IR 05000353/1989007

Insp Rept 50-353/89-07 on 890126-0203.No Violations, Deviations or Unresolved Items Noted.Major Areas Inspected: Licensee Programs That Identify & Control Specific Differences in Design & Const of Both Units

ML20248H826
Person / Time
Site:	Limerick
Issue date:	04/03/1989
From:	Blumberg N, Drysdale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20248H796	List: IR 05000353/1989007 ML20248H793
References
50-353-89-07, 50-353-89-7, NUDOCS 8904140234
Download: ML20248H826 (10)

Text

{{#Wiki_filter:,

  *
 ?.
. ;

U.S! N CLEAR' REGULATORY COMMISSION

'     ' "

REGION'I

  . Report No; '50-353/89-07 Docket N License No. CPPR-10 Licensee: PhiladelphiaLElectric Company 2301 Market Street Philadelphia, Pennsylvania 19101-

> Facility Name: Limerick Generating > Station, Unit 2

     '

Inspection'At: . Limerick,. Pennsylvania-Inspection Conducted: January 26 - February 3,1909 h .. I n spector : [[/- [ Mu P. Drysdale', ~ Reactor Engine (r '

      /J date"
       &'
  -Approved by: [M  fu d A'  [[
   .N. Blumberg,' Chief, Operati4nal Programs dite Section, Division of Reactor Safety Inspection Summary: Inspection on January 26 - February 3,1989 (Inspection Report No. 50-353/89-07)

Areas Inspected: This was a routine unannounced inspection of certain licensee programs that identify and control specific differences in the design and construction of Limerick Generating Station (LGS) Units. Material ~ Control, Maintenance, and associated QA programs for Unit 2 were reviewed to assess the extent to which they comply with the LGS QA Plan and the " Readiness Assessment Program'for Limerick 2". These programs were also assessed to determine the extent to which they are being integrated into counterpart programs functioning within the plant operating organizatio ' Results: The inspector found that Material Control, Maintenance, and QA , programs associated with plant differences are being effectively managed in that the current and ongoing turnover of Unit 2 systems and equipment is providing the plant operating organization with functioning programs which will support two-unit operation. This turnover is currently proceeding ahead of schedule and is placing increased demands on the LGS plant staff resources during the current refueling outage. The inspector expressed concerns that increased QA monitoring and management oversight may be necessary to ensure that operational support for Unit 2 systems is adequately maintained after turnove No violations, deviations, or unresolved items were identified during this ! inspection perio F 8904140234 DR 890404 ADOCK 05000353 PDC

- _ - _ _ _ _ - _ _ _ .

meg -

 ' "
,3] *
,m.

!

,

gy .: l;, ,

, ,

M, DETAILS f ~1.0. Persons Contacted i

 ~

1 1.1 Philadelphia Electric Company

  -R. Chester, PECo QA, Unit 2 J.~ Cooney, Manager, Consolidated Open Items List  q
  *D. DiPaolo, Superintendent, PEco QA, Unit 2  )
  *G. Edwards,-Transition Manager,' Operations Program  1
  *R. Hinojosa, PECo'QA, Unit 2-D. Kelsey, Startup I&C Preventive Maintenance Coordinator
  * Lauderback, QC Supervisor, Unit 2 Startup
  *A. Shapik, Supervisor, Material Control-R. Stipcevich, PECo Project Engineer, Unit D. Thompson, Branch Head, Plant Equipment Configuration
  * Ullrich, Startup Manager,-Unit 2
  *R. Weigle, Superintendent, Startup Operations  ,
  *B. Wells, Bechtel Materials Control Manager  -
  *C, Wyler, Superintendent, Material Control  .

g , 1.2 United States Nuclear Regulatory Commission R. Gramm,-Senior Resident Inspector, Unit 2

  *R. Fuhrmeister, Resident Inspector, Unit 2 T. Kenny, Senior Resident Inspector, Unit 1  j
  * Denotes those individuals who were present at the exit meeting on 1 February 3, 198 q 2.0 Objective The' objective of this inspection was to assess certain licensee programs which identify specific design, construction and material differences between LGS Units 1 and 2; and to ensure in the final state of Unit 2 construction that the management of material control, maintenance, and associated QA programs adequately recognize and assimilate unique hardware differences between Units 1 and 2 during the transition to two-unit operatio .0 Organization (Module 36301)

The inspector examined the major organizational . features, programs, and j

 . relationships between the Unit 2 architect-engineer (Bechtel), the Unit 2 )

Startup Division, the LGS Plant Division, and site QA to the extent that ! each is concerned with material control, maintenance, and QA during the transfer of responsibilities for Unit 2 systems and equipment to the LGS Plant Division. This effort started near the end of construction and will proceed through preoperational testing and power ascension into full two-unit commercial operation. Particular inspection emphasis was placed , upon a review of programs which address and control unique differences in j the design,. construction, maintenance, and operation of Units 1 and j l l

_ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _

-
. ,

> -
 ,
,

These programs were assessed to. ensure that all identified differences have been accounted for and that appropriate management controls are established and effectively track the on going efforts to integrate these

 . differences-into the existing material control and maintenance programs that are administered by LGS Plant Division and monitored by the corporate and site QA group The principle tracking mechanism for Unit 2 transition activities at LGS is the " Unit 2 Readiness Assessment Program" (RAP). This program provides,a listing of specific action items assigned to each functional group (Material Control, Startup, Plant Operations, Maintenance /I&C,   'l
 > Quality Assurance, Licensing, etc.) and presents a planned schedule fo the accomplishment of each task. The inspector reviewed this program in
 . detail and observed that specific tasks associated with plant difference ~s   !

have been assigned to the Material Control, Maintenance /I&C, and QA groups. These- tasks include . development of a Plant Differences List, a , detailed Unit 2 Equipment Qualification (EQ) List, and a listing of Unit 2 l Equipment and Spare Parts Differences. The inspector observed that these RAP action items are being implemented into LGS Plant programs through efforts of the Plant Transition Group.under the direction of the

,_ -Transition Manager. .The Transition Manager coordinates all activities of
 'this group to ensure that plant differences affecting material control and maintenance are fully recognized and turned over to the LGS Plant Staff in a timely. manner which will support two-unit operation. He also-ensures that Transition Group activities are coordinated with-the needs of key events in the Unit I refueling outage; with the tie-in of shared Unit 1 and Unit 2 systems; and with the Unit 2 approach to fuel load, power ascension, and commercial operatio The inspector also reviewed the Consolidated Open Items List (COIL) which has been recently revised and expanded into a comprehensive senior-management tool for continuous tracking of outstanding work items associated with key events in all areas related to operational readiness of Unit 2 and the transition to ful'1 two-unit commercial operation at LG The inspector observed that the expanded COIL now includes the results.of audit findings growing out'of the " Unit 2 Readiness Verification Program" (RVP) conducted by the Nuclear Quality Assurance (NQA) Department. It was also noted that the COIL now contains the " LGS Unit 2 NRC/NRR Open Items List", and a U sting of outstanding. actions associated with unique plant difference The inspector concluded that the organizational programs and relationships between the Unit 2 architect-engineer, the Unit 2 Startup Division, and the LGS Plant Division have functioned effectively to ensure an orderly and efficient transition of Unit 2 systems from construction and startup to commercial operation. Unique hardware differences between Units 1 & 2 systems have been identified in the material control, maintenance and QA organizations to the extent that will ensure each unit can be maintained and operated as designe i

______z____.__._.__ _ _ __ _

  -  -- _- -_ .
   -

g .

   -
    .
   -

e L . 4. ' -

l' 4.0 Material Control (Modules 35743, 35744, 35746, 35747, 35748-and 42400) 1:

    ~4.11 ' Construction. Spare Parts Procurement
.t-The Unit 2 spare. parts program was implemented early in the construction phase partly due to the anticipated procurement times involved in long lead item This effort was initiated by the Bechtel~ Construction Group and resulted in development of a comprehensive spare parts list for Unit 2-consisting of approximately 4600 items. Bechtel Construction initiated the procurement of Unit 2-
    . spare parts through their procurement program which has been approved by PECo'under the criteria established for " approved suppliers."

Thus, material and, spare parts during Unit 2 construction were purchased under a Bechtel system and were not within the LGS purchas-ing program operated for Unit 1 by the LGS Procurement Engineering and Material Management Groups. Bechtel initially established two spare parts programs, i.e., Construction Spare Parts and Operational Spare Parts. The Construction Saare Parts program was scoped t provide adequate inventory for'ali unit 2 needs from initial construc-tion.through commercial operation. These spare parts have remained dedicated to Unit 2. The Operational Spare Parts inventory was kept segregated from all Unit 1 needs throughout construction of Unit 2, however, on a case basis, an equipment exchange program allowed .

          '

Unit 2 spare parts to be transferred for use in Unit Late in the construction activity.on Unit 2, PECo and Bechtel commenced to merge spare parts procurement for both units into one program to be conducted by the LGS Materials Management Group. ~This effort involved establish-me'nt of a " Baseline Scoping Study" to determine the stock inventory levels necessary to support one spare parts program for two operating ; units. This baseline scoping study was on going during the course of ' this: inspection and was occurring in parallel with the effort to assign. new PECo Stock Code numbers to the Bechtel procured part The inspector reviewed this effort in detail to ensure that unique plant safety related material was maintained separately within the spare parts inventory. Twelve individual spare parts inventory - descriptions were reviewed to assess the segregation of unique spare i parts and the assignment of common spare part l The inspector noted that the spare parts procurement program ' implemented by Bechtel was adequately controlled to ensure that Unit 2 construction and startup needs were well satisfied without unnecessary delays or shortages. The transfer of all post-construction warehouse stock has been well coordinated and material identification and historical documentation has been well preserved. No unsatisfactory conditions were note .

          ,

l _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ l

 .
  ..
   . .
     . _ _ _ _ - _ -
.
.,

f.;

; -

'

.

>

4.2 Dedication of Commercial Grade Material  ! For more than a year preceding this inspection the procurement of nearly all commercial grade items (CGI) for safety-related . applications in both units has been the responsibility of the Bechtel Procurement Group. In anticipation of the_ eventual phase-out,of this function by Bechtel, the LGS Procurement Engineering Group has _ developed an administrative procedure which prescribes a detailed method for dedicating commercial grade procurement to safety-related applications. The inspector reviewed the draft version of AD-12 (Se'e Attachment A) to ensure that the procedure complies with the LGS 0A Plan and industry standards. No unsatisfactory conditions were noted, however, this procedure had not yet been reviewed by the Plant Operations Review Committee (PORC). The inspector also reviewed ten. safety-related procurement packages and found that'none of the ! items .had been procured as commercial material or obtained from an I unapproved. source, j The inspector noted that the LGS Procurement Engineering appeared.to be adequately prepared to assume commercial grade procurement after t .the necessary administrative controls are approved by POR . , 4.3 Receipt Inspection and Storage In the effort to cc.nbine Bechtel's Unit 2 spare parts program with the LGS spare parts for Unit 1, all material formerly stored in the Bechtel warehouse onsite was selected for removal from the site or for transfer to the PECo storehouse. This effort required the .; assignment of PECo Stock Code numbers to all items designated for transfer. Additional identification tagging was also required for those spare parts and materials which needed to be held in exclusive reserve only for Unit 2 to ensure that an adequate supply was avail-able for startup testing. .The physical transfer of this material has been occurring for approximately two years and is scheduled for completion in May 1989. The inspector observed the packaging and identification of material leaving the Bechtel warehouse (e.g., miscellaneous spare parts, replacement components, bulk consumables, etc.) and the subsequent receipt inspection upon arrival at the PECo storehouse. Particular attention was paid to observing the handling of unique plant specific material. All material arriving into the receipt inspection area of the storehouse was handled in a i manner afforded to shipments received from off-site following i approved receipt inspection methods applied to all newly arriving material. The inspector reviewed several material history packages ; for the transferred material and observed that in all cases identi-fication and traceability was well documented. Component identification l labeling was also checked and no inconsistencies were noted with the supporting documentatio The inspector toured the PECo storehouse and observed the general methods utilized for designating storage _ _ - -

- .

      - -
        ,
      ,
        .
  .
,
  -
   .

d

locations for various categories of material. Unit 2 reserved components were selected for review and were observed to be well-

     -designated from other storehouse stock. The storehouse appeared to be very well organized, maintained, and controlled. No unsatisfactory conditions were note .0 Maintenance-(Module 35743, 35745,'and 42451)'
       ~

The inspector examined-the. ongoing development of the. Unit 2 maintenance prog' ram which is primarily within the cognizance of the Unit 2 Startup Grou The' program for transition of maintenance responsibilities to the LGS Plant Division after successful preoperational testing was also reviewe The Unit 2 Startup and Transition Groups ~ are taking responsibility for

     ;

Unit 2 maintenance. activities beginning after release of-each Bechtel

   " subsystem" from its construction phase. Maintenance program development has involved;the collection of corrective maintenance (CM) history from
   ~the construction phase, establishing a preventive maintenance (PM)'

program (including written procedures), and establishing maintenance tracking systems (e.g. component history and maintenance planning system, the preventive maintenance baseline, and the surveillance test system).

PM procedure development has required that unique Unit 2 systems be reviewed.and individual PM procedures written to address those systems and equipment which'cannot be covered under a common procedure for the corresponding' system in Unit 1. Likewise, this need for Unit 2 specific maintenance procedures generated a requirement to review and upgrade all Unit 1 procedures to reflect unique hardware in Unit 1 and to establish a uniform maintenance program for both units. This effort was ongoing during this inspection period, however, the necessary maintenance history and PM requirements were being documented and included in the turnover package for each system as maintenance responsibility is passed to the LGS Plant Division. The inspector reviewed several unique PM procedures for Unit 2 to ensure that individual plant differences are adequately addressed and that replacement parts, repair procedures, etc. were

   . properly specified to reflect the appropriate level of uniqueness. In addition, the inspector noted maintenance program features still under development, such as:
   *

establishment of a comprehensive list identifying unique Unit 2 equipment; due for completion by June 198 * establishment of a Unit 2 Component History and Maintenance Planning System (CHAMPS) database; due for completion by May 198 *- development of the Unit 2 Preventive Maintenance baseline program; due for completion by May 198 .. _ _ _ _ _____._-___.____-_m-___ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - * . .

_-_____ _ .

.
.
.

 *

establishment and implementation of the Unit 2 Equipment Qualification (EQ) program for Maintenance /I&C groups; due for completion by June 198 The inspector reviewed the turnover plan for Unit 2 systems to determine how responsibilities for maintenance are conducted and monitored. This tri.asition is basically structured in three phases as follows:

   -Organization Maintenance (PM&CM)

Phase and Division Responsibilities I. Pre-Op. Testing Unit 2 Startup Perform PM&CM activities LGS Plant Provide Technical Support II. Interim Phase Unit 2 Startup Schedule and Control after system PMs& cms , turnover LGS Plant Perform PM and CM activities and daily system operator rounds III. Power Ascension Unit 2 Startup Schedule and Support PMs& cms LGS Plant Perform and Control PMs& cms The inspector concluded that the maintenance programs for Unit 2 are being well developed and planned for an orderly transfer of responsibility to the LGS Plant Division. This transfer was noted to be occurring in a timely manner which will support the current Unit 2 startup and power ascension schedule with actively functioning maintenance programs in place. However, the inspector expressed concerns to the licensee that increased management attention and QA monitoring efforts may be warranted in view of the fact that most LGS Plant organizations will be heavily focused upon the demands of the Unit I refueling outage. Licensee management acknowledged that Unit 2 system maintenance requirements cannot be sacrificed during the outage period and agreed that potential schedule conflicts between the Unit 1 outage, the Unit 2 startup, and their common tie-in must be closely monitored to ensure that all activities are conqucted in a satisfactory manne .0 Management Meetings (Module 30703) Licensee management was informed of the purpose and scope of this inspection at the entrance interview on January 27, 1989. The inspection findings were discussed with licensee representatives throughout the inspection period and the results were presented to licensee management at the exit interview on February 3, 198 _ _ _ _ - . _ _

 -
.
 '
 -
 .
 . .

B At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involved at any time during the course of the ; inspectio ,

       '!
       !
       !
       !
       !
       ,
       :

i

       !
       ;

t_.____.__.____._.._.__

_ - _ _ .

, ;; ^

'

 ,
 ,
-.    -ATTACHMENT A DOCUMENTS REVIEWED 1.0 Bechtel Construction' Documents CP-D-2, Equipment Substitution, Transfer or Replacement CP-F-4, Procedure for Construction /Startup Spare Parts for Limerick Generating Station Unit .3 CP-F-7, Procedure for Field Evaluation, Procurement and Control of Commercial Grade Items for Use In Safety Related Applications for LGS-I .4 CP-F-8, Procedure for Equipment Qualification Replacement Parts Review for Limerick Generating Station, Unit 2 2.0 Limerick Unit 2 Programs 2.1 Readiness Program Assessment for Limerick 2 2.2 Limerick Generating Station, Unit 2 Licensing Plan 2.3 Limerick 2 Readiness Verification Program (RVP) Description 2.4 Description of Equipment Qualification for Limerick Generation Station Unit 2 2.5 Limerick Unit 2 Transition of Responsibilities 2.6 Turnover Guideline, 2/1/89 3.0 PECo Administrative Documents 3.1 A-25, Preparation of Preventive Maintenance Procedures 3.2 A-25.1, Preventive Maintenance Program 3.3 A-26, Appx. 6, Instructions for Completing the LGS Parts List A-27.1, Procurement of Coded Q-Listed Items 3.5 A-27.2, Procurement of Non-Coded 0-Listed Items A-27.4, Receipt Inspection of Quality Assured Items A-27.6, Establishing Procurement Codes for Q-Listed Items 3.8 A-27.9, Procedure for Transfer of Unit 2 Quality Assured Items from Bechtel to PECo Groups Other than the PECo Storeroom I
      \

I l I l

    ,- . - . - - - - - - - - _ _ --

_ - . - - _ _ - .

., ..

~ ' Att'achment A
.

.'

I 3.9 A-129.2, Classification and Engineering Evaluation of Items and 1 Services - (Draft)  ! 3.1D A-129.3, Commercial Grade Dedication Activities (Draft) i

        !

3.11 A '29.5, Receipt of Items (Draft) ] 4.0 Tracking System Programs 4.1 Unit 1/ Unit 2 Differences List, 1/20/89 4.2 Plant Staff Unit 2 Readiness Assessment Program, 1/27/89 4. 3 Unit 2 Spaca Parts Program, 1/13/89 4.4 Consolidated Open Item List (COIL),1/26/89 anu 2<3/89 l l l l

1 l J I ' ___ h }}