IR 05000341/2019003
| ML19310E673 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/06/2019 |
| From: | Eric Duncan Reactor Projects Region 3 Branch 4 |
| To: | Peter Dietrich DTE Energy |
| References | |
| IR 2019003 | |
| Download: ML19310E673 (31) | |
Text
November 6, 2019
SUBJECT:
FERMI POWER PLANT, UNIT 2 - INTEGRATED INSPECTION REPORT 05000341/2019003
Dear Mr. Dietrich:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On October 16, 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.
Three findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or significance or severity of the violations 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.
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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; 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 No. 05000341 License No. NPF-43
Enclosure:
As stated
Inspection Report
Docket Number:
05000341
License Number:
Report Number:
Enterprise Identifier: I-2019-003-0058
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
July 01, 2019 to September 30, 2019
Inspectors:
T. Briley, Senior Resident Inspector
G. Edwards, Health Physicist
J. Harvey, Resident Inspector
L. Kozak, Senior Reactor Analyst
R. Ng, 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
Incorrect Datum Used to Assess Lake Levels Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/2019003-01 Open/Closed None (NPP)71111.01 The inspectors identified a finding of very low safety significance (i.e., Green) and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, when licensee personnel failed to have appropriate measures in place to assess the impact of projected Lake Erie water levels on the site. As a result, actual lake level, including any predicted maximum lake level during a flood watch or warning, was determined to be 1.3' [feet] higher during a flooding event than what was calculated.
Inadequate Response to an Out-of-Service Diesel Fire Pump Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/2019003-02 Open/Closed
[H.5] - Work Management 71111.18 A self-revealed finding of very low safety significance (i.e., Green) and an associated Non-Cited Violation (NCV) of Fermi License Condition 2.C.(9) was identified when licensee personnel failed to take appropriate actions in response to an out-of-service diesel fire pump.
Specifically, a temporary diesel fire pump (DFP) used to restore system functionality failed to function as designed and the risk plan that was developed could not be implemented as written.
Failure to Properly Pre-Plan Work in Accordance with the Work Control Conduct Manual Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green FIN 05000341/2019003-03 Open/Closed
[H.7] -
Documentation 71153 A self-revealed finding of very low safety significance (i.e., Green) was identified when the licensee failed to properly pre-plan maintenance activities on the Feedwater Distributed Control System in accordance with the Work Control Conduct Manual. This resulted in an unplanned loss of the gland seal exhauster trip safety function.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000341/2019-001-00 LER 2019-001-00 for Fermi Unit 2, Unplanned Loss of Safety Function of Gland Seal Exhauster Trip During Planned Maintenance Due to Inadequate Procedure.
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
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensee's readiness to cope with external flooding under the following conditions:
- High Lake Erie water level monthly averages
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency Diesel Generator (EDG) 12 while Combustion Turbine Generator (CTG)11-1 was out of service for planned maintenance during the week ending September 14, 2019
- (2) Electric Fire Pump while the Diesel Fire Pump and a Temporary Alternate Diesel Fire Pump were out of service for corrective maintenance during the week ending September 7, 2019
- (3) Division 1 Core Spray (CS) while Division 2 CS was out of service for planned maintenance during the week ending September 21, 2019
- (4) Division 2 Non-Interruptible Air System (NIAS) after planned maintenance during the week ending September 28, 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 Emergency Equipment Cooling Water (EECW) system during the week ending September 28, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) General Service Water Pump House during the week ending August 31, 2019
- (2) Auxiliary Building Sub-Basement and NIAS Room during the week ending September 28, 2019
- (3) Auxiliary Building Fifth Floor, Division 1 and Division 2 Standby Gas Treatment Rooms during the week ending September 28, 2019
- (4) Reactor Building Basement and Sub-Basement, Northeast Corner Room during the week ending September 28, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Torus Room
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 power ascension following a planned down power for Main Steam Isolation Valve (MSIV) testing and a rod pattern adjustment on September 8, 2019
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated an as-found simulator assessment during the week ending August 31, 2019
- (2) The inspectors observed and evaluated an as-found simulator assessment during the week ending September 7, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Emergent maintenance on Mechanical Draft Cooling Tower Fan D during the week ending August 3, 2019
- (2) Planned High Pressure Coolant Injection (HPCI) surveillance testing during the week ending August 24, 2019
- (3) Planned CTG 11-1 maintenance, new CTG fuel oil storage tank installation, with an installed Alternate Diesel Fire Pump during the week ending September 14, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Operability and functionality of the Standby Liquid Control (SLC) system following identification of a potential non-conservative Technical Specification associated with minimum SLC tank level, as documented in Condition Assessment Resolution Document (CARD) 19-21369
- (2) Operability and functionality of the Suppression Chamber (Torus) structure following a missed Technical Requirements Manual (TRM) surveillance requirement to perform an exterior visual inspection, as documented in CARD 19-25694
- (3) Functionality of the Diesel Fire Pump following identification of wear on the right angle drive anti-rotational clutch, as documented in CARD 19-26111
- (4) Operability and functionality of the Reactor Core Isolation Cooling (RCIC) system following identification of an abnormal RCIC flow controller reading while the system was in a standby condition, as documented in CARDs 19-26174 and 19-26198
- (5) Operability and functionality of the Division 2 Reactor Protection System (RPS),
Average Power Range Monitor (APRM), and Oscillation Power Range Monitor (OPRM) systems following abnormal light indications during a planned logic module functional test, as documented in CARD 19-26362
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Installation of an Alternate Diesel Fire Pump while the Diesel Fire Pump was out of service for an extended period (Temporary Modification)
- (2) Installation of Gland Seal Exhauster trip function (Permanent Modification)
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) RPS Channel A2 Reactor Vessel Level 1 and 2 agastat relays following planned maintenance during the week ending July 13, 2019
- (2) CTG 11-1 following planned maintenance during the week ending September 14, 2019
- (3) Division 2 NIAS following planned maintenance during the week ending September 28, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Low Pressure Coolant Injection (LPCI) Loop Select 480 Volt Swing Bus (72CF)automatic throwover scheme operability test during the week ending July 8, 2019
- (2) Emergency Diesel Generator (EDG) 14 24-hour run followed by hot fast restart during the week ending August 3, 2019
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) High Pressure Coolant Injection (HPCI) pump and valve operability test at 1025 pounds per square inch (psi) during the week ending August 24, 2019
- (2) Division 2 LPCI and Suppression Pool Cooling/Spray pump and valve operability test during the week ending August 31,
RADIATION SAFETY
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage (IP Section 02.01)
The inspectors evaluated radioactive material storage.
- (1) The inspectors toured the following areas:
- Fermi 2 Radioactive Waste Building Basement
- Fermi 2 Radioactive Waste Building Mezzanine
- Fermi 2 Radioactive Waste Building Main Floor
- Fermi 2 Radioactive Waste Onsite Storage Facility
The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:
- 55 Gallon Drum 6512; Fermi 2 Radioactive Waste Onsite Storage Facility
- 55 Gallon Drum 6572; Fermi 2 Radioactive Waste Onsite Storage Facility
- 55 Gallon Drum 6577; Fermi 2 Radioactive Waste Onsite Storage Facility
- 55 Gallon Drum 6578; Fermi 2 Radioactive Waste Onsite Storage Facility
- 55 Gallon Drum 6225; Fermi 2 Radioactive Waste Onsite Storage Facility
Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)
The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:
- (1) Liquid or Solid Radioactive Waste Processing Systems
- Fermi 2 Spent Fuel Pool Cooling and Clean Up
- Fermi 2 Asphalt Solidification System
- Fermi 2 Floor Drain Collection System
Radioactive Waste Resin and/or Sludge Discharges Processes
- Fermi 2 Spent Resin Tank
- Fermi 2 Primary Resin System
- Fermi 2 Resin Demineralizers
Waste Characterization and Classification (IP Section 02.03) (1 Sample)
The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:
(1)
- Fermi 2 Dry Active Waste
- Fermi 2 Condensate Resin System
Shipment Preparation (IP Section 02.04) (1 Sample)
The inspectors evaluated and observed the following radioactive material shipment preparation processes:
(1)
- EF2-19-051; UN (United Nations) 3321; Radioactive Material, LSA-II (Low Specific Activity-II), 7; 07/17/2019
Shipping Records (IP Section 02.05) (1 Sample)
The inspectors evaluated the following non-excepted package shipment records:
(1)
- EF2-17-136; Dewatered Resin Liner, LH-16-017; 01/12/2018
- EF2-18-007; Dewatered Resin Liner, LH-16-007; 01/19/2018
- EF2-18-009; Dewatered Resin Liner, LH-17-005; 02/12/2018
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 2 (July 1, 2018 - June 30, 2019)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) Unit 2 (July 1, 2018 - June 30, 2019)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) Unit 2 (July 1, 2018 - June 30, 2019)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 2 (July 1, 2018 - June 30, 2019)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 2 (July 1, 2018 - June 30, 2019)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) Unit 2 (July 1, 2018 - June 30, 2019)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the issuance of parts and storage of quality material that could be indicative of a more significant safety issue
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following Licensee Event Report (LER):
- (1) LER 2019-001-00, Unplanned Loss of Safety Function of Gland Seal Exhauster Trip during Planned Maintenance Due to Inadequate Procedure (ADAMS Accession ML19060A290). The circumstances surrounding this LER are documented in the Results Section of this report.
INSPECTION RESULTS
Incorrect Datum Used to Assess Lake Levels Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000341/2019003-01 Open/Closed
None (NPP)71111.01 The inspectors identified a finding of very low safety significance (i.e., Green) and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, when licensee personnel failed to have appropriate measures in place to assess the impact of projected Lake Erie water levels on the site. As a result, actual lake level, including any predicted maximum lake level during a flood watch or warning, was determined to be 1.3
[feet] higher during a flooding event than what was calculated.
Description:
As discussed in the Fermi Updated Final Safety Analysis Report (UFSAR), the determination of a mean Lake Erie water level reference point to ensure that safety-related structures, systems, and components (SSCs) are protected from flooding was based on 1935 New York Mean Tide (NYMT) lake level data. During this inspection period, the inspectors discovered that to calculate the maximum expected Lake Erie water level and assess site impact from potential flooding, the licensee utilized National Weather Service (NWS) data, which was based on 1985 International Great Lakes Datum (1985 IGLD) to determine the Lake Erie water level reference point. While inspecting the potential impacts of record high Lake Erie water levels, the inspectors discovered a non-conservative 1.3' difference between the two water level reference points.
The flooding design basis as described in the UFSAR ensured that safety-related SSCs would continue to be functional provided the Lake Erie water level was no higher than 575.3 using NYMT data. This accounted for a maximum postulated storm-induced wave surge and flooding to a level of 586.9 NYMT, or 3.9 above the site grade of 583.0. The inspectors reviewed NWS lake level data and discovered the current monthly mean level using 1985 IGLD data was 574.6, and was therefore less than the flooding design basis level of 575.3.
However, since the NYMT Lake Erie water level reference point was 1.3 lower than the NWS Lake Erie water level reference point, after adjusting for this difference, the actual maximum Lake Erie water level in the event of a storm-induced wave surging and flooding was 576.9 NYMT, which exceeded the maximum Lake Erie water level described in the UFSAR. The inspectors discussed the issue with licensee personnel, and the licensee subsequently performed evaluations to assess the actual impact on safety-related SSCs. In addition, the equipment and strategies assumed to be available for beyond-design-basis accidents (i.e.
FLEX equipment) were evaluated. Following these evaluations, and despite the high lake level and Lake Erie water level reference point difference, the licensee determined that safety-related SSCs would continue to be functional.
Regarding the licensees FLEX strategy, which relied upon adequate warning time from the NWS when certain flood levels were predicted, the licensee discovered that the NWS utilized a 1.5 uncertainty when performing lake level predictions. As a result, even with the difference in Lake Erie water level reference points, the plant would have received the prediction for extreme flood levels within a sufficient warning time to implement FLEX strategies.
As a result of the inspection, the licensee revised their Memorandum of Understanding (MOU) with the NWS to incorporate the difference between the datums. The licensee also implemented a monitoring program to ensure future Lake Erie water level increases were closely tracked.
Corrective Actions: The licensee entered this issue into their Corrective Action Program and established a formal monitoring plan to assess lake levels.
Corrective Action References: CARDs 19-25657, 19-25893, and 19-25820
Performance Assessment:
Performance Deficiency: The failure to develop appropriate measures to assess compliance with the flooding design and licensing basis, and to ensure an appropriate warning was received from the NWS to implement certain FLEX strategies was a performance deficiency.
Specifically, the difference in reference datum between site design documents and Lake Erie water level measurements was not accounted for.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, a misunderstanding of current or predicted Lake Erie water level could result in the plant being in a condition outside its design and licensing basis, inoperable safety-related equipment, or an inability to perform response actions as planned for extreme flooding conditions. The inspectors consulted IMC 0612, Appendix E, Examples of Minor Issues, Examples 3j and 3k and the associated Note that followed these examples.
Specifically, when errors are discovered regarding design assumptions, if reasonable doubt exists as to the operability of safety-related SSCs (regardless if they are later determined operable), the issues can be considered more than minor. For this issue, reasonable doubt existed regarding safety-related SSCs because with the datum difference that existed in Lake Erie water level measurement the licensee was not within the design and licensing basis for flood protection.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors also consulted Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation. Based on actual Lake Erie levels, the finding screened as having very low safety significance (i.e., Green), because there was no loss of safety function for any of the safety-related SSCs. Further, no issues with implementation of the licensees FLEX strategy were identified.
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 measures shall be established to assure that the applicable regulatory requirements and the design basis, as defined in Part 50.2 and as specified in the license application, for those SSCs to which this Appendix applies, are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, since issuance of the Fermi 2 Operating License on July 15, 1985, until July 12, 2019, the licensee failed to establish measures to assure that regulatory requirements and the design basis were correctly translated into specifications, procedures, or instructions. The licensee utilized information from the National Weather Service to receive notifications of flood watches and warnings that were inconsistent with the methodology used in the UFSAR flooding design basis, without compensation for the existing difference in Lake Erie water level reference points being used. As a result, actual Lake Erie water levels were identified to be 1.3 higher at the site than reported, which could challenge safety-related SSCs.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Response to an Out-of-Service Diesel Fire Pump Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000341/2019003-02 Open/Closed
[H.5] - Work Management 71111.18 A self-revealed finding of very low safety significance (i.e., Green) and an associated Non-Cited Violation (NCV) of Fermi License Condition 2.C.(9) was identified when licensee personnel failed to take appropriate actions in response to an out-of-service diesel fire pump.
Specifically, a temporary diesel fire pump (DFP) used to restore system functionality failed to function as designed and the risk plan that was developed could not be implemented as written.
Description:
On August 13, 2019, the licensee entered Technical Requirements Manual (TRM) Action 3.12.2 A.1 due to planned maintenance on the DFP. The TRM required either the pump to be restored or an alternate pump to be installed within 14 days. Upon discovery of extensive wear on components associated with the DFP right angle drive, the licensee concluded that the DFP would not likely be restored within 14 days. The licensee initiated actions to procure an alternate DFP to comply with the TRM requirements and restore full system capabilities. The licensee received and installed a temporary diesel-driven fire pump and exited the TRM action within the 14 day action requirement on August 27, 2019. On September 3, 2019, the licensee initiated a weekly test to operate the temporary DFP.
Approximately 10 minutes after the pump was started, pump coolant was observed to be leaking from the temporary fire pump. The pump was immediately shut down by the operators. Upon investigation, the licensee believed either the coolant had been overfilled and/or the engine had overheated. It was also noted that during the test the pump had been running with no system demand (i.e. dead-headed) during test preparations. After consulting with the vendor, the licensee determined that the pump should have had a minimum flow line installed to prevent damage from overheating under low-demand conditions. While the temporary pump did include a relief valve on the pump discharge, the system did not function in the same manner as the relief valve on the permanent pump, which provided both relief and minimum flow functions during pump operation.
In addition, the licensees risk plan to operate with a single electric pump available (pending re-design/re-work of the temporary DFP following this issue) relied upon power being available from the Combustion Turbine Generators (CTGs) in the event of a loss of offsite power. However, the licensee had removed all CTGs from service for planned maintenance.
As a result of these issues, the licensee coordinated with the temporary pump vendor to enable its relief valve to also function as a minimum flow line. Additionally, the licensee revised the risk plan to incorporate other strategies while the CTGs were out of service.
Corrective Actions: The licensee added a functional minimum flow line and revised the risk plan to ensure all elements of the plan could be performed.
Corrective Action References: CARDs 19-26837, 19-26615, and 19-26603
Performance Assessment:
Performance Deficiency: The failure to take necessary actions to minimize fire risk and perform repairs as soon as practical when fire equipment was taken out of service, as required by the fire protection program, was a performance deficiency. Specifically, fire risk was not minimized, and restoration of system capability was not timely when a temporary fire pump was installed with an inadequate design. Further, fire risk was not minimized when the risk plan that was developed could not be implemented as written due to credited backup power not being available.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the availability, reliability, and capability of the fire protection system was adversely impacted by the installation of a temporary DFP that could not function as designed. Further, although normal power was available, the risk plan also relied upon a backup source of power that was not available had it been needed.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding screened as having very low safety significance (i.e., Green) based on answering Yes to Question 1.4.3-A, which asked whether or not adequate fire water capacity still existed for equipment important for safe shutdown. In this case, the electric fire pump was still functional with normal power available.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee did not coordinate with the pump vendor to ensure all necessary plant technical requirements were incorporated into the design of the temporary fire pump. Further, site personnel with expertise in engineering modifications were not initially involved to ensure all technical requirements were incorporated into the design of the temporary fire pump.
Enforcement:
Violation: Fermi License Condition 2.C.(9) requires, in part, that the licensee shall maintain in effect all provisions of the approved fire protection program as described in the UFSAR. Section 9A.1.3.2.i of the Fermi UFSAR described the components of the fire protection program and required, in part, that assurance will exist that, actions are taken to minimize fire risk and repairs are made as soon as practical when fire equipment is taken out of service.
Contrary to the above, from August 27, 2019, until September 17, 2019, actions were not taken to minimize fire risk, nor were repairs made as soon as practical when the permanent diesel fire pump was out of service as required by Fermi License Condition 2.C.(9) as specified in UFSAR Section 9A.1.3.2.i. Specifically, a temporary diesel fire pump was installed that lacked a functional minimum flow line, which resulted in the pump failing its first weekly surveillance. This required extensive re-design, during which time the plant fire response capability was reduced to a single fire pump. Additionally, fire risk was not minimized because the fire risk plan that was developed for operating with only a single fire pump could not be implemented as written since backup power that was credited in the fire risk plan was not available.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Trend in Incorrect Parts Issued or Ordered 71152 During a semi-annual trend review, the inspectors noted that a large number of CARDs initiated since January 2019 identified incorrect parts that had been ordered or issued for work. The inspectors shared this observation with licensee staff who agreed that it appeared a trend existed. The licensee initiated CARD 19-27102 as a result of the inspectors observations to document five recent issues. During further discussions with the licensee, the inspectors noted that 12 additional CARDs dating back to January 2019 also identified issues with incorrect parts. Within this group of CARDs, and upon further review, the licensee discovered a potential adverse trend within one particular department. In reviewing the CARDs, the inspectors also noted an inconsistent use of cause-codes within the CARDS to describe the various parts issues. In some cases, no cause-codes were assigned at all.
As such, the failure to utilize a consistent method of assigning cause codes to CARDs could result in plant personnel missing opportunities to identify trends before they become larger concerns. At the end of the inspection period, the licensee planned to further assess this issue.
Observation: Failure to Address a Trend in the Storage of Quality Material 71152 During a semi-annual trend review, the inspectors reviewed Elevation CARD 19-21685 from the sites Nuclear Quality Assurance (NQA) organization regarding the storage and staging of parts. The inspectors had also noted what appeared to be a number of CARDS written throughout the year that addressed the improper storage and handling of materials. The NQA Elevation CARD documented numerous recurring issues with the storage and handling of quality material that dated back to 2015, along with some more recent issues. The inspectors reviewed several of the actions that resulted from the Elevation CARD and from previous NQA audits. One of the primary issues was the discovery that quality and non-quality material were not being stored in accordance with plant procedures. In particular, parts had been issued, not used, and then not properly returned to the warehouse within the procedurally required timeframe, which increased the likelihood that material traceability could be lost and/or parts could be stored in an uncontrolled environment. From an NQA audit finding identified in CARD 15-22778, the licensee implemented a corrective action which established a recurring activity to periodically inspect areas of the plant where improperly stored material was being found (i.e., PST [Performance Scheduling and Tracking] events). The inspectors discovered that while the PSTs were being performed and generally found no issues, NQA continued to identify that parts were stored inappropriately, which eventually resulted in the Elevation CARD. While discussing the PST events with the inspectors, the licensee also identified that there was an allowance for the return of improperly stored material to the warehouse of up to 60 days, contrary to the site procedural requirements of 7 days (online work) or 30 days (outage work). Further, the licensee identified that the PST events did not require a check of non-quality material being stored improperly, which had also been identified as an issue. The licensee initiated a CARD to address the issues with how the PSTs were written.
The inspectors also reviewed an Interim Effectiveness Review (IER) that the licensee performed to support closure of the NQA Elevation CARD. This IER was completed on August 30, 2019, and concluded that actions associated with the Elevation CARD had been performed satisfactorily. However, on August 14, 2019, NQA denied a request to close the CARD based on the identification of continuing issues with the storage of material and the failure to correctly follow the appropriate process for closing NQA Elevations. As of October 3, 2019, the inspectors noted there had been no additional actions created to address the failure to close the NQA Elevation CARD, or develop a revised action plan to measure the effectiveness given the apparent discrepancy between the conclusion of the IER and NQAs assessment regarding the effectiveness of the corrective actions that had been performed.
Failure to Properly Pre-Plan Work in Accordance with the Work Control Conduct Manual Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green FIN 05000341/2019003-03 Open/Closed
[H.7] -
Documentation 71153 A self-revealed finding of very low safety significance (i.e., Green) was identified when the licensee failed to properly pre-plan maintenance activities on the Feedwater Distributed Control System in accordance with the Work Control Conduct Manual. This resulted in an unplanned loss of the gland seal exhauster trip safety function.
Description:
On January 1, 2019, during reactor startup and at approximately 5 percent rated thermal power, the licensee began a planned maintenance activity to correct a failed main steam line flow indication associated with the digital Feedwater Distributed Control System (FW DCS).
This maintenance included performing a full system reboot of FW DCS. Before the maintenance was performed, the licensee attached an impact statement to the work order, as required by Work Control Conduct Manual (MWC) 10, Revision 39. Specifically, Step 4.40.1 of the MWC required, in part, In Maximo [the work order system software], under the safety/impact tab for Work Order, and under the impact statement section, provide the following: affected modes, Technical Specifications, technical requirements, expected alarms, precautions including system component status, any requirements prior to tagging, prohibited parallel work, trips/actions including trip(s) and action(s) to prevent, indications/actuations including indication(s) and actuation(s), system impact/PMT [post maintenance testing]
including plant system impact, system impact. However, the licensee failed to include information regarding the rod worth minimizer (RWM) and the turbine gland seal exhauster (GSE) trip in the impact statement that should have been included. When reviewing the work order prior to performing the maintenance activity, the Operations crew on shift noted the impact statement was missing a reference to the Technical Specifications for the RWM. As a result, the licensee was able to be prepared for the impact of the work on the RWM and enter the appropriate Technical Specification (TS) Limiting Condition for Operation (LCO).
However, the licensee failed to identify that the GSE trip function was also impacted, and therefore during the maintenance activity did not enter the associated TS LCO required action.
The GSE trip function is relied upon between 0 and 10 percent rated thermal power to ensure that dose limits do not exceed regulatory limits during a control rod drop accident. The impact to the GSE trip function when resetting the FW DCS resulted from a modification that was installed during the most recent refueling outage in October 2018. Therefore, resetting the FW DCS would not have previously impacted the GSE trip.
When FW DCS was reset, annunciator 4D32, MSL [Main Steam Line] Radn [Radiation] Mon
[Monitor] GS [Gland Seal] STM [Steam] EXHS [Exhaust] Trip Enabled, cleared and unexpectedly re-alarmed in the control room. Operators subsequently determined that the GSE trip function was disabled during the reset of FW DCS, which lasted approximately 1 minute and 19 seconds. As a result, the licensee submitted (EN) 53811 pursuant to 10 CFR 50.72(b)(3)(v)(C) and 10 CFR 50.72(b)(3)(v)(D) as any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to: 1) control the release of radioactive material, and 2) mitigate the consequences of an accident, respectively. On March 1, 2019, the licensee submitted Licensee Event Report (LER) 05000341/2019-001-00 for this event.
The licensee performed a causal evaluation and determined that the cause of the event was that the Failure Modes Effect and Analysis (FMEA) discussion in the engineering modification package did not specifically identify a loss of FW DCS as a failure mode for the GSE trip. In addition, the inspectors noted that Section 4.40, Work Order Safety/Impact Section Completion, of MWC 10 did not include suggested reference documentation for Operations personnel to review. As a result, the inspectors questioned the licensee as to what documentation was reviewed when generating the impact statement. The licensee stated a review of previous FW DCS work orders and impact statements, and the applicable FW DCS procedures was completed. Additionally, when reviewing corrective actions, the inspectors questioned whether all relevant documents were fully updated and if any additional failure modes were evaluated. Upon further review, the licensee determined additional documents were required to be updated to include information regarding the impact of the FW DCS on the GSE trip function. Also, the licensee determined there was a lack of alignment between the causal evaluation and correction actions, such that a review of additional failure modes was not performed to address the FMEA gap that was identified.
Corrective Actions: The licensee entered the issues into their Corrective Action Program.
Planned corrective actions included updating additional applicable procedures and design documents with the relevant GSE trip information and evaluating the lack of alignment between the causal statement and corrective actions.
Corrective Action References: CARDs 19-27084 and 19-26836
Performance Assessment:
Performance Deficiency: The licensees failure to properly pre-plan maintenance activities on the FW DCS in accordance with the Work Control Conduct Manual was a performance deficiency. Specifically, the licensee failed to evaluate the impact of FW DCS on the GSE trip instrumentation, which resulted in the unplanned loss of the GSE trip safety function.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
Specifically, the licensee disabled the GSE trip when the function was required. Without mitigating actions, the failure to trip the GSEs could have resulted in a dose above regulatory requirements if a control rod drop accident had occurred. Therefore, the required barrier was adversely impacted.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the performance deficiency affected the Barrier Integrity cornerstone. The finding was determined to be of very low safety significance (i.e., Green), because the inspectors answered Yes to the question, Does the finding only represent a degradation of the radiological barrier function provided for the control room, or auxiliary building, or spent fuel pool, or SBGT [Standby Gas Treatment ] system (BWR)? in Exhibit 3, Barrier Integrity Screening Questions.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. The licensee failed to create and maintain complete, accurate and up-to-date documentation. Specifically, the licensees engineering design change document failed to completely identify all failure modes. Additionally, the licensee failed to update documentation associated with the FW DCS and GSE systems when implementing the plant modification in 2018, which could have aided in the licensees system impact evaluation.
Enforcement:
Because the Work Control Conduct Manual was not subject to the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plant, the inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 16, 2019, the inspectors presented the integrated inspection results to Mr. P. Dietrich, Senior VP and Chief Nuclear Officer, and other members of the licensee staff.
- On July 18, 2019, the inspectors presented the Radiaton Protection inspection results to Mr. M. Caragher, Executive Director - Nuclear Production, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
19-25280
NRC Identified: Local Lake Level Indication Reads Higher
than UFSAR Assumed Maximum Starting Level for Flood
07/12/2019
19-25458
Determine Impact of CARD 19-25280 and EFA-A30-19-007
on FLEX and Hardened Vent Required Equipment in MOP25
07/18/2019
19-25657
AOP 20.000.01 MOU for Flooding is Not Specific in Datum
Reference
07/29/2019
19-25893
Flood Analysis Past Functionality of FLEX Strategy in
Reverence to CARD 19-25657
08/05/2019
Miscellaneous
Adverse
Condition
Monitoring Plan
ACMP 19-016
Lake Erie Water Level Elevation
IGLD 1985
Brochure on the International Great Lakes Datum 1985
01/1992
NARP-18-0277
Letter of Agreement Between Fermi 2 and NOAA - National
Weather Service
11/19/2018
NARP-19-0140
Letter of Agreement Between Fermi 2 and NOAA - National
Weather Service
07/31/2019
National Ocean
Survey, Detroit,
History and Theory of Datum Planes of the Great Lakes
TE-K11-19-039
Impact of Incorrect Datum Reference Used for Design
Maximum Flood Level on Past Functionality of FLEX/HCVS
(CARD 19-25657)
Procedures
20.000.01
Acts of Nature
0, 48, 49, 54
29.400.01
ARP 7D22
General Service H2O Screen a H2O Level High/Low
MOP01-200
Severe Weather Guidelines
MOP25
Beyond-Design-Basis Event Coping Strategies Program
Document
Work Orders
38560633
Lube and Inspect Reactor/Auxiliary Building Water Tight
Doors
07/16/2014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.04Q Corrective Action
Documents
05-24306
Add Electric Fire Pump to DC-6105, Dedicated Shutdown for
Appendix R Loads
07/20/2005
18-28658
Discharge Pressure Above Normal Parameters
10/23/2018
Drawings
Diagram Core Spray System C.S.S. Reactor Building
Core Spray System Functional Operating Sketch
AG
Non-Interruptible Control Air System Division I & II
Functional Operating Sketch
Emergency Diesel Generator System Functional Operating
Sketch
BH
P&ID Diesel Generator System Division I RHR Complex
P&ID Diesel Fuel Oil System and Lube Oil System Division I
RHR Complex
Miscellaneous
T13019
Temporary Change Notice - Fire Water Suppression System
Procedures
23.129
NIAS Divisions 1 and 2 Control Air Startup
117
23.203
Core Spray System
23.307
Emergency Diesel Generator System
27
28.504.03
Fire Suppression Water System Simulated Automatic
Activation Test
Work Orders
49771706
Perform 28.504.09 Electric Fire Pump Monthly Operability
Test
07/02/2019
50002740
Perform 28.504.09 Electric Fire Pump Monthly Operability
Test
07/30/2019
Drawings
Emergency Equipment Cooling Water System Division II
Emergency Equipment Cooling Water System Division I
Procedures
23.127
Reactor Building Closed Cooling Water/Emergency
Equipment Cooling Water System
145
71111.05Q Corrective Action
Documents
19-24505
2019 Fire Protection Self-Assessment Deficiency -
Investigate GSW Fire Rated Assemblies to be Included into
TRM 3.12.8
06/13/2019
19-26383
Diesel Fire Pump Room Fire Doors were Found Blocked
Open Without a Fire Impairment
08/23/2019
19-26426
Need DCR for Diesel Fire Pump Procedures to Address Log
Entry while Fire Doors to Diesel are Open
08/26/2019
Fire Plans
FB-AB-5-16b
Auxiliary Building, South Standby Gas Treatment System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(SGTS) Room, Zone 16, EL. 6776
FP-AB-5-16a
Auxiliary Building North Standby Gas Treatment (SGTS)
Room, Zone 16, Elevation 6776
FP-AB-5-16b
Auxiliary Building, South Standby Gas Treatment System
(SGTS) Room, Zone 16, Elevation 6776
Miscellaneous
9A.4-44
Fermi 2 UFSAR
TR 3.12.8
Fire Protection Fire Rated Assemblies
Procedures
28.502.02
CO2 System Valve Lineup Verification
35.000.242
Barrier Identification/Classification
FP-AB-BMT-4
Control Air Compressor Room, Zone 4 Elevation 5510
FP-GSW-1-31
General Service Water Pumphouse Zone 31
FP-RB-B-5b
Reactor Building Basement Northeast Corner Room Zone 5,
Elevation 5620
FP-RB-SB-5a
Reactor Building Sub-Basement Northeast Corner Room,
Zone 5, Elevation 5400
Work Orders
47714949
Perform 28.502.18 Division 1 SGTS CO2 Actuation Test
2/13/2018
48565671
Perform 28.502.18 Division 2 SGTS CO2 Actuation Test
01/31/2019
Calculations
DC-5426
PBOC - High and Moderate Energy Line Break Evaluation
D
Corrective Action
Documents
19-23894
NRC Identified Concern: Housekeeping in Torus
05/21/2019
Drawings
29.100.01 SH 5
Secondary Containment and Radiation Release
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
Reactivity
Maneuvering Plan
September 2019 RPA
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SS-OP-904-1903
Evaluation Scenario
Procedures
MOP19
Operations Conduct Manual, Reactivity Management
26A
Corrective Action
Documents
19-26718
Minimum Flow Line for Alternate Diesel Fire Pump Detached
from Pump Discharge Line
09/07/2019
19-26837
CTG Black Start Capability Removed When Relied Upon for
FPEE-19-0003
09/11/2019
Drawings
Emergency Equipment Cooling Water Division 1
Miscellaneous
EF2-PRA-005.11
High Pressure Coolant Injection (HPCI) System - System
Information Notebook
MMR12
Equipment Out of Service Risk Management
ODE-20
Protected Equipment
Procedures
20.300.120kV
Loss of 120kV
20.300.SBP
Loss of Offsite and Onsite Power
23.202
High Pressure Coolant Injection System
116
23.206
Reactor Core Isolation Cooling System
103
23.208
RHR Complex Service Water Systems
26
23.501.01
Fire Water Suppression System
MMR App H
On-Line Core Damage Risk Management Guidelines
MMR12
Equipment Out of Service Risk Management
MOP05-100
Protected Equipment
2C
ODE-20
Protected Equipment
Calculations
DC-0623
Standby Liquid Control System Design Calculations
A
DC-4997
Standby Liquid Control Instrumentation Surveillance
Calibration
D
DC-4997
SLC Design Value Changes to Meet Power Uprate/Higher
Energy Cycles
DC-5961
WS01 Boron Injection Variables
DC-5962
WS01A Boron Weight Equivalents
Corrective Action
Documents
16-26260
Diesel Fire Pump Angle Drive Inspection Findings
08/09/2016
19-21369
Tech Spec 3.1.7 Figure 1 SLC Tank Level Limits Potentially
Non-Conservative
2/21/2019
19-24615
Diesel Fire Pump Engine SWI>Action Level B
06/18/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
19-25694
TRM Surveillance Requirement 3.6.1.1 Not Referenced in
Procedure or SST Event and Potentially Not Performed in
RF19
07/29/2019
19-26111
Condition of the DFP Right Angle Anti-Rotational Clutch
08/13/2019
19-26174
RCIC Flow Controller Issue Unable to be Resolved Under
08/15/2019
19-26186
Lack of Follow-Through on a Known Component Degraded
Condition
08/16/2019
19-26198
RCIC Flow Issue
08/16/2019
19-26237
Missing Bolts in DFP Right Angle Drive
08/19/2019
19-26362
While Performing 44.010.143 Division 2 RPS Two Out of
Four Logic Module Functional Test on APRM 2 OPRM Trip
Light Did Not Come On Nor Did RPS Test Box Light Come
On (Both Acceptance Criteria)
08/22/2019
19-27084
Review and Address CARD Quality Issues with CARD 19-
20002
09/20/2019
Drawings
107E5901WH
C5100, C51R809A & B
107E5901WH
Two-Out-Of-Four Logic Module
29.100.01 SH 1A
29.100.01 SH 3A
RPV Flooding & Emergency Depressurization - ATWS
Schematic Diagram Power Range Neutron Monitoring
Reactor Protection System Outputs
H
Schematic Diagram Reactor Protection System Relay
Tabulation
X
Schematic Diagram Reactor Protection System Trip System
B System Relays
X
Schematic Diagram Reactor Protection System Trip System
A Scram Trip Logic
M
Schematic Diagram Reactor Protection System Scram
Solenoids
N
RCIC System Instrumentation Loop
W
6I72102155009
Schematic Diagram Reactor Protection System Trip System
B Scram Trip Logic
M
Core Spray System C.S.S. Reactor Building
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Reactor Core Isolation Cooling System
BE
Reactor Core Isolation Cooling (RCIC) System Barometric
Condenser
Miscellaneous
MQA13-100
Quality Assurance Conduct Manual, Trend Condition
Evaluation Report
TE-P80-19-035
Condition of the Diesel Fire Pump Right Angle Drive
Procedures
44.110.004
Remote Shutdown RCIC Flow Indication Calibration
Work Orders
53945247
RCIC Pump Discharge Flow Transmitter Elec
Corrective Action
Documents
19-27387
Alternate Diesel Fire Pump Trip during Weekly Surveillance
Run
09/30/2019
Drawings
Visual Annunciator & Sequence Recorder Alarm Schematic
V
Control System Feedwater (DCS-FW) External Connections
H
Schematic Diagram Gland Sealing Steam Exhauster (E&W)
G
Fire Protection Functional Operating Sketch
BX
Engineering
Changes
19-0014
Alternate Diesel Fire Pump (ADFP)
C
Engineering
Evaluations
FPEE-19-003
TR LCO 3.0.3 Evaluation for the Non-Functional Diesel Fire
Pump TRM Section TR3.12.2
Miscellaneous
EDP-37673
EDP Continuation Sheet - Scope of Work
Fermi 2 UFSAR
Other Auxiliary Systems
LRN-01-0410,
LCR H01-03
Letter to NRC from PSEG Nuclear LLC, Request for Change
to Technical Specifications Mechanical Vacuum Pump Trip
Instrumentation Hope Creek Generating Station Facility
Operating License NPF-57 Docket No. 50-354
01/04/2002
Work Request
Revision
55179348
PMT and TRSR Verification for TM 10-0014, Revision E
Procedures
28.504.03
Fire Suppression Water System Simulated Automatic
Actuation Test
Work Orders
54828250
TM 19-0014, Install Alternate Diesel Fire Pump at Pump
House
08/16/2019
54938127
Perform Temporary Diesel Fire Pump Weekly Operability
Test
09/12/2019
Corrective Action
19-25181
Schedule Adherence A Work Not Completed as Scheduled
07/09/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
19-26850
CTG 11-1 Lube Oil Leak
09/12/2019
19-26876
CTG 11-1 DC Power Supply Failure Alarm During SOP Run
09/12/2019
Drawings
Schematic Diagram Nuclear Steam Supply Shut Off System
Trip System A
O
Schematic Diagram NSSS System Main Steam Line
Outboard Isolation Valves B2103F028A, B, C, D
S
Schematic Diagram Reactor Protection System Testability
Modification
L
Engineering
Changes
70056
CTG 11 Fuel Oil Tank Replacement
C
Miscellaneous
Fermi 2 Archived Operator Log
09/24/2019 -
09/26/2019
Letter from Detroit Edison to NRC: Proposed Technical
Specification Change (License Amendment) - Response
Time Testing
05/23/2002
Procedures
23.324
Supervisory Control-120 KV Switchyard and CTG 11
Generators
23.601
Instrument Trip Sheets
35.318.017
Inspection and Testing of Multi-Contact Auxiliary Relays
44.020.011
Response Time Test of B21-N081A Reactor Vessel Low
Water Level 1 Transmitter
Work Orders
299261
Replace RPS Channel A2 Reactor Vessel Level 1 and 2
Agastat Relays
07/09/2019
46187487
Replace Desiccant in Division 2 NIAS Dryer
09/24/2019
244081
Change Crankcase Oil, Inspect Belts, Lube Motor Bearings,
and Clean Exterior
09/12/2019
50349443
Clean and Inspect CTG 11-1 Water Cooler and Inspect
Cooler Belts
04/02/2018
50349457
Calibrate 63HR Hydraulic Ratched Pressure Switch on CTG
11-1
04/02/2018
50349598
Semi-Annual Inspection of CTG 11-1
04/02/2018
50452150
Piping Tie In (FOST)
04/15/2018
54721898
CTG 11-1 Liquid Fuel Pump Bypass Servo Valve is Leaking
Fuel Oil While CTG is Operating
08/06/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
55165181
Repair CTG 11-1 Lube Oil Leak
09/12/2019
Corrective Action
Documents
17-26455
Procedure Revision for LPCI Swing Bus Surveillance
24.321.07
08/01/2017
19-26353
HPCI Barometric Condenser Vacuum Pump Flashing Amps
08/22/2019
Drawings
Schematic Diagram 480V Essential Bus 72C Position 3C &
Q
High Pressure Coolant Injection System (HPCI) Reactor
Building
BN
High Pressure Coolant Injection System Barometric
Condenser (HPCI) Reactor Building
AJ
Residual Heat Removal (RHR) Division 2
CB
One Line Diagram 480V Essential Bus 72B, 72C, 72E, and
2F
BA
Miscellaneous
DC-0367
Pump Curves and Requirements, Volume 1
Q
Procedures
23.307
Emergency Diesel Generator System
26
24.202.01
HPCI Pump and Valve Operability Test at 1025 PSI
119
24.204.06
Division 2 LPCI and Suppression Pool Cooling/Spray Pump
and Valve Operability Test
24.307.33
Emergency Diesel Generator No. 14-24 Hour Run Followed
by Hot Fast Restart
Work Orders
48747466
Perform 24.404.06 Division 2 LPCI and Torus Cooling/Spray
Pump and Valve Operability Test
03/01/2019
49471252
Perform 24.204.06 Division 2 LPCI and Torus Cooling/Spray
Pump and Valve Operability Test
05/30/2019
49759149
Perform 24.321.07 480V Swing Bus 72 CF Automatic
Throw-Over Scheme Operability
07/08/2019
244112
Perform 24.202.01 HPCI Pump/Flow Test and Valve Stroke
at 1025 PSIG
08/20/2019
298122
Perform 24.204.06 Division 2 LPCI and Torus Cooling/Spray
Pump and Valve Operability Test
08/21/2019
Corrective Action
Documents
CARD 18-21171
Dose Estimate Exceeded When Loading 8-120 Liner for
Transportation
2/12/2018
CARD 18-22666
Vendor Box Arrived on Site as a Non-Radioactive Shipment
With a RAM Tag
03/30/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 18-23247
Telepole Failed Source Check Following RAM Shipment
Receipt
04/22/2018
Corrective Action
Documents
Resulting from
Inspection
CARD 19-25399
NRC Identified - Repairs to Spent Resin Tank Required
07/17/2019
Miscellaneous
NPRP-19-0016
Scaling Factors Report Dated February 4, 2019
2/14/2019
Procedures
65000.506
Shipping Low Specific Activity (LSA) Radioactive Material
65000.509
Shipping Greater Than A1, A2 Quantities of Radioactive
Material
65000.510
Shipping Limited Quantity of Radioactive Material
65000.610
Shipping Cask USA/9168/B(U)
Shipping Records EF2-17-136
Dewatered Resin Liner, LH-16-017
01/12/2018
EF2-18-003
Dewatered Resin Liner, LH-16-007
01/19/2018
EF2-18-009
Dewatered Resin Liner, LH-17-005
2/12/2018
71151
Corrective Action
Documents
Resulting from
Inspection
19-27175
NRC Identified Typographical Error in RCIC Monthly
Performance Indicator
09/24/2019
Miscellaneous
MSPI Derivation Report - Cooling Water System-
Unavailability Index
06/30/2019
Fermi 2 RHR Performance Indicators
08/01/2018 -
07/31/2019
MSPI Derivation Report - Residual Heat Removal System-
Unreliability Index
06/30/2019
MSPI Derivation Report - Residual Heat Removal System-
Unavailability Index
06/30/2019
Fermi 2 RCIC Performance Indicators
07/01/2018 -
06/30/2019
MSPI Derivation Report - Heat Removal Systems-
Unreliability Index
06/30/2019
N/A
Monthly Performance Indicator Submittal to the NRC for
Occupational Exposure Control Effectiveness
07/01/2018 -
06/01/2019
N/A
Monthly Performance Indicator Submittal to the NRC for
07/01/2018 -
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RETS/ODCM Radiological Effluent Occurrences
06/01/2019
N/A
Monthly Performance Indicator Submittal to the NRC for
RCS Specific Activity
07/01/2018 -
06/01/2019
Corrective Action
Documents
CARD Search Results, Keyword=Incorrect Part
01/01/2019 -
09/13/2019
19-21685
NQA Elevation - Leaders Actions Have Been Insufficient in
Correcting Fundamental Worker Behaviors for the Control
and Traceability of Safety-Related Material, Parts, and
Components
03/05/2019
19-21750
OSC Cognitive Trend in Supply Chain Performance Issues
03/06/2019
19-23431
Cognitive Trend: Non-Maintenance Related Rework Events
Due to Inadequate Engineering Parts Evaluations
05/03/2019
19-25682
Late Adds - Material Being Added to Work Orders Inside of
T10 (Adverse Trends per OSC)
07/29/2019
19-27524
NRC Identified Trend - Parts Issues
10/03/2019
Miscellaneous
NPMA-16-0040
Effectiveness Review for CARD 15-22778: NQA Audit
Finding - Safety Related (QA1) and Non-Safety (NQ) Spare
Parts Improperly Maintained
04/05/2016
Work Orders
44401214
PM: ME76; Perform MRTW of Unused Q Material from MEP
Buildings
05/20/2017
44477754
PM: ME77; Perform MRTW of Unused Q Material from MOV
Shop and Building 49
05/19/2017
Corrective Action
Documents
18-30364
MSL B Flowrate Meter Downscale
2/25/2018
19-20002
4D32 MSL RADN MON GS STM EXHS Trip Enabled
Cleared with Power Less Than 10 Percent
01/01/2019
19-24865
19-20002-08 Performance Gap Analysis Tracking
06/28/2019
19-26836
NRC Identified 45.618.003 Reactor Feedwater System
Bailey DCS Maintenance Incomplete Information
09/11/2019
19-27084
Review and Address CARD Quality Issues with CARD 19-
20002
09/20/2019
Procedures
20.000.07
Fuel Cladding Failure
23.107
Reactor Feedwater and Condensate Systems
149
45.618.003
Reactor Feedwater System Bailey DCS Maintenance
ARP 3D82
Main Steam Line CH A/B/C/D Radiation Monitor Hi-Hi
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MES90-119
Preparation and Control of Engineering Design Packages
MWC10
Work Control Conduct Manual-Chapter 10, Work Package
Preparation
Work Orders
2849877
Main Steam Line Flow Failed for Steam Lines on DCS Flat
Panel Display, Halt/Restart Both FW DCS Processors
01/1/2019