IR 05000315/2024003

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Integrated Inspection Report 05000315/2024003 05000316/2024003 07200072/2024001 and Exercise of Enforcement Discretion
ML24298A098
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/31/2024
From: Matthew Learn
NRC/RGN-III/DORS/ERPB
To: Lies Q
Indiana Michigan Power Co
References
EA-24-078 IR 2024003, IR 2024001
Download: ML24298A098 (1)


Text

SUBJECT:

DONALD C. COOK NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000315/2024003; 05000316/2024003; 07200072/2024001 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Q. Shane Lies:

On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant. On October 8, 2024, 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 did not involve a violation of NRC requirements.

If you disagree with a finding not associated with a regulatory requirement 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 31, 2024 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, Matthew C. Learn, Acting Branch Chief Engineering and Reactor Projects Branch Division of Operating Reactor Safety Docket Nos. 05000315; 05000316 and 07200072 License Nos. DPR58 and DPR74

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000315; 05000316 and 07200072

License Numbers: DPR-58 and DPR-74

Report Numbers: 05000315/2024003; 05000316/2024003 and 07200072/2024001

Enterprise Identifiers: I2024-003-0057 and I2024-001-0130

Licensee: Indiana Michigan Power Company

Facility: Donald C. Cook Nuclear Plant

Location: Bridgman, MI

Inspection Dates: July 01, 2024 to September 30, 2024

Inspectors: N. Audia, Reactor Inspector J. Cassidy, Senior Health Physicist A. Guieb, Project Engineer T. Hooker, Health Physicist E. Kokkinis, Project Engineer J. Kutlesa, Senior Emergency Preparedness Inspector J. Mancuso, Senior Resident Inspector T. Okamoto, Project Engineer D. Sargis, Health Physicist

Approved By: Matthew C. Learn, Acting Branch Chief Engineering and Reactor Projects Branch Division of Operating Reactor Safety

Enclosure

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 Implement Design Control Process Causes Main Turbine Trip Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 FIN 05000315,05000316/2024003-01 Open/Closed A self-revealed finding of very low safety significance (Green) was identified with the licensee's failure to implement a modification to a turbine supervisory instrumentation (TSI)card. Specifically, the licensee failed to correctly implement a modification to the turbine protection system, leading to incorrect inputs included into the turbine trip circuit which led to a main turbine trip and subsequent reactor trip.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000316,05000315/20 Safety-Related Motor 71111.21N.03 Discussed 23011-01 Control Center Bus Bar Commercial Grade Dedication

EDG EA24-078 Failure to Comply with 71124.08 Closed 10 CFR Part 37

LER 05000316/2024-001-00 LER 2024-001-00 for Donald 71153 Closed C. Cook Nuclear Plant, Unit 2, Reactor Trip due to Main Turbine Trip from a High-High Thrust Bearing Position Trip

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On September 27, 2024, Unit 1 reduced power to approximately 90 percent of rated thermal power for main turbine valve testing. The unit returned to full rated thermal power on September 28, 2024, and remained at or near full rated thermal power for the inspection period.

Unit 2 began the inspection period shutdown to address a reactor coolant system leak in excess of the 10 gallons per minute allowed by technical specifications. The unit started up on July 1, 2024, reached full rated thermal power on July 4, 2024, and remained at or near full rated thermal power for the remainder of the 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 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

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 1E motor driven auxiliary feedwater pump (MDAFP) following a surveillance run on July 12, 2024
(2) 2CD emergency diesel generator (EDG) during 2AB EDG work on July 25, 2024
(3) 1CD EDG following planned surveillance on September 4, 2024
(4) 1AB EDG following surveillance run on September 11, 2024
(5) Unit 2 turbine driven auxiliary feedwater pump (TDAFP) during 12AB loop feed enclosure maintenance window on September 19, 2024

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 emergency core cooling (SIS) on August 5, 2024.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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 17A/D Unit 1: auxiliary feed pump rooms and corridor to auxiliary feed pump rooms, both units, elevation 591' on September 3, 2024
(2) Fire Zone 107/50: auxiliary feedwater battery room and HVAC on September 18, 2024
(3) Fire Zone 18: CD diesel generator room, Unit 2, elevation 587' - 0" on September 18, 2024

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on August 15, 2024.

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the Unit 1 safety injection pump room on September 16, 2024.

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 control room during a Unit 1 downpower for main turbine valve functional testing on September 13, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated RQ-E4903 As-found Simulator Training on August 6, 2024.
(2) The inspectors observed and evaluated an As-found Simulator Evaluation Scenario on August 27, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Unit 1 main steam on July 15, 2024
(2) Unit 2 component cooling water (CCW) a(1) action plan on July 8, 2024
(3) EDG frequency issues on July 29, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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) risk management during loop feed enclosure replacement on September 16, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples 1 Partial)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) AR 2024-5435; 1-DCR205 Failed Inservice Test (IST) Stroke Time on July 15, 2024
(2) AR 2024-5371; FLEX Blended RCS Pump Out of Service on July 16, 2024
(3) AR 2023-4337; Indications of Partial Discharge on 12AB Loop Feed Enclosure on July 17, 2024
(4) AR 2024-5322; 2-HV-AFP-T2AC is not working properly on July 17, 2024
(5) AR 2024-6357; Work Order Generation for 2-IMO52 Repack on August 20, 2024
(6) AR 2024-6986; Use of Local Tachometer for EDG Surveillance on September 18, 2024 (7) (Partial)

AR 2024-6650; Ice Bed Temperature Following Glycol Restoration on September 19, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) 12 AB loop feed enclosure temp modifications on July 17, 2024
(2) Unit 1 TDAFP temporary modifications on July 17, 2024
(3) 1-DCR205 temporary modifications on July 18, 2024

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (9 Samples)

(1) 2-QRV251 following packing leak on July 11, 2024
(2) 2W component cooling water PMT following planned work on July 18, 2024
(3) east diesel driven fire pump PMT following planned work window on July 30, 2024
(4) 2N safety injection (SI) pump PMT following planned work on July 30, 2024
(5) supplemental diesel generator on August 14, 2024
(6) 1-BATT-AB Cell 114 replacement on August 26, 2024
(7) CEQ fan tripping on September 18, 2024
(8) AB loop feed enclosure PMT on September 24, 2024
(9) 2-WMO716, west containment spray heat exchanger essential service water inlet valve on September 27, 2024

Surveillance Testing (IP Section 03.01) (4 Samples)

(1) 2W residual heat removal (RHR) operability test on August 19, 2024
(2) 2AB EDG monthly surveillance run on August 20, 2024
(3) 2W MDAFP surveillance run on September 12, 2024
(4) Unit 1 main turbine valve functional testing on September 13, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) Unit 2 west charging pump operability test on July 29, 2024

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) FLEX diesel testing on September 13, 2024

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:

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.

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) hostile action-based drill on September 24,

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.

Groundwater Protection Initiative (GPI) Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the GPI program to identify incomplete or discontinued program elements.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,

& Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1) Dry Active Waste Building
(2) Radioactive Material Building

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) Cask Dewatering Area in 587' Drumming Room

Waste Characterization and Classification (IP Section 03.03) (3 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) 2022 Dry Active Waste
(2) 2023 Primary Filters
(3) 2022 Primary Resins

Shipping Records (IP Section 03.05) (3 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Shipment DCC24-048, Surveillance Coupon, UN2915 Type A package
(2) Shipment DCC24-030, Dry Active Waste, UN3321
(3) Shipment DCC23-015, Primary Resin, UN3321 LSA-II, RQ

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS07: High Pressure Injection Systems (IP Section 02.06)===

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (July 1, 2023, through June 30, 2024)
(2) Unit 2 (July 1, 2023, through June 30, 2024)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (July 1, 2023, through June 30, 2024)
(2) Unit 2 (July 1, 2023, through June 30, 2024)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1 (September 1, 2023, through June 30, 2024)
(2) Unit 2 (September 1, 2023, through June 30, 2024)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) September 1, 2023, through June 30, 2024

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) September 1, 2023, through June 30, 2024

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) April 1, 2022, through June 30, 2024.

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) April 1, 2022, through June 30, 2024.

EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) Sirens are not part of the sites primary ANS. ANS will be inspected via IP 71114.02.

===71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03) (2 Samples 1 Partial)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) turbine trip for steam leak on July 15, 2024
(2) indication of partial discharge on 12AB loop feed enclosure on August 1, 2024 (3) (Partial) damage to the rod cluster control assembly in Unit 2 outage on August 12, 2024

71153 - Follow-up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02)===

The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.

(1) LER 2024-001-00 for Donald C. Cook Nuclear Plant, Unit 2, Reactor Trip due to Main Turbine Trip from a High-High Thrust Bearing Position Trip, 05000316/2024-001-00 (ADAMS Accession No. ML24141A120). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855 - Operation of an ISFSI Operation of an ISFSI

(1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading activities from August 19 through August 23, 2024. Specifically, the inspectors observed the following activities during the loading of cask No. 65:
  • fuel loading
  • heavy load movement of loaded multi-purpose canister (MPC) out of the spent fuel pool
  • closure welding and non-destructive evaluations
  • stack-up and download of the MPC from the transfer cask into the storage cask
  • radiological field surveys

The inspectors performed walkdowns of the ISFSI pad and haul path, which also included performing independent radiation surveys.

The inspectors evaluated the following:

  • spent fuel selected for loading into dry cask storage during this loading campaign
  • selected corrective action program documents
  • selected 72.48 screenings
  • changes to the sites 10 CFR 72.212 report since the previous inspection

INSPECTION RESULTS

URI Safety-Related Motor Control Center Bus Bar Commercial 71111.21N.03 (Discussed) Grade Dedication URI 05000316,05000315/2023011-01

Description:

The NRC continued to evaluate the unresolved item documented in inspection report 2023011-01 (ADAMS Accession Number ML23233A187) related to the commercial grade dedication activities for a motor control center bus bar. The inspectors requested additional information related to the issues of concern and plan to review it to determine whether any performance deficiencies or violations exist.

Enforcement Enforcement Action EA24-078: Failure to Comply with 10 CFR 71124.08 Discretion Part 37

Description:

On November 15, 2016, the licensee was issued NRC Inspection Report Nos.

05000315/2016404 and 05000316/2016404, which documented a licensee-identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52.

Subsequently, the inspectors re-evaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for Enforcement Discretion established within Section 9.3 of the NRC Enforcement Policy.

Corrective Actions: As specified in NRC Enforcement Policy, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action. Additional corrective actions are not required.

Corrective Action References: Not Applicable

Enforcement:

Violation: On November 15, 2016, a violation of 10 CFR Part 37 was documented in Donald C. Cook Inspection Report Nos. 05000315/2016404 and 05000316/2016404. The inspectors determined that the previously identified violation remains.

Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Section 9.3 of the NRC Enforcement Policy Enforcement Discretion for Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.

Failure to Implement Design Control Process Causes Main Turbine Trip Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 FIN 05000315,05000316/2024003-01 Open/Closed A self-revealed finding of very low safety significance (Green) was identified with the licensees failure to implement a modification to a turbine supervisory instrumentation (TSI)card. Specifically, the licensee failed to correctly implement a modification to the turbine protection system, leading to incorrect inputs included into the turbine trip circuit which, led to a main turbine trip and subsequent reactor trip.

Description:

On March 22, 2024, the Unit 2 main turbine tripped due to a main turbine thrust bearing trip condition, which led to an automatic trip of the Unit 2 reactor. The thrust bearing trip signal is designed to trip the main turbine if a thrust bearing wear condition is sensed on the turbine and is fed by a 2-out-of-2 logic trip input from thrust bearing probes A and B. Directly prior to the trip, probe B had spiked above the high alarm setpoint while probe A remained normal.

The licensee investigated the alarm and determined the momentary indication was most likely an indication of probe failure or a bad driver and recommended bypassing the alarm.

Approximately a minute later, probe B spiked high again (with probe A still reading normal),this time above the trip setpoint, inputting one of two trip inputs required for the trip signal.

Despite only having one of the two designed inputs for a trip, the Unit 2 main turbine still tripped.

Licensee investigation revealed the cause to be during implementation of engineering change EC00000047291, which modified a TSI card. This card is connected to the thrust bearing probes, with additional probes used to monitor various other trip conditions. In 2007, the main turbine thrust bearing trip was incorrectly set to monitor all probes on the TSI card instead of only the thrust bearing probes, allowing a 2-out-of-all logic trip input for the trip signal. At the time of the trip, vibration probe 1X on the TSI card showed bad quality (interpreted by the logic as failed or above setpoint), which input one of two trip inputs required for the trip signal. When thrust bearing probe B exceeded the trip setpoint, the second required trip input was met, signaled a trip, and caused the main turbine to trip and subsequent reactor trip.

Corrective Actions: The licensee took immediate corrective actions to remove the incorrect inputs for the thrust bearing trip, replaced the TSI card associated with the main turbine thrust bearing probes, and replaced probe B. Planned corrective actions going forward will be replacement of the remaining probes.

Corrective Action References: AR 2024-2321 Unplanned reactor/turb trip due to thrust bearing high vibe AR 2024-2318 MT TSI TP2 High vibes

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to implement a modification to a TSI card was contrary to EC0000047291 and was a performance deficiency.

Specifically, the licensee included additional probes into the thrust bearing trip function of the TSI card, which altered the trip logic.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to use adequate design control resulted in an automatic reactor trip.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that this finding is of very low safety significance (Green) because they answered No to Exhibit 1, Section B, Transient Initiators screening question.

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:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On October 8, 2024, the inspectors presented the integrated inspection results to Q. S. Lies, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.
  • On July 11, 2024, the inspectors presented the radiation protection inspection results to Q. S. Lies, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.
  • On July 26, 2024, the inspectors presented the emergency preparedness inspection results to L. Ellis, Plant Manager, and other members of the licensee staff.
  • On August 23, 2024, the inspectors presented the ISFSI cask loading inspection results to M. Scarpello, Director of Regulatory Compliance and Licensing, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60855 Calculations SD220712-001 Evaluation of ISFSI Pad Settlement Survey 0

Corrective Action AR 2021-6205 Dry Cask Personnel Did Not Follow Written Instructions 07/15/2021

Documents AR 2021-7151 Dry Cask - Welding Interpass Temperature Not Monitored 08/17/2021

AR 2022-4965 Possible Degradation of Sheave Bearing on 12-QM3E 06/06/2022

AR 2024-0560 Elevated ISFSI Cask Delta T 01/20/2024

AR 2024-2987 Deficiencies Found during Monthly Dry Cask Inspection 04/07/2024

AR 2024-3469 12-QM80 Cable Deterioration Observed 04/19/2024

Corrective Action AR 2024-6459 WOs for East Aux Building Crane (12-QM3E) Need 08/22/2024

Documents Updating

Resulting from

Inspection

Engineering EC1000494 DC Cook Dry Cask Loading Campaign #5 0

Evaluations NFG-DCO23-01 Decay Heat Calculations to Support Dry Cask Storage 0

Campaign #5 (Summer 2024)

Miscellaneous 72.48 Tracking Incorporation of Holtec Engineering Change Order (ECO) 10/18/2021

No.: 2021-0188-5014-132

2.48 Tracking Addition of 69kV-12kV Transformer #10 01/18/2022

No.: 2021-0203-

2.48 Tracking The 72.212 Evaluations Report and Regulatory Compliance 03/28/2022

No.: 2022-0037-Report are Being Updated

2.48 Tracking Update of the 10 CFR 72.212 Evaluations Report to Address 01/23/2024

No.: 2024-0004-the NRC Approved Changes for the Renewed Certificate(s)

of Compliance and Associated HOLTEC FSAR(s)

2.48 Tracking Transport Operations 04/21/2024

No.: 2024-0043-

2.48 Tracking MPC Preparation for Loading Transfer Operations 04/26/2024

No.: 2024-0048-

Inspection Type Designation Description or Title Revision or

Procedure Date

2.48 Tracking MPC Loading Operations 05/22/2024

No.: 2024-0052-

2.48 Tracking MPC Boron Sampling 05/30/2024

No.: 2024-0062-

2.48 Tracking DC Cook Dry Cask Loading Campaign #5 10/19/2022

No.: 7248-2022-

0116-00

NDE Reports 920422-967-04 GQP-9.2 Liquid Penetrant Examination Report 08/21/2024

Procedures 1 EHP SP.045 Ultrasonic Testing of Unit 1 Fuel for Cycle 14 Reload 0

EHP SP.048 Unit 1 In-Mast Fuel Sipping 0

2-EHP-4051-Fuel Selection and Sequence Development for Dry Cask 9

DCO-300 Storage

2-OHL-4030- Unit 12 Tours - ISFSI 23

SOM-009

2-OHP-4051-MPC Loading Operations 33

DCO-300

2-OHP-4051-MPC Welding, Blowdown, Drying and Backfill 36

DCO-400

2-OHP-4051-Transfer Operations 31

DCO-500

MHI-5025 Control and Inspection of Rigging and Lifting Equipment, 23

Data Sheet 20, Annual Rigging and Lifting Inspection

Record

PMP-2350-SES-10 CFR 72.48 Reviews 8

2

PMP-5020-MHP-Lifting and Rigging Program 50

001

Radiation CNP-2405-00110 Semi-Annual ISFSI Pad Survey 05/29/2024

Surveys SW_VSDS-M-Neutron Dose Rate Survey for Comparison of Meters 08/07/2021

210807-2

Self-Assessments GT 2023-8773 NRC ISFSI Inspection 05/09/2024

NOS-21-03 Nuclear Oversight Audit: Spent Fuel Storage 10/11/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 55565828-48 Perform DCO-805 Special Lifting Device Inspections 05/01/2024

C10044660001 MTE (12-QM-3E) Perform Inspection/Maintenance 12/12/2023

C10044660003 MTM: 12-QM-3E Perform Inspections and Maintenance 12/14/2023

C10070699001 MTM: 12-QM-3E, Perform Monthly Mechanical Crane 06/06/2024

Inspection

71111.04 Drawings OP-1-5151A-51 Flow Diagram Emergency Diesel Generator AB Unit No. 1 07/15/2021

OP-1-5151B-65 Flow Diagram Emergency Diesel Generator AB Unit #1 04/15/2024

OP-2-5135-40 Flow Diagram CCW Pumps and CCW Heat Exchangers 11/14/2022

OP-2-5142 Flow Diagram Emergency Core Cooling (SIS) 10/19/2022

OP-2-5151D-71 Flow Diagram Emergency Diesel Generator CD Unit No. 2 07/13/2021

Procedures 1-OHP-4021-032-Operating DG1AB Subsystems - DB1AB Fuel Oil System 36

008AB Valves

1-OHP-4021-032-Operating DG1CD Subsystems 43

008CD

1-OHP-4030-156-East MDAFP Valve Lineup 22

017E

1-OHP-4030-156-East MDAFP Valve Lineup 22

017E

2-OHP-4021-008-Placing Emergency Core Cooling System in Standby 036

2 Readiness

2-OHP-4021-032-Operating DG2CD Subsystems 37

008CD

2-OHP-4030-208-E.C.C.S. Valve Position Verification 009

053V

2-OHP-4030-216-Unit Two East CCW Loop Flow Path Verification 39

20E

2-OHP-4030-216-Unit Two West CCW Loop Flow Path Verification 36

20W

2-OHP-4030-256-Turbine Driven Auxiliary Feedwater System Test 38

017T

71111.05 Fire Plans Fire Pre-Plans Volume 1 47

Miscellaneous D.C. Cook Nuclear Plant Fire Safety Analysis (FSA) 08/11/2021

Revision 5

24-009-A Fire Drill 08/15/2024

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.06 Calculations PRA-FLOOD-004 Internal Flooding - Qualitative Screening Analysis 2

PRA-FLOOD-007 Floor Drains Capacity 1

PRA-FLOOD-008 Flood Sources and the Associated Flood Mechanisms 2

PRA-FLOOD-014 Internal Flood Detailed Analysis 0

71111.11Q Procedures RQ-E-4903-U2 Licensed Operator Requalification Training Scenario 08/06/2024

71111.12 Corrective Action 2019-9540 As-Found LLRT Failure of Both 2-CCW-244-25 and 10/07/2019

Documents 2-CCW-243-25

21-10369 CCW-05 Maintenance Rule (a)(1) Consideration 12/22/2021

21-3313 As-Found LLRT of 2-CCW-244-25 Was Unable to be 04/20/2021

Pressurized

21-8634 SML-78 Drop 75 (C-9 Status Light) Not Lit 10/19/2021

21-9413 MRule Reliability Criteria for Function MS-09 Exceeded 11/17/2021

22-3634 Open & Inspect CCW Contain Isolation Valves on Unit 2 04/26/2022

22-5260 Sparge/Flush the Component Cooling Water Hx in U2C28 06/20/2022

23-7589 1-CCW-243-25 LLRT Failed 10/18/2023

24-2445 2-CCW-244-72 Gross LLRT Failure 03/26/2024

24-2448 2-CCW-243-25 Gross LLRT Failure 03/26/2024

24-2450 2-CCW-244-25 Gross LLRT Failure 03/26/2024

Miscellaneous Cook Nuclear Plant Excellence Plan Indicator CNP.142 07/2024

Number of (a)(1) Systems, Unit 1, Unit 2 and Common

Maintenance Rule Scoping Document; Component Cooling 10

Water

Maintenance Rule Scoping Document; Main Steam System 7

71111.13 Procedures 12-OHP-SP-475 Risk Management for LCO 3.8.1 Entry during AB Loop Feed 09/09/2024

Modification

71111.15 Corrective Action 2023-4337 Indications of Partial Discharge on 12AB Loop Feed 06/08/2023

Documents Enclosure

23-9079 1-IMO-255 10 dpm Packing Leak 11/30/2023

24-4592 2-HV-AFP-T1AC Will Not Run 05/26/2024

24-5371 FLEX Blended RCS Pump Out of Service 07/01/2024

24-5435 1-DCR-205 Failed IST Stroke Time 07/04/2024

24-6357 Work Order Generation for 2-IMO-52 Repack 08/19/2024

24-6650 Ice Bed Temperature Following Glycol Restoration 08/30/2024

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 2024-5322 2-HV-AFP-T2AC is Not Working Properly 06/28/2024

AR 2024-6986 Use of Local Tachometer for EDG Surveillance 09/17/2024

Miscellaneous OHI-4032 Leakage Monitoring Program Cumulative Leak Rate Data 12/07/2023

Log

Procedures 1-OHP-4030-114-RCDT and Containment Sumps Valve Test 38

011

EHI-5072 ECCS Recirculation Leakage Reduction Program 10

OHI-4032 Leakage Monitoring Program 021

PMP-4030-001-Impact of Safety Related Ventilation on the Operability of 37

001 Technical Specification Equipment

PMP-7030-OPR-Operability Determination 41

001

71111.18 Corrective Action 2022-5345 Evaluate TDAFP Room Cooler Performance 06/23/2022

Documents 2022-5373 U1 TDAFP Room Cooler 1-HV-T1AC Not Working Correctly 06/24/2022

22-5375 U1 Unexpected CR Alarm for TDAFP Room Coolers 06/25/2022

22-6759 MRE Needed on U1 TDAFP Room Cooler Conditions

23-8396 Create WO to Replace 1-HV-AFP-T1AC 11/06/2023

24-2805 2-DCR-205 Blown Diaphragm 04/02/2024

Miscellaneous DWWO 2022-1-HV-AFP-T1AC Replace Cooler Unit 07/28/2022

8603

GT 2022-10244 Risk Tracking for 1/2-DCR-205-206 and 1-VCR-11/21 12/20/2022

Diaphragms

71111.24 Corrective Action 2024-6974 Light Not Lit on 2-HV-CEQ-1 Control Switch 09/17/2024

Documents

Procedures 1-OHP-4030-114-Breaker Alignment 09/23/2024

031

1-OHP-5030-050- Main Turbine and Feed Pump Turbine Valve Functional 09/14/2024

001 Checks

2-MHP-5021-Supplemental Diesel Generator Maintenance 005

033-001

2-OHP-4030- Supplemental Diesel Generator Testing - SDG Quarterly 39

033-01 Surveillance

2-OHP-5030- FLEX 500 kW DG Functional Test 09/11/2024

FSG-421

Inspection Type Designation Description or Title Revision or

Procedure Date

2-OHP-5030- FLEX 250/350 kW DG Functional Test 09/11/2024

FSG-422

2-OHP-5030- FLEX 26 kW DG Functional Test 09/11/2024

FSG-423

2-OHP-4030-203-West Centrifugal Charging Pump Operability Test 33

2W

2-OHP-4030-214-Breaker Alignment 09/24/2024

031

2-OHP-4030-217-West Residual Heat Removal Train Operability 08/15/2024

050W Test Modes 1-4

2-OHP-4030-256-West Motor Driven Auxiliary Feedwater System Test 09/13/2024

017W

2-OHP-4030- West Motor Driven Auxiliary Feedwater System Test 9

STP-017W

OHI-4016 Conduct of Operations: Guidelines IST Valve Operability 62

After Maintenance

Work Orders C10054830 001 MTM, 12-OME-250-SDG1, Annual Maintenance 08/06/2024

(Vendor/MT)

C10055989002 2-WMO-716 Full PM 07/22/2024

C10062773 001 MTM, 12-OME-250-SDG2, Annual Maintenance (Vendor) 08/06/2024

C10062959024 1-BATT-AB Replace Cell 114 08/21/2024

C10071943004 MTI, 2-QRV-251, Reinstall Instr, A/L Diagnostics 06/28/2024

C10076413-001 MTE: 2-HV-CEQ-1 (2-152-CEQ1) Replace Back Up Breaker 09/17/2024

C10076413-003 2-HV-CEQ-1: 2-IHP-4030-228-005B - Post Maintenance 09/17/2024

Test

71114.02 Corrective Action AR 2022-6301 Loss of Federal IPAWS System 08/05/2022

Documents AR 2024-1557 Nationwide Cell Phone Outage 02/22/2024

Miscellaneous FEMA Design Alert and Notification System Evaluation Report 01/01/2021

Report

Self-Assessments NOS-24-02 Nuclear Oversight Audit NOS-24-02, Emergency 04/11/2024

Preparedness

71114.03 Corrective Action AR 2024-1487 Evidence of EP-I-ERO Training Not Documented 02/20/2024

Documents (NOS-24-02)

AR 2024-2141 ARM-24-03-01, EP Training and Qualification 03/19/2024

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous N/A ERO Staff Training Records: 25 Records Various

Procedures CNP OSA Report ERO On-Shift Staffing Analysis Report 12/09/2019

71114.05 Calculations KLD TR - 1409 Donald C. Cook Nuclear Plant 2024 Population Update 06/12/2024

Analysis

Corrective Action AR 2022-9770 PARs Not in Accordance With Drill Manual 11/30/2022

Documents

Procedures N/A DC Cook Emergency Plan Rev. 49

71124.07 Calculations Cook Work Work Practice Evaluation for GPI Implementation at Cook 5

Practices

Evaluation SRA

DC Cook SSC Systems, Structures, and Components Site Risk 11

Risk Evaluations Assessment

SRA

Corrective Action AR 2022-10270 REMP Air Station Loss of Power Documentation for the 12/21/2022

Documents Annual

AR 2023-0575 12-THP-6010-RPP-601 and Tech Spec 5.5.1c.3 Compliance 01/19/2023

Issue

AR 2023-2224 REMP TLD at Location OFT11 Lost 03/16/2024

AR 2024-3218 NBF REMP Air Sample Unavailable 04/10/2024

Miscellaneous ENVI-8916-GPI-Groundwater Protection Program 1

001

Land Use Census Radiological Environmental Monitoring Program Land Use 09/30/2022

22 Census Summary

Land Use Census Radiological Environmental Monitoring Program Land Use 09/30/2023

23 Census Summary

Procedures 12-THP-6010- Collection of REMP Surface Water Sample 9

RPP-630

2-THP-6010- Collection of REMP Groundwater Samples 16

RPP-634

PMP-6010-OSD-Off-Site Dose Calculation Manual 27

001

Self-Assessments GT 2021-10170-1 Self-Assessment Report for the Radiological Environmental 2021

Monitoring Program (REMP)

GT 2023-8764 - 1 Self-Assessment Report for the Radiological Environmental 2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Monitoring Program (REMP)

71124.08 Calculations RPC/TB RP-16-10 CPR Part 37 Category 1 and Category 2 Quantity 09/06/2016

Determination

Corrective Action AR 2024-1644 10 CFR 61 Scaling Factor Data - 2022, Data Entry Error 02/27/2024

Documents AR 2024-3186 Vehicle Inspection Check off Sheet Tire Inspections 06/30/2024

Corrective Action AR 2024-5469 Part 37 Annual Review 07/08/2024

Documents

Resulting from

Inspection

Miscellaneous 10 CFR 61 10 CFR 61 Scaling Factor Data - 2022 Not Provided

Scaling Factor

Data - 2022

CFR 61 10 CFR 61 Scaling Factor Data - 2023 Not Provided

Scaling Factor

Data - 2023

2-THP-6010- Radioactive Source Leak Test Record 05/20/2024

RPP-011 Data

Sheet 2

Lesson Plan GP-10CFR37 Approved Individual 3

I-AIND

NEI 14-04 Cook Nuclear Plant Indiana and Michigan Power Part 37 1

Security Plan for the Protection of Category 1 and

Category 2 Quantities of Radioactive Material

SPP-2060-SFI-Protection of Category 1 and Category 2 Quantities of 9

217 Radioactive Material

Procedures 12-THP-6010- Radioactive Source Control 33

RPP-011

2-THP-6010- Scaling Factor Determination 8

RPP-913

2-THP-6010- 10 CFR Part 37 Material Accountability Program 3

RPP-917

PMP-6010-PCP-Radioactive Waste Process Control Program 15

900

71124.08 Procedures PMP-6010-PCP-Shipment of Radioactive Materials and Waste 7

901

Self-Assessments GT 2023-0671 Perform the Annual Part 37 Security review for 2023 11/15/2023

GT 2023-8765-1 Radiation Protection Radwaste Program 06/06/2024

Shipping Records DCC23-015 Primary Resin 05/23/2023

DCC24-030 Dry Active Waste 04/10/2024

DCC24-048 Surveillance Capsule S 06/11/2024

Work Orders C10027792002 Received Leak Check Counting Data 11/22/2022

C10043544001 RP Perform Source Leak Checks 06/05/2023

C10054043002 Received Leak Check Counting Data 11/20/2023

71151 Miscellaneous EPP-2080-ERO-Emergency Preparedness Performance Indicators 04/01/2022

300 Performance Indicator Verification through

06/30/2024

PMP-7110-PIP-Reactor Oversight Program Performance Indicators and 23

001 Monthly Operating Report Data Sheets and MSPI Derivation

Sheets (High Pressure Injection Systems and Cooling Water

Systems; April 2023 through March 2024)

PMP-7110-PIP-Reactor Oversight Program Performance Indicators and 23

001 Monthly Operating Report Data Sheets and MSPI Derivation

Sheets (Heat Removal System (AFW) and Residual Heat

Removal System; July 2023 through June 2024)

PMP-7110-PIP-Reactor Coolant System Specific Activity Multiple

001 Data Sheet

PMP-7110-PIP-Occupational Exposure Control Effectiveness Multiple

001 Data Sheet

PMP-7110-PIP-RETS/ODCM Radiological Effluent Occurrences Multiple

001 Data Sheet

21