IR 05000315/2020001
| ML20134J115 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/13/2020 |
| From: | Richard Skokowski NRC/RGN-III |
| To: | Gebbie J Indiana Michigan Power Co |
| References | |
| IR 2020001 | |
| Download: ML20134J115 (20) | |
Text
May 13, 2020
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000315/2020001 AND 05000316/2020001
Dear Mr. Gebbie:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant, Units 1 and 2. On April 16, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Donald C. Cook Nuclear Plant, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Richard A. Skokowski, Chief Branch 4 Division of Reactor Projects
Docket Nos. 05000315 and 05000316 License Nos. DPR-58 and DPR-74
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000315 and 05000316
License Numbers:
Report Numbers:
05000315/2020001 and 05000316/2020001
Enterprise Identifier: I-2020-001-0043
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Plant, Units 1 and 2
Location:
Bridgman, MI
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
B. Bergeon, Operations Engineer
J. Cassidy, Senior Health Physicist
J. Mancuso, Resident Inspector
J. Nance, Senior Resident Inspector
D. Reeser, Operations Engineer
J. Rutkowski, Senior Resident Inspector
Approved By:
Richard A. Skokowski, Chief
Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Donald C. Cook Nuclear Plant, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure of Source Range Nuclear Instrumentation Resulted in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000316/2020001-01 Open/Closed Not Applicable 71153 A self-revealed Severity Level (SL) IV non-cited violation (NCV) of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.3.1, Reactor Trip System (RTS) Instrumentation and TS LCO 3.3.8, Boron Dilution Monitoring Instrumentation (BDMI), was identified when it was discovered that one of the two source range neutron detectors was inoperable during reactor startup testing.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000316/2020-001-00 LER 2020-001-00 for Donald C. Cook, Unit 2, Failure of Source Range Nuclear Instrumentation Resulting in a Condition Prohibited by Technical Specifications 71153 Closed
PLANT STATUS
Unit 1 and Unit 2 began the inspection period at rated thermal power and remained at or near 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/readingrm/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. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 west Essential Service Water (ESW) following system maintenance on February 27, 2020
- (2) Unit 2 Turbine Driven Auxiliary Feedwater system on March 9, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Auxiliary Building 573' elevation on February 26, 2020
- (2) Auxiliary Building 609' elevation on February 26, 2020
- (3) Unit 2 AB Emergency Diesel Generator (EDG) on March 12, 2020
- (4) Unit 2 CD EDG on March 12, 2020
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating examinations and biennial written examinations administered during the period of February 24, 2020 through March 27, 2020.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on March 5, 2020.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
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 the shifting of the condensate booster pumps in Unit 1 on January 17, 2020.
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) U1 AB/CD 4kv Switchgear ventilation on March 3, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Units 1 and 2 Train A Reserve Feed outage on March 3, 2020
- (2) Emergent work for moisture intrusion into Motor Control Center (MCC) in Turbine Building on March 11, 2020
- (3) Emergent work for 4kv Switchyard breaker failing to close on March 17, 2020
- (4) EDG outage and downpower to 50 percent for Feedwater Turbine Pump Condenser cleaning during the week of March 22, 2020
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:
- (1) Unit 1 AB and CD EDG Jacket Water and Lube Oil Heat Exchanger(s) mounting support bracket(s) operability determination
- (2) Unit 2 N-44 Power Range Nuclear Instrument failure operability determination
- (3) Unknown particulate found in fuel injector pumps
- (4) Unit 1 CD EDG South Combustion Air After-Cooler vent trap leak operability determination
- (5) Wrong tubing found installed on Lower Containment Area Rad Monitor
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Unit 2 West ESW system following planned work on January 14, 2020
- (3) Unit 2 Train A Reserve Feed following planned on March 4, 2020
- (4) Unit 2 AB EDG after replacement of eight fuel injector pumps on March 25, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 1 Steam Generator Wide Range Level Calibrations on February 26,
OTHER ACTIVITIES - BASELINE
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in EDG performance that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) The inspectors reviewed the licensee's assessment and corrective actions associated with lateral support bumpers. During a spring refueling outage, the licensee identified a missing lateral support bumper on the Unit 1 reactor coolant pump 2.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000315/2020-001-00, Failure of Source Range Nuclear Instrumentation Resulting in a Condition Prohibited by Technical Specifications, (ADAMS Accession No. ML20013D824).
Additional details regarding the disposition of this LER are documented in the Results section of this report.
INSPECTION RESULTS
Observation: Emergency Diesel Generator Trends 71152 On November 7, 2019, the licensee experienced an unanticipated drop in frequency on the Unit 2 CD emergency diesel generator (EDG) while performing a scheduled performance test. The licensees investigation determined that the cause for the reduction in frequency was binding of the diesels 6F fuel injector. The inspectors were aware of previous issues with fuel injectors on the plants emergency diesels and decided to review the plants experience with the injectors to determine if there existed an adverse trend that should have been investigated by the licensee and was not. The inspectors initially planned on reviewing operating history during the previous six months to a year but determined that it would be appropriate to review several years of experience mainly by reviewing condition reports that detailed issues with the EDGs.
The plant has four EDGs, two per unit, utilizing 12-cylinder Worthington Model SWB-12 diesels. Each cylinder is equipped with a Bendix model FDX-22 high-pressure fuel injection pump connected to a high-pressure fuel line and a high-pressure fuel injection nozzle. The final injection pressure into the diesel cylinder is advertised at about 15,000 psi. That pressure requires tight tolerances in the fuel injection pump (plunger and casing/guide tube)thus necessitating materials that can resist some scoring and fuel that does not contain material that can damage the injector in the tight tolerance areas. Damage in the tight tolerance areas could cause injector jamming with resultant failure to permit fuel injection.
The high pressure also raises the potential for fuel line leaks. The four EDGS are the only machines at the plant that use this model of injector.
In 2017, the licensee was issued non-cited violation 2017001-003 (ADAMS Accession Number ML1712A321) for failure to correct a previously identified configuration issue with the diesel fuel injectors that could and did cause a split in diesel injector fuel lines. The inspectors' review of condition reports since that time did identify a number of minor fuel leaks associated with injectors and their fuel lines. However, while such leaks normally resulted in the EDG being declared inoperable to fix the leaks, the inspectors did not identify any reports documenting leaks of a sufficient magnitude to, by themselves, require declaring the EDG, with the leak, incapable of performing its design function.
The fuel injector failure of November 7 was determined to be from internal scoring of the injector from abrasive particles either left in the injector after manufacture or factory refurbishment or, from particles in the fuel. Similar failures occurred in 2006 and 2016.
Seven fuel injector failures on recently installed new injectors were experienced in 2006. The failures were attributable to foreign material found in the pumps as supplied by the vendor. In 2016 one fuel injector again failed again due to foreign material fouling.
The licensee corrective actions after the 2006 failures was to require the injector pump vendor to implement measures to improve and verify pump and test stand cleanliness during the refurbishment process. After the 2016 failure, the licensee required multiple changes to improve cleanliness at the refurbishment vendors facilities to improve cleanliness and to enhance plant receipt inspections. The licensee also implemented plans to replace 23 installed fuel pumps, which had not been inspected in accordance with latest inspection criteria. The 2019 failure involved a fuel pump that had been refurbished in 2011. At the time of failure that injector had been in service for approximately 210 operating hours including approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in the Unit 2 CD EDG. In response, the licensee accelerated plans to replace the installed fuel pumps that had not been inspected per the revised criteria.
The inspectors, in addition to reviewing condition reports, reviewed the licensees purchase orders that included the licensees requirements for cleanliness during the vendors work on fuel injectors for the Cook plant. From the documents reviewed, the inspectors did not identify an issue with the licensees response to the conditions found or to their specified corrective actions.
Very Low Safety Significance Issue Resolution Process: Lateral Support Bumper Gaps 71152 This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.
Description:
Near the end of the previous Unit 1 refueling outage (RFO), licensee staff identified a lateral shim for reactor coolant pump (RCP) 11 on the grating adjacent to the pump. The licensee could not determine why the shim was not installed. Prior to restart, the licensee corrected the condition and performed additional inspections on lateral shims in Unit 1. This review identified that a shim on RCP 12 was out of tolerance by 1/16-inch.
Westinghouse evaluated the issue and determined that although the out of tolerance condition reduced the overall margin, the condition did not render the reactor coolant system (RCS) incapable of operating in accordance with the current licensing bases. At the time, the licensee planned to inspect Unit 2 to determine whether a similar condition existed during the next RFO scheduled in October 2019. The inspectors reviewed the licensee's condition evaluation, extent of condition, and proposed corrective actions.
During the Unit 2 RFO, the inspectors conducted a walkdown and visual inspection of the lateral supports that could be viewed from normally accessed areas in containment. The licensee performed a similar inspection and also obtained measurements where practical. The largest gap measured was 1-5/8 inches. The inspectors observations are consistent with this measurement.
Licensing Basis: Because the cold gaps exceed the gaps established for normal operating pressure and temperature (NOP/NOT) conditions and will change as RCS temperature changes, the inspectors inquired as to the acceptability of larger gaps at other than NOP/NOT. The licensee stated that the gaps do not represent a safety concern because of available margins and the reduced severity of conditions that could require lateral restraint - specifically loss of coolant accidents (LOCAs) and seismic events. In particular, seismic events generate lateral force well below those experienced during a LOCA. With respect to the current license bases of Donald C. Cook Nuclear Plant, the licensee considers the larger gaps to be within the current licensing basis (CLB) of the facility because they are in accordance with plant design and gaps must exist to allow for thermal expansion and contraction of the RCS. The inspectors noted that regulatory requirements do not limit analysis to NOP/NOT conditions but did not arrive at a conclusion regarding compliance with regulatory or license conditions.
Significance: The inspectors concluded that the existence of larger gaps at other than NOP/NOT is of very low safety significance based on the information provided by the licensee and Westinghouse, coupled with the engineering judgement of NRC staff. The events that could lead to the lateral support bumpers providing mitigation are LOCA and seismic events.
The LOCA has a very low probability of occurrence, with the most severe challenge occurring at NOP/NOT where the bumpers have gaps consistent with the analyzed conditions. At lower temperatures and pressures, the forces would be significantly less. For seismic events, the forces are significantly lower than LOCA forces. In summary, given a low probability of an initiating event, and significantly lower forces when the gaps are larger, the condition is of very low safety significance.
Technical Assistance Request: The inspectors did not enter either the TIA or Technical Assistance Request process. However, the resident staff did request assistance from region based inspectors who contacted the cognizant branch in the Office of Nuclear Reactor Regulation (NRR). The involved staff agreed that the design approach is consistent with standards practices at the time of design. In addition, in the event of a seismic occurrence, existing requirements to inspect piping provide appropriate safeguards to detect seismic induced damaged. Therefore, the condition represents an issue of very low safety significance that does not warrant additional review.
Corrective Action Reference: AR 2019-4856
Failure of Source Range Nuclear Instrumentation Resulted in a Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000316/2020001-01 Open/Closed
Not Applicable 71153 A self-revealed Severity Level (SL) IV non-cited violation (NCV) of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.3.1, Reactor Trip System (RTS)
Instrumentation and TS LCO 3.3.8, Boron Dilution Monitoring Instrumentation (BDMI), was identified when it was discovered that one of the two source range neutron detectors was inoperable during reactor startup testing.
Description:
On November 6, 2019, the licensee replaced one of the Unit 2 source range neutron flux detectors, NRI-32, as part of scheduled work during the refueling outage. The NRI-32 was replaced per its scheduled work order and successfully passed its post maintenance test (PMT) and was subsequently declared operable on November 7, 2019. The PMT was done in accordance with procedure 2-IHP-4030-213-229, Nuclear Instrumentation Source Range Channel Operational Test and Calibration, which had been used in the past to successfully test and calibrate detectors following various replacement and maintenance activities. No significant changes to the procedure or the work activities were observed that would affect the validity of the test.
During start up testing at 2102 on November 13, 2019, it was observed that NRI-32 did not respond as expected while the other channel of detection continued to give expected results.
The licensee performed a partial calibration utilizing the same procedure as before, 2-IHP-4030-213-229, and the detector was once again declared operable on November 14, 2019, after successfully completing the procedure. Subsequently, during start up testing, the detector again failed to operate as expected and the licensee fully inserted all rods and opened the reactor trip breakers.
Subsequent testing was able to identify the cause of the failure as a degraded connector.
The licensee swapped the cable to an installed spare, tested the detector again with 2-IHP-4030-213-229, and the detector was returned to operable at 2217 on November 18, 2019.
No further issues were noted with the detector during start up activities.
As a result of the second failure, the licensee undertook a past operability determination evaluation (PODE) and determined that the degraded connector had existed since replacement during the outage. Technical Specification LCO 3.3.1, Reactor Trip System Instrumentation, requires two source range neutron flux trip channels to be operable in Modes 3, 4, and 5 when the rod control system is capable of rod withdrawal, or one or more rods are not fully inserted. Technical Specification LCO 3.3.8, Boron Dilution Monitoring Instrumentation, requires two source range neutron flux monitoring channels to be operable in Modes 3, 4 and 5. The licensee determined these LCOs were not met prior to transitioning to applicable modes. Additionally, the licensee determined that the duration of inoperability exceeded the TS LCO allowed outage times for both of these requirements and generated Licensee Event Report (LER) 05000/316/2020-001-00 for an Operation or Condition Prohibited by TSs in accordance with 10 CFR 50.73(a)(2)(1)(B), and as an event or condition that could have prevented fulfillment of a safety function in accordance with 10 CFR 50.73(a)(2)(v)(A).
Corrective Action References: AR 2019-11394.
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency. Specifically, the licensee tested the detector following its replacement utilizing procedure 2-IHP-4030-213-229, Nuclear Instrumentation Source Range Channel Operational Test and Calibration, and the detector successfully passed the test. The licensees PODE determined that at low levels of counts the detector behaved correctly. Furthermore the licensee had used this test successfully in the past to restore the detector to operability and there had been no significant changes to conditions to call the adequacy of the test into question.
Enforcement:
Traditional Enforcement is being used to disposition this violation with no associated Reactor Oversight Process performance deficiency, per NRC Memorandum Interim Guidance for Dispositioning Severity Level IV Violations with No Associated Performance Deficiency, dated June 15, 2018 (ADAMS Accession No. ML18158A220). The inspectors assessed the severity of the violation using Section 6.0 of the NRC Enforcement Policy and determined the significance is appropriately characterized as Severity Level IV due to the inappreciable potential safety consequences. As the other channel of detection remained operable during the specified time frame, no loss of safety function occurred, and Donald C. Cook Unit 2 did not enter any unanalyzed conditions.
Violation:
A. Donald C. Cook Unit 2 TS LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, requires two source range neutron flux trip channels to be operable in Modes 3, 4, and 5 when the rod control system is capable of rod withdrawal, or one or more rods are not fully inserted. With one source range neutron flux trip channel inoperable in Modes 3, 4, or 5, the required action is to restore the channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the required action completion time is not met, then the requirement is to immediately take actions to fully insert all rods and to place the rod control system in a condition incapable of rod withdrawal within one hour. Additionally, if two Source Range Neutron Flux Trip Channels are inoperable in Modes 3, 4, or 5, the required action is to immediately open the reactor trip breakers (RTBs).
B. Technical Specification LCO 3.3.8, Boron Dilution Monitoring Instrumentation (BDMI),requires two source range neutron flux monitoring channels to be operable in Modes 3, 4 and 5. When one source range neutron flux monitoring channel is inoperable in Modes 3, 4, or 5, the required action is to restore the channel to operable status within 7 days.
Contrary to the above:
A. Only one source range neutron flux channel was operable due to source range detector, 2-NRI-32, being inoperable beginning with the closing of the RTBs at 0050 on November 13, 2019 and remained as such until the RTBs were re-opened at 1556 on November 15, 2019. This totaled a period of 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> and 6 minutes, longer than the allowed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
B. Only one source range neutron flux channel was operable due to source range detector, 2-NRI-32, being inoperable beginning with Unit 2s entry into Mode 5 at 0052 on November 5, 2019, until the Unit exited the mode of applicability on at 1017 on November 18, 2019. The total period of 13 days 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> and 25 minutes exceeded the LCO duration of 7 days.
Enforcement Action: This violation is being treated as an 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 April 16, 2020, the inspectors presented the integrated inspection results to Mr. J. Gebbie, Senior VP and Chief Nuclear Officer and other members of the licensee staff.
- On March 5, 2020, the inspectors presented the Biennial Licensed Operator Requalification Program Inspection Results to Mr. S. Lies, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
2-OHP-4030-219-
2FV
Lineup Sheet 2 West ESW Train Restoration
2-OHP-4030-256-
017T Lineup
Sheet 1
Turbine Driven Auxiliary Feedwater System Test
Corrective Action
Documents
Resulting from
Inspection
AR 2020-2122
Revise Fire Preplans for Fire Zone 36
03/03/2020
Fire Plans
Fire Pre-Plans Volume 1
Fire Pre-Plans Volume 1
71111.11B Corrective Action
Documents
AR 2019-7053
PZR Insurge/Outsurge
07/21/2019
Unit 2 Simulator Quadrant Power Range Tilt Anomalies
05/04/2018
Unit 2 Simulator Feedwater Pump Discharge Pressure
Higher than Plant Value
07/23/2018
Unit 1 and 2 Simulator SGTR Level Response Differs
Between Units
05/04/2019
Unit 1 Simulator Boric Acid Flow Controller will Switch to
Manual
08/12/2019
Miscellaneous
BRE20-RO-B
Biennial Licensed Reactor Operator Requalification Written
Examination Administered the Week of 03/02/2020.
2/06/2020
BRE20-SRO-B
Biennial Licensed Senior Reactor Operator Requalification
Written Examination Administered the Week of 03/02/2020
2/06/2020
JPM RO-O-A092
Calculate SG Tube Leakage
JPM RO-O-AEO-
E005
Local Main Steam Line Isolation (CR Evac)
JPM RO-O-AEO-
E221
Locally Control Charging Flow Using Control Valve QRV-251
JPM RO-O-AEO-
E250
Shift Turbine Driven Auxiliary Feed Pump Suction to ESW
JPM RO-O-AEO-
E276
Perform Local DG Trip and Isolation (Alternate)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
JPM RO-O-
Transfer to Cold Leg Recirculation (Alternate Path)
JPM RO-O-E265-
U12
Restore DG Power to Bus T11B/T21B using SUP-012
JPM RO-O-E276-
U12
Respond to Loss of Secondary Heat Sink
JPM RO-O-E277-
U12
Depressurize the RCS Following a SGTR (Normal Spray)
JPM SR-O-N0013 Determine if Core Alterations Can Continue
RQ-C-4465
Classroom Lesson, Period 4406 LOR Operations Review
RQ-E-ANN-10
LOR Annual Operating Examination Simulator Scenario #10
RQ-E-ANN-38
LOR Annual Operating Examination Simulator Scenario #38
RQ-E-ANN-44
LOR Annual Operating Examination Simulator Scenario #44
RQ-E-ANN-67
LOR Annual Operating Examination Simulator Scenario #67
TDG-SIM-004
Reactor Core Testing Guideline (U1C29)
03/14/2019
TDG-SIM-004
Reactor Core Testing Guideline (U2C24)
04/05/2018
TDG-SIM-005
Simulator Performance Testing Documentation ILT NRC18-
06/27/2018
TDG-SIM-005
Simulator Performance Testing Documentation LOR Tear 44
Annual Exam RQ-E-ANN-38 Rev 5
01/15/2020
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U1C29
Steady State Test
07/17/2019
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U2C24
Steady State Test
06/14/2018
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U2C25
Steady State Test
2/17/2020
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U1C29
Transient 3, Simultaneous Closure of all MSIVs
07/23/2019
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U1C29
07/24/2019
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U2C24
Transient 9, Maximum Size Main Steam Line Break
03/05/2018
TRP-2070-SIM-
003
Simulator Performance Testing Documentation U2C24
Transient 10, Stuck Open PORV with Hi Head Injection
07/16/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Prohibited
TRP-2070-SIM-
003, Data Sheet 1
Simulator Performance Testing Documentation 03/06/2019
Unit 1 Manual Reactor Trip
03/06/2019
Procedures
TDG-SIM-001
Simulator Steady State Testing Guideline
TDG-SIM-002
Simulator Transient Testing Guideline
TDG-SIM-004
Reactor Core Testing Guideline
TDG-SIM-005
Scenario Based Testing Guideline
TPD-600-LOR
License Operator Requalification Training Program
Description
TRP-2070-SIM-
001
Simulator Configuration Control
TRP-2070-SIM-
2
Simulator Change Request Implementation
TRP-2070-SIM-
003
Simulator Performance Testing
TRP-2070-TAP-
300-LOR
LOR Training Annual Operating Test and Biennial Written
Examination Development
TRP-2070-TAP-
300-OPS
Operations Training Examination and Simulator Exercise
Guide Development
TRP-2070-TAP-
400-LOR
LOR Training Annual Operating Test and Biennial Written
Examination Implementation
TRP-2070-TAP-
400-OPS
Operations Training Implementation
TRP-2070-TAP-
400-SEC
Operations Training NRC Exam Security
Self-Assessments GT2019-0553
20 Pre-NRC 71111.11 Inspection Quick-Hit Self-
Assessment
03/04/2020
Miscellaneous
System Health Reports
Maintenance Rule Basis Documents
Miscellaneous
IPTE Briefing Guide for PRF110033, Replace/Test 12-TR-3
& Breaker 12-12CD (EC-56698)
01/21/2020
Risk Profile for the Week of March 22, 2020
03/23/2020
SOS 19-108859
Switching Order Cook: Bus 9 - Upper Bus Tie 34KV CB BG
Procedures
PMI-4090
Criteria for Conducting Infrequently Performed Tests or
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Evolutions
Calculations
1-QT-110-AB
AB Emergency Diesel Lube Oil Cooler
2/14/1992
2-QT-131-CD
CD Emergency Diesel Jacket Water Cooler
2/14/1992
SQUG-1-QT-131-
AB Emergency Diesel Jacket Water Cooler
Corrective Action
Documents
AR 2019-12287
Anchor Bolts Pulling from Wall
2/18/2019
AR 2019-5748
Unit 2 Unexpected Annunciator 210, Drops 11 and 17
06/03/2019
AR 2020-0057
Momentary Spike on N-44 in U2 Caused a(n) Unexpected
CR alarm
01/03/2020
AR 2020-0312
N-44 Failed to 102% in U2 Caused an Unexpected CR
Alarm
01/12/2020
Miscellaneous
Site/Unit: AEP / 1;
Procedure: 12-
QHP-5050-NDE-
006; Outage No.
U1-C29;
Summary No.
830200; Report
No. U1VT-19-
111; Workscope:
ISI; Work Order
No. 55533838-02
Visual Examination of Component Supports and Snubbers
(VT-3), Vessel Supports, EDG, AB-EDJWHEX-VS-2
2/19/2019
Procedures
2-OHP-4030-232-
27AB
AB Diesel Generator Operability Test (Train B)
EC-0000056698-
2-TR-3, 34.5kV Bus Grounding Transformer and Breaker
2-52-12CD Integrated Functional Test
03/04/2020
Procedures
1-IHP-4030-151-
014
Steam Generator 1 and 3 Steam Flow/Feedwater Flow
Mismatch and Steam Pressure Protection Set 2 Transmitter
Calibrations
1-IHP-4030-151-
015
Steam Generator 2 and 4 Steam Flow/Feedwater Flow
Mismatch and Steam Pressure Protection Set 2 Transmitter
Calibrations
71151
Calibration
Records
2019-1598
U2 AB EDG High Pressure Fuel LIne Leaking at Leak-Off
Port
2/20/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2016-11594
New Spare Injection Pumps Found with FME
10/13/2016
2016-1797
Unit 1 CD EDG Seized Fuel Injector Pump Failure Analysis
07/08/2016
2016-4732
3R Fuel Pump Froze up on 1CD Diesel
04/17/2016
2016-4732
3R Fuel Pump Froze up on 1CD Diesel
2016-9690
1-OME-150-AB Fuel Line Leak Near #6 Rear Fuel Injector
10/16/2018
2017-3827
Unit 1 and Unit 2 EDG Health Decreased to Red
04/12/2017
2017-9778
1AB EDG Fuel Oil Leak
10/01/2017
2018-6204
Old EDG Fuel Injector O-Rings M&E 0405391725, are Brittle
06/11/2018
2018-8758
Develop Plan to Replace EDG Fuel Injectors and Fuel LInes
on all Four EDGs
01/30/2020
2018-8758
Develop Plan to Replace EDG Fuel Injectors and Fuel LInes
on all Four EDGs
01/30/2020
2018-9690
1-OME-150-AB Fuel Line Leak Near #6 Rear Fuel Injector
10/16/2018
2019-11077
Drop in Frequency Noted in LOP/LOCA Testing
11/07/2019
2019-11077
Apparent Cause Evaluation - U2CD Fuel Injector Failure
2/04/2020
2019-11077-14
Return Fuel Injection Pumps for Refurbishment
01/30/2020
20-0483
WR Needed to Replace Fuel Injectors on 1 CD EDG
01/15/2020
2106-8003-01
Seized Fuel Injector 1CD EDG
10/18/2016
Miscellaneous
PO01582531
Repair and Return Fuel Injectors
PO01583071
Injector Pump Refurbishments
2