ML20247B865
| ML20247B865 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/17/1989 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20247B869 | List: |
| References | |
| NUDOCS 8905240263 | |
| Download: ML20247B865 (10) | |
See also: IR 05000353/1989200
Text
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WASHINGTON, D. C. 20555
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May 17, 1989
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, J Docket Noi 50-353
Mr. _ George A. Hunger, Jr.
Director-Licensing
ATTN: Correspondence Control Desk
. Philadelphia. Electric Company
2301 Market Street
'
Philadelphia, Pennsylvania 19101
Dear'Mr. Hunger:
SUBJECT:
INSPECTION OF CORRECTIVE ACTIONS-FOR THE INDEPENDENT CONSTRUCTION.
ASSESSMENT, LIMERICK GENERATING STATION, UNIT 2: REPORT 50-353/89-200
The Nuclear Regulatory Consnission (NRC) conducted an inspection of corrective
actions by Philadelphia' Electric Company (PECO) related to the " Program for
the Independent Design and Construction Assessment (IDCA) of Limerick Unit 2."
The NRC reviewed, on a sampling basis, PECO's corrective actions for deficien-
cies identified.in the construction assessment report published by PECO's:
independentcontractor,StoneandWebsterEngineeringCompany(SWEC),andth'e
deficiencies identified in NRC Report 50-353/88-202. This NRC inspection was.
conducted ~en-site'at Limerick Generating Station, Unit'2, during March 27-31,.
j
1989, with the exit meeting conducted March 31,.1989. Enclosed with this
'
letter are an executive sununary and the subject inspection report.
The NRC inspection team concluded that SWEC's independent construction-
assessment (ICA):ofLimerickUnit2followedtherequirementsofthe'overall
IDCA program for identifying and recording deficiencies as observation
reports. . In general, Bechtel Corporation's responses to the observation
. reports wert. comprehensive, SWEC's approval t,f the final responses were
appropriate, and Bechtel's corrective actions reviewed by the NRC team were
technica31y proper.
,
The NRC' team found, however, that the final resolution of one observation
report required additional inform & tion. 'One construction observation report
documented several pipe support grouted-ir, anchors that did not meet the
requirements for thinimum embedment length. The respoase to this observa-
l
tion report did not adequately justify excluding other' applications of
1
grouted-in anchors such as those' for platform steel and equipment anchorage.
Additional'information that PECO provided after the inspection is currently
- being reviewed by the appropriate NRR technical staff.
,
l
The NkC team also reviewed, on a sampling basis, PECO's corrective actions in
l
response to deficiencies identified in NRC Report 50-353/88-202, which docu-
mented our review of SWEC's on-site ICA effort and our independent construc-
t
-tion inspection. The corrective actions in response to individual discre-
pancies noted in the report were attached to John S. Kemper's letter to the
NRC dated March 29, 1989.
In general, the responses to the NRC identified
discrepancies were appropriate and the corrective actions taken by PECO were
adequate. However, full resolution requires additional infonnation or action
8905240263 890517
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Mr. Georg] A. Hung:r, Jr.
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M8Y 17. 1989
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by PECO. Your are requested to respond to this letter
within 30 days, addressing the following:
l
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'
Verification that the wire size used for motor leads on the operator
for valve HV-52-2F001C is adequate for its application (Section
4.4.2);and
A clarification of your construction quality assurance program as
it relates to your response to COR-056 (Section 4.6).
These items have been discussed with your staff during the inspection and at
the exit meeting. Since the IDCA program did not provide a mechanism for
changing SWEC's reports, any revisions to amplify or clarify your responses
to observation repotts in the SWEC ICA report should be submitted with your
response to this report.
Similarly, any revisions to your response to NRC
report 50-353/88-202 should also be addressed in your response to this report.
Although there are several items which remain open, none of these items,
either individually or collectively, is of sufficient safety significance to
impact the upcoming licensing decisions involving Limerick, Unit 2.
The items
which remain open are listed in Enclosure 2 to this letter, one of which is
identified as as an unresolved item. These items, however, should be resolved
i
before the full power license is granted. Some of the items identified by the
inspection team may be potential enforcement findings. Any enforcement
actions will be identified by Region I in separate correspondence.
Should you have any questions concerning this inspeution, please contact me
or Mr. Eugene V. Imbro at (301) 492-0954.
Sincerely,
1
Steven A. Varga, Director
Division of Reactor Projects I/II
Office of Noclear Reacter Regulation
Enclosures:
(
1.
Executive Summary
{
2.
Inspection Report 50-353/89-200
cc: See next page
5520 Document Name: Limerick ICA Report
- SEE PREVIOUS CONCURRENCE PAGE
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Mrf George A. Hunger, Jr.
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The NRC team also reviewed, on a sampling basis, PEC0's corrective actions in
response to deficiencies identified in NRC Report 50 353/88-202, which docu-
!
mented our review of SWEC's on-site ICA effort and our independent construc-
tion inspection. :The corrective: actions in response to individual discre.
pancies noted in the report were attached to John S. Kemper's letter to the
NRC dated March 29,' 1989.
In general, the responses to the NRC identified
discrepancies were appropriate and the corrective actions taken by PECO were
adequate. 'However, full resolution'of several items requires additional
information' or action by PECO.
Your are requested to respond to this letter
within 30 days, addressing the'following:
Verification that the wire size used for motor leads on the operator
for valve HV-52-2F001C is adequate for its application (Section
4.4.2); and
A clarification of your construction quality assurance program as
'
it relates to your response to COR-056 (Section 4.6).
These items have been discussed with your staff during the inspection and at
the exit meeting. Since the IDCA program did not provide a mechanism for
changing SWEC's reports, any revisions to amplify or clarify your responses
to observation reports in the SWEC ICA report should be submitted with your
response to this report. Similarly, any revisions to your response to NRC
report 50-353/88-202 should also be addressed in your response to this report.
Although there are'several items which remain open, none of these items, either
individually or collectively, is of sufficient safety significance to impact
the' issuance of your low power operating license. The items which remain
open are listed in Enclosure 2 to this letter, one of which is identified as
as an unresolved item. These items, however, should be resolved before the
i
full power license is granted.
Some of the items identified by the inspection
team may be potential enforcement findings. Any enforcement actions will be
identified by Region I in separate correspondence.
Should you have any questions concerning this inspection, please contact me
or Mr. Eugene V. Imbro at (301) 492-C954.
Sincerely,
Steven A. Varga, Director
Division of Rea:: tor Projects I/II
Office of Nuclear Reactor Regulation
Enclosures:
1.
Executive Summary
2.
Inspection Report 50-353/89-200
I
1
cc:
See next page
5520 Document Name: Limerick ICA Report
1
0FC :RSIB:DRIS:NRR :RSIB:DRIS:NRR:RSIB:DRIS:NRR:DIR:DRIS:NRR:
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_____:..... _____...:.._____. ____:.____......__: ___________:_____...___:________....:..._____
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DATE :05/ -/89
- 05/ /89
- 05/ /89
- 05/ /89
- 05/ /89
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_ ____________ _ ____
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Mr. William M. Alden
-2-
,
The NRC team also reviewed, on a sampling basis, PECO's corrective actions in
response to deficiencies identified in NRC Report 50-353/88-202, which docu-
mented our review of SWEC's on-site ICA effort and our independent construc-
tion inspection.
The corrective actions in response to individual discre-
pancies noted in the report were attached to John S. Kemper's letter to the
NRC dated March 29, 1989.
In general, the responses to the NRC identified
discrepancies were appropriate and the corrective actions taken by PEC0 were
adequate. . However, full resolution of several items requires additional
information or action by PECO.
Your are requested to respond to this letter
within 30 days, addressing the following:
Verification that the wire size used for motor leads on the operator
for valve HV-52-2F001C is adeauate for its application (Section
4.4.2); and
A clarification of your ce e ruction quality assurance program as
it relates to your response to COR-056 (Section 4.6).
l
These items have been discussed with your staff during the inspection and at
the exit meeting. Since the IDCA program did not provide a mechanism for
changing SWEC's reports, any revisions to amplify or clarify your responses
to observation reports in the SWEC ICA report should be submitted with your
response to this report. Similarly, any revisions to your response to NRC
report 50-353/88-202 should also be addressed in your response to this report.
Although there are several items which remain open, none of these items, either
individually or collectively, is of sufficient safety significance to impact
the issuance of your low power operating license. The items which remain
open are listed in Enclosure 2 to this letter, one of which is identified as
as en unresolved item. These items, however, should be resolved before the
full power license is granted. Some of the items identified by the inspection
team may be potential enforcement findings. Any enforcement actions will be
identified by Region I in separate correspondence.
Should you hav:e any questions concerning this inspection, please contact me
or Mr. Eugene V. 1mbro at (301) 492-0954.
Sincerely,
Steven A. Varga, Director
I
l
Division of Reactor Projects 1/II
l
Office of Nuclear Reactor Reguiation
Enclosures:
1.
Executive Summary
2.
Inspection Report 50-353/89-200
cc: See next page
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b,
5520 Document Name: Limerick ICA Report O
OFC :RS B:DRIS:NRR :RS :
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DATE :05/3 /89
- 05/3 /89
- 05/U,t89
- 05/1t/89
- 05/ /89
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- Mr. Georg] A. Hung:r, Jr.
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May 17, 1989
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cc w/ enclosures:
Mr. Troy B. Conner, Jr., Esq.
Mr. Ted Ullrich
Conner and Wetterhahn'
Manager - Unit 2 Startup
1747 Pennsylvania Avenue N.W.
Limerick Generating Station
Washington, DC 20006
P.O. Box A
)
Sanatoga, Pennsylvania 19464
l
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Mr. Rod Krich, S7-1
Mr. John Doering
?
Philadelphia Electric Company
Superintendent - Operations
2301 Market Street
P.O. Box A
Philadelphia, Pennsylvania -19101
Sanatoga, Pennsylvania 19464
Mr. Graham Leitch, Vice President
Mr. Thomas Gerusky, Director
Limerick Generating Station
Bureau of Radiation Protection
P.O. Box A
.
PA Dept. of Environmental Resources
Sanatoga, Pennsylvania 19464
P.O. Box 2063
Harrisburg, Pennsylvania 17120
Mr. James Linville
Single Point of Contact
U.S. Nuclear Regulatory Commission
P.O. Box 11880
Region I
.
Harrisburgh, Pennsylvania 17108
475 Allendale Road
King of Prussia, Pennsylvania 19406
Mr. Thomas Kenny
Mr. Philip J. Duca
Senior Resident Inspector
Superintendent - Technical
U.S. Nuclear Regulatory Commission
Limerick Generating Station
P.O. Box 596
P.O. Box A
Pottstown, Pennsylvania 19464
.Sanatoga, Pennsylvania 19464
Mr. Joseph W. Gallagher
Institute of Nuclear Power Operations
Vice President, Nuclear Services
1100 Circle 75 Parkway
Philade'iphia Electric Company
Atlants, Georgia 30339
)
2301 Market Street
b
Philadelphia, Pennsylvania 19101
f
Mrc John S. Kemper
Mr. David Honan, N2-1
Senior Vice President - Nuclear
Philadelphia Electric Company
~
Philadelphia Electric Compeny
2301 Market Street
2301 Narket Street
Philadelphia, Pennsylvania 19101
Philadelphia, Pennsylvania 19101
Mr. W. Baranowski
Assistant Project Manager, IDCA
Stone & Webster Engineering Corporation
Cherry Hill Operations Center
3 Executive Campus
P.O. Box 5200
Cherry Hill, New Jersey 08034
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BBoger, NRR
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'LShao, NRR
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LMarsh, NRR
MPeranich, NRR
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Inspection Team Members
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4
EXECUTIVE SUMMARY
INSPECTION REPORT 50-353/89-200
LIMERICK GENERATING STATION - UNIT 2
The Nuclear Regulatory Commission (NRC) monitored the design and construction
aspects of the Limerick independent design and construction assessment (IDCA)
in three phases:
(1) preparation of the review plans, (2) implementation of
the review plans and performance of the review, and (3) evaluation of the
final IDCA report including assessment of the corrective actions. This
inspection concerned the third phase of the construction assessment, evalua-
tion of the report and corrective actions, and was conducted at the Limerick
site.
The NRC inspection team reviewed the independent construction assessment (ICA)
report written by the IDCA contractor, the Stone and Webster Engineering
Company (SWEC), including the construction action item (CAI) reports and
construction observation reports (CORs) issued during SWEC's ICA effort. The
team also evaluated a sample of Bechtel's responses and corrective actions
concerning SWEC's CAls and CORs, as well as discrepancies identified by the
NRC'sindependentinspectiondocumentedinInspectionReport(IR)
50-353/88-202.
Overall, the team found that SWEC properly followed the IDCA program for
reporting deficiencies and discrepancies on observation reports and for
accepting only appropriate responses to the CORs. The team also found that,
with several exceptions, the responses provided to SWEC were appropriate and,
with one exception, the corrective actions were complete and properly
i
implemented. The team also found that with only a few exceptions, the
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responses and corrective actions for the NRC-identified deficiencies were
appropriate and properly implemented.
In fact, the team was favorably
impressed with the licensee's efferts to determine the scope of identified
deficiencies.
The following are the instances in which the team found that the responses to
'
SWEC CORs and NhC-idtatified issues were incomplete and full resolution
required additional inforn.ation or licensee action. The first three issues
below remain open for additional action by the licensee or the NRC,
Cechtel's review for COR-34, which identified grouted-in anchors not
a.
meeting minimum embedment, revealed that this deficiency applied to 23
pert.ent of the grouted-in anchors examined. Bechtel's response to the
C0R only addressed anchors for large-bore pipe supports and excluded
other applications of grouted-in anchors based on the presumed inherent
conservatism in the design of these other uses, but did not document the
specific conservatism and safety factors on which Bechtel based this
exclusion. Additional information provided by the licensee after the
inspection is currently under review by the NRC staff.
b.
SWEC issued COR-56 to document what was thought to be a trend of changes
made to inspected and accepted equipment in electrical equipment instal-
lations. Bechtel's response stated in part that the site's quality
assurance (QA) program was a graduated ona that was " sufficient to assure
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the [ safety-related] equipment's function. The team found this defini-
tion of the site's nuclear QA program to be narrow. The licensee drafted
a position paper to clarify the meaning of the COR response and describe
the philosophy of its nuclear QA program. The license committed to
provide the clarification in a response to this inspection report.
c.
The NRC team questioned, in Section 4.5.2.1 of IR 50-353/88-202, the
qualification and size of motor leads for the operator on valve
HV-52-2F001C. The licensee adequately resolved the question regarding
environmental qualification, but did not address the question regarding
vire size. The licensee needs to verify that the wire's properties
are consistent with the design requirements of the motor-operated valve.
d.
The NRC team discussed, in Section 4.5.2.1 of IR 50-353/88-202, a concern
regarding reactor protection system (RPS) cables and engineered safety
system (ESS) cables sharing a common penetration. The final safety
analysis report (FSAR) did not address this configuration. The team's
review of this concern found the technical justification adequate.
However, the FSAR was not updated to reflect the actual design and
as-built configuration until after this inspection.
e.
In Section 4.4.2.1 of IR 50-353/88-202, the NRC team documented a concern
regarding a lack of cadweld sister splice testing as described in the
FSAR. Although the technical adequacy of the licensee's response was
satisfactory, the licensee's evaluation identified a high rate (approxi-
mately 10 percent) of missed sister splice testing. Because of this high
rate of missed cadweld sister splice testing and as a result of this
inspection, the licensee initiated an update to the FSAR that reflected
the methods used to satisfy the FSAR cadweld requirements,
f.
Bechtel's response to COR-007 was not complete. The response only
documented the evaluation of the radiographic indications associated with
one of three low pressure coolant injection welds identified by the COR.
The NRC determined that in fact the Bechtel and General Electric Company
corrective actions for sycluating the radiographs were complete *6y satis-
f
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factory for all three welds, and the results of these actions were
cocumented in Bechtel's response to CAI-022.
Based on the team's findings, in conjunction with the SWLr ICA results, the
I
tecm concluded that a weakness had existed in the site's QC progran..
This
weekness, identified as unresolved item 89-200-01, resulted in certain
deficiencies not bdng identified and certain installations not beinb
inspected with adequate criteria. The team noted that the licensee had taken
the appropriate corrective action for the deficient conditions identified by
the SWEC ICA group and the NRC inspection team. The team also concluded,
based on the scope of the SWEC and NRC inspections, that these concerns did
not constitute a programmatic breakdown since the majority of equipment
inspected was properly installed. Examples of the deficiencies include:
Required washers, jam nuts, and staked threads missing from
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foundation connections on many items of equipment;
A lack of inspection criteria of embedment length for grouted-in
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anchors that resulted in 23 percent of installations reviewed not
meeting requirements for minimum embednient;
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Failure of 35 structural installations to have bolt threads
excluded from the connections' shear plane as required; and
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Failure to inspect welds substituted for bolts at five connections,
and use of inadequate criteria for inspection of substituted welds,
which failed to identify 52 connections that did not meet the
)
appropriate criteria,
q
Although several issues reviewed by the team have not yet been fully resolved,
none of the items are of sufficient safety significance to impact the up-
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coming licensing decisions dealing with Limerick Generating Station, Unit 2.
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However, the issues should be resolved before the full power license is
granted.
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LIST OF OPEN ITEMS
Inspection Report 50-353/89-200
Limerick Generating Station, Unit 2
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The following items remain open pending additional information from or action
by the licensee, or additional review by the NRC. One issue has been assigned
an NRC Region I tracking number as an unresolved item (UI).
NRC review of additional information regarding Bechtel's resolution of
grouted-in anchors that did not meet minimum embedment depths (Section
4.3.1).
The licensee's verification that the wire size used for motor leads on
the operator for valve HV-52-2F0010 is adequate for its application
(Section 4.4.2).
The licensee's clarification of its construction quality assurance
program as it relates to Bechtel's response to Construction Observation
Report 056 (Section 4.6).
NRC-identified trend associated with improperly performed quality
control inspections (UI 88-200-01, Section 4.6).
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