Text

Responds to Deficiencies Noted in SALP Rept 50-352/86-99, Per NRC 870605 Transmittal & 870702 Meeting.Areas Addressed Include Plant Operations,Security & Safeguards & Training & Qualification Effectiveness
	ML20235J465
Person / Time
Site:	Limerick
Issue date:	08/14/1987
From:	Gallagher W; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20235J442	List: ML20235J439; ML20235J465;
References
	NUDOCS 8710010457
	Download: ML20235J465 (10)
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ENCLOSURE 2 PHILADELPHIA ELECTRIC COMPANY

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2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA, PA.19101 (215) 841 5001 JOSEPH W. G AL GHER gygggt 14, 198]

NWCLSAM OPE R ATIONS Docket No. 50-352 4 Mr. William T. Russell Administrator Region I U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Systematic Assessment of Licensee Performance (SALP) for Limerick Generating Station Report Number 50-352/86-99 Assessment Period: February 1, 1986 to January 31, 1987

Dear Mr. Russell:

1 This letter provides the Philadelphia Electric Company i (PECo) written response to SALP Report No. 50-352/86-99 for I Limerick Generating Station (LGS) which was forwarded by your I letter of June 5, 1987.

' PECo appreciated the opportunity to meet with the NRC staff on July 2, 1987 at the Limerick Training Center to discuss the results of the SALP Board report.

In general, the SALP Board assessment confirmed a strong orientation toward safe operation of LGS. This letter provides our comments on activities which the SALP Board analysis found to require improvement. A discussion of each activity follows.

Plant Operations The SALP Board presented no recommendations in the area of Plant Operations; however, the report noted that " licensee management does not appear to be thoroughly involved in activities affecting the quality of the fire protection program, as evidenced by the relatively large number of licensee event reports (LERs) in this area..."

8710010457 870924 PDR ADDCK 05000352 O PDR

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Mr. William T. Russell August 14, 1987 Page 2

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1 During this.12 month. assessment period, seven of nine

-LERs. associated with: Fire Protection activities involved fire

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3 doors and barriers. In the effort to curb this trend, more l emphasis has been placed on Fire Protection in the General' Employee-Training (GET) program to increase personnel awareness, of fire protection requirements. Further, station management'has conducted special fire protection discussions with station !

personnel on fire watches, control of fire doorsiand barriers, and. control of~ combustible materials. Only one fire protection 1

. associated ~LER has been. generated during the 6 months following

' February 1, 1987. :No LERs have been generated as a result of

-inadequate fire door or fire barrier control even though Unit 1 has been in a refueling outage since May 15, 1987.

The report also noted that " Additional management attention is warranted in staffing, since the Fire Protection-iAssistant position (left-vacant a year ago).-has not been l l permanently filled.....- Also, the corporate. Fire Protection Engineer rarely visits the plant to review the program or more

< importantly, to monitor Unit 2 construction activities as they may affect Unit 1."

PEco presently expects to have the Fire Protection Assistant position filled by-October, 1987. The Personnel Department is' expediting'the' recruitment of a qualified person.

The Corporate Fire Marshall currently conducts a minimum L of two inspections of-Unit 1 each year. The' inspection consists

of plant walkdowns'for fire hazards and overview of testing l- performed on fire system pumps, post indicating valves, and fire l hoses.- In addition, the Corporate Fire Marshall conducts a LBuilder',s Risk Inspection of Unit 2 every.four to-six weeks.

These. inspections include reviews, walkdowns, and testing of Unit

, 2 fire suppression systems. The unit is inspected for fire hazards, including their potential effects on Unit 1 operation.

Periodic site fire protection inspections are also i= conducted by station management, the Fire Protection Engineer of Engineering & Research, Safety Department representatives, and the' Quality Assurance Divisions of Nuclear Operations and

! Engineering and Research. .In addition, a Fire Protection l Engineer Support Request List has been created to provide l additional plant inspections and better communication and

coordination between the station Fire Protection Group and the

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Fire Protection Engineer.

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August 14, 1987 Page 3 Radiological' Controls 1 ._ . In the. Radiation Protection section of Radiological l Controls,lthe SALP report stated: ,

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C " Corporate' support was'not evident in l

plant' radiological control activities, .,

l and:is clearly lacking in programs to <

maintain personnel exposure levels as-low-as-reasonably-achievable (ALARA)....

'Regarding the ALARA program, there are no corporate' implementing procedures, as well'as a lack of formal participation

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(from.a site focus on work packages) by the Engineering and Maintenance c ..Depa r taents . . ALARA. goals-set by the site i

. Health *Physicsf(EP) group are' achievable

!' and establish.a level of excellence;

however, these goals do not receive L

' formal corporate sanction or involvement.

HP procedures assign responsibility to the site ALARA group to. revise modifications-to incorporate ALARA considerations.- However, the site.HP ALARA group is unqualified and undermanned for'this. task which is l' appropriately a' responsibility of

' licensee corporate engineering departments."

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'In' order to-be more responsive-in supporting LGS Health

. Physics Programs, significant changes are being made in the

. Radiation Protection Section of the Nuclear Support Department.

[ A new Radiation Protection Director, has been appointed. The corporate Radiation Protection Section is being restructured to

include additional professional and experienced personnel with j L clearly defined responsibilities. A broader scope.of support q l

will be provided in the areas of plant health physics !

assessments, operational assistance, ALARA reviews, operational

( ALARA support, equipment evaluations, radiological environmental l monitoring overviews, and dosimetry services.

A Radiological Engineering Group is being established

. . . . 'within-the Radiation Protection Section which will have -

l operational, as well as, engineering ALARA design experience.

l .Once properly staffed, the Radiation Protection Section will take l

the lead in coordinating or providing ALARA design reviews in I

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Mr. William T. Russell August 14, 1987 Page 4 support of both sites. It is anticipated that this group will be fully staffed and operating by March, 1988.

The operational ALARA program is being upgraded to require a deeper involvement of work group supervisors and management towards collective and individual dose control. The Radiation Protection Section is becoming more involved with raising the awareness of these groups pertaining.to dose estimates, dose budget, dose planning, and providing guidance concerning setting and meeting dose goals and objectives. The section will work closely with the stations and corporate departments to establish meaningful and challenging man-Rem goals for 1988.

The Radiation Protection Section is revising and upgrading the controlling radiological docuuents to provide a stronger corporate reference point for. coordination between PECo radiological policy and guidance and the site implementation programs. These upgrades include revisions to the Nuclear Operations Requirements & Guidelines No. 14, " Radiation Protection Program" and the Radiation Protection Manual (RPM).

Consideration is being given to separation of the ALARA section of the RPM for use as an individual manual for increased emphasis. It is anticipated that these documents will be fully upgraded and approved for use prior to December 31, 1987.

The Mechanical Engineering Division of Engineering &

Research has formalized and increased its ALARA design review activities in support of the site. A draft revision of Engineering and Research Department Procedure ERDP 3.1,

" Procedure for Handling Modifications", requires Nuclear and Environmer 41 Section input to modifications involving work in radiation creas or ' work on radioactive systems. In addition, an ALARA Review Checklist is required to be completed for everj modification when radiological concerns may be involved to ensure that ALARA considerations have been incorporated into the design.

The Mechanical Engineering Division and Radiation Protection Section have implemented a program to identify aed prioritize ALARA modifications. The prioritization of the modification requests is based upon potential man-Rem savings a?d cost. justification. This program is expected to aid in implementing those requests which have the largest impact for reducing radiation exposure.

Further corporate initiatives include the heat stress program, as it relates to radiological controls, and major

! changes in dose accountability and access control. Corporate

) administrative and implementing procedures have been written to describe the aforementioned program and are in the final review cycle.

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August'14, 1987 Page 5 I' -In1the Chemistry Controls section of-Radiological-Controls, the SALP report discussed the reliability of the Post--

Accident Sampling System'(PASS) and the licensee's capability to analyze non-radiological chemical parameters in various plant systems.

The PASS availability has continued to improve substantially as operational and design problems.,have been corrected. Routine quarterly tests have been consistently

- completed satisfactorily. In addition, the appropriate LGS staff and the Mechanical' Engineering Division continue to review and

! modify PASS to upgrade the system components and instrumentation to further improve the system reliability.

The disagreements with the standard measurement comparisons for non-radiological chemical parameters were-resolved by. bracketing,the analyses results_with standards for all subsequent sample determinations. At present, almost all analyses are control charted, and the action levels are set at two and three sigma with the exception of the gamma spectrometer efficiency check,-which is + 10%. This agrees with the ,

recommendation contained in paragraph 6.2.1 of INPO document CY- !

701, Rev. 1, "QC Program for Chemistry Instrumentation".

In' addition, the performance of most of the major i laboratory instruments, including the plasma spectrometer, is being checked quarterly using outside laboratory standards. This latter instrument was the one experiencing the calibration problems-mentioned in the SALP report.

Security and Safeguards The SALP Board recommendation in the area of Security and Safeguards was for the licensee to continue-to evaluate the effectiveness and impact of security program changes. The SALP report stated:

4 "In summary, the licensee has implemented many program changes and pursued many program improvements during this assessment period. Increases in program oversight and direction, management involvement and support, and enhancement

. . . - - . in the training. program all served to -

demonstrate the licensee's desire to develop and implement a high quality security program with a well qualified and dedicated, professional force.

However, many of those changes occurred

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August 14, 1987 Page 6 late in the period and the effectiveness of the changes has not been assessed."

PECo is continuing to make' improvements to the security program. The following is a summary of some of the significant changes made since the end of the 1986 SALP assessment period:

A. Staffing-Security ,

A Nuclear Plant Security section, headed by a Director with responsibility for the management and oversight of the PECo nuclear security program, has been established. The Director will be assisted by two Analysts. The number of Shift Security Assistants has been increased to six, five of which have been trained and qualified, enabling PECo to provide 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months oversight of the LGS contract security force as of April 15, 1987.

The Claims Security Division has assigned an investigator with primary responsibility to Limerick, which is resultimg in better coverage for investigations and increased overview of the security operation. Protection Technology Incorporated (PTI) management has worked closely with PECo and they have also made staffing improvements. PTI selected a replacement Program Manager with both operational supervisory and training experience. In addition the number of Corporals and Central Alarm Station / Secondary Alarm Station (CAS/SAS) Attendants was increased to provide better supervisory oversite. Specific watchmen have been assigned to the daily badging and shift clerical functions.

B. Administration and Procedures-Security A Security Incident Review Committee (SIRC) was established and implemented to provide a formal management review process to analyze significant security events in order to surface the root causes and improve the overall effectiveness of the security program. There has been a reduction in the number of reportable security events which is a direct result of Shift Security Assistant coverage and the SIRC activities.

Planning for the incorporation of LGS Unit 2 into operational i security is ahead of schedule. Much of the preliminary J .. . planning is complete.and PECo has held meetings with NRC.

Regional and Headquarters staff concerning the initial s concepts.

P A greater emphasis has been placed on improving the interface h between plant operations and security. A member of the

! security staff attends the control room shift turnover b

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August 14, 1987 Page 7 briefings.- In addition,,the, Chief Security Coordinator and an: engineer ~ from station: operations jointlyL review and take -

appropriate action on all'I&E Information Notices-concerning_

security;and' operations interface.

The Nuclear Plant Security and-Instrument andtControl-Sections have developed and implemented a preventive maintenance program for security equipment. ,

The Nuclear Employee Data System (NEDS) has 'been incorporated atcLimerick. cThis computerized. sharing.of information with other licensees has standardized and expedited the processing of contract employees. A new Personnel Processing Center

. facility with a separate security office is also being utilized to streamline the clearing and training of nuclear workers. In' compliance'with 10 CFR Section 73.57, more than 3500;of an. estimated.4000! employees.who have unescorted

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access privileges at LGS have been fingerprinted and the cards sent to the NRC for' FBI criminal. history records. The Security ~ Specification for: contractors.was also1 revised and issued-to incorporate the fingerprinting requirements.

Badge and card key Plant Protection-(PP). procedures, and .

-search. train equipment Surveillance Tests were revised to better clarify these' documents. -The substance of PTI Security Instructions are being incorporated into PECo's Plant Protection procedures.

The-frequency of protected. area: patrols.has been increased to

-provide a greater deterrent to intruders.

-C. " Human' Factors'&> Equipment-Security At.the request of PECo, PTI completed a Post (Watch Station) habitability study in May resulting in the installation of stools, increased supervisory visits, and increased manpower ,

rotatior on some Posts. !

, The PTI Access Lieutenant and Operations Sergeant were relocated in the PEco Shift Security Assistant's office so there can be a closer w: rking relationship between the groups. l

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PECo and PTI have initiated efforts to improve the morale of

. . . .the security force. members. The security force break room i has been remodeled with improvements to lockers, chairs, )

tables, kitchen facilities, vending machines and bulletin i boards. PTI has implemented a " Guard and Supervisor of the j Quarter Program", and awards for weapons proficiency. In addition, in February.an Ombudsman Program was started which >

provides for security force members concerns to be received l

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August 14,.1987 Page 8

. anonymously.on<a PTI 24: hour; hot-line. PTI has also increased benefits in-the areas.of wages, sick days and differential pay for jury duty.

TherPEco security staff _have obt'ained a " stand alone" computer to better protect Safeguards Information,' generate management. reports:and track action items.

< i D. Training-Security '

'PECo is establishing a training program to have the new Shift Security Assistants. properly trained in the classroom and on-the-job. Other members of the plant security. staff have attended' seminars on fence alarm, closed circuit television, and interview technique.. The PECo security staff is.also }'

-actively involved.in..the. Edison 2 Electric Institute Security 2 Committee,:and'the RegionJI NucleartSecurity Association.

PTI has added a' Shift SergeantuSyllabus,. Badge Clerk function. !

module, and1 Shift Clerk function module to the security force i training program. Upgrades have also been made in the '

Surveillance Test =and CAS/SAS, training programs,. Response Team module, Watchman on-the-job training program and Guard i training course. The supervisory training course has been revised to place a greater emphasis on the Fitness for Duty Program.

1 Training and Qualification Effectiveness l j

The SALP Board presented no recommendations in the area JS of"Trainingnand-Qualification ~ Effectiveness, however,.the report '

noted:

1 "Other weaknesses identified in individual exams included SRO ability to predict automatic depressurization system response when blowdown was in progress and suppression pool temperature limits as related to net positive suction head for emergency core cooling system pumps.

Reactor operator weaknesses involved correlating reactor vessel level with

.. . . . ' intermediate range neutron monitor .

detector response, and power response during a loss of feedwater transient."

The Licensed Operator Requalification Training (LORT)

, lesson plans will be revised to re-emphasize these three areas of 4

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August 14, 1987 Page 9 e

' licensed operator exam weaknesses. The revised lesson plans will be used in LORT cycles 3 and 4 which will be conducted in September and October, 1987.

Licensing Activities The SALP Board assessment of licensing activities identified three areas of concern. The areas were "(1) the timeliness of licensee applications for NRC staff action relative to the. requested action date; (2) the provision of adequate technical analysis to support the licensee's proposed no significant hazards consideration (NSBC) determinations and, (3) the coordination of plant activities and communications with the NRC tstaff". Further, the SALP Board recommended that a meeting be conducted to discuss progress in resolving the three areas of concern.

On June 23, 1987, a meeting was held in Bethesda, Md.,

between the-NRC staff and PECo Licensing representatives to discuss the three areas of concern. In order to improve the timeliness of amendment submittals, the PECo organizations which propose technical specification amendments have been requested to identify their licensing needs twelve to fifteen months in advance. Licensing has prepared a list of current anticipated licensing proposals. This list will be maintained and used to identify upcoming licensing items to the NRC staff in periodic meetings.

Generalized No Significant Bazards Consideration (NSHC) determinations were the result of an overall learning curve regarding the implementation of the guidance contained in Genaric Letter 86-03, " Applications For License Amendments". The

! Licensing Section is revising its procedures to incorporate the guidance provided in Generic Letter 86-03 plus the additional insights gained from NRC and PECo correspondence and dialogue.

Training will be provided for the Licensing Section staff to explain the purpose and content of these procedure revisions. It is expected that the revised procedures and training, combined with an increase in the Licensing Section staff, will enable PECo to provide consistent NSHC determinations with adequate technical detail and continue the improving trend noted at the end of the assessment period.

The concern of apparent lack of plant and corporate

. . . licensing interface, which resulted in. poor communication with I the NRC staff, was identified as a result of a single event. As noted in the SALP report, there have been no similar recurrences during the assessment period. Increased corporate licensing presence at the plant site, daily communications with the plant staff and licensing involvement in certain plant meetings, all t

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August 14, 1987 Page 10 ncontribute to better communications between corporate licensing, plant personnel, and the NRC. staff.

Should you have any questio'ns or require additional information, please contact us.

I Very trul'y yours, 0 00 %

i cc: Addressee E.'M. Kelly, Senior Resident' Site Inspector 1

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I' ENCLOSURE 3 l

U. S. NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NO. 50-352/86-99 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION UNIT 1 ASSESSMENT PERIOD: FEBRUARY 1, 1986 - JANUARY 31, 1987 l BOARD MEETING DATE: MARCH 17, 1987 l

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TABLE OF CONTENTS Page I. INTRODUCTION , ......... ............ 1 l A. Purpose and Overview ... ............ 1 B. SALP Board Members . . . . . . . . . . . . . ..... 1 C. Background . . . . . . . . . . . . . . . . . . . . . . 2 II. CRITERIA ........ . ......... ..... 5 III.

SUMMARY

OF RESULTS .................... 6 A. Facility Performance . ........... .. .. 6 B. Overall Facility Evaluation .. ...... .. .. 6 IV. PERFORMANCE ANALYSES. . . . . . . . . . . . . . . ... 8 i A. Plant Operations . . . .......... . ..... 8 B. Radiological Controls ........... . .... 12 C. Maintenance .... ............ ..... 17 D. Surveillance . . ... .... ..... . . 21 E. Engineering Support. ... ....... ..... 25 F. Emergency Preparedness ......... ..... 28 G. Security and Safeguards .......... ..... 30 H. Training and Qualification Effectiveness . ..... 34 I. Licensing Activities . .......... ..... 37 J. Assurance of Quality . ..... ... . . ..... 41 V. SUPPORTING DATA AND SUMMARIES . . . . . . . .. ..... 44 A. Investigation and Allegation Review .... ..... 44 B. Escalated Enforcement Actions ....... . ... 44 C. Management Conferences . . . . . . . . . . . ..... 44 ,

D. Licensee Event Reports . . . . . . . . . . . ..... 45 )

E. Licensing Activities . . . ........ ..... 47 l l

Tables and Figures l I

Table 1 - Licensee Event Reports . ........... ..... 48 1 Table 2 - Inspection Hours Summary .......... ..... 54 l Table 3 - Enforcement Summary . ........ .... . ..... 55 i Table 4 - Inspection Activities . . . . . . ........ ..... 57 Table 5 - Unplanned Automatic Trips and Shutdowns . ... ..... 59 Figure 1 - Number of Days Shutdown .... .. .... ..... 60 1

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I. INTRODUCTION A. Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this information. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations.

SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of the staff members listed below, met on March 17, 1987 to review the collection of performance observa-tiens and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety performance at the Limerick Generating Station Unit 1 for the period February 1,1986 through January 31, 1987. The summary findings and totals reflect a 12-month assessment period.

B. SALP Board Board Chairman W. F. Kane, Director, Division of Reactor Projects (DRP),

Members L. H. Bettenhausen, Acting Director, Division of Reactor Safety (DRS)

R. M. Gallo, Chief, Projects Branch 2, DRP C. J. Cowgill, Acting Chief, Reactor Projects Section 2A J. R. Johnson, Acting Chief, Operations Branch, DRS l M. Shanbaky, Acting Chief, Emergency Preparedness and Radiological Protection Branch, DRSS E. M. Kelly, Senior Resident Inspector W. R. Butler, Chief, BWR Project Directorate No. 4 R. E. Martin, Licensing Project Manager, NRR L_______---_-_______

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Other Attendees S. D. Kucharski, Resident Inspector J. H. Williams, Project Engineer L. Scholl, Reactor Engineer F. Hebdon, AE00.

R. Bailey, Physical Security Inspector R. Keimig, Chief, Safeguards Section W. Pasciak, Chief, Effluent Radiation Protection Section i T. Dragoun, Senior Radiation Specialist ,

J. Sweeney, Consultant i C. Background

1. Licensee Activities The startup test program was completed, and commercial operation was declared on February 1, 1986, following performance of the 100-hour warranty run on January 23-28, 1986. The plant oper-ated at full rated power through most of the assessment period at a capacity factor of approximately 82%.

The one unplanned scram from power during the period occurred on February 10, 1986 from 99.8% power on a high flux signal.

The high flux was the result of a pressure increase from tur-bine control valve closure due to a momentary ground created in the main turbine pressure control system by a test engineer who had been collecting turbine operating data. Following reactor startup on February 11, the plant operated at full rated power through May 2, 1986. A planned shutdown was commenced on May 2, 1986, and a six-week scheduled outage was begun to perform surveillance testing. An unplanned scram signal on low reactor vessel level occurred during the subsequent cooldown (with manual level control using a single feedwater pump) with all rods already inserted. The outage !

was completed within the scheduled time frame, and major work i included replacement of all 14 main steam safety valves, over-haul of all 4 emergency diesels, and extensive surveillance testing.

The plant achieved full rated power operation on June 21, 1986 and operated until July 4, 1986 when the plant was shut down due to an increase in unidentified drywell leakage. In addition to replacing LPCI valve packing, a recirculation pump seal was replaced and on July 13 the plant returned to full power operation.

3 Full power operation continued from July 1986 for a record 198 days until a controlled shutdown was begun on January 27, 1987 and a manual scram from 27% power was performed to repair three valves found later to be contributing to the high unidentified drywell leakage.

Plant load drops from full power were performed on several occasions at the end of the assessment period. Control rod pattern changes for the remaining rod groups still inserted in the core were made to extend core life. End-of-cycle coastdown began at the end of the period, as target burnup was reached and all control rods were fully withdrawn. New fuel arrived onsite on January 21-23, 1987. A license amendment to extend core life by allowing increased core flow and partial feedwater heating was. submitted to the NRC on November 16, 1986 and was approved shortly following the end of the assessment period.

Detailed preplanning was undertaken during the assessment period in preparation for the initial refueling scheduled to last 11 weeks and expected to begin in May 1987. The refueling will involve a full core offload, approximately 80 system modi-fications, and extensive testing and maintenance activities.

Organizational changes at the station level occurred through-out the assessment period, including promotion of a new station manager in April 1986. The licensee announced changes in November 1986 in PEC0 senior management associated with nuclear programs. The Senior Vice President for Nuclear Power and the Vice President (VP) for Electric Production retired, and J. S.

Kemper was appointed to a new position of Senior VP with three new VPs reporting to him, effective on November 24, 1986.

Annual emergency preparedness exercises were held on April 3, 1986 and January 15, 1987.

Startup commenced on January 30, 1987 after being shut down for 4 days to repair valve packing leaks, and power ascension to rated conditions was underway at the end of the assessment period.

2. Inspection Activities Two NRC resident inspectors were assigned to the site during the assessment period. The total NRC inspection hours for the 12 month assessment period was 2781 hours0.0322 days 0.773 hours 0.0046 weeks 0.00106 months . Distribution of these hours for each functional area is depicted in Table 2.

During this assessment period, the first year of commercial operations was covered. NRC teams evaluated two emergency preparedness exercises, conducted on April 3, 1986 and January 15, 1987.

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4 l A summary of enforcement activities is provided in Table 3, followed by inspection activities in Table 4.

This report also includes assessment of " Training and Qualifi-cation Effectiveness" and " Assurance of Quality" as separate functional areas. Although these topics are assessed in other functional areas through their use as evaluation criteria, these two areas are summarized separately to provide a synopsis. For example, quality assurance effectiveness was assessed on a day-to-day basis by the resident inspector and as an integral part of specialist inspections. Although quality work is the responsibility of every employee, one of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. Other major factors that influence quality, such as involvement of first-line supervision, safety committees, and worker attitudes, are discussed in each func-tional area.

Engineering support was evaluated as a separate functional area for the first time during this assessment period. Fire Protection is assessed as part of Operations, as in the last assessment, since there was only one programmatic inspection in this area. Security continued to receive increased inspec-tion effort, as in the previous period, because of identified weaknesses.

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II. CRITERIA Licensee performance is assessed in selected functional areas. Each functional area represents areas significant to nuclear safety and the environment, and are normal programmatic areas. The following evaluation criteria were used as appropriate to assess each functional area.

1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

3. Responsiveness to NRC initiatives

4. Enforcement history

5. Reporting and analysis of operational events.

6. Staffing (including management)

7. Training effectiveness and qualification Based upon the SALP Board assessment each functional area evaluated is classified into one of these performance categories. The definitions of these performance categories are:

Category 1. Reduced NRC attention may be appropriate. Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety is being achieved.

Category 2. NRC attention should be maintained at normal levels. Licen- i see management attention and involvement are evident and concerned with I nuclear safety; licensee resources are adequate and reasonably effective such that satisfactory performance with respect to operational safety is being achieved.

Category 3. Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear strained or not effectively used so that minimally satisfactory performance with respect to operational safety is being achieved.

The SALP Board has also categorized the performance trend over the course of the SALP assessment period. The SALP trend categories are:

Improving: Licensee performance was determined to be improving near the close of the assessment period.

Declining: Licensee performance was determined to be declining near the {'

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' A trend is assigned only when a definite trend of performance is discernible, and the SALP Board believes that continuation of the trend

, may result in a change of performance level.

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6 III.

SUMMARY

OF RESULTS A. Facility Performance Functional Category Category Area Last Period This Period (12/1/84 - 1/31/86) (2/1/86 - 1/31/87)

A. Plant Operations 1 1 B. Radiological Controls 2 1 C. Maintenance 2 1 D. Surveillance 2 1 Not E. Engineering Support Evaluated 1 F. Emergency.

Preparedness 1 1 G. Security and Safeguards 3 2 H. Training & Quali-fication Effective-ness 2 1 I. Licensing Activities 1 2 J. Assurance of Quality 1 1 1

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B. Overall Facility Evaluation The SALP Board assessment confirmed a strong orientation toward safe plant operation and found significant management, staffing, and performance strengths in plant operations, maintenance, surveillance, and emergency preparedness. Other functional areas, while rated Category 1 on the strength of performance during the period, were '

found to be so because of strong station management. Radiological controls and engineering support are examples of functional areas where strong corporate support will be necessary to sustain Category 1 performance. In most functional areas the licensee exhibited an ability to predict problems by taking a proactive approach to critically self-evaluate performance and institute ef fective corrective actions to prevent problems from occurring.

Control room activities were observed to be at a consistently high quality level. The conduct of business in the control room was professional and improved over previous assessments. Operator attitudes toward plant safety and cooperation with the NRC were excellent.

Security exhibited poor performance in past assessments, necessi-tating many program changes during the current assessment period.

Program improvements included increased oversight and direction of the security contract force, as well as increased licensee manage-ment involvement and enhanced training program enhancements. These changes indicate to us the licensee's intent to develop and implement a high quality security program. However, many of the cilanges occurred late in the assessment period and their effectiveness has not yet been assessed. Therefore, high management attention to the program must continue to ensure that this level of effort is maintained.

i 8

0 IV. PERFORMANCE ANALYSIS I

A. Plant Operations (974 hours0.0113 days 0.271 hours 0.00161 weeks 3.70607e-4 months ; 35's) l

1. Analysis This area was rated as Category 1 during the previous assess-ment period, concluding that staffing was at full complement, control room activities were fully supported by technical personnel and strong management involvement, with demonstrated ability to implement effective corrective action and perform critical self evaluations. Areas needing improvement were coordination between operators, on-shift. communication, and an increased recognition of Technical Specification requirements under changing plant conditions. Operator license examination failures during the previous period also reflected a recurrent weakness in supervising refueling operations.

Plant operations and activities were monitored by the resi-dent and region-based inspectors during this assessment period.

Station management continues to be visible in control room activities, particularly during major plant evolutions. Technical specifications and license conditions have been adhered to consistently. Operators are cognizant of safety system status, alarmed conditions, and equipment problems. Shift supervision has responded with conservative decisions on operability when equipment problems arise.

There were two unplanned scrams during the assessment period.

The only scram from power occurred at the beginning of the assessment period due to data collection that was not adequately l

controlled, and has not been a recurrent problem. The second scram occurred due to reactor vessel water level oscillations with all rods inserted and the reactor in a shutdown condition.

In contrast, nine unplanned scrams cccurred during the last assessment period. The licensee is an active member of the BWR Owners Group Scram Frequency Reduction Committee that convenes quarterly to discuss root causes of scrams and successful preventive measures. Good practices recommended or already implemented at Limerick include: head sets for communication between I&C technicians, test engineers and operators during surveillance; adjustment of the main steam line high radiation setpoint; protective cages around instrumentation racks and reduction in the number of continuously lighted control room annunciators. The result has been a marked reduction in unplanned scrams.

I

T 9

'[

Control room routines were maintained at a high level. New l

access controls were instituted.during the period that were effective in limiting non-essential personnel -and noise, and l improved the conduct of business in the control room to correct a chronic past problem. Improved access controls were notable since Unit 2 control panels were under construction during the last' half of < the period. Operator performance reflected high morale'and a cooperative attitude. Formalized shift turnover procedures were implemented during the assessment period, and, turnovers have been crisp and professional. Operators have

'found plant problems because of attention to detail in ttrn-overs, such as a reactor water cleanup pump which had tripped but was not annunciated, and a self-identified violation involving. chilled water isolation valves that had not been-t . properly isolated.

The plant operating; review committee (PORC)'has continued to effectively keep safe plant operation as the highest :>riority, D and plant management regularly convenes the PORC when signifi-cant issues arise. The closecut of the startup test program was carried out with the- same high quality as the conduct of the program rated as Category 1 in the previous assessment. Staf-fing levels and a tracking method were maintained such that the PORC was_able to assure that open test exceptions carried into the operational phase were closed out or periodically reviewed forfstatus with technically adequate action plans for each cpen test exception.

' Licensed operator staffing has been maintained _at a high level to support safe reactor operation. Staffing for both units is essentially in place; this allows for extra licensed expertise in the control room-to better handle collateral duties such as the fire brigade, equipment blocking and release for mainte-nance, and startups and shutdowns. Less use of overtime occurred as compared with the last assessment period when the plant was in a power ascension test program. Plant management communicates effectively with shift supervision and control room staff through daily meetings, as well as an end of the week planning session for weekend activities. Shift technical advisors (STAS) determine the scope of appropriate post maintenance testing; and assist in event deportability, recon-struction and emergency response. A new position of technical assistant on shift (TAOS) was created at the end of the period to allow the STA to remain in the control room with the shift superintendent. The TAOS has assumed computer display and offsite dose calculation responsibilities.

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' Licensed training programs were accredited by INP0 in October 1986. One set of license examinations was given during the l current assessment period; a total of 4 senior reactor opera-tors, three reactor operator candidates and an instructor certification were examined, and all passed.

Fire protection was assessed as part of resident inspections and one inspection by a region based fire protection specialist.

Deficiencies from the previous assessment for brigade members who missed quarterly meetings and semi annual drills were resolved by training makeup sessions. However, licensee manage-tent does not appear to be thoroughly involved in activities affecting the quality of the fire protection program, as evi-denced by the relatively large number of licensee event reports (LERs) in this area and in particular the number of LERs issued because of degraded fire barriers. It appears that, with proper training and increased management involvement, some of the fire protection related events could have been avoided. Additional management attention is warranted in staffing, since the Fire Protection Assistant position (left vacant a year ago) has not been permanently filled. The position has been temporarily filled by a technician who does not have State certification as a fire brigade instructor. Also, the corporate Fire Protection ,

Engineer rarely visits the plant to review the program, or more I importantly, to monitor Unit 2 construction activities as they ,

may affect Unit 1. '

Marked improvements were made in reducing the number of unnecessary control room annunciator alarms, with a daily average of five or less nuisance alarms by the end of the assessment period. Green plastic covers are used to identify expected alarming conditions, and other colored markings for which heightened response via alarm response procedures is necessary. Operators were responsive to, knowledgeable of the cause of, and aggressively investigated equipment conditions causing alarms.

The licensee's performance is exemplary with respect to reportable events. Of the 50 prompt notification events reported under 10 CFR 50.72, all were correctly identified and properly analyzed. The high percentage of licensee event reports (LERs) resulting from follow-up of the 10 CFR 50.72 reports indicates a thorough and careful reporting policy.

There also were few subsequent revisions of the LERs. None of the events reported was of unusual safety significance, and no events or problems specific to Limerick were considered significant. All of these considerations suggest that corrective actions are effective.

11 The plant was critical for 7365 hours0.0852 days 2.046 hours 0.0122 weeks 0.0028 months during the reporting period and experienced an average of 0.14 unplanned scrams with rod motion per 1000 critical hours. This scram frequency indicates a well operated and maintained plant.

In summary, the quality of operations was evident throughout the assessment period. A notable exception was fire protection program activities, particularly barrier control, staffing and corporate involvement. The number of reportable events attributable to operator error was significantly reduced, and the overall scram rate was extremely low.

2. Conclusion Category 1

3. Board Recommendations hone.

I

12 B. Radiological Controls (301 hours0.00348 days 0.0836 hours 4.976852e-4 weeks 1.145305e-4 months ; 10.8%)

1. Analysis Overview In the previous assessment period this area was rated as I Category 2. One minor weakness had been noted regarding ineffective communication of health physics (HP) control requirements to the work groups. This weakness has been recognized by the consistent efforts of the HP group to l

improve communications at all levels, including timely l

issuance of event reports for radiological incidents.

l I

! During this period there were several months of full power l operation and a 6-week outage which provided the opportunity to assess the radiological controls program under other than

, routine operational conditions. A total of six specialist inspections were performed: two in radiation protection; two in radwaste management and environmental monitoring; and two in chemistry controls. ,

, Radiation Protection Low plant radiation levels and the lack of significant d contamination have allowed station management and HP super-vision to focus attention on the more hczardous work such as neutron detector and recirculation pump seal replacements, resulting in excellent control of work and low personnel exposures. Total 1986 station exposure was approximately 70 man-rem, within the site management goal, due in part to the onsite Senior Health Physicist who has been aggressive in seeking cooperation and support from other site departments.

The HP department is fully staffed with permanent, qualified, and dedicated personnel. A new director of corporate programs was appointed at the end of the assessment period. Contract personnel play major roles in the respiratory protection and general employee training programs. No negative impact on the quality of these programs has been noted due to good licensee oversight of and qualification programs for the contract personnel.

Corporate support was not evident in plant radiological control activities, and is clearly lacking in programs to maintain per-sonnel exposure levels as-low-as-reasonably-achievable ( ALARA).

This issue is discussed further in Section IV.J, Assurance of Quality. Regarding the ALARA program, there are no corporate implementing procedures, as well as a lack of formal partici-pation (from a site focus on work packages) by the Engineering -

and Maintenance Departments. ALARA goals set by the site HP

13 9

group are achievable and establish a level of excellence; however, these goals do not receive formal corporate sanction or involvement. HP procedures assign responsibility to the site ALARA grcup to revise modifications to incorporate ALARA considerations. However, the site HP ALARA group is unquali-fled and undermanned for this task which is more appropriately a responsibility of licensee corporate engineering departments.

Nonetheless, the oversight of plant activities by onsite ALARA engineers and HP has been excellent.

Outage work was effectively controlled due to clear and well stated radiation work procedures, and the use of experienced lead HP technicians and similarly experienced work crews.

Although radiological hazards are generally low, the tech-nicians in charge of work took conservative precautions to prevent workers from becoming lax in regard to radiation protection. An overall positive attitude across all site work groups has been reflected by their adherence to routine HP controls. Sensitive automatic personnel friskers installed at the power block main access passageway provide control of very low levels of radioactive materials. However, the excel-lent control afforded by this equipment is complicated by the abnormally high level of naturally occurring radioactive material (radon) found in the geographic area of the site.

There was a concern identified by the NRC during the May 1986 outage that heat stress of the workers, with primary containment spot coolers secured, might compromise radiological consrols.

The licensee responded with a comprehensive heat stress control program expected to be administered during the 1987 refueling outage.

The respiratory protection program reflects a conservative approach to the control of intakes by workers with good proce-dures and a sizeable force of well-trained contractors.

A well organized training program continues to make a positive contribution to the effectiveness of the HP program. General employee training and respiratory protection instructors must complete a rigorous qualification program. The content and presentation of training for workers is tightly controlled by the corporate Nuclear Training Manual.

Audit programs appear to be effective in identification of program weaknesses. Several problems with the control of high radiation exclusion areas found during an NRC inspection had been identified by the licensee one month earlier, and were appropriately corrected by the end of the assessment period.

14 Radioactive Waste Management and Environmental Monitoring Program controls in processing and classification of radwaste were well managed. Significant organizational improvements were instituted at the end of the assessment period, including a change to a separate line organization from the previous matrix organization. A Radwaste Manual was developed to describe the conduct of operations, position responsibilities and program requirements. Management directed oversight /

approval of all radwaste discharges, review of performance indicators associated with the water balance program, and a published goal / commitment to become a "zero-release" (i.e.,

no radioactive liquid discharges) plant., Staffing was complete, with minimal reliance on contractor personnel. The non-liceased operator training program, which applies to radwaste operators, received INPO accreditation during this assessment period.

Technical support was also in place to identify radwaste equip-ment problems, establish unique priorities for work requests and identify equipment improvements. Continued radwaste program improvements to minimize dry active waste include plans for a super-compaction facility shared between the peach Bottom and '

Limerick stations.

An inspection of the licensee's radiological environmental monitoring found consistent application of the program, Quality assurance of the environmental thermoluminescent dosimetry (TLD) measurements is supported by two well-recognized comparison programs. No administrative offsite dose limits were approached, and radioactive waste shipments have been in compliance with the state requirements of South Carolina and Washington.

Chemistry Controls The licensee has developed and is implementing a site-specific water chemistry control program which follows EpRI and industry consensus standards. The onsite effort represents a significant improvement in resin controls, limiting chlorides, better trend-ing of solids and conductivity, and overall water quality since the last assessment. Review of plant chemistry performance and trends is routinely performed by station management.

Technical support to the station for resolution of post accident sampling system (PASS) reliability was not coordinated until identified and highlighted by the NRC. The licensee had not been able to satisfactorily complete surveillance tests to demonstrate PASS operation throughout the assessment period due to recurring component failures. By the end of the assessment period, licensee management directed the appropriate resources and had developed a thorough corrective action plan, including completing the surveillance and initiating system modifications.

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15 The licensee's capability to analyze non-radiological chemical parameters in various plant systems was reviewed. The results of.the standard measurements comparison showed six out of four-teen disagreements. The disagreements occurred in the metal analysis area and were caused by poor ad.tention to calibration and a lack of appropriate measurement control charts. Another problem was related to the licensee setting an arbitrary ten-percent control value rather than a statistically useful con-trol value. The problem of control charts was identified in an inspection during the previous assessment period. These problems could have been avoided with more attention to quality control details at the site or with better corporate involve-ment, in addition to a more timely followup of identified problems.

Personnel performance in chemistry was very good, even with roughly half of the licensee's staff (at the Support Chemist and ANSI technician level) as contractors. The licensee received INPO accreditation for their chemistry training program. Permanent (licensee) chemistry staffing is nearing final goals and should improve upon completion of the required training and qualification. QA surveillance at the beginning of the assessment period identified significant weaknesses in the plant chemical control programs which have been subsequently strengthened, i Summary Low radiation and contamination levels have allowed management focus on and excellent control of radiological work, resulting in low personnel exposures. Effective qualification and train-ing programs have allowed for good oversight of contractors and positive attitudes among site work groups with respect to HP controls, While audit programs are identifying some program I weaknesses, appropriate corporate support and involvement with I radiological and ALARA programs was not evident. Moreover, site )

radiological controls and ALARA oversight were effective, in j spite of the absence of corporate sanctions, because of strong station HP group management.

Radwaste program improvements continued to be implemented throughout the assessment period, as were chemistry practices, although increased corporate direction or assistance in those areas was warranted by virtue of problems experienced with !

laboratory QC and PASS reliability. l l

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2. Conclusion !

Category 1

3. Board Recommendations Licensee: See Section IV.J, Assurance of Quality NRC: Continue the routine inspection program, considering expected increased challenges associated with the 1987 refueling outage.

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w 17 C. Maintenance (362 hours0.00419 days 0.101 hours 5.98545e-4 weeks 1.37741e-4 months ; 13%)

1. Analysis This area was rated Category 2 during the last assessment period. No concerns were identified during that assessment, and, overul, maintenance programs were judged to be function- '

ing well The resident inspectors reviewed routine plant maintenance during the present assessment, and there was one programmatic inspection by a region-based specialist. Maintenance activi-ties were more extensive than in the previous period, as craft supported two outages; one a six-week surveillance test outage i and the other a one-week recirculation pump seal and packing replacement outage.

Careful and well-controlled maintenance programs have resulted in quality work during the assessment period. Program chal- '

lenges have been met by maintenance personnel as indicated by a lack of equipment deficiencies and excellent plant reli-ability and availability. There were no scrams attributable to this area, nor was there a backlog of safety related corrective maintenance. No examples occurred of recurrent failures involving rework or excessively drawn-out job schedules. Maintenance supervision demonstrated effective work planning, responded capably to contingencies, and main-tained an adequately staffed craft organization.

Maintenance was well-managed during the assessment period.

Maintenance craft accumulate the largest percentage of the i station's radiation exposure, and thus ALARA is a principal goal within the Maintenance Division. The ALARA goal was ambitiously set and slightly exceeded due, in part, to a large number of unanticipated reactor water cleanup system pump repairs. However, a vendor representative was consulted and, by eventually improving operating and maintenance proce-dures, no additional pump seal failures were experienced during the last quarter of the assessment period. Other targeted management goals included minimizing the use of contractors and eliminating excessive craft overtime. A new onsite maintenance supervisor was appointed at the end of the assessment period who has applied valuable quality control (QC) and maintenance experience to that position.

Significant demands for maintenance were met during the assess-ment period as evidenced by performance during the six-week mini-outage and major equipment repairs, including: the replacement of a recirculation pump seal, the replacement of all 14 main steam safety relief valves; the overhaul of all four emergency diesel generator er gines; and, rework of

18 o

l feedwater check valves and the main steam isolation valves :

(MSIV's). Generic information was factored into maintenance programs to promptly surface safety concerns, and effective vendor interface controls were evident in these major repairs.

Maintenance work has been extensive during the assessment period. Over 3500 preventive and corrective maintenance activities were completed, and with essentially no backlog of outstanding safety related corrective maintenance. Work is centered about a computerized program for history and mainte-nance planning (CHAMPS) that is also used to track maintenance, equipment history, failure-trends, and scheduling of resources.

A computer generated maintenance request form (MRF) has proved to be an efficient means of interfacing between plant staff, quality control, maintenance planning, and operations. Routine work is coordinated through a series of meetings during the day.

The meetings serve not only to effect proper interface among organizations on site, but also improvements in scheduling and maintenance craft morale. Work controls have been effective, particularly with respect to post-job critiques and work planning. Accurate appraisals of actual versus estimated job hours have been provided through the use of CHAMPS. Job dur-ation has been optimized by responsive health physics coverage, turnover of equipment, and effective engineering support.

Accurate job planning has enabled effective utilization of craft resources.

Maintenance Division senior management have extensive experience in nuclear maintenance. The Division, which consists of over 1100 personnel, has doubled in size in the past six years and is currently organized such that a significant mobile resource of craft are available on short notice for maintenance contingen- ,

cies and outages. As of the end of the assessment period, site '

maintenance was comprised of approximately 120 craft and 20 technical personnel. Competent maintenance engineering support was evidenced by complex and difficult in place repairs to a high pressure coolant injection (HPCI) isolation valve which were technically well conceived. The licensee has also recog-nized the need to plan for future growth within craft ranks by the addition of 29 entry-level Helpers currently in an on-the-job training progression.

Well-developed maintenance procedures have been prepared using a unique procedure writer's guideline. Maintenance procedures have been found to be sufficiently detailed, particularly in those cases of complex maintenance such as MSIV refurbishment, diesel overhauls, and safety relief valve replacements. Lessons learned have been factored into procedures based on plant experience, such as the recirculation pump seal replacement and control rod drive overhauls, as have Peach Bottom experiences.

The absence of any scrams attributable to maintenance activities reflects, in part, carefully developed procedures.

1 19 l Craft training programs were accredited by INP0 during the assessment period. Training initiatives have included pur-chase of a plastic recirculation pump seal training aid and plans to purchase a spare MSIV. A dedicated training facility at Barbados Island (a decommissioned fossil station) is equipped with Limitorque valves and other plant equipment for hancs-on training. The instructor to student ratio is excel-lent, at approximately 1 to 4. Formal classroom and on-the-job training are a part of a craftsman's progression to journeyman.

Specialty training has also been provided where necessary, as for example with~ refuel floor, snubber rebuilding, pump seals and control rod drive work.

Housekeeping was. maintained at a consistently high quality level.through persistent management attention, establishment of administrative controls including a housekeeping committee, and the effective use of a contract cleanup crew. As a result, there existed few hazards to fire, equipment and personnel safety during the assessment period. The licensee assured a continued level of good housekeeping, even with more difficult conditions dictated by refueling outage preparations, by use of a plant area concept accountable within the maintenance organization.

Quality audits and surveillance have given extensive coverage to maintenance activities. QC is involved in all safety-related maintenance via the MRF processing system. Quality trending reports during this assessment have analyzed findings over a two year period, assessing maintenance errors as a declining trend. The majority of quality findings in maintenance are related to the control of heavy loads at Limerick, and manage-ment accordingly initiated training to address the deficiencies.

In summary, maintenance programs were challenged more fre-quently during the current assessment period, and proved to be a strength as evidenced by a lack of equipment problems caused by maintenance, excellent plant reliability, and the lack of rework. Safety-related work was properly prioritized and pl a r.n ed . Efficient supervision of qualified craft resulted in effectively implemented procedures. No instances were identi-fied where maintenance caused equipment or system inoperability.

Consistently good engineering support was evidenced by well-planned and executed major repairs. Control of the removal '

from and return to service of safety related systems (including post-maintenance testing) was a consistent program strength.

20-a

2. Conclusions Category 1 j

3. Board Recommendations None' l

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l D. Surveillance (429 hours0.00497 days 0.119 hours 7.093254e-4 weeks 1.632345e-4 months ; 15.4%)

1. Analysis Surveillance was rated Category 2 during the previous assessment. Concerns were expressed with management of troubleshooting activities, controls on valve positions and independent verifications.

Test programs were reviewed by resident and region-based inspectors during the present assessment period. Specialist inspections covered the surveillance test and calibration control program, and containment local leak rate testing during the six-week May 1986 mini outage.

A well-managed surveillance test program was conducted during the assessment period. This is evidenced by the 40% fewer )

LERs than last. assessment period, the fewer number of missed surveillance, and the absence of emergency core cooling system (ECCS) actuations and reactor scrams caused by testing. One unplanned scram was caused by improperly controlled trouble-shooting at the beginning of the period. Tighter management controls on troubleshooting, including the requirement for a troubleshooting control form approved by shift supervision, prevented similar problems for the remainder of the period.

There were few unplanned actuations of safety systems (9 reportable events or 16% of all LERs, principally inad-vertent isolations) caused by test errors. Scheduling and control of surveillance testing has been excellent and there have been very few missed or late tests (of the 16,000 sur-veillance tests run annually). Routine testing is scheduled so as to minimize impact on plant operations. Complex testing has also been rescheduled for dayshif t during the week when plant management is more immediately available should signifi-cant problems arise.

The program has been successful in uncovering equipment prob-lems, such as the residual heat removal (RHR) service water pump flow blockage. Questionable test results receive proper super-visory attention. Evaluation of test results and anomalies have resulted in accurate identification of root cause, and the licensee has made conservative decisions with regard to system operability when test results were marginal.

The licensee maintains useful surveillance records enabling effective trending of test results when equipment problems were noted. Examples where test data were effectively utilized included the reactor protection system (RPS) power supply breakers and the containment purge system isolation valves, both the subject of 10 CFR Part 21 reports during the period. The hicensee was also able to reconstruct accurate i 1

22 l

test records to appraise potentially adverse trends on operation. l This was evident in an average power range monitor (ApRM) noise event involving an unexplained half-scram signal wherein a study of past testing helped to confirm proper RPS response in spite of seemingly anomalous results.

l The licensee conducts thorough and effective testing of systems, using procedures containing sound technical detail. Technicians j are well-trained and qualified, and good communications has been 1 established with licensed operators. Technicians have f'a all cases) suspended testing, and informed control room supervision prior to resumption of testing, when erroneous system responses have occurred. This practice has enabled prompt assessment of root cause for equipment malfunctions and timely reconstruction of sequences of events. In most reportable events during this period involving test technician errors, the licensee's staff comprehensively determined root cause, and this has been a factor in reducing repetitive occurences and improving proce- 3 dural inadequacies. Test procedures are developed to the point that, with improvements in human factors, incorporation of vendor recommendations and embodied precautions, high confidence in test procedures has been reached. The sub-PORC concept has assured that procedures remain technically sound by better attention to procedural detail on the part of responsible engineers and work groups prior to presentation to the i full review committee.

There have been instances where communications between test and control room personnel have led to violations (identified by the licensee), but these have been corrected and have not ;

been recurrent. In response to one reportaole event during the assessment period, the licensee provided timers in the control room that better administratively control the two-hour limit associated with channel functional testing.

There have been fewer reportable events associated with test-ing as compared with the last period, and the majority of these events have involved either fire protection or toxic gas detec-tion systems. Reportable events in the fire protection area were due to doors that were propped open and improperly con- .

trolled, missing barriers and seals, and surveillance that were missed due to poor communications. Moreover, there were a relatively high number of reportable events (see causal anal-ysis discussed in Section V.D.2.b) attributable to chlorine or '

toxic gas detecto- design deficiencies. As a result, the licensee has expended a considerable effort in maintaining these state-of-the-art systems. New chlorine electrolyte probes were installed at the beginning of the period to improve the reli-ability of a previous system involving a tape which broke frequently (and the source of numerous events). The licensee continued to address toxic gas detector design problems at the

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1 end of the assessment period by increasing test surveillance intervals and vendor / engineering involvement.

Previous problems associated with the temporary procedure con-trol (TPC) process have been corrected. PORC review has been effective in maintaining test procedure changes to a minimum.

Administrative processes to troubleshoot or to utilize TPCs, when necessary, are not cumbersome and have also contributed to procedure improvement. Previously experienced problems asso-ciated with instrument valve manipulations have been eliminated by the creation of a valving school and by restricting root valve manipulations to instrumentation and control (I&C) tech-nicians, as only one instance occurred during the period in which mispositioning an instrument root valve caused a report-able event. The licensee also has substantial capability in the area of performance data gathering and trend analysis, such .

as with the vibration monitoring program, chemistry database ;

management system and emergency diesel engine testing.

The licensee reported a number of self-identified violations involving testing. With the exception of fire protection barriers and doors, none of the test discrepancies were repetitive or indicative of a larger breakdown and attest to the licensee's continued ability to self-identify and correct problems. An effective concept for correcting the cause of test errors has been the use of roundtable discussions between I&C technicians and engineers. For example, a drywell airlock door leak rate test was six weeks overdue, but was discovered because the licensee had not had a large backlog of overdue surveillance tests and was adequately staffed to review test schedules and find these isolated examples. A retest of the 1 airlock was promptly performed, scheduling program errors were corrected, and the event was accurately reported. The licen-see's program (STARS) for scheduling and tracking surveillance assists in assuring that tests are performed on schedule. The coordination of the test program, across all disciplines, is very strong due, in part, to the importance placed on the pro-gram by licensee personnel and the assignment of an engineer as a dedicated surveillance test coordinator.

In summary, surveillance testing has been successful in reli-ably confirming operability and uncovering equipment problems.

The program is extensive yet well controlled, and personnel are qualified and conservatively conduct testing. Staff and shif t supervision are appropriately involved, engineering eval-uations are solicited when necessary, and staffing is adequate to support test schedules. Testing is integrated into day-to-day operations of the plant without unduly affecting reactor operation. The relatively few instances of missed surveillance are not a programmatic concern in an otherwise excellent test program.

24

2. Conclusion Category 1 l

3. Board Recommendations .;

None i

25 E. Engineering Support (61 hours7.060185e-4 days 0.0169 hours 1.008598e-4 weeks 2.32105e-5 months ; 2.2%)

1. Analysis This area has not been rated in previous assessments. During this assessment pericd the resident and specialist inspectors reviewed the plant modification and design change process, and assessed engineering support for plant operations, maintenance activities, and the upcoming initial refueling outage.

Corporate engineering and design support has been previously noted to be strong, and the company is highly engineering-oriented. Engineering issues have been effectively dealt with during this assessment, such as safety relief valve setpoint drifts and safety evaluations to support continued plant oper-ation such as for the extension of the reactor core isolation cooling (RCIC) system high energy line break boundary. One unplanned scram was attributed to a design limitation in feedwater level control and, as a result, the licensee is considering installation of additional startup level control valves.

Plant modifications have been implemented throughout the assessment period, with minimal impact on plant operations.

Detailed preplanning and design was performed for the large number of modifications planned for the first refueling out-age scheduled in May 1987. The most extensive modification for the outage involves tie-in of the standby gas treatment system to the refueling floor volume, a license condition required to be implemented prior to moving irradiated fuel.

Over 85% of the modification was completed as of the end of the assessment period, well in advance of the outage, and is typical of design changes which are completed such that there are more pre-engineered modification packages than there are opportunities or staff to install them. ,

1 Major modifications are performed by an experienced onsite j Construction Division staff, consisting of approximately 65 l permanently assigned craft personnel that are supplemented by contractors to support outage activities. The construction superintendent has been onsite at Limerick for 9 years and has had previous experience at Peach Bottom. The group performs extensive advance planning and utilizes the concept of a Construction Job Memorandum to summarize work scope for field l personnel. The group has been successful in coordinating among the licensee's matrixed organizations with minimal impact on plant operations, and has as a goal to levelize manpower during the upcoming refueling outage, accomplishing as much work in advance as practicable. Walkdowns of systems, and effective communications among work groups including daily participation in planning (TRIPOD) meetings, have served to

26 l

1 accomplish this goal. Design changes were implemented without extending the critical path schedule during the May 1986 outage, and have been practically integrated into the projected schedule for the refueling outage.

Safety evaluations associated with system changes are suf-ficiently detailed, giving evidence of the strong corporate engineering resources from which the licensee can draw for design support. A Field Engineering group is also available for electrical design and modifications. This group has con-sistently provided expertise to solve safety system problems.

Examples included: various relay and logic problems; the reactor protection system (RPS) power supply breakers that were moddfied to more reliably open to protect the hydraulic control l unit scram solenoids; and, the average power range monitors noise event that produced an unexplained half-scram signal and detailed questions relating to proper RPS response. This group is also responsible for Limitorque motor-operated valve (MOVATS) testing and troubleshooting, as well as reactor protection system inverter operation and safety-related breaker design and maintenance.

Engineering problems were experienced during the assessment period as evidenced by Unit 1/2 interface contamination incidents. The configuration of isolation devices in these piping systems cross-connecting common unit systems were such that internal contamination was allowed to migrate in several instances to the radiologically uncontrolled Unit 2 side of the piping systems. The licensee assembled a group to investi-gate the short term and long term actions necessary to ensure that Unit 1/2 interfaces are maintained isolated. Also, in response to NRC concerns near the end of the assessment period, corporate engineering developed a plan to address chronic PASS reliability problems that had not been appropriately recognized and brought to licensee management's attention.

There was a large number of LERs attributable to chlorine or toxic gas detector design deficiencies, and the licensee has expended considerable effort in these state-of-the-art systems.

New chlorine electrolyte probes were installed at the beginning of the period to improve the reliability of a previous system involving a tape which broke frequently (the source of numerous LERs). The licensee continued to react to these design problems at the end of the assessment period by increasing vendor and engineering involvement.

An item of concern involved the generation of new computer-drafted process and instrument drawings (P& ids) which were found ,

near the end of the assessment period to contain a substantial number of errors. In response, the licensee undertook immediate review of the drawings, red-lined copies in the

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27 q

control room and emergency response facilities, and undertook a program to permanently correct the drawings. No operational safety problems were identified as a result of these drawing errors. Engineering design controls and quality program effec-tiveness were being reviewed by the licensee at the end of the 4 assessment period to preclude similar future errors.

As noted in the last SALP report, the Technical Engineering .

group continues to be a valuable source of engineering knowledge J in the operation and test of plant systems. Further, the way in l which onsite programs are organized (i.e., the matrix organi-zation) integrates engineers into all site activities. For l instance, the plant engineer-maintenance has a staff which I provides engineering support for Unit 1 maintenance. In l parallel, the Maintenance Division has a self-contained engi- j neering group. Both groups of engineers constitute a source j of engineering support for Unit 1 maintenance which is separate and distinct from corporate design engineers. This is a typical

]

organizational structure of the licensee and is indicative of strong engineering within the company.

The licensee updated the " Level 1" portion of the probabilistic risk assessment (PRA) in September 1986, modifying system fault trees to reflect as- built system designs and revising accident sequence event trees to incitde: consideration of the emergency operating procedures; an updated station battery life estimate; and, a changed MSIV closure setpoint. The result of the update i was a reduction by a factor of 3 in the calculated core damage i frequency, and additional insights into initiating events. The licensee plans to use the current PRA as an analytical tool for cost / benefit analysis on design changes, evaluating changes to l the technical specifications, and providing a prioritization method for an integrated living schedule for licensing actions.

In summary, the licensee is strongly oriented toward engineering and has effective engineering support integral to all disci-plines in addition to the historically strong corporate design ,

engineering function. Engineering activities of the assessment j period were escalated, particularly in the second half, as f extensive planning and implementation of modifications for the I first refueling outage were underway.

l

2. Conclusion Category 1

3. Board Recommendations j i

None l

l

28 F. Emergency Preparedness (326 hours0.00377 days 0.0906 hours 5.390212e-4 weeks 1.24043e-4 months ; 11.7%) .

l

1. Analysi s j 1

Licensee performance in this area was rated as Category 1, (consistent) during the previous assessment period based principally upon support and guidance by the licensee's corporate staff, as well as the licensee's own initiatives in emergency preparedness.

During the current assessment period, there were three region-based inspections that observed two emergency exercises and a remedial medical drill.

Performance during the annual exercises has reflected success-ful planning and management of emergency preparedness (EP),

and demonstrates the licensee's ability to respond. Response personnel were knowledgeable in their duties and in use of implementing procedures; an indication of an effective train-ing program. In both exercises, the Emergency Director and Emergency Coordinator provided conservative, decisive technical support to operators in mitigation of degrading scenario events.

Decision-making by key licensee responders; effective command and control of the emergency facilities and organization; accurate protective measures for workers and protective action recommendations for the public; and, timely notifications to offsite authorities are all program strengths. Although minor exercise deficiencies were identified, the licensee corrected these by providing additional training in areas in which improvement was needed. Senior licensee staff and management were present at both exercise critiques.

The Station Manager has emphasized training, cooperation, and the importance given to emergency response. The corporate staff provides strong direction for the program, supports scenario development, and maintains current status on the state of off-site preparedness. The site Planning Coordinator has effectively maintained EP procedures and integrated changes into the EP training program which have been identified through drills and exercises. Implementing procedures have been improved based on feedback from drill evaluations and this process has improved the overall state of emergency preparedness at Limerick.

Emergency planners have successfully coordinated with all matrix organizations, working towards solving problems such as crowd control in the Operations Support Center (OSC) and radio

communications. A problem noted during the assessment period i involved coordination between corporate security and site operations regarding the assessment of bomb threats and the declaration of an unusual event. However, steps were in effect at the end of the period to effectively resolve this issue with

1 29

, all parties concerned. During a bomb threat that occurred i<n December 1986, control room supervisors were knowledgeable of emergency and security plan details, and decisive in initiating-searches and recognizing appropriate emergency action levels.

The dedicated emergency response facilities have been maintained in an adequate state of readiness through the period. Communi-cations and computer-based assessment equipment availability are given a high priority. The licensee also conducts quarterly trainine exercises, which has been reflected in the strong leadership evident by senior staff participation in the Emergency Director position.

In summary, the licensee has maintained a high state of emer-gency preparedness. Personnel have displayed evidence of good training, attitude, and dedication to this functon. Emergency preparedness activities are well integrated in day-to-day plant activities, and are part of.the routine PORC agenda. Strong corporate direction of the onsite programs and offsite functions has resulted in a program which has matured over past assessment periods.

2. Conclusion Category 1

3. Board Recommendations None i

30 G. Security and Safeguards (328 hours0.0038 days 0.0911 hours 5.42328e-4 weeks 1.24804e-4 months ; 11.8%)

1. Analysis:

During the previous SALP, Category 3 concerns were identified for weak management oversight of contractor activities, and a lack of willingness to address long-standing program shortcomings. As a result of escalated enforcement at the end of the previous period, the licensee iaitiated aggressive actions during this SALP period to address those concerns and to improve the program overall.

During this assessment period, three routine, unannounced physical protection inspections were conducted by a regional-based inspector. Routine resident inspections were performed throughout the assessment period.

The licensee and the security force contractor have aggressively pursued a planned course of action to identify the root causes of their previously identified poor performance. To improve the overall performance of the security organization, the licensee developed and implemented several significant changes.

Senior corporate officials affirmed their support for and intent to implement an effective security program at both of its nuclear generating stations by initiating a reorganization of corporate responsibilities. The Manager of Nuclear Support was given the responsibility to establish a security organiza-tion that would be headed by a Director. The role of the Director of Nuclear Security was defined, and assigned respon-sibility for the management and oversight of the PECO nuclear security program. A technical analyst was assigned to assist the Director. ,

In conjunction with this change, the licensee allocated large '

capital expenditures and authorized eight shift security assis-tant supervisor positions to provide 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months oversight of the contract security force, three of which were filled at the end of the assessment period. The responsibilities of these super-visors include assuring that the contractor properly implements the licensee's security program and that the security force maintains a high level of performance. In addition to the PECo supervisors, the licensee's senior onsite security representa-tive, the Nuclear Security Specialist, was also assigned a j staff of four technical assistants. These technical assistants are responsible to monitor key aspects of the security program on a day-to-day basis. The development and implementation of l this expanded PECo oversight organization, along with the corporate changes, is evidence that the licensee is attempting to implement a sound security program that goes beyond minimum

31 compliance with NRC requirements. . However, these changes are very recent, and,. therefore, their impact on the program has not yet been assessed by NRC.

Additionally, to instill in the security force personnel a strong sense of. purpose and a clear understanding of their

-roles and-responsibilities, the security force contractor made changes to its supervisory staff, implemented numerous human factors improvements and refined the training program.

To combat earlier problem's of low morale and job dissatisfaction in the security. force, the contractor addressed employee con- )

cerns regarding pay, benefits and human factor's. Overtime hours !

were'substantially reduced and additional personnel were hired to meet Unit 2 security duties previously assigned to members of the Unit 1-security force. As'a result of continued support of the security program by the plant manager and other plant func-tional groups, as well as the improvements made to the program,

' the morale of security . force personnel appears to have improved, as. demonstrated by a professional and dedicated demeanor.

The licensee also required its contractor to refine the train-ing program.- Two noteworthy refinements are the development ,

of a training program curriculum to define the purpose and '

performance objectives of the program, and the initiation of routine random testing of security force performance and qualification criteria. The.results appear to be' effective, es evidenced by the greater awareness of duties and a more responsible attitude displayed by security force personnel.

The licensee's training program is carried out by individuals who are experienced and assigned.to security training only. j Training facilities have adequate classroom space. Lesson '

plans are fairly well developed, generally thorough, and kept current through feedback from supervisors and quality assurance, and from the on-the-job performance testing. Random testing is a significant program enhancement that has improved the perform- )

ance and self-confidence of security force members. Security procedures and instructions were recently revised to be more clear and concise, which should enable members of the security force to improve their performance.

Overall, the licensee, and its contractor appear to be addres-sing the major security program shortcomings experienced in the past. The licensee's efforts in this regard are significant but management attention must continue at the current level.

Security management continued to be actively involved in industry and NRC initiatives dealing with nuclear security programs. This provides evidence of support for the secur-ity program at a high level in the licensee's organization.

Management personnel also exhibited a clear understanding

32 and conservative approach to technical security issues as evidenced by their handling of security matters that evolved as a result of the resumption of Unit 2 construction. The licensee's approach to resolution of those matters was noteworthy. A very clear and comprehensive plan was devel-oped, integrated with other plant functional and construction '

groups and subsequently reviewed on-site with NRC representa-tives before being implemented. This approach was extremely effective in preventing numerous problems that are usually encountered under such circumstances.

The licensee submitted four security event reports pursuant to 10 CFR 73.71(c) during the assessment period. One report concerned the misidentification of a vital area door; another concerned a minor delay in response to an alarm because of a miscommunication; the third identified the discovery of a weapon during the search of a vehicle prior to entering the plant protected area; and the fourth reported a non-credible bomb threat. In all cases, the licensee's compensatory measures were timely ar.d appropriate, The reports to NRC were prompt, clear, and thorough. These reports have shown considerable improvement during the assessment period.

Inspector reviews of the security incident files found that the NRC-approved security plan was being properly implemented.

The lack of systems and equipment-related event reports during this period is noteworthy, and evidence of increased licensee attention to preventive maintenance and surveillance testing.

During the assessment period, the licensee submitted two revisions to the Security Plan under the provisions of 10 CFR 50.54(p) and provided its response to the August 4, 1986 Miscellaneous Amendments to 10 CFR 73.55 codified by the NRC.

The licensee's corporate security staff is responsible for ensuring that Plans are current, and for coordinating changes when required. The staff is very effective in carrying out this responsibility. They often communicate and review Plan changes with regional licensing personnel to ensure a clear understanding and, when the Plan changes are submitted to NRC, they are of good quality, indicative of a thorough review and good understanding of NRC security performance objectives.

In summary, the licensee has implemented many program changes and pursued many program improvements during this assessment period. Increases in program oversight and direction, manage-ment involvement and support, and enhancement in the training program all served to demonstrate the licensee's desire to develop and implement a high quality security program with a well qualified and dedicated, professional force. However, i many of those changes occurred late in the period and the effectiveness of the changes has not been assessed. Therefore, !

l

+

1 33 high level management attention to the program must continue to ensure that the current level of eff>rt to improve the program is maintained.

2. Conclusions Category 2 !

3. Board Recommendations Licensee: Continue to evaluate the effectiveness and impact 9 of security program changes.

i NRC: Maintain existing inspection effort. i i

I, i

5 L__-----____--_ !

i 34

q H. Training and Qualification Effectiveness j

1. Analysis The various aspects of this functional area have been considered and discussed as an integral part of the other functional areas and the respective inspection hours have bc en included in each one. . Consequently, this discussion is a synopsis of the assess- ,

ments related to training conducted in other areas. Training effectiveness has been measured primarily by the observed per-formance of licensee personnel and, to a lesser degree, as a review of program adequacy. This discussion addresses three principal areas: licensed operator training, non-licensed staff train! 3, and the status of INPO training accreditation.

During the previous assessment period, training and qualifi- l cations effectiveness was considered as a separate functional area for the first time and rated Category 2. Training and qualification effectiveness continues to be an evaluation criterion for each functional area. The previous assessment recommended refresher training in refueling operations and core alterations in preparation for the first refueling outage, as well as increased emphasis on Technical Specifications for licensed personnel. The current assessment is based on resident and specialist observations as well as two specific inspections of nonlicensed and maintenance training programs.

Fire protection training was assessed as part of one inspection by a region based fire protection specialist. Deficiencies from the previous assessment for brigade members who missed quarterly meetings and semi annual drills were resolved by training makeup sessions. However, licensee management does not appear to be thoroughly involved in activities affecting the quality of the fire protection program, as evidenced by the relatively large numt:er of licensee event reports (LERs) in this area and in particular the number of LERs issued because of degraded barriers. It appears that, with proper training and increased management involvement, some of the events could have been avoided.

During the current assessment period license examinations were given to four senior reactor operator (SRO) candidates, three reactor operator (RO) candidates and an instructor certifica-tion, which all passed. Emergency procedure use continued to be a licensee strength, as was knowledge of specific systems in written exams. Knowledge of technical specifications was also a notable strength which is an improvement from last year. One generic weakness observed during the conduct of the exams was l difficulty in the location of control room indications (not I currently installed on the simulator) during oral exams.

l Simulator upgrades, which include a better panel mimic of

35 isolation logic and setpoints, process monitors, and a complete remote shutdown panel, are scheduled to be completed by October 1988. Other weaknesses identified in individual exams included SR0 ability to predict automatic depressurization system response when blowdown was in progress and suppression pool temperature limits as related to net positive suction head for emergency core cooling system pumps. Reactor operator weaknesses involved correlating reactor vessel level with intermediate range neutron monitor detector response, and power response during a loss of feedwater transient. Internal coordination of license appli-cations has significantly improved due to centralized corporate oversight.

The effectiveness of plant operator and test technician train-ing programs was reflected in the absence of reactor scrams and the low number of safety system actuations attributable to those groups. I&C technicians are well-trained and qualified, and good communications have been established with licensed operators. Technicians have (in all cases) suspended testing, and informed control room supervision prior to resumption of testing, when erroneous system responses have occurred. In most reportable events during this period involving test technician errors, the licensee's staff comprehensively determined root-cause, and this has been a factor in reducing repetitive occurrences. An effective concept for correcting the cause of test errors has been roundtable discussions between I&C tech-nicians and engineers. For cxample, previous problems with instrument vah, manipulations have been corrected by the creation of a vulving school and by restricting root valve manipulations to I&C technicians. Only one instance occurred during the period in which mispositioning an instrument root valve caused a reportable event.

The licensee reported 21 events attributable to personnel errors. However, with the exception of fire protection barriers and doors, none were repetitive or indicative of a larger breakdown and attest to the licensee's continued ability to self-identify and correct problems.

A well-organized and controlled radiological training program continues to make a positive contribution to the effectiveness of the HP program. This is evident by the low station personnel exposure history to date, and by the excellent attitude of all site work groups adhering to HP controls. Instructors involved in general employee training and respiratory protection training must complete a rigorous qualification program. The content and presentation of training for workers is tightly controlled by the corporate Nuclear Training Manual.

36 Craft trainin; programs were accredited by INP0 during the l assessment period. The Limerick Training Center and Barbados Training Center support tha non-licensed training activities very well. Contractor support is also enlisted for training.

Training initiatives have included purchase of a plastic recirculation pump seal tre.ining aid and plans to purchase a spare MSIV. The maintenance training facility at Barbados, a decommissioned fossil station is equipped with Limitorque valves, a spare reactor water cleanup pump, and other actual plant equipment for hands-on training. Formal classroom and on-the-job training are a part of a maintenance craftsman's progression to the journeyman rate. Specialty training has also been provided where necessary, as for example with refuel floor activities, snubber rebuilding, pump seals and control rod drive rebuilds.

In summary, management has promoted a positive attitude in all areas toward the importance of training. The licensee achieved INP0 accreditation of all of its ten training programs on October 30, 1986, two months ahead of a self-imposed schedule set during the previous assessment period.

2. Conclusion Category 1

3. Board Recommendations:

None

37 o

I. Licensing Activities

1. ' Analysis This area was rated' as Category 1 during the previous assess-ment period based on issues associated predominantly with issuance of the full power license and completion of the Startup Test Progra:n. The previous assessment concluded that management invo'.vemeTc was apparent and very productive, that a high degree of liceasee responsiveness was exhibited, that corporate staffing levo)3 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 interveners pursuant to 10 CFR 2.206.

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: (1) the timeliness of licensee applications for NRC staff action relative to the requested action date; (2) the provision of adequate technical analyses to support the licensee's pro-posed no significant hazards consideration (NSHC) determinations; and, (3) the coordination of plant activities and communications with the NRC staff.

Management involvement in assuring quality is apparent in the areas of strength noted above. However, several weaknesses in licensing activities 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 has resulted 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 refueling 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

38 1

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 l

in this meeting to project the anticipated filing date for j 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 formalized scheduling process may be 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 changes to the technical specifications 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 concerns the generalized nature of the licensee's analyses in its initial proposals of no significant hazards consideration (NSHC) determination. This area was not very active in the previous assessment which included only partial consideration 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. 1 and 2 as well as seven other amendment applications, 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, resulting 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 NRC 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.

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

o 39 4

which received attention during the assessment period. Spe-cifically, this concerned the licensee amendment no. 1 Technical 1 Specification changes to permit an extension of the surveillance interval for instrumentation line excess flow check valves. The extension permitted postponement of testing until an outage on the basis that it was undesirable to conduct such testing during )

power operations. However, the licensee later began testing )

some of the valves before the commencement of the outage, seem- i ingly in at least partial conflict with the basis for the

{

request for the extension. The conflict appears to have been j due in part to a lack of good communications between plant j staff and corporate licensing personnel. The staff addressed i 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 stand-ards of communications expected from licensees. The staff !

identified no further need for corrective action by the licensee in response to this specific event and there have been no similar recurrences during the assessment period.

A principal licensee strength is its approach to issues from a safety standpoint. The licensee's proposals have been technically sound, have reflected acceptable margins of safety and have contained few errors in technical information. This strength was apparent in the application for revision of the Technical Specification limits on feedwater temperature and core flow, which was accompanied by a safety analysis that was extensive in scope and systematic in its approach, and in the SGTS fan capacity issue wherein the licensee recognized the need for greater fan capacity and modified the design accordingly.

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 continues from the last assessment period and one which has shown no improvement during this assessment period.

Changes have been adopted in the licensee's corporate organi-zation, 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 characterizes these changes as being in response to a need to provide more responsive control, 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

40 is increasing in effectiveness. The licensee's staff coordin-ates an effective response to NRC requests for information.

There is a visible effort to improve effectiveness and all communications are handled in a professional manner. Based on '

the recent implementation of these changes there is an insuf-ficient basis to conclude whether they will be effective in clieviating the weakness noted above. ,

l 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. 3 However, the timeliness of submittals, the adequacy of NSHC

determinations, and the 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 main-tain the improving trend achieved by the end of the assessment period.

2. Conclusions Rating: Category 2

3. Board Recommendations NRC: Conduct a meeting with the licensee to discuss progress in resolving the three areas of concern, namely the timeliness of submittals, the adequacy of NSHC determinations and licensee plant / corporate staff communications.

., a f

41 4

J. Assurance of Quality

1. Analysis Management involvement and control in assuring quality was initially considered as a separate functional area in the previous SALP, in-addition to being one of the evaluation criteria in the other functional areas. The previous assessment rated this area as Category 1. This discussion is a synopsis of the assessments relating to the assurance l of quality for activities in other functional areas. The l area was evaluated by both resident and region-based inspec-tors and is based, in part, on one_ specific inspection of QA/QC programs and Independent Safety Engineering Group (ISEG) activities.

In assessing how the licensee assures quality, the SALP Board has considered various attributes normally considered key contributors to the assurance of quality. Among the attributes considered are implementation of management goals, planning and control of routine activities, worker enthusiasm and attitudes, management involvement, staffing, and training.

Licensee management addresses these attributes in diverse ways. An operational excellence program was institued during the assessment period that, while formally completed, estab-lished the desired attitude across all work groups to carefully consider safety and quality, apply attention to detail, involve supervision and critically self-evaluate. Those traits have been evident in the attitudes and performance of personnel at Limerick.

The Plant Operating Review Committee (PORC) was convened on over 100 occasions during the assessment period, and has been instrumental in maintaining safe reactor operation as a priority.

The group has clearly insisted on procedures, safety evaluations in support of modifications, and well considered approaches to solving station problems. A tracking system is used that ;

clearly assigns accountability to resolve open issues, such as J test exceptions remaining from the startup test program. The group has consistently remanded items to their orginator when less than expected quality was presented. The expectations for quality in the many issues presented to the PORC have been high.

As discussed in Section IV.A, the fire protection program war-rants additional management attention with regard to staffing, since the Fire Protection Assistant position (left vacant a year ago) has not been permanently filled. The position has been temporarily filled by a technician who does not have State certification as a fire brigade instructor. Also, the corporate i

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ I

42 f Fire Protection Engineer rarely visits the plant to get a feel-1 ing for the program, but more importantly to closely monitor construction activities as they may present a fire hazard for Unit 1.

Also, as discussed in Section IV-.8, corporate support was not evident in plant. radiological control activities during the period. An otherwise excellent corporate radiation protection manual appears to be generally ignored at site and corporate levels, and corporate involvement is clearly lacking in the ALARA program. ALARA goals set by the site are achievable, and establish a level of excellence; however, these goals do not receive formal corporate sanction or involvement.

Nonetheless, the oversight of plant activities by onsite ALARA engineers and HP has been excellent.

The Independent Safety Engineering Group (ISEG) has been active in feeding back experience to operational practices, while independently assessing significant potential problems.

A Nuclear Safety Section Supervisor chairs the licensee's Operational Experience Assessment Committee (0EAC) at monthly meetings, and the scope of industry wide experience reviewed and the quality of OEAC recommendations is excellent. ISEG investigations have provided valuable lessons learned, such as tagging both ends of long leads associated with temporary circuit alterations. The ISEG moderates the newly established Plant Incident Review Committee, utilizing shift supervision to successfully determine the root of operational problems such as the drywell chilled water isolation valve violation.

The ISEG has studied reportable events, particularly in the area of personnel error. In response to an LER at the end of the assessment period, the ISEG is undertaking a review of the use and replacement of fuses in safety related circuits.

Investigation of reportable events were thorough, and recom-mendations made by ISEG were well received by licensee management. The ISEG has also been involved with a study of the reliability of the main feedwater system in concert with corporate engineering, important in light of its role as a PRA accident initiator. The ISEG is a contributor to quarterly meetings of a BWR Owner's Group on scram reduction, and in a new Human Performance Evaluation System (HPES) used to evaluate causal factors in personnel errors and explore the man-machine interface. The experience of ISEG members has been diverse and useful.

QA/QC involvement in performing audits and surveillance has helped to keep quality in the forefront of areas such as opera-tions startup testing, maintenance, surveillance, non-licensed training and fire protection. A visible QA/QC organization is evident. The personnel assigned to these areas were found to

43 be knowledgeable of the QA program as it is applied to opera-tional activities such as maintenance and testing. QA/QC groups include contract support personnel, and the licensee has provided complete training for contractors prior to per-forming their new function to assure a smooth transition. QA and QC have been utilized by licensee management to solve various quality problems during the assessment period. These problems have included control room communications breakdowns, vendor access screening, the control of safeguards information and security barrier breaches. At the end of the assessment period the licensee was proposing more active involvement by QC in monitorin'g test activities and performing independent verifications.

Meetings were held onsite to discuss the licensee's use of a Quality Assurance Trending and Tracking system (QATTS) as discussed in the previous assessment period. QATTS findings have been effectively presented to licensee senior management who are aware of and have proposed measures to correct and reduce observed trends. These include training initiatives, procedural changes, and proposed design fixes. The QATTS is being developed by the licensee into a useful management tool.

The licensee's Nuclear Review Board (NRB) was convened auring routine sessions and on a number of special occasions during the assessment period to review the more significant and unantici-pated safety problems. These included confirmation of expected reactor protection system response during the APRM noise event, and the review of significant nonconformance findings of quality j audits such as from vendor screening, chemistry control pro-grams, and others. NRB recommendations have been undertaken by Engineering and Production organizations. The NRB was restruc-tured under a new chairman at the end of the assessment period.

In summary, the quality programs in effect at Limerick have included QA/QC, the Nuclear Review Board and PORC committees, the ISEG, and effective front-line supervision of all disciplines. The quality programs have instituted a set of checks and balances to prevent undetected errors, and their overall result has been good personnel attitudes, few alle-gations, evidence of quality workmanship and a substantially problem-free period of reactor operation. ,

2. Conclusion Category 1

3. Board Recommendations None o_____________________. - - I

44 i

V. SUPPORTING DATA AND SUMMARIES A. Investigations and Allegation Review No NRC Office of Investigations reviews were conducted during the assessment period.

There were five allegations concerning Unit 1 during this assessment period, which included three in the area of security. Of the three security issues, one is a carryover from last assessment period based on additional concerns of the alleger; the other two were found to be unsubstantiated and a drug-related concern which is still open.

Another allegation concerned demineralized resin transfers which involved an unsubstantiated ALARA concern. The.last allegation dealt with internal piping contamination between Unit 1 and Unit 2, and was rsolved.

B. Escalated Enforcement Actions

1. Civil Penalties None.

2. Actions Pending/ Resolved None.

3. Orders None.

4. Confirmatory Action Letters None.

C. Management Conferences On July 11, 1986, the licensee met with NRC management in King of Prussia, Pennsylvania to discuss the previous SALP report findings.

45 D. Licensee Event Reports (LER)

1. Tabular Listing Type of Eveny A. Personnel Error 21 B. Design /Manuf./Constr./ Install. 15 C. External Cause 2 D. Defective Procedure 8 E. Component Failure 7 X. Other 2 Total 55 A tabulation of LERs by functional area, and an LER synopsis is attached as Table 1.

LER Nos.86-002 to 86-056 were received and reviewed by the NRC during the assessment period.

2. Causal Analysis l

The 55 LERs which were reported during the assessment period were also subject to an ongoing review as part of NRC inspec-tions for trends and root cause identification. The following sets of common mode events were identified:

a. Twenty-one LERs concern events caused by personnel error, which is a reduction both in the total number and frequency of these occurances from last assessment period. Licensee management is continuing its effort to better understand and reduce personnel errors by increased training and personnel awareness, and Independent Safety Evaluation j Group (ISEG) involvement in the Human Performance Evaluation System (HPES).

While the number of personnel error-related events account for approximately 40'4 of all reports during the assessment period, the principal contributors were associated with j fire doors and barriers and inadequate communications dur- 1 ing surveillance testing. The licensee has recognized these trends and has taken steps to reduce related causal factors. Further, although 12 of the 21 events were in the '

area of surveillance testing, a number were deficiencies L )

I

_ _ - - - - - l

l I 46 1

l found by the licensee (e.g., 4 overdue or missed surveil-lance tests) because of effective supervisory overview and control of testing, and do not therefore represent a significant trend because of the extensive scope and otherwise excellent test program record,

b. Fifteen LERs were attributed to design, manufacturing, !

construction or installation problems. The total number of events appear to be high, but eleven of the LERs were attributed to toxic gas detection systems. Unanticipated sensitivity to moisture and external environmental con-ditions was the principal cause of the events. The systems were modified during this assessment period and are in the process of further refinement.

c. LERs86-037, and 86-046 were events attributed to external causes. Both involved misoperation of the chlorine detec-tion probes during rain storms and high winds. The licensee is planning to relocate and protect the probes from moisture intrusion.

d. LERs86-011, 86-014,86-035, 86-040,86-041, 86-042,86-044, and 86-056 were events attributed to procedural deficiencies. The total number of LERs caused by proce-dure deficiencies dropped 25% from the last assessment period which reflects improvement based on the experiences gained throughout the current assessment period. Further human factors improvements incorporated in procedures at-the end of the assessment period should further reduce events attributable to procedural deficiencies, icluding communications breakdowns (LER Nos.86-016, 025, 032, and 047).

e. LERs86-013, 86-022,86-026, 86-031,86-045, 86-050, and 86-054 were events attributed to random component failure. This is a significant reduction from the 22 reportable events from the previous assessment period,

f. Nine LERs (Nos.86-006, 009, 017 thru 19, 027, 034, and 036) were associated with fire protection activities.

Seven of these involved inadequately controlled fire doors and barriers which warrant further management attention and increased emphasis in training. The frequency of these events increased concurrent with outage activities in May-June 1986, and therefore warrants particular atten-tion during the May 1987 refueling outage.

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'O E. Licensing Activities

1. NRR/ Licensee Meetings October 1,1986, Scheduling of Licensing Activities

2. Schedular Extensions Granted (Full Power' License Conditions)

Amendment No. I to the full power licensee granted a one-time extension of 14 weeks in the 18-month surveillance interval for leak rate testing of instrumentation line excess flow check valves. j Amendment No. 2 to the full power license granted a one-time extension of twelve weeks in the surveillance interval for leak rate testing of 27 containment isolation valves.

3. Exemptions Granted (Full Power License)

In conjunction with the issuance of Amendment No. 2 to the license, a one-time exemption from the scheduler requirements of 10 CFR Part 50 Appendix J for the leak rate testing of 27 containment isolation valves was granted.

4. Licenst Amendments Issued License Amendment Nos. I and 2, which extended the leak rate test surveillance intervals on containment isolation valves, were issued on February 6,1986 and tiarch 3, -1986, respectively.

5. Emergency Technical Specification Changes Granted License Amendment No. 3, which approved operation with a reduction of feedwater temperature of up to 60 Farenheit degrees and an increase of up to 105% in rated core flow was issued on February 17, 1987.

There were six outstanding requests for amendments to the Unit 1 full power license at the end of the assessment period.

s r

48 l

l TABLE 1 TABULAR LISTING OF LERS BY FUNCTIONAL AREA LIMERICK GENERATING STATION, UNIT NO. 1 I. LER by Functional Area Number by Cause Code Area A B C D- E X Total A. Plant Operations 9 11 2 2 3 2 29 B. Radiological Controls C. Maintenance 1 1 D. Surveillance 12 3 6 4 25 E. Engineering Support F. Emergency Preparedness G. Security and Safeguards H. . Training and Qualification Effectiveness I. Licensing Activities J. Assurance of Quality K. Other Totals 21 15 2 8 7 2 55 Cause Codes: A. Personnel Error B. Design, Manufacturing, Construction, or Installation Error C. External Cause D. Defective Procedure E. Component Failure X. Other i

1 i

, 49 l

TABLE 1(Continued]

l II. LER Synopsis LER Number- Cause Summary 86-002 A Unplanned Isolation of the Reactor Enclosure and Actuation of SGTS and RERS during testing due to Personnel Error 86-003 A Unplanned Closure of Shutdown Cooling Isolation Valve 86-004 8 Unplanned Isolation of the Reactor Enclosure and SGTS/RERS Initiation Due to Exhaust Fan Blade Pitch Instrumentation Imbalance 86-005 B Main Control Room Chlorine Isolation and Emergency Fresh Air System Actuation due to Analyzer Tape Break 86-006 A Late Performance of Fire Hose and Cart Visual Surveillance Tests86-007 8 Actuation of Control Room Emergency Fresh Air System due to Analyzer Tape Break 86-008 B Main Control Room Chlorine Isolation and Emergency Fresh Air System Actuation due to Analyzer Tape Discoloration 86-009 A Overdue Calibration of Remote Shutdown Panel Instruments86-010 A Feedwater Flow Transmitter Miscalibration -

Operation in Excess of Licensed Maximum Power Level 86-011 D Reactor Scram on High Neutron Flux due to Ground in EHC Circuit :

86-012 B RHR Service Water Radiation Monitor Loss of Isolation Capability on Downscale Failure 86-013 E Reactor Water Cleanup Isolations during Surveil-lance Testing 86-014 0 Reactor Enclosure Isolation due to Breach in Equipment Access Airlock l 86-015 B Chlorine Analyzer Tape Break and CREFAS Actuation i

_ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ . __ _ J

f

.o I 50 e l TABLE 1 Continued)

LER Number Cause Summary 86-016 A HVAC Isolation Trip Channel Inoperable for Greater than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months during Surveillance Testing 86-017 B Internal Fire Protection Seals Missing in Electrical Gutters ,

i 86-018 X Firewatch Violation due to Missing Penetration Plugs86-019 A Failure to perform Hourly Fire Watch due to Personnel Error 86-020 B Low Reactor Water Level Scram Due to Personnel !

Error and Unavailability of Automatic Feedwater !

Level Control Valve 86-021 A Actuation of SGTS due to Improper Use of Jumpers During Testing 86-022 E Manual Isolation of Main Control Room Ventilation and Emergency Fresh Air System Actuation due to High Toxic Chemical Concentration Alarm Caused by Detector Malfunction 86-023 A Division II ESF Actuation During Surveillance Test due to Personnel Error caused by Procedural Inaccuracy 86-024 A Unplanned Isolation of Reactor Enclosure HVAC and SGTS/RERS Initiation due to Personnel Error in Opening of Both Airlock Doors Simultaneously 86-025 A Isolation of Shutdown Cooling Caused by Communi-cation Error during Testing 86-026 E Unplanned Isolation of the Reactor Enclosure HVAC and SGTS/RERS Initation Due to a Blown Fuse from Unknown Cause in High Radiation Circuitry i

86-027 A Fire Watch Violation Due to Personnel Error in Propping Open Fire Door 86-028 B Control Room Emergency Fresh Air System Actuation due to False Toxic Gas Concentration Alarm Caused by Drywell Chiller Freon Venting

i 51 TABLE 1 Continued)

LER Number Cause Summary 86-029 B RPS/UPS Static Inverter De-Energized and Isolation of Instrument Gas Caused by an Incomplete Connec-tion on a Logic Card Connector during Transfer of Power Supplies86-030 A Personnel Error Caused Unplanned Group I MSIV Isolation Signal During Troubleshooting / Stroking Turbine Stop Valve 86-031 E Special Report - Combined Appendix J Type B and C Leakage Exceed Allowable Limits86-032 A Daily Surveillance Test Overlooked for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Due to Personnel Error / Insufficient Communication at Shift Turnover 86-033 8 Reactor Water Cleanup System Isolation on High Differential Flow Caused by Collapse of Steam Voids due to Piping Deficiency in Blowdown Configuration 86-034 A Open Fire Door for 5-1/2 hours Without a Posted l

Firewatch Due to Personnel Error While Performing l

HP Surveys86-035 D Failure to Comply with Technical Specification Action Due to Procedural Deficiency - Overdue Weekly IRM Channel Functional Surveillance Tests During Shutdown 86-036 A Delay of 20 Minutes in Performing Hourly Fire Watch for Five Barriers Due to Unscheduled Security Computer Outage and Inadequate Communications86-037 C Control Room Ventilation Isolation and Emergency Fresh Air System Actuation Due to Chlorine Analyzer j Malfunction l 86-038 A Primary Containment Isolation Valves Inoperable with Penetration Open 86-039 B Main Control Room Chlorine Isolations and Emergency Fresh Air System Actuations Due to Electroylte Probe 86-040 0 Reactor Water Cleanup System Isolations Due to High Regenerative Heat Exchanger Room Temperature Caused by Inadequate ventilation and Opening of a Pressure Relief Valve

52 0

TABLE 1 Continued)

'LER Number Cause Summary 1

1: 86-041 0 Deficient Surveillance Test Procedure in Verifying l Energized 480 VAC Safeguards MCC 86-042 D Incomplete Performance of Weekly Surveillance Test for Division IV DC Power Alignment Due to Personnel and Clerical / Duplication Errors and Procedural Deficiency 86-043 B Toxic Gas Detection System Vinyl Chloride Channel Dperating in Nonconservative Condition Due to Calibration Design Deficiency caused by High Humidity Effects86-044 0 Vinyl Chloride and AmmoniaToxic Gas Alarm Setpoints Reversed Due to Calibration Error 86-045 E Division II Isolations Due to Blown Fuse Caused by Improperly Fitted Test Leads and Personnel Errors86-046 C Main Control Room Chlorine Isolations & Emergency Fresh Air System Actuations Caused by High Winds /

Moisture Effects on Probes86-047 A RCIC Steam Supply Isolation during Testing Caused by Personnel Error and Inadequate Communications86-048 A RWCU Isolation During Return to Service of Demineralized Caused by Improper Valving Sequence and Personnel Error 86-049 B RWCU Isolation During Testing Due to Inaccessible Test Connections86-050 E Removal of HPCI from Service to Repair Steam Supply {

Isolation Valve 86-051 X Fire Watch Not Established for Missing Spare Electrical Conduit seal 86-052 A HPCI Steam Supply Isolation During Testing Caused by Personnel Error in Use of Calibrator Unit 86-053 A Group VI C Isolation Caused by Impropcr Instrument j Root Valve Manipulation by Non-Licensed Plant )

Operator

53 TABLE 1 Continued)

'LER Number. Cause Summan

.86-054 E Reactor Enclosure Isolation Caused by Improperly-Sized-Blown Fuse During SGTS Controller Replacement 86-055 B RCIC/ERFDS Temporary Cables Improperly Isolated and Protected in Raceway from Fire Damage, Affecting Safe Shutdown Capability 86-056 0 Inconsistency Between Centrol Rod Block and SDV Level Instruments Caused by Inadequate Surveillance Test Procedures I

.- _ _ _ _ . . _ . _ _ . _ - _ _ _ . _ _ . _ _ _ _ ___d

54 s

TABLE 2 INSPECTION HOURS

SUMMARY

(2/1/86 - 1/31/87)

LIMERICK GENERATING STATION, UNIT NO. 1 1

Hours % of Time A. Plant Operations. . . . . . . . . . . 974 35.0 B. Radiological Controls . . . . . ... 301 10.8 C. Maintenance . . . . . . . . . . . . . 362 13.0 D. Surveillance. . . . . . . . . . . . . 429 15.4 E. Engineering Support .

.. ..... 61 2.2 F. Emergency Preparedness. . . . . . . . 326 11.7 G. Security and Safeguards . ...... 328 11.8 H. Training and Qualification Effectiveness . . . . . . . . . . . .

I. Licensing Activities. . . ....

J. Assurance of Quality. . . . . . **

Total 2781 100.0 Hours expended in facility licensing activities and operator licensing activities not included with direct inspection effort statistics.

Hours expended in the areas of training and assurance of quality are included in other functional areas, therefore, no direct inspection hours are given for these areas.

l

55 TABLE 3 ENFORCEMENT

SUMMARY

(2/1/86 - 1/31/87)

LIMERICK GENERATING STATION, UNIT NO. 1 A. Number and Severity Level of Violations Severity Level No.

l Severity Level 3 0 l Severity Level 4 3 Severity Level 5 1 Deviation 1 Total 5 B. Violations vs. Functional Areas Severity Level FUNCTIONAL AREAS III IV V DEV TOTAL A. Plant Operations 1 1 1 3 B. Radiological Controls 0 C. Maintenance 0 D. Surveillance 0 E. Engineering Support 0 F. Emergency Preparedness 0 G. Security and Safeguards 2 2 Violation and Deviation Totals: 0 3 1 1 5 C. Summary - Enforcement Data Inspection Inspection Severity Functional Report N . Date Level Area Violation 86-17 7/21-31/86 4 Operations Failure to maintain chilled water containment isolation valve operability

e 56 l- TABLE 3 Continued)

Inspection Inspection Severity Functional Report No. Date Level Area Violation I

86-17 7/21-31/86 DEV Operations Inability to remotely close the outboard isolation valves on chilled water systems 86-19 9/16-19/86 4 Security Closed circuit camera deficiency 86-25 10/9 - 25/86 4 Security Failure to maintain safeguards information as prescribed in 10 CFR 73.21 87-02 1/5-9/87 5 Operations Failure to post a firewatch during grinding operations i

1 l

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l 57 a

TABLE 4 INSPECTION REPORT ACTIVITIES (2/1/86 - 1/31/87)

LIMERICK GENERATING STATION, UNIT NO. 1 Report / Dates Inspector Hours Areas Inspected 86-04 Resident 142 Routine 3/1/86 - 4/13/86 86-05 Specialist 39 Startup test program clasecut 2/24/86 - 2/28/86 86-06 Specialist 82 Follow-up on security program !

3/3/86 - 3/10/86 I l

86-07 Specialist 127 Emergency preparedness exercise 4/2/86 - 4/4/86 Team 86-08 Specialist 18 Radiological environmental 3/10/86 - 3/14/86 monitoring program 86-09 Resident 328 Routine 4/14/86 - 5/31/86 86-10 Specialist 26 Nonradiological chemistry 5/19/86 - 5/21/86 program 86-11 Resident 314 Routine 6/1/86 - 7/31/86 86-12 Specialist 38 Leak Rate Testing 5/27/86 - 5/30/86 1 1

86-13 Specialist 43 Radiation protection program i 5/22/86 - 5/30/86 86-14 Specialist 40 Effectiveness of QA and QC 5/30/86 - 6/5/86 activities 86-15 Specialist 68 Routine followup on security ;

7/1/86 - 7/11/86 items 86-16 Specialist 33 Technical Specification l 7/7/86 - 7/11/86 surveillance testing and I calibration program l

4

9 58 TABLE 4 Continued)

Report / Dates Inspector Hours Areas Inspected 86-17 Special 30 Assess cause and evaluate inoper-7/21/86 - 7/31/86 Resident ability of drywell chilled water containment isolation valves 86-18 Resident 211 Routine i 8/1/86 - 9/15/86

( 86-19 Specialist 26 Safeguards including 9/16/86 - 9/19/86 psychological testing program 86-20 Specialist 43 Maintenance programs 9/8/86 - 9/12/86 86-21 Specialist 64 Radwaste management 9/16/86 - 9/19/86 86-22 Specialist 51 Non-licensed staff training 9/22/86 - 9/26/86 86-23 Resident 285 Routine Inspection 9/16/86 - 11/26/86 86-24 Specialist 0 Licensed operator examinations 10/24/86 - 12/1/86 86-25 Special 53 Security issues 10/9/86 - 1/25/87 Resident 86-26 Specialist 39 Inspection of radiological water 11/3/86 - 11/7/86 chemistry control program 86-27 Resident 353 Routine 11/27/86 - 1/27/87 87-01 Specialist 175 Emergency preparedness exercise 1/14/87 - 1/16/87 Team 87-02 Specialist 40 Fire protection program 1/5/87 - 1/9/87 87-03 Specialist 31 Security program 1/6/87 - 1/9/87 87-04 Specialist 82 Radiological controls including 1/12/87 - 1/16/87 ALARA programs

9 59 TABLE 5 This is a sideways table in the system under SALP Limi 86-99 Table 5 i

o 60 figure 1 Number of Days Shutdown Limerick Generating Station, Unit No. 1 Feb. 86 ~~l 1 OAY SHUTDOWN

__l Mar. 86 Apr. 86 4

May 86 29 DAYS SHUTDOWN l l

June 86 16 DAYS SHUTOOWN l I

July 86 9 DAYS SHUTOOWN l l

Aug. 86 I

Sep. 86 Oct. 86 Nov. 86 Dec. 86 Jan. 87 l 5 DAY SHUTDOWN l

E

'O . [, , h< UNITED STATES ENCLOSURE 4-

. f f'. yN( -[ fc.

NUCLEAR REGULATORY COMMISSION D

REGIOM I .

' o, .

631 PARK AVENUE

- %..Q...,p[ KING OF PRUSSIA, PENNSYLVANIA 19406 05 JUN 1987 I-Docket No. 50-352

' Philadelphia Electric Company ATTN: Mr. J. W. Gallagher Vice President, Nuclear Operations

.2301 Market Street Philadelphia, PA 19101 Gentlemen:

Subject:

Systematic Assessment of Licensee Performance (SALP)

Report Number 50-352/86-99 On March 17, 1987, the NRC Region I SALP Board reviewed and evaluated the performance of activities associated with the Limerick Generating Station.

This assessment is documented in the enclosed SALP Board report. A meeting l- will be scheduled to discuss the assessment. That meeting is intended to provide a forum for Lindid discussions relating to the performance evaluation.

At the meeting, you should be prepared to discuss our assessment and your plans to ensure improved or continued emphasis upon those activities which would have a positive effect upon performance. Any comments you may have !

regarding our report may be discussed. Additionally, you may provide written comments within 30 days after the meeting.

J Following our meeting and receipt of your response, the enclosed report, your written response, if any, and a summary of our findings and planned actions will be placed in the NRC Public Document' Room.

Your cooperation is appreciated.

Sincerely, hh[

William T. Russell

_=4 Regional Administrator

Enclosure:

NRC Region I SALP Report No. 50-352/86-99 f

i L !,

mar 1% AnM -v - wr ~

\mgwy

j,. Philadelphia Electric Company 05 M 1987 cc: w/ encl John S. Kemper, Senior Vice President, Engineering and Production S. J. Kowalski, Vice President, Engineering and Research J. Franz, Manager Limerick Generating Station Troy B. Conner, Jr. Esquire Eugene J. Bradley, Esquire, Assistant General Counsel W. M. Alden, Engineer in Charge, Licensing Section Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania Chairman Zech Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Carr bcc w/ encl:

Region I Decket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

J. Linville, RI E. Kelly, SRI, Limerick Region I SLO l Robert J. Bores, DRSS W. Johnston, DRS T. Martin, DRSS J. Taylor W. Russell, RI J. Allan, RI D. Holody, RI K. Abraham, PA0 (2 copies)

Board Members l

l

Erclosure 5 SALP Board Report Errata Sheet The following changes have been incorporated into the Amended Report. The original page is not included as the changes are seen as being minor and editorial in nature.

PAGE LINE NOW READS SHOULD READ 29 12 license licensee Basis: Typing error 35 17 has have Basis: Grammatical error 40 17 te the Basis: Typing error i

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