ML19312A445

Integrated Inspection Report 05000315/2019003 and 05000316/2019003

ML19312A445
Person / Time
Site:	Cook
Issue date:	11/07/2019
From:	Eric Duncan Reactor Projects Region 3 Branch 4
To:	Gebbie J Indiana Michigan Power Co
References
IR 2019003
Download: ML19312A445 (23)

See also: IR 05000315/2019003

Text

November 7, 2019

Mr. Joel P. Gebbie

Senior VP and Chief Nuclear Officer

Indiana Michigan Power Company

Nuclear Generation Group

One Cook Place

Bridgman, MI 49106

SUBJECT: DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - INTEGRATED

INSPECTION REPORT 05000315/2019003 AND 05000316/2019003

Dear Mr. Gebbie:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at Donald C. Cook Nuclear Plant, Units 1 and 2. On October 15, 2019, the NRC

inspectors discussed the results of this inspection with you and other members of your staff.

The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding

involved a violation of NRC requirements. We are treating this violation as a non-cited violation

(NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this

inspection report, you should provide a response within 30 days of the date of this inspection

report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional

Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector

at D.C. Cook.

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 D.C. Cook.

J. Gebbie -2-

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Eric R. Duncan, Chief

Branch 4

Division of Reactor Projects

Docket Nos. 05000315 and 05000316

License Nos. DPR-58 and DPR-74

Enclosure:

As stated

cc: Distribution via LISTSERV

ML19312A445

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive Non-Publicly Available

OFFICE RIII

NAME EDuncan:bw

DATE 11/7/2019

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000315 and 05000316

License Numbers: DPR-58 and DPR-74

Report Numbers: 05000315/2019003 and 05000316/2019003

Licensee: Indiana Michigan Power Company

Facility: Donald C. Cook Nuclear Plant, Units 1 and 2

Location: Bridgman, MI

Inspection Dates: July 01, 2019 to September 30, 2019

Inspectors: J. Ellegood, Senior Resident Inspector

N. Feliz-Adorno, Senior Reactor Inspector

T. Go, Health Physicist

P. Laflamme, Senior Resident Inspector

J. Mancuso, Resident Inspector

R. Ng, Project Engineer

J. Rutkowski, Project Engineer

M. Ziolkowski, Senior Physical Security Inspector

Approved By: Eric R. Duncan, Chief

Branch 4

Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Donald C. Cook Nuclear Plant, Units 1

and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the

NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer

to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Main Steam Stop Valve Dump Valve Inoperable for Longer than its Technical Specification

Allowed Outage Time

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [H.14] - 71152

Systems NCV 05000315/2019003-01 Conservative

Open/Closed Bias

The inspectors identified a finding of very low safety significance (i.e., Green) and an

associated Non-Cited Violation (NCV) of Technical Specification (TS) 3.7.2, Steam Generator

Stop Valves (SGVSs), when licensee personnel failed to have four Unit 1 SGSVs and

associated actuator trains operable while in Mode 1 and subsequently failed to restore the

affected SGSV actuator train and SGSV to an operable status or place Unit 1 in Mode 2 within

the time limits specified by the associated TS Limiting Condition for Operation (LCO). In

addition, a NCV of TS 3.0.4, LCO Applicability, was identified because the licensee entered

a Mode of applicability without the SGSV actuator train and associated SGSV being operable

as required. Specifically, the licensee failed to identify that Unit 1 #2 SGVS Train B Dump

Valve MRV-222 was inoperable during a post-maintenance test (PMT) conducted on

May 6, 2019; and subsequently entered Mode 1 contrary to TS 3.0.4 and operated for

21 days, contrary to TS 3.7.2.

Additional Tracking Items

Type Issue Number Title Report Section Status

URI 05000315,05000316/20 Site Specific Shielding and 60855.1 Closed

18003-02 Barriers for HI-TRAC

Transfer Cask Require NRC

Approval Prior to Use

2

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On September 29, 2019, the

licensee reduced power to about 55 percent to repair a leak on a feedwater pump casing.

Unit 1 remained at or near 55 percent power for the remainder of the inspection period.

Unit 2 operated at or near rated thermal power until July 21, 2019, when the licensee shut

down the unit in response to a degradation of Non-Essential Service Water (NESW) flow.

On July 25, 2019, the licensee restarted Unit 2. Unit 2 reached rated thermal power on

July 26, 2019, and remained at or near rated thermal power until September 9, 2019, when

Unit 2 began coast down operations prior to a scheduled refueling outage. On

September 29, 2019, the licensee reduced power to about 50 percent to perform Main Steam

Safety Valve testing. Following this testing, Unit 2 remained at or near 50 percent power for the

remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/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 performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensee's readiness to cope with external flooding for

the following area:

• Screen House

71111.04Q - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 1 Emergency Diesel Generator (EDG) AB and Associated Support Systems on

July 8, 2019

(2) Unit 2 Residual Heat Removal (RHR) on July 23, 2019

(3) Unit 2 Turbine Driven Auxiliary Feedwater (TDAFW) Pump on August 8, 2019

3

(4) Unit 1 West Motor Driven Auxiliary Feedwater (MDAFW) Pump on August 14, 2019

(5) Unit 2 CD EDG on August 21, 2019

71111.04S - Equipment Alignment

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the

Unit 1 Qualified Offsite Power Lines on September 23, 2019

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (4 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) U2 CD EDG on July 7, 2019

(2) U2 AB EDG on July 7, 2019

(3) Auxiliary Building 573' Elevation on July 11, 2019

(4) U2 4 Kilovolt (kV) Switchgear Rooms AB and CD on July 11, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protection in the:

(1) Auxiliary Building, Elevations 573' and 587'

71111.07A - Heat Sink Performance

Annual Review (IP Section 02.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 2 Non-Essential Service Water (NESW)

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control

Room during a plant shutdown for a maintenance outage on July 21, 2019

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training in

the Unit 2 Simulator on September 12, 2019

4

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (3 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with

the following equipment and/or safety significant functions:

(1) Unit 1 Auxiliary Feedwater (AFW)

(2) Unit 1 Main Feedwater

(3) Supplemental Emergency Diesel Generators (EDGs)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work

activities:

(1) Elevated Risk due to unplanned Unit 1 AB EDG inoperability on June 17, 2019

(2) Elevated Risk associated with the loss of Unit 2 NESW from July 21 through

July 24, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) AR 2015-5237, Asymmetric Natural Circulation Cooldown with Low Decay Heat

(2) AR 2019-6882, Ice Condenser After Exceeding Notification Limit

(3) AR 2019-7053, PZR [Pressurizer] Insurge/Outsurge

(4) AR 2019-7919, Low Differential Pressure Across Fuel Handling Area Ventilation

System Charcoal Bed

(5) Step Change in Differential Pressure (D/P) Across Auxiliary Fuel Handling Area

Exhaust Filter

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Mechanism-Operated Contact Switch Adjustment for Unit 1 AB EDG to 4kV Bus

Supply Breaker; Work Order (WO) 55535235

(2) Unit 2 NESW Strainers following Cleaning, July 21 through 23, 2019

(3) Unit 2 East RHR Pump following Valve Work; WO 55359920

(4) Unit 1 CD EDG, on August 29, 2019, following planned maintenance

(5) Unit 1 TDAFW System on September 3, 2019, following planned maintenance

(6) Unit 1 East Component Cooling Water (CCW) Check Valve Flow Test following RCP

1. 3 Lower Bearing CCW Throttle Valve Adjustment on September 13, 2019

5

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated a Unit 2 maintenance outage from July 21 through

July 25, 2019, which resulted from accumulated debris in the NESW strainers

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance test:

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) Unit 2 New Fuel Receipt Inspections; WO 55518169 and WO 55518412

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) Emergency Preparedness Drill on July 16, 2019

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Licensed Operator Requalification Training (LORT) with Drill Exercise Performance

(DEP) on September 10, 2019

RADIATION SAFETY

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Radioactive Material Storage (IP Section 02.01) (1 Sample)

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the following areas:

• Radioactive Waste Drumming Room located in the Auxiliary Building 587'

• Radioactive Waste Condensate Tanks South/North 587'

• South Boric-Acid Evaporator Room 587

• Radioactive Material Building and Contaminated Equipment Storage Area

(CESA) Building where Dry Active Waste (DAW) Containers were Stored

• Mausoleum Storage Area and CESA Contains Contaminated Equipment

Stored in Sea-Lands

The inspectors performed a container check (e.g., swelling, leakage and deformation)

on the following containers:

• DAW Container No. 321; Air Compressors; dated February 19, 2013

6

• DAW Container No. 314; Stinger Whip Welding Equipment; dated

July 27, 2017

• DAW Container No. 230; Spent Fuel Pool Tools and Spares; dated

February 1, 2012

• DAW Container No. 323; Camera Cables; dated February 1, 2013

• DAW Container No. 102; Thimble Plugs Tools for Seal-Table; dated

May 6, 2019

• DAW Container No. 324; Power Packs and Electrical Transformers; dated

March 14, 2016

• DAW Container No. 226; Specimen Tools/Bolts for CRD Tools; dated

April 28, 2019

• DAW Container No. 237; CRDM [Control Rod Drive Mechanism] Equipment

Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems during plant

walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems

• Radioactove Waste Drumming Room located in the Auxiliary Building 587

Resin Transfer/Sluicing System into a Liner/Cask

• Energy Solution Liquid System; Radioactive Waste Water Demineralizer

System

• Spent Resin Storage Tank Resin Transfer System

• DAW Trash Loading Located in the Auxiliary Building

Radioactive Waste Resin and/or Sludge Discharges Processes

• Energy Solutions Liquid System; Radioactive Waste Water Demineralizer

System

• Spent Resin Storage Tank Resin Transfer System

Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the

following waste streams:

(1) Shipping Cask Containing Spent Resin to Bear Creek, TN; Low Specific Activity

(LSA-II)

Contaminated Equipment RAM [Radioactive Material] Shipment to Energy Solution

Services as Surface Contaminated Objects (SCO-II)

Sample Shipment of 8 Samples to be Analyzed to GEL Laboratory as a Limited

Quantity Material

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated the following radioactive material shipment preparation processes:

(1) DCC18-053; UN3321, RAM LSA-II; Fissile Excepted; 7, RQ-1; Spent Resin Mixed

Bed Ion Exchange Media to Bear Creek, TN; dated July 12, 2018

DCC18-074; UN3321, RAM LSA-II; Fissile Excepted; 7, RQ-1; Spent Resin Mixed

7

Bed Ion Exchange Media to Bear Creek, TN; dated December 5, 2018

DCC19-053; UN2913, RAM SCO-II; Fissile Excepted; 7, RQ-1; Contaminated

Equipment Contained in a Metal Box to Energy Solution Services, Memphis, TN;

dated June 11, 2019

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1) DCC18-059; UN3321, RAM LSA-II; Fissile Excepted; 7, RQ-1; Spent Resin Mixed

Bed Ion Exchange Media to Bear Creek, TN in a Type-A Cask; dated June 11, 2019

DCC18-023; UN2910, RAM; Excepted Package; 7, Limited Quantity Material to GEL

Labs; Containing Samples for 10CFR61 Analysis; dated March 18,

DCC18-019; UN2910, RAM; Excepted Package; 7, Limited Quantity Material of

Valves to Spartanburg, SC for Recertification; dated March 11, 2019

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) PMP-7110-PIP-001; Reactor Oversight Program Performance Indicators (PIs) and

Monthly Operating Report Data for Reactor Coolant Specific Activity; Unit 1; from

January 1, 2018 through December 31, 2018

(2) PMP-7110-PIP-001; Reactor Oversight Program PIs and Monthly Operating Report

Data for Reactor Coolant Specific Activity; Unit 2; from January 1, 2018 through

December 31, 2018

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed licensee Nuclear Oversight reports, Nuclear Safety Review

Board (NSRB) reports, and System Health summaries to identify potential adverse

trends in documented issues that were not entered into the licensees corrective

action program. The inspectors also assessed NRC findings to identify trends.

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples 1 Partial)

The inspectors reviewed the licensees implementation of the corrective action program

related to the following issues:

(1) (Partial)

Missing Lateral Support Shim for Reactor Coolant Pump (RCP)-11

(2) Through-Wall Leak on Unit 1 RCP Seal Injection Lines

(3) Unit 1 Steam Generator Stop Valve Dump Valve Failed Surveillance

8

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants

Operation of an Independent Spent Fuel Storage Installation at Operating Plants (1 Partial)

(1) (Partial)

The inspectors closed Unresolved Item 05000315/2018003-002; 05000316/2018003-

02, Site Specific Shielding and Barriers for HI-TRAC Transfer Cask Require NRC

Approval Prior to Use. The details of this review are documented in the inspection

results below. No findings or violations were identified.

INSPECTION RESULTS

Unresolved Item Site Specific Shielding and Barriers for HI-TRAC Transfer 60855.1

(Closed) Cask Require NRC Approval Prior to Use

URI 05000315,05000316/2018003-02

Description:

During the 2018 loading campaign, the licensee loaded spent fuel into Holtec Multi-Purpose

Canister (MPC) 32 with Holtec International Transfer Cask (HI-TRAC) 125D. The site was

using Holtec International Storage Module (HI-STORM) 100 CoC [Certificate of Compliance]

No. 1014, Amendment No. 9, Revision 1 (9R1). During the campaign, the licensee used

additional shielding for As Low As Is Reasonably Achievable (ALARA) purposes. The

additional shielding was in contact with the upper portions of the HI-TRAC and surrounding,

but not in contact, with the HI-TRAC, which could hinder airflow or radiation heat transfer from

the HI-TRAC. The licensee identified that the use of the shielding was not bounded by the

conditions described in the cask Final Safety Analysis Report (FSAR) and subsequently

requested Holtec to perform a site-specific thermal analysis to include the shielding. The

site-specific thermal analysis contained inputs that were different than the design basis

calculation inputs contained in the FSAR.

The licensee performed a 10 CFR 72.48 screening and evaluation, which concluded that the

activity could be implemented without prior NRC approval. Subsequently, the 10 CFR 72.212

report was revised to allow the use of temporary shielding, and the licensee administratively

imposed lower building temperatures limits and nuclear fuel assembly heat load limits from

those specified in CoC No. 1014, Amendment No. 9R1, as determined in the site-specific

thermal analysis. The licensee identified that the use of temporary shielding had the potential

to result in CoC No. 1014, Amendment No. 9R1, Appendix B, Design Features, Section 3.9,

and Approved Contents, Section 2.4, being non-conservative. Specifically, with the shielding

in use, more restrictive requirements than those established in CoC No. 1014, Amendment

No. 9R1 were necessary to ensure alignment with the FSAR safety analyses for peak

cladding temperature (PCT) limits.

This issue was reviewed by the inspectors and technical specialists in the Division of Spent

Fuel Management to determine compliance with Section 3.9 of CoC No. 1014, Amendment

No. 9R1, Appendix B; potential non-conservatism of Section 3.9 of CoC No. 1014,

Amendment No. 9R1, Appendix B; and compliance with 10 CFR 72.48(c)(1)(ii)(B).

Regarding whether the licensee was compliant with CoC No. 1014, Amendment No. 9R1;

Appendix B, Section 3.9, Design Features, stated the following:

9

Short term operations involving the HI-TRAC transfer cask can be carried out if the reference

ambient temperature (three-day average around the cask) is below the Threshold

Temperature of 110 degrees F [Fahrenheit] ambient temperature, applicable during HI-TRAC

transfer operations inside the 10 CFR Part 50 or 10 CFR Part 52 structural boundary and 90

degrees F outside of it. The determination of the Threshold Temperature compliance shall be

made based on the best available thermal data for the site. If the reference ambient

temperature exceeds the corresponding Threshold Temperature, then a site-specific analysis

shall be performed using the actual heat load and reference ambient temperature equal to the

three-day average to ensure that the steady state peak fuel cladding temperature will remain

below the 400°C [degrees Celcius] limit.

While the above implied that a site-specific analysis was not necessary when the reference

ambient temperature was below the corresponding threshold temperature, it did not preclude

a site-specific analysis. Therefore, the licensee performed a site-specific analysis with the

use of additional shielding and the administrative limits implemented by the licensee, which

were bounded by the limits of Section 3.9 of Holtec CoC No. 1014, Amendment No. 9R1,

Appendix B. Therefore, the licensee was compliant with Section 3.9 of Holtec CoC No. 1014,

Amendment No. 9R1, Appendix B.

Regarding whether Section 3.9, Design Features, of CoC No. 1014, Amendment No. 9R1,

Appendix B, was non-conservative, based on a review of Holtec Report No. HI-2177676,

Thermal Evaluation of Shielding on HI-TRAC, which analyzed the transfer cask with

temporary shielding in place, the inspectors determined that the use of the temporary

shielding rendered the Design Features Section 3.9 and Approved Contents Section 2.4 of

CoC No. 1014, Amendment No. 9R1, Appendix B as non-conservative. However, by

performing a site-specific thermal analysis and imposing temperature and fuel loading

restrictions, the licensee remained compliant with the requirements of CoC No. 1014,

Amendment No. 9R1.

Regarding whether the licensee was compliant with 10 CFR 72.48(c)(1)(ii)(B), CNP 72.48 No.

7248-2018-0139-02, Thermal Evaluation of Shielding Package Around the HI-TRAC at D.C.

Cook, provided the 10 CFR 72.48 screening of the proposed activity. The licensee

answered No to 10 CFR 72.48 Screening Question E., Does the proposed activity require a

change to the ISFSI [Independent Spent Fuel Storage Installation] Technical Specifications or

the CoC? The licensee provided the explanation, Calculation package (HI-2177676)

provided technical results to demonstrate compliance with CoC No. 1014, Amendment 9,

Revision 1.

Based on the determination that the licensee was compliant with Section 3.9 of CoC No.

1014, Amendment No. 9R1, Appendix B, the inspectors did not find any indication that the

licensee was not in compliance with 10 CFR 72.48.

Since the licensee was compliant with CoC No. 1014, Amendment No. 9R1, Appendix B and

10 CFR 72.48, the inspectors consider this Unresolved Item closed.

Corrective Action References: AR 2018-4056, AR 2018-6342, and AR 2018-6642

10

Main Steam Stop Valve Dump Valve Inoperable for Longer than its Technical Specification

Allowed Outage Time

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [H.14] - 71152

Systems NCV 05000315/2019003-01 Conservative

Open/Closed Bias

The inspectors identified a finding of very low safety significance (i.e., Green) and an

associated Non-Cited Violation (NCV) of Technical Specification (TS) 3.7.2, Steam

Generator Stop Valves (SGVSs), when licensee personnel failed to have four Unit 1 SGSVs

and associated actuator trains operable while in Mode 1 and subsequently failed to restore

the affected SGSV actuator train and SGSV to an operable status or place Unit 1 in Mode 2

within the time limits specified by the associated TS Limiting Condition for Operation (LCO).

In addition, a NCV of TS 3.0.4, LCO Applicability, was identified because the licensee

entered a Mode of applicability without the SGSV actuator train and associated SGSV being

operable as required. Specifically, the licensee failed to identify that Unit 1 #2 SGVS Train B

Dump Valve MRV-222 was inoperable during a post-maintenance test (PMT) conducted on

May 6, 2019; and subsequently entered Mode 1 contrary to TS 3.0.4 and operated for

21 days, contrary to TS 3.7.2.

Description:

During Unit 1 Refueling Outage 29, and while in Mode 2, the licensee adjusted the packing

on #2 SGSV Train B Dump Valve 1-MRV-222. This valve was part of the actuation system

used to operate the #2 SGSV. On May 6, 2019, following the packing adjustment and prior to

a Mode change, the licensee performed portions of the Unit 1 #2 SGSV Train B Dump Valve

surveillance test as a post maintenance test. On the first attempt, the valve failed to stroke

within the required maximum stroke time of 2 seconds. At that time, the licensee believed

that the #2 SGSV Train B Dump Valve operated in a humid environment. To replicate this

environment, the licensee wetted the #2 SGSV Train B Dump Valve packing and stem. The

valve subsequently passed the surveillance test, the licensee declared the Unit 1 #2 SGSV

Train B Dump Valve operable, and on May 9, 2019, transitioned Unit 1 from Mode 2 to

Mode 1.

During the next scheduled Unit 1 #2 SGSV Train B Dump Valve surveillance test on

May 29, 2019, the valve again failed to stroke within the 2 second stroke time limit. The

licensee performed additional investigation and identified that the valve packing had

hardened and required replacement. The licensee also identified that the environment that

was assumed to exist during the previous troubleshooting effort had been incorrect and that,

in fact, the #2 SGSV Train B Dump Valve operated in a non-humid (dry) environment, and

therefore the packing was not wet during operation. The packing was replaced, and following

a successful PMT the Unit 1 #2 SGSV Train B Dump Valve was returned to service.

During inspection activities to assess the licensees corrective actions, the inspectors

identified that the licensee failed to identify that the Unit 1 #2 SGSV Train B Dump Valve and

associated #2 SGSV was inoperable from the time Unit 1 entered Mode 1 on May 9, 2019,

until the issue was corrected on May 30, 2019. Additionally, the licensee failed to assess the

impact of this issue on operability. Following discussions with licensee staff, AR 2019-8511,

Past ODE [Operability Determination Evaluation] Possibly Missed, was generated and an

operability assessment was performed. This assessment was completed on September 24,

11

2019, and concluded that the Unit 1 #2 SGSV Train B Dump Valve and associated #2 SGSV

was inoperable beginning with the transition to Mode 1 on May 9, 2019, until the valve

packing was replaced on May 30, 2019.

Corrective Actions: The licensee performed a past operability assessment under

AR 2019-8511. The deficient condition was corrected previously under AR 2019-5615

on May 30, 2019.

Corrective Action References: AR 2019-5615

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to identify that

the Unit 1 #2 SGSV Train B Dump Valve was inoperable during a PMT was a performance

deficiency. Specifically, the PMT performed by the licensee created more favorable

conditions for valve operation than what existed in the actual operating environment. As a

result, the licensee failed to identify that the Unit 1 #2 SGSV Train B Dump Valve and

associated #2 SGSV was inoperable.

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 finding resulted in one train of SGSV actuators

being inoperable, causing a delay in the opening of the #2 SGSV and rendering the #2 SGSV

also inoperable.

Significance: The inspectors assessed the significance of the finding using Appendix A, The

Significance Determination Process (SDP) for Findings At-Power. The inspectors answered

Yes to Question A.2 in Exhibit 2 because the Unit 1 #2 SGSV Train B Dump Valve was

inoperable for 21 days, which was greater than the TS 3.7.2 Allowed Outage Time of 7 days.

Therefore, a Detailed Risk Evaluation (DRE) was performed using Inspection Manual Chapter (IMC) 0609, Appendix A. The inspectors performed a bounding analysis by failing the Unit 1

1. 2 SGSV Train B Dump Valve for 21 days and determined the delta core damage frequency

(CDF) was 4.7E-9. As a result, the finding was determined to be of very low safety

significance (i.e., Green).

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,

when troubleshooting the Unit 1 #2 SGSV Train B Dump Valve after its failure on

May 6, 2019, the licensee failed to validate the assumptions about the environment in which

the valve operated. This caused the licensee to perform an inadequate PMT and ultimately

fail to restore the valve to an operable status.

Enforcement:

Violation: Technical Specification 3.7.2, Steam Generator Stop Valves (SGSVs), required

that in Mode 1 all four SGSVs and their associated actuator trains be operable. Technical Specification 3.7.2.A required that with one SGSV actuator train inoperable, that the SGSV

actuator train be restored to an operable status within 7 days. Technical Specification 3.7.2.E

required that if the required action and completion time of Technical Specification 3.7.2.A is

not met, to declare each affected SGSV inoperable. Technical Specification 3.7.2.F, Steam

12

Generator Stop Valves (SGSVs), required that with one SGSV inoperable in Mode 1 that the

SGSV be restored to an operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Technical Specification 3.7.2.G

required that if the required action and associated completion time of Technical Specification 3.7.2.F is not met the Unit be placed in Mode 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Technical Specification 3.0.4 required that when a Limiting Condition for Operation is not met,

that entry into a Mode applicable to a technical specification shall only be made when, a) the

associated actions to be entered permit continued operation in the Mode in the applicability

for an unlimited period of time, or b) after the performance of a risk assessment and the

establishment of risk management actions, or c) when an allowance is stated in the individual

value, parameter, or other specification.

Contrary to the above, on May 9, 2019, with Unit 1 in Mode 1 and with the #2 SGSV Train B

Dump Valve, which was a part of the #2 SGSV actuator train, inoperable, the licensee failed

to restore the inoperable #2 SGSV actuator train to an operable status within 7 days and

failed to declare the associated #2 SGSV inoperable. Also, on May 9, 2019, with Unit 1 in

Mode 1 and with the #2 SGSV inoperable, the licensee failed to restore the #2 SGSV to an

operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as required by Technical Specification 3.7.2.F, and failed to

place Unit 1 in Mode 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as required by Technical Specification 3.7.2.G. In

addition, prior to entering Mode 1 from Mode 2 on May 9, 2019, with an inoperable SGSV and

associated Limiting Condition for Operation 3.7.2.G that did not permit continued operation

for an unlimited period of time and did not provide an allowance as stated in an individual

value, parameter, or other specification, the licensee failed to perform a risk assessment and

establish risk management actions as required by Technical Specification 3.0.4.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On October 15, 2019, the inspectors presented the integrated inspection results to

Mr. J. Gebbie, Senior VP and Chief Nuclear Officer, and other members of the licensee

staff.

• On August 8, 2019, the inspectors presented the Radioactive Material

Processing/Transportation and RCS Specific Activity Performance Indicator inspection

results to Mr. S. Lies, Site Vice President, and other members of the licensee staff.

13

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04Q Corrective Action 2018-0075 U1 CD EDG Tripped Due to Air System Issues 01/02/2018

Documents 2018-0242 DG1CD Tripped on Overspeed During a Start 01/08/2018

2018-6841 Unit 1 CD EDG Not Synchronizing to T11D Bus 07/02/2018

2018-6917 Potential Commonality in Recent Repeat Events 07/05/2018

2018-9194 Unit 2 PAC Trip 09/27/2018

Drawings 1-OP-5151D-72 Flow Diagram Emergency Diesel Generator CD Unit 1

OP-1-5113A-9 Flow Diagram Essential Service Water

OP-1-5143-80 Flow Diagram Emergency Core Cooling (RHR) Unit No. 1

OP-1-5148C-30 Flow Diagram Diesel Generator Area & Electric Switchgear

Room Heating & Ventilation System Unit 1

OP-1-5151A-50 Flow Diagram Emergency Diesel Generator AB Unit 1

OP-1-5151C-58 Flow Diagram Emergency Diesel Generator CD Unit 1

OP-1-98013-42 Diesel Generator 1AB and Auxiliaries Elementary Diagram

OP-1-98014-40 Diesel Generator 1CD and Auxiliaries Elementary Diagram

OP-1-98016-41 Diesel Generator 1AB Miscellaneous Auxiliaries Elementary

Diagram

OP-1-98017-46 Diesel Generator 1CD Miscellaneous Auxiliaries Elementary

Diagram

OP-2-5143-75 Flow Diagram Emergency Core Cooling (RHR) Unit No. 2

OP-5151B-61 Flow Diagram Emergency Diesel Generator AB Unit #1

Procedures 1-OHP-4012-032- Operating DG1CD Subsystems 37

008CD

1-OHP-4021-008- Placing Emergency Core Cooling System in Standby 36

002 Readiness

1-OHP-4021-017- Operation of the Residual Heat Removal System 31

001

1-OHP-4021-032- Operation DG1AB Subsystems 32

008AB

1-OHP-4021-032- Operating DG1AB Subsystems 30

008B

1-OHP-4030-156- East Motor Driven Auxiliary Feedwater System Test 14

017E

14

Inspection Type Designation Description or Title Revision or

Procedure Date

2-OHP-4021-008- Placing Emergency Core Cooling System in Standby 36

02 Readiness

2-OHP-4021-032- Operating DG2CD Subsystems - DG2CD Starting Air 32

008CD System Valves

2-OHP-4021-07- Operation of the Residual Heat Removal System 27

001

2-OHP-4030-256- Turbine Driven Auxiliary Feedwater System Test 31

017T

Work Orders 55501397 MTRI, 2-PPS-1, Calibrate/Replace as Necessary

71111.05Q Drawings 12-5972 Fire Hazards Analysis Plan Below Basement Units 1 and 2 5

12-5974 Fire Hazard Analysis Mezzanine Floor El. 609 Units 1 & 2 12

Fire Plans Fire Pre-Plans Volume 1 33

Fire Zone 18 2 CD Diesel Generator Room, Unit 2 Elevation 587 33

Fire Zone 40A 4 kV AB Switchgear Room, Unit 1 Elevation 609-0 33

Fire Zone 47A 4kV AB Switchgear Room, Unit 2 Elevation 609-0 33

71111.06 Calculations MD-12-Flood- Flooding Due to Groundwater Level Increase, Cook Nuclear 1

008-N Plant Flood Hazard Re-Evaluation

PRA-Flood-002 Internal Flooding Impact on Plant Power Distribution 1

PRA-Flood-004 Internal Flooding - Qualitative Screening Analysis 2

PRA-Flood-008 Flood Sources and Associated Flood Mechanisms 2

PRA-Flood-008 Rupture Flow Rates of Flood Sources 2

Appendix F

SD-061206-001 Flooding Evaluation Report for D.C. Cook Nuclear Power 3

Plant

Corrective Action GT-2015-5625-23 Inspection Frequency for Interim Flood Measures 08/12/2015

Documents

Drawings OP-1-5123A Station Drainage - Auxiliary Building, Unit 1 21

OP-12-5123 Station Drainage Auxiliary Building 14

Procedures 1-OHP-4022 ESW System/Rupture 11

12-EHP-4075- Operator Time Critical Actions 16

TCA-001

12-OHP-4027- Flooding Response Deployment 1

FSG-1501

15

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.07A Drawings OP-1-5114-152 Flow Diagram Non-Essential Service Water Unit No. 1

OP-2-5114-93 Flow Diagram Non-Essential Service Water Unit No. 2

Procedures 1-OHP-4022 NESW System Loss/Rupture 14

2-OHP-4021-028- Operation of the Containment Chilled Water System, 44

018 Figure 1, System Drawings

71111.11Q Miscellaneous RQ-C-4431 Secondary Side Break & Pressurized Thermal Shock 1

Analysis

SOER 87-3 Pipe Failures in High Energy Systems Due to Erosion 04/02/1987

Corrosion

71111.12 Corrective Action 2019-5615-1 1-MRV-222 Failed Surveillance 05/29/2019

Documents

Miscellaneous Two-year Unavailability Report for the Supplemental Diesel 09/25/2019

Generator (SDG) System; SSC 12-SDG

71111.15 Calculations DC-D-01-CS-4 Piping and Pipe Support Analysis of CS and RC System for 02

EBASCO Walkdown Package Nos. CS-11 and RC-09

Corrective Action 2018-6093 Increasing Unit 1 CCW Out-Leakage 06/06/2018

Documents 2018-6615 Unidentified HELB Break Locations 06/26/2018

2018-7570-01 Operability Determination Evaluation (Unit 1 East CCW Heat 07/27/2018

Exchanger Leak)

2019-5237 Asymmetrical Natural Circulation Cooldown Issue with Low 05/14/2019

Decay Heat

2019-5666 Revise Procedure to Support TRM Update 05/30/2019

2019-7053 Pressurizer Insurge/Outsurge

AR 2019-6882 U2 Ice Bed Temps Above eSOMS Notification Limits 07/15/2019

AR 2019-7919 12-HV-AFX Charcoal D/P Outside of ESOMS Limits 08/19/2019

Drawings 1-CS-780-L1-2 Containment 3

OP-1-5129 CVCS-Reactor Letdown & Charging 68

OP-12-5148-63 Flow Diagram Auxiliary Building Ventilation Units 1 & 2 63

Engineering 0000055754 Install Mechanical Jumper to Connect the Essential Service 01

Changes Water System to the Component Cooling Water System in

Either Unit to Provide a Source of Makeup Water to the

CCW System

Miscellaneous FHA Exhaust Fan Charcoal Differential Pressure 08/23/2019

Temporary Design, Install Mechanical Jumper to Connect the Essential 03

16

Inspection Type Designation Description or Title Revision or

Procedure Date

Modification 12- Service Water System to the Component Cooling Water

TM-15-49 System in Either Unit to Provide a Source of Makeup Water

to the CCW System

UFSAR Section Rupture of a Steam Pipe 28

14.2.5

WCAP-14717 Evaluation of the Effects of Insurge/Outsurge Out-of-Limit

Transients on the Integrity of the Pressurizer Program

MUHP-5063 Summary Report

Procedures 12-OHP-4021- Component Cooling Water System Operation 48

016-003

12-OHP-5030- Supply ESW to CCW for Makeup Using Temporary 4

016-001 Modification

Work Orders 55504921-01 12-HV-AFX, Auxiliary Building Ventilation Fuel Handling 08/23/2017

Area Exhaust Filter Unit, Replace Charcoal Bed

55504921-02 12-HV-AFX, Auxiliary Building Ventilation Fuel Handling 08/28/2017

Area Exhaust Filter Unit, Perform Test After Charcoal

Replacement

71111.18 Procedures OHI-4016 Conduct of Operations: Guidelines 56

71111.19 Corrective Action 2019-8353 Failed PMT 55533608-05, U1 CD Diesel has a Slight Leak 08/30/2019

Documents on the 1-R Jacket Water Outlet

AR-2019-8528 Unit 1 East CCW Pump Surveillance was Aborted Due to #3 09/06/2019

RCP CCW Flows

Engineering DIT-B-03787-01 Restoration of Component Cooling Water Flow to Unit 1 09/10/2019

Evaluations Reactor Coolant Pump #3 Motor Bearing Cooler

Miscellaneous Clearance Order 2-IMO-312 Actuator

2241552

Procedures 1-OHP-4030-116- East Component Cooling Water Loop Surveillance Test 09/13/2019

020E

1-OHP-4030-132- CD Diesel Generator Operability Test (Train A), DG1CD 57

027CD Fast Speed Start

2-OHP-4030-208- ECCS Valve Operability Test - Train A 35

053A

Shipping Records 55518412-11 MTRS, (R2P) U2 Load New Fuel into SFP

Work Orders 55359920-10 OPS: 2-IMO-312, Stroke for PMT Operability

17

Inspection Type Designation Description or Title Revision or

Procedure Date

55518169-01 MTRS, (R2P) U2 Unload New 17x17 Fuel

55535360-14 MTM, 2-OME-35N Open NESW PP Strainer and Check for 97/21/2019

Debris

55535386-05 2-OME-35S MTM: 2-OME-35S; Open NESW Strainer and 07/22/2019

Check for Debris

WO Task: 1-FMO-231/Perform A-Found Diagnostic 01

55523374 01

71111.20 Miscellaneous Forced Outage Critical Path 07/22/2019

Procedures PMP-2291-OLR- Technical Specification 3.0.4.b Risk Assessment Review 46

001 and Approval Form for Transitioning Modes with an

Intermediate Range Nuclear Instrument Inoperable

71114.06 Miscellaneous 2019 DC Cook DR1 Drill Manual 07/30/2019

2019 DC Cook DC Cook EMPE Drill 07/16/2019

EMPE Manual

DR2 Drill Dress Rehearsal 2 (Team 3) August 13,

Scenario Manual 2019

EP-S-19DR2 2019 Dress Rehearsal #2 1

Procedures RMT-2080-TSC- Activation and Operation of the TSC 27

001

RMT-2080-TSC- Site Emergency Director List 1

CHK-001

RMT-2080-TSC- PET-Operations Checklist 0

CHK-009

71124.08 Calculations PMP-2030-REC- 2016 10CFR61 Scaling Factor Report 11/08/2017

001

PMP-2030-REC- 2017 10CFR61 Scaling Factor Report 10/29/2018

001

Engineering Technical 3002 8- Cask Handling Procedure for USDOT Spec 7A, Type-A 05/14/2018

Evaluations 120A Cask Transportation Cask

Self-Assessments GT-2018-1675 Self Assessment of the Radwaste Program at DC Cook that 08/30/2018

Covers Radwaste Processing, Handling and Transportation

Shipping Records DCC18-043 Compactible Trash to Energy Solution Bear Creek Facility 05/10/2018

for Processing

DCC18-044 A Box of Contaminated Equipment to Framatome, Inc. 05/16/2018

18

Inspection Type Designation Description or Title Revision or

Procedure Date

DCC18-059 Mixed Bed Ion Exchange Spent Resin for Processing to 07/24/2018

Energy Solution Bear Creek, Oak Ridge,TN

DCC18-074 Mixed Bed Resin PRC-1M; Class -B Shipment; UN3321; 11/30/2018

LSA-II; RQ; Contained in a Shipping Cask Model 8-120B; to

Energy Solution for processing

DCC19-033 UN2910 Excepted Package Limited Quantity of Steel Drum 04/15/2019

for Part 61 Anlysis

DCC19-038 Shipment of 2 Sea-Vans Containing Contaminated 04/25/2019

Equipment to Westinghouse

DCC19-041 Compacted Contaminated Trash to Unitech Services, TN 05/01/2019

DCC19-053 1 Sea-van on a Flatbed Trailer Containing a Shipment 06/11/2019

Consigned as UN2913, SCOII Fissile Excepted

71151 Calculations PMP-7110-PIP- Reactor Oversight Program Performance Indicators and 01/01/2018 -

001 Monthly Operating Report Data for Reactor Coolant Specific 12/31/2018

Activity; Unit 1 and 2

71152 Corrective Action 2019-2963 Investigate Reactor Coolant Pump Seal Injection Line Under 03/22/2019

Documents Suspicious Boric Acid Deposit

2019-4341 Failure to Verify Procedure Directed Terminal Points 04/24/2019

2019-4734 Labeling in Unit 1 Lube Oil Tank Room Junction Box 05/03/2019

2019-4895 1-MRV-222 Failed Post Maintenance Test Timing 05/06/2019

2019-5615 1-MRV-222 Failed Surveillance 05/29/2019

2019-8511 Past Operability Determination Possible Missed 09/05/2019

Miscellaneous Outage Control Center Shift Package 09/30/2019

Indiana Michigan Power 2019 Second Quarter Trend Report

AEP-19-005 Donald C. Cook Nuclear Plant Safety Review Board Meeting 03/04/2019

NOS-19-002 Nuclear Oversight Quarterly Report for October - December 01/21/2019

2018

NOS-19-006 Nuclear Oversight Quarterly Report for January - March 04/23/2019

2019

UCR 2215 UFSAR Change Request, Data Sheet 1 of PMP-2350-SAR- 0

001, UFSAR Update Process

Procedures 1-IHP-6040-171- Verification of Turbine Support Systems Interlocks 4

001

19

20