NG-05-0436, Supplement to the Response to a Notice of Violation Contained in Inspection Report 5000331/2005011
| ML052290275 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 08/09/2005 |
| From: | Vanmiddlesworth G Nuclear Management Co |
| To: | Document Control Desk, NRC/RGN-III |
| References | |
| IR-05-011, NG-05-0436 | |
| Download: ML052290275 (2) | |
Text
NMC Committed to Nuclear Excellence Duane Arnold Energy Center Operated by Nuclear Management Company, LLC August 9, 2005 NG-05-0436 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Supplement to the Response to a Notice of Violation Contained in Inspection Report 5000331/2005011
Reference:
Letter (NG-05-0418) from Van Middlesworth (NMC) to USNRC, "Response to a Notice of Violation Contained in Inspection Report 5000331/2005011," Dated August 1, 2005 Based on discussions with members of your staff, we have concluded that a supplement to~our previousresponse (Referenced above) to the Notice of Violation (NOV) contained in Inspection Report 500o33P/2005O0.1 -is appropriate in order to clarify the fact thatwe do not contest either-of the violations.,-'
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Nuclear Management Company (NMC) hasiconcluded that maintaining the conditions for performance of Scram Time Testing under-Technical Specification. (TS) 3.10.1 after completion-of;the~vessel hydro leak-test was contrary to our.TS's. As stated. in~our August 1; 2005 response toethe NOV! the procedures directing.Scram Time Testing under vessel hydro conditions have been quarantined. Further, we have reviewed the 10 CFR 50.59%scfeen that was conducted to support the 1999 procedure changes that allowed the Scram Time Testing under vessel hydro conditions and concluded that it too-was inappropriate. Specifically, the-10 CFR-50.59 screen should-have concluded-that a TS amendment was needed if the testing was performed in extended vessel hydro conditions (i.e., after completion of the leak testing), Without exiting.TS,,3.10.1.
We had previously 'concluded that the reason for the two-violations-was the sama:: in 1999 a cross-functional group of ourstaff reviewed benchmark information and r concluded that the TS for vessel hydrdand.ScramTirne Testing could be used in that.
manner.!, Additionally, it -should be noted.that tho~e-same individuals were the ones who performed the procedure revisions and supporting 10 CFR 50.59 screen. Therefore, the.-rason for theviolations remains the:same:< the individuals involved failed to coGclude.thtatthe changes. mad4xgallpw for Scramr jirneTesting underextended ve'Siel hydro.conditionstwas.cohtrary to:TS.!':-:,' ':"')S 1-i:
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Document Control Desk Page 2 In addition to quarantining the inappropriate procedures, we have reviewed all revisions made to similar procedures (surveillance test procedures for TS section 3.10) from 1999 to present and concluded that no similar errors were made.
Regarding corrective actions taken to prevent further violations, we have concluded that similar errors will not happen again for the following reason: as a result of the 2000 rule change to 10 CFR 50.59, the screening process was made much more rigorous and we performed extensive retraining of plant staff for the revisions to 10 CFR 50.59. This training covered the need to carefully review the affected licensing bases such as TS to determine whether prior NRC approval would be required.
As stated in the referenced letter, NMC will not conduct scram time testing in that same manner unless the TS are changed.
If you have any further questions regarding this topic, please call Steve Catron, Nuclear Safety Assurance Manager at (319) 851-7234.
This letter contains no new commitments.
Gary D. Van Middlesworth Site Vice President, Duane Arnold Energy Center Nuclear Management Company, LLC cc:
Region Ill D. Spa!ding (NRC-NRR)
NRC Resident Office