IR 05000353/1987099
| ML20246A351 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/21/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245F620 | List: |
| References | |
| 50-353-87-99-01, 50-353-87-99-1, NUDOCS 8905080239 | |
| Download: ML20246A351 (28) | |
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FINAL SALP. REPORT:
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I U.S. NUCLEAR. REGULATORY COMMISSION
REGION I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE ,
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INSPECTION REPORT S0-353/87-99 PHILADELPHIA ELECTRIC COMPANY $
LIMERICK GENERATING STATION- 1 UNIT 2 4
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ASSESSMENT PERIOD: AUGUST 1,1987 - DECEMBER 31, 1988 i
SALP BOARD MEETING: FEBRUARY 22, 1989 l
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aTABLE DF CONTENTS Page l 1 ' INTRODUCTION'. . . . . . . . . . . . . ... . . . . . . . . . 1
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. - Purpose and Overvie . . . . . . . . . . . . . . . . . 1 SALP Board Members. . . . . . . . . . . . . . . . . . . 1 Licensee Activities . . . . . . . . . . . . . . . . . . 1 3_ Direct Inspection and Review Activities . . . . . . . . 2 I SUMMARY OF RESU LTS . . . . . . . . . . . . . . . . . . . . . 3 Overview. . . . . . . . . . . . . . . . . . . . . ... 3 Performance Summary . ................. 3 II CRITERIA . . . . . . . ... . . . . . . . . . . . . . . . . . 5 IV . PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . 7 . Construction. . . . . . ................ 7 Engineering / Technical Support . . . . . . . . . . . . 10 C .- Preoperational . Testi ng. . . . . . . . . . . . . . . . . 14 Safety Assessment / Quality Verification. . . . . . . . 17 SUPPORTING DATA AND SUMMARIES. . . . . . . . . . . . . . . 21 Enforcement Activi ty. . . . . . . . . . . . . . . . . 21 Investigations and Allegations. . . . . . . . . . . . 21 . Management Conferences. . . . . . . . . . . . . . . . 21 Construction Deficiency Reports . . . . . . . . . . . 22 Tables Table 1 . Inspection Hours Table 2 - Enforcement Summary Table 3 - Construction Deficiency Reports Table 4 - Limerick Unit 1 SALP Performance Summary
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- : INTRODUCTION
^ Purpose and Overview The Systematic Assessment of License'e Performance (SALP) is an integrated NRC staff effort to collect observations and data on a periodic basis and to evaluate licensee performance. The SALP process is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to improve the quality and safety of plant operation An NRC SALP Board, composed of the staff members listed in Section B, met on February 22, 1989 to review the collection of performance observations and data to assess the licensee's performance at the Limerick Generating Station Unit 2. This assessment was conducted in
- accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section III of this repor This report is the SALP Board's assessment of licensee's safety performance at the Limerick Generating Station Unit 2 for the period August l' 1987 through December 31, 1988. The summary findings and
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. totals reflect a 17 month assessment perio SALP Board Members Chairman S. Collins, Deputy Director, Division of Reactor Projects (DRP)
Members R. Gallo, Chief, Operations Branch, Division of Reactor Safety W. Butler, Director, Projects Directorate I-2, NRR E. Wenzinger, Chief, Project Branch 2, DRP J. Linville, Chief, Projects Section 2A, DRP R. Clark, Project Manager, NRR R. Gramm, Senior Resident Inspector, Limerick Unit 2 i Other Attendees (Non-votina) i R. Fuhrmeister, Resident Inspector, Limerick Unit 2 T. Kenny, Senior Resident Inspector, Limerick Unit 1 Licensee Activities Over the course of the assessment period the project has been in a transition from the construction to the preoperational test phase Bulk construction has been completed and systems were turned over for
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component and pmoperational testing. Plant' labeling, pipe-insulation, painting, and other system: completion activities are still in progres The~ reactor pressure vessel hydrostatic test was completed on February 22, 1988, eight months ahead of the scheduled date. The electrical and instrumentation portions of the component testing phase began in October 198 The PEco staff was extensively reorganized during'the assessment period. On November 1,1987, Mr. John Kemper was elected Senior Vice President-Nuclear with responsibility to oversee the Unit 2 construc-tion and startup activities. In March 1988, the former president retired. Also in March 1988, Mr. Joseph F. Paquette was electe President and Chief Operating Officer and Mr. Corbin A. McNeill was elected to the position of Executive Vice President-Nuclear. Later in April 1988, the former PECo Chairman of the Board and Chief Executive Officer retired and Mr. Paquette was elected to fill those position PEco has contracted with Stone and Webster Engineering Corporation to perform an independent design and construction assessment. The assessment was initiated in May 1988 and is ongoin Direct Inspection and Review Activities Two NRC resident inspectors were assigned to the site during the assessment period. The total NRC inspection time expended during the 17 month assessment period was 5,597 hours0.00691 days <br />0.166 hours <br />9.871032e-4 weeks <br />2.271585e-4 months <br /> or 3,951 hours0.011 days <br />0.264 hours <br />0.00157 weeks <br />3.618555e-4 months <br /> on an annualized basis. Distribution of these hours by functional area is depicted in Table A summary of enforcement activities is provided in Table The inspections have included the NRC Nondestructive Examination van inspection, inspection of preoperational test activities and operator examinations for dual unit licensed personne The conduct of the Stone and Webster Engineering Corporation independent assessment program has been closely inspected by NRC personnel. A confirmatory site inspection was conducted by the NRC of as-built hardwar The NRC construction inspection program is approximately 95% complete, a level commensurate with the plant status. NRC review of pre-operational test procedures and conduct of test witness activities has been performed in conjunction wit the startup program. Areas to be inspected prior to license issuance include Loss of Offsite Power l (LOP), Integrated Leak Rate (ILR) test witness, review of the power ascension test program, and review of operational readiness for a
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~II. . F$tN4ARY DF ^RESULTS
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- Overview The licensee has effectively managed the transition from the construction to the preoperational test phase. System completion and turnover activities have been well controlled and performed by experienced personne The preoperational test program has been well planned and execute Test personnel have rigorously adhered to applicable test instructions. Overview by quality assurance and Test Review Board personnel has been thorough. The plant operations staff has been fully integrated into the implementation of the test progra Extensive actions were taken to augment engineering programs'in response to concerns identified in the previous assessment. The *
control cf the design reconciliation with the as-built plant has been performed in accordance with a well conceived program. Some apparently historical problems were identified with respect to items supplied by General Electric including PGCC wiring errors and design interface problems. Once identified, these issues were aggressively pursued and resolve The licensee has proactively planned and implemented the programs to determine the plant readiness for operations. These reviews have included extensive design and construction audits along with reviews of procedural and staffing readiness. The final safety analysis updates, and as-built configuration verification efforts are examples of proactive programs in which PECo management is actively and aggressively involve performance' Summary Functional Category Last Period Category This Period Area (1/1/86 - 7/31/87) (8/1/87 - 12/31/88) Construction 1* 1 Engineering / Technical 2 1 Support
- Preoperational Testing 1 Safety Assessment / *** 1 Quality Verification Assurance of Quality 2 N/A
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- Construction areas:of: containment,' safety related ' structures, soils and foundations; piping systems and supports; safety related components-mechanical; auxiliary systems; electr.ical . equipment' and cables; and
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instrumentation and controls were individually assessed. All were rated Category ,
- Area not rated due to limited amount of inspection and test activit ***New functional area this period, replaces previous Assurance of Quality area.
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-III. MRITERIA I Licensee. performance is , assessed in selected functional areas; depending L on whether the facility is in a construction or operational phase.
l Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each '
functional area: Assurance of quality, including management involvement and control; Approach to the resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Construction events (including response to, analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows: Category Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC 4ttention may be appropriat . Category Licensee management attention to and involvement in the performance of nuclear safety or safeguards activit.as is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal level . Category Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirement Licensee
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Trend: The SALP Board may decide.to include an appraisal of the performance trend of a functional area. Normally, this trend will only be used when both a definite trend of performance is discernible to the Board, and the Board believes that continuation of the trend will result in a change of performance leve Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Licensee performance was determined to be declining near the close of the assessment perio l
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'1V. 3 PERFORMANCE ANALYSIS Construction (3,277 hours0.00321 days <br />0.0769 hours <br />4.580026e-4 weeks <br />1.053985e-4 months <br />; c59%)
The previous assessment of construction activities was that management control and oversight had been maintained over all major construction activities. The site work force was very knowledgeable and highly motivated to produce good workmanship. 'Close involvement of field engineering personnel and thorough quality oversight contributed to the good performance noted during the previous assessment perio During this assessment perivJ construction personnel continued to demonstrate their knowledge and cognizance of installed systems within their jurisdictio Instrumentation craft were typically provided work packages for instrument tubing installation which contained
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appropriate sketches and specification criteria to guide'the routin Excellent verbal and written communications between the craft and engineering personnel facilitated the installation process. Quality control personnel were found knowledgeable of inspection criteria and installation requirements. Cooperation among site personnel was highly visibl The licensee has established an effective program for administration of the Pre-service Inspection (PSI) program. A system was developed to accurately track the completion status of required examination The PSI weld identification and surface preparation was performed in a conscientious manner attributable in part to the quality of onsite craftsmen training. The certification and training program for personnel assigned visual inspection tasks was excellent. One weak area involved the fact that practical tests performed by the inspectors were performed with_unflawed specimens. The licensee revised the practice in response to the concern raised by the NRC. The licensee has maintained an aggressive oversight of the program including a 100% review of the contractor PSI data. Although not a regulatory requirement the licensee dedicated sufficient resources to assure that the PSI program was staffed with experienced professional personnel which formed the foundation of the good implementation phas Review of plant records relative to electrical cable installation noted the documents as complete and retrievable. Personnel responsible for handling the records were knowledgeable and well trained. The quality assurance audits were found thorough and the nonconformance dispositions technically soun A defective diesel generator power output cable was found during a megger test. Coordination of engineering and quality assurance was goed in obtaining a replacement cable. The difficult cable repull based upon the raceway configuration and the cable minimum bend radius was satisfactorily performed based upon good engineering planning and !
the exercise of proper controls during the cable pull process.
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2 0ne: notable exception to:an otherwise effective program was maintenance activities improperly performed on the standby diesel generators as an abrasive compound was not properly removed after the bearings were reworked. The improper maintenance was caused by the lack of written procedures and cleanliness acceptance criteria to guide the bearing rework. One additional preventive maintenance concern arose when untimely corrective action was initiated by Bechtel to protect the top cover of the reactor pressure vessel to prevent particulate intrusion. The site organization had been awaiting a General Electric engineering disposition prior to rectifying the immediate concern of maintaining system cleanliness. When identified by the NRC, the licensee promptly established appropriate internal citanliness control measure An extensive plant labeling program was initiated during this assess-ment period. The labels are provided for piping, duct, instruments, valves and other components. Information regarding process flow direction, system identification and unit identification are provide Appropriate quality control involvement existed during the labeling process. In conjunction with the labeling program a coordinated facility painting program was implemented to provide rapid differen-tiation of Unit 2 rooms. The dedication of extensive licensee resources to these areas is indicative of a commitment to achieve operational nuclear plant safet NRC inspection of the Power Generation Control Complex (PGCC) cabinet panel wiring identified discrepant conditions. These involved a few improperly labeled and terminated wires and were typical of PBCC wiring problems found at other sites. This was found to be factory wiring accepted under the General Electric quality program which had not been reinspected onsite. As a result of the NRC finding the licensee embarked on an extensive onsite reinspection of all PGCC panels by Bechtel and GE personnel to identify, analyze and correct the dis- j crepancies that were found. Further discussions on the reporting '
aspects of this issue can be found in section V.D. of this assessmen A comprehensive system turnover process was implemented for turnover from construction to startup. The program involved hardware and software reviews by personnel representing quality, construction, engineering and startup organizations. Additional documentation of turnover boundary drawings, equipment lists, turnover procedures and QC inspection reports were generated to facilitate control and accuracy of this proces Site construction activities continued to be guided by the use of pre planned work packages that describe the scope of work and applicable installation criteria. As exemplified by the installation activities on the feedwater spargers, personnel were appropriately trained, quality monitoring personnel were actively involved and engineering personnel were present in the field to verify proper installation, i
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i .The site work force staffing levels.tarre appropriate for.% 74mses of work activities. Overtime was controlled for personnel ein all parts of the organization. . Discussions with licensee personnel have found I them to be well trained, highly experienced and technically knowledgeabl Summary Construction activities have been well controlled, guided by use of i work packages and close field engineering involvement. Experienced I management provided active overview of construction program implemen-tation. Weaknesses identified during the inspection reviews were determined to be isolated cases. The system turnover program was effectively performed and the status of construction completion is accurately known by the licensee. Licensee personnel, including contractors, were found to be highly experienced, technically know-ledgeable and well trained to carry out their work activitie Conclusion Category 1
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The main conclusion of the prev.ious SALP report with regard to
> engineering activities was that more management attention was needed to better assure effective' programs are implemented in the areas of control of design information at organizational interfaces and the i accuracy of FSAR information. The licensee initiated numerous actions
! as discussed below in response to the these observations and recom-L mendations. During this assessment period these actions have included l a variety of initiatives to augment engineering programs and to
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address areas of weakness. This assessment addresses predominantly Bechtel engineering effort A joint review was performed by Bechtel and General Electric of their design interface controls. . As a result of this review, the system for controlling these interfaces has been modified to improve communications between these organizations and control the design interfaces. Also, independent, multidisciplinary engineering reviews have been performed on selected design changes, design interfaces and potential construction. problem areas. These actions appear to be effectively assuring the continuity of requirements through the design and installation process. Several errors identified by the hRC during.this assessment period are attributable to problems that occurred previously in the General Electric and the Bechtel engineering
and design interface. These errors included ambiguous designation of component quality level, and incorrect redundant reactivity control logic-drawings and wiring. Extensive licensee reviews were parformed to determine the scope of the problems. Where additional problems were uncovered, appropriate engineering dispositions were rendere Actions have been taken to review, verify, and evaluate the accuracy with which the FSAR reflects the current plant configuration and to ver.ify the translation of FSAR code commitments into site specifica- ,
tions. Through these initiatives the licensee has self identified {
and corrected FSAR inaccuracies. The licensee has established a j schedule for issuance of updated FSAR figures, designated discipline licensing coordinators to maintain cognizance of respective licensing documents and revised design change forms to assure positive verifi-cation of design changes affecting the FSAR. The licensee's organi- j zation has been sensitized by their management to the importance of j the FSAR and has established controls to ensure the accuracy of the documen An extensive Bechtel Design Closure Plan has been established to identify areas requiring reconciliation of design documents in relationship to the as-built plant configuration. Elaborate computer data bases and sssociated documentation derived from as-built configurations provide assurance that structural integrity has been maintained for the containment liner plate, building steel and ,
reinforced concrete. Personnel were technically knowledgeable of
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-l 4 e the program and enhancements that were imple:aented to the similar Unit 1 program A major program for independent verification of the Limerick' 2 design
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and construction activities was initiated by the licensee and closely monitored by the NRC during this assessment period and is still in progress. Stone and Webster Engineering Corporation (SWEC) was selected to perform the assessment. SWEC developed review plans based upon the FSAR, design specifications and site procedures. The review plans were generally thorough in scope and were expanded wherever necessary in response to minor NRC concerns. SWEC selected very experienced personnel to perform the design review. The details and questions raised within the SWEC finding reports reflect the depth and scope of the SWEC review. This program involves a significant commitment of resources by the licensee and is considered an excellent initiative that to date has provided a high level of confiderice in the quality of design and construction at Limerick The ongoing NRC inspection of the SWEC assessment has confirmed the plant construction and the adequacy of program implementation to dat Several examples were found where licensee reviews for deportability were'either poorly documented or non-conservative. NRC review and questioning of issues such as the use of zinc in lieu of malleable iron conduit couplings and.the non-safety related fire protection flow switch trip of the standby diesel generators resulted in several meetings, and additional testing and analyses in order to substantiate the original licensee conclusion regarding deportabilit None the less, in both cases, the discrepant hardware was replace When the NRC questioned the review of design defects in core spray l system wiring, the reviewer revealed that additional information was available, and had been used to support the conclusion that the defect was not reportable. Bechtel, during re-review of an old item involving motor operated valve high current trip on instant 'eous reversal concluded that no hardware modifications were necessary, but recom-mended that plant operating procedures be amended to preclude simultaneous stroking of more than one containment isolation valv pEco engineering concluded that no measures were needed. This non-conservative approach to reporting has shown recent improvements due to licensee responses to NRC initiative ,
The licensee has an effective program for assuring proper environmental qualification of components and equipment. The engineering organization has implemented a program to update the equipment qualification packages with more detailed checklists and additional documentatio Post inspection site walkdowns were performed by technically competent personnel to ensure that all elements of the site installation conformed with the seismic and environ' mental qualification require- j ment _ _ _ _ . _
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added to the scope of the licensee's Nuclear Quality Assurante section audit: plan. Action items for engineering are the responsibility of
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Bechtel Power Corporatio Licensee audits of. design documents have been implemented to verify that field changes have been properly incorporated into the design documents. Bechtel quality and engineering organizations were found to promptly disseminate infor-mation, regarding offsite identified design problems, for internal investigation. Examples include a computer code error and concerns regarding the logic for motor operated valves. The above observations indicate an effective program for assuring the quality of engineering activitie A unique Design Process Improvement Program has been instituted by Bechtel engineering. On a bimonthly basis, engineering managers meet to review recently identified issues. Quality Assurance audit findings are analyzed and any associated corrective actions are disseminated to key personnel. Internal engineering assessment results are also .
presented. This program represents an innovative approach for Bechtel to perform introspective reviews of the engineering progra Philadelphia Electric Company (PECO) management is actively involved with the planning and implementation of the construction of the plant. This was evident by management participation, review, and approval of short and long range construction schedules and weekly work plans; the review of work progress and approval of changes in the workscope. The licensee has assigned key individuals to monitor and coordinate day-to-day work by Bechtel. The audit and surveillance function of the licensee is extensive and effective to control the work of contractor The licensee developed a comprehensive list of differences between Units 1 and 2. The list appears to accurately document the differences between the units and has been valuable for providing input to the licensed operator differences training. The training process was well defined and-included classroom instruction, plant walkthrough training and simulator instruction. Appropriate exami-nations were administered by the licensee to effectively screen the unprepared candidate The effectiveness of the licensee training was demonstrated by the fact that the 60 candidates, currently licensed on Unit 1, that successfully passed the licensee examination also passed the NRC administered examination. The candidates that did not pass the licensee administered examination were promptly removed from their Limerick 1 licensed duties until remedial training and/or other corrective actions are completed. This is indicative of a conservative management approach toward plant safet l
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Bechtel engineering has effectively supported licensee activities with regard to technical and engineering support for plant
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construction and preparation for operation. Efforts have been i
responsive to the concerns raised in the previous SALP. Major i, actions were instituted to assure the accuracy of FSAR information.
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The process of reconciliation of the as-built plant versus the design documents has.been performed in a careful methodical natur Initiatives such as the independent design and construction
. verification program have confirmed a high quality of design and construction for Limerick 2. While the reporting evaluations were performed in a less than satisfactory manner early in the assessment, the process has improved due to implementation of ongoing licensee initiatives. Extensive effort was expended to maintain accurate knowledge of the plant differences and the impact upon plant operations. The operator training for dual unit licenses was performed in a thorough manner which resulted in excellent examination score Conclusions Rating: Category 1 Board Recommendations None
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l Pewoperational Testino (L290 hours;'23%) j This functional area consists of the. initial equipment calibration and component tests.(Blue Tag tests) preceding-preoperational system 1 tests, and preoperational test activities, including procedure generation, review, and. approval, and performance'of the~ testin '
.This area was not rated for Unit 2 in the previous SALP perio The' administrative: procedures for the preoperational test program 'li were reviewed at the beginning of the assessment period, and
. periodically throughout the period,.by NRC inspectors. The test ;
program was based upon the successful Unit 1 test program, modified 1 to include. lessons learned. During the assessment period, several-issues were raised by the inspectors as a result of NTOL experience at other sites regarding control of measuring and test equipment, communications with shift-supervision, and the lack of verifiable test records from component. testing used to satisfy the optional ,
steps of preoperational tests. In each case, the administrative !
procedures were. revised, and training was conducted for all test startup QA and startup QC personnel on the. change The Reactor Pressure Vessel Code Hydrostatic Test was well planned and executed. The preplanning and attention to. detail by bot I Bechtel and PECo was evidenced by the heat stress screening and training program which was. conducted to ensure safety of personnel-during the test and by.the planning of the pressure boundary walkdown by 11 teams. The' team composition included craft personnel, quality control inspectors, quality assurance inspectors and authorized nuclear inspectors / authorized nuclear inservice inspectors as appropriate. Thorough quality control involvement and quality assurance oversight was present during all test phases as evidenced-by Bechtel review of quality documentation, and the conduct of careful system ralkdowns during the tes On the whole, there has been good communication and cooperation between the startup personnel and other work grou The Startup Group managers have instilled'ps, including in the group Quality an attitude of Atsuranc working together with the quality organization to ensure that the work is performed and documented correctly. This has at times led to minor delays in testing while procedure changes were processed and witness points worked out, but has at the same time ensured that all the requirements were me The startup program has applied state-of-the-art vibration monitoring to the initial operation of mechanical equipment. This has led to the identification and correction of minor deficiencies which could have affected equipment service life. Examples include the rebalancing of the generator for the 'D' standby diesel generator, Residual Heat Removal pump bearing replacement, and modifications to the foundations r of the Turbine Enclosure Cooling Water Pumps. These baselin'e data initiatives will also be useful for future predictive maintenanc I l
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L cActivitiescof ;the 7est ReviewiBoard (TIB) tsum toen assessed, incianHag l procedure reviews, . pre: gram reviews:and test vesults aview; The - - '
( Test Review Board provided detailed technical aviews of preoperational
- test procedures and ensured that all regulatory requirements and FSAR it commitments-were satisfied in the procedure. This review.is guide by a Regulatory Review List which is based, in part, on a key-word
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search of the'FSAR,' generated by the TRB. The TRB, on its own L initiative requested Nuclear Quality Assurance to perform a review of .
L its activities which led to recommended ways in which the TRB activities L could be. enhanced. The TRB instituted a number of the recommendations, D including' formalizing review procedures used by the TRB'to ensure better documentation of the procedure reviews. performed. :The TRB meetings were'noted to be conducted in a professional manner and a questioning attitude regarding procedure technical adequacy and testing philosophy was evidence that the TRB was functioning as an independent organizatio The Startup Group has been utilizing personnel from the station i Operations Group for performing many tasks in the tests. This enhances the knowledge and training of the operators on the Unit 2 equipment, as well.as.provides feedback on equipment performance to )
.the test engineers. An example of.this feedback was the retuning of i theigovernors and' regulators for the Unit 2 Emergency Diesel i Generators:to make the response more closely resemble that of their
' Unit 1 counterparts, even though the governors and regulators were initially within acceptable tolerances. Many of the test procedures are intentionally based on the corresponding Unit 1 test. procedure This-helped to incorporate the lessons learned at Unit 1 into the Unit 2 program. In _ addition, a large percentage of the test engineers have participated.in the. Unit 1 test program, which helps to bring the lessons learned at Unit 1 into the unit 2 test progra Further, ,!
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the test personnel have often performed similar or identical tests on the identical Unit I equipment. These initiatives, in addition to ,
the inclusion of the system designers and_ equipment vendor represen- i tatives in the initial equipment operation contributed to the successful ;
completion of preoperational test i Summary A significant inspection effort of field activities conducted by NRC has found the testing to be performed in a controlled manner, with a conservative approach, with quality program personnel in evidence for major steps and restorations. The initial review of tes' results found the documentation satisfactorily assembled. Outstanding test exceptions and problems are appropriately identified to engineering-for evaluation and resolution. Work activities are performed in accordance with applicable guidance and regulations. Appropriate monitoring of test performance and system / equipment post-test res-toration is provided by the Quality Organization. Good working
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z relationships between .the various work groups'-(Startup,' Field Engineering, Instrumentation and Controls, Quality Control and Quality ,
Assurance), along with the management-instilled attitude of. performing '
the job correctly the first time have provided an effective smooth running test progra Conclusion Category I'
Board Recommendation None
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LD. FSafety Assessme rt/ Duality; Verification (Inspection Hours'. Included in 0ther FunctieaaTTr'eas During the previous assessment. period the area of Assurance of-Quality'was rated Category 2. Areas'of strength included site-staffing and extensive quality assurance monitoring and surveillance activities. Concerns regarding the control of the design interface area were. identified. The resumption of project construction activities was noted to be controlled in a suitable manne '
The PECo nuclear organization has been substantially revised. One key facet of the organization. change was'the consolidation of the ;
multiple quality assurance / control groups that. existed previousl l'
P Additionally, the reporting relationship of the quality assuranc . general manager was elevated within the PECo organization and the roles of the Independent Safety Engineering and Performance-Assessment groups were incorporated into quality assurance. These
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measures have strengthened the ability of quality assurance to
' identify and analyze quality issue .
PEJo has-proactively' performed assessments'to determine the state of
'the Unit 2 readiness for operations. These initiatives include the Readiness Program Assessment, the Operational Readiness Verification
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and the. Independent Design and Construction Assessment. These 1 reviews have included examination of programs, processes, documentation i and. hardware. The focus of the reviews is to examine Unit 2 readiness with respect to licensing commitments in the area of facilities, training, operating practices and programs as well as verifying the adequacy of the plant design and construction. These extensiv multi-layered reviews-provide an appropriate framework to ascertain the. operational.' readiness'of Unit 2. The previous Unit 1 SALP was issued for the assessment period from February 1,1987 through April 30, 1988. Table 4 provides the performance summary for the operational areas that will be common for Unit 2 after license issuanc In response to concerns identified in the previous SALP, PEco quality assurance has increased the frequency and scope of technical audits of engineering activities. These audits have been effective in ;
' identifying some areas of weakness in the appitcation of the design control program The'11censee has been very sensitive to information disseminated in NUREG-1275,~ Volume 1, regarding new plant operating experiences. A detailed review was performed of the recommendations identified in the. report in relationship to site practices. A presentation was
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made to the Nuclear Review Board documenting the Limerick startup program fulfillment of the identified recommendation Factors such
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, as searly involvement ofx the plant operations >staffswere fully e implemented during:the test program. A verification effort was established for quality assurance to check the implementation'of the recommendations. Subsequently NUREG 1275, Volume 2, on plant air systems was similarly reviewe The resolution of NRC open inspection items has been aggressively
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reviewed by PECo. Management attention was apparent in this area as 1 reflected by the dedication of several personnel to coordinate the tracking and documentation of corrective actions. Few closeout packages have been returned as a result of NRC review. One isolated shortcoming was noted in the corporate commitment tracking effor Measures are being instituted by PECo to enhance this syste Plant safety committees have been closely monitoring Unit 2 activitie As examples, in depth investigations were performed after several plant evolutions caused water spills during Unit 2 test activitie The Plant Operations Review Committee convened a special meeting to review the circumstances of the spills, the intended corrective actions at J the ramifications upon Unit 1 operations. The Nuclear Review Board has raised concerns regarding design deficiencies that have been identified on Unit 2 that also impact Unit I and has received presentations from licensee engineering on that subjec PORC and NRB have successfully functioned to monitor Unit 2 activities and assess their impact on Unit The licensee has established several mechanisms to address worker concern Either an exit interview is conducted with employees leaving the jobsite, or a followup registered letter was sent to the employee to solicit identification of quality problems. NRC review of selected concerns indicates that quality assurance personnel perform appropriate investigations of the identified concerns. A quality assurance hotline is available for all employees to address concerns. The licensee systems appear effective in providing resolution of worker problems through normal organizational channels, handling of exit interview quality concerns and a high degree of worker job satisfactio On July 1,1988cPECo instituted a new fitness for duty policy requiring drug' testing for all employees with unescorted access. The policy includes random tasting in the future and strong disciplinary actions for involvement sith illegal drugs. Additional deterrents include the use of specially trained dogs to search the sit Allegations regarding fitness for duty questions have led to thorough investigations and reinspection of potentially affected hardwar The licensee has aggressively pursued a program to minimize fitness for duty problems onsite.
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' Recent industry problems have identified cases.of out of specification material-supplied to nuclear pro.iects. PECo' quality'
, assurance had pitviously implemented a long_ standing , sampling program to compare material physical and chemical aspects against the i specification requirements. The testing las included items such as fasteners, structural steel and raceway components. This additional verification beyond normal receipt inspection practices has demon-strated a conservative proactive approach toward nuclear safet Bechtel has implemented recent industry guidance regarding the handling of commercial grade components. A procedure was developed to guide component dedication and extensive research was performed to identify currently installed commercial grade components. This new srogram is intended to prevent recurrence of a problem where commercial grade conduit couplings were supplied with incorrect certification During this assessment period operations personnel were assigned to man the Unit 2 control panels. A full time shift supervisor and reactor operator were dedicated to perform control room functions during the course of pre-op testing. The shift supervisor was involved-in pre-test briefings and was observed to question test methodology to ensure that Unit I was not adversely affected or that potential problems such as reactor vessel draindown would not occur. A new position of Shift Startup Engineer (SSE) was established to coordinate startup activities and to act as the liason between the operating crew and startup test personnel. These measures served to ensure early involvement of the operating staff and to have a single individual maintain overall cognizance of daily test activitie On May 19, 1988, PECo initiated a comprehensive Independent Design and Construction Assessment (IDCA) at Limerick 2 to compliment the Readiness Verification Program. The assessment is being performed by an independent contractor, Stone and Webster Engineering Company (SWEC) under contract to PECo. The NRC has conducted team inspections at SWEC's Cherry Hill, NJ offices and on site to monitor (1) preparation of the review plan and (2) implementation of the review plans and construction assessment. Overall, the teams found that the SWEC assessment was comprehensive and met the IDCA program requirements. While both SWEC and the NRC teams found a number,of minor discrepancies, no major design or construction problems were identified. Overall, the quality of construction at Limerick 2 was found to be excellen Efficient processing of the application for an operating license -
especially during the last six months of the process - requires ( intense involvement by the applicant. The FSAR needs to be updated l to accurately reflect and be current with the as-built plant. The Technical Specification (TSs) need to be finalized. Any changes
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h requimd in the TSs forethe operating unit to pemit tie-in of the r :second. unit need to be processed and issued in . time to incorporate l l'
the same changes in the proposed.TSs for the license. All open ,
items for licensing need to be resolved and addressed in an NRC 1 safety evaluation report supporting issuance of an operating licens In this respect, there are some areas where the applicant's attention to the staff's needs for information in support of the license appli-cation would be helpful. For example, there has been considerable delay in responses to some NRC initiatives such as closing out generic and multiplant issues. The late receipt of an assessment of design changes has impacted NRC review of FSAR revisions and thus preparation of the NRC's safety evaluatio Summary The PEco reorganization strengthened the ability of Quality Assurance to identify and analyze safety issue The licensee has implemented major self-assessment programs to assure the readiness for operation of Unit 2. Safety review groups have actively monitored the conduct of preoperational tests and preparations for operation. Proactive measures have been taken in the area of surfacing worker concerns and identifying discrepant materials supplied to the site. The licensee has been extremely responsive to concerns identified by the NR Conclusion Category 1-Board Recommendation None t.
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9 ' SUPPORTI91G IRTA RND SUMERIES Enforcement Activity l
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No escalated enforcement actions or confirmatory action letters were issued during the assessment period. A synopsis of the issued ,
violations is shown in Table l On October 22, 1987, an enforcement conference was held to discuss the evaluation of the licensee's significant deficiency report regarding the fire protection flow switch circuit design. The licenste committed to remove the standby diesel trip input from the switche * Based upon-the existing design criteria, the NRC agreed with the >
o licensee's position that the matter was not a reportable ite Investigations and Allegations During the assessment period routine inspection followup was <
performed in response to the allegations identified below:
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(RI-87-A-0118): Alleged that a construction superintendent used
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illegal drugs. The employee admitted drug use and was terminate ; Management Conferences September 8, 1987 - Meeting held between PECo and Region I to f- discuss the power ascension test program. The planned program was compared with respect to other recent BWR startup program PECo committed to amend the planned testing to include control rod drive scram time testing at intermediate pressure . October 9, 1987 - Meeting held to discuss the interaction of the fire protection flow switches and the standby diesel genera 6'r . April 21, 1988 - The new PECo president met with the Region I Regional Administrato . May 13, 1988 - Meeting between PEco, Region I and NRR to discuss the Readiness Verification Program. An Independent Design and Construction verification initiative was proposed by PEC < May 24, 1988 - A followup meeting was held between PECo, NRR and Region.I to further discuss the independent design and construction assessment activitie . October 31, 1988 - A meeting between PECo and Region I to discuss the plant status and planned tie-in outage with Unit .__ - _ _ _ - - _ _ _ _ _ _ ____
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7f November 2; 3988>- A eneeting between PEto and?NRR to @scuss the plant status and planned tie-in outage with Unit ~ Construction Deficiency' Reports General ,
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During the assessment period 15 potential construction deficiencies l were reported by PEC Four reports were subsequently determined to be non-reportable based upon-additional licensee investigatio .
The licensee has demonstrated an increased sensitivity to the
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handling and evaluaaion of 10CFR50.55(e) items, since the last SALP assessment. T,1e corrective measures and associated inves-tigations are thoro;gh. A tabulation of the 11 construction deficiency. reports by functional area is provided in Table I 2. i Causal Analysis Seven of eleven Construction Deficiency Reports (CDRs) were attributed to offsite manufacturer problems. These related to L wiring ~and termination errors, snubber overgreasing, and bus bar material. problems. These issues were generally identified through site testing activities. Equipment failures brought the bus bar problems to. light and NRC inspection identified the
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discrepant PGCC wirin One CDR was caused by the failure of site personnel to install polyvinyl chloride insulated wire in accordance with the design restriction Two CDRs involved design errors that caused Appendix R safe shutdown deficiencies. These were identified during the course of extensive Unit 2 reverification of the safe shutdown design analysi One CDR arose during the preoperational test program when the the NRC requested to review the bases for the suppression pool water test level. Licensee engineering found that some non-conservative assumptions had been made in the original analysi .. :...
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i C _.-____m______m__m_____._m-___ _ _ _ _ _ . _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ - . _ . _ - _ _ . _ _ _ - __- _ _ _ _ _ . _ _ _ _..._m-. ___d
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i TABLE 1 m /InspectionHours-Summary i;
Limerick Generating Station Unit 2 i
August 1, 1987 - December 31, 1988
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Functional Area Hours % of Time
~ Construction 3,277 59
' Engineering / Technical Support 1,030 18 Preoperational Testing 1,290 23 Safety Assessment / Quality Verification *
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TOTAL 5,597 100
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- Hours expended in the area of safety assessment / quality verification are 1 included in other functional area !
-The period includes NRC inspection reports 87-12 through 88-2 !
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Enforcement Summary Limerick Generating Station, Unit 2 August 1, 1987 - December 31, 1988 Number of Violations by Severity Level *
Functional Area IV i Subtotal Construction 3 2 5
.- Engineering 2 1 3 Preoperational Testing 0- 0 0 Safety Assessment / Quality 0 0 0 Verification TOTALS 5 3 8
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- No escalated enforcemen*, actions were imposed during the assessment perio s
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b ? TABLE 3
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Construction Deficiency Report
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Limerick Generating Station, Unit 2 August 1, 1987 - December 31,'1988
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Cause Codes Functional Area A B C D E F G Subtotal
' Construction 1 3 4 Engineering- 3 3' l
~ Preoperational. Testing 3 1 4
. Safety Assessment / Quality Verification TOTALS 1 3 3 4 11
. Cause Codes A. Personnel Error B. Design Error External
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m Procedure Inadequacy
. Component Failure
'l Fabrication Error o Other a,.
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I ITABLE '4
. - Performance Summary Systematic Assessment of Licensee Performance I i' ^
Limerick Generating Station, Unit 1 February 1, 1987 - April 30, 1988 Are Category Piant Operations 1 Radiological. Controls' 1
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C'. Maintenance 1 Surveillance 1 Engineering / Technical' Support 2 Emergency Preparedness 2 Security and Safeguards 1
' Safety Assessment / Quality Verification 1-(
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