IR 05000373/1987024
| ML20236B839 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/21/1987 |
| From: | Danielson D, Schapker J, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236B824 | List: |
| References | |
| 50-373-87-24, 50-374-87-24, GL-84-11, NUDOCS 8710260377 | |
| Download: ML20236B839 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-373/87024(DRS); 50-374/87024(DRS)
I Docket Nos. 50-373; 50-374 Licenses No. NPF-11; No. NPF-18 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690'
Facility Name:
LaSalle County Station, Units-1 and 2 Inspection At:
LaSalle Site, Marseilles, Illinois l
l Inspection Conducted:
August 4-6, 18-19, September 29, 30, and i
p g ctober 1, 1987 O
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Inspectors:
. F. Schapk'r
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Approved By:
D. H. Danielson, Chief
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Materials and Processes Section Date l
Inspection Summary Inspection on August 4-6, 18-19, September 29, 30, and October 1, 1987 (Reports No. 50-373/87024(DRS); No. 50-374/87024(DRS))
Areas Inspected:
Routine, unannounced safety inspection of licensee actions taken to implement Generic Letter 84-11 (25589); followup on open item (92701)
and allegations (99014); and review of training (41400).
Results:
No violations or deviations were identified.
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DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
- G. Diederich, Station Manager l
- P. Manning, Assistant Superintendent Technical Services
- R. Bishop, Technical Services Superintendent
- K. Kocinba, Quality Assurance Engineer
- M.' Richter, Technical Staff Engineer
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T. Hammerich,-Technical. Staff Supervisor D. Brown, Quality Assurance Superintendent J. Renwick, Production Superintendent
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l R. Smeets, Technical Staff Electrical Engineer l
D.'Zoloty, Technical Staff ISI Coordinator j
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- J. Hill, Technical Staff Mechanical Engineer j
- D. Enright, Quality Assurance Engineer i
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Nuclear Regulatory Commission (NRC)
- M. Jordan, Senior Resident Inspector
- R. Kopriva, Resident Inspector e
i The inspectors also contacted and interviewed other licensee and
.s contractor personnel.
- Denotes those in attendance of the exit meeting on August 19, 1987.
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- Denotes those in attendance of the final exit meeting on October 1, 1987.
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2.
Licensee Action on Previous Inspection Findings i-i (0 pen) Open Item (374/85-029-01):
High Pressure Core Spray (HPCS) return
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line to condensate storage tank degradation.
The' licensee's System Materials Analysis Department (SMAD) performed analysis of the damaged piping and determined the failure of the piping was due to microbiological corrosion, primarily of the weld metal..The li consulted with General Electric Company (GE) the system designe,censee has r and is i
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in the process of developing a system modification or repairing / replacing the affected piping.
In the interim the HPCS ability to function in the event of a loss of coolant accident has not been impaired.
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The HPCS primary suction source is the condensate storage (CY)
tank - normal / standby mode - however, the HPCS takes suction from the suppression pool (NH) in the event that the CY is not available.
This item remains open pending further action by the licensee.
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3.
(Closed TI 2515/89) Inspection of Licensee's Action taken to Implement Generic Letter 84-11:
Inspection of Boiling Water Reactor Stainless Steel Piping The purpose of this inspection is to verify that the licensee has performed inspections of stainless steel piping welds susceptible to
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Intergranular Stress Corrosion Cracking (IGSCC) and in initiated actions l
.in accordance with Generic Letter (GL) 04-11.
a.
Inspection Program The NRC inspector reviewed the licensee's ISI records and documentation for LaSalle Units 1 and 2 scheduled outages and confirmed that the reinspection program of piping susceptible to IGSCC including piping equal to or greater over 200 F, which are part of or connected to the reactor coolant pressure boundary out to j
the second isolation valve were inspected in accordance with Generic
Letter 84-11 guidelines.
J Unit 1 ISI Ultrasonic examinations (UT) of IGSCC susceptible welds.
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included 33 welds selected as a minimum sample size for welds not l
previously inspected (four minimum) for each pipe size, in.
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addition 126 welds were UT' examined following Induction Heat Stress
Improvement (IHSI).
As a result of the Post-IHSI UT examinations, j
two welds exhibited " crack-like" indications.
The indications were
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evaluated by NUTECH as being possible IGSCC.
These two welds were I
evaluated assuming the indications were IGSCC and were found to meet all NRC and ASME Code Criteria for continued operation for an 18 month fuel cycle.
Further examination in accordance with GL 84-11 guidelines are planned to evaluate the cracked indications
during the next refueling outage.
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Unit 2 ISI Ultrasonic examinations of IGSCC susceptible welds i
included 48 of a total of 129 welds.
Included in the sample were 39 welds which were mechanically stress improved to mitigate
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the susceptibility of the stainless steel piping to IGSCC.
The Mechanical Stress Improvement Process (MSIP) has been evaluated by i
Argonne National Laboratory (ANL) for the NRC as a remedy to l
mitigate the IGSCC of stainless steel piping in BWR's.
Based on l
ANL's own research work and the data and analysis provided by l
O'Donnell and Associates, Inc., ANL judged MSIP to be an effective i
means of improving the residual stress state of piping system j
weldments and considered its effectiveness in terms of mitigating Q
susceptibility to stress corrosion cracking to be equivalent to i
IHSI.
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l The licensee also performs a visual inspection for leakage at design l
l pressure prior to restart at each outage where the containment-is l
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deinerted.
The NRC inspector reviewed records documenting visual
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inspection for leakage for the last two outages.
The visual
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i examinations were ' consistent with IWA-5241and IWA-5242 of the
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1980 Edition of Section XI of the ASME Boiler and Pressure Vessel
. Code, b.
Competence of UT Examiners
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The NRC inspector verified the UT Examiners who performed i
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inspections / evaluations on piping required by GL-84-11 were qualifiedL by formal performance canaMl'Ly demonstration-test conducted at the Electric Power Research Institute (EPRI) Nondestructive Examination Center. UT inspectors who are performing ~as SNT-TC-1A-Level I.UT examiners work only with or under the direct supervision -
of Level II or III examiners.
Reference NRC Inspection Reports
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No. 50-373/85035; No. 50-374/85036; and No. 50-374/87002.
c.
Leak Detection and Leakage Limits LaSalle Technical Specifications specify the following for. reactor coolant system leakage and leakage detection systems:
3.4.3.1 The following reactor coolant system leakage detection'
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The primary containment atmosphere particulate radio-activity monitoring -system.
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The primary containment sump flow monitoring system,
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Either the primary containment air coolers condensate flow rate monitoring system or.the primary containment atmosphere gaseous radio activity monitoring system.
Applicability: Operational Conditions 1, 2, 3.
Action: With only two of the above required leakage detection system operable, operation may continue for up to 30 days provided grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the required gaseous and/or particulate radio active monitoring system is inoperable; otherwise,.
be in a least H01 SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.4.3.2 Reactor coolant system leakage shall be limited to:
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5 gpm unidentified leakage.
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25 gpm total leakage averaged over any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
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1 gpm ieakage'at a reactor coolant.' system pressure-at 1000 50 psig from any reactor coolant system pressure isolation valve specified in Table 3.4.3.2-1.
GL 84-11 Attachment 1 - Leak' Detection and Leakage-Limits - Paragraph B states:
" Plant shutdown shall be initiated for inspection and corrective action when any leakage. detection system indicates, within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an increase in rate of unidentified leakage in excess of 2 gpm or its equivalent, whichever occurs first.
For sump level monitoring systems w'Ah a fixed-measurement internal method, the level shall be monitu sd.
at 4-hour intervals or less.
At least one of the leakage measurement instruments associated with each sump shall be operable, and the. outage time forLinope'rable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or immediately initiate an orderly shutdown."
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The licensee took exception to this portion of GL 84-11 in the response to the Generic Letter, based-on "An extensive containment leakage system has been installed at LaSalle.
It consisted of-particulate and noble gas monitors, humidity, hydrogen, and oxygen analyzers, drywell floor drain and equipment sumps with fill-up' and l
pump down rate and level indication.
Based on-the age of the plant
and the IGSCC mitigation efforts, it is. felt that. present Technical Specification limits adequately monitor leakage and.need no l
revisions."
The NRC inspector informed the licensee that the LaSalle Technical Specifications do not comply with GL 84-11 guidelines, however, the.
licensee had submitted the above position to GL 84-11 to the NRC in response to the GL. The NRC inspector informed-the licensee that this is an unresolved item (373/87024-01; 374/87024-01)) pending further evaluation by the NRC.
4.
Allegation Followup (Closed) Allegation RIII-87-A-0020:
This report documents the receipt and followup of allegations made by a former worker at LaSalle. These are summarized as follows:
a.
Undersize Fillet Welds
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(1) Allegation
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l Undersize fillet welds were accepted for the Fine Motion Control l-System.
Fillet welds which were required to be 1/4" were only l
3/16" but were accepted anyway.
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(2) NRC Review The NRC inspector reviewed the pertinent drawings (MS-271 and
MS-272) and found that there were.only six 1" structural fillet welds.
The NRC inspector visually examined those welds'and
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found each to be ample in size.
Inquiries-to MCCo and CECO'
supervisors and engineers who were responsible for the job -
disclosed that there had never been a question of meeting size requirements on these welds. However, they recalled questions j
concerning the &" fillets on 18 of the-32 socket welds:on the 1" and 1&" pipes in the Fine Motion Control Rod System.
These welds were made in accordance with ANSI B31.1.
requirements. Although a small amount of work on the Fine
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Motion Control System was safety-related, the ' pipe. welding j
was not.
For these reasons, the Nonconformance Report System,
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which was in place and operating for safety-related work, did.
not apply to the pipe welding. The interviews revealed that~any.
undersize welds were reinforced as necessary to make their size
acceptable and no record of repair was made because the welds.
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were considered to be in-process until' turned over to CECO. All
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32 socket welds were visually examined by the NRC inspector and found to be of acceptable size.
These welds could have been undersize when seen by.the alleger and subsequently reinforced to j
their present size without the need for additional documentation.
j (3) Conclusion This allegation could not be substantiated. All 1/4" fillet
welds in the Fine Motion Control System are now of acceptable size.
b.
Hydro Test Witnessing l
(1) Allegation A hydrostatic test for an instrument stand on the 761' elevation of the Unit 2 reactor building in the vicinity of column lines B and 17 required the presence of both Morrison (MCCo) quality control and CECO QA/QC, but was run without Morrison QC.
(2) NRC Review The station traveller which included the hydro test in question was examined by the NRC inspector.
Presence of a MCCo QC representative at the hydro test is identified as a Hold Point-on the traveller.
The hydro test operation was identified as Operaticn 12 of Work Request No. 33572.
It was found signed as complete by James L. Shaw, the MCCo QC inspector and by -
M. Oclon, the CECO representative. The records'show no irregularities and the presence of the CECO ' representative supports this position. One of the principal functions of the CECO representative is to confirm the effectiveness of the MCCo QC representative in monitoring the identified activity.
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(3) Conclusion
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This allegation could not be substantiated. The records indicate that a representative of MCCo QC was in attendance at the time of the ~ hydro. test.
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Hydro Test Venting (1) Allegation
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The hydro test of b above, required:a vented system, but the i
test was run without venting.
(2) NRC Review l
I The NRC inspector reviewed the test. records and procedures i
pertaining to the hydro test of the instrument stand,'and i
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l interviewed CECO Q.C. personnel who were present during the test. The hydro test in question was performed on one of four
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i essentially identical. systems.
Each of the systems has the'
l same type venting and each had the hydro test signed off by'
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The-venting operation is specifically addressed.in the hydro test procedure and was properly signed off as complete.
The appropriate facilities were available, I
ard all documentation indicates that the system was properly.
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vented.
1 (3) Conclusion l
l This allegation could not be substantiated. All-pertinent.
j records and CECO Q.C. personnel indicate that the test was
properly vented, i
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d.
Installation of Valve with Hold Tag (1) Allegation l
A relief valve in the Fine Motion Control System may have been installed before a hold tag on the valve was cleared.
(2) NRC Review The NRC inspector reviewed the documentation pertaining to the l
installation of the relief. valve in question. Though.there are approved procedures in place for_ installing a valve prior.to removing a hold tag, the existing records indicate that the use of these methods was not necessary in the case of the relief valve identified in the allegation.
This is'a Lonergan Model #LCJ-14,- 1/2" x 1" carbon steel relief valve with a' set-pressure' of 1775# and was identified as 2C11-FM-142.
It was received by MCCo on _ February 17, 1987 (Report No. LM 793). The
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original Certificate of Conformance-(C0C) from Lonergan was -
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dated December 10, 1986.
It was corrected on February 25, 1987,.
- S to show the proper tag number.. The final acceptance of MCC0's Receiving Inspection was~ dated February 26, 1987. That was the day after the COC was corrected.
The Material Request on which H
the valve was ordered out of storage was dated February 27, 1987, or the day after the valve was finally cloared by QC.
It appears that the valve was not' withdrawn from stock until the paperwork was cleared.
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(3) Conclusion This allegation could not be substantiated. The pertinent records indicate that the hold tag was cleared before the valve was removed from stock.
e.
Substitution of Station Construction Standards for AWS DI.1 (1) Allegation The station attempted to substitute Station Construction Standards for contractually accepted structural welding acceptance standards (AWS D1.1).
(2) NRC Review i
The NRC inspeLor revieved the structural welding acceptance requirements and ussociated documentation.
The. standards.which the station proposed to be used in place of the AWS D1'.I' weld acceptance criteria are alternately known as the. Visual Weld Acceptance Criteria or "VWAC."
The use of these standards for
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structural weldments in. nuclear power plants was concluded to be acceptable to the NRC as indicated in an August 26, 1985,
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letter from J. P. Knight, Acting Director, Division of
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Engineering, NRR, to D. E. Datton, Chairman of the Nuclear Construction Issues Group (NCIG). That'1etter also~ stated that use of the document was valid only if.the licensee's commit to the use of VWAC in their SAR.
LaSa11e's UFSAR, E.4.3.2 states,
" Visual Weld Inspection is in accordance with... NCIG-01, Revision 2, entitled " Visual Weld Acceptance Criteria for Structural Welding in Nuclear Power Plants." That document is the CECO version of VWAC.
CECO instructed, in Field Change i
Request (FCR)No.L86-713datedNovember 25, 1986, that drywell I
structural steel welds should be examined in accordance with NCIG-01, Revision 2.
l The use of the VWAC was approved by both NRC and CECO.
Its use l
was authorized to MCCo through the FCR.
The use of VWAC (the
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standard proposed by the station) was not only acceptable at I
the time of the subject encounter, it was mandatory. The station's request that MCCo use VWAC rather than AWS D1.1 as acceptance criteria for visual acceptance of structural welds was both justified and appropriate.
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(3) Conclusion
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The allegation was substantiated in that a change of acceptance criteria for structural welds was made.
However, the standards proposed by the station were the standards which were applicable
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to the facility.
f.
Weld Performed on Leaking Pipe Joint (1) Allegation
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A pipe joint was welded after inspection disclosed water to be leaking from the joint during fit-up inspection.
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(2) NRC Review
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The NRC inspector reviewed the documentation associated with this weld joint and interviewed the MCCo Q.C. Supervisor and those responsible for performing the weld.
The pipe joint with questionable fit-up inspection is weld Number 21 in'the Chillwater System, MCCo Job No. 2828, WR No. L52139, Traveler i
No. 4.
(This is not a safety-related system.) The. joint is located between a pipe and a gate valve.
The valve is mounted with the flow axis in the horizontal position and the stem is also horizontal.
Interviews with those responsible for the installation of this valve disclosed that water was present at the time of original inspection. 'Three independent estimates of the flow rate ranged from two to 10 drops per minute.
However, after an extended period a puddle formed in the enlarged diameters at the center of the valve and water began I
leaking through the tack-welded joint.
This was the condition observed by the alleger.
To correct this condition, the tack-welds were removed and the joint was opened.
The water was removed from the joint side of the valve and the inside of the valve near the joint was dried es.
by heating the outside of the valve with a gas torch. When dry, the joint was reassembled, tack-welded, inspected and welded.
Fit-up inspection was signed as accepted by MCCo Q.C. in the Weld Data Report.
The rate of leakage was reported to be
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so low that a period of several days was required to fill the depression at the center of the valve to a point at which water might reach the joint.
(3) Conclusion This allegation was not substantiated. 'The condition was corrected prior to welding.
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Waiver of Inspection
'(1) Allegation
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A foreman requested that the MCCo QC. Supervisor waive'a weld
joint. fit-up inspection after.the inspection' disclosed.the; presence of water in the tack-welded joint.
(2) NRC Review.
The joint on which fit-up inspection was' waived is the same joint which is discussed in f.' above. The NRC inspector interviewed the MCCo Q.C. inspector and inspected the.do.uments-dealing with the installation of the system. :The-results of the investigation indicate that this. fit-up' inspection was not:
waived; it was performed and accepted on the' Weld Data Report.
(3) Conclusion
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This allegation was not-substantiated.
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Attitude of LaSalle Station Construction Department Toward Quality
(1) Allegation The attitude of LaSalle Station Construction Department favored speed over quality.
(2) NRC Review The NRC inspector interviewed CECO personnel responsible for planning and following the work. These interviews indicated
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support for quality on modifications and' disclosed the following objective evidence of Station Construction commitment to quality work.
(a) A high percentage of personnel on the job'during the outage were Q.C. personnel.
The high ratio was designed to assure good communication and to prevent delays in
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detection and reporting of deficiencies.
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(b) Quality control personnel were stationed at the work areas.
This limited the number of jobs on which they were applied and reduced time' lost in transit when they
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were needed.
It achieved this at a. cost of' increasing the number of Q.C. personnel necessary to cover the job.
(c) Sargent and Lundy (S&L) performed an independent analysis.
of the work in the Alternate Rod Insertion (Modification M-1-2-84-061) and the Primary Containment Vent and Purge System (Modification M-1-2-84-048)..The purpose of this analysis was to verify that the jobs were done. properly.
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S&L made the following statements concerning quality i
inspections on those modifications:
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... Adequate quality inspections have been
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integrated into the installation travelers..."
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... ' Completed installation travelers included
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completed signoffs on traveler steps and/or supplemental forms to document the inspections that were performed."
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"The appropriate site organizations are given adequate opportunity... to incorporate in-progres,s i
verification and hold points as deemed necessary."
(3) Conclusion This allegation was not substantiated. All of the cited
activities of CECO which reduced inspection performance time did so by increasing the presence of QA personnel to avoid reducing the quality of the work.
5.
Unresolved Items l'nresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, open items, deviations, or violations. An unresolved item disclosed during the inspection is discussed in Paragraph 3.
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Exit Meeting The inspectors met with site representatives (denoted in Persons Contacted Paragraph) at the conclusion of the inspection. The inspectors summarized the scope and findings of the inspection noted in this report.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents / processes as proprietary,
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