ML17229B529

Forwards Response to Violations Noted in Insp Rept 50-331/96-04.Corrective Actions:Action Request 960844 Initiated to Address to Inspector Concern

ML17229B529
Person / Time
Site:	Duane Arnold
Issue date:	07/29/1996
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NG-96-1525, NUDOCS 9608270103
Download: ML17229B529 (5)

Text

CATEGORY j.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:9608270103 DOC.DATE: 96/07/29 NOTARIZED: NO DOCKET I ACIL:50-331 Duane Arnold Energy Center, Iowa Electric Light a Pow 05000331 AUTH. NAME AUTHOR AFFILIATION FRANZ,J.F. IES Utilities Inc., (formerly Iowa Electric Light & Power C RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to NRC ltr re violations noted in insp rept 50-331/96-04.C/A:on 960517 action request 960844 was initiated to address to inspector concern.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: E RECIPIENT COPIES RECIPIENT COPIES 6 ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-3 PD 1 1 KELLYiG. 1 1 0 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEOD/ 1 1 DEDRO 1 1 NTER 1 1 NRR/DISP/P1PB 1 1 FB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN3 FILE 01 1 1 ERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 D 0

E N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE CONTACT THE DOCUMENT CONTROL DESKS ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

IES Utilities Inc.

200 First Street S,E.

PO. Box 351 Cedar Rapids. IA 52406.0351 Telephone 319 398 8162 Fax 319 398 8192 UTILITIES John F. Franz, Jr.

~/iCe PreSident. NVC'ear July 29, 1996 NG-96-1525 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P 1-37 Washington, D.C. 20555-0001

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Reply to a Notice of Violation Transmitted with Inspection Report 96004 File: A-105, A-102

Dear Sir:

This letter and attachment are provided in response to the Notice of Violation transmitted with NRC Inspection Report 96004.

This letter contains no new commitments.

Ifyou have any questions regarding this matter, please contact my office.

Sincerely, hnF. F anz Vice President, Nuclear

Attachment:

Reply to a Notice of Violation Transmitted with Inspection Report 96004 cc: R. Murrell L. Liu G. Kelly (NRC-NRR)

H. Miller (Region III)

NRC Resident Office

>I j DOCU

'stb08270i03 9b0729 PDR ADOCK 0500033i 8 PDR

~n lES tnovstnes Company

Attachment to NG-96-1525 Page 1of2 IES Utilities Inc.

Reply to a Notice of Violation Transmitted with Inspection Report 96004 VIOLATION Technical Specification (TS) 6.8.1 requires that written procedures covering areas such as corrective maintenance be implemented. Maintenance Directive (MD) 020, "Maintenance Planning," Revision 25, specifies that the Opera'ions Shift Supervisor (OSS) is responsible for determining the efFect of the maintenance on the plant and any other requirements or special conditions (like TS requirements) that are required for the maintenance to occur.

Contrary to the above, on May 17, 1996, the inspectors identified that the OSS failed to determine that a TS limiting condition for operation (LCO) was necessary for the May 15, 1996, maintenance on a drywell pressure monitor. The inspectors identified that TS Table 3.2-H, Action Statement 93 specified a 30 day LCO with the drywell pressure monitor inoperable.

This is a Severity Level IV violation (Supplement 1).

RESPONSE TO VIOLATION

1. REASON FOR THE VIOLATION On March 19, 1996, it was determined that the recorder indication provided by Pressure Recorder (PR) 4398A was operable but slowly degrading. A Corrective Maintenance Action Request (CMAR) was initiated to resolve the concern. As part of the planning of this CMAR (in accordance with the appropriate Maintenance Directive), the plant efFect section of the CMAR was annotated to indicate that a 30 day LCO was required in accordance with TS table 3.2-H Action Statement 93.

Action Statement 93 states:

Ifthe number of OPERABLE channels (both intlicator aml recortler inoperable) is retlucetl to one channel, folloiveither step (a) or (b) beloiv.

a. Operation may continue for the next 30 days provided at least one (I) channel ofinstrumentation specified in Table 3.Z-Ffor the identical parameter is OPERABLE"'* or fo..oiv step (c) beloiv.

b. Restore the inoperable channel to OPERABLE status ivithin 7 days, should neither channel ofinstrunrentation specified in Table 3.2-F for the irlentical paranieter be OPERABLE, or folloivstep (c) beloiv.

Attachment to NG-96-1525 Page 2 of 2

c. Within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> bein at least HOTSTANDBYand within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bein COLD SHUTDO8%

On May 15, 1996, the CMAR was released for work. PR4398A provides both digital indication and recorder indication for wide-range drywell pressure indication to meet the requirements of Reg. Guide 1.97 (0-250 psig). Additional wide range drywell pressure indication is supplied in the control room by Pressure Indicator (PI) 4396C.

PI4396C has a range of 0-100 psig. When PR4398A was removed from service, the OSS determined that. PI4396C was the indication that fulfilled the requirements of the LCO statement and therefore, didn't enter the 30 day action statement.

2. CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED On May 17, 1996, Action Request 960844 was initiated to address the inspector's concern. PR4398A was verified to be operable. It was determined that a 30 day LCO was required when the PR was removed from service. The total period the recorder was out of service was less than one day.

Training was held with all Licensed Operators on the need to enter an LCO when PR4398A is removed from service and that PI4396C is not the indicator noted in Action Statement 93. Additionally, Licensed Operators will be trained during the Licensed Operator Requalification program on the unique ranges of accident range instruments in our TS tables.

3. CORRECTIVE STEPS THAT WILLBE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are necessary.

4. DATE WHEN FULL COMPLIANCE WILLBE ACHIEVED Full compliance was achieved on May 17, 1996, when PR4398A was verified to be operable.