IR 05000331/2017007

Energy Center - NRC Problem Identification and Resolution Inspection Report 05000331/2017007

ML17123A087
Person / Time
Site:	Duane Arnold
Issue date:	05/03/2017
From:	Stoedert K NRC/RGN-III/DRP/B1
To:	Dean Curtland NextEra Energy Duane Arnold
References
IR 2017007
Download: ML17123A087 (28)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 May 3, 2017 Mr. Dean Curtland

Director of Site Operations NextEra Energy Duane Arnold, LLC 3277 DAEC Road Palo, IA 52324-9785

SUBJECT: DUANE ARNOLD ENERGY CENTER-NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000331/2017007

Dear Mr. Curtland:

On April 25, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at your Duane Arnold Energy Center (DAEC).

The enclosed inspection report documents the inspection results, which were discussed at an interim exit meeting on March 24, 2017, and an exit teleconference on April 25, 2017, with you and other members of your staff. The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

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

On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at DAEC was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP.

Through consideration of risk and consequence, the significance of the issues and priority for issue evaluation and resolution were determined. Corrective actions were generally implemented in a timely manner, commensurate wi th their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to procedure. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant based on the samples we reviewed. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth and details for all departments. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work envir onment at DAEC. Licensee staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that your station's performance in each of these areas supported nuclear safety. 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. Because the licensee initiated condition reports (CRs) to address the issue, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2a of the Enforcement Policy. The NCV is described in the subject inspection report.

If you contest the violation or significance 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 copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at the DAEC.

If you disagree with the cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III, and the NRC Resident Inspector at the DAEC.

This letter, its enclosure, and your response, (if any), will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,/RA/

Karla Stoedter, Chief Branch 1 Division of Reactor Projects Docket No. 50-331 License No. DPR-49

Enclosure:

Inspection Report 05000331/2017007 cc: Distribution via LISTSERV

SUMMARY OF FINDINGS

Inspection Report 05000331/2017007; 03/06/2017 - 04/25/2017; Duane Arnold Energy Center; Identification and Resolution of Problems.

This report covers an 8-week period of inspection by four regional inspectors. A Green finding was identified by the inspectors. The findings involved a non-cited violation (NCV) of the

U.S. Nuclear Regulatory Commission (NRC) requirements. 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," dated April 29, 2015. Cross-Cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated February 2016.

Identification and Resolution of Problems On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Duane Arnold Energy Center (DAEC) was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP. Through consideration of risk and consequence, the significance of the issues and priority for issue evaluation and resolution were determined. Corrective actions were generally implemented in a timely manner commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to procedure. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant based on the samples we reviewed. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth and details for all departments. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at DAEC. Licensee staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that the licensee's performance in each of these areas supported nuclear safety.

Although implementation of the CAP was determined to be effective overall, the inspectors identified several issues that represented potential weakness of the program.

Cornerstone: Barrier Integrity

Green.

The inspectors identified a finding and an associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(f)(1) for the licensee's failure to scope in multiple check valves of the main steam isolation valve leakage treatment system (LTS) into the Inservice Testing (IST) Program. Specifically, these valves were credited to mitigate the consequences of the main steam isolation valve leakage following a loss of coolant accident but they were not scoped into the IST program. Since the licensee made a commitmen t to the NRC to put these valves into the IST program as part of License Amendment 207, this issue is also a Deviation in accordance with the NRC Enforcement Policy. The licensee put this issue into the CAP as Action Requests (ARs) 2193481 and 2193482 and planned to include these valves in the full IST program.

This performance deficiency was more than minor because if left uncorrected, there was a potential to lead to a more significant safety concern. Specifically, these valves that were credited to mitigate the consequence of an accident were not tested in accordance with the IST program. The finding screened as very low safety significance (Green)because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components, nor did it involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding affected the cross-cutting area of problem identification and resolution in the aspect of evaluation because the licensee justified that the valves be put into the augmented IST program since they were non-code components. In addition, the licensee did not re-scope these components into the IST program when 10 CFR 50.55(f)(1) was changed in 1999. This misconception continued when the licensee discovered several valves of the LTS were not in the IST program scope in 2015. [P.2] (Section 4OA2.1.b.2.ii)4

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of problem identification and resolution (PI&R) as defined by Inspection Procedure 71152, "Problem Identification and Resolution." Documents reviewed are listed in the Attachment to this report. Note that the licensee's computer program tracks condition reports (CRs) as action requests (ARs).

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the CAP at DAEC to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," were met. The inspectors observed and evaluated the effectiveness of meetings related to the CAP, such as the Management Review Committee meeting and the Department Corrective Action Review Board meeting. Selected licensee personnel were interviewed to assess their understanding of, and their involvement in, the CAP. The inspectors reviewed selected CRs across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensee's CAP. The majority of the risk-informed samples of CRs reviewed were issued since the last NRC biennial PI&R inspection completed in May 2015. The inspectors also reviewed selected issues that were more than five years old. The inspectors assessed the licensee's characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations and condition evaluations. The inspectors assessed the scope and depth of the licensee's evaluations. For issues that were characterized as significant conditions adverse to quality, the inspectors evaluated the licensee's corrective actions to prevent recurrence and for issues that were less significant, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance. The inspectors performed a 5-year review of the safety-related control building chiller system based on input from the resident staff. The system is part of the control building heating, ventilation and air conditioning system and its function is to provide chilled water for temperature control in the building. This ensures operability of plant equipment and maintains accessibility and habitability of the building, including the control room. The primary purpose of this review was to determine whether the licensee was monitoring and addressing performance issues of the control building chiller system. The inspectors performed walkdowns, as needed, to verify the resolution of issues. A 5-year review of the instrument air system was also performed to assess the licensee's efforts in monitoring the effectiveness of maintenance. Although this system is non safety related, its failure would adversely affect plant operation and require operator intervention. The system is currently a Maintenance Rule (a)(1) system that is in the monitoring phase of the (a)(1) action plan. The inspectors performed walkdowns, as needed, to verify the resolution of issues. The inspectors examined the results of self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors also performed walkdowns, as necessary, to verify the resolution of the issues. b. Assessment

(1) Identification of Issues Based on the results of the inspection, the inspectors concluded that DAEC was generally effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were normally identified and captured in a complete and accurate manner in the CAP. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the CAP for resolution. The inspectors determined that the licensee was generally effective at trending low level issues to prevent larger issues from developing. The licensee used the CAP to document instances where previous correct ive actions were ineffective or were inappropriately closed.

The inspectors performed a 5-year review on the control building chiller systems. As part of this review, the inspectors interviewed the current system engineer, reviewed

CRs, critical equipment failure evaluations and condition evaluations. In addition, the inspectors performed a system walkdown to assess the material condition of the system and surrounding area. The inspectors concluded that control building chiller system related concerns were identified and entered into the CAP at a low threshold, and concerns were resolved in a timely manner commensurate with their safety significance.

i) Observation Declining Rate of Identification The inspectors review the CR generation rate for the last five years and noted a steady decline over this period. Specifically, there were over 9,100 CRs generated in 2012 compared with only about 6,600 generated in 2016, a 28 percent drop. The most significant decline was from 2014 to 2016 when a 27 percent drop was observed. Considering the impact of an outage year to a non-outage year and the change in how the licensee classified routine work activities as non-corrective action items, the inspectors still observed an 11 percent drop in identification rate.

As documented in the pre-inspection self-assessments, the licensee had also recognized this declining trend and had taken steps to address this issue. The inspectors recognized that there may be multiple reasons for this issue such as: organizational change, staff reduction, backlog reduction, etc. Based on the samples reviewed, both low and high safety significance issues were in the CAP. Through interviews with the licensee's staff, the inspectors concluded that the staff were willing to bring up safety issue and write CRs. Therefore, this declining trend had not affected plant operations but the licensee needs to be cognizant of this trend before it affects the problem identification process.

ii) Findings No findings were identified.

(2) Prioritization and Evaluation of Issues

Based on the results of the inspection, the inspectors concluded that the station was effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk.

The inspectors determined that the Management Review Committee meetings and the Department Corrective Action Review Board meetings were generally thorough and maintained a high standard for evaluation quality. Members of the Management Review Committee discussed selected issues in sufficient detail and challenged each other regarding their conclusions and recommendations.

The inspectors determined that the licensee usually evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

In general, appropriate actions were assigned to correct the degraded or non-conforming

condition.

i) Observations Corrective Action Program Process Issues During this inspection, the inspectors identified a number of CAP process issues at DAEC. For example, AR 1776321, "LPCI Manual Realignment from S/D Cooling in Mode Three," documented an issue related to the low pressure cooling injection operation. The licensee performed an apparent cause evaluation but did not assign corrective action to the apparent cause identified as required by the licensee's CAP procedure. A number of actions were assigned but were not corrective actions such that they could be changed or cancelled without as much oversight as corrective actions

would receive. The licensee initiated AR 2192557, "NRC PI&R - Corrective Actions for ACE 1776321-05," to address this issue. In another example, AR 1599839, "Replacement of 1VAC015A/B Cooling Coils Has Not Been Timely," documented timeliness issues with safety-related room cooler cooling coils replacement. One of the corrective action assignments to replace the coil was canceled without proper justification and approval from the Management Review Committee as required by the licensee's CAP procedure. The licensee initiated AR 2192698, "NRC PI&R - LTCA 1599839-04 Cancelled Inappropriately," to address this issue. Although these issues were minor procedure violations, the licensee needs to be vigilant and adhere to procedures in order to maintain the overall CAP effectiveness.

ii) Findings Failure to Include Valves in the Inservice Testing Program

Introduction:

The inspectors identified a finding of very low safety significance and an associated non-cited violation of 10 CFR 50.55a for the licensee's failure to scope multiple check valves into the IST Program. Since the licensee made a commitment to the NRC to put these valves into the IST program as part of License Amendment 207, this issue is also a Deviation in accordance with the NRC Enforcement Policy.

Description:

On August 15, 1994, as supplemented on December 21, 1994, and January 20, 1995, the licensee submitted a request for a license amendment to increase the allowable main steam isolation valve (MSIV) leakage and delete the Technical Specification requirements applicable to the MSIV leakage control system (LCS). MSIV leakage would be directed to the main steam drain lines and the main condenser instead of the LCS. The licensee proposed to use non-safety-related components to fulfill the safety related leakage control function through an alternate treatment path. The licensee committed in their submittal, among implementing modifications, that all valves within the seismic verification boundary that were required to reposition to establish the boundary or treatment path would be included in the American Society of Mechanical Engineers (ASME),Section XI, IST program. License Amendment 207 was approved and issued by the NRC on February 22, 1995. The ASME Section XI Code is now the ASME Code for Operations and Maintenance (OM Code). Despite the commitment, the licensee did not include all the valves within the seismic verification boundary into the scope of the ASME IST program when Amendment 207 was implemented in 1995. This new leakage treatment system (LTS) contained valves that were scoped into the IST program because of meeting other scoping criteria.

However, five LTS valves were put in to the augmented IST program and four other LTS valves, due to an oversight, were not included in the IST program at the time. During an outage scope review in 2015, the licensee identified that four valves for the LTS were not in the IST program and proceeded to put one of them into the augmented IST program. Actions to put the other three valves into the augmented IST program were assigned but not completed. The licensee uses the augmented IST program for components that are not ASME Class 1, 2 or 3 components but have a safety function or have a commitment to be included in the IST program. Testing of the valves in the augmented IST program would be performed in accordance with the ASME Code only to the extent practical. However, relief requests would not be submitted for a valve if the code requirement could not be met. Therefore, components in the augmented IST program are subjected to less stringent requirements than those in the IST program. Prior to September 1999, 10 CFR 50.55a(f)(1) required, in part, that safety-related pressure vessels, piping, pumps and valves must meet the requirements applicable to components which are classified as ASME Code Class 2 or Class 3 for a boiling water-cooled nuclear power facility whose construction permit was issued prior to

January 1, 1971. On September 22, 1999, 10 CFR 50.55a(f)(1) was revised and requires, in part, that pumps and valves that perform a function to shut down the reactor or maintain the reactor in a safe shutdown condition, mitigate the consequences of an accident, or provide overpressure protection for safety related systems (in meeting the requirements of the 1986 Edition, or later, of the Boiler and Pressure Vessel or OM Code) must meet the test requirements applicable to components which are classified as ASME Code Class 2 or Class 3 for a boiling water-cooled nuclear power facility whose construction permit was issued prior to January 1, 1971. DAEC received their construction permit on June 22, 1970. Therefore, all the valves in the LTS were required to be scoped in the full IST program per 10 CFR 50.55a(f)(1) as they were credited to mitigate the consequences of an accident.

On December 8, 2015, during a refueling outage scoping review, the licensee identified that the four valves were not included in the IST program. Actions were created to scope these valves into the augmented IST program. Upon the inspectors' questioning, the licensee reviewed the work history and determined only corrective maintenance had been performed on some of these valves.

The licensee completed a functional assessment and determined the valves were functional but non-conforming.

Analysis:

The inspectors determined that the failure to include the nine valves into the IST program in accordance with 10 CFR 50.55a(f)(1) as well as the commitment for License Amendment 207 was within the licensee's ability to foresee and correct. This issue was therefore a performance deficiency and was more than minor because if left uncorrected, there was a potential to lead to a more significant safety concern. Specifically, these valves that were credited to mitigate the consequence of an accident were not tested in accordance with the IST program and may not function appropriately when needed. The inspectors evaluated the finding using the Significance Determination Process in accordance with IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," Exhibit 3, dated June 19, 2012. The finding screened as very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components, nor did it involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding affected the cross-cutting area of problem identification and resolution in the aspect of evaluation to ensure that resolutions address causes and extent of conditions commensurate with their safety significance.

Specifically, through Lice nse Amendment 207, the lic ensee applied and the NRC approved the use of non-code components in lieu of a safety-related system provided that the licensee included the valves in the IST program to provide a high degree of confidence that these valves would remain functional. Instead the licensee mistakenly concluded that the valves could be put into the augmented IST program since they were non-code components. In addition, the licensee did not re-scope these components into the IST program when 10 CFR 50.55(f)(1) was changed in 1999. This misconception continued when the licensee discovered several valves of the LTS were not in the IST program scope in 2015. [P.2]

Enforcement:

Title 10 of the CFR, Section 50.55a(f)(1) requires, in part, that pumps and valves that perform a function to mitigate the consequences of an accident must meet the test requirements applicable to components which are classified as ASME Code Class 2 or Class 3 for a boiling water-cooled nuclear power facility whose construction permit was issued prior to January 1, 1971. Contrary to the above, DAEC, which received their construction permit on June 22, 1970, failed to ensure that nine MSIV leakage treatment system valves which perform a function to mitigate the consequences of an accident met the test requirements applicable to components which are classified as ASME Code Class 2 or Class 3 for a boiling water-cooled nuclear power facility whose construction permit was issued prior to January 1, 1971. Specifically, the licensee put these nine valves in the augmented IST program and therefore, did not meet the all the requirements applicable to components which are classified as ASME Code Class 2 or Class 3.

The inspectors determined that the failure of the licensee to meet the commitments for License Amendment 207 was also a Deviation from February 22, 1995 when the amendment was issued, to September 22, 1999, when the requirements were codified in 10 CFR 50.55a.

The licensee put this issue into the CAP and planned to include these valves in the full IST program. Because this violation was of very low safety significance and the issue was entered in into the licensee's CAP as ARs 2193481 and 2193482, this violation is being treated as a NCV, consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 0500031/2017007-01, Failure to Include Valves in the Inservice Testing Program)

(3) Effectiveness of Corrective Action Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk.

Problems identified using root or apparent cause methodologies were resolved in accordance with the CAP procedural and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely.

The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

The inspectors performed a 5-year review of the instrument air system. As part of this review, the inspectors interviewed the current system engineer, reviewed the instrument air system health report, CRs, operating experience, and Maintenance Rule (a)(1) action plan. The system action plan was initiated in May 2016 to address a number of critical component failures, which exceeded the system's condition monitoring performance criterion. The failures had been appropriately addressed and the system was in the monitoring phase of its (a)(1) action plan. In addition, the inspectors walked down the instrument air system to assess material condition. The inspectors concluded that instrument air system related concerns were identified and entered into the CAP at a

low threshold, and concerns were resolved in a timely manner commensurate with their safety significance.

i) Observations Inadequate Implementation of Technical Specification Bases Change Process The inspectors assessed the corrective actions associated with non-cited violation (NCV)05000331/2015007-02, "Failure to Correctly Update the Updated Final Safety Analysis Report." The corrective actions associated with this NCV also included addressing errors in the Technical Specification Bases. The inspectors identified that one of the proposed corrections to Technical Specification Bases page B3.5-28 had been made but, due to an oversight, was changed back to read incorrectly. The inspectors considered this a minor violation of TS 5.5.10 a, "Technical Specification Bases Change Control Program." Technical Specification 5.5.10.a., stated, "Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews." Licensee procedure ACP 102.24, "Preparation, Review and Processing of Bases Changes," Revision 10, Step 3.3.2.(3) stated that "the Licensing Engineer determines the content of the proposed changes. This shall include consideration of the effect(s) on outstanding change requests." The licensee was working on two change packages with the same page in both packages simultaneously and failed to ensure that both packages contained the correct wording on the effected page. The licensee wrote AR 2192712, "2017 NRC PIR TS Bases Page Incorrectly Updated" to correct this error. Corrective Action Program Vulnerability The inspectors identified a vulnerability in the licensee's CAP process. Currently, the licensee's process allows the owner of a Significance Level 2 or 3 condition adverse to quality CR to approve intent changes and due da tes extensions for assignments unless these actions were designated by the MRC as requiring MRC approval for due date extensions and intent changes. As such, corrective actions can be cancelled without scrutiny. For example, in AR 2063651, "Allowable Stress Higher Than CLB's Listed in Block Wall Calc," the licensee documented an issue with a number of calculations that listed an incorrect allowable limit. This CR was initially screened by the licensee as a condition not adverse to quality. However, the MRC changed that to a condition adverse to quality and noted that corrective action was required. The MRC did not specifically require MRC approval for due date extensions and intent changes. However, the corrective action was later changed by the owner to a routine work assignment item and was currently pending for completion. Per procedure PI-AA-104-1000, "Condition Reporting," a routine work assignment, when tied to a CR, does not meet the corrective action definition and are not part of the CAP. Therefore, the owner's action that changed a corrective action into a routine work assignment directly conflicted with the intent of the MRC. The licensee entered this issue into the CAP as AR 2200047, "DAEC NRC PI&R:

Vulnerability of the CAP to evaluate this issue. ii) Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed the OE program implementing procedures, attended CAP meetings to observe the use of OE information, and reviewed licensee evaluations of OE issues and events. The objective of the review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were appropriate, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE, were identified and implemented in an effective and timely manner. b. Assessment The inspectors observed that operating experience was discussed as part of the daily and pre-job briefings. Operating experience evaluations were limited to certain types; for example, NRC generic communications, significant industry issues, Part 21's, and General Electric Service Information Letters. Additional industry operating experience was disseminated across plant departments for their review and use, if needed. Specific equipment related issues were distributed to appropriate engineers for evaluating and screening into the CAP. The inspectors also verified that the use of OE in formal CAP products such as root cause evaluations and equipment apparent cause evaluations was appropriate and adequately considered. In addition, operating experience was used when developing the instrument air system Maintenance Rule (a)(1) action plan.

Generally, OE that was applicable to DAEC was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations. Based on the results of the inspection, the inspectors concluded that operating experience was effectively utilized at the station. No significant issues were identified during the inspectors' review of selected licensee operating experience evaluations.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments and Nuclear Oversight audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the

inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. These issues were entered into CRs as required by the CAP procedures. The inspectors also determined that findings from the CAP self-assessment were consistent with the inspectors' assessment.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensee's sa fety conscious work environment (SCWE) through the reviews of the facility's Employee Concerns Program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of CRs. The inspectors also reviewed the results from a 2015 safety culture survey and meeting minutes of the Safety Culture Monitoring Panel.

The inspectors held scheduled interviews with 21 individuals in various group and individual settings to assess their willingness to raise nuclear safety issues. These individuals included supervisory and non-supervisory licensee and contractor personnel.

Additionally, the inspectors interviewed other licensee staff informally during plant walkdowns to ascertain their views on the effectiveness of the CA program and their willingness and freedom to raise issues.

The individuals in the scheduled interviews were randomly selected to provide a distribution across various departments at the site. In addition to assessing individuals' willingness to raise nuclear safety issues, the interviews also included discussion on any changes in the plant environment over the last six months. Items discussed included:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP;

• willingness to use the CAP; and

• knowledge and understanding of ECP.

The inspectors also discussed the functioning of the ECP with the program coordinator; reviewed program logs from 2015 through 2017; and reviewed selected case files to identify any emergent issues or potential trends.

b. Assessment The inspectors did not identify any issues of concern regarding the licensee's SCWE. Information obtained during the interviews indicated that an environment was established where licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee and contractor personnel were aware of and generally familiar with the CAP and other processes, including the ECP and the NRC's allegation process, through which concerns could be raised. In addition, a review of the types of issues in the ECP indicated that the licensee staff members were appropriately using the CAP and ECP to identify issues. The inspectors did not observe and were not provided any examples where there was retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews.

c. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meetings On March 24, 2017, the inspectors presented the inspection results to Mr. D. Curtland and other members of the licensee staff. The licensee acknowledged the issues presented. One item had remained open pending licensee's evaluation. This open item was discussed and closed during a teleconference exit on April 25, 2017. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Casey, Chemistry Manager

D. Curtland, Site Director

M. Davis, Licensing Manager

J. Debois, Performance Improvement Manager

M. Durbin, Maintenance Director

P. Hanson, Engineering Director

C. Hill, Training Manager

D. Hobson, Manager of Projects

D. Morgan, Radiation Protection Manager

M. Strope, Operations Manager

J. Schwertfeger, Security Manager

M. Foritz, Emergency Preparedness Manager

B. Simmons, Performance Assessment Manager

NRC

K. Stoedter, Branch Chief

B. Bergeon, Acting Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Open and

Closed

05000331/FIN-2017007-01 NCV Failure to Include Valves in the Inservice Testing (IST) Program (Section 4OA2.1.b.2.ii)

Discussed

None

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 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.

Condition Reports

AR 0341404

070454 NCAQ - Apparent Discrepancy in DAEC HELB

Analysis October 13, 2009

AR 1599839 Replacement of 1VAC015A/B Cooling Coils has Not Been Timely December 7, 2010

AR 1774177 Maintenance Rule 50.65(A)(1) Red Eval Revision - Chillers June 7, 2012

AR 1776321 LPCI Manual Realignment from S/D Cooling in Mode Three June 14, 2012

AR 1780414 A Chiller Unloading Without an Unload Signal June 28, 2012

AR 1807351 RADTRAD V3.03 Error Notice - Natural Deposition September 27, 2012

AR 1824467 Rollup of Issues With Embedded Conduits and Water November 16, 2012

AR 1878171 Non-Conservative Drywell Pressure Assumed in LOCA

Dose Calc May 20, 2013

AR 1922406 Accidental Discharge on Handgun - Rapid OE CR November 21, 2013

AR 1934710 Common Cause Evaluation for RCIC and SBDG Events January 21, 2014

AR 1944002 B CS Conduit Water Found - 2A205 February 26, 2014

AR 1954564 Documentation of Simple Troubleshooting on IT265A April 3, 2014

AR 1968971 HPCI Inboard Isol "A" Logic Occurred During

STP 3.3.6.1-13 May 30, 2014

AR 1974995

NRC 95002 Inspection - RCIC Classification as

Safety-Related June 27, 2014

AR 1979556 1J379, 1J391, 2J258, and 2J2060 Should be EQ Boxes July 22, 2014

AR 1990281 RCIC Room Cooling Cables Have Low Insulation Resistances September 10, 2014

AR 1991300 Inst Air Blowdown Valve Unable to be Opened per

OP-017 September 15, 2014

AR 1998983 Track and Implement Commitments IAW

NG-14-0235 October 14, 2014

AR 2000025 V22-0017 HPCI Turb Discharge Check Second Crack Found on Disc October 18, 2014

AR 2000253 Evaluate Unplanned Orange Shutdown Risk from

10/18/14 October 19, 2014

AR 2006364 Amplifying Instruction of STP 3.10.1-02 Not Performed November 12, 2014

AR 2012985 Observations for Airlines Above RFPs December 13, 2014

AR 2016908 Change Management Plan - Coating Program January 7, 2015

AR 2017390 Replace 1VAC011 January 9, 2015

AR 2022223 3Q/4Q RP Trend-Procedure Adherence Declined Performance January 31, 2015

AR 2022708 PA Vehicle Search:

Driver Interview Questions Not All Asked February 3, 2015

AR 2024869 2015 FP Triennial Inspection - Vessel Overfill Impacts February 11, 2015

AR 2025444 PI+R Prep Assessment Discrepancies February 15, 2015

AR 2025470 PI+R Prep Assessment Gap February 13, 2015

AR 2034076 Secondary Containment Airlock Doors #225 and #228

Both Opened March 21, 2015

AR 2035078 Potential Unplanned LCO Entry 3.6.1.3 Condition F March 25, 2015

AR 2035592 RC CARB Rejected

CA 1990448-03 March 26, 2015

AR 2035930 Track the Implementation of LTAM 13-111 March 27, 2015

AR 2037048 125VDC Battery, 1D1, Specific Gravities April 1, 2015

AR 2048955 4KV Breaker 0224A8971-0016 Charging Motor May 19, 2015

AR 2049249 15EXEOF:

Process Flow Data Sent to Midas Incorrectly May 20, 2015

AR 2050319 Drawing Discrepancy / Unexpected Voltage on Relay Contact May 26, 2015

AR 2059120 NS180001 Instrument Air Quality Test Failure July 8, 2015

AR 2063509 Reduced Margin to ASME Operating Limit on Stroke Time July 29, 2015

AR 2063651 Allowable Stress Higher Than CLB's Listed in Block Wall Calc July 30, 2015

AR 2076452 Bad Equalize Contact On Switch September 24, 2015

AR 2077358 Instrument Air Flow Action Limit Exceeded September 29, 2015

AR 2079777 15 TD3AR - Crew Did Not Anticipate Re-Energization of 1A3 October 7 2015

AR 2080575 HCVS Rad Monitor Does Not Meet Temperature Specifications October 9, 2015

AR 2082389

CE 2077358 - Air Audit Required October 15, 2015

AR 2088694

MI-3027 Dew Point Exceeds Station Limit November 4, 2015

AR 2092300 Missed ASME Code Surveillance for V19-0124 CVCM Disassembly November 18, 2015

AR 2096144 Valves Should be Included in the IST Program December 8, 2015

AR 2100521 NRC Finding - B Condensate Pump Packing Shield/Ventilation January 5, 2016

AR 2101383 1K032A Rebuilt Compressor Found With Fine Grit Inside January 8, 2016

AR 2102366 IT265B Instrument Air Dryer Degraded Performance January 13, 2016

AR 2102756 Incorrect Relay Actuation During 186/DG2 Lockout Relay Test January 14, 2016

AR 2104450 Moral Continues to Decline at Duane Arnold January 21, 2016

AR 2104943 EC Security Impact Review Inconsistencies January 25, 2016

AR 2105042 10 CFR Part 37 Implementation Issues January 25, 2016

AR 2105156

DEP-PI Miss During LOCT January 25, 2016

AR 2105462 2016 50.59 UFSAR Change 05-031 Did Not Reflect MOE for DBAs January 26, 2016

AR 2108683 Enterprise Risk Application to Hard Containment Vent Project February 9, 2016

AR 2109139 Personnel Search Medical Exemption List February 10, 2016

AR 2111716 8A Monitoring Well Showing Elevated Tritium February 20, 2016

AR 2114658 Protected Area Vehicle Search March 3, 2016

AR 2114764 EQ Documentation Needs Clarification March 3, 2016

AR 2117204 LLEA Part 37 Information March 14, 2016

AR 2117206 Security Key Inventory Issue March 14, 2016

AR 2117211 Security Record Documentation Practices March 14, 2016

AR 2120438

SEL 16-032 ASO Left Weapon Unattended Momentarily March 25, 2016

AR 2120863

CA 341404-05 Has Numerous Errors May 28, 2016

AR 2123866 Evaluate the Ground Water Tritium Presentation RCSC April 7, 2016

AR 2124092 Unable to Calibrate Load Cell With Current Procedure April 8, 2016

AR 2124644 New Source of Tritium Determined By RSCS Activities April 11, 2016

AR 2125833 1P216 HPCI Main Pump Outboard Shaft Seal Leak April 15, 2016

AR 2126762 Trend - Instrument Air Assessment Level Exceeded April 20, 2016

AR 2128272 "A" Chiller Discharge Pressure Low Out of Spec. April 27, 2016

AR 2128533 1P216 HPCI Pump Outboard Shaft Seal Leak April 15, 2016

AR 2128548 Evaluate/Implement Permanent Monitoring Solutions for

IT-88 April 28, 2016

AR 2131074 Resin Possibly Exhausted in Monitoring Well HIC May 10, 2016

AR 2134479 RWPs Do Not Include Instructions Required by

Procedure

May 26, 2016

AR 2134780 NOS Identified HEPA/VAC Room Issues May27, 2016

AR 2135679 16IPX Evaluate The Delta Between ERDS & Midas Data Times June 2 2016

AR 2135767 The HP Planning for

HIC 16-R-002 Was Not Done for the Job June 2, 2016

AR 2137075 PDS3025 Air Dryer Hi D/P Possible Cause of Air Dryer Trips June 16, 2016

AR 2137378 RCE CAPRS Cancelled Without MRC Approval June 10, 2016

AR 2137402 Documentation for Locked High Rad Area Entries Not Found June 10, 2016

AR 2137896 MIDAS Software Ownership Needs to be Documented June 14, 2016

AR 2138459 MIDAS Dose Assessment June 16, 2016

AR 2141393 Nuclear Safety:

Secondary Containment Airlock System June 30, 2016

AR 2146889

HP-55 - Radiological Work Screening Form July 29, 2016

AR 2146890

HP-21 - HP Briefing Checklist Summary July 29, 2016

AR 2147236 2Q16 RP Management Awareness Area-RCA HEPA Vacuum Controls August 2, 2016

AR 2147378 EP Drill 16TD2 Validation Rework Due to Lack of Midas Expert August 2, 2016

AR 2147887 RP Technician on Watch Without Respirator Qualification August 4, 2016

AR 2149987 Replace

JBD-17-10 Carbon Steel Air Pipe w/Stainless Steel August 15, 2016

AR 2151412 T1 Transformer Lock-Out August 22, 2016

AR 2151959

HPP 3102.03 - Radiation Protection Job Planning August 24, 2016

AR 2153559

16TD2 - Drill Scenario Did Not Consider Restoration of 1A3 August 31, 2016

AR 2154889 Trend - 1K003 Increased Duty Cycle September 9, 2016

AR 2157394 Actions Not Clear for February 2016 GWPP Tritium Issue

CE 2111716 September 22, 2016

AR 2160580 STP NS800001 Failure October 5, 2016

AR 2160767 Trip Setting on 1B3419

MO-2000 Found on Incorrect Setting October 6, 2016

AR 2160971 V25-0001, RCIC Torus Suction Line Chk Valve Failed ASME STP October 7, 2016

AR 2161159 CV4415 Failed Local Leakage Rate Test October 8, 2016

AR 2162443 MO4424 Internal Seat Damage October 13, 2016

AR 2162851 As-Found Loose Bonnet Fasteners on MO4423 October 15, 2016

AR 2164974 Identified FME During Torus Closeout Per IPOI 7 October 24, 2016

AR 2165588 Torus Closeout & Engineering Inspection FME Discovery October 26, 2016

AR 2166159 1B3419 "A" RHR Drywell Spray Inboard Tripped During PMT October 29, 2016

AR 2166942 A SBDG Jacket Cooling Water Leak Identified November 1, 2016

AR 2170757 1K-3 Duty Cycle is at the ASME Alert Limit November 22, 2016

AR 2172523 IT265A Air Dryer High DP Alarm Activated Three Times in an Hour December 4, 2016

AR 2175497 Potential NRC Finding - 2016 ERO Tabletop Drills December 16, 2016

AR 2177447 Instrument Air Dryers Spontaneously Went into Bypass December 31, 2016

AR 2177715 IT265B - Switching Valve Not Porting Air January 2, 2017

AR 2179017 Replace Control Building Chiller 1VCH001B per

EC287318 January 11, 2017

AR 2183599 Sim Rad Driver Unavailable for Second Run of Drill Development February 3, 2017

Apparent Cause Evaluation

ACE 1994734

SEL 14-072 HU Error Results in Security Event Log September 29, 2014

ACE 2041170 NOS Finding-Deficiencies in Configuration Management April 16, 2015

ACE 2044732 Qualification Event April 30, 2015

ACE 2056826 Discrepancies Between User Manual and Site June 25, 2015

ACE 2080185 HPCI and RCIC Condensate Storage Tank Suction Transfer Inoperable October 8, 2015

ACE 2099065 ACE, NRC Potential Violation HPCI/RCIC Relay Reportability January 21, 2016

ACE 2102327 50.59 Eval of Portable Heaters During Severe Weather January 13, 2016

ACE 2126348 Vacuum Breaker Did Not Move During STP April 19, 2016

ACE 2128559 RCIC Turbine Trip During

STP-Relay Blocks on Wrong Contact April 28, 2016

ACE 2128777 Operations Crew Adverse Trend in Procedure Use and Adherence May 3, 2016

ACE 2129328 ACE for Secondary Containment Breach June 7, 2016

ACE 2144950

SEL 16-063 SO Exited the PA and Reentered W/O

Search Require July 20, 2016

ACE 2147887 RP Technician on Watch Without Respirator Qualification August 4, 2016

ACE 2155933 Hard Pipe Vent Rupture Disc Torque Requirements September 14, 2016

ACE 2160423 NRC Violation - HPCI/RCIC Vacuum Breaker Line ARP October 5, 2016

ACE 2175497 Potential NRC Finding - 2016 ERO Tabletop Drills December 16, 2016

Common Cause Evaluation

CCA 2022041 3Q/4Q Engineering PAR Adverse Trend January 30, 2015

CCA 2110066 Equipment Reliability - Critical Component Failures

2015 February 14, 2016

CCA 2110066 Equipment Reliability - Critical Component Failures

2015 February 14, 2016

Audit, Assessment and Self-Assessments

AR 2029698 Perform Self-Assessment of MOV Program Documentation March 3, 2015

AR 2072018 2016 SAQH on Operation Clearance Program June 30, 2016

AR 2074004 2016 SAQH on Configuration Control September 15, 2015

AR 2074004 2016 SAQH on Configuration Control January 25, 2016

AR 2074016 2016 SAQH on Operations Work Management/Execution June 30, 2016

AR 2097987 Fleet Corrective Action Program - DAEC June 7, 2016

AR 2113378 Conduct A Quick Hit Self-Assessment (SAQH) on the

FME February 26, 2016

AR 2135203 NOS Escalation-2 Control of RCA Vacuums Cleaners May 31, 2016

AR 2155942 Level 1 Assessment:

RP Postings September 14, 2016

AR 2157298 Level 1 Assessment:

Kaman High Rad Alarms September 22, 2016

AR 2158565 PDA AFI Leadership Assessment September 27, 2016

AR 2180322 DAEC OE Program L1A Assessment Generic Implication January 17, 2017

AR 2185437 Level 1 Assessment:

CM Monitoring of Fire Protection DBD February 14, 2017

PDA 15-010 Nuclear Oversight Report - Performance Improvement December 22, 2015

PDA 16-001 DAEC Nuclear Oversight Report March 17, 2016

PDA 16-006 DAEC Nuclear Oversight Report July 19, 2016

Miscellaneous

2017 Duane Arnold Problem Investigation and Resolution Pre-Inspection Assessment January 27, 2017 DAEC Engineering Self Evaluation and Trending Analysis Report 4Q2015, 1Q2016, 2Q2016 DAEC Groundwater Investigation Findings and Recommendations April 7, 2015 DAEC Radiation Protection Self Evaluation and Trending Analysis Report 4Q2015, 1Q2016, 2Q2016 DAEC Survey Analysis Report October 15, 2015

Duane Arnold Organizational Effectiveness Survey Result April 2016 Duane Arnold Station Fifth Interval In-Service Testing Program Revision 3

EVAL-PDA-19.01-00602 - Instrument Air (a)(1) Action Plan November 9, 2016

ISO-HBB-014-01-H, RCIC Pump Suction Revision 0 Maintenance Corrective Action Review Board Package March 8, 2017 Management Review Committee Package March 7, 2017 Self-Evaluation and Trending Analysis Report for Second Quarter 2016 July 15, 2016 Self-Evaluation and Trending Analysis Report for Third and Fourth Quarter 2016

January 16, 2017 System Health Report:

18.00 - Instrument Air Q3-2016 Tables of Explanations of CRs Associated With Effectiveness Review

1999648-17

March 23, 2017 Work Order

40318134-01, PSV3223A:

Verify Relief VLV SetPT December 4, 2015 Work Order

40456120-16, CV4327 Check and Adjust Magnets October 22, 2016 Work Order

40496672-01, STP 3.6.1.7-02 Drywell Suppression Chamber VAC Brkr Insp October 24, 2016

BECH-E105<014> 480V Motor Control Center Schedules Revision 27 Bech-M169<3> Control Building Chillers 1VCH001A and

1VCH001B Revision 14

CAL-R00-PUP-007 DBA LOCA Radiological Consequences Dose With Alternate Source Term Revision 3

WO 40055244-01 V03-0089 - Bonnet Leak on Check Valve December 9, 2010

WO 40390183-08 1B3419:

Inspect and Calibrate Replacement Breaker October 13, 2016

WO 40450920-11 SUS99.28:

Geoprobe Fence Sampling in OCA November 8, 2016

WO 40495420-01 V03-001:

Disassembly & Inspect December 27, 2016

WO 40497284-01 1B3419 A RHR Drywell Spray Inboard Tripped During PMT

October 30, 2016

WO 40498029-01 1G031/ENG:

Replace Jacket Cooling Water Gasket Cylinder #3 November 7, 2016 WO A-81966 Replace Cooling Coil November 3, 2008 WR A-00639 Valve Has a Blown Gasket, Check Valve,

360 Degrees Leak March 29, 1990

Operating Experience

AR 1956085

CAL-M98-058 (ADS Accumulator Size Verification)

Inputs Error April 8, 2014

AR 2062301 Failed Diesel Driven Fire Pump from Clogged

Y-Strainer July 23, 2015

AR 2063400 Browns Ferry OE on HPCI Steam Supply Valve IST Failure July 29, 2015

AR 2064541 Part 21 Report from NAMCO August 4, 2015

AR 2065240 OE on Brunswick U2 MSIV Failure August 6, 2015

AR 2065333 Pre-Notification of Part 21 NAMCO Switch (Event Number 51280) August 6, 2015

AR 2090010 Reduced Operating Margin Contributed to Loss November 9, 2015

AR 2116396 ICES

323695 - Browns Ferry HPCI Steam Line Inboard Isolation October 20, 2016

AR 2137751 OE Review Columbia Trip Due to Improper N/A of Steps June 13, 2016

AR 2141767 Part 21 Notification for Target Rock Solenoid Valves July 1, 2016

AR 2142179 OE from Fitzpatrick TCOA RHRSW Injection July 6, 2016

AR 2145693 OE Evaluation - NRC

IN 2016-09 Reverse Engineering July 25, 2016

AR 2150105 OE Review of Broken Buried Pipe Due to Heavy Loads August 16, 2016

AR 2163002 Part 21 Applicability - CAD Solenoid Valves October 16, 2016

AR 2181576 Part 21 Report From C&D Technologies January 25, 2017

AR 2183198 SOR Part 21 - Post Accident Radiation Dose Inaccuracies February 1, 2017

AR 2183218 Part 21 Notification for Target Rock Solenoid Valves February 1, 2017

AR 2592406 Accidental Discharge on Handgun - Rapid OE November 21, 2013

Procedures

ACP 102.24 Preparation, Review, and Processing of Bases Changes Revision 10

ACP 114.15 Condition Reports and Screening Revision 9

EP-AA-1005 (DAEC) Maintaining Equipment Important to Emergency Preparedness (DAEC Specific Information)

Revision 10

EP-AA-105 Maintaining Equipment Important to Emergency Response Revision 4

ER-AA-109 Nuclear Fleet Protective Coatings Revision 2

HP-21 HP Briefing Checklist Summary Revision 12

HP-55 Radiological Work Screening Form Revision 24

HPP 3102.03 Radiation Protection Job Planning Revision 42

MA-AA-101-1000 Foreign Material Exclusion Procedure Revision 15

MA-AA-107-1000 Control and Calibration of Measuring and Test Equipment (MTE)

Revision 0

NA-AA-200-1000 Employee Concerns Program Revision 0

NSC-PP-022 Corporate Procurement Engineering and Dedication Process for Reverse Engineering Activities Revision 0

OI 149 Residual Heat Removal System Revision 161

OI 150 Reactor Core Isolation Cooling System Revision 84

OP-AA-100-1002 Plant Status Control Management Revision 7

PI-AA-01 Corrective Action Program and Condition Reporting

Revision 4

PI-AA-102 Operating Experience Program Revision 12

PI-AA-102-1000 Significant Operating Experience Report (SOER) and INPO Event Report (IER) Process Implementation Revision 14

PI-AA-102-1001 Operating Experience Program Screening and Responding To Incoming Operating Experience Revision 17

PI-AA-102-1002 Internal Operating Experience Revision 8

PI-AA-104-1000 Condition Reporting Revision 12

PR-AA-100-1001 Project Management Revision 10

QI-4-NSC-9 Procurement Engineering Control Revision 8

RP-AA-104-1000 ALARA Implementing Procedure Revision 7 Valve-A391-01 Equipment-Specific Maintenance Procedure Anchor/Darling (Flowserve US Inc.) Valves Revision 20

Root Cause Evaluations

RCE 1922406 Accidental Discharge of Handgun November 21, 2013

RCE 1999648 Additional Coating Delamination Found in Torus - Effectiveness Review for Items 17 and 31

October 16, 2014

RCE 2002062 Security One Hour Report to the NRC October 24, 2014

RCE 2141149 RB Airlock Doors Momentarily Open at the Same Time June 29, 2017

RCE 2161689

RFO 25 MSIV LLRT Failures October 21, 2016

Condition Reports

Generated for this Inspection

AR 2193569 2017 NRC PI&R -

RWA 341404-06 Classified as RWA vs CA March 24, 2017

AR 2192770 IOD Not Performed for Installed Part 21 Issue March 21, 2017

AR 2191141 Unable to Locate Meeting Minutes March 13, 2017

AR 2192557 NRC PI&R - Corrective Actions for

ACE 1776321-05 March 20, 2017

AR 2193276 NRC PI&R Insp - AR S/L of Licensee Identified Findings March 23, 2017

AR 2192818 NRC PI&R - Verbal Approval by MRC for Cancellation of River Inspection March 21, 2017

AR 2192712 2017 NRC PI&R Tech Spec Bases Page Incorrectly Updated March 21, 2017

AR 2192708 NRC PI&R - LTCA

2102756-11 Misclassified During Evaluation 03

March 21, 2017

AR 2192698 NRC PI&R - LTCA

1599839-04 Cancelled Inappropriately March 21, 2017

AR 2192692 NRC PI&R -

AR 1878171 Misclassified Assignment Types March 21, 2017

AR 2191338

RWA 2138459-01 Should Have Been a CA from

CE 2135679-01

March 14, 2017

AR 2190723 NRC Identified PI6920B Inaccurate March 10, 2017

AR 2193314 2017 NRC PI&R - Circuit Maintenance Data Sheet Improvement March 23, 2017

AR 2193482

MSIV-LTS Check Valves Additions to IST Program

Not Tracked March 24, 2017

AR 2193481 NRC Questions on Commitments for

MSIV-LTS Valves March 24, 2017

AR 2194657 2017 NRC PI&R - CAP Process Issues March 29, 2017

AR 2200047 DAEC NRC PI&R:

Vulnerability of the CAP April 22, 2017

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

AR Action Request

ASME American Society of Mechanical Engineers

CAP Corrective Action Program

CFR Code of Federal Regulations

CR Condition Report

DAEC Duane Arnold Energy Center

ECP Employee Concerns Program

IMC Inspection Manual Chapter

IST Inservice Testing

LCS Leakage Control System

LTS Leakage Treatment System

MSIV Main Steam Isolation Valve

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

OE Operating Experience

PI&R Problem Identification and Resolution

SCWE Safety Conscious Work Environment