IR 05000315/2022003
| ML22301A168 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/28/2022 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DORS/ERPB |
| To: | Lies Q Indiana & Michigan Electric Co |
| References | |
| IR 2022003 | |
| Download: ML22301A168 (21) | |
Text
SUBJECT:
DONALD C. COOK NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000315/2022003 AND 05000316/2022003
Dear Mr. Lies:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant. On October 12, 2022, 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.
Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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 Donald C. Cook Nuclear Plant.
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 Nuclear Plant.
October 28, 2022 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, Néstor J. Féliz Adorno, Chief Engineering and Reactor Projects Branch Division of Operating 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:
05000315/2022003 and 05000316/2022003
Enterprise Identifier:
I-2022-003-0047
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Plant
Location:
Bridgman, MI
Inspection Dates:
July 01, 2022 to September 30, 2022
Inspectors:
S. Bell, Health Physicist
J. Mancuso, Resident Inspector
P. Zurawski, Senior Resident Inspector
Approved By:
Néstor J. Féliz Adorno, Chief
Engineering and Reactor Projects Branch
Division of Operating Reactor Safety
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
Failure to Apply Design Control Measures to a Design Change Results in Loss of Auxiliary Building Barrier Integrity Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000315,05000316/2022003-01 Open/Closed None (NPP)71111.12 A finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III,
Design Control, was self-revealed for the licensees failure to subject the change of the auxiliary building pyrojectors locking device to design control measures commensurate with those applied to its original design. As a result, the locking devices of three pyrojectors eventually failed causing the pyrojectors to open during fuel handling operations. This condition resulted in the required fuel handling area exhaust ventilation (FHAEV) train to be inoperable, which was contrary to Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.13.
Failure to Ensure Correct Operation of the Meteorological Tower Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000315,05000316/2022003-02 Open/Closed
[P.5] -
Operating Experience 71124.07 An NRC identified finding of very low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1 for the failure to implement and maintain procedures to ensure adequate operation of the meteorological tower. Specifically, the licensee failed to implement and maintain procedures that included the assessment, and when necessary, removal of vegetation to ensure correct operation of the meteorological tower.
Water Discovered on Safety Related Battery Charger Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000316/2022003-03 Open/Closed
[H.5] - Work Management 71152A A finding of very low safety significance (Green) with an associated non-cited violation (NCV)of Technical Specification (TS) 5.4, Procedures, was self-revealed for the licensees failure to implement procedure PMP-5020-LCD-001, Control of Leak Collection Devices.
Specifically, the licensee removed a leak collection device installed over the 2-BC-B N-train battery charger prior to installation of the permanent fix. Nothing was put in place to protect the charger in the interim, which resulted in water dripping onto the battery charger causing it to become inoperable.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On August 28, 2022, the unit was removed from service due to a reactor coolant pump electrical issue. After repairs, Unit 1 power was restored to rated thermal power on September 5, 2022. Unit 2 began the inspection period at rated thermal power with power reduced to approximately 90 percent power on August 16 and 31, 2022, for turbine valve testing. Power was restored on August 18 and September 3, 2022, respectively. On September 28, 2022, power was reduced to approximately 58 percent in preparation for a refueling outage. The unit was removed from service on October 1,
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from an impending K7/G3 strong geomagnetic storm on August 16, 2022
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) North/south spent fuel pool heat exchangers on August 15, 2022 (2)2-BC-AB1 battery charger during 2-BC-AB2 maintenance on August 15, 2022
- (3) Unit 1 & 2 emergency diesel generators (EDGs) due to supplemental diesel generator maintenance on August 18, 2022
- (4) Unit 2 Train B distributed ignition system on September 7, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 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 17D; east auxiliary feed pump room, Unit 1, elevation 591' on July 19, 2022
- (2) Fire Zone 46C; emergency power system motor control room, Unit 2, elevation 609' on July 19, 2022
- (4) Fire Zone 64B; safety injection pump south, Unit 1, elevation 587' on July 21, 2022
- (5) Fire Zone 51; auxiliary building, elevation 633' on July 21, 2022
- (6) Fire Area AA 5/6; auxiliary building, elevation 587' on September 7, 2022
- (7) Fire Zones 42D & 46D; emergency power system Unit 1 & 2 AB battery rooms on September 15, 2022
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Turbine building, elevation 591' on August 11, 2022
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Unit 1 Control Room during startup from a forced outage on September 4, 2022
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification RQ-S-4704-U2-T2 in the facility's simulator on August 25, 2022
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Loss of auxiliary building integrity on May 4, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 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) Unit 1 east diesel driven fire pump emergent work on July 11, 2022
- (2) Unit 2 CD EDG failed surveillance and emergent work on July 13, 2022
- (3) Work Week Cycle 123, Week 07 with supplemental diesel work window and K7/G3 geomagnetic storm predicted on August 16, 2022
- (4) Work Week Cycle 123, Week 09 with Unit 1 forced outage on August 29, 2022 (5)2-OME-90-RO hydraulic operator actuator leak on August 31, 2022
- (6) Work Week Cycle 123, Week 11 with Unit 2 motor driven auxiliary feedwater pump work on September 12, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (2) AR 2022-5912; Unit 1 Ice Deck Door Blocked from Opening on July 20, 2022
- (3) AR 2022-6251; Gas Voids Identified in Emergency Core Cooling System on August 3, 2022
- (4) AR 2022-6432; Unit 1 'A' Lower Distributed Ignition System Failure on August 11, 2022
- (5) AR 2022-6991; Suspected Essential Service Water Leak on 1-HV-AFP-T2AC, Unit 1 Turbine Driven Auxiliary Feedwater Pump Room Cooler on September 2, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- 13 reactor coolant pump cabling following repair on September 2, 2022 (3)2-OME-90-RO hydraulic operator actuator leak on September 7, 2022
- (4) Unit 2 distributed ignition system following planned work on September 7, 2022
- (5) Unit 2 west motor driven auxiliary feedwater pump following planned work on September 14, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated a Unit 1 automatic reactor trip due to the #13 reactor coolant pump cable failure from August 28 through September 5, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2 main steam safety valve TREVI testing on September 28, 2022
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Training Evaluation RQ-S-4704-U1-T2 on September 8,
RADIATION SAFETY
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 1 (July 1, 2021 through June 30, 2022)
- (2) Unit 2 (July 1, 2021 through June 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1 (July 1, 2021 through June 30, 2022)
- (2) Unit 2 (July 1, 2021 through June 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (April 1, 2021 through June 30, 2022)
- (2) Unit 2 (April 1, 2021 through June 30. 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) July 1, 2021 through June 30, 2022 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) April 1, 2021 through June 30, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) AR 2022-1468; 2-BC-B-N-Train battery charger failure on July 5, 2022
- (2) Unit 1 #13 reactor coolant pump cable failure on September 2,
INSPECTION RESULTS
Failure to Apply Design Control Measures to a Design Change Results in Loss of Auxiliary Building Barrier Integrity Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000315,05000316/2022003-01 Open/Closed None (NPP)71111.12 A finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, was self-revealed for the licensees failure to subject the change of the auxiliary building pyrojectors locking device to design control measures commensurate with those applied to its original design. As a result, the locking devices of three pyrojectors eventually failed causing the pyrojectors to open during fuel handling operations. This condition resulted in the required fuel handling area exhaust ventilation (FHAEV) train to be inoperable, which was contrary to Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.13.
Description:
The D.C. Cook auxiliary building has a series of pyrojectors that were originally intended to mitigate fires in the auxiliary building. These pyrojectors were originally held closed with a fuseable link in order to facilitate opening during times of intense heat. However, based on health physics considerations, the licensee removed the opening function of the pyrojectors during a fire by replacing the fuseable links with chains. These chains were subsequently changed to stainless-steel wiring to keep the pyrojectors closed during normal operation but allowing them to be opened in the case of fires that did not involve radiological hazards.
On May 3, 2022, individuals performing work on the spent fuel pool floor of the auxiliary building identified that rain was pooling on the floor from an opening overhead. The control room was notified, and operators immediately declared the required FHAEV train inoperable and entered Condition A of TS LCO 3.7.13. This LCO required one FHAEV train to be operable and in operation during movement of irradiated fuel assemblies in the auxiliary building. The auxiliary building boundary needed to be closed to support FHAEV operability.
An LCO note stated that the auxiliary building boundary may be opened intermittently under administrative control. Because the auxiliary building was not opened under administrative control, Condition A required the licensee to immediately suspend movement of irradiated fuel assemblies in the auxiliary building.
Licensee personnel were dispatched and discovered three of the pyrojectors on the roof of the auxiliary building had broken stainless-steel wiring and opened during the inclement weather. Licensee Maintenance Rule Evaluation AR 2022-3902-5 found that the failure of the stainless-steel wiring was due to a lack of design control measures when the licensee changed the linkage on the pyrojectors from the original fuseable links to the stainless-steel wiring. The licensee determined that, Had there been a proper design performed prior to the installation of the stainless-steel wiring the fatigue stresses would have been understood and an inspection plan could have been implemented.
Corrective Actions: The licensees immediate corrective actions included suspending movement of irradiated fuel assemblies in the auxiliary building and sealing the pyrojectors by installing stainless-steel ties on the vents.
Corrective Action References: AR 2022-3902
Performance Assessment:
Performance Deficiency: The licensee failure to subject the change of the auxiliary building pyrojectors locking device to design control measures commensurate with those applied to its original design was contrary to 10 CFR 50, Appendix B, Criterion III, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Structure, System, or Component (SSC) and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the performance deficiency resulted in the opening of three pyrojectors causing a loss of auxiliary building integrity, a physical design barrier intended to protect the public from radionuclide releases caused by accidents or events, during fuel handling operations.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as having very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the auxiliary building.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion III, states, in part, that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design. It also states that the design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Contrary to the above, circa November 2012, the licensee failed to subject the change of the auxiliary building pyrojectors locking device to design control measures commensurate with those applied to its original design. Specifically, the licensee changed the design of the locking devices with stainless-steel wiring without implementing design control measures to verify its adequacy. As a result, the new failure mechanism was not understood and managed causing three of the pyrojectors to open resulting in the loss of auxiliary building integrity during fuel handling operations on May 3, 2022. This condition caused the required FHAEV train to be inoperable and, thus, an unplanned entry into TS LCO 3.7.13, Condition A.
The timeframe of this violation was approximated with the best available information at the time of this inspection.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Ensure Correct Operation of the Meteorological Tower Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000315,05000316/2022003-02 Open/Closed
[P.5] -
Operating Experience 71124.07 An NRC identified finding of very low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1 for the failure to implement and maintain procedures to ensure adequate operation of the meteorological tower. Specifically, the licensee failed to implement and maintain procedures that included the assessment, and when necessary, removal of vegetation to ensure correct operation of the meteorological tower.
Description:
The inspectors performed walkdowns of the meteorological tower during the week of August 1, 2022. Meteorological data is a parameter in the calculation of radiation dose received by the public during both normal operation and during potential accident conditions. The inspectors observed the growth of trees in close proximity north of the tower.
Trees may interfere with operation of the tower by changing wind conditions (wind speed and wind direction) resulting in reported data that may not be indicative of actual meteorological data. The concern is for the sensors located at 10 meters in height on the tower.
The NRC provides guidance to licensees in the form of Regulatory Guides. These Regulatory Guides provide approved method(s) but not required methods to perform various tasks. Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, Revision 1, states in part, Whenever possible, wind measurements should be made at locations and heights that avoid airflow modifications by obstructions such as large structures, trees, and nearby terrain. The sensors should be located over level, open terrain at a distance of at least 10 times the height of any nearby obstruction if the height of the obstruction exceeds one-half the height of the wind measurement. Wind sensors should be located on top of the measurement tower or mast or extended outward on a boom to reduce airflow modification and turbulence induced by the supporting structure itself.
ANSI/ANS-3.11-2015, "Determining Meteorological Information at Nuclear Facilities," also provides information on obstructions associated with meteorological towers.
The inspectors reviewed licensee procedures that governed the tower operation and maintenance. These procedures failed to address the assessment and when necessary, the removal of vegetation to ensure proper function of the meteorological instrumentation.
Corrective Actions: The licensee plans on establishing procedural guidance to include the assessment of vegetation, and, when necessary, removal of vegetation to ensure adequate meteorological tower operation.
Corrective Action References: AR 2022-6282
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to implement and maintain procedures that included the assessment and when necessary, removal of vegetation to ensure correct operation of the meteorological tower was within the licensees ability to foresee and correct and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the failure to ensure that obstructions do not impact the function/accuracy of meteorological sensors may impact the licensees assessment of dose to the public from airborne radioactive releases.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The violation was of very low safety significance (Green) because it was not a failure to implement the Effluent Program, nor did dose exceed Appendix I or 10 CFR 20.1301(e) criteria.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The licensee did not use industry nor externally available information on this subject.
Enforcement:
Violation: TS 5.4.1 states in part that, "Written procedures or instructions shall be established, implement and maintained covering the following activities: a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978." Section 7 of this document, addresses, "Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure)," and Section 7h, addresses, "Meteorological Monitoring."
Contrary to the above, as of August 4, 2022, the licensee failed to establish a procedure to address the activities covered in Regulatory Guide 1.33, Appendix A, Section 7h.
Specifically, the licensee failed to establish procedure(s) to include provisions for the assessment and when necessary, removal of vegetation to ensure the correct operation of the meteorological tower.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Water Discovered on Safety Related Battery Charger Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000316/2022003-03 Open/Closed
[H.5] - Work Management 71152A A finding of very low safety significance (Green) with an associated non-cited violation (NCV)of Technical Specification (TS) 5.4, Procedures, was self-revealed for the licensees failure to implement procedure PMP-5020-LCD-001, Control of Leak Collection Devices.
Specifically, the licensee removed a leak collection device installed over the 2-BC-B N-train battery charger prior to installation of the permanent fix. Nothing was put in place to protect the charger in the interim, which resulted in water dripping onto the battery charger causing it to become inoperable.
Description:
On February 22, 2022, the Unit 2 Control Room received an alarm for low voltage on the 2-BC-B N-train battery charger. An auxiliary operator was dispatched to the location and identified that water was dripping on to the charger from scaffolding that was constructed as part of a project to install a permanent leak catch device. The N-train direct current distribution system in each unit provides direct current electrical power primarily to circuits associated with the turbine driven auxiliary feedwater system. The main components of the system are the battery, two chargers, and the electrical distribution components that provide power to the loads. Visual inspection by the licensee revealed that both the exterior and interior of the charger were wet. The charger was declared inoperable. However, the associated TS Limiting Condition for Operation (LCO) was met when the licensee swapped to the redundant 2-BC-A charger, which remained dry. The licensee took action to shield the 2-BC-B charger from the leak above and then dried it out. A surveillance test confirmed that drying the 2-BC-B charger restored it to an operable condition.
The licensee had previously identified this leak location on May 6, 2016, and documented this discovery in their corrective action program as AR 2016-5697. This AR described the leak rate as 20 drops per minute that, "could increase with more severe rain." The licensee determined that the 2-BC-B charger could remain operable, but a leak collection device was needed until completion of roof repairs. Licensee personnel installed a temporary leak collection device but failed to follow the process that provides administrative controls for leak collection devices. Specifically, procedure PMP-5020-LCD-001, Control of Leak Collection Devices, Revision 13, requires records of leak collection device locations. In December of 2021, the temporary shield was removed during construction of scaffolding needed to complete construction of a permanent leak collection device. Nothing was put in place to protect the charger in the interim. On February 22, 2022, inclement weather caused leakage onto the charger causing it to be inoperable.
Corrective Actions: The initial corrective actions were to swap to the 2-BC-A N-train battery charger while the 2-BC-B N-train battery charger was repaired. At the time of this inspection period, the licensee planned to install the permanent shielding for the 2-BC-B N-train battery charger as a long-term corrective action.
Corrective Action References: AR 2022-1468
Performance Assessment:
Performance Deficiency: The removal of the leak collection device over the 2-BC-B N-train battery charger was contrary to Revision 13 of Procedure PMP-5020-LCD-001, Control of Leak Collection Devices.
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, failure to properly control the leak collection device via site procedure led to the failure of the safety related N-train power subsystem and subsequent inoperability of the charger.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as Green, or very low safety significance, because the inspectors answered no to the Exhibit 2, Section A questions in IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated December 20, 2019.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee did not plan, control, and executed the installation of the scaffold such that the leak control device remained in place to reasonably protect the battery charger.
Enforcement:
Violation: TS 5.4, Procedures, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance, requires, in part, that maintenance that can affect the performance of safety related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to this requirement, from December 2021 to February 22, 2022, the licensee failed to implement a written procedure recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, the licensee failed to implement Revision 13 of Procedure PMP-5020-LCD-001, Control of Leak Collection Devices. Step 3.7 of the procedure states that, When necessary repairs are complete, then the work group responsible for the repair should verify the LCD has been removed and discarded. Licensee procedure PMP-2010-PRC-001, Revision 37, defined the term verify as to observe an expected condition exist and stated that the appropriate contingency was to establish the expected condition. However, the work group responsible for the repair associated with the leak removed and discarded the leak collection device protecting the 2-BC-B N-train battery charger before completing the repair. Since the charger remained unprotected from the leak, during inclement weather on February 22, 2022, the charger was soaked with water and declared inoperable. The leak collection device was removed when installing a scaffold as part of corrective maintenance activities related to the repair.
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 October 12, 2022, the inspectors presented the integrated inspection results to Mr. Q. S. Lies, Senior VP and Chief Nuclear Officer, and other members of the licensee staff.
On August 4, 2022, the inspectors presented the radiation protection baseline inspection results to Mr. Q. S. Lies, Senior VP and Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OHI-4000
Conduct of Operations: Standards
133
PMI-2291
Work Control Process
25
Procedures
PRA-FIRE-OLR-
BASIS
Fire Risk Significance and Risk Management Actions for
10CFR 50.65(a)(4) Online Risk Assessments
001
Drawings
OP-2-12035
Distribution Panel Auxiliary One-Line Diagram 600V Bus
21C, 21D Engineered Safety System (Train A)
1-OHP-4021-032-
001CD
DG1CD Operation
051
1-OHP-4021-032-
008AB
Operating DG1AB Subsystems
035
2-OHP-4021-
018-002
Placing in Service and Operating the Spent Fuel Pit Cooling
and Cleanup System
035
2-OHP-4021-032-
001AB
DG2AB Operation
061
2-OHP-4021-032-
001CD
DG2CD Operation
051
2-OHP-4021-082-
006
Operation of 2AB and 2CD Battery Chargers
BATTERY CHARGERS
013
Procedures
OP-2-12015
Distribution Panel Auxiliary One-Line Diagram 600V Bus
21A, 21B Engineered Safety System (Train B)
20
Fire Plans
Fire Zones 17D,
2D, 46C, 46D,
47A, 51, 64B
Fire Pre-Plans Volume 1
MD-12-FLOOD-
001-S
Externally Sourced Flooding Walkdown Report
PRA-FLOOD-004
Internal Flooding - Qualitative Screening Analysis
Calculations
PRA-FLOOD-008
Flood Sources and the Associated Flood Mechanisms
2-OHP-4027-
FSG-1501,
Flood Program Deployment
Procedures
PMP-5091-FLD-
001
Flood Protection Program Implementation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
RQ-S-4704-U1-
T1
Period 4704 U1 Training Scenario 1
22-3902
Aux Building Bent on 650' Elevation Opened During
Refueling
05/03/2022
Corrective Action
Documents
22-5648
2-PP-145 East Diesel Fire Pump Outboard Bearing
Packing Smoked During Surveillance Run
07/09/2022
Calibration
Records
22-5752
CD EDG Fail Surveillance
07/12/2022
Corrective Action
Documents
AR 2022-6432
Unit 1 'A' Lower DIS Failure
08/10/2022
Unit Risk Reports - Work Week Cycle 123, Week 07
Unit Risk Reports - Work Week Cycle 123, Week 11
Miscellaneous
Unit Risk Reports - Work Week Cycle 123, Week 09
Calculations
MD-12-ESW-
2N
Impact of ESW Supply Header Crosstie Shutoff Valve
Leakage on the ESW System
AR 2022-5752
2CD EDG Fail Surveillance 7/12/22
07/12/2022
AR 2022-5912
U1 ICE Deck Door Blocked from Opening
07/20/2022
AR 2022-6251
Gas Voids Identified in WCCS
08/03/2022
AR 2022-6290
Gas Voids Identified During ECCS Void Inspection
08/03/2022
AR 2022-6432
Unit 1 'A' Lower DIS Failure
08/10/2022
AR 2022-6929
2-OME-90-RO HYDRAULIC OPERATOR ACTUATOR EHC
Leak
08/31/2022
Corrective Action
Documents
AR 2022-6991
Suspected ESW Leak on 1-HV-AFP-T2AC, U1 TDAFP Rm
Cooler #2
09/02/2022
Operability
Evaluations
AR 2022-6251
Compensatory Action for ODE Associated With Gas Voids
Were Identified in the Train A Emergency Core Cooling
System ECCS)
08/08/2022
1-IHP-4030-134-
001
Train 'A' Lower Ignitor Circuit Testing
Procedures
PMP-4030-001-
001
Impact of Safety Related Ventilation on the Operability of
Technical Specification Equipment
037
AR 2022-6828
Unit 1 Reactor Trip, RCP 13 Trip
08/28/2022
AR 2022-6828-09
Maintenance Rule Evaluation AR 2022-6828 - RCP 13 Trip
09/28/2022
Corrective Action
Documents
AR 2022-6929
2-OME-90-RO Hydraulic Operator Actuator EHC Leak
08/31/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
PMP-4010-TRP-
001
Unit 1 Reactor Trip Review Report (AR 2022-6828-16)
08/30/2022
2-IHP-4030-234-
001
Unit 2 DIS Surveillance Testing
2-OHP-4030-256-
017W
West Motor Driven Auxiliary Feedwater System Test
09/14/2022
Procedures
OHI-6080
Emergency Diesel Generator Logs
07/21/2022
10038191
2-OME-90-RO Hydraulic Operator Actuator EHC Leak
Work Orders
C10037961033
1-1191PG-1/1-1192PG-1: Megger for Final PMT
09/02/2022
AR 2022-6828
Unit 1 Reactor Trip, RCP 13 Trip
08/28/2022
Corrective Action
Documents
AR 2022-6828-09
Maintenance Rule Evaluation AR 2022-6828 (Unit 1 Reactor
Trip - RCP 13 Trip)
09/28/2022
Miscellaneous
PMP-4010-TRP-
001
Unit 1 Reactor Trip Review Report (AR 2022-6828-16)
08/30/2022
Procedures
2-EHP-4030-
051-256
Main Steam Safety Valve Setpoint Verification with Lift
Assist Device
09/29/2022
June 28, 2022 Emergency Response Drill Scenario
Miscellaneous
RQ-S-4704-U1-
T2
Period 4704 U1 Training Scenario 2
AR 2021-0996
Offsite Vendor Refurbishment of Wind Speed Sensors
01/28/2021
Corrective Action
Documents
AR 2022-1996
4th Quarter REMP Sampling Deviations
03/15/2022
Corrective Action
Documents
Resulting from
Inspection
AR 2022-6282
Failure to Implement/Maintain Procedures for the
Meteorological Tower
08/04/20222
2018 Annual Radioactive Effluent Release Report
04/29/2019
2018 Annual Radiological Environmental Operating Report
04/29/2019
2019 Annual Radioactive Effluent Release Report
04/29/2020
2019 Annual Radiological Environmental Operating Report
05/14/2020
20 Annual Radioactive Effluent Release Report
04/28/2021
20 Annual Radiological Environmental Operating Report
05/12/2021
21 Annual Radioactive Effluent Release Report
04/29/2022
Miscellaneous
21 Annual Radiological Environmental Operating Report
05/13/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ODCM Revisions 25 Through 27 Approval Documents
Various
2-IHP-4030-036-
001
Meteorological Instrumentation Primary and Backup Towers
Channel Calibration
2-IHP-6030-036-
001
Shoreline Weather Tower Instrument Calibration
Procedures
PMP-6010-OSD-
001
Offsite Dose Calculation Manual
- 27
Work Orders
Cl0002667001
2-IHP-4030-036-00l, (12-ETR-400) Primary & Backup
Weather Calibration
03/30/2022
Unit 1 and Unit 2 Reactor Coolant System Dose Equivalent
Iodine Data April 1, 2021 Through June 30, 2022
Various
Radiological Effluent Dose Summary Reports April 1, 2021
Through June 30, 2022
Various
Radiation Protection Performance Indicator Reports July 1,
21 Through June 30, 2022
Various
MSPI Derivation Reports - Heat Removal Systems
(07/01/2021 Through 06/30/2022) - Unit 1
MSPI Derivation Reports - Heat Removal Systems
(07/01/2021 Through 06/30/2022) - Unit 2
MSPI Derivation Reports - Residual Heat Removal
(07/01/2021 Through 06/30/2022) - Unit 2
71151
Miscellaneous
MSPI Derivation Reports - Residual Heat Removal
(07/01/2021 Through 06/30/2022) - Unit 1
AR 2022-1468
2-BC-B-N-Train Battery Charger Failure
2/22/2022
AR 2022-6828
Unit 1 Reactor Trip, RCP 13 Trip
08/28/2022
Corrective Action
Documents
AR 2022-6828-09
Maintenance Rule Evaluation AR 2022-6828 (Unit 1 Reactor
Trip - RCP 13 Trip)
09/28/2022
Miscellaneous
OMO-4010-TRP-
001
Unit 1 Reactor Trip Review Report (AR 2022-6828-16)
08/30/2022