IR 05000352/1985032

Insp Rept 50-352/85-32 on 850805-09.No Violation Noted. Major Areas Inspected:Licensee Action on Previous NRC Concerns & QA Program for Power Ascension

ML20135C130
Person / Time
Site:	Limerick
Issue date:	08/30/1985
From:	Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20135C129	List: IR 05000352/1985032 ML20135C125
References
50-352-85-32, NUDOCS 8509110324
Download: ML20135C130 (6)

Text

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

,

i

.

i i

i i

j U.S. NUCLEAR REGULATORY COMMISSION j REGION I

,

j Report No. 50-552/85-32 t

] Docket No. 50-352

j License No. NPF-27 Licensee: Philadelphia Electric Company

2301 Market Street I Philadelphia, Pennsylvania 19101

Facility Name: Limerick Generating Station, Unit 1 i ,

{ Inspection At: Limerick, Pennsylvania t

Inspection Conducp : August 5 - 9, 1985 Inspectors: 8 2935 i

'

l M. Dev, Reactor Engineer date Approved by: .

d. k Dr. P. K. Eapen, Chief, 3D!7P~~ I l / dater i Quality Assurance Section

!

j Inspection Summary: Routine, unannounced inspection conducted m August 5-9, j 1985 (Inspection _ Report No. 50-352/85-32) '

$

}

! Areas Inspected: Licensee's action on previous NRC concerns and the quality j assurance program for power ascension. The inspection involved 40 inspection j hours by one region-based inspecto '

j '

Results

No violations were identified.

l

<

I

)

I

!

'

i i

1; l. . O l

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

.

.

DETAILS 1.0 Persons Contacted  :

,

S. DiMauro, Lead Auditor - PEC0

'

C. Endris, Regulatory Engineer - PECO

• K. Folta, QA Engineer - PEC0 GILBERT i *C. Harmon, QC Supervisor - PECO

M. Held, QC Engineer - PECO

• G. Lauderback, QA Engineer - PECO

• G. Leitch, Plant Manager - PECO C. Mengers, Gen Supervisor, QA Audit - PECO i C. O'Donnel, Lead Auditor - PECO

*J. Rubert, Supervisor, QA Audit - PECO

G. Rainey, Instrument & Control Engineer - PECO 0. Rossman, QA Engineer - PEC0 R. Smith, QA Engineer - PECO

• R. Smith, Lead Auditor - PECO

• V. Warren, Test Engineer - PECO

,

• Denotes those present at exit meeting held on August 9, 198 The inspector also contacted other licensee and contractor technical and administrative personnel during this inspectio .

2.0 Licensee's Action on Previous NRC Concerns

(Closed) Inspector Follow Item (50-352/84-21-03): The licensee's trend analysis method did not address all corrective action systems. There was no procedure for evaluation and analysis of corrective action quality

,

tren In response to the above the licensee has established a Procedure, QADP-32, Revision 0, Quality Assurance Tracking and Trending System Trending Quality Deficiencies. This procedure describes method to be used for the Electric Production QA Trend Analysis and evaluation of quality 1 problems identified as a result of QA Audits, QC Inspections, QC Monitor- ,

ing, QA Surveillances, LERs, INP0 Evaluations, JUMA Audits, ANI Inspections, l NRC Inspections, QC Initiated Non-compliance Reports, and other Noncom-formance Reports. In addition, Engineering and Research QA findings are trended in accordance with the Procedure QAI-29. The inspector reviewed the licensee's Procedure QADP-33, Revision 0, for the Entry of Data into l the Quality Assurance Tracking and Trending System Data Base, and Instruc-tion for Data Input to Quality Assurance Tracking and Trending Syste The new trending system incorporated attributes such as, personnel error;

design, manufacturing and construction deficiency; external causes; pro-l cedural deficiency; management or QA program deficiency; records; and commitments. These attributes were trended against findings relative to organization, criteria, severity, activities, causes and the time-span.

i Based on the above this item is close _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _____-

____ -- _

.

.

4 (0 pen) Inspector Follow Item (50-352/84-31-08): Appendix I of the

, Administrative Procedure A-46 addressed station QA records, individual responsibility, and records maintenance and transmission to NRMS. The initial review indicated that the intent of the Appendix I was not

, uniformly implemented. The current inspection verified that the licensee updated all but 15 of the 68 station procedure '

This item remains open pending completion of the remaining 15 procedures.

(0 pen) Unresolved Item (50-352/84-67-04)

Two fuel bundles (LY 8076 and LY 8310) were stuck in the spent fuel pool rack during fuel loading. An investigation was conducted to evaluate and analyze the severity of the problem. The licensee has not completed the required test because the i dummy fuel bundles have been loaned to the Hope Creek Generating Statio l This item remains open, pending completion of the required test by the j licensee.

1 3.0 Quality Assurance Program for Power Ascension

,

3.1 Reference / Requirements

--

10 CFR Appendix B, Quality Assurance Criteria for Nuclear Power Plants ..., Criteria X and XVI

--

Limerick Generating Station (LGS) FSAR, Section 17.2, Operational Quality Assurance Program

--

LGS Technical Specification, Section 6, Administrative Controls

'

--

ANSI N45.2.12 - 1977, Requirements for Auditing Quality ( Assurance Program

--

ANSI N18.7 - 1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

!

--

LGS Quality Assurance Plan, Volume III, Operation Phase

--

Philadelphia Electric Company (PECo) Nuclear Review Board Procedure, NRB-3, Audits 3.2 Program Review The inspector reviewed LGS QA Operational Program as applicable to startup and power ascension test to verify that the licensee has established procedures to provide QA/QC coverage for the following activities:

--

conduct of testing

--

Tracking of test deficiencies

! --

Test documentation

--

Control of measuring and test equipment

--

QA and management audit of test program and audit review I

-

.-

,

--

Responsibility of QA personnel as related to startup test program The inspector reviewed the following LGS administrative and QA proce-dures and instructions:

--

A-13, Procedure for Reporting Defects and Noncompliance, Rev. 2

--

A-14, Procedure for Control of Plant Modification, Rev. 2

--

A-25.1, Preventive Maintenance Program, Rev. 1

--

A-26, Procedure for Corrective Maintenance, Rev. 1

--

A-27.1, Administrative Procedure for Procurement of Q-Listed Items, Rev. 1

--

A-43, Surveillance Testing Program, Rev. 7

--

A-47, Procedures for Preparation and Control of Surveillance Test Procedure, Rev. 4

--

A-200, Startup Test Procedure Format and Content , Re A-201, Startup Test Procedure Control, Rev. 1

--

A-202, Startup Test Implementation, Rev. 1

--

A-203, Startup Test Program Personnel Training and Qualifica-tion, Rev. 0

--

A-204, Hot Functional Test Procedure Preparation, Control and Conduct, Rev. 0

--

QADP-6, Quality Assurance Division Audit Program - Preopera-tional and Operational Phase, Rev. 10

--

t 1 0ADP-8, Procedure for Preoperation and Use of Audit Checklist, Rev. 6 j

\

l

'

--

QADP-9, Procedure for Control of Apparent Deficiencies and '

Auditor Follow up Required Items, Rev. 10

--

--

QADP-9.1, QC Procedure for Control of Nonconformances, Rev. 1 QADP-12, Procedure for Performance of QA Division Surveillance, Rev. 10

--

QADP-26, Quality Control Inspection of LGS Startup Preopera-

--

tional Testing Activities, Rev. 2 QADP-27, Procedure for Issuance and Control of Limerick Startup

--

Quality Control Corrective Action Request, Rev. 3 QADP-27.1, Procedure for Performance of Startup Nonconformance Report Trend Analysis, Rev. 3

--

QADP-28, Procedure for Quality Assurance Monitoring of Completed

--

LGS Startup Preoperational Test Packages, Rev. 1

--

QADP-30, Procedure for LGS Startup QC Surveillances, Rev. 1 QADP-100, Training, Qualification and Certification of Quality I Control Personnel, Rev. 2

--

--

QADP-101, Quality Control Inspection Program, Rev. 1

--

QADP-101.1, Cor. duct of QC Inspection Activities, Rev. 2 QADP-101.2, QC Review of Inspection Points in Work / Test Procedures, Rev. 1

--

QADP-104, QC Monitoring Program, Rev. 1

--

QADP-104.1, Scheduling, Performing, Documenting and Status

--

Tracking Quality Control Monitoring Activities, Rev. 2 QADP-104.2, Preparation of Detailed Monitoring Checklist, Rev. 1

_

,

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

-

,

.

--

QADP-105, Calibration and Control of QC Measuring and Test Equipment, Rev. 0

--

LGS-QCI-003, Instruction for Review of Startup Test Procedures (STP) and Hot Functional (HF) Procedures, Rev. 3 -

--

LGS-QCI-005, Instruction for Surveillance of Startup and Hot Functional Testing Programs, Rev. 1

--

LGS-QCI-007, Instruction for Review of Startup and Hot Func-tional Testing Programs, Rev. 1 3.3 Program Implementation The inspector discussed with the Electric Production and Engineering and Research QA/QC Supervisory personnel, LGS Instrument and Control

. engineer, and their staff regarding scope, responsibility and imple-mentacion of LGS startup and power ascension test program. The inspector verified that LGS has established procedures and instruc-tions, referenced in paragraph 3.2, to provide QA/QC coverage for power ascension test activities including conduct of testing, track-l

'

ing of test deficiencies, test documentation, and control of measur-ing and test equipment, by QA/QC personnel, on a regular basi These procedures and instructions were adequate and the individuals a performing QA/QC overview of the startup test activities were experi-

! enced, qualified, properly indoctrinated and certified to meet the

licensee and regulatory requirement l The inspector reviewed the following management and quality assurance l audits of the test program on a sampling basis and verified that j they were performed in accordance with the program requirements.

AL-84-41 MI, Measuring and Instrumentation AL-84-18 PR, Control of Heavy Load AL-84-28 PR, Preoperational Testing AL-84-58 PR, Corrective Action AL-84-86 PR, Initial Fuel Load and Zero Power Testing AL-84-19 MEM, Corrective Maintenance Program AL-84-69 MEM, Corrective Maintenance Program Al-84-40 SU, Hot Functional Startup Testing Al-85-07 M00, Minor Plant Modification AL-85-30 PR, Corrective Action Program for QA/NRC Identified Noncompliances The inspector noted that these audits properly identified unresolved items and nonconformances and recommended corrective actions, as applicable. It was also noted that LGS open items tracking mechanism updated " Activities Report" biweekly and "Open Item List" monthl This provided updated status of all outstanding audit finding and nonconformances to the LGS QA/QC and the management. The audits were reviewed by responsible management personnel and items requiring

, resolution were properly dispositioned and documented in accordance with program requirement _

____-.____.__-_-.-.-m.___-______

. _ _ _ _ _ _ _ _ ___

,.

i The inspector witnessed the following Electric Production QA audit in progress:

AL-85-64 S0, LCO Surveillance Test Procedure Review AL-85-64 PR, TMI Lesson Learned Routine Test Procedure Review i

'

The inspector also reviewed Current QA Audit Schedule and found it adequat .4 Findings

,

No violations were identified in the areas inspecte .0 Management Meetings Licensee management was informed of the scope and purposes of the inspec-

'

tion at an entrance meeting conducted on August 5, 1985. The findings of the inspection were discussed with licensee representatives during the

course of the inspection. An exit meeting was conducted on August 9, 1985 at the conclusion of the inspection (See Paragraph 1.0 for attendees) to provide the findings of this inspection to licensee managemen At no time during the inspection was written material provided to the license '

l i

$

t

'

)1 l