Text

SALP Rept 50-352/87-99 for Feb 1987 - Apr 1988
	ML20150B301
Person / Time
Site:	Limerick
Issue date:	07/07/1988
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
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ML20150B299	List: ML20150B297; ML20150B301;
References
	50-352-87-99, NUDOCS 8807110470
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ENCLOSURE 3

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT NO. 50-352/87-99

PHILADELPHIA ELECTRIC COMPANY

LIMERICK GENERATING STATION

UNIT I

ASSESSMENT PERIOD:

FEBRUARY 1, 1987 - APRIL 30, 1988

BOARD MEETING DATE: JUNE 8, 1988

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TABLE OF CONTENTS

Page

I.

INTRODUCTION

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A.

Purpose and Overview .

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B.

SALP Board Members . . . . . . . . . . . . . . . . . .

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CRITERIA

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III.

SUMMARY OF RESULTS

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A.

Overall Evaluation .

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B.

Background Activities. . . . . . . . . . . . . . . . .

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1.

Licensee. . . . . . . . . . . . . . . . . . . . .

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2.

Inspection.

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C.

Performance Summary.

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D.

Unplanned Shutdowns, Scrams and Forced Outages . . . .

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IV.

PERFORMANCE ANALYS!$. . . . . . . . . . . . . . . . . . . .

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A.

Plant Operations . . . . . . . . . . . . . . . . . . .

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B.

Radiological Controls

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C.

Maintenance

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Survaillant.e . . . . . . . . . . .

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E.

Enotneering/ Technical Support.

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F.

Em4 rte >.cy Frepareaness . . . . . . . . . . . . .

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G.

Security and Sa'egaards

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H.

Sainty Assessn r it/ Quality Verification . . .

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V.

SUSP6RTING DATA AND SUMMARIES . . . . . . . . . . . . . . .

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A.

Ira 3Stigatiot.s and A11enations . . . . . . . . . . . .

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B.

Escalated Enforcement Actions

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C.

Management Conferences . . . . . . . . . . . . . . . .

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U.

Licensee Event Reports . . . . . . . . . . . . . . . .

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1.

Report Quality.

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2.

Causal Analysis . . . . . . . . . . . . . . . . .

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Tables

Table 1 - Inspection Hours Summary

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Table 2 - Enforcement Summary .

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Table 3 - Licensee Event Reports

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I.

INTRODUCTION

A.

Purgose 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

management 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, 1983 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 II of this repcrt

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This report is the SALP Board's assessment of the licensee's safety

performance at tha Limerick Generating Station Unit 1 for the period

February 1, 1937 through April 30, 1988.

The summary findings and

totals reflect a 15-month assessment period.

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B.

SALP Board Membars

Chairman

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W. F. Kane, Director, Division of Reactor Projects (DRP),

Members

W. Johnson, Director, Division of Reactor Safety

G. Sjoblem, 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

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R. Gallo, Chief, Operations Branch, DRS

S. Collins, Deputy Director, DRP (Part Time)

E. Kelly, Chief, Technical Support Section, DRP

J. Linville, Chief, 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, Peach Bottom

J. Williams, Project Engineer, DRP

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J. Gadzala, Reactor Engineer, DRP

W. Pasciak, Chief. Effluents Radiation Protection Section, DRSS

T. Dragoun, Senior Radiation Specialist

R. Summers, Emergency Responsive Coordinator, DRSS

R. Keimig, Chief, Security and Safeguards Section, DRSS

H. Gregg, Senior Reactor Engineer, DRS

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II.

CRIT _ERIA

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Licensee performance is assessed ic 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.

1.

Management involvement in assuring quality

2.

Approach to resolution of technical issues from a safety standpoint

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3.

Responsiveness to NRC initiatives

4.

Enforcement history

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Reporting, analysis and corrective actions for operational events.

6.

Staffing (including management)

7.

Training effectiveness and qualification programs

Based upon the SALF Board tssessment each functional area evaluated

is classified into one of these performance categories.

The definitions

of these performance categories are:

Ca_tegory_1.

Reduced NRC attention may be appropriate.

Licensee

managament attention and involvement are aggressive and oriented

toward nuclear safety; licensee resources are ample and effectively

used so that a high level of performance with respect to operational

safety is being achieved.

Category 2.

NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and

concerned with nuclear safety; 14:ensee resources are adequate and

reasonably effective such that satisfactory performance with respect

to operational safety is b3ing achieved.

CategoA .

Both hkC and licensee attention should be increased.

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Licensee managemens attention or involvement is acceptable and

considers nuclear safety, but weaknesses are evident; licensee

resources appear strained or not effectively used 50 that minimally

satisfactory performance with respect to operational safety is being

a t.hi eved.

Trend.

The SALP Board may decide to include an appraisal of the

performance trend of a functional area.

Normally, this trend

will only be used when both a definite trend of performance is

discernible to the Board, and the Board believes that

continuation of the trend will result in a change of performance

level.

Improving:

Licensee performance was determined to be improving

near the cle.se of the assessment period.

Declining:

Licensee performance was determined to be declining

near the close of the assessment period.

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III. SU MARY OF RESULTS

A.

Overall Evaluation

Duri,1g the assessment period site performance has remained strong

despite additional pressure associated with a major corporate reorgani-

zation. Site management has been very effective in providing the

leadership necessary to achieve this performance, to maintain good

morale and to foster a strong safety perspective throughout the site

organization. The completion of the reversal in performance 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 corporate support was evident for the security area, in other

areas such as engineering and technical support, and emergency

preparedness ineffective corporate oversight and support has resulted

in a decline in performance.

In the area of emergency preparedness

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 previou:ly fragmented quality

organization, further corporate management attention appears to be

necessary to assure accountability from corporate support groups.

Strong performance has continued in plant operations, radiological

controls, maintenance and surveillance.

In operations a strong team

of operators, operations management, 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 ne,<1y licensed

BWRs this period.

Corporate support for the radiological environ-

mental monitoring was demonstrated 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 corrected and the conduct of maintenance and surveillance is

typified by strict adherence to procedures.

Safety review committees

are used effectively.

Site management and supervision have been effective in maintaining a

positive attitude of teamwork at all levels of the organization.

This is considered to be the principal factor in the continuation of

the overall strong performance exhibited in prior SALP periods.

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B.

Background Activities

1.

Licensee

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Unit I completed a 198-day continuous power run at the end of

the previous assessment, followed by a controlled shutdown to

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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, 1937.

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 corrective

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maintenance to 20 control rod drives, rebuilding of feedwater

valves, the replacement of all 14 nain steam safety relief

valves, and extensive preventive maintenance including tear-down

and overhaul of Reactor 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

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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

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through 7 to 83*o power. An automatic scram occurred on

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September 7 due to a turbine trip on high water level in a

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moisture separator because of an isolated instrument air supply

to the moisture separator level controls.

Recovery from the

scram began the following day and full power was achieved by

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September 17.

Full power operation continued for approximately

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five days until an automatic scram occurred on September 19, due

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to a turbine trip caused by rupture of a weld on an electro-

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hydraulic control (EHC) system line to a main turbine control

valve.

Recovery from the September 19 scram began the following day,

but the unit renained at 85*; pov.r for the following 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

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localized corrosion. No detectable increase in offgas releases

was experienced, although coolant radioiodine activities

increased by a fTctor of about ten.

Reactor pow (t was

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maintained 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,

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1987.

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The pisnned outage lasted 10 days and was for condenser tube

cleaning and circulating water system improvements.

Feedwater

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valve repairs, Intermediate Range Monitor (IRM) replacements and

several modifications were also accomplished.

Unit I was

returned to power en April 22. At the end cf the assessment

period Unit 1 was operating at reduced power because of the fuel

leak.

Organizational changes at the station level and at corporate

occurred throughout the assessment, including reass1gnment of

the station manager to Peach Bottom and announcement of a new

station manager on January 1, 1938.

Ths ,rospective station

manager remained in a special license fataliarization training

program through the end of this assessment period, and is

expected to assume the duties of Limerick Unit 1 Station Manager

in August 1938.

The licensee announced a major corporate reorganization of the

company's Nuclear Operations and Support Services which became

effective on November 1, 1987.

Changes included creation of: a

Vice President for the Limerick Station, assumed by the former

Unit 1 Plant Manager; corporate Vice President: for newly formed

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Divisions of Nuclear Services and Nuclear Engineering; and a

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Senior Vice President, Nuclear.

The reorganization also involved

reconstituting the Nuclear Review Board (NRB) to include member-

ship of three senior executives outside of PECo.

The site

organizations operated in a transition for the latter part of

this assessment.

The Vice President of Limerick remained in an

acting station manager position through the end of the assessment

period.

On February 2, 1988, the President and Chief Oparating Officer

announced his retirement effective March 1, 1983. On February

16, 1988, a new Executive Director Nuclear from outside the

PECc 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 Chas. man and

Chief Executive Officer announced his retirement effective April

13, the date of the licensee's annual board meeting.

The Board of

Directors elected a new Chairman and Chief Executive Officer,

a former PECo Vice President who had recently been elected

President and Chief Operating Of ficer at another utility.

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2.

Inypection

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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 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months or 3,226 hours0.00262 days 0.0628 hours 3.736772e-4 weeks 8.5993e-5 months 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 period, the secor.d year of commercial

operations was reviewed as well as the Unit 1 initial refueling

outage.

NRC inspection 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 evaluat. s of Safety Assessment /Qutlity

Verification as a new functioc , area.

The topics assessed in

this new area include Licensing activities as well as what

was formerly covered under the As5arance of Quality. Also,

Tra:ning and Qualifications is no longer a separate functional

area and is included.

Refueling activities were evaluated as part of the Engineering /

Technical Support functional area for the first time during this

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assessment period.

Fire protection is assessed, as in previous

assessments, in the functional area of Operations, since there

was no spe"ial programmatic inspection in this area.

House-

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keeping is included in the area of maintenance.

Security

continued to receive increased inspection effort, as in previous

assessments, because of past identified weaknesses.

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C.

Performance Summary

Functional

other 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

program is strictly maintained using grease procedures and locally

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posted instructions on proper lubricant and fill points.

Conduct of maintenance is 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) expertence

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.

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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 area.

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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 nieaningful measures such as:

high priority non-outage

workable corrective jobs older than 60 days 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.

Staffing was improved by consolidation of maintenance groups as part

of the corporate the reorganization.

The licensee supports 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 feedback and supported by a site maintenance training

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representative.

Special courses have been devised and plant specific

mockups are effectively employed.

Supervision and control of contractor maintenance is a recognized

problem, as evident in the undervessel damage incurred during the CR0

rebuilds and by QA audits of selected outage jobs.

The licensee has

already taken steps towards improving contractor workmanship by

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appointing a dedicated licensee foreman for outage undervessel work,

a supervisory engineer for reactor work during refueling, and better

screening and training of contractors.

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Summary

In summary, several 'evels of management are effectively involved in

maim:enance; equipment reliability has been excellent; maintenance

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

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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 1

Board Recommendations

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D.

Surveillance (549 hours0.00635 days 0.153 hours 9.077381e-4 weeks 2.088945e-4 months ; 14%)

Analysis

Surveillance was rated Category 1 during the previous assessment.

Testing successfully confirmed operability and identified equipment

problems, and benefited from involved supervision and cood engineer-

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ing support.

Relatively few instances of missed tests occurred.

During this assessment period the success of the programs depended

upon 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

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assessments were significantly reduced such as instrument valving

errors, missed fire watches, reactor water cleanup system isolations

and difficulties with toxic gas analyzers.

Surveillance 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 staf f in the technical engineering group.

Trending is also

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reported-routinely to the PORC. Another useful trending initiative

is the plant electronic notebook system (PENS) which involves

computerized data entry from the daily surveillance log.

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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

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and exhibit good understanding and respect for station adm'nistrative

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controls.

The licensee's sensitivity to scram potential is demonstrated by ac

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A-day /B-day logic channel test schedule:

coded into the computerized

scheduling system and incorporated in admi.nistrative procedures;

stamped in red on procedures; and posted in the main control and

auxiliary equipment rooms.

This disciplined approach to testing is

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used to prevent coincident logic actuations and demonstrates good

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control over testing.

The conduct of testing is founded on effective communications and

professional working relationships between test personnel and

licensed ooerators.

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

modification testing during the refueling outage.

Inservice Testing

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(IST) is similarly well-coordinated.

Some management deficiencies

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were noted with the Containment Integrated Leak Rate Test (CILRT)

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involving overuse of tags, an extensively revised procedure, building

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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 surveillarce 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 identif:ed, as in one case where planning for weekend work

loads identified an incorrect test date.

The master test schedule 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

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undetected reversal of thermocouple leads.

Test procedures implicitly

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allow for sound communications between test personnel and control

room operating staff, including a pretest briefing on expected alarms

and the impact on system operability. A consistent technician

appr3ach is to suspend test activity when a procedural error or

equipment discrepancy is found until the problem can be resolved.

The licensee has created an atmosphere wherein personr.el reJtinely

exhibit attentien to dateil and involve their surervilion when

at.tivities are in question. Color e.oded instrument cabinets'in the

auxiliary equipment room have reduced the potential for human error

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associated with divisionalized testing. The licensee minimized the

use of lifted leads during testing and has virtually eliminated

inaccessible test points.

Station management has communicated to

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work groups that activities should be conducted with the idea of

eliminating system challenges.

Improved communintions between test persunel and operators,

development and use of procedures that comply with human factors

guidelines, involvenent of first line-supervision, and routine use of

root cause 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,

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Certification training during this assessment period has been effec-

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 t.ie

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.

Much of the quality oversight of surveillance is accomplished in PORC

meetings. A plant incident tracking system has been effective in

focusing on the more safety significant fssues that occur from

day-to-day.

The licensee's QA and QC involvement in surveillance

testing has been minimal, and has not provided assu ance of the

effectiveness in activities in areas such as independent verifica-

tions.

Summary

Management's oversight of testing has been strong.

Clear account-

ability for testing performance is ensured by the scheduling program.

Workers and technicians exhibit attention to detail and have the

benefit of dedicated technical support, including new developments in

trending.

The licensee has demonstrated an aggressive approach to

testing beyond mere compliance with recuirements.

Conclusion

Category 1

Boa rd__Pecommenda ti on s

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.

E.

Engineering / Technical Support (958 hours0.0111 days 0.266 hours 0.00158 weeks 3.64519e-4 months , 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 corporate 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 tne vibrations could be achieved.

Site engineering support for tha inservice testing (IST) of pumps and

valves was found to be well coordinated, staffed with technically

competent personnel and had a hign decree of site management involve-

tent.

The IST organization was a knowledgeable cohesive group that

closely interfaced with their maintenar.ce department cNnterp&rts.

Site engineering interf aced with corporate engineering and requested

their assistance when needed.

However, corporate engineering

i

guidance appeared to be lacking and did not appear to thoroughly

l

evaluate some issues.

Examples int.luded programmatic deficiencies

l

with document control, ill-defined organizational and personnel

l

responsibilities, and discrep ncies between the licensee's criteria

and ASME Coda Section XI.

In response to past engineering support

deficiencies, corporate engineering is oresently 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 four emergency diesel

generators (EDGs), resulted in escalated enforcement.

Although an

associated problem involving a deficiency in the EDG time delay

setting was identified by the licensee as early as June 1984, the

-

- -

. _ .

_-

.

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.

Prior 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 E0 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 fuel load

over three years ago. Application of TCAs had doubled over each of

the past three years, with approximately 25% not restored or

permanently modified. While corporate engineering provided timely

engineered design packages to support major refueling outage license

l

condition modifications, the increasing numbar of TCAs indicated an

inability to support routine plant operation.

In the latter half of

the assessmer.t peried 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 difficulties requiring more aggressive corrective

action, such as the inordinately large number of secondary contain-

ment isoldtions. Whi'ie various root causes could be assigned to

thtse, the overriding issue invoh es blocking and tagging errors due

to lack of identification of instrument air lines.

This problem was

,

[

alsa the apparent cause of a scram in September 1987.

Site technical

engineers completed an exhaustive welkdov.n ef accessible air lines by

the end of the period.

This concern was also raised by the Nuclear

Review Board but lonpr term solutions are siill forthcoming.

Past

chronic reportable events involving 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 solution has been delayed.

In certain other events ( .g.

LER 87-42 regarding RPS relays) the licensee demonstrated a

philosophy to go beyond mere compliance with requirements in p suit

l

of the root cause.

l

Planning and technical support were excellent for the ref ' ling

outage.

Staffing in health physics, QA and QC were ircr ased,

assuring better outage coverage, including detailed au ts for

I

license conditions. Management concern for reactor s ety was

!

evident by establishment of a refueling floor outag organization

with well defined lines of communication and by ce sain outage

i

,

conservatisms including the NRB's concern to ass e backup decay heat

removal using fuel pool cooling systems during

anned modifications

to emergency service water systems.

Althou h aanagement's decision

to secure ventilation systems on the refu

floor in August during

hot humid weather necessary to tie-in st

gas treatment caused

worker heat stress problems and some A

neerns (see section

III.8), that philosophy was abandoned

ontingencies wera employed

after worker feedback was received.

icensee successfully

employed a modification coordinato

ilar to test coordinators for

complex surveillances described

A

ion III.C) for critically

complicated changes, such as t /(/

tie-in, which involved many

work groups.

[(/

A high degree of technical @

nagement support of the ISI Program

was ed denced by the use [

r recording and processing ultrasonic

General Electric Company "Smart UT"

which .s an advanced sy

examination data, and

comprehensive QA coverage of ISI activi-

ties.

The ISI Progr

dequately staffed with well trained

,

personncl.

QA staf

onsible for ISI are kncwledgeable and

!

competent to moni

.se activities.

l

The licerisee h

.tained an up-to-date PRA, primarily in antici-

!

pationofUnig

censing questions.

However, extensive use of the

study where g

Id seemingly contribute to Unit 1 operating

decisions

.s preventive traintenance and modifications has not

been made.'

tain Unit 2 milestones such as tie-in of service water

systems (

rticularly far diesel preoperational testing) have been

well pl

ned and were presented to the NRC in advance of dual unit

oper&t

n.

Also, ergineering solutions to past problems such as FASS

reli

ilft.v and interunit contamination of shared systems have been

eff tively resclved and applied to Unit 2 as well,

mmary

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

support for outage activities was effective, corporate support for

routine operating activities was not always so.

.

..

_ _ - _ _ _ _ _ _ _ _

_

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

'

29a

.

l

engineering solution 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.

l

Planning and technical support were excellent for the refueling

outane.

Staffing in health physics, QA and QC were increased,

l

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 end some ALARA concerns (see section

III.B), 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 Sectisn III.C) for critically

complicated changes, such as the SGTS tie-in, which involved many

work groups.

A high degree of technical 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 monitor these activities.

The licensee has maintained an up-to-cate PRL, primarily in antici-

pation of Unit 2 licensing questions.

However, extensive use of t%

study where it would seemingly contribute to Ur.it 1 operating

decisions such as preventive maintenance and modifications has not

been made.

Certain Unit 2 milestones such as tie-in of service water

systems (particularly for diesel preoperational testing) have been

well planned t.nd were presented to the NRC in advance of dual unit

operation.

O so, engineering solutions to past problems such as PASS

reliability and interunit contamination of shared systems have been

effectively resolved and applied t3 Unit 2 as well

l

Summary

In summary, although engineering and technical support for the first

j

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

support for outage activities was effective, corporate support for

routine operating activities was not always so.

_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

- _ _ _ - .

.

30

.

Near the end of this evaluaticn period an increase in iodine

activity in the coolant was identified as due to leaking fuel.

Heat

l

flux restrictions to minimize further fuel degradation have caused a

l

power derating of the plant. Although the cause of the leakage has

l

not been fully determined, 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

l

_ _ _ - _ _ _ _ .

____ -______ __

__

.

31

.

F.

Emergency Preparedness (121 hours0.0014 days 0.0336 hours 2.000661e-4 weeks 4.60405e-5 months ; 3?f)

Analysis

During the previous assessment period, itcensee performance in this

area.was rated Category 1.

This was based upon good exercise

performance and the licensee's own initiatives in routine emergency

,

j

preparedness activities.

j

f

During the current assessment period, one routine safety inspection

was conducted, one full participation emergency exercise was

.

l

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.

l

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

l

violation was issued for the licensee's failure to take corrective

,

action on outstanding Emergency Preparedness Program deficiencies

l

identified by their own audit program.

.

The audits of the Emergency Plan, Emergency Plan Procedure , and

Corporate Proceaures noted in the precteding paragrapk have bean

!

conducted by the corporate organizatior, with contractor suoport every

12 months. These audits were performed in adequate detail to provide

j

essurance that potential weaknesses were identified and discussed

l

with emergency preparedness management.

However, two separate 1986

l

ir, dependent audits were performed which identified recurrent program

deficiencies.

The results of both audits were sent to the Director,

Emergency Preparedness.

No action was taken by the ccrporate Emergency

Preparedness staff or other management to correct these identified

deficiencies.

This led to an NRC finoing that formal distribution of

the 1986 audit results to appropriate plant or corporata management

was not made.

In thi lic9ntee's 1987 QA tudit report se u rci new

findings were identified in addition to recurring program deficiencies,

which irdicates an inadequate respense to self identified problems.

Deficiencies associated with program management and the independent

review process remained unresolved, an Action Item Management Team

was established to address these concerns.

_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ _

,

.

..

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ .

..

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

observed 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 suffered as a result.

Scenario development and review via

l

contract support has been acceptable.

The Director, Eeergency

l

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 program;

however the effectivness of these improvements have not yet been

assessed by the NRC.

Emergency Response Facilities (ERF) are dedicated and have been

adequately maintained throughout the period.

Summary

In sammary there appears to be adequate ability to respond to

emerpencies, however, it apcears that the strong ir,terface exhibitud in

previous assessments betseen the cc parste emerD!ncy preparedness

staff and the SEPC/ site support staff has been weakened.

Responsi-

bility for assignnent a.nd comple:ian of tite daties is assumed by the

SEPC without adeouate resources or direction from the corporate

stuff.

Conclusion

Category 2

1

l

Coard Recomm?ndations

l

Licensee

1.

Focus additional attention on resolving outstanding audit

findings and institute more timely corrective action for them.

,

l

J

2.

Ensure effective completion of required Emergency Preparedness

Program tasks, including planned correedye action resulting

from identified deficiencies.

l

_

.

..

. _ _ _ - _ -

_ - - .

\\

.;

33

c.

G.

Security and Safeauards (231 hours0.00267 days 0.0642 hours 3.819444e-4 weeks 8.78955e-5 months , 7%)

Analysis

'

During the previous 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 matched to a substantial degree by the licensee's security

contractor. This combined effort to establish and maintain an

effective and high quality security program resulted in excellent

performance throughout tne period (one minor violation), in addition

to further program enhancements.

The additional enhancements included:

(1) establishing a Security

k

Incident Review Committee composed of operations and security

management personnel, to evaluate all security events for plant

safety and security consequences; (2) providing proprietary shift

,

l

supervisors specialized training in alarm station operations, audits,

l

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 1 program

and assigning responsibility for the transition to an individual with

no concurrent Unit 1 procram duties.

The implementation of further

enhancenents provide continued evidence of managements' further

,

I

interest in maintaining an effective program rather than a compliance

!

oriented program,

l

The licensee continued to use a self appraisal program to monitor the

on going performance of the security force and to identify potential

problems easily and correct them effectively.

The responsibility for

implementing this program was reassigned fron the security contractor

to the licensee's proprietary Supervisors during this period. The

self-appraisal rrogram combined with other security progran audits

and surveillances, and the NT requirni annual program review, is

believed by NRC, to be a significant fattar in improving the security

program and is indicative of the licensee's desire to achieve high

que+v in its program implementation. This was also apparent by the

O s actions in respor.se to generic Regulatory Effectiveness

1

s-

he is

indings.

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, promptly corrected potential problems.

.

34

.

The licensee's security contract also continued to make enhancemen s

to its portion of the program.

These included:

(1) improving t

established security force training program by refining lesson

ans

and obtaining additional training aids; (2) providing additio I

emergency preparedness task training (3) renovating the equi ment and

arms room and revising arms issue procedures; (4) developi

a pool

of trained and qualified supervisory personnel to provide an effec-

tive line of succession; ana (5) developing and impleme ing on post

security task certifications.

In addition, the contra tor exerted a

commendable effort to improve employment benefits an human factors

for the guard force in order to strengthen morale.

Security management involvement in industry and

C initiatives

involving nuclear power plant security progras d throughout the

period in response to identified problems,

nstrating management

support of the program.

In addition, the

see has taken very

aggressive measures to reinforce its Fi

or Outy Policy and to

achieve a drug free work place for per

at the Limerick

Generating Station. On several occa

uring the period, the

licensee conducted drug sweeps of

tion using specially trained

dogs, pursued in-depth investigat A

alleged drug related

activities, provided special dr d/

eness training sessions for

supervisory personnel, and enf

ppropriate disciplinary actions

for offenders. The licensee'

iatives in this regard are

exemplary and demonstrate a

esponsible position to ensure

public health and safety.

V

The training program i

A , mented by well qualified and

experienced instructo

no :orcurrent duties.

Facilities and

equipment are adequ

lesson plans are well developed and kept

i

current through va i

redback mechanisms, including the self-

,

assessment and o

W

task certification programs.

The initiatives

implemented dur ,

previous as ,essment period, particularly the

revisions to

res and post instructions to makc them clear and

f

concise, wer -

ontly effective as indicated by the relativcly

small rumba

guard force personnel errors.

Staffing

proprietary and contractor organizatien is effective

as evide

G by the effective oversight and ex:ellent performance

.

during fie period.

Staf*ing of the guard force also appears to be

suffi

nt as indicated by the limited use of overtime.

This is also

!

cons tred by the NRC, to be a significant f actor in iraproving the

i

pro.ran and indicative of the licens,ee's desire to achieve high

q

lity in program implementation.

The licensee's event reporting procedures were found to be clear and

consistent with the NRC's new reporting 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 resulted from

,

a computer failure, and the seventh resulted from the detection of a

!

l

. - -

-

.

'.

34a

The licer.see's security contractor also continued to make enhance-

ments to its portion of the program.

These included:

(1) improving

the estaM ished security force training program by refining lesson

plans aim obtaining additional training aids; (2) providing addi-

tional emergency preparedness task training (3) renovating the

equipment and arms room and revising arms issue procedures;

(4) developing a pool of trained and qualified supervisory personnel

to provide an effective line of successien; and (5) developino and

implementing on post security ta:k certifications.

In addition, the

contractor exerted a commendable effort to improve employment bene-

fits and human factors for the guard force in order to strengthen

morale.

Security management involvement in industry and NRC initiatives

involvir.j n miear power plant security progressed throughout the

period it response to identified problems, demonstrating maragement

support of the program.

In addition, the licensee has taken very

aggressive measures to reinforce its Fitness for Duty Policy and to

achieve a drug free work place for iersonnel at the Limerick

Generating Station.

On several oct sions during the period, the

licensee conducted drug sweeps of tne Station using specially trained

dogs, pursued in-depth investigations of alleged 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 progra.t 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 various feedback mechanisms, including the self-

assessment and on post task certification programs.

The initiatives

implemented during the previous assessment period, particularly the

revisions to 'rocedures 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 effective

as evidenced by the effective oversight and excellent performance

during the period.

staffing of the guard force also appears to be

sufficient as indicated by the limited use of overtime.

This is also

considered by the NRC, to be a significant fat. tor in improving the

program and indicative of the licensee's desire to achicve F'gh

quality in program implementation.

The licensee's event reporting procedures were found to be clear and

consistent with the NRC's new reporting 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 resulted from

a computer failure, and the seventh resulted from the detection of a

--

.

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

35

.

weapon at a protected area access control point.

Each report was

clear and concise, and indicated appropriate response to the reported

event.

During the assessment period, 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 ensuring that

plans are current and for coordinating changes, when required.

The

licensee's staff is very effective in carrying out this responsibi-

lity.

They cften communicate and review changes with the NRC to

ersure 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 its security contractor continued to

strive for an effective and high quality program throughout the

period.

Significant improvements were made to the program and these

resulted in excellent performance and implementation of a security

program that is oriented toward meeting the NRC's nuclear plant

security objectives rather than merely regulatory compliance.

The

efforts expended dur;ng this period (a-d the preceding period) are

commendable and demonstrate the licensee's ability to turn a marginal

progr;m into a high quality program through management involvement,

attention and oversight.

Conclusion

Category 1

Board Recommendations

Licensee:

Continue initiatives to further enhance program.

f

I

1

,

l

1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _ _ _ _ _

-

.

36

.

H.

Safety Assessment /0uality verification

Analysis

Assurance of ouality has been considered as a separate functional

area in past SALPs, in addition to being one of the evaluation

criteria in functional areas, and was rated as Category 1.

This area

has been expanded to encompass activities previously evaluated in

Licensing, including safety evaluations. This discussion is a

synopsis of quality and safety 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 management goals, planning

of routine activities, worker enthusiasm, managcment involvement, and

training are examples.

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-

ficing 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 tre nearing

resolutions.

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 staff ed and well trained

group.

Management overview is evident as warranted.

The Plant Operations Review Committee (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.

Routine meetings are reflected by excellent written

minutes that provide a good reference for station performance.

The

value of PORC safety decisions is a result of the professional

meeting atmosphere developed by past station managers and continued

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 underscorino the

importance to safety of routine tasks, including quality and

,

M

_

..

37

.

excellence banners.

Station manager memoranda to site personnel

commend them for a job well done such as the outage, or serve 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 operation.

Safety evaluations (modifications, TCAs, new procedures, and general

plant issues) have been insightful and complete.

Prior to the reorganization the licensee's quality verification

groups (QA/QC) were fragmented among work organizations which diluted

their effectiveness 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 t'.eir own problems, QA/QC has not been an essential ingred-

ient in assuring operating excellence.

Quality group involvement in

certain areas such 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 conscientious 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 i.volve-

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

recurring.

The Nuclear Review Board (NRB) was reconstituted at the beginning of

this period, including the addition of three senior consultants. The

Board has progressed to a more thoughtful diagnosis of problems, as

evidenced by focus on issues during the refueling outage concerning

decay heat removal and the increased number of personnel contamina-

tions. All of the 11censee's shift superintendents have had an

opportunity to address the NRB in a full meeting on topics renging

from Peach Bottom feedback to the selection process for promotions.

The NRB has also expressed increased awareness for the effect of Unit

2 preoperational test preparations.

. _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

38

.

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 been eliminated.

The detail presented in LERs has been excel-

lent, reflecting the strong 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 Prepared-

ness Progr:m 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 sensitivity to people,

and has allowed for the plant to survive difficult reorgani:ational

phases and other high expectations in light of questions regarding

Peach Bottom.

The leadersnip of suporintendents 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 Recommendations

None

_ _ . _ _ - .

- - . - -

-

_-

-_

.

-_

-

_

_ _ _ _ _ _ _

_ _ _ _ -

.

39

.

V.

SUPPORTING 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 contract personnel during this

period resulted in the discharge of several workers when drug tests

confirmed the information or when they refused to submit to a test.

A forth drug allegation could not be pursued due to inadequate

information from an anonymous source.

B.

Escalated Enforcement Actions

Level III violation (no civil penalty) for Appendix R diesel fire

flow switch design.

C.

Management Conferences

On July 7, 1987, the licensee met with NRC management on site to

discuss the previous SALP report findings.

On October 8, 1987, licensee engireering representatives met with NRC

Region I personnel in King of Prussia to discuss the technical

aspects relating to flow switches in the tire suppression system

which could have affected ciesel generatar operability.

On October 22, 1987, an enforcement conference was held at the NR

Region I office in King of Prussia te discuss a violation of 10 C)..

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 good. 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 f rom

added attention. The licensee routinely supplements LERs with

additional findings and has a good 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 wr:re late.

-

_

,

.

- - -

-

-- - -

'

.

40

o

2.

Causal Analysis

Number

Percent

A.

Personnel Error

32

39

B.

Design /Manuf./Constr./ Install.

21

26

C.

External Cause

0

-

0.

Proceduce 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 s d root cause

a

identification.

The following sets of common mode

events were identified:

a.

Thirty-two LERs were attributed to personnel error.

(Approximately 26 on an annualized basis.) These LERs

accounted for approximately 40% of the events reported as

was the case during the previous assessment period.

As shown in the follow":ig table the refueling outage period

accounted for a significant percentage (56%) of the total

number of personnei 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

percertage of the total.

__ _______ ____ _

.

M

.

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-Aig 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*f, respectively, of the

remaining LERs.

Increased management attention to personnel errors 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 one of two

instruments will initiate a control room isolation.

Further modifications were planned to revise the system

l

logic so that spurious signals on one instrument will not

cause an isolation, although this has been a chronic

'

problem.

l

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 response to apparently

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

annualized basis this represents an approximate 20*4

reduction from the previous assessment period and maintains

a downward trend noted in the previous SALP, A detailed

review of the eight LERs did not reveal any cause for

concern that a systematic problem may be present in the

station's procedure writing and revision programs.

. - . .

,_.

-

- -.

.

42

,

e.

Component failures acceunted 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 projram, procedure, or performance problems

which may have contributed to the failures.

l

.

43

.

'

TABLE 1

Inspection Hours Summary

February 1, 1987 - April 30, 1988

Limerick Generating Station Unit 1

Hours

f4 of Time

A.

Plant Operations

1191

29

8.

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 Veritication

__

TOTAL

4032

100

Hours expenued 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, and Numbers 88-01 through 08.

Total hours represent a 15-month assessment period, and are equivalent to 3226

hours on an annualized basis. Approximately two-thirds of the 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 0.384 hours 0.00229 weeks 5.25851e-4 months ) was expended by specialist or team

inspections (EO, EP, Restart and E0P teams) as dor"mented in 22 reports during

the assessment period.

I

..,

s

44

.

TABLE 2

Enforcement Summary

Limerick Unit 1

2/1/87 - 4/30/88

Violations and

Severity Level

Functional Area

III

IV

V

Subtotal

A.

Plant Operations

0

2

1

3

8.

Radiological Contrcis

0

C.

Maintenance

0

1

0.

Surveillance

0

E.

Engineering / Technical

1

4

0

5

Support

F.

Emergency Preparedness

0

2

0

2

G.

Security / Safeguards

0

1

0

1

H.

Safety Assessment /

Quality Verification

TOTAL

1

9

2

12

.

e

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

A.

Plant Operations

10

2

0

1

4

3

20

B.

Radiological Controls

0

C.

Maintenance

3

1

0

2

1

7

0.

Surveillance

16

1

0

6

4

0

27

E.

Engineering / Technical

3

17

0

1

2

5

28

Support

F.

Emergency Preparedness

0

G.

Security / Safeguards

H.

Safety Assessment /

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

8.

Design, Manufacturing or Installation

C.

Unknown or External Cause

D.

Procedure Inadequacy

E.

Component Failure

X.

Other

As discussed in Section V.D, LER tabulations include LER Nos. 86-57, 87-01

to 70, and 88-01 to 11.

ENCLOSURE 4

..

[#'poing

UNITED STATES

g

NUCLEAR REGULATORY COMMISSION

.

j

.$

REGION I

' " '

'

,

f

475 ALLENDALE ROAD

,

of

KING OF PRUSSI A, PENNSY LV ANI A 194o6

.....

07 JUL 1988

Docket No. 50-352/NPF-39

Philadelphia Electric Company

ATTN: Mr. C. A. McNeill

Executive Vice President

Nuclear

2301 Market Street

Philadelphia, Pennsylvania 19101

,

Gentlemen:

Subject: Systematic Assessment of Licensee Pei ormance (SALP) Board Report

'

Number 50-352/87-99

-

An NRC SALP Scard has reviewed and evaluated the performance of activities at

the Lim:-.ek Generating 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.

At the SALP meeting you should be prepared to discuss our assessments and your

plans to improve performance. The meeting is intended to be a candid dialogue

wherein any comments you may have regarding our report are discussed.

Additiondily, you may provide written comments within 20 days after the

meeting.

Your cooperation with us is appreciated.

Sincerely,

0

William T. Russell

Regional Administrator

Enclosure:

SALP Board Report No. 50-352/87-99

s tL ,

- sqttiffvt

W

.

,

- .

o,

.

3

<

o'

Philadelphia Electric Company

2

ggg

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 7ech

Commissioner Roberts

Commissioner Carr

Commissioner Rogers

!

1

4

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