ML111320302: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
 
(StriderTol Bot change)
 
(2 intermediate revisions by the same user not shown)
Line 1: Line 1:
#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 29, 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 industrys 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 NRCs 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 NRCs 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
NRCs 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 29, 2011
Inspectors:
J. Lennartz, Senior Resident Inspector
P. LaFlamme, Resident Inspector
Approved by:
Jamnes L. Cameron, Chief
Branch 6
Division of Reactor Projects
 
Enclosure
INSPECTION SCOPE
IR 05000315/2011011; 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. 
This report covers an announced Temporary Instruction inspection.  The inspection was
conducted by resident inspectors.  The NRCs 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 industrys preparedness for events
that may exceed the current design basis for a plant.  The focus of the TI was on (1) assessing
the licensees capability to mitigate consequences from large fires or explosions on site,
(2) assessing the licensees capability to mitigate station blackout (SBO) conditions,
(3) assessing the licensees capability to mitigate internal and external flooding events
accounted for by the stations design, and (4) assessing the thoroughness of the licensees walk
downs and inspections of important equipment needed to mitigate fire and flood events to
identify the potential that the equipments 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 NRCs 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 licensees 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 licensees capabilities by reviewing the licensees
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 testing 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 procedures.
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 was entered into the licensees corrective action program.
The inspectors did not identify any issues of concern.
Licensee Action
Describe the licensees 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 Abnormal
Operating Procedures, EDMG, and SAMG procedures credited for B.5.b strategy
actions.  The licensees 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 licensees capabilities by reviewing the licensees
walkdown activities.  In addition, the inspectors walked down several procedure
sections that were walked down by the licensee to independently verify the licensees
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 procedures.
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 licensees corrective action program.
The inspectors did not identify any issues of concern.
Licensee Action
Describe the licensees 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 licensees 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 licensees
corrective action program.
The inspectors did not identify any issues of concern.
Licensee Action
Describe the licensees 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 licensees 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 licensees 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 licensees mitigation strategy. 
03.02  Assess the licensees 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 licensees 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 mitigate an 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 licensees capability to mitigate SBO conditions by
reviewing the licensees walkdown activities.  In addition, the inspectors selected a
sample of equipment utilized/required to mitigate an SBO and independently walked
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 downs that hoses for aligning
demineralized water to the spent fuel pool during a loss of inventory needed 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 licensees corrective action program.
The inspectors did not identify any issues of concern.
Licensee Action
Describe the licensees 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 licensees 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 licensees 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 licensees capabilities to mitigate flooding by
reviewing the licensees 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 licensees 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 licensees corrective action program.
The inspectors concluded that useable procedures and equipment were in place
and available to mitigate the most limiting flooding events, which was a circulating
water pipe expansion joint rupture or turbine building sump check valve failure
during a postulated 11 foot seiche coupled with an historical high lake level of
583.6 feet above sea level.
 
9
Enclosure
Licensee Action
Describe the licensees 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 mitigate 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
licensees 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 inspectors assessment was consistent with the licensees
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 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 licensees
corrective action program.
The inspectors did not identify any issues of concern.
 
11
Enclosure
03.04  Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire
and flood events to identify the potential that the equipments function could be lost during seismic events possible for the
site. Assess the licensees 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 licensees walkdowns and inspections.
Licensee Action
Describe the licensees 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 mitigate 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
licensees 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
licensees 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 licensees
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 licensees 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 Sherriffs 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 Reqd by TPD-600-
EPT
 
16 
Enclosure
AR 2011-4983
Appendix 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 licensees 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 licensees 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 licensees walkdowns and inspections of important
equipment needed to mitigate fire and flood events to identify the potential that the
equipments 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 NRCs 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
NRCs 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
DISTRIBUTION:
Daniel Merzke
RidsNrrDorlLpl3-1 Resource
RidsNrrPMDCCook Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
Steven Orth
Jared Heck
Allan Barker
Carole Ariano
Linda Linn
DRPIII
DRSIII
Patricia Buckley
Tammy Tomczak
ROPreports Resource
}}

Latest revision as of 06:21, 13 January 2025

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 29, 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 industrys 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 NRCs 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 NRCs 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

NRCs 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 29, 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 - 04/29/2011; 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 NRCs 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 industrys preparedness for events

that may exceed the current design basis for a plant. The focus of the TI was on (1) assessing

the licensees capability to mitigate consequences from large fires or explosions on site,

(2) assessing the licensees capability to mitigate station blackout (SBO) conditions,

(3) assessing the licensees capability to mitigate internal and external flooding events

accounted for by the stations design, and (4) assessing the thoroughness of the licensees walk

downs and inspections of important equipment needed to mitigate fire and flood events to

identify the potential that the equipments 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 NRCs 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 licensees 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 licensees capabilities by reviewing the licensees

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 testing 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 procedures.

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 was entered into the licensees corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensees 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 Abnormal

Operating Procedures, EDMG, and SAMG procedures credited for B.5.b strategy

actions. The licensees 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 licensees capabilities by reviewing the licensees

walkdown activities. In addition, the inspectors walked down several procedure

sections that were walked down by the licensee to independently verify the licensees

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 procedures.

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 licensees corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensees 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 licensees 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 licensees

corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensees 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 licensees 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 licensees 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 licensees mitigation strategy.

03.02 Assess the licensees 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 licensees 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 mitigate an 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 licensees capability to mitigate SBO conditions by

reviewing the licensees walkdown activities. In addition, the inspectors selected a

sample of equipment utilized/required to mitigate an SBO and independently walked

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 downs that hoses for aligning

demineralized water to the spent fuel pool during a loss of inventory needed 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 licensees corrective action program.

The inspectors did not identify any issues of concern.

Licensee Action

Describe the licensees 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 licensees 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 licensees 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 licensees capabilities to mitigate flooding by

reviewing the licensees 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 licensees 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 licensees corrective action program.

The inspectors concluded that useable procedures and equipment were in place

and available to mitigate the most limiting flooding events, which was a circulating

water pipe expansion joint rupture or turbine building sump check valve failure

during a postulated 11 foot seiche coupled with an historical high lake level of

583.6 feet above sea level.

9

Enclosure

Licensee Action

Describe the licensees 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 mitigate 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

licensees 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 inspectors assessment was consistent with the licensees

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 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 licensees

corrective action program.

The inspectors did not identify any issues of concern.

11

Enclosure

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire

and flood events to identify the potential that the equipments function could be lost during seismic events possible for the

site. Assess the licensees 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 licensees walkdowns and inspections.

Licensee Action

Describe the licensees 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 mitigate 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

licensees 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

licensees 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 licensees

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 licensees 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 Sherriffs 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 Reqd by TPD-600-

EPT

16

Enclosure

AR 2011-4983

Appendix 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 licensees 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 licensees 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 licensees walkdowns and inspections of important

equipment needed to mitigate fire and flood events to identify the potential that the

equipments 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 NRCs 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

NRCs 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

DISTRIBUTION:

Daniel Merzke

RidsNrrDorlLpl3-1 Resource

RidsNrrPMDCCook Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Steven Orth

Jared Heck

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports Resource