IR 05000331/2010007

IR 05000331-10-007, on 09/13/2010 - 10/01/2010, Duane Arnold Energy Center, Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

ML103120289
Person / Time
Site:	Duane Arnold
Issue date:	11/08/2010
From:	Robert Daley NRC/RGN-II/DRS/EB3
To:	Costanzo C NextEra Energy Duane Arnold
References
IR-10-007
Download: ML103120289 (16)

Text

ber 8, 2010

SUBJECT:

DUANE ARNOLD ENERGY CENTER EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000331/2010-007(DRS)

Dear Mr. Costanzo:

On October 1, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications inspection at your Duane Arnold Energy Center. The enclosed inspection report documents the inspection results, which were discussed on October 1, 2010, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of the 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 Duane Arnold Energy Center. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, 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/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No.50-331 License No. DPR-49

Enclosure:

Inspection Report 05000331/2010007(DRS)

w/Attachment: Supplemental Information

REGION III==

Docket No: 50-331 License No: DPR-49 Report No: 05000331/2010-007 Licensee: NextEra Energy Duane Arnold, LLC, Iowa Facility: Duane Arnold Energy Center Location: Palo, IA Dates: September 13 - October 1, 2010 Inspectors: C. Tilton, Senior Reactor Inspector (Lead)

V. Meghani, Reactor Inspector M. Munir, Reactor Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000331/2010-007; 09/13/2010 - 10/01/2010; Duane Arnold Energy

Center; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications.

This report covers a two-week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. One Severity Level IV finding was identified by the inspectors.

The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance and associated NCV of Technical Specification (TS) 3.8.1 for the licensee failing to perform TS Surveillance Requirement (SR) 3.8.1.6, which verifies the fuel oil transfer system operates to transfer fuel oil from storage tank to the day tank. Specifically, the licensee failed to perform Inservice Testing (IST) of the diesel fuel transfer pumps as intended by TS SR 3.8.1.6.

The inspectors determined that failure to perform IST of the diesel fuel transfer pumps as intended by TS SR 3.8.1.6 was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems attribute of Equipment Performance and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigation Systems Cornerstone. All four questions on this table were answered "no." Specifically, the licensee had still performed functionality tests of the pumps at the required frequency, and if the pumps had exhibited lower than expected flow during a demand period, the fuel day tanks had adequate margin to compensate to allow for operator action. Therefore, the issue screened as having very low safety significance. This finding has a cross-cutting aspect in the area of Human Performance, Work Control because the licensee did not appropriately assess the impact of changes to the work scope or activity on the plant and human performance. Specifically, the licensee failed to recognize that deleting the section of STP 3.8.1-11 that pertained to IST testing of the fuel oil transfer pump would delete steps in the procedure that were required by TS SR 3.8.1.6. (IMC 0302 (H.3(b))

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

.1 Evaluation of Changes, Tests, or Experiments

a. Inspection Scope

From September 13, 2010 through October 1, 2010, the inspectors reviewed eight safety evaluations performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 17 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issue requiring the change, tests, or experiment was resolved;

• the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection constituted eight samples of evaluations and 17 samples of changes as defined in IP 71111.17-04.

b. Findings

Failure to Perform Technical Specification Surveillance Requirement (SR) 3.8.1.6

Introduction:

A finding of very low safety significance and associated Non-Cited Violation (NCV) of Technical Specifications (TS) was identified by the inspectors for the licensee failing to perform Surveillance Requirement SR 3.8.1.6 which states: Verify the fuel oil transfer system operates to transfer fuel oil from storage tanks to the day tank.

Description:

To comply with Technical Specification (TS) 3.8.1, AC Sources -

Operating, the licensee is required to verify the diesel fuel oil transfer system operates to transfer fuel oil from storage tank to the day tank. This verification constitutes technical specification surveillance requirement SR 3.8.1.6. The TS Bases for this surveillance requirement states: This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control system for manual fuel transfer systems are OPERABLE.

Additional assurance of fuel oil transfer pump OPERABILITY is provided by meeting the testing requirements for pumps that are contained in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. Such testing is performed on a quarterly basis.

While reviewing screening SCRN023681, the inspectors noted that the licensee deleted steps in surveillance test procedure STP 3.8.1-11, Standby Diesel Generator Air Compressor, Air Start Check Valve and Fuel Oil Transfer Pump Tests. These steps performed the ASME Boiler and Pressure Vessel Code,Section XI, Inservice Testing, program requirements for the diesel fuel oil transfer pumps. This testing was deleted, because the licensee determined that the fuel oil transfer pumps did not have to be tested in accordance with IST testing requirements, since the pumps were not Code Class 1, 2, or 3 components. However, even though the pumps may not have needed to be tested as per IST requirements, the IST testing still needed to be performed, because it was an integral part of TS SR 3.8.1.6, as described in its associated TS Bases.

Screening SCRN023681 was performed on November 14, 2007. The licensee entered this issue into their corrective action program as AR 00583647. The licensee used the provisions in SR 3.0.3 for missed surveillances, allowing them to schedule the surveillance testing within its specified frequency on November 30, 2010, (Train B) and December 6, 2010, (Train A) with the previously deleted IST requirements included. As per SR 3.0.3, the licensee performed a risk evaluation showing that performing the fuel transfer pump surveillance testing at these dates was of low risk-significance.

Analysis:

The inspectors determined that the failure to perform the IST for the diesel fuel oil transfer pumps was contrary to the requirements of TS SR 3.8.1.6, Verify the fuel oil transfer system operates to transfer fuel oil from storage tank to the day tank and was performance deficiency.

The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, by not performing the IST portion of SR 3.8.1.6 for the diesel fuel oil transfer pumps, the licensee had not adequately ensured that these pumps would perform their safety related functions during an accident.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigation Systems Cornerstone. All four questions on this table were answered "no." Specifically, the licensee had still performed functionality tests of the pumps at the required frequency, and if the pumps had exhibited lower than expected flow during a demand period, the fuel day tanks had adequate margin to compensate to allow for operator action. Therefore, the issue screened as Green.

This finding has a cross-cutting aspect in the area of Human Performance, Work Control because the licensee did not appropriately assess the impact of changes to the work scope or activity on the plant and human performance. Specifically, the licensee failed to recognize that deleting the section of STP 3.8.1-11 that pertained to IST testing of the fuel oil transfer pump would delete steps in the procedure that were required by TS SR 3.8.1.6. (IMC 0305 (H.3(b))

Enforcement:

Technical Specification 3.8.1, AC Sources - Operating, requires the licensee to verify the diesel fuel oil transfer system operates to transfer fuel oil from storage tank to the day tank. This verification includes performing IST of the diesel fuel oil transfer pumps.

Contrary to the above, the licensee failed to perform the IST requirements of the diesel fuel oil transfer pumps. Specifically, on November 14, 2007, a screening removed several steps on procedure STP 3.8.1-11, Standby Diesel Generator Air Compressor, Air Start Check Valve and Fuel Oil Transfer Pump Tests, which performed the IST requirements of these components. Since November 14, 2007, these requirements have not been met. The licensees corrective actions included reinstatement of the IST program requirements to the steps on the procedure and the scheduling of surveillances for November 30, 2010, (Train B) and December 6, 2010, (Train A). Because this violation was of very low safety significance and it was entered into the licensees Corrective Action Program as AR 00583647, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000331/2010007-01 - Failure to Perform Technical Specification Surveillance Requirement 3.8.1.6)

.2 Permanent Plant Modifications

a. Inspection Scope

From September 13, 2010 through October 1, 2010, the inspectors reviewed ten permanent plant modifications. This review included in-plant walkdowns for portions of the modified HPCI suction line, two added supports within the RCIC piping inside the reactor building and a river water modification of wall penetrations.

The modifications were selected based upon risk-significance, safety-significance, and complexity. The inspectors reviewed the modifications selected to determine if:

• the supporting design and licensing basis documentation was updated;

• the changes were in accordance with the specified design requirements;

• the procedures and training plans affected by the modification have been adequately updated;

• the test documentation as required by the applicable test programs has been updated; and

• post-modification testing adequately verified system operability and/or functionality.

The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an attachment to this report.

This inspection constituted ten permanent plant modification samples as defined in IP 71111.17-04.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Condition Reports

a. Inspection Scope

From September 13, 2010 through October 1, 2010, the inspectors reviewed 15 corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent pant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting Summary

On October 1, 2010, the inspectors presented the inspection results to Mr. Kleinheinz and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Kleinheinz, Engineering Director

M. Lingenfelter, Design Engineering Manager

G. Young, Nuclear Oversight Manager

R. Murrell, Licensing Engineer

L. Swenzinski, Licensing Engineer

Nuclear Regulatory Commission

R. Daley, Chief, Engineering Branch 3, Division of Reactor Safety

L. Haeg, Senior Resident Inspector

R. Murray, Resident Inspector

LIST OF ITEMS

Opened and Closed

05000331/2010007-01 NCV Failure to Perform Technical Specification Surveillance Requirement 3.8.1.6 Attachment