IR 05000352/1987022
| ML20235J474 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/21/1987 |
| From: | Strosnider J, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235J463 | List: |
| References | |
| 50-352-87-22, GL-83-28, NUDOCS 8710010460 | |
| Download: ML20235J474 (8) | |
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- U.S. NUCLEAR REGULATORY COMMISSION-
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REGION I.
Report No.
50-352/87-22
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Docket No.
50-352
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License No.
.l Licensee:
Philadelphia Electric' Company 2301 Market. Street Philadelphia,' Pennsylvania;19101 q
Facility Name:
Limerick Generating Station, Unit 1 Inspection At: Philadelphia, Pa and Limerick, Pa.
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Inspectior. Dates: August 31 - September 4, 1987
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Inspector:
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9 ?J h R. W. Winters, Reactor Engineer, M&P, EB,
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DRS, Region I
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Approved by:.
trosnider, Chief, M~aterials & Processes date
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l-ction, Engineering Branch, DRS, RI-Inspection Summary: Routine announced. inspection on August 31 -
September 4,1987 (Report No. 50 352/87-22)
Areas Inspected: Vendor Manual Control Results: No violations or devictions were ide'ritified.
8710010460 870923 PDR ADOCK 05000352 G
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DETAILS 1.0 Persons Contacted h
Philadelphia Electric Company D. Anders, Engineer, Mechanical Design Engineering Group
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- R. Brown, Engineer / Supervisory, Independent Safety Engineering Group
- J. Doering, Supt. of Operations, Limerick Generating Station j
- K. Folta, Quality Assurance Engineer
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G. Hackney, Supervisor Records Management R. King, Designer in Charge, Engineering Design. Division
- J. McElwain, Quality Assurance, Lead Auditor
- D. Neff, Compliance Engineer.
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- J. Rubert, Quality Assurance site Supervisor D. Snodgrass, Engineer, Independent Safety Engineering Group K. Young, Engineer, Independent Safety Engineering Group j
Bechtel Western Power Corporation
- A. Hill, Construction Administrator i
S. Ployhar, Senior Engineer
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United States Nuclear Regulatory Commission
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- E. Kelly, Senior Resident Inspector i
- J. Kaucher, Resident Inspector j
- Denotes those attending the exit. meeting.
The inspector also contacted other administrative and technical l
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2.0 Licensee's Actions on Previous NRC Concerns l
(Closed) Unresolved ' Item (86-03-02) Turbine Enclosure backwash Area Equipment Drain Sump Contamination.
The inspector reviewed the techniques used to collect samples from the i
sump effluent and to monitor all of the water discharged from the plant. A review of the analysis made of all water discharged from the collection tank for the drain sump during 1987 did not reveal any-radioactivity above background during this period. The plan for controlling and monitoring all water leaving the plant was acceptable.
The inspector also verified that the sumps were clearly. identified.
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This item is closed.
l (Closed) Unresolved Item (87-01-03)
Failure of the Emergency Director.
(ED) to sign the Unusual Event Notification Form in a timely manner.
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During the exercise January 15, 1987 the ED filled out but did not sign. the Unusual Event Notification Message form as required by Appendix I of procedure EP-102..This form contains the information to be communicated to various government agencies concerning the plant-status.
Subsequent to the exercise the ED was reminded of this requirement. The licensee has revised Appendix I of Ep-102 to include a requirement for the date and time signed to be entered on the form as well as the ED's signature.
In addition the licensee has emphasized this requirement in subsequent training at refresher courses. The. inspector verified that Appendix I had been revised, and that the training course outline had been modified to put additional. emphasis on this requirement.
This item is closed.
(Closed) Unresolved Item (87-01-06] The Field Survey Map-in the Technical Support Center (TSC) main display area was not maintained during the exercise January 15, 1987.
The map in the TSC is used as a backup /information display to graphically exhibit the information on the official. map in the dose assessment room.
The official map in the dose assessment room was maintained throughout the exercise by the Dose Assessment Supervisor.
l Through interviews and by reviewing training documents the inspector determined that the need for maintaining this backup map has-been
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emphasized both to the Dose Assessment Supervisor on. duty during the exercise and in the refresher training course given to individuals j
performing this function.
This item is closed.
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l 3.0 Control of Vendor Manuals and Technical Information 3.1 References / Requirements Generic Letter 83-28, Required Actions Based on Generic Implementations of Salem ATWS Events
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10 CFR 50, Appendix B, Criterion VI, Document Control 3.2 Documents / Activities Reviewed The inspector reviewed the licensee commitments -procedures and manuals as shown in Attachment I to determine the adequacy of the Vendor Manual Control program implemented by the' licensee.
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3.3 Details of the Review To determine the effectiveness of vendor manual control by the licensee, the inspector selected two purchases ~made by the licensee that required control of. vendor manuals. The first was a modi.fication to the refueling bridge, the second'was for the purchase of a spare reactor vessel head stud tensioner.
Both of
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'j these manuals had been received and processed in accordance with.
l Engineering and Research Department Procedure ERDP 6.2 and
distributed in accordance with ERDP 6.4 as required,-
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l To determine that the procedures were being fo11 owed and were l
adequate the inspector followed the processing of these manuals
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from receipt by the Design Services Section (DSS).of the
Engineering Design Division (EDD) through the review by the Responsible Engineer and distribution system to the using organizations at the site. Review and distribution to the site is performed at the corporate offices, distribution to using i
organizations on site is performed by the site Administration j
Services Organization.
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At the time of this inspection purchasing was normally performed j
by the Bechtel Western Power Corporation, the Contractor on site, j
Manuals received as the result of purchases by the Contractor l
were first reviewed by the Contractor's Project. Engineering
- i Organization then sent to the licensee for review and i
distribution as described above.
l To assure that changes to vendor manuals have been incorporated into applicable procedures the Independent Safety Engineering
Group (ISEG) is responsible for independently reviewing vendor.
I manual changes, determining the affected procedures and assuring these procedures have been revised as required.
3.4 Findings
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l ERDP 6.2, paragraph 6.3, requires that "The Responsible Engineer i
shall review all documents submitted for review for technical
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adequacy and compliance with the specifications and for agreement
with the comments submitted by the EDD".
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For the manuals reviewed as described above receipt was by the DSS and distribution was made without comment to the Responsible Engineers. During interviews with the Responsible Engineers the
inspector observed that " technical adequacy" was left to the i
discretion of the reviewer and varied between the two reviewers.
The original manual for the bridge crane was provided by the NSSS
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supplier as part of the original plant equipment..The.
modification was performed by the original equipment manufacturer that built the equipment for. the NSSS supplier. _ When the l
modification manual was received the reviewer determined it'was i
" technically adequate" for the modification and released this j
manual. This manual contained more than the information required'
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for the modification. The reviewer did not indicate what portions
.i of this manual referred to the modification and what portions of the original manual were applicable to the unmodified parts of i
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the equipment. The stud tensioner wfs'c*rdered as a duplicate of f
existing tensioners at the plant, The manual for the stud i
tensioner was similarly reviewed and found " technically
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l a de q ua '.e".
In this case the reviewqp did not determine if the
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manual was a duplicate of the manuals for the original tensioners at the plant and therefore should not become a separate mailual.
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manual.
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AfterrevieuedapprovalthemanhalsarsreturnedtotheDSSfor
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l distributioninaccordancewiththei(Imarked" uncontrolled"were applicable procedures. One copy marked " controlled" and severa sentito the Site Administration Services section for site distributicy.'The Bechtel Document Control., Center on site also'
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- pceived transmittals of the manuals.
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Th; inspector verified that the transmittal forms had been
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upendelinquenttransmittalacknowledgementsforbou! cont,(olled l
and uncontrolled manuals.
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On site distribution was controlled by 4ne Administrative'.1 S9rvices sectt:dn.
Upon receipt of t4c. v!anuals from DSS the cort / rolled manu. {s are place in the station librarf as reference
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Manuals marked uncontrolled are placeain sLtillite libraries in the plant. Users of these satellite, libraries are
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procedurally required to verify Ulat the manuals they are using are up to date by comparison w(tli'the library controlled copy.
"When. revisions are received the' Administrative Services section
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updates both the controlled manuals in the library and the
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manuals in the satellite libraries.
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The inspector interviewed members of the ISEG to determine the
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methods used tu assure that vendor manual changes are e
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incorporated into the appropriate vendor manuals. 'Iudividual
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ISEG members were a aigned to specific vendor manuals and based
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on the experience Mld training of the ISEG Engineer determined l
through reference te_ tha procedures incex which procedures were
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working documents.'g pirements werd acequately transferred to the assure the vendor r In addition the ISEG monitc h the INPO' event
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reports, and cther industry inputs.so provide adiance warnirg of l
critical items for maintenance and op.erations.
3.5 Conclusions
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Based ob the results of this inspection the licensee has adequately met his commitments to satisfy the requirements of
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Generic Letter 83-28, paragraph 2.2.2.
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The procedures describing the' review requirements for vendor manuals provide only general guidance to the reviewing' engineers.
Avoiding such' phases as " technical adequacy" and inserting specific guidance, particularly in the area of what to delete from existing manuals, would enhance the review process.
In the ISEG review if a more positive method of determining the
' applicable procedures was developed this review would not only be expedited but greater assurance that all effected procedures were found would result.
4.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or violations.
-Unresolved items are discussed in paragraph 2.0.
5.0 Management Meetings Licensee management was' informed of the scope and purpose of the'
inspection at the entrance interview on August 31, 1987.at the l
Corporate office and September 2, 1987 at the Station. The findings l
of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the September 4,1987 exit interview (see paragraph I for attendees).
At no time during the inspection was written material provided to the licensee by the inspector.
The licensee did not indicate that proprietary information was involved within the scope of this inspection.
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ATTACHMENT I
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Correspondence Reviewed
l Generic Letter 83-28, July 8, 1983, Required Actions Based on Generic
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Implications of Salem ATWS Events
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Letter, November. 10, 1983,. V. S. Boyer, PECo, to D. G. Eisenhut,.
USNRC, Response to Generic Letter 83-28 PECo, Request for Additional Information - Preliminary Review of.
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Letter, March 19, 1985, A. Schwencer, USNRC, to Edward G. Bauer, Jr.,
Generic Letter 83-28 Responses, Limerick Generating Station Letter, May 29, 1985, S. L. Daltroff, PECo, to A. Schwencer, USNRC, Limerick Generation Station - Units.1 and 2 Generic Letter 83-28
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" Required Action Based on Generic Implications of Salem ATWS Events" Le.ter, June 7,1985, S. L. Daltrof f, PECo, to Dr. Walter R. Butler,
l USNRC, Limerick Generating Station Units 1 and 2 Generic Letter 83-28
(Salem ATWS Event)
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Procedures Reviewed i
Philadelphia Electric Company J
l A-6, Revision 3, May 20, 1987, Control and Distribution of Drawings, Manuals, and Drawing Logs
l ERDP 6.2, December 17,1986, Revision 9, Procedure for Processing
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Vendor Documents j
ERDP 6.4, May 12, 1986, Revision _3, Procedure for Control of Vendor Technical Manuals
LS-A-1, May 20, 1986, Revision 1, Administrative Procedure for Review, Disposition and Monitoring of Responses to NRC IE Bulletins, IE'
Information Notices, and Division of Licensing Generic Letters
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LS-A-2, June 24, 1986, Revision 1, Administrative Procedure for Participation in Nuclear Plant Reliability Data System (NPRDS)
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LS-I-5, May 23, 1986, Revision 2, Implementing Procedure'for i
Utilization of the INP0 NPRD System LS-I-6, April 24, 1986, Revision 1, Implementing Procedure for Review, Disposition and Monitoring Nuclear Regulatory Commission IE Bulletins, IE Information Notices, and Division of Licensing Generic Letters, Rev. 0
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I NS-A-5; June 24,1986, Revision 2, Administrative Procedure for Review
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and Implementation of Operating Experience Information for Vendor Manual Maintenance NSS-I-4, A'ugust 12, 1987, Revision 6, Procedure for Review and Utilization of Operating Experience Information i
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NSS-I-5, June 12, 1987,- Revision 5, ProceCure Governing the Use of the Institute of Nuclear Power Operatior,s Nuclear Network i
Bechtel Western Power Corporation a
EDP 4.58, Revision 3, Specifying and Reviewing Supplier Engineering
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and Quality Verification Documentation NPAI 3,08, Revision 2, Engineering Review of Supplier Documentation
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Vendor Manuals Reviewed
-Vendor - Cimcorp Inc./ Par Systems l
Manual - Instruction Manual General Electric Refueling Platform j
f Vendor - Biach Industries, Inc.
Manual - 1,600,000 Pound Tensioner, Model 1-5090 i
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