IR 05000353/1988026

Insp Rept 50-353/88-26 on 880927-30.No Violations or Deviations Noted.Major Areas Inspected:Corporate Emergency Support Program,Staffing,Training,Mgt Support & Communications

ML20207K815
Person / Time
Site:	Limerick
Issue date:	10/06/1988
From:	Chaudhary S, Strosnider J, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207K808	List: IR 05000353/1988026 ML20207K805
References
50-353-88-26, NUDOCS 8810170039
Download: ML20207K815 (10)

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l U.S. NUCLEAR REGULATORY COMMISSION REGION !

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Report N /85-26

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Docket N License N CPPR-107 Licensee: Phil_adelphia Electric CoTpany 2301 Mar 6et Street PiiilRe_1p hi ad'enn syl v a ni a Facility Name: Lirerick Generating Station, Unit 2 I Inspection At: Sara:oca uPottstoyn_, and PhiladelpM aa Pennsvivania Inspection Dates: September 27-30 J 953 Inspectors: M_ en 5,A.Crauchhy,45eniorReactorEngineer,

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PPS, EB, ORS, Region I

-- b: S U R. W. Winters, Reactor Engineer, MPS, EB, date-CRS Reaton Approved by: )g 5

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. 5trosnicer, Chief, Materials & Processes date ection, dngineering Branch, DRS, RI

.I n sp e c t i op_S u yy : Routine unannounced inspection on September 27-30,1933 (Report No. 50-353,'.5-26)

Areas Inseected: Tne inspection covered the Corporate Engineering support program, for Limerick Unit Areas inspected ircluded organization and staffing, training, ransgevent support, and cormunicatiens. The inspection focused on the prograrratic aspects of the engineering organizatio Results: No violations or deviations were identifie DR ADOCK 05000353 PNV

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r 1.0 Persons Contacted i

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Philadelphi( Electric Company f

G. Bell, Superintendent Audit Section

• J. Corcoran, Manager Quality, Limerick Generating 5tation ,

• 0, DiPaolo, Superintendent, Unit 2 Quality Assurance  !

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J. Evans, Superintendent, Engineering Support Section l

{ * R. Taust, Quality Assurance Engineer ,

i * 0. Helwig, Gtneral Manager, Nuclear Quality Asturance  :

) * G. Lauderback, Startup Quality Control Supervisor i

J, O'Rcurke, Manager, Quality $upport Division  !

• R. Stipcevich, Unit 2, Project Engineer

] hehtel Power Corporation j i i I V. Aggawar, Group Supervisor, Architectural and $tructural f

{ * T. Chapman, Group Lead l

1 S. Cleaver, Group Supervisor, Electrical l t J. Drowley, Grcup Supervisor, Mechanical

{ * M. Drucker, Quality Assurance Engineer l

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j C. Haynes, Group Supervisor, Plant Design

L. Metcalf, Quality Engineer, Construction [

j ** R. Palaniswamy, Unit 2, Project Engineer l

K. Patel, Engineering Super.isor i

l R. Slaughter, Resident Engineer, Quality Engineering f j

K. Stout, Quality Control Engineer j i I j United States Naclear Regulatory Commission _ i

• R. Fuhrmeister, Resident Inspector  !

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R Gram.?, Senter Resident Inspector

• Denotes those attending the exit meetin '

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The inspectors also contacted other ad?inistrative and technical  !

j personnel during the inspection, 2.0 Ogective  ;

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The eb.h':tive of this inspection was to assess t.he adequacy of the i l lic' _ e's engineering program for cesign control, interf aces with other

inn enal and xternal organizations, management support., staffing levels

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and experience, training, and responses to NRC requirements and request The docurents reviewed during this inspection are listed in Attachment ,

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< 3.0 Introduction  !

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i Limerick Generating Station, Unit 2, is in the final phases of I construction. Approximately 95*. of the construction is complete and l

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l preoperational testing of the completed systems is in progress. The }

l construction of this generating station is organized on the classical I I construction management techniques i.e. the licensee as the owner has j l

contracted architectural engineering services with Bechtel Power i Corporation, and Bechtel is providing construction services. Additional products and services are provided by subcontractors either directly to

the licensee or through Bechtel. However, Bechtel is responsible for all engineering and construction services and the licensen exer

tses management overvie i

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i 4.0 O_rget z a t ion l The inspectors reviewed the licensee's organization to determine the structure, levels of responsibility and interfaces with other groups.

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Based on the above review and discussions with licensee management i 4 personnel the inspectors determined the following:

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Tne engineering responsibility for Unit 2 design is assigned to the i i

licensee's architectural engineering consultant, Bechtel Power f Corporation (BPC). BPC provides comprehensive design and i l construction service i

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The licensee's in-house engineering organization exercises a I A

monitoring function and general technical overvie I

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BPC's engineering group is organized on the basis of cla>sical engineering disciplines. Each discipline is headed by a supervisor  ;

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who ib responsible for the technical adequacy of the groups work,  !

The supervisors report to a Project Engineer who exercises technical and triagement controls over the entire engineering effort for the ptuject.,

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The administrative, ano engineering procedures ranuals establish the managerent controls to assure technical adequacy of the work. These

, procecures have been reviewed and approved by the licensee. In some j instances the licensee has imposed additional requirements over i CPC's standard procedures.

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The licensee also has a p'oject engineer assigned to the project who

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performs a liaison function between the licensee's engineering and j BPC's project engineering organizatio The licensee inforced the inspectors that an organization and l staffing plan is being developed to assume the engineering

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responsibilities from BPC after the completion of construction to j support the operations phase of the plan l

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5.0 staffing i The inspectors reviewed the staffing levels and experience of the personnel assigned to various disciplines by BPC. Based on these reviews  !

and discussions with cognizant personnel the irspectors determined that:  !

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The Unit 2 project engineering organization of BPC current'y l consists of approximately 160 administrative, professional and management personne i

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The majority of the professional personnel are degreed engineers I with an average of approximately eight years of experience, l

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Theprojectengineerinformedtheinspectorsthatthestaffinglevel  !

in the BPC engineering office is declining due to the project s i nearing completion, i

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The licensee's engineering organization has assigned system l engineers currently working on Unit I to follow the same systems on  :

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BPC calls upon the specialized expertise from the San Francisco l cffice when requirud. The Environmental Qualification program is handled by the $an Francisco office due to the specialized nature of this progra ,0 Co munications

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The inspectors reviewed the interface cent,rols and procedures within the BPC organization, within t,he licensee's organization, and between the l licensee and EPC, Eased on these reviews and discussion with engineering  ;

and management personnel the inspectors determined the following: l

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The interf aces among disciplines within BPC is controlled by engineering procedures appreved by EPC ennagement and the license The liceasee's internal administrative controls establish interface procedures within the organization. These procedures have been approved by management and are the same for the entire coepan EPC holds weekly meetings on the project to review and resolve any interdisciplinary problems or concerns. This meeting also establishes priorities for t,he near term wor The licensee atteads this eeetin T u re is a weekly meeting held between the EPC engineering and construction /preoperational t,est organizations to review the status of scheduled work, engineering support required ard to resolve any identified problems. The licensee also attends this meeting.

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Monthly, BPC presents a comprehensive project status report to the r licensee's higher nanagement. This report is presented during a meeting held at the site generally in the last week of the mont The report includes detailed information regarding cost and !

schedule, problem areas, regulatory status and milestones reache !

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The licensee has developed a comprehensive list of differences [

between Units 1 and 2. This list was initiated as a management tool :

to minimi:e and control the differences between the two units, ease l maintainability and support operations. The list also was found to l be a useful guide in the reactor operator training program. The t inspectors reviewed the list and concluded that it is a good i initiative by the licenset to develop such a co prehensive list to I document the differences between units, because such a list is also ;

valuable during the operations phase of the plant by providing ready references for maintenance and surveillance planning, operator ;

training, engineering, and modifications, j i

f 7.0 Workload f l

The inspectors reviewed the work currently in progress and scheduled in i BP Based on these reviews and discussions with cogni: ant personnel the I inspectors determined that:  ;

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The majority of the work currently perforced by the engineering [

crganization falls within a definition of minor design changes and j resolution of problems identified during the final inspections and j preoperational testin *

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The priority of the work is dictated by the preoperational test schedule. The systems scheduled for test first have the highest priorit J

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Records are coatrolled by the BFC Document Control Group and a !

cceplete set of engineering records are kept both in the engineering -

office and at the site. For accessiM11ty, the engineering office is staffed minimally during the night shif l

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Trackirg of the work backlog is accomplished by type of item, !

large bore pipe or small bore pipe. Currently the work is on !

schedule including preparation of as built drawings. For large bore j pipe 6t5 of 730 cesign calculations have been reviewed, for small i bore pipe 317 of 375 design calculations have been complete l

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Design reviews are accorpitsbed by independent reviewers in the sa're I group as the original designe j

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The workload is c:eclining cue to the near co oletion of the projec For example, civil and st.ructural work is ecre than 90'. complete, pipe supports ircluding design verification is 99*. cceplete. The

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major workloaci is in the area of HVAC and preoperational test suppo-t, I  !

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! 8.0 t!anagement Suppen ,

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The inspectors reviewed the management provided to the engineering j organi:ation for Unit 2 by BPC and the licensee. Based on this review, .

discussions with engineers, and personal observations, the inspectors i determined the following' '

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To increase the efficiency and effectiveness of engineering and -

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design services BPC established a project engineering organi:ation !

within easy commuting distance from the plant site. This was a good management initiative by BpC and the license [

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BPC has maintained continuity within the engineering organi:ation by [

} retaining a majority of engineers associated with the design of !

Unit I for completion of Unit !

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The Computer Assisted Design Drafting (CADD) system is being extensively used for drawing preparation and revisions. Once a l i

drawing has been entered into the system and approved, revisions are l verified electronically. The CADD syster. is currently working three '

shifts to maximize machine use, and provide a faster turnaround of j drawing updates for use in the fiel j

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Engineering management also has maintained a staff of experienced i engireers under the direction of a Senior Project Engineer n BPC's ;

vadcuarters in San Francisco. These engireers provide support in [

speciali:ed areas, such as, environmental qualification and complex {

engineering analyses which the on site project engineering cannot t i perfor l l I

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The licensee has initiated a program to resolve action items j reported in the latest 5ALD Report (50-353/c6-99). Tnese actions !

items have been designed to improve perfo..wance in the areas of l engineering and assurance of quality, l

j In engineering, the actions consist of expanded review of vendor and j construction documentation 2nd design interfaces by the BPC Chief {;

Engineers in their respective cisciplines; upgrading of engineers !

t rai niro; in the end uses of design document,5; improveu nt in GE/Eechsel design interfaces; and, verification by audits of the effectiveness of these inprovetents. Additionally, actions have l been initiated to review, verify, and evaluat.e the accuracy of the t

, FSAR with the current plant, design configuratio These actions !

will include issuance of quarterly repgrt,s identifying issues and I

corrective actions neeced or ieplemente ,

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! I i i l The licensee's Nuclear 6 'iity Assurance audits of design documents !

i are planned to verify that e field changes have been properly l i incorporcted into the design u uments. A multidisciplinary team !

l (udit is planned to review design organization interfaces and the !

i vendor document review proces '

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The responsibility for design review and audits have been added to l the licensee's audit plan. The action items for engineering are the j

responsibility of BPC. The inspector was informed that these ;

{ actions in engineering have recently been implemente '

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l 9.0 qualityAssurance l l f j The inspectors interviewad cognizant personnel to deternine the extent of i 1 Quality Assurance involvement in the engineering and design proces I i Based on these discussions the inspectors determined that' '

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The BPC engineering organi:ation has established Quality Engirecring l l positions within the engineering organization to provide continual j i monitoring and oversight of the engineering and design processes.

3 In addition, BPC has resident Quality Assurance engineers located in l

. the engineering office who are part of the independent Quality l j Assurance organization, f

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Quality Assurance / Quality Control is performed by means of an audit and surveillance process by independent audits and monitoring by the i Quality Assurance organtration, j

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The Quality Assurance findings are transmitted to engineering ,

managetent for action. The correcthe actions are reviewed and

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accepted b) Quality Assurance. The response time is also specified '

by QJality Assuranc !

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Management Corrective Action Reports (KAR) are issued by Quality Assurance to escalate findings when there is a need t,o bring the problem or its resolution t,o a highet level of BPC management, j 10.0 Training and Professional Developme _

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The inspectors mbserved t, hat the professional training of engineers and other professional and te;hnical personnel is controlled and coordinated by BPC Corporate wice policies and procedures frem San Francisco. This area was not reviewed in detail. The inspectors, however, observed that the majority of the technical staff was graduate engineers, and a large nu-ter of this sp ft held professional license Also, BPC is regul:H y

, represented in professional societies, code comittees, and industry groups. Many of the engineers frem the onsite organication represent BPC 1 in t,hese co-mittees and organizations.

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j 11.0 Reporti_ng Procedures

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l j The licensee has established procedures to implement the regulatory (

l requirements for reporting to the NRC. The BPC engineering organiza. tion  :

provides technical support to the licensee on an as needed basis. During i

! the construction phase, majority of reporting falls witu n the  :

requirements of 10 CFR 50.55(e). BPC provides all analysu and evaluation  !

in this area and submits these analyses to the licensee for evaluation,  !

1 concurrence and submittal as required, t l l i

12.0 Conclusions l

Based on the above reviews and observations, the inspectors determined L that the licensee's and SPC's engineering organizations and management f controls implemented to assure the quality of the effort is adequate for i the current phase of plant rocstruction. The licensee has shown initiatives to resolve identified problems and to upgrade programs required for support of plant construction and startup.

3 13.0 Management Meetings

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I i Licensee management was informed of the scope and purpose of the j

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inspection at the entrance intervien' on September 27, 1988. The findings  ;

! of the inspection were discussed with licensee representatives during the  !

I course of the inspection and presented to licensee management at the t j 5eptember 30, 1955 emit interview (see paragraph I for attendees).

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L l At no time during the inspection was written material provided to the I i licensee by the inspector. The licensee did not indie. ate that l proprietary information was involved wit,hin the scope of this inspection.

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ATTACHMENT A  !

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DOCUMENTS REV! EWE 0

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Bechtel Power Corporation __0ccuments

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l Management Correc_t_ive Action Rep s

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i l MCAR 1-41 Revision 1. Potential 10 CFR 50.55(e) report, Lack of 'T' l Orains Within Tolerance from Motor Low Point on Valves M55-HV-2F002 and l M99 HV 2F007 l i

MCAR 1-43, Revision 0, Westingneuse Motor Starter Insulation i Engineering,0epartment Project _ Ins'.ruction (EOPI) l i

E0P!-4.1.1, Revision 6. Design Criteria Limerick Generating Station l 1 Units 1 and 2 i 1 E0PI-4,26.1, Revision 1, Interdiscip11 nary Design Review Limerick )

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Generating Station Units 1 and 2 '

E0PI-4.28.1, Revision 1, Project Q-List Limerick Generating Station EDP!-4.36.1, Revision 1, Standard Computer Programs Limerick Generating Station Units 1 and 2 i

EDPI-4.37.1, Revision 5, Design Calculations Limerick Generating Station

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EDPI-4.46.1, Revision 16, Project Orawings Limerick Generating Station l Units 1 and 2 1 -

ManagerofEngineering_ Directive _(MED)

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MEO-4.2-0, Revision 6. Generic Engineering Documents  !

l ME0-4.25-0, Revision 6, Design Interface Control

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i MEO 4.25-0, Revision 9. Project Q-List

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Engineering _ Department Precedure (EOP)

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E0P 4.2 Revision 3 Generic Engineering Documents EDP-4.25. Revisien 1, Design Interface Control E0P-4.26 Revisicn 0, Interdisciplinary Design Review E0P-4.27, Revision 0, Design Verification E0P-4.23. Revisten 2 Project Q List E0r-4.30, Revision 1, Standard Computer Programs

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E0P-4.37. Revision 4, Cesign Caled ations

! EDP-4.46 Revision 0. Project Drawings i

DesignCalculationiDO)

114.1.3, Review of Steel Eeans at Elevation 201'-0" Drawing C-195, Area 17 114.1.4, Assessment of Elevatior. 201 Area $ teel for Pipe loads

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Drawings 8031-C-195, $heet 1. Revision 26. Reactor But1 ding Unit 2 Structural I Steel Sections and Details Elevation 201'-0" 7 8031-C-195, Sheet 2, Revision 2, Reactor Building Unit 2 Structural Steel Sections and Details. Elevation 201'-0"

Other_Bechtel  !

i Limerick Generating $tation Unit 2, Project Status Review Meeting,  !

Thursday, Septe-ber 22, 198S  !

l Ph11ade.1phia Electric Corp _any

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Project Change Request Procedura, Revision 4, l t

Limerick Generating Station, Quality Assurance Prog *am, Volume 1, Design,  ;

Constru: tion, and Preoperatioral Phase, November 15, 1957 i

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