ML20155B817

Forwards Insp Rept 50-353/88-200 on 880808-12 Re Review Plans for Independent Design & Const Assessment.Recommends Clarifications Be Included in Review Plans to Achieve Acceptable Review in Independent Design Assessment Scope

ML20155B817
Person / Time
Site:	Limerick
Issue date:	09/29/1988
From:	Varga S Office of Nuclear Reactor Regulation
To:	Alden W PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20155B822	List: IR 05000353/1988200 ML20155B817
References
NUDOCS 8810070090
Download: ML20155B817 (7)

See also: IR 05000353/1988200

Text

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[ September 29, 1988

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Docket No. 50-353

Mr. William M. Alden

Director-Licensing

ATTN: Correspondence Control Desk

Philadelphia Electric Company

2301 Market Street

Philadelphia, Pennsylvania 19101

Dear Mr. Alden:

SUBJECT:

INSPECTION OF REVIEW PLANS FOR THE INDEPENDENT DESIGN ANO

CONSTRUCTION ASSESSMENT, LIMERICK GENERATING STATION, UNIT 2

As part

for the of its plan

Independent to monitor

Design Philadelphia

and Construction Electric

Assessment (IDCACompany)'s

of Limerick Unit(PECO) "Pro

2,"

the NRC conducted an inspection of the associated review plans. The

inspection took place at the Cherry Hill, New Jersey, offices of the independ-

ent contractor Stone and Webster Engineering Company (SWEC), during the week

of August 8, 1988, with the exit meeting on August 12, 1988. Enclosed are an

executive sumary of that inspection and the subject inspection report. As a

result of this inspection, the NRC recomended additions and clarifications be

included in the review plans to achieve an acceptable depth of review within

the defined IDCA scope. All of the additions and clarifications are documented

in the enclosed addenda to the inspection report and all were discussed with

SWEC. Many of these additions were added to the review plans by SWEC prior to

the exit meeting and all were agreed to be subsequently added to the review

plans. With the inclusion of the items identified in the enclosed inspection

report, the NRC finds the review plans to be acceptable and no other response

is required, s. ,

The independent design assessment (IDA) review plans are generally comprehen-

sive but require the addition of certain design attributes to be considered

complete. All of the inspection disciplines require additions and clarifica-

tions to the review plans with most significant exacted in the electrical and

instrumentation and controls areas. In the electrical discipline, the inspec-

tion team recomended that the review plans be expanded from a review of the 4

kV switchgear in the ac distribution system to a verification of the adequacy

of the station ac and de distribution system's abP ity to supply operating and

control power for loads required for safe shutdown during all modes of plant

operation. In the instrun.entation and controls discipline, the inspection team

recomended that the safety-related 120 Vac instrument power be reviewed for

its apparent lack of an uninterruptible power supply. With the addition to the

review plans of the design attributes identified in the enclosed inspection

report, the scope of the IDA will be considered acceptable,

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Mr. William M. Alden -2- September 29, 1988

The independent construction assessment (ICA) review plans represent a good

first ef fort at identifying the kinds of installations and types of construc-

tion attributes that must be reviewed for an adequate assessment of construc-

tien practices. However, the NRC inspection team had two basic concerns with

the ICA effort. Namely, the scope and depth of inspection were incom'pletely

defined in the review plans; and the planning, preparation and training for the

ICA were incomplete. The team noted that SWEC developed the review plans

without a plant visit and system walkdown by the principal ICA personnel. The

NRC team considered this omission a major contributor to the weaknesses identi-

fied in the review plans.

The SWEC ICA offort began on the Monday following the exit meeting for this

inspection. Because of this schedule, all of the individual ICA review

recomendations in the enclosed inspection report were discussed with the

appropriate SWEC personnel. As a result of these discussions, SWEC comitted

to add two additional reviewers to their team. With the incorporation into the

ICA review plans of attributes to address the NRC team's significant concerns,

the plans will be adequate for their purpose. .

In general, it is our understanding that all review plan attributes will be

evaluated. If a certain attribute cannot be evaluated within the scope of

review selected by SWEC, then that attribute should be evaluated by selecting

another sample outside the approved scope of review. Otherwise, a justifica-

tion will be required for omission of the attribute evaluation.

If you have any questions regarding this report or forthcoming inspection

plans, ph o contact tre or Gene Imbro. Mr. Imbro can be reached at

(301) 492-0954

Sincerely,

even A. d, ro e ctor

Division of Reactor Pro ec s I/II

Office of Nuclear Reacto egulation .

Enclosures:

1. Executive Sumary

2. Inspection Report 50-353/08-200

cc w/ enclosures: See next page

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Mr. William M. Alden -3- September 29, 1988

cc:

Troy B. Conner, Jr., Esquire Mr. Robert Gram

Conner and Wetterhahn Senior Resident Inspector

1747 Pennsylvania Ave., N.W. U.S. Nuclear Regulatory Comission

Washington, D. C. 20006 Pottstown, Pennsylvania ~19464

Mr. Charles Mengers 57-1 Mr. Ted Ullrich

Philadelphia Electric Company Manager - Unit 2 Startup

2301 Market Street Limerick Generating Station

Philadelphia, Pennsylvania 19101 P. O. Box A

Sanatoga, Pennsylvania 19464

Mr. Grahm M. Leitch, Vice President Mr. John Doering

Limerick Generatir.g Station Superintendent-0perations

Post Office Box A Limerick Generating Station

Sanatoga, Pennsylvania 19464 P. O. Box A

Sanatoga, Pennsylvania 19464

Mr. James Linville Thomas Gerusky, Direct'or

U.S. Nuclear Regulatory Comission Bureau of Radiation Protection

Region ! PA Dept. of Environmental Resources

475 Allendale Road P. O. Box 2063

King of Prussia, PA 19406 Harrisburg, Pennsylvania 17120

Mr. Thomas Kenny Governor's Office of State

Senior Resident Inspector Planning and Development

.

j

US Nuclear Regulatory Comission ATTN: Coordinator, Pennsylvania

P. O. Box 596 State Clearinghouse

Pottstown, Pennsylvania 19464 P. O. Box 1323

Harrisburg, Pennsylvania 17102

Mr. Joseph W. Gallagher Mr. Philip J. Duca

Vice President Nuclear Services Superintendent-Technical l

Philadelphia Electric Company Limerick Generating Station l

2301 Market Street P. O. Box A  !

Philadelphia, Pennsylvania 19101 Sanatoga, Pennsylvania 19464

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Mr. John S. Kemper INPO l

Senior Vice President-huclear 1100 Circle 75 Parkway

Philadelphia Electric Company Atlanta, Georgia 30339

2301 Market Street , i

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Philadelphia, Pennsylvania 19101 *

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EXECUTIVE SUMtiARY

Inspection Report 50-383/88-200

Limerick Generating Station - Unit 2 .,

The NRC has planned to monitor each of the design and construction aspects of

the Lin,erici Inocpendent Design and Construction Assessment (IDCA) in three

phases: (1) preparation of review plans, (2) implementation of the review

plans and performance rf the review, and (3) evaluation of the final IDCA

report including assessment of the corrective actions. This int.pection covered

the first phase, preparation of review plans, and was conducted at the Cheery

Hill, New Jersey offices of the IDCA contractor, Stone and Webster Engineering

Company (SWEC).

The inspection team found the independent design assessment (IDA) review plans

to be conprehensive, explicit, and logically structured. The team found the

SWEC reviewers contacted for the IDA to be experienced and techrically compe-

tent. With the addition to the IDA review plans of the design afoributes

iJentified in Addendum I to the subject inspection report, the inspection team

censiders the scope of the IDA review to be acceptable. The more signifi-

cant additions and clarifications to the iDA review plans recommended by the

NRC inspection team include the following.

(1) IDA Mechahical Systems - the inputs and outputs of the ultimate heat sink

sizing calculations should be verified. Residual heal removal (RHR) and

spent fuel pool cooling heat exchangers, relief valve, control valve,

and orifice sizing calculations are to be included in the review plans.

(2) IDA Mechanical Components - the seismic qualification of the RHR heat

exchanger, piping analysis overlap techniques, internally generated

missiles, and a multi-discipline hazards analysis review should be

included in the review plans.

(3) IDA Electrical Power Systems - the scope of review should be expanded

from a review of the 4 kV switchgear in the ac distribution system to a

verification of the adequacy of the station ac and de distribution .

system's ability to supply quali G noerating and control power for loads

reoutred for safe shutdown during all modes of plant operation. A review

of clectrical penetraticns and cable pull'.99 calculations should also be

reviewed. ,

,

(4) IDA Instrumentation and Controls - review of the 120 Vac instrument power

as an uninterruptible source' of safety-related power, and review of the

main control board internal wiring should be included. Also reviews of

calculations should include calibration, flow element sizing, high

pressure restricting orilice sizing (including ((vitation damage assess-

r.ent), and control valve sizing.

(5) IDA Civil / Structural - review should include an assessment of nonseismic

and seismic nuilding interactions, suppression poci swell loads on

miscellaneous steel structures, and the effect of floor flexibility on the

amplified response spectra.

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The NRC construction team found the ICA review plans to be comprehensive in

most areas. The review plans represented a good first ettort at identifying

the attributes necessary for an overall assessment of construction practices.

However, the NRC inspection team identified two areas of concern from.the

initial evaluation of the ICA review plans: (1) the scope and depth of inspec-

tion were incompletely defined in the review plans and (2) the planning,

preparation, and t 3inir.g for the ICA were incomplete. The NRC construction

tean noted that SWEC developed the review plans without a site visit and system

wal T wn by the priacipal ICA personnel. We believe this omission was a major

contributor to the weaknesses identified in the review plans.

The following contributed to the team's concern regarding the scope of the

ICA.

(1) The ICA review plans did not comprehensively identify all types of items

and equipment which SWEC will inspect during the ICA, and in some

instances SWEC had not defined the applicability of identified equipment

to the RHR system.

(2) Several plans did not include a minimum level of effort or a sample

selection process.

(3) Important review plan attributes were missing or were incomplete. Fcr

exarrple, Review Plan LK-C-1903 did not include an attribute to verify the

strength of concrete through a review of concrete compressive test

results; and the LK-C-1904 attributes for cable routing involved only a

record review without a physical check of actual routing.

(4) Certain attributes were inapplicable to the RHR system because they

addressed in-process characteristics and the system was essentially

complete.

(5) The individual plans did not identify the types of items or infomation

that the discipline reviewers were to provide to the procurement reviewer

for traceability reviews. Also Review Plan LK-C-1906 did not provide any

requirements to perfom these material traceability reviews on samples

identified by the other ICA members. .

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The following factors contributed to the team's concern regarding the

preparation, plannir.3, and training for the ICA.

(1) The SWEC ICA group had not reviewed the actual condition and status of the

RHR system to determi.ne its effect on the ICA effort and the review plans.

For example, the installation of piping insulation can significantly

reduce the number of welds and piping samples accessible for examination.

(2) The ICA group had not obtained all of the infomation required for an

adequate preparation of the ICA effort. For example: SWEC had not

identified the applicable ASME codes for welding and nondestructive

examinations (NDE), and had not gathered sufficient detail drawings to

detemine sarrples and applicability of attributes.

(3) The staffing level appeared to be inadequate for the size of the on-site

review ef fc.rt defined by the plans.

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