IR 05000341/2019002
| ML19210D343 | |
| Person / Time | |
|---|---|
| Site: | Fermi, 07200071  |
| Issue date: | 07/26/2019 |
| From: | Eric Duncan Reactor Projects Region 3 Branch 4 |
| To: | Fessler P DTE Energy |
| References | |
| IR 2019001, IR 2019002 | |
| Download: ML19210D343 (27) | |
Text
July 26, 2019
SUBJECT:
FERMI POWER PLANT, UNIT 2INTEGRATED INSPECTION REPORT 05000341/2019002 AND 07200071/2019001
Dear Mr. Fessler:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fermi Power Plant, Unit 2. On July 9, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Fermi. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Eric R. Duncan, Chief Branch 4 Division of Reactor Projects
Docket Nos.: 05000341 and 07200071 License No.: NPF-43
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000341 and 07200071
License Number:
Report Numbers:
05000341/2019002 and 07200071/2019001
Enterprise Identifiers: I-2019-002-0058 and I-2019-001-0111
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
April 1, 2019 to June 30, 2019
Inspectors:
S. Bell, Health Physicist
T. Briley, Senior Resident Inspector
N. Fields, Health Physicist
V. Myers, Senior Health Physicist
J. Nance, Resident Inspector
R. Ng, Project Engineer
J. Rutkowski, Project Engineer
T. Taylor, Resident Inspector
Approved By:
Eric R. Duncan, Chief
Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Fermi Power Plant, Unit 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Verify the Adequacy of the Design of the Reactor Building to Suppression Chamber Vacuum Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000341/2019002-01 Open/Closed None (NPP)71153 A finding of very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified by the inspectors when the licensee failed to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves automatically closed upon increasing torus pressure and remain closed during all containment high pressure conditions. Specifically, during various loss of offsite power (LOP) and loss of coolant accident (LOCA) scenarios, the butterfly valves would not close automatically without manual operator action.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000341/2018-007-00 LER 2018-007-00 for Fermi,
Unit 2, Reactor Building to Suppression Chamber Vacuum Breaker Condition Prohibited by Technical Specifications 71153 Closed LER 05000341/2019-002-00 LER 2019-002-00 for Fermi 2,
Secondary Containment Airlock Doors Opened at the Same Time Resulting in a Condition Prohibited by Technical Specifications 71153 Closed
PLANT STATUS
Unit 2 operated at or near rated thermal power during the entire inspection period with the exception of power changes to perform planned rod pattern adjustments.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the sites readiness for high winds potentially affecting lake level on April 11 and April 12, 2019
Summer Readiness Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated the summer readiness of offsite and alternate alternating current (AC) power systems
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Reactor Core Cooling Injection system while the High Pressure Coolant Injection (HPCI) system was out-of-service for planned surveillance testing during the week ending May 25, 2019
- (2) Division 1 Non-Interruptible Air System (NIAS) during planned maintenance on Division 2 NIAS during the week ending May 25, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the HPCI system during the week ending April 6, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (6 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Reactor Building First Floor, South Hydraulic Control Unit and Railroad Bay Area on April 10, 2019
- (2) Reactor Building Fourth Floor, Standby Liquid Control Area on April 10, 2019
- (3) General Service Water (GSW) Pump House during the week ending April 13, 2019
- (4) Residual Heat Removal (RHR) Complex, Emergency Diesel Generator (EDG) 13 Room on April 24, 2019
- (6) Circulating Water (CW) Pump House during the week ending April 27, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Partial)
The inspectors evaluated internal flooding mitigation protections in the:
- Torus Room during the week ending June 29, 2019
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a Recirculation System Digital Control System (DCS) module replacement during the week ending May 18, 2019
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Reactor Protection System (RPS) during the week ending April 13, 2019
- (2) Reactor Recirculation System during the week ending April 27, 2019
- (3) Primary Containment Isolation functions during the week ending May 18, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Planned Recirculation System DCS module replacement during the week ending May 4, 2019
- (2) Emergent Independent Spent Fuel Storage Installation (ISFSI) Cask 1 dye penetrant testing and gas monitoring within the time-to-boil period during the week ending June 8, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (1 Sample)
The inspectors evaluated the following operability determinations or functionality assessments:
- (1) Operability and functionality of the condensate storage tank, associated tank level instrumentation, and connected systems following the identification of the potential for vortex conditions at low tank levels, as documented in Corrective Action Resolution Document (CARD) 19-23227
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Reactor Water Cleanup (RWCU) isolation circuit timer following emergent maintenance during the week ending April 6, 2019
- (2) Division 2 RHR Pump D Suppression Pool Suction Motor-Operated Valve (E1150-F004D) following planned maintenance during the week ending May 25, 2019 (3)24/48 Volt Battery Charger 2IB-1 following emergent maintenance during the week ending June 1, 2019
- (4) Division 2 RHR Pump B discharge pressure trip unit following emergent maintenance during the week ending April 13, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
- (1) HPCI pump and valve operability test at 1025 pounds per square inch (psi) during the week ending May 26, 2019
Surveillance Tests (Other) (IP Section 03.01) (6 Samples)
- (1) EDG 11 fast start and load test during the week ending April 12, 2019
- (2) Division 1 Emergency Core Cooling System (ECCS) Reactor Vessel Water Level 2, Anticipated Transient Without Scram (ATWS)-Recirculation Pump Trip (RPT)functional test during the week ending April 12, 2019
- (3) EDG 12 - Diesel Generator Service Water, Diesel Fuel Oil transfer, and Starting Air Compressor valve operability test on May 16, 2019
- (4) Division 1 Standby Gas Treatment filter performance test during the week ending May 25, 2019
- (5) Reactor Pressure Vessel Jet Pump 11 flow/pressure indication loop calibration on May 14, 2019
- (6) Division 1 RHR Cooling Tower Fan Operability and RHR Service Water (RHRSW)valve line-up verification on May 15, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated an Emergency Preparedness Drill that was conducted on May 21,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
- Radwaste effluent radiation monitor
- Circulating Water System decant line effluent radiation monitor
- Onsite Storage Facility effluent radiation monitor
Dose Calculations (IP Section 02.05) (1 Sample)
The inspectors reviewed the following discharge permits to evaluate public dose calculations:
- Vent of primary containment on November 16, 2018
The inspectors also reviewed the following annual radiological effluent release reports:
- 2017 Annual Report
- 2018 Annual Report
Abnormal gaseous or liquid tank discharges
- No abnormal gaseous or liquid tank discharges were available for review during this inspection
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed the following radioactive effluent discharge system surveillance test results:
Sampling and Analysis (IP Section 02.03) (1 Sample)
The inspectors reviewed the following radioactive effluent sampling and analysis activities:
- Standby Gas Treatment effluent sampling
- Reactor Building effluent sampling
- Onsite Storage Facility effluent sampling
Effluent discharges with inoperable monitors
- Reactor Building
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:
- Division 1 Standby Gas Treatment System
- Division 2 Standby Gas Treatment System
- Reactor Building Ventilation System
- Onsite Storage Facility Ventilation System
71124.07 - Radiological Environmental Monitoring Program
Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)
- (1) The inspectors assessed the implementation of the groundwater protection initiative
Site Inspection (IP Section 02.01) (1 Sample)
- (1) The inspectors evaluated the radiological environmental monitoring program implementation
Walkdowns and calibration and maintenance record review
- Air Sampling Station API-1, Estral Beach
- Air Sampling Station API-2, Site Boundary North North West
- Air Sampling Station API-3, Site Boundary North West
- Air Sampling Station API-5, Site Boundary South
- Air Sampling Station API-6, Site Boundary West North West
- Dosimeter Monitoring Station T12, Pointe Mouille Game Area
- Dosimeter Monitoring Station T22, North Side of Pointe Aux Peaux
- Dosimeter Monitoring Station T23, South Side of Point Aux Peaux
- Dosimeter Monitoring Station T25, Toll Road
The inspectors observed the following environmental sample collection and preparation:
- Milk Sampling Location M-8, Calder Dairy
Licensee actions in response to missed sample, inoperable sampler, lost dosimeter, or anomalous measurement
- 2017 first quarter dosimeter location T-7 found missing
- 2017 third quarter dosimeter location T-37 found missing
- 2017 fourth quarter dosimeter location T-37 found missing
- 2018 first quarter dosimeter location T-47 found missing
Sampling program for the potential of licensed material entering groundwater
- Condensate Storage Tank
- Condensate Return Tank
- U2100 Cable Vault
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified the licensee performance indicators submittals listed below:
BI02: RCS Leak Rate Sample (IP Section 02.11)===
- (1) Unit 2 (April 1, 2018 - March 31, 2019)
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) Unit 2 (April 1, 2018 - March 31, 2019)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) Unit 2 (April 1, 2018 - March 31, 2019)
71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000341/2018-007-00, Reactor Building to Suppression Chamber Vacuum Breaker Condition Prohibited by Technical Specifications (ADAMS Accession ML19036A741). The circumstances surrounding this LER are documented in the Inspection Results Section of this report.
- (2) LER 05000341/2019-002-00, Secondary Containment Airlock Doors Opened at the Same Time Resulting in a Condition Prohibited by Technical Specifications (ADAMS Accession ML19112A331). The circumstances surrounding this LER are documented in the Results Section of Integrated Inspection Report
===05000341/2019001 (ADAMS Accession ML19130A097)
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants
Operation of an Independent Spent Fuel Storage Installation at Operating Plants===
- (1) The inspector evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading from June 17 through June 21, 2019. Specifically, the inspector observed the following activities:
- Stack-Up and download of Multi-Purpose Canister (MPC)-596 from the transfer cask (HI-TRAC) to the storage cask (HI-STORM) at the Cask Transfer Facility (CTF)
- Heavy load movement of the HI-TRAC and empty MPC-587 up through the refuel floor hatch into the Dryer Separator Pit (DSP)
- Loading spent fuel into MPC-587
- Heavy load movement of the HI-TRAC and loaded MPC-587 out of the spent fuel pool into the DSP
- Post-hydro dye penetrant weld evaluation for MPC-587
- Blowdown, vacuum drying, and helium backfill evolutions for MPC-587
- Radiological technical specification and general area surveys
The inspector performed a walkdown of the ISFSI pad, including independent radiation surveys, and a walkdown of the ISFSI haul path.
The inspector evaluated the following:
- Spent fuel selection for the 11 casks in the loading campaign
- Selected CARDs
- Selected 10 CFR 72.48 screenings and evaluations
- The licensees change in Certificate of Compliance (CoC) loading amendment from Amendment 5 to Amendment 10, including a change in MPC type from MPC-68 to MPC-68M
INSPECTION RESULTS
Failure to Verify the Adequacy of the Design of the Reactor Building to Suppression Chamber Vacuum Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green NCV 05000341/2019002-01 Open/Closed
None (NPP)71153 A finding of very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified by the inspectors when the licensee failed to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves automatically closed upon increasing torus pressure and remain closed during all containment high pressure conditions. Specifically, during various loss of offsite power (LOP) and loss of coolant accident (LOCA) scenarios, the butterfly valves would not close automatically without manual operator action.
Description:
The reactor building to suppression chamber vacuum breakers consist of a power-to-close, spring-to-open butterfly isolation valve and a testable check valve in series. The function of the reactor building to suppression chamber vacuum breakers is to relieve vacuum when primary containment depressurizes below reactor building pressure. In addition, the two vacuum breakers in series (butterfly valve and check valve) must be closed to maintain a leak tight primary containment boundary. In accordance with Fermis Updated Final Safety Analysis Report (UFSAR), the butterfly valves are normally closed and open automatically to prevent formation of a negative pressure in the torus. The butterfly valves close automatically upon increasing torus pressure and remain closed during all containment high pressure conditions.
On December 8, 2018, while in Mode 4 (cold shutdown), the licensee identified a legacy design issue since initial power operation on January 23, 1988, in the control logic circuitry for the reactor building to suppression chamber vacuum breakers that prevented automatic closure of the butterfly isolation valves following power restoration from a LOP event. The reactor building to suppression chamber vacuum breaker check valves were not impacted by the design issue and therefore there was no loss of safety function. Procedural guidance was available to manually close the butterfly valves from the main control room following a LOP event.
On February 2, 2019, the licensee submitted LER 05000341/2018-007-00 (ADAMS Accession ML19036A741) to the NRC in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition which was prohibited by the plants Technical Specifications.
Technical Specification (TS) 3.6.1.7, Reactor Building-to-Suppression Chamber Vacuum Breakers, requires, in part, that each reactor building to suppression chamber vacuum breaker shall be operable in Mode 1, 2, and 3. As a consequence of this design control issue, the licensee declared that the reactor building to suppression chamber vacuum breaker butterfly valve in each line had been inoperable since initial power operation whenever the reactor was in Modes 1, 2, or 3. LCO 3.6.1.7 did not include any associated actions for the condition (failure to reclose following restoration of power), which placed the licensee in LCO 3.0.3, which required the licensee to place the reactor in Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and Mode 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Since the licensee was not previously aware of the condition of the valve, the actions required by LCO 3.0.3 were not taken.
Although the design issue was identified by the licensee during an engineering evaluation of an unrelated issue associated with LOP/LOCA conditions, the inspectors identified inadequacies in the licensees characterization and evaluation of the issue of concern. Specifically, the licensee failed to document in their evaluation of the design issue why it was not identified during or in the years following original plant construction nor during periodic functional testing of the reactor building to suppression chamber vacuum breakers. In addition, the past operability evaluation was generic in nature stating that TS LCO 3.6.1.7 was not met (i.e. inoperable), but did not recognize that LCO 3.0.3 applied, and also was not met. When questioned by the inspectors, the licensees proposed TS actions did not involve TS LCO 3.0.3, which would have been required while the plant operated in Mode 1, 2, or 3 with the butterfly valves in their normally closed position. Therefore, the finding was considered NRC-Identified.
The licensees corrective action program ownership screening committee and management review committee both determined a formal causal evaluation was not necessary. Therefore, a qualitative description of the event stated the cause was a legacy design issue with a supporting technical justification. The design issue was corrected through a physical plant modification that included a post-maintenance functional test (open and close valve strokes)and a one-time post-maintenance test that consisted, in part, of removing and re-installing control power fuses to verify the butterfly isolation valves functioned as designed. The licensee did not document an evaluation of the effectiveness of past and present functional testing procedures until questioned by the inspectors. The inspectors determined current, post-modification reactor building to suppression chamber vacuum breaker functional test procedures (to open and close the butterfly valves) were adequate to verify automatic closure of the butterfly valves following power restoration from a LOP event.
Corrective Actions: A physical modification was implemented to re-wire the manual override portion of the vacuum breaker butterfly isolation valve control circuits so that the butterfly isolation valves would automatically re-close following the restoration of electrical power following a LOP event.
Corrective Action References: CARD 18-29870
Performance Assessment:
Performance Deficiency: The failure to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves close automatically upon increasing torus pressure and remain closed during all containment high pressure conditions (specifically following a restoration of electrical power)was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone. Specifically, the reactor building to suppression chamber vacuum breaker butterfly isolation valves would not automatically close following a LOP event in order to perform their containment isolation function during all containment high pressure conditions.
Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The inspectors concluded the issue was of very low safety significance (i.e., Green) based on answering No to Exhibit 3 Barrier Integrity Screening Questions B.1 and B.2.
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by performance of a suitable testing program. Fermi UFSAR Table 6.2-2, Note 24 states, in part, that each reactor building to suppression chamber butterfly valve is normally closed and opens automatically to prevent formation of a negative pressure in the torus and that the butterfly valve closes automatically upon increasing torus pressure and remains closed during all containment high pressure conditions.
Technical Specification LCO 3.6.1.7 requires that each reactor building to suppression chamber vacuum breaker be operable in Mode 1, 2, and 3. Technical Specification LCO 3.0.3 requires, in part, that when an LCO is not met and an associated action is not provided, the unit shall be placed in a Mode or other specified condition in which the LCO is not applicable and that this action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and Mode 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Contrary to the above, from initial power operation on January 23, 1988, until December 19, 2018, the licensee failed to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves close automatically upon increasing torus pressure and remain closed during all containment high pressure conditions. Specifically, during various LOP and LOCA scenarios, the butterfly valve would not close automatically without manual operator action. Additionally, because the licensee was not aware of the reactor building to suppression chamber vacuum breaker inoperability since initial power operation, the licensee failed to take the actions required by TS LCO 3.0.3 whenever the reactor had been in Modes 1, 2, or 3.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 23, 2019, the inspectors presented the Radiation Protection Program inspection results to Mr. M. Caragher, Plant Manager, and other members of the licensee staff.
- On June 21, 2019, the inspectors presented the Independent Spent Fuel Storage Installation inspection results to Mr. J. Rivet, Mr. P. Crane, Mr. J. Haas, and other members of the licensee staff.
- On July 9, 2019, the inspectors presented the integrated inspection results to Mr. P. Fessler and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855.1
ALARA Plans
RWP Number: 191061 Task Description: 2019 ISFSI
Campaign
2/19/2019
Calculations
HI-2125415
Thermal Evaluation of HI-STORM System in a Cask Transfer
Facility (CTF) at Fermi
03/25/2013
HI-2188547
Fermi MPC-68M Lifting Analysis
05/30/2019
RRTI-2995-05
Response to Request for Technical Information (RRTI)
Holtec International Helium Backfill - NRC Question
06/27/2019
Calibration
Records
1043-10181460
Traceable Certificate of Calibration for 3-Button Stopwatch
2/27/2019
6850-ACAL-
COMP-1-135032
Certificate of Calibration Accu-Flow Calibrated Leak Model #:
GPP-8-HE-QF25-110CC-SR15
03/22/2019
KELC-592390
Certificate of Calibration Extech Easyview 11A Type K
Thermometer
04/18/2019
Corrective Action
Documents
Selected ISFSI-Related CARDs Generated Since
July 21, 2016
16-0104
Quality Assurance Audit of the Independent Spent Fuel
Storage Installation (ISFSI) Program
05/02/2016
18-0102
Nuclear Quality Assurance Audit of the Independent Spent
Fuel Storage Installation Program
03/12/2018
CARD 19-24551
Trend on MPC Indications - Resolution Required
06/15/2019
CARD 19-24601
NQA - Receipt Inspection of ISFSI MPCs and Lids Not
Completed in Accordance with MMM12 Receipt and Source
Inspections
06/18/2019
Drawings
ISFSI Delivery and Cask Haul Path
01/21/2016
Miscellaneous
Visual Examination Report, NDE VT Level II Personnel
Certificate, NDE PT Level II Personnel Certificate, and
Certification of Inspection, Examination and Testing
Personnel for NDE Personnel
04/25/2019
PCI Energy Services Welder Performance Qualifications and
Welder Maintenance Logs for Welding Personnel
04/25/2019
Visual Acuity Record and Non-Destructive Inspector
Certification Record for Mass Spectrometer Leak Testing
Personnel
04/30/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Quarterly TLD Data from TLD 68 for 2013, 2017, and 2018
Selected 72.48 Screenings and Evaluations Performed
Since July 21, 2016
DTE Electric Company Fermi 2 Nuclear Power Plant
Independent Spent Fuel Storage Installation 10 CFR 72.212
Evaluation Report ISFSI NRC Docket 72-71
04/22/2019
Fermi 2 UFSAR Section 17.2A Quality Assurance of the
Independent Spent Fuel Storage Installation
Composite Cask Load Reports for Campaign 3 Casks 1
Through 11
06/10/2019
Fermi Training Matrix
06/13/2019
Holtec International Qualification Records for Dry Cask
Personnel
05/29/2019
MC-GTAW
ASME Section IX Welding Procedure Specification and
Supporting Procedure Qualification Records
01/27/2017
MN-GTAW
ASME Section IX Welding Procedure Specification and
Supporting Procedure Qualification Records
01/27/2017
Certificate of
Conformance
91542-01
Detroit Electric Company (DTE) - Enrico Fermi Power Plant
Unit 2 DTE 4701334966 Change Order 1
05/23/2019
FER-DCS-001-R-
001
Fermi 2 Dry Cask Storage Fuel Characterization for Cycles 1
Through 12
2/30/2009
Holtec
International PO#
4700949383
HI-STORM 100 with MPC-68M Canister
2/26/2019
Procedures
2.RIG.17
Mobile Crane Operation
35.710.042
Multi-Purpose Canister (MPC) Loading
35.710.043
Blowdown, Drying, Sealing, and Backfill of the MPC
35.710.044
MPC Transport
35.710.045
Dry Cask Storage Equipment Preparation and Lay-Up
35.710.046
MPC Unloading
35.710.047
Responding to ISFSI Abnormal Conditions
35.710.048
MPC Preparation
35.710.049
HI-STORM Offloading and Preparation for Site Fabrication
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Completion
35.710.050
MPC Offloading and Handling
53.000.09
Dry Cask Storage Fuel Selection for Cask Loading
67.000.105
HI-TRAC Radiation Survey
67.000.106
HI-STORM Radiation Survey
67.000.107
MPC/HI-TRAC Contamination Survey
GQP-1.0
Project Organization and Documentation
GQP-1.1
QA Orientation and Project Training
GQP-12.0
Control of Measuring and Test Equipment
GQP-15.0
Non-Conforming Items
GQP-17.0
Quality Records
GQP-7.1
Procurement, Receipt, Storage, and Issue of ASME III
Subsection NCA-3800/NCA-4200 Weld Materials
GQP-8.1
Process Traveler
GQP-9.0
Training, Qualification, Examination, and Certification of NDE
Personnel in Accordance with SNT-TC-1A and CP-189
GQP-9.1
Training, Qualification, Examination, and Certification of
Inspection and Testing Personnel in Accordance with
ANSI/ASME N45.2.6-1978 and ASME NQA-1
GQP-9.2
High Temperature Liquid Penetrant Examination and
Acceptance Standards for Welds, Base Materials and
Cladding (50°-350°F)
GQP-9.6
Visual Examination of Welds
GWS-1
ASME Applications
07/24/2015
MMA07
Hoisting, Rigging, and Load Handling
26A
MMM12
Receipt and Source Inspections
WCP-3
Weld Material Control
07/09/2015
WCP-5
Weld and Base Metal Repair
09/23/2013
WCP-8
Preheating and Postweld Heat Treatment
09/23/2013
Radiation Work
Permits (RWPs)
191061
2019 ISFSI Campaign
03, 04
Self-Assessments Surveillance
Report 19-1003A
ISFSI Campaign #3 Preparation Assessment Report
05/30/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
Perform Licensing Renewal for HI-STORM Lifting Beam
Inspection
03/20/2019
Perform Licenses Renewal Inspection/NDE of HI-TRAC Lift
Link
04/01/2019
Perform Licenses Renewal Inspection/NDE of HI-STORM
Lifting Bracket
03/06/2019
MPC Lifting Cleats Inspection
04/08/2019
Low Profile Transporter Inspection
03/19/2019
Perform License Renewal Inspection/NDE MPC Lift Lock
Assembly Inspection
03/19/2019
Annual Vertical Cask Transporter Maintenance
2/05/2019
NEIL Required-Perform F Frequent Inspection Per MIOSHA
R408.11872 Rule 1872(2)(A)
2/18/2019
NEIL Required-RB Overhead Crane PM Inspections
04/17/2019
SPF 2090
Perform 32.717.01 Monthly Rx Bldg Crane Manipulation-
NEIL Required
03/22/2019
Corrective Action
Documents
10-20653
Engineering Evaluation of ITC Proposed Changes
01/26/2010
18-29819
Abnormal Noise on CB Disconnect Switch
2/06/2018
19-22736
Potential Degradation of Passive Vehicle Barrier System
04/11/2019
Miscellaneous
NOAA Webpage
NOAA Tides and Currents Webpage,
https://tidesandcurrents.noaa.gov, Position 9063090, Fermi
Power Plant
Procedures
20.000.01
Flooding
Work Orders
50014198
Perform Periodic Verification of Grid Adequacy
2/01/2019
218251
Perform Quarterly Walkdown of 120/345 kV Switchyards
06/20/2019
2583978
Abnormal Noise on CB Disconnect Switch
05/24/2019
Drawings
NIAS Division 1 Dryer P5002D012 Controls
N
Station and Control Air
CQ
Reactor Core Isolation Cooling System
BE
Procedures
23.129
Station and Control Air System
116
23.206
Reactor Core Isolation Cooling System
103
Corrective Action
Documents
19-22583
G3352F034 MOV Actuator Missing Stem Dust Cap
04/05/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
High Pressure Coolant Injection (HPCI) System Reactor
Building
BN
High Pressure Coolant Injection (HPCI) System Barometric
Condenser Reactor Building
AJ
Procedures
23.202
High Pressure Coolant Injection System
114
71111.05Q Fire Plans
FP-CWPH-1-32
Circulating Water Pumphouse Zone 32 Elevation 5836
Procedures
FP-GSW-1-31
General Service Water Pumphouse Zone 31
FP-RB-1-7b
Reactor Building South Control Rod Drive (CRD) and
Railroad Bay Area, Zone 7
FP-RB-4-17a
Reactor Building SLC System Zone 17 El. 6596
FP-RHR-1-11-
RHR Complex, EDG 11 Room, El. 5900
FP-RHR-1-13-
RHR Complex, EDG 13 Room, El. 590 0
Corrective Action
Documents
19-23894
NRC Identified Concern: Housekeeping in Torus
05/21/2019
Drawings
29.100.01 SH 5
Continuous Use Procedure
Reactor Building Sub-Basement Plan Elevation 5400 Scale
1/8 = 1-0
M
Reactor Building Basement Plan Elevation 6520
N
Sump Pump Diagram Radwaste System
BR
Diagram Floor Drains All Floors Auxiliary and Reactor
Buildings
Floor and Equipment Drains Sub-Basement Plan Reactor
Building
Y
Procedures
ARP 2D82
Reactor Building Torus Sump Level Hi-Hi/Lo-Lo
ARP 2D83
Reactor Building Leakage to Torus Sump High
71111.11Q Miscellaneous
Operations
Conduct Manual
MOP01
Conduct of Operations
Operations
Conduct Manual
MOP19
Reactivity Management
26A
Operations
Operations Conduct
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Depaartment
Expectation ODE-
Procedures
23.138.01
Reactor Recirculation System
115
Corrective Action
Documents
15-23626
C7100 Functional Failure Evaluation
05/25/2015
15-29250
Found Blown Fuse on Y Phase for RPS A Alternate
Transformer Feed
11/22/2015
16-28543
Single Rod Scram of CR 26-07
10/26/2016
17-20163
Use of RPS Test Box May Cause Loss of RPS Function
01/06/2017
17-21106
Review RPS for Maintenance Rule (a)(1) Classification
2/07/2017
17-23734
RPS-A EPA Breaker Found Tripped
04/19/2017
17-29439
Significant Arching in A RRMG Set Exciter Brushes - Root
Cause Evaluation
17-29735
B3105 Limiter 1 Being Enforced
2/05/2017
18-23130
Root Cause Evaluation Report - North RRMG Set Tripped
After Attempted Start
18-29870
Reactor Building to Suppression Chamber Vacuum Breaker
UFSAR Non-Conformance
2/08/2018
19-20117
Timer G33R616A Did Not Start Timing Immediately Upon
Actuation Signal during 44.020.151
01/04/2019
19-22916
Maintenance Rule Criteria for A7100 System has been
Exceeded
04/17/2019
Miscellaneous
(a)(1) Action Plan for Primary Containment Isolation
2/13/2016
Reactor Recirculation System System Health - Third Quarter
2018
Reactor Recirculation System System Health Report -
Second Quarter 2018
Maintenance Rule Monthly Evaluation Report for April 2019
05/02/2019
(a)(2) System Classification Review for Primary Containment
Isolation
09/16/2016
C7100 System Monitoring
2/20/2019
(a)(1) Action Plan
RPS (C71) Get Well Plan
(a)(1) Action Plan
B3100 Reactor Recirculation System Get Well Plan
MMR APP F
Maintenance Rule Conduct Manual, Appendix F -
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Maintenance Rule Conduct Manual
Procedures
23.628.02
Engineered Safety Features Actuation Instrumentation (RPS
and ECC)
Corrective Action
Documents
19-24210
NQA - Holtec Field Condition Report to Evaluate Indication
Identified on Multi-Purpose Canister [MPC] S/N 0590 [PIS]
G1300A045 (CARD 19-24152) Was Not Reviewed and
Approved by Plant Support Engineering Per MES07
06/03/2019
19-24232
Foreign Material Identified in SFP
06/04/2019
19-24266
NQA - Expired Chemical Sherwin Dubl-Chek Developer D-
100 Found Staged for Use for Liquid Penetrant Testing on
Multi-Purpose Canister Welds
06/05/2019
Miscellaneous
Risk
Management
Plan
Multiple Alarms on C32K816, Replace INNIS21 and Cable
Assembly
05/14/2019
Work Orders
53570537
Multiple Alarms on C32-K816, RW and RR Flat Panel
Display. Troubleshoot and Repair
05/13/2019
Corrective Action
Documents
07-23630
CDBI: UFSAR Anti-Vortex Methodology Non-Conservative
06/28/2007
07-23630-01
Prepare EDP to Increase CST Transfer Setpoint and
Refueling Level Requirements
07/27/2007
19-23227
Recommend Review of Site Response to Open CARD 07-
23630
04/26/2019
Miscellaneous
Crew Learning Opportunity (CLO) Worksheet
50.59 Screen 19-
20
Review of Compensatory Measures for CARD 07-23630
CST Vortex Issue
Bases 3.3.5.1
ECCS Instrumentation
MQA11-100
Operability Determination Process
2A
Corrective Action
Documents
19-22486
Timer G33R616A Did Not Start Timing Immediately Upon
Actuation Signal during 44.020.152
04/02/2019
19-22650
RHR Pump Discharge Pressure at 0 PSIG
04/09/2019
19-23901
Mini on Valve E1150f004d
05/21/2019
19-24070
Human Performance Issue Battery Charger 2IB-1
05/29/2019
Drawings
and 24 - 300# Powell O.S.Y. Gate Valve with Limitorque
Operator
A
General Arrangement 24 Volt and 130 Volt Battery Chargers
E
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Residual Heat Removal (RHR) Division 2
CB
One Line Diagram 48/24V DC Instrumentation Batteries
Distribution
Internal Wiring Diagram 24V ESF Battery Chargers
I
Procedures
35.306.020
Motor Operated Valve Mini Periodic Inspection
Work Orders
48565660
Perform Mini Periodic MOV Inspection (E1150-F004D)
05/21/2019
244172
Inspect/Test Division 2 24 VDC Battery Charger 2IB-1
05/29/2019
53586525
Timer G33R616A Did Not Start Timing Immediately Upon
Actuation Signal during 44.020.152
04/02/2019
53654676
RHR Pump Discharge Pressure at 0 PSIG
04/10/2019
54076383
Inspect/Test Division 2 24 VDC Battery Charger 2IB-1
05/29/2019
Corrective Action
Documents
19-23952
Small Packing Leak Coming from E4100F068 HPCI Control
Valve
05/22/2019
Drawings
High Pressure Coolant Injection (HPCI) System Reactor
Building
BN
High Pressure Coolant Injection System (HPCI) Barometric
Condenser Reactor Building
AJ
Miscellaneous
Plan of the Day - Tuesday May 21, 2019
05/21/2019
Procedures
24.202.01
HPCI Pump and Valve Operability Test at 1025 PSI
118
24.202.08
HPCI Time Response and Pump Operability Test at 1025
24.307.14
Emergency Diesel Generator 11 - Start and Load Test
44.030.249
ECCS - Reactor Vessel Water Level (L2), ATWS-RPT
Division, Functional Test
Work Orders
46360904
Perform 43.404.001 Section 5.8 Division 1 Standby Gas
Treatment System Heater Operability
08/15/2018
46533988
Perform 43.404.001 Division 1 Standby Gas Treatment Filter
Performance Test
08/15/2018
46534020
Perform 43.404.001 Division 1 Standby Gas Treatment
System Charcoal Sample Withdrawal
08/16/2018
48698659
Perform 24.202.08 Sec-5.1 (Water Level) HPCI RTT and
Pump Operability at 1025 PSIG
05/22/2019
49189307
DGSW, DFOT and Starting Air Operability Test for EDG 12
05/15/2019
49336665
Division 1 RHR Cooling Tower Fan Operability and Valve
05/16/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Line-Up Verification Test
53629338
Calibration RPV Jet Pump 11 Flow/Pressure Indicating Loop
05/14/2019
Corrective Action
Documents
19-23913
Untimely EAL Classification during ERO Drill
05/21/2019
19-23923
May 21, 2019 RERP Drill: Green Team OSC Staff Missing
Maintenance Team Members
05/22/2019
18-29288
Potential Knowledge Issue Identified With General
Troubleshooting and Repair Of Radiation Monitors
11/14/2018
18-30351
Onsite Storage Facility Channel 5 Alarm Setpoint Increase
2/23/2018
19-23435
2018 Annual Effluent Report Submitted to the NRC
Contained Inaccuracies
05/03/2019
19-23711
Reactor Building System Particulate, Iodine, and Noble Gas
Sample Pump Failure
05/14/2019
Miscellaneous
2017 Annual Radioactive Effluent Release Report
04/30/2018
2018 Annual Radioactive Effluent Release Report
04/30/2019
NARP-14-0195
Acceptance of Emergency Action Level Basis Calculations
10/20/2014
NPRP-18-0112
On Site Storage Facility System Particulate, Iodine, and
Noble Gas Channel 5 Low Alarm Setpoint Needs to be
Adjusted
06/20/2018
NPRP-18-0215
Alarm Setpoint Adjustments on the Onsite Storage Facility
System Particulate, Iodine, and Noble Gas Monitor
Channel 5
2/21/2018
Work Orders
46675683
Perform 64.080.110 Circulating Water System Decant Line
Radiation Monitor Calibration
05/09/2018
46782282
Perform 64.080.102 Radioactive Waste Effluent Radiation
Monitor Calibration
05/30/2018
46926507
Perform 64.713.019 Attachment 17, Gaseous Effluent
Cumulative And Projected Dose (Monthly)
07/09/2018
47166492
Perform 64.713.019 Attachment 17, Gaseous Effluent
Cumulative and Projected Dose (Monthly)
08/15/2018
51089423
Process Radiation Monitor Onsite Storage Facility Ventilation
Exhaust Radiation Monitor Penthouse Instrument Rack
09/12/2018
51433193
Perform 64.080.102 Radioactive Waste Effluent Radiation
Monitor Calibration
08/03/2018
51822541
Onsite Storage Building Ventilation Exhaust Process
09/11/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation Monitoring System Calibration
2436065
Planned Vent/Purge of Primary Containment Atmosphere
11/16/2018
Calibration
Records
44.100.001
Meteorological Monitoring - Wind Speed Channel Calibration
05/11/2018
Serial Number
6387
Radeco Model AVS-28A Calibration
04/08/2019
Serial Number
22
Radeco Model AVS-28A Calibration
04/08/2019
Serial Number
7572
Radeco Model AVS-28A Calibration
04/05/2019
Corrective Action
Documents
19-20363
Degraded Mechanical Equipment and Support Items Found
in CST/CRT Valve Vaults
01/16/2019
19-21419
Met Tower TRLCO 3.3.13 Condition B
2/24/2019
19-22281
Met Tower TRLCO 3.3.13 Condition B
03/25/2019
Miscellaneous
2017 Annual Radiological Environmental Operating Report
04/30/2018
Responses to D4000 Meteorological Questions
05/21/2019
2018 Annual Radiological Environmental Operating Report
04/30/2019
Procedures
Offsite Dose Calculation Manual (ODCM)
2.000.200
Land Use Census
2.000.201
Airborne Particulate and Iodine Sampling Using RADeCo
Model AVS-28A Air Sampler
2.000.203
REMP Results Analysis - Review and Action
2.000.207
Shipping Environmental Samples
67.000.104
Maintenance of Decommissioning Records
MRP30
Integrated Ground-Water Protection Program
Self-Assessments
Quick Hit Self-Assessment for the NEI 07-07 5-Year
Groundwater Protection Structures Review
01/16/2019
71151
Drawings
Diagram All Floors Auxiliary and Reactor Buildings
Y
Floor Drains All Floors Auxiliary and Reactor Buildings
Engineering
Changes
Design Change
Package 80010
Separation of Drywell Identified and Unidentified Leakage
A
Miscellaneous
EDG MSPI and WANO Performance Indicators (April 2018 -
March 2019)
HPCI Performance Indicators (April 2018 - March 2019)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
50.59 Screen 17-
280
Separation of Drywell Identified and Unidentifed Leakage
and Update UFSAR Figures 5.5.2 and 9.3-5 to Reflect
Changes per EDP 80010
A
Mitigating Systems Performance Index (MSPI) Basis
Document
Regulatory Assessment Performance Indicator Guideline
Procedures
43.401.200
Local Leakage Rate Test Type B - General
43.401.511
Local Leakage Rate Test, Bypass Leakage Valves
41B
Corrective Action
Documents
18-29870
Reactor Building to Suppression Chamber Vacuum Breaker
UFSAR Non-Conformance
2/08/2018
18-56668
2018 DBAI SA: 50.59 Screen 13-0098 Did Not Identify
UFSAR Impacts (Deficiency)
09/05/2018
19-23093
LER 2019-002 Submitted to the NRC with Clerical Errors
04/23/2019
19-23095
Incorrect/Confusing Title of Licensee Event Report in NRC
Submittal (NRC-19-0020)
04/23/2019
Drawings
Torus to Rx Building Vacuum Breaker Valves T2300F450A
Through T2300F410
U
I-2678-03
U
Engineering
Changes
Design Change
Package 80071
Automatic Closure of Torus to RB Vacuum Breakers
Isolation Valves T2300F409 and T2300F410 After Loss of
AC Power
2/19/2018
Miscellaneous
LER 2019-002-00
Secondary Containment Airlock Doors Opened at the Same
Time Resulting in a Condition Prohibited by Technical
Specifications
Procedures
24.402.01
Drywell and Suppression Chamber Vacuum Breaker
Operability Test
& 40