IR 05000352/1987012
| ML20234B255 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/18/1987 |
| From: | Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20234B246 | List: |
| References | |
| 50-352-87-12, GL-83-28, NUDOCS 8707020301 | |
| Download: ML20234B255 (9) | |
Text
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/87-12 Docket No.
50-352 License No.
NPF-39 Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station Unit 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted:
May 18-22, 1987 b
$
Inspectors: _
ev,PL,ReactorEngi/eer
' dite
.
Approved by:
d'
_
67 f/77 Dr. P. K. Eapen, Chfief
/dat6
'
Quality Assurance Section Inspection Summary:
5pecial announced inspection on May 18-22, 1987
{ReportNo. 50-352/87-12)
Areas Inspected:
Licensee's actions to address the concerns identified in NRC Generic Letter 83-28 related to Equipment Classification.
Results: No violations were identified.
I i
.
B70702030.1 870624 PDR ADOCK 05000352 G
.i
.
DETAILS 1.0 Persons Contacted Philadelphia Electric Company (PECo)
R. Brown, Supervisory Engineer
- J. Burke, Lead Auditor
- A. Coppa, Maintenance Engineer
- C. Endris, Administrative Engineer
- K. Folta, QA Engineer
- D Neff, Compliance Engineer
- J. Robert, Site QA Supervisor
- J. Spencer, Superintendent Plant Services United States Nuclear Regulatory Commission E. Kelly, Senior Resident Inspector
- S. Kucharski, Resident Inspector The inspector also contacted other licensee administrative and technical personnel during the course of this inspection.
- Denotes those present at the exit meeting on May 22, 1987.
2.0 Review of The Licensee's Actions For Equipment Classification Required By NRC Generic Letter 83-28 In February 1983 the Salem Nuclear Power Station experienced two failures of the reactor trip system on demand. Regulatory and industry task forces were formed to determine the safety significance and generic implications of the events. Based on these findings, certain actions were required of all licensees.
These actions, transmitted in Generic Letter 83-28 fell into four areas:
(1) Post-Trip review (2) Equipment Classification and Vendor Interface
!
(3) Post-Maintenance Testing, and (4) Reactor Trip System Reliability Improvements PECo submitted their response to GL 83-28 in the letters listed in attachment A.
This inspection included only the area related to the Equipment Classificatio _
.
4 2.1 Implementation Review The inspector reviewed the applicable documents listed in Attachment A to determine that the Equipment Classification Program addressed the following:
--Safety-related components are identified through written procedures for procurement, maintenance, and modifications,
--Management oversight of source documentation is assured for the i
designation of the safety-related structures, systems, and
'
components,
--Corporate level procedures are established for safety-related components procurement, maintenance, and modifications,
--Periodic Quality Assurance audits of activities impacting safety-i related equipment are conducted, and
'
--Corporate action program for safety-related equipment has been implemented.
The inspector reviewed the licensee's Administrative Procedure A-26, Procedure for Corrective Maintenance, and its Appendices for safety-related work activities.
The following maintenance request forms (MRFs)
for the corrective & preventive maintenance work were reviewed.
The safety classification of the components and the activities reviewed were found to be properly identified and evaluated.
MRFs 8507127, Control Enclosure HVAC - Indicating Meter Failure 8508757, Standby Liquid Control - Relief Valve Cap Leak j
8605731, RCIC Pump and Turbine - ASME Section XI Exam.
8702769, RCIC - Remote Shutdown Panel Switch Replacement 8703645, RCIC - Remote Shutdown Panel Guardrail Installation j
8701238, RPS - Improper Connection 8708212, RPS - Relay Base (C714-K160) Broken 8781284, Emergency Diesel Generator - control Cabinet
-
Cleaning 8780276, Emergency Diesel Generator - Alternator Cleanup 8780179, 480 Volt FW MOV Inlet Check 8780052, RHR - Bench Test 8781278, DC System - Battery Inspection 8781279, DC System - Battery 18-Month Surveillance A field verification of system mechanical drawings and electrical elementa ry diagrams versus installed equipment was performed and certain equipment was selected for verification of the implementation of the licensee's Equipment Classification program.
For each component selected, the inspector reviewed the adequacy of the safety classification related to procurement, receipt, storage and handling, and maintenance activities, as discussed in the following paragraphs:
l
-
-
-
>
.
,
a.
Reactor Protection Systems Recirculation Pump M/G Sets A visual inspection of the Recirculation Pump Motor Generator Sets and associated equipment, and instruments on panels IAC051, 1AC052, 1BC051, and 1BC052 was conducted and the inspector verified that their safety classification was correctly identi fie:, in accordance with the Nuclear Records Management System spare parts procurement program.
ATWS Control Panel The inspector reviewed the licensee's Redundant Reactivity Control System which is relied upon to actuate RHR and Core Spray systems in response te ATWS events.
ATWS panels 20A201 and 10A202 instruments were found to be properly identified on QADs and the NRMS spare parts list.
Identification of RRCS SV 047, IF009 (safety-related) and SV 047, 1F110B (non-safety-related) were verified through associated QADs and procurement documentation. The ATWS equipment selected were also verified for proper storage and incorporation into the shelf life program.
The RRCS panels IC634 and IC635 were opened and inspected to verify the wiring configuration.
An ongoing surveillance activity was also witnessed.
_ Remote Shutdown Panel The inspector visually inspected the Remote Shutdown Panels 10C201 and 20C201 and verified the adequacy of the associated equipment classification.
The inspector also reviewed the modification design change package, MDCP 0037 implementing
,
Remote Shutdown Panel 10C201 RHR SW HI-HI Radiation Warning
{
Lamps. The licensee had conducted a safety evaluation for this modification. The package also included an Equipment Qualifica-tion evaluation and materials list.
The related as-built drawings were not updated as the modifications were not complete.
Several Interim Design Change Notices were also found
{
on hold. The licensee representatives stated that the drawings
discussed above will be updated within 90 days of the completion j
of the field verification of the modification in accordance with Bechtel procedure EDPI 4.73.1, Modification Design Package.
l The inspector also reviewed the Reactor Protection System modification packages MDCP 0490, Replacement of Over and Under Voltage Relays; MDCP 0800, Relocation of Pressure Switches; and NOD 05090, Removal of Selected Electronics Cards from RRCS.
These modifications are ongoing.
The verification of physical configuration of under voltage relay and shunt trip coils in the RPS breaker Panel 1AC248 were not properly identified on the i
Schematic Diagram E-392, Rev B.
The licensee representatives stated that the as-built drawings are in the process of being revised by Bechte.
.
Equipment classification and related procurement Quality Coding of the following safety-related RPS components were verified and found to be accurate.
Agastat Relay, Type EGPI,120 VAC,114-46984 (Material Code)
EGPD, 125 VDC, 114-46985 EGPB, 24 VDC, 114-46986 Potter Broomfield Relay, Auxiliary, 24 VDC, 114-37319 120 VAC (.5-15 Sec), 114-37321 b.
Safeguard Electric Power System The inspector verified the equipment classification related to the 4kV Emergency Diesel Generator 1AG501 and associated equipment and instruments, including the DC motor driven fuel pump, 1AP538; diesel oil transfer pump, 1AP514 and related 4 kV safeguard switchgears.
The NRMS spare parts list identified Diesel Generator subcomponents based on their safety classif-ication evaluation.
A visual inspection of 120V Static Inverter Panels 1AD160, IBD160 and 10D161 was conducted.
The safety classification of related instruments were verified to be properly identified.
The inspector witnessed an ongoing surveillance test.
The inspector also visited the Division I, Channel ZA battery room and inspected 125VDC, 60 cell Batteries 1A2D101 and 1 AID 101.
The effects of battery acid was noticable on the floor near the center of the battery racks. The licensee representative stated that a maintenance request has been initiated to rectify the problem.
The inspector reviewed the maintenance request forms (MRFs) 87812 and 87813 issued for this purpose.
The work was not completed at the time cf the inspection, c.
Safety Systems Portions of the Emergency Service Water System, Residual Heat Removal Service Water, Nuclear Boiler, Fuel and Diesel Oil Storage and Transfer, Nuclear Boiler Vessel Instrumentation,
'
.
Control Rod Drive Hydraulic System, Reactor Core Isolation Cooling System, Reactor Enclosure and Refueling Area HVAC, Control Enclosure - HVAC, and Reactor Protection System design and drawings were reviewed.
On a random basis instruments and equipment were selected and their safety classification was
,
verified in accordance with the QADs (Attachment A) and the NRMS spare parts procurement evaluation documen.
The inspector reviewed modification package MDCP 0482, Refueling Floor Temporary Maintenance, including its safety evaluation, related design and drawings, and materials list.
The modifi-cation was complete and the safety classification of the structure, system and component, and modification work was properly identified.
2.2 Program Assessment The licensee uses the Bechtel Project Q-Li st to identify safety-related structures, systems and components at Limerick Generating Station Unit 1.
The Q-List defines its purpose, scope and limita-tions of its use.
This document is divided into three basic sections, as follows:
1) Civil and Architectural Discipline 2) Electrical Discipline 3) Control Systems, Mechanical, and Plant Design Disciplines With exception to the Electrical Discipline section, most Q-Listed structures, systems, and components are defined on the Quality Assurance Diagrams (QADs).
In a letter dated June 7, 1985, the licensee stated that by the conclusion of the first refueling outage for Limerick Unit 1,
a procedure to control the Equipment Classification (Q-List) will be established and implemented.
Discussion with the licensee's Engineering & Research Department representative indicated that the development of such a procedure will be deferred until Unit 2 is licensed.
The licensee intends to request an extension for their compliance to GL 83-28 Action Items 2.1 and 2.2 related to Equipment Classification.
This is an unresolved item pending the licensee's resolution of the issue on the docket (50-352/87-12-01).
2.3 Assurance of Quality The inspector reviewed the following Site Nuclear Operation Quality Assurance audits:
AL 86-08 SP, Procurement and Storage AL 86-117 PR, Environmental Qualification of Safety-Related Electrical and Mechanical Equipment A1 87-12 TR, Craftsman Training These audits reviewed the licensee's quality control activities and identified several noncompliances.
The recommended corrective actions and their implementation were found to be adequate.
l
p
.
.
The. inspector reviewed the licensee's. Equipment Classification related training program and verified that individuals performing spare parts: procurement evaluation were required to conduct self-studies of _ certain procedures and licensing documentation. There is no formalized Equipment Classification related training program for the ' personnel performing safety related activities of preparation, review,. procurement, maintenance and plant modifications.
The licensee stated that' the departmental training program will be revised to include Equipment Classification related attributes. The.
effectiveness of the licensee action will be verified in a future NRC inspection. This is an unresolved item (50-352/87-12-02).
2.4 Conclusion Except for the unresolved items discussed above, the 1icensee's equipment classification activities were consistent with the intent of Generic Letter 83-28 Action Items 2.1 and 2.2.
3.0 Unresolved Item Unresolved. items are matters about which more information is required in order to ascertain whether they are acceptable, deviations, or violations.
Two unresolved items were identified during this inspection and are discussed in Paragraph 2.
4.0 Management Meetings The licensee management was informed of the scope and purpose of the inspection at an entrance meeting conducted on May 18, 1987. The finding of the inspection were discussed with the licensee representatives during the course of this inspectinn, An exit meeting was held on May 22, 1987 at the conclusion of the inspection-(see. Paragraph 1.0 for attendees) at which time the licensee management was informed of the inspection results.
At no ' time during this inspection was written material provided to the licensee.
l l
ATTACHMENT A
.
1.0 References / Requirements
NRC Generic Letter 83-28, " Generic Implications of Salem ATWS Events" 10 CFR Appendix B LGS Technical Specifications FSAR Quality Assurance Program - Philadelphia Electric Company, Limerick Generating Station ANSI N18.7-1972, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants ANSI N45.2.2-1972, Packing, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants PECo Letter to NRC, Response to GL 83-28 dated November 10, 1983 PECo Letter to NRC, Supplemental Response to GL 83-28 dated June 7, 1985 2.0 Documents Reviewed
'
Administrative Procedure A-2, Control of Procedures and Certain Documents, Rev 4, August 25, 1986 A-26, Procedure for Corrective Maintenance, Rev 11, January 20, 1987 A-26, Appendix 1, Instruction for Completing Limerick Generating Station
'
Maintenance Request Forms (MRFs), Rev 7, January 20, 1987
A-26, Appendix 2, Instruction for Completing Limerick Generating Station Equipment Trouble Tag, Rev 3, September 17, 1096 A-26, Appendix 3, Instruction for Completing Limerick Generating Station Operation Verification Form, Rev 1, March 22,1985 A-27.0, Administrative Procedure for the Procurement of Quality Related Items and Services, Rev 0, (Under Station Review)
A-27.1, Administrative Procedure for procurement of Coded Q-Listed Items, Rev 2,, June 10, 1986 A-27.2, Administrative Procedure for Procurement of Non-Coded Q-Listed Items, Rev 2, June 10, 1986 A-27.3, Administrative Procedure for the Procurement of Safety-Related Services, Rev 2, February 11, 1987 A-27.4, Administrative Procedure for Receipt Inspection of Q-Listed Items, Rev 3, March 24, 1985 A-27.5, Administrative Procedure for Preparation and Approval of Receipt Inspection Requirements for Q-Listed Items, Rev 1, October 30, 1984
ATTACHMENT A Cont.
.
A-27.6, Administrative Procedure for Establishing Procurement Codes for Q-Listed Items, Rev 0, March 9, 1984
-
A-27.7, Administrative Procedure for Designating Q-Listed Items as Catalog Items, Rev 0, September 28, 1984 A-27.9, Procedure for Transfer of Unit 2 Q-Listed Equipment from Bechtel to PECo Groups Other than the PECo Storeroom, Rev 3, October 11, 1985 A-27.10, Administrative Procedure for Transfer of Quality Related Items to Limerick from other PECo locations, Rev 0, February 11, 1987 A-27.11, Coding of Spare Parts for Use at Limerick Generating Station Rev 0, (Under Station Review)
3.0 Prints and Drawings QAD-M-11, Emergency Service Water, Sh 1&2, Rev 23 QAD-M-12, Residual Heat Removal Service Water, Rev 22 QAD-M-20, Fuel & Diesel Oil Storage and Transfer, Sh 3, Rev 21 QAD-M-41, Nuclear Boiler, Rev 22 QAD-M-42, Nuclear Boiler Vessel Instrumentation Sh 1, Rev 17 QAD-M-47, Control Rods Drive Hydraulic - Part B, Sh 1, Rev 17 QAD-M-48, Standby Liquid Control, Rev 14 QAD-M-50, RCIC Pump Turbine, Sh 1, Rev 18 QAD-M-76, Reactor Enclosure and Refueling Area - HVAC, Sh 1, Rev 9 QAD-M-78, Control Enclosure HVAC, Sh 1, Rev 15 E-28, Single Line Meter & Relay Diagram D114, D124, D134, 0144 Safeguard Load Center, Rev 11 E-32, Single Line Meter & Relay Diagram, Uninterruptible AC System RPS, UPS, and Computer System, Sh 1, Rev 22 E-33, Single Line Meter & Relay Diagram 125/250 VDC System Sh 1, Rev 24; Sh 2, Rev 23; and Sh 3, Rev 22 E-361, Schematic Diagram - RHR Service Water Pumps, Rev 20 E-392, Schematic Diagram - RPS Breaker Panel Protective Devices RPS/UPS System, P/ 8 E-961 Local Device laule, Sh 17, Rev 7