IR 05000315/2024050
| ML24345A203 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/11/2024 |
| From: | Jason Kozal NRC/RGN-III/DORS |
| To: | Ferneau K Indiana Michigan Power Co |
| References | |
| IR 2024050 | |
| Download: ML24345A203 (1) | |
Text
SUBJECT:
DONALD C. COOK NUCLEAR PLANT - SPECIAL INSPECTION REACTIVE REPORT 05000315/2024050 AND 05000316/2024050
Dear Kelly Ferneau:
On July 26, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed its assessment of multiple frequency related emergency diesel generator failures occurring from October 2022 through July 2024, which occurred on July 23, 2024, at Donald C. Cook Nuclear Plant. Based on this assessment, the NRC sent an inspection team to your site on August 19, 2024.
On October 31, 2024, the NRC completed its special inspection 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.
Three findings of very-low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Donald C. Cook Nuclear Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Donald C. Cook Nuclear Plant.
December 11, 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, Jason W. Kozal, Division Director 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:
05000315/2024050 and 05000316/2024050
Enterprise Identifier:
I-2024-050-0002
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Plant
Location:
Bridgman, Michigan
Inspection Dates:
August 19, 2024, to August 23, 2024
Inspectors:
K. Fay, Senior Reactor Inspector
M. Gangewere, Reactor Inspector
J. Winslow, Senior Project Engineer
Angela Prenger, Project Engineer
Approved By:
Jasmine Gilliam, Chief
Engineering Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a special 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 Procedure 1-2-EDS-722 When Attaching Banana Jack Adapters Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000315,05000316/2024050-01 Open/Closed
[P.3] -
Resolution 93812 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to accomplish activities affecting quality in accordance with documented instructions, procedures or drawings. Specifically, the licensee failed to follow design instruction 1-2-EDS-722 Terminal Strip Banana Jack Adapters when installing replacement Pomona Jacks.
Failure to Identify and Correct Cause of May 2024 Failed 2 AB EDG Slow Speed Start Surveillance.
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000315,05000316/2024050-02 Open/Closed
[H.14] -
Conservative Bias 93812 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50,
Appendix B, Criterion XVI, Corrective Action for the licensees failure to identify and correct a condition adverse to quality. Specifically, the licensee failed to identify and correct defective equipment which prevented the 2AB EDG from meeting Technical Specification 3.8.1.2 during the May 2024 slow speed start emergency diesel generator surveillance.
Failure to Ensure Adequate Test Instrumentation in EDG Fast Start Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000315,05000316/2024050-03 Open/Closed None (NPP)93812 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50,
Appendix B, Criterion XI, Test Control for the licensees failure to ensure adequate test instrumentation was used during the 2AB Emergency Diesel Generator Fast Start surveillance test procedure. Specifically, the licensee failed to use the test instrumentation needed to verify the appropriate start time of the Emergency Diesel Generator as required in the Technical Specification.
Additional Tracking Items
None.
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.
INSPECTION RESULTS
Assessment 93812 Charter Item No. 1 - Identify a timeline for all diesel failures within the last 3 years. This timeline may include relevant and major plant conditions, system lineups, operator actions responding to the failures, and any applicable maintenance or component replacements.
From August 2022 to the time of the inspection, D.C. Cook experienced four failures of components on their emergency diesel generators (EDGs) which resulted in frequency dropping below its technical specification approved band of 59.4 to 60.5Hz. The site has four safety-related EDGs which are all Worthington SWB-12 models. The inspectors identified and evaluated one additional failure occurring on July 12, 2022, as possibly being related to the other four failures. In four of the five cases, one of the four safety-related EDGs were rendered inoperable due to the component failures.
The first component failure occurred during the 2CD slow speed surveillance test on July 12, 2022, when the licensee detected a complete loss of loading while paralleled to the grid. The 2CD EDG was declared inoperable, and licensees troubleshooting determined an intermittent fault from dirty contacts on the mechanism operated contact (MOC) switch for the droop circuit relay resulted in the EDG dropping load. The failed component was adjusted on July 14, 2022, and tested satisfactorily on July 15, 2022.
The second component failure occurred during a Unit 2 outage on October 2, 2022, when the 2CD EDG frequency unexpectantly lowered to 59.2Hz during integrated Load Sequence and Engineered Safety Features (ESF) testing. The 2CD EDG was already declared inoperable to perform the testing, but the licensee determined it could have performed its safety function with the degraded condition. The most likely cause was determined to be the 2301A Governor and Digital Reference Unit (DRU). The 2301A Governor and DRU were replaced October 17. 2022, retested satisfactorily on October 17, 2022, and declared operable.
The third component failure occurred during a slow speed surveillance test of the 2CD EDG on August 10, 2023, when the frequency dropped out of its allowed technical specification band of 59.4Hz to 60.5Hz. The frequency dropped to 58Hz and then rose to 59Hz and stabilized. The 2CD EDG was declared inoperable, and the most likely cause was determined to be a cracked solder joint on pin number 1 of the DRU. The DRU was replaced August 13, 2023, and was retested satisfactorily on August 13, 2023.
The fourth component failure occurred during a slow speed surveillance test of the 2AB EDG on May 21, 2024, when the frequency failed to reach its technical specification band of 59.4Hz to 60.5Hz. The 2AB EDG stabilized at 59.3 Hz and then oscillated between 59.3Hz and 60Hz. The 2CD EDG was declared inoperable, and the most likely cause was determined to be the minimum speed threshold and slow start control relay. The relays were replaced May 22, 2024, and the 2AB EDG was retested satisfactorily on May 22, 2024.
This event was evaluated under the Management Directive 8.3 (ML24199A199).
The fifth component failure occurred during a fast speed surveillance test of the 2AB EDG on July 23, 2024, when the frequency failed to reach its technical specification band of 59.4Hz to 60.5Hz. The 2AB EDG stabilized at 59.3 Hz after startup, operators then took manual control to raise frequency within band which resulted in frequency unexpectantly jumping between 59.7Hz and 60.2Hz. The 2CD EDG was declared inoperable, and the most likely cause was determined to be the DRU. The DRU was replaced on July 23, 2024, and the 2AB EDG was retested satisfactorily on July 23, 2024. This event was evaluated under the Management Directive 8.3 (ML24214A330) process and the NRC determined that a special inspection was appropriate.
NRC Region III dispatched a Special Inspection Team (SIT) on August 19, 2024, to review the diesel generator component failures in accordance with the SIT charter.
Detailed Sequence of Events 6/2013. DRU 13576302 was installed in the 2CD EDG as part of a preventive maintenance activity.
7/12/2022. The 2CD EDG was declared inoperable for a planned slow speed start surveillance test. Action Request (AR) AR 2022-5752 was written later by the licensee for a complete loss of loading while paralleled to the grid during the slow speed start surveillance test. The 2CD EDG unloaded, and the frequency lowered from 60Hz to 58.5Hz.
7/15/2022. The 2CD EDG was declared operable after troubleshooting and a satisfactory slow speed start surveillance test.
8/1/2022. The licensee determined the dirty contacts on the MOC switch, combined with a slight misalignment, was the cause for complete loss of loading.
10/2/2022. The 2CD EDG was declared inoperable for a planned Load Sequence and Engineered Safety Features (ESF) test. AR 2022-7748 was written later by the licensee for the frequency unexpectedly lowering from 60.01Hz to 59.2Hz during the integrated ESF test.
Later in the test procedure, the licensee adjusted the frequency to 60Hz with expected behavior. DRU 13576302 was removed from the 2CD EDG and replaced with DRU 14484581 as part of troubleshooting activities.
10/17/2022. The 2CD EDG was declared operable after troubleshooting and a satisfactory fast speed start surveillance test.
10/31/2022. The licensee determined a past operability evaluation was not necessary because the previous failure on 7/12/2022 was related to the MOC switch and the 10/2/2022 failure was related to the electronic governor.
12/15/2022. The licensee determined the most likely cause to be the electronic governor for the unexpected lowering of frequency during testing.
1/30/2023. The vendor analysis report was completed on DRU 13576302. No failure mechanism could be identified, and the vendor suggested it could be the raise/lower switch or the droop circuit. The licensee eliminated the raise/lower switch as the cause but could not refute the droop circuit.
8/10/2023. The 2CD EDG was declared inoperable for a planned slow speed start surveillance test. During the test, frequency dropped to 58Hz and then rose to 59Hz and stabilized.
8/11/2023. DRU 14484581 was removed from the 2CD EDG and replaced with DRU 14523850 as part of troubleshooting activities.
8/12/2023. AR 2023-5770 was written by the licensee for the frequency dropping to 58Hz and then rising to 59Hz and stabilizing during the slow speed start surveillance test. The 2CD EDG was not synchronized to the associated bus before the drop and rise, leading to the test being aborted.
8/13/2023. The licensee identified cracked soldering on a pin used in DRU 14484581.
8/14/2023. The 2CD EDG was declared operable after troubleshooting and a satisfactory slow speed start surveillance test.
9/2023. DRU 14484581 was sent to the vendor for failure analysis and repair for intermittent failure and the cracked soldering.
10/11/2023. The vendor analysis report was completed on two DRUs regarding the cracked soldering. The vendor determined the cause of the cracking to be from creep fatigue due to mechanical stress from the Pomona Jacks, banana clips used to connect test equipment to electrical devices, which did not meet the Institute of Printed Circuits (IPC) standards.
10/22/2023. The Pomona Jacks on the 1AB EDG were replaced with different model.
10/29/2023. The Pomona Jacks on the 1CD EDG were removed.
1/2/2024. DRU 14523849 was removed from the 2CD EDG as part of a preventive maintenance activity. Additionally, the Pomona Jacks on the 2CD EDG were removed.
3/19/2024. DRU 14484581 was installed in the 2AB EDG as a part of the corrective actions to address extent-of-condition from the 2CD EDG degraded DRU issue. Additionally, the Pomona Jacks on the 2AB EDG were removed.
5/21/2024. The 2AB EDG was declared inoperable for a planned slow speed start surveillance test. AR 2024-4497 was written later by the licensee for the frequency stabilizing at 59.3Hz and then oscillated between 59.3Hz and 60Hz during the slow speed start surveillance test. Minor manual adjustments to the frequency caused jumps between the two values with a blackout zone in between and audible changes in speed.
5/22/2024. The 2AB EDG was declared operable after troubleshooting and a satisfactory slow speed start surveillance test.
6/20/2024. The licensee determined the most likely cause of the oscillating frequency to be corrosion on the control relays for minimum speed threshold and slow start relays.
7/23/2024. The 2AB EDG was declared inoperable for a planned fast speed start surveillance test. AR 2024-5817 was written later by the licensee for frequency stabilizing at 59.3Hz after startup, then operators took manual control to raise frequency within band, which resulted in frequency unexpectantly jumping between 59.7Hz and 60.2Hz during a fast speed start surveillance test.
7/24/2024. DRU 14484581 was removed from the 2AB EDG and replaced with DRU 14523850 as part of troubleshooting activities. The 2AB EDG was declared operable after the troubleshooting and a satisfactory fast speed start surveillance test.
9/9/2024. The licensee completed bench testing on DRU 14484581 and determined the possible cause to be the potentiometer for both the May 2024 and July 2024 2AB EDG failures.
Assessment 93812 Charter Item No. 2 - Review the licensees troubleshooting efforts and follow-up actions for each failure reviewed as part of Charter Item #1 to assess the adequacy of the licensees efforts, including the extent of the condition.
2CD Emergency Diesel Generator: July 12, 2022 The licensees troubleshooting efforts found the reason for the 2CD EDG suddenly dropping load on July 12, 2022, was caused by an intermittent fault from dirty contacts on the mechanism operated contact (MOC) switch for the droop circuit relay resulting in the EDG dropping load. Upon further inspection, the MOC switch was determined to also have been slightly misaligned. The combination of the dirty contacts and misalignment caused the governor to switch from droop to isochronous mode while paralleled to the electrical grid and could result in the EDG shutting down.
The licensee was able to replicate the condition on a second 2CD EDG run, but did not hook up test equipment for monitoring. The 2CD EDG was brought to full load and after 20 minutes the load dropped to 0kW with no operator action. The Failure Investigation Process (FIP)team considered the 2-65X-DGCD HFA relay as a potential cause because of how it functions to maintain the governor in droop mode, but upon further testing, determined the MOC switch was the most likely cause.
The licensee performed a third run of the 2CD EDG with test equipment hooked up but were not able to replicate the condition. The FIP team consulted with a vendor who specializes in diesel generator governors and DRUs and concluded a governor failure would not be intermittent based on the EDG running successfully after the initial events; therefore, it is not the cause. The licensee cleaned and adjusted the MOC switch and performed a post maintenance and surveillance test satisfactorily.
The MOC switch and 2-65X-DGCD HFA relay were later replaced during the next refueling outage and a failure analysis was performed on both components. The inspectors noted a condition evaluation was performed as a corrective action item, and the most likely cause was changed to dirty contacts on the 2-65X-DGCD HFA relay after the failure analysis did not identify any issues with either component. The team concluded that the licensees troubleshooting efforts and extent-of-condition reviews were reasonable but noted no further consideration was given to the governor or DRU after the failure analysis of the two components did not identify any issues.
2CD Emergency Diesel Generator: October 2, 2022 The licensees troubleshooting efforts found the reason for the 2CD EDG lowering in frequency during Load Sequence and Engineered Safety Features (ESF) testing was caused by a failure of the 2301A Governor and Digital Reference Unit (DRU). After testing was completed, a FIP team was formed, and a support/refute matrix and fault tree analysis were performed. The FIP team discussed installing test instrumentation on the 2CD EDG governor and performing another test run, but a determination was made to replace the governor and DRU because no other components in the system would lead to similar results.
The governor and DRU units were replaced and sent out for failure analysis testing. After 10,000 cycles on the governor and DRU units the condition was not able to be repeated and was considered a one-time spurious incident.
During the 2CD EDG Load Sequence and Engineered Safety Features (ESF) the licensee was able to manually raise frequency back to its technical specification approved band after it spontaneously dropped low out of band. The licensee determined the 2CD EDG would have performed its safety function during a design basis accident. The inspectors concluded the licensees troubleshooting efforts were reasonable but noted no correlation was identified between the July 12, 2022, failure and this failure because the July 12, 2022, failure was attributed to the MOC switch during the past operability evaluation.
2CD Emergency Diesel Generator: August 8, 2023 The licensees troubleshooting efforts found the reason for the 2CD EDG lowering in frequency during a slow speed start surveillance test was caused by a cracked solder joint on pin number 1 of the DRU. Specifically, pin number 1 of the DRU provides power to the DRU card and an interruption in power to only the DRU results in a signal to shut the EDG fuel racks causing a lowering in frequency. The function of the DRU is to allow operators to adjust the frequency during EDG operation.
The failure of the DRU was identified after test instrumentation was installed on subsequent runs of the 2CD EDG, and the output signal could be observed decreasing when technicians would lightly agitate wires connected to pin number 1. The failure mechanism was confirmed by independent vendor testing and was determined to be caused by stress introduced during the manufacture of components, due to not adhering to IPC standards, leading to creep fatigue cracking of the solder joints. The vendor additionally determined the addition of Pomona Jacks on the DRU along with a lack of vendor guidance on terminal screw torque allowed stress to be added to the joints and potentially propagate a crack.
The licensee determined all DRUs in all four EDGs were approximately the same age and corrective action was taken to reflow solder joints, remove Pomona Jacks from DRUs, and standardize terminal screw torque on DRUs. The inspectors determined the licensees troubleshooting efforts, extent-of-condition reviews, and actions performed were reasonable, but noted a different style of Pomona Jack on the 1AB EDG. Additional details associated with the Pomona Jacks are documented in a finding and associated non-cited violation 05000315,05000316/2024050-01.
2AB Emergency Diesel Generator: May 21, 2024 The licensees troubleshooting efforts found the reason for the 2AB EDG not achieving frequency in the technical specification approved band and randomly changing frequency during a slow speed start surveillance test was caused by corrosion on the minimum speed threshold relay and the slow start control relay. Specifically, corrosion prevented the relay from energizing and demanding a setpoint signal of 60Hz from the DRU.
The licensee postulated the DRU output signal would have been lowered during the unloading of the diesel during the April slow speed surveillance run and may have resulted in a lower startup frequency on the May 21, 2024. Additionally, the licensee explained the fluctuations observed in frequency were a result of the relay intermittently energizing and shutting and opening of the setpoint contact. The function of the minimum speed threshold relay and the slow start control relay is to ensure the EDG properly comes up to 60Hz given a slow or fast start demand on the EDG.
The inspectors questioned the as-left condition of the DRU output setting after discovering operators set the frequency to 60Hz prior to EDG shutdown at the end of the slow speed start surveillance procedure. Furthermore, the inspectors questioned how fluctuating frequency could be related to the setpoint demand feature of the DRU after it was understood frequency would be locked in at 60Hz once setpoint was demanded. Following discussion with the NRC, the licensee wrote corrective action document AR 2024-6894, 2AB EDG frequency only reached 59.3 Hz and was oscillating which stated, During further evaluation of the cause for the failure in May (AR 2024-4497), resulting from the incorrect assumption documented by AR 2024-6726, it was determined that the failure was likely due to the DRU and is related to the failure in July (AR 2024-5817).
The inspectors concluded the licensees troubleshooting efforts failed to identify and correct the degraded condition observed on the 2AB EDG on May 21, 2024. Furthermore, the inspectors noted less rigor applied to the May 21, 2024, troubleshooting effort compared with the other four failures. Examples of less rigor included, the support/refute matrix not fully filled out, the charter for the FIP team not fully filled out, there was no as-found or as-left testing performed on the minimum speed threshold relay or the slow start control relay, and no post-event critique performed as required by procedure. Additional details are documented in a 05000315,05000316/2024050-02.
2AB Emergency Diesel Generator: July 23, 2024 The licensees troubleshooting efforts found the reason for the 2AB EDG not achieving frequency in the technical specification approved band and jumping in frequency when operators manually adjusted it during a slow speed start surveillance test was caused by a failure of the 2AB EDG DRU. Specifically, during subsequent EDG testing, with test equipment installed, the output signal was observed to be acting erratically when frequency was raised and lowered by plant operators.
The licensee determined from traces of test equipment installed on the DRU that when operators issued a change request for frequency, the DRU was making a large step change in frequency outside the requested band. Additionally, they recognized the DRU was unable to maintain the frequency between 59.7-60.1 Hz.
The licensee replaced the DRU and found there was reasonable assurance that the issue is confined to only the DRU installed in the 2AB EDG because the vendor was unaware of any other instances of this failure occurring, all DRUs were recently refurbished, and there were older DRUs in the plant which have not exhibited this issue. The DRU is an electrical device with over 200 subcomponents making it difficult to isolate the specific failure mechanism.
The postulated cause is a degraded low limit potentiometer.
The inspectors noted the licensee was unaware the same DRU which failed on the 2CD EDG on August 23, 2023, was refurbished with fresh solder connections and reinstalled in the 2AB EDG in March of 2024. The inspectors concluded the licensees troubleshooting efforts and extent-of-condition reviews were reasonable.
Conclusion The licensee is planning to replace the current low voltage DRUs with new high voltage DRUs because new low voltage DRUs are no longer manufactured. The inspectors also noted during the course of the inspection the licensee was not making use of quarantine process to preserve the as-found condition of defective equipment. Additionally, the inspectors noted a robust but flexible troubleshooting process which was not consistently implemented from failure to failure.
Assessment 93812 Charter Item No. 3 - Review the licensees evaluations of the EDG failures, including operability, functionality, reliability, and availability assessment of the EDGs and the impacts to their safety systems loads.
Assessment Overview:
The team performed an in-depth review of five corrective actions associated with the EDG failures. From these five failures, the licensee performed the following:
- 3 Condition Evaluations (July 2022, October 2022, and May 2024)
- 1 Apparent Cause Evaluation (August 2023)o Including 1 condition evaluation for the Part 21
- 2 Past Operability Determination Evaluations Reliability:
The inspectors noted that the licensees corrective action procedure requires them to complete an equipment reliability assessment when a critical component failure occurs.
From the three condition evaluations performed, two (October 2022 and May 2024) included an equipment reliability assessment. However, the inspectors noted no prevention, detection or correction attributes were identified to be applicable.
The inspectors found the one apparent cause evaluation (ACE) completed August 2023, identified the cause of the loss of power to the DRU was due to a cracked solder joint, with the first contributing cause due to the addition of the Pomona Jacks that allowed additional stress on the solder joints. The second contributing cause was lack of vendor guidance on terminal screw torques. An organizational and programmatic failure modes, and human performance review were completed; however, no leadership, teamwork, or worker behaviors were identified to have contributed to this event. An equipment reliability review was also completed, and the inspectors noted the Part 21 and lack of vendor guidance were captured in the attributes noted; however, there were no attributes or contributors identified for the first contributing cause of addition of Pomona Jacks.
The inspectors also found the ACE did not include any aspects from the information notice recommendation to limit the DRU to one refurbishment and replacement thereafter for limiting the additional cycles on the terminal screws to limit the likelihood of low cycle fatigue.
As a result of the July 23, 2024, failure of the Unit 2 AB EDG, the licensee performed a common cause evaluation in support of operability of the redundant EDGs at Units 1 and 2.
This common cause paper provided reasonable assurance that this issue was confined only to the DRU installed in the Unit 2 AB EDG. Additionally, the licensee initiated an action to perform a new Equipment Apparent Cause Evaluation on July 29, 2024, which includes another common cause on all four underfrequency events including: ARs 2022-5752, 2023-5760, 2024-4497, and 2024-5817. This was not completed at the time of the inspection and therefore, not reviewed as a part of this inspection.
Operability:
The inspectors noted, AR 2024-6894 was initiated on September 12, 2024, as a result of this inspection and determined that the May 2024 failure was most likely due to the DRU and is related to the July 2024 failure. A past operability review is currently being conducted to properly evaluate this new condition.
Past surveillances were reviewed, and there were no instances of the results being out of the allowable band if instrument uncertainty were accounted for due to the prior step verifying that the temporary installed fluke was within tolerance.
Availability:
Additionally, as part of Charter Item 1, the team reviewed the planned and unplanned unavailability hours for each of the failures. The inspectors concluded all of the hours completed at the time of the inspection fell into the planned unavailability of the EDG allotted outage time. The unavailability data was not complete for the July 2024 failure; therefore, the inspectors were unable to review it. The inspectors found the planned unavailability hours reasonable.
Functionality:
As part of Charter item 2 and 4, functionality, and functional failures were reviewed. Results will be captured under that item for this aspect.
In conclusion, during the review of the five failures, the team noted a narrow focus during each of the respective failures. Failures were not thoroughly evaluated in aggregate to take an in-depth look at commonalities (e.g., same DRU in 3 of 5 failures) between failures.
Only specific differences to eliminate any potential common causes were noted.
For example,
- In the Operability Determination Supplement for the July 2022 failure, the identified cause was an intermittent failure/fault in the T21D8 MOC switch and stated the HFA relay was refuted, and the Governor/DRU was only ruled out due to vendor expertise.
- The condition evaluation was completed in February of 2023 and the HFA relay was identified as the cause of this failure This stated that the scope of this evaluation did not include the Governor or DRU, and further examination of those components would be performed under the October 2022 AR.
- The Past operability review (AR 2022-7748-2) for the October and July failures prior to completion of this CE evaluated only the MOC switch as the failure.
- The NRC inspection team noted during the October 2022 failure, the governor, DRU, MOC switch, and HFA were all removed and replaced from the system during the outage at the same time and all bench tested, which prevented verification of each of the causes. The testing results for all four components came back satisfactorily.
- The October 2022 failure was then evaluated under a separate Condition Evaluation with the cause identified as a one-time spurious failure that could not be replicated in testing.
Assessment 93812 Charter Item No. 4 - Assess the licensees maintenance practices and monitoring of the diesel generator system performance information, including the system health reports, corrective action program for trends, and overall timeliness and effectiveness of evaluating associated failures, degradations, and deficiencies.
The inspectors determined overall, in system health reporting and trending, the licensee did not identify any EDG trends for these failures as part of their trending process, nor did the EDG system fall below green status on the system health report scorecard. For the maintenance rule, the EDG system has not had an (a)(1) action plan since 2009.
The inspectors identified the licensee did not properly evaluate the October 2022 frequency drop during LOP/LOCA testing as being a functional failure. The inspectors also questioned that for the July 2024 failure, no maintenance rule evaluation screening occurred. ARs were written for both issues.
As discussed in the previous charter item, the inspectors noted that some EDG parameters, such as exhaust temperatures and slow speed start timing, were routinely out of the band identified in the procedures (sensitivity to issues). ARs are not typically written for these issues. Although these parameters were not acceptance criteria, informal documentation and trending of these items may remove opportunities to identify trends at a low level through meeting a threshold of formal trending, especially if items are interrelated on a system.
Assessment 93812 Charter Item No. 5 - Review the effectiveness of the licensees problem identification and resolution (PI&R) program in identifying, prioritizing, evaluating, and correcting EDG problems. Also, review whether the licensees use of internal and external operating experience for these problems is adequate.
During review of these EDG issues, the inspectors did not identify any instances where the licensee did not follow their process. The inspectors determined the licensee was aware of failures and past issues, but as already discussed, a holistic view of issues not was not captured, such as commonalities and trends.
The inspectors reviewed the licensees procedures associated with operating experience, evaluations of operating experience, and operating experience reviewed as part of EDG troubleshooting and assessments. The inspectors determined the licensees use of operating experience was reasonable. The inspectors noted no formal benchmarking was completed, however, contact with the vendor/owners group is apparent.
In conclusion, the inspectors noted that the licensee had narrow focus on manufacturing defects and vendor analysis and lacked a self-critical focus on the areas within their ability to improve.
Failure to Implement Procedure 1-2-EDS-722 when Attaching Banana Jack Adapters Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000315,05000316/2024050-01 Open/Closed
[P.3] -
Resolution 93812 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to accomplish activities affecting quality in accordance with documented instructions, procedures or drawings. Specifically, the licensee failed to follow design instruction 1-2-EDS-722 Terminal Strip Banana Jack Adapters when installing replacement Pomona Jacks.
Description:
The Woodward Digital Reference Unit (DRU) had operating experience of terminal strip-to-circuit board solder connection experiencing low cycle fatigue failure which resulted in intermittent continuity. Vendor Information Notice, IN-23-09, Precautions Regarding Woodward DRU, identified a contributing factor to this failure was the use of external monitoring equipment and the additional stress at the solder joint from the moment arm exerted by Pomona brand banana jacks with unsupported wire weight.
EDG modification 1-MOD-35181 1AB/1CD Emergency Diesel Generator Replacement Speed Governing System evaluated the use of Pomona Banana Jack adapter models 5699, 5700, and 5701. AR 2023-5760, 2CD EDG Frequency Drop After Start but before Synch to T21D Task 24 directed the removal of all Pomona Jacks on the DRUs installed in the plant.
Work Order Evaluation 2100020650 Engineering Guidance for the Change to the use of Pomona Jacks for DRUs recommended to replace the screw style banana jack with the spade/ring terminal type Model 3777A or equivalent to reduce the stress on the solder joints.
While installing the modification, the licensee failed to follow three sections of the design standard 1-2-EDS-722 Terminal Strip Banana jack Adapters. First the licensee did not meet Section 1.1.2 which states, Ring tongue terminal is to be soldered to the test adapter utilizing site approved work instructions or procedure. The licensee did not remove the existing spade lug and solder on a ring terminal as specified in Section 1.1.2. Second, the licensee failed to attach the insulated barrel of the test adapter and the second wire with a ty-rap; therefore, not meeting Section 1.3.2 which states, If the ring tongue test adapter is installed on a terminal point associated with another wire, the insulated barrel of the test adapter is also to be attached to the associated wire with a Ty-rap or approved equivalent wire tie.
Third, the licensee installed non-safety-related adapters on the DRU contrary to Section 2.2 which states, Material safety classification of the terminal strip banana jack adapters shall match the safety classification of the electrical circuit the adapter is being installed in.
Corrective Actions: Following interactions with the inspectors the licensee decided to remove the Pomona Jacks from the 1AB EDG.
Corrective Action References: AR 2024-6480
Performance Assessment:
Performance Deficiency: The licensees failure to accomplish activities affecting quality in accordance with documented instructions, procedures, or drawings to install replacement Pomona Jacks was contrary to 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, and was a performance deficiency. Specifically, the licensee failed to follow design instruction 1-2-EDS-722 Terminal Strip Banana Jack Adapters when installing replacement Pomona Jacks.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, installing non-safety-related adapters on the safety-related Digital Reference Unit failed to ensure the material safety classification of the terminal strip banana jack adapters matched the safety classification of the electrical circuit the adapter was being installed, therefore affecting the availability and reliability of the Emergency Diesel Generator.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Using Exhibit 2, Mitigating Systems Screening Questions, the Team was able to answer yes to question A.1 and determined the finding to be of very-low safety significance (Green). Specifically, the degraded condition of incorrectly installing the Pomona Banana Jacks did not represent a loss of operability or PRA system function.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensees corrective action AR 2023-5760 task 24 stated Remove the Pomona jacks on the DRUs installed in the plant and the licensee failed to adequately evaluate the change of their corrective action.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The licensee established 1-2-EDS-722, Terminal Strip Banana Jack Adapters as the implementing procedure for installing banana jack, an activity affecting quality.
Procedure 1-2-EDS-722, Section 2.2 states, Material safety classification of the terminal strip banana jack adapters shall match the safety classification of the electrical circuit the adapter is being installed in.
Contrary to the above, on October 22, 2023, the licensee failed to follow Section 2.2 of procedure 1-2-EDS-722. Specifically, the licensee installed non-safety-related adapters on the safety-related Digital Reference Unit and failed to ensure the material safety classification of the terminal strip banana jack adapters matched the safety classification of the electrical circuit the adapter was being installed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Identify and Correct the Cause of May 2024 Failed 2 AB EDG Slow Speed Start Surveillance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000315,05000316/2024050-02 Open/Closed
[H.14] -
Conservative Bias 93812 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action for the licensees failure to identify and correct a condition adverse to quality. Specifically, the licensee failed to identify and correct defective equipment, which prevented the EDG from meeting Technical Specification 3.8.1.2 during the May 2024 slow speed start emergency diesel generator surveillance.
Description:
On May 22, 2024, the 2AB EDG frequency failed to reach its technical specification band of 59.4Hz to 60.5Hz. The licensees evaluation of the failure concluded that corrosion prevented the relay from energizing and demanding a setpoint signal of 60Hz from the DRU. This conclusion was based on the assumption that the DRU output signal would have been lowered during the unloading of the diesel during the April slow speed surveillance run and may have resulted in a lower startup frequency on the May 21, 2024.
During the inspection, the inspectors questioned the as-left condition of the DRU output setting after discovering operators set the frequency to 60Hz prior to EDG shutdown at the end of the slow speed start surveillance procedure. Following discussions with the inspectors, the licensee wrote corrective action document AR 2024-6894 which stated, During further evaluation of the cause for the failure in May (AR 2024-4497), resulting from the incorrect assumption documented by AR 2024-6726, it was determined that the failure was likely due to the DRU and is related to the failure in July (AR 2024-5817).
The inspectors concluded the licensees troubleshooting efforts failed to identify and correct the degraded condition observed on the 2AB EDG on May 21, 2024.
Corrective Actions: The licensee replaced the DRU on the 2AB EDG and is performing a Past Operability Review for the potential for the two events to be related.
Corrective Action References: AR 2024-4497 and AR 2024-6894
Performance Assessment:
Performance Deficiency: The inspectors determined the licensee failed to identify and correct defective equipment which prevented the EDG from meeting Technical Specification 3.8.1.2 during the May 2024 slow speed start emergency diesel generator surveillance was contrary to 10 CFR Part 50 Appendix B, Criterion XVI, Corrective Action and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to properly identify and correct the degraded condition observed on the 2AB EDG on May 21, 2024, affected the availability and reliability of the 2AB Emergency Diesel Generator.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, dated January 1, 2021. The inspectors answered Question 3 of Exhibit 2, Mitigating Systems Screening Questions, YES because the degraded condition represents a loss of the PRA function of one train of a multi-train TS system for greater than the allowed technical specification outage time. Since this question was answered YES, a detailed risk evaluation was required.
A senior reactor analyst performed a detailed risk evaluation using SAPHIRE version 8.2.11 and the Cook SPAR model version 8.82 to assess the significance of the finding. Results from the licensees probabilistic risk assessment model were reviewed and considered best-available information to assess the significance of the finding for fire and large early release frequency (LERF). The following assumptions and factors were considered in the quantification:
- The exposure period for the finding was 63 days, beginning after the failed surveillance in May 2024.
- The failure modeling for the finding was represented as degraded, rather than catastrophic, resulting in an increased rate for failure to run of the 2AB EDG.
The basis for this assumption was the licensees determination that the degraded frequency experienced in May and July of 2024 was sufficient to accept loads and support mitigating system success criteria. The inspectors independently reviewed this evaluation and identified no issues.
- An increased failure rate for the 2AB EDG failure to run was calculated by using plant-specific operating experience from 2024, conservatively assuming the May and July failed surveillances to be functional failures, to update NUREG/CR-6928 industry-average parameter data from 2015. This resulted in a failure rate of 6.45E-2.
Sensitivity cases for an update of average parameter data from 2020 and a failure rate of 0.1 were also considered.
- The Cook SPAR model is Unit 1 specific, so the basic event for 1AB EDG failure to run was used as a surrogate to represent the finding.
- Credit was given for flexible coping strategies (FLEX).
The resultant change in core damage frequency was estimated to be less than 1E-6/year in the best-estimate and sensitivity cases. Therefore, the finding was determined to be of very-low safety significance (Green). The change in LERF was determined to be of very-low safety significance (Green) in the best-estimate and sensitivity case. The dominant core damage sequences for the finding were driven by fires originating from the main transformers. These scenarios involved a fire-induced loss of offsite power (LOOP) due to damage of reserve feed, failure of the 2CD EDG due to loss of power to the supply and exhaust fan, failure of the 2AB EDG due to the finding, and core damage due to Station Blackout (SBO) without available mitigation.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee failed to properly evaluate the resistance of the relay before and after cleaning off the corrosion, which led to improperly identifying the relay as the proximate cause of the failed 2AB slow speed start surveillance.
Enforcement:
Violation: 10 CFR Part 50 Appendix B, Criterion XVI, Corrective Action states, in part, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, from May 2024 to July 2024, the licensee failed to establish measures to assure that conditions adverse to quality are promptly identified and corrected. Specifically, the licensee failed to identify and correct defective equipment which prevented the EDG from meeting Technical Specification 3.8.1.2 surveillance during the May 2024 slow speed start emergency diesel generator surveillance.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Ensure Adequate Test Instrumentation in EDG Fast Start Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000315,05000316/2024050-03 Open/Closed None (NPP)93812 The NRC identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control for the licensees failure to ensure adequate test instrumentation was used during the 2AB Emergency Diesel Generator Fast Start surveillance test procedure. Specifically, the licensee failed to use the test instrumentation needed to verify the appropriate start time of the Emergency Diesel Generator as required in the Technical Specification.
Description:
Technical Specification Surveillance Requirement 3.8.1.8. step a requires verification that each EDG starts in less than or equal to 10 seconds with voltage greater than or equal to 3910V and frequency greater than or equal to 59.4 Hz during a fast speed start. This surveillance requirement is met by performing test procedure 2-OHP-4030-232-027AB, AB Diesel Generator Operability Test (Train B), step 4.20.7. ECP-1-2-O0-44, Instrument Uncertainty Review, Rev. 19 determined that the installed instrumentation would not meet the criteria required in the procedure after the instrument uncertainty was determined by calculation ECP-1-2-UNC-111, EDG Speed Instrument Uncertainty, Rev. 10. The licensee therefore determined test instrumentation would be used instead.
The inspectors discovered the licensee was using installed instrumentation instead of test instrumentation as required by ECP-1-2-O0-44, Rev. 10. The installed instrumentation was determined to have an added error of
.04 seconds which was not accounted for in the
fast speed start surveillance procedure. The licensee performed an operability review of recent fast speed start surveillance times and determined 1 second of margin existed and no operability concern existed.
Corrective Actions: The licensee will utilize step 4.19.4 of the fast speed start surveillance procedure 2-OHP-4030-232-027AB to install and utilize appropriate test equipment ensure technical specification acceptance criteria is met for EDG startup.
Corrective Action References: AR 2024-6986
Performance Assessment:
Performance Deficiency: The inspectors determined the licensees failure to include provisions for assuring the EDG fast start surveillance test procedure requirements were met was contrary to 10 CFR 50, Appendix B, Criterion XI, Test Control and was a performance deficiency. Specifically, the licensee failed to use the test instrumentation needed to verify the appropriate start time of the Emergency Diesel Generator as required in the Technical Specification.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to use test equipment required by the EDG Speed Instrument Uncertainty calculation to verify the Emergency Diesel Generator could timely perform its safety-related function and therefore affected the availability and reliability of the Emergency Diesel Generator.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Using Exhibit 2, Mitigating Systems Screening Questions, the Team was able to answer yes to question A.1 and determined the finding to be of very-low safety significance (Green). Specifically, the degraded condition of improperly measuring EDG rated speed did not represent a loss of operability or PRA system function.
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. Specifically, the instrument uncertainty review was performed in 2011 and the failure of using the wrong instrumentation was indicative of present performance.
Enforcement:
Violation: 10 CFR Part 50 Appendix B, Criterion XI states, in part, Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.
Procedure 2-OHP-4030-232-027AB, Attachment 2, AB Diesel Generator Operability Test (Train B) step 4.19.4 states Verify connection of Yokogawa DL 750 or equivalent is complete (N/A if not used)
Contrary to the above, from November 22, 2011, until the time of the inspection, the licensee failed to ensure adequate test instrumentation was used in surveillance test procedure 2-OHP-4030-232-027AB, Attachment 2, AB Diesel Generator Operability Test (Train B). Specifically, the licensee did not install and utilize test instrumentation on the EDG after they evaluated the installed instrumentations instrument uncertainty did not permit operators to verify Technical Specification Requirements.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 31, 2024, the inspectors presented the special inspection results to Shane Lies, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
93812
Calculations
1-2-UNC-111
CALC1
EDG Speed Instrument Uncertainty
93812
Calculations
1-2-UNC-121-
CALC1
EDG Exhaust Manifold Temperature Uncertainty Calculation
93812
Calculations
ECP-12-O0-11
EDG Speed
93812
Calculations
ECP-2-O0-45
Assessment of Unit 2 Emergency Diesel Generator
Capability
93812
Corrective Action
Documents
AR 2022-5807
Develop plan to improve EDG surveillance reliability
07/14/2022
93812
Corrective Action
Documents
AR 2022-6366
TCE Requested for MOC Switch Failures
08/09/2022
93812
Corrective Action
Documents
AR 2022-7748
U2 CD EDG Frequency Not Acceptable
10/02/2022
93812
Corrective Action
Documents
AR 2023-5760
2CD EDG Frequency Drop After Start but Before
Synch to T21D
08/11/2023
93812
Corrective Action
Documents
AR 2023-5770
DG2CD Failed to Achieve Steady State Condition on Start
08/12/2023
93812
Corrective Action
Documents
AR 2024-4532
Unit 2 AB EDG - Corrosion on Relay Connections
05/22/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6427
Clarification to 2-OHP-4030-232-027AB Att 1 Step 4.17.5d&e
08/21/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6428
Surface corrosion on EDG FFD rectifiers
08/21/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6429
MRE Screening insufficient on 2024-5817
08/21/2024
93812
Corrective Action
AR 2024-6433
Unshielded Length of EDG Governor Wiring
08/21/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
More Than Allowed
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6446
Incorrect Routing for Cable in EDISON Cable Database
08/22/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6480
EDG Test Jack Installation Gaps from Installing 1-2-EDS-722
08/23/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6724
Wrong Tolerance Used for Calibrating 2-DGAB-FREQ-REM
09/04/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6726
Incorrect Assumption During FIP for AR 2024-4497
09/04/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6815
Remove Pomona Test Jacks from Drawings
09/10/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6857
MRE Determination for AR 2022-7748
09/11/2024
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-6986
Use of Local Tachometer for EDG Surveillance
09/17/2024
93812
Corrective Action
Documents
Resulting from
AR 2024-7027
Corrective Action Not Written Using SMART Criteria
09/18/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
93812
Corrective Action
Documents
Resulting from
Inspection
AR 2024-7037
Inconsistencies in Conducting Post-Event Critiques
09/19/2024
93812
Engineering
Changes
1-MOD-35181-R0 \\ Replace the Unit 1 AB Diesel Generator \\
Governing Systems
93812
Engineering
Changes
2-MOD-35182-R0 \\ 2AB/2CD Emergency Diesel Generator
Replacement Speed Governing System
93812
Miscellaneous
93812
Miscellaneous
8003869-FA
Failure Analysis of Woodward 2301A and Woodward DRU
01/11/2023
93812
Miscellaneous
Information Notice - Precautions Regarding Woodward DRU
93812
Miscellaneous
Q4-2022 Unit 1
System Health Report
06/13/2023
93812
Miscellaneous
Q4-2022 Unit 2
System Health Report
06/13/2023
93812
Miscellaneous
Q4-2023 Unit 1
System Health Report
2/15/2024
93812
Miscellaneous
Q4-2023 Unit 2
System Health Report
2/15/2024
93812
Miscellaneous
VTD-WOOD-0063
Woodward Governor Co. Installation and Operation Manual
for 2301A Load Sharing and Speed Control with Dual
Dynamics
93812
Miscellaneous
VTD-WOOD-0065
Woodward Governor Co. Digital Reference Unit Manual with
High, Low, & Intermediate Set Points
93812
Miscellaneous
VTD-WORT-0001
Vendor Manual - Worthington Corporation Installation and
Operating Instructions for Four Cycle - Diesel and Dual Fuel
Engines
1-OHP-4030-132-
27AB
AB Diesel Generator Operability Test (Train B)
93812
Procedures
2-EHP-5035-
Maintenance Rule Program Administration
93812
Procedures
2-OHP-4030-232-
27AB
AB Diesel Generator Operability Test (Train B)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
93812
Procedures
PMI-7030
Corrective Action Program
93812
Procedures
PMI-7034
Self-Assessment and Benchmark Programs
93812
Procedures
PMP-2291-TRS-
001
Troubleshooting
93812
Procedures
PMP-3130-ISPM-
001
In-Storage Preventive Maintenance
93812
Procedures
PMP-5020-FLM-
001
Fluid Leak Management Program
93812
Procedures
PMP-7030-MOP-
001
Corrective Action Program Management Oversight Process
93812
Procedures
PMP-7030-TND-
001
Trend Analysis
93812
Procedures
PMP-7032-FIP-
001
Failure Investigation Process
93812
Procedures
PMP-7032-IRT-
001
Issue Resolution Team Process
93812
Procedures
PMP-7034-SAP-
001
Conduct of Self Assessments
93812
Self-Assessments
GT 2022-5877-2
Emergency Diesel Generator System Vulnerability
Review Report
93812
Shipping Records
PO 44842
Purchase Order and Receipt Inspection Report for DRU
2/14/2006
93812
Shipping Records
PO C1008292
Purchase Order and Receipt Inspection of Digital Speed
Reference Unit
08/28/2023
93812
Shipping Records
PO C1008650
Purchase Order and Receipt Inspection of Digital Speed
Reference Unit
10/05/2023
93812
Shipping Records
PO C1009228
Purchase Order and Receipt Inspection Report for DRU
2/20/2023
93812
Shipping Records
PO C1009427
Purchase Order for Digital Speed Reference Unit
10/31/2023
93812
Shipping Records
PO C1010232
Purchase Order and Receipt Inspection Report for DRU
2/15/2024
93812
Work Orders
C10043000007
1-DGAB-DRU, Replace Digital Reference Unit
10/22/2023