IR 05000331/1996013

Insp Rept 50-331/96-13 on 961220-970203.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20137A364
Person / Time
Site:	Duane Arnold
Issue date:	03/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137A354	List: IR 05000331/1996013 ML20137A349 ML20137A358
References
50-331-96-13, NUDOCS 9703200298
Download: ML20137A364 (15)

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U. S. NUCLEAR REGULATORY COMMISSION I I

REGION lil l l

l Docket No: 50-331 License No: DPR-49 l

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Report N /96013 l

Licensee: lES Utilities In I 200 First Street I P. O. Box 351 i

Cedar Rapids, IA 52406-0351 I l

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Facility: Duane Arnold Energy Center I

Dates: December 20,1996 - February 3,1997 1

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1 Inspectors: K. Riemer, Senior Resident inspec'or )

C. Lipa, Resident inspector i

Approved by: Michael J. Jordan, Chief Reactor Projects Branch 5

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EXECUTIVE SUMMARY

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Duane Arnold Energy Center NRC Inspection Report No. 50-331/96013

{ This inspection report included resident inspectors' evaluation of aspects of licensee j operations, engineering, maintenance, and plant suppor .

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The inspectors and identified several examples of inattention to detail in multiple j departments, as discussed below.

i j Ooerations

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e The inspectors observed well controlled plant shutdown, downpower, and startup J

evolutions. (Sections 01.2 and 01.3)

) e The inspectors closed an unresolved item abnic operators' use of an uncontrolled document during daily surveillances. This was an example of inattention to detail and was an example of a violation. (Section M8.1)

Maintenance e The inspectors identified several concerns while observing annual standby gas treatment system charcoal filer testing. This was an unresolved ite (Section M1.2)

e The inspectors identified the use of an uncontrolled document during a chemistry surveillance. This was an example of a violation. (Section M1.3)

e Materiel condition continued to be a challenge- (Section M2.1)

Enaineerina e The inspectors identified that the main steam line radiation monitors were not set according to Technical Specifications. This was a violation. '(Section E1.1)

Plant Sunnort e The inspectors identified an incorrect equation in the SBGT efficiency test that was not identified by the technician who used the Surveillence test procedure. This was an example of inattention to detail. (Section M1.2)

• The inspectors identified the use of an uncontrolled document (which contained an error) during the completion of a daily surveillance. (Section M1.3)

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i Report Details

] Summarv of Plant Status

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The plant began this inspection period at 100 percent power. The "A" reactor recirculation pump MG set tripped on December 25,1996. The plant responded as

expected and stabilized at 65 percent power. The source of the "A" recirculation MG set

] trip was a broken slip ring connector. Repairs were completed and the "A" recirculation

pump was returned to service on December 29. The plant returned to 100 percent power

, on December 29,1996. On January 10,1997, the licensee initiated a controlled i shutdown to investigate the cause of increasing unidentified drywell leakage. Unidentified j leakage was at 0.98 gpm, well below TS limit of 5 gpm. On January 19, the plant was i

returned to 100 percent power. On February 1, power was reduced to 15 percent to j allow repair of a body to bonnet leak on the "B" feedwater pump discharge check valve.

j The plant power level was approximately 67 percent at the end of the inspection period.

! L.Onerations 01 Conduct of Operations

01.1 General Comments (71707) l The inspectors conducted frequent reviews of plant operations. This included observing routine control room activities, accompanying in-plant operators on daily rounds, attending shift turnovers and crew briefings, and performing panel walkdowns. The conduct of operations was professional. Noteworthy observations are detailed in the sections belo .2 Plant Shutdown to Renair Cause of Unidentified Drvwell Leakaae insoection Scone On January 10,1997, plant management decided to bring the plant to a shutdown condition to investigate the source of increasing unidentified leakage in the drywel The inspectors observed portions of the plant shutdown, plant startup, and other evolution Observations and Findinas As discussed in Inspection Report 50-331/96011, the licensee had been following a  ;

slowly increasing trend in unidentified drywell leakage. The licensee suspected l

packing leakage on reactor recirculation discharge valve MO4627. On January 10,  ;

1997, the licensee backseated MO4627; however, the leakage rate did not I decrease. Management deci&d to commence a controlled reactor shutdown to investigate the cause of the unidentified leakag i

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i The licensee identified the cause to be a body to bonnet leak on V19-97, a 3/4 inch manual valve in the RHR system. Although the repair could be made with the plant

in a hot shutdown condition, plant management decided to bring the plant to cold

] shutdown to make other repairs. These additional repairs were prioritized on the forced outage list. Some of these repairs included testing of RHR check valve'

i V20-82 and replacement of a one inch elbow on the main steam isolation valve

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leakage treatment system.

I s Conclusions

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The inspectors (,oncluded that plar t management conservatively decided to bring l the plant to a cald shutdown condition to repair valve V19-197 and perform other

repairs as part of the forced outage plan. The inspectors concluded that the work activities during the shutdown were well coordinated. The plant shutdown and startup were both well controlle ;

j 01.3 Reactor Downnower for Feedwater Discharae Check Valve Renair Insoection Scone

i On January 31,1997, operators commenced a planned power reduction from 100 l percent power to 50 percent power to support repairs of the "B" feedwater pump discharge check valve. The inspectors obsented portions of the evolution briefings, valve repairs, and return to powe )

l i Observations and Findinas

On January 24,1997, licensee personnel identified a body to-bonnet leak on the

"B" feedwater pump discharge check valve. To support repairs of the valve, plant operators reduced reactor power from 100 to 50 percent power to isolate and depressurize the maintenance boundaries required for the work. The licensee was

! unable to isolate the area at 50 percent power. The licensee had contingency plans

to place the unit in hot shutdown should this occur and operators proceeded to shut down the reactor. However, at approximately 15 percent power, the licensee was i

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able to effectively isolate the maintenance area and mechanics then performed the

required valve repairs. The licensee successfully completed the valve repairs and, at the end of the inspection period, commenced activities to return the unit to full

powe The inspectors observed pre-evolution briefings for the task and observed portions of the maintenance activities on the valve. The inspectors concluded that station management provided strong support for establishing the appropriate conditions for the maintenance work and that operators correctly proceeded to shut the plant down when the required conditions could not be established. The inspectors also observed effective communications between the operations and maintenance departments during the valve repair. Operators returned the unit to full power in a deliberate and conservative manne '

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! Conclusions The inspectors concluded that the repair activity, and associated plant

] manipulations were well controlled. The inspectors also concluded that these

activities were performed in a conservative manner. The inspectors noted excellent l coordination between the operations and maintenance departments.

9 02 Operational Status of Facilities and Equipment

02.1 Ennineered Safety Feature (ESF) System Walkdowns (71707) Insoection Scone The inspectors used Inspection Procedure 71707 to walk down accessible portions i of the following ESF systems:

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} e standby diesel generators l e residual heat removal (RHR)

e emergency service water l e RHR service water j e high pressure coolant injection (HPCI) Observations and Findinas

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The inspectors performed routine plant inspections during the period to assess

licensee housekeeping and materiel condition. The inspectors concluded that, with

{ one exception, overall plant housekeeping was good. On January 21,1997, the i inspectors toured the RHR valve room and noted tools and debris from a thermolag

removal activity lying around the job site and on top of MO2OO4 ("A" low pressure l

! coolant injection (LPCI) outboard injection valve). The inspectors were concerned with the possibility of tools or debris impacting the declutch lever and potentially affecting the operation of the valve. An operator on rounds had identified the condition of the room as a concern earlier in the day but the situation was not corrected until after the inspectors discussed their concerns with operations shift managemen Conclusions Equipment operability and material condition were acceptable. Minor discrepancies were brought to the licensee's attention and were corrected. Regarding the housekeeping issue noted above, the inspectors concluded that the condition of the room was a departure from the standards maintained in the rest of the plant. The licensee re-established the condition of the room to the level of cleanliness that existed before the maintenance work was started. The inspectors concluded that this was an isolated departure from the plant standards normally maintaine . - . . . - . -- - - - - - . - . . . _ - . - . - -- --

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07 Quality Assurance in Operations

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07.1 Licensee SeyfAssessment Activities i

l During the inspection period, the inspectors reviewed several licensee self-

assessment activities, including

l e Action Request (AR) Screening meetings i e Operations Committee meeting i

The invectors concluded that the self assessment activities observed were effective. There was active management participation and deficiencies were being tracked by the licensee's AR process, ll. Maintenance M1 Conduct of Maintenance M1.1 General Comments Insoection Scone (62703) (61726)

The inspectors observed or reviewed all or portions of the following work activities:

e thermolag removal e standby liquid control quarterly surveillance e standby gas treatment (SBGT) charcoal filter test e feedwater check valve leak repair e main steam line radiation monitor repair e drywell leak repairs e RRMG set brush repairs e high pressure coolant injection system room cooler repair o radiation monitor sensor check Conclusions As discussed below, the inspectors were concerned with a lack of attention to detail during SBGT system testing and with the use of an uncontrolled document during the performance of surveillance testin M1.2 Standbv Gas Treatment Charcoaf Filter Testing Insoection Scone On January 9 and 10,1997, the inspectors observed portions of annual Surveillance Test Procedure (STP) 47 LOO 3, " Standby Gas Treatment System HEPA and Charcoal Filter Efficiency Tests." The inspectors reviewed the TS

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i q requirements, TS bases, and surveillance procedure. The inspectors also )

4 independently calculated the results of the test. Several concerns were identifie !

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, b. Observations and Findinas l

) e On January 8,1997, the licensee identified that as-found test results for the l

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"A" SBGT train were unacceptable. The TS 3.7.L.2.a requires the inplace i test to show A99.9 percent halogenated hydrocarbon removal. Actual results were 99.39 percent efficiency. The licensee determined that the

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cause of the test failure was bypass flow. This was due to a combination of

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charcoal settling over time and the practice of periodically removing charcoal for laboratory analysis without replacing the amount removed.

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! The licensee documented the condition on AR 970010970010and added I approximately 16 pounds of charcoal to the bed from which a sample had

, been removed. Subsequent inplace testing also failed. This time, the j licensee added a total of approximately 80 pounds of charcoal to the other i five beds in the train. On January 9,1997, the "A" train tested ,

j satisfactorily at 99.99 percent efficienc o On January 10,1997, the licensee tested the "B" SBGT train and i

determined the as-found efficiency to be acceptable at 99.9 percent. The I

! inspectors independently calculated the results to be 99.89 percent and l 1 questioned the licensee on the appropriateness of rounding the value up to j meet the TS requirement. The inspectors planned to consult the Office of

Nuclear Reactor Regulation (NRR) to determine the acceptability of the 99.89 percent efficiency result. This was considered part of an unresolved item (URI) on SBGT system testing issues discussed below.

Following the initial test of the "B" SBGT train, the licensee added approximately 80 pounds to the charcoal beds and ratestod the train. The I

final result was 99.93 percent efficiency, well above the TS requirement.

i e The inspectors identified an error in the equation used to calculate the l charcoal efficiency in STP 47 LOO 3. The chemistry technician performed the calculation correctly, based on the standard method for calculating efficiency; howsver the error was not identified. The inspectors were concerned that this was an example of inattention to detail, which was similar to other examples discussed in this inspection report. This will be reviewed as part of an URI on SBGT system testing issue The licensee subsequently documented the error on AR 970116970116and revised the procedur e The inspectors identified two discrepancies between the test method described in the TS bases and the actual test method used at the plan Page 3.7-39 of TS bases specifies that charcoal testing shall be performed according to United States Atomic Energy Commission (USAEC) Report

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DP-1082. Initially, the licensee did not have this document; however, they

, stated that the system was tested to a current industry standard. By the

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end of the inspection period, the licensee obtained the USAEC report and

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initiated AR 970270970270to review the need to update TS bases. The TS bases

also discusses the use of a grain thief to obtain the charcoal samples for

. offsite laboratory testing. The inspectors asked the licensee's contractor how the samples were obtained and were informed that a grain thief was

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not used.

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' Conclusions i

I The inspectors had several concerns with the SBGT testing. Further review by the i

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inspectors was necessary to reach an enforcement decision. The unresolved item I (50-331/96013-01) will address the list of SBGT system testing issues discussed

! above. These issues include a determination of the applicability of the TS bases for the method of obtaining charcoal samples, the usage of " rounding" of calculations to determine operability, and the validity of the equation contained in STP 47 LOO M1.3 Uncontrolled Document Used Durina Chemistry Surveillance l Insoection Scoce

On December 30,1996, the inspectors observed portions of Surveillance Test

. Procedure STP 42D011, " Radiation Monitor Sensor Check." The technician used

an informal reference sheet during the completion of the surveillance. The

inspectors identified that the reference sheet listed an incorrect value for the Offgas l Vent Pipe Hi-Hi Radiation Alarm Setpoint.

, Observations and Findinas

After the inspectors brought this issue to plant management's attention, AR l 970290 was written and the reference sheet was removed from the test package.

i Chemistry technicians were instructed to stop using the uncontrolled document,

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and instructions were given on how to perform the applicable steps of the STP i

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without it. There was no operability concern because the incorrect value for the setpoint was in the conservative directio Conclusions The inspectors were concerned with the use of an uncontrolled document for surveillance testing. The failure to incorporate acceptance criteria in STP 42D011 was an example of a violation of 10 CFR Part 50 Appendix B Criterion X (50-331/96013-02a).

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t M2.1 Plant Material Condition i insnaction Scone

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1. l The inspectors noted that several material condition issues and self-revealing I j equipment failures existed during the report period. As discussed below, two of I

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these, the drywell leakage increase and feedwater pump check valve leak resulted

in management decisions to schedule a plant shutdown and plant down power to perform repairs. Additionally, the trip of the "A" reactor recirculation motor 3 generator (RRMG) resulted in an unplanned plant down power. The inspectors i reviewed the issues to determine if there was any affect on equipment operability

or plant safety, in each case, the inspectors observed appropriate licensee

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response to repair or schedule maintenance and to determine root cause. The

examples are listed below:

e On December 25,1996, the "A" RRMG tripped, as documented on

AR 96-2912. The cause was determined to be a broken connector to the

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slip ring. During the plant shutdown on January 10,1997, the licensee

inspected the condition of the connectors on the "B" RRMG. These

connectors were satisfactory.

{ * On December 27,1996, during the performance of STP 47B009-Q j containment atmosphere dilution (CAD) valve SV4334B did not open. The j

, licensas documented the occurrence on AR 96-2915 and deenergized closed 1

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SV4334A to ensure containment isolation requirements were met. Repair l i was planned for April 1997. The inspectors verified that the CAD system I

met TS requirements in this configuratio * On December 29, operators declared HPCI room cooler 1V-AC-14A inoperable due to a bad bearing. The inspectors verified that TS requirements were met due to the other room cooler (1V-AC-14B) being operable. Repairs were stillin progress at the end of the inspectio l l

• On January 10,1997, a plant shutdown was commenced to repair RHR l system valve V19-197, which had developed a body to bonnet leak. See Section 01.2 for detail I

• During the plant shutdown on January 10,1997, there were problems with

"B" IRM, "D" SRM, and "C" APRM. All were repaired or replace * On January 12,1997, the "C" MSt.RM failed due to defective resistor. The monitor was repaired and reinstalled on January 14; however, on January 21, the instrument had drifted low out of tolerance. Instrument technicians adjusted the monitor back in tolerance and documented the occurrence on AR 97-0040. On January 31, the system engineer had noticed that the monitor was drifting low again and was continuing to monitor the indicatio A work request card was initiated to perform repair _ _ . _ . . _ _ _ _ . . . . _ __ _ _ _ _ . . . . . _ . _ _ . _._ _._ __._._ _._._ _ .

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i j e On January 19,1997, the "B" RRMG scoop tube locked up. This was a

repeat occurrence of this problem. The cause was not determined although

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system engineers were performing troubleshooting and working with the

manufacturer.

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e On January 21,1997, the inspectors identified that the "B" standby filter j unit (SFU) flow controller was reading downscale instead of upscale as

expected with the system in standby readiness line up. The licensee

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subsequently started the "B" SFU and determined that the flow controller

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was not functioning properly, rendering the "B" SFU inope'able. The l licensee entered a 7-day LCO per TS 3.10.A.3.a. The cause was determined to be a failed diode. The diode was replaced and the system was tested

, satisfactorily. The LCO was exited later that day. This was documented in

AR 97-0034. The inspectors determined that technical specifications were

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i e On January 24,1997, the licensee identified a body to bonnet leak on V07-OOO5 ("B" feedwater pump discharge check valve). On January 31, 1997, the licensee commenced a down power evolution to isolate and repair j the valve. See Section 01.3 for details.

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Conclusions l

j Continuing a theme documented in the prior inspection report (50-331/96011), the

inspectors were concerned about the materiel condition problems discussed above.

l The licensee performed a plant shutdown and two downpower evolutions to repair '

emergent equipment problems. The inspectors concluded, however, that the l i licensee's response to each of the individual items above was appropriat )

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M8 Miscellaneous Maintenance issues (92902)

M8,1 (Closed) Unresolved item 50-331/96011-04: Incorrect Acceptance Criteria Used for Completion of Daily Surveillances. As discussed in inspection Report 96011, the licensee identified one example where acceptance criteria was incorrect due to the use of an uncontrolled reference document with incorrect data. The licensee's corrective actions focused only on the particular example. During this inspection period, the inspectors identified an additional example where an uncontrolled document with incorrect data was used in a surveillance as discussed in Section M1.3. This item was closed to a violation. (50-331/96013-2b)

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Ill Engineering

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j E1 Conduct of Enginsedng Insoection Scone (73051)

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! The inspectors evaluated engineering involvement in resolution of emergent material

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condition problems and otner routine activities. The inspectors reviewed areas such

as operability evaluations, root cause analyses, safety committees, and self i assessments. The effectiveness of the licensee's controls for the identification, l resolution, and prevention of problems was also examined.

! E Main Steam Line Radiation Monitor 3 Times Normal Setooint i Insoection Scone l The inspectors walked down control room panels and identified that normal

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background radiation indicated on the panels was much lower than the previous

! cycle. This was due to lower hydrogen injection rates established by the noble

metals chemical addition project. The inspectors compared the main steam line radiation monitor (MSLRM) indications and setpoints to the TS requirements.

J i Qhagrvations and Findinas i

On December 17,1996, the inspectors identified that the MSLRM setpoint was much higher than 3x Normal required by TS. The 3x Normal trip function isolates Group i valves, except the MSIVs. During Cycle 14, the licensee operated the j hydrogen water chemistry (HWC) system at an injection rate of 15 standard cubic feet per minute (scfm), resulting in radiation levels of 600 mR/hr at the steam lines.

Since startup from refueling outage 14 (November 1996), the injection rate was

typically 6 scfm or less, resulting in radiation levels of apptcximately 150 - 200 l mR/hr. Although the hydrogen injection rate was reduced, the MSLRM 3x Normal j setpoint remained at 1800 mR/hr until questioned by the inspectors.

! On December 18,1996, the licensee documented the concern on AR 962392962392and j increased the hydrogen injection rate to 15 scfm to bring the MSLRM indication and

setpoints in compliance with TS. On December 20,1996, the licensee changed the MSLRM setpoint to 400 mR/hr and lowered hydrogen injection to 6 scfm.

i Through interviews, the inspectors determined that the licensee recognized that the I MSLRM setpoints would need to be adjusted as part of the project; however, the licensee did not recognize that prompt adjustment was necessary to ensure TS

compliance. Instead, the licensee relied on their knowledge of the basis for the TS

} and concluded that little safety significance was associated with the greater than i 3x normal interim setpoin !

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i Conclusions l The inspectors also concluded that low safety significance was associated with this

! issue; however, the licensee demonstrated poor planning for ensuring compliance i with TS during this project. Duane Arnold Technical Specification 3.2.A,

) Table 3.2-A requires the Main Steam Line Radiation trip level setting to be s.3x

! Normal Rated Power Background. The failure to meet this requirement was a j Violation (50-331/96013-03).

! E1.2 Pressure Lockina of RHR Shutdown Coolina Manual isolation Valve i

i Insoection Scone t On January 15,1997, the inspectors interviewed operators and mechanics in the l plant who were having difficulty clearing the tagout in place to support valve

V19-197 replacement as discussed in Section 01.2. Specifically, operators and mechanics could not open 18-inch RHR shutdown cooling manualisolation valve

V19-148, which appeared to be pressure locked. The inspectors reviewed the

licensee's corrective action Observations and Findinas The licensee vented the bonnet area and the valve opened smoothly. The licensee initiated AR 97-0091 to document the issue and perform an operability evaluation on the valve body and bonnet that were subjected to higher than normal pressure Conclusions The inspectors planned to review the licensee's operability evaluation. This is an inspection follow-up item (50-331/96013-05).

IV Plant Suncort R1 Radiological Protection and Chemistry Controls insoection Scone (71750)

The inspectors observed radiological postings and evaluated radiological work practices while observing maintenance and test activities. Two concerns were identified in this are Observations and Findinas As discussed in Section M1.2, the inspectors identifier an incorrect equation in the SBGT efficiency test that was not identified by the technician who used the ST As discussed in Section M1.3, the inspectors identified the use of an uncontrolled document (which contained an error) during the completion of a daily surveillanc .. . _ _ _ - _ _ _ . ..

! Conclusions I

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As discussed in other sections of this report, the inspectors were concerned with

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inattention to detail by the technician performing the efficiency calculation and with the use of uncontrolled documents during surveillance tests.

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V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to membe 's of licensee management at the conclusion of the inspection on February 3,1997. The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the inspection a

should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee a

J. Franz, Vice President Nuclear G. Van Middlesworth, Plant Manager R. Anderson, Manager, Outage and Support  ;

P. Bessette, Manager, Engineering J. Bjorseth, Maintenance Superintendent D. Curtland, Operations Manager R. Hite, Manager, Radiation Protection K. Peveler, Manager, Regulatory Performance INSPECTION PROCEDURES USED 3

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IP 37551: Engineering IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and j Preventing Problems IP 61726: Surveillance Observation IP 62703: Maintenance Observation IP 62707: Maintenance Observation , ,

IP 71707: Plant Operations  !

IP 71750: Plant Support IP 92901: Followup - Operations IP 92902: Followup - Engineering IP 92903: Followup - Maintenance l

ITEMS OPENED, CLOSED, AND DISCUSSED j i

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50-331/96013-01 URI Standby Gas Treatment System Testing issues i 50-331/96013-02 NOV Uncontrolled Documents Used During Surveillances 50-331/96013-03 NOV Main Steam Line Radiation Monitors Not Set Per TS j 50-331/96013-04 IFl Pressure Locking of RHR Shutdown Cooling Manual Valve

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Closed j i

50-331/96011-04 Incorrect Acceptance Criteria Used in Daily Surveillance j J

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LIST OF ACRONYMS USED CFR Code of Federal Regulations DAEC Duane Arnold Energy Center DDC Design Document Change EMA Engineered maintenance action HEPA High Efficiency Particulate Air HPCI High Pressure Coolant injection HWC Hydrogen Water Chemistry

. IFl inspection followup item IR Inspection report LCO Limiting Condition for Operation LER Licensee Event Report LPCI Low Pressuro Coolant injection MSIVs Main Steam isolation Valves MSLRM Main Steam line Radiation Monitor NOV Notice of Violation NRR Office of Nuclear Reactor Regulation 01 Operating Instruction RHR Residual heat removal RRMG Reactor recirculation motor generator SBGT Standby Gas Treatment scfm standard cubic feet per minute

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SFU Standby Filter Unit SLC Standby liquid control STP Surveillance Test Procedure TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item USAEC United States Atomic Energy Commission

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