IR 05000331/1998021

Insp Rept 50-331/98-21 on 981214-17.No Violations Noted. Major Areas Inspected:Licensing Corrective Actions & Engineering Involvement in Corrective Action Process

ML20199B610
Person / Time
Site:	Duane Arnold
Issue date:	01/05/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199B608	List: IR 05000331/1998021 ML20199B604
References
50-331-98-21, NUDOCS 9901140002
Download: ML20199B610 (13)

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- U. S. NUCLEAR REGULATORY COMMISSION l REGION lli Docket No: 50-331 License No:' DPR-49 l

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R'eport No: 50-331/98021(DRS)

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- Licensee: IES Utilities In !

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200 First Street ,

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P. O. Box 351 l

. Cedar Rapids, IA 52406-0351- '

Facility: Duane Amold Energy Center

' Location: Palo, Iowa j Dates: Inspection -December 14-17,1998

Inspector: R. Mendez, Reactor Engineer Approved by: R. N. Gardner, Chief, Engineering Specialists Branch 2 DMsion of Reactor Safety

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9901140002 990105 PDR ADOCK 05000331-G PDR

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EXECUTIVE SUMMARY Duane Amold Energy Center NRC inspection Report 50-331/98021 Tne inspection reviewed licensee corrective actions and engineering involvement in the corrective action process. The inspector concluded that the licensee was effective in implementing corrective actions for the items reviewed. For some of the items mviewed, corrective actions were considered excellent. In addition, the engineering staff was knowledgeable and involved in the corrective action proces. 3r the items reviewe Enaineerina e Actions to correct Appendix R emergency lighting deficiencies and procedure deficiencies were excellent (Sections E8.4 and E8.5). 1

• Engineering involvement in the corrective actbn process was good (All Sections).

• Actions to investigate tne recirculation motor generator event and reactor recirculation l pump trip and runback were comprehensive (Sections E8.1 and E8.2).

• A requirement directing the closing of the group 1 isolation valves was not included in the surveillance procedure prerequisites. In addition, maintenance procedures did not  ;

include verification that an isolation valve would close on loss of power. A non-cited l violation was identified (Section E8.8).

• Maintenance procedures did not include cautions that a group tilA primary containment i

isolation system actuation would occur after opening of a 125 VDC breaker. A non-cited l

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violation was identified (Section E8.9)

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Report Details .

111. Enolpoering The inspection included a review of the licensee's corrective actions and engineering

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involvement in the corrective action precess. The inspector determined that the licensee was effective in implementing corrective actions. The engineering staff was knowledgeable and-involved in the corrective action proces 'E8- Miscellaneous Engineering lasues (IP 92903)

E8.1 :(Closed) Insoection Followuo item 50-331/96002-01:' Reactor Recirculation Moto . Generator Set Tripped on. Exciter Field Undervoltage

On January 17,1996, the non-safety-relate'd?B" reactor recirculation motor generator set 4 tripped on exciter field undervoltage. Action request (/ R) number 3388 was issued to I

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investigate the root cause and take corrective actions. The licensee performe troubleshooting to investigate suspected problems with the two saturable reactors, the

. brushes, slip rings, rectification diodes and varistors. The transformer in the voltage ,

regulator circuit was tested and verified not to have failed. In addition, the effect of fuse ,

aging was also investigated but the licensee determined that aging was not a factor. The l

. licensee issued corrective maintenance action requests (CMARS) and replaced all the l components suspected of failing. The inspector reviewed documentation of the licensee's j troubleshooting activities and considered the actions to be thorough. Although no root . l

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cause was determined, the licensee's investigation and corrective actions were

. determined to be comprehensive. There have been no reactor recirculation moto generator trips since the occurrence of this event.-

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. E8.2 (Closed)Insoection Followuo item 50 331/96002-02: Reactor Recirculation Pump Runback

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' On January 23,1996,- a group Ill isolation signal was manually inserted on both the 'A'

and 'B' logic circuits in preparation for preplanned maintenance. This action caused the

"B" reactor recirculation pump to experience a speed controller runback that caused  ;

reactor power level to drop from 100 percent power to 70 percont. The licensec issued AR 3403 to develop a troublest d.ing plan utilizing engineers assembled from the j electrical and instrumentation and controls (l&C) departments. A series of failure '

scenarios were developed and compared to the response of both a spare recirculation pump speed controller output signal and an intermittent runback signal. Although no root cause was determined, the inspector considered the licensee's corrective actions,

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troubleshooting activities and root cause investigations to be comprehensive. There have been no recirculation pump runbacks caused by the insertion of a group 111 isolation signal

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E8.3 (Closed) Insoection Followuo item 50-331/96003-02: Potential for Fire Loading in Reactor Building i

Wood used for scaffolding was stacked in the reactor building in a configuration that could i prevent the automatic fire suppression system from adequately extinguishing a fire. The licenseo issued AR 95-0928 to resolve this issue. The licensee performed an evaluation and concluded that storage to a height of eight feet was allowed by the fire code if the fire sprinkler could produce a water density that was equal to or greater than 0.30 gallons per minute per square foot. The licensee pc rormed calculation FPE-S98-002 that demonstrated that the sprinkler density requiruw.1ts met or exceeded 0.30 gallons per

minute per square foot. The inspector toured the rs actor building and noted that wood scaffolding, stored in two areas, did not exceed the maximum height of eight feet and that

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the licensee had postings prohibiting storage of wood scaffolding above the eight foot height.

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l E8.4 (Closed) Insoection Followuo item 50-331/96003-03: Emergency Lighting Concerns

A significant number of emergency lighting lamps were incorrectly aimed and not positioned properly. The licensee issued action requests and additional procedure

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guidance to correct the problem with improperly aimed and positioned emergency light The work was performed under AR 96-0455, CMAR A33055, preventative maintenance ,

action request (PMAR) 1104646 and General Maintenance Procedure (GMP)-ELEC-03.

. The licensee developed checklists and walked down all the Appendix R emergency lights i j- and checked for proper position. The licensee routinely checked the positions during implementation of surveillance procedure GMP-ELEC-0 i

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The licensee had not previously established acceptance criteria for the failure of an l emergency lighting unit and the start and stop times were not documented during the 8- l

hour discharge test. Con:equently, the inspector could not determine whether the emergency lights were passing or failing the discharge tests. Subsequently, the licensee

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established pass-fait criteria in accordance with the Electric Power Research Institute (EPRI) standard " Battery Performance Monitoring by Intemal Ohmic Measurements,"

testing methodology. The inspector noted that the licensee incorporated the EPRI testing methodology and acceptance criteria. The new testing methodology no longer required an eight-hour discharge test. The inspector revieweu surveillance test data and noted that emergency lighting batteries that did not meet the EPRI standard were promptly replace The inspector noted that the licensee expended considerable effort to resolve the emergency lighting issues and considered the corrective actions to be excellen E8.5 (Closed) Violation 50-331/97006-01 A: Inadequate Corrective Actions l

Corrective actions taken in response to procedure deficiencies cited in a previous !

inspection report had not been adequate to preclude repetition. Several occurrences l were identified where the licensae failed to identify and correct procedure errors that I referenced the incorrect component or procedure. As part of the corrective actions, the

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licensee revised the administrative control procedures to include a flow chart for procedure usage. The flow chart indicated when to stop using a procedure when  ;

technical errors were identified and identified mechanisms to correct inaccuracies. The l inspector reviewed the procedures cited in the violation to verify that corrective action had been taken. In addition, the inspector reviewed ARs 8804,8805,8806,8807. 8808 and determined that the licensee's actions to correct other procedure inaccuracies vvere excellen E8.6 (Closed) Violation 60-331/97006-03: Motor Operated Valve (MOV) Surveillance Acceptance Criteria Not in Agreement with UFSAR Values Design valve closure time acceptance limits as described in the Updated Final Safety Analysis Report (UFSAR) for valves MO-2003 and MO-1905 had not been incorporated into surveillance procedure (STP) 45A002-Q. In addition, the licensee found other valves that did not meet the closure time acceptance limits as described in the UFSAR. The licensee found that the acceptance limits contained in the STPs occurred due to failure to adequately review and maintain the UFSAR while implementing the inservice testing requirements. The licensee issued ARs 8504,8505,8506 and 8507 to resolve differences between the UFSAR and the surveillance procedures. The licensee found I that some of the surveillance procedures contained valve stroke times that were different I than that specified by the UFSAR. The inspector reviewed surveillance procedures and l verified that the correct stroke times were incorporated. Moreover, the licensee found l that some valves in the Uf-SAR were incorrectly listed as providing an automatic isolation I function. The licensee submitted an UFSAR change to correct these discrepancie E8.7 (Closed) URI 50-331/97006-06: Licensee's Resolution of Electrical Calculation inconsistencies The inspectors previously identified several inconsistencies among the licensee's MOV calculations. The inconsistencies occurred because different values or assumptions were used by the licensee or by the architect engineer performing the calculation. Some of the differences neted by the team were incorrect size or length of cables, differences in starting and running currents, the short circuit contnbution of the battery chargers and current loading of the inverters. The irispector reviewed the inconsisteacias in some of the voltage drop calculations and determined that the differences were m nor and did not affect 'ho operability of the MOVs. In many cases the licensee used values in the calculations that were overly conservative. The licensee took corrective acticos to resolve the inconsistencies in the calculations and used values that reflected the plant configuration for plant equipment such as cable lengths and inverter current loading. This unresolved item is not being issued as a violation because some of the calcuiation inconsistencies were minor and many of the errors were conservative. For example, one calculation used a realistic value for inverter loading while another calculation used the maximum possible inverter loading. The maximum possible inverter loading used in one calculation was not reasonable because most accident scenarios would have caused the inverter to be loaded to only one-half of the manufacturer's maximum rating. Moreover, the diffe ence in inverter voltage drop between the two calculations was only 0.3 Volt _

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E8.8 (CloseJ) Licensee Event Report (LER) 50-331/98002-00: Unexpected Engineered Safety  !

Features (EU) Actuations Due to inadequate Procedures On A% 3,1998, an unexpected group isolation was generated during performance of STP 3.7.7-02. During investigation of this event, the licensee found that the surveillance procedure did not direct closing the group 1 isolation valves and therefore, one of the valves responded to the isolation signal by closing. A review of the circumstances surrounding this event revealed that the unexpected group 1 signal was initiated due to required plant conditions not being reflected in the procedure prerequisites. In addition, the licensee found that valve CV4640 failed to respond to the isolation signal because a relay failed to drop out. The cause of the valve failing to close in response to the group 1 isolation was the mechanical binding of outboard main steam drain and reactor sample isolation relay which prevented sending the isolation signal to the valve. The mechanical binding of the relay was believed to have occurred during reassembly following relay replacement. A review of the CMAR, which provided instructions to replace the relay, did not require that the relay drop out when de-energized. The licensee's corrective action consisted of revising the STP to add precautions for expected group 1 isolation, to add a prerequisite to the STP to verify group iso ations and to verify and document that the relay dropped ou The failure to establish adequate procedures is a viciation of 10 CFR Part 50, Appendix B, Criterion V. This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-255/90021-01(DRS)).

E8.9 (Closed) LER 50-331/98003-00- Invalid ESF Actuations of Group ill Primary Containment isolation System Components C'aused by Loss of Instrument AC Control Power and Procedure Deficiencies On April 10,1998, a group lilA primary containment isolation system (PCIS) actuation occurred as a result of a loss of p)wer to a 120 Volt instrument AC distribution panel. The power loss occurred after the attemate feec breaker was opened for maintenance. The loss of power was unexpected because the normal switch that supplied the 120 V distribution was in the closed position and because the altemate feed breaker was in the open position and therefore, not electrically connected to the distribution panel. The licensee performed troubleshooting and investigation; however, the licensee could not determine the root cause for the event. The inspector concluded that the licensee's actions to determine the root cause were acceptable and this event was not considered a non-cited violation because procedures were adequately followe On April,13,1998, another group illa PCIS actuation occurred unexpectedly when a 125 VDC dis *ribution breaker was opened for maintenance. This event was directly l caused by opening of the breaker; however, the licensee was not aware that the l group lilA isolation would occur. The I,censee concluded that the event occurred because of procedure deficiencies. The licensee revised procedures to indicate that one of the automatic actions that would result from opening the 125 vDC breaker would be a

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group Illa PCl3 actuation. The inspector concluded that corrective actions were acceptable.

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The failure to establish adequate procedures is a violation of 10 CFR Part 50,

Appendix B, Criterion V. This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-255/98021-02(DRS)).

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E8.10 (Closed) Violation 50-331/98004-06- Inadequate work instruction and procedure Instructi'.)ns to replace and calibrate a safety-related primary containment isolation system

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relay were not appropriate to the circumstances. Neither the work instruction used to replaco the relay nor the procedure directed maintenance personnel to disconnect the !

relay power leads prior to connecting a temporary power source. This caused an out-of-5 l service circuit to be energized. The licensee revised the PMAR to allow completion of the - '

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maintenance activity with the leads lifted. Subsequently, procedure Relay-A109-01 was

revised to add details regarding the lifting of leads from the relay and to verify the relay

was de-energized. In addition, the licensee revised administrative control procedure

] (ACP) 102.17, Revision 5, to include a checklist for discussion of the potential effects of l

[ adding energy back into a system during testin E8.11 (Closed) Violation 50-331/98010-01 A and 50-331/98010-01B: Failure to Fe!!ow Work l- Control Procedures i

The licensee failed to approve changes to a PMAR in violation of procedure ACP 1408.1.

. The changes to the PMAR were not reviewed by the affected departments. The licensee

issued AR 982040 to document this issue and take corrective actions. The changes to the PMAR were deteimined not to have an affact on the work performed. The licensee i counseled maintenance personnel on the need to reroute changes in the maintenance

scope to the appropriate departments in accordare with procedure ACP 14 In addition, the licensee failed to ensure that the acceptance criteria, for installation of a l

Grayboot splice, was met. The inspector identified that the wrong size Grayboot kit was !

!' installed to the motor power leads of the residual heat removal min flow valve MO-200 The licensee issued AR 981536 to document and resolve this issue and an operability determination was initiated. The operability detemiination concluded that the initial Grayboot connection was acceptable based on ne connector being environmentally

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qualified and because the available full load current was below the rating of the

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connector. On May 15,1998, the licensee reworked the Grayboot splice and replaced the incorrect diameter conductor with the appropriate size conducto E8.12 (Closed) Violation 50-331/98010-02: Failure to Establish a Training Program for Grayboot Application The licenses failed to establish a program which provided indoctrination and training of personnel performing Graybont applications. The licensee's electrical and 1&C staff had performed Grayboot applications since 1992 but no training lesson plan for the

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specialized application had been developed. On July 27,1998, refresher training was

L provided to the electrical and l&C technicians using recently developed Grayboot training and qualification materla!. The content of the training included Grayboot installation l

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practices and proper adherence to acceptance criteria. The inspector reviewed training !

performanco objective documentation on insla!!ing and inspecting Grayboot connector The inspector detennined that the training records adequately documented training of maintenance personnel.-

V. Management Meetings l

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X1 Exit Meeting Summary l

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'The inspectors presented the inspection results to members of licensee management at the _ conclusion of the inspection on December 17,1998. The licensee acknowledged the findings

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presente i The inspectors asked the liceasee whether any materials examined during the inspection should I

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' be considered proprietary. No proprietary information was identifie ,

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PARTIAL LIST OF PERSONS CONTACTED J. Ertman, Programs Engineering Team Leader l M. Huting, Program Engineering Supervisor.- l lJ. Karrick, Licensing Engineer .

M. McDermott, Engineering Manager l R. Murrell, Regulatory Communications Supervisor K. Peveler, Regulatoiy Performance Manager

l lNSPECTION PROCEDURE USED I lP 92903 Followup - Engineering ,

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! ITEMS OPENED, CLOSED, AND DISCUSSED

! l Q9fD94 50-331/98021-01 NCV Unexpected ESF Actuations

! 50-331/98021-02 NCV invalid ESF Actuations

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- Closed

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50-331/06002-01- IFl Reactor Recirculation Pump Runback l-50-331/96002- IFl Reactor Recirculation Motor Generator Set Tripped on Exciter Field Undervoltage

50-331/96003-02 IFl Potential for Fire Loading in Reactor Building s

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50-331/96003-03 IFl Emergenc) ;ghting Concerns 50-331/97006-01A VIO Inadequate Corrective Actions 1

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50-331/97006-03 VIO MOV Sunteillance Acceptance Criteria Not in l-" ,

Agreement with UFS.AR Values

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50-331/97006-06 URI Licensee's Resolution of Electrical Calculation ;

inconsistencies L- 50-331/98002-00- LER Unexpected ESF Actuations I i .50 331/98003-00 LER invalid ESF Actuations I L , l l 50-331/98010-01A VIO Failure to Approve Changes to Work Control Procedures L 50-331/98010-01B VIO Failure to Follow Work Control Procedures

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l 50-331/98010-02 VIO Failure to Establish a Training Program for Grayboot f Application j 50-331/98021-01 NCV Unexpected ESF Actuations L

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50-331/98021 02- NCV Invalid ESF Actuations  !

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LIUT OF ACRONYMS USED

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.ACPi Administrative Cuatrol Procedure

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. Action Request

,CMAR - Corrective Maintenance Action Request DAEC . Duane Arnold Energy Center

~DRS Division of Reactor Safety -

EPRI ' Electric Power Research institute

'o ? , SESF Engineered Safety Feature

GMP' General Maintenance Procedure I&C Instrumentation and Control MOV; _ Motor Operated Vnive -

' NRC - . Nuclear Regulatory Commission i

. PCIS : Primary Containment isolation System-

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PMA ' Preventive Maintenance Action Request -

,- STP Surveillance Test Procedure UFSAR4 -. Updated Finel Safety Analysis Report

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' LIST OF DOCUMENTS REVIEWED l

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Erocedur<ss and Surveillances 1

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b ; ACP 102.17. " Pre-job Briefs and Infrequently Performed Tests and Evolutions," Revision 5 I L

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AOP 302.1, " Loss of 125 VDC Power'" Revision 29 fARP 1C05B, ' Annunciator Response Procedure," Revision 9 l GMP-ELEC 03, "DC and AC/DC Emergency Lighting,". Revision 18 -

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, ~ 01454," Emergency Service Water System," Revision 30

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STP 3.E.1-02, "LPCl. System Operability Tests," Revision 2

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'.  ;STP 3.7,7-02," Response Time Check and Functional Test of the Main Turbine Bypass System,"

Revision 7 : ' '

E STP 45A002-Q, "LPCI System Quarterly Operability Tests," Revision 16 '

Relay-A-109-01, "Agastat 2400 and 7000 Series Timing Relays Calibration," Revision 12 1 Relay-G080-11,." General Electric Relays Type CR120," Revision 3  ;

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195-0928.01 Wood Scaffolding to Be Limited to Eight Feet in Height 960455.01' Review Past Emergency Lighting Failure Trends

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960455.03; identify. Emergency Lights tht Need to Be Relocated 982040.01- . Failure to Adequately Review Changes to PMAR 1099102 981536.00 . Wrong Size Greyboot Connector Was Installed 3388~ _ "B" Recirculation MG Set Tripped on Field Undervoltage -

3403- Reactor Power Transient on January 23,1996 3404' . Lock Out Scoop Tubes and Start Recorder on Recirculatinn MG Speed Control i3405? Shielded Wiring for Recirculation MG Set Speed Controllers

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D3406) ' UFSAR Change for Runback of Recirculation Pump on Feedwater Pump Trip b 364 '

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Safe Shutdown Emergency Lights-36491 . Review Past Emergency Light Failure Trends 3650- ' Review Performance Criteria for Cunant Safe Shutdown Path

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Identify Emergency Lights that Need to Be Relocated q

< i3652i , Revise Emergency Lighting Procedures to incorporate Battery Conductance

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.' 3 Testing 8359 Engineering Calculations Were Not Verified 8360- Error in Cable Resistance Values Calculation CAL-E-88-05-8362? Verify CALC-E88-005 Revision' 3 for Limiting Power to DC MOVs 8503; - Determine Basis for Valve Stroke Times in the UFSAR 38504 Review' Stroke Time' Allowable to not Exceed UFSAR'

,(8505' UFSAR Core Spray injection Closing Times 18506' RHR System Shutdown Cooling Discharge Inboard Isolation Valve Closing Time

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-8540, . Revision of DC System Calculation APED-R42-002 to Resolve Discrepancies 8541- - Direct Current Short Circuit Analysis w :8542l  : Revision of DC Analysis APED-R42-003 h 8805j  : Operations to Conduct Review to identify Technical inaccuracies

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8807- Des!gnation of NRC Commitments in Procedures

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8808 Standards and Expectations for Communications, Procedure Use and Adherence 11358- Recirculation Sample Line Did Not isolate as Expected 11359 - Recirculation Sample Line isolation Did Not Close on Group 1 Isolation 11360

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Revise STP 3.7.7-02 to Add Prerequisite to Verify Group Isolation 11361 Review Maintenance Procedures for Adequate Relay Functional Testing  ;

11437 . Temporary Power Loss to Division 1 Instrument AC Bus ~ l 11555 Primary Containment isolation Occurred from Group 3 Isolation When 1D1119 I Was Opened : 1 11557 Determine Information Needed for Operators When De-energizing Loads 11570- Inadvertent Energizing of Power Circuit Calculations APED-R42.002 Analysis of the Direct Current Electrical Power Distribution System CAL-lELP-E-88-05 Limiting Power Circuit Current for DC MOVs FPE-S98-002 Evaluation of Scaffold Storage Area Sprinkler System Requirements i

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