IR 05000341/2015007

NRC Problem Identification and Resolution Inspection Report 05000341/2015007, November 30, 2015, Through December 18, 2015

ML16032A591
Person / Time
Site:	Fermi
Issue date:	01/29/2016
From:	Billy Dickson NRC/RGN-III/DRP/B5
To:	Fessler P DTE Electric Company
References
IR 2015007
Download: ML16032A591 (36)

Text

UNITED STATES ary 29, 2016

SUBJECT:

FERMI-2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000341/2015007

Dear Mr. Fessler:

On December 18, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Fermi-2 facility. The enclosed inspection report documents the inspection results, which were discussed at the exit meeting on December 18, 2015, with Mr. M. Philippon and other members of your staff.

The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the samples selected for review, the team concluded that the corrective action program (CAP) at Fermi-2 was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP.

A qualitative risk and uncertainty based approach was used to determine the significance of the issues, the priority and the method for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance.

Operating experience was entered into the CAP when appropriate and evaluated according to the corrective action program requirements. The use of operating experience was integrated into daily activities and was generally effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments. The assessments and audits reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Fermi-2. Licensee staff was generally aware of and familiar with the CAP and other station processes, including the employee concerns program, through which concerns could be raised. The team determined that your stations performance in each of these areas supported nuclear safety. Based on the results of this inspection, one NRC identified finding of very low safety significance (Green) was documented in this report. The finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III and the NRC resident inspector at the Fermi-2.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Billy Dickson, Chief Branch 5 Division of Reactor Projects Docket No. 50-341 License No. NPF-43

Enclosure:

Inspection Report No. 05000341/2015007

REGION III==

Docket Nos: 50-341 License Nos: NPF-43 Report No: 05000341/2015007 Licensee: DTE Electric Company Facility: Fermi-2 Location: Newport, MI Dates: November 30, 2015, through December 18, 2015 Team Leader: R. Ng, Project Engineer Inspectors: P. Smagacz, Resident Inspector T. Bilik, Senior Reactor Inspector R. Baker, Operations Engineer Approved by: B. Dickson, Chief Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000341/2015007; 11/30/2015-12/18/2015; Fermi-2; Identification and

Resolution of Problems.

This inspection was performed by three region-based inspectors and the Fermi Resident Inspector. One Green finding was identified by the inspectors. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310; Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of the U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.

Identification and Resolution of Problems Based on the samples selected for review, the team concluded that the corrective action program (CAP) at Fermi-2 was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP.

A qualitative risk and uncertainty based approach was used to determine the significance of the issues, the priority and the method for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance.

Operating experience was entered into the CAP when appropriate and evaluated according to the corrective action program requirements. The use of operating experience was integrated into daily activities and was generally effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments. The assessments and audits reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Fermi-2. Licensee staff was generally aware of and familiar with the CAP and other station processes, including the employee concerns program, through which concerns could be raised. The team determined that your stations performance in each of these areas supported nuclear safety.

Although implementation of the CAP was determined to be effective generally, the inspectors identified several issues that were minor violations and/or represented potential weaknesses of the program.

NRC-Identified

and Self-Revealed Findings Cornerstones: Initiating Events

Green.

The inspectors identified a finding of very low safety significance for the licensees failure to meet American Society of Mechanical Engineers (ASME) Code requirements to perform planned engineering lifts of loads that exceeded a hoists rated capacity.

Specifically, on September 25 and September 26, 2013, the licensee used the Unit 2 turbine building reactor feed pump monorail hoist to perform multiple lifts of floor plugs. The weight of the floor plugs exceeded the rated capacity of the hoist and the licensee did not follow the requirements of ASME Code B30.16, Section 16-3.4, Planned Engineered Lifts, for lifts in excess of the rated load. These requirements include, in part, inspections, calculations, test lifts, distances traveled, and record keeping and retention. The Code also limits the number of lifts to two within any continuous 12-month period without meeting additional requirements. The licensee captured this issue in their CAP as Condition Assessment Resolution Document (CARD) 15-30077. No violation of regulatory requirements was identified.

The performance deficiency was of more than minor safety significance because if left uncorrected, it would have the potential to lead to a more significant safety concern.

Specifically, if the hoist failed, and a heavy object were to fall through the turbine building hatch opening, it could cause a loss of condenser vacuum and subsequent plant trip or possibly a steam leak into the turbine building. The finding was of very low safety significance because it did not cause a reactor trip. The inspectors determined this finding affected the cross-cutting aspect of problem identification and resolution, evaluation (P.2)due to the failure of the organization to thoroughly evaluate issues to ensure resolutions address causes and extend of condition commensurate with their safety significance.

Specifically, the licensee failed to evaluate thoroughly the causes for not complying with ASME Code requirements once a lift exceeded a hoists rated capacity had occurred.

Therefore, effective corrective actions and an extent of condition were not identified.

(Section 4OA2.1.b.3.ii)

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of problem identification and resolution (PI&R) inspection as defined by Inspection Procedure 71152, Problem Identification and Resolution. Documents reviewed were listed in the Attachment to this report.

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the corrective action program (CAP) at Fermi-2 to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, were met. The inspectors observed and evaluated the effectiveness of meetings related to the CAP, such as the Condition Assessment Resolution Document (CARD) Ownership Screening Committee meeting and the Management Review Committee meeting. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the CAP.

The inspectors reviewed selected CARDs across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensees CAP. The majority of the risk-informed samples of CARDs reviewed were issued since the last NRC biennial PI&R inspection completed in November of 2013.

The inspectors also reviewed selected issues that were more than five years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, common cause evaluations and direct cause evaluations. The inspectors assessed the scope and depth of the licensees evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensees corrective actions to prevent recurrence and for less significant issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance.

The inspectors selected the preventive maintenance program to review in detail based on input from the resident staff. The preventive maintenance program covered both safety-related and nonsafety related systems and is a risk significant equipment management program. The primary purpose of this review was to determine whether the licensee was monitoring and correcting equipment performance issues at both the system and component levels. The inspectors reviewed the licensee staffs ability to characterize and resolve instances involving equipment unavailability or degradation, identified through operating experience or actual events, by effective revision or augmentation of the preventive maintenance program, as appropriate.

A five year review of the safety-related service water system was undertaken to assess the licensee staffs efforts in monitoring for age-related piping system degradation. The inspectors review was to determine whether the licensee staff was properly monitoring and evaluating the performance of the system through effective implementation of station monitoring program, such as identifying and correcting issues. The inspectors performed walkdowns, as needed, to verify the resolution of issues.

The inspectors examined the results of self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the licensees corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors performed walkdowns, as necessary, to verify the resolution of the issues.

The inspectors also reviewed the open corrective action items related to the Greater-than-Green security finding that were not completed by the end of the associated 95001 supplemental inspection (Inspection Report 05000341/2014408, ADAMS Accession Number ML15015A739).

b. Assessment

(1) Problem Identification Based on the results of the inspection, the inspectors concluded that, in general, the station was effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were identified and captured in a complete and accurate manner in the CAP. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the CAP for resolution.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors performed a five-year review of the safety related service water system.

The inspectors interviewed program owner and reviewed corrective action documents, inspection reports, inspection procedures, as well as quarterly NRC Generic Letter 89-13 and buried piping program health reports. The inspectors also reviewed a life-cycle management report prepared by Structural Integrity Associates, which discussed modeling of internal and external corrosion and water chemistry. The inspectors evaluated repair/replacement plans going forward and performed a partial system walkdown of visible parts of the system, including piping recently replaced, and a portion of the cathodic protection system.

The inspectors determined that there was an improving trend in the overall health of the program over the last five years. While outer diameter corrosion had been minimal, due in large part to the stations soil characteristics and a well-maintained cathodic protection system, internal corrosion was an ongoing issue. As a result, the licensee had implemented additional monitoring/inspections, water chemistry additions, computer modeling, cleaning, as well as ongoing repair/replacement of piping and system components. As such, the inspectors concluded that the licensee staff were properly monitoring and evaluating the performance of the system through effective implementation of the monitoring program and that internal corrosion degradation should improve.

i) Observations Change in Identification Rate During the previous PI&R inspection, the inspectors identified a negative trend related to self-identification rate compared to the outside identification rate. The licensee implemented a number of corrective actions to address that trend. The inspectors reviewed the licensees performance indicators during this inspection. The self-identification rate compared to the outside identification rate improved since the last PI&R inspection. The licensee continues to address the issue with training and group discussions, and the inspectors noted that management remains sensitive to the issue.

The inspectors also identified a small decline in CARD generation rates in the last five years. The licensee attributed that partially to process changes in how low level conditions were captured. The licensee continued to monitor the generation rates.

Based on a review of the issues reported in the CAP, the inspectors did not identify any issues affecting the overall effectiveness of the program. The licensee needed to be cognizant of this issue and to address the decline before it affected the CAP.

Effectiveness of the Preventative Maintenance Program The inspectors noted that the licensee recently became aware of, through both external agency assessments and internal self-assessments/equipment failures, shortcomings in their preventive maintenance program effectiveness. For example, CARD 15-22997, MES51 Does Not Define SPV/Single Point Vulnerabilities, identified a preventive maintenance program deficiency, which had resulted in a missed opportunity to preclude an unidentified single point vulnerability from initiating a significant event that challenged operators and subsequently led to an automatic scram. Also, CARD 15-23217, Self-Assessment Deficiency: Critical PM Deferral Process, and CARD 15-23701, NQA Audit Deficiency - MES51 Does Not Provide for Repeat Extension of PMs, were examples of internal processes that identified program deficiencies and led to exacerbate efforts to manage and resolve engineering backlogs.

Lastly, CARD 15-23465, Trip of RBHVAC, Autostart of Div. 1 SGTS and CCHVAC Auto Swap to Recirc, and CARD 15-23626, Loss of RPS B, were examples of missed opportunities to incorporate an effective revision or augmentation of the preventive maintenance program, based upon available industry operating experience events, potentially precluding equipment failures.

Additionally, the inspectors noted that external agency evaluations performed in 2015 also characterized the recent equipment failures potentially resulted from maintenance program strategies implemented at the time of the events. The licensee captured the highlights of these assessments in CARDs 15-25138 and 15-25139, and performed investigations to determine the underlying causes and corrective actions appropriate to resolve identified programmatic issues. The inspectors noted that the planned corrective actions to address programmatic issues would be implemented over the next calendar year. The inspectors considered this an improvement opportunity for the preventative maintenance program.

ii) Findings No findings were identified.

(2) Problem Prioritization and Evaluation Based on the results of the inspection, the inspectors concluded that the station was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk. In particular, the inspectors observed that the majority of the low level issues were either closed at a level appropriate for a condition evaluation or closed to a trend.

The inspectors determined that the CARD Ownership Screening Committee meetings and the Management Review Committee meetings were generally thorough and maintained a high standard for evaluation quality. Members of the committees discussed selected issues in sufficient detail and challenged each other regarding their conclusions and recommendations. The inspectors did not identify any significant issues with those items assigned an apparent cause evaluation, root cause evaluation, or common cause evaluation.

The inspectors reviewed the licensees work order backlog and concluded that equipment issues were generally being addressed appropriately. The inspectors determined that the licensee usually evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified. In general, appropriate actions were assigned to correct the degraded or non-conforming condition.

There were no open items identified by the inspectors in operations, emergency preparedness, engineering, or maintenance backlogs that were risk-significant, either individually or collectively.

i) Observations Classification Error The inspectors identified that a number of the Level 4 CARDs should have been classified as Level 3 items. These issues were conditions adverse to quality but were classified as enhancements that did not require any corrective action. The inspectors determined these issues were minor procedural errors because no current safety concerns existed. However, these deficiencies had the potential to lead to degraded or inoperable conditions not being recognized. One such example was CARD 14-10011, Inadequate Margin for Load Shed Action to Preclude Exceeding Design Basis during MPC Movement. In this case, the licensee identified that the current procedure did not take into account for temperature sensor uncertainty and spent fuel cask temperature margin to initiate actions to prevent exceeding the safety analysis temperature input value of the Reactor Building temperature during spent fuel cask loading activities. An evaluation of the spent fuel loading was performed and determined that heat load from the spent fuel for the loading campaign would not cause the temperature limit to be exceeded. However, an evaluation had to be completed for future loading campaign until the procedure was changed. The inspectors determined that this was a condition adverse to quality and that the CARD should have been classified as Level 3. The licensee entered this issue into the CAP as CARD 15-29884 and re-evaluated the level classification. Since no loading campaign was currently planned, the inspectors considered this classification error issue minor.

Engineering Evaluation The inspectors noted that the engineering backlog has increased in volume over the inspection period and questioned the licensee on its ability to effectively control the backlog. The increase in backlog could potentially distract the licensee from effectively monitoring the long term safety systems health and affect proper resource utilization.

The licensee provided the inspectors with their plan to reduce the backlog and discussed timelines and the prioritization issues to clear the backlog. The inspectors concluded that the plan could be successful in reducing the engineering backlog. A more detailed discussion on outstanding corrective action items is provided in Section 4OA2.1.b.3 below.

Due Date Extensions Licensee procedure MQA11, Condition Assessment Resolution Document, requires justification for each due date extension request for corrective actions. However, the inspectors identified in selected CARDs that justification provided for due date extensions appeared to lack details. Normally, the reason for extending the due date, the reason why it was acceptable to extend the due date in terms of the impact to plant safety, and the reason why the due date requested was the best estimate when all the actions could be completed would be documented. However, for a number of the outstanding CARDs, the inspectors could not identify any discussion related to the due date impact to plant safety nor why all the actions could be completed by the requested dates.

For example, in CARD 06-22176, Additional Penetrations Identified that Require Post LOCA Radiation Shine Evaluation, corrective actions were assigned in 2011 to update the penetrations dose evaluation. In November 2012, the due date was extended to first quarter of 2014 for the work to be incorporated with the power uprate project. In first quarter of 2014, the due date was further extended to December 2015 to obtain a separate contractor engineering service, as it was not incorporated into the power uprate project. The licensee stated at the time that funding for the service had not been obtained and the effort was expected to take approximately seven months. In December of 2015, the due date was extended again to December 2016, citing the need for contractor proposals to be received by the end of first quarter of 2016. The licensee again stated that the project was expected to take approximately seven months. For the most recent extension, the licensee documented the reason why the impact to the plant was minimal.

The inspectors concluded that none of the three extensions documented why the due date could be feasible when the funding for the work had not even been approved. The impact to plant safety for delaying the work was also not documented except for the last request. Even though the requests were approved by the appropriate licensee management and met the minimum requirements for extension per procedure, the inspectors reasoned that the due dates requested appeared to be arbitrary without the full details documented. The licensee acknowledged this issue and planned to improve the documentation for due date extensions.

ii) Findings No findings were identified.

(3) Effectiveness of Corrective Action Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk. Problems identified using root or apparent cause methodologies were resolved in accordance with the CAP procedural and regulatory requirements.

Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely. The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

A five-year review was performed on the licensees implementation of their preventive maintenance program and the licensee staffs ability to incorporate revisions or augmentations of the program to resolve instances involving equipment unavailability or degradation. The inspectors reviewed issues dated back to January 2011 and assessed the effectiveness of the licensee staffs ability to characterize and resolve issues that were identified through operating experience or actual events.

The inspectors noted several examples where the initial evaluations of operating experience and industry best practices/standards did not identify or proactively address potential improvements to the licensees preventive maintenance program. However, the licensees corrective actions to address program deficiencies, once identified as a result of equipment failures, appear generally effective based on the programs procedural revisions the inspectors reviewed.

The inspectors review of the previous five years of the licensees efforts to address issues with the safety-related service water system did not identify any negative trends or inability by the licensee to address long term degradation issues. The inspectors review of the previous five years of the licensees efforts to address issues identified with the preventive maintenance programs implementation and the licensee staffs ability to incorporate revisions or augmentation of the program to resolve instances involving equipment unavailability or degradation, did not identify any negative trends or inability by the licensee to address long-term issues.

i) Observations Outstanding Correction Action Items During this inspection, the inspectors recognized that there was a large population of outstanding correction action items. Specifically, there were over 3000 open corrective action items at the time of the inspection. More than 500 of these open corrective action items were Level 3 to Level 1 items, which the licensee considered conditions adverse to quality or significant conditions adverse to quality. About 13 percent of these items (68)were greater than 2 years old. There were also seven Level 1 CARDs, which were considered significant conditions adverse to quality by the licensee, and five of these were over 1000 days old.

The inspectors verified a sample of these CARDs were evaluated and actions assigned appropriately. In general, these open CARDs were being tracked by the responsible department. The inspectors reviewed a sample of the corrective action items and determined that most of the remaining actions were design non-conformances, which required updating design calculation or performing modification to restore compliance.

The due dates for these action items had been extended a number of times due to resource limitations or other emergent issues. For those corrective actions that were safety significant, the inspectors evaluated whether the due dates were reasonable and whether the licensee had appropriate compensatory actions in place.

For those items that affected safety related equipment, the inspectors determined that the corrective actions were untimely and the issues were minor violations of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, because the equipment affected were either operable or operable with appropriate compensatory actions in place. While the total number of outstanding actions was still manageable, they could potentially affect the licensees understanding of the design basis of the plant and complicate future equipment issue resolution. The licensee acknowledged the inspectors concern and was working on a plan to reduce the backlog.

Effectiveness Review The inspectors noticed several examples where the effectiveness review only measured success of corrective actions by the absence of a recurring event. In one example, CARD 15-21792, 72CF Failed to Throwover, the issue was the result of an increase resistance across a contact that had accumulated over many years. The effectiveness review only called for noting the absence of trips over an 18-month span to demonstrate effectiveness of the corrective actions. Since this was a long developing issue, an 18-month span would not allow sufficient time for the problem to recur. Licensee procedure MQA-11, Condition Assessment Resolution Document, Section 7, addresses effectiveness reviews and denotes that effectiveness reviews should include, where possible, specific and measurable criteria. The inspectors questioned whether a quantitative approach was plausible by measuring resistances during the monthly surveillance test. The licensee initiated CARD 15-30098 to document the inspectors observations and to evaluate future effectiveness reviews for including quantitative results vice the absence of failure.

ii) Findings Failure to Comply with ASME B30.16 for Planned Engineered Lifts

Introduction:

The inspectors identified a finding of very low safety significance for the licensees failure to meet the American Society of Mechanical Engineers (ASME) Code requirements to perform planned engineered lifts of loads that exceeded a hoists rated capacity. Specifically, on September 25 and 26, 2013, the licensee used the Unit 2 turbine building reactor feed pump (RFP) monorail hoist to perform multiple lifts of floor plugs without meeting the requirements of ASME Code B30.16, Section 16-3.4, Planned Engineered Lifts. The weight of the floor plugs exceeded the rated capacity of the hoist. No violation of regulatory requirements was identified.

Description:

While reviewing CARD 13-26948, Underhung Hoist used Over Rated Capacity Without Meeting ASME B30.16, as part of the biennial PI&R team inspection, the inspectors noted that the licensee failed to comply with the requirements of ASME B30.16, Section 16-3.4, for Planned Engineered Lifts when performing lifts of RFP floor plugs.

Discussions with the licensee revealed that on September 25 and 26, 2013, the licensee conducted multiple lifts of the Unit 2 south turbine building RFP floor plugs using underhung hoist U3100-E031B, which had a rated capacity of 30,000 lbs. At one point, personnel performing the lifts questioned the capacity of the hoist versus the weight of the plugs being moved. They reported that the weight (32,000 lbs.) of one of the blocks dyno tested during the plug movements was in excess of the hoists rated capacity.

ASME Code B30.16 permits lifts that exceed the rated capacity of the hoist if the requirements of Section 16-3.4, Planned Engineered Lifts are met. Licensee personnel, without verifying, mistakenly believed that an evaluation of the hoist capacity had been performed in CARD 12-22088, Weight of Floor Plugs above the South RFPT may Exceed Capacity of Installed Overhead Hoist and deemed adequate. Therefore, instead of stopping and performing the Code required actions before proceeding, licensee personnel continued to complete the plug lifts. Subsequent to the lifts, CARD 13-26948 was initiated to document the non-conformance and to take corrective actions to restore compliance with the Code.

As noted above, the inspectors reviewed CARD 13-26948 and identified that the corrective actions taken were inadequate to restore compliance with the Code.

Specifically, the licensee limited corrective action just to a visual examination of the hoist. Additional Code requirements included in part, inspections, calculations, test lifts, distances traveled, and record keeping and retention. The Code also limits the number of lifts to two within any continuous 12-month period without meeting additional requirements. The licensee also failed to evaluate the north turbine building hoist, as the same conditions existed for the hoist previously. The inspectors determined that the hoists were never in compliance with the Code requirements even though multiple lifts exceeding the hoists rated capacity had been completed. If the hoist failed, and a heavy object were to fall through the turbine building hatch opening, it could have resulted in a loss of condenser vacuum and subsequent plant trip or possibly a steam leak into the turbine building.

Analysis:

The inspectors determined the licensees failure to comply with the requirements of ASME B30.16 for Planned Engineered Lifts to life RFP floor plugs was a performance deficiency warranting a significance evaluation. The inspectors reviewed the examples of minor issues in IMC 0612, "Power Reactor Inspection Reports,"

Appendix E, "Examples of Minor Issues," dated August 11, 2009, and found no similar examples. Consistent with the guidance in IMC 0612, Appendix B, "Issue Screening,"

dated September 7, 2012, the inspectors determined the performance deficiency was of more than minor safety significance because if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. Specifically, if the hoist failed, and a heavy object were to fall through the turbine building hatch opening, it could have resulted in a loss of condenser vacuum and subsequent plant trip or possibly a steam leak into the turbine building.

In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," Table 3, "SDP Appendix Router," the inspectors determined this finding affected the Initiating Events Cornerstone, specifically the Transient Initiator contributor, and would require review using IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power,"

dated June 19, 2012. The inspectors performed a Phase 1 SDP review of this finding using the guidance provided in IMC 0609, Appendix A, Exhibit 1, "Initiating Events Screening Questions," and determined this finding was a licensee performance deficiency of very low safety significance (Green) because it did not cause a reactor trip.

The inspectors determined this finding affected the cross-cutting area of problem identification and resolution, evaluation (P.2) due to the failure of the organization to thoroughly evaluate issues to ensure resolutions address causes and extend of condition commensurate with their safety significance. Specifically, the licensee failed to evaluate thoroughly the causes for not complying with Code requirements once a lift that exceeded a hoists rated capacity had occurred. Therefore, effective corrective actions and an extent of condition were not identified.

Enforcement:

The licensees failure to comply with ASME Code requirements to conduct planned engineered lifts of RFP floor plugs did not affect 10 CFR 50, Appendix B, components; therefore, no violation of regulatory requirements occurred. The licensee entered this finding into its corrective action program as CARD 15-30077. (FIN 05000341/2015007-01, Failure to Comply with ASME B30.16 for Planned Engineered Lifts)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed the operating experience program implementing procedures, and completed evaluations of operating experience issues and events. The inspectors also attended the weekly operating experience meeting to observe the screening of OE information and reviewed selected monthly assessments of the OE performance indicators. The inspectors discussed OE program activities with the facilitys OE coordinator, and observed daily activities such as pre-job briefs for the use of operating experience information. The intent was to determine if the licensee was effectively integrating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of operating experience experience, were identified and implemented effectively and in a timely manner.

b. Assessment Based on the results of the inspection, the inspectors concluded that in general, operating experience was effectively utilized at the station. Both internal and external operating experience was being incorporated into station activities. The inspectors observed that operating experience was discussed as part of the daily and pre-job briefings. Industry operating experience was effectively disseminated across plant departments and was used to assist with resolving equipment issues. No significant issues were identified during the inspectors review of selected licensee operating experience evaluations.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments and Nuclear Quality Assurance (NQA) audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the self-assessments and audits reviewed, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. These audits and self-assessments were completed by personnel knowledgeable in the subject area. The inspectors concluded that the NQA audits were generally thorough and critical based on the number and nature of issues identified as well as the recommendations proposed. The inspectors observed that CARD items had been initiated for issues identified through NQA audits and self-assessments. Corrective actions developed from these assessments were tracked for resolution in the CAP and enhancement actions were assigned in the Action Item Management System. The inspectors reviewed the self-assessment performed on the CAP itself and generally agreed with the overall results and conclusions drawn.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed selected Fermi personnel to determine if there were any indications that licensee personnel were reluctant to raise safety concerns to either their management or the NRC due to fear of retaliation. The inspectors reviewed selected employee concern program (ECP) case files to identify any emergent issues or potential trends. The inspectors also assessed the licensees safety conscious work environment through a review of ECP implementing procedures, discussions with the Fermi ECP coordinator, interviews with personnel from various departments, and reviews of corrective action documents. The inspectors reviewed licensees self-assessments and assessments by external organizations of safety culture to determine if there were any organizational issues or trends that could affect the licensees safety performance.

b. Assessment The inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety conscious work environment at Fermi-2.

Licensee staff members were aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. In addition, a review of the types of issues in the ECP indicated that the licensee staff members were appropriately using the CAP and ECP to identify issues. The licensee staff also indicated that management had been supportive of the CAP by providing time and resources for employee to generate their CARDs.

The staff generally expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be communicated to supervision and safety significant issues were being corrected. Some employees indicated that training and retraining of the CAP process were not performed and they lacked the proficiency to navigate the computerized CAP efficiently. The inspectors considered that an improvement opportunity for the CAP implementation.

Since the beginning of 2014, two major safety culture assessments had been performed by the licensees staff, and a nuclear plant owner/operators organization. The results indicated that there were no impediments to the identification of nuclear safety issues.

However, the inspectors reviewed these surveys and identified that there was a slight disconnect on a number of issues between staff and management. These issues were related to resource utilization and corrective action effectiveness. The inspectors determined that these issues did not result in a chilled environment as the staff still exhibited and expressed a willingness to bring up safety issues. The licensee acknowledged the discrepancies and was developing a plan to address the issues.

c. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting On December 18, 2015, the inspectors presented the inspection result to Mr. M. Philippon and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Philippon, Plant Manager

L. Peterson, Engineering Director

J. Davis, Training Manager

M. OConnor, Security Manager

W. Colonnello, Work Management Director

E. Kokosky, Organizational Effectiveness Director

W. Raymer, Maintenance Manager

J. Louwers, Quality Assurance Manager

R. Laburn, Radiation Protection Manager

C. Harris, Performance Improvement Manager

A. Hassoun, Licensing Manager

NRC

B. Dickson, Branch Chief

B. Kemker, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000341/2015007-01 FIN Failure to Comply with ASME B30.16 for Planned Engineered Lifts (Section 4OA2.1.b.3.ii)

Closed

05000341/2015007-01 FIN Failure to Comply with ASME B30.16 for Planned Engineered Lifts (Section 4OA2.1.b.3.ii)

Discussed

None