ML20198B175
| ML20198B175 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/08/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 9812180090 | |
| Download: ML20198B175 (22) | |
Text
. . _ _ _ ._ . - . _ _ _ _ _ _ . _ . _ - _ _ . . _ . _ . . _ _ . _ . _ _ - .
December 8, 1998 l
Mr. G. Rainey, President.
PECO Nuclear Nuclear Group Headquarters Correspondence Control Desk P. O. Box 195 Wayne, PA ~ 19087-0195
SUBJECT:
Mid-Year inspection Resource Planning Meeting - Limerick Generating Station
Dear Mr. Rainey:
On November 10,1998,the NRC staff held an inspection' resource planning meeting (IRPM). The IRPM provided a coordinated mechanism for Region I to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in l
May 1999.
Enclosure 1 contains a historicallisting of plant issues, referred to as the Plant issues Matrix (PIM), that were considered during this IRPM process to arrive at an integrated view -
l . of licensee performance trends. The PIM includes only items from inspection reports or i other docketed correspendence between the NRC and PECO Energy. The IRPM may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
This material will be placed in the PDR as part of the normalissuance of NRC inspection l reports and other correspondence.
l f - This letter advises you of our planned inspection effort resulting from the Limerick IRPM l review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival '
I onsite. Enclosure 2 details our inspection plan for the next 6 months. Resident inspections are not listed due to their ongoing and continuous nature.
- We willinform you of any changes to the inspection plan if you have any questions, l please contact Clifford Anderson at 610-337-5227.
Sincerely, Original Signed by:
/
Clifford J. Anderson, Chief ;
Projects Branch 4 Division of Reactor Projects f 9912190090 981200 / -
! PDR ADOCK 05000352 [
r G PDR A&naes/mT OFFICIAL RECORD COPY .se pr ( ,s - wr -
- c. .rv .
I I . .
G. Rainey 2 Docket Nos. 50-352,50-353
Enclosures:
- 1) Plant issues Matrix l
- 2) Inspection Plan l
l cc W/encls:
l J. J. Hagan, Vice President, Nuclear Station Support
. G. Edwards, Chairman, Nuclear Review Board and Director - Licensing J. von Suskil, Vice President - Limerick Generating Station M. P. Gallagher, Plant Manager, Limerick Generating Station T. Moore, Manager, Experience Assessment Secretary, Nuclear Committee of the Board Commonwealth of Pennsylvania l
F I
l
l G. Rainey 3 Distribution w/encts:
l Region I Docket Room (with concurrences)
! H. Miller, RA/W. Axelson, DRA (1) l C. Hehl, DRP l J. Wiggins, DRS l
R. Crienjak, DRP L. Nicholson, DRS ,
DRS Branch Chiefs l
l C. Anderson, DRP D. Florek, DRP J. Lanning, DRP l J. Noggle, DRS G. Smith, DRS N. McNamara, DRS '
M. Oprendek, DRP R.Junod,DRP I NRC Resident inspector Nuclear Safety Information Center (NSIC)
PUBLIC Distribution w/ encl: (Via E-Mail)
B. McCabe, OEDO R. Capra, PDI-2, NRR B. Buckley, PD 1-2, NRR M. Thadani, PD 1-2, NRR R.' Correia, NRR M. Campion, ORA DOCDESK !
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\ BRANCH 4\PPR\ LIM \tRMP.11 To receive a cop of this document, indicate in the box: "C" = Copy without attachment / enc re "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rl/jbf)gP l Rl/DRP ,l NAME D @kj/ CAnderson ([G l
DATE 12$98 12/(f /98 U OFFICIAL RECORD COPY 4
G O
ENCLOSURE 1 LIMERICK PLANT ISSUES MATRIX .
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Coda item Description 7/06/98 Positive IR 98-04 N OPS 5B The root cause evaluation for the missed RPS PMT was thorough and addressed the most probable root cause(s) for the event. Primarily, the review of the RPS work packages by the work control personnel and control room supervisor was less than adequate. In addition, the outage schedule review of the relay replacement activities was also less than adequate. The RPS relay work order activities were moved forward in the refuel outage schedule and did not provide adequate review time to determine the impact of the relay replacement on plant activities.
7/06/98 NCV IR 98-04 L OPS 1C A breakdown of several barriers in the work control process resulted in missed Technical Negative LER 1-98-006 2A Specification (TS) post-maintenance test (PMT) requirements for the 'A' reactor protection system (RPS). Subsequent relay replacement in the 'B' RPS channel resulted in both channels being inoperab;e for approximately two and one-half hours. Once recognized, management implementcd immediate corrective actions to comply with the TS requirements and address the work control process deficiencies.
7/06/98 Positive IR 98-04 N OPS 1A Control room operators at Unit 1 performed overall reactor start-up activities well to complete refueling outage (1R07). The operators broad interpretation of a Note in the GP-2 procedure was corrected by operations management to allow the reactor core isolation cooling (RCIC) system tuning evolution.
7/06/98 Negative IR 98-04 L OPS 18 Material and procedural deficiencies challenged control room operators at Unit 2 which delayed the diagnosis of the inadvertent initiation of the standby liquid control system.
The response of the operators was adequate. The evaluation to address the impact of injecting sodium pentaborate into the reactor vessel along with the cleanup activities was acceptable.
6/19/98 NCV IR 98-05 N OPS SB A reactor water cleanup (RWCU) system engineered safety feature (ESF) actuation Negative NCV 98 occurred and was not reported to the NRC as required. The ESF actuation was not 04 reported due to the outdated information contained in the site reportability reference manual. Further review identified two additional RWCU isolations that had not been reported to the NRC for the same reasons.
From 3/98 to 9/98 1 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 5/18/98 Negative IR 98-03 N OPS 1A The operations organization demonstrated a weakness in technical specification 3A interpretation when the shift manager and operations manager both agreed that Technical Specification 3.0.3 did not have to be entered, when it should have been, when both control room emergency fresh air supply (CREFAS) systems were declared inoperable. It was inappropriate to base this decision on an expectation that an engineering evaluation would, in a short period of time, declare one of the CREFAS systems operable.
5/18/98 Negative IR 98-03 N OPS 1A Several problems with the licensee not keeping the unified log current and excessive use 3A of back dating of many of the log entries demonstrated weak log keeping practices and may have contributed to the missed control room emergency fresh air supply limiting conditions for operation.
5/18/98 VIO IR 98-03 N OPS 1A Operators failed to recognize, enter and log all the applicable limiting conditions for VIO 98-03-01 operation (LCO) related to the control room emergency fresh air supply (CREFAS) system inoperable equipment and thus demonstrated a weakness in understanding of the CREFAS technical specifications. Failure to make LCO entries in the control room unefied log is similar to problems noted in NRC inspection report 352,353/97-10 and is considered a violation of Appendix B, Criterion XVI, " Corrective Action," due to the repetitive nature of the issue.
5/18/98 Strength IR 98-03 N OPS 1A Control room and refueling bridge operators appropriately conducted Unit 1 shutdown activities. The shift supervision remained aware of scheduled and emergent outage activities and effectively coordinated field activities, thereby reducing work conflicts.
Outage management provided effective oversight to support the operations staff.
Operations management's decision to provide shutdown training at the site-specific simulator enhanced the operators' response and ability to effectively control the unit safely during the shutdown and cooldown. -
5/18/98 Strength IR 98-03 N OPS 1A Management ensured that adequate oversight of refueling outage 1RFO7 work was in place. The outage risk assessment model system effectively confirmed and documented when higher risk evolutions occurred in the outage schedule. Procedures were technically adequate and guidance was in place for maintaining decay heat removal available.
From 3/98 to 9/98 2 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 3/16/98 VIO IR 98-02 N OPS SC Deficiencies were identified with the control of locked valves, in that, a suppression pool hatch VIO 98-02-03 valve was not properly locked after a local leak rate test. This was a repetitive failure indicative of ineffective corrective actions for previous, NRC identified, locked valve problems.
3/16/98 Positive IR 98-02 N OPS 3A Operators responded well to degraded flow indications for the Unit 1 No. 2 jet pump.
SC Engineering and I&C technicians supported the operations staff in determining the operational condition and status of the clogged jet pump. Management implemented more restrictive limits >
for operation of the unit prior to and after the GE analysis was performed.
3/16/98 Positive IR 98-02 N OPS 1A Equipment operators performed well during routine tours. The operators were aware of plant parameters and alert to changing plant conditions.
3/16/98 Positive IR 98-02 N OPS 1A Cperators conducted the Unit 1 startup wellin a controlled fashion. Additional control room operators helped to minimize disturbances on the operator withdrawing the control rods. Good support by the reactor engineering staff was observed.
3/16/98 Negative IR 98-02 N OPS 5B The corrective actions planned and implemented for the loss of shutdown cooling event were LER 1-98-002 generally adequate; however, the root cause of the initial inability to re-open the shutdown cooling isolation valve was not identified. In addition, weaknesses vere noted with the licensees post-event review process.
3/16/98 Negative IR 98-02 S OPS 3A The reactor water cleanup jumper installation, the initiating action for the loss of shutdown LER 1-98-002 3C cooling event, was properly control ed in accordance with plant procedures. However, the individual installing the jumper failed to take adequate precautions. The flow blockage in the RWCU bottom head drain line, which created the need to install the jumper, should have been classified and tracked as an operator work-around.
3/16/98 Positive IR 98-02 N OPS 1B in general, operator response to the February 6 loss of shutdown cooling event, was LER 1-98-002 appropriate and timely with the exception of a minor procedure compliance error. The operating procedures used to respond to this event were acceptable with minor exceptions that were addressed by corrective actions following the event.
From 3/98 to 9/98 3 of 17 ,
i
LIMERICK PLANT ISSUES MATRIX Date Type l Source ID SFA Code item Description 3/16/98 Negative IR 98-02 N OPS SB On three occasions, operators did not resolve why the 1B residual heat removal (RHR) minimum '
SC flow valve was out of its normal position. Later, the licensee identified that the valve failed closed as a result of a degradation of a transistor in the analog trip unit. ln each instance, operators re-aligned the system without establishing an adequate bases for system operability.
This failure to recognize degraded performance also contributed to the delay in implementing i appropriate correctrve action.
7/10/98 Strength IR 98-06 N MAINT 2B The licensee's process for assessing the risk associated with equipment outages (both at-power, and during shutdown) appears to be thorough and accurate. The work control process and online risk computer assessments were considersd a strength.
7/10/98 Positive IR 98-06 N MAINT 2A The overall housekeeping and material condition of those SSCs selected for reviewwere being t maintained in good condition.
~
7/06/98 Negative IR 98-04 N MAINT 3A During a five-year EDG overhaul, the inspector identified four examples of poor procedure use. ,
These examples were cross-departmental, and while individually of minor safety significance and not subject to formal enforcement, indicated an overall weakness in the PECO staff's procedural adherence. ,
7/06/98 Positive IR 98-04 N MAINT 3A Overall, PECO performed the five-year emergency diesel generator (EDG) overhaut ;
in a we!!-coordinated manner. The maintenance and modification work was planned, i implemented, and supervised well. '
6/19/98 VIO IR 98-05 S MAINT SC A RWCU isolation occurred due to a smal1 steam leak in conjunction with a loss of ventilation VIO 98-05-01 resulting from a load center supply breaker trip. The premature breaker trip was a result of an LER 1-98-005 incorrectly wired (reversed polarity) current transformer internal to the breaker which had been recently replaced. Further evaluations identified two more similar wiring errors. Corrective actions for previous industry information conceming similar occurrences were neither timely nor adequate and resulted in a violation of 10 CFR50, Appendix B, Criterion XVI, Corrective Action violation.
From 3/98 to 9/98 4 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 3/16/98 NCV IR 98-02 L MAINT 3A An unplanned closure of a primary containment isolation valve, instrument gas transversing Negative NCV 98-02-05 4A incore probe purge valve, HV-059-i31 occurred during performance of a post maintenance LER 1-97-012 surveillance test following relay replacements. An isolation relay was not properly identified on the post-maintenance surveillarce test due to being mislabeled on an electrical print used as a reference for planning the test The electrical print error resulted from an incorrect revision following a 1995 plant modification. The licensee identified inaccurate drawing was a violation of Technical Specification 6.8.1.
5/18/98 Positive IR 98-03 N MAINT 3B The inservice inspection (ISI) was performed acceptably and included appropriate ASME 3A program coverage, qualified personnel, approved procedures, proper implementation, adequate examination documentation, and PECO oversight The inspections were sufficiently thorough to determine the integrity of the components inspected.
5/18/98 Positive IR 98-03 N MAINT 3A Generally, surveillance testing was conducted well during refueling outage 1RF07. Large, complex tests were well supervised with management oversight and were conducted by an individual test coordinator.
5/18/98 Positive IR 98-03 N MAINT 3A Overall, maintenance activities performed during refueling outage 1R07 were conducted well and without incident Supervisors were present in the field and field teams were well briefed.
Technicians had work packages at the job-site and understood the effect of their activity on the unit 3/16/98 VIO IR 98-02 N MAINT 3A Deficiencies were identified with the configuration control process when retuming the secondary VIO 98-02-04 SC meteorological tower back to service after a calibration. This led to the operations staff improperly declaring a monitor operable prior to correction of all identified deficiencies.
8/31/98 NCV 1R 98-07 L ENG 2A The identification of the missing fire damper by a fire protection technician, demonstrated a LER 1 3A healthy questioning attitude with appropriate follow-up. The root cause for the missing dampers CM was thorough; however, weaknesses were noted with the comprehensiveness of previous actions for related issues which had the potential to identify this issue sooner. The failure to have an adequate fire barrier between independent fire zones is a violation of 10 CFR 50 Appendix "B" Criterion 111,
- Design Contror and is being treated as a Non-Cited Violation.
From 3/98 to 9/98 5 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 8/31/98 Negative IR 98-07 N ENG 4B Reactor engineering support of a routine rod pattem adjustment activity was weak in that 3B unexpected alarms were received which required plant operators to reduce plant power.
Reactor engineering had not adequately assessed the response of the local power range monitors to the rod pattem adjustment and therefore predicted a non-conservative plant power level for the conduct of the activity. This lapse in engineering performance for the routine activity resulted in an unexpected challenge to the unit operators.
7/10/98 Negative IR 98-06 N ENG SC PECO was very slow to implement the lessons teamed from the Peach Bottom maintenance rule SB baseline inspection and to resolve deficiencies in its program.
7/10/98 Positive IR 98-06 N ENG 5A The licensee's nuclear quality assurance surveillance activities were comprehensive in nature and that these efforts were effective in identifying program implementation deficiencies. The maintenance rule self-assessment process was beneficial in documenting areas for improvement.
7/10/98 Positive IR 98-06 N ENG 3B Plant personnel knowledge of the maintenance rule program was good.
7/10/98 Negative IR 98-06 N ENG SC With respect to the initial Unit 2 maintenance rule periodic evaluation the team notM t.mt the 4C licensee had identified several events that reflected a weakness in the corrective action implementation process. The team also observed a problem relative to the untimely issuance of this document. Despite the problem with timeliness in issuing this periodic evaluation, the licensee had initiated corrective actions in response to the identified issues and the content of the assessment provided appropriate insights into the implementation of the maintenance rule process at LGS. Additionally, the team determined that the Unit.1 periodic evaluation had been issued within the licensee's established goal of 90 days, indicating an improvement in the review and issuance process associated with the (a)(3) assessments.
7/10/98 Positive IR 98-06 N ENG 4C Structures had been adequately scoped within the scope of the maintenance rule and were appropriately classified as (a)(2) systems. The performance criteria to move the classifications of structures into an (a)(1) status will be reviewed and revised as necessary by tha expert panel.
From 3/98 to 9/98 6 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 7/10/98 VIO IR 98-06 N ENG 4C Structures systems and component performance criteria were, in general, conservatively VIO established and were directly related to the probabilistic risk assessment assumptions. However 50-352/353- two instances of failure to establish appropriate performance criteria (safety relief valves and fuel 98-06-01 pool cooling system) are examples of a violation of 10 CFR 50.65 (a)(2). The licensee had identified a similar violation in the control room emergency fresh air system. Extensive activities to get the maintenance rule program in compliance with requirer'n ents just prior to the inspection were evident.
7/10/98 Positive IR 98-06 N ENG 3B System managers were knowledgeable of the maintenance rule requirements and industry 4C operating experience applicable to their assigned systems.
7/10/98 Positive IR 98-06 N ENG 4C The maintenance rule expert panel performed its assigned function in accordance with the program requirements and in an appropriate manner.
7/10/98 Weakness IR 98-06 N ENG 4C The lack of plant-specific reliability estimates in the plant specific analysis (PSA) was considered a weakness. In addition, using specific failure-modes of single components to estimate the importance measure values of systems is contrary to the guidance given in NUMARC 93-01 and <
was concluded to be a weakness.
7/10/98 Strength IR 98-06 N ENG 4C Use of the Limerick plant specific analysis (PSA) in verifying consistency between performance criteria and PSA assumptions was considered a strength.
7/10/98 NCV IR 98-06 L ENG 4C PECO had completed a thorough scoping review of all structures, systems and components Negative NCV 50- under the scope of the maintenance rule in preparation for the NRC's maintenance rule 352/353 inspection team. The licensee had identified, although extremely late, an additional 50 06-02 structures, systems and components and had correctly scoped them into their maintenance rule program. For those structures, systems and components that were excluded from the scope of the rule, justification was found to be acceptable.
7/06/98 VIO IR 98-04 N ENG 5A A ganeric impact review which identified 10 additional valves at each unit that required additional VIO 98-04-04 testing to confirm operability was not timely. In addition, the subsequent valve testing problems were not reported in an licensee event report. This is a violation of 10 CFR 50.73, reporting requirements. Further, weaknesses were identified in the implementation of the PEP process that led to the missed LER and could lead to missed or untimely operability assessments.
From 3/98 to 9/98 7 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 7/06/38 VIO IR 98-04 N ENG SC Overall, the root cause evaluation for the deficient testing of primary containment isolation valves VIO 98-04-03 (PCIVs) was adequate; however, the corrective actions implemented for testing deficiencies associated v.ith numerous containment isolation valves were weak. Interim corrective actions to address discrepancies that led to the missed testing were not implemented and the long term corrective action plan and implementation time-table were not established in a timely manner.
Further, two recommendations by the generic review team were rejected without adequate bases. However following the inspection the licensee made a number of improvements in the corrective actions, including finalizing planned corrective actions and establishing implementation goals. This licensee identified violation of Technical Specification 4.6.3.1, primary containment isolation valve survei!!ance requirements is being cited because corrective actions were weak and untimely. -
6/19/98 NCV IR 98-05 L ENG 4A Six electrical circuits entering primary containment (three in Unit 1 and three in Unit 2) were Negative NCV 98-05-08 SB outside the design bases of the plant, in that the electrical containment penetrations did not have LER 1-98-009 duar overcurrent protection over the entire range of postulated faults. The circuits pertained to inboard isolation valves. PECO had determined that the deficiency was the result of poor communicatioi ' "q different engineering groups during initial plant licensing. The failure to assure the plant cc.. aration was consistent with the design and licensing bases was treated as an NCV. However, following discovery of this condition deficiencies were noted in addressing operability.
6/19/98 NCV IR 98-05 S ENG 2A Pressure setpoint drift of main steam system safety relief valves caused by corrosion induced Negative NCV 98-05-07 4A bonding. This failure to n eet Technical Specification surveillance requirements was treated as LER 1-98-008 an NCV.
6/19/98 NCV IR 98-05 S ENG 4A Three of the four differential pressure switches in the emergency trip system (which provides an Negative NCV 98-05-06 anticipatory trip signal to the end-of-cycle reactor recirculation pump trip system and to the LER 1-98-007 reactor protection system) had fallen below the Technical Specification (T/S) allov..:cle value.
This resulted in two independent trains of a single safety system being inoperable from a common cause. This failure to meet the T/S surveillance requirements was treated as an NCV.
From 3/98 to 9/98 8 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID l SFA Code item Description 3/16/98 URI 1R 98-02 N ENG 4A Because of the lack of seismic qualifrcations of the cask storage pit in the spent fuel pool (SFP),
URI 98-02-11 which could result in a lowering of the spent fuel pool water level, the local power range monitor (LPRM) stored in the pool had to be lowered in the spent fuel pool. This item is unresolved pending further review of the licensee basis documentation regarding LPRM storage and SFP configuration.
6/19/98 URI 1R 98-05 L ENG 4A A potential suppression chamber steam bypass leakage path between the drywell and the Negative URI 98-05-05 suppression pool air spaces was discovered resulting in a condition outside the design basis of LER 1-97-010 the plant. During a LOCA, a postulated single hot short affecting the cables of two inboard isolation valves could result in their opening and interconnecting the two areas. Isolation of the two areas is necessary to ensure adequate pressure suppression during design bases events.
This issue is unresolved pending the PECO evaluation of significance of the condition.
3/16/98 NCV IR 98-02 L ENG 4C Failure to perform a first cycle ana!f sis of a reactor flux wire specimen at Unit 2. PECO Negative NCV 98-02-10 determined the root cause to be a procedural inadequacy that failed to track documentation and LER 2-97-010 completion of the analysis. The licensee identified failure to perform the analysis is a violation of Technical Specification surveillance 4.4.6.1.4. -
6/19/98 Positive IR 98-05 N ENG 5A The team concluded that PECO's self-assessments of engineering practices were acceptable.
Also, QA was effective in identifying and documenting unacceptable engineering practices.
6/19/98 Positive IR 98-05 N ENG 5A The team concluded that the process for corrective action (PEP), including reportability and 5B operability determinations, operating experience feedback, self-assessments, and oversight committees were generally appropriate and effective. A range of issues and problems had been documented, categorized, analyzed, and addressed. Nonetheless, the team noted an operability determination that was inconsistent and potentially confusing to operators. Further, the team found that numerous operational challenges had occurred due to repetitive equipment and system design problems and the above processes did not appear to have been effective in reducing the challenges.
5/18/98 Negative IR 98-03 L ENG 3A Contract workers did not consistently perform the skimmer surge tank modification activities SA appropriately, and on several occasions failed to perform adequate quality verification checks.
PECO quality verification personnel identified these deficiencies, which were adequately resolved.
From 3/98 to 9/98 9 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 6/19/98 Positive IR 98-05 N ENG 3A System managers were actively involved in plant activities and their support of such activities 3B was acceptable. Evaluations of events in different systems had been well documented, thoroughly evaluated and comprehensive. System managers had a good general knowledge of their assigned systems, the current issues, and the technical resources available to them for resolution.
6/19/98 Positive IR 98-05 N ENG 4C 10 CFR 50.59 safety evaluations were of good quality and performed in accordance with the requirements of 10 CFR 50.59 and the applicable PECO procedures by trained, qualified personnel. The 10 CFR 50.59 Program was well established and was being implemented well.
No indications of unauthorized changes were identified.
5/18/98 Negative IR 98-03 N ENG 4B The planned testing, to identify additional control rod anomalies, for Limerick was adequate.
SB However, the testing plan documented in the interim PECO disposition of channel bowing, SC provided inappropriate flexibility. Specifically, more subjective testing methods were allowed instead of requiring scram time testing for each suspect channel. The engineering disposition did not establish sufficient bases for the attemate testing. In addition, no formal communication was provided to the operators, following the identification of a generic channel bowing concem.
6/19/98 Positive IR 98-05 N ENG 4C in general, the procedures, controls, and training supporting the 10 CFR 50.59 safety evaluation process provided comprehensive guidance and were found to be acceptable.
5/18/98 Positive IR 98-03 N ENG SB The response to degraded scram and notching performance of control rod 18-15 was SC conservative. The evaluation and corrective actions implemented to address fuel channel bowing in a select population of fuel bundles were prompt and comprehensive.
5/18/98 Positive IR 98-03 N ENG 4A The engineering work on the skimmer surge tank modification had been comprehensive and acceptable. The decision to forego detailed pre-fabrication measurements was reasonable, but better measurements prior to installation could have prevented most of the later fit up problems.
6/19/98 Negative IR 98-05 N ENG 4B The team concluded that the qualified life calculation for Agastat series GP/EGP relays in a harsh environment included several discrepancies that primarily affected normally energized relays and would be reviewed by NRC follow:ng actions to resolve these discrepancies.
3/16/98 Positive IR 98-02 N ENG 4C PECO proactively prepared to identify the onset of vibration in the recirculation system by placing vibratory sensors at critical locations on the recirculation system.
From 3/98 to 9/98 10 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 5/18/98 Positive IR 98-03 N ENG 4B The licensee's activities to inspect, assess, and repair the A and B RHR pumps were very good.
SB The engineering team determined the root cause and identified appropriate corrective actions.
SC ,
6/19/98 VIO IR 98-05 N ENG 4B PECO had established a generally effective program to evaluate and control the replacement of VIO 98-05-01 safety-related Agastat GP/EGP type relays, including detailed monitoring of relay performance.
However, the team concluded that corrective actions regarding replacement of Agastat relays in three panels which perform at higher temperatures (95'F) had been ineffective and represented a violation. These relay replacements were deficient in that relays remained in service longer than intended, experienced increasing failure rates, and caused the control room emergency fresh air supply (CREFAS) system to be unable to respond to an actuation signal on April 4,1998. This is a violation of 10 CFR 50, Appendix B, Criterion XVI.
3/16/98 Positive IR 98-02 N ENG 4C LGS he.s developed a comprehensive " BOP 700 Strategy" to improve BOP system performance and reliability. LGS implemented parts of the strategy in resolving system problems and performing work to address equipment degradation.
6/19/98 Positive IR-9805 N ENG 4C The team concluded that backlogged engineering activities, both in the plant system and design engineering areas, were manageable and properly controlled. A sample review of the description of the activities found no items with potential safety significance on which resolutions ,
lagged.
3/16/98 Positive IR 98-02 N ENG 4C LGS has implemented a program to identify chronic plant issues and provides for a comprehensive program to monitor resolution of these issues.
6/19/98 Positive IR 98-05 N ENG 5B Operability determinations were acceptable and timely. Applicable root cause analyses were detailed and acceptable, and the depth of evaluations was commensurate with the significance of theissues.
3/16/98 Positive IR 98-02 N ENG 4C Engineering used a comprehensive approach to assess perforrnance of plant systems. Several systems not meeting plant performance criteria have been identified and corrective action focused on these systems.
Frorn 3/98 to 9/98 11 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 6/19/98 Positive IR 98-05 N ENG 5B The team concluded that troubleshooting activities and the root cause determination for the standby liquid control unplanned actuation were well planned and effective. Activities were conducted safely by technically competent individuals. The root cause determination was correct and insightful.
3/16/98 Negative IR 98-02 N ENG SB The operability determinations associated with the failure of the HPCI exhaust valve to stroke closed were flawed. The determinations did not take into account the closing time required by technical specifications.
3/16/98 eel IR 98-02 N ENG 4B The engineering staff did not aggressively pursue comprehensive troubleshooting, testing, and Negative eel 98-02-08 5B component inspection of the HPCI turbine exhaust valve following multiple failed valve eel 98-02-09 5C surveillances. Prior to the fifth failure of this valve to stroke, a conclusive root cause was not IR 97-10 identified and consequently led to ineffective corrective action, which in tum resulted in this URI 97-10-06 valve, being inoperable for an extended period of time.
The engineering assessment and supporting safety evaluation to support operability of the HPCI exhaust valve was inadequate in that it did not address the valve closure time requirements.
The plant operations review committee (PORC) approved the safety evaluation, but failed to cha!!enge the engineering assessment discounting the requirement for the valve to close the first time to meet the closure time required by technical specifications in assessing operability.
PORC accepted the degraded condition of the valve without having identified the root cause or evaluating the corrective actions to ensure future valve reliability and thereby the ability to meet the required closure time. The use of a safety evaluation to accept the delay in further investigations and testing of the HPCI exhaust valve, until the next scheduled refueling outage, in effect inappropriately modified the technical specifications required closing time. The use of the safety evaluation in addressing operability was not necessary nor consistent with NRC guidance on operability provided in genes: letter 91-18.
3/16/98 Negative IR 98-02 N ENG 4B The licensee failed to fully implement a 1990 LER corrective action commitment that involved 5B replacement of potentia!!y defective transistors in a select population of safety-related analog trip SC units. In addition, the recent operability determination addressing these transistors remaining in service, was not timely nor comprehensive.
From 3/98 to 9/98 12 of 17
LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 3/16/98 eel IR 98-02 N ENG 3A Engineering efforts to identify the root cause of the 1B RHR minimum flow valve inadvertent Negative eel 98-02-06 4A closure demonstrated inadequate troubleshooting. Initial efforts were narrowly focused and eel 98-02-07 5B based on faulty assumptions. This failure to identify the root cause led to ineffective corrective actions and resulted in multiple modes of the RHR system being inoperable for extended periods of time.
8/31/98 MISC IR 98-07 N PS 3B The Post Accident Sampling System was determined to be operable and technicians Positive 3A demonstrated very good use of the system when acquiring actual samples.
8/31/98 MISC 1R 98-07 N PS SA The 1996 and 1997 audit reports of emergency preparedness met the specific requirements of Negative 10 CFR 50.54(t). However, the audit reports did not contain sufficient detail describing the bases for their conclusions, program assessments were redundant from year to year, repeat items were not properly tracked, and checklist recommendations and areas for improvement were not discussed.
8/31/98 MISC IR 98-07 N PS 1C The licensee conducted emergency response training and dri!!s as required and training for the Positive 3A Emergency Response Organization was effectively implemented.
8/31/96 MISC IR 98-07 N PS 2B Based upon the review of recent licensee changes, the E-Plan changes were adequately 471 Positive 3A reviewed in accordance with 10 CFR 10.54(q). The letters of agreement with offsite agencies were in place and the licensee's offsite program with the states and counties continue to be a strength in their emergency preparedness program.
8/31/98 MISC 1R 98-07 N PS 2B Facilities related h emergency preparedness were in a state of operational readiness and Negative 2A surveillance tests and equipment inventories were performed as required. However, the inspector noted instances where emergency equipment remained degraded for long periods of time necessitating reliance on compensatory measures. Information regarding repeated failures of offsite sirens was referred to Federal Emergency Management Agency (FEMA) on July 16, 1998.
8/31/98 MISC IR 98-07 N PS SC The licensee's process for identifying, resolving and preventing problems in the emergency Negative SB preparedness area consisted of three systems that were not well integrated for the purpose of trending of problems. As a result, several repeat emergency preparedness performance issue
- occurred but were not tracked as repeat issues.
From 3/98 to 9/98 13 of 17
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LIMERICK PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 5/18/98 Positive IR 98-03 N PS 1C The control room operators appropriately declared an ALERT ca April 17,1998, due to the potential presence of an unidentified toxic or flammable gas. The licensee controlled the non-radiological event well with no adverse effects on either unit. Although the source of the gaseous smell was not identified prior to termination of the event, PECO did identify the source when the smell recurred the following day.
5/18/98 Negative IR 98-03 N PS SC A few radiological problems were identified shortly before and during the early Unit i seventh 1C refuel outage period and they were of minor safety consequence; however, they were not effectively resolved in a timely manner.
5/18/98 Negative IR 98-03 3 PS SC Other-utility radiation protection (RP) technicians brought in for the outage were not evaluated 1C for their knowledge of RP fundamentals, which was previously found to be a weakness in the Limerick RP technician training program in 1997. In light of Limerick's experience in this area, waiving of the RP fundamentals examination for other-utility RP technicians was considered a poor practice.
5/18/98 Weakness IR 98-03 N PS 1C Interviews with some advanced radiation worker personnel to verify the degree of proficiency revealed a deficiency relative to knowledge of survey and contamination release criteria.
Verification and oversight of activities conducted by advanced radiation workers was not well executed, consequently, the potential for inadequate performance existed. Notwithstanding, no actual performance deficiencies were noted during this review.
5/18/98 Negative IR 98-03 N PS 1C The daily source response check of contamination instrumentation had been recorded in a misleading manner.
5/18/98 Positive IR 98-03 N PS 1C A very good level of air sampling was performed during the Unit 1 seventh refuel outage, with no indications of airbome radioactivity areas. Follow-up whole body counts for persons subject to personnel contamination did not identify any intemal exposures.
5/18/98 Strength IR 98-03 N PS 1C During the Unit 1 seventh refueling outage, the drywell was effectively shielded resulting in relatively uniform and low dose rate conditions. The licensee was aggressive in reducing hot spots in plant piping, which resulted in improved radiological conditions in various plant areas, including the suppression pool.
5/18/98 Negative IR 98-03 N PS 1C Alarm setpoints on electronic dosimeters were not commensurate with radiological conditions and accordingly, were not established to optimize exposure control.
From 3/98 to 9/98 14 of 17
J LIMERICK PLANT ISSUES MATRIX Date -Type Source ID l SFA Code item Description 5/18/98 Strength IR 98-03 N PS 1C Generally effective radiation protection job coverage and radiological briefings to workers were provided during the Unit 1 seventh refuel outage.
3/16/98 Negative IR 98-02 N PS 1C Regarding the loss of shutdown cooling event that occurred on February 6,1998, while emergency response procedures did not explicitly require the event to be classifed as an emergency condition, we found that the crew on shift at the time of the event did not consult the Nuclear Emergency Plan and Emergency Response Procedures, which was a licensee expectation, to determine if plant conditions met emergency action level criteria. The licensee's initial investigation into this matter was poor; however, following discussions with the NRC, a more thorough investigation was conducted. The licensee developed adequate corrective actions from the event.
3/16/98 NCV IR 98-02 L PS iC The licensee found a locked high radiation door in an unlocked and unguarded condition. This Negative NCV 98-02-13 licensee identified failure to control the locked high radiation door is a violation of TS 6.12.
3/16/98 Positive IR 98-02 N PS 1C The QA audit requirements were met and the contractor's ONOC program for the Radiological Environmental Monitoring Program (REMP) provided effective validation of analytical results.
3/16/98 Positive IR 98-02 N PS 1C The meteorological data acquisition was good. However, a weakness was noted with the calibration and maintenance programs for the meteorological instrumentation and related equipment.
3/16/98 Positive IR 98-02 N PS 1C Overall performance was good and the radiological environmental monitoring program was effective, although an instance of poor attention to detail was noted involving the rough handling of a sample filter.
From 3/98 to 9/98 15 of 17
ABBREVIATIONS USED IN PIM TABLE BOP Balance of Plant CREFAS Control Room Emergency Fresh Air Supply ESF Engineered Safety Feature FEMA Federal Emergency Management Agency HPCI High Pressure Coolant injection LCO Limited Conditions for Operation LGS Limerick Generating Station LER Licensee Event Report LOCA Loss of Coolant Accident NCV Non Cited Violation PECO PECO Energy PEP Performance Enhancement Prdgram PMT Post Maintenance Test QA Quality Assumnce RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal RPS Reactor Protection System RWCU Reactor Water Cleanup SSC Systems, St- tures and Components 16 of 17
GENERAL DESCRIPTION OF PIM TABLE COLUMNS g, The adual date of an event or significant issue for those items that have a clear date of occurrence (mainly LERs), the date the source of the information was issued (such as for EALs), or the last date of the inspection period (for irs).
Type The categorization of the item or finding - see the Type / Findings Type Code table, below.
Source The document that descnbes the findings: LER for Licensee Event Reports, EAL v Enforcement Action Letters, or IR for NRC inspection Reports.
/D Identification of who discovered issue: N for NRC; L for Licensee; or S for Self identifying (events).
SFA SALP Functional Area Codes: OPS for Operations; MAINT for Maintenance; ENG for Engineering; and PS for Plant Support.
Code Template Code - see table below.
Item Descript/on Details of NRC findings on LERs that have safety significance (as stated in irs), findings described in IR Executrve Summaries, and amphfying information contained in EALs.
TYPE / FINDINGS CODES TEMPLATE CODES ,
ED Enforcement Discretion - No Civil Penalty Strength Overall Strong Licensee Performance 1 Operational Performance: A- Normal Operations; B - Operations During Transients; and C -
Programs and Processes Weakness OverallWeak Licensee Performance 2 Material Condition: A - Equipment Condition or B - Programs and Processes EEI
- Escalated Enforcement item - Waiting Final NRC Adion 3 Human Performance: A - Woik Performance; B - Knowledge, Skills, and Abilities / Training; C -
VIC Violation Levet I,11, til, or IV Work Environment NCV Non-Cited Violation
_ 4 Engineering / Design: A - Design; B - Engineenng E:Jpport; C - Programs and Processes DEV Deviation from Licensee Commitment to NRC 5 Problem identification and Resolution: A -Identication; B - Analysis; and C - Resolution Positive Individual Good Inspection Finding Negative individual Poor Inspection Finding NOTES:
Eels are apparent violations of NRC requirements that are being considered for escalated LER Licensee Event Report to the NRC enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action"(Enforcement Policy), NUREG-1600. Howevsi, the NRC has not reached its URI " Unresolved item from inspection Report final enforcement decision on the issues identified by the Eels and the PIM *ntries may be modified when the final decisions are made. Before the NRC makes its enforcement decision, the Licensing Licens.ng issue from NRR I censee will be provided with an opportunity to either (1) respond to the apparent violation or (2)
MISC Mscellaneous - Emergency Preparedness Finding (EP), Declared request a predecisional enforcement conference.
Emergency, Nonconformance issue, etc. The type of all MISC "
findings are to be put in the item Description column. URis are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be mod. fed when the final conclusions are made.
17 Of 17
ENCLOSURE 2 LIMERICK INSPECTION PLAN FOR DECEMBER 1998 THROUGH MAY 1999 Inspection Program Area / Title Planned Dates Type inspection / Comments Audit NRR ECCS Suction Strainer Audit 1-11-1999 64704 Fire Protection 1-18-1999 RegionalInitiative 37550 Followup Engineering 1-25-1999 RegionalInitiative 84750 Environmental 2-22-1999 Core initial Operating Examination 3-15-1999 83750 Outage-Radeon 4-19-1999 Core Legend:
IP -
Inspection Procedure Number Tl -
Temporary Instruction Program / Sequence Number Core - Minimum NRC Inspection Program (mandatory at all plants)
OA -
Other inspection Activity RI -
Additional Inspection Effort Planned by Region i SI -
Safety Initiative inspection ,
i 4