ML20247A278
| ML20247A278 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/21/1989 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8903290086 | |
| Download: ML20247A278 (12) | |
Text
_____-. -_. _ ___ _.-____ _ _
l 3890011500
- 4 PHILADELPHIA ELECTRIC COMPANY e
I,lMERICK GENER ATING STATION P. O. BOX A SAN ATOG A. PENNSYLV ANI A 19464 (215) 3271200, EXT. 3000
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March 21, 1989 Docket No. 50-353 Construction Permit No. CPPR-107 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Subject:
Limerick ~ Generating Station, Unit 2 Power Ascension Self-Assessment Program
Dear Sir:
In response to a request by W. T. Russell, NRC Region 1 Administrator, Philadelphia Electric Company will conduct a self-assessment of the performance of-the Limerick Generating Station during the Unit 2 Power Ascension Program starting with Initi'al-Fuel Loading.
The operation of Limerick Unit 2 and the performance of the Limerick Generating Station will be assessed by the Site Management Oversight Committee during this period.
The assessment program will evaluate the following areas:
1.
Adequacy of the Unit 2 and common systems for safe and reliable operation.
2.
Control room operations and professionalism.
3.-
Teamwork and communications.
4.
Engineering and_ maintenance support services.
5.
Organizational interfaces, involving both onsite and offsite groups..
l-6.
Plant configuration control.
l 7.
Procedural adequacy and effectiveness of implementation.
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1 3890011500 March 21, 1989 Page 2 of 3 1
The Self-Assessment Program (refer to flow chart on Figure 1) will use as input the existing plant performance monitoring programs which will be expanded to include both units.
The performance of plant equipment, systems and personnel, including support organizations, will be evaluated bi-weekly by the plant management and the nuclear quality assurance organization management.
The evaluations will be based on the input from the plant programs and direct observations and interactions with personnel by the i
management personnel performing the evaluations.
These evaluations will be reviewed and evaluated by plant line management at a bi-weekly Plant Operations Review Committee (PORC) meeting.
This meeting will be augmented by attendance of representatives from organizations which support and interface with the Limerick Generating Station.
The augmented PORC will assess plant performance and the effectiveness of the identification and resolution of problems in the areas listed above and the overall readiness of the plant for continued power ascension testing.
The results of the assessment will be recorded in the PORC meeting minutes.
Following completion of Fuel Loading and Zero Power Testing l
Phase, Low Power Testing Phase, and Test Condition 2, the Site Management Oversight Committee will review and evaluate overall station readiness to continue power ascension testing.
Details of the evaluation and assessment process are contained in the attachments to this letter.
The Site Management Oversight Committee will consist of the following:
Vice President, Limerick Generating Station (Chairman)
Sr. Vice President, Nuclear Construction (Alternate Chairman)
Manager, Limerick Quality Division (NOA)
Chairman, Nuclear Review Board Plant Manager, Limerick Station (LGS)
Manager, Performance Assessment Division (NOA)
Project Manager, Limerick Station (LGS)
Support Manager, Limerick Station (LGS)
Manager, Nuclear Engineering Division (NED)
Plant Manager, Peach Bottom Station (PBAPS)
Training Superintendent, Limerick (LGS)
Manager, Nuclear Support Division At the completion of Test Condition 2 and prior to exceeding 50%
power, the Site Management Oversight Committee will prepare a report to summarize the assessment activities.
The report will provide a specific recommendation concerning readiness to continue power ascension, operations and testing above 50% power.
3890011500 March 21, 1989 Page 3 of 3 Prior to exceeding 50% power on Unit 2 the assessment report
-will be provided to the NRC Region 1 for review.
During the review period, power ascension testing will continue in Test Condition 3.
with power level limited to 50%.
Issuance of this report to the NRC will conclude.the special Self-Assessment Program.
Permanent routine management performance monitoring programs-will continue to assess performance of the Limerick Generating Station through the remainder of the Power Ascension Program and during commercial operation.
A. final report summarizing performance during the entire Power Ascension Program will be provided to the Site Management Oversight Committee by the plant staff after commercial operation of.the unit is achieved.
The following attachments are provided to describe the details of the Self-Assessment Program:
Figure 1 - Overview of Self-Assessment Program Figure.2 - Power-Flow Operating. Map - Input to Self-Assessment Program - Bi-weekly Self-Assessment - Site Management Oversight Committee Assessment If you need additional information or have any questions, please do not hesitate to contact us.
Sincgre y,
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1 ROH:ljm Attachments cc: R.
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Clark, USNRC Project Manager W.
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Russell, Administrator, Region I, USNRC R.
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Gramm, USNRC Senior Resident Inspector, LGS-2 3
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3890011500 ATTACHMENT l' s" **
.Page 1. of;4>
I INPUT TO SELF-ASSESSMENT PROGRAMS I.
Plant' Administrative Program This.section provides a summary-of Plant Administrative Programs that will be reviewed as part of the Self-Assessment Program.
A.
, Event Reports - Liste'd below are reports that-identify and analyze operational events, conditionsfor.
situations.
These. documents also provide a tracking mechanism-to verify that events are investigated and identified causes or concerns are. resolved.
Transient Scram Reports Plant Upset Reports Plant Incident Tracking Program Licensee Event Forms Radiological Awareness Reports Excessive Exposure Evaluations Personnel Contamination Record B.
System / Equipment Status - Listed below are the items that report, log or identify specific problems that are related to system or equipment operation.
Preventive and Corrective Maintenance Requests Temporary Circuit Alterations Startup Test Plateau Summaries L
Startup Test Exception Reports Chemistry Reports System Operability Status Surveillance Test List (Master Test Schedule)
Surveillance Test List (Master Test Schedule-Reschedule)
3890011500-ATTACHMENT 1 j
Page 2 of 4
~
l C.
Regulatory Activity - Listed below are items that report l
on activities related to compliance with regulatory requirements and commitments.
Suspected Licensee Event Reports NRC Inspection Exit Summaries NRC'Open Items NRC Inspection Violatior.s Regulatory Support Group Bi-weekly Report D.
Programmatic Items - Listed below are logs and reports that provide indicators of satisfactory performance related to plant programs.
Temporary Procedure Changes PORC Open Items Startup Test Procedure Change Notices Consolidated Open Items List Contaminated Area Survey Data Modification Status Engineering Support Status j
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3890011500-
-ATTACHMENT'l 7"
Page 3 of 4-u EII._ Nuclear Quality Assurance This'section provides a' summary of the activities of the
- Nuclear Quality Assurance Organization that will be used by the Self-Assessment Program.
LA..
LGS-Quality Division I
LGSDQuality Division (LQD) will perform a review of the-Startup Test: Procedures (STP) result packages to ensure all applicable test objectives.and acceptance criteria are satisfied prior to PORC review and approval at_the completion of a test. plateau.
LGS. Quality will also perform a series of audits. commencing with fuel load and concluding with the fuel warranty run.
These audits will address qualification of test personnel,: selected testing activities, PORC review of completed test packages, Test Exception Reports (TER) and Startup Test Change Notices (STCN). In addition, LGS Quality will monitor the Power' Ascension Program.
Areas covered will include but are not limited to, test performance, control room activities, communications, and acceptance criteria verification.
The established monitoring programs will continue during the period.
LGS Quality Division will provide the bi-weekly augmented PORC a summary of the activities performed for their evaluation / assessment.
B.
Independent Safety Engineering Group (ISEG)
During the. LGS Unit 2 Power Ascension Program, ISEG review will focus on testing which could result in significant challenges to plant systems or plant operation.
ISEG will independently evaluate and review safety evaluations for Test Exception Reports (TER) associated with acceptance criteria deviations.
Additionally, ISEG will review selected test results packages for technical accuracy and perform investigations of selected plant events.
I
3890011500 ATTACHMENT 1
~
~
Page 4 of 4 C.
Performance Assessment Division (PAD)
During the LGS Unit 2 Power Ascension Program, PAD will be assessing the status and condition of plant equipment, the adequacy of programs and the performance.
of plant personnel based on the INPO Performance Objectives and Criteria.
The methodology of the assessment will be the established PAD approach, consisting of team inspections, observation of procedures in use, activities in progress, personnel performing normal evolutions and tests, and interviewing on a not-to-interfere basis.
A typical assessment covers a 4-5 day period, including backshift coverage.
The assessments will be performed at various points throughout the Power Ascension Program.
1 I
i 1
3890011500 ATTACHMENT 2 Page 1 of 1 1
BI-WEEKLY'SELF-ASSESSMENT Every other week at a scheduled augmented PORC meeting, an assessment of the Limerick Generating Station operations will be.
made based on the input described in Attachment 1.
In addition to the required PORC membership specified in the Technical Specification, this PORC meeting will be augmented by non-voting; representatives from the following organizations:
Training LGS Operations Power Ascension Program LGS Technical / Regulatory LGS Quality Division LGS Maintenance /I&C Independent Safety. Engineering Group LGS Plant Services Performance Assessment Division LGS Support Division Nuclear Engineering Division Engineering Project Management
. Prior to the augmented PORC meeting, a data package reporting plant performance along with a brief written evaluation of the Plant Operations will be prepared based on a review of the items described in Part I of Attachment 1.
This evaluation will also include a qualitative assessment of plant operations by Operations Management based on participation in the daily Shift Superintendent's Meeting TRIPOD (three-day look ahead planning) and informal discussions with the plant operations personnel and site support groups.
The NQA Department will prepare similar evaluations to provide PORC a summary of activities described in Part II of Attachment 1.
The augmented PORC will. discuss these reports and consider comments from the representatives of the organizations in attendance.
Any corrective actions identified by PORC will use the appropriate plant program to ensure they are addressed and resolved.
These items will be included as PORC Open Items until the resolution is reviewed by PORC.
The PORC assessment of operations will be documented in the PORC meeting minutes.
3890011500 ATTACHMENT 3 Page 1 of.1 SITE-MANAGEMENT OVERSIGHT COMMITTEE ASSESSMENT As described in the body of the Self-Assessment Program letter, the-Site Management Oversight Committee will meet ~to assess Limerick Generating Station operations at the conclusion of the following Unit 2 test phase's. '(see Figure 2).
1.
Initial Fuel Load /Zero Power-Testing Phase 2.
Low Power Testing Phase 3.
Test Condition 2 The committee will review the evaluations presented to the bi-weekly augmented PORC meetings described in Attachment 2 and appropriate specific reports from the programs described in Attachment 1. requested by the committee.
Nuclear Quality Assurance will present assessments of its consolidated observations and findings including corrective actions completed or pending for findings which were identified to the Site Management Oversight Committee.
Based on the committee's assessment, any concerns will be identified and corrective actions accomplished-through the appropriate plant administrative program.
Plant Management will provide the committee with a status of these corrective actions on a periodic basis to ensure that the resolution of each item addressed the concerns of the-committee.
The committee evaluations will be documented by meeting minutes which will be transmitted to PECo corporate executives.
At the conclusion of Test Condition 2, the Site Management Oversight Committee will review their previous eva*.uations and the bi-weekly assessments by the PORC.
The committee will make an assessment of LGS Unit 2 operation and overall performance of the Limerick Generating Station including a review of the status of the corrective actions that had been identified during previous assessments.
Based on this assessment, a report will be prepared to address performance in each of the areas evaluated during the Self-Assessment Program.
The areas as identified in the body of this letter are:
1.
Adequacy of the Unit 2 and common systems for safe and reliable operation.
2.
Control room operations and professionalism.
3.
Teamwork and communications.
4.
Engineering and maintenance support services.
5.
Organizational interfaces, involving both onsite and offsite groups.
6.
Plant configuration control.
7.
Procedural adequacy and effectiveness of implementation.
This report will be submitted and discussed with NRC Region 1, prior to authorizing plant operations and testing above 50% power.