ML20137G874
| ML20137G874 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/08/1986 |
| From: | Chaudhary S, Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20137G864 | List: |
| References | |
| 50-352-85-47, IEB-80-07, IEB-80-13, IEB-80-7, NUDOCS 8601210305 | |
| Download: ML20137G874 (10) | |
See also: IR 05000352/1985047
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/85-47
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Docket No.
50-352
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License No.
Licensee:
Philadelphia Electric Company
2301 Market Street
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Philadelphia, Pennsylvania 19101
Facility Name:
Limerick Generating Station Unit-1
Inspection At:
Limerick, Pennsylvania
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Inspection Conducted: December 2 - 6, 1985
Inspectors:
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M. Dev, Reactor Engineer
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Approved by:
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Dr. P.K. Eapen, Chief
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Quality Assurance Section
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Inspection Summary:
Routine, unannounced inspection conducted on December 2-6,
1955 (Inspection Report No. 50-352/85-47)
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Areas Inspected:
Licensee's action on previous NRC concerns, Facility Design
Changes and Modifications and response to License Conditions. The inspection
involved 58 inspection hours by two region-based inspectors.
Results: No violations were identified.
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DETAILS
1.0 Persons Contacted
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R. Brown, Engineer Supervisory (NSS), PECO
- C, Endriss, Regulatory Engineer, PECO
- F. Hunt, QA Engineer, Bechtel
G. Kelly, QA Engineer, Bechtel
- K. Kemper, Engineer Supervisory (MODS), PEC0
J. Law, Outage Engineer, PEC0
G. Leitch, Plant Manager, PECO
J. Lubinsky, QA Engineer, PECO
- J. Spencer, Superintendent - Plant Services, PECO
- V. Warren, Test Engineer, PECO
U.S. Nuclear Regulatory _ Commission
- E. Kelly, Senior Resident Inspector, Limerick Generating Station, Unit-1
- P. Eapen, Chief, QA Section, Region I
The inspector also contacted other licensee and contractor technical and
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administrative personnel during this inspection.
- Denotes those present at exit meeting held on December 6, 1985.
2.0 Licensee's Action on Previous NRC Concerns
(Closed) Inspector Follow Item (352/84-43-01): The Itcensee was required
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to develop Inservice Inspection (lSI) program to include inspections for
BWR Jet Pumps (IE Bulletin 80-7) and Core Spray Spargers (IE Bulletin 80-13).
The licensee has developed procedure LIM-VTI-2, Supplement C, Rev. O,
" Inservice Visual Examination of RPV Jet Pumps and Shroud Annulus" with a
provision to conduct " Ultrasonic Examination for the Jet Pump Holddown
Beam" in accordance with LIM-UTI-14.
The licensee has also developed procedure LIM-VTI-2, Supplement J, Rev. O,
" Inservice Visual Examination of Core Spray Headers & Spargers and Feed-
water Sparger Assemblies.
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The licensee has incorporated these procedures in " Limerick Gene"ating
Station Unit-1, First 10-Year Interval Augumented Inservice In<pection
Program", Specification 8031-P-501, Rev. 1.
The inspector reviewed these
procedures and had no further questions.
Based on the above, this item is closed.
(. Closed) Deviation (50-352/84-29-03):
This item pertains to missing refer-
ence marks on welds for UT examination as committed to in the FSAR. The
licensee had marked approximately 80% of the welds in PSI program. The
remaining welds were to be marked during ISI examination. The ISI plan
(specification P-501) has been issued to establish weld center line re-
quirements. Also, the NOE contractors procedure for marking datam points
has been revised.
This item is closed.
(Closed)UnresolvedItem(50-352/85-16-011: This item pertains to lack of
specific criteria for the evaluation of torsion in steel members. The 11-
censee has revised specification C-115 to particularly emphasize the analy-
sis for torsion. The specification still does not provide any specific
method and/or criterion for torsion analysis.
It may not be possible to
develop a specific analysis / design method for evaluating torsion and/or
the need for stiffness because many analytical methods, ranging from finite
elements, vendor recommendations, standard practice, and evaluation based
on previous analysis may be required for analysis and design for torsion.
An appropriate method must be selected on a case by case basis depending
on the complexity of design. A predetermined method on criterion established
by specification may be unduly restrictive, and in many cases, may even be
inappropriate.
This item is closed.
.(_ Closed)UnresolvedItem(5_0-352/84-48-011:
Feedwater check valve analysis.
The inconsistencies in the feedwater check valve slam analysis have been
resolved by a new analysis.
The inspector reviewed this new analysis for
technical adequacy and acceptability of analytical methods. The inspector
had no further questions in this regard at this time.
This item is closed.
License Condition 2.C.(3).d:
The licensee condition required the licensee
to provide a stairway for fire brigade access from the turbine building to
the Unit I cable spreading room and the static inverter room, prior to
start up, following the first refueling outage.
The inspector verified
that a temporary access from Elevation 239'-0" turbine building to the
Unit 1 cable spreading room Elevation 254'-0", has been erected. This
stairway will remain in place until a permanent stairway is constructed. A
notice to this effect has been posted on the stairway. This item will be
reviewed and dispositioned by NRR.
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License Condition Attachment 1 and Item 1 to License NPF-39: The license
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condition required the licensee to complete the modifications to the liquid
nitrogen vaporization facility and the containment inerting system describ-
ed in the licensee's letter dated September 26, 1984. The inspector veri-
fled that the nitrogen system modification (IE Bulletin 84-01), including
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tetting has been completed as addressed in the NRC Region I combined in-
spection reports 50-352/85-25 and 50-353/85-06, dated June 25, 1985.
Sub-
sequently, the licensee informed NRR regarding completion of this item,
through the letter dated November 22, 1935. This item will be reviewed
and dispositioned by NRR.
LicenseCondition2.C.(71: The license condition required the licensee to
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submit the ISI program by October 26, 1985, for NRC staff review and ap-
proval.
The inspector verified that the licensee has submitted the program
for NRC review and approval.
This item will be reviewed and dispositioned
by NRR.
License Condition 2.C.(8):
Salem ATWS Event, Generic Letter 83-28: The
license condition required the licensee to implement its commitments
applicable to Generic Letter 83-28. The inspector reviewed the adequacy
of the licensee's actions for the following items:
A.
Actions 3.1.1 and 3.1.2. post-Maintenance Testing (Reactor Trip
lystem Components)
Position
Licensees and applicants shall submit the results of their review of
test and maintenance procedures and Technical Specifications to
assure that post-maintenance operability testing of safety-related
components in the reactor trip system (RTS) is required to be con-
ducted and that the testing demonstrates that the equipment is
capable of performing its safety functions before being returned to
service.
Licensee and applicants shall submit the results of their check of
vendor and engineer recommendations (regarding safety-related com-
ponents in the RTS) to ensure that any appropriate test guidance is
included in the test and maintenance procedures or the Technical
Specifications, where required.
Discussion
In the letter dated November 10, 1983, the licensee described their
planned and completed actions.
It was verified that the licensee has
established and implemented a computerized history and maintenance
planning system (CHAMPS).
The system assures that all maintenance
activities are initiated, performed, tested and documented in
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accordance with approved procedures. The post-maintenance acceptance
testing is duly prescribed on the Maintenance Request Form (MRF) by
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the cognizant operation engineering personnel. The surveillance test
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and the review of test results provide a method for operation verifi-
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cation and completion of the scope of the maintenance works, includ-
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ing identification of any deficiency and discrepancy in the material,
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process or procedure and resolutions thereof. The post-maintenance
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testing program ensures that a post-maintenance test is required to
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be performed on the safety-related components in the reactor trip
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system components prior to returning these component to service, and
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that the post-maintenance testing demonstrates that the components
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can perform their intended safety functions.
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The licensee has developed procedures to review, evaluate and imple-
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ment vendor and engineering recommendations for all safety related
equipment and components.
The licensee is committed to the following
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five aspects of INP0 NUTAC Vendor Equipment Technical information
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Program.
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(1) NSSS Vendor Contact - The licensee has established administrative
controls to assess and evaluate NSSS vendor technical bulletins
by qualified personnel and implement their recommendations as
applicable.
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(2) NPRDS - The licensee has expanded participation in the Nuclear
Plant Reliability Data System.
(3) Other Vendors - The licensee has established procedures and
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implemented to review and update vendor technical information
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for all safety-related equipment.
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(4) Handling of Equipment Technical _Information - The licensee has
developed administrative procedure to review, evaluate and
update equipment technical information received from vendors and
other industry or regulatory sources.
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(5) Internal Handli_nq of Vendor Sources - The licensee has
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established a QA program for all safety-related services per-
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formed by vendors, contractors or any qualified supplier.
The following procedures provide administrative guidelines for
Generic Letter 83-28 related matters:
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LS-A-1
Administrative Procedure for Review, Disposition and
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Monitoring of Response to NRC IE Bulletins, IE Information
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Notices, and Division of Licensing Generic Letters
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LS-A-2
Administrative Procedure for Participation in Nuclear
Plant Reliability Data System
LS-I-5
Implementing Procedure for Utilization of the INPO
NPRD System
LS-I-6
Implementing Procedure for Review, Disposition and
Monitoring Nuclear Regulatory Commission IE Bulletins,
IE Information Notices and Division of Licensing Generic
Letters
NS-A-5
Administrative Procedure for Review and Implementation
of Operating Experience Information for Vendor Manual
Maintenance
NSS-I-4
Procedure for Review and Utilization of Operating
Experience Information
NSS-I-5
Procedure Governing the Use of the Institute of Nuclear
Power Operations Nuclear Network
ERDP 6.4 Procedure for Control of Vendor Technical Manuals
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B.
Actions 3.2.1 and 3.2.2, Post-Maintenance Testing (All Other Safety
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Related Components)
Position
Licensee and applicants shall submit a report documenting the extend-
ing of test and maintenance procedures and Technical Specifications
review to assure that post-maintenance operability testing of all
safety-related equipment is required to be conducted and that the
testing demonstrates that the equipment is capable of performing its
safety functions before being returned to service.
Licensees and applicants shall submit the results of their check of
vendor and engineering recommendations (all other safety-related
components) to ensure that any appropriate test guidance is included
in the test and maintenance procedures or the Technical Specifica-
tions, where required.
Discussion
In the letter dated November 10, 1983, the licensee stated that
post-maintenance testing and vendor and engineering recommendations
are reviewed, evaluated, conducted and implemented precisely the way
it is done for the reactor protection system discussed above (Actions
3.1.I/2)
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C.
Action 4.1, Reactor Trip System Reliability (Vendor-Related
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Modifications)
Position
All vendor-recommended reactor trip breaker modifications shall be
reviewed to verify that either:
(1) each modification has, in fact,
been implemented; or (2) a written evaluation of the technical
reasons for not implementing a modification exists.
For example, the modifications recommended by Westinghouse in NCO-
Elec-18 for the 08-50 breakers and a March 31, 1983, letter for the
DS-416 breakers shall be implemented or a justification for not
implementing shall be made available. Modification not previously
made shall be incorporated or a written evaluation shall be provided.
Discussion
The Limerick Generating Station Unit-1 is a GE BWR plant and as such
this item is not applicable.
D.
Action 4.5.1, Reactor Trip System Reliability (System Functional
Testing
Position
On-line functional testing of the reactor trip system, including inde-
pendent testing of the diverse trip features, shall be performed on
all plants. The diverse trip features to be tested include the break-
er undervoltage and shunt trip features on Westinghouse, B&W and CE
plants; the circuitry used for power interruption with the silicon
controlled rectifiers on B&W plants; and the scram pilot valve and
backup scram valves (including all initiating circuitry) on GE plants.
Discussion
The licensee is a co-sponser of the BWR Owners Group effort to address
the review of the existing Technical Specification intervals for test-
ing reactor trip system components.
The inspector reviewed the licen-
see responses dated May 8, 1984, May 29, 1985 and June 7, 1985 related
to reactor trip system testing and test frequencies. The licensee con-
firmed the intent of the letters that the on-line functional testing
of the reactor protection system, which included reactor trip system,
was performed at a frequency indicated in the plant Technical Specifi-
cation.
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Based on the foregoing discussion, the inspector determined that the
licensee has completed the action required by GL-83-28, Action items
3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1. and 4.5.1.
3.0 Design Changes and Modifications
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3.1 Reference / Requirements
10 CFR 50.59, Changes, Tests and Experiments
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Limerick' Generating Station Quality Assurance Plan, Volume III,
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Operation Phase
Limerick Generating Station (LGS) Technical Specification,
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Section 6, Administrative Controls
LGS Final Safety Analysis Report (FSAR), Section 17.2, Quality
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Assurance Program
ANSI NI8.7-1976, Administrative Controls and Quality Assurance
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for the Operation Phase of Nuclear Power Plants
Regulatory Guide 1.33, Quality Assurance Program Requirements,
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Appendix A, Rev. 2, 1978
Regulatory Guide 1.64, Quality Assurance Requirements for the
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Design of Nuclear Power Plants, Rev. 2,1976
3 . 2.
Program Implementation and Findings
The inspector reviewed the licensee's plant modification procedures
A-14, " Procedure for control uf plant modifications", Revision 2 and
A-26, " Procedure for corrective maintenance", Revision 8. The licensee
has submitted to the NRC an Annual Plant Modification report in ful-
fillment of the reporting requirements of the 10 CFR 50.59(b). The
report indicated that 43 modifications were completed during the
period ending June 30, 1983.
The inspector reviewed the following
modifications:
84-0222, 13 kV Power
84-0284, RCIC Turbine Exhaust System
85-0295, High Pressure Coolant Injection
85-0310, High Pressure Coolant Injection
85-0320, Reactor Core Isolation Cooling
85-0375, 125/250 VDC System
85-0401, High Pressure Coolant Injection
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The inspector discussed with the Modification Coordinator, Field
Quality Assurance Engineer and other supervisory personnel, the
scope, responsibilities, coordination and implementation of safety-
related plant modifications. The procedure A-14 delineated the
responsibilities for development, review implementation, documenta-
tion and closure of major, minor or emergency designated modification
packages.
The reviewed packages were considered major modifications
and contained duly initiated modification proposals, modification pro-
ject change requests, as applicable, design / drawing change notices,
safety evaluation reports, and operation verification documentation.
The modifications were instituted to rectify the problems identified
during the initial testing program, or to increase system availabili-
ty and reliability.
The safety concerns were adequately addressed,
analyzed and evaluated. The inspector independently verified that
these modifications neither increased the consequences of an accident
or malfunction of equipment important to safety as evaluated in the
plant FSAR nor created the possibility of an accident or malfunction
of a different type than already included in the FSAR. Also, these
modifications did not reduce the margin of safety as defined in the
plant Technical Specification.
The modifications were controlled by
Maintenance Requests uniquely identifying the modification, including
planned corrective actions, installation, and QA/QC verification of
the modification activities.
The modifications were conducted in
accordance with the approved plant procedures and operation verifica-
tion documented the acceptability of post-modification testing as
applicable.
It was also noted that these modifications did not
affect related operating and surveillance procedures required by the
Technical Specification. The modification packages demonstrated that
the training program for the individuals engaged in safety related
modification activities has been implemented and the cognizant groups
were responsible for their indoctrination and qualification. The
as-built drawings, in most cases, were properly revised. Wherever,
the as-built drawings were not completed because of administrative,
technical or construction schedule, the items were properly identi-
fled for incorporation in the upcoming revision cycle.
The inspector also witnessed the selected activities for the follow-
ing modifications in progress, including volt-ampero test for the
welding electrodes, and PT:
85-0319, Modification of corridor through 13 kV Switchgear Room
85-0418, Otosel Generator Engine Gauge Panel Support Adjustment
85-0617, Installation of 3/4" Flange on Emergency Service Water
Safety / Relief Valvo line
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The activities were well coordinated and have adequate QA/QC
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coverage.
No violations were identified.
4.0. Management Meetings
Licensee management was informed of the scope and purposes of the inspec-
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tion at an entrance meeting conducted on December 2, 1985. The findings
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of the inspection were discussed with licensee representatives during the
course of the inspection. An exit meeting was conducted on December 6,
1985 at the conclusion of the inspection (See Paragraph 1.0 for attendees)
to provide the findings of this inspection to licenseo management.
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At no time during the inspection was written material provided to the
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licensee,
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