ML060260024
| ML060260024 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 01/25/2006 |
| From: | Burgess B NRC/RGN-III/DRP/RPB2 |
| To: | Vanmiddlesworth G Nuclear Management Co |
| References | |
| IR-05-005 | |
| Download: ML060260024 (31) | |
See also: IR 05000331/2005005
Text
January 25, 2006
Mr. Gary Van Middlesworth
Site Vice-President
Duane Arnold Energy Center
Nuclear Management Company, LLC
3277 DAEC Road
Palo, IA 52324
SUBJECT:
DUANE ARNOLD ENERGY CENTER
NRC INTEGRATED INSPECTION REPORT 05000331/2005005
Dear Mr. Van Middlesworth:
On December 31, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Duane Arnold Energy Center. The enclosed integrated inspection report
documents the inspection findings which were discussed on January 13, 2006, with you and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, there were two NRC-identified findings of very low safety
significance, of which both involved a violation of NRC requirements. However, because these
violations were of very low safety significance and because the issues were entered into the
licensees corrective action program, the NRC is treating these findings and issues as
Non-Cited Violations in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
Additionally, a licensee identified violation is listed in Section 4OA7 of this report.
If you contest the subject or severity of a Non-Cited Violation, you should provide a response
within 30 days of the date of this inspection report, with the basis for your denial, to the
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of
Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the
Resident Inspector Office at the Duane Arnold Energy Center.
G. Van Middlesworth
-2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's document
system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Bruce L. Burgess, Chief
Branch 2
Division of Reactor Projects
Docket No. 50-331
License No. DPR-49
Enclosure:
Inspection Report 5000331/2005005
w/Attachment: Supplemental Information
cc w/encl:
E. Protsch, Executive Vice President -
Energy Delivery, Alliant;
President, IES Utilities, Inc.
C. Anderson, Senior Vice President, Group Operations
J. Cowan, Executive Vice President and Chief Nuclear Officer
J. Bjorseth, Site Director
D. Curtland, Plant Manager
S. Catron, Manager, Regulatory Affairs
J. Rogoff, Vice President, Counsel, & Secretary
B. Lacy, Nuclear Asset Manager
Chairman, Linn County Board of Supervisors
Chairperson, Iowa Utilities Board
The Honorable Charles W. Larson, Jr.
Iowa State Senator
D. Flater, Chief, Iowa Department of Public Health
D. McGhee, Iowa Department of Public Health
DOCUMENT NAME:C:\\MyFiles\\Roger\\ML060260024.wpd
G Publicly Available
G Non-Publicly Available
G Sensitive
G Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE
RIII
RIII
RIII
RIII
NAME
BBurgess/trt
DATE
01/25/06
OFFICIAL RECORD COPY
G. Van Middlesworth
-2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's document
system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Bruce L. Burgess, Chief
Branch 2
Division of Reactor Projects
Docket No. 50-331
License No. DPR-49
Enclosure:
Inspection Report 5000331/2005005
w/Attachment: Supplemental Information
cc w/encl:
E. Protsch, Executive Vice President -
Energy Delivery, Alliant;
President, IES Utilities, Inc.
C. Anderson, Senior Vice President, Group Operations
J. Cowan, Executive Vice President and Chief Nuclear Officer
J. Bjorseth, Site Director
D. Curtland, Plant Manager
S. Catron, Manager, Regulatory Affairs
J. Rogoff, Vice President, Counsel, & Secretary
B. Lacy, Nuclear Asset Manager
Chairman, Linn County Board of Supervisors
Chairperson, Iowa Utilities Board
The Honorable Charles W. Larson, Jr.
Iowa State Senator
D. Flater, Chief, Iowa Department of Public Health
D. McGhee, Iowa Department of Public Health
G. Van Middlesworth
-3-
ADAMS Distribution:
HKN
DWS
RidsNrrDirsIrib
GEG
KGO
GAW1
CAA1
C. Pederson, DRS (hard copy - IRs only)
DRPIII
DRSIII
PLB1
JRK1
ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No:
50-331
License No:
Report No:
Licensee:
Nuclear Management Company, LLC
Facility:
Duane Arnold Energy Center
Location:
Palo, Iowa
Dates:
October 1 through December 31, 2005
Inspectors:
G. Wilson, Senior Resident Inspector
R. Baker, Resident Inspector
M. Kurth, Resident Inspector Quad Cities
C. Acosta Acevedo, Reactor Inspector
B. Palagi, Senior Operations Engineer
Observers:
None
Approved by:
Bruce L. Burgess, Chief
Branch 2
Division of Reactor Projects
Enclosure
2
SUMMARY OF FINDINGS
IR 05000331/2005005; 10/01/2005 - 12/31/2005; Duane Arnold Energy Center, Fire Protection,
and Identification and Resolution of Problems.
This report covers a 3-month period of baseline resident inspection and announced baseline
inspections of heat sink performance and licensed operator requalification. The inspections
were conducted by Region III reactor inspectors and the resident inspectors. Two Green
findings with associated non-cited violations (NCV) were identified. The significance of most
findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not
apply may be Green or be assigned a severity level after NRC management review. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A.
Inspector-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
Green. A finding of very low safety significance was identified by the inspectors for the
failure to control and evaluate transient combustibles in the southeast corner room of the
reactor building. The transient combustibles consisted of wood planking located on
scaffolding within the room. The primary cause of this finding was related to the
cross-cutting area of Human Performance for the failure to follow approved procedures.
The licensee entered this issue into their corrective action program and processed the
associated combustible permits.
This finding was more than minor because it matched example 4.a. in Appendix E,
Examples of Minor Issues and Cross-Cutting Aspects, of Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports. This was due to the fact that the
licensee routinely failed to perform evaluations on similar issues. The finding was of
very low safety significance because of the low fire degradation rating associated with
wood. The issue was an NCV of License Condition 2.C.(3) that requires the licensee to
implement and maintain in effect all provisions of the approved fire protection program.
(Section 1R05)
Green. A finding of very low safety significance was identified by the inspectors for
failure to correct deficiencies with the control of transient combustibles. The transient
combustibles consisted of wood planking located on scaffolding. The primary cause of
this finding was related to the cross-cutting area of Problem Identification and Resolution
due to inadequate corrective actions for repeated deficiencies associated with the
control of transient combustibles. The licensee entered this issue into their corrective
action program, processed the associated combustible permits, and performed an
apparent cause evaluation.
This finding was more than minor because it matched example 3.g. in Appendix E,
Examples of Minor Issues and Cross-Cutting Aspects, of IMC 0612, Power Reactor
Inspection Reports. This was due to the fact that the licensee failed to take actions to
correct nonconforming conditions. The finding was of very low safety significance
Enclosure
3
because of the low fire degradation rating associated with wood. The issue was an NCV
of License Condition 2.C.(3), that requires the licensee to implement and maintain in
effect all provisions of the approved fire protection program. (Section 4OA2.1.b.)
B.
Licensee-Identified Violations
A violation of very low safety significance, which was identified by the licensee has been
reviewed by the inspectors. Corrective actions taken or planned by the licensee have
been entered into the licensees corrective action program. This violation and corrective
actions tracking numbers are listed in Section 4OA7 of this report.
Enclosure
4
REPORT DETAILS
Summary of Plant Status
Duane Arnold Energy Center (DAEC) operated at full power for the entire assessment period
except for brief down-power maneuvers to accomplish rod pattern adjustments and to conduct
planned surveillance testing activities with the following exception:
On October 4, 2005, the reactor was reduced in power to approximately 65% for the
installation of temporary temperature monitoring of the High Pressure Core Injection
(HPCI) injection line. The plant returned to full power on October 5, 2005.
1.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01
Adverse Weather (71111.01)
.1
Winter Preparations
a.
Inspection Scope
The inspectors performed a detailed review of the licensees procedures and a
walkdown of three systems to observe the licensees preparations for cold weather
conditions for a total of one sample. The documents listed in the Attachment were used
by the inspectors to accomplish the objectives of the inspection procedure. During the
inspection, the inspectors focused on plant specific system design features and
implementation of procedures for responding to or mitigating the effects of adverse
weather. Inspection activities included, but were not limited to, a review of the licensees
adverse weather procedures, preparations for the winter season, and a review of the
analysis and requirements identified in the Updated Final Safety Analysis Report
(UFSAR).
The inspectors evaluated cold weather readiness of the following three systems for a
total of one sample:
Intake Structure heating, ventilation and air-conditioning (HVAC) during the week
ending October 22, 2005;
Pumphouse HVAC during the week ending October 29, 2005; and
Cathodic Freeze Protection during the week ending November 12, 2005.
b.
Findings
No findings of significance were identified.
Enclosure
5
1R04
Equipment Alignment (71111.04)
.1
Partial Walkdown
a.
Inspection Scope
The inspectors performed three partial walkdowns of accessible portions of trains of
risk-significant mitigating systems equipment. The documents listed in the Attachment
were used by the inspectors to accomplish the objectives of the inspection procedure.
Equipment alignment was reviewed to identify any discrepancies that could impact the
function of the system and potentially increase risk. Redundant or backup systems were
selected by the inspectors during times when the trains were of increased importance
due to the redundant trains of other related equipment being unavailable. Inspection
activities included, but were not limited to, a review of the licensees procedures,
verification of equipment alignment, and an observation of material condition, including
operating parameters of in-service equipment. Identified equipment alignment problems
were verified by the inspectors to be properly resolved.
The inspectors selected the following equipment trains to verify operability and proper
equipment line-up for a total of three samples:
Reactor Core Isolation Cooling (RCIC) system with the HPCI system declared
inoperable during the week ending October 8, 2005;
B train of the River Water Supply (RWS) system with the A train of RWS out of
service (OOS) for maintenance during the week ending October 22, 2005; and
A and B Standby Diesel Generators (SBDGs) with the T1 345 kV transformer
OOS for inspection/maintenance during the week ending November 5, 2005.
b.
Findings
No findings of significance were identified.
1R05
Fire Protection (71111.05)
.1
Quarterly Fire Zone Walkdowns (71111.05Q)
a.
Inspection Scope
The inspectors walked down six risk-significant fire areas to assess fire protection
requirements. The documents listed in the Attachment were used by the inspectors to
accomplish the objectives of the inspection procedure. Various fire areas were reviewed
to assess if the licensee had implemented a fire protection program that adequately
controlled combustibles and ignition sources within the plant, effectively maintained fire
detection and suppression capability, maintained passive fire protection features in good
material condition, and had implemented adequate compensatory measures for OOS,
degraded or inoperable fire protection equipment, systems or features. Fire areas were
selected based on their overall contribution to internal fire risk as documented in the
plants Individual Plant Examination of External Events (IPEEE), their potential to
adversely impact equipment which is used to mitigate a plant transient, or their impact
Enclosure
6
on the plants ability to respond to a security event. Inspection activities included, but
were not limited to, the control of transient combustibles and ignition sources, fire
detection equipment, manual suppression capabilities, passive suppression capabilities,
automatic suppression capabilities, compensatory measures, and barriers to fire
propagation.
The inspectors selected the following areas for review for a total of six samples:
During the week ending October 22, 2005:
Area Fire Plan (AFP) 31, Intake Structure Pump Area; and
AFP 32, Intake Structure Traveling Screen Area.
During the week ending November 5, 2005:
AFP 23, Battery Rooms 1D-2, 1D-4, 1D-1, Battery Corridor;
AFP 24, Essential Switchgear Rooms 1A-4, 1A-3; and
AFP 28, Emergency Service Water (ESW)/Residual Heat Removal Service
Water (RHRSW) Pump Rooms, and Main Pump Room.
During the week ending November 19, 2005:
AFP 2, South Corner Rooms.
b.
Findings
Introduction: A finding of very low safety significance (Green) and an associated NCV of
License Condition 2.C.(3) were identified by the inspectors for the failure to control and
evaluate transient combustibles in the southeast corner room of the reactor building.
Description: On October 25, 2005, the inspectors conducted a walkdown of the reactor
building and identified wood planking on scaffolding in the southeast corner room
without a Combustible Material/Flammable Liquid Control permit. The inspectors noted
that the scaffolding and associated wood planking were readily observable and
represented a significant quantity of transient combustibles. The weight of the wood
planking on the scaffolding was estimated to be 250 pounds. Discussions with the Fire
Engineer confirmed that the combustibles were not listed in the Fire Marshals database
of permits.
The wood planking was located beside the safety-related residual heat removal and core
spray pumps. Therefore, a fire involving the wood scaffolding materials could affect the
safety-related pumps.
Administrative Control Procedure (ACP) 1412.2, Control of Combustibles, specified
that class A materials exceeding 100 pounds may be brought into power block
buildings by permit only and defined wood as a class A material. The procedure also
noted that the use of wood in the power block buildings shall be minimized.
The Fire Engineer then initiated CAP 38552 to address the transient combustible issues.
Enclosure
7
Analysis: The inspectors determined that failing to identify transient combustibles in the
southeast corner room of the reactor building without an appropriate Combustible
Material/Flammable Liquid Control permit was an example of not complying with a
standard. As it could have reasonably been foreseen or corrected by the licensee, it
was, therefore, a performance deficiency. Since a performance deficiency existed, the
inspectors reviewed this issue against the guidance contained in Appendix B, Issue
Screening, of Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection
Reports. In particular, the inspectors compared this finding to the findings identified in
Appendix E, Examples of Minor Issues and Cross-Cutting Aspects, of IMC 0612 to
determine whether the finding was minor. Following that review, the inspectors
concluded that the guidance in Appendix E example 4.a. was applicable for the specific
finding. The finding was greater than minor because the licensee routinely failed to
perform evaluations on similar issues. In addition, the finding affected the cross-cutting
area of Human Performance because of the failure to follow the associated procedures
for transient combustibles.
As a result, the inspectors reviewed this issue in accordance with IMC 0609,
Appendix FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Fire Protection SDP, Attachment 2, Degradation Rating Guidance
Specific to Various Fire Protection Program Elements. The inspectors determined that
the unapproved presence of wood planking on scaffolding was a low degradation finding
against the combustible controls program because wood will not cause a fire from
existing sources of heat or electrical energy. After identifying that the issue had a low
degradation rating, the inspectors used IMC 0609, Appendix F, Attachment 1,
Application of Fire Protection SDP Phase 1 Worksheet, Task 1.3.1, Qualitative
Screening for All Finding Categories, for determining the severity level. Since the
finding had a low degradation rating, it was of very low safety significance and screened
as Green.
Enforcement: License Condition 2.C.(3) required the Nuclear Management Company
(NMC) to implement and maintain in effect all provisions of the approved fire protection
program as described in the DAEC Final Safety Analysis Report (FSAR), which
describes the fire protection program as contained in the Fire Plan and was incorporated
into the UFSAR by reference. Section 6.1 of the Fire Plan referenced ACP 1412.2,
assigning inspection responsibility to the Fire Marshal, to assure transient combustibles
were located, used, and documented. ACP 1412.2 also defined wood as a class A
material, and required a Combustible Material/Flammable Liquid Control permit for
bringing more than 100 pounds of such material into the power block. Contrary to the
above, on October 25, 2005, the NRC identified wood planking weighing approximately
250 pounds on scaffolding that had been in place in the southeast corner room of the
reactor building for 63 days without the required permit. Once identified, the licensee
initiated CAP 38552. Because this violation was of very low safety significance and
entered into the licensees corrective action program, this violation is being treated as an
NCV, per Section VI.A of the NRC Enforcement Policy. (NCV 05000331/2005005-01)
Corrective actions taken included an extent of condition review, which identified two
additional scaffolds with wood planking that did not have the required combustible
permit. Appropriate combustible permits were placed on all three scaffolds. In addition,
an apparent cause evaluation was performed.
Enclosure
8
1R07
Heat Sink Performance (71111.07B)
.1
Biennial Review of Heat Sink Performance
a.
Inspection Scope
The inspectors reviewed the performance of the HPCI room cooler and the RCIC room
cooler (a total of two heat exchangers). These heat exchangers were chosen for review
based on their high risk assessment worth in the licensees probabilistic safety analysis.
This review resulted in the completion of two inspection samples. While on-site, the
inspectors verified that the inspection and maintenance of these heat exchangers were
adequate to ensure proper heat transfer. This was done by conducting independent
heat transfer capability calculations, reviewing the methods used to inspect the heat
exchangers, and verifying that the as-found results were appropriately dispositioned,
such that the final condition was acceptable. The inspectors also verified by review of
procedures and test results that chemical treatments, ultrasonic tests, and methods
used to control biotic fouling corrosion and macrofouling were sufficient to ensure
required heat exchanger performance.
The inspectors verified that the condition and operation were consistent with design
assumptions in heat transfer calculations by conducting a service water system
walkdown and reviewing related procedures and surveillance. The inspectors also
verified that redundant and infrequently used heat exchangers were flow tested
periodically at maximum design flow. This was performed by reviewing related flow
tests.
The inspectors verified the performance of the ultimate heat sink and its
sub-components, such as piping, intake screens, intake bays, pumps, valves, etc. by
reviewing procedures, surveillance, and inspections conducted on the system.
The inspectors verified that the licensee had entered significant heat exchanger/heat
sink problems into their corrective action program and that the actions taken were
appropriate.
The documents that were reviewed are listed in the Attachment.
b.
Findings
No findings of significance were identified.
1R11
Licensed Operator Requalification Program (71111.11)
.1
Annual Operating Test Results
a.
Inspection Scope
The inspector reviewed the overall pass/fail results of the annual operating examination
which consisted of Job Performance Measure (JPM) and simulator operating tests
(required to be given per 10 CFR 55.59(a)(2)) administered by the licensee. The
Enclosure
9
operating testing was conducted in November and December 2005. The results were
compared with the SDP in accordance with NRC Manual Chapter 0609I, Operator
Requalification Human Performance SDP. This represents one sample.
b.
Findings
No findings of significance were identified.
.2
Quarterly Operating Crew Evaluation
a.
Inspection Scope
During the week ending October 22, 2005, the inspectors observed a training crew
performance on Simulator Exercise Guide (SEG) 2005E-01 for a total of one sample.
The scenario included a reactivity transient due to a loss of feedwater heating, followed
by a reactor coolant leak inside the primary containment, and a subsequent reactor
scram. The documents listed in the Attachment were used by the inspectors to
accomplish the objectives of the inspection procedure. The inspection activities
assessed the licensees effectiveness in evaluating the requalification program, ensuring
that licensed individuals operated the facility safely and within the conditions of their
license, and evaluated licensed operators mastery of high-risk operator actions.
Inspection activities included, but were not limited to, a review of high risk activities,
emergency plan performance, incorporation of lessons learned, clarity and formality of
communications, task prioritization, timeliness of actions, alarm response actions,
control board operations, procedural adequacy and implementation, supervisory
oversight, group dynamics, interpretations of technical specifications, simulator fidelity,
and the licensee critique of performance.
The crews performance was compared to licensee management expectations and
guidelines as presented in the following documents:
ACP 101.01, Procedure Use and Adherence, Revision 33;
ACP 101.2, Verification Process and SELF/PEER Checking Practices,
Revision 5; and
ACP 110.1, Conduct of Operations, Revision 3.
b.
Findings
No findings of significance were identified.
1R12
Maintenance Effectiveness (71111.12)
a.
Inspection Scope
The inspectors reviewed two systems to assess maintenance effectiveness. The
documents listed in the Attachment were used by the inspectors to accomplish the
objectives of the inspection procedure. Maintenance activities were reviewed to assess
maintenance effectiveness, including maintenance rule activities, work practices, and
common cause issues. Inspection activities included, but were not limited to, the
Enclosure
10
licensee's categorization of specific issues including evaluation of maintenance
performance criteria, appropriate work practices, identification of common cause errors,
extent of condition, and trending of key parameters. Additionally, the inspectors
reviewed implementation of the maintenance rule (10 CFR 50.65) requirements,
including a review of scoping, goal-setting, performance monitoring, short-term and
long-term corrective actions, functional failure determinations associated with reviewed
condition reports, and current equipment performance status.
The inspectors performed the following maintenance effectiveness reviews for a total of
two samples:
An issue/problem-oriented review of the Control Building/Reactor Building
Radiation Monitors was performed, because it was designated as risk-significant
under the maintenance rule, during the week ending November 5, 2005; and
A function-oriented review of the Offsite Power System was performed because it
was designated as risk-significant under the maintenance rule, during the week
ending November 5, 2005.
b.
Findings
No findings of significance were identified.
1R13
Maintenance Risk Assessments and Emergent Work Control (71111.13)
a.
Inspection Scope
The inspectors reviewed the licensees evaluation of plant risk, scheduling, and
configuration control for a total of three samples. An evaluation of the performance of
maintenance associated with planned and emergent work activities was completed by
the inspectors to determine if they were adequately managed. In particular, the
inspectors reviewed the program for conducting maintenance risk safety assessments to
ensure that the planning, assessment and management of on-line risk was adequate.
The documents listed in the Attachment were used by the inspectors to accomplish the
objectives of the inspection procedure. Licensee actions taken in response to increased
on-line risk were reviewed, including the establishment of compensatory actions,
minimizing activity duration, obtaining appropriate management approval, and informing
appropriate plant staff. These activities were accomplished when on-line risk was
increased due to maintenance on risk-significant structures, systems, and components
(SSCs).
The following activities were reviewed for a total of three samples:
The inspectors reviewed the maintenance risk assessment for work planned
during the weeks of October 8, 22, and 29, 2005.
b.
Findings
No findings of significance were identified.
Enclosure
11
1R15
Operability Evaluations (71111.15)
a.
Inspection Scope
The inspectors reviewed one of the licensees operability evaluations of degraded or
non-conforming systems. The documents listed in the Attachment were used by the
inspectors to accomplish the objectives of the inspection procedure. An operability
evaluation, which affected the mitigating systems cornerstone was reviewed to ensure
adequate justification for declaration of operability and that the component or system
remained available. Inspection activities included, but were not limited to, a review of
the technical adequacy of the evaluation against the Technical Specifications (TSs),
UFSAR, and other design information; validation that appropriate compensatory
measures, if needed, were taken; and comparison of each operability evaluation for
consistency with the requirements of ACP-114.5, Action Request System and
ACP-110.3, Operability Determination.
The inspectors reviewed the following operability evaluations for a total of one sample:
Condition Evaluation (CE) 003049, HPCI Venting Operability, during the week
ending October 22, 2005.
b.
Findings
No findings of significance were identified.
1R16
Operator Workarounds (OWA) (71111.16)
.1
Semi-Annual Workaround Review
a.
Inspection Scope
During the week ending November 12, 2005, the inspectors performed a semi-annual
review of the cumulative effects of OWAs for a total of one sample. The documents
listed in the Attachment were reviewed to accomplish the objectives of the inspection
procedure. OWAs were reviewed to identify any potential effect on the functionality of
mitigating systems. Inspection activities included, but were not limited to, a review of the
cumulative effects of the operator workarounds on the availability and the potential for
improper operation of the system, for potential impacts on multiple systems, and on the
ability of operators to respond to plant transients or accidents. Additionally, reviews
were conducted to determine if the workarounds could increase the possibility of an
initiating event, if the workaround was contrary to training, required a change from long
standing operational practices, created the potential for inappropriate compensatory
actions, impaired access to equipment, or required equipment uses for which the
equipment was not designed.
b.
Findings
No findings of significance were identified.
Enclosure
12
1R19
Post-Maintenance Testing (71111.19)
a.
Inspection Scope
The inspectors reviewed four post-maintenance testing (PMT) activities. The documents
listed in the Attachment were used to accomplish the objectives of the inspection
procedure. PMT procedures and activities were verified to be adequate to ensure
system operability and functional capability. Inspection activities were selected based
upon the SSCs ability to impact risk. Inspection activities included, but were not limited
to, witnessing or reviewing the integration of testing activities, applicability of acceptance
criteria, test equipment calibration and control, procedural use and compliance, control
of temporary modifications or jumpers required for test performance, documentation of
test data, system restoration, and evaluation of test data. Also, the inspectors verified
that maintenance and PMT activities adequately ensured that the equipment meets the
licensing basis, TS, and UFSAR design requirements.
The inspectors selected the following PMT activities for review for a total of four
samples:
Modification Work Order (MWO) 1133138, Startup Transformer Feeder to 1A4,
during the week ending October 29, 2005;
MWO 1133137, Standby Transformer Feeder to 1A4, during the week ending
October 29, 2005;
Preventative Work Order (PWO) 1132174, A Standby Diesel Generator, during
the week ending November 19, 2005; and
MWO 1133139, Feeder Breaker from 1G-21/Generator to 1A4, during the week
ending November 26, 2005.
b.
Findings
No findings of significance were identified.
1R22
Surveillance Testing (71111.22)
a.
Inspection Scope
The inspectors reviewed four surveillance test activities. Inspection procedure
objectives were accomplished as indicated by the documents listed in the Attachment to
this inspection report. Surveillance testing activities were reviewed to assess
operational readiness and ensure that risk-significant SSCs were capable of performing
their intended safety function. Surveillance activities were selected based upon risk
significance and the potential risk impact from an unidentified deficiency or performance
degradation that an SSC could impose on the unit if the condition were left unresolved.
Inspection activities included, but were not limited to, a review for preconditioning,
integration of testing activities, applicability of acceptance criteria, test equipment
calibration and control, procedural use, control of temporary modifications or jumpers
required for test performance, documentation of test data, TS applicability, impact of
testing relative to Performance Indicator (PI) reporting, and evaluation of test data.
Enclosure
13
The inspectors selected the following surveillance testing activities for review for a total
of four samples:
Surveillance Test Procedure (STP) 3.5.1-05, HPCI Operability Test, during the
week ending October 15, 2005;
STP 3.8.1-06, B SBDG Fast Start, during the week ending October 22, 2005;
STP 3.3.1.1-24, Local Power Range Monitor Calibration, during the week ending
November 5, 2005; and
STP 3.5.3-02 RCIC Operability Test, during the week ending
November 12, 2005.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems (71152)
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
.1
Routine Review of Identification and Resolution of Problems
a.
Inspection Scope
For inspections performed and documented in previous sections of this report, the
inspectors routinely reviewed issues during baseline inspection activities and plant
status reviews to verify that they were being entered into the corrective action program
at an appropriate threshold, that adequate attention was being given to timely corrective
actions, and that adverse trends were identified and addressed. Minor issues entered
into the corrective action program as a result of the inspectors observations are
included in the attached list of documents reviewed. This activity does not count as an
annual sample.
b.
Findings
Introduction: A finding of very low safety significance (Green) and an associated NCV of
License Condition 2.C.(3) were identified by the inspectors for failing to promptly identify
and correct issues with the control of transient combustibles.
Description: The inspectors determined that the licensee had, during several
opportunities, failed to take timely and effective corrective actions with respect to the
control of transient combustibles. The first issue associated with the failure to properly
control transient combustibles, occurred on May 27, 2005, when the inspectors identified
that the licensee had failed to place a combustible material permit on a scaffold that had
wood planking in the reactor building. This issue resulted in NCV 05000331/2005009-01
being issued for the failure to control and identify transient combustibles. The corrective
actions to the issue as documented in CAP 36606 identified this as an isolated case,
therefore, no further corrective actions were taken.
Enclosure
14
An additional failure to control transient combustibles, occurred on September 27, 2005,
when the licensee identified that a scaffolding with wood planking in the A ESW pump
room did not have a combustible material permit. The corrective actions to the issue as
documented in CAP 38085 identified this as an isolated case.
Following the second occurrence, a CE was performed. The CE also came to the
conclusion that this was an isolated case. Therefore, no further corrective actions were
taken.
On October 25, 2005, the inspectors identified another issue associated with the failure
to properly control transient combustibles in the southeast corner room of the reactor
building. The inspectors then contacted the Fire Protection Program Engineer on the
issue. This resulted in an extent of condition review being performed where two
additional examples of the failure to properly control transient combustibles in the reactor
building were identified. This resulted in an apparent cause evaluation being performed.
Of particular note, Section 4.10 of the Fire Plan stated that the Fire Marshal was
responsible for conducting periodic inspections to minimize combustibles within the
owner-controlled area. In addition, procedure ACP 1412.2, Control of Combustibles,
stated that the Fire Marshal was responsible for performing periodic inspections to
assure transient combustibles were located, used, and documented with a Combustible
Material/Flammable Liquid Control permit. The identified failures to properly control
combustible materials that had been in the plant for a time period of 63 days to more
than one year, raised an issue regarding how effective periodic inspections were in
identifying transient combustibles and why this was not identified during corrective action
reviews.
Analysis: The inspectors determined that failing to correct deficiencies associated with
control of transient combustibles was an example of not complying with a standard that
could have reasonably been foreseen or corrected by the licensee, and was, therefore, a
performance deficiency. Since a performance deficiency existed, the inspectors
reviewed this issue against the guidance contained in Appendix B, Issue Screening, of
IMC 0612, Power Reactor Inspection Reports. In particular, the inspectors compared
this finding to the findings identified in Appendix E, Examples of Minor Issues and
Cross-Cutting Aspects, of IMC 0612 to determine whether the finding was minor.
Following that review, the inspectors concluded that the guidance in Appendix E
example 3.g. was applicable for the specific finding. The finding was greater than minor
because the licensee failed to take actions to correct repetitive nonconforming
conditions. In addition, the finding affected the cross-cutting area of Problem
Identification and Resolution due to inadequate corrective actions for the deficiencies
associated with the control of transient combustibles.
As a result, the inspectors reviewed this issue in accordance with IMC 0609,
Appendix FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Fire Protection SDP, Attachment 2, Degradation Rating Guidance
Specific to Various Fire Protection Program Elements. The inspectors determined that
the unapproved presence of wood planking on scaffolding was a low degradation finding
against the combustible controls program because wood will not cause a fire from
existing sources of heat or electrical energy. After identifying that the issue had a low
degradation rating, the inspectors used IMC 0609, Appendix F, Attachment 1,
Enclosure
15
Application of Fire Protection SDP Phase 1 Worksheet, Task 1.3.1, Qualitative
Screening for All Finding Categories for determining the severity level. Since the finding
had a low degradation rating, it was of very low safety significance and screened as
Green.
Enforcement: License Condition 2.C.(3) required NMC to implement and maintain in
effect all provisions of the approved fire protection program as described in the DAEC
FSAR, which describes the fire protection program as contained in the Fire Plan and
was incorporated into the UFSAR by reference. Appendix A, Section C.8., Corrective
Action, of Branch Technical Position 9.5-1, states that measures to assure conditions
adverse to fire protection, such as uncontrolled combustible material and
nonconformances, are promptly identified and corrected. The licensee committed to this
without any noted exception. Section 4.10 of the Fire Plan gave the Fire Marshal the
responsibility for conducting periodic inspections to minimize combustibles within the
owner-controlled area and for evaluating conditions likely to reduce the effectiveness of
the Fire Program or any of its part and initiating corrective action. Section 6.1 of the Fire
Plan referenced ACP 1412.2, assigning inspection responsibility to the Fire Marshal, to
assure transient combustibles were located, used, and documented in accordance with
ACP 1412.2. ACP 1412.2 also defined wood as a class A material, and required a
Combustible Material/Flammable Liquid Control permit for bringing more than
100 pounds of such material into the power block. Contrary to the above, from a period
of May 27, 2005 through October 25, 2005, the licensee failed to properly control
transient material. In addition, the routine walkdowns performed by the Fire Marshal
also failed to identify these discrepancies. Once identified, the licensee initiated
CAP 38552. Because this violation was of very low safety significance and entered into
the licensees corrective action program, this violation is being treated as an NCV, per
Section VI.A of the NRC Enforcement Policy. (NCV 05000331/2005005-02)
Corrective actions taken included an extent of condition review, which identified two
additional scaffolds with wood planks that did not have the required combustible permit.
Appropriate combustible permits were placed on all three scaffolds. In addition, an
apparent cause evaluation was performed.
.2
Daily Corrective Action Program Reviews
a.
Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees corrective action program. This review was
accomplished through inspection of the stations daily condition report packages. This
activity does not count as an annual sample.
Enclosure
16
b.
Findings
One specific issue which involved a Licensee-Identified Violation was identified during
this daily review as discussed in Section 4OA7.
.3
Semi-Annual Trend Review
a.
Inspection Scope
Inspectors performed a review of the licensees CAPs and associated documents to
identify trends that could indicate the existence of a more significant safety issue. This
review focused on repetitive equipment issues, but also considered the results of daily
inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending
efforts, and licensee human performance results. Nominally, the review considered the
6-month period of June 2005 through December 2005, although some examples
expanded beyond those dates when the scope of the trend warranted.
The inspectors semi-annual trend review also included issues documented in major
equipment problem lists, repetitive and/or rework maintenance lists, departmental
problem/challenges lists, system health reports, quality assurance audit/surveillance
reports, self-assessment reports, and maintenance rule assessments. The results of
this trend review were compared and contrasted with the results contained in the
licensees CAP and Nuclear Oversight Department reports. Corrective actions
associated with a sample of the trends identified by the licensee were reviewed for
adequacy.
Inspectors also evaluated the licensees trending CAPs against the requirements of the
licensees Corrective Action Program as specified in ACP 114.8, Action Request
Trending, Revision 5. Additional documents reviewed are listed in the attachment. This
activity does not count as an annual sample.
b.
Findings and Issues
No findings or issues of significance were identified.
.4
Status of Human Performance Cross-Cutting Issue Corrective Actions
a.
Introduction
During the mid-cycle assessment for the 2005 calendar year inspection program, the
NRC staff identified a substantive cross-cutting issue in the area of human performance.
The results of this assessment were provided to the licensee in August 2005, in the
Duane Arnold Energy Center Mid-Cycle Performance Review letter.
Specifically, the findings and associated violations were attributed to inadequate human
performance associated with procedural requirements.
The licensee has continued to revise and enhance their human performance
improvement plan to address these issues.
Enclosure
17
This review counts as one annual sample.
b.
Effectiveness of Corrective Actions
(1)
Inspection Scope
The inspectors reviewed the licensees comprehensive human performance
improvement plan and related documents in detail, with the intent of determining
whether or not the corrective actions addressed generic implications, and to verify that
they were appropriately focused to correct the human performance problems. The
specific focus for the inspectors review was the time period from July 1, 2005, through
December 2, 2005.
(2)
Issues
For the focus period noted above, the inspectors identified two findings and associated
violations of very low safety significance (Green) where human performance was not
adequate. In both of these instances procedural requirements were not followed.
In addition to the items above that met the threshold for being documented in an
inspection report, another 13 minor issues were identified with human performance as
the primary or contributing cause for the focus period. Once again, these issues were
associated with procedural requirements. These minor issues resulted in department
clock resets for operations, maintenance, security, engineering, training, radiation
protection, and chemistry. In addition, there were five site clock resets for human
performance during this time frame.
The inspectors also analyzed the data to identify whether or not the trend in human
performance issues was declining, improving, or steady. Based on the analyzed data for
the associated time period, the inspectors determined that the effectiveness of the
licensees corrective actions for the human performance substantive cross-cutting issue
was indeterminate, as evidenced by the continued occurrence of human performance
events and issues at the station. The inspectors will continue to evaluate the licensees
efforts to improve human performance by reviewing the cumulative effect of their
corrective actions.
4OA5 Other Activities
(Closed) Unresolved Issue (URI) 05000331/2004-004: Failure to Demonstrate the
Capability to Achieve and Maintain Safe Shutdown Conditions Due to Bus Lockout.
On June 2, 2005, a review of an event reported at Monticello resulted in the
determination that Duane Arnold Energy Center was vulnerable to a similar issue in that,
the Remote Shutdown Panel did not meet design criteria for Appendix R, because the
metering circuits in the control room could cause a lock out of an essential bus. Control
room 4160 VAC current sensing and protective relaying circuits for the standby
transformer, the startup transformer, and the 1G21 diesel generator, as well as the
kilowatt meter for the 1G21 diesel generator has the potential to initiate a 1A4 essential
power bus lockout if a hot short were to occur in this control room circuitry. In a
Enclosure
18
potential fire event, it is plausible that an outside voltage source in contact with one or
more current transformer phase legs, could force current through the over-current trip
relay causing them to trip, thereby resulting in lockout signals at essential bus 1A4 or the
1G21 diesel generator. The inspectors determined that the licensee failed to identify the
single failure vulnerability associated with the ammeter circuits when the remote
shutdown panel was designed and installed from 1983 to 1985. The licensee entered
this issue into their corrective action program as CAP 35060. On June 17, 2005, a
temporary modification was implemented that disconnected control room ammeter
cables in the 1A4 essential switchgear room removing the possibility of a hot short
lockout. The inspectors reviewed the licensees corrective actions and risk assessment.
Upon a further review, no issues were identified with the effectiveness of the corrective
actions associated with this operating experience review. The licensees risk
assessment calculated a change in core damage frequency due to this issue of
5.6E-7/yr. The RIII Senior Reactor Analyst (SRA) reviewed this calculation and
determined that the analysis and results were reasonable, so this finding was
determined to be characterized as having very low safety significance (Green).
Therefore, URI 05000331/2005004-04 is closed to the licensee identified violation as
described in Section 4OA7.
4OA6 Meetings
.1
Exit Meeting
The inspectors presented the inspection results to Mr. G. Van Middlesworth and other
members of licensee management on January 13, 2006. The licensee acknowledged
the findings presented. The inspectors asked the licensee whether any materials
examined during the inspection should be considered proprietary. No proprietary
information was identified.
.2
Interim Exit Meetings
Interim exit meetings were conducted for:
The Biennial Heat Sink Inspection, with Mr. G. Van Middlesworth, Site Vice
President, on October 7, 2005.
Operator Requalification Program Examination Result Review with
Mr. M. Fisher via telephone on December 29, 2005.
4OA7 Licensee-Identified Violations
The following violation of very low significance was identified by the licensee and is a
violation of NRC requirements which meets the criteria of Section VI of the NRC
Enforcement Manual, NUREG-1600, for being dispositioned as an NCV.
Cornerstone: Mitigating Systems
.1
This finding relates to URI 05000331/2005004-04, as discussed in Section 4OA5 of this
report. 10 CFR 50, Appendix B, Criterion III, Design Control, states, in part, that design
Enclosure
19
changes, including field changes, shall be subject to design control measures
commensurate with those applied to the original design. Contrary to this requirement,
the licensee failed to identify the single failure vulnerability associated with the ammeter
circuits when the remote shutdown panel was designed and installed from 1983 to 1985.
The finding was identified by the licensee through its external event review process. The
licensee performed a risk evaluation of this finding which was reviewed by the RIII SRA
as a Phase III SDP evaluation. A Phase II inspection of the IMC 0609, Appendix F, Fire
Protection Significance Determination Process, was not applicable because this issue
applied only to fire scenarios which required the use of the alternate shutdown system,
(i.e., control room evacuation scenarios). The alternate shutdown system relied on
power supplied from the Division II electrical switchgear room. A hot short in the
metering circuit for this division would result in a lockout of the power supply and it would
be unable to supply power for an alternate shutdown. The licensee determined that a
fire in one of three separate panels in the control room could result in the hot short
occurring and could result in control room evacuation if the fire was not suppressed.
Based on this information and using a non-suppression probability of 1E-2 to represent
the failure to suppress the fire in 15 minutes, the licensee calculated a change in core
damage frequency due to this issue of 5.6E-7/yr. The SRA reviewed this calculation and
determined that the analysis and results were reasonable. Therefore, this finding was
determined to be best characterized as having very low safety significance (Green).
Since the licensee identified the problem and took corrective actions, this violation is
being treated as an NCV. The licensee entered this issue into their corrective action
program as CAP 35060.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
G. Van Middlesworth, Site Vice President
J. Bjorseth, Site Director
D. Curtland, Plant Manager
S. Catron, Nuclear Safety Assurance Manager
S. Haller, Site Engineering Director
B. Kindred, Security Manager
C. Kress, Training Manager
G. Rushworth, Operations Manager
G. Pry, Maintenance Manager
J. Windschill, Chemistry and Radiation Protection Manager
NRC personnel
D. Spaulding, Project Manager, NRR
B. Burgess, Chief, Reactor Projects Branch 2
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Failure to Identify and Control Transient Combustibles in
the Southeast Corner Room of the Reactor Building (1R05)05000331/2005005-02
Inadequate Corrective Actions for the Control of Transient
Combustibles (4OA2)
Closed
Failure to Identify and Control Transient Combustibles in
the Southeast Corner Room of the Reactor Building (1R05)05000331/2005005-02
Inadequate Corrective Actions for the Control of Transient
Combustibles (4OA2)05000331/2005004-04
Failure to Demonstrate the Capability to Achieve and
Maintain Safe Shutdown Conditions Due to Bus Lockout
(4OA5)
Attachment
2
Discussed
None.
Attachment
3
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety but rather that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
Section 1R01: Adverse Weather
Integrated Plant Operating Instruction (IPOI) 6, Cold Weather Operations, Revision 32
Operating Instruction (OI) 711A2, Pumphouse HVAC Valve Lineup, Revision 1
OI 711A1, Pumphouse HVAC Electrical Lineup, Revision 1
OI 711A3, Pumphouse HVAC Control Panel Lineup, Revision 1
OI 710A2, Intake Structure HVAC System Valve Lineup, Revision 1
OI 710A1, Intake Structure HVAC System Electrical Lineup, Revision 2
Task 019, Inspect and functionally check and calibrate the Pumphouse ventilation dampers and
pressure/temperature controllers, Revision 3
Task 48, Inspect Unit Heaters, Revision 0
Task 84, IPOI 6 Unit Heater Inspection, Revision 0
Task 85, IPOI 6 Heat Tracing Inspection, Revision 0
PWO 1132014, Intake Structure North Fan Damper DO7711A, October 20, 2005
PWO 1132012, Intake Structure North Fan Damper DO7710A, October 20, 2005
PWO 1132010, Intake Structure North Fan Damper DO7709A, October 20, 2005
OI 985, Plant Cathodic and Freeze Protection System, Revision 13
OI 985A1, Cathodic Protection Electrical Lineup, Revision 0
OI 985A2, Freeze Protection Electrical Lineup, Revision 4
OI 537, Condensate/Demin Services Water, Revision 32
PWO 1132507, Cathodic and Freeze Protection System Inspection, November 4, 2005
Section 1R04: Equipment Alignment
OI 150A1, RCIC System Electrical Lineup, Revision 0
OI 150A2, RCIC System Valve Lineup and Checklist, Revision 8
OI 150A4, RCIC Control Panel Lineup, Revision 1
OI 410A1, RWS System Electrical Lineup, Revision 8
OI 410A4, B RWS System Valve Lineup and Checklist, Revision 7
OI 324A2, SBDG 1G-21 System Electrical Lineup, Revision 1
OI 324A4, SBDG 1G-21 System Valve Lineup and Checklist, Revision 2
OI 324A8, SBDG 1G-21 System Control Panel Lineup, Revision 0
OI 324A1, SBDG 1G-31 System Electrical Lineup, Revision 1
OI 324A3, SBDG 1G-31 System Valve Lineup and Checklist, Revision 2
OI 324A7, SBDG 1G-31 System Control Panel Lineup, Revision 1
Attachment
4
Section 1R05: Fire Protection
ACP 1412.2, Control of Combustibles, Revision 24
AFP 31, Intake Structure Pump Area, Revision 25
AFP 32, Intake Structure Traveling Screen Area, Revision 27
AFP 23, Control Building 1D-2, 1D-4, 1D-1 Battery Rooms and Battery Corridor, Revision 24
AFP 24, Control Building 1A-4, 1A-3 Essential Switchgear Rooms, Revision 28
AFP 28, Pump House ESW/RHRSW Pump Rooms and Main Pump Room, Revision 29
AFP 2, Reactor Building South Corner Rooms, Revision 23
CAP 38552, Scaffold in SE Corner Room without Combustible Materials Tag, October 25, 2005
(NRC Identified)
Section 1R07: Heat Sink Performance (71111.07)
466M003, RCIC Room Cooling Units and HPCI Room Cooling Units, Revision 0
CAL-M05-003, RCIC Emergency Room Cooler Heat Transfer Calculation, Revision 8
CAL-M05-004, HPCI Emergency Room Cooler Heat Transfer Calculation, Revision 8
CAP 27143, Tube leak on 1VAC015A (RCIC room cooling unit), dated April 22, 2003
CAP 30567, Inadequate documentation of HPCI and RCIC room cooler design basis, dated
January 30, 2004
CAP 33858, RCIC room cooler 1VAC015A has a 2-3 dpm leak from a tube, dated
November 16, 2004
CAP 33872, Non code repair performed on 1VAC015A without prior NRC approval, dated
November 16, 2004
FSAR040654, Revise UFSAR table 9.2-1 required ESW flow rates, dated August 7, 2005
OTH037448, Prepare new HPCI and RCIC room heat up calculations dated March 16, 2004
System Description, ESW SD-454, Revision 3
72B123-R1, 1VAC14A HPCI Room Cooler, dated January 13, 1972
72B124-R1, 1VAC14B HPCI Room Cooler, dated January 13, 1972
72B125-R1, 1VAC15A RCIC Room Cooler; dated January 14, 1972
72B126-R1, 1VAC15B RCIC Room Cooler; dated January 14, 1972
Material List for CIG 2.92, Unit 1VAC15A and 1VAC15B, Revision 4
Material List for F2G 8.03, Unit 1VAC14A and 1VAC14B, Revision 4
PCR041074, Revise ACP 1208.4 with new minimum flow rate, dated October 5, 2005 (NRC
Identified)
ACP 1208.4, GL 89-13 Heat Exchanger Performance and Trending, Revision 7
ACP 1208.5, Service Water Reliability Program, Revision 2
Abnormal Operating Procedure (AOP) 410 Loss of RWS, Revision 17
Annunciator Response Procedure (ARP) 1C23A, HVAC Reactor Building and Main Plant Air -
Panel 1C23A, Revision 2
ARP 1C23B, Main Plant HVAC, Revision 5
Corrosion Monitoring Program Manual, DAEC, Revision 6
FP-PE-SW-01, Service Water and Fire Protection Inspection Program, Revision 1
GMP-MECH-26, Heat Exchangers, Revision 7
OI 410, RWS System, Revision 48
STP NS54002, ESW Operability Test, Revision 16
EMP-1P099-FV, Emergency Service Water Flow Verification Test, dated February 15, 2002
FAC Component Evaluation Report for HBD-24, Outage RFO-15
FAC Component Evaluation Report for HBD-24, Outage RFO-16
Attachment
5
STP NS100102, RWS and Screen Wash System Vibration Measurement and Operability
Test A, dated August 7, 2005
STP NS100102, RWS and Screen Wash System Vibration Measurement and Operability
Test B, dated August 14, 2005
STP NS54002, ESW Operability Test B, dated September 3, 2004
STP NS54002, ESW Operability Test A, dated September 9, 2004
WO1117721, RCIC Room Cooling Unit, dated October 2, 2001
WO1119642, HPCI Room Cooling Unit, dated May 14, 2002
WO1121564, RCIC Room Cooling Unit, dated October 23, 2002
WO1123712, HPCI Room Cooling Unit, dated April 29, 2003
WO1125110, RCIC Room Cooling Unit, dated October 7, 2003
WO1126683, HPCI Room Cooling Unit, dated March 25, 2004
WO1127819, RCIC Room Cooling Unit, dated September 10, 2004
WO1131213, HPCI Room Cooling Unit, dated August 22, 2005
WO1133615, Inspect and Clean as Needed, B Intake Structure Pit, dated September 27, 2005
Section 1R11: Licensed Operator Requalification Program
SEG 2005E-01, Steam Leak Inside Primary Containment/High Drywell Pressure, Revision 0
Emergency Operating Procedure (EOP) 2, Primary Containment Control, Revision 12
EOP 1, Reactor Pressure Control, Revision 13
Emergency Action Level (EAL) Table 1, Revision 6
ACP 110.1, Conduct of Operations, Revision 3
ACP 101.01, Procedure Use and Adherence, Revision 33
ACP 101.2, Verification Process and SELF / PEER Checking Practices, Revision 5
Section 1R12: Maintenance Effectiveness
DAEC Cycle 19 Maintenance Rule Periodic Review, October 06, 2005
Maintenance Rule Monitoring and Status Report, October 07, 2005
Maintenance Rule Performance Criteria Basis Document for Offsite Power, Revision 3
Maintenance Rule Criteria Values for Offsite Power, October 31, 2005
Maintenance Rule Performance Criteria Basis Document for Control Building Heating
Ventilation and Air-Conditioning System, Revision 5
Maintenance Rule Performance Criteria Basis Document Control Room Indication
Instrumentation Used for Significant EOP Decisions, Revision 0
Maintenance Rule Performance Criteria Basis Document Annunciators, Revision 3
Corrective Action (CA) 040760, RCE1034 Interim Corrective Action for ECP1628 CB/RB
Radiation Monitor Replacement, dated August 12, 2005
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Work Procedure Guidelines (WPG) - 2, On-Line Risk Management Guideline, Revision 20
Maintenance Risk Evaluation for Week 40, September 29, 2005, Revision 1, October 2, 2005,
and Revision 2, October 3, 2005
DAEC Online Schedule, Week 9539/9540, September 30, 2005
Maintenance Risk Evaluation for Week 42, October 14, 2005
DAEC Online Schedule, Week 9541/9542, October 14, 2005
Maintenance Risk Evaluation for Week 43, October 21, 2005
Attachment
6
DAEC Online Schedule, Week 9542/9543, October 21, 2005
Section 1R15: Operability Evaluations
ACP 110.3, Operability Determination, Revision 3
ACP 114.5, Action Request System, Revision 472
CE003049, Condition Evaluation Documenting HPCI System Venting Operability, HPCI System,
October 12, 2005
Section 1R16: Operator Workarounds
ACP 1410.12, Operator Burden Program, Revision 5
Operations (OP)-001, Operator Burden and Tagout (Section) Audit, Revision 33, dated
October 15, 2005
OWA 05-001, Potential Vulnerability for lockout of 1A4 power supply to the Alternate Shutdown
Panel, June 2, 2005
OWA 05-002, Turbine Steam Seal Main Steam Supply (CV-1175) Isolation,
September 22, 2005
Operator Challenge 05-001, 1P-5A/1P-5B Condensate Pump Operations, May 6, 2005
Operator Challenge 05-003, Feedwater regulating valve controller programing uncertainties,
May 30, 2005
Operator Challenge 05-006, HPCI system Operable But Degraded requiring compensatory
actions, October 12, 2005
Operator Challenge 05-007, Rod 18-15 double notched on withdrawal and twice failed to insert,
October 30, 2005
Section 1R19: Post-Maintenance Testing
Maintenance Directive-024, Post Maintenance Testing Program, Revision 34
MWO 1133138, Startup Transformer Feeder to 1A4, October 21, 2005
MWO 1133137, Standby Transformer Feeder to 1A4, October 21, 2005
PWO 1132174, A Standby Diesel Generator, October 31, 2005
MWO 1133139, Feeder Breaker from 1G-21/Generator to 1A4, November 10, 2005
Section 1R22: Surveillance Testing
STP 3.5.1-05, HPCI System Operability Test, Revision 23
STP 3.8.1-06, Standby Diesel Generators Operability Test (Fast Start), Revision 25
STP 3.3.1.1-24, Local Power Range Monitor Calibration, Revision 10
STP 3.5.3-02, RCIC System Operability Test, Revision 17
Section 4OA2: Identification and Resolution of Problems
ACP 114.4, Corrective Action Program, Revision 20
CAP 38552, Scaffold in SE Corner Room without Combustible Materials Tag, October 25, 2005
(NRC Identified)
Condition Evaluation 3035, Untagged Scaffold in the A ESW Room, September 29, 2005
Apparent Cause Evaluation 1516, Erected Scaffolding found without Combustible Control Tags,
October 27, 2005
Attachment
7
CAP 26606, Control of Combustibles, May 27, 2005 (NRC Identified)
CAP 38085, Untagged Scaffold in the A ESW Room, September 27, 2005
ACP 1412.2, Control of Combustibles; Revision 24
RCE 001035, Cross Cutting Finding in the Area of Human Performance, September 2, 2005
Section 4OA5: Other Activities
Licensee Event Report (LER) 2005-001, Failure to Demonstrate the Capability to Achieve and
Maintain Safe Shutdown Conditions, August 1, 2005
CAP 35060, Corrective Action Does Not Address all Failure Sequences, June 2, 2005
Section 4OA7: Licensee-Identified Violations
CAP 35060, Corrective Action Does Not Address all Failure Sequences, June 2, 2005
LIST OF ACRONYMS USED
Attachment
8
Administrative Control Procedure
AFP
Area Fire Plan
Annunciator Response Procedure
Abnormal Operating Procedure
Corrective Action Plan
Condition Evaluation
CFR
Code of Federal Regulations
Duane Arnold Energy Center
Emergency Action Level
Emergency Operating Procedure
Emergency Service Water
High Pressure Core Injection
Heating, Ventilation, Air-Conditioning
IMC
Inspection Manual Chapter
Individual Plant Examination of External Events
IPOI
Integrated Operating Instructions
IR
Inspection Report
LER
Licensee Event Report
MWO
Modified Work Order
NRC
Nuclear Regulatory Commission
Non-Cited Violation
Operating Instruction
Out Of Service
OP
Operations
Operator Workaround
Protected Area
Publicly Available Records
Performance Indicator
Post-Maintenance Testing
PWO
Preventive Work Order
Reactor Core Isolation Cooling
Residual Heat Removal Service Water
RWS
River Water Supply
SBDG
Standby Diesel Generator
Significance Determination Process
SEG
Simulator Exercise Guide
Structures, Systems, Components
Surveillance Test Procedure
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved Issue
WPG
Work Procedure Guidelines
Work Order