Text

SALP Rept 50-353/87-99 for Aug 1987 - Dec 1988
	ML20236C259
Person / Time
Site:	Limerick
Issue date:	03/15/1989
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20236C251	List: ML20236C249; ML20236C259;
References
	50-353-87-99, NUDOCS 8903220046
	Download: ML20236C259 (28)
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SALP BOARD REPORT

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U.S. NUCLEAR REGULATORY COMMISSION

9EGION I

______________________________________________________________________________

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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INSPECTION REPORT 50-353/87-99

PHILADELPHIA ELECTRIC COMPANY

LIMERICK GENERATING STATION

UNIT 2

ASSESSMENT PERIOD: AUGUST 1, 1987 - DECEMBER 31, 1988

SALP BOARD MEETING:

FEBRUARY 22, 1989

8903220046 890315

PDR

ADoCK 050CO353

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PDC

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TABLE OF CONTENTS

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INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . .

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A.

Purpose and Overview. .

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B.

SALP Board Members. . . . . . . . . . . . . . . . . . .

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C.

Licensee Activities . . . . . . . . . . . . . . . . . .

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D.

Direct Inspection and Review Activities . . . . . . . .

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II.

SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . .

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A.

Overview.

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B.

Performance Summary .

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III.

CRITERIA . . . . . . . . . . . . . .. . . . . . . . . . . . .

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IV

PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . .

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A.

Construction. . .

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Engineering / Technical Support .

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C.

Preoperational Testing. . . . . . . . . . . . . . . . * . 14

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D.

Safety Assessment / Quality Verification. . . . . . . .

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V.

SUPPORTING DATA AND SUMMARIES. . . . . . . . . . . . . . .

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A.

Enforcement Activity.

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B.

Investigations and Allegations. . . . . . . . . . . .

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C.

Management Conferences.

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D.

Construction Deficiency Reports . . . . . . . . . . .

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Tables

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Table 1 - Inspection Hours

Table 2 - Enforcement Summary

Table 3 - Construction Deficiency Reports

Table 4 - Limerick Unit 1 SALP Performance Summary

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INTRODUCTION

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Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an

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integrated NRC staff effort to collect observations and data on a

periodic basis and to evaluate licensee performance.

The_SALP

process is supplemental to normal regulatory processes used to ensure

compliance to NRC rules and regulations.

SALP is intended to be

sufficiently diagnostic to provide a rational basis for allocating

NRC resources and to provide meaningful guidance to the licensee's

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management to improve the quality and safety of plant operations.

An NRC SALP Board, composed of the staff members listed in Section B,

met on February 22, 1989 to review the collection of performance

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observations and data to assess the licensee's performance at the

Limerick Generating Station Unit 2.

This assessment was conducted in

accordance with the guidance in NRC Manual Chapter 0516, " Systematic

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Assessment of Licensee Performance." A summary of the guidance and

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evaluation criteria is provided in Section III of this report.

This report is the SALP Board's assessment of licensee's safety

performance at the Limerick Generating Station Unit 2 for the period

August 1, 1987 through December 31, 1988.

The summary findings and

totals reflect a 17 month assessment period.

B.

SALP Board Members

Chairman

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S. Collins, Deputy Director, Division of Reactor Projects '(DRP)

Members

R. Gallo, Chief, Operations Branch, Division of Reactor Safety

W. Butler, Director, Projects Directorate I-2, NRR

E. Wenzinger, Chief, Project Branch 2, DRP

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J. Linville, Chief, Projects Section 2A, DRP

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R. Clark, Project Manager, NRR

R. Gramm, Senior Resident Inspector, Limerick Unit 2

Other Attendees (Non-voting)

R. Fuhrmeister, Resident Inspector, Limerick Unit 2

T. Kenny, Senior Resident Inspector, Limerick Unit 1

C.

Licensee Activities

Over the course of the assessment period the project has been in a

transition from the construction to the preoperational test phases.

Bulk construction has been completed and systems were turned over for

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component and preoperational. testing.

Plant labeling, pipe

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insulation, painting, and other system completion activities are

still in progress.

The reactor pressure vessel hydrostatic test was completed on

February 22, 1988, eight months ahead of the scheduled.date. . The

electrical and instrumentation portions of the component testing

phase began in October 1987.

~The PECo staff was extensively reorganized during the assessment

period.

On November 1, 1987, Mr. John Kemper was elected Senior Vice

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President-Nuclear with responsibility to oversee the Unit 2 construc-

tion and startup activities.

In March 1988, the former. president

retired. 'Also in March 1988, Mr. Joseph F. Paquette'was elected.

President and Chief Operating Officer and Mr. Corbin A'. McNeill was

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elected to the position of Executive Vice President-Nuclear.

Later

in April 1988, the former PECo Chairman of the Board and Chief

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Executive Officer retired and Mr. Paquette was elected -to' fill those

positions.

PECo has contracted'with Stone and Webster Engineering' Corporation to

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perform an-independent design and construction assessment. The

assessment was initiated in May 1988 and is ongoing.

D.

Direct Inspection and' Review Activities

Two NRC resident inspectors were assigned to the site during the

assessment period.

The total NRC inspection time expended during the

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17 month assessment period was 5,597 hours0.00691 days 0.166 hours 9.871032e-4 weeks 2.271585e-4 months or 3,951. hours on an

annualized basis.

Distribution of these hours by functional area is

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depicted in Table 1.

A summary of enforcement activities.is provided

in Table 2.

The inspections have included the NRC Nondestructive Examination van

inspection, inspection of preoperational test activities and operator

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examinations for dual unit licensed personnel.

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The conduct of the Stone and Webster Engineering Corporation

independent assessment program has been closely inspected by NRC

personnel. A confirmatory site inspection was conducted by the NRC ,

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of as-built hardware,-

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The NRC construction inspection program is approximately 95% complete,

a level commensurate with the plant status.

NRC review of pre-

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operational test procedures and conduct of test witness activities

has been ' performed in conjunction wit the startup program. Areas to

be inspected prior to license issuance include Loss of-Offsite Power

(LOP),. Integrated Leak Rate (ILR) test witness, review of.the power

ascension test program, and review of operational readiness for a'

dual unit site.

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II.

SUMMARY OF RESULTS

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A.

Overview

The licensee has effectively managed the. transition from the

construction to the preoperational test phase. . System completion ' and

turnover activities have been well controlled and performed by.

experienced personnel.

The preoperational test program his been well planned and executed.

Test personnel have rigorously adhered to applicable ~ test

instructions. Overview by quality assurance and Test Review Board

personnel has been thorough.

The plant' operations staff has been

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fully integrated into the implementation of the test program.

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Extensive actions were taken to augment engineering programs in

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response to concerns identified in the previous assessment. The

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control cf the design reconciliation with the as-built plant has been

performed in accordance with a well conceived program.

Some apparently

historical problems were identified with respect to items supplied

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by General Electric including PGCC wiring errors and design interface

problems. Once identified, these issues were aggressively pursued

and resolved.

The li:ensee has proactively planned and implemented the programs to

dettre.ine the plant readiness for operations. These reviews have

included extensive design and construction audits along with reviews

of procedural and staffing readiness.

The final safety analysis

updates, and as-built configuration verification efforts are

examples of proactive programs in which PECo management is actively

and aggressively involved.

B.

Performance Summary

Functional

Category Last Period

Category This Period

Area

(1/1/86 - 7/31/87)

(8/1/87 - 12/31/88)

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Construction

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Engineering / Technical

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Support

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Preoperational Testing

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Safety Assessment /

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Quality Verification

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Assurance of Quality

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Construction areas of: containment, safety related structures, soils'and

foundations; piping systems and supports; safety related components-

mechanical; auxiliary systems; electrical equipment.and cables; and-

instrumentation and controls were individually assessed. A11 were rated

Category 1.

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- Area.not rated due to limited amount of inspection and test activity.

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area.

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III. CRITERIA

Licensee performance is assessed in selected functional areas, depending

on whether the facility is in a construction or operational phase,

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Functional areas normally represent areas significant to nuclear-safety

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and the environment.

Some functional areas may not be assessed because'of

little or no licensee activities or lack of meaningful observations.

Special areas may'be added to highlight significant observations.

The following evaluation criteria were used, as app 1_icable, to assess each

functional _ area:

1.

Assurance of quality. including management involvement and control;

2.

Approach to the resolution of technical issues from a safety

standpoint;

3.

Responsiveness to NRC initiatives;

4.

Enforcement history;

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Construction events (including response to, analyses of, reporting

of, and corrective actions for);

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Staffing (including management); and

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Effectiveness of training and qualification program.

On the basis of the NRC assessment, each functional area evaluated is

rated according to three performance categories. The definitions of these

performance categories are as follows:

1.

Category 1.

Licensee management attention and involvement are

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readily evident and place emphasis on superior performance of nuclear

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safety or safeguards activit'ies, with the resulting performance

substantially exceeding regulatory requirements.

Licensee resources

are ample and effectively used so that a high-level of plant and -

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personnel performance is being' achieved.- Reduced NRC attention may

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be appropriate.

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Category 2.

Licensee management attention to and involvement in the

performance of nuclear safety or safeguards activities is_ good. gThe

licensee has attained.a level of performance above that needed to

meet regulatory. requirements.

Licensee resources are' adequate and

reasonably allocated so that good plant and personnel performance is

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being achieved. NRC attention may be maintained at normal levels.

3.

Category 3.

Licensee management attention 'to'and involvement-in the

performance of nuclear safety or safeguards activities are not.

sufficient. The licensee's performance does not significantly exceed

that needed to meet minimal regulatory requirements.

Licensee

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resources appear to be strained or not effectively used. NRC

attention should be increased above normal levels.

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Trend: The SALP Board may decide to include an appraisal of the

performance trend of a functional area.

Normally, this trend will

only be used when both a definite trend of performance is discernible

to the Board, and the Board believes that continuation of the trend

will result in a change of performance level.

Improving:

Licensee performance was determined to be improving near

the close of the assessment period.

Declining:

Licensee performance was determined to be declining near

the close of the assessment period.

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IV.

PERFORMANCE ANALYSIS

A.

Construction (3,277 hours0.00321 days 0.0769 hours 4.580026e-4 weeks 1.053985e-4 months ; 59%)

The previous assessment of construction; activities.was that

management control and oversight had been maintained over'all major

construction activities.

The site work force was very knowledgeable

and highly motivated to produce good workmanship. Close involvement

of field engineering personnel and thorough quality oversight

contributed to the good performance noted during the previous

assessment period.

During this assessment period. construction personnel continued to

demonstrate their' knowledge and cognizance of installed systems within

their jurisdiction. . Instrumentation craft were typically provided

work-packages for instrument tubing installation which contained

appropriate sketches and specification criteria to guide the routing.

Excellent verbal and written communications between the craft and

engineering personnel facilitated the-installation process. Quality

control personnel were found knowledgeable of inspection criteria and

installation requirements.

Cooperation among site personnel was highly

visible.

The licensee has established an effective program for administration

of the Pre service Inspection (PSI) program.

A system was developed

to accurately track the completion status of required examinations.

The PSI weld identification and surface preparation was performed in

a conscientious manner attributable in part to the quality of onsite

craftsmen training.

The certification and training program for

personnel assigned visual inspection tasks was excellent. One weak

area involved the fact that practical tests performed by the inspectors

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were performed with unflawed specimens. The licensee revised-the

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practice in response to the concern raised by the NRC.

The licensee

has maintained an aggressive oversight of the program including a

100% review of the contractor PSI data. Although-not a regulatory

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requirement the licensee dedicated sufficient resources to assure

that the PSI program was staffed with experienced professional

personnel which formed the foundation of the good implementation phase.

Review of plant records relative to electrical cable installation

noted the documents as complete and retrievable.

Personnel responsible'

for handling the records were knowledgeable and well trained. The-

quality assurance audits were found thorough and the nonconformance

dispositions technically sound.

A defective diesel. generator power output cable was found during a

megger test.

Coordination of engineering and quality assurance was

good in obtaining a replacement cable.

The difficult cable repull

based upon the raceway configuration and the cable minimum bend radius

was satisfactorily performed based upon good engineering planning and.

the exercise of proper controls during the cable pull process.

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One notable exception to an otherwise effective program was maintenance-

activities. improperly performed on the standby. diesel generators as

an abrasive compound was not. properly. removed after the bearings were

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reworked.

The improper maintenance was caused by the lack of written'

procedures and cleanliness acceptance criteria to guide the bearing

rework. One additional preventive maintenance concern arose when

untimely corrective action was initiated by Bechtel.to protect the

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top cover of the reactor pressure vessel.' to prevent particulate

intrusion. The site organization had been awaiting a General

Electric engineering disposition prior to rectifying the immediate

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concern of maintaining system cleanliness. When identified'by the

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NRC, the licensee promptly established' appropriate internal'

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cleanliness control. measures.

An extensive plant labeling program was initiated during this assess-

ment period. The labels are provided for piping, duct, instruments,

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valves and other components.

Information regarding process flow

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direction, system identification and unit. identification are provided.

Appropriate quality control involvement existed during the labeling

process.

In conjunction with the labeling program a coordinated-

facility painting program was implemented to provide rapid differen-

tiation of Unit 2 rooms. The dedication of extensive licensee

resources to these areas is indicative of a commitment to achieve

operational nuclear nlant safety.

NRC inspection of the Power Generation Control Complex (PGCC) cabinet

panel wiring identified di,crepant conditions. These involved a few

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improperly labeled and t'.cminated wires and were. typical of PBCC wiring

problems found at other sites.

This was found to be factory wiring

accepted under the General Electric quality program which had not

been reinspected onsite. As a result of the NRC finding the licensee

embarked on an extensive onsite reinspection of all PGCC panels by

Bechtel and GE personnel to identify, analyze and correct the dis-

crepancies that were found.

Further discussions on the reporting

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aspects of this issue can be found in section V.D. of this assessment.

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A comprehensive system turnover piocess was implemented for turnover-

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from construction to startup. The program involved hardware and

software reviews by personnel representing quality, construction,

engineering and startup organizations. Additional documentation of

turnover boundary drawings, equipment lists, turnover procedures and.

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QC inspection reports were generated to facilitate. control and-

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accuracy of this process,

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Site construction activities continued to be guided by the use of

pre planned work packages that describe the scope of work and

applicable installation criteria. As exemplified by the installation

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activities on the feedwater spargers, personnel were appropriately

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trained, quality monitoring personnel were actively. involved and

engineering personnel were present in the field to verify proper

installation.

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The site work force staffing levels were appropriate for the phases of-

work activities. Overtime was controlled for personnel in all parts-

of the organization.

Discussions with licensee personnel have found

them to be well trained, highly experienced and technically-knowledgeable.

Summary

- Construction. activities have been well controlled, guided by use of,

work packages and close field engineering involvement. . Experienced

management provided active overview of construction program implemen-

. tation. Weaknesses identified during the inspection reviews were

determined to be isolated cases. The system turnover program was

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effectively performed and the status of construction completion is-

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accurately known by the licensee.

Licensee personnel, including

contractors, were found to be highly experienced, technically know-

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ledgeable and well trained to carry out their work activities.

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Conclusion

Category 1

Board Recommendations

None

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Engineering / Technical Support ( 18%: 1030 hours0.0119 days 0.286 hours 0.0017 weeks 3.91915e-4 months )

The main conclusion of the previous SALP report with regard to

engineering activities was that more management attention was needed

to better assure effective programs are implemented in the areas of

control of design information at organizational interfaces and the

accuracy of FSAR information.

The licensee initiated numerous actions

as discussed below in response to the these observations and recom-

mendations.

During this assessment period these actions have included

a variety of initiatives to augment engineering programs and to

address areas of weakness. .This assessment addresses predominantly

Bechtel engineering efforts.

A joint review was performed by Bechtel and General Electric of their

design interface controls.

As a result of this review, the system

for controlling these interfaces has been modified to improve

communications between these organizations and control the design

interfaces. Also, independent, multidisciplinary engineering reviews

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have been performed on selected design changes, design interfaces and

potential construction problem areas.

These actions appear to be

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effectively assuring the continuity of requirements through the

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design and installation process.

Several errors identified by the

NRC during this assessment period are attributable to problems that

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occurred previously in the General Electric and the Bechtel engineering

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and design interface. These errors included ambiguous designation of

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component quality level, and incorrect redundant reactivity control

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logic drawings and wiring.

Extensive licensee reviews were perforned

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to determine the scope of the problem;. Where additional problems

were uncovered, appropriate engineering dispositions were rendered.

Actions have been taken to review, verify, and evaluate the accuracy

with which the FSAR reflects the current plant configuration and to

verify the translation of FSAR code commitments into site specifica-

tions.

Through these initiatives the licensee has self identified

and corrected FSAR inaccuracies.

The licensee has established a

schedule for issuance of updated FSAR figures, designated discipline

licensing coordinators to maintain cognizance of respective licensing

documents and revised design change forms to assure positive verifi-

cation of design changes affecting the FSAR.

The licensee's organi-

zation has been sensitized by their management to the importance of

the FSAR and has established controls to ensure the accuracy of the

document.

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An extensive Bechtel Design Closure Plan has been established to

identify areas requiring reconciliation of design documents in

relationship to the as-built plant configuration.

Elaborate computer

data bases and associated documentation derived from as-built

configurations provide assurance that structural integrity has been

maintained for the containment liner plate, building steel and

reinforced concrete.

Personnel were technically knowledgeable of

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the program and enhancements that were implemented to the similar

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Unit 1 programs.

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A major program for independent verification of the Limerick 2 design

and construction activities was. initiated by the licensee and closely

monitored by.the NRC during thir assessment period and is still in

progress.

Stone and Webster Engineering Corporation (SWEC) was

selected to perform the assessment. .SWEC developed review plans

based upon the FSAR, design specifications and site procedures.

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review plans were generally thorough in scope and were expanded

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wherever necessary in response to minor NRC concerns.

SWEC selected

very experienced personnel to perform the design review.

The details

and questions raised within the SWEC finding reports reflect the depth

and scope of the SWEC review.

This program involves a significant

commitment of resources by the licensee and is considered an excellent

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initiative that to date has provided.a high level of confidence in-

the quality of desigr and construction at Limerick 2.

The ongoing

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NRC inspection of the SWEC assessment has confirmed the plant

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construction and the adequacy of program implementation to date.

Several examples were found where licensee reviews for deportability

were either poorly documented or non-conservative.

NRC review and

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questioning of issues such as the use of zinc in lieu of malleable

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iron conduit couplings and the non-safety related fire protection

flow switch trip of the standby diesel generators resulted in

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several meetings, and additional testing and analyses in order to

substantiate the original licensee conclusion regarding' deportability.

None the less, in both cases, the discrepant hardware was replaced.

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When the NRC questioned the review of design defects in core spray

system wiring, the reviewer revealed that additional information was

available, and had been used to support the conclusion that the defect

was not reportable.

Bechtel, during re-review of an old item involving

motor operated valve high current trip on instantaneous reversal

concluded that no hardware modifications were necessary, but recom-

mended that plant operating procedures be amended to preclude

simultaneous stroking of more than one containment isolation valve.

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PECo engineering concluded that no measures were needed.

This non-

conservative approach to reporting has shown recent improvements due

to licensee responses to NRC initiatives.

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The licensee has an effective program for assuring proper. environmental

qualification of components and equipment. The engineering organization

has implemented a program to update the equipment quaH fication

packages with more detailed. checklists and additional documentation.

Post inspection site walkdowns were performed by technically' competent

personnel to ensure that all elements of the site installation

conformed with the seismic and environ ~ mental qualification require-

ments.

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The responsibility for design review and technical audits has been

added to the scope of the licensee's Nuclear Quality. Assurance section

audit plan. Action items for engineering are the responsibility of

Bechtel Power Corporation.

Licensee audits of design documents have

been implemented to verify that field changes have been properly

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incorporated into the design documents. Bechtel quality and

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engineering organizations were found to promptly disseminate infor-

mation, regarding offsite identified design problems, for internal

investigation.

Examples include a computer code error and concerns

regarding the logic for motor. operated valves. The above observations

indicate an effective program for assuring the quality of engineering

activities.

A unique Design Process Improvement Program has been instituted by

Bechtel engineering. On a bimonthly basis, engineering managers meet'

to review recently identified issues. -Quality Assurance audit findings

are analyzed and any associated corrective actions are disseminated to

key personnel.

Internal engineering assessment results are also

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presented.

This' program represents an innovative approach for Bechtel

to perform introspective reviews of the engineering program.

Philadelphia Electric Company (PECO) management is actively involved

with the planning and implementation of the construction of the

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plant. This was evident by management participation, review, and

approval of short and long range construction schedules and weekly

work plans; the review of work progress and approval of changes in

the workscope. The licensee has assigned key individuals to monitor

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and coordinate day-to-day work by Bechtel.

The audit and surveillance

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function of the licensee is extensive and effective to control the

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work of contractors,

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The licensee developed a comprehensive list of differences between

Units 1 and 2.

The list appears to accurately document the

differences between the units and has been valuable for providing

input to the licensed operator differences training.

The training

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process was well defined and included classroom instruction, plant

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walkthrough training and simulator instruction. Appropriate exami-

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nations were administered by the licensee to effectively screen the'

unprepared candidates.

The effectiveness of the licensee training was demonstrated by the

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fact that the 60 candidates, currently licensed on Unit 1, that

successfully passed the' licensee examination also passed the NRC-

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administered examination.

The candidates that did not pass the

licensee administered examination were promptly removed from their

Limerick 1 licensed duties until remedial training and/or other

corrective actions are completed.

This is indicative of a conservative

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management approach toward plant safety.

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Summary

Bechtel engineering has effectively supported licensee activities

with regard to technical.and engineering support for plant

construction.and preparation for operation.

Efforts have been

responsive to the. concerns raised in'the previous SALP. Major

actions were instituted to assure the accuracy of FSAR'information.

The process of reconciliation'of.the as-built plant versus.the

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' design' documents has been performed .in a careful. methodical'rature.

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Ir,itiatives.such as the independent designLand construction

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. verification program have confirmed a. high quality of ' design- and

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construction for Limerick 2.

While.the reporting evaluations were-

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performed in a less than. satisfactory manner early in the

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assessment, the process has improved due to implementation of~

l

ongoing' licensee initiatives.

Extensive effort was expended to

maintain accurate knowledge of the plant differences and the impact

upon plant operations. The operator training for dual unit licenses

was performed in a thorough manner which resulted in excellent

examination scores.

Conclusions

Rating: Category 1

Board Recommendations

None

,

l

\\

l

...

< 4e

"JO"

E____1___.__

_

-

%

a

,&

.'

'

.

,

'

1

14

!

l

C.

Preoperational Testing (1,290 hours0.00336 days 0.0806 hours 4.794974e-4 weeks 1.10345e-4 months ; 23%)

This functional area consists of the initial equipment calibration

1

and component tests (Blue Tag tests) preceding preoperational system.

I

l

tests, and preoperational test activities, including procedure

l

generation, review,.and approval, and performance of the testing.

1

This area was not rated for Unit 2 in the previous SALP period.

l

-

The administrative procedures for the preoperational test program

l

were reviewed at the beginning of the assessment period, and

periodically throughout the period, by NRC inspectors.

The test

i

program was based upon the successful Unit 1 test program,. modified

to include lessons learned.

During the assessment period, several

'

issues were raised by the inspectors as a result of NT0L experience

at other sites regarding control of measuring and test' equipment,

communications with shift supervision, and the lack of verifiable

test records from component testing used to satisfy the optional

,

steps of preoperational tests.

In each case, the administrative

procedures were revised, and training was conducted for_all test

startup QA and startup QC personnel on the changes.

The Reactor Pressure Vessel Code Hydrostatic Test was'well planned

and executed.

The preplanning and attention to detail by both

Bechtel and PECo was evidenced by the heat stress screening and

training program which was conducted to ensure safety of personnel

during the test and by the planning of the pressure boundary walkdown

by 11 teams. The team composition included craft personnel, quality

control inspectors, quality assurance inspectors and-authorized

nuclear inspectors / authorized nuclear inservice inspectors as

i

appropriate. Thorough quality. control involvement and quality

assurance oversight was present during all test' phases as evidenced

by Bechtel review of quality documentation, and the conduct of careful

system walkdowns during the test.

l

On the whole, there has been good communication and cooperation between

the startup personnel and other work groups, including Quality Assurance.

i

The Startup Group managers have instilled in the group an attitude of

working together with the quality organization to ensure that the

work is performed and documented correctly.

This has at times led to

minor delays in testing while procedure changes were_ processed and

witness points worked out, but has at the same time ensured that all

the requirements were met.

The startup program has applied state-of-the-art vibration monitoring

to the initial operation of mechanical equipment. 'This has led.to

the identification and correction of minor deficiencies which could

t

have affected equipment service life.

Examples include the rebalancing

of the generator for the

'O' standby diesel generator, Residual Heat

Removal pump bearing replacement, and modifications to the foundations-

of the Turbine Enclosure Cooling Water Pumps. These' baseline data

initiatives will also be useful for future predictive. maintenance.

l

_ _

_--

,.

..

.

_

.

. _ _

_ _ _ - - -

-___

.

'

.

l .'"

.

1

15

l

Activities of the Test Review Board (TRB) have been assessed, including

i

procedure reviews, program reviews and test results review.

The

Test Review Board provided detailed technical reviews of preoperational

test procedures and ensured that all regulatory requirements and FSAR

commitments were satisfied in the procedure.

This review is guided

by a Regulatory Review List which is based, in part, on a key-word

.

search of the FSAR, generated by the TRB. The TRB,.on its own

l

initiative requested Nuclear Quality Assurance to perform a review of-

'its activities which led to recommended ways in which the TRB activities

could be enhanced. The TRB instituted a number of the recommendations,

including formalizing review procedures used by the TRB to ensure

.

better documentation of the procedure reviews performed. .The TRB

l

meetings were noted to be conducted in a professional manner and a

,

!

questioning attitude regarding procedure technical adequacy and. testing

l

philosophy was evidence that the TRB was functioning as an independent

organization.

I

The Startup Group has been utilizing personnel from tb station

!

Operations Group for performing many tasks in the tests. This

!

enhances the knowledge and training of the operators on the Unit 2

l

equipment, as well as provides feedback on equipment performance to

j

the test engineers. An example of this feedback was the retuning 'of

4

the governors and regulators for the Unit 2 Emergency Diesel

Generators to make the response more closely resemble that of their

Unit 1 counterparts, even though the governors and regulators were

{

initially within acceptable tolerances. Many of the test procedures

j

are intentionally based on the corresponding Unit 1 test procedures.

This helped to incorporate the lessons learned at Unit 1 into the

Unit 2 program.

In addition, a large percentage of the test engineers

have participated in the Unit 1 test program, which helps to bring

l

the lessons learned at Unit 1 into the Unit 2. test program.

Further,

the test personnel have often performed similar or identical tests on

the identical Unit 1 equipment.

These initiatives, in addition to

the inclusion of the system designers and equipment vendor represen-

tatives in the initial equipment operation contributed to the successful

,

completion of preoperational tests.

{

\\

1

Summary

!

l

A significant inspection effort of field activities conducted by. NRC

has found the testing to be performed in a controlled manner, with a

conservative approach, with quality program personnel in evidence.for

major steps and restorations.

The initial review of test results

i

found the documentation satisfactorily assembled.

Outstanding test

j

l

exceptions and problems are appropriately identified to engineering

j

for evaluation and resolution. Work activities are performed in

i

accordance with applicable guidance and regulations. Appropriate

'

monitoring of test performance and system / equipment post-test res-

toration is provided by the Quality Organization.

Good working

.

!

\\

' t

1

j

.

__.___a__

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

.-~

..

.

. .. .

.

..

. = .

.

...

..

-

.

. _ - - . _ _ .

.

,

-

.

. -

.

1

16

I

l

relationships between the various work groups (Startup, Field

Engineering, Instrumentation and Controls, Quality Control and Quality

Assurance), along with the management-instilled attitude of performing

the job correctly the first time have provided an effective smooth

l

running test program.

Conclusion

1

l

Category 1

Board Recommendation

None

I

l

,

l

I

._

'

.

-

.

s .

,

.

17

i

D.

Safety Assessment / Quality Verification (Inspection Hours Included in

Other Functional Areas

During the previous assessment period the area of Assurance of'

I

Quality was rated Category 2.

Areas;of strength. included. site

staffing and extunsive quality assurance monitoring and surveillance

activities.

Concerns regarding the control of the design interface

area were identified.

The resumption of project construction

activities was noted to be controlled in a suitable manner,

j

l

The PECo nuclear organization has been substantially revised.

One-

~

,

key facet of the organization change was the consolidation of the

!

~

l

multiple quality assurance / control groups that existed previously.

l

Additionally, the reporting relationship of the quality assurance:

-)

general manager was elevated within the PECo organization and~the

'

roles of the Independent Safety Engineering and Performance

Assessment groups were incorporated into quality assurance. These

measures have strengthened'the ability of quality assurance to

l

identify and analyze quality issues.

PEco has proactively performed assessments to determine the state of

the Unit 2 readiness for operations.

These initiatives include the

l

Readiness Program Assessment, the Operational Readiness Verification

'

and the Independent Design and Construction Assessment, These

reviews have included examination of programs, processes, documentation

i

and hardware.

The focus of the reviews is to examine Unit 2 readiness

I

with respect to licensing commitments in the area of facilities,

I

training, operating practices and programs as well as verifying the

adequacy of the plant design and construction. These extensive

multi-layered reviews provide an appropriate framework to ascertain

the operational readiness of Unit 2.

The previous Unit 1 SALP was

l

issued for the assessment period from February 1, .1987 through April-

30, 1988.

Table 4 provides the performance summary for the

operational areas that will be common for Unit 2 after license

issuance.

,

"

In response to concerns identified in the previous SALP, PECo quality

assurance has increased the frequency and scope of technical audits:

of engineering activities. These audits have been. effective in

~

identifying some areas of weakness in the application.of the design

l

control programs.

The licensee has been very sensitive to information disseminated in

NUREG-1275, Volume 1, regarding new plant operating experiences.

A

.

detailed review was performed of the recommendations identified in

the report in relationship to site practices. A presentation was

made to the Nuclear Review Board documenting the Limerick startup

.

program fulfillment of the . identified recommendations.

Factors such-

L

1

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

_ _ _

._

___

__

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

_

l

.

'

j

-

.

.v

..

'

.

18

as early involvement of the plant operations staff were fully

implemented during the test program.

A verification effort was

established for quality assurance to check the. implementation of the

recommendations.

Subsequently NUREG 1275, Volume 2, on plant air .

systems was similarly reviewed.

The resolution of NRC'open inspection items has been. aggressively

l

reviewed by PECo. Management attention was apparent in this area as

reflected by the dedication of several personnel to coordinate the

tracking and documentation of corrective actions.

Few closecut

l

'

_.

1

packages have been returned as a result of NRC review.

One isolated

shortcoming was noted in the corporate commitment tracking effort.

1

Measures are being instituted by PECo to enhance this system.

]

Plant safety committees have been closely monitoring Unit 2 activities.

As examples, in depth investigations.were per formed after several

plant evolutions caused water spills during Unit 2 test activities.

The Plant Operations Review Committee convened a special meeting to

review the circumstances of the spills, the intended corrective

actions and the ramifications upon Unit 1 operations. The Nuclear

!

jl

Review Board has raised concerns regarding design deficiencies that

have been identified on Unit 2 that also impact Unit 1 and has

received presentations from licensee engineering on that subject.

j

PORC and NRB have successfully functioned to monitor Unit 2

i

activities and assess their impact on Unit 1;

'

The licensee has established several mechanisms to address worker

concerns.

Either an exit interview is conducted with employees

leaving the jobsite, or a followup registered letter was sent to the

employee to solicit identification of quality problems.

NRC review

of selected concerns indicates that quality assurance personnel

perform appropriate investigations of the identified concerns. A

quality assurance hotline is available for all employees to address

The licensee systems appear effective in providing resolution

concerns.

of worker problems through normal organizational channels, handling

of exit interview quality concerns and a high degree of worker job

satisfaction.

l

'

On July 1,1988, PECo instituted a new fitness for duty policy

requiring drug testing for all employees with unescorted access. The

policy includes random testing in the future and strong disciplinary

'

.

actions for involvement with illegal drugs. Additional-deterrents

I

include the use of specially trained dogs to search the site.

Allegations regarding fitness for duty questions have' led to thorough

investigations and reinspection of potentially affected hardware.

The licensee has aggressively pursued a program to minimize fitness

for duty problems onsite.

c-

.

,

-

.

- .-

,

4

19

Recent industry problems have identified cases of out of

specification material supplied to nuclear projects.

PECo quality

assurance had previously implemented a long standing sampling program

to compare material physical and chemical aspects against the

specification requirements. The testing has included items such as

fasteners, structural steel and raceway components.

This additional

verification beyond normal receipt inspection practices has demon-

strated a conservative proactive approach toward nuclear safety.

Bechtel has implemented recent industry. guidance regarding the . .

.)

handling of commercial grade components. A procedure was developed

to guide component dedication and extensive research was performed to

l

identify currently installed commercial grade components. This new

3

program is intended to prevent recurrence of a problem where commercial

grade conduit couplings were supplied with incorrect certifications.

During this assessment period operations personnel were assigned to

man the Unit 2 control panels.

A full time shift' supervisor and

'

reactor operator were dedicated- to perform control room functions

during the course of pre-op testing.

The shift supervisor was involved

in pre-test briefings and was observed to question test methodology

to ensure that Unit 1 was not adversely affected or that potential

problems such as reactor vessel draindown would not occur. A new

position of Shift Startup Engineer (SSE) was established to coordinate

startup activities and to act as the liason between the operating

crew and startup test personnel.

These measures served to ensure

early involvement of the operating staff and to have a single individual

maintain overall cognizance of daily test activities.

On May 19, 1988, PECo initiated a comprehensive Independent Design

and Construction Assessment (IOCA) at Limerick 2 to compliment the.

Readiness Verification Program.

The assessment is being performed

i

by an independent contractor, Stone and Webster Engineering Company

'

(SWEC) under contract to PECo.

The NRC has conducted team

inspections at SWEC's Cherry Hill, NJ offices and on ' site to monitor

'

(1) preparation of the review plan and (2) implementation of the

'

review plans and construction assessment.

Overall, the teams found

that the SWEC assessment was comprehensive and met the IDCA program

requirements. While both SWEC and the NRC teams found a number of'

i

minor discrepancies, no major design or construction problems were

identified. Overall, the quality. of construction at Limerick 2 was

found to be excellent.

Efficient processing of the application for an operating license -

especially during the last six months of the process - requires

intense involvement by the applicant.

The FSAR needs to be updated

to accurately reflect and be current with the as-built plant.

The

Technical Specification (TSs) need to be finalized. Any changes

_

_ - - - _ _ _

.-.

,

x

R

j

,

..

,

1

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l

.u

a

,

'

.

-20'

l

,

required in the TSs for the. operating unit to permit tie-in of the

second unit need to be processed and issued in time to incorporate

the same changes in the proposed TSs.for the' license. All open

.

items. for licensing need.to be resolved and-addressed in an NRC

l

safety evaluation report supporting issuance of an operating license.

.In this respect, there are some areas where the' applicant's attention

to the staff's needs for information in support of thellicense appli-

cation would be helpful.

For example, there has been considerable.

delay in responses to some NRC initiatives such as closing out generic

l

and multiplant issues. The late receipt of an assessment.of design

changes has impacted NRC' review of FSAR revisions and thus preparation

1

of the NRC's' safety evaluation.

'

Summary

i

The PECo reorganization. strengthened the ability of Quality Assurance

to identify.and analyze safety issues,

The licensee has implemented

major self-assessment programs to assure the readiness for operation

of Unit'2.

Safety review groups have actively monitored the conduct

of preoperational tests and preparations for operation.

Proactive

y

measures have been taken in the area of surfacing worker concerns and

'

identifying discrepant materials supplied to the site. The licensee.

has been extremely responsive to concerns identified by the NRC.

Conclusion

i

Category 1

Board Recommendation

None

'

l

. -

- - _ _ _ _ _ _ _ _ _ _ -

_.

_

.

. . . ,

.

,

.

21

..

V.

SUPPORTING DATA AND SUMMARIES

A.

Enforcement Activity

No escalated enforcement actions or confirmatory action letters were

issued during the assessment period.

A synopsis of the issued

)

violations is shown in Table 2.

I

l

On October 22, 1987, an enforcement conference was held to discuss

l

the evaluation of the licensee's significant deficiency report

regarding the fire protection flow switch circuit design.

The licensee

l

committed to remove the standby diesel trip input from the switches.

l

Based upon the existing design criteria, the NRC agreed with the

,

licensee's position that the matter was not a reportable item.

B.

Investigations and Allegations

{

t

Ouring the assessment period routine inspection followup was

!

,

j

performed in response to the allegations identified below

i

'

--

(RI-87-A-0118): Alleged that a construction superintendent used

i

illegal drugs. The employee admitted drug use and was

]

terminated.

i

C.

Management Conferences

1.

September 8, 1987 - Meeting held between PECo and Region I to

discuss the power ascension test program.

The planned program

was compared with respect to other recent BWR startup programs.

PECo committed to amend the planned testing to include control

,

l

rod drive scram time testing at intermediate pressures.

2.

October 9, 1987 - Meeting held to discuss the interaction of the

fire protection flow switches and the standby diesel generators.

3.

April 21, 1988 - The new PECo president met with the Region I

Regional Administrator,

,

i

4.

May 13, 1988 - Meeting between PECo, Region I and NRR to discuss

the Readiness Verification Program. An Independent Design and

Construction verification initiative was proposed by PECo.

5.

May 24, 1988 - A followup meeting was held between PECo, NRR and

Region I to further discuss the independent design and

construction assessment activities.

6.

October 31, 1988 - A meeting between PECo and Region I to

discuss the plant status and planned tie-in outage with Unit 1.

_

_ _ -

-

,

O

O

'

.

22-

7.

November 2, 1988 - A meeting between PECo.and NRR to discuss

the plant status and planned tie-in outage with Unit 1.

D.

Construction Deficiency Reports

1.

General

During the assessment period 15 potential construction deficiencies

were reported by PECo.

Four reports were subsequently determined

to be non reportable based upon additional licensee investigation.

1

,.

The licensee has demonstrated an increased sensitivity to the

handling and evaluation of 10CFR50.55(e) items, since the last

l

SALP assessment.

The corrective measures and associated inves-

1

tigations are thorough. A tabulation of the 11 construction

deficiency reports by functional area is provided in Table 3.

'

2.

Causal Analysis

Seven of eleven Construction Deficiency Reports (CDRs) were

attributed to offsite manufacturer problems. These related to

wiring and termination errors, snubber overgreasing, and bus bkr-

l

material problems.

These issues were generally identified

'

l

through site testing activities.

Equipment failures brought th(e

l

bus bar problems to light and NRC inspection identified the

j

discrepant PGCC wiring.

{

One CDR was caused by the failure of site personnel to install

polyvinyl chloride insulated wire in accordance with the design

restrictions.

Two CDRs involved design errors that caused Appendix R safe

shutdown deficiencies. .These were identified during the course

of extensive Unit 2 reverification of the safe shutdown design

analysis.

One CDR arose during the preoperational test program when.the

the NRC requested to review the bases for the suppression pool

water test level. Licensee _ engineering found that some non-

1

l

conservative assumptions had been made in the original analysis.

1

..

I

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

-

l

1

.

,

e =

,

.

,

.

23

l

'

1

TABLE 1

l

Inspection Hours Summary

'

Limerick Generating Station Unit 2

August 1, 1987 - December 31, 1988

Functional Area

Hours

% of Time

,

1

l

A.

Construction

3,277

59

l

B.

Engineering / Technical Support

1,030

18

C.

Preoperational Testing

1,290

23

D.

Safety Assessment / Quality Verification

1

l

.....__________.._____.._________ ..._____________........___ ...........

l

TOTAL

5,597

100

'

1

_____ _____________ .______________________________________ ....______...

Hours expended in the area of safety assessment / quality verification are

included in other functional areas.

The period includes NRC inspection reports 87-12 through 88-26,

1

l

- - _ _ _ _ _ _ _ _ _ - - _ - _ _ _

-

,

.

*

.

,

24

l

TABLE 2

-

Enforcement Summary

i

I

Limerick Generating Station, Unit 2

.

August 1, 1987 - December 31, 1988

)

l

Number of Violations by Severity Level *

i

Functional Area

~~

~

Subtotal

IV

V

)

A.

Construction

3

2

5

]

)

B.

Engineering

2

1

3

C.

Preoperational Testing

0

D.

Safety Assessment / Quality

0

Verification

TOTALS

5

3

8

l

No escalated enforcement actions were imposed during the assessment period.

l

..

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

_

_ _ _ _ _

-

*

.

,

,,

,

25

TABLE 3

Construction Deficiency Report

Limerick Generating Station, Unit 2

August 1, 1987 - December 31, 1988

Cause Codes

Functional Area

A

B

C

D

E

F

G

Subtotal

A.

Construction

1

3

4

B.

Engineering

3

C.

Preoperational Testing

'3

1

4

D.

Safety Assessment / Quality

Verification

TOTALS

1

3

4

11

Cause Codes

A.

Personnel Error

B.

Design Error

C.

External

D.

Procedure Inadequacy

'

E.

Component Failure

F.

Fabrication Error

G.

Other

,

.

_ _ _ _ _ _ _ _ _ , - - - - _ _ - - - _ _ _

.

s'

,a a

,

.

26

TABLE 4

Performance Summary

Systematic Assessment of Licensee Performance

Limerick Generating Station, Unit 1

February 1, 1987 - April 30, 1988

Area

ML20236C259

Text

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