ML17334B464

Forwards Correspondence from Constituent,J Johnson, Expressing Concerns Re Cooling Tubes

ML17334B464
Person / Time
Site:	Cook
Issue date:	01/11/1993
From:	HOEKSTRA P HOUSE OF REP.
To:	RATHBUN D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
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ML17334B463	List: ML17334B462 ML17334B464
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NUDOCS 9303030175
Download: ML17334B464 (41)

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.PETER.HOEK6TRA 2o Duroc', MlcNIGAN'Kntttteestt nf tfje Sttfteb States@ouse nf 3Reyt.edentatf'bed tsnasfjington,@jr.20516-2202 January ll, 1993 Mr.Dennis Rathbun, Director Office of Congressional Affairs Nuclear Regulatory Commission Washington, DC 20555

Dear Mr.Rathbun:

Enclosed is correspondence I have received from one my constituents relative to her concerns about the deterioration on cooling tubes at several nuclear power plants (including D C Cook in Benton Harbor, Michigan).

Her information came from an Associated Press article on that subject.I am writing to request information pertaining to the safety of the nuclear power plant in Benton Harbor.Please provide a written response to the concerns raised by Mrs.Johnson.Is the press article accurate?Why are the NRC standards being ignored or waived in these cases?What is the potential risk to Michigan residents?

Thank you in advance for your cooperation in this effort to alleviate my constituent's concerns.I.lo rward to your prompt reply.S ncere y'yo rs, PETE HOEKSTRA Member of Congress PH: jk Muskegon Area Office 900 Third Street, Suite 203 Muskegon, MI 49440 616-722-8386

.'930303017.5 930223-I'PDR'DOCK 050Q03i'5',I DR

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r~~~v 4 4 Distribution Sheet Distri41.txt

@i~/~Priority: Normal From: Stefanie Fountain Action Recipients:

RidsNrrPM JStang RidsNrrDlpmLpdiii1

-Copies: 0 0 OK OK Internal Recipients:

TTC C-TNN RidsRgn3MailCenter RidsOgcMle RidsOeMailCenter RidsNrrDripRexb RidsNrrDipmOlhp RidsNrrDipmlipb Rids Manager RidsEdoMailCenter RidsAcrsAcnwMailCenter 0 1 FILE CENTER 01 ACRS External Recipients:

NOAC INEEL Marshall 0 0 0 0 0 Paper Copy 0 OK OK OK , OK OK OK OK OK 0 OK Paper Copy Paper Copy Paper Copy Paper Copy Paper Copy=Total Copies: Item: ADAMS Document Library: ML ADAMS" HQNTAD01 ID: 003699106:1

Subject:

OVERSIGHT PROCESS FOR D.C.COOK NUCLEAR PLANT Body: ADAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View Page 1 I j o A Distri41.txt

• the Document in ADAMS.The Document may also be viewed by searching for Accession Number ML003699106.

lE01-General (50 Dkt)-Insp Rept/Notice of Violation Response (for use by HQ)Docket: 05000315 Docket: 05000316 Page 2

UNION OF ,CONCERNED SCIENYlSTS February 16, 2000 Mr.John A.Grobe Director-Division of Reactor Safety United States Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 SUB JECT: OVERSIGHT PROCESS I'OR D C COOING Dear Mr.Grobe The transition to the revised reactor oversight process at the D C Cook nuclear plant was discussed on February 15, 2000, at a meeting at NRC headquarters in Rockville, Maryland.The licensee proposed to remain under the NRC Manual Chapter 0350 process for the first full year after restart of Unit 2 and then switch to full scale implementation of the revised reactor oversight process.The NRC staff counter-proposed a phased-in transition to the revised reactor oversight process with the significance determination process being used for all NRC inspection findings, some of the performance indicators being used immediately and the remainder of the performance indicators adopted as their trailing data became available.

3 i There are advantages and disadvantages to both approaches.

The licensee identified accuracy and resource burden problems associated with the historical data needed for many of the performance indicators.

The NRC staff identified a problem with not having oversight data for the public following restart of the most troubled plant in the US in the past two years.'he concerns of both the licensee and the NRC staff appear sincere and valid.It would be difficult to select either approach because that would cause the concerns of the unselected party to remain unresolved.

Fortunately, there seems to be a compromise available During the past two years, the licensee's Restart Action Plan and the NRC staff's Manual Chapter 0350 process provided assurance that D C Cook Unit 2 can be restarted with adequate safety margins.It, would be reasonable to assume, therefore, that all these assessments, evaluations, tests, reviews, and inspections resulted in performance in each performance indicator category being restored to the GREEN band.If not, the licensee's System Readiness Reviews or the NRC's inspections to close the confirmatory action letter would have flagged non-GREEN performance.

In other words, if either the licensee or the NRC staff had any doubts that performance in any performance indicator category was not GREEN, the plant would not be ready for restart.Accepting this assumption'allows every performance indicator in the revised reactor oversight process to be artificially set to GREEN when D C Cook Unit 2 enters Mode 2.For example, the scram performance indicator could assume that there have been zero scrams in the past 7,000 critical hours and the alert and Washington Office: 1616 P Street NW Suite 310 o Washington DC 20036-1495

~202-3324900

~FAX: 202-3324905 Cambridge Headquarters:

Two Brattle Square o.Cambridge MA 02238-9105

~617-547-5552

~FAX: 617-864-9405 California Office: 2397 Shattuck Avenue Suite 203~Berkeley CA 94704-1567

~510-843-1872

~FAX: 510-843-3785 tEB 22 2000>D~dF9/og

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February 16, 2000 Page2of2 notification system performance indicator could assume that 100%of the sirens have been tested successfully.

By setting all of the performance indicators to GREEN, the licensee would not have to waste the resources required to collect and validate the historical data.The licensee would have to establish the data collection and reporting infrastructure necessary to report the performance indicators quarterly beginning at the end of the quarter in which D C Cook Unit 2 enters Mode 2.This process would enable the NRC staff to demonstrate to the public that it was achieving the goal of maintaining safety.Beginning with the quarter in which the plant restarted, the performance indicators would accurately inform the licensee, the NRC staff, and the public how the plant's performance trended relative to an initial"clean slate." At the same time, the NRC staff could focus resources on verifying that D C Cook Unit 1 is ready for restart.This compromise approach has its faults.The largest fault is that the starting point for the performance indicators is selected arbitrarily and may be non-conservatively higher than actual performance.

But actual performance cannot be precisely determined for some of the performance indicators until one or more quarters aAer restart.The arbitrary starting point only compromises safety when the actual performance level would be low in the WHITE band, in the YELLOW band, or in the RED band.The extensive efforts by the licensee and the NRC staff over the past two years prov'ide reason to believe that the actual performance in all of the performance indicator categories is GREEN or at worst in the high end of the WHITE band.The artificial starting points track to actual performance levels at different rates for the performance indicators.

Some PIs will revert to actual performance within a quarter or two while some can take up to three years.The key point is that all of the performance indicators will accurately trend relative performance beginning with the very first quarter.D C Cook Unit 2 will not enter Mode 2 unless both the licensee and the NRC staff believe that safety margins in all of the performance indicator categories have been adequately restored.The PIs would therefore reveal where, if any, erosions from that condition have occurred following restart.It seems better to use the revised reactor oversight process in its entirety immediately upon restart of D C Cook Unit 2 than to postpone its use for a full year as proposed by the licensee or to only use some of the process as proposed by the NRC staff.The nuclear industry and the NRC staff have touted the revised reactor oversight process as THE monitoring program for the new millenium.

The NRC should use its best tool at the worst plant.Artificially setting all of the performance indicators to GREEN would be somewhat unfair to other licensees who have earned all GREENs through operational performance.

But I doubt that any licensee would trade places with D C Cook's licensee just to earn a"free ticket" to GREEN performance indicators.

Sincerely, David A.L chbaum Nuclear Safety Engineer E

Distribution Sheet Distri66.txt

~-sa//gag~~Priority: Normal From: Stefanie Fountain Action Recipients:

Internal Recipients:

FILE CENTER 01 Copies: Paper Copy External Recipients:

Total Copies: Item: ADAMS Document Library: ML ADAMS" HQNTAD01 ID: 003695620:1

Subject:

TASK ORDER NO.074,"D.C.COOK ENGINEERING FOLLOW-UP TEAM INSPECTION" UNDER CONTRACT NO.NRC-03-98-021.

Body: ADAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS.The Document may also be viewed by searching for Accession Number ML003695620.

DF02-Direct Flow Distribution:

PDR Direct Documents Docket: 05000315 Docket: 05000316 Page 1 k I', j P~8 RE0p+0 I 9~O++**+UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.20555-0001 January 28, 2000 Beckman and Associates, Inc.Attn: Vicki Beckman 1071 State Route 136 Belle Vernon, PA 15012

SUBJECT:

TASK ORDER NO.074,"D.C.COOK ENGINEERING FOLLOW-UP TEAM INSPECTION" UNDER CONTRACT NO.NRC-03-98-021

Dear Ms.Beckman:

In accordance with Section G.5, Task Order Procedures, of the subject contract, this letter definitizes the subject task order.The effort shall be performed in accordance with the enclosed Statement of Work.Task Order No.074 shall be in effect from January 28, 2000, through March 10, 2000, with a total cost ceiling of$127,385.67.

The amount of$123,375.95 represents the estimated reimbursable costs and the amount of$4,009.72 represents the fixed fee.Accounting data for Task Order No.074 is as follows: B8R No.: Job Code: BOC: APPN No.: FFS¹: Oblig.Amt.: 020-15-103-105 J-2548 252A 31X0200.020 NRR98021074

$127,385.67 The following individuals are considered to be essential to the successful performance of work hereunder:

Mr.John Chiloyan, Mr.Raymond Cooney, Mr.Richard Ely, and Mr.Charles Jones.The Contractor agrees that such personnel shall not be removed from the effort under the task id~.The issuance of this task order does not amend any terms or conditions of the subject contract.

E 0 I I 4))t Your contacts du'ririg the course'of this task order are: Technical Matters: Edmund Kleeh Project Officer (301)415-2964 I Contractual Matters: Mona Selden Contract Specialist (301)415-7907 Acceptance of Task Order No: 074 should be made by having an official,:authorized to bind your organization, execute'three copies of this document in the space provided and return two copies to the Contract Specialist.

You should retain the third copy for your records.Sine rey, S ron D.Stewart, Contracting Officer Contract Management Branch 2 Division of Contracts and Property Management Office of Administration

Enclosure:

Statement of Work ACCEPTE: Task Order o.074 TITLE DATE

'Task Order,074"..

TITLE: D.C.Cook Engineering Follow-up Team'Inspection h DOCKET NUMBER: 50-315/316,'8 R,"NUMBER:

020-15-103-105 INSPECTION REPORT NUMBER: 50-336/JOB CODE'-.2548:.;.;,.'.,,.

NRC PROJECT OFFICER: E.A.Kleeh, NRR (301)415-2964 TECHNICAL MONITOR: Mel Holmberg, Rill (630)829-9748 PERFORMANCE PERIOD: January 28, 2000;, March 10, 2000 BACKGROUND An NRC design (AE)inspection completed in September 1997, identified issues that resulted in operability concerns for safety related systems and components.

The licensee voluntarily shutdown both units of the D.C.Cook plant and identified required corrective actions in a letter to the NRC.CAL 97-011 dated September 19, 1997 formalized the commitment for the licensee to remain shutdown until compensatory actions were undertaken.

Subsequently the licensee by self-assessments and the NRC by additional inspections identified more performance issues that were incorporated into'a pre-startup checklist attached to a letter sent from NRC to licensee on July 30, 1998.The items on that checklist had to be resolved by licensee as prerequisites to startup of either D.C.Cook unit.This inspection is being performed to determine the status of licensee corrective actions for those issues contained on that checklist and to verify their acceptability; to evaluate if licensee is maintaining its design basis;and to ensure the operability of selected safety systems in accordance with maintained design basis.OBJECTIVE The objective of this task order is to obtain expert technical assistance in the areas of electrical and mechanical design.Four specialists (two electrical and two mechanical) are needed to assist the NRC inspection team in the resolution of design, performance, and programmatic issues identified inConfirmatlve Action Letters (CALs), inspection reports, and LERs (hereafter all three referred to as inspection reference documents)and the D.C.Cook Restart Action INatiix.Each of the four specialists (electrical and mechanical) should primarily have a design background in his area of expertise, such as from an architect-engineer firm with experience in design and system operational requirements.

The specialists should also be familiar with the installation and surveillance testing of equipment; and how the engineering, operations, and corrective-action programs normally function and internally improve themselves.

The specialists should be thoroughly familiar with NRC regulations, closure of CALs, resolution of engineering followup and evaluation items, and overall NRC inspection methodology.

The specialists should be familiar with the regulatory process, and should be able to determine relevant regulatory commitments from docketed licensee correspondence for their assigned review areas.The specialists should be able to verify implementation of the licensee's commitments, assess the effectiveness and adequacy of the licensee's corrective-actions which includes detailed reviews of design and facility modifications, determine if licensee is maintaining the appropriate design basis taking into account design changes and modifications, and evaluate the overall performance and acceptability of broad programmatic areas like the engineering, operations, and corrective-action programs.The inspection will be conducted in accordance with lp 37550"Engineering," IP 37551"Onsite Engineering," IP 37700"Design Changes and Modifications," IP 37701"Facility Modifications;" IP 37702"Design Changes and Modifications Program," IP 37828"Installation and Testing of Modifications," 40500"Effectiveness of Licensee Process to Identify, Resolve, and Prevent Problems," IP 92700" Onsite Followup of Written Reports of Nonroutine Events At Power Reactor Facilities," and IP 92903"Followup-Engineering." It shall be the responsibility of the contractor to assign technical staff, employees, and subcontractors, who have the required combination of educational background and experience to meet both the technical and regulatory objectives of the.work specified in this Statement Of Work (SOW).The NRC will rely on representation made-by the contractor

~'I~4

• conc"ming',,the qualifications of'the personnel, proposed for assignment to',this'task order inclu'ding'assurance that all information contained in the technical an'd"cost'proposal's,~

incliidingi'resumes and conflict of int'crest.'disclosures is accu'rate and truthful.QI I, p WORK RE UIREMENTS AND SCHEDULE'he contractor shall provide the qualiTied specialists, and the, necessary facilities, materials, and services to assist the NRC staff in preparing for, conducting, and documenting the inspection activities and findings.The contractor shall provide the latest rad-worker training and MMPI test dates'of the.specialists to the Project Officer.The Technical Monitor/Team Leader'foi this task is Mel Holmberg.The'Technical Monitor may issue technical instructions during.the duration, of this task order that are in accordance with the SOW;and they, shall not constitute new assignments of work, or chariges in cost or period of performance.

The contractor shall refer to the basic contract for further information'and guidance on any technical-directions issued'under this task'order.

": 'I I 1.Modifications to the scope of work, costs, or period of performance of this task order must be issued by the Contracting Officer and will be coordinated with the NRR Project Officer.h!-1.Prepare for the Engineering Corrective Action Team Inspection a.Each specialist will review the CALs issued to the licensee, NRC inspection reports, and LERs for the last thirty months;and the D.C.Cook Restart Action Matrix for the inspection area assigned to him by the Technical Monitor.Schedule Com letion 1.Prepare for the inspection of D.C.Cook at Region III headquarters in Lisle, Illinois on or about January'31

-February 04, 2000.b.Determine the documents'associated with the specific design-problems identified in inspection reference documents relevant to specialist's assigned area of review or'assigned by Technical Monitor.c.Request copies of all inspection reference documents for the last 30 months for the assigned inspection area;licensee's programmatic requirements for identifying and addressing problems;and documents that indicate corrective actions taken for design problems stated in any inspection reference documents including those self-identified by licensee in determining the true scope of conditions.

2.Perform the inspection a.Make queries to the licensee on design and programmatic issues stated in inspection reference documents consistent with the intent of the inspection and assigned inspection area.2.Specialists will perform on-site inspection at D.C.Cook on or about February 07-11, 2000.and on or about February 22-25, 2000.Review of documentation, licensee inquiries, and other inspection-related activities will be conducted in specialist's home offices during Y*;,.;"',week of February 14,-,-18 2000.".;" b.Review design>ch<<ange packages, facility modifications;

'and;,'.setpoint

" change~packages to deterrriine

.if licensee's

'orrective

-actions'or specific design problems are appropriate and resolve the issues.c.Monitor the'performance of actual design modifications arid s'etpoint changes including the functional testing of ha'rdware,changes.

d.Evaluate thoroughly,:;licensee corrective actions for design'and'programmatic issues outlined in inspection reference documents in assigned area of review.1.)Effectiveness of corrective actions overall.2.)Adequacy of'oot-cause analyses.3.)Determine if licensee's analyses have effectively identified and addressed all similar issues.4.)Has licensee performed functional tests where corrective actions involved hardware changes or additions.

5.)Has design requirements been translated correctly into vendor/design specifications.for post modification testing.6.)Refer to IPs 37550, 37551, 37700, 37701, 37702, 37828, 40500, 92700, and 92903 for additional insights.e.Respond in a timely manner to licensee's responses to queries made in 2.a.f.Identify and develop findings or concerns as appropriate in accordance with the intent of inspection and IPs 37550, 37551, 37700, 37701, 37702, 37828, 40500, 92700, and 92903.g.Evaluate that any licensee corrective actions undertaken indicate corresponding changes in plants'esign basis and even licensing basis dependent on the relevance of the issues involved.Attachment

~~t'" F~i W'4 Vying"'W'-'"">I~~It"0"'"T<<" F~~h, Assess';,the,effectiven'ess",,of~licensee',s controls.'or',,'.en'gineering

..'program

,.in'pprovingplant., design'modifications;

'evising design.and licensing basis;.determining relevant preventive maintenance; and declaring the:systems in which design changes, were incorporated as operational.

F i.Each specialist should verify that'licensee has appropriately addressed all',items in inspection reference documents.

and'm'ost.especially any design problems',identified in the D.C.Cook Restart Aetio'n Matr'ix for his assigned inspection area during the course of the inspection.

I 1 I t', I e 3.Prepare the inspection report.a.Follow the guidelines of NRC INSPECTION MANUAL, Manual Chapter 0610,"Inspection Reports." unless otherwise directed by Technical Mo'nitor.3.Documentation of inspection will take place on or about February 28-March 03, 2000, in specialists'ome offices.Final feeder report input is due on or about March 06, 2000.b.Feeder report should discuss inspection activities, be concise, and focus on safety significant findings based on facts and regulatory requirements.

NOTE: Prior to the start of either in-office in~section preparation in Region III headquartersor on-site inspection activities, the contractor's staff is required to be available to coordinate inspection aspects, such as travel logistics, with the Team Leader/Technical Monitor.REPORT REQUIREMENTS At the completion of Task 1, the contractor's specialists shall provide an inspection plan to the NRC Team Leader.The format and scope of this input shall be as directed by the NRC Team Leader..During Task 2, the contractor's specialists shall provide daily reports to the NRC Team Leader.The format and scope of this report shall be as directed by the NRC Team Leader.At the completion of Task 2 (prior to the inspection team's debriefing the licensee), the contractor's specialists shall provide a summary of their inspection findings to the NRC Team.Leader.The format and scope shall be as directed by the NRC Team Leader.Typically, this input will consist of an electronic version (WordPerfect file on diskette)of the specialist's inspection findings.At the completion of Tasks 3, the contractor shall send a copy of the final inspection report input (feeder report)4 Attachment to,the"-NRC.

Project Officer anditp'e original,and,one.

comput'r,,diskette version (WordPerfect:6.1 or other~lBMi.PC compatible software acceptable) to the'NRC Team Lea'de'r.'-,-!The format and scope of the final, report inputs,'shall<be in accordance, with the guidance in NRC Inspection Manual Chapter,0610 or as directed by the NRC Team.L'eader.

A specialist's feeder report will serve as documentation of the specialist's inspection activities, effort, and findings,'nd will be used by the NRC Team Leader for the preparation of the NRC's inspection report.The form and scope of the final report input shall be in accordance with the guidance in NRC Inspection Manual Chapter 0610 or as directed by the'.NRC Team Leader.As a minimum, each specialist's report input shall include the following:

~Identity of the individuals (name, company, and title)that provided information to.the specialists during the inspection.

~For each area, inspected, a description of the activities and general findings and conclusions reached regaiding the adequacy of the area.h~For each area with a concern or findings, a discussion of the concerns or findings with technical bases.NOTE: The contractor is not required to undertake any further efforts toward report finalization except as directed by Technical Monitor and as stated in the SOW.For example, management review of the feeder report beyond its submittal to the NRC Team Leader and Project Officer is not needed.Business Letter Re ort The contractor shall provide monthly progress reports in accordance with the requirements of the basic contract.MEETINGS AND TRAVEL For estimating purposes, the following meetings and travel are anticipated:

One, four-person, 5 day trip to Region III headquarters in Lisle, Illinois to prepare for the inspection on or about January 31-February 04, 2000.Two, four-person, 5 day trips to the D.C.Cook site near Benton Harbor, Michigan to conduct the onsite phase of the inspection on or about February 07-11,'2000 and February 22-25, 2000.NOTE: The contractor's staff shall coordinate all travel arrangements in advance with the NRC Team Leader.NRC FURNISHED MATERIAL Documents required to prepare for the inspection will be provided by the NRC Team Leader.OTHER APPLICABLE INFORMATION The work specified in this SOW is 100%licensee fee recoverable.

The contractor shall provide'fee recovery information in the monthly progress reports in accordance with the requirements of the basic contract.The contractor's specialists assigned to this task order will have to be badged for.unescorted access privilege at the plant site.The contractor shall provide all documentation required for badging (as identified by the NRC Team Leader)at the plant site.Questions concerning badging and the plant site access shall be addressed to the NRC Technical Monitor.Attachment Distribution Sheet Distri-2.txt Priority: Normal From: Esperanza Lomosbog Action Recipients:

Internal'ecipients:~

FILE CENTER 01 External Recipients:

Copies: Paper Copy 4 Total Copies: Item: ADAMS Document Library: ML ADAMS" HQNTAD01 ID: 003695780:1 II

Subject:

TASK ORDER NO.074,"D.C.COOK ENGINEERING FOLLOW-UP TEAM INSPECTION" U NDER CONTRACT NO.NRC-03-98-021 Body: ADAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS.The Document may also be viewed by searching for Accession Number ML003695780.

DF02-Direct Flow Distribution:

PDR Direct Documents Docket: 05000315 Docket: 05000316 Page 1 A l 0'b P

~g RE0(.n O I Vl 0 Y.Cy+~~0++*++~,~><>UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C.20555-0001 January 28, 2000 Beckman and Associates, Inc.Attn: Vicki Beckman 1071 State Route 136 Belle Vernon, PA 15012

SUBJECT:

TASK ORDER NO.074,"D.C.COOK ENGINEERING FOLLOW-UP TEAM INSPECTION" UNDER CONTRACT NO.NRC-'03-98-021

Dear Ms.Beckman:

In accordance with Section G.5, Task Order Procedures, of the subject contract, this letter definitizes the subject task order.The effort shall be performed in accordance with the enclosed Statement of Work.Task Order No.074 shall be in effect from January 28, 2000, through March 10, 2000, with a total cost ceiling of$127,385.67.

The amount of$123,375.95 represents the estimated reimbursable costs and the amount of$4,009.72 represents the fixed fee.Accounting data for Task Order No.074 is as follows: B&R No.: Job Code: BOC: APPN No.: FFS¹: Oblig.Amt.020-15-103-105 J-2548 252A 31X0200.020 NRR98021 074$127,385.67 The following individuals are considered to be essential to the successful performance of work hereunder:

Mr.John Chiloyan, Mr.Raymond Cooney, Mr.Richard Ely, and Mr.Charles Jones.The Contractor agrees that such personnel shall not be removed from the effort under the task ilC C~.~The issuance of this task order does not amend any terms or conditions of the subject contract.

1 f 1'

'+N k ll Your contacts during the course of this task o'rder are: l Technical Matters: Edmund Kleeh Project Officer (301)415-2964 Contractual Matters: Mona Selden Contract Specialist (301)415-7907 Acceptance of Task Order No.074 should be made by having an official, authorized to bind your organization, execute three copies of this document in, the space provided and return two copies to the Contract Specialist.

You should retain the third copy for your records.Sine rey, S ron D.Stewart, Contracting Officer Contract Management Branch 2 Division of Contracts and Property Management Office of Administration

Enclosure:

Statement of Work ACCEPTE: Task Order o.074 NAME'TITLE DATE STATEMENT OF WORK...Task Order 074 TITLE.D.C.Cook Engineenng Follow up Team.Inspection DOCKET NUMBER: 50-315/316 B8R NUMBER: 020-15-103-105 JOB CODE:.J-.2548...

INSPECTION REPORT NUMBER: 50-336/NRC PROJECT OFFICER: E.A.Kleeh, NRR (301)415-2964 TECHNICAL MONITOR: Mel Holmberg, Rill (630)829-9748 PERFORMANCE PERIOD: January 28, 2000-March 10, 2000 BACKGROUND An NRC design (AE)inspection completed in September 1997, identified issues that resulted in operability concerns for safety related systems and components.

The licensee voluntarily shutdown both units of the D.C.Cook plant and identified required corrective actions in a letter to the NRC.CAL 97-011 dated September 19, 1997 formalized the commitment for the licensee to remain shutdown until corn'pensatory actions were undertaken.

Subsequently the licensee by self-assessments and the NRC by additional inspections identified more performance issues that were incorporated into a pre-startup checklist attached to a letter sent from NRC to licensee on July 30, 1998.The items on that checklist had to be resolved by licensee as prerequisites to startup of either D.C.Cook unit.This inspection is being performed to determine the status of licensee corrective actions for those issues contained on that checklist and to verify their acceptability; to evaluate if licensee is maintaining its design basis;and to ensure the operability of selected safety systems in accordance with maintained design basis.OBJECTIVE The objective of this task order is to obtain expert technical assistance in the areas of electrical and mechanical design.Four specialists (two electrical and two mechanical) are needed to assist the NRC inspection team in the resolution of design, performance, and programmatic issues identified inConfirrnative Aetio'n Letters (CALs), inspection reports, and LERs (hereafter all three referred to as inspection reference documents)and the D.C.Cook RestartAction Matrix.Each of the four specialists (electrical and mechanical) should primarily have a design background in his area of expertise, such as from an architect-engineer firm with experience in design and system operational requirements.

The specialists should also be familiar with the installation and surveillance testing of equipment; and how the engineering, operations, and corrective-action programs normally function and internally improve themselves.

The specialists should be thoroughly familiar with NRC regulations, closure of CALs, resolution of engineering followup and evaluation items, and overall NRC inspection methodology.

The specialists should be familiar with the regulatory process, and should be able to determine relevant regulatory commitments from docketed licensee correspondence for their assigned review areas.The specialists should be able to verify implementation of the licensee's commitments, assess the effectiveness and adequacy of the licensee's corrective-actions which includes detailed reviews of design and facility modifications, determine if licensee is maintaining the appropriate design basis taking into account design changes and modifications, and evaluate the overall performance and acceptability of broad programmatic areas like the engineering, operations, and corrective-action programs.The inspection will be conducted in accordance with lp 37550"Engineering," IP 37551"Onsite Engineering," IP 37700"Design Changes and Modifications," IP 37701"Facility Modifications-," IP 37702"Design Changes and Modifications Program," IP 37828"Installation and Testing of Modifications," 40500"Effectiveness of Licensee Process to Identify, Resolve, and Prevent Problems," IP 92700" Onsite Followup of Written Reports of Nonroutine Events At Power Reactor Facilities," and IP 92903"Followup-Engineering." It shall be the responsibility of the contractor to assign technical staff, employees, and subcontractors, who have the required combination of educational background and experience to meet both the technical and regulatory objectives of the work specified in this Statement Of Work (SOW).The NRC will rely on representation made by the contractor 0 V~h co'nc'erning the'qualifications info'rrnation contained in the accurate and truthful.of the'pers'onnel",proposed, for:as'sigriment to.this task order includingassurance'that'all technicalarid"cost proposals, including resumes,and conflict of'iriterest.disclosures',l'is 1 I WORK RE UIREMENTS AND SCHEDULE The contractor shall provide the qualified specialists, and the necessary facilities, materials, and services to as'sist the NRC:staff in preparing for, conducting, and documenting the inspection activities and findings.The contractor shall provide the latest rad-worker training and MMPI test.dates, of the specialists to the Project Officer.The Technical Monitor/Team Leader for this task is Mel Holmber g'.The"Technical Monitor may issue technical instructions duiing'the duration'of this task order that are in accordance with the SOW;.and they shall not constitute new assignments of work, or chan'ges in cost or period of performance.

The contractor.,'shall" refer to the, basic contract for further information.and guidance on any technical directions issued under, this-task order:*,'odifications to the scope of work, costs, or period of performance of this task order must be issued by the Contracting Officer and will be coordinated with the NRR Project Officer.al 1.Prepare for the Engineering Corrective Action Team Inspection a.Each specialist will review the CALs issued to the licensee, NRC inspection reports, and LERs for the last thirty months;and the D.C.Cook Restart Action Matrix for the inspection area assigned to him by the Technical Monitor.Schedule Com letion 1.Prepare for the inspection of D.C.Cook at Region III headquarters in Lisle, Illinois on or about January 31-February 04, 2000.b.Determine the documents associated with the specific design problems identified in inspection reference documents relevant to specialist's assigned area of review or'ssigried by'Technical Monitor.c.Request copies of all inspection reference documents for the last 30 months for the assigned inspection area;licensee's programmatic requirements for identifying and addressing problems;and documents that indicate corrective actions taken for design problems stated in any inspection reference documents including those self-identified by licensee in determining the'true scope of conditions.

2.Perform the inspection a.Make queries to the licensee on design and programmatic issues stated in inspection reference documents consistent with the intent of the inspection and assigned inspection area.2.Specialists will perform on-site inspection at D.C.Cook on or about February 07-11, 2000 ,and on or about February 22-25, 2000.Review of documentation, licensee inquiries, and other inspection-related activities will be conducted in specialist's home offices during

~,

;,.":",.".'.-'g;>'.',",.',.',,',.'.'.".';"-l",'eek, of February.'1'4-'8, 2000.'"..,:,.;

b.'Review design;change:packages,=facility modifications,'.and;;.setp'oin't, change packages to'determine if licensee's corrective actions-for specific design problems are appropriate and resolve the issues.!c.Monitor the performance, of actual design modifications an'd s'etp'oint changes inclu'ding the functional testing of hardware changes.d.Evaluate thoroughly lice'nsee corrective actions for design an'd programm'atic issues'utlined in inspection reference documents in assigned area of review.1.)Effectiveness of corrective actions overall.2.)Adequacy of'oot-cause analyses.3.)Determine iflicensee's analyses have effectively identified and addressed all similar issues.4.)Has licensee performed functional tests where corrective actions involved hardware changes or additions.

5.)Has design requirements been translated correctly-into vendor/design specifications for post modification testing.6.)Refer to IPs 37550, 37551, 37700, 37701, 37702, 37828, 40500, 92700, and 92903 for additional insights.e.Respond in a timely manner to licensee's responses to queries made in 2.a.f.Identify and develop findings or concerns as appropriate in accordance with the intent of inspection and IPs 37550, 37551, 37700, 37701, 37702, 37828, 40500, 92700, and 92903.g.Evaluate that any licensee corrective actions undertaken indicate corresponding changes in plants'esign basis and even licensing basis dependent on the relevance of the issues involved.Attachment 0 4 F/FL I II'-

'h.',Assess,the:effectiveness,-'of~",license'e's-',--',',:i,.',":.::

'~"'"-,+>>.t',.,: controls.for',',engineering.'.-program in approving plant design,.",, m'odwfications; revising design and licensing basis;'determining relevant preventive maintenance; and declaring the systems in which design changes were incorporated as o erational.

p 1 i.Each specialist should verify, that licensee', has appropriately addressed.all items in inspection reference documents.

and most especially any design problems identified in, the D.C.Cook Restart Action Matrix for his'ssigned inspection area during tlie course of the inspection.

3.Prepare the inspection report.a.Follow the guidelines of NRC INSPECTION MANUAL, Manual Chapter 0610,"Inspection Reports." unless otherwise directed by Technical Monitor.3.Documentation of inspection will take place on or about February 28-March 03, 2000, in specialists'ome offices.Final feeder report input is due on or about March 06, 2000.b.Feeder report should discuss inspection activities, be concise, and focus on safety significant findings based on facts and regulatory requirements.

NOTE: Prior to the start of either in-office inspection preparation in Region III headquarters or on-site.inspection activities, the contractor's staff is required to be available to coordinate inspection aspects, such as travel logistics, with the Team Leader/Technical Monitor.REPORT REQUIREMENTS At the completion of Task 1, the contractor's specialists shall provide an inspection plan to.the NRC Team Leader.The format and scope of this input shall be as directed by the NRC Team Leader..During Task 2, the contractor's specialists shall provide daily reports to the NRC Team Leader.The format and scope of this report shall be as directed by the NRC Team Leader.At the completion of Task 2 (prior to the inspection team's debriefing the licensee), the contractor's specialists shall provide a summary of their inspection findings to the NRC Team Leader.The format and scope shall be as directed by the NRC Team Leader.Typically, this input will consist of an electronic version (WordPerfect file on diskette)of the specialist's inspection findings.At the completion of Tasks 3, the contractor shall send a copy of the final inspection report input (feeder report)Attachment

~Q~~

II I~p r'0-~to (he NRC,~Project Officer and the original and one computer diskette version (WordPerfect 6.1 or other IBM PC compatible software acceptable) to the NRC Team Leader.The format-and scope of the final report inputs shall be in accordance.

with the guidance in NRC Inspection Manual Chapter 0610 or as directed by the NRC Team Leader.A specialist's feeder report will serve as documentation of the specialist's inspection activities, effort, and findings, and will be used by the NRC Team Leader for the preparation of the NRC's inspection report.The form and scope of the final report input shall be in accordance with the guidance in NRC Inspection Manual Chapter 0610 or as directed by the NRC Team Leader.As a minimum, each specialist's report input shall include the following:

~Identity of the individuals (name, company, and title)that provided iriformation to the specialists during the inspection.

~For each area inspected, a description of the activities and general findings and conclusions reached regarding the adequacy of the area.~For each area with a concern or findings, a discussion of the concerns or findings with technical bases.NOTE: The contractor is not required to undertake any further efforts toward report finalization except as directed by Technical Monitor and as stated in the SOW.For example, management review of the feeder report beyond its submittal to the NRC Team Leader and Project Officer is not needed.Business Letter Re ort The contractor shall provide monthly progress reports in accordance with the requirements of the basic contract.MEETINGS AND TRAVEL For estimating purposes, the following meetings and travel are anticipated:

One, four-person, 5 day trip to Region III headquarters in Lisle, Illinois to prepare for the inspection on or about January 31-February 04, 2000.Two, four-person, 5 day trip's to the D.C.Cook site near Benton Harbor, Michigan to conduct the onsite phase of the inspection on or about February 07-11, 2000 and February 22-25, 2000.NOTE: The contractor's staff shall coordinate all travel arrangements in advance with the NRC Team Leader.NRC FURNISHED MATERIAL Documents required to prepare for the inspection will be provided by the NRC Team Leader.OTHER APPLICABLE INFORMATION The work specified in this SOW is 100%licensee fee recoverable.

The contractor shall provide'fee recovery information in the monthly progress reports in accordance with the requirements of the basic contract.The contractor's specialists assigned to this task order will have to be badged for unescorted access privilege at the plant site.The contractor shall provide all documentation required for badging (as identified by the NRC Team Leader)at the plant site.Questions concerning badging and the plant site access shall be addressed to the NRC Technical Monitor.Attachment DOCKET NO(S).50-315/316 Ilike Murphy Radiation Program Manager US EPA Region 5 (AE-17J)77 West Jackson Boulevard Chicago, IL 60604-3507 December 1, 1999 DISTRIBUTION:

File Center PD3-1 r/f JStang THarris

SUBJECT:

DONALD C.COOK NUCLEAR POWER PLOTS, UNITS 1 IrIND 2 Thefollowin documentsconcernin ourreviewofthesub'ectfacil'retransmittedfor ourinformation.

DESCRIPTION OF DOCUMENT Notice of Receipt of Application Draft/Final Environmental Statement Notice of Availability of Draft/Final Environmental Statement Safety Evaluation Report, or Supplement No.Environmental Assessment and Finding of No Significant Impact Notice of Issuance of Environmental Assessment Notice of Consideration of Issuance of Facility Operating License or Amendment to Facility Operating License DATED jweekly Notice;Applications and Amendments to Operating censes Invohnn No Si nilicant Hazards Conditions Exemption Construction Permit No.CPPR-Facility Operating License No.Order Monthly Operating Report for See Page(s), Amendment No., Amendment No.Transmitted by Letter Annual/Semi-Annual Report 1998 Annual 0 eratin R t Other Transmitted by Letter Office of Nuclear Reactor Regulation

Enclosures:

As stated CC: Toni L.Harris DOCUMENT NAME: To receive a co of this document indicate In the box: C~Co without attachment/enclosure E~Co with attachment/enclosure N~No co OFFICE iKS/NAME THarris DATE 12//99 OFFICIAL RECORD COPY

-~I~I*9 I'I 1'I'I ,~

DISTRIBUTION:

File Center PD3-1 r/f 3Stang THarris DOCKET NO(S).50-315/16 November 23, 1999 tlike IIurphy l)adiation ProgramN1anager US EPA Region 5 (AE-170)77 I!est OacksonBBoulevard Chicago, IL 60604-3507

SUBJECT:

DONALD C.COOK NUCLEAII PLANT UNQIS 1 AtlD 2 Thefollowin documentsconcernin ourreviewofthesub'ectfaciT aretransmittedfor ourinformation.

DESCRIPTION OF DOCUMENT Notice of Receipt of Application Draft/Final Environmental Statement Notice of Availability of Draft/Final Environmental Statement Safety Evaluation Report, or Supplement No.Environmental Assessment and Finding of No Significant Impact DATED Notice of Issuance of Environmental Assessment C'otice of Consideration of Issuance of Facility Operating License or Amendment to~Fcility Operating License Biweekly Notice;Applicqtiolts and Amendments.to Operating Ucenses Involvtn No Si niftcant Hazards Conditions Exemption Construction Permit No.CPPR-Facility Operating License No.Order Monthly Operating Report for See Page(s), Amendment No., Amendjgggt No.Transmitted by Letter Annual/Semi-AnnualReport:

COrreCtipn tp 1998 AnnualEEnyir'Onmental 0 eratin Rpt Transmitted by Letter Other Office of Nuclear Reactor Regulation

Enclosures:

As stated Toni L.Harris CC: DOCUMENT NAME: To receive a co of this document indicate In the box: "C~Co with out attachment/enclosure E~Co with attachment/onclosuro N~No co OFFICE NAME DATE LA PD3-1 THarris 11/23/99 OFFICIAL RECORD COPY A 4~I L 1~'I~E-1 P E I.=r g~t l p~1~5