IR 05000315/2019002

Integrated Inspection Report 05000315/2019002 and 05000316/2019002

ML19214A137
Person / Time
Site:	Cook
Issue date:	08/01/2019
From:	Eric Duncan Reactor Projects Region 3 Branch 4
To:	Gebbie J Indiana Michigan Power Co
References
IR 2019002
Preceding documents:	ML19339D858 (5 December 2019)
Download: ML19214A137 (22)

Text

ust 1, 2019

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2INTEGRATED INSPECTION REPORT 05000315/2019002 AND 05000316/2019002

Dear Mr. Gebbie:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant, Units 1 and 2. On July 23, 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.a 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. 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

Inspection Report

Docket Numbers: 05000315 and 05000316 License Numbers: DPR-58 and DPR-74 Report Numbers: 05000315/2019002 and 05000316/2019002 Enterprise Identifier: I-2019-002-0069 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Plant, Units 1 and 2 Location: Bridgman, MI Inspection Dates: April 01, 2019 to June 30, 2019 Inspectors: J. Ellegood, Senior Resident Inspector T. Go, Health Physicist J. Mancuso, Resident Inspector R. Ruiz, Project Engineer J. Rutkowski, Project Engineer 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 Failure to Develop Procedures for Loss of Electrical Bus Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000315,05000316/2019002-01 Open/Closed The inspectors identified a finding of very low safety significance and an associated non-cited violation (NCV) of TS 5.4.1.a when licensee personnel failed to have established procedures for the operation of the electrical distribution system as well as procedures for combating emergencies and other significant events, including a loss of electrical power to safety-related electrical Bus 21B. Because these procedures had not been established, the restoration of safety-related Bus 21B was delayed following a May 17, 2019, electrical fault in the 2-ABD-B switchgear.

Additional Tracking Items Type Issue Number Title Report Section Status URI 05000315,05000316/ Record Retention 71111.21M Closed 2018010-01 Requirements of the Boron Injection Tank and its Associated Support Structure

PLANT STATUS

Unit 1 began the inspection period shutdown and defueled for a refueling outage. On May 8, 2019, the licensee restarted Unit 1 and commenced power ascension. Unit 1 was subsequently held at about 50 percent power to address an East Main Feed Pump issue. On May 18, 2019, the licensee completed repairs to the East Main Feed Pump and resumed power ascension. On May 20, 2019, Unit 1 reached full power and remained at or near full power for the remainder of the inspection period.

Unit 2 operated at or near full power for the entire 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.

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated the summer readiness of offsite and alternate Alternating Current (AC) power systems

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 AB 250 Volt Direct Current (VDC) Battery prior to CD 250 VDC Battery cell replacement, on June 6, 2019

(2) Supplemental Diesel Generators following maintenance on June 6, 2019

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) The inspectors evaluated fire brigade performance on June 20, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 4 Kilovolt (kV) Switchgear Rooms on May 29, 2019

(2) Unit 1 AB and CD 250 VDC Battery Rooms on May 29, 2019

(3) Unit 2 4KV Switchgear Rooms on May 29, 2019

(4) Unit 2 AB and CD 250 VDC Battery Rooms on May 29, 2019

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) The inspectors observed and evaluated licensed operator performance in the main control room during plant heatup and restart from a refueling outage on May 8, 2019 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance during requalification training in the simulator on June 18, 2019

71111.12 - Maintenance Effectiveness Quality Control (IP Section 02.02)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Switchgear 2-ABD-B Bus Bar Replacement Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 2 250 VDC systems

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

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

(1) Unit 2 600V Bus 21B recovery on May 18 and 19, 2019

(2) Emergent Unit 2 CD 250 VDC battery cell replacement on June 6, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 11 Reactor Coolant Pump (RCP) Seismic Support Gap Out of Specification

(2) Unit 1 Aggregate Operability Determination

(3) Unit 2 Pressurizer Pressure Oscillations Due to Spray Valve Opening Intermittently

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 West Centrifugal Charging Pump Power Cable Replacement

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 Reactor Control and Instrumentation (RC&I) return to service testing following upgrade during Refueling Outage (RFO) U1C29

(2) Unit 1 Solid State Protection System (SSPS) return to service testing following upgrade during RFO U1C29

(3) Unit 1 Reactor Vessel V3 examinations following work during RFO U1C29

(4) Unit 1 Upper Cavity inspections and Foreign Material Exclusion (FME) retrieval following work during RFO U1C29

(5) U1 Fuel Upender following repairs during RFO U1C29

(6) Unit 1 Reactor Coolant Pump (RCP) lateral bumper repair

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated RFO U1C29

===71111.21M - Design Bases Assurance Inspection (Teams)

The inspectors completed their review of Unresolved Item (URI)05000315/2018010-01; 05000316/2018010-01; Record Retention Requirements of the Boron Injection Tank. The review and closure of this URI did not constitute an inspection sample.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

(1) Unit 2 IHP-4030-228-005B, Train B Containment Equalization Fan Surveillance Testing, on June 20, 2019 Surveillance Tests (other) (IP Section 03.01) ===

(1) Unit 1 Low Power Physics Testing on May 8, 2019

(2) Unit 1 Turbine-Driven Auxiliary Feedwater Testing on May 7, 2019

(3) Unit 1 IHP-4030-151-010, Steam Generators 2 and 3 Steam Pressure Protection Set 3 Channel Operational Test and Calibration, on June 18,

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls (IP Section 02.01)

The inspectors evaluated airborne controls and radioactive monitoring.

(1) Installed Ventilation Systems:

• 2HV-AES-2; Auxiliary Building Ventilation Engineered Safety Feature Exhaust Fan #2

• 12-HV-AFX; Auxiliary Building Ventilation Fuel Handling and Exhaust Filter Unit Temporary Ventilation Systems:

• Refuel Floor 650 Hold Down Spring Cutting Area

• Unit 1 Down Draft Table at 650 Upper Containment

• Unit 1 Lower Containment Portable or Installed Monitoring Systems:

• Serial Number 342 at Refuel Floor 650

• Serial Number 631 at Unit 1 Lower Containment

• Serial Number 585 at Unit 1 Lower Containment Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)

The inspectors evaluated self-contained breathing apparatus program implementation.

(1) Status and Surveillance Records for Self-Contained Breathing Apparatuses (SCBAs):

• DW222039

• DW222036

• DW223151

• DW119016

• DW220024 SCBA Fit for On-Shift Operators:

• Three Operations Personnel SCBA Maintenance Check:

• DW222039

• DW222036

• DW223151

• DW119016

• DW220024 Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)

The inspectors evaluated the licensees use of respiratory protection devices by:

(1) Evaluations for the Use of Respiratory Protection:

• RWP-191154; Decontamination of Highly Contaminated Area Near Reactor Coolant Pump No. 13

• RWP-191140; Installation of Insulation of Reactor Coolant Pump No. 13

• RWP-191142; U1C29 Containment Scaffold Activities Respiratory Protection Use During Work Activities:

• RWP-191105; U1C29 Reactor Lower Internal/Baffle Bolt Activities

• RWP-191175; U1C29 Regeneration Heat Exchanger Locked High Radiation Activities Medical Fitness for Use of Respiratory Protection Devices:

• Three Operations Personnel Observation of Donning, Doffing and Functional Test:

• Three Operations Personnel

• Two Radiation Protection Personnel Respiratory Protection Device Evaluation

• Six Powered Air Purifying Respirators; PureFlo ICS Model PF60ESM

71124.04 - Occupational Dose Assessment External Dosimetry (IP Section 02.02)

(1) The inspectors evaluated the licensees external dosimetry program implementation

Internal Dosimetry (IP Section 02.03) (1 Sample)

(1) The inspectors evaluated the licensee's internal dosimetry program implementation Whole Body Counts

• Whole Body Count performed on March 12, 2019 In-Vitro Internal Monitoring

• GEL Lab Tritium Analysis dated January 21, 2016 Dose Assessments Performed Using Air Sampling and Derived Air Concentration (DAC) Monitoring

• RWP-191175; Monitoring dated March 27, 2019

• RWP-191142; Monitoring dated March 19, 2019

Source Term Categorization (IP Section 02.01) (1 Sample)

(1) The inspectors evaluated the licensees characterization of the source term and use of scaling factors for the use of hard-to-detect radionuclide activity

Special Dosimetric Situations (IP Section 02.04) (1 Sample)

(1) The inspectors evaluated special dosimetric situations:

Declared Pregnant Workers

• Declaration on February 14, 2019

• Declaration on November 6, 2018 Effective Dose Equivalent Exposures

• None Available Shallow Dose Equivalent

• None Available Neutron Dose Assessment

• None Available

71124.05 - Radiation Monitoring Instrumentation Calibration and Testing Program (IP Section 02.02)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors, and Small Article Monitors

• SAM-12 No. 153

• GEM-5 No. 1 Personnel Contamination Monitor

• ARGOS No. 6 Personnel Contamination Monitor Failure to Meet Calibration or Source Check Acceptance Criteria

• None were available during this inspection

Walkdowns and Observations (IP Section 02.01) (1 Sample)

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) The inspectors reviewed the following:

Portable Survey Instruments

• Eberline RM-20 No. 272 Calibrated on June 14, 2018

• Ludlum L-177 No. 156878 Calibrated on October 8, 2018

• Telepole TP-032 Calibrated on January 23, 2019

• Thermo Scientific RO-20 No. 356 Calibrated on April 22, 2019

• Eberline Thermo RO-20 No. 359 Calibrated on April 22, 2019

• Victoreen V-451 No. 1325 Calibrated on June 21, 2018

• Rados RDS-710756 Portable Hand Held Calibrated on August 13, 2018

• Rados RDS-710749 Portable Hand Held Calibrated on August 13, 2018

• Thermo E-600 With HP-270 Calibrated on May 4, 2019

• Hopewell BX-3-1 Calibrated on November 14, 2018 Source Check Demonstration

• Eberline Thermo RO-20 No. 359 Calibrated on April 22, 2019

• Rados RDS-710756 Portable Hand Held Calibrated on August 13, 2018

• Rados RDS-710749 Portable Hand Held Calibrated on August 13, 2018

• Thermo E-600 with HP-270 Calibrated on May 4, 2019 Area Radiation Monitors (ARM) and Continuous Air Monitors

• ARM 12-ERA-7507 Sampling SAT Room Radiation Monitor

• ARM 12-ERA-7505 Auxiliary Building 587 Monitor

• ARM 12-ERA-7006 TBX Nuclear Sample Room

• ARM 12-ERA-7000 TBX Nuclear Sample Room

• ARM 12-ERA-9403 Auxiliary Building 609 Hallway Area

• CAM AMS-4 No. 461 Eberline

• CAM AMS-4 No. 342 Eberline

• CAM AMS-4 No. 527 Eberline 609 Radwaste Handling Building

• CAM AMS-4 No. 586 Eberline Spent Fuel Pool Area Personnel Contamination Monitors, Portal Monitors and Small Article Monitors (SAM)

• SAM-12 No. 153

• GEM-5 No. 1 Personnel Contamination Monitor

• ARGOS No. 6 Personnel Contamination Monitor

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) ===

(1) PMP-7110-PIP-001 Reactor Oversight Program Performance Indicators and Monthly Operating Report Data; Occupational Exposure Control Data Samples; reviewed from January 1, 2018 through December 31, 2018 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample.

(IP Section 02.16) (1 Sample)

(1) PMP-7110-PIP-001 Reactor Oversight Program Performance Indicators and Monthly Operating Report; RETS/ODCM Radiological Effluent Occurrence Samples; Reviewed from January 1, 2018 through December 31, 2018

71152 - Problem Identification and Resolution Annual Follow-Up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Capture of and review for applicability of operating experience with emphasis on items reported per the requirements of 10 CFR 21

(2) Operator response to loss of Bus 21B

INSPECTION RESULTS

Unresolved Item Record Retention Requirements of the Boron Injection 71111.21M (Closed) Tank and its Associated Support Structure 05000315,05000316/2018010-01

Description:

As part of follow-up inspection activities to address issues previously identified in Unresolved Item (URI)05000315/2018010-01; 05000316/2018010-01, the inspectors reviewed additional information provided by the licensee regarding the design and licensing basis of the boron injection tank and its associated support structure and consulted with technical staff from the Office of Nuclear Reactor Regulation (NRR). Based on this review, the inspectors sufficiently resolved the issues discussed in URIs05000315/2018010-01; 05000316/2018010-01 and consider URI 05000315/2018010-01; 05000316/2018010-01 closed. In particular, the inspectors did not identify any licensee actions that were inconsistent with the design and licensing basis of the boron injection tank and its associated support structure.

Corrective Action Reference(s): AR 2018-7104, Lack in Documentation for BIT (Boron Injection Tank) 1-TK-11, on 07/12/2018.

Failure to Develop Procedures for Loss of Electrical Bus Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000315,05000316/2019002-01 Open/Closed The inspectors identified a finding of very low safety significance and an associated non-cited violation (NCV) of TS 5.4.1.a when licensee personnel failed to have established procedures for the operation of the electrical distribution system as well as procedures for combating emergencies and other significant events, including a loss of electrical power to safety-related electrical Bus 21B. Because these procedures had not been established, the restoration of safety-related Bus 21B was delayed following a May 17, 2019, electrical fault in the 2-ABD-B switchgear.

Description:

On May 17, 2019, a Unit 2 electrical fault resulted in the loss of safety-related Bus 21B. The licensee immediately entered LCO 3.8.9, Distribution Systems - Operating, Condition A and declared Bus 21B and all of its associated loads inoperable. Control room staff subsequently identified that event response procedures had not been established to address the loss of Bus 21B and in lieu of a response procedure, consulted numerous resources to guide their response to the event. These resources included a number of alarm response procedures (ARPs) as well as Procedure OHP-4021-082-021, Removal and Restoration of Power to 600V Bus 21B and Associated Motor Control Centers. This procedure addressed the de-energization and restoration of Bus 21B as well as buses that were powered from Bus 21B in a non-emergency situation. Since these buses provide power to numerous safety-related loads, the procedure was intended to be implemented only with the plant in Mode 5, Mode 6, or Defueled. Coincident with the control room staff stabilizing the plant, Auxiliary Equipment Operators (AEOs) conducted a plant walkdown and determined that the 2-ABD-B switchgear was the source of the fault. The control room staff subsequently implemented actions to de-energize and electrically isolate the 2-ABD-B switchgear and to recover Bus 21B.

The Shift Technical Advisor subsequently identified that Power-Operated Relief Valve (PORV) block valve 2-NMO-152 received power from Bus 21B and confirmed that status lights for the valve were not illuminated. The PORVs were specifically addressed in Technical Specification (TS) 3.4.11, Pressurizer Power Operated Relief Valves (PORVs)and, if inoperable, in accordance with LCO 3.4.11 Condition A, required closing the associated block valve within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The crew was also required to perform the action of LCO 3.4.11 Condition C to place the associated PORV in manual control within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Further, LCO 3.4.11 Condition H required that if the requirements of LCO 3.4.11 Condition A and/or Condition C were not met, that the plant be placed in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. However, the control room crew failed to promptly recognize that the PORV was rendered inoperable when power was lost to Bus 21B, and therefore the actions required by LCO 3.4.11 Condition A and LCO 3.4.11 Condition C, were not performed until about 1-1/2 hours after the LCO completion times of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> had expired, but prior to the expiration of the requirement to place the plant in Mode 3.

Following completion of the actions related to the inoperable PORV, the licensee continued preparations to restore power to Bus 21B. Subsequently, with the 2-ABD-B switchgear electrically isolated, the licensee unsuccessfully attempted to close the supply breaker to Bus 21B. The licensee did not initially understand the cause for this failure until an operator identified that an interlock between the Bus 21B breaker and a Bus 21B crosstie breaker was not satisfied with the crosstie breaker in its racked out position. Subsequently, the licensee racked the crosstie breaker into its test position, which satisfied the interlock requirement, and successfully closed the Bus 21B supply breaker to restore power to all of the Bus 21B loads.

Following restoration of Bus 21B, the licensee exited LCO 3.8.9 Condition A within the required LCO Allowed Outage Time (AOT). Technical Requirements Manual (TRM) 8.11.2, FLEX Plant Connection Points and Plant Components, and FLEX Plant Connection Points and Plant Components Combined with FLEX Portable Equipment, specified in Technical Requirements for Operation (TRO) 8.11.2 that the FLEX plant connection points and plant components specified in the FLEX Equipment Program shall be available. The Actions Section of TRO 8.11.2 included a Note, which specified that TRO 8.11.2 Condition entry was not required for the unavailability of plant components covered by Technical Specifications or other TRM sections. Therefore, until Bus 21B was restored, none of the conditions of TRO 8.11.2 was applicable. However, following restoration of Bus 21B and the 2-ABD-B switchgear, the inspectors conducted a plant walkdown and identified that the 2-ABD-B switchgear included a 600V FLEX connection point, and therefore the conditions of TRO 8.11.2 had been required to be met between the time that Bus 21B was restored to service and the 2-ABD-B switchgear was repaired and returned to service. TRO 8.11.2 Condition A required that if one or more required FLEX primary or alternate connection points or plant components specified in the FLEX Equipment Program were not available, then in accordance with Condition A.1 the licensee must immediately verify that a primary or alternate connection point was available. Furthermore, TRO 8.11.2 Condition C required that if the requirements of Condition A.1 were not met within the required completion time that, in accordance with Condition C.1, the licensee must immediately initiate action to implement compensatory measures. However, after the inspectors identified that the 2-ABD-B switchgear included a 600V FLEX connection point, the inspectors determined that licensee staff failed to perform any of the required actions of TRM 8.11.2 although the 2-ABD-B switchgear FLEX connection point was specified in the FLEX Equipment Program. The licensee restored the connection point to an available status on May 22, 2019, when the 2-ABD-B switchgear was restored.

Corrective Actions: Immediate corrective actions by the licensee included electrically isolating the faulted 2-ABD-B switchgear and re-energizing Bus 21B. The licensee subsequently replaced damaged bus bars and recovered the 2-ABD-B switchgear. The licensee also entered this issue into their corrective action program.

Corrective Action References: AR-2019-5318, Failure of Auxiliary Jacket Water Breaker Causes Loss of Bus 21B 600V, May 17, 2019

Performance Assessment:

Performance Deficiency: The inspectors concluded that the failure to have established procedures that addressed the operation of the electrical distribution system, including a fault in the 2-ABD-B switchgear that resulted in the loss of Bus 21B that included safety-related loads, was a performance deficiency. TS 5.4.1.a required that the licensee establish, implement and maintain procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), which included procedures for the operation of the Alternating Current System and procedures for combating significant events including a loss of electrical power. However, the licensee failed to have established procedures for the operation of Bus 21B and its loads in Mode 1 and failed to have established procedures for combating a loss of Bus 21B. As a result of the licensee's failure to have established procedures for the operation of Bus 21B, and following an event that resulted in the loss of Bus 21B, licensee personnel failed to promptly identify that actions were required to place an inoperable PORV in manual control and close the associated block valve, and failed to verify that a FLEX primary or alternate connection point was available.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone. Specifically, the licensee failed to establish procedures to address the operation of the Alternating Current System and for combating significant events, including a loss of electrical power event. Specifically, the licensee failed to establish procedures to address the operation of electrical Bus 21B and the combating of a loss of electrical Bus 21B in Mode 1.

Significance: The inspectors assessed the significance of the Finding-using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors reviewed the issue in accordance with Inspection Manual Chapter (IMC) 0609 Appendix A.

Using Exhibit 2, the inspectors determined the issue specific to restoration of Bus 21B screened as having very low risk significance (i.e., Green) because it was not inoperable for longer than the TS Allowed Outage Time (AOT). The inspectors concluded that the failure to complete the TRM actions within the required completion time was also of very low risk significance (i.e., Green) because the inspectors answered No to all of the questions in Exhibit 2. The issue related to the inoperable PORV block valve required a Detailed Risk Evaluation (DRE) because the loss of power to the block valve represented a loss of the ability to isolate the associated PORV in the event the PORV failed to close following a open demand signal.

The inspectors modeled the inoperability of a pressurizer PORV block valve for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to bound the time in excess of the AOT the block valve was inoperable. Using this duration, the Standardized Plant Analysis Risk (SPAR) model calculated an Incremental Conditional Core Damage Probability (ICCDP) of 1.5E10-10. With this very low risk impact, the inspectors concluded that the issue was of very low risk significance (i.e., Green). The inspectors consulted with the regional Senior Reactor Analyst (SRA) regarding their conclusion. The SRA agreed that the issue was of very low risk significance.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: TS 5.4.1.a requires, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. NRC Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3.s(2), Electrical Systems - Onsite, includes procedures for the operation of the Alternating Current System and Section 6.c, Procedures for Combatting Emergencies and Other Significant Events - Loss of Electrical Power, includes procedures for combating significant events including a loss of electrical power event.

Contrary to the above, as of May 17, 2019, the licensee failed to establish procedures to address the operation of the Alternating Current System and for combating significant events, including a loss of electrical power event. Specifically, the licensee failed to establish procedures to address the operation of electrical Bus 21B while in Mode 1 and for combating a loss of electrical Bus 21B.

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 April 11, 2019, the inspectors presented the URI 05000315/2018010-01; 05000316/2018010-01 inspection results to Mr. J. Petro and other members of the licensee staff.

• On April 18, 2019, the inspectors presented the Radiation Protection inspection results to Mr. S. Lies, Site Vice President, and other members of the licensee staff.

• On June 6, 2019, the inspectors presented the Radiation Monitoring Instrumentation and Performance Indicator Verification Review inspection results to Mr. S. Lies, Site Vice President, and other members of the licensee staff.

• On July 23, 2019, the inspectors presented the integrated inspection results to Mr. J. Gebbie and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Procedures 12-OHP-4021- Supplemental Diesel Generator Operations 25

033-001

2-OHP-4021-082- Operation of 2AB & 2CD Battery Chargers 12

006

71111.12 Corrective Action AR 2017-10698 Maintenance Rule Scoping Documents Do Not Comply with 10/22/2017

Documents Site Procedures

AR 2018-4810 Unexpected CR Alarm U2 AB Battery Ground 04/30/2018

GT 2019-1626 STRIDE STI-19-02; Change Battery Surveillance Test 02/20/2019

Interval

Engineering EC-56979 Replacement Vertical Bus, MCC 2-ABD-B 05/19/2019

Changes

Engineering 32543 Supporting EC-56979 Busbar Requirements

Evaluations

Work Orders 55529338-01 Battery AB, CD, and N-Train Battery Quarterly Surveillance 05/24/2019

71111.13 Corrective Action AR 2019-3488 Boric Acid Deposit on the #4 Reactor Coolant Pump Seal 04/03/2019

Documents Injection 2 Line

71111.15 AR 2019-3126 Aggregate ODE or U1C29 03/26/2019

AR 2019-6101 Unexpected Lowering in Pressurizer Pressure 06/15/2019

Corrective Action AR 2019-4856 11 RCP-Loose Lateral Restraining Bumper Shim 05/05/2019

Documents

Resulting from

Inspection

71111.18 Engineering EC-0000056878 Contingency 1-80007R-1 Cable Replacement 0

Changes

Procedures PMP-5040-SDP- Standard Design Process Interface 2

001

PMP-5040-SDP- Standard Design Process Interface 3

001

71111.19 Drawings 1-2-3834-5 N.S.S.S. Support Framing Coolant Pump Support Sections 5

& Details - D.C. Cook Nuclear Plant

Engineering EC-0000052453- Unit 1 Reactor Controls & Instrumentation (RCI), Calibration 1

Changes TP-003B Testing of Inputs for Control Group 2

Inspection Type Designation Description or Title Revision or

Procedure Date

EC-0000052453- Unit 1 Reactor Controls & Instrumentation (RCI), Calibration 1

TP-003D Testing of Inputs for Control Group 4

EC-0000054411- U1 Solid State Protection System (SSPS) Train B Upgrade 3

TP-003 Functional Testing

Miscellaneous CYCLE 10912- Online Daily Cycle (U1 DGAB) 03/19/2019

11007

Procedures 1-EHP-4030-134- Unit 1 LLRT - Test Sketch Leak Rate Data Sheet 25

203

1-OHP-4030-132- DG1AB Load Sequencing & ESF Testing 49

217B

Work Orders 55454613-09 MTI, 1-QRV-171, Check Indications, Adjust/Calibrate Limit 03/29/2019

Switches

71111.20 Miscellaneous DIT-S-06353-00 Unit 1 Cycle 28, End-of-Cycle (EOC) Time-to-Boil 02/04/2019

Information

R-EDG-DGAB- Unit 1 AB Diesel Generator Jacket Water Pump Clearance 0

0904

R-NI-FMS-0657 Flux Mapping System Clearance 2

Procedures 1-OHP-4021-001- Plant Heatup from Cold Shutdown to Hot Standby 82

001

1-OHP-4021-001- Reactor Start-Up 65

2

2-EHP-4030- Low Power Physics Tests with Dynamic Rod Worth 17

2-356 Measurement

2-THP-6010- ALARA Plan Template 04/24/2019

RPP-413

Radiation SW_VSDS-M- U1-U/C Upender Survey for Diving 04/24/2019

Surveys 20190425-1

Radiation Work 191186 U1C29 - Spent Fuel Pool Transfer Canal and Refuel Cavity 1

Permits (RWPs) Diving Activities

71111.21M Corrective Action AR 2018-7104 Lack in Documentation for BIT 1-TK-11 07/12/2018

Documents

Miscellaneous ASME Section III 1968 thru

Winter 1969

Addenda

Inspection Type Designation Description or Title Revision or

Procedure Date

ASME Section VIII 1968 thru

Winter 1969

Addenda

71111.22 Corrective Action GT 2019-6188 1-IHP-4030-151-010 Step 4.15.4 Needs a Note 06/18/2019

Documents

Procedures 1-IHP-4030-151- Steam Generators 2 and 3 Steam Pressure Protection Set 3 6

010 Channel Operational Test and Calibration

1-OHP-4030-156- Turbine Driven Auxiliary Feedwater System Test 26

017T

2-EHP-4030- Low Power Physics Tests with Dynamic Rod Worth 17

2-356 Measurement

2-IHP-4030-228- Train B CEQ Fan Surveillance and Engineered Safety 0

005B Feature Response Time Test

71124.03 Calculations S279303 Fit Test Report 04/10/2019

Corrective Action AR-2017-8946 Auxiliary Building Fuel Area Fan Charcoal, Door Seals and 09/16/2017

Documents Latches Needed to be Replaced

AR-2018-0654 Evaluate Available Charcoal Run Time for 1-HV-AES-1; 01/22/2018

Percent Efficiency was 96.37 %

Miscellaneous 353790 - 0 TRI Air Testing, Inc.; Laboratory Report Compressed 02/01/2019

Air/Gas Quality Testing

55526138-01 OPFP, Air Hawk SCBA Monthly Inspection 07/30/2018 -

2/06/2018

Procedures FPP-2281-RES- Maintenance and Repair of Respiratory Devices 13

201

FPP-2281-RES- Respiratory Fit Testing With the Portacount 6

210

PMP-2281-RES- Control and Use of Respiratory Protection Devices 19

001

Radiation Work Installation of Insulation of RCP No. 13 0

Permits (RWPs) RWP-191140

RWP-191105 Reactor Baffle Bolt Inspection and Repair Activities Include 1

Lower Internal Movements

RWP-191154 Decontamination of Highly Contaminated Area Near Reactor 0

Coolant Pump No.13

Inspection Type Designation Description or Title Revision or

Procedure Date

RWP-191175 Medium Risk: Valve Maintenance Activities 0

71124.04 Calculations 27212 Multiple WBC Summary Sheet for Contaminated Individuals 03/11/2019 -

03/14/2019

DPW Report Declared Pregnant Women Radiation Exposure Monitoring, 04/09/2017 -

Reporting and Dose Control 01/09/2019

RWP-191175 Valve Maintenance Activities; Total Effective Dose 03/22/2019

Equivalent Evaluation Based on Derived Air Concentration

of Particulate

Corrective Action AR-2019-3655 Worker Received a Level 2 Particle Percon on the Left Shirt 04/08/2019

Documents Sleeve in Clean Area at 609 Elevation Auxiliary Building

West Hallway

Procedures 12-THP-6010- Operation of the ORTEC Fastscan Whole Body Counter 11

RPP-212

PMP-6010-RPP- Radiation Exposure Monitoring, Reporting and Dose Control 17

100

71124.05 Calibration 12-THP-6010- AMS-4 No.586 Calibration Data Sheet 01/03/2019

Records RPC-515

2-THP-6010- AMS-4 Calibration Data Sheet No. 585 02/20/2019

RPC-515

2-THP-6010- Calibration of the Mirion Technologies RDS-31 Meter and 02/18/2019

RPC-516 Smart Probes; No. RDS-712427

2-THP-6010- Calibration of the Mirion Technologies RDS-31 Meter and 01/22/2019

RPC-516 Smart Probes; SN RDS-712427

2-THP-6010- Calibration of Portable Dose-Rate Instrument Calibration 01/14/2019

RPC-517 Data Sheet

2-THP-6010- Calibration of the Radiological Contamination Friskers; RM- 11/07/2019

RPC-525 14/RM-20/L-177 Calibration Data Sheet; RM-14 No. 8702

2-THP-6010- Calibration of the ORTEC Fastscan Whole Body Counter; 09/13/2018

RPC-535 Reference Standard and Calibration Confirmation

Worksheet; SN. FS-2

2-THP-6010- Calibration of the F&J Battery Powered Air Sampler 11/12/2018

RPC-537 Calibration Data Sheet; SN BPLV-10398 CRP-362

2-THP-6010- Calibration of the MGP Model AMP-50 and AMP-100 Area 04/20/2019

RPC-555 Monitor

Inspection Type Designation Description or Title Revision or

Procedure Date

2-THP-6010- Calibration of the Ludlum 3030P Alpha-Beta Counter Data 02/11/2019

RPC-577 Sheet; SN 264783

2-THP-6010- Calibration of the Thermo Scientific Small Article Monitor 04/17/2019

RPC-596 SAM-12 No. 148

2-THP- Calibration of Portable Dose-Rate Instruments RO-20 No. 04/01/2019

6010RPC-517 356

2-THP-6020- Gamma Spectrometry Using ORTEC Global Value and 10/31/2016

INS-526 Gamma Vision Software; Performed on Detector Nos. 3 and

Radiation Safety Thermo Scientific Model E-600R Calibration with Model 02/22/2019

& Certified Probe SHP-270; SN 02603

Services RSCS

Calibration

Certificate No.

2603129836-0

Procedures 12-THP-6010- Calibration of the Eberline Model AMS-4 7

RPC-515

71151 Miscellaneous PI Verification Reactor Oversight Program Performance Indicators for January

PMP-7110-PIP- Monthly Operating Report Data 2018 through

001 December

2018

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

001 Monthly Operating Report Data; RETS/ODCM Radiological 12/2018

Effluent Occurrences

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

001 Monthly Operating Report Data; Occupational Exposure 12/2018

Control Effectiveness

71152 Corrective Action AR 2019-5318 Failure of Auxiliary Jacket Water Breaker Causes Loss of 05/17/2019

Documents 21B 600V

AR 2019-5592 Bus Restoration Procedure Inappropriately N/A'd 05/28/2019

GT-2017-13010 2018 Part 21 Tracking Items 12/20/2017

GT-2019-0164 2019 Part 21 Tracking Items 01/07/2019

Procedures PMP-7030-P21- Processing and Reporting of Defects and Noncompliances 8

001

19