ML20149E732
| ML20149E732 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/06/1988 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Russell W NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8801140003 | |
| Download: ML20149E732 (5) | |
Text
______ _ ______-_ _
PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA PA.19101 (215)841 450o JOHN S. KEMPER January 6, 1988 SetNIOR VICE4REstDENT - NUCLE AR Mr. William T. Russell i
Adninistrator l
Region I U.S. Nuclear Regulatory Ccnmission ATTN: Docunent Control Desk Washington, DC 20555
SUBJECT:
Systematic Assessment of Licensee Performance (SALP) for Limerick Generating Station Unit 2 Report Nunber 50-353/86-99 Assessment Period: January 1, 1986 - July 31, 1987 FILE:
COVT 1-1 (NRC)
Dear Mr. Russell:
This iet,ter provides the Ph!1adelphia Electric Company (PECo) written response to SALP Report No. 50-353/86-99 for Limerick Generating Station (LGS) Unit 2 which was forwarded by your letter of Noverrber 19, 1987.
PECo appreciated the opportunity to meet with the NRC on Decenter 7,1987 to review the results of the SALP Board report.
Based on our review of the SALP Report ar.d the discussions.at the Deccmber 7, 1987 meeting, we offer the below listed responses.
In most cases, fmetional areas rated Categor, I are not addressed. Those rated Category 2, Engineering and Assurance of Quality, are addressed.
Fngineering The SALP Board reccnmendations and PEco responses in the area of engineering are as follows:
Reccmnendat 'ori:
"The licensee needs to improve effectiveness of project engineering control of design interface."
Response
This reccmmndation is based on several problems discussed in the SALP Report which occurred over a nurber of years.
We have reviewed these problems individually and collect lvely and in relation to independent findings made recently by PECo and Bechtel. We conclude that they are isolated incidents of failure go 8801140003 880106
{DR ADOCK 05000353
)O DCD-
\\
=
to inplement the well established and tested procedures which govern engineering activities. Including design Interface control.
As a result of this review, we have identified several process-enhancements which we believe will improve our success in transferring design requirements through Interfacing organizations to the ultimate user in the construction or operating organizations.
The following actions will be taken to enhance the effectiveness of the existing process governing design interface between PECo, Bechtel, GE, and subcontractors:
1.
Currently scheduled reviews of design changes by a multi-discipi jned team from Bechtel's Chief Engineers' office will be expanded to ensure that vendor docunentation and construction docunentation are reviewed for consistency with design requirements. This will provide feedback con:erning the effectiveness of current checking and review processes.
Processes for translating design requirements into construction docunents will also be reviewed to assure that they provide appropriate interpretation of design consIderatlons.
2.
A meeting will be held with General Electric to review the Unit 2 design interface to assure that there has been adequate conmunication of design requirements and design changes.
3.
A Bechtel training program will be initiated to reinforce the importance of considering end use of docunents initiated or reviewed by engineering personnel. This training program will be based on flow charts developed by each d!scipilne supervisor tracing the process by which design docunents reach construction. As the project proceeds through construction Into operation and Configuratico Managc<nent prgrams, this infonnation will be used to assure that complete coverage is given to design requirunents and there is a clear understanding of the design expectations of interfacing oiganizations (e.g. Bechtel or PECo construction or subcontractors).
Reccmnendat ion'.
"The licensee needs to give prcamt attention to assure FSAR accuracy."
Response
This reccmnendation is based on three instances where FSAR figures showing structural details were found to be inconsistent with current civil / structural design drawings and a single Instance where FSAR information was not translated into the impicmenting design docunent. Subsequent to the SALP reporting m
~
' period, a second instance of failure to im!:;ement an FSAR cemnitment was identified by the NRC. We have reviewed these ins'.ances of non-conformance to the FSAR and reached conclusions as to root cause and appropriate corrective actions described be'cw.
The root cause of the design drawing /FSAR figure inconsistencies was determined to be a lack of specificity in procedures governing reconciliation of design /FSAR differences which impact FSAR figures. As a result, FSAR figures were not consistently revised to reflect the latn ' approved design. drawings on which they were based. Corrective actior,will include developnent of a clearly defined 41 Icy for revising FSAR figures in response to changes in associat.>d design drawings. This policy will establish the following requirements:
1.
FSAR Section 1.7 tables IIsting current electrical drawings, control and instrumentation drawings, and piping and instrunentation drawings will be updated at each scheduled FSAR revision beginning in February 1988 to reflect the current status of drawing revisions. Related FSAR figures will be revised accordingly.
This practice will continue through ccmnercial operation of Limerick 2 after which the requirements of 10CFR50.71, requiring annual updates, will take effect.
2.
FSAR figures based on civil /.,tNetural design drawings will be revised to add references to tnose design drawings.
These FSAR figures are unique in that most are ccxnposites of saveral design drawings asserrbled spec!fically to meet the inforTnation requirements of Regulatory Guide 1.70 and the Standard Review Plan. As such much of the detall contained, e.g., wel d synbol s and s i zes, is unrelated to assessing conformance to the Ccmnission's requirements. The addition of design drawing references to these FSAR figures will enable the NRC to audit plant construction against the appropriate uesign drawings rather than against a ccrroosite FSAR figure not intended for that purpose. References to related ciesign drawings are currently provided on other FSAR figures.
Because of their unique nature, review of and changes to civil / structural-based FSAR figures will not be ccmplete in time to support the February 1988 FSAR revision; incorporation into the June 1988 revision is planned.
The roo', cause of the two failures to incorporate FSAR informat ion into implementing design docurents was determined to be isolated, unrelated breakdcwns in implementation of wel' -established procedures which. equire review of design documents against the FSAR to assure consistency. These brerkdowns occurred li) wldely disparate time frames.
In order to minimize the possibility of such breakdowns in the future, the follcming enhancements will be implemented within the scope of eristing procedures:
1
_ - _=
._ _. ~...
- _ 4-1.
Bechtel will reinstate the posit!'on of 11 censing coordinator within each engineering discipline as existed during FSAR preparation. These individuals will maintain a working.
knowledge of FSAR content related to their disciplines, will provide discipline training with regard-to FSAR conformance, and will perform Ilcensing reviews for their disciplines.
2.
All design change processes have been o" are being clarified to assure that a positive review for FSAR conformance is-performed.
3.
FSAR change procedures will be revised to require explicit IdentifIcatlon of new ccamltments and a cross reference to
. l the Inplanenting design docunent. This should prevent future problems such as occurred with the conmitment to L
testing of diesel intake and exhaust piping.
4.
Chief Engineers reviews (discussed in response to the previous reccamendatlon) will also assess conformance of the design to the FSAR.
PECo believes these improvements are fully responsive to the Ccnmission's reccnmendation, will acconplish their intended purpose, and will result in c.n increased level of confidence that.
Limerick 2 is constructed in accordance with its licensing basis.
Safety-Related Components - Mechanical This functional area was rated Category 1; no response to the SALP i
Report is provided.
Infonnation requested by the NRC at the December 7,1987 meeting regarding status of the Unit 2 preventive maintenance and Limitorque
?
operator rework and testing programs.wl11 be provided by January 31, 1988.
f Assurance of Quality i
There were no SALP Board reccnmendations in this area; hcwever, PECo j
wishes to respond to the folicwing issue addressed in the SALP Report:
Issue:
l "As discussed in Section IV.B of this assessment, several cases l
were identified by NRC wherein design organization Interface l
control weaknesses resulted in inproperly lastalled hardware.
These weaknesses were apparent between Bechtel and General t
Electric and between Bechtel and subcontractor engineering organizations. Licensco quality assurance and design personnel were not able to detect these problems."
e I
c.er-w,,---,w-+.-
~-,-e~.
n, - -
en-
,---w,--,,.a w,.,e
-,, e t e r.,,
,1, r
-,-,vw,r.
r +-
,,,rg--,w,
--.,J y-
JPo
_5_
Response
The Nuclear Quality Assurance (NQA) and Nuclear Engineering (NE) organizations will strengthen their oversight activities relating to design organization Interfaces and the vendor docunent review process. A nulti-discipline (NQA and NE personnel) team design review will be performed in 1988 to provide a more in-depth look at these activities.
In addition NQA audits will be scheduled in 1988 to cover the implementation of field changes into design doctments and in-process engineering activities.
SuTnery PECo is cannitted to the pursuit of excellence at Limerick 2 In the areas of Engineering and Assurance of Quality as well as to naintaining the current high level of performance in other functional areas.
The results of reviews reported herein identify no fundc,Tental deficiencies in the design and construction processes which continue to serve us well. We are confident that the enhancenents discussed in this letter will help us to achieve that goal. We recognize that ongoing corporate reorganization and Peach Bottom restart activities will conpete with Limerick Unit 2 for our resources and we will take the actions necessary to assure that all three activities are successfully acconplished.
To date Limerick 2 is several nonths ahead of schedule with fuel load forecast for June 1989. We trust that the NRC will provide the level of support necessary to acconpilsh the reviews required to support plant startup and licensing and we will continue to work with you in this regard.
Should you have any questions or requir.e additional inforret i on, please contact us.
Very truly yours,
- d s' /d. /-
/
RLB/cb/12228709 Copy to:
W. T. Russell, Regional Administrator USNRC Region 1 R. A. Granm, Limerick Generating Station Unit 2 USNRC Resident inspector