IR 05000315/2016007

Re-Issued Inspection Report - D.C. Cook, Units 1 & 2, Temporary Instruction 2515/191, Mitigation Strategies, NRC Spent Fuel Pool Instrumentation and Emergency Preparedness Report 05000315/2016007 and 05000316/2016007

ML16160A133
Person / Time
Site:	Cook
Issue date:	06/07/2016
From:	Ann Marie Stone Division Reactor Projects III
To:	Gebbie J Indiana Michigan Power Co
Bartlett B
References
IR 2016007
Download: ML16160A133 (17)

Text

UNITED STATES une 7, 2016

SUBJECT:

RE-ISSUED INSPECTION REPORT - DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS REPORT 05000315/2016007 05000316/2016007

Dear Mr. Gebbie:

On May 12, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/staffing/Multi-Unit Dose Assessment Plans inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2. The NRC inspection team discussed the results of this inspection with you and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.

After the inspection report was issued, the NRC identified that the report number was incorrect.

The report number should have been 05000315/0216007; 05000316/2016007. This error has been corrected. The cover letter and the enclosed inspection report are being re-issued to correct the inspection record.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any findings or violations of more than minor significance. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 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 NRC Public Document Room or from the Publicly Available Records (PARS)

component of 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 (the Public Electronic Reading Room).

Sincerely,

/RA Kenneth Riemer Acting for/

Ann Marie Stone, Team Leader Technical Support Section Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74

Enclosure:

IR 05000315/2016007; 05000316/2016007

REGION III==

Docket Nos: 05000315; 05000316 License Nos: DPR-58; DPR-74 Report No: 05000315/2016007; 05000316/2016007 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Power Plant, Units 1 and 2 Location: Bridgman, MI Dates: April 25 through May 12, 2016 Inspectors: B. Bartlett, Project Engineer, Region III (Team Lead)

J. Boettcher, Resident Inspector, Palisades J. Mateychick, Senior Reactor Inspector, Region IV S. Sheldon, Project Engineer, Region III J. Havertape, Region III, Reactor Engineer L. Kozak, Senior Reactor Analyst, Region III (Observer)

M. Humberstone, Senior Reactor Analyst, HQ (Observer)

Approved by: A. Stone, Team Leader Technical Support Section Enclosure

SUMMARY

Inspection Report (IR) 05000315/2016007, 05000316/2016007; 04/25/2016 - 04/29/2016;

Donald C. Cook Nuclear Power Plant, Units 1 and 2: Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/staffing/Multi-Unit Dose Assessment Plans.

This inspection was performed by three NRC regional inspectors and one resident inspector.

No findings of significance or violations of NRC requirements were identified during this inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated February 201

NRC-Identified and Self-Revealing Findings

None

Licensee-Identified Violations

None

REPORT DETAILS

4OA5 Other Activities (TI 2515/191)

The objective of Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan Revision 0 (ADAMS Accession No. ML15169A106) and Revision 1 (ADAMS ML15280A023) and the NRCs plant safety evaluation (ADAMS ML15264A851) and to verify that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools. The purpose of this TI was also to verify the licensees had implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.

The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262).

The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensees submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections.

1. Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The team examined the licensees established guidelines and implementing procedures for the beyond-design basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified that the licensee satisfactorily:

• developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events;

• integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;

• protected FLEX equipment from site-specific hazards;

• developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;

• trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and

• developed the means to ensure that the necessary off-site FLEX equipment would be available from off-site locations.

The inspectors verified that non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program as appropriate.

c. Findings

No findings were identified.

2. Spent Fuel Pool Instrumentation

a. Inspection Scope

The team examined the licensees newly installed spent fuel pool instrumentation.

Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors determined that the licensee satisfactorily installed and established control of the spent fuel pool (SFP)instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified that the licensee satisfactorily:

• installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal(s) and safety evaluation;

• installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittal(s); and

• trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

The inspectors verified that non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit extended loss of offsite power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented multi-unit dose assessment (including releases from spent fuel pools) capability using the licensees site-specific dose assessment software and approach as described in the licensees multi-unit dose assessment submittal. Documents reviewed are listed in the attachment.

b. Assessment The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all AC power to all site units and impedes access to the site. The inspectors verified the following:

• licensee satisfactorily implemented required staffing change(s) to support a multi-unit ELAP scenario;

• EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and

• implemented multi-unit dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

The inspectors verified that non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

4OA6 Management Meeting

.1 Exit Meeting Summary

On May 12, 2016, the inspectors presented the inspection results to Mr. J. Anderson of the licensees staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Gebbie, Chief Nuclear Officer

S. Lies, Site Vice-President

M. Scarpello, Regulatory Assurance Manager

R. Wynegar, Regulatory Assurance

S. Mitchell, Regulatory Assurance Supervisor

V. Gupta, Performance Improvement Supervisor

J. Ross, Plant Manager

L. Baun, PA Director

K. Simpson, EP Supervisor

S. Wiederwax, EP

D. Etheridge, Ops

R. Strasser, Severe Accident Management Team (SAMT)

D. Burris, SAMT

L. Bush, SAMT

J. Anderson, SAMT

B. Lewis, Ops

J. Cross, Maintenance

U.S. Nuclear Regulatory Commission

J. Cameron, Branch Chief, Reactor Projects Branch 4

T. Brown, Branch Chief, Japan Lessons Learned Division

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None