ML14266A423
| ML14266A423 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/19/2014 |
| From: | O'Brien K Division of Reactor Safety III |
| To: | Vehec T NextEra Energy Duane Arnold |
| David J. Oliver | |
| References | |
| IR-2014-010 | |
| Download: ML14266A423 (17) | |
See also: IR 05000331/2014010
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, IL 60532-4352
September 19, 2014
Mr. Thomas Vehec
Vice President
NextEra Energy Duane Arnold, LLC
3277 DAEC Road
Palo, IA 52324-9785
SUBJECT: DUANE ARNOLD ENERGY CENTER - NRC FOLLOW-UP INSPECTION
REPORT 05000331/2014010 AND NOTICE OF VIOLATION.
Dear Mr. Vehec:
On September 3, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a follow-up
inspection conducted during the week of April 21, 2014, at your Duane Arnold Energy Center
(DAEC). The purpose of the inspection was to evaluate corrective actions for recent Non-Cited
Violations (NCVs) associated with the discovery of submerged safety-related cables in
embedded conduits. The enclosed report presents the results of this inspection, which were
discussed on September 3, 2014, with Mr. G. Pry, and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions in your license.
Within these areas, the inspection consisted of a selected examination of procedures and
representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has identified an issue that was evaluated
under the risk significance determination process as having very low safety significance
(Green). The NRC has also determined that a violation is associated with this issue. This
violation was evaluated in accordance with the NRC Enforcement Policy. The current
Enforcement Policy is included on the NRCs web site at
(http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding it are described in detail in the subject inspection report. The violation is being
cited in the Notice because DAEC had failed to restore compliance, or demonstrate objective
evidence of plans to restore compliance in a reasonable period following documentation of four
associated NCVs issued from January 30, 2013, to December 5, 2013.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRCs
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure your compliance with regulatory requirements.
T. Vehec -2-
In addition, if you disagree with the cross-cutting aspect assigned to the 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), Section 2.390, Public
Inspections, Exemptions, Requests for Withholding, 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 NRCs Public Document Room or from the NRC's Agencywide Documents
Access and Management System (ADAMS). ADAMS is accessible from the NRC web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal privacy or proprietary information so that it can be made available to the
Public without redaction.
Sincerely,
/RA/
Kenneth G. OBrien, Director
Division of Reactor Safety
Docket No. 50-331
License No. NPF-49
Enclosure:
Inspection Report 05000331/2014010;
w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
NOTICE OF VIOLATION
NextEra Energy Duane Arnold Docket No. 50-331
Duane Arnold Energy Center License No. NPF-49
During an NRC inspection conducted from April 21 2014, to April 25, 2014, with continued in-
office review through September 3, 2014, a violation of NRC requirements was identified. In
accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI,
Corrective Action, states, 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, from October 16, 2012, to July 10, 2014, the licensee did not
assure that conditions adverse to quality were corrected. Specifically, the licensee failed
to remove water from nine conduits containing safety-related cables and the cables were
not qualified for continuous exposure to water. Safety-related components served by
these cables were essential safety busses, residual heat removal pumps, both
emergency diesel generator control and output power, and high pressure coolant
injection.
This violation is associated with a (Green) Significant Determination Process (SDP) finding.
Pursuant to the provisions of 10 CFR 2.201, NextEra Energy Duane Arnold is hereby required
to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional
Administrator, Region III, and a copy to the NRC Resident Inspector at the Duane Arnold
Energy Center, within 30 days of the date of the letter transmitting this Notice of Violation
(Notice). This reply should be clearly marked as a Reply to a Notice of Violation;
VIO 05000331/2014010-01 and should include for each violation: (1) the reason for the
violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective
steps that have been taken and the results achieved, (3) the corrective steps that will be taken,
and (4) the date when full compliance will be achieved. Your response may reference or
include previous docketed correspondence, if the correspondence adequately addresses the
required response. If an adequate reply is not received within the time specified in this Notice,
an order or a Demand for Information may be issued as to why the license should not be
modified, suspended, or revoked, or why such other action as may be proper should not be
taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs Agencywide Documents Access and Management
System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or
safeguards information so that it can be made available to the public without redaction. If
NOTICE OF VIOLATION -2-
personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request withholding of such material, you must specifically identify the portions of your response
that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
explain why the disclosure of information will create an unwarranted invasion of personal
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 23 day of September, 2014
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-331
License No: NPF-49
Report No: 05000331/2014010
Licensee: NextEra Energy Duane Arnold, LLC
Facility: Duane Arnold Energy Center
Location: Palo, IA
Dates: April 21 through September 3, 2014
Inspectors: D. Oliver, Senior Resident Inspector (Point Beach)
S. Shah, Reactor Engineer
Approved by: Kenneth G. O'Brien, Director
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000331/2014010, 04/21/2014 - 09/03/2014; Duane Arnold Energy Center (DAEC);
Problem Identification and Resolution
This report covers a 1-week period of announced onsite baseline inspection by Region III based
engineering inspectors. With continued in-office review through September 3, 2014, one finding
was identified by the inspectors. The finding was considered a cited violation 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 disposition in accordance with the NRCs Enforcement
Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5,
dated February 2014.
A. NRC-Identified and Self-Revealed Findings
Cornerstone: Mitigating Systems
Green: The inspectors identified a finding of very low safety significance and an
associated cited violation of Title 10, Code of Federal Regulations (CFR), Part 50,
Appendix B, Criterion XVI, Corrective Action, where the licensee failed to correct a
condition adverse to quality following the discovery of water in several safety-related
electrical conduits. Specifically, the licensee identified water in 23 embedded conduits
containing cables for safety-related equipment. However, the licensee failed to take
corrective action to remove water from nine of the conduits. This violation is being cited
because the licensee had failed to restore compliance, or demonstrate objective
evidence of plans to restore compliance in a reasonable period following documentation
of four associated Non-Cited Violations (NCVs) issued from January 30, 2013 to
December 5, 2013.
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, by not removing water from
the conduits, cables were continuously exposed to water which is an adverse
environment for which they were not qualified, designed or evaluated for, and will lead to
cable degradation and could potentially cause cable failure. Cable failure would prevent
the systems from carrying out their intended safety-related functions. The finding had a
cross-cutting aspect in the area of Human Performance because the licensee did not
operate and maintain equipment within design margins. Margins were not carefully
guarded or changed only through a systematic and rigorous process. Special attention
was not placed on maintaining defense-in-depth, and safety-related equipment.
Specifically, the corrective actions developed by the licensee were insufficient to restore
safety-related cables to their design environment to ensure that cables did not remain
submerged. [H.6] (Section 4OA2)
B. Licensee-Identified Violations
None
2
REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems (71152)
Cornerstones: Mitigating Systems
.1 Selected Issue Follow-Up Inspection: Corrective Actions Following Discovery That
Standby Diesel Generator (SBDG) Cables Were Submerged
a. Inspection Scope
The inspectors reviewed 18 corrective action process documents that were related to the
follow-up actions to recent non-cited violations associated with the discovery of
submerged safety-related cables in embedded conduits. The inspectors reviewed these
documents to evaluate the effectiveness and timeliness of corrective actions taken and
proposed related to the quality assurance and design control of safety-related cabling.
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 is provided in the
Attachment to this report.
This review constituted one in-depth problem identification and resolution sample as
defined in Inspection Procedure 71152-05.
b. Findings
(1) Failure to Remove Water From Conduits Containing Safety-Related Cables
Introduction: The inspectors identified a finding of very low safety significance
(Green) and an associated cited violation of 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, for the licensees failure to correct a condition adverse to quality
following the discovery of water in several safety-related electrical conduits. Specifically,
the licensee identified water in 23 embedded conduits containing cables for
safety-related equipment. However, the licensee failed to take corrective action to
remove water from nine of the conduits. This violation is being cited because the
licensee had failed to restore compliance, or demonstrate objective evidence of plans to
restore compliance in a reasonable period following documentation of four associated
non-cited violations issued from January 30, 2013 to December 5, 2013.
Description: Thirty-four conduits containing cables for safety-related equipment and
equipment important to safety were included in the licensees Aging Management
Program for Inaccessible and Embedded Cables (AMP). The scope of this AMP had
been recently expanded to include conduits that contained low voltage cables as a
result of the discovery of water in October 2012 in conduit 1K111, which contained
cables that support the A SBDG. These cables were replaced because of a failed
cable in that conduit. As described in NRC Inspection Report 05000331/2013008, the
licensee performed Apparent Cause Evaluation (ACE) 01812795-00, Water Damaged
SR [Safety-Related] Cables in the TB [Turbine Building] Floor at Elevation 734, dated
October 16, 2012. The ACE included an extent of condition evaluation to determine how
3
many conduits contained similar conditions of wetted and submerged cables. The
licensees extent of condition evaluation determined that all conduits associated with both
SBDGs that were embedded in the Turbine Buildings concrete base mat contained water
in sufficient quantity to submerge the cables contained within the conduits. This discovery
prompted the licensee to include all conduits that were embedded in the turbine and
reactor building concrete base mats into the AMP.
As a result of the licensees inspections of embedded conduits with the expanded scope of
the AMP, the licensee discovered water in a total 23 of the 25 conduits inspected, with 9
conduits remaining to be inspected. Of the 23 conduits containing water, 11 conduits were
subsequently closed following their inspection with water remaining in the conduits.
Boroscope video taken by the licensee during inspections revealed that some conduits
had retained enough water to completely submerge the cables contained within. Among
the 11 conduits containing water, 9 contained safety-related cabling for:
- 4kV feeds to essential busses from both Standby Transformers;
- 4kV power cables for A, B and C Residual Heat Removal pumps;
- A SBDG low voltage control and 480 VAC cables;
- B SBDG 4kV power cables; and
- High Pressure Coolant Injection low voltage control cables
In addition to the cables listed above, the licensee had determined that water had been
removed from 12 of the conduits. However, during the week of April 21, 2014, the
inspectors noted that while the licensee was performing inspections from the turbine
building end of conduits that terminated in the reactor building, visible signs of water
seepage was present at the conduit seals in the reactor building, indicating that water
could be present in conduits that were determined by the licensee to be dry, or
dewatered because they had only been inspected from one end.
Since October 2012 when the licensee initially discovered water in the conduits
associated with the A SBDG, the licensee has not restored the cables to compliance
by removing the water and drying the cables out; nor has the licensee provided any
objective plans to do so in the future. Rather the licensee has made several attempts
to qualify cables that were not initially designed, procured, tested, or installed for
submerged environmental conditions.
The issue of submerged cabling in the industry has been the subject of numerous NRC
regulatory guidance documents, public meetings and NRC findings and violations
stemming from a range of issues from failure to meet design control to actual events
that resulted from these conditions.
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,
4
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.
There are numerous NRC publications, such as Information Notice 2010-26,
Submerged Electrical Cables mentioned above, written on this issue and referenced by
the licensee, which acknowledge the potential for safety-related cables to become
submerged. These standards reflect expectations for licensees to detect this condition
and to take prompt and effective corrective action in accordance with the licensees
Corrective Action Program to prevent further degradation from being exposed to wetting
or submergence lasting more than a few days. In the case of DAEC, the licensee had
concluded that cables in wetted or submerged environments constitutes a
nonconforming condition, but did not evaluate the continued degradation that occurs as
the cables remain exposed to the adverse environment.
The inspectors concluded that by not removing the safety-related cables from the
adverse environment, restoring the design conditions and evaluating degradation, the
licensee had allowed a condition adverse to quality to persist. Additionally, the
inspectors determined, by a review of the intended future actions and interviews with the
licensees staff, that the licensee had no objective plans to remove the water from the
conduits or dry the cables out to prevent further degradation.
Analysis: The inspectors determined that failure to correct a condition adverse to quality
following the discovery of water in conduits containing safety-related cables was contrary
to 10 CFR Part 50, Appendix B, Criterion XVI and was within the licensees ability to
foresee and correct. Therefore, this was a performance deficiency. Specifically, the
licensee identified water in nine conduits containing safety-related cables which were not
qualified for continuous exposure to water and failed to take corrective action to remove
the water from the 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, by not removing water from the conduits, cables were
continuously exposed to water, which is an adverse environment for which they were not
qualified, designed or evaluated for, and will lead to cable degradation and could
potentially cause cable failure. Cable failure would prevent the systems from carrying
out their intended safety-related functions.
In accordance with IMC 0609, Significance Determination Process, Attachment
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 that the finding could be evaluated using Appendix A, The Significance
Determination Process (SDP) for Findings At-Power, Exhibit 2 for the Mitigating
Systems cornerstone and determined that the finding is a deficiency affecting the design
or qualification of a mitigating structures, systems and components (SSC), and that the
5
SSCs currently maintain their operability or functionality as applicable; and therefore, the
issue is screened as having very low safety significance (Green).
The finding had a cross-cutting aspect in the area of Human Performance because the
licensee did not operate and maintain equipment within design margins. Margins were
not carefully guarded or changed only through a systematic and rigorous process.
Special attention was not placed on maintaining defense-in-depth, and safety-related
equipment. Specifically, the corrective actions developed by the licensee were
insufficient to restore safety-related cables to their design environment to ensure that
cables did not remain submerged. [H.6]
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
states, 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, from October 16, 2012, to at least July 10, 2014, the licensee did not assure
that conditions adverse to quality were corrected. Specifically, the licensee failed to
remove water from nine conduits containing safety-related cables and the cables were
not qualified for continuous exposure to water.
This violation is being cited as described in the Notice of Violation, which is enclosed
with this inspection report. This is consistent with the NRC Enforcement Policy,
Section 2.3.2.a.2, which states, in part, that the licensee must restore compliance within
a reasonable period of time (i.e., in a timeframe commensurate with the significance of
the violation) after a violation is identified. The performance deficiency was previously
identified by the NRC on December 5, 2013, and documented as a Non-Cited Violation
(NCV) along with another NCV for creating a procedure that allowed cables to remain
submerged indefinitely. Associated NCVs relating to this performance deficiency were
also issued from January 30, 2013, to December 5, 2013. (Inspection Reports
05000331/2012005, 05000331/2013002, and 05000331/2013008). The inspectors
determined that the licensee had failed to restore compliance within a reasonable time
following issuance of these NCVs, and failed to have objective plans to restore
compliance in the future. (VIO 05000331/2014010-01, Failure to Remove Water
From Conduits Containing Safety-Related Cables)
4OA6 Management Meetings
.1 Exit Meeting Summary
On September 3, 2014, the inspectors presented the inspection results to Mr. G. Pry 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.
ATTACHMENT: SUPPLEMENTAL INFORMATION
6
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
G. Pry, Plant General Manager
M. Davis, Licensing/Emergency Preparedness (EP) Manager
M. Fairchild, Program Engineer Motors and Cables
K. Kleinheinz, Engineering Director
L. Swenzinski, Senior Licensing Engineer
D. Church, Manager Program Engineering
L. Nicholson, Nextera Fleet Licensing
NRC
R. Daley, Chief, Engineering Branch 3
C. Lipa, Chief, Reactor Project Branch 1
D. Oliver, Senior Resident Inspector, Point Beach Nuclear Plant
L. Haeg, Senior Resident Inspector, DAEC
J. Steffes, Resident Inspector, DAEC
C. Phillips, Project Engineer, Reactor Project Branch 1
R. Ng, Project Engineer, Reactor Project Branch 1
J. Gilliam, Reactor Engineer, Engineering Branch 3
M. Jeffers, Reactor Engineer, Engineering Branch 3
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
05000331/2014010-01 VIO Failure to Remove Water From Conduits Containing Safety-
Related Cables (Section 4OA2)
Closed
None
Discussed
None
1 Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION
Number Description or Title Date or Revision
1812795 Apparent Cause Evaluation for Failed 3
Cables in 1K111
1960738 NECR Conduit Seals Appear to be Damp April 23, 2014
1961073 Evaluate Potential Cable Effect from Damp April 24, 2014
Conduit Seals
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title Date or Revision
1960358 Megger Readings for 1P044A-M and Cable April 22, 2014
are Inconsistent
1960587 Conduit 1K109 Inspection Results April 22, 2014
1960223 Debris Found in Conduit 1K112 During April 22, 2014
Inspection
1960222 A SBDG 1K110, 1K111, & 1K112 Conduit April 21, 2014
Inspection Results:
1916178 Untimely Corrective Actions in the Work October 29, 2013
Management Process
1917237 Cable 1A0311-D is in a Wetted November 1, 2013
Environment
1915185 Review Corrective Actions on Conduits September 19, 2013
1939810 Water Found in 2A204 B RHR Feeder February 10, 2014
Conduit
1968613 Replacement of SBDG Cables May 29, 2014
1965405 A Cable in Conduit 1K112 Appears to Have May 13, 2014
a Split Jacket
1950040 Evaluate Installing Level Alarms in March 20, 2014
Manholes
1950235 WO40301105 (MH107) Sump Was on a March 20, 2014
Block Not Fully Pumping
1950277 Cables for Standby XFMR Breakers Not March 20, 2014
Included in POD 1913616
1967520 Evaluate Opening the NECR SBDG May 22, 2014
Conduits for Inspection
1 Attachment
1967523 Evaluate Opening the Reactor Building May 22, 2014
Embedded Conduits
DRAWINGS
Number Description or Title Date or Revision
BECH-E301 Turbine Generator Building Embedded 5
Conduit Below EL-7340
BECH-E302 Reactor Building Embedded Conduit 5
Below EL.716-9
PROCEDURES
Number Description or Title Date or Revision
ACP 1210.7 Electrical and I&C Aging Management 5
Programs
ACP 1210.8 Electrical Cables and Connections 1
Inspection Procedure
REFERENCES
Number Description or Title Date or Revision
N/A Duane Arnold Inaccessible Cable Program April 21, 2014
- Actions Being Taken to Address
OBD/OBN Conditions
ECPM SECT 1.0 Electrical Cable Program Description 3
ECPM SECT 2.0 Electrical Cable Scoping and Population 3
ECPM SECT 3.0 Cable Program Inspection/Test Population 2
Selection
ECPM SECT 3.1 Cable Program Inspection/Test List 1
ECPM SECT 4.1 Cable Aging Management Review 1
ECPM SECT 4.2 Cable Aging due to Ohmic Heating 0
ECPM SECT 4.3 Adverse Localized Equipment 1
Environments
ECPM SECT 4.4 Electrical Manhole Inspection Frequency 1
ECPM SECT 4.5 Electrical Cable Operability 4
ECPM SECT 4.6 Test and Inspection Data Review and 1
Trending
ECPM SECT 4.7 Test and Inspection Methodology 0
ECPM SECT 4.8 Action for Failed or Degraded Cables 2
ECPM SECT 4.9 Susceptibility of Water Collection in 0
Control Building Embedded Conduits
ER-AA-106 Cable Condition Monitoring Program 3
N/A Inaccessible 4160 V and 480 V Power March 31, 2014
Cable Test Results
N/A Embedded Conduit Inspection Results March 31, 2014
2
VENDOR DOCUMENTS
Number Description or Title Date or Revision
12-021 Condition Assessment of 5KV and 600 V February 29, 2012
Cables Removed from the Duane Arnold
Nuclear Plant
12-111 Evaluation of 600 V Cables with Damaged August 2, 2012
Insulation Removed from the Duane
Arnold Nuclear Power Plant
WORK ORDERS
Number Description or Title Date or Revision
40235151 SUS24.01 Inspect TURB BLDG Side of April 22, 2014
Conduits for Water
3
LIST OF ACRONYMS USED
ACE Apparent Cause Evaluation
ADAMS Agencywide Documents Access And Management System
AMP Aging Management Program for Inaccessible and Embedded Cables
CFR Code of Federal Regulations
DAEC Duane Arnold Nuclear Center
IMC Inspection Manual Chapter
NRC Nuclear Regulatory Commission
PARS Public Available Records System
SBDG Standby Diesel Generator
SDP Significance Determination Process
SSC Structure, System, and Component
4
T. Vehec -2-
In addition, if you disagree with the cross-cutting aspect assigned to the 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), Section 2.390, Public
Inspections, Exemptions, Requests for Withholding, 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 NRCs Public Document Room or from the NRC's Agencywide Documents
Access and Management System (ADAMS). ADAMS is accessible from the NRC web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal privacy or proprietary information so that it can be made available to the
Public without redaction.
Sincerely,
/RA/
Kenneth G. OBrien, Director
Division of Reactor Safety
Docket No. 50-331
License No. NPF-49
Enclosure:
Inspection Report 05000331/2014010;
w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
DOCUMENT NAME: G:\DRSIII\DRS\Work in Progress\-DAEC 2014 010 Notive of Violation DJO.docx
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 Via email RIII
NAME DJOliver:ls SOrth CLipa RCDaley KGOBrien
DATE 09/15/14 09/18/14 09/19/14 09/22/14 09/23/14
OFFICIAL RECORD COPY
Letter to Thomas Vehec from Kenneth G. O'Brien dated September 23, 2014.
SUBJECT: DUANE ARNOLD ENERGY CENTER - NRC FOLLOW-UP INSPECTION
REPORT 05000331/2014010 AND NOTICE OF VIOLATION
DISTRIBUTION:
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RidsNrrDirsIrib Resource
Cynthia Pederson
DRPIII
DRSIII
Patricia Buckley
ROPreports.Resource@nrc.gov0