indiana michigan power company donald c. cook …

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INDIANA MICHIGAN POWER COMPANY

DONALD C. COOK NUCLEAR POWER PLANT

LIFE CYCLE MANAGEMENT PROJECT

SEMI-ANNUAL PROGRESS REPORT

PREPARED FOR

MICHIGAN PUBLIC SERVICE COMMISSION

OCTOBER 2016

PURSUANT TO COMMISSION ORDER U-17026

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TABLE OF CONTENTS

ACRONYMS AND DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

EXECUTIVE OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

IN-SERVICE DATES OF COMPLETED PROJECTS . . . . . . . . . . . . . . . . . . . . . . . . . . 6

PROJECT CHANGE REQUEST FORM LOG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 DEFERRALS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

ATTACHMENTS

Attachment 1: Updated LCM Sub-Project Phase Designations. . . . . . . . . . . . . . . . 15

Attachment 2: Update of LCM Sub-Project Cost Estimates . . . . . . . . . . . . . . . . . . 18

Attachment 3: LCM Sub-Project Expenditures to Date. . . . . . . . . . . . . . . . . . . . . . .21

Attachment 4: LCM Project Timeline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Attachment 5: Cook Nuclear Plant Pre-Outage Milestone Matrix . . . . . . . . . . . . . . 26

Attachment 6: LCM Schedule Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Attachment 7: Major Scope Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Attachment 8: LCM Project Issues and Challenges . . . . . . . . . . . . . . . . . . . . . . . . 32

INDEPENDENT MONITOR’S SEPTEMBER 2016 LIFE CYCLE MANAGEMENT PROJECT SEMI-ANNUAL PROGRESS REPORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Att 9

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ACRONYMS AND DEFINITIONS

AE Architect Engineer AEP American Electric Power

AMSAC ATWS Mitigating System Actuation Circuit ATWS Anticipated Transient Without Scram BKR Breaker BOB Buchanan Office Building

CP&B Corporate Planning and Budgeting CCW Component Cooling Water CEQ Containment Air Recirculation/Hydrogen Skimmer CO2 Carbon Dioxide

Cook / CNP Donald C. Cook Nuclear Power Plant CRID Control Room Instrumentation Distribution CTS Containment Spray EAC Estimate at Completion

ECCS Emergency Core Cooling System EDG Emergency Diesel Generator EP Emergency Power

ESFAS Engineered Safety Features Actuation System ESW Essential Service Water FAT Factory Acceptance Testing FW Feedwater

GSU Generator Step-Up HDP Heater Drain Pump HP High Pressure

HTR Heater HVAC Heating, Ventilation, Air Conditioning

HX Heat Exchanger I&M Indiana Michigan Power Company

IURC Indiana Utility Regulatory Commission LCM Life Cycle Management LP Low Pressure

Mod Modification MPSC Michigan Public Service Commission MSR Moisture Separator Reheater MVA Million Volt-Amperes

NESW Non-Essential Service Water OEM Original Equipment Manufacturer PCRF Project Change Request Form

PM Project Manager PMBOK Project Management Body of Knowledge

PMI Project Management Institute

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PMP Project Management Professional PMT Preventative Maintenance PPC Plant Process Computer PRF Project Request Form RCP Reactor Coolant Pump RFP Request for Proposal RMS Radiation Monitoring System

RPAC Radiation Protection Access Control RPS Reactor Protection System SG Steam Generator

SWEPCO Southwestern Electric Power Company SWCIP Secondary Water Chemistry Improvement Project

TAM Temporary Alarm Monitor TDAFP Turbine Driven Auxiliary Feed Pump Temp Temporary

TR Transformer TSC Technical Support Center UAT Unit Auxiliary Transformer UNK Unknown UPS Uninterruptible Power Supply VAC Volts - AC

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EXECUTIVE OVERVIEW

This Semi-Annual Progress Report has been generated to provide the current status of the LCM sub-projects that comprise the LCM Project at Cook Nuclear Plant. This report represents actual engineering, construction, budget, and schedule progress through June 30, 2016. As an effort to maintain consistency, the majority of the information provided within this report is the same data as provided in the LCM-6 Interim Status Update Report, supporting Cause No. 44182 LCM 6, as filed with the Indiana Utility Regulatory Commission in October 2016. In addition, Attachment 9 to this report contains the Independent Monitor’s September 2016 Life Cycle Management Project Semi-Annual Progress Report. The following information has been provided as a high-level summary:

• Thirty-nine (39) LCM sub-projects have been completed and placed in-service as of June 30, 2016

o Completed at a total cost of $317.1 million as compared to their original Estimate at Completion value of $320.6 million.

• Actual expenditures through June 30, 2016, total approximately $688 million for completed and in-progress sub-projects.

• Multiple LCM sub-projects advanced in project phase. A summary of the phase changes is as follows:

• There have been nine (9) schedule changes between December 31, 2015 and June 30, 2016.

Overall, the LCM Project and the associated sub-projects are progressing as anticipated. I&M continues to evaluate the remaining LCM project schedule to ensure continued safe and reliable operation of the Cook Nuclear Plant. Schedule changes will continue to be reported in Semi-Annual Progress Reports as they are known. I&M is on track to complete the overall LCM Project within the Estimate at Completion (EAC) as filed, with a slightly extended timeframe for a few sub-projects.

Phase Designation Number of Projects (as of 12/31/15)

Number of Projects (as of 06/30/16)

Phase 4 37 39

Phase 3 5 8

Phase 2B 15 15

Phase 2A 7 8

Phase 1 19 9

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IN-SERVICE DATES OF COMPLETED PROJECTS

Line LCM Sub-Project Project Number In-Service Date (Month / Year)

1 U2 Generator Step-Up Transformer PRF040174 05/2012 2 U2 Iron Filtration PRF110060 04/2012 5 U2 ESW Pump Motor (2-PP-7E/7W) PRF080073 05/2012 6 765kV Breaker 2-52-A2 PRF040478 04/2012 8 U1 CEQ Fan Motor Coolers PRF100073 10/2014 9 U2 CEQ Fan Motor Coolers PRF120048 04/2015 11 Security UPS and Battery Chargers PRF080131 01/2014 13 U2 Feedwater Heaters (LP) – 4A/4B PRF040464 11/2013 14 U2 Control Room Chiller (HVAC) PRF110002 01/2015 15 U1 Plant Process Computer PRF040069 10/2013 16 U2 Plant Process Computer PRF040068 12/2013 17 U1 Control Room Annunciator PRF040065 04/2013 18 U2 Control Room Annunciator PRF040064 10/2013 19 U1 Unit Auxiliary Transformers PRF040196 05/2013 20 U2 Unit Auxiliary Transformers PRF040198 11/2013 21 Ice Machine and Glycol Chillers PRF040034 03/2015 22 U1 West Containment Spray HX PRF110008 10/2014 23 RPAC Renovation PRF080095 09/2014 27 765kV Breaker 2-52-B2 PRF040479 11/2013 28 34kV Circuit Breaker – BC Breaker PRF110031 11/2013 29 34kV Circuit Breaker – BE Breaker PRF040480 05/2013 30 34.5/4kV Cables (with line #48) PRF040111 05/2014 34 U2 Main Generator Hydrogen System PRF040460 11/2013 35 U1 Seismic Monitoring System PRF040439 11/2013 36 U2 Seismic Monitoring System PRF110105 11/2013 38 U1 HP Feedwater Heaters PRF040467 05/2016 39 U1 Control Room Chiller (HVAC) PRF040033 03/2015 40 U1 East CTS Heat Exchanger PRF040301 04/2016 43 Ice Condenser Sys (Transport/ Bins) PRF090189 03/2015 44 #23 Reactor Coolant Pump (RCP) PRF140060 05/2015 45 Transformer 7 PRF050011 12/2014 46 Public Address System PRF060050 12/2014 48 34.5/4kV Cables (with line #30) PRF040111 05/2014 56 U1 Condensate Polishers (SWCIP) PRF070114 10/2014 57 U2 Condensate Polishers (SWCIP) PRF080001 09/2014 63 69kV Switchyard EP-Line PRF040499 12/2014 84 U1 Feedwater Heater Digital Controls PRF110090 01/2015 98 U1/U2 7.5 Ton Carbon Dioxide System PRF040518 07/2014 101 U2 Feedwater Heater Digital Controls PRF110091 03/2014

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CONFIDENTIAL-SUBJECT TO PROCTIVE ORDER ISSUED JUNE 5, 2012 IN CASE NO. U-17026

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ATTACHMENT 3: LCM SUB-PROJECT EXPENDITURES TO DATE


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ATTACHMENT 4: LCM PROJECT TIMELINE


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ATTACHENT 6: LCM SCHEDULE CHANGES


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ATTACHMENT 7: MAJOR SCOPE CHANGES

The below LCM sub-projects have had major scope changes. In some instances, the change has required (or will require) a revision to the sub-project’s respective Capital Improvement Requisition (IR). PRF070119 Unit 1 Exciter Air Bridge Rectifiers

• This sub-project required an IR revision to fund an engineering scope change. During a Design Review Board meeting, the project team was challenged on the power source for the door fans. Subsequently, a determination was made to install a redundant power source utilizing two separate Motor Control Centers (MCC’s) - one to supply the power fans on the right side of the individual cabinets and one for the left. This engineering scope change ensures that one door fan is always functioning for each of the rectifier cabinets, in the event there is a loss of power from one of the MCC’s.

PRF080060 Technical Support Center / North Access (TSC/NA) Building

• As has been discussed in every proceeding since Cause No. 44182 LCM 3, the construction of the TSC/NA Building sub-project was stopped in 2014 due to indication of potentially significant cost overruns. Additionally, the scope of this sub-project was reduced as a result of an in-depth project scrub. The re-defined scope was formally documented and frozen to any/all future changes. Construction was put on hold to allow for the engineering to complete in October 2015 and major project construction was moved out of 2016 and into 2017. As a precaution and to provide protection of the asset, minor shell construction work was completed in the fourth quarter of 2015, and the building was heated and sealed for the winter. Since the engineering has been completed and bids have been received, this sub-project’s IR has been revised to reflect the updated cost estimate to complete construction of the building.

The following LCM sub-projects had major scope changes previously identified in Cause No. 44182 LCM 6:

• PRF040578 / PRF040579 Unit 1 and Unit 2 Polar Cranes • PRF055096 Turbine Room Sump

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ATTACHMENT 8: LCM PROJECT ISSUES AND CHALLENGES

PRF040486 / PRF040487 Unit 1 and Unit 2 Radiation Monitoring Systems • Due to delays in receiving vendor documentation, the Engineering Changes (EC)

for both Radiation Monitoring System sub-projects are missing vendor design information, including how the Plant Process Computer will interface with the Rad-Serv system. As a result, Cook's Design Review Board has to determine if the sub-projects will use Open Item Constraints (OIC’s) or revise the EC packages to finalize unresolved issues. In addition, before implementation begins, planning must be completed for the EC’s. As a result, the project team is anticipating the first radiation monitor installation to occur in July 2017. This date was chosen to give planners and procedure writers ample time to complete all supporting documentation related to the EC’s. Thus far, the vendor has shipped the majority of the required monitors, with the remaining scheduled for delivery in October 2016, to support installation efforts.

PRF040140 Steam Generator Water Level Controls

• The schedule for this sub-project is being extended to address a number of risks, including resolution of vendor test exception reports (TER's)/anomaly reports (AR's) and identified issues following the official Factory Acceptance Testing. Retests are required for many AR's to assure the proposed resolution is successful. These items, including additional testing in the simulator, are required prior to installation. As such, the installation schedule was reviewed at an Outage Scope Meeting and received Senior Management approval to move from U2C23 to U2C24 to minimize project and station risk.

The following LCM sub-projects had challenges previously identified in Cause No. 44182 LCM 6:

• PRF080060 Technical Support Center / North Access Building • PRF040185 / PRF040188 Unit 1 and Unit 2 Fuel Transfer Equipment • PRF090184 EP1 and EP2 Transformers

LCM PROJECT SUCCESS

PRF040300 / PRF110009 Unit 2 East / West Containment Spray Heat Exchangers

• The Containment Spray Heat Exchanger (CTS HX) replacements were originally scheduled to be replaced one at a time during corresponding unit refueling outages. After completing the U1 installations and incorporating lessons learned, the project team has recognized an opportunity to implement both the Unit 2 East and West CTS HX’s during the U2C23 refueling outage in the fall of 2016. This opportunity includes numerous benefits, including: anticipated cost savings to be realized during installation, reduction of crane usage conflicts, impact to other work groups is reduced to only one outage, extended duration that exists to support the U2 Turbine replacement provides additional installation time, and the retention of experienced staff and craft personnel.

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INDEPENDENT MONITOR’S SEPTEMBER 2016 LIFE CYCLE

MANAGEMENT PROJECT SEMI-ANNUAL PROGRESS REPORT

ATTACHMENT 9

(NOTE: E3’s Independent Monitor report serves to provide an independent evaluation on the progress and reasonableness of the entire LCM Project. These reports are used for both the Michigan and Indiana jurisdictions. In Cause No. 44182, the Indiana Utility Regulatory Commission (IURC) approved the LCM Project, including an estimate for Management Reserve costs. Specific to Indiana, the use of Management Reserve is evaluated on an individual sub-project basis. For purposes of I&M’s filings with the IURC, E3’s report provides an independent evaluation of I&M’s use of these funds according to methodology accepted by the IURC.)

Table of Contents

Final Report i

SEMI-ANNUAL PROGRESS REPORT .................................................................................... 1 Executive Summary .................................................................................................................... 1

Overview ................................................................................................................................. 1 Independent Monitoring .......................................................................................................... 1 Current Project Status ............................................................................................................. 1 Budget ..................................................................................................................................... 2 Schedule .................................................................................................................................. 2 Project Management ............................................................................................................... 2 Conclusions ............................................................................................................................. 2

Overview ..................................................................................................................................... 4 Background ............................................................................................................................. 4 Objective ................................................................................................................................. 4

Independent Monitoring ............................................................................................................. 4 IM Project Cost ....................................................................................................................... 4 Project Schedule ...................................................................................................................... 4 Scope of Work and Changes ................................................................................................... 5 Deliverables ............................................................................................................................ 5 Actual and Planned Actions .................................................................................................... 5

Current Project Status ................................................................................................................. 6 Sub-Projects Completed .......................................................................................................... 6 Sub-Projects in Progress ......................................................................................................... 8

Budget ......................................................................................................................................... 9 LCM Original Budget ............................................................................................................. 9 June 2016 Budget .................................................................................................................... 9 June 2016 Budget vs. LCM Original Budget .......................................................................... 9 Total Sub-Projects ................................................................................................................. 13 Cost Variance Reports .......................................................................................................... 14 Project Change Request Forms ............................................................................................. 16

Schedule .................................................................................................................................... 17 Project Management ................................................................................................................. 20 Attachment 1 – LCM Project – Forecast of Sub-Project Costs ................................................ 21 Attachment 2 – Cost Variance Reports Summary .................................................................... 22 Attachment 3 – Project Change Request Forms Reviewed ...................................................... 23 Attachment 4 – Level 1 LCM Project Schedule ....................................................................... 24 Attachment 5 – Site Photos ....................................................................................................... 25

TABLES

Table 1 LCM Projects Completed .................................................................................................. 7

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Final Report ii

Table 2 June 30, 2016 Budget....................................................................................................... 11

Table 3 Deferred Sub-Projects - 5 ................................................................................................ 12

Table 4 Inactive Sub-Projects - 21 ................................................................................................ 13

Table 5 Cost Variance Report Summary ...................................................................................... 15

Table 6 Causes of Cost Variances ................................................................................................ 16

Table 7 Earned Value Reports ...................................................................................................... 19

Table 8 LCM Schedule Changes between LCM 5 and LCM 6 .................................................... 19

FIGURES

Figure 1 EVR for U2 LP and HP Turbine Replacement .............................................................. 18

Copyright ©2016 by E3 Consulting® All Rights Reserved.

This report has been prepared for the use of the client named in the report for the specific purpose identified in the report. This report should not be relied upon by any other party for any other purpose. This report is not to be used, circulated, quoted or referred to, in whole or in part, for any other purpose without the prior written consent of E3 Consulting. The conclusions, observations and recommendations contained herein attributed to E3 Consulting constitute the opinions of E3 Consulting. For a complete understanding of the conclusions and opinions, this report should be read in its entirety. To the extent that statements, information and opinions provided by the client or others have been used in the preparation of this report, E3 Consulting has relied upon the same to be accurate. While we believe the use of such information provided by others is reasonable for the purposes of this report, no assurances are intended and no representations or warranties are made. E3 Consulting makes no certification and gives no assurances except as explicitly set forth in this report.

Table of Contents

Final Report iii

Acronym Definition AEP American Electric Power AFUDC Allowance for Funds Used During Construction AMSAC ATWS Mitigating System Actuation Circuitry ATWS Anticipated Transient Without SCRAM BOB Buchanan Office Building CCW Component Cooling Water CEQ Containment Pressure Equalization Fans Cook or CNP Donald C. Cook Nuclear Plant CPI Cost Performance Index CRID Control Room Instrumentation Distribution CVR Cost Variance Report E3 E3 Consulting EAC Estimate At Completion EDG Emergency Diesel Generator EPRG Executive Project Review Group ESFAS Engineering Safety Features Actuation System ESW Essential Service Water EVR

Earned Value Report FW Feedwater

HP

High Pressure HVAC Heating, Ventilating, and Air Conditioning

HX

Heat Exchanger IM Independent Monitor IM Agreement E3’s IM Contract No. 1560548 with I&M dated August 9, 2013 I&M Indiana Michigan Power Company IR Capital Improvement Requisition IURC Indiana Utility Regulatory Commission LCM or Project Life Cycle Management Project LCM Original Budget Exhibit I&M-22 for the Certificate of Necessity for the Project in Michigan (Case No. U-17026) or

Exhibit TJB-5 for requested relief in Indiana (Cause No. 44182). LCM Team or Team I&M’s team of experts assigned to manage the LCM Project LP Low Pressure MPSC Michigan Public Service Commission MR Monthly Report MSR Moisture Separator Reheater NAB North Access Building NESW Non-Essential Service Water PCRF Project Change Request Form PRB Project Review Board RPS Reactor Protection System SAPR Semi-Annual Progress Report SCRAM Safety Control Rod Axe Man – (Reactor Trip) SOW Scope Of Work

Table of Contents

Final Report iv

SWCIP Secondary Water Chemistry Improvement Project SPI Schedule Performance Index TDAFP Turbine Driven Auxiliary Feed Pump TSC Technical Support Center UPS Uninterruptable Power Supply

E3 Consulting 1

SEMI-ANNUAL PROGRESS REPORT

EXECUTIVE SUMMARY Overview

This September 2016 Semi-Annual Progress Report (SAPR) has been prepared by E3 Consulting® (E3) to provide an update on our Independent Monitoring (IM) activities related to the sub-projects that make up the Life Cycle Management (LCM) Project (Project) at the Donald C. Cook Nuclear Plant (Cook or CNP). This SAPR is based on our review of a number of documents, cost reports, Project Change Request Forms (PCRF), Cost Variance Reports (CVR), schedules, Earned Value Reports (EVR), discussions with the LCM team (LCM Team), and observations of the actual construction progress during the January 1, 2016 through June 30, 2016 period. We visited the Cook Plant on January 21, 2016 for a monthly progress meeting, plant tour, and Executive Project Review Group (EPRG) meeting. The February 25, April 28, and June 1, 2016 monthly progress meetings were conducted by conference calls. On June 30, 2016 the monthly progress meeting was conducted in Denver, CO. We last visited the Cook plant on March 31, 2016 and attended the monthly progress meeting.

Please note that since June 30, 2016 we participated in the July 28, August 25, and September 19 monthly progress meetings by conference call.

Independent Monitoring E3’s primary Scope of Work (SOW) is to evaluate and explain any differences that may arise between the LCM original budget [as presented by Indiana Michigan Power Company (I&M) as either Exhibit I&M-22 for the Certificate of Necessity for the Project in Michigan (Case No. U-17026) or Exhibit TJB-5 for requested relief in Indiana (Cause No. 44182)] (LCM Original Budget) costs and the actual costs incurred for the LCM Project. In addition, the SOW is to evaluate and explain any differences that may arise between the projected in-service dates and the actual in-service dates for the sub-projects. There have been no changes to the IM’s SOW.

E3’s IM project costs for the January 1 through June 19, 2016 period were $155,558, which represents 38.70 percent of the revised not-to-exceed annual budget of $402,000 for 2016.

Current Project Status The current schedule for the Project shows a completion date of 2022, which is consistent with the Indiana Utility Regulatory Commission’s (IURC) LCM 5 Order. This is in alignment with the schedule changes presented in the March 2016 SAPR. As of June 30, 2016, a total of 39 sub-projects have been completed (technically 37, since four sub-projects have been combined into two); there are 12 major and 33 minor sub-projects in progress (45 total), five sub-projects have been deferred, 21 sub-projects are inactive, and seven other sub-projects have not had any expenditures through the end of June 2016 for a total of 117 sub-projects.

Semi-Annual Progress Report

Final Report 2

Budget The LCM Original Budget, as filed, had an Estimate At Completion (EAC) of $948.8 million plus a management reserve of $220 million for a total of $1,168.8 million1, but did not include an Allowance for Funds Used During Construction (AFUDC). The Project was 58.87 percent complete based on the $688.1 million actual cost through June 30, 2016 compared to the LCM Original Budget of $1,168.8 million, which includes the LCM Management Reserve.

Schedule The current schedule for the Project shows a completion date of 2022. As reported in previous SAPRs, recent schedule changes pushed out the completion dates for eight sub-projects to 2019–2022. As of June 30, 2016, a total of 39 sub-projects have been completed. E3 is not overly concerned about the changing sub-project schedules because rescheduling does not have a significant cost impact since it is usually limited to annual cost escalation.

Project Management We are pleased to report that the LCM Team’s management is challenging the project managers, assistant project managers, and engineers to ensure that the budget allocations are being prudently spent, well-managed, and that the expenditures are necessary. They have also deferred or inactivated 26 sub-projects demonstrating the LCM Team’s strong management efforts to ensure that the LCM Project is accomplished at the lowest reasonable cost and in a prudent manner.

Conclusions Based on all of the information, cost reports, CVRs, EVRs, schedules, and PCRFs that we have reviewed, meetings we have attended, and site visits conducted, we have formed the following conclusions and opinions:

1. Based on the cost details and causes provided by the LCM Team, we concluded that the 39 completed sub-projects installed at 12.15 percent over their $282.8 million LCM Original Budget were well managed and that their cost variances were justified. We also found that the cost variances on the 31 CVRs (technically 33 since two sub-projects were combined) received were clearly documented and justified, six completed sub-projects did not require CVRs because their actual costs were within 10 percent of their LCM Original Budgets or no funds were spent on them.

1 It is understood by E3 that the LCM “Original Budget” of $1,168,842,000 has been reduced by $23,495,838 to a new total of $1,145,346,162 as a result of removing upsizing costs ($22,649,361) and Allowance For Funds Used During Construction costs for period July 1, 2011 through December 31, 2011 ($846,477). However, when reporting LCM status (such as variances, performance indicators, etc.) E3 will use the original baseline cost estimate for the LCM program and sub-projects, as filed in Exhibit TJB-5.


Final Report 3

2. There are 12 major sub-projects in progress with 68.01 percent of the $480.2 million LCM Original Budget spent through June 30, 2016.

However, the costs for the other 10 major sub-projects in progress are under their LCM Original Budget amount.

3. The 33 minor sub-projects in progress had an actual cost through June 2016 of $44.4 million, or 49.56 percent of their $89.6 million LCM Original Budget.

4. E3 is of the opinion that deferring the five deferred sub-projects with a total LCM Original Budget of $3.4 million should not have a material impact on the LCM Team’s ability to complete these sub-projects and it is expected that some of them will eventually be inactivated.

5. We are of the opinion that inactivating 21 sub-projects with a total LCM Original Budget of $69.4 million reflects sound judgement. Further review by the LCM Project management team determined that they may no longer be needed to achieve the goals of the LCM Project. Inactive sub-projects do not require CVRs. This is another indicator of the LCM Team’s strong managerial control of Project costs.

6. Another seven sub-projects with an LCM Original Budget of $23.6 million have not had any expenditures as of the end of June 2016.

7. The total sub-project costs through June 2016 were $688.1 million, representing 58.87 percent of the $1,168.8 million LCM Original Budget. On this basis, we conclude that the Project is 58.87 percent complete.

8. E3’s review of the cost information that is available for each of the LCM sub-projects revealed that the costs are well documented and include all of the necessary details.

9. We conclude that the LCM scheduling and cost management processes reflect the level of detail and management attention expected in the nuclear industry.

10. E3 is of the opinion that the Level One schedule is realistic, achievable, and reflects sound scheduling practices as required in the nuclear industry.

11. The CVRs for 31 (technically 33 since two were combined) of the completed sub-projects showed that the actual cost of these sub-projects was $33.3 million (12.9 percent) greater than the LCM forecast of $258.7 million. Six of the completed sub-projects had costs that were within 10 percent of their budgets and don’t require CVRs.

12. E3 is of the opinion that I&M’s system of using PCRF’s, EPRG, and Project Review Board (PRB) to control the Project’s cost is sound.

13. E3 has reviewed a total of 354 PCRFs and examined all of them with respect to schedule changes and found that the reasons provided were justified and based on sound planning practices.



Final Report 4

14. The planning and scheduling process integration with cost expenditures, particularly with EVR, has been implemented by the LCM Team to improve the process and provide better oversight of the Project’s progress versus cost and schedule. For the 15 EVRs provided to E3, five had Schedule Performance Indexes (SPI) and seven had Cost Performance Indexes (CPI) equal to or greater than 1.0 (favorable). The weighted average of the SPIs was 1.00 and the CPI was 1.03 indicating that on average the schedule for these 15 sub-projects is on schedule and the earned value is 3.0 percent greater than the actual cost. These CPIs and SPIs are an indicator of effective management by the LCM Team. Please note that this conclusion only applies to the 15 sub-projects that had EVRs prepared for them.

OVERVIEW Background

This September 2016 SAPR was prepared by E3 to provide our current assessment of the Project’s progress as of June 30, 2016 based on our observations, discussions, and review of all of the information gathered during the January 1 through June 30, 2016 period.

Objective The objective of this SAPR is to provide a six-month update on the current status of the Project as required by our Independent Monitoring Agreement (IM Agreement).

INDEPENDENT MONITORING The current status of E3’s IM services for the Project is discussed in the following paragraphs.

IM Project Cost E3’s IM project costs for the January 1 through June 19, 2016 period were $155,558, or 38.7 percent of the revised not-to-exceed annual budget of $402,000 for 2016.

Project Schedule E3’s activities as the IM included requesting and reviewing documents. We visited the Cook Plant on January 21, 2016 for a monthly progress meeting, plant tour, and EPRG meeting. The February 25, April 28, and June 1, 2016 monthly progress meetings were conducted by conference call. On March 31, 2016, we toured the Cook Plant and attended the monthly progress meeting. The June 30, 2016 monthly progress meeting was held in Denver covering progress through May.

Please note that since June 30, 2016, E3 participated in the LCM monthly progress meetings by phone on July 28, August 25, and September 19, 2016.


Final Report 5

Scope of Work and Changes E3, serving as the IM for I&M, IURC, and Michigan Public Service Commission (MPSC), conducted a multi-task review that focused on the cost and scheduling aspects of the Project to evaluate and explain any differences that may arise between the LCM Original Budget and the actual costs incurred for the Project related to the following causes:

I. Additions or changes in Project contracts/Project scope; II. Delays and/or suspensions of work;

III. Labor rates; IV. Labor productivity; V. Commodity material costs;

VI. Performance of the contractors; and VII. Any other changes that impact the costs of the LCM Project.

E3 also submits weekly project management reports that provide information on our past and planned activities to ensure we are on schedule and within budget, and that I&M is aware of progress and areas of concern.

There have been no changes to the SOW.

Deliverables E3 is to provide: 1) a Monthly Report (MR) listing findings on the SOW, 2) a SAPR every six months, 3) written reports as required, 4) participation in conference calls and regulatory proceedings, and 5) all other requirements stated in the IM Agreement.

During the first half of 2016, we submitted MRs for December 2015, and February and March 2016 reflecting progress through the prior month. We did not issue a MR for January (showing progress through December 2015) because that period was included in the March 2016 SAPR that was submitted to the IURC.

Since June 30, we submitted MRs for April, May, and June 2016.

Written testimony was provided on the March 2016 SAPR; however, verbal testimony was not required before the IURC because their staff and staff of the Indiana Office of Utility Consumer Counselor’s office did not have additional questions.

Actual and Planned Actions E3 participated in six monthly LCM meetings and toured the CNP twice in the first half of 2016. E3 visited the CNP on January 21 and March 31, 2016 during the U1C27 spring outage.

During the second half of 2016, we plan to participate in six monthly progress meetings (five through conference calls, and one on site visit in October with the LCM team). Weekly project management reports will also be submitted to keep the LCM Team advised on IM Project costs, schedule, and progress.


Final Report 6

CURRENT PROJECT STATUS Sub-Projects Completed

As of June 30, 2016, a total of 39 sub-projects have been completed as shown in Table 1.

During the January 1 through June 30, 2016 period, two sub-projects were completed: Line No. 38, PRF040467 and Line No. 40, PRF040301. Please note that Line No. 48 has been combined with Line No. 30 as one sub-project, and Line No. 43 was combined with Line No. 21, so technically 37 sub-projects have been completed. However, we continue to list these four sub-projects so that we can maintain the same total number of sub-projects as in the LCM filings with the two commissions.


Final Report 7

Table 1 LCM Projects Completed

Line LCM Sub-Project PRF No. In-Service Date 1

1 U2 Generator Step-Up Transformer 040174 05/2012 2 2 U2 Iron Filtration 110060 04/2012 3 5 U2 ESW Pump Motor (2-PP-7E/7W) 080073 05/2012 4 6 765kV Breaker 2-52-A2 040478 04/2012 5 8 U1 CEQ Fan Motor Coolers 100073 10/2014 6 9 U2 CEQ Fan Motor Coolers 120048 04/2015 7 11 Security UPS and Battery Chargers 080131 01/2014 8 13 U2 Feedwater Heaters (LP) – 4A/4B 040464 11/2013 9 14 U2 Control Room Chiller (HVAC) 110002 01/2015

10 15 U1 Plant Process Computer 040069 10/2013 11 16 U2 Plant Process Computer 040068 12/2013 12 17 U1 Control Room Annunciator 040065 04/2013 13 18 U2 Control Room Annunciator 040064 10/2013 14 19 U1 Unit Auxiliary Transformers 040196 05/2013 15 20 U2 Unit Auxiliary Transformers 040198 11/2013 16 21 Ice Machine and Glycol Chillers (with line #43) 040034 03/2015 17 22 U1 West Containment Spray HX 110008 10/2014 18 23 RPAC Renovation 080095 09/2014 19 27 765kV Breaker 2-52-B2 040479 11/2013 20 28 34kV Circuit Breaker – BC Breaker 110031 11/2013 21 29 34kV Circuit Breaker – BE Breaker 040480 05/2013 22 30 34.5/4kV Cables (with line #48) 040111 05/2014 23 34 U2 Main Generator Hydrogen System 040460 11/2013 24 35 U1 Seismic Monitoring System 040439 11/2013 25 36 U2 Seismic Monitoring System 110105 11/2013 26

38 U1 Feedwater Heaters HP – 5A/5B/6A/6B 040467 5/2016

27 39 U1 Control Room Chiller (HVAC) 040033 03/2015 28 40 U1 East Containment Spray Heat Exchanger 040301

4/2016

29 43 Ice Condenser Sys (Transport/ Bins) (with line #21) 090189 03/2015 30

44 #23 Reactor Coolant Pump (RCP) 140060 05/2015 31 45 Transformer 7 050011 12/2014 32 46 Public Address System 060050 12/2014 33 48 34.5/4kV Cables (with line #30) 040111 05/2014 34 56 U1 Condensate Polishers (SWCIP) 070114 10/2014 35 57 U2 Condensate Polishers (SWCIP) 080001 09/2014 36 63 69kV Switchyard EP-Line 040499 12/2014 37 84 U1 Feedwater Heater Digital Controls 110090 01/2015 38 98 U1/U2 7.5 Ton Carbon Dioxide System 040518 07/2014 39 101 U2 Feedwater Heater Digital Controls 110091 08/2014

Notes: CEQ – Containment Pressure Equalization Fans ESW – Essential Service Water


Final Report 8

HX – Heat Exchanger HVAC – Heating, Ventilating, and Air Conditioning LP – Low Pressure SWCIP – Secondary Water Chemistry Improvement Project UPS – Uninterruptable Power Supply

Sub-Projects in Progress Since January 1, 2016, no additional major sub-projects have been started and one was completed, Line No. 38, PRF040467.

There are 12 major and 33 minor sub-projects in progress for a total of 45. Major sub-projects have an LCM Forecast cost of $10 million or greater.

The following paragraphs provide some detail on the major sub-projects that are in progress.

1. Line No. 12, PRF040465 – U2 HP Feedwater Heaters (FW) 6A/6B were installed during U2C22 , while 5A/5B are scheduled for U2C24

2. Line No. 41 PRF040139 – U1 Steam Generator Water Level Controls are scheduled for U1C28

3. Line No. 50, PRF080060 – Technical Support Center and North Access Buildings is continuing with engineering, and major construction is anticipated to resume in

4. Line No. 53 PRF040140 – U2 Steam Generator Water Level Controls are scheduled for U2C24

5. Line No. 55, PRF110093 – U2 LP and HP Turbine Replacement is scheduled for replacement during U2C23

6. Line No. 74, PRF040487 – U1 Radiation Monitoring System is scheduled for completion in

7. Line No. 75, PRF040486 – U2 Radiation Monitoring System is scheduled for completion in

8. Line No. 89, PRF040250 – U1 Reactor Protection System (RPS)/Engineering Safety Features Actuation System (ESFAS) is scheduled for installation during U1C29

and U1C30

9. Line No. 90, PRF120032 – U1 Spec 200 is scheduled for installation during U1C30 and U1C31

10. Line No. 99, PRF090253 – U2 Moisture Separator Reheater (MSR) Digital Controls is scheduled for installation during U2C24 .



Final Report 9

11. Line No. 106, PRF040248 – U2 RPS / ESFAS is scheduled for installation during U2C25 and U2C26

12. Line No. 107, PRF120033 – U2 Spec 200 is scheduled for installation during U2C26 and U2C27 in

Please note that five Non-Essential Service Water (NESW) sub-projects have been combined into two sub-projects for ease of tracking as follows:

• Line 58, PRF040491 now includes Line 59, PRF040489 and Line 72, PRF060002.

• Line 70, PRF040492 now includes Line 71, PRF060001.

In addition, Line 24, PRF110084 now includes Line 25, PRF110085.

BUDGET E3’s budget comparison is based on the Project’s June 30, 2016 Budget compared to the LCM Original Budget as discussed in the following paragraphs.

LCM Original Budget The LCM Original Budget of $1,168.8 million includes the total estimated cost for the 117 sub-projects of $948.8 million plus a management reserve of $220.0 million.

June 2016 Budget The June 30, 2016 Budget in Table 2 shows the current LCM cost status. To date, the actual cost of the sub-projects is $688.1 million.

June 2016 Budget vs. LCM Original Budget Attachment 1, at the end of this SAPR, shows the actual expenditures for each of the sub-projects through June 30, 2016. We have summarized these costs for the sub-projects on Table 2 and have grouped them into six categories: 1) completed sub-projects, 2) major sub-projects in progress, 3) minor sub-projects in progress, 4) deferred sub-projects, 5) inactive sub-projects, and 6) sub-projects with no expenditures through June 30. Through June 30, 2016, $688.1 million of the $1,168.8 million (58.87 percent) has been spent, while $428.1 million remains to be spent as shown on line 64 of Table 2.

The Original Budget’s $220.0 million management reserve has been reduced by two uses: 1) the $38.3 million Feedwater Heater Structural Impacts, and 2) the $14.4 million U2 Heater Drain Pump Discharge Valves as shown on Attachment 1 at the bottom of page 2. Thus, the available, remaining management reserve is $167.3 million shown near the bottom of page 3.

Sub-Projects Completed The actual cost of the 39 completed sub-projects was $317.1 million compared to the LCM Original Budget of $282.8 million (12.15 percent over) as shown in Table 2. Eleven of the



Final Report 10

completed sub-projects shown in Table 2 were over their LCM Original Budget (from 14.31 to 232.40 percent), while the others were completed at 24.52 to 98.98 percent of their LCM Original Budget.

Sub-Projects in Progress As shown in Table 2, we have selected 12 major sub-projects in progress to report on (major sub-projects have an LCM Original Budget greater than $10 million) and have grouped the remaining 33 minor sub-projects in progress into one figure. There are a total of 45 sub-projects in progress through June 2016. The 12 major sub-projects had a total cost of $326.6 million, which is 68.01 percent of the Total LCM Forecast or LCM Original Budget of $480.2 million.

All of the other 10 major sub-project costs in progress are under their LCM Original Budget at this time.

The 33 minor sub-projects in progress had an actual cost through June 2016 of $44.4 million or 49.56 percent of their LCM Original Budget of $89.6 million.



Final Report 14

Cost Variance Reports CVRs are provided to E3 whenever a completed sub-project’s actual cost varies from the LCM Forecast (as filed) by more than 10 percent, over or under. Inactive sub-projects do not require CVRs. Table 5 shows that E3 has received 31 CVRs and it summarizes the details of each. The CVRs document the reasons for the cost variances and identify their primary causes (seven). They also describe the lessons learned from the sub-project’s cost variances. Based on the details provided, and our review of these details and causes provided, we concluded that the 31 (technically 33 since four were combined into two sub-projects) completed sub-projects were well managed and that their cost variances were justified. Attachment 2 lists all sub-projects and shows the details for each of the CVRs. We have also shown on Attachment 2 that six of the completed sub-projects (Line Nos. 2, 5, 19, 20, 39, and 63) did not require CVRs because their actual costs were within 10 percent of their LCM Original Budget.

These 31 CVRs documented the cost details and the $33,305,518 (12.9 percent) cost variances and assigned them to the seven cause categories defined in Attachment D of E3’s IM Contract as summarized in Table 6. Please note that the cost variances shown in Tables 2 and 6 may be different because the CVRs are not updated for actual closing costs, which are usually minimal, while Table 2 shows the total actual cost.


Final Report 15

Table 5 Cost Variance Report Summary



Final Report 16

Table 6 Causes of Cost Variances

Table 6 indicates that the contract or scope of work caused -73.16 percent of the cost variances, which were offset by delays 7.36 percent, materials 3.51 percent, contractor performance 7.27 percent, and other causes such as risk mitigation, rework, inadequate estimate, or field changes 154.04 percent. Attachment 2, page 3, shows that the total cost variance for the 31 completed sub-projects was $33,305,518.

E3’s review of the cost information that is available for each of the LCM sub-projects revealed that the costs are well documented and include all of the necessary details. We also found that the cost variances for the 31 CVRs received through August 2016 were well documented and justified.

Project Change Request Forms I&M has a formal PCRF system that it uses for monitoring, controlling, documenting, and tracking changes in sub-project scope, schedule, budget, or cost that have been made since the LCM filing.

It should be noted that I&M implements multiple formal review processes to manage sub-project funding. When sub-projects change phases, they are required to go through the PRB. If the sub-project’s cost is greater than $500,000, it must be reviewed by the EPRG, which is comprised of CNP Senior Management. If a sub-project’s total cost changes, the cost changes must be approved by the I&M Subsidiary Company Board, consisting of American Electric Power (AEP) executives and the President of I&M, in order to increase its Capital Improvement Requisition (IR) amount. The CNP Projects organization holds weekly and monthly financial reviews of all ongoing LCM sub-projects.

E3 attended the January 21, 2016 EPRG meeting during which three LCM sub-projects were discussed along with two other non-LCM presentations: 1) Line No. 38 U1 6A/6B HP Feedwater Replacement phase change from 2B - Detailed Engineering and Design to 3 – Implementation was discussed and approved, 2) Line No. 24 U1 Blowdown Recovery phase change from 2A to

A B CCause of Cost Changes $ x 1,000 Percent

1 Contract or Scope of Work (24,365) (73.16) 2 Delays 2,450 7.36 3 Labor Rates - - 4 Labor Productivity 326 0.98 5 Materials 1,169 3.51 6 Contractor Performance 2,421 7.27 7 Other 51,304 154.04

Total - $ 33,306 100.00


Final Report 17

2B and IR change were presented and approved, and 3) U1 East Containment Spray Heat Exchanger phase change from 2B to 3 and IR change were discussed and approved. We observed that top management was asking discerning questions on all of the presentations to make certain that the IR revisions and phase changes were reasonable and prudent.

E3 is of the opinion that I&M’s system of using PCRF’s, EPRG, and PRB to control the Project’s cost is sound.

E3 reviewed 354 PCRFs, and has identified them on Attachment 3. E3 also reviewed all of the PCRFs with respect to schedule changes and found that the reasons given were justified and based on sound planning practices.

SCHEDULE Attachment 4 is a Level One Schedule for the LCM sub-projects. Please note that the five deferred and 21 inactivated sub-projects are shown on this schedule in 2018. We know that the 21 inactivated sub-projects may not be undertaken and that the five deferred sub-projects will be further reviewed and some may be inactivated in the future.

E3 is of the opinion that the schedule shown in Attachment 4 is realistic, achievable, and reflects sound scheduling practices as required in the nuclear industry.

Earned Value Reports The planning and scheduling process integration with cost expenditures, particularly with earned value management, which combines scope, schedule, and resource measurements to assess sub-project performance and progress2 has been implemented by the LCM Team to improve the process and provide better oversight of the Project’s progress versus cost and schedule. Figure 1 is an example of the EVR for the U2 LP and HP Turbine Replacement, which is the largest LCM sub-project that is currently scheduled for installation during U2C23 (Fall 2016). Please note that the actual figures in red for July 2016 onward are projections.

2 A Guide to Project Management Body of Knowledge (PMBOK® Guide), Fifth Edition, ANSI, p538.


Final Report 20

PROJECT MANAGEMENT We are pleased to report that the LCM Team’s management is challenging the project managers, assistant project managers, and engineers to ensure that the budget allocations are being prudently spent, well-managed, and that the expenditures are necessary.

We note that 26 sub-projects have been deferred or inactivated as mentioned above. This is another sign of the LCM Team’s strong management efforts to ensure that the LCM Project is accomplished at the lowest reasonable cost and in a prudent manner.


Final Report 21

ATTACHMENT 1 – LCM PROJECT – FORECAST OF SUB-PROJECT COSTS

ATTACHMENT 1 CONTAINS CONFIDENTIAL INFORMATION

CONFIDENTIAL-SUBJECT TO PROCTIVE ORDER ISSUED JUNE 5, 2012 IN CASE NO. U-17026 ATTACHMENT 1 (Public)


Final Report 22

ATTACHMENT 2 – COST VARIANCE REPORTS SUMMARY


Attachment 2E3 Consulting

Donald C. Cook LCM Independent Monitoring

CONFIDENTIAL-SUBJECT TO PROCTIVE ORDER ISSUED JUNE 5, 2012 IN CASE NO. U-17026 (Public Version)


Final Report 23

ATTACHMENT 3 – PROJECT CHANGE REQUEST FORMS REVIEWED

10/3/2016 11:58 AM Attachment 3.xls 1 of 11

A B C D

Sub-Project I&M Total No. Sub-Project Number PCRF No. Approved

1 1 U2 Generator Step-Up (GSU) Transformer PRF0401742 1 12/16/20113 2 12/16/20114 2 U2 Iron Filtration PRF1100605 1 12/16/20116 2 2/22/20127 3 U1 Fuel Transfer Equipment PRF0401858 1 3/13/20149 2 6/11/2014

10 3 6/4/201511 4 9/1/201512 5 1/26/201613 6 6/15/201614 4 U2 Fuel Transfer Equipment PRF04018815 1 3/13/201416 2 6/11/201417 3 6/4/201518 4 9/1/201519 5 1/26/201620 6 6/15/201621 5 U2 Essential Service Water (ESW) Pump Motor (2-PP-7E/7W) PRF08007322 6 765KV Breaker (BKR) 2-52-A2 Replace PRF04047823 7 U2 Emergency Core Cooling System (ECCS) Pump Coolers PRF10008824 1 11/8/201325 2 3/26/201426 3 4/23/201427 4 2/11/201528 5 2/24/201629 8 U1 Containment Air Recirculation/Hydrogen Skimmer (CEQ) Fan Motor Coolers PRF10007330 1 11/8/201331 2 9/5/201432 9 U2 Containment Air Recirculation/Hydrogen Skimmer (CEQ) Fan Motor Coolers PRF12004833 1 11/8/201334 2 9/5/201435 3 12/4/201436 10 U1 Main Generator Seal Oil Pumps PRF04052537 1 9/16/201438 11 Security Uninterruptible Power Supply (UPS) Inverter and Battery Chargers PRF08013139 12 U2 Feedwater Heaters High Pressure (HP) - 5A/5B/6A/6B PRF040465 * 7/30/201540 1 1/12/201241 2 7/27/201242 * 12/21/201143 3 11/16/201244 4 2/6/2014


Donald C. Cook LCM Independent MonitoringList of LCM Project Change Request Forms Reviewed


A B C D




45 5 2/20/201446 6 2/6/201447 7 5/29/201448 8 5/29/201449 9 9/8/201450 10 1/13/201551 11 1/16/201552 12 2/5/201553 13 2/12/201554 14 2/12/201555 15 3/3/201556 16 3/13/201557 17 4/30/201558 18 4/30/201559 19 4/30/201560 20 6/15/201661 13 U2 Feedwater Heaters Low Pressure (LP) - 4A/4B PRF04046462 1 3/22/201363 2 5/29/201464 14 U2 Control Room Chiller (HVAC) PRF11000265 1 2/12/201566 2 9/3/201567 3 12/14/201568 4 2/11/201669 15 U1 Plant Process Computer (PPC) Replacement PRF04006970 2 6/1/201271 3 2/15/201372 4 1/11/201273 5 1/11/201274 6 3/18/201375 7 3/18/201376 8 4/12/201377 9 5/14/201378 10 6/11/201379 16 U2 Plant Process Computer (PPC) Replacement PRF04006880 1 2/15/201381 2 3/18/201382 3 3/18/201383 4 2/15/201384 5 5/14/201385 6 6/11/201386 17 U1 Control Room Annunciator System Replacement PRF04006587 2 6/1/201288 3 8/22/201289 4 9/6/2012


A B C D




90 5 10/8/201291 6 9/27/201292 7 10/8/201293 8 10/23/201294 9 11/8/201295 10 3/7/201396 18 U2 Control Room Annunciator System Replacement PRF04006497 1 8/22/201298 2 3/7/201399 3 5/15/2013

100 19 U1 Unit Auxiliary Transformers (UATs) TR1AB/TR1CD PRF040196101 1 12/8/2011102 2 2/1/2012103 3 4/4/2012104 5 9/13/2012105 6 2/27/2014106 20 U2 Unit Auxiliary Transformers (UATs) TR2AB/TR2CD PRF040198107 2 7/18/2012108 21 Ice Machine and Glycol Chillers PRF040034109 1 12/16/2011110 2 1/18/2012111 3 2/15/2013112 4 2/12/2015113 PCRF Rejected 5 2/16/2015114 22 U1 West Containment Spray (CTS) Heat Exchanger (HX) PRF110008115 1 12/20/2013116 2 5/21/2014117 23 Radiation Protection Access Control (RPAC) Renovation PRF080095118 1 11/19/2013119 2 2/11/2014120 3 6/19/2014121 4 1/8/2015122 24 U1 Blowdown Recovery PRF110084123 1 4/4/2014124 2 7/23/2015125 3 9/17/2015126 4 7/13/2016127 5 7/28/2016128 * 12/20/2013129 * 7/30/2015130 25 U2 Blowdown Recovery PRF110085 * 12/20/2013131 1 4/4/2014132 26 Drumming Room HVAC PRF040421133 1 9/16/2014134 27 765KV Breaker (BKR) 2-52-B2 Replace PRF040479


A B C D




135 1 6/18/2013136 2 12/6/2013137 28 34kV Circuit Breakers - BC Breakers PRF110031138 1 12/6/2013139 29 34kV Circuit Breakers - BE Breakers PRF040480140 30 U2 34.5/4kV Cables PRF040111141 1 9/13/2012142 2 4/25/2013143 3 7/30/2013144 4 9/11/2013145 5 2/27/2014146 31 U1 Emergency Core Cooling System (ECCS) Pump Coolers PRF100087147 1 11/8/2013148 2 3/24/2015149 3 9/17/2015150 32 Turbine Room Sump PRF055096151 1 5/7/2015152 2 2/24/2016153 33 U1 Main Generator Hydrogen Gas System (Purity Meters) PRF040461154 1 11/12/2013155 2 8/26/2014156 3 2/11/2016157 4 9/27/2016158 34 U2 Main Generator Hydrogen Gas System (Purity Meters) PRF040460159 1 11/12/2013160 35 U1 Seismic Monitoring System PRF040439161 1 12/12/2012162 2 9/4/2013163 36 U2 Seismic Monitoring System PRF110105164 1 12/12/2012165 2 9/4/2013166 37 Emergency Diesel Generator (EDG) Load Bank PRF110048167 38 U1 Feedwater Heaters High Pressure (HP) - 5A/5B/6A/6B PRF040467168 1 7/27/2012169 2 8/7/2012170 3 2/12/2013171 4 3/22/2013172 5 9/30/2013173 6 10/28/2013174 7 2/3/2014175 8 5/29/2014176 9 5/29/2014177 10 5/29/2014178 11 5/29/2014179 12 6/18/2014


A B C D




180 13 9/8/2014181 14 2/12/2015182 15 3/3/2015183 16 3/3/2015184 17 4/30/2015185 18 4/30/2015186 19 9/17/2015187 20 9/17/2015188 21 9/17/2015189 22 10/15/2015190 23 10/15/2015191 24 10/12/2015192 25 10/29/2015193 26 10/29/2015194 27 10/29/2015195 28 10/29/2015196 39 U1 Control Room Chiller (HVAC) PRF040033197 1 5/7/2015198 40 U1 East Containment Spray (CTS) Heat Exchanger (HX) PRF040301199 1 12/10/2013200 2 4/10/2014201 3 6/11/2015202 4 10/1/2015203 5 11/24/2015204 6 2/11/2016205 41 U1 Steam Generator (SG) Water Level Controls PRF040139206 1 8/21/2012207 2 3/21/2013208 3 3/14/2013209 4 10/28/2013210 5 7/29/2014211 6 1/14/2015212 7 8/13/2015213 42 U1 Turbine Driven Auxiliary Feed Pump (TDAFP) Governor PRF040236214 1 10/23/2012215 2 2/13/2013216 43 Ice Condenser System (Transport & Bins) PRF090189217 44 #23 Reactor Coolant Pump (RCP) Motor PRF070215218 45 Transformer 7 PRF050011219 1 2/4/2014220 2 2/27/2014221 3 8/8/2014222 4 2/5/2014223 46 Public Address System PRF060050224 1 9/16/2014


A B C D




225 2 2/11/2015226 47 34kV Circuit Breakers - 12 AB Breaker PRF110032227 1 9/10/2013228 2 7/24/2014229 3 2/11/2016230 48 34.5/4kV Cables - see Line No. 30 PRF040111231 49 Emergency Power Cable PRF110025232 1 1/22/2014233 2 4/25/2014234 50 Technical Support Center (TSC) and North Access Buildings PRF080060 * 7/30/2015235 1 2/11/2014236 2 3/21/2014237 3 5/2/2014238 4 6/2/2014239 5 7/15/2015240 6 3/13/2015241 7 1/29/2016242 8 1/27/2016243 9 3/16/2016244 10 9/14/2016245 51 U2 East Containment Spray (CTS) Heat Exchanger (HX) PRF040300246 1 12/10/2013247 2 4/10/2014248 3 6/11/2015249 4 10/1/2015250 5 9/14/2016251 52 U2 West Component Cooling Water (CCW) Heat Exchanger (HX) PRF110007 * 7/30/2015252 1 5/28/2013253 2 4/12/2013254 3 8/6/2015255 53 U2 Steam Generator (SG) Water Level Controls PRF040140256 1 8/27/2012257 2 3/21/2013258 3 3/21/2013259 4 10/28/2013260 5 7/29/2014261 6 1/14/2015262 7 8/13/2015263 8 6/8/2016264 54 U2 Turbine Driven Auxiliary Feed Pump (TDAFP) Governor PRF040235265 1 10/23/2012266 2 2/12/2013267 55 U2 Low Pressure (LP) and High Pressure (HP) Turbines PRF110093268 1 11/12/2012269 2 10/28/2013


A B C D




270 3 2/4/2014271 4 12/17/2013272 5 12/18/2014273 6 7/16/2015274 7 7/17/2015275 8 8/7/2015276 9 9/1/2015277 10 9/1/2015278 11 9/15/2015279 12 9/15/2015280 13 9/15/2015281 14 10/1/2015282 15 1/26/2016283 16 5/4/2016284 17 5/4/2016285 18 5/16/2016286 19 7/13/2016287 20 7/28/2016288 21 9/21/2016289 56 U1 Condensate Polishers PRF070114290 1 12/16/2011291 2 7/18/2012292 3 3/12/2013293 4 10/22/2013294 5 7/22/2014295 6 1/29/2015296 7 6/4/2015297 57 U2 Condensate Polishers PRF080001298 1 12/16/2011299 2 7/18/2012300 3 3/12/2013301 4 10/22/2013302 5 7/22/2014303 58 U2 Non-Essential Service Water (NESW) Pumps PRF040491304 1 3/3/2015305 2 7/28/2016306 59 U2 Non-Essential Service Water (NESW) Pump Motors PRF040489307 1 3/3/2015308 60 34kV Grounding Transformers TR-3 PRF090186309 1 7/24/2014310 2 2/11/2016311 61 EP1 and EP2 Transformers PRF090184312 1 6/4/2015313 PCRF Rejected 2 2/24/2016314 3 3/7/2016


A B C D




315 62 34kV Circuit Breakers - 12 CD Breaker PRF110033316 1 7/24/2014317 63 69kV Switchyard EP-Line PRF040499318 1 11/8/2013319 2 2/4/2014320 3 8/8/2014321 64 U2 Heater Drain Pump (HDP) Discharge Valves (2-CRV-251,252,253) PRF090230322 1 1/6/2015323 2 6/1/2015324 3 9/4/2015325 65 U2 West Containment Spray (CTS) Heat Exchanger (HX) PRF110009326 1 12/10/2013327 2 4/10/2014328 3 6/11/2015329 4 10/1/2015330 5 6/2/2016331 6 9/14/2016332 66 U1 West Component Cooling Water (CCW) Heat Exchanger (HX) PRF110006333 2 4/12/2013334 * 7/30/2015335 3 8/6/2015336 67 U2 East Component Cooling Water (CCW) Heat Exchanger (HX) PRF040154337 1 5/28/2013338 2 4/12/2013339 * 7/30/2015340 3 8/6/2015341 68 U1 East Component Cooling Water (CCW) Pump PRF040181342 1 9/16/2014343 69 U2 East Component Cooling Water (CCW) Pump PRF040180344 1 9/16/2014345 70 U1 Non-Essential Service Water (NESW) Pumps PRF040492346 1 3/3/2015347 2 7/28/2016348 71 U1 Non-Essential Service Water (NESW) Strainer PRF060001349 1 3/3/2015350 72 U2 Non-Essential Service Water (NESW) Strainer PRF060002351 1 3/3/2015352 73 34kV Grounding Transformers TR-6 PRF090185353 1 7/24/2014354 74 U1 Radiation Monitoring System (RMS) PRF040487355 1 7/18/2013356 2 7/8/2014357 3 9/14/2016358 75 U2 Radiation Monitoring System (RMS) PRF040486359 1 7/18/2013


A B C D




360 2 7/8/2014361 3 9/14/2016362 76 U1 Regenerative Heat Exchanger (HX) PRF100089 * 12/20/2013363 1 9/16/2014364 77 U1 Exciter Air Bridge Rectifiers PRF070119365 1 12/4/2014366 2 7/6/2015367 * 7/30/2015368 4 12/11/2015369 5 5/18/2016370 78 U1 250DC Ground Detection System PRF060081 * 12/20/2013371 1 9/16/2014372 79 U1/U2 Plant Air Compressor PRF040136 * 12/20/2013373 1 9/16/2014374 80 U1 N-Train Battery Chargers PRF120030375 1 7/31/2014376 2 1/29/2015377 3 7/30/2015378 81 U2 N-Train Battery Chargers PRF120031379 1 7/31/2014380 2 1/29/2015381 3 7/30/2015382 82 U1 Moisture Separator Reheater (MSR) Digital Controls PRF040472383 1 3/13/2015384 83 U1 East Component Cooling Water (CCW) Heat Exchanger (HX) PRF040155 * 7/30/2015385 1 5/29/2013386 2 4/12/2013387 3 8/6/2015388 84 U1 Feedwater Heater Digital Controls PRF110090389 1 5/29/2014390 85 U1 Main Generator Exciter PRF040522391 1 9/16/2014392 86 U1 West Component Cooling Water (CCW) Pump PRF110094393 1 9/16/2014394 87 250 VDC Contactors Obsolete PRF040877395 1 7/30/2015396 2 12/14/2015397 88 U1 Control Room Recorders - Phase III PRF040105398 1 5/28/2015399 2 9/3/2015400 3 12/14/2015401 4 2/11/2016

402 89U1 Reactor Protection System (RPS) / Engineered Safety Features Actuation System (ESFAS)

PRF040250

403 * 7/30/2015


A B C D




404 90 U1 Spec 200 (Reactor Protection System Input/Output Modules) PRF120032405 1 3/5/2013406 * 7/30/2015407 91 U1 Fire Detection Alarm PRF080053 * 12/20/2013408 1 1/14/2015409 2 5/4/2016410 92 U2 Fire Detection Alarm PRF080054 * 12/20/2013411 1 1/14/2015412 2 5/4/2016413 93 U1 Polar Crane PRF040578 * 12/20/2013414 1 2/12/2015415 2 5/7/2015416 3 10/29/2015417 4 6/7/2016418 94 U1 Retube Generator Stator Water Coolers PRF040456419 1 9/16/2014420 95 U1 Generator Exciter Cooler PRF040458421 1 9/16/2014422 96 U1 Control Room Instrumentation Distribution (CRID) Inverters PRF040425423 1 9/16/2014424 97 Nitrogen (N2) Bulk Storage Tank PRF040164425 1 9/16/2014426 98 U1/U2 7.5 Ton Carbon Dioxide (CO2) System PRF040518427 99 U2 Moisture Separator Reheater (MSR) Digital Controls PRF090253428 1 3/13/2015429 100 U2 Moisture Separator Reheater (MSR) Valve and Piping Optimization PRF090254430 101 U2 Feedwater Heater Digital Controls PRF110091431 1 5/29/2014432 102 U2 Main Generator Exciter PRF040521433 1 9/16/2014434 103 U2 West Component Cooling Water (CCW) Pump PRF110095435 1 9/16/2014436 104 4kV/600 VAC Cables PRF040113437 1 1/22/2014438 2 4/25/2014439 3 2/12/2015440 4 9/8/2015441 105 U2 Control Room Recorders - Phase III PRF110102442 1 5/21/2015443 2 9/3/2015444 3 12/14/2015445 4 2/11/2016

446 106U2 Reactor Protection System (RPS) / Engineered Safety Features Actuation System (ESFAS)

PRF040248

447 * 7/30/2015


A B C D




448 107 U2 Spec 200 (Reactor Protection System Input/Output Modules) PRF120033449 * 7/30/2015450 108 U2 Regenerative Heat Exchanger (HX) PRF100090451 1 9/16/2014452 109 U2 Polar Crane PRF040579453 1 2/12/2015454 2 5/7/2015455 3 10/29/2015456 4 6/7/2016457 110 U2 Retube Generator Stator Water Coolers PRF040452458 1 9/16/2014459 111 U2 Generator Exciter Cooler PRF040454460 1 9/16/2014461 112 U2 Control Room Instrumentation Distribution (CRID) Inverters PRF070173462 1 9/16/2014463 113 AMSAC Inverters PRF040232464 1 9/16/2014465 114 U1/U2 17 Ton Carbon Dioxide (CO2) System PRF040519466 115 Emergency Diesel Generator (EDG) Fuel Oil Storage Tank PRF040336467 1 9/16/2014468 116 Emergency Diesel Generator (EDG) Fuel Oil Storage Tank PRF040335469 1 9/16/2014470 117 Weather Tower PRF120043471 1 3/16/2016471 Total PCRF Issued 354

Note: * - PRF080113


Final Report 24

ATTACHMENT 4 – LEVEL 1 LCM PROJECT SCHEDULE


LCM Projects

LCM-6

Level 1 LRP 17-Aug-16 13:49

CONFIDENTIAL-SUBJECT TO PROCTIVE ORDER ISSUED JUNE 5, 2012 IN CASE NO. U-17026 ATTACHMENT 4 (Public)


Final Report 25

ATTACHMENT 5 – SITE PHOTOS

New U2 Turbine Rotors on train cars, 1 HP and 3 LP, entering the Cook Nuclear Plant site

New U2 HP Turbine Rotor on left and Upper Shell being staged for assembly

E3: ATTACHMENT 5

New U2 LP Turbine Rotor on left and Lower Inner Casing staged for assembly

New U2 LP Upper Inner Casing being staged for assembly near U1

E3: ATTACHMENT 5

L-1 and L-0 Blade Installation Complete on New U2 LP Turbine Rotor

New U2 LP Turbine Rotor Completely Bladed

E3: ATTACHMENT 5

New U2 HP Feedwater Heater 6B Staged for Installation

Technical Support Center/North Access Building with Floor in Place

E3: ATTACHMENT 5

indiana michigan power company donald c. cook …

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