IR 05000341/2023002
| ML23215A194 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/04/2023 |
| From: | Karla Stoedter NRC/RGN-III/DORS/RPB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| EA-23-0067 | |
| Download: ML23215A194 (1) | |
Text
SUBJECT:
FERMI POWER PLANT, UNIT 2-INTEGRATED INSPECTION REPORT 05000341/2023002
Dear Peter Dietrich:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On July 25, 2023, 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. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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 or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.
August 4, 2023 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, Karla K. Stoedter, Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000341 License No. NPF43
Enclosure:
As stated
Inspection Report
Docket Number:
05000341
License Number:
Report Number:
Enterprise Identifier:
I2023002-0054
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
April 01, 2023 to June 30, 2023
Inspectors:
J. Gewargis, Resident Inspector
R. Ng, Senior Project Engineer
J. Reed, Health Physicist
T. Taylor, Senior Resident Inspector
Approved By:
Karla K. Stoedter, Chief
Reactor Projects Branch 2
Division of Operating Reactor Safety
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
Inoperable Diesel Fire Pump due to Clogged Cooling Water Strainers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202300202 Open/Closed
[H.1] -
Resources 71111.15 A self-revealed finding of very low safety significance (Green) occurred due to the licensee's failure to follow Procedure MES51, "Preventive Maintenance Program," when changing the general service water (GSW) intake cleaning frequency from twice per year to once per year.
Specifically, the licensee did not provide a technical justification for the change and did not address internal operating experience which supported a twice per year cleaning frequency.
The reduction in cleaning frequencies led to the accumulation of debris in the intake and resulted in operators declaring the diesel fire pump (DFP) inoperable immediately following routine testing on February 27 and March 7, 2023, due to concerns about sufficient cooling water flow to the engine.
Failure to Implement Fire Barrier Inspections in Accordance with Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300203 Open/Closed
[H.5] - Work Management 71152A On April 26, 2023, the NRC inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation (NCV) of Fermi Operating License Condition 2.C.(9) when the licensee failed to perform fire barrier inspections in accordance with their fire protection program. Specifically, the licensee failed to perform fire barrier inspections per the frequencies described in the Technical Requirements Manual (TRM).
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000341/202300201 Review of Increasing Differential Pressures on the Division 1 Emergency Equipment Service Water/Emergency Equipment Cooling Water Heat Exchangers 71111.07A Open
PLANT STATUS
Unit 2 began the inspection period at or near 100 percent power. On April 28, 2023, a planned down power to approximately 91 percent was completed for routine testing. The plant returned to 100 percent power on April 29, 2023. The plant performed a down power to approximately 91 percent power on May 4, 2023, for routine testing. The plant returned to 100 percent power later that day. On June 9, 2023, the plant commenced a planned down power to approximately 70 percent power for planned maintenance and surveillances. The plant was returned to 100 percent power on June 10, 2023. The plant remained at or near 100 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, observed risk significant activities, and completed onsite 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
71111.04 - 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 1 emergency diesel generator (EDG) ventilation system, completed the week ending April 22, 2023
- (2) Reactor core isolation cooling (RCIC) during high pressure coolant injection (HPCI)work during the week ending May 20, 2023
- (3) Division 1 ultimate heat sink components during emergent work on the 'D' mechanical draft cooling tower (MDCT), completed the week ending June 30, 2023
- (4) Reactor building airlock doors and secondary containment during the week ending June 30, 2023
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the HPCI system, which concluded the week ending April 20, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 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) Auxiliary building 4, heating ventilation and cooling (HVAC), and testability on May 29, 2023
- (2) Auxiliary building 5, Division 1 and 2 control center (CC)HVAC, main control room computer room, and reactor building 2 (door gap failures) during the week ending June 30, 2023
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the: "Troom" (auxiliary building basement pipe tunnel)
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Partial)
The inspectors evaluated readiness and performance of:
(1)
(Partial)
The division 1 emergency equipment service water (EESW) emergency equipment cooling water (EECW) heat exchangers during an emergent issue involving unexpectedly high differential pressure. The sample will continue into the third quarter and is discussed in the unresolved item documented within this report.
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 down power to approximately 91 percent for routine testing following resolution of feedwater heater level control issues on May 4, 2023
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated the May 10, 2023, licensed operator requalification scenario: reactor water cleanup leak into the reactor building followed by anticipated transient without scram and flooding emergency operating procedure contingencies during the week ending May 13, 2023
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 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) Control air compressor issues during the week ending May 5, 2023
- (2) Direct current (DC) distribution during the week ending April 14, 2023
- (3) Turbine building crane inspection issues (extent of condition concerns to reactor building crane, heavy lifts) during the week ending May 20, 2023
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 the storage locations for safety-related parts, during the week ending May 27, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Troubleshooting level control issues in the south reheater seal tank during the week ending April 22, 2023
- (2) Condensate storage tank diving during the week ending April 22, 2023
- (3) Review of repair plans for a packing leak on E4150F003, the HPCI outboard steam supply containment isolation valve, completed the week of June 30, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) HPCI outboard steam isolation valve primary containment isolation valve (PCIV)packing steam leak in both the open and closed position during the week ending June 17, 2023
- (2) Standby gas treatment system breaker 72F3A past operability due to delayed closure during the week ending June 30, 2023
- (3) Diesel fire pump strainer issues during the week ending June 30, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (8 Samples)
- (1) Division 1 residual heat removal service water heat exchanger (HX) inlet valve inspection and stem replacement during the week ending April 15, 2023
- (2) Division 2 standby gas treatment system calibration, fan inspection, PMT run, and breaker 72F3A slow to close during the week ending April 26, 2023
- (3) Planned EDG 11 safety system outage and post-maintenance automatic fast start during the week ending May 5, 2023
- (4) HPCI planned safety system outage the week of May 15, 2023
- (5) Replacement of the Division 1 EESW minimum flow control valve, completed the week ending June 3, 2023
- (6) Review of the post-maintenance testing performed for main steam drain containment isolation valve B2103F019 following actuator yoke separation, completed the week ending June 17, 2023
- (7) HPCI outboard steam supply containment isolation valve packing ring addition and post ring addition cycling during the week ending June 17, 2023
- (8) Replacement of 'D' MDCT fan trip vibration sensor and post replacement run following failure during the week ending June 17, 2023
Surveillance Testing (IP Section 03.01) (4 Samples)
- (1) Operability test of 480V swing bus 72CF automatic throw over scheme during the week ending April 22, 2023
- (2) Main steam flow line 'B' calibration functional during the week ending April 22, 2023
- (3) EDG ECCS emergency start circuits and auto surveillance test during the week ending April 29, 2023
- (4) Standby feedwater pump 'A' pump and valve operability test during the week ending June 30, 2023
Inservice Testing (IST) (IP Section 03.01) (2 Samples)
- (1) Division 1 low pressure coolant injection pump and valve surveillance during the week ending April 15, 2023
- (2) RCIC pump and valve surveillance during the week ending May 13,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (8 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Portable ion chambers in the radiation protection instrument calibration facility
- (2) Portable neutron radiation instruments in the radiation protection instrument calibration facility
- (3) Portable friskers in the radiation protection counting room
- (4) Tool and equipment monitors at the primary radiologically controlled area exit
- (5) Whole-body contamination monitors at the primary radiologically controlled area exit
- (6) Portal monitor at the guardhouse exit
- (7) High range dose rate meters in the radiation protection instrument calibration facility
- (8) Particulate, iodine, and noble gas monitor in the reactor building
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Telepole, S/N: 6608026
- (2) SAM11, S/N 308
- (3) Atlantech standup whole-body counter
- (4) PCM1B, S/N 415
- (5) Ludlum 177, S/N 81051
- (6) Ludlum 2000, S/N 251372
- (7) RADeCo HD28, S/N 1967
- (8) Canberra GEM5, S/N 0612072
- (9) Canberra ARGOS5ABZ, S/N 1611257
- (10) Box calibrator BX3, S/N 10133814
- (11) AMS4, S/N 1400
- (12) F&J L12P, S/N 309
- (13) AMP200, S/N 7716019 with probe S/N 7716019
- (14) E520, S/N 4842 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Division 2 containment area high range radiation monitor
- (2) Reactor building exhaust plenum process radiation monitor
OTHER ACTIVITIES-BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 2 (April 1, 2022 through March 31, 2023)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) Unit 2 (April 1, 2022 through March 31, 2023)
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) Unit 2 (April 1, 2022 through March 31, 2023)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Selective review of the licensee's preventative maintenance and surveillance scheduling process, completed the week ending June 17, 2023
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
The inspectors performed a review over the (nominal) six-month period starting January 2023 for potentially adverse trends.
- (1) The inspectors reviewed Management Review Meeting (MRM) functional area performance indicators for maintenance, engineering, and operations departments for the first two quarters of 2023. Additionally, the inspectors reviewed currently open Nuclear Quality Assurance (NQA) department issues (areas of concern, elevations, escalations, and findings) and compared the results to items opened from 2020 through 2022. Further, numbers of corrective action program (CAP) documents opened by NQA were also compared to prior years. No noticeable difference was identified in either area. The inspectors also reviewed corresponding site procedures regarding the collection and review of MRM and NQA data. No issue of significance was identified.
71153 - Follow-Up of Events and Notices of Enforcement Discretion Notice of Enforcement Discretion (NOED) (IP Section 03.04)
- (1) The inspectors evaluated the licensee actions surrounding Notice of Enforcement Discretion EA230067 which can be accessed at http://www.nrc.gov/reading-rm/doc-collections/enforcement/notices/noedreactor.html, during the week ending June 3, 2023. Inspectors performed walkdowns of plant systems that were to be protected as a compensatory measure during the period of enforcement discretion with no issues of concern.
INSPECTION RESULTS
Unresolved Item (Open)
Review of Increasing Differential Pressures on the Division 1 Emergency Equipment Service Water/Emergency Equipment Cooling Water Heat Exchangers URI 05000341/202300201 71111.07A
Description:
On May 31, 2023, while performing a routine surveillance of the Division 1 emergency equipment service water (EESW) system, the licensee noted the measured differential pressure (dP) across the 'A' EESW/ emergency equipment cooling water (EECW) heat exchanger (HX) (on the EESW side) was higher than both the maintenance limit and the established operability limit. The measured dP was 10.55 psid, while the operability limit was 10.18 psid. Both divisions of EESW have two HXs, only one of which is lined up at a time and is capable of performing all safety-related functions of the system. The HXs are of the plate-and-frame style. Given the measured dP, the licensee declared division 1 of the EESW system inoperable and entered Technical Specification limiting condition of operations (LCO)action statement 3.7.2.B.1, which required the system to be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If it was not restored to operable in that time frame, Technical Specification actions to shut the plant down would be entered. The other EESW HX ('C') on the division 1 side had exceeded the maintenance limit in December of 2022 and had not yet been cleaned, so it was not immediately available for service. Additionally, the licensee had concerns about placing the 'C' HX in service pending an understanding of what unexpectedly drove the dP up on the 'A' HX.
As part of the investigation, the licensee placed the 'C' HX in service for troubleshooting and trended the dP across the HX while inspecting and cleaning the 'A' HX. Small pieces of rust-like ferrous material were observed inside the 'A' HX and were believed to be the cause of the high dP. The 'A' HX was cleaned and reassembled. 'C' HX dP continued to trend upward, exceeding 14 psid while appearing to level out. During the maintenance efforts to clean and restore the 'A' HX, the licensee requested a Notice of Enforcement Discretion (NOED) from the NRC in order to complete the maintenance activities and perform testing to demonstrate operability on a timeline that could exceed the required action time of LCO action statement 3.7.2.B.1. The NOED was granted by the NRC. Documents associated with the NOED can be found in ADAMS (ML23157A026 and ML23158A133). Following approval of the NOED, the licensee tested the 'A' EESW HX, which had a measured dP less than both the maintenance and operability limits with a stable trend. The licensee declared the system operable prior to expiration of LCO action 3.7.2.B.1 and completed cleaning and inspection of the 'C' EESW HX.
Potential causes discussed with the NRC as part of the NOED process centered mainly around a potential phenomenon associated with new underground EESW piping that was installed on division 1 during the spring 2022 refueling outage, the method with which the HXs were placed/remained in standby during normal operations, and issues with the reservoir (the ultimate heat sink) from which the EESW pumps draw suction. As of the publishing of this inspection report, the licensee tested one of the Division 2 HXs with satisfactory results.
Testing of the 'C' HX following its eventual cleaning and reassembly also revealed satisfactory results. The licensee developed an adverse condition monitoring plan to formally trend the performance of the division 1 EESW HX's and commenced a root cause evaluation.
Further NRC inspection is required to ascertain if a performance deficiency exists associated with the unexpected performance of the division 1 EESW HXs, as described above. The inspectors will review any corrective action documents, and will continue to perform independent inspection under baseline inspection procedure 71111.07A, Heat Exchanger/Sink Performance. The inspection sample was commenced when issues first arose with the 'A' EESW HX and will continue until the NRC determines whether a performance deficiency and/or violation of NRC requirement occurred.
Planned Closure Actions: The NRC will continue to assess the licensee's potential causes and evaluate the licensee's review of this issue. If a performance deficiency is identified, an assessment would then be made to determine if it is more-than-minor and whether a violation exists/existed.
Licensee Actions: The licensee cleaned and tested both the 'A' and 'C' Division 1 EESW/EECW HXs and instituted a formal monitoring plan to trend performance. Further, the
'D' HX on division 2 was tested satisfactorily. The licensee plans to complete a root cause evaluation of this issue.
Corrective Action References: CARD 2330619 Inoperable Diesel Fire Pump due to Clogged Cooling Water Strainers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202300202 Open/Closed
[H.1] -
Resources 71111.15 A self-revealed finding of very low safety significance (Green) occurred due to the licensee's failure to follow Procedure MES51, "Preventive Maintenance Program," when changing the general service water (GSW) intake cleaning frequency from twice per year to once per year.
Specifically, the licensee did not provide a technical justification for the change and did not address internal operating experience which supported a twice per year cleaning frequency.
The reduction in cleaning frequencies led to the accumulation of debris in the intake and resulted in operators declaring the diesel fire pump (DFP) inoperable immediately following routine testing on February 27 and March 7, 2023, due to concerns about sufficient cooling water flow to the engine.
Description:
The licensee installed a new DFP in December of 2022. A small diameter pipe exists on the discharge of the pump to deliver cooling water to the diesel engine. The water runs through two sets of strainers before reaching the jacket cooling water heat exchanger. The first set is a duplex strainer which allows the operators to swap between the strainers while the pump is running. The second set consists of two relatively smaller Yshaped strainers in parallel lines, each with a pressure control valve. The minimum required pressure for raw water to the heat exchanger was 10 psig. Following post-modification testing, the pump ran successfully during weekly and monthly surveillances through February 20, 2023.
On February 27, the DFP was declared inoperable following a weekly test. Five minutes into the February 27th run, raw water pressure was 9 psig. The duplex strainers were shifted, which temporarily raised pressure above the minimum. However, pressure dropped back to near the minimum required pressure approximately 15 minutes into the run. The duplex strainer was shifted again, but the strainer differential pressure pegged high shortly thereafter. Pressure to the heat exchanger was noted to be at 6 psig as the surveillance was completed. While engine temperatures remained within normal bands, the licensee declared the DFP inoperable due to concerns with strainer performance.
In addition to cleaning/replacing the strainers, divers inspected the DFP suction within the GSW pump structure. Lake debris (namely silt and biological matter) was found near the pump suction to a depth of approximately 1216 inches. The licensee described this as an abnormally high amount compared to previous routine diving inspections. The east side (DFP suction) of the intake structure was cleaned. Cleaning of the west side (electric fire pump suction) was postponed due to incoming weather. The DFP was tested and restored to service. On March 7, the DFP was run for a weekly surveillance test. Again, issues with raw water pressure and duplex strainer differential pressure were experienced. The DFP was shut down prior to completion of the surveillance and declared inoperable. Both east and west sides of the intake were cleaned by divers, and the DFP was restored prior to expiration of the 14-day action time in the Technical Requirements Manual (TRM).
Subsequent investigation by the licensee concluded a change in frequency for cleaning and inspecting the GSW intake structure was the cause of the strainer issues. Since 2011, the GSW intake structure was being cleaned twice a year due to observed increases in silt and sediment attributed to ongoing erosion of the GSW jetty-a break-wall-like protrusion from the shore out into the lake. Issues noted in the corrective action program from 2009 thru 2011 that supported an increase in the cleaning frequency at the time included damage to the electric fire pump suction strainer and a negative trend in DFP raw water-cooling strainer outlet pressure. A fully intact jetty would allow debris to settle-out in the canal it formed prior to reaching the intake structure in amounts that could threaten pump operation. While some work had been performed in restoring the jetty in recent years (but not completed because the project was postponed), a decision was made in 2022 to change the preventive maintenance (PM) frequency for cleaning the intake back to once per year. The strainer issues described here occurred approximately one year after the decision.
The licensee uses procedure MES51, "Preventative Maintenance Program," to change the frequency of PM activities. Step 5.2.1.4 requires the PM Change Request Form, MES51001, to be filled out. The inspectors reviewed the PM change documentation for revising the intake cleaning frequency and found no technical information was used to support the decision. In addition, a documented consideration of internal operating experience (OE) was not completed. Specifically, the justification section for the new PM frequency was left blank
("N/A"). Per the form, "N/A" indicates the justification has not changed, yet the original justification listed several OE items that indicated a 184-day frequency was needed vice a 366-day frequency. Further in the Section (5.2.2.4.c), 29 different sources of information are listed for consideration when establishing PM frequencies, but none were referenced in the justification Section. Additionally, under the "Consequences of a Failure" section of the PM change form, the fire pumps were not considered in the assessment.
The inspectors reviewed the licensee's evaluations regarding the past operability of both fire pumps and considered weather events that occurred, test lineups used, and cleaning activities that occurred the first few months of 2023. The inspectors determined only the DFP was impacted following storms that occurred shortly before each of the weekly surveillances left the DFP inoperable. The licensee has since documented a corrective action in the CAP to reinstitute cleaning of the intake structure twice per year.
Corrective Actions: The licensee cleaned the fire pump suction area of lake debris and completed an equipment cause evaluation. A corrective action exists to increase the frequency of cleaning the GSW intake structure back to twice a year.
Corrective Action References: CARD 2321607
Performance Assessment:
Performance Deficiency: The licensee did not follow procedure MES51 when changing the frequency of PM activities D259 and P246, which are associated with cleaning the GSW intake structure.
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, when changing the PM frequency, the licensee did not provide a basis for why the change was acceptable. As a result, debris accumulated which clogged the DFP raw water (engine) cooling strainers to the point that the DFP was considered inoperable on two occasions.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Specifically, under the fire water supply category, the inspectors determined the issue was of low degradation. Per attachment 2, high degradation would imply a loss of system function, which did not exist due to the electric fire pump being operable while the DFP was inoperable.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the equipment cause evaluation cited a business decision to enhance financial savings was involved in the PM frequency change.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Implement Fire Barrier Inspections in Accordance with Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300203 Open/Closed
[H.5] - Work Management 71152A On April 26, 2023, the NRC inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation (NCV) of Fermi Operating License Condition 2.C.(9) when the licensee failed to perform fire barrier inspections in accordance with their fire protection program. Specifically, the licensee failed to perform fire barrier inspections per the frequencies described in the Technical Requirements Manual (TRM).
Description:
On February 20, 2023, the NRC triennial fire protection inspection team requested copies of inspections performed on cable trays in the control air compressor room. While gathering the documents, the licensee discovered the inspections had only been partially completed in accordance with the implementing procedure, 28.507.01, "Fire Barrier Inspections." This procedure implements TRM Surveillance Requirements (TRSRs) 3.12.8.5, 3.12.4.3, and 3.12.5.3. These TRSRs direct the visual inspection of exposed fire rated assemblies, inspects hatches/floor plugs and verifies actuation of doors and ventilation dampers in support of the carbon dioxide (CO2) system, and verifies actuation of doors and ventilation dampers in support of the halon system, respectively. These TRSRs, along with certain preventative maintenance and other recurring activities, are scheduled via an administrative process that uses labels to track the various activities. The activity tracking completion of these TRSRs is FP37, "Perform 28.507.01 Fire Barrier Inspection (Mode 1, 2, 3)- License Renewal." In response to the NRC team's question, the licensee realized some surveillances were complete, and several surveillances were scheduled beyond their critical dates. The licensee only became aware of this gap due to questions by the NRC inspectors. The licensee entered this issue into the corrective action program (CAP) as CARD 2321419 to ensure remaining surveillances were properly rescheduled and to verify what had actually been completed.
On April 21, 2023, the resident inspectors questioned the status of activity FP37 while performing an indepth problem identification and resolution sample. It appeared that the critical date for some of the surveillances had passed with no record of them having been completed. While responding to the inspectors questions, the licensee discovered several surveillances had not been completed before the critical date (the due date with an additional 25 percent grace period applied) had elapsed. In response, the licensee issued CARD 2323106, NRC Identified - FP37, "Perform 28.507.01 Fire Barrier Inspection (Mode 1, 2, 3) - License Renewal," and implemented TRSR 3.0.3 which allowed them to delay considering the affected fire barriers non-functional after completing a risk evaluation (for delays greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). The initial investigation results documented in CARD 2323106 revealed actions created in CARD 2321419, to ensure TRSRs were completed on time, had not been performed. The licensee performed a review to determine which areas from 28.507.01 were complete and which were still outstanding. The licensee determined the critical dates for TRSR 3.12.8.5, which inspects the fire rated assemblies overall, and 3.12.4.3, which ensures the fire barriers needed for the CO2 system to perform its function, had been missed.
Corrective Actions: The licensee entered the issue into the CAP and performed the required evaluations per TRSR 3.0.3 to support continued functionality of equipment pending completion of the missed surveillances.
Corrective Action References: CARDs 2323106 and 2321419
Performance Assessment:
Performance Deficiency: The licensee failed to implement procedure 28.507.01, "Fire Barrier Inspections," which directs TRSRs 3.12.8.5 to be completed every 24 months, and TRSRs 3.12.4.3 and 3.12.5.3 to be completed every 18 months.
Screening: The inspectors determined the performance deficiency was more-than-minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Absent NRC intervention, the failure to recognize fire barrier surveillances had not been completed (nor scheduled properly) per the fire protection program could lead to a situation where barriers could degrade and not be detected. Fire barriers are credited to ensure the plant can be safely shutdown in the event of fires. The licensee failed to complete required TRM surveillances within the required frequency, to include a 25 percent grace period. The surveillance was completed in full only when questions were raised by the NRC inspectors as a follow-up to CARD 2321419. The inspectors utilized IMC 0612, Appendix E, "Examples of Minor Issues," Example 11.b, to inform their decision, since the more-than-minor example includes a situation involving activities performed greater than 25 percent beyond the required frequency. Further, when the licensee performed the remaining walkdowns, conditions were discovered that were entered into the CAP for disposition.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding screened as having very low safety significance (Green) because Step 1.3 "Low Degradation Deficiencies," was answered Yes. Specifically, the "Fire Confinement and Localized Cable or Component Protection" section of attachment 2 provides categories of high or low degradation for passive materials and components. Licensee walkdowns following identification of the issue revealed some signs of degradation. However, when evaluated, the barriers were determined to remain functional. Therefore, the affected components fell into the low degradation category.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Throughout the first two quarters of 2023, the inspectors noted several examples of weaknesses in the work management process (mostly identified by the licensee). Many involved instances where activities such as FP37 were improperly scheduled, such as two examples involving components in the inservice testing program.
Enforcement:
Violation: Fermi Operating License Condition 2.C.(9) requires, in part, the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report.
Updated Final Safety Analysis Report Appendix B, Section 1.18, describes required visual inspections that are part of the fire protection program. Specifically, Section 1.18 states, in part, the CO2 system and fire rated assemblies are required to be inspected in accordance with the TRM.
TRM Surveillance Requirement 3.12.8.5 requires fire rated assemblies to be inspected at a frequency of once every 24 months.
TRM Surveillance Requirement 3.12.4.3 requires components associated with the CO2 system to be inspected every 18 months.
Contrary to the above, from July 28, 2022, to April 26, 2023, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report. Specifically, the CO2 system and fire rated assemblies were not inspected in accordance with the TRM. TRM Surveillance Requirement 3.12.8.5 was required to be completed by March 20, 2023, but was not completed until April 26, 2023. Additionally, TRSR 3.12.4.3 was required to be completed by August 4, 2022, but was not completed until April 26, 2023.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 25, 2023, the inspectors presented the integrated inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer, and other members of the licensee staff.
On May 19, 2023, the inspectors presented the Radiation Protection inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
22652
EDG 12 Switchgear Outdoor Air Damper, X4103F115
04/05/2023
6I7212221-05
Schematic Diagram HPCI System-Pump Discharge Isolation
Valve E4150F006 and F007
6M7212035
HPCI Reactor Building
BQ
6M7212043
Diagram HPCI System Barometric Condenser Reactor
Building
AJ
6M7212044
RCIC System
BE
6M7212045
RCIC System Barometric Condenser
AT
6M7215708-1
HPCI System Functional Operating Sketch
6M7215708-2
HPCI Turbine Lube Oil/Control Oil Functional Operating
Sketch
L
MN2052
RHR Service Water System Division 1
Drawings
MN2057
P & ID Diesel Generator Ventilation RHR Complex Division 1
23.202
HPCI System
119
23.420
RHR Complex Heating and Ventilation
Procedures
23.428
Secondary Containment Airlocks and Penetrations
2330448
Work Order Request for Fire Door Gap Gauges
05/23/2023
2330541
Fire Extinguisher Tracking
05/26/2023
2331034
Door R45 Failed Acceptance Criteria of 28.507.02
06/20/2023
2331076
Door R511 Failed Acceptance Criteria of 28.507.02
06/22/2023
2331113
Door R28 (RB2 Airlock) Acceptance Criteria Not Met for
28.507.02
06/23/2023
2331126
NQA-Expired Fire Extinguisher Yearly Service Tags
06/23/2023
2331182
TRM Door Failures
06/26/2023
Corrective Action
Documents
20743
Revise Fire Door Surveillance Procedure 28.507.02
01/27/2023
28.502.02
Fire Extinguisher Yearly Maintenance Inspection
28.507.02
Fire Door Surveillance Test
Procedures
FPAB416c
Auxiliary Building Ventilation Equipment Room Zone
Calculations
DC5426
PBOC-High and Moderate Energy Line Beak Evaluation
08/14/2015
Corrective Action
24957
Floor Drains Overflowed from Pumping Down Sump DO74
07/27/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
20544
Floor Drains do Not Flow Properly
01/20/2023
Corrective Action
Documents
Resulting from
Inspection
23235
NRC Concern Regarding Disposition of CARD 2320544
05/01/2023
6M7212223
Equipment Drains All Floors Auxiliary and Reactor Buildings
Y
6M7212224
Floor Drains All Floors Auxiliary and Reactor Buildings
Drawings
6M7215710-2
Sump Pumps System Functional Operating Sketch
Miscellaneous
EF2PRA012
Fermi 2 Internal Flood Analysis Notebook
20176
Increasing Trend Division 2 EECW Heat Exchanger DP
01/06/2012
22181
Increasing Trend Division 1 EECW Heat Exchanger DP
03/22/2012
27521
Unexpected Increase in Division 1 EECW Heat Exchanger
Differential Pressure After Recent Swap
10/03/2019
2330880
Request Work Order to Trend DP on EECW Heat Exchangers
06/13/2023
2331002
Division 1 EECW Heat Exchanger Swap and Partial
Surveillance Not Completed as Scheduled
06/20/2023
Corrective Action
Documents
231651
Performing 24.308.02 P4400B001C EECW Backup HX DP is
Greater than Maintenance Limit and Less than Operability
Limit
2/08/2022
2.000.03
Power Operation 25% to 100% to 25%
107
24.110.05
RPS-Turbine Control and Stop Valve Functional Test
Procedures
SSOP2022271
Licensed Operator Training Simulator Lesson Plan
21480
Division 2 Control Air Compressor Will Not Load
2/11/2020
26271
Findings from Division 1 NIAS Air Dryer Troubleshooting WO
05/29/2020
28926
Secondary Containment Isolation
08/03/2020
2330611
Request for ReInvestigation of Storage Location of New
Transformers
05/31/2023
2330893
Functional Area MRM's not Completed in Maintenance in
Accordance with FBP111
06/13/2023
2331040
Evaluate License Amendment Req Implementation Process
06/21/2023
2331177
OE Reviews Not Timely
06/29/2023
Corrective Action
Documents
2331201
Determine if More Robust Actions are Required to Prevent
Recurrence of OE20230127 Here at Fermi
06/29/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2331208
23 PI&R FSA - Vertical Slice Identified Gaps in
Performance Improvement Activities Associated with
Surveillance Tracking and Monitoring Issues within O&WM
06/28/2023
2331212
Recent Lack of Engagement in OE Review Committee
(OERC)-Maintenance
06/29/2023
2331214
Lack of Engagement in OE Review Committee
(OERC) -O&WM
06/29/2023
27395
130V Battery Charger 2B2 Low Voltage
08/23/2021
20333
Schedule Challenge HPCI SSO
01/12/2023
21006
Preliminary Industry OE from Farley Scram due to Turbine
Trip
2/06/2023
21156
Recommend Revision to 35.622.003
2/10/2023
21413
NQA Concern-Lack of Procedure Guidance for Control of QA
Level 1 Material Offsite Once Issued per the Work Control
Process
2/20/2023
21511
Positive CLO Ops Shift 3-Unexpected Valve Closures during
24.129.04
2/22/2023
21522
NQA-Vendor, National Compressor, Failed to Perform
commercial Grade Dedication Requirements for Joy
Manufactured Control Air Compressor Discharge Valves,
Potentially Impacting 7Day LCO
2/22/2023
21527
Division 2 Air Compressor Not Loading Trouble
Shooting-Synergy Data Acquisition Leads Incorrectly
Connected
2/23/2023
21578
Issues with TB Crane Inspection Procedure 35.716.003
2/24/2023
21580
Issue with Alignment of Crane Rails
2/24/2023
22164
Rounds Operators Supporting Fire Protection Work due to
Minimum Manning
03/17/2023
23249
NQA-Unsatisfactory ASME Pressure Retaining Parts
Inspection due to Non-ASME Valve Installed in ASME Class C
Location per Work Order 50432973
05/02/2023
23259
R3000F025A Valve Stem Broke, Valve Stuck Shut
05/02/2023
6M7212015
Diagram Station and Control Air
CU
Drawings
6M7215730-3
Non-Interruptible Control Air System Division 1 and 2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Functional Operating Sketch
EED20383
XFMRs Were Stored at the MAG Barn Outside of
Fermi/WHSE Control, PEG to Evaluate if Acceptable or Not
Engineering
Evaluations
EFA-R1621-001
Pick-Up Voltage Acceptance Criteria for CR120B GE Relays
70382
Replace R3000f025A 3/4" OS&Y Globe Valve with a Full
Ported 3/4" Ball Valve
A
B30.22022
Overhead and Gantry Cranes
22
R3200
R3200 Tracking Group Basis Document
01/18/2022
R3200 (a)(1) Get
Well Plan
R3200 (a)(1) Get Well Plan
06/14/2022
Miscellaneous
VMC72
Dryer, Decade III Heat-Les [Confidential]
C
35.716.003
Turbine Building Cranes Frequent and Periodic Inspection
35.717.003
Reactor Building Crane-Frequent and Periodic Inspection
14A
Procedures
MQA14
NQA Oversight Activities
53341758
TB North Overhead Crane Periodic Inspection
2/01/2021
58580779
License Renewal-TB South Overhead Crane Periodic
Inspection
11/29/2022
228923
License Renewal - RB Overhead Crane PM Inspections
2/12/2022
Work Orders
67495146
License Renewal Replace Suction and Discharge Valves with
New or Refurbished Valves
01/24/2023
Corrective Action
Documents
2031438
Material Found at Bottom of Condensate Storage Tank
10/20/2020
230006
Design Change Package: E4150F003 Steam Leak Deflector
Plate
6M7212006
Condensate Storage and Transfer System Diagram
BJ
6M7212081
Diagram Control Rod Drive Hydraulic System Reactor Building
Part 1 of 2
AX
M2005
Feedwater Heater Drains, Emergency Drains, and Heater Air
Vents System
BL
M20051
Feedwater Heater Drains Emergency Drains and Heater Air
Vents System
Drawings
M57011
Nuclear Boiler System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
M57081
HPCI System
Dive Operations and Safety Plan - Fermi 2 CST Cleaning
Plan of the Day-Sunday, April 16, 2023
04/16/2023
Clearance: P1100000145
04/18/2023
CST Cleaning and Inspection
E4100000298
Clearance for HPCI Steam Supply Outboard Isolation Valve
E4150F003
06/09/2023
Risk Management
Plan
MMA26 / South Reheater Seal Tank High Level
04/03/2023
Miscellaneous
Troubleshooting
Datasheet
22509, 2322527
05/29/2019
23.108
Extraction Steam and Heater Drains
Procedures
ODE20
Protected Equipment
58991232
Remove FME Debris from Bottom of CST
10/20/2020
Work Orders
68515723
Manually Back Seat E4150F003 and add Packing Rings
06/10/2023
DC6132 VOL I
Analysis of Loss of Coolant Accident (LOCA) using Alternative
Source Terms
C
Calculations
DC6132 VOL II
Analysis of LOCA using the Alternative Source Term
Methodology
29388
Electric Fire Pump Suction Strainer is Collapsed, Repeat Issue
10/17/2011
23596
CARD 1321913 Closed Without Performing Requested
Evaluations
05/17/2013
2330359
E4150F003 Packing Leak
05/19/2023
2330388
Evaluate Back-Seating E4150F003 HPCI Turbine STM Supply
05/21/2023
2330511
DSW Intake Water Depth Concern
05/26/2023
2331136
Failed EQRT on Equipment Cause Evaluation for CARD
23081
06/26/2023
231235
Valve Packing Has a Small Wisp While Valve is Open
11/18/2022
21232
Breaker Position 72F3A Greased with Anderol are Passed
Industry Life of Anderol and Need to be Prioritized for
Refurbishment
2/14/2023
Corrective Action
Documents
21607
Primary and Alternate Raw Water Strainers are Below the
2/27/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Required Psig
21607
Diesel Fire Pump Primary and Alternate Raw Water Strainers
are below the Required Psig
2/07/2023
21609
Evaluate if DFP Meets the Required 8Hour Run Time with
Strainers Issue
2/07/2023
21765
Recommend Improvement to Diesel Fire Pump Raw Water
Strainer Design
03/02/2023
21865
Duplex Strainers Swapped Multiple Times during DFP Run
03/07/2023
21895
Damaged Diesel Fire Pump Jacket Coolant Strainer Screen
03/08/2023
21955
DFP Jacket Cooler Inlet Strainers Need Cleaned
03/10/2023
21956
DCR: 28.504.07 Acceptance Criteria Not Marked in Body,
Request Y Strainer Pressure Evaluation for Acceptance
Criteria
03/10/2023
21976
Damage Strainer Screen
03/10/2023
22019
DFP Jacket Coolant Strainer Needs Cleaning
03/13/2023
22028
EDP 80165 Replacement Diesel Fire Pump FCR
03/13/2023
23081
2F3A Delayed Closure
04/26/2023
Corrective Action
Documents
Resulting from
Inspection
2330551
NRC Identified-Details in USFAR Table 6.22 for Penetration
X11, "Steam to HPCI"
05/26/2023
6M7212135
Fire Protection System (Sheet 1)
Drawings
6M7212135-1
Fire Protection System (Sheet 2)
BN
Miscellaneous
Archived Operator Log from 10/01/2022 to 03/13/2023
Operability
Evaluations
EFA-E4123-001
E4150F003 Packing Leak Impact on PCIV Function
05/26/2023
Procedures
28.504.07
Diesel Fire Pump Engine Monthly Operability Test
Calibration
Records
E41NA01S
HPCI Auxiliary Oil Pump Start/Stop Pressure Switch
09/24/2015
22110
Scoring in Threaded Portion of Valve Stem
03/19/2019
2330190
Brass Shaving Found Around Stem
05/15/2023
2330244
Oil Leak Observed on Remote Servo
05/15/2023
Corrective Action
Documents
2330283
AsFound Testing and Inspection Results - E4150F004
05/18/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2330284
E4100F029 Strokes Closed Quicker than IST Limits
05/18/2023
2330296
HPCI SSO Steam was Being Directed to a Floor Drain without
Providing Local Radiological Air Sampling for the activity
05/17/2023
2330296
HPCI SSO Steam was Being Directed to a Floor Drain without
Providing Local Radiological Air Sampling for the Activity
05/18/2023
2330889
Trip of E1156C001D-D MDCT Fan While in High-Speed
06/12/2023
2330911
MDCT Vibration Switch Trip Removal Modification Request
and EOC for Switch Replacement
06/13/2023
21504
Term Strip Piece Missing and Valve Stem has Scratches and
Nicks
2/16/2021
21232
Breaker Position 72F3A Greased with Anderol are Past
Industry Life of Anderol and Need to be Prioritized for
Refurbishment
2/14/2023
23207
Unsat Visual Inspection of Relay
05/01/2023
23207
Unsat Visual Inspection of Relay
05/01/2023
4M7214708
LLRT Penetration X8 Main Steam Drains
B
6I721N271240
Wiring Diagram Diesel Generator 11 Relay Cable R30P311
01/04/2013
6I721N271250
Wiring Diagram Diesel Generator 12 Rly Cable R30P321
10/31/2009
6I721N271260
Wiring Diagram Diesel Generator 12 Relay Cab R30P331
08/20/2010
6I721N271270
Wiring Diagram Diesel Generator 14 Relay Cab R30P341
11/14/2005
6M7212035
HPCI System Reactor Building
6M7212089
Nuclear Boiler System
BP
6M7212985
Drips and Drains from Steam Lines and Main turbine
AQ
6M7215701
Nuclear Boiler system Functional Operating Sketch
6M7215701-1
Nuclear Boiler System
6M7215706-2
RHR Division 1 Functional Operating Sketch
03/17/2022
6M7215709-1
Reactor Core Isolation Cooling (RCIC) System Sketch
Functional Operating Sketch
6M7215715-3
Standby Feedwater System Functional Operating Sketch
O
6M7215715-4
Standby Feedwater Lube Oil System Turbine Building
Functional Operating Sketch
F
Drawings
6M7215729-1
Emergency Equipment Cooling Water (Division 1) Functional
Operating Sketch
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
6M7215734
EDG System Functional Operating Sketch
05/18/2020
6M7215857
Process Diagram Residual Heat Removal System
03/16/1990
6SD7212510-01
One Line Diagram 480V E.
- S.S Bus 72B, 72C, 72E, and 72F
07/10/2010
Engineering
Evaluations
TEE4123-041
Evaluation of E4150F003 Packing Configuration Change
without Thrust Testing
05/29/2023
Motor Operated Valves Course Manual
071994
ANSI/ANS56
Containment System Leakage Testing Requirements
2002
Miscellaneous
Industry guideline for Implementing Performance-Based
Option of 10 CFR Part 50, Appendix J
3A
23.107.01
Standby Feedwater System
24.107.03
SBFW Pump and Valve Operability and Lineup Verification
Test
24.202.01
HPCI Pump/Flow Test and Valve Stroke at 1025 PSIG
24
24.204.01
Division 1 LPCI and Suppression Pool Cooling/Spray Pump
and Valve Operability Test
24.206.01
RCIC System Pump and Valve Operability Test
24.208.02
Division 1 EESW Pump and Valve Operability
24.307.45
EDG 11-Fast Start Followed by Load Reject
24.321.07
480V Swing Bus 72CF Automatic Throwover Scheme
Operability
24.413.03
Control Room Emergency Filtration Operability Test
35.306.003
Limitorque Motor Operator-Periodic Inspection
2.307.02
Logic System Functional Test of Division 2 EDG ECCS
Emergency Start Circuits and Auto Trip/Bypass Circuits
43.401.300
Local Leakage Rate Test Type C General
55B
43.401.302
Local Leakage Rate Testing for Penetration X8
Procedures
44.020.406
NSSSS-Main Steam Line Flow, Trip System B, Channel B
B21N088B Flow Loop Calibration/Functional
48689815
Calibrate HPCI Auxiliary Oil Pump Pressure Switch
05/16/2023
49401579
Replace HPCI Oil Pressure Indicators - Difficult to Read
05/16/2023
55963352
Replacement and VT2 Inspection of Div. 1 EESW Min Flow
Back Pressure Limiting Valve
05/31/2023
Work Orders
60569575
Perform Maxi Periodic MOV Inspection (E4150F007)
05/17/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
219826
LIR WO Inspection and Repair as Required: E1100F014A
04/11/2023
61612190
Perform 44.020.406 NS4 Maine Steam Line Flow, Trip Sys. B,
B21N088B, Cal/Func
04/21/2023
61925955
Perform 24.321.07 480V Swing Bus 72CF Automatic
Throwover Scheme Operability
03/30/2023
264151
Perform 24.307.45 EDG 11 Fast Start Followed by Load
Reject
05/05/2023
264151
Perform 24.307.45 EDG 11 Fast Start Followed by Load
Reject
05/04/2023
63576191
Perform 24.206.01 RCIC System Pump Operability and Valve
Test @ 1000 PSIG
05/12/2023
63858421
Perform 24.20201 HPCI Pump/Flow Test and Valve Stroke at
25 PSIG
05/19/2023
263234
Perform 24.107.03 SEC5.2 SBFW PUMP "A" Flow Test
06/30/2023
247296
Perform 24.204.01 Div. 1 LPCI and Suppression Pool Cooling
Pump and Valve Operability Test
04/12/2023
65832278
Complete 42.307.02 Logic System Functional Test of
Divisional 2 EDG ECCS Emergency Start Circuits and Auto
Trip/Bypass Circuits
04/11/2023
265289
2F3A Delayed Closure
04/26/2023
68515723
Manually Back Seat E4150F003 and Add Packing Rings
06/10/2023
686776618
Replace Vibration Switch (E11N130D) For MDCT Fan D
06/14/2023
10133814
Box Calibrator BX3
06/17/2022
4842
E520
2/27/2023
7716019
AMP200
2/14/2023
AtlanTech
Standup
Whole-Body Counter
2/07/2022
S/N: 0612072
GEM5
10/12/2022
S/N: 105
RAS1
09/12/2022
S/N: 1400
AMS4
11/21/2022
S/N: 1611257
ARGOS5ABZ
11/29/2022
S/N: 1967
HD28
01/31/2023
Calibration
Records
S/N: 251372
Ludlum 2000
03/06/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
S/N: 308
SAM11
2/16/2023
S/N: 309
F&J L12P
2/08/2023
S/N: 415
PCM1B
01/23/2023
S/N: 6608026
Telepole
2/01/2023
S/N: 81051
Ludlum 177
01/25/2023
25225
Multiple Telepoles Failed during Survey
04/15/2022
27369
Inability to Calibrate Div 2 SGTS SPING
06/23/2022
28101
Off Gas B Radiation Monitor IPCS Point Fails Calibration
07/21/2022
28170
Cannot Cal Div SGTS Div 2 due to SS1 OOS
07/25/2022
232145
CHRRMs Failed Calibration
2/28/2022
Corrective Action
Documents
22670
Failed to Report Calibration of OSSF SPING Past Critical Date
04/06/2023
2330324
Evaluate incorporation of ANSI N323A into the Radiation
Protection Instrument Program Through
Procedure 65.000.156
05/18/2023
Corrective Action
Documents
Resulting from
Inspection
2330328
Calibration Sheet Review Incorrect Unit
05/18/2023
NPRC010328
Evaluation of Daily Instrument Response Checks
10/23/2001
Engineering
Evaluations
NPRC970242
Evaluation of the Basis Documentation for the Process and
Effluent Radiation Monitor Setpoints
06/30/1997
2.000.133
Changing and ReCalculating Radiation Monitor Setpoints
65.000.156
Radiological Instrumentation Source Checking
Procedures
65.000.519
Radioactive Material Receipt / Source Control
Self-Assessments
Radiation
Monitoring
Instrumentation
Inspection Plan:
Instrumentation Program Self-Assessment
10/24/2022
228249
Perform 64.080.206 RX BLDG Exhaust Plenum PRM
calibration
11/11/2020
57135390
Perform 64.120.041 Containment Area High Range
Calibration
04/07/2022
61563226
Perform 64.713.050 Source Leak Test
2/22/2022
Work Orders
64420671
Perform 66.000.404 GSW Rad Mon Cal
2/22/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
2330908
NRC Identified-IRIS Data for RCS Total Leakage Discrepancy
06/13/2023
MSPI Derivation Report-Emergency AC Power System
Unreliability Index
03/2023
MSPI Derivation Report-Emergency AC Power System
Unavailability Index
03/2023
Fermi 2-EDG MSPI and WANO Performance Indicators
Various
Fermi 2-HPCI Performance Indicators
Various
MSPI Derivation Report-High Pressure Injection System
Unreliability Index
03/2023
MSPI Derivation Report-High Pressure Injection System
Unavailability Index
03/2023
Miscellaneous
24.000.02
Eight Hour - Mode 1, 2, 3 - Control Room RCS Operation
Leakage
Various
24.202.01
HPCI Pump and Valve Operability Test at 1025 PSI
24
24.202.08
HPCI Time Response and Pump Operability Test at 1025 PSI
71151
Procedures
24.307.14
EDG 11-Start and Load Test
21419
23 NRC Fire Protection Inspection: FP37, " Perform
28.507.01 Fire Barrier Inspection (MODE 1, 2, 3)- License
Renewal" Requires Full Completion
2/20/2023
Corrective Action
Documents
23167
Identified Possible Crack in RHR Fire Barrier
04/27/2023
Corrective Action
Documents
Resulting from
Inspection
23106
NRC Identified-FP37, "Perform 28.507.01 Fire Barrier
Inspection (Mode 1, 2, 3)- License Renewal
04/26/2023
Procedures
28.507.01
Fire Barrier Inspections
53082290
Perform 28.507.01 Fire Barrier Inspection (Mode 1, 2, 3)
09/21/2020
Work Orders
272867
Perform 28.507.01 Fire Barrier Inspection
(Mode 1, 2, 3)- License Renewal
04/27/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
MQA14100
NQA Issue Elevation & Escalation
Miscellaneous
NRC230039
Request for Enforcement Discretion for Technical Specification 3.7.2
06/06/2023
Procedures
24.208.02
Division 1 EESW Pump and Valve Operability
80