IR 05000331/1998015

Insp Rept 50-331/98-15 on 981125-990112.Violations Noted. Major Areas Inspected:Aspects of Licensees Operations, Engineering,Maint & Plant Support

ML20203F149
Person / Time
Site:	Duane Arnold
Issue date:	02/10/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203F136	List: IR 05000331/1998015 ML20203F130 ML20203F143
References
50-331-98-15, NUDOCS 9902180067
Download: ML20203F149 (18)

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U. S. NUCLEAR REGULATORY COMMISSION l

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Docket No: 50-331 License No: DPR-49  !

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Report No: 50-331/98015(DRP)

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Licensee: Alliant, IES Utilities In !

200 First Street I P. O. Box 351 i Cadar Rapids, IA 52406-0351 Faciity: Duane Arnold Energy Center ,

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Location: Palo, Iowa Dates: November 25,1998 through January 12,1999 Inspectors: P. Prescott, Senior Resident inspector M. Kurth, Resident inspector Approved by: R. D. Lanksbury, Chief Reactor Projects Branch 5 i

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I EXECUTIVE SUMMARY l

Duane Arnold Energy Center i NRC Inspection Report 50-331/98015(DRP)

This inspection report included the resident inspectors' evaluations of aspects of licensee {

operations, engineering, maintenance, and plant suppor ;

Operations

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The inspectors concluded that the overall conduct of operations continued to be professional with an appropriate focus on safety. (Section 01.1)

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The inspectors concluded that the plant downpower, shutdown, and startup were well- )

controlled evolutions. The plant shutdown and startup were characterized by careful  !

planning and were accomplished without error. Good teamwork was noted between operations, maintenance, and engineering personnel to resolve emergent equipment issues during the startup. The prompt plant shutdown to repair the condensate piping leak demonstrated conservative operating philosophy and focus on plant safet (Section O1.2) l I

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The inspectors walked down accessible portions of the heater bay,250 VDC battery '

l chargers, and cable spreading room and found equipment operability, material j condition, and housekeeping to be satisfactory. (Section O2.1)

Maintenance

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The inspectors found the licensee's initial root cause evaluation, maintenance rule determination, inservice inspection evaluation, and repairs to a through-wall crack on the condensate low pressure heaters bypass line to be thorough. (Section M1.2)

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The inspectors identified deficient soldering of a jumper lead on a 250 VDC battery l charger circuit card in that the jumper lead was too short to extend sufficiently through '

the circuit board and was not visible beneath the solder. The quality control (QC)

inspector who had verified that the soldering was acceptable relied on his skill-of-the-craft rather than reviewing and using the required maintenance procedure which prescribed that the jumper be clearly visible beneath the solder. A contributing factor to this violation for failure to perform the proper soldering verification was a sense 1 of urgency to reconfigure the circuit board and have it placed in service. In addition, the j QC inspector was busy supporting other work activities and therefore did not review the !

procedure requirements. (Section M1.3) l

Following inspector identification of the deficient soldering on the 250 VDC battery )

charger circuit card, the licensee addressed the need to ensure maintenance personnel j and QC inspectors reviewed and used procedures. Licensee management also  ;

reinforced the need for plant personnel to take the proper time to complete work '

activities. The inspectors considered these corrective actions to be reasonabl (Section M1.3)

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The licensee did not adequately consider the impact of planned painting of the reactor :

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building floor on the standoy gas treatment (SBGT) system charcoal filters in the event i the system automatically initiated during accident conditions. (Section E1.2) !

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The licensee's subsequent response to the inspectors' concerns regarding protection of I the SBGT system from volatile organic compounds in paint that was to be used on the - :

. issctor building floor was appropriate. Conservative assumptions in the calculations I an:14dministrative controls placed on the painting activities ensured adequate efficiency l of the c.harcoal beds and operability of the SBGT system in the event of system j initiation. (Section E1.2) '

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Plant Suooort I a

The inspectors concluded that radiological practices observed during maintenance activities and daily walkdowns were good. (Section R1.1) l

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A questioning attitude by health physics personnelled to the discovery of a self-contained breathing apparatus (SCBA) cylinder which contained compressed nitrogen instead of breathing air. The inspectors determined that, upon discovery, the licensee ,

addressed the issue appropriately. The licensee conservatively tested each SCBA . !

cylinder onsite to ensure each contained the appropriate amount of breathing air. Also, j l

the licensee held a fact finding meeting and initiated a root cause investigation to l

l determine the facts surrounding the issue and the possible need for corrective action l (Section F2.1)

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Report Details Summary of Plant Status At the beginning of the inspection period, the licensee operated the plant at 100 percent powe On December 12,1998, the licensee initiated a power reduction and performed monthly turbine valve testing. On December 13,1998, while at reduced power, auxiliary operators (AO)

performed a routine visualinspection of the heater bay area. The AOs identified a one gallon-per-minute (gpm) leak on the condensate low pressure heaters bypass line. The exact location of the leak was indeterminate due to insulation covering the pipe. On December 14,1998, the licensee initiated a controlled power reduction to bring the plant to a cold shutdown condition after identifying that the leak was due to a crack in the weld where the pipe and a support stanchion were joined. Following successful repair, the licensee commenced a plant startup on December 19,1998. The licensee synchronized the main turbine generator to the grid at 6:02 a.m. on December 20,1998. The licensee operated the plant near full power for the remainder of the inspection perio . Operations 01 Conduct of Operations O1.1 General Comments Inspection Scope (71707)

i The inspectors followed the guidance of Inspection Procedure 71707 and conducted frequent reviews of plant operations. These inspection activities included observing routine control room and in-plant activities, attending shift turnovers and crew briefings, and performing panel walkdowns. The conduct of operations was professional and

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focused on safety with appropriate management oversight. Noteworthy observations are detailed in the sections belo Observations and Findinas l The conduct of operations was professional. The inspectors observed strict use of

! procedures and thorough shift turnovers. Overall, emergent equipment issues were j promptly addressed and conduct of operations was appropriately focused on safety.

f Conclusions The inspectors concluded that overall conduct of operations continued to be professional, with an appropriate focus on safety.

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01.2 Observations of Plant Reduction in Power Shutdown and Startuo Inspection Scope (71707)

The inspectors monitored licensee activities during a reduction in power for turbine valve testing, a reactor shutdown, and a reactor startup. This included observation of portions of each shift's activities, management and reactor engineering briefings, operator use of I procedures, and coordination between control room and in-plant operator l l

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On December 12 through 13,1993, operators initiated an 80 percent reduction in reactor power for monthly turbine valve testin .

On December 14,1998, the licensee shut down the plant to repair a leak on the condensate low pressure heaters bypass lin .

Following repair of the leak, the licensee commenced reactor startup on  ;

December 19,199 Observations and Findinas l Operations personnel performed an error-free power reduction for the scheduled control rod sequence exchange and main turbine valve testing. The inspectors noted good j coordination between operations and reactor engineering personnel during the evolutio l

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During the downpower, AOs performed the Operations Procedure OP 20 " Area -

Inspections." The purpose of the procedure was to ensure equipment integrity was {

adequate by visualinspection of normally inaccessible high radiation areas. In the ,

heater bay, AOs identified a one gpm leak on the condensate low pressure heaters l bypass line. The exact location of the leak could not be initially identified due to  !

insulation on the piping. Subsequently, the licensee removed the insulation and found j the leak at the location where a support stanchion was welded to the pipin '

The inspectors observed good teamwork between various departments and licensee

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management to assess the crack and develop a repair plan. Based on a review of crack

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location and configuration, engineering personnel expressed concern that the crack was potentially fatigue-related and could become larger. Subsequently, the operations shift began a controlled power reduction in accordance with Integrated Plant Operating .

Instruction 4, " Shutdown." The inspectors observed the power reduction. Activities i l were well coordinated and performed in a controlled manne On December 18,1998, prior to startup, the licensee conducted a post-maintenance walkdown of the heater bay area, where the majority of the forced outage activities were conducted. The inspectors found no discrepancies during an independent walkdown of l the area. The inspectors observed only minor equipment problems during the startup and good teamwork by all departments in support of startup activities.

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This was the first startup since the improved Technical Specifications (ITS) were implemented in August 1998. The licensee conducted a review of the startup and surveillance test procedures to ensure compliance with ITS. The operations' shift personnel questioned if the plant mode change could occur because the required daily jet pump operability test results were unsatisfactory. At minimum recirculation pump speed, the differential pressure across the jet pumps was too low to measure accurately, which resulted in an unsatisfactory ITS-required surveillance tes Surveillance test requirement 3.0.4 prescribed that all applicable surveillance test requirements (e.g., Surveillance Test Procedure (STP]) 3.5.2-01, " Daily Jet Pump Operability Test," must be met before entry into another mode. Engineering personnel performed an engineering evaluation and noted that ITS 3.4.2.1 stated that the

" surveillance is not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor thermal power was greater than 25 percent." Deviations due to instrument inaccuracies were expected at low flow rates. The jet pumps were considered operable based on the surveillance test results prior to the shutdown. The licensee continued to evaluate the ITS requiremen Conclusions The inspectors concluded that the plant downpower, shutdown, and startup were well-controlled evolutions. The plant shutdown and startup were characterized by careful planning and were accomplished without error. Good teamwork was noted between operations, maintenance, and engineering personnel to resolve emergent equipment issues during the startup. The prompt plant shutdown to repair the condensate piping leak demonstrated conservative operating philosophy and focus on plant safet Operational Status of Facilities and Equipment O2.1 General Plant Tours and System Walkdowns (71707)

The inspectors followed the guidance of Inspection Procedure 71707 in walking down accessible portions of several systems. The systems chosen, based on maintenance work activities and probabilistic risk significance, were-

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heater bay area (main steam, feedwater, and condensate lines) I

. 250 volt direct current (VDC) battery chargers

. cable spreading room Equipment operability, material condition, and housekeeping were satisfactory in all i'

cases. The inspectors did not identify any substantive concerns as a result of these walkdowns. Issues concerning these systems are discussed in Sections M1.2 and .

M1.3, respectivel I

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08 Miscellaneous Operations issues (92901)

0 (Closed) Licensee Event Reoort (LER) 50-331/97-004-00: Main steam line (MSL) low reactor pressure isolation instrumentation not in agreement with numerical values in technical specifications (TS).

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On February 23,1997, the licensee determined that the as-left calibration settings on three of the four instruments that initiate the isolation of the MSLs on low reactor pressure (<850 psig in Run mode) were not in agreement with the value prescribed by TS and were set in the non-conservative direction. The licensee considered the instruments to be operable based on the plant engineering setpoint calculation However, the licensee revised the calibration procedures to ensure that the instruments'

as-left settings would be in verbatim compliance with the preferred direction of the TS numerical value. The licensee subsequently recalibrated the instrument Previously, during calibration of these instruments, the licensee had applied instrument tolerances to the setpoint values given in TS. The licensee had, at that time, custom TS. Included in the definition of limiting safety system setting (LSSS) was the statement, "The limiting safety system setting plus the tolerance of the instrument as given in the system design control document gives the limiting trip point for operation."

This definition allowed the licensee to control the instrument tolerances (e.g., accuracy repeatability, drift, etc.) in the system design control documents (i.e., engineering setpoint calculations and plant surveillance test procedures). As a result, the licensee considered the TS instrumentation tables for " trip level setting" as nominal values and not the values that determined channel operability. Through its Instrument Setpoint Program (ISP), the licensee calculated the as-found values given in the plant instrument calibration procedures that determined channel operability. These calculations were based upon an NRC-approved setpoint methodology topical report NEDC-31336P-A,

" General Electric (GE) Instrument Setpoint Methodology." The licensee considered these calculations to be the system design control documents given in the TS definition of LSS None of the as-found settings exceeded the allowable value of >821 psig as required by ,

the engineering setpoint calculations. Therefore, the instruments would have performed i their intended safety function, with the margin required by the GE setpoint methodology, l prior to reaching the analytical limit of 800 psi l l

The licensee completed a review of plant procedures that performed calibrations on TS '

instrumentation to determine if the specified as-left value would allow an in-plant setting

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not in conservative agreement with the numerical TS value. The licensee determined that one additional instrument function, the recirculation flow upscale control rod block, had instrument channels not in conservative agreement with TS. This condition was reported in LER 97-005-00 (see below). Also, two other surveillance test procedures for the high pressure coolant injection (HPCI) turbine exhaust diaphragm pressure high and HPCI condensate storage tank level low had the potential to cause equipment to be left calibrated in a non-conservative direction from the TS value. The licensee revised all these procedure The long-term corrective action was to replace the nominal values listed in the TS instrument tables with the allowable values calculated in the ISP. This was completed when the ITS were implemented on August 1,1998. This item is close . -

0 (Closed) LER 50-331/97-005-00: Setpoint for recirculation flow upscale rod block greater than TS allowance. The inspectors noted the same issues and corrective ;

actions taken for LER 50-331/97-004-00 (see above) were also applicable to this LE This item is close . Maintenance M1 Conduct of Maintenance M1.1 General Comments

' Insoection Scope (62707 and 61726)

The inspectors observed all or portions of the surveillance test activities and work request activities listed below. The applicable surveillance test or work package documentation was reviewed. Specific tests and work request activities observed are listed below:

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Corrective maintenance action request (CMAR) A41401: 1D44 250 VDC battery charger; replace amplifier card and sensing / current limit card

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CMAR A47966: Emergency service water return piping from reactor core

. isolation cooling (RCIC) room cooler; freeze-seal downstream piping and replace corroded piping j

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CMAR A41472: Condensate bypass line 12-GBD-033 around low pressure  ;

heaters ; cut out leaking 10 foot section of piping and replace, and also install i new pipe support

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CMAR A41491: 1P092A hydrogen seal oil pump; pump / motor making rubbing j noise and tripped, replaced seized pump and realigned  ;

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. CMAR A43068: Main generator field grcund detecting relay 64 GF2; troubleshoot relay tripping Surveillance Test Activities

. STP-3.7.7-01: " Monthly Turbine Bypass Valve Testing"

. STP-NS930001: " Monthly Turbine Operations"

. STP-NS13B004: *NFPA Annual Diesel Driven Fire Pump Operability Test"

. STP 3.3.2.1-03: " Rod Worth Minimizer Functional Test" i

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. Observations and Findinas The inspectors determined that, overall, licensee personnel conducted the work associated with these activities in a professional and thorough manner. Technicians were knowledgeable of their assigned tasks and work document requirements. The inspectors noted good planning and execution of the RCIC room cooler essential service water piping replacement. The inspectors observed that emergent work on the 1D44 1 250 VDC battery charger and main generator field ground detecting circuitry required significant troubleshooting, which was done in a logical and thorough manner. The {

licensee's decision to repair the safety-related 1D44 250 VDC battery charger to I availability status showed conservative decision-makir.g. The inspectors focused particular attention on the RCIC room cooler and the 250 VDC battery charger because j of their probabilistic risk significance. The licensee displayed proper sensitivity to the !

risk significance of these systems by restoring them to an operable status in a timely 1 fashion. However, a failure to follow procedures during soldering repairs to a printed circuit board was identified by the inspectors during the battery charger maintenance, as detailed in Section M1.3 of this inspection repor M12 Leak on Condensate Low Pressure Heaters Bvoass Line i Inspection Scoce (62707 and 37551)

The inspectors observed maintenance activities to repair a through-wall leak on the condensate low pressure heaters bypass line. The piping leak resulted in a five day i l forced maintenance outage. The inspectors reviewed the work order package and l l maintenance history. The inspectors also reviewed the inservice inspection (ISI)

requirements and maintenance rule applicability and inspected the removed section of pipin l Observations and Findinas

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On December 13,1998, the AOs found a one gpm leak on the 12-inch condensate low l pressure heaters bypass line during a routine inspection of the heater bay. The licensee l initially believed the leak was at a mechanical joint of the 10-inch isolation valve ;

l MO-1473. Subsequently, the licensee removed the piping insulation and found the leak source at a piping support downstream of the valve. The leak was located at the weld around the three-inch pipe support that attached the support to the underside of the l piping. The licensee decided to place the plant in cold shutdown and repair the leak.

l (See Section O1.2 for details).

l After removing additional insulation to inspect the piping, the licensee found extensive l

pitting on the external piping surface. Ultrasonic testing results led to the decision that a 10-foot section of the piping would need to be replaced. In a preliminary evaluation for the cause of the severe corrosion, engineering personnel determined that previous packing leaks on valve MO-1473 saturated the piping insulation with water and reacted to form calcium chloride. The licensee planned to send sections of the piping to a laboratory for analysis. The licensee also decided not to re-insulate the piping. This decision was based on the fact that the condensate in the line was normally stagnant, and the piping did not get hot enough to evaporate water that soaked into the insulatio _ _ _ . _ . __ _ ___ _ _ _ _ _ . _ _ _ _ _ _ _ _ -, ._ _ __

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The licensee also modified the pipe support. The original pipe support was a three-inch pipe stanchion welded to the pipe with a plate on the bottom that acted as a sliding foo Below the sliding foot was a plate attached to an adjustment stud of a spring can. In the preliminary root cause evaluation, the licensee determined that the bottom support plate separated from the adjustment stud of the spring can. This allowed unequalload distribution when the support plate tilted, which placed the load on the pipe support stanchion at one point. Locking up of the sliding foot transferred pipe movement to the failed pipe weld. The licensee changed the support to a saddle type support, attached to the pipe by two U-bolt brackets, with the same sliding foot and spring can arrangement at the bas The licensee had previously evaluated the piping for ISI requirements and determined I that the piping did not need to be in the ISI program because there was normally no flow in the piping. The licencee did not consider the piping to be categorized as (a)(1) under the maintenance rule because no previous piping leaks in the condensate system were documented. Through a review of the work history, the inspectors did not find any

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significant concerns. Engineering personnel performed a load analysis on 51 other pipe supports welded directly to the process pipe in the condensate system and conducted a general walkdown of other pipe supports in the heater bay area. The inspectors independently checked other supports in the heater bay area. No problems were identified. The licensee completed repairs on the condensate line and did not note any leaks during plant startu Conclusions The inspectors determined the licensee's initial root cause evaluation, maintenance rule

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determination, ISI evaluation, and repairs of a through-wall crack on the condensate low pressure heaters bypass line to be thoroug M1.3 Solderino Performed on Circuit Card for 250 VDC Battery Charaer Inspection Scope (62707)

i The inspectors observed maintenance activities to reconfigure a jumper on a circuit card for the 250 VDC battery charger,1D44. The inspectors reviewed the maintenance action request and maintenance instruction form and conducted interviews with plant personne l Observations and Findinos On December 3,1998, instrument and controls (l&C) technicians followed the instructions provided in the maintenance instruction form (MIF) for CMAR A41401 to l reconfigure a jumper on a sensor and current limit circuit card that was to be installed in the 250 VDC battery charger,1D44. The licensee completed the reconfiguration and in accordance with the MIF, a quality control (OC) inspector signed a procedure step that verified that the soldering was acceptable per Maintenance Department Procedure GMP-INST-011, Section B, " Soldering Acceptance Criteria."

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The NRC inspectors evaluated the adequacy of the soldering using Section B of GMP-INST-011, and noted that the profile for one of the two jumper leads was not clearly visible beneath the solder, which was contrary to Step 5.3(4) of the above-mentioned maintenance procedure. The inspectors discussed the discrepancy with the QC inspector. He explained that he did not review ar use the maintenance procedure and that he relied on his skill-of-the-craft to ve.ify that the soldering was performed correctly. As described in the Notice of Violation included with this inspection report, the failure to verify that the component lead was clearly visible beneath the solder in accordance with Step 5.3(4) of GMP-INST-011, Section B, was a violation of TS 5.4.1.a (VIO 50-331/98015-01). Through further discussions with several individuals

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involved in completing the maintenance task, the inspectors determined that several contributing factors led to the failure to perform the proper soldering verification: There was a sense of urgency to reconfigure the circuit board. The licensee committed to shipping the in-service circuit board to the vendor that day and needed the spare board reconfigured so it could be placed in servic . The QC technician was busy supporting other work activities and relied on his

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skill-of-the-craft to verify the soldering without reviewing the requirements of the soldering procedur . The jumper used for reconfiguration was unsoldered from one location on the circuit board then resoldered in another location on the circuit board. The jumper length was proper for its original application; however, when moved, was too short in length to allow the jumper to extend sufficiently through the circuit bomd per the procedur The QC inspector and system engineer agreed that the jumper was not extended sufficiently through the circuit board and another MIF was developed to resolder a jumper. The jumper was unsoldered and removed and a quality level one wire of sufficient length was soldered properly in place. The QC inspector verified that the soldering was acceptable in accordance with the procedure. Therefore, the date when full compliance was achieved was December 3,1998. The NRC inspectors verified that the soldering was accepteble in accordance with the procedure. The licensee placed the circuit card in the 250 '/DC battery charger and satisfactorily conducted post-r.laintenance testin The licensee initiated action request (AR) 14036 to document and address the QC inspector's reliance on skill-of-the-craft to verify the proper soldering without reviewing the requirements of the procedure. Subsequently, licensee management met with maintenance and QC personnel to reinforce the expectation that prior to performing assigned work activities, they were responsible for reviewing work documents to become familiar with the type and extent of work to be performed. Also, licensee management reinforced their expectation that the proper time should be taken to do the job right the first time. Licensee management explained that if workers feel rushed to complete work activities, they should seek management involvement to ensure the necessary time is provided to complete the work properly. A written response is not required to the violation based on the corrective actions take . ..____~_ ._ ..___ _ _.________m-- _ - . _

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. Conclusions

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L The inspectors _ identified deficient soldering of a jumper lead on a 250 VDC battery . ;

L charger circuit card in that the jumper lead was too short to extend sufficiently through the circuit board and was not visible beneath the solder. The QC inspector who had verified that.the soldering was acceptable relied on his skill-of-the-craft rather than i'

reviewing and using the required maintenance procedure which prescribed that the

" jumper be clearly visible beneath the solder. A contributing factor to this violation for ,

failure to perform the proper soldering verification was a sense of urgency to reconfigure j the circuit board and have it placed in service, in addition, the QC inspector was busy l l supporting other work activities and therefore did not review the procedure requirements. The licensee subsequently addressed the need to ensure maintenance personnel and QC inspectors _ reviewed and used procedures. Licensee management .

f also reinforced the need for plant personnel to take the proper time to complete work

activities. The inspectors considered these corrective actions to be reasonabl ,

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E1 Conduct of Engineering i

E Protection of Standbv Gas Treatment (SBGT) System Durina Paintina ' Insoection Scope (37551 and 40500)

The inspectors reviewed the licensee's precautions to address potential contamination '{

of charcoal beds in the SBGT system prior to planned extensive painting of the floor in l the reactor building. The inspectors reviewed the Operating instruction (01) procedure 01 170, " Standby Gas Treatment System," the material hazards sheets for the

- primer / sealer and self-leveling epoxy for the floor paint, Deviation Report 86-398 on .

plant painting, and the system engineers' revised evaluation on the impact of the paint

on the SBGT system. Discussions were held with the SBGT system engineer, the supervisor of the painters, and the health physics supervisor, Observations and Findinas During this inspection period, the licensee made preparations to paint a large area of the main reactor building floor. The SBGT procedure 01170, contained a precaution on painting greater than 1000 square feet in any ventilation zone that can be lined up to the SBGT system. The procedure required that if the SBGT was operated during that time, an evaluation of the effects of the volatile organic compounds (VOC) on the carbon bed should be made.

l The procedure requirement was based on a 1986 event. In June 1986, painting was in j Lf progress while the SBGT system was in operation. Operations personnel requested l l that this condition be evaluated to determine if significant fumes had entered the SBGT

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l system. The licensee determined that only a relatively small area was painted and no l corrective actions were necessary. The licensee found that industry practice was to  !

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i consider the painting of an area greater than 1000 square feet, where the resulting fumes are communicated to the charcoal beds, to be considered "significant." A memorandum was issued that required notifying the control room when an area greater than 1000 square feet was to be painted. This was to allow personnel to take precautions to ensure that painting was stopped in the event of an automatic SBGT system initiatio The inspectors questioned the ability to perform a ventilation flow reconfiguration in the event of an automatic initiation of the SBGT system. The inspectors were concerned that the VOC found in some paints could be absorbed by charcoal in the SBGT system and lead to charcoal degradation. The licensee's procedure did not consider whether the SBGT system would be able to still perform its safety function in the event of an ;

accident. The licensee had not performed an actual quantitative analysis for various '

paints. The supervisor in charge of painting requested that engineering personnel review the job prior to painting the reactor building floor. Engineering personnel responded in a memo that the new paint had less VOCs; therefore, any amount of area could be painted provided that shift operations personnel were notified. The inspectors pointed out to the system engineer and health physics supervisor that the 1000 square feet area was a qualitative analysis not actually based on VOC content of the previous paint use The licensee contacted various utilities for their method of controlling painting and reviewed an industry document, "A Study on the Effects of Coating Operations on Radiciodine Removing Absorbents," presented at the twenty-first DOE /NRC Nuclear Air Cleaning Conference. The study prescribed how to calculate the impact on charcoal efficiency of VOCs on a known amount of charcoal with given air flow rates. The licensee subsequently performed calculations based on the study. The inspectors reviewed the calculations and found the analysis, as it applied to the licensee's SBGT system, to be thoroug The licensee also added several other administrative precautionary measures to be performed for painting activities. The painting was to be scheduled when no operation of the SBGT system was planned. Shift operations personnel were to be notified at the start of the painting activity. Personnel responsible for the painting were to ensure that the square footage painted did not exceed the system angineer's calculations (with conservative assumptions) and that painting stops if the SBGT system started. These requirements were documented in the operations department shift order c. Conclusions The licensee did not adequately consider the impact of planned painting of the reactor building floor on the SBGT system charcoal filters in the event the system automatically

initiated during accident conditions. The licensee's subsequent response to the inspectors' concerns regarding protection of the SBGT system from VOCs in the paint

! was appropriate. Conservative assumptions in the calculations and administrative l controls placed on the painting activities ensured adequate efficiency of the charcoal i

beds and operability of the SBGT system in the event of system initiatio l

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o IV. Plant Suonort

LR1 Radiological Protection and Chemistry Controls

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~ R1.1 Daily Radioloaical Work Practices -

a, Lngoection r Scope (71750)

The inspectors observed radiological worker practices during various maintenance activities detailed in this inspection report, and also monitored radiological practices-during daily plant tour b. Observations and Findinas Without exception, the inspectors observed that radiation protection technicians were active at job sites and were taking appropriate actions and surveys in accordance with good as-low-as-reasonably-achievable'(ALARA) practices. Na deficiencies were identifie c. Conclusions The inspectors concluded that radiological practices observed during maintenance j activities and daily walkdowns were goo F2 Status of Fire Protection Facilities and Equipment F Self-Contained Breathina Anoaratus (SCBA) Cylinder Found to Contain Nitronen a. Insoection Scope The inspectors reviewed the circumstances surrounding the licensee's identification of a SCBA cylinder that was filled with nitrogen. The inspectors conducted interviews with plant personnel, reviewed action requests, and attended a fact finding meetin b. Observations and Findinos On November 30,1998, an l&C technician performed the routine task of using ,

compressed air to clear debris from a condenser differential pressure transmitter lin The technician used a SCBA cylinder to accomplish the task. As the technician was {

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exiting the reactor building, health physics (HP) personnel questioned the technician regarding the SCBA cylinder use. (The HP department was responsible for maintaining and controlling the SCBA cylinders.) The technician explained that the cylinder was filled with nitrogen and used to clear instrument lines. At this point, the HP person took !

control of the cylinder and wrote AR 98-3090 to address the issue of having a SCBA cylinder, that was normally filled with breathing air, filled with nitrogen. Also, a fact finding meeting was held to determine the conditions that led to the issu i 14 l

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During the fact finding meeting, the licensee determined that for the past several years l&C technicians have used the SCBA cylinders to clear the pressure transmitter lines because of their small size and ease of use rather than using a larger nitrogen cylinde The SCBA cylinders were normally used for respiratory protection when entering oxygen deprived areas (e.g., inerted drywell or in response to a fire). In this case, an I&C technician needed more pressure to clear the instrument line so he returned to the 1&C shop and filled the SCBA tank with compressed nitroge Upon discovery, the licensee conservatively tested all the SCBA cylinders onsite to ensure each contained the appropriate amount of breathing air. As a result of the fact l finding meeting, l&C department personnel acquired alternative compressed air cylinders to clean instrument lines. Also, the licensee was conducting a root cause investigation to determine the facts surrounding this issue and the possible need for corrective action I Conclusions A questioning attitude by HP personnel led to the discovery of a SCBA cylinder which i contained compressed nitrogen instead of creathing air. The inspectors determined that, upon discovery, the licensee appropriately addressed the issue. The licensee conservatively tested each SCBA cylinder onsite to ensure each contained the appropriate amount of breathing air. Also, the licensee held a fact finding meeting and j initiated a root cause investigation to determine the facts surrounding the issue and the possible need for corrective action V. Manaaement Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on January 12,1999. 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 identifie G, ,

PARTIAL LIST OF PERSONS CONTACTED Licensee

' J. Franz, Vice President Nuclear G. Van Middlesworth, Plant Manager R. Anderson, Manager, Outage and Support J. Bjorseth, Maintenance Superintendent D. Curtland, Operations Manager R. Hite, Manager, Radiation Protection M. McDermott, Manager, Engineering K. Peveler, Manager, Regulatory Performance l

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k INSPECTION PROCEDURES USED IP 37551: Onsite Engineering -

IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing ,

Problems IP 61726: Surveillance Test Observation IP 62707: Maintenance Observation IP 71707: Plant Operations

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IP 71750: Plant Support i IP 92901: Followup - Operations ITEMS OPENED, CLOSED, AND DISCUSSED l Opened

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50-331/98015 -01 VIO Failure to verify component lead was visible beneath the solder contrary to procedures  :

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Closed  :

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50-331/97-004-00 LER MSL low reactor pressure isolation instrumentation not in agreement with the conservative direction of the numerical values l in TS l

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50-331/97-005-00 LER Setpoint for recirculation flow upscale rod block greater than TS i allowance i

50-331/98015 -01 VIO Failure to verify component lead was visible beneath the solde- I contrary to procedures Discussed None

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LIST OF ACRONYMS USED i ALARA As low as reasonably achievable i

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AOs' Auxiliary operator AR Action Request CFR Code of Federal Regulations CMAR Corrective Maintenance Action Request

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DAEC Duane Arnold Energy Center '

DRP Division of Reactor Projects >

GE General Electric -

gpm Gallon-per-minute HP Health physics HPCI High pressure coolant injection '

I&C instrument and calibration IP Inspection procedure ISI inservice inspection i

ISP instrument Setpoint Program ITS Improved Technical specifications LER Licensee Event Report LSSS Limiting safety system settings MlF Maintenance instruction form MSL Main steam line NRC Nuclear Regulatory Commission 01 Operating instruction PDR Public Document Room PSIG Pounds per square inch gauge QC Quality control RCIC Reactor core isolation cooling RG Regulatory Guide  ;

l SBGT Standby gas treatment system SCBA Self-contained breathing apparatus STP Surveillance Test Procedure TS Technical Specification

VDC Volts direct current l VIO Violation i

VOC Volatile organic compounds

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