IR 05000331/1986017

Insp Rept 50-331/86-17 on 860916-1117.No Noncompliance Noted.Major Areas Inspected:Operational Safety,Maint,Lers, Surveillance,Ie Bulletin & Info Notice,Spds,Tmi Item & Seismic Instrumentation.Concern Noted Re SPDS

ML20214K914
Person / Time
Site:	Duane Arnold
Issue date:	11/21/1986
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214K870	List: IR 05000331/1986017 ML20214K868
References
TASK-2.E.4.2, TASK-TM 50-331-86-17, IEB-86-001, IEB-86-1, IEIN-86-072, IEIN-86-72, NUDOCS 8612020508
Download: ML20214K914 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-331/86017(DRP)

Docket No. 50-331 License No. DPR-49 Licensee: Iowa Electric Light and Power Company IE Towers, P. O. Box 351 Cedar Rapids, IA 52406 Facility Name: Duane Arnold Energy Center Inspection At: Palo, IA Inspection Conducted: September 16, 1986 through November 17, 1986 Inspector: J. S. Wiebe N. V. Gilles Approved: lNf

. k.i , Chief Reactor P4ojects Section 20

//-N-[I Date Inspection Summary Inspection on September 16 - November 17, 1986 (Re) ort No. 50-331/86017(DRP))

Areas Inspected: Routine, unannounced inspection )y the resident inspectors of licensee action on previous inspection findings, operational safety, maintenance, surveillance, Licensee Event Reports, Bulletins, Information Notices, Recirculation Pump Motor-Generator Field Breaker, Safety Parameter Display System and Seismic Instrumentation, and TMI item Results: One item was noted in the area of operational safety for which a notice of violation was not issued. Continuing concern was noted by the inspector in the area of identifying and correcting problems with the Safety l Parameter Display Syste _

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DETAILS Persons Contacted R. Anderson, Assistant Operations Supervisor H. Giorgio, Radiation Protection Supervisor

• L. Gosnell, Instrument Tech. Foreman

• M. Grim, Site Licensing Engineer

• R. Hannen, Assistant Plant Superintendent, Operations

• B. Hopkins, Plant Performance Engineer

• K. Howard, Plant Performance Supervisor M. Huting, Assistant Quality Assurance Superviso L. Jenkins, Quality Assurance Engineer

• C. Kardos, Computer Services

• E. Kelenyi, Plant Performance Engineer

• B. Lacy, Maintenance Superintendent (Acting)

J. Loehrlein, Supervising Engineer, Design Engineering C. Mick, Operations Supervisor

• W. Miller, Technical Services D. Mineck, Plant Superintendent, Nuclea J. Probst, Technical Support Engineer R. Salmon, Technical Services Superintendent

• P. Serra, Radiation Protection Supervisor

• J. Smith, Technical Support Supervisor

• A. Steen, Operations Shift Supervisor S. Swails, Acting Group Leader, Nuclear Licensing

• C. Sutton, Computer Services

• J. West, Senior Quality Assurance Engineer K. Young, Assistant Plant Superintendent, Radiation Protection / Security In addition, the inspector interviewed several other licensee personnel including Operations Shift Supervisors, Control Room Operators, engineering personnel, and contractor personnel (representing the licensee).

• Denotes those present at the exit interview . LicenseeActiononPreviousInspection_gi[qin (Closed) Open Item (331/85032-01(DLPH- ;ncomplete Equipment Histor The inspector verified that the Corrective Maintenance Action Request (CMAR) history data was placed in the Computerized History and Maintenance Planning System (CHAMPS). This item is considered close , (0 pen) Violation (331/85032-02(DRP)) and Open Item (331/85032-04(DRP)): Lack of Maintenance Trending. After reviewing trending programs at different utilities, the licensee has deciced to develope a trending program consisting of two aspect _

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First, the maintenance planners review the Equipment History when planning the CMAR to determine: 1) whether the preventive maintenance program is satisfactory or should be revised as to the frequency and type of preventive maintenance, and 2) whether materials, parts or components are functioning reliably. This review is required by Administrative Proce<iure 1408.1, " Corrective Maintenance", Revision 10, paragraph 5.3.8. The inspector is concerned, however, that this requirement may not produce the desired results since: 1) the requirement is not located in the

" Instructions" section of the procedure where an individual would look for the instructions to process a CMAR, 2) there is no place

- to document the review and there is no item or check on the CMAR form to remind personnel of this requirement, and 3) there are no instructions for processing a determination that either the preventive maintenance program is unsatisfactory or the material, parts, or components are unreliabl Second, a procedure is being developed to require periodic reviews of systems or components. This procedure should be issued by November 30, 198 This item remains open pending licensee resolution of the inspector concerns for the first aspect and issuance of the procedure for the second aspect of the trending program. This will be reviewed during a future inspectio (Closed) Open Item (331/85032-03(DRP)): Include Construction Control Form Information in Equipment Database. The Construction Control Fonn (CCF) is used only to control work associated with design changes. As a result, no repair work is conducted with this document and no failure information is associated with it. The only information associated with it is the installation and removal of equipment. Since the Design Change Package includes the information concerning equipment installation and removal and the Design Change Package is referenced by the Equipment Database, the inspector has concluded that inclusion of the CCF information in the Equipment Database would be redundant. This item is considered closed.

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/ (0 pen) Open Item (331/85034-01)DRP)): Quality of Surveillance Test Procedures. The inspector has noted that the quality of procedures appears to be improving. The inspector notes, however, that an inadequate preventive maintenance procedure caused wetting of both trains of the Standby Filter Unit which resulted in a shutdown as required by the Technical Specifications. This item remains open pending further NRC review to verify the improving trend and to evaluate if the preventive maintenance procedure problem is an isolated case. This will be reviewed during a future inspectio (Closed) Open Item (331/85016-01(EPS)): Unsatisfactory Utilization of the Post Accident Sampling System. The inspector observed a satisfactory sample ac Sampling System (PASS)quisition and analysisdrill during an unannounced using the Post shortly afterAccident

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the 1985 exercise. The inspector also observed two additional unannounced drills in which the utilization of the PASS was

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satisfactory. This item is considered close . Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the

. . inspection period. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the reactor building and

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turbine building were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector, by observation and direct

interview, verified that the physical security plan was being implemented

in accordance with the station security plan except as discussed belo On November 5, 1986, at 6:05 P.M., the inspector noted that the guard stationed to monitor the fence on the south side of the Access Facility and the north side of the Low Level Radioactive Waste Storage Facility was filling out crossword puzzles. The inspector was concerned that this activity distracted the guard from performing his assigned duty. The inspector informed the Security Supervisor who confiscated the magazine, reinstructed the guard, and checked the other guard stations to see if similar problems existed. No other distracting material was discovere This item remains open pending NRC specialist review of the circumstances of this event and the corrective action taken (331/86017-01(DRP)).

The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the inspection, the inspector walked down the accessible portions of the Residual Heat Removal System and the Direct Current Power System to

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verify operability.

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While monitoring the preparations for shipment of used Local Power Range Monitors (LPRMs), the inspector noted that although these monitors

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contain small quantities of uranium enriched in U-235, they were not being inventoried during the annual inventory of Special Nuclear Material. This appears to conflict with 10 CFR 70.51(d) which states that each licensee who is authorized to possess more than 350 grams of

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contained U-235, U-233, or plutonium, or any combination thereof, shall conduct a physical inventory of all special nuclear material in his possession under license at intervals not to exceed twelve months. Since the licensee is clearly authorized to possess more than 350 grams of the specified material, it would appear that all special nuclear material must be inventoried annually.

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In accordance with 10 CFR 74.15(a) a Nuclear Material Transaction Report (D0E/NRC Form 741) does not need to be completed and distributed if the licensee transfers or receives special nuclear material containing less than 1 gram of contained U-235, U-233 or plutonium. This however does

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not remove the requirement to inventory and keep track of the material once it is received. This issue is unresolved pending licensee completion of an inventory of the LPRMs and subsequent NRC specialist review (331/86017-02(DRP)).

The Duane Arnold Energy Center Technical Specifications paragraph 6. requires, in part, that procedures for normal startup of the facility be implemente Integrated Plant Operating Instruction No. 4, " Shutdown",

Revision 2, dated August 9, 1985, (a procedure for normal shutdown of the facility) Section 3.0 requires, in part, insertion of control rods in accordance with the Control Rod Withdrawal Sequence. Contrary to the above on October 15, 1986, Integrated Plant Operating Instruction No. 4 was not fully implemented when a group of peripheral control rods were inserted contrary to the sequence specified by the Control Rod Withdrawal Sequence documen This event developed as follows. During a reactor shutdown on October 15, 1986, a second licensed operator was stationed in accordance with Technical Specification paragraph 3.3.B.3.c because the Rod Worth Minimizer was out of service. The operator at the console and the second licensed operator were using the same Control Rod Withdrawal Sequence document to carry out their respective duties. As the operator turned the page after completing the rod movements on that page, two pages stuck together. Neither the operator at the console nor the second licensed operator noted that two pages had been turned. A peripheral rod group was inserted out of sequence from notch 48 to notch 42 when the operator noted the misseJ page. Upon being informed of the rod insertion error, the Shift Supervisor directed that a P-1 computer printout be run to verify that the thermal parameters were within the proper limits. No thermal limit problems were noted on the P-1 and the nuclear engineer concurred with returning the mispositioned rods to their proper positio The shutdown continued in accordance with the Rod Control Sequenc Following this event, the licensee required that the second licensed operator have a duplicate Rod Centrol Sequence to verify and initia This will prevent the common mode failure which allowed the insertion error. The licensee also returned the Rod Worth Minimizer to service prior to reactor restart. The licensee hac recognized the unreliability of the Rod Worth Minimizer and had previously initiated a design change to install a new process computer and Rod Worth Minimizer. The switchover to the new process computer and Rod Worth Minimizer will be performed online following the 1987 refueling outag In accordance with 10 CFR Part 2, Appendix C, Section V.A., a notice of violation will not be issued for this violation (331/86017-03(DRP))

because it meets all of the following tests : It was identified by the licensee. (The operator involved noted the problem. Although this violation is self disclosing, it would not have been discovered until the operator attempted to move the next group that moved the mispositioned rods.)

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. . It fits in Severity Level IV or (This violation would be a Severity Level IV). It was reported; if required. (This event was not required-to be reported. However, the subject was brought up in the daily morning meeting which the inspector attends and the inspector was subsequently independently informed by plant management.) It was or will be corrected, including measures to prevent recurrence, within a reasonable tim (The violation was immediately corrected by restoring the rod pattern. To prevent recurrence, the licensee instituted a practice of providing a duplicate Rod Control Sequence to the second licensed operato This was completed prior to the plant restart. A surveillance procedure requiring implementation of this practice was issued on October 17,1986.) It was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. (No such violation could be identified.)

One item nas identified for which a notice of violation was not issue One unrr y,1ved item of minor significance and one inspector concern (open itea) of minor significance were identifie . Monthly Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review: the limiting conditions for operations were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified;

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radiological controls were implemented; and, fire prevention controls were impicmente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety relateo equipment maintenance which may affect system perfcrmance.

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High Pressure Coolant Injection Suction Valve from Torus Intermediate Range Monitor F

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t High Pressure Coolant Injection Steam Supply Isolation Valve

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Recirculation Pump Motor Bearing High Pressure Coolant Injection Recirc Valve to Condensate Storage Tank Following completion of maintenance on the High Pressure Coolant-Injection System, the 250 Volt Battery, and the Intermediate Range Monitor, the inspector verified that these. systems had been returned

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to service properl No problems or concerns were identifie . Monthly Surveillance Observation

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The inspector observed technical specifications required surveillance testing on the Rod Sequence Control System, the Rod Worth Minimizer, the Residual Heat Removal System, the 250 Volt Battery, the High Pressure Coolant Injection System, the Reactor Core Isolation Cooling System, and the Post Accident Sample System and verified that testing was performed in accordance with adequate procedures, that test instrumentation was

calibrated, that limiting conditions for operation were met, that removal

and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure

, requirements and were reviewed by personnel _other than the individual

! directing the test, and that any deficiencies identified during the i testing were properly reviewed and resolved by appropriate management personne >

No problems or concerns were identifie . Licensee Event Reports Followup

. Through direct observations, discussions with' licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective

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• (Closed) Licensee Event Report (LER) 85006(331/85006-LL):

Inadvertent Diesel Generator and Standby Filter Unit Initiation.

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The inspector verified that Operating Instruction No. 304.2,

, "4160V/480V Essential Electrical Distribution System", Revision 0, '

I dated July 28, 1986, requires placing the affected diesel generator

control switch in the PULL-TO-LOCK position prior to deenergizing s the electrical bus. The inspector also verified that Operating i Instruction No. 317.1, "120 VAC Instrument Control System", Revision 0, dated July 10, 1986, has a caution statement to review what

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systems / controls will be affected by deenergizing the instrument bus and has a list of affected loads for each bus. This LER is i

considered closed.

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) (Closed) Licensee Event Report (LER)' 85036 (331/85036-LL):

. Emergency Diesel Generators Sequencing Design Anomaly. As t

scheduled in the November 4, 1985 Integrated Plan Semiannual

Update, the modification to correct-the design anonaly was completed prior to March 31, 1986. By letter from R. W. McGaughy,

Manager, Nuclear Division to H. Denton, Director, Office of

Nuclear Reactor Regulation, dated May 9, 1986, the-licensee-l submitted a description of the modification to the NRC. By J letter from Mohan C. Thadani, Project Director, to Mr. Lee Liu, Chairman of the Board and Chief Executive Officer, dated-September 11, 1986, the NRC concluded that the' described modifications assure that the loading of the Emergency Core Cooling System pump motors on the emergency diesel generators

will be sequenced in accordance with the plant design basis.

This LER is considered close ,

j (0 pen) Licensee Event Report (LER) 86019(331/86019-LL): Station 250 Volt Battery Cell Degradation As a Result of Suspected Galvanic 4- Reaction. On September 22, 1986, the 250 volt battery was declared '

inoperable which rendered the High Pressure Cooling Injection (HPCI)

! system inoperable. The battery, however, was left in service and i therefore HPCI, if needed, was available to supply water to the l reactor' vessel. The concern for the operability of the battery i developed because of degradation of some positive plates which was

observed during a licensee inspection. The degradation was in the form of material being eaten away in the junction area where the

positive plates connect to the internal bus bar, and in the supporting hooks which suspend the plates from insulation at the

- opposite end. The two 125 y batteries and the two 24 volt batteries did not show similar degradation, j With the plant shutdown, the licensee tested the 250 volt battery to determine if the degradation had affected its electrical j~

characteristics. The test showed that the battery in its present condition would supply the design emergency power, however, the licensee could not show that the degraded cells would withstand a seismic event.

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To provide short term action, the licensee bypassed all of the 16 cells that showed degradation and obtained 16 replacement cell The replacement cells were C and D Power Systems type LC-17 which

are lead-calcium cells. These cells were installed on the floor and held in place by a fire retardant treated wood frame. The inspector provided Region III specialists with the licensee's 10 CFR 50.59

! safety evaluation which included a seismic analysis of this configuration and no problems were identified. The licensee and the j manufacturer determined that the differences in the float voltages

and charging currents used by the new lead-calcium and old i lead-antimony cells would not affect cell capacity or cell life i expectancy for short term applications. The licensee agreed to inform the NRC if it was necessary to operate in this configuration beyond the 1987 refueling outage. During the outage the licensee i

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plans to replace the 250 volt battery, both 125 volt batteries, and both 24 volt batteries. All these batteries are approaching the end of their 20 year life times and battery replacement plans had been in place prior to this even In the short term, until the batteries are replaced, the licensee is performing a positive plate degradation visual inspection weekly for the 250 volt battery. This inspection is performed biweekly for the 125 volt and 24 volt batteries. If a plate is noted to be degraded, the cell will be inspected daily. At the close of this inspection no further degradation had been identified in the operating cell This LER is considered open for continuing review of the battery condition until the licensee replaces the batterie . IE Bulletin Followup For the IE Bulletin listed below the inspector verified that the Bulletin was received by licensee management and reviewed for its applicability to the facilit If the Bulletin was applicable the inspector verified that the written response was within the time period stated in the Bulletin, that the written response included the information required to be reported, that the written response included adequate corrective action commitments based on information presented in the Bulletin and the licensee's response, that the licensee management forwarded copies of the written response to the appropriate onsite management representatives, that information discussed in the licensee's written response was accurate, and the corrective action taken by the licensee was as described in the written respons (Closed) Bulletin 86-01(331/86001-BB): Minimum Flow Logic Problems That Could Disable Residual Heat Removal Pumps. This logic problem does not exist at the Duane Arnold Energy Center. This bulletin is considered close No problems or concerns were identifie . Information Notice Followup The inspector reviewed the following IE Information Notice (IN) to verify licensee review for applicability and proper distribution to the appropriate personne IE Information Notice 86-72: Failure of 17-7 PH Stainless Steel Springs in Valcor Valves Due to Hydrogen Embrittlement. In response to IE Information Notice 86-72, the licensee has reviewed plant records to determine the extent to which 17-7 PH stainless steel springs are used in valves installed in the plant. The licensee has determined that there are no valves manufactured by Valcor Engineering Corp. installed in environments which could be susceptible to hydrogen embrittlemen Therefore, the subject concern of IE Information Notice 86-72 does not apply to the Duane Arnold Energy Cente No problems or concerns were identified.

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i Recirculation Pump Motor-Generator Set Field Breaker In accordance with a request from Region III, the inspector verified that-the Field Breaker for the Motor-Generator set is .not a model AKF-25 with two trip coils. The inspector also verified that the Field Breaker is

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tested during refueling outages to ensure that it will trip.

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No problems or concerns were identifie . Safety Parameter Display System (SPDS)

During drywell inerting/deinerting operations, the inspector.noted

,' that the SPDS did not respond properly to a change of span on the Drywell/ Torus Hydrogen-0xygen analyzers. Normally the span is set at t

0-10%.- The span is changed to 0-25% when deinerted. Since the SPDS does not recognize when the span is 0-25% an actual reading of 10%

oxygen or hydrogen would read out as 4% on the SPDS. This is

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potentially misleading to the operators.

When questioned, the operations department was aware of the problem

, and had informally identified it to another group. The inspector had previously been concerned that maintenance on the SPDS was not being

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conducted in a timely manner (see Inspection Report 331/86012). The present case appears to be similar in that the problem was not formally identified via-the administrative system and therefore could not be tracked, evaluated, and prioritized. The inspector continues to be concerned that there is no formal system in use for identifying,

, tracking, evaluating, and prioritizing hardware and software problems with the SPDS.

The inspector is aware that the licensee is procuring a new computer system including the SPDS, the process computer, and the Rod Worth i

Minimizer. A formal system for identifying, tracking, evaluating, and

, prioritizing hardware and software problems will be invaluable for troubleshooting, evaluating, and maintaining the new computer system.

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The licensee has determined that when problems are noted with the SPDS, the Maintenance Action Request (MAR) form will be used to formally

. identify the problem. The MAR would be closed when the problem is resolved or is being tracked by another system. This item is open pending licensee resolution and subsequent NRC review of the effectiveness of this system in identifying and correcting SPDS

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problems (331/86017-04(DRP)).

One concern (open item) of moderate significance was identifie . Seismic Instrumentation In response to a request from IE Headquarters, the inspector reviewed

the Seismic Monitoring Instrumentation, associated Surveillance and

Preventive Maintenance Program, and failure data. The results of the l review are as follows

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. . .:.- Updated Final Safety Analysis Report (UFSAR) Description The inspector could find no reference to these instruments in the '

UFSA Applicable Technical Specifications The inspector could find no reference to these instruments in the Technical Specification Non-Technical Specification Surveillance Performed The inspector could find no surveillance pertaining to these instrument Preventive Maintenance Performed The inspector could find no preventive maintenance pertaining to these instrument Failure Data The inspector could find no failure data related to these instrument The inspector notes that there is also no documentation that indicates these instruments are operable. This item is considered unresolved pending further NRC review (331/86017-05(DRP)).

One unresolved item was identifie . TMI Action Items (Closed) TMI Action Item (II.E.2.4.7) Containment Isolation Dependability - Radiation Signal on Purge Valves. The inspector verified that the modification to the Containment Purge System met licensee commitments and NRC requirements, equipment changes were properly approved and controlled, proper changes were made to procedures and as-built drawings, personnel training was accomplished, pre-operational testing was completed, and equipment was operabl This item is considered close . Exit Interview

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The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection i on November 14, 1986, and summarized the scope and findings of the l

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inspection activities. The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector. The licensee did not identify any such documents or processes as proprietary.

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