plant or corporate management
was not made. In the licensee's 1987 QA audit report several new
findings were identified in addition to recurring program deficiencies,
i
which indicates an inadequate response to self identified problems.
Deficiencies associated with program management and the independent
I review process remained unresolved, an Action Item Management Team
!
was established to address these concerns.
1
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. 32
During the unannounced, full participation exercise held on April 5,
1988, the licensee's execution and participation demonstrated
acceptable planning and thorough accident management.' The NRC team
obse rved several minor performance weaknesses in the areas of infor-
mation flow, use of Emergency Plan Procedures (EPP), and training of
personnel to effectively carry out EPP's. The licensee also demon-
strated adequate corrective action for previously identified NRC
exercise items through appropriate program changes and retraining.
The level of staffing and resources maintaining the Emergency
Preparedness program is strained and the effectiveness of the Site
Emergency Preparedness Coordinator (SEPC) in completing task assign-
ments has suf fered as a result. Scenario development and review via
!
contract support has been acceptable. The Director, Emergency
Preparedness was also overburdened in that oversight responsibility
for program administration, on site planning support, off site
planning support, and drill / exercise conduct must be implemented at
both the Limerick and Peach Bottom sites. Near the end of the SALP
period the licensee implemented management changes and also dedicated
additional corporate support to the Emergency Preparedness progran;
however the effectivness of these improvemeats have not yet been
assessed by the NRC.
Emergency Response Facilities (ERF) are dedicated and have been
adequately maintained throughout the period.
Summary
In summary there appears to be adequate ability to respond to
emergencies, however, it appears that the strong interface exhibited in
previous assessments between the corporate emergency preparedness
staff and the SEPC/ site support staff has been weakened. Responsi-
bility for assignment and completion of site duties is assumed by the
SEPC without adequate resources or direction frcm the corporate
staff.
Conclusion
,
Category 2
l
Board Recommendations
Licensee
1. Focus additional attention on resolving outstanding audit
findings and institute more timely corrective action for them.
2. Ensure effective completion of required Emergency Preparedness
Program tasks, including planned corr '<ve action resulting
from identified deficiencies.
- , .,
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. .
. 33-
G. Security and Safeguards (281 hours0.00325 days <br />0.0781 hours <br />4.646164e-4 weeks <br />1.069205e-4 months <br />, 7*;)
Analysis
During the provious assessment period, this area was rated category
2. The licensee and the security force contractor aggressively
pursued a planned course of action to identify and correct the root
causes of their identified poor performance and implemented many
changes in an effort to improve the overall security program.
Those changes included a significant increase, on the part of the
licensee, in program oversight and direction, management involvement
and support, and training program enhancements.
A high degree of licensee management attention to and involvement in
the program continued to be evident during this assessment period and
was n.atched to a substantial degree by the licensee's security
contractcr. This combined effort to estaolish and maintain an
effective and high quality security program resulted ia excellent
performance throughout the period (one minor violation), in addition
to further program enhancements.
The additional enhancements included: (1) establishiig a Security
Incident Review Committee composed of operations and security
management personne?, to evaluate all security events for plant
safety and security consequences; (2) providing proprietary shift
supervisors specialized training in alarn station operations, audits,
surveillance testing techniques, and emergency preparedness; and (3)
developing an action plan and tracking system to provide for a smooth
integration of Unit 2 systems and equipment into the Unit I program
and assigning responsibility for the transition to an individual with
no concurrent Unit 1 program duties. The implementation of further
enhancements provide continued evidence or managements' further
I interest in maintaining an effective program rather than a compliance
oriented program.
The licensee continued to use a self-appraisal program to monitor the
on going performtnce of the security force ?nd to identify potential
problems easily and correct them effectively. The responsibility for
implementing this program was reassigned from the security contractor
to the licentee's proprietary supervisors during this period. The
self-appraisal program combined with other security program audits
and surveillances, and the NRC required annual program review, is
believed by NRC, to be a significant factor in improving the security
l program and is indicative of the licensee's desire tc achieve high
quality in its program implementation. This was also apparent by the
- licensee's actions in response to generic Regulatory Effectiveness
Review findings. In that regard, the licensee, on its own initia-
tive, actively pursued the generic findings at the Limerick
Generating Station to determine if any similar deficiencies existed
and, as appropriate, promrtly corrected potential problems.
.._- - . ,
p,,e ,
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34
The licensee's _ security contract also cmtinued to make enhancements
'to~its portion of the program. These included: (1) improving tti
established security force training program by refining lesson plans
and obtaining additional training aids; (2) providing additional
emergency preparedness task training (3) renovating the equipnent and
arms room and revising arms issue procedures; (4) developing a pool
of traiaed and qualified supervisory personnel to provide an effec-
tive line of succession; and (5) developing and implementing on-nost
security task certifications. In addition, the contractor exerted a
commendable effort to improve employment benefits and human factors
for the guard force in order to strengthen morale.
Security management involvement in industry and NRC initiatives
involving nuclear power plant security progressed throughout the
period in response to identified problens, demonstrating management
support of the program. In addition, the licensee has taken very
aggressive measures to reinforce i;s Fitness for Duty Policy and to
achieve a drug free work place for personnel at the Limerick
Generating Station. On several o:casions during the period, the
licensee conoucted drug sweeps of the Station using specially trained
dogs, pursued in-depth investigations of allaged drug related
activities, provided special drug awareness training sessions for
supervisory personnel. and enforced appropriate disciplinary actions
for offenders. The licensee's initiatives in this regard are
exemplary and demonstrate a very responsible position to ensure
public health and safety.
The training program is implemented by well qualified and
experienced instructors with no concurrent duties. Facilities and
equipment are adequate and lesson plans are well developed and kept
current through vcrious feedback mechanisms, including the self-
assessmer.t and on post task certification programs. The initiatives
implemented during the previcus rssessnert period, particularly the
revisions to nrocedures and post instructions to make them clear and
! concise, were apparently effective as indicated by the relatively
small number of guard force personnel errors.
Staffing of the proprietary and contractor organization is effactive
as evidenced by the effective oversight and excellent performance
l during the period. Staffing of the guaru fnrce also appears to be
sufficient as indicated by the 'imited cse overtime. This is also
considered by the NR to be a significant factoi in improving the
program and indicath. of the licensee's desire to achieve high
quality in program iraplementation. '
l- The licensee's event reporting procedures were found to be clear and
consistent with the NRC's new reportirg requirements. Seven event
reports were submitted to the NRC during the period. Four of the
reports resulted from the licensee's follow-up of drug related
activities: one involved an inattentive guard; another reeulted from
a computer failure, and the se enth resulted from the detection of a
%
. .
v
l 35
weapon at a protected area access cont.;l point. Each report was
cleer and corcise, and indicated appropriate response to the reported
event.
During the assessment parfod, the licensee submitted two revisions
to the security plan under the provisions of 10 CFR 50.54(p). The
licensee's corporate security staff is responsible for ensu.ing that
plans are current and for coordinating changes, when required. The
?icensee's e,taff is very effective in carrying out this responsibi-
lity. They oftan communicate and review changes with the NRC to
ensure a clear understanding. When the plan changes are submitted to
NRC, they are of good quality, which is indicative of a thorough
review and a comprehensive understanding of NRC security performance
objectives.
Summary
In summary, the licensee and iti, security contractor continued to
strive for an effective and high quality program throughout the
period. Significant improvements wr.re made to the program ared these
resulted in excellent performance and imp'ementation of a security
program that is oriented toward meeting the NRC's nuclear plant
security objectives rather than merely regulatory compliance. The
efforts expended during this period (and the preceding period) are
commendable and demonstrate the licensee's ability to turn a carginal
program into a high quality program through management irvclvement,
attention and oversight.
Conclusion
Category 1
Board Recommendations
Iicensee: Continue initiatives to further enhance program.
!
'
l- # _ . . __ __
. _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ .
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36
H. Safety Assessment / Quality Verification
Analysis
Assurance of quality has been considered as a separate functional
area in past SALPs, in addition to being one of the evaluation
criteria in functional areas, aad was rated as Category 1. This area
has been expanded to encompass activities previously evaluated in
Licensing, incluaing safety evaluations. This discussion is a
synopsis of quality and rafety evaluation philosophies reflected in
other functional areas. In assessing this area, the SALP Board has
considered attributes which are key contributors in assuring safety
and verifying quality. Implementation of managemer.t goals, planning
of routine activities, worker enthusiasm, management involvement, and .
training are e>amples. .
.
The previous SALP noted that the licensee had demonstrated consider-
able technical capability and evidence of management involvement in
licensing activities. The weakness noted was the quality of the no
significant hazards determinations (NSHDs) associated with license
amendment applications. The SALP Board recommended monthly meetings
between the licensee and NRC staff, which have been held.
During this SALP period, management took an active role in resolution
of any problems and ensured that schedules were met without sacri-
f:cing quality. There was a noted improvement in the thoroughness
and scope of the NSHDs. There are only four multi plant generic
issues remaining to be closed on Limerick 1 and these are nearing
resolut ons.
Licensee management has upgraded training programs for the licensing
staff and arranged for the personnel to spend more time onsite.
Licensing activities are conducted by a well staffed and well trained
group. Management overview is evident as warranted.
The Plant Operations Reviqw Committu (PORC) continues to be forceful
in maintaining safe operation. Use of a sub-PORC process keeps the
focus of the full committee on significant safety issues. Use of a
specially devised PORC process whenever operational conditions change
has insured that no problems remain unaddressed prior to startup;
however, more visible involvement by the ISEG and QA in that process ,
is warranted. Rou',ine meetings are reflected by excellent written '
minutes that. provide a good reference for station performance. The
value of PORC safety dec:sions is a result of the professional
meting atmosphere developed by past station managers and continu :d
under the strong leadership of the Superintendent of Operations.
The licensee conveys quality messages to workers in relatively simple
ways. Signs are evident throughout the plant underscoring the
importance to safety of routine tasks, including quality and
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. _ _ _ _ - - _ _ _ _ _ _ _ _ .
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37
- ,
excellence banners. Station inanager memoranda to site personnel
commend them for a job well done such as the outage, or serva as
reminders for careful work practices such as fire doors.
Management and corporate involvement with worker exposure programs
was still of some concern to NRC in that a Station ALARA Review
Committee had never formally met until NRC concerns were raised.
However, dissemination of the ALARA message to work groups was
evident.
The licensee has instituted unique corrective action programs which
are sufficiently self-critical to prevent recurrence and get at the
root cause of problems. An example was the video tape of skits
performed by operators designed to show that well-executed routine
activities can significantly reduce risk and enhance safe oparation.
Safety evaluations (modifications, TCA>, nen procedures, and general
plant issues) have been insightful and complete.
Prior to the reorganization the licensee's quality verification
groups (QA/0C) were fragmented among work organizations which diluted
their effectivenass at times. Some problems in communicating quality
concerns to operating staff were noted. However, because of excel-
lent work performance and the ability of work groups to find and
correct their own problems, QA/QC has not been an essential.ingred-
tent in assuring operating et ellence. Quality group involvement in
certain areas scch as surveillance testing has been minimal, and has
not allowed for an even assurance of activities such as independent
verifications. Quality auditors and inspectors are generally well
qualified and very consciantious as reflected in audits which were
detailed and critical of activities such as emergency preparedness,
fire protection, and maintenance.
As discussed in Section IV.0, technician qualifications and involve-
ment of first-line supervision have resulted in high quality test
programs. Supervision's attention to detail has.been instrumental in
effectively getting to root cause and preventing problems from
i recurr'.g.
L The Nuclear Review Board (NRB) was reconstituted at the beginning of
l
this period, including the addition of three senior consultants. The
Board nas prcgressed to a more thoughtful diagnosis of problems, as
evidenced by focus on issues during the refueling outage concerni g
.
decay heat removal and the increased numbar of personnel contamina -
l tions. All of the licensee's shif t superintendents have had an
E opportunity to address the NRB in a full meeting on topics ranging
I from Peach Bot +om feedback to the selection pincess for promotions.
The NRB has also expressed increased awareness f.e the effect of Unit
l 2 preoperational test preparations,
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Corrective action programs are portrayed by the quality of LERs, with
the exception of design problems manifest in secondary containment
.isolations and chlorine detectors. Past events due to instrument
valving errors, missed fire watches, and safety system actuations
have b?en eliminated. The detail presented in LERs has been excel-
lent, reflecting tne s'.rong technical expertise of the staff.
Although increasing trends for LERs have been noted, such as during
the refueling outage, the licensee properly interpreted those trends.
Some late LERs and the practice of extending them by supplements to
provide all required information suggest a management weakness in the
utility's Licensing organization. Corrective actions in response to
recurrent licensee identified deficiencies in the Emergency Preparec-
ness Program were unnecessarily delayed because of a lack of corporate
management oversight and of a lack of line management accountability
for program audit findings.
The licensee's initiatives in the area of fitness for duty have been
progressive, employing competent onsite security investigators, using drug
dogs as an effective deterrent, instituting policies for drug screening of.
contract organizations, and maintaining consistent communications with the
NRC regarding fitness for duty issues. The licensee has sent a clear
message to all site employees regarding expected levels of fitness for
duty.
Summary
Quality programs at Limerick have, in an integrated fashion, fostered
a healthy working atmosphere. Programs have sufficient overlap and
depth such that there is high assurance that undetected errors are
rare. Site management prevents significant problems by early
detection and unique resolution such that recurrences are infrequent.
The preponderant cultural attitude is one of se 'tivity to people,
and has allowed for the plant to survive difficult reorganizational
phases and other high expectations in light of questions regarding
Peach Bottom. The leadership of superintendents and front-line
. supervisors, and the management which is an out-fall from the PORC,
have been instrumental in assuring quality.
Conclusion
Category 1
Board Recommendetions
Nane
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V. SUPPOPTING DATA AND SUMMARIES
A. Investigations and Allegations
No NRC Office of Investigations reviews were conducted during the
assessment period.
Three allegations of drug use by ontract personnel during this
t' period resulted in the discharge of several workers when drug tests
confirmed the information or when they refused 'o submit t a test.
A forth drug allegation could not be pursuei due to inadequate
information from an anonymous source.
B. Escal.ated Enforcement Actions
Level III violation (no civil penalty) for Appendix R diesel fire
flow switch design.
C. Management Conferences
On July 7, 1987, t eh licensee met with NRC management on site to
discuss the previous SALP report findings.
On October 8, 1987, licensee engineering reoresentatives met with NRC
Region I personnel in King of Prussia to discuss the technical
aspects relating to flow switches in the fire suppression system
which could have affected diesel generator operability.
On October 22, 1987, an enforcement conferer.ce was held at the NRC
Region i office in King of Prussia to discuss a violation of 10 CFR
50, Appendix R requirements involving the diesel generator flow
switch cable routing.
D. Licensee Event Reports (LER).
1. Report Quality
Utilizing the basic evaluation methodology presented in NUREG-
1022, Supplement 2, overall quality of licensee event reports
- (LERs) is very geod. A strong point for Limerick LERs continues
to be the in-depth discussion of failure and root cause.
'
There
has been improvement in the identification of previous occur-
rences. There has also been improvement in the safety assess-
ment discussions, but this is an area which would benefit from
added attention. The licensee routinely supplements LERs with
additional findings and has a go,d practice of using diagrams
where appropriate. While reviewing 82 LERs this assessment
period, clarification was only needed on several occasions by
the staff. However, in several instances LERs were late.
.
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. 40
2. Causal Analysis
Number Percent
A. Personnel Error 32 39~
B. Design /Manuf./Constr./ Install. 21 26
.
C. External Cause 0 -
D. Procedure Inadequacy 8 10
E. Component Failure 12 15
X. Other (incl. unknown) 9 10
TOTAL 82 100
Events
A tabulation of LERs by functional area is attached as
Table 3.
-
LER Nos. 86-57, 87-01 to 87-70, and 88-01 to 88-11
were received and reviewed by the NRC during the
assessment period.
-
The 82 LERs which were reported during the assessment
period were also subject to an ongoing review as part
of NRC inspections for trends and root cause
l
identification. The following sets of common mode
l
events were identified:
l
l a. Thirty-two LERs were attributed to personnel error.
L (Approximately 26 on an ann- lized basis.) These LERs
! accounted for approximately ,J% of the events reported as
.
was the case during the previous assessment period.
.4e>
As shown in the following table the refueling outage period
accounted f:r a significant percentage (56%) of the total
number of personnal error LERs. For the periods outside of
the outage, there appears to be a gradually improving trend
in the number of personnel error LERs as well as the
percentage of the total.
c
M- a _ _ , _ _ _ _ . _ , . . , , , _ _ , _ . , . _ --. , , .. . _ _ _
, _ . _ _ _ _ . _ . .
_ _ _ - - _ _ _ _ _ _ _ - _ - - _ _
.. < ,
.
. 41
Personnel Error % of
Time Frame (Quarterly) LERs Total
Feb 1-Apr 30, 1987 4 31
May 1-Jul 31,1987 14 56
Aug 1-Oct 31, 1987 9 39
Nov 1, 1987-Jan 31, 1988 3 25
Feb 1-Apr 30, 1988 2 22
May 15-Aug 26, 1987 18 60
(Refueling Outage)
A different breakdown of the personnel errors indicates
that approximately 62% were partially or wholly a result of
inattention to detail, whereas a lack of knowledge
necessary to complete a specific task or poor judgement
were primary factors in 25% and 13%, respectively, of the
remaining LERs.
Increased management attention to personnel errcrs as a
result of the significant increase during the outage
appears to have been effective.
b. Twenty-one LERs were attributed to design, manufacturing,
construction or installation problems. Of these, five were
again a result of the sensitivity of the control room
chlorine detectors to moisture and the fact that onr. of two
instruments will initiate a control room isolation.
Further modifications were planned to revise the system
logic so that spurious signals on one instrument will not
cause an isolation, although this has been a chronic
problem.
o
'
The remaining LERs were the result of various problems
however, there did not appear to be any common cause or
programmatic deficiencies evident.
c. LER 87-47 was attributed to an external cause in that a
- control room isolation occurred in respcise to apparentir
l higher than normal chlorine levels in the atmosphere
however the source of the chlorine could not be identified.
d. Eight LERs were a result of procedural deficiencies. On an
annualizec basis this represents an approximate 20%
reduction from the previous assessment period and mairitains
a downward trend noted in the previous SALP. A detailed
, review of the eigh. LERs did not reveal any cause for
! cnncern that a systematic problem may be present in the
station's procedure writing and revision programs.
l
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- 42
e. Component failures accounted for 12 LERs during the period.
This represents a negligible increase in the rate of
component failures over the number experienced during the
previous period. A detailed review did not indicate any
maintenance program, procedure, or performance problems
which may have contributed to the failures,
i
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TABLE 1
Inspection Hours Summary
February 1, 1987 - April 30, 1988
Limerick Generating Station Unit 1
Hours % of Time
A. Plant Operations 1191 29
B. Radiological Controls 429 11
C. Maintenance 503 12
D. Surveillance 549 14
E. Engineering / Technical Support 958 24
F. Emergency Preparedness 121 3
G. Security and Safeguards 281 7
H. Safety Assessment / Quality Verification *
__
TOTAL 4032 100
- Hours expended in the area of safety assessment / quality verification are
included in other functional areas.
Inspection hours are the result of NRC Inspection Report Numbers 87-05 through
31, anc Numbers 88-01 through 0 3.
i
Total hours represent a 15-month assessment period, and are equivalent to 3226
hours on an annualized basis. Approximately two-thirds of th( total time (2650
hours) was expended by resident inspection documented in 11 reports. The other
one-third of the total time (1382 hours0.016 days <br />0.384 hours <br />0.00229 weeks <br />5.25851e-4 months <br />) was expended by specialist or team
inspections (EQ, EP, Restart and E0P teams) as documented in 22 reports during
the assessment period,
i
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e <* .
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, 44
TABLE 2
Enfor ement Summary
Limerick Unit 1
'
2/1/87 - 4/30/88 .
Violations and
S_everity Level
Functional Area III IV V Subtotal
A. Plant Operations 0 2 1 3
B. Radiological Controls 0 0 0 0
C. Maintenance 0 0 1 1 ,.
D. Surveillance 0 0 0 0
E, Engineering / Technical 1 4 0 5
Support
F. Emergency P.eparedness 0 2 0 2
G. Security / Safeguards 0 1 0 1
H. Safety Assessment /
Quelity Verification r
TOTAL 1 9 2 12
l
1
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L
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,
<$ ~
, 45
TABLE 3
Licensee Event Reports
Limerick Unit 1
2/1/87 - 4/30/88
Number by Cause
Functional Area A B C D E X Subtotal
i
A. Plant Operations 20 2 0 1 4 3 20
B. Radiological Controls 0 0 0 0 0 0 0
C. Maintenance 3 1 0 0 2 1 7
D. Surveillance 16 1 0 6 4 0 27
E. Engineering / Technical 3 17 0 1 2 5 28
Support
F. Emergency Preparedness 0 0 0 0 0 0 0
G. Security /Saf(guards *
H. Safety Assessment / 0 0 0 0 0 0 0
Quality Verification
TOTALS 32 21 0 8 12 9 82
- Security Event Reports are discussed separately in Section III.G.
Causal Codes: A. Personnel Error
B. Design, Manufacturing or Installation
C. Unknown or External Cause
D. Procedure Inadequacy
E. Component Failure
X. Othe-
As discussed in Section V.0, LER tabulations include LER Nos. 86-57, 87-01
to 70, and 68-01 to 11.
i