05000331/FIN-2011004-01
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Finding | |
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| Title | Degraded or Non-Conforming Conditions not Properly Evaluated |
| Description | A finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the licensees failure on two occasions to follow procedure EN-AA-203-1001, Operability Determinations/Functionality Assessments, when degraded or non-conforming conditions were identified. Specifically, in one case, the duty Shift Manager incorrectly concluded that an immediate determination of operability for the Ultimate Heat Sink (UHS) was not applicable when a degraded wing dam condition was identified upstream of the intake structure. In another case, the duty Shift Manager incorrectly concluded that immediate determinations of operability for Residual Heat Removal (RHR) and Residual Heat Removal Service Water (RHRSW) thermal relief valves were not applicable when it was identified that several valves had not been tested in accordance with American Society of Mechanical Engineers (ASME) Code requirements. For each issue, the conclusions were contrary to the requirements of procedure EN-AA-203-1001 which requires all degraded or non-conforming conditions be evaluated under an immediate operability determination and prompt operability determination (POD) if warranted. The licensee entered the inspectors concerns into the Corrective Action Program (CAP) as Condition Report (CR) 01679373 and 01684521, for the UHS and RWS system, and RHR and RHRSW systems, respectively. The licensee performed PODs that determined the affected structures, systems, and components (SSCs) were operable but degraded or non-conforming pending restoration of the SSCs to full design and licensing basis qualification. The inspectors determined that the issues of concern represented a performance deficiency because they were the result of the licensees failure to meet a procedural requirement, and the cause was reasonably within the licensees ability to foresee and correct and should have been prevented. The performance deficiency was determined to be more than minor and a finding because, if left uncorrected, failing to properly assess the operability of degraded or non-conforming conditions would have the potential to lead to a more significant safety concern. The inspectors applied IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, to this finding. Because the finding was a qualification deficiency confirmed not to result in loss of operability (Question 1 under the Mitigating Systems Cornerstone column of Table 4a), the finding screened as very low safety significance (Green). The inspectors determined that the contributing cause that provided the most insight into the performance deficiency was associated with the cross-cutting aspect of Human Performance, having Decision-Making components, and involving the licensee making safety-significant decisions using a systematic process. Specifically, by deciding that systematic evaluations of operability were not required to assess the impact of the conditions on the design and licensing bases of the SSCs, the licensee did not ensure that the impact was clearly understood and whether compensatory measures were necessary. |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2011004 Section 1R15 |
| Date counted | Sep 30, 2011 (2011Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | R Winter K Riemer M Mitchell L Haeg J Draper R Murray J Beavers V Myers |
| CCA | H.13, Consistent Process |
| INPO aspect | DM.1 |
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Finding - Duane Arnold - IR 05000331/2011004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2011Q3
Self-Identified List (Duane Arnold)
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