ML20154Q150

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-331/98-301OL Issued on 980821.Corrective Actions Will Be Examined During Future Inspections

ML20154Q150
Person / Time
Site:	Duane Arnold
Issue date:	10/16/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
References
50-331-98-301OL, NUDOCS 9810230153
Download: ML20154Q150 (2)

See also: IR 05000331/1998301

Text

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October 16, 1998

- Mr. John F. Franz, Jr.

Vice President, Nuclear

Alliant Tower

200 First Street SE

P. O. Box 351

Cedar Rapids, IA 52406-0351

SUBJECT: EXAMINATION WEAKNESSES (NRC INSPECTION REPORT

50-331/98301(OL))

Dear Mr. Franz. i

l

This will acknowledge receipt of your letter dated September 21,1998, in response to our letter

dated August 21,1998, transmitting Examination Weaknesses associated with the above

mentioned inspection report at the Duane Arnold Energy Center. We have reviewed your

corrective actions and have no further questions at this time. These corrective actions will be

examined during future inspections.

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in reference to your last comment, we agree with your comment that a decision to scram does

not constitute a weakness, rather it may be a conservative action to a degrading plant condition. l

However, in this case, the candidate was not down graded because he took a conservative

action, but that he failed to follow approved emergency operating procedures (EOP) when

ample time was available. The procedure in question was EOP 3, " Secondary Containment

Control," whereby the candidate was given Max Normal radiation conditions that did not warrant

a plant shutdown. In fact, the emergency procedure directed him to verify no system discharge

into the affected rooms, continue to monitor the radiation levels, and when the same two

parameters exceeded the Max Safe limits to initiate a controlled reactor shutdown, not a reactor

scram at high power. With indications of a possible fuel-clad leak, an unnecessany and

significant mechanical transient, such as a reactor scram, could cause additional (extensive)

fuel failure. Therefore, the performance of a reactor scram, in this case, was not the most

conservative action. His actions could have potentially caused additional fuel damage

(degraded the plant) due to the unnecessary mechanical transient.

Sincerely,

s/S. A. Reynolds

John A. Grobe, Director

Division of Reactor Safety

Docket No.: 50-331

License No.: DPR-49 ,n4o )

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J. Franz 2

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cc: E. Protsch, Executive Vice President

Energy Delivery Atliant; l

President, IES Utilities, Inc.

G. Van Middlesworth, Plant Manager j

K. Peveler Manager, Regulatoy Performance

Chairperson, Iowa Utilities Board

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Project Mgr., NRR

J. Caldwell, Rill

C. Pederson, Rll!

B. Clayton, Rlli ,

SRI Duane Arnold i

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emi UTILITIES IEs unime. i e.

i Duane Arnold Energy Center

IES Utilities 32U DAEC Road

Palo. IA 52324-9785

OfEce: 319.851.7611

Fax: 319.851.7986

September 21,1998 ~ ~'"

- NG-98-1611

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U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Mail Station 0-PI-17

Washington, D.C. 20555-0001

Subject: Duane Arnold Energy Center

DocketNo: 50-331

Op. License No: DPR-49

Reply to Weaknesses Identified in Inspection Report 98-301(OL)

Reference: NRC Inspection Report No.98-301(OL)

File: A-102

Dear Sir:

This letter and attachment are provided, as requested, in response to the weaknesses

contained in the above referenced inspection report relating to the hdtial Operator

License examinations conducted at the Duane Arnold Energy Center in July 1998.

This letter contains no new commitments.

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

Sincerely, ,

.

John F. Franz -

Vice President, Nuclear /

Attachment ~I

cc: R. Murrell

E. Protsch

j D. Wilson

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R. Laufer (NRC-NRR)

J. Caldwell(Region III)

NRC Resident Office

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Attachment to

s NG-98-1611

Page 1 of 2

, Reply to Weaknesses

Identified in Inspection Report 98-301(OL)

The Duane Amold Energy Center is continuing to review the weaknesses outlined in

Inspection Report 98-301(OL) conceming the initial operator license examination

conducted in July,1998. The weaknesses identified will be used as feedback into the ~

licensed operator training program in accordance with our Systematic' Approach to

Training process. Preliminary reviews of the results of the initial operator license

examinations have determined that improvement opportumties currently exist in the areas

of examination development and candidate preparation.

Concerning examination development, there is room for improvement in the development

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of written examination questions, job performance measures, and simulator scenarios.

, These improvements in the examinations are needed to assure the appropriate level of

difficulty, improve the ability to discriminate between competent and less than competent l

candidates, and conform with the guidance contained in NUREG 1021, Interim Rev. 8. A

contributor to weaknesses in examination development was our staff's n-wness to the

examination development process and the complexity of the timelines associated with

NUREG 1021. Attending the May,1998, NRC Region III Examination Writers

Workshop was helpful, but not an adequate substitute for experience with this process.

Additionally, the selection of some Improved Technical Specification questions for the

written examination was inappropriate. Specifically, some of the examples selected were

at a complexity level that may have required an operator to obtain further consultations

(e.g. Licensing support) prior to making the appropriate determinations.

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With regard to candidate preparation, it has been determined that the candidates may not

have been exposed to NRC style high level written examination questions early enough in

the program to assure appropriate readiness for the written examination.

Corrective actions for these two areas and the inspection report identified weaknesses will

, be determined after completion of the review of the examination weaknesses in

accordance with our Systematic Approach to Trainmg process, review of initial operator

license class lessons teamed, and other activities as appropriate. These actions are

expected to be completed by December 15,1998.

- We would like to take this opportunity to comment on a specific statement contained in

the Inspection Report concerning a perceived weakness involving a candidate's

performance during the Dynamic Simulator Examination. Specifically, the report states,

"Some applicants displayed weaknesses in performing abnormal and emergency

operating procedures (EOPs). For example: (1) an SRO [ senior reactor operator]

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Attachment to

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Page 2 of 2

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applicant decided to ccnservatively scram the reactor after only receiving Mar Normal

indications on two area radiation monitors, contrary to the EOP directions...". We

believe that inserting a manual scram, in response to degrading plant conditions, is based

on the SRO's or operator's judgment and that this candidate's decision to scram does not

constitute a weakness. The candidate's actions were consistent with our conservative

operating philosophy. Our existing Administrative Control Procedure,'ACP 1410.1,

" Conduct of Operations," Section 3.6, " Reactivity Control," supports this position by

stating: "All on-shift licensed Operators shall take action to reduce power or scram the 1

reactor ifnecessary to ensure safety ofthe reactor orpersonnel. " l

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