IR 05000331/1997007

Insp Rept 50-331/97-07 on 970318-0425.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20141D737
Person / Time
Site:	Duane Arnold
Issue date:	05/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141D700	List: IR 05000331/1997007 ML20141D695 ML20141D718 ML20141D737
References
50-331-97-07, 50-331-97-7, NUDOCS 9705200186
Preceding documents:	ML20149E646 (10 July 1997)
Download: ML20141D737 (12)

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U. S. NUCLEAR REGULATORY COMMISSION

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

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Report N /97007

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Licensee: IES Utilities In First Street S.E.

l P. O. Box 351 Cedar Rapids, IA 52406-0351

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{ Facility: Duane Arnold Energy Center i

) Dates: March 18,1997 - April 25,1997

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inspectors: K. Riemer, Senior Resident inspector

C. Lipa, Resident inspector Approved by: M. Jordan, Chief Reactor Projects Branch 5 l

J D ADO 050 331 0 PDR j

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EXECUTIVE SUMMARY

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Duane Arnold Energy Center

! NRC inspection Report 50-331/97007 l

l This inspection report included resident inspectors' evaluation of aspects of licensee

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operations, engineering, maintenance, and plant support. The inspectors identified j examples of weaknesses in the areas of test control and corrective action ! Ooerations i

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e The inspectors concluded that the startup was well controlled and conducted in a l

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slow and conservative manner. (Section 01.2)

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l e The inspectors identified examples of weak scaffolding control, including, storage !

I of scaffold materials, erection of the scaffold, and subsequent operations l department walkdown of the scaffold. (Section 02.2)

l Maintenance

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e The inspectors identified that the test procedure for RHR service water was i inadequate in that it was not consistent with the design basis. This constituted a i violation. (Section M3.1)

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j e The i;censee identified a repeat occurrence of the use of incorrect acceptance

criteria during daily surveillances. This was an example of a violation. (Section

M1.2)

e The licensee identified that a document change form (DCF) was not incorporated during an instrument calibration surveillance test. As a result, instruments were left ;

outside the as-left acceptance criteria. This was a repeat example of problems with l control of DCFs and was an example of a violation. (Section M3.2)

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j e The inspectors considered that engineering support was effective in identifying a j degraded condition on the RHRSW pump before pump operability was affected.

Also maintenance and engineering coordinated effectively to promptly replace the

! pump. (Section E2.1)

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e The ingactors identified one example where turnover between firewatches was inadequue (Section F1.1)

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Report Details Summary of Plant Status

The plant was in a hot shutdown condition at the beginning of the inspection period due to leakage from a drywell cooler. The plant was returned to full power on March 22,199 '

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With the exception of a scheduled downpower evolution for turbine valve testing, the plant

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operated at approximately 100 percent power for the remainder of the inspection perio . Operations 01 Conduct of Operations 01.1 General Comments (71707)

The inspectors conducted frequent reviews of plant operations. This included observing routine control room activities, accompanying in-plant operators on daily rounds, attending shift turnovers and crew briefings, and performing panel walkdowns. The conduct of operations was generally considered to be professional. One example of operator error during surveillance testing is discussed in Section M1.2. Other observations are detailed in the sections below.

l 01.2 Reactor Plant Startup From Maintenance Outage inspection Scone On March 14,1997, the licensee performed a plant shutdown to correct a high drywell leakap: ets concern. The high rate was caused by a well water leak from a drywell caoler (reference NRC IR 50-331/97004). The licensee commenced a reactor startup on March 18,1997; the inspectors observed in-plant and control room startup activitie Observations and Findinas The inspectors observed the following during the startup: effective shift management oversight of the activities, formal communications between operators, and strict procedural adherence. The inspectors did obsen.*e minor discrepancies between the operating crews during the conduct of the reactor startup. For example, one crew controlled pressure set adjustments in a more formal manner than did the following crew. Also, not all crews consistently cal!cd out the receipt of expected annunciators. The inspectors had no substard e concerns with the crew differences but noted that they did not always matt.. operations management stated expectations. The inspectors discussed their observations with operations managemen _ _ . . .

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. . Conclusions Overall, the inspectors concluded that the startup was well controlled and conducted in a slow and conservative manne Operational Status of Facilities and Equipment 02.1 Enoineered Safety Feature System Walkdowns (71707)

i The inspectors used inspection Procedure 71707 to walk down accessible portions l of the following ESF systems:

l e control building chillers e high pressure coolant injection (HPCI)

e standby diesel generators (SBDG)

e reactor core isolation cooling system (RCIC)

e residual heat removal (RHR) system o RHR service water (HHRSW)

e emergency service water (ESW)

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Equipment operability, material condition, and housekeeping were acceptabl Several minor discrepancies were brought to the licensee's attention and were corrected. The inspectors identified concerns with scaffolding installation and storage as discussed belo .2 Scaffoldina in Contact With Safetv-Related Eauinment l Observations and Findinas On March 31,1997, the inspectors identified that scaffolding erected to support maintenance activities in the standby diesel generator (SBDG) was in direct contact with panel 1C 93 (1G-31 load control panel). A horizontal scaffold brace had scratched the paint on the back side of the panel. The inspectors reviewed

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administrative control procedure (ACP) 1408.2, " Scaffold Control," and concluded that no procedural violation existed. The inspectors, however, discussed with operations management their concern for the potential impact to the panel from

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scaffold movement. The licensee corrected the situation and inspectors verified

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that the scaffolding was no longer in contact with the pane Subsequent to the inspectors' initial identification of the matter the ingnactors l observed scaffolding in contact with the back of the same panel on April 9,1997.

l The inspectors again discussed the issua with operations management and verified l that the situation was corrected.

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On April 8, the inspectors identified a concern with the licensee's scaffolding storage in the Torus basement area. Specifically, stored ladder brackets were in j contact with safety-related Torus level instrument tubing (LT 4397A and B). The

condition was corrected after discussion with operations management.

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Conclusions

! The inspectors did not identify any specific operability concerns as a result of the i

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scaffolding concerns discussed above, and the inspectors determined that a procedural violation did not occur. However, the inspectors concluded that the

{ erection of the scaffold, and subsequent operations department walkdown of the scarfold, were examples of weak scaffolding control.

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07 QuaNty Assurance in Operations l 07.1 Licensee Self-Assessment Activities

! During the inspection period, the inspectors reviewed multiple licensee self-l assessment activities, including:

i j e Action Request Screening Panels l

e Monthly Safety Committee Meeting j e Monthly Quality Assurance Audit Exit j e Operations Committee Meetings .

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! The inspectors observed active management participation and concluded that the j self-assessment activities observed were effective.

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j 08 Miscellaneous Operations issues f 92700)

08.1 (Closed) Licensee Event Report (LER) 50-331/94-07-00: Residual Heat Removal

(RHR) System Shutdown Cooling isolation. On May 29,1994, while lining up

! shutdown cooling, an isolation of the system occurred. The cause was reported to be a pressure surge in the "B" reactor recirculation pump suction piping as a result of opening the shutdown cooling isolation valve. Changes were made to Operating Instruction 149, "RHR System," to prevent recurrence. No additional shutdown  !

cooling isolations have occurred since May 1994. The licensee plans to perform a !

modification to provide a more permanent resolution to this issue, s;nce this is currently considered an operator work around (Action Request (AR) 940066.05).

The inspectors had no further concerns. This item is close .2 (Closed) LER 50-331/95-04-00: Inadvertent Group 3 Isolations from invalid Signals. The inspectors verified that appropriate corrective actions were  ;

implemented. There was no violation of NRC Regulations. This item is close .3 (Closed) Violation 50-331/96013-03: Main Steam Line Radiation Monitors Not Set Per TS. The inspectors reviewed the licensee's response letter dated April 4,1997, and verified that corrective actions were implemented. This item is close .4 (Closed) LER 50-331/97-01-00: Failure to Comply with TS for Main Steam Line Radiation Monitors. This NRC identified issue was the subject of a violation in inspection Report 50-331/96013. The inspectors had no further concerns. This item is close !

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11. Maintenance l M1 Conduct of Maintenance l

M1.1 General Comments Insoection Scone (62703. 61726)

The inspectors observed or reviewed all or portions of the following work activities: l e Group i primary containment isolation logic test e RHRSW quarterly surveillance c RHRSW pump replacement  ;

• Safety related air compressor replacement e Reactor recirculation Inbe oil pump repair ' Observations and Findinas As discussed below and in Section M3, the inspectors were concerned with several examples of problems with test contro M1.2 Reoeat Examole of incorrect Accentance Criteria Used for ESW Temneratures

insoection Scone (40500. 61726) '

During a daily surveillance on April 8,1997, the licenses identified that incorrect acceptance criteria had been used since February 9,1997. The licensee initiated AR 971061. The inspectors reviewed this issue and the similarity to another issue ;

identified on December 8199 ! Observations and Findinas On April 8,1997, operators performing STP 42A001, " Daily instrument Checks,"

identified that incorrect ESW temperature acceptance criteria had been used since February 9,1997. Apparently, an operator documented the incorrect value in STP 42A001 on February 9,1997, and this incorrect value had been copied daily into the STPs until identification on April 8,199 As discussed in inspection Report (IR) 50-331/96011, incorrect acceptance criteria for ESW temperature had been used from October 25 until December 8,1996. The licensee's practice prior to December 8 had been to record the ESW temperature acceptance criteria on an uncontrolled document in the control room. After the December 8,1996, finding, operations management directed that operators stop using the uncontrolled document and instead, copy the acceptance criteria from surveillance to surveillanc The use of incorrect acceptance criteria from October 25 until December 8,1996, was cited as a violation in IR 50-331/96013. The licensee's response to the

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violation discussed corrective actions to prevent recurrence; however, the actions l- did not prevent the use of the incorrect acceptance criteria from February 9 until April 8,1997, Conclusions ,

L , The licensee's corrective actions for the use of incorrect acceptance criteria in l December 1998 were ineffective in that incorrect acceptance criteria were again

! used from February 9 until April 8,1997. This is considered a violation of 10 CFR Part 50, Appendix 8, Criterion XVI. (50-331/97007-01)

l M3 Maintenance Procedures and Documentation l l- j M3.1 RHRSW Surveillance Testing Discrenancy ' Inspection Scone (62703)  ;

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The inspectors observed the performance of surveillance test procedure (STP) l 45C001-0, "RHR Service Water Operability Test," Revision 8 on March 31,199 The inspectors reviewed the surveillance in detail, including, TS requirements, TS bases, Operating Instructions, and test results.

' Obrarvations and Findinos l The inspectors identified a discrepancy between the surveillance test line-up and the design basis. An analysis was performed in 1983 to reduce the TS required flow rate from 2400 gallons per minute (gpm) to 2040 gpm. The analysis assumed the flow rate of 2040 gpm was delivered to the RHR heat exchanger. During surveillance testing per STP 45C001-0 on March 31, the licensee closed the normally open RHRSW continuous strainer backwash valve before taking the

required pressure and flow readings. Closing the backwash valve prior to i

demonstrating adequate flow rate did not test the most limiting case. By design, the backwash flow rate was apgoximately 200 gp !

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ln rer,ponse to the inspectors' concerns, the licensee initiated AR 971037 and performed an operability evaluation. Using actual test results, the licensee demonstrated that there was sufficient margin to support design basis flow rate to l the heat exchanger with the backwash valve open. The licensee also initiated Document Change Form 97-T-0098, which revised the STP steps to ensure the backwash valve was in the normally open position prior to demonstrating the TS

required flow rate for future testing.

I Conclusions Although there were no operability concerns, the inspectors were concerned that

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the test procedure was inadequate. The inspectors concluded that corrective actions were appropriate. This constituted a violation of 10 CFR Part 50, Appendix B, Criterion XI. (50-331/97007-02).

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M'*.2 incorrect Accentance Criteria Used Due to Document Chanae Form (DCF) Not

incoroorated Durina Surveillance Insnection Scone i

On April 10,1997, the licensee identified that changes made to the main steam j low pressure switches STP by a DCF were not incorporated prior to performance of i' the STP on March 25,1997. This was documented on AR 971137. The inspectors reviewed this issue and the corrective actions for other recent problems i

with control of DCFs.

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Qhgervations and Findinas i

On February 23,1997,in response to NRC concerns regarding instrument setpoint j values (reference IR 50-331/97004), the licensee issued a DCF to revise l acceptance criteria and as-left values for main steam low pressure instrumentation

calibrated per STP 42A003-0. When the STP was performed on March 25,1997, the DCF was not in the test package and, therefore, the old acceptance criteria

, were used. As a result, all four pressure switches were left outside of the new

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acceptance criteria. The licensee documented that the switches were operable l because they were within the allowable values. The instruments were promptly

reset to the new acceptance criteria on April 11,199 ;

The inspectors were concerned with this issue because of the . similarity to other l

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recent problems with control of DCFs. See irs 50-331/96-06, l 96-07, and 96011 for details. in the licensee's response to the violation in IR 50- ,

, 331/96011, corrective actions were discussed that were expected to prevent !

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recurrence of further problems with DCFs. The corrective actions are considered

ineffective in that this additional example occurred on March 25,1997.

! Conclusions The inspectors were concerned that control of documents change forms continues i to be a challenge at Duane Arnold Energy Center. The failure of the test package i performed on March 25,1997, to incorporate the new acceptance criteria was 1 considered an example of a violation of 10 CFR Part 50, Appendix B, Criterion XVI (50-331/97007-03).

111 Enaineerina E2 Engineering Support of Facilities and Equipment Insoection Scoon (37551)

The inspectors evaluated engineering involvement in resolution of emergent material condition problems and other routine activities. The inspectors reviewed areas such as operability evaluations, root cause analyses, safety committees, and self

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l assessments. The effectiveness of the licensee's controls for the identification, resolution, and prevention of problems was also examined.

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E2.1 increase in Vibration Levels on "A" RHRSW Pumo l

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On April 4,1997, during review of test results from STP 45 COO 1-0, "RHRSW

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Operability Test," engineering identified increased vibration on the "A" RHRSW l pump. Although the vibration values met the acceptance criteria, engineering recommended prompt pump replacement. The inspectors reviewed current and

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past test results for this pump and observed the pump replacemen Observations and Findings On April 4,1997, during final review of test results from the STP performed on l March 31,1997, engineering identified an increase in vibration levels on the "A"

RHRSW pump. Engineering characterized this as an acute rubbing or looseness condition developing on the pump. Operations considered the pump inoperable and entered a 30-day LCO.

On April 9, the "A" RHRSW pump was replaced with a rebui!t spare. The l inspectors observed that the pump replacement was well coordinated betweeh operations, maintenance, and engineering. (Weaknesses identified with the post-installation testing are discussed in IR 50-331/96006.)

i On April 11,1997, testing of the new pump showed higher than expected vibration l

levels. Engineering obtained additional vibration data and concluded that the high l

vibration was possibly due to storage of the pump in a horizontal position in the warehouse for over a year. Engineering performed en operability evaluation for

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Operations and the LCO was canceled on April 18. h new pump was considered j to be in " alert" and increased testing was scheduled. Weekly testing of the pump ]

showed that the vibration appeared to be trending down, indicating improvement  !

over time, consistent with the licensee's operability evaluatio I Conclus' ions

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l The inspectors considered that engineering support was effective in identifying a !

l degraded condition before pump operability was affected. Also maintenance and l engineering coordinated effectively to promptly replace the pump. The inspectors j l planned to review the licensee's root cause analysis for the increase in vibration -

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inspection Follow-up Item (50-331/97007-04).

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I IV Plant Suncort F1 Control of Fire Protection Activities F Inadeauate Turnover Between Fire Watches Inspection Scone (71750)

l . During plant tours and observations of maintenance activities, the inspectors l examined fire barriers, emergency lighting, and control of flammable materials. The j inspectors identified a concern with the turnover between two firewatche Observations and Findings On April 15,1997, during plant tours, the inspectors observed a person performing the required 30-minute firewatch following hot work. When the inspectors questioned the individual on the nature and location of the hot work that had been

performed, the individual stated that there had been a grinding activity, but he could not identify the location. The inspectors discussed this concern with maintenance supervision who indicated that the firewatch had relieved another 1 firewatch who had been there during the grinding activity. Maintenance supervision l agreed that the firewatch turnover was inadequat In response to the inspector's concerns, the licensee initiated changes to Administrative Control Procedure 1412.3, " Control of ignition Sources," to include specific requirements for briefings to relieving firewatches.

l Conclusions The inspectors were concerned with the inadequate turnover between the firewatches. The licensee's corrective actions were considered appropriat V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on April 25,1997. The licensee acknowledged the findings presented.

l 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 j PARTIAL LIST OF PERSONS CONTACTED

Licensee J. Franz, Vice President Nuclear G. Van Middlesworth, Plant Manager R. Anderson, Manager, Outage and Support i P. Bessette, Manager, Engineering

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J. Bjorseth, Maintenance Superintendent D. Curtland, Operations Manager K. Peveler, Manager, Regulatory Performance i

INSPECTION PROCEDURES USED IP 37551: Onsite Engineering

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

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Preventing Problems IP 61726: Surveillance Observation l IP 62703: Maintenance Observation I IP 62707: Maintenance Observation 1 IP 71707: Plant Operations IP 71750: Plant Support l IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power j Reactor Facilities

! IP 92901: Followup - Operations IP 92902: Followup - Engineering IP 92903: Followup - Maintenance ITEMS OPENED AND CLOSED Opened l

50-331/97007-01 NOV Repeat Example of Incorrect ESW Acceptance Criteria 50-331/97007-02 NOV RHRSW STP Not Consistent With Design Basis  !

50-331/97007-03 NOV Repeat Occurrence Of Problem With DCF Control - Incorrect I Acceptance Criteria for Main Steam Low Pressure Swi'.ches l 50-331/97007-03 IFl Increased Vibration on "A" RHRSW Pump Closed l

50-331/94007 LER RHR System Shutdown Cooling Isolation

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50-331/95004 LER Inadvertent Group 3 Isolations From invalid Signals 50-331/96013-03 VIO Main Steam Line Radiation Monitors Not Set Per TS 50-331/97001 LER Failure to Comply with TS for Main Steam Line Radiation Monitors

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! LIST OF ACRONYMS USED

ACP Administrative Control Procedure .

AR Action Request i CFR Code of Federal Regulations  !

DAEC Duane Arnold Energy Center DCF Document change form ESW Emergency service water GPM Gallons per minute I HPCI High Pressure Coolant injection  ;

IFl Inspection followup item  !

lR inspection report 1

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LCO Limiting Condition for Operation i LER Licensee Event Report NOV Notice of Violation NRC Nuclear Regulatory Commission PDR Public document room RCIC Reactor Core isolation Cooling RHR Residual heat removal RHRSW Residual heat removal service water SBDG Standby diesel generator STP Surveillance Test Procedure TS Technical Specification  ;

UFSAR Updated Final Safety Analysis Report i

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