ML14224A150
| ML14224A150 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 08/11/2014 |
| From: | Christine Lipa NRC/RGN-III/DRP/B1 |
| To: | Richard Anderson NextEra Energy Duane Arnold |
| References | |
| IR-14-003 | |
| Download: ML14224A150 (49) | |
See also: IR 05000331/2014003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, IL 60532-4352
August 11, 2014
Mr. Richard L. Anderson
Vice President
NextEra Energy Duane Arnold, LLC
3277 DAEC Road
Palo, IA 52324-9785
SUBJECT: DUANE ARNOLD ENERGY CENTER - NRC INTEGRATED INSPECTION
REPORT 05000331/2014003
Dear Mr. Anderson:
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated
inspection at your Duane Arnold Energy Center. The enclosed report documents the results of
this inspection, which were discussed on July 21, 2014, with you and other members of your
staff.
Based on the results of this inspection, three NRC-identified findings of very low safety
significance were identified. The findings involved violations of NRC requirements. However,
because of their very low safety significance, and because the issues were entered into your
corrective action program, the NRC is treating the issues as non-cited violations (NCVs) in
accordance with Section 2.3.2 of the NRC Enforcement Policy. Additionally, two licensee-
identified violations are listed in Section 4OA7 of this report.
If you contest the subject or severity of any NCV, 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, DC 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, DC 20555-0001; and the Resident Inspector
Office at the Duane Arnold Energy Center. In addition, if you disagree with the cross-cutting
aspect assigned to any finding in this report, you should provide a response within 30 days of
the date of this inspection report, with the basis for your disagreement, to the Regional
Administrator, Region III, and the NRC Resident Inspector at the Duane Arnold Energy Center.
R. Anderson -2-
In accordance with Title 10 of the Code of Federal Regulation 2.390, Public Inspections,
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter
and its enclosure, and your response (if any) will be available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Christine Lipa, Chief
Branch 1
Division of Reactor Projects
Docket No. 50-331
License No. DPR-49
Enclosure:
Inspection Report 05000331/2014003
w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-331
License No: DPR-49
Report No: 05000331/2014003
Licensee: NextEra Energy Duane Arnold, LLC
Facility: Duane Arnold Energy Center
Location: Palo, IA
Dates: April 1 through June 30, 2014
Inspectors: L. Haeg, Senior Resident Inspector
J. Steffes, Resident Inspector
D. Oliver, Reactor Inspector
S. Shah, Reactor Engineer
V. Myers, Health Physicist
R. Elliott, Reactor Engineer
C. Norton, Project Manager
Approved by: Christine Lipa, Chief
Branch 1
Division of Reactor Projects
Enclosure
TABLE OF CONTENTS
SUMMARY OF FINDINGS ........................................................................................................... 2
REPORT DETAILS ....................................................................................................................... 5
Summary of Plant Status ........................................................................................................... 5
1. REACTOR SAFETY ....................................................................................................... 5
1R01 Adverse Weather Protection (71111.01) .............................................................. 5
1R04 Equipment Alignment (71111.04) ........................................................................ 6
1R05 Fire Protection (71111.05) ................................................................................... 7
1R06 Flooding (71111.06) ............................................................................................. 7
1R11 Licensed Operator Requalification Program (71111.11) ...................................... 8
1R12 Maintenance Effectiveness (71111.12) ................................................................ 9
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) ........ 12
1R15 Operability Determinations and Functionality Assessments (71111.15) ............ 13
1R18 Plant Modifications (71111.18) .......................................................................... 17
1R19 Post-Maintenance Testing (71111.19) ............................................................... 17
1R22 Surveillance Testing (71111.22) ........................................................................ 18
2. RADIATION SAFETY ................................................................................................... 19
2RS5 Radiation Monitoring Instrumentation (71124.05) .............................................. 19
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) ...................... 20
4. OTHER ACTIVITIES .................................................................................................... 26
4OA1 Performance Indicator (PI) Verification (71151) ................................................. 26
4OA2 Identification and Resolution of Problems (71152) ............................................ 27
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) ............... 33
4OA6 Management Meetings ...................................................................................... 33
4OA7 Licensee-Identified Violations ............................................................................ 33
SUPPLEMENTAL INFORMATION ............................................................................................... 1
KEY POINTS OF CONTACT..................................................................................................... 1
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ......................................................... 2
LIST OF DOCUMENTS REVIEWED......................................................................................... 3
LIST OF ACRONYMS USED .................................................................................................. 10
SUMMARY OF FINDINGS
Inspection Report 05000331/2014003; 04/01/2014 - 06/30/2014, Duane Arnold Energy Center;
Maintenance Effectiveness, Operability Determinations and Functionality Assessments, and
Identification and Resolution of Problems.
This report covers a three-month period of inspection by resident inspectors and announced
baseline inspections by regional inspectors. Three Green findings were identified by the
inspectors. The findings were considered non-cited violations (NCVs) of Nuclear Regulatory
Commission (NRC) regulations. The significance of inspection findings is indicated by their
color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection
Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011.
Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting
Areas effective date January 1, 2014. All violations of NRC requirements are dispositioned in
accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's program for
overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.
NRC-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
- Green. The inspectors identified a finding of very low safety significance (Green) and
associated non-citied violation of Duane Arnold Energy Center (DAEC) Renewed
Operating License Condition 2.C.(3), for the failure to implement compensatory
measures for non-functional fire suppression deluge systems. Specifically, the licensee
did not establish hourly fire patrols within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovering the non-functional status
of deluges 3 and 4 in accordance with Technical Requirements Manual (TRM) Limiting
Condition for Operation (TLCO) 3.11.4, Fire Suppression Deluge and Sprinkler
Systems, Condition A.2. The licensee documented the issue in the corrective action
program (CAP) as condition reports (CRs) 01959153, 01964875, 01964878, 01968702,
01968720 and 01971501; and implemented fire patrols until the deluge systems were
satisfactorily tested per TRM requirements.
The performance deficiency was determined to be more than minor and a finding in
accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue
Screening, because it impacted the Reactor Safety - Initiating Events Cornerstone of
Protection Against External Factors to limit the likelihood of events that upset plant
stability and challenge critical safety functions during shutdown as well as power
operations. The inspectors also determined that if left uncorrected, the performance
deficiency would have the potential to lead to a more significant safety concern. The
inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, to this
finding. The inspectors answered Yes to question E.2(2), Does the finding involve
fixed fire protection systems or the ability to contain a fire within Table 3 - SDP Appendix
Router, and transitioned to IMC 0609, Appendix F, Fire Protection Significance
Determination Process. The inspectors processed the finding in accordance with Fire
Protection SDP Phase 1 Screening in IMC 0609, Appendix F, Attachment 1 and
answered Yes to Step 1.3, Task 1.3.1 question, Is the reactor able to reach and
maintain safe shutdown (either hot or cold) condition? Therefore, the finding screened
as very low safety significance (Green).
2
The inspectors determined that the performance characteristic of the finding that was the
most significant causal factor of the performance deficiency was associated with the
cross-cutting aspect of Consistent Process in the Human Performance area and
involving individuals using a consistent systematic approach to make decisions. [H.13]
(Section 1R15.1)
Cornerstone: Mitigating Systems
- Green. The inspectors identified a finding of very low safety significance (Green) and
associated non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, for the failure to prescribe a procedure appropriate to the
circumstances for work order planning as related to the failure of under-voltage relay
127-SB2. Specifically, procedure MA-AA-203-1001, Work Order Planning, Section 4.2,
Step 2, inappropriately allowed the selection of model work orders without verification of
the acceptance criteria, requirements for as-found/as-left data, set points, and other
related information. The issue was entered into the licensees CAP for resolution as
CRs 01972812 and 01972807; and the licensee took actions to add a verification step to
procedure MA-AA-203-1001, Section 4.2, Step 2, to verify the procedure being
referenced contained the relevant information to the work task being accomplished.
The inspectors determined that the issue of concern represented a performance
deficiency because it was the result of the licensees failure to prescribe a procedure
appropriate for the circumstances. The performance deficiency was determined to be
more than minor and a finding in accordance with IMC 0612, Power Reactor Inspection
Reports, Appendix B, Issue Screening, because if left uncorrected, the performance
deficiency would have the potential to lead to a more significant safety concern. The
inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, to this
finding. The inspectors answered No to all questions within Table 3 - SDP Appendix
Router, and transitioned to IMC 0609, Appendix A, The Significance Determination
Process for Findings At-Power. Per Exhibit 2 - Mitigating Systems Screening
Questions, the inspectors determined that because the finding did not represent an
actual loss of function (redundant loss of power instrumentation remained operable
during the period of the 127-SB2 inoperability), the finding screened as very low safety
significance (Green).
The inspectors determined that the performance characteristic of the finding that was the
most significant causal factor of the performance deficiency was associated with the
cross-cutting aspect of Evaluation in the Problem Identification and Resolution area and
involved the organization thoroughly evaluating issues to ensure that resolutions
address causes and extent of conditions commensurate with their safety significance.
[H.13] (Section 4OA2.5)
Cornerstone: Barrier Integrity
- Green. A finding of very low safety significance and associated non-citied violation of
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was
identified by the inspectors for the licensees failure to accomplish procedure EN-AA-
203-1001, Operability Determinations/Functionality Assessments. Specifically, on
multiple occasions but as recently as March 20, 2014, the licensee failed to properly
evaluate operability following intermittent downward spikes of the A refueling floor
exhaust duct - high radiation monitor (RIS-4131A). The improper operability evaluations
3
resulted in not declaring RIS-4131A inoperable when appropriate, improper prioritization
of investigation of the cause, and untimely resolution of the degraded conditions. The
licensee entered the inspectors concerns into the CAP as CR 01954560. The licensee
invoked a policy to properly assess operability in the interim, completed a prompt
operability determination (POD) to evaluate intermittent downward spikes, completed a
past operability review (POR), and ultimately identified the cause and implemented
repairs to RIS-4131A.
The inspectors determined that the issue of concern represented a performance
deficiency because it was 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 in accordance with IMC 0612, Power Reactor
Inspection Reports, Appendix B, Issue Screening, because it impacted the Barrier
Integrity Cornerstone Attribute of structure, system, and component (SSC) and Barrier
Performance, and adversely affected the Cornerstone objective of maintaining
containment and radiological barrier functionality. The inspectors applied IMC 0609,
Attachment 4, Initial Characterization of Findings, to this finding. The inspectors
answered No to all questions within Table 3 - SDP Appendix Router, and transitioned
to IMC 0609, Appendix A, The Significance Determination Process for Findings At-
Power. Per Exhibit 3 - Barrier Integrity Screening Questions, the inspectors answered
No to questions B.1 and B.2, and Yes to question C.1, therefore, the finding screened
as very low safety significance (Green).
The inspectors determined that the performance characteristic of the finding that was the
most significant causal factor of the performance deficiency was associated with the
cross-cutting aspect of Human Performance, Consistent Process, and involving
individuals using a consistent, systematic approach to make decisions. [H.13]
(Section 1R12.1)
Licensee-Identified Violations
Violations of very low safety or security significance or Severity Level IV that were
identified by the licensee have been reviewed by the NRC. Corrective actions taken or
planned by the licensee have been entered into the licensees CAP. These violations
and CAP tracking numbers are listed in Section 4OA7 of this report.
4
REPORT DETAILS
Summary of Plant Status
Duane Arnold Energy Center (DAEC) operated at full power for the entire inspection period
except for brief down-power maneuvers to accomplish rod pattern adjustments or to conduct
planned surveillance testing activities.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection (71111.01)
.1 External Flooding
a. Inspection Scope
The inspectors evaluated the design, material condition, and procedures for coping with
the design basis probable maximum flood. The evaluation included a review to check
for deviations from the descriptions provided in the Updated Final Safety Analysis Report
(UFSAR) for features intended to mitigate the potential for flooding from external factors.
As part of this evaluation, the inspectors checked for obstructions that could prevent
draining, checked that the roofs did not contain obvious loose items that could clog
drains in the event of heavy precipitation, and determined that barriers required to
mitigate the flood were in place and operable. Additionally, the inspectors performed a
walkdown of the protected area to identify any modification to the site which would inhibit
site drainage during a probable maximum precipitation event or allow water ingress past
a barrier. The inspectors also walked down underground bunkers/manholes subject to
flooding that contained multiple train or multiple function risk-significant cables. The
inspectors also reviewed the abnormal operating procedure (AOP) for mitigating the
design basis flood to ensure it could be implemented as written. Documents reviewed
are listed in the Attachment to this report.
This inspection constituted one external flooding sample as defined in Inspection
Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
.2 Readiness For Impending Adverse Weather Condition - Extreme Heat/Drought
Conditions
a. Inspection Scope
The inspectors performed a detailed review of the licensees procedures and
preparations for operating the facility during an extended period of time when ambient
outside temperature was high and the ultimate heat sink was experiencing elevated
temperatures. The inspectors focused on plant specific design features and
implementation of the procedures for responding to or mitigating the effects of these
conditions on the operation of the facilitys River Water Supply, Emergency Service
5
Water, Residual Heat Removal Service Water, and electrical substation systems.
Inspection activities included a review of the licensees adverse weather procedures,
daily monitoring of the off-normal environmental conditions, and that operator actions
specified by plant specific procedures were appropriate to ensure operability of the
facilitys normal and emergency cooling systems. Documents reviewed are listed in the
Attachment to this report.
This inspection constituted one readiness for impending adverse weather condition
sample as defined in IP 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment (71111.04)
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk significant
systems:
- B Control Building Chiller (CBC) subsystem with the A CBC subsystem out of
service for planned maintenance (PM);
- Intake Structure Ventilation System; and
- SCRAM Discharge Volume system.
The inspectors selected these systems based on their risk significance relative to the
Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted
to identify any discrepancies that could impact the function of the system and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, the UFSAR, Technical Specification (TS) requirements, outstanding
work orders (WOs), CRs, and the impact of ongoing work activities on redundant trains
of equipment in order to identify conditions that could have rendered the systems
incapable of performing their intended functions. The inspectors also walked down
accessible portions of the systems to verify system components and support equipment
were aligned correctly and operable. The inspectors examined the material condition of
the components and observed operating parameters of equipment to verify that there
were no obvious deficiencies. The inspectors also verified that the licensee had properly
identified and resolved equipment alignment problems that could cause initiating events
or impact the capability of mitigating systems or barriers and entered them into the
corrective action program (CAP) with the appropriate significance characterization.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted three quarterly partial system walkdown samples as
defined in IP 71111.04-05.
b. Findings
No findings were identified.
6
1R05 Fire Protection (71111.05)
.1 Routine Resident Inspector Tours (71111.05Q)
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk significant
plant areas:
- Pre-Fire Plan (PFP) -RB-757; Pre-Fire Plan Reactor Building El. 757,
Revision 0;
- PFP-RB-812; Pre-Fire Plan Reactor Building El. 812, Revision 0;
- PFP-TB-780; Pre-Fire Plan Turbine Building El. 780, Revision 0;
- PFP-RB-828; Pre-Fire Plan Reactor Building El. 828, Revision 0; and
- PFP-RB-855; Pre-Fire Plan Reactor Building El. 855, Revision 0.
The inspectors reviewed areas 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 implemented adequate
compensatory measures for out-of-service, degraded or inoperable fire protection
equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to impact equipment which could initiate or mitigate a
plant transient, or their impact on the plants ability to respond to a security event.
Using the documents listed in the Attachment to this report, the inspectors verified that
fire hoses and extinguishers were in their designated locations and available for
immediate use; that fire detectors and sprinklers were unobstructed; that transient
material loading was within the analyzed limits; and fire doors, dampers, and penetration
seals appeared to be in satisfactory condition. The inspectors also verified that minor
issues identified during the inspection were entered into the licensees CAP.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted five routine resident inspector tour samples as defined in
IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding (71111.06)
.1 Underground Vaults
a. Inspection Scope
The inspectors selected underground bunkers/manholes subject to flooding that
contained cables whose failure could disable risk-significant equipment. The inspectors
determined whether any cables were submerged, that splices were intact, and that
appropriate cable support structures were in place. In those areas where dewatering
7
devices were used, such as a sump pump, the inspectors determined whether the
device was functional and level alarm circuits were set appropriately to ensure that the
cables would not be submerged. In those areas without dewatering devices, the
inspectors verified that drainage of the area was available, or that the cables were
qualified for submergence conditions. The inspectors also reviewed the licensees
corrective action documents with respect to past submerged cable issues identified in
the CAP to verify the adequacy of the corrective actions. The inspectors performed a
walkdown of the following underground bunkers/manholes subject to flooding:
- Manholes 1MH104, 105, 106, and 107.
Specific documents reviewed during this inspection are listed in the Attachment to this
report.
This inspection constituted one underground vaults sample as defined in
IP 71111.06-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification (71111.11Q)
a. Inspection Scope
On June 2, 2014, the inspectors observed a crew of licensed operators in the plants
simulator during licensed operator requalification training to verify that operator
performance was adequate, evaluators were identifying and documenting crew
performance problems and training was being conducted in accordance with licensee
procedures. The inspectors evaluated the following areas of the crew:
- licensed operator performance;
- clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan
actions and notifications.
The crews performance in these areas was compared to pre-established operator action
expectations and successful critical task completion requirements. Documents reviewed
are listed in the Attachment to this report.
This inspection constituted one resident inspector quarterly review of licensed operator
requalification sample as defined in IP 71111.
8
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk
a. Inspection Scope
On May 20, 2014, the inspectors observed a crew of licensed operators during the
performance of a downpower evolution to perform a rod pattern adjustment. This was
an activity that required heightened awareness or was related to increased risk. The
inspectors evaluated the following areas of the crew:
- licensed operator performance;
- clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan
actions and notifications.
The performance in these areas was compared to pre-established operator action
expectations, procedural compliance and task completion requirements. Documents
reviewed are listed in the Attachment to this report.
This inspection constituted one resident inspector quarterly observation during periods of
heightened activity or risk sample as defined in IP 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following
risk-significant systems:
- Intake Structure Ventilation system;
- Area and Process Radiation Monitors; and
- Safety-Related Electrical Relays for the Standby and Start-Up Transformers.
The inspectors reviewed events such as where ineffective equipment maintenance had
resulted in valid or invalid automatic actuations of engineered safeguards systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
9
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and
components (SSCs)/functions classified as (a)(2), or appropriate and adequate
goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were entered into the CAP with the appropriate significance
characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted three routine quarterly evaluation samples as defined in
IP 71111.12-05.
b. Findings
(1) Failure to Accomplish Procedure for Repetitive Malfunctions of Refuel Floor Radiation
Monitor
Introduction: A finding of very low safety significance and associated non-cited violation
(NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, was identified by the inspectors for the licensees failure to accomplish
procedure EN-AA-203-1001, Operability Determinations/Functionality Assessments.
Specifically, on multiple occasions but as recently as March 20, 2014, the licensee failed
to properly evaluate operability of intermittent downward spikes of the A refueling floor
exhaust duct - high radiation monitor (RIS-4131A). The improper operability evaluations
resulted in not declaring RIS-4131A inoperable when appropriate, improper prioritization
of investigation of the cause, and untimely resolution of the degraded conditions.
Description: On February 21, 2014, operators in the main control room received an
unexpected alarm associated with the A refueling floor exhaust duct - high radiation
monitor (RIS-4131A). Upon further investigation, the licensee determined that a
downscale condition had occurred on the radiation monitor and the condition was
spurious, in that following a reset of the alarm, the downscale condition cleared. The
licensee documented the downscale condition in the CAP as CR 01942767,
documented that there is reasonable assurance that RIS-4131A remains able to
perform its safety function, therefore, RIS-4131A is operable, and the CR was closed to
trending.
During the week of March 3, 2014, the inspectors reviewed the extent of the downscale
conditions for RIS-4131A over the prior year. The inspectors noted five prior CRs dating
back to April of 2013 that documented similar spurious downscale alarms for RIS-4131A.
For each occurrence, the downscale alarm was reset, the radiation monitor was verified
to be indicating normally after the alarm reset and during the daily channel check, and
the CRs were closed to trend. However, following a downscale occurrence in October of
2013, the licensee generated a trend CR that documented the ongoing issues with
10
downscale alarms from RIS-4131A, and generated a condition evaluation to determine
why prior work orders performed to correct the downscale conditions had not been
effective. In November of 2013, DAEC Nuclear Oversight generated a CR also
recognizing the stations inability to correct the unknown condition with the radiation
monitor that was resulting in the repetitive downscale alarms.
Following additional downscale conditions on March 20 and April 1, 2014; and the
inspectors recollection that Revision 16 was made to licensee procedure
EN-AA-203-1001, Operability Determinations/Functionality Assessments, on
February 11, 2014, the inspectors questioned the licensees closing to trend downscale
conditions of RIS-4131A. In particular, the inspectors noted that EN-AA-203-1001
was revised to require more rigorous, systematic, and consistent
operability/functionality/reportability (OFR) screenings and immediate operability
determinations (IODs) for all CRs involving TS SSCs. The inspectors were concerned
that the licensee was not: 1) ensuring that the periodic inoperable conditions of the
radiation monitor were being properly evaluated under EN-AA-203-1001, 2) recognizing
that a degraded condition existed with RIS-4131A, and 3) establishing the appropriate
timeliness of resolution.
Specifically, EN-AA-203-1001, Section 4.1.2 required in part, that if the shift manager
receives notice that a SSC described in the current licensing basis is affected by a
degraded condition, the shift manager shall: perform the OFR screening using
instructions in Section 4.2. Section 4.2.1.1 of EN-AA-203-1001 required, in part, that
the shift manager shall perform the OFR screening of CRs that identify a degraded
condition. Attachment 1 of EN-AA-203-1001, OFR Screening, required in part, that
the required action for degraded conditions of TS SSCs is to perform an IOD. The
inspectors determined that the March 20 and April 1, 2014, downscale conditions of
RIS-4131A represented a degraded condition for RIS-4131A, and OFR and IOD
screenings had not been performed. In particular, EN-AA-203-1001, Section 4.3.1
required in part, that if the condition affects a TS SSC, the shift manager shall complete
the IOD without delay and in a controlled manner using the best available information,
and Section 4.3.6 required in part, that the shift manager prepares the IOD using the
guidance in EN-AA-203-1001-F04, AR Operability Notes Worksheet, to determine the
IOD content. Additionally, Section 4.3.9 required in part, that if the IOD raises a
question of past operability, then the shift manager shall request a prompt operability
determination (POR).
Based on the inspectors questions/concerns above, the licensee generated
CR 001954560 on April 3, 2014. Corrective actions included invoking a policy to
properly assess operability until final corrective actions were taken (logging of TS
LCO 3.3.6.1, Primary Containment Isolation Instrumentation, and 3.3.6.2, Secondary
Containment Isolation Instrumentation, entries during momentary inoperable
conditions), completing a prompt operability determination (POD) to evaluate operability
of the instrument and to evaluate for compensatory measures (RIS-4131A was
determined to be operable but degraded), and completing a past operability review.
Based on determining that RIS-4131A was operable but degraded, the station elevated
and prioritized investigation into the cause of the downward spikes, and ultimately
identified the cause and implemented repairs to RIS-4131A.
11
Analysis: The inspectors determined that the issue of concern represented a
performance deficiency because it was the result of the licensees failure to meet
procedural requirements, 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 it impacted the Barrier Integrity Cornerstone Attribute of SSC and Barrier
Performance, and adversely affected the Cornerstone objective of maintaining
containment and radiological barrier functionality. Specifically, the degraded condition of
RIS-4131A adversely impacted defense-in-depth provided by the primary and secondary
containment isolation refueling floor exhaust duct - high radiation function.
The inspectors applied Inspection Manual Chapter (IMC) 0609, Attachment 4, Initial
Characterization of Findings, to this finding. The inspectors answered No to all
questions within Table 3 - Significance Determination Process (SDP) Appendix Router,
and transitioned to IMC 0609, Appendix A, The Significance Determination Process for
Findings At-Power. Per Exhibit 3 - Barrier Integrity Screening Questions, the
inspectors answered No to questions B.1 and B.2, and Yes to question C.1,
therefore, the finding screened as very low safety significance (Green).
The inspectors determined that the performance characteristic of the finding that was the
most significant causal factor of the performance deficiency was associated with the
cross-cutting aspect of Human Performance, Consistent Process, and involving
individuals using a consistent, systematic approach to make decisions. Specifically, on
numerous occasions, improper operability decisions were made with respect to
intermittent downward spiking of RIS-4131A. By not using the systematic operability
process to evaluate the intermittent downward spikes, ongoing malfunctions of
RIS-4131A were accepted for an extended period of time. [H.13]
Enforcement: Title 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures,
and Drawings, requires, in part, that activities affecting quality shall be prescribed by
documented instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these instructions.
Contrary to the above, on multiple occasions but as recently as March 20, 2014, the
licensee failed to properly accomplish procedure EN-AA-302-1001, Operability
Determinations/Functionality Assessments, Revision 16, following intermittent
downward spiking of the A refueling floor exhaust duct - high radiation monitor
(RIS-4131A).
Because this violation was of very low safety significance and because the issue was
entered into the licensees CAP as CR 01954560, consistent with Section 2.3.2 of the
Enforcement Policy it is being treated as a NCV. (NCV 05000331/2014003-01, Failure
to Accomplish Procedure for Repetitive Malfunctions of Refuel Floor Radiation
Monitor).
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the
maintenance and emergent work activities affecting risk-significant and safety-related
12
equipment listed below to verify that the appropriate risk assessments were performed
prior to removing equipment for work:
- B Standby Diesel Generator (SBDG) unavailability during gasket replacements;
- Cable Spreading Room Suppression system failed surveillance test;
- Technical Requirements Manual (TRM) and TS missed surveillances;
- Work Week 1424 plant risk; and
- Plant risk during Core Spray surveillance testing and Emergency Core Cooling
System Instrument PMs.
These activities were selected based on their potential risk-significance relative to the
Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that
risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
and complete. When emergent work was performed, the inspectors verified that the
plant risk was promptly reassessed and managed. The inspectors reviewed the scope
of maintenance work, discussed the results of the assessment with the licensee's
probabilistic risk analyst or shift technical advisor, and verified plant conditions were
consistent with the risk assessment. The inspectors also reviewed TS requirements and
walked down portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted five maintenance risk assessment and emergent work
control samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (71111.15)
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- Standby Liquid Control tank foreign material issue;
- SCRAM Discharge Volume High Water Level Calibration (Float Switches),
LS1861D (Reactor Protection System (RPS) Channel B2) found to be high out of
the TS-required calibration value;
- Fire Protection System Deluge 3 & 4 lack of TRM surveillance test; and
- Alternate Depressurization System accumulator sizing issue.
The inspectors selected these potential operability/functionality issues based on the risk
significance of the associated components and systems. The inspectors evaluated the
technical adequacy of the evaluations to ensure that TS operability or functionality was
properly justified and the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors compared the operability,
functionality and design criteria in the appropriate sections of the TS, TRM, and UFSAR
to the licensees evaluations to determine whether the components or systems were
13
operable or functional. Where compensatory measures were required to maintain
operability or functionality, the inspectors determined whether the measures in place
would function as intended and were properly controlled. The inspectors determined,
where appropriate, compliance with bounding limitations associated with the evaluations.
Additionally, the inspectors reviewed a sampling of corrective action documents to verify
that the licensee was identifying and correcting any deficiencies associated with
operability and functionality evaluations.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted four operability evaluation samples as defined in
IP 71111.15-05.
b. Findings
(1) Failure to Establish Fire Patrols as Compensatory Actions in Accordance with the Fire
Protection Program
Introduction: The inspectors identified a finding of very low safety significance (Green)
and associated NCV of DAEC Renewed Operating License Condition 2.C.(3), for the
failure to implement compensatory measures for non-functional fire suppression deluge
systems. Specifically, the licensee did not establish hourly fire patrols within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of
discovering the non-functional status of deluges 3 and 4 in accordance with TRM
TLCO 3.11.4, Fire Suppression Deluge and Sprinkler Systems, Condition A.2.
Description: On March 6, 2014 the licensee transitioned their fire protection program to
National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire
Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. As part of
the transition analysis, the licensee documented in FHA-200, Fire Protection Design
Documentation, Appendix F, Fire Safety Analysis, that deluge systems 3 and 4,
associated with Reactor Feedwater Pumps 1P-1B and 1P-1A, respectively, had been
determined to be of high safety significance in the event of a fire. Being of high safety
significance, controls and testing requirements for deluge systems 3 and 4 were
incorporated into TRM Section 3.11.4, Fire Suppression Deluge and Sprinkler
Systems, for periodic testing to ensure functionality. In accordance with Technical
Surveillance Requirement (TSR) 3.11.4.4, these deluges were required to be air flow
tested on 36 month basis.
On April 17, 2014 while reviewing License Renewal Interim Staff Guidance
LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems,
Atmospheric Storage Tanks, and Corrosion Under Insulation, the licensee discovered
that procedures did not exist for air flow testing of deluges 3 and 4. Prior to transition to
NFPA 805, under 10 CFR 50, Appendix R, these deluges were not required to be air
flow tested at any point. Therefore, prior to April 17, 2014, fire suppression deluges
3 and 4 had never been air flow tested. The licensee determined that because no
physical impairment was apparent for the deluges, there existed a reasonable
expectation of functionality. The licensee declared the TSR 3.11.4.4 missed and
invoked TSR 3.0.3 to perform a risk assessment for the missed surveillance and
manage the risk impact until the next available window to air flow test the deluges.
14
In part, TSR 3.0.3 stated that, if it is discovered that a Surveillance was not performed
within its specified Frequency, then compliance with the requirement to declare the
TLCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the
limit of the specified Frequency, whichever was greater. This delay period is permitted
to allow performance of the Surveillance. A risk evaluation shall be performed for any
Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed. On
May 9, 2014, the resident inspectors challenged the licensees use of TSR 3.0.3 to delay
the performance of air flow testing based on IMC 0326, Appendix A, Section A.03 that
stated, in part, Surveillance Requirement 3.0.3 may not be applied when a licensee
discovers that a Technical Specifications surveillance has never been performed. In
cases where a specified safety function or a necessary and related support function
required for operability has never been performed, then a reasonable expectation of
operability does not exist. Although the statement referred to the Technical
Specifications, the inspectors determined that the IMC 0326 statement also applied to
the TRM TSRs after discussions with the NRC Technical Specification Branch.
On May 29, 2014, the licensee directed that a Condition Evaluation be performed to
determine the use of TSR 3.0.3 and its appropriateness to the circumstances and further
directed that a functionality assessment be performed. On June 10, 2014, the licensees
Condition Evaluation confirmed that use of TSR 3.0.3 was not appropriate given
TSR 3.11.4.4 air flow testing for deluge systems 3 and 4 had never been performed
(i.e. not missed). The inspectors noted that TSR 3.0.1 stated, in part, that TSRs shall
be met during the MODES or other specified conditions in the Applicability for individual
TLCOs, unless otherwise stated in the TSR. Failure to meet a Surveillance, whether
such failure is experienced during the performance of the Surveillance or between
performances of the Surveillance, shall be failure to meet the TLCO. Failure to perform
a Surveillance within the specified Frequency shall be failure to meet the TLCO
expect as provided in TSR 3.0.3. On June 10, 2014, the licensee declared fire
suppression deluge systems 3 and 4 non-functional, entered TLCO 3.11.4, Condition A
and established hourly fire watches in the Reactor Feedwater Pump area. See
Section 4OA7 of this report that provides additional background information for a
Licensee-Identified Violation associated with this issue.
The issues were documented in CRs 01959153, 01964875, 01964878, 01968702,
01968720 and 01971501. Corrective actions included establishing procedures to air
flow test the systems and prompted changes to EN-AA-203-1001, Operability
Determinations/Functionality Assessments, to add clarification that a missed
surveillance is not the same as a surveillance that has never been performed. On
July 4, 2014, the licensee successfully tested, in accordance with the approved
procedures, and restored functionality of the automatic fire suppression deluge systems
3 and 4.
Analysis: The inspectors determined that the issue of concern represented a
performance deficiency because it was the result of the licensees failure to establish an
hourly fire patrol in accordance with TLCO 3.11.4 required action Condition A.2.
Specifically, on May 9, 2014, the inspectors raised the question about the licensee
invoking TSR 3.0.3 and performing a risk assessment associated with a system which
had never been tested before, where a reasonable expectation of functionality did not
exist. The performance deficiency was within the licensees ability to foresee and
correct and should have been prevented because the licensee had a process in place to
15
address the status of the deluge system 3 and 4 functionality through the Operability
Determination/Functionality Assessment procedure.
The performance deficiency was determined to be more than minor and a finding in
accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue
Screening, because it impacted the Reactor Safety - Initiating Events Cornerstone of
Protection Against External Factors to limit the likelihood of events that upset plant
stability and challenge critical safety functions during shutdown as well as power
operations. The inspectors also determined that if left uncorrected, the performance
deficiency would have the potential to lead to a more significant safety concern.
The inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, to
this finding. The inspectors answered Yes to question E.2(2), Does the finding involve
fixed fire protection systems or the ability to contain a fire within Table 3 - SDP Appendix
Router, and transitioned to IMC 0609, Appendix F, Fire Protection Significance
Determination Process. The inspectors processed the finding in accordance with Fire
Protection SDP Phase 1 Screening in IMC 0609, Appendix F, Attachment 1 and
answered Yes to Step 1.3, Task 1.3.1 question, Is the reactor able to reach and
maintain safe shutdown (either hot or cold) condition? Therefore, the finding screened
as very low safety significance (Green).
The inspectors determined that the performance characteristic of the finding that was the
most significant causal factor of the performance deficiency was associated with the
cross-cutting aspect of Consistent Process in the Human Performance area and
involving individuals using a consistent systematic approach to make decisions.
Specifically, the licensee did not systematically consider and apply the aforementioned
TRM statements and EN-AA-203-1001 procedure (which establishes a process
consistent with IMC 0326); in order to correctly assess the non-functional status of
deluges 3 and 4 upon discovery that TSR 3.11.4.4 was never performed. [H.13]
Enforcement: Duane Arnold Energy Center Renewed Operating License Condition
2.C.(3), Fire Protection Program, stated, in part that Duane Arnold shall implement
and maintain in effect all provisions of the approved fire protection program that comply
with 10 CFR 50.48(a) and 10 CFR 50.48(c). Fire protection program procedure
FP-AB-100, DAEC Fire Protection Program, section 3.4.4(3), stated in part, that for
NFPA 805 credited Fire Protection System and Features, TLCOs and compensatory
measures were prescribed by the TRM.
Contrary to the above, on April 17, 2014, the licensee failed to institute compensatory
measures for non-functional fire suppression deluge systems as required by
Duane Arnold Energy Center Renewed Operating License Condition 2.C.(3).
Specifically, the licensee did not establish an hourly fire patrol within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of
discovering the non-functional status of deluges 3 and 4 in accordance with TRM
TLCO 3.11.4, Fire Suppression Deluge and Sprinkler Systems, Condition A.2.
Because this violation was of very low safety significance and because the issue was
entered into the licensees CAP as CRs 01959153, 01964875, 01964878, 01968702,
01968720 and 01971501, consistent with Section 2.3.2 of the Enforcement Policy it is
being treated as a NCV. (NCV 05000331/2014003-02, Failure to Establish Fire
Patrols as Compensatory Actions in Accordance with the Fire Protection
Program).
16
1R18 Plant Modifications (71111.18)
a. Inspection Scope
The inspectors reviewed the following modification:
- A Control Building Chiller (CBC) condenser head replacement following
discovery of internal surface pitting during PM.
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety
evaluation screening against the design basis, the UFSAR, and the TS, as applicable, to
verify that the modification did not affect the operability or availability of the affected
system. The inspectors, as applicable, observed ongoing and completed work activities
to ensure that the modification was installed as directed and consistent with the design
control documents; the modification operated as expected; post-modification testing
adequately demonstrated continued system operability, availability, and reliability; and
that operation of the modification did not impact the operability of any interfacing
systems. As applicable, the inspectors verified that relevant procedure, design, and
licensing documents were properly updated. Lastly, the inspectors discussed the plant
modification with operations, engineering, and training personnel to ensure that the
individuals were aware of how the operation with the plant modification in place could
impact overall plant performance.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- A CBC testing following PM;
- Low Pressure Coolant Injection (LPCI) system testing following PM;
- B SBDG testing following ventilation system PM; and
- Reactor Core Isolation Cooling (RCIC) testing following PM.
These activities were selected based upon the structure, system, or component's ability
to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate
for the maintenance performed; acceptance criteria were clear and demonstrated
operational readiness; test instrumentation was appropriate; tests were performed as
written in accordance with properly reviewed and approved procedures; equipment was
returned to its operational status following testing (temporary modifications or jumpers
required for test performance were properly removed after test completion); and test
17
documentation was properly evaluated. The inspectors evaluated the activities against
TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various
NRC generic communications to ensure that the test results adequately ensured that the
equipment met the licensing basis and design requirements. In addition, the inspectors
reviewed corrective action documents associated with post-maintenance tests to
determine whether the licensee was identifying problems and entering them in the CAP
and that the problems were being corrected commensurate with their importance to
safety.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted four post-maintenance testing samples as defined in
IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether
risk-significant systems and equipment were capable of performing their intended safety
function and to verify testing was conducted in accordance with applicable procedural
and TS requirements:
- Surveillance Test Procedure (STP) 3.0.0-01, Instrument Checks, Revision 142
(Routine);
- STP 3.5.1-01B; B Core Spray System Operability Test, Revision 15 (in-service
test (IST));
Functional Test, Revision 15 (Routine);
- STP 3.5.1-03A; A Core Spray System Simulated Automatic Actuation,
Revision 9 (Routine).
The inspectors observed in-plant activities and reviewed procedures and associated
records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel
or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and
were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was
in accordance with TSs, the UFSAR, procedures, and applicable commitments;
18
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable
prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability;
tests were performed in accordance with the test procedures and other
applicable procedures; jumpers and lifted leads were controlled and restored
where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in
accordance with the applicable version of Section XI, American Society of
Mechanical Engineers code, and reference values were consistent with the
system design basis;
- where applicable, test results not meeting acceptance criteria were addressed
with an adequate operability evaluation or the system or component was
declared inoperable;
- where applicable for safety-related instrument control surveillance tests,
reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical
contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems
encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the
performance of its safety functions; and
- all problems identified during the testing were appropriately documented and
dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
These inspections constituted five routine samples, one in-service test sample, and one
reactor coolant system leak detection surveillance testing inspection sample, as defined
in IP 71111.22, Sections-02 and-05.
b. Findings
No findings were identified.
2. RADIATION SAFETY
Cornerstones: Occupational and Public Radiation Safety
2RS5 Radiation Monitoring Instrumentation (71124.05)
This inspection constituted a partial sample as defined in IP 71124.05-05.
.1 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down effluent radiation monitoring systems, including at least one
liquid and one airborne system. Focus was placed on flow measurement devices and all
19
accessible point-of-discharge liquid and gaseous effluent monitors of the selected
systems. The inspectors assessed whether the effluent/process monitor configurations
aligned with Offsite Dose Calculation Manual (ODCM) descriptions and observed
monitors for degradation and out-of-service tags.
b. Findings
No findings were identified.
.2 Calibration and Testing Program (02.03)
Process and Effluent Monitors
a. Inspection Scope
The inspectors selected effluent monitor instruments (such as gaseous and liquid) and
evaluated whether channel calibration and functional tests were performed consistent
with radiological effluent TSs/ODCM. The inspectors assessed whether: (a) the
licensee calibrated its monitors with National Institute of Standards and Technology
traceable sources; (b) the primary calibrations adequately represented the plant nuclide
mix; (c) when secondary calibration sources were used, the sources were verified by the
primary calibration; and (d) the licensees channel calibrations encompassed the
instruments alarm set-points.
The inspectors assessed whether the effluent monitor alarm setpoints were established
as provided in the ODCM and station procedures.
For changes to effluent monitor setpoints, the inspectors evaluated the basis for
changes to ensure that an adequate justification existed.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
This inspection constituted one complete sample as defined in IP 71124.06-05.
.1 Inspection Planning and Program Reviews (02.01)
Event Report and Effluent Report Reviews
a. Inspection Scope
The inspectors reviewed the radiological effluent release reports issued since the last
inspection to determine if the reports were submitted as required by the ODCM/TSs.
The inspectors reviewed anomalous results, unexpected trends, or abnormal releases
identified by the licensee for further inspection to determine if they were evaluated, were
entered in the CAP, and were adequately resolved.
The inspectors selected radioactive effluent monitor operability issues reported by the
licensee as provided in effluent release reports, to review these issues during the onsite
20
inspection, as warranted, given their relative significance and determine if the issues
were entered into the CAP and adequately resolved.
b. Findings
No findings were identified.
Offsite Dose Calculation Manual and Final Safety Analysis Report Review
a. Inspection Scope
The inspectors reviewed UFSAR descriptions of the radioactive effluent monitoring
systems, treatment systems, and effluent flow paths so they could be evaluated during
inspection walkdowns.
The inspectors reviewed changes to the ODCM made by the licensee since the last
inspection against the guidance in NUREG-1302 and 0133, and Regulatory
Guides 1.109, 1.21, and 4.1. When differences were identified, the inspectors reviewed
the technical basis or evaluations of the change during the onsite inspection to
determine whether they were technically justified and maintain effluent releases as-low-
as-reasonably-achievable.
The inspectors reviewed licensee documentation to determine if the licensee has
identified any non-radioactive systems that have become contaminated as disclosed
either through an event report or the ODCM since the last inspection. This review
provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59
evaluations and allowed a determination if any newly contaminated systems have an
unmonitored effluent discharge path to the environment, whether any required ODCM
revisions were made to incorporate these new pathways, and whether the associated
effluents were reported in accordance with Regulatory Guide 1.21.
b. Findings
No findings were identified.
Groundwater Protection Initiative Program
a. Inspection Scope
The inspectors reviewed reported groundwater monitoring results and changes to the
licensees written program for identifying and controlling contaminated spills/leaks to
groundwater.
b. Findings
No findings were identified.
Procedures, Special Reports, and Other Documents
a. Inspection Scope
The inspectors reviewed Licensee Event Reports, event reports and/or special reports
related to the Effluent Program issued since the previous inspection to identify any
21
additional focus areas for the inspection based on the scope/breadth of problems
described in these reports.
The inspectors reviewed Effluent Program implementing procedures, particularly those
associated with effluent sampling, effluent monitor set-point determinations, and dose
calculations.
The inspectors reviewed copies of licensee and third party (independent) evaluation
reports of the Effluent Monitoring Program since the last inspection to gather insights
into the licensees program and aid in selecting areas for inspection review (smart
sampling).
b. Findings
No findings were identified.
.2 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down selected components of the gaseous and liquid discharge
systems to evaluate whether equipment configuration and flow paths align with the
documents reviewed in Section 02.01 above and to assess equipment material
condition. Special attention was made to identify potential unmonitored release points
(such as open roof vents in boiling water reactor turbine decks, temporary structures
butted against turbine, auxiliary or containment buildings), building alterations which
could impact airborne, or liquid effluent controls, and ventilation system leakage that
communicates directly with the environment.
For equipment or areas associated with the systems selected for review that were not
readily accessible due to radiological conditions, the inspectors reviewed the licensee's
material condition surveillance records, as applicable.
The inspectors walked down filtered ventilation systems to assess for conditions such as
degraded high-efficiency particulate air/charcoal banks, improper alignment, or system
installation issues that would impact the performance or the effluent monitoring capability
of the effluent system.
As available, the inspectors observed selected portions of the routine processing and
discharge of radioactive gaseous effluent (including sample collection and analysis) to
evaluate whether appropriate treatment equipment was used and the processing
activities align with discharge permits.
The inspectors determined if the licensee has made significant changes to their effluent
release points (e.g., changes subject to a 10 CFR 50.59 review or require NRC approval
of alternate discharge points).
As available, the inspectors observed selected portions of the routine processing and
discharging of liquid waste (including sample collection and analysis) to determine if
appropriate effluent treatment equipment is being used and that radioactive liquid waste
is being processed and discharged in accordance with procedure requirements and
aligns with discharge permits.
22
b. Findings
No findings were identified.
.3 Sampling and Analyses (02.03)
a. Inspection Scope
The inspectors selected effluent sampling activities, consistent with smart sampling, and
assessed whether adequate controls have been implemented to ensure representative
samples were obtained (e.g. provisions for sample line flushing, vessel recirculation,
composite samplers, etc.).
The inspectors selected effluent discharges made with inoperable (declared
out-of-service) effluent radiation monitors to assess whether controls were in place
to ensure compensatory sampling was performed consistent with the radiological
effluent TSs/ODCM and that those controls were adequate to prevent the release of
unmonitored liquid and gaseous effluents.
The inspectors determined whether the facility was routinely relying on the use of
compensatory sampling in lieu of adequate system maintenance, based on the
frequency of compensatory sampling since the last inspection.
The inspectors reviewed the results of the Inter-Laboratory Comparison Program to
evaluate the quality of the radioactive effluent sample analyses and assessed whether
the Inter-Laboratory Comparison Program includes hard-to-detect isotopes, as
appropriate.
b. Findings
No findings were identified.
.4 Instrumentation and Equipment (02.04)
Effluent Flow Measuring Instruments
a. Inspection Scope
The inspectors reviewed the methodology the licensee uses to determine the effluent
stack and vent flow rates to determine if the flow rates were consistent with radiological
effluent TS/ODCM UFSAR values, and that differences between assumed and actual
stack and vent flow rates did not affect the results of the projected public doses.
b. Findings
No findings were identified.
Air Cleaning Systems
a. Inspection Scope
The inspectors assessed whether surveillance test results since the previous inspection
for TS required ventilation effluent discharge systems (high-efficiency particulate air and
23
charcoal filtration), such as the standby gas treatment system and the
containment/auxiliary building ventilation system, met TS acceptance criteria.
b. Findings
No findings were identified.
.5 Dose Calculations (02.05)
a. Inspection Scope
The inspectors reviewed all significant changes in reported dose values compared to the
previous radiological effluent release report (e.g., a factor of 5, or increases that
approach Appendix I criteria) to evaluate the factors which may have resulted in the
change.
The inspectors reviewed radioactive liquid and gaseous waste discharge permits to
assess whether the projected doses to members of the public were accurate and based
on representative samples of the discharge path.
The inspectors evaluated the methods used to determine the isotopes that are included
in the source term to ensure all applicable radionuclides are included within detectability
standards. The review included the current Part 61 analyses to ensure hard-to-detect
radionuclides are included in the source term.
The inspectors reviewed changes in the licensees offsite dose calculations since the
last inspection to evaluate whether changes were consistent with the ODCM and
Regulatory Guide 1.109. The inspectors reviewed meteorological dispersion and
deposition factors used in the ODCM and effluent dose calculations to evaluate whether
appropriate factors were being used for public dose calculations.
The inspectors reviewed the latest Land Use Census to assess whether changes
(e.g., significant increases or decreases to population in the plant environs, changes
in critical exposure pathways, the location of nearest member of the public or critical
receptor, etc.) have been factored into the dose calculations.
For the releases reviewed above, the inspectors evaluated whether the calculated doses
(monthly, quarterly, and annual dose) are within the 10 CFR Part 50, Appendix I, and TS
dose criteria.
The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank
discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to
ensure the abnormal discharge was monitored by the discharge point effluent monitor.
Discharges made with inoperable effluent radiation monitors, or unmonitored leakages,
were reviewed to ensure that an evaluation was made of the discharge to satisfy
10 CFR 20.1501 so as to account for the source term and projected doses to the public.
b. Findings
No findings were identified.
24
.6 Groundwater Protection Initiative Implementation (02.06)
a. Inspection Scope
The inspectors reviewed monitoring results of the Groundwater Protection Initiative to
determine if the licensee implemented its program as intended and to identify any
anomalous results. For anomalous results or missed samples, the inspectors assessed
whether the licensee identified and addressed deficiencies through its CAP.
The inspectors reviewed identified leakage or spill events and entries made into
10 CFR 50.75 (g) records. The inspectors reviewed evaluations of leaks or spills and
reviewed any remediation actions taken for effectiveness. The inspectors reviewed
onsite contamination events involving contamination of ground water and assessed
whether the source of the leak or spill was identified and mitigated.
- On October 11, 2012, approximately 200 to 700 gallons of radioactively
contaminated water leaked to the ground from the Condensate Storage Tank pit
through a failed seal. The inspectors reviewed the licensees notification to the NRC
(Event No. 48403), the licensees ground water monitoring program, completed
remediation, as well as the licensees plan to install additional sample wells for better
characterization of the spill.
For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the
inspectors assessed whether an evaluation was performed to determine the type and
amount of radioactive material that was discharged by:
- Assessing whether sufficient radiological surveys were performed to evaluate the
extent of the contamination and the radiological source term and assessing whether
a survey/evaluation had been performed to include consideration of hard-to-detect
radionuclides.
- Determining whether the licensee completed offsite notifications, as provided in its
Groundwater Protection Initiative implementing procedures.
The inspectors reviewed the evaluation of discharges from onsite surface water bodies
that contain or potentially contain radioactivity and the potential for ground water leakage
from these onsite surface water bodies. The inspectors assessed whether the licensee
was properly accounting for discharges from these surface water bodies as part of their
effluent release reports.
The inspectors assessed whether on-site ground water sample results and a description
of any significant on-site leaks/spills into ground water for each calendar year were
documented in the Annual Radiological Environmental Operating Report for the
Radiological Environmental Monitoring Program or the Annual Radiological Effluent
Release Report for the Radiological Effluent TSs.
For significant, new effluent discharge points (such as significant or continuing leakage
to ground water that continues to impact the environment, if not remediated), the
inspectors evaluated whether the ODCM was updated to include the new release points.
25
b. Findings
No findings were identified.
.7 Problem Identification and Resolution (02.07)
a. Inspection Scope
The inspectors assessed whether problems associated with the Effluent Monitoring and
Control Program were being identified by the licensee at an appropriate threshold and
were properly addressed for resolution in the licensees CAP. In addition, they
evaluated the appropriateness of the corrective actions for a selected sample of
problems documented by the licensee involving radiation monitoring and exposure
controls.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
4OA1 Performance Indicator (PI) Verification (71151)
.1 Reactor Coolant System Leakage
a. Inspection Scope
The inspectors sampled licensee submittals for the RCS Leakage performance indicator
for the period from the second quarter 2013 through the first quarter 2014. To determine
the accuracy of the PI data reported during those periods, PI definitions and guidance
contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The
inspectors reviewed the licensees operator logs, RCS leakage tracking data, issue
reports, event reports and NRC Integrated Inspection Reports for the period of
April, 2013 through March, 2014, to validate the accuracy of the submittals. The
inspectors also reviewed the licensees issue report database to determine if any
problems had been identified with the PI data collected or transmitted for this indicator
and none were identified. Documents reviewed are listed in the Attachment to this
report.
This inspection constituted one reactor coolant system leakage sample as defined in
IP 71151-05.
b. Findings
No findings were identified.
26
.2 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors reviewed licensee submittals for the Occupational Exposure Control
Effectiveness Performance Indicator for the fourth quarter 2013. The inspectors used PI
definitions and guidance contained in the Nuclear Energy Institute Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 7, dated
August 2013, to determine the accuracy of the Performance Indicator data reported
during those periods. The inspectors reviewed the licensees assessment of the
Performance Indicator for occupational radiation safety to determine if the indicator-
related data was adequately assessed and reported. To assess the adequacy of the
licensees Performance Indicator data collection and analyses, the inspectors discussed
with radiation protection staff the scope and breadth of its data review and the results of
those reviews. Documents reviewed are listed in the Attachment to this report.
The inspectors reviewed a licensee-identified issue that occurred on October 8, 2013,
and was documented as a licensee-identified NCV of TS 5.7.2 in NRC Inspection Report 05000331/2013005. The licensee previously did not report this as a PI occurrence.
Upon discussion with the licensee, the licensee has determined that the issue was an
occurrence of the Occupational Exposure Control Effectiveness PI in accordance
with Nuclear Energy Institute Document 99-02. This licensee has entered this issue into
their CAP as CR 01971250. This will result in the change for this PI from zero to one
occurrence. This change will not result in a change in regulatory significance to this PI.
This inspection constituted a partial occupational exposure control effectiveness sample
as defined in IP 71151-05.
b. Findings
No findings were identified.
However, the inspectors identified a minor violation of 10 CFR 50.9 Completeness and
Accuracy of information for one occurrence that was not reported. Specifically, the
Occupational Exposure Controls Effectiveness PI occurrence on October 8, 2013 was
not initially reported and then not corrected when NRC issued IR 2013-005 as discussed
above. Because this results in the change for this PI from zero to one occurrence, and
does not result in a change in regulatory significance of this PI, this is considered a
minor violation.
4OA2 Identification and Resolution of Problems (71152)
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
and plant status reviews to verify they were being entered into the licensees CAP at an
appropriate threshold, that adequate attention was being given to timely corrective
actions, and that adverse trends were identified and addressed. Attributes reviewed
included: identification of the problem was complete and accurate; timeliness was
27
commensurate with the safety significance; evaluation and disposition of performance
issues, generic implications, common causes, contributing factors, root causes, extent-
of-condition reviews, and previous occurrences reviews were proper and adequate; and
that the classification, prioritization, focus, and timeliness of corrective actions were
commensurate with safety and sufficient to prevent recurrence of the issue. Documents
reviewed are listed in the Attachment to this report.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure they were considered an
integral part of the inspections performed during the quarter and documented in
Section 1 of this report.
b. Findings
No findings were identified.
.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 CAP. This review was accomplished through
inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant
status monitoring activities and, as such, did not constitute any separate inspection
samples.
b. Findings
No findings were identified.
.3 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees CAP and associated documents to
identify trends that could indicate the existence of a more significant safety issue. The
inspectors review was 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. The inspectors
review nominally considered the 6-month period of January 2014 through June 2014,
although some examples expanded beyond those dates where the scope of the trend
warranted.
The review also included issues documented outside the normal CAP 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 inspectors
compared and contrasted their results with the results contained in the licensees
28
CAP trending reports. Corrective actions associated with a sample of the issues
identified in the licensees trending reports were reviewed for adequacy.
This inspection constituted one semi-annual trend inspection sample as defined in
IP 71152-05.
b. Findings
No findings were identified.
.4 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors evaluated the licensees implementation of their process used to identify,
document, track, and resolve operational challenges. Inspection activities included, but
were not limited to, a review of the cumulative effects of the operator workarounds on
system 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.
The inspectors performed a review of the cumulative effects of operator workarounds.
The documents listed in the Attachment to this report were reviewed to accomplish the
objectives of the inspection procedure. The inspectors reviewed both current and
historical operational challenge records to determine whether the licensee was
identifying operator challenges at an appropriate threshold, had entered them into their
CAP and proposed or implemented appropriate and timely corrective actions which
addressed each issue. Reviews were conducted to determine if any operator challenge
could increase the possibility of an Initiating Event, if the challenge was contrary to
training, required a change from long-standing operational practices, or created the
potential for inappropriate compensatory actions. Additionally, all temporary
modifications were reviewed to identify any potential effect on the functionality of
Mitigating Systems, impaired access to equipment, or required equipment uses for which
the equipment was not designed. Daily plant and equipment status logs, degraded
instrument logs, and operator aids or tools being used to compensate for material
deficiencies were also assessed to identify any potential sources of unidentified operator
workarounds.
These inspections constituted one operator workaround annual inspection sample as
defined in IP 71152-05.
b. Findings
.5 Selected Issue Follow-Up Inspection: Standby Transformer Relay Root Cause
Evaluation
a. Inspection Scope
The inspectors reviewed Root Cause Evaluation (RCE) 01934040, Under-voltage Relay
Failed, associated with the January 17, 2014, surveillance test failure of Standby
Transformer under-voltage relay 127-SB2. The inspectors assessed whether the
licensees determination of the root and contributing causes, corrective actions, and
29
effectiveness measures were appropriate. The finding below describes a finding and
violation identified by the inspectors during their review.
This inspection constituted one in-depth problem identification and resolution sample as
defined in IP 71152-05.
b. Findings
(1) Failure to Prescribe Work Order Planning Procedure Appropriate to the Circumstances
Introduction: The inspectors identified a finding of very low safety significance (Green)
and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, for the failure to prescribe a procedure appropriate to the circumstances
for work order planning as related to the failure of under-voltage relay 127-SB2.
Specifically, procedure MA-AA-203-1001, Work Order Planning, Section 4.2, Step 2,
inappropriately allowed the selection of model work orders without verification of the
acceptance criteria, requirements for as-found/as-left data, set points, and other related
information.
Description: On January 17, 2014, the licensee performed STP 3.3.8.1-05B, 1A4 4KV
Emergency Transformer Supply Under-Voltage Calibration. During performance of the
STP, two trip circuit contacts on Standby Transformer supply under-voltage relay
127-SB2 did not open as expected. Upon further investigation, the licensee discovered
that the 11-12 and 13-14 127-SB2 contacts had been configured incorrectly. The
contacts were arranged in series with a third contact 19-20, such that upon a reduction
of supply voltage, two contacts would open, but one contact remained closed and would
have prevented the relay trip signal from tripping the Standby Transformer supply
breaker when voltage reduced to less than 2450 Volts. The function of the 127-SB2
relay was to sense a loss of offsite power, open the Standby Transformer supply
breaker, and provide a permissive signal to the 1A4 4KV essential bus to allow the bus
to be reenergized by the B SBDG. The contact configuration was such that this
function would have been inhibited had it been called upon.
Technical Specification 3.3.8.1, Loss of Power Instrumentation, required in part,
relay 127-SB2 to be operable in Modes 1, 2 and 3. The failed STP on January 17, 2014,
demonstrated that the 127-SB2 relay was inoperable and the required action to satisfy
the TS was to place the channel in trip within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery (Condition A.1) and if
that was not achieved, declare the associated SBDG inoperable immediately
(Condition C.1). Upon the discovery of the inoperable relay, the licensee declared the
B SBDG inoperable to comply with LCO 3.3.8.1, Condition C.1. The licensee
documented the issue in CR 01934040 and performed a POR. The prompt operability
review (POR) noted that relay 127-SB2 had been replaced on September 16, 2013, as
part of WO 40126852. Further review noted that no in-field, post-installation functional
testing had been performed or identified as part of the WO instructions. Therefore, relay
127-SB2 had been inoperable from September 16, 2013, to January 17, 2014, or 120
days. During this timeframe, the relay miss-configuration had gone unrecognized and
the TS required actions unfulfilled, resulting in the licensee operating in a condition
prohibited by Technical Specifications. The event was reported by the licensee as
Licensee Event Report (LER) 2014-001-00 and 2014-001-01 in accordance with
10 CFR 50.73(a)(2)(i)(B). See Section 4OA3.1 in reference to the above mentioned
LERs and Section 4OA7 for an associated licensee-identified violation.
30
As part of the event analysis called out by CR 01934040, the licensee performed an
RCE in accordance with procedure PI-AA-100-1005, Root Cause Analysis, Revision 9.
The RCE identified two root causes and two contributing causes. The first root cause
was that existing procedural guidance was inadequate to correctly setup the relay per
procedure RELAY-080-08, General Electric Under-Voltage Relay Type NGV,
Revision 10, which WO 40126852 referenced for calibration of relay 127-SB2. The
licensee determined that RELAY-080-08 did not define set-point criteria and relay
configuration. The corrective action to prevent recurrence was to make changes to
RELAY-080-08 to state that when a relay or contact is replaced, the configuration of the
relay or contact shall match the installed relay and applicable drawings. Furthermore,
the procedure was changed to record allowable dropout voltage as specified in
applicable drawings and that a maintenance supervisor or engineer shall verify the
correct set-point information.
The second root cause was that existing procedural guidance was inadequate to
correctly test the relay per procedure MD-024, Post Maintenance Testing Program,
Revision 23, that stated calibration alone was an adequate post maintenance test for
protective relays. The corrective action to prevent recurrence was to modify procedure
MD-024 to require at a minimum, return to service testing of TS-required equipment to
ensure that functionality and operability requirements are met.
The resident inspectors reviewed the RCE and found the licensees root and contributing
causes, as well as the corrective actions, appropriate to the circumstances with one
exception. A contributing cause was identified by the licensee associated with WO
planning being inadequate to identify relay configuration and acceptance criteria. The
licensees corrective action to address this contributing cause was to provide a briefing
to WO planners that procedure MA-AA-203-1001, Section 4.2 stated, in part that
acceptance criteria, requirements for as-found/as-left data, set points, and other related
information must be copied verbatim from the controlled procedure, and that if that
requirement was not going to be conducted, the expectation was that the requirements
were verified to ensure that the information was in fact contained in the procedure being
referenced. Procedure PI-AA-100-1005, Section 4.10, Step 2 stated in part, that
corrective actions should be specific and address each root and contributing cause.
Further, Section 4.10, Step 3 stated, in part that all corrective actions shall be consistent
with the SMART approach - (Specific, Measurable, Achievable, Relevant, and Timely)
(refer to PI-AA-205). Per procedure PI-AA-205, Condition Evaluation and Corrective
Action, Revision 25, a Relevant corrective action is one in which the action is aligned
with the issue that it is intended to resolve and will correct the problem.
The inspectors questioned the licensees corrective action to provide a briefing of
expectations to WO planners given the apparent procedural weakness in
MA-AA-203-1001. Specifically, Section 4.2 of MA-AA-203-1001 provided WO planners
with several options/steps that could be used to create work task instructions. The
corrective action to address the contributing cause only addressed Option/Step 3 in
Section 4.2 but made no reference to Option/Step 2 which stated that Controlled
procedures may be referenced in the work task instructions and included in the work
order package. The inspectors were concerned that using Option 2, as it existed, did
not ensure that WO planners verify the controlled document referenced contained the
appropriate acceptance criteria, as-found/as-left data, set points, and other related
information relevant to the circumstances.
31
The existing procedural error-trap that was not addressed as part of the RCE
contributing cause corrective action was documented in CRs 01972812 and 01972807.
Condition Report 01972807 specifically added a verification step as part of procedure
MA-AA-203-1001, Section 4.2, Step 2, to verify the procedure being referenced
contained the relevant information to the work task being accomplished.
Analysis: The inspectors determined that the issue of concern represented a
performance deficiency because it was the result of the licensees failure to prescribe a
procedure appropriate for the circumstances. Specifically, on June 18, 2014, procedure
MA-AA-203-1001, Work Order Planning, Section 4.2, Step 2, inappropriately allowed
the selection of model work orders without verification of the acceptance criteria,
requirements for as-found/as-left data, set points, and other related information. The
performance deficiency was within the licensees ability to foresee and correct and
should have been prevented because the licensee had a process in place to
appropriately identify, evaluate and correct issues noted as part of the Root Cause
Evaluation process.
The performance deficiency was determined to be more than minor and a finding in
accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue
Screening, because if left uncorrected, the performance deficiency would have the
potential to lead to a more significant safety concern. Specifically, MA-AA-203-1001 was
deficient, in that a WO planner could select a model work order without a required
verification of the work objectives to ensure correct equipment configuration and
functional testing was performed.
The inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, to
this finding. The inspectors answered No to all questions within Table 3 - SDP
Appendix Router, and transitioned to IMC 0609, Appendix A, The Significance
Determination Process for Findings At-Power. Per Exhibit 2 - Mitigating Systems
Screening Questions, the inspectors determined that because the finding did not
represent an actual loss of function (redundant loss of power instrumentation remained
operable during the period of the 127-SB2 inoperability), the finding screened as very
low safety significance (Green).
The inspectors determined that the performance characteristic of the finding that was the
most significant causal factor of the performance deficiency was associated with the
cross-cutting aspect of Evaluation in the Problem Identification and Resolution area and
involved the organization thoroughly evaluating issues to ensure that resolutions
address causes and extent of conditions commensurate with their safety significance.
Specifically, the licensee correctly identified the need to ensure work orders either
contained appropriate acceptance criteria, as-found/as-left data, set points, and other
related information relevant to the circumstances, but failed to fully evaluate the
adequacy of the contributing cause corrective action and its applicability to the work
order planning procedure as a whole.
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, requires in part, that activities affecting quality shall be prescribed by
documented procedures of a type appropriate to the circumstances.
Contrary to the above, on June 18, 2014, the licensee failed to prescribe a work order
planning procedure appropriate for the circumstances. Specifically, procedure
MA-AA-203-1001, Work Order Planning, Revision 1, was not appropriate in that it did
32
not ensure that appropriate configuration and testing criteria were verified prior to
developing work orders.
Because this violation was of very low safety significance and because the issue was
entered into the licensees CAP as CRs 01972812 and 01972807, consistent with
Section 2.3.2 of the Enforcement Policy it is being treated as a NCV.
(NCV 05000331/2014003-03, Failure to Prescribe Work Order Planning Procedure
Appropriate to the Circumstances).
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)
.1 (Closed) Licensee Event Report 05000331/2014-001-00 and 05000331/2014-001-01:
Condition Prohibited by Technical Specifications - Past Inoperability of Standby
Transformer Under-Voltage Relay
This event, which occurred on January 17, 2014, involved the Standby Transformer
under-voltage relay 127-SB2 which was found inoperable during surveillance testing and
was inoperable since it was replaced on September 16, 2013. See Section 4OA2.5
above for a detailed description of the event and an associated NRC-identified NCV.
The inspectors reviewed LERs05000331/2014001-00 and 05000331/2014001-01
against reporting requirements and found no issues. A licensee-identified violation
associated with this event and the enforcement aspects are discussed in Section 4OA7
below. Documents reviewed are listed in the Attachment to this report. These LERs are
closed.
This inspection constituted one event follow-up sample as defined in IP 71153-05.
4OA6 Management Meetings
.1 Exit Meeting Summary
On July 21, 2014, the inspectors presented the inspection results to Mr. G. Pry, Plant
General Manager, and other members of the licensee staff. The licensee acknowledged
the issues presented. The inspectors confirmed that none of the potential report input
discussed was considered proprietary.
.2 Interim Exit Meetings
An interim exit was conducted for the inspection results for the areas of radiation
monitoring instrumentation, radioactive gaseous and liquid effluent treatment, and
occupational exposure control effectiveness performance indicator verification with
Mr. R. Anderson, Site Vice President, on June 13, 2014. The inspectors confirmed that
none of the potential report input discussed was considered proprietary.
4OA7 Licensee-Identified Violations
The following violations of very low significance (Green) were identified by the licensee
and are violations of NRC requirements which meet the criteria of the NRC Enforcement
Policy for being dispositioned as NCVs.
- Duane Arnold Energy Center Renewed Operating License Condition 2.C.(3),
Fire Protection Program, stated, in part that Duane Arnold shall implement and
33
maintain in effect all provisions of the approved fire protection program that
comply with 10 CFR 50.48(a) and 10 CFR 50.48(c).
Contrary to the above, on March 6, 2014, the licensee transitioned their fire
protection program to NFPA 805 without having tested or having procedures to
test fire suppression deluge systems 3 and 4. Specifically, procedure
FP-AB-100, DAEC Fire Protection Program, Section 3.4.4, stated in part that,
NFPA 805, Section 3.2.3(1) provides the requirements for establishing
procedures that address inspection, testing and maintenance for fire protection
systems and features credited by NFPA 805. Section 3.4.4(2), stated in part
that, fire protection systems are periodically inspected and tested in accordance
with established procedures recommended by equipment manufacturers or by
nationally recognized organizations such as the NFPA. Procedure
FP-AA-04-1000, Fire Protection Maintenance, Testing, Impairment and
Compensatory Actions, Section 4.2.1.1, stated in part that, procedures shall be
established for any testing on fire protection systems, equipment and features.
Section 1R15.1 above provides additional background description for this
licensee-identified violation. The inspectors determined the finding could be
evaluated using the SDP in accordance with IMC 0609, Significance
Determination Process, Attachment 0609.04, Initial Characterization of
Findings, Table 3 - SDP Appendix Router and IMC 0609, Appendix F,
Attachment 1, Fire Protection Significance Determination Process Phase 1
Worksheet. Because the inspectors answered Yes to the Step 1.3, Task 1.3.1
question Is the reactor able to reach and maintain safe shutdown (either hot or
cold) condition? the finding screened as very low safety significance (Green).
The licensee documented the issue in CR 01959153; created appropriate testing
procedures to demonstrate deluge 3 and 4 functionality, and satisfactorily air flow
tested the deluge systems in accordance with approved procedures.
- Technical Specification 3.3.8.1, Loss of Power Instrumentation, required in part,
that if any 4.16 kV emergency bus under-voltage (degraded voltage) channel
was inoperable, that the associated Diesel Generator (DG) be declared
inoperable within one hour from discovery of loss of initiation capability for
feature(s) in one or both divisions as well as placing the channel in trip within
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above on September 19, 2013, the licensee failed to declare the
B DG inoperable and entered a condition prohibited by TSs. Specifically,
WO 40126852 was completed to replace relay 127-SB2, 1A4 4KV Emergency
Transformer Supply Under-voltage, due to dirty contacts. However, 127-SB2
was returned to service without post maintenance testing appropriate to the
circumstances. This resulted in 127-SB2 being in an inoperable status when the
required action to declare the B DG inoperable within one hour was not
accomplished. Section 4OA2.5 above provides additional background
description for this licensee-identified violation. The licensee documented the
conditions prohibited by TSs for relay 127-SB2 in CRs 01934167 and 01934040.
The inspectors determined the finding could be evaluated using the SDP in
accordance with IMC 0609, Significance Determination Process, Attachment
0609.04, Initial Characterization of Findings, Table 3 - Appendix Router and
IMC 0609 Appendix A, The Significance Determination Process for Findings At
Power, Exhibit 2 - Mitigating Systems Screening Questions. Because the
34
inspectors answered No to all questions in Section A, the finding screened as
very low safety significance (Green). Section 4OA2.5 describes the corrective
actions taken by the licensee.
ATTACHMENT: SUPPLEMENTAL INFORMATION
35
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
R. Anderson, Site Vice President
G. Pry, Plant General Manager
K. Kleinheinz, Site Engineering Director
W. Bentley, Maintenance Director
M. Davis, Emergency Preparedness and Licensing Manager
K. Peveler, Nuclear Oversight Manager
R. Wheaton, Operations Director
R. Porter, Radiation Protection Manager
D. Olsen, Chemistry Manager
J. Schwertfeger, Security Manager
C. Hill, Training Manager
B. Murrell, Licensing Engineer Analyst
L. Swenzinski, Licensing Engineer
C. Casey, Chemistry Supervisor
Nuclear Regulatory Commission
C. Lipa, Chief, Reactor Projects Branch 1
M. Chawla, Project Manager, NRR
Attachment
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
05000331/2014003-01 NCV Failure to Accomplish Procedure for Repetitive Malfunctions
of Refuel Floor Radiation Monitor (Section 1R12.1)05000331/2014003-02 NCV Failure to Establish Fire Patrols as Compensatory Actions in
Accordance with the Fire Protection Program
(Section 1R15.1)05000331/2014003-03 NCV Failure to Prescribe Work Order Planning Procedure
Appropriate to the Circumstances (Section 4OA2.5)
Closed
05000331/2014003-01 NCV Failure to Accomplish Procedure for Repetitive Malfunctions
of Refuel Floor Radiation Monitor (Section 1R12.1)05000331/2014003-02 NCV Failure to Establish Fire Patrols as Compensatory Actions in
Accordance with the Fire Protection Program
(Section 1R15.1)05000331/2014003-03 NCV Failure to Prescribe Work Order Planning Procedure
Appropriate to the Circumstances (Section 4OA2.5)
05000331/2014-001-00; LER Condition Prohibited by Technical Specifications - Past
-01 Inoperability of Standby Transformer Under-Voltage Relay
(Section 4OA3.1)
Discussed
None
2
LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection. Inclusion on this list
does not imply that the NRC inspector reviewed the documents in their entirety, but rather that
selected sections or 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.
1R01 Adverse Weather Protection
AOP 903; Severe Weather; Revision 39
OP-AA-102-1002; Seasonal Readiness; Revision 4
AOP 410; Loss of River Water Supply/High River Bed Elevation/Low River Water Depth;
Revision 27
AOP 902; Flood; Revision 51
Condition Evaluation (CE) 01942883-01; Inventory of Flood Materials per WO 40249718-01 and
AOP 902
CE 01957698-01; Conduct a Rework Evaluation for Rainwater Leaking into the RCIC Room
Through Hatch
CR 01942883; Inventory of Flood Material per WO 40249718-01 and AOP 902
CR 01949252; Frequency Based PM Needed for Flooding Preps
CR 01957698; Rainwater Leaking into RCIC Room Through Hatch
CR 01963290; Storm Drain Entrance Almost Completely Blocked by Gravel
CR 01969659; Doors, Bottom Seal Improvements Mitigate Potential Water Intrusion
CR 01969674; Flood/Conduit Seals Capability for Flood Protection
CR 01969689; Conduit Internal Seal Inspections/Flood Inspections
CR 01972529; Water Found in MH107 Following Storm/Heavy Rain
CR 01972989; Water Intrusion into Various Reactor Building and Essential Switchgear Room
CR 01973136; Initiate Work Order to Seal Penetration - AOP 902
CR 01973155; Initiate Work Order to Relocate Gasoline/Diesel Storage Tanks - AOP 902
CR 01973261; Rain Water Entering CSC Building during Severe Weather
CR 01973305; AOP 902 Flood Entry Due to Cedar River Water Level
CR 01973311; Safety CR Rain Water Intrusion at Cable Spreading Room Door
CR 01973646; Water Intrusion into Refuel Floor and RCIC Room
POD 01957698-01; Rainwater Leaking into RCIC Room through Hatch; Revision 0
1R04 Equipment Alignment
Operating Instruction (OI) 710, Intake Structure HVAC System, Revision 14
DCR985A; Intake Structure Air Compressors
DCR985B; Power Separation for Instrument Air Compressors
OI 255A2; Control Rod Drive System Valve Lineup and Checklist; Revision 5
OP-AA-102-1003; Guarded Equipment; Revision 5
OI 255A2; Control Rod Drive System Valve Lineup and Checklist; Revision 5
OI 710; Intake Structure HVAC System; Revision 14
OI 730A1; Control Building HVAC System Electrical Lineup; Revision 3
OI 730A4; Plant Chilled Water System Valve Lineup; Revision 17
OI 730A6; Control Building HVAC System Control Panel Lineup; Revision 9
BECH-M161; P&ID Air Conditioning System Control Building; Revision 53
BECH-M169<2>; P&ID Control Building Cooling System; Revision 22
BECH-M169<3>; P&ID Control Building Chillers 1VCH001A and 1VCH001B; Revision 13
3
DCR985A; Intake Structure Air Compressors
DCR985B; Power Separation for Instrument Air Compressors
1R05 Fire Protection
STP NS13B005; WK3-Portable Fire Extinguishing Equipment Inspection
STP NS13B005; Portable Fire Extinguishing Equipment
CR 01974458; Violation of Fire Hazards Analysis for Fire Zone OAG
CR 01974441; Violation of Administrative Control Procedure (ACP) 1412.2, Control of
Combustibles
CR 01974230; Poor Housekeeping in the Turbine Building Exhaust Fan Penthouse
FHA-200; NFPA 805 Fire Protection Design Document; Revision 16
FHA-400; Duane Arnold Energy Center Fire Protection Program; Revision 14
FP-AB-100; Fire Protection Program; Revision 0
ACP 1412.2; Control of Combustibles; Revision 41
ACP 1412.4; Impairments to Fire Protection Systems; Revision 69
PFP-RB-757; Pre-Fire Plan Reactor Building El. 757; Revision 0
PFP-RB-812; Pre-Fire Plan Reactor Building El. 812; Revision 0
PFP-RB-828; Pre-Fire Plan Reactor Building El. 828; Revision 1
PFP-RB-855; Pre-Fire Plan Reactor Building El. 855; Revision 1
PFP-TB-780; Pre-Fire Plan Turbine Building El. 780; Revision 0
STP NS13F006; Structural Steel Fireproofing Inspection; Revision 17
STP NS13B005; WK3-Portable Fire Extinguishing Equipment Inspection
STP NS13B005; Portable Fire Extinguishing Equipment
CR 01964471; Deluge #2 Leak Getting Worse
CR 01966499; Missing Items During Fire Brigade Inventory
CR 01966736; Leakage on Primary Line Upstream of Isolation
CR 01966799; HPCI Deluge #2 FPR-14-7114
1R06 Flooding
ECPM SECT 4.4; Electrical Manhole Inspection Frequency; Revision 1
WO 40308721; SUS99.09 Inspect Manholes MH104, MH105, MH106 and MH107
BECH-E350<1>; Underground Duct Bank Layout; Revision 7
BECH-E351<1>; Manhole Details; Revision 2
CR 01965875; Manhole MH104, MH105; MH106, MH107 Inspect Results May 14, 2014
CR 01966371; DNA - CAS Operator Observed Water Flowing From Manhole
CR 01972529; Water Found in MH107 Following Storm/Heavy Rain
CR 01974836; Run Boroscope through Conduit Y156A to Check for Obstruction
1R11 Licensed Operator Requalification Program
OP-020; Area Inspections; Revision 26
Reactivity Management Plan; Downpower for Control Rod Sequence Exchange; May 2014
CE 01967067; Tar-Like Substance Found on Floor of the Condenser Bay; Revision 1
CR 01967056; CV1097A Has a 5-10 DPM Packing Leak
CR 01967057; V03-0245 LS-1070A Lower Isolation Packing Leak
CR 01967058; CV1064 in Steam Tunnel Has 10-15 DPM Leak from Packing
CR 01967067; Identified Abnormal Leakage on Condenser Bay Floor
4
1R12 Maintenance Effectiveness
CR 01943118; 1K016A Intake Air Compressor Tripped Again
CR 01944636; TC7715A Leaking Air
CR 01944627; 1VT050A Excessive Leakage
CR 01944750; 1K016A Failed Once Again
CR 01952071; Air Leak Past Fitting Upstream of Check Valve V77-0019
CR 01960690; 1K016A Intake Air Compressor is Short Cycling
CR 01960301; 1K016A Intake Air Compressor Found Not Cycling
CR 01961140; 1K016A Found Tripped
CR 01961192; V77-0022 Has an Air Leak
CR 01962708; 1K016A Not Carrying Load at Intake Structure
CR 01966760; Air Dryer was Found in Service but not Purging
CR 01967005; DO7713A Positioner Inlet Supply Line Leaking Air
CR 01969340; DNA-River Water Supply HVAC Controllers Not Installed per Specifications
CR 01970330; 1K-16A Exhaust Line Air Fryer Not Functioning
CR 01942767; Unexpected Alarm on RIS-4131A
CR 01949942; Unexpected Alarm on A Fuel Pool Rad Monitor Downscale
CR 01953813; Annunciator 1C03A (C-1) Fuel Pool Exhaust RIS-4131A/B Rad Monitor
CR 01954560; Momentary Alarms Associated with RIS-4131A
CR 01867785; Unexpected Alarm from RIS-4131A
CR 01867929; Momentary Spike Down on RR4131
CR 01877344; Fuel Pool Exhaust RIS-4131A/B Downscale/Inoperable Alarm Activated & Reset
CR 01909908; RIS-4131A Spiked Downscale
CR 01911385; Fuel Pool Exhaust RIS-4131A/B Downscale/Inoperable Alarm Activated & Reset
CR 01912005; CRs and WRs are not Automatically Crossed Referenced to WOs
CR 01912041; Trend - RIS-4131A/B Downscale/Inoperable Alarms not Fixed
CR 01920482; No Equipment Reliability Issues for the Refuel Floor Radiation Monitor
CR 01935047; Trend - Increased Trend in Relay Issues
1R13 Maintenance Risk Assessments and Emergent Work Control
WPG-2; On-Line Risk Management Guideline; Revision 65
WMA-AA-100; Risk Management Program; Revision 0
EN-AA-105; Probabilistic Risk Assessment (PRA) Program; Revision 0
Operators Risk Report; June 26, 2014
Operators Logs; May 30-31, 2014, and June 9, 16, 17, 2014
WO 40239697-01; E/S4599B: Replace Electrolytic Capacitors
STP 3.5.1-03A; A Core Spray System Simulated Automatic Actuation; Revision 9
WPG-1; Work Process Guideline; Revision 61
OP-AA-104-1007; Online Aggregate Risk; Revision 2
WM-AA-100-1000; Work Activity Risk Management; Revision 1
OP-AA-102-1003; Guarded Equipment; Revision 5
Work Week 1424 Work Activity Risk Management Summary and Weekly Probabilistic Risk
Analysis
AOP 410; Loss of River Water Supply/High River Bed Elevation/Low River Water Depth;
Revision 27
EP-AA-105 (DAEC); Maintaining Equipment Important to Emergency Preparedness (DAEC
Specific Information); Revision 3
EP-AA-105; Maintaining Equipment Important to Emergency Response; Revision 4
Operators Risk Report; June 26, 2014
5
Operators Logs; May 30-31, 2014, and June 9, 16, 17, 2014
WO 40239697-01; E/S4599B: Replace Electrolytic Capacitors
WO 40293372-01; 94-K7333B Replace Relay
WO 40249563-01; AV7318B-O: Calibrate Positioner
WO 40267914-01; 1VEF036B: MA-Inspect Unit
WO 40310673-01; 1G-31 Lube Oil Cooler Heat Exchanger
STP 3.3.8.1-04B; 1A4 4KV Emergency Bus Under-voltage Relay Calibration; Revision 2
M063-033; B Control Building Chiller Mechanical Drawing (1VCH001B); Revision 6
M063-036; Control Building Chiller Condenser 1E235A Fabricated Head; Revision 0
CE 01965912; Kaman 2 High Alarms
CR 01973110; Kaman 2 Auto Check Source Needs Repositioning
CR 01972939; Emergency Service Water System Unavailability in Maintenance Rule Yellow
Status
CR 01948954; Unplanned TS and TRM Entries due to Door Timeout
CR 01949651; Unplanned Standby Filter Unit/Control Building Boundary LCO Entry on
Door 402
CR 01945507; Possible Missed Surveillance; 1/2 of 3.4.5-03 Not Completed
1R15 Operability Determinations and Functionally Assessments
CR 01946048; Apparent Cause Evaluation Report, LS1861D Calibration Found out of
Tolerance
EN-AA-203-1001; Operability Determinations/Functionality Assessments; Revision 16
FP-AA-104-1000; Fire Protection Maintenance, Testing, Impairment and Compensatory Action;
Revision 0
FP-AB-100; DAEC Fire Protection Program; Revision 0
ACP 107.0; Surveillance Tests
ACP 111.0; Inspection, Test Control and Testing; Revision 6
ACP 1412.4; Impairments to Fire Protection Systems, Revision 70
ACE 1966869; Standby Liquid Control Foreign Material; Revision 2
POR 1966869; Standby Liquid Control Foreign Material Past Operability Review
CE 01964875-01; NRC Question on Use of TSR 3.0.3 and the TRM
CR 01946048; Apparent Cause Evaluation Report, LS1861D Calibration Found Out of
Tolerance
CR 01959153; No Air Flow Testing Procedures Exist for TRM Deluge Systems
CR 01963691; TRM Surveillance Requirements Not Performed
CR 01963696; Missed TRM Surveillance for Hose Stations
CR 01964875; NRC Question on Use of TSR 3.0.3 and the TRM
CR 01964878; NFPA Requirements for Air Flow Testing
CR 01971501; TLCO Times for Fire Detection and Suppressions Challenged
CR 01966869; Standby Liquid Control Foreign Material
Procedure Change Request (PCR) 01968702; EN-AA-203-1001 - Operability
Determinations/Functionality Assessments
PCR 01968720; ACP 107.0 - Surveillance Tests
TWR 01976300; Provide Training on the Proper Use of SR 3.0.3 and TSR 3.0.3
CR 01956085; CAL-M98-058 (Alternate Depressurization System Accumulator Size
Verification) Inputs Error
CR 01956930; Investigate Potential Non-Conservative TS SR 3.5.1.3
6
1R18 Plant Modifications
CR 01961603; Errors on Original Code Data Reports for Condenser
CR 01961294; S&L Draft Evaluation Not Favorable for 1E235A Return to Service
CR 01960576; A Control Building Chiller Condenser 1E235A Return Head Has Corrosion
1R19 Post-Maintenance Testing
STP 3.5.1-05; HPCI System Operability Test; Revision 58
WO 40170771; MO2247-O, Lube and Inspect Gearbox and Limit Switch
WO 40176867; MO2318-O; Inspect Lube Gearbox and Limit Switch
WO 40175686; 1P218-M, Inspect & Perform PI Test
STP 3.8.1-06B; B Standby Diesel Generator Operability Test (Fast Start); Revision 15
WO 40184541; 1P229C-M, Change Out Upper Motor Bearing (RHR)
CR 01844913; C RHR Motor Oil Reservoir Found Metal Shavings
WO 40107646; Replace Electrolytic Capacitors
WO 40168715; MO 2515-O, Lube & Inspect
WO 40173426; Calibrate TE 2406 (Maintenance Run)
WO 40172163; FI 2509: Calibrate
WO 40172161; FIC2509: Replace MPU Board
WO 40172164; FT2509: Calibrate
STP 3.5.3-02; RCIC System Operability Test; Revision 37
MD-062; Work Order Task(s); Revision 7
MD-024; Post Maintenance Testing Program; Revision 78
STP 3.5.1-02A; A LPCI System Operability Tests; Revision 14
STP 3.5.3-02; RCIC System Operability Test; Revision 44
CAL-E90-008; In-Service Testing Program Instrument Accuracy; Revision 17
POD 1971819; Instrument Accuracy Accounted for in RCIC Flow Rate in STP 3.5.3-02
CR 01964910; NRC Question Regarding PI 2302, HPCI Booster Pump Suction PI
CR 01967624; FI2509 Indicated 395 GPM During RCIC Operability Test
CR 01967794; DNA - Margin to RCIC Tech Spec Flow Requirement is Low
CR 01971819; Instrument Accuracy Accounted for in RCIC Flow Rate STP
1R22 Surveillance Testing
STP 3.3.6.1-32; RCIC Exhaust Diaphragm Channel Functional Test; Revision 4
ACP 107; Surveillance Tests; Revision 17
STP 3.0.0-01; Surveillance Test Procedure Instrument Checks; Revision 142
STP 3.3.6.1-32; RCIC Exhaust Diaphragm Channel Functional Test; Revision 4
STP 3.5.1-01B; B Core Spray System Operability Test; Revision 15
STP 3.3.1.1-13; Turbine Control Valve EOC RPT Logic and RPS Instrument Function Test;
Revision 15
STP 3.5.1-03A; A Core Spray System Simulated Automatic Actuation; Revision 9
STP NS930002; Main Turbine Stop and Combined Intermediate Valves Test; Revision 5
APED-E41-002; Process Diagram High Pressure Coolant Injection System
CAL-M91-010; Recommended Discharge Pressure for HPCI Main Pump Test; Revision 1
CAL-M91-011; Recommended Discharge Pressure for RCIC Main Pump Test; Revision 0
CE 1961465-01; Evaluate Minimum HPCI Pump Discharge Pressure During Operability STPs
CE 1961479-01; Evaluate Minimum RCIC Pump Discharge Pressure During Operability STPs
CR 01961465; DNA AR: HPCI STPs May Contain an Incorrect Pump Discharge Pressure
7
CR 01961479; DNA AR: RCIC STPs Minimum Pump Discharge Pressure Less Than CAL
M91011
CR 01967068; SV and ISV Position Indication Problems for STP NS930002
CR 01968205; ODMI for MSR Drain Tank Dump Valve Leak By
PCR 1961750; Change STPs 3.5.1-05, 3.5.1-09, 3.5.1-10 Minimum HPCI Pump Discharge
Pressure
2RS5 Radiation Monitoring Instrumentation
STP 3.0.0-01; Surveillance Test Procedure Instrument Checks; Revision 142
STP NS790301; GSW Radiation Monitor Calibration
STP NS791011; K8 Calibration
STP NS791013; K10 Calibration
OI 920; Drywell Sump Systems; Revision 46
2RS6 Radioactive Gaseous and Liquid Effluent Treatmen
PCP 8.7; Alarm Setpoints for Liquid Rad Monitors; Revision 17
PCP 8.4; Alarm Setpoints and Efficiency for GE Offgas Stack Rad Monitor; Revision 10
EV-AA-100; Fleet Ground Water Protection Program; Revision 2
ACP 1411.35; The DAEC Groundwater Protection Program; Revision 8
STP 3.6.4.3-03-A; SBGT Sys HEPA/CHAR Filter Efficiency Test
STP 3.6.4.3-03-B; SBGT Sys HEPA/CHAR Filter Efficiency Test
NS790505; Effluent Noble Gas Sampling & Analysis; Revision 3
NS790601; Effluent P & I Sampling & Analysis; Revision 24
EV-AA-100-1001-F01; 10 CFR 50.75(g) Documentation; various dates
Duane Arnold Energy Center Operations and Maintenance Activity Assessment of Unplanned
Releases; July 12, 2013
EN 48403; Offsite Notification Due to Leak From Condensate Storage Tank Containment Pit
Sump; October 12, 2012
Five Year Review of the DAEC GWPP Monitoring Plan; August 13, 2013
Ground Water Protection Initiative Site Conceptual Model; May 29, 2013
CR 01812156; CST Pit Sump Seal Leaking
CR 01827363; Structural Monitoring, CST Foundation Floor Surface Cracks
CR 01820689; Degraded Drain Piping Found in Turbine Building Basement
CE 01905073; Tritium and Cesium 137 Identified in Conduit Water - 2013
4OA1 Performance Indicator Verificaiton
CR 01910625; Walkdown Scope Increase
CR 01971250; TS Hi-Rad Violation Not Characterized Correctly: NRC PI Q413
MSPI Basis Document; Revision 16
NRC PI Data Calculation, Review and Approvals; RCS Leakage; 2nd Quarter 2013 through
1st Quarter 2014
OI 920; Drywell Sump System; Revision 46
CR 01866940; Very Slight Increasing Trend in Drywell Unidentified Leakage
CR 01867793; Drywell Equipment Sump Did Not Auto Pump
CR 01871786; Equipment Sump Inconsistent Pump Volumes Today
CR 01872165; DWEDS Totalizer FQ3708 Drift Due to 1P-037A Control Circuit De-energized
CR 01872166; Abnormal DW Identified Leakage Calculation Due to FQ3708 Drift
CR 01879703; Drywell Equipment Drain Pump, 1P-37B, Did Not Auto Pump
8
CR 01886976; DWEDS Has Not Pumped for Greater Than 8 Hours
CR 01887568; Level Switch is Sticking
CR 01887570; Drywell Floor Drain Leakage Calculated High
CR 01951939; Potential Adverse Trend - Sump Pump Issues
CR 01965584; Equipment Sump Failed to Pump at 1200
CR 01910625; Walkdown Scope Increase
CR 01971250; TS Hi-Rad Violation not Characterized Correctly: NRC PI Q413
4OA2 Identification and Resolution of Problems
RCE 01934040; Under-voltage Relay Failed Root Cause Evaluation
MA-AA-203-1001; Work Order Planning; Revision 1
Relay-G080-08; General Electric Under-voltage Relay Type NGV; Revision 11
STP 3.3.8.1-05B; 1A4 4KV Emergency Transformer Supply Under-voltage Calibration;
Revision 2
WO 40136277-01; STP 3.3.8.1-05-B 4KV Transformer Supply Under-voltage
MD-024; Post Maintenance Testing Program; Revision 78
MA-AA-202; Work Order Execution Process; Revision 8
MD-062; Work Order Task(s); Revision 6
MA-AA-201; Work Order Identification, Screening and Validation Process
WM-AA-200; Work Management Process Overview; Revision 8
AD-AA-103; Nuclear Safety Culture Program; Revision 5
PI-AA-100-1002; Procedure for Failure Investigation Process; Revision 9
OP-AA-100-1002; Plant Status Control Management; Revision 2
PI-AA-101-1000; Focused Self-Assessment Planning, Conduct and Reporting; Revision 10
ACP 1410.2; LCO Tracking and Safety Function Determination Program; Revision 32
AD-AA-100-1006; Procedure and Work Instruction Use and Adherence; Revision 3
PI-AA-204; Condition Identification and Screening; Revision 24
PI-AA-205; Condition Evaluation and Corrective Action; Revision 25
PI-AA-100-1005; Root Cause Analysis; Revision 9
PI-AA-100-1007; Apparent Cause Evaluation; Revision 8
CR 01934040; STP 3.3.8.1-05-B, 4KV Emergency Transformer Under-voltage Failed
CR 01934167; 127/SB2 Standby Transformer 1X4 Under-voltage Relay Wrong Configuration
CR 01941895; Reportability Review Due Date Set Past LER 60 Day Due Date
CR 01972812; Contributing Cause Actions for Under-voltage Relay RCE #1934040
PCR 01972807; MA-AA-203-1001 - Work Order Planning
9
LIST OF ACRONYMS USED
ACP Administrative Control Procedure
ADAMS Agencywide Document Access Management System
AOP Abnormal Operating Procedure
CAP Corrective Action Program
CBC Control Building Chiller
CE Condition Evaluation
CFR Code of Federal Regulations
CR Condition Report
DAEC Duane Arnold Energy Center
DG Diesel Generator
IOD Immediate Operability Determination
IMC Inspection Manual Chapter
IP Inspection Procedure
kV Kilovolt
LCO Limiting Condition for Operation
LER Licensee Event Report
LPCI Low Pressure Coolant Injection
NCV Non-Cited Violation
NFPA National Fire Protection Association
NRC U.S. Nuclear Regulatory Commission
ODCM Offsite Dose Calculation Manual
OFR Operability/Functionality/Reportability
OI Operating Instruction
PARS Publicly Available Records System
PCR Procedure Change Request
PFP Pre-Fire Plan
PI Performance Indicator
PM Planned Maintenance
POD Prompt Operability Determination
POR Prompt Operability Review
RCE Root Cause Evaluation
RCIC Reactor Core Isolation Cooling
SBDG Standby Diesel Generator
SDP Significance Determination Process
SSC Structure, System, and Component
STP Surveillance Test Procedure
TLCO Technical Requirements Manual Limiting Condition for Operation
TRM Technical Requirements Manual
TSR Technical Surveillance Requirement
TS Technical Specification
UFSAR Updated Final Safety Analysis Report
R. Anderson -2-
In accordance with Title 10 of the Code of Federal Regulation 2.390, Public Inspections,
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter
and its enclosure, and your response (if any) will be available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Christine Lipa, Chief
Branch 1
Division of Reactor Projects
Docket No. 50-331
License No. DPR-49
Enclosure:
Inspection Report 05000331/2014003
w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
DISTIRBUTION w/encl:
RidsNrrDorlLpl3-1 Resource Linda Linn
RidsNrrPMDuaneArnold Resource DRPIII
RidsNrrDirsIrib Resource DRSIII
Cynthia Pederson Patricia Buckley
Darrell Roberts Carmen Olteanu
Steven Orth ROPreports.Resource@nrc.gov
DOCUMENT NAME: Duane Arnold IR 2014 003
Publicly Available Non-Publicly Available Sensitive 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 RNg for CPhillips:rj CLipa
DATE 08/11/14 08/11/14
OFFICIAL RECORD COPY