ML20206B633

Forwards NRR SALP Rept for Feb 1986 - Jan 1987.Overall Performance Rating in Functional Area of Licensing Activities Decreased from Category 1 to Category 2.Decline Based on Untimeliness of Util Requests for NRC Actions

ML20206B633
Person / Time
Site:	Limerick
Issue date:	04/02/1987
From:	Martin R Office of Nuclear Reactor Regulation
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8704090261
Download: ML20206B633 (13)

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' April'2, 1987

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. MEMORANDUM FOR:-.- William F. Kane, Director "

Division of Reactor Projects,' Region I ,

THROUGH: Robert M. Bernero, Director- _

l Division of BWR Licensing,'NRR; ' ~ , .

Walter R. Butler, Director ' . ' -

'BWR Project. Directorate No. 4 NRR.

FROM: Robert E. Martin, Project Manager BWR Project Directorate No.'4, NRR -

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SUBJECT:

'SALP REPORT FOR LIMERICK GENERATING STATION-4 M. . .

t Enclosed is the NRR SALP report for Unit 1 of the Philadelphia. Electric. Company's :

Limerick.. Generating Station for the period February 1,,1986 to' January 31, 1987.

Consistent with the resumption of construction' activities on Unit 2 during this period,' a separate SALP report will be prepared for Unit' 2. The report is based., .

on SALP inputs provided by technical review personnel and the assessments made. ,

, , ' by the' Project Manager. The overall performance rating. in the functional' area

. of Licensing ~ Activities is Category 2. iThis-is a decline from the, rating of Category 1 for the past several SALP rating periods. The decline-is based -

! principally on the. untimeliness of the licensee's requests for NRC staff actions,;

j such as license amendment applications,* relative to the time by which the amend-1 ments are needed, inadequacies in the. licensee's initially submitted no signifi- .

I cant hazards consideration (NSHC) determinations and one notable instance of-

) failure to coordinate plant activities with submittals previously~made to NRC.'

The NSHC assessments appear to be improving near the end of the rating period,-

I the timeliness of submittals concern shows no improvement and the coordination

! of plant status with submittals issue has not recurred.

ensemas menea W Robert E. Martin, Project Manager BWR Project Directorate No. 4. NRR

Enclosure:

NRR SALP report i cc: H. Denton .

J. Sniezek G. Holohan l-D. Vassallo R. Gallo l G. Kelly i i NRC PDR 8704090261 870402 2 i Local PDR ADOCK 0500 PDf4 Reading {DR l

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% y ,,,+ April 2, 1987 MEMORANDUM FOR: William-F. Kane, Director Division of Reactor Projects, Region I THF.00GH: Robert M. Bernero, Director Division of BWR Licensing, NRR Walter R. Butler, Director -

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BWR Project Directorate No. 4, NRRI FROM: Robert E. Martin, Project Manager BWR Project Directorate No. 4. NRR

SUBJECT:

SALP REPORT FOR LIMERICK GENERATING STATION.

Enclosed is the NRR SALP report for Unit 1 of the Philadelphia Electric Company's Limerick Generating Station for the period February 1,1986 to January 31, 1987.

4 Consistent with the resumption of construction activities on Unit 2 during this period, a separate SALP report will be prepared for Unit 2. The report is based on SALP inputs provided by technical review personnel and the ar.sessments made by the Project Manager. The overall' performance rating in the functional area of Licensing Activities is Category 2. This is a decline from the' rating of Category 1 for the past several SALP rating periods. The decline is based principally on the untimeliness of the licensee's requests for NRC staff actions, such as license amendment applications, relative to the time by which the amend-ments are needed,- inadequacies in the licensee's initially submitted no signifi-cant hazards consideration (NSHC) determinations and one notable instance of failure to coordinate plant activities with submittals previously made to NRC.

The NSHC assessments appear to be improving near the end of the rating period, the timeliness of submittals concern shows no improvement and the coordination of plant status with submittals issue has not recurred.

l RobertE[. d. Martin,ProjectManager BWR Project Directorate No. 4, NRR-

Enclosure:

NRR SALP report cc: H. Denton J. Sniezek G. Holohan D. Vassallo R. Gallo G. Kelly i

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s Docket No. 50-352

. FACILITY: Limerick Generating Station, Unit 1 LICENSEE: Philadelphia Electric Company EVALUATION PERIOD: February 1, 1986 to January 31, 1987 PROJECT MANAGER: Robert E. Martin I.0 E TRODUCTION This report presents the results of the evaluation of the Philadelphia Electric  !

Company (PECo), the licensee for the Limerick Generating Station, Unit 1 in the

- functional area of Licensing Activities.

The approach used in this evaluation is consistent with the provisions of NRR 4

Office Letter No. 44,. Revision 1 NRR Inputs to SALP Process, dated December 22,

1986, which requires that each organization responsible for preparing a Safety

Evaluation provide a SALP input upon completion of the evaluation. The staff has applied the SALP evaluation criteria for the performance attributes based on first hand experience with the licensee or with the licensee's submittals.

The individual SALP evaluations for each rated issue were assembled into a matrix (See Appendix A). Those data were then used, with appropriate weighting factors.

for the importance to safety of the licensing issue, to develop the overall' evaluation of the licensee's performance. The assessments for the individual ratings were also tempered with judgment regarding the appropriateness of the rating for the specific licensing issue.

This approach is consistent with NP,C Manual Chapter 0516, which specifies that  ;

each functional area evaluated will be assigned a performance category based on -

a composite of a number of attributes.

, 2.0 SumA3Y OF RESULTS, .s This area was rated as Category 1 during the previous assessment period based on issues associated predominantly with issuance of the full power license and completion of the Startup Test Program. The previous assessment concluded that management involvement was apparent and very productive, that a high degree of -

licensee responsiveness was exhibited, that corporate staffing levels were stable and that reportable event frequencies had improved significantly. An

area of potential weakness was noted in the maintenance of oversight to ensure that forthcoming scheduler requirements were recognized and were responded to in a timely manner.

This assessment is based principally on the licensee's performance in support of three amendments to the operating license, the review of nine other technical issues and five petitions concerning licensee actions submitted by intervenors ,

pursuant to 10 CFR 2.206.

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The licensee has continued to demonstrate strengths in the areas of its approach to problems from a safety standpoint, the qualifications and level of staffing and in the declining frequency of reportable events.- However, several areas have not experienced the highest level of performance. These areas are (a) the i timeliness of licensee applications for NRC staff action relative to the requested ses'to support the action licensee's date, (2) the no proposed provision of adequate significant technical analy(NSHC) determinations, hazards consideration and (3) the coordination of plant activities and comunications with the NRC staff.

Based on the assessment discussed in this report, the licensee's performance in the functional area of Licensing Activities is rated Category 2.

3.0 CR_ITERIA The seven evaluation criteria as given in NRC Manual Chapter 0516 (Table 1) were considered in this assessment. In addition, housekeeping in and around the plant is also discussed. Several areas, asterisked below, were not rated or were not assigned a rating category based on a limited data base or non-applicability of the issue during this period. These criteria are.as follows:

A. Management involvement in assuring quality B. Approach to resolution of technical issues from a safety standpoint C. P,esponsiveness to NRC initiatives

, D. Enforcement History

• E. Staffing (including management)

, F. Reporting and analysis of reportable events G. Training qualification and effectiveness

• H. Housekeeping

• 4.0 PERFORVANCE ANALYSIS This performance assessment is based on the staff's evaluation of the licensee's performance in suppnrt of licensing actions which had a significant level of activity during the assessment period. These actions included the following issues:

1. Request for miscellaneous corrections to Tech Specs (TS)

2. Request for scheduler exemption from UFSAR filing l 3. A change to the corporate organization Tech Specs

4. Revision to Iodine spiking TS reporting requirements

5. Operator requalification training program approval-

6. Instrumentation line excess flow check valve TS surveillance interval extension

7. Containment isolation valve TS surveillance interval extension

8. Containment isolation small lines radiation monitor location review (II.E.2.4.7)

9. LPCI injection valve differential pressure TS setpoints

10. Standby gas treatment synem service to refueling floor TS

11. Revision to TS allowable air inleakage to control room

12. Revision to TS allowable feedwater temperature and core flowrate h

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- 5.1 Manaaement involvement and Control in Assurino Quality i Management involvement in assuring quality is apparent in the areas 'of strength noted above. However several weaknesses have developed in the assessment period which call for further management involvement. One of these areas, which was also noted in the previous assessment, is the timeliness of licensee applications for NRC staff action relative to the requested action date. An apparent lack of sufficient advance planning and preparation' is resulting in the majority of the requests for action being submitted only a short time before the needed action '

date. This concern applies to the subject of license amendment nos.'1,-2 and 3 and to the amendment applications concerning the standby gas treatment system

. service to the refucling floor and to the allowable control room air inleakage rate. For example, two of these issues were included in the initial operating license yet the responsive license amendment application was submitted only a few months prior to the needed action date. This concern was discussed with the licensee in a meeting on October 1. 1986 wherein the staff emphasized the importance of submitting applications, for which the need can be foreseen, in a timely manner so that the necessary actions can be completed without unduly impacting plant availability. The effort by the licensee in this meeting to project the anticipated filing date for requests for staff action and the date ,

such action is needed 'is commendable. However, three of the four items for which NRC staff action was requested by a specific time experienced delays in the projected-filing date of two or more months. This area will continue to be monitored by the staff and a more fomalized sd 'aling process may be i explored if the present less formal process remains unsatisfactory.

It should also be noted that, while some applications for action have been

, untimely, the absence of any requests for emergency Technical Specification

changes speaks well of the licensee's past efforts to develop the Technical ,

Specifications and the licensee's practices in managing the operation of the plant.

An additional area of weakness concerning management invo_1vement concerns

, the generalized nature of the licensee's arguments in f ts initial proposals of no significant hazards consideration (NSHC) determination. This area was not very active in the previous assessment which included only partial con-sideration of license amendment nos. I and 2. However, the much greater degree of activity in this assessment period, which included the remaining consideration of amendment nos. I and 2 as well as seven other amendment appli-cations, indicates that an enhanced level of management involvement over that apparent in the assessment period is warranted. Most of the nine license amendment applications considered in the rating period were initially inadequate-in their analysis of one or more of the three factors of 10 CFR 50.92. The deficiencies consisted of discussions which were overly simplified and ambiguous to support the assertion that each of the three factors were met. This results l in a more extensive NRC staff effort to develop the NSHC Federal Register notice which extends the time required to process applications. This issue has been addressed by Generic Letter 86-03, by letters to the licensee dated May 20, 1986 and February 19, 1987 and in extensive discussions with the licensee's staff, including a meeting on October 1, 1986. The licensee's performance appeared to be on a clearly improving trend at the end of the rating period.

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! A high level of continuing management involvement is also necessary to ensure 1

that plant activities remain coordinated with licensee corporate staff activities.

Although not typical of the licensee's performance, there was one issue in this area which received attention during the assessment period. Specifically, this concerned the license amendment no.1 Technical Specification changes to permit an extension of the surveillance interval for instrumentation line excess ficw checkvalves. The extension permitted postponement of testing until an outage on the basis that it was undesirable to conduct such testing during power opera-tions. However, t.he licensee later began testing some of the valves before the comencement of the outage, seemingly in at least partial conflict with the basis for the request for the extension. The conflict appears to have been due in part to a lack of good communications between plant staff and corporate licensing personnel. The staff addressed this issue in a letter dated August 5, 1986 to the licensee noting that although the issue may not constitute a legal violation, it represented a departure from the highest standards of communica-tions expected from licensees. The staff identified no further need for cor-rective action by the licensee in response to this specific event and there have been no similar recurrences during the assessment period.

Based on the above considerations a rating of Category 2 is assigned for this attribute.

5.2 Approach to Resolution of Technical Issues From a Safety Standpoint i A principal licensee strength is its approach to issues from a safety stand-point. The licensee's proposals have been technically sound, have reflected acceptable margins of safety and have contained few errors in technical infor-mation. This strength was apparent in the application for revision of the Technical Specification limits on feedwater temperature and core flow, which

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was accompanied by a safety analysis which was extensive in scope and systematic in its approach, and in the SGTS fan capacity issue wherein the licensee recog-nized the need for greater fan capacity and modified the design accordingly.

Based on the above considerations a rating of Category 1 is assigned for this attribute.

5.3 Responsiveness to NRC Initiatives

Strengths are apparent in the licensee's responsiveness in that the channels of communication between the staff and the licensee continue to be very effective.

The licensee is very responsive in arranging the appropriate resources for conferences and meetings. A weakness is also apparent in this area in that the problem of timely submittal of requests for staff action is one which con-tinues from the last assessment period and one which has shown no improvement during this assessment period.

Based on the above considerations a rating of Category 2 is assigned for this attribute.

5.4 Reportino and Analysis of Reportable Events With respect to reportable events, the licensee has generally submitted LER's in a timely manner. The licensee's performance is exemplary in this regard. Of

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the 50 prompt notification events; twenty involved Engineered Safety Features l (ESF) actuations, two involved temporary inoperability of safety-related equip- l ment requiring entry into Technical Specification action statements, and the.

i remainder were miscella7eous events including a bomb threat. The events were I generally identified and analyzed properly. The high percentage of LERs. resulting i from follow-up of the 50.72 reports would indicate a very thorough ard careful I

reporting policy. There also were very few subsequent revisions of the LERs.  !

! Of the two unplanned reactor scrams experienced during the evaluation period, one. occurred when the unit was at power. The second unplanned reactor scram

occurred due to personnel error, when the unit was being manually shutdown for '

4 a six week surveillance testing program. None of the events reported was of unusual safety significance and no events or problems specific to Limerick-were presented for the NRR Operating Reactor Events Briefings. All of these considerations suggest that correctives actions are effective.

The plant was critical for 7365 hours0.0852 days <br />2.046 hours <br />0.0122 weeks <br />0.0028 months <br /> during the reporting period and experienced an average of 0.14 unplanned scrams with rod motion per 1000 critical hours.

This scram frequency is much lower than the current national average of 1.14 scrams /1000 hours critical and indicates a well operated and maintained plant.

Based on the above considerations, the rating for this attribute is Category 1.

5.5 Staffing Changes have been adopted in the licensee's corporate organization, including the licensing staff that interfaces with NRR. The corporate changes include bringing the Engineering and Research, the Nuclear Operations and the Electric Production groups under a single Senior Vice President. These changes also include some reorganization at the plant staff level. The licensee charac-terizes these changes as being in response to a need to provide more responsive control and because of growth and specialization and to bring the Peach Bottom and Limerick plants under a common organization. The current licensing staff for Unit 1 is gaining further licensing experience and is increasing in effec-tiveness and all communications are handled in'a professional manner. Based on the recent implementation of these changes there is an insufficient basis to conclude whether they will be effective in alleviating the weakness noted above. ,

l Based an the linited time for the revised organization to demonstrate its i

effectiveness in addressing the weaknesses noted herein, the rating for this  !

attribute is Category 2.

5.6 Housekeeping and Control R_com Conduct 4

Observations made by the NRR Project manager while visiting the plant on .

several occasions during the rating period and those of the Resident Inspectors l

. indicate that the plant is maintained in an orderly and clean working-environ-

, ment. In all observed instances control room personnel conducted themselves  !

in a highly professional manner. This is reflected, for example, in the careful examination given to just issued amendments to the license / Technical Specifi-cation prior to proceeding with operations based on the amendments.

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Based on the limited observations a formal rating is not assigned.

6.0 Conclusion i In summary, for the present assessment period, the licensee's performance in the areas of technical responses to safety issues, responsiveness to staff communications and staffing levels continues at the high level previously experienced while the frequence of reportable events has improved markedly.

However, the timeliness of submittals, the adequancy of NSHC determinations and adequacy of corporate and plant staff coordination on actions before the NRC staff need continuing attention to improve the past level of performance or to maintai.n the improving trend achieved by the end of the assessment period.

Accordingly, an overall performance rating of Category 2 has been assigned in the licensing area.

i Section 043 of the Manual Chapter 0516 defines the meaning of rating the licensee's performance as Category 2 as follows

NRC attention should be maintained at normal levels. Licensee management attention and ir.volvement are evident and are concerned with nuclear safety. Licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational i safety and construction quality is being achieved.

l The NRC staff's attention will continue'to be focussed on the weak areas noted-herein, namely, the timeliness of submittals, the adequacy of NSHC determina-tions, and corporate / plant staff coordination as well as on the other areas.

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Appendix B - NRR Supportino Data and Summary

1. NRR Licensee Meetinos October 1, 1986, Scheduling of Licensing Activities

2. NRR Site Visits 1

April 3 PM observed activities at licensee's Emergency Operations Facility at Norristown during the EP exercise.

April 4 PM visited the plant, discussed licensing activities with the Resident Inspector and observed the licensee's critique of the EP exercise.

June 2,3 PM attended two days of General Employee Training (GET) at plant for issuance of unescorted access bade.

June 30 PM and Licensing Assistant visited plant including Unit 2 under construction July 1 PM visited plant and discussed licensing activities with Resident Inspector July 23 The Deputy Director, DBL, other member's of the Director's staff and OGC visited the plant with the PM.

3. Commission Briefinos None

4. Scheduler Extensions Granted Amendment No. I to the license granted a one-time extension of 14 weeks in the.18 month surveillance interval for instrumentation line excess flow check valves.

, Amendment No. 2 to the license granted a one-time extension of twelve weeks in the surveillance interval for certain containment isolation valves.

. 5. Reliefs Granted None

6. Exemptions Granted In conjunction with the issuance of Amerdment No. 2 to the license, a one time exemption from the scheduler requirements of Appendix J for the surveillance testing of certain containment isolation valves was granted.

7. License Amendments issued License amendment nos. I and 2, which extended the surveillance intervals on certain containment isolation valves, were issued on February 6, 1986 and March 3, 1986 respectively.

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l License amendment no. 3, which approved operation with a reduction of feedwater temperature of up to 60*F and an increase in core flow up to

105% of rated flow was issued on February 17, 1987.

There were six outstanding requests for amendments to the license at the end of the rating period.

8. Emeraency Technical Specification Changes Granted None l

9. Orders Issued None

10. NRR/ Licensee Manaaement Conference None l

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APPENDIX C

SUMMARY

OF PREVIOUS NRC SALP EVALUATIONS FOR THE LIMERICK GENERATING STATION Functional Area 12/1/83 - 11/30/84 12/1/84 - 1/31/86 Trend

-(Note 1)

A. Plant Operations 2 1 Consistent B. Radiolooical Controls 2 2 (Note 2)

C. Maintenance Not Evaluated 2 Consistent D. Surveillance Not Evaluated 2 Consistent E. Emergency Preparedness 2 1 Consistent F. Security and Safeguards 3 3 Consistent G. Preoperational &

Startup Testing 2 1 (Note 3)

H. Training & Quali-fication Effective-ness Not Evaluated 2 No basis I. Licensing Activities 1 1 Consistent J. Assurance of

. Quality Not Eva)uated 1 No basis Notes: 1. The low power license was issued in October 1984, the full

, power license was issued in August 1985, and commercial operation was achieved in February 1986.

2. A high level of performance could not be confinned since Radiological Controls Programs had not yet been significantly challenged.

3. Progressive improvement was noted throughout the assessment period, i

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I APPENDIX D

SUMMARY

OF PREVIOUS NRR SALP EVALUATION OF LIMERICK GENERATING STATION LICENSING ACTIVITIES-12/01/83 to 12/01/84 to- 02/01/86 to 11/30/84 1/31/86 1/31/87 (Proposed Unit 1)

Licensing '

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• Manaaement ^

Involvement i 1 2

• Approach to i Resolution of Tech Issues 1 1 1

• Responsiveness 1 1 2

' Enforcement 1 History * * --

Reportable Events

• 2 1

• Staffing 1

• 2

• Training * * --

• Housekeepino **

• i Overall Summary 1 1 2

• This crea was not formally assigned a numerical rating due to the small number l and scope of issues addressed during the rating period. However, if the trend experienced on those few issues had been maintained over a larger base of l experience then this would probably have been rated a Category 1.

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• • Plant was under construction / pre-operational status for almost all of this period. Based on comments by senior NRC representatives during site visits this would probably have been a category 2 with an improving trend had it been rated separately during that period.

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