IR 05000315/2016008

NRC Pilot Design Bases Inspection (Programs) Inspection Report 05000315/2016008; 05000316/2016008 (Axd)

ML16160A063
Person / Time
Site:	Cook
Issue date:	06/07/2016
From:	Jeffers M NRC/RGN-III/DRS/EB2
To:	Gebbie J Indiana Michigan Power Co
References
IR 2016008
Download: ML16160A063 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION une 7, 2016

SUBJECT:

DONALD. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC PILOT DESIGN BASES INSPECTION (PROGRAMS) INSPECTION REPORT 05000315/2016008; 05000316/2016008

Dear Mr. Gebbie:

On May 13, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed the program portion of the pilot Design Bases Inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2. The enclosed report documents the results of this inspection, which were discussed on May 13, 2016, with yourself, and other members of your staff.

Based on the results of this inspection, the NRC inspectors did not identify any findings or violations of more than minor significance. However, inspectors documented a licensee-identified violation which was determined to be of very-low safety significance in Section 4OA7 of this report. The NRC is treating this violation as Non-Cited Violation consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the subject or severity of the Non-Cited-Violation, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Donald C. Cook Nuclear Power Plant, Units 1 and 2.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark T. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74

Enclosure:

IR 05000315/2016008; 05000316/2016008

REGION III==

Docket No: 50-315; 50-316 License No: DPR-58; DPR-74 Report No: 05000315/2016008; 05000316/2016008 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Power Plant, Units 1 and 2 Location: Bridgman, MI Dates: May 9 - 13, 2016 Inspectors: A. Dunlop, Senior Reactor Inspector, Lead B. Jose, Senior Reactor Inspector G. Hausman, Senior Reactor Inspector Observers: J. Isom, Senior Reactor Operations Engineer, NRR Approved by: M. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000315/2016008; 05000316/2016008, 05/09/2016 - 05/13/2016;

Donald C. Cook Nuclear Power Plant, Units 1 and 2; Pilot Design Bases Inspection (Programs).

The inspection was a 1-week onsite baseline inspection that focused on the implementation of the Environmental Qualification Program. The inspection was conducted by three regional engineering inspectors. No findings were identified by the inspectors. All violations of U.S.

Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 201

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

A violation of very-low safety significance that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees Corrective Action Program. This violation and Corrective Action Program tracking number is listed in Section 4OA7 of this report.

REPORT DETAILS

1R21 Design Bases Inspection (Programs)

.1 Introduction

This is a pilot inspection of a licensee program conducted per U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.21N. The objective of the Design Bases Inspection (DBI) is to gain reasonable assurance that structures, systems, and components can adequately perform their design basis function. This includes reasonable assurance that electrical equipment important-to-safety for which a qualified life has been established can perform its safety functions without experiencing common cause failures before, during, and after applicable design basis events. This inspection will review the licensees implementation of the electrical equipment Environmental Qualification (EQ) Program, as required by their license, for maintaining the qualified status of equipment during the life of the plant. The inspection is intended to assess the programs effectiveness by sampling a limited number of components. This inspectable area verifies aspects of the Mitigating Systems and Barrier Integrity cornerstones for which there are no indicators to measure performance.

The inspectors assessed the implementation of the EQ Program, established to meet the requirements of Title 10, Code of Federal Regulations (CFR), Part 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants. The scope of this rule included safety-related equipment relied upon to remain functional during and following design basis events, nonsafety-related equipment whose failure under postulated environmental conditions could prevent safety-related equipment from performing design functions, and certain post-accident monitoring equipment. The NRC originally verified plants EQ Program implementation through a series of onsite inspections from 1984 - 1989. The EQ Program at that time established measures to ensure components met the EQ rule through the 40-year operating license period. Since that time, both units have renewed their operating licenses for an additional 20 years, and in 2014 Unit 1 entered its period of extended operation.

Specific documents reviewed during the inspection are listed in the Attachment to the report.

.2 Inspection Sample Selection Process

The inspectors selected components for review using information provided by the licensee. This included risk informing the selection based on the Donald C. Cook Nuclear Power Plant probabilistic risk assessment by generally selecting components that had a high Fussell Vesely Importance factor. Additional selection criteria included discussions with plant staff, reviewing procurement, maintenance, and design records, and walking down plant areas susceptible to high energy line breaks. Based on these reviews, the inspectors focused the inspection on EQ Program elements and components repaired, modified, or replaced. Components from each unit were selected and included motor-operated valves, air operated valves (AOVs), electrical containment penetrations, and transmitters (pressure, flow, and level) located both inside and outside of containment. For each component selected, the inspectors evaluated the environmental qualifications of supporting sub-components including seals, lubricants, connectors, control and power cables, solenoids, transducers, limit switches, and terminal blocks.

This inspection constituted seven samples as defined in IP 71111.21N, Attachment 1, Section 02.01. The pilot program DBI, in conjunction with the team portion of the DBI (IP 71111.21M), constitutes completion of the baseline triennial Component Design Bases Inpection (IP 71111.21).

.3 Component Design

a. Inspection Scope

The inspectors assessed the licensees implementation of the EQ Program as required by 10 CFR 50.49. The inspectors evaluated whether the licensee staff properly maintained the EQ of electrical equipment important to safety through plant life (repair, replacement, modification, and plant life extension), established and maintained required EQ documentation records, and implemented an effective Corrective Action Program (CAP) to identify and correct EQ-related deficiencies and evaluate EQ-related industry operating experience.

This inspection effort included a review of EQ Program-related procedures, component EQ files, EQ test records, equipment maintenance and operating history, maintenance and operating procedures, vendor documents, design documents, and calculations.

Additionally, the inspectors performed in-plant walkdowns of accessible components to verify installed equipment was the same as described in the EQ component documentation files, verify components were installed in their tested configuration, determine whether equipment surrounding the EQ component may fail in a manner that could prevent the EQ component from performing its safety function, and verify that components located in areas susceptible to a high-energy line break were properly evaluated for operation in a harsh environment. Components removed from the EQ Program were reviewed to ensure an adequate basis existed to no longer require the components to meet EQ requirements. The inspectors reviewed procurement records and inspected a sample of replacement parts stored in the warehouse to verify EQ parts approved for installation in the plant were properly identified and controlled; and that storage time and environmental conditions did not adversely affect the components qualified life or service life. Documents reviewed for this inspection are listed in the

. The following seven EQ components (samples) were reviewed:

Containment Quadrant #3 Electrical Control Containment Penetration #4 (1-CEP-3C4); EQ sub-components: electrical penetration and flood up tubes; Pressurizer Relief Valve Upstream Shutoff Motor Operated Valve (1-NMO-151);

EQ sub-components: actuator and motor Steam Generator # 2 Feedwater Regulating AOV (1-FRO-220); EQ sub-components: solenoid valve (1-XSO-294);

Steam Generator # 4 Stop AOV (2-MRV-240); EQ sub-components: limit switches and solenoid valves (2-XSO-241 and 2-XSO-242);

Pressurizer Safety Valve SV-45B Discharge Acoustic Monitor (2-QR-107B);nonsafety-related Regulatory Guide 1.97 instrument; Auxiliary Feedwater to Steam Generator OME-3-1 Flow Indicator Transmitter (1-FFI-210); Regulatory Guide 1.97 instrument; and Lower Containment Train 'B' Water Level Indicator Transmitter (1-NLI-320);

Regulatory Guide 1.97 instrument.

b. Findings

No findings were identified.

.4 Operating Experience

a. Inspection Scope

The inspectors reviewed three EQ-related operating experience issues associated with the selected components to ensure that associated generic concerns had been adequately evaluated and addressed by the licensee. The operating experience issues listed below were reviewed as part of this inspection:

NRC Information Notice 2014-04, Potential for Teflon Material Degradation in Containment Penetrations, Mechanical Seals; NRC Information Notice 2015-12, Unaccounted for Error Terms Associated with the Irradiation Testing and Environmental Qualification of Important-to-Safety Components; and OE9884, Acoustic Monitoring System Accelerometer Connectors.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered Into the Corrective Action Program

a. Inspection Scope

The inspectors reviewed a sample of the selected component problems identified by the licensee and entered into the CAP. The inspectors reviewed these issues to assess the licensees threshold for identifying issues and the effectiveness of corrective actions related to design issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the CAP. The specific corrective action documents sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On May 13, 2016, the inspectors presented the inspection results to Mr. J. Gebbie, and other members of the licensee staff. The licensee acknowledged the issues presented.

Several documents reviewed by the inspectors were considered proprietary information and were either returned to the licensee or handled in accordance with NRC policy on proprietary information.

4OA7 Licensee-Identified Violations

The following violation of very-low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.

The licensee identified a finding of very low safety significance (Green) with an associated Non-Cited Violation of 10 CFR 50.49(d), Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, for the licensees failure to keep EQ files current and to retain EQ files in an auditable form to permit verification that each item of electric equipment that is important to safety meets EQ requirements. Specifically, during the licensees Self-Assessment GT 2015-12352-4, Environmental Qualification Program - 71111.21P Component Design Bases Inspection Engineering Programs, dated May 6, 2016, the licensee identified that contrary to 10 CFR 50.49(d); an excessive number of Equipment Qualification Evaluation Reports had not been incorporated into Central Equipment Environmental Qualification Files;

(2) the EQ Master List was controlled through a non-quality assurance database; and

(3) the EQ Evaluation Tracking Log was not being maintained in accordance with Procedure 12-EHP-5025-EQE-002, Performing EQ Evaluations, Revision 6. In addition, the licensee stated in Action Request (AR) 2016-0841, DCC-QA-105-QCN Has Several Unincorporated Changes Pending, dated January 21, 2016, that the large backlog of pending changes made it difficult for plant personnel to identify appropriate EQ requirements for plant equipment. As a result, the licensee entered the self-assessment identified issues into their CAP as follows:

AR 2016-2844, Excessive Number of EQERs not Incorporated into CEEQ Files, dated March 11, 2016; AR 2016-2950, Some EQ Documents do not Meet PMP-2030-REC-001, dated March 15, 2016; and AR 2066-2842, EQ Procedure Non-Compliance, 12-EHP-5052-EQE-002, dated March 11, 2016.

The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Design Control and affected the cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to maintain EQ files current and to retain the EQ files in an auditable form. The finding screened as Green utilizing Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. Specifically, the finding was determined to be a documentation concern and no evidence was found during the assessment to suggest EQ components were not qualified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Gebbie, Chief Nuclear Officer

S. Lies, Site Vice President

M. Lloyd, Vice President Engineering

K. Anderson, Engineering Programs Supervisor

D. Aubrey, Engineering Programs Manager

K. Baker, Design Engineering Manager

A. Garrett, Plant Engineering Director

S. Mitchell, Nuclear Regulatory Affairs Supervisor

S. Partin, Site Director

J. Petro, Design Engineering Director

J. Ross, Plant Manager

M. Scarpello, Nuclear Regulatory Affairs Manager

R. Wynegar, Nuclear Regulatory Affairs

U.S. Nuclear Regulatory Commission

M. Jeffers, Chief, Engineering Branch 2

T. Taylor, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None LIST OF ACRONYMS USED ADAMS Agencywide Document Access Management System AOV Air-Operated Valve AR Action Request CAP Corrective Action Program CFR Code of Federal Regulations DBI Design Bases Inspection EQ Equipment Qualifications IP Inspection Procedure NCV Non-Cited Violation NRC U.S. Nuclear Regulatory Commission PARS Publicly Available Records System