ML20216B087
| ML20216B087 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216B075 | List: |
| References | |
| 50-331-97-06, 50-331-97-6, NUDOCS 9709050226 | |
| Download: ML20216B087 (3) | |
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NOTICE OF VIOLATION lES Utilities, Incorporated Docket No. b0-331 Duane Arnold Energy Center License No. DPR-49 During an NRC inspection conducted on March 24 through April 25,1997, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600 (60 FR 34381; June 30, 1995), the violations are listed below:
1.
Criterion XVI of 10 CFR Part 50, Appendix B, states,in part, that mea.tures shall be established to assure that conditions adverse to quality are promptly identified and corrected and that measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition.
Contrary to the above:
a.
As of April 25,1997, corrective actions taken in response to a previous violation involving procedure deficiencies and cited in inspection Report 96005, dated September 27,1996, had not been adequate to preclude repetition. Seven occurrences were identified where the licensee had failed to identify and correct procedure deficiencies (EO-331/97006 01a).
b.
As of April 7,1997, adequate prompt corrective actiom had not been taken for a flaw identified in the body of the residual heat removal pump D j
discharge check valve (V19 001) in March of 1995. The flawed valve was
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retumed to servic6 in March of 1995, without adequate nondestructive examinations to verify the subsurface extent of the flaw. The flaw was subsequently removed by grinding it out on April 10,1997(50 331/97006-Olb).
This is a Severity Level IV violation (Supplement 1).
2.
Criterion XI of 10 CFR Part 50, Appendix B, requires,in part, that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service are identified and perfornied in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above:
As of April 24,1997, design valve closure time acceptance limits as described in the Updated Safety Analysis Report (UFSAR) for valves MO 2003 and MO 1905 had not been incorporated into surveillance test procedure (STP) 45A002-Q, " Low Pressure Coolant injection Operability." Further, on April 24,1997, the licensee identified that for valves MO-2117 and MO-2137, design valvo closure time acceptance limits as described in the UFSAR had not been incorporated into surveillance test STP 45A001-O, " Core Spray System Quarterly Operability" (50-331/97006-03).
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This is a Severity Level IV violation (Supplement 1).
3.
Criterion V of 10 CFR Part 50, Appendix B, states, in part, that activities affecting quality shall be prescribed b s documented instructions, procedures, or drawings, of i
a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Engineering Department procedure 1203.21, " Engineering Calculations," Revision 3
- Section 3.2 stated, " Engineering calculations shall be verified independently by another individual technically qualified in the same subject and who did not participate in the original calculation," and, " Engineering caculation numbers for all IES Utilities Inc. and all supplier generated calculations shall appear as: CAL XYY-ZZZ,...."
Engineering Department procedure 1206.31, " Design Verification Procedure,"
Revision 6, Section 3.4 required, " Design review of design document (s) or modifications will be sufficient to verify the appropriateness of the design input; including assumptions, design basis, and applicable regulations; codes and standards; and that the design is adequate for the intended application...."
Administrative Control Procedure (ACP) 114.5, Revision 9, paragraph 3.1.(2).(a) required review and documentation of operability evaluations on the Action Request (AR) form, Contrary to the above:
a.
As of April 7,1997, a fracture mechanics calculation performed on March 29,1995, to accept a flaw in the body of check valve V19-001, lacked a documented independent review of the calculation and a calculation control number (50-331/97006-04a).
b.
As of April 24,1997, a calculation in engineering maintenance action A26702G, dated September 19,1996, which demonstrated the acceptability of a new relief valve on the B residual heat removal heat exchanger did not meet procedure 1206.31 requirements in that the incorrect design code was used for stress level acceptance criterion, an incorrect /nonconservative input value was used, design assumptions were not given, and the applicable code edition was not documented in this calculation (50-331/97006-04b).
On July 1,1997, following the pressure locking of valve V19-148, an c.
operability assessment in accordance with ACP 114.5 was not documented in the associated action request, AR 97-0094 (50-331/97006-04c).
This is a Severity Level IV violation (Supplement I).
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4.
Criterion til of 10 CFR Part 50, Appendix B, states, in part, that measures shall provide for verifying or checking the adequacy of the design, and that changes shall be subject to design control measures commensurate with those applied to the original design.
Contrary to the above:
Adequate design control measures were not used in calculation CAL M97 002, dated February 3,1997. A non-verificd input ascumption was used for the bonnet temperature in CAL M97 002, which evaluated the pressure locked valve V19148.
This calculation used a straight average between the drywell temperature and the reactor coolant system with no supporting thermal analysis to confirm or bound the valve bonnet temperature heatup (50-331/9700610).
This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Duane Amold Energy Center is hereby required to submit a written statement or explanation to the U.G. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555 with a copy to the U.S. Nuclear Regulatory Commission, Region 111, 801 Warrenville Road, Lisle, Illinois 60532-4351, and a copy to the NRC Resident inspector at the Duane Arnold Energy Center within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violatiom (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the.
corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
Dated at Lisle, Illinois, this 1st day of September 1997 l
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