IR 05000315/2019012
| ML19301C355 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/28/2019 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Gebbie J Indiana Michigan Power Co |
| References | |
| IR 2019012 | |
| Preceding documents: |
|
| Download: ML19301C355 (13) | |
Text
October 28, 2019
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000315/2019012 AND 05000316/2019012
Dear Mr. Gebbie:
On September 27, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant, Units 1 and 2. On September 26, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, 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 D.C. Cook.
If you disagree with a cross-cutting aspect assignment 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 Donald C. Cook. 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/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety
Docket Nos. 05000315 and 05000316 License Nos. DPR-58 and DPR-74
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000315 and 05000316
License Numbers:
Report Numbers:
05000315/2019012 and 05000316/2019012
Enterprise Identifier: I-2019-012-0027
Licensee:
Indiana Michigan Power Company Nuclear Generation Group
Facility:
Donald C. Cook Nuclear Plant, Units 1 and 2
Location:
Bridgman, MI
Inspection Dates:
August 26, 2019 to September 27, 2019
Inspectors:
I. Hafeez, Reactor Inspector
G. Hausman, Senior Reactor Inspector
A. Shaikh, Senior Reactor Inspector
Approved By:
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Donald C. Cook Nuclear Plant, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Include Appropriate Acceptance Criteria In Fire Protection Water System Flow Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000316,05000315/2019012-01 Open/Closed
[H.6] - Design Margins 71111.05XT The inspectors identified a finding of very-low safety significance and associated violation of Technical Specification 5.4 Procedures, for the licensees failure to maintain fire protection water system flow test procedure. Specifically, the licensee failed to maintain Procedure 12-FPP-4030-066-006, Three Year Fire Protection System Unobstructed Flow Test, by not including appropriate acceptance criteria in the procedure to demonstrate that adequate fire protection water flow and pressure would be delivered to various fire suppression loads in the plant.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.05XT - Fire Protection - NFPA 805 Fire Protection Inspection Requirements (IP Section 02.01a)
The inspectors evaluated fire protection program implementation in the following selected areas and/or fire zones, including analyzed electrical circuits:
- (1) AA5/6 (6M) Unit 2 Auxiliary Building (Aux Building Middle West)
Analyzed Circuits: (Include if applicable)
- West Charging Pump
- (2) AA40
- (41) Unit 1 ESS and MCC Rooms
Analyzed Circuits: (Include if applicable)
- SG#1 Water Level(Wide Range) Control Rm Indication
- (3) AA44 (46A/B/C/D) Unit 2 Emergency Power Area (All zones)
Analyzed Circuits: (Include if applicable)
- (4) AA48 (55 & 56) Unit 1 SWGR Cable Vault and Aux Cable Vault
B.5.b Inspection Activities (IP Section 02.03) (1 Sample)
The inspectors evaluated the following B.5.b Mitigating Strategies:
(1)
- Make up to Refueling Water Storage Tank (RWST)
- Make up to Condensate Storage Tank (CST)
INSPECTION RESULTS
Failure to Include Appropriate Acceptance Criteria In Fire Protection Water System Flow Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000316,05000315/2019012-01 Open/Closed
[H.6] - Design Margins 71111.05XT The inspectors identified a finding of very-low safety significance and associated violation of Technical Specification 5.4 Procedures, for the licensees failure to maintain fire protection water system flow test procedure. Specifically, the licensee failed to maintain Procedure 12-FPP-4030-066-006, Three Year Fire Protection System Unobstructed Flow Test, by not including appropriate acceptance criteria in the procedure to demonstrate that adequate fire protection water flow and pressure would be delivered to various fire suppression loads in the plant.
Description:
On September 29, 2016, Procedure 12-FPP-4030-066-006, Revision 7 was implemented to meet the requirements of Technical Requirements Surveillance (TRS)8.7.5.20 and thereby, establish operability of the fire suppression water system per Technical Requirements Manual (TRM) 8.7.5. TRM 8.7.5, states, in part, that the fire suppression water system shall be operable with an operable flow path capable of taking suction from either one of the fire water tanks and transferring the water through protected area distribution piping and TRS 8.7.5.20 requires, in part, that the licensee verify, by a series of full flow tests, every fire main segment to be clear of obstruction. Section 1.0 of procedure 12-FPP-4030-066-006 states, in part, that the purpose of this procedure is to verify that the fire mains are clear and free of obstructions and that this procedure complies with Unit 1 and Unit 2 TRM TRS 8.7.5.20. Procedure 12-FPP-4030-066-006, Section 5.0, Acceptance Criteria, states, in part, that the fire protection engineer verifies that the flow loop test demonstrates adequate, unimpeded system flow for the system to perform its intended fire protection functions. However, the inspectors identified that no quantitative acceptance criteria was included in the procedure for the fire protection engineer to verify that the flow and pressure measurements taken during the flow test demonstrated unimpeded flow and that the fire suppression system would be able to perform its intended fire protection function of supplying adequate flow and pressure to various suppression loads throughout the plant. Specifically, the licensee stated that at the time of the test, no quantitative acceptance criteria for maximum allowed pressure loss in the system piping had been established for this test and a general trend in pressure and flow measurements taken during each test was used to qualitatively access the degradation of the fire suppression system piping. The inspectors determined that the licensee could therefore not have verified the operability of the fire suppression water system because the maximum allowed pressure loss for the system to still be able to perform its fire protection functions was not known. The inspectors further determined that in December 2016, the licensee performed a calculation to determine the maximum allowed pressure losses in the system piping to be used as the acceptance criteria for procedure 12-FPP-4030-066-006 for future tests. The inspectors questioned the licensee's acceptance of the September 29, 2016, test against the new quantitative acceptance criteria and the licensee stated that no determination had been conducted to ensure that the previous September 29, 2016, test was satisfactory. In order to address the inspector's question and concern regarding the September 29, 2016, test, the licensee reconciled the test data against the new quantitative acceptance criteria and determined that the test had failed the acceptance criteria and therefore, the licensee would have failed to meet TRS 8.7.5.20 and TRM 8.7.5. In addition, during the inspection, the licensee conducted its Three Year Fire Protection System Unobstructed Flow Test to meet TRM 8.7.5 and TRS 8.7.5.20 requirements utilizing the new quantitative acceptance criteria and again failed the test. Therefore, the licensee declared the fire suppression water system inoperable per TRM 8.7.5.
Corrective Actions: The licensee documented the failed flow tests of 2016 and 2019 and the inspectors' concerns into its corrective action program (CAP) and implemented immediate corrective action to align a backup source of fire suppression system water distribution as required by TRM 8.7.5 action item. In addition, the licensee had reached out to its contractor that performed the quantitative hydraulic calculation to re-evaluate the plant's fire suppression system piping flow model and the licensee intends to inspect and determine which sections of piping may be obstructed.
Corrective Action References:
AR 2019-9028; NRC Identified Finding for 12-FPP-4030-066-006 Done in 2016
AR 2019-8760; Loop 3 FP Flow Test Did Not Meet Acceptance Criteria
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee's failure to include appropriate acceptance criteria in the fire protection suppression water system flow test procedure 12-FPP-4030-066-006, Revision 7 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to include acceptance criteria in the flow test procedure resulted in the licensee accepting the fire protection suppression system flow test as satisfactory even though the system would not be able to automatically meet the pressure and flow requirements for various automatic suppression loads in the plant. Therefore, this failure adversely affected the mitigating system cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events (fire) to prevent undesirable consequences (i.e., core damage).
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors screened the finding using Appendix F, Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet, dated September 20, 2013. The inspectors answered YES to Question 1.4.3.A, Would adequate fire water capacity (flow and required pressure) still be available for protection of equipment important to safe shutdown in the most limiting location onsite? Specifically, the licensee had the capability to manually start a second fire pump to augment the lowered pressure and flow seen by the fire suppression system due to the main distribution piping obstructions. Therefore, the inspectors determined that adequate fire water capacity would still be available to provide protection of equipment important to safe shutdown in the most limiting location onsite and that the finding screened as having very-low safety significance (Green).
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, the inspectors determined that the licensee failed to understand, calculate and guard the absolute design margins of pressure and flow required for adequate suppression capabilities onsite and instead relied on relative trending data to establish system capability resulting in the licensee's failure to incorporate acceptance criteria into its flow test procedure that would maintain the fire water system within its design margins.
Enforcement:
Violation: TRM 8.7.5, states, in part, that the fire suppression water system shall be operable with an operable flow path capable of taking suction from either one of the fire water tanks and transferring the water through protected area distribution piping and TRS 8.7.5.20 requires, in part, that the licensee verify, by a series of full flow tests, every fire main segment to be clear of obstruction. Procedure 12-FPP-4030-066-006 Revision7 was used to ensure this requirement was met; however, this procedure contained no acceptance criteria to ensure the adequacy of flow. Technical Specification 5.4.1.d requires, in part, that, written procedures shall be established, implemented, and maintained covering the Fire Protection Program implementation. Contrary to the above, on September 29, 2016, the licensee did not have a procedure that implemented the Fire Protection Program requirement in the TRM (8.7.5) to verify that the fire distribution piping was free of obstruction and operable. Specifically, procedure 12-FPP-4030-066-006 Revision 7, Three Year Fire Protection Water System Unobstructed Flow Test did not contain acceptance criteria to verify that the fire protection water system could meet its intended fire protection function.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 26, 2019, the inspectors presented the triennial fire protection inspection results to Joel P. Gebbie and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.05XT Calculations
MD-12-HV-013-N
AB & CD Battery Rooms Hydrogen Evolution
PRA-NB-FIRE-
FQ
Fire PRA Model Quantification Notebook
R2684-1098-000
Unobstructed Flow Test Acceptance Criteria
2/22/2016
Corrective Action
Documents
AR 2016-7239
NFPA 805 Monitoring Program FPRA/Maintenance
Performance
06/16/2016
GT 2014-13933
Change NFPA 805 Higher Risk Evaluation (HRE) Definition
11/05/2014
GT 2016-12812
NFPA 805 Monitoring Program - return systems to a(2)
status
11/04/2016
Corrective Action
Documents
Resulting from
Inspection
AR 2019-8242
2-OHP-4026-EDM-001 Observations
08/28/2019
AR 2019-8593
Additional Spare Batteries needed for NFPA 805
Headlamps
09/10/2019
AR 2019-8712
Possible Enhancements to 12-OHP-4025-001-002
09/12/2019
AR 2019-9028
NRC Identified Finding for 12-FPP-4030-066-006 Done in
2016
09/24/2019
AR 2019-9101
NRC Observation from 2019 Fire Protection Triennial
09/26/2019
Drawings
2-5724E
Heating & Ventilation Cable Enclosure Area & Battery
Room @ El.625'-0" Unit 2
OP-2-5148C
Flow Diagram Diesel Generator Area & Elec. Switchgear
Rooms Heating & Ventilation Sys. Unit #2
OP-2-98731
Area Heating Elementary Diagram
OP-2-98741
Aux Bldg Ventilation Sheet No. 1 Elementary Diagram
Engineering
Changes
Modify U1 East 600V SWGR RM Mezz Area C02 from
Manual to Automatic
Engineering
Evaluations
Engineering
Equivalency
Evaluation 11-71
Emergency Power Systems Area and EPS Control Rod
Drive Room Fire Door Closure Evaluation
04/03/2017
Fire Plans
FPMP
NFPA 805 Monitoring Program Analysis
Fire Area: AA5/6 - Auxiliary Building (El. 587 ft.)
Fire Area: AA40 - Unit 1 Engineered Safeguards Systems
and Motor Control Center Room
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(El. 609 ft. 6 in.)
Fire Area: AA44 - Unit 2 Emergency Power Systems Area
(El. 609 ft. 6 in.)
Fire Area: AA48 - Unit 1 Switchgear Rooms Cable Vault
and Auxiliary Cable Vault (El. 625 ft. 10 in. and 620 ft. 6 in.)
Miscellaneous
ES-PIPE-1013-
QCN
Pipe Material Specification
FAQ 10-0059
NFPA 805 Monitoring
Performance-Based Standard for Fire Protection for Light
Water Reactor Electric Generating Plants
2001 Edition
Technical Requirements Manual
Procedures
1-OHP-4025-LS-
Process Monitoring from LSI Panels
1-OHP-4025-LS-
Start-up AFW
1-OHP-4025-LS-
Start-up AFW
1-OHP-4025-LS-
RCS Make-up with CVCS Cross-tie
1-OHP-4025-LTI-
Local Main Steam Isolation
2-FPE-2270-
FPCE-001
Fire Protection Program Change Evaluations (FPCE)
2-FPE-2270-
FPMP-001
Fire Protection Required SSC Monitoring Program
2-FPP-2270-
066-005
Fire Truck Inventory and Operability Test
2-FPP-2270-
066-024
Hydrostatic Testing and Re-Rack of Fire Hose
2-FPP-2270-
066-030
Other Fire Protection Equipment Inspections
2-FPP-2270-
066-037
Functional Check and Inspection of the Hale Portable
Pumps
2-FPP-4030-
Three Year Fire Protection Water System Unobstructed
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
066-006
Flow Test
2-OHP-4025-
001-002
Fire Response Guidelines
2-OHP-4025-
001-002
Fire Response Guidelines
2-OHP-4026-
EDM-001
Extensive Damage Mitigation Initial Response
2-OHP-4026-
EDM-002
Extensive Damage Mitigation Enhanced Site Response
Strategies
2-IHP-4030-266-
2
Unit 2 Engineered Safety Switchgear CO2 Fire Suppression
Test
2-OHP-4025-LS-
Process Monitoring from LSI Panels
2-OHP-4025-LS-
RCS Make-up with CVCS Cross-tie
NFPPM
NFPA 805 Fire Protection Program Manual
PMP-2270-CCM-
001
Control of Combustible Materials
PMP-2270-CCM-
001
Control of Combustible Materials
PMP-2270-SDR-
001
Fire Protection Suppression, Detection Systems, and Rated
Assemblies
PMP-4030--001-
001
Impact of Safety Related Ventilation on the Operability of
Technical Specification Equipment
PMP-4100-SDR-
2
Outage Risk Assessment and Management
Work Orders
2-PP-144
Electric Fire Pump Test
07/17/2018
2-PP-145E
Diesel Fire Pump Test
07/18/2018
55470909
Year Fire Protection Water Flow Test
09/26/2016
55470910
Year Fire Protection Water Flow Test
09/28/2016
55499733
OPFP, U-2 Turb Bldg, Hydro Test/Re-Rack Fire Hose
06/27/2018
55506058
OPFP, Annual Hydro Test of Misc Fire Hose Outside P.A.
06/06/2018
55521410
OPFP, Hale Portable Pumps Accessory Inspection
07/25/2019
10