IR 05000315/2006008

IR 05000315-06-008, 05000316-06-008; American Electric Power, on 7/31/2006-8/18/2006; D. C. Cook Nuclear Power Plant, Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML062440252
Person / Time
Site:	Cook
Issue date:	08/31/2006
From:	Christine Lipa NRC/RGN-III/DRP/RPB4
To:	Nazar M Indiana Michigan Power Co
References
IR-06-008
Download: ML062440252 (23)

Text

ust 31, 2006

SUBJECT:

D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000315/2006008; 05000316/2006008

Dear Mr. Nazar:

On August 18, 2006, the U.S. Nuclear Regulatory Commission completed a team inspection at the D. C. Cook Nuclear Power Plant, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on August 18 2006, with Mr. Peifer and other members of your staff during an exit meeting.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved an examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution programs. However, during the inspection, several examples of minor problems were identified, where the documentation of an issue was incomplete, in that, the extent of the evaluation and the status of the corrective actions could not be clearly discerned. Additionally, there were several examples where industry operating experience was not properly evaluated for applicability to the station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Christine A. Lipa, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74 Enclosure:

Inspection Report 05000315/2006008; 05000316/2006008 w/Attachment: Supplemental Information cc w/encl:

M. Peifer, Site Vice President L. Weber, Plant Manager S. Simpson, Regulatory Affairs Manager G. White, Michigan Public Service Commission L. Brandon, Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division Emergency Management Division MI Department of State Police State Liaison Officer, State of Michigan D. Lochbaum, Union of Concerned Scientists

SUMMARY OF FINDINGS

IR 05000315/2006008; 05000316/2006008; American Electric Power; on 7/31/2006-8/18/2006;

D. C. Cook Nuclear Power Plant, Units 1 and 2; Biennial baseline inspection of the identification and resolution of problems. No violations or findings were identified.

The inspection was conducted by a regional projects inspector, a resident inspector, and a regional electrical engineering specialist.

Identification and Resolution of Problems The team identified that the licensee was effective at identifying problems and incorporating them into the corrective action program. The licensees effectiveness at problem identification was evidenced by the relatively few deficiencies identified by the team that had not been previously identified by the licensee during the review period. In general, the licensee was effectively prioritizing, evaluating, and correcting issues. However, the team found several examples where the documentation of an issue did not clearly indicate whether it had been properly evaluated, what the status of the corrective actions were, or whether it had been effectively resolved.

Operating experience usage was also effective, but the team found several examples where operating experience, primarily issued by the NRC, was not screened by the station or was not properly evaluated by the assigned department.

Licensee audits and self-assessments were generally thorough, probing, and made good use of outside resources to maintain independence. On the basis of interviews conducted during this inspection, workers at the site felt free to input safety findings into the corrective action program.

A. Inspector-Identified and Self-Revealed Findings No findings of significance were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program

(1) Inspection Scope The team assessed the licensees processes for identifying and correcting problems.

This included a review of program procedures, interviewing plant personnel, and evaluating various station meetings to understand the implementation of the licensees corrective action program (CAP) and related activities.

The team reviewed selected CAP products, such as condition reports (CRs), audits, self-assessments, and other documents to determine if problems were being identified at the appropriate threshold and entered into the CAP. This review primarily covered those items generated since the 2004 NRC Problem Identification and Resolution Inspection (inspection report 05000315/2004014; 05000316/2004014), but also included a sample of items generated since 2001.

The team evaluated whether issues were effectively documented, evaluated and corrected in the CAP. The team reviewed selected CRs, Apparent Cause Evaluations, Root Cause Reports, prompt investigations, operability determinations, and Common Cause Analyses. Attributes reviewed included the technical adequacy of the cause determinations, adequacy of the extent of condition reviews including evaluations of potential common cause or generic concerns, and whether applicable industry operating experience had been considered.

Other attributes reviewed by the team included the quality of the licensees trending of conditions and the corresponding corrective actions. The team searched for items or issues which looked like potential trends and assessed whether the licensee had appropriately identified and captured these trends within the CAP. The team also assessed licensee corrective actions stemming from previous Non-Cited Violations and Licensee Event Reports.

The team selected the Essential Service Water system for a more extensive review because the system historically had maintenance rule (a)(1) action plans to address unavailability and reliability issues and because the system ranked high on the licensees Probabilistic Risk Assessment list. The team examined licensee initiated CRs, cause and operability evaluations, work orders and corrective actions generated over the past 5 years to identify those deficient conditions and trends that had occurred.

The team also conducted walkdowns and interviewed plant personnel to identify other processes that may exist where problems and findings could be identified. In particular, the team focused on the Performance Observation Program (POP) based on past licensee identified examples where issues were identified that were not captured in the CAP.

During this inspection, the team reviewed 14 self-assessments, 8 audits, 22 CRs, 5 trend evaluations, and 15 apparent or root cause evaluations.

(2) Assessment No findings of significance were identified.

On August 17, 2006, the team attended a Corrective Action Review Board meeting.

This board, comprised of senior licensee management, was responsible for reviewing the quality of root cause evaluations and for monitoring the overall health of the CAP.

During the meeting, the Board reviewed the current CAP performance indicator data.

The team noted that the Board challenged the CAP program coordinators on the indicator data and appeared to provide effective high-level oversight of the CAP.

The team concluded that the licensee was effectively managing and monitoring the essential service water system. The team noted that the licensee had identified and initiated corrective actions that generally resolved deficient conditions. The team identified no apparent trends that had not been previously identified by the licensee.

The team also noted that long standing issues such as relatively short service life on the service water pumps were being resolved within the CAP.

Identification of Issues The licensee implemented a broad CAP governed by corporate-level policies and procedures. A shared computerized data base was used for creating individual reports and for subsequent management of the processes of issue evaluation and response.

This included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate. Workers were encouraged to raise concerns and typically identified issues at a low threshold. This was evidenced by the large number of CRs generated annually (about 6000-7000/yr) which were reasonably distributed across the various departments. While workers were familiar with the various avenues for raising concerns (NRC, CAP, etc), most preferred to bring issues directly to their supervision.

The NRC inspectors had recently evaluated the licensees trending program in the inspection quarter ending June 30, 2006. The inspection results were documented in Inspection Report 2006-004. The team noted that cause codes were being used and that thresholds were established and being used to identify trends in condition reports.

The licensee had initiated a large number of trend reports (78 in 2005 and about 34 to date in 2006). However, the team noted that the licensee had not identified an apparent trend regarding incorrect reportability determinations. Since March 2006, the NRC identified three occasions where the licensee did not make a required report per 10 CFR 50.72 and/or 50.73. Although the licensee documented each occurrence in a CR, the events in the aggregate where not considered a potential trend. This was discussed with licensee management who initiated CR 0801181 to address the issue.

The licensee established the POP to conduct in-field observations of activities by supervision. This program had its own procedure and documentation forms separate from the corrective action program. This provided an opportunity for potentially significant issues to be identified through a POP observation, but not be captured in the CAP. In fact, shortly after the 2004 NRC PI&R inspection, the licensee identified some examples where this had occurred. The team reviewed a sampling of POP results generated by the maintenance and operations departments, who together accounted for the majority of the observations, and did not identify any cases where an issue was not captured in the CAP as appropriate.

Prioritization and Evaluation of Issues Once initiated, CRs were first reviewed by the department CAP coordinators for completeness and for assignment of the applicable trend coding. The CRs were then reviewed by the Initial Screening Committee (ISC) to assign priority and actions.

Potential operability issues were promptly routed to the operating shift for review by the Shift Manager. Selected issues were then reviewed by the station Management Screening Committee (MSC), comprising senior managers from each department, to verify that the overall CAP objectives were being met. The team attended several ISC and MSC meetings and observed that issues were being appropriately challenged and reportability, repetitiveness, and trending were discussed where appropriate.

Root and apparent cause evaluations were assigned by the ISC and/or MSC as appropriate. Once completed, the evaluation was reviewed by the initiating department for quality. A sampling of the evaluations were also reviewed by the Corrective Action Review Committee (CARC). Evaluations rejected by the CARC, were sent back to the initiating department and a CR was generated listing the reasons for the rejection. The team attended a CARC meeting and reviewed several CRs generated by the Committee; no issues were identified.

Although issues were generally appropriately screened and evaluated, the team identified some examples where the quality of the evaluation or of the documentation was weak. The majority of these issues were attributed to past problems which were identified and addressed by the licensee; however, there were some current examples:

• The inspectors concluded that the extent of condition evaluation for CR 06017004, Unit 2 Experienced a Loss of MCC 2-ABD-C Due to Electrical Component Failure, was narrowly focused. The evaluation pertained to the instantaneous trip function for a molded case circuit breaker (MCCB) that supplied the non-safety related auxiliary jacket water pump motor on the Unit 2 CD emergency diesel generator, which failed to open the breaker when the motor shorted to ground. This breaker was in the MCCB testing program and it failed to open due to hardened grease on the moveable mechanical parts inside the breaker. The team noted that no evaluation, based on risk and significance, was conducted to identify MCCBs that should be tested prior to the next scheduled test date to preclude a more significant breaker failure. The team subsequently verified that no similar MCCB breaker failures having more significant adverse consequences had occurred and that there did not appear to be an adverse trend of MCCB failures.

• The evaluation for CR 05187067, Failure of Unit 2 East Essential Service Water Radiation Monitor, did not fully document all the actions taken nor did it consider such items as industry operating experience or past corrective actions for similar, previous station issues.

• The evaluation for CR 05097036, Adequacy of Locked High Radiation Area Controls, concluded that the controls for Very High Radiation Areas were adequate, without documenting the basis for the conclusion.

• An operations department self-assessment finding regarding the effectiveness of the surveillance test program, documented in CR 04162079, Operations Self-Assessment SA-2004-OPS-003-QH Surveillance Program Evaluates the Effectiveness of the Surveillance Program as Applied to a Variety of Technical Specification Related Plant Equipment, identified an apparent trend.

Specifically, the evaluation identified an increase in the number of surveillance test failures between 2001-2004. However, the apparent trend was not evaluated to determine the reason and significance for the increased number of failed items. The team reviewed subsequent surveillance test failures through June 2006 and noted a general decline in the number of test failures. The team also did not identify an adverse trend regarding repeat surveillance failures.

The licensee wrote CRs 0801523, 0801534, 0801657, and 0801697 to document the teams concerns.

The team attended a Plant Operations Review Committee meeting held on August 3, 2006. The meeting was held to discuss a potential Notice of Enforcement Discretion request due to elevated temperatures in the unit 1 lower containment areas. The team noted that the Committees review of the issue was thorough and probing.

Effectiveness of Corrective Actions Corrective actions were, in general, adequately implemented, were effective in addressing the parent issue, and were timely commensurate with the significance of the issue. However, the team found some examples where timely corrective actions were not taken, were not being effectively tracked, or were not properly evaluated or supported by the documented basis. These examples included:

• The team identified several examples where corrective actions were deferred with no documented basis. The team subsequently determined that the extensions were appropriate, however, the lack of documentation did make the basis for the decision making difficult to discern.

• The team noted that in the evaluation for CR 06082038, In-Depth Apparent Cause Evaluation was Rejected by CARC, the originating department had concluded that a clock reset was unnecessary because the evaluation was approved by the department prior to the CARC rejection. The team felt that this was an inadequate basis for why a clock reset was unnecessary.

• In 2003, the licensee initiated CR 03036056, Unit 2 Reactor Tripped on Low Steam Generator Level Coincident with Steam Flow/Feed Flow Mismatch due to Control Group 3, Dual Power Supply Failure in Rack 21, to address a station-wide issue with low voltage power supplies. The corrective actions for this issue were scheduled to be completed in December 2006; however, some of these actions were being implemented through other CRs which were not linked back to CR 03036056.

• One corrective action identified in the root cause evaluation documented in CR 04261020, Root Cause Evaluation Needed for the Decision Making Process That Led to the Attempt to Move Accumulator Volume into #21 Accumulator by Raising the Pressures in the Remaining Three Accumulators Higher Than #21 Accumulators Pressure, was to incorporate a presentation by senior management and the Operations Director regarding expectations for questioning attitude and sound, conservative operational decision making into the operator Initial License Training Program as an on-going action. The presentation was not incorporated into Lesson Plan RO-C-ADM14 (Standards) in January 2005 as specified, and then the corrective action was closed. However, based on discussions with licensee personnel, the presentation was presented to operators attending the most recently completed Initial License Training class.

The licensee documented the teams observations in CRs 0801608 and 0801657.

The team noted some deficiencies regarding tracking and documentation of effectiveness reviews specified in older root cause evaluations. For example, CR 02082003 was initiated after the unit 2 main turbine control valves failed to operate as designed during testing in 2003. One effectiveness review was scheduled following turbine testing during the unit 2 cycle 14 outage in 2004. A second effectiveness review was scheduled following a modification to the turbine control system originally scheduled for installation in the unit 2 cycle 15 outage in 2005. This modification was later deferred to the cycle 16 outage in 2006 and then once again deferred to the cycle 17 outage in 2007. There was no documentation of whether the first effectiveness review was completed and no basis for deferring the modification. The team later determined that the required testing had been performed during the cycle 14 outage and the reason for deferring the modification was reasonable and justified. The team also noted that effectiveness reviews for more recent evaluations (CRs 03114044 and 04354007)contained objective and measurable criteria and were implemented as designed.

b. Assessment of the Use of Operating Experience

(1) Inspection Scope The team reviewed the licensees program for handling operating experience.

Specifically, the team reviewed the implementing procedure, attended meetings of the Operating Experience Screening Committee (OESC) and Prevention Review Board (PRB), reviewed operating experience evaluated by the plant, and verified that the licensee had adequately addressed some examples of operating experience provided by the team.

During this inspection, the team reviewed 22 CRs generated by the licensee addressing industry operating experience.

(2) Assessment No findings of significance were identified.

The licensee primarily obtained operating experience from the NRC website or from an industry website. Operating experience from the NRC (Part 21 reports, Information Notices, etc) were documented in CRs and sent to the appropriate departments for screening. Industry operating experience was sent to the OESC for review and a CR was generated if warranted. The PRB selectively evaluated a sampling of operating experience documented in the CRs to determine if they had been appropriately reviewed.

In general, operating experience was being well utilized at the station. The team observed that it was discussed as part of the daily station planning meetings and as part of pre-job briefings. During interviews with the team, various licensee staff commented favorably on the use of operating experience in daily activities. The team also noted that the OESC and PRB generally did a good job in implementing how operating experience was used at the station.

However, the team did identify examples where some operating experience was not properly screened and/or reviewed. In particular, the team noted that, in some cases, the operating experience was inadequately screened for applicability by the individual departments. These examples included:

• The team identified that Westinghouse Technical Bulletin 06-02, dated March 2006, regarding testing of molded case circuit breakers, was applicable to the licensee, but was not entered into the CAP for evaluation.

• The inspectors identified that 10 CFR Part 21 reports listed on the NRC web site that were included in Event Notifications and Licensee Event Reports were not being screened into the licensee corrective action program for evaluation. The team identified three examples of such reports that were potentially applicable to the licensee, but which had not been entered into the CAP for evaluation.

• The evaluation for CR 05097036, Adequacy of Locked High Radiation Area Controls, stated that prior operating experience had not been screened by the station; however, there was no corrective action to determine why it had not been screened.

• The department evaluation for CR 05081020, OE20236 - NRC Event Notification of Missed Unusual Event Notification, erroneously concluded that the operating experience did not apply to the station.

• The team identified that CRs documenting NRC generated operating experience were not being reviewed by the PRB. This was contrary to the objective of the PRB as stated above.

The team also noted that in a 2006 audit, the licensees Performance Assurance group had identified that the security department was not adequately reviewing operating experience for applicability. The licensee generated CRs 0801206, 0801523, 0801525, 0801649, and 0801659, and to address the teams observations.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed selected department self-assessments, and Performance Assurance audits of the corrective actions, operations, maintenance, engineering and plant support (radiation protection, security, and emergency preparedness) programs. The team evaluated whether these audits were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition to the document review, the team also interviewed licensee staff regarding the implementation of the audit and self-assessment programs. The team focused on those audits and assessments completed since 2004.

During this inspection, the team reviewed 14 self-assessments and 8 audits.

(2) Assessment No findings of significance were identified.

The audits and assessments were performed primarily under well-defined and focused procedures. A sampling of the audits and assessments were reviewed by the PRB as part of the management oversight of the program.

The team noted that the audits and assessments were generally critical and probing and typically utilized outside resources to maintain independence. There were a number of findings and observations identified across the spectrum of performance, including issues of proper CAP implementation. As appropriate, the audit/assessment findings were documented in CRs. However, the team noted that recommendations identified in the audits or assessments were not always tied to a specific CR for resolution.

However, the team verified that, in most cases, the recommendations were being properly evaluated.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors interviewed approximately 22 members of the plant staff, across all major work groups and all levels of responsibility. The purpose of the interviews was to assess whether a safety-conscious work environment existed at the station. The interviews were conducted using the guidance provided in Appendix 1 of NRC Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues.

The inspectors also reviewed the licensees 2004 Safety Conscious Work Environment Survey. In particular, the inspectors reviewed some of the corrective actions implemented after the survey and discussed the effectiveness of these actions with those licensee staff interviewed during the inspection.

In addition to the interviews, the inspectors looked for any evidence that plant employees might be reluctant to raise safety concerns during document reviews and observations of activities. The inspectors reviewed the station procedures related to the Employee Concerns Program (ECP), and discussed the implementation of this program with the stations program coordinator.

The inspectors also reviewed the licensees implementation of the Differing Professional Opinion (DPO) program. This program provided an alternative avenue for resolving disagreements between licensee staff and supervision regarding technical issues.

Specifically, the inspectors reviewed the implementing procedure for the program and the resolution of DPO issues identified since 2004.

As an aid in assessing this area, the inspectors referred to Principles for a Strong Nuclear Safety Culture, which was an industry guidance document developed in 2004.

The inspectors also referred to station procedure PMI-2015, Policy for Maintaining a Safety-Conscious Work Environment, revision 2.

(2) Assessment No findings of significance were identified.

Workers indicated that they felt comfortable identifying issues and discussing concerns with supervision without fear of reprisal. The inspectors observed that all personnel interviewed were aware of the different avenues through which they could express concerns including the corrective action program, informing their supervision, contacting the ECP coordinator, or coming to the NRC; however, most workers said they preferred reporting issues directly to their immediate supervisor. Only two of the interviewees had any interface with the licensees ECP or DPO programs; both individuals had generally favorable impressions of their experience.

The licensee trained first line supervisors on safety culture fundamentals as one of the key corrective actions following the 2004 survey. The inspectors noted that the training materials were consistent with the licensees policy statement and the aforementioned industry guidance. Between January and June 2006, the ECP staff performed some follow-up assessments of safety culture in various station departments. These assessments primarily consisted of interviews with department staff. The overall results were documented in a July 30, 2006, Memorandum to the Site Vice President. The responses provided to the ECP staff were generally consistent with those provided during the NRC inspectors interviews. The licensee planned to conduct another site wide assessment of safety conscious work environment (safety culture) in 2007.

The inspectors noted that the ECP process was readily utilized by station staff. In 2005 and as of August 14, 2006, there were 53 and 48 issues, respectively, processed by the ECP. The licensee expected the number of issues to be higher in 2006, based on having both a spring and fall outage scheduled in that year. The inspectors did not notice a particular trend in the specific issues that were identified. The inspectors concluded that issues were being appropriately handled by the ECP through interviews with the ECP staff and a review of selected closed case files.

Since 2004, the licensee has had only two DPO issues. One of these issues (i.e., DPO 04-001) did not appear to be adequately addressed by the licensee staff.

The issue dealt with the adequacy of local leak rate testing for containment isolation valves having a rubber diaphragm in place of a metal disk. These valves were tested in the reverse direction of their safety function (i.e., in the non-accident direction).

Although the testing was in accordance with the Technical Specification and licensing basis, it did not challenge the packing, bellows seals and containment side diaphragms of these valves. Therefore, there was a potential for a valve to pass the testing, but actually be inoperable due to an undetected leak. The licensee identified 23 valves that may yield non-conservative results when reverse-tested. Corrective actions included revising testing procedures and, for some of the valves, implementing modifications to allow for testing in the accident direction. This issue was documented in CR 4063027.

This issue had also been previously reviewed by the NRC, as discussed in inspection report 05000315/316-2004010(DRP). As stated in that report, there were no violations or findings associated with this issue.

The inspectors noted that the licensees closure memo in the DPO file only discussed the regulatory aspects and not the technical concerns. Additionally, the associated CR did not discuss the status of the corrective actions. During an interview, the originator of the DPO stated that while the procedure revisions were made, he was unaware if or when the modifications would be completed. Licensee management subsequently provided the inspectors with the scheduled completion dates for the modifications.

However, the inspectors were concerned that the lack of documentation in the CR and the lack of feedback to the originator of a DPO could result in some workers losing confidence that issues would be effectively resolved. This was discussed with the program coordinator who initiated CR 0801230 to address this issue.

4OA6 Management Meetings

Exit Meeting Summary

The inspectors presented the inspection results to Mr. M. Peifer and other members of licensee management at the conclusion of the inspection on August 18, 2006. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

The licensee stated that all proprietary information provided to the inspectors had been returned.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Brown, Human Performance Manager

T. Brown, Radiation Protection Manager

B. Gillespie, Training Manager

M. Horvath, Employee Concerns Program Coordinator

C. Hutchinson, Manager NDM-Site Programs Group

J. Jensen, Vice President-Support Services

C. Lane, Manager, Engineering Programs

S. Papageorgiou, Learning Organization

M. Peifer, Site Vice President

M. Scarpello, Supervisor, Nuclear Regulatory Assurance

S. Simpson, Manager, Nuclear Regulatory Assurance

S. Vasquez, Maintenance Manager

B. Wallace, Learning Organization

J. Wicks, Assistant Operations Manager

V. Woods, Performance Assurance Manager

Nuclear Regulatory Commission

B. Kemker, Senior Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None Attachment