IR 05000331/1997016
| ML20202E938 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 12/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20202E909 | List: |
| References | |
| 50-331-97-16, NUDOCS 9712080186 | |
| Download: ML20202E938 (19) | |
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i U. S. NUCLEAR REGULATORY COMMISSION I
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REGION til
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t Docket No.:
50 331 i
License No.:
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Report No.:
50-331/97016(DRP)
i Licensee:
lES Utilities Inc.
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200 First Street S.E.
F. O. Box 351 i
Cedar Rapids, IA 52406 03s:
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Facility:
Duane Arnold Energy Center l
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Location:
Palo, Iowa Dates:
September 28 November 10,1997 Inspectors:
C. Lipa, Senior Resident inspector M. Kurth, Resident inspector
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Approved by:
R, D. Lanksbury, Chief Reactor Projects Branch 5
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i EXECUTIVE SUMMARY Duane Arnold Energy Center
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NRC Inspection Report No. 50 331/97016(DRP)
This inspection report covers the resident inspectors' evaluation of aspects of licensee
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operations, engineering, maintenance, and plant support.
Operation 1 The condu t of operations was professional; shift tumovers and briefings were thorough, e
communications were effective, and tagouts were property prepared.
(Sections 01.1 and O2.2)
Safety-rclated systems and components were properiy maintained and materiel condition e
was good. However, scaffolding materials were not properly controlled in two cases.
(Section O2.1)
Active involvement by plant management in the review of Action Requests and root e
cause reports resulted in effective self assessment. (Section 07.1)
Ceveral open items regarding the spent fuel pool licensing basis were reviewed.
e Corrective actions were completed and no additional concems were noted. (Section 08)
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Maintenanct During a routine monthly standby diesel generator surveillance test, the inspectors
identified that an auxiliary operator failed to complete a step as required. This was a non-cited violation, (Section M1.2)
Emergent equipment issues were, in general, promptly resolved. However, in one case, e
the licensee's response to degraded oilin the residual heat removal service water pump motor was weak. (Section M2.1)
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The inspectors identified that on numerous occasions over a 6 month period that the
refuel floor material accountability log (MAL) was not balanced as required. Also, the refuel floor supervisor failed to ensure that the MAL was periodically balanced as required. This was a violation. (Section M2.2)
Enoineering
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in general, the engineering department's involvement in and support of plant activities e
such as emergent equipment issues and surveillance testing was good. Engineering personnel promptly evaluated a potential 10 CFR Part 21 issue involving piping welds on the Fairbanks Morse diesel engines. Ultrasonic test results indicated that the issue was not a problem at Duane Amold. (Sections E1 and E1.1)
The inspectors identified a concem with the procedure usage requirements for the high o
pressure coolant injection keep-fill modification. (Section E2.1)
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PJant SuppoA The inspectors observed good radiation protection support for the reactor core isolation
cooling simulated auto actuation test and for the high press.ure coolant injection system quarterly operability test. (Section R1.1)
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Beport Details i
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Summary of Plant Status
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The plant began this inspection period at 100 percent power. On November 1 and 2,1997, there l
was a routine down power for turbine valve testing, main steam isolation valve testing, and a
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control rod seqt.ence exchangc. The plant was operated near full power for the remainder of the inspection period.
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01 Conduct of Operations 01.1 pitneral Comments (71707)
The inspectors conducted frequent reviews of plant operations. This included observing routine control room activities, attending shift tumovers and crew briefings, and performing panel walkdowns. The conduct of operatinns was professional. Shift turnovers and briefings were thorough. The inspectors also noted good three way communications and appropriate response 'o alarms, m
Operational Status of Facilities and Equipment i
O2.1 General Plant Torrs and Walkdowns (71707)
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The inspectors followed the guidance of Inspection Procedure 71707 in walking down accessible portions of several systems. The inspectors checked system line-ups, lubrication levels, and equipment condition. The following systems were inspected:
River water supply system e
Residual heat removal service water system (RHRSW)
e Emergency service water system o
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Standby diesel generators (SBDG)
o H gh pressure coolant injection (HPCI)
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b.
Observations and Findinat
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Equipment operability, materiel condition, and housekoeping were acceptable. Several minor discrepancies were brought to the licensee's attention and were corrected.
On November 5,1997, the inspectors performed a walkdown of the HPCI system prior to -
the scheduled HPCI surveillance tast STP 45D001-0,'HPCI System Quarterly Operability Test." Several scaffolding platforms constructed in the HPCI toom to support maintenance and inspection activities were left ireplace during the surveillance test. The inspectors identified a scaffolding knuckle resting on the HPCI pump in close proximity to the HPCI pump shaft prior to the performance of the test. The inspectors were
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concemed that during the HPCI test, the knuckle could have vibrated off the HPCI pump
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and fallen onto the rotating pump shaft, possibly causing injury to personnelin the HPCI room during the HPCI test or damage to the HPCI system.
The licensee immediately removed the scaffolding knuckle and contacted the scaffolding personnel to perform a scaffolding walkdown to ensure it was property constructed. The scaffolding personnel verified and ensured that the scaffolding was sound and would not collapse during the HPCI test. The licensee also initiated Action Request (AR) 972560.
The inspectors also identified two scaffolding boards which were improperly stored in a storage room in the radiologically controlled area. The boards were stored above the rack where a sign read," Storage of Materials Not Pemiitted Above Rack.* The purpose for storing materials below the top of the rack was to maximize the effectiveness of the fire suppression system in the room. The inspectors discussed their concem with the scaffolding foreman. The scaffolding foreman immediately hao the boards moved to an area below the top of the storage rack.
The inspectors identified no other concems as a result of these walkdowns, c.
Conclusions The inspectors determined that safety-related systems and components were property maintained md materiel condition was good. However, the inspectors observed two instances where scaffolding materials were not properly controlled. The inspectors were concemed about the lack of attention to detail for both scaffolding issues.
02.2 Review of Safety-Related Taaouts The inspectors reviewed three safety-related tagouts in detail. The tagouts were 971096, 971059, and 971287 for the containment atmosphere dilution and high pressure coolant injection systems. The tagouts were found to be property prepared and the components were verified to be in the required positions. The irsspectors had no concerns.
Quality Assurance in Operations 07.1 1.icensee Self-Assessment Activities During the inspection period, the inspectors reviewed multiple licensee self assessment activities, including:
Action Request screening meetings e
Safety Committee meeting, November 4,1997
Quality Assurance 3rd Quarter Assessment The inspectors observed active participation by plant management in the review of Action Requests, root cause reports, and other activities. The inspectors concluded plant management demonstrated a strong questioning attitude and provided the proper leadership that resulted in effective self assessment activities in the identification and resolution of problems.
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M Miscellaneous Operations issues (92901)
CD1 L nsed) Viotahgn 50 331/94012 04: Inadequate Procedure for Fast Manual Startup of M. dt'y Diesel Generator. The licensee corrected the identified errors in the procedure.
E mver, other inadequate procedures continued to be identified by the inspectors as
..; sed in Inspection Reports No.60-331/96005(DRP) and 50-331/97006(DRP). The a
' spectors will review licensee efforts to improve the adequacy of operating procedures in viewing the closure of violation 50-331/97006-01a. This item is closed.
C ylosed) Linr1921mnt Report (LER) 50-331/95-03-00: Plant Shuidown Due to Shutdowr, Margin Calculation Error. During plant startup on April 17,1995, the initial
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shutdown margin calculation indicated a value less than expected and less than the minimum required by the Technical Specifications. The plant was promptly shutdown.
Subsequently, the licensee and General Electric (GE) verified that adequate shutdown margin had existed during the startup. Corrective actions focused on: 1) improving the ability to accurately determine the values for certain reactivity factors,and 2) working with GE to correct their misprediction of the designed shutdown margin. Corrective actions g
were reviewed and determined to be implemented prior to the subsequent refuel outage R
startup in November 1999. This LER is closed.
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gloledjj.ER 50-331/0:i 10-00: Spurious High Pressure Coolant injection (HPCI)
sotation Dunng System Restoration. The licensee determined that during warming of the iPCI steam line, tha steam flow instrument sensors momentarily sensed high flow. The system isolated as designed in response to an apparent high flow condition. The
,1censee's corrective actions, which included revision of the steam line warming procedure, were considered to be appropriate. This LER is closed.
08.4 (Closed) Inspection FoPow item (IFI) 50-S31/96003-06: A discrepancy existed between the Undated Final S9fety Analysis Repcrt (UFSAR) Section 9.1 and Operating Instruction (01) 149 with respect tu parallel operation of the fuel pool cooling mode of the residual heat removal (RHR) system aad the spent fue! pool cooling (SFPC) system. The inspectors reviewed Reh.sn 49 of 01149 dated September 30,1996, and the May 1997 Revi,lan to the UFSAR. The discrepancy had been corrected and this item is closed.
08.5 (Closed) IFl 50-331/9600604: Th7 licensing basis did not contain a spent fuc! pool (SFP)
equihbiium temperature whers the SFP cooling mode of RHR alone was used to cool the SFP, The inspectors reviewed UFSAR Scrtion 9.1. OM49 Ruvision 49, and 01-435 Revision 23 dated Ocwber 9,1996. These documents stated that the SFPC and RHR systems would be used as nea.escary, whether alone or in paralle', to maintain SFP temprature below 150' F. This item is closed.
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08.6 LCJgits!) IFl 50-331/96004-05: Design temperatures of the SFPC system and the SFP were not clearly s',ated 11 the licensing basis. The May 1537 update to UFSAR Section 9.1 more clearly stated the limit for each system. This item is closed.
08,7 (Closed) IFl 50-331/96004-00: A discrepancy existed bewesn the original 1993 rerack submittal and Supplement 1 to this submittal regarding the neat load assumed in a particular case. The licensee supplied conected infoimation to the NRC in a letter dated September 23,1996. This item is closed
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08.8 (Cjosed) IFl 50-331/96004-07: A discrepancy existed between the rerack submittal and the Updated Final Safety Analysis Report (UFSAR) with respect to how soon after shutdown a fuel shuffle or core off load could begin. The UFSAR and Refueling Procedure 403 were revised to be consistent with the rerack submittal. This procedure prohibits core alterations until 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> after reactor shutdown. This item is closed.
08.9 (Closed 1lFl 50-331/96004-08: No procedurallimit was placed on the number of fuel assemblies to be moved out of the core, put back in the core, or left in the SFP, or the number of new assemblies placed into the core during a core reload. The inspectors
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reviewed Refueling Procedure 403, Revision 1, dated October 9,1996. The revised procedure places a limit on the number of end-of life fuel assemblies that may be discharged. This item is closed.
08.10 (Closed)IFl 50-331/96004-09: The UFSAR descriptions of maximum normal heat load and maximum possible heat ;oad were not consistent with the 1993 rc, ek submittal.
UFSAR Section 9.1 and 01149 were revised to use definitions for these terms consistent with those used in the terack submittal. This item is closed.
08.11 (Closed)IFl 50-331/96004-11: The UFSAR had previously stated that the RHR system served as the Seismic Category I makeup source to the spent fuel pool. This was corrected and UFSAR Section 1.8.13 now states that the Emergency Service Water system serves as the Seismic Category I makeup source to the spent fuel pool. This item is closed.
11. Maintenance
M1 Conduct of Maintenance M1.1 General Comments a.
Inspection Scope f62707) (61726)
The inspectors observed or reviewed all or portions of the following work activities. This included review of procedures, Technical Specifications, and the UFSAR.
Ultrasonic testing of SBDG lubricating oil pipe welds
Standby gas treatment (SBGT) system charcoal replacement and testing e
Monthly SBDG testing and special heat exchanger testing e
Special emergency service water flow test e
RHRSW pump motor lubricating oil sampling
Reactor water cleanup fivw transmitter replacement
HPCI keep-fill piping mod.'fication e
Reactor core isolation cooling (RCIC) system quarterfy surveillance test e
HPCI system quarterly surveillance test
- The inspectors observed that several of the complex activities listed above, such as the HPCI keep fill modification, the SBDG heat exchanger testing, the SBGT charcoal replacement, and the RCIC surveillance test were well coordinated and controlled.
Personnel from different depart nents were involved and wsre property briefed to' ensure
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the steps of the activity were understood by allinvolved. Engineering personnel were available and involved in several of the activities listed above.
M1.2 Operator Failed to Follow Procedure When Conductino the Standby Diesel Generator Monthly Onerability Test a.
Impection Scope (61726j On October 2,1997, the licensee performed STP 48A001 M, " Standby Diesel Generators Monthly Operability Test." The inspectors observed the pre-test briefing, observed portions of the test, and reviewed the procedure.
b.
Observations and Findinas Step 7.4.1 of STP 48A001 M specifies to verify 1G-21 prestart engine checklist, Attachment 4, is completed. The first item of Attachment 4, *1G21 Prestart Engine Checklist," required the auxiliary operator to determine the actual condition of the starting air receivers and filters. The normal condition is drained. The inspectors observed the operator properly verify that the starting air receivers were drained, however, the operat sr did not verify that the starting air filter was drained. Based on interviews, the inspectort deterndned that the operator did not previously verify that the starting air filter was drained nor did F,e believe that it was necessary to perform the verification. Following discuss..in with the inspectors, the operator consulted with the system engineer and then verified that the starting air filter was drained. Operations management stated that they expected the operator to verify both the starting air receivers and filters. Operations management discussed their expectations with the operator. The procedure step was being updated to divide the one step into two steps (Determine the actual condition of:
(1) the starting air receivers, and (2) the starting air filters) to ensure operators perform the proper verifications.
Technical Specifications (TS) 6.8.1.6 requires that written procedures involving nuclear safety, including applicable check off lists, covering surveillance and testing requirements of equipment that could have an effect on the nuclear safety of the facility shall be implemented. The failure to verify that the starting air filter was drained during the conduct of STP 48A001 M was a violation of TS 6.81.6. This non repetitive and corrected minor violation is considered to be a non-cled violation, consistent with Section IV of the NRC Enforcement Polici;(50-331/97016-01 (DRP)).
M1.3 Conclusions on Conduct of Maintenance and Surveillance Activities Maintenance and surveillance testing activities were generally completed thoroughly and profes lonally. The inspectors identified one non-cited violation which resu'aA when an sperator failed to follow a procedure. Specifically, the operator failed to verify that the starting air filter was drained during the conduct of the monthly standby diesel generator testing.
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M2 Maintenance and Materiel Condition of Facilities and Equipment M2.1 Plant Materiel Condition a.
trispection Scope (62707)
The inspectors noted that there were several minor emergent equipment issues during the inspection period. In most cases, the inspectors observed appropriate licensee response to repair and to determine the root cause. The equipment issues are listed below; b.
Observations and Findinns On September 30,1997, durino surveillance testing, the diesel fire pump coolant
water temperature was higher than expected. The cause was determined to be inadequate mesh size of the basket strainer. The strainer was previously replaced with the incorrect mesh size in July 1997 due to using an out-of-date drawing.
On October 9,1997, during a test, the licensee identified that the oil for *B"
RHRSW pump motor appeared cloudy and :he level was higher than normal.
Operations personnel promptly reported the condition, the pump was secured, a 30-day Limiting Condition for Operation (LCO) was entered, and.\\R 072311 was initiated. The licensee identified the cause to be a leak in the motor oil cooling water tubing, which was subsequently repaired.
The inspectors reviewed the history on the "B" RHRSW pump and noted that a work card had been written on October 3,1997, when the auxiliary operator identified cloudy looking oilin the pump during his rounds. The inspectors were concemed that the condition was not investigated further between October 3 and October 9 when the pump was declared inoperable. This was cor,sidered a departure from the licensee's generally prompt resolution of degraded conditions.
On October 15,1997, an automatic initiation of the control room standby filter unit
occurred. The cause was determined to be spurious spiking of radiation monitor RM 61018. The licensee planned to investigate further according to AR 972324972324
On October 20,1997, the drywell equipment drain sump level switch failed low.
- Operators received a high level alarm and responded appropriately. The switch was subsequently replaced.
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On November 10,1997, the "A" control building chiller tripped. The cause was
determined to be a failed lubricating oil pump. A 30-day LCO was sppropriately entered. Repairs were not completed prior to the completion of this inspection period.
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Conclusiqrn in general, the licensee promptly resolved the emergent equipment issues discussed above. Engineering and maintenance personnel provided appropriate support to resolve the issues. The slow response to investigate the cause of degraded oilin the RHRSW pump motor was a departure from the licensee's usual good performance in the resolution of problems.
M2.2 Failure to Balance the Refuel Floor Material Accountability Loa (MAL) and Failure of the Refuel Floor Supervisor to ensure the MAL was Balanced a.
Inspection Scope On November 5,1997, the inspectors conducted a routine tour of the refuel floor. The inspection included a review of the foreign material exclusion (FME) zone surrounding the spent fuel pool and cask pool.
b.
Observations and Findinas On November 5,1997, the inspectors identified that the refuel floor Material Accountability Log (MAL) contained numerous entries for various work activities conducted in the FME zone. The FME zone was established to prevent the intrusion or loss of unwanted materials, tools, parts, dirt, and debris into areas such as the spent fuel pool and cask pool. Section 4.5 of Administrative Control Procedure (ACP) 1408.12, Revision 7, requires that all FME zones shall have an associated MAL located outside the entrance to the zone. The log should contain refuel floor MAL sheets goveming work being performed in the FME zone. Allitems entering, exiting, consumed, or present in the FME zone shall be logged using the refuel floor MAL sheet with the following exceptions: (a) Items which are tethered, or secured per the dress r3quirements of Section 4.3; (b) items which are carried into, or out of, or within the FME zone by a crane or hoist; (c) items whose presence within the FME protected area is tracked by another procedure; and (d) items for which special provisions are specified in Section 4.7.
Section 4.5(4) requires that the MAL shall be balanced at least once per calendar day when there is work in the FME zone when the reactor head is installed. The inspectors reviewed the MALs and identified numerous examples where entries were made in the MAL when work was conducted when the reactor head was ir, stalled; however, the licensee failed to balance the MAL on those calendar days. On 6 separate days from May 19 until October 29,1997, a total of 24 MAL entries were made for items that were not exempt from entry in the MAL in accordance with ACP 1408.12, Section 4.5, such as rags, bags, vacuum hoses, water hoses, tools, power cords, and smears. All materials entering the FME zone were removed after use, however, the MAL sheets were not balanced until November 6,1997. Also, on 4 separate days from July 14 through 27, 1997, a total of 12 MAL entries were made for items that were, not exempt from entry in the MAL in accordance with ACP 1408.12, Revision 7, Section 4.5, such as tags, tools, smears, and plaW,c bags. Allitems entered in the MAL were not balanced until August 1, 1997.
On November 6,1997, after the inspectors' findings were communicated to phnt management, the refuel floor supervifor balanced the MALs to ensure allitems were accounted for in the FME zone. No discrepancies were noted. Section 5.1(5) of
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ACP 1408.12, requires that the refuel floor supervisor ensure that the MAL is periodically balanced per the requirements of Section 4.5. As stated above, the MAL is required to be balanced at least once per calendar day when there is work in the FME zone. From May 19 through November 5,1997, the refuel floor supervisor failed to ensure the MAL was periodically balanced per the requiremeats of ACP 1408.12, Section 4.5.
Technical Specification 6.8.1.2 requires that written procedures involving nuclear safety, including applicable checkoff lists and instructions, covering refueling operations, shall be implemented and maintained. The failure to balance the MAL at least once per,alendar day when there was work in the FME zone on numerous occasions between May 19 and October 29,1997, and thn failure of the refuel floor supervisor the ensure that the MAL was periodically balanced per the requirements of ACP 1408.12, Section 4.5 was a violation of TS 6.8.1.2 (50-331/97016-02).
Also, NRC inspectors noted that the general cleanliness of the refuel floor was appropriate. Adequate boundaries were established abng the walls for the storage of radiologically contaminated Equipment used on the refuel floor. The licensee effectively used stanchions to clearly delineate the FME area from the surrounding areas The proper radiological postings were in place on the refuel floor.
c.
Conclusions The inrpectors identified concems with adherence to the refuel floor FME zont.
requirements. The licensee failed to balance the MAL at least once per day when there was work in the FME zone and the refuel floor supervisor failed to ensure that the MAL was periodically balanced.
M7 Quality Assurance in Maintenance M7.1 Licensee-Identified Adverse Trend in Human Pedormance a.
Inspection Scope On October 31,1997, the licensee notified the inspectors of an adverse trend in recent human performance. The inspectors reviewed the licensee's completed corrective actions, b.
Observations and Findinos On October 31,1997, the liconsee identified a slight trend in human performance issues..
T5ere had been five recent issues related to w 'aknesses and errors in work control.
(Action Request numbers 972553,972585,972540,970284, and 971936). On November 10,1997, individual departments held human performance meetings and discussed the causes and reinforced areas such as focus on safety, questioning attitude, and procedure adherence.
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Conclusions The inspectors considered the issues discursed above to be of minor significance.
However, the trend was of concem. The INpectors concluded that the licensee acted appropriately to address an adverse trend i.: human pe formance issues.
M8 M6scellaneous Maintenance issues (92902)
MS.1 (Closed) Licensee Event Report (LER) 50-331/97-10-00: Primary Containment Isolation From Failed Relay Coil. On August 14,1997, while the plant was operating at 100 percent power, containment isolations in Groups ll and IV were received. The cause was determined to be a failed relay coil, which was subsequently replaced. In addition, the licensee iniiiated actions to replace other similar relay coils to prevent additional failures. The replacements were scheduled to be completed t'y May 1998. The inspectors considered the corrective actions to be appropriate. This LER is considered to be closed.
Ill. Enoineerina E1 Conduct of Engineering a.
inspection Scope (37551)
The inspectors evaluated engir eering invcivement in resolution of emergent materiel condition oroblems and other routine activities. The inspectors ravviewed areas such as operability evaluations, root cause analyses, safety committees, and self assessments.
The effectiveness of the licensee's controls for the identification, resolution, and prevention of problems was also examined.
The inspectors observed good involvement by engineering personnel during activities.
This included being available during surveillance testing to monitor parameters, preparing procedure revisions as needed, and supporting maintenance activities to answer questions. Examples included fuel pool cooling isolation valve cycling, control building chiller work, standby diesel generators (SBDG), high pressure coolant injection (HPCI),
and reactor core isolation cooling (RCIC) surveillance tet, ting, and special emergency service water flow testing.
E1.1 Good Resolution of PotentialIssue on Standbv Diesel Generator a.
ins'pection Scope (37551)
On October 2,1997, the licensee initiated AR 971967971967when a possible industry issue was identified with Fairbanks Morse SBDGs. The licensee promptly contacted other utilities to understand the scope of the issue and performed testing on site to determine the applicability of the issue to DAEC.
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b.
Observations and Findinas The licensee had been riotified that other utilities experienced cracking of welds in the SBDG lubricating oil system. The cause was reported to be that the original welds were not full penetration welds in all cases. On October 2 and October 3, the licensee performed non-destructive testing and verified that the subject welds at DAEC were full penetration welds. Also, the testing verified that there were no cracks in the welds.
c Conclusions The it,4pectors concluded that the licensee promptly and ag,,sively pursued an industry issue to eliminate a potential concem affecting the SBDGs.
E2 Engineering Support of Facilities and Equipment E2.1 Hiah Pr?ssure Coolant Iniection Pipina Modification In_saecticn Scope (37551)
a.
n On October 28,1997, the licensee began pre-fabrication work for Engineering Change Package 1593. Field installation was performed on November 4,1997. The inspectors reviewed the safety evaluation, modification, and Technical Specifications, and observed portions of the work in the plant.
b.
Observations and Findings The modification was being installed to ensure that the HPCI injection lines would remain full of water Juring an off normal suction line-up to the suppression pool. This modification would allow HPCI to remain operable dunng periodic calibration of the condensate storage tank level switches.
Safety evaluation 97-78 was of appropriate detail and adequately provided the bases for the determination that the change did not involve an unreviewed safety question. The modification instructions were of approntiate detail and provided guidance for pre-fabrication work and field installation. The inspectors observed good involvement in the activity by radiation protection, engineering, fire protection, quality control, and quality assurance personnel.
The inspectors identified one concem with the implementation of the engineering change package. On November 4,1997,5e inspectors went back to the job site after all field welds had been completed and the welders had left the job site. The inspectors noted that several steps in the work package had not been signed off. Based on interviews of fire watch and quality control personnel in the area, Steps 11 through 14 had been completed; however, there were no initials in the ' Craft initial and Date* blocks in the work package. After further discussion with licensee personnel, the inspectors determined that the welder and mechanical maintenance technician involved in the activity considered the woix package instructions to be a " reference only" rather than a " continuous use*
procedure.
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After cdditional review, the inspectors determined that the modification had been installed correct,y. However, the inspectors were concemed with the work package instructions being considered as " reference only" for a safety-related modification. Pending further review of licensee administrative procedures that define the pn.,eedure usage requirements for different types of activities, this is considered an unresolved item (50 331/97016-03(DRP)).
c.
Conclusions The inspectors determined that the installation of the HPCI keep-fill modification was a good initiative. This modification will enable activities such as maintenance on the condensate storage tank level switches to be performed without affecting HPC ' system operability. The inspectors did identify concems with the level of procedural e :pliance required for modification activities.
E8 Miscellaneous Engineerinc hsues (92902)
EB.1 (Closed) IFl 50-331/96003-07: Licensee-identified UFSAR discrepancy regsrding effect on components in turbine building in the event of a circulating water expansion joint break. The licensee's operability evaluation provided justification that the intent of the UFSAR statement was met and there was no operability concem. The UFSAR was subsequently revised. This item is closed.
IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Good Radiation Protection Support for RCIC and HPCI Surveillarce Tests a.
Inspection Scope (71750_)
The inspectors reviewed the adequ..cy of radiological controls in accordance with inspection Procedure 71750. This included observing radiological work practices supporting the October 16,1997, RCIC surveillance test and the November 5,1997, HPCI surveillance test.
b.
Observations and Findinos On October 16,1997, the inspectors observed the pre-test briefing and portions of STP 45E003, "RCIC RSak 1 Auto Actuation / Restart Test." On November 5,1997, the inspectors observed nt evWat briefing and portions of STP 45D001-Q,"HPCI System Quarterly Operability 1eo ' The Mspectors observed r'diation protection personnel poviding a thorough pre-test br;efing to inform individuals of changing radiological conditions during the test and the necessary precautions to be taken. Radiation protection personnel were observed providing good support in the field during the test and property controlled those areas where radiation exposure rates increased during the test.
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Conclusions
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Radiation protection personnel provided effective support during the RCIC surveillance test and the HPCI surveillance test.
R1.2 QLriticality Monitorino of Shippino Containers a.
Inspection Scope f83526) -
The inspectors reviewed Refueling Procedure RFP 401, "New F sei Rece'pt, inspection, and Channeling," Technical Specifications, special nuclear mate di and.perJng licenses; and interviewed the radiation protection supervisor and c.ir ;nvolved personnel.
b.
Observations and Findinas On April 22,1997, the licensee initiated Action Request (AR) 971228 to determine if additional actions were required to monitor criticality during the receipt of new fuel on-site in accordance with 10 CFR Part 70.24. The licensee determined that the proper controls for criticality monitoring exist on the refuel floor; however, they failed to provide criticality monitoring during the new fuel receipt process.
Typically, new fuel is transported in an inner container (RA 3) with an outer wooden box.
Only a combination of both the wooden shipping container and the RA 3 inner container was an approved method to ship new fuel in accordance with 10 CFR Par 170.24.
Therefore, the transport of new fuel in RA-3 inner containers without the outer container required criticality monitoring in accordance with 10 CFR Part 70.24. The inspectors reviewe. (.rocedure RFP 401, "New Fuel Receipt, inspection, and Channeling." The procedure instructed personnel to remove the RA 3 container from the wooden box and place onto a flatbed trailer orienting the containers long axis parallel to the trailer's long axis. The transport piocess was not monitored for criticality. In addition, to preclude criticality, RA-3 containers were not permitted to be stacked more than three containers in height. The fuel is then transpcited to the refueling feor where criticality monitors were
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In-place.
De licensee's planned corrective actions were: 1) to install the proper criticality nirnitoring on the RA-3 container when it is removed from the outer wooden container u,itil its transfer to the refuel floor, and 2) to modify existing fuel handling procedures to ensure compliance with the requirements of 10 CFR Part 70.24. The inspectors will further evaluate the licensee's plans to correct this discrepancy. This will be tracked as an unresolved item pending determination if the licensee's practices for transporting fuel without monitoring for criticality constitutes a violation of 10 CFR Part 70.24 (50-331/97016-04(DRP)).
c.
Conclusions The inspectors concluded that when new fuel was handied and transported without monitoring for criticality upon removal from the woo'.ien shipping containers, the licensee could potentially have been in non-compliance wi'.n 10 CFR Part 70.24.
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V. Manaaement Meetinas
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. Exit Meeting Summary.
The inspectors presented the inspection results to memoers of licensee management at the
conclusion of the inspection on Nevember 10,1997. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary, No proprietary informatbn vias ioentified.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee-'
, J. Franz, Vice President Nuclear G. Van Middlesworth, Plant Manager
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R. Anderson, Manager, Outage and Support J. Bjorseth, Maintenance Superintendent
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D Curtland, Operations Manager
R. Hite, Manager, Radiation Protection M. McDermott, Manager, Engineering
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K. Peveler, Manager, Regulatory Performance
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INSPECTION PROCEDURES USED
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IP 37551:
- Onsite Engineering
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IP 61726:
. Surveillance Observation IP 62707:
- Maintenance Observation.
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IP 71707; Plant Operations--
IP 71714:-
Cold Weather Preparations IP 71750:
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- lP 83526:
. Plant Support Control of Radioactive Materials and Contamination, Surveys, and Monitoring-
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F
. IP 92700:
Onsite Followup of Written Reports of Nontoutine Events at Power Reactor-Facilities e
IP 92901:
_ Followup - Operations IP 92902:
Followup - Engineering IP 92903:
Followup - Maintenance -
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened-50-331/97016-01 NCV Failure to follow procedure for SBDG surveillance test
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50-331/97016-02
\\/10 Failuie to balance material accountability log 50-331/97016-03 URI Procedure usage requirements during modifications 50-331/97016-04 URI Compliance with 10 CFR 70.24 during fuel receipt
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Closed
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50 331/94012-04 VIO Inadequate procedure for fast manual startup of SBDG
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50-331/95-03-00 LER Plant shutdown due to shutdown margin calculation error 50-331/95-10-00 LER Spurious HPCI isolation during system restoration 50-331/96003-06 IFl Parallel operation of RHR and GFPC systems
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50-331/96003-07 IFl Licensee-identified UFSAR discrepancy regarding components in turbine building 50 331/96004-04 IFl SFP equilibrium temperature using RHR
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50 331/96004-05 IFl Design basis SFPC system temperatures not clear 50-331/96004-06 IFl
- SFP heat load discrepancy
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50-331/96004 07 IFl Delay time for core cif-load
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50-331/96004-08 IFl No procedure limits on fuel movement -
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50-331/96004-09 IFl Maximum SFP heat load inconsistencies
50-331/96004-11 IFl Incorrect UFSAR description of RHR as makeup to SFP l
50-331/97-10-00 LER Primary containment isolation signal from failed relay coil.
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i LIST OF ACRONYMS USED ACP Administrative Control Procedure AR Action Request CFR Code of Federal Regulations DAEC Duane Amold Energy Center FME Foreign material exclusion GE General Electric HPCI.
High Pressure Coolant injection IFl inspection Follwup item
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IP Inspection procedure
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Inapection report LCO Limiting Condition for Operation LER Licensee Event Report MAL Material accountability log
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NCV Non-cited violation NOV Notice of Violation NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation Ol Operating Instruction
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QA Quality Assurance RCIC Reactor Core Isolation Cooling RHR Residual heat removal RHRSW Residual heat removal service water RP&C Radiological Protection and Chemistry SAR Safety analysis report SBDG Standby diesel generator SBGT Standby gas treatment system SEAR Safety evaluation applicability review SFP Spent fuel pool SFPC Spent fuel pool cooling
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STP Surveillance Test Procedure TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item
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VIO Violation su I
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