ML20248B766
| ML20248B766 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/05/1989 |
| From: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906090170 | |
| Download: ML20248B766 (14) | |
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'I PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET I
P.O. BOX 8699 PHILADELPHIA A, PA.19101 (215) 841 4 221 C, A. McNDLL, Jn.
June 5, 1989 exacurava vice enestorut-wuctsAn Docket No. 50-353 Construction Permit No. CPPR-107 U.
S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 j
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SUBJECT:
Limerick Generating Station, Unit 2 Readiness for Fuel Loading and Conducting Startup Testing Gentlemen:
Philadelphia Electric Company (PECo) expects to complete the construction and preoperational testing activities necessary to support the initial fuel loading and low power startup testing for Limerick Generating Station, Unit 2 (LGS-2) as early as June 16, 1989, but no later than June 30, 1989.
Accordingly, we request that the Commission staff be prepared to issue a
license authorizing LGS-2 fuel loading and operation up to 5 percent of rated power as early as June 16, 1989.
A number of construction and preoperational testing activities may not be completed at initial fuel loading based on a review of construction and test status conducted by PECo management on June l
3, 1989.
These activities are identified, along with bases for deferral, in Attachments 1 and 2, respectively. However, we expect a significant number of these items to be completed prior to issuance of the license.
These activities have been assessed to assure that their deferral does not innact the safety analysis or represent a potential adverse effect on the health and safety of l
the public.
1 PECo has reviewed the Limerick Generating Station, Unit 1 operating license, as well as other recently issued licenses, and the LGS-2 licensing activities to date, and identified the items in Attachment 3 as anticipated license conditions or exemptions.
I Each exemption was requested in previous correspondence.
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PECo has undertaken several self-assessment activities to provide additional confidence in our readiness for operation.
These include the Readiness Program Assessment (RPA),
the Organizational Readiness Program, and the Readiness Verification Program (RVP) which have been described in previous correspondence and which are briefly described in Attachments 4 and 5.
Based on the above, PECo has high confidence that LGS-2 will be ready to initiate fuel loading as early as June 16, 1989.
Sincerely, 1
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Attachments:
i 1.
Construction Activities That May Not Be Completed by Fuel Load (1 page) 2.
Pre-Operational Tests That May Not Be Completed by Fuel Load (3 pages) 3.
Exemptions and Anticipated Conditions of License (1 page) 4.
Readiness Program Assessment and Organizational Readiness Program (2 pages) 5.
Bases for PECo's Confidence in the Quality of the Design, Construction, and Testing of Limerick Unit 2 (4 pages) l l
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W. T. Russell, USNRC, Administrator, Region 1 l
T. J. Kenny, USNRC, Senior Resident Inspector, LGS l
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COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF' PHILADELPHIA' l
Corbin A.~.McNeill,.being first duly sworn, deposes and says:
.That.he is Executive'Vice President-Nuclear of Philadelphia' Electric Company, the. Applicant herein; that he has. read the foregoing letter relating to the Company's application for an operating license for Limerick Unit 2 and knows the contents
~.thereof; and that the statements and matters set forth therein are
-true and correct to.the best'of his knowledge, information and-belief.
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' Executive-Vice 3 resident-Nuclear 1.
Subscribed and sworn to before me this M ay d
of June, 1989.
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Notary Public i
' NOTAndSEAL I
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SUSAN C. TIIOnf410N, Notary Public City of Philadelphia. Phila. County fJy Commisslan Expirer fAay 4,1D02 l
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t Construction Activiti'es That May Not Be Completed by Fuel 1 Load
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=Activitvf Justification
~ Landscaping and' Grading Note 1 Miscellaneous ~punchlist actions Note 2 I
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' NOTES:
1.
Yard-grading' ' configurations. are ' subject to. engineering safety evaluations to assure that potential? for external flooding is within p
_ station' design basis as' described in FSAR Section~2.4.
' 2 ~. - Work will be completed.. prior to the operational mode required.:
Items being..t) acked to completion : via Consolidated' open' Items List (COIL),
-- which is available onsite for NRC review.
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Pre-Operational Tests That May Not Be Completed by Fuel Load Test Completion By-Justification Gaseous Radwaste Recombiners (2P72.1)
Mode 2 Note 1
- Floor &. Equipment Drain Collection.
Mode 3 Note 2 Systems
- Condensate. Backwash Area Floor &
Equipment Drain Collection Testing, Test Report, and Approval (2P69.1, 2P69.3A)
'.Drywell Floor & Equipment Drain Sumps. Leakage Detection System (2P69.3B)
- Condensate Backwash Receiving Tank Mode 2 Note 3 and Transfer Pump.
Pre-Op Test.(2P68.1)
Condensate Transfer System Mode 2 Note 4
-Pre-Op Test (2P37.1).
Reactor Enclosure Charcoal & HEPA Mode 3 Note 5 Filters (TT1.13) 1:
Refueling' Floor HVAC Final Air Commercial Note 6 Balance Operation Main Generator Stator Cooling System Mode 1 Note 7
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(2A97.1)-
- Containment Hydrogen Recombiner, Mode 3 Note 8 H2/02 Analyzer (2P73.1)
Turbine Enclosure HVAC Final Air Mode 2 Note 9 Balance
-Feedwater System (2P45.1)
Mode 2 Note 10 l
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NOTES:
1.
The Gaseous Radwaste Recombiners are part of the Gaseous Waste Management Systems as described in FSAR Section 11.3.
The system function is to collect and delay release of non-condensible radioactive gases removed from the main condenser by the steam jet air ejectors during normal plant operation.
The system is not safety-related.
Non-condensible radioactive gases will not collect in the main condenser when the main steam isolation valves (MSIVs) are closed.
Accordingly, the preoperational testing will be completed prior to MSIV opening in Test Condition "Heatup" (prior to entering Mode 2).
2.
The Drywell Floor and Equipment Drain Sumps Leakage Detection System is part of the Drywell Sump Level Monitoring System as described in FSAR Section 5.2.5.2.1.3.
Requirements for operability are addressed by Technical Specification Section 3/4.4.3, " Reactor Coolant System Leakage
- Leakage Detection Systems".
The system is required to be operational during Operational Conditions 1,
2, and 3.
Accordingly, the pre-operational test will be completed during Test condition "Open Vessel" and prior to entering Mode 3 per Technical Specification requirements.
The Condensate Backwash Area Floor and Equipment Drain System is described in FSAR Section 9.3.3.2.
The system is not safety-related.
The system pre-op test will be completed prior to Test Condition "Heatup" (Mode 2) so it can be placed in service in accordance with General Procedure 2,
" Normal Plant Startup."
3.
The Condensate Backwash Receiving Tank and Transfer Pump are part of the Condensate Cleanup System described in FSAR Section 10.4.6 and 11.4.
Condensate quality water is used to backwash the filter-demineralized resin.
The backwash is sent to the receiving tank for subsequent transfer via the backwash transfer pump to radwaste for processing.
The system is not safety-related.
The system pre-operational test will be completed prior to Test Condition "Heatup" (Mode 2) so it can be placed in service in accordance with General Procedure 2,
" Normal Plant i
Startup."
4.
The Condensate Transfer System is part of the Condensate System described in FSAR Section 9.2.7.
The condensate transfer pumps and the condensate transfer jockey pump take their suction from the condensate J
storage tanks to provide water for various services in the radwaste enclosure, the reactor enclosure, and for the fuel pool filter demineralized backwash.
The system is not safety-related.
The system pre-operational test will be completed prior to Test Condition "Heatup" (Mode 2) so it can be placed in service in accordance with General Procedure 2, "14rmal Plant Startup."
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- NOTES: (cont'd) 5.
The Reactor Enclosure Charcoal and HEPA Filters are part of the Reactor Enclosure and Refueling Area HVAC Systems described in FSAR Section 9.4.2.
Requirements for operability are addressed by Technical
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Specification Section 3/4.6.5,
" Secondary Containment Reactor Enclosure Secondary Containment Integrity". Reactor enclosure integrity is required during Operational Conditions 1, 2, and 3.
Accordingly, the pre-operational test will be completed during Test Condition "Open Vessel" and prior to entering Mode 3 per Technical Specification requirements.
6.
Refueling Floor HVAC is part of the Reactor Enclosure and Refueling Area HVAC Systems for Normal Operation described in FSAR Section 9.4.2.1.
Secondary containment isolation and potential equipment compartment flooding via the steam flooding dampers are the only active safety-related functions of the normal operation of reactor enclosure and refueling area HVAC systems and these functions are covered under other pre-op tests already performed.
Final air balancing will be completed after fuel load and reactor hydro-test and is not required to maintain secondary containment integrity on the refuel floor.
7.
As described in FSAR Section 10.2.2.2, the Main Generator Stator Cooling System is not safety-related.
This cooling system provides water cooling for the main generator stator windings.
The Main Generator Stator cooling acceptance test is to be completed prior to placing system in service in accordance with General Procedure 2,
" Normal Plant Startup."
8.
The Containment Hydrogen Recombiner H2/02 System is part of the Containment Atmospheric Control System described in FSAR Section 6.2.5.2.
Requirements for operability are addressed by Technical Specification Section 3/4.6.6, " Primary Containment Atmospheric Control Primary Containment Hydrogen Recombiner Systems."
The system is j
required to be operational during Operational Conditions 1, 2,
and 3.
Accordingly, the pre-operational test will be completed during Test Condition "Open Vessel" and prior to entering Mode 3 per Technical Specification requirements.
9.
The Turbine Enclosure Ventilation System is described in FSAR Section 9.4.4.
The system is not safety-related.
The final air balance will be completed prior to Test Condition "Heatup" (Mode 2) so it can be placed in service in accordance with General Procedure 2,
" Normal Plant Startup."
The system is not safety-related.
The Feedwater System pre-op test is to be completed prior to placing system in service in accordance with General Proceduro 2,
" Normal Plant Startup."
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Exemptions and Anticipated Conditions of License o.
Schedular exemptions from requirements of:
10 CFR 50.33(k)/50.75 re: decommissioning funding 10 CFR 50. 44 (c) (3) (i) re: inerting within six months of initial criticality i
o Exemptions from the requirements of:
10 CFR 50.44 (c) (3) (ii) (B) re: common power supplies for hydrogen recombiner containment isolation valves 10 CFR 50 Appendix J III.D.2 (b) (ii) re: air lock testing 10 CFR 50 Appendix J II.H.4, III.C.2, & III.C.3 re: MSIV leak rate testing 10 CFR 50 Appendix J II.H.1 & III.C.2 re: TIP leak rate testing 10 CFR 70.24 re: criticality monitoring o
20 CFR 50.59 applicability to fire protection o
Submit start-up test revisions made under 10 CFR 50.59 within one month j
o Construction items and Preoperational tests to be completed, as determined necessary by NRC Region 1.
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Readiness Program Assessment and Organizational Readiness Program In 1987, approximately two years prior to scheduled fuel load for Limerick Unit 2, PECo initiated a self-assessment of existing programs and processes that relate to completion and readiness.
This self-assessment initiative was called the Readiness Program Assessment (RPA). The objective of the RPA was to identify and assess PECo programs intended to assure and demonstrate completion of Limerick Unit 2 and its readiness for operation in accordance with licensing commitments.
The RPA approach was to:
o Identify and characterize existing PECo completion and readiness programs; o
Determine how these programs fit together in the context of plant completion and readiness for operation; and o
Determine the accountability structure that will certify construction completion and operational readiness to senior PECo management and the NRC.
The RPA addressed the following functional areas:
o Licensing o
Quality Assurance and Quality Control o
Engineering, Design and Analysis o
Construction o
Startup and Operations Hardware Readiness Organizational Readiness The Readiness Program Assessment Team concluded that existing PECo programs and processes can assure and demonstrate that Limerick Unit 2 construction is complete and that it is ready for operation in accordance with the licensing commitments under the following conditions:
o that the programs and processes are properly implemented by the Project team, and o
that corrective action for the open items is developed and properly implemented.
The Readiness Program Assessment Report which summarized this program was submitted to NRC by letter dated April 11, 1988.
The report identified items which required additional action by PECo in order to demonstrate
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Limerick Unit 2 readiness for operation.
In addition, this self-assessment program was reviewed by NRC and was cited in SALP Report 50-353/88-99 dated l
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March 15, 1989.
It stated that this program, along with those described in Attachment 5,
were multi-layer reviews which provided an appropriate framework to ascertain operational readiness of Limerick Unit 2.
The original assessment has been reviewed quarterly and updated semiannually to assure that the conclusions of the original report remain valid.
Open items have been tracked to completion by management at the monthly project status review meetings.
The final RPA Report update was dated March 31, 1989.
The RPA open item related to organizational readiness was addressed by the organizational Readiness Program described below.
The Organizational Readiness Program was developed as a systematic way to accomplish the transition from a single unit to a two unit operation at Limerick Generating Station.
This program included on-site as well as off-site organizations.
17 schedules encompassing 250 action plans were developed and implemented for the following PECo organizational units and activities:
o Nuclear Plant Chemistry o
Emergency Preparedness Section o
Health Physics o
Plant Services / Radiation Protection o
Information Resource Management Section o
Licensing Section o
Maintenance and I&C o
Material Control o
Nuclear Engineering o
operations Section o
Operations / Technical Section o
Operations / Fuel Management Section o
Nuclear Quality Assurance o
Nuclear Plant Security o
Start-Up o
Nuclear Training Section o
Fire Protection Detail items in tha Action Plans from the Organizational Readiness Program not completed as of June 1, 1989 and which are prerequisites to fuel load, heatup or power ascension testing have been entered in the Limerick Unit 2 Consolidated Open Item List (COIL) to assure completion prior to the operational mode required.
The COIL is available on site for NRC review.
The RPA and Organizational Readiness Program were regularly reviewed by PEco senior managers.
Program updates were reviewed by PECo's Nuclear Review Board.
All open items from the RPA report submitted to NRC by letter dated April 11, 1988 have been closed and independent verification of open item closecut was included in the Readiness Verification Program (RVP) described in Attachment 5.
On the basis of the above described programs and their results, Philadelphia Electric Company concludes that it is ready for licensed operation of Limerick Unit 2.
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I Bases for PECo's Confidence in the Quality of the l
Design, Construction, and Testing of Limerick Unit 2 1.0 Project Processes and Programs 1.1 Licensing The basic licensing approach and licensing organization was described i
in the Readiness Program Assessment (RPA) Report which was submitted to the NRC by letter dated April 11, 1988.
It was determined that there was a programmatic link between engineering and construction programs and LGS licensing documents.
This linkage provides reasonable assurance that the FSAR and its supporting documents accurately reflect Limerick Unit 2 physical configuration.
There is a direct link between the licensing documents anf. engineering processes through the Design Control Program and Licensing Document Revision Program.
The link between the licensing documents and construction processes is assured through the Design Control Program and configuration control activities.
1.2 Design The basic engineering, design and analysis approach was described in 1
the Readiness Program Assessment (RPA) Report which was submitted to the NRC by letter dated April 11, 1988.
The design control process has evolved over the design and construction period of the Limerick Generating Station.
Although there were complex interrelationships amcng the design control programs, an experienced Engineering team was completing a design which was substantially the same as an existing licensed design.
It was found that personnel interviewed in the various organizations involved in the engineering, design and analysis areas showed understanding of the overall process in their discipline area, and understood their interface responsibilities in a consistent manner.
No disconnects were noted within the Engineering functional area or with the major interfaces with the other functional areas.
This is consistent with what le expected from an experienced Engineering team and assured that design could be properly completed.
1.3 Construction The construction program approach was described in the Readiness Program Assessment (RPA) Report which was submitted to the NRC by letter dated April II, 1988.
It was concluded that PECo and Bechtel had developed a systematic and well integrated construction program.
There were strong procedural and programmatic links between Engineering, Construction and Quality Assurance / Quality Control. The work package approach when combined with the Material and Labor Control System provided a valid approach to assessing the remaining work.
Walkdowns in the turnover process and start-up testing provide the asnurance that construction has been completed.
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1.4 Testing The Tecting program approach was described in the Hardware Readiness Section of the Recdiness Program Assessment (RPA) Report which was submitted to the NRC by letter dated April 11, 1988.
This program was developed to ensure that the plant hardware meets the design intent of the FSAR and that it will remain in that condition until called upon to perform.
It was found that detailed procedures have been developed by PECo to guide the plant personnel in the execution of these functions.
These procedures were based on a proven approach, namely, that used to establish Limerick Unit l's readiness for operation.
The experiences of other power plants, INPO, and the NRC were also incorporated into the procedure development processes to assure that the PECo approach to plant readiness remained at the state-of-the-art level in quality.
Additionally, the procedures and their execution were reviewed by PECo management to ensure their regulatory adequacy and completeness in meeting the intent cf the PECo and the regulatory requirements.
1.5 Organizational Readiness Organizational Readiness was assured by execution of the Organizational Readiness Program described in Attachment 4.
1.6 Quality Assurance & Quality Control Programs The Quality Assurance & Quality Control (QA/QC) programs were described in the Readiness Program Assessment (RPA) Report which was submitted to the NRC by letter dated April 11, 1988.
PECo's QA/QC programs contain a number of specific features which provide confidence in the quality of the design, 1
construction and testing of LGS.
PECo and Bechtel performed 3330 audits, 4720 surveillance, 45557 receipt inspections summarized in receiving reports, and since construction restart in 1986, about 1,500,000 in-process and final inspection activities.
The extent and results of these QA/QC activities give PECo confidence that Limerick Unit 2 has achieved high quality in its design, construction, and testing.
2.0 READINESS VERIFICATION PROGRAM The objective of the Readiness Verification Program (RVP) was to provide a
managed program of independent verifications and self-assessment activities performed under the direction of PECo's Nuclear Quality Assurance (NGA).
This program was designed to provide additional confidence to PECo management that Limerick Unit 2 was ready to be licensed and placed in operation.
In order to provide this assurance, selected verifications were performed.
This self-assessment program was reviewed by NRC and was cited in SALP Report 50-353/88-99 dated March 15, 1989.
It stated that this program, along with those described in Attachment 4 were multi-layer reviews which provided an appropriate framework to ascertain operational readiness of Limerick Unit 2.
The Readiness Verification Program (RVP) Description was transmitted to the NRC by letter dated September 16, 1988.
The RVP encompassed two 2 of 4
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s distinct verification elements that were structured such that when they were combined, they provided a comprehensive independent measure of Limerick Unit 2's readiness for operation.
The two RVP verification elements were:
Desian and Construction Readines
' verification Independent verification in selected areas were performed, including an in-depth Independent Design and Construction Assessment (IDCA) with NRC oversight, to provide added confidence that Limerick Unit 2 design and construction programs have been effectively implemented and are in j
accordance with licensing commitments.
Operational Readiness Verification Independent verifications in selected areas of operational readiness were performed, including procedural adequacy, facilities, training, operatior.al practices, and programs designed to provide adequate staff operational knowledge to give additional assurance that Limerick Unit 2 is ready for operation in accordance with licensing and other commitments.
2.1 Design and Construction Readiness Verification Results The major emphasis of Cesign and construction readiness verification was the conduct of an Independent Design and Construction Assessment (IDCA).
The IDCA was a comprehensive technical assessment pcrformed by Stone &
Webster Engineering Corporation (SWEC) of the design and construction process as implemented at Limerick Unit 2.
Utilizing deep vertical-slice review techniques applied to the containment heat removal function of residual heat removal, SWEC was able to draw conclusions as to the adequacy of design and construction of safety-related systems at Limerick Unit 2.
The IDCA program description was submitted to the NRC by letter dated June 1, 2988 with Revision 1 dated July 7, 1988.
The NRC confirmed the acceptability of the IDCA program by letter dated July 28, 1988.
- Overall, the IDCA resulted in over 35,000 checks of hardware and design information consuming in excess of 100,000 professional personnel-hours.
The results of the IDCA were submitted to NRC by letters dated February 10, 1989 (Independent Construction Assessment); April 18,1989 (IDCA Summary and Independent Design Assessment) ; and May 25,1989 (Supplement for Hazards Review Program).
Based on their reviews and contingent upon completion of certain corrective actions, SWEC concluded that:
o The design of safety-related systems and structures for Limerick Unit 2 complies with licensing commitments and is technically adequate.
o The construction of safety-related systems and structures for Limerick Unit 2 is satisfactory and is generally in accardance with drawings and specifications.
o With the exception of the design process employed for Balance of Plant (BOP) safety-related setpoints, for which corrective action is being taken, the design and construction process employed for Limerick Unit 2 ic an acceptable process.
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In addition to the IDCA, PECo NQA. performed additional design and construction verifications. Utilizing normal NQA assessment techniques such no audits, surveillance, inspections, and independent critical evaluations, and in conjunction with the SWEC IDCA results, NQA was able to draw conclusions as to the design and construction adequacy of Limerick Unit 2.
The-results of PECo NQA verifications were found to be consistent with the overall conclusions from the IDCA.
t 2.2 Operational Readiness Verification Results
' The Operational Readiness Verification consisted of selected assessments parformed by the Nuclear Quality Assurance (NQA) to critically evaluate programs, procedural adequacy, training, and identified problems or concerns with applicability to licensed operation of Limerick Unit 2.
Industry operating experience and how it is incorporated. into Limerick was particularly emphasized in these assessments.
This verification used the same NQA assessment techniques discussed above and allowed NQA to conclude that Limerick Unit 2 was ready for licer. sed operation.
2.3 Overall RVP Conclusion Based on the results of the two verification elements of the RVP, PECo concludes that additional confidence exists that Limerick Unit 2 is ready to be licensed and placed into operation.
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