IR 05000341/2021002
| ML21216A213 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/06/2021 |
| From: | Nestor Feliz-Adorno Reactor Projects Region 3 Branch 4 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2021002 | |
| Download: ML21216A213 (23) | |
Text
SUBJECT:
FERMI POWER PLANT, UNIT 2 - INTEGRATED INSPECTION REPORT 05000341/2021002
Dear Mr. Dietrich:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On July 27, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-identified violations which were determined to be of very low safety significance are documented in this report. 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 the 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 Power Plant, Unit 2.
If you disagree with a cross-cutting aspect assignment 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 Power Plant, Unit 2.
August 6, 2021 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Néstor J. Féliz Adorno, 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-2021-002-0134
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
April 01, 2021 to June 30, 2021
Inspectors:
T. Briley, Senior Resident Inspector
T. Taylor, Resident Inspector
Approved By:
Néstor J. Féliz Adorno, 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. Licensee-identified non-cited violations are documented in report section: 71111.1
List of Findings and Violations
Multiple Hourly Fire Watch Tours Not Performed at the Emergency Diesel Generator 11, 12, and 13 Fuel Oil Storage Tank Rooms Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/2021002-01 Open/Closed
[H.12] - Avoid Complacency 71111.05 The inspectors identified a finding of very low safety significance (Green) with an associated Non-Cited Violation (NCV) of Technical Specification (TS) 5.4.1, "Procedures," for the failure to perform multiple hourly fire watch tours at the EDG 11, 12, and 13 fuel oil storage tank rooms in accordance with Fire Protection Program procedures.
Additional Tracking Items
None.
PLANT STATUS
Unit 2 began the inspection period at rated thermal power. On May 15, 2021, the unit commenced a planned shutdown to address a steam leak in the reactor building steam tunnel.
Following completion of maintenance activities, the reactor was restarted and taken critical on May 22, 2021. The main generator was synchronized to the power grid on May 23, 2021. The unit returned to rated thermal power on May 24, 2021. The unit remained at or near rated thermal power for the remainder of the inspection period.
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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the following systems:
- (1) Division 1 120 kV switchyard and Division 2 345 kV switchyard during the week ending June 30, 2021
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Standby feedwater (SBFW) system 'A' while SBFW system 'B' was out of service for planned maintenance during the week ending May 15, 2021
- (2) Division 1 standby gas treatment (SBGT) system following planned maintenance and surveillance testing during the week ending May 15, 2021
- (3) Division 1 core spray system while Division 2 core spray system was out of service for planned maintenance during the week ending June 19, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors completed an evaluation of system configuration during a complete walkdown of the reactor core isolation cooling (RCIC) system on June 30, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Residual heat removal (RHR) complex, emergency diesel generator (EDG) 11 engine room and fuel oil storage tank room during the week ending February 19, 2021
- (2) RHR complex, EDG 12 engine room and fuel oil storage tank room during the week ending February 19, 2021
- (3) RHR complex, EDG 13 engine room and fuel oil storage tank room during the week ending March 13, 2021
- (4) Reactor building fourth floor, reactor recirculation motor generator set area during the week ending May 1, 2021
- (5) Reactor building sub-basement, high pressure coolant injection pump room during the week ending May 1, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated fire brigade training and performance during an offsite live burn training scenario on June 25, 2021
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) High pressure coolant injection (HPCI) room following identification of a degraded HPCI flood seal during the week ending May 15, 2021
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) P4400B001A heat exchanger on Division 1 emergency equipment cooling water (EECW)
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during shifting of reactor recirculation pump motor generator set ventilation fans during the week ending April 10, 2021
- (2) The inspectors observed and evaluated licensed operator performance in the control room during a planned downpower evolution for a steam leak investigation in the reactor building steam tunnel on May 15, 2021
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification training in the simulator on June 1, 2021
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Partial)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)
(Partial)
General Electric HFA relays (multiple plant systems)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Emergent work on temporary in-core probes and associated risk assessment for scheduled local power range monitor testing and calibration during the week ending May 1, 2021
- (2) Emergent work to diagnose and repair separator seal tank level issue during the week ending May 1, 2021
- (3) Emergent work to diagnose and repair an underground cable fault that resulted in loss of 13 kV tag line and control power to transformer 1 in the Division 1 120 kV switchyard
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability and functionality of the alternate diesel fire pump with less than design discharge flow, as documented in CARDs 21-21167 and 21-21704
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Emergency core cooling system (ECCS) reactor water level 2 relay (B21K202C)testing following relay replacement during the week ending April 17, 2021
- (3) East turbine bypass valve testing following failure to properly open during the week ending May 22, 2021
- (4) Division 1 control complex heating ventilation and air conditioning (CCHVAC) chiller adjustments following high oil temperature trip during the week ending June 12, 2021
- (5) Reactor core isolation cooling steam line outboard containment isolation valve (E5150F008) testing following packing leak repairs during the week ending June 30, 2021
- (6) Reactor protection system 'B' system testing following electrical protection assembly breaker repair during the week ending June 30, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated mid-cycle outage activities associated with a reactor building steam tunnel steam leak from May 16, 2021 to May 23, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Main steam isolation valve and turbine stop valve testing during the week ending May 29, 2021
- (2) Local power range monitor testing with degraded in-core probe system during the week ending June 30, 2021
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Standby gas treatment system valve operability test during the week ending May 8,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 2 (April 1, 2020 - March 31, 2021)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) Unit 2 (April 1, 2020 - March 31, 2021)
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) Unit 2 (April 1, 2020 - March 31, 2021)
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 that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Multiple Hourly Fire Watch Tours Not Performed at the Emergency Diesel Generator 11, 12, and 13 Fuel Oil Storage Tank Rooms Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/2021002-01 Open/Closed
[H.12] - Avoid Complacency 71111.05 The inspectors identified a finding of very low safety significance (Green) with an associated Non-Cited Violation (NCV) of Technical Specification (TS) 5.4.1, "Procedures," for the failure to perform multiple hourly fire watch tours at the EDG 11, 12, and 13 fuel oil storage tank rooms in accordance with Fire Protection Program procedures.
Description:
On February 8, 2021, the licensee initiated fire impairment 2021-0028 after identifying a degraded alternate diesel fire pump (ADFP). The ADFP had just been installed as a backup system to a non-functional permanently installed diesel fire pump. The ADFP was degraded because it produced less than the required design flow rate due to a pump suction configuration problem. The licensee performed a fire protection engineering evaluation (i.e.,
FPEE 21-0003) of the fire water suppression system with the ADFP degraded flow rate and determined the minimum sprinkler system flow in several plant locations could not be met if the ADFP was placed in service without the electric fire pump. These locations included the Division 1 EDG 11 and EDG 12 fuel oil storage tank rooms (two physically separate spaces)and the Division 2 EDG 13 fuel oil storage tank room. The compensatory fire impairment specified hourly fire watch tours in those locations until the ADFP pump was fully capable of producing the fire water suppression system design flow rate. Licensee procedure MOP 11-100, Fire Protection System Implementation, Revision 7, step 4.4.1 stated, "an hourly fire watch is a tour of all items/areas on the Out of Specification Log Sheet. These tours are to be performed within a one-hour period and will begin approximately on the hour and terminate before the next hour. Tours will terminate in the control room."
The inspectors performed a historical review of the key card reader data for each affected location. They noted several hourly fire watches where it appeared the individual assigned fire watch duties did not enter the location as needed to perform the fire watch tours of the EDG 11, 12, and 13 fuel oil storage tank rooms. Subsequent investigation by the licensee confirmed four fire watch tours (i.e., February 19, 2021, 3:00 p.m. for Division 1 EDG 11 and 12 fuel oil storage tank rooms and 6:00 p.m., 7:00 p.m., and 8:00 p.m. for Division 2 EDG 13 fuel oil storage tank room) were inadvertently not performed. The inspectors also noted multiple fire watch tours that had questionable tour performance completion times.
Specifically, the inspectors questioned the licensee on the feasibility of traversing to the specified rooms given the tour completion times as indicated by key card reader history. The licensee investigated the questionable times and determined a programmatic fire watch implementation problem existed. Specifically, multiple individuals assigned fire watch duties were not performing the tours properly. These improper tours were generally the result of personnel going to the incorrect location. For example, some individuals walked down the EDG 13 engine room instead of the assigned EDG 13 fuel oil storage tank room. The licensee determined multiple assigned fire watch personnel did not thoroughly review or have the written list of assigned fire watch tour locations in hand while in the field, did not fully utilize available human performance practices for verification, and performed less than adequate turnovers discussing assigned fire watch duties and programmatic responsibilities.
It was also determined that fire watch training and procedural guidance did not specify how to perform a fire watch tour once an individual arrived at the correct location (e.g., what to look for and how extensive of a room walkdown is to be performed based on the type of fire impairment). The inspectors noted that multiple divisional fire watch tours were not performed at the specified locations based on independent inspector time trials and data analytics of the key card reader time stamps for the assigned fire watch personnel between February 8, 2021 and February 25, 2021.
Corrective Actions: The licensee corrective actions included, but were not limited to, development of a new fire protection procedure that specified specific fire watch roles and responsibilities, including how to properly conduct an hourly fire watch tour; additional supervisory checks and balances to ensure fire watch tours are being properly performed; and enhancements to fire watch turnovers, including utilization of a copy of the specified fire watch location paperwork.
Corrective Action References: CARD 21-22547
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee's failure to perform hourly fire watch tours at the EDG 11, 12, and 13 fuel oil storage tank rooms was contrary to revision 7 of procedure MOP11-100 and was a performance deficiency.
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 failure to perform multiple hourly fire watch tours as a compensatory measure for the degraded fire water suppression system does not ensure the EDGs 11, 12, and 13 would remain available to perform their accident mitigating function.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC)0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.4.2, Fixed Fire Protection Systems, the inspectors determined that the finding was of very low safety significance (i.e.,
Green). Specifically, the degraded AFDP did not adversely affect the ability of the fixed fire protection system to protect any equipment important to safe shutdown. The electric fire pump was available (and starts first on lowering fire water suppression system header pressure) to provide full design flow for the duration of the compensatory fire watches.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, assigned fire watch personnel did not use human performance practices for task execution and verification, and turnovers.
Enforcement:
Violation: Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. The licensee established MOP11-100, "Fire Protection System Implementation," Revision 7 as a fire protection program implementation procedure. Step 4.4.1 of this procedure was applicable for implementation of compensatory fire watches. It stated "an hourly fire watch is a tour of all items/areas on the Out of Specification Log Sheet. These tours are to be performed within a one-hour period and will begin approximately on the hour and terminate before the next hour.
Tours will terminate in the control room."
Contrary to the above, from February 8, 2021 to February 25, 2021, the licensee failed to implement written procedures covering fire protection program implementation. Specifically, the licensee included the EDG 11, 12, and 13 fuel oil storage tank rooms in the Out of Specification Log Sheet. However, the licensee did not perform multiple hourly fire watch tours on these locations. On February 19, 2021, the 3:00 p.m. assigned fire watch did not enter the Division 1 EDG 11 and 12 fuel oil storage tank rooms. Similarly, on February 19, 2021, the 6:00 p.m., 7:00 p.m., and 8:00 p.m. assigned fire watch did not perform the Division 2 EDG 13 fuel oil storage room tour. In addition, multiple hourly fire watches between February 8, 2021, and February 25, 2021, were not performed by the assigned hourly fire watch in the Division 1 EDG 11 and 12 fuel oil storage tank rooms and Division 2 EDG 13 fuel oil storage tank room based on performance completion times that were determined not to be feasible (i.e., could not reasonably get to the specified rooms in the logged completion times).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation.
Contrary to the above, from April 30, 2007, to February 8, 2021, the licensee did not maintain written procedures covering fire protection program implementation. Specifically, the licensee established 28.504.03, Fire Suppression Water System Simulated Automatic Actuation Test, as a fire protection program implementing procedure. It contained acceptance criteria for electric fire pump, diesel fire pump, and alternate diesel fire pump (when installed as a temporary backup system) water flow and discharge pressure to verify that the water supply for the fire suppression water systems were consistent with plant design calculations. Design Calculation 5713 Volume 1, Hydraulic Evaluation of the Fire Distribution Loop, established the acceptance criteria to meet various regulatory and National Fire Protection Association (NFPA) code requirements. However, revisions 18 through 30 of procedure 28.504.03 did not have its acceptance criteria revised when the acceptance criteria derived by revision C of Design Calculation 5713 was revised with more restrictive values.
Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.4.3 Fire Water Supply, the inspectors determined that the finding was of very low safety significance (i.e., Green). Specifically, adequate fire water capacity was still available for protection of equipment important to safe shutdown in the most limiting location onsite as one or more fire pumps met the applicable acceptance criteria values based on review of surveillance record history.
Corrective Action References: CARD 21-21583 Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: License condition 2(C)(9), Modifications for Fire Protection, states, in part, DTE Electric Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR).
Contrary to the above, from February 7, 2021, to February 24, 2021, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR. Specifically, Updated Final Safety Analysis Report (UFSAR) section 9.5.1.1, Fire Protection Program Design Basis, states, in part, the Fermi 2 fire protection system was designed and developed using National Fire Protection Association (NFPA)standards. UFSAR section 9.5.1.1.2, Codes and Standards, references NFPA 20 (1970 edition), Standard for the Installation of Centrifugal Fire Pumps, as a code and standard used for guidance in the design of the fire protection system. UFSAR 9.5.1.2.1 states the fire pumps meet the intent of NFPA 20. NFPA 20 (1970 edition), section 143.l, Suction Connections, states, in part, suction inlets should be at least 12 inches above the bottom of sump or suction well to avoid obstruction. However, the alternate diesel fire pump (ADFP)suction inlet was installed on the bottom of the general service water pump pit. This resulted in degraded ADFP discharge flow rates requiring compensatory actions.
Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.4.3 Fire Water Supply, the inspectors determined that the finding was of very low safety significance (i.e., Green). Specifically, adequate fire water capacity was still available for protection of equipment important to safe shutdown in the most limiting location onsite, despite the degraded ADFP discharge flow, as the electric fire pump remained available to meet full system design parameters.
Corrective Action References: CARD 21-21704 Observation: Semiannual Trend Review 71152 The inspectors identified a negative trend in the thoroughness of the licensee's review of several operational issues. The inspectors also noted a number of human performance issues over the last several months that were, in part, attributed to a lack of attention to detail, and/or complacency. While some issues were identified by the licensee as they occurred, others were identified by the inspectors as they performed an independent review. Examples included but were not limited to:
The inspectors identified that an Engineering Functional Analysis (EFA) for a degraded flooding seal in the high pressure coolant injection pump room established a compensatory measure that did not support operability. The licensee subsequently implemented an appropriate compensatory measure. Further, the inspectors identified the licensee incorrectly assumed a normal shutdown would commence versus a reactor scram per licensee emergency procedures when determining the time water would reach a certain height after a hypothetical torus rupture. This error did not affect the outcome of the evaluation. The inspectors did not identify a violation of regulatory requirements associated with this example.
The licensee performed a past operability evaluation for a violation associated with the improper storage of nitrogen bottles documented in NRC inspection report 05000341/2021001 (ADAMS Accession: ML21124A128) as NCV 05000341/2021001-01. However, the inspectors identified that the licensee evaluation of an affected location was an existing analysis performed on a different plant location that was not applicable for the operability evaluation. This error did not affect the outcome of the evaluation. The inspectors did not identify a violation of regulatory requirements associated with this example.
The licensee, at times, maintained a door to the steam tunnel from the reactor building first floor open in Mode 1. The licensee maintained the door open when personnel were inside the area investigating elevated area temperatures in the reactor building steam tunnel. The door served several functions, which included a high-energy-line-break (HELB) barrier. However, the inspectors noted the licensee did not evaluate the impact of maintaining the door open on its function. After questioning by the inspectors, the licensee determined that maintaining the door open for reasons other than momentary transit constituted an unanalyzed condition. As a result, the licensee submitted an eight-hour non-emergency event notification to the NRC (EN 55231) and a corresponding license event report (LER 2021-001-00). The inspectors plan to perform additional review of the circumstances discussed in the event report.
Air-operated valve T4600F407 had a function to isolate the non-safety-related reactor building ventilation system from the safety-related standby gas treatment system (SBGT). It failed to stroke closed during a planned surveillance test. The licensee replaced an air cylinder and some internal components on the actuator. The licensee did not perform a post-maintenance test to verify proper operation of the valve and left it in the open position with the pneumatics to close the valve isolated. The licensee stated they were concerned that if the valve failed to reopen during testing or was inadvertently closed, the operability of both divisions of SBGT could be impacted.
However, the inspectors noted that, while the valve was failed into its safety position to support SBGT system operability, it had a required FLEX function to close during beyond-design-basis events to vent primary containment. While the licensee had concluded pneumatics could be restored during a beyond-design-basis event, the inspectors identified the condition was not documented per site procedure MOP25, "Beyond-Design-Basis Event Coping Strategies Program Document," as a condition affecting hardened vent capability for in excess of 30 days. Additionally, the licensee later determined their initial assessment of the impact on the SBGT system was incorrect, in that failure of the valve to open would impact only one division of the SBGT system. The valve was subsequently successfully tested. The inspectors did not identify a violation of regulatory requirements associated with this example.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 27, 2021, the inspectors presented the integrated inspection results to Mr. P. Dietrich, Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-22519
Ceramic Insulators Missing Parts
03/21/2021
Corrective Action
Documents
21-25739
Breaker A7 open (Bus 1-2B) Overcurrent on X Phase
06/29/2021
Generator
Transformers
S1100 Main Turbine Generator Transformers System Health
Report 1Q2021
05/03/2021
Miscellaneous
S2000 345kV
345kV Switchyard System Health Report 1Q2021
05/03/2021
Procedures
MWC16-100
Seasonal Readiness
Corrective Action
Documents
Resulting from
Inspection
21-25340
NRC Identified E2100-F010A Missing Handwheel Stem Nut
06/16/2021
Diagram Core Spray System
Reactor Core Isolation Cooling System
BE
Reactor Core Isolation Cooling (RCIC) System Barometric
Condenser
AT
Standby Gas Treatment and Primary Containment Purge
System Reactor Building
AI
Piping and Instrument Diagram Standby Feedwater System
U
Drawings
23.107.01
Standby Feedwater System
23.203
Core Spray System
23.206
Reactor Core Isolation Cooling System
105
Procedures
23.404
16-29844
Expectations for Fire Watch Rounds Requires Clarification
and Documentation
2/11/2016
20-28405
Fire Brigade Annual Live Burn Requirement Will go Overdue
due to COVID-19 on 8/22/2020
07/20/2020
21-22116
Door Modified
03/08/2021
Corrective Action
Documents
21-23702
Water-Tight Penetration
04/27/2021
Corrective Action
Documents
21-22547
Failure to Compensatory Fire Watch Inspections - NRC
Identified
03/22/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-23889
Several Sprinklers in Close Proximity to HVAC Ducting -
NRC Identified
05/04/2021
Resulting from
Inspection
21-24760
NRC Question - Extent of Condition Review for Modified
Door (RHR - D26)
05/31/2021
Reactor and Auxiliary Building Sub-Basement Walls
M
Fire Protection Evaluation Reactor Building Sub-Basement
L
General Arrangement RHR Complex Grade Floor Plan
I
Drawings
A-N-2641
Fire Protection Residual Heat Removal Complex Floor Plan
EL. 590'-0"
FP-RB-4-17b
Reactor Building Recirculation System Motor Generator
Area, Zone 17, Elevation 659'6"
FP-RB-SB-4a
High Pressure Coolant Injection Pump and Turbine Room,
Zone 4
FP-RHR-1-11-
RHR Complex, EDG 11 Room, El. 590'-0"
FP-RHR-1-11-OS
RHR Complex, EDG 11 Oil Storage Room, El. 590'-0"
FP-RHR-1-12-
RHR Complex, EDG 12 Room, El. 590'-0"
FP-RHR-1-12-OS
RHR Complex, EDG 12 Oil Storage Room, EL. 590'-0"
FP-RHR-1-13-
RHR Complex, EDG 13 Room, El 590'-0"
FP-RHR-1-13-OS
RHR Complex, EDG 13 Oil Storage Room, El 590'-0"
Fire Plans
FPEE-05-0020
NFPA 13-1980 Non-Compliances for Several Sprinkler
Systems
23.501.01
Fire Water Suppression System
28.507.03
Fire Door Inspection - BOP
35.000.242
Barrier Identification and Classification
Procedures
MOP11-100
Fire Protection Implementation
Calculations
DC-4689
Flood Depth in the Torus Room Assuming a Torus Rupture
A
21-23702
Water-Tight Penetration
04/27/2021
21-23890
Tracking CARD for EFA-E41-21-03, High Pressure Coolant
Injection Wall Penetration Gap, Comp Measure
05/04/20201
Corrective Action
Documents
21-23932
Potential Confusion Associated with Operability
Determination of CARD 21-23702
05/05/20201
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
ARP 2D82
Reactor Building Torus Sump Level Hi-Hi/Lo-Lo
19-24051
Recommend Scheduling Swap of the Division 1 EECW Heat
Exchangers
05/28/2019
19-27521
Unexpected Increase in Division 1 EECW Heat Exchanger
Differential Pressure After Recent Swap
10/03/2019
Corrective Action
Documents
20-29940
Division 1 EECW Plat/Frame Hx Cleaning WO Scope
Deleted and Rescheduled Numerous Times
09/03/2020
Heat Exchanger
Inspection Report
EECW Division 1 Plate Frame Hx, WO 54099224
03/01/2021
Miscellaneous
VMB9-37
Alfa Laval MX25-BFD Plate Heat Exchanger Instruction
Manual
A
Work Orders
54099224
Clean EECW Division 1 'A' Plate Type Heat Exchanger
03/02/2021
Training Change
Request SS-OP-
2-2066
Simulator Lesson Plan
Miscellaneous
Training Change
Request SS-OP-
2-2068
Simulator Lesson Plan
20.107.02
Loss of Feedwater Heating
2.000.03
Power Operation 25% to 100% to 25%
106
29.100.01 SH 1
RPV Control
Procedures
29.100.01 SH 1A
Corrective Action
Documents
21-24863
E4150F042 Valve Slow to Open During 44.030.153
06/03/2021
Corrective Action
Documents
Resulting from
Inspection
21-25339
Response to NRC Question Regarding HFA Relays Extent
of Condition
06/16/2021
Procedures
35.318.017
Inspection and Testing of Multi-Contact Auxiliary Relays
21-21105
TIP 'D' Squib Valve Partial Discharge During
Troubleshooting
2/04/2021
21-23548
Air Line Disconnected on N22F414B Causing the Valve to
Fail Open
04/21/2021
Corrective Action
Documents
21-23562
I/V Curve Unsuccessful I/V Curve on TIP 'E'
04/22/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-25739
Breaker A7 Open (Bus 1-2B) Overcurrent on X Phase
06/29/2021
SD-2500-01
One Line Diagram Plant 4160V & 480V System Service
CD
Drawings
SD-2500-02
One Line Diagram 13.8 kV
BE
ODE-2
Operations Evolution Order
Miscellaneous
Risk Management
Plan
TIP Detector Isolation
04/22/2021
Calculations
DC 5713 Volume
Hydraulic Evaluation of the Fire Distribution Loop
C-F
21-21167
Alternate Diesel Fire Pump Flow Concern
2/07/2021
21-21191
Alternate Diesel Fire Pump Did Not Achieve 2500 gpm @
150 psig
2/08/2021
21-21250
Indications of a Partially Plugged Suction Line During
Alternate Diesel Fire Pump Run
2/10/2021
21-21583
Investigation into TRSR 3.12.2.13
2/18/2021
Corrective Action
Documents
21-21704
Suction Hoses Installed Beyond Expected Depth
2/23/2021
Procedures
28.504.03
Fire Suppression Water System Simulated Automatic
Actuation Test
18-30
13-24513
EDG 13 Overspeed Trip Alarm During Standby Checks
06/24/2013
17-23166
Recommend Enhancement on EDG Overspeed Switch
04/06/2017
21-22187
EDG 11 Overspeed Will Not Reset
03/09/2021
21-23248
Contacts Slow to Close
04/13/2021
21-24247
T100B009 Division 1 CCHVAC Chiller Trip
(MCR Alarm 8D5)
05/14/2021
21-24290
Leak Walkdown - Valve Packing Leak on E5150F008 "RCIC
Turbine Steam Supply OTBD CNTM ISO MOV"
05/16/2021
21-24307
CCHVAC EIT Request Spec Sheet Change to Adjust
Division 1 CCHVAC Oil Cooler Set Point
05/16/2021
21-24355
N1100F059A MS East Bypass Valve Discrepancies During
24.109.02
05/17/2021
21-24365
NQA - Forced Outage 21-01 Contingency Work Order 221325 - Replace Heat Stressed Cables to E5150008
Was Not Routed to QA for Review
05/18/2021
Corrective Action
Documents
21-24383
Leadership Gap - Maximum Appropriate Involvement Not
Achieved During Evaluation of E5150F008 MOV As-Found
05/18/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Conditions
21-24386
E5150F008 As-Found Condition FO 2021-01
05/18/2021
21-24416
Work Order Revision Recommended
05/19/2021
21-24430
Trip of RPS B, 'B' EPA Breaker Tripped Causing Loss of
RPS B
05/18/2021
21-24511
Failed PMT During EPA B Channel Functional - 61260479
05/21/2021
NBS ANN Inputs and Relay Tabulation Testability
Modification
AH
Reactor Protection System Motor Generator Set B
Z
Water, Side and Miscellaneous Chiller Inst. Control Center
A/C System Reactor Building
AG
Drawings
AMD-4312
Elec Protection Assembly
F
ACMP 21-07
Division 1 CCHVAC Chiller
LCO 2021-0178B
Operations Log
Miscellaneous
VMS25-49
Centrifugal Water Chillers
L
24.109.02
Turbine Bypass Valve Operability Test
Procedures
44.30.253
ECCS - Reactor Vessel Water Level (Levels 1, 2, and 8),
Division 1, Channel C Functional Test
43041256
Contingency Work Order Requested for 44.030.253; Level 1,
2, and 8 Channel C Functional
08/13/2015
210452
Received 8D5 Division 1 Control Room A/C Trouble in the
05/14/2021
217916
Received D5 Division 1 Control Room A/C Trouble in the
05/15/2021
221106
E5150F008 Damage to Valve Stem
05/17/2021
222390
Install Monitoring Equipment and Adjust Lube Oil Pressure
05/17/2021
Work Orders
249461
N1100F059A MS East Bypass Valve Discrepancies During
24.109.02
05/19/2021
21-24268
Water Leaks Identified from Three Drywell Penetrations
05/15/2021
21-24276
TB2 Steam Tunnel
05/15/2021
21-24277
Steam Leak Noted in TB2 Steam Tunnel, N2200F64
05/15/2021
Corrective Action
Documents
21-24278
Steam Leak Noted in TB2 Steam Tunnel, N200F349
05/15/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-24302
Main Turbine Generator Rubbing Observed During Coast
Down After Trip
05/16/2021
21-24303
Control Rod 06-27 Over Inserted During Scram
05/16/2021
21-24374
Request Work Order to Support Transducer Calibration
Check of MTG Instrumentation
05/18/2021
21-24386
E5150F008 As-Found Condition FO 2021-01
05/18/2021
21-24494
Untimely Issue Resolution and/or Poor Communications
Associated with G3352F220 Results in Increased Dose and
Radiological Risk
05/21/2021
21-24506
Untimely Identification of Issues in Corrective Action
Program and to OCC
05/21/2021
Corrective Action
Documents
Resulting from
Inspection
21-24360
NRC Concern
05/17/2021
Engineering
Evaluations
FPEE-02-0020
Fire Barrier Evaluation for Turbine Building Steam Tunnel
Penetration Seals to the Torus Room Ceiling
Miscellaneous
Reactivity
Maneuvering
Plan
FO 21-01 Reactor Startup
2.000.04
Plant Shutdown from 25% Power
2.000.05
Pressure and Temperature Monitoring During Heat up and
Cooldown
23.205
Residual Heat Removal System
148
23.623
Reactor Manual Control System
Procedures
54.000.01
Shutdown Margin Check
36A
20-29133
TIP 'E' Flux Lower than Expected on TIP Run
08/09/2020
21-22988
T4600F407 Failed to Stroke During 24.404.03
04/04/2021
21-23507
TIP 'E' Signal Cable TDR and Detector I/V Curve Tests
Reveal TIP 'E' Detector is Functional
04/21/2021
Corrective Action
Documents
21-23754
Unexpected Message Received from 3DMonicore When
Reprocessing TIPs
04/28/2021
Drawings
D-35730
Assembly Drawing T4XXB-SR (CW) and T4XXB-SR (CW) -
M3
J
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
T4600-000149
Configuration Control of T4600F407 due to Failing to Stroke
Closed During Surveillance Test 24.404.03
05/04/2021
23.206
Traversing In-Core Probe (TIP) System
24.110.05
RPS - Turbine Control and Stop Valve Functional Test
29.FSG.13
FLEX Containment Venting
54.000.05
LPRM Calibration
Procedures
MOP 25
Beyond-Design-Basis Event Coping Strategies Program
Document
Fermi 2 EDG MSPI and WANO Performance Indicators
04/2020 -
03/2021
Fermi 2 HPCI Performance Indicators
04/2020 -
03/2021
RCS Leakage Data
20
RCS Leakage Data
21
Miscellaneous
Mitigating Systems Performance Index (MSPI) Basis
Document
71151
Procedures
24.000.02
Shiftly, Daily, and Weekly Required Surveillances
159
21-22988
T4600F407 Failed to Stroke During 24.404.03
04/04/2021
21-23702
Water-Tight Penetration
04/27/2021
Corrective Action
Documents
21-23782
Crew Learning Opportunity, Incorrect Clearance Authorized
for Work (Level 4 Tagging Issue)
04/29/2021
21-23235
NRC Identified: Inadequate Communications Results in
Revision to Technical Evaluation (TE-A30-21-005) for Past
Operability of N2 Bottle Rack
04/12/2021
Corrective Action
Documents
Resulting from
Inspection
21-23817
NRC Concerns Regarding Steam Tunnel Entries
04/30/2021
Miscellaneous
CLO Worksheet
21-23703 MCR Received 17D21 Division 2 SGTS CO2
Storage Vessel Press High/Low
04/27/2021
Work Orders
46479459
Replace Defective Terminal Blocks at T46P408B
04/27/2021