05000331/LER-2005-003

LER-2005-003,

Docket Number
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
Initial Reporting
3312005003R00 - NRC Website

FACILITY NAME (1)r DOCKET NUMBER (2)r -

• r LER NUMBER (6 PAGE (3) Duane Arnold Energy Center 05000331

I. Description of Event:

In 1999, the Duane Arnold Energy Center (DAEC) modified procedures to allow Scram Time Testing during the performance of the Class 1 leak tests. This change was implemented after a multi-disciplined team (Solutions Team) reviewed industry operating experience and various TS LCOs. Specifically, the Solutions Team was formed based upon industry _experience that other Boiling Water Reactors (BWRs) were performing Scram Time Testing during leak testing. The Solutions Team evaluated the-TS-require-mbritS—and concluded that""" the use of various Special Operations LCOs would be needed to allow concurrent testing.

The team concluded that TSs had no restrictions as to the number or combination of Special Operations LCOs that could be entered simultaneously. Procedures were subsequently modified to adopt this industry practice.

The specific procedure changes to support scram time testing during leak testing were associated with the Surveillance Test Procedure (STP) 3.10.1-01, "Non-Nuclear Heat Class 1 System Leakage Pressure Tests," and STP 3.10.1-02, "Non-Nuclear Heat Class 1 Ten Year System Leakage Pressure Test." A 10 CFR 50.59 screening was performed in 1999 for the procedure changes that were made to STPs 3.10.1-01 and STP 3.10.1-02. In that screening, it was concluded that the procedure changes did not require a change to the Technical Specifications. Part of the procedure changes associated with the screening added steps to hold the reactor pressure at 850-950 pounds per square inch gauge (psig) after the completion of the reactor system hydrostatic test and the Visual Test (VT) - 2 inspections to allow performance of Scram Time Testing.

Subsequent to these procedure changes, scram time testing was performed in the four refueling outages between 1999 and 2005. During each performance of scram time testing, the vessel hydro conditions were extended past the VT-2 inspections performed for the vessel hydro to allow for completion of the scram time testing.

II. AssTiTifigiitZUSafety-Consequences:-- _ This report is being submitted pursuant to 10CFR50.73(a)(2)(i)(B).

This event did not affect the availability of other systems needed to maintain safe shutdown conditions, remove residual heat, control the release of radioactive material, or mitigate the consequences of an accident.

Therefore, there were no actual safety consequences associated with this event. There was no effect on public health and safety as a result of this event.

This event did not result in a Safety System Functional Failure.

III. Cause of Event:

The cause of this event was the failure to recognize that the changes made to allow for Scram Time Testing under extended vessel hydro conditions were contrary to TS.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Duane Arnold Energy Center 05000331 NUMBER� NUMBER

IV. Corrective Actions:

On July 22, 2005, STPs 3.10.1-01 and 3.10.1-02 were quarantined to prevent scram time testing during vessel hydro.

DAEC will submit a plant-specific license amendment reCluest to implement TSTF-484;-"Uie-off TS 3.10.1 for Scram Time Testing activities," after approval by NRC. This action is anticipated to be completed by March 1, 2006.

EIIS System and Component Codes:

N/A — There were no component failures.

V. Additional Information:

Previous Similar Occurrences:

A review of LERs at the DAEC over the last 3 years identified the following LERs with similar events.

Cooling Mode to Low Pressure Coolant Injection Standby Readiness During Reactor Startup.

Locked in Refuel Position During Control Rod Movement as Required by Technical Specifications.

Specification 3.0.4.