Text

Forwards SALP Repts 50-277/85-98 & 50-278/85-98 for Apr 1985 - Jan 1986 & 50-352/85-99 for Dec 1984 - Jan 1986. Improvement Needed in Limerick Security/Safeguards & Peach Bottom Surveillance,Maint,Licensing & Security/Safeguards
	ML20215C170
Person / Time
Site:	Peach Bottom, Limerick, 05000000
Issue date:	12/09/1986
From:	Murley T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kemper J; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
	NUDOCS 8612150049
	Download: ML20215C170 (4)
	v • d • e

09 DEC 1986 Docket Nos. 50-277 50-278 50-352 Philadelphia Electric Company ATTN: Mr. John S. Kemper Senior Vice President, Engineering and Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP) Reports for Limerick and Peach Bottom This refers to the NRC assessment of the Limerick Generating Station and Peach

, Bottom Atomic Power Station conducted by this office and discussed with your staff at a meeting on July 11, 1986. The NRC Region 1 SALP report for Peach Bottom is provided as Enclosure 1 and the SALP report for Limerick, is provided as Enclosure 2. Your responses for Peach Bottom and Limerick both dated August 12, 1986, submitted pursuant to our letter of June 6,1986, provided comments on the SALP reports. These letters are provided as Enclosures

<

3, 4 and 5.

Our overall assessment of the operation of the Limerick Generating Station concludes that there is effective management attention, oriented toward nuclear safety, in all functional areas evaluated except for the Security and

Safeguards area. The improvement from Category 2 to Category 1 in the Plant j

'

Operations, Emergency Preparedness and Startup Testing areas reflects plant staff commitment to a high level of performance with respect to operational safety. However, the repeat of a Category 3 rating in the Security and Safe-guards area, at Limerick and Peach Bottom, indicates that PECo management was willing to accept minimally satisfactory performance over an extended period.

We acknowledge the commitments to improve this area discussed in your August 12, 1986 responses and plan to continue our increased attention to this area until permanent improvement is demonstrated.

Our overall assessment of the operation of the Peach Bottom Atomic Power Station concludes that while the plant is being operated safely, significant performance improvement is needed in several functional areas. Specifically, declining performance was noted in the Plant Operations, Maintenance, Surveil-lance, and Licensing areas, and Category 3 ratings were assigned in the Security l and Safeguards and Assurance of Quality functional areas. The commitments

'

8612150049 861209 PDR ADOCK 05000277 G PDR i

0FFICIAL RECORD COPY FINAL PB SALP FORWARDING LTR - 0001.0.0 11/29/80 k0

- - - -- - -- - _.

_

_- _________ - __ _ ___ ___ ___ _

i

Philadelphia Electric Company 2 09 DEC 1986 discussed in your August 12, 1986 letter are significant and will require con-tinued high level management attention in order to achieve the intended im-provements in those areas. We plan to have periodic management meetings with you to review your progress in making these improvements and better understand how PECO management is monitoring the program and the commitments that have been established. We will be particularly interested in the results of your efforts to reduce automatic scrams and protection system challenges. We acknowledge your comment that some scram signals were generated in the course of performing outage work in confined spaces. We believe it is appropriate to review these events to determine if there has been a trend of equipment failure or poor work practices.

In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures will be placed in the NRC Public Document Room. No reply to this letter is required. Your actions in response to the NRC Systematic Assessment of Licensee Performance will be reviewed during future inspections of your licensed activities.

Your cooperation is appreciated.

S'@@YA1 SIGNED BY:

,

JAMES M. AllAN Thomas Regional Adminir,trator

Enclosures:

1. NRC Region I Systematic Assessment of Licensee Performance, Peach Bottom Atomic Power Station, Inspection Report 50-277/85-98 and 50-278/85-98 2. NRC Region I Systematic Assessment of Licensee Performance, Limerick Generating Station, Inspection Report 50-352/85-99 3. NRC Region I Letter, to S. L. Daltroff, June 6,1986 4. PECo Letter, S. L. Daltroff to T. Murley, August 12, 1986 5. PECo Letter, S. L. Daltroff to T. Murley, August 12, 1986 6. List of Attendees at Management Meeting

REGION I==

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-277/85-98 and 50-278/85-98 PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION ASSESSMENT PERIOD - APRIL 1,1985 TO JANUARY 31, 1986 BOARD MEETING DATES MARCH 24 AND APRIL 22, 1986 l

.gk& W'

' ~ ~

,

n _ .. , . -+..o- - + < . 9-.* *

.

o n

.

i

.

SUMMARY CF RESULTS 3.1 Overall Facility Evaluation During this assessment period performance problems continued to manifest themselves at Peach Bottom. Management involvement and effectiveness toward improving operating activities have not been evider.t. Indications of the lack of adequate management involvement and effectiveness include: poor dissemination of management goals and policies; poor communication between the different departments and divisions; and a focus on compliance concerns rather than acknowledgement and correction of the root causes of problems.

An area of continued major concern is the number of reactor shutcowns and protection system challenges which have occurred.

As noted in Table 5 a large number of these are attributed to personnel errors. A common cause of the personnel errors appears to be inattention to detail resulting from failure to either follow or consult the appropriate procedure, indicating a compiacert att tude i to,zarc procedural compliance. The comp-lacent attitude is also exhibited in poor work practices that generate unnecessary protective system challenges. While initiatives to address scram causes have been in place, permanent

! corrective actions are considered ineffective, and higher levels of management involvement are necessary to redirect this effort.

Routine activities do not seem to receive appropriate manage-ment attention. The number of underlying issues (e.g. , inat-tention to detail, poor followup on commitments, poor oversight of contractors and a lack of aggressiveness in identification and resolution of routine problems) and the defensive attitude of management, leads us to conclude that there is a problem with how corporate policies are understood and adhered to on-site.

This problem has resulted in a detached attitude at the site; although a number of functional areas are rated as Category 2, the historic lack of improvement is of concern. In particular, j the Security Area epitomizes a lack of aggressive management in l

assuring that the licensee's policies, practices and procedures,

'

were understood by contractor personnel. Further, it is not clear that those who have responsibility are being held accoun-table. Recent events associated with control rod withdrawal errors during a startup, although outside the assessment period, are another indication of management not effectively assuring that the responsibility and accountability for proper operations are sufficiently understood, resulting in many instances of sloppy work practices and a sense of complacency.

(

!

- - - - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ }

.

f.

In contrast to the above, major evolutions at Peach Bottom associated with primary system piping replacement and major hardware modifications did not reflect the shortcomings noted in the previous paragraphs. This has resulted in a favorable Category I rating for Refueling / Outage Activities. The good performance in this one functional area can be attributed to the fact that the work was planned, directed and executed in close coordination with the engineering. department. Engineering support historically has been noteworthy in construction oriented activities.

!

o

.

t 3.2 Facility Performance Catego ry Category Functional Area Last Period This Period Trend

'

(January 1, 1984 to (April 1, 1985 to March 31, 1985) January 31,1986)

1. Plant Operations 2 2 Declining '

2. Radiological 3 2 Consistent Controls 3. Maintenance 1 2 Consistent 4. Surveillance 2 2 Declining 5. Fire Protection & 2 2 Consistent Housekeeping 6. Emergency 2 2 Consistent Preparedness 7. Security and 3 3 Improving Safeguards

'

! 8. Refueling / Outage 1 1 Consistent Activities 9. Training and Not Evaluated 2 Consistent Qualification Effectiveness 10. Assurance of Not Evaluated 3 Consistent Quality 11. Licensing Activities 1 2 Consistent l

. _ _ _ . . . ._

.

-

.

C IV. FUNCTIONAL AREA ASSESSMENTS 4.1 Plant Operations (31%, 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months )

Analysis During this assessment period, resident and specialist inspections routinely reviewed plant operations. The functional area of plant operations was also reviewed during team inspections prior to each unit restart following the refueling outage periods. These two restart team inspections concluded that each unit could be safely returned to reactor power operations.

During the assessment period, a total of thirty-five automatic scram signals and unplanned shutdowns occurred as follows: Nineteen auto-matic scrams on Unit 2 (eight at power with rod motion); three unplanned shutdowns on Unit 2; and, thirteen automatic scrams on Unit 3 (shutdown reactor protection system challenges). These scrams'and shutdowns are listed in Table 5, including descriptions and causal analyses as determined by the SALP Board.

Eight scrams can be attributed to personnel errors by operations personnel. Six scrams can be attributed to errors by licensed operators, and two scrams due to errors by non-licensed operators.

A common cause of these personnel errors appears to be operator

inattention to detail resulting from failure to either follow or consult the appropriate procedure. There appears to be a complacent attitude among operators with respect to procedural implementation and compliance. One additional scram can be attributed to poor control of work activities, in that a procedure did not provide an appropriate caution.

There were several other instances where lapses occurred in proce-dural adherence. For example, the following procedural violations occurred: Unit 2 control rod blocking (tagout) while full out, improper control room supervisor shift relief, improper preparation of equipment blocking permits on Unit 3 and vessel draining on Unit 2 during RHR shutdown cooling operation. The control rod blocking while full out during reactor power operation was particularly disturbing because two licensed and one senior licensed operators were cognizant

,

of the situation. When the inspector noted that the control rod was i full out and blocked, so that it would not insert during a scram, the licensee initiated immediate action to return the rod to an operable condition. Less than one hour after the control rod drive was returned to service, a reactor scram occurred. Licensee corrective actions included a revision to the control rod blocking sequence specifically requiring the rod to be full in prior to its removal from service.

The return to power operations for Unit 2 following the 15 month pipe replacement and refueling outage commenced in July 1995.

g Unit 2 startup testing, after an extended outage in which recircula-tion piping was replaced and the plant was refueled, was well

.

controlled and adequately managed. Testing included modification (

,

- -

- , . .

.

'

.

. 16 l

!

acceptance tests, refueling acceptance tests, and routine surveil-lance tests. Plant management was heavily involved in testing, problem resolution and testing decisions including frequent meetings.

A PECo manager was assigned to coordinate the overall test program as his only responsibility. Testing was performed in a cautious manner.

All increases in plant power during Unit 2 restart were accomplished with the forethought of reactor safety and safety of plant equipment.

There was an ongoing audit by QA personnel of plcnt testing progress.

Daily and shift status meetings were conducted to discuss test scheduling, to review problem areas, and to pre-brief personnel on test procedures. Restart team staffing appeared to be good. Suffi-cient personnel were available to conduct testing at remote locations. l Management decisions regarding plant and reactor safety are usually conservative as evidenced by power reductions and shutdowns that were not required by Technical Specifications. One case of non-conservative operation was the decision by plant management to swap i reactor feed pumps (RFP) at 44% power. The RFP swapping evolution resulted in a water hammer transient and reactor scram during troubleshooting activities although no procedure to control this evolution existed.

Control room operator response to plant transients and reactor scrams continues to be a strength as evidenced by inspector ( observations during several transients. Operators effectively use the symptom-oriented emergency operating procedures and associated checklists called Transient Response Implementation Plan (TRIP)

procedures.

, The assignment of an additional senior licensed operator, stationed outside the control room, relieves the shift superintendent of certain administrative duties ("Outside" Shif t Supervisor) on the day and afternoon shifts Monday through Friday and is a strength. The licensee is planning to increase the manning of the "Outside" Shift Supervisor position to full time (i.e., 21 shifts per week).

With respect to control room activities, there is no evidence of control room distractions and interior noise level is controlled.

However, at times the public address system tends to distract from control room formality. The addition of a control room carpet has aided in noise control. Access to the general control room area is restricted by the vital area doors. The Unit 2 door has recently been restricted to operations personnel only. The overall control room appearance and cleanliness is good with no evidence of inap-propriate material.

.

_

.

,

17 ,

{

Licensed shift operators are generally alert and attentive to control room panels and indications. However, an apparent inattentive Unit 3 licensed operator was not recognized and dealt with by shift super-vision until noted by an NRC inspector in June 1985.

I It appears that the on-site review committe (PORC) should be more self-critical in-an attempt to anticipate problems, especially in regards to the number of recurring personnel errors. Although plant procedures did not require PORC review and approval of modification i

l test results, PORC chose to review the completed Modification j

Acceptance Tests as well as the test procedures for Unit 2. The PORC

- is functioning well for routine activities based upon observation by inspectors at several PORC meetings during the assessment period.

l However, two instances in which PORC review was not thorough in more complex cases were the safety evaluations for the radwaste storage

,

facility (see section 4.2) and, the safety evaluation for the Unit 3 steam separator bolt and jet pump instrument damage. The initial i

safety evaluation of the jet pump instrument line damage did not

' include evaluation of potential damage from reactor operation, loose parts consideratior.s, adequate information on using three instead of four calibrated jet pumps to allow core flow assessments during

,

operation. The safety evaluation has been revised to include the I above concerns.

j The licensee has had difficulty adhering to NRC reporting require-ments. In August 1985, with Unit 3 shut down and defueled, the

licensee instituted a policy of not reporting RPS actuations, which was promulgated by a memorandum in conflict with an approved pro-

!

cedure. Based on the licensee's interpretation of the 10 CFR 50.72

! and 50.73, and NUREG 1022 reporting requirements, NRC notification

'

was not made for eight RPS actuations that occurred between August 29, 1985 and October 10, 1985. Following discussions with NRC Region I, the licensee withdrew the policy of not reporting RPS actuations.

The licensed operator training program resulted in one operator and three senior operators being licensed during this assessment period.

In addition, two candidates passed the senior operators examination as part of instructor certification. No significant areas of weak-ness were noted during the written examinations. However, a weakness was noted in the use of procedures during the simulator portion of the exam. Specifically, the candidates had difficulty in locating and differentiating between the applicable procedures during the simulator scenarios. Overall, the licensee's replacement operator training program is adequately implemented as evidenced by perfor-mance on NRC administered examinations.

I i

_ _ . _ , - _._ - .

. . _ . . . - - - _ . _ _ , _ _ _ . . _ . . . ,

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

s A review of the licensed operator requalification training indicates a properly functioning program, with two strengths and one weakness noted. The one noted strength was that lesson plans prepared by the Training Section for licensed operator requalification were well written, and presented by highly qualified instructors. The second strength was the oral walkthrough examination guide prepared for the requalification examination, which was of high quality. The noted weakness was that the licensee's requalification program does not ensure that those staff member (s) reviewing the annual written re-qualification exam are periodically administered an exam themselves.

One staff member had not taken a written exam for four years. The licensee responded to this weakness by rotating the review of the exam through four senior staff members. Thus each senior staff ,

member would periodically take the requalification exam. l Housekeeping throughout plant and station areas was determined to be adequate during the assessment period, with inprovements noted from

'

the prior assessment period. Routine inspections of the Unit 2 and Unit 3 drywells during the outage period revealed adequate clean-liness. Site QC has responsibility for evaluating housekeeping and they appeared to be effective in early identification and resolution of housekeeping discrepancies. Housekeeping conditions, noted problem areas and corrective actions were routinely discussed at the daily and weekly cutage meetings.

Management controls to assure that approved procedures were not revised informally were weak in that two cases were noted where

'

problems arose. Faulty guidance modifying administrative procedure requirements resulted in a number of RPS actuations not being reported in a timely manner. The licensee had written a memorandum allowing non-licensed operators to prepare blocking permits, which was contrary to administrative procedures. When notified of this discrepancy, the licensee revised the administrative procedure in an apparent non-conservative direction, to allow the non-licensed oper-ators to prepare the blocking permits. Licensee response to these issues is under review by the NRC.

In summary, operations is staffed with an adequate number of licensed and non-licensed operators, and management personnel. Appropriate procedures and hardware are in place. However, during the recent history of extensive outage activities a complacent attitude towards procedural adherence and support of plant operations has become evident. Management actions to address these issues in the past have not been effective.

l

..

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

'

.

19 .

Conclusion Rating: Category 2 Trend: Declining Board Recommendations Licensee:

--

Address the apparent complacent attitude and stress procedural compliance.

-- Address the number of and repetitiveness of reactor scrams and personnel errors.

NRC:

-- Conduct a team inspection to better understand underlying reasons for licensee's historial performance problems.

,

l l

l

.

- - -

y -- - - , , - c

--_-. ___ _-

.

'.

4.2 Radiological Controls (12%, 495 hours0.00573 days 0.138 hours 8.184524e-4 weeks 1.883475e-4 months )

Analysis Inspection efforts in this area included six inspections by Region Specialists in the program areas detailed below; and, two inspections conducted by Agreement State representatives and reviewed by NRC Region I. Day-to-day review of ongoing activities was provided by the Resicent Inspectors.

During the previous assessment period, programmatic weaknesses in the radiation protection and transportation areas resulted in the radiological controls area being assessed as Category 3. During the current assessment period, significant problems were noted in the transportation area. However, improvements were noted in radiation protection. The overall area of radiological controls has improved.

Radiation Protection Four inspections, including a special team inspection during the Unit 3 refueling outage, indicated that management attention was directed to improving performance in radiation protection. A plant reorganization separated the radiation protection and chemistry functions, and established a separate ALARA section within the

'

radiation protection organization. Key positions, (e.g., the

.

Health Physicist-ALARA), within the reorganized radiation protection group were filled in a reasonable time. However, authorities and responsibilities for the Health Physicist-ALARA, altered duties of the Health Physicist Support and the new reporting relationship for the Senior Health Physicist were not reflected in the licensee's position guides and procedures.

The inability to take effective corrective action to prevent recurrence of radiation protection problems was brought to the licensee's attention during the previous assessment period.

Improvements in radiological controls for outage work activities were noted during this assessment period indicating that the licensee had directed attention to improving management review and control of radiation protection activities. Improvements in management review of outage work activities noted included: The assignment of lead radiation protection personnel, an improved communication of work

scope and job location, an increased surveillance of work areas, a

'

better review of work packages, a better defined outage responsi-bility for the newly-formed ALARA section, and weekly reviews of outage problem areas by senior radiation protection management.

t t

.

,

.

21 .

Corrective actions appeared to be effective as evidenced by the review of the Unit 3 core ~ spray sparger T" box repair activities.

The licensee conducted an adequate and generally effective planning and preparation phase including review of previous repair work, construction of a mock-up to train personnel, and use of a shielded work station to control exposures. External exposure controls were well-organized and included continuous dose assessment and control, adequate surveillance of potentially changing dose rates, and continuous access control to the work area. A generally adequate program to control contamination and prevent internal exposures to workers including auxiliary ventilation, close supervision of respiratory protection practices, and strict radiation work permit controls was noted. A generally improving ALARA program including dose tracking, administrative exposure control, and recording of exposures and dose rates for possible use during future work on Unit 2 was provided.

An ineffective training program for the radiation protection staff was noted during the previous assessment period. Training program improvements were noted in the training of contractor and senior licensee radiation protection technicians suggesting increased management attention. General employee training (GET) and general respiratory training (GRT) programs were satisfactory except for uncertain policies regarding pregnant female contractor employees.

In addition, professional staff training in radiation protection was lacking. Although the licensee had planned a 60 topic program of professional training to be completed over a three year period, (i.e., 1982-85), approximately one-half of the program had not been completed by July 1985. When brought to the licensee's attention, the licensee indicated that efforts were underway to provide additional training.

The review of the licensee's quality assurance program, as it related to the radiation protection program, indicated that management attention had been directed to improving and strengthening the licensee's capability to identify and correct radiation protection deficiencies. Radiation protection professional personnel reviewed ongoing work activities to ensure that radiation work permit and control point radiological controls were being observed. Quality control personnel inspected ongoing work activities to ensure that radiation work permit and control point radiological controls were being observed. Quality control personnel inspected ongoing work activities using detailed monitoring checklists containing appropriate radiation protection attributes. Audits of radiation protection operations and the ALARA program were conducted by qualified quality assurance personnel.

I

i

!

'

. l

,

!

Radioactive Waste Management and Effluent Monitoring Two inspections by Radiation Specialists reviewed the design, construction, testing and proposed operation of the low-level radioactive waste storage facility and effluent monitoring activities. The Resident Inspectors reviewed day-to-day operations of the licensee's radioactive waste management and effluent monitoring program. No effluent release limits were exceeded.

The licensee's safety evaluation report and PORC review'for the low-level on-site radioactive waste storage facility did not consider the potential radiological consequences of a fire in the facility's storage cells suggesting a lack of thorough technical review in the licensee's 10 CFR 50.59 review process. Review of the preoperational testing of the facility had not been completed although the testing had been completed indicating a lack of timely technical review. l Transportation Three inspections, including a special inspection and two inspections by Agreement State representatives reviewed by NRC Region I, identified five problems and several weaknesses in the transportation area. Burial privileges at two Agreement State waste disposal sites were temporarily suspended during the assessment period. An Enforcement Conference was held with the

'

licensee on November 14, 1985, to discuss the problems and weaknesses noted.

Multiple problems were noted in the transportation area. Repetitive problems with lifting cables used to remove palletized high integrity containers from shipping casks resulted in a civil penalty assessment and suspension of burial site privileges by South Carolina. Failure to provide a strong-tight container for a low specific activity container resulted in suspension of burial site privileges by Washington. Corrective action was timely and included studies to determine the causes of the problems and additional training for radioactive waste operators.

Poorly stated procedures for shipments of irradiated control rod blades suggesting inattention to technical detail in the review of special shipping procedures were noted. Procedures failed to ensure that each cask liner loaded into the Model FSV-1 shipping cask (Certificate of Compliance No. 6346) corresponded to the liner and contents described in the shipping papers. Procedures for draining residual fuel pool water from irradiated control rod blade shipments resulted in contamination of the external trunion cup area of the FSV-1 cask. Timely corrective actions taken by the licensee included a quality control verification of the liner / shipping paper correspondence and a provision for access to the trunion cup area for I decontamination and contamination surveys.

_ _ _ _ _ _ _ _ _ _ _ _ _

.

'

.

Events, including the problems with control rod blade and routine radioactive waste shipments, were reported in a timely manner

,

although information relating to the causes and potential corrective actions was incomp!ete when reported. The licensee promptly dispatched professional representatives to the burial sites to assess and review the problems and recommend corrective actions. At the Enforcement Conference on November 14, 1985, the licensee addressed each probler.1 noted with immediate corrective actions and long term follow-up plans.

A generally effective surveillance and inspection program was implemented by the site quality control organization including detailed monitoring checklists and mandatory inspection hold points in procedures related to shipping. -

Review of the licensee's quality assurance program in July 1985, as it related to transportation activities, indicated that the licensee had implemented an audit program for shipping activities addressing

~

applicable criteria in 10 CFR 50, Appendix B. Corrective action measures initiated as a result of audit findings were reviewed for implementation during follow-up audits. Adequate quality assurance }

procedures and checklists have been used in auditing shipping activities. The licensee reviewed the quality assurance program to ensure that adequate procedures were in place to implement the quality assurance plan for transport packages.

Conclusion Rating: Category 2 Trend: Consistent Board Recommendations Licensee:

--

Complete long-term transporation related corrective actions discussed during the November 14, 1985 Enforcement Conference.

-- Evaluate the effectiveness of the QA program relative to transportation related problems.

NRC:

-- Conduct augmented inspection of transportation area and QA activities to review licensee's long-term corrective actions.

\

.

_ _ . - _ . _ _ _ _ _ _ _ _ _ . _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . _ _ _ _ _ _ _

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

'

.

4.3 Maintenance (9%, 367 hours0.00425 days 0.102 hours 6.068122e-4 weeks 1.396435e-4 months )

Analysis The maintenance area was assessed as Category 1 for the previous SALP period. That assessment observed that management was strongly involved in maintenance activities, personnel were well trained, work adequately planned, procedures were found to be detailed, and maintenance workers were observed to follow procedures.

During this assessment period maintenance activities were reviewed during each resident inspection. Specialist inspections examined maintenance and related activities during reviews of plant modifi-cations, responses to IE Bulletins, reviews of corrective and preventive maintenance programs, and maintenance associated with outages on both units. Specific maintenance activities reviewed included; snubber testing and rebuilding, emergency service water i

(ESW) system cleaning and ESW pipe replacement, control rod drive exchange, diesel generator maintenance, RHR pump and valve inspec-tions and repairs, core spray sparger work, and plant modification.

During this assessment period the licensee has been generally responsive to NRC concerns regarding maintenance activities.

Poor work practices by maintenance personnel resulted in 13 unplanned 4 reactor scram signals while shutdown. The cause of these scrams was due to bumping reactor scram sensors and cables under the reactor vessel. Also, two unplanned reactor shutdowns were caused by inadequate spare parts for safety related valves.

Extensive management involvement in the larger maintenance activities has resulted in a beneficial influence on both the control and the quality of maintenance and modifications. Large maintenance tasks appear to be well planned and executed, as demonstrated by both the recent control rod drive (CRD) changeout and the core spray sparger "T" box repair on Unit 3. The licensee pro-vided adequate mock up training and had detailed procedures for both tasks. Few problems were encountered with the CRD changeout and the work proceeded on schedule. The MOD associated with the repair of the crack in the core spray sparger was examined in detail. The work inside the rei;.or vessel was well planned and conducted in an efficient manr.er with minimum personnel radiation exposures.

Smaller maintenance tasks appear to suffer in many cases from lack of planning and management attention. It appears that the smaller jobs may result in a lower quality of work. The problems associated with the three failures of Unit 2 RHR 154A motor operated valve could have been reduced with more accurate and specific maintenance procedures, better vendor information, and a more thorough determination cf failure root causes. Maintenance Division workers apparent 1 /

installed the valve operator yokenut and locknut spare parts on the valve stem without consideration of proper thread engagement. The

_

i

_. - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _

.

'

.

25 ,

poor thread engagement fit caused two additional failures, requiring a shutdown of Unit 2 each time. Maintenance Division engineering was not contacted until the second valve failure. It appeared to take two Unit 2 shutdowns to get appropriate management attention to the valve repair activities.

Several inspections reviewed the corrective and preventive maintenance programs. The programs were found to be adequately established and activities were being monitored via the Computerized History and Maintenance Planning System (CHAMPS). A portion of the equipment qualification program was also being incorporated into the CHAMPS. The computer program gives the licensee a better capability for researching equipment history and trending equipment failures. A post maintenance testing program, as required by Generic Letter 83-28, was found to be in place and was being implemented satisfactorily.

As a result of problems identified in the use of liquid nitrogen for containment inerting at another BWR in early 1984, an inspection followup was conducted regarding licensee actions in response to five recommendations made by General Electric. Four of the five recom-mendations had been carried out by the licensee. However, the evaluation of inerting system operation involved a commitment to functionally test such operational features as the liquid nitrogen

{

vaporizer, a low temperature shutoff valve and a low temperature switch. The modifications to perform this testing, the test proce-dure and the test had not been accomplished in a timely manner.

There has been slow response and considerable delay in the imple-mentation of commitments made in March 1984.

A large number of Unit 3 safety related snubbers failed the func-tional tests performed. Questions were raised regarding test acceptance criteria, the consequences and causes of the large number of failures, and proper maintenance practices. Similar problems were noted on Unit 2 snubbers during the December 1985 outage. The pro-gram for assessing operability of snubbers needs continued licensee management review.

During this assessment period, a number of problems occurred with the RHR pumps which required a large maintenance commitment. Problems included a fire in the 3C RHR pump motor, wear ring cracking on several RHR pumps and low flow conditions with the 2A RHR pump. The related maintenance activities appeared to be well planned with adequate management attention. The licensee's investigation of root causes and subsequent reporting of the RHR pump wear ring problems appeared to be thorough.

!

k

_.

.

26 ,

Several inspections focused on diesel generator (DG) maintenance activities, including the removal of the interpolar connecting bars, the replacement of the scavenging air blower, and the DG annual preventive maintenance. Maintenance workers were found to be knowl-edgeable, well trained, and performed the work in a timely manner.

However, there appears to be a lack of communication between Maintenance Division workers and Maintenance Division engineering.

It appears that Maintenance Division foremen were the only ones knowledgeable of two service information letters (SILs) issued by Fairbanks-Morse in November 1984 and October 1985 concerning the potential for scavenging air blower failure when running the DG at low loads. Apparently, maintenance engineering, mechanical engineer-ing and operations personnel did not become aware of the SIls until after the DG scavenging air blower failure. Wider knowledge of the SILs could have prevented running the DG for 51 hours5.902778e-4 days 0.0142 hours 8.43254e-5 weeks 1.94055e-5 months at low loads.

Formal controls over vendor manuals have been established and vendor evaluation of the state of the manuals was obtained. However, neither site maintenance procedures nor the Walworth vendor manual for the RHR 154A motor operated valve were specific enough to include the actual stem engagement design.

The licensee uses operating experience feedback in its maintenance program. For example, based on problems with Unit 3, the ESW piping

{

was cleaned and some pipe sections replaced. The work proceeded noticeably smoother on Unit 3 than earlier work on Unit 2. Other examples include expanded maintenance activities on the RHR pumps and snubbers.

A review of maintenance considerations to safeguard against over-pressurizing low pressure ECCS piping indicated that activities were well planned and conducted. The maintenance history on the interface valves is stored on a computer and is readily retrievable for engi-neering studies. The desigt. of piping systems and testing logic provides protection against overpressurization of the low pressure piping. The interface valve leak tighness is assured through implementation of the preventive maintenance program.

Conclusion Rating: Category 2 Trend: Consistent Board Recommendations Licensee:

--

Improve the control of vendor information.

I NRC: None

.

O

'

.

i 4.4 Surveillance (12%, 483 hours0.00559 days 0.134 hours 7.986111e-4 weeks 1.837815e-4 months )

- Analysis In the current assessment period, region-based inspectors conducted inspections of the containment integrated leak rate test (CILRT) and the local leak rate test (LLRT) programs. Inspections &lso reviewed surveillances applicable to health physics, fire protection, refueling equipment, maintenance activities, snubbers, emergency preparedness, and environmental monitoring. A programmatic review of the surveillance program was conducted during the Unit 2 restart team inspection. Resident inspectors routinely reviewed selected surveillance program areas each month.

The previous assessment period noted the following problems regarding surveillance test activities: surveillance tests not completed after the tests had begun, specific steps required by

. Technical Specifications not denoted as such, inadequate review of surveillance results by technical personnel and failure to follow a surveillance test procedure. These problems were not evident during this assessment period.

Management involvement in prioritizing personnel assignments to assist in the surveillance test program was good. Management was also

,

involved in surveillance test preparation and solving problems that I arose. The licensee took conservative positions on surveillance

,

testing when questionable areas were identified, and was generally responsive in providing requested information.

There were six automatic scrams during this assessment period related to surveillance testing. Four of these scrams were attributed to personnel error and two resulted from random equipment failures. The scrams were all on Unit 2. During Unit 2 pre-startup testing, tech-

-

nicians used a new instrument line backfilling device which caused excessive water pressure to the instrument lines and resulted in scram signals while shut down. Use of this new backfilling device was suspended. Attention to detail and proper planning could have eliminated most of these events.

Two surveillance tests were missed during the assessment period.

One of the tests was an I&C surveillance on a portal monitor and the other was a Unit 3 safety relief valve (SRV) manual actuation test.

The missed I&C surveillance was due to an oversight by the I&C group.

The SRV test was only partially completed (8 of 11 SRVs tested) and resulted in 3 SRVs not being tested during the Unit 3 cycle from September 1983 to July 1985.

l.

- _ _ _ .

.

28 .

Plant chemistry was reviewed during routine resident inspectior.s and during two specialist inspections. A reorgnization of the chemistry group is considered to be a licensee strength based on the following:

(1) a full time Senior Chemist heads the group, (2) the chemistry group reports directly to the Superintendent, Operations, and, (3) the reorganization improves ties with plant operations. A review of the chemical analytical program determined that the licensee has the capability to make consistently accurate radioactivity and chemical measurements. A goal of 0.3 micrombos/cm has been set for reactor water conductivity. The goal is well below the Technical Specification limit of 5.0. When the goal is not achieved, plant power reductions or shutdowns have been effected to repair condenser leakage. Thus, an overall conservatism has been shown by the licensee with respect to operational chemistry.

The Unit 2 and Unit 3 CILRT were satisfactorily conducted during the assessment period. The contractor was effective in assisting the licensee during test performance. A problem regarding the LLRT test direction for stem leakage with valve A0-2502B ouring the Unit 2 test was handled properly. However, the licensee did not immediately take the initiative to see if other valves had the same potential for untested stem leakage.

The "as-found" Unit 2 LLRT data required some engineering judgement

to support leakage values. Even though conservative values were used, the licensee recognized that engineering judgement was a weak justification for the as found leakage value. The licensee recognized that in a few cases a LLRT was not performed prior to maintenance. The licensee subsequently ensured LLRTs were performed prior to maintenance and improved LLRT performance on Unit 3. The CILRT personnel have now been given responsibility for the LLRT pro-gram, and an improvement in test control has been noted.

'

During a review of the surveillance program near the end of the assessment period, a major weakness was noted. Neither the Peach Bottom Technical Specifications nor administrative procedures address -

requirements or contain guidance regarding actions to be taken relative to overdue surveillance tests. Management controls for the j

surveillance testing program are not adequate to ensure system

!

operability when called upon to function in that the current program I

does not address actions to be taken when the equipment surveillance l

testing interval has been exceeded. This is indicative of a lack of management sensitivity to assuring system operability.

l In summary, improvements are noted in leak rate testing conduct, l however management philosophy toward the conduct of the surveillance

!

program is weak.

l l

l t

l l . _ _ _ . _ _ _

.-

- _- .

.

- i..

,

S. 29

- g-Conclusion

Rating: Categ'ory 2

, 1 Trend: . Declining Board Recommendations Licensee:

-- Establish management policy and controls which reflect the relationship between surveillance testing and equipment and system operability NRC: None i

o

.; .

--

- - . . - - . - - - . - - . , , , , , , - - , . . . - - - - - -

- - - - - - - - - - - - , . - - . - - - - - _ , - . - . - . - - - - - - - - - , - , - - . -

.

,

'i t

4.5 Fire Protection (4%, 173 hours0.002 days 0.0481 hours 2.86045e-4 weeks 6.58265e-5 months )

Analysis In the current assessment period, fire protection was reviewed during two specialist inspections and as part of each resident inspection.

A routine specialist inspection was conducted for fire protection modifications required by 10 CFR 50, Appendix R Sections III.G.3 and III.L. A reactive specialist inspection investigated the cause and corrective actions associated with a cable tray fire in the Radwaste Building.

During the previous assessment period, the licensee coqtinued to make improvements in fire protection. Maintenance of fire barriers, access to fire equipment, outage related housekeeping activities and onsite fires were identified as areas requiring improvement and increased management attention.

The licensee developed detailed modification packages for the design changes, construction, and post-modification testing for plant modifications for Alternate Shutdown Capability (10 CFR 50, Appendix R, Sections III.G.3 and III.L). The modification packages were reviewed for technical adequacy and compliance with the NRC requirements and the licensee commitments in this area. The i licensee's administrat!ve procedures were verified to be adequate

~

for the control of the modification activities. Licensee personnel involved in the various stages of the modification are well qualified and trained. Human factor considerations were employed in arranging the devices and switches on the alternate shutdown panels, maintaining similerity to the control room configuration.

Two major fires occurred during the assessment period. The first fire occurred on November 2, 1985, in the 3C RHR pump motor (Unit 3). The fire was detected by installed fire detectors. The second fire occurred on November 10, 1985, in a non-safety related cable tray and divers' equipment cage in the Radwaste Building

(common to Units 2 and 3). This fire was detected by a roving fire watch, and subsequently by alarming fire detectors. Licensee fire brigade response in locating both fires and subsequent fire suppres- '

sion with portable equipment was good. The cause of the 3C RHR pump motor fire was equipment failure resulting in the motor oil reservoir and the motor windings igniting. The cause of Radwaste Building cable tray fire remains unknown.

With respect to the Radwaste Building fire, a lack of conservatism was evidenced by the licensee's interpretation of the fire protection requirements. If a degraded fire barrier exists, TS require that a continuous fire watch be posted or a roving watch be established, if the detectors on one side of the affected barrier are operable. The fire hazard analysis had cetermined that a fire barrier is required ( for the Fan Room of the Radwaste Building to comply with Appendix R, i

l

!

_ _ _ .

.

=

.

,

31 .

'

isSection III, and additional detectors are required in the Fan Room.

Since the existing detection system was operable, the licensee established a roving fire watch. Although the licensee met the TS, a conservative interpretation would have provided for a continuous fire watch since the same study that identified the need for a fire barrier also identified the need for additional fire detection. After the fire, a continuous fire watch was established.

Conclusion Rating: Category 2 ~

Trend: Consistent Board Recommendations Licensee:

-- Assess the results and evaluations of the radwaste building

,

cable tray fire.

NRC:

--

Meet with licensee to discuss the assessment of radwaste

!

building fire.

l

.

. . - _ -

,

.

,

t

's 4.6 Emergency Preparedness (10%, 431 hours0.00499 days 0.12 hours 7.126323e-4 weeks 1.639955e-4 months )

Analysis During the assessment period, emergency preparedness activities included a programmatic inspection in June 1985 and observation of the annual emergency preparedness exercise in October 1985 by a team of twelve NRC and NRC contractor personnel. The Resident Inspectors monitored licensee performance throughout the period.

During the previous assessment period, problem areas were identified in the training of personnel in the emergency preparedness organization, in licensee audits, and in failure to provide accurate emergency initiating conditions. These areas were re-evaluated during this assessment period. Although progress was made in all of the deficient areas, the licensee was slow to *

re,spond.

During the annual emergency exercise significant deficient areas were noted. These deficiencies were partly due to lack of training for emergency personnci (which was delayed due to the Unit 2 piping replacement outage) and resulted in a confirma',ory action letter (CAL) issued on November 5, 1985. The CAL addressed four areas that required improvement including:

1) Clear delineation of the current emergency organization with authority and responsibilities well documented in the Emergency Plan; 2) Definitive protective action decision-making procedures with the basis and methodology for implementation; 3) Precise emergency action levels based upon the integration of plant parameters, and radiological and environmental conditions, and; 4) Comprehensive training program for key emergency response personnel including both classroom and practical training.

The licensee's corrective actions for the first three areas have been completed. Training for key personnel is ongoing with the classroom and practical portion scheduled to t,e completed by March 31, 1986. In addition, three drills have been scheduled in 1986, prior to the next annual emergency exercise. NRC review of the above actions is pending.

!

.

,

. 33

.t Corporate support is more evident in the emergency planning program and a new corporate incident response facility has been completed and successfully tested as part of the last exercise. Current on-site staffing in the emergency preparedness area consists of one full-time on-site experienced planner, corporate staff support and two contractor trainers. An improvement in emergency planning staffing has been noted during the last few assessment periods.

The licensee's QA organization has not been used effectively to audit the overall implementation of the emergency preparedness program. Previously identified problem areas do not appear to be tracked and resolved. The audit program was found to lack followup on previously identified deficiencies in the emergency preparedness area.

In summary, the licensee has provided additional resources to resolve the identified problem areas. However, progress throughout the period, although steady, has been slow.

Conclusion Rating: Category 2 Trend: Consistent I

Board Recommendations Licensee:

--

Improve QA audit resolution and corrective action followup activities of emergency planning.

--

Promptly complete the actions required of the CAL.

NRC: None k

I

.

-e - .- ,n -

_m

.

-

.

,

34 .

.

4.7 Security and Safeguards (6*;, 238 hours0.00275 days 0.0661 hours 3.935185e-4 weeks 9.0559e-5 months )

Analysis Three unannounced physical protection inspections were performed during the assessment period by region-based inspectors. One material control and accounting inspection was conducted. Routine resident inspections continued throughout the assessment period.

Two security event reports were submitted pursuant to th'e requirements of 10 CFR 73.71. One report pertained to a computer failure and the other related to a failure in the AC power system.

Each event was adequately handled and appropriate compensatory security measures were implemented.

Security program implementation during periods of routine plant operations was satisfactory. However, during April 1985, with Unit 2 at the end of a major outage, a routine physical security inspection identified several problems (access control and alarm response) and an Enforcement Conference resulted. Similar problems were identified during June 1984, when Unit 2 was beginning the major outage. NRC identified problem areas were addressed by the licensee during a May 1985 Enforcement Conference and actions to prevent recurrence for the issues were provided at that time. The security problems stemmed j

from the licensee's less than adequate supervision and oversight of the security contractor.

In reviewing the security deficiencies that were observed during the April 1985 Unit 2 outage, of particular concern was the fact that members of the security force again did not respond to alarms in vital creas. The failure to respond to alarms was further l

compounded by a breakdown in communication between the licensee and the security contractor, in that there was confusion regarding the implementation of oral instructions. Security force members failed to recognize degraded security situations similar to the June 1984 events. Additionally, neither the contract security supervisors nor licensee management were exercising sufficient oversight of the guard force; and, they were either unaware of or did not recognize certain events as serious security system breakdowns.

Although senior licensee management made a previous commitment to NRC to provide more effective oversight of the security contractor, there was still a serious lack of pre planning by the security

.

!

staff for major maintenance outages. The problems which occurred during the last assessment period and those during this period appear to share the same general root cause: inadequate licensee management attention to and control of the security contractor. In

,

l

! addition, the failure of the security staff to adequately plan and prepare for outage periods is evident. The security force contractor did not fully analyze the additional outage security -

l l

__ _ _ _ _ -

.

,

.

b ,

t needs or take positive and effective action to meet the objectives of commitment; outlined in the NRC-approved physical security plan.

Additional management attention to this matter was required.

During the assessment period, the licensee transmitted revisions to the Security Plan under the provisions of 10 CFR 50.54(p). These revisions were in response to NRC letters advising that portions of a previous plan change were not considered acceptable and required modification or a change to the previously approved plan. The revisions were submitted by the licensee as reouested and these were considered acceptable. In general, the plan changes were found to be of good quality and indicate a thorough knowledge of security objectives. The licensee's corporate security staff is responsible for ensuring that security plans are maintained current and for coordinating changes when required. The licensee has been effective in this area and have been responsive to Region I concerns and comments regarding security plan changes. They also communicate with Region I staff when more complex changes are required.

During the latter portion of this assessment period, some improvement in the overall performance of the licensee's security management staff and that of the security force contractor was apparent. The licensee has hired a Nuclear Security Specialist to assist the i

Administrative Engineer and Plant Manager in responding to the needs of the security program. The findings of a recent security special-ist inspection demonstrated the effectiveness of this action as

'

evidenced by more timely and comprehensive response to previous inspection findings. The security force contractor has proposed an enhanced training and qualification program for its personnel which exceeds the existing training standards and is designed to respond better to the current and future security needs of the licensee. The proposal is currently under evaluation by the licensee. These actions demonstrated that increased management attention was being directed to security program implementation.

Conclusion Rating: Category 3 Trend: Improving Board Recommendations Licensee:

-- Provide closer day-to-day management ovarsight to assess the control of the contractor security force.

l

.

~_ ---

.

-

.

,

36 ,

-- Establish measures to anticipate demands for needed resources of the security organization.

NRC: None i

.

-

_ _ _ _ _

.

-

.

,

.

'

,

'

4.8 Refueling / Outage Activities (16*4 666 hours0.00771 days 0.185 hours 0.0011 weeks 2.53413e-4 months )

Analysis

The previous assessment of refueling / outage activitie' ocused on Unit 2 because it was shut down for most of the periou co replace recirculation system and RHR system piping. The licensee's performance was Category 1 during the last evaluation period.

During this assessment period both units experienced outages. Unit 2 was in the pipe replacement outage from the beginning of the period until July 6, 1985, when the unit was restarted. On November 29, 1985, Unit 2 went into a mini-outage for equipment qualification (EQ)

modifications and other work until returning to service on December 25, 1985. Unit 3 was shut down on July 14, 1985, for its sixth refueling outage and remained in an outage through the end of January 1986. Unit 3 experienced problems during the outage, such as damaged jet pump instrument lines, broken shroud head hold down bolts, extensive weld overlay work and NDE, all-inclusive snubber inspections and repair, RHR pump inspections and repair, DG scavenging air blower failure, and core spray sparger repair.

Team inspections were performed to assess the readiness of each unit .nrior to restart. Various regional inspectors examined ( outage / refueling activities and the resident inspectors reviewed licensee activities in this area during each inspection. Aspects of outage activities assessed during this period included QA and QC coverage, modification control and acceptance testing, welding, purchasing, inservice inspection (ISI), nondestructive examination (NDE), control of contractors, management involvement, procedures, planning, audits, fuel reconstitution, core reload, and response to generic issues.

Licensee engineering took an active role in the resolution of problems related to intergranular stress corrosion cracking (IGSTC)

indications found in the Unit 3 recirculation and RHR system piping, core spray spargers, and the recirculation inlet and outlet nozzles. Contractor engineering and construction services were used effectively and NRC was informed of work status and problems in a timely manner. Where weld overlay or welding was used to provide structural strength, welder qualification, performance of welding, documentation and QC involvement were determined to meet ASME code standards and regulatory requirements.

Review of ISI activities of Unit 3 was directed toward work in meeting the requirements of NRC Generic Letter 84-11 for detection of IGSCC. The licensee's ISI program was staffed with an adequate number of competent, knowledgeable personnel. Planning and careful completion of tasks in 151 was evident. Contractor services were used for NDE of stainless steel recirculation and RHR piping welds,

. _ _ _ _ _ _ _ _ __

.

,

38 ,

.

,

for overlays on Unit 3 welds, and the set up of equipment to detect and establish growth rates of IGSCC. An in-depth review of these activities concluded that licensee and contractor personnel provided excellent coverage of NDE work. The licensee provided for daily involvement of ISI coordinators and the authorized nuclear inservice inspector and for overall supervision of NDE activities in additicn to the normal ISI program.

Both resident and regional based inspectors reviewed the fuel reconstitution activities. The expertise of contractor personnel performing fuel reconstitution work was outstanding. Work performed by them was of the highest quality. However, problems were noted regarding QC activities (see section 4.10).

The licensee reorganized the outage management activities for the Unit 3 outage. In order to manage outage activities, daily meetings were held to discuss work status, problems and operational milestones. Rather than having one larger group for all activities the work was divided into smaller and more manageable areas including j fuel floor, drywell, reactor systems, and balance of plant. '

Coordinators were assigned to each area and shift engineers were on site at all times to handle any problems as they arose. The organization for managing outage activities appeared to work well.

j The Major Outage Recovery Effort (MORE) team established to coordinate the restoration activities in the Unit 2 drywell and to implement preoperational and system startup testing was well administered and staffed with experienced, competent personnel.

Hardware deficiencies identified by the NRC inspectors were already identified and tracked by the MORE team. The startup and preoperational testing of Unit 2 performed by the MORE team was well planned and documented.

Core reload activities for Unit 2 in May 1985 and for Unit 3 in November 1985 were adequately planned and conducted. During the Unit 3 core offloading, a peripheral fuel bundle was isolated from a source range monitor (SRM). The fuel bundle had been omitted in the fuel loading sequence used to offload the core. A temporary procedure change was made to allow continued fuel moves with one inoperable SRM in a quadrant of the core.

In summary, the licensee's refueling and outage activities are well planned and adequately implemented. The refueling and outage organization exhibited sustained excellent performance during the assessment period. Many difficult and unique problems were adequately handled. Good coordination among engineering, construction, maintenance, testing and outage organizations was evident.

l

.

Conclusion Rating: Category 1 Trend: Consistent Board Recommendations Licensee: None NRC: None I

k

.

I .

-

.

40 .

.

4.9 Training and Qualification Effectiveness (N/A)

Analysis During this assessment period, training and qualification effectiveness is being considered as a separate functional area for the first time. Training and qualification effectiveness continues to be an evaluation criterion for each functional area.

The various aspects of this functional area have been considered and discussed as an integral part of other functional areas and the respective inspection hours have been included in each one.

Consequently, this discussion is a synopsis of the assessments related to training conducted in other areas. Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy.

The discussion below addresses three principal areas: licensed operator training, non-licensed staff training, and status of INPO training accreditation.

During the assessment period, resident and specialist inspections routinely reviewed training. Two operator licensing exams were given by region-based examiners. Licensed operator requalification training was reviewed during the Unit 2 team restart inspection.

j Training was reviewed during programmatic reviews of operations (licensed, non-licensed and requalification), radiation protection, general employee training (GET), general respiratory training (GRT), maintenance, fire protection, emergency preparedness, and chemistry.

The licensee is proceeding with INPO accreditation of training programs. Training programs for Senior Licensed Operators, Licensed Operators, Non-licensed Operators, Chemistry Technicians, and Health Physics Technicians were accredited by INPO in May 1985. The remaining five programs (I&C, Electrical Maintenance, Mechanical Maintenance, Technical Staff and Management, and Shift Technical Advisor) have all been submitted and INPO accreditation visits at Peach Bottom are scheduled in April 1986.

Although the licensed operator training and requalification training programs function well as evidenced by NRC exam performance, a number of personnel errors have resulted in reactor scram signals and ESF actuations. Six scrams can be attributed to errors by licensed operators and two scrams can be attributed to errors by non-licensed operators. Also, four scrams can be attributed to errors by I&C Technicians during surveillanca activities.

(

,

~- - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _

.

,

.

GET and GRT were reviewed both during resident and specialist inspections. The overall GET and GRT programs appear to be adequate.

The effectiveness of an expanded GET and a new " Nuclear Professionalism - Job Orientation" training has not been assessed.

Poor performance during the annual emergency exercise can be attributed to inadequate training. Deficiencies were noted during the previous assessment period in emergency plan training. Based on this deficiency, the licensee accomplished the following: revised lesson plans and hired two experienced contractors to train the staff; and, developed a training matrix to document and track staff training. Although the licensee made progress, emergency plan training was not completed and key managers had not been trained.

During the annual emergency exercise, significant problems occurred stemming, in part, from this lack of training. (See Section 4.6)

An improvement in HP and chemistry technician performance during the assessment period was noted. The development and implementation of a five day senior HP technician training program is considered a licensee strength for the overall HP training program. A continuing training program for chemistry technicians was implemented in 1985 and attendance was good.

Maintenance related train. ,, that is conducted prior to actual i

in plant job performance, is considered a licensee strength.

'

-Reviews were conducted of the mockup training for the Unit 3 core spray sparger repair and of the formal control rod drive (CRD)

training. A mockup of the in-vessel core spray sparger piping and the shielded work booth was used to train maintenance personnel prior to the actual work. The mockup training was successful as evidenced by a smooth running maintenance evolution. The licensee has a formal training program for CRD mechanism assembly and disassembly. The training program includes use of an under vessel mockup of a CRD mechanism. The success of the CR0 training is evidenced by only minimal problems during the changeout of over 80 CRDs during the Unit 2 and 3 refueling outages. The man-rem doses for the above mentioned maintenance jobs were well below the initial estimates.

Cnnclusion Rating: Category 2 Trend: Consistent Board Recommendations Licensee: None NRC: None

\

!

. . _ _

. ..

.

'

L

-

.

42 .

4.10 Assurance of Quality (N/A)

Analysis Management involvement and control in assuring quality continues to be an evaluation criterion for each functional area. During this assessment period, assurance of quality is being considered as a separate functional area.

The various aspects of the programs to assure quality have been considered and discussed ti an integral part of each functional area and the respective inspection hours are included in each one.

Consequently, this discussion is a synopsis of the assessments relating to the quality of work conducted in other areas.

The previous assessment period highlighted several strengths in the licensee's quality assurance (QA) program primarily associated with engineering activities.

Activities examined during this period included: plant modifications, maintenance, operations, overlay welding, pipe inspections, equipment calibration, worker qualifications, material controls, chemistry, radiation protection, and plant outage recovery.

l The offsite review committee, the Nuclear Review Board, is i functioning satisfactorily and demonstrates a questioning attitude with regard to safety issues. However, the NRB has not demonstrated effectiveness relative to review and correction of identified lapses in procedural adherence.

The PORC should be more instrumental in improving operational safety particularly in the areas of reduction of personnel errors and improved procedural adherence.

The Independent Safety Engineering Group has been under staffed (1-2 vacancies) and without a permanent on-site supervisor for most of the assessment period. A daily review by ISEG of safety equipment and the effect on plant operations was stopped due to manpower limit-ations. The daily review had been initiated because of a prior experience with the simultaneous inoperability of a diesel generator and one train of containment cooling, and was a corrective action identified at the Enforcement Conference held o., February 8,1985.

The ISEG daily review was resumed only after the commitment was brought to the licensee's attention by the NRC.

(

- _ _ _ _ _ _ . _ _ _ _ _ _ _ _

.

'

.

The licensee's QA audits of the Unit 2 outage recovery were thorough both from the standpoint of scope of activities and depth of cover-age. Management use of the audit program was determined to lack effectiveness during the Unit 2 readiness inspection in that, no provision had been made to perform a final systematic review of open QA/QC problem reports to ensure disposition, as necessary, prior to plant restart. The licensee responded by developing a computerized program called QA Tracking and Trending System (QATTS) which allowed for a systematic review of open problem reports by the QA staff.

Open problem report information is provided to the Superintendent -

Operations for disposition before plant restart.

QA has not been used effectively to audit the overall emergency pre-paredness program or the annual exercise. Problem areas identified in the past do not appear to be tracked until fully resolved. For example, the need for precise emergency action levels have been identified in several NRC inspections of annual exercises.

QA oversight of surveillance testing activities was weak in that it did not identify weaknesses in the surveillance program such as the missed or partially completed surveillances, and the lack of pro-cedures regarding actions to be taken relative to overdue surveil-lance tests.

During the assessment period, quality control (QC) rersonnel were

'

frequently observed inspecting maintenance and surveillance

'

activities. The QC involvement in control rod drive (CRD) rebuild on both units, diesel generator maintenance, and weld overlay was strong. QC's method of sampling and reviewing local leak rate tests (LLRT) was assessed to be very effective. Both LLRT and containment integrated leak rate testing activities are reviewed in accordance with a detailed monitoring checklist which is specific to the type of test performed. The checklists were judged to be comprehensive and technically useful.

Licensee QC coverage of fuel reconstitution work on Unit 3 was weak. ;

Initially, the only personnel on the refueling floor significantly involved in the fuel reconstitution effort were contractor personnel.

QC checks were performed by the workers conducting the fuel recon-stitution activity. Licensee management personnel were unaware of the situation. When the problem was brought to management's attention, the licensee separated the QC function from the fuel I reconstitution effort.

I In summary, based on performance in several functional areas, the focus of established committees and management does not appear directed toward the resolutien of operational problems and the assurance of operational quality.

(

e

_ - . - -

____ _ _ _

. .

'

..

44 .

t Conclusion ,

Rating: Category 3 Trend: Consistent Board Recommendations Licensee:

-- Consider a management review to determine:

(1) the effectiveness of the several oversight groups and (2) the extent to which these groups are used to assure that performance improvements are achieved.

NRC: None

.

_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ -

.

-

.

,

.

,

4.11 Licensing Activities (NA)

Analysis The approach used in this evaluation was to select a number of licensing actions which involved a significant amount of staff effort or which were related to important safety or regulatory issues for the SALP performance period. The previous assessment period evaluated licensing activities as Category 1, with a declining trend.

The staff noted a trend during that period where management involve-ment and control did not appear to be fully functional. The trend manifested itself in the noticeable decline in the licensee's usually timely response and resolution of licensing issues and the need to give more attention to the significant hazards consideration deter-mination (Sholly determinations) that were submitted for each Technical Specification change request.

By letter dated July 9, 1985, the licensee responded to the above noted weaknesses of the previous SALP by indicating that their licensing staff had been increased in size and reorganized to improve the response time for licensing issues at Peach Bottom.

Actions considered during the current SALP evaluation include ifcense amendments requests, exemptions and relief requests, responses to i

Generic letters, and TMI and Salem (ATWS) items. Fifty-six licensing actions were completed during this evaluation period. A summary of actions active during this period is presented in Table 6. Strong management involvement and attention were especially evident during this period for those issues having potential for substantial safety impact and extended shutdowns; namely, the Unit 3 refueling and pipe inspection program and the proposed re-racking of Unit 2 and 3 spent fuel pools. Management screening of submittals in these two areas was highly apparent since the submittals were consistently clear and of high quality.

Both of these above actions show evidence of the licensee's capability for excellent prior planning, assignment of priorities, and the development of defined procedures to control activities.

However, despite the licensee's steps to respond to the previous SALP recommendations concerning licensing activities, there continues to be evidence of the lack of management attention in the areas of timely resolution of NRC initiatives and the variable quality of Sholly evaluations. Examples of significant delays in follow-up responses by the licensee include resolution of Technical Specifi-cations regarding Appendix J, purge and vent valves, containment cooling, and diesel fuel oil. Concerning Sholly evaluations, overall

'.

quality was still highly variable during the report period. Con-siderable NRC staff attention was required prior to Federal Register

, j publication on most Technical Specification change requests.

)

j 2 he

__ _ .- _ _ _ _ _ _ _ ,_ __ -_

. _ . _ . . _ _ _ _ _ _ -

_ _ _ _ _ _ _ _ _ _ _ . .

.

"

.

As indicated in the previous SALP, it was noted that a declining trend overall existed for licensing activities involving the Peach Bottom facility. As pointed out above, the same licensing weaknesses identified during the last assessment period remain basically uncorrected. Therefore, although the licensee has provided excellent

[

and timely resolution for certain select actions during this report period, the NRC staff continues to face a long-standing backlog of licensing actions requiring licensee follow-up before they can be resolved.

Conclusion Rating: Category 2 {

Trend: Consistent Board Recemmendations Licensee: None ,

NRC:

-- NRR Project Manager to meet at least quarterly with the licensee to discuss licensing issues (i .e. , backlogs, problems, schedules, and projected workloads)

.

_._

.

'

e :

'

, 47

.

c V. SUPPORTIf3 DATA AND SUMMARIES t

-

5.1 Investigations and Allegations Review Three allegations were received during the assessment period:

--

unqualified personnel sent to Peach Bottom to perform QC functions

--

potential overexposure during Unit 3 offgas pipe tunnel release

--

alleger fired for talking to NRC 5.2 Escalated Enforcement Actions 1. Civil Penalties Civil Penalty of 525,000.00 associated with NRC Inspection 277/85-11 conducted during period February 13 - 15, 1985 (previous assessment period). The violations were associated with radiation protection practices during the Unit 2 pipe replacement outage. The Notice of Violation and Civil Penalty were combined with escalated enforcement from Limerick (Enforcement Action #85-42 dated June 7, 1985).

2. Orders

.

None 3. Confirmatory Action Lettars (CAL)

CAL dated November 5, 1985, regarding actions to be taken by PECo in the area of Peach Bottom emergency preparedness. (See section 4.6).

4. Enforcement Conferences

--

May 13, 1985; Security violations

--

June 21, 1985; Apparent inattentive Unit 3 reactor operator

-- November 14, 1985; Radwaste transportation activities and recent violations 5.3 Management Conferences Held During the Assessment Period June 12, 1985; SALP management meeting

'

--

(

.

- _ _ - _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _

.

'

.

48 .

-- August 1, 1985; Status of the Peach Bottom June 18, 1984 Order

-- October 23, 1985; PECo Maintenance Division meeting

) 5.4 Licensee Event Reports (LERs)

1. Causal Analysis Fifty LERs were submitted during the assessment period for Units 2 and 3. The LERs are characterized by cause for each functional area in Table 1. Causally-linked event sets were identified.

LER Number 2-85-06 -- RPS actuations during shutdown caused when IRM 3-85-17 cables were bumped in the subpile room (see Table 3-85-21 5A) due to personnel work practices.

3-85-30 2-85-04 --

RDS and ESF actuations caused due to I&C tech-2-85-07 nician errors with the instrument backfilling 2-85-09 equipment and improper valving of instruments.

2-85-10

'

2-85-15 2-85-16 2-85-11 -- RPS actuations during turbine testing.

2-85-25 3-85-16 -- ESF actuations due to personnel errors associated 3-85-19 with testing and installing blocking permits.

3-85-24 3-85-26 3-85-13 -- Unit 3 piping cracks and IGSCC indications in 3-85-13, reactor components.

Revision 1 3-85-14 3-85-20 2. AE00 Review The Office for Analysis and Evaluation of Operational Data ( AE00) assessed the Licensee Event Reports (LERs). The review covered fifteen LERs submitted during the assessment period.

The LERs submitted were adequate in each important respect with few exceptions. The LERs provided clear descriptions of the cause and nature of the events as well as adequate explanations 1 of the effects on both system function and public safety. The I I described corrective actions taken or planned by the licensee l

- - - __ - .____- _ _ _ _ _ _ _ _ - _

_

.

'

,

.

- were considered to be commensurate with the nature, seriousness and frequency of the problems found. Table 1 provides a tabular listing of the LERs versus functional area.

The evaluation of the content and quality of a representative sample of LERs submitted by Peach Bottom 2 and 3 during the April 1, 1985 to January 31, 1986 SALP period was performed using a refinement of the basic methodology presented in NUREG/CR-4178. The results of this evaluation indicate that Peach Bottom 2 and 3 submitted above average LERs.

The principle weaknesses identified, in terms of plant safety significance, involves the safety consequence discussions. The deficiency in the safety consequence discussion concerns whether events are being evaluated such that the possible consequences of the event, had it occurred under a different set of initial conditions, are identified.

Another observation resulting from the evaluation involves the numbering of LERs. Two LERs for Unit 2 were numbered the same even though they were different events (i.e., LER 2-85-06).

In summary, the LERs indicate that the licensee provided ade-quate descriptions of the events. None of the LERs reviewed by AE00 involved a significant event or serious challenge to plant safety.

5.5 Automatic Scrams and Unplanned Shutdowns 1. During the assessment period, 19 automatic scrams and three unplanned shutdowns occurred on Unit 2.

2. During the assessment period, 13 automatic scrams occurred on Unit 3.

Table 5 summarizes all automatic scrams and unplanneo shutdowns.

'

.

', .

50 ,

.

,

TABLE I TABULAR LISTING OF LERs BY FUNCTIONAL AREA PEACH BOTTOM ATOMIC POWER STATION Area Number /Cause Code Total A B C D E X 1. Plant Operations 17 1 1 3 1 1 24 2. Radiological Controls 0

,

3. Maintenance 1 2 5 8 4. Surveillance 2 3 5 5. Fire Protection 2 2 4 6. Emergency Preparedness -0 7. Security and Safeguards 0 8. Refueling / Outage Activities 4 4 8 l 9. Training 0

10. Quality Assurance 1 1 11. Licensing Activities 0 TOTALS 24 4 1 3 5 13 50 Cause Codes:

A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D - Defective Procedure

! E - Component Failure X - Other l

,

i i

!

l t _ _ _ _

-- -

_ _ _

..

'..

.

-

<

TABLE 2 VIOLATION SUMMARY (4/1/85 - 1/31/86)

l/ PEACH BOTTOM ATOMIC POWER STATION l A. NUMBER AND SEVERITY LEVEL OF VIOLATIONS Number of l Violations Severity Level I O Severity Level II 0 Severity Level III 4 Severity Level IV 11 Severity Level V 2 i

Total 17 B. VIOLATIONS VS. FUNCTIONAL AREA Functional Area Severity Level III IV V Totals 1. Plant Operations '0 3 0 3 2. Radiological Controls 4 0 1 5 3. Maintenance 0 0 0 0 4. Surveillance 0 3 0 3 i 5. Fire Protection / Housekeeping 0 0 0 0 6. Emergency Preparedness 0 0 0 0 7. Security and Safeguards 0 4 0 4 8. Refueling / Outage Activities 0 0 1 1 9. Training 0 0 0 0 10. Quality Assurance 0 1 0 1 11. Licensing Activities 0 0 0 0 Total 4 11 2 17 i

.

.____ _ - _ _ _-.-_____-__-_____-__-_

_ _ _ _ _

.

-

. ,

.

C. ' SUMMARY LISTING Inspection Inspection Severity Functional Report No. Date Level Area Violation (s)

277/85-12 March 16 - IV Operations Failure to follow 278/85-12 May 10, 1985 procedures for Shift Supervisor relief and for checking seismic restraints 277/85-16 April 14-18, 1985 IV Security (1) Failure to 278/85-13 report changes in security program IV Security (2) Failure to post guard for access control to {

drywell IV Security (3) Failure to wear photo ID badge in protected area

,'

IV Security (4) Failure to respond to vital area alarms 278/85-23 June 4-13, 1985 IV Surveillance Failure to adequately test containment isolation valves 277/85-27 May 30, 1985 III Radiological Radwaste drum 278/85-23 Controls shipped to facility with hole 277/85-29 September 14 - IV Surveillance (1) Failure to 278/85-33 October 25, 1985 perform ST on portal monitor IV Surveillance (2) Failure to perform ST on Unit 3 SRVs IV Operations (3) Failure to make 50.72 and 50.73 notifications (

. . _ .

-

.

..' 53

.

Inspection Inspection Severity Functional Report No. Date Level Area Violation (s)

IV Operations (4) Failure to adhere to equipment blocking (tagout)

procedures 277/85-31 July 29 - III Radiological (1) Failure to 278/85-28 August 1, 1985 Controls include accurate activities in shipping papers III Radiological (2) Contamination Controls on exterior surface of FSV-1 cask V Radiological Improper Controls certification on radwaste shipment manifest 278/85-32 September 9-13 IV Quality Failure to 19S5 Assurance implement QA

,

program requirements 278/85-32 September 9-13, V Refueling Failure to comply 1985 Outage with written HP and QC procedures 277/85-39 October 18, 1985 III Radiological Improperly 278/85-40 Controls attached pallet lifting cables i

i I l

. (

.

54 ".

TABLE 3 IN5pECTION REPORT ACTIVITIES (4/1/85 - 1/31/86)

PEACH BOTTOM ATOMIC POWER STATION Report Number Inspection Hours Areas Inspected Unit 2 Unit 3 85-12 85-12 339 Resident Operational Safety 85-15 274 Unit 2 Restart Team Inspection 85-16 85-13 8 Security / Safeguards 85-17 36 Unit 2 Local Leak Rate Testing 85-19 85-15 12 Dosimetry 85-21 85-17 248 Resident Operational Safety 85-18 85-18 None Operator Licensing Exams 85-22 85-19 None Operator Licensing Exams 85-23 85-23 54 Unit 2 Integrated Leak Rate Testing 85-24 85-20 76 Emergency Preparedness 85-25 85-21 275 Resident Operational Safety 85-22 10 Inattentive Unit 3 operator 85-26 74 Unit 2 Startup Testing 85-27 85-25 4 Radwaste Shipping 85-28 85-26 140 Health Physics and Chemistry Team Special Inspection 85-29 85-33 297 Resident Operational Safety 85-30 85-27 296 Resident Operational Safety

'

85-31 85-28 33 Radwaste Shipping 85-32 85-29 80 Security / Safeguards f

!

_ - _ _ _ _ , _ _ . - _ _ . _ . _ _

.,. . _ _ .

__-..__. - _. _ _ _ _ _ _ _ . . _

.

'

, e

," 55

.

Report Inspection Hours Areas Inspected if Unit 2 Unit 3 85-33 85-30 118 Electrical and I&C Maintenance Programs

.

85-31 20 Health Physics Allegation Followup 85-32 41 Unit 3 Fuel Reconstitution 85-34 85-14 133 Generic Letter 84-11 and IGSCC 85-36 85-34 310 Emergency Preparedness Annual Exercise 85-35 72 Unit 3 Local Leak Rate Testing 85-36 28 Health Physics for Unit 3 Core Spray Sparger Repair and Low Level Radwaste Facility 85-37 85-38 33 Safeguards Material Control & Accountability 85-38 85-37 42 Unit 3 Core Spray Sparger Repair and Weld Overlays 85-39 91 Alternate Safe Shutdown Modifications 85-39 85-40 4 Radwaste Shipping 85-41 245 Resident Operational Safety and Unit 3 Restart Team Inspection

, 85-40 223 Resident Operational Safety 85-41 13 Followup On Radwaste Fire 85-42 85-42 15 Radwaste Enforcement Conference 85-43 85-43 42 Security / Safeguards ll l

.

, - . - - - - - - - -,-,n - -.-... a

.

'

. .

..

56 .

Report Inspection Hours Areas Inspected Unit 2 Unit 3 85-44 85-44 291 Resident Operational Safety 86-01 86-01 36 Radiological Effluents 86-02 78 Health Physics Training 86-02 67 Unit 3 Integrated Leak Rate Testing

,

i i

i l

I

'l

!

l l'l

,

!

i

.

'

, e

"

, 57

.

TABLE 4

'

INSPECTION HOURS SUMMARY (4/1/85 - 1/31/86)

PEACH BOTTOM ATOMIC POWER STATION Functio _nal Area Hours % of Time 4.1 Plant Ope rati on s . . . . . . . . . . . . . . . . . . . . . . . . 1300 31.3 4.2 Radiological Controls..... ............. 495 11.9 4.3 Maintenance............................. 367 8.8 4.4 Surveillance............................ 483 11.6 4.5 Fire Protection......................... 173 4.3

"

4.6 Emergency Preparedness.................. 431 10.4 4.7 Security and Safeguards.. .............. 238 5.7 4.8 Refueling / Outage Activities............. 666 16.0 4.9 Training **............... ............... 0 0 4.10 Quality Assurance **.. ................... 0 0 4.11 Licensing Activities *................... O _0_ ;

T0TAL....................... ... ............ 4153 100%

Hours expended'are not included with direct inspection effort statistics.

- Hours expended in training and quality assurance are included in other functional areas. .

i

,

a

- ._.

.

-

, ,

..

58 .

.

TABLE 5 LISTING OF ALL AUTL1ATIC SCRAM SIGNALS & UNPLANNED SHUTDOWNS PEACH BOTTOM ATOMIC POWER STATION Unit 2 (4/1/85 thru 1/31/86)

Power Level Description Cause Note 1 N

_o. Date 1 5/30/85 SD Scram signal from high pressure Personnel error -

while in cold shutdown (NO ROD reactor operator MOVEMENT) during hydro and excess flow check valve testing. Pressure increased due to test personnel stopping leak concurrent with operator actions to raise pressure.

(LER 2-85-02)

2 6/22/85 SD Scram signal when reactor level Personnel error -

transmitter was valved into I&C technician service too quickly causing false low level while in cold shutdown (N0 ROD MOVEMENT).

(LER 2-85-04)

<

3 6/22/85 SD Scram signal when reactor level Personnel error -

transmitter was being backfilled I&C technician with water. Incorrect operation of the backfilling assembly caused a false low level signal while in cold shutdown (N0 ROD MOVEMENT).

(LER 2-85-04)

4 6/27/85 SD Scram signal from two IRMs while Personnel work in cold shutdown (NO R0D practices MOVEMENT) while working in subpile room, maintenance personnel inadvertently bumped two IRM voltage cables causing a full scram signal. (LER 2-85-06)

5 6/28/85 SD Same as #3 above. (LER 2-85-07)

6 6/28/85 SD Same as #3 above. (LER 2-85-07)

7 6/29/85 SD Same as #3 above. (LER 2-85-09)

7/6/85 Startup from outage Note 1 - Determined by SALP Board, may not agree with LER analysis.

t

Scrams with Rod Movement

o

.

o o

59 i

Power

/- Level Description Cause No. Date Scram due to turbine control Equipment failure -

8* 8/5/85 100%

random setpoint valve (TCV) closure while testing at 100% power. EHC drift pressure experienced a normal momentary decrease during TCV

3 testing combined with set-point drift of TCV #4 pressure switch that actuates scram. The -

low pressure trip of both TCV #3 and #4 caused a full scram.

(LER 2-85-11)

8/7/85 Startup

'9* 8/7/85 2% High IRM scram at 2% power during Personnel error -

unit startup. Reactor operator reactor operator withdrew a high worth rod two notches during startup mode to control reactor pressure with EHC out of service. He failed to uprange switches and an IRM high-

/ high scram occurred. (LER 2-85-12)

8/8/85 Startup Shutdown required by TS due to Inadequate 10 8/12/85 simultaneous inoperability of maintenance spare the E-3 DG and RHR loop A (MOV parts RHR 154A). (LER 2-85-13)

8/14/85 Startup 11 8/19/85 Same as #10 above, except E-2 DG inoperable.

Low level scram signal while in Personnel error -

12 8/20/85 SD reactor operator hot shutdown (N0 R0D MOVEMENT)

during plant cooldown. Actual low level occurred due to slow response of level controller, combined with inattention of reactor operator during level swings. (LER 2-85-14)

\

.

-

, ,

..

60 ,

,

Power Level Description Cause No. Date False low level scram signal Equipment failure -

13 8/22/85 SD random while in cold shutdown while in cold shutdown while testing a pressure transmitter (N0 ROD MOVEMENT). A leaking instrument isolation valve resulted in a pressure spike on the level sensing lines resulting in full RPS actuation. (LER 2-85-15)

8/26/85 Startup Low level scram from 5% power Personnel error -

14* 8/26/85 5%

non licensed during plant startup when a pressure transmitter was in- operator correctly returned to service by an operator. The resulting false low level caused by pressure spikes on the sensing lines caused a scram.

(LER 2-85-16)

8/26/85 Startup 9/19/85 Shutdown required by TS due to Low flow due to 15 unmodified impeller simultaneous inoperability of the 2A RHR pump and the E-2 DG.

(LER 2-85-19)

16 9/24/85 SD Low level scram signal while in Personnel error -

reactor operator cold shutdown (N0 R00 MOVEMENT).

Operator incorrectly aligned RHR while in shutdown cooling, causing an actual low level as the vessel drained to the torus.

The operator did not follow the procedure. (LER 2-85-20)

10/4/85 Startup Low level scram from 100% power Equipment failure -

17* 10/17/85 100% random due to loss of feedwater when all RFPs tripped, caused by a faulty connector on the total flow summer in the reactor feed-water level control system.

(LER 2-85-22)

.

o

'

,

e.

61 f

Power No. Date level Description Cause 10/18/85 Startup 18* 11/29/85 31% Scram from 31% power due to Personnci error -

turbine stop valve closure operations with inadequate control of

' troubleshooting by operators.

The reactor operator's misunder-standing of control room alarms regarding scram bypasses con-tributed to the scram.

(LER 2-85-25)

12/24/85 Startup

.

19' 12/26/85 44% Scram from 44% power due to low Personnel error -

level during reactor feedwater reactor operator system transient. A combination of feedwater control and RFP equipment problems combined with licensed operators swapping RFPs at power resulting in a water hammer in feedwater system and loss of RFPs. (LER 2-85-27)

12/29/85 Startup 20* 1/1/86 90% Scram from 90% power due to Personnel error -

turbine trip caused by moisture operations separator high level trip. A combination of a faulty moisture separator drain valve and a non-licensed operator personnel error ,

causing the dump valve to close resulted in a high level trip.

(LER 2-86-01),

1/2/86 Startup APRM high scram from 95% power Multiple random i 21* 1/24/86 95%

equipment caused by high reactor pressure when the E-2 DG tripped (half failures - design scram) when carrying an RPS bus, and 2 MSIVs closed due to DC

solenoid failures. (LER 2-86-03)

.

- . - _ - _ - _ . . - _ - - _ _

-

m.._ __ ,_ _ . _ _ _ _ _ . _ _ _ _ . _ _ - , . _ _ _ _ _ _ . . _ _ _ _ _

_ _

,__

. . - , - . . . . . . _. . - . . - _ . _ _ .

s s

'

,=

62 .

P 1/24/86 SD Voltage transient on #2 startup Equipment failure - ,

source when 2A recirc MG set design .

started causing a voltage dip in 2B RPS logic power supply on alternate feed resulting in loss c of power to SDV high level bypass relays. Since the SDV level was high due to an actual scram (see

<

21 above), a second full scram a

signal occurred. (LER 2-86-04)

,

i

!

i I

l

[

!

I

!

't I

a i

y

!

I

,

l ,

_ _ _ _ . , _ _ . . _ _ _ _ _ . . _ _ _ _ . . . _ . . . . _ . . _ , _ _ _ _ _ _ _ _ , , _ _ , , _ . . . _ _ . . . _ . _ _ _ _ _ , _ , , _ _ . _ . . . . . _ . _ _ _ _ , . , _ _ . . _ _ _ , . . _ . - _ _ . , _ . _ _ _ _ . . , , . , _ .

.

'

e,o

63

.

f Unit 3 (4/1/85 thru 1/31/86)

Power Level Description Cause

_No. Date Scram signal with no fuel in the Personnel work 1 8/26/85 SD practices -

reactor vessel (N0 ROD MOVEMENT)

when worker bumped one IRM cable maintenance in subpile room. Scram occurred

.

because one RPS channel was out of service (tripped) due to relay maintenance and IRM tripped the other RPS channel. (LER 3-85-21)

2 8/28/85 SD Same as #1 above.

3 8/29/85 SD Same as #1 above.

4 9/11/85 50 Same as #1 above.

Similar te 81 above except Personnel work 5 9/11/S5 SD worker bumped SDV high level practices -

switch and scram due to SOV maintenance level high. (LER 3-85-22)

.,

6 9/12/85 50 Same as #1 above.

7 9/13/85 SD Same as #1 above.

8 9/13/85 SD Same as #1 above.

9 9/14/85 SD Same as #1 above.

10* 10/10/85 SD Same as #1 above except two IRMs were bumped and some rod movement occurred. The control rods were withdrawn with core defueled for ALARA considerations during core spray sparger work.

11 10/18/85 SD Scram signal with no fuel in the Control of work reactor vessel (NO R00 MOVEMENT) activities when engineer removed jumpers from the RPS logic in accordance with special procedure. A half-scram was already present due to maintenance on one RPS channel.

The procedure did not provide a caution when half scram was already present. (LER3-85-16)

{ l i

l

.

J

O

o,e .

'

f Power Date Level Description Cause

_o.

N 12 10/18/85 SD Same as #1 above. (LER 3-85-17)

13 12/17/85 50 Same as #1 above, except the reactor core was loaded and in cold shutdown. (LER 3-85-30)

, ----______ _ _ _ _ _ _ _ _ _ _ _ _

o a

o,'

O 65

.

TABLE 6 NRR SUPPORTING DATA AND SUMMARY PEACH BOTTOM ATOMIC POWER STATION 1. NRR/ Licensee Meeting / Site Visits Site Visits: June 12, 1985; November 21, 1985 '

Meetings: 05/13/85: SALP Board Meeting 05/30/85: " Energy Absorbers" 06/14/85: SPDS 09/05/85: Unit 3 Pipe Cracks 09/17/86: Unit 3 Core Spray Sparger Cracks 10/01/85: Unit 3 Cracks in Safe Ends 10/31/85: N-1 Safe Ends 12/19/85: Cracks in Shroud Head Bolts and Wear Rings 2. Commission Meetings None 3. Scheduler Extensions Granted 08/05/85; submittal of DCRDR Summary Report 4. Relief Granted 05/14/85; ISI Relief 5. Exemptions Granted None 6. License Amendments issued Amendment Nos. 109, 112 issued June 6, 1985; approves miscellaneous TS changes Amendment Nos. 110, 113 issued July 17, 1985; approves 50.72 & 50.73 reporting requirements Amendment Nos. 111, 115 issued October 2,1985; approves correction of set points of Emergency Plan Test Frequency Amendment No. 114 issued August 23, 1985; Unit 3 Reload Amendment Nos. 112, 116 issued November 19, 1985; approves changes in coolant leakage detection systems Amendment Nos. 113, 117 issues November 19, 1985; Nureg-0737 TS Amendment Nos. 114, 118 issued November 22, 1985; revised certain portions of RETS 7. Emergency / Exigent Technical Specifications None 8. Orders Issued None

.

9. NRR/ Licensee Management Conferences None

,

s

,

.

' ,o

,

.

'

Figure 1 Unit 2 - Number of Days Shutdown PEACH BOTTOM ATOMIC POWER STATION Apr. 85 Sixth Refueling Outage l 30 Days Shutdown l l

May 85 31 Days Shutdown ;

I I

June 85 30 Days Shutdown I

10 Day $ Shutdown July 85 _l 11 Days Shutdown Aug 85 l 10 Days Shutdown i

Sept 85 _ _ _l l Oct 85 l 4 Days Shutdown Nov 85 ll 1 Day Shutdown I

26 Days Shutdown Dec 85 1 12 Days Shutdown Jan 86 i

J,q

o 67 t

Figure 2

'Jnit 3 - Number of Days Shutdown PEACH BOTTOM ATOMIC POWER STATION Apr. 85 May 85 June 85 July 85 l$1xth Refueling Outagel l 15 Days Shutdown l I '

'

Aug 85 1 31 Days Shutdown <

g l Sept 85 l 30 Days shutdown g

Oct 85 I 31 Days shutdown l g

-~

k l Nov 85 30 Days Shutdown

!

Dec 85 I 31 Days Shutdown g

Jan 86 1 31 Days Shutdown (

.

. _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ .

O

,

f ENCLOSURE 2

~

SALP REPORT

.

U,S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

'

INSPECTION REPORT NO. 50-352/85-99 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION ASSESSMENT PERIOD: DECEMBER 1, 1984 - JANUARY 31, 1986 BOARD MEETING DATE: MARCH 18, 1986

.

4

%b i

i

_ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .-_ __ - _ _____ __- ___ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ - - _ _ - _ _ _ _ - _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ -

- - - - - - - - - - - - - - - - - - - - - - - _ - - - - - - - _ - - _ _ _

_ _ _ _ _ _

=

5 i

.

l

.

TABLE OF CONTENTS Page

,...................... 1 I. INTRODUCTION

A. Purpose and Overview . . . . . . . . . . . . . . . . .

B. SALP Board Members . . . . . . . . . . . . . . . . . .

Background . . . . . . . . . . . . . . . . . . . . . . 2 C.

II. CRITERIA .........................

.................... 7 III. SUMMARY OF RESULTS A. Overall Facility Evaluation ............. 7 Facility Performance . . . . . . . . . . . . . . . . . 8 B.

IV. FUNCTIONAL AREA ASSESSMENTS . . . . . . . . . . . . . . . .

!

Plant Operations . . . . . . . . . . . . . . . . . . . 9 l A.

Radiological Controls ................ 13

! B.

..................... 16 C. Maintenance y 19 D. Surveillance . . . . . . . . . . . . . . . . . . . . .

E. Emergency Preparedness . . . . . . . . . . . . . . . . 24 Security and Safeguards

,

F. ...............

Preoperational and Startup Testing . . . . . . . . . . 27 G.

i Training and Qualification Effectiveness . . . . . . . 30

! H.

I. Licensing Activities . . . . . . . . . . . . . . . . .

l J. Assurance of Quality . . . . . . . . . . . . . . . . .

V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . .

Investigation and Allegation Review ......... 39 A.

............ 39 B. Escalated Enforcement Actions 39 C. Management Conferences . . . . . . . . . . . . . . . . 40 t

D. Licensee Event Reports . . . . . . . . . . . . . . . .

i TABLES l

Table 1 - Tabular Listing of LERs by Function Area ......... 45

Table 2 - Inspection Hours Summary .................

Table 3 - Enforcement Summary . . . . . . . . . . . . . . . . . . . . 47

Table 4 - Inspection Report Activities ...............

Table 5 - Unplanned Reactor Scrams. . . . . . . . . . . . . . . . . . 57 Table 6 - Flanned Shutdowns and Reactor Trips . . . . . . . . . . . .

Table 7 - NRR Supporting Data . . . . . . . . . . . . . . . . . . . .

Figures (

Figure 1 - Number of Days Shutdown. .................

1

, .

i i *

.

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

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

An NRC SALP Board, composed of the staff members listed below, met on March 18, 1986 to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516 " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety performance at the Limerick Generating Station for the period

! - December 1, 1984 through January 31, 1986. The summary findings and totals reflect the 14-month assessment period.

B. SALP Board Members Chairmen R. W. Starosteck , Director, Division of Reactor Projects (DRP)

W. F. Kane, Deputy Director, DRP Members S. D. Ebneter, Director, Division of Reactor Safety (DRS)

S. J. Collins, Chief, Projects Branch 2, ORP T. T. Martin, Director, Division of Radiation Safety and Safeguards (URSS)

L. H. Bettenhausen, Chief, Operations Branch, DRS R. E. Martin, Licensing Project Manager, NRR R. M. Gallo, Chief, Reactor Projects Section 2A E. M. Kelly, Senior Resident Inspector Other Attendees J. E. Beall, Project Engineer, RPS 2A K. Gibson, Reactor Engineer, RPS 2A (

- _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

O

, *

' 2

\

C. Background 1. Licensee Activities The assessment period began with fuel loading finished and the reactor vessel hydrostatic test completed. A low power operating license had been issued on October 26, 1984.

Initial criticality was achieved on December 22, 1984, and rated pressure and temperature were established on January 14, 1985.

The plant was shutdown from February 1 until February 17, 1985, to correct deficiencies reported in Licensee Event Reports. Low power testing was completed on March 4, 1985, and the plant entered a four week outage to correct deficiencies identified during low power testing. The reactor was restarted on April 1 and the turbine generator was synchronized to the grid for the first time on April 13. The unit was shut down on April 17, 1985 to perform minor maintenance and modification work in anticipation of full power license issuance. An emergency plan exercise was held on April 3, with supplemental exercises held on April 10 and April 22, 1985.

The plant remained shutdown from April 17 until August 8, 1985, due to ASLB hearings associated with offsite emergency planning.

j The Licensing Board issued a Fourth Partial Initial Decision disposing of those issues on July 22, 1985. The extended shut-down delayed startup testing by approximately 4 months. ,

A full power operating license was issued on August 8, 1985.

Startup testing commenced in Test Condition (TC)-1, with heatup and pressurization and ascension to 5% power by August.10.

Operational Condition 1 was achieved for the first time on August 12, 1985. The NRC issued an Order on August 16, 1985, restricting reactor operation to 5% of rated thermal power based on court appeal of the full power license. The plant remained at approximately 3% power until August 21 when the Order was rescinded.

Circulating cooling water makeup had been limited by agreements with the Delaware River Basin Commission (ORBC) to conditions on flow and temperature in the Schuylkill River prior to June 1985, and dissolved oxygen since June 1985. The licensee has utilized an onsite storage inventory of up to 10.5 million gallons to support operations at various power levels during periods of low river flow. Startup testing was conducted within available makeup water restraints. Special preparations were made by the licensee during the last week of September for Hurricane Gloria, the effects of which were felt onsite during September 26 and 27, 1985. No plant or major site damage was experienced.

(

--

.

'

e

' 3 t

The plant operated at 50-75* power through October and November 1985 for TC-3 through 5 testing. The unit was shut-down during October 8-15 following a turbine trip startup test to clean out main condenser water boxes to alleviate high zinc concentrations experienced in condensate and feedwater. The licensee initiated a program of more frequent condensate resin replacements to control reactor water conductivity. Following a turbine trip test on November 14 the plant remained shutdown until November 25 to replace 1RMs and repair a main turbine combined intermediate valve. The final phase of TC-6 startup testing was begun in December at power levels of 65-100%.

The unit reached full rated power for the first time on December 26, 1985, and operated until January 2, 1986, when a steam leak in the main turbine cross-around piping was found.

The plant was shutdown in conjunction with a turbine trip test on January 2, 1986, and the steam leak was repaired. A plant startup was suspended due to 5 of the 6 main turbine combined intermediate valves being stuck closed. The valves were heated, successfully opened, and the reactor was brought to 90*4 power by January 12. However, a main turbine control valve was discovered to be incapable of fully closing, and a planned shutdown and manual scram was initiated on January 13, 1986. The plant remained shutdown to repair the valve and inspect all other turbine valves until January 20; full rated power was maintained through the

,

'

remainder of the assessment period. The 100-hour warranty run was begun on January 23 and finished on January 28. The startup test program was completed on January 31 and the licensee declared the unit in commercial operation on February 1, 1986.

2. Inspection Activities A senior resident inspector for operations and a senior resident inspector for construction were assigned to the site from the beginning of the assessment period until April 1985. A new senior operations resident inspector was assigned in July 1985 and con-tinued to implement the NRC resident inspection program.

Previous assessment periods covered the completion of construc-tion and preoperational testing. Increased inspection efforts during this assessment period focused on the readiness of the licensee to assume power operations and on the conduct of the startup and power ascension test program. Due to the change in plant status from the previous assessment period, increased inspection was also devoted towards radiological controls, surveillance and maintenance activities.

(

i

.

'

$

,

An NRC team inspection was conducted in January 1985 to assess the licensee's readiness for power operations. Adequate manage-ment controls were found to be established and implemented to support full power operation. Special inspections were con-ducted during the assessment period to evaluate the effectiveness of the licensee's Security Programs.

This report also discusses " Training and Qualification Effective-ness" and " Assurance of Quality" as separate functional areas.

Although these topics, in themselves, are assessed in the other functional areas through their use as evaluation criteria, the two areas provide a synopsis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspections.

Although quality work is the responsibility of every employee, one of the management tools used to measure quality assurance effectiveness is reliance on quality inspections and audits.

Other major factors that influence quality, such as involvement of first-line supervision, safety committees, and worker attitudes, are discussed in each area.

Fire Protection was not evaluated as a separate functional area during this assessment period, f

'

The NRC conducted a total of 4445 inspection hours during this assessment period, equating to 3810 hours0.0441 days 1.058 hours 0.0063 weeks 0.00145 months on an annualized basis.

Functional area distribution of inspection hours is detailed in Table 2. Table 3 lists specific enforcement data and Table 4 summarizes all inspection activities during the assessment period.

k

,

. -

{

II. CRITERIA The following evaluation criteria were used to assess each functional s area:

1. Management involvement and control in assuring quality.

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

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Reporting and analysis of reportable events.

6. Staffing (including management).

7. Training effectiveness and qualification.

To provide consistent evaluation of licensee performance, attributes associated with each criterion and describing the characteristics applicable to Category 1, 2, and 3 performance were applied as discussed in NRC Manual Chapter 0516, Part II and Table 1.

l Category _1. Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety or construction is being achieved.

NRC Inspection and Enforcement Manual Chapter 2515 allows reduction of inspection effort of nuclear safety performance in functional areas assessed as Category 1 as part of the SALP process except at sites near high population areas such as Limerick. Accordingly, even if rated Category 1, NRC attention will continue at the basic program level and will not be reduced at the Limerick facility.

Category 2. NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.

Category 3. Both NRC and licensee attention should be increased.

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

.- . . _ . .

.

o

6 (

The SALP Board has also assessed each functional area to compare the licensee's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend for each functional area. The trend categories used by the SALP Board are as follows:

Improving: Licensee performance has generally improved over the last quarter of the current SALP assessment period.

Consistent: Licensee performance has remained essentially constant over the last quarter of the current SALP assessment period.

Declinino: Licensee performance has generally declined over the last quarter of the current SALP assessment period.

,

I o

'

i

-- -

. _ , _ _ . . - . _ .

-

. . . _ . . . . - . _ . - . _ . _ _ _ . _ . . _ _ _ _ _ _ _ _ , _ . , , _ _ _ _ _ . - _ . _ _ _ _ _ _ , _ _ - _ _ _ , _ . - _ ---_ -. . - . .

,

'

.

' 7 k

III . SU'<MARi Or RESU'_TS A. Overall Facility Evaluation Strong plant management and supervision were evident, and visibly involved, in plant operations during the assessment period. Site organizations are well-staffed to support plant operatiors. Trend analysis of reportable events during the period showed progressive improvement, indicative of licensee efforts to identify and correct problems.

Conduct of the startup test program was excellent, with management and 0A/QC involvement instrumental in identifying and resolving tech-nical problems. Tests were managed in a safe and deliberate manner, FCRC review cf test resuits was thorough, anc administrative holds were apprcpriately exercised when needed.

During the assessmert oeriod, some plant problems were caused by inaceauate communications between lit.ensed operators and shift super-vision, and between operators and I&C technicians. Although the erob'ets were adcressed recent events indicate that continued management attention to establisn clearer direction on independent verificaticn and troubleshooting activities is still needed.

I Tne licensee is very responsive to self identified safety problems and NRC cencerns. Tne licensee has instituted innovative and diverse corrective measures which include new procedures, design modifications, training initiatives and an Operator Excellence Program.

In the Security area, repeated instances of problems were identified by the NRC. Tne licensee has not cemonstrated sufficient control over the Limerick security contract to obtain a higner standard of performance. Management attention and aggressive involvement are necessary to correct tne underlying reasons for these problems since previous effcrts appearec to have adcressed the symptoms and were not successful in improving security activities.

(

.

. o

8 i

B. Facility Performance Category Category Recent Functional Trend-Area last Period This Period 12/1/83 - 11/30/84 12/1/84 - 1/31/86 A. Plant Operations 2 1 Consistent (Note 1)

B. Radiological 2 2 (Note 2)

Controls Maintenance Not Evaluated 2 Consistent C.

D. Surveillance Not Evaluated 2 Consistent E. Emergency 2 1 Consistent Preparedness Security and 3 3 Consistent F.

Safeguards G. Preoperational & 2 1 (Note 3)

,

Startup Testing Training & Quali- Not Evaluated 2 No basis H.

fication Effective-ness Licensing Activities Consistent I. 1 1 Assurance of Quality Not Evaluated 1 No basis J.

Notes: 1. Assessed as Operational Readiness and Plant Operations last period.

2. A high level of performance could not be confirmed since Radio-logical Controls Programs have not yet been significantly challenged.

3. Progressive improvement was noted throughout the assessment period.

I

.

'

,

.

t l IV Functional Area Assessments A. Plant Operations (39%; 1733 hours0.0201 days 0.481 hours 0.00287 weeks 6.594065e-4 months )

During this assessment period, resident and specialist inspections routinely reviewed plant operations, and a team inspection concluded that adequate management controls had been established and implemented regarding plant readiness for full power operation. Senior resident inspectors from Peach Bottom and Susquehanna observed shift operations during testing and ascension towards full power operation. This is the first assessment of Plant Operations as a separate functional area. Operational Readiness was assessed during the previous two SALPs. A weakness previously noted involved a high incidence of personnel errors.

During the 14-month assessment period, nine unplanned automatic reactor trips occurred. Four of the trips are attributed to design deficien-cies which had been previously evaluated by the licensee but were not corrected until after the scrams. Five of the trips are attributable to operator error. The unplanned trips that occurred early in the assessment period received prompt management attention and an Opera-tional Excellence Program was instituted which has been instrumental in preventing recurrence of the root causes of the earlier scrams.

, Operators were instructed to better coordinate instrumntation tag-outs with I&C technical assistance. The licensee also undertook a plant outage, at his own initiative, to perform design modifications to address personnel error related trips.

The licensee effectively performs post-scram reviews, and corrective actions associated with unplanned scrams have been thorough. In re-sponse to NRC concerns with the cool-down rate and full-in control rod position indications after one scram, additional simulator scen-ario training was devoted to scrams from low decay heat rate condi-tions. Also, a special procedure was developed to address post-scram rod position indication abnormalities as well as the use of various control rod displays and the process computer. In this case, the licensee made effective use of procedures, training and hardware changes to ensure proper post-scram operator actions.

Licensed control room operators have exhibited a professional, open, cooperative attitude toward NRC concerns, and a dedication to safe plant operation. Shift turnovers are professionally conducted and involve personnel from chemistry, health physics, I&C and maintenance departments. Licensee management interfaces with control room super-vision in several daily meetings at which a shift superintendent is present. Plant problems are promptly relayed to management by the operations shift. Shift Technical Advisors are an integral part of shift operations in the control room and routinely monitor plant con-ditions, equipment performance, and provide an oversight function for l

.

,

'

$

panel walkdowns and adherence to Technical Specifications. Licensee initiatives in response to NRC findings this period have included expanding the scope of STA responsibilities aimed towards improve-ments in post-maintenance testing and control room log reviews. The correction of nuisance alarm indicators is systematically tracked and pursued through the corrective maintenance program.

A weakness identified by the NRC early in the assessment period was ineffective control of access to the main control room. The licensee undertook design and administrative actions to reduce control room congestion, and shift supervision has consistently exercised juris-dictional controls to limit noise and unnecessary personnel. The

- licensee also took steps in response to NRC concerns regarding operator attention to logkeeping, which has since been generally accurate, complete, and receives additional Shift Superintendent and STA review.

Operators have demonstrated an overall sound krowledge of Technical Specifications. Technical Specification violations have occurred with control room habitability systems, the standby liquid control system outboard isolation valve, and control rod notch testing above the preset level of the RSCS and RWM. Increased operator recognition of Technical Specification requirements resulting from changing plant f conditions is needed. Recurrent violations in this area have not

'

been experienced due to the licensee's use of PORC Position Papers, Operator Aids, and augmented operator training in the requalification program.

Overtime guidelines were strictly enforced during the assessment period, even with the increased demands placed upon the operating staff due to startup testing. The licensee consistently provided extra licensed operators to support startup test evolutions. The licensee had 6 full shifts and 61 licensed individuals on site at the end of the assessment period.

,

Two sets of operator licensing exams were administered during the

+

period. The first set of candidates had a high SRO Failure rate (4 of 6), with a weakness in the use of TRIP procedures noted during simulator exams. The second set of candidates were comprised mainly

,

j of staff engineers and resulted in a reduced failure rate (2 of 13),

but noted a recurrent weakness in supervising refueling operations.

On shift communication and coordination can be improved. There have

!

been instances of inadequate communication between shift supervision l

l and operators, one resulted in the simultaneous inoperability of two RWCU isolation valves. Operator use of transient (TRIP) procedures

'

during plant transients has been good with clear communication between

shift supervision and licensed operators evident. Operators are pro-

'

ficient in recovery from plant transients such as restarting idle

! (, l l

l t

_ . .

.

11 t.

i recirculation loops. An instance occurred where a vessel level dis-crepancy between wide and narrow range indication at lower pressures during a reactor cooldown caused two scram signals. Operators had been cognizant of the pressure compensation effect but had not com-municated the discrepancy effectively during the reactor cooldown.

A lack of coordination between operators during a startup also caused a scram resulting from the failure to place a feedwater pump.in service as pressure was being increased.

Station organization and reporting chains are effectively structured.

The Superintendent of Operations has staff from the operations, chem-istry and technical engineering groups. The Technical Engineering group includes test engineers who are assigned systems responsibilities, and have been instrumental in supporting plant operations via equipment troubleshooting.

The Station Manager approached operational problems in a conservative fashion, imposing administrative holds on power operation when startup test results were in question such as the feedwater flow transmitter miscalibration, and initiating a plant shutdown when potential safety issues arose such as the crossover piping expansion joint failure and the main turbine control and intercept valve problems. The Station Manager has been visible in plant, particularly in the control room j during major plant problems and test evolutions, and usually leads a

-

daily morning meeting in the control room with principal staff and the Shift Superintendent. The Station Manager has also been respon-sive to NRC initiatives, such as incorporation of certain NRC findings into the licensed operator requalification program, and maintains open and consistent communication with the NRC inspectors and managers from NRR and Region I.

LERs which were reported during the assessment period were subject to an ongoing review as part of NRC inspections for trends and root cause identification. Causal analysis of LERs during this period is detailed in Section V.D. A trend was identified early in the assessment period by the NRC with events caused by personnel errors, but had decreased towards the end of the period. Plant operating experience and

"de-bugging" of procedures are reflected in the lowered incidence of personnel errors.

The plant fire protection systems and equipment were maintained in good working condition. Plant cleanliness and housekeeping is con-sidered a strength in the licensee's management control system.

Transient combustibles are well controlled. The plant reflects a general absence of standing pools of water, oil or debris beneath equipment, spare or miscellaneous materials stored about the plant or excessive dust on components in pipe tunnels. Floor coatings in the Reactor Enclosure building had been renewed and significantly improved.

(

,

. ~ . . - - - - - _ - - - - _ _ _ . - _ _ _ . - . _ , . , , . _ - _ - - -

. ,.- .-

.

12 i

The plant onsite review committee (PORC) was very active in startup testing, operating activities and special issues or station problems.

Frequently convened PORC sessions created a large demand on station management's time, but did not detract from safe plant operation and was not realized at the expense of other programs. The PORC was instrumental in improving the quality of plant operations during the assessment period.

In summary, staffing of licensed operators is at full complement and control room activities are well supported by technical' personnel.

Strong management involvement in operations is evident, and resulted in a well-executed startup test program under the constraints of cooling water limitations, condenser leakage problems and licensing restrictions. Station management has been responsive to A!C concerns, performs critical self-evaluations, and solves identiffed problems with effective corrective action.

2. Conclusion Rating: Category 1 Trend: Consistent 3. Board Recommendations

,

None i

.

13 (

B. Radiological Controls (10*;, 424 hours0.00491 days 0.118 hours 7.010582e-4 weeks 1.61332e-4 months )

1. Analysis During this assessment period, the licensee's Radiological Controls Program implemented Radiation Work Permit (RWP) procedures and experienced its first major challenges including: contaminated water leakage into Unit 2; a reactor water cleanup system resin spill; an unplanned offsite low level radioactive gaseous release; and, two contaminated Intermediate Range Monitor (IRM) replacements.

There were nine inspections performed in the area of radiological controls during the assessment period including Radiation Protection, Chemistry, Effluent Monitoring, Radioactive Waste Management and Transportation activities. Routine reviews of this area focused on the licensee's organization, training, reactor shielding verifica-tion start-up testing, and implementation of the ALARA and Respiratory Protection programs. The startup test reviews, through TC-5, verified that adequate shielding was in place based on measurements taken inside and outside of the reactor, turbine and control enclosures.

The licensee was receptive to taking action on all identified fol-low-up items, in particular, for the post accident sampling and moni-( toring systems. All identified concerns were corrected by their

'

commitment dates. The licensee demonstrated a thorough understanding of the technical issues and coordinated their efforts with corporate engineering representatives.

Review of the qualification and training program for radiation pro-tection staff found it to be in various stages of development and implementation. The technician qualification program defines the responsibilities, tasks, and qualification requirements. The licen-see was further refining their program by analyzing the tasks and associated procedures for each level of technician responsibility.

Training interviews by the NRC showed adequate knowledge by the licensee staff. In addition, all the senior level qualified tech-nicians hired from Peach Bottom Station were tested to determine areas of weakness and establish a remedial training program for these technicians. The licensee is also coordinating an entry-level tech-nician training program with the Peach Bottom Station. The general employee training program for all radiation workers is well developed and implemented.

,

.

. - -. .. -._ . - . _ . _ , ._

.

t 1.1 Exposure Control programs Review of external and internal exposure control programs found that the licensee implements a generally effective, well-defined program. The licensee demonstrated good control of work, assess-ment of whether an RWP would be required, and coordination of RWP procedures with Maintenance Request Forms. As discussed above, the first major challenges to exposure control programs were experienced during the period although none represented significant radiological hazards. Actions to contain contami-nation, investigate additional sources, and implement corrective and preventive actions were timely, thorough and appropriate to the situation. The licensee has experienced problems in effectively communicating radiation protection controls with some work groups. For example, during the IRM replacement, the pre-job briefing was given to one crew, but not to the next shift's work crew which actually performed the work. On another occasion, a system was breached and the workers were using radia-tion surveys taken prior to the breach. The licensee conducted effective post-job critiques to examine the causal factors and to resolve identified problems.

A comprehensive review of the Respiratory Protection Program was performed during this assessment period after the licensee

notified the NRC of their intention to take protection factors when estimating individual internal exposures. The licensee has improved in the respiratory protection area since the previous assessment period. Engineering controls were avail-able and required to be used, prior to the selection of respira-tory protection, to reduce exposures. The licensee audited con-tractor facilities and procedures, and were performing quality control surveillances for those services being performed by con-tractors. The surveillances and audits found that the licensee was meeting the necessary requirements for protection factors.

1.2 Chemistry and Effluent Monitoring The licensee is meeting Technical Specification requirements for process and effluent sampling and analysis, and for reactor coolant water quality, and has shown a management commitment to overall program development by developing a chemistry data base on a computerized system to maintain and trend plant system chemistry parameters. Plant chemistry is organized under the Superintendent of Operations and this reflects the licensee's emphasis on reactor water chemistry and effluent water quality.

The group is managed by a senior chemist and has demonstrated analytical capabilities with, for example, use of an ton chromatograph. Condenser tube problems were experienced during the assessment period, but conductivity levels were closely trended and controlled within Technical Specification limits by good ( secondary plant water treatment and radwaste management.

.

'

.

NRC review of chemical and radiochemical startup testing did not identify any deficiencies or unacceptable conditions. The licensee demonstrated the ability to meet reactor water quality specifications, effluent monitoring system performance as stated in the FSAR, and Technical Specification limits. Minor arith-metical and transcription errors were noted in two startup tests, one of which had been reviewed by the PORC. However, these were isolated instances and did not affect the test results. Some problems were also identified with regard to sampling arrangements for radioactive waste processing and in sampling techniques in response to unidentified leaks. These problems were resolved when discussed with licensee management.

1.3 Radwaste Management and Transportation During this assessment period, the licensee developed and imple-mented the Radioactive Waste Management and Transportation Pro-gram. Initial NRC review determined that the program develop-ment was significantly behind in schedule, considering opera-tional demands. The licensee acquired an experienced consultant to supervise all activities in radioactive waste processing operations, using a matrix management concept. A readiness plan was developed and submitted to the NRC in May 1985. NRC

<

concerns were quickly resolved and considerable effort was

' expended to develop and/or revise appropriate radwaste pro-cedures. Significant QA involvement during radioactive waste shipments was also noted, and is a management commitment for improving this program area. Presently, the overall program has significantly improved, procedures are clear and technically accurate, training courses are thorough and well documented, and staffing is almost complete.

2. Conclusion Rating: Category 2 l

Trend: A high level of performance could not be confirmed since l

radiological controls programs have not yet been signifi-l cantly challenged.

3. Board Recommendations I

! None

!

i l

.

'

(

C. Maintenance (5*., 214 hours0.00248 days 0.0594 hours 3.53836e-4 weeks 8.1427e-5 months )

1. Analysis During the assessment period, three inspections were performed which assessed maintenance activities. There was no maintenance functional area assessment in the previous SALP report, although administrative controls for maintenance were evident and found to be effectively implemented during that assessment period.

Inspectors observed maintenance activities on a routine and periodic basis, along with the review of selected design change and modifica-tion activities. Maintenance activities were also assessed by the Operational Readiness Team inspection. Additionally, corrective and preventive maintenance for high-low pressure interface valves in the RHR and core spray systems, and the licensee's commitments to NRC Generic Letter 83-28 with respect to post-maintenance testing were reviewed during this assessment period.

The overall corrective and preventive maintenance programs are func-tioning well. The use of a computerized Maintenance Request Form (MRF) has been a successful management initiative which assures proper equipment control prior to and following maintenance work. Generic problems and evaluations of completed maintenance are tracked through

' the licensee's computerized history and maintenance planning system (CHAMPS). However, maintenance information and trend analysis of the data was not sufficiently developed during this assessment period to verify the effectiveness of this system. Quality control involvement is evident in the maintenance process by the establishment of hold points in maintenance procedures and QC review of all safety-related MRFs. Additional QC involvement was begun for maintenance in non-safety-related areas including fire protection equipment, seismic class IIA hangers, ASME components and non-Q-listed equipment in close proximity to safety-related equipment. MRFs sampled during this assessment period revealed that the licensee is properly classifying maintenance work and that QC is extensively involved in these activ-ities.

A weakness had been identified by the NRC regarding a lack of summary data for licensee management overview of maintenance backlogs, work status and trends. The licensee implemented weekly status reports to senior station staff addressing the backlog of MRFs awaiting an outage.

The reports compare outstanding MRFs between the current and previous week, thus providing trend information. Maintenance activities are discussed in daily meetings held between plant supervision and main-

tenance personnel, providing effective communication and coordination of work.

'

(

.

'

.

i A review of valve maintenance history and program application concludes that the licensee's preventive maintenance program assures a high reliability for operation and leak tightness for valves forming high-low pressure interf aces in the core spray and RHR systems.

The licensee has effectively used an equipment trouble tag (ETT)

system for in plant identification of equipment deficiencies, and to initiate MRFs for corrective maintenance. The NRC has identified cases where an ETT had not been removed but the MRF had been closed-out, presenting a potential concern for control of system status.

The licensee has since been successful in requiring removal of the ETT when blocking permits associated with an MRF are cleared. A backlog of ETTs had developed during startup testing but the licensee has taken steps to identify outstanding maintenance actions and pri-oritize their completion. The failure to control the removal of equipment from service for maintenance has not been a recurrent problem although isolated incidences do occur.

The development of preventive maintenance and spare parts programs are thorough and well thought-out. Program development incorporated review by vendors, the Architect Engineer, industry sources and the licensee's system startup engineers. The licensee also developed written engineering bases for Q versus non-Q spare parts determinations.

j A repair of the HPCI turbine governor had initially used a Unit 2 replacement part per verbal authorization from a contractor. In re-sponse to NRC concerns with the environmental qualification for the spare part, the original governor was refurbished and re-installed.

The NRC identified a lack of formal controls over environmental qual-ification (EQ) reports on mechanical and electrical equipment, and the licensee subsequently approved new procedures to control the issu-ance and revisions to EQ reports. EQ requirements such as valve stem packing, seat ring and diaphragm replacements, were added to the CHAMPS computer, in response to NRC concerns, to automatically schedule and track replacement of shelf-life items.

Adequate controls over post-maintenance testing have been established tnrough the use of an operational verification form (OVF), which is reviewed and authorized by shift supervision prior to return of equipment to service. One reportable event was attributable to inadequate post-maintenance testing, involving the inoperability of a fire protection sprinkler system due to valve positions not properly restored after a hydrostatic test by a contractor. An event involving a reactor scram was caused by improperly removing a level transmitter from service to perform maintenance. The licenses now implements an RPS instrument matrix to achieve proper equipment blocking.

l

.

,

18 i

Relative to Generic Letter 83-28, the licensee has also committed to following the INPO NUTAC Vendor Equipment Technical Information Pro-gram, including expanded participation in NPRDS, procedures to update vendor technical information, and administration controls to evaluate and implement vendor technical bulletins. The licensee's onsite ISEG is actively involved in the program.

Design changes and modifications made to the plant were found to be well-documented and controlled, with appropriate safety evaluations to support the change and updates of design drawings. Modifications performed during April-July 1985, and in response to license commit-ments, were found to be properly implemented. Procedures for post-modification acceptance testing are well defined. Modifications to HPCI and RCIC, the nitrogen vaporization skid, standby liquid control initiation logic and the reactor protection system inverters and power supply breakers have improved plant operation and reliability. The RPS modification should reduce the number of trips caused by power supply problems. Staffing in the site modification group is adequate to support work, and QA/QC are actively involved in the program.

The licensee has maintained an overall high standard of plant house-keeping throughout the assessment period. The facility is free of debris which could adversely affect equipment maintenance. Adminis-trative controls have been established over temporary scaffolds and i work structures in the plant, including a tagging system for marking authorized use along with a pre-installation review by Maintenance Division supervision to assure that scaffolds do not adversely impact equipment access or operation.

2. Conclusions Rating: Category 2 Trend: Consistent 3. Board Recommendation None (

.

D. Surveillance (7*., 330 hours0.00382 days 0.0917 hours 5.456349e-4 weeks 1.25565e-4 months )

1. Analysis This area received routine assessment and programmatic review by the team inspection for operational readiness. There was no specific surveillance functional area assessment in the previous SALP report.

Early in the assessment period the licensee experienced a recircula-tion pump speed increase transient associated with instrumentation

/ and control (I&C) personnel troubleshooting the recirculation flow control circuit. I&C personnel did not obtain control roc,m permission to perform the troubleshooting activities, indicating a lack of admin-istrative controls for the performance of troubleshooting activities.

In response, controls were established and augmented by training, however, additional problems have occurred. One involved the opening of both scram discharge volume drain valves; the other involved a scram on February 10, 1986, where a ground was created in the turbine EHC logic. Management controls on troubleshooting need to be better defined so that shift supervision is aware of activities being performed and proper equipment restoration is documented and independently verified.

The licensee has experienced problems controlling valve positions and j system operability during surveillance activities.

The licensee reacts in a conservative and safe fashion to identified plant problems. Two instances of instrument calibration errors were discovered by testing that were promptly resolved with sound technical judgement. Jet pump flow monitors were found to be improperly com-pensated for column temperature and the licensee initiated a shutdown.

Another example involved miscalibrated feedwater flow transmitters which resulted in an underestimate of about 0.6% in computer-calculated core thermal power. In both cases, the licensee's technical investi-gation and resolution were prompt and accurate. Licensee management were immediately involved in the problems, and took conservative actions by reducing power and placing an administrative hold on further operations until the problems were clearly understood and safely resolved.

A concern involving mispositioned ESW system valves pointed to inade-quacies with the licensee's practices for determining the required positions of manual valves, since previous lineup verifications for ESW had not identified the incorrect valve positions.

i k

.

20

!

The control of equipment and systems released for testing has been observed to be good. Inadequate communications and administrative control over test groups has, on occasion, led to problems. However, proper equipment blocking procedures and tagging processes have been diligently followed which have since prevented recurrence of these types of events. Safety system logic initiations have been caused by manipulation of instrumentation valves during surveillance testing.

On two occasions, while backfilling a level indicator reference leg, a technician misaligned an equalizing valve which caused.a LPCI injec-tion to the reactor vessel. The licensee added head chambers to level sensing lines which have prevented recurrence of the problem. The return of instrumentation to service caused a reactor scram, and the practice of backfilling and venting instrument sensing lines has since been jurisdictionally limited to I&C technicians and formalized by a written procedure. Critical instrument racks in the Reactor Enclosure are clearly marked with caution signs that describe those controls, and there were no scrams or safety system actuations for the remain-der of the period attributed to instrumentation valve manipulations.

The licensee has exhibited good control ove" surveillance testing by the use of procedures, Operations Aids, effective work group interfaces and coordinated scheduling. A dedicated test engineer schedules and tracks surveillances via the ccmputerized Surveillance Test and Records

. (STARS) system. A test coordinator performs a daily review of opera-

ting logs to assure that all required tests are scheduled and completed.

The licensee's record of adhering to required surveillance schedules

-

has been good and, in those few cases where tests were missed, the licensee promptly identified, corrected and reported the events.

Problem identification and reporting has been stressed by station management and has been effective through the entire assessment period.

The temporary procedure change (TPC) process was identified by the NRC as being potentially prone to errors. The licensee instituted revised management controls over the process, in addition to the l

I existing provisions of two authorizing signatures (one senior-licensed)

I and retroactive PORC review within 14 days. These management controls have been effectively implemented in that the frequency and use of TPC's towards the end of the assessment period has decreased from that observed initially when many surveillances were being run for the first time. The licensee's test engineers assigned to individual systems are cognizant of procedural changes, and procedures have had sufficient review cycle time to result in a well-developed and "de-

!

bugged" ret of surveillance procedures.

I I :

P ( . t

i l

l t

.

21

'

.

Licensee reviews of surveillance test results have identified potential safety problems that were subsequently corrected. One example involved a surveillance test of reactor protection system logic that was suc-cessfully passed but, because of ouestioning attitude of the shift superintendent, a binding probleen was identified with the scram relay auxiliary contacts. The problem was brought to plant management attention, and corrective maintenance and PORC evaluations were promptly instituted in support of continued operation.

Personnel performing surveillance testing were found to be knowledgeable and well-trained regarding test activities, as well as for actions required if abnormal conditions were encountered. Testing was observed to be performed using properly calibrated test equipment and in accordance with approved test procedures.

The licensee has expended considerable efforts in the area of compen-satory fire watches for degraded fire barriers. The frequency of missed watches was reduced towards the end of the assessment period due to the licensee's oversight of the contractor who performs the watches. The licensee assigned a dedicated engineer reporting to the Regulatory Engineer who is responsible for fire surveillances.

In summary, controls over troubleshooting activities have been generally effective, but instances later in the period indicate a need to estab-

,

lish clearer bounds on troubleshooting. Problems were identified with the manner in which independent verification is performed following surveillance testing. Technical investigations regarding I&C problems have been thorough and have been resolved by conservative management decisions. Controls over systems released for testing have, in most cases, been good. Events involving inadequate communications and I&C valving errors were significantly reduced during the assessment period.

Surveillance test requirements have been met due to well-developed procedures, effective work group interfaces, use of Operator Aids, and coordinated scheduling using a computerized system. The few cases of missed surveillances were isolated instances that were found, reported and effectively corrected.

2. Conclusion Rating: Category 2 Trend: Consistent 3. Board Recommendations None l

l

f

!

_ _ .

-4'

.

22 E. Emergency Preparedness (6*;, 281 hours0.00325 days 0.0781 hours 4.646164e-4 weeks 1.069205e-4 months )

1. Analysis During the assessment period, NRC emergency preparedness activities included observation of the annual emergency preparedness exercise, an accountability and evacuation drill, a routine inspection to follow-up appraisal items, and a special inspection of the security force emergency preparedness (EP) training.

The licensee has recently been very responsive to NRC initiatives.

NRC inspection findings from the prior exercise identified 28 items needing improvement. The April 1985 exercise indicated that none of these items were repeated. In addition, the scenario was provided to the NRC staff within the time schedule recommended and was put together in a professional manner.

The training and qualification program was determined to be effective as indicated by the following:

- demonstration during the exercise of timely classification and notification, good command and control in each emergency response facility and prompt protective action recommendations; I - performance-based training given to the security force and demonstrated in the accountability drill, and;

- implementation of quality assurance / control checks.

The licensee has, on their own initiative and in response to an alle-gation, made efforts to improve the Security Force EP training program. The requirement for EP training was prioritized and received management attention. Some employees, who had been responsible for the previous problems in this area, were terminated. Quality Assur-ance oversight for Security Force EP training was increased.

The results of the accountability drill on July 17, 1985 demons-trated that accountability and evacuation of Limerick Unit I personnel and evacuation of Limerick Unit 2 construction personnel can be conducted simultaneously and completed in a timely manner.

In January 1985, two NRC region-based inspectors conducted a follow-up inspection to evaluate progress made on open items identified during the Emerjency Preparedness Implementation Appraisal conducted in June 1984. It was evident during that inspection that the critical areas received an adequate level of management attention.

Outstanding items were resolved satisfactorily.

l

.

. _ _ __, - _ _ _

.

,

Licensee responsiveness was enhanced by the hiring of a full time Emergency preparedness Coordinator for onsite activities, and the PECO corporate staff also provided support and guidance. In addition, high level management were present at the licensee's April 1985 exer-cise critique, further supporting the importance of the program. The corporate staff, as well as providing program support, currently main-tains an incident response center to assist during emergencies. This center was recently completed and successfully tested during the PBApS exercise in the fall of 1985.

The overall emergency preparedness program has shown much improve-ment and was typified by the excellent performance of the licensee's emergency organization during the April 1985 exercise.

In preparation for a full-scale graded exercise in April 1986, the licensee held three practice drill sessions at the end of the assess-ment period, each with full plant staff involvement.

2. Conclusion Rating: Category 1 Trend: Consistent t

3. Board Recommendations None

,

l F

- __ _

__

.

i

.

i ~

.

F. Security and Safeguards (6%; 270 hours0.00313 days 0.075 hours 4.464286e-4 weeks 1.02735e-4 months )

1. Analysis During the assessment period in addition to routine safeguards in-spections, three special security inspections were conducted.

During February 1985, a routine physical security inspection found several program implementation problems and an enforcement conference resulted. Security force personnel had failed to follow procedures and, as a result, the licensee did not identify a breakdown in the security program. A civil penalty resulted for the licensee's fail-

' ure to exercise proper supervision and oversight of the contract security force.

Senior licensee management made a commitment to NRC to pursue more effective oversight of the security force and the overall security program. To achieve this, a Nuclear Security Specialist was added to the licensee's on-site staff and the contractor added a corporate level performance analysis group and an on-site performance analysis group to its staff. These actions provided the licensee with increased control over the security organization, and some stabili-zation of the program resulted, i

During the last quarter of the assessment period, the licensee iden-tified several problems with the " split plant barrier" between Unit I and the unfinished Unit 2, which included incomplete and degraded ,

vital area barriers. An inspection conducted by the NRC revealed that the licensee took timely and sound compensatory security measures.

However, the length of time over which these problems existed prior to discovery calls into question the adequacy of the barrier installa-tion review and the res'irces applied thereto. It also raises ques-tions about the ability of the security staff to provide adequate and continuing review of program implementation. With the resumption of Unit 2 construction, a greater awareness of and dedication to effec-tive implementation of the security program is required.

A high turnover rate in the security force and guards asleep on post or leaving their posts without authorization are evidence of job dissatisfaction and low morale. Yet, there is little evidence that the contractor was doing anything to alleviate these problems. Addi-tionally, the training program does not appear to instill in security force members a strong sense of purpose and an understanding of their role, responsibilities and importance.

(

,

l e

- , -- -- -,.

,

.

~

i

,

Six Security Event Reports were submitted in accordance with 10 CFR 73.73 during this period. Two events concerned the failure to follow procedures by the Central and Secondary Alarm Station operators (CAS/SAS). One event concerned a security force member being found asleep on post and another involved a bomb threat which was determined to be a hoax. Another event involved the finding of vital area barrier deficiencies discussed previously. The remaining report involved a security force member found off his post by the licensee's Station Manager. In all cases the licensee's compensatory measures were timely and appropriate.

During the period, the licensee submitted changes to its Security Plan, Contingency Plan, and Training and Qualification Plan, under the provisions of 10 CFR 50.54(p). Some portions of these changes were not considered acceptable as submitted, and required revision.

The licensee made the necessary revisions, resubmitted the changes, and the changes were then found acceptable under 10 CFR 50.54(p). In general, the changes were of good quality and indicative of a thorough knowledge of NRC security objectives. The licensee's corporate security staff is responsible for ensuring that the Plans are maintained current and for coordinating changes when required. The corporate security staff has been effective in carrying out this responsibility and are always responsive to Region I concerns and comments regarding Plan changes. Communications with Region I staff were initiated by the j licensee for more complex changes to preclude any misunderstandings.

All changes were appropriately marked to aid the NRC reviewer, how-ever, the summary which accompanied some of the changes could have been improved by more clearly indicating the overall intent of the change.

The licensee promptly responds to identified violations, however, the nature of the violations identified during this period are indicative of poor performance and suggest that the root cause of problems is i

either not adequately identified or not aggressively pursued. The l licensee did not exercise proper oversight of its security contractor to obtain a satisfactory standard of performance from its personnel.

2. Conclusions l

!

' Rating: 3 Trend: Consistent 3. Board Recommendation Licensee:

The above noted deficiencies are indicative of weak licensee over-sight of contractor activities and a lack of willingness to address l

long-standing identified program shortcomings. The licensee should I

(

- . . _ _ _ __.

.

..

-t assess control and accountability of the contractor in conjunction with a determination of alternative schemes to improve performance in this functional area.

Increase upper level management attention to the security program and plant management oversight and control of the security contractor. Improve the coordination among groups that support and interact with the security program, especially Unit 2 construction groups. Aggressively pursue with the security contractor means to improve job understanding, satisfaction and morale in order to obtain better performance from the security force members.

NRC:

Continue Supplementary Inspection Program.

!

I r

,

.

4

,

G. preoperational and Startup Testing (27%; 1193 hours0.0138 days 0.331 hours 0.00197 weeks 4.539365e-4 months )

1. Analysis During this assessment period, three inspections of preoperational testing activities and twelve inspections of startup testing activ-ities were performed as well as routine reviews inspector examined these areas on a daily basis. In the previous assessment, preopera-tional and startup testing were rated jointly as a Category 2 with identified weaknesses in preoperational test control and system turn-over activities. Startup testing had been noted as a strength.

1.1 preoperational Test program The preoperational test program was completed by the licensee during the previous assessment period. NRC inspection during this assessment reviewed test results and test exceptions. The licensee satisfactorily completed their review and approval of test results and resolved test exceptions that were identified during the program. Senior management involvement was instru-mental in the successful disposition of those test exceptions.

As a result, the NRC's preoperational test inspection program was closed during this assessment period. No outstanding issues remain in this area.

.

1.2 Startup Test Program This assessment period covered startup testing activities from just prior to initial criticality though the completion of the power ascension test program.

Except for a short period of time during a portion of the heatup phase of testing, the licensee implemented an effective startup test program. Problems encountered during startup testing, which were identified as concerns by the NRC early in the program, were promptly corrected by the licensee. Some examples of these were: (a) congestion and noise levels in the control room existed during the transition from the preoperational phase to the startup phase; (b) during a brief 2-week portion of the heatup phase, the licensee was placing more emphasis on testing rather than on review and approval of completed testing and test excep-tions; and (c) a violation resulted for not specifically follow-ing the administrative procedure for processing two test exceptions associated with Level 1 acceptance criteria. The licensee immed-iately placing more emphasis on timely review and approval of test results and test exceptions and continued to do so through-out the rest of the program.

k

.

\

Once the initial difficulties were resolved, the licensee's test program was effectively implemented. The licensee was observed to satisfy the FSAR and licensee commitments regarding testing.

The licensee involved the entire station in the startup testing.

In addition to the operating shift and test personnel, staff system engineers observed their system performance when tested and when their respective systems were expected to be challenged such as during the major plant transients of loss of offsite power test and the turbine trip testing. Senior licensee manage-ment including the Station Manager routinely observed all major test evolutions.

Overall, the conduct of the startup test program was considered to be exemplary, with direct licensee _ involvement at all levels in test activities and a minimal adverse effect upon plant operations. The power ascension portion of testing from 5 to 100*4 power was completed in six months with three unplanned '

scrams at power and a minimum number of open test exceptions.

Plant operating problems, such as water availability and chemistry were effectively dealt with and had no adverse impact on completion of the startup test progra'm. The program identi-fied technical issues which required a significant level of sophistication and precision to resolve, such as the miscali-bration of the feedwater flow transmitters. The resolution of I this issue indicated in-depth evaluation and attention to detail.

~

Certain positive attributes were observed and are in part responsible for the successful and safe conduct of the startup test program: strong senior management involvement in the establishment of the startup testing program and day-to-day activities, conservative approach by management in the resolu-tion of test exceptions and problems, adequate numbers of experienced and trained startup test personnel, administrative and startup test procedures based on other successful startup programs, extensive planning and coordination of startup acti-vities (this permitted the licensee to perform planned startup test reactor scrams in parallel with reactor shutdowns due to i plant problems), use of the plant simulator to test the proce-i dure and train personnel, high plant morale, responsive licensee actions to NRC concerns, performance of additional tests when

.

!

data was not sufficient to justify proceeding with the program, j

and feedback to plant procedures regarding lessons learned while i performing startup tests. Two attributes warrant special note, QC performed essentially 100% surveillance of the startup test program and QA audited each of the testing conditions. QA was staffed with knowledgeable personnel who provided prompt feedback to the startup test program personnel to assure that the program was carried out as committed in the FSAR. The other attribute

!

i l

r I

i

'

. . - - - - - , . - - - - - . - - - - - - - . - - - _ - _ _ - - . . _ . _ . . - - -

-.

.

i of note was the comprehensive PORC review of the startup test results. The PORC was clearly not a " rubber stamp" review.

Each test was reviewed and extensive discussion was required to satisfy the PORC that the test results and any test exceptions were acceptable and the plant was capable of safely proceeding into the next test condition.

2. Conclusion Rating: 1 Trend: Continuing improvement was noted throughout the period.

3. Board Recommendations None (

,

f

.

- - . .- ___ . . _

.

(

H. Training and Qualification Effectiveness (NA)

1. Analysis During the assessment period, training and qualifications effectiveness is being considered as a separate functional area for the first time.

Training and qualification effectiveness continues to be an evaluation

- criterion for each functional area.

The various aspects of this functional area have been considered and

' discussed as an integral part of the other functional areas and the respective inspection hours have been included in each one. Conse- i quently, this discussion is a synopsis of the assessments related to training conducted in other areas. Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy. This dis-cussion addresses three principal areas: licensed operator training, non-licensed staff training, and the status of INP0 training accreditation.

Weaknesses were noted during operator licensing examinations this period which suggest a need for the following training improvements:

emphasis in the utilization of Transient Response (TRIP) procedures; Technical Specification familiarity and use, particularly for multiple

{ component failures; increased on-the-job training relative to refuel-ing floor procedures and refueling equipment operation; and, improved communication among the candidates during the simulator portion of the exams. An overall strength noted was candidate familiarity with equipment and component location. Limerick's full-scope simulator

i

! is performing well and is proving a valuable asset for transient training.

,

The performance of licensed operators in the control room has been observed by the NRC to be good. Operators are proficient in recovering i

from plant transients and have demonstrated an overall sound knowledge of Technical Specifications as evidenced by daily discussions with NRC inspectors. As discussed in Section IV.G, the licensee used the

Limerick simulator as an effective tool to prepare personnel for plant response to several of the major test evolutions during the power

- ascension program. As a result, operating shifts were observed to be well prepared during the conduct of testing such as initial turbine

,

roll and the loss-of power test. Also, operators effectively used the Transient Response (TRIP) procedures during major testing such as the turbine trips; this was notable in light of the weakness identified during the first set of license exams given. Another example of training which enhanced the startup test program was the licensee's pre-test practice at the remote shutdown panel for the shutdown test from outside of the control room.

k

.__. _

.

'

.

31 i,

STA training was observed during the end of the assessment period to be in conformance with license commitments. The utilization of presently qualified STAS has been effective and is discussed in Section IV.A. The current shif t complement of STAS have had the benefit of startup test experience and are therefore knowledgeable of plant transient response.

Staffing levels in the fire protection area were acceptable, and a full time Fire Protection Assistant is assigned on-site. Fire pro-tection staff were experienced and knowledgeable of program require-ments. Fire brigade training deficiencies were observed in that some fire brigade members missed quarterly meetings and semi-annual drills.

The licensee took short-term and long-term corrective action to improve the effectiveness of the trainirg program.

The general training program for all radiation workers is well developed and implemented. The licensee further refined the radiation protection technician training program by analyzing the tasks and associated procedures for each level of technician responsibility. Training interviews by the NRC showed adequate knowledge by the staff. In addition, the licensee tested all senior-level technicians to. determine areas of weakness and establish a remedial training program. A train-ing program for entry-level Assistant Technicians is being coordinated

,

with the Peach Bottom Station.

!

A measure of the effectiveness of the licensee's training programs was the relatively few number of unplanned scrams and unnecessary challenges to safety systems attributable to perso1nel errors during the assessment period. Five of the nine unplanned scrams were caused by personnel error. I&C technician errors in the last 8 months of the assessment period were reduced by a factor of 20 as compared with the first 6 months of the period. The frequency of such events (analyzed in Section V.D) was significantly reduced towards the end of the assessment period due, in part, to licensee management initia-tives in training.

Training interviews by the NRC indicated that Maintenance Division craftsmen and supervisors receive training on administrative controls applicable to their job classifications, as well as technical training on selected nuclear maintenance topics. Maintenance engineering personnel pursue a self-guided indoctrination and familiarization program. Onsite on-the-job training is provided for junior technical assistants in the maintenance department.

4

. - - - . .,, - -

. - - - - , = - , . - , - . - - - ,

.

i As noted in Section IV.F, the security force training program does not appear to instill in force members a strong sense of purpose and an understanding of their role and responsibilities.

The licensee's training programs are currently being audited for accreditation by INPO. Self-evaluations for all ten INP0 accredi-tation areas have been submitted to INP0; INP0 audits of the program were begun in February 1986; and accreditation is scheduled for com-pletion during the next SALP assessment period.

2. Conclusion:

Rating: 2 Trend: No basis 3. Board Recommendations NRC:

None Licensee:

Provide refresher training in refueling operations and core alter-ations in preparation for first refueling outage. Also, consider emphasis of training in Technical Specification LCOs, where multiple component failures may affect more than one system LCO.

I o

l f

. -. ._. __ - _ . - - _ - _ _ . _ _ _ . . _

- . - - -- _

I

. :

.

i I. Licensing Activities (NA)

1. Analysis This assessment is based on the licensee's performance in support of major licensing activities such as the Atomic Safety and Licensing Board and Appeal Board activities, issuance of Safety Evaluaticn Report Supplement (SSER), Nos. 4, 5, and 6, issuance of the full power license and execution of the startup testing program.

The licensee has sustained the high level of performance in the Licensing area that has been attained in the past two assessments with only one major exception. Specifically, this was in the hand-ling of the safety parameter display system (SPDS) issue as discussed below. However, the licensee's response to staff inquiries in this area was vigorous and technically sound.

Overall, the licensee's strong points are their approach to problems from a safety standpoint, responsiveness to NRC concerns, the quali-fications and depth of staffing and the reporting of events. Senior management control is widely apparent and particularly when a response to a problem is called for. An area where some weakness may be apparent is in the continual maintenance of a broad oversight to ensure that forthcoming schedular requirements, such as needed

'

requests for amendment of the license and the requirements of con-ditions to the license, are recognized and responded to in a timely manner.

The licensee's management has been directly involved in almost all of the major licensing activities addressed in this assessment.

Notable examples of the positive contributions resulting from this invulvement as well as several areas which could have benefited from additional attention are discussed below.

Management involvement in responding to the issues identified in SSERs 4, 5, and 6 was very productive in that for the majority of these issues the initial response was sufficient and further requests for information were not required to support the resolution of the issues. For one of these issues, the potential effects of tornado missiles on the ultimate heat sink, the Senior Vice President for Nuclear Power was directly involved in the staff's visit to the plant site. Although several other issues, namely the Independent Design Verification Program (IDVP) item concerning pipe break jet impinge-ment loads and the remote shutdown systems issues, required several interations, these issues were responded to vigorously over a short period of time upon clarification of the problem areas.

l l

.

34

!

Management involvement in the preparation of the first two requests for amendments to the license was cpparent in that the Superintendent for Plant Operations participated in a meeting to ensure that these applications contained adequate bases for the determinations on significant hazards and environmental impacts. Management involvement was also particularly evident in the development and implementation of a corrective action program in response to the relatively high rate of reportable events experienced in the early months of licensed operation. Management's control of communications was demonstrated while undergoing several changes in management responsibilities in response to the transition in plant status from a construction /

preoperational state to an operating state. Coordination of the communications between the NRR staff and personnel in the Electrical Production Department, the Engineering and Research Department, which previously had the sole responsibility for dealing with NRR on issues, and the plant staff has been accomplished in a very effective manner.

.

The licensee's high degree of responsiveness to staff initiatives continued to be demonstrated for all but a few instances (e.g.,

remote shutdown system and safety parameter display system issues)

wherein the licensee allowed a substantial fraction of the available time for dealing with an issue to expire before submitting the response to the staff. The licensee has supported meetings and dis-

,

cussions with the staff as frequently and in as much depth as required

to reach a technically sound and thorough resolution. This was demon-strated on the tornado missile effects, IDVP, preservice inspection, remote shutdown, Detailed Control Room Design Review (DCRDR) and SPDS issues. The licensee characteristically meets prior schedule commitments or advises the staff of the need and the basis for read-justment of schedules.

The licensee's corporate staff has centinued to be maintained at a stable level. This is due in part to the relatively low turnover of key technical and managerial personnel, many of whom have been with the licensee throughout much of the Unit 1 operating licensing review.

The corporate staff level in Philadelphia has been ample to meet the needs of the licensing activities during this period. This has been demonstrated in meetings and discussions with the NRC staff wherein the staffing level has in virtually every instance been adequate to meet the objectives of the meeting.

Finally, as discussed in Section IV.A (Operations) and analyzed in Section V.C (LER supporting data), there have been 143 events reported

' during the assessment period. A relatively large (58) number of these events occurred during the first 2-3 months of the period, and 37 occurred prior to achieving initial criticality on December 21, 1984.

During the remaining 12 months of the assessment period, the rate at (

.

I which events were reported decreased significantly, due in part to the licensee's energetic corrective action programs. The frequency of events was reduced by about two-thirds, and is considered to be average for a new plant.

2. Conclusions Rating: Category 1 Trend: Consistent 3. Board Recommendations NRC: Conduct a meeting with the licensee to discuss ongoing PRA activities.

Licensee: None

(

.

\

J. Assurance of Quality (NA)

1. Analysis During the assessment period, the assurance of quality is befng con-sidered as a separate functional area for the first time. Maragement involvement and control in assuring quality continues to be one evalu-ation criterion for each functional area.

The various aspects of quality assurance program requiriments have been considered and discussed as an integral part of each functional area and the respective inspection hours are included in each one.

Consequently, this discussion is a synopsis of the assessments con-ducted in those areas.

As discussed in Section IV.G, QA/QC coverage of the startup test pro-gram was extensive. QA audits were performed for each test condition and QC personnel performed 100% surveillance of startup testing. The application of QA/QC in startup activities significantly contributed to the high degree of success of the test program.

QA and QC involvement is evident in the areas of modification and design activities, and radwaste shipping and transportation. Also, QC is directly incorporated into maintenance job classification and (

planning processes. QC review and approval is required for all safety-related maintenance actions for fire protection, ASME and se-lected non-safety work, and QC mandatory witness points are included as part of maintenance activities. The licensee utilizes Quality Assurance as part of corrective actions for NRC findings as evidenced by the audit of PORC-reviewed procedures for proper inter-disciplinary evaluation.

The licensee has implemented a system to analyze trends and determine root cause of quality problems in response to NRC concerns expressed in the previous assessment wherein a weakness was identified in the implementation of QA for plant operations. The weakness involved a lack of a comprehensive trending analysis which considered all exist-ing corrective action systems. The licensee's Electric Production QA Department developed a procedure in July 1985 to track and evaluate quality problems identified by not only licensee QA/QC programs but also other organizations such as INPO, ANI, NRC and the Joint Utility Management Association (JUHA).

The Quality Assurance Tracking and Trending System (QATTS) compiles findings in appropriate operational areas, performs trend analysis to define potential problem areas, and evaluates root cause and correc-tive action. Information is graphically displayed in monthly reports to licensee QA management and quarterly reports which are distributed I

( !

!

-- __ _

,

a

,

37

!

i to upper level licensee management including the Vice President Electric Production. The QATTS exhibits findings for each respon-sible organization versus cause codes, and weighted findings against 10 CFR Part 50, Appendix B. The system is relatively sophisticated but fairly new, and the licensee is revising the methods of data presentation via trend lines to make quality problems more readily apparent. The initial quarterly report covered the third quarter (July-September) of 1985 and utilized findings from a two year period dating back to October 1, 1983. The organizations evaluated included Limerick and Peach Bottom Stations, the PECO Maintenanca Division, Engineering and Research Department, and vendors. The effectiveness of QATTS has not yet been assessed by NRC inspections, although it is of interest to note that QATTS indicated that the cause of most findings were personnel errors which involve non-adherence to proce-dures.

The licensee's corporate Nuclear Review Board has been convened on-site on several occasions during the assessment period. The topics of discussion were the more significant safety issues experienced during the period. The licensee also utilizes the Independent Safety Engineering Group (ISEG) for oversight of plant operation and design, including post-scram reviews, attendance at PORC meetings, and the LER survey and trend analysis this period. The onsite review y

committee (PORC) was active in review and approval of startup test

,

' results, plant operational activities, and special issues or station problems. The high level of activity during this assessment period resulted in frequently convened PORC meetings. The meetings created a large demand on station management and supervision time, but did not detract from safe plant operation and was not realized at the expense of other programs. The PORC has been instrumental in improving the quality of LERs, safety evaluations for modifications, and Technical Specification interpretations via PORC Position Papers.

Although not all of the above discussed programs have been reviewed for effectiveness by the NRC, there is clear evidence of the use of various methods to assure that quality is instilled in all facets

' of facility activities by licensee management.

2. Conclusion Rating: 1 Trend: No Basis

,

i )

-

,

i

__ _ ___ _ _ _ _ _ _ _ _ _ . _ _.._._ _ _ _ _

, _ _ _ _ . - . _ _ _ _ , . -

.

3. Board Recommendations:

NRC: Schedule a meeting with the licensee to discuss the use and effectiveness of the QATTS.

Licensee: None

,

$ l

o

.

(

V. SUPPORTING DATA AND SUMMARIES A. Investigation and Allegation Review No investigations were conducted during the assessment period.

Several allegations were received from plant employees and a security program subcontractor, and were reviewed by NRC security specialists. One allegation that two guards left their post was substantiated, and enforcement action is under consideration.

Another allegation involved an alleged hole in a bioshield door which was unsubstantiated.

B. Escalated Enforcement Actions 1. Civil Penalties A fif ty thousand dollar civil penalty was issued during the assessment period for cumulative violations of physical security requirements. Also, a violation is under consideration in con-nection with openings found in security vital area barriers.

2. Orders

,

A Confirmatory Order was issued by NRR on August 16, 1985 restricting power levels to 5*; rated. The Order effectuated an August 15 decision by the Third Circuit Court of Appeals staying the full power license pending appeals. The Order was lifted on August 21, 1985.

3. Confirmatory Action Letters None C. Management Conferences February 15, 1985 Corporate and Site Security Organization February 22, 1985 Operational Excellence Program March 11, 1985 Enforcement Conference - Oversight of Security Guard Force; Falsification of Training Records March 12, 1985 SALP Management Meeting September 25, 1985 Startup Test Program Status February 7, 1986 Enforcement Conference - Degraded vital (

area barriers

.

, .

. 40

!

D. Licensee Event Reports (LER)

1. Tabular Listing Type of Events A. Personnel Error 60 B. Design /Manuf./Constr./ Install. 42 C. External Cause 0 0. Defective Procedure 14 E. Component Failure 16 X. Other 11 Total 143 LERs Reviewed LER Nos. 84-03 to 86-001 2. Causal Analysis

[

A detailed evaluation of LER quality using a sample of 30 LERs issued during the assessment period was made using a refinement of the basic methodology presented in NUREG/CR-4178. In general, the LERs were found to be of above average quality based on the requirements contained in 10 CFR.50.73.

All 143 LERs which were reported during the assessment period (40 in 198,, 4 102 in 1985, and 1 in 1986) were also subject to an ongoing review as part of NRC inspections for trends and

~

root cause identification.

Three sets of common' mode events were identified.

a. Personnel Errars by I&C Technicians

_

LER No. Discussion ~

84-31 These events were caused by poor 85-03 communication by I&C technicians with

35-14 the on-shift licensed operators.

85-51 84-11 These events were caused by I&C technicians 84-30 and involve ESF actuations generated by 85-10 electrical grounds and shorts which occurred 85-11 during the performance of STs.

{

85-16 85-49 ,

.--r -

-u. ,--m... -. - m - _ _ . _ - - , --- - - - - . - - -

.

1 LER No. Discussion 84-07 These events were caused by I&C technicians 84-19 not properly venting and filling instrument 85-18 lines or other valving errors.

85-37 85-40 85-47 84-17 These events involve mental mistakes by I&C 84-24 technicians such as leaving a device with 84-32 the wrong setpoint (84-17), not resetting 85-20 a partial isolation during a surveillance 85-88 test (84-24), not checking an electrical print (84-32 and 85-20), and not recognizing the physical sensitivity of a relay (85-88).

The frequency of personnel errors was identified in December, 1984, was discussed with site management at that time, and was formally transmitted to the licensee as a regional concern in January 1985. Meetings were held at Region I with licensee management regarding plans for cor-rective action. Licensee initiatives were successful in

!

,

reducing the incidence of events caused by personnel error.

Specifically, there has been only one event (LER 85-88)

caused by I&C technician personnel error in the last 8 months of the assessment period as compared with 20 during the first 6 months of the assessment period.

b. Operations Inexperience (1) Procedure Deficiencies LER No.

84-04 Four hose stations not inspected due to omission from ST.

84-15 Inadvertent ESF actuation during ST due to valve omitted as isolation valve in procedure.

84-43 TS required data not taken on stroke time of suppression pool level instrumentation valve due to procedure deficiency.

85-02 RWCU isolation due-to restoration procedure not ensuring adequate filling and venting of system.

I 85-15 Sprinklers inoperable due to administrative J procedure deficiency which did not address I post-modification restoration of TS required non-safety systems.

<

' ~

. u

.

. . t

-

,

, .

'

. 85-22 MSIV leakage control system inoperable due to ST

~

P 4

,3~

deficiency not reclosing breakers after test.

m 85-34 Inadequate sodium pentaborate volume due to ST

calculation' deficiency.

,e 85-38 ' Inadvertent ESF during ST due to omission in restoration procedure leading to actuation upon

'

' power restoration.

85-58 TS required check for water in EDG day tanks overlooked due to omission in ST.

s , , q 85-64 RWCU pump tripped due to airbound suction piping s

caused by inadequate ST which did assure adequate post-test vent and backfill. RWCU was acting as

.

TS required decay heat removal system due to

.

i both loops of RHR shutdown out of service.

s 85-32 s RWCU isolation due to inadequate system startup

,

procedure which did not adequately address an existing system configuration.

'

.

'

85-98 RWCU isolation due to omission in a procedure

< '

used to effect a modification to the SLCS.

'

The frequency of events caused by procedure deficiencies dropped sharply during the assessment period reflecting

,

the gains in experience in employing procedures under varying plant conditions. There were 8 events caused by precedural deficiencies reported the first 5 months of the assessment period as compared with only 4 events during

,

the'tast 9 months.

(2) Misunderstanding of TS Requirements 84-09 Service water rad sample not obtained within TS-84-27 required period.

84-16 Recirc pump start without TS-required pre-start ST.

84-44 Failure to demonstrate alternative means of decay heat removal as required by TS.

d

'

85-13 Partial loss of HPCI isolation ability due to transmitter not being placed in tripped condition ;

s as required by TS after being out of service for one hour.

( b

l

.

.- _ . . - - - . _ . - .

.___ ,

!

l

*

. 43 (

85-78 TS-required ST not performed because cognizant individual failed to recognize that the plant conditions which triggered the TS requirement had been met.

85-84 TS-required manual rod block not inserted because cognizant individual failed to recognize that declaring the third (of eight) IRM inoperable triggered TS requirements.

85-91 TS-required containment isolation provisions not met because cognizant individual failed to.

recognize that deenergizing the motor operated stop check in the SLCS would trigger the TS LCO.

The frequency of events caused by not meeting TS require-ments dccreased during the assessment period due to gains in operating experience similar to the decrease in procedure deficiency caused events. There were 5 instances of TS misunderstanding during the first 3 months of the assessment period as compared with 3 instances in the last 11 months of the assessment period. The more recent examples of TS misunderstanding differ from previous ones in that the earlier events involve not f

understanding TS requirements whereas later events involve not recognizing that changing plant conditions triggered additional TS requirements. This difference was recognized by the licensee in taking long term corrective actions in response to 85-78 and 85-84.

c. Component Failure 84-08 85-50 These events involve an ESF actuation (CR 84-10 85-59 Emergency Fresh Air System) due to chlorine 84-28 85-63 analyzer tape break. The licensee attempted 84-33 85-81 numerous modifications and finally installed 84-46 85-85 a new system which is expected to be more 85-29 85-86 reliable. The new system was not yet oper-85-30 85-92 ational at the close of the assessment 85-31 85-93 period.

85-42 85-97 l

l L

.

,

.

'

1 84-12 These events involve an ESF actuation (RWCU isolation)

84-26 due to defects in Riley Temperature Modules. Three 84-34 other identical events (85-25, 85-35 and 85-55) were 84-35 suspected to be due to similar defects. Initially 84-36 the licensee was unable to identify the source of the 85-01 trips. Corrective actions included the installation 85-27 of circuit monitoring equipment which enabled 85-61 identification and repair of the device causing each 85-71 subsequent trip. The incidence of these. events decreased with 8 events in the first 4 months of the assessment period to 4 events in the last 10 months.

84-39 These events involve RPS and NSSSS actuation due to 85-07 voltage fluctuations. The licensee installed RPS 85-24 power supply circuit monitoring equipment, identified 85-26 and replaced the failing components, and determined the root cause to be excessive cabinet internal temperatures. The licensee modified the cabinets to increase air flow and lowered the local area temperature. No subsequent failures were experienced.

The decrease in reportable events due to repetitive component failures is due to the licensee's consistent emphasis on root I

cause identification and correction. An exception to this is the chlorine analyzer tape break which isolates the control room emergency fresh air system. Poor original design and slow determination of the root cause indicate less than adequate management attention.

L ( )

.

F

,

.

o

. 45

!

TABLE 1 TABULAR LISTING OF LERS BY FUNCTIONAL AREA LIMERICK GENERATING STATION, UNIT NO. 1 Cause Code Area A B C D E X Total Plant Operations 20 38 5 9 9 81 A.

Radiological Controls O B.

3 1 1 5 C. Maintenance Surveillance 25 9 4 38 D.

E. Emergency Preparedness Security and Safeguards 0 F.

Outages 0 G.

.

H. Training And Qualification

Effectiveness 1. Licensing Activities 1 1

J. Assurance of Quality 12 4 1 1 18 K. Other Totals 60 42 15 15 11 143 Cause Codes: A. Personnel Error B. Design, Manufacturing, C'onstruction, or Installation Error C. External Cause D. Defective Procedure E. Component Failure X. Other i

.

~ ~

.

f TABLE 2 INSPECTION HOURS SUMMARY (12/1/84 - 1/31/86)

LIMERICK GENERATING STATION, UNIT NO. 1 Hours % of Time A. Plant Operations. . . . . . . . . . . 1733 39 8. Radiological Controls . . . . . . . . 424 10 214 5 C. Maintenance . . . . . . . . . . . . .

330 7 D. Surveillance. . . . . . . .....

Emergency Preparedness. 281 6 E. ......

Security and Safeguards . . . . . . . 270 6 F.

G. Preoperational and Startup Testing Testing . . . . . . . . . . . . . . . 1193 27

. H. Training and Qualification I Effectiveness . ........... N/A N/A I. Licensing Activities. . . ..... N/A N/A J. Assurance of Quality ........ N/A Ng Total 4445 100 k

i l

.

. .

47

'i

. TABLE 3 ENFORCEMENT SUMMARY (12/1/84 - 1/31/86)

LIMERICK GENERATING STATION, UNIT NO. 1

,

A. Number and Severity Level of Violations Severity Level No.

Severity Level 1 0 Severity Level 2 0 Severity Level 3 1 Severity Level 4 9 Severity Level 5 _1 Total 11 i

B. Violations Vs. Functional Areas Severity Levels II III IV V DEV TOTALS FUNCTIONAL AREAS 6 6 A. Plant Operations

y B. Radiological Controls O

C. Maintenance

D. Surveillance

E. Emergency Preparedness

F. Security and Safeguards 1 3 1 5 G. Preop./Startup 1 0 1 9 1 1 12 Violation and Deviation Totals:

k

.

o y , .. ,_ , . _ , _ - . _ _ - ,.c ,_- - m.

~ ~ . - - _ - - . , _ . . - . . _ _ , . _ , . _ _ _

.

. ,

48 i

.

C. Summary - Enforcement Data Inspection Inspection Severity Functional Report No. Date Level Area Violation 85-01 1/2-4/85 IV Preoperations Failure to follow Blue Tag test procedures and QC inspection procedures regarding work on the circuits on DWG E-519 85-01 1/2-4/85 DEV Preoperations Failure to have Preop test IP 59.1 implement the test methods described in its FSAR test abstract.

1/1-31/85 IV Operations Tech. Specs. related 85-02 equipment removed from service without proper authorization.

85-02 1/1-31/85 IV Operations Control room maintained in a vacuum without per-forming safety evaluation.

(

IV Operations MSIV-LCS inoperable due 85-03 1/24-2/1/85 to operator oversight and incorrect surveillance test procedures.

85-06 1/16-2/7/85 V Startup Failure to follow Admin-istrative Procedures in the processing of TER-22 and TER-29.

85-06 1/16-2/7/85 IV Startup I&C personnel operating reactivity equipment without control room operator knowledge.

85-06 1/16-2/7/85 IV Startup Lack of control for troubleshooting activities.

85-08 1/17-21/85 IV Operations Failure to maintain RWCU containment isola-tion valves operable.

I

,

.

, ,

- 49 I

Inspection Inspection Severity Functional Report No. Date Level Area Violation 85-12 2/4-8/85 III Security A total of five viola-tions have been cate-gorized as a Level III and a $50,000 fine was imposed.

1. Failure to control vital area keys after security shift is completed.

2. Failure to change compromised vital area locks.

3. Failure to report a security event to NRC.

4. Failure to re-

"

establish an ade-

{

quate level of pro-tection for a degredated security system.

5. Failure to certify watch persons prior to entry on duty.

85-16 3/16-4/30/85 IV Operations Failure to assure a multidisciplinary review of an ST at SUB-PORC.

l IV Operations ESW Loop B discharge 85-43 11/1-14/85 valves throttled and ESW Pump A discharge valve unlocked.

Security One Severity Level III 86-01 1/2-3/86 III violation regarding openings in protected area and vital area

' barriers and security force members leaving assigned posts.

\

.- .. --

- . .- .. .. . _ _ . - .-

.

. .

50 f

TABLE 4 INSPECTION REPORT ACTIVITIES (12/1/84 - 1/31/86)

LIMERICK GENERATING STATION, UNIT NO. 1 Inspector Hours Areas Inspected Report / Dates 84-71 Specialist 191 Startup Test Program 12/5-31/84 84-72 Resident 157 Routine, daily inspections and unscheduled backshift inspections 12/1-31/84 84-73 Specialist 25 Followup inspection of Emergency 12/4-5/84 Preparedness 84-74 Specialist 75 Startup Test Program 12/28/84-1/11/85 85-01 Resident 15 Special Inspection - Inoperability 1/2-4/85 of two containment isolation valves 85-02 Resident 213 Routine, daily inspections and

unscheduled backshift inspections 1/1-31/85

'

85-03 Specialist 227 Special announced operational assessment team inspection 1/24-2/1/85 85-04 Cancelled Specialist 20 Routine, unannounced inspection of 85-05 the safety related corrective /

1/15-17/85 preventive maintenance program Specialist 79 Startup Test Program 85-06 1/16-2/7/85 Specialist NA Operator Licensing Exams 85-07 1/14-18/85 85-08 Resident 10 Special inspection - RWCU system 1/17-21/85 inoperability Specialist 22 Routine, unannounced inspection of 85-09 system interactions 1/22-24/85

\

_ _. _. . _ _ _ - ._ - __ _ . _ _ -,

.

. ,

- 51

.

Inspector Hours Areas Inspected Report / Dates 85-10 Specialist 40 Routine, announced inspection of Emergency Preparedness Implementa-1/22-3/8/85 tion Appraisal 85-11 Resident 278 Routine, daily inspections and unscheduled backshift inspections 2/1-3/15/85 85-12 Specialist 46 Routine, unannounced physical 2/4-8/85 protection inspection 85-13 Specialist 94 Routine, announced inspection on 2/25-3/11/85 Chemistry, Radiation Protection and Radioactive Waste Management 85-14 Specialist 58 Startup Test Program 2/20-3/13/85 85-15 Conference NA Enforcement Conference for IR 85-12 85-16 Resident 216 Routine, daily inspections and unscheduled backshift inspection ( 3/16-4/30/85 85-17 Specialist 186 Routine, announced inspection of 4/2-4/85 observation of the licensee's emergency exercise 85-18 Specialist 26 Routine, unannounced inspection of 3/26-28/85 the preoperational test procedure results evaluation.

85-19 Specialist 186 Special, inspection of the 4/1-19/85 operation, maintenance testing and surveillance of the high-low pressure interface 85-20 Specialist 48 Routine, unannounced inspection of 4/1-4/85 the Startup Test Program test results 85-21 Specialist 50 Routine, unannounced safety 4/1-4/85 inspection of Radiation Protection 85-22 Specialist 68 Special Physical Security Inspection 4/17-22/85 l

.

. .

52

'

i.

Inspector Hours Areas Inspected Report / Dates 85-23 Specialist 20 Routine, unannounced inspection of the chemistry and gaseous radwaste 4/23-26/85 systems 85-24 Specialist 23 Routine, unannounced inspection of 4/30-5/2/85 the Startup Test Program 85-25 Resident 64 Routine, daily inspections and unscheduled backshift inspections 5/1-31/85 85-26 Specialist 56 Routine, announced ins'pection of the Radioactive Waste Management 5/20-26/85 Program 85-27 Specialist 58 Routine inspection in closing out 1/3-28/85 of outstanding items 85-28 Specialist 29 Routine, inspection of Radioactive Waste Management Program 9/16-19/85 85-29 Specialist 28 Security Program management 7/8-12/85 effectiveness, physical barriers

and detection aids 85-30 Resident 274 Routine, daily inspections and unscheduled backshift inspection 85-31 Specialist 12 Special, announced inspection of 7/17/85 an emergency preparedness account-ability and evacuation drill 85-32 Specialist 40 Routine, inspection of the Quality 8/5-9/85 Assurance program for power ascension 85-33 Specialist 18 Special, inspection of the Emergency 8/8/85 Preparedness training program for the security force 85-34 Specialist 4 Security drawings allegation 8/7/85 followup 85-35 Specialist 72 Startup Test Program 8/11-23/85 85-36 Resident 278 Routine, daily inspections and '

l unscheduled backshift inspections 9/23-10/30/85

~

\

.

_ _-

._. _

.

. .

- 53 i

Report / Dates Inspector Hours Areas Inspected 85-37 Specialist 145 Startup Test Program '

9/3-20/85 85-38 Specialist 81 Startup Test Program 9/30-11/6/85 85-39 Specialist 44 Routine inspection of the fire 10/7-11/85 protection / prevention program 85-40 Specialist 27 Routine inspection of the radiation 10/7-11/85 protection program 85-41 Specialist NA Operator Licensing Exams 11/11/85 85-42 Specialist 32 Routine inspection of the Physical Security 10/28-11/1/85 85-43 Resident 49 Special inspection - Emergency Service Water System 11/1-14/85 Specialist 90 Startup Test Program j 85-44 11/20-12/6/85 85-45 Specialist 14 Special inspection, followup on an 11/19/85 allegation to the Security Plan 85-46 Resident 209 Routine daily inspection /unschedule backshift inspection 12/1/85-1/10/86 85-47 Specialist 58 Routine inspection of licensee's 12/2-6/85 action on previous NRC concerns 85-48 Specialist 61 Startup Test Program 12/16/85-1/3/86 86-01 Specialist 22 Special inspection for degradation 1/2-9/86 of physical security barriers 86-02 Specialist 68 Routine inspection of the Radiation Protection Program 1/6-10/86 Resident 207 Routine daily inspection and 86-03 unscheduled backshift inspections 1/11-2/19/86

!

._ . - . - _. -- - - _ . _ . - - - - . .- - __

--

.

,

54 TABLE 5

,

. UNPLANNED REACTOR SCRAMS LIMERICK GENERATING STATION, UNIT NO. 1 Power Date Level Description Cause 1 Note 1 1. 12/21/84 SD Reactor trip on The "B" RPS static inverter loss of "B" RPS voltage regulator board channel power con- failed on (high current with "A" temperature), output channel surveil- voltage fluctuated, and lance testing, feeder breaker to "B" RPS (LER 84-039) panel tripped open on over voltage.

12/22/84 Startup -Initial Criticality 2.*1/31/85 3.5?. Reactor trip on Improper activity control low vessel level by not involving I&C in due to operator that operator failed to error valving back realize that instrument -

in-service a jet had common reference leg pump developed head with vessel level j' instrument follow- instrumentation.

ing corrective maintenance. (LER 85-021)

2/17/85 Startup 3. 4/23/85 50 Reactor trip on Inadequate instrument low vessel level valve tagout. Failure due to I&C error to open instrument while removing a equalizing valve and not reactor level recognizing the effect of instrument from a leaking vent fitting.

service. A sur-veillance test was being performed (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months after tagout) on the other channel logic which generated a full scram signal. (LER 85-046)

8/8/85 Startup Note 1 - Determined by SALP Board, may not agree with LER analysis.

l * Scrams with Rod Movement

o

- o

, 55 (

Power Date Level Description Cause Operator inadvert- Personnel error compounded 4. 8/8/85 SD ently mispositioned by design change in that mode switch during switch had been replaced a startup into Run four months prior and was position (with easier to position.

MSIVs closed) caus- prior and was easier ing a reactor trip, to position.

(LER 85-066)

8/8/85 Startup Reactor trip on low Procedural inadequacy and 5.*9/11/85 28'4 vessel level during personnel error caused loss startup as a result of one of two on-line of reactor feed- condensate pumps due to water pumps trip- a spurious high suction ping on low suction strainer differential pressure. (LER pressure signal generated 85-073) while placing a third condensate pump in service.

l j

! 9/11/85 Startup l

6.*10/15/85 5tartup Reactor trip on Personnel error due to (800 psig) low vessel level lack of coordination

during startup between operators.

because the oper-ator increased reactor pressure above condensate pump discharge

,

pressure without starting a re-actor feed pump.

(LER 85-083)

j 10/15/85 Startup 7.*12/8/85 65's Reactor trip on Design deficiency in that high neutron flux GE SIL-362 was not imple-due to recircula- mented, and mismatch tion pump motor- between actual speed and generator speed demand signal was not increase caused apparent when operators by control cir- attempted to balance cuit failure. signals.

l (LER 85-095)

12/10/85 Startup

.

.

- 56 i

Power Date Level Description Cause 8. 1/2/86 SD Reactor trips on Design deficiency for 9. 3/3/86 low vessel level, wide versus narrow range twice within 90 vessel level instrumenta-minutes, because tion which feed turbine of indicated level trip versus RPS logic discrepancy respectively, between narrow and wide range instrumentation at decreased reactor pressure.

(LER 86-001)

1/8/86 Startup I

k

,

i

,

"

- - - - - - . . _ _ _ _ _ _ . . _ _ , _ . _ _ _ _ , _ _ _ _ , _ _ _ _ _ , _ ,_ _

O

*

.

.I TABLE 6 PLANNED SHUTDOWNS AND REACTOR TRIPS LIMERICK GENERATING STATION, UNIT NO. 1 Power Date Level Description 3/1/85 Heatup Manual scram on completion of T.C. heatup in conjunction with commencing maintenance outage 4/17/85 NA Drove rods to Cold Shutdown to await full power license 9/12/85 17?; Manual scram from remote shutdown panel (STP-28.1)

9/16/85 21'4 Scram on low level during loss of off-site power test (STP-31.1)

10/8/85 50*; Turbine Trip (STP-27.3)

11/14/85 75'; Turbine Trip (STP-27.3)

! 12/18/85 92*. Full MSIV Isolation (STP-25.3)

1/2/86 9 9'. Turbine Trip (STP-27.4)

1/13/86 25'; Manual scram from 25?; power to investigate Main Turbine Control valve #4 failure to close NOTE: All planned scrams were part of the Startup Test Program except the scram on 1/13/86 0 ,

-.

e. ,

- 58

TABLE 7 NRR SUPPORTING DATA 1, NRR/ Licensee Meetings January 10, 1985 Independent Design Verification Program Review February 7, 1985 DL Director's Briefing on Project Status March 5, 1985 IDVP Meeting on Jet Impingement Loads March 12, 1985 SALPMeetingandLicensingActivitieshsvi$w April 22, 1955 Remote Shutdown System Redundancy December 17, 1985 TS Surveillance Interval Extension for Valves 2. NRR Site Visits December 20, 1984 Ultimate Heat Sink Protection from Tornado Missile Events August 20, 1985 PM visited Resident Inspector and plant staff September 25, 1985 PM Attended Management Meeting to Discuss Results of Initial Phases of Startup Test Program December 5, 1985 PM, Hydrologist and Plant Systems personnel toured site in support of affidavits on potential for flooding of plant (LER 85-80)

3. Commission Briefings August 8, 1985 Consideration of Issu wce of Full Power License 4. Schedular Extensions Granted (Full Power License Conditions)

a) Fire protection - install stairway to Unit 2 cable spreading room b) Reactor Enclosure Cooling Water and Chilled Water Isolation Valves -

by first refueling outage c) Hydrogen Recombiner Redundant Isolation Valves - by first refueling outage d) Remote Shutdown System switches for pumps - by first refueling outage I

.

d'

' , ,

' 59 e) Refueling floor volume connection to Standby Gas Treatment System -

by first refueling outage f) Scheduling of next full emergency preparedness exercise - by May 1986 Note: Items a, b, c, and e were repeated in the full power license from the low power license which was issued prior to this SALP rating period. Item d was updated from the low power license.

5. Reliefs Granted Relief pursuant to 10 CFR 50.55a(g) for Revision 5 to the Inservice Testing Program for Pumps and Valves as discussed in SSER No. 5.

Relief from certain ASME Code Section XI Preservice Inspection requirements as discussed in SSER No. 5.

6. Exemptions Granted (Full power License)

a) GDC-61, SGTS to Refueling Floor Area b) GDC-56, Containment Isolation Valves c) GDC-19, Remote Shutdown Capability d) Appendix J, Containment Airlock Testing

/ e) Appendix J, MSIV Leak Rate Testing

~

f) Appendix J TIP Valve Leak Rate Testing g) Appendix J, RHR Valve Leak Rate Testing h) 10 CFR 50.44, Initial Containment Inerting i) Appendix E, Scheduling of EP Exercise 7. License Amendments Issued Two requests for amendment of the full power license Technical Specifica-tions were received but have not been acted on within the rating period.

Also, the following activities relevant to the issuance of a full power license occurred.

May 1985, SER Supplement No. 4 June 1985, SER Supplement No. 5 August 1985, SER Supplement No. 6 May 2, 1985 , ASLB Third Partial Initial Decision July 22,1985, ASLB Fourth Partial Initial Decision 8. Emergency Technical Specification Changes Granted None (

,.'

6 s

..

t 60 9. Orders Issued Numerous Orders were issued during this period by the ASLB and the ASLAB.

Perhaps the two most prominent orders issued were those issued by NRR on August 15 and 21, 1985. In the August 15, 1985 Order, the Director, NRR, suspended operation above 5% power in view of the U.S. Court of Appeals for the Third Circuit's stay of effectiveness of the full power license.

In the August 21 Order, the Director, NRR, rescinded the August 15 order based on the Court's lifting of its stay.

10. NRR/ Licensee Management Conference

.

February 7, 1985 Briefing of the Director, DL by the licensee and the staff on overall status of the project.

!

I

,

.. s*

O 4 ,. 4 Figure 1 Number of Days shutdown Limerick Generating Station, Unit No. 1 Dec. 84 28 Days Shutdown l l

~

Jan. 85 l 1 Day Shutdown I

Feb. 85 17 Days Shutdown I l

Mar. 85 31 Days Shutdown i Apr. 85 13 Days Shutdown I I

May 85 31 Days Shutdown I i

Jun. 85 30 Days Shutdown I

Jul. 85 31 Days Shutdown 1 Aug. 85 16 Days Shutdown I I

Sep. 85 1 4 Days Shutdown l

Oct. 85 I 6 Days Shutdown l

Nov. 85 I 10 Days Shutdown l

Dec. 85 1 4 Days Shutdown l

Jan. 86 13 Days Shutdown I

'

I i

,j

- _ _ _ - _ _ - _ _

'

' ** ENCLOSURE 3

- [ " U[ \,j,n yy E

+ u c:c .

-[a I t > . m.* A v t '. . h

./ .< .. . m v m:.. a u

.

a

,. .

8 .

g

..... t w

Docket Nos. 50-277 0 6 JUN 1986 50-278 50-352 Philadelphia Electric Corrpany ATTN: Mr. S. L. Daltroff Vice President, Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SAlp)

The NRC Region I SALP Board has reviewed and evaluated the performance of activities associated with limerick Genterating Station, Unit 1, for the period Dccember 1, 1984 through January 31, 1986 and Peach Bottom Atomic Power Station Units 2 and 3 for the period April 1,1985 through January 31, 1986. The results of the assessments are documented in the enclosed SAlp Board Reports.

A meeting to discuss the assessments will be scheduled for a mutually acceptable date, j As indicated by the enclosed assessments, we have observed a marked contrast in overall facility performance between the Limerick and Peach Bottom sites.

In its review the SALP Board noted that the programs at both sites are essen-tially similar, acceptable and fundamentally sound; however, we note an

'

apparent inconsistent implementation of these programs at the two sites, with much poorer results at Peach Bottom. We attribute this contrasting perfor-mance to the different direction given by the plant managers regarding how the programs are used and integrated into site activities. Specifically, the poor work practices observed, the procedural non-adherences, inattention to detail, and the defensive attitude toward NRC-identified problems reflect a serious management deficiency at the Peach Bottom site.

In contrast, the major activities at Peach Bottom associated with primary system piping replacement and other hardware modifications did not reflect the shortcomings referred to above. We attribute this good performance in the area of Refueling / Outage Activities, and the favorable Category 1 rating, to the f act that the work was planned, directed and executed in close coordination with your engineering department. Engineering support historically has been a strength of the Philadelphia Electric Company.

In order to understand better the perceived management deficiencies at Peach Bottom, and how they affect the safe operation of the plants, we will conduct an in-depth team inspection in the near future.

I

.

WMb5W I

. _ . _ _ , _ _ _ _ . _.,. ,_ __. _ _ ____ __ _ ,,,_.. _ _ _.

_ . _ . _ . _ _ . - _ _ . , _ .- , , _ _ . _ .

_ _ - - - _ _ _ -

j'

.i Philadelphia Electric Company 2 06 JUN 1986 At the SALP meeting, we request that you be prepared to discuss your evaluation of the situation and your plans to improve performance where weaknesses were noted in the SALP assessments. Additionally, you will be requested to provide any written comments within 30 days after the meeting. After the meeting and upon receipt of your response, your comments will be evaluated and we will provide our conclusions after consideration of the results from the forthcoming team inspection.

Your cooperation is appreciated.

Sincerely,

} W ?'

Thomas Regional Administrator

! Enclosure: 1. SALP Board Report No. 50-277/85-98 and 50-278/85-98 2. SALP Board Report No. 50-352/85-99

.

cc w/ enc 1:

V. S. Boyer, Senior Vice President, Nuclear Power John S. Kemper, Vice President, Engineering and Research J. Franz, Manager, Limerick Generating Station (Receives All 2.790 Information)

( R. S. Fleischmann, Manager, Peach Bottom Atomic Power Station (Receives All 2.790 Information)

Troy B. Conner, Jr., Esquire (Receives All 2.790 Information)

Eugene J. Bradley, Esquire, Assistant General Counsel W. M. Alden, Engineer in Charge, Licensing Section Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania a

J

._______ _ ____._._._ ___,__- _ _ _ . . _ _ _ _ _ _ _ _ - . . _ _ _ _ _ _ _ , _ _ _ _ _

, _ . _ . _ _ _ _ _ ._ _ _ _ _ _ _ _ . .

,

..

il l Philadelphia Electric Company 3 1 0 6 JUN 1988 bec w/ enc 1: '

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

PA0 (2 copies)

SALP Board Members (9)

T. Murley, RI DRP SALP File J. Taylor, IE D. Eisenhut, NRR R. Bernero, NRR DRP Division Directors, Regions II, III, IV V

'

(

~

ENCLOSURE 4 PHILADELPHIA ELECTOIC CSMPANY

'

,

2301 MARMET STREET P.O.30X 8699 PHILADELPHIA. PA.19101 taisi s45 soot August 12, 1986 m m,.m Docket No. 50-352 SALP Report: 50-352/85-99 Dr. T. E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue 19406 King of Prussia, Pa.

Dear Dr. Murley:

This letter provides our response to the SALP report for Limerick Generating Station which was forwarded by your letter of June 6, 1986.

Ne wish to thank the NRC for the opportunity to meet with you and the NRC staff at your office in King ofto discuss 11, 1986 Prussia on July Meetings of this nature provide a valuable Board report.

opportunity to exchange ideas, understand concerns and establish mutually recognized goals.

Philadelphia Electric has a goal of obtaining an overall SALP rating of 1. As your staff noted during the meeting, Limerick has continued to make improvemen goal.

During the meeting you requested that we confirm, in writing, our commitment to undertake a program to identify problems associated with the security area.

Security has been a difficult isarea, requiring recognized that increase t

events are being kept to a minimum itA reorganization related to i

improvement is required. Initially a nuclear plant security is being implemented.

senior level experienced security manager is being

' transferred to the Electric security operations at both Production staff to directThis individual nuclear plants.

, is currently visiting other utilities to review their programs and identify practices which can further enhanceBased upo

,

our security performance.

reorganization is contemplated including increased PECo i

'

,

'h -

. - _ - _ _ _ _-_

.gu02 33, Ause

-

Dr. T. E. Murloy Pogo 2

*

.

~

security personnel presence at both nuclear plants. Goals will be set and a timetable established to bring Security to a SALP rating of 1.

Should you have any questions or require additional information, please contact us.

Very truly yours,

'

,

/ , f

'

r y Lj ed L-/

cc: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 E. M. Kelly, Site Inspector See Service List l

l I

t _ _ _ - - _ _ _ _ _ _ _ _ _ - -

. _ _ - - _ - -- --

. . . .

B.' conner, Jr., Esq. l.C

-

'

,"

Trhemins.vogler,Esq.

me l

,

. o Nr. Frank R. Romano Cr. Robert L. Anthony

.

me. Maureen Sha111gan !

'

Charles W. Elliott, Esq.

Sarry M. Bartman, Esq. l Mr. Thomas Gerusky

.

Cirector, Penna. Emergency Management Agency !

Ang s Love, Esq.

David Wersan, Esq.

Robert J. Sugarman, Esq.

Rathryn S. Lewis, Esq.

Spence W. Perry, Esq.

Jcy M. Gutierres, Esq. Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section (3 Copies)

E. N. Nelly Timothy R. S. Campbell '

i .

!

.

I I

i I

!

July 21, 1986 i

i

, - ,,,-n,. .- - - , - - - - ~ - - - - - - - - - , - - - - - . - - - - - - - - - - - , , - - - - - -

.ugust 12, 1986

Dr. Thoma0 E. MurlOy Pcg2 2

.

2.

Address the number and repetitiveness of reactor scrans and personnel errors.

Concerning these recommendations, the following actions are in various stages of implementations o Leadership Training Program for supervisory personnel is underway.

o An aggressive program is underway to qualify and license relief and to provide immediate replacements for losses due to sickness, resignations, and retirements, o Shift professional personnel'will be supplemented with certified BWR engineers provided by the Nuclear Steam System These engineers will assist shift supervision Supplier.during the ecming period of training and qualification of personnel directed towards meeting quota.

o PECo is implementing a project management program for modifications which is using the concept of "LivingThis program Schedule".

scheduling which is expected to reduce pressures and strains on plant operating staff during periods of outage.

Additional actions being taken to improve our performance in the area of Plant Operations are as follows:

1. A system engineer program is being implemented which provides an engineer for each of the principal systems.

The engineer will monitor, arrange for preventative maintenance, and otherwise provide increased surveillance and performance monitoring of the system assigned.

2. A radwaste volume reduction progrr.m implemented.

is beingDry active was Additionally, a under contract with Genera 1' Electric.

resin reduction process, provided by General of 1987. Electric, will be implemented in the first quarter 3. Computerized log keeping activities are being pursued to provide additional reliable review of plant parameters in order to detect anamolles earlier.

4.

Refurbishing of the control room and its immediate environs will be expedited in the interest of improving the work environment and shift employee morale.

5. The equipment blocking management system is in place at Limerick and is being put in place at Peach Bottom to

- - _ _ _ _ _ - - - _ _ - . . , _ _ - . _

. - _ - _ . _ _ _ - - - _ _ - _ _ _ _ _ _

,

'

. ENCLOSURE 5 ;

-

.

-.

PHILADELPHIA ELECTRIC COMPANY 2301 MARMET STREET P.O.tox sees PHILADEWHIA. PA.19ggust 12,1986 arm sai soon mm Docket Mos. 50-277 g_ 50-278 i

i Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue 19406 King of Prussia, PA Systematic Assessment of Licensee Performance SUBJECT:

(SALP) for Peach Botton AprilAtomic Power Station 31, 1986

'

Assessment Period:

1, 1985 to January SALP Report.No. 50-277/85-98 REFERENCE: 50-278/85-98

Dear Dr. Murley:

,

Your letter dated June 6, 1986, forwarded the Systematic Assessment of Licensee Performance (SALP) Repo The purpose of this letter is to provide the Philadelphiaresponse Electric Company (PEco)The response to the Limerick SALP Report will the SALP report.

be filed separately.

( Philadelphia Electric Company management 12, appreciated 1986 at the the

opportunity to meet with the NRC staff on July Based l

i Region I Office and to discuss the SALP Report findings.the meeting on the discussions at comments:

Plant Operations i

i

' The SALP Board recommendations in the area of Plant Operations are as follows:

1.

Address the apparent complacent attitude and stress

.

' procedure compliance.

4 4q97d>b6 %

_

- _ - _ _ _ _ __ - - - _ ._ - _ _ _ _ _ . _ _ _ _ _ .

-- y . . _ _.

August 12, 198'6

~

Dr. Thomas'E. Murl-f Pago 3

.

..

reduce-the time delay in obtaining blocks and to improve

,

the legibility of permits. ,

6. Operator training programs have been accredited by the untional Academy for Nuclear Training.

The SALP Report noted that "atcontrol from times the public room address A formality".

system tends to distract planned modification vill provide for an upgrade of the plantOne feat public address system. separate page buttons for the control room a Depressing the general page button will page the the plant. Depressing the other page plant but not the control room.

button will page both the plant and control room areas.

Proper use of these two page buttons will reduce the number of non-operational related pages broadcast in the control

.

room.

The number and repetitiveness of scrams reported against The Independent Safety Peach Bottom is of concern to us. reviews plant scrams and prepares i i

Engineering event Group (ISEG) reports to determine As root partcauses of thisand recom l

'

corrective actions to preclude recurrence.in scram analysis, the site ISEG involvement in the iBWR Owners' Group Scram Frequency As l participantReduction Committee's efforts to reduce unplanned scrams.

commented during the. meeting, we are quite concerned that reactor scram signals generated in the course of performing in confined spaces under the vision and mobility outage work, constraints imposed by environmental When theconditions, details ofare creating these an impression of poor performance. events are an&lyzed, we bel that they have minimal significance. In reality, they were the result of bumping cables (which are highly sensitive to spontaneous pulse generation)

However, thesewhile and personnel others likewere themperforming are part

.various tasks. record and we are concerned that of the Licensee Event Report these types of events are not discounted.

Radiologica) Controls Board Recommendations For Licensee:

..

1. Complete long-term transportation related corrective 1985 actions discussed during the November 14, Enforcement Conference.

2.

Evaluate the ef fectiveness of the QA program relative to transportation related problems.

,

, - . . , - - . - - -

, . . . , .-n -

Auguot 12, 1986 Dr,. Thomao E. Murloy Pago 4

.

Concerning Recommendation 1, all of the long-term transportation related These corrective involved the actions have arrangement of been rigging cables completed.

for pallets, the cask trunion cup contamination problem, and increased QC inspections during loading operations.

The SALP Report requests an evaluation of the ef fectiveness of the QA program relative to transportation related The applicable fuel floor (Fuel Bandling) and programs.

Bealth Physics (EPO/CO) procedures have been r Control and station personnel concerning radioactiveAs a result of the material / waste shipments.the Quality Assurance Division will be identified items, included in the review of fuel floor and Special Procedures relating to include to shipment of radioactive material / waste in o steps.

Additional actions being taken to improve our performance in the area of Radiological Controls are as follows:

1.

The Health Physics Section at the station will be reorganized with the adoption of a Radwaste Section to be responsible for the handling and shipping and volume reduction practices.

the separation of Bealth 2.

As noted in the SALP report, Physics and Chemistry has been, and will continue to be, an effective step to improve the operations of these act.ivities.

3. Changes already made in the procedures and hard I

' problems with such shipments which had occurred during the SALP period.

4. Programs are in place and will be strengthened to reduce the volume of radwaste being include the shipped use of atosupercompactor disposal sites.

These programs willfor dry active waste and the installation of th I

system to reduce resin shipments and disposal.

Improved frisking has been accomplished by use of 5.

automatic friskers located at key access points and t plant exits.

l t

.

-

- -

--- __ __

August 12, 1986

Dr. Thomas E. Murloy Pogo 5

.

-

,

Maintenance i f

l

\

Board Recommendations for Licensee:

,

Improve the control of vendor information. l t

' _

Peach Botton Procedure A-92, " Control ofInVendor Manuals",

response to INPOwas l in December, 1985. '

placed into effectrecommendations, a major rewrite of this procedure is bein performed which will substantially incorporate the concepts contained in INPO Good Practice NA-304.

In addition to the major revisions to Peach Botton Procedure A-92, we are continuing with the vendor manual update program committed to in response to Generic Letter 83-28 (Salem ATWS).

As a result of this vendor manual update program, we have identified a number of enhancements to the applicable Engineering & Research Department procedures pertaining to oris expected th affecting the control of vendor manuals. It these ERDP procedures will be revised to include these ,

enhancements by June, 1987 in order to provide a fully

'

integrated system for vendor manual control between Peach Bottom and the Engineering and Research Department.

Additional actions being taken to improve our performance in the area of Maintenance are as follows:

1.

Esintenance training programs have been submitted to and evaluated by INPO as pa,rt of the Accreditation process. .

2. On-the-job training has been formalized as part of the /

accreditation process and should improve performance of routine maintenance activities.

3. Maintenance personnel have been assigned to the planningin of non-outage work. Pre-planning should result reduced equipment out-of-service times and reduced j

radiation exposure.

The daily meeting for planning and coordinating

.

4.

activities is continuing successfully.

5. A major program is underway to clean up and paint t l plantfoster a positive attitude in the workplace among plant l

'

personnel that will encourage quality work.

h

Dr. Thomas E. Murlcy Pago 6

-

!

. .

>

Surveillance Board secommendations for Licensee Establish management policy and controls which system operability.

Peach Botton has Testing System) Administrative been revised, Procedure approved andA-43 (Surveillance implemented.

The revised procedure addresses control and disposition Discussions between of grace period tests and overdue tests. members of your staf Additional actions being taken to improve our performance in the area of Surveillance are as follows:

~

1.

Backfilling procedures have been revised to eliminate scrams due to backfilling instruments.

the In response to a weakness identified by NRC, 2.

Surveillance Test Tracking Software Program is being revised in order tothose clearly identify tests which to appropriate require prompt station management

'

action to ensure timely completion.

i

'

Fire Protection Board Recommendations for Licensee: i Assess the results and evaluations of the radwaste build ng cable tray fire.

was performed by the t

An in-house evaluation of this eventSafety Evaluation Group The ISEG(ISEG) Gro PECo Independentindependent evaluation was performed by a ven report, the vendor report, Division commentsJ.on the vendor report were transmitted to Cooney, PECo, to S. D. Ebneter, NRC, NRC via letter M.

dated May 21, 1986.

Emergency Preparedness

,

Board Recommendations f or Licensee t Improve QA audit resolution and corrective action

'

1.

followup activities of emergency planning.

_ _ _

August 12, 1986

'

Dr. Thomas E. Murle, , Pego 7

-

.

. .

2. Promptly complete the actions required ot the Confirmatory Action Letter.

Concerning Recommendation 1, the Emergency Preparedness section tracks open critique / drill items. The OA Division will conduct a comprehensive audit by the end of 1986 of the Emergency Preparedness program including emergency action levels and Emergency Preparedness Section tracking and resolution of critique and drill open items.

Concerning Recommendation 2, all of the actions identified by the Confirmatory Action Letter referenced in the SALP Report have been completed. By March 31, 1986, eight. members of received formal training to corporate and station management qualify them as both Site Emergency Coordinator and Emergency Director. Three additional members will also be considered qualified as of the same date when documentation of the required reading assignment is received. Although the number of personnel available to serve the subject positions may be adequate, training to qualify all Shift Superintendents and station Senior Engineers is ongoing.

The corporate personnel designated as Site Emergency Coordinators, and the station Senior Engineers / Shift Supervision designated as Emergency Directors have been trained in the applicable event classification procedure (EP-101). This obligation was satisfied by virtue of Training participation in either the standard Emergency Plant Program or the Cycle I Licensed Operator Requalification.

Security and Safeguards j Board Recommendations for Licensee:

Provide closer day-to-day management oversight to assess 1.

the control of the contractor security force.

2.

Establish measures to anticipate demands for needed resources of the security organization.

l A reorganization related to nuclear plant security is being l Initially a senior-level, experienced security implemented.is manager being transferred to the Electric Production staff This to direct security operations at both nuclear plants.

individual is currently visiting other utilities to review their programs and identify practices which can further enhance our security performance. Based upon these reviews, further reorganizaticn is contemplated including increased PECo security personnel presence at both nuclear plants.

_ - - - .- - - - _ . - - ._ _ _-_-.

August 12, 1986 Pogo 8 Dr. Thoman E. Murio)

-

.

,..

!

Goals will be set and a timetable established to bring Security to a SALP rating of 1.

Refuelino/Cutage Activities None.

Board Recommendations for Licensee: that We are pleased to find acknowledgement in the rating of " Category l' in this area.

the responsibility and authority of ide him more It should be noted thatthe outage manager has been strengthen control of activities during an outage.

Training and Qualification Effectiveness None.

Board Recommendations for Licensee: d Training deficiencies noted in the SALP Report concerneOur comme Emergency Preparedness Training.

corrective provided in the actions taken Preparedness Emergency to resolve these deficiencies Section of this response.

Five programs are in the INPO accreditation process. d an Responses to the recommendations have bee October, 1986. is Feedback from plant events, particularly operator errors, being used to revise lesson plans and Simulator Training Scenarios to improve training effectiveness. !

f pssurance of Quality Board Recommendations for Licensee:

-- Consider a management review to determine:

groups (1)

the effectiveness of the several oversight and to which these groups are used to assure (2) the extent that performance improvements are achieved

. - - - _ _ .- - _ .

August 12, 1986 Pcgo 9 .

, Dr . Thomac 5. Murloy "

.

'

.

is an important organisation ;

The Nuclear Review Board (NRS)

used by PBCo to review the effectiveness of the severalThe M oversight groups.

special meetings, and is kept well informed of plant events.

. The NRS is comprised of knowledgeable The NRB has and expe l review safety concerns and corrective actions.

'

proven to be an effective mechanism for ensuring necessary improvements.

"QA oversight of The SALP Report also noted that: it did not surveillance testing activities was weak in that identify weaknesses in the surveillance program such as the missed or partially completed surveillances, a Surveillance Tests."

PBAPS Administrative Procedure A-43 (Surveillance Testing System)The hasQuality been revised Assurance to address Division overdue will conduct Surveillance an Tests.

additional audit of the ST program by the end of 1986 to include verification of the adequacy of this revised Administrative Procedure.

The SALP Report discussed Quality Control activities All purchase associated issued by Peach Bottom site.

with Unit The3 fuelControl Quality reconstitution. d ord organization is responsible for reviewing all purchase or ers issued by the site for proper Quality Assurance requirements.

!

This review will provide QC with notification of upcoming fuel floor activities, thereby enabling QC to provide the

proper coverage.

I Review Committee, comprised mainly of operations An Incident personnel, has been established to review the re l' errors and to gain input with regard to appropriate

'

corrective actions. as developed by INPO The Human Performance Evaluation System, and several utilities, is in the process of beingSeveral this people

' implemented.

use, and various mechanisms to inform the workers aboutThis progra program are under development.be implemented by the last qu l

l l

l

. _ _ - ,- - , _ _ _ - . .__-. ,- _ _ - - _

r Auguot 1986

pr. Thomas s. Murloy Pcgo 10

i

.-

'

(.

Licensine Activities mone.

soard Recommendations for Licenseet The SALP report noted a decline in the licensee's us Technical Specification issues, and the need to give more attention to the significant hasards considerationthat is submitted for determination (Sholly determinations) While the each Technical Specification change request. ;

<

preparation of License Amendment Applications the requ j

extensive review prior to submittal, we acknowledge that '

time needed to process an application should be reduced.

Acquisition of technical information necessary for preparation of the application, and on site review of th

!

more timely manner.

A license amendment application summary report has been developed for monitoring the pregress of applicationThe report w preparation. Peach Bottom Licensing Engineer and submitted The to his management as part of the bi-weekly staf f minutes. re meet schedule milestones and permit management to focus Additionally, theon those areas requiring more attention.

Licensing Engineer who prepared the application will

,' personally present the proposed application to the ThisPORC shouldfor

' approval for all but minor license revisions.

expedite the PORC approval process.

While the format of the significant hazards consideration was

<

revised in response to a finding in last year's SALP, 1986, we were to advised in Generic Letter 86-03, dated February 10, improve the technical discussions supporting the hazardsSin detenmination.

with the only application processed by the NRC since the

.

February 10, 1986 letter was published in the Federal I

Register with few revisions, we conclude that our efforts to improve the quality We areof the applications pleased is approaching that the NRC's NRC Project Manager expectations. concurred during the SALP meeting that the quality of the

!

License Amendment Applications has shown a noted improvement We will continue to emphasize the in recent months.

' importance of the significant hazards consideration in the preparation of future applications.

t

August M 3 Dr. Thomas E. Murt Pcgo 11 l

., .

I Should you have any questions or require additional information, please do not hesitate to contact us.

Very trul yours,

.

-

s

.

]

cc: T. P. Johnson, Resident Site Inspector

-

!

,

.-. - _ _ _ - .

-. _ _ -__ - __ -_______-_- _-_ - ____-_______ ____ ____ -____-___- -

ENCLOSURE 6

..

ATTENDEES Philadelphia Electric Company J. Spencer, Superintendent, Plant Services, Limerick Generating Station

- J. Franz, Plant Manager, Limerick Generating Station G. Leitch, Superintendent, Nuclear Generation S. Daltroff, Vice President, Electrical Production M. Cooney, Manager, Nuclear Production T. Doering, Superintendent, Operations, Limerick Generating Station W. Texter, General Supervisor, Quality Control R. Deneen, Director, Security P. Weindorfer, Assistant Director, Security W. Knapp, Director, Radiation Protection C. Mangans, General Supervisor, Quality Assurance R. Dubiel, Sr. Health Physicist, Limerick Generating Station J. Gallagher, Manager, Engineering W. Casey, Superintendent, Station Section

, R. Fleischmann, Manager, Peach Bottom Atomic Power Station J. Basilo, Administrator, Engineering, Limerick Generating Station G. Hunger, Jr. , Engineer-in-Charge, Nuclear Safety Section R. Logue, Superintendent, Nuclear Service R. Bulmer, Superintendent, Nuclear Training D. DiPacco, Sr. Engineer, Quality Assurance, Limerick Generating Station E. Gibson, Engineering, Quality Assurance, Limerick Generating Station W. Alden, Licensing C. McDermott, Manager, Public Relations W. Birely, Licensing Engineer, Peach Bottom Atomic Power Station J. Nagle, Licensing Engineer, Limerick Generating Station Nuclear Regulatory Commission R. Starostecki, Director, Division of Reactor Projects S. Collins, Chief, Projects Branch No. 2, Division of Reactor Projects R. Gallo, Chief, Reactor Projects Section 2A, Division of Reactor Projects T. Murley, Regional Administrator, Region I T. Johnson, Senior Resident Inspector, Peach Bottom Atomic Power Station E. Kelly, Senior Resident Inspector, Limerick Generating Station H. Williams, Resident Inspector, Peach Bottom Atomic Power Station S. Kucharski, Resident Inspector, Limerick Generating Station K. Abraham, Public Affairs Officer, Region I R. Keimig, Chief, Safeguards Security, Div. of Reactor Safety and Safeguards W. Johnson, Deputy Director, Division of Reactor Safety R. Martin, Project Manager, Nuclear Reactor Regulation J. Beall, Project Engineer, Division of Reactor Projects J. Wiggins, Chief, Materials & Processes, Division of Reactor Safety L. Bettenhausen, Chief, Operations Branch, Division of Reactor Safety Other D. Ney, Pa. Dept. of Environmental Resources, Bureau of Radiation Protection R. Wolf, Staff Writer, Philadelphia Inquirer i

__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _

IR 05000277/1985098

Text

Enclosures:

REGION I

Dear Dr. Murley:

Dear Dr. Murley:

Navigation menu

IR 05000277/1985098

Text

Enclosures:

REGION I

Dear Dr. Murley:

Dear Dr. Murley:

Navigation menu

Search