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| {{Adams
| | #REDIRECT [[IR 05000352/1997007]] |
| | number = ML20198N177
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| | issue date = 10/27/1997
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| | title = Insp Repts 50-352/97-07 & 50-353/97-07 on 970722-0915. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support
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| | author name =
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| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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| | addressee name =
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| | addressee affiliation =
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| | docket = 05000352, 05000353
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| | license number =
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| | contact person =
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| | document report number = 50-352-97-07, 50-352-97-7, 50-353-97-07, 50-353-97-7, NUDOCS 9711030182
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| | package number = ML20198N168
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| | document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
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| | page count = 42
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| }}
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| See also: [[see also::IR 05000352/1997007]]
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| =Text=
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| {{#Wiki_filter:_ . _ . ._ _ . _ , _ - . . . _ . - _ . _ _ _ _ _ _ _ _ _ _ _ _ . . _ . _ _ . _ . - _ . _ _ . _ . _ _ _ . _ . _ _ _ .
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| U.S. NUCLEAR REGULATORY COMMISSION
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| <
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| REGION I
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| I
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| 4
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| Docket Nos. 50 352
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| i 50 353 i
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| ; License Nos. NPF39
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| NPF 85 l
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| Report Nos. 97 07
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| 97 07
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| Licensee: PECO Energy
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| .
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| Facilities: Lirnc:,ck Generating Station, Units 1 and 2
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| Location: Wayne, PA 19087 0195
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| Dates: July 22,1997 through September 15,1997
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| Inspectors: N. S. Perry, Senior Resident inspector
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| R. L. Fuhrmeister, Project Engineer
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| L. L. Eckert, Radiation Specialist
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| R. M. Latta, Operations Engineer, NRR
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| L. L. Campbell, Senior Operations Engineer, NRR
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| Approved by: ,
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| Clifford Anderson, Chief
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| Projects Branch 4
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| Division of Reactor Projects
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| 2 ,,.
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| -___ _-_ _
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| EXECUTIVE SUMMARY
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| Limerick Generating Station, Units 1 & 2
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| NRC Inspection Report 50 352/97 07, 50 353/97-07
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| .
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| This integrated inspection included aspects of PECO Energy operations, engineering,
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| maintenance, and plant support. The report covers an 8 week period of resident
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| inspection.
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| Ooerotions
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| * Since a number of valves were identified as inadequately locked as required, a
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| programmatic problem existed concerning how valves are locked and independently
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| verified as adequately locked. Immediate corrective actions taken of verifying all
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| .
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| accessible valves listed in the Locked Valve List, as adm ately locked were good.
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| (Section 02.1)
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| % The reactor water clean-up (RWCU) system automatically isolated due to a high
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| differential flow condition while restoring a filter demineralizer to service. The high
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| differential flow condition was caused by the B RWCU filter domineralizer Y strainer
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| manual drain va!ves leaking into the backwash receiving tank. The affected valves
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| were adjusted, and the filter domineralizer was returned to service; no other
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| ; comparable valves were found leaking on Unit 1 or Unit 2. Additionally, on August
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| 6, for Unit 2, and September 10, for Unit 1, there were a number of RWCU
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| luolations. This large number of isolations over a fairly short period of time was a
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| , challenge for the operators. These concerns regarding the RWCU systems for both i
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| units will remain as an inspector follow up item, pending review for common cause
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| issues and maintenance rule implications. (Section 08.2)
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| Maintenance
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| e Observed maintenance activities were conducted well using approved procedures or
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| work instructions, and were completed with satisfactory results. Communications
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| between the various work and support groups were good, and supervisor oversight
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| was good. (Section M1.1)
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| e in general, surveillances were performed by knowledgeable personnel, and were
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| satisfactorily completed. In particular, very good system manager support for the
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| Unit 1 reactor core isolation cooling (RCIC) test; also noted was the knowledge level
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| of the attending equipment operator for the RCIC pump run. Overall, surveillance
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| tests were conducted well using approved procedures, and were completed with
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| satisfactory results. Communications between the various work and support groups
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| were good, and supervisor oversight was good. (Section M1.2)
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| e Proper actions woro taken to ensure that a TS required voltage verification was met,
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| once it was discovered to be potentially missed. However, personnel did not
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| properly track the missed surveillance step to ensure that it was completed when
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| the clearance was removed. Additionally, the engineering review which concluded
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| 1
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| Executive Summary l
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| that the TS tequirement had been met by an alternate means appeared weak.
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| (Section M1.3)
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| *
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| Personnel identified foreign materialin the high pressure coolant injection (HPCI)
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| turbine exhaust drain pot drain line which rendered the HPCI system inoparable
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| since an undetermined amount of condensed water was present in the HPCI turbine.
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| This resulted in a violation of the foreign material exclusion (FMEl program. (Section
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| M8.1)
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| Enaineerina I
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| * Actions taken to address each 021 test failure have been appropriate. Although no
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| clear tie between the f ailures has been determined, investigations continue.
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| (Section E1.2)
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| * Operators appropriately declared three EDGs inoperable when they became aware of
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| a potentlat problem with the fuel oil due to a high cloud point. The EDGs were -
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| declared operable later the same day after it was shown that the oilin the storage
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| tanks was below the cloud point maximum. However, documentation for the
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| operability datermination was weak,in that various work groups had to be
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| contacted to get all of the facts of the operability determination. (Section E1.2)
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| Plant Suncort
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| * The licensee maintained and implemented good routine radioactive liquid and
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| gaseous effluent control programs. Tne radiation monitoring system (RMS)
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| calibration program was good, as were the ventilation system surveillance program
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| and Quality Assurance and Quality Control programs. Several opportunities were
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| identified in which RMS system tracking and trending could be improved.
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| * Fire protection procedures were found to provide adequate guidance and appropriate
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| acceptance criteria for testing fire protection equipment. (Section F3.1)
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| * Station personnel identified that a potential voltage mismatch may exist between a
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| fire protection deluge valve and its control panel, resulting in marginal power
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| available to operate the valve. An evaluation concluded that a technical
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| specification noncompliance occurred between issuance of the facility operating
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| license for Unit 1 on October 26,1984, and December 20,1995, when the
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| technical specifications were relocated to the Technical Requirements Manual, since
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| the valve may have been unable to perform its design function. Corrective actions
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| included making adjustments to the valve to optimize mechanical operation, posting
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| a continuous firewatch, increased testing of the valve, and the valve was replaced
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| on September 3,1997. This violation had more than minor significance since it
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| resulted in a condition where a technical specification-required deluge valve was
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| inoperable for an extended period of time and resulted in a non-cited violation. The
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| safety consequences for this event were low. (Section F8.1)
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| ._ . . . _ . __ . _ . . - _ . -
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| TABLE OF CONTENTS
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| S u m m a r y o f Pl a nt S t a t u s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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| 1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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| 01 C ond uct o f O p e ration s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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| 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . 1
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| 02.1 Control ei Locked Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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| 07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
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| 07.1 Self. Assessment Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
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| 08 Miscellaneous Operations issues . . . . . . . . . ........................ 3
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| 08.1 (Closed) LER 2 97 008, Automatic Closure of Drywell Chilled Water
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| System Primary Containment isolation Valves, An ESF Actuation,
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| Resulting From Emeigency Diesel Generator Voltage Regulation Failure . 3
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| 08.2 (Closed) LER 2 97 009, Reactor Water Clean-up (RWCU) Isolation, An
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| ESF, Caused by a RWCU Filter Der.iineralizer Y Strainer Manual Drain
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| Valves Leaking into the Backwash Receiving Tank . . . . . . . . . . . . . . . . 3.
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| II . M aint e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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| M1 Conduct of Maintenance ....................................... 4
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| M 1.1 General Comments on Maintenance Activities . . . . . . . . . . . . . . . . . . . 4
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| M1.2 General Comments on Surveillance Activities . . . . . . . . . . . . . . . . . . . . 5
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| M1.3 Potential Missed Surveillance Test ........................... 6
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| M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
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| M 8.1 (Closed) LER 2 97 007 Unit 2 HPCI System inoperable Due to
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| Clogged Turbine Exhaust Drain Line .......................... 7
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| Ill. Engineering ................................................... 7
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| E1 Conduct of Engineering ........................................ 7
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| E 1,1 D21 Emergency Diesel Generator issues ....................... 7
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| E1.2 Emocqancy Diesel Generator High Cloud Point Response . . . . . . . . . . . . 8
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| E7 Quality Assurance on Engineering Activities . . . . . . . . . . . . . . . . . . . . . . . . . . 9
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| E 7.1.1 Review of PECO Audits and PECO's Use of Third Party Audits . . 10
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| E 7.1.2 Review of Commercial Grade Surveys . . . . . . . . . . . . . . . . . . . 14
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| E7.1.3 Purchase Order Revision Controls . . . . . . . . . . . . . . . . . . . . . . 15
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| I V . Pl a n t S u p p o r t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
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| iv
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| _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____ __
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| Table of Contents
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| R1 Radio'ogical Protection and Chemistry (RPF s Controls . . . . . . . . . . . . . . . . . 17
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| R1.1 Implementation of the Radioactiv< :id and Gaseous Effluent
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| ControI Programs . . . . . . . . .
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| ............ ............. 17
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| R2 Status ot RP&C Facilities and Eoulpment . ......................... 18
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| R2.1 Calibration of Effluent / Process / Area / Accident Radiation Monitoring
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| Systems (RMS) ..............................
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| ......... 18
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| R2.2 Air Cle aning Syste ms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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| R7 Quality Assurance (CA) in RP&C Activities . . . . . . . . . . . . . . . . . . . . . .... 20
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| F1
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| Control of Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
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| F1.1 Main Control Room Fire Suppression System . . . . . . . . . . . . . . . . . . . 21
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| F2 Status of Fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . 22
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| F2.1
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| in Plant Walkdo wns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
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| F3 i
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| Fire Protection Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . 24 l
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| F3.1 Procedure Upgrade Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
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| F6 Fire Protection Organization and Administration . . . . . . . . . . . . . . . . . . . . . . 28 i
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| F6.1
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| Fire Prote ction Council . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
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| F6.2 Fire Protection Focused improvement Team . . . . . . . . . . . . . . . . . . . . 29
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| F8 Miscellaneous Plant Support issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
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| F8.1 (Closed) LER 1 97 006, Previous Condition Prohibited by Tech Specs
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| in thrt a Fire Protaction System Deluge Valve may not have
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| Funedoned per Design Since issuance of the Unit 1 Operating License . 30
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| V. Management Meetings . . . . . . . . . . . . . . . . .......................... 30
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| X1 Exit Maeting Sum mary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
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| X2
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| Review of UFS AR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
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| INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
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| ITEhnS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
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| LIST O F ACRO NYM S USE D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
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| LIST O P DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
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| Report Details
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| Summary of Plant Status
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| Unit 1 began the inspection period operating at 100 percent power. The unit remained at
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| 4 full power throughout the inspection period with minor exceptions for testing and the
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| following events:
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| f
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| e August 31 Operators reduced reactor power to 60 percent following a
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| loss of one control rod's position during the weekly control rod
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| exercise test. After fully inserting the control rod, the unit
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| returned to 100 percent power on September 1.
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| ~
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| o September 12 Operators reduced reactor power to approximately 60 percent
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| to perform a control rod sequence exchange, to scram time
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| 1 test control rods, and to work on the A reactor feed pump.
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| The unit was returned to 100 percent power on September 14,
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| after completion of the activities.
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| , Unit 2 %gon the laspection period operating at 100 percent power. The unit remained at
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| j full power throughout the inspection period with minor exceptions for testing and the
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| following event:
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| e August 11 Operators reduced reactor power to 97 percent after a steam
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| leak was identified at the main turbine first stage pressure
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| '
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| switch. The switch was isolated and power was returned to
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| 100 percent the same day.
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| ) 1. DoeratioDE
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| 01 Conduct of Operations'
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| 01.1 General Comments (71707)
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| Using Inspection Procedure 71707, the inspectors conducted freque:it reviews of
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| ongoing plant operations, in general, PECO Energy's conduct of operations was
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| professional and safety conscious.
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| 02 Operational Status of Facilities and Equipment
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| 02.1 Control of Locked Valves
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| a. insoection Scoos (71707)
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| During this inspection period, the inspector identified instances where valves,
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| required to be locked to restrict operation, were not adequately locked.
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| . ' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report
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| outline. Individual reports are not expected to address all outline topics.
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| 2 l
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| Additionally, operations personnel idantified other similarly inadequately locked
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| valves. Immediate corrective actions were discussed with operations personnel.
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| b. Observations and Findinas
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| On August 18, the inspector identified a Unit 1 C core spray valve (0521F016C,
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| seal vent to drain) which appeared to be inadequately locked in that the chain
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| around the valve handwheel had a large amount of slack in it. After checking the
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| other Unit 1 core spray pumps, the inspector notified control room operators of the .
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| valve. Operators subsequently tightened up the chain. On August 20, the l
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| inspector identified two analogous core spray valves on Unit 2 with an excess of
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| slack in the chain. Again control room operators were notified and the valve chains
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| were tightened. On August 22, the inspector discussed the locking of valves with
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| plant management, and noted that the operators should have checked the other
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| unit's core spray valves when one was identified as deficient; plant management
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| was in agreement. On August 26, the inspector performed a walkdown of the Unit
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| 1 reactor building to determine if other valve locking devices were adequate; the
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| inspector performed a similar walkdown of the Unit 2 reactor building on August
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| 27. A significant number of valves were identified as potentially inadequately
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| locked. After verifying that the valves were required to be locked, the inspector
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| notified control room operators of the concern that there may be a number of valves
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| in the plants which are inadequately locked.
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| During the next several days, operations personnel walked down all accessible
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| valves listed on the Locked Valve List to determine the extent of the problem. No
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| valves were identified as out of the required position. However, a number of valves
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| were identified as either inadequately locked or in need of tightening up of the
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| locking mechanisms. Prior to the end of the inspection period, all accessible valves
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| required to be locked were appropriately verified as adequately locked. No further
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| discrepancies were identified by the inspector.
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| Limerick administrative procedure A C-000, Centrol of Locked Valves and Devices,
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| Revision 0, requires in part, that the lock.ou .: be applied through the
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| handwheel or other operating mechanism to restrict operation of the valves and
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| devices listed in the Locked Valve List. Additionally, the procedure notes that the
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| intent of the locking device is for administrative control over the position of
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| specified valves and devices, and 'he component should be locked so as to prevent
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| excessive movement. During thie qspection period, the inspector and subsequently
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| operators identified a number of valves which were not adequately locked as
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| required by administrative procedure A C 008. This is a violation. (VIO 50 352.
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| 353/97 07 01)
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| c. Conclusions
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| Since a number of valves were identified as inadequately locked as required, a
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| programmatic problem existed concerning how valves are locked and independently
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| verified as adequately locked, immediate corrective actions taken of verifying all
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| accessible valves listed in the Locked Valve List, as adequately locked were good,
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| 3
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| 07 ' Ouality Assurance in Operations
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| 07.1 Self-Assessment Activities (71707)
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| During the inspection period, the inspectors reviewed or attended various self-
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| )
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| ..
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| assessment activities, including:
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| -
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| various Plant Operations Review Committee (PORC) meetings and meeting
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| minutes
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| -
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| the quarterly Nuclear Review Board (NRB) meeting on September 4
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| -
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| various quality verification and independent safety engineering group reports
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| The inspectors noted in particular that at the NRB meeting, members thoroughly
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| !
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| reviewed plant events and appropriately questioned plant management concerning
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| root causes and corrective actions. The NRB members actively participated in the
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| meeting with open discussions of the issues, while maintaining a focus on safety. l
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| 08 Miscellaneous Operations issues (90712)
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| 08.1 (Closed) LER 2 97 008. Automatic Closure of Drvwell Chilled Water System Primarv
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| ; Containment isolation Valves. An ESF Actuation. Resultino From Emeroency Diesel
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| Generator Voltaae Reaulation Failure.
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| This Licensee Event Report (LER) concerned an instance where a relay failure
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| associated with an electrical bus overvoltage condition, which was caused by an
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| EDG voltage regulation failure, caused the automatic closure of drywell chilled water
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| system primary containment isolation valves. The event occurred during
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| performance of a special test for the D21 EDG. The cause of the relay failure was
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| determined to be a coil failure that resulted from the excessive voltage of the event;
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| ; no other loads connected to the bus were found to be adversely affected. The
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| drywell chilled water system valves were reopened and declared operable when the
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| f ailed control circuit relay was replaced. Troubleshooting, maintenance , and testing
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| were completed on the D21 EDG. The EDG voltage regulator's failed rectifier bank
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| i
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| was swapped to an alternate rectifier bank and tested satisfactorily; the EDG was
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| then restored to an operable condition. The defective rectifier bank will be shipped
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| offsite for failure analysis. The LER met the requirements of 10 CFR 50.73, and the
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| ,
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| inspector had no further questions regarding the event.
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| 08.2 (Closed) LER 2 97-009. Reactor Water Clean-uo (RWCU) Isolation. An ESF. Caused
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| by a RWCU Filter Demineralizer Y Strainer Manual Drain Valves Leskina into the
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| .
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| Backwash Receivina Tank.
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| This LER concerned an instance where the RWCU system automatically isolated due
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| to a high differential flow condition while restoring a filter demineralizer to service.
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| The high differential flow condition was caused by the B RWCU filter domineralizer
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| Y strainer manual drain valves leaking into the backwash receiving tank. The
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| affected valves were adjusted, and the filter demineralizer was returned to service;
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| I no other comparable valves were fouvf leaking on Unit 1 or Unit 2. The LER met
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| - _- _
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| 4
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| the requirements of 10 CFR 50.73, and the inspector had no further questions
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| regarding the event. However, the inspector noted that on August 6, for Unit 2,
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| and September 10, for Unit 1, there were a number of RWCU isolations. The
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| inspector was concerned that this large number of isolations over a fairly short
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| period of time was a challenge to the operators. The inspector was also concerned
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| that these events could indicate less than adequate maintenance or engineering
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| attention of the systems or less than adequate management attention. These
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| concerns regarding the RWCU systems for both units will remain as an inspector
| |
| follow up item, pending review for common cause issues and maintenance rule
| |
| implications. (IFl 50 352,353/97 07 02)
| |
| II. Maintenance
| |
| M1 Conduct of Mainten6nce
| |
| M1.1 General Comments on Maintenance Activities (62707)
| |
| a. Insoection Scoos (62707)
| |
| i
| |
| l The inspectors observed selected maintenance activities to determine whether
| |
| approved procedures were in use, details were adequate, technical specifications
| |
| were sat;sfied, maintenance was performed by know!edgeable personnel, and post-
| |
| maintenance testing was appropriately completed.
| |
| The inspectors observed portions of the following work activities:
| |
| -
| |
| Unit 2 Standby Liquid Control tank level sensing line cleaning, on August 27
| |
| -
| |
| D21 Emergency Diesel Generator fuelline replacement, on August 29
| |
| -
| |
| Replacement of Unit 1 fire protection deluge valve 173, on September 2
| |
| -
| |
| Unit 2 reactor core isolation cooling (RCIC) valve work, on September 9
| |
| -
| |
| Unit 1 RCIC governor va!ve servo replacement, on September 11
| |
| b. Observations and Findinas
| |
| For the standby liquid control (SLC) tank level sensing line cleaning, the inspector
| |
| noted that the work was well coordinated between the maintenance personnel and
| |
| control room operators. During the cleaning process, the inspector identified a
| |
| chain and lock around the instrument tubing on top of the SLC tank. This was
| |
| >
| |
| brought to the attention of operations personnel, who were unable to identify the
| |
| source of the lock; no locks or devices were identified in the area as missing a lock
| |
| and chain. Operations personnel concluded that the chain and lock must have been
| |
| inadvortently left there from a previous activity; operators removed the chain and
| |
| lock from the top of the tank. The inspector independently tried to determine if any
| |
| valves or devices in the area were missing a chain and lock; none were identified.
| |
| Additionally, the Unit 1 SLC tank was inspected, and no similar conditions were
| |
| identified. The inspector agreed with the operator's conclusion as the most likely
| |
| source of the chain and lock.
| |
| . . , a
| |
| | |
| _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - _ - _ _ _ _ .
| |
| _-__-
| |
| 5
| |
| For the Unit 1 RCIC governor valve servo replacemer t, the inspector observed that
| |
| there was very good system manager interface with the operators and the >
| |
| maintenance personnel. The inspector noted that although the location of the servo
| |
| is difficult to reach with some climbing required, the work was completed without
| |
| incident.
| |
| c. Conclusions
| |
| Overall, the inspector concluded that the observed maintenance activities were
| |
| conducted well using approved procedures or work instructions, and were
| |
| completed with satisfactory results. Communications between the various work
| |
| and support groups were good, and supervisor oversight was good.
| |
| M1,2 General Comments on Surveillance Activities (61726)
| |
| a. Insoection Scone (61726)
| |
| The inspectors observed selected surveillance tests to determine whether approved
| |
| procedures were in use, details were adequate, test instrumentation was properly
| |
| calibrated and used, technical specifications were satisfied, testing was performed
| |
| by knowledgeable personnel, and test results satisfied acceptance criteria or were
| |
| properly dispositioned.
| |
| The inspectors observed portions of the following surveillance activities:
| |
| -
| |
| D21 Emergency Diesel Generator (EDG) weekly, on August 14, 21, 28, and
| |
| September 4
| |
| -
| |
| D13 EDG monthly, on August 19
| |
| -
| |
| Unit 1 Standby Uquid Control pump, valve and flow, on August 25
| |
| -
| |
| Unit 2 B Residual Heat Removal pump, valve and flow, on September 4
| |
| -
| |
| Unit 1 RCIC pump, valve and flow, on September 10
| |
| -
| |
| D23 EDG monthly, on September 10
| |
| -
| |
| Unit 2 RCIC pump, valve and flow, on September 12
| |
| b. Observations and Findinos
| |
| in general, the inspector observed that the surveillances were performed by
| |
| knowledgeable personnel, and were satisfactorily completed. In particular, the
| |
| inspector observed very good system manager support for the Unit 1 RCIC test;
| |
| also noted was the high level of system knowledge of the attending equipment
| |
| operator for the RCIC pump run.
| |
| c. Conclusions
| |
| Overall, the inspector concluded that observed surveillance tests were conducted
| |
| well using approved procedures, and were completed with satisfactory results.
| |
| Communications between the various work and support groups were good, and
| |
| supervisor oversight was good.
| |
| | |
| _. -. - -.- .-. _ . , _ - . _ -. . - . - - . - -
| |
| 1
| |
| 6
| |
| M1.3 Potential Missed Surveillance Test (61726)
| |
| a. Insoection Scooe (61726)
| |
| The inspector reviewed an instance where a technical specification required
| |
| surveillance test was apparently missed on July 18. The inspector reviewed the
| |
| operations logs concerning the surveillance, reviewed the surveillance test,
| |
| reviewed the engineering justification for how the testing requirement was
| |
| alternately met, and discussed the situation with appropriate plant persor.nel.
| |
| b. Observations and Findinas ,
| |
| !
| |
| On July 16, a portion of weekly surveillance test ST 6 094 450 0,120 VAC I
| |
| Safeguard Power Distribution Alignment and Voltage Check, could not be performed I
| |
| due to a clearance on a distribution panel (03Y501).- The procedure step, which
| |
| required verification of 120 VAC nominal voltage at the panel, could not be
| |
| completed since the panel was deenergized. it appears that when it was identified
| |
| that the surveillance test step could not be completed, the clearance should have
| |
| been annetated to indicate that when the clearance was removed, the missed
| |
| procedure step should be completed to meet the technical specification (TS)
| |
| requirement. Apparently, this was not done, and the clearance was removed
| |
| without performing the voltage verification afterwards.
| |
| On July 18, plant personnel identified that the surveillance had apparently been
| |
| missed, and that the TS requirement had not been met. The surveillance test step
| |
| was immediately performed satisfactorily, thereby satisfying the TS requirement.
| |
| Engineering personnel determined, on July 18, that the TS requirement had bean
| |
| met by an alternate means; apparently on July 17, dampers were successfully
| |
| stroked, which are powered from the distribution panelin question.
| |
| Technical Specification 4.8.3.1 requires, in part, that specified power distribution
| |
| system divisions shall be determined energized at least once per 7 days by verifying
| |
| correct breaker alignment and voltage on the panels: 120 VAC distribution panel
| |
| 03Y501 is one of the specified panels. Surveillance test procedure ST 6 094-450-
| |
| O, step 4.5.3 requires verification of 120 VAC nominal voltage present at panel
| |
| OCC564, which verifies that distribution panel 03Y501 is energized. It was not
| |
| clear to the inspector that successfully cycling dampers properly verified 120 VAC
| |
| nominal voltage present at the panel. Subsequent to this, the operators who
| |
| restored the distribution panel pointed out that they had properly verified the panel
| |
| vcitage during the restoration, even though they were not directed to; therefore, the
| |
| technical specification surveillance requirement was met,
| |
| c. Conclusions
| |
| Proper actions were taken to ensure that a TS required voltage verification was met,
| |
| once it was discovered to be - 'stially missed. However, personnel did not
| |
| properly track the missed su- ance step to ensure that it was completed when
| |
| the clearance was removed. Additionally, the engineering review which concluded
| |
| that the TS requirement had been met by an alternate means appeared weak.
| |
| . _ . - - - , - .
| |
| -
| |
| | |
| l
| |
| I
| |
| !
| |
| 7 I
| |
| M8 Miscellaneous Maintenance issues (90712)
| |
| M8.1 (Closed) LER 2 97 007 Unit 2 HPCl System inocerable Due to Cloaaed Turbine
| |
| Exhaust Diain Line
| |
| This LER concerned an instance where the Unit 2 HPCI system was declared incperable
| |
| due to the failure of a routine test; the test concluded that the HPCl turbine exhaust drain
| |
| pot orifice was clogged. This rendered the HPCI system inoperable since personnel could
| |
| not determine how much water was present in the HPCI turbine. The blockage was
| |
| identified during performance of a quarterly surveillance test designed to verify that the
| |
| drain line is not blocked. The immediate corrective action was to disassemble and clean ;
| |
| the drain line; a small piece of cloth was found block!ng the drain line. Ercineering ]
| |
| personnel concluded that since no water was found in the drain line, HPCI would have
| |
| perfortned its intended function and was therefore available. Planned corrective actions
| |
| included: evaluation of tasks to ensure appropriate foreign material exclusion (FME)
| |
| prsctices are specified, evaluation of the HPCI system for increased monitoring in
| |
| accordance with Limerick's Maintenance Rule Program, communication of this event to
| |
| appropriate personnel, and review of FME Program enhancements in progress to ensure
| |
| that the circumstances of these events are addressed by planned actions. Plant
| |
| management concluded that the foreign material was most likely introduced during the
| |
| system work performed during the refueling outage in February 1997, due to less than
| |
| adequate implementation of PECO Nuclear's FME program. Administrative procedure A C-
| |
| 131, Foreign Material Exclusion, requires in part that FME control recommendations be
| |
| defined and included in the work package, and that workers shall understand and adhere to
| |
| FME requirements. This violation of the FME program had more than minor significance
| |
| since it caused the HPCI system to be inoperable, and was programmatic since it required
| |
| broader corrective actions to address identified issues associated with the control of FME.
| |
| (VIO 50 353/97 07 03)
| |
| lli. Enaineerina
| |
| E1 Conduct of Engineering
| |
| E1.1 D21 Emeroency Diesel Generator issues (37551)
| |
| Lnsoection Scoce
| |
| During this inspection period and going back several months, the inspector noted a
| |
| number of issues concerning the D21 EDG. This EDG has been oa an increased
| |
| frequency testing since early July 1997. The inspector discussed the D21 EDG
| |
| failure with engineering personnel, reviewed the associated test failure special
| |
| reports, and observed a number of D21 surveillance tests.
| |
| b. Observations and Findinas ,
| |
| During this inspection period, D21 had two test failures, one on July 26, and the
| |
| other on August 28. There have been two other D21 test failures in 1997, one on
| |
| January 1, and the other on July 3. The July 3, test failure resulted in increasing
| |
| | |
| ______ _-_____ -
| |
| -
| |
| 3
| |
| the technical specification test frequency from monthly to weekly. The two
| |
| additional failures since than have iesulted in extending the time period for the
| |
| increased frequency testing. The July 3, failure is suspected to be related to
| |
| problems ast.ociated with the govemore; both the electronic and mechanical
| |
| governors were replaced and the old ones were returned to the manufacturer for
| |
| failure analysis. The July 26, failure was du' '.o one of the two rectifier banks
| |
| malfunctioning; this rectifier bank was also sent out for failure analysis. The August
| |
| 28, failure was due to a significant fuel oA leak on the fuel oil return header tube.
| |
| The tube's support was found to be loose, which resulted in the tubing rubbinq on a
| |
| jacket water pipe elbow, due to engine vibration; the tubing wore through, causing
| |
| the iaak. The damaged section of tubing was replaced and successfully pressure
| |
| tested, all similar tubing supports for all eight EDGs wcre inspected and tightened as
| |
| ,
| |
| necessary, the repaired D21 tubing will be replaced during the next overhaul
| |
| I
| |
| (scheduled for later in 1997), and an rassessment of tubing supports will be
| |
| performed to investigate the modification or replacement of the tubing supports to
| |
| l
| |
| provide a more positive clamp of the tube and prevent rotation of the support,
| |
| Through discussions with engineering personnel, the inspector determined that the
| |
| EDus are currently classified as a Maintenance Rule Al system, which results in
| |
| increased management attention to the system. Although the EDGs were already
| |
| j an A1 system, the fuel oil tubing failure was classified as a maintenance
| |
| i
| |
| preventable functional failure, which would result in an evaluation to determine if
| |
| the system should be classified as an A1 system. Currently the EDGs are getting
| |
| increased attention from management, engineering and maintenance personnel.
| |
| '
| |
| Additionally, the inspector noted that the D21 EDG is scheduled for an 18 month
| |
| overhaul inspection late this year. One of the issues engineering personnel plan to
| |
| address is the vibration of the engine; although D21's vibration is within the
| |
| acceptable range, it is higher the all of the other EDGs. No clear tie has been
| |
| identified between the failures on D21 at this time; however, results of the failure
| |
| analyses may provide additional information,
| |
| c. Conclusions
| |
| Actions taken to address each D21 test failure have been appropriate. Although no
| |
| clear tie between the failures has been determined, investigations continue.
| |
| E1.2 Emeraency Fasel Generator Hioh Cloud Point Resoonse (37551)
| |
| a. Insoection Scoos
| |
| On August 12, operations personnel were notified of an unsatisfactory tost result
| |
| for the EDG fuel oil clouc' point. Specifically, the cloud point maximum is 17
| |
| degrees Fahrenheit, whereas the tested cloud point for fuel oil delivered on July 17,
| |
| 18, and 22 was 18 degrees Fahrenheit. The inspector reviewed the actions taken
| |
| by plant personnel to verify that the affected EDGs were operable.
| |
| i
| |
| ---__w
| |
| | |
| 9
| |
| b. Observations and Findinas
| |
| After operations personnel were notified of the out of specification fuel oil test
| |
| results, they declared the affected EDGs inoperable; one Unit 1 EDG (D13) and two
| |
| Unit 2 EDGs (D21, D23) were affected by the test results. Technical specifications
| |
| require that within 31 days of obtaining the fuel oil sample the specified properties
| |
| be verified as met; cloud point is one of the specified properties. For the above
| |
| event, the fuel oil was sampled on July 17,18, and 22, and the results were made
| |
| known to operations personnel on August 12. Once the EDGs were declared
| |
| inoperable, the operators, in conjunction with engineering and chemistry personnel,
| |
| devised a plan to determine if the EDGs were inoperable based on the fuel oil
| |
| storage tank oil cloud point. The fuel oil storage tanks were sampled, and the
| |
| results were immediately tested for cloud point; all were found to be well below the
| |
| maximum level. Since the sample might not be a true representation of overall tank
| |
| cloud point, since the tank could not be easily recirculated and mixed, chemistry
| |
| personnel analytically determined that the storage tanks' cloud points were
| |
| acceptable. This was easily accomplished since only a few thousand gallons of
| |
| unacceptable fuel oil was added to tens of thousands of existing fuel oil with quite a
| |
| bit of margin to the cloud point maximum. The three EDGs were declared operable
| |
| late on August 12.
| |
| On August 13, when the inspector tried to review the operability determination for
| |
| declaring the EDGs operable, no good documentation could be located. Only after
| |
| discussing the event with operations, engineering and chemistry personnel, could
| |
| the inspector get the complete story as to why the EDGs were declared operaole.
| |
| Operations management agreed that a better job of documentation could have been
| |
| -
| |
| done,
| |
| c. Conclusions
| |
| Operators appropriately declared three EDGs inoperable when they became aware of :
| |
| a potential problem with the fuel oil due to a high cloud point. The EDGs were
| |
| declared operable later the same day after it was shown that the oil in the storage
| |
| tanks was below the cloud point maximum. However, documentation for the ;
| |
| operability determination was weak,in that various work groups had to be i
| |
| contacted to get all of the facts of the operability determination.
| |
| E7 Quality Assurance on Engineerlag Activities (38701)
| |
| During this reporting period the inspectors evaluated selected aspects of PECO's I
| |
| procurement program in ceder to confirm that the licensee was effectively l
| |
| implementing a OA program to ensure that safety related items were in '
| |
| conformance with reguletory requirements, licensee commitments and industry
| |
| standards. Specifically, the inspectors reviewed PECO's governing procedural
| |
| controls contained in procedures P-C-7," Services Requisition Process," Revision 2,
| |
| and P-C-9, " Evaluated Vendor List," Revision 1, as well as selected procurement
| |
| purchase orders, the supporting documentation and the associated audit reports.
| |
| Within this area the inspectors examined the audit reports used by PECO for
| |
| l
| |
| | |
| 10
| |
| l
| |
| qualifying and maintaining Quality Systems, Inc. (OSI) on its Evaluated Vendors List
| |
| i
| |
| (EVL), as well as the audit of Continental Technical Services (CTS). The inspectors 1
| |
| also performed a limited review of the commercial grade item survey of Dryden Oil
| |
| Company.
| |
| E7.1.1 Review of PECO Audits and PECO's Use of Third Party Audin
| |
| 1. Review of the 1992 PECO Audit Report for OSI
| |
| The inspectors performed a partial review of the 1992 PECO audit of OSI that was
| |
| conducted February 26 27,1992, at OSI's Birdsboro, PA facility (Reference: PECO
| |
| Audit Report No. VA A 174937, dated March 24, 1992). This audit assessed OSl's
| |
| pedormance relative to the conducting utility subcontractor audits, surveillances
| |
| snd inspections. The scope of the audit appeared to be acceptable for the services
| |
| being provided with the exception that there was no documentation to support
| |
| PECO's decision not to review the areas of order entry (the processing of incoming
| |
| safety-related customer purchase orders) and procurement.
| |
| 2. Review of PECO's Use of the 1994 Duquesne Audit Heport for OSI
| |
| The inspectors also reviewed PECO's use of a 1994 Nuclear Procurement Issues
| |
| Committee (NUPIC) joint audit of OSI for the purposes of maintaining OSI on the
| |
| PECO EVL. The audit scope was limited to inspection and auditing services
| |
| provided by OSI to the nuclear industry. This audit was performed by the
| |
| Duquesne Light Nuclear Group (Duquesne) at OSI's Birdsboro, PA facility on March
| |
| 10-11,1994. Duquesne used NUPIC Audit Checklist, Revision 4 (the NUPIC
| |
| checklist effective for the period of January 27,1993, through April 19,1994).
| |
| '
| |
| The scope of the Duquesne audit checklist appeared to be acceptable for the
| |
| services being provided with the exception that there was no documentation to
| |
| support PECO's acceptance of Duquesne's decision not to review QSl's order entry
| |
| and procurement practices.
| |
| PECO informed the inspectors that prior to January 1995, PECO Instruction No. 4,
| |
| " Evaluated Vendors List Instruction," Revision O, dated December 16,1993, was
| |
| used to accept NUPIC audits including the 1994 Duquesne audit of OSI. Section
| |
| 7.2.3, " Quality Assurance Audit / Survey Review," and Exhibit 4-8, " Audit / Survey
| |
| Review Form Checklist," of Instruction No.4 requires that th: PECO Assessor
| |
| assigned to process a NUPIC audit report, evaluate the acceptability of the
| |
| information contained in the NUPIC audit report and its supporting checklist and
| |
| ensure that any NUPIC checklist attributes marked "Not Applicable" are adequately
| |
| explained and justifiable. Contrary to the requirements of Instruction No. 4, there
| |
| was no explanation in the 1994 Duquesne audit and checklist for entering "Not
| |
| Applicable" for Checklist Items No.1, " Order Entry," and No. 4, "Procuremont."
| |
| The 1994 Duquesne audit of OSI reviewed the corrective action that was
| |
| implemented by OSI to address two audit findings contained in the 1992 PECO
| |
| audit report for OSI. The 1992 PECO audit report for OSI contained the following
| |
| statements concerning two audit findings, documented as Vendor Corrective Action
| |
| Requests (VCR):
| |
| | |
| - . .. _ . - . _ - . . _ - - _ _ . - - - ... - -
| |
| l
| |
| 11 1
| |
| e VCR VA O 2151 was issued because QSI has been performing internal
| |
| audits utilizing personnel not independent of OSI operations.
| |
| * VCR O 2152 was issued because internal audit plans were not being
| |
| reviewed by another lead auditor prior to the performance of the audit
| |
| required by QSI procedure.
| |
| The inspectors verified that the 1994 Duquesne audit of OSIincluded an adequate
| |
| review of the implementation of the corrective action for the two VCRs identified in
| |
| the 1992 PECO audit of OSI. The following statements were contained in the 1994
| |
| Duquesne OSI Audit Report concerning the implementation of OSl's correctiva
| |
| action for the two VCRs identified during the 1992 PECO audit of OSI:
| |
| * ABSTRACT:
| |
| Continued corrective action implementation for findings identified
| |
| during the previous NUPlC Joint Audit (PECO Audit No. VA A-
| |
| 174937, 2/26 27/92) was satisfactory.
| |
| * SECTION SUMMARY, Section XI- Program Compliance, item C
| |
| ,
| |
| Internal audits are performed by the Vice President of Operations,
| |
| who has no direct responsibility for quality assurance functions, and
| |
| reports directly to the President / Chief Executive Officer for QSI. The
| |
| 1993 internal audit plan was reviewed by an independent lead
| |
| auditor. The checklist satisfactorily documented the objective
| |
| evidence reviewed.
| |
| Based on the above audit results, it appeared that the 1994 Duquesne audit had
| |
| verified that OSI had and continued to implement adequate corrective action for the
| |
| two VCRs identified during the 1992 PECO audit of OSI.
| |
| 3. Review of the 1997 PECO Audit Report for QSI
| |
| The inspectors also performed a partial review of the 1997 PECO Assessment No.
| |
| A1077041, dated April 2,1997, for an audit that was conducted on March 3,
| |
| 1997, at OSI's Birdsboro, PA facility. The assessment evaluated the
| |
| implementation of OSI's OA program as it applies to providing QA auditing and
| |
| Quality Verification inspection personnel and services. The assessment was
| |
| performed using Revision 7 of the NUPIC Audit Checklist. The scope of the audit
| |
| appeared to be acceptable for the services being provided and included within its
| |
| scope order entry and procurement. This assessment report contained the following
| |
| ,
| |
| statements concerning order entry and procurement.
| |
| <
| |
| e investiaated Results, item 1, Order Entry
| |
| ,
| |
| A review and discussion of order entry activities noted that the only
| |
| current nuclear utility orders for audit and/or inspection activity has
| |
| . . _ .
| |
| | |
| 12
| |
| been from PECO and Centerior Energy (CEI). The current PECO
| |
| contract for QA services has no releases against it. The CEl contract
| |
| for offsite QA support has had various work releases in the last audit
| |
| period. QSI has also provided audit / inspection services for nuclear
| |
| vendors but they were not addressed in this audit. in accordance
| |
| with the OSI QA program, the President and QA Manager have the
| |
| responsibility for implementing the QA policy as it pertains to the
| |
| services provided and contractually imposed. Seven (7) purchase
| |
| order releases were reviewed and found to be properly addressed by
| |
| OSI as described on the Quality Assurance Agent Support Forms
| |
| (OAASFs). No instances were identified where purchase order
| |
| requirements could not be met, This area is considered satisfactory.
| |
| e investiaated Results, item IV, Procurement
| |
| Procurements are controlled by Sections 4 and 7 of the Qaality
| |
| System, Inc QA Manual. Per discussion with the QA
| |
| Manager, OSI does not purchase material or equipment. Any
| |
| inspections reo' ring calibrated equipment to be performed by
| |
| QSI are accomplished using the client's andts vendor's
| |
| equipment. While OSI does have measures established for the
| |
| procurement of services, none have been issued.
| |
| 4. Review of Audit Reports for CTS
| |
| The inspectors performed a partial review of the 1995 PECO Audit Report No. VA-
| |
| A0945946, dated August 2,1995, for an audit that was conducted July 19 20,
| |
| 1995, at CTS's Stone Mountain, GA facility. The audit scope was limited to
| |
| inspection, nondestructive examination (NDE), and auditing services provided by
| |
| CTS to the nuclear industry. The scope of the audit appeared to be acceptable for
| |
| the services being provided. The NUPIC Audit Checklist used by PECO for this
| |
| audit was Revision 6 (the NUPIC checklist effective on March 26,1995). As a
| |
| result of this audit, nine VCRs were issued.
| |
| 5. Comparison of OSI and CTS Audit Reports
| |
| The inspectors questioned PECO about the apparent differences in selected audit
| |
| checklist elements used for the audit of OSI and CTS. Initially, it appeared that the
| |
| audit scope for CTS was far more extensive than the audit scope for QSI. The
| |
| inspectors determined that this was the result of the use of different revisions of
| |
| the NUPIC audit checklists being used to audit OSI and CTS.
| |
| For example, Revision 4 of the NUPIC Audit Checklist was used for the 1994
| |
| Duquesne audit of OSI and the following are some of the NUPIC Audit Checklist
| |
| sections that were identified as being applicable or not applicable for QSl:
| |
| * Section 1 - Order Entry, NOT APPLICABLE (NA) ,
| |
| * Section IV - Procurement, NA l
| |
| l
| |
| l
| |
| l
| |
| I
| |
| | |
| _ _ _ . _ . _ - - . ___ . _ _ _ _ _ _ .
| |
| 13
| |
| e Section VI- Fabrication / Assembly, Special Processes, NA (See NOTE)
| |
| e Section Vil- Test / Inspection, APPLICABLE
| |
| e Section Vill- Handling, Storage, and Shipping, NA
| |
| e Section IX - Calibration, NA
| |
| e Section X - Document Control, AFPLICABLE
| |
| NOTE: According to PECO, special processes (e.g., NDE services) is a
| |
| service provided by OSI.
| |
| However, Revision 6 of the NUPIC Audit Checklist was used for the 1995 PECO
| |
| audit of CTS. The following are some of the NUPIC Audit Checklist sections that
| |
| were identified as being applicable or not app licable for CTS.
| |
| e Section 1 - Order Entry, APPLICABLE
| |
| e Section IV - Procurement, APPLICABLE
| |
| e Section V - Material Control / Handling, Storage, & Shipping, NA
| |
| e Section VI Fabrication / Assemble /Special Processes, NA (See NOTE)
| |
| e Section Vil- Test / Inspection, APPLICABLE
| |
| e Section Vill - Calibration, NA
| |
| e Section IX - Document Control, APPLICABLE
| |
| NOTE: For Audit Checklist item No. VI, Section IV,
| |
| " Fabrication / Assembly /Special Processes," of the PECO audit reports
| |
| states, " CTS's scope of service does not apply to the control of
| |
| fabrication, assembly and special processes since they only provide
| |
| Quality Assurance Services (i.e., OA/QV Inspections). The
| |
| assessment of CTS's control over the qualification and certification of
| |
| -
| |
| NDE personnel is addressed in Section V Inspection / Tests of this
| |
| report."
| |
| Based on a review of the above information, the NRC inspectors determined that
| |
| the only apparent differences in the NUPIC Audit Checklist sections used for the
| |
| 1994 Duquesne of OSI and the 1995 PECO Audit of CTS were as follows:
| |
| e Order Entry was reviewed during the CTS sudit, but was not reviewed during
| |
| the OSI audit.
| |
| e Procurement was reviewed during the CTS Audit, but was not reviewed
| |
| during the OSI audit.
| |
| , Conclusion
| |
| Based on a review of PECO's 1992 audit of Quality Systems, Inc. (OSI) and PECO's
| |
| use of a 1994 Duquesne' audit of OSI for the purposes of maintaining OSI on the
| |
| PECO Evaluated Vendor List (EVL), the inspectors determined that PECO failed to
| |
| , document why the areas of order entry and procurement were not considered and
| |
| , reviewed during the implementation audit of OSI quality assurance (QA) program.
| |
| The inspectors determined that the acceptance of the 1994 Duquesne audit
| |
| !
| |
| | |
| . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _
| |
| 14
| |
| appeared to be contrary to the requirements of PECO Instruction No. 4, " Evaluated
| |
| Vendors List Instruction," dated December 16,1993, becaute of Duquesne not
| |
| explaining why the areas of order entry and procurement were not reviewed during
| |
| the audit. However, the inspectors determined that the scope of the 1997 PECO
| |
| audit of QSt included the order entry and procurement processes. In its 1997 audit
| |
| of OSI, PECO determined that OSI had adequate OA program and implementing
| |
| procedure controls in place for the order entry process and based on a review of
| |
| several order entries, PECO determined that these controls were being effectively
| |
| implemented. Further, in its 1997 audit of OSIin the area of procurement, PECO
| |
| detemined that OSI had not issued any purchase orders (POs) for safety-related
| |
| equipment or services.
| |
| Because of the nature of the audit omissions in the 1992 PECO audit and the 1994
| |
| Duquesne audit and the fact that the 1997 audit confirmed OSI had implemented
| |
| adequate QA controls for order entry and in the area of procurement, OSI had not
| |
| issued any safety-related POs, the failure of PECO to evaluate OSl's implementation
| |
| of these areas constitutes a violation of minor significance and is being treated as a
| |
| non-cited violation consistent with Section IV of the NRC Enforcement Policy.
| |
| (NCV 50 352,353/97-07 04)
| |
| l
| |
| E7.1.2 Review of Commercial Grade Survevs
| |
| 1. Commercial Grade Survey of Dryden Oil
| |
| The inspectors performed a limited review of PECO's 1994 commercial grade
| |
| survey of the Dryden Oil Company (Dryden) that was conducted April 12-13,1994,
| |
| at Dryden's Baltimore, MD facility (Reference: PECO Assessment No. CG A-
| |
| OR'34410, dated May 11,1994). The commercial grade survey was performed
| |
| using the NUPIC Commercial Grade Survey Checklist, Revision 1, and assessed
| |
| Dryden's commercial controls and performance relative to the supply of lubricants,
| |
| oils, and greases. Dryden was placed on PECO's EVL as a supplier of commercial
| |
| grade products rather than safety-related products or services. As such, Dryden
| |
| products would be dedicated by PECO as basic components before use in sa:ety-
| |
| related applications. The inspectors determined that since placing Dryden on its
| |
| EVL, for the purpose of providing commercial grade items, PECO had issued only
| |
| one purchase requisition (Material Requisition No. 0118464) to Dryden for the
| |
| supply of non-safety-related oil, and that there was no evidence that the oil had
| |
| ever been used. Further, PECO informed the inspectors that the oil had been -
| |
| supplied by Dryden in 1995 and was now classified as surplus material.
| |
| The inspector concluded that the Dryden Oil survey was adequate to place the
| |
| . company on the EVL as a commercial grade supplier. Because PECO is a NUPIC
| |
| member,its commercial grade survey of Dryden may be used by other NUPIC
| |
| members fer procuring commercial grade items from Dryden and dedicating them as
| |
| basic components.
| |
| ,
| |
| l
| |
| _
| |
| | |
| ~ .- - . _ _ . -- -
| |
| i
| |
| !
| |
| 15
| |
| ' E7.1.3 Purchase Order Revision Controls
| |
| a. Insoection Scone
| |
| The inspectors reviewed PECO's program for the establishment of technical
| |
| procurement controls described in procedures P-C-7," Services Requisition
| |
| Process,' Revision 2, and P-C 9, " Evaluated Vendor List," Revision 1. The
| |
| inspectors also evaluated the implementation of PECO's procurement program
| |
| during the revit>w of safety-related purchase orders (POs) involving OSI and CTS.
| |
| b. Observations and Findinas
| |
| The inspectors reviewed selected POs in order to determine if these documents
| |
| provided appropriate methods and responsibilities for the requisition of safety-
| |
| related items and services. In particular, the inspectors examined POs B-LOA-
| |
| 000479 and B-LOA .000516, which concerned the acquisition of quality verification
| |
| support services from CTS and OSI respectively. Based on the review of these POs
| |
| it was determined that PECO's Purchasing Department had initiated the requisition
| |
| subsequent to a request from Nuclear Quality Assurance (NOA) for support services
| |
| et both the Limerick and Peach Bottom stations for future outage work. However,
| |
| as indicatea by the licensee, neither OSI nor CTS had provided any quality
| |
| verification personnel (e.g., ANSI N 45.2.6 Level I,11, or 111 inspectors) to either
| |
| Limerick or Peach Bottom.
| |
| As determined by the inspectors, the CTS PO (B-LOA 000479) had been
| |
| appropriately initiated by authorized personnel in the licensee's purchasing
| |
| organization in accordance with the requirements of procedure P C-7. The
| |
| inspectors also ascertained that subsequent changes to the PO including the
| |
| termination of this requisition were appropriately authorized by functionally
| |
| designated PECO personnel. However, during the review of the associated
| |
| purchase order documents, the inspectors noted that despite the apparent change in
| |
| scope of the PO for CTS (e.g., Revision 1 placed the order on hold and Revision 2
| |
| canceled the requisition) limited supporting information, related to a record of
| |
| transaction or a purchase order review form, was available to address the potential
| |
| effects of these changes on the technical and quality requirements of the PO.
| |
| Additionally, as described in paragraph 7.11 of procedure P-C-7, changes to an
| |
| issued PO require that the requester prepare a Request for Change Order (RCO)in
| |
| accordance with Exhibit P-C-7-9 of the procedure. However, as determined by the
| |
| inspectors the specified RCO had not been completed in conjunction with the
| |
| termination of PO B-LOA-000479 as required.
| |
| During the review of PO B-LOA 000479, the inspectors noted that a June 22,
| |
| 1995, memorandum, from the Peach Bottom Quality Division to PECO's
| |
| 4
| |
| procurement organization, conceming the composition of contract support personnel
| |
| had been forwarded to all of the organizations competing for the quality verification
| |
| support services contract. The memorandum stated that, "It would be beneficial if
| |
| at least 5 of the 16 candidates hava current Level ll certifications in: Ultrasonic
| |
| '
| |
| Inspections (UT) or instrumentation and Controls." Based on the review of this
| |
| | |
| 16
| |
| memorandum, the inspectors determined that it had been properly forwarded to the
| |
| prospective contractor organizations by PECO's procurement organization and that
| |
| it did not materially alter the intent of the PO in that it merely expanded on the
| |
| specific areas of expertise associated with the requested ANSI N45.6 SNT-TC-1 A,
| |
| Level 11 certified inspectors. Therefore, this memorandum was not regarded as a
| |
| substantive change to the requisition which would have necessitated a revision to
| |
| the purchase order.
| |
| As a result of the review of procedure P-C-7, the inspectors determined that
| |
| appropriate provisions had been established for the evaluation of " sole source"
| |
| suppliers including the development of Exhibit P-C-7 7, Pole Source Justification
| |
| form. Howevor, none of the POs reviewed during this inspecthn involved sole
| |
| source suppliers and the examination of this area was limited to the ovaluation of
| |
| PECO's procedural controls.
| |
| As previously noted, PO B-LOA-000479 underwent two revisions the first of which
| |
| , placed the requisition on hold, pending the completion of an audit of CTS's quality
| |
| assurance (QA) plan. Relative to Revision 1 of the PO, the licensee stated that the
| |
| terms "QA program" and "QA plan" were used interchangeably relative to the
| |
| process of verifying the vendors compliance to the requirements of Appendix B of
| |
| 10 CFR Part 50. The need for auditing CTS's OA program had been documented
| |
| on PEP 10003739, dated March 13,1995, subsequent to the licensee's
| |
| determination that a safety-related PO had been issued to an unapproved vendor
| |
| (CTS) who was not on the Evaluated Vendors List (EVL). Specifically, the PEP
| |
| indicated that contrary to the requirements of Procedure Number PA 3,
| |
| " Administrative Controls for Purchase of items and Services for Nuclear Safety
| |
| Related Applications at Power Plants" and Procedure P-C-7, Revision 1, purchasing
| |
| had incorrectly issued a PO to a supplier of quality verification personnel services
| |
| without the vendor being listed as either approved or conditionally approved on the
| |
| EVL. The PEP further stated that the vendors OA program would need to be
| |
| formally evaluated and approved by NOA prior to the vendor providing quality
| |
| verification services. This condition was imposed even though CTS would be
| |
| working under PECO's OA program, because the PO specified that the vendor was
| |
| responsible for supplying ANSI N 45.2.6 Level 11 qualified inspection personnel
| |
| under CTS's OA program, which was required to meet the applicable criteria of
| |
| Appendix B of 10 CFR Part 50.
| |
| Based on the review of PEP 10003739 the inspectors determined that appropriate
| |
| corrective actions had been developed in response to this nonconformance including
| |
| the revision of procedures PA-3 and P-C-7 to clarify the requirements related to the
| |
| placement of safety related service POs and an organizational realignmeni which
| |
| currently has the Nuclear Group processing their own procurement requisitions.
| |
| However, as a result of the review of this PEP, it was determined that the
| |
| documented generic implications review of similar POs, to verify that the identified
| |
| condition was an isolated occurrence, had not been completed in conjunction with
| |
| the close out of the Performance Enhancement Program (PEP). Subrequent to the
| |
| identification of this issue, the licensee revised PEP 10003739, on September 16,
| |
| 1997, to address the inappropriate closure of the PEP without completing the
| |
| | |
| 1
| |
| l
| |
| 17
| |
| generic implications assessment. The revised PEP indicated that Nuclear Quality
| |
| Assurances' current assessment (A1103691) involving the Nuclear Groups
| |
| procurement activities included a review of POs for products and services. ;
| |
| Specifically, the evaluation was performed to determine if safety related products i
| |
| and services were being procured from approved or conditionally approved vendors 1
| |
| on PECO's EVL in accordance with procedures P-C 1 and P-C-7. This assessment,
| |
| which utilized a representative sampling process, did not identify any deficiencies
| |
| and the generic review aspect of this PEP was appropriately completed.
| |
| c. Conclusions
| |
| Within the areas examined, two examples involving the lack of adherence to
| |
| administrative controls related to procurement transactions were identified. The
| |
| examples included the issuance of a purchase order to a supplier of quality
| |
| verification personnel services without the vendor being listed on the evaluated
| |
| vendor list, documented in PEP 10003739, and the failure to complete a request for
| |
| change order when a contract was terminated. The inspectors also identified that
| |
| PEP 10003739 had been inappropriately closed without the performance of the
| |
| specified generic implications review. However, the licensee's subsequent
| |
| corrective actions were prompt, and included a comprehensive assessment of the
| |
| Nuclear Groups procurement activities. Although the noncompliances identified
| |
| collectively indicate a weakness in the licensee's implementation of procurement
| |
| controls, this failure constitutes a violation of minor significance and is being treated
| |
| as a non-cited violation consistent with Section IV of the NRC Enforcement Policy.
| |
| (NCV 50-352,353/97-07 05)
| |
| IV. Plant Suooort
| |
| R1 Radiological Protection and Chemistry (RP&C) Controls
| |
| R 1.1 Imolementation of the Radioactive Liouid and Gaseous Effluent Control Proarams
| |
| a. Insoection Scoos (84750)
| |
| The inspection consisted of: (1) tours of radioactive liquid and gaseous effluent
| |
| pathways and process facilities; (2) review of unplanneti or unmonitored release
| |
| pathways; (3) 1996 Annual Radioactive Effluent Release Report; and, (4) review of
| |
| the Offsite Dose Calculation Manual (ODCM).
| |
| b. Observations and Fmdinas
| |
| The inspector reviewed the 1996 annual radioactive effluent release report. This
| |
| report provided data indicating total released radioactivity for liquid and gaseous
| |
| effluents. The annual report also summarized the assessment of the projected
| |
| maximum individual and population doses resulting from routine radioactive airborne
| |
| and liquid effluents. Projected doses to the public were well below the Technical
| |
| Specification (TS) limits. The inspector identified no additional anomalous
| |
| measurements, omissions or adverse trends in the reports.
| |
| | |
| _- . - - .- =
| |
| 18
| |
| The inspector reviewed a licensee 10 CFR 50.59 analysis pertaining to numerous
| |
| typographical discrepancies within the ODCM and planned changes to address
| |
| those discrepancies. The inspector identified no additional discrepancies within the
| |
| ODCM or noted any inadequacies pertaining to the 10 CFR 50.59 analysis. The
| |
| licensee was in the process of implementing new dose assessment software at the
| |
| time of the inspection. The licensee plans to make additional changes to the ODCM
| |
| prior to formal programmatic implementation of this software.
| |
| The inspector conducted a tour and reviewed selected radioactive liquid and gas
| |
| processing facilities and equipment, including effluent / process / area radiation ,
| |
| monitors and air cleaning systems. The major component out of service at the time
| |
| of the inspection was the RM-21 Radiation Monitoring System (RMS) computer and
| |
| the licensee was initiating actions to address this particular equipment problem.
| |
| Although this equipment was out of service, it did not impact the licensee's
| |
| capability to comply with licensee requirements, in that it is used as a data
| |
| collection tool. The licensee is performing manual data retrievalin accordance with
| |
| the ODCM.
| |
| The inspector reviewed a special study conducted by the licensee to account for
| |
| potential releases from a modificatiun of the Chemistry Laboratory roof. This report
| |
| was well-detailed and no inadequacies were noted by the inspector,
| |
| c. Conclusions
| |
| Based on the above reviews, that inspector determined that the licensee maintained
| |
| and implemented good routine radioactive liquid and gaseous effluent control
| |
| programs.
| |
| R2 Status of RP&C Facilities and Equipment
| |
| R2.1 Calibration of Effluent / Process / Area / Accident Radiation Monitorina Systems (RMS)
| |
| a. Insppction Scoce (84750)
| |
| The inspector reviewed the most recent calibration results for the following selected
| |
| effluent / process / area / accident RMS.
| |
| * North Stack Effluent
| |
| * Wide Range Accident
| |
| * Residual Heat Removal (RHR) Service Water
| |
| '
| |
| * South Stack Effluent
| |
| * Air Ejector Offgas Effluent
| |
| * Liquid Radioactive Waste Discharge
| |
| * Service Water
| |
| | |
| - __ .. , . .- . -_. - - . - . - _ _ .
| |
| 19
| |
| b. Observations and Findinos
| |
| t
| |
| The inspector noted that the licensee used multiple calibration sources and took
| |
| multiple roadings during the RMS calibration process. All calibration results
| |
| reviewed were within the licensee's acceptance criteria.
| |
| 4
| |
| The inspector discussed the maintenance and operability / reliability with the RMS
| |
| system engineer who has been assigned the system for the past several years. The
| |
| *
| |
| inspector reviewed work orders for RMS back into 1996. The inspector noted that
| |
| the backlog and timeliness of addressing problems has improved. The system
| |
| engineer attributed this improvement to the fix-it-now teams.
| |
| The inspector noted the following potential areas for improvement regarding the
| |
| RMS.
| |
| , e Reliability / availability was not formally tracked.
| |
| * One of the acceptance criteria was that the calibration factor had to be
| |
| within 135% of the previous calibration factor. The inspector considered
| |
| this a large acceptance band.
| |
| e Linearity of the RMS was not formally determined. The inspector noted that
| |
| the correlation coefficient from a least squares fit of the calibration data was
| |
| , a good parameter for trending system performance.
| |
| .
| |
| The Radiation Protection Manager indicated that these matters would be reviewed
| |
| , and corrective actions would be taken, as appropriate.
| |
| 1 c. Conclusions
| |
| The RMS calibration program was good. Several opportunities were identified in
| |
| which system tracking and trending could be improved.
| |
| R2.2 - Air Cleanino Svstems
| |
| ,
| |
| a. Insoection Scoce (84750)
| |
| The inspector reviewed the licensee's most recent surveillance test results (visual
| |
| inspection, in-place high efficiency particulate air (HEPA) leak tests, in-place
| |
| charcoal leak tests, air capacity tests, pressure drop tests, and laboratory tests for
| |
| the iodine collection efficiencies) for the control room, reactor enclosure and
| |
| refueling area, standby ges treatment, and radioactive waste enclosure common
| |
| tanks vent and equipment.
| |
| b. Observations and Findinos
| |
| '
| |
| No discrepancies were noted for the in-place HEPA leak tests, in-place charcoal leak
| |
| j tests, air capacit y tests.
| |
| _ _ _ _ _ _ _ _ _ _ _ _ .
| |
| | |
| - - _ - _ - . - . - . .- -- . -. -- - ..
| |
| ;
| |
| 20
| |
| The licensee's TS specify Regulatory Position C.6.a of Regulatory Guide (RG) 1.52,
| |
| Revision 2, March 1978, as the requirement for the laboratory testing of the
| |
| .
| |
| charcoal. RG 1.52 references ANSI N509-1976, " Nuclear Power Plant Air-Cleaning
| |
| Units and Components." ANSI N509-1976 specifias that testing is to be performed
| |
| in accordance with paragraph 4.5.3 of RDT M 161T, " Gas Phase Adsorbents for
| |
| Trapping Radioactive lod *e and lodine Components." Charcoal efficiency testing
| |
| was conducted by a ver. Jr service. The Office of Nuclear Reactor Regulation
| |
| (NRR) has identified a potential testing discrepancy regarding charcoal efficiency
| |
| *
| |
| testing using the methodology described in RDT M 161T. This matter involves
| |
| '
| |
| .
| |
| testing conditions for the charcoal. This matter will be further reviewed
| |
| (IFl 50-353/97 07-06).
| |
| One minor matter regarding a lack of acceptance criteria in the Radioactive Waste
| |
| : Enclosure Common Tank Vent and Equipment procedure ST-4-079 320-0 was
| |
| noted by the inspector. The inspector assessed that the most recent surveillance
| |
| '
| |
| results did not appear to conflict with the system flow rates denoted in the UFSAR.
| |
| The inspector reviewed a 10 CFR 50.59 review pertaining to a potential surveillance
| |
| test failure of the "A" CREFAS Monthly Operability Test conducted on June 18,
| |
| '
| |
| 1997. This analysis determined that an eighth of an inch water gauge had been
| |
| i maintained with respect to surrounding structures and outside conditions and
| |
| identified some discrepancies in the surveillance procedure in-use at that time.
| |
| Corrective actions were taken. The inspector noted no discrepancies pertaining to
| |
| this 10 CFR 50.59 review.
| |
| '
| |
| The inspector reviewed work orders for selected systems back into 1996. The
| |
| inspector noted that the backlog and timeliness of addressing problems has
| |
| improved. The system engineers attributed this improvement to the fix it-now
| |
| teams.
| |
| !
| |
| c. Conclusions
| |
| Based on the above reviews and discussion, the inspector determined that the
| |
| licensee implemented a good surveillance program.
| |
| R7 Quality Assurance (QA)in RP&C Activities
| |
| .
| |
| a. Insoection Scone (84750)
| |
| L The inspection consisted of: (1) review of the 1996 audit: (2) a radiation protection
| |
| '
| |
| self assessment; and (3) implementation of the measurement laboratory quality
| |
| control program for radioactive liquid and gaseous effluent samples.
| |
| - b. Observations and Findinas
| |
| '
| |
| The inspector reviewed the NOA audit of the effluents program. The audit was
| |
| well-targeted and no issues of regulatory significance were noted by the audit team.
| |
| .
| |
| 4
| |
| | |
| . _ _ _ _ _
| |
| _ _ _ -___ _ - _ __ - -
| |
| 21
| |
| The licensee's self-assessment was self-critical and highlighted challenges regarding
| |
| RMS aging and ODCM discrepancies.
| |
| OC over instrumentation was very good. The inspector reviewed the QC data for
| |
| inter-laboratory comparisons. The inspector noted that the last two tutium samples ,
| |
| (second quarter 1996 and first quarter 1997) were in disagreement with the vendor
| |
| laboratory. The licensee attributed the first disagreement to improper distillation
| |
| techniques. Thn licensee was unable to explain the second disagreement. The
| |
| Chemistry Supervisor noted to the inspector that this discrepancy had not been
| |
| investigated. The inspector considered this lack of follow up to be a weakness in
| |
| chemistry laboratory QC. The Chemistry Supervisor stated to the inspector that
| |
| sample preparation OC would be programmatically strengthened.
| |
| c. .Qnpelusions
| |
| Based on the above reviews, the inspectors determined that the licensee's OA audit
| |
| was good. Overall, the licensee implemented a good OC program to validate
| |
| measurement results for effluent samples.
| |
| F1 Control of Fire Protection Activities
| |
| F1.1 Main Conttql Room Fire Sucoression System (71750)
| |
| l
| |
| During this inspection period, the inspector reviewed the UFSAR basis for an
| |
| automatic fire suppression system for the control room with a focus on inadvertent
| |
| I
| |
| actuation of the system, in so doing, the inspector considered the following
| |
| questions:
| |
| 1. Does the control room have an automatic fire suppression system (AFSS)?
| |
| If yes, does it have initiation logic along with actuation on a automatic time or
| |
| manual delay basis and what chemical is used (e.g., water, halon, carbon dioxide,
| |
| etc.)? Describe briefly.
| |
| If no, identify what is used for fire suppression in the control room.
| |
| 2. With an AFSS, does the licensee have specific or general
| |
| abnormal / emergency procedures for an inadvertent actuation of the AFSS
| |
| during operations and shutdown?
| |
| Desciibe immediate actions and briefly describe supplemental actions.
| |
| 3. Do licensee procedures and/or technical specifications provide for the use of
| |
| emergency breathing apparatus for in the control room (give type of
| |
| apparatus: SCBA, Air line, etc.)? Is there sufficient equipment to support the
| |
| control room staff? Are the numbers specified in TS, procedures,
| |
| surveillances? Do these numbers reflect what actually exist in the plant?
| |
| - -
| |
| | |
| _ _ _ _ _ _ _. _ _ _ . __ _ _ _. . _ _ _ . __ ___
| |
| 22
| |
| Briefly describe the type of apparatus and when they would be used.
| |
| Limerick Generating Station's UFSAR 9A.5.3.24, Fire Area 24, Control Room and
| |
| Peripheral Rooms, states that a fire activates smoke detectors, which cause an
| |
| audible / visual annunciation to register on the fire protection panels in the control
| |
| room. Operators then callin the plant fire brigade to manually extinguish the fire. +
| |
| There is no automatic fire suppression system for the control room. Fire procedure
| |
| F A-533, Control Room 533 and Peripheral Rooms 530 to 535 (El. 269) Fire Area
| |
| 24, revision 4, proposes stretching a CO2 hose line into the control room, from just
| |
| outside the control room door, and attacking the fire, as the primary strategy. The
| |
| secondary strategy is to stretch the dry chemical unit hose from the turbine building
| |
| through the control room door and attacking the fire. For fires in the peripheral
| |
| rooms, the procedure proposes attackirig the fire using portable fire extinguishers,
| |
| located in the control room, as the primary strategy; the portable extinguishers use
| |
| halon as the extinguisher.
| |
| Limerick UFSAR 6.4.4.2.3 states that full-faced demand self-contained breathing >
| |
| apparatus rated for 1 hour per cylinder and protective clothing are available for
| |
| contro! room operators. Routine Test procedure RT-0-111-900-0, revision 18, One-
| |
| hour SCBA Cylinder inspection and Functional Test, which is performed monthly or
| |
| after use, specifies a minimum of 14 SCBA Paks for the control room. The
| |
| inspector counted 14 SCBA Paks in the control room. Special Event procedure SE-
| |
| 2, revision 10, Toxic Gas / Chlorine, directs operators to don self-contained breathing
| |
| apparatus within 2 minutes for: High Toxic Chemical Conc alarmed; Control Room
| |
| Chlorine Isolation Initiated alarmed; and Harsh or unusual odor.
| |
| F2 Status of Fire Protection Facilities and Equipment
| |
| F2.1 In-Plant Walkdowns (92904)
| |
| a. Scoos of insoection
| |
| The inspector conducted in-plant walkdowns of portions of several fire protection
| |
| procedures, During these walkdowns, the inspector took note of the material
| |
| condition of the. fire protection equipment. The specific procedures which were
| |
| evaluated in the f; eld are indicated in the list of procedures in the attachment to this
| |
| report. Additionally, the inspector discussed recently identified problems with
| |
| deluge valves with fire protection staff members.
| |
| b. Observations and Findinos
| |
| Recently, several issues have developed which involve the facility design. These
| |
| issues include identification of structural steel requiring fireproof coating, aiming and
| |
| testing of emergency lighting units required for safe shutdown, and compatibility
| |
| ___ _ problems between the installed fire suppression system deluge valves and their
| |
| electronic control panels. To assist with resciution of these design issues, PECO
| |
| will assign a supervisor from the Probabilistic Safety Assessment (PSA) group in
| |
| Nuclear Engineering to the site for a period of six montns. The PSA group is the
| |
| organization within Nuclear Engineering with responsibility for fire protection.
| |
| I
| |
| | |
| _ _ _ _ _ _ _ _ __ - _ - _ _ . - - _
| |
| 23
| |
| Auxillary Equipment Room Halon* Stations
| |
| The inspector observed the condition of the Unit 1 and Unit 2 Auxiliary Eo.uipment
| |
| Room Halon* banks. The Halon* cylinders ond connections were free of excessive
| |
| corrosion products. The connections were tight and marked to show whether the
| |
| cylinder which was connected at that point was in the main or reserve bank, and
| |
| which cylinder was connected (Main 1, Reserve 2, etc.).
| |
| Fire Suppression Water System Deluge Valves
| |
| The inspector noted the condition of the sprinkler systems throughout the plant and
| |
| observed that they appeared to be well-kept and in good condition. Two open head
| |
| sprinkler systems were inspected in detail, the Unit 1 Reactor Enclosure Hatchway
| |
| Elevation 217' Sprinkler System, DL-72, and the Unit 1 Reactor Enclosure Water
| |
| Curtain Elevation 217', DL-68. The equipment was well-preserved, lined up for
| |
| actuation, and the valves associated with the deluge valve station were clearly
| |
| marked.
| |
| During discussions with the fire protection staff, the in 3ector was informed that
| |
| PECO had recently determined that there is a compatibility problem between the
| |
| installed deluge valves and the currently installed electronic control panels. This
| |
| matter was evaluated by PECO Nuclear Engineering, and corrective actions included
| |
| replacement of the six inch deluge valves. Currently, when a deluge valve fails a
| |
| surveillance test, it is reworked, and returnri to fe'l functional condition.
| |
| Fireproof Coated Steel
| |
| The incpector observed the status of the coating on beams in the plant which are
| |
| required to be protected from the effects of an exposure fire. The inspector noted
| |
| that there were uncoated attachments on several of the beams, in response to the
| |
| inspector's questions regarding the extent to which attachments need to t,e coated,-
| |
| PECO engineering personnel contacted the supplier of the coating material, and
| |
| were advised that unless the attachment constitutes a significant portion of the
| |
| beam cross-section, it need not be coated beyond the depth of the beam coating.
| |
| Plans are to incorporate this information into a specification being generated which
| |
| willlist, in detail, those beams requiring protection (see discussion in Section F4.1).
| |
| The inspector found this response acceptable.
| |
| Battery Powered Emergency Lights
| |
| The inspector performed a walk down of the Unit 2 Residual Heat Removal (RHR)
| |
| system equipment listed in UFSAR Appendix 9A as requiring remote cperation for
| |
| shutdown from outside the control room. The inspector noted the Nsitioning of the
| |
| emergency lighting units (ELUs) and the aiming of the heads. The inspector
| |
| dotermined that the RHR equipment and the pathways to the RHR equipment are
| |
| illuminated. The inspector also notad that many of the ELUs now have red labels
| |
| affixed indicating that the units are required for safe shutdown and the heads are
| |
| not to be moved. Fire protection staff members informed the inspector that
| |
| -
| |
| x -
| |
| | |
| - . _ - - . . _ _ _ - . - - . . - - - _ .. . . --
| |
| 24
| |
| '
| |
| completion of the safe shutdown lighting review was expected in the September-
| |
| October time frame this year. PECO currently plans to mark the lamp heads
| |
| showing the alming points starting about November 1997. The inspector checked
| |
| the condition of a number of ELUs and found them to be free of corrosion, with
| |
| proper electrolyte levels and charging indications. A review of previously completed
| |
| ' _ inspections indicated that several ELUs were found to have deficiencies during each
| |
| inspection. The deficiencies were entered into the PECO corrective action system.
| |
| Fire Dampers
| |
| The inspector used the mechanical drawings listed in ST-7-022-921-2,
| |
| i
| |
| Attachment 1, Rev.1, Fire Damper Tabulation, to locste fire dampers in two areas
| |
| ; of the Unit 2 Reactor Enclosure, Area 13 of Elevations 253' and 217', For those
| |
| : dampers readily accessible (i.e., not greater than six feet from floor level nor in high
| |
| ; radiation areas), the inspector verified that the locations shown on the drawings
| |
| matched the field locations. In addition, the inspector evaluated labeling and
| |
| accessibility to perform maintenance. The inspector did not open the access panels
| |
| at the dampers. The inspector determined that the dampers were at the locations
| |
| shown on the drawings, and those accessible had bar code labels affixed,
| |
| c. Conclusions
| |
| Based on the observed condition of the selected equipment in the field, the
| |
| inspector concluded that the fire protection equipment is in good repair, readily
| |
| identifiable, and ready for use.
| |
| F3 Fire Protection Procedures and Documentation
| |
| F3.1 Procedure Uoarade Proaram (92904)
| |
| a. Insoection Scooe
| |
| The inspector reviewed a sample of current revisions of procedures governing fire
| |
| protection activities. The inspector evaluated the extent of the revisions, and their
| |
| affect on the procedures' useability, in addition, several procedures were taken to
| |
| the field by the inspector to evaluate adequacy of the procedures for conducting the
| |
| activities. The procedures reviewed are listed in an attachment to this report.
| |
| Those procedures which were " walked-down" in the field are identified in the
| |
| attachment.
| |
| b. Observations and Findinas
| |
| As discussed in NRC Integrated Inspection Report (01) 50-352 & 353/97 01, PECO
| |
| had initiated a Project Plan to improve fire protection procedures. Action Request
| |
| (AR) A1050861, Limerick Generating Station _(LGS) Fire Protection Procedures, is
| |
| being used to track the surveillance test (ST) and routine test (RT) procedures in the
| |
| Fire Protection Rewrite Procedure Project which was initiated to enhance the clarity
| |
| of fire protection test procedures. The AR contains 55 separate items to track
| |
| __ -_
| |
| | |
| 25
| |
| individual procedures, with scheduled completion dates prior to the next scheduled
| |
| use of the procedure, in view of the goal of Industrial Risk Management (IRM) to
| |
| trensfer the testing to other departments for performance, the revised procedures
| |
| will u:e the station standard format with simpler steps, corresponding sign-offs for
| |
| each step, and caution statements and notes set off prior to the step to which they
| |
| are applicable (human factors format). The change of fire protection from Technical
| |
| Specifications to Technical Requirements Manual (TRM) is also being captured in
| |
| the revisions. Inspector observations related to specific procedures are given
| |
| below:
| |
| Halon* System inventory Procedures
| |
| Procedures ST-7 022-3531, Rev. 4, Halon System inventoryi and ST-7-022-353 2,
| |
| Rev. 6, Halon System inventory, formerly checked both the main and reserve banks
| |
| at the same time, if any of the cylinders were found to be out of specification on
| |
| weight or pressure, the procedure directed moving cylinders between the banks to
| |
| return at least one bank to operable status. The new revisions test one bank at a
| |
| time, either the main or reserve bank. This ensures that one bank remains operable
| |
| at all times, since the bank under test is returned to operable status before the other
| |
| bank is taken out of service for test. In addition, the format has been changed to
| |
| the human factors format, and steps have been simplified. The prior revisions
| |
| required recording the empty weight of the cylinder from the stamping at the neck.
| |
| The new rovision simply requires recording the cylinder empty weight, since a
| |
| number of the new cylinders have the empty weight marked on a label affixed to
| |
| the side, rather than stamped at the neck. The inspector walked-down procedures
| |
| ST-7-022-353 2, Rev. 6 Halon System Inventory, ST-7-022 353 2, Rev. 7, Unit 2
| |
| Main Bank Halon System Inventory,-and ST-7-022-354, Rev. O, Unit 2 Reserve
| |
| Bank Halon System Inventory, in the field and found them to be adequate for
| |
| performing the required tests.
| |
| Procedure RT-7-022-353-0, TSC Halon System Inventory, ensures the gaseous
| |
| agent fire suppression system for the Technical Support Center (TSC)is operable.
| |
| The new revision, Rev. 5, sets off notes and cautions at the appropriate step, and
| |
| adds specific sign-offs for meeting the minimum weight and pressure range
| |
| acceptance criteria. Rev. 5 also improves the readability of the procedure over
| |
| Rev. 4, and simplifies the instructions. Fire protection group personnel informed the
| |
| inspector that they plan to contract this work, along with all other " commercial
| |
| building" (outside the power block) fire protection system testing, to an outside
| |
| company. Responsibility for oversight will remain with the PECO fire protection
| |
| group.
| |
| Emergency Lighting Unit Procedures
| |
| The inspector reviewed the current and prior revisions of the safe shutdown ELU
| |
| test procedures,_ RT-6-108-300-0, Rev. 6 and 4, RT-6108 300-1, Rev. 5 and 4,
| |
| and RT-6-108 300-2, Rev. 4 and 3, Safe Shutdown Eight (8) Hour Self Contained
| |
| Battery Pack Operation Verification. The prior revisions of the procedure contained
| |
| directions for irispecting the ELUs, along with individual step signoffs for the
| |
| | |
| . _ _ _ _ _ _ - _ _ _ - - _ _ - - _ _
| |
| 26
| |
| inspection steps, diagrams showing individual ELUs, paths and equipment to be
| |
| illuminated, and signoffs for each safe shutdown ELU. The new revisions retain the
| |
| diagrams and individual ELU signoffs, but have deleted the individual inspection step
| |
| signoffs to improve clarity. The inspection steps and acceptance criteria have been
| |
| retained.
| |
| Fire Rated Structural Assembly Procedures l
| |
| Procedure ST-7-022 920-1, Rev. 3, Un41 Refuel Fire Rated Assembly inspection, !
| |
| provides guidance and acceptance criteria for conducting inspections of fire rated
| |
| structural assemblies (including structural steel) and electrical raceway fire
| |
| encapsulations. The procedure requires all visible and accessible assemblies to be
| |
| inspected. The specific items to be inspected are listed in attachments to the
| |
| procedure. Attachment 1 provides a list of the fire rated structural assemblies
| |
| (walls, slabs, etc.) and Attachment 2 provides a list of the raceway encapsulations.
| |
| At the current time, all the raceway encapsulations are considered to be inoperable
| |
| in accordance with NRC Generic Letter (GL) 92-08 regarding Thermo-Lag issues,
| |
| and hourly fire watches are being performed. There is a corresponding procedure
| |
| and set of attachments for Unit 2.
| |
| !
| |
| ;
| |
| in August 1996, PEP issue 5811, insulation Missing From Structural Steel, was
| |
| I
| |
| initiated, documenting deficiencies identified during the inspection of the fire rated
| |
| assemblies. One of the difficulties identified by PECO employees was identification
| |
| of the specific structural steel members which required coating. The fire protection
| |
| group has maintained a copy of Engineedng Work Request (EWR) L 00508 which
| |
| showed those steel members requiring protection from exposure fires. The
| |
| drawings included in the EWR package date from 1989, and are not otherwise
| |
| available at the site. To resolve the problem with accessibility of the information,
| |
| PECO Nuclear Engineering is developing a specifieration, NE 264, which willlist each
| |
| specific structural steel member requiring coating, and the required extent of the
| |
| coating. The Unit 2 portion of the listing has been incorporated into ST-7-022-920-
| |
| 2, Attachment 1, Rev. 5, Structural Fire Rated Assembly Tabulation, dateo April 22,
| |
| 1997. The inspector concluded that this will simp!!fy obtaining the information, and
| |
| makes performing the inspection easier. The Unit 1 listing has not yet been
| |
| incorporated into the corresponding tabulation, which still contains a single signoff
| |
| for the steel being inspected in accordance with the EWR,
| |
| Fire Damper inspection Procedures
| |
| PEP 6033, improvements to Fire Protection Procedures and Program, has an entry
| |
| from March 1997, indicating that several of the procedure revisions tracked by AR
| |
| A1050861 are overdue. One of the overdue revisions was for ST-7-022-921-2,
| |
| Fire Damper Inspection. This procedure contains instructions for inspection and
| |
| functional testing of fire dampers. The procedure contains wording which allows
| |
| corrective actions to be taken if a fire damper does not perform properly during the
| |
| functional test, and requires a notation in the Additional Action / Test Comments
| |
| Section. The procedure also contains a requirement to clean and lubricate the
| |
| latching mechanism of trap door type fire dampers. The list of dampers to be
| |
| a
| |
| | |
| 27
| |
| inspected is contained in an attachment to the procedure. Revision 2 of the
| |
| procedure, dated May 21,1997, revised the reference to the list of dampers. The
| |
| inspector field verified locations of dampers in several plant areas, as discusseu in
| |
| Section F2.1, using ST-7-022-9212, Attachment 1. Rev.1, Fire Damper
| |
| Tabulation, dated February 14,1995. The dampers were located at the positions
| |
| shown in the referenced drawings, and were readily identifiable. The inspector
| |
| noted that several of the dampers would require significant preparatory work in the
| |
| form of scaffolding and health physics surveys to perform the inspections.
| |
| Fire protection group personnel informed the inspector that the current procedure
| |
| was cumbersome to use in that it required inspections of dampers in several
| |
| systems at the :ame time. Their intent is to revise the procedure and tabulation to
| |
| group the fire "oers on a system basis, rather than plant area basis. This will
| |
| enable persont C h .erforrn the inspections during system outage weeks.
| |
| While reviewin9 other fire damper inspection procedures, the inspector noted that
| |
| ST-7-022 9210, Rev. 6, Fire Damper inspection, had two temporary changes
| |
| against it at the time of the inspection. One corrected a TRM reference to the
| |
| correct technical specifications (for control room ventilation LCOs) and the other
| |
| required compensatory actions to be taken during the inspection of the dampers in
| |
| the control room normal and emergency Ventilation systems. These compensatory
| |
| measures are necessary because with the ductwork access panels open, the
| |
| ventilation systems cannot isolate on toxic gas release, radiation release, or steam
| |
| line breaks. These compensatory actions were developed as a result of an ongoing
| |
| review of fire protection procedures to determine plant impacts.
| |
| Sprinkler System Procedures
| |
| Two recently revised procedures covered sprinkler systems: RT-7-022-322-0,
| |
| Remote Buildings (Outside PAB) Sprinkler System Operability Verification, and
| |
| RT-7 022-320-1, BOP Fire Protection Sprinkler System operability.
| |
| The buildings outside the protected area boundary (PAB) were not within the scope
| |
| of NRC purview, 'out the inspector reviewed the procedure to verify consistency
| |
| with in-plant procedures. PECO plans to contract this work to an outside company,
| |
| so the procedure was revised to a more conventional text format. Cautions and
| |
| notes were set off just prior to the step to which they apply, as with the human
| |
| factored procedure formst.
| |
| The balance of plant (BOP) procedure will be used by station personnel and so was
| |
| converted to the human factored procedure format. The BOP procedure was also
| |
| split into two procedures. RT-7 022-3201, Rev. 6, BOP Fire Protection Sprinkler
| |
| System Operability Verification, details the 18-month tests of wet pipe sprinkler
| |
| systems in the turbine building. RT-7-022-321 -1, Rev. O, Outage Wet Pipe
| |
| Sprinkler System Operability Verification and Visual Inspection, tests those systems
| |
| which are not accessible during normal operation (condenser bay and moisture
| |
| separator area).
| |
| !
| |
| 1
| |
| | |
| _ _ . _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . ____ _ _ . _ .
| |
| ;
| |
| _
| |
| 4 28
| |
| _To_ evaluate a representative procedure which had not been revised, the inspector
| |
| , reviewed ST 7 022-730-1, Rev 4, Fire Suppression Water System (FSWS)
| |
| : Air / Water Nozzle Flow Test. This procedure tests open head sprinkler systems and
| |
| ! pre-action sprinkler systems in the Unit 1 Reactor Building and Diesel Generator
| |
| i Cells. The procedure provides.a discrete set of instructions for each individual
| |
| sprinkler system. The inspector perfornied a field verification of steps for two
| |
| i systems. The systems evaluated were Reactor Etelosure Hatchway Elev. 217,
| |
| j; Deluge Fire Protection Sprinkler System, DL-72, and Reactor Enclosure Water
| |
| l Cortain Elev. 217, Deluge Fire Protection System, DL 68. The inspector determined
| |
| -
| |
| p :that for those open head systems where the potential exists to trip the deluge
| |
| [ valve, appropriate steps are included to prevent water discharge, and to restore the
| |
| system in accordance with station operating procedures. The inspector noted that
| |
| : Section 4.3 of Precautions and Limitations provides three alternative methods which
| |
| .
| |
| may be used for verifying air flow at the open nozzles. A previous review by the ,
| |
| [ resident inspection staff determined that PECO is using a fourth method, which is
| |
| j functionally equivalent.
| |
| I
| |
| f The use ot a functional equivalent would appear to be permissible, since the
| |
| j procedure step states to _ verify flow at each nozzle, without specifically stating
| |
| a how. The inspector noted that the procedure calls for verifying air flow at each
| |
| .
| |
| j - nozzle, out does not provide the number of nozzles in the various sprinkler systema.
| |
| c. . Conclusions
| |
| b-
| |
| Based on the review of the new and prior procedure revisions, along with the field
| |
| I walkdown of the procedures, the inspector concluded that the procedures provide
| |
| p adequate guidance and appropriate acceptence criteria for testing of fire protection ,
| |
| systems.
| |
| ,
| |
| j: F6- Fire Protection Organization and Administration
| |
| i: F6.1 - Fire Protectio, Council (92904)-
| |
| 4
| |
| a. Insoection Scoae
| |
| The inspector discussed the activities of the Fire Protec'..on Council with several of
| |
| *
| |
| .its members, and reviewed the action items which were generated during its
| |
| i meetings.
| |
| : b. Observations and Findinas
| |
| '
| |
| As discussed in NRC IR 50-352 & 353/97-01, PECO instituted a Fire Protection
| |
| ; Council in February 1997. At the time of that inspection, insufficient time had -
| |
| ; passed to achieve any significant results.
| |
| The Fire Protection Council is comprised of the IRM Managers from Limerick (LGS)
| |
| p and Peach Bottom (PBAPS), the Nuclear Engineering Department (NED) Probabilistic
| |
| l Safety Assessment (PSA) Branch Manager, the LGS and PBAPS Fire Protection
| |
| i
| |
| s
| |
| _ _
| |
| _ . . . _ __ _ _
| |
| _ _ --
| |
| | |
| 29
| |
| Program and Firt. Protection System Managers, and the NED PSA Fira Protection
| |
| Program and Safe Shutdown Program Managers. Other personnel are added if
| |
| needed to address specific issues. The management sponsor for the council is the
| |
| Executive Vice-President, Nuclear.
| |
| The council is functioning to provide management oversight of the fire protection
| |
| improvement projects, to establish priorities and to coordinate the efforts between
| |
| NED, PBAP3 and LGS. The council has obtained funding to bring in contractor
| |
| assistance for the procedure improvement project at LGS, and has added additional
| |
| contractor support for the program for calendar year 1998. The council has created
| |
| several additional fire protection performance indicators for tracking, including the
| |
| availability of the diesel driven, motor driven, and backup fire pumps. The council
| |
| will focus on program and process issues, and leave the equipment issues to the
| |
| focused improvement team discussed in Section F6.2.
| |
| c. Conclusions
| |
| 1
| |
| Based on the discussions with members of the Fire Protection Council and review of I
| |
| the Action items generated at its meetings, the inspector concluded that the council
| |
| was a good initiative for bringing fire protection issues to management's attention
| |
| and prioritizing the improvement efforts.
| |
| F6.2 Fire Protection Focused imorovement Team (92904)
| |
| a. Insnection Scoce
| |
| '
| |
| The inspector discuesed the Focused improvement Team (FIT) with team members,
| |
| and attended a FIT meeting on-site.
| |
| b. Observations and Findinas
| |
| The Fire Protection FIT was assembled to provide a higher level of attention to
| |
| address equipment problems at the Limerick site. The purpose of the team is to
| |
| identify equipment issues, prioritize the equipment issues, search for commonalities
| |
| between the Peach Bottom and Limerick sites, and determine courses of action for
| |
| long-term resolution of equipment reliability and maintenance issues.
| |
| The initial meeting of the FIT was held August 14,1997. It consisted of a
| |
| " brainstorming" session to identify the known and potential hardwars issues with
| |
| fire protection systems. Action items from the meeting included developing a list of
| |
| obsolete parts / equipment and breaking down the equipment issues into logical
| |
| groupings, such as fire pump bearing problems, fire diesel battery problems, and so
| |
| forth. A second meeting, which the inspector attended, was held August 21,
| |
| 1997.
| |
| The FIT goal is to identify all of the fire protection system functions and
| |
| components which do not meet expectations for performance or maintainability and
| |
| ensure that the identified issues are being properly addressed. In addition, the FIT
| |
| | |
| ..__ _ -__ _ . . _ _ _
| |
| i
| |
| )
| |
| !
| |
| 30
| |
| will attempt to anticipate future problem areas based on PECO and industry
| |
| experience. An example is a recently identified issue with testing of foam fire
| |
| fighting equipment. After performing the required test, the concentrate remains in
| |
| the lines, and can cause the foam concentnte check valve to stick with a resultant
| |
| failure of the next test. The FIT is evaluating what actions to take for resolving this
| |
| emergent problem.
| |
| c. Conclusions
| |
| Based on the issues raised at the FIT meeting, and a review of the action items in
| |
| progress, the inspector concluded that the FIT is a good initiative to identify fire
| |
| protection equipment and system problems.
| |
| F8 Miscellaneous Plant Support issues (90712)
| |
| F8.1 (Closed) LER 1-97 006, Previous Condition Prohibited by Tech Snecs in that a Fire
| |
| ; Protection System Deluae Valve may not have Functioned oer Deslan Since
| |
| issuance of the Unit 1 Operatina License.
| |
| This LER concerned an instance where station personnel identified that a potential
| |
| voltage mismatch may exist between a fire protection deluge valve and its control
| |
| panel, resulting in marginal power available to operate the valve. An evaluation
| |
| concluded that a technical specification noncompliance occurred between issuance
| |
| of the facility operating license for Unit 1 on October 26,1984, and Decembcr 20,
| |
| 1995, when the applicable technical specifications were relocated to the Technical
| |
| Requirements Manual, since the valve may have been unable to perform its design
| |
| function. Corrective actions included making adjustments to the valve to optimize
| |
| mechanical operation, posting a continuous firewatch, increased testing of the
| |
| valve, and the valve was replaced on September 3,1997. This violation had more
| |
| tn:.n minor significance since it resulted in a condition where a technical
| |
| specification-required deluge valve was inoperable for an extended period of time.
| |
| However, safety consequences for this event were low, since no actual fires
| |
| occurred in the area. Additionally, had a fire occurred and had the valve failed to
| |
| automatically operate, it would have been manually activated by the fire brigade,
| |
| which would have responded to the fire alarm. This licensee-identified and
| |
| corrected violation is being treated as a non-cited violation, consistent with Section
| |
| Vll.B.1 of the NRC Enforcement Policy. (NCV 50 352/97-07 07)
| |
| V. Manaaement Meetinas
| |
| 4
| |
| X1 Exit Meeting Summary
| |
| The inspector presented the inspection results to members of plant management at the
| |
| '
| |
| conclusion of the inspection on September 17,1997. The plant manager acknowledged
| |
| the inspectors' findings. The inspectors asked whether any materials examined during the
| |
| inspection should be considered proprietary. No proprietary information was identified.
| |
| .
| |
| J
| |
| .
| |
| | |
| . . . .-
| |
| . . - _ _ _ . .__ _ ._ _ . . . . . _ .
| |
| [
| |
| ,
| |
| 31
| |
| ,
| |
| X2 Review of UFSAR Commitments
| |
| - A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR
| |
| '
| |
| description highlighted the need for a spacial focused review that compares plant practices, -
| |
| procedures and/or parameters to the UFSAR description. While performing the inspections
| |
| discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that
| |
| related to the areas inspected. The inspectors verified that the UFSAR wording was
| |
| , consistent with the observed plant practices, procedures and/or parameters.
| |
| .
| |
| 4
| |
| 4
| |
| .
| |
| J
| |
| .f
| |
| a
| |
| 4
| |
| ;-
| |
| I
| |
| - , . - ,
| |
| | |
| _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ - _ - -
| |
| 32
| |
| INSPECTION PROCEDURES USED
| |
| IP 37551: Onsite Engineering
| |
| IP 38701: Procurement Program
| |
| IP 61726: Surveillance Observation
| |
| IP 62707: Maintenance Observation
| |
| IP 71707: Plant Operations
| |
| IP 71750: Plant Support Activities
| |
| IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
| |
| IP 90712: In-office Review of Written Reports
| |
| IP 90713: Review of Periodic and Special Reports
| |
| IP 92904: Followup - Plant Support
| |
| IP 93702: Prompt Onsite Response to Events at Operating Power
| |
| Reactors
| |
| ITEMS OPENED, CLOSED, AND JISCUSSED
| |
| Ooened
| |
| l
| |
| [ 352,353/97-07-01 VIO Control of Locked Valves (O2.1)
| |
| 352,353/97-07-02 IFl Concerns associated with a number of RWCU isolations.
| |
| (08.2)
| |
| 353/97-07 03 VIO HPCI System Inoperable Due to Clogged Turbine Exhaust Drain
| |
| r Line. (M8.1)
| |
| {
| |
| 353/97-07-06 IFl Charcoal Efficiency Testing Adequacy (R2.2)
| |
| Closed
| |
| 352,353/97-07-04 NCV Review of PECO Audits and PECO's Use of Third Party Audits
| |
| (E7.1.1 )
| |
| 352, 353/97-07-05 NCV Purchase Order Revision Controls (E7.1.3)
| |
| 352/97-07-07 NCV Fire Protection System Deluge Valve may not have Func.tioned
| |
| per Design. (F8.1)
| |
| 352/1-97-006 LER Previous Condition Prohibited by Technical Specifications in
| |
| that a Fire Protection System Deluge Valve may not have
| |
| Functioned per Design Since issuance of the Unit 1 Operating
| |
| License. (F8.1)
| |
| 353/2 97-007 LER Unit 2 HPCI System inoperable Due to Clogged Turbine
| |
| Exhaust Drain Line. (M8.1)
| |
| . 1
| |
| .
| |
| | |
| . . _. _
| |
| 33
| |
| ITEMS OPENED, CLOSED, AND DISCUSSED (Continuod)
| |
| 353/2 97-008 LER Automatic Closure of Drywell Chilled Water System Primary
| |
| Containment isolation Valves, an ESF Actuation, Resulting
| |
| from Emergency Diesel Generator Voltage Regulation Failure.
| |
| (08.2)
| |
| 353/2 97 009 LER Unit 2 Reactor Water Clean-up Isolation, an ESF, Caused by a
| |
| RWCU Filter Demineralizer Y Strainer Manual Drain Valves
| |
| Leaking into the Backwash Receiving Tank. (08.3)
| |
| Discussed
| |
| None
| |
| LIST OF ACRONYMS USED
| |
| AFSS Automatic Fire Suppression System
| |
| AR Action Request
| |
| BOP Balance of Plant
| |
| CEI Centerior Energy
| |
| CFR Code of Federal Regulations
| |
| CREFAS Control Room Engineering Fresh Air System
| |
| EDG Emergency Diesel Generator
| |
| ELU Emergency Lighting Unit
| |
| ESF Engineered Safety Feature
| |
| EWR Engineering Work Request
| |
| FIT Focused improvement Team
| |
| FME Foreign Material Exclusion
| |
| FP Fire Protection
| |
| FSWS Fire Suppression Water System
| |
| GL Generic Letter
| |
| HEPA High Efficiency Particulate
| |
| HPCI High Pressure Coolant injection
| |
| IFl inspection Follow-up Item
| |
| IR inspection Report
| |
| IRM Industrial Risk Management
| |
| LCO Limiting Condition For Operation
| |
| LER Licensee Event Report
| |
| LGS Limerick Generating Station
| |
| NCV Non-Cited Violation
| |
| NDE Nondestructive Examination
| |
| NED Nuclear Engineering Department
| |
| NOA Nuclear Quality Assurance
| |
| NRB Nuclear Review Board
| |
| NRC Nuclear Regulatory Commission
| |
| NUPIC Nuclear Procurement issues Committee
| |
| ODCM Offsite Dose Calculation Manual
| |
| | |
| _. . . . _ - . _ . _ _ _ . . . _ ._ - _ _._ _. _ _ ..
| |
| _
| |
| _
| |
| ;
| |
| -34 _
| |
| IPAB1 Proterted Area' Boundary
| |
| PBAPS4 Peach Bottom Atomic Power Station
| |
| . _ PECO - - PECO _ Energy
| |
| PEP Performance Enhancement Process
| |
| -PO- Purchase Order.
| |
| ' PORC - Plant Operations Review Committee
| |
| PSA Probabilistic Safety Assessment
| |
| ' QA - Quality .^ ssurance
| |
| -QC- Quality Control
| |
| '
| |
| QV _
| |
| Quality Verification
| |
| RCIC '- Reactor Core Isolation Cooling-
| |
| RCO- _ Request for Change Order
| |
| RHR Residual Heat Removal
| |
| 4 -RMS Radiation Monitoring System
| |
| RP&C Radiological Protection and Chemistry
| |
| -
| |
| RP' Radiation Protection
| |
| RT Routine Test
| |
| RWCU. Reactor Water Clean-up
| |
| b SCBA - Self Contained Breathing Apparatus -
| |
| SLC Standby Liquid Control
| |
| ST- Surveillance Test-
| |
| TRM Technical Requirements Manual
| |
| -TS -Technical Specification
| |
| TSC- Technical Support Center
| |
| .
| |
| .UFSAR Updated Final Safety Analysis Report
| |
| URI Unresolved item
| |
| VIO Violation
| |
| .
| |
| A
| |
| 4 -
| |
| I
| |
| o
| |
| ;
| |
| 4
| |
| J
| |
| i
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| :
| |
| i'
| |
| : ,, J ;-_. , . L .. .-. , ,, , , ..i--,
| |
| | |
| _ _ _ _ _ __ _ . _ . . _ - _ .__ - . . . .- . _. ____ _ _____ _ . _ . _. _. _
| |
| k
| |
| '
| |
| 35
| |
| 1;
| |
| "
| |
| LIST OF DOCUMENTS REVIEWED. ,
| |
| . Procedures
| |
| I - A-c-043,' Surveillance Testing Program, Rev. O
| |
| {- - A C-079, Procedure- Adherence and Use, Rev.
| |
| : ST-7-022 3531, Halon System Inventory, Rev. 4
| |
| 1~
| |
| ST-7 022-3531, Unit 1 Main Bank Halon System Inventory, Rev. 5
| |
| ST-7 022-354-1, Unit.1 Reserve Bank Halon System inventory, Rev. 0
| |
| - iST-7 022-353 2, Halon System Inventory, Rev. 6
| |
| ! lST-7-022-353-2,' Unit 2 Main Brnk Halon System Inventoryi Rev. 7
| |
| iST-7-022 354-2, Unit 2 Reserve Bank Halon System Inventory, Rev. O
| |
| i ST-7-022-730-1, FSWS Air / Water Nozzle Flow Test, Rev. 4
| |
| iST-7-022-9201, Unit 1 Refuel Fire Rated Assembly Inspection, Rev. 3 I
| |
| . . __
| |
| ! '
| |
| - l ST-7-022 920-1, Attachment 1, Structural Fire Rated Assembly Tabulation, Rev. 'J (with
| |
| ,
| |
| - temporary change 1-87-0903 1)
| |
| ST-7-022 9201- Unit 1 Refuel Fire Rated Assembly inspection, Rev. 2
| |
| ,
| |
| ST-7-022-920 1,- Attachment 1,-Structural Fire Rated Assembly Tabulation, Rev. 2
| |
| ;_ ST 7-022-920-2, Attachment 1, Structural Fire Rated Assembly Tabulation, Rev. 5 (with
| |
| temporary change 1 97 0904 2)
| |
| L ST-7 022 921-0, Fire Damper Inspection, Rev. 6 (with temporary changes 1-97-0901-0
| |
| and 2 97-0908-0)
| |
| ;- ST-7-022 921-0, Attachment 1, Fire Damper Tabulation, Rev. 6
| |
| ,
| |
| - ST-7 022-921_-1, Fire Damper inspection, Rev. 5
| |
| i ST-7-022-921 -2, Fire Damper Inspectioni Rev. 2
| |
| i ST-7-022-921 -2, Attachment 1, Fire Damper Tabulation, Rev.1
| |
| ;
| |
| ST-7-022-922 0, Fire Rated Penetration Test Sample Visual inspection, Rev. 6
| |
| l
| |
| ST-7-022-922-0, Attachment 1, Fire Rated Penetration Seal Tabulation, Rev. 4
| |
| 5
| |
| '
| |
| RT-6-108-300-0, Safe Shutdown Eight (8) Hour Selt-Contained Battery Pack Operation
| |
| Verification, Rev. 6
| |
| '
| |
| RT-6-108-300-0, Safe Shutdown Eight (8) Hour Self-Cor tained Battery Pack Operation
| |
| . Verification, Rev. 4 -
| |
| RT-6-108-300-1, Safe Shutdown Eight (8) Hour Self Contained Battery Pack Operation
| |
| . Verification, Rev 5-
| |
| RT 6-108 300-1, Safe Shutdown Eight (8) Hour Self-Contained Battery Pack Operation
| |
| >
| |
| Verification, Rev. 4
| |
| i RT-6-108-300-2, Safe Shutdown Eight (8) Hour Self Contained Battery Pack Operation
| |
| 4
| |
| - Verification, Rev. 4
| |
| RT-6-108-300-2,. Safe Shutdown Eight (8) Hour Self Contained Battery Pack Operation
| |
| Verification, Rev.~3
| |
| '
| |
| , RT-7 022 3201, BOP Fire Protection Sprinkler System Operability Verification, Rev.6
| |
| RT-7-022-320 1, BOP Fire Protection Sprinkler System Operability Verification,' Rev. 5
| |
| RT 7-022-321-1, Catage Wet Pipe Sprinkler System Operability Verification and Visual
| |
| Inspection, Rev. O
| |
| L RT-7-022-322 0, Remote Buildings (Outside PAB) Sprinkler System Operability Verification,
| |
| Rev.6
| |
| RT-7-022 322-0, Remote Buildings (Outside PAB) Sprinkler System Operability Verification,
| |
| Rev.5
| |
| +
| |
| 4
| |
| '
| |
| . , , . + ,.--,_,&---,c. -,e -
| |
| -,----,,.---c.-, e - - , - - w c ---
| |
| r
| |
| | |
| _ _ . _
| |
| _____ _ _ - ____-___-___ - - _ _ _ _ _ _ _ ..
| |
| . .. -
| |
| i
| |
| !
| |
| 36
| |
| RT 7 022 353 0, TSC Halon System Inventory, Rev. 5
| |
| RT 7 022 353 0, TSC Halon System Inventory, Rev. 4
| |
| S22.8.C, Hatchway Flow Control Valve Reset, Rev. 6
| |
| S22.8.E Pre Action or Deluge System Reset, Rev. 6
| |
| i Denotes procedures which were walked down, in part, in the facility
| |
| \
| |
| htd@e.rino Documents \
| |
| Specification A 39A, Fire Protection Specification for Structural Steel Fireproofing
| |
| (CAFCOTE 800), Limerick Generating Station Units 1 and 2, Rev.8
| |
| l Specification A 39A, CAFCOTE 560 Application and Installation Guide, Rev.1
| |
| i
| |
| Specification A 39, Specification for Structural Steel Fireproofing for the Limerick
| |
| Generating Station Units 1 and 2
| |
| Engineering Work Request L 00508, Fire Coating on Structural Steel Beams, Rev. 8
| |
| A 305, Sher? 1, Architectural; Alr/ Steam / Fire & Water Boundaries Floor Plan El 177' 0"
| |
| Unit i, Rev.12
| |
| A 305, Sheet 2, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El.177' 0"
| |
| Unit 2, Rev. O
| |
| A 305, Sheet 3, Architectural Security Boundaries Flocr Plan El.177' 0" Unit 1&2, Rev.
| |
| O
| |
| A 306, Sheet 1, Architectual Air / Steam / Fire & Water Boundaries Floor Plan El. 201' 0"
| |
| Unit 1, Rev.16
| |
| A 306, Sheet 2, Architectural Air / Steam / Fire & Water Boundaries Floor Plan El. 201' 0"
| |
| Unit 2, Rev. O
| |
| A 306, Sheet 3, Architec" .el Security Boundaries Floor Plan El 201' 0" Unit 1&2, Rev.
| |
| O
| |
| A 307, Sheet 1, Architectural; Air /Steem/ Fire & Water Laundaries Floor Plan El. 217' 0"
| |
| Unit 1, Rev.19
| |
| A 307, Sheet 2, Architectural: Air / Steam / Fire & Water Boundaries Floor Plan El. 217' 0"
| |
| Unit 2, Rev. 3
| |
| A 307, Sheet 3, Architectural Security Boundaries Floor Plan El/ 217' 0" Unit 1&2, Rev.
| |
| O
| |
| A 308, Sheet 1, Architectural; Air / Steam / Fire & Water Boundaries F!oor Plan El. 253' 0"
| |
| Unit 1, Rev.13
| |
| A 308, Sheet 2, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El. 253'-0"
| |
| Unit 2, Rev. O
| |
| A 308, Sheet 3, Architectural Security Boundarles El. 253' 0" Unit 1, Rev. O
| |
| A 309, Sheet 1, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El 283' 0" &
| |
| 269' 0" Unit 1, Rev.16
| |
| A 309, Sheet 2, Architectural; Air / Steam / Fire & Water Boundarles Floor Plan El. 283' 0" &
| |
| 269' 0" Unit 2, Rev. O
| |
| A 309, Sheet 3, Architectural - Security Boundaries Floor Plan El. 283' 0" & 209' 0" Unit
| |
| 1 &2, Rev. O
| |
| A 310, Sheet 1, Architectural: Air / Steam / Fire & Wbter Boundaries Floor Plan El. 313'-0",
| |
| 302' & 332' Unit 1, Rev.13.
| |
| A 310, Shset 2, Architectural: Air / Steam / Fire & Water Boundaries Floor Plan El. 313' 0",
| |
| 302' & 352' Unit 2, Rev. O
| |
| y v .
| |
| | |
| . . - - - - -_-._ - _ - .. - - _ - ..- .- -
| |
| ------_-. - -
| |
| ;
| |
| 37
| |
| .
| |
| A 310, Sheet 3, Architectural Security Boundaries Floor Plan El. 313'0", 302' & 332'
| |
| )
| |
| Unit 1&2, Rev. O i
| |
| '
| |
| A 311, Sheet 1, Architectural; Air / Steam / Fire & Water Boundarles Floor Plan El. 352'-0"
| |
| ] Unit 1, Rev. 6
| |
| A 311, Sheet 2, Architectural; Air / Steam / Fire & Water Boundaries Floor Plan El. 352' 0"
| |
| Unit 2, Rev. 0
| |
| l A 311, Sheet 3, Architectural Security Boundaries Floor Plan El. 352' 0" Unit 1&2, Rev.
| |
| 1
| |
| 0
| |
| 4 A 185, Architectural Control Bldg. Fire Proofing Sec. & Det., Rev. 5
| |
| C 426, Control Room Area Floor Plan, El. 239' 0" Area 8, Rev. 24
| |
| ! C 432, Control Room Area Floor Plan, El. 254' 0" Area 8, Rev. 22 '
| |
| 3 C 440, Control Room Area 8, Sections and Dettils, R: v.12
| |
| l C 473, Sheet 1, Control Room Area 8 Structural Steel, Framing Plan El. 254' 0" & El.
| |
| j 269' 0", Rev.12
| |
| j C 473, Sheet 2, Control Room Area 8 Structural Steel, Traffic Control Barriers El. 269' 0", ;
| |
| l Rev.0 *
| |
| 1
| |
| . C 478, Control Room Area 8 Structural Steel, Framing Plan El. 289' 0" & El 304' 0", Rev.
| |
| i
| |
| 12
| |
| l C 191, Reactor Building Units 1&2, Structural Steel Column Schedule, Rev. 24 '
| |
| i C 460, Control Room Area 8 Structural Steel, Framing Plan El. 239' 0", Rev.16
| |
| j M 1151, Heating and Ventilating Reactor Bldg. Unit No. 2 Plan at El. 217' 0" Area 13,
| |
| i Rev.16
| |
| { M 1152, Heating and Ventilating Reactor Bldg. Unit No. 2 Plan at El. 253' 0" Area 13,
| |
| ; Re'.'. 19
| |
| 4
| |
| j Other Dpeuments *
| |
| UFSAR, Appendix 9A
| |
| Limerick Unit 1 Technical Requirements Manual
| |
| '
| |
| Limerick Unit 2 Technical Requirements Manual
| |
| PEP lssue 5811, insulation Missing From Structural Steel
| |
| ; PEP lssue 6033, Fire Protection Procedure improvements
| |
| '
| |
| Action Request A1050861, PEP 10006033 LGS Fire Protection Procedure
| |
| l
| |
| Quality Concern 127, irregularities in Performance of Fire Protection Surveillance Tests
| |
| ,
| |
| I
| |
| :
| |
| i
| |
| !
| |
| <
| |
| .
| |
| l
| |
| l
| |
| 1
| |
| r
| |
| - - - . . - # f-,~- , .. ,'. E ~ S 5,. , - ~ , - - . . . , .-r% ,..m.,-.s-,, ,,.. .- -v., n ,._ -~ m.-m---. . - - - , , ,- 2 .m, ,,...v, - r~<
| |
| }}
| |