ML20214V454
| ML20214V454 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/05/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214V419 | List: |
| References | |
| 50-352-86-99, NUDOCS 8706120105 | |
| Download: ML20214V454 (62) | |
See also: IR 05000352/1986099
Text
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ENCLOSURE
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NO. 50-352/86-99
PHILADELPHIA ELECTRIC COMPANY
LIMERICK GENERATING STATION
UNIT 1
ASSESSMENT PERIOD: FEBRUARY 1, 1986 - JANUARY 31, 1987
BOARD MEETING DATE: MARCH 17, 1987
8706120105 870605 ~
PDR ADOCK 05000352
G PDR
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TABLE OF CONTENTS
Page
I. INTRODUCTION ...... ................. 1
A. Purpose and Overview . . . . . ............ 1
B. SALP Board Members . . . . . . . . . . . . . . . . . . 1
C. Background . . . . . . . . . . . . . . . . . . . . . . 2
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II. CRITERIA . .. . .... ................. 5
III. SUMMARY OF RESULTS .. ........ ......... 6
A. Facility Performance . . . . . . ........... 6
B. Overall Facility Evaluation ............. 6
IV. PERFORMANCE ANALYSES. . . . . . . . . . . . . . . . . . . . 8
A. Plant Operations . . . . . . . . . . . ....... 8
B. Radiological Controls ................ 12
C. Maintenance ... .................. 17
D. Surveillance . . . . . . . . . . . . . ........ 21
E. Engineering Support. ................ 25
F. Emergency Preparednesss ............... 28
G. Security and Safeguards ............... 30
H. Training and Qualification Effectivenesss ...... 34
I. Licensing Activities . . . ............. 37
J. Assurance of Quality ................ 41
V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . 44
A. Investigation and Allegation Review ......... 44
B. Escalated Enforcement Actions ............ 44
C. Management Conferences . . . . . . . . ....... 44
D. Licensee Event Reports . . . . . ........... 45
E. Licensing Activities . . . . . . . . . . . . . . . . . 47
Tables and Figures
Table 1 - Licensee Event Reports .................. 48
Table 2 - Inspection Hours Summary ................. 54
Table 3 - Enforcement Summary . ................... 55
Table 4 - Inspection Activities . . .. ............. 57
Table 5 - Unplanned Automatic Trips and Shutdowns . . ........ 59
Figure 1 - Number of Days Shutdown ................. 60
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I. INTRODUCTION
A. Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an
integrated NRC staff effort to collect the available observations and
data on a periodic basis and to evaluate licensee performance based
upon this information. SALP is supplemental to normal regulatory
processes used to ensure compliance to NRC rules and regulations.
SALP is intended to be sufficiently diagnostic to provide a rational
basis for allocating NRC resources and to provide meaningful guidance
to the licensee's management to promote quality and safety of plant
construction and operation.
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An NRC SALP Board, composed of the staff members listed below, met
on March 17, 1987 to review the collection of performance observa-
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tions and data to assess the licensee performance in accordance
with the guidance in NRC Manual Chapter 0516, " Systematic Assessment
of Licensee Performance." A summary of the guidance and evaluation
criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Limerick Generating Station Unit i for the
period February 1,1986 through January 31, 1987. The summary
findings and totals reflect a 12-month assessment period.
B. SALP Board
Board Chairman '
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W. F. Kane, Director, Division of Reactor Projects (DRP), ,
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Members
i L. H. Bettenhausen, Acting Director, Division of Reactor Safety
! (DRS)
i R. M. Gallo, Chief, Projects Branch 2, DRP
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C. J. Cowgill, Acting Chief, Reactor Projects Section 2A
J. R. Johnson, Acting Chief, Operations Branch, DRS
M. Shanbaky, Acting Chief, Emergency Preparedness and Radiological -
Protection Branch, DRSS
E. M. Kelly, Senior Resident Inspector
W. R. Butler, Chief, BWR Project Directorate No. 4
R. E. Martin, Licensing Project Manager, NRR
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Other Attendees'
S. D. Kucharski, Resident Inspector
J. H. Williams, Project Engineer.
L. Scholl, Reactor Engineer
F. Hebdon, AE00
R. Bailey, Physical Security Inspector
R. Keimig, Chief, Safeguards Section
W. Pasciak, Chief, Effluent Radiation Protection Section
T. Dragoun, Senior Radiation Specialist
J. Sweeney, Consultant
C. Background
1. Licensee Activities
The startup test program was completed, and commercial operation
was declared on February 1,1986, following performance of the
100-hour warranty run on January 23-28, 1986. The plant oper-
ated at full rated power through most of the assessment period
at a capacity factor of approximately 82%.
The one unplanned scram from power during the period occurred
on February 10, 1986'from 99.8% power on a high flux signal.
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The high flux was the result of a pressure increase from tur-
bine control valve closure due to a momentary ground created
in the main turbine presture control system by a test engineer
who had been collecting turbine operating data. Following
reactor startup on February 11, the plant operated at full
rated power through May 2, 1986. A planned shutdown was
commenced on May 2, 1986, and a six-week scheduled outage
l was begun to perform surveillance testing. An unplanned
scram signal on low reactor vessel level occurred during the
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subsequent cooldown (with manual level control using a single
i- feedwater pump) with all rods already inserted. The outage
l was completed within the scheduled time frame,.and major work
included replacement of all 14 main steam safety valves, over-
, haul of all 4 emergency diesels, and extensive surveillance
' testing. ,
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i Tbe plant aphieved full rated power operation on June 21, 1986
and operated until July 4, 1986 when the plant was shut down
, dde to an iicrease in unidentified drywell leakage. In
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ad;11 tion to= replacing LPCI valve packing, a recirculation pump
i seal was replaced and on July 13 the plant returned to full
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power operaflon.
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Full power operation continued from July 1986 for a record 198
days until a controlled shutdown was begun on January 27, 1987
and a manual scram from 27% power was performed to repair
three valves found later to be contributing to the high
unidentified drywell leakage.
Plant load drops from full power were performed on several
occasions at the end of the assessment period. Control rod
pattern changes for the remaining rod groups still inserted in
the core were made to extend core life. End-of-cycle coastdown
began at the end of the period, as target burnup was reached and
all control rods were fully withdrawn. New fuel arrived onsite
on January 21-23, 1987. A license amendment to extend core life
by allowing increased core flow and partial feedwater heating
was submitted to the NRC on November 16, 1986 and was approved
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shortly following the end of the assessment period.
Detailed preplanning was undertaken during the assessment
period in preparation for the initial refueling scheduled to
last 11 weeks and expected to begin in May 1987. The refueling
will involve a full core offload, approximately 80 system modi-
fications, and extensive testing and maintenance activities.
Organizational changes at the station level occurred through-
out the assessment period, including promotion of a new station
manager in April 1986. The licensee announced changes in
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November 1986 in PECO senior management associated with nuclear
programs. The Senior Vice President for Nuclear Power and the
Vice President (VP) for Electric Production retired, and J. S.
Kemper was appointed to a new position of Senior VP with three
new VPs reporting to him, effective on November 24, 1986.
Annual emergency preparedness exercises were held on April 3,
1986 and January 15, 1987.
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Startup commenced on January 30, 1987 after being shut down
for 4 days to repair valve packing leaks, and power ascension
! to rated conditions was underway at the end of the assessment
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period.
2. Inspection Activities
Two NRC resident inspectors were assigned to the site during
the assessment period. The total NRC inspection hours for the
12 month assessment period was 2781 hours0.0322 days <br />0.773 hours <br />0.0046 weeks <br />0.00106 months <br />. Distribution of
these hours for each functional area is depicted in Table 2.
During this assessment period, the first year of commercial
operations was covered. NRC teams evaluated two emergency
preparedness exercises, conducted on April 3, 1986 and January
15, 1987.
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A summary of enforcement activities is provided in Table 3,
followed by inspection activities in Table 4.
This report also includes assessment of " Training and Qualifi- *
cation Effectiveness" and " Assurance of Quality" as separate
functional areas. Although these topics are assessed in other
functional areas through their use as evaluation criteria, these
two areas are summarized separately to provide a synopsis. For
example, quality assurance effectiveness was assessed on a
day-to-day basis by the resident inspector and as an integral
part of specialist inspections. Although quality work is the
responsibility of every employee, one of the management tools
to measure this effectiveness is reliance on quality assurance
inspections and audits, Other major factors that influence
quality, such as involvement of first-line supervision, safety
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committees, and worker attitudes, are discussed in each func-
tional area.
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Engineering support was evaluated as a separate functional
area for the first time during this assessment period. Fire
Protection is assessed as part of Operations, as in the last
assessment, since there was only one programmatic inspection
in this area. Security continued to receive increased inspec-
tion effort, as in the previous period,.because of identified
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weaknesses.
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II. CRITERIA
Licensee performance is assessed in selected functional areas. Each
functional area represents areas significant to nuclear safety and the
environment, and are normal programmatic areas. The following evaluation
criteria were used as appropriate to assess each functional area.
1. Management involvement and control in assuring quality
2. Approach to resolution of technical issues from a safety standpoint
3. Responsiveness to NRC initiatives
4. Enforcement history
5. Reporting and analysis of operational events.
6. Staffing (including management)
7. Training effectiveness and qualification
Based upon the SALP Board assessment each functional area evaluated is
classified into one of these performance categories. The definitions of
these performance categories are:
Category 1. Reduced NRC attention may be appropriate. Licensee manage-
ment attention and involvement are aggressive and oriented toward nuclear
safety; licensee resources are ample and effectively used so that a high
level of performance with respect to operational safety is being achieved.
Category 2. NRC attention should be maintained at normal levels. Licen-
see management attention and involvement are evident and concerned with
nuclear safety; licensee resources are adequate and reasonably effective
such that satisfactory performance with respect to operational safety is
being achieved.
Category 3. Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear
safety, but weaknesses are evident; licensee resources appear strained or
not effectively used so that minimally satisfactory performance with
respect to operational safety is being achieved.
The SALP Board has also categorized the performance trend over the
course of the SALP assessment period. The SALP trend categories are:
Improving: Licensee performance was determined to be improving near the
close of the assessment period.
Declining: Licensee performance was determined to be declining near the
close of the assessment period.
A trend is assigned only when a definite trend of performance is
discernible, and the SALP Board believes that continuation of the trend
may result in a change of performance level.
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III. SUMMARY OF RESULTS
A. Facility Performance
Functional Category Category
Area Last Period This Period
(12/1/84 - 1/31/86) (2/1/86 - 1/31/87)
A. Plant
Operations 1 1
B. Radiological
Controls 2 1
C. Maintenance 2 1
D. Surveillance 2 1
Not
E. Engineering Support Evaluated 1
F. Emergency
Preparedness 1 1
G. Security and
Safeguards 3 2
H. Training & Quali-
fication Effective-
ness 2 1
I. Licensing Activities 1 2
J. Assurance of Quality 1 1
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B. Overall Facility Evaluation
The SALP Board assessment confirmed a strong orientation toward
safe plant operation and found significant management, staffing, and
performance strengths in plant operations, maintenance, surveillance,
and emergency preparedness. Other functional areas, while rated
Category 1 on the strength of performance during the period, were
found to be so because of strong station management. Radiological
controls and engineering support are examples of functional areas
where strong corporate support will be necessary to sustain Category
1 performance. In most functional areas the licensee exhibited an
ability to predict problems by taking a proactive approach to
critically self-evaluate performance and institute effective
corrective actions to prevent problems from occurring.
Control room activities were observed to be at a consistently high
quality level. The conduct of business in the control room was
professional and improved over previous assessments. Operator
attitudes toward plant safety and cooperation with the NRC were
excellent.
Security exhibited poor performance in past assessments, necessi-
tating many program changes during the current assessment period.
Program improvements included increased oversight and direction of
the security contract force, as well as increased licensee manage-
ment involvement and enhanced training program enhancements. These
changes indicate to us the licensee's intent to develop and implement
a high quality security program. However, many of the changes
occurred late in the assessment period and their effectiveness has
not yet been assessed. Therefore, high management attention to the
program must continue to ensure that this level of effort is maintained.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations (974 hours0.0113 days <br />0.271 hours <br />0.00161 weeks <br />3.70607e-4 months <br />; 35%)
1. Analysis
This area was rated as Category 1 during the previous assess-
ment period, concluding that staffing was at full complement,
control room activities were fully supported by technical
, personnel and strong management involvement, with demonstrated
ability to implement effective corrective action and perform
critical self evaluations. Areas needing improvement were
coordination between operators, on-shift communication, and an
increased recognition of Technical Specification requirements
under changing plant conditions. Operator license examination
failures during the previous period also reflected a recurrent
weakness in supervising refueling operations.
Plant operations and activities were monitored by the resi-
dent and region-based inspectors during this assessment period.
Station management continues to be visible in control room
activities, particularly during major plant evolutions. Technical
specifications and license conditions have been adhered to
consistently. Operators are cognizant of safety system status,
alarmed conditions, and equipment problems. Shift supervision
has responded with conservative decisions on operability when
, equipment problems arise.
There were two unplanned scrams during the assessment period.
The only scram from power occurred at the beginning of the
assessment period due to data collection that was not adequately
controlled, and has not been a recurrent problem. The second
scram occurred due to reactor vessel water level oscillations
with all rods inserted and the reactor in a shutdown condition.
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In contrast, nine unplanned scrams occurred during the last
assessment period. The licensee is an active member of the BWR
Owners Group Scram Frequency Reduction Committee that convenes
quarterly to discuss root causes of scrams and successful
preventive measures. Good practices recommended or already
implemented at Limerick include: head sets for communication
between I&C technicians, test engineers and operators during
surveillances; adjustment of the main steam line high radiation
setpoint; protective cages around instrumentation racks and
reduction in the number of continuously lighted control room
annunciators. The result has been a marked reduction in
unplanned scrams.
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Control room routines were maintained at a high level. New
access controls were instituted during the period that were
effective in limiting non-essential personnel and noise, and
improved the conduct of business in the control room to correct
a chronic past problem. Improved access controls were notable
since Unit 2 control panels were under construction during the
last half of the period. Operator performance reflected high
morale and a cooperative attitude. Formalized shift turnover
procedures were implemented during the assessment period, and
turnovers have been crisp and professional. Operators have
found plant problems because of attention to detail in turn-
overs, such as a reactor water cleanup pump which had tripped
but was not annunciated, and a self-identified violation
involving chilled water isolation valves that had not been
properly isolated.
The plant operating review committee (PORC) has continued to
effectively keep safe plant operation as the highest priority,
and plant management regularly convenes the PORC when signifi-
cant issues arise. The closeout of the startup test program was
carried out with the same high quality as the conduct of the
program rated as Category 1 in the previous assessment. Staf-
fing levels and a tracking method were maintained such that the
PORC was able to assure that open test exceptions carried into
the operational phase were closed out or periodically reviewed
for status with technically adequate action plans for each open
test exception.
Licensed operator staffing has been maintained at a high level
to support safe reactor operation. Staffing for both units is
essentially in place; this allows for extra licensed expertise
in the control room to better handle collateral duties such as
the fire brigade, equipment blocking and release for mainte-
nance, and startups and shutdowns. Less use of overtime
occurred as compared with the last assessment period when the
plant was in a power ascension test program. Plant management
communicates effectively with shift supervision and control
room staff through daily meetings, as well as an end of the
week planning session for weekend activities. Shift technical
advisors (STAS) determine the scope of appropriate post
maintenance testing; and assist in event reportability, recon-
struction and emergency response. A new position of technical
assistant on shift (TAOS) was created at the end of the period
to allow the STA to remain in the control room with the shift
superintendent. The TAOS has assumed computer display and
offsite dose calculation responsibilities.
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Licensed training programs were accredited by INP0 in October
1986. One set of license examinations was given during the
, current assessment period; a total of 4 senior reactor opera-
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tors, three reactor operator candidates and an instructor
certification were examined, and all pass,ed
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Fire protection was assessed as part of resident inspections
and one inspection by a region based fire protection specialist.
Deficiencies from the previous assessment for brigade members
who missed quarterly meetings and semi annual drills were
resolved by training makeup sessions. However, licensee manage-
ment does not appear to be thoroughly involved in activities
affecting the quality of the fire protection program, as evi-
i denced by the relatively large number of licensee event reports
(LERs) in this area and in particular the number of LERs issued
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because of degraded fire barriers. It appears that, with proper
training and increased management involvement, some of the fire
protection related events could have been avoided. Additional
management attention is warranted in staffing, since the Fire
Protection Assistant position (left vacant a year ago) has not
1 been permanently filled. The position has been temporarily
filled by a technician who does not have State certification as
a fire brigade instructor. Also, the corporate Fire Protection
Engineer rarely visits the plant to review the program, or more
importantly, to monitor Unit 2 construction activities as they
may affect Unit 1.
Marked improvements were made in reducing the number of
unnecessary control room annunciator alarms, with a daily
, average of five or less nuisance alarms by the end of the
assessment period. Green plastic covers are used to identify
expected alarming conditions, and other colored markings for
which heightened response via alarm response procedures is
i necessary. Operators were responsive to, knowledgeable of the
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cause of, and aggressively investigated equipment conditions
causing alarms.
! The licensee's performance is exemplary with respect to
! reportable events. Of the 50 prompt notification events
- reported under 10 CFR 50.72, all were correctly identified
{ and properly analyzed. The high percentage of licensee event
reports (LERs) resulting from follow-up of the 10 CFR 50.72
reports indicates a thorough and careful reporting policy.
- There also were few subsequent revisions of the LERs. None of
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the events reported was of unusual safety significance, and no
l events or problems specific to Limerick were considered
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significant. All of these considerations suggest that
corrective actions are effective.
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The plant was critical for 7365 hours0.0852 days <br />2.046 hours <br />0.0122 weeks <br />0.0028 months <br /> during the reporting
period and experienced an average of 0.14 unplanned scrams
with rod motion per 1000 critical hours. This scram frequency
indicates a well operated and maintained plant.
In summary, the quality of operations was evident throughout
the assessment period. A notable exception was fire protection
program activities, particularly barrier control, staffing and
corporate involvement. The number of reportable events
attributable to operator error was significantly reduced, and
the overall scram rate was extremely low.
2. Conclusion
1
Category 1
3. Board Recommendations
None,
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B. Radiological Controls (301 hours0.00348 days <br />0.0836 hours <br />4.976852e-4 weeks <br />1.145305e-4 months <br />; 10.8%)
1. Analysis
Overview
In the previous assessment period this area was rated as
Category 2. One minor weakness had been noted regarding
ineffective communication of h"alth physics (HP) control
requirements to the work groups. This weakness has been
recognized by the consistent efforts of the HP group to
improve communications at all levels, including timely
issuance of event reports for radiological incidents.
During this period there were several months of full power
operation and a 6-week outage which provided the opportunity
to assess the radiological controls program under other than
routine operational conditions. A total of six specialist
inspections were performed: two in radiation protection; two
in radwaste management and environmental monitoring; and two
in chemistry controls.
Radiation Protection
Low plant radiation levels and the lack of significant
contamination have allowed station management and HP super-
vision to focus attention on the nore hazardous work such
as neutron dete.ctor and recircula. ion pump seal replacements,
resulting in excellent control of work and low personnel
exposures. Total 1986 station exposure was approximately 70
man-rem, within the site management goal, due in part to the
onsite Senior Health Physicist who has been aggressive in
seeking cooperation and support from other site departments.
The HP department is fully staffed with permanent, qualified,
and dedicated personnel. A new director of corporate programs
was appointed at the end of the assessment period. Contract
personnel play major roles in the respiratory protection and
general employee training programs. No negative impact on the
quality of these programs has been noted due to good licensee
oversight of and qualification programs for the contract
personnel.
Corporate support was not evident in plant radiological control
activities, and is clearly lacking in programs to maintain per-
sonnel exposure levels as-low-as-reasonably-achievable (ALARA).
This issue is discussed further in Section IV.J, Assurance of
Quality. Regarding the ALARA program, there are no corporate
implementing procedures, as well as a lack of formal partici-
pation (from a site focus on work packages) by the Engineering
and Maintenance Departments. ALARA goals set by the site HP
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group are achievable and establish a level of excellence;
however, these goals do not receive formal corporate sanction
or involvement. HP procedures assign responsibility to the
site ALARA group to revise modifications to incorporate ALARA
considerations. However, the site HP ALARA group is unquali-
fied and undermanned for this task which is more appropriately
a responsibility of licensee corporate engineering departments.
Nonetheless, the oversight of plant activities by onsite ALARA
engineers and HP has been excellent.
Outaga work was effectively controlled due to clear and well
stated radiation work procedures, and the use of experienced
lead HP technicians and similarly experienced work crews.
Although radiological hazards are generally low, the tech-
nicians in charge of work took conservative precautions to
prevent workers from becoming lax in regard to radiation
protection. An overall positive attitude across all site
work groups has been reflected by their adherence to routine
HP controls. Sensitive automatic personnel friskers installed
at the power block main access passageway provide control of
very low levels of radioactive materials. However, the excel-
lent control afforded by this equipment is complicated by the
abnormally high level of naturally occurring radioactive
material (radon) found in the geographic area of the site.
There was a concern identified by the NRC during the May 1986
outage that heat stress of the workers, with primary containment
spot coolers secured, might compromise radiological controls.
The licensee responded with a comprehensive heat stress control
program expected to be administered during the 1987 refueling
outage.
The respiratory protection program reflects a conservative
approach to the control of intakes by workers with good proce-
dures and a sizeable force of well-trained contractors.
A well organized training program continues to make a positive
contribution to the effectiveness of the HP program. General
employee training and respiratory protection instructors must
complete a rigorous qualification program. The content and
presentation of training for workers is tightly controlled by
the corporate Nuclear Training Manual.
Audit programs appear to be effective in identification of
program weaknesses. Several problems with the control of high
radiation exclusion areas found during an NRC inspection had
been identified by the licensee one month earlier, and were
appropriately corrected by the end of the assessment period.
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Radioactive Waste Management and Environmental Monitoring
Program controls in processing and classification of radwaste
were well managed. Significant organizational improvements
were instituted at the end of the assessment period, including
a change to a separate line organization from the previous
matrix organization. A Radwaste Manual was' developed to
describe the conduct of operations, position responsibilities
and program requirements. Management directed oversight /
approval of all radwaste discharges, review of performance
indicators associated with the water balance program, and a
published goal / commitment to become a "zero-release" (i.e.,
no radioactive liquid discharges) plant. Staffing was complete,-
with minimal reliance on contractor personnel. The non-licensed
operator training program, which applies to radwaste operators,
received INP0 accreditation during this assessment period.
Technical support was also in place to identify radwaste equip-
ment problems, establish unique priorities for work requests and
identify equipment improvements. Continued radwaste program
improvements to minimize dry active waste include plans for a
super-compaction facility shared between the Peach Bottom and
Limerick stations.
An inspection of the licensee's radiological environmental
monitoring found consistent application of the program. Quality
assurance of the environmental thermoluminescent dosimetry (TLD)
-measurements is supported by two well-recognized comparison
programs. No administrative offsite dose limits were approached,
and radioactive waste shipments have been in compliance with the
state requirements of South Carolina and Washington.
Chemistry Controls
The licensee has developed and is implementing a site-specific
water chemistry control program which follows EPRI and industry
consensus standards. The onsite effort represents a significant
improvement in resin controls, limiting chlorides, better trend-
ing of solids and conductivity, and overall water quality since
the last assessment. Review of plant chemistry performance and
trends is routinely performed by station management.
Technical support to the station for resolution of post
accident sampling system (PASS) reliability was not coordinated
until identified and highlighted by the NRC. The licensee had
not been able to satisfactorily complete surveillance tests to
demonstrate PASS operation throughout the assessment period due
to recurring component failures. By the end of the assessment
period, licensee management directed the appropriate resources
and had developed a thorough corrective action plan, including
completing the surveillances and initiating system modifications,
f
.
.
15
The licensee's capability to analyze non radiological chemical
parameters in various plant systems was reviewed. The results
of the standard measurements comparison showed six out of four-
teen disagreements. The disagreements occurred in the metal
analysis area and were caused by poor attention to calibration
and a lack of appropriate measurement control charts. Another
problem was related to the licensee setting an arbitrary ten-
percent control value rather than a statistically useful con-
trol value. The problem of control charts was identified in
an inspection during the previous assessment period. These
problems could have been avoided with more attention to quality
control details at the site or with better corporate involve-
ment, in addition to a more timely followup of identified
problems.
Personnel performance in chemistry was very good, even with
roughly half of the licensee's staff (at the Support Chemist
and ANSI technician level) as contractors. The licensee
received INP0 accreditation for their chemistry training
program. Permar.ent (licensee) chemistry staffing is nearing
final goals and should improve upon completion of the required
training and qualification. QA surveillances at the beginning
of the assessment period identified significant weaknesses in
the plant chemical control programs which have been
subsequently strengthened.
Summary
Low radiation and contamination levels have allowed management
focus on and excellent control of radiological work, resulting
in low personnel exposures. Effective qualification and train-
ing programs have allowed for good oversight of contractors and
positive attitudes among site work groups with respect to HP
controls. While audit programs are identifying some program
weaknesses, appropriate corporate support and involvement with
radiological and ALARA programs was not evident. Moreover, site
radiological controls and ALARA oversight were effective, in
spite of the absence of corporate sanctions, because of strong
- station HP group management.
!
i
Radwaste program improvements continued to be implemented
throughout the assessment period, as were chemistry practices,
although increased corporate direction or assistance in those
, areas was warranted by virtue of problems experienced with
4
laboratory QC and PASS reliability.
!
l
I
i
b.
_ _ _ _ _ _ _ _ _ __ _ _
,.
.
-
16
2. Conclusion
Category 1
3. Board Recommendations
Licensee: See Section IV.J, Assurance of Quality
NRC: Continue the routine inspection program, considering
expected increased challenges associated with the 1987 refueling
outage.
. . . . . . . . . . __--
.
-
17
C. Maintenance (362 hours0.00419 days <br />0.101 hours <br />5.98545e-4 weeks <br />1.37741e-4 months <br />; 13%)
1. Analysis
This area was rated Category 2 during the last assessment
period. No concerns were identified during that assessment,
and, overall, maintenance programs were judged to be function-
ing well.
The resident inspectors reviewed routine plant maintenance
during the present assessment, and there was one programmatic
inspection by a region-based specialist. Mainter;ince activi-
ties were more extensive than in the previous period, as craft
supported two outages; one a six week surveillance test outage
and the other a one-week recirculation pump seal and packing
replacement outage.
Careful and well-controlled maintenance programs have resulted
in quality work during the assessment period. Program chal-
1enges have been met by maintenance personnel as indicated
by a lack of equipment deficiencies and excellent plant reli-
ability and availability. There were no scrams attributable
to this area, nor was there a backlog of safety related
corrective maintenance. No examples occurred of recurrent
failures involving rework or excessively drawn-out job
schedules. Maintenance supervision demonstrated effective
work planning, responded capably to contingencies, and main-
tained an adequately staffed craft organization.
Maintenance was well-managed during the assessment period.
Maintenance craft accumulate the largest percentage of the
station's radiation exposure, and thus ALARA is a principal
goal within the Maintenance Division. The ALARA goal was
ambitiously set and slightly exceeded due, in part, to a
large number of unanticipated reactor water cleanup system
pump repairs. However, a vendor representative was consulted
and, by eventually improving operating and maintenance proce-
dures, no additional pump seal failures were experienced during
the last quarter of the assessment period. Other targeted
management goals included minimizing the use of contractors and
eliminating excessive craft overtime. A new onsite maintenance
supervisor was appointed at the end of the assessment period
who has applied valuable quality control (QC) and maintenance
experience to that position.
Significant demands for maintenance were met during the assess-
ment period as evidenced by performance during the six-week
mint-outage and major equipment repairs, including: the
replacement of a recirculation pump seal, the replacement of
all 14 main steam safety relief valves; the overhaul of all
four emergency diesel generator engines; and, rework of
.___-_________ _ _ _ _
.
-
18
feedwater check valves and the main steam isolation valves
(MSIV's). Generic information was factored into maintenance
programs to promptly surface safety concerns, and effective
vendor interface controls were evident in these major repairs.
Maintenance work has been extensive during the assessment
period. Over 3500 preventive and corrective maintenance
activities were completed, and with essentially no backlog of
outstanding safety related corrective maintenance. Work is
centered about a computerized program for history and mainte-
nance planning (CHAMPS) that is also used to track maintenance,
equipment history, failure trends, and scheduling of resources.
A computer generated maintenance request form (MRF) has proved
to be an efficient means of interfacing between plant staff,
quality control, maintenance planning, and operations. Routine
work is coordinated through a series of meetings during the day.
The meetings serve not only to effect proper interface among
organizations on site, but also improvements in scheduling and
maintenance craft morale. Work controls have been effective,
particularly with respect to post-job critiques and work
planning. Accurate appraisals of actual versus estimated job
hours have been provided through the use of CHAMPS. Job dur-
ation has been optimized by responsive health physics coverage,
turnover of equipment, and effective engineering support.
Accurate job planning has enabled effective utilization of craft
resources.
i
Maintenance Division senior management have extensive experience
in nuclear maintenance. The Division, which consists of over
1100 personnel, has doubled in size in the past six years and is
currently organized such that a significant mobile resour:e of
craft are available on short notice for maintenance contingen-
cies and outages. As of the end of the assessment period, site
maintenance was comprised of approximately 120 craft and 20
technical personnel. Competent maintenance engineering support
was evidenced by complex and difficult in place repairs to a
high pressure coolant injection (HPCI) isolation valve which
were technically well conceived. The licensee has also recog-
nized the need to plan for future growth within craft ranks by
the addition of 29 entry-level Helpers currently in an on-the-
job training progression.
Well-developed maintenance procedures have been prepared using a
unique procedure writer's guideline. Maintenance procedures
have been found to be sufficiently detailed, particularly in
those cases of complex maintenance such as MSIV refurbishments,
diesel overhauls, and safety relief valve replacements. Lessons
learned have been factored into procedures based on plant
experience, such as the recirculation pump seal replacement and
control rod drive overhauls, as have Peach Bottom experiences.
The absence of any scrams attributable to maintenance activities
reflects, in part, carefully developed procedures.
. _- . ._. _ _ _ _ _ _ _ _ _ _ __ - - _ _ . - - _ - . _ _ - _ - -
_ _ _ _ _ _ _ _ _
.
4
-
19
3
i
i
Craft training programs were accredited by INPO during the
'
assessment period. Training initiatives'have included pur-
chase of a plastic recirculation pump seal training aid and
plans to purchase a spare MSIV. A dedicated training facility
!
' at Barbados Island (a decommissioned fossil station) is
equipped with Limitorque valves and other plant equipment for
"
hands-on training. The instructor to student ratio is excel-
lent, at approximately I to 4. Formal classroom and on-the-job
training are a part of a craftsman's progression to journeyman.
Specialty training has also been provided whert necessary, as
for example with refuel floor, snubber rebuilding, pump seals
and control rod drive work.
'
Housekeeping was maintained at a consistently high quality
level through persistent management attention, establishment
'
of administrative controls including a housekeeping committee,
!. and the effective use of a contract cleanup crew. As a result,
i
there existed few hazards to fire, equipment and personnel
safety during the assessment period. The licensee assured a
- continued level of good housekeeping, even with more difficult
i
conditions dictated by refueling outage preparations, by use
l of a plant area concept accountable within the maintenance
organization.
Quality audits and surveillances have given extensive coverage
4
to maintenance activities. QC is involved in all safety-related
, maintenance via the MRF processing system. Quality trending
j reports during this assessment have analyzed findings over a
3 two year period, assessing maintenance errors as a declining
, trend. The majority of quality findings in maintenance are
a
related to the control of heavy loads at Limerick, and manage-
ment accordingly initiated training to address the deficiencies.
t
! In summary, maintenance programs were challenged more fre-
, quently during the current assessment period, and proved to be
t
a strength as evidenced by a lack of equipment problems caused
- by maintenance, excellent plant reliability, and the lack of
, rework. Safety-related work was properly prioritized and
i planned. Efficient supervision of qualified craft resulted in
! effectively implemented procedures. No instances were identi- '
I fied where maintenance caused equipment or system inoperability.
Consistently good engineering support was evidenced by well-
- planned and executed major repairs. Control of the removal
j from and return to service of safety related systems (including
post-maintenance testing) was a consistent program strength,
i
'
l
!
- _ - - . .-
<
.
-
20
2. Conclusions
Category 1
3. Board Recommendations
None
.
.
21
D. Surveillance (429 hours0.00497 days <br />0.119 hours <br />7.093254e-4 weeks <br />1.632345e-4 months <br />; 15.4%)
1. Analysis
Surveillance was rated Category 2 during the previous
assessment. Concerns were expressed with management of
troubleshooting activities, controls on valve positions
and independent verifications.
Test programs were reviewed by resident and region-based
inspectors during the present assessment period. Specialist
inspections covered the surveillance test and calibration
control program, and containment local leak rate testing
during the six week May 1986 mini outage.
A well-managed surveillance test program was conducted during
the assessment period. This is evidenced by the 40% fewer
LERs than last assessment period, the fewer number of missed
surveillances, and the absence of emergency core cooling system
(ECCS) actuations and reactor scrams caused by testing. One
unplanned scram was caused by improperly controlled trouble-
shooting at the beginning of the period. Tighter management
controls on troubleshooting, including the requirement for a
troubleshooting control form approved by shift supervision,
prevented similar problems for the remainder of the period.
There were few unplanned actuations of safety systems
(9 reportable events or 16% of all LERs, principally inad-
vertent isolations) caused by test errors. Scheduling and
control of surveillance testing has been excellent and there
have been very few missed or late tests (of the 16,000 sur-
veillance tests run annually). Routine testing is scheduled
so as to minimize impact on plant operations. Complex testing
has also been rescheduled for dayshift during the week when
plant management is more immediately available should signifi-
cant problems arise.
The program has been successful in uncovering equipment prob-
lems, such as the residual heat removal (RHR) service water pump
flow blockage. Questionable test results receive proper super-
visory attention. Evaluation of test results and anomalies
have resulted in accurate identification of root cause, and the
licensee has made conservative decisions with regard to system
operability when test results were marginal.
The licensee maintains useful surveillance records enabling
effective trending of test results when equipment problems
were noted. Examples where test data were effectively
utilized included the reactor protection system (RPS) power
supply breakers and the containment purge system isolation
valves, both the subject of 10 CFR Part 21 reports during the
period. The licensee was also able to reconstruct accurate
s
..
. 22
,
~
test records to appraise potentially adverse trends on operation.
This was evident in an average power range monitor (APRM) noise
event involving an unexplained half-scram signal wherein a study
of past testing helped to confirm proper RPS response in spite
of seemingly anomalous results.
The licensee conducts thorough and effective testing of systems,
using procedures containing sound technical detail. Technicians
are well-trained and qualified, and good communications has been
established with licensed operators. Technicians have (in all
cases) suspended testing, and informed control room supervisicn
prior to resumption of testing, when erroneous system responses
have occurred. This practice has enabled prompt assessment of
root cause for equipment malfunctions and timely reconstruction
of sequences of events. In most reportable events during this
period involving test technician errors, the licensee's staff
comprehensively determined root cause, and this has been a
factor in reducing repetitive occurences and improving proce-
dural inadequacies. Test procedures are developed to the point
that, with improvements in human factors, incorporation of
vendor recommendations and embodied precautions, high confidence
in test procedures has been reached. The sub-PORC concept has
assured that procedures remain technically sound by better
attention to procedural detail on the part of responsible
engineers and work groups prior to presentation to the
full review committee.
There have been instances where communications between test
and control room personnel have led to violations (identified
by the licensee), but these have been corrected and have not
been recurrent. In response to one reportable event during
the assessment period, the licensee provided timers in the
control room that better administratively control the two-
hour limit associated with channel functional testing.
There have been fewer reportable events associated with test-
ing as compared with the last period, and the majority of these '
events have involved either fire protection or toxic gas detec-
tion systems. Reportable events in the fire protection area
were due to doors that were propped open and improperly con-
trolled, missing barriers and seals, and surveillances that
were missed due to poor communications. Moreover, there were
a relatively high number of reportable events (see causal anal-
ysis discussed in Section V.D.2.b) attributable to chlorine or
toxic gas detector design deficiencies. As a result, the
licensee has expended a considerable effort in maintaining these
state-of-the-art systems. New chlorine electrolyte probes were
installed at the beginning of the period to improve the reli-
ability of a previous system involving a tape which broke
frequently (and the source of numerous events). The licensee
continued to address toxic gas detector design problems at the
,
-
w
..
. 23
end of.the assessment period by increasing test surveillance
intervals and vendor / engineering involvement.
Previous problems associated with the temporary procedure con-
trol (TPC) process have been corrected. PORC review has been
effective in maintaining test procedure changes to a minimum.
Administrative processes to troubleshoot or to utilize TPCs,
when necessary, are not cumbersome and have also contributed to
procedure improvement. Previously experienced problems asso-
ciated with instrument valve manipulations have been eliminated
by the creation of a valving school and by restricting root
valve manipulations to instrumentation and control (I&C) tech-
nicians, as only one instance occurred curing the period in
which mispositioning an instrument root valve caused a report-
able event. The licensee also has substantial capability in
the area of performance data gathering and trend analysis, such
' as with the vibration monitoring program, chemistry database
, _
management system and emergency diesel engine testing.
The licensee reported a number of self-identified violations
involving testing. With the excaption of fire protection
barriers and doors, none of the test discrepancies were
repetitive or indicative of a larger breakdown and attest to
the licensee's continued ability to self-identify and correct
problems. An effective concept for correcting the cause of
test errors has been the use of roundtable discussions between
I&C technicians and engineers. For example, a drywell airlock
door leak rate test was six weeks overdue, but was discovered
because the licensee had not had a large backlog of overdue
surveillance tests and was adequately staffed to review test
schedules and find these isolated examples. A retest of the
airlock was promptly performed, scheduling program errors were
corrected, and the event was accurately reported. The licen-
see's program (STARS) for scheduling and. tracking surveillances
assists in assuring that tests are performed on schedule. The
coordination of the test program, across all disciplines, is
very strong due, in part, to the importance placed on the pro- '
gram by licensee personnel and the assignment of an engineer as
a dedicated surveillance test coordinator.
In summary, surveillance testing has been successful in reli-
ably confirming operability and uncovering equipment problems.
The program is extensive yet well centrolled, and personnel
are qualified and conservatively conduct testing. Staff and
shift supervision are appropriately involved, engineering eval-
uations are solicited when necessary, and staffing is adequate
to support test schedules. Testing is integrated into day-to-
day operations of the plant without unduly affecting reactor
operation. The relatively few instances of missed surveillances
are not a programmatic concern in an otherwise excellent test
program.
.
x
.
.-
24
2. Conclusion
Category 1
3. Board Recommendations
None
n'
'
.
. 25
E. Engineering Support (61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br />; 2.2%)
1. Analysis
This area has not been rated in previous assessments. During
this assessment period the resident and specialist inspectors
reviewed the plant modification and design change process, and '
assessed engineering support for plant operations, maintenance
activities, and the upcoming initial refueling outage. j
Corporate engineering and design support has been previously
noted to be strong, and the company is highly engineering-
oriented. Engineering issues have been effectively dealt with ,
during this assessment, such as safety relief valve setpoint I
drifts and safety evaluations to support continued plant oper- !
ation such as for the extension of the reactor core isolation
cooling (RCIC) system high energy line break boundary. One I
unplanned scram was attributed to a design limitation in
feedwater level control and, as a result, the licensee is
considering installation of additional startup level control
valves.
Plant modifications have been implemented throughout the
assessment period, with minimal impact on plant operations.
Detailed preplanning and design was performed for the large
number of modifications planned for the first refueling out-
age scheduled in May 1987. The most extensive modification
for the outage involves tie-in of the standby gas treatment
system to the refueling floor volume, a license condition
required to be implemented prior to moving irradiated fuel.
Over 85% of the modification was completed as of the end of
the assessment period, well in advance of the outage, and is
typical of design changes which are completed such that there
are more pre-engineered modification packages than there are
opportunities or staff to install them.
Major modifications are performed by an experienced onsite
Construction Division staff, consisting of approximately 65
permanently assigned craft personnel that are supplemented by
contractors to support outage activities. The construction
superintendent has been onsite at Limerick for 9 years and has
had previous experience at Peach Bottom. The group performs
extensive advance planning and utilizes the concept of a
Construction Job Memorandum to summarize work scope for field
personnel. The group has been successful in coordinating
among the licensee's matrixed organizations with minimal
impact on plant operations, and has as a goal to levelize
manpower during the upcoming refueling outage, accomplishing
as much work in advance as practicable. Walkdowns of systems,
and effective communications among work groups including daily
participation in planning (TRIPOD) meetings, have served to
-- - - . - . _ _ _ - -- . - _ _ - - -
.
.. 26
accomplish this goal. Design changes were implemented without
extending the critical path schedule during the May 1986 outage,
and have been practically integrated-into the projected schedule
for the refueling outage.
Safety evaluations associated with system changes are suf-
ficiently detailed, giving evidence of the strong corporate
engineering resources from which the licensee can draw for
design support. A Field Engineering group is also available
for electrical design and modifications. This group has con-
sistently provided expertise to solve safety system problems.
Examples included: various relay and logic problems; the
reactor protection system (RPS) power supply breakers that were
modified to more reliably open to protect the hydraulic control
unit scram solenoids; and, the average power range monitors
noise event that produced an unexplained half-scram signal and
detailed questions relating to proper RPS' response. This group
is also responsible for Limitorque motor-operated valve (MOVATS)
testing and troubleshooting, as well as reactor protection
system inverter operation and safety-related breaker design and
maintenance.
Engineering problems were experienced during the assessment
period as evidenced by Unit 1/2 interface contamination
incidents. The configuration of isolation devices in these
piping systems cross-connecting common unit systems were such
that internal contamination was allowed to migrate in several
instances to the radiologically uncontrolled Unit 2 side of
the piping systems. The licensee assembled a group to investi-
gate the short term and long term actions necessary to ensure
that Unit 1/2 interfaces are maintained isolated. Also, in
response to NRC concerns near the end of the assessment period,
corporate engineering developed a plan to address chronic PASS
reliability problems that had not been appropriately recognized
and brought to licensee management's attention.
There was a large number of LERs attributable to chlorine or
toxic gas detector design deficiencies, and the licensee has
.
expended considerable effort in these state-of-the-art systems.
l New chlorine electrolyte probes were installed at the beginning
of the period to improve the reliability of a previous system
j involving a tape which broke frequently (the source of numerous
LERs). The licensee continued to react to these design problems
- at the end of the assessment period by increasing vendor and
l engineering involvement.
'
An item of concern involved the generation of new computer- 1
l drafted process and instrument drawings (P& ids) which were found
l near the end of the assessment period to contain a substantial
number of errors. In response, the licensee undertook
immediate review of the drawings, red-lined copies in the
,
.
.
. 27
control room and emergency response facilities, and undertook a
program to permanently correct the drawings. No operational
safety problems were identified as a result of these drawing
errors. Engineering design controls and quality program effec-
tiveness were being reviewed by the licensee at the end of the
assessment period to preclude similar future errors.
As noted in the last SALP report, the Technical Engineering
group continues to be a valuable source of engineering knowledge
in the operation and test of plant systems. Further, the way in
which onsite programs are organized (i.e., the matrix organi-
zation) integrates engineers into all site activities. For
instance, the plant engineer-maintenance has a staff which
provides engineering support for Unit 1 maintenance. In
parallel, the Maintenance Division has a self-contained engi-
neering group. Both groups of engineers constitute a source
of engineering support for Unit 1 maintenance which is separate
and distinct from corporate design engineers. This is a typical
organizational structure of the licensee and is indicative of
strong engineering within the company.
The licensee updated the " Level 1" portion of the probabilistic
risk assessment (PRA) in September 1986, modifying system fault
trees to reflect as- built system designs and revising accident
sequence event trees to include: consideration of the emergency
operating procedures; an updated station battery life estimate;
and, a changed MSIV closure setpoint. The result of the update
was a reduction by a factor of 3 in the calculated core damage
frequency, and additional insights into initiating events. The
licensee plans to use the current PRA as an analytical tool for
cost / benefit analysis on design changes, evaluating changes to
the technical specifications, and providing a prioritization
method for an integrated living schedule for licensing actions.
In summary, the licensee is strongly oriented toward engineering
and has effective engineering support integral to all disci-
plines in addition to the historically strong corporate design
engineering function. Engineering activities of the assassment
period were escalated, particularly in the second half, as
extensive planning and implementation of modifications for the
first refueling outage were underway.
2. Conclusion
Category 1
3. Board Recommendations
,
None
,
!
.. _ . _ _ . _
i
.
.
28
1
1
F. Emergency Preparedness (326 hours0.00377 days <br />0.0906 hours <br />5.390212e-4 weeks <br />1.24043e-4 months <br />; 11.7%)
1. Analysis
Licensee performance in this area was rated as Category 1,
(consistent) during the previous assessment period based
principally upon support and guidance by the licensee's
corporate staff, as well as the licensee's own initiatives
During the current assessment period, there were three region-
based inspections that observed two emergency exercises and a
remedial medical drill.
Performance during the annual exercises has reflected success-
ful planning and management of emergency preparedness (EP),
and demonstrates the licensee's ability to respond. Response
personnel were knowledgeable in their duties and in use of
implementing procedures; an indication of an effective train-
ing program. In both exercises, the Emergency Director and
Emergency Coordinator provided conservative, decisive technical
support to operators in mitigation of degrading scenario events.
Decision-making by key licensee responders; effective command
and control of the emergency facilities and organization;
accurate protective measures for workers and protective action
recommendations for the public; and, timely notifications to
offsite authorities are all program strengths. Although minor
exercise deficiencies were identified, the licensee corrected '
these by providing additional training in areas in which
improvement was needed. Senior licensee staff and management
were present at both exercise critiques.
The Station Manager has emphasized training, cooperation, and
the importance given to emergency response. The corporate staff
provides strong direction for the program, supports scenario
development, and maintains current status on the state of off-
site preparedness. The site Planning Coordinator has effectively
maintained EP procedures and integrated changes into the EP
'
training program which have been identified through drills and
exercises. Implementing procedures have been improved based on
feedback from drill evaluations and this process has improved
the overall state of emergency preparedness at Limerick.
Emergency planners have successfully coordinated with all
matrix organizations, working towards solving problems such as
crowd control in the Operations Support Center (OSC) and radio
communications. A problem noted during the assessment period
involved coordination between corporate security and site
operations regarding the assessment of bomb threats and the
declaration of an unusual event. However, steps were in effect
at the end of the period to effectively resolve this issue with
,
.
.
29
all parties concerned. During a bomb threat that occurred in
December 1986, control room supervisors were knowledgeable of
emergency and security plan details, and decisive in initiating
searches and recognizing appropriate emergency action levels.
The dedicated emergency response facilities have been maintained
in an adequate state of readiness through the period. Communi-
cations and computer-based assessment equipment availability are
given a high priority. The licensee also conducts quarterly
training exercises, which has been reflected in the strong
leadership evident by senior staff participation in the
Emergency Director position.
In summary, the license has maintained a high state of emer-
gency preparedness. Personnel have displayed evidence of good
training, attitude, and dedication to this functon. Emergency
preparedness activities are well integrated in day-to-day plant
activities, and are part of the routine PORC agenda. Strong
corporate direction of the onsite programs and offsite functions
has resulted in a program which has matured over past assessment
periods.
2. Conclusion
Category 1
3. Board Recommendations
None
_ _ . .
.
. 30
G. Security and Safeguards (328 hours0.0038 days <br />0.0911 hours <br />5.42328e-4 weeks <br />1.24804e-4 months <br />; 11.8%)
1. Analysis:
During the previous SALP, Category 3 concerns were identified
for weak management oversight of contractor activities, and
a lack of willingness to address long-standing program
shortcomings. As a result of escalated enforcement at the
end of the previous period, the licensee initiated aggressive
actions during this SALP period to address those concerns and
to improve the program overall.
During this assessment period, three routine, unannounced
physical protection inspections were conducted by a regional-
based inspector. Routine resident inspections were performed
throughout the assessment period.
The licensee and the security force contractor have aggressively
pursued a planned course of action to identify the root causes
of their previously identified poor performance. To improve the
overall performance of the security organization, the licensee
developed and implemented several significant changes.
Senior corporate officials affirmed their support for and
intent to implement an effective security program at both of
its nuclear generating stations by initiating a reorganization
of corporate responsibilities. The Manager of Nuclear Support
was given the responsibility to establish a security organiza-
tion that would be headed by a Director. The role of the
Director of Nuclear Security was defined, and assigned respon-
sibility for the management and oversight of the PECO nuclear
security program. A technical analyst was assigned to assist
the Director.
In conjunction with this change, the licensee allocated large
capital expenditures and authorized eight shift security assis-
tant supervisor positions to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> oversight of the
contract security force, three of which were filled at the end
of the assessment period. The responsibilities of these super- ,
visors include assuring that the contractor properly implements
the licensee's security program and that the security force
maintains a high level of performance. In addition to the PECo
supervisors, the licensee's senior onsite security representa-
tive, the Nuclear Security Specialist, was also assigned a
staff of four technical assistants. These technical assistants
are responsible to monitor key aspects of the security program
on a day-to-day basis. The development and implementation of
this expanded PECo oversight organization, along with the
corporate changes, is evidence that the licensee is attempting
to implement a sound security program that goes beyond minimum
.
. 31
compliance with NRC requirements. However, these changes are
very recent, and, therefore, their impact on the program has
not yet been assessed by NRC.
Additionally, to instill in the security force personnel a
strong sense of purpose and a clear understanding of their
roles and responsibilities, the security force contractor made
changes to its supervisory staff, implemented numerous human
factors improvements and refined the training program.
To combat earlier problems of low morale and job dissatisfaction
in the security force, the contractor addressed employee con-
cerns regarding pay, benefits and human factors. Overtime hours
were substantially reduced and additional personnel were hired
to meet Unit 2 security duties previously assigned to members of
the Unit 1 security force. As a result of continued support of
the security program by the plant manager and other plant func-
tional groups, as well as the improvements made to the program,
the morale of security force personnel appears to have improved,
as demonstrated by a professional and dedicated demeanor.
The licensee also required its contractor to refine the train-
ing program. Two noteworthy refinements are the development
of a training program curriculum to define the purpose and
performance objectives of the program, and the initiation of
routine random testing of security force performance and
qualification criteria. The results appear to be effective,
as evidenced by the greater awareness of duties and a more
responsible attitude displayed by security force personnel.
The licensee's training program is carried out by individuals
who are experienced and assigned to security training only.
Training facilities have adequate classroom space. Lesson
plans are fairly well developed, generally thorough, and kept
current through feedback from supervisors and quality assurance,
and from the on-the-job performance testing. Random testing is
a significant program enhancement that has improved the perform-
ance and self-confidence of security force members. Security
procedures and instructions were recently revised to be more
clear and concise, which should enable members of the security
force to improve their performance.
Overall, the licensee, and its contractor appear to be addres-
sing the major security program shortcomings experienced in the
past. The licensee's efforts in this regard are significant but
management attention must continue at the current level.
Security management continued to be actively involved in
industry and NRC initiatives dealing with nuclear security
programs. This provides evidence of support for the secur-
ity program at a high level in the licensee's organization.
Management personnel also exhibited a clear understanding
..
.
32
and conservative approach to technical security issues as
evidenced by their handling of security matters that evolved
as a result of the resumption of Unit 2 construction. The
licensee's approach to resolution of those matters was
noteworthy. A very clear and comprehensive plan was devel-
oped, integrated with other plant functional and construction
groups and subsequently reviewed on-site with NRC representa-
tives before being implemented. This approach was extremely
effective in preventing numerous problems that are usually
encountered under such circumstances.
The licensee submitted four security event reports pursuant
to 10 CFR 73.71(c) during the assessment period. One report
concerned the misidentification of a vital area door; another
concerned a minor delay in response to an alarm because of a
miscommunication; the third identified the discovery of a
weapon during the search of a vehicle prior to entering ti.9
plant protected area; and the fourth reported a non-credible
bomb threat. In all cases, the licensee's compensatory
measures were timely and appropriate. The reports to NRC
were prompt, clear, and thorough. These reports have shown
considerable improvement during the assessment period.
Inspector reviews of the security incident files found that
the NRC-approved security plan was being properly implemented.
The lack of systems and equipment-related event reports during
this period is noteworthy, and evidence of increased licensee
attention to preventive maintenance and surveillance testing.
During the assessment period, the licensee submitted two
revisions to the Security Plan under the provisions of 10
CFR 50.54(p) and provided its response to the August 4,1986
Miscellaneous Amendments to 10 CFR 73.55 codified by the NRC.
The licensee's corporate security staff is responsible for
ensuring that Plans are current, and for coordinating changes
when required. The staff is very effective in carrying out
this responsibility. They often communicate and review Plan
changes with regional licensing personnel to ensure a clear
understanding and, when the Plan changes are submitted to NRC,
they are of good quality, indicative of a thorough review and
good understanding of NRC security performance objectives.
In summary, the licensee has implemented many program changes
and pursued many program improvements during this assessment
period. Increases in program oversight and direction, manage-
ment involvement and support, and enhancement in the training
program all served to demonstrate the licensee's desire to
develop and implement a high quality security program with a
well qualified and dedicated, professional force. However,
many of those changes occurred late in the period and the
effectiveness of the changes has not been assessed. Therefore,
-___ -_ - __ _ _ _ _ _ - _ _ - _ _ _ .
.
.
33
high level management attention to the program must continue
to ensure that the current level of effort to improve the
program is maintained.
2. Conclusions
Category 2
3. Board Recommendations
Licensee: Continue to evaluate the effectiveness and impact
of security program changes.
NRC: Maintain existing inspection effort.
I
i
_ . _
_ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
. 34
H. Training and Qualification Effectiveness
1. Analysis
The various aspects of this functional area have been considered
and discussed as an integral part of the other functional areas
and the respective inspection hours have been included.in each
one. Consequently, this discussion is a synopsis of the assess-
ments related to training conducted in other areas. Training
effectiveness has been measured primarily by the observed per-
formance of licensee personnel and, to a lesser degree, as a
review of program adequacy. This discussion addresses three
principal areas: licensed operator training, non-licensed
staff training, and the status of INP0 training accreditation.
,
During the previous assessment period, training and qualifi-
l cations effectiveness was considered as a separate functional
area for the first time and rated Category 2. Training and
qualification effectiveness continues to be an evaluation
criterion for each functional area. The previous assessment
recommended refresher training in refueling operations and
core alterations in preparation for the first refueling outage,
as well as increased emphasis on Technical Specifications for
licensed personnel. The current assessment is based on resident
I
and specialist observations as well as two specific inspections
of nonlicensed and maintenance training programs.
Fire protection training was assessed as part of one inspection
by a region based fire protection specialist. Deficiencies from
the previous assessment for brigade members who missed quarterly
meetings and semi annual drills were resolved by training makeup
sessions. However, licensee management does not appear to be
thoroughly involved in activities affecting the quality of the
fire protection program, as evidenced by the relatively large
number of licensee event reports (LERs) in this area and in
particular the number of LERs issued because of degraded
barriers. It appears that, with proper training and increased
management involvement, some of the events could have been
avoided.
During the current assessment period license examinations were
given to four senior reactor operator (SRO) candidates, three
reactor operator (RO) candidates and an instructor certifica-
tion, which all passed. Emergency procedure use continued to be
a licensee strength, as was knowledge of specific systems in
written exams. Knowledge of technical specifications was also a
notable strength which is an improvement from last year. One
generic weakness observed during the conduct of the exams was ,
difficulty in the location of control room indications (not )
currently installed on the simulator) during oral exams.
Simulator upgrades, which include a better panel mimic of
.
- - - - - - _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _
, .-_ _ _ _ _ _ _ _ _ _ _ -
.
. 35
l
isolation logic and setpoints, process monitors, and a complete
remote shutdown panel, are scheduled to be completed by October
1988. Other weaknesses identified in individual exams included
SR0 ability to predict automatic depressurization system response
when blowdown was in progress and suppression pool temperature
limits as related to net positive suction head for emergency
core cooling system pumps. Reactor operator weaknesses involved
correlating reactor vessel level with intermediate range neutron
monitor detector response, and power response during a loss of
feedwater transient. Internal coordination of license appli-
cations has significantly improved due to centralized corporate
oversight.
The effectiveness of plant operator and test technician train- 1
ing programs was reflected in the absence of reactor scrams
and the low number of safety system actuations attributable to
those groups. I&C technicians are well-trained and qualified,
and good communications has been established with licensed
operators. Technicians have (in all cases) suspended testing,
and informed control' room supervision prior to resumption of
testing, when erroneous system responses have occurred. In most
reportable events during this period involving test technician
errors, the licensee's staff comprehensively determined root
cause, and this has been a factor in reducing repetitive
occurrences. An effective concept for correcting the cause of
test errors has been roundtable discussions between I&C tech-
nicians and engineers. For example, previous problems with
instrument valve manipulations have been corrected by the
creation of a valving school and by restricting root valve
manipulations to I&C technicians. Only one instance occurred
during the period in which mispositioning an instrument root
valve caused a reportable event.
The licensee reported 21 events attributable to personnel
- errors. However, with the exception of fire protection
barriers and doors, none were repetitive or indicative of
a larger breakdown and attest to the licensee's continued
ability to self-identify and correct problems.
A well-organized and controlled radiological training program
continues to make a positive contribution to the effectiveness
of the HP program. This is evident by the low station personnel
exposure history to date, and by the excellent attitude of all
site work groups adhering to HP controls. Instructors involved
in general employee training and respiratory protection training
must complete a rigorous qualification program. The content and
presentation of training for workers is tightly controlled by
the corporate Nuclear Training Manual.
t
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
. 36
Craft training programs were accredited by INPO during the
assessment period. The Limerick Training Center and Barbados
Training Center support the non-licensed training activities
very well. Contractor support is also_ enlisted for training.
Training initiatives have included purchase of a plastic
recirculation pump seal training aid and plans to purchase a
spare MSIV. The maintenance training facility at Barbados, a
decommissioned fossil station is equipped with Limitorque
valves, a spare reactor water cleanup pump, and other actual
plant equipment for hands-on training. Formal classroom and
on-the-job training are a part of a maintenance craftsman's
progression to the journeyman rate. Specialty training has
also been provided where necessary, as for example with refuel
floor activities, snubber rebuilding, pump seals and control
rod drive rebuilds.
In summary, management has promoted a positive attitude in all
areas toward the importance of training. The licensee achieved
INPO accreditation of all of its ten training programs on
Octooer 30, 1986, two months ahead of a self-imposed schedule
set during the previous assessment period.
2. Conclusion
Category 1
3. Board Recommendations:
None
.
!
!
,
. 37
I. Licensing Activities
1. Analysis
This area was rated as Category 1 during the previous assess-
ment period based on issues associated predominantly with
issuance of the full power license and completion of the
Startup Test Program. The previous assessment concluded that
management involvement was apparent and very productive, that
a high degree of licensee responsiveness was exhibited, that
corporate staffing levels were stable and that reportable event
frequencies had improved significantly. An area of potential
weakness was noted in the maintenance of oversight to ensure
that forthcoming scheduler requirements were recognized and
were responded to in a timely manner.
This assessment is based principally on the licensee's
performance in support of three amendments to the operating
license, the review of nine other technical issues and five
petitions concerning licensee actions submitted by intervenors
pursuant to 10 CFR 2.206.
The licensee has continued to demonstrate strengths in the
areas of its approach to problems from a safety standpoint,
the qualifications and level of staffing and in the declining
frequency of reportable events. However, several areas have
not experienced the highest level of performance. These areas
are: (1) the timeliness of licensee applications for NRC staff
action relative to the requested action date; (2) the provision
of adequate technical analyses to support the licensee's pro-
posed no significant hazards consideration (NSHC) determinations;
and, (3) the coordination of plant activities and communications
with the NRC staff.
Management involvement in assuring quality is apparent in the
areas of strength noted above. However, several weaknesses in
licensing activities have developed in the assessment period
which call for further management involvement. One of these
areas, which was also noted in the previous assessment, is the
timeliness of licensee applications for NRC staff action
relative to the requested action date. An apparent lack of
sufficient advance planning and preparation has resulted in the
majority of the requests for action being submitted only a short
time before the needed action date. This concern applies to
the subject of license amendment nos. 1, 2 and 3 and to the
amendment applications concerning the standby gas treatment
system service to the refueling floor and to the allowable
control room air inleakage rate. For example, two of these
issues were included in the initial operating license yet the
responsive license amendment application was submitted only a
few months prior to the needed action date. This concern was
.
. 38
discussed with the licensee in a meeting on October 1, 1986
wherein the staff emphasized the importance of submitting
applications, for which the need can be foreseen, in a timely
manner so that the necessary actions can be completed without
unduly impacting plant availability. The effort by the licensee
in this meeting to project the anticipated filing date for
requests for staff action and the date such action is needed is
commendable. However, three of the four items for which NRC
staff action was requested by a specific time experienced delays
in the projected filing date of two or more months. This area
will continue to be monitored by the staff and a more formalized
scheduling process may be explored if the present less formal
process remains unsatisfactory.
It should also be noted that, while some applications for
action have been untimely, the absence of any requests for
emergency changes to the technical specifications speaks
well of the licensee's past efforts to develop the technical
specifications and the licensee's practices in managing the
operation of the plant.
An additional area of weakness concerns the generalized nature
of the licensee's analyses in its initial proposals of no
significant hazards consideration (NSHC) determination. This
area was not very active in the previous assessment which
included only partial consideration of license amendment nos.
I and 2. However, the much greater degree of activity in this
assessment period, which included the remaining consideration
of amendment nos. I and 2 as well as seven other amendment
applications, indicates that an enhanced level of management
involvement over that apparent in the assessment period is
warranted. Most of the nine license amendment applications
considered in the rating period were initially inadequate in
their analysis of one or more of the three factors of 10 CFR
50.92. The deficiencies consisted of discussions which were
overly simplified and ambiguous to support the assertion that
each of the three factors were met, resulting in a more
extensive NRC staff effort to develop the NSHC Federal Register
notice which extends the time required to process applications.
This issue has been addressed by NRC Generic Letter 86-03, by
letters to the licensee dated May 20, 1986 and February 19,
1987, and in extensive discussions with the licensee's staff
including a meeting on October 1, 1986. The licensee's
performance appeared to be on a clearly improving trend at
the end of the rating period.
A high level of continuing management involvement is also
necessary to ensure that plant activities remain coordinated
with licensee corporate staff activities. Although not typical
of the Itcensee's performance, there was one issue in this area
'
..
. 39
which received attention during the assessment period. Spe-
cifically, this concerned the licensee amendment no. 1 Technical
Specification changes to permit an extension of the surveillance '
interval for instrumentation line excess flow check valves. The
extension permitted postponement of testing until an outage on
the basis that it was undesirable to conduct such testing during
power operations. However, the licensee later began testing
some of the valves before the commencement of the outage, seem-
ingly in at least partial conflict with the basis for the
request for the extension. The conflict appears to have been
due in part to a lack of good communications between plant
staff and corporate licensing personnel. The staff addressed
this issue in a letter dated August 5, 1986 to the licensee
noting that although the issue may not constitute a legal
violation, it represented a departure from the highest stand-
ards of communications expected from licensees. The staff
identified no further need for corrective action by the
licensee in response to this specific event and there have
been no similar recurrences during the assessment period.
A principal licensee strength is its approach to issues from
a safety standpoint. The licensee's proposals have been
technically sound, have reflected acceptable margins of safety
and have contained few errors in technical-information. This
strength was apparent in the application for revision of the
Technical Specification limits on feedwater temperature and
core flow, which was accompanied by a safety analysis that was
extensive in scope and systematic in its approach, and in the
SGTS fan capacity issue wherein the licensee recognized the need
for greater fan capacity and modified the design accordingly.
Strengths are apparent in the licensee's responsiveness in that
the channels of communication between the staff and the licensee
continue to be very effective. The licensee is very responsive
in arranging the appropriate resources for conferences and
meetings. A weakness is also apparent in this area in that the
problem of timely submittal of requests for staff action is one
which continues from the last assessment period and one which
has shown no improvement during this assessment period.
Changes have been adopted in the licensee's corporate organi-
zation, including the licensing staff that interfaces with NRR.
The corporate changes include bringing the Engineering and
Research, the Nuclear Operations and the Electric Production
groups under a single Senior Vice President. These changes
also include some reorganization at the plant staff level.
The licensee characterizes these changes as being in response
to a need to provide more responsive control, because of growth
and specialization and to bring the Peach Bottom and Limerick
plants under a common organization. The current licensing
staff for Unit 1 is gaining further licensing experience and
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
___
.
. 40
is increasing in effectiveness. The licensee's staff coordin-
ates an effective response to NRC requests for information.
There is a visible effort to improve effectiveness and all
communications are handled in a professional manner. Based on
the recent implementation of these changes there is an insuf-
ficient basis to conclude whether they will be effective in
alleviating the weakness noted above.
In summary, for the present assessment period, the licensee's
performance in the areas of technical responses to safety
issues, responsiveness to staff communications and staffing
levels cor.tinues at the high level previously experienced
while the frequence of reportable events has improved markedly.
However, the timeliness of submittals, the adequacy of NSHC
determinations, and the adequacy of corporate and plant staff
coordination on actions before the NRC staff need continuing
attention to improve the past level of performance or to main-
tain the improving trend achievec by te end of the assessment
period.
2. Conclusions
Rating: Category 2
3. Board Recommendations
NRC: Conduct a meeting with the licensee to discuss progress
in resolving the three areas of concern, namely the timeliness
of submittals, the adequacy of NSHC determinations and licensee
plant / corporate staff communications.
,
,
__ _ _ _ _ _ _ _ _ . - _ _ .
-- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _
.
.
41
J. Assurance of Quality
1. Analysis
Management involvement and control in assuring quality was
initially considered as a separate functional area in the
previous SALP, in addition to being one of the evaluation
criteria in the other functional areas. The previous
assessment rated this area as Category 1. This discussion
is a synopsis of the assessments relating to the assurance
of quality for activities in other functional areas. The
area was evaluated by both resident and region-based inspec-
tors and is based, in part, on one specific inspection of
QA/QC programs and Independent Safety Engineering Group
(ISEG) activities.
In assessing how the licensee assures quality, the SALP
Board has considered various attributes normally considered
key contributors to the assurance of quality. Among the
attributes considered are implementation of management goals,
planning and control of routine activities, worker enthusiasm
and attitudes, management involvement, staffing, and training.
Licensee management addresses these attributes in diverse
ways. An operational excellence program was institued during
the assessment period that, while formally completed, estab-
lished the desired attitude across all work groups to carefully
consider safety and qualit9, apply attention to detail, involve
supervision and critically self-evaluate. Those traits have
been evident in the attitudes and performance of personnel at
Limerick.
The Plant Operating Review Committee (PORC) was convened on
over 100 occasions during the assessment period, and has been
instrumental in maintaining safe reactor operation as a priority.
The group has clearly insisted on procedures, safety evaluations
in support of modifications, and well considered approaches to
solving station problems. A tracking system is used that
clearly assigns accountability to resolve open issues, such as
test exceptions remaining from the startup test program. The
group has consistently remanded items to their orginator when
less than expected quality was presented. The expectations
for quality in the many issues presented to the PORC have been
high.
As discussed in Section IV.A, the fire protection program war-
rants additional management attention with regard to staffing,
since the Fire Protection Assistant position (left vacant a
year ago) has not been permanently filled. The position has
been temporarily filled by a technician who does not have State
certification as a fire brigade instructor. Also, the corporate
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
. 42
Fire Protection Engineer rarely visits the plant to get a feel-
ing for the program, but more importantly to closely monitor
construction activities as they may present a fire hazard for
Unit 1.
Also, as discussed in Section IV.B, corporate support was not
evident in plant radiological control activities during the
period. An otherwise excellent corporate radiation protection
manual appears to be generally ignored at site and corporate
levels, and corporate involvement is clearly lacking in the
ALARA program. ALARA goals set by the site are achievable,
and establish a level of excellence; however, these goals
do not receive formal corporate sanction or involvement.
Nonetheless, the oversight of plant activities by onsite
ALARA engineers and HP has been excellent.
The Independent Safety Engineering Group (ISEG) has been
active in feeding back experience to operational practices,
while independently assessing significant potential problems.
A Nuclear Safety Section Supervisor chairs the licensee's i
Operational Experience Assessment Committee (0EAC) at monthly
'
meetings, and the scope of industry-wide experience reviewed
and the quality of OEAC recommendations is excellent. ISEG
investigations have provided valuable lessons learned, such
as tagging both ends of long leads associated with temporary
circuit alterations. The ISEG moderates the newly established
Plant Incident Review Committee, utilizing shift supervision
to successfully determine the root of operational problems
such as the drywell chilled water isolation valve violation.
The ISEG has studied reportable events, particularly in the
area of personnel error. In response to an LER at the end of
the assessment period, the ISEG is undertaking a review of
the use and replacement of fuses in safety related circuits.
Investigation of reportable events were thorough, and recom-
mendations made by ISEG were well received by licensee
management. The ISEG has also been involved with a study of
the reliability of the main feedwater system in concert with
corporate engineering, important in light of its role as a PRA
accident initiator. The ISEG is a contributor to quarterly
meetings of a BWR Owner's Group on scram reduction, and in
a new Human Performance Evaluation System (HPES) used to
evaluate causal factors in personnel errors and explore the
man-machine interface. The experience of ISEG members has
been diverse and useful. ,
QA/QC involvement in performing audits and surveillance has
helped to keep quality in the forefront of areas such as opera-
tions startup testing, maintenance, surveillance, non-licensed i
training and fire protection. A visible QA/QC organization is
evident. The personnel assigned to these areas were found to
.
. 43
be knowledgeable of the QA program as it is applied to opera-
tional activities such as maintenance and testing. QA/QC
groups include contract support personnel, and the licensee
has provided complete training for contractors prior to per-
forming their nev function to assure a smooth transition. QA
and QC have been utilized by licensee management to solve
various quality problems during the assessment period. These
problems have included control room communications breakdowns,
vendor access screening, the control of safeguards information
and security barrier breaches. At the end of the assessment
period the licensee was proposing more active involvement by
QC in monitoring test activities and performing independent
verifications.
Meetings were held onsite to discuss the licensee's use of
a Quality Assurance Trending and Tracking system (QATTS) as
discussed in the previous assessment period. QATTS findings
have been effectively presented to licensee senior management
who are aware of and have proposed measures to correct and
reduce observed trends. These include training initiatives,
procedural changes, and proposed design fixes. The QATTS is
being developed by the licensee into a useful management tool.
The licensee's Nuclear Review Board (NRB) was convened during
routine sessions and on a number of special occasions during the
assessment period to review the more significant and unantici-
pated safety problems. These included confirmation of expected
reactor protection system response during the APRM noise event,
and the review of significant nonconformance findings of quality
audits such as from vendor screening, chemistry control pro-
grams, and others. NRB recommendations have been undertaken by
Engineering and Production organizations. The NRB was restruc-
tured under a new chairman at the end of the assessment period.
,
In summary, the quality programs in effect at Limerick have
included QA/QC, the Nuclear Review Board and PORC committees,
the ISEG, and effective front-line supervision of all
disciplines. The quality programs have instituted a set of
checks and balances to prevent undetected errors, and their
overall result has been good personnel attitudes, few alle-
gations, evidence of quality workmanship and a substantially
problem-free period of reactor operation.
2. Conclusion
Category 1
3. Board Recommendations
None
8
- _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
. 44
V. SUPPORTING DATA AND SUMMARIES
A. Investigations and Allegation Review
No NRC Office of Investigations reviews were conducted during the
assessment period.
There were five allegations concerning Unit 1 during this assessment
period, which included three in the area of security. Of the three
security issues, one is a carryover from last assessment period based
on additional concerns of the alleger; the other two were found to
be unsubstantiated and a drug-related concern which is still open.
Another allegation concerned demineralizer resin transfers which
involved an unsubstantiated ALARA concern. The last allegation dealt
with internal piping contamination between Unit I and Unit 2, and was
rsolved.
B. Escalated Enforcement Actions
1. Civil Penalties
None.
2. Actions Pending/ Resolved
r
None.
f 3. Orders
l
None.
4. Confirmatory Action Letters
None.
C. Management Conferences
On July 11, 1986, the licensee met with NRC management in King of
Prussia, Pennsylvania to discuss the previous SALP report findings.
l
l
l
i
i -
_ _ __ _ ___ __.___.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _________ __ ________________ ______ __-_ _____ - ______
.
.
45
D. Licensee Event Reports (LER)
1. Tabular Listing
Type of Events
A. Personnel Error 21
B. Design /Manuf./Constr./ Install. 15
C. External Cause 2
, D. Defective Procedure 8
E. Component Failure 7
X. Other 2
Total 55
A tabulation of LERs by functional area, and an LER synopsis
is attached as Table 1.
LER Nos.86-002 to 86-056 were received and reviewed by the
NRC during the assessment period.
2. Causal Analysis
The 55 LERs which were reported during the assessment period
were also subject to an ongoing review as part of NRC inspec-
tions for trends and root cause identification. The following
sets of common mode events were identified:
a. Twenty-one LERs concern events caused by personnel error,
which is a reduction both in the total number and frequency
of these occurances from last assessment period. Licensee
management is continuing its effort to better understand
and reduce personnel errors by increased training and
personnel awareness, and Independent Safety Evaluation
Group (ISEG) involvement in the Human Performance
Evaluation System (HPES).
While the number of personnel error-related events account
for approximately 40% of all reports during the assessment
period, the principal con'tributors were associated with
fire doors and barriers and inadequate communications dur-
ing surveillance testing. The licensee has recognized
>
these trends and has taken steps to reduce related causal
factors. Further, although 12 of the 21 events were in the
area of surveillance testing, a number were deficiencies
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ___
l
+
i
!
. 46 !
.
t
!
, found by the licensee (e.g., 4 overdue or missed surveil-
lance tests) because of effective supervisory overview I
and control of testing, and do not therefore represent a
!
' significant trend because of the extensive scope and
otherwise excellent test program record.
b. Fifteen LERs were attributed to design, manufacturing,
construction or installation problems. The total number ,
,
of events appear to be high, but eleven of the LERs were -
attributed to toxic gas detection systems. Unanticipated
sensitivity to moisture and external environmental con-
,
'
ditions was the principal cause of the events. The systems
were modified during this assessment period and are in the *
process of further refinement.
i
c. LERs86-037, and 86-046 were events attributed to external
causes. Both involved misoperation of the chlorine detec- ,
i tion probes during rain storms and high winds. The
i licensee is planning to relocate and protect the probes i
from moisture intrusion.
,
'86-044, and 86-056 were events attributed to procedural l
deficiencies. The total number of LERs caused by proce- i
j dure deficiencies dropped 25% from the last assessment
,
period which reflects improvement based on the experiences ,
l gained throughout the current assessment period. Further "
1 human factors improvements incorporated in procedures at !
j. the end of the assessment period should further reduce F
l events attributable to procedural deficiencies, icluding ,
a communications breakdowns (LER Nos.86-016, 025, 032, '
3 and 047). !
l i
, e. LERs86-013, 86-022,86-026, 86-031,86-045, 86-050, !
l and 86-054 were events attributed to random component ;
failure. This is a significant reduction from the 22 <
4
reportable events from the previous assessment period. '
<
'
- f. Nine LERs (Nos.86-006, 009, 017 thru 19, 027, 034,
and 036) were associated with fire protection activities. '
i Seven of these involved inadequately controlled fire doors !
and barriers which warrant further management attention
i and increased emphasis in training. The frequency of i
- these events increased concurrent with outage activities !
.
in May-June 1986, and therefore warrants particular atten-
l tion during the May 1987 refueling outage.
. i
4
! :
'
,
[
- - - - _ _ - -
- __
.
. 47
E. Licensing Activities
1. NRR/ Licensee Meetings
October 1,1986, SchedLling of Licensing Activities
2. Schedular Extensions Granted (Full Power License Conditions)
Amendment No. I to the full power licensee granted a one-time
, extension of 14 weeks in the 18-month surveillance interval
for leak rate testing of instrumentation line excess flow
Amendment No. 2 to the full power license granted a one-time
extension of twelve weeks in the surveillance interval for
leak rate testing of 27. containment isolation valves.
3. Exemptions Granted (Full Power License)
In conjunction with the issuance of Amendment No. 2 to the
license, a one-time exemption from the scheduler requirements
of 10 CFR Part 50 Appendix J for the leak rate testing of 27
containment isolation valves was granted.
4. License Amendments Issued
License Amendment Nos. I and 2, which extended the leak rate
test surveillance intervals on containment isolation valves,
were issued on February 6,1986 and March 3,1986,
respectively.
5. Emergency Technical Specification Changes _ Granted
License Amendment No. 3, which approved operation with a
reduction of feedwater temperature of up to 60 Farenheit
degrees and an increase of up to 105*.' in rated core flow was
issued on February 17, 1987.
There were six outstanding requests for amendments to the Unit
1 full power license at the end of the assessment period.
.
. 48
TABLE 1
TABULAR LISTING OF LERS BY FUNCTIONAL AREA
LIMERICK GENERATING STATION, UNIT NO. 1
I. LER by Functional Area
Number by Cause Code
Area A B C D E X Total
A. Plant Operations 9 11 2 2 3 2 29
B. Radiological Controls
C. Maintenance 1 1
D. Surveillance 12 3 6 4 25
E. Engineering Support
G. Security and Safeguards
I H. Training and Qualification
i Effectiveness
1
1. Licensing Activities
J. Assurance of Quality
K. Other
Totals 2 T TS~ -~ 2 ~~8 ~T 2 T5
Cause Codes: A. Personnel Error
8. Design. Manufacturing, Construction, or Installation
Error
C. External Cause
D. Defective Procedure
E. Component Failure
X. Other
.
- 49
TABLE 1 (Continued)
II. LER Synopsis
LER Number Cause Summary
86-002 A Unplanned Isolation of the Reactor Enclosure and
Actuation of SGTS and RERS during testing due to
Personnel Error
86-003 A Unplanned Closure of Shutdown Cooling Isolation
Valve
86-004 8 Unplanned Isolation of the Reactor Enclosure and
SGTS/RERS Initiation Due to Exhaust Fan Blade Pitch
Instrumentation Imbalance
86-005 8 Main Control Room Chlorine Isolation and Emergency
Fresh Air System Actuation due to Analyzer Tape
Break
86-006 A Late Performance of Fire Hose and Cart Visual
Surveillance Tests86-007 8 Actuation of Control Room Emergency Fresh Air
System due to Analyzer Tape Break
86-008 8 Main Control Room Chlorine Isolation and Emergency
Fresh Air System Actuation due to Analyzer Tape
Discoloration
86-009 A Overdue Calibration of Remote Shutdown Panel
Instruments86-010 A Feedwater Flow Transmitter Miscalibration -
Operation in Excess of Licensed Maximum Power Level
86-011 0 Reactor Scram on High Neutron Flu < due to Ground in
EHC Circuit
86-012 B RHR Service Water Radiation Monitor loss of
Isolation Capability on Downscale Failure
86-013 E Reactor Water Cleanup Isolations during Surveil-
lance Testing
86-014 0 Reactor Enclosure Isolation due to Breach in
Equipment Access Airlock
86-015 B Chlorine Analyzer Tape Break and CREFAS Actuation
.
. 50 ,
TABLE 1 Continued)
LER Number Cause Summary
86-016 A HVAC Isolation Trip Channel Inoperable for Greater
than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during Surveillance Testing
86-017 B Internal Fire Protection Seals Missing in
Electrical Gutters86-018 X Firewatch Violation due to Missing Penetration
Plugs86-019 A Failure to perform Hourly Fire Watch due to
Personnel Error
86-020 B Low Reactor Water Level Scram Due to Personnel
Error and Unavailability of Automatic Feedwater
Level Control Valve
86-021 A Actuation of SGTS due to Improper Use of Jumpers
During Testing
86-022 E Manual Isolation of Main Control Room Ventilation
and Emergency Fresh Air System Actuation due to
High Toxic Chemical Concentration Alarm Caused by
Detector Malfunction
86-023 A Division II ESF Actuation During Surveillance Test
due to Personnel Error caused by Procedural
Inaccuracy
86-024 A Unplanned Isolation of Reactor Enclosure HVAC and
SGTS/RERS Initiation due to Personnel Error in
Opening of Both Airlock Doors Simultaneously
86-025 A Isolation of Shutdown Cooling Caused by Communi-
cation Error during Testing
86-026 E Unplanned Isolation of the Reactor Enclosure HVAC
and SGTS/RERS Initation Due to a Blown Fuse from
Unknown Cause in High Radiation Circuitry
86-027 A Fire Watch Violation Due to Personnel Error in
Propping Open Fire Door
86-028 B Control Room Emergency Fresh Air System Actuation
due to False Toxic Gas Concentration Alarm Caused
by Drywell Chiller Freon Venting
- !
. 51
<
TABLE 1 Continued)
LER Number Cause Summary
86-029 8 RPS/UPS Static Inverter De-Energized and Isolation
of Instrument Gas Caused by an Incomplete Connec-
tion on a Logic Card Connector during Transfer of
Power Supplies86-030 A Personnel Error Caused Unplanned Group I MSIV
Isolation Signal During Troubleshooting / Stroking
Turbine Stop Valve
66-031 E Special Report - Combined Appendix J Type B and C
Leakage Exceed Allowable Limits86-032 A Daily Surveillance Test Overlooked for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Due
to Personnel Error / Insufficient Communication at
Shift Turnover
86-033 B Reactor Water Cleanup System Isolation on High
Differential Flow Caused by Collapse of Steam Voids
due to Piping Deficiency in Blowdown Configuration
86-034 A Open Fire Door for 5-1/2 hours Without a Posted
Firewatch Due to Personnel Error While Performing
HP Surveys86-035 D Failure to Comply with Technical Specification
Action Due to Procedural Deficiency - Overdue
Weekly IRM Channel Functional Surveillance Tests
During Shutdown
86-036 A Delay of 20 Minutes in Performing Hourly Fire Watch
for Five Barriers Due to Unscheduled Security
Computer Outage and Inadequate Communications86-037 C Control Room Ventilation Isolation and Emergency
Fresh Air System Actuation Due to Chlorine Analyzer
Malfunction
86-038 A Primary Containment Isolation Valves Inoperable
with Penetration Open
86-039 B Main Control Room Chlorine Isolations and Emergency
Fresh Air System Actuations Due to Electroylte
Probe
86-040 0 Reactor Water Cleanup System Isolations Due to High
Regenerative Heat Exchanger Room Temperature Caused
by Inadequate Ventilation and Opening of a Pressure
Relief Valve
$ 4-
n ,
.- -
!
. 52
.
TABLE 1 Continued)
LER Number Cause Summary
,~.86-041 0 Deficient Surveillance Test Procedure in Verifying
Energized 480 VAC Safeguards MCC
86-041 D Incomplete Performance of Weekly Surveillance Test
'
for Division IV DC Power Alignment Due to Personnel
and Clerical / Duplication Errors and Procedural
Deficiency
'
ll 86-043 B ,m Toxic Gas Detection System Vinyl Chloride Channel
' Operating in Nonconservative Condition Due to
Calibration Design Deficiency Caused by High
Humidity Effects86-044 0 Vinyl Chloride and AmmoniaToxic Gas Alarm Setpoints
Reversed Due to Calibration Error
86-045 E Division II Isolations Due to Blown Fuse Caused by
Improperly Fitted Test Leads and Personnel Errors86-046 C Main Control Room Chlorine Isolations & Emergency
Fresh Air System Actuations Caused by High Winds /
Moisture Effects on Probes86-047 A RCIC Steam Supply Isolation during Testing Caused
by Personnel Error and Inad2quate Communications
'86-048 A RWCU Isolation During Return t6 Service of
s
Demineralizer Caused by Improper Valving Sequence
and Personnel Error
86-049 B RWCU Isolation During Testing Due to Inaccessible
Test Connections
r
-86-050 E Removal of HPCI from Service to Repair Steam Supply
2'
Isolation Valve
86-051 X Fire Watch Not Established for Missing Spare
'l
Electrical Conduit seal
86-052 A HPCI Steam Supply Isolation During Testing Caused
,
by Personnel Error in Use of Ca11brator Unit
86-053 A Group VI C Isolation Caused by Improper Instrument
Root Valve Manipulation by Non-Licensed Plant
Operator
_ _ _ _ _ _ _ _
.
. 53
TABLE 1 Continued)
LER Number Cause Summary
86-054 E Reactor Enclosure Isolation Caused by Improperly-
Sized-Blown Fuse During SGTS Controller Replacement
86-055 B RCIC/ERFDS Temporary Cables Improperly Isolated and
Protected in Raceway from Fire Damage, Affecting
Safe Shutdown Capability
86-056 D Inconsistency Between Control Rod Block and SDV
Level Instruments Caused by Inadequate Surveillance
Test Procedures
,
_ _ _ _ . _ . _ _ _ _ _ . _
1
.
-
.
54
TABLE 2
INSPECTION HOURS SUMMARY (2/1/86 - 1/31/87)
LIMERICK GENERATING STATION, UNIT N0. I
Hours % of Time
A. Plant Operations. . . . ...... 974 35.0
8. Radiological Controls . . . . .... 301 10.8
C. Maintenance . .. ......... 362 13.0
D. Surveillance. . ........... 429 15.4
E. Engineering Support . ........ 61 2.2
F. Emergency Preparedness. ....... 326 11.7
G. Security and Safeguards . . . . . . . 328 11.8
H. Training and Qualification
Effectiveness . . . . . . . . . . . . **
I. Licensing Activities. . . . . . . . . *
J. Assurance of Quality. .... ...
- --
Total 2781 100.0
Hours expended in facility licensing activities and operator
ifcensing activities not included with direct inspection effort
statistics.
Hours expended in the areas of training and assurance of quality
are included in other functional areas, therefore, no direct
inspection hours are given for these areas.
.
.
. 55
TABLE 3
ENFORCEMENT SUMMARY (2/1/86 - 1/31/87)
LIMERICK GENERATING STATION, UNIT NO. 1
A. Number and Severity Level of Violations
Severity Level No.
Severity Level 3 0
Severity Level 4 3
Severity Level 5 1
Deviation __1
Total 5
B. Violations vs. Functional Areas
Severity Level
FUNCTIONAL AREAS III IV V DEV TOTAL
A. Plant Operations 1 1 1 3
B. Radiological Controls O
C. Maintenance 0
D. Surveillance 0
E. Engineering Support 0
G. Security and Safeguards 2 2
Violation and Deviation Totals: 0 3 1 1 5
C. Summary - Enforcement Data
Inspection Inspection Severity Functional
Report No. Date Level Area Violation
86-17 7/21-31/86 4 Operations Failure to maintain
chilled water
containment isolation
valve operability
.
. 56
TABLE 3 Continued)
.
Inspection Inspection Severity Functional
Report No. Date Level Area Violation
86-17 7/21-31/86 DEV Operations Inability to remotely
close the outboard
isolation valves on
chilled water systems
86-19 9/16-19/86 4 Security Closed circuit camera
deficiency
86-25 10/9 - 25/86 4 Security Failure to maintain
safeguards information
as prescribed in
87-02 1/5-9/87 5 Operations Failure to post a
firewatch during
grinding operations
- - ._ -- ,. . - -_. - . -.
- _______ _ ___-___-___________ _ ___________ _
.
o 57
TABLE 4
INSPECTION REPORT ACTIVITIES (2/1/86 - 1/31/87)
LIMERICK GENERATING STATION, UNIT NO. 1
Report / Dates Inspector Hours Areas Inspected
86-04 Resident 142 Routine
3/1/86 - 4/13/86
86-05 Specialist 39 Startup test program closeout
2/24/86 - 2/28/86
86-06 Specialist 82 Follow-up on security program
3/3/86 - 3/10/86
86-07 Specialist 127 Emergency preparedness exercise
4/2/86 - 4/4/86 Team
86-08 Specialist 18 Radiological environmental
3/10/86 - 3/14/86 monitoring program
86-09 Resident 328 Routine
4/14/86 - 5/31/86
86-10 Specialist 26 Nonradiological chemistry
5/19/86 - 5/21/86 program
86-11 Resident 314 Routine
6/1/86 - 7/31/86
86-12 Specialist 38 Leak Rate Testing
5/27/86 - 5/30/86
86-13 Specialist 43 Radiation protection program
5/22/86 - 5/30/86
86-14 Specialist 40 Effectiveness of QA and QC
5/30/86 - 6/5/86 activities
86-15 Specialist 68 Routine followup on security
7/1/86 - 7/11/86 items
86-16 Specialist 33 Technical Specification
7/7/86 - 7/11/86 surveillance testing and
calibration program
- _ _ _ - _ _ - - _ _ _ _
.
. 58
TABLE 4 Continued)
Report / Dates Inspector Hours Areas Inspected
86-17 Special 30 Assess cause and evaluate inoper-
7/21/86 - 7/31/86 Resident ability of drywell chilled water
containment isolation valves
86-18 Resident 211 Routine
8/1/86 - 9/15/86
86-19 Specialist 26 Safeguards including
9/16/86 - 9/19/86 psychological testing program
86-20 Specialist 43 Maintenance programs
9/8/86 - 9/12/86
86-21 Specialist 64 Radwaste management
9/16/86 - 9/19/86
86-22 Specialist 51 Non-licensed staff training
9/22/86 - 9/26/86
86-23 Resident 285 Routine Inspection
9/16/86 - 11/26/86
86-24 Specialist 0 Licensed operator examinations
10/24/86 - 12/1/86
86-25 Special 53 Security issues
10/9/86 - 1/25/87 Resident
86-26 Specialist 39 Inspection of radiological water
11/3/86 - 11/7/86 chemistry control program
86-27 Resident 353 Routine
11/27/86 - 1/27/87
87-01 Specialist 175 Emergency preparedness exercise
1/14/87 - 1/16/87 Team
87-02 Specialist 40 Fire protection program
1/5/87 - 1/9/87
87-03 Specialist 31 Security program
1/6/87 - 1/9/87
87-04 Specialist 82 Radiological controls including
1/12/87 - 1/16/87 ALARA programs
-
- - - -
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b
v' 60
Figure 1
Number of Days Shutdown
Limerick Generating Station, Unit No.1
Feb. 86 --l 1 DAY SHUTDOWN
--l
Mar. 86
Apr. 86
May 86 29 DAYS SHUTDOWN l
l
June 86 16 DAYS SHUTDOWN l
l
July 86 9 DAYS SHUTDOWN l
l
Aug. 86
Sep. 86
Oct. 86
Nov. 86
Dec. 86
Jan. 87 l 5 DAY SHUTDOWN
l