IR 05000352/1987011

Insp Rept 50-352/87-11 on 870504.No Violations Noted.Major Areas Inspected:Licensee Action on Previous Findings, Preparation for Refueling,Training,Qa/Qc & Engineering Interfaces & Independent Verification

ML20214S267
Person / Time
Site:	Limerick
Issue date:	05/22/1987
From:	Marilyn Evans, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214R724	List: IR 05000352/1987011 ML20214R721
References
50-352-87-11, NUDOCS 8706090205
Download: ML20214S267 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-11 Docket N License N NPF-39 Priority --

Category --

Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit 1 j Inspec' tion At: Limerick, Pennsylvania Inspection Conducted: May 4-8, 1987 Inspectors:

M. Eva

[A 'datd b

, e tor fngineer ' ' /

Approved by: ~

M D. 'FloreK, Acting Chief, Test Programs / da1(e f7 Section, 08, DRS

Inspection Summary: Inspection on May 4-8, 1987 (Inspection Report No. 50-352/87-11)

Areas Inspected: Routine onsite inspection by one region based inspector of licensee actions on previous inspection findings, preparation for refueling, training, standby gas treatment system license condition, QA/QC interfaces,

independent verification, engineering interface and plant tours.

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Results: No violations were identifie NOTE: For acronyms not defined, refer to NUREG-0544 " Handbook of Acronyms and Initialism."

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870609020D B70522 PDR ADOCK 05000352 l l G PDRg

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! DETAILS 1.0 Persons Contacted Philadelphia Electric Company

• J. Burke, Lead Auditor, Quality Assurance (QA)

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J. Doering, Operations Superintendent

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C. Endriss, Administrative Engineer E. Firth, Training Coordinator

• J. Franz, Manager, Limerick Generating Station

• M. Gallagher, Reactor Engineer

• E. Gibson, QA Engineer M. Held, QC Engineer

• K. Hunt, Radwaste Engineer

• W. Rekito, Compliance Engineer

• J. Rubert, Site QA Supervisor J

S. Taylor, ALARA Technical Assistant Other NRC Personnel

E. Kelly, Senior Resident Inspector S. Kucharski, Resident Inspector

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. * Denotes those present at the exit meeting on May 8, 1987.

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The inspector also contacted other members of the licensee's technical, operational and QA/QC staf .0 Licensee Actions on Previous Inspection Findings (Closed) Unresolved Item (352/84-67-04) Licensee to conduct an inspection i

of the spent fuel pool storage racks based on the fact that two fuel

! bundles were stuck or partially stuck during the initial fuel loading in j November of 198 The inspector reviewed the following documents:

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! -Letter from M. L. Eyre, Test Engineer, to K. W. Kunt, Reactor Engineer, j " Geometry Investigation of the Fuel Storage Racks", dated December 6, i 198 '

l -Mechanical Engineering Division Memorandum RES 6-8-4, " Limerick Generating Station Unit 1 Modification #925, Spent Fuel Storage Rack

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j Problems", dated November 4, 198 ;

{ -Letter from G. M. Zaimis, Project Engineer, Mechanical Engineering Division, to R. T. Scott, Superintendent, Construction Division Limerick

Section, " LGS, Unit 1 Engineering Work Letter, Revision 0, Modification j #925, Evaluation of Spent Fuel Storage Rack Binding Problems", dated j December 12, 1986.

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f The inspector noted that the licensee conducted a thorough investigation of the spent fuel storage rack problems using the dummy fuel assembl The licensee's Mechanical Engineering department subsequently evaluated the identified problems, and the following corrective actions were-

. implemented: Ten spent fuel storage rack defective locations have been plugged; The storage of double blade guides has beu restricted to specified allowable locations; and Fuel Inventory Log A-44-3 has been revised to administratively restrict storage of fuel assemblies in seventeen location The inspector toured the refuel floor area and verified that the ten defective spent fuel storage rack locations had been plugged and that the seventeen restricted storage locations were properly identified on the Refuel Floor Spent Fuel Pool Status Board. This item is close .0 Preparation for Refueling The inspector reviewed the adequacy of the licensee's procedures for the conduct of refueling operations. This included a review of administrative requirements for the control of refueling operations and plant conditions during refueling. The procedures listed in Attachment A covered the following activities:

-Fuel handling, transfer and core verification; ,

-Inspection of fuel to be reused, fuel assembly inspection using underwater video system; and-Periodic monitoring of spent fuel pool cooling parameters and consideration of contingency cooling method These procedures were reviewed for technical adequacy and to verify the licensee had established:

-clear definition of lines of supervision;

-shift manning requirements;

-requirements for training and qualification of key personnel;

-QA/QC requirements;

-communication requirements;

-radiation monitoring and radiological control requirements;

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requirements for equipment checkout, dry runs of critical operations, and fuel handling;

-requirements for work stoppages, delays and holds; and-requirements for monitoring shutdown margin, reactivity, radiation levels, water level, decay heat removal and containment integrit In addition, the inspector reviewed a sampling of surveillance procedures applicable to operational conditior. 5 (mode switch in refuel) and verified that the procedures satisfied technical specification requirement The inspector interviewed key licensee personnel including the Refuel Coordinator, Reactor Engineer, and representatives of the licensee's Training, Health Physics, Quality Assurance, Quality Control and Operations departments concerning their responsibilities and understanding of administrative requirements. The inspector noted that the licensee has established a formal Refueling Floor Outage Organization. Specific responsibilities have been defined for each position in the organizatio The licensee stated the primary reason for establishing this organization was to clearly describe lines of communication for activities on the refuel floor, but not to change existing lines of supervisio The inspector verified that requirements for the checkout and dry run of the refuel bridge had been established. The plans for establishing clean area requirements were also reviewed and discussed with licensee personne .1 Findings No unacceptable conditions were identifie .0 Training The inspector reviewed the licensee's program for the training of licensed and non-licensed operations personnel in preparation for refueling activities. Discussions with the Training Coordinator indicated that I

training included classroom training and on-the-job training concerning l use of the refueling equipmen .1 Classroom Training i

The inspector reviewed lesson plans for classroom training on Refueling Operations and Fuel Handling. Separate lessen plans had been prepared for training of SR0s, Ros and non-licensed operator Review of these lesson plans verified they included a system overview, detailed description of the refueling equipment, review of applicable procedures and Technical Specifications, and a discussion of related industry event _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _

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4.2 On-The-Job Training SR0s, R0s and non-licensed operators all received on-the-job training which included performance of Fuel Handling Procedure FH-410,

" Refueling Platform Shift Checkout", and movement of the dummy fuel bundle as per a provided Core Component Transfer Authorization Sheet (CCTAS). The inspector interviewed a SR0 and a non-licensed operator on the refuel bridge and questioned the operators concerning the training they had receive In addition, the operators walked through several Fuel Handling and System Procedures regarding operation of the refuel bridge and fuel movement. All of the inspector's questions were satisfactorily answere .3 Findings No unacceptable conditions were identified with regard to the licensee's training program for refueling operation .0 Standby Gas Treatment System - License Condition The inspector discussed License Condition 14, " Refueling Floor Volume Connection to Standby Gas Treatment System (SBGTS)", with a licensee representative. This license condition requires the licensee to complete and test all modifications required to SBGTS prior to any movement of irradiated fuel within the refueling floor volume. The licensee a representative explained to the inspector the licensee's plans for implementing the SBGTS modification prior to removal of the drywell hea The inspector reviewed procedure GP-6.1, " Shutdown Operations - Refueling, Core Alteration and Core Off-Loading", draft Revision 1, and noted specific steps in the procedure requiring Station Management approval prior to removal of the drywell head and the reactor vessel hea In addition, the inspector noted that QA will specifically audit compliance with License Condition 14 prior to movement of irradiated fuel. No discrepancies were identifie .0 QA/QC Interface with Refueling Activities The inspector interviewed representatives of the licensee's Quality Assurance and Quality Control Organizations to ascertain the extent of QA/QC coverage of refueling activities. The inspector noted that QC will supply two qualified accounting technicians per shift durirg actual fuel movements and all operations involving the refuel bridge. QA will perform audits and surveillances of various activities including fuel unloading and loading and LPRM replacemen In addition, QA will audit licensing commitments that must be complicd with prior to refueling or startup following the refuel outag .1 Findings No deficiencies were identifie _- -

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7.0 Independent Verification During review of Unresolved Item 84-67-04 (see paragraph 2.0), the inspector independently verified that the ten defective spent fuel pool locations had been plugged so that no fuel bundles or blade guides could be inserted in those locations. In addition, the inspector observed the Refuel Floor Spent Fuel Pool Status Board and verified that the seventeen restricted storage areas were properly identifie .0 Engineering Support Interface During review of Unresolved Item 84-67-04 (see paragraph 2.0), the inspector reviewed the licensee's Mechanical Engineering Division evaluation of Spent Fuel Storage Rack Problems. The inspector noted that Mechanical Engineering thoroughly reviewed the problems identified in Reactor Engineering's " Geometry Investigation of the Fuel Storage Racks" and identified the causes of the problems. Mechanical Engineering recommended appropriate corrective action and notified the Construction Division of necessary work needed to implement the corrective action. No discrepancies were identifie .0 Plant Tours The inspector made several tours of the refuel floor area to observe work in progress, housekeeping and cleanliness controls. The inspector noted that the area surrounding the spent fuel pool and the refuel bridge had been appropriately designated as Housekeeping Zones II and I respectivel Material and personnel accountability logs were posted at the entrance to each area. No unacceptable conditions were identifie .0 Exit Interview A management meeting was held at the conclusion of the inspection on May 8,1987 to discuss the inspection scope, findings and observations as detailed in this report (see Paragraph I for attendees). i' written information was provided to the licensee at any time durins this inspection. The licensee did not indicate that any proprietary information was contained within the scope of this inspectio ._

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Attachment _A Procedures Reviewed Procedure N Revision Title date approved FH-105 5 Core Component Movement- 11/13/84 Core Alterations FH-401 3 Startup of Refueling 11/3/86 Platform FH-410 2 Refueling Platform Shift 10/12/84 Checkout FH-602 0 Qualification of Refueling 2/15/84 Platform Operators FH-605 3 Core Component Transfer 5/16/86 Authorization Sheet Instructions GP- (draft) Shutdown Operations- 3/20/87 Refueling, Core Alteration and Core Off-loading GP- Shutdown Operations- 4/1/87 Shutdown Condition Technical Specification Actions A-30 4 Administrative Procedure 4/10/87 for Plant Housekeeping

ST-3-097-355-1 1 Core Post-Alteration 4/9/85 i Verification ST-6-107-630-1 5 Core Alteration Testing 11/6/84 S97. Operation of the Refueling 8/15/85 Platform Bridge, Trolley and Main Hoist M-041-011 1 Maintenance Procedure for 5/22/85 Reactor Vessel Disassembly M-041-024 1 Maintenance Procedure for 4/30/85 Reactor Vessel Assembly

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