ML20212M715

Insp Rept 50-409/87-02 on 870105-0302.Deficiencies Noted: Environ Qualification File for GE RTV Sealants Not in Auditable Form & Lack of Adequate Participation of QA Personnel in Environ Qualification Training Program

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: ML20212M691 ML20212M715
References
50-409-87-02, 50-409-87-2, NUDOCS 8703120151
Download: ML20212M715 (10)

See also: IR 05000409/1987002

Text

.

,Q

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

Inspector: Anil S. Gautam M M*/5P "" 3! &7 '

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

[, A, MAAk&h

Approved By: R. N. Gardner, Chief 87

Plant Systems Section Date

"

87031201S1 070306

PDH ADOCK 05000409

0 PDR

.

O

Inspection Summary

. Inspection on January _5 thru February 27,1987 (Report No. 50_4,09/870_02JDRSR

8

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

_physical

cceplianceto10CFR50.49; adequacy (ModulesNo.30703andNo.25576).

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.

2

.

.

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. USNRC

• 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,

Allis Chalmers electric motors, General Atomic radiation monitor

detectors, and level transmitters.

No violations of NRC requirements were identified.

I

i

l

3

i

'

.

' +

v

EQ Program Compliance to 10 CFR 50.49.

~

3.

'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

P methods-forl equipment; qualification; provides for evaluation and

maintenance of EQ documentation in an auditable form, including .

-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-

.

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:

ACP .02.13, " Operations Review Committee (ORC),"

Issue 3, dated August 28, 1986.

ACP .03.4, " Environmental Qualification of Electrical

Equipment Important-to Safety Program," Issue 3,

dated August 18, 1986.

ACP .04.3, " Substitution Request," Issue 8, dated

March 13,~1985.

ACP .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,

j Issued December 18, 1986.

l Specific areas reviewed in these procedures included definitions

of harsh and mild environments, equipment qualified life, service

t

conditions, periodic testing, maintenance and surveillance, and

l upgrading of replacement equipment purchased'after February 22, 1983.

'

One deficiency was identified and is noted below:

!- (1) During review of Procedure I&E 48-02, Revision 7, the

it inspectors noted that torquing requirements for housing

,. covers on transmitters, switches, ASCO valves and junction

j boxes did not include tolerances. The inspectors were

'

concerned that without tolerances the covers may be

!

i

i

I

4

[

.

J-

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

. conditioning units in the containment, and an independent

I

blower fan that exhausts through a vent. The inspectors noted

i that neither the air conditioning units nor the blower were on

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

! specifications for EQ equipment in the containment, no concerns

regarding plant operability were identified. The licensee

!

5

l

, --

.

-

,

n:; s

4

Y Lwas informed, however,:that any effacts on the-aging .of EQ :

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 -

-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.

.

The inspectors also reviewed the licensee's staff training program

l 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

j from the QA department had not attended the plant EQ training;

L

,

l 6

l

l

t-

. ._ _ _ . __ - . . ._. _ m- _

r.  ; ,, l

'

. h. . ,

-

- 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

- (50-409/87002-02(DRS)).

- 4. - Detailed Review of Qualification Files

i

The licensee qualified their EQ equipment.to the requirements of the ,

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

i' equipment to that installed in the plant; allowed mounting methods and

, orientation; qualification of interfaces (conduit housing, seal, etc.);

evaluation of aging effects on equipment; description of test' sequence

and methodology; environmental conditions for the equipment during an  ;

'

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.  :

L The inspectors selectively reviewed the above areas, as applicable, '

! including special reviews for the required duration of operability of

, equipment; licensee evaluation of tested materials and configurations

! relative to actual plant installations; adequacy of test conditions;

aging calculations for qualified life and replacement intervals; effects

[

.

of decreases in insulation resistance on equipment performance; adequacy

of demonstrated accuracy of equipment and interfaces; and licensee

-

.

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

j Switches and Switch Gear. The inspectors found that in almost all cases

i the files allowed verification of equipment qualification to a specified

performance for accident conditions. Exceptions are noted below:

, a. General Electric (GE) RTV Sealant

'

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

i

non-EQ gasketed condulets in their appropriate appitcations. During ,

! this review the inspectors noted that the licensee did not have '

adequate documentation in their EQ files to justify the use of these

compounds in a steam environment. L

1

i

l

i

!.

i

) 7

i

T

• ,,w ,we ,e-,,, -+-p.mm , _ _ -y ene,y y , m-mw- - --- . ..w'

w ,

,

s

'* '

-

1

3

,

N.

-

, 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 <

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.

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

~

function. The licensee's evaluation stated that all EQ equipment

. would perform their safety functions prior to submergence; however,

) statements regarding submergence had not been included in the files.

!

j' The licensee was informed that appropriate flood levels needed to be

[ addressed in their EQ files. The licensee took immediate corrective

i action to include appropriate statements in their EQ files and to

j clarify requirements for submergence.

l

l No violations of NRC requirements were identified.

!

i

!

! 8

!

!

[

. - - ... ... - . . . - . - . - - . . ..

h .

.,

,

i

"

, c. ASCO Solenoid Valves

_During review of the.EQ files for the' ASCO solenoid valves, the-

-

.

'

inspectors noted that the manufacturer had recommended monthly

cycling'of the valvesias a means for preventive maintenance. The

.

licensee confirmed that-this recommendation was;not being implemented;

3: however, there was no technical justification in .their EQ files.

-The. licensee was informed that the manufacturers' recommendations'-

'

4

i! should be considered to be EQ requirements unless technically

-justified to not affect the EQ of the equipment. t

,

The licensee took'immediate corrective action and performed an

,

evaluation of past cycling performed on the appropriate EQ valves.

p Based on their evaluation they demonstrated that conservative

4 assumptions.in~ periodic testing and good maintenance history

,

justified less frequent cycling of the valves.

No violations of NRC requirements were identified. '

5. Plant Physical Inspection

i

The NRC inspectors selected over 27 items 'on the MEL for examination-in

j the plant. The EQ file'of each item had been reviewed, and information

t

regarding the location, manufacturer, model/ serial numbar, mounting,

i orientation,-environment, and interfaces had been noted. .The inspectors

.!

examined the selected items in the field,.if accessible, and verified

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,

, insulation, lubricants, etc.), evidence of significant temperature

rise from process, drainage, mounting methods, physical conditions and

!' housekeeping. Items examined in the field during this walkdown were

'.

found to meet their appropriate EQ requirements with the following

exceptions: i

l

'

l- a. ASCO Solenoid Valves 62-25-021, and 62-25-022

. During examination of these valves in the plant the inspectors  ;

!- noted that both valves were held in place by Mineral Insulated (MI)

!

'

cable and instrument air lines or process piping. The inspectors

were concerned that vibration from the estraints would affect the

l. operation of the valve. The licensee stated that the rigid mounting

! supports provided by the MI cable and pipe nipples were adequate as '

l the valves de-energized to perform their safety function during an

! accident. The licensee also stated that a seismic study was being

j' performed on the associated control valves as part of the LACBWR

'

Integrated consequence Study (NUREG-0827), which would include a

review of the effects of any induced vibration on the ASCO valves

j during service conditions.

i

l No violations of NRC requirements were identified.

!

>

9

4

-. _ _. - _ ___ _ _. __.. -.~ -.-._.-_-___.~..__.__.._~_._..._ _ _.

- .

0

-6. 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.

10