IR 05000331/1996006
| ML17229B554 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 11/14/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17229B552 | List: |
| References | |
| 50-331-96-06, 50-331-96-6, NUDOCS 9611220270 | |
| Download: ML17229B554 (20) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No:
License No:
50-331 DPR-49
~Re orat No.
50-331/96006(DRP)
Licensee:
IES Utilities Inc.
200 First Street S.E.
P. 0.
Box 351 Cedar Rapids, IA 52406-0351
~Faci 1 it:
Duane Arnold Energy Center Dates:
July
September 6,
1996 Ins ectors:
K. Riemer, Senior Resident Inspector C. Lipa, Resident Inspector N. Kurth, Reactor Engineer A. Vegel, Senior Resident Inspector, Fermi Plant K. Selburg, Radiation Protection Specialist T. Tongue, Project Engineer A
roved b
R.
D. Lanksbury, Chief Reactor Projects Branch
96ii220270 9hiii4 PDR ADOCK 0500033i
EXECUTIVE SUNHARY Duane Arnold Energy Center NRC Inspection Report 50-331/96006(DRP)
This inspection report included resident and regional inspectors evaluation of aspects of licensee operations, engineering, maintenance, and plant support.
The inspectors and licensee identified several examples of poor execution of safety system work.
These occurred during routine activities and the examples were noted across multiple departments.
The inspectors also identified several examples of weak licensee control and oversight of contractor performed activities.
The inspectors were concerned about this issue in light of the large number of contractors anticipated to arrive on site for the upcoming refuel outage.
~0erations
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The inspectors noted good operator performance during power change evolutions.
The operators also actively participated in shift briefings and communicated well with other departments during the regularly scheduled formal shift turnovers.
(Section 01.2)
The inspectors identified that a mispositioned valve in the standby diesel generator cooling water system constituted a violation of Technical Specifications and Operating Instruction 324.
(Section 01.3)
The operator's poor communications with the maintenance department during post maintenance testing of the "D" Residual Heat Removal Service Water (RHRSW)
pump contributed to unnecessarily lengthening the amount of time the pump was out of service.
(Section 01.5)
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Operator error during a routine High Pressure Coolant Injection (HPCI)
system surveillance test unnecessarily lengthened the time that the system was technically inoperable.
(Section 01.6)
Maintenance Pre-outage Thermo-lag removal activities resulted in a half scram event.
(Secti on Hl.2)
Weak oversight of contractor activities resulted in incomplete implementation of fire protection impairment program requirements in violation of Technical Specification 6.8. 1 and Administrative Control Procedure 1412.4.
(Section H1.4)
Poor preplanning and inadequate procedures for maintenance activities on the "A" Standby Diesel Generator contributed to inadvertently making the diesel inoperable without operator knowledge.
(Section Hl.6)
The Fix It Now (FIN) team appeared highly effective in accomplishing on line work with minimal "up-front" administration activities or planning.
(Section H1.7)
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Engineering support to resolve plant material condition issues appeared appropriate.
(Section N2. 1)
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Several errors were noted during the implementation of Engineered Naintenance Action process activities.
(Section El. 1)
Plant Su ort
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Anomalies were noted in preliminary thermoluminescent dosimeter results during the inspection period.
(Section R8. 1)
Re ort Details Summar of Plant Status At the beginning of the inspection period the plant was at 100 percent power and remained at or near full power for the remainder of the inspection period.
Exceptions were scheduled downpower evolutions for planned testing activities and control rod sequence exchanges.
I. 0 erations
01.1 Conduct of Operations General Comments 71707 01.2 The inspectors conducted frequent reviews of ongoing plant operations.
In general, the conduct of operations was professional and safety-conscious.
Observations indicated that the control room staffing levels were appropriate and operations staff was knowledgeable of plant conditions, responded promptly and appropriately to alarms, and performed thorough turnovers.
Control Room Observations b.
Observations and Findin s
The inspectors noted good operator control of power change evolutions performed for routine testing activities and rod sequence exchanges.
Operators utilized formal communications for reactor power changes performed to support scram solenoid pilot valve testing and control rod sequence exchanges.
The inspectors also observed the use of appropriate independent operator checks during these same evolutions.
In addition, the inspectors observed the operators perform professional and thorough turnovers.
Operators actively participated in shift briefings by noting discrepant plant conditions and identifying potential conflicts between scheduled work items for their shift.
Operators also generally communicated well with other departments during the regularly scheduled formal shift turnover.
01.3 Diesel Generator Coolin Valve Found His ositioned b.
Observations and Findin s
On July 23, 1996, the inspectors identified that valve V-23-170 (standby diesel generator engine driven air cooling water pump suction drain)
was mispositioned.
The inspectors found the valve in the "open" position; Operating Instruction (OI) 324,
"Standby Diesel Generator System,"
requires the valve to be closed.
The inspectors verified that a second valve downstream of V-32-170 was closed and concurred with the licensee's assessment that the mispositioning did not adversely impact standby diesel generator operabilit The licensee documented the occurrence via action request (AR) 96-1498 and performed an OI 324 valve line-up check of both standby diesel generator rooms.
No other valves were found mispositioned during the checks.
The valve is not used by the chemists for sampling and the licensee's review of the computerized tagout system determined that the valve had not been tagged since the valve line-up was performed during the last refuel outage.
The licensee was unable to positively determine the cause of the mispositioning but reasoned that the valve was most likely bumped during routine oil cleanup of the standby diesel generators by the plant helper crew.
The licensee initiated an addendum to the original AR to brief the plant helpers of the incident.
The failure of valve V-32-170 to be in its required position constitutes a no response violation of Technical Specification 6.8. 1. which requires that written procedures covering areas such as normal startup, operation, and shutdown of systems and components of the facility be implemented (50-331/96-006-01 (DRP)).
0 erators Identif His ositionin of V33-0582 Observations and Findin s
On August 14, 1996, the licensee initiated AR 96-1545 to document the mispositioning of valve V33-0582 (Reference Section Hl.2 for additional details).
The operator's identification of the mispositioned valve demonstrated proper attention to detail during the performance of routine tasks.
Inade uate Communications Durin
"D" RHRSW Work Observations and Findin s
On August 20, 1996, following maintenance on the
"D" RHRSW pump (Reference Section Hl.5), operators started the
"D" RHRSW pump for post maintenance operability testing.
Haintenance personnel had repacked the pump earlier in the day and requested notification from the operations department prior to running the pump in order to have personnel available to monitor the pump and adjust the packing if necessary.
Operators initially started the pump without maintenance personnel present.
Subsequently, mechanics reported insufficient leak-off from the pump and requested that it be shut down for packing adjustment.
The pump was restarted later; after further observations and packing adjustments, mechanics were not satisfied with the packing leak-off.
Inspections revealed that the first ring of packing was damaged requiring retagging the pump and reworking the pump packing.
Subsequent to the pump packing being replaced and adjusted, the pump was successfully tested and declared operable.
The packing damage was caused by the pump start and run with the packing leak'-off not properly adjusted.
The inspectors were concerned because miscommunication between the operations and maintenance departments unnecessarily lengthened the time for the
"D" RHRSW outag Incorrect Strokin of Valve N02239 HPCI Outboard Steam Isolation Valve Observations and Findin s
On August 27, 1996, while performing the HPCI System quarterly operability test (STP 45D001-g) the licensee identified that control room operators stroked valve N02239 in a manner different than covered in the pre-test briefing.
The HPCI system quarterly operability test satisfied a number of technical specification (TS) requirements, one of which was to perform a quarterly stroke time test of N02239.
However, during the current operating cycle, N02239 developed a packing leak.
The licensee added the repair of N02239 to both the refuel outage scope and forced shutdown schedule.
To stop the packing leak until the valve could be permanently repaired, the licensee installed a temporary modification (TN 96-19) to electrically backseat the valve.
Part of TN 96-19's scope included a stroke test to verify that N02239 still met the applicable stroke time specification after being electrically backseated.
Subsequently, N02239 was placed on its own quarterly testing schedule (separate from STP 45D001-9) to ensure that TS requirements were still being met.
The licensee initiated temporary DCF 96-T-0170 to allow the option of not stroke testing N02239 during the routine quarterly performance of STP 45D001-0.
Following the routine, scheduled HPCI maintenance outage on August 27, 1996, operators intended to perform STP 45D001-g to verify HPCI system operability.
The control room staff briefed performance of the STP without performing the applicable steps to test N02239, as allowed for by temporary DCF 96-T-0170.
Operations management was also present for the brief.
However the operator performing the test proceeded with the steps that stroked N02239.
After stroking N02239 operators aborted the test and realigned the system to its normal status.
Plant staff decided to then wait and reperform the operability test at the beginning of the next day shift.
The test was successfully completed the next day and the HPCI system returned to an operable status.
While the inadvertent stroking of N02239 had no adverse safety consequences, the inspectors were concerned that the operator displayed inattention to detail during the performance of safety-related work.
The inspectors were also concerned that a human performance deficiency unnecessarily lengthened the time that the HPCI system was technically inoperable.
Conclusions on Conduct of 0 erations Observations and Findin s
The inspectors determined that the operators performed well during power change evolutions and during the conduct of most routine daily activities.
However, the inspectors were concerned that human errors and inadequate communications adversely affected safety system work causing safety equipment to be out of service longer than required.
While the actual consequences were minor, they were similar in nature to those observed in other department.1 0 erational Status of Facilities and E ui ment En ineered Safet Feature S stem Walkdowns 71707 The inspectors used Inspection Procedure 71707 and applicable UFSAR sections to walk down accessible portions of the following ESF systems:
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Standby filter units
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High Pressure Coolant Injection
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Core Spray System
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Reactor Core Isolation Cooling
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Standby Diesel Generators
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River Water Supply System
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Division I and II Batteries
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Residual Heat Removal Service Water System Equipment operability, material condition, and housekeeping were acceptable in all cases.
Several minor discrepancies such as missing nuts on drain line supports, a loose nut on a support rack, and a loose electrical conduit connection were brought to the licensee's attention and were corrected.
The inspectors identified no substantive concerns as a result of these walkdowns.
07.1 guality Assurance in Operations Licensee Self-Assessment Activities During the inspection period, the inspectors reviewed multiple licensee self-assessment activities, including:
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Routine Operations Committee meetings
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Routine Action Request screening meetings
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Fact Finding meetings The inspectors observed active management participation at the meetings.
Identified deficiencies were being tracked by the licensee's AR process.
The inspectors were concerned however, with an emerging negative trend in human performance events that occurred during the inspection period.
These events were both licensee and NRC identified and occurred during the performance of routine, fundamental tasks.
II. Maintenance Conduct of Maintenance Ml.l General Comments a
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Ins ection Sco e
62703 61726 The inspectors observed or reviewed portions of the following work activities:
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Standby gas treatment (SBGT) system relays and flow switches
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Dynamic VOTES testing on M02009, RHR minimum flow valve
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Control room positive pressure test
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River water pump underwater vibration probe installation
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Standby diesel generator (SBDG) maintenance and surveillance test
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"8" well water pump discharge valve modification
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HPCI system maintenance
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"D" RHRSW pump repack
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Temporary scaffold installation Standby Diesel Generator speed switch maintenance Observations and Findin s
The inspectors noted good execution of on-line LCO maintenance for the SBGT system and RHR system.
The inspectors also noted effective engineering support for the SBGT and RHR system maintenance.
The inspectors did note some problems with licensee oversight of contractor performed activities.
The inspectors also had concerns with the execution of selected safety system work.
His ositionin of Fire Protection S stem Nitro en Valve Observations and Findin s
On August 14, 1996, while performing STP NS13C004-A (Deluge System Annual Test and Inspection),
operators discovered valve V33-582 (Deluge 17-6 (Fans X and Y) Heat Actuation Device Inboard Nitrogen Isolation) in the incorrect position.
The operators discovered the valve in the closed position when the valve is required to be open.
The operators were performing the surveillance to verify system operability following maintenance performed by contractor personnel.
While there were no adverse consequences as a result of the valve's incorrect position, the inspectors were concerned that this item, similar to several other examples discussed in this report section, represented problems encountered as a result of contractor personnel performing work at the site.
Scaffold Installation Concerns Observations and Findin s
During the course of the inspection period, the inspectors identified multiple concerns with the erection of temporary scaffolding in the plant spaces.
The licensee utilized contractor personnel to install scaffolding to support outage and pre-outage work activities.
Examples of items noted included:
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Scaffolding in contact with service air system filter
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Scaffolding in contact with sound powered phone lines and a
cable raceway
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Scaffolding in contact with electrical conduit
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Minor ventilation ductwork damage, apparently as a result of personnel stepping on the ductwork to gain access to a scaffold platform
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Scaffolding installed in close proximity to sensitive instrument racks
The inspectors were especially concerned with the installation of the scaffold erected near sensitive instrument racks located in the north end of the first floor reactor building.
The scaffolding was erected to support Thermo-lag removal and replacement material installation.
On August 21, the inspectors walked down the area with licensee personnel and discussed their concer'ns with the possibility of items being dropped onto sensitive instruments.
On August 30, a section of Thermo-lag material inadvertently dropped from the work area and the shock to the instrumentation caused a scram discharge volume high level half scram.
Subsequent to receiving the half scram, the licensee installed additional protective sheeting around the work area and reduced the scope of work to be performed prior to the refuel outage.
While the examples noted, with the above exception, did not result in significant adverse consequences, the inspectors were concerned with the potential for future adverse effects, especially in light of the anticipated additional scaffold installation and corresponding work activities associated with the upcoming refuel outage.
Incom lete Im lementation of Fire Protection Im airment Re uest Observations and Findin s
On August 9, 1996, the inspectors identified that fire door 111 was blocked open without a fire protection impairment request (FPIR)
initiated and posted on the door.
The door was blocked open to support contractor activities in the turbine building basement.
The fire marshall authorized the fire door permit but, as allowed by administrative control procedure (ACP) 1412.4 (Impairments to Fire Protection Systems),
a FPIR was not initiated because workers were to remain in the area while the door was blocked open.
The workers went on break and neglected to close the door.
ACP 1412.4 requires that fire doors that will be blocked open will require a Fire Door Impairment Permit be placed on the fire door.
The licensee subsequently documented the occurrence via AR 96-1179, contacted the supervisor and discussed procedural requirements with the workers, and initiated a FPIR to allow the door to be blocked open while unattended.
While the consequences were minor, the inspectors were concerned that this event demonstrated another example of weak licensee oversight of contractor activities.
This failure constitutes a no response violation of Technical Specification 6.8. 1 which requires that written procedures covering areas such as the Fire Protection Program be implemented (50-331/96-006-02 (DRP)).
RHRSW "D" Pum Re ack Observations and Findin s
On August 20, the inspectors observed maintenance personnel repack the
"D" RHRSW pump.
The work was performed well and the inspectors had no concerns with the maintenance activity.
However, as discussed in Section 01.5, post maintenance testing activities were poorly coordinated and implemented.
Due to miscommunication.between maintenance and operations personnel, the initial packing was damaged
and the pump had to be removed from service again and repacked.
The inspectors were concerned because poor performance of post maintenance testing activities unnecessarily lengthened the time that the pump was unavailable.
Standb Diesel Generator Ino erabilit As a Result of Naintenance Activities Ins ection Sco e
62703 93702 On September 3,
1996, the "A" Emergency Diesel Generator (EDG) was inadvertently made inoperable during a corrective maintenance activity.
The inspectors reviewed the event and associated circumstances for safety significance, prompt verification of the status, and short term corrective actions.
Observations and Findin s
The inspectors review of the event found that the "A" EDG was removed from a fully operable status without the knowledge or authorization of the operations personnel on shift.
This occurred during maintenance when an I and C technician was attempting to calibrate the speed sensor for the engine tachometer and also resulted in an unplanned removal of the speed switch.
The speed switch performs the function of giving an automatic closure signal to the EDG output breaker during automatic/accident signals thus, removal makes the EDG inoperable.
When the I and C technician encountered some problems with the calibration, she promptly informed appropriate individuals including the system engineer.
The system engineer immediately recognized that the EDG was technically inoperable and informed the control room operators.
Operations personnel promptly declared the EDG inoperable, entered the LCO, and verified the operability of the other EDG and necessary ECCS equipment.
Within 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />, the "A" EDG was properly reassembled, tested and returned to standby status.
Initial information indicated that the technician was working within the authorized procedures and this may have resulted from one or more of the following; inadequate procedures, a failure in the planning process to recognize the situation with this unusual work request and/or having engineering involved after-the-fact.
The licensee promptly took appropriate short term corrective actions to restore the EDG back to service and commenced several actions to investigate and identify long term corrective actions.
These included review of the applicable procedures; I.SS-S519-001
"Synchro-Start Products Speed Switch.
G-2 Calibration" and I.SE-E158-001
"Electro-Mechanico Speed Element/Indicator Calibration."
It also included evaluation of associated training, review of prejob briefs for similar issues, review of the PHAR data base for plant affect, and conducting an HPES evaluation.
A root cause investigation was initiated that was due within 30 days.
Since this occurred late in the inspection period, additional information is forthcoming on the issue that was not available at the end of the inspection.
A final resolution will be determined during a
future inspection and this issue is an unresolved inspection item (50-331/96006-03(DRP)).
c.
Conclusion The occurrence resulted in an unplanned entry into a Technical Specification LCO.
The cause may have been related to vague procedures, lack of instructions/communications, lack of recognition by planning or operations, and/or late involvement by engineering.
Prompt corrective actions were appropriate and at the close of the inspection an investigation was in progress for long term corrective actions.
Due to the lateness in the inspection period, this matter is unresolved.
H1.7 Fix-It-Now FIN Team Activities a.
Ins ection Sco e
62703 The purpose of this inspection was to monitor the activities of the FIN team.
This consisted of a review of how the FIN team functions overall within the maintenance work process, its interface with other organizational groups, and a comparison of the team activities to the guideline procedure.
b.
Observations and Findin s
The FIN team was officially made part of the licensee organization in Harch 1996 following a trial period.
Its activities are addressed in administrative procedure ACP 1408.1
"Haintenance Action Requests" Revision 25, effective Harch 22, 1996.
The team has representatives from all maintenance disciplines including mechanical, electrical, and instrument and control technicians.
Based on licensee data the FIN team completed 75 percent of all maintenance work requests generated during the month of July 1996.
However, the inspector noted that the team makes up only 15 to 20 percent of the maintenance work force.
Additional data was not available on the ratio of man-hours expended.
The inspector monitored work in progress, planning meetings on a daily basis, interviewed team members, and reviewed the controlling ACP procedure.
The FIN team uses a computer data base for followup tracking and trending of work requests and has significantly reduced the work request administrative load up front.
There are provisions for assessing the team capabilities, conversion of work requests to AR's, PHAR's or CHAR's, and consideration for gC involvement as necessary.
The actual work is performed as with any request.
The inspector found the FIN team concept at Duane Arnold to be excellent.
The team was effective with acceptable results, and functioned well within the maintenance department as well as within the plant organization.
The team members qualifications were found to be a
strength and a key to the success of the team.
However, this also appears to be a point of vulnerability in that a person of lesser qualities could result in a failure of the team.
This was acknowledged by plant management.
Conclusions The inspector found that the FIN team was highly effective in accomplishing on line work with minimal "up-front",administration activities or planning.
The members credentials were a strength and a
key to the teams effectiveness.
It was also a point of vulnerability where a weak performer could jeopardize the teams effectiveness.
Conclusions on Conduct of Maintenance The inspectors noted that most maintenance activities during the period were completed thoroughly and professionally.
However the inspectors noted several weaknesses with licensee oversight and control of contractors.
The safety consequences of the noted items were minor, however the inspectors were concerned with the potential for future problems in light of the large number of contractor personnel anticipated to support the upcoming refuel outage.
The inspectors were also concerned with several examples noted where the execution of planned safety system work was adversely impacted by human performance errors, a theme observed across departments during the inspection period.
Maintenance and Materiel Condition of Facilities and Equipment Plant Material Condition Observations and Findin s
Plant materiel condition was acceptable.
The inspectors noted that a
number of materiel condition issues arose during the inspection period that required the response of plant personnel.
While each individual occurrence was of minor consequence, collectively the issues represented distractions for operators and other plant staff.
In each case, the issue was entered into the plant's maintenance process or corrective action process and corrected, as appropriate.
The inspectors considered the licensee's response to these materiel condition issues to be appropriate.
The examples are listed below:
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HPCI steam supply drain pot drain line pipe support with two (of four) missing nuts
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Flow switch failure causing a failure of the "A" chiller to start
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Upscale spiking of "A" APRM
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Reactor Recirculation Pump "B" scoop tube lockup
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Main generator relay faceplate film deposit During the inspection period, the inspectors also reviewed the licensee's proposed resolution of longer term material condition issues.
The inspectors reviewed the licensee's Operator Work Around, Temporary
Hodification, Long Term Tagout, and Degraded Instrument lists.
The inspectors verified that the items had associated work requests and/or engineering packages assigned to them and most items were included in the upcoming refuel outage scope.
The licensee appeared to have reasonable justification for those items not scheduled for the upcoming refueling outage.
Some of the temporary modifications were for monitoring equipment that the licensee intended to keep installed to track equipment performance; others required a longer lead time for parts procurement or engineering paperwork.
The inspectors had no substantive concerns with the licensee's proposed dates for these items.
The inspectors concluded that, pending successful implementation of the proposed corrective actions during the refuel outage, the licensee's approach to resolving plant equipment deficiencies appears reasonable and appropriate.
Conclusions The inspectors noted prompt operator identification, appropriate maintenance attention, and thorough engineering support of the identified materiel condition issues.
Hiscellaneous Naintenance Issues (92902)
Closed Violation 50-331 94013-04a b
and c:
Three examples of Failure to Follow Procedures Due to Personnel Error.
The inspectors verified the implementation and adequacy of corrective actions described in IR 50-331/94013 (Sections S.b and 6.b)
and the licensee's reply letter, dated September 12, 1994.
Corrective actions were considered appropriate to prevent recurrence.
This item is closed.
Closed Ins ection Fol 1 owu Item IFI 50-331 96004-12:
Discrepancy Between UFSAR and Procedures Regarding Standby Liquid Control (SLC)
Boron Concentration Limit.
The inspectors verified that STP-44C001,
"SLC System Boron Concentration Test," which was revised on July 17, 1996, contained acceptance criteria for the upper boron concentration limit described in the UFSAR.
This item is closed.
Conduct of Engineering Ins ection Sco e
37551 III. En ineerin Selected engineering problems or events were evaluated to determine their root cause(s).
The effectiveness of the licensee's controls for the identification, resolution, and prevention of problems was also examined.
The inspection included review of areas such as corrective action systems, root cause analysis, safety committees, and self assessment.
El. 1 En ineered Maintenance Action EHA Process Errors a.
Ins ection Sco e
73051 The inspectors reviewed the circumstances surrounding two licensee identified EHA problems.
The inspectors reviewed AR 96-1522, which documented an incorrect torque switch setting on a motor operated valve, and AR 96-1115, which documented an EHA error associated with the average power range monitor (APRH) power supply.
b.
Observations and Findin s
On.July 31, 1996, the licensee completed work on HO-2010 (RHR cross tie valve) to replace the spring pack and change the torque switch setting of the valve.
The torque switch setting specified by the EHA differed from the setting specified by the maintenance procedure.
The licensee's formal engineering evaluation of the event concluded that there was no operability concern with the valve.
AR 96-1522 was then re-assigned to the guality Assurance department to perform an HPES evaluation of the event.
On August 12, 1996, the licensee initiated AR 96-1115 to document an implementation error associated with the EMA to replace the capacitors on the APRH power supply.
In this case the work was performed correctly but the PHAR data base was not updated prior to closing out the maintenance action request HAR.
c.
Conclusions In a prior inspection report (IR 50-331/96002)
the NRC documented concerns associated with weaknesses in the licensee's EHA process.
NRC inspection report 50-331/96-002 contained a violation (NOV 50-331/96002-07) documenting the licensee's failure to adequately correct weaknesses in the EHA process.
The two items discussed above are similar in nature to the example documented in IR 50-331/96-002 and indicate additional licensee attention is necessary in order to fully correct problems in the EMA process.
Pending NRC formal review and closure of NOV 50-331/96-002-07 to assess the effectiveness of the licensee's corrective actions, (and to determine whether these items potentially represent EMA program deficiencies or personnel error on the part of the involved individuals), this item is an unresolved item (URI 96-006-6).
E1.2 S ent Fuel Pool Rack Criticalit Anal sis b.
Observations and Findin s
During the licensee's review of documentation to support the improved standard Technical Specification submittal, licensee personnel identified a potential conflict with the storage of fuel in the spent fuel pool.
The assumptions (UFSAR Section 9. 1.2.3. 1.3) for the criticality analysis for the spent fuel storage racks indicated that storage of fuel with an initial enrichment of 3. 1 percent was acceptable.
However, fuel currently exists and is stored at the site which has an initial enrichment of 3.27 percent.
An initial preliminary
E2 assessment of the spent fuel pool storage racks performed by the storage rack vendor indicated that the critical fuel parameter is actually the K-infinity (criticality) value, not initial fuel enrichment.
Additionally, Section 9. 1.2. 1.3 of the UFSAR refers to the criticality value of the fuel (k-effective) in the safety design basis for the spent fuel pool racks.
Also, the design criteria in Section 9. 1.2.3. 1. 1 referenced the k-effective value.
The licensee expected to obtain the vendor's formal detailed analysis supporting this conclusion after the conclusion of the inspection period.
The licensee documented the above information via AR 96-1587.
Pending inspector review of the final vendor analysis and associated licensee closure of AR 96-1587, this is an inspection followup item (IFI 96006-04(DRP)).
Engineering Support of Facilities and Equipment Observation and Findin s
E8 E8.1 The inspectors reviewed plant equipment and activities against the UFSAR descriptions (reference Sections 02. 1, M8.2, and E1.2.b).
No discrepancies were noted during plant equipment walkdowns.
Minor discrepancies were noted concerning the description of spent fuel storage in the spent fuel pool.
These discrepancies will be tracked during the closure of the associated IFI.
Miscellaneous Engineering Issues (92902)
Closed Licensee Event Re ort LER 50-331 94-010 Revision 0:
Manual Scram Due to Loss of Electro-Hydraulic Control (EHC) Oil.
As discussed in IR 50-331/94013, the licensee determined the cause of the leak to be a crack in the EHC actuator supply line to a turbine control valve.
The crack was apparently due to hydraulic pressure pulses in the piping, and a General Electric recommended accumulator kit was installed.
No further EHC oil leaks in this piping have been identified.
Corrective actions were considered to be appropriate.
This item is closed.
IV. Plant Su ort R8 Miscellaneous Radiological Protection and Chemistry (RPSC)
Issues R8.1 Anomalies in Preliminar Thermoluminescent Dosimeter Results Anomalies in preliminary thermoluminescent dosimeter (TLD) results were noted in the second quarter of 1996.
The licensee identified several discrepancies in TLD results through a dose comparison between TLDs and self reading dosimeters (SRDs) including:
total worker dose recorded by TLDs read approximately 50X higher, as opposed to the anticipated lON lower, than SRDs; twice as many workers as compared to the last two quarters received between 10 and 20 millirem (mrem);
and approximately 30/o of TLDs which were not issued were returned with exposures of 10 mrem as opposed to the typical reading of 0 mrem.
The inspectors determined that none of the doses recorded by either SRDs or TLDs exceeded any regulatory dose limits.
(
Z
Upon further evaluation, the licensee determined that the vendor laboratory did not use the licensee's control TLDs in processing the second quarter dosimeters.
The vendor, at the licensee's request, reprocessed the TLD data using the control information and submitted a
revised report to the licensee.
The licensee's review found that the new data was still slightly higher than anticipated, and was evaluating potential reasons for the discrepancy.
This issue is an inspection followup item and will remain open pending inspector review of the licensee's evaluation during a routine inspection (IFI No. 50-331/96006-05(DRP)).
V. Kana ement Neetin s
Xl Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 6,
1996.
The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
PARTIAL LIST OF PERSONS CONTACTED Licensee J.
Franz, Vice President Nuclear G.
Van Hiddlesworth, Plant Hanager R. Anderson, Hanager, Outage and Support P. Bessette, Hanager, Engineering J. Bjorseth, Haintenance Superintendent D. Curtland, Hanager, Operations R. Hite, Hanager, Radiation Protection D. Jantosik, Acting Hanager, Corporate guality Assurance K. Peveler, Hanager, Licensing and Emergency Planning INSPECTION PROCEDURES USED IP 37551:
IP 40500:
IP 61726:
IP 62703:
IP 62707:
IP 71707:
IP 71750:
IP 92700:
IP 92901:
IP 92902:
IP 92903:
IP 93702:
~0ened Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observation Haintenance Observation Haintenance Observation Plant Operations
, Plant Support Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities Followup Operations Followup - Engineering Followup - Haintenance Prompt Onsite Response to Events at Operating Power Reactors ITEHS OPENED, CLOSED, AND DISCUSSED 50-331/96006-01 NOV Diesel Generator Cooling Valve Found Hispositioned 50-331/96006-02 NOV 50-331/96006-03 URI 50-331/96006-04 IFI 50-331/96006-05 IFI 50-331/96-006-06 URI Closed 50-331/94-010, Rev.
50-331/94013-04a,b,c 50-331/96004-12 Discussed 50-331/96002-07 Incomplete Implementation of Fire Protection Impairment Request Standby Diesel Generator Inoperability As a Result of Haintenance Activities Spent Fuel Pool Rack Criticality Analysis Anomalies in preliminary thermoluminescent dosimeter results were noted in the second quarter of 1996.
EHA Implementation Errors LER Hanual Scram Due to Loss of EHC Oil.
NOV Three Examples of Failure to Follow Procedures IFI UFSAR Discrepancy on SLC Concentration VIO Failure to adequately correct weaknesses in the EHA process
LIST OF ACRONYMS USED APRM AR CFR CMAR DAEC DCP EHC EMA EOC FIN GL HPCI HPES IandC IFI IP IR LCO LER MD NOV NRR OI OSS PMAR QA RHR Average power range monitor Action Request Code of Federal Regulations Corrective Maintenance Action Request Duane Arnold Energy Center Design change package Electro-hydraulic control Engineered maintenance action End of cycle Fi x-It-Now Generic Letter High pressure coolant injection Human performance evaluation system Instrument and controls Inspection followup item Inspection Procedure Inspection report Limiting Condition for Operation Licensee Event Report Maintenance Directive Notice of Violation Office of Nuclear Reactor Regulation Operating Instruction Operations Shift Supervisor Preventative maintenance action request Quality Assurance Residual heat removal RHRSW Residual heat removal service water RPKC RPS RPT RRMG SBDG SBGT SFP SFPC SLC SRD STP TI TLD TS Radiological Protection and Chemistry Reactor protection system Recirculation pump trip Reactor recirculation motor generator Standby diesel generator Standby gas treatment Spent fuel pool Spent fuel pool cooling Standby liquid control Self Reading Dosimeter Surveillance Test Procedure Temporary Instruction Thermoluminescent Dosimeter Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved Item 18