ML20202G473
| ML20202G473 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 02/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20202G435 | List: |
| References | |
| 50-331-98-02, 50-331-98-2, NUDOCS 9802200137 | |
| Download: ML20202G473 (22) | |
See also: IR 05000331/1998002
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.- U. S. NUCLEAR REGULATORY COMMISSION
REGION lli
Docket No: 50 331
- Ucense No: DPR-49
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Report No: 50-331/98002(DRP)
' Licensee: IES Utilities Inc.
200 First Street S.E.
P. O. Box 351.
Cedar Rapids, IA 52406 0351
Facility: . Duane Amold Energy Center
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. Location: Palo, Iowa
Dates: December 23,1997 - February 4,1998
. Inspectors: C. Lipa, Senior Resident inspector
M. Kurth, Resident inspector
Approved by: R. D. Lanksbury, Chief
- Reactor Projects Branch 5
9002200137 990206
PDR ADOCK 05000331 ;
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EXECUTIVE SUMMARY
Duane Arnold Energy Center
NRC Inspection Report No. 50 331/98002(DRP)
This inspection report included resident inspectors' evaluation of aspects of licensee operations,
engineering, maintenance, and plant support.
Operations
l The conduct of operations continued to be professional, wit', appropriate focus on safety
- as demonstrated by prompt identification of emergent equipment issues and the well-
controlled power reduction on January 22,1998. (Section 01.1).
l * The inspectors and licensee identified three instances where the limiting condition for
operation was exceeded for primary containment isolation valves. This resulted in three
violations. The inspectors were concerned that several discussions were necessary with
licensee personnel before a review of th6 issue was initiated. The inspectors concluded
that the licensed took the appropriate action following identification of the issue.
(Section 01.2).
- Residual heat removal service water, eniergency service water, standby gas treatment,
and emergency diesel generator systems equipment was properly maintained.
Housekeeping within the plant was acceptable in most cases. (Section 02.1).
Maintenance
- The inspectors identifbd weak controls in the testing and installation of standby liquid
control .ystem squib valve explosion charges. Specifically, there were no formal controls
to ensure that TS requirements regarding charges coming from the same batch would be
adhered to. (Section M1.2).
- The licensee promptly resolved equipment issues that occurred during the inspection
period. Personnel from the maintenance and engineering departments provided good
support and exhibited good teamwork in resolong the issues. Additional efforts were
planned to reduce containment atmosphere monitor system leakage and prevent this
from continuing to be a recurring problem. (Section M2.1).
- Corrective acthn following identification of an incorrect o-ring in a safety related chiller
was inadequate. There was no action taken to determine cause or prevent recurrence of
another failure, A non cited Wolation was identified. (Section M1.3).
Enaineenno
e The licenseo identified four examples where current surveillance testing did not meet
current TS. These were identified during a thorough review as part of the conversion to
improved TSs. This was a non-cited violation. (Section E8.16).
- The inspectors identified that testing was performed on a safety related control building
chiller without a safety evaluation. A violation was identified. (Section E8.17).
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Plant tunnort
e Radiation protection personnel provideo good support during the traversing incore probe
replacement. (Gection R1.1)
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Resort Details l
Summary of Plant Status ;
The plant began this inspection period at 100 percent powe'. On December 24,1997, there was
a short power reduction for a control rod sequence exchange On January 22,1998, the plant
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was reduced to approximately 75 percent reactor power for several hours for quarterty main i
steam isolation valve testing. The plant was operated at approximately 100 percent for the !
remainder of the period.
I. Operations
01 Conduct of Operetiona
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01.1 General Con ..s(71707). l
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a. inanection Scone {
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The inspectors followed the guidance of inspection Procedure 71707 and conducted ;
frequent reviews of plant operations. This included observing routine control room {
activities, accompanying in plant opersbrs on daily rounds, reviewing system tegouts, j
attending shift tumovers and crew briefings, and performing panel walkdowns. ,
b,~ Observations and Findinas i
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The conduct of operations was professional. The inspectors observed strict use of - I
procedures and thorough shift tumovers. Emergent equipment issues were promptly !
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addressed and cv,xiuot of operations was appropriately focussed on safety, The
inspectors observed a routine power reduction on January 22,1998. The evoluti9n was -
well-controlled.
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c. Conclusions !
The inspectors ccncluded that conduct of operations continued to be professional, with _ !
appropriate focus on safety.
01.2. Umitina condition for operation (LCO) Exceeded for Well Water Containment Isolation
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Valves
a. Inspection Scope l
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The inspectors reviewed licensee corrective actions in response to inspection Followup
Item (IFI) 9600210. The inspectors had identified incorrect LCO durations when safety- i
related instrument air compressnrs were removed from service. The licenses
subsequently perfor ned a detailed evaluation per Action Request (AR) 971141. The - i
- 9 valuation concluded that LCO times had been exceeded for well water containment '
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- isolation valves, and the licensee submitted Licensee Event Repor1 (LER) 9713.
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b. Observations and Findinas
As discussed in inspection Report 50 331/96002, the inspectors identified that the
licensee used incorrect LCO duration when one of the safety related air compressors was
removed from service. The inspectors held several discussions with licensing and
engineering personnel before a detailed review was inillated in April 1997. The results of
the licensee's review and subsequent independent inspections by the inspectors are
detailed below.
The licensee's review of this issue identified that TS the LCO for inoperable containment
isolation valves had been exceeded. When one of the safety related air compressors
(lK 3 or IK-4) was removed from servim, two well water containment isolation valves
were rendered inoperable. The plant was designed with only one well water containment
isolation valve at each drywell penetration because the piping inside the drywell was a
closed system. This design is consistent with 10 CFR Part 50, Appendix A, Criterion 57.
Technical Specifications 3.7.B.1,3.7.B.2, and 3.7.B.3 address primary containment valve
operability requirements and applicable action statements. With one vf the wulwater
isolation valves (CV5704A, CV5704B, CV5718A, or CV57188) inoperable, the roquired
action was to initiate an orderly shutdown and be in at least hot shutdown within the next
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and colo shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee identified, in
LER 9713, one instance in January 1997 where IK 3 was out of service for 91.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />
(50-331/98002-01(DRP)). The inspectors identified two other Instances, in
January 1996, IK 4 was out of service for 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> (50-331/98002 02(DRP)), and in
April 1997, IK 3 was out of service for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> (50-331/98002 03(DRP)). The three
instances described above represented three violations of TS.
The licensee planned to submit a TS change and to consider design modifications to
enable longer allowed outage times when IK 3 or IK-4 is removed from service for
maintenance.
c. .Qonclusions
The inspectors and licensee identified three instances where the limiting condition for
operation was exceeded for primary containment isolation valves. This resulted in three
violations. The inspectors were concemed that several discussions were necessary with
licensee personnel before a review of the issue was initiated. The inspectors concluded
that the licensee took the appropriate action following identification of the issue.
02 Operational Status of Facilities and Equipment
02.1 General Plant Tours and System Walkdowns (71707)
a. Inspection Scope
The inspectors followed the guidance of Inspection Procedure 71707 in walking down
accessible portions of several systems:
Residual heat removal service water (RHRSW)
- Emergency service water (ESW)
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e Standby d;esel generators
e Standby gas treatment system
b. Observations and Findinas
Equipment operability and materiel condition were acceptable in all cases. Several minor
discrepancies were brought to the licensee's attention and were corrected. The
inspectors identified two instances where temporary equipment was tied off to r.onduits.
The licensee promptly corrected the two examples and initiated an AR to increase staff
awareness on appropriate methods of securing temporary equipment.
c. Conclusions
The inspectors conctuoed that plant equipment was properly maintained. Housekeeping
was acceptable in most cases.
02.2 Detailed Walkdown of Standby Llauld Control (SLC) System
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a. Inspection Scope (71707)
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During the inspection period, the inspectors followed the guidanco of Inspection
l Procedure 71707 and conducted a detailed walkdown of the standby lic;oid con'rol system
l to verify its standby readiness condition. The inspectors reviewed syatem diagrsms,
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Operating instruction (01) 153, * Standby Liquid Control System," the Updated Fhal Safety
Analyc's Report (UFSAR) description, surveillance tests, operator logs, and maintenance
history. Ti:e inspectors also observed a routine quarterly surveillance test.
b. Observations and Findinas .
The inspectors varified that the SLC system was properly lined up and that test results
were satisfactory. The inspectors identKed only minor discrepancies betweea the 01,
operator logs, and surveillance tesi .cceedure. The licensee initiated AR 980268 and
promptly resolvec the discrepancies,
c. Conclusions
The inspectors concluded that the licensee maintained the SLC system in the proper
standby readiness condition.
07 Quality Assurar;ce in Operationu
07.1 Licensee Self Assessment Activities (71707)
During the inspection period, the inspee'. ,rs reviewed multiple licensee self assessment
activilles, Inc.luding:
- Safety Committee Meeting
Action Request Screening Meetings
e Operations Com,witee Meeting
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The inspectors observed active participal'on by plant management in the review of AR,
6afety Evaluations, root cause reports, and other acilvities. One concem is discussed in
Section M1.3. In Pia! Instance, corrective actions were not adequate to prevent
recurrence of a failure of safety related equipment. The inspectors concluded that, in
general, plant management established sufficient guidance and oversight to ensure
strong self assessment, and effective identification and resolution of problems.
08 Miscellaneous Operations issues (92700)
08.1 (Closed) IFI 50431/95006 01: Licensee Failed to Enter Applicable LCOs for Surveillance
Testing. The inspectors did not identify any cases where LOOS were exceeded during
surveillance testing. The licensee recognized NRC's position that exceeding TS LCOs,
even for surveillance testing, would nat be acceptable. This issue was still under review
by the Office of Nuclear Reactor Regulation (NRA) (AIT 96-0278). This IFl is closed and
the issue will be tracked by AIT 96 0278.
08.2 (Closed) Violation (VIO) 50-431/95008-01: Incorrect Tagout Restoration of Containment
Atmosphere Dilution (CAD) System, The inspectors reviewed corrective actions
described in the response letter dated November 20,1995. The inspectors also reviewed
improvements to Administrative Control Procedure (ACP) 1410.5, "Tagout Procedure."
The revised ACP provides additional controls on tagout activit}es, such as restoration of
valve position. The ACP requires that the required clearance position be stated on the
tagout form prior to releasing the tagout for clearance. The inspectors considered the
corrective actions to be appropriate. This item is closed.
08.3 (Closed) IFl 50 331/95008-02: Rope Found in Suction for Fuel Pool Cooling Pump. The
licensee recovered the rope and performed a root cause analysis. The licensee
determined that the rope had been trapped in the system since prior to 1992. Corrective
actions were appropriate and the inspectors had rio further concems. This item is closed.
08.4 (Closed) IFl 50-331/96002-10: Incorrect LCO Time When Instrument Air Compressor
Removed From Service. This item is closed to a violation as discussed in Section 01.2.
08.5 (Closed) LER 50 331/96-05-00: Primary Containment isolation System (PCIS) Groups 3
and 5 Isolations. This occurred during a refueling outage. The licensee determined that
the likely cause was a voltage drop in a temporary power supply. This resulted in a loss
of power signal to logic for the Group 3 and 5 PCIS. The licensee reroved the temporary
power supply and restored normal source of power to the instrument AC systen prior to
plant start up. This item is closed.
08.6 (Closed) VIO 50-331/96005-01: Operating Procedure Deficiencies. The vidation
involved four examples of inadequate or deficient plant operating procedures. The
inspectors reviewed the corrective actions specified in the licensee's response letter,
dated September 27,1996. Each procedure was appropriately corrected. Additional
procedure deficiencies were identified during inspection 50-331/97006 and a violation
was cited (9700G-01a), item 96005-01 is closed. Corrective actions regarding prxedure
deficiencies will be reviewed during closure of Violation 50 331/97006-01a.
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08.7 (Closed) VIO 50-331/96007-01: Failure to Follow Procedure During a Tagout Activity.
The inspectors reviewed the corrective actions specified in the licensee's response letter,
dated February 21,1997. The corrective actions were appropriate. This item is closed.
08.8 (Closed) VIO 50 331/97004 01: Residual Heat Removal Operating instruction (01) Not
Followed. The inspectors reviewed the licensee's ccrrective actions, which included:
1) revising the Ol to clarify the expectation, and 2) operations management issued a
memo to operations personnel reinforcing procedural compliance expectations. This item
is closed.
08.9 (Closed) VIO 50-331/97004 02: Diesel Generator Cooling Valve Found Mispositioned.
The inspectors identified a repeat occurrence of Valve V32170 being out of position on
July 23,1996. The licensee determined that the likely cause was that the valve handle
was bumped during routine oil cleanup. The handles for V32170 and other similar
valves were removed to prevent recurrence. This item is closed.
08.10 (Closed) VIO 50 331/97004 03: Annunciator Response Procedure (ARP) Not Promptly
Corrected. The inspectors reviewed the implementation of the corrective actions
described in the licensee's response letter dated May 21,1997. The inspectors had no
further concerns. This item is closed.
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08.11 (Closed) VIO 50-331/97009-01: Inadequate Drywell spray Tagout. Plant management
reinforced expectations regarding preparation, installation, and removal of tagouts. The
inspectors considered corrective actions to be appropriate. This item is closed.
08.12 (Closed) VIO 50-331/97009-02: niver Water Selector Switch Found in Wrong Position.
The inspectors had identified this issue on May 12,1997. The licensee performed a root
cause analysis and implemented several corrective actions. The inspectors considered >
the corrective actions to be appropriate. This item Is closed,
ll. Maintenance
M1 Conduct of Maintenance
M1.1 General Comments
a. Inspection Scope (62707) (61726)
The inspectors observed or reviewed all or portions of the following work activities:
- Scram discharge volume high water level functional test, STP 3.3.1.109
e Daily instrument checks, STP 42A001
- Standby liquid control, squib valve testing, PMAR 1099750
- Standby liquid control flow test, STP 3.1.7-01
- Instrument air compressor IK-4 air dryer maintenance, CMAR A40268
- Traversing incore probe replacement
- Dynamic VOTES test on M01939, EMP-M01939/1940 DV
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e Sts.ndby gas treatment rough filter clean and inspect, PMAR 1102802
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e Standby liquid motor oil change, PMAR 1098488
, o Containment atmosphere monitor (CAM) system leakage walkdown,
STP 685007 CY
c. Conclusions
in general, the inspectors observed sound maintenknee practices, appropriate use of
procedures, and good coordination among departments. Concerns with corrective action
to prevent recurrence of a problem and controls over installation of squib valves are
discussed below.
M1.2 Weak Controls for Soulb Valve Exolosion Cheroe Testino and Installation
a. Inspection Scope (62707) -
The inspectors observed preventive maintenance action request (PMAR) 1099750. The
inspectors also reviewed other applicable documents, such as TS, UFSAR, maintenance
procedures, and surveillance test procedures.
b. Observations and Findinal
The inspectors identified that PMAR 109g750 required testing only one squib valve
explosion charge out of a batch of two charges. This was not consistent with
TS 4.4.A.2.b, which specifies that one of three charges from the same batch shall be
tested and the other two installed in the system. Through interviews, the inspectors
determined that the licensee had an extra explosion charge with a different manufacture
date in the warehouse that they planned to install during refueling outage (RFO) 15
(April 1998). The inspectors were concemed that theia were no formal controls in place
to ensure that the squib valve explosion charges installed during the upcoming RFO
would be from the same batch.
The inspectors verified that there was no present operability concem. The currently
installed valve charges were from the same batch as the charge that was tested in
preparation for RFO 14 (October 1996) and met TSs..
The licensee initiated AR 980263 and planned to correct the condition prior to RFO-15.
The licensee later found that the two different charges were from the same lot at the
manufacture and satisfied the TS requirement.
c. Conclusions
The inspectors identified weak controls in the testing and installation of SLC squib valve
explosion charges. Specifically, there were no formal controls to ensure that TS
requirements regarding charges coming from the same batch would be adhered to.
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M1.3 Inadeauale Corrective Actions for incorrect o-rina In Control %Mna Chiller
a. Inmotion Scope (62707)
The inspectors observed maintenance on the 'B' control building chiller on Decemb$r 2,
1997. The licensee had declared the chiller inoperable after identification of a signiticant
'olileak and promptly entered the approoriate LCO, The inspectors discussed the
apparent cause of the failure with the mechanical maintenance technicians in the field.
The technicians showed the inspectors a cut o-ring for the slide valve that they believed
was the wrong size and suspected to be the cause of the failure. -The incorrect o ring
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had been insta' led in August 1997. The licensee subsequently replaced the o-ring with
the correct size and initiated AR 972760. Approximately one month later, the inspectors
followed up to see what the licensee determined to be the cause of the failure and the
cause of the incorrect o ring.
b. Observations andfindinns
The inspectors identified that AR 972760 had been closed and that no followup had
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occurred to determins how the incorrect o-ring was installed. After discussion with plant
mana9ement, an addendum AR 972760.01 was initiated to determine when and how the
incorrect o-ring was installed on the chiller. The AR also assigned to the mainionance
department to initiate other corrective actions to prevent recurrence. The licensee also -
Initiated AR 980193 to review whether there was a possible break down in the normal -
corrective action process that allowed the original AR to be closed without appropriate
followup.
The failure to initiate corrective actions to prevent recurrence of the incorrect o rbg was a .
- violation of 10 CFR Part 50, Appendix B, Criterion XVI.- This was considered a minor
violation and is a non cited violation according to Section IV of the NRC Enforcement
Policy. (F0 331/98002-04(DRP)).
c. Conclualons
The inspectors concluded that licensee corrective actions were inadequate following
discovery of the incorrect o ring installation. There were no actions taken to prevent
recurrence of another failure.
'M2 - Maintenance and Materiel Condition of Facilities and Equipment
M2.1 Plant Materiel Conditiori
a.- Insoection Scope (62707)
The inspectors reviewed several emergent work items to ensure appropriate operability
evaluations were performed, TS were met, repairs were made, and root causes were
determined where appropriate.
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b. Observations and Findinas
The inspectors noted that there were several emement equipment issues during the
inspection period. The examples are listed below.-
- On January 12,1998, a temperature switch for the drywell equipment drain sump
failed. The scensee promptly er.tered a 24-hour LCO. The temperature switch
was promptly replaced the same day. (AR 980028)
- On January 17,1998, a *B" control building chiller trouble alarm was received in
the control room. The licensee entered a 30-day LCO. The cause was
determined to be a problem with the oil heater switch. The con)ponent was
repaired and the system tested satisfactorilylaterin the same day. (AR 980039)
e On January 22,1998, during a walkdown of the containment atmosphere monitor
(CAM) system (STP 685007-CY), the licensee identified a recurring problem with
leakage exceeding the allowable values in the STP. The licensee determined that
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there was no oparability concern for the CAM system or other systems that use
the same piping. Also, the system engineer determined that the adualleakage
was greater than the administrative ilmit sr.t in the STP, but was within the overall
containment allowable leakage. The licensee had plans in place to perform
modifications to prevent recurrence of leakage problems with this system.
(AR 961802 and 980053, CMAR A32615A, and A37048A)
declared inoperable when the system failed to pass routine surveillance test
STP 3.3.5.136. The licensee entered a 30-day LCO snd initiated repairs.
(AR 980286). Additional efforts were planned to reduce containment atmosphere
monitor system leakage and prevent this from continuing to be a recurring
problem.
t * On January 30,1998, during quarterly surveillance testing of the "B" core spray
f system, the minimum flow valve failed to open as expected. The licensee
promptly secured the pump and entered a seven-day LCO. Corrective
Maintenance Action Request (CMAR) A46905 was initiated and flow transmitter
FT2130 was re calibrated. The licensee's operability evaluation was approved by
the Operations Committee on February 1,1998, and the system was declared
c. Conclusions
The licensee promptly resolved equipment issues that occurred during the inspection
period. Personnel from the maintenance and engineering departments provided good
support and exhibited good teamwork in resolving the issues.
M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) IFl 60-331/95009-03: Plastic Shipping Plugs Installed in Transmitters. The
inspectors performed a walkdown of harsh environment areas during refueling outage 14
Ir, November 1996 and found no environmentally qualified transmitters with plastic plugs.
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The licensee subsequently revised transmitter calibra.lon procedures to require i
examination of plugs durin;; future calibrations and installation of new transmitters. The
procedures specified that metal plugs were to be installed if needed. The inspectors had ;
no further concems. This item is closed. '
M8.2 (Closed) 1.ER 50-331/96-03-00: Primary Containment Isolation System Groups 1 )
Through 5 lsolations Due to Reactor Protection System Elactrical Protection Assembly l
Breaker Trip on Under Voltage. The licensee was not able to determine the cause. i
Temporary instrumentation was installed to monitor for possible voltage fluctuations. I
Components in the power supply were inspected and replaced. The inspectors l
considered the corrective actions to be thorough. This item is closed.
M8.3 (Closed) Unresolved item (URI) 50 331/96004 03: PoorTroubleshooting Activities. The
inspectors reviewed corrective actions following two instances where data was lost during
troubleshooting activities. The first instance was the failure of installed monitoring
equipment to record data following a trip of the "B" reactor recirculation motor generator
(RRMG). The licensee determined that the trigger points were not properly armed due to
a personal error during set up of the equipment. Training was provided to personnel.
The second instance involved damage to a transformer during troubleshooting. The
licensee determined that incorrect values were used for applying load during testing of
the transformer. The licensoe also developed a guideline to address calling people in for
after hours maintenance and troubleshooting. The Inspectors considered the corrective
actions to be appropriale. This item is closed.
MS.4 (Closed) URI 50-331/96006-06: Engineered Maintenance Action (EMA) Process Errors.
The licensee identified two instances where the EMA process was not effective l-
ensuring documentation was updated following maintenance. The licensee corrected the
documentation. The inspectors performed a detailed review of changes to the EMA
process as discussed in Section E8.3. The additional controls in the EMA process were
considered appropriate. Thia, item is closed.
M8,5 (Closed) VIO 50-331/96007-03: Improper Tagout Doundary Established. The licensee's
root cause debrmined that several barriers broke down during this event. There was
also a misunderstanding regarding the scope of the work to be performed. The
inspectors verified that the corrective actions were appropriate. This item is cleted.
M8.6 (Closed) VIO 50-331/96007 04: Incorrect Test Equipment installation. The licensee
determined the cause to be an inadequate procedure in that there were no specific
details regudin;, the location to connect recorder leads. The procedure was revised to
include specific information on the installation of recoroer leads. This itsm is closed.
M8.7 (Closed) VIO 50-331/96007 0); Failure to Llow Procedure During Calibration of
Inverter. The control room received 125 Vdc trouble annunciators during a calibration
activity. Fuses, capacitors, and resistors were found damaged. The licensee determined
the cause to be that the technician failed to follow the procedure and failed to use the
latest change to the procedure. Corrective actions included replacing the damaged
components, providing remedial training to the technician, and providing verification
training to plant personnel. This Cem is closed.
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M8.8 (Closed) LER 50 331/96,0 % and (Closed) VIO 50-331/96007 01; High Pressure
Coolant injection (HPCI) Syn . - . Mon Due to Misplaced Relay Block. The licensee
determined the cause to be personnel error due to a break down in self checking and
dual verification. Meetings were held with all plant maintenance personnel following this
event to reinforce expectations. These items are closed.
M8.9 (Closed) IFl 50-331/96007-07: Reactor Core Isolation Cooling Flow Controller Concems. '
The licensee identified concems with the lasting of fiow controller FIC 2509. The
manufacturer recommended checking deviation meter movement during mode transf' of I
the controller from automatic to manual. Th9 calibration procedure was subsequently I
revised to ensure recommended testing is performed. The inpectors had no further I
concems. This item is closed.
Form (DCF) Not incorporated During Diesel Surveillance Test and Repeat DCF
Control Problem. There were several examples discussed in inspec*'". Reports
Nos. 50-331/96011 and 50-331/97007 regarding problems with control of DCFs. The
inspectors reviewed the licensee's corrective actions as described in the licensee's
response letters dated February 26,1997, and June 9,1997. Procedure ACP 106.3 was
revised to prcvide better control of DCFs. Other plant procedures were also revised to
reflect changes made to ACP 106.3. The inspectors had no further concems. These
items are closed.
M8.11 (Closed) VIO 50-331/96013-02: Use of Uncontrolled Documents During TS Surveillance
Testing. The violation listed two examples where incorrect data from uncontrolled
documents were used during surveillance testing. There was little safety significance
associated with the examples. The licensee corrected the data on the documents and
provided additional controls to ensure that data used during surveillance tests is
controlled or maintained on controlled documents. Additionally, the licensee reviewed
other surveillance tests where supporting documents were used. The licensee corrected
several other cases where uncontrolled documenh were used. The inspectors
considered the corrective actions to be thorough. This item is closed.
M8.12 (Closed) LER 60 97-02-00: Both Standby Gas Treatment (SBGT) Trains Inoperable Due
to Low Carbon Bed Efficiencies. This was the subject of a violation in Inspection Report
No. 50-331/97004, as discussed in Section MS.13, below. The inspectors verified that
appropriate corrective acticns were implemented. The inspectors had no further
concems. This item is closed.
MB.13 LQlgyd) VIO 50-331/97004-01: Incorrect Evaluation of SBGT Test Results. The
inspectors had raised a concem in this case with the licensee inappropriately rounding up
a value to meet the TS, The licensee subsequently declared the system inoperable,
restored the syrtem to full compliance with TS, and made changes to improve carbon
bed efficiency in the future. Additionally, as discussed in the licensee's response letter
dated May 21,1997, plant management reinforced expectations to all plant personnel
regarding procedural adherence and verbatim compliance with TS. The inspectors had
no further concems. This item is closed.
M8.11 (Closed) VIO 50-331/97004 05: Incorrect Equation in SBGT Surveillance Test Procedure
(STP). The licensee verified that the correct equation had been used to arrive at the
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values within the STP. The STP was subsequently revised. Addit:onally, plant
management reinforced procedural adherence expectations. Specifically addressed was
the need to stop and get the procedure corrected if it was found to be in error. The
inspectors had no further concems. This item is closed.
M8.15 iClosed) VIO 50 331/97007-01: Repeat Example of Incorrect ESW Acceptance Criteria.
The inspectors reviewed the licensees corrective actions as described in the licensee's
response letter dated June 9,1997. The licensee revised the surveillance test procedure
to record the data in the American Society of Mechanical Engineers (AGME) Data Book.
The inspectors have not. ldentified any similar Instances since the corrective action was
implemented. This item is closed.
M8.16 (Closed) VIO 50-331/97009-04: Failure to Spccify Post Maintenance Testing for
Ventilation Dampers. The inspectors reviewed the corrective actions specified in the
licensco's response letter dated July 28,1997. This included a quality assurance
department follow-up review to assess the effectiveness of the corrective actions. The
inspectors determined that the corrective actions were appropriate. This item is closed.
,
Ill. Enaineerina >
E1 Conduct of Engineering
a. Inspection Scope (37551)
The inspectors eveluated engineering involvement in resolution of emergent rNterial
condition problems and other routine activities. The inspectors reviewed areas such as
operability evaluations, root cause analyses, safety committees, and self assessments. *
The effectiveness of the licensee's controls for the identification, resolution, and
prevention of problems was also examined,
c. ,Q20 gly 3].qng
As discussed in Section M2.1, engineering personnel provided good support and
exhibited good teamwork with other departments in promptly resolving emergent
equipment issues. However, two concoms were noted. One violation was identified
regarding the failure to perform a safety evaluation prior to testing the control building
chiller, as discussed in Section E8.17. A non-cited violation was identified, as discussed
in Section M1.3 for inadequate corrective actions following identification of an incorrect o-
ring in a control building chiller.
E8 Miscellaneous Engineering lasues (92902)
E8.1 (Clo$ed) 1.ER 95-013-00 and 01: HPCI System inoperable Due to Water in Turbina
Steam Exhaust Line. The licensee's corrective actions described in the LER were
verified to be completed. In addition, a modification was performed in October 1996 to
prevent recurrence. The details of the originalissue and modification are currently under
review by NRR (AITS96-254, Revision 1). The issue will continue tu be tracked by
AITS96-254, Revision 1. This LER is closed.
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E8.2 (Closed) LER 50 331/96-0100.01. and 02: Core Average Control Rod Scram Time
'
Exceeding TS Limit. The licensee performed to:, ting in March 1996 in response to
industry operating experience regarding problems with Viton scram solenoid pilot valve
(SSPV) diaphragms. The condition was promptly corrected and a program to monitor
, degradation in response times was initiated. During the October 1996 refueling cutage,
the licensee replaced the Viton diaphragms with Buna N diaphragms. The licensee
planned to test a sample of SSPVs during the April 1998 outage to ensure continued
satisfactory operation of the Buna N diaphragms. Also, scram time testing will be
performed prior to start up as required by TS. This item is closed.
E8.3 (Closed) VIO 50 331/96002 07: Failure to Correct Weak Controls in EMA Process. The
inspectors reviewed the licensee's corrective actions as described in their resp >nse
letter, dated M6y 9,1996. Also, the current EMA process procedure, Administrative
<
Control Procedure 109.1, Revision 6, was reviewed to verify added controls. The
inspectors concluded that corrective actions were appropriate and had no further
concems. This item is closed.
E8.4 (Closed) IFl 50-331/96002 08: Inconsistency of Valve Closure Time in UFSAR. This item
iitvolved the licensee's position that the Update Final Safety Analysis Report (UFSAR)
values are considered " nominal design values." The inspectors reviewed this issue
further in inspection Report No,50 331/97006, Section M3.1, and identified several
additional discrepancies. The inspectors concluded that the failure to ensure design
acceptance criteria as described in the UFSAR were incorporated into surveillance testing
was a violation (50-331/97006-03(DRS)). This item (50 331/96002 08) is closed to the
violation cited in Inspection Report No. 50 331/97006.
E8.5 {C1gjed) URI 50-331/96003-01: Potential for Pressure Locking of Drywell Spray Valve.
'
The licensee's initial review of M01902 did not document the basis for operability. A
phone conf 6rence was held between the licensee, the NRC resident inspectors, and NRC
staff at the Office of Nuclear Reactor Regulation (NRR) on August 1,1996, to discuss the
inspectors' concoms. The licensee subsequently prepared a detailed engineering
evaluation that provided appropriate justification for operability. Also, the valve was
modified on October 27,1996, to relieve the potential pressure locking concem
(CMAR A23968). The inspectors had no further concems. This item is closed.
. E8.6 (Closed) VIO 50-331/96005 03: Inadequate 10 CFR 50.59 Safety Evaluation (SE) for
Emergency Service Water Make up to Spent Fuel Pool. The inspectors reviewed the
implementation and adequacy of corrective actions specified in the licensee's response
letter dated September 27,1996. The inspectors also reviewed revised SE 95-06,
Revision 1. The inspectors concluded that corrective actions were appropriate. This item
is closed.
E8.7 (Closed) URI 50-331/9601105: Configuration Control of Temporary Modifications (T M).
The inspectors reviewed other open and closed TMs and had no concems. The TM fom,
requires: 1) installation signature and verification; 2) removal signature and verification;
3) installation prerequisi'es, sequence constraints, and post-installation test requirements;
and 4) post removal test requirements. Procedure ACP 1410.6 contains adequate
controls of plant configuration. This item is closed.
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E8.8 (Closed) URI 50-331/96011-07; Drywell Seismic Monitor Design Temperature Exceeded.
The licensee identified this condition and took action to ensure design temperature would
not be exceeded in the future. The licensee plans a modification du,ing the next refueling
outage to install additional insulation and a cooling air duct for the monitor. The
inspectors determined that the UFSAR was correcl and the licensee took appropriate
action to restore the degradod equipment. This item is closed.
E8.9 (CJ81ed) URI 50 331/9501108: Implementation of 10 CFR 50.73 Reportability
Requirements. The licensee had already submitted " voluntary" LER 96 07, Revision 00,
regarding main steam safety valves that failed to meet TS setpoints. The inspectors
were concemed that an LER was required and was not voluntary. After further
discussions, the licensee reviewed the reportability practices of other plants. The
licensee determ!ned that the failures were reportable under 10 CFR 50.73(a)(2)(vil) and
issued Revision 01 to LER 96 07. Additionally, the licensee provided reportabil!!y training
to licensing personnel. The inspectors did not identify any other concems with the
licensee's reportability practices. This item is closed,
i
E8.10 {plosed) URI 50 331/97004 07: Use of * Nominal" Values for TS Setpoints. The
inspectors had identified that actualinstrument setpoints were not all on the preferred
side of the inequality sign glven in TS. The licensee promptly reviewed all TS instmments
and reset severalinstruments to ensure compliance with TS. A commitment letter was
submitted to the NRC on February 25,1997, which detailed tne licensee's plans to ensure
l continued compliance with the TS values. Final resolution of this issue will be addressed
'
in the improved Technical Specifications, which are currently with NRR for review. This
item is closed.
E8.11 (Closed) VIO $0-331/97004-08: Failure to Perform an SE When Cha.4 ") Room
Temperature for GLC System. The licensee subsequently performed a SE to document
the basis for the determination that no unreviewed safety question was involved. Also,
( the licensee revised their 10 CFR 50.59 process to ensure SEs are performed when
changes are made to the UFSAR. This item is closed.
E8.12 (Closed) LER 50 331/97-06-00; inadequate Functional Test of the HPCI System Steam
Leak Detection Time Delay. The surveillance test was revised and alllogic performed as
required when tested. This was part of the non-cited violation (NCV) discussed in
Sectien E8.16. This item is closed.
E8.13 (Closed) LER 50-331/97 07-00: Inadequate Test of Reactor Mode Switch to Shutdown
Position Rod Block Function and Rod Block Monitor. The inspectors verified that
corrective actions were completed and that the testing required by TS was satisfactorily
completed. This issue was part of a NCV as discussed in Section E8.16. This item is
closed.
EB.14 (Closed) VIO 50-331/97007-02: Residual Heas %moval Service Water (RHRSW)
Surveillance Test Not Consistent With Design Basis. The inspectors had identified that
the licensee closed a normally open back wash valve during this test. This prevented
accounting for diverted flow during quarterly surveillance testing. The licensee
determined that there was no operability concem after a review of pump performance
data. The STP was promptly revised to test the system correctly. This item is closed.
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E8.15 [Qlosed) LER 50 331/97-09-00: Inadequate Survelllance Testing of Reactor Water
Cleanup (RWCU) Area Differential Temperature Isolation Logic. The inspectors reviewed
corrective actions and virified that required testing was completed as required by TS.
This item was the subject of an NCV as discussed in Section E8.16. This item is closed.
E8.10 frosed) Unresolved item fURI) 50 331/97010-03: Inadequate TS Surveillance Test
identified During Licensee's improved TS Project. Inspection Report No. 50 331/97010
discusses three examples 2nd Inspection Repori No. 50-331/97012 discusses an
additional example. The fu.r examples were identified by the licensee as part of the
improved TS Project. The inspectors verified that, in each case, the sumeillance tests
were properly revised and performed satisfactorily as required. The licensee submitted
licensee event reports as required by 10 CFR 50.73. The failure of the surveillance tests
to adequately perform the testing required by TS was a violation. This non rnpetitive,
licensee-identified and correried violation is being treated as an NCV consistent with
Section Vll.B.1 of the NRC Enforcement Policy 30-331/98002 05(DRP)). This item is
closed.
E8.17 (Q sed) URI 50 331/97017 03: Testing on Control Building Chiller Without a Safety
Evaluation (SE). The inspectors reviewed the details of the chiller 100 percent load test
performed on November 19,1997. The licensee had used Tagout Number 971369 to fall
open a control valve in the heating loop in order to increase the heat in the control
building. The control building ventilation system serves the control room, cable spreading
room, safety related battery rooms, and essential switch gear rooms. The inspectors
were concerned that no safety evaluation was performed prior to the test to determine
what effect the testing could have on safety-related components within the control
building. Part 50.59 of 10 CFR required that a written safety evaluation be performed for
a test that is not described in the safety analysis report, and that the SE provides the
bases for the determination that the test does not involve en unreviewed safety question.
The failure to perform an SE in this case was a violation (50-331/98002 06(DRP)).
IV. Plant Supped
R1 Radiological Protection and Chemistry Controls
R11 Good Radiation Protection Support for Transversina incore Probt(TIP) Replacement
a. Inspection Scope f71750)
The inspectors reviewed the adequacy of radiological controls in accordance with
inspection Procedure 71750. This included observing radiological work practices
supporting the January 8,1998, TIP replacement.
b. Observations and Findinas
On January 8,1998, the inspectors observed portions of the *C" TIP replacement. The
inspectors observed radiation protection personnel providing good support during the
replacement process. Radiation protection personnelwere performing numerous
exposure rate surveys in the TIP toom and the surrounding area to ensure exposure rate
levels were not in excess of established limits. Upon removal of the "C" TIP, radiation
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protection personnel placed it and its cable in containers for transfer to the radweste
building. The inspectors noted good area controls by radiation protection personnel to
ensure no personnel would com3 in close proximity to the containers during their transfer
from the TIP room to the radwaste building,
c. Conclusions
Radiation protection personnel provided good support during the TIP replacement,
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V. Mananoment Meetinos
, a
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on February 4,1998. The licensee acknowledged the
findings presented.
The inspecte t asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee l
!
J. Franz, Vice President Nuclear
- G. Van Middlesworth, Plant Manager
. R. Anderson, Manager, Outage and Support
J. Bjorseth, Mair:tenance superintendent
D. Curtland, Operations Manager i
R. Hite, Manager, Radiation Protection !
M. McDermot, Manager, Engineering ,
K. Poveler, Manager, Regulatory Performance !
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. !
INSPECTlON PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observation
IP 62707: Mair,tenance Observation
IP 71707: Piant Operations
IP 71750: plant Support
IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Powu Reactor
Facilities
IP 92901: Followup Operetions
IP 92902: Fol!owup Engineering
IP 92903: Followup Maintenance
IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
ITEM 8 OPENED, CLO8ED, AND DISCUSSED
Opened
50-331/98002 01 NOV LCO time exceeded for well water containment isolation valves
50-331/98002 4 2 NOV LCO time exceeded for wsll water containment isolation valves
50 331/98002 03 NOV LCO time exceeded for well water containment isolation valves *
50-331/98002 04 NCV Inadequate corrective actions for incorrect o ring
50-331/98002 05 NCV inadequate TS surveillances
50 331/98002 06 NOV Testing on chiller without a safety evaluation
Closed
50 331/95006-01 IFl Licensee failed to enter applicable LCOs for surveillance testing
50 331/95006-01 VIO Incorrect tagout restoration of CAD system .
50-331/95006 02 IFl Rope in fuel pool cooling pump
50 331/95009-03 IFl Plastic shipping plugs installed in transmitters
50 331/95-13 00,01 LER- HPCI system inoperable due to water in turbine sieam exhauct line
50 331/96-01 00, LER Core average control rod scram time exceeding TS limit 01,02
50 331/96002 07 VIO Failure to correct weak controls in EMA process
50 331/96002-08 IFl Inconsistency of valve closure time in UFSAR
50 331/96002 10- IFl incorrect LCO time when instrument air compressor taken out of
service
50-331/96-03 00 LER PCIS Groups 1 through 5 isolations
50 331/96003-01 URI Potential for pressure locking of drywell spray volve
50 331/96-04-00 LER HPCI system isolation due to misplaced relay block
50-331/96004-03 URI Poor troubleshooting activities
.50 331/96-05-00 LER PCIS Groups 3 and 5 isolations
50-331/96005-01 VIO Operating procedure deficiencies
50-331/96005-03 VIO Inadequate 10 CFR 50,59 SE for emergency service water maka-
up to spent fuel pool
50 331/96006-06 URI EMA process errors
50 331/96007 01 VIO Failure to follow procedure during a tagout activity
50-331/96007-C3 VIO Improper tagout boundary established
50-331/96007-04 VIO Incorrect test equipment installation
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50-331/96007-05 VIO Failure to follow procedurm during calibration of inverier
50 331/96007 06 VIO HPCI system isolation due to misplaced relay block
50 331/96007-07 IFl Reactor core isolation cooling flow controller cor.cerns
50 331/96011 01 VIO DCF not incorporated during diesel surveillance test
50 331/96011 05 URI Configuration control of TMs
50 331/96011 07 URI Drywell seismic monitor design temperature exceeded
50-331/96011 08 URI implementation of 10 CFR 50.73 reportability requirements
50 331/96013-02 VIO Use of uncontrolled documents during TS surveillance testing
50 331/97-02 00 LER Both SBGT trains Inoperable due to low carbon bed efficiencies
50 331/97004 01 VIO Residual heat removal Ol not followed
50 331/97004 02 VIO Diesel generator cooling vaive found mispositioned
50 331/97004 03 VIO ARP not promptly corrected
50-331/97004 04 VIO incorrect evaluation of SBGT test results
50-331/97004 05 VIO Incorrect equation in SBGT STP
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50 331/97004-07 URI Use of " nominal" values for TS setpoints
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50 331/97004-08 VIO Failure to perform an SE when changing room temperature for SLC
system
,
50-331/97 06-00 LER Inadequate functional test of the HPCI system steam leak detection
I time delay
50-331/97 07 00 LER inadequate test of reactor mode switch to shutdown position
50-331/97007 01 VIO Repeat example of incorrect ESW acceptance criteria
50 331/97007 02 VIO RHRSW surveillance test on consistent with design basis
50-331/97007 03 VIO Repeat DCF control problem
50-331/97-09-00 LER inadequate surveillance testing of RWCU area differential
temperature isolation logic
50 331/97009 01 VIO Inadequate drywell spray tagout
50-331/97009-02 VIO River water selector switch found in wrong position
l.
i 50 331/97009 04 VIO Failure to specify post maintenance testing
50 331/97010 03 URI Inadequate TS surveillance tests identified during licensee's ITS
project
50 331/97017-03 URI Testing or' control building chiller without a sa fety evaluation
50-331/98002-04 NCV Inadequate corrective actions for incorrect o-ring
50-331/98002-05 NCV Inadequate TS surveillances
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LIST OF ACRONYMS USED
ACP Administrative Control Procedure
AR - Action Request
ARP Annunciator Response Procedure
ASME American Socir' ,. Aechanical Engineers
CAD Containment atmosphere dilution
CAM Con'ainment atmosphere monitor
CFR Coda of Federal Regulations
CMAR Corrective Maintenance Action Request
DAEC Duane Amold Energy Center
DCF Document change form
EMA Engineered maintenance action
ESW Emergency service water
.HPCI High Pressure Coolant injection
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IFl Inspection followup item
IP inspection procedure ,
IR ' Inspection report
LCO - Limiting Condition for Operation
LER Licensee Event Report
, NCV Non-cited violation
NOV Notice of vlotation
NRC. Nuclear Regulatory Commission
NRR Office of Nuclear R; actor Regulation
01 Operating Instruction .
9
PCIS Primary containment isolation sy tem
PMAR Preventive maintenance action request
RFO Refuel Outage
RHRSW Residual heat removal service water
RRMG Reactor recirculation motor generator
SAR' Safety analysis report
SBDG Standby diesel generator
SBGT Standby gas treatment system
SE Safety evaluation
SLC S'andby liquid control
SSPV Leam solenold pilot valve
STP Surveillance Test Procedure-
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TIP Traversing incore probe
TS Technical Specification.
UFSAR Updated Final Safety Analysis Report
URI Unresolved item
VIO Violation
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