ML20236X389

Responds to Technical Assistance Request (AIT 96-0278) Re Entering Limiting Conditions for Operation at Duane Arnold Energy Ctr

ML20236X389
Person / Time
Site:	Duane Arnold
Issue date:	08/03/1998
From:	Bellamy R NRC (Affiliation Not Assigned)
To:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
TAC-M97310, NUDOCS 9808070344
Download: ML20236X389 (4)

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UNITED STATES E NUCLEAR ' REGULATORY COMMISSION E WASHINGTON, D.C. 2006 Hoot

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i MEMORANDUM TO: Geoffrey E. Grant, Director Division of Reactor Projects l Region lli i c

FROM: Ronald R. Bellamy, Acting Director Project Directorate ill-3 l Division of Reactor Projects ill/IV Office of Nuclear Reactor Regulation ,

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SUBJECT:

RESPONSE TO TECHNICAL ASSISTANCE REQUEST (AIT 96-0278)  !

RELATED TO ENTERING LIMITING CONDITIONS FOR OPERATION AT THE DUANE ARNOLD ENERGY CENTER (TAC NO. M97310)

By memorandum dated August 23,1996, your office forwarded the subject request for technical assistance requesting that NRR review the following:

1. The acceptability of Duane Amold's practice of not entering limiting conditions for operation (LCOs) for surveillance testing (which is inconsistent with NRC Part 9900 guidance);

2. The acceptability of Duane Arnold's practice of not entering LCOs when certain support systems are out-of-service; and

3. While reviewing Duane Arnold's conversion to improved technical specifications (ITS), please review the licensee's intent to maintain its current practice of not entering LCOs for TS-required surveillance testing, even in cases where the system is rendered inoperable, and its intent not to enter LCOs for the systems i listed when support systems are inoperable.

1 The Technical Specification Branch (TSB) reviewed your request in conjunction with their l review of the licensee's October 30,1996, amendment request to convert the current Duane i Arnold Energy Center (DAEC) TS to the ITS. In their October 30,1996, submittal, the licensee proposed incorporating their current LCO entry practices into the ITS by adding Allowed Outage l Time (AOT) Notes to the necessary LCO Actions. k l

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In a January 16,1997 memorandum (from Chris Grimes to Glenn Kelly), TSB stated that it  ;

agreed with the Region's position that the licensee should enter the appropriate TS LCOs l whenever a system is incapable of performing its design function due to surveillance testing or 7, g) due to a support system being out of service. Furthermore, TSB stated that since the ITS are ()\

l constructed with a presumption that equipment will be declared inoperable during surveillance >

testing that renders the equipment incapable of performing its design function, this issue must be resolved before the review of the licensee's conversion to the ITS can be completed. l 9808070344 980003 PDR ADOCK 05000331 l P PDR 7 p, U *' lNE@ I d C . a _ m . ~ .

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~y On March 20,1997. the staff met with the licensee to discuss their LCO entry practices. During the meeting, the staff requested that the licensee re-evaluate their ITS amendment request with I respect to their policy on entering LCOs. Subsequent to this meeting, by memorandum dated April 8,1997 (from Chris Grimes to Glenn Kelly), TSB supplemented its January 16,1997, position. TSB stated that the licensee's practice of routinely not entering LCOs to perform surveillance, even when the surveillance renders the equipment inoperable, is not consistent with the intended TS practices. However, because the licensee has effectively accomplished the intended result of the TS through the use of administrative controls, there is no immediate safety issue. Furthermore, TSB stated that bringing the practices at Duane Arnold into conformance with present TS usage conventions would best be accomplished by the NRC staff ,

completing its review of the licensee's request to convert to the ITS.

In a September 5,1997, letter and during a September 9,1997, meeting with the staff, the licensee presented a revised list of TSs that would include AOT notes for entering LCOs during surveillance. During the meeting the staff stated that it would only consider LCO entry exceptions for those few cases where there was adequate technical justification. By letter dated November 21,1997, the licensee provided a final list of seven TSs that would include AOT notes for LCO entry. The staff reviewed each deviation from the ITS format proposed by the licensee on a case-by-case basis. As a result of its review, the staff approved five of the AOT notes on LCO entry.

By letter dated May 22,1998, the staff issued Amendment 223 which converts the Duane Arnold Energy Center's current TS to the ITS. The licensee implemented this amendment on August 1,1998. This completes NRR's effort on AIT 96-0278 and closes TAC No. M97310. If l you have any questions regarding this ;ssue, please contact Rich Laufer of my staff at (301) l 415-1373. I Docket No. 50-331 cc: CHehl, RI LPlisco, Ril TGwynn, RIV l l

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August. 3, 1998 l

On March 20,1997, the staff met with the licensee to discuss their LCO entry practices. During  !

the meeting, the staff requested that the licensee re-evaluate their ITS amendment request with  !

respect to their policy on entering LCOs. Subsequent to this meeting, by memorandum dated I April 8,1997 (from Chris Grimes to Glenn Kelly), TSB supplemented its January 16,1997, )

position. TSB stated that the licensee's practice of routinely not entering LCOs to perform surveillance, even when the surveillance renders the equipment inoperable, is not consistent with the intended TS practices. However, because the licensee has effectively accomplished the intended result of the TS through the use of administrative controls, there is no immediate safety issue. Furthermore, TSB stated that bringing the practices at Duane Arnold into conformance with present TS usage conventions would best be accomplished by the NRC staff completing its review of the licensee's request to convert to the ITS.

In a September 5,1997, letter and during a September 9,1997, meeting with the staff, the licensee presented a revised list of TSs that would include AOT notes for entering LCOs during surveillance. During the meeting the staff stated that it would only consider LCO entry exceptions for those few cases where there was adequate technicaljustification. By ietter dated November 21,1997, the licensee provided a final list of seven TSs that would include AOT notes for LCO entry. The staff reviewed each deviation from the ITS format proposed by the licensee on a case-by-case basis. As a result of its review, the staff approved five of the AOT notes on LCO entry.

By letter dated May 22,1998, the staff issued Amendment 223 which converts the Duane Arnold Energy Center's current TS to the ITS. The licensee implemented this amendment on August 1,1998. This completes NRR's effort on AIT 96-0278 and closes TAC No. M97310. If you have any questions regarding this issue, p! ease contact Rich Laufer of my staff at (301) 415-1373.

Docket No. 50-331 cc: 0t . E., RI LPlisco, Rll TGwynn, RIV Distribution:

Docket File MKurth, (Resident inspector)

PD3-3 R/F PUBLIC l

EAdensam (EGA1) OGC RLanksbury, Rill ACRS DOCUMENT NAME: G:\DUANEARN\DUA97310.TIA

• see previous concurrence To receeve a copy of this document, indicate m the bon C = Copy w/o attachment / enclosure E = Copy with attachmenvenclosure N = No copy OFFICE PM.PD33 E LA:PD33 E BC:TsB C AID):PD33 (A .DRPW

/ \

NAME RLaufer k EBarnhill W Beckner

• RBellamy EAde sam DATE 1/M /98 9 /M/98 7/9/98 / /98 / /98 r OFFICIAL RECORD COPY l

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August 3, 1998 On March 20,1997, the staff met with the licensee to discuss their LCO entry practices. During the meeting, the steff requested that the licensee re-evaluate their ITS amendment request with I respJct to their policy on entering LCOs. Subsequent to this meeting, by memorandum dated April 8,1997 (from Chris Grimes to Glenn Kelly' TSB supplemented its January 16,1997, position. TSB stated that the licensee's practice of routinely not entering LCOs to perform surveillance, even when the surveillance renders the equipment inoperable, is not consistent with the intended TS practices. However, because the licensee has effectively accomplished the intended result of the TS through the use of administrative controls, there is no immediate l safety issue. Furthermore, TSB stated that bringing the practicos at Duane Arnold into conformance with present TS usage conventions would best be accomplished by the NRC staff completing its review of the licensee's request to convert to the ITS.

In a September 5,1997, letter and during a September 9,1997, meeting with the staff, the licensee presented a revised list of TSs that would include AOT notes for entering LCOs during surveillance. During the meeting the staff stated that it wculd only consider LCO entry exceptions for those few cases where there was adequate technicaljustification. By letter dated November 21,1997, the licensee provided a final list of seven TSs that would include AOT notes for LCO entry. The staff reviewed each deviation from the ITS format propoaod by the licensee on a case-by-case basis. As a result of its review, the staff approved five of tne AOT notee on LCO entry.

By letter dated May 22,1,998, the staff issued Amendment 223 which converts the Duane I Arnold Energy Center's current TS to the ITS. The licensee implemented this amendment on August 1,1998. This completes NRR's effort on AIT 96-0278 and closes TAC No. M97310. If you have any questions regarding this issue, please contact Rich Laufer of my staff at (301) 415-1373.

Docket No. 50-331 cc: CHehl, RI LPlisco, Ril TGwynn, RIV Distribution:

Docket File MKurth, (Resident inspector)

P D3-3 R/F PUBLIC EAdensam (EGA1) OGC RLanksbury, Rlli ACRS

! DOCUMENT NAME: G:\DUANEARN\DUA97310.TIA

• see previous concurrence l

To reew. e copy at this document. indicat. ,n in, box c-copy w/o attachmenvenclosure E-copy witn sitachment/ enclosure N - No copy OFFICE PM:PD33 E LA:PD33 E BC:Tsb C A(D).PD33 (ApDRPW G_ /

NAME RLaufer k EBarnhill W Beckner' RBellamy EAde sam DATE 1 O \/98 9 /M/98 7 / 9 /98 / /98 7 / /98 OFFICIAL RECORD COPY I

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