IR 05000315/2015007

IR 05000315/2015007; 05000316/2015007, September 14, 2015 Through October 2, 2015, Donald C. Cook Nuclear Power Plant, Units 1 and 2; NRC Problem Identification and Resolution

ML15308A396
Person / Time
Site:	Cook
Issue date:	11/04/2015
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	Weber L Indiana Michigan Power Co
References
IR 2015007
Download: ML15308A396 (24)

Text

November 4, 2015

SUBJECT:

DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000315/2015007; 05000316/2015007

Dear Mr. Weber:

On October 2, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) biennial inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2. The NRC inspection team discussed the results of this inspection with Mr. J. Gebbie and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report. This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the inspection samples, the inspection team determined that your staff's implementation of the corrective action program (CAP) supported nuclear safety. In reviewing your CAP, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staff's performance was adequate to support nuclear safety. The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons-learned from industry operating experience into station programs, processes, and procedures. The team determined that your station's performance in each of these areas supported nuclear safety. Finally, the team determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the team's observations, your employees are willing to raise concerns related to nuclear safety through at least one of several means available In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management Sy stem (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Kenneth Riemer, Chief Branch 2 Division of Reactor Projects

Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74

Enclosure:

IR 05000315/2015007; 05000316/2015007 w/Attachment: Supplemental Information

REGION III Docket Nos: 05000315; 05000316 License Nos: DPR-58; DPR-74 Report No: 05000315/2015007; 05000316/2015007 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Power Plant, Units 1 and 2 Location: Bridgman, MI Dates: September 14 through October 2, 2015 Inspectors: B. Bartlett, Project Engineer, Region III (Team Lead) J. Lennartz, Project Engineer, Region III J. Maynen, Senior Security Inspector, Region III N. Shah, Project Engineer, Region III M. Doyle, Region III, Inspector in Training

Approved by: Kenneth Riemer, Chief Branch 2 Division of Reactor Projects

2

SUMMARY OF FINDINGS

Inspection Report (IR) 05000315/2015007, 05000316/2015007; 09/14/2015 - 10/2/2015; Donald C. Cook Nuclear Power Plant, Units 1 and 2: Biennial Problem Identification and

Resolution (PI&R) Inspection.

This inspection was performed by four NRC regional in spectors. No findings of significance or violations of NRC requirements were identified during this inspection.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Proce ss," Revision 4, dated December 2006.

Problem Identification and Resolution On the basis of the samples selected for review, the team concluded that implementation of the corrective action program (CAP) at D. C. Cook was effective. The licensee had a low threshold for identifying problems and entering them into the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions for conditions adverse to quality were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was enter ed into the CAP and appropriately evaluated for applicability to station activities and equipment. The use of operating experience was integrated into daily activities. Audits and self-assessments were performed at appropriate frequencies and at an appropriate level to identify issues. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to raise safety concerns without fear of retaliation. The inspectors did not identify any impediments to the health of the safety-conscious work environment at D. C. Cook.

NRC-Identified

and Self-Revealed Violations None 3

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of problem identification and resolution as defined in Inspection Procedure 71152. .1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensee's CAP implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel. The inspectors reviewed risk and safety significant issues in the licensee's CAP since the last U.S. NRC problem identification and resolution inspection in September 2013. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as source s to select issues. Additionally, the inspectors reviewed action requests (ARs) generated as a result of facility personnel's performance in daily plant activities. The inspectors also reviewed ARs and a selection of completed causal evaluations from the licensee's various investigation methods, which included root cause, apparent cause, equipment apparent cause, and work group evaluations. The inspectors selected the Essential Service Water (ESW) system for a detailed review. The ESW system was selected based upon its risk significance and that a detailed plant walk down had not been performed within the last 18 months. For the ESW system a five year review was performed. The inspectors' review was to determine whether the licensee staff were properly monitoring and evaluating the performance of

this system through effective implementation of station monitoring programs. A five year review on the ESW system was also undertaken to assess the licensee staff's efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of the diesel generators to determine if there were readily identifiable issues with the system and if any identified issues were adequately described in the CAP and system health documents.

During the reviews, the inspectors determined whether the licensee staff's actions were in compliance with the facility's procedures and requirements including Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports associated with conditions adverse to quality. This included a review of completed investigations and previous NRC findings and non-cited violations.

b. Assessment

(1) Effectiveness of Problem Identification Based on the results of the inspection, the inspectors concluded that problem identification was generally effective. Based on the information reviewed, the inspectors determined that D. C. Cook personnel had a low threshold for initiating ARs; station personnel appropriately screened issues from both the NRC and industry operating experience at an appropriate level and entered them into the CAP when applicable; and identified problems were generally entered into the CAP in a complete, accurate, and timely manner. The inspectors determined that licensee personnel were generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that identified problems were generally prioritized and evaluated commensurate with their safety significance, including an appropriate consideration of risk. Higher level evaluations, such as root cause and apparent cause evaluations, were generally technically accurate; of sufficient depth to effectively identify the cause(s); and generally considered extent of condition, generic implications, and previous occurrences in an adequate manner. The inspectors determined that the initial screening committee and management review committee meetings were generally thorough and meeting participants were actively engaged and well-prepared. Initial screening committee and management review committee meetings accurately prioritized issues. The inspectors determined that, overall, licensee personnel evaluated equipment operability and functionality requirements adequately after a degraded or non-conforming condition was identified, and appropriate actions were assigned to correct the degraded or non-conforming condition. There were no items identified by the inspectors in the backlogs of the CAP or maintenance that were risk significant, either individually or collectively. The inspectors reviewed the licensee's work order backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.

Observations While the inspectors did not identify any ARs or Work Orders (WO) that were not being worked at the appropriate priority the inspectors did identify numerous examples where WO had the wrong priority level. The inspectors' review of the WO backlog identified examples where higher priority WOs remained open, one of them remained open after almost 9 years. A deeper assessment demonstrated that the WO had been completed on the equipment in question but that insulation remained to be reinstalled, or painting remained to be performed or some other minor aspect remained to be completed. The licensee did not have a process by which the high priority designation could be removed from the WO even though the high priority portion of the work had been completed. In other examples, the inspectors identified some very low priority WOs that remained in the backlog after more than 12 years. The issue identified was minor but had been placed on a low priority. The inspectors pointed that a low priority was not supposed to equate to no priority. The inspectors also pointed out that failure to complete even low priority work could lead to workers losing confidence that the CAP system could effectively address items needing repair. In one example after nine years a worker had written another AR to address a piece of equipment that had not yet been repaired. The new AR was closed to the existing open WO that has yet to be completed some three years later. The inspectors reviewed the maintenance backlog for items categorized under its work management process as Work Priority 3A (should be worked within 21 days) and 3B (should be worked in the next component outage). The inspectors reviewed several 3A and 3B work orders on safety-related equipment which were more than one year old. One example involved Work Order 55384527 which was written in 2011 to repair a leaking steam generator Power Operated Relief Valve (PORV) and was categorized as 3B in accordance with the licensee's work management process. The associated Action Request was closed upon the creation of the work order, but the work order had not yet been completed. The inspectors agreed with the licensee's conclusion that the steam generator PORV leakage did not render the PORV inoperable. However, the inspectors questioned how a 3B work order could be over 4 years old. A second example involved WO 55421433 which was written to repair leakage identified as coming from the Unit 2 west ESW strainer. Upon removal of the strainer insulation to examine the suspected area, the licensee determined that the leakage was actually condensation and that no active leak was present. The portion of the work order pertaining to the repair of the leak was canceled. However, the work order remained open pending completion of the remaining tasks. It also remained categorized as a 3B work order because it was originally classified as a 3B priority. The inspectors questioned why the work order wasn't reclassified to a lower priority once it was

determined that there was no active leak. Licensee management stated that they were assessing what should be done about the older items in the backlog. The inspectors stated that the NRC conclusion was not new to the licensee, but it had also been presented within the last year to licensee management by internal organizations (Quality Assurance) and by other outside reviewing organizations. The licensee acknowledged this comment.

(3) Effectiveness of Corrective Actions Based on the results of the inspection, the corrective actions reviewed were overall, found to be appropriately focused to correct the identified problem and were generally implemented in a timely manner commensurate with the issues' safety significance. Problems identified through root or apparent cause evaluations were generally resolved in accordance with the CAP procedures and regulatory requirements. Corrective actions intended to prevent recurrence were generally comprehensive, thorough, and timely.

The corrective actions associated with selected NRC documented findings and violations, as well as licensee-identified violations, were generally appropriate to correct the problem and were implemented in a timely manner.

Observations Three examples (minor significance) were identified where corrective actions implemented were different from the corrective action as developed/documented in the condition report; and, there was no documentation to justify why the implemented corrective action was different than the developed corrective action. Based on additional document reviews and questioning, the inspectors concluded in all cases that the corrective action taken was reasonable and appropriate:

• A corrective action (GT 2014-15348, Update Technical Data Book Figure with New Valve Position) was developed to revise the technical data book to reflect the new position for the ESW outlet valve from the containment spray heat exchanger (1-WMO-717) following ESW flow verification testing. However, the Technical Data Book valve position (8 turns from full closed) did not match the documented corrective action (7 turns from full closed).

• A corrective action was developed to implement "annual" quick hit self-assessments of the Performance Observation Program (AR 2013-12834, Performance Observation Program Assessments). However, the actual corrective action implemented was to perform assessments every two years. (The licensee generated AR 2015-12700, Integrated Self-Assessment Schedule was not Revised Properly, to address this observation.)

One example was identified where the success criteria for an effectiveness review (Root Cause Evaluation in AR 2013-10273, Cut Line Process Issue) was considered inappropriate: The documented effectiveness review success criteria included verifying that no site clock resets directly caused by a lack of standards adherence had occurred since the corrective action to prevent recurrence had been implemented. The inspectors concluded that using no clock resets as a success criteria would only prove the corrective action to prevent recurrence did not fail; however, it would not measure the effectiveness of the corrective action (i.e., was there an overall reduction in issues caused by a lack of standards adherence.) The examples in Section 2 above and in this section highlighted the inspectors' observations that:

• Some corrective actions were being closed to work orders without ensuring that the work orders were completed; and

• WOs were not being re-reviewed for priority after their initial creation. The backlog of 3B work orders contained over 600 items, but many of those work orders did not currently meet the licensee's work planning process requirements to be in the 3B category.

The licensee documented these observations in AR 2015-12836. Since a large majority of the backlog 3B work orders were for nonsafety-related systems, the inspectors concluded that the licensee's work management process was effective. No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented. b. Assessment In general, OE was appropriately used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was disseminated across the various plant departments. No issues were identified during the inspectors' review of licensee OE evaluations. The inspectors also verified that the use of OE in formal CAP products such as root cause evaluations and equipment apparent cause evaluations was appropriate and adequately considered. Generally, OE that was applicable to D. C. Cook was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations. The inspectors determined that it was unclear whether OE was properly evaluated as part of CAP cause evaluations. The inspectors identified several examples where as part of the evaluation, licensee staff identified applicable industry or internal OE, but did not discuss whether the failure to address the OE was a precursor to the event. It was unclear whether this was due to a failure to perform or document the evaluation. Licensee staff were subsequently able to determine that for the examples in question, the OE was not a precursor to the specific events. The licensee subsequently generated AR 2015-12776, "Disposition of OE Search Results," to evaluate whether OE was being properly evaluated during formal cause evaluations.

Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staff's ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits. b. Assessment Based on the results of the inspection, the inspectors did not identify any issues of concern regarding the licensee's staff's ability to conduct self-assessments and audits.

Assessments were conducted in accordance with plant procedures, were generally thorough and intrusive, adequately covered the subject area, and were effective at identifying issues and enhancement opportunities at an appropriate threshold. Identified issues were entered into the CAP with an appropriate significance characterization and corrective actions were completed and/or scheduled to be completed in a timely manner commensurate with their safety significance.

Observations The inspectors reviewed the licensee's assessment of their self-assessment and benchmarking program. The provided assessments appeared to review and assess the compliance of their programs with existing procedural requirements and did not generally look at the effectiveness of the programs. However, the inspectors overall assessment of the self-assessment process did indicate that the programs appeared to meet licensee intended requirements for identifying issues.

Findings No findings were identified.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensee's safety-conscious work environment through the reviews of the facility's employee concern program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. The site's most recent safety culture assessment was reviewed and the employee concerns program coordinators were interviewed. b. Assessment Based on the results of the inspection, the inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety-conscious work environment at D. C. Cook. Information obtained during the interviews indicated that an environment was established where licensee employees felt free to raise nuclear safety issues without fear of retaliation; were aware of and generally

familiar with the CAP and other processes, including the employee concerns program and the NRC, through which concerns could be raised; and safety significant issues could be freely communicated to supervision.

Findings No findings were identified.

4OA6 Management Meeting

.1 Exit Meeting Summary

On October 2, 2015, the inspectors presented the inspection results to Mr. J. Gebbie and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Gebbie, Site Vice-President

S. Lies, Vice-President Engineering

M. Scarpello, Regulatory Assurance Manager

D. Wood, Radiation Protection Manager

K. Ferneau, Operations Director

R. Wynegar, Regulatory Assurance

S. Mitchell, Regulatory Assurance Supervisor

V. Gupta, Performance Improvement Supervisor

J. Ross, Plant Engineering Director

Nuclear Regulatory Commission

K. Riemer, Chief, Reactor Projects Branch 2

LIST OF ITEMS

Opened

None

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but