ML20237H984

Forwards NRR SALP Input for Plant for Period Jan 1986 - Jul 1987

ML20237H984
Person / Time
Site:	Limerick
Issue date:	08/21/1987
From:	Clark R Office of Nuclear Reactor Regulation
To:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8708250236
Download: ML20237H984 (13)

Text

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, August 21, 1987 Docket No. 50-353 MEMORANDUM FOR: James C. Linville, Chief Reactor Projects Section 2B i

Division of Reactor Projects Region I THRU: Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II

( FROM: Richard J. Clark, Project Manager Project Directorate I-2 Division of Reactor Projects I/II

SUBJECT:

NRR SALP INPUT - LIMERICK GENERATION STATION, UNIT NO. 2 Enclosed is the NRR SALP input for Philadelphia Electric Company's Limerick Generating Station, Unit 2 for tl jeriod January 1,1986 to July 31, 1987.

As discussed in the enclosure, our evaluation was conducted according to NRR Office Letter No. 44, dated December 22, 1986 and NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance. The overall performance rating in the functional area of Licensing Activities is Category 1.

Original signed by Richard J. Clark Richard J. Clark, Project Manager Project Directorate I-2 Division of Reactor Projects I/II

Enclosure:

As stated I

cc w/ Enclosure G. Kelly, Senior Resident Inspector, Unit 1 R. Gramm, Senior Resident Inspector, Unit 2 l

DISTRIBUTION

_ Docket File NRC PDR' local PDR PDI-2 Reading SVarga/BBoger WButler RClark/RMartin M0'Brien PD PDI-2/P ' d PDI-2/D F RClark:ni WBlitler ,. ,d F(87 4f//2/87 $/9/87 9708250236 870021 PDR ADOCK 0500 3

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[pa a< coq;o UNITED STATES

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)y WASHINGTON, D C 20555 l g-, rj August 21, 1987

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Docket No. 50-353 i MEMORANDUM FOR:

James C. Linville, Chief _

Reactor Projects Section 28 J Division of Reactor Projects Region I THRU: Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II FROM:

Richard J. Clark, Project Manager Project Directorate I-2 Division of Reactor Projects I/II

SUBJECT:

NRR SALP'TNPUT - LIMERICK GENERATION STATION, UNIT NO. 2 Enclosed is the NRR SALP input for Philadelphia Electric Company's Limerick Generating Station,' Unit 2 for the period January 1,1986 to July 31, 1987.

As discussed in the enclosure, our evaluation was conducted according to NRR Office Letter No. 44, dated December 22, 1986 and NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance. The overall performance rating in the functional area of Licensing Activities is Category 1.

1, /

R haf J. lark, Project Manager PhojectDirectorateI-2 Division of Reactor Projects I/II

Enclosure:

As stated cc w/

Enclosure:

G. Kelly, Senior Resident Inspector, Unit 1 l R. Gram, Senior Resident Inspector, Unit 2 l

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Docket No. 50-353 FACILITY: Limerick-Generating Station, Unit 2 APPLICANT: Philadelphia Electric Company EVALUATION PERIOD: January 1, 1986 to July 31, 1987

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PROJECT MANAGER: Richard J. Clark

1. INTR 0 DUCTION This report contains NRR's input to the SALP review for the Limerick Generating Station, Unit No. 2. The assessment of the applicant's performance was conducted according to NRR Office Letter No. 44, "NRR Inputs to SALP Process," Revision 1. dated December 22, 1986. This Office Letter incorporates NRC Manual Chapter 0516. " Systematic Assessment of Licensee

< Performance."

II.

SUMMARY

NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a composite of a number of attributes. The single final rating should be tempered with judgement as to the significance of the individual elements.

The licensee has, in general, continued the high level of performance of the previous two SALP evaluations in the Licensing Activities area. Overall, the licensee's strong points are the approach to problems from a safety standpoint, the responsiveness to NRC concerns, the qualifications and depth of staffing and the reporting of events. Senior management control is widely apparent and particularly when a response to a problem is called for.

' Based on this approach, the performance of the Philadelphia Electric Company in the functional area - Licensing Activities - is rated Category 1.

III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 and its Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.

IV. METHODOLOGY This evaluation represents the integrated inputs of the Project Manger (PM) and those technical reviewers who expended significant amounts of effort on Limerick Generating Station Unit No. 2 licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the PM and

each reviewer applied specific evaluation criteria to the relevant licenses performance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1, 2 or 3) to each attribute. The reviewers included this information as part of each Safety Evaluation input transmitted to the Division of Reactor Projects, I/II. The PM, after reviewing the SALP inputs of the technical reviewers, combined this information with his own assessment of I applicant performance and, using appropriate weighting factors, arrived at a composite rating for the applicant. This rating also reflected the comments of ,

the NRR Senior Executive assigned to the Limerick SALP assessment. l A written evaluation was then prepared by the PM and circulated to NRR l management for comments which, where provided, were incorporated in the final l 1

draft. f The basis for this appraisal was the applicant's performance in support of ]

licensing actions that were either completed or had a signifi: ant level of j activity during the rating peM od. These actions included 5 issues related to '

ui.it 2 construction.

In Janery 1986, the applicant resumed construction on Unit 2. As of the end of the ra'ing period, the Unit is considered about 70% completed. The applicant's +arget fuel load date is June 1989.

V. ASSESSMENT 1F PERFORMANCE ATTRIBUTES The applicant's pt.aformance evaluation is based on a consideration of the seven attributes sp'cified in NRC Manual Chapter 0516. In addition to the above, housekeeping in and around the plant is also discussed. These are:

• Management involvement and Control in Assuring Quality Approach to Resolution of Technical Issues from a Safety Standpoint Responsiveness to NRC Initiatives

• Enforcement History Reporting and Analysis of Reportable Events *

• Staffing (Including Management)

Training and Qualification Effectiveness The applicant's performance for the Licensing Activities functional area was evaluated for seven of the eight attributes listed above. The data base of experience in this rating period for the remaining attribute (asterisked above) was too minimal for meaningful evaluation.

a A. MANAGEMENT INVOLVEMENT AND CONTROL IN A3SllRING QUALITY On November 24, 1986, the directors of Philadelphia Electric Company reorganized the executive organization and elected new officers. Formerly, Electric Production and Engineering and Research were separate organizations, each reporting to the President and Chief Operating Officer, J. H. Austin.

Now, Nuclear Operations, Engineering and Research and Electric Production report to John S. Kemper, Senior Vice President for Engineering and Production. The Vice President for Nuclear Operations, Joseph W. Gallagher ie responsible for all aspects of nuclear activities at Peach Bottom and Limeric except for maintenance and nuclear records. Maintenance for all Philadelphia Electric Company facilities is the responsibility of Marty J. McCormick, Manager, Maintenance Department, who reports to Alvin J. Weigand, Vice President, Electric Production. The changes are intended to provide heightened management attention to nuclear activities including licensing related activities. . _ _ ,

Since Engineering and Research is principally responsible for directing Bechtel's activities during construction of Unit 2, the licensing staff for Unit 2 is part of the Mechanical Engineering Division of Engineering and Research. The licensing staff for Unit 2 is distinct from the licensing staff for Unit 1; the latter is part of the Nuclear Support Department under Nuclear Operations. The two licensing staffs maintain close coordination with each other.

During the SALP evaluation period, the applicant has shown good management overview in the area of licensing activities. The applicant's licensing staff has met with us to apprise us of their plans for preoperational testing and to bring some of the Unit 2 support systems such as the RHRSW system (which will eventually tie into and provide common support to Units 1 and 2) under Technical Specification requirements prior to fuel load.

On the basis of these observations, a rating of 1 is assigned in this area.

B. APPROACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOIN l

The applicant maintains a significant technical capability in almost all j engineering and scientific disciplines necessary to resolve items of concern to the NRC and the licensee.

In addition, the applicant utilizes the services l of nuclear support groups to assist in the resolution of technical problems or to utilize new and proven techniques that will enhance the operation and safety of the plant.

The applicant's technical capability is reflected in the submittals made in support of or in response to applicant or NRC initiated actions. The good )

communications between the applicant and NRC Staff have been beneficial to both in processing of licensing actions and minimizing the need for additional information.

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4-The applicant's efforts towards the resolution of safety issues is evident by its active participation and close contact with various industry groups involved in the identification and resolution of safety issues. These groups include the BWR Owners Group, the Institute of Nuclear Power Operations, the Seismic Qualification Utility Group, the Nuclear Utilities Fire Protection Group, the Nuclear Utility Group on Station Blackout, IDCOR, the Nuclear Utility Management and Resource Committee, the Atomic Industrial Forum, and the American Nuclear Society.

The rating for this attribute is Category 1.

C. RESPONSIVENESS TO NRC INITIATIVES The applicant has been responsive to NRC initiatives in most instances.

Schedules are negotiated with the licensee based on priorities. The applicant meets deadlines and notifies the NRC staff well in advance of any schedular problems. The applicant facilitates a timely resolutica of most issues.

Submittals are technically sound and thorough; acceptable resolutions are proposed initially in most instances.

Based on the above, a Category 2 is assigned to this criterion.

D. ENFORCEMENT HISTORY The Project Manager has occasionally had the opportunity to participate in inspections and audits at the site during the rating period. The applicant has taken actions to resolve deficiencies, deviations and open items in a satisfactory manner. The applicant's contact with the resident, regional and j headquarters personnel was professional.

A rating of.1 has been assigned to this attribute.

1 E _. REPORTING AND ANALYSIS OF REPORTABLE EVENTS The applicant has filed a Part 21 report whenever there has been anEvents indication l

of a possible deficiency or defect in items processed for Unit 2.

involving security issues have been promptly reported and assessed.

There has not been sufficient activity in this area with respect to licensing l l

activities to assign a meaningful evaluation.

l l F. STAFFING (INCLUDING MANAGEMENT)

The licensing group has exhibited a high degree of cooperation with the NRC staff. The good communication between the ifcensing group and the NRC has The been beneficial to both of us in the processing of licensing actions.

l applicant's licensing staff is always responsive to our requests and l

inquiries. The staff regularly is at the plant site to keep abreast Inof plant

! activities. Areas of expertise are well defined within the group.

addition the group does en excellent job of enordinating the effort when input l 1 l

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is required from the different groups within the applicant's organization.

The licensing engineers are knowledgeable and keep abreast of all licensing actions. Most of the senior licensing staff members in the Nuclear Support Department have had operational experience at either Peach Bottom or Limerick.

The corporate staff level in Philadelphia has been ample to meet the needs of the licensing activities during this period. This has been demonstrated in meetings and discussions with the NRC staff wherein the PEC0 staff level participation in virtually every instance has been adequate to meet the ob,iectives of the meeting.

Based on the licensing group's performance a SALP rating of Category 1 is given to this criterion.

G. TRAINING AND QUALIFICATION EFFECTIVENESS The bases for our assessments ~tn this topic are the Project Manager's contacts with the corporate licensing staff and the plant staff during the rating period. There were no scheduled NRR review activities concerning licensee training and qualification programs during this rating period.

Nevertheless the Project Manager has found that the training and qualifications of the licensee's corporate staff are adequate. This finding is due in part to the relatively low turnover of key technical and managerial personnel, many of whom have been with the licensee throughout much of the Unit 1 operating licensing review.

A SALP rating of Category 2 is assigned to this area.

H. HOUSEKEEPING Limerick Units 1 and 2 share common reactor and turbine buildings. Unit 2 is located between Unit 1 and the Administration Building and the Technical Security Support Center. Since Unit 1 is operating, it is a protected area.

fences severely restrict the movement of personnel and material on site. Based on the Project Manager's limited observations, the applicant has done a commendable job of coping with this problem. The applicant appeared to be maintaining a high standard for plant housekeeping and cleanliness.

l A rating of Category 1 is assigned to this area.

VI. CONCLUSION The applicant's licensing activities are conducted by a well staffed and well trained group resulting in an overall efficient operation. Management overview is evident in that the licensing group is well integrated into other plant activities and licensing activities reflect a uniform approach.

Upper management becomes involved in licensing actions when necessary to assist in resolving the more difficult issues. i f

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- The' applicant's greatest strengths appear to be in the'following areas:

Approach to Resolution of Technical Issues frohi a Safety Standpcint - The applicant has extensive technical capability that is reflected in their submittals and discussions with the NRC. .

Staffing - The applicant continues to upgrade the experien'ce, capability and effectWeness of the licensing group and the supporting administrate'ive and technical personnel to provide the necessary submittals 'for an ' operating license.

Based upon'the evaluation of the above criterion, an overall SALP rating of Category 1 is assigned to the area, of " Licensing Activities."

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GPPENDiX A 1.1MERICK UNIT 2 NRR SUPPORTING DATA AND

SUMMARY

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1. NPR-Applicant Meetings february 25, 1936 - Projected schedules for Unit 2 Construction April 30, 1986 - Projected review processes for Unit 2 issues October 1,1986 - Projected schedules for licensing activities October 8,1986 - Use of ASME Code Case N-411, Snubber Optimization November.7, 1986 - Use of ASME Code Case N-411, Snubber Optimization December 3, 1986 - Use of ASME. Code Case N-411, Snubber Optimization January 15, 1987 - Use of ASME Code Case N-411, Snubber Optimization April 29, 1987 - Projected schedules for licensing activities Ma, 14, 1987 - Plans for Incorporating Unit 2 RHRSW, l J / and Diesel Gene?ators into Unit -1 TSs and Protected Area 2.. NRR Site Visits June 2-3, 1986 - PM attended two days of General Employee Training (GET) at plant; general site tour Jm 2 30, 1986 - PM and Licensino Assistant visited site; walk-through of l' nit 2 June 24-25, 1987 - GET Training, 9ener.il site visit July 2, 1987 - Site visit

3. Commission Briefings Nore 4 .- Schedule Extensions Granted None. Not applicable since Plant is still under construction

5. R,eliefs Granted None

6. Exemptions Granted None

7. License Amendments Issued None. Not applicable since Unit 2 does not have License

8. Er.ergency Technical Specification Chanoes Granted None a

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9. Orders Issued NRR did not issue any Orders during this SALP period. The ASLB and ASLAB issued various Orders relating to the hearings on this plant 10, %RR/ Applicant Manaaement Conferences None b . _ _ . - _ . - _ _ _ _ _ - . _ - . _ . - - -

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,- r-L APPENDIX 8

SUMMARY

OF PREVIOUS NRC SALP EVALUATIONS FOR THE LIMERICK GENERATING STATION (The SALPs Primarily Evaluated Limerick Onit 1 Since. Construction of Unit 2 Was On Hold)

Functional- Trend Area 2/1/83 - 11/30/84 12/1/84 - 1/31/86 (Note'1)

A. Plant Consistent 2 1 Operations B. Radiological Controls 2 2 (Note 2)

- Not Evaluated 2 Consistent C. Maintenance Not Evaluated 2 Consistent D. Surveillance E. Emergency 2 3 Consistent  ;

. preparedness

'F. Security and Consistent 3 3 Safeguards G. Preoperational &'

Startup Testing 2 1 (Note 3)

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H. Training & Quali-fication Ef#ce.tive- 2 ho basis ness Not Evaluated Licensing Activities 1 Consistent I. 1 i

J. Assurance of No basis Quality Not Evaluated 1 Notes: 1. The low power license was issued in October 1984, the full 1

power license was issued in August 1985, and commercial operation was achieved in February 1986.

2. A high level of performance could not be confirmed since Radiological Control Programs had not yet been significantly challenged.

3. Progressive improvement was noted throughnut the assessnent period.

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Licensing Activities

1. Analysis The previous SALP evaluations for Limerick covered both units, since both facilities were under construction for all but the last six months of the last evaluation period. The last SALP evaluation (December 1984 to January 1986) on L merick dealt only with Unit 1, since construction i

of Unit 2 was on hola. To provide a historical perspective, licensing activities were rated as Category 1 during the two previous assessment periods based predominantly on issues associated with issuance of the low power and full power licenses and completion of the startup test program for Unit 1. The previous assessment concluded that management involvement was apparent and very productive, that a high degree of licensee respon-siveness was exhibited, that corporate staffing levels were stable and that reportable event frequencies had improved significantly. An area of potential weakness was noted in the maintenance of oversight to ensure that forthcoming schedular requirements were recognized and were responded to in a timelyinanner.

This assessment is based principally on the applicant's performance in support of five issues related to the proposed design of Unit 2. The most significant licensing action was submitted in March 1986, twc months after resumption of construction, and involved a proposed reduction in the number of snubbers in Unit 2 (compared to Unit 1) based on ASME Code Case N-411. While the applicant's initial submittal on the snubber issue was inadequate, the applicant was responsive in providing the additional information requested by the staff; the subsequent submittals were of high quality.

During this SALP evaluation period, the applicant has demonstrated good PECo's licensing management overview in the area of licensing activities.

staff has met with us on several occasions to apprise us of the status of Ur.it 2 construction, and the projected schedules for future submittals I

that will require NRC review.

One of the applicant's principal strengths is its approach to resolution of technical issues from a safety standpoint. The applicant's proposals

( have been technically sound and have reflected acceptable margins of safety. The applicant maintains a significant technical capability in almost all the engineering and scientific disciplines necessary to resolve items of concern to the NRC.

In addition, the applicant utilizes the services of nuclear support groups to assist in the resolution of technical l problems or to utilize new and proven techniques that will enhance the l safety of the plant. The good communications between the applicant and NRC staff have been beneficial to both in processing of licensing actions f and in minimiting the need for additional information.

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l The applicant has been responsive to NRC initiatives and requests for information. The applicant has been willing and takes the initiative in arranging appropriate resources for conferences and meetings whenever this would assist in resolution of an issue.

The corporate staff level in Philadelphia has been ample to meet the needs of the licensing activities during this period. This has been demonstrated in meetings and discussions with the NRC staff wherein the staff level has in virtually every instance been adequate to meet the objectives of the meeting. Since PEco's office of Engineering and Research is principally responsible for directing Bechtel's activities during construction of Unit 2, the licensing staff for Unit 2 is part The of the Mechanical Engineering Division of Engineering and Research.

licensing staff for Unit 2 is distinct from the licensing staff for Unit 1; the latter is part of the Nuclear Support Department under Nuclear Operations. The two licensing staffs maintain close coordination with each other, which has been-beneficial, since the Unit I licensing staff has had substantially more operational 2xperience.

2. CONCLUSION The applicant's licensing activities are conducted by a well staffed and trained group resulting in an overall efficient operation. Strong manage-ment overview is evident in that the licensing activities reflect a uniform approach. Upper management becomes involved in licensing actions when necessary to assist in resolving the more difficult issues.

Recommended Rating: Category 1 Recommended Trend: Consistent Recommended Actions: None

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