IR 05000331/1999009

Insp Rept 50-331/99-09 on 990708-0819.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support

ML20211F808
Person / Time
Site:	Duane Arnold
Issue date:	08/26/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211F789	List: IR 05000331/1999009 ML20211F783
References
50-331-99-09, NUDOCS 9908310077
Download: ML20211F808 (12)

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- U. S. NUCLEAR REGULATORY COMMISSION REGIONlli l

Docket No: 50-331 License No: DPR-49 Report No: 50-331/99009(DRP)

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Licensee: Alliant, IES Utilities In First Street P.O. Box 351 Cedar Rapids, IA 52406-0351 Facility: Duane Arnold Energy Center Location: Palo, Iowa Dates: July 8 through August 19,1999 ,

I inspectors: P. Prescott, Senior Resident inspector ;

M. Kurth, Resident inspector l

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Approved by: M. N. Leach, Chief -

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Reactor Projects Branch 2 Division of Reactor Projects 9908310077 %

gDR ADOCK 05000331 PDR

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EXECUTIVE SUMMARY Duane Amold Energy Center NRC Inspection Report 50-331/99009(DRP)

This inspection report included the resident inspectors' evaluations of aspects of licensee operations, engineering, maintenance, and plant suppor Operations

. The inspectors noted conservative operating practices during routine activities and the downpower for main turbine and main steam isolation valve testing (Section 01.1).

. Based on a lack of understanding of the Technical Specification (TS), an operating crew failed to recognize the need to log and enter a TS limiting condition for operation when power was lost to the drywell sump pump level switches, which rendered the reactor containment leakage detection system inoperable. This resulted in a Non-Cited Violation (Section 01.2).

. The licensee appropriately determined that the reactor containment leakage system was operational even though the drywell floor drain sump pump was not functionin However, due to miscommunications during the shift tumovers, on-coming operating crews were not following through with instructions to track the daily reactor containment unidentified leakage (Section 01.3).

Maintenance

- Surveillance tests and maintenance activities were conducted in an acceptable manne The inspectors observed good planning and execution of maintenance activities for the

• B" core spray and reactor core isolation cooling system maintenance outages (Section M1.1).

Enaineerina l

. The inspectors determined that the replacement and relocation of the standby liquid i control system injection isolation drain valve, V26-0020, was adequately performe The licensee provided sufficient documentation to support the installation, relocation, and post-maintenance testing (Section E2.1).

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. The responsible system engineer was pro-active in trending and making preparations for potential flooding from the Cedar River, the plant's ultimate heat sink (Section E2.2). l l

Plant Sucoort {

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- Radiation protection personnel provided sufficient support during new fuel receipt and j inspection activities. However, the procedures that radiation protection technicians j implemented were non-specific. This, in combination with management expectations l that were not communicated to radiation protection personnel, resulted in inconsistent ,

verification that fuel assemblies and shipping boxes were free of removable  !

contamination (Section R1.1). l i

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! Report Details Summary of Plant Status The licensee operated the plant at 100 percent power at the beginning of this inspection perio On July 17.,1999, at 11:00 p.m., operators reduced power to 70 percent for main turbine valve and main steam isolation valve testing. Following surveillance testing, the plant was retumed to full power on July 18,1999, at 11:00 a.m. The licensee maintained the unit at essentially full power for the remainder of this inspection perio l. Operations 01 Conduct of Operations 01.1 - Observations of Routine Activities and Planned Power Reduction and Ascension a.- Insoection Scope (71707)

The inspectors conducted numerous reviews of ongoing plant activities. These reviews included observations of control room shift tumovers and operator performance during plant evolutions. The inspectors interviewed operations personnel regarding plant status and events and reviewed daily log On July 17 and 18,1999, the inspectors observed licensee activities during a down-power for main turbine valve and main steam isolation valve (MSIV) testing to approximately 70 percent power and subsequent retum to full power operations. This included observations of operations shift activities, management and reactor engineering briefings, operator use of procedures, and cooperation between control room and in-plant operators. The following procedures were reviewed:

. Surveillance Test Procedure (STP) 3.3.1.1-19, " Functional Test of Turbine Stop Valve Closure input to RPS (Reactor Protection System) and RPT [ Reactor Protection Trip)," Revision 3

- STP 3.6.1.3-03, "MSIV Trip Closure Time Check," Revision 0

- STP 3.7.7-01, " Bypass Valves Test," Revision 1

• Operations Procedure (OP) 20, " Area inspections," Revision 9 Observations and Findinas The inspectors observed that operations personnel effectively communicated operational information, maintained accurate records, and were knowledgeable of plant and equipment status. The inspectors observed that operations personnel conducted effective shift tumovers and properly used procedures. In general, the conduct of operations was appropriately focused on safet On July 17 and 18,1999, operators performed an error-free power reduction and subsequent retum to full power. The inspectors observed that the nuclear shift

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operators reviewed the surveillance test procedures thoroughly prior to performance of the' surveillance tests. A walk-down of normally inaccessible areas of the plant, such as the heater bay and main steam tunnel, was conducted. No significant new equipment problems were found. A steam leak on MO-1169, the steam seal supply isolation valve, was found to be leaking at an unidentified point. The operators appropriately completed an Action Request (AR) to identify and repair the leak. The inspectors reviewed the outstanding list of OP 20 identified equipment issues, No significant items were note Conclusions The inspectors noted conservative operating practices during routine activities and the downpower for main turbine and MSIV testin .2 Technical Specification Entries Insoection Scope (71707)

The inspectors reviewed the circumstances of operators failing to recognize the need to log and enter a TS limiting condition for operation. Documents that were reviewed included:

- Duane Amold Energy Center Technical Specifications

- Administrative Control Procedure (ACP) 1410.2, 'LCO Tracking and Safety Function Determination Program," Revision 3 Observations and Findinas On July 25,1999, several control room annunciators alarmed simultaneously due to a loss of the radwaste building 480 volt motor control center,1B63. An operator investigated and determined its supply breaker,1BR725, had tripped open. The i operating crew identified that power was lost to both drywell sump pump level switches, l thereby rendering the pumps inoperable. Operations personnel reviewed TS 3.4.4,

• Reactor Containment System (RCS) Operational Leakage," and TS 3.4.5, *RCS Leakage Detection Instrumentation," and considered the drywell sump system operable based on TS bases information that the sumps' flow integrators, pump fill timers, and .

pump out timers were functioning. However, based on a lack of understanding of the TS bases, the crew failed to recognize the dependency of the flow integrators and ;

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timers on the functioning pumps. Operations personnel, while reviewing the logs the l following day, determined that the operating crew should have entered TS 3.4.5.A, that ;

i required the inoperable drywell sump system be restored to an operable status within ;

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inoperable drywell sump system was restored within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after j receiving the control room annunciator alarms; therefore, the TS LCO time was not exceede Technical Specification 5.4.1.a requires, in part, that written procedures shall be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33. Revision 2, February 1978. Regulatory Guide 1.33, Revision 2 Appendix A," Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," Section 1.h, states, in part, that administrative procedures for log entries should be covered by written procedures. Administrative Control Procedure 1410.2,

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Revision 3, a procedure implemented by Section 1.h of Regulatory Guide 1.33, l Step 3.3(1), requires that when any TS system or component is declared inoperable for reasons other than STPs, the appropriate LCO action shall be entered. Contrary to the l above, on July 25,1999, the licensee failed to implement Step 3.3(1) of ACP 1410.2 in

! that the operations personnel failed to enter TS 3.4.5.A when the drywell sump system was inoperable. This Severity Level IV violation (50-331/99009-01(DRP)) is being treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy. This violation is entered in the licensee's corrective as AR 16282.

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As documented in Inspection Report 50-331/99007(DRP), Section 01.2, several examples have occurred in recent months of operating crews not entering the appropriate TS LCOs. The inspectors noted that causes included: a lack of understanding of TS; a lack of attention to detail by operations personnel; and vague or unclear wording in the TS and TS bases. The licensee initiated AR 16199 to review the examples and deteimine possible common causes and the need for further corrective action I c. Conclusions Based on a lack of understanding of the TS, an operating crew failed to recognize the need to log and enter a TS LCO when power was lost to the drywell sump pump level switches, which rendered the reactor containment leakage detection system inoperabl This resulted in a Non-Cited Violatio .3 Drywell Floor Drain Sumo Pumo Problem Inspection Scoce (71707)

The inspectors reviewed the circumstances surrounding the failure of the drywell floor drain sump high level switch LS3701. Documents that were reviewed included:

- Duane Amold Energy Center Technical Specifications

- STP 3.0.0-01, " Instrument Checks," Revision 3

- Action Request 16004," Failed Switch LS3701" I Observations and Findinos On July 9,1999, during routine surveillance testing, the licensee determined that the drywell floor drain sump high level switch, LS3701, failed to properly function. This prevented the drywell floor drain sump pump from operating. The operations crew reviewed the applicable TS LCO and TS bases for the reactor containment leakage monitoring system and determined that TS LCO requirements were met and that the reactor containment leakage monitoring system was operational. The licensee relied on j the equipment drain sump to determine total containment leakage. Action Request 16004 was initiated to document the problem and the immediate actions that were taken. Also, the AR was used to inform on-coming operating crews that daily instrument checks for drywell unidentified leakage could not be completed due to the i failure of LS3701. On July 13, maintenance and post-testing activities were completed and LS3701 was placed back in servic p

The inspectors verified that the operating crew properly determined that the reactor containment leakage system was operational. However, from July 9 through 12, the on- ,

coming operating crews completed the daily instrument checks by recording a zero for

drywell unidentified leakage and entered a note referring to AR 16004. This was j contrary to the information provided in AR 16004 that was supposed to inform crew members that the drywell unidentified leakage data points could not be completed. This was miscommunicated between operating crews during shift turnovers. Once repaired, it was determined that the drywell unidentified leakage remained constant (nominally 0.05 gallons per minute) during the period that the sump pump was unable to operat Conclusions The licensee appropriately determined that the reactor containment leakage system was operational even though the drywell floor drain sump pump was not functionin ;

I However, due to miscommunications during the shift tumovers, on-coming operating

) crews were not following through with instructions to track the daily reactor containment unidentified leakage.

l 02 Operational Status of Facilities and Equipment l

O2.1 General Plant Tours and System Walkdowns (71707)

The inspectors followed the guidance of Inspection Procedure 71707 in walking down !

accessible portions of two safety systems. The systems chosen, based on maintenance ,

work activities and probablistic risk significance, were.

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. Standby liquid control (SBLC) system l l . Reactor core isolation cooling (RCIC) system

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Equipment operability, material condition, and housekeeping were acceptable in all

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cases. The inspectors did not identify any substantive concems as a result of these l

walkdown II. Maintenance M1 Conduct of Maintenance M1.1 General Comments Insoection Scope (62707. 61726)

l The inspectors observed all or portions of the surveillance test activities and work request activities listed below. The applicable surveillance test or work package documentation was reviewed. Specific tests and work request activities observed are listed below:

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l Maintenance Activities

. Corrective Maintenance Action Request A42009: MO-2147 core spray inboard pump suction from torus; exceeded torque rating, inspect internal gears of motor operator

. Preventive Maintenance Action Request (PMAR) A44103: V24-0058, test connection on RCIC steam line; replace valve and replace cap with weld cap

. PMAR A45402: V24-0057, test connection on RCIC steam line; repack and replace cap with a welded cap I

. Preventive Work Order (PWO) 1107669: MO-2124 core spray minimum flow valve; overhaul motor operator

. PWO 1109395: Startup transformer feeder breaker to bus 1 A2; calibrate and inspect time overcurrent relay

. PWO 1109444: Diesel-driven fire pump IPO49E; perform semi-annual engine inspection Surveillance of Activities

. STP 3.3.1.1-13, " Turbine Control Valve EOC [ Electro-hydraulic Operating Control] RPT Logic and RPS Instrument Functional Test," Revision 2

. STP 3.3.1.1-19, " Functional Test of Turbine Stop Valve Closure input to RPS and RPT," Revision 3

. STP 3.5.3-02, *RCIC System Operability Test," Revision 2

. STP 3.6.1.3-03, *MSIV Trip / Closure Time Check," Revision 0

. STP 3.7.7-01, " Bypass Valves Test," Revision 1 Observations and Findinos In general, the work associated with these activities was conducted in a professional and thorough manner Work was performed with the appropriate radiological control measures in place. Technicians were knowledgeable of their assigned tasks and work document requirements. The inspectors noted good planning and execution of the "B" core spray and RCIC system maintenance outages. The licensee displayed proper sensitivity to the risk significance of these systems by returning them to an operable status in a timely fashio Conclusions In general, surveillance tests and maintenance activities were conducted in an acceptable manner. The inspectors observed good planning and execution of maintenance activities for the "B" core spray and RCIC system maintenance outage ..

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111. Engineering E2 Engineering Support of Facilities and Equipment r

E Standbv Liauid Control (SBLC) System Valve Replacement insoection Scope (37551)

On June 12 through 14,1999, the licensee replaced the SBLC injection isolation drain valve, V26-0020, for better throttling capabilities for surveillance testing. The inspectors reviewed Engineered Maintenance Action A46968, TS, and post-maintenance testin b. Observations and Findings As documented in Inspection Report 50-331/99003(DRP), Section E1.2, the SBLC injection isolation drain valve, V26-0020, was being replaced to improve throttling capabilities for surveillance testing to demonstrate system operability. The valve was relocated and piping was re-routed to accommodate the increased size of the replacement globe valv Engineered Maintenance Action A46968 was of appropriate detail and provided sufficient information to support the relocation and replacement of V26-0020. The work instructions were of sufficient detail and provided guidance for welding and field installation work. The inspectors noted that the licensee appropriately considered piping stresses and support loadings due to the larger valve size and determined that sufficient support was provided. The licensee adequately performed post-maintenance testing on the welds and valve by pressurizing the system and verifying that no leaks develope c. Conclusions The inspectors determined that the replacement and relocation of the SBLC injection isolation drain valve, V26-0020, was adequately performed. The licensee provided sufficient documentation to support the installation, relocation, and post-maintenance testin . E Preoarctions for Potential Floodina From the Plant's Ultimate Heat Sink Inspection Scooe (37551. 62707 and 71707)

The inspectors reviewed the licensee's preparation for the potential flooding from the ,

plant's ultimate heat sink, the Cedar River. The inspectors reviewed the licensee's Abnormal Operating Procedure (AOP) 902, " Flood," Revision 1 j

! Observations and Findinas  !

Based on recent weather concems, the system engineer responsible for station i preparations for flooding had been gathering information from the National Weather Service and local news on potential flooding upstream on the Cedar River. Heavy rain )

conditions had occurred in the northem portion of the state. Based on this information i and an upward trend of the river water intake level, the system engineer issued a station l memorandum for maintenance to make preparations for potential flooding condition ,

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Materials necessary to protect the plant against flooding were pre-staged prior to meeting the flood stage requirement outlined in AOP 902. A spare diesel generator was also brought onsite to supply electrical power, if needed, for the river water pump hous Operations management was also notified of the potential for flooding of the Cedar River. The predicted crest was expected to occur on July 26,1999. The actual maximum river level stage was expected to be ene foot over the entry level into AOP 902. The system engineer issued almost daily memorandums to update other departments on the progress of flood preparations and actual river level. The river did

. reach the expected crest level, which did not pose any actual potential problem to site equipment. For approximately one day, access to the river water pump house was restricte c, Conclusions The responsible system engineer was pro-active in trending and making preparations for potential flooding from the Cedar River, the plant's ultimate heat sin IV, Plant Support R1 Radiological Protection and Chemistry Controls R Radioloolcal Protection Suooort for New Fuel Receiot Insoection Scope (71750)

The inspectors assessed the adequacy of radiation protection (RP) activities during the receipt and inspection of new fuel. Refueling Procedure (RFP) 401, "New Fuel Receipt,

' Inspection, and Channeling," Revisions 5 through 7, provided instructions for RP personne Observations and Findinos On July 22,1999, RP technicians were observed wiping new fuel bundles and intemal )

shipping container components for detection of removable contamination. The wipes were counted using portable survey instruments located on the refuel floor and later counted using more precise instrumentation in the RP laboratory. The RP technicians explained that the wipes were field tested on the floor and later counted in the RP laboratory. The RP laboratory count was considered the official count to determine if the components were contaminated. This was contrary to RFP 401, Section 5.3, " Fuel Inspection and Channeling Activities," that required the new fuel to be wiped and counted before proceeding to the next step. The inspectors questioned the RP manager and he explained his expectations were that the new fuel was wiped and counted for general removable contamination and that the refuel floor survey instruments were adequate to determine if removable contamination was presen Therefore, the procedural requirement was met when the technicians counted the wipes using the portable instrumentation on the refuel floo Also, the RP technicians were not consistent when checking for alpha and beta-gamma removable contamination. One RP technician was observed sampling for alpha contamination and a second technician was observed sampling for alpha and beta-

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gamma contamination. The procedure was not specific and required the RP technician to verify the components were free of contamination. The RP manager explained that

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contamination. The RP technicians sampled for alpha and beta-gamma contamination after the RP manager shared his expectations. The inspectors noted that no contamination was identified during the fuel receipt and inspection proces c. Conclusions Radiation protection personnel provided sufficient support during new fuel receipt and inspection activities. However, the procedures that radiation protection technicians implemented were non-specific. This, in combination with management expectations that were not communicated to radiation protection personnel, resulted in inconsistent verification that fuel assemblies and shipping boxes were free of removable contaminatio V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 19,1999. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee

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R. Anderson, Manager, Outage and Support J. Bjorseth, Maintenance Superintendent D. Curtland, Operations Manager J. Franz, Vice President Nuclear R. Hite, Manager, Radiation Protection M. McDerrnott, Manager, Engineering K. Peveler, Manager, Regulatory Performance G. Van Middlesworth, Plant Manager 1 l

INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-331/99009-01 NCV Failure to log entry into a TO LCO 4

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Closed 50-331/99009-01 NCV Failure to log entry into a TS LCO Discussed None

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l LIST OF ACRONYMS USED l

ACP Administrative Control Procedure

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AOP Abnormal Operating Procedure AR Action Request CFR Code of Federal Regulations DRP Division of Reactor Projects IP inspection procedure LCO Limiting Condition for Operation MSIV Main steam isolation valve NCV Non-cited violation ,

NRC Nuclear Regulatory Commission l OP Operations Procedure PMAR Preventive Maintenance Action Request PWO Preventive Work Order RCIC Reactor core isolation cooling RCS Reactor Containment System RFP Refueling Procedure RP Radiation Protection RPS Reactor protection system  !

RPT Reactor protection trip '

SBLC Standby liquid control STP Surveillance Test Procedure TS Technical Specification l

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