ML20199C664
| ML20199C664 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/06/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20199C656 | List: |
| References | |
| 50-352-98-09, 50-352-98-9, 50-353-98-09, 50-353-98-9, NUDOCS 9901190049 | |
| Download: ML20199C664 (18) | |
See also: IR 05000352/1998009
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
. Docket Nos. 50-352
50-353
License Nos. NPF-39
NPF-85 '
Report Nos. 98-09
98-09
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Licensee: PECO Energy
Correspondence Control Desk
P.O. Box 195
- Wayne, PA 19087-0195
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Facilities: Limerick Generating Station, Units 1 and 2 l
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l Location: Wayne, PA 19087-0195
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Dates: October 18,1998 through November 30,1998
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l Inspectors: A. L'. Burritt, Senior Resident inspector
F. P. Bonnett, Resident inspector
J. D. Noggle, Senior Radiation Specialist
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Approved by: Clifford J. Anderson, Chief
Projects Branch 4
Division of Reactor Projects
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9901190049 990106
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PDR ADOCK 05000352
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l EXECUTIVE SUMMARY '
Limerick Generating Station, Units 1 & 2 l
NRC inspection Report 50-352/98-09,50-353/98-09
This integrated inspection included aspects of PECO Energy operations, engineering, 1
maintenance, and plant support. The report covers a 6-week period of resident inspection
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and region-based specialinspection of a planned spent fuel shipment from Limerick Station.
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Operations
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e Conduct of operations at Limerick Units 1 and 2 was professional and focused on
safety principles. Operators demonstrated safe and conservative decision making l
during the two forced load reductions at Unit 1 due to high vibrations on the 18 l
condensate pump. (Section 01.1) )
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e A reactor operator mispositioned a control rod during the performance of the control
rod exercise test due to distractions within the control room. PECO's corrective
actions focused on correcting operator behaviors but did not initially address
eliminating other causal factors that distracted the operator. Further, weaknesses
were identified related to the documentation of control rod movement abnormalities
and resolution of these abnormalities which are potential operator distractions.
(Section O2.2)
e Plant management was not appropriately informed by piant staff of a procedural
adherence deficiency relevant to the mis-located alignment pin for the shipping cask
inner closure lid during a presentation at the Senior Leadership Meeting. However,
following NRC intervention, plant management responded well by stopping further
cask loading operations. (Section 07.1) l
Maintenance
e Overall, PECO and supporting contractors did not effectively plan, prepare for, or
implement the irradiated fuel shipment. Technicians were challengerl by a
procedure that was technically flawed, in part as a result of an inadequate review
by the cask vendor. PECO did not provide adequate levels of quality verification
and oversight commensurate with the potential safety significance associated with i
this infrequently performed activity. In two instances procedures were not followed !
precisely and in'one of these cases technicians exercised poor judgement and
deviated from a procedure in an attempt to resolve a problem without involving
management or implementing the appropriate change process. This represented a
violation of Technical Specification 6.8.1.a. In addition, technicians attempted to
resolve emergent problems without informing the control room. (Section M1.2)
- LER 2-98-005 described a condition prohibited by Technical Specifications in which
an average power range monitor (APRM) surveillance test had been missed. The
l cause of the missed test was the removal of the surveillance activity from the
schedule based on a personnel error involving a faulty assumptions. This licensee
identified issue is being treated as a Non-Cited Violation. (Section M8.1)
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Executive Summary (cont'd)
e LER 2-98 007 described a condition prohibited by Technical Specifications in which
l the surveillance test for the residual heat removal (RHR) heat exchanger discharge
! line high radiation indication light located on the Unit 2 remote shutdown panel
(RSP) had been missed. The cause of the missed surveillance was the cancellation
of the surveillance test, which tested the light, due to an inadequate review of a
plant modification. This licensee identified issue is being treated as a Non-Cited
Violation. (Section M8.2)
Plant Sucoort
e During receipt inspection of an empty spent fuel cask, the licensee properly
identified that external radiation levels were above regulatory limits and notified the
- shipper in accordance with regulatory requirements. (Section R1.1)
e Radiological controls during the spent fuel cask loading activities were generally
good. However, health physics technicians failed to recognize and correct poor
work practices performed by nuclear maintenance division workers until they were
prompted by the inspector on several occasions. Although the licensee addressed
these practices with the individuals, they did not capture the radiation worker
l performance and HP oversight deficiencies in their self assessment or in their
corrective action system. (Section R1.2)
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TABLE OF CONTENTS
EX E C UTIVE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
TA B LE O F C O NTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
Summary of Plant Status ............................................1
1. O p e r a ti o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01.1 G ene ral Comrn ents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
02 Operational Status of Facilities and Equipment ................... 2
O2.1 Engineered Safety Feature (ESF) System Walkdowns . . . . . . . . . . 2
02.2 Mispositioned Control Rod During Exercise Test ............. 2
07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
07.1 Licensee Self-Assessment Activities .....................3
il . M aint e n a nc e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
M 1.1 General Comments on Surveillance Activities . . . . . . . . . . . . . . . 4
M1.2 Spent Fuel Shipment Preparations . . . . . . . . . . . . . . . . . . . . . . . 4
M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
M8.1 (Closed) LER 2 - 9 8 -0 0 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
M8.2 (Closed) LER 2 - 9 8 -0 0 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Ill . Engin e erin g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ 9
E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
E8.1 (Closed) VIO 50-3 5 2, 3 5 3/9 8-04-03 . . . . . . . . . . . . . . . . . . . . . 9
E8.2 (Closed) EA 9 8 - 141 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0
IV. Pla nt Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ 10
R1 Radiological Protection and Chemistry (RP&C) Controls ............ 10
R1.1 Spent Fuel Cask Receipt inspection . . . . . . . . . . . . . . . . . . . . . 10
R1.2 Radiological Controls During Shipping Cask Loading . . . . . . . . . . 11
V. M a nagem ent Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
.X1 Exit Meeting Summary . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . 12
INSPECTION PRO CEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
LIST O F AC RO NYMS U S E D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
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Report Details
Summary of Plant Status
Unit 1 began this inspection period operating at 100% power with an asymmetrical rod
pattern to suppress a leaking fuel pin in fuel assembly 41-40. The unit remained at full
power throughout the inspection period with minor exceptions for testing and the following
plant events.
- November 7 Unit operators' reduced power to 69% to facilitate the removal
of the 1B condensate pump from service due to an increased
frequency of vibration alert alarms. A maintenance team
replaced the lower pump motor bearing which rectified the
problem Operators' commenced increasing reactor power,
observing power ramping limitations, on November 8 and
achieved 100% power on November 10.
- November 13 Unit operators' reduced power to 75% to facilitate the removal
of the 1B condensate pump from service due to reading 12.5
mils vibration on the vibration monitoring system.
Maintenance found and corrected an insufficient oil supply in
the bearing. Operators' returned the unit to 100% on
November 16.
Unit 2 began this inspection period operating at 100% power. The unit remained at full
power throughout the inspection period with minor exceptions for testing and rod pattern
adjustments.
l. Ooerations
01 Conduct of Operations'
01.1 General Comments (71707)
In general, PECO Energy's (PECO) conduct of operations at Limerick Units 1 and 2
was professional and focused on safety principles. Operators demonstrated safe
and conservative decision making during the two forced load reductions at Unit 1
due to high vibrations on the 18 condensate pump.
1 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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02 Operational Status of Facilities and Equipment
O2.1 Enaineered Safetv Feature (ESF) System Walkdowns (71707)
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l The inspectors used inspection Procedure 71707 to walk down accessible portions
of the following ESF systems:
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- Standby Liquid Control System (Unit 1)
- Residual Heat Removal Service Water System (Common)
- Emergency Service Water System (Common)
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Equipment operability, material condition, and housekeeping were acceptable in all
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cases. The inspectors identified no substantive concerns as a result of these
l walkdowns. .
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! O2.2 Miscositioned Control Rod Durina Exercise Test
a. Insoection Scope (71707)
On November 8, the Unit 2 reactor operator (RO) inadvertently mis-positioned
! control rod 46-07 while performing surveillance test ST-6-107-760-2," Control Rod
! Exercise." The inspector performed an independent review of the event and
i reviewed the performance enhancement program (PEP) evaluation,
b. Observations and Findinas
The RO was experiencing difficulty moving several control rods from position 48 to
i position 46 during the performance of the surveillance test (ST). The RO notified
l the control room supervisor (CRS) for each control rod for which he experienced the
problem in particular, control rod 46-07 required several attempts to move the
control rod to position 46. The RO then became distracted by an incoming
telephone call. Subsequently, believing that he had complete the test of control rod
46-07, the RO selected the next control rod to be tested. After completing the
exercise test for the second control rod, the RO noted that control rod 46-07 still
remained at position 46 and returned it to position 48. Realizing that two control
I rods had been at position 46, the RO informed the CRS who then entered off-
normal procedure ON-123, "Mispositioned Control Rod," and verified that all control
rods were at the proper positions.
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Several factors hindered the performance of the ST. The RO was experiencing
I difficulty with control rods failing to move and remain in the correct position on the
first attempt when inserted one notch. This was due to misadjusted flow settings
at the hydraulic control unit. Periodic rod block monitor (RBM) alarms distracted the
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RO requiring the CRS to direct bypassing the RBM. Further, the RO allowed himself
- to become distracted by another task (answering a telephone call) prior to
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completing the first Lastly, the RO did not review the data sheet to verify where
s he was in the procedure prior to continuing in the surveillance test.
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Although adequate corrective actions weie eventually implemented, following
discussions with the inspector, the initial resolution of this issue focused on the
operator behaviors only and did not address the impact of the equipment problems
and other distractions on operator performance for this ST or other control room
tasks. The inspector also noted that the procedure required the operator to
document any observed abnormality in the comments section of the procedure.
This was not performed for any of the control rods that failed to move and remain in
the correct position on the first attempt. An action request to investigate the cause
of the CRD moving problem was initiated on November 8; however, as of the date
of the exit meeting, the CRD problem had not been resolved apparently as a result
of an administrative error with the action request. The failure to document the
abnormalities is a minor violation not subject to formal enforcement.
c. Conclusions
A reactor operator mispositioned a control rod during the performance of the control
rod exercise test due to distractions within the control room. PECO's corrective
actions focused on correcting operator behaviors but did not initially address
eliminating other causal f actors that distracted the operator. Further, weaknesses
were identified related to documentation of control rod movement abnormalities and
resolution of these abnormalities which are potential operator distractions.
07 Quality Assurance in Operations
07.1 Licensee Self-Assessment Activities (71707)
a. Inspection Scope
The inspectors routinely attended the Senior Leadership Meeting. l
b. Observations and Findinas
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! The inspector determined that the Senior Leadership Meetings were an effective
means for plant management to communicate their expectations to the plant staff.
l Plant management discussed plant status, reviewed recent plant events, and
l tracked the status of plant processes. Representatives from various organizations
frequently made presentations to explain the details of recent events to
management.
On November 6, the inspector observed a presentation to management related to i
difficulties encountered on November 5, during the loading of a fuel bundle into a l
shipping cask (Section M1.2). Specifically, technicians discovered that the
alignment pin for the inner cask closure lid was mis-located. The presenter
characterized the event as an ' attention to detail' issue in spite of several probing
questions by the plant manager. The inspector, aware that the issue resulted from
a failure to adhere to the procedure, challenged the presenter after the meeting.
The presenter disclosed to the inspector that the misplaced guide pin was the result
of a procedure adherence problem. The inspector then informed the plant manager
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that his staff did not fully disclose information relevant to the mis-located pins
during the presentation at the Senior Leadershio Meeting. The Plant Manager
directed that no further work be performed urxil the issue was resolved.
c. Conclusions
Plant management was not appropriately informed by plant staff of a procedural
adherence deficiency relevant to the mis-located alignment pin for the shipping cask
inner closure lid during a presentation at the Senior Leadership Meeting. However,
following NRC intervention, plant management responded well by stopping further
cask loading operations.
11. Maintenance
M1 Conduct of Maintenance
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M 1.1 General Comments on Surveillance Activities (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:
e ST-2-052-801-2, Loop A Core Spray System Response Time Testing - Unit 2
(Nov.14) l
- ST-6-048-230-1,SLC Pump Valve and Flow - Unit 1 (Nov. 24)
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,
M1.2 Soent Fuel Shioment Preoarations
a. insoection Scooe (627001
l The inspectors reviewed a planned spent fuel shipment from Limerick Station to
verify conformance with the requirements of the NRC Certificate of Compliance for
l the shipping container, the associated safety analysis report, and PECO's
l procedures for radiological controls, and fuel cask loading and shipping activities.
i Fuel cask loading activities were observed during the period between November 2
and 12,1998.
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b. Observations and Findinas
On November 5, PECO initiated activities to load one spent fuel assembly (with the
fuel channel removed) into a fuel shipment cask for transport to General Electric
Nuclear Energy (GE) for the purpose of research and examination at Vallecitos,
California. This was PECO's first attempt to prepare, process, and ship spent fuel
from the Limerick Generation Station.
PECO established a special team to conduct this activity. The team consisted of GE
representatives, who were responsible for shipping the material and facilitating the
required security for the transportation of the special nuclear material: Nuclear
Assurance Corporation International (NAC), the shipping cask supplier; and
members of PECO's nuclear maintenance department, who were responsible for the
conduct of on-site licensed activities associated with loading the assembly into the
shipping cask and preparing it for transport.
In accordance with the established procedures, all fuelloading activities were
conducted underwater in the spent fuel and cask loading pools. The personnel
assigned to conduct the activity were verified to be trained and qualified. As part of
the process, all affected personnel were briefed on the conduct of the task.
Appropriate radiological controls were established, including personnel monitoring,
radiological surveys, and contamination controls. PECO's Plant Operating Review
Committee approved the procedures for use, and the applicable procedures were
available in the work area. Supervisory personnel were assigned to effect
management oversight and control.
Summary of Activities
PECO installed the bundle into the cask on November 5,1998. When attempting to
install the cask inner lid, an alignment pin inserted in the wrong position, prevented
the lid from being installed. On November 6,1998, PECO transferred the bundle
back into spent fuel pool to facilitate moving the alignment pin to the correct
position and identified that the fuel bundle spring fingers had been damaged, which
would prevent subsequent insertion of the bundle into the cask. On November 11,
1998 the spring fingers were removed. On November 12,1998 the bundle was
again placed into the cask and a procedure discrepancy was noted regarding the
seating of the bundle in the cask. On November 13,1998 PECO terminated further
efforts to ship the bundle.
( Seatina of Bundle in Cask
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I During the first attempt to load the fuel assembly into the cask, the bail handle
appeared to be approximately 0.5 inches below the inner closure lid flange (based
on observations from an underwater camera), and not 3.0 inches below the inner
closure lid flange surface as described in Prccedure M-053-006, Rev.1, "NLl-1/2
- Spent Fuel Shipping Cask Preparation and Loading". While the PECO staff opined
that parallax distortion may be affecting the observation and that 2 inches below
the cask flange would be acceptable, PECO took no action to make an actual
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measurement to verify that the assembly was fully seated or verify the adequacy of
the procedural description.
On the second attempt to install the spent fuel assembly into the shipping cask, the
licensee measured the actual position of the fuel assembly in the cask and noted
that the fuel assembly bail handle extended approximately 0.5 inches above the
inner closure lid flange, which was contrary to the expectation expressed in the
procedure that the bail handle would be 3.0 inches below the inner lid closure
flange when the fuel assembly was properly seated in the cask. PECO stopped
activities in order to determine if the cask and closure lid were properly configured
to accommodate the fuel assembly.
Subsequent PECO and contractor review revealed that the cask was properly
configured and was designcd to accommodate the funi assembly. However, PECO
had to perform actual measurements of the inner c. ure lid to verify that it was the
correct component. The licensee determined that the inner closure lid was recessed
to fit the extended bail handle and that the procedure incorrectly described the
expected position of the bail handle. PECO also determined that the loading
procedure had not been adequately reviewed by the cask vendor. PECO terminated
further efforts to effect shipment of the selected fuel assembly due to constraints
on resources and time.
Inner Closure Lid Mis-alianment
Following the initial attempt to load the cask, PECO attempted to install the inner
cask closure lid onto the cask. However, PECO encountered difficulty in properly
aligning the closure lid to the cask. Subsequent licensee review of the fuelloading
procedure determined that cask disassembly specifications of the procedure were
not followed precisely. Procedure M-053-006 (a Category Level 1, continuous use
procedure), specified that the cask lid alignment guide pins were to be installed prior
to removing the bolted inner cask closure lid. However, the PECO work crew
experienced difficulty in accessing the guide pins and, upon consultation with the
cask vendor and GE representatives that were present, elected to remove the lid
before installing the guido pins. The PECO work crew deviated from a procedure in
an attempt to resolve a problem without involving management or implementing the
appropriate change process. Subsequently, one of the guide pins was installed in
the wrong alignment socket, resulting in the licensee's inability to properly align the
inner lid for closure,
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The inspector independently determined that procedure M-053-006 had not been
l adequately reviewed by the licensee and contractors, and that technicians failed to
l adhere to the sequence of procedure, with respect to installation of the inner cask
closure lid alignment guide pins. Technical Specification (TS) 6.8.1 and applicable
references requires that maintenance be properly pre-planned and performed in
accordance with written procedures. Licensee procedure A-C-079, " Procedure
Adherence and Use," requires that the user perform each step in the sequence
specified in a Category Level 1 procedure. Procedure, M-053-006,"NLl-1/2 Spent
Fuel Shipping Cask Preparation and Loading," a Category Level 1 procedure, steps
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5.7.17 through 5.7.28, specifies the sequence for installation of the inner cask lid
alignment pins. The inspector considered the failure to install the inner cask tid
alignment pins in the sequence specified in procedure steps 5.7.17 through 5.7.28
to be a violation. (VIO 50-352,353/98-09-01)
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Bent Sorina Finoers
During the first attempt to load the fuel assembly into the cask, refueling bridge
alignment difficulties were encountered in loading the fuel assembly into the cask.
A GE representative opined that the difficulty was due to the extremely close
l tolerance between the fuel assembly and the internal cask fuel basket since the fuel
l assembly was not enclosed in a fuel channel, which allowed the spring fingers to be
l extended.
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Upon removal of the fuel assembly from the cask, PECO observed that four spring
l fingers located at the bottom of the fuel assembly had been bent during the loading
process. The procedure cautioned that extreme care be taken to eliminate damage
! to the fuel bundle spacers but did not address the spring fingers. PECO determined
l that the bent spring fingers would likely provide interference upon reloading of the
fuel assembly into the cask. Subsequently, the licensee resolved the condition by
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removing the damaged spring fingers from the fuel assembly. Special tooling and
l processes were acquired and used to accomplish this unanticipated operation.
Communication
Though ultimately responsible for the conduct of alllicensed activities on site, shift
management and operations personnel were unaware of the emerging inner cask
closure lid alignment problems until informed by the inspector. The refueling floor
supervision and vendor representatives attempted to determine a resolution to the
inner cask closure lid alignment problem given a fuelloaded and cask submerged
configuration without involving the operations shift supervision in the control room.
Upon understanding the nature of the problems, operations shift supervision
required refueling floor activities to be suspended pending the development of an
! approved plan for resolving the inner cask closure lid alignment problem.
Subsequent'y, a recovery plan (involving removal of the fuel assembly from the cask
in order to re-install the alignment guides in the proper position) was approved and
initiated to resolve the problem.
Quality Verification
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The inspector determined that quality verification was not adequate to assure key
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steps were performed correctly for the infrequently performed fuel shipment tasks.
Although some redundant verifications were performed using double verification
(DV) steps, a number of the key steps only specified worker verifications (WV).
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WVs involve only one level of verification, one person instead of two confirming the
step was completed correctly. For example, the procedure step to confirm the fuel
bundle was correctly seated only specified a WV which ultimately was not adequate
- to identify that the fuel bundle was not seated consictently with the procedural
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requirements. The inspector also noted that no Quality Assurance personnel
observed the key refuel floor activities.
Cessation of Fuel Shioment
Several emergent problems and an inadequate procedure led to personnel
uncertainty, confusion and procedural adherence errors during the loading of a dry
cask shipping container. Based on the sum of these unexpected events, PECO
ceased further cask loading activities, unloaded the cask, and shipped the empty
cask off-site. PECO stated that increased planning, enhanced procedure review,
and coordination with the contractors would be worked out prior to any future
attempts to ship the irradiated fuel bundle. The inspector reviewed and determined
that the licensee's corrective actions were adequate.
c. Conclusions
Overall, PECO and supporting contractors did not effectively plan, prepare for, or
implement the irradiated fuel shipment. Technicians were challenged by a
procedure that was technically flawed,in part as a result of an inadequate review
by the cask vendor. PECO did not provide adequate levels of quality verification
and oversight commensurate with the potential safety significance associated with
this infrequently performed activity. In two instances procedures were not followed
precisely and in one of these cases technicians exercised poor judgement and
deviated from a procedure in an attempt to resolve a problem without involving
management or implementing the appropriate change process. This represented a
violation of Technical Specification 6.8.1a. In addition, technicians attempted to
resolve emergent problems without informing the control room.
M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) LER 2-98-005. Averaae Power Ranae Monitor (APRM) Gain Measurement
and Adiustment Missed Surveillance
This LER documents the discovery that the APRM gain determination and
adjustment was not performed within the Technical Specification required weekly
periodicity. On June 29,1998, the surveillance test coordinator discovered that the
APRM surveillance had not been performed and promptly notified the control room.
The surveillance test (ST) was subsequently performed within in a day of the
required interval and no adjustments were required. The licensee determined that
the missed ST was a result of the scheduled activity to perform this test being
incorrectly updated as complete. Apparently this action was taken based on the
faulty assumption that the same ST performed during a recent startup would meet
the weekly requirement. However, since the testing performed during the startup
was prior to the normally scheduled day for the ST, the interval lapsed prior to
completion of the next scheduled test. Although the licensee found the primary
cause to be personnel error, the investigation was unable to determine who or what
group was responsible. The licensee also determined that weaknesses existed in
the use of software program for scheduling weekly STs.
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The inspector performed an in-field review including interviews to confirm the cause
of the event and to verify implementation of the corrective actions. The licensee's
corrective actions included issuing a read and sign bulletin, adding a requirement to
obtain ST coordinator approval prior to rescheduling weekly STs, and the
incorporation of an "out of sequence report" to identify and track STs out of there
normal scheduled frequency. The licensee also plans to enhance the weekly ST
software program. The inspector determined that the corrective actions
implemented to prevent recurrence were adequate the cause for this missed
surveillance was different than other recently missed STs. Therefore this event
could not have reasonably been prevented by previous corrective actions. This
licensee-identified, non-repetitive and corrected violation is being treated as a No
Cited Violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
(NCV 50-352,353/98-09-02)
M8.2 (Closed) LER 2-98-007, Remote Shutdown Panel Hiah Radiation Liaht Missed
Surveillance
This LER documents the discovery of a missed surveillance test for the RHR heat
exchanger discharge line high radiation indication light located on the Unit 2 remote
shutdown panel (RSP). On August 4,1998, station personnel performing a routine
review of surveillance test revisions determined that surveillance requirement SR 4.3.7.4.2 had not been performed for this indicating light since December 10,
1997. The missed surveillance occurred due to an inadequate engineering review of
a plant modification that removed the unit specific RHR service water radiation
monitor from each unit, and subsequent cancellation of the 24-month Channel
Calibration Surveillance Test, in which the light was tested.
The inspector performed an in-field review of ST-2-012-404-0, Radiation Monitoring
- RHR Service Water Radiation Monitor: Division I, Channel A Calibration / Functional l
Test. PECO revised the test procedure so that the light was adequately tested at I
the RSP. The light in question was for indication only and did not have any required !
safety function associated with it. The inspector determined that the corrective i
actions implemented to prevent recurrence of this event were adequate. This
licensee-identified, non-repetitive and corrected violation is being treated as a Non-
Cited Violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
(NCV 50-352,353/98-09-03)
lli. Enaineerina
E8 Miscellaneous Engineering issues (92902)
l E8.1 (Closed) VIO 50-352,353/98-04-03: Weak and Untimely Corrective Actions for
'
Inadeauate Primary Containment isolation Valve Testina
in December 1997, the licensee identified that 89 automatic closing and 26 remote
manually operated primary containment isolation valves (PCIVs) had not been
adequately tested. The inspector determined that PECO's corrective actions
10
implemented for these testing deficiencies were weak. Further, interim corrective
actions to address discrepancies that led to the missed testing had not been
implemented and the long term corrective action plan and implementation time-table
were not established in a timely manner.
The root cause of the surveillance testing error was due to personnel error during
initial surveillance test development caused by an error in the original design
documents. A review of data provided on the logic diagrams failed to determine the
appropriate logic path required to be tested for closing the PCIVs. Long term
corrective actions to prevent recurrence included revising the logic drawings by
December 1999. In the interim but subsequent to the initial inspection, an 1
engineering design change request was posted against each of the applicable f
drawings to alert potential users of the drawing inaccuracy. Further, engineering
performed a detailed review of the control room emergency fresh air supply system ]
'
drawings to ensure the logic system testing satisfied applicable requirements. No
deficiencies were identified. Applicable surveillance tests are being revised to
include the proper closing logic contacts. The revision will be completed prior to
the next scheduled performance. This item is closed. I
i
E8.2 (Closed) EA 98-141: Ineffective Corrective Actions for the Hiah Pressure Coolant I
iniection and Residual Heat Removal Systems
The inspector identified three violations that involved failures to identify and correct
conditions adverse to quality, including instances where inoperability of safety-
related equipment was not recognized. These failures involve internal binding of the
high pressure coolant injection exhaust valve, the residual heat removal minimum
flow valve being found closed on four occasions, and the reversed installation of a
D22 emergency diesel generator bearing. The inspector deteunined that the l
licensee's response to these issues was adequate. The ir spector noted that the l
operability determination process and review by plant stah has improved. This itern l
is closed.
IV. Plant Support
R1 Radiological Protection and Chemistry (RP&C) Controls
R 1.1 Soent Fuel Cask Receiot inspection
a. Insoection Scope (86740)
On November 4,1998, Limerick Generating Station accepted receipt of an empty
spent fuel shipping cask. Receipt inspection of the fuel cask was verified with
respect to 10 CFR 70 and 49 CFR Parts 171-177. Radiation surveys were
conducted in accordance with procedure, HP-C-715, Rev. 4, " Surveys in Support of
Exclusive-Use Radioactive Shipments and Receipt / Shipment of Non-Exempt
Radioactive Packages." The inspector reviewed the radiation survey and discussed
the results with radwaste shipment personnel.
11
b. Observations and Findings
According to licensee records, during receipt inspection of the empty cask contact
radiation readings of 1 mrem /hr gamma and 12 mrem /hr beta radiation were
detected by the licensee. The cask was shipped from Memphis, Tennessee, as an
excepted package, limited quantity - empty shipment. Department of
Transportation (DOT) radiation limits for this type of shipment specify that the
radiation exposure rate may not exceed 0.5 mrem /hr. Accordingly, this shipment,
as received, was not in conformance with the requirements specified in 49 CFR
173.421(a)(2). The shipper, Hake Inc., a licensee of the Agreement State of
Tennessee, was informed of the apparent violation by the licensee, as required.
NRC Region I staff similarly informed the appropriate Agreement State personnel.
Otherwise, cask components and configuration were verified to be in accordance
with the Certificate of Compliance for NAC cask Model No. NLl-1/2. The cask was
then opened and prepared for loading in accordance with the applicable procedure.
c. Conclusions
During receipt inspection of an empty spent fuel cask, the licensee properly
identified that external radiation levels were above regulatory limits and took ,
appropriate actions to notify the shipper, in accordance with regulatory
requirements.
R1.2 Radioloaical Controls Durina Shionina Cask Loadina
a. Inspection Scoce (86740)
The inspector observed radiological controls during the activities involving loading a
shipping cask with a spent fuel bundle.
b. Observations and Findinas
1
1
Overall, health physics (HP) technicians effectively maintained radiological controls l
of activities associated with the loading of a shipping cask with spent fuel.
However, some poor work practices by NMD technicians were observed by the
inspector. During the cask pit and spent fuel pool gate handling activities, poor
contamination control behaviors were observed on two separate occasions with no
coaching or interface by HP technicians with the workers. These behaviors
included improper protective clothing and handling of the gate without first being
surveyed. Another poor performance included an inadequate survey for alpha
contamination on the under-surface of the inner cask lid prior to workers handling it.
The inspector pointed out these practices to the HP supervisor. Subsequent dose
rate surveys of these and other components removed from the cask or fuel pools
were performed and demonstrated to be at a proper dose sensitivity by the HP
technicians.
- .
_ _ _ _ . _ _ _ _ _ _ _ . - . _ _ -- . _ . . _ _ . _ . . _ __ . _ _ _ - _ _ _ _ __- - . . - _
,
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i During the self-assessment critique, the inspector observed that radiation worker
l
practices were characterized as "overall... good." These above stated poor work
practices were not mentioned. Although HP supervision counseled the individuals
and believed they had resolved the issue, the poor practices and lack of HP
oversight were not captured in the self assessment critique for future work
performance improvements nor in a corrective action process for trending purposes.
c. Conclusions ;
Radiological controls during the spent fuel cask loading activities were generally
good. However, health physics technicians failed to recognize and correct poor :
work practices performed by nuclear maintenance division workers until they were '
prompted by the inspector on several occasions. Although the licensee addressed l
these practices with the individuals, they did not capture the radiation worker
performance and HP oversight deficiencies in their self assessment or in their ,
corrective action system.
V. Mansaement Meetinas ;
X1 Exit Meeting Summary
The inspector presented the inspection results to members of plant management at
the conclusion of the inspection on December 4,1998. The plant manager ;
acknowledged the inspectors' findings. The inspectors asked whether any materials I
examined during the inspection should be considered proprietary. No proprietary l
information was identified.
I
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.
13
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observation
IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 86740: Inspection of Transportation Activities
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 DISCUSSED
Opened
VIO 50-352,353/98-09-01: Procedure Adherence Error During Dry Cask Shipping
Activities. (Section M1.2)
Opened / Closed
NCV 50-352,353/98-09-02: Average Power Range Monitor (APRM) Gain
Measurement and Adjustment Missed Surveillance
(Section M8.1)
NCV 50-352,353/98-09-03: Remote Shutdown Panel High Radiation Light Missed
Surveillance (Section M8.2)
Closed
LER 50-353/2-98-005: Average Power Range Monitor (APRM) Gain
Measurement and Adjustment Missed Surveillance
(Section M8.1)(NCV 98-09-02)
LER 50-353/2 98-007: Remote Shutdown Panel High Radiation Light Missed
Surveillance (Section M8.2)(NCV 98-09-03)
VIO 50-352,353/98-04-03: Weak and Untimely Corrective Actions for inadequate
Primary Containment isolation Valve Testing (Section
E8.1)
EA 98-141: Ineffective Corrective Actions for the High Pressure
Coolant injection and Residual Heat Removal Systems
(Section E8.2)
Discussed
None
_ _ _ _ _ _ _ _ _
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. ,
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14 l
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LIST OF ACRONYMS USED
CFR Code of Federal Regulations
DOT U.S. Department of Transportation
ESF Engineered Safety Feature
.GE General Electric Nuclear Energy Company l
GL Generic Letter
IR inspection Report
LER Licensee Event Report
LGS Limerick Generating Station
LICENSEE Philadelphia Electric Company Energy Company
NAC Nuclear Assurane Corporation, international, incorporated
NCV Non-Cited Violation
NMD Nuclear Maintenance Division
NRC Nuclear Regulatory Commission i
'
PEP Performance Enhancement Process
RBM Rod Block Monitor
RP&C Radiological Protection and Chemistry
RSP Remote Shutdown Panel
ST Surveillance Test
TS Technical Specification
VIO Violation
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