IR 05000341/2021004

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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

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.

February 7, 2022 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:

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

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 Aspect Report Section Mitigating Systems Green NCV 05000341/2021004-01 Open/Closed

[P.3] -

Resolution 71111.15 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 Aspect Report Section Not Applicable Severity Level IV NCV 05000341/2021004-02 Open/Closed Not Applicable 71111.15 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 Aspect Report Section Emergency Preparedness Green NCV 05000341/2021004-03 Open/Closed None (NPP)71152 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.

REACTOR SAFETY

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,

RADIATION SAFETY

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 Aspect Report Section Mitigating Systems Green NCV 05000341/2021004-01 Open/Closed

[P.3] -

Resolution 71111.15 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 Aspect Report Section Not Applicable Severity Level IV NCV 05000341/2021004-02 Open/Closed Not Applicable 71111.15 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 Aspect Report Section Emergency Preparedness Green NCV 05000341/2021004-03 Open/Closed None (NPP)71152 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

Procedure

Type

Designation

Description or Title

Revision or

Date

21-29510

Survey Points of the Shore Barrier

10/26/2021

Corrective Action

Documents

21-31105

Condition of the Alternate Diesel Fire Pump

2/16/2021

21-30746

Multiple Issues at Cooling Tower De-Ice Shack

2/06/2021

21-31119

Temp Power Cart Weather Protection Issues

2/16/2021

Corrective Action

Documents

Resulting from

Inspection

21-31246

RB/AB Roof Issues

2/21/2021

Drawings

6C721-40

Shore Barrier Plan and Sections

N

Engineering

Changes

EDP-60079

Rehabilitation of General Service Water Channel Jetties

20.000.01

Acts of Nature

23.101

Circulating Water System

105

23.131

General Service Water System

114

71111.01

Procedures

MWC16-100

Seasonal Readiness

Corrective Action

Documents

Resulting from

Inspection

21-31032

Oil Markings on Division 1 EESW Motor Just Grooves in

Bezel

2/14/2021

6M721-5734

Emergency Diesel Generator System

BL

6M721N-2056

P&ID Diesel Generator Ventilation RHR Complex Division I

R

Drawings

M-2183-1

RHRSW Return System

AB

Fire Plans

FP-RHR-2-52

RHR Complex, EDG 11 Switchgear and Switchgear

Ventilation Room Zone 52, Elevation 617'0"

Miscellaneous

DBD-X41-03

Residual Heat Removal Complex Heating and Ventilation

System

B

23.205

Residual Heat Removal System, Attachment 1B, DIV 2 RHR

Initial Valve Lineup

2/09/2021

23.208

RHR Complex Service Water System, Attachment 1B,

DIV 2 RHRSW Valve Lineup

11/28/2018

23.307

Emergency Diesel Generator System, Attachment 10B,

EDG 12 Standby Lineup Verification

10/17/2019

71111.04

Procedures

23.307

Emergency Diesel Generator System, Attachment 2B,

EDG 12 Electrical Lineup

10/23/2006

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

23.307

Emergency Diesel Generator System, Attachment 1B,

EDG 12 Valve Lineup

03/31/2020

23.420

RHR Complex Heating and Ventilation, Attachment 1,

RHR Complex Heating and Ventilation Electrical Lineup

11/15/2006

23.501.01

Fire Water Suppression System

MMA08

Scaffolding

Calculations

DC-4921

Appendix R Calculations Vol. 1 Book 1 of 3

21-29684

Degraded Hardware on Door RB-6

10/31/2021

Corrective Action

Documents

21-29954

Fire Door R5-9 has a Crack in the Door Face

11/08/2021

FP-AB-2-9b

Auxiliary Building, Division I Switchgear Room, Zone 9,

EL. 6133

2/15/2021

FP-AB-5-16f

Auxiliary Building, Fifth Floor Ventilation Equipment Room,

Zone 16, Elevation 677'0"

FP-AB-BMT-4

Control Air Compressor Room, Zone 4, EL., 551'0"

FP-RB-4-17a

Reactor Building SLC System Zone 17 EL. 6596

2/15/2021

FP-RB-B-5b

Reactor Building Basement Northeast Corner Room Zone 5,

EL. 562'0"

Fire Plans

FP-RB-SB-5a

Reactor Building Sub-Basement Northeast Corner Room,

Zone 5, EL. 540'0"

71111.05

Procedures

35.000.242

Barrier Identification/Classification

Corrective Action

Documents

Resulting from

Inspection

21-31053

NRC-Concern-Test Cap for the HPCI Room Flood Level had

a Detached Loss Prevention Chain

2/15/2021

23.702.01

Plant Systems Leak Check Procedure

ARP 2D78

Reactor Building Floor/Equipment Drain Sumps Level

HI-HI/LO-LO

Procedures

EF2-PRA-012

Fermi 2 Internal Flood Analysis Notebook

2/13/2021

71111.06

Work Orders

58045750

Sump Pump "On" Light for Manhole 169470 Not Illuminated

with Alarm In

07/26/2021

71111.11A

Miscellaneous

Requalification

Program Annual

Testing Summary

Results

Licensed Operator Annual Examination Performance

Records for 2021

11/18/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

Various CARDS

Reviewed CARDS for Operations-Related Issues Which

Occurred Since the Previous 71111.11B Inspection for

PI and R to Determine How the Issues Were Dispositioned

01/20/2020

to

08/31/2021

21 Fermi

Biennial

Requalification

Written

Examination

Reviewed Entire Written Examination (30 Questions) for RO

and SRO Licensed Operators Administered During 2021

Fermi Biennial Requalification Examination

09/16/2021

CRs for Simulator

Issues - Various

Open and Closed CRS to Determine How They Were

Addressed

11/2020 to

11/2021

Instruction 1.20 -

Simulator Fidelity

B

Simulator-to-Plant Fidelity Transient Testing Checklists

NANT-21-0065

Simulator Configuration Update for 10 Change Requests

and Modifications

06/21/2021

NRC Form 396s -

Various

Reviewed Medical Records for 3 ROs and 3 SROs per

ANSI/ANS - 3.4, 1983 Standard

Operating

Examination -

JPMs Various

from 2021 Fermi

Biennial

Requalification

Exam

Reviewed 10 JPMs for Requalification Operating Exam

10/01/2021

71111.11B

Miscellaneous

Operating

Examination -

Simulator

Scenarios. Four

reviewed from

21 Biennial

Requalification

Operating Test

Simulator Scenarios from 2021 Operating Test Administered

During Week 3 of 2021 Biennial Requalification Exam

10/01/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Simulator Core

Performance

Testing - Various

Fermi 2020 Cycle 21 Core Model Testing

10/30/2013

Simulator

Malfunction Tests

- Various

Malfunction Testing as Required by ANSI/ANS-3.5-1985

06/01/2020

Simulator Review

Board (SRB)

SRB Meeting Minutes for Three Meetings Within the Past

Year

08172015

Instruction 1.16

Examination Safeguards and Controls, Revision 46

05/27/2020

Instruction 5.12,

5D,

Revision 25

LOR Grading Form - Reactor Operator. Reviewed for RO

That Passed with Remediation and Documented

Remediation Actions Taken

03/02/2021

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

Includes Program Requirements for Condition of Licenses

05/27/2021

Procedures

SM-7

Various 2020 Surveillance Tests for Safety-Related

Equipment or Systems Verifying Simulator Performance

Corrective Action

Documents

21-29630

Loss of Heater Drains During Down Power

10/28/2021

Miscellaneous

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

2/01/2021

20.107.02

Loss of Feedwater Heating

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

29.EDM.04

SFP Spray - External Strategy

71111.11Q

Procedures

MOP01

Conduct of Operations

14-20349

Received 3D57 for CW System

01/17/2014

19-25461

Design Differential Pressure Not IAW SOE19-01

07/19/2019

71111.12

Corrective Action

Documents

19-27829

RHRSW Pump C Differential Pressure Issues

10/15/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

20-20545

Pump Performance Data for SOE 19-01 Did Not Meet

Acceptance Criteria

01/16/2020

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

Documents

Resulting from

Inspection

21-22263

NRC Identified - Concern with the Ability to Evaluate

Emergency Action Level for Lowering Spent Fuel Pool Level

03/11/2021

Drawings

I-2181-01

Process Radiation Monitor Subsystems

N

Engineering

Changes

EDP 37088

Install Spent Fuel Pool Level Instrumentation to Comply with

NRC Order EA-12-051 Guidance

100033987

Commercial Grade Dedication-Temperature Gauge

100116743

Commercial Grade Dedication-Polyamide Tubing

Engineering

Evaluations

TE-R30-20-025

Loss of Flange Material on Division 1 EESW, RHRSW C,

and EDGSW Pump Column Flange Connections

Get Well Plan for CARD 14-20706

Maintenance Rule Monthly Evaluation Report - Reactor Core

Isolation Cooling

11/02/2021

System Health Report - Reactor Core Isolation Cooling

04/26/2021

Miscellaneous

CARDs/DERs by

System

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

2/16/2021

EP-542

Computer-Based Offsite Dose Assessment-Airborne

Release

MMR Appendix E

Maintenance Rule Specific SSC Functions

Procedures

MMR Appendix I

Maintenance Rule Support System Information

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SOE 19-01

IST Baseline Test for E1151C001A

Work Orders

56479097

Perform Valve Actuator Overhaul and AOV Diagnostic

Testing

2/14/2021

Corrective Action

Documents

21-27421

Requesting Investigation into Phoenix Model Showing EDG

and 14 Unavailable

08/23/2021

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

Fermi 2-MSPI Basis Document

71111.13

Miscellaneous

R30-00

Emergency Diesel Generator Design Basis Document

I

21-24863

E4150F042 Valve Slow to Open During 44.030.153

06/03/2021

21-29769

HCCI Inoperability per CARDs 21-24863 and 21-25079

11/03/2021

21-30235

21 RHR LIR Deficiency - LI-RHR-008 E1100F048A(B)

Magnesium Rotor Motor Inspections Not Performed Since

2013

11/17/2021

21-30291

Control Room Envelope Not Analyzed for Heating Steam

11/18/2021

Corrective Action

Documents

21-30493

Division 2 ESF 260/130V DC Battery Ground Detection Fault

11/25/2021

21-25079

NRC Identified: Unidentified HPCI Inoperability

06/09/2021

Corrective Action

Documents

Resulting from

Inspection

21-29970

Improper Plant Storage

11/08/2021

Drawings

6I721-2573-23

480V Ess Bus 72, Position "4A and 5A"

K

Engineering

Evaluations

TE-E41-21-034

Past Operability Evaluation for E4150F042 Delayed Stroke

Miscellaneous

T41-00

Reactor Auxiliary Building Ventilation System

E

71111.15

Procedures

MOP23

Plant Storage

Corrective Action

Documents

21-30542

Unable to Obtain As-Found Data

11/30/2021

I-2441-01

Schematic Diagram EECW Pump A

S

Drawings

I-2970-01

BOP Recording and Indicating and Controlling Instrument

Loop and Computer Inputs

C

Engineering

Changes

70341

Replacement of Division 1 EECW TCV Controller P44K800A

71111.18

Work Orders

60739425

Replacement of Division 1 EECW TCV Controller P44K800A

11/30/2021

21-28799

TR Relay Did Not Meet Pickup Acceptance Criteria

10/05/2021

71111.19

Corrective Action

Documents

21-28800

TR Relay Did Not Meet Pickup Acceptance Criteria

10/05/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

21-28839

E11-3185-G46 Sway Strut Clamp Bearing Surface Noted on

Existing Weld

10/05/2021

21-28856

TR, AR-Open, and AR-Close Relays All Failed Pickup

Acceptance Criteria

10/06/2021

21-28874

Inspections of New Pipe Restraint E11-3185-G46

10/06/2021

21-28940

B21N680C Reactor Vessel Low Water Level 3 Instrument

Failed Upscale

10/07/2021

21-28977

No I & C Personnel Qualified to Conduct Pressure Sensor

Response Time Test (Qualification Number 42001000)

10/08/2021

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

P4400F504A

2/01/2021

21-30989

SSO Tagging Delayed due to Scaffold Issues

2/14/2021

21-31030

I&C Scheduled Work Not Completed as Scheduled T-0

(Work Week 2150)

2/14/2021

21-31211

9D21 Division 1 Sequencer Trouble

2/20/2021

Corrective Action

Documents

Resulting from

Inspection

21-31229

PMT Did Not Involve Test of Sequence

2/21/2021

6M721-5444

Emergency Equipment Cooling Water Division 1

CC

Drawings

I-2714-22

H11P898A Load Sequencing Diagram

F

Engineering

Changes

80028

Division 1 Outage Tie-Ins Buried Pipe Replacement for

RHRSW and EESW Systems

B

EDG14 SSO

Fragnet for EDG 14 Safety System Outage

EFA-R16-21-001

Pickup Voltage Acceptance Criteria for CR120B GE Relays

Troubleshooting

Data Sheet

WO 62687291, CARD 21-28940, Equipment PIS B21N680C

10/08/2021

Miscellaneous

VMC1-61

Trip/Calibration System

G

23.601

Instrument Trip Sheets

2.307.05

EDG Auto Load Sequencer Timer Calibration

43.000.004

Visual Examination of Component Supports

Procedures

44.010.125

APRM 2 Channel Functional Test

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

51174031

Perform Valve Actuator Overhaul and AOV Diagnostic

Testing

11/30/2021

56479097

Perform Valve Actuator Overhaul and AOV Diagnostic

Testing

2/14/2021

295313

ECN - 80028 - Division 1 Phase 4 RF21 - Replace Existing

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

10/05/2021

2688438

B21N680C Reactor Vessel Low Water Level 3 Instrument

Failed Upscale. Troubleshoot and Repair

10/10/2021

Work Orders

63934322

Division 1 EDG Sequencer Power Supply Failures

2/21/2021

Corrective Action

Documents

Resulting from

Inspection

21-30724

NRC Identified - 29.EDM.04 Requires Amplifying Information

2/06/2021

71111.20

Miscellaneous

RF21 - Training

for Licensed

Operators

Refueling/Cold Shutdown EOPs/SAGs

2/01/2021

Corrective Action

Documents

Resulting from

Inspection

21-00255

EDG14 Standby Jacket Coolant Pump Packing Leak

2/20/2021

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

65T

N

6M721-2044

Diagram Reactor Core Isolation Cooling System

BE

Drawings

6M721-2045

Diagram Reactor Core Isolation Cooling (RCIC) System

Barometric Condenser

AT

23.307.17

EDG14 Start and Load Test

23.601

Instrument Trip Sheets

24.206.01

RCIC System Pump and Valve Operability Test

Procedures

2.302.10

Calibration and Functional Test of Division 2 4160 Volt

Bus 65F Under Voltage Relays

39A

57463038

Perform 42.302.4160 V Bus 65F (EDG 14) Division 2,

Under Voltage Circuits, C/Functional

10/27/2021

71111.22

Work Orders

57535004

Perform 24.206.1 RCIC System Pump Operability and

11/04/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

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

at 1025 PSIG

11/16/2021

57785101

Perform 44.010.206 RPS SDV High Water Level Trip SYS

A, CH A, Float Switch Functional Test

11/17/2021

Personnel Qualifications for 10 CFR 50.54Q Compliance

Reviews (Table)

06/01/2021

Miscellaneous

LP-ER-874-0001

CFR 50.54Q Compliance Reviews (Training Lesson

Plan)

Fermi 2 Radiological Emergency Response Preparedness

Plan

EP-101

Classification of Emergencies

43A

EP-590

10CFR50.54(q) Screens and Evaluation

71114.04

Procedures

QG-ER-874-0001

10CFR50.54(q) Reviewer Qualification Guide

71114.06

Miscellaneous

EP-101

Classification of Emergencies

18-27809

Personnel Contamination Event

10/04/2018

Corrective Action

Documents

21-26554

Internal Contamination While Performing Tagout D074

07/28/2021

Corrective Action

Documents

Resulting from

Inspection

21-29143

NRC Identified - 2021 RP Baseline Inspection: Inaccurate

Hot Particle Analysis

10/15/2021

Gamma Spectroscopy Report for Particle

10/04/2018

RF20 EDEX Dose Calculation

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

Luminescence Dosimeters

01/10/2014

NPRP-21-0030

Evaluation of Impact of Current Radionuclide Mix on

Radiation Protection Instrumentation

04/29/2021

Miscellaneous

NPRP-21-0050

Scaling Factor Report and Waste Stream Sample Results

08/10/2021

71124.04

Procedures

67.000.400

Personnel Contamination Event Dose Assessment

26A

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

5XLB Calibration Worksheet for SN 0506381

09/15/2021

Ion Chamber Instrument Calibration Form for Ludlum 9-3,

SN 343171

07/15/2021

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

2015

08/24/2021

SAM11 Calibration Form for SN 306

09/27/2021

Telepole Calibration Form for SN 6604-067

08/24/2021

Calibration

Records

Gamma Spectroscopy Calibration Report for Detector 2

09/16/2021

Certificate of Calibration for Source L93-0056

07/19/1993

Certificate of Calibration for Source X92-0180

08/01/1980

Miscellaneous

Certificate of Calibration for Source SN 264/88

03/03/1988

53843052

Turbine Building Vent Exhaust Monitor Calibration

09/29/2020

55852729

Circulating Water System Decant Line Radiation Monitor

Calibration

11/21/2019

71124.05

Work Orders

57752832

Channel 'B' Offgas Radiation Monitor Calibration

09/23/2020

Procedures

Offsite Dose Calculation Manual

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

(Monthly - September)

10/27/2020

57036890

Containment Purge Pre-Release Calculation

03/20/2020

71124.06

Work Orders

58789904

SPING Iodine/Particulate Sampler Flowrate Monitor

Inoperable

09/30/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

59467731

Containment Purge Pre-Release Calculation

2/09/2020

59534825

SPING Noble Gas Monitor Inoperable

09/10/2020

21-23003

Potential Math Error in SFPLI EOP (29.100.01 sh5)

04/05/2021

21-23072

Possible 50.9 Issue with SFPLI Modification

04/06/2021

21-23559

Review Recently Identified Housekeeping Conditions and

Assess Operations Performance

04/22/2021

21-23694

Typographical Error Noted in 2016-01E

04/27/2021

21-28223

Site Compliance Issues with MOP23 Plant

Storage/Housekeeping and MOP11 Fire

Protection/Transient Combustibles

09/17/2021

21-29071

Crew Learning Opportunity CTG11-1 LCO

10/12/2021

Corrective Action

Documents

21-30442

TBHVAC North and South Trains Tripped

11/23/2021

21-22263

NRC Identified Concern with the Ability to Evaluate

Emergency Action Level for Lowering Spent Fuel Pool Level

03/11/2021

21-23015

Revise EAL Training Examples with Information Regarding

Spent Fuel Pool Level Indicator

04/05/2021

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

Scaffolds Constructed >90 Days Ago

08/04/2021

21-27046

Roll-Up of NRC Issues for One Task (D074)

08/10/2021

Corrective Action

Documents

Resulting from

Inspection

21-28794

Staged Items in the Reactor Building

10/04/2021

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

Distribution - Division 2

AS

Drawings

6SD721-2531-13

Internal Wiring Diagram 130 V ESF Battery Charger

M

Engineering

Changes

EDP 37088

Spent Fuel Pool Instrumentation Project Engineering Design

Plan

Night Order for SFP Level Indicator and EAL RS2.1

21Q3

Operations Continuous Learning Report

09/30/2021

71152

Miscellaneous

21-23072

Possible 50.9 Issue with SFPLI Modification (Root Cause

Analysis)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

21-27388

Equipment Cause Evaluation for 21-27388 HPCI and

Division 2 EDG Sequencer Power Failure

10/06/2021

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

Charging System

11/08/2021

NRC-14-005

License Amendment Request to Revise the Emergency

Action Level Scheme for the Fermi 2 Emergency Plan

10/21/2014

EP-101

Classification of Emergencies

EP-101

Classification of Emergencies

43A

Procedures

EP-101

Classification of Emergencies

44