ML20236U493
| 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: |
| References | |
| 50-331-98-10, NUDOCS 9807300206 | |
| Download: ML20236U493 (9) | |
See also: IR 05000331/1998010
Text
_ _ _ - _ _
.
..
..
.
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION lll
Docket No:
50-331
'
License No:
i
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
..
l'
9807300206 990630
F
ADOCK 05000331
?
e
pDR
l
- _ _ _ _ _ _ _ _ _ _ _ _
.
!
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.
,
Maintenance
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)
1
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)
!
J
l
l
i
2
1
!
i
- ___--
. _ _ _ _
_ _
_ - _ _ _ _ _ _ _
-_
- _ _ _ _ _
.
.
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.
l
3
i
'
l
L
___ __. _ _ _ _ _ _ _ _
.
.
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
,
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))
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"
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)
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
I
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
4
1
- _ _ _ _ _
_- _ _ _ _ _ _ _ _ _
.
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
l
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
performance was evaluated by supervision prior to declaring that he was qualified to
l
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
5
l
l
.-
_ _ _ . _
. _ _ _ _ _ _ _ _ _ _ -
.
.
!
)
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
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 98135998135900, dated May 3,1998 and AR98142798142700, 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
qualified to perform Grayboot applications were also qualified by experience.
Failure to establish a program which will provide for indoctrination and training of
{
personnel performing Grayboot applications, an activity affecting quality, to assure that
'
suitable proficiency is achieved and maintained, is considered a violation of 10 CFR 50, Appendix B, Criterion 11. (50-331/98010-02(DRS))
.
c.
Conclusion
l
Training records indicated that the electrician was not qualified by training to perform
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
'
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.
l
0
. _ _ _ _ _ - _ _ _ _ _ _ _ -
,
.
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.
7
l
PARTIAL LIST OF PERSONS CONTACTED
l
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
1
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
Electrical Maintenance
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-131/98010-Ola
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
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
Failure to establish a program which will provide for indoctrination
and training of personnel performing Grayboot applications.
Closed
None
Discussed
None
8
i
LIST OF ACRONYMS USED
Administrative Control Procedure
Automatic Depressurization System
Action Request
CMAR
Corrective Maintenance Action Request
Duane Arnold Energy Center
Division of Reactor Safety
Environmental Qualifications
!
1&C
Instrument and Control
NRC
Nuclear Regulatory Commission
On the Job Training
PMAR
Preventive Maintenance Action Request
Quality Control
Surveillance Test Procedure
9