ML20212B531
| ML20212B531 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 02/06/1987 |
| From: | Taylor J DAIRYLAND POWER COOPERATIVE |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| LAC-12101, NUDOCS 8703030579 | |
| Download: ML20212B531 (4) | |
Text
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3*g D /DA/RYLAND hh[a/[ COOPERATlVE P O. BOX 817
- 2615 EAST AVE. SO LA CROSSE.
(608) 788 4 000 JAMES W. TAYLOR
' General Manager February 6, 1987 In reply, please refer to LAC--12101 DOCKET NO. 50-409 l
4 Mr. James G. Keppler Regional Administrator l
U. S. Nuclear Regulatory Commission 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 SALP 6 BOARD REPORT #50-409/86001 l.
REFERENCE:
(1) NRC Letter, J. Keppler to J. Taylor, dated September 30, 1986
Dear Mr. Keppler:
On October 9, 1986, a SALP meeting was held in Glen Ellyn, Illinois, to discuss the SALP 6 Board Report (Reference 1), which covered the period from January 1, 1985, through June 30, 1986. During the meeting, Bert Davis, l
Deputy Administrator, Region III, requested that Dairyland Power Cooperative i
submit a response on two areas: Maintenance / Modifications and Outages. This letter provides the response.
Regarding the Maintenance / Modifications topic, the report concluded:
"The licensee's performance regarding maintenance, especially as it relates to failure analysis, and the effectiveness of the preventive maintenance program, appears to have declined from that of the previous SAIJ' evaluation and should be given additional attention by the licensee.
On the other hand the licensee's modification program is considered very effective in not only improving operations but also in enhancing safety. However, due to the large number of equipment failures which have resulted in reactor scraag and other reportable events the overall performance in this area is rated Category 3. "
0703030579 07 ADOCK 050 ko9 R
PDR I
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l Mr. James G. Keppler.
February 6, 1987 Regional Administrator LAC-12102 U. S. Nuclear Regulatory Commission page 2 Outage / maintenance issues are closely tied to unexpected outage j
frequency (scram rate).
DPC has developed a program to reduce scrams significantly by the end of 1987. Of the 24 scrams of all power levels tabulated for 1985/86, the cause of 4 have been resolved (lA inverter changeout, procedure upgrade on secondary plant warmup and breaker winterization). Additionally, the detector cables for Nuclear Instrumenta-
. tion Channels Nos. 5 and 6 have been installed in rigid conduit in the Containment Building to eliminate noise.
Fourteen more will be dealt with in 1987 (nuclear instrumentation changeout, partial scram logic enhancement, i
1/3 of scram solenoids replaced, control air system upgrade and shutdown safety system relay replacement).
Five of the remaining 6 scrams (2/3 of scram solenoids, feedwater control system and non-vital equipment removal from vital buses) will be reviewed in 1987 for further action or be accomplished (remaining scram solenoids) in 1988/89.
The 6 scrams, should they reoccur, represent 3.0 scrams per year which is below the industry 1986 annual average (reported by INPO) of 3.8.
Other actions are being evaluated which could prevent occurrence of scrams repetitive in nature.
Any modifications selected will be based on the ability to integrate them safely into the plant in a systematic manner.
As recognized in the SALP report, actions recently taken did not have an opportunity to demonstrate their effectiveness during the SALP 6 period.
As actions underway are implemented, their effectiveness should be demonstrated as time progresses.
DPC recognizes that failure evaluation is a continuing process not limited to historical scrams only.
Plans are underway to replace various aging components subject to repetitivo failures, some of which can cause scrams, others for which replacement is good operations practice.
This effor t will continue for the life of the plant.
Two of the mechanisms used to identify candidate equipment for upgrading replacement are observations of staff personnel and the computerized maintenance request summary which indicates the frequency of repair on various components as well as by system.
A computerized report is available for review of historical maintenance of the equipment back through the beginning of 1986.
A significant factor in overall plant enhancement is the fact these practices are not limited to
" safety-related equipment" but include the balance of the plant which is covered by the LACBWR maintenance request process.
It is apparent, in reviewing industry events, that balance of plant problems have significant potential if they are not considered within the same context as safety-related events in addressing the aging issues.
DPC agrees that some of the events which occurred during the 1986 refueling outage could have been prevented by improved communications between plant personnel. Memos were sent to all plant personnel reminding them of the need to work together and perform jobs in a thorough manner and asking for suggestions on how to improve the next outage. DPC plans to incorporate the lessons learned from the 1986 refueling outage in planning for the 1987 outage.
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Mr. James G. Keppler February 6, 1987 Regional Administrator LAC-12102 U. S. Nuclear Regulatory Commission page 3 Efforts will be made to better integrate all maintenance and refueling-activities throughout outages. Pre-outage planning has increased each year including the addition of extensive efforts in scoping outage activities and preparing for planned maintenance and modifications.
Additionally, a mechanism to enhance outage planning efforts has been added to the LACBWR maintenance request forms starting with January 1987 issuance.
A location to quantify the manhours involved in the maintenance activity has been added to the maintenance request form.
The computerized maintenance tracking summary has also had the manhour field entered into its database.
This addition will permit us to generate a database of manhour efforts on particular maintenance activities which are repetitive in nature and will permit better and more accurate scheduling of outage activities during the pre planning stage.
It will also be an additional strengthening to our ALARA program in estimating potential exposures when job planning.
Other outage / maintenance planning issues include coordination, communication and root cause determination. Greater emphasis will be placed on these areas to enhance plant performance. Daily reporting of the maintenance department work schedule to the Operations Supervisor / Duty Shift Supervisor will be established. The communication will aid in operational support to maintenance to ensure better efforts are made to determine the root cause of failures (by aiding in diagnostics).
These efforts must be based on communications of all operationally observed component deficiencies (prior to failure) to the individual doing the maintenance work. We will also stress thorough completion of symptom / problem listing on the Maintenance Request form including followup observations beyond the initiating cause of the MR.
These observations, particularly in such categories as instrumenta-tion, provide valuable information to personnel attempting to determine the root cause of failure.
Repetitive failures will be brought to the attention of the Operations Review Committee.
Internal distribution has been started monthly using the computerized maintenance summary program of 2 reports which will be useful to supervisors in identifying repetitive or increasing problem areas. The one report lists all maintenance requests initiated during the preceding month, both reactor plant and balance of plant.
The second report summarizes all maintenance requests still open at the end of the month.
Widesprend exposure of this information should reduce both the potential of backlogs of maintenance requests being created and also the potential of missing significance of timing and repairing outstanding equipment.
These items of enhancement for maintenance and outages or any other area we feel needs improvement will be integrated into our commitment tracking system, in a manner similar to that used for the Regulatory Improvement Progrum, and implemented using applicable criteria of our Quality Assurance Program.
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Mr.~ James G. Keppler February 6, 1987 Regional Administrator LAC-12102 U. S. Nuclear Regulatory Commission page 4 If there 'are any ' questions regarding this reponse, please contact us.
Very truly yours, JWT:LSG:JDP:dh cc - Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C.
20555 NRC Resident Inspector Roby Bevan, NRC-Project Manager 4
1 J
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