IR 05000373/1981052
| ML20041B759 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/10/1982 |
| From: | Holzmer M, Peschel J, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20041B754 | List: |
| References | |
| 50-373-81-52, 50-374-81-22, NUDOCS 8202250170 | |
| Download: ML20041B759 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No 50-373/81-52; 50-374/81-22
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Docket Nos. 50-373; 50-374 Licenses No. CPPR-99; CPPR-100 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
LaSalle County Station, Units 1 and 2 Inspection At:
LaSalle Site, Marseilles, IL Inspectian Conducted: December 9, 10, 14, 23, 29, 30, 1981 and January 7, 11, and 15, 1982 Inspectors:
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M. Peschel fI Approved By: J
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agemer.t Programs Section Inspection Summary Inspection on December 9, 10,
'4, 23, 29, 30, 1981 and January 7, 11, and 15, 1982 (Reports No. 50-373/81-52; 50-374/81-22)
Areas Inspected:
Licensee action on previous inspection findings - unresolved items and noncompliances. The inspection involved a total of 67 inspector-hours onsite by three NRC inspectors.
Results: Of the areas inspected, one unresolved item was upgraded to an apparent of item of noncompliance (failure to properly control purchased material upon receipt at site).
8202250170 820211 PDR ADOCK 05000373 PDR
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DETAILS 1.
Persons Contacted Commonwealth Edison Company
- B. B. Stephenson, Project Manager
- R.
Cosaro, Site Project Superintendent
- R.
D. Bishop, Assistant Superintendent
- P. F. Manning, QC Supervisor J. J. Coonan, Assistant Superintendent, Maintenance
- R. D. Vine, QA Engineer B. L. Wood, QA Engineer R. T. Rose, Lead Structural Engineer D. J. Skoza, PCD Engineer G. L. Cooper, Master Instrument Mechanic N. B. Carpenter, Efficiency Coordinator
- P. Welsh, Office Supervisor R. Frederick, Stores Supervisor W. Shewski, Manager, Quality Assurance G. Marcus, Director, Quality Assurance - Engineering and Construction C. W. Schroeder, Technical Staff Supervisor
- Denotes those present at the exit interviews.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (373/81-25-01 and 374-81-13-01): Unknown status of the certificate of conformance for a shipment of cable to the site, received on MRR No. 6125. The inspector found that MRR No. 6125 documents the receipt on February 2, 1979, of reels of instrument cable without the required certificates of conformance per Specification J2967 and purchase order No. 181714.
Included in the shipment was reel No. B0159, part of which was installed in a safety-related system, cable IVY 100, on March 26, 1979. No " Hold" status was established and no hold tags were applied. No nonconformance report (NCR) was issued.
Interim use status was authorized on April 10, 1979, after the fact. Efforts to obtain the missing certificates of conform-ance were ineffective. The results of this activity are contrary to the requirements of Commonweatlh Edison Company Quality Assurance Manual Quality Procedures QP No. 7-1 and QP No. 15-1 and the requirements of 10 CFR 50, Appendix B, Criterion VII " Control of Purchased Material, Equipment, and Services."
As a result of the inspection findings, these unresolved items (373/81-25-01; 374/81-13-01) are considered closed and upgraded to item of nontompliance as violation of Criterion VII of 10 CFR 50, Appendix B, per the Appendix to this report (373/81-52-01; 374/81-22-01).
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Subsequent to the events that resulted in this violation, Commonwealth Edison expedited the missing Certificate of Conformance for MRR No. 6125, received and submitted them to Sargent & Lundy for review and acceptance, via QAL No. 5133 on December 2, 1981, and received S&L's letter dated December 14, 1981, stating that the submitted documentation was reviewed and found acceptable for use.
Additionally, the site construction QA organization initiated a program to identify all other interim status items and take necessary and appro-priate action to satisfy the requirements and establish the proper acceptance status for other similar items.
On December 30, 1981, the site construction QA Superintendent issued QAL No. 5226, subject: " Telephone Verification of Interim Release Documentation" advising all QA personnel that the approach was to be used only as a matter of last resort, that QA management and responsible QA engineers are to be advised, that required followup activities are to be initiated, and hold provisions of Quality Procedure QP No. 15-1 are to be placed into effect after 30 days, to preclude a repetition in the future of the type of activity that resulted in this violation.
The inspection results indicate that appropriate action had been taken to correct the identified item of noncompliance and to prevent recur-rence, therefore, no reply to this item of noncompliance is required.
(Closed) Unresolved Items (373/81-25-02 and 374/81-13-02):
Interpreta-tion and use of S&L " audited" comment on document reviews for MRR No. 7257. The inspector found that S&L had submitted an explanation and interpretation of their use of the term " audited" to the CECO Quality Assurance Superintendent at the LaSalle County Station Site on November 5, 1981. The explanation related to documentation requirements of S&L Specfication J-2918 which is the reference specification for MRR No. 7257. On December 14, 1981, the site QA Superintendent released QAL No. 5182 stating that the use of the term
" audited" was acceptable for J-2918 as presented by their November 5, 1981 letter.
The inspector found this approach and CECO acknowledgement to be acceptable.
(Closed) Noncompliance Item (50-373/81-22-08):
Lack of documented certifications for QC personnel. The inspector found that CECO had issued Procedure No. LAP-1700-2, Revision 0, August 31, 1981
"Per-sonnel Qualification and Certification Program for Quality Control Personnel to Meet the Intent of ANSI N45.2.6," which included a personnel certification form and the criteria for certification. The personnel certification forms on file for all of the present operations QC staff were reviewed by the inspector and found to be in accordance with the requirements of the procedure. This action to have appropriate certifications prepared and on file for each of the personnel on the QC staf f and provisions in the newly issued procedure (LAP-1700-2) to provide for the training and certification of quality control personnel were found to be an acceptable response to this item of noncompliance.
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(Closed) Unresolved Item (50-363/81-22-09):
Incomplete information concerning description of ASME Code and safety-related items on material request forms. The inspector found that CECO Procedure LAP 1400-3 has been revised in Section 4.g. to add note, "When an ASME Code Class item is being requested, the originator shall indicate the ASME Code Class in the description of the item he is requesting." The inspector found that the stores item numbers, purchase order numbers, work request numbers, etc. as used, added additional identification information on special and safety-related items to provide adequate control in the material request process. Additionally, this requirement was reviewed with the storeroom personnel on a training basis and all material red tags on ASME Code Material Class 1, 2 and 3 presently in the storeroom have been marked with the appropriate class and ASME Code Section refereuces. The inspector's review indicated that the response to this unresolved item is acceptable.
(Closed) Unresolved Item (50-373/81-22-12):
Programs for surveillances or audits of receipt-handling / unloading and inspection of equipment and rigging per ANSI N45.2.2-1974, Paragraph 7.4.
The inspector reviewed the records on file for two quality assurance surveillances conducted for activities in which rigging was involved; (QAS 01-81-15 on September 23, 1981, re:
hoisting and rigging on the IB diesel generator and housekeeping in the IB D.G. room; QAS 01-81-200 on December., 1981, re: maintenance activity - observance of work performed on WR No. L11376 and No. L11995 core spray bracket rework, and jet pump beam replacement).
The inspector was advised that surveillances were periodic, not required to be scheduled, and followed work activity set up by work requests and that hold points were established. However, a minimum activity was scheduled and the December 10, 1981, schedule indicated a (S.A.) semi-annual schedule for surveillance of hoisting and rigging and annual audits. The last audit was February 1981.
The inspector reviewed procedures relative to the inspections of equipment and rigging.
LMS-HC-01, Revision 2, July 28, 1981, " Station Cranes and Hoists Preventive Maintenance and Inspection."
LMP-GM-9, Revision 2, November 24, 1978, "LaSalle Station Safe Rigging Practices."
LMP-SL-1 with proposed revisions proof listing January 19, 1982,
" Periodic and Annual Rigging Equipment Inspection."
LMP-SL-2 with propcsed revisions proof listing January 20, 1982,
" Periodic Inspection of Special Lif ting Devices."
The procedures with their proposed revisions are considered adequate to meet the basic inspection requirements outlined in Section 7.4 of ANSI N45.2.2.
This unresolved item is considered closed.
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(Closed) Unresolved Item (50-373/81-22-22): Lack of procedures to implement Fluid System Cleanliness and Housekeeping programs to meet the requirements of ANSI N45.2.2-1973 and ANSI N45.2.3-1973. The
- inspector found that the licensee had issued procedures (LAP 300-16, Revision 0 and 1AP 900-14, Revision 5) to address the above mentioned
areas and a review of these procedures showed them to be acceptable.
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(Closed) Unresolved Item (50-373/81-22-23):
Lack of a method to establish a "Q list" and apply it to non-safety-related/ASME Section III Activities. The inspector found that the licensee had issued LAP-1500-2, Revision 0 Equipment Classification and Quality Assurance Requirements, to establish the "Q list" and provide for it's application, and a review of the procedure found it to be acceptable.
(Closed) Noncompliance (373/81-16-01): Procurement documents failed to impose the quality assurance program requirements of 10 CFR 50, Appendix B.
Quality Procedure No. 4-51'has been amended to state which safety-related q
purchases are to be covered by a Quality Assurance (QA) Program.
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Specifically, Safety-Related Commercial Grade procurements do not have to reference the provisions of 10 CFR 50, Appendix B, and the manufacturer need not have an approved QA program. For these Safety-Related Commercial
Grade procurements, acceptability "...shall be established and verified by receipt inspection under the applicable QA Program and, where applicable, by functional or operational checkout prior to being placed into operation."
(QP 4-51 per 3.0)
Four recent Safety-Related Commerical Grade purchase orders were examined and found to comply with the licensee's approved QA program.
(Closed) Unresolved Item (373/81-16-04): Qualification of Offsite Review Group (ORG) members in the Reactor Operations discipline were ambiguous. Qualifications for this discipline were reviwed in order to clarify the requirements for experience as a reactor operator.
Procedures now require experience as a reactor operator and five years experience in reactor operations /NPP operations.
(Closed) Unresolved Item (373/81-16-05): Newly hired buyers or Purchasing Agents are not adminstrative1y prohibited from working on
QA related purchase orders until having received QA training. A memo
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issued on June 11, 1981, by N. E. Wandke prohibits new buying personnel from committing purchase orders for safety-related and/or ASME code requirements until completing the Indoctrination and Training Program for buyers.
(0 pen) Noncompliance (50-373/81-22-13):
Station records not adequately protected from fire.
Example 1.
Central File Room does not meet NFPA-232-1975 criteria for fire protection as required by LSCS-FSAR. The FSAR was revised to specify what fire protection is afforded in the Central File Room and
to eliminate the commitment to NFPA-232-1975 for all LSCS records storage except the archive storage area.
In a telephone conversation with NRR, QA Branch, the inspector verified that this revision would be
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acceptable and the item is considered closed.
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Example 2.
Quality Records were stored in a non-fire rated room in the basement of the service building. All Quality Records have been moved to the archive storage area (vault) where proper fire protection is afforded.
The room in which these records were stored is the room in which micro-filming operations take place. The staff finds it acceptable for quality records to be located in this room if they are "... processed in a timely manner through the microfilming operation and will not reside in this area for any significant period of time."
(Commonwealth Edison Company letter from L. O. De1 George to J. G. Keppler dated Auguat 7, 1981).
Mechanical problems with the microfilming process and personnel losses in records processing have caused unacceptable delays in the microfilming operation. This process is an integral part of the station's permanent record storage program. Though adequate protection is now afforded to records which await microfilming, the matter will not be considered closed until microfilming operations are proceeding in a timely manner and the current backlog is eliminated.
(Closed) Unresolved Item (373/81-22-15):
Inadequate indexing of QA records. The inspector examined the applicable Master Retention Schedule which lists the record type, retention period and storage locatfon for QA records and found it to be adequate for describing record storage areas.
(Closed) Unresolved Item (373/81-22-16):
Lack of administrative system to manage non periodic surveillances. The applicant is writing a cross-reference between every surveillance required by Technical Specifications and the surveillance procedure which is used to meet the requirement.
Since the technical specifications may change any time before issuance of the license, the completion of this cross reference has been included in LLP 3-81 as an item to be completed prior to fuel load, and the matter is considered closed.
(Closed) Unresolved Item (373/81-22-17):
Plant instruction governing calibration of instruments used in meeting technical specification. The licensee has issued LAP-300-6 (Revision 0, November 1981) which acceptably governs the calibration of these instruments.
(Closed) Unresolved Item (373/81-22-18):
Battery Surveillance procedures did not include provisions to record the instrument number of thermometers, hydrometers and voltmeters used.
Procedures LOS DC-Q2, M1 and W1 were
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revised to include instructions to record this information, and spaces on the data sheets on which to record it.
(Closed) Unresolved Item (373/81-22-02):
Calibrated hydrometer floats to verify technical specification requirements for station batteries.
The Station Nuclear Engineering Department has directed that calibrated hydrometer floata be obtained and that procedures governing their use be written and implemented.
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Exit Interviews The inspectors met with licensee representatives (denoted under Persons Contacted) at the conclusion of the inspections on December 30, 1981, and on Jenuary 7 and 15, 1982. The inspectors summarized the scope and findings of the inspections. The licensee acknowledged the information.
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