ML20155B817
| ML20155B817 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/29/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Alden W PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20155B822 | List: |
| References | |
| NUDOCS 8810070090 | |
| Download: ML20155B817 (7) | |
See also: IR 05000353/1988200
Text
V
._-
-
'
4
p/
so %e,
o
UNITED STATES
%
NUCLEAR REGULATORY COMMISSION
" #'I
j
j
i
t
WASHINGTON D. C. 20555
enk
[
September 29, 1988
,
. ,
Docket No. 50-353
Mr. William M. Alden
Director-Licensing
ATTN: Correspondence Control Desk
Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania
19101
Dear Mr. Alden:
SUBJECT:
INSPECTION OF REVIEW PLANS FOR THE INDEPENDENT DESIGN ANO
CONSTRUCTION ASSESSMENT, LIMERICK GENERATING STATION, UNIT 2
As part of its plan to monitor Philadelphia Electric Company)'s (PECO) "Pro
for the Independent Design and Construction Assessment (IDCA of Limerick Unit
2," the NRC conducted an inspection of the associated review plans.
The
inspection took place at the Cherry Hill, New Jersey, offices of the independ-
ent contractor Stone and Webster Engineering Company (SWEC), during the week
of August 8, 1988, with the exit meeting on August 12, 1988.
Enclosed are an
executive sumary of that inspection and the subject inspection report. As a
result of this inspection, the NRC recomended additions and clarifications be
included in the review plans to achieve an acceptable depth of review within
the defined IDCA scope. All of the additions and clarifications are documented
in the enclosed addenda to the inspection report and all were discussed with
SWEC. Many of these additions were added to the review plans by SWEC prior to
the exit meeting and all were agreed to be subsequently added to the review
plans. With the inclusion of the items identified in the enclosed inspection
report, the NRC finds the review plans to be acceptable and no other response
is required,
s.
,
The independent design assessment (IDA) review plans are generally comprehen-
sive but require the addition of certain design attributes to be considered
complete. All of the inspection disciplines require additions and clarifica-
tions to the review plans with most significant exacted in the electrical and
instrumentation and controls areas.
In the electrical discipline, the inspec-
tion team recomended that the review plans be expanded from a review of the 4
kV switchgear in the ac distribution system to a verification of the adequacy
of the station ac and de distribution system's abP ity to supply operating and
control power for loads required for safe shutdown during all modes of plant
operation.
In the instrun.entation and controls discipline, the inspection team
recomended that the safety-related 120 Vac instrument power be reviewed for
its apparent lack of an uninterruptible power supply. With the addition to the
review plans of the design attributes identified in the enclosed inspection
report, the scope of the IDA will be considered acceptable,
001007oo90 880929
f0
ADOCK 05000 %
o
't
,
--_
. .. ..
_
o
4
.
'
Mr. William M. Alden
-2-
September 29, 1988
The independent construction assessment (ICA) review plans represent a good
first ef fort at identifying the kinds of installations and types of construc-
tion attributes that must be reviewed for an adequate assessment of construc-
tien practices. However, the NRC inspection team had two basic concerns with
the ICA effort. Namely, the scope and depth of inspection were incom'pletely
defined in the review plans; and the planning, preparation and training for the
ICA were incomplete. The team noted that SWEC developed the review plans
without a plant visit and system walkdown by the principal ICA personnel.
The
NRC team considered this omission a major contributor to the weaknesses identi-
fied in the review plans.
The SWEC ICA offort began on the Monday following the exit meeting for this
inspection.
Because of this schedule, all of the individual ICA review
recomendations in the enclosed inspection report were discussed with the
appropriate SWEC personnel. As a result of these discussions, SWEC comitted
to add two additional reviewers to their team. With the incorporation into the
ICA review plans of attributes to address the NRC team's significant concerns,
the plans will be adequate for their purpose.
.
In general, it is our understanding that all review plan attributes will be
evaluated.
If a certain attribute cannot be evaluated within the scope of
review selected by SWEC, then that attribute should be evaluated by selecting
another sample outside the approved scope of review.
Otherwise, a justifica-
tion will be required for omission of the attribute evaluation.
If you have any questions regarding this report or forthcoming inspection
plans, ph o contact tre or Gene Imbro. Mr. Imbro can be reached at
(301) 492-0954
Sincerely,
even A.
d,
ro e
ctor
Division of Reactor Pro ec s I/II
Office of Nuclear Reacto
egulation
.
Enclosures:
1.
Executive Sumary
2.
Inspection Report 50-353/08-200
cc w/ enclosures:
See next page
_
v
o
a
Mr. William M. Alden
-3-
September 29, 1988
'
cc:
Troy B. Conner, Jr., Esquire
Mr. Robert Gram
Conner and Wetterhahn
Senior Resident Inspector
1747 Pennsylvania Ave., N.W.
U.S. Nuclear Regulatory Comission
Washington, D. C.
20006
Pottstown, Pennsylvania ~19464
Mr. Charles Mengers 57-1
Mr. Ted Ullrich
Philadelphia Electric Company
Manager - Unit 2 Startup
2301 Market Street
Limerick Generating Station
Philadelphia, Pennsylvania 19101
P. O. Box A
Sanatoga, Pennsylvania 19464
Mr. Grahm M. Leitch, Vice President
Mr. John Doering
Limerick Generatir.g Station
Superintendent-0perations
Post Office Box A
Limerick Generating Station
Sanatoga, Pennsylvania 19464
P. O. Box A
Sanatoga, Pennsylvania 19464
Mr. James Linville
Thomas Gerusky, Direct'or
U.S. Nuclear Regulatory Comission
Bureau of Radiation Protection
Region !
PA Dept. of Environmental Resources
475 Allendale Road
P. O. Box 2063
King of Prussia, PA 19406
Harrisburg, Pennsylvania 17120
Mr. Thomas Kenny
Governor's Office of State
.
Senior Resident Inspector
Planning and Development
j
US Nuclear Regulatory Comission
ATTN:
Coordinator, Pennsylvania
P. O. Box 596
State Clearinghouse
Pottstown, Pennsylvania 19464
P. O. Box 1323
Harrisburg, Pennsylvania 17102
Mr. Joseph W. Gallagher
Mr. Philip J. Duca
Vice President Nuclear Services
Superintendent-Technical
Philadelphia Electric Company
Limerick Generating Station
l
2301 Market Street
P. O. Box A
Philadelphia, Pennsylvania
19101
Sanatoga, Pennsylvania 19464
'
~~
Mr. John S. Kemper
l
Senior Vice President-huclear
1100 Circle 75 Parkway
Philadelphia Electric Company
Atlanta, Georgia 30339
2301 Market Street
,
i
t
Philadelphia, Pennsylvania
19101
.
. _ _ _ _ _ _
.__
_ _ _ _ -
_
_
.
.
___
..
,
,-
.
.
.
l
'
Mr. William M. Alden
-3
cc:
B. K. Grimes, NRR
C. J. Haughney, NkR
'
E. V. Imbro, NRR
'
'
J. E. Konklin, NRR
R. W. Parkhill, NRR
i
S. R. Stein, NRR m
)
.)
'
InspectionTeamMFmber]s
s
i
E. C. Wenzinger, RI
/
[
,
J. C. Linville, RI
//
t
J. R. Strosnider, RI
R. A. Gram, RI
i
E. H. Gray, RI
Distribution:
Central File
RSIB R/F
l
DRIS R/F
D. Cppf,}.jfef),4)/!4
I
.S }$'O 9 , 4,} W 2
i
\\ lYB
r,Mex
.
2 Clark NAM'
i
1
1
,
1
1
,
l
!
,i
1
I
I
'
!
M
~
'
'
j.....:..............: p .......:.. $ :NRR:5fB:DRI5:NRR:D:DR15:NRR:D:
.0FC
- R5 :
- FR :RSIB:DRI5:NRR:5IB:DRI5
.P-I/ 1:NRR:
{
,...:............:............:.. . .......:........
-
lNAME RParkhill:
M Stein
- Elmbro
- CHaughney
- BGrimes
- WB
ler
j
lDATE :09/w/88.....:............ r. ............:............:............:............:. . .......:........
i
- 09/le/88
- 09/J.8/88
- 09/ /88
- 09/
/88
- 9/
88
1
i
/
^
i
'
f
i
i
<
.
__-
_
_
. __
g
j
i
2
.
.
!
.
Mr. William M. Alden
-4-
September 29, 1988
!
Distribution:
(w/ encl)
l
Docket File 50-353
RSIB R/F
[
DRIS R/F
LPDR
BKGrimes, NRR
i
CJHaughney, NRR
EVImbro, NRR
i
JEKor;klin, NRR
!
RWParkhill, NRR
!
SRStein, .':RR
I
JSniezek, NRR
!
FMiraglia, NRR
[
DCrutchfield, NRR
'
SVarga, NRR
!
WButler, NRR
t
RClark, NRR
i
Inspection Team Members
{
ECWenzinger, RI
i
JClinville, RI
[
JRStrosnider, RI
'
RAGrann, RI
EHGray, RI
(
Regional Administrators
!
Regional Division Directors
!
ACRS(3)
'
OGC (3)
l
IS Distribution
j
!
!
!
i
,
f
i
f
>
i
i
- SEE PREVIOUS CONCURRENCES:
i
0FC
- RSIB:DRI5:NRR :R518:DRIS:NRR:RSIB:DRIS:NRR:5IB:D
RR:D:
DRP.Illl:N y
l
- S {...w....:........
.....:..............:.............:.............:.....
5: ..
- ..
.
l
'
HAME :*RParkhill:
- SStein
- Elmbro
- CHaug
- BG
es
ga
.....:..............:.............:.............:............:...........:
......h...:........
DATE :09/ /88
- 09/ /88
- 09/ /83
- 09/.1488
- 09/1)/88
'8
-
.
,
0
.
EXECUTIVE SUMtiARY
Inspection Report 50-383/88-200
Limerick Generating Station - Unit 2
.,
The NRC has planned to monitor each of the design and construction aspects of
the Lin,erici Inocpendent Design and Construction Assessment (IDCA) in three
phases:
(1) preparation of review plans, (2) implementation of the review
plans and performance rf the review, and (3) evaluation of the final IDCA
report including assessment of the corrective actions.
This int.pection covered
the first phase, preparation of review plans, and was conducted at the Cheery
Hill, New Jersey offices of the IDCA contractor, Stone and Webster Engineering
Company (SWEC).
The inspection team found the independent design assessment (IDA) review plans
to be conprehensive, explicit, and logically structured.
The team found the
SWEC reviewers contacted for the IDA to be experienced and techrically compe-
tent. With the addition to the IDA review plans of the design afoributes
iJentified in Addendum I to the subject inspection report, the inspection team
censiders the scope of the IDA review to be acceptable.
The more signifi-
cant additions and clarifications to the iDA review plans recommended by the
NRC inspection team include the following.
(1)
IDA Mechahical Systems - the inputs and outputs of the ultimate heat sink
sizing calculations should be verified.
Residual heal removal (RHR) and
spent fuel pool cooling heat exchangers, relief valve, control valve,
and orifice sizing calculations are to be included in the review plans.
(2)
IDA Mechanical Components - the seismic qualification of the RHR heat
exchanger, piping analysis overlap techniques, internally generated
missiles, and a multi-discipline hazards analysis review should be
included in the review plans.
(3)
IDA Electrical Power Systems - the scope of review should be expanded
from a review of the 4 kV switchgear in the ac distribution system to a
verification of the adequacy of the station ac and de distribution .
system's ability to supply quali G noerating and control power for loads
reoutred for safe shutdown during all modes of plant operation.
A review
of clectrical penetraticns and cable pull'.99 calculations should also be
reviewed.
,
,
(4)
IDA Instrumentation and Controls - review of the 120 Vac instrument power
as an uninterruptible source' of safety-related power, and review of the
main control board internal wiring should be included. Also reviews of
calculations should include calibration, flow element sizing, high
pressure restricting orilice sizing (including ((vitation damage assess-
r.ent), and control valve sizing.
(5)
IDA Civil / Structural - review should include an assessment of nonseismic
and seismic nuilding interactions, suppression poci swell loads on
miscellaneous steel structures, and the effect of floor flexibility on the
amplified response spectra.
1
- - .
-.
-
-____ _ .
- --
_
.
.
.
.
The NRC construction team found the ICA review plans to be comprehensive in
most areas. The review plans represented a good first ettort at identifying
the attributes necessary for an overall assessment of construction practices.
However, the NRC inspection team identified two areas of concern from.the
initial evaluation of the ICA review plans:
(1) the scope and depth of inspec-
tion were incompletely defined in the review plans and (2) the planning,
preparation, and t 3inir.g for the ICA were incomplete.
The NRC construction
tean noted that SWEC developed the review plans without a site visit and system
wal T wn by the priacipal ICA personnel.
We believe this omission was a major
contributor to the weaknesses identified in the review plans.
The following contributed to the team's concern regarding the scope of the
ICA.
(1) The ICA review plans did not comprehensively identify all types of items
and equipment which SWEC will inspect during the ICA, and in some
instances SWEC had not defined the applicability of identified equipment
to the RHR system.
(2) Several plans did not include a minimum level of effort or a sample
selection process.
(3)
Important review plan attributes were missing or were incomplete.
Fcr
exarrple, Review Plan LK-C-1903 did not include an attribute to verify the
strength of concrete through a review of concrete compressive test
results; and the LK-C-1904 attributes for cable routing involved only a
record review without a physical check of actual routing.
(4) Certain attributes were inapplicable to the RHR system because they
addressed in-process characteristics and the system was essentially
complete.
(5) The individual plans did not identify the types of items or infomation
that the discipline reviewers were to provide to the procurement reviewer
for traceability reviews.
Also Review Plan LK-C-1906 did not provide any
requirements to perfom these material traceability reviews on samples
identified by the other ICA members.
.
.
The following factors contributed to the team's concern regarding the
preparation, plannir.3, and training for the ICA.
(1) The SWEC ICA group had not reviewed the actual condition and status of the
RHR system to determi.ne its effect on the ICA effort and the review plans.
For example, the installation of piping insulation can significantly
reduce the number of welds and piping samples accessible for examination.
(2) The ICA group had not obtained all of the infomation required for an
adequate preparation of the ICA effort.
For example:
SWEC had not
identified the applicable ASME codes for welding and nondestructive
examinations (NDE), and had not gathered sufficient detail drawings to
detemine sarrples and applicability of attributes.
(3) The staffing level appeared to be inadequate for the size of the on-site
review ef fc.rt defined by the plans.
2
. _ _
.