IR 05000352/1988014
| ML20151A911 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/08/1988 |
| From: | Blumberg N, Dev M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151A897 | List: |
| References | |
| 50-352-88-14, GL-85-03, GL-85-13, GL-85-22, GL-85-3, NUDOCS 8807200160 | |
| Download: ML20151A911 (7) | |
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O.S. NUCLEAR PEGULATORY : COMMISSION
REGION I
Report No.
50-352/88-14 Occket No.
50-352-License No. NPF-39 Licensee:
Philadelphia Electric Company
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2301 Market Street Philadelphia, Pennsylvania 19101
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Facility Name:
Limerick Generating Station Unit Number 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted: June 1 - 3, 1988 Inspector:
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W I
M. Dev, P, Reactor gin r
' da'te Approved by:
W N. Blumberg', Chief, Oper itional Programs
~date Section, 08, DRS Inspection Summa _ry:
Routine, Unannounced Inspection conducted on June 1-3, 1988 (Inspection Report Number 50-352/88-14)
Areas Inspected:
Review of the Licensee's. Actions on previously NRC identified concerns, and review of the conduct of the Limerick Generating Station Offsite-Review Committee (Nuclear Review Board - NRB)-.
Results: Documentation to support the licensee's review and disposition of
' the NRC Generic Letters 85-03, 85-13 and 85-22 was found inadequate. This is an unresolved issue and discussed in paragraph 3.3.1.
8807200160 880708,
PDR ADOCK 0500
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' DETAILS OF INSPECTION ~
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1.0 Persons contacted Philadelphia Electric Company (PECo)
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Limerick Generating Station (LGS) Unit 1-
- R. Brown, Supervisory Engineer,
- J. Burke,-Lead Auditor
- J. Doering,-Superintendent, Operations C. Endriss, Regulatory Engineer K. Kemper, Maintenance Engineer
- R. Mulford, Executive Assistant
- D. Neff, Compliance Engineer
- J. Rubert, Assistant Supt. Operations Audits United States Nuclear Regulatory Commission (US NRC)
- T. Kenny, Senior Resident Inspector L. Scholl, Resident Inspector
- denotes those present at the exit meeting on June 6, 1988.
The inspector also contacted other administrative and technical personnel during this inspection.
2.0 Licensee's Actions on Previous NRC Concerns (Closed) Violation'(50-352/87-25-01): Inadequate maintenance of Station Maintenance Records.
A deficiency in the station maintenance procedure-led to improper administration of 40 maintenance request forms (MRFs). Twenty four of these MRFs were found not closed on computerized history and maintenance planning system (CHAMPS) and the remaining sixteen did not receive final review and signoff six or more months after work completion.
The licensee reviewed, assembled and signed-off these maintenance packages and closed them on tia CHAMPS Administrative Procedure A-26, "Corrective Maintenance" was also revised to require closure of MRFs within six months. In addition, the licensee reviewed and verified the completion status of station MRFs, including I&C group, and found their completion in compliance to the station procedure.
Currently, the MRFs status is reported biweekly to PORC meetings, and a monthly management review report is provided to the Vice President.
Based on the review of the licensee's corrective action implentation and discussion with the cognizant maintenance engineer, the inspector
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determined that the licensee action was complete. This item is close, -. _ _
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3.0 Offsite Review Committee-Nuclear Review Board (NRB) (Module No. 40701)
3.1 Inspection Criteria / References The scope of this inspection was to ascertain if the functions of the Limerick Generating Station Nuclear Review Board were performed in accordance with regulatory requirements established in the
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regulatory requirements and the licensee's plans and procedures
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listed in Attachment-1.
3.2 Program Review The licensee's NRB functions and activities were reviewed to verify that:
Administrative controls, duties and responsibilities,
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including the composition of the committee and subcommittees are adequately defined.
-- The committee's independent review has. adequately evaluated the LGS potentially significant nuclear issues.
-- The action items and associated resolutions are properly.
reviewed, evaluated and documented.
-- The NRB meeting frequency and meeting agenda provided adequate assurance that the LGS NRB investigations and recommendations are properly implemented.
'3.3 Program Implementation and Findings 3.3.1 The licensee's charter of Nuclear Review Board establishes an offsite review board-whose purpose is to review, audit and evaluate both technical and organizational matters pertaining to the safe operation of the Limerick Generating Station, Unit 1, and to identify actual and potential problems and implement prompt and effective corrective actions. The NRB is composed of senior level individuals with diverse technical and nuclear plant operational backgrounds and operates as an advisory group to the Limerick Generating Station.
The inspector attended a NRB meeting on June 4, 1988.
All nine NRB members and their designated alternates were present at the meeting, thus providing a full quorum for the conduct of the NRB business. At the meeting the plant manager provided a report on the current plant status; significant operating abnormalities, including unplanned scrams, significant upsets, and significant personnel errors; unanticipated deficiencies in equipment, system or structures; performance
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tiends; and special topics including status of failed fuel,.the preventive maintenance program for safety / relief valves, the radioactivity level of the suppression pool, and a report on an electrician drilling through the back of an energized panel. The Board reviewed the ramifications of each item' arid suggested measures to preclude similar personnel errors and equipment
. failures, in the future.
'The inspector noted that three NRC Generic Letters: GL 85-03, Clarification of Equivalent Control Capacity For Standby Liquid Control System; GL 85-13, Transmittal-of NUREG-1154 Regarding the Davis-Basse Loss of Main and Auxiliary Feedwater Event; and GL 85-22, Potential for Loss of Post-LOCA Recirculation Capability due to Insulation Debris Blockage had responses outstanding to the NRB. Although these Generic Letters did not require written response to the NRC, the licensee's administrative procedure LS-A-1 requires review for applicability of NRC Generic Letters.
The inspector noted that no documented evidence was available to support that these Generic Letters were evaluated, and the appropriate actions were properly implemented. The licensee stated that the licensing department has been instructed to provide verification of the completion of the action items.
Pending review to determine the adequacy and effectiveness of the licensee action, this is
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considered an unresolved item (50-352/88-14-01),
3.3.2 Independent Safety Engineering Group The NRB has. delegated the Independent Safety Engineering Group (ISEG) to conduct safety evaluations under the provision of 10 CFR 50.59.
Selected safety evaluation reports (Attachment-1) were reviewed by the inspector and verified that all aspects of the regulatory requirements, as applicable, were included in the review and were properly documented.
3.3.3 QA/QC Interfaces The NRB has delegated responsibility to the QA audit group to conduct periodic audits of LGS Unit 1 operations, including requirements of the Quality Assurance Plans in accordance with Unit 1 Technical Specifications paragraph 6.5.2.8. The inspector reviewed selected QA audit reports (Attachment-1) and determined that the audits were conducted as per schedule by qualified and trained individuals, the audit scope and objectives were met, and the audit findings were comprehensive. Audit plans and scopes were adequately reviewed and concurred by the NRB prior to the conduct of these audits, in accordance with the procedure NRB-3, Audit. The results of these audits were forwarded to the NRB for review. The inspector verified that appropriate followup actions were taken by the NRB, and the required corrective actions were timely implemented by the cognizant organization.
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3.4 Conclusions The licensee's offsite review committee (NRB-Nuclear Review Board)
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administrative controls, duties and responsibilities are adequately
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' defined and implemented in accordance with the plant Technical
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Specifications and the licensee's policy, QA Plans and administrative procedures (Attachment-1). Composition of the NRB and its subcommittees, member qualification, meeting frequency and quorum were found satisfactory. Review of the previous NRB reports indicated that the Board evaluated and provided recommendations regarding potentially significant issues to the Executive Vice President-Nuclear, in a timely manner. The NR3 had assigned to its members and-subcommittees the significant nuclear issue action items based on t'leir qualification and expertise.
The NRB also has maintained and updated periodically the status of these action items, including their implementation.
Based on the review of the licensee NRB meetings minutes, discussion with the cognizant NRB members and licensee management, and attendance to the NRB meeting, the inspector determined tha.t the licensee NRB functions and activities are adequate and satisfactory.
However, the inspector noted that in one instance, the NRC Generic Letters 85-03, 85-13 and 85-22 and the associated action items completion were not properly documented to support their implementation.
4.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violations.
One unresolved item was identified and discussed in paragraph 3.3.1.
5.0 Management Meetings The licensee management was informed of the scope and purpose of this inspection at an entrance meeting conducted on June 1,1988. The findings of the inspection were discussed with the licensee representatives during the course of this inspection. An exit meeting was conducted on June 3, 1988 ( see paragraph 1.0 for attendees ) at which time the findings of the inspection were presented.
At no time during this inspection was written material concerning inspection findings provided to the licensee. The licensee did not indicate that any proprietary information was involved within the scope of this inspectio "
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ATTACHMENT 1 Documents' Reviewed:
e 1.0 Procedu'res/ Reference (Paragraph 3.1)
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10 CFR 50.73, Licensee Event Report System.
LGS Technical ~ Specifications, Section 6, Administrative Controls, August, 1985.
LGS Final Safety Analysis Report, Chapter 13, Conduct of Operations, Rev 51, 1988.
ANSI N18.7-1976, Quality Assurance for the Operational Phase of.
Nuclear Power Plants.
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements
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Licensing Section Procedure LS-A-1, Administrative Procedure for Review, Oisposition and Monitoring of Responses to NEC IE Bulletins,
'IE Information Notices, and Division of Licensing Generic Letters, Rev 1, May 20, 1986.
Charter of Nuclear Review Board, Revision 11, May 23, 1988 (Including various NRB procedures)
Quality Assurance Division Audit Program, QADP6, Revision 12, March,
1987 ISED-I2, Implementing Procedure for Review of Safety Evaluations, Revision 1, May 3, 1988 A-26, Procedure for Corrective Maintenance, Revision 13, February 23, 1988 AG-21, Plant Incident Tracking System, Revision 0, December 3, 1987 Memorandum, Independent Safety Engineering Division Safety Evaluation Review for the Nuclear Review Board
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Attachment'l
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2.0 Safety Evaluations (Paragraph 3.3.2)
Mud 86-5392,-Testing of New and used Charcoal Absorbent Mod 87-5326, CR0 Cooling water Plug Replacement-Mod 87-5032, Core Spray and HPCI Feedwater Injection valve Actuators Replacement MDCP-614, SGTS fan capacity Increase and Connection to the Refueling Area 3.0 Audits (Paragraph 3.3.3)
AL87-158 PL, LGS Triennial Fire Protection Program,-December 16, 1987 AL87,-49 PL, LGS Offsite Radiological Environmental Monitoring Program, May 20, 1987 AL87-159 PL, LGS Emergency Plan and Implementing Procedures, December 18, 1987 AL87-164 MI, LGS Calibration and Control of Portable Measuring and Test Equipment, December 29, 1987 AL87-170 S0,. LGS Unit 1 Full Power Limiting Conditions for Operation, December 4, 1987 AL37-185 PR, LGS Corrective Action Program, December 30, 1987 SL88-03 PL, LGS Fire Protection Plan Associated Open Items and Quality Concerns ( Surveillance ), February 26, 1988 Independent Review of the Limerick Generating Station Emergency Planning per 10 CFR 50.54(t) by Emergency Planning Services, December 11, 1987
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