IR 05000341/2019010
| ML19273A900 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/30/2019 |
| From: | Eric Duncan Reactor Projects Region 3 Branch 4 |
| To: | Fessler P DTE Energy |
| References | |
| IR 2019010 | |
| Download: ML19273A900 (24) | |
Text
September 30, 2019
SUBJECT:
FERMI POWER PLANT, UNIT 2BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000341/2019010
Dear Mr. Fessler:
On August 16, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Fermi Power Plant, Unit 2 and 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the sample reviewed, the team determined that the station had a low threshold for identifying issues and entering them into the Corrective Action Program. A risk-based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were usually implemented in a timely manner, commensurate with their safety significance.
However, the team identified examples of weaknesses in evaluating problems, and in the timeliness of corrective actions taken to resolve those problems.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, operating experience was generally entered into the Corrective Action Program when appropriate and evaluated in accordance with Corrective Action Program implementing procedures. The use of operating experience was integrated into daily activities and found to be generally effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for most departments based on the documents the team reviewed. Most of the self-assessments reviewed were found to be effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. However, the team identified some weaknesses in your audits and self-assessments, and some inadequacies in your evaluation of industry and NRC operating experience.
Finally the team reviewed the stations programs to establish and maintain a safety conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on our review of your recent safety culture assessments and the results of the interviews we conducted, the team did not identify any impediment to the establishment of a safety conscious work environment. Your staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised.
The NRC inspectors did not identify any finding or violation of more than minor significance.
Based on the samples reviewed, and although a finding or violation was not identified during this inspection, the range and number of identified deficiencies and weaknesses in the Corrective Action Program and supporting processes led the team to conclude that your overall implementation of the Corrective Action Program at Fermi was marginally effective.
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-2019-010-0047
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
July 29, 2019 to August 16, 2019
Inspectors:
V. Meghani, Reactor Inspector
R. Ng, Project Engineer
J. Rutkowski, Project Engineer
A. Shaikh, Senior Reactor Inspector
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 a biennial problem identification and resolution 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.
INSPECTION RESULTS
Assessment 71152B Based on the samples reviewed, and the range and number of deficiencies and weaknesses in the licensee's Corrective Action Program and supporting processes that were identified through these samples, the team concluded that the licensee's implementation of the Corrective Action Program was marginally effective.
Effectiveness of Problem Identification:
Based on the samples reviewed, the team concluded that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team determined that problems were usually entered into the Corrective Action Program in a complete and accurate manner.
The team also noted that some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program. These externally-identified deficiencies represented missed opportunities by licensee staff to identify issues to be addressed through the Corrective Action Program.
The team found that the licensee utilized a number of Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. The licensee generally performed adequate department self-assessments and quality assurance audits to identify issues in station processes. Similarly, the licensee generally screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.
However, the team identified several issues related to the self-assessment process and the Operating Experience Program. Details of these issues are discussed in the Observation section of this report.
The team determined that the licensee was generally effective at trending low level issues and taking appropriate corrective actions to prevent more significant issues from developing.
The licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The team performed a 5-year review of emergency diesel generator leakage. As part of this review, the team interviewed the emergency diesel generator system engineer, reviewed corrective action resolution documents (CARDs), plant health reports, and condition evaluations. In addition, the team performed a system walkdown to assess the material condition of the emergency diesel generator system and surrounding areas. The team concluded that emergency diesel generator leakage concerns were identified and entered into the Corrective Action Program at a low threshold, and concerns were resolved in a timely manner commensurate with their safety significance. For the areas walked down, the team did not identify any additional issues.
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the team determined that licensee performance was adequate with opportunities for improvement at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. The Ownership Screening Committee and the Management Review Committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. The team observed a productive dialogue between the members of these committees and the members challenged each other when dispositioning CARDs.
In general, once a degraded or non-conforming condition was identified, the Corrective Action Program directed that an equipment operability or functionality review be performed. The majority of the samples reviewed were evaluated in a timely manner. However, the team identified an issue with the technical rigor of some of these evaluations. Additional details of this issue are discussed in the Observation section of this report.
The team identified several issues related to the untimely screening and inadequate evaluation of operating experience. Additional details of these issues are described in Observation section of this report.
Effectiveness of Corrective Actions:
Based on the samples reviewed, the team determined that the licensee was adequate with opportunities for improvement in corrective action implementation. In general, corrective actions for deficiencies that were safety significant were implemented in an adequate and timely manner. Problems identified using a root cause or other cause methodologies were, in general, resolved in accordance with Corrective Action Program requirements. The corrective actions assignments that were sampled by the team for selected NRC documented violations and for licensee event reports (LERs) were generally effective and timely.
However, the team identified a relatively high number of systems that were categorized as Maintenance Rule (a)(1). The team reviewed selected Maintenance Rule (a)(1) systems and their corrective action plans and concluded there was a weakness in the licensee's equipment reliability program. Additional details of this weakness are discussed in the Observation section of this report.
The team also identified that corrective actions from Self-Assessments and Nuclear Quality Assurance (NQA) audits were not always implemented in a timely manner. Additional details of these issues are described in Observation section of this report.
Assessment 71152B Based on the samples reviewed, the team determined that licensee performance in the use of operating experience was adequate with some opportunities for improvement. The licensee screened industry and NRC operating experience information for station applicability. Based on these initial screenings, the licensee initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as CARD reviews and investigations. However, the team identified a number of issues regarding the timeliness of the screening and technical rigor of Operating Experience evaluations. These issues are further discussed in the Observation section of this report.
Assessment 71152B Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was adequate with some opportunities for improvement. The licensee performed department self-assessments and quality assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold.
The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. Nuclear Quality Assurance (NQA) identified deficiencies with the licensee's processes and those issues were addressed by the station through the Corrective Action Program. However, the team identified several weaknesses between department self-assessments and NQA audits.
These weaknesses were related to the ability of the self-assessment and audit programs to cause timely, lasting change and prevent more significant issues from occurring. Additional details are discussed in the Observation section of this report.
Assessment 71152B Based on a review of documents and interviews with licensee staff, the team did not identify any impediment to the establishment of a safety conscious work environment.
The team reviewed the results from the 2018 Nuclear Safety Culture Assessment (NSCA)performed by the licensee, the subsequent root cause evaluation that was completed as prescribed by CARD 19-23612, Station Leaders Have Allowed a Culture of Rationalizing and Tolerating Unacceptable Performance, and Nuclear Safety Culture Monitoring Panel meeting minutes. The team also conducted focus group meetings and one-on-one interviews with more than 50 licensee staff concerning the effectiveness of the Corrective Action Program, the ability to raise issues, and the freedom from potential retaliation for raising issues.
In general, the licensee's staff was aware of and familiar with the Corrective Action Program and other processes, such as the Employee Concerns Program, to raise nuclear safety concerns. Licensee staff indicated they could raise safety concerns without a fear of retaliation. Through the interviews and document reviews, the team was not provided or identified any examples of retaliation for raising nuclear safety concerns. Although some work groups felt that the Corrective Action Program was not effective for addressing low level issues, the staff interviewed believed that operational issues and issues with high safety significance were being appropriately addressed in a timely manner.
Observation: Evaluation Technical Rigor Weaknesses 71152B During this inspection, the team identified a number of examples in which the licensees evaluations lacked technical rigor. In several cases, incorrect assumptions were used in decision-making processes such that the significance of the issue was marginalized, or the corrective actions were delayed.
For example, during the review of a Nuclear Quality Assurance (NQA) audit finding documented in CARD 19-20869, Inadequate Control of Safety-Related Fuses Maintained and Installed by Operators, the team identified that the shift manager relied on the successful operation of safety-related systems following fuse replacements and continued satisfactory performance of surveillances as an indicator of the safety-related pedigree of the newly installed fuses. The shift manager concluded that no nonsafety-related fuses had been installed in safety-related systems. Since satisfactory performance of post-maintenance testing and surveillances was not necessarily indicative of fuse performance at designed fault or over-current conditions, the team questioned the licensees operability conclusion. The licensee then provided an alternate basis for operability, which included operator interviews following the NQA audit finding and the procedure requirements to verify and document that correct fuses were being installed for use. However, the team noted that the NQA audit finding specifically stated that operators were not documenting the fuse replacement information and that safety-related and nonsafety-related fuses were stored in the same lockers. The licensee subsequently performed a cross-verification of safety-related and nonsafety-related fuses located in the same locker and determined that safety-related fuses did not have corresponding nonsafety-related fuses in the same locker boxes based on examining the procurement master material list. The licensee entered this issue into their Corrective Action Program as CARD 19-25794.
During the review of CARD 08-26828, Non-Qualified Support System to Ensure Adequate Post-LOCA [Loss-Of-Coolant-Accident] Emergency Depressurization, the team noted that this issue had been identified more than 10 years ago, but had not yet been resolved. This issue was associated with the qualification of equipment relied on to mitigate a design basis small break LOCA. The licensee classified this issue as a condition adverse to quality, but considered the emergency core cooling system fully operable. Following discussions with Engineering and Operations staff, the team determined that the staff in these departments did not have a common understanding of the issue. Operations staff stated they would follow the subject emergency operating procedure and restore the air system to containment when required to emergency depressurize the reactor pressure vessel. Engineering staff, however, understood that the air system may be available, but could not be relied upon for design basis accident mitigation because the equipment was not safety-related. This information was not shared between the two groups. It was unclear why Operations staff did not obtain that information from Engineering staff, even after the team posed the question. Therefore, the team concluded that a lack of technical rigor in the licensees operability determination for CARD 08-26828 led to an incorrect conclusion. The licensee entered this issue into their Corrective Action Program as CARD 19-26112 and 19-26154. At the end of the inspection, no additional compensatory actions were required since the licensee had recently verified that adequate trapped air inside the drywell piping had always been available to support emergency depressurization. As a result, the team did not identify a finding or violation of more than minor significance.
Both examples highlighted a lack of technical rigor in the licensees evaluation. As a result, incorrect assumptions were relied upon in the licensees decision-making process. At the end of the inspection, the licensee planned to evaluate this identified weakness through the CARDs identified above.
Observation: Equipment Reliability Program Weaknesses 71152B At the time of this inspection, 14 systems were in a Maintenance Rule (a)(1) status; which was unusually high, particularly for a single unit site. The team reviewed the Maintenance Rule (a)(1) system performance recovery plans for selected systems and interviewed the stations Maintenance Rule Program coordinator. As associated with these Maintenance Rule (a)(1) systems, the team also reviewed all Tier 1 system health reports and several Tier 2 and Tier 3 system Corrective Action Program documents. The licensee utilized system health reports as a trending tool for Tier 1 systems.
The team determined that the performance recovery plans were detailed and listed requirements and actions to return the systems to a Maintenance Rule (a)(2) status. The team concluded that the licensee had appropriately documented equipment issues that led to a Maintenance Rule (a)(1) status in the Corrective Action Program. Given that system health reports were generated only for Tier 1 systems and not considered in the Maintenance Rule review process, it was unclear if the licensees equipment trending practices could have identified an issue and taken actions prior to reaching a Maintenance Rule (a)(1) status. The team considered this a weakness in the licensees equipment reliability program.
The licensee completely revised procedure FBP-41, Equipment Reliability Program, in March 2019. This revised procedure described, a risk informed approach that extended beyond reliability initiatives to ensure emphasis of condition-based maintenance to minimize unavailability while maximizing reliability. It included activities that were essential for effective life cycle management, by ensuring proper prioritization, scheduling, and integration into site long range plans. This process supported a zero tolerance for unplanned failures on critical equipment. The procedure provided a uniform prioritization process for a proposed change or issue. The resultant ranking provided a means to determine the projects and/or initiatives that should be funded and implemented. As a result, the licensee developed a list of modifications and changes, along with schedules for the completion of required actions. The team concluded that, if properly implemented, this new process, over time, could potentially improve equipment reliability.
Observation: Operating Experience Review Inadequacies 71152B While the licensee generally addressed Operating Experience identified by external organizations appropriately, the team identified several instances where the licensee's reviews of NRC and industry operating experience were inadequate.
Information Notice (IN) 2017-04, High Energy Arcing Faults (HEAF) in Electrical Equipment Containing Aluminum Components, was issued by the NRC in August 2017. The issue was entered into the licensee's Corrective Action Program as CARD 18-21869 in March 2018.
However, the corrective action to investigate the use of aluminum components as documented in the CARD was still open at the time of this inspection. Upon questioning by the team, the licensee determined that the concern of aluminum increasing the effects of a HEAF were limited since the electrical design specifications and the plant's Support Engineering Practice Standards only allowed a limited use of aluminum in the electrical design of the plant. Given that the plant was designed with the separation of safety-related trains and fire areas, the licensee determined that there was reasonable assurance that the electrical systems would meet their design functions during any fault on a nonsafety-related system or a single failure of a safety-related system. The licensee entered the timeliness concern identified by the inspectors into their Corrective Action Program as CARD 19-26081.
Information Notice 2017-06, Battery and Battery Charger Short-Circuit Current Contributions to a Fault on the Direct Current Distribution System, was issued by the NRC in September 2017. Although the IN was subsequently entered into the licensees database to be screened, the issue was not entered into the Corrective Action Program until March 2018. It was also noted that the evaluation performed for the IN was later found to be inadequate by an NRC inspection team in early 2019. As a result, a new evaluation was performed through CARD 19-23651, which identified an operable-but-nonconforming condition that required plant modifications. The licensee entered the timeliness concern identified by the inspectors into their Corrective Action Program as CARD 19-26102.
Further, the inspectors identified two examples where industry operating experience did not result in an engineering evaluation, despite their potential applicability to the main steam isolation valves (MSIVs). In the first example, Licensee Event Report (LER) 2017-002 described MSIV pilot valve binding due to potential foreign material. A second example associated with LER 2018-002 described slow MSIV closure times due to foreign material introduced by the vendor during manufacturing. For the 2018 LER, the site screened the issue as not applicable to Fermi. In the case of the 2017 LER, the station had not considered the operating experience at all. After the inspectors reviewed the operating experience and questioned the site regarding their applicability, the licensee issued CARD 19-26074 to evaluate applicability since Fermi used the same vendor for the refurbishment of their equipment.
Although the team did not identify any violations of NRC requirements, these issues represented inadequacies in the licensee's screening and evaluation of operating experience in a timely manner such that potential issues with safety-related equipment might go unnoticed. Specifically, the licensee failed to ensure that all available avenues for Operating Experience were reviewed for applicability as LERs often described issues that could pertain to other sites, especially when associated with the same vendor or with parts issues.
Additionally, the licensee did not ensure that personnel with an appropriate level of expertise were reviewing issued Operating Experience, especially when specific sites were not specifically identified in the operating experience documents that were received.
Observation: Self-Assessment and Audit Weaknesses 71152B The team reviewed several department self-assessments regarding the storage and staging of material. These assessments were conducted in April 2017, October 2017, and April 2018. In April 2017, the results of a department self-assessment documented that all critical attributes concerning material storage areas and staged material were met. However, in May 2017, NQA performed an audit in the same area and identified a number of findings and, multiple barrier failures and programmatic breakdowns, regarding the storage and staging of material. Similarly, a department self-assessment performed in October 2017 and April 2018 documented that all critical attributes were met. However, in March 2019, NQA issued an elevation letter citing numerous issues in the storage and staging of material, and the fact that previous NQA findings had not been resolved. The team determined that this apparent disparity between the department self-assessment conclusions and the NQA findings throughout the period called into question the quality of the department reviews.
In another example, the team reviewed a common cause analysis performed in November 2017 regarding the control of measurement and test equipment (M&TE). While the common-cause analysis highlighted weaknesses in the program and instituted corrective actions that ultimately reduced the number of current issues, the team noted a history of similar M&TE control issues that dated back to at least early 2015. Specifically, in January 2015, NQA performed an audit that identified issues in the control of M&TE after use and in the trending of M&TE deficiencies. In May 2015, a department self-assessment identified that M&TE users did not understand their responsibilities for controlling M&TE. In January 2016, the site identified an emerging trend in M&TE that was assumed to have failed or had been lost. In June 2017, an NQA audit prompted an apparent cause analysis to address multiple gaps in the M&TE calibration program and the process for the control and issuance of M&TE. Finally, in October 2017, another adverse trend in the same area was identified, which led to the common cause analysis.
The examples above demonstrated that the licensee's self-assessments and audits did not always identify performance gaps. Further, when performance issues were identified by self-assessments and audits, they sometimes recurred before being effectively addressed.
The team also reviewed NRC finding 05000341/2018004-01 regarding a valve stem and disc that was dropped during a lifting and rigging evolution in 2018, and a subsequent formal self-assessment on lifting and rigging. This assessment identified that the previous self-assessment in lifting and rigging performed in February 2016 was not adequate. Specifically, in 2016, a lifting and rigging department self-assessment failed to identify gaps in Fermi procedures relative to industry standards. That self-assessment also failed to identify gaps in the first line supervisor's ability to monitor lifting and rigging evolutions.
In addition to the licensee-identified issues with the 2016 assessment, the team determined that the licensee had missed an opportunity to determine whether worker behavior contributed to the 2018 stem and disc drop event. For instance, the various analyses that were performed by the licensee in response to the 2018 stem and disc drop event referred to a culture of taking short cuts, having a can-do attitude that leads to poor decision-making and substandard performance, and a failure to conduct an adequate pre-job brief. While the 2016 self-assessment included a critical attribute associated with fundamental behaviors, the focus of this assessment did not include human performance, but rather on recommended qualifications, training, and the definition of roles among crew members.
In the three examples listed above, the team noted there were no corrective actions developed to explore why self-assessments and audits were either inadequate or not timely in addressing problems. The team concluded that while self-assessments and audits were performed in accordance with licensee procedures, performance gaps went unnoticed or uncorrected. The team concluded that this indicated a lack of intrusiveness in the licensee's assessment and a lack of vigilance in correcting performance issues.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 16, 2019, the inspectors presented the biennial problem identification and resolution 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
Corrective Action
Documents
05-24876
Blown Scram Pilot Fuse
08/22/2005
07-22140
Reactor Recirculation Pump Driver Mount Drain Lines
Potentially Direct Unidentified Leak Sources into the
Identified Leak Path
04/19/2007
07-23630
CDBI - UFSAR Anti-Vortex Methodology Non-Conservative
06/28/2007
08-26828
Non-Qualified Support System to Ensure Adequate Post-
LOCA Emergency Depressurization
10/15/2008
08-27506
DC-0501 Vol 1 HPCI Key Calculation Review Results
11/11/2008
09-26761
Key Calculation Review of DC-5490 Vol. I, Ventilation Air
Quality for EDG Switchgear Room
09/01/2009
10-28090
Reactor Building Superstructure Re-Analysis
09/14/2010
11-29120
DC-0919 Recommended Setting Changes
10/06/2011
11-29284
Legacy Circuit Design Associated with the RHR 4.16kV Load
Shed Scheme
10/12/2011
2-21134
Evaluate OE35219 (Preliminary - Automatic Reactor Trip
and Loss of Offsite Power Due to Failed Switchyard
Insulator) for Applicability to Fermi
2/10/2012
2-23735
Main Steam Line Radiation Monitor F Cage Broken Bolts
04/24/2012
2-24521
05/16/2012
2-29077
Reactor Scram Due to H2 In-Leakage to Stator Water
11/07/2012
13-10103
Main Steam Piping Support Exceeds Design Load
06/07/2013
13-22663
EDP - Setpoint Change is Required for the TSC Upstream
HEPA Filter DP Switch
04/15/2013
13-24841
EDG Steady State Voltage and Frequency Technical
Specification Ranges
07/10/2013
14-21857
Configuration Control Discrepancy: Drawing M-3184-1
Doesn't Reflect the Plant Configuration of the Division 2
RHRSW Piping
03/01/2014
14-22610
Repetitive Failures of RPS Relay K17B
03/20/2014
14-22612
EDG 11 Manually Tripped During Surveillance Test Due to
Fire from Turbocharger Lagging
03/20/2014
14-22646
EDG 11 Jacket Coolant Leak at Standby Heater Control
03/21/2014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Switch
14-23829
Lube Oil Leak from Body of R3000F111B During EDG 13
Governor Vent Run
05/02/2014
14-25670
EDG Lockwire Gauge is Inconsistent
07/11/2014
14-27839
Warehouse Cannot Properly Store Spare MSIV Actuators
10/06/2014
15-20167
NQA Recommendation - Benchmark and Develop
Performance Metrics for M&TE Program
01/08/2015
15-20168
NQA Recommendation - Formalize How M&TE is Turned
Over After Use
01/08/2015
15-21132
Calculation (DC-4931) Damper Minimum Air Pressure
Calculation Identified Margin Issue
2/12/2015
15-21952
Replacement CRD Pump Not Stored IAW Vendor Manual
03/17/2015
15-22182
Warehouse Documentation Did Not Match ASME Tube Plug
Heat Codes for Drywell Cooler #2
03/25/2015
15-22883
NRC Identified Issue: EDG-14 Oil Leak
04/22/2015
15-22949
Review and Revise SAM Program Section 3.2
04/24/2015
15-23047
Crankcase Vacuum Tubing Cracked at Fitting
04/28/2015
15-23171
Excessive Smoke from EDG 14 During SOP Run
05/02/2015
15-23277
RHRSW Return from RHR HX High Temperature Alarm
Setpoints Above Piping Design Temperature
05/07/2015
15-23290
Leaking Bypass Valve
05/07/2015
15-23679
M&TE Users Do Not Understand Responsibilities
05/27/2015
15-24444
Jet Pump Failure AOP May be Non-Conservative
06/26/2015
15-25177
Recommend Spare Parts for RHRSW Pump/Motor
07/27/2015
15-26907
29.ESP.03 EOP Support Tool Box Damaged
09/27/2015
15-27998
Discrepancy Identified in Replacement Coupling and
Installed Coupling For CRD Pump Replacement
10/19/2015
16-20417
Emerging Trend - CARDS on Assumed Failures of M&TE
01/15/2016
16-21485
NRC Resident Question Regarding AOV T4600F406
2/17/2016
16-21963
Switch Calibration Drift
03/02/2016
16-23673
Independent RHRSW Inspection - Piping Calculation is
Inconsistent with Drawing
05/04/2016
16-24088
Fuel Oil Leak on EDG 11 Fuel Oil Transfer Pump B
05/18/2016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
16-24244
Starting Air Leak Inside EDG 14 Starting Air Compressor Air
Dryer
05/21/2016
16-25611
2016 EQ Program Self Assessment Deficiency
07/14/2016
16-25666
Lube Oil Leak on EDG 12 Flex Coupling
07/17/2016
16-26533
2016 CDBI Issue: Non-Conformance to Licensing Bases for
Evaluation of Degraded Voltage
08/17/2016
16-26814
Inclement Weather Results in Unplanned LCO Entry, EOP
Entry, and 8 Hour Report to NRC
08/27/2016
16-27087
Additional Support Not Evaluated in Pipe Stress Calculation
09/06/2016
16-28543
Single Rod Scram of CR 26-07
10/26/2016
16-29549
New Spider Bearing 0.010" Larger than Previous One
Installed on RHR Service Water Pump
11/29/2016
16-29936
Siren Performance - 200 Amp Fuses
2/14/2016
17-00469
EDG 13 Fuel Tank Room
2/23/2017
17-20141
SPF Failed Test of Shut Down Relay from Overspeed
Simulation Per WO 43631018 PM 1291
01/05/2017
17-20163
Use of RPS Test Box May Cause Loss of RPS Function
01/06/2017
17-21316
CCA: Steam Leaks on High Pressure Turbine 1st Stage
Pressure Instrument Lines
05/16/2017
17-21382
RERP Drill 02/14/17: Failure of Follow-Up Notifications
Objective
2/17/2017
17-21385
Common Cause Evaluation: Negative Trend Seen in Follow-
Up Notifications Performance
05/11/2017
17-22078
Evaluate the Impact on EAL Threshold Values EP-101
Based on OCDM Revision
03/15/2017
17-22236
CCA: Trend in Radiation Protection TPE Failures
05/10/2017
17-23685
Common Cause Evaluation: Emerging Trend -
Mispositionings in Operations
06/02/2017
17-23736
Adverse Trend - Foreign Material Exclusion
04/20/2017
17-24655
EACE: Failure of E1150F068B, Division 2 RHRSW HX
Outlet FCV to Open
17-24758
NQA Audit Finding - Repeat Finding on Improper Controls of
Safety-Related (QA1) and Non-Safety (NQ) Material
05/23/2017
17-24845
Several DevonWay Operating Experience Evaluations are
05/25/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Overdue
17-25157
Division 2 RHRSW is Exceeding Maintenance Rule
Performance Criteria
06/08/2017
17-25383
NQA Audit 17-0107 Finding - Procedures for M&TE
Calibration Methods Not Properly Approved and Controlled in
Accordance with QA Program
06/16/2017
17-25480
NRC Information Notice 2017-03
06/21/2017
17-25545
CFR Part 21 for NUMAC PRNM 386SX Computer Module
and ASP Module
06/23/2017
17-26069
E1150F068B Monitoring and Inspection WOs Needed
07/19/2017
17-26338
NQA Audit 17-0110 Deficiency - Radioactive Material (RAM)
Control Gaps and Inconsistencies
07/27/2017
17-26340
NQA Audit 17-0110 Deficiency - Poor Housekeeping Inside
Contaminated Areas
07/27/2017
17-26351
Received 17D41 For Division 2 DW Temperature High
07/27/2017
17-26708
Division 1 CCHVAC Supply Fan Vibration Trend
08/09/2017
17-26894
NRC Identified Issue with Firearms Instructor Qualification
08/16/2017
17-27148
2017 NRC FP Triennial: Review FPEE-16-0001 to Determine
if the Addition of Steps to 20.000.18 Have an Impact on Time
Critical Operator Actions
08/25/2017
17-27225
Elevated Dose Rates Observed Coming From the FPCCU
Precoat Tank
08/29/2017
17-28757
Cognitive Trend in Maintenance - Assumed Failures of M&TE 10/26/2017
17-29262
NRC RIS 2017-05: Administration of 10 CFR Part 72
Certificate of Compliance
11/16/2017
18-00690
EDG 11 Engine Room
08/22/2018
18-00983
Standby Heating Discharge Control Temperature Switch is
Leaking for EDG 14
11/28/2018
18-20628
NRC Issues Regulatory Issue Summary 2018-01 on 10 CFR Part 37 Issues
01/24/2018
18-20786
NRC ENS Phone Not Communicating Correctly
01/29/2018
18-21062
Continuing Vibration Trend Division 1 CCHVAC Supply Fan
Motor
2/07/2018
18-21062-01
Complete MPFF Evaluation on Division 1 CCHVAC
2/27/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
18-21869
(OE 2017-0395) NRC Information Notice 2017-04 - High
Energy Arcing Faults in Electrical Equipment Containing
Electrical Components
03/06/2018
18-22371
Leak Identified on R3001C006
03/21/2018
18-22931
Dry Cask Noble Fission Gas Release Response Strategy
04/11/2018
18-24354
Oil Leak from Flange Supplying EDG #11 LO Filter
06/01/2018
18-24437
08/23/2018
18-25713
Equipment Cause Evaluation: Recirc Pump Seal Purge
Relief Valve B3100F015B Repetitive Failures
08/24/2018
18-27810
Increased Dose Rates Experienced During RF19
10/04/2018
18-28008
Organizational Effectiveness Evaluation: Unexpected Dose
Rate Conditions After Opening the G3352F001
10/08/2018
18-29027
Root Cause Evaluation Report: E1150F068B Did Not Close
as Expected
01/16/2019
18-29102
2018 NSCA Results - Trait CO.2 Basis for Decisions
11/07/2018
18-29367
Part 21 for ITT Conoflow for GT25 Current to Pressure
Transducers
11/19/2018
18-29568
New Replacement Stem and Disc Dropped from Rigging with
Personnel Injury
11/29/2018
18-29620
2018 LIR Reactor Recirculation - Seal Purge Relief Valves
11/30/2018
18-29672
EDG 14 Air Coolant Hx Leaking Coolant
2/02/2018
18-29775
Clogged Drain Lines Resulting in Multiple Leaks
2/07/2017
18-29870
Reactor Building to Suppression Chamber Vacuum Breaker
UFSAR Nonconformance
2/08/2018
18-30322
EDG 13 JCS STBY Circulating Pump Seal Leaking
2/21/2018
18-30330
Adverse Trend in Lifting and Rigging Practices
2/21/2018
18-30400
NQA - Valve R3000F118B (Lube Oil Source Valve for
R30NA11B) Has Slight Weeping
2/27/2018
19-00209
130 DPM Leak from EDG 11 Coolant Standby Heating - Low
Temp SW Elec
04/08/2019
19-20549
EDG 13 Standby Lube Oil Pump Leak
01/24/2019
19-20652
Provide Additional Training/Information Regarding the
Purpose and Value of the Site Corrective Action Process
01/29/2019
19-20869
NQA Audit 19-0101 Finding: Inadequate Control of Safety-
2/06/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Related Fuses Maintained and Installed by Operations
19-21169
NRC Finding - Inadequate Lifting and Rigging Practices
Result in Damage to Division 2 Residual Heat Removal
Structures and Components
2/15/2019
19-21335
Operations Department Reset for Unacceptable Performance 02/20/2019
19-21397
- 1 and #9 Cylinder Liner Indicator Valve Adapter O-Rings
Found Leaking During Hydrostatic Test
2/22/2019
19-21433
NRC Violation - Inadequate Work Instructions for
Maintenance on EDG 14
2/25/2019
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
19-21969
Strategic Engineering Identified Part 21 Issue on Safety-
Related 4160V-480 Dry Transformers
03/13/2019
19-22077
EDG 13 Strategic Engineering Walkdown
03/18/2019
19-22412
SLC Ignition Continuity Loss Squib A
03/28/2019
19-22895
Evaluate Impact of Part 21 on SF-1154 Hydraulic Fluid Used
in Power Piping Snubbers
04/16/2019
19-23227
Recommend Review of Site Response to Open CARD 07-
23630
04/26/2019
19-23602
2019 AFI Station Leaders Have Not Corrected Worker
Behaviors Affecting Plant Status Control
05/09/2019
19-23612
Root Cause Evaluation of Culture that Allowed Rationalizing
and Tolerating Unacceptable Worker and Plant Performance
05/09/2019
19-23651
2019 DBAI: Information Notice IN 17-06 - Battery Chargers
(Ametek Chargers) May Contribute up to 10 Times their
Rating for a Short Period
05/10/2019
19-23897
No Tie-Down and/or Securing Devices Within the Off-Site
RET Team Van to Safely Secure Cargo
05/20/2019
19-24015
INPO Operating Experience Report for Exporting Radioactive
Material RIS 19-01 Clarification
05/24/2019
19-24107
Secondary Containment Doors Open at the Same Time
05/30/2019
19-24316
Tagouts/Protection Putting Operators at Risk
06/05/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
19-24655
DevonWay Errors Preventing Operating Experience
Evaluations from Being Properly Closed Out
06/20/2019
19-25978
2019 PI&R NRC Inspection Observation: CARD 19-24107 AI
- 4 Closure
08/07/2019
19-25988
2019 PI&R Inspection NRC Observations: Maintenance
Programs
08/07/2019
19-25989
2019 PI&R Inspection NRC Observations: Potential Missed
Opportunities to Address Maintenance Behavioral Gaps
08/07/2019
19-26074
2019 PIR - Evaluate Monticello MSIV OE
08/12/2019
19-26080
OE Review in DevonWay is Past Due
08/12/2019
Corrective Action
Documents
Resulting from
Inspection
19-25794
2019 PI&R Inspection - CARD 19-20869 Quality Less Than
Adequate to Support Conclusion of Reasonable Assurance
08/01/2019
19-25794
2019 PI&R Inspection - CARD 19-20869 Quality Less Than
Adequate to Support Conclusion of Reasonable Assurance
08/01/2019
19-25840
2019 NRC PI&R Inspection: NRC Identified Hanging Oil
Drops on EDG 11 Upper Air Start Distributor
08/02/2019
19-25840
NRC Identified Oil Drops on EDG 11 Upper Air Start
Distributor
08/02/2019
19-25933
Spec 3071-128-EJ Identified with a Deficiency
08/06/2019
19-25978
2019 PI&R NRC Inspection (Observation) - CARD 19-24107
AI #4 Closure
08/07/2019
19-25978
CARD 19-24107 AI #4 Closure
08/07/2019
19-25988
Maintenance Programs
08/07/2019
19-25988
2019 PI&R Inspection NRC Observations: Maintenance
Programs
08/07/2019
19-25989
2019 PI&R Inspection NRC Observations: Potential Missed
Opportunities to Address Maintenance Behavioral Gaps
08/07/2019
19-25989
Potential Missed Opportunities to Address Maintenance
Behavioral Gaps
08/07/2019
19-25993
2019 PI&R - Disposition of Paragon Labs Failure Analysis
Report TR1801449-01-0 Recommendations
08/08/2019
19-26074
2019 PI&R - Evaluate Monticello MSIV OE
08/12/2019
19-26074
Evaluate Monticello OE
08/12/2019
19-26081
2019 PI&R: Review of IN 2017-04 Has Not Been Completed
08/12/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
in a Timely Manner
19-26102
2019 PI&R: IN 2017-06 Not Reviewed in a Timely Manner
08/13/2019
19-26103
2019 PI&R
08/13/2019
19-26112
2019 PI&R - RFI-083: Discuss CARD 08-26828 Assurance of
Operability
08/13/2019
19-26139
2019 PI&R Inspection Insight on Part 21 Screening Practices
08/15/2019
19-26140
2019 PI&R Inspection - Insight on Evaluating Effectiveness
of Previous Self Assessments
08/15/2019
19-26141
2019 PI&R NRC Inspection (Observation) - Confidence in
08/15/2019
19-26143
2019 PI&R NRC Inspection (Observation) - Personnel
Associating SCWE with Industrial Safety Not Nuclear Safety
08/15/2019
19-26154
2019 PI&R Inspection - NRC Team Observation Related to
Older Open CARDs
08/15/2019
19-26179
2019 PI&R Inspection Concluded Fermi's Corrective Action
Program is Marginally Effective
08/16/2019
Drawings
Relaying & Metering Diagram Diesel Generator #11 Unit 2
X
Diagram Primary Containment Pneumatic Supply System
Z
Operator Time Critical Actions and Design Basis Sheet 1
E
Engineering
Changes
EDP-70032
Replacement of Bussmann MIN-3 Fuses with Bussmann
BBS-3 Fuses at C71P002B, D, F
TSR-36584
Re-Classify Auxiliary Building Superstructure as Seismic II/I
TSR-37859
Reconciled Design Loads
Engineering
Evaluations
17-22857
Apparent Cause Evaluation: Degraded Reactor Building
Pressure Due to OPDRVs
05/16/2017
18-23026
Root Cause Evaluation: Reactor Scram Due to Loss of 64
Transformer
04/16/2018
Miscellaneous
2019 CARD Backlog - July
Compensatory Monitoring Plan - 3D11 SLC Ignition
Continuity Loss/Circuit A Continuity Light is Off
03/29/2019
2017 CARD Backlog End of Year
D&Z Safety Conscious Work Environment Survey Results
05/29/2019
USA NSCA Survey Organization Level and Department
Statistics
08/10/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Spring 2019 Fermi Employee Engagement Overview
05/06/2019
Listing of Systems in Maintenance Rule (a)(1) Status
07/15/2019
2018 CARD Backlog End of Year
16-0262
50.59 Screening - Revision to Programming of T41R800A/B
Recorder
ECP-19-001
(0801.26)
2019 First Quarter Report - Employee Concerns Program
04/30/2019
LER 17-22425
NRC 1 Hour-Reportable Physical Security (10 CFR 73.71)
03/23/2017
LER 17-24655
Division 2 RHR HX SW Outlet FCV Failed to Open
05/22/2017
LER 18-20257
Reactor Building Pressure > -0.125" During a Planned Swap
of Two Train to Single Train RBHVAC
01/11/2018
LER 18-28457
RHR Pump "C" Tripped After Auto Start During 24.307.02
10/18/2018
LER 19-21227
AB5-RB5 Interlock Switch Needs Adjustment
2/16/2019
Monticello
Nuclear
Generating Plant
LER 2017-002-00
Main Steam Isolation Valve Closure Time Outside of
Technical Specification Requirements
Monticello
Nuclear
Generating Plant
LER 2018-002-00
C Outboard Main Steam Line Isolation Valve Delayed
Closure Due to Foreign Material in the Air Valve
NAPI-18-0016
2018 Nuclear Safety Culture Assessment Report
11/01/2018
NQA 17-0114
Nuclear Quality Assurance Audit Report, Nuclear Quality
Assurance Audit of the Corrective Action and Operating
Experience Programs
11/06/2017 -
11/17/2017
NQA 18-0113
Nuclear Quality Assurance Audit Report, Quality Assurance
Audit of the Corrective Action and Operating Experience
Programs
11/05/2018 -
11/16/2018
OE 2018-0012
RIS17-08, Process for Scheduling and Allocating Resources
01/08/2018
SCR-37770
Revision to Programming of T41R800A/B Recorders
Procedures
24.307.14
Emergency Diesel Generator 11 - Start and Load Test
24.307.30
Emergency Diesel Generator No. 11 - 24 Hour Run Followed
by Hot Fast Restart
24.307.47
Emergency Diesel Generator 13 - Fast Start Followed by
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Load Reject
29.100.01 Sh 1
RPV Control
29.100.01 Sh 3
RPV Flooding, & Emergency Depressurization
29.100.01 Sh 4
RPV Alternative Level/Pressure Control
35.000.224
Alignment and Tension Adjustment of V-Belt Driven
Equipment
2.307.02
Logic System Functional Test of Division 2 EDG ECCS
Emergency Start Circuits and Automatic Trip/Bypass Circuits
ARP 1D30
RHR HX A Cooling H2O Discharge Temperature High
ARP 2D35
RHR HX B Cooling H2O Discharge Temperature High
FBP-41
Equipment Reliability Program
MMR Appendix D
Guidelines for Determining Functional Failures and
Maintenance Preventable Functional Failures
MMR Appendix F
Maintenance Rule Performance Criteria
MMR02
Maintenance Rule Program Description
6A
MMR06
Establishing Performance Criteria
MMR09
Establishment of Get Well Plans
17A
MQA11
Corrective Action Program
MQA11-200
Condition Initiation
1A
MQA11-300
Screening and Assignment
MQA11-400
Corrective Action Program Condition Disposition
MQA11-500
Non-Corrective Action Program Condition Dispositions
MQA11-500
Quality Assurance Conduct Manual Implementing Procedure
Non-Corrective Action Program Condition Disposition
MQA15
Quality Assurance Conduct Manual, Apparent Cause
Evaluations
Self-Assessments 17-0113
Quality Assurance Audit of the Equipment Reliability Program 10/31/2017
17-0114
Nuclear Quality Assurance Audit Report - Corrective Action
and Operating Experience Programs
2/18/2017
18-0110
Nuclear Quality Assurance Audit of the Radiological
Effluents, Radiological Material Transfer and Disposal, and
Radiation Protection Programs
08/27/2018
18-0113
Nuclear Quality Assurance Audit Report - Corrective Action & 12/14/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operating Experience Programs
2019Q1
Maintenance Continuous Learning Report
03/31/2019
NAPI-18-0014
Quick Hit Self-Assessment - CARD Closure Quality
09/28/2018
NAPI-19-0006
Focused Self-Assessment - Corrective Action Program
03/29/2019
NAQA-15-0001
NQA Special Oversight - M&TE
01/08/2015
NARP-17-0230
NRC Performance Indicator Comparative Analysis
05/03/2017
NARP-18-0155
Simulator Notifications Performance Assessment
05/15/2018
NPMA-16-0028
Focused Self-Assessment Report: Rigging, Lifting, and
Material Handling
2/22/2016
NPMA-19-0023
Focused Self-Assessment Report: Lifting and Rigging
Program
04/17/2019
NPOP-17-0066
Review of B.5.b Strategies
08/10/2017
NPOP-18-0466
Effectiveness Review for CARD 17-27545
05/22/2018
NPRP-18-0039
Quick Hit Self Assessment: Occupational ALARA Planning
and Controls
03/29/2018
NSSC-17-0006
Quick Hit Self-Assessment: Material Storage and Staging
04/27/2017
NSSC-17-0019
Quick Hit Self-Assessment: Material Storage and Staging
10/31/2017
NSSC-18-0002
Quick-Hit Self Assessment: Material Storage and Staging
04/16/2018
TMPE-18-0084
Quick Hit Self Assessment: Configuration Management and
Temporary Alterations
06/15/2018
Work Orders
25971306
Replace Scram Pilot Solenoid Fuses in C71P002F Per EDP-
70032
11/28/2018
25971310
Replace Scram Pilot Solenoid Fuses in C71P002B Per EDP-
70032
11/28/2018
26809154
Replace Scram Pilot Solenoid Fuses in C71P002D Per EDP-
70032
11/28/2018
37662340
Implement Mounting Configuration Change for EDG 14
Emergency Overspeed Switch
04/23/2015
46561773
Division 1 Reactor Building Differential Pressure Recorder
Response
2/23/2016
46671775
Implement a Software Change Request for T41R800B
2/23/2016