ML20059K812

Forwards Insp Rept 50-331/93-15 on 930824-1014 & Notice of Violation.Violation of Concern Because B Sbdg Was Inoperable for Time in Excess of That Allowed by TS

ML20059K812
Person / Time
Site:	Duane Arnold
Issue date:	11/05/1993
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Leslie Liu IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
Shared Package
ML20059K813	List: IR 05000331/1993015 ML20059K812 ML20059K835
References
EA-93-255, NUDOCS 9311160205
Download: ML20059K812 (3)

See also: IR 05000331/1993015

Text

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NOV 0 51993

Docket No. 50-331

EA 9';-255

Iowa Electric Light and Power

Company

ATTN: Mr. Lee Liu

Chairman of the Board

and Chief Executive

Officer

IE Towers

P. O. Box 351

Cedar Rapids, IA 52406

Dear Mr. Liu:

SUBJECT: ROUTINE RESIDENT INSPECTION AT DUANE 'RN0LD ENERGY CENTER

This refers to the inspection conducted by Messrs. J. Hopkins and C. Miller of

this office on August 24 through October 14, 1993. The inspection included a

review of activities authorized for your Duane Arnold Energy Center (DAEC)

facility. At the conclusion of the inspection, the findings were discussed

with those members of your staff identified in the enclosed report.

Areas examined during the inspection are identified in the' report. Within

these areas, the inspection consisted of a selective examination of procedures

and representative records, interviews with personnel, and observation of-

activities in progress.

Based on the results of this inspection, (50-331/93015(DRP)), one apparent

violation was identified and is being considered for escalated enforcement

actica in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions" (Enforcement Policy), 10 CFR Part 2,- Appendix C.

-

This apparent violation with two examples is of concern to us because the "B"

standby diesel generator (SBDG) was inoperable for a time in excess of that- .I

allowed by your technical specifications. During this time, including a. l

period when the "A" SBDG was also inoperable and core alterations were in -

progress, the "B" SBDG would not have been able to perform its design function

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to automatically supply power to essential bus lA4 had offsite power been ig0 -

lost. Additionally, we are concerned that the inadequate maintenance

procedures and practices that allowed this condition to occur had the

potential for multiple failures of logic functions in a number of systems-

important to safety.

Inasmuch as these inspection findings are being considered for escalated

enforcement action, no Notice of Violation is presently being issued. Please

be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further

NRC review.

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An enforcement conference to discuss this apparent violation has been *

scheduled for November 19, 1993, at 10:00 a.m. (CST) in the Region III office ,

in Glen Ellyn, Illinois. This enforcement conference will be closed to public >

observation. The purposes of this conference are to discuss the apparent ,

violations, their causes and safety significance; to provide you the '

opportunity to point out any errors in our inspection report; and to provide

an opportunity for you to present your proposed corrective actions. In

particular, we expect you to address the root cause of the SBDG output- breaker ,

failure to close and your corrective actions, and actions you are taking to

ensure that maintenance procedures incorporate appropriate checks to ensure .,

that system operability is not affected when the maintenance is complete. In  ;

'

addition, this is an opportunity for you to provide any information concerning

your perspectives on 1) the severity of the violations, 2) the factors that

the NRC considers when it determines the amount of a civil penalty that may be

assessed in accordance with Section VI.B.2 of the Enforcement Policy, and ,

'

3) the possible basis for exercising discretion in accordance with Section VII

of the Enforcement Policy. You will be advised by separate correspondence of  !

the results of our deliberations on this matter. No response regarding these t

apparent violations is required at this time. ,

In addition, based on the results of this inspection, certain other of your

activities appeared to be in violation of NRC requirements, as specified in

the enclosed Notice of Violation (Notice). The first violation is of

particular concern because the inadequate foreign material exclusion (FME)  ;

controls for areas which communicate with the reactor coolant system presented

'

a potential for equipment damage, including fuel failure. Fuel failures that '

have occurred at other plants have been attributed to foreign material coming

in contact with the fuel rod cladding, ultimately resulting in cladding

failure. The weaknesses in your FME program that allowed inadequate controls

to exist in areas which communicate with the reactor coolant system demand

your prompt and continuing attention. We will closely follow your fuel

performance monitoring over the next several fuel cycles. The second

violation meets the criteria for a non-cited violation; however, we have

chosen not to exercise this option because of the number of occurrences, and

because nearly every occurrence could have been prevented by a second person

who was available to provide back-up verification for the activities which

were taking place. These examples of a breakdown in the verification process

had the potential to affect the overall quality of plant activities.

Certain other of your activities also appeared to be in violation of NRC

requirements. However, as described in the enclosed inspection report, you

identified this violation. Therefore,-the violation will not be subject to

'

enforcement action because your efforts in identifying and correcting the

.

violation meet the criteria specified in Section VII.B of the " General

Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement

Policy, 10 CFR Part 2, Appendix C).

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response. In your

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NOV 0 51993-

Iowa Electric Light and 3 -

Power Company

response, you should document the specific actions taken and any additional

actions you plan to prevent recurrence. For the first violation, you should -

address how the foreign material exclusion program for the overall plant and

the refuel floor will be improved, and why corrective actions for the spent

fuel pool cooling pump trips were not taken in. a timely fashion. For the

second violation, you should indicate what steps you will_take to improve

verification processes and how personnel errors will be reduced. After

reviewing your response to this Notice, including your proposed corrective ,

actions and the results of future inspections, the NRC will determine whether

further NRC enforcement action is necessary to ensure compliance with NRC

regulatory requirements.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter, the enclosures, and your responses to this letter will be placed

'

in the NRC Public Document Room.

The response directed by this letter and the accompanying Notice are not i

subject to the clearance procedures of the Office of Management and Budget as  :

required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning this inspection.

'

Sincerely,

onigir41 uignA ty. E. c. Gro nm

Edward G. Greenman, Director  :

Division of Reactor Projects

Enclosures:

1. Notice of Violation ,

2. Inspection Report

No. 50-331/93015(DRP)

cc w/ enclosure: }

D. Wilson, Plant i

Superintendent - Nuclear

K. Young, Manager, Nuclear

Licensing

OC/LFDCB

Resident Inspector, RIII 'i

Stephen Brown, Iowa Dept. -!

of Commerce i

Licensing Project Mgr., NRR i

James Luehman, OE l

James Lieberman, OE '

James Goldberg, OGC ,

James Partlow, NRR

Technical Support Section, RIII

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fuel pool cooling pump trips were not taken in a timely fashion. For the

second violation, you should indicate what steps you will take to improve

verification processes and how personnel errors will be reduced. After

reviewing your response to this Notice, including your proposed corrective

actions and the results of future inspections, the NRC will determine whether

further NRC enforcement action is necessary to ensure compliance with NRC

regulatory requirements.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy'of .

this letter, the enclosures, and your responses ta this letter will be placed l

in the NRC Public Document Room. [

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The response directed by this letter and the accompanying Notice are not  !

subject to the clearance procedures of the Office of Management and Budget. as ,

required by the Paperwork Reduction Act of 1980, PL 96-511. ,

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We will gladly discuss any questions you have concerning this inspection. <

Sincerely, ,

i

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Edward G. Greenman, Director

Division of Reactor Projects ,

Enclosures:  ;

1. Notice of Violation

2. Inspection Report

No. 50-331/93015(DRP)

cc w/ enclosure:

D. Wilson, Plant

Superintendent - Nuclear

K. Young, Manager, Nuclear i

Licensing .; '

OC/LFDCB

Resident Inspector, RIII

Stephen Brown, Iowa Dept.

of Commerce

Licensing Project Mgr., NRR

James Luehman, OE -

James Lieberman, OE  ;

James Goldberg, OGC ',

James Partlow, NRR

Technical Support Section, RIII ,

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