IR 05000315/2020002
| ML20224A031 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/10/2020 |
| From: | Nestor Feliz-Adorno Reactor Projects Region 3 Branch 4 |
| To: | Gebbie J Indiana Michigan Power Co |
| References | |
| IR 2020002 | |
| Download: ML20224A031 (15) | |
Text
August 10, 2020
SUBJECT:
DONALD C. COOK NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000315/2020002 AND 05000316/2020002
Dear Mr. Gebbie:
On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant. On July 1, 2020, 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.
No findings or violations of more than minor significance were identified during this inspection.
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects
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:
05000315/2020002 and 05000316/2020002
Enterprise Identifier: I-2020-002-0026
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Plant
Location:
Bridgman, MI
Inspection Dates:
April 01, 2020 to June 30, 2020
Inspectors:
S. Bell, Health Physicist
M. Garza, Emergency Preparedness Inspector
B. Jose, Senior Reactor Inspector
J. Mancuso, Resident Inspector
J. Rutkowski, Project Engineer
P. Zurawski, Senior Resident Inspector
Approved By:
Néstor J. Féliz Adorno, Chief
Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Donald C. Cook Nuclear Plant, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000315,05000316/20 12007-02 Qualification Basis for Safety-Related Relays and Motor-Starter Contactors 71111.21M Closed
PLANT STATUS
Unit 1 began the inspection period at 50 percent rated thermal power due to a leak on the west main feedwater pump. After repair, the unit was returned to 100 percent thermal power on April 3, 2020, and operated at or near that level for the remainder of the inspection period.
Unit 2 began the inspection period at or near rated thermal power. On May 1, 2020, the licensee shut the unit down due to pressurizer spray valve reactor coolant system (RCS)leakage. The unit remained shut down for repairs until May 12, 2020, when it was returned to 100 percent thermal power. The unit operated at or near rated thermal power for the remainder of inspection period.
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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities, and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on May 29, 2020
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 east residual heat removal (RHR) system while the west RHR system was inoperable for maintenance on May 14, 2020
- (2) Unit 1 east motor driven auxiliary feedwater pump (MDAFP) and Unit 1 steam driven auxiliary feedwater pump (AFW) during testing of Unit 1 MDAFP on May 29, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone 19: emergency diesel generator (EDG) room 2AB on April 14, 2020
- (2) Fire Zone 18: EDG room 2CD on April 14, 2020
- (3) Fire Zone 61: Spray additive tank room, Unit 1 and 2, elevation 587' 0" on May 12, 2020
- (4) Fire Zones 1E & 1F: Containment spray pump, Unit 2 east and west on May 12, 2020
- (6) Fire Zone 40B: Unit 1 4KV CD switchgear room on May 21, 2020
- (7) Fire pump house on May 28, 2020
- (8) Fire Zone 83: Unit 1 main turbine lube oil room on June 4, 2020
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room during the post maintenance testing of the steam driven AFW pump while other surveillance activities were also being conducted on April 30, 2020
- (2) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room during fast shutdown and subsequent cooldown due to a high RCS leak rate on May 1, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;
- (1) Scheduled Unit 1 and Unit 2 work planned and scheduled for the week of May 25, 2020
- (2) Unit 2 elevated risk due to planned essential service water (ESW) work on June 2, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 2020-3367, Train A Reserve Feed Inoperable on April 17, 2020
- (2) AR 2020-3408, Unit 2 Train A Lower Igniter Circuit Failed on April 20, 2020
- (3) AR 2020-3380, Loop 2 Delta T Low Alarm in Unit 2
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Replacement motor for 12-Pp-31s-Mtr - south spent fuel pit pump motor as documented in Engineering Change (EC) 0000056938 on May 27, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
(1)12-OHP-4030-018-130S; south spent fuel pit pump surveillance test after pump replacement on May 25, 2020
- (2) West motor driven AFW system test on June 9, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated plant response activities to a high Unit 2 reactor coolant leakrate and susbsquent plant recovery and restart from May 1 to May 10, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Steam generator stop valve dump valve surveillance test on May 18, 2020
- (2) Unit 1 west motor driven auxiliary feedwater AFW system test on June 9, 2020
- (3) Steam generator level calibration set points on June 17, 2020
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) Unit 2 West RHR operability test on May 14, 2020
- (2) Unit 2 East ESW system test on June 3, 2020
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the following maintenance and testing of the alert and notification system:
- 2018 Annual Siren Maintenance
- 2019 Annual Siren Maintenance
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (3 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit 2 lower containment gaseous effluent monitoring system to station vent, including the containment lower compartment train 'A' radiation monitor (2-ERS-2300)and associated sampling lines
- (2) Unit 2 Steam Jet Air Ejector gaseous effluent system to discharge, including the exhaust noble gas activity monitor (SRA-2900) and associated sample lines
- (3) Unit 2 Gland Seal gaseous effluent system to discharge, including the exhaust noble gas activity radiation monitor (SRA-2800) and associated sample lines
Sampling and Analysis (IP Section 03.02) (4 Samples)
- (1) Inspectors evaluated the compensatory sampling program requirements and implementation
- (2) Inspectors evaluated the gaseous effluent sampling system and processing from the Unit 2 station vent to ensure representative samples were obtained
- (3) Inspectors evaluated the gaseous effluent sampling system for the Unit 2 lower containment to ensure representative samples were obtained
- (4) Inspectors evaluated the effluent sampling for batch liquid effluents from the monitor tank to ensure representative samples were obtained
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) February 2020 Liquid and Gaseous Effluent
- (2) March 2020 Liquid and Gaseous Effluent
Abnormal Discharges (IP Section 03.04) (1 Sample)
- (1) There were no abnormal discharges for the inspectors to evaluate during the inspection period
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
(1)3rd quarter 2019 through 1st quarter 2020
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) 3rd quarter 2019 through 1st quarter 2020
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
(1)3rd quarter 2019 through 1st quarter 2020
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)1st quarter 2019 through 1st quarter 2020
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the Unit 2 reactor coolant system leakrate of approximately eight gpm and licensees response on May 1,
INSPECTION RESULTS
Unresolved Item (Closed)
Qualification Basis for Safety-Related Relays and Motor-Starter Contactors URI 05000315,05000316/2012007-02 71111.21M
Description:
During the 2012 Component Design Bases Inspection (CDBI) the inspectors identified an unresolved item (URI)05000315/2012007-02 and 05000316/2012007-02, regarding the licensees actions to maintain or extend the life of safety-related relays and motor-starter contactors beyond the vendor recommended service life. Specifically, the licensee did not have a program in place to ensure that safety-related relays and motor starter contactors were replaced or evaluated as acceptable for continued service before the component exceeded the vendor recommended life. Based on the inspectors questions, the licensee initiated AR 2012-9701, Condition not Adverse to Quality, on August 8, 2012, to investigate the impact of service life on the General Electric (GE) HFA, HEA and HGA relays and motor contactor operability.
The inspectors reviewing the issue recently, noted that, a Preventive Maintenance (PM)
Strategy and basis for all Critical and Non-Critical safety-related relays was developed by the licensee as part of a PM Optimization effort in 1998. The PM Optimization documents stated that the licensee will replace these relays, as required. Additional actions were taken after the 2012 NRC Inspection report to evaluate the service life of GE relays. Report 51-9219913-000 was issued in January 2014, which evaluated GE HEA, HFA, HGA relay service life to be at least 61 years. D.C. Cook Plant has operated less than 61 years and their current operating license will expire at 60 years. Therefore, there was no issue with the replacement frequency of the aforementioned GE relays. Also, the inspectors noted that, a PM Strategy and basis for all Critical and Non-Critical safety-related Agastat relays was developed by the licensee as part of a PM Optimization effort in 2000. PM Optimization documentation discussed DIT-S-00425-00, which evaluated Agastat relay service life beyond 100 years, based on various thermal degradation analysis. However, based on industry operating experience, the licensee had created PMs as of June 26, 2000, to replace the Agastat relays between 10 to 15 years based on their service conditions. The inspectors reviewed selected work orders and verified that the licensee has been replacing some Agastat relays at nine-year intervals. The inspectors noted that Agastat relay replacement program existed at D.C. Cook Plant before 2012 and was not an issue of concern. In the case of motor-starter contactors, the inspectors noted that, a PM strategy and basis for all Critical and Non-Critical safety-related motor-starter contactors was developed by the licensee in 2011, which called out a 10 year Motor Control Center (MCC) enclosure inspection task in procedure 12-IHP-5030-EMP-013 (Electrical Enclosure 10-Year Preventive Maintenance) to detect the need to replace motor-starter contactors. A review of safety-related motor-starter contactor PMs created on September 24, 2000, identified as needed replacement tasks for motor-starter contactors existed prior to 2012.
Based on the review of all the documents mentioned above and the lack of substantial in-service failure history, the inspectors reasonably reached a conclusion that, the licensee appears to have established programmatic controls to effectively manage and implement safety-related relay and motor-starter contactor life cycle. The inspectors did not identify any violation of NRC requirements and therefore, this URI is closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 1, 2020, the inspectors presented the integrated inspection results to Mr. J. Gebbie, Senior VP and Chief Nuclear Officer and other members of the licensee staff.
- On June 2, 2020, the inspectors presented the Emergency Preparedness Program Inspection Exit Meeting inspection results to Mr. J. Gebbie, Senior VP and Chief Nuclear Officer and other members of the licensee staff.
- On June 25, 2020, the inspectors presented the radiation protection baseline inspection results to Mr. S. Lies, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Assessment of Response to Information Request - Flood
Causing Mechanism Reevaluation
06/15/2017
Flood Hazard Reevaluation Report MD-12-Flood-011-N
Procedures
PMP-5091-FLD-
001
Flood Protection Program Implementation
Drawings
OP-2-5143-75
Emergency Core Cooling Unit 2
Procedures
1-OHP-4030-156-
017E
East MDAFP Valve Lineup
1-OHP-4030-156-
017T
TDAFP Valve Lineup
2-OHP-4021-008-
2
Placing Emergency Core Cooling System in Standby
Readiness
Fire Plans
Pre-Fire Plans
Volume 1
Fire Zone 83 Turbine Building Unit 1 Lube Oil Room Elev.
591-0
Pre-Fire Plans
Volume 1
4KV AB Switchgear Room Unit 1 Elevation 609'
Pre-Fire Plans
Volume 1
4KV CD Switchgear Room Unit 1 Elev. 609'
Pre-Fire Plans
Volume 2
Fire Pump House
Miscellaneous
Cook Unit 1 and 2 Online Risk Cycle 114 Week 09
05/26/2020
Cook Nuclear Plant Key Maintenance and Testing Schedule
05/26/2020
Corrective Action
Documents
20-4967
Degraded ESW Pipe Downstream of 1-WMO-715
AR 2020-4967
Degraded ESW Pipe Downstream of 1-WMO-715
06/17/2020
Operability
Evaluations
SFD-1-2020-17
Safety Function Determination - Degraded ESW Pipe
Downstream of 1-WMO-715
06/17/2020
Calculations
MD-12-SFP-007-
N
Minimum Performance Required for the Spent Fuel Pumps
(SFP)
Engineering
Changes
Replacement Motor for 12-PP-31S-MTR-South Spent Fuel
Pit Pump Motor
Procedures
2-OHP-4021-
018-002
Placing in Service and Operating the South Spent Fuel Pit
Cooling and Cleanupp System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2-OHP-4030-
018-130S
South Spent Fuel Pit Pump Surveillance Test
2-OHP-4030-208-
051S
South Safety Injection Pump Test
2-OHP-4030-219-
2E
East Essential Service Water System Test
2-OHP-4030-256-
017T
Turbine Driven Auxiliary Feedwater System Test
Work Orders
229305-01
2-4X1-TDFP, Pick Up/Drop Out Testing on HFA Relay
04/29/2020
55532046-01
Calibrate 2-62-TFL
04/29/2020
55534565-01
MTI, 2-FFS-259, Calibrate Flow Switch
04/30/2020
71111.21M Engineering
Evaluations
DIT-S-00425-00
Evaluation for Validity of Service Life Extension of Agastat
7000 and E 7000 Series of Relays
2/29/2000
Miscellaneous
None
Relays Preventive Maintenance Optimization: Timing Relays
_ Agastat
07/14/2003
TR-106857-V29
Preventive Maintenance Basis, Volume 29: Relays -
Protective; Prepared by Applied Resource Management for
Electric Power Research Institute (EPRI)
07/30/1998
TR-106857-V31
Preventive Maintenance Basis, Volume 31: Relays - Timing;
Prepared by Applied Resource Management for EPRI
07/30/1998
Procedures
PMP-5030-001-
003
Preventive Maintenance
Work Orders
55516970
MTI, 2-62-1 MDFP; Replace, Calibrate and PMT Agastat
Relay
10/15/2019
55516970
MTI, 2-62-WMFL; Replace, Calibrate and PMT Agastat
Relay
10/15/2019
55527320
1-88X-DERH16; Replace Degraded Starter
01/23/2019
55530721
MTE: 1-ABD-C-3C, Replace Starter 1-88X-LQBA-CD
04/06/2019
Procedures
1-OHP-4030-151-
018
Steam Generator Stop Valve Dump Valve Surveillance Test
1-OHP-4030-156-
017W
West Motor Driven Auxiliary Feedwater System Test
2-OHP-4030-217-
050W
West Residual Heat Removal Train Operability Test Modes
1-4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
55547538-01
Perform 1-OHP-4030-156-017W
06/09/2020
Corrective Action
Documents
AR 2019-10340
Siren Testing
10/23/2019
AR 2019-10813
Siren 1104-Partial Failure and 1152 Failed Monthly Test
11/02/2019
AR 2019-10816
Siren 1104-Partial Fail and 1152 Failure
11/02/2019
AR 2019-11012
Driver/Amp Failure; Siren #: 1152, Driver/Amp Partial; Siren
11/06/2019
AR 2020-0969
01/29/2020
Miscellaneous
AEP-ANS-2017-1
Alert and Notification System Design Report
05/19/2017
PMP-2080-EPE-
001
Alert and Notification System Equipment Inspection and
Maintenance
Corrective Action
Documents
AR 2019-12245
Unannounced ERO Drill Response Time Greater Than
Expectation
2/17/2019
AR 2020-1676
ERO Qualification not Active
2/19/2020
AR 2020-1704
ERO Qualification not Active
2/19/2020
AR 2020-1877
ERO Qualification Process and Tracking in PQM
2/24/2020
AR 2020-1878
Timely Reporting of EP Qualification Issues
2/24/2020
Miscellaneous
June 18, 2019 Unannounced Drive-In Augmentation Drill
Evaluation Report
06/26/2019
November 2, 2018 Unannounced Drive-In Augmentation
Drill Evaluation Report
01/18/2019
Unannounced All-Call Drill (Call Only) Evaluation Report
01/30/2020
Corrective Action
Documents
AR 2018-10645
Revise Table B-1 in Cook E-Plan
11/26/2018
AR 2019-1746
ERO Drill Critique Process
2/25/2019
AR 2019-1864
PMP-2080-EPE-002 Responsibilities
2/28/2019
AR 2020-1047
Gland Seal Effluent RMS High Range Reading
01/31/2020
AR 2020-1609
Compensatory Actions for PAS (CR 2019-0281)
2/17/2020
AR 2020-1771
Cook Emergency Plan References to RMA-2080-EPA-008
2/20/2020
PMP-2080-EPP-
101
Emergency Classification
Miscellaneous
Donald C. Cook Nuclear Plant Emergency Plan
NOS-19-02
Nuclear Oversight Audit-Emergency Preparedness
04/19/2019
NOS-20-03
Nuclear Oversight Audit-Emergency Preparedness
04/08/2020
Corrective Action
Documents
AR 2017-1247
Investigate Differences in Skin Dose Factors
2/01/2017
AR 2019-1165
Env. Staff Did Not Fully Correct the Identified Condition
2/05/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AR 2020-1047
Gland Seal Effluent RMS High Range Reading
01/31/2020
Miscellaneous
U2 Vent Stack Sample Analysis
06/25/2020
2019 Annual Radioactive Effluent Release Report
04/29/2020
2018 Annual Radioactive Effluent Release Report
04/29/2019
Liquid Effluent Monitor Tank Number 3 Release
Documentation
06/24/2020
2018 Land Use Census
09/28/2018
2019 Land Use Census
09/30/2019
Unit 2 Lower Containment Atmosphere Effluent Sample
Analysis
06/25/2020
Procedures
2-OHP-4021-
006-004
Transferring Distillate from Monitor Tanks
2-THP-6020-
CHM-308
Effluent Batch Releases
2-THP-6020-
CHM-322
Vent Stack Gaseous Sampling
PMP-6010-OSD-
001
Offsite Dose Calculation Manual
14-15, 26
71151
Miscellaneous
First Quarter 2019 through First Quarter 2020 RETS-ODCM
PI Validation Documents
Various
NRC Performance Indicator Data; Emergency Preparedness
- Drill/Exercise Performance
3rd quarter
2019 through
1st quarter
20
NRC Performance Indicator Data; Emergency Preparedness
- Alert and Notification System
3rd quarter
2019 through
first quarter
20
NRC Performance Indicator Data; Emergency Preparedness
- ERO Participation
3rd quarter
2019 through
1st quarter
20