IR 05000315/2023011
| ML23233A187 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/31/2023 |
| From: | Jamie Benjamin NRC/RGN-III/DORS/EB1 |
| To: | Lies Q Indiana Michigan Power Co |
| References | |
| IR 2023011 | |
| Download: ML23233A187 (1) | |
Text
SUBJECT:
DONALD C. COOK NUCLEAR PLANT - FUNCTIONAL ENGINEERING INSPECTION - COMMERCIAL GRADE DEDICATION REPORT 05000315/2023011 AND 05000316/2023011
Dear Q. Shane Lies:
On July 24, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jamie C. Benjamin, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000315 and 05000316 License Nos. DPR-58 and DPR-74
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000315 and 05000316
License Numbers:
Report Numbers:
05000315/2023011 and 05000316/2023011
Enterprise Identifier:
I-2023-011-0024
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Plant
Location:
Bridgman, MI
Inspection Dates:
June 12, 2023 to June 30, 2023
Inspectors:
E. Fernandez, Senior Reactor Inspector
D. Melendez-Colon, Reactor Inspector
E. Rosario, Reactor Inspector
Approved By:
Jamie C. Benjamin, Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Functional Engineering Inspection - Commercial Grade Dedication at Donald C. Cook Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000316,05000315/20 23011-01 Safety-Related Motor Control Center Bus Bar Commercial Grade Dedication 71111.21N.03 Open
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.03 - Commercial Grade Dedication Commercial Grade Dedication (section 03.01)
The inspectors reviewed the implementation of the licensees processes for dedicating commercial-grade items/services as basic components and/or for procuring safety-related structures, systems, and components for the following samples:
(1)00035526, Mobilux EP1 Grease, Vesco Oil Corp
- (2) CJ18840-1, Garolite Sheet, G-10, 1/2 Thick, 24 x 36, McMaster-Carr (3)00036194, Oil, DTE Extra Heavy, 55gal drum, Vesco Oil Corp (4)00035998, Gauge, Site Glass, Bearing Pedestal Housing with Drain, 3/8 in - 18 NPT Connection, Curtiss Wright Stream (5)100001351, Bushing, Control Room Ventilation Fan, SK-1 7/16 IN. 2 SK1-5/8 IN, Motion Industries
- (6) CGD-77720102-1, Cap, Fill, 4 Inch, Glass-Filled PBT, Paragon (7)100001188, Assembly, Cover & Grid Includes Fasteners-Seals & Gaskets, Debora Smith Energy Partners (8)100001491, Pipe Clamp EDGs, McMaster-Carr (9)00034654, Ste, Brass instrument Quick Connect, 1/4 IN FNPT X 3/8 IN, Lennon Fluid Systems LLC (10)00034780, Vertical Bus Bar, Tin Plated Copper, Storm Power Components
- (11) CGD-341713-1, Mechanical Seal, Cartridge Single Seal, Paragon (12)100001170 Pressure Gauge, 2-1/2", 0-100 Psi, Power Process Engineering
INSPECTION RESULTS
Unresolved Item (Open)
Safety-Related Motor Control Center Bus Bar Commercial Grade Dedication URI 05000316,05000315/2023011-01 71111.21 N.03
Description:
The Donald C. Cook Nuclear Plant purchased, dedicated and reversed engineered (under Specification No. ES-BUS-BAR-0001-QCN Rev 0) a non-safety related obsolete Cutler Hammer Control 9800 series Motor Control Centers (MCCs) vertical bus bar for use in safety-related applications. Specification No. ES-BUS-BAR-0001-QCN Rev 0 states under Dedication Instructions, Ensure the bus bars are either plain or tin coated copper. The dedication plan did not verify the new bus bar was tin coated. The original Cutler Hammer bus bars were aluminum with a tin coating. The new bus bars are made of copper with a non-documented unknown coating. The new configuration now consist of the new copper bus bar mated to a tin coated aluminum bus bar, which then come into sliding contact with silver plated copper bus stabs. The design change also uses a non-safety related corrosion inhibiting compound (e.g., Penetrox A-13), to prevent early failure of the tin coated aluminum to copper joint.
The inspectors identified three issues of concern with this commercial grade dedication sample.
1. The new configuration consisting of a new cooper bus bar material mated with an existing
tin coated aluminum bus bar has the potential to create a new or unique failure mechanism due to the dissimilar metals. The licensees evaluation did not address this potential failure mechanism.
2. Low contact resistance between bus bar mating surfaces was a listed critical attribute. The
original configuration used tin coatings between the tin coated aluminum bus bar to tin coated aluminum bus bar to create and maintain this condition. The new configuration uses a non-safety related corrosion inhibiting compound, Pentrox A-13, to create and maintain this condition. The licensee did not have documentation to show how this compound was qualified for use in safety-related applications.
3. Preventive maintenance/testing, instructions and inspection procedure acceptance criteria
did not appear to be modified to address this new or unique configuration.
On July 18, 2023, the licensee provide the inspectors a white paper title "DC Cook Response to Proposed Non-Cited Violation" which will be included in the review and final disposition for this Unresolved Item.
Planned Closure Actions: The inspectors planned to review the licensee's white paper to determine if any of the listed issues of concern represent a performance deficiency, and or violation of NRC requirements.
Corrective Action References: AR 2023-4974
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 24, 2023, the inspectors presented the Functional Engineering Inspection - Commercial Grade Dedication results to Q. Shane Lies and other members of the licensee staff.
On July 5, 2023, the inspectors presented the Exit for DC Cook Commercial Grade Dedication inspection results to Shane Lies - SVP Chief Nuclear Officer and other members of the licensee staff.
On July 24, 2023, the inspectors presented the Re-Exit inspection results to Steve Mitchell and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
22-6828
Unit 1 Reactor Trip - RCP 13 Trip
08/28/2022
22-6872
U1 RCP 12 Motor Electrical Penetration Corrosion and
Heat
08/29/2022
Corrective Action
Documents
22-9357
OSDD PO C1005443: Motion Industries
11/14/2022
23-4546
Review Current Practices for Oil Storage
06/19/2023
Corrective Action
Documents
Resulting from
Inspection
23-4974
NRC Inspection-Commercial Grade Dedication Violation
for Vertical Bus Bar
07/06/2023
00031489
Commercial Grade Item Dedication Evaluation - Bushing,
S Type QD Sure Grip-QMW
Rev. 0
00034654
Commercial Grade Item Dedication Evaluation - Stem,
Brass Instrument Quick Connect, 1/4 IN FNPT X 3/8 IN
Rev. 0
00034780
Commercial Grade Item Dedication Evaluation for Bus
Bar
00035526
Commercial Grade Item Dedication Evaluation - Grease,
Mobilux EP1, in 12 to 14 oz Tubes
Rev. 0
00035998
Commercial Grade Item Dedication Evaluation - Gauge,
Sight Glass, Bearing Pedestal Housing with Drain,
3/8 IN - 18 NPT Connection
Rev. 0
00036194
Commercial Grade Item Dedication Evaluation - Oil, DTE
Extra Heavy, 0121, 55 Gallon Drum
Rev. 0
100001170
Commercial Grade Item Dedication Evaluation for
100001188
Commercial Grade Item Dedication
Evaluation - Assembly, Cover & Grid
Rev. 0
100001351
Commercial Grade Item Dedication Evaluation - Bushing,
S Type QD Sure Grip-QMW, SK-1 7/16 IN
Rev. 0
100001491
Commercial Grade Item Dedication Evaluation - Clamp,
Pipe, 2 Mounting Holes, Steel
Rev. 0
CE-NEYS-0010
COMPONENT EVALUATION: Penetrox A and
Penetrox A-13
71111.21N.03
Engineering
Evaluations
CGD-341713-1
Commercial Grade Item Dedication Technical Evaluation,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Test Plan, and Test Datasheet for Mechanical Seal
CGIEL02
EPRI CGI Joint Utility Task Group Commercial Grade
Item Evaluation for Lugs, Compression, Un-Insulated
CGSR-AVL-1130-
Commercial Grade Survey Report for Paragon
DCCPS-604-QCS
Specification for Cable Terminations and Splices
ES-BUS-BAR-
0001-QCN
Purchase and Design Specification for Vertical Bus Bar
HP-0045
Emergency Diesel Generator (EDG) Fuel Linkage Parts
10/12/2004
237-3-902-2
Oil Sample Analysis Report
06/28/2023
24454
Commercial Grade Survey Report Transmittal - FENOC
Survey 2017-0021
07/05/2017
24974
NUPIC Joint Commercial Grade Survey of Swagelok
Company
03/05/2021
77720102
Test Data Package - Fill Cap
Rev. 1
CJ18840-1
Dedication Plan for Garolite Sheet
Rev. 0
Miscellaneous
EM-C-2130
Bus Operation and Maintenance
08/30/2022
2-EHP-5043-
CGD-001
Rev. 22
2-EHP-5043-
SLE-001
Shelf Life
Revs. 9, 10,
2-MMP-3120-
NETS-001
Receipt Inspection of Safety Related/Safety Interfaced
Material and Equipment
Rev. 23
2-MMP-3120-
NETS-001
Receipt Inspection of Safety Related/Safety Interfaced
Material and Equipment
Rev. 16
Procedures
2-MMP-7090-
NETS-011
Material Testing
Rev. 11
01591934
Receipt Inspection Report - 185731
07/26/2021
01593390
Receipt Inspection Report - 62725200
06/02/2021
01597677
Receipt Inspection Report - 0001374362, 0001374363
10/27/2022
01600299
Receipt Inspection Report - 196836
08/07/2020
01601287
Receipt Inspection Report - 198407
03/11/2021
Shipping Records
197350
Receipt Inspection Report Bus Bar PO# 01599553
09/24/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
C1001629
Receipt Inspection Report Pressure Gauge for EDG
C1004435
Receipt Inspection Report - 1386277
08/31/2022
C1004553
Receipt Inspection Report for Mechanical Seal
C1005296
Receipt Inspection Report - 1388211
2/12/2022
C1005443
Receipt Inspection Report - 1388079, 1388081
11/09/2022
C1005887
Receipt Inspection Report - 1389264
2/13/2023
RTN-23933
Receipt Inspection Report - 1389380
01/26/2023
55522280-01
MTH: 2-HV-ACRA-1; Investigate Abnormal Noise
10/24/2019
55550267-06
MTM, 1-WRV-761-ACT, Remove Air Line TCC/EC-57644
2/18/2021
Work Orders
C10038459001
2-TK-47-CD, Replace Locking Fill Cap
03/01/2023