ML20236U493

Insp Rept 50-331/98-10 on 980505-06.No Violations Noted. Major Areas Inspected:Maint Activities Related to Grayboot Applications Including Training & Qualifications of Maint Staff to Perform Grayboot Applications

ML20236U493
Person / Time
Site:	Duane Arnold
Issue date:	06/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236U481	List: ML20236U480 ML20236U491 ML20236U493
References
50-331-98-10, NUDOCS 9807300206
Download: ML20236U493 (9)

See also: IR 05000331/1998010

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U. S. NUCLEAR REGULATORY COMMISSION

REGION lll

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Docket No: 50-331

License No: DPR-49

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Report No: 50-331/98010(DRS)

Licensee: IES Utilities Inc.

200 First Street S.E.-

P. O. Box 351

Cedar Rapids, IA 52406-0351

Facility: Duane Arnold Energy Center

Location: Palo, Iowa

Dates: Inspection - May 5 - 6,-1998

Exit - June 4,1998

Inspector: Zelig Falevits, Reactor Engineer

Approved by: John M. Jacobson Chief, Lead Engineers Branch

Division of Reactor Safety

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9807300206 990630 F

PDR ADOCK 05000331  ?

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EXECUTIVE SUMMARY

Duane Arnold Energy Center

NRC Inspection Report 50-331/98010

The inspector reviewed maintenance activities related to Grayboot applications including

training and qualifications of maintenance staff to perform Grayboot applications. ,

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Maintenance

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A violation with several examples was identified concerning failure to follow procedural

requirements during performance of maintenance activities. The specific examples were i

limited to the installation of certain electrical (Grayboot) connectors. (Sections M1.1)

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A violation was identified concerning failure to establish a program which will provide for j

indoctrination and training of maintenance personnel performing Grayboot applications prior

to performing these activities on safety related components. The failure to properly train

personnel in this area resulted in the installation of an undersized Grayboot connector and

contributed to the failure of another application. (Sections M5.1)

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Report Details

II. Maintenance

M1 Conduct of Maintenance

M1.1 Performance of Electrical Gravboot Annlications

a. Inspection Scone

The inspector performed an inspection to determine if electrical maintenance activities such

as electrical Grayboot applications and electrical terminations were adequately performed.

b. Inspection Results

(1) The inspector reviewed maintenance related activities associated with Grayboot

applications. Grayboot connectors are quick disconnect electrical connectors with a

single pin and socket crimped to electrical conductors and enclosed in receptacle and

plug boots. They are used for in-line connections in class IE applications and are

environmentally qualified.

Prior to field implementation of Preventative Maintenance Action Request (PMAR)

No.1099102, dated March 1,1998, the PMAR did not contain specific instructions

on use of No.12 AWG SIS conductors as extension wires (with Amp Ring terminals

on one end and Grayboot applications on the other end of the conductors). This

PMAR, in part, added Grayboot connections to cable 183491B which is the power

feed cable to MO 4627-0, "Rx Recirc IP201 A Outlet Valve." The reference tr>

procedure GMP-ELEC-008 for crimping instructions and the size and type of the

extension wires to be used was added to the cover sheet of the PMAR by the

Maintenance Planner on April 12,1998 after the oversight was identified by the QC

inspector.

Administrative controi procedure ACP 1408.1, Revision 30, Section 3.2.(9), stated

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

documented and if necessary a CMAR form initiated. Changes shall be rerouted

through affected departments." The licensee stated that the changes were not

reviewed by other affected departments such as engineering for the addition of the

extension wires since no documented evidence existed that the changes were

reviewed. The inspector determined that the Planner that added the statement " splice

12 GW SIS on motor leads with EQ tape and Grayboots per proc No. 2," failed to

adequately document and reroute the changes made to the PMAR through the

affected departments.

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Failure to adequately document and route through affected departments for review

and approval, changes made in scope of work to PMAR 1099102 after it was ,

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authorized for work per the requirements of ACP 1408.1, is considered an example

of a violation of 10 CFR 50, Appendix B, Criterion V.

(50-331/98010-Ola(DRS))

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In addition, the inspector noted that the Grayboot applications and wire splicing j

performed were not delineated in the electrical wiring and schematic diagrams to i

reflect the as-built configuration of the modified wiring.

(2) The inspector interviewed the electrician that performed the Grayboot application on

April 12,1998, and determined that the electrician had performed similar Grayboot

installations on two other safety related (Ql) valves. Specifically, PMAR No.

1066883, dated August 2,1993, added Grayboot electrical connections to MO4629-0

and PMAR No. 1094312, dated April 15, 1995, added Grayboot electrical

connections to MO 2009-0. General maintenance procedure GMP-ELEC-08,

" Scotch Brand Tape and Gray Boot Connections Installations Instructions," was used

to install the Grayboots and electrical connections. The inspector reviewed the

PMARs and the procedure and determined that the packages reviewed did not

document the size and type of wires used in performing the Grayboot applications on

the two MOVs. However, it was not clear if extension wires were used.

The inspector noted that PMAR 1084312, dated April 15, 1995, installed Grayboots

and tape to motor power leads of valve M02009-0, "RHR IP229A min flow valve"  !

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per procedure BMP-ELEC-008. Step 5.l(8) of the procedure, titled "EGS Grayboot

Connections," documented the actual measured wire insulation diameter as 0.180 ,

inches for the incoming line wire and 0.139 inches for the load wire. Step 5.l(8)(a) l

which required verification of wire diameter of the two conductors as stated above

was signed off by QC as verified and acceptable. In addition, step 5.2(2) which  !

stated, " verify wire insulation diameter is between 0.09 and 0.16 inches," was

initialed as verified by the maintenance electrician. However, the diameter measured

for the line wire and documented in step 5.l(8) as 0.180 inches, fell outside the 4

acceptance criteria (0.09 to 0.16 inches) specified in step 5.2(2). The inspector

concluded that the licensee used an undersized Grayboot kit (12-18 AWG) for a wire

l insulation with 0.18 inches diameter. The inspector requested that the licensee

investigate this concern. Subsequently, on May 12,1998, the licensee initiated AR

981536.00 to replace the undersized Grayboot installation with the correct kit for

conductor size 8-10 AWG. Engineering was in the process of performing an

j operability determination.

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Failure to ensure that the 0.09 to 0.16 inches acceptance criteria specified in

procedure BMP-ELEC-008 for wire insulation diameter of wire sizes 12 to 18 AWG,

was met prior to performing Grayboot application is considered an example of a

violation of 10 CFR 50, Appendix B, Criterion V.

(50-331/98010-01b(DRS))

c. Conclusion

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The inspector determined that prior to field implementation of PMAR No. 1099102, dated

March 1,1998, the PMAR did not contain specific instructions on use of No.12 AWG SIS

conductors, as extension wires. Failure to adequately document and route for review and

approval, changes made in scope of work to PMAR 1099102 after it was authorization for

work, was considered an example of a violation of Criterion V. In addition, the licensee's I

failure to ensure tFat the 0.09 to 0.16 inches acceptance criteria (specified in procedure

BMP-ELEC-008) for wire insulation diameter of wire sizes 12 to 18 AWG was met prior to

performing Grayboot application, was considered another example of a violation of Criterion

V.

M5 Maintenance StafT Trainine and Qualifications

MS.1 Gravboot Annlication Trainine and Qualification Process

a. Inspection Scone

The inspector examined the licensee's maintenance training and qualification program and

records to determine if electrical maintenance activities, such as Grayboot applications, were

performed by trained, qualified and certified individuals.

b. Inspection Results

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Licensee electrical and I&C craft have been performing Grayboot applications in safety

related circuits since 1992. Ilowever, no training lesson plan to train craft on this

specialized application has been developed. In April 1995, Training Management Action

Reouest, TMAR No. TM95-0741 was issued after the I&C group supervisor requested that

training material be developed to train electrical and I&C crafl on proper selection and

application of Grayboot connections. Th'e due date to establish this lesson plan was March i

1,1998; however, on December 12,1997, TM95-0741, which included development of the

Grayboot training material task, was transferred to TM97-2570 and no new due date was

specified for completion of this task. As of May 6,1998, no training lesson plan had been

developed for Grayboot applications.

The inspector questioned the basis for qualification of the electrician to perform Grayboot

applications; in particular, the first one which he perfonned in 1993. Training records

indicated that the electrician was not qualified by training (i.e., classroom, OJT) but was

considered qualified by experience after he was interviewed on July 25,1995, by the

electrical maintenance supervisor. Based on the supervisor's evaluation of"the electricians

knowledge of the task and demonstrated job performance" he was declared " proficient by

experience" and awarded qualification. Ilowever, no documentation was available for

review to indicate what actual experience was considered to conclude that the electrician

was qualified by experience. The inspector determined that the electrician had minimal

experience to perform this specialized activity. The licensee could not locate documentation

to show that the electrician was observed performing a Grayboot application and that his

l performance was evaluated by supervision prior to declaring that he was qualified to

i perform Grayboot applications. When questioned by the inspector, the electrician stated that

he did not receive formal training on Grayboot applications but that he had performed a

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Grayboot application using the procedure. No documentation could be found to indicate that

this occurred.

The inspector determined that all three electricians deemed qualified by the licensee to i

perform this application were qualified in the same manner and found to be " Proficient by

Experience" to perform Grayboot applications. The inspector concluded that the licensee

failed to ensure that the electricians, which were qualified by experience, possessed adequate

knowledge and skills to perform this specialized activity. )

In a related issue, AR 981359.00, dated May 3,1998 and AR981427.00, dated May 4,1998,

documented that during performance of STP46D004.1, " Manual Opening and Exercising of

the ADS and LLS Relief Valves," ADS isolation valve SV4400 failed to open on demand.

Licensee troubleshooting identified that a wire clamp and crimp were found loose on a

recently installed Grayboot connector for SV4400. This Grayboot application was

perfonned during the 1998 outage by an I&C technician. Corrective Maintenance Action

Request (CMAR) A47138, dated May 3,1998, was issued to replace the deficient Grayboot

connector. The inspector was informed that the I&C technicians that are considered l

qualified to perform Grayboot applications were also qualified by experience.

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Failure to establish a program which will provide for indoctrination and training of

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personnel performing Grayboot applications, an activity affecting quality, to assure that

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suitable proficiency is achieved and maintained, is considered a violation of 10 CFR 50,

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Appendix B, Criterion 11. (50-331/98010-02(DRS)) .

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c. Conclusion l

l Training records indicated that the electrician was not qualified by training to perform l

l Grayboot applications but by experience, even though his experience performing Grayboot

applications was minimal and was not evaluated to determine if he was proficient

l performing this specialized activity. As of May 6,1998, no training lesson plan had been

developed for Grayboot applications. Failure to establish a program which will provide for

[ indoctrination and training of personnel performing Grayboot applications to assure that

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suitable proficiency is achieved and maintained was considered a violation of Criterion II.

In a related issue, on May 3,1998 ADS isolation valve SV4400 failed to open on demand

during testing. Licensee troubleshooting identified that a wire clamp and crimp were found

loose on a recently installed Grayboot connector for SV4400.

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V. Management Meetings

X1 Exit Meeting Summary

The inspectors presented the inspection results to members oflicensee management at the

conclusion of the inspection on June 4,1998, during a telephone exit. 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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l PARTIAL LIST OF PERSONS CONTACTED

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Participated in the Telephone Conference Exit on June 4.1998

D. Binger, Training Specialist

l C. Kress, Training Supervisor-Technical

l R. Minear, Electrical Maintenance Supervisor

l B. Murrell, Regulatory Communications Supervisor

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K. Putnam, Licensing Manager

K. Young, Manager, Nuclear Training

NRC

Z. Falevits, Reactor Engineer, Rill

L. Collins, DAEC Senior Resident Inspector (Acting)

M. Kurth, DAEC Resident Inspector

INSPECTION PROCEDURE USED

IP 62705 Electrical Maintenance

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-131/98010-Ola VIO Failure to initial, sign and route for review and approval, changes

made in scope of work to PMAR 1099102 afler it was authorization

for work.

50-331/98010-Olb VIO Failure to ensure that the 0.09 to 0.16 inches acceptance criteria was

met prior to performing the Grayboot application.

50-331/98010-02 VIO Failure to establish a program which will provide for indoctrination

and training of personnel performing Grayboot applications.

Closed

None

Discussed

None

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LIST OF ACRONYMS USED

ACP Administrative Control Procedure

ADS Automatic Depressurization System

AR Action Request

CMAR Corrective Maintenance Action Request

DAEC Duane Arnold Energy Center

DRS Division of Reactor Safety

EQ Environmental Qualifications

! 1&C Instrument and Control

NOV Notice of Violation

NRC Nuclear Regulatory Commission

OJT On the Job Training

PMAR Preventive Maintenance Action Request

QC Quality Control

STP Surveillance Test Procedure

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