ML20138G039

Responds to NRC Re Violations Noted in Insp Rept 50-409/85-13.Corrective Actions:Affected Carbon Dioxide Cylinders Replaced by Halon Fire Extinguishers & Surveillance Test Upgraded to Preventive Maint Sys

ML20138G039
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	10/16/1985
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
LAC-11194, NUDOCS 8510250398
Download: ML20138G039 (5)

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. 3 D DA/RYLAND h [k COOPERAT/VE eo Boxsi7 2 sis EAST AV SOUTH . LA CROSSE WISCONSIN 54501 (608) 788 4000 October 16, 1985 In reply, please refer to LAC-11194 DOCKET No. 50-409 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Directorate of Regulatory Operations Region III 799 Roosevelt Road Glen Ellyn, IL 60137

SUBJECT:

DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)

PROVISIONAL OPERATING LICENSE NO. DPR-45 IE INSPECTION REPORT NO. 50-409/85013 (DRS)

RESPONSE TO NOTICE OF VIOLATION

. feference: (1) NRC Latter, Reyes to Taylor, dated September 18, 1985.

Dear Mr. Keppler:

The following is our response to the Notice of Violation submitted as an Appendix to your letter (Reference 1):

Notice of Violation As a result of the inspection conducted on July 8-11, August 20, and August 30, 1985, and in accordance uith the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violation vaa identified:

Technical Specification 15.6.8.1f for the TA Crosse plant states, in part, " Written procedures shall be established, implemented, and maintained covering ... Fire Protection Program implementation."

Section B.6.e of the licenasee's Appendix A response to the Branch Technical Position 9.5-1 indicated that " Carbon dioxide (CO2 ) extinguishing units are to be tested every five years in accordance with the Factory Mutual Handbook." The uritten procedure for this requirement is located in the Fire Protection Program Implementation Procedure 6.5.

Contrary to the above, fire extinguishers vere past due their required hydrostatic test achedule and had not been removed from service.

UP6.26 8510250398 851016 0CT 2 1 N PDR ADOCK 05000409 l G PDR

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Mr. James G..Kappist Orobsr 16, 1985

,- . Regional Administrator LAC-11194 DPC Response The affected CO2 cylinders have been replaced by Halon fire extinguishers that have a higher extinguishment capacity and would be less harmful to the equipment'they are intended to protect.

A statement that portable extinguishers which will reach their hydro date before the next semi-annual inspection will be removed from service, will be inserted in the inspection procedure, FPP 6.5.

Date Full Compliance Achieved Halon extinguishers were installed on October 4, 1985.

In addition, the following open items have been addressed:

Open Item (409/85013-02(DRS))

The Licensee had not~ completed the analysis for open current transformer secondaries as the result of a fire. The inspectors identified current transformer application in the control circuits for the emergency diesel generators 1A and 1B, which could be damaged in a control room fire. No determination had been made by the Licensee regarding the effects of this damage on the operability of the emergency diesels. Therefore, the licensee is requested to submit to Region III the analysis for open current transformer secondaries as the result of a fire.

Current Transformer Secondaries Response A review of the circuits-containing current transformers was completed for the diesel generator, which the current transformers supply instrumentation to the control room only and do not affect any control circuits. In conversation with Electrical Engineering departments of Allis-Chalmers, Westinghouse,-and DPC personnel, the general opinion is that if a current transformer opens it will merely burn itself out internally and not create a major problem.

Open Item (409/86013-04 (DRS)) Section 1 (1) Lighting Unit Placement

'he inspectors questioned whether adequate illumination is available in the following plant areas:

(a) Along the path of the Containment Building' stairway, 640' elevation

.(grade floor), to the 701' elevation.

(b) Containment Air Lock area - One DC Lighting unit was revived to an

'eight hour battery; however, this bulb does not appear to give adequate illumination when both containment air lock doors are closed.

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Mr. James G. Keppler October 16, 1985 Regional Administrator LAC-11194 (c) Upper platform of the shutdoun condenser platform where an operator is required to read an instrument gage.

At the exit meeting of July 11, 1985, the Licensee indicated that a valkdown vould be performed along the required emergency Lighted path to determine if adequate emergency lighting ittumination levela are available.

Emergency Lighting Response On September 28, 1985, all illumination in the containment was turned off and the areas of concern were verified to have adequate lighting by the following personnel: Fire Protection Supervisor, Operations Supervisor, and Licensed Reactor Operator.

Open Item (409/85013-06 (DRS))

The inspector observed that a hydrogen detector is instatted in the electrical equipment and in the "1B" battery rooms, which contain the station batteries. Both hydrogen detectors alarm in the control room at a pre-determined hydrogen concentration. In the inspector's review of the periodic maintenance program on the hydrogen detectors, it was noted that these detectora vere due for a semi-annual surveillance test (previously completed in December 1984) during July 1985. These testa had not been completed at the time of the inspection visit although the 25 percent extension period as allowed by Technical Specifications had not expired. The hydrogen detectors are currently covered under the plant routine job tickler program which has a lover priority than a second program known as the

" Preventive Maintenance Program." The inspector requested the Licensee to avitch the testing program for the hydrogen detectors. Licensee management agreed to consider the inspector's request. This is considered an Open Item pending timeliness of the surveillance test completion.

Hydrogen Detector Semi-Annual Surveillance Test Response The surveillance test had been upgraded from a tickler file to a Preventive Maintenance system by August 30, 1985.

Open Item (409-85014-09(DRS))

Section B.6.e of Appendix A of the Licensee's response to the Branch Technical Position 9.5-1 stated, in part, " Testing and maintenance of the fire protection equipment is performed according to established schedules for the foltouing : (a) portable extinguishera... Portable extinguishers are inspected, tested, and maintained in accordance with FM recommendations contained in the FM Handbook of Industrial Losa Protection."

Section 4-6 of the FM Losa Prevention Data Sheets (formerly FM Handbook of Industrial Losa Protection) indicated that carbon dioxide extinguishere need to be hydrostatically tested every five years.

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Mr. James G. Keppler October 16, 1985

. Regional Administrator LAC-11194 The inspectors observed that the 100 pound Cog uheeled unit located on the main floor of the Turbine Building, 668' elevation, and tuo 5 pound cog extinguishing unite located in the electrical equipment room (access way to control room benchboani consoles), 654' elevation vare past due their scheduled periodic hydrostatic retest. The 100 pound Cog uheeled unit was last tested in April 1978 and was due again during April 1983 uhile the two portable cog units vere last tested in Februarit 1978 and were due again during February 1983.

This represents a violation of Technical Specification 15.6.8.1.f concerning the implementation of the Fire Protection Program.

DPC Response See Answer to violation.

p en Item (409/85013-10(DRS))

The inspector reviewed Procedure No. FPP 6.7 titled, " Fire Equipment Location and Inventory and MSA Monthly Inspection" uith the follouing coments:

a. The handlights located at the fire brigade station were not being inventoried or functionally tested.

b. The smoke ejector located at the fire brigade station uas not receiving a check to verify its operability.

These tuo coments are considered an Open Item pending revision of this procedure.

Fire Equipment Inventory Resposne On September 10, 1985, a change to FPP 6.7 that incorporates items a and b was submitted for ORC reiew and has since been implemented. ,

The remaining open items are currently being worked on for a timely resolution.

If you have any questions regarding this submittal, please feel free to contact us.

Sincerely, DAIRYLAND POWER COOPERATIVE ff James W. Taylor General Manager JWT:MTP:sks I

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k Mr. James G. Keppler. October 16, 1985 Regional Administrator ' LAC-11194 cc: Luis A. Reyes, Chief Operations Branch Region- III NRC Resident Inspector John Stang, LACBWR Project Manager b

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