IR 05000341/2021004

Integrated Inspection Report 05000341/2021004

ML22034A562
Person / Time
Site:	Fermi
Issue date:	02/07/2022
From:	Nestor Feliz-Adorno Reactor Projects Region 3 Branch 4
To:	Peter Dietrich DTE Electric Company
References
IR 2021004
Download: ML22034A562 (33)

Text

February 7, 2022

SUBJECT:

FERMI POWER PLANT, UNIT 2 - INTEGRATED INSPECTION REPORT 05000341/2021004

Dear Mr. Dietrich:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On January 20, 2022, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is 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. 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, Signed by Feliz-Adorno, Nestor on 02/07/22 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: NPF-43 Report Number: 05000341/2021004 Enterprise Identifier: I-2021-004-0095 Licensee: DTE Electric Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Inspection Dates: October 01, 2021 to December 31, 2021 Inspectors: T. Briley, Senior Resident Inspector A. Dahbur, Senior Reactor Inspector G. Hansen, Senior Emergency Preparedness Inspector T. Iskierka-Boggs, Operations Engineer V. Myers, Senior Health Physicist R. Ng, Project Engineer T. Ospino, Resident Inspector T. Taylor, Acting Senior Resident Inspector D. Turpin, Reactor Engineer C. Zoia, Senior Operations Engineer Approved By: Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Fermi Power Plant, Unit 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Improper Storage of Equipment in Auxiliary Building Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.15 Systems NCV 05000341/2021004-01 Resolution Open/Closed The inspectors identified a finding of very low safety significance (Green) with an associated NCV of Technical Specification 5.4.1, "Procedures," for the improper storage of material in the auxiliary building. Contrary to plant procedures, equipment over 400 pounds was secured to a handrail adjacent to a floor opening on the fifth floor. When challenged by the inspectors, the equipment was moved. However, a few days later the inspectors found that someone had moved the equipment back to the same location.

Failure to Make Required 10 CFR 50.72 Report Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71111.15 NCV 05000341/2021004-02 Open/Closed The inspectors identified a Severity Level IV NCV of 10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors," for the licensee's failure to report to the NRC their discovery that the high-pressure coolant injection (HPCI) pump was inoperable.

Failure to Maintain Emergency Plan Effectiveness - Ineffective EALs RS2.1 and RG2.1 Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green None (NPP) 71152 Preparedness NCV 05000341/2021004-03 Open/Closed On March 12, 2021, NRC inspectors identified the failure of the licensee to maintain the effectiveness of the sites emergency plan that meets the requirements in Title 10 Code of Federal Regulations (CFR) Part 50, Appendix E, and the planning standards of Title 10 CFR 50.47(b). Specifically, the licensee failed to maintain the ability to accurately declare emergency action level (EAL) classifications RS2.1 and RG2.1 due to errors in the spent fuel pool water level EAL thresholds.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at or near 100 percent reactor power. On October 28, 2021, the plant commenced a planned power reduction to approximately 60 percent for a rod pattern adjustment and repairs to a non-safety-related steam valve. Power was subsequently returned to 100 percent power on October 30, 2021. On December 17, 2021, the plant commenced a planned downpower to approximately 58 percent in preparation for the refueling outage. The plant remained at or near 58 percent 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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold winter weather the week ending December 25, 2021, to include a review of the following systems:

Fire protection system, specifically, the alternate diesel fire pump General service water system (for readiness to protect against frazil ice)

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on December 21, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Division 2 residual heat removal service water (RHRSW) during Division 1 RHRSW safety system outage during the week ending October 9, 2021

(2) Emergency diesel generator (EDG) 11 and 12 during EDG 14 maintenance outage during the week ending October 30, 2021

(3) Division 1 emergency equipment service water during division 2 maintenance the week ending December 18, 2021

(4) Electric fire pump with the alternate diesel fire pump out of service, completed the week ending December 18, 2021

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of EDG 12 on November 15, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 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) Division 1 control air compressor room on November 9, 2021

(2) Division 2 control air compressor room on November 9, 2021

(3) Reactor building basement northeast corner room on November 17, 2021

(4) Reactor building sub-basement northeast corner room on November 17, 2021

(5) Auxiliary building level 5 during the week ending December 4, 2021

(6) Auxiliary building, division I switchgear room on December 15, 2021

(7) Reactor building standby liquid control system on December 15, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Auxiliary building sub-basement high-pressure coolant injection (HPCI) Room, on December 13, 2021

(2) Division 2 residual heat removal pump room, completed the week of

December 26, 2021 Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Division 2 EDG cable bunker on October 27, 2021

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests and biennial written examinations administered between September 16, 2021 and November 18, 2021.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on September 16, 2021.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a planned downpower on October 28, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated cold EOP/SAG (Emergency Operating Procedure/Severe Accident Guidelines) training on December 1, 2021.

(2) The inspectors observed and evaluated training on upcoming modifications scheduled for the refueling outage on December 8, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Spent fuel pool level instrumentation

(2) Reactor core isolation cooling system

(3) Residual heat removal service water system

(4) Maintenance rule review of the last 2-years high pressure injection system associated CARDs on December 16, 2021

(5) Process radiation monitoring system, completed the week ending December 25, 2021

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Review of quality control sampling related to the replacement of actuator P4400F504B-002 associated with work-order 56479097 on December 14, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 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) Availability of emergency diesel generators with sequencers out of service during the week of December 26, 2021

(2) Emergent replacement of feedwater digital control system modules during the week of December 26, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Past operability for failed surveillance regarding high pressure coolant injection suction-swap circuitry

(2) DC ground and fuse removal on safety related 480V bus 72F-A during the week ending December 4, 2021

(3) Impact on components due to equipment improperly stored in the auxiliary building

(4) Implementation of LCO 3.0.6 for battery charger cooler work the week ending December 18, 2021

(5) Missed PMs for RHR Division 1 and 2 heat exchanger bypass valves during the week ending November 29, 2021

(6) Review of an unanalyzed steam line in the control room envelope, completed December 31, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Replacement of the division 1 emergency equipment cooling water (EECW)temperature controller with a new model, completed the week of December 26, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Emergent Work on Failed Reactor Water Level Transmitter on October 8, 2021

(2) EDG 14 Planned Maintenance Outage during the week ending October 23, 2021

(3) Division 1 RHRSW Relay Maintenance and Discharge Piping Strut Replacement during the week ending November 6, 2021

(4) Replacement of Average Power Range Monitor 2 Circuit Card during the week ending November 27, 2021

(5) Division 1 EECW Makeup Valve Actuator Replacement completed the week of December 26, 2021

(6) Division 2 EECW Makeup Valve Actuator Replacement (including fit-up issues) on December 14, 2021

(7) Testing of Division 1 Load Sequencer Logic following power supply and circuit card replacement during the week ending December 25, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 4160V Bus 65F Undervoltage Logic Testing during the week ending November 6, 2021

(2) RCIC Pump and Valve Operability Testing on November 6, 2021

(3) HPCI Pump and Valve Operability Test on November 16, 2021

(4) Scram Discharge Volume High Water Level Trip System A, Channel A Float Switch Functional Test on November 17, 2021

(5) EDG 14 Slow Speed Start Test on December 20, 2021

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

The licensee did not make any changes to the site's Emergency Action Level procedures or Emergency Plan during the period of this inspection (July 1, 2020 through June 30, 2021). The NRC inspectors independently reviewed the revisions of the site's Emergency Action Level procedures and Emergency Plan that were current for the inspection period to verify no changes were made.

This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) Simulator scenario on November 9,

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Intake that occurred on July 14, 2020

(2) Intake that occurred on April 9, 2021

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Shallow dose assessment for a particle on a shoe, dated October 4, 2018

(2) Effective dose equivalence assessments for radiation work permit 203034

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (13 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Canberra 5XLB, SN 0506381

(2) Ludlum 9-3, SN 343171

(3) MGP AMP-100, SN 933007

(4) Eberline AMS-4, SN 12547

(5) Canberra ARGOS5Z, SN 1610-243

(6) Canberra GEM5, SN 0512-029

(7) RADECO H-809V1, SN 4356

(8) Ludlum 12, SN 318608

(9) Ludlum 177, SN 81048

(10) Eberline RO-20, SN 12015

(11) NE Technology SAM11, SN 306

(12) MGP Telepole, SN 6604-067

(13) Canberra HPGE, Detector 2 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Turbine building vent radiation monitor

(2) Circulating water system decant line radiation monitor

(3) Off gas channel 'B' radiation monitor

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Sampling and Analysis (IP Section 03.02) (3 Samples)

The inspectors evaluated sampling and analysis for the following effluent pathways:

(1) Turbine building vent

(2) Reactor building vent

(3) Containment purge

Dose Calculations (IP Section 03.03) (3 Samples)

The inspectors evaluated the following dose calculations:

(1) Containment purge pre-release evaluation

(2) Turbine building monthly dose calculation

(3) Site monthly cumulative dose evaluation

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicator submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) ===

(1) October 01, 2020 through September 30, 2021

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 01, 2020 through September 30, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 01, 2020 through September 30, 2021

71152 - Problem Identification and Resolution (PI&R)

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.

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Ability to declare emergency action levels (EALs) associated with modified spent fuel pool level indication

(2) Actions taken in response to component failures on division 2 direct current system

INSPECTION RESULTS

Improper Storage of Equipment in Auxiliary Building Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.15 Systems NCV 05000341/2021004-01 Resolution Open/Closed The inspectors identified a finding of very low safety significance (Green) with an associated NCV of Technical Specification 5.4.1, "Procedures," for the improper storage of material in the auxiliary building. Contrary to plant procedures, equipment over 400 pounds was secured to a handrail adjacent to a floor opening on the fifth floor. When challenged by the inspectors, the equipment was moved. However, a few days later the inspectors found that someone had moved the equipment back to the same location.

Description:

On October 26, 2021, the inspectors discovered equipment used for handling refrigerant that was not restrained in accordance with plant procedures. The licensee established procedure MOP23, "Plant Storage," Revision 6, to reasonably ensure equipment stored at the auxiliary building would not adversely impact nearby equipment important to safety during a seismic event. It prohibited 'daisy-chaining' equipment together. However, this equipment was

'daisy-chained' to a handrail. In addition, the equipment weight was over 400 pounds and it was secured to a handrail that the procedure stated was only acceptable for up to 400 pounds. The inspectors were particularly concerned because there was an opening below the handrail that led to lower levels of the building which contained electrical conduit associated with Division 1 equipment important to safety and fire protection piping. No engineering evaluation existed to justify placement the of the equipment.

As a result of this discovery, the licensee moved the equipment to a procedurally allowed location. While touring the auxiliary building a few days later, the inspectors found the equipment back against the same handrail. The licensee again moved the material to an approved location. In addition, the licensee performed an engineering evaluation and concluded that the handrail would have prevented the equipment from tumbling down in a seismic event given the geometry of the particular handrail and weight of the equipment.

Corrective Actions: The licensee moved the material to an approved location and reiterated to all personnel the requirements for storing material in the plant. Given the similarity to an NCV issued in Fermi Inspection Report 05000341/2021001 (i.e., NCV 05000341/2021001-01) for the improper storage of nitrogen bottles on a handrail, the licensee started to reassess the use of handrails to secure equipment at all.

Corrective Action References: CARD 21-29970

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to properly restrain equipment over 400 pounds in the auxiliary building was contrary to licensee procedure MOP23, "Plant Storage," Revision 6, and was a performance deficiency.

Equipment over 400 pounds was secured to a handrail above other plant equipment and was also 'daisy-chained' together.

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 properly restrain the equipment led to reasonable doubt as to the operability or functionality of nearby equipment that was important to safety.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green) based on answering 'no' to all the questions in Section A of Exhibit 2. Specifically, the licensee performed an engineering evaluation and reasonably determined that the equipment would not become a seismic hazard.

Cross-Cutting Aspect P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the corrective actions taken to address NCV 05000341/2021001-01 did not resolve the causes for the plant storage issues. Furthermore, after the improperly stored equipment was moved to an approved location, the licensee moved the equipment back to the unapproved location within days without evaluation.

Enforcement:

Violation: TS 5.4.1, "Procedures," requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Contrary to the above, since at least October 26, 2021, to November 8, 2021, the licensee failed to implement a procedure recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, Section 9 of Regulatory Guide 1.33 states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established procedure MOP23, "Plant Storage," Revision 6, to implement storage and staging requirements of equipment during, in part, maintenance activities that could affect the performance of safety-related equipment. The procedure prohibited 'daisy-chaining' equipment together and securing equipment weighing more than 400 pounds to handrails.

However, when preplanning and performing maintenance activities involving refrigeration equipment, the licensee secured equipment weighing more than 400 pounds to a handrail without performing an engineering evaluation and daisy-chained pieces of equipment together.

The start date of the violation was unknown because information was not available to reasonably determine or estimate when the licensee first stored the equipment as described above. The inspectors identified the violation on October 26, 2021, and the licensee restored compliance on November 8, 2021.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Make Required 10 CFR 50.72 Report Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71111.15 Applicable NCV 05000341/2021004-02 Applicable Open/Closed The inspectors identified a Severity Level IV NCV of 10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors," for the licensee's failure to report to the NRC their discovery that the high-pressure coolant injection (HPCI) pump was inoperable.

Description:

The HPCI pump is normally aligned to the condensate storage tank (CST) and has a Technical Specification (TS) related function to automatically transfer to the torus upon a low level in the CST. The licensee tested the associated circuitry on June 3, 2021. After injecting the simulated low-level signal for one of the two level detection channels, the transfer of suction (via opening and closing of the two different suction valves) took approximately 5 minutes, which was longer than anticipated. As a result, the licensee declared that channel of instrumentation inoperable and entered TS limiting conditions for operation (LCO) 3.3.5.1 action D.2, which required the channel to be placed in trip or suction aligned to the torus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Later investigation revealed a set of contacts with some carbon build-up on a relay associated with the suction transfer. It was believed this set of contacts was the reason for the slow transfer. The next day, the contacts were cleaned and the LCO action for one inoperable channel was exited by the licensee.

On June 8, 2021, the inspectors challenged the licensee regarding the loss of initiation capability and why TS LCO 3.3.5.1 D.1 was not entered. Specifically, the licensee did not realize the failed relay was common to both channels of level instrumentation. Having two level channels inoperable constituted a loss of HPCI initiation capability, which would have required entry into TS LCO 3.3.5.1 action D.1. This action required HPCI to be declared inoperable within one hour if not aligned to the torus. The HPCI suction remained aligned to the CST for several hours after the discovery of the failed relay because the licensee was implementing action D.2 instead. The licensee reviewed this concern and determined action D.1 should have been entered on June 3. Since HPCI is a single-train system, its inoperability also constituted a loss of safety function which was reportable under 10 CFR 50.72 (b)(3)(v)(D) as an eight-hour notification. The eight-hour notification was sent on November 3, 2021 (EN 55558).

Regarding the inappropriate TS entry, the inspectors determined that since the suction transfer ultimately occurred after 5 minutes during the test, this reasonably demonstrated the circuit was restored to operable due to the carbon build-up having been 'burned through' enough during the test. Until the contacts were burnished the following day, it was unlikely enough deposits would accumulate to adversely affect the circuit. As a result, the inspectors determined the issue of the inappropriate TS entry to be of minor significance. Regarding the condition of the contacts, the maintenance program for the relay type in question was reviewed by the inspectors as part of a maintenance effectiveness sample in NRC Inspection Report 05000341/2021003. No performance deficiencies were identified.

Corrective Actions: The licensee sent in a late event notification and entered the issue into the corrective action program to explore the missed notification and issues regarding the initial operability determination for the HPCI system.

Corrective Action References: CARDs 21-25079 and 21-29769

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: Based on the NRC Enforcement Policy dated January 15, 2020, section 6.9 lists a failure to make a required report per 10 CFR 50.72 as an example of a Severity Level IV violation.

Violation: 10 CFR 50.72 requires, in part, that each nuclear power reactor licensee shall notify the NRC Operations Center of those non-emergency events specified in paragraph (b).

Paragraph (b)(3)(v)(D) of 10 CFR 50.72 states, in part, that events or conditions that at time of discovery could have prevented fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident be reported within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Contrary to this requirement, on June 3, 2021, the licensee failed to notify the NRC Operations Center of a condition that at the time of discovery could have prevented fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Specifically, the licensee did not notify the NRC Operations Center within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of discovering a failed relay that resulted in the loss of HPCI safety function. The licensee discovered the failed relay on June 3, 2021 during a surveillance. However, the licensee did not recognize the full impact of the relay failure on the operability of HPCI, which is a single-train system, until June 8, 2021.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Maintain Emergency Plan Effectiveness - Ineffective EALs RS2.1 and RG2.1 Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green None (NPP) 71152 Preparedness NCV 05000341/2021004-03 Open/Closed On March 12, 2021, NRC inspectors identified the failure of the licensee to maintain the effectiveness of the sites emergency plan that meets the requirements in Title 10 Code of Federal Regulations (CFR) Part 50, Appendix E, and the planning standards of Title 10 CFR 50.47(b). Specifically, the licensee failed to maintain the ability to accurately declare emergency action level (EAL) classifications RS2.1 and RG2.1 due to errors in the spent fuel pool water level EAL thresholds.

Description:

On October 21, 2014, Fermi 2 submitted to the Nuclear Regulatory Commission a License Amendment Request (LAR), specifically NRC-14-0055, License Amendment Request to Revise the Emergency Action Level Scheme for the Fermi 2 Emergency Plan. The LAR was submitted to the NRC for review and approval of the proposed Emergency Action Level (EAL)scheme change that incorporated the guidance in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. The submitted EAL scheme change included new spent fuel pool (SFP) level EALs that incorporated threshold values for classification of a Site Area Emergency (SAE), and General Emergency (GE) that used the top of the spent fuel racks as a reference level for identifying the respective EAL (RS2.1 and RG2.1) thresholds. The top of rack reference level was identified as 0 feet, and the threshold value identified for classifying a SAE or GE using EAL RS2.1 and RG2.1 was 0 feet, 3 inches (03).

During the licensees development of the EAL LAR submittal, work associated with EDP-37088 was ongoing in response to NRC Order EA-12-051. The NRC Order required the installation of reliable SFP indicators for monitoring the spent fuel pool water level.

EDP-37088 incorporated the scope of work planned for the installation of primary and backup SFP level instrumentation to monitor water level from the normal level of the pool to the top of the spent fuel rack in the spent fuel pool.

The licensees EAL LAR submittal (NRC-14-0055) was prepared and submitted to the NRC for review and approval on October 21, 2014. This was prior to the completion of the work orders supporting EDP-37088, that were completed in December of 2014. Following the completion of the work orders, the licensee modified the EAL threshold value setpoint identified in NRC-14-0055 to a numeric reference level that enhanced the ability to read this value on the SFP level indicator installed in the Control Room. The licensee established the threshold value at 15 feet, the numeric level determined to be the equivalent to the 03 reference level identified in the EAL LAR.

On March 12, 2021, in response to questions posed by the NRC Senior Resident Inspector as to the accuracy and ability to read the 15-foot SFP level EAL threshold value, the licensee conducted an emergency preparedness drill scenario that simulated the loss of SFP level.

During the drill it was identified that the existing SFP level monitoring system and the SFP level indicator would not provide level indications below the 15.09-foot level, preventing the classification of an SAE or GE based on the identified EAL threshold value of 15 feet.

Corrective Actions: Upon identification of the deficiency, the licensee entered the issue into the sites corrective action program and implemented compensatory measures in the form of a standing order (night order) for the control room. The order stipulated if there is a leak in the SFP and the level is dropping and reaches the bottom of the scale and stops moving and it is known that there was no repair or change to the leak then it is to be assumed that the level has reached the 15 feet and the SAE should be declared.

As a result of the licensees evaluation of the deficiency, including a root cause analysis, the licensee revised EP-101, Classification of Emergencies, changing the EAL threshold values for RS2.1 and RG2.1 to 16 feet, a readable indication on the Control Room SFP level indicator.

Corrective Action References: CARD 21-22263

Performance Assessment:

Performance Deficiency: On January 26, 2016, the licensee updated the sites EAL classification scheme, incorporating the guidance in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. EP 101, Classification of Emergencies, Revision 41, included new spent fuel pool (SFP) level EALs that contain a SFP level threshold value of 15 feet for the classification of a Site Area Emergency (SAE) and General Emergency (GE) for EALs RS2.1 and RG2.1 respectively. The identified threshold value of 15 feet was not a readable level on the SFP level indicator installed in the main control room due to errors in the licensee's calibration of the SFP level indicator. The inability of the main control room staff to identify a decrease in the SFP level to the EAL threshold values would have adversely impacted the site's ability to accurately declare a SAE or GE using EALS RS-2.1 and RG-2.1.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the offsite EP attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.

Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. The SDP guidance allows for mitigating factors to be credited when determining significance. Using the SDP, and informing the evaluation with accident analysis insights, NRC inspectors determined that mitigating factors exist since there are other initiating conditions (ICs) with associated EALs that would lead to a declaration of a Site Area Emergency or General Emergency before the SFP Level EAL is met. Due to these mitigating factors, the inspectors assessed the significance of the finding as Green.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50.54(q)(2) requires, in part, that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements of Title 10 CFR Part 50, Appendix E, and the planning standards of 10 CFR 50.47(b).

10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Contrary to the above, since January 26, 2016 (date of revision to EP 101, Classification of Emergencies, Revision 41), the licensee failed to maintain the effectiveness of its emergency plan and use a standard emergency classification and action level scheme that includes facility system and effluent parameters in determining the initial offsite response measures.

Specifically, the licensee failed to maintain the ability to accurately declare EAL classifications RS-2.1 and RG-2.1, involving spent fuel pool water level indications during implementation of the sites Emergency Plan.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Semi-Annual Trend Review 71152 The inspectors noted an adverse trend in conditions reflective of issues documented in 2021 NRC inspection reports (i.e., 05000341/2021001 and 05000341/2021002). One area of note dealt with the quality and thoroughness of reviews involving the operations department (references: observation documented in section 71152 of NRC Inspection Report 05000341/2021002 and NCV 05000341/2021001-01). Examples follow:

An evaluation reviewed by inspectors regarding an unanalyzed steam line within the control room envelope justified operability by relying on an excess-flow check valve.

This valve was installed during original construction and had never been tested nor had preventative maintenance performed on it. When asked by inspectors if the valve could be shut to eliminate any concern, engineering reported that operations had been consulted and that the valve could not be shut. Upon further review, it was determined the valve had a handwheel and could be closed. The licensee subsequently added the issue to the 'ops concerns' list, closed the valve, and added further information to the evaluation regarding operability.

Work was approved on combustion turbine generator (CTG) 11-1 without realizing it would be rendered non-functional while other work was ongoing on one of the EDGs.

The issue was discovered when unexpected alarms were received in the control room.

Following the observation listed in NRC Inspection Report 05000341/2021002 regarding the reactor building steam tunnel door, the inspectors discovered sump covers removed in the reactor building southeast corner sub-basement to support work in the sump. Despite being listed as a barrier requiring consideration in site procedure 35.00.242, "Barrier Identification/Classification," Revision 59, a risk assessment was not performed prior to removing the covers. Subsequent investigation revealed there were no safety impacts.

Despite the potential for the turbine building ventilation system to trip on cold inlet temperatures being a known condition, with specific temperature monitoring added to rounds conducted every shift, the system tripped on cold temperature due to inadequate monitoring on operator rounds.

Another area dealt with the storage and staging of materials in the reactor and auxiliary buildings. Since NCV 05000341/2021001-01, within the last 6 months the following were noted:

Improper storage of equipment on the auxiliary building fifth floor (NCV 05000341/2021004-001 in this report).

Repeat instances of equipment tied together as a form of restraint, contrary to plant procedure, identified by the site's nuclear quality assurance department and NRC.

Fire extinguishers not stowed appropriately. In one instance, a fire extinguisher fell down an elevator shaft days after the inspectors identified it was improperly secured.

Multiple scaffolds identified by NRC inspectors as being installed past their due date without an engineering evaluation. In one instance, a scaffold was constructed within 3 inches of safety-related equipment without the required engineering evaluation (it was later deemed acceptable as built).

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 20, 2022, the inspectors presented the integrated inspection results to Mr. P. Dietrich, Chief Nuclear Officer, and other members of the licensee staff.

On October 15, 2021, the inspectors presented the radiation protection inspection results to Mr. P. Dietrich, Chief Nuclear Officer, and other members of the licensee staff.

On November 5, 2021, the inspectors presented the 2021 Fermi Biennial License Operator Requalification Program inspection results to Mr. J. Angel, Training Director, and other members of the licensee staff.

On November 22, 2021, the inspectors presented the 71111.11A Annual Requalification Results Exit Meeting inspection results to Mr. B. Sullivan, Vice President - Engineering &

Technical Support, and other members of the licensee staff.

On December 7, 2021, the inspectors presented the emergency plan and emergency action levels changes review inspection results to Mr. E. Frank, Equipment Reliability Supervisor, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 21-29510 Survey Points of the Shore Barrier 10/26/2021

Documents 21-31105 Condition of the Alternate Diesel Fire Pump 12/16/2021

Corrective Action 21-30746 Multiple Issues at Cooling Tower De-Ice Shack 12/06/2021

Documents 21-31119 Temp Power Cart Weather Protection Issues 12/16/2021

Resulting from 21-31246 RB/AB Roof Issues 12/21/2021

Inspection

Drawings 6C721-40 Shore Barrier Plan and Sections N

Engineering EDP-60079 Rehabilitation of General Service Water Channel Jetties 0

Changes

Procedures 20.000.01 Acts of Nature 56

23.101 Circulating Water System 105

23.131 General Service Water System 114

MWC16-100 Seasonal Readiness 2

71111.04 Corrective Action 21-31032 Oil Markings on Division 1 EESW Motor Just Grooves in 12/14/2021

Documents Bezel

Resulting from

Inspection

Drawings 6M721-5734 Emergency Diesel Generator System BL

6M721N-2056 P&ID Diesel Generator Ventilation RHR Complex Division I R

M-2183-1 RHRSW Return System AB

Fire Plans FP-RHR-2-52 RHR Complex, EDG 11 Switchgear and Switchgear 7

Ventilation Room Zone 52, Elevation 617'0"

Miscellaneous DBD-X41-03 Residual Heat Removal Complex Heating and Ventilation B

System

Procedures 23.205 Residual Heat Removal System, Attachment 1B, DIV 2 RHR 02/09/2021

Initial Valve Lineup

23.208 RHR Complex Service Water System, Attachment 1B, 11/28/2018

DIV 2 RHRSW Valve Lineup

23.307 Emergency Diesel Generator System, Attachment 10B, 10/17/2019

EDG 12 Standby Lineup Verification

23.307 Emergency Diesel Generator System, Attachment 2B, 10/23/2006

EDG 12 Electrical Lineup

Inspection Type Designation Description or Title Revision or

Procedure Date

23.307 Emergency Diesel Generator System, Attachment 1B, 03/31/2020

EDG 12 Valve Lineup

23.420 RHR Complex Heating and Ventilation, Attachment 1, 11/15/2006

RHR Complex Heating and Ventilation Electrical Lineup

23.501.01 Fire Water Suppression System 64

MMA08 Scaffolding 21

71111.05 Calculations DC-4921 Appendix R Calculations Vol. 1 Book 1 of 3 1

Corrective Action 21-29684 Degraded Hardware on Door RB-6 10/31/2021

Documents 21-29954 Fire Door R5-9 has a Crack in the Door Face 11/08/2021

Fire Plans FP-AB-2-9b Auxiliary Building, Division I Switchgear Room, Zone 9, 12/15/2021

EL. 6133

FP-AB-5-16f Auxiliary Building, Fifth Floor Ventilation Equipment Room, 4

Zone 16, Elevation 677'0"

FP-AB-BMT-4 Control Air Compressor Room, Zone 4, EL., 551'0" 5

FP-RB-4-17a Reactor Building SLC System Zone 17 EL. 6596 12/15/2021

FP-RB-B-5b Reactor Building Basement Northeast Corner Room Zone 5, 4

EL. 562'0"

FP-RB-SB-5a Reactor Building Sub-Basement Northeast Corner Room, 6

Zone 5, EL. 540'0"

Procedures 35.000.242 Barrier Identification/Classification 60

71111.06 Corrective Action 21-31053 NRC-Concern-Test Cap for the HPCI Room Flood Level had 12/15/2021

Documents a Detached Loss Prevention Chain

Resulting from

Inspection

Procedures 23.702.01 Plant Systems Leak Check Procedure 13

ARP 2D78 Reactor Building Floor/Equipment Drain Sumps Level 16

HI-HI/LO-LO

EF2-PRA-012 Fermi 2 Internal Flood Analysis Notebook 12/13/2021

Work Orders 58045750 Sump Pump "On" Light for Manhole 169470 Not Illuminated 07/26/2021

with Alarm In

71111.11A Miscellaneous Requalification Licensed Operator Annual Examination Performance 11/18/2021

Program Annual Records for 2021

Testing Summary

Results

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11B Corrective Action Various CARDS Reviewed CARDS for Operations-Related Issues Which 01/20/2020

Documents Occurred Since the Previous 71111.11B Inspection for to

PI and R to Determine How the Issues Were Dispositioned 08/31/2021

Miscellaneous 2021 Fermi Reviewed Entire Written Examination (30 Questions) for RO 09/16/2021

Biennial and SRO Licensed Operators Administered During 2021

Requalification Fermi Biennial Requalification Examination

Written

Examination

CRs for Simulator Open and Closed CRS to Determine How They Were 11/2020 to

Issues - Various Addressed 11/2021

Instruction 1.20 - Simulator-to-Plant Fidelity Transient Testing Checklists 4

Simulator Fidelity

B

NANT-21-0065 Simulator Configuration Update for 10 Change Requests 06/21/2021

and Modifications

NRC Form 396s - Reviewed Medical Records for 3 ROs and 3 SROs per 0

Various ANSI/ANS - 3.4, 1983 Standard

Operating Reviewed 10 JPMs for Requalification Operating Exam 10/01/2021

Examination -

JPMs Various

from 2021 Fermi

Biennial

Requalification

Exam

Operating Simulator Scenarios from 2021 Operating Test Administered 10/01/2021

Examination - During Week 3 of 2021 Biennial Requalification Exam

Simulator

Scenarios. Four

reviewed from

21 Biennial

Requalification

Operating Test

Inspection Type Designation Description or Title Revision or

Procedure Date

Simulator Core Fermi 2020 Cycle 21 Core Model Testing 10/30/2013

Performance

Testing - Various

Simulator Malfunction Testing as Required by ANSI/ANS-3.5-1985 06/01/2020

Malfunction Tests

- Various

Simulator Review SRB Meeting Minutes for Three Meetings Within the Past 08172015

Board (SRB) Year

Procedures Instruction 1.16 Examination Safeguards and Controls, Revision 46 05/27/2020

Instruction 5.12, LOR Grading Form - Reactor Operator. Reviewed for RO 03/02/2021

5D, That Passed with Remediation and Documented

Revision 25 Remediation Actions Taken

MNT18, Revision Conduct of Operations Training Manual 11/10/2020

MOP01 Revision Conduct of Operations 11/05/2020

MOP19, Revision Reactivity Management 04/30/2019

ODE-8, Revision Administrative Guidelines and Desk Instructions Which 05/27/2021

Includes Program Requirements for Condition of Licenses

SM-7 Various 2020 Surveillance Tests for Safety-Related 15

Equipment or Systems Verifying Simulator Performance

71111.11Q Corrective Action 21-29630 Loss of Heater Drains During Down Power 10/28/2021

Documents

Miscellaneous Refueling/Cold Shutdown EOPs/SAGs Training 12/01/2021 12/01/2021

Procedures 20.107.02 Loss of Feedwater Heating 27

2.000.03 Power Operation 25 Percent to 100 Percent to 25 Percent 107

23.107 Reactor Feedwater and Condensate Systems 155

29.EDM.01 SFP Makeup/Spray - Internal Strategy 5

29.EDM.04 SFP Spray - External Strategy 3

MOP01 Conduct of Operations 42

71111.12 Corrective Action 14-20349 Received 3D57 for CW System 01/17/2014

Documents 19-25461 Design Differential Pressure Not IAW SOE19-01 07/19/2019

19-27829 RHRSW Pump C Differential Pressure Issues 10/15/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

20-20545 Pump Performance Data for SOE 19-01 Did Not Meet 01/16/2020

Acceptance Criteria

21-23072 Possible 50.9 Issue with SFPLI Modification 04/06/2021

21-23827 3D17 IPCS Computer Trouble Alarm 05/01/2021

21-23992 CARD Inappropriately Closed 05/06/2021

21-26201 RHRSW Pump C Exceeded IST Alert Criteria 07/15/2021

21-27491 No Off-Gas Radiation Spikes >50% Last Several Months 08/25/2021

21-27922 Track SPING OOS Time 09/08/2021

21-28383 Review of Radiation Monitor Alarm Setpoints 09/22/2021

21-28792 SS-1 CARD Documentation Requires Investigation 10/04/2021

21-29459 Request Replacement WO for RHRSW Pump C 10/25/2021

21-30345 SPING Compensatory Monitoring 11/19/2021

Corrective Action 21-22263 NRC Identified - Concern with the Ability to Evaluate 03/11/2021

Documents Emergency Action Level for Lowering Spent Fuel Pool Level

Resulting from

Inspection

Drawings I-2181-01 Process Radiation Monitor Subsystems N

Engineering EDP 37088 Install Spent Fuel Pool Level Instrumentation to Comply with 0

Changes NRC Order EA-12-051 Guidance

Engineering 100033987 Commercial Grade Dedication- Temperature Gauge 0

Evaluations 100116743 Commercial Grade Dedication- Polyamide Tubing 0

TE-R30-20-025 Loss of Flange Material on Division 1 EESW, RHRSW C, 0

and EDGSW Pump Column Flange Connections

Miscellaneous Get Well Plan for CARD 14-20706 13

Maintenance Rule Monthly Evaluation Report - Reactor Core 11/02/2021

Isolation Cooling

System Health Report - Reactor Core Isolation Cooling 04/26/2021

CARDs/DERs by HPCI CARDs from 12/27/2019 to 12/16/2021 12/16/2021

System

Procedures EP-542 Computer-Based Offsite Dose Assessment-Airborne 15

Release

MMR Appendix E Maintenance Rule Specific SSC Functions 27

MMR Appendix I Maintenance Rule Support System Information 2

Inspection Type Designation Description or Title Revision or

Procedure Date

SOE 19-01 IST Baseline Test for E1151C001A 1

Work Orders 56479097 Perform Valve Actuator Overhaul and AOV Diagnostic 12/14/2021

Testing

71111.13 Corrective Action 21-27421 Requesting Investigation into Phoenix Model Showing EDG 08/23/2021

Documents 13 and 14 Unavailable

Miscellaneous Plan of the Day, 12/28/2021-12/29/2021 0

Fermi 2- MSPI Basis Document 9

R30-00 Emergency Diesel Generator Design Basis Document I

71111.15 Corrective Action 21-24863 E4150F042 Valve Slow to Open During 44.030.153 06/03/2021

Documents 21-29769 HCCI Inoperability per CARDs 21-24863 and 21-25079 11/03/2021

21-30235 2021 RHR LIR Deficiency - LI-RHR-008 E1100F048A(B) 11/17/2021

Magnesium Rotor Motor Inspections Not Performed Since

2013

21-30291 Control Room Envelope Not Analyzed for Heating Steam 11/18/2021

21-30493 Division 2 ESF 260/130V DC Battery Ground Detection Fault 11/25/2021

Corrective Action 21-25079 NRC Identified: Unidentified HPCI Inoperability 06/09/2021

Documents 21-29970 Improper Plant Storage 11/08/2021

Resulting from

Inspection

Drawings 6I721-2573-23 480V Ess Bus 72, Position "4A and 5A" K

Engineering TE-E41-21-034 Past Operability Evaluation for E4150F042 Delayed Stroke 0

Evaluations

Miscellaneous T41-00 Reactor Auxiliary Building Ventilation System E

Procedures MOP23 Plant Storage 7

71111.18 Corrective Action 21-30542 Unable to Obtain As-Found Data 11/30/2021

Documents

Drawings I-2441-01 Schematic Diagram EECW Pump A S

I-2970-01 BOP Recording and Indicating and Controlling Instrument C

Loop and Computer Inputs

Engineering 70341 Replacement of Division 1 EECW TCV Controller P44K800A 0

Changes

Work Orders 60739425 Replacement of Division 1 EECW TCV Controller P44K800A 11/30/2021

71111.19 Corrective Action 21-28799 TR Relay Did Not Meet Pickup Acceptance Criteria 10/05/2021

Documents 21-28800 TR Relay Did Not Meet Pickup Acceptance Criteria 10/05/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

21-28839 E11-3185-G46 Sway Strut Clamp Bearing Surface Noted on 10/05/2021

Existing Weld

21-28856 TR, AR-Open, and AR- Close Relays All Failed Pickup 10/06/2021

Acceptance Criteria

21-28874 Inspections of New Pipe Restraint E11-3185-G46 10/06/2021

21-28940 B21N680C Reactor Vessel Low Water Level 3 Instrument 10/07/2021

Failed Upscale

21-28977 No I & C Personnel Qualified to Conduct Pressure Sensor 10/08/2021

Response Time Test (Qualification Number 42001000)

21-29319 Identified Oil Leak 10/21/2021

21-29574 Broken Pin on Open Drain I/O Module A4 Position APRM2 10/27/2021

21-30573 Stroke Time Outside of Owner Specified Limit for 12/01/2021

P4400F504A

21-30989 SSO Tagging Delayed due to Scaffold Issues 12/14/2021

21-31030 I&C Scheduled Work Not Completed as Scheduled T-0 12/14/2021

(Work Week 2150)

21-31211 9D21 Division 1 Sequencer Trouble 12/20/2021

Corrective Action 21-31229 PMT Did Not Involve Test of Sequence 12/21/2021

Documents

Resulting from

Inspection

Drawings 6M721-5444 Emergency Equipment Cooling Water Division 1 CC

I-2714-22 H11P898A Load Sequencing Diagram F

Engineering 80028 Division 1 Outage Tie-Ins Buried Pipe Replacement for B

Changes RHRSW and EESW Systems

Miscellaneous EDG14 SSO Fragnet for EDG 14 Safety System Outage 14

EFA-R16-21-001 Pickup Voltage Acceptance Criteria for CR120B GE Relays 0

Troubleshooting WO 62687291, CARD 21-28940, Equipment PIS B21N680C 10/08/2021

Data Sheet

VMC1-61 Trip/Calibration System G

Procedures 23.601 Instrument Trip Sheets 40

2.307.05 EDG Auto Load Sequencer Timer Calibration 34

43.000.004 Visual Examination of Component Supports 35

44.010.125 APRM 2 Channel Functional Test 67

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 51174031 Perform Valve Actuator Overhaul and AOV Diagnostic 11/30/2021

Testing

56479097 Perform Valve Actuator Overhaul and AOV Diagnostic 12/14/2021

Testing

295313 ECN - 80028 - Division 1 Phase 4 RF21 - Replace Existing 10/05/2021

E11-3185-G46 Sway Strut (RB RHR HX Room)

2688438 B21N680C Reactor Vessel Low Water Level 3 Instrument 10/10/2021

Failed Upscale. Troubleshoot and Repair

63934322 Division 1 EDG Sequencer Power Supply Failures 12/21/2021

71111.20 Corrective Action 21-30724 NRC Identified - 29.EDM.04 Requires Amplifying Information 12/06/2021

Documents

Resulting from

Inspection

Miscellaneous RF21 - Training Refueling/Cold Shutdown EOPs/SAGs 12/01/2021

for Licensed

Operators

71111.22 Corrective Action 21-00255 EDG14 Standby Jacket Coolant Pump Packing Leak 12/20/2021

Documents

Resulting from

Inspection

Drawings 6I721-2572-29 4160V Ess. Buses 65E and 65F Load Shedding Strings O

6I721-2578-11 Relaying and Metering Diagram 4160V Ess. Bus 65F and N

65T

6M721-2044 Diagram Reactor Core Isolation Cooling System BE

6M721-2045 Diagram Reactor Core Isolation Cooling (RCIC) System AT

Barometric Condenser

Procedures 23.307.17 EDG14 Start and Load Test 61

23.601 Instrument Trip Sheets 40

24.206.01 RCIC System Pump and Valve Operability Test 89

2.302.10 Calibration and Functional Test of Division 2 4160 Volt 39A

Bus 65F Under Voltage Relays

Work Orders 57463038 Perform 42.302.4160 V Bus 65F (EDG 14) Division 2, 10/27/2021

Under Voltage Circuits, C/Functional

57535004 Perform 24.206.1 RCIC System Pump Operability and 11/04/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Valve Test at 1000 PSIG

57535091 Perform 24.206.01 RCIC PCIV Valve Operability 11/04/2021

57710385 Perform 24.202.01 HPCI Pump / Flow Test & Valve Stroke 11/16/2021

at 1025 PSIG

57785101 Perform 44.010.206 RPS SDV High Water Level Trip SYS 11/17/2021

A, CH A, Float Switch Functional Test

71114.04 Miscellaneous Personnel Qualifications for 10 CFR 50.54Q Compliance 06/01/2021

Reviews (Table)

LP-ER-874-0001 10 CFR 50.54Q Compliance Reviews (Training Lesson 0

Plan)

Procedures Fermi 2 Radiological Emergency Response Preparedness 49

Plan

EP-101 Classification of Emergencies 43A

EP-590 10CFR50.54(q) Screens and Evaluation 1

QG-ER-874-0001 10CFR50.54(q) Reviewer Qualification Guide 0

71114.06 Miscellaneous EP-101 Classification of Emergencies 44

71124.04 Corrective Action 18-27809 Personnel Contamination Event 10/04/2018

Documents 21-26554 Internal Contamination While Performing Tagout D074 07/28/2021

Corrective Action 21-29143 NRC Identified - 2021 RP Baseline Inspection: Inaccurate 10/15/2021

Documents Hot Particle Analysis

Resulting from

Inspection

Miscellaneous Gamma Spectroscopy Report for Particle 10/04/2018

RF20 EDEX Dose Calculation 0

Internal Dose Assessment Package for an Intake 07/14/2020

Internal Dose Assessment Package for an Intake 04/09/2021

Varskin Calculation 10/06/2018

NPRP-14-0002 Offsite Background Study for Optically Stimulated 01/10/2014

Luminescence Dosimeters

NPRP-21-0030 Evaluation of Impact of Current Radionuclide Mix on 04/29/2021

Radiation Protection Instrumentation

NPRP-21-0050 Scaling Factor Report and Waste Stream Sample Results 08/10/2021

Procedures 67.000.400 Personnel Contamination Event Dose Assessment 26A

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Calibration 5XLB Calibration Worksheet for SN 0506381 09/15/2021

Records Ion Chamber Instrument Calibration Form for Ludlum 9-3, 07/15/2021

SN 343171

AMP-100 Calibration Form for SN 933007 09/16/2021

AMS-4 Calibration Form for SN 12547 07/26/2021

ARGOS Series Calibration Form for SN 1611-253 06/09/2021

GEM5 Calibration Data Form for SN 0512-029 07/08/2021

H809 Series Air Sampler Calibration Form for SN 4356 08/17/2021

Ludlum 12 Calibration Form for SN 318608 08/19/2021

Ludlum 177 Calibration Form for SN 81048 06/08/2021

Ion Chamber Instrument Calibration Form for RO-20, SN 08/24/2021

2015

SAM11 Calibration Form for SN 306 09/27/2021

Telepole Calibration Form for SN 6604-067 08/24/2021

Gamma Spectroscopy Calibration Report for Detector 2 09/16/2021

Miscellaneous Certificate of Calibration for Source L93-0056 07/19/1993

Certificate of Calibration for Source X92-0180 08/01/1980

Certificate of Calibration for Source SN 264/88 03/03/1988

Work Orders 53843052 Turbine Building Vent Exhaust Monitor Calibration 09/29/2020

55852729 Circulating Water System Decant Line Radiation Monitor 11/21/2019

Calibration

57752832 Channel 'B' Offgas Radiation Monitor Calibration 09/23/2020

71124.06 Procedures Offsite Dose Calculation Manual 25

Work Orders 53127465 Turbine Building Gaseous Dose (Monthly - June) 07/06/2020

53341703 Turbine Building Gaseous Dose (Monthly - July) 08/10/2020

53359285 Site Gaseous Effluent Cumulative Dose (Monthly - July) 08/25/2020

53575013 Turbine Building Gaseous Dose (Monthly - August) 09/07/2020

53596418 Site Gaseous Effluent Cumulative Dose (Monthly - August) 09/16/2020

53896691 Site Gaseous Effluent Cumulative Dose 10/27/2020

(Monthly - September)

57036890 Containment Purge Pre-Release Calculation 03/20/2020

58789904 SPING Iodine/Particulate Sampler Flowrate Monitor 09/30/2020

Inoperable

Inspection Type Designation Description or Title Revision or

Procedure Date

59467731 Containment Purge Pre-Release Calculation 12/09/2020

59534825 SPING Noble Gas Monitor Inoperable 09/10/2020

71152 Corrective Action 21-23003 Potential Math Error in SFPLI EOP (29.100.01 sh5) 04/05/2021

Documents 21-23072 Possible 50.9 Issue with SFPLI Modification 04/06/2021

21-23559 Review Recently Identified Housekeeping Conditions and 04/22/2021

Assess Operations Performance

21-23694 Typographical Error Noted in 2016-01E 04/27/2021

21-28223 Site Compliance Issues with MOP23 Plant 09/17/2021

Storage/Housekeeping and MOP11 Fire

Protection/Transient Combustibles

21-29071 Crew Learning Opportunity CTG11-1 LCO 10/12/2021

21-30442 TBHVAC North and South Trains Tripped 11/23/2021

Corrective Action 21-22263 NRC Identified Concern with the Ability to Evaluate 03/11/2021

Documents Emergency Action Level for Lowering Spent Fuel Pool Level

Resulting from 21-23015 Revise EAL Training Examples with Information Regarding 04/05/2021

Inspection Spent Fuel Pool Level Indicator

21-26212 Missing Reviews on the 50.59 Form for Scaffold 07/15/2021

21-26574 Transient Combustibles on RB-1 07/28/2021

21-26577 Removed Cover for RB SE Equipment Drain Sump 07/28/2021

21-26754 4 Scaffolds Constructed >90 Days Ago 08/04/2021

21-27046 Roll-Up of NRC Issues for One Task (D074) 08/10/2021

21-28794 Staged Items in the Reactor Building 10/04/2021

Drawings 61721-2225-02 Schematic Diagram HPCI System Power Distribution S

61721-2714-40 Schematics - Digital Load Sequencing System G

6SD721-2530-11 One Line Diagram 26-/130 ESS Dual Battery 2PB AS

Distribution - Division 2

6SD721-2531-13 Internal Wiring Diagram 130 V ESF Battery Charger M

Engineering EDP 37088 Spent Fuel Pool Instrumentation Project Engineering Design 0

Changes Plan

Miscellaneous Night Order for SFP Level Indicator and EAL RS2.1 0

21Q3 Operations Continuous Learning Report 09/30/2021

21-23072 Possible 50.9 Issue with SFPLI Modification (Root Cause 0

Analysis)

Inspection Type Designation Description or Title Revision or

Procedure Date

21-27388 Equipment Cause Evaluation for 21-27388 HPCI and 10/06/2021

Division 2 EDG Sequencer Power Failure

CUR-36003 Failure Analysis of a DC to AC Inverter Galaxy Series 10/06/2021

CUR-36073 Failure Analysis of DC-to-DC Converter 10/05/2021

DET-40279 Failure Analysis of an Auxiliary Transformer from Battery 11/08/2021

Charging System

NRC-14-005 License Amendment Request to Revise the Emergency 10/21/2014

Action Level Scheme for the Fermi 2 Emergency Plan

Procedures EP-101 Classification of Emergencies 41

EP-101 Classification of Emergencies 43A

EP-101 Classification of Emergencies 44

30