IR 05000331/1985036

Insp Rept 50-331/85-36 on 851209-860110.No Violation or Deviation Noted.Major Areas Inspected:Control of Engineering,Maint & Surveillance Testing Activities Re HPCI & RCIC Sys

ML20137N693
Person / Time
Site:	Duane Arnold
Issue date:	01/30/1986
From:	Hawkins F, Sutphin R, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137N686	List: IR 05000331/1985036 ML20137N682
References
50-331-85-36, NUDOCS 8602040219
Download: ML20137N693 (10)

Text

.

o U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-331/85036(DRS)

Docket No. 50-331 License No. DPR-49 Licensee: Icwa Electric Light and Power Company Security Building, P. 0. Box 357 Cedar Rapids, IA 52406 Facility Narre: Duane Arnold Energy Center Inspection At: Palo, IA Inspection Conducted: December 9, 1985 thrcugh January 10, 1986

\ 3c; 8'b Inspectors: R. A. Westberg , _ . _

Q.G.%3 R. N. Sutphin \ ~i~30 i b~a'te Approved By: F. Hawkins, Chief i / 5 C) /86,

'

Quality Assurance Prograns Secticn Date Inspection Sumary Inspection conducted December 9,1985 through January"10,1985

- ~~ ' ~~

(Report No. 50733TffiSTf3M'D'RS)

Areas liis~p'e_cted_:_ Special inspection by two regional inspectors of control of engineering, maintenance, and surveillance testing activities relative to the HPCI and RCIC systems. The inspection involved 138 inspector-hours onsite and 42 inspector-hours at Region III. It was conducted in accordance with NRC inspection procedures Nos. 30703, 39701, 61700, 61724, 61725, 62700, 62702, and 9270 Results: No violations or deviations were identifie PDR 0 ADOCM 05000331 PDR

.

-

.

DETAILS 1. Persons Contacted Iowa Electric Light and Power Corpany_

• D. L. Mineck, Plant Superintendent

• R. Hannen, Assistant Plant Superintendent, Operations

• J. Miller, Technical Services Superintendent

• B. Lacy, Maintenance Superintendent

"J. C. Smith, Acting Technical Support Supervisor

• R. A. McCracken, Quality Control Supervisor

• C, R. Mick, Operations Supervisor

• D. Wilson, Licensing Manager -

• R. Lessly, Manager Design Engineering

• Y. Anagnostopoulos, Maintenance Engineering Supervisor

• R. Rockhill, Mechanical Maintenance Supervisor

• Huting, Assistant Guality Control Supervisor

• D. Essig, Supervising Quality Assurance Engineer

• R. Browning, Senior Licensing Engineer

• S. Grim, Licensing Engineer

• B. Leimkuehler, Mechanical Engineer

• M. Dwyer, Technical Group Leader

• L. G. Jenkins, Quality Assurance Engineer

• A. Steen, Operaticns Shif t Supervisor

• B. Seely, Mechanical Foreman

• D. Pladsen, Mechanical Foreman A. R. Jacobstein, Plant Performance Engineer K. Peveler, Senior Mechanical Engineer J. Kozman, Supervising Engineer T. G. Dalten, Licensing Engineer R. L. Zook, Assistant Operations Supervisor G. R. Fulford, Maintenance Planner L. Voss, Electrical Maintenance Supervisor

_

General Electric

• J. W. Smith, Operations Engineer U.S. fluclear Reg.ula.t_ory Cornission

• J. S. Wiebe, Senier Resident Inspector

• fi. Valliere, Resident Inspector Other licensee personnel were contacted as a matter of routine during the i inspectio * Denotes those present at the exit interview on January 10, 198 '

.

2. HihPressureCoolantInjection_(~HPCIlSA tem and Reactor Core Isolation

~ ~-~- ~ ~

oo 'i~ng TRCTCT SysteiiMeTiibilTty A~ss.es_st;Lep_t' ~ ~~~ ~ ~ ~ ~ ' ~ ~ '

The purpose of this inspection was to perform an indepth assessment of the control of engineering, maintenance, and surveillance testing cn the HPCI and RCIC systems by the licensee and their contractors. This inspection was prompted by the NRC's concerns regarding the apparent lack of reliability of the HPCI and RCIC syste.ms as evidenced by the numerous Licensee Event Reports (LERs) issued from 1983 to date. These concerns were heightened in the maintenance area because of poor performance, personnel errors, lack of trending, incomplete equipment history, and a relatively large backlog of corrective maintenance items. They are reflected in previous NRC inspection reports and were the basis for the ceclining SALP rating in the maintenance functional are Objectives The objectives of this assessment were to (1) analyze engineering, maintenance, and surveillance activities relative to the HPCI and RCIC systems; (2) determine basic underlying causes of problems; (3)

develop observations and (4) provide recommendations for actio Methodolo,91 This assessment was conducted through the evaluation of Licensee Event Reports (LERs), Deviation Reports (DRs), Ncnconformance Reports (NCRs),

Corrective Maintenance Action Requests (CMARs), Service Information Letters (SILs), preventive maintenance (PM) procedures, maintenance procedures, surveillance testing procedures, measuring and test equipment (M&TE) use, and ongoing maintenance training. The inspectors also conducted a program overview through a review of policy documents, control documents, and personnel interview Results (1) LER Review The inspectors reviewed all the HPCI and RCIC system LERs for 1984 and 1985 against the requirements of 10 CFR 50.73. Special attention was paid to classification and deternination of root causes. This review resulted in the following observations:

(a) Root causes were incorrectly identified on two of eight HPCI LER (b) Root causes were not specified cn three of eight RCIC LERs and roct causes were incorrectly identified on four of the five remaining LER .

(c) LER cause code "x", meaning other or unkncwn, was employed in 6 of 16 samples (37%). The use of this cause code appeared excessive; however, its usage on the 1985 HPCI LERs showed a decrease, while its use on RCIC LERs showed an increase during the same perio (d) Human error was the basis for two HPCI and one RCIC LERs in 1984. No LERs were attributed to human error in 19E (e) HPCI reliability appears to be increasing. The fact that five LERs were filed in 1984 and three were filed in 1985 supports that conclusion. Further, of the three LERs filed in 1985, only one relates to HPCI reliability. One of the remaining two, LER 85-007, was written to inform the NRC and the industry of a HPCI turbine reversing chamber cracking problem. The other, LER 85-043, documented a voluntary outage to perform maintenance on a leaking valv (f) RCIC reliability appears to be decreasing. This conclusion is based on the fact that three LERs were filed in 1984, while five were filed in 1985. Of the 1985 LERs, three were caused by defective materials or ccmponents, and the remaining two were caused by either defective procedures or preventive maintenanc (2) Dev_iation Report Review Deviation Reports on the HPCI and RCIC systems were reviewe Deviation Reports (DRs) document the identification and evaluation of a deviation. Deviations include violation of the technical specifications; environmental technical specifications; surveillance test procedures; operations manua The deviation reporting system is described in Administrative Control Procedure (ACP) No. 14022, Revision All plant personnel are responsible for the prcmpt identification of deviations, the origination of deviation reports, and providing the DRs to the Operations Shift Supervisor. A total of 246 DRs had been written and listed on HPCI and RCIC systems since October 1975. The inspectors' review of these DRs produced the following observaticns:

(a) Information that is available to assist in trending and problem evaluation is not always used. Several obvious trends in the failure mcde of instrumentation and pressure switches were recognized by the inspectors during their review that had neither been recognized nor investigated by the license .

(b) Cause codes, such as " unknown" or " instrument drift",

appear to be used too frequently. In a sample of 25 HCPI ,

and RCIC DRs written for instruments found out of tolerance,17 docun.ented the cause as instrument drif t and no cause was given on 5 other (c) Late management reviews and closecuts may be precluding the potential berefits of prompt and effective corrective actions, k:hile the nonnal time required to close out a DR was one to three months, one DR was identified that was closed two years after an event. Similarly, two DRs were identified that were closed eight months af ter the respective event (3) Nonconformanc_e_ Rep _ ort Review Nonconformance Reports (NCRs) for the HPCI and RCIC systems that were written during the pericd 1982 through 1985 were selected for review. Fourteen NCRs were reviewed. Two NCRs applied to both HPCI ar.d RCIC, nine applied to HPCI, and three applied to RCI These reviews produced the following observations:

(a) Engineering evaluations in the past have not always been timely. For exarrple, the engineering evaluation required by NRC No.84-034 (1984) had not been con.pleted at the time of this inspection. When the inspectors brought this issue to the attention of licensee personnel, action was taken to perform the required evaluatio (b) Engineering evaluations in the past have not always been as complete as they should be. The engineering evaluation for NCR fo.85-135 failed to address how long the HPCI turbine would ccntinue to run with water contamination in the oil. The evaluation did, however, address starting and reaching the required speed in the required time. Further, the engineering evaluation for NCR No.83-151 did not clearly define a test for acceptatility upon completion of RCIC turbine trip coil rewin (4) Corrective Maintenance Acticn Re, quest Review The inspectors reviewed the licensee's list of CMARs issued for work on components either ccntained within the HPCI and RCIC systems or directly associated with the systems. The list contained 600 items of work activity frcn 1978 to December 10, 1985. The list included the CPAR number, origin date, i activation date, corrpletion date, component identification, and a brief description of the maintenance problem or activity required. The list was arranged in numerical order by the CFAR numbe :

ew

-

.

The inspectors used the list to generate a CMAR history for three safety-related n.otor operated vahes in the HPCI system, for further review. This history was limited to activity from 1981 through 1985. The valves selected were E0V-2239 (HPCI steam lire cutboard isolation vahe), MCV-2238, HPCI steam line inboard isolaticn valve), and POV-2202 (HPCI steam supply valve). This maintenance history review resulted in the following cbservations:

(a) The planned component raaintcnance history program had not teen implemented to identify adverse trends and potential problem (b) Root causes are not always identified in the maintenance data packages for future reference and us (c) Corrective acticns are not always taken pror.ptly wherever adverse trends or significant prcblems are identified as evidenced by the repetitise maintenance on the HPCI steem supply valves during a 23-ircnth pericd in 1982 and 198 (d) l'aintenance trainir.g cr retraining is not conducted for areas that show adverse trend (5) Serv ce Information Letter (SIL) Review i

SILs are issued by General Electric Nuclear Fuel and Services Division to reconar.end actions to be taken for problems that have been experienced by crerating EWR plant During this inspection, the licer.see's HPCI/RICI Reliability l Task Force Chairman indicated that 13 SILs were being evaluated l by the task force. The inspector read SILs and selected four which specifically indicated that system reliability could be improved through their implementatio The following cbservations were made:

(a) SIL No. 31 (1976) and SIL No. 336 (1980) had been previously evaluated and partially iraplen.ented; however, more work was being considered during the term of the inspectio (b) SIL No. 377 (1982) and SIL No. 382 (1982) were being evaluated. No evidence of previous evaluation was eviden (6) Preventive Maintenance Review Prever.tive maintenance is established by Chapter 8 of the Ouality Assurance Mar.ual . It is irrplemented by Procedure Nc. 1409.2, " Preventive Maintenance," Revision 3, and Procedure No. MD-012, " Preventive Maintenance Action Frquest (PVAR) Form Description," Revision 0. PM is scheduled by the ccrrputer as a preplanr.ed task under the direction of a PM Coordinato ..

w gy

.

.

The inspector reviewed the progran descriptior., the impicnenting procedures, the schedule for HPCI and RCIC PM, and selected FM procedures. The following observaticos were made:

(a) The PV Coordinater is respcnsible for all electr ical, rrechanical, ar.d instrument PM. This was considered a strong point by the inspecto (b) There is no scheduled PP cn valve packing inspecticn and Limitorque torque switch settings er n.otor operator running current. This is not consistent with current industry practice (7) Maintenance Performance Review Corrective maintenance is established by Chapter S of the Quality Assurance Manual. It is irrplerented by Procedure Nc. 1408.1 " Corrective Maintenance," Revisien Faintenance activities are preplanned ard initiated by a formal work request. When maintenance activities are complex, a naintenance prccedure is required. Written authorization by the Operations Supervisor must Le received prior to concencing wor The inspector reviewed the prograr descriptior.; the implementing procedure, including the latest draft; selected mainter.ance repair procedures; and PAR No. 69480 which documented recent HFCI maintenance. This review produced the following observations:

(a) MAR No. 69480 required only a visual inspection of the valve sten when the valve had bcen repackc.d seven months previously. Additionally, the stroke time had increased three seconds in each directicn due to an operator change and the valve had previcusly placed the plant in a LC0 ccnditicn due to the san.e packing leak. It appears that direct rieasurerent of the stu. would have been appropriate since the cause of failure was not determined and maintenance on the valve for a third tin.e will defeat any ALARA ccnsiderations which may have existe (b) The instructior.s for adjusting the valve packing in the maintenance instructions for MAR ho. 69480 described an alternative method for adjustment of the packing that was r.ot addressed by either existing repair procedure No. GPM-007, " Valve Repacking," Revision 0, or procedure No. GFM-030, " Anchor / Darling Cate Valve Repair Procedure,"

Revision F

_

"N*W@ . .

(c) Anchor Valve drawing ho.1463-3, Revision C, shows a stainless steel lantern ring in the subject valv No lantern was fcund when the valve was disassenbled on PAR

?!c. 69480. No engineering justification or 10 CFR 50.59 review could be produced docurenting approval for this configuration. Subsequently, it was determined that the lantern ring was renoved in 1975. During this inspection, I an Engineering Work Request No. EWR 86-002 was generated to !

require both an engineering evaluation of the lantern l ring's ren. oval and a 10 CFR 50.59 safety evaluatio The inspector found the results ecceptabl (d) The Cf'AR procedure currently in draf t appeared weak in the area of root cause analysis and determinatio (S) Maintenance Training There is currently no documented training prcgram for mainter.ance persennel; however, apprentice training programs for I&C, electrical, and rrechanical traintenance personnel are currently being develcped and irrplerrente The ir.spector reviewed the proposed " step prograris" fcr maintenance perscnnel, the 1986 Training Course Catalog, and the trainir.g records of selected rcaintenance personnel. In additicn, interviews were conducted with key training and vaintenance personnel. This review prcduced the follcwing observations:

(a) The step programs for apprentice rnaintenance personnel appear to be excellen (b) The more experienced the raintenance personnel, the less the training they have received. Conversely, the newer raintenance personnel have received r. ore docurented riainterance trainin (c) Administrative Training Procedure No. ATP-8.6, " Continuing Training ~ Program fcr ?!aintenance, Radiation Protection, and Non-Licensed Gperators," Pevision 0, deals primarily in plant occurrences and industry related events. It does r,ct provide for continuing training cf journeyraen r echanics in maintenanc (d) There is no training schedule for retraining er continuing training of journeymen mechanic (9) Measuring and Test Equiprent _Reviqw The licensee's l%TE program and activities were reviewed. ACP 1408.8, " Control of Measuring and Test Equipment", Revision 4, ACP 1408.7, "Ccntrol of Permanent Plant Instrumentation, Revision 3, and ACP 1408.6, " Calibration Prccedures", f.evisien 0, were reviewed and fcund to provide an effective program pla N 6C

. -

(IC) Surveillance Testing Review The licensee's surveillance testine program was reviewcd to verify cerrpliance with ccnriitr.:ents and activities directly associated with the HPCI and RCIC systems. Two administratise centrol procedures, three surveillance test procedures for HPCI, ard three surveillance test procedures for RCIC were revio:c All were found to be acceptabl d. Conclusions and ,Reccu.end_at_ ions The inspectors concluded that the lictosce's task force has identified several methcds to improve HPCI and RCIC reliabilit The increase in HPCI reliability is indicative of their effort's effectiveness; however, the overall assessn.ent indicates that additicr,al attention is required in several areas. Accordingly, censideration shculd be given to the following recorrendations:

(1) Place increased errrhasis on the determination of the root causes of events and equiprcent malfur.ctions (Paragraphs 2c(1)(a), (b),

and (c); 2c(2)(b); and 2c(4)(b)).

(2) Increcse nanagerent attentien relative to required engincering reviews. (Paragraphs 2c(3)(a) and (b) and 2c(2)(c)).

(3) Investigate the cbvious trends apparent in the Ceviation Peport Listin (Paragraph 2c(2)(a).

(4) Reduce the excessive use of cause codes unkncwn and

"other". (Paragraphs 2c(1)(c) and 2c(2)(b)).

(5) Give increased attention to nanufacturers/vendccs reconcendetions for reliatiility (Paragraphs 2c(5)(a) and (b)).

(F) Implen.ent the planred maintenance history and trending program as scan as practicable (Paragraph 2C(4)(a)).

(7) Rewrite Procedure No. GPM-007 to reflect current r:aintcnance practices and train the perscnnel in its implenentatio (Paragraph 2c(7)(b)).

(8) Include valve packing inspections ar d linitorque torque switch settings in the PM program (Paragraph 2c(6)(b)).

(9) Establish training cbjectives, a training schedule, and training program for continuing training for journeyman level and suservisory maintenance personnel (Paragraphs 2c(8)(c) a (d)).

(10) Strengthen the corrective maintenance procedurr relative to root cause detern ination and docunentation and train the responsible personnel in its irrplenentatio (Paragraph 2C(7)(d)).

.o ..

(11) Include more QC or peer type inspections on LC0-related maintenance to ensure root cause deterninaticn. (Paragraph 2c(7)(a)).

(12) Investigate the practice of renoving lantern rings from valves so equiped without an engineering evaluation and identify any generic implications. (Paragraph 2c(7)(c)).

3. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

cn January 10, 1986, and sunrr.arized the purpose, scope, and findings of the inspection. The probable contents of the report were discussed with licensee personnel and no proprietary information was identifie