ML20212M715
| ML20212M715 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/05/1987 |
| From: | Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212M694 | List: |
| References | |
| 50-409-87-02, 50-409-87-2, NUDOCS 8703120151 | |
| Download: ML20212M715 (10) | |
See also: IR 05000409/1987002
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U. S. NUCLEAR REGULATORY CCPNISSION
REGION III
Report No. 50-409/87002(DRS)
Docket No. 50-409
License No. DPR-45
Licensee: Dairyland Power Cooperative
2615 East Avenue - South
La Crosse, WI 54601
Facility Name: La Crosse Boiling Water Reactor
Inspection At: La Crosse Site, Genoa, Wisconsin
Glen Ellyn, Illinois
Inspection Conducted: January 5 through March 2, 1987
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Inspector:
Anil S. Gautam
M
Reactor Inspector, Region III
Date
Also participating in the inspection and contributing to the report were:
R. J. Smeenge
Reactor Inspector, Region III
R. Lasky, Engineer, I&E
M. Jacobus, Technical Staff Engineer
Sandia National Laboratories
D. Jackson, Consultant Engineer
Idaho hational Engineering Laboratory
H. Stromberg, Consultant Engineer
Idaho National Engineering Laboratory
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Approved By:
R. N. Gardner, Chief
Plant Systems Section
Date
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87031201S1 070306
PDH
ADOCK 05000409
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Inspection Summary
50_4,09/870_02JDRSR
. Inspection on January _5 thru February 27,1987 (Report No.
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Areas Inspected: Special announced safety inspection of the environmental
qualification (EQ)ofelectricequipmentwithinthescopeof10CFR50.49.
The inspection included licensee action cn SER/TER connitinents; EQ program
of EQ docunientation; and a plant
_ cceplianceto10CFR50.49; adequacy (ModulesNo.30703andNo.25576).
physical inspection of EQ equipment
Results: The licensee has implemented a program to meet the requirements
of 10 CTR 50.49. Deficiencies in the areas inspected are sumarized below:
Potentially Enforceable / Unresolved I_t_e_m
Item Number
Description
Report Section
50-409/67002-03(DRS)
EQ file for the GE RTV scalants
4a
not in an auditable form due to the
lack of a similarity analysis for
the sealing compounds RTV-615,
RTV-11, and RTV-106.
Open Items
Item Number
Description
Report Section
50-409/87002-01(DRS)
Lack of study to evaluate postulated
3b(1)
failures of containtrent cooling units
on the qualification of EQ equipment.
50-409/87002-02(DRS)
Lack of adequate participation of
3e
QA personnel in plant EQ training
program.
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DETAILS
1.
Persons Contacted
a.
Dairyland Power Cooperative (DPC)-
- J. W. Taylor, General Manager
+*J. Parkyn, Plant Supe. intendent
- J. Leifer, Assistant General Manager
- R. Brimer, Electrical Engineer
- B. Wery, QA Supervisor
b.
Consultants
- P. A. Di Benedetto, Di Benedetto Associates
c.
- I. V111alva, Senior Resident Inspector, LACBWR
- Denotes those attending the interim site exit interview on
January 9,1987.
+ Denotes those attending the exit interview on March 2, 1987,
at the conclusion of the inspection.
2.
Licensee Action on SER/TER Commitments
The NRC inspection team evaluated the implementation of the licensee's
EQ corrective action commitments made as a result of EQ deficiencies
identified by the NRC in the LACBWR June 25, 1982, FRC/TER; December 21,
1982, SER; and April 18, 1985 final SER for the environmental qualification
of safety related electrical equipment.
The majority of the deficiencies identified in the FRC/TER and SERs
addressed documentation, similarity, aging, qualified life and replacement
schedules. All open items identified in the FRC/TER and the SERs were
discussed with the NRC staff, and the licensee's proposed resolutions
to these items were found acceptable by the NRC, as stated in their
April 18, 1985 SER. The primary objective of the Region III EQ audit
in this area was to verify that appropriate analyses and necessary
documentation to support the licensee's proposed and accepted resolutions
to NRR were contained in the licensee's EQ files.
During this review, the NRC inspection team reviewed EQ documentation
relevant to prior discrepancies identified in the SERs. This included
licensee corrective action on Limitorque actuators, ASCO solenoid valves,
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Allis Chalmers electric motors, General Atomic radiation monitor
detectors, and level transmitters.
No violations of NRC requirements were identified.
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3.
EQ Program Compliance to 10 CFR 50.49.
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'The inspectors reviewed. selected areas of the licensee's EQ program to
verify compliance to 10..CFR 50.49. The licensee's EQ program identified
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methods-forl equipment; qualification; provides for evaluation and
maintenance of EQ documentation in an auditable form, including
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-maintenance records; provides for updating of replacement equipment, and ^
control of. plant modifications. Based on their review, the-inspectors
1 determined that the= licensee had established an~adeouate EQ program in
' compliance'with.the requirements'of 10 CFR 50.49. v licensee's methods-
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for establishing and maintaining the environmentalLc
'ification of
electrical equipment were reviewed in the following nas:
a.
EQ Program Procedures
The inspectors examined the' adequacy'of~the licensee's' policies
and procedures for establishing and maintaining the environmental
qualification of equipment within the scope of 10 CFR 50.49. The
licensee's EQ program was reviewed for procurement of qualified
equipment;' maintenance of qualified equipment; modifications to
the plant that could affect qualified equipment; updating of the
EQ master list; and review and approval of EQ documentation.
Procedures reviewed included the following documents:
.02.13, " Operations Review Committee (ORC),"
Issue 3,
dated August 28, 1986.
.03.4, " Environmental Qualification of Electrical
Equipment Important-to Safety Program," Issue 3,
dated August 18, 1986.
.04.3, " Substitution Request," Issue 8, dated
March 13,~1985.
.05.1, " Procurement Document Control," Issue 10,
dated December 26, 1985.
I&E
48-02, " Repair or Adjustment of Environmentally
Qualified Electrical Equipment," Issue 7, dated
December-16, 1986.
LACBWR Preventive Maintenance Cross Reference Listing,
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Issued December 18, 1986.
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Specific areas reviewed in these procedures included definitions
of harsh and mild environments, equipment qualified life, service
conditions, periodic testing, maintenance and surveillance, and
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upgrading of replacement equipment purchased'after February 22, 1983.
One deficiency was identified and is noted below:
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(1) During review of Procedure I&E 48-02, Revision 7, the
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inspectors noted that torquing requirements for housing
covers on transmitters, switches, ASCO valves and junction
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boxes did not include tolerances. The inspectors were
concerned that without tolerances the covers may be
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inadvertently under or over torqued, thereby affecting the
environmental seal the covers provided. The licensee took
immediate corrective action during this inspection, and
revised _the procedure to identify appropriate tolerances
'for the torque values.
No violation of NRC requirements were identified.
b.
10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment
IE Bulletin No.79-01B required licensees of all power reactor
facilities with an operating license to provide a MEL that
identified each Class IE electrical equipment item relied upon
to perform a safety function during a design basis event.
10 CFR 50.49, Paragraph (d), requires licensees to prepare a
list of electric equipment important to safety and within the
scope of the rule. The NRC inspectors reviewed the LACBWR
MEL for compliance to 10 CFR 50.49. Areas reviewed included
adequacy of the MEL, technical justifications for removal of
items from the MEL, and licensee reviews of the MEL for changes
due to field modifications.
The inspectors verified the completeness / adequacy of the list
in terms of equipment needed under accident conditions through
review of Piping and Instrumentation Drawings (P& ids), Emergency
Procedures, Technical Specifications and FSARs.
The inspectors
reviewed equipment needed to function under accident conditions,
including equipment used during a primary system leak, scrams,
and a complete loss of electric power.
Equipment needed for these
accidents were identified in the Plant Emergency Procedures 4.3,
4.1, and 4.2 respectively. All applicable equipment in the
procedures were reviewed for applicability and inclusion in the
MEL. The following exception was identified.
(1) The LACBWR containment building is maintained at a normal
operating temperature of 70 F to 80*F by means of two air
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conditioning units in the containment, and an independent
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blower fan that exhausts through a vent. The inspectors noted
that neither the air conditioning units nor the blower were on
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the MEL. The licensee stated that during an accident none of
this equipment was required to perform a safety function and
that the FSAR did not assume operation of this equipment for
the safe shutdown of the plant. The licensee also stated
that postulated failures of this equipment during normal
operation would cause a temperature rise in the containment,
if the equipment was not restored within an hour.
Since the above equipment had adequate redundancy, and
sufficient margins existed in the licensee's qualification
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specifications for EQ equipment in the containment, no concerns
regarding plant operability were identified. The licensee
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Lwas informed, however,:that any effacts on the-aging .of EQ :
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equipment in;the containment due to failures of the above-
equipment during normal operation must be addressed in their.
EQ files.1: The licensee. agreed to perform an onsite review / study
in summer to simulate postulate failures of the above equipment-
under worst ' case ambient conditions.
This study will identify
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-temperature rises in the containment during normal operation
and during and after an accident, as applicable. Pending NRC.
review of this study, this is an Open Item (50-409/87002-01(DRS)).
c.
EQ Maintenance and Surveillance Program-
The inspectors reviewed. specific maintenance, replacement,
surveillance tests, and inspections necessary to preserve the
environmental qualification of EQ equipment identified on the MEL.
The NRC inspectors found the licensee s methods for scheduling
maintenance and surveillance adequate.
No violations of NRC requirements were identified.
d.
Plant Procurement and Upgrading of Replacement Equipment
Licensee procedures adequately addressed upgrading of replacement
equipment purchased after February 22, 1983. Procurement procedures
and documents adequately addressed appropriate quality and regulatory.
requirements regarding the environmental qualification of equipment
within the scope of 10 CFR 50.49. Checklists were used to provide
evidence of reviews and approvals. For example, procurement packages
for the replacement of Foxboro transmitters, ASCO solenoid valves,
NAMCO limit switches and General Atomic radiation monitoring equipment
were found to properly address upgrading of replacement equipment to
requirements of IEEE 323-1974.
No violations of NRC requirements were identified.
e.
Quality Assurance (QA) and Training Program
During this review, the inspectors determined that the licensee
had implemented a program to monitor the quality of EQ activities
through surveillance, audits, and the reviews of the records and
files for plant modifications and equipment procurement. NRC
inspectors reviewed Audit 60-85-1, conducted in March 1985, and found
the methodology, results and follow-up of corrective action relative
to this QA audit acceptable.
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The inspectors also reviewed the licensee's staff training program
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and associated training records relevant to the performance of
EQ activities. Training records indicated that the licensee had
implemented a training program for key personnel responsible for
EQ activities, including management and operations and maintenance
personnel, and that the training program addressed key aspects of
10 CFR 50.49 requirements. The NRC inspectors noted that personnel
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from the QA department had not attended the plant EQ training;
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- however, the plant QA personnel did exhibit _ a consistent; awareness 'of
. environmental qualification requirements.of 10 CFR 50.49. 'The.
licensee agreed to increase the participation'of all appropriate
personnel in the EQ training program. Pending further NRC review of
the plant's EQ training' program, this.is an Open Item
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- (50-409/87002-02(DRS)).
- 4.
- Detailed Review of Qualification Files
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The licensee qualified their EQ equipment.to the requirements of the
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DOR Guidelines (10 CFR 50.49, Paragraph K). -The inspectors reviewed 29
equipment qualification files for evidence of the environmental
qualification of-equipment within the scope of 10 CFR 50.49 and evidence
of equipment qualification to the DOR Guidelines.
Files were found to
include a full description of-the equipment; similarity analysis of tested
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equipment to that installed in the plant; allowed mounting methods and
orientation; qualification of interfaces (conduit housing, seal, etc.);
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evaluation of aging effects on equipment; description of test' sequence
and methodology; environmental conditions for the equipment during an
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accident; qualification for submergence of applicable equipment;
resolution of test anomalies; and maintenance / surveillance criteria
for the preservation of the qualified status of the equipment.
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The inspectors selectively reviewed the above areas, as applicable,
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including special reviews for the required duration of operability of
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equipment; licensee evaluation of tested materials and configurations
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relative to actual plant installations; adequacy of test conditions;
aging calculations for qualified life and replacement intervals; effects
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of decreases in insulation resistance on equipment performance; adequacy
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of demonstrated accuracy of equipment and interfaces; and licensee
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evaluations of discrepancies identified in IE Notices and Bulletins.
EQ files were reviewed for Electrical Cables, Cable Splices, Terminations,
Terminal Blocks, Electric Motors, Solenoid Valves, Electrical Penetrations,
Seals, Lubricants, Transmitters, Detectors, Radiation Monitors, Limit
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Switches and Switch Gear. The inspectors found that in almost all cases
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the files allowed verification of equipment qualification to a specified
performance for accident conditions. Exceptions are noted below:
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a.
General Electric (GE) RTV Sealant
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LACBWR uses two kinds of RTV potting compounds, RTV 11 and RTV 615,
as a moisture intrusion seal at the connections of mineral insulated
cables to EQ devices. Both kinds of compounds are used inside
non-EQ gasketed condulets in their appropriate appitcations. During
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this review the inspectors noted that the licensee did not have
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adequate documentation in their EQ files to justify the use of these
compounds in a steam environment.
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At the site exit _ meeting.the licensee provided an additional existing
test report of research conducted at Wyle Laboratories relative to
the sealing of.in-containment electrical, equipment. This test report
(Research Project RP 1707-12)' indicated that a similar sealing
compound, GE RTV 106,_had been tested at 300'F, 60 psig,'and exposed
1to-steam and chemical spray with no anomalies.. The NRC-inspectors
found this test acceptable in terms of the environmental conditions
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tested and the similarity of tested sealant to the installed sealants;
however,:the licensee did not have a similarity analysis in their
file to permit proper verification.
Based on their review of the test data on RTV 106, the inspectors-
determined that sufficient qualification documentation had been
available at the site to mitigate concerns regarding the qualification
of the installed RTV. sealants.
10 CFR-50.49 Paragraph (j) states
. that _a record of qualification, including documentation, must be.
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maintained in an auditable form for the entire period during which
the covered item is installed in the plant to permit verification
that the equipment is qualified for its application and meets its
performance requirements during an accident. Contrary to the
above, the EQ file for the RTV sealant was not auditable to permit
appropriate verifications, in that a similarity analysis of the
above sealants was missing. - The licensee's failure to maintain an
auditable EQ file for the RTV sealant past the November 30, 1985 EQ
deadline is considered a violation of 10 CFR 50.49, and pending
further review this is a Potentially Enforceable / Unresolved Item
(50-409/87002-03(DRS)).
b.
Containment Flood Level
-During review of the EQ files, the inspectors noted that there was
no positive statement in the files to identify the plant containment
flood level, and that the files did not include any qualification
for submergence.
The licensee identified the cause of the worst flood condition to
be a line break below the core level.
In such an event the licensee
confirmed that the containment flood level would reach elevation 630'
in approximately three hours. The NRC inspectors reviewed calcula-
tions done by the licensee regarding the time and elevation at which
the appropriate EQ equipment would be submerged, and the time and
sequence at which the EQ equipment would perform their safety
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function. The licensee's evaluation stated that all EQ equipment
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would perform their safety functions prior to submergence; however,
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statements regarding submergence had not been included in the files.
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The licensee was informed that appropriate flood levels needed to be
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addressed in their EQ files.
The licensee took immediate corrective
action to include appropriate statements in their EQ files and to
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clarify requirements for submergence.
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No violations of NRC requirements were identified.
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c.
ASCO Solenoid Valves
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_During review of the.EQ files for the' ASCO solenoid valves, the-
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inspectors noted that the manufacturer had recommended monthly
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cycling'of the valvesias a means for preventive maintenance. The
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licensee confirmed that-this recommendation was;not being implemented;
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however, there was no technical justification in .their EQ files.
-The. licensee was informed that the manufacturers' recommendations'-
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should be considered to be EQ requirements unless technically
-justified to not affect the EQ of the equipment.
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The licensee took'immediate corrective action and performed an
evaluation of past cycling performed on the appropriate EQ valves.
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Based on their evaluation they demonstrated that conservative
assumptions.in~ periodic testing and good maintenance history
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justified less frequent cycling of the valves.
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No violations of NRC requirements were identified.
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5.
Plant Physical Inspection
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The NRC inspectors selected over 27 items 'on the MEL for examination-in
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the plant. The EQ file'of each item had been reviewed, and information
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orientation,-environment, and interfaces had been noted. .The inspectors
examined the selected items in the field,.if accessible, and verified
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that the method of installation of each item was not in conflict with
its environmental qualification.
Specific areas reviewed included
traceability of installed items to EQ files, ambient environmental
conditions, qualification of interfaces (connectors, wires, seals,
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insulation, lubricants, etc.), evidence of significant temperature
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rise from process, drainage, mounting methods, physical conditions and
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housekeeping.
Items examined in the field during this walkdown were
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found to meet their appropriate EQ requirements with the following
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exceptions:
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a.
ASCO Solenoid Valves 62-25-021, and 62-25-022
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During examination of these valves in the plant the inspectors
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noted that both valves were held in place by Mineral Insulated (MI)
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cable and instrument air lines or process piping. The inspectors
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were concerned that vibration from the estraints would affect the
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operation of the valve. The licensee stated that the rigid mounting
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supports provided by the MI cable and pipe nipples were adequate as
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the valves de-energized to perform their safety function during an
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accident.
The licensee also stated that a seismic study was being
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performed on the associated control valves as part of the LACBWR
Integrated consequence Study (NUREG-0827), which would include a
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review of the effects of any induced vibration on the ASCO valves
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during service conditions.
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No violations of NRC requirements were identified.
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Open Item
Open Items are_ matters which have been discussed with the licensee,
which will'be reviewed further by the inspector, and which involve
some action on the part of the NRC or licensee or both. Open Items
disclosed during this inspection are discussed in Paragraphs 3b(1),
and 3e.
7.
Potentially Enforceable / Unresolved Item
An unresolved item is a matter about which more information is required
in order to ascertain whether it is an acceptable item, an open item, a
deviation, or a violation.
Potentially Enforceable / Unresolved Items are
unsolved items, which if ascertained to be a violation will be followed
up with enforcement action in accordance with NRC enforcement guidance
on environmental qualification. A Potentially Enforceable / Unresolved
Item is discussed in Paragraph 4a.
8.
Exit Interview
The Region III inspectors met with the licensee's representatives (denoted
under Paragraph 1) during an interim exit on January 9,1987, and
discussed findings by phone at the conclusion of the inspection on
March 2, 1987. The inspectors summarized the purpose and findings of
the inspection and the licensee acknowledged this information. The
licensee did not identify any documents / processes reviewed during the
inspection as proprietary.
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