ML20248J447

Notice of Violation from Insp on 980318-0428.Violation Noted:On 980408,STP 42B012-CY,Prerequisite 6.4,was Not Properly Implemented

ML20248J447
Person / Time
Site:	Duane Arnold
Issue date:	05/29/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248J439	List: IR 05000331/1998004 ML20248J437 ML20248J447
References
50-331-98-04, 50-331-98-4, NUDOCS 9806090135
Download: ML20248J447 (2)

Text

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l NOTICE OF VIOLATION lES Utilities, Inc. Docket No. 50-331 Duane Arnold Energy Center License No. DPR-49 i

During an NRC inspection conducted on March 18 through April 28,1998, three violations of l NRC requirements were identified in accordance with the " General Statement of Policy and

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Procedure for NRC Enforcement Actions," NUREG-1600, the violations ara listed below:

1. Technical Speci'ication 6.8.1.6 states that written procedures involving surveillance and testing requirements of equipment that could have an affect on the nuclear safety of the facility be implemented.

Surveillance Test Procedure (STP) 42B012-CY, " ADS (Automatic Depressurization System) Timer Calibration and Logic System Functional Test," Prerequisite 6.4, stated,  ;

" Ensure steam line plugs are in place and steam line depressurized or reactor level is below main steam line and vessel depressurized."

Contrary to the above, on April 8,1998, STP 428012-CY, Prerequisite 6.4, was not properly implemented. Operators did not ensure that the steam line was depressurized ,

or that the reactor level was below the main steam line and the vessel depressurized.

This is a Severity Level IV vic,iation (Supplement I).  ;

2. 10 CFR Part 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings,"

requires, in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on 3-ril 16,1998, instructions to replace and calibrate a safety-related primary containmen: "ation system relay, A718-K065, an activity affecting quality, under preventive maimenance action request (PMAR)1102482, was not appropriate to the circumstances. Neither the work instructions used to replace the relay nor the procedure (Relay-A-109-01, "Agastat Relays") used to calibrate the relay directed the workers to disconnect the relay power leads prior to connecting a temporary power source, which resulted in inadvertently energizing an out-of-service circuit.

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

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3. Technical Specification 3.2.H requires containment hydrogen / oxygen in-line monitors to be operable in Modes 1,2, and 3. If no operable channels are available, Technical Specifications further require that the licensee either rostore at lesst one channel to operable status within 7 days, or within 7 days and at least every other day thereafter, demonstrate the ability to obtain and analyze containment samples for hydrogen and oxygen, or within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> place the affected unit in at least hot standby and within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in cold shutdown.

Contrary to the above, from September 1984 to March 20,1998, both containment hydrogen / oxygen in-line monitors were inoperable and the reactor was not taken to cold shutdown. Sample lines were not heat traced and insulated as required by the Updated 9006090135 980529 PDR ADOCK 05000331 G PDR l

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. 1 Notice of Violation l Final Safety Analysis Report, which would result in significant inaccuracies during

. accident conditions under which the monitors are required to operate.

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

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.S. Nuclear Regulatory Commission, ATTN:

. Document Control Desk, Washington, D.C. 20555, with a copy to the U.S. Nuclear Regulatory Commission, Region lil, 801 Warrenville Road, Lisle, Illinois 60532-4351, and a copj to the NRC Resident inspector at the Duane Amold Energy Center within 30 days of the date of the letter

' transmitting this Notice of Violation (Notice). This reply should be cleasiy marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (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 l 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.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy, or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. - If you request withholding of such material, you muft specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain wh) , > disclosure of information will create an unwarranted invasion of personal privacy or provide ' information required by 1

10 CFR 2.790(b) to support a request for withholding confidemune commercial or financial information). . If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois -

this 87tiday of May 1998

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