ML20215K067

Responds to Violations Noted in Insp Repts 50-373/86-29 & 50-374/86-30 on 860707-11,22-24 & 0922-23.Corrective Actions:Procedures LAP-220-4, Degraded Equipment Log & LAP-100-12, Trend Analysis Program, Will Be Revised

ML20215K067
Person / Time
Site:	LaSalle
Issue date:	11/26/1986
From:	Turbak M COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
2417K, NUDOCS 8705110058
Download: ML20215K067 (7)

Text

. /r%

f -- -},- One CommonmMh EcHoon First National Plaza, Chica0o, Illinois

• " Navomber 26, 1986

'N ,/ Address Hoply to: Post Omce Box 767 L/ Chicago, Illinois 60690 0767 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL. 60137

Subject:

LaSalle County Station Units 1 & 2 Response to Inspection Report Nos. 50-373/86-029 and 50-374/86-030 NRC Docket No. 50-373 and 50-374 Reference (a): C.J. Paperiello letter to Cordell Reed dated October 14, 1986

Dear Mr. Keppler:

This letter is in response to the inspection conducted by P.L. Eng on July 7-11, 22-24 and September 22-23, 1986, of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company response to the three Severity Level IV violations identified in the Notice of Violation is provided in Attachment A.

Commonwealth Edison recognizes that some deficiencies have existed in the ASME Section XI Inservice Testing Program. However, we believe that overall management of the program is sound and that it properly features review of data collected by cognizant engineers who are most sensitive to changes in equipment performance. In the attachment we discuss this and also actions being taken to better control IST documentation.

Additionally, Commonwealth Edison has included in Attachment B, a response to the intimation that Quality Assurance did not follow up on findings in a 1985 inspection.

If you have any further questions on this matter, please direct them to this office.

Very truly yours, i

M. S. Turbak Operating Plant Licensing Director

/klj cc: NRC Resident Inspector-LSCS att.

2417K

/ / 1 HP2A88s 8taa8872  %

s ote 1328s G PDR

=

i ATTACHMENT A l I

4 The Technical Staff ASME Section XI Inservice Testing Coordinator  ;

(IST coordinator) is responsible for maintenance of the IST ASME Section XI 1 program, which includes coordination of submittals to the NRC regarding the

IST program. He also functions to ensure that the requirements of the IST program are procedurally implemented (i.e., that there are procedures which identify the performance necessary to meet the requirements of the IST program and that each procedure is tracked by the LSCS surveillance program at the required frequency).

The department performing each surveillance procedure and the

assigned system engineers are responsible'for reviewing the surveillance data to ensure that the acceptance criteria are met and/or appropriate additional

, actions are taken. On September 23 1986, a memo was sent to all Production departments describing what is expected with respect to documentation requirements. In addition-the details of this memo were discussed with the Technical Staff.

All testing for work requests which perform code work on pumps in the

Section XI IST program will have the post maintenance testing scope approved

] by the Technical Staff Supervisor prior to performance of the test.

Additional training on the inservice testing program, its require-4 ments and its goals will be given to the Technical Staff personnel who review IST (ASME Section XI) required data. In addition, the procedure which guides special testing, LTP-100-2, will be revised to provide direction for completing and documenting IST requirements and data when performing special tests.

VIOLATION: IR 374/86030-01 (AIR 374-100-86-03001) i

1. LaSalle Technical Specification 4.0.5 states that inservice testing of. ,

j pumps and valves be performed in accordance with Section II of the ASME

! Code unless specific relief has been granted by the Commission. IWP-3400 of Section XI specifies that inservice testing shall be performed on each pump in the inservice testing program on a quarterly basis during normal

operation. Subsection IWP-3230 states in part that for pumps whose test i

data fall into the alert range, the frequency of testing shall be doubled until the cause of the deviation is determined and the condition corrected.

Contrary to the above, test data taken for the Unit 2 RCIC pump on December 23, 1985, placed the pump into the alert range and as of July 24, l 1986, increased frequency testing of the pump had not been conducted, i

l r

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

The RCIC pump vibration point 4A entered the alert range on December 23, 1985. Attachment C of LAP-100-12 was completed to increase the testing

-frequency. This attachment was provided to the Unit 2 Operating Engineer, the Tech Staff system engineer and the Tech Staff ASME Section II Inservice Testing (IST) coordinator. An evaluation performed on February 6, 1986, indicated that the increased frequency test did not need to be performed. This evaluation was inadequate in that it did not provide proper documentation of the justification for not performing the additional testing. The subsequent performance of surveillance LOS-RI-Q3 for the Unit 2 RCIC pump on April 16, 1986, had vibration levels in the acceptable range. This validated the previous evaluation that the RCIC pump was fully operable during the period.

CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION:

Procedure LAP-220-4. " Degraded Equipment Log (DEL),".will be revised to ensure that any ASME Section XI Clacs 1, 2 and 3 Pumps or Valves (i.e.,

items covered by the IST Program) which are found in the required action range during the performance of a surveillance, will be tracked via the DEL. An evaluation form will be initiated that provides for documenting the evaluation of off-normal data and actions taken to resolve the-off-normal data.

LAP-100-12. " Trend Analysis Program," will be revised so that if the trending program shows that action must be taken due to adverse trends, or if any ASME Section XI class 1, 2 and 3 Pumps or Valves are in the alert range, the same evaluation form described above will be initiated. This form when completed will be filed with the completed. surveillance procedure to provide a complete documentation package for ease of review.

DATE OF FULL COMPLIANCE:

LaSalle is presently in full compliance with the requirements. The additional measures that will be~taken to better document the process will be completed by January 15, 1987. LaSalle is presently placing equipment in the IST program which falls in the required action range in the DEL.

i

1 i

I 1

VIOLATION: IR 374/86030-03A (AIR 374-100-86-03003)

IR 374/86030-03B (AIR 374-100-86-03005)

IR 373/86029-05'(AIR 373-100-86-02905)

2. LaSalle Technical Specification 6.2.A.7 for both Units 1 and 2, requires the licensee to adhere to detailed written procedures for surveillance and

testing requirements.

! a. Licensee procedure LOS-RI-Q3, " Reactor Core Isolation Cooling System

! Pump Operability and Inservice Test," requires the use of control room pressure instrument PI-2E51-R604 to measure the Unit 2 RCIC water les pump discharge pressure.

Contrary to the above, on March 26, 1986, the licensee obtained I pressure data from gauge PI-2E51-R501. As a result the licensee j unknowingly entered into a Limiting Condition for Operation.

! b. Work request number L55974 addressing maintenance' performed on the j

Unit 2 RCIC water les pump required that the pump be returned to i service by performing pertinent portions of procedure LOS-RI-Q3, i

" Reactor Core Isolation Cooling System Pump Operability and Inservice

} Test." Steps F.2 and F.5.d require the collection of vibration velocity data.

1 Contrary to the above, the licensee failed to obtain vibration j_ velocity data as required on the Unit 2 RCIC water les pump on March j 21 and 26, 1986.

t c. Step F.3.c of licensee procedure LOS-RH-Ql, "RHR and RHR SW Pump

! Inservice Test for Operational Conditions 1, 2, 3, 4 and 5."

l specifies that pressure instrument PI-1E12-R002C be used for j obtaining Unit 1 LPCI water leg pump suction pressure. Steps F.7, i F.8, and F.9 of LOS-RH-Q1 specify that pressure gauge PI-lE12-P612C

, be used for obtaining the "C" LPCI pump discharge pressure.

1 Contrary to the above, on March 9, 1986, the licensee obtained pressures for the Unit 1 LPCI and LPCI water les pumps test data using instruments other than those identified in LOS-RH-Q1.

l 1

i i

i i

i-

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

On March 21, 1986 LST 86-46 was performed which noted that 2E51-R604 pressure indicator was offscale high. The data indicate that the water leg pump was operable in shutoff head conditions with the discharge pressure slightly above the pump curve. On March 26, 1986, LOS-RI-Q3 were performed and the data was taken from the incorrect gauge as described in the inspection report. On April 4, 1986, LST 86-60 was performed and showed the pump to be operating satisfactorily. On April 16, 1986 LOS-RI-Q3 was performed and the water leg pump was indicated as being in the required action range. LST 86-72 was performed on April 29, 1986 to verify that the pump was still operating properly and action was taken to revise the LOS to establish new limits based on the actual pump performance. We believe that the RCIC water leg pump was operable throughout the period of concern.

As stated not all the vibration velocity measurements were made in the tests on March 21 and March 26, 1986. The RCIC water leg pump was fully tested with all required data taken (including vibration) and all vibration data were in the acceptable range on April 16, 1986.

As stated the test performed by LOS RH Q1 on March 9, 1986 used data from instrumentation other than that required by procedure. LOS-RH-Q1 was satisfactorily completed for the LpCI C pump and water leg pump on May 23, 1986 using the correct gauge. The use of the incorrect gauge had no affect on the results of the test.

CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION Procedure LAP-100-11 "LaSalle County Station General Surveillance Program," will be revised to require that if alternate instrumentation is used during performance of a surveillance, an evaluation of that use will be performed prior to taking any credit for that surveillance. Also the procedure revision will provide a specific form to document the reason why a surveillance is performed and why a partial surveillance was done if the entire surveillance is not completed. This form will also document any additional actions which must be taken to ensure operability of equipment and the resolution of those actions.

DATE OF FULL COMPLTANCE LaSalle is presently in full compliance. procedure revisions for clarification will be completed by January 15, 1987.

_4_

VIOLATION: IR 373/86029-02 (AIR 373-100-86-02902)

3. LaSalle Technical Specification 4.0.5 states that inservice testing of pumps and valves be performed in accordance with Section XI of the ASME Code unless specific relief has been granted by the Commission. IWP-3111 states that those pumps not tested during shutdown periods shall be tested

. and their characteristic parameters verified to be within the acceptable ranges as defined in the inservice testing program within one week of return to service. The licensee drained the reactor cavity on Unit 1 down on May 10, 1986, thereby returning the suppression pool to normal conditions and requiring two ECCS pumps to be operable.

Contrary to the above, the licensee did not verify the characteristic parameters of the two ECCS pumps declared operable to be within the acceptable range as defined in the inservice testing program within one I week of their return to service in that the "B" and "C" RHR pumps were tested on June 17 and May 23, 1986, respectively, and had not been

, acceptably tested during the shutdown period.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED An evaluation was performed during On-site review 86-16 completed May 9, 1986 recognizing that the high pump differential pressure was in the required action range and attributing this to the change in suppression

! pool level. This occurs because the suction pressure gauge is more sensitive to small pressure changes than the discharge pressure gauge due to the range of each gauge. This difference in indication in pressure change was confirmed to exist when the pumps were run af ter the suppression pool level was returned to normal and had been confirmed for similar pumps via testing at various pool levels. On May 23, 1986, and June 17, 1986, the performance of the C and B LPCI pumps respectively were

, verified to be satisfactory at normal pool levels.

CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION During cold shutdown and refueling modes with low suppression pool level the pumps which have a suction from the suppression pool will be deemed i operable using the Technical Specification flow and discharge pressure requirements alone. Within one week of restoring the suppression pool to normal level, the pumps will be run to verify the pumps remain within the normal operating limits for pump differential pressure.

DATE OF FULL COMPLIANCE The Station is in full compliance. The procedures which perform the testing of pumps with suction from the suppression pool will be revised by February 28, 1987.

4 2417K

{

i

• s . . ,,

ATTACHMENT B i

Response to Section 3 Paragraph 2 of Inspection Report 50-373/86-029 & 50-374/86-030 Despite observations made durina the IST inspection conducted in 1985, the licensee at the time of this inspection had still not performed a Quality Assurance audit of the inservice testina program athough such an audit was planned prior to the end of this calender year. Audit questions and areas of interest had yet to be developed."

The inspector reviewed Q.A. involvement in the May, 1985 inspection of IST (50-373/85-016; 50-374/85-016). That inspection report indicated that:

"The inspectors noted the Quality Assurance (QA) audits of the inservice testing program and associated testing had not been performed. Members of the Quality Assurance Department had performed audits of surveillance testing in general but had not audited the inservice testing program per se. The licensee stated that the Quality Assurance Department would consider adding points of inspection associated with inservice testing to their audit guidelines. No violations or deviations were identified".

Quality Assurance did consider the inclusion of IST requirements in their audit guidelines. The whole of section XI of the ASME Code was included in the 1985 audit schedule; however, the audit's main concern was Inservice Inspection (ISI). No specific items associated with subsections IWV or IWP were included, although other subsections were referenced.

The 1986 Quality Assurance audit schedule included "In-Process ISI/IST" with subsections IWP and IWV explicitly addressed in the reference section requiring specific questions / verification in the audit. The audit (QQA 01-86-29) was performed in October, 1986, as scheduled. This allowed for ample operation of both LaSalle units following startup from the Unit I refuel outage. This ensured sufficient IST data collection to allow for a creditable audit of the IST Program on both LaSalle units.

In addition, the IST area has been more clearly defined with regard to Quality Assurance involvement and the 1987 audit schedule has an IST audit scheduled for March, 1987.

l

.-_ - _ _ _ . - _ _ _ _ _ _