IR 05000331/2013008

IR 05000331-13-008; 09/03/2013 - 10/31/2013; Duane Arnold Energy Center (Daec); Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

ML13339A886
Person / Time
Site:	Duane Arnold
Issue date:	12/05/2013
From:	Robert Daley Engineering Branch 3
To:	Richard Anderson NextEra Energy Duane Arnold
George Hausman
References
IR-13-008
Download: ML13339A886 (23)

Text

cember 5, 2013

SUBJECT:

DUANE ARNOLD ENERGY CENTER EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000331/2013008

Dear Mr. Anderson:

On October 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and 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 31, 2013, with Mr. Steve Huebsch, 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.

Two NRC identified findings of very low safety significance (Green) were identified during this inspection. These findings were determined to involve 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.

If you contest the violations or significance of these NCVs 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 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 Title 10, Code of Federal Regulations (CFR), Part 2, Section 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 05000331/2013008 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-331 License No: DPR-49 Report No: 05000331/2013008 Licensee: NextEra Energy Duane Arnold, LLC Facility: Duane Arnold Energy Center (DAEC)

Location: Palo, IA 52324-9785 Dates: September 3 through October 31, 2013 Inspectors: George M. Hausman, Senior Engineering Inspector (Lead)

David J. Oliver II, Engineering Inspector Stuart N. Sheldon, Senior Engineering Inspector Robert A. Winter, Engineering Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

IR 05000331/2013008; 09/03/2013 - 10/31/2013; Duane Arnold Energy Center (DAEC);

Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.

This report covers a two-week announced baseline inspection on evaluations of changes, tests, and experiments and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. Two findings were identified by the inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red)using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP).

Cross-cutting aspects were determined using IMC 0310, Components Within the Cross Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 7, 2012. 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 an associated NCV of Title 10, Code of Federal Regulations (CFR), Part 50, Appendix B,

Criterion III, Design Control, where the licensee failed to establish measures for the selection and review for the suitability of safety-related cables with Procedure Electrical Cable Program Manual (ECPM) 4.5, Electrical Cable Operability, Revision 2.

Specifically, ECPM 4.5, Attachment 1, Qualification of Cables in Wetted Environments, allowed for safety-related cabling that was not qualified or specifically designed for total submergence in water to be used in water filled conduits contrary to its unsuitability for this application, without suitable testing or design control measures. The licensee entered the issue into their Corrective Action Program as Action Request (AR) 01902782, ECPM - Electrical Cable Operability, dated September 10, 2013, which suspended the use of ECPM 4.5 by quarantining the procedure until the identified discrepancies could be resolved.

The performance deficiency was determined to be more than minor because the finding, if left uncorrected, would become a more significant safety concern. Specifically, not identifying and appropriately evaluating degraded or non-conforming conditions to properly assess the operability of cables subjected to protracted and/or extensive exposure to water could warrant not declaring a structure, system, and component (SSC) inoperable by the use of compensatory actions to maintain or enhance a degraded or non-conforming condition. This finding has a cross-cutting aspect in the area of human performance, decision-making because the licensee did not use conservative assumptions in implementing ECPM 4.5, Electrical Cable Operability,

Revision 2. Specifically, the licensee failed to perform an effective review of the consequences of their decision to include an attachment to this procedure that provided a method not previously approved for qualifying safety-related cables for submergence.

H.1(b) (Section 1R17.1b)

• Green: The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality following discovery of water and mud in safety-related electrical conduit 1K109 associated with the A Standby Diesel Generator (SBDG). Specifically, the licensee identified an obstruction characterized as mud located 8-feet from the turbine building (TB) end of conduit 1K109. As a result, the licensee failed to take corrective action to remove the water and mud from the conduit and to evaluate the mud obstruction. The licensee entered the finding into their Corrective Action Program as AR 01909315, NRC 5059/MOD Inspection Violation of App B Criterion 16, dated October 3, 2013. The licensee has performed insulation resistance checks on the EDG power cable and obtained satisfactory results. Additionally, the licensee performed an evaluation of the mud-like material in the conduit and determined that it is likely cable pulling compound, as opposed to degraded cable jacket material. The licensee also set a date for further inspection of the conduit to April 2014, which coincides with the next EDG outage period.

These corrective action items are being tracked in CR 1909315. Additionally the licensee is evaluating the frequency interval for inspecting this and other similar conduits.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstones attribute of design control for ensuring the availability, reliability, and capability of systems that respond to Initiating Events to prevent undesirable consequences. Specifically, material characterized by the licensee as mud facilitated continual exposure to a wetted and water submergence environment of the safety-related A SBDG power cables. Continual exposure to a wetted and water submergence environment could lead to cable failure. Cable failure would prevent the system from carrying out its intended safety-related function of automatically starting and connecting to its corresponding essential service bus to supply power to emergency loads in an event (i.e., a loss-of-coolant-accident (LOCA)and/or degraded/under-voltage condition). This finding has a cross-cutting aspect in the area of human performance, decision-making because the licensee did not use conservative assumptions to correct a condition adverse to quality following discovery of water and mud in safety-related electrical conduit 1K109 associated with the A SBDG.

Specifically, the licensee failed to perform an effective review of the safety-related consequences of their decision not to complete the inspection of conduit 1K109 to ensure that no water and mud remained inside the conduit subjecting the cables to a submergence environment. H.1(b) (Section 4OA2.1b)

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

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

.1 Evaluation of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed seven safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59, to determine whether the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed twenty-four 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, and 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 and experiment was resolved;

• the licensee conclusions for evaluations of changes, tests, and 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. The list of safety evaluations, screenings and/or applicability determinations reviewed by the inspectors is included as an Attachment to this report.

This inspection constituted seven samples of evaluations and twenty-four samples of screenings and/or applicability determinations as defined in IP 71111.17-04.

b. Findings

Failed to Establish Measures for the Selection and Review for the Suitability of Safety- Related Cables

Introduction:

The inspectors identified a finding of very low safety significance (Green)and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, where the licensee failed to establish measures for the selection and review for the suitability of safety-related cables with Procedure Electrical Cable Program Manual (ECPM) 4.5, Electrical Cable Operability, Revision 2. Specifically, ECPM 4.5, 1, Qualification of Cables in Wetted Environments, allowed for safety-related cabling that was not qualified or specifically designed for total submergence in water to be used in water filled conduits contrary to its unsuitability for this application, without suitable testing or design control measures.

Description:

On June 24, 2013, the licensee revised Procedure ECPM 4.5, Electrical Cable Operability, Revision 2, to include information from a licensee developed white paper that changed the procedures Attachment 1 to Qualification of Cables in Wetted Environments. Based on discussions with the licensees staff and a review of Action Request (AR) 01871921, ECPM - Electrical Cable Operability, dated May 6, 2013, the inspectors determined that the intent of the changes was to provide enhanced guidance to the Operations staff. The enhanced guidance was to assist the Operations staff in making operability decisions for safety-related cables that had been exposed to moisture and/or submergence and to address aspects of an NRC finding from the licensees first prompt operability determination (POD) documented in NRC Inspection Report 05000331/2012005, Section 1R15.

On October 12, 2012, during refueling outage (RFO) 23 (i.e., October 6 through November 26, 2012), the licensee performed work activity EC 275694, Repair Cable K00081-V, Revision 2, to replace the failed A Standby Diesel Generator (SBDG) day tank level switchs cable. The safety-related cable was installed in electrical conduit 1K111 located underneath the turbine building (TB) base mat between the TBs A SBDG day tank room and the northeast corner room (NECR) located in the reactor building. Due to the inability to replace only one cable within conduit 1K111, all cables were removed and replaced with new cables. Upon opening the TB end of conduit 1K111, entrapped water was discovered and released (approximately 80 gallons). Examination of the removed cables showed physical signs of water damage (i.e., cables were waterlogged and jacketing material degraded). In addition, further investigation by the licensee revealed that several other safety-related electrical cables that were located within conduits embedded within the TB base mat were either completely submerged or had been subjected to some amount of standing water.

On April 18, 2013, the licensee completed Root Cause Evaluation (RCE) 01824467-02 Wetted Cables within Embedded Circuits, Revision 3, to evaluate the cause(s) of water intrusion into inaccessible buried electrical conduits. In response to the above mentioned findings and the RCE, the licensee created an action to revise the ECPM to include a new attachment to ECPM 4.5 that previously existed in the form of a white paper developed to generically support engineering evaluations of cables that had undergone degradation as a result of being exposed to water. The inspectors determined that during the development of the paper, the licensee drew the conclusion that the issuance of NUREG 1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, which includes an Aging Management Program (AMP) for the monitoring of inaccessible cables, constituted the use of the AMP alone as means to maintain the design and licensing basis of cables that were discovered to be exposed to and/or submerged in water. The white paper makes reference to excerpts from numerous NRC generic communications and the licensees AMP for inaccessible cable monitoring to draw the conclusion that cables may be, in effect, qualified for submergence by their inclusion in the licensees AMP. The inspectors determined that this implied conclusion constituted an adverse change to the licensees procedures that served to provide a decision basis for making immediate operability decisions. The change could ultimately lead the licensee to conclude that cables that were not designed to reside in a wetted and/or submerged environment are fully operable without further engineering evaluation.

On September 10, 2013, in response to the inspectors concerns during the inspection, the licensee entered the issue into their Corrective Action Program as AR 01902782, ECPM - Electrical Cable Operability, dated September 10, 2013, which suspended the use of ECPM 4.5 by quarantining the procedure until the identified discrepancies could be resolved.

Analysis:

The inspectors determined that the licensees failure to establish measures for the selection and review for the suitability of safety-related cables with Procedure ECPM 4.5, Electrical Cable Operability, Revision 2, was contrary to 10 CFR Part 50, Appendix B, Criterion III, Design Control and was a performance deficiency.

Specifically, ECPM 4.5, Attachment 1, Qualification of Cables in Wetted Environments, allowed for safety-related cabling that was not qualified or specifically designed for total submergence in water to be used in water filled conduits contrary to its unsuitability for this application, without suitable testing or design control measures. The change contained language that allowed the facility to either accept a degraded condition as-is or to qualify cables by crediting the use of the licensees AMP for continual underwater duty, thus preventing a full engineering evaluation to assess the extent of the degradation from exposure to such an environment.

The inspectors determined that the performance deficiency was more than minor because the finding, if left uncorrected, would become a more significant safety concern.

Specifically, not identifying and appropriately evaluating degraded or non-conforming conditions to properly assess the operability of cables subjected to protracted and/or extensive exposure to water could prevent not declaring a structure, system and component (SSC) inoperable or the use of compensatory actions to maintain or enhance a degraded or non-conforming condition.

In accordance with IMC 0609, Significance Determination Process, 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined that the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of a mitigating SSC; however, the SSC maintained its operability or functionality as applicable. Therefore, the inspectors answered "yes" to the Mitigating Systems Screening Question A.1 in Exhibit 2 and screened the finding as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of human performance, decision-making because the licensee did not use conservative assumptions in implementing Procedure ECPM 4.5, Electrical Cable Operability, Revision 2. Specifically, the licensee failed to perform an effective review of the consequences of their decision to include an attachment to this procedure that provided a method not previously approved for qualifying safety-related cables for submergence. (H.1(b))

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established for the selection and review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of the structures, systems and components (SSCs). These design control measures shall provide for the verifying or checking the adequacy of design, such as by the performance of a suitable testing program and where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying of checking processes, it shall include suitable qualifications testing of a prototype unit under the most adverse design conditions. Design control measures shall be applied to items such as the compatibility of materials and the delineation of acceptance criteria for inspections and tests.

Contrary to the above, from June 24 to September 10, 2013, the licensee failed to establish measures for the selection and review for the suitability of safety-related cables with Procedure ECPM 4.5, Electrical Cable Operability, Revision 2. Specifically, ECPM 4.5, Attachment 1, Qualification of Cables in Wetted Environments, allowed for safety-related cabling that was not qualified or specifically designed for total submergence in water to be used in water filled conduits contrary to its unsuitability for this application, without suitable testing or design control measures.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance and was entered into the licensees Corrective Action Program as AR 01902782, ECPM - Electrical Cable Operability, dated September 10, 2013. The licensees immediate corrective actions included suspending the use of ECPM 4.5, by quarantining the procedure until the identified discrepancies could be resolved. (NCV 05000331/2013008-01, Failed to Establish Measures for the Selection and Review for the Suitability of Safety-Related Cables).

.2 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed 13 permanent plant modifications that had been installed in the plant during the last three years. This review included in-plant walkdowns for portions of the Emergency Diesel Generator B and the Hydrogen Supply System. 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 13 permanent plant modification samples as defined in IP 71111.17-04.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed 22 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 plant modifications and evaluations of changes, tests, and experiments. 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 list of specific corrective action documents that were sampled and reviewed by the inspectors are listed in the to this report.

b. Findings

Failed to Ensure the SBDG Power Cables Were Not Submerged

Introduction:

The inspectors identified a finding of very low safety significance (Green)and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality following discovery of water and mud in safety-related electrical conduit 1K109 associated with the A SBDG. Specifically, the licensee identified an obstruction characterized as mud located 8-feet from the TB end of conduit 1K109. As a result, the licensee failed to take corrective action to remove the water and mud from the conduit and to evaluate the mud obstruction.

Description:

Following the discovery of water in the TB end of conduit 1K111 (Reference Section 1R17.1b), the licensee performed an Apparent Cause Evaluation (ACE) 01812795-00, Water Damaged SR [Safety-Related] Cables in the TB Floor at Elevation 734, dated October 16, 2012. The ACE included an investigation into how the cables became wetted and submerged and an extent of condition evaluation. The licensees extent of condition evaluation determined that five conduits sequentially numbered 1K108 through 1K112 imbedded in the TBs concrete base mat contained water in sufficient quantity to submerge cables within the conduits. All five conduits were associated with the A SBDG. The licensee also determined that five conduits (i.e., 2K231 through 2K235) associated with the B SBDG were also affected in the same manner.

On October 16, 2012, conduit 1K109 was opened from the NECR end located in the reactor building and approximately 1 to 2 gallons of water was removed.

On March 7, 2013, the TB end of conduit 1K109 was opened and 27 gallons of water was removed from the first 8-feet of the conduit. As a result, AR 01854812, Found Water in 1K109, dated March 7, 2013, was issued which stated that Further inspection and pumping was not possible due to the conduit being obstructed beyond 8-feet by mud. The licensee did not elaborate on the obstruction that was characterized as mud nor was a detailed engineering evaluation performed as a result of the discovery. The cables contained in conduit 1K109 were the 3-phase output power cables for the A SBDG.

Although, not all water and mud was removed from electrical conduit 1K109, the licensee closed AR 01854812. The AR closure was based on the associated POD. The inspectors found that the licensee considered the cables contained in conduit 1K109 to be initially operable but non-conforming. The POD reflected the most recent discovery of water (i.e., March 7, 2013) and the satisfactory (i.e., greater than minimum acceptable) insulation resistance measurements that were taken over one year earlier (i.e., January 2012). The inspectors subsequent review of the associated POD identified that the licensee concluded that all cables associated with both SBDGs were considered fully operable based on their inclusion into the AMP. The licensee credited the use and actions of the AMP to justify operability for both the A and B SBDGs.

However, this does not meet the expectations and the requirements of the NRC as identified in Information Notice 2010-26, NUREG-1801, Generic Aging Lessons Learned (GALL) Report and Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants.

Information Notice 2010-26, Submerged Electrical Cables, dated December 2, 2010, stated the following:

• The NRC expects licensees to identify conditions that are adverse to quality for cables, such as long-term submergence in water. Upon discovery of a submerged condition, the licensee should take prompt corrective actions to restore the environment to within the cables design specifications, immediately determine the operability of the cable(s) to perform its intended design function, and determine the impact of the adverse environment on the design life of the cable.

• Cables not designed or qualified for, but exposed to, wet or submerged environments have the potential to degrade. Cable degradation increases the probability that more than one cable will fail on demand because of a cable fault, lightning surge, or a switching transient. Although a single failure is within the plant design basis, multiple failures of this kind would be challenging for plant operators. Also, an increased potential exists for a common-mode failure of accident mitigating system cables if they are subjected to the same environment and degradation mechanism for which they are not designed or qualified for.

NUREG 1801, Generic Aging Lessons Learned (GALL) Report, Revision 2, Appendix A, Quality Assurance for Aging Management Programs, stated the following:

• The license renewal applicant must demonstrate that the effects of aging on structures and components (SC) subject to an aging management review (AMR)will be managed in a manner that is consistent with the current licensing basis (CLB) of the facility for the period of extended operation. Therefore, those aspects of the AMR process that affect the quality of safety-related SCs are subject to the quality assurance (QA) requirements of Appendix B to 10 CFR Part 50.

The inspectors verified that the licensee did not have any safety-related cables installed at DAEC that were qualified for submergence. As a result, the inspectors determined that as of March 7, 2013, the licensee failed to take appropriate corrective action to remove all water and mud from electrical conduit 1K109 to restore the environment for conduit 1K109 to within the cables design specifications and to determine the resultant impact on the cables design life following exposure to the water and mud submergence.

Therefore, the inspectors concluded that the licensee failed to correct a condition adverse to quality following discovery of water and mud in safety-related electrical conduit 1K109 associated with the A SBDG. The licensee entered this finding into their Corrective Action Program as AR 01909315, NRC 5059/MOD Inspection Violation of App B Criterion 16, dated October 3, 2013. The licensee has performed insulation resistance checks on the EDG power cable and obtained satisfactory results.

Additionally, the licensee performed an evaluation of the mud-like material in the conduit and determined that it is likely cable pulling compound, as opposed to degraded cable jacket material. The licensee also set a date for further inspection of the conduit to April 2014, which coincides with the next EDG outage period. These corrective action items are being tracked in CR 1909315. Additionally the licensee is evaluating the frequency interval for inspecting this and other similar conduits.

Analysis:

The inspectors determined that the licensees failure to correct a condition adverse to quality following discovery of water and mud in safety-related electrical conduit 1K109 associated with the A SBDG was contrary to 10 CFR Part 50, Appendix B, Criterion XVI and was a performance deficiency. Specifically, the licensee identified an obstruction characterized as mud located 8-feet from the TB end of conduit 1K109. As a result, the licensee failed to take corrective action to remove the water and mud from the conduit and to evaluate the mud obstruction.

The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstones attribute of design control for ensuring the availability, reliability, and capability of systems that respond to Initiating Events to prevent undesirable consequences. Specifically, material characterized by the licensee as mud facilitated continual exposure to a wetted and water submergence environment of the safety-related A SBDG power cables. Continual exposure to a wetted and water submergence environment will lead to cable failure. Cable failure would prevent the system from carrying out its intended safety-related function of automatically starting and connecting to its corresponding essential service bus to supply power to emergency loads in an event (i.e., a loss-of-coolant-accident (LOCA)and/or degraded/under-voltage condition).

In accordance with IMC 0609, Significance Determination Process, 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The performance deficiency affected the design or qualification of a mitigating SSC; however, the SSC maintained its operability or functionality as applicable. Therefore, the inspectors answered "yes" to the Mitigating Systems Screening Question A.1 in Exhibit 2 and screened the finding as having very low safety significance (Green).

This finding has a cross-cutting aspect in the area of human performance, decision-making because the licensee did not use conservative assumptions to correct a condition adverse to quality following discovery of water and mud in safety-related electrical conduit 1K109 associated with the A SBDG. Specifically, the licensee failed to perform an effective review of the safety-related consequences of their decision not to complete the inspection of conduit 1K109 to ensure that no water and mud remained inside the conduit subjecting the cables to a submergence environment. (H.1(b))

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.

Contrary to the above, as of October 31, 2013, the licensee failed to correct a condition adverse to quality regarding discovery of water and mud in safety-related electrical conduit 1K109 associated with the A SBDG. Specifically, the licensee identified an obstruction characterized as mud located 8-feet from the TB end of conduit 1K109. As a result, the licensee failed to take corrective action to remove the water and mud from the conduit and to evaluate the mud obstruction.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance and was entered into the licensees Corrective Action Program as AR 01909315, NRC 5059/MOD Inspection Violation of App B Criterion 16, dated October 3, 2013. The licensee has performed insulation resistance checks on the EDG power cable and obtained satisfactory results.

Additionally, the licensee performed an evaluation of the mud-like material in the conduit and determined that it is likely cable pulling compound, as opposed to degraded cable jacket material. The licensee also set a date for further inspection of the conduit to April 2014, which coincides with the next EDG outage period. These corrective action items are being tracked in CR 1909315. Additionally the licensee is evaluating the frequency interval for inspecting this and other similar conduits. (NCV 05000331/2013008-02, Failed to Ensure the SBDG Power Cables Were Not Submerged).

4OA6 Meetings

.1 Exit Meeting Summary

On October 31, 2013, the inspectors presented the inspection results to Mr. Steve Huebsch and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content.

.2 Interim Exit Meeting Summary

On September 20, 2013, the inspectors presented the preliminary inspection results to Mr. Richard L. Anderson 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

R. Anderson, Site Vice-President

T. Anderson, Maintenance Manager (Acting)

R. Bierman, Design Engineering

D. Davidson, Procedures Supervisor

M. Davis, Licensing/Emergency Preparedness (EP) Manager

J. Dubois, Program Engineering Manager

M. Fairchild, Program Engineer Motors and Cables

S. Haller, Design and Project Engineering Manager

G. Holt, Configuration Management Supervisor

S. Huebsch, Engineering Supervisor (Mechanical) Design

K. Kleinheinz, Engineering Director

B. Lawrence, Balance-of-Plant (BOP) Systems Engineering Supervisor

B. Murrell, Licensing (Inspection Lead)

M. Ogden, Systems Engineering

K. Peveler, Nuclear Oversight (NOS) Manager (Acting)

G. Pry, Plant General Manager

J. Quimby, Programs Supervisor

J. Santiago, Design Engineering Supervisor

K. Smith, Engineering Administration Support

E. Sorenson, Programs Engineering Supervisor

L. Swenzinski, Licensing (50.59 Program Owner)

R. Wheaton, Operations Director

Nuclear Regulatory Commission

L. Haeg, Senior Resident Inspector

R. Murray, Resident Inspector

Attachment

LIST OF ITEMS

Opened

05000331/2013008-01 NCV Failed to Establish Measures for the Selection and Review for the Suitability of Safety-Related Cables. (Section 1R17.1b)

05000331/2013008-02 NCV Failed to Ensure the SBDG Power Cables Were Not Submerged. (Section 4OA2.1b)

Closed

05000331/2013008-01 NCV Failed to Establish Measures for the Selection and Review for the Suitability of Safety-Related Cables. (Section 1R17.1b)

05000331/2013008-02 NCV Failed to Ensure the SBDG Power Cables Were Not Submerged. (Section 4OA2.1b)

Discussed

None.

Attachment