IR 05000352/1989016

Insp Rept 50-352/89-16 on 890807-11.No Violations Noted. Major Areas Inspected:Corporate Engineering Group & Support Provided to Facility & Mods Performed During Plant Second Refueling Outage

ML20247E807
Person / Time
Site:	Limerick
Issue date:	09/05/1989
From:	Mcbrearty R, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247E803	List: IR 05000352/1989016 ML20247E799
References
50-352-89-16, NUDOCS 8909180009
Download: ML20247E807 (5)

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P U.S. NUCLEAR REGULATORY-COMMISSION

REGION I

t Report'N /89-15

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License No. NPF-39 Priority Category Licensee: Philadelphia Electric Company P. O. Box 7520 Philadelphia, PA 19101 Fa'cility Name: Limerick Ger,erating Station Unit 1 Inspection At: .Sanatoga, pennsylvania Inspection Conducted: August 7-11, 1989 Inspectors: i - f Rh A. Scfrearty', React 4r ngin er 'd e

" Approved by: b J. R. Strosnider, Chief,

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Materials & Processes Section, EB, DRS Inspection Summary: -Inspection.on August 7-11,1989 (Report No. 50-352/89-16)

Areas Inspected: A routine, unannounced inspection was conducted of the licensee's co'rporate engineering group and the. support provided to Limerick 1. Areas inspected included modifications which were performed during the Limerick 1 second refueling outag Results: The licensee has recently changed the engineering / modification process to' address previously identified problems that were resulting in a large number of design changes. The inspector reviewed several modification

' packages performed under the old system and found them adequate. He also

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reviewed a modification package performed under the new system and found that the modification was processed with fewer design changes. Although it has only recently been implemented, the process appears to be an improvemen PDR ADOCK 05000352 Q PDC

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l Details Persons Contacted'

philadelphia Electric Company

• S. Bowie, Auditor.- Nuclear Quality Assurance

• G. L. Englehardt, Senior Project hanager.- Nuclear Engineering Department

• C. J. Gerdes, Project Manager - Nuclear Engineering Department

• G.. M. Leitch, Vice President - Limerick Generating Station

• M.:J. McCormick, Plant Manager - Limerick Generating Station J. A..Muntz, Technical Engineer D. Neff, Compliance Engineer

• R. L. Payne, Quality Assurance Engineer I. A. Sajanlal, Engineer

• Sokso, Licensing Engineer

• T. G. Szonntag, Branch Head - Nuclear Engineering Department, Site ,

Engineering

• T. Ullrich, Project Manager - Limerick Generating Station K. J. Walsh, Technical Engineer U. S. Nuclear Regulatory Commission

• L. Scholl, Resident Inspector

• Denotes those present at the exit meetin .D Introduction On July 1,1989 a new engineering organization was established by Philadelphia Electric Company to enhance the engineering support provided to the various nuclear facilities operated by the licensee. Additionally, a new system for processing design changes and modifications'was established which empnasizes planning, control, and a collaborative effort for all the participant Packages representing modifications which were performed during the Limerick Unit I second refueling outage were selected for inspection to assess the support provided by the licensee's corporate engineering group. Those modifications were performed under the organization in effect prior to July 1, 1989, and except for one package were processed under the older syste .0 Modifications The following modification packages were selected for inspection:

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Modification #86-0974, MSRV Pilot Disc replacement.

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Modification #86-5134, increase ESW Inlet / Outlet Headers from 2" to 3" diameter and replace 2" Globe Isolation Valves with 3" Gate F . Valves for Core Spray pump compartment unit cooler ;

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Modification #87-5658, delete RHR head spray.

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Modification #89-5973, replace suppression pool temperature monitoring system resistance temperature detectors (RTDs) with RTDs that are 28" longe Modification #0974 involved substituting the MSRV 6B pilot disc material with PH 18-8M0 disc material on 50% of the main steam safety relief valve !

This was done as a result of an inservice evaluation recommended by the

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BWR Owners Group to generically qualify the substitute material as a fix for high set point drif l

Applicable procedures and specifications are listed on the Procedure /

Specification Checklist, and drawings which are affected for units I and 2 '

are fdentified on Engineering Review Requests. The modification design, safety evaluation and Engineering Work Letter (EWL) was approved at PORC

. meeting No.88-093 on 9/29/88. Minutes of that meeting state the reason >

for the modification and the fact ths.t the program was approved by the NRC and is being implemented by other utilitie The EWL, dated 8/17/88, ;

identifies the responsibilities of various groups within the licensee's organization. The Responsible Engineer is identified and an appendix to the EWL fully describes the scope of work to be performed. The purchase order invokes the PECo ]A program for services performed at Limerick. For services performed at other locatiens the purchase order invokes the General Electric BWR QA program as described in the current NRC accepted revision of Licensing Topical Report NEDO - 1120 ,

In addition to the above, applicable Codes, Standards and Regulatory Requirements are identified and the appropriate FSAR sections and tables are reference Documentation associated with the remaining three modifications was i found to be equally complete and indicated that the engineering support provided to the site was adequate for the scope of work involve !

Modification #87-5658 involved deletion of the head spray mode of the RHR system and was determined, as stated in the Safety Evaluation prepared by l the licensee, to require Technical Specification revisions, a license !

amendment and prior NRC approval. The licensee's application for the required license amendment and T.S. revisions was submitted on 9/29/88 to the NRC. The NRC approval of the modification, the T.S. revisions and the license amendment was issued on 1/11/89.

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-Modification #89-5973 is an indication of how the new system and-organization will function. The modification was started prior to 7/1/89 when the_new organization was put into place. The engineering followed the proposed new system which included the use of the Modification Team and the design review and approval proces The Modification Team is comprised;of the following personnel:

Project Manger - Nuclear Engineering Department staff member assigned to the site

• PECo Engineer

• Operations representative - site

• Construction representative

• Station System Engineer

• A/E representative

• Modification Coordinator After the Site Modification Management Group, comprised of senior plant staff, approves the conceptual design, The Modification Team responsi-bilities include a review of the conceptual design, selection of the preferred alternative, preparation of a draft project plan, definition of performance requirements, establishment of schedules and review of the draft safety evaluation. The team responsibilities are fulfilled at meetings which are scheduled at various stages of work progress. A final meeting may be held upon completion of the modification to_ discuss problems that may have arisen, and ways to improve the proces The documentation associated with mod 5973 showed evidence of more thorough prior planning and review in that fewer changes to the original concept were needed than were associated with the earlier package The licensee has compared the new method for processing modifications with the old method and has observed an approval rate by PORC for first time issue of modifications of over 92% compared to a first cycle approval rate of 60% prior to use of the new system. Rework and field revisions have decreased approximately 65% under the current method of processing modification Conclusions Safety Evaluations prepared by the licensee concerning modifications addressed the appropriate areas of the project and were approved by PORC prior to the implementation of associated modifications. Codes, standards and regulatory requirements were identified as was the need for T.S. revisions, license amendments and prior NRC approval of the modification as required.

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l An indicator of. a r.eed for more thorough planning ana review of modifica--

tions is the comparatively large number of changes to the' original concept L which are included in a number of the modification packages. The licensee has recognized the problem and has taken steps to correct the situatio A modification processed under the new system required fewer changes to the original des.ign than those implemented under the original syste Further evidence of improved planning of modifications is the large percentage of safety evaluations which are approved by .PORC at their first submittal, and the decrease in rework and field revisions exhibited by modifications-processed under the current syste .0 Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion.of the inspection on August 11, 1989. The inspector

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summarized the scope and findings of the inspectio At no time during the inspection was written material provided by the inspector to the licensee. The licensee did not indicate that proprietary information was involved within the scope of this inspection.