ML20198N177
| ML20198N177 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/27/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198N168 | List: |
| References | |
| 50-352-97-07, 50-352-97-7, 50-353-97-07, 50-353-97-7, NUDOCS 9711030182 | |
| Download: ML20198N177 (42) | |
See also: IR 05000352/1997007
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Docket Nos. 50 352
i 50 353 i
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- License Nos. NPF39
NPF 85 l
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Report Nos. 97 07
97 07
Licensee: PECO Energy
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Facilities: Lirnc:,ck Generating Station, Units 1 and 2
Location: Wayne, PA 19087 0195
Dates: July 22,1997 through September 15,1997
Inspectors: N. S. Perry, Senior Resident inspector
R. L. Fuhrmeister, Project Engineer
L. L. Eckert, Radiation Specialist
R. M. Latta, Operations Engineer, NRR
L. L. Campbell, Senior Operations Engineer, NRR
Approved by: ,
Clifford Anderson, Chief
Projects Branch 4
Division of Reactor Projects
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EXECUTIVE SUMMARY
Limerick Generating Station, Units 1 & 2
NRC Inspection Report 50 352/97 07, 50 353/97-07
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This integrated inspection included aspects of PECO Energy operations, engineering,
maintenance, and plant support. The report covers an 8 week period of resident
inspection.
Ooerotions
- Since a number of valves were identified as inadequately locked as required, a
programmatic problem existed concerning how valves are locked and independently
verified as adequately locked. Immediate corrective actions taken of verifying all
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accessible valves listed in the Locked Valve List, as adm ately locked were good.
(Section 02.1)
% The reactor water clean-up (RWCU) system automatically isolated due to a high
differential flow condition while restoring a filter demineralizer to service. The high
differential flow condition was caused by the B RWCU filter domineralizer Y strainer
manual drain va!ves leaking into the backwash receiving tank. The affected valves
were adjusted, and the filter domineralizer was returned to service; no other
- comparable valves were found leaking on Unit 1 or Unit 2. Additionally, on August
6, for Unit 2, and September 10, for Unit 1, there were a number of RWCU
luolations. This large number of isolations over a fairly short period of time was a
, challenge for the operators. These concerns regarding the RWCU systems for both i
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units will remain as an inspector follow up item, pending review for common cause
issues and maintenance rule implications. (Section 08.2)
Maintenance
e Observed maintenance activities were conducted well using approved procedures or
work instructions, and were completed with satisfactory results. Communications
between the various work and support groups were good, and supervisor oversight
was good. (Section M1.1)
e in general, surveillances were performed by knowledgeable personnel, and were
satisfactorily completed. In particular, very good system manager support for the
Unit 1 reactor core isolation cooling (RCIC) test; also noted was the knowledge level
of the attending equipment operator for the RCIC pump run. Overall, surveillance
tests were conducted well using approved procedures, and were completed with
satisfactory results. Communications between the various work and support groups
were good, and supervisor oversight was good. (Section M1.2)
e Proper actions woro taken to ensure that a TS required voltage verification was met,
once it was discovered to be potentially missed. However, personnel did not
properly track the missed surveillance step to ensure that it was completed when
the clearance was removed. Additionally, the engineering review which concluded
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Executive Summary l
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that the TS tequirement had been met by an alternate means appeared weak.
(Section M1.3)
Personnel identified foreign materialin the high pressure coolant injection (HPCI)
turbine exhaust drain pot drain line which rendered the HPCI system inoparable
since an undetermined amount of condensed water was present in the HPCI turbine.
This resulted in a violation of the foreign material exclusion (FMEl program. (Section
M8.1)
Enaineerina I
- Actions taken to address each 021 test failure have been appropriate. Although no
clear tie between the f ailures has been determined, investigations continue.
(Section E1.2)
- Operators appropriately declared three EDGs inoperable when they became aware of
a potentlat problem with the fuel oil due to a high cloud point. The EDGs were -
declared operable later the same day after it was shown that the oilin the storage
tanks was below the cloud point maximum. However, documentation for the
operability datermination was weak,in that various work groups had to be
contacted to get all of the facts of the operability determination. (Section E1.2)
Plant Suncort
- The licensee maintained and implemented good routine radioactive liquid and
gaseous effluent control programs. Tne radiation monitoring system (RMS)
calibration program was good, as were the ventilation system surveillance program
and Quality Assurance and Quality Control programs. Several opportunities were
identified in which RMS system tracking and trending could be improved.
- Fire protection procedures were found to provide adequate guidance and appropriate
acceptance criteria for testing fire protection equipment. (Section F3.1)
- Station personnel identified that a potential voltage mismatch may exist between a
fire protection deluge valve and its control panel, resulting in marginal power
available to operate the valve. An evaluation concluded that a technical
specification noncompliance occurred between issuance of the facility operating
license for Unit 1 on October 26,1984, and December 20,1995, when the
technical specifications were relocated to the Technical Requirements Manual, since
the valve may have been unable to perform its design function. Corrective actions
included making adjustments to the valve to optimize mechanical operation, posting
a continuous firewatch, increased testing of the valve, and the valve was replaced
on September 3,1997. This violation had more than minor significance since it
resulted in a condition where a technical specification-required deluge valve was
inoperable for an extended period of time and resulted in a non-cited violation. The
safety consequences for this event were low. (Section F8.1)
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TABLE OF CONTENTS
S u m m a r y o f Pl a nt S t a t u s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01 C ond uct o f O p e ration s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . 1
02.1 Control ei Locked Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
07.1 Self. Assessment Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
08 Miscellaneous Operations issues . . . . . . . . . ........................ 3
08.1 (Closed) LER 2 97 008, Automatic Closure of Drywell Chilled Water
System Primary Containment isolation Valves, An ESF Actuation,
Resulting From Emeigency Diesel Generator Voltage Regulation Failure . 3
08.2 (Closed) LER 2 97 009, Reactor Water Clean-up (RWCU) Isolation, An
ESF, Caused by a RWCU Filter Der.iineralizer Y Strainer Manual Drain
Valves Leaking into the Backwash Receiving Tank . . . . . . . . . . . . . . . . 3.
II . M aint e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
M1 Conduct of Maintenance ....................................... 4
M 1.1 General Comments on Maintenance Activities . . . . . . . . . . . . . . . . . . . 4
M1.2 General Comments on Surveillance Activities . . . . . . . . . . . . . . . . . . . . 5
M1.3 Potential Missed Surveillance Test ........................... 6
M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
M 8.1 (Closed) LER 2 97 007 Unit 2 HPCI System inoperable Due to
Clogged Turbine Exhaust Drain Line .......................... 7
Ill. Engineering ................................................... 7
E1 Conduct of Engineering ........................................ 7
E 1,1 D21 Emergency Diesel Generator issues ....................... 7
E1.2 Emocqancy Diesel Generator High Cloud Point Response . . . . . . . . . . . . 8
E7 Quality Assurance on Engineering Activities . . . . . . . . . . . . . . . . . . . . . . . . . . 9
E 7.1.1 Review of PECO Audits and PECO's Use of Third Party Audits . . 10
E 7.1.2 Review of Commercial Grade Surveys . . . . . . . . . . . . . . . . . . . 14
E7.1.3 Purchase Order Revision Controls . . . . . . . . . . . . . . . . . . . . . . 15
I V . Pl a n t S u p p o r t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
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Table of Contents
R1 Radio'ogical Protection and Chemistry (RPF s Controls . . . . . . . . . . . . . . . . . 17
R1.1 Implementation of the Radioactiv< :id and Gaseous Effluent
ControI Programs . . . . . . . . .
............ ............. 17
R2 Status ot RP&C Facilities and Eoulpment . ......................... 18
R2.1 Calibration of Effluent / Process / Area / Accident Radiation Monitoring
Systems (RMS) ..............................
......... 18
R2.2 Air Cle aning Syste ms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
R7 Quality Assurance (CA) in RP&C Activities . . . . . . . . . . . . . . . . . . . . . .... 20
F1
Control of Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
F1.1 Main Control Room Fire Suppression System . . . . . . . . . . . . . . . . . . . 21
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F2 Status of Fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . 22
F2.1
in Plant Walkdo wns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
F3 i
Fire Protection Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . 24 l
F3.1 Procedure Upgrade Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
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F6 Fire Protection Organization and Administration . . . . . . . . . . . . . . . . . . . . . . 28 i
F6.1
Fire Prote ction Council . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
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F6.2 Fire Protection Focused improvement Team . . . . . . . . . . . . . . . . . . . . 29
F8 Miscellaneous Plant Support issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
F8.1 (Closed) LER 1 97 006, Previous Condition Prohibited by Tech Specs
in thrt a Fire Protaction System Deluge Valve may not have
Funedoned per Design Since issuance of the Unit 1 Operating License . 30
V. Management Meetings . . . . . . . . . . . . . . . . .......................... 30
X1 Exit Maeting Sum mary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
X2
Review of UFS AR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
ITEhnS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
LIST O F ACRO NYM S USE D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
LIST O P DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
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Report Details
Summary of Plant Status
Unit 1 began the inspection period operating at 100 percent power. The unit remained at
4 full power throughout the inspection period with minor exceptions for testing and the
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following events:
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e August 31 Operators reduced reactor power to 60 percent following a
loss of one control rod's position during the weekly control rod
exercise test. After fully inserting the control rod, the unit
returned to 100 percent power on September 1.
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o September 12 Operators reduced reactor power to approximately 60 percent
to perform a control rod sequence exchange, to scram time
1 test control rods, and to work on the A reactor feed pump.
The unit was returned to 100 percent power on September 14,
after completion of the activities.
, Unit 2 %gon the laspection period operating at 100 percent power. The unit remained at
j full power throughout the inspection period with minor exceptions for testing and the
following event:
e August 11 Operators reduced reactor power to 97 percent after a steam
leak was identified at the main turbine first stage pressure
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switch. The switch was isolated and power was returned to
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100 percent the same day.
) 1. DoeratioDE
01 Conduct of Operations'
01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted freque:it reviews of
ongoing plant operations, in general, PECO Energy's conduct of operations was
professional and safety conscious.
02 Operational Status of Facilities and Equipment
02.1 Control of Locked Valves
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a. insoection Scoos (71707)
During this inspection period, the inspector identified instances where valves,
required to be locked to restrict operation, were not adequately locked.
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. ' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report
outline. Individual reports are not expected to address all outline topics.
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Additionally, operations personnel idantified other similarly inadequately locked
valves. Immediate corrective actions were discussed with operations personnel.
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b. Observations and Findinas
On August 18, the inspector identified a Unit 1 C core spray valve (0521F016C,
seal vent to drain) which appeared to be inadequately locked in that the chain
around the valve handwheel had a large amount of slack in it. After checking the
other Unit 1 core spray pumps, the inspector notified control room operators of the .
valve. Operators subsequently tightened up the chain. On August 20, the l
inspector identified two analogous core spray valves on Unit 2 with an excess of
slack in the chain. Again control room operators were notified and the valve chains
were tightened. On August 22, the inspector discussed the locking of valves with
plant management, and noted that the operators should have checked the other
unit's core spray valves when one was identified as deficient; plant management
was in agreement. On August 26, the inspector performed a walkdown of the Unit
1 reactor building to determine if other valve locking devices were adequate; the
inspector performed a similar walkdown of the Unit 2 reactor building on August
27. A significant number of valves were identified as potentially inadequately
locked. After verifying that the valves were required to be locked, the inspector
notified control room operators of the concern that there may be a number of valves
in the plants which are inadequately locked.
During the next several days, operations personnel walked down all accessible
valves listed on the Locked Valve List to determine the extent of the problem. No
valves were identified as out of the required position. However, a number of valves
were identified as either inadequately locked or in need of tightening up of the
locking mechanisms. Prior to the end of the inspection period, all accessible valves
required to be locked were appropriately verified as adequately locked. No further
discrepancies were identified by the inspector.
Limerick administrative procedure A C-000, Centrol of Locked Valves and Devices,
Revision 0, requires in part, that the lock.ou .: be applied through the
handwheel or other operating mechanism to restrict operation of the valves and
devices listed in the Locked Valve List. Additionally, the procedure notes that the
intent of the locking device is for administrative control over the position of
specified valves and devices, and 'he component should be locked so as to prevent
excessive movement. During thie qspection period, the inspector and subsequently
operators identified a number of valves which were not adequately locked as
required by administrative procedure A C 008. This is a violation. (VIO 50 352.
353/97 07 01)
c. Conclusions
Since a number of valves were identified as inadequately locked as required, a
programmatic problem existed concerning how valves are locked and independently
verified as adequately locked, immediate corrective actions taken of verifying all
accessible valves listed in the Locked Valve List, as adequately locked were good,
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07 ' Ouality Assurance in Operations
07.1 Self-Assessment Activities (71707)
During the inspection period, the inspectors reviewed or attended various self-
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assessment activities, including:
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various Plant Operations Review Committee (PORC) meetings and meeting
minutes
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the quarterly Nuclear Review Board (NRB) meeting on September 4
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various quality verification and independent safety engineering group reports
The inspectors noted in particular that at the NRB meeting, members thoroughly
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reviewed plant events and appropriately questioned plant management concerning
root causes and corrective actions. The NRB members actively participated in the
meeting with open discussions of the issues, while maintaining a focus on safety. l
08 Miscellaneous Operations issues (90712)
08.1 (Closed) LER 2 97 008. Automatic Closure of Drvwell Chilled Water System Primarv
- Containment isolation Valves. An ESF Actuation. Resultino From Emeroency Diesel
Generator Voltaae Reaulation Failure.
This Licensee Event Report (LER) concerned an instance where a relay failure
associated with an electrical bus overvoltage condition, which was caused by an
EDG voltage regulation failure, caused the automatic closure of drywell chilled water
system primary containment isolation valves. The event occurred during
performance of a special test for the D21 EDG. The cause of the relay failure was
determined to be a coil failure that resulted from the excessive voltage of the event;
- no other loads connected to the bus were found to be adversely affected. The
drywell chilled water system valves were reopened and declared operable when the
f ailed control circuit relay was replaced. Troubleshooting, maintenance , and testing
were completed on the D21 EDG. The EDG voltage regulator's failed rectifier bank
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was swapped to an alternate rectifier bank and tested satisfactorily; the EDG was
then restored to an operable condition. The defective rectifier bank will be shipped
offsite for failure analysis. The LER met the requirements of 10 CFR 50.73, and the
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inspector had no further questions regarding the event.
08.2 (Closed) LER 2 97-009. Reactor Water Clean-uo (RWCU) Isolation. An ESF. Caused
by a RWCU Filter Demineralizer Y Strainer Manual Drain Valves Leskina into the
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Backwash Receivina Tank.
This LER concerned an instance where the RWCU system automatically isolated due
to a high differential flow condition while restoring a filter demineralizer to service.
The high differential flow condition was caused by the B RWCU filter domineralizer
Y strainer manual drain valves leaking into the backwash receiving tank. The
affected valves were adjusted, and the filter demineralizer was returned to service;
I no other comparable valves were fouvf leaking on Unit 1 or Unit 2. The LER met
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the requirements of 10 CFR 50.73, and the inspector had no further questions
regarding the event. However, the inspector noted that on August 6, for Unit 2,
and September 10, for Unit 1, there were a number of RWCU isolations. The
inspector was concerned that this large number of isolations over a fairly short
period of time was a challenge to the operators. The inspector was also concerned
that these events could indicate less than adequate maintenance or engineering
attention of the systems or less than adequate management attention. These
concerns regarding the RWCU systems for both units will remain as an inspector
follow up item, pending review for common cause issues and maintenance rule
implications. (IFl 50 352,353/97 07 02)
II. Maintenance
M1 Conduct of Mainten6nce
M1.1 General Comments on Maintenance Activities (62707)
a. Insoection Scoos (62707)
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l The inspectors observed selected maintenance activities to determine whether
approved procedures were in use, details were adequate, technical specifications
were sat;sfied, maintenance was performed by know!edgeable personnel, and post-
maintenance testing was appropriately completed.
The inspectors observed portions of the following work activities:
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Unit 2 Standby Liquid Control tank level sensing line cleaning, on August 27
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D21 Emergency Diesel Generator fuelline replacement, on August 29
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Replacement of Unit 1 fire protection deluge valve 173, on September 2
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Unit 2 reactor core isolation cooling (RCIC) valve work, on September 9
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Unit 1 RCIC governor va!ve servo replacement, on September 11
b. Observations and Findinas
For the standby liquid control (SLC) tank level sensing line cleaning, the inspector
noted that the work was well coordinated between the maintenance personnel and
control room operators. During the cleaning process, the inspector identified a
chain and lock around the instrument tubing on top of the SLC tank. This was
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brought to the attention of operations personnel, who were unable to identify the
source of the lock; no locks or devices were identified in the area as missing a lock
and chain. Operations personnel concluded that the chain and lock must have been
inadvortently left there from a previous activity; operators removed the chain and
lock from the top of the tank. The inspector independently tried to determine if any
valves or devices in the area were missing a chain and lock; none were identified.
Additionally, the Unit 1 SLC tank was inspected, and no similar conditions were
identified. The inspector agreed with the operator's conclusion as the most likely
source of the chain and lock.
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For the Unit 1 RCIC governor valve servo replacemer t, the inspector observed that
there was very good system manager interface with the operators and the >
maintenance personnel. The inspector noted that although the location of the servo
is difficult to reach with some climbing required, the work was completed without
incident.
c. Conclusions
Overall, the inspector concluded that the observed maintenance activities were
conducted well using approved procedures or work instructions, and were
completed with satisfactory results. Communications between the various work
and support groups were good, and supervisor oversight was good.
M1,2 General Comments on Surveillance Activities (61726)
a. Insoection Scone (61726)
The inspectors observed selected surveillance tests to determine whether approved
procedures were in use, details were adequate, test instrumentation was properly
calibrated and used, technical specifications were satisfied, testing was performed
by knowledgeable personnel, and test results satisfied acceptance criteria or were
properly dispositioned.
The inspectors observed portions of the following surveillance activities:
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D21 Emergency Diesel Generator (EDG) weekly, on August 14, 21, 28, and
September 4
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D13 EDG monthly, on August 19
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Unit 1 Standby Uquid Control pump, valve and flow, on August 25
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Unit 2 B Residual Heat Removal pump, valve and flow, on September 4
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Unit 1 RCIC pump, valve and flow, on September 10
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D23 EDG monthly, on September 10
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Unit 2 RCIC pump, valve and flow, on September 12
b. Observations and Findinos
in general, the inspector observed that the surveillances were performed by
knowledgeable personnel, and were satisfactorily completed. In particular, the
inspector observed very good system manager support for the Unit 1 RCIC test;
also noted was the high level of system knowledge of the attending equipment
operator for the RCIC pump run.
c. Conclusions
Overall, the inspector concluded that observed surveillance tests were conducted
well using approved procedures, and were completed with satisfactory results.
Communications between the various work and support groups were good, and
supervisor oversight was good.
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M1.3 Potential Missed Surveillance Test (61726)
a. Insoection Scooe (61726)
The inspector reviewed an instance where a technical specification required
surveillance test was apparently missed on July 18. The inspector reviewed the
operations logs concerning the surveillance, reviewed the surveillance test,
reviewed the engineering justification for how the testing requirement was
alternately met, and discussed the situation with appropriate plant persor.nel.
b. Observations and Findinas ,
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On July 16, a portion of weekly surveillance test ST 6 094 450 0,120 VAC I
Safeguard Power Distribution Alignment and Voltage Check, could not be performed I
due to a clearance on a distribution panel (03Y501).- The procedure step, which
required verification of 120 VAC nominal voltage at the panel, could not be
completed since the panel was deenergized. it appears that when it was identified
that the surveillance test step could not be completed, the clearance should have
been annetated to indicate that when the clearance was removed, the missed
procedure step should be completed to meet the technical specification (TS)
requirement. Apparently, this was not done, and the clearance was removed
without performing the voltage verification afterwards.
On July 18, plant personnel identified that the surveillance had apparently been
missed, and that the TS requirement had not been met. The surveillance test step
was immediately performed satisfactorily, thereby satisfying the TS requirement.
Engineering personnel determined, on July 18, that the TS requirement had bean
met by an alternate means; apparently on July 17, dampers were successfully
stroked, which are powered from the distribution panelin question.
Technical Specification 4.8.3.1 requires, in part, that specified power distribution
system divisions shall be determined energized at least once per 7 days by verifying
correct breaker alignment and voltage on the panels: 120 VAC distribution panel
03Y501 is one of the specified panels. Surveillance test procedure ST 6 094-450-
O, step 4.5.3 requires verification of 120 VAC nominal voltage present at panel
OCC564, which verifies that distribution panel 03Y501 is energized. It was not
clear to the inspector that successfully cycling dampers properly verified 120 VAC
nominal voltage present at the panel. Subsequent to this, the operators who
restored the distribution panel pointed out that they had properly verified the panel
vcitage during the restoration, even though they were not directed to; therefore, the
technical specification surveillance requirement was met,
c. Conclusions
Proper actions were taken to ensure that a TS required voltage verification was met,
once it was discovered to be - 'stially missed. However, personnel did not
properly track the missed su- ance step to ensure that it was completed when
the clearance was removed. Additionally, the engineering review which concluded
that the TS requirement had been met by an alternate means appeared weak.
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M8 Miscellaneous Maintenance issues (90712)
M8.1 (Closed) LER 2 97 007 Unit 2 HPCl System inocerable Due to Cloaaed Turbine
Exhaust Diain Line
This LER concerned an instance where the Unit 2 HPCI system was declared incperable
due to the failure of a routine test; the test concluded that the HPCl turbine exhaust drain
pot orifice was clogged. This rendered the HPCI system inoperable since personnel could
not determine how much water was present in the HPCI turbine. The blockage was
identified during performance of a quarterly surveillance test designed to verify that the
drain line is not blocked. The immediate corrective action was to disassemble and clean ;
the drain line; a small piece of cloth was found block!ng the drain line. Ercineering ]
personnel concluded that since no water was found in the drain line, HPCI would have
perfortned its intended function and was therefore available. Planned corrective actions
included: evaluation of tasks to ensure appropriate foreign material exclusion (FME)
prsctices are specified, evaluation of the HPCI system for increased monitoring in
accordance with Limerick's Maintenance Rule Program, communication of this event to
appropriate personnel, and review of FME Program enhancements in progress to ensure
that the circumstances of these events are addressed by planned actions. Plant
management concluded that the foreign material was most likely introduced during the
system work performed during the refueling outage in February 1997, due to less than
adequate implementation of PECO Nuclear's FME program. Administrative procedure A C-
131, Foreign Material Exclusion, requires in part that FME control recommendations be
defined and included in the work package, and that workers shall understand and adhere to
FME requirements. This violation of the FME program had more than minor significance
since it caused the HPCI system to be inoperable, and was programmatic since it required
broader corrective actions to address identified issues associated with the control of FME.
(VIO 50 353/97 07 03)
lli. Enaineerina
E1 Conduct of Engineering
E1.1 D21 Emeroency Diesel Generator issues (37551)
Lnsoection Scoce
During this inspection period and going back several months, the inspector noted a
number of issues concerning the D21 EDG. This EDG has been oa an increased
frequency testing since early July 1997. The inspector discussed the D21 EDG
failure with engineering personnel, reviewed the associated test failure special
reports, and observed a number of D21 surveillance tests.
b. Observations and Findinas ,
During this inspection period, D21 had two test failures, one on July 26, and the
other on August 28. There have been two other D21 test failures in 1997, one on
January 1, and the other on July 3. The July 3, test failure resulted in increasing
______ _-_____ -
-
3
the technical specification test frequency from monthly to weekly. The two
additional failures since than have iesulted in extending the time period for the
increased frequency testing. The July 3, failure is suspected to be related to
problems ast.ociated with the govemore; both the electronic and mechanical
governors were replaced and the old ones were returned to the manufacturer for
failure analysis. The July 26, failure was du' '.o one of the two rectifier banks
malfunctioning; this rectifier bank was also sent out for failure analysis. The August
28, failure was due to a significant fuel oA leak on the fuel oil return header tube.
The tube's support was found to be loose, which resulted in the tubing rubbinq on a
jacket water pipe elbow, due to engine vibration; the tubing wore through, causing
the iaak. The damaged section of tubing was replaced and successfully pressure
tested, all similar tubing supports for all eight EDGs wcre inspected and tightened as
,
necessary, the repaired D21 tubing will be replaced during the next overhaul
I
(scheduled for later in 1997), and an rassessment of tubing supports will be
performed to investigate the modification or replacement of the tubing supports to
l
provide a more positive clamp of the tube and prevent rotation of the support,
Through discussions with engineering personnel, the inspector determined that the
EDus are currently classified as a Maintenance Rule Al system, which results in
increased management attention to the system. Although the EDGs were already
j an A1 system, the fuel oil tubing failure was classified as a maintenance
i
preventable functional failure, which would result in an evaluation to determine if
the system should be classified as an A1 system. Currently the EDGs are getting
increased attention from management, engineering and maintenance personnel.
'
Additionally, the inspector noted that the D21 EDG is scheduled for an 18 month
overhaul inspection late this year. One of the issues engineering personnel plan to
address is the vibration of the engine; although D21's vibration is within the
acceptable range, it is higher the all of the other EDGs. No clear tie has been
identified between the failures on D21 at this time; however, results of the failure
analyses may provide additional information,
c. Conclusions
Actions taken to address each D21 test failure have been appropriate. Although no
clear tie between the failures has been determined, investigations continue.
E1.2 Emeraency Fasel Generator Hioh Cloud Point Resoonse (37551)
a. Insoection Scoos
On August 12, operations personnel were notified of an unsatisfactory tost result
for the EDG fuel oil clouc' point. Specifically, the cloud point maximum is 17
degrees Fahrenheit, whereas the tested cloud point for fuel oil delivered on July 17,
18, and 22 was 18 degrees Fahrenheit. The inspector reviewed the actions taken
by plant personnel to verify that the affected EDGs were operable.
i
---__w
9
b. Observations and Findinas
After operations personnel were notified of the out of specification fuel oil test
results, they declared the affected EDGs inoperable; one Unit 1 EDG (D13) and two
Unit 2 EDGs (D21, D23) were affected by the test results. Technical specifications
require that within 31 days of obtaining the fuel oil sample the specified properties
be verified as met; cloud point is one of the specified properties. For the above
event, the fuel oil was sampled on July 17,18, and 22, and the results were made
known to operations personnel on August 12. Once the EDGs were declared
inoperable, the operators, in conjunction with engineering and chemistry personnel,
devised a plan to determine if the EDGs were inoperable based on the fuel oil
storage tank oil cloud point. The fuel oil storage tanks were sampled, and the
results were immediately tested for cloud point; all were found to be well below the
maximum level. Since the sample might not be a true representation of overall tank
cloud point, since the tank could not be easily recirculated and mixed, chemistry
personnel analytically determined that the storage tanks' cloud points were
acceptable. This was easily accomplished since only a few thousand gallons of
unacceptable fuel oil was added to tens of thousands of existing fuel oil with quite a
bit of margin to the cloud point maximum. The three EDGs were declared operable
late on August 12.
On August 13, when the inspector tried to review the operability determination for
declaring the EDGs operable, no good documentation could be located. Only after
discussing the event with operations, engineering and chemistry personnel, could
the inspector get the complete story as to why the EDGs were declared operaole.
Operations management agreed that a better job of documentation could have been
-
done,
c. Conclusions
Operators appropriately declared three EDGs inoperable when they became aware of :
a potential problem with the fuel oil due to a high cloud point. The EDGs were
declared operable later the same day after it was shown that the oil in the storage
tanks was below the cloud point maximum. However, documentation for the ;
operability determination was weak,in that various work groups had to be i
contacted to get all of the facts of the operability determination.
E7 Quality Assurance on Engineerlag Activities (38701)
During this reporting period the inspectors evaluated selected aspects of PECO's I
procurement program in ceder to confirm that the licensee was effectively l
implementing a OA program to ensure that safety related items were in '
conformance with reguletory requirements, licensee commitments and industry
standards. Specifically, the inspectors reviewed PECO's governing procedural
controls contained in procedures P-C-7," Services Requisition Process," Revision 2,
and P-C-9, " Evaluated Vendor List," Revision 1, as well as selected procurement
purchase orders, the supporting documentation and the associated audit reports.
Within this area the inspectors examined the audit reports used by PECO for
l
10
l
qualifying and maintaining Quality Systems, Inc. (OSI) on its Evaluated Vendors List
i
(EVL), as well as the audit of Continental Technical Services (CTS). The inspectors 1
also performed a limited review of the commercial grade item survey of Dryden Oil
Company.
E7.1.1 Review of PECO Audits and PECO's Use of Third Party Audin
1. Review of the 1992 PECO Audit Report for OSI
The inspectors performed a partial review of the 1992 PECO audit of OSI that was
conducted February 26 27,1992, at OSI's Birdsboro, PA facility (Reference: PECO
Audit Report No. VA A 174937, dated March 24, 1992). This audit assessed OSl's
pedormance relative to the conducting utility subcontractor audits, surveillances
snd inspections. The scope of the audit appeared to be acceptable for the services
being provided with the exception that there was no documentation to support
PECO's decision not to review the areas of order entry (the processing of incoming
safety-related customer purchase orders) and procurement.
2. Review of PECO's Use of the 1994 Duquesne Audit Heport for OSI
The inspectors also reviewed PECO's use of a 1994 Nuclear Procurement Issues
Committee (NUPIC) joint audit of OSI for the purposes of maintaining OSI on the
PECO EVL. The audit scope was limited to inspection and auditing services
provided by OSI to the nuclear industry. This audit was performed by the
Duquesne Light Nuclear Group (Duquesne) at OSI's Birdsboro, PA facility on March
10-11,1994. Duquesne used NUPIC Audit Checklist, Revision 4 (the NUPIC
checklist effective for the period of January 27,1993, through April 19,1994).
'
The scope of the Duquesne audit checklist appeared to be acceptable for the
services being provided with the exception that there was no documentation to
support PECO's acceptance of Duquesne's decision not to review QSl's order entry
and procurement practices.
PECO informed the inspectors that prior to January 1995, PECO Instruction No. 4,
" Evaluated Vendors List Instruction," Revision O, dated December 16,1993, was
used to accept NUPIC audits including the 1994 Duquesne audit of OSI. Section
7.2.3, " Quality Assurance Audit / Survey Review," and Exhibit 4-8, " Audit / Survey
Review Form Checklist," of Instruction No.4 requires that th: PECO Assessor
assigned to process a NUPIC audit report, evaluate the acceptability of the
information contained in the NUPIC audit report and its supporting checklist and
ensure that any NUPIC checklist attributes marked "Not Applicable" are adequately
explained and justifiable. Contrary to the requirements of Instruction No. 4, there
was no explanation in the 1994 Duquesne audit and checklist for entering "Not
Applicable" for Checklist Items No.1, " Order Entry," and No. 4, "Procuremont."
The 1994 Duquesne audit of OSI reviewed the corrective action that was
implemented by OSI to address two audit findings contained in the 1992 PECO
audit report for OSI. The 1992 PECO audit report for OSI contained the following
statements concerning two audit findings, documented as Vendor Corrective Action
Requests (VCR):
- . .. _ . - . _ - . . _ - - _ _ . - - - ... - -
l
11 1
e VCR VA O 2151 was issued because QSI has been performing internal
audits utilizing personnel not independent of OSI operations.
- VCR O 2152 was issued because internal audit plans were not being
reviewed by another lead auditor prior to the performance of the audit
required by QSI procedure.
The inspectors verified that the 1994 Duquesne audit of OSIincluded an adequate
review of the implementation of the corrective action for the two VCRs identified in
the 1992 PECO audit of OSI. The following statements were contained in the 1994
Duquesne OSI Audit Report concerning the implementation of OSl's correctiva
action for the two VCRs identified during the 1992 PECO audit of OSI:
- ABSTRACT:
Continued corrective action implementation for findings identified
during the previous NUPlC Joint Audit (PECO Audit No. VA A-
174937, 2/26 27/92) was satisfactory.
- SECTION SUMMARY, Section XI- Program Compliance, item C
,
Internal audits are performed by the Vice President of Operations,
who has no direct responsibility for quality assurance functions, and
reports directly to the President / Chief Executive Officer for QSI. The
1993 internal audit plan was reviewed by an independent lead
auditor. The checklist satisfactorily documented the objective
evidence reviewed.
Based on the above audit results, it appeared that the 1994 Duquesne audit had
verified that OSI had and continued to implement adequate corrective action for the
two VCRs identified during the 1992 PECO audit of OSI.
3. Review of the 1997 PECO Audit Report for QSI
The inspectors also performed a partial review of the 1997 PECO Assessment No.
A1077041, dated April 2,1997, for an audit that was conducted on March 3,
1997, at OSI's Birdsboro, PA facility. The assessment evaluated the
implementation of OSI's OA program as it applies to providing QA auditing and
Quality Verification inspection personnel and services. The assessment was
performed using Revision 7 of the NUPIC Audit Checklist. The scope of the audit
appeared to be acceptable for the services being provided and included within its
scope order entry and procurement. This assessment report contained the following
,
statements concerning order entry and procurement.
<
e investiaated Results, item 1, Order Entry
,
A review and discussion of order entry activities noted that the only
current nuclear utility orders for audit and/or inspection activity has
. . _ .
12
been from PECO and Centerior Energy (CEI). The current PECO
contract for QA services has no releases against it. The CEl contract
for offsite QA support has had various work releases in the last audit
period. QSI has also provided audit / inspection services for nuclear
vendors but they were not addressed in this audit. in accordance
with the OSI QA program, the President and QA Manager have the
responsibility for implementing the QA policy as it pertains to the
services provided and contractually imposed. Seven (7) purchase
order releases were reviewed and found to be properly addressed by
OSI as described on the Quality Assurance Agent Support Forms
(OAASFs). No instances were identified where purchase order
requirements could not be met, This area is considered satisfactory.
e investiaated Results, item IV, Procurement
Procurements are controlled by Sections 4 and 7 of the Qaality
System, Inc QA Manual. Per discussion with the QA
Manager, OSI does not purchase material or equipment. Any
inspections reo' ring calibrated equipment to be performed by
QSI are accomplished using the client's andts vendor's
equipment. While OSI does have measures established for the
procurement of services, none have been issued.
4. Review of Audit Reports for CTS
The inspectors performed a partial review of the 1995 PECO Audit Report No. VA-
A0945946, dated August 2,1995, for an audit that was conducted July 19 20,
1995, at CTS's Stone Mountain, GA facility. The audit scope was limited to
inspection, nondestructive examination (NDE), and auditing services provided by
CTS to the nuclear industry. The scope of the audit appeared to be acceptable for
the services being provided. The NUPIC Audit Checklist used by PECO for this
audit was Revision 6 (the NUPIC checklist effective on March 26,1995). As a
result of this audit, nine VCRs were issued.
5. Comparison of OSI and CTS Audit Reports
The inspectors questioned PECO about the apparent differences in selected audit
checklist elements used for the audit of OSI and CTS. Initially, it appeared that the
audit scope for CTS was far more extensive than the audit scope for QSI. The
inspectors determined that this was the result of the use of different revisions of
the NUPIC audit checklists being used to audit OSI and CTS.
For example, Revision 4 of the NUPIC Audit Checklist was used for the 1994
Duquesne audit of OSI and the following are some of the NUPIC Audit Checklist
sections that were identified as being applicable or not applicable for QSl:
- Section 1 - Order Entry, NOT APPLICABLE (NA) ,
- Section IV - Procurement, NA l
l
l
l
I
_ _ _ . _ . _ - - . ___ . _ _ _ _ _ _ .
13
e Section VI- Fabrication / Assembly, Special Processes, NA (See NOTE)
e Section Vil- Test / Inspection, APPLICABLE
e Section Vill- Handling, Storage, and Shipping, NA
e Section IX - Calibration, NA
e Section X - Document Control, AFPLICABLE
NOTE: According to PECO, special processes (e.g., NDE services) is a
service provided by OSI.
However, Revision 6 of the NUPIC Audit Checklist was used for the 1995 PECO
audit of CTS. The following are some of the NUPIC Audit Checklist sections that
were identified as being applicable or not app licable for CTS.
e Section 1 - Order Entry, APPLICABLE
e Section IV - Procurement, APPLICABLE
e Section V - Material Control / Handling, Storage, & Shipping, NA
e Section VI Fabrication / Assemble /Special Processes, NA (See NOTE)
e Section Vil- Test / Inspection, APPLICABLE
e Section Vill - Calibration, NA
e Section IX - Document Control, APPLICABLE
NOTE: For Audit Checklist item No. VI,Section IV,
" Fabrication / Assembly /Special Processes," of the PECO audit reports
states, " CTS's scope of service does not apply to the control of
fabrication, assembly and special processes since they only provide
Quality Assurance Services (i.e., OA/QV Inspections). The
assessment of CTS's control over the qualification and certification of
-
NDE personnel is addressed in Section V Inspection / Tests of this
report."
Based on a review of the above information, the NRC inspectors determined that
the only apparent differences in the NUPIC Audit Checklist sections used for the
1994 Duquesne of OSI and the 1995 PECO Audit of CTS were as follows:
e Order Entry was reviewed during the CTS sudit, but was not reviewed during
the OSI audit.
e Procurement was reviewed during the CTS Audit, but was not reviewed
during the OSI audit.
, Conclusion
Based on a review of PECO's 1992 audit of Quality Systems, Inc. (OSI) and PECO's
use of a 1994 Duquesne' audit of OSI for the purposes of maintaining OSI on the
PECO Evaluated Vendor List (EVL), the inspectors determined that PECO failed to
, document why the areas of order entry and procurement were not considered and
, reviewed during the implementation audit of OSI quality assurance (QA) program.
The inspectors determined that the acceptance of the 1994 Duquesne audit
!
. _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _
14
appeared to be contrary to the requirements of PECO Instruction No. 4, " Evaluated
Vendors List Instruction," dated December 16,1993, becaute of Duquesne not
explaining why the areas of order entry and procurement were not reviewed during
the audit. However, the inspectors determined that the scope of the 1997 PECO
audit of QSt included the order entry and procurement processes. In its 1997 audit
of OSI, PECO determined that OSI had adequate OA program and implementing
procedure controls in place for the order entry process and based on a review of
several order entries, PECO determined that these controls were being effectively
implemented. Further, in its 1997 audit of OSIin the area of procurement, PECO
detemined that OSI had not issued any purchase orders (POs) for safety-related
equipment or services.
Because of the nature of the audit omissions in the 1992 PECO audit and the 1994
Duquesne audit and the fact that the 1997 audit confirmed OSI had implemented
adequate QA controls for order entry and in the area of procurement, OSI had not
issued any safety-related POs, the failure of PECO to evaluate OSl's implementation
of these areas constitutes a violation of minor significance and is being treated as a
non-cited violation consistent with Section IV of the NRC Enforcement Policy.
(NCV 50 352,353/97-07 04)
l
E7.1.2 Review of Commercial Grade Survevs
1. Commercial Grade Survey of Dryden Oil
The inspectors performed a limited review of PECO's 1994 commercial grade
survey of the Dryden Oil Company (Dryden) that was conducted April 12-13,1994,
at Dryden's Baltimore, MD facility (Reference: PECO Assessment No. CG A-
OR'34410, dated May 11,1994). The commercial grade survey was performed
using the NUPIC Commercial Grade Survey Checklist, Revision 1, and assessed
Dryden's commercial controls and performance relative to the supply of lubricants,
oils, and greases. Dryden was placed on PECO's EVL as a supplier of commercial
grade products rather than safety-related products or services. As such, Dryden
products would be dedicated by PECO as basic components before use in sa:ety-
related applications. The inspectors determined that since placing Dryden on its
EVL, for the purpose of providing commercial grade items, PECO had issued only
one purchase requisition (Material Requisition No. 0118464) to Dryden for the
supply of non-safety-related oil, and that there was no evidence that the oil had
ever been used. Further, PECO informed the inspectors that the oil had been -
supplied by Dryden in 1995 and was now classified as surplus material.
The inspector concluded that the Dryden Oil survey was adequate to place the
. company on the EVL as a commercial grade supplier. Because PECO is a NUPIC
member,its commercial grade survey of Dryden may be used by other NUPIC
members fer procuring commercial grade items from Dryden and dedicating them as
basic components.
,
l
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~ .- - . _ _ . -- -
i
!
15
' E7.1.3 Purchase Order Revision Controls
a. Insoection Scone
The inspectors reviewed PECO's program for the establishment of technical
procurement controls described in procedures P-C-7," Services Requisition
Process,' Revision 2, and P-C 9, " Evaluated Vendor List," Revision 1. The
inspectors also evaluated the implementation of PECO's procurement program
during the revit>w of safety-related purchase orders (POs) involving OSI and CTS.
b. Observations and Findinas
The inspectors reviewed selected POs in order to determine if these documents
provided appropriate methods and responsibilities for the requisition of safety-
related items and services. In particular, the inspectors examined POs B-LOA-
000479 and B-LOA .000516, which concerned the acquisition of quality verification
support services from CTS and OSI respectively. Based on the review of these POs
it was determined that PECO's Purchasing Department had initiated the requisition
subsequent to a request from Nuclear Quality Assurance (NOA) for support services
et both the Limerick and Peach Bottom stations for future outage work. However,
as indicatea by the licensee, neither OSI nor CTS had provided any quality
verification personnel (e.g., ANSI N 45.2.6 Level I,11, or 111 inspectors) to either
Limerick or Peach Bottom.
As determined by the inspectors, the CTS PO (B-LOA 000479) had been
appropriately initiated by authorized personnel in the licensee's purchasing
organization in accordance with the requirements of procedure P C-7. The
inspectors also ascertained that subsequent changes to the PO including the
termination of this requisition were appropriately authorized by functionally
designated PECO personnel. However, during the review of the associated
purchase order documents, the inspectors noted that despite the apparent change in
scope of the PO for CTS (e.g., Revision 1 placed the order on hold and Revision 2
canceled the requisition) limited supporting information, related to a record of
transaction or a purchase order review form, was available to address the potential
effects of these changes on the technical and quality requirements of the PO.
Additionally, as described in paragraph 7.11 of procedure P-C-7, changes to an
issued PO require that the requester prepare a Request for Change Order (RCO)in
accordance with Exhibit P-C-7-9 of the procedure. However, as determined by the
inspectors the specified RCO had not been completed in conjunction with the
termination of PO B-LOA-000479 as required.
During the review of PO B-LOA 000479, the inspectors noted that a June 22,
1995, memorandum, from the Peach Bottom Quality Division to PECO's
4
procurement organization, conceming the composition of contract support personnel
had been forwarded to all of the organizations competing for the quality verification
support services contract. The memorandum stated that, "It would be beneficial if
at least 5 of the 16 candidates hava current Level ll certifications in: Ultrasonic
'
Inspections (UT) or instrumentation and Controls." Based on the review of this
16
memorandum, the inspectors determined that it had been properly forwarded to the
prospective contractor organizations by PECO's procurement organization and that
it did not materially alter the intent of the PO in that it merely expanded on the
specific areas of expertise associated with the requested ANSI N45.6 SNT-TC-1 A,
Level 11 certified inspectors. Therefore, this memorandum was not regarded as a
substantive change to the requisition which would have necessitated a revision to
the purchase order.
As a result of the review of procedure P-C-7, the inspectors determined that
appropriate provisions had been established for the evaluation of " sole source"
suppliers including the development of Exhibit P-C-7 7, Pole Source Justification
form. Howevor, none of the POs reviewed during this inspecthn involved sole
source suppliers and the examination of this area was limited to the ovaluation of
PECO's procedural controls.
As previously noted, PO B-LOA-000479 underwent two revisions the first of which
, placed the requisition on hold, pending the completion of an audit of CTS's quality
assurance (QA) plan. Relative to Revision 1 of the PO, the licensee stated that the
terms "QA program" and "QA plan" were used interchangeably relative to the
process of verifying the vendors compliance to the requirements of Appendix B of
10 CFR Part 50. The need for auditing CTS's OA program had been documented
on PEP 10003739, dated March 13,1995, subsequent to the licensee's
determination that a safety-related PO had been issued to an unapproved vendor
(CTS) who was not on the Evaluated Vendors List (EVL). Specifically, the PEP
indicated that contrary to the requirements of Procedure Number PA 3,
" Administrative Controls for Purchase of items and Services for Nuclear Safety
Related Applications at Power Plants" and Procedure P-C-7, Revision 1, purchasing
had incorrectly issued a PO to a supplier of quality verification personnel services
without the vendor being listed as either approved or conditionally approved on the
EVL. The PEP further stated that the vendors OA program would need to be
formally evaluated and approved by NOA prior to the vendor providing quality
verification services. This condition was imposed even though CTS would be
working under PECO's OA program, because the PO specified that the vendor was
responsible for supplying ANSI N 45.2.6 Level 11 qualified inspection personnel
under CTS's OA program, which was required to meet the applicable criteria of
Appendix B of 10 CFR Part 50.
Based on the review of PEP 10003739 the inspectors determined that appropriate
corrective actions had been developed in response to this nonconformance including
the revision of procedures PA-3 and P-C-7 to clarify the requirements related to the
placement of safety related service POs and an organizational realignmeni which
currently has the Nuclear Group processing their own procurement requisitions.
However, as a result of the review of this PEP, it was determined that the
documented generic implications review of similar POs, to verify that the identified
condition was an isolated occurrence, had not been completed in conjunction with
the close out of the Performance Enhancement Program (PEP). Subrequent to the
identification of this issue, the licensee revised PEP 10003739, on September 16,
1997, to address the inappropriate closure of the PEP without completing the
1
l
17
generic implications assessment. The revised PEP indicated that Nuclear Quality
Assurances' current assessment (A1103691) involving the Nuclear Groups
procurement activities included a review of POs for products and services. ;
Specifically, the evaluation was performed to determine if safety related products i
and services were being procured from approved or conditionally approved vendors 1
on PECO's EVL in accordance with procedures P-C 1 and P-C-7. This assessment,
which utilized a representative sampling process, did not identify any deficiencies
and the generic review aspect of this PEP was appropriately completed.
c. Conclusions
Within the areas examined, two examples involving the lack of adherence to
administrative controls related to procurement transactions were identified. The
examples included the issuance of a purchase order to a supplier of quality
verification personnel services without the vendor being listed on the evaluated
vendor list, documented in PEP 10003739, and the failure to complete a request for
change order when a contract was terminated. The inspectors also identified that
PEP 10003739 had been inappropriately closed without the performance of the
specified generic implications review. However, the licensee's subsequent
corrective actions were prompt, and included a comprehensive assessment of the
Nuclear Groups procurement activities. Although the noncompliances identified
collectively indicate a weakness in the licensee's implementation of procurement
controls, this failure constitutes a violation of minor significance and is being treated
as a non-cited violation consistent with Section IV of the NRC Enforcement Policy.
(NCV 50-352,353/97-07 05)
IV. Plant Suooort
R1 Radiological Protection and Chemistry (RP&C) Controls
R 1.1 Imolementation of the Radioactive Liouid and Gaseous Effluent Control Proarams
a. Insoection Scoos (84750)
The inspection consisted of: (1) tours of radioactive liquid and gaseous effluent
pathways and process facilities; (2) review of unplanneti or unmonitored release
pathways; (3) 1996 Annual Radioactive Effluent Release Report; and, (4) review of
the Offsite Dose Calculation Manual (ODCM).
b. Observations and Fmdinas
The inspector reviewed the 1996 annual radioactive effluent release report. This
report provided data indicating total released radioactivity for liquid and gaseous
effluents. The annual report also summarized the assessment of the projected
maximum individual and population doses resulting from routine radioactive airborne
and liquid effluents. Projected doses to the public were well below the Technical
Specification (TS) limits. The inspector identified no additional anomalous
measurements, omissions or adverse trends in the reports.
_- . - - .- =
18
The inspector reviewed a licensee 10 CFR 50.59 analysis pertaining to numerous
typographical discrepancies within the ODCM and planned changes to address
those discrepancies. The inspector identified no additional discrepancies within the
ODCM or noted any inadequacies pertaining to the 10 CFR 50.59 analysis. The
licensee was in the process of implementing new dose assessment software at the
time of the inspection. The licensee plans to make additional changes to the ODCM
prior to formal programmatic implementation of this software.
The inspector conducted a tour and reviewed selected radioactive liquid and gas
processing facilities and equipment, including effluent / process / area radiation ,
monitors and air cleaning systems. The major component out of service at the time
of the inspection was the RM-21 Radiation Monitoring System (RMS) computer and
the licensee was initiating actions to address this particular equipment problem.
Although this equipment was out of service, it did not impact the licensee's
capability to comply with licensee requirements, in that it is used as a data
collection tool. The licensee is performing manual data retrievalin accordance with
the ODCM.
The inspector reviewed a special study conducted by the licensee to account for
potential releases from a modificatiun of the Chemistry Laboratory roof. This report
was well-detailed and no inadequacies were noted by the inspector,
c. Conclusions
Based on the above reviews, that inspector determined that the licensee maintained
and implemented good routine radioactive liquid and gaseous effluent control
programs.
R2 Status of RP&C Facilities and Equipment
R2.1 Calibration of Effluent / Process / Area / Accident Radiation Monitorina Systems (RMS)
a. Insppction Scoce (84750)
The inspector reviewed the most recent calibration results for the following selected
effluent / process / area / accident RMS.
- North Stack Effluent
- Wide Range Accident
'
- South Stack Effluent
- Air Ejector Offgas Effluent
- Liquid Radioactive Waste Discharge
- __ .. , . .- . -_. - - . - . - _ _ .
19
b. Observations and Findinos
t
The inspector noted that the licensee used multiple calibration sources and took
multiple roadings during the RMS calibration process. All calibration results
reviewed were within the licensee's acceptance criteria.
4
The inspector discussed the maintenance and operability / reliability with the RMS
system engineer who has been assigned the system for the past several years. The
inspector reviewed work orders for RMS back into 1996. The inspector noted that
the backlog and timeliness of addressing problems has improved. The system
engineer attributed this improvement to the fix-it-now teams.
The inspector noted the following potential areas for improvement regarding the
RMS.
, e Reliability / availability was not formally tracked.
- One of the acceptance criteria was that the calibration factor had to be
within 135% of the previous calibration factor. The inspector considered
this a large acceptance band.
e Linearity of the RMS was not formally determined. The inspector noted that
the correlation coefficient from a least squares fit of the calibration data was
, a good parameter for trending system performance.
.
The Radiation Protection Manager indicated that these matters would be reviewed
, and corrective actions would be taken, as appropriate.
1 c. Conclusions
The RMS calibration program was good. Several opportunities were identified in
which system tracking and trending could be improved.
R2.2 - Air Cleanino Svstems
,
a. Insoection Scoce (84750)
The inspector reviewed the licensee's most recent surveillance test results (visual
inspection, in-place high efficiency particulate air (HEPA) leak tests, in-place
charcoal leak tests, air capacity tests, pressure drop tests, and laboratory tests for
the iodine collection efficiencies) for the control room, reactor enclosure and
refueling area, standby ges treatment, and radioactive waste enclosure common
tanks vent and equipment.
b. Observations and Findinos
'
No discrepancies were noted for the in-place HEPA leak tests, in-place charcoal leak
j tests, air capacit y tests.
_ _ _ _ _ _ _ _ _ _ _ _ .
- - _ - _ - . - . - . .- -- . -. -- - ..
20
The licensee's TS specify Regulatory Position C.6.a of Regulatory Guide (RG) 1.52,
Revision 2, March 1978, as the requirement for the laboratory testing of the
.
charcoal. RG 1.52 references ANSI N509-1976, " Nuclear Power Plant Air-Cleaning
Units and Components." ANSI N509-1976 specifias that testing is to be performed
in accordance with paragraph 4.5.3 of RDT M 161T, " Gas Phase Adsorbents for
Trapping Radioactive lod *e and lodine Components." Charcoal efficiency testing
was conducted by a ver. Jr service. The Office of Nuclear Reactor Regulation
(NRR) has identified a potential testing discrepancy regarding charcoal efficiency
testing using the methodology described in RDT M 161T. This matter involves
'
.
testing conditions for the charcoal. This matter will be further reviewed
(IFl 50-353/97 07-06).
One minor matter regarding a lack of acceptance criteria in the Radioactive Waste
- Enclosure Common Tank Vent and Equipment procedure ST-4-079 320-0 was
noted by the inspector. The inspector assessed that the most recent surveillance
'
results did not appear to conflict with the system flow rates denoted in the UFSAR.
The inspector reviewed a 10 CFR 50.59 review pertaining to a potential surveillance
test failure of the "A" CREFAS Monthly Operability Test conducted on June 18,
'
1997. This analysis determined that an eighth of an inch water gauge had been
i maintained with respect to surrounding structures and outside conditions and
identified some discrepancies in the surveillance procedure in-use at that time.
Corrective actions were taken. The inspector noted no discrepancies pertaining to
this 10 CFR 50.59 review.
'
The inspector reviewed work orders for selected systems back into 1996. The
inspector noted that the backlog and timeliness of addressing problems has
improved. The system engineers attributed this improvement to the fix it-now
teams.
!
c. Conclusions
Based on the above reviews and discussion, the inspector determined that the
licensee implemented a good surveillance program.
R7 Quality Assurance (QA)in RP&C Activities
.
a. Insoection Scone (84750)
L The inspection consisted of: (1) review of the 1996 audit: (2) a radiation protection
'
self assessment; and (3) implementation of the measurement laboratory quality
control program for radioactive liquid and gaseous effluent samples.
- b. Observations and Findinas
'
The inspector reviewed the NOA audit of the effluents program. The audit was
well-targeted and no issues of regulatory significance were noted by the audit team.
.
4
. _ _ _ _ _
_ _ _ -___ _ - _ __ - -
21
The licensee's self-assessment was self-critical and highlighted challenges regarding
RMS aging and ODCM discrepancies.
OC over instrumentation was very good. The inspector reviewed the QC data for
inter-laboratory comparisons. The inspector noted that the last two tutium samples ,
(second quarter 1996 and first quarter 1997) were in disagreement with the vendor
laboratory. The licensee attributed the first disagreement to improper distillation
techniques. Thn licensee was unable to explain the second disagreement. The
Chemistry Supervisor noted to the inspector that this discrepancy had not been
investigated. The inspector considered this lack of follow up to be a weakness in
chemistry laboratory QC. The Chemistry Supervisor stated to the inspector that
sample preparation OC would be programmatically strengthened.
c. .Qnpelusions
Based on the above reviews, the inspectors determined that the licensee's OA audit
was good. Overall, the licensee implemented a good OC program to validate
measurement results for effluent samples.
F1 Control of Fire Protection Activities
F1.1 Main Conttql Room Fire Sucoression System (71750)
l
During this inspection period, the inspector reviewed the UFSAR basis for an
automatic fire suppression system for the control room with a focus on inadvertent
I
actuation of the system, in so doing, the inspector considered the following
questions:
1. Does the control room have an automatic fire suppression system (AFSS)?
If yes, does it have initiation logic along with actuation on a automatic time or
manual delay basis and what chemical is used (e.g., water, halon, carbon dioxide,
etc.)? Describe briefly.
If no, identify what is used for fire suppression in the control room.
2. With an AFSS, does the licensee have specific or general
abnormal / emergency procedures for an inadvertent actuation of the AFSS
during operations and shutdown?
Desciibe immediate actions and briefly describe supplemental actions.
3. Do licensee procedures and/or technical specifications provide for the use of
emergency breathing apparatus for in the control room (give type of
apparatus: SCBA, Air line, etc.)? Is there sufficient equipment to support the
control room staff? Are the numbers specified in TS, procedures,
surveillances? Do these numbers reflect what actually exist in the plant?
- -
_ _ _ _ _ _ _. _ _ _ . __ _ _ _. . _ _ _ . __ ___
22
Briefly describe the type of apparatus and when they would be used.
Limerick Generating Station's UFSAR 9A.5.3.24, Fire Area 24, Control Room and
Peripheral Rooms, states that a fire activates smoke detectors, which cause an
audible / visual annunciation to register on the fire protection panels in the control
room. Operators then callin the plant fire brigade to manually extinguish the fire. +
There is no automatic fire suppression system for the control room. Fire procedure
F A-533, Control Room 533 and Peripheral Rooms 530 to 535 (El. 269) Fire Area
24, revision 4, proposes stretching a CO2 hose line into the control room, from just
outside the control room door, and attacking the fire, as the primary strategy. The
secondary strategy is to stretch the dry chemical unit hose from the turbine building
through the control room door and attacking the fire. For fires in the peripheral
rooms, the procedure proposes attackirig the fire using portable fire extinguishers,
located in the control room, as the primary strategy; the portable extinguishers use
halon as the extinguisher.
Limerick UFSAR 6.4.4.2.3 states that full-faced demand self-contained breathing >
apparatus rated for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per cylinder and protective clothing are available for
contro! room operators. Routine Test procedure RT-0-111-900-0, revision 18, One-
hour SCBA Cylinder inspection and Functional Test, which is performed monthly or
after use, specifies a minimum of 14 SCBA Paks for the control room. The
inspector counted 14 SCBA Paks in the control room. Special Event procedure SE-
2, revision 10, Toxic Gas / Chlorine, directs operators to don self-contained breathing
apparatus within 2 minutes for: High Toxic Chemical Conc alarmed; Control Room
Chlorine Isolation Initiated alarmed; and Harsh or unusual odor.
F2 Status of Fire Protection Facilities and Equipment
F2.1 In-Plant Walkdowns (92904)
a. Scoos of insoection
The inspector conducted in-plant walkdowns of portions of several fire protection
procedures, During these walkdowns, the inspector took note of the material
condition of the. fire protection equipment. The specific procedures which were
evaluated in the f; eld are indicated in the list of procedures in the attachment to this
report. Additionally, the inspector discussed recently identified problems with
deluge valves with fire protection staff members.
b. Observations and Findinos
Recently, several issues have developed which involve the facility design. These
issues include identification of structural steel requiring fireproof coating, aiming and
testing of emergency lighting units required for safe shutdown, and compatibility
___ _ problems between the installed fire suppression system deluge valves and their
electronic control panels. To assist with resciution of these design issues, PECO
will assign a supervisor from the Probabilistic Safety Assessment (PSA) group in
Nuclear Engineering to the site for a period of six montns. The PSA group is the
organization within Nuclear Engineering with responsibility for fire protection.
I
_ _ _ _ _ _ _ _ __ - _ - _ _ . - - _
23
Auxillary Equipment Room Halon* Stations
The inspector observed the condition of the Unit 1 and Unit 2 Auxiliary Eo.uipment
Room Halon* banks. The Halon* cylinders ond connections were free of excessive
corrosion products. The connections were tight and marked to show whether the
cylinder which was connected at that point was in the main or reserve bank, and
which cylinder was connected (Main 1, Reserve 2, etc.).
Fire Suppression Water System Deluge Valves
The inspector noted the condition of the sprinkler systems throughout the plant and
observed that they appeared to be well-kept and in good condition. Two open head
sprinkler systems were inspected in detail, the Unit 1 Reactor Enclosure Hatchway
Elevation 217' Sprinkler System, DL-72, and the Unit 1 Reactor Enclosure Water
Curtain Elevation 217', DL-68. The equipment was well-preserved, lined up for
actuation, and the valves associated with the deluge valve station were clearly
marked.
During discussions with the fire protection staff, the in 3ector was informed that
PECO had recently determined that there is a compatibility problem between the
installed deluge valves and the currently installed electronic control panels. This
matter was evaluated by PECO Nuclear Engineering, and corrective actions included
replacement of the six inch deluge valves. Currently, when a deluge valve fails a
surveillance test, it is reworked, and returnri to fe'l functional condition.
Fireproof Coated Steel
The incpector observed the status of the coating on beams in the plant which are
required to be protected from the effects of an exposure fire. The inspector noted
that there were uncoated attachments on several of the beams, in response to the
inspector's questions regarding the extent to which attachments need to t,e coated,-
PECO engineering personnel contacted the supplier of the coating material, and
were advised that unless the attachment constitutes a significant portion of the
beam cross-section, it need not be coated beyond the depth of the beam coating.
Plans are to incorporate this information into a specification being generated which
willlist, in detail, those beams requiring protection (see discussion in Section F4.1).
The inspector found this response acceptable.
Battery Powered Emergency Lights
The inspector performed a walk down of the Unit 2 Residual Heat Removal (RHR)
system equipment listed in UFSAR Appendix 9A as requiring remote cperation for
shutdown from outside the control room. The inspector noted the Nsitioning of the
emergency lighting units (ELUs) and the aiming of the heads. The inspector
dotermined that the RHR equipment and the pathways to the RHR equipment are
illuminated. The inspector also notad that many of the ELUs now have red labels
affixed indicating that the units are required for safe shutdown and the heads are
not to be moved. Fire protection staff members informed the inspector that
-
x -
- . _ - - . . _ _ _ - . - - . . - - - _ .. . . --
24
'
completion of the safe shutdown lighting review was expected in the September-
October time frame this year. PECO currently plans to mark the lamp heads
showing the alming points starting about November 1997. The inspector checked
the condition of a number of ELUs and found them to be free of corrosion, with
proper electrolyte levels and charging indications. A review of previously completed
' _ inspections indicated that several ELUs were found to have deficiencies during each
inspection. The deficiencies were entered into the PECO corrective action system.
Fire Dampers
The inspector used the mechanical drawings listed in ST-7-022-921-2,
i
Attachment 1, Rev.1, Fire Damper Tabulation, to locste fire dampers in two areas
- of the Unit 2 Reactor Enclosure, Area 13 of Elevations 253' and 217', For those
- dampers readily accessible (i.e., not greater than six feet from floor level nor in high
- radiation areas), the inspector verified that the locations shown on the drawings
matched the field locations. In addition, the inspector evaluated labeling and
accessibility to perform maintenance. The inspector did not open the access panels
at the dampers. The inspector determined that the dampers were at the locations
shown on the drawings, and those accessible had bar code labels affixed,
c. Conclusions
Based on the observed condition of the selected equipment in the field, the
inspector concluded that the fire protection equipment is in good repair, readily
identifiable, and ready for use.
F3 Fire Protection Procedures and Documentation
F3.1 Procedure Uoarade Proaram (92904)
a. Insoection Scooe
The inspector reviewed a sample of current revisions of procedures governing fire
protection activities. The inspector evaluated the extent of the revisions, and their
affect on the procedures' useability, in addition, several procedures were taken to
the field by the inspector to evaluate adequacy of the procedures for conducting the
activities. The procedures reviewed are listed in an attachment to this report.
Those procedures which were " walked-down" in the field are identified in the
attachment.
b. Observations and Findinas
As discussed in NRC Integrated Inspection Report (01) 50-352 & 353/97 01, PECO
had initiated a Project Plan to improve fire protection procedures. Action Request
(AR) A1050861, Limerick Generating Station _(LGS) Fire Protection Procedures, is
being used to track the surveillance test (ST) and routine test (RT) procedures in the
Fire Protection Rewrite Procedure Project which was initiated to enhance the clarity
of fire protection test procedures. The AR contains 55 separate items to track
__ -_
25
individual procedures, with scheduled completion dates prior to the next scheduled
use of the procedure, in view of the goal of Industrial Risk Management (IRM) to
trensfer the testing to other departments for performance, the revised procedures
will u:e the station standard format with simpler steps, corresponding sign-offs for
each step, and caution statements and notes set off prior to the step to which they
are applicable (human factors format). The change of fire protection from Technical
Specifications to Technical Requirements Manual (TRM) is also being captured in
the revisions. Inspector observations related to specific procedures are given
below:
Halon* System inventory Procedures
Procedures ST-7 022-3531, Rev. 4, Halon System inventoryi and ST-7-022-353 2,
Rev. 6, Halon System inventory, formerly checked both the main and reserve banks
at the same time, if any of the cylinders were found to be out of specification on
weight or pressure, the procedure directed moving cylinders between the banks to
return at least one bank to operable status. The new revisions test one bank at a
time, either the main or reserve bank. This ensures that one bank remains operable
at all times, since the bank under test is returned to operable status before the other
bank is taken out of service for test. In addition, the format has been changed to
the human factors format, and steps have been simplified. The prior revisions
required recording the empty weight of the cylinder from the stamping at the neck.
The new rovision simply requires recording the cylinder empty weight, since a
number of the new cylinders have the empty weight marked on a label affixed to
the side, rather than stamped at the neck. The inspector walked-down procedures
ST-7-022-353 2, Rev. 6 Halon System Inventory, ST-7-022 353 2, Rev. 7, Unit 2
Main Bank Halon System Inventory,-and ST-7-022-354, Rev. O, Unit 2 Reserve
Bank Halon System Inventory, in the field and found them to be adequate for
performing the required tests.
Procedure RT-7-022-353-0, TSC Halon System Inventory, ensures the gaseous
agent fire suppression system for the Technical Support Center (TSC)is operable.
The new revision, Rev. 5, sets off notes and cautions at the appropriate step, and
adds specific sign-offs for meeting the minimum weight and pressure range
acceptance criteria. Rev. 5 also improves the readability of the procedure over
Rev. 4, and simplifies the instructions. Fire protection group personnel informed the
inspector that they plan to contract this work, along with all other " commercial
building" (outside the power block) fire protection system testing, to an outside
company. Responsibility for oversight will remain with the PECO fire protection
group.
Emergency Lighting Unit Procedures
The inspector reviewed the current and prior revisions of the safe shutdown ELU
test procedures,_ RT-6-108-300-0, Rev. 6 and 4, RT-6108 300-1, Rev. 5 and 4,
and RT-6-108 300-2, Rev. 4 and 3, Safe Shutdown Eight (8) Hour Self Contained
Battery Pack Operation Verification. The prior revisions of the procedure contained
directions for irispecting the ELUs, along with individual step signoffs for the
. _ _ _ _ _ _ - _ _ _ - - _ _ - - _ _
26
inspection steps, diagrams showing individual ELUs, paths and equipment to be
illuminated, and signoffs for each safe shutdown ELU. The new revisions retain the
diagrams and individual ELU signoffs, but have deleted the individual inspection step
signoffs to improve clarity. The inspection steps and acceptance criteria have been
retained.
Fire Rated Structural Assembly Procedures l
Procedure ST-7-022 920-1, Rev. 3, Un41 Refuel Fire Rated Assembly inspection, !
provides guidance and acceptance criteria for conducting inspections of fire rated
structural assemblies (including structural steel) and electrical raceway fire
encapsulations. The procedure requires all visible and accessible assemblies to be
inspected. The specific items to be inspected are listed in attachments to the
procedure. Attachment 1 provides a list of the fire rated structural assemblies
(walls, slabs, etc.) and Attachment 2 provides a list of the raceway encapsulations.
At the current time, all the raceway encapsulations are considered to be inoperable
in accordance with NRC Generic Letter (GL) 92-08 regarding Thermo-Lag issues,
and hourly fire watches are being performed. There is a corresponding procedure
and set of attachments for Unit 2.
!
in August 1996, PEP issue 5811, insulation Missing From Structural Steel, was
I
initiated, documenting deficiencies identified during the inspection of the fire rated
assemblies. One of the difficulties identified by PECO employees was identification
of the specific structural steel members which required coating. The fire protection
group has maintained a copy of Engineedng Work Request (EWR) L 00508 which
showed those steel members requiring protection from exposure fires. The
drawings included in the EWR package date from 1989, and are not otherwise
available at the site. To resolve the problem with accessibility of the information,
PECO Nuclear Engineering is developing a specifieration, NE 264, which willlist each
specific structural steel member requiring coating, and the required extent of the
coating. The Unit 2 portion of the listing has been incorporated into ST-7-022-920-
2, Attachment 1, Rev. 5, Structural Fire Rated Assembly Tabulation, dateo April 22,
1997. The inspector concluded that this will simp!!fy obtaining the information, and
makes performing the inspection easier. The Unit 1 listing has not yet been
incorporated into the corresponding tabulation, which still contains a single signoff
for the steel being inspected in accordance with the EWR,
Fire Damper inspection Procedures
PEP 6033, improvements to Fire Protection Procedures and Program, has an entry
from March 1997, indicating that several of the procedure revisions tracked by AR
A1050861 are overdue. One of the overdue revisions was for ST-7-022-921-2,
Fire Damper Inspection. This procedure contains instructions for inspection and
functional testing of fire dampers. The procedure contains wording which allows
corrective actions to be taken if a fire damper does not perform properly during the
functional test, and requires a notation in the Additional Action / Test Comments
Section. The procedure also contains a requirement to clean and lubricate the
latching mechanism of trap door type fire dampers. The list of dampers to be
a
27
inspected is contained in an attachment to the procedure. Revision 2 of the
procedure, dated May 21,1997, revised the reference to the list of dampers. The
inspector field verified locations of dampers in several plant areas, as discusseu in
Section F2.1, using ST-7-022-9212, Attachment 1. Rev.1, Fire Damper
Tabulation, dated February 14,1995. The dampers were located at the positions
shown in the referenced drawings, and were readily identifiable. The inspector
noted that several of the dampers would require significant preparatory work in the
form of scaffolding and health physics surveys to perform the inspections.
Fire protection group personnel informed the inspector that the current procedure
was cumbersome to use in that it required inspections of dampers in several
systems at the :ame time. Their intent is to revise the procedure and tabulation to
group the fire "oers on a system basis, rather than plant area basis. This will
enable persont C h .erforrn the inspections during system outage weeks.
While reviewin9 other fire damper inspection procedures, the inspector noted that
ST-7-022 9210, Rev. 6, Fire Damper inspection, had two temporary changes
against it at the time of the inspection. One corrected a TRM reference to the
correct technical specifications (for control room ventilation LCOs) and the other
required compensatory actions to be taken during the inspection of the dampers in
the control room normal and emergency Ventilation systems. These compensatory
measures are necessary because with the ductwork access panels open, the
ventilation systems cannot isolate on toxic gas release, radiation release, or steam
line breaks. These compensatory actions were developed as a result of an ongoing
review of fire protection procedures to determine plant impacts.
Sprinkler System Procedures
Two recently revised procedures covered sprinkler systems: RT-7-022-322-0,
Remote Buildings (Outside PAB) Sprinkler System Operability Verification, and
RT-7 022-320-1, BOP Fire Protection Sprinkler System operability.
The buildings outside the protected area boundary (PAB) were not within the scope
of NRC purview, 'out the inspector reviewed the procedure to verify consistency
with in-plant procedures. PECO plans to contract this work to an outside company,
so the procedure was revised to a more conventional text format. Cautions and
notes were set off just prior to the step to which they apply, as with the human
factored procedure formst.
The balance of plant (BOP) procedure will be used by station personnel and so was
converted to the human factored procedure format. The BOP procedure was also
split into two procedures. RT-7 022-3201, Rev. 6, BOP Fire Protection Sprinkler
System Operability Verification, details the 18-month tests of wet pipe sprinkler
systems in the turbine building. RT-7-022-321 -1, Rev. O, Outage Wet Pipe
Sprinkler System Operability Verification and Visual Inspection, tests those systems
which are not accessible during normal operation (condenser bay and moisture
separator area).
!
1
_ _ . _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . ____ _ _ . _ .
_
4 28
_To_ evaluate a representative procedure which had not been revised, the inspector
, reviewed ST 7 022-730-1, Rev 4, Fire Suppression Water System (FSWS)
- Air / Water Nozzle Flow Test. This procedure tests open head sprinkler systems and
! pre-action sprinkler systems in the Unit 1 Reactor Building and Diesel Generator
i Cells. The procedure provides.a discrete set of instructions for each individual
sprinkler system. The inspector perfornied a field verification of steps for two
i systems. The systems evaluated were Reactor Etelosure Hatchway Elev. 217,
j; Deluge Fire Protection Sprinkler System, DL-72, and Reactor Enclosure Water
l Cortain Elev. 217, Deluge Fire Protection System, DL 68. The inspector determined
-
p :that for those open head systems where the potential exists to trip the deluge
[ valve, appropriate steps are included to prevent water discharge, and to restore the
system in accordance with station operating procedures. The inspector noted that
- Section 4.3 of Precautions and Limitations provides three alternative methods which
.
may be used for verifying air flow at the open nozzles. A previous review by the ,
[ resident inspection staff determined that PECO is using a fourth method, which is
j functionally equivalent.
I
f The use ot a functional equivalent would appear to be permissible, since the
j procedure step states to _ verify flow at each nozzle, without specifically stating
a how. The inspector noted that the procedure calls for verifying air flow at each
.
j - nozzle, out does not provide the number of nozzles in the various sprinkler systema.
c. . Conclusions
b-
Based on the review of the new and prior procedure revisions, along with the field
I walkdown of the procedures, the inspector concluded that the procedures provide
p adequate guidance and appropriate acceptence criteria for testing of fire protection ,
systems.
,
j: F6- Fire Protection Organization and Administration
i: F6.1 - Fire Protectio, Council (92904)-
4
a. Insoection Scoae
The inspector discussed the activities of the Fire Protec'..on Council with several of
.its members, and reviewed the action items which were generated during its
i meetings.
- b. Observations and Findinas
'
As discussed in NRC IR 50-352 & 353/97-01, PECO instituted a Fire Protection
- Council in February 1997. At the time of that inspection, insufficient time had -
- passed to achieve any significant results.
The Fire Protection Council is comprised of the IRM Managers from Limerick (LGS)
p and Peach Bottom (PBAPS), the Nuclear Engineering Department (NED) Probabilistic
l Safety Assessment (PSA) Branch Manager, the LGS and PBAPS Fire Protection
i
s
_ _
_ . . . _ __ _ _
_ _ --
29
Program and Firt. Protection System Managers, and the NED PSA Fira Protection
Program and Safe Shutdown Program Managers. Other personnel are added if
needed to address specific issues. The management sponsor for the council is the
Executive Vice-President, Nuclear.
The council is functioning to provide management oversight of the fire protection
improvement projects, to establish priorities and to coordinate the efforts between
NED, PBAP3 and LGS. The council has obtained funding to bring in contractor
assistance for the procedure improvement project at LGS, and has added additional
contractor support for the program for calendar year 1998. The council has created
several additional fire protection performance indicators for tracking, including the
availability of the diesel driven, motor driven, and backup fire pumps. The council
will focus on program and process issues, and leave the equipment issues to the
focused improvement team discussed in Section F6.2.
c. Conclusions
1
Based on the discussions with members of the Fire Protection Council and review of I
the Action items generated at its meetings, the inspector concluded that the council
was a good initiative for bringing fire protection issues to management's attention
and prioritizing the improvement efforts.
F6.2 Fire Protection Focused imorovement Team (92904)
a. Insnection Scoce
'
The inspector discuesed the Focused improvement Team (FIT) with team members,
and attended a FIT meeting on-site.
b. Observations and Findinas
The Fire Protection FIT was assembled to provide a higher level of attention to
address equipment problems at the Limerick site. The purpose of the team is to
identify equipment issues, prioritize the equipment issues, search for commonalities
between the Peach Bottom and Limerick sites, and determine courses of action for
long-term resolution of equipment reliability and maintenance issues.
The initial meeting of the FIT was held August 14,1997. It consisted of a
" brainstorming" session to identify the known and potential hardwars issues with
fire protection systems. Action items from the meeting included developing a list of
obsolete parts / equipment and breaking down the equipment issues into logical
groupings, such as fire pump bearing problems, fire diesel battery problems, and so
forth. A second meeting, which the inspector attended, was held August 21,
1997.
The FIT goal is to identify all of the fire protection system functions and
components which do not meet expectations for performance or maintainability and
ensure that the identified issues are being properly addressed. In addition, the FIT
..__ _ -__ _ . . _ _ _
i
)
!
30
will attempt to anticipate future problem areas based on PECO and industry
experience. An example is a recently identified issue with testing of foam fire
fighting equipment. After performing the required test, the concentrate remains in
the lines, and can cause the foam concentnte check valve to stick with a resultant
failure of the next test. The FIT is evaluating what actions to take for resolving this
emergent problem.
c. Conclusions
Based on the issues raised at the FIT meeting, and a review of the action items in
progress, the inspector concluded that the FIT is a good initiative to identify fire
protection equipment and system problems.
F8 Miscellaneous Plant Support issues (90712)
F8.1 (Closed) LER 1-97 006, Previous Condition Prohibited by Tech Snecs in that a Fire
- Protection System Deluae Valve may not have Functioned oer Deslan Since
issuance of the Unit 1 Operatina License.
This LER concerned an instance where station personnel identified that a potential
voltage mismatch may exist between a fire protection deluge valve and its control
panel, resulting in marginal power available to operate the valve. An evaluation
concluded that a technical specification noncompliance occurred between issuance
of the facility operating license for Unit 1 on October 26,1984, and Decembcr 20,
1995, when the applicable technical specifications were relocated to the Technical
Requirements Manual, since the valve may have been unable to perform its design
function. Corrective actions included making adjustments to the valve to optimize
mechanical operation, posting a continuous firewatch, increased testing of the
valve, and the valve was replaced on September 3,1997. This violation had more
tn:.n minor significance since it resulted in a condition where a technical
specification-required deluge valve was inoperable for an extended period of time.
However, safety consequences for this event were low, since no actual fires
occurred in the area. Additionally, had a fire occurred and had the valve failed to
automatically operate, it would have been manually activated by the fire brigade,
which would have responded to the fire alarm. This licensee-identified and
corrected violation is being treated as a non-cited violation, consistent with Section
Vll.B.1 of the NRC Enforcement Policy. (NCV 50 352/97-07 07)
V. Manaaement Meetinas
4
X1 Exit Meeting Summary
The inspector presented the inspection results to members of plant management at the
'
conclusion of the inspection on September 17,1997. The plant manager acknowledged
the inspectors' findings. The inspectors asked whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
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,
X2 Review of UFSAR Commitments
- A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR
'
description highlighted the need for a spacial focused review that compares plant practices, -
procedures and/or parameters to the UFSAR description. While performing the inspections
discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that
related to the areas inspected. The inspectors verified that the UFSAR wording was
, consistent with the observed plant practices, procedures and/or parameters.
.
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32
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 38701: Procurement Program
IP 61726: Surveillance Observation
IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
IP 90712: In-office Review of Written Reports
IP 90713: Review of Periodic and Special Reports
IP 92904: Followup - Plant Support
IP 93702: Prompt Onsite Response to Events at Operating Power
Reactors
ITEMS OPENED, CLOSED, AND JISCUSSED
Ooened
l
[ 352,353/97-07-01 VIO Control of Locked Valves (O2.1)
352,353/97-07-02 IFl Concerns associated with a number of RWCU isolations.
(08.2)
353/97-07 03 VIO HPCI System Inoperable Due to Clogged Turbine Exhaust Drain
r Line. (M8.1)
{
353/97-07-06 IFl Charcoal Efficiency Testing Adequacy (R2.2)
Closed
352,353/97-07-04 NCV Review of PECO Audits and PECO's Use of Third Party Audits
(E7.1.1 )
352, 353/97-07-05 NCV Purchase Order Revision Controls (E7.1.3)
352/97-07-07 NCV Fire Protection System Deluge Valve may not have Func.tioned
per Design. (F8.1)
352/1-97-006 LER Previous Condition Prohibited by Technical Specifications in
that a Fire Protection System Deluge Valve may not have
Functioned per Design Since issuance of the Unit 1 Operating
License. (F8.1)
353/2 97-007 LER Unit 2 HPCI System inoperable Due to Clogged Turbine
Exhaust Drain Line. (M8.1)
. 1
.
. . _. _
33
ITEMS OPENED, CLOSED, AND DISCUSSED (Continuod)
353/2 97-008 LER Automatic Closure of Drywell Chilled Water System Primary
Containment isolation Valves, an ESF Actuation, Resulting
from Emergency Diesel Generator Voltage Regulation Failure.
(08.2)
353/2 97 009 LER Unit 2 Reactor Water Clean-up Isolation, an ESF, Caused by a
RWCU Filter Demineralizer Y Strainer Manual Drain Valves
Leaking into the Backwash Receiving Tank. (08.3)
Discussed
None
LIST OF ACRONYMS USED
AFSS Automatic Fire Suppression System
AR Action Request
BOP Balance of Plant
CEI Centerior Energy
CFR Code of Federal Regulations
CREFAS Control Room Engineering Fresh Air System
EDG Emergency Diesel Generator
ELU Emergency Lighting Unit
ESF Engineered Safety Feature
EWR Engineering Work Request
FIT Focused improvement Team
FME Foreign Material Exclusion
FP Fire Protection
FSWS Fire Suppression Water System
GL Generic Letter
HEPA High Efficiency Particulate
HPCI High Pressure Coolant injection
IFl inspection Follow-up Item
IR inspection Report
IRM Industrial Risk Management
LCO Limiting Condition For Operation
LER Licensee Event Report
LGS Limerick Generating Station
NCV Non-Cited Violation
NDE Nondestructive Examination
NED Nuclear Engineering Department
NOA Nuclear Quality Assurance
NRB Nuclear Review Board
NRC Nuclear Regulatory Commission
NUPIC Nuclear Procurement issues Committee
ODCM Offsite Dose Calculation Manual
_. . . . _ - . _ . _ _ _ . . . _ ._ - _ _._ _. _ _ ..
_
_
-34 _
IPAB1 Proterted Area' Boundary
PBAPS4 Peach Bottom Atomic Power Station
PEP Performance Enhancement Process
-PO- Purchase Order.
' PORC - Plant Operations Review Committee
PSA Probabilistic Safety Assessment
' QA - Quality .^ ssurance
-QC- Quality Control
'
QV _
Quality Verification
RCIC '- Reactor Core Isolation Cooling-
RCO- _ Request for Change Order
4 -RMS Radiation Monitoring System
RP&C Radiological Protection and Chemistry
-
RP' Radiation Protection
RT Routine Test
RWCU. Reactor Water Clean-up
b SCBA - Self Contained Breathing Apparatus -
ST- Surveillance Test-
TRM Technical Requirements Manual
-TS -Technical Specification
.
.UFSAR Updated Final Safety Analysis Report
URI Unresolved item
VIO Violation
.
A
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_ _ _ _ _ __ _ . _ . . _ - _ .__ - . . . .- . _. ____ _ _____ _ . _ . _. _. _
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1;
"
LIST OF DOCUMENTS REVIEWED. ,
. Procedures
I - A-c-043,' Surveillance Testing Program, Rev. O
{- - A C-079, Procedure- Adherence and Use, Rev.
- ST-7-022 3531, Halon System Inventory, Rev. 4
1~
ST-7 022-3531, Unit 1 Main Bank Halon System Inventory, Rev. 5
ST-7 022-354-1, Unit.1 Reserve Bank Halon System inventory, Rev. 0
- iST-7 022-353 2, Halon System Inventory, Rev. 6
! lST-7-022-353-2,' Unit 2 Main Brnk Halon System Inventoryi Rev. 7
iST-7-022 354-2, Unit 2 Reserve Bank Halon System Inventory, Rev. O
i ST-7-022-730-1, FSWS Air / Water Nozzle Flow Test, Rev. 4
iST-7-022-9201, Unit 1 Refuel Fire Rated Assembly Inspection, Rev. 3 I
. . __
! '
- l ST-7-022 920-1, Attachment 1, Structural Fire Rated Assembly Tabulation, Rev. 'J (with
,
- temporary change 1-87-0903 1)
ST-7-022 9201- Unit 1 Refuel Fire Rated Assembly inspection, Rev. 2
,
ST-7-022-920 1,- Attachment 1,-Structural Fire Rated Assembly Tabulation, Rev. 2
- _ ST 7-022-920-2, Attachment 1, Structural Fire Rated Assembly Tabulation, Rev. 5 (with
temporary change 1 97 0904 2)
L ST-7 022 921-0, Fire Damper Inspection, Rev. 6 (with temporary changes 1-97-0901-0
and 2 97-0908-0)
,
- ST-7 022-921_-1, Fire Damper inspection, Rev. 5
i ST-7-022-921 -2, Fire Damper Inspectioni Rev. 2
i ST-7-022-921 -2, Attachment 1, Fire Damper Tabulation, Rev.1
ST-7-022-922 0, Fire Rated Penetration Test Sample Visual inspection, Rev. 6
l
ST-7-022-922-0, Attachment 1, Fire Rated Penetration Seal Tabulation, Rev. 4
5
'
RT-6-108-300-0, Safe Shutdown Eight (8) Hour Selt-Contained Battery Pack Operation
Verification, Rev. 6
'
RT-6-108-300-0, Safe Shutdown Eight (8) Hour Self-Cor tained Battery Pack Operation
. Verification, Rev. 4 -
RT-6-108-300-1, Safe Shutdown Eight (8) Hour Self Contained Battery Pack Operation
. Verification, Rev 5-
RT 6-108 300-1, Safe Shutdown Eight (8) Hour Self-Contained Battery Pack Operation
>
Verification, Rev. 4
i RT-6-108-300-2, Safe Shutdown Eight (8) Hour Self Contained Battery Pack Operation
4
- Verification, Rev. 4
RT-6-108-300-2,. Safe Shutdown Eight (8) Hour Self Contained Battery Pack Operation
Verification, Rev.~3
'
, RT-7 022 3201, BOP Fire Protection Sprinkler System Operability Verification, Rev.6
RT-7-022-320 1, BOP Fire Protection Sprinkler System Operability Verification,' Rev. 5
RT 7-022-321-1, Catage Wet Pipe Sprinkler System Operability Verification and Visual
Inspection, Rev. O
L RT-7-022-322 0, Remote Buildings (Outside PAB) Sprinkler System Operability Verification,
Rev.6
RT-7-022 322-0, Remote Buildings (Outside PAB) Sprinkler System Operability Verification,
Rev.5
+
4
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-,----,,.---c.-, e - - , - - w c ---
r
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RT 7 022 353 0, TSC Halon System Inventory, Rev. 5
RT 7 022 353 0, TSC Halon System Inventory, Rev. 4
S22.8.C, Hatchway Flow Control Valve Reset, Rev. 6
S22.8.E Pre Action or Deluge System Reset, Rev. 6
i Denotes procedures which were walked down, in part, in the facility
\
htd@e.rino Documents \
Specification A 39A, Fire Protection Specification for Structural Steel Fireproofing
(CAFCOTE 800), Limerick Generating Station Units 1 and 2, Rev.8
l Specification A 39A, CAFCOTE 560 Application and Installation Guide, Rev.1
i
Specification A 39, Specification for Structural Steel Fireproofing for the Limerick
Generating Station Units 1 and 2
Engineering Work Request L 00508, Fire Coating on Structural Steel Beams, Rev. 8
A 305, Sher? 1, Architectural; Alr/ Steam / Fire & Water Boundaries Floor Plan El 177' 0"
Unit i, Rev.12
A 305, Sheet 2, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El.177' 0"
Unit 2, Rev. O
A 305, Sheet 3, Architectural Security Boundaries Flocr Plan El.177' 0" Unit 1&2, Rev.
O
A 306, Sheet 1, Architectual Air / Steam / Fire & Water Boundaries Floor Plan El. 201' 0"
Unit 1, Rev.16
A 306, Sheet 2, Architectural Air / Steam / Fire & Water Boundaries Floor Plan El. 201' 0"
Unit 2, Rev. O
A 306, Sheet 3, Architec" .el Security Boundaries Floor Plan El 201' 0" Unit 1&2, Rev.
O
A 307, Sheet 1, Architectural; Air /Steem/ Fire & Water Laundaries Floor Plan El. 217' 0"
Unit 1, Rev.19
A 307, Sheet 2, Architectural: Air / Steam / Fire & Water Boundaries Floor Plan El. 217' 0"
Unit 2, Rev. 3
A 307, Sheet 3, Architectural Security Boundaries Floor Plan El/ 217' 0" Unit 1&2, Rev.
O
A 308, Sheet 1, Architectural; Air / Steam / Fire & Water Boundaries F!oor Plan El. 253' 0"
Unit 1, Rev.13
A 308, Sheet 2, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El. 253'-0"
Unit 2, Rev. O
A 308, Sheet 3, Architectural Security Boundarles El. 253' 0" Unit 1, Rev. O
A 309, Sheet 1, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El 283' 0" &
269' 0" Unit 1, Rev.16
A 309, Sheet 2, Architectural; Air / Steam / Fire & Water Boundarles Floor Plan El. 283' 0" &
269' 0" Unit 2, Rev. O
A 309, Sheet 3, Architectural - Security Boundaries Floor Plan El. 283' 0" & 209' 0" Unit
1 &2, Rev. O
A 310, Sheet 1, Architectural: Air / Steam / Fire & Wbter Boundaries Floor Plan El. 313'-0",
302' & 332' Unit 1, Rev.13.
A 310, Shset 2, Architectural: Air / Steam / Fire & Water Boundaries Floor Plan El. 313' 0",
302' & 352' Unit 2, Rev. O
y v .
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37
.
A 310, Sheet 3, Architectural Security Boundaries Floor Plan El. 313'0", 302' & 332'
)
Unit 1&2, Rev. O i
'
A 311, Sheet 1, Architectural; Air / Steam / Fire & Water Boundarles Floor Plan El. 352'-0"
] Unit 1, Rev. 6
A 311, Sheet 2, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El. 352' 0"
Unit 2, Rev. 0
l A 311, Sheet 3, Architectural Security Boundaries Floor Plan El. 352' 0" Unit 1&2, Rev.
1
0
4 A 185, Architectural Control Bldg. Fire Proofing Sec. & Det., Rev. 5
C 426, Control Room Area Floor Plan, El. 239' 0" Area 8, Rev. 24
! C 432, Control Room Area Floor Plan, El. 254' 0" Area 8, Rev. 22 '
3 C 440, Control Room Area 8, Sections and Dettils, R: v.12
l C 473, Sheet 1, Control Room Area 8 Structural Steel, Framing Plan El. 254' 0" & El.
j 269' 0", Rev.12
j C 473, Sheet 2, Control Room Area 8 Structural Steel, Traffic Control Barriers El. 269' 0", ;
l Rev.0 *
1
. C 478, Control Room Area 8 Structural Steel, Framing Plan El. 289' 0" & El 304' 0", Rev.
i
12
l C 191, Reactor Building Units 1&2, Structural Steel Column Schedule, Rev. 24 '
i C 460, Control Room Area 8 Structural Steel, Framing Plan El. 239' 0", Rev.16
j M 1151, Heating and Ventilating Reactor Bldg. Unit No. 2 Plan at El. 217' 0" Area 13,
i Rev.16
{ M 1152, Heating and Ventilating Reactor Bldg. Unit No. 2 Plan at El. 253' 0" Area 13,
- Re'.'. 19
4
j Other Dpeuments *
UFSAR, Appendix 9A
Limerick Unit 1 Technical Requirements Manual
'
Limerick Unit 2 Technical Requirements Manual
PEP lssue 5811, insulation Missing From Structural Steel
- PEP lssue 6033, Fire Protection Procedure improvements
'
Action Request A1050861, PEP 10006033 LGS Fire Protection Procedure
l
Quality Concern 127, irregularities in Performance of Fire Protection Surveillance Tests
,
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