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#REDIRECT [[IR 05000315/2011011]]
{{Adams
| number = ML111320302
| issue date = 05/13/2011
| title = IR 05000315-11-011, on 05000316/2011011, 03/23/2011 - 04/29/2011; D. C. Cook Nuclear Power Plant Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
| author name = Cameron J
| author affiliation = NRC/RGN-III/DRP/B6
| addressee name = Weber L
| addressee affiliation = Nuclear Generation Group, Indiana Michigan Power Co
| docket = 05000315, 05000316
| license number = DPR-058, DPR-074
| contact person =
| document report number = IR-11-011
| document type = Inspection Report, Letter
| page count = 23
}}
See also: [[see also::IR 05000315/2011011]]
 
=Text=
{{#Wiki_filter:UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532
-4352  May 13, 2011
 
Mr. Larry Weber
Senior Vice President and
  Chief Nuclear Officer
Indiana Michigan Power Company
Nuclear Generation Group
One Cook Place
Bridgman, MI  49106
SUBJECT: D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183
INSPECTION REPORT 05000315/2011011; 05000316/2011011
 
Dear Mr. Weber: On April 2 9, 2011 , the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your D. C. Cook Nuclear Power Plant, Units 1 and 2 , using Temporary Instruction
(TI) 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
."  The enclosed inspection report documents the inspection results which were discussed on April 29, 2011, with Mr. J. Gebbie, and other members of your staff.  The objective of this inspection was to promptly assess the capabilities of the D. C. Cook
Nuclear Power Plant to respond to extraordinary consequences similar to those that have
recently occurred at the Japanese Fukushima Daiichi Nuclear Station.  The results from this inspection, along with the results from this inspection performed at other operating commercial
nuclear plants in the United States will be used to evaluate the U.S. nuclear industry's readiness to safely respond to similar events.  These results will also help the NRC to determine if additional regulatory actions are warranted.
  All of the potential issues and observations identified by this inspection are contained in this
report.  The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations.  Any resulting findings or violations will be documented by the NRC in a separate report.  You are not required to respond to this
letter.   
  L. Weber    -2-  In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html
(the Public Electronic Reading Room).
      Sincerely,        /RA/        Jamnes L. Cameron, Chief      Branch 6      Division of Reactor Projects
 
Docket Nos.
50-315; 50-316 License Nos. DPR
-58; DPR-74  Enclosure:
Inspection Report 05000315/2011011; 05000316/2011011
cc w/encl:
Distribution via ListServ
 
Enclosure U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos:
05000315; 05000316
License Nos:
DPR-58; DPR-74 Report No:
05000315/2011011; 05000316/2011011
Licensee: Indiana Michigan Power Company
Facility: D. C. Cook Nuclear Power Plant, Units 1 and 2
Location: Bridgman, MI
Dates: March 23, 2011, through April 2
9, 2011  Inspectors: J. Lennartz, Senior Resident Inspector
  P. LaFlamme, Resident Inspector
   
Approved by:
Jamnes L. Cameron, Chief
  Branch 6  Division of Reactor Projects
 
 
1  Enclosure INSPECTION SCOPE
  IR 05000315/2011011; 05000316/2011011, 03/23/2011 - 04/2 9/2011; D. C. Cook Nuclear Power Plant Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.    This report covers an announced Temporary Instruction inspection.  The inspection was conducted by
resident inspectors.  The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
INSPECTION SCOPE
  The intent of the TI is to provide a broad overview of the industry's preparedness for events that may exceed the current design basis for a plant.  The focus of the TI was on (1) assessing the licensee's capability to mitigate consequences from large fires or explosions on site,
(2) assessing the licensee's capability to mitigate station blackout (SBO) conditions, (3) assessing the licensee's capability to mitigate internal and external flooding events accounted for by the station's design, and (4) assessing the thoroughness of the licensee's walk
 
downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site.  If necessary, a more specific follow
-up inspection will be performed at a later date.
  INSPECTION RESULTS
  All of the potential issues and observations identified by this inspection are contained in this report.  The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations.  Any resulting findings or violations will be documented by the NRC in a separate report.   
  2  Enclosure 03.01  Assess the licensee's capability to mitigate conditions that result
from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh).  Use Inspection Procedure (IP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline.  If IP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of
inspection.
Particular emphasis should be placed on strategies related to the spent fuel pool.  The inspection should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action
  Describe what the licensee did to test or inspect equipment.
a. Verify through test or inspection that equipment is available and functional. Active equipment shall be tested and passive equipment shall be walked down and inspected.
It is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested.
  This review should be done for a reasonable sample of mitigating strategies/equipment.
Licensee actions included identifying the equipment (active and passive) as directed by the Extensive Damage Mitigation Guidelines
(EDMGs) utilized for implementing B.5.b actions and the Severe Accident Management Guidelines (SAMGs).  The scope was defined as that equipment specifically designated for B.5.b or SAMG mitigation (i.e., special hoses, fittings, onsite fire truck, etc.).  All equipment, permanent and temporary, that is used to perform
the EDMGs was walked down to verify the equipment was in the correct physical location, and properly labeled.
All procedures were reviewed and, based on the in
-plant walkdowns, credited equipment was verified to be able to meet the EDMGs functional requirements.
  Licensee personnel then identified surveillances/tests and performance frequencies for the identified equipment and reviewed the results of recent tests.  Also, active equipment within the scope defined above that was not permanently installed
was tested (i.e., plant fire truck was tested to verify the capability to meet specified pressure and flow). 
     
   
  3  Enclosure  Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed test results, discussed actions, reviewed records, etc.). 
The inspectors assessed the licensee's capabilities by reviewing the licensee's walkdown activities
and previously performed surveillance tests.  In addition, the inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site
and verified that required testi
ng had been completed satisfactorily.  This included verifying that hoses, fittings, the onsite fire truck, tool boxes, ladders, quick identifiers/ tags and labels were accounted for, properly staged and in adequate material condition as specified by
plant procedure s. Discuss general results including corrective actions by licensee.
Licensee personnel identified that components used for
implementing
the loss of spent fuel pool procedure required enhanced labeling
.  The inspectors verified this issue w as entered into the licensee's corrective action program.
  The inspectors did not identify any issues of concern.
Licensee Action
  Describe the licensee's actions to verify that procedures are in place and can be executed (e.g. walkdowns, demonstrations, tests, etc.)
b. Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and
 
10 CFR 50.54(hh) are in place and are executable.  Licensees may choose not to connect or operate permanently installed equipment during this verification.
 
 
  The licensee performed walkdowns and demonstrations using
their A bnormal Operating Procedures, EDMG, and SAMG procedures credited for B.5.b strategy actions.  The licensee's walkdowns included using Auxiliary Equipment Operators to lay out hoses required to
provide water as credited in their B.5.b analysis, and verifying valve lineups using drawings for credited flow paths.  The licensee
evaluated their ability to perform the procedures, as well as a review of equipment and plant accessibility needed to perform
proceduralized actions. 
 
 
   
 
  4  Enclosure This review should be done for a reasonable sample of mitigating
strategies/equipment.
  Describe inspector actions and the sample strategies reviewed.  Assess
whether procedures were in place and could be used as intended.
The inspectors assessed the licensee's capabilities by reviewing the licensee's walkdown activities.  In addition, the inspectors walked down several procedure sections that were walked down
by the licensee to independently verify the licensee's conclusions.  These walkdowns included verifying actions required by operators to mitigate a loss of spent fuel pool inventory and/or cooling; to mitigate
a large fire; to establish alternate refueling water storage tank makeup; to support steam generator depressurization
; to flood containment for core cooling; and to establish an alternate supply to the turbine driven auxiliary feedwater pump, could be accomplished as specified by
the procedure s. Discuss general results including corrective actions by licensee.
The licensee identified that the procedure for
a loss of spent fuel pool cooling should be enhanced
to include instructions for closing the weir gate, which separates the fuel transfer canal from the spent fuel pool.  The inspectors verified that this condition was entered into the licensee's corrective
action program.
  The inspectors did not identify any issues of concern.
Licensee Action
  Describe the licensee's actions and conclusions regarding training and qualifications of operators and support staff.
c. Verify the training and qualifications of operators and
the support staff needed to implement the procedures and work instructions are current for activities related to Security
Order Section B.5.b and severe accident management guidelines as required by
10 CFR 50.54 (hh). 
  The licensee reviewed the required training and qualifications of staff needed
for activities related to B.5.b and SAMG procedures
to verify that they were current , which included
qualification requirements for the fire brigade, operations personnel, and the emergency response organization.  Additionally, the licensee reviewed the
number of individuals qualified for each of the positions in each department to ensure credited actions could be performed.
Describe inspector actions and the sample strategies reviewed to assess
training and qualifications of operators and support staff
The inspectors assessed the licensee's training and qualification activities by reviewing training and qualification materials, and records related to B.5.b and SAMG event response
training.  Additionally, the inspectors verified that the training was documented and current.  Specifically, the inspectors reviewed a sample of training
lesson plans, attendance verification sheets, and training slides.
 
  5  Enclosure Discuss general results including corrective actions by licensee.
Licensee personnel
identified that continuing training on SAMG and B.5.b strategies for the emergency response organization decision makers had not been done
in 2010.  The inspectors verified that this condition
was entered into the licensee's corrective action program.
  The inspectors did not identify any issues of concern.
Licensee Action
  Describe the licensee's actions and conclusions regarding applicable agreements and contracts that are in place.
d. Verify that any applicable agreements and contracts are in place and are capable of
meeting the conditions needed to mitigate the consequences of these events.
  This review should be done for
a reasonable sample of mitigating strategies/equipment.
    The licensee reviewed their procedures and commitments to determine what agreements or contracts would be needed to support necessary B.5.b and SAMG actions.  The licensee verified that applicable agreements and contracts were in place and current, and
that they were capable of meeting the conditions needed to mitigate the consequences of events related to B.5.b and SAMG actions
. For a sample of mitigating strategies involving contracts or agreements with
offsite entities, describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).
The inspectors reviewed the licensee's B.5.b commitments and that verified the licensee had the appropriate letters of agreement and contracts in place.  The inspectors sampled the letters of agreement and contracts to verify
that they were current and
that they could reasonably meet
the conditions needed to mitigate the consequences of these events.  The sample
included agreements with state and local officials, the local health care provider, and local offsite fire departments.
Discuss general results including corrective actions by licensee.
The inspectors did not identify any issues of concern or any conditions requiring corrective actions. 
 
   
  6  Enclosure Licensee Action
  Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open corrective action documents to assess problems with mitigating strategy implementation identified by the licensee.  Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.
The following Action Requests (AR) were entered
into the licensee's Corrective Action Program in response to issues identified in
Section 03.01:
  AR 2011-3416 - Enhance 12
-OHP-4021-018-001, "Loss Of Spent Fuel Pit Cooling."
AR 2011-4027 - SAMG, EDM, B.5.6 Training Not Given as Required by TPD
-600-EPT, "Emergency Preparedness Training Program Description."
 
The inspectors reviewed each AR and did not identify any
significant
potential to impact the licensee's mitigation strategy.    03.02  Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid.  Refer to TI 2515/120, "Inspection of Implementation of Station Blackout Rule Multi
-Plant Action Item A
-22" as a guideline.  It is not intended that TI 2515/120 be completely reinspected.  The inspection should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action
  Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO event.
a. Verify through walkdowns and inspection that all required
materials are adequate and properly staged, tested, and
maintained.
Licensee actions included identifying
equipment utilized/required to mitigat e a n SBO and conducting
walkdowns to ensure that the equipment was in adequate material condition and properly staged.
  Describe inspector actions to verify equipment is available and useable. 
The inspectors assessed the licensee's capability to mitigate SBO conditions by reviewing the licensee's walkdown activities.  In addition, the inspectors selected a sample of equipment utilized/required
to mitigate an SBO and independent
ly walk ed down that equipment to verify that the equipment was properly aligned and staged.
The sample of equipment selected by the inspectors included tool boxes, ladders, and hoses that were staged in the 765 kilovolt (KV), 345 KV and 69 KV switchyards, the 4 KV switchgear rooms, the emergency diesel generator rooms and the auxiliary building.   
 
  7  Enclosure Discuss general results including corrective actions by licensee.
The licensee identified during material staging walk down
s that hoses for aligning demineralized
water to the spent fuel pool during a loss of inventory need
ed to be designated and staged in closer proximity
to the spent fuel pool.  Additionally, the licensee identified that
specified materials required to
repair or reduce spent fuel pool leakage are currently stored off
site and need to be stored on site.  The inspectors verified these conditions were entered into the licensee's corrective action program.
  The inspectors did not identify any issues of concern.
Licensee Action
  Describe the licensee's actions to verify the capability to mitigate an SBO event.
b. Demonstrate through walkdowns that procedures for response to an SBO are executable.
Licensee actions included identifying
the time critical operator actions associated with
an SBO.  These actions were then walked down
and validated during
the performance of a simulator scenario on April 8, 2011, consisting of a dual unit loss of offsite power and an SBO in Unit 1.
Describe inspector actions to assess
whether procedures were in place and could be used as intended.
The inspectors reviewed the procedure actions associated with the loss of all Alternating Current (AC) power, restoration of 4KV power and supplemental diesel generators, loss of component cooling water, and steam generator level and power
operated relief valve control.  The inspectors also observed the simulator scenario on April 8, 2011, to compare the procedure actions with the time critical actions implemented during the simulator scenario. 
Discuss general results including corrective actions by licensee.
The inspectors concluded that
the time critical operator actions
were executable and reasonable and
did not identify any conditions
requiring corrective actions.     
  8  Enclosure 03.03  Assess the licensee's capability to mitigate internal and external flooding events required by station design.  Refer to
IP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.
  Licensee Action
  Describe the licensee's actions to verify the capability to mitigate existing design basis flooding events
. a. Verify through walkdowns and inspection that all required
materials are adequate and properly staged, tested, and
maintained.
Licensee actions included identifying
equipment, structures
and penetration seals utilized/required to mitigate internal and external flooding.  The licensee then walked down the
equipment to ensure
that it was adequate and properly staged.  Doors, barriers, sumps, berms and penetration seals
that were utilized to mitigate
flooding were identified
and inspected.
  In addition, the licensee reviewed maintenance and surveillance testing history for the Structures, Systems, and Components (SSCs) credited to mitigate internal and external flooding events. Describe inspector actions to verify equipment is available and useable.  Assess whether procedures were in place and could be used as intended.
The inspectors assessed the licensee's capabilities to mitigate flooding by reviewing the licensee's walkdown activities.  In several instances, these reviews involved the inspectors accompanying licensee engineering personnel during in
-field walkdowns.  In addition, the inspectors independently walked down selected flood mitigation equipment to further assess the licensee's flood mitigating capabilities.
  Licensee flood mitigation procedures and flooding analysis were also reviewed to verify usability and accuracy. 
  Discuss general results including corrective actions by licensee.
The licensee identified that the turbine building sump vault hatch did not have a periodic maintenance activity to inspect/repair the hatch.  The inspectors verified
that this condition
was entered into the licensee's corrective action program.
 
The inspectors
concluded that useable procedures and equipment were in place and available to mitigate the most limiting
flooding events, which w as a circulating water pipe expansion joint rupture or turbine building sump check valve failure during a postulated 11 f oo t s eiche coupled with an historical high lake level of 583.6 f eet above sea level. 
  9  Enclosure Licensee Action
  Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.
b. Verify through walkdowns that all required materials are adequate and properly
staged, tested, and maintained.
Licensee actions included identifying
equipment utilized/required
to mitigat e fire and flood events.  Plant walkdowns were performed to assess functionality of
important equipment needed to mitigate
a flood or fire following a design basis earthquake.  Walk downs
included external
visual inspections of associated pumps, diesels, motors, breakers, pipes, valves, tanks, intake structures, hoses, and fittings.
The material condition of surrounding equipment and structures, including the structure that houses the credited equipment, were
also inspected.  Non
-seismic equipment and structures were visually inspected to determine if any surrounding SSCs could be adversely impacted due to seismic interaction
. Describe inspector actions to verify equipment is available and useable.  Assess whether procedures were in place and could be used as intended.
The inspectors accompanied licensee
personnel on selected walkdowns to verify the licensee's actions and assess their adequacy.  Additionally, the inspectors independently walked down fire piping, fire mitigating components, the B.5.b fire truck , B.5.b related equipment, flooding barriers, and areas susceptible to flooding.  The walkdown included the residual heat removal and containment spray pump rooms, emergency diesel generator rooms, fire water storage tank yard
and the screen house intake structure.  The inspector's assessment w as consistent
with the licensee's conclusions that there were a few potential seismic vulnerabilities that need to be evaluated, as described below.
Discuss general results including corrective actions by licensee.  Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews. 
The licensee identified four potential deficiencies
as summarized below:  1) The licensee noted that the alarms in the condenser pits and the auxiliary
building sump that are credited to alert operators to take action to mitigate internally flooding are both non safety
-related and non
-seismic.  Therefore, seismic response procedures will be enhanced to have Auxiliary Equipment Operators check the turbine and auxiliary buildings for internal flooding as soon as possible in order to assist control room operators in taking action to
mitigate/terminate the event.
   
  10  Enclosure 2) The licensee identified that during an external flooding event due to a s
eiche, the west wall of the turbine building is credited for preventing flooding on the turbine building 591
f oot elevation.  However, documentation could not be found to verify that the turbine building west wall that extends beyond the screenhouse was Seismic Class I.  Therefore, structural design engineering
will evaluate if the wall can be analyzed to be seismically qualified, or if it has to be modified.
  3) The license identified that although the plant is designed with diverse sources of fire protection equipment and water sources to supply fire mitigation equipment, this equipment and its associated water sources are not designed and installed to Seismic Class I requirements.  Therefore , the licensee will evaluate the need to develop mitigating strategies to provide additional means of mitigating a fire following a seismic event.  4) The licensee identified that the plant fire truck is currently housed in a structure
on site that is not designed to Seismic Class I requirements.  Therefore, the licensee will evaluate the need to relocate the
fire truck to a Seismic Class I structure or to a location that would not present a seismic hazard to the equipment.
 
The inspectors verified that all of these issues were entered into the licensee's corrective action program.
  The inspectors did not identify any issues of concern.
   
  11  Enclosure 03.04  Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess the licensee's development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function.  Use IP 71111.21, "Component Design Basis Inspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensee's walkdowns and inspections.
Licensee Action
  Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.
  a. Verify through walkdowns that all required
materials are adequate and properly
staged, tested, and maintained.
  Licensee actions included identifying
equipment utilized/required
to mitigat e fire and flood events.  Plant walkdowns were performed to assess functionality of
important equipment needed to mitigate
a flood or fire following a design basis earthquake.  Walk downs
included external
visual inspections of associated pumps, diesels, motors, breakers, pipes, valves, tanks, intake structures, hoses, and fittings.
The material condition of surrounding equipment and structures, including the structure that houses the credited equipment, were
also inspected.  Non
-seismic equipment and structures were visually inspected to determine if any surrounding SSCs could be adversely impacted due to seismic interaction.  Describe inspector actions to verify equipment is available and useable. 
Assess whether procedures were in place and could be used as intended.
  The inspectors accompanied licensee
personnel on selected walkdowns to verify the licensee's actions and assess their adequacy.  Additionally, the inspectors
independently walked down fire piping, fire mitigating components, the B.5.b fire truck, B.5.b related equipment, flooding barriers, and areas susceptible to flooding.  The walkdown included the residual heat removal and containment spray pump
rooms, emergency diesel generator rooms, fire water storage tank yard
and the screen house intake structure.  The inspector's assessment
was consistent with the licensee's conclusions that there were a few potential seismic vulnerabilities that
need to be evaluated, as described below.
   
  12  Enclosure Discuss general results including corrective actions by licensee.  Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews. 
  The licensee identified four potential deficiencies as summarized below:
  1) The licensee noted that the alarms in the condenser pits and the auxiliary building sump that are credited to alert operators to take action to mitigate internally flooding are both non safety
-related and non
-seismic.  Therefore, seismic response procedures will be enhanced to have Auxiliary Equipment Operators check the turbine and auxiliary buildings for internal flooding as soon as possible in order to assist control room operators in taking action to
mitigate/terminate the event.
2) The licensee identified that during an external flooding event due to a seiche, the west wall of the turbine building
is credited for preventing flooding on the turbine building 591 foot elevation.  However, documentation could not be
found to verify that the turbine building west wall that extends beyond the screenhouse was Seismic Class I.  Therefore, structural design
engineering will evaluate if the wall can be analyzed to be seismically qualified, or if it has to be modified.
3) The license identified that although the plant is designed with diverse sources
of fire protection equipment and water sources to supply fire mitigation equipment, this equipment and its associated water sources are not designed
and installed to Seismic Class I requirements.  Therefore , the licensee will evaluate the need to develop mitigating strategies to provide additional means
of mitigating a fire following a seismic event. 4) The licensee identified that the plant fire truck is currently housed in a structure on site that is not designed to Seismic Class I requirements.  Therefore, the licensee will evaluate the need to relocate the
fire truck to a Seismic Class I structure or to a location that would not present a seismic hazard to the equipment.
  The inspectors verified that all of these issues were entered into the licensee's corrective action program.
  The inspectors did not identify any issues of concern.
 
13  Enclosure Meetings  .1 Exit Meeting
  The inspectors presented the inspection results to Mr. J. Gebbie
and other members of licensee management on April 29, 2011.  The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.
   
14  Enclosure SUPPLEMENTAL INFORMATION
  KEY POINTS OF CONTACT
Licensee  J. Gebbie, Site Vice President
Q. Lies, Plant Manager
D. Cobb, Maintenance Manager, WIN Team
G. Curten, Design Engineering, Mechanical
R. Pletz, Fire Protection and Safety Services Supervisor
M. Scarpello, Regulatory Affairs Manager
  Nuclear Regulatory Commission
 
J. Cameron, Chief, Reactor Projects Branch 6/DRP/RIII
   
15  Enclosure LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.  Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that
selected sections of portions of the documents were evaluated as part of the overall inspection effort.  Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
 
03.01  Assess the licensee's capability to mitigate conditions that result from beyond design basis events  Number Description or Title
Date or Revision  Fire Pre-Plans Fire Protection Response to a Large Fire or Explosion Event
Revision 12
  Berrien County Emergency Management Memorandum of Understanding
February 1, 2010  Lake Township Fire and Rescue Memorandum of Understanding
November 17, 2010  Bridgman City Fire Department Memorandum of Understanding
December 6, 2010  Lakeland HealthCare Memorandum of Understanding
November 5, 2010  Medic1 Ambulance Memorandum of Understanding
December 21, 2010  Entergy, Palisades Nuclear Plant Reciprocal Laboratory Use Agreement October 14, 2010  Mutual Assistance Agreement between Detroit Edison, Entergy Nuclear Palisades, LLC, and Indiana Michigan Power
November 5, 2010  Nuclear Power Plant Emergency Response Voluntary Assistance Agreement
January 17.
2007  Voluntary Assistance Agreement by and Among Electric Utilities Involved in Transportation of Nuclear Materials January 17, 2007  Berrien County Sherriff's Department Memorandum of Understanding
November 9, 2010  Michigan State Police Memorandum of Understanding
September 26, 2008  12-OHP-4022-018-001 Loss of Spent Fuel Pit Cooling
Revision 13
12-OHP-4026-EDM-001 Extensive Damage Mitigation Initial Response
November 18, 2008 12-OHP-4026-EDM-002 Extensive Damage Mitigation Enhanced Site Response Strategies
November 18, 2008 12-OHP-4026-EDM-003 Extensive Damage Mitigation Resource Management Guidance November 18, 2008 12-OHP-5030-APR-001 Appendix R Toolbox and Ladder Inventory
Revision 3
AR 2011-3416 Enhance 12
-OHP-4022-018-001 Loss of Spent Fuel Pit Cooling  AR 2011-4027 SAMG, EDM, B.5.b Training Not Given as Req'd by TPD
-600-EPT 
16  Enclosure AR 2011-4983 Appen dix R Toolbox Electrical Tape Not Correct Type By Procedure  Donald C. Cook Nuclear Plant Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami Action Plan Response
April 15, 2011
Lesson Plan
AE-C-00104 Abnormal/ Emergency Tasks
August 12, 2008 Lesson Plan
AE-C-EDMG Auxiliary Equipment Operators Continuing Training
Revision 0
Lesson Plan
AE-J-3322 B.5.b EDMG3
February 28, 2009 Lesson Plan
RQ-C-3245 Validated SEC Threat/Extensive Damage Mitigation
November 8, 2007 Lesson Plan
RQ-C-3614 License Operator Requalification SAMG/SACRG Review
Revision 0
  Lesson Plan
RQ-S-3601-D1 Licensee Operator Requalification Dual Unit Training Scenario
Revision 0
OP-12-5132-29 Flow Diagram CVCS
-Boron Hold up Boric Acid Reserve Tank Units 1 & 2
Revision 29
SAMG SAG-1 Feeding Steam Generators
April 8, 2009
SAMG SAG-2 Depressurize RCS
April 8, 2009
SAMG SAG-4 Inject Into Containment
April 8, 2009
SAMG-1 Severe Accident Management Guidance Manual
April 10, 2007
WO 55367675
-01 Appendix R Toolbox and Ladder Inventory
January 29, 2001  03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions  Number Description or Title
Date or Revision 12-OHP-4021-033-001  Supplemental Diesel Generator Operations
Revision 6
12-OHP-4023-SUP-009  Restoration of 4KV Power from EP
Revision 7
1-OHP-4021-028-014, Attachment 6
  Initiating or Restoring From ESW Cooling To Air Handling Units Following A Failure of Both Chiller Packages
Revision 26
1-OHP-4022-055-003  Loss of Condensate to Auxiliary Feedwater Pumps
Revision 9
1-OHP-4023-ECA-0.0  Loss of All AC Power
Revision 25
1-OHP-4025-R-13  Restore Diesel Generators
Revision 4
2-OHP-4022-016-004  Loss of Component Cooling Water
Revision 19
2-OHP-4023-ECA-0.0  Loss of All AC Power
Revision 24
2-OHP-4025-LS-3  Steam Generator 2/3 Level Control
Revision 4
2-OHP-4025-R-12  Component Restoration
Revision 6
 
17  Enclosure 2-OHP-4025-R-8  Restore Electrical System
Revision 2
  03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design
Number Description or Title
Date or Revision 12-OHP-4022-001-009 Seiche August 12, 2010 1-OHP-4024-124 Annunciator #124 Response: Containment
March 9 2007
MD-12-CW-005-N Flooding Due to Circulating Water Expansion Joint Failure
April 6, 2006
MD-12-SCRN-001-N Screen House Internal Flood Levels
January 15, 2009 SD-061206-001 Flooding Evaluation Report for D.C. Cook Power Plant
Revision 2
WO 55311728
-02 12-DR-129, Inspect for Functionality/ Corrosion / Degradation
July 13, 2010
WO 55325852
-01, MTM Inspect and Lube Watertight Doors per ME.DOOR.001
August 26, 2009  03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events
Number Description or Title
Date or Revision DCC-PV-12-MC17-N Flood Protection Features
October 14, 2001 DCC-PV-12-MC33-N Flood Protection
November 23, 1994 DIT-B-02531-00 Seismic Class I Boundaries
October 23, 2002 N920101 Fire Protection Storage Tanks at Cook Plant
February 11, 1992 OP-125152-14 Flow Diagram Fire Protection
-Water Yard Piping Unit 1 & 2
Revision 14
 
18  Enclosure LIST OF ACRONYMS USED
AC Alternating Current
ADAMS Agencywide Documents Access and Management System
AR Action Request
CFR Code of Federal Regulations
EDMG Extensive Damage Mitigation Guidelines
IP Inspection Procedure
KV Kilovolt NRC United States Nuclear Regulatory Commission
SAMG Severe Accident Management Guidelines
SBO Station Blackout
SSC Structures, Systems, and Components
TI Temporary Instruction
 
  L. Weber    -2-  In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html
(the Public Electronic Reading Room).
      Sincerely,        /RA/        Jamnes L. Cameron, Chief      Branch 6      Division of Reactor Projects
 
Docket Nos. 50
-315; 50-316 License Nos. DPR
-58; DPR-74  Enclosure:
Inspection Report 05000315/2011011; 05000316/2011011
cc w/encl:
Distribution via ListServ
 
   
   
   
DOCUMENT NAME: 
G:\DRPIII\1-Secy\1-Work In Progress
\TI Reports
\Cook 2011 001Rev.docx
  Publicly Available
  Non-Publicly Available
  Sensitive  Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
  OFFICE  RIII    RIII            NAME  J. Rutkowski:dtp  J. Cameron
      DATE  05/10/11  05/11/11    OFFICIAL RECORD COPY
   
  Letter to L. Weber from J. Cameron dated May 13, 2011.
  SUBJECT: D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000315/2011011;
05000316/2011011
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Revision as of 19:27, 10 July 2019

IR 05000315-11-011, on 05000316/2011011, 03/23/2011 - 04/29/2011; D. C. Cook Nuclear Power Plant Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
ML111320302
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 05/13/2011
From: Jamnes Cameron
NRC/RGN-III/DRP/B6
To: Weber L
Nuclear Generation Group, Indiana Michigan Power Co
References
IR-11-011
Download: ML111320302 (23)


See also: IR 05000315/2011011

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532

-4352 May 13, 2011

Mr. Larry Weber

Senior Vice President and

Chief Nuclear Officer

Indiana Michigan Power Company

Nuclear Generation Group

One Cook Place

Bridgman, MI 49106

SUBJECT: D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183

INSPECTION REPORT 05000315/2011011; 05000316/2011011

Dear Mr. Weber: On April 2 9, 2011 , the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your D. C. Cook Nuclear Power Plant, Units 1 and 2 , using Temporary Instruction

(TI) 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event

." The enclosed inspection report documents the inspection results which were discussed on April 29, 2011, with Mr. J. Gebbie, and other members of your staff. The objective of this inspection was to promptly assess the capabilities of the D. C. Cook

Nuclear Power Plant to respond to extraordinary consequences similar to those that have

recently occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results from this inspection performed at other operating commercial

nuclear plants in the United States will be used to evaluate the U.S. nuclear industry's readiness to safely respond to similar events. These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this

report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this

letter.

L. Weber -2- In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html

(the Public Electronic Reading Room).

Sincerely, /RA/ Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects

Docket Nos.

50-315; 50-316 License Nos. DPR

-58; DPR-74 Enclosure:

Inspection Report 05000315/2011011; 05000316/2011011

cc w/encl:

Distribution via ListServ

Enclosure U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

05000315; 05000316

License Nos:

DPR-58; DPR-74 Report No:

05000315/2011011; 05000316/2011011

Licensee: Indiana Michigan Power Company

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

Location: Bridgman, MI

Dates: March 23, 2011, through April 2

9, 2011 Inspectors: J. Lennartz, Senior Resident Inspector

P. LaFlamme, Resident Inspector

Approved by:

Jamnes L. Cameron, Chief

Branch 6 Division of Reactor Projects

1 Enclosure INSPECTION SCOPE

IR 05000315/2011011; 05000316/2011011, 03/23/2011 - 04/2 9/2011; D. C. Cook Nuclear Power Plant Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event. This report covers an announced Temporary Instruction inspection. The inspection was conducted by

resident inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the TI is to provide a broad overview of the industry's preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on (1) assessing the licensee's capability to mitigate consequences from large fires or explosions on site,

(2) assessing the licensee's capability to mitigate station blackout (SBO) conditions, (3) assessing the licensee's capability to mitigate internal and external flooding events accounted for by the station's design, and (4) assessing the thoroughness of the licensee's walk

downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. If necessary, a more specific follow

-up inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.

2 Enclosure 03.01 Assess the licensee's capability to mitigate conditions that result

from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of

inspection.

Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action

Describe what the licensee did to test or inspect equipment.

a. Verify through test or inspection that equipment is available and functional. Active equipment shall be tested and passive equipment shall be walked down and inspected.

It is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested.

This review should be done for a reasonable sample of mitigating strategies/equipment.

Licensee actions included identifying the equipment (active and passive) as directed by the Extensive Damage Mitigation Guidelines

(EDMGs) utilized for implementing B.5.b actions and the Severe Accident Management Guidelines (SAMGs). The scope was defined as that equipment specifically designated for B.5.b or SAMG mitigation (i.e., special hoses, fittings, onsite fire truck, etc.). All equipment, permanent and temporary, that is used to perform

the EDMGs was walked down to verify the equipment was in the correct physical location, and properly labeled.

All procedures were reviewed and, based on the in

-plant walkdowns, credited equipment was verified to be able to meet the EDMGs functional requirements.

Licensee personnel then identified surveillances/tests and performance frequencies for the identified equipment and reviewed the results of recent tests. Also, active equipment within the scope defined above that was not permanently installed

was tested (i.e., plant fire truck was tested to verify the capability to meet specified pressure and flow).

3 Enclosure Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed test results, discussed actions, reviewed records, etc.).

The inspectors assessed the licensee's capabilities by reviewing the licensee's walkdown activities

and previously performed surveillance tests. In addition, the inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site

and verified that required testi

ng had been completed satisfactorily. This included verifying that hoses, fittings, the onsite fire truck, tool boxes, ladders, quick identifiers/ tags and labels were accounted for, properly staged and in adequate material condition as specified by

plant procedure s. Discuss general results including corrective actions by licensee.

Licensee personnel identified that components used for

implementing

the loss of spent fuel pool procedure required enhanced labeling

. The inspectors verified this issue w as entered into the licensee's corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensee's actions to verify that procedures are in place and can be executed (e.g. walkdowns, demonstrations, tests, etc.)

b. Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and

10 CFR 50.54(hh) are in place and are executable. Licensees may choose not to connect or operate permanently installed equipment during this verification.

The licensee performed walkdowns and demonstrations using

their A bnormal Operating Procedures, EDMG, and SAMG procedures credited for B.5.b strategy actions. The licensee's walkdowns included using Auxiliary Equipment Operators to lay out hoses required to

provide water as credited in their B.5.b analysis, and verifying valve lineups using drawings for credited flow paths. The licensee

evaluated their ability to perform the procedures, as well as a review of equipment and plant accessibility needed to perform

proceduralized actions.

4 Enclosure This review should be done for a reasonable sample of mitigating

strategies/equipment.

Describe inspector actions and the sample strategies reviewed. Assess

whether procedures were in place and could be used as intended.

The inspectors assessed the licensee's capabilities by reviewing the licensee's walkdown activities. In addition, the inspectors walked down several procedure sections that were walked down

by the licensee to independently verify the licensee's conclusions. These walkdowns included verifying actions required by operators to mitigate a loss of spent fuel pool inventory and/or cooling; to mitigate

a large fire; to establish alternate refueling water storage tank makeup; to support steam generator depressurization

to flood containment for core cooling; and to establish an alternate supply to the turbine driven auxiliary feedwater pump, could be accomplished as specified by

the procedure s. Discuss general results including corrective actions by licensee.

The licensee identified that the procedure for

a loss of spent fuel pool cooling should be enhanced

to include instructions for closing the weir gate, which separates the fuel transfer canal from the spent fuel pool. The inspectors verified that this condition was entered into the licensee's corrective

action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensee's actions and conclusions regarding training and qualifications of operators and support staff.

c. Verify the training and qualifications of operators and

the support staff needed to implement the procedures and work instructions are current for activities related to Security

Order Section B.5.b and severe accident management guidelines as required by

10 CFR 50.54 (hh).

The licensee reviewed the required training and qualifications of staff needed

for activities related to B.5.b and SAMG procedures

to verify that they were current , which included

qualification requirements for the fire brigade, operations personnel, and the emergency response organization. Additionally, the licensee reviewed the

number of individuals qualified for each of the positions in each department to ensure credited actions could be performed.

Describe inspector actions and the sample strategies reviewed to assess

training and qualifications of operators and support staff

The inspectors assessed the licensee's training and qualification activities by reviewing training and qualification materials, and records related to B.5.b and SAMG event response

training. Additionally, the inspectors verified that the training was documented and current. Specifically, the inspectors reviewed a sample of training

lesson plans, attendance verification sheets, and training slides.

5 Enclosure Discuss general results including corrective actions by licensee.

Licensee personnel

identified that continuing training on SAMG and B.5.b strategies for the emergency response organization decision makers had not been done

in 2010. The inspectors verified that this condition

was entered into the licensee's corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensee's actions and conclusions regarding applicable agreements and contracts that are in place.

d. Verify that any applicable agreements and contracts are in place and are capable of

meeting the conditions needed to mitigate the consequences of these events.

This review should be done for

a reasonable sample of mitigating strategies/equipment.

The licensee reviewed their procedures and commitments to determine what agreements or contracts would be needed to support necessary B.5.b and SAMG actions. The licensee verified that applicable agreements and contracts were in place and current, and

that they were capable of meeting the conditions needed to mitigate the consequences of events related to B.5.b and SAMG actions

. For a sample of mitigating strategies involving contracts or agreements with

offsite entities, describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).

The inspectors reviewed the licensee's B.5.b commitments and that verified the licensee had the appropriate letters of agreement and contracts in place. The inspectors sampled the letters of agreement and contracts to verify

that they were current and

that they could reasonably meet

the conditions needed to mitigate the consequences of these events. The sample

included agreements with state and local officials, the local health care provider, and local offsite fire departments.

Discuss general results including corrective actions by licensee.

The inspectors did not identify any issues of concern or any conditions requiring corrective actions.

6 Enclosure Licensee Action

Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open corrective action documents to assess problems with mitigating strategy implementation identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.

The following Action Requests (AR) were entered

into the licensee's Corrective Action Program in response to issues identified in

Section 03.01:

AR 2011-3416 - Enhance 12

-OHP-4021-018-001, "Loss Of Spent Fuel Pit Cooling."

AR 2011-4027 - SAMG, EDM, B.5.6 Training Not Given as Required by TPD

-600-EPT, "Emergency Preparedness Training Program Description."

The inspectors reviewed each AR and did not identify any

significant

potential to impact the licensee's mitigation strategy. 03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to TI 2515/120, "Inspection of Implementation of Station Blackout Rule Multi

-Plant Action Item A

-22" as a guideline. It is not intended that TI 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action

Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO event.

a. Verify through walkdowns and inspection that all required

materials are adequate and properly staged, tested, and

maintained.

Licensee actions included identifying

equipment utilized/required to mitigat e a n SBO and conducting

walkdowns to ensure that the equipment was in adequate material condition and properly staged.

Describe inspector actions to verify equipment is available and useable.

The inspectors assessed the licensee's capability to mitigate SBO conditions by reviewing the licensee's walkdown activities. In addition, the inspectors selected a sample of equipment utilized/required

to mitigate an SBO and independent

ly walk ed down that equipment to verify that the equipment was properly aligned and staged.

The sample of equipment selected by the inspectors included tool boxes, ladders, and hoses that were staged in the 765 kilovolt (KV), 345 KV and 69 KV switchyards, the 4 KV switchgear rooms, the emergency diesel generator rooms and the auxiliary building.

7 Enclosure Discuss general results including corrective actions by licensee.

The licensee identified during material staging walk down

s that hoses for aligning demineralized

water to the spent fuel pool during a loss of inventory need

ed to be designated and staged in closer proximity

to the spent fuel pool. Additionally, the licensee identified that

specified materials required to

repair or reduce spent fuel pool leakage are currently stored off

site and need to be stored on site. The inspectors verified these conditions were entered into the licensee's corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensee's actions to verify the capability to mitigate an SBO event.

b. Demonstrate through walkdowns that procedures for response to an SBO are executable.

Licensee actions included identifying

the time critical operator actions associated with

an SBO. These actions were then walked down

and validated during

the performance of a simulator scenario on April 8, 2011, consisting of a dual unit loss of offsite power and an SBO in Unit 1.

Describe inspector actions to assess

whether procedures were in place and could be used as intended.

The inspectors reviewed the procedure actions associated with the loss of all Alternating Current (AC) power, restoration of 4KV power and supplemental diesel generators, loss of component cooling water, and steam generator level and power

operated relief valve control. The inspectors also observed the simulator scenario on April 8, 2011, to compare the procedure actions with the time critical actions implemented during the simulator scenario.

Discuss general results including corrective actions by licensee.

The inspectors concluded that

the time critical operator actions

were executable and reasonable and

did not identify any conditions

requiring corrective actions.

8 Enclosure 03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to

IP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action

Describe the licensee's actions to verify the capability to mitigate existing design basis flooding events

. a. Verify through walkdowns and inspection that all required

materials are adequate and properly staged, tested, and

maintained.

Licensee actions included identifying

equipment, structures

and penetration seals utilized/required to mitigate internal and external flooding. The licensee then walked down the

equipment to ensure

that it was adequate and properly staged. Doors, barriers, sumps, berms and penetration seals

that were utilized to mitigate

flooding were identified

and inspected.

In addition, the licensee reviewed maintenance and surveillance testing history for the Structures, Systems, and Components (SSCs) credited to mitigate internal and external flooding events. Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors assessed the licensee's capabilities to mitigate flooding by reviewing the licensee's walkdown activities. In several instances, these reviews involved the inspectors accompanying licensee engineering personnel during in

-field walkdowns. In addition, the inspectors independently walked down selected flood mitigation equipment to further assess the licensee's flood mitigating capabilities.

Licensee flood mitigation procedures and flooding analysis were also reviewed to verify usability and accuracy.

Discuss general results including corrective actions by licensee.

The licensee identified that the turbine building sump vault hatch did not have a periodic maintenance activity to inspect/repair the hatch. The inspectors verified

that this condition

was entered into the licensee's corrective action program.

The inspectors

concluded that useable procedures and equipment were in place and available to mitigate the most limiting

flooding events, which w as a circulating water pipe expansion joint rupture or turbine building sump check valve failure during a postulated 11 f oo t s eiche coupled with an historical high lake level of 583.6 f eet above sea level.

9 Enclosure Licensee Action

Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.

b. Verify through walkdowns that all required materials are adequate and properly

staged, tested, and maintained.

Licensee actions included identifying

equipment utilized/required

to mitigat e fire and flood events. Plant walkdowns were performed to assess functionality of

important equipment needed to mitigate

a flood or fire following a design basis earthquake. Walk downs

included external

visual inspections of associated pumps, diesels, motors, breakers, pipes, valves, tanks, intake structures, hoses, and fittings.

The material condition of surrounding equipment and structures, including the structure that houses the credited equipment, were

also inspected. Non

-seismic equipment and structures were visually inspected to determine if any surrounding SSCs could be adversely impacted due to seismic interaction

. Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors accompanied licensee

personnel on selected walkdowns to verify the licensee's actions and assess their adequacy. Additionally, the inspectors independently walked down fire piping, fire mitigating components, the B.5.b fire truck , B.5.b related equipment, flooding barriers, and areas susceptible to flooding. The walkdown included the residual heat removal and containment spray pump rooms, emergency diesel generator rooms, fire water storage tank yard

and the screen house intake structure. The inspector's assessment w as consistent

with the licensee's conclusions that there were a few potential seismic vulnerabilities that need to be evaluated, as described below.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee identified four potential deficiencies

as summarized below: 1) The licensee noted that the alarms in the condenser pits and the auxiliary

building sump that are credited to alert operators to take action to mitigate internally flooding are both non safety

-related and non

-seismic. Therefore, seismic response procedures will be enhanced to have Auxiliary Equipment Operators check the turbine and auxiliary buildings for internal flooding as soon as possible in order to assist control room operators in taking action to

mitigate/terminate the event.

10 Enclosure 2) The licensee identified that during an external flooding event due to a s

eiche, the west wall of the turbine building is credited for preventing flooding on the turbine building 591

f oot elevation. However, documentation could not be found to verify that the turbine building west wall that extends beyond the screenhouse was Seismic Class I. Therefore, structural design engineering

will evaluate if the wall can be analyzed to be seismically qualified, or if it has to be modified.

3) The license identified that although the plant is designed with diverse sources of fire protection equipment and water sources to supply fire mitigation equipment, this equipment and its associated water sources are not designed and installed to Seismic Class I requirements. Therefore , the licensee will evaluate the need to develop mitigating strategies to provide additional means of mitigating a fire following a seismic event. 4) The licensee identified that the plant fire truck is currently housed in a structure

on site that is not designed to Seismic Class I requirements. Therefore, the licensee will evaluate the need to relocate the

fire truck to a Seismic Class I structure or to a location that would not present a seismic hazard to the equipment.

The inspectors verified that all of these issues were entered into the licensee's corrective action program.

The inspectors did not identify any issues of concern.

11 Enclosure 03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess the licensee's development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, "Component Design Basis Inspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensee's walkdowns and inspections.

Licensee Action

Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through walkdowns that all required

materials are adequate and properly

staged, tested, and maintained.

Licensee actions included identifying

equipment utilized/required

to mitigat e fire and flood events. Plant walkdowns were performed to assess functionality of

important equipment needed to mitigate

a flood or fire following a design basis earthquake. Walk downs

included external

visual inspections of associated pumps, diesels, motors, breakers, pipes, valves, tanks, intake structures, hoses, and fittings.

The material condition of surrounding equipment and structures, including the structure that houses the credited equipment, were

also inspected. Non

-seismic equipment and structures were visually inspected to determine if any surrounding SSCs could be adversely impacted due to seismic interaction. Describe inspector actions to verify equipment is available and useable.

Assess whether procedures were in place and could be used as intended.

The inspectors accompanied licensee

personnel on selected walkdowns to verify the licensee's actions and assess their adequacy. Additionally, the inspectors

independently walked down fire piping, fire mitigating components, the B.5.b fire truck, B.5.b related equipment, flooding barriers, and areas susceptible to flooding. The walkdown included the residual heat removal and containment spray pump

rooms, emergency diesel generator rooms, fire water storage tank yard

and the screen house intake structure. The inspector's assessment

was consistent with the licensee's conclusions that there were a few potential seismic vulnerabilities that

need to be evaluated, as described below.

12 Enclosure Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee identified four potential deficiencies as summarized below:

1) The licensee noted that the alarms in the condenser pits and the auxiliary building sump that are credited to alert operators to take action to mitigate internally flooding are both non safety

-related and non

-seismic. Therefore, seismic response procedures will be enhanced to have Auxiliary Equipment Operators check the turbine and auxiliary buildings for internal flooding as soon as possible in order to assist control room operators in taking action to

mitigate/terminate the event.

2) The licensee identified that during an external flooding event due to a seiche, the west wall of the turbine building

is credited for preventing flooding on the turbine building 591 foot elevation. However, documentation could not be

found to verify that the turbine building west wall that extends beyond the screenhouse was Seismic Class I. Therefore, structural design

engineering will evaluate if the wall can be analyzed to be seismically qualified, or if it has to be modified.

3) The license identified that although the plant is designed with diverse sources

of fire protection equipment and water sources to supply fire mitigation equipment, this equipment and its associated water sources are not designed

and installed to Seismic Class I requirements. Therefore , the licensee will evaluate the need to develop mitigating strategies to provide additional means

of mitigating a fire following a seismic event. 4) The licensee identified that the plant fire truck is currently housed in a structure on site that is not designed to Seismic Class I requirements. Therefore, the licensee will evaluate the need to relocate the

fire truck to a Seismic Class I structure or to a location that would not present a seismic hazard to the equipment.

The inspectors verified that all of these issues were entered into the licensee's corrective action program.

The inspectors did not identify any issues of concern.

13 Enclosure Meetings .1 Exit Meeting

The inspectors presented the inspection results to Mr. J. Gebbie

and other members of licensee management on April 29, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

14 Enclosure SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee J. Gebbie, Site Vice President

Q. Lies, Plant Manager

D. Cobb, Maintenance Manager, WIN Team

G. Curten, Design Engineering, Mechanical

R. Pletz, Fire Protection and Safety Services Supervisor

M. Scarpello, Regulatory Affairs Manager

Nuclear Regulatory Commission

J. Cameron, Chief, Reactor Projects Branch 6/DRP/RIII

15 Enclosure LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that

selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events Number Description or Title

Date or Revision Fire Pre-Plans Fire Protection Response to a Large Fire or Explosion Event

Revision 12

Berrien County Emergency Management Memorandum of Understanding

February 1, 2010 Lake Township Fire and Rescue Memorandum of Understanding

November 17, 2010 Bridgman City Fire Department Memorandum of Understanding

December 6, 2010 Lakeland HealthCare Memorandum of Understanding

November 5, 2010 Medic1 Ambulance Memorandum of Understanding

December 21, 2010 Entergy, Palisades Nuclear Plant Reciprocal Laboratory Use Agreement October 14, 2010 Mutual Assistance Agreement between Detroit Edison, Entergy Nuclear Palisades, LLC, and Indiana Michigan Power

November 5, 2010 Nuclear Power Plant Emergency Response Voluntary Assistance Agreement

January 17.

2007 Voluntary Assistance Agreement by and Among Electric Utilities Involved in Transportation of Nuclear Materials January 17, 2007 Berrien County Sherriff's Department Memorandum of Understanding

November 9, 2010 Michigan State Police Memorandum of Understanding

September 26, 2008 12-OHP-4022-018-001 Loss of Spent Fuel Pit Cooling

Revision 13

12-OHP-4026-EDM-001 Extensive Damage Mitigation Initial Response

November 18, 2008 12-OHP-4026-EDM-002 Extensive Damage Mitigation Enhanced Site Response Strategies

November 18, 2008 12-OHP-4026-EDM-003 Extensive Damage Mitigation Resource Management Guidance November 18, 2008 12-OHP-5030-APR-001 Appendix R Toolbox and Ladder Inventory

Revision 3

AR 2011-3416 Enhance 12

-OHP-4022-018-001 Loss of Spent Fuel Pit Cooling AR 2011-4027 SAMG, EDM, B.5.b Training Not Given as Req'd by TPD

-600-EPT

16 Enclosure AR 2011-4983 Appen dix R Toolbox Electrical Tape Not Correct Type By Procedure Donald C. Cook Nuclear Plant Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami Action Plan Response

April 15, 2011

Lesson Plan

AE-C-00104 Abnormal/ Emergency Tasks

August 12, 2008 Lesson Plan

AE-C-EDMG Auxiliary Equipment Operators Continuing Training

Revision 0

Lesson Plan

AE-J-3322 B.5.b EDMG3

February 28, 2009 Lesson Plan

RQ-C-3245 Validated SEC Threat/Extensive Damage Mitigation

November 8, 2007 Lesson Plan

RQ-C-3614 License Operator Requalification SAMG/SACRG Review

Revision 0

Lesson Plan

RQ-S-3601-D1 Licensee Operator Requalification Dual Unit Training Scenario

Revision 0

OP-12-5132-29 Flow Diagram CVCS

-Boron Hold up Boric Acid Reserve Tank Units 1 & 2

Revision 29

SAMG SAG-1 Feeding Steam Generators

April 8, 2009

SAMG SAG-2 Depressurize RCS

April 8, 2009

SAMG SAG-4 Inject Into Containment

April 8, 2009

SAMG-1 Severe Accident Management Guidance Manual

April 10, 2007

WO 55367675

-01 Appendix R Toolbox and Ladder Inventory

January 29, 2001 03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions Number Description or Title

Date or Revision 12-OHP-4021-033-001 Supplemental Diesel Generator Operations

Revision 6

12-OHP-4023-SUP-009 Restoration of 4KV Power from EP

Revision 7

1-OHP-4021-028-014, Attachment 6

Initiating or Restoring From ESW Cooling To Air Handling Units Following A Failure of Both Chiller Packages

Revision 26

1-OHP-4022-055-003 Loss of Condensate to Auxiliary Feedwater Pumps

Revision 9

1-OHP-4023-ECA-0.0 Loss of All AC Power

Revision 25

1-OHP-4025-R-13 Restore Diesel Generators

Revision 4

2-OHP-4022-016-004 Loss of Component Cooling Water

Revision 19

2-OHP-4023-ECA-0.0 Loss of All AC Power

Revision 24

2-OHP-4025-LS-3 Steam Generator 2/3 Level Control

Revision 4

2-OHP-4025-R-12 Component Restoration

Revision 6

17 Enclosure 2-OHP-4025-R-8 Restore Electrical System

Revision 2

03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design

Number Description or Title

Date or Revision 12-OHP-4022-001-009 Seiche August 12, 2010 1-OHP-4024-124 Annunciator #124 Response: Containment

March 9 2007

MD-12-CW-005-N Flooding Due to Circulating Water Expansion Joint Failure

April 6, 2006

MD-12-SCRN-001-N Screen House Internal Flood Levels

January 15, 2009 SD-061206-001 Flooding Evaluation Report for D.C. Cook Power Plant

Revision 2

WO 55311728

-02 12-DR-129, Inspect for Functionality/ Corrosion / Degradation

July 13, 2010

WO 55325852

-01, MTM Inspect and Lube Watertight Doors per ME.DOOR.001

August 26, 2009 03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events

Number Description or Title

Date or Revision DCC-PV-12-MC17-N Flood Protection Features

October 14, 2001 DCC-PV-12-MC33-N Flood Protection

November 23, 1994 DIT-B-02531-00 Seismic Class I Boundaries

October 23, 2002 N920101 Fire Protection Storage Tanks at Cook Plant

February 11, 1992 OP-125152-14 Flow Diagram Fire Protection

-Water Yard Piping Unit 1 & 2

Revision 14

18 Enclosure LIST OF ACRONYMS USED

AC Alternating Current

ADAMS Agencywide Documents Access and Management System

AR Action Request

CFR Code of Federal Regulations

EDMG Extensive Damage Mitigation Guidelines

IP Inspection Procedure

KV Kilovolt NRC United States Nuclear Regulatory Commission

SAMG Severe Accident Management Guidelines

SBO Station Blackout

SSC Structures, Systems, and Components

TI Temporary Instruction

L. Weber -2- In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html

(the Public Electronic Reading Room).

Sincerely, /RA/ Jamnes L. Cameron, Chief Branch 6 Division of Reactor Projects

Docket Nos. 50

-315; 50-316 License Nos. DPR

-58; DPR-74 Enclosure:

Inspection Report 05000315/2011011; 05000316/2011011

cc w/encl:

Distribution via ListServ

DOCUMENT NAME:

G:\DRPIII\1-Secy\1-Work In Progress

\TI Reports

\Cook 2011 001Rev.docx

Publicly Available

Non-Publicly Available

Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII NAME J. Rutkowski:dtp J. Cameron

DATE 05/10/11 05/11/11 OFFICIAL RECORD COPY

Letter to L. Weber from J. Cameron dated May 13, 2011.

SUBJECT: D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000315/2011011;

05000316/2011011

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