ML20063N501
| ML20063N501 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/03/1982 |
| From: | Root L IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20063N498 | List: |
| References | |
| LDR-82-249, NUDOCS 8209220120 | |
| Download: ML20063N501 (5) | |
Text
-_
o Iowa Electric Light and Ibwer Company September 3, 1982 LDR-82-249 U,","UAE.*E uo,s r NL4 IAAA (,9 %F MTNIN Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Re:
Duane Arnold Energy Center
Subject:
Response to Inspection Report 82-03 File: A-102, NRC-4, Inspection Report 82-03
Dear Mr. Keppler:
This letter responds to Mr. Streeter's letter of August 3, 1982, concerning the routine safety inspection conducted at the Duane Arnold Energy Center on April 1 through May 11, 1982. One item of noncompliance was identified.
The following response describes the actions that have been taken to correct the one item of noncompliance and the one open item noted in the subject inspection report. Your letter required a response to the open item in paragraph 3 of the report. We understand that paragraph 4 is the item to which the response is required.
Violation:
Technical Specification 6.8.1.5 states " Detailed written procedures involving nuclear safety, including applicable check-off lists and instructions, covering preventive and corrective maintenance operations which could have an effect on the nuclear safety of the facility shall be adhered to."
Administrative Control Procedure 1404.6, " Jumper and Lifted Lead Control,"
Section 6.1.5, states "The qualified personnel verifying the removal of jumper or lifted lead clearance shall sign in the removal verification space."
Contrary to the above, on April 4, 1982, after the removal of Cardox Jumper 82-146 the tag sheet for Jumper 82-135, bypassing the APRM flow comparator was signed off as being removed.
8209220120 820916 PDR ADOCK 05000331 O
PDR 12 - A CENTURY OF SERVICE - 1982
- Getter.nl Office
- PC. Ikn3 331
- Cett.nr ILepids, Imsis 32MNi
- 319/3%4811
.o Mr. James G. Keppler LDR-82-249 September 3, 1982 Page 2 This is a severity Level V violation.
(Supplement I).
Response
1.
Corrective action taken and the results achieved:
The APRM jumpers were removed and verified. The Cardox jumpers were verified removed and a clearance form completed.
2.
Corrective action taken to avoid further noncompliance:
The Administrative Procedure for jumper and lifted leads has been reviewed and amended to provide signoff and verification signatures for each jumper / lifted lead. The installation and removal of each jumper and/or lifted lead shall be administrative 1y controlled and independently, visually verified by qualified personnel. The personnel involved in installation / removal of a jumper or lifted lead shall sign the clearance form once for each installation and/or removal.
All personnel involved with jumpers and or lifted leads have been reinstructed on the new procedure for jumper and lifted lead control.
3.
Date when full compliance will be achievad:
Full compliance was achieved on September 1, 1982 with the reinstruction of personnel being completed.
Open Item 82-03-02 "On April 16, 1982, during performance of a Surveillance Test Procedure, an operator noted that the solenoid for Control Valves 1965 and 2035 were not de-energizing as required on one step.
Investigation by the licensee revealed that the control switch for the valves was wired incorrectly. The switch has been modified by Design Change 953 to ensure that positive operator action would be required to re-open the valves and re-initiate RHR steam condensing following an accident condition when the system had isolated on high drywell pressure or low reactor water level. The control switch was wired such that by placing the control switch to the closed position the relay to energize the control valve solenoid would energize allowing the valves to be opened by adjusting the flow controller. The The system is not required by technical specifications or the FSAR.
intended function of the system was not degraded and the system would isolate when required.
e 3
Mr. James G. Keppler LDR-82-249 September 3, 1982 Page 3 As a result of the review of this event the inspector has the following concerns:
a.
There was a breakdown in the review of the design change package in that:
(1) Two wires listed to be installed as part of the design package were already in place and drawings in the package clearly showed this.
(2) The reviews of the package by QA and the Safety Review Committee should have indentified this deficiency.
4 b.
There was a breakdown in the installation and Quality Control Verification because the control switch was wired incorrectly and QA verified that it was installed correctly.
c.
Testing of the control switch did not thoroughly test each function of the switch.
l These occurences appear to draw into question the effectiveness of the corrective actions delineated by the licensee response to " Inspection Reports No. 50-331/80-23 and 50-331/81-12. This is an open item (50-331/82-03-02)."
Response
1.
Corrective action-taken and the results achieved:
The wiring for Design Change 953 was reviewed and put into the proper configuration. The Post Installation / Modification Testing for this change was revised and reperformed with satisfactory results. Review of the Post' Installation / Modification Testing indicates that the intended design functions were met. The desired isolation function was demonstrated which was the primary function of the test.
To ensure that a generic. problem did not exist, the utility engineering group performed an independent review of all safety related, electrical design change packages with Post Installation / Modification Testing between January 1,1981 and April 16, 1982, i.e. twenty seven packages.
i As a result of this review, no additional problems were identified.
c The independent review and revised Post Installation / Modification Testing for Design Change 953 was reviewed and approved by the l
l
- _... _ _ _. _, _. _ _. _, - - _ _ _ _ - _.. ~ _ _ _., _. _. _ _ _.
Mr. James G. Keppler LDR-82-249 September 3, 1982 Page 4 Operations Committee.
In addition, QC verified the proper installation of this design change and witnessed the reperformance of the Post Installation / Modification Testing.
2.
Corrective action to avoid further errors:
The plant procedures have been reviewed and are being changed to provide a visual indication of the status of the wiring during each stage of the design change process. For example, Engineering will be required to visually accent the affected portion of the historical copy of the Electrical Scheme and Connection drawings to provide a clear picture of the wiring status before the design modification.
Different visual accentuation will be utilized to indicate the final design configuration.
During implementation of the Design Change, the interim status of the affected wiring shall be shown by visually accenting each change or addition on the drawing as it is made in the plant. Quality Control will use these accented drawings during inspection to verify the installation of the wiring. These drawings will provide a visual presentation of the changes which will facilitate QC inspections and prevent a recurrence of this event.
The visual accentuation process combined with Design Engineering's terminal status list will provide effective control and monitoring of the Electrical Construction Process while providing clear and concise modification boundaries for testing.
The completed visually accented drawings will be reviewed by the Post Installation / Modification Testing committee prior to the release of the modifications for Post Installation / Modification Testing. The review by the Post Installation Modification Testing committee has been upgraded to provide a more stringent evaluation of the system test boundary when; A) there are controlled elements which do not have positive status indication such as the lack of position indication for the control valves effected by Design Change 953 and B) the effected circuitry involves multiple controlled elements such as the operation of several valves by the switch which was rewired in Design Change 953.
Mr. James G. Keppler LDR-82-249 September 3, 1982 Page 5 This approach of visually accenting the drawings will facilitate the review process and prevent the recurrence of a breakdown in the review of the. design change.
In summary, the use of accented drawings during each step of the design l
change / modification process will facilitate engineering review, QC
~
inspection and the Post Installation / Modification Testing committee review.
3.
Date when corrective actions will be implemented.
Corrective actions will be implemented by December 31, 1982 v' en the procedures will be in place and appropriate personnel will be i
reinstructed.
If.there are any questions, please contact us.
Very truly yours Larry D. Root Assistant Vice President Nuclear Generation LDR/KLH/kmh*
l cc:
K. Hill D. Arnold L. Liu S. Tuthill NRC Resident Office i
f m
.-r,.
e.,-
.,n.,
,,9n,-
,e
,-m a-
.e,.
,