05000331/FIN-2012005-02
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Finding | |
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Title | Degraded/Non-Conforming Conditions Not Properly Evaluated |
Description | A finding of very low safety significance and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors on October 17, 2012, for the licensees failure to accomplish procedure EN-AA-203-1001, Operability Determinations/Functionality Assessments, when degraded or non-conforming conditions were identified. Specifically, the duty Shift Manager approved Prompt Operability Determination (POD) 01812339 that was performed following the identification of submerged power and control cables associated with the A Standby Diesel Generator (SBDG). The POD did not discuss the fact that the applicable cables were not qualified for submergence, incorrectly concluded that the cables conformed to the Updated Final Safety Analysis Report (UFSAR), and did not evaluate whether compensatory actions were required. The POD conclusions were contrary to the requirements of procedure EN-AA-203-1001 that required all degraded or non-conforming conditions be evaluated for compensatory actions. The licensee documented the inspectors concerns in CR 01813800, revised POD 01812339, and assigned compensatory actions for the degraded and non-conforming conditions. The inspectors determined that failing to evaluate a degraded or non-conforming condition for compensatory actions represented a performance deficiency because it was the result of the licensees failure to meet a regulatory 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 and evaluating the necessity for compensatory actions would have the potential to lead to a more significant safety concern. The inspectors applied IMC 0609.04, Initial Characterization of Findings, to this finding. Because the finding pertained to an event while the plant was shutdown, Table 3 instructed reference of IMC 0609, Appendix G, Shutdown Operations Significance Determination Process. Because the finding did not require a quantitative assessment, 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 Problem Identification and Resolution, having Operating Experience (OE) components, and involving the licensee implementing and institutionalizing OE through changes to station processes and procedures. |
Site: | Duane Arnold ![]() |
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Report | IR 05000331/2012005 Section 1R15 |
Date counted | Dec 31, 2012 (2012Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | R Orlikowski M Phalen D Jones L Haeg J Draper R Murray S Bell R Elliott |
CCA | P.5, Operating Experience |
INPO aspect | CL.1 |
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Finding - Duane Arnold - IR 05000331/2012005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2012Q4
Self-Identified List (Duane Arnold)
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