IR 05000315/2021010: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:September 7, 2021
 
==SUBJECT:==
DONALD C. COOK NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000315/2021010 AND 05000316/2021010
 
==Dear Mr. Gebbie:==
On August 5, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Donald C. Cook Nuclear Plant. On August 5, 2021 the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
 
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
 
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
 
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
 
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
 
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
 
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, Signed by Feliz-Adorno, Nestor on 09/07/21 Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Docket Nos. 05000315 and 05000316 License Nos. DPR-58 and DPR-74
 
===Enclosure:===
As stated
 
==Inspection Report==
Docket Numbers: 05000315 and 05000316 License Numbers: DPR-58 and DPR-74 Report Numbers: 05000315/2021010 and 05000316/2021010 Enterprise Identifier: I-2021-010-0045 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Plant Location: Bridgman, MI Inspection Dates: July 19, 2021 to August 05, 2021 Inspectors: E. Fernandez, Reactor Inspector J. Mancuso, Resident Inspector R. Ng, Project Engineer G. O'Dwyer, Reactor Engineer Approved By: Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Enclosure
 
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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===
 
No findings or violations of more than minor significance were identified.
 
===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.
 
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
 
==OTHER ACTIVITIES - BASELINE==
 
===71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04) ===
{{IP sample|IP=IP 71152|count=1}}
: (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
 
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the ice condenser glycol chiller system.
 
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
 
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
 
==INSPECTION RESULTS==
Assessment: Assessment of the Corrective Action Program                                71152B Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program was generally effective and supported nuclear safety.
 
Effectiveness of Problem Identification:
Based on the samples reviewed, the team concluded that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team determined that the licensee usually entered problems into the Corrective Action Program completely and accurately. The inspectors determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety.
 
The team also noted that some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program. In addition, the licensee also utilized Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. For example, the licensee performed department self-assessments and quality assurance audits to identify issues in station processes. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.
 
The team determined that the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.
 
The team performed a 5-year review of the ice condenser glycol chiller issues. As part of this review, the team interviewed the system engineer, reviewed the plant health report, and reviewed selected corrective actions and condition evaluation documents. The team concluded that the ice condenser glycol chiller concerns were identified and entered into the Corrective Action Program at a low threshold and were resolved in a timely manner commensurate with their safety significance. The team did not identify any additional issues.
 
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. The Initial Screening Committee and the Management Screening Committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. In addition, the team observed a healthy dialogue between the members of these committees and the members challenged each other when dispositioning issues.
 
In general, once a degraded or non-conforming condition was identified, the Corrective Action Program directed that an equipment operability or functionality review be performed. As a result, most of the samples reviewed were evaluated in a timely manner. However, the team noted examples of condition reports that had less than adequate documentation of evaluation activities. The details of this issue are documented in the observation section below.
 
Effectiveness of Corrective Actions:
Based on the samples reviewed, the team determined that the licensee was generally effective in corrective action implementation. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems identified using a root cause or other cause methodologies were resolved in accordance with Corrective Action Program requirements. The team determined that the licensee generally assigned corrective actions that were effective and timely for NRC identified issues and licensee event reports (LERs).
 
Assessment: Use of Operating Experience                                                71152B Based on the samples reviewed, the team determined that licensee's performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to the station. The team observed the Operating Experience Screening Committee meeting and determined that the licensee initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as issue reviews and investigations. The team did not identify any concerns in this area.
 
Assessment: Self-Assessments and Audits                                                71152B Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and nuclear oversight audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. The licensee's Nuclear Oversight (NOS) identified deficiencies with the licensee's processes and those issues were addressed by the station through the Corrective Action Program. The team did not identify any concern in this area.
 
Assessment: Safety Conscious Work Environment                                          71152B The team reviewed the results from the 2019 Employee Concerns Annual Assessment, the 2019 and 2020 departmental safety culture surveys and the 2020 Gallup survey. The team also conducted one-on-one interviews with 23 licensee staff concerning the effectiveness of the Corrective Action Program, the ability to raise issues, and the freedom from potential retaliation for raising issues. The team did not identify any impediment to the establishment of a safety conscious work environment.
 
In general, the licensee's staff was aware of and familiar with the Corrective Action Program and other processes to raise nuclear safety concerns, such as the Employee Concerns Program. Licensee staff indicated they could raise nuclear safety concerns without a fear of retaliation. The team did not identify examples of retaliation for raising nuclear safety concerns. The licensee staff interviewed believed that operational issues and issues with high safety significance were being appropriately addressed in a timely manner.
 
Minor Violation: Failure to Follow the Operability Evaluation Procedure                  71152B Minor Violation: In 2015, an NRC Component Design Bases Inspection identified a finding for the licensees failure to appropriately establish the in-service inspection boundaries for the safety-related component cooling water system. As part of the corrective actions, the licensee performed Engineering Change (EC) 56391 to upgrade steam generator sample coolers 1-QC-501-6 and 2-QC-501-9 from Seismic Class III to Seismic Class I.
 
On March 4, 2019, during the walkdown being performed in support of this EC, the licensee noted that support for cooler 1-QC-501-6 was missing the bottom unistrut bolt and support for cooler 2-QC-501-9 was missing a top mounting bolt. The licensee initiated AR 2019-1940 to document the missing bolts. The shift manager stated in the operability review section of the AR that an operability justification was not required because the support was Seismic Class III (not safety related). The licensee also created Work Order Task 55529607-01 to replace the bolts.
 
In May 2019, the missing top mounting bolt on cooler 2-QC-501-9 was replaced. However, the missing bottom unistrut bolt on cooler 1-QC-501-6 was not accessible and therefore not replaced. The work order was subsequently closed in June 2019.
 
In January 2020, the licensee discovered that the work order was closed and wrote AR 2020-0255 to ask Engineering to accept the condition as-is. However, engineering stated in the AR that evaluating the acceptance of the missing bolt as-is required significant engineering resources. Therefore, work order 55561980 was initiated to replace the missing bolt, which was in planning status at the time of this inspection.
 
During this inspection, the team noted the licensee incorrectly treated the affected piping section as Seismic Category III when evaluating the need to perform an operability determination. Procedure PMP-7030-OPR-001, Operability Determination, Revision 37, required an operability evaluation for Seismic Class I components such as this piping section.
 
The team determined that the failure to follow this procedure was a performance deficiency and a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."
 
Screening: The inspectors determined the performance deficiency was minor. The performance deficiency was minor because it did not adversely affect the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the deficiency did not result in reasonable doubt about the equipments seismic qualifications as the licensee did not have to revise any calculation or evaluation to resolve the associated operability concerns.
 
=====Enforcement:=====
This failure to comply with 10 CFR50 Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
 
Observation: Lack of Technical Rigor in Corrective Action Program Evaluation            71152B The team noted examples of lack of technical rigor in corrective action program evaluations, including:
The licensees audit determined a vendors quality assurance program was ineffective as documented in AR 2019-12088. The licensee removed the vendor from the Approved Suppliers List / Quality Suppliers List and concluded items received from that vendor after January 2017 required additional quality evaluation for acceptance or rejection. The licensee also determined that a sight glass provided by this vendor was installed on the oil reservoir for the Unit 1 east charging pump 1-PP-50E. The licensee performed discrepant condition evaluation (DCE) 2020-0390 to evaluate the impact of the non-qualified sight glass to the charging system and initiated work order 55542705 to replace the sight glass with a quality-related part. The DCE concluded that the sight glass had the same form, fit and function as a quality assurance (QA)qualified installation. Therefore, the licensee concluded that the part would maintain the required integrity with no additional justification. However, the team concluded the DCE did not provide sufficient technical justification because it did not consider relevant attributes such as seismic qualifications, material properties and equipment qualification (EQ) as the licensee would have to perform for the unqualified spare parts. The inspectors determined there was no significant safety impact since the sight glass was replaced within a reasonable amount of time.
 
The licensee generated AR 2020-4967 for degraded essential service water piping due to flow accelerated corrosion. The licensee determined that the minimum allowable wall thickness criteria established in procedures for certain areas were non-conservative due to the presence of welded piping attachments. The licensee created assignments to correct the calculations, revise the affected inspection procedures, and review the extend of condition. However, the team noted the licensee did not establish an interim action until the procedures were revised. The licensee entered this issue into the corrective action program as AR 2021-6742 and planned to revise the affected procedures to add interim guidance. The licensee did not identify examples of unacceptable wall thickness that were deemed acceptable due to the non-conservative acceptance criteria.
 
The licensee failed to perform an operability evaluation because it incorrectly determined the affected component was Seismic Class III (not safety related). This issue was documented as a minor violation in this inspection report.
 
The inspectors concluded that the lack of technical rigor in corrective action program evaluation represented a weakness in addressing deficient conditions. The licensee entered this issue into the corrective action program as AR 2021-7077.
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
 
On August 5, 2021, the inspectors presented the biennial problem identification and resolution inspection results to you and other members of the licensee staff.
 
=DOCUMENTS REVIEWED=
 
Inspection Type              Designation  Description or Title                                    Revision or
Procedure                                                                                          Date
71152B    Corrective Action              Security Survey Results                                  07/2019
Documents                      Material Management Survey Results                      08/2019
Chemistry/Environmental Survey Results                  11/2019
Work Control and Schedule Survey Results                09/2020
2010-11114  Exposed Insulation Found During U2C19 Recirc Sump        10/19/2010
Walkdown
2013-13536  NRC Comment on Methodology of Vortex Calculations        09/13/2013
2013-16557  Cable Tray and Conduit Overfill Issues                  10/28/2013
2014-14190  Failure of 2D5 Synch Circuit                            11/12/2014
2014-15099  Identified a Pin Hole Leak in 2-HV-AFP-EAC ESW Piping    10/02/2014
2015-4459    ISI-Scope Deferral for U2C22                            03/31/2015
2016-12216  U2C23 Baffle-Former Bolt UT Inspection Results          10/23/2016
2016-1537    AR 2016-1537 Plant and Drawing Configuration Discrepancy 02/08/2016
for Condensate System
2016-7752    PRT Seismic Anchor Movement                              06/30/2016
2017-11986  1SI-158-L2/L3 Leakage Above Acceptance Criteria          11/22/2017
2017-4740    Loss of CCS Charging Warrants an AOP                    05/09/2017
2017-7596    Floor Drain Credited in Fire Modeling Are Not Monitored  08/07/2017
2017-9084    AR 2017-9084, 12-OME-129-9 Glycol Chiller #9 Trouble    09/16/2017
Alarm
20174-5989  N-Train Battery Charger Part Evaluation                  06/15/2017
2018-10025  AR 2018-10025 Update Drawing Desktop Guide              10/30/2018
2018-1045    Missed Security Patrol                                  02/01/2018
2018-10451  NRC Inspection QHSA-71124.05 Rad Monitoring              11/15/2018
Instrumentation
2018-11245  12-DR-GCS2 Missing Required Door Sweep                  12/17/2018
2018-6613    Inadequate Evaluation of LOCA Anchor Motions            06/26/2018
2018-7204    Deficiency of Evaluation of Emergency Level Conditions  07/17/2018
2018-9690    1-OME-150-AB Fuel Line Leak Near #6 Rear Fuel Injector  10/16/2018
2019-10855-4 Review Installation of Sight Glass in 1-PP-50E          01/14/2020
2019-11077  Drop in Frequency Noted During LOP/LOCA Testing          11/07/2019
Inspection Type Designation Description or Title                                        Revision or
Procedure                                                                                Date
2019-12088  Vendor Quality Program Ineffective                          12/11/2019
2019-12191  GT 2019-12191, Cook Review of NRC IN-2012-22, Rev 1:        11/20/2019
Counterfeit, Fraudulent, Suspect Item (CRSI) Training
Offerings
2019-12255  Corrosion in Fire Protection Piping                          12/17/2019
2019-1349  Bent Hanger in U2-East RHR Pump Room 2-GRH-V819              02/11/2019
2019-1398  Determine Impact (CDI) for Completion of SD-180820-001      02/12/2019
2019-4190  Air Void Per UT is Unacceptable Location Prior to 1-IMO-261  04/21/2019
2019-5275  Transcript Error of SRD Calibration                          05/16/2019
2019-6691  Negative Trend of INPO Radiation Protection Events          07/08/2019
Indicator
2019-6882  AR 2019-6882, Unit 2 Ice Bed Temps above ESOMS              07/15/2019
Notification Limits
2019-6998  AR 2019-6998 Unexpected Alarm in Unit 2 Control Room        07/18/2019
2019-7047  Received a 204 Drop 13 South NESW PP Strainer DP High        07/21/2019
2019-7276  AR 2019-7276 Intermittent Alarm 2-SG-7 PT 162                07/27/2019
2019-8320  AR 2019-8320 Unit 2 ITS 5.5.12.d Specific Requirements      08/29/2019
May Not Being Met
20-0255  WOT 55529607 Was Not Completed as Prescribed                01/09/2020
20-0390  1-PP-50E, Replace Sight Glass Installed Under WO            01/13/2020
55455925
20-0529  Update Specs to Support Section XI Requirements              01/16/2020
20-10105  MTS UPS Condition Identified During PM                      12/10/2020
20-10439  GT 2020-10439 Cook Review of IN 2020-004 - Operating        12/23/2020
Experience Related to Failure of Buried Fire Protection Main
Yard Piping
20-10440  GT 2020-10440 Cook Review of IN 2018-11, SUPPLEMENT          12/23/2020
1: QA Record Falsification at Kobe Steel and Other
International Vendors 12/23/2020
20-1047  ACE AR 2020-1047, Gland Seal Effluent RMS High Range        12/16/2020
Reading
20-1877  CCE AR 2020-1877 ERO Qualification Process and Tracking      01/13/2021
in PQM
20-2027  Failed Operations Surveillance                              02/28/2020
Inspection Type Designation Description or Title                                          Revision or
Procedure                                                                                Date
20-2642  ACE AR 2020-2642 Radiation Monitor Communication to          06/25/2020
Control Room Lost
20-3709  RCE CR 2020-3709 RCS Leak - Plug Unit 1 NRV-163/NRV-          08/04/2020
164 Bellows Tell-Tale at the Bonnet
20-3739  ACE AR 2020-3739, 2-NRI-32 is Slowly Failing Low              09/19/2020
20-4285  Actions are Not Always Changing Workflow State as            05/20/2020
Required
20-4891  AR 2020-4891, 1-VTR-185 High Temp Alarm                      06/15/2020
20-4946  Wrong Radiation Work Permit used to Enter the U2 Vestibule    06/17/2020
20-4967  Degraded ESW Pipe Downstream of 1-WMO-715                    06/17/2020
20-6117  NOS Identified Deficient Execution of Fire Door Surveillance  08/03/2020
20-7242  GT 2020-7242, Cook Review of IN 2020-02 - FLEX Diesel        11/23/2020
Generator Operational Challenges
20-8177  Performance Issues/Common Cause                              10/05/2020
21-0169  Cook Review of IN 2007-21, Supplement 1: Pipe Wear Due        01/06/2021
to Interaction of Flow-Induced Vibration and Reflective Metal
Insulation
21-2008  CCE AR 2021-2008, Glycol Chiller Failure Possible Trend      04/28/2021
21-2838  CCE AR 2021-2838 Vulnerabilities introduced During Design    04/05/2021
Modifications
21-2858  AR 2021-2858 U2 Ice Condenser FME Walkdown                    04/06/2021
21-3139  AR 2021-3139 Disparity in Unit 2 Source Range Readings        04/17/2021
21-4239  AR 2021-4239, 2-NRV-152 Failed as Found Stroke Time on        05/11/2021
Backup Air
21-4250  GT 2021-4250 Cook Opex Review of NRC IN 21-01,                05/11/2021
Lessons Learned from NRC Inspections of Design-Basis
Capability of Power-Operated Valves at Nuclear Power
Plants
21-4721  Steam/Water Leak on 2FW-115-4                                05/21/2021
21-4722  28 DPM Condensate Leak                                        05/22/2021
21-4743  2-SV-1A-4 Steam Leak                                          05/23/2021
21-4750  Leak by on 1-CW-344E                                          05/23/2021
21-4812  Minor RCS Back Leakage Suspected Through 1-SI-152S            05/25/2021
21-4817  WR Only to Install Missing Clips on CCW Cooling Coils        05/25/2021
Inspection Type              Designation    Description or Title                                        Revision or
Procedure                                                                                                Date
21-4882      1-OME-34W Packing Leaks on Inlet and Outlet Valves          05/26/2021
21-5016      U2 CD EDG Coalescing Filter Air Leak                        06/01/2021
GT 2020-10549  White Finding for Check Valve Not Meeting IST                12/30/2020
Requirements
GT 2021-1076    Perform OE Evaluation for James A Fitzpatrick Finding        02/01/2021
GT 2021-2166    Westinghouse Technical Bulletin TB-19-5 Rev. 1              03/09/2021
Corrective Action 2021-6378      Drawing Updated Prematurely and EDB Impacts Missed          07/22/2021
Documents        2021-6638      Operability Review of CR 2019-1940 & Seismic Class          07/29/2021
Resulting from    2021-6742      Interim Guidance Not Developed for UT Exam                  08/03/2021
Inspection        2021-6785      Attachments Not Attached to AR 2019-1349-2                  08/04/2021
21-6809      DIT / Calc Guidance for FAC Tmins Do Not Include WPA        08/04/2021
Stresses
21-7077      Observation of Technical Rigor in ENG Products              08/16/2021
21-7078      NRC Observation on CR Generation Rates                      08/16/2021
Engineering      03554          DIT-B-03554-00-Provided Program Engineering with            11/22/2013
Evaluations                      Minimum Allowable Pipe Wall Thicknesses
Miscellaneous                    Operations Survey Results                                    06/2019
5700-11        Interim Acceptance Criteria for Safety Related Piping System 2
NDE Reports      1-OHP-4030-102- RCS Pressure Isolation Valves Leak Rate Surveillance Test    10/20/2020
017
Procedures        12-EHP-5043-    Evaluation of Degraded/Nonconforming Conditions              029
EDC-001
2-MHP-5021-    Emergency Diesel Engine Fuel Injector Maintenance            15
2-018
ECP-01          Employee Concerns Program Administration Manual              10
PMI-7030        Corrective Action Program                                    46
PMP-7030-CAP-  Action Initiation                                            41
001
PMP-7030-CAP-  Condition Action and Closure                                38
2
PMP-7030-MOP-  Corrective Action Program Management Oversight Process      32
001
PMP-7030-OPR-  Operability Determination                                    037
Inspection Type            Designation  Description or Title                                    Revision or
Procedure                                                                                          Date
001
Self-Assessments 2019-1575-1  GT 2019-1575-1; CRE Program Full SA; ESYN; System        09/25/2019
Engineering NSSS
2019-8560    AR 2019-8560 DIT Inappropriately Updated BOM for SI      09/09/2019
Pumps Caused Configuration Change
2019-8779    ARM-19-09-01 Mods Not Adequately Prepared with Excess    10/17/2019
Emergent Problems After Implementation
21-6317    AR 2021-6317; 1-WRV-723: AB Emergency Diesel North      07/20/2021
Combustion Air Aftercooler HE-47-ABN ESW Inlet/Bypass
Valve
GT 2019-11203 Improvement Actions                                      11/10/2019
GT 2020-8602  Biennial PI&R Inspection                                02/25/2021
NOS 19-04    Material Control, and Measuring and Test Equipment      07/25/2019
NOS-19-03    Maintenance, Work Control, and Special Processes        06/25/2019
NOS-19-05    Nuclear Oversight Audit - Corrective Action Program      07/29/2019
NOS-19-08    NOS Audit - Engineering, Design Control, & In-Service    10/17/2019
Inspection (ISI)/In-Service Testing (IST)
NOS-20-03    NOS Audit NOS-20-03, Emergency Preparedness            04/04/2020
NOS-21-01    REMP/ODCM                                                04/08/2021
SA-2019-ECP-  2019 Employee Concerns Annual Assessment                01/17/2020
001
Work Orders      55547169      Plug Unit 1 NRV-163 and NRV-164 Bellows Tell-Tale at the 11/05/2020
Bonnet
13
}}
}}

Latest revision as of 17:01, 18 January 2022

Biennial Problem Identification and Resolution Inspection Report 05000315/2021010 and 05000316/2021010
ML21245A413
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 09/07/2021
From: Nestor Feliz-Adorno
Reactor Projects Region 3 Branch 4
To: Gebbie J
Indiana Michigan Power Co
References
IR 2021010
Download: ML21245A413 (16)


Text

September 7, 2021

SUBJECT:

DONALD C. COOK NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000315/2021010 AND 05000316/2021010

Dear Mr. Gebbie:

On August 5, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Donald C. Cook Nuclear Plant. On August 5, 2021 the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

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, Signed by Feliz-Adorno, Nestor on 09/07/21 Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Docket Nos. 05000315 and 05000316 License Nos. DPR-58 and DPR-74

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000315 and 05000316 License Numbers: DPR-58 and DPR-74 Report Numbers: 05000315/2021010 and 05000316/2021010 Enterprise Identifier: I-2021-010-0045 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Plant Location: Bridgman, MI Inspection Dates: July 19, 2021 to August 05, 2021 Inspectors: E. Fernandez, Reactor Inspector J. Mancuso, Resident Inspector R. Ng, Project Engineer G. O'Dwyer, Reactor Engineer Approved By: Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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

No findings or violations of more than minor significance were identified.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the ice condenser glycol chiller system.

Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment: Assessment of the Corrective Action Program 71152B Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program was generally effective and supported nuclear safety.

Effectiveness of Problem Identification:

Based on the samples reviewed, the team concluded that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team determined that the licensee usually entered problems into the Corrective Action Program completely and accurately. The inspectors determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety.

The team also noted that some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program. In addition, the licensee also utilized Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. For example, the licensee performed department self-assessments and quality assurance audits to identify issues in station processes. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.

The team determined that the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.

The team performed a 5-year review of the ice condenser glycol chiller issues. As part of this review, the team interviewed the system engineer, reviewed the plant health report, and reviewed selected corrective actions and condition evaluation documents. The team concluded that the ice condenser glycol chiller concerns were identified and entered into the Corrective Action Program at a low threshold and were resolved in a timely manner commensurate with their safety significance. The team did not identify any additional issues.

Effectiveness of Prioritization and Evaluation of Issues:

Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. The Initial Screening Committee and the Management Screening Committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. In addition, the team observed a healthy dialogue between the members of these committees and the members challenged each other when dispositioning issues.

In general, once a degraded or non-conforming condition was identified, the Corrective Action Program directed that an equipment operability or functionality review be performed. As a result, most of the samples reviewed were evaluated in a timely manner. However, the team noted examples of condition reports that had less than adequate documentation of evaluation activities. The details of this issue are documented in the observation section below.

Effectiveness of Corrective Actions:

Based on the samples reviewed, the team determined that the licensee was generally effective in corrective action implementation. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems identified using a root cause or other cause methodologies were resolved in accordance with Corrective Action Program requirements. The team determined that the licensee generally assigned corrective actions that were effective and timely for NRC identified issues and licensee event reports (LERs).

Assessment: Use of Operating Experience 71152B Based on the samples reviewed, the team determined that licensee's performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to the station. The team observed the Operating Experience Screening Committee meeting and determined that the licensee initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as issue reviews and investigations. The team did not identify any concerns in this area.

Assessment: Self-Assessments and Audits 71152B Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and nuclear oversight audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. The licensee's Nuclear Oversight (NOS) identified deficiencies with the licensee's processes and those issues were addressed by the station through the Corrective Action Program. The team did not identify any concern in this area.

Assessment: Safety Conscious Work Environment 71152B The team reviewed the results from the 2019 Employee Concerns Annual Assessment, the 2019 and 2020 departmental safety culture surveys and the 2020 Gallup survey. The team also conducted one-on-one interviews with 23 licensee staff concerning the effectiveness of the Corrective Action Program, the ability to raise issues, and the freedom from potential retaliation for raising issues. The team did not identify any impediment to the establishment of a safety conscious work environment.

In general, the licensee's staff was aware of and familiar with the Corrective Action Program and other processes to raise nuclear safety concerns, such as the Employee Concerns Program. Licensee staff indicated they could raise nuclear safety concerns without a fear of retaliation. The team did not identify examples of retaliation for raising nuclear safety concerns. The licensee staff interviewed believed that operational issues and issues with high safety significance were being appropriately addressed in a timely manner.

Minor Violation: Failure to Follow the Operability Evaluation Procedure 71152B Minor Violation: In 2015, an NRC Component Design Bases Inspection identified a finding for the licensees failure to appropriately establish the in-service inspection boundaries for the safety-related component cooling water system. As part of the corrective actions, the licensee performed Engineering Change (EC) 56391 to upgrade steam generator sample coolers 1-QC-501-6 and 2-QC-501-9 from Seismic Class III to Seismic Class I.

On March 4, 2019, during the walkdown being performed in support of this EC, the licensee noted that support for cooler 1-QC-501-6 was missing the bottom unistrut bolt and support for cooler 2-QC-501-9 was missing a top mounting bolt. The licensee initiated AR 2019-1940 to document the missing bolts. The shift manager stated in the operability review section of the AR that an operability justification was not required because the support was Seismic Class III (not safety related). The licensee also created Work Order Task 55529607-01 to replace the bolts.

In May 2019, the missing top mounting bolt on cooler 2-QC-501-9 was replaced. However, the missing bottom unistrut bolt on cooler 1-QC-501-6 was not accessible and therefore not replaced. The work order was subsequently closed in June 2019.

In January 2020, the licensee discovered that the work order was closed and wrote AR 2020-0255 to ask Engineering to accept the condition as-is. However, engineering stated in the AR that evaluating the acceptance of the missing bolt as-is required significant engineering resources. Therefore, work order 55561980 was initiated to replace the missing bolt, which was in planning status at the time of this inspection.

During this inspection, the team noted the licensee incorrectly treated the affected piping section as Seismic Category III when evaluating the need to perform an operability determination. Procedure PMP-7030-OPR-001, Operability Determination, Revision 37, required an operability evaluation for Seismic Class I components such as this piping section.

The team determined that the failure to follow this procedure was a performance deficiency and a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."

Screening: The inspectors determined the performance deficiency was minor. The performance deficiency was minor because it did not adversely affect the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the deficiency did not result in reasonable doubt about the equipments seismic qualifications as the licensee did not have to revise any calculation or evaluation to resolve the associated operability concerns.

Enforcement:

This failure to comply with 10 CFR50 Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Lack of Technical Rigor in Corrective Action Program Evaluation 71152B The team noted examples of lack of technical rigor in corrective action program evaluations, including:

The licensees audit determined a vendors quality assurance program was ineffective as documented in AR 2019-12088. The licensee removed the vendor from the Approved Suppliers List / Quality Suppliers List and concluded items received from that vendor after January 2017 required additional quality evaluation for acceptance or rejection. The licensee also determined that a sight glass provided by this vendor was installed on the oil reservoir for the Unit 1 east charging pump 1-PP-50E. The licensee performed discrepant condition evaluation (DCE) 2020-0390 to evaluate the impact of the non-qualified sight glass to the charging system and initiated work order 55542705 to replace the sight glass with a quality-related part. The DCE concluded that the sight glass had the same form, fit and function as a quality assurance (QA)qualified installation. Therefore, the licensee concluded that the part would maintain the required integrity with no additional justification. However, the team concluded the DCE did not provide sufficient technical justification because it did not consider relevant attributes such as seismic qualifications, material properties and equipment qualification (EQ) as the licensee would have to perform for the unqualified spare parts. The inspectors determined there was no significant safety impact since the sight glass was replaced within a reasonable amount of time.

The licensee generated AR 2020-4967 for degraded essential service water piping due to flow accelerated corrosion. The licensee determined that the minimum allowable wall thickness criteria established in procedures for certain areas were non-conservative due to the presence of welded piping attachments. The licensee created assignments to correct the calculations, revise the affected inspection procedures, and review the extend of condition. However, the team noted the licensee did not establish an interim action until the procedures were revised. The licensee entered this issue into the corrective action program as AR 2021-6742 and planned to revise the affected procedures to add interim guidance. The licensee did not identify examples of unacceptable wall thickness that were deemed acceptable due to the non-conservative acceptance criteria.

The licensee failed to perform an operability evaluation because it incorrectly determined the affected component was Seismic Class III (not safety related). This issue was documented as a minor violation in this inspection report.

The inspectors concluded that the lack of technical rigor in corrective action program evaluation represented a weakness in addressing deficient conditions. The licensee entered this issue into the corrective action program as AR 2021-7077.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On August 5, 2021, the inspectors presented the biennial problem identification and resolution inspection results to you and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action Security Survey Results 07/2019

Documents Material Management Survey Results 08/2019

Chemistry/Environmental Survey Results 11/2019

Work Control and Schedule Survey Results 09/2020

2010-11114 Exposed Insulation Found During U2C19 Recirc Sump 10/19/2010

Walkdown

2013-13536 NRC Comment on Methodology of Vortex Calculations 09/13/2013

2013-16557 Cable Tray and Conduit Overfill Issues 10/28/2013

2014-14190 Failure of 2D5 Synch Circuit 11/12/2014

2014-15099 Identified a Pin Hole Leak in 2-HV-AFP-EAC ESW Piping 10/02/2014

2015-4459 ISI-Scope Deferral for U2C22 03/31/2015

2016-12216 U2C23 Baffle-Former Bolt UT Inspection Results 10/23/2016

2016-1537 AR 2016-1537 Plant and Drawing Configuration Discrepancy 02/08/2016

for Condensate System

2016-7752 PRT Seismic Anchor Movement 06/30/2016

2017-11986 1SI-158-L2/L3 Leakage Above Acceptance Criteria 11/22/2017

2017-4740 Loss of CCS Charging Warrants an AOP 05/09/2017

2017-7596 Floor Drain Credited in Fire Modeling Are Not Monitored 08/07/2017

2017-9084 AR 2017-9084, 12-OME-129-9 Glycol Chiller #9 Trouble 09/16/2017

Alarm

20174-5989 N-Train Battery Charger Part Evaluation 06/15/2017

2018-10025 AR 2018-10025 Update Drawing Desktop Guide 10/30/2018

2018-1045 Missed Security Patrol 02/01/2018

2018-10451 NRC Inspection QHSA-71124.05 Rad Monitoring 11/15/2018

Instrumentation

2018-11245 12-DR-GCS2 Missing Required Door Sweep 12/17/2018

2018-6613 Inadequate Evaluation of LOCA Anchor Motions 06/26/2018

2018-7204 Deficiency of Evaluation of Emergency Level Conditions 07/17/2018

2018-9690 1-OME-150-AB Fuel Line Leak Near #6 Rear Fuel Injector 10/16/2018

2019-10855-4 Review Installation of Sight Glass in 1-PP-50E 01/14/2020

2019-11077 Drop in Frequency Noted During LOP/LOCA Testing 11/07/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

2019-12088 Vendor Quality Program Ineffective 12/11/2019

2019-12191 GT 2019-12191, Cook Review of NRC IN-2012-22, Rev 1: 11/20/2019

Counterfeit, Fraudulent, Suspect Item (CRSI) Training

Offerings

2019-12255 Corrosion in Fire Protection Piping 12/17/2019

2019-1349 Bent Hanger in U2-East RHR Pump Room 2-GRH-V819 02/11/2019

2019-1398 Determine Impact (CDI) for Completion of SD-180820-001 02/12/2019

2019-4190 Air Void Per UT is Unacceptable Location Prior to 1-IMO-261 04/21/2019

2019-5275 Transcript Error of SRD Calibration 05/16/2019

2019-6691 Negative Trend of INPO Radiation Protection Events 07/08/2019

Indicator

2019-6882 AR 2019-6882, Unit 2 Ice Bed Temps above ESOMS 07/15/2019

Notification Limits

2019-6998 AR 2019-6998 Unexpected Alarm in Unit 2 Control Room 07/18/2019

2019-7047 Received a 204 Drop 13 South NESW PP Strainer DP High 07/21/2019

2019-7276 AR 2019-7276 Intermittent Alarm 2-SG-7 PT 162 07/27/2019

2019-8320 AR 2019-8320 Unit 2 ITS 5.5.12.d Specific Requirements 08/29/2019

May Not Being Met

20-0255 WOT 55529607 Was Not Completed as Prescribed 01/09/2020

20-0390 1-PP-50E, Replace Sight Glass Installed Under WO 01/13/2020

55455925

20-0529 Update Specs to Support Section XI Requirements 01/16/2020

20-10105 MTS UPS Condition Identified During PM 12/10/2020

20-10439 GT 2020-10439 Cook Review of IN 2020-004 - Operating 12/23/2020

Experience Related to Failure of Buried Fire Protection Main

Yard Piping

20-10440 GT 2020-10440 Cook Review of IN 2018-11, SUPPLEMENT 12/23/2020

1: QA Record Falsification at Kobe Steel and Other

International Vendors 12/23/2020

20-1047 ACE AR 2020-1047, Gland Seal Effluent RMS High Range 12/16/2020

Reading

20-1877 CCE AR 2020-1877 ERO Qualification Process and Tracking 01/13/2021

in PQM

20-2027 Failed Operations Surveillance 02/28/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

20-2642 ACE AR 2020-2642 Radiation Monitor Communication to 06/25/2020

Control Room Lost

20-3709 RCE CR 2020-3709 RCS Leak - Plug Unit 1 NRV-163/NRV- 08/04/2020

164 Bellows Tell-Tale at the Bonnet

20-3739 ACE AR 2020-3739, 2-NRI-32 is Slowly Failing Low 09/19/2020

20-4285 Actions are Not Always Changing Workflow State as 05/20/2020

Required

20-4891 AR 2020-4891, 1-VTR-185 High Temp Alarm 06/15/2020

20-4946 Wrong Radiation Work Permit used to Enter the U2 Vestibule 06/17/2020

20-4967 Degraded ESW Pipe Downstream of 1-WMO-715 06/17/2020

20-6117 NOS Identified Deficient Execution of Fire Door Surveillance 08/03/2020

20-7242 GT 2020-7242, Cook Review of IN 2020-02 - FLEX Diesel 11/23/2020

Generator Operational Challenges

20-8177 Performance Issues/Common Cause 10/05/2020

21-0169 Cook Review of IN 2007-21, Supplement 1: Pipe Wear Due 01/06/2021

to Interaction of Flow-Induced Vibration and Reflective Metal

Insulation

21-2008 CCE AR 2021-2008, Glycol Chiller Failure Possible Trend 04/28/2021

21-2838 CCE AR 2021-2838 Vulnerabilities introduced During Design 04/05/2021

Modifications

21-2858 AR 2021-2858 U2 Ice Condenser FME Walkdown 04/06/2021

21-3139 AR 2021-3139 Disparity in Unit 2 Source Range Readings 04/17/2021

21-4239 AR 2021-4239, 2-NRV-152 Failed as Found Stroke Time on 05/11/2021

Backup Air

21-4250 GT 2021-4250 Cook Opex Review of NRC IN 21-01, 05/11/2021

Lessons Learned from NRC Inspections of Design-Basis

Capability of Power-Operated Valves at Nuclear Power

Plants

21-4721 Steam/Water Leak on 2FW-115-4 05/21/2021

21-4722 28 DPM Condensate Leak 05/22/2021

21-4743 2-SV-1A-4 Steam Leak 05/23/2021

21-4750 Leak by on 1-CW-344E 05/23/2021

21-4812 Minor RCS Back Leakage Suspected Through 1-SI-152S 05/25/2021

21-4817 WR Only to Install Missing Clips on CCW Cooling Coils 05/25/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

21-4882 1-OME-34W Packing Leaks on Inlet and Outlet Valves 05/26/2021

21-5016 U2 CD EDG Coalescing Filter Air Leak 06/01/2021

GT 2020-10549 White Finding for Check Valve Not Meeting IST 12/30/2020

Requirements

GT 2021-1076 Perform OE Evaluation for James A Fitzpatrick Finding 02/01/2021

GT 2021-2166 Westinghouse Technical Bulletin TB-19-5 Rev. 1 03/09/2021

Corrective Action 2021-6378 Drawing Updated Prematurely and EDB Impacts Missed 07/22/2021

Documents 2021-6638 Operability Review of CR 2019-1940 & Seismic Class 07/29/2021

Resulting from 2021-6742 Interim Guidance Not Developed for UT Exam 08/03/2021

Inspection 2021-6785 Attachments Not Attached to AR 2019-1349-2 08/04/2021

21-6809 DIT / Calc Guidance for FAC Tmins Do Not Include WPA 08/04/2021

Stresses

21-7077 Observation of Technical Rigor in ENG Products 08/16/2021

21-7078 NRC Observation on CR Generation Rates 08/16/2021

Engineering 03554 DIT-B-03554-00-Provided Program Engineering with 11/22/2013

Evaluations Minimum Allowable Pipe Wall Thicknesses

Miscellaneous Operations Survey Results 06/2019

5700-11 Interim Acceptance Criteria for Safety Related Piping System 2

NDE Reports 1-OHP-4030-102- RCS Pressure Isolation Valves Leak Rate Surveillance Test 10/20/2020

017

Procedures 12-EHP-5043- Evaluation of Degraded/Nonconforming Conditions 029

EDC-001

2-MHP-5021- Emergency Diesel Engine Fuel Injector Maintenance 15

2-018

ECP-01 Employee Concerns Program Administration Manual 10

PMI-7030 Corrective Action Program 46

PMP-7030-CAP- Action Initiation 41

001

PMP-7030-CAP- Condition Action and Closure 38

2

PMP-7030-MOP- Corrective Action Program Management Oversight Process 32

001

PMP-7030-OPR- Operability Determination 037

Inspection Type Designation Description or Title Revision or

Procedure Date

001

Self-Assessments 2019-1575-1 GT 2019-1575-1; CRE Program Full SA; ESYN; System 09/25/2019

Engineering NSSS

2019-8560 AR 2019-8560 DIT Inappropriately Updated BOM for SI 09/09/2019

Pumps Caused Configuration Change

2019-8779 ARM-19-09-01 Mods Not Adequately Prepared with Excess 10/17/2019

Emergent Problems After Implementation

21-6317 AR 2021-6317; 1-WRV-723: AB Emergency Diesel North 07/20/2021

Combustion Air Aftercooler HE-47-ABN ESW Inlet/Bypass

Valve

GT 2019-11203 Improvement Actions 11/10/2019

GT 2020-8602 Biennial PI&R Inspection 02/25/2021

NOS 19-04 Material Control, and Measuring and Test Equipment 07/25/2019

NOS-19-03 Maintenance, Work Control, and Special Processes 06/25/2019

NOS-19-05 Nuclear Oversight Audit - Corrective Action Program 07/29/2019

NOS-19-08 NOS Audit - Engineering, Design Control, & In-Service 10/17/2019

Inspection (ISI)/In-Service Testing (IST)

NOS-20-03 NOS Audit NOS-20-03, Emergency Preparedness 04/04/2020

NOS-21-01 REMP/ODCM 04/08/2021

SA-2019-ECP- 2019 Employee Concerns Annual Assessment 01/17/2020

001

Work Orders 55547169 Plug Unit 1 NRV-163 and NRV-164 Bellows Tell-Tale at the 11/05/2020

Bonnet

13