NG-87-3176, Responds to Violations Noted in Insp Rept 50-331/87-16. Corrective Actions:Fire Watch Reestablished in Accordance W/Procedure & Contract Personnel Will Meet W/Fire Marshall Before Commencing W/Hot Work Activities

Responds to Violations Noted in Insp Rept 50-331/87-16. Corrective Actions:Fire Watch Reestablished in Accordance W/Procedure & Contract Personnel Will Meet W/Fire Marshall Before Commencing W/Hot Work Activities

ML20238A666
Person / Time
Site:	Duane Arnold
Issue date:	08/21/1987
From:	Rothert W IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NG-87-3176, NUDOCS 8708310164
Download: ML20238A666 (4)

Text

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. -4 lowa Electric Light and Power Company August 21, 1987 NG-J7-3176 i

Mr. A. Bert Davis l Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Response to NRC Inspection Report 87-016 File: A-102, A-103

Dear Mr. Davis:

This letter and attachment are provided in response to the subject report concerning inspections of activities at the Duane Arnold Energy Center.

Very truly yours, William C. Rothert Manager, Nuclear Division WCR/ JCT /kmf

Attachment:

Response to Inspection Report 87-016 l cc:- .0fS. "NRC? Document Contrdl' Desk!.(Original) ,

~L; Liu L. Root A. Cappucci NRC Resident Inspector - DAEC Commitment Control 870185 MBQ% p g a c-, . - n , . c ., , _ - . s, _ ,,

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> i Attachment to NG-87-3176 j Page One

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Iowa Electric Light and Power Company Response to Inspection Report 87016 NRC Item of Violation A (Severity Level IV)

The Duane Arnold Energy Center Technical Specifications, Section 6.8.1 requires in part, that Fire Protection Program implementation procedures be implemented. ]

A Fire Protection Program implementation procedure (ACP No.  !

1412.3, " Control of Ignition Sources", Revision 4, dated April 29, 1986) requires in Paragraph 5.4.8, that a fire watch be maintained for at least a half hour after completion of cutting or welding J activities.

1 Contrary to the above, on May 22, 1987, a fire watch was not maintained for a half hour after completion of welding activities on the East Moisture Seperator man hole cover.

Response to Item of Violation A i

1. Corrective Action Taken and Results Achieved The fire watch was established in accordance with procedure after the Inspector noted the deficiency.

The worker, a contract employee, was aware of the procedural requirement prior to the incident. The Plant Superintendent immediately reviewed the situation with the worker's supervisor and the personnel involved with the incident were reinstructed as to the requirements of hot work. The Fire Marshall sent a memorandum to all qualified fire watch personnel informing of this incident and reasserting the importance of following fire watch procedures and requirements.

2. Corrective Action to be Taken The Fire Marshall now requires all Iowa Electric contract administrators to have contractor personnel meet with him prior to commencement of any hot work activities. The Fire Marshall will monitor fire watch activities to effectively communicate the need for strict procedural compliance to all workers and to take immediate corrective action as required to prevent future incidents.

The Fire Marshall will summarize his comments, actions, and observations in his monthly fire inspection report and forward them to higher levels of management.

3. Date When Full Compliance will be Achieved Full compilance was achieved on May 22, 1987, with the reestablishment of the required fire watch. Iowa Electric will assure future compliance thru continuing review of our actual work practices by supervisory personnel.

C .

Attachment to NG-87-3176' Page Two NRC Item of Violation B (Severity Level IV)

The Code of Federal Regulations Title iv, Part 50, Appendix B,Section V requires that activities affecting quality be prescribed i by procedures appropriate to the circumstances and that procedures include appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, on May 28, 1987, a construction acceptance test procedure was not appropriate to the circumstances in that it had changed the setpoint on a differential current relay and did

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not reset it back to the correct setpoint. This resulted in the "B" Diesel Generator falling to start a Core Spray pump and two j Residual lleat Removal Pumps.

Response to Item of Violation B i'

1. Corrective Action Taken and Results Achieved The construction acceptance test procedure was revised to require that the setpoint be returned to the correct setting after the test. The manufacturer's test did not specify returning the setpoint to its design value after testing, i This error in the procedure was not detected in the course of engineering review. The setpoint had originally been set by the manufacturer, but had been adjusted at DAEC as part of an acceptance test provided by the manufacturer.

2. Corrective Action to be Taken Existing design control procedures are Intended to cover all aspects of providing a design change to meet the function (s) required. Engineering, Maintenance, Construction, Testing, and Operations personnel will be instructed, by letter and additional training, on the intent of the design control procedures. Particular emphasis will be placed on using caution when applying manufacturer's component recommendations and standard tests to prove the function of a system. Furthermore, design control program acceptance procedures will be reviewed and, if necessary, revised to ensure that design changes and testing will for the design modifications:

A) initialize equipment setpoints, B) verify equipment setpoint function prior to placing the system in service, C) assure that equipment setpoints are maintained and tested.

Attachment to NG-87-3176 Page Three 1 1

3. Date When Full Compliance will be Achieved 3 Full compliance was achieved on June 5, 1987, with the J adjustment of the differential current relay and successful test of the Diesel Generator.

NRC Item of Violation C (Severity Level V)

The Code of Federal Regulations Title 10, Part 50.73, Paragraphs (a)(1) and (a)(2)(vii)(A) require that a licensee submit a Licensee Event Report within 30 days, regardless of the plant mode, for any event where a single cause of condit. ion caused two independent trains to become inoperable in a single system designed to shutdown the reactor and maintain it in a safe shutdown condition.

Contrary to the above, on July 9, 1987, the licensee had not submitted within 30 days, n Licensee Event Report for the event discussed in the previous violation.

Response to Item of Violation C

1. Corrective Action Taken and Results Achieved A Licensen Event Report (LER 87-009) was submitted on July 17, 1987.11e Plant Superintendent sent a memorandum to the personnel involved with the determination of deportability to inform them of this violation and to instruct them to conservatively apply the deportability guidance providad in NUREG 1022 and its supplements.

2. Corrective Action to be Taken In the future, Iowa Electric will take a more conservative approach to the evaluation and determination of deportability to insure that the intent of 10CFR50.73 is understood and followed.

3. Date When Full Compliance was Achieved Full compliance was achieved with the submittal of the LER on July 17, 1987.

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