ML20236C259
| ML20236C259 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/15/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236C251 | List: |
| References | |
| 50-353-87-99, NUDOCS 8903220046 | |
| Download: ML20236C259 (28) | |
See also: IR 05000353/1987099
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SALP BOARD REPORT
______________________________________________________________________________
U.S. NUCLEAR REGULATORY COMMISSION
9EGION I
______________________________________________________________________________
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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
g PDC
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TABLE OF CONTENTS
Page
I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . 1 i
A. Purpose and Overview. . ................ 1
B. SALP Board Members. . . . . . . . . . . . . . . . . . . 1
C. Licensee Activities . . . . . . . . . . . . . . . . . . 1 j
D. Direct Inspection and Review Activities . . . . . . . . 2
II. SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . 3 ;
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A. Overview. ....................... 3
B. Performance Summary . . ............... .3
III. CRITERIA . . . . . . . . . . . . . .. . . . . . . . . . . . . 5
IV PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . 7
A. Construction. . . ................... 7
8. Engineering / Technical Support . .......... . 10
, C. Preoperational Testing. . . . . . . . . . . . . . . . * . 14 q
l D. Safety Assessment / Quality Verification. . . . . . . . 17 1
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V. SUPPORTING DATA AND SUMMARIES. . . . . . . . . . . . . . . 21
A. Enforcement Activity. . .... .......... . 21 l
B. Investigations and Allegations. . . . . . . . . . . . 21
C. Management Conferences. l
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l D. Construction Deficiency Reports . . . . . . . . . . . 22 !
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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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I. INTRODUCTION ,
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A. Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an i
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
management to improve the quality and safety of plant operations.
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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 ,
Assessment of Licensee Performance." A summary of the guidance and l
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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l S. Collins, Deputy Director, Division of Reactor Projects '(DRP) l
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
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
i 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 -
elected to the position of Executive Vice President-Nuclear. Later R
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
l 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 ll
17 month assessment period was 5,597 hours0.00691 days <br />0.166 hours <br />9.871032e-4 weeks <br />2.271585e-4 months <br /> or 3,951. hours on an
l annualized basis. Distribution of these hours by functional area is -
! 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 ,
examinations for dual unit licensed personnel. j
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,- "'
The NRC construction inspection program is approximately 95% complete,
a level commensurate with the plant status. NRC review of pre-
L 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 !
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 l
fully integrated into the implementation of the test program. l
l Extensive actions were taken to augment engineering programs in
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response to concerns identified in the previous assessment. The
control cf the design reconciliation with the as-built plant has been
performed in accordance with a well conceived program. Some apparently
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historical problems were identified with respect to items supplied
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)
A. Construction 1* 1
B. Engineering / Technical 2 1-
Support
C. Preoperational Testing **
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0. Safety Assessment / ***
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Quality Verification
l E. Assurance of Quality 2 N/A-
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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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l ** Area.not rated due to limited amount of inspection and test activity.
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- New functional area this period, replaces previous Assurance of Quality
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, q
Functional areas normally represent areas significant to nuclear-safety '
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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5. Construction events (including response to, analyses of, reporting
of, and corrective actions for);
6. Staffing (including management); and l
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7. 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
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 - .!
personnel performance is being' achieved.- Reduced NRC attention may i
be appropriate. !
2. 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 ,
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. j
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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 <br />0.0769 hours <br />4.580026e-4 weeks <br />1.053985e-4 months <br />; 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 a
were performed with unflawed specimens. The licensee revised-the '
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 '
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
reworked. The improper maintenance was caused by the lack of written'
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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 j
concern of maintaining system cleanliness. When identified'by the j
NRC, the licensee promptly established' appropriate internal' I
cleanliness control. measures. I
An extensive plant labeling program was initiated during this assess-
ment period. The labels are provided for piping, duct, instruments, y
valves and other components. Information regarding process flow I
direction, system identification and unit. identification are provided.
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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
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panel wiring identified di,crepant conditions. These involved a few
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 ,
aspects of this issue can be found in section V.D. of this assessment. '
l A comprehensive system turnover piocess was implemented for turnover-
l 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.
l QC inspection reports were generated to facilitate. control and-
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accuracy of this process, t
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
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 ,
effectively performed and the status of construction completion is- H
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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B. Engineering / Technical Support ( 18%: 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br />)
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
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interfaces. Also, independent, multidisciplinary engineering reviews
have been performed on selected design changes, design interfaces and
potential construction problem areas. These actions appear to be l
effectively assuring the continuity of requirements through the '
design and installation process. Several errors identified by the
NRC during this assessment period are attributable to problems that l
occurred previously in the General Electric and the Bechtel engineering l
and design interface. These errors included ambiguous designation of l
l component quality level, and incorrect redundant reactivity control l
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logic drawings and wiring. Extensive licensee reviews were perforned '
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.
l 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 )
Unit 1 programs. l
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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. The l
review plans were generally thorough in scope and were expanded '
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
l initiative that to date has provided.a high level of confidence in-
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the quality of desigr and construction at Limerick 2. The ongoing i
NRC inspection of the SWEC assessment has confirmed the plant '
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
l questioning of issues such as the use of zinc in lieu of malleable
1 iron conduit couplings and the non-safety related fire protection
flow switch trip of the standby diesel generators resulted in
! 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.
! 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. l
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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 .
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 '
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
l 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 I
and coordinate day-to-day work by Bechtel. The audit and surveillance i
function of the licensee is extensive and effective to control the '
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 i
process was well defined and included classroom instruction, plant
l walkthrough training and simulator instruction. Appropriate exami-
l 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
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successfully passed the' licensee examination also passed the NRC-
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
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corrective actions are completed. This is indicative of a conservative
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 j
' design' documents has been performed .in a careful. methodical'rature. '
- Ir,itiatives.such as the independent designLand construction
) . verification program have confirmed a. high quality of ' design- and l
l construction for Limerick 2. While.the reporting evaluations were- I
performed in a less than. satisfactory manner early in the l
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
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C. Preoperational Testing (1,290 hours0.00336 days <br />0.0806 hours <br />4.794974e-4 weeks <br />1.10345e-4 months <br />; 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.
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The administrative procedures for the preoperational test program
l were reviewed at the beginning of the assessment period, and
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periodically throughout the period, by NRC inspectors. The test
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
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.
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Activities of the Test Review Board (TRB) have been assessed, including
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
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
l
have participated in the Unit 1 test program, which helps to bring
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
.I
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...
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16 I
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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
running test program. l
Conclusion 1
l
Category 1
Board Recommendation
None
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i
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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
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-
.
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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
packages have been returned as a result of NRC review. One isolated 1
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 !
Review Board has raised concerns regarding design deficiencies that
have been identified on Unit 2 that also impact Unit 1 and has jl
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
concerns. The licensee systems appear effective in providing resolution
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.
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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 l
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
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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.
'
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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
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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
the evaluation of the licensee's significant deficiency report l
regarding the fire protection flow switch circuit design. The licensee l
committed to remove the standby diesel trip input from the switches.
Based upon the existing design criteria, the NRC agreed with the l
,
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 ;
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(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.
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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
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TABLE 1 l
l
Inspection Hours Summary '
Limerick Generating Station Unit 2
August 1, 1987 - December 31, 1988
Functional Area Hours % of Time
, 1
l
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
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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 IV
~~
V
~
Subtotal ;
)
A. Construction 3 2 5 ]
)
B. Engineering 2 1 3
C. Preoperational Testing 0 0 0
D. Safety Assessment / Quality 0 0 0
Verification
TOTALS 5 3 8
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- No escalated enforcement actions were imposed during the assessment period.
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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 3
C. Preoperational Testing '3 1 4
D. Safety Assessment / Quality
Verification
TOTALS 1 3 3 4 11
Cause Codes
A. Personnel Error
B. Design Error
C. External
D. Procedure Inadequacy '
E. Component Failure
F. Fabrication Error
G. Other
,
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26
TABLE 4
Performance Summary
Systematic Assessment of Licensee Performance
Limerick Generating Station, Unit 1
February 1, 1987 - April 30, 1988
Area Category
A. Plant Operations 1
l
l B. Radiological Controls 1
l
C. Maintenance 1
b. Surveillance 1
1
E. Engineering / Technical Support 2
'
F. Emergency Preparedness 2 ;
G. Security and Safeguards 1 l
H. Safety Assessment / Quality Verification 1 j
s
,
_ - _ _ - _ _ _ _ _