IR 05000331/1998010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-331/98-10 Issued on 980630.Reviewed C/As & Have No Further Questions.C/As Will Be Examined During Future Insps

ML20237B371
Person / Time
Site:	Duane Arnold
Issue date:	08/14/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
References
50-331-98-10, NUDOCS 9808180218
Download: ML20237B371 (2)

Text

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AUG 14 95

' Mr. John F. Franz, Jr.

.Vice President, Nuclear Alliant Tower 200 First Street SE .

P. O. Box 351 Cedar Rapids, IA 52406-0351 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-331/98010)

Dear Mr. Franz:

This will acknowledge receipt of your letter dated July 30,1998, in response to our letter

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dated June 30,1998, transmitting a Notice of Violation associated with failure to adequately I

train technicians on the installation of certain electrical connectors at the Duane Arnold Energy i Center. We have reviewed your corrective actions and have no further questions at this time.

These corrective actions will be examined during future inspections.

Sincerely, Original /s/ S. Reynolds for John A. Grobe, Director Division of Reactor Safety Docket No.: 50-331-License No.: DPR-49

' Enclosure: Lir dtd 7/30/98 from J. Franz, IES Utilities to USNRC -

cc w/o encl: E. Protsch, Executive Vice President Energy Delivery Alliant; President, IES Utilities, Inc.

G. Van Middlesworth, Plant Manager cc w/ encl: K. Peveler, Manager, Regulatory Performance

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p _ Chairperson, Iowa Utilities Board

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See Attached Distnbution L DOCUMENT NAME: G:DRS\DUA98010.TY l

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B. Clayton, Rill w/ encl SRI Duane Arnold w/ encl DRP w/enci TSS w/enci DRS (2) w/enct Rlli PRR w/enci-PUBLIC IE-01 w/enci ')

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July 30,1998 ~'""'*""""""

NG-98-1305 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station 0-PI-17 Washington, D.C. 20555-0001 l Subject: Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Reply to a Notice of Violation Transmitted with Inspection Report 98010 File: A-105, A-102

Dear Sir:

This letter and attachment are provided in response to the Notice of Violation transmitted with NRC Inspection Report 98010.

If you have any questions regarding this matter, please feel free to contact my office.

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Sincerely,

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John Vice President, Nuclear l Attachment: Reply to a Notice of Violation Transmitted with Inspection Report 98010

! cc: R. Murrell i E. Protsch D. Wilson

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R. Laufer (NRC-NRR)  !

-LCaldwell(Region III)~ )

NRC Resident Office i DOCU

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Attachment to

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Page1of5 Alliant-IES Utilities Inc.

Reply to a Notice of Violation Transmitted with Inspection Report 98010 VIOLATION 1:

Criterion V of 10 CFR 50, Appendix B, " Instructions, Procedures, and Drawings,"

requires, in part, dat activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with those procedures.

(a) Administrative Control Procedure ACP 1408.1, Revision 30, Section 3.2 (9), stated, l

" changes in scope of work after authorization of a PMAR for work shall be

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documented and if necessary a CMAR form initiated. Changes shall be rerouted through affected departments." 3 Contrary to the above, on April 12, 1998, licensee maintenance staff failed to adequately document and reroute through affected departments for review and approval, changes made in scope of work to Preventive Maintenance Action Request (PMAR) 1099102 after authorization of the PMAR for work.

(b) General Maintenance Procedure GMP-ELEC-08, " Scotch Brand Tape and Grayboot Connections Installations Instructions," Revision 15, Section 5.1 (8) stated,

" determine from Appendix 6 which kit is required." In addition, Section 5.2," Kit GB-1 Installation Instructions," Step (2), stated, " verify wire insulation diameter is between 0.09 and 0.16 inches for wire sizes 12 to 18 AWG in diameter," nrior to performing the Grayboot installation.

Contrary to the above, on May 6,1998, the inspector identified that on April 15, !

1995, during performance of PMAR 1084312, the wrong size Grayboot kit was installed to the motor power leads of valve MO2009,"RHR 1P229A min flow valve".

This occurred because the licensee failed to ensure that the 0.09 to 0.16 inches acceptance criteria for wire insulation diameter of wire sizes 12 to 18 AWG, as prescribed in procedure BMP-ELEC-008, was met.

This is a severity Level IV Violation (Supplement 1).

RESPONSE TO VIOLATION 1(a):

l 1. REASON FOR THE VIOLATION l

In Much 1998, PMAR 1099102 was processed to overhaul the limitorque operator for MO4627," Reactor Recirc Pump IP201 A Outlet Valve." As a part of this work, it was planned to install Grayboot connectors to facilitate future L

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_- Page 2 of 5 maintenance. On April 12, 1998, during the Grayboot installation process, an electrician identified the need to install No.12 AWG SIS conductors as extension l wires (with Amp Ring terminal on one end and Grayboot connections on the other end of the conductors). The PMAR was revised by the Motor Operated Valve engineer assigned to the job. This change occurred after the PMAR was l authorized for work.

ACP 1408.1, Revision 30, sates, in part, that, " Changes in scope of work after authori:ation ofa PAMRfor work shall be documented and ifnecessary a CAMR form initiated. Changes shall be rerouted through affected departments." A review of this work package conducted in May,1998, determined that the above change to PMAR 1099102 was not reviewed by other affected departments, mainly the Environmental Qualification (EQ) group of engineering. The reason for this violation was failure to follow procedure. The cause for the failure to follow procedure was less than adequate attention to detail by the engineer involved.

2. CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED An Action Request (AR' was initiated to document this issue and take actions as necessary. The chang , made to the PMAR were reviewed and determined to have no affect on the maintenance performed or the components' EQ qualification. Additionally, the personnel involved were counseled on the need to reroute changes in maintenance scope to the appropriate departments as defined in ACP 1408.1.

3. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS All corrective actions to avoid furtlur violations have been completed.

4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on May 6,1998, with the conclusion that the changes made to the PMAR without the appropriate reviews had no affect on the maintenance that was performed.  !

RESPONSE TO VIOLATION 1(bh 1. REASON FOR THE VIOLATION in January 1995, PMAR 1084312 overhauled the limitorque operator for MO2009,"RHR Pump 1P229A & C, Min Flow Valve." As part of this overhaul, l

Grayboot connectors were installed per procedure GMP-ELEC-08. Step 5.l(8) of

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.- Page 3 of 5 the maintenance procedure recorded the diameter of the wire installed. The recorded diameters were 0.180 inches and 0.139 inches. Step 5.2(2) verifies the wire insulation diameter is between 0.09 and 0.16 inches. In May 1998, as a result of a review of this PMAR package, it was determined that the recorded I values were not within the acceptance limits listed in Step 5.2(2). Specifically the diameter of 0.180 inches was not within the allowance of 0.09 and 0.16 inches.

The cause of this violation was failure to satisfy the established procedure acceptance criteria due to less than adequate attention to detail by the personnel i involved. l l

2. CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED I

An AR was initiated to document and resolve this issue. As a result, an initial l operability determination was completed. The operability determination concluded there was no operability concem based on: 1) the fact at the current and voltage which the Grayboot connecGon would see was below the Grayboot connection rating for the installed connector,2) the smaller connector provided a tighter connection and had no mechanical or EQ concerns, and 3) the margin by which the wire size exceeded the criteria was minimal and the valve had been performing acceptably.

l The incorrect diameter wire was replaced by correct diameter wire on May 15, 1998, by Corrective Maintenance Action Request A41955.

Appropriate maintenance personnel were provided additional training on the correct installation of Grayboots (as discussed later in this response).

3. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS All corrective steps to avoid further violations have been completed.

4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l

Full compliance was achieved on May 15, 1998, with the replacement of the incorrect diameter wire.

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VIOLATION 2:

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Criterion 11 of 10 CFR 50, Appendix B," Quality Assurance Program," states, in part, the licensee shall establish a program which will provide for indoctrination and training of personnel performing activities affecting quality, as necessary, to assure that suitable proficiency is achieved and maintained.

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Contrary to the above, the inspector identified that as of May 5,1998, the licensee failed to establish a program which will provide for adequate identification and training of personnel performing Grayboot applications, which are activities affecting quality, to assure that suitable proficiency is achievd and maintained.

RESPONSE TO VIOLATION 2:

1. REASON FOR THE VIOLATION

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Electrical and instrument and control (I & C) personnel have been performing Grayboot applications in safety related circuita since 1992. In 1995, the practice of Grayboot splice installation was identified by the electrical and I & C 1 departments as requiring initial training based on infrequent performance of this task. Subject-matter experts conducted a task analysis and determined that training would consist of classroom instruction and a performance evaluation.

Upon identifying Grayboot as a new task in 1995, incumbent's previous Grayboot experience was reviewed in accordance with current industry practices (INPO ACAD 92-04) and qualification granted by the department supervisors based on the individual's previous documented work history (i.e., completed historical work packages requiring Grayboot installations). Specifically, the individuals involved were evaluated by their supervisors to insure that they had knowledge of the task and demonstrated job performance, and were therefore declared

" proficient by experience." However, after further review in May 1998, it was determined that the individuals that were considered " proficient by experience" did not receive detailed training on the application of Grayboots. The cause for this violation is failure to establish detailed Grayboot training to those individuals considered " proficient by experience."

2. CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED On July 27,1998 refresher training was provided to appropriate electrical and I &

C technicians using recently developed Grayboot training and qualification !

materials. The content of this training included Grayboot installation practices and !

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acceptance criteria with a focus on attention-to-detail during task performance.

3. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l All corrective steps to avoid further violation have been completed.

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4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on July 27,1998, with the completion of the formal training to the appropriate personnel in the electrical and I & C shops.

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