IR 05000373/1989020
| ML20247K897 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/11/1989 |
| From: | Danielson D, Huber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247K890 | List: |
| References | |
| 50-373-89-20, 50-374-89-20, NUDOCS 8909220060 | |
| Download: ML20247K897 (7) | |
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U.S. NUCLEAR REGULATORY COMl41SSION
REGION III
Reports No. 50-373/89020(DRS); 50-374/89020(DRS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle Nuclear Power Station Inspection At: Marseilles, IL 61341 Inspection Conducted: August 8-31, 1989 Inspector:
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Approved By:
. U nielsen, Chief
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t Hiaterials and Processes Section D~ ate Inspection Summary Inspection on August 8-31, 1989 (Reports No. 50-373/8902(a!DRS); 50-374/89020(DRS))
Areas Inspected: Special safety inspection conducted to followup on allegation RIII-89-A-0102 (99014). Areas involved Technical Specification surveillance activities and QC inspections of piping systems following maintenance.
Results: Of the areas inspected, no violations, deviations or unresolved or open items were found; the allegations were not substantiated.
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REPORT DETAILS
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-Persons Contacted Commonwealth Edison Company (CECO)
'+T. Himmerich, Quality Assurance
+W. E. Morgan,' Nuclear Licensing Administrator Nuclear Regulatory Commission (NRC)
+R. D. Lanksbury, Senior Resident Inspector R. A. Kopriva, Resident Inspector I
+ Denotes those who participated.in telephone exit on August 31, 1989.
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2.
Followup on Allegation (Closed) Allegation RIII-89-A-0102: The NRC inspector performed followup inspection relative to allegations pertaining to activities at the LaSalle site. The results are discussed below..
a.
Background On July 25,.1989, an individual alleged quality assurance deficiencies in the areas of Technical Specification surveillance and certain Quality Control (QC) inspection activities.
Specifically, these allegations were:
(1) Procedures did not exist to control and identify testing and implementation procedures necessary to ensure that the requirements of TS 4.0.1, 4.0.2, 4.0.3, 4.0.4, and 4.0.5 were
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met.
(2) Inspections prior to closure of Class 1 and 2 piping were not performed in accordance with established standards and the
. licensee's QA manual.
b.
NRC Review (1) Technical Specifications (TS) 4.0.1, 4.0.2, 4.0.3, 4.0.4, and 4.0.5 (see Attachment 1) provide programmatic requirements for conducting surveillance activities and implementing limiting conditions for operation. These programmatic requirements themselves do not require specific testing; however, they should be reflected in the licensee's surveillance program
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through implementing procedures. The NRC inspector reviewed copies of several procedures implemented by the licensee that govern the conduct of surveillance testing at LaSalle.
Procedures reviewed included:
LAP-100-ll "LaSalle County Station General Surveillance
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Program," Revisions 5 and 9, dated April 26, 1985 and April 17, 1989, respectively.
LAP-100-29, " Conduct and Review of Station Surveillance,"
a Revisions 1 and 3, dated March.19, 1987 and March 24, 1989, respectively.
LAP-300-6,."LaSalle County Station Instrument Surveillance.
- Program," Revision 2, dated August.14,.1987.
LTS-600-4, "ASME Section XI In-Service Inspection,"
Revision 6, dated April 24, 1989.
LAP-1300-13, "ASME Section XI Program," Revision 0, dated October 24, 1988.
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LAP-1600-6, " Conduct of the Operating Department Surveillance Program," Revision 4, dated November 3, 1987.
LTP-600-4, "ASME Section XI In-Service Testing of Pumps
and Yalves." Revision 6, dated June 13, 1989.
The inspector concluded from this review that these procedures included limitations and actions designed to ensure that surveillance were performed pursuant to the programmatic requirements of section 4.0.1 through 4.0.5 of the TS.
(2) Allegation item (2) above, regarding the licensee's QC inspections of the closure of Class 1 and 2 piping systems
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following maintenance was based on LAP-300-16, " Cleanness i
Control."
This cleanness control procedure outlines methods and responsibilities required to prevent the introduction of foreign material into systems during maintenance activities.
The alleger was concerned that the foreman in charge of the maintenance crew performing the work on the system was permitted to perform "close-out" inspections by the cleanness procedures, in violation of ANSI N18.7-1978, ANSI N45.2-1973, the licensee's QA manual and NRC Regulatory Guide 1.33.
LaSalle is currently committed to ANSI /ASME NQA-1-1983 and adopted the standard as part of their QA program in 1985.
The licensee has also committed to Regulatory Guide 1.37, Revision 3, 1973, which endorsed ASME N45.2.1-1973, " Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants." ANSI /ASME NQA-1-1983, specifies, " Inspection for acceptance shall be performed by
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persons 1 0ther than those who performed or directly supervised the work being inspected," and ANSI N45.2.1-1973, covers t
onsite cleaning of materials and components, cleanness
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control, and preoperational cleaning and lay-up of important
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nuclear power-plant fluid systems during construction. This standard also briefly covers maintaining installation cleanliness.
Procedures and maintenance work packages'were reviewed and s
interviews were conducted to determine the licensee's practice in performing QC inspections of the closure of piping systems and the extent with which they complied with applicable guides, standards and the licensee's own procedures.
The following procedures and maintenance work requests were.
reviewed:
Procedures LAP-100-30, " Independent Verification," Revision 4,-dated
March 11, 1989.
LAP-300 16, " Cleanness Control," Revisions 4 and 5, dated January 5, 1987 and August 29, 1988,.respectively.
LAP-1500-1, " Quality Assurance Program," Revision 0, dated June 1976, LAP-1700-3, " Guidelines for Quality Control Hold Points,"
Revisions 0 and 1,-dated July 2, 1985 and February 18, 1988, respectively.
Maintenance Work Requests L 73132 Disassemble valve and inspect, completed May 21, 1988.
L 72509 Replace minimum flow line orifice, completed May 10, 1988.
L 73955 Disassemble and repair check valve, completed May 11, 1988.
L 56059 Dismantle valve and inspect / repair, completed May 23, 1986.
L 69451 Repair valve, performed on July 8, 1987.
The inspection confirmed that LAP-300-16 involved cleanness requirements of ANSI /ASME NQA-1-1983. and Regulatory Guide 1.37.
The NRC inspector also confirmed that the cleanness procedure LAP-300-16 was followed by the maintenance department and that the type of work to be performed was outlined by procedure.
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q.f S o, Through that procedure, it was'the maintenance foreman's responsibility to verify compliance with the procedure, but not to perform the final QC' inspection to verify that the system was -
clean prior.to: closure.. LAP-1700-3 outlined the requirements
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for station'QC personnel to establish these hold points. The
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requirement for final cleanliness inspection to assure exclusion L
.of foreign materials.of. safety-related. systems was part of LAP-1700-3 and.the final ~ step of the latest revision of
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. LAP-300-16 required a final QC inspection for cleanness.
The NRC inspector confirmed that the reviewed work requests had QC hold points to perform the cleanness inspection, and verified-that QC personnel performed these inspections independent of; the maintenance foreman and the related maintenance activities.
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Conclusion g
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Of the areas reviewed by the NRC inspector, no problems were noted and the allegations could not be substantiated. Guidance was provided to ensure adequate' implementation of the TS surveillance requirements.. QA standards were adhered.to by the licensee during performance of maintenance and during final QC-inspections such that closeout inspections of piping systems were performed by an organization independent of that which performed maintenance on the systems.
3.
Exit Meeting The NRC inspector held a telephone exit with the-licensee representatives (denoted in Paragraph 1) on August 31, 1998, to discuss the scope-and..
findings'of the inspection.
In addition, the inspectors also discussed the likely informational content of the inspection report. The licensee
'did not identify any documents / processes as proprietary.
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ATLUIMENT 1
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APPLICABILITY
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SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall.be met during the OPERATIONAL CONDITIONS or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirements.
4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance.
4.0.3 Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements.for a
. Limiting Condition for Operation.
Exceptions to these requirements are stated in the individual Specifications.
Surveillance requirements do not have to be performed on inoperable equipment.
4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operatior, have been performed within the stated surveillance interval or as otherwise specified.
4.0.5 Surveillance Requirements for inservice inspection and testing of ASME
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Code Class 1, 2, & 3 components shall be applicable as follows:
Inservice inspection of ASME Code Class 1, 2, and 3 components and a.
inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).
b.
Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shalT be applicable as follows in these Technical Specifications:
ASME Boiler and Pressure Vessel Required frequencies Code and applicable Addenda for performing inservice terminology for inservice inspection and testing
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inspection and testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days b
LA SALLE - UNIT 1 3/4 0-2 AMENOMENT NO.
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' APPLICABILITY
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SURVEILLANCE REQUIREMENTS (Continued)
The provisions of Specification 4.0.2 are applicable to the above c.
required frequencies for performing inservice inspection and testing activities.
d.
Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.
Nothing in the ASME Boiler and Pressure Vessel Code shall be construed e.
to supersede the requirements of any Technical Specification.
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LA SALLE - UNIT 1 3/4 0-3 i
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