IR 05000341/2023003

Integrated Inspection Report 05000341/2023003 and 07200071/2023001

ML23304A155
Person / Time
Site:	Fermi, 07200071
Issue date:	11/07/2023
From:	Karla Stoedter NRC/RGN-III/DORS/RPB2
To:	Peter Dietrich DTE Electric Company
References
EA-23-091 IR 2023003
Download: ML23304A155 (32)

Text

November 7, 2023

SUBJECT:

FERMI POWER PLANT, UNIT 2-INTEGRATED INSPECTION REPORT 05000341/2023003 AND 07200071/2023001

Dear Peter Dietrich:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On October 20, 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. Two of these findings involved violations of NRC requirements one was determined to be Severity Level IV.

We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Stoedter, Karla on 11/07/23 Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000341 and 07200071 License No. NPF-43

Enclosure:

As stated

Inspection Report

Docket Number: 05000341 and 07200071 License Number: NPF-43 Report Number: 05000341/2023003 Enterprise Identifier: I-2023-003-0052 and I-2023-001-0102 Licensee: DTE Electric Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Inspection Dates: July 01, 2023 to September 30, 2023 Inspectors: T. Taylor, Senior Resident Inspector T. Briley, Senior Project Engineer J. Bozga, Senior Reactor Inspector L. Rodriguez, Senior Reactor Inspector E. Fernandez, Senior Reactor Inspector J. Gewargis, Resident Inspector T. Hooker, Health Physicist R. Ng, Senior Project Engineer J. Reed, Health Physicist D. Sargis, Health Physicist A. Shaikh, Senior Reactor Inspector Approved By: Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure

SUMMARY

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

List of Findings and Violations

Mechanical Draft Cooling Tower Bolt Repair Lacks Engineering Documentation Cornerstone Significance/Severity Cross-Cutting Report Aspect Section Mitigating Green [H.6] - Design 71111.18 Systems Severity Level IV Margins NCV 05000341/202300301 Open/Closed The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to mechanical draft cooling tower (MDCT) fan D anchorage completed on July 21, 2023, did not require a license amendment. Specifically, the licensee made a change to the MDCT fan D anchorage design pursuant to 10 CFR 50.59(c). This change involved going from one existing American Society of Testing and Materials (ASTM) A36 anchor bolt as the anchorage design to the full penetration welding of an ASTM A193 Grade B7 anchor bolt to an existing damaged piece of ASTM A36 anchor bolt. However, no written evaluation was provided describing the basis for determining that this change would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety.

Inoperable Mechanical Draft Cooling Towers Following Modification to Brake Control Circuit Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152A Systems NCV 05000341/202300302 Open/Closed A finding of very low safety significance (Green) with an associated non-cited violation of 10 CFR 50 Appendix B, Criterion III, "Design Control," was self-revealed when all four MDCTs were declared inoperable due to the licensee's failure to verify or check the adequacy of the design of new speed switches installed as part of Engineering Design Package 80072.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000341/202300201 Review of Increasing 71111.07A Open Differential Pressures on the Division 1 Emergency Equipment Service Water/Emergency Equipment Cooling Water Heat Exchangers

URI 05000341/202300303 Mechanical Draft Cooling 71153 Open Tower 'D' Inoperable due to High Vibrations

PLANT STATUS

Unit 2 began the inspection period at or near 100 percent power. On July 23, 2023, power was reduced to approximately 88 percent following high temperatures on the center condenser pump motor. On July 31, power was further reduced to approximately 58 percent to facilitate repairs to the center condenser pump motor. Power was restored to 100 percent on August 3, following repairs. On August 6, power was reduced to approximately 90 percent and then returned to 100 percent as part of a planned rod pattern adjustment. On August 9, power was reduced to approximately 90 percent and returned to 100 percent for planned maintenance/testing. On August 19, power was reduced to approximately 23 percent to facilitate a search for increased drywell unidentified leakage. On August 20, the plant was shut down to repair the source of leakage in the drywell. The planned outage concluded on September 8, when the plant was synchronized to the grid. The plant returned to 100 percent power on September 9,

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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) Emergency diesel generator (EDG) division 1 and division 2 ventilation during hot weather on July 26, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (10 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) Fire protection walkdown of EDG 12 engine room prior to slow start run during the week ending July 8, 2023

(2) Auxiliary building (AB) 1 walkdown to include cable vaults after cable vault inspections during the week ending July 15, 2023

(3) Reactor building, southeast corner room, basement and sub-basement during the week ending August 9, 2023

(4) Residual heat removal (RHR) complex, EDG 14 room and fuel oil storage room during the week ending August 9, 2023

(5) AB 2 and AB mezzanine walkdown with TRM requirement review of 28.505.09A/.09 during the week ending August 12, 2023

(6) Turbine building, third floor during the week ending August 18, 2023

(7) Turbine building, second floor during the week ending August 18, 2023

(8) AB, division 2 switchgear room during the week ending August 18, 2023

(9) Reactor building, first floor north during the week ending August 18, 2023

(10) Reactor building, first floor south during the week ending August 18, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill of the turbine building second floor hydrogen seal oil unit during the week ending August 12, 2023

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Partial)

The inspectors evaluated readiness and performance of:

(1) (Partial)

Inspectors continued review of issues associated with unexpectedly high differential pressures measured on the Division 1 emergency equipment service water (EESW)/emergency equipment cooling water (EECW) heat exchangers. The sample was opened in the second quarter (IR 05000341/2023002). Also refer to Unresolved Item (05000341/2023002-01).

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 up power from 64 percent to 85 percent after the center condenser pump motor replacement on August 2, 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) Reactor recirculation motor-generator controller replacement during the week ending July 22, 2023

(2) Down power and at power drywell entry to investigate increasing drywell leakage during the week ending August 19, 2023

(3) Center condenser pump motor replacement/wall removal, main steam isolation valve isolation temperature instruments, during the week ending September 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) EDG 12 lube oil flexible coupling leak degraded during EDG 12 run and governor level change and the damper challenges over the weekend of July 9, 2023

(2) MDCT fan 'D' trip on July 18, 2023, in fast-mechanical issue/vibes during the week ending September 30, 2023

(3) Reactor core isolation cooling outboard steam supply containment isolation valve E5150F008 steam leak on actuator/past operability during the week ending September 30, 2023

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) Repair of MDCT 'D' bolt during the week ending September 30, 2023

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated planned outage activities to repair 'B' recirculation sample line from August 20, 2023, to September 8, 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)

(1) Repair and testing of recirculation sample line weld during the week ending

September 16, 2023 Surveillance Testing (IP Section 03.01) (2 Samples)

(1) EDG 14 diesel generator service water (DGSW) diesel fuel oil transfer pump and valve operability test during the week ending August 15, 2023

(2) EDG 13 fast start run operability test during the week ending August 15,

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

GPI Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.

OTHER ACTIVITIES-BASELINE

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

MS08: Heat Removal Systems (IP Section 02.07) ===

(1) Unit 2 (July 1, 2022 through June 30, 2023)

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) Unit 2 (July 1, 2022 through June 30, 2023)

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) Unit 2 (July 1, 2022 through June 30, 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) Review of circumstances leading to inoperable overspeed protection circuits on the mechanical draft cooling towers.

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 EA-23-091, which can be accessed at http://www.nrc.gov/reading-rm/doc-collections/enforcement/notices/noedreactor.html, on July 26,

OTHER ACTIVITIES

-TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855 - Operation of an ISFSI Operation of an ISFSI

(1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading activities from June 26 through June 30, 2023. Specifically, the inspectors observed the following activities during the loading of multipurpose canister (MPC) No. 728:

• fuel loading

• heavy load movement of loaded MPC out of the spent fuel pool

• closure welding and non-destructive evaluations

• canister processing including blowdown and vacuum drying

• radiological field surveys The inspectors performed walkdowns of the ISFSI pad and walkdowns of the ISFSI haul path.

The inspectors evaluated the following:

• spent fuel selected for loading into dry cask storage during this loading campaign

• selected corrective action program documents

• selected 72.48 screenings

• changes to the site's 72.212 report since the previous inspection

INSPECTION RESULTS

Unresolved Item Review of Increasing Differential Pressures on the Division 1 71111.07A (Open) Emergency Equipment Service Water/Emergency Equipment Cooling Water Heat Exchangers URI 05000341/202300201

Description:

The inspectors continued their review of issues associated with unexpectedly high differential pressures measured on the Division 1 EESW/EECW heat exchangers as discussed in Inspection Report 05000341/2023002 and as part of Unresolved Item 05000341/2023002-01.

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, the NRC will perform an assessment to determine if the performance deficiency 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 heat exchangers (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, which was still in progress as the third quarter closed.

Corrective Action References: 202330619 Mechanical Draft Cooling Tower Bolt Repair Lacks Engineering Documentation Cornerstone Significance/Severity Cross-Cutting Report Aspect Section Mitigating Green [H.6] - Design 71111.18 Systems Severity Level IV Margins NCV 05000341/202300301 Open/Closed The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to MDCT fan D anchorage completed on July 21, 2023, did not require a license amendment. Specifically, the licensee made a change to the MDCT fan D anchorage design pursuant to 10 CFR 50.59(c). This change involved going from one existing ASTM A36 anchor bolt as the anchorage design to the full penetration welding of an ASTM A193 Grade B7 anchor bolt to an existing damaged piece of ASTM A36 anchor bolt. However, no written evaluation was provided describing the basis for determining that this change would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety.

Description:

Fermi Updated Safety Analysis Report (UFSAR) Section 1.2.2.3.6, Loss of Normal Heat Sink, states, The natural-draft cooling towers provide the normal heat sink for the once-through-type main unit condenser and auxiliary systems. Should this heat sink be lost, the reactor can be safely shut down and maintained using the mechanical-draft cooling towers and the residual heat removal (RHR) reservoir as a heat sink.

Fermi UFSAR Section 9.2.5, Ultimate Heat Sink, states, in part, The ultimate heat sink is provided by the RHR complex, which contains the RHR service water (RHRSW) system, the

[emergency equipment service water system] EESWS, the diesel generator service water system, the MDCTs, the emergency ac power system (diesel generators), and the reservoir.

Fermi UFSAR Table 3.2-1, "Structures, Systems, and Components Classification," delineates the MDCTs including structure fans and related hardware as Category I and meeting the Quality Assurance requirements of 10 CFR 50, Appendix B.

Fermi UFSAR Table 3.9-43, Safety-Related Mechanical Components Not Covered by ASME Code, delineates that the MDCTs have a design specification for structural steel of American Institute of Steel Construction (AISC) and a design code of reinforced concrete as American Concrete Institute (ACI).

MDCT fan D is anchored to its concrete pedestal via three mounting anchor bolts. The licensee identified during walkdowns that the front mounting anchor bolt was sheared off and not connected to the concrete pedestal. The licensee implemented Design Equivalent Change Package 700015, Repair damaged anchor for E1156B002B MDCT D gear reducer, Revision 0 that modified the MDCT fan D anchorage.

The inspectors reviewed Design Equivalent Change Package 700015, Revision 0. The licensee made the determination in Design Equivalent Change Package 700015, Revision 0 that no written evaluation was needed to determine potential impacts related to the design change. This activity involved the full penetration welding of an ASTM A193 Grade B7 anchor bolt to an existing piece of damaged ASTM A36 anchor bolt. The inspectors identified that the design verification of the new anchor bolt configuration had not considered the following:

1) The full penetration welding of the new anchor bolt ASTM A193 Grade B7 material with the existing damaged ASTM A36 material has the potential to introduce weld residual stresses which can adversely affect the yield strength of the anchor bolt material.

2) The dissimilar bolt material condition may cause an accelerated corrosion process (one anchor bolt material will be noble-cathode and the other anchor bolt material will be sacrificial-anode) at the heat affected zones.

3) The standard specification for ASTM A193 specifies that Grade B7 shall be heat treated by quenching in a medium and tempering. The AISC 9th Edition specifies that an anchor bolt that is quenched and tempered should not be welded or heat treated. The full penetration welding to the ASTM A193 Grade B7 anchor bolt material can adversely affect the mechanical properties of the bolt material which include the yield strength, ultimate strength, elongation, hardness and area.

The licensee's decision to full penetration weld the aforementioned anchor bolt materials together, as evaluated under Design Change 700015, created an anchorage design that could result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the updated final safety analysis report due to the considerations discussed above.

The licensee is permitted to make changes to the facility as described in the UFSAR without prior NRC approval provided that these changes would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of structure, system or component important to safety used in establishing the plant design bases. Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, states that the methods described in Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Evaluations, Revision 1, are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.59. NEI 96-07, Revision 1, Section 4.3.2, addresses Does the Activity Result in More Than a Minimal Increase in the Likelihood of Occurrence of a Malfunction of an SSC Important to Safety? The section states, in part: although this criterion allows minimal increases, licensees must still meet applicable regulatory requirements and other acceptance criteria to which they are committed (such as contained in regulatory guides and nationally recognized industry consensus standards, e.g., the ASME Boiler and Pressure Vessel Code and Institute of Electrical and Electronics Engineers standards). Further, departures from the design, fabrication, construction, testing and performance standards as outlined in the General Design Criteria (Appendix A to Part 50) are not compatible with a no more than minimal increase standard. In addition, changes in design requirements for earthquakes, tornadoes and other natural phenomena should be treated as potentially affecting the likelihood of malfunction. Based upon the above, the inspectors concluded that the change would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety.

Corrective Actions: The licensee sent a mock-up of the modified anchorage configuration to a vendor for testing to address the weld residual stresses, mechanical properties and galvanic corrosion.

Corrective Action References: CR 2023-33153 and CR 2023-33264

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to provide a written evaluation describing the basis for determining that the change to the MDCT fan D anchorage design, which was completed on July 21, 2023, did not require a license amendment was contrary to 10 CFR 50.59(d)(1) and was a performance deficiency.

Specifically, the licensee made a change to the MDCT fan D anchorage design pursuant to 10 CFR 50.59(c) and did not address the change in a full written evaluation.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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. In addition, the associated violation was determined to be more than minor because the inspectors could not conclude that the changes would not result in a more than minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety used in establishing the MDCT fan D anchorage design without further evaluation.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Significant Determination Process (SDP). However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. The inspectors determined the finding could be evaluated using the SDP and used IMC 0609, Attachment 4, Initial Characterization of Findings, issued December 13, 2019, and Appendix A, The Significance Determination Process for Findings at Power, issued November 30, 2020, to evaluate the technical issue. The finding was screened against the Mitigating Systems cornerstone. The finding screened as having very low safety significance (Green) because the MDCT fan D anchorage maintained its operability to provide sufficient cooling to permit safe shutdown and cooldown of the plant in the event of a design-basis accident. As such, the finding corresponded to a Severity Level IV violation in accordance with Example 6.1.d.2 of the NRC Enforcement Policy.

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. Specifically, the licensee failed to adequately evaluate the weld residual stresses, mechanical properties and galvanic corrosion due to the full penetration welding of an ASTM A193 B7 anchor bolt to an existing damaged ASTM A36 anchor bolt for the effect on the anchorage design margin.

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: In accordance with Section 6.1.d.2 of the NRC's Enforcement Policy, the violation was classified as a Severity Level IV violation because the underlying technical issue was of very low risk significance.

Violation: Title 10 CFR 50.59, Changes, Tests and Experiments, (d)(1) states, in part, a licensee shall maintain records of changes in the facility made pursuant to paragraph

(c) of this section. These records must include a written evaluation that provides the bases for the determination that the change does not require a license amendment pursuant to 10 CFR 50.59(c)(2).

10 CFR 50.59(c)(2)(ii) states, in part, a licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated).

Fermi USAR Section 1.2.2.3.6, Loss of Normal Heat Sink, states, The natural-draft cooling towers provide the normal heat sink for the once-through-type main unit condenser and auxiliary systems. Should this heat sink be lost, the reactor can be safely shut down and maintained using the mechanical-draft cooling towers and the residual heat removal (RHR)reservoir as a heat sink.

Fermi UFSAR Section 9.2.5, Ultimate Heat Sink, states, in part, The ultimate heat sink is provided by the RHR complex, which contains the RHR service water (RHRSW) system, the

[emergency equipment service water system] EESWS, the diesel generator service water system, MDCTs, the emergency ac power system (diesel generators), and the reservoir.

Fermi UFSAR Table 3.2-1, "Structures, Systems, and Components Classification," delineates the MDCTs including structure fans and related hardware as Category I and meeting the Quality Assurance requirements of 10 CFR 50, Appendix B.

Fermi UFSAR Table 3.9-43, Safety-Related Mechanical Components not Covered by ASME Code, delineates that the MDCT fans have a design specification for structural steel of AISC and a design code of reinforced concrete as ACI.

Contrary to the above, as of July 21, 2023, the licensee failed to maintain records of a change to the facility made pursuant to paragraph

(c) of this section. Specifically, the licensee changed the anchorage design for MDCT fan D and did not evaluate whether changes in the anchorage weld residual stresses, mechanical properties and galvanic corrosion constituted more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety.

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

Inoperable Mechanical Draft Cooling Towers Following Modification to Brake Control Circuit Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152A Systems NCV 05000341/202300302 Open/Closed A finding of very low safety significance (Green) with an associated non-cited violation of 10 CFR 50 Appendix B, Criterion III, "Design Control," was self-revealed when all four MDCTs were declared inoperable due to the licensee's failure to verify or check the adequacy of the design of new speed switches installed as part of Engineering Design Package 80072.

Description:

The MDCTs consist of four fans (two per division) that are designed to remove heat from the ultimate heat sink. The plants ultimate heat sink is a reservoir of water beneath the residual heat removal (RHR) service water complex. The fans are protected from overspeed during design basis tornadoes by a control circuit that senses fan speed via a magnetic sensor located near the gear teeth. This signal is sent to a speed switch that will apply brakes to the fan if the speed gets too high. On March 13, 2023, procedure 46.205.001, "Calibration of RHR Cooling Tower Fan Overspeed Protection System," Revision 33, was being performed on the 'D' MDCT fan. The purpose of the procedure was to test the overspeed braking system to ensure it actuated at the correct fan rotation per minute (RPM) using a simulated speed signal injected into the overspeed switch. During the test, technicians noted the RPM indication was at zero with the fan running in fast speed. Troubleshooting revealed that while the test would pass with the 4-volt peak-to-peek (4Vp-p) simulated square wave applied to the switch per the test, the brakes would not work with the actual ~9Vp-p field signal sent from the magnetic sensor. In consultation with the switch supplier, the licensee determined an appropriate voltage the switch would function at when installed in the licensees system. This information led to a design change, which was implemented by the licensee to restore the MDCT fans to an operable status (addition of an adjustable potentiometer to lower input voltage from the sensor to the switch). As a result of their discussions with the switch supplier during troubleshooting (Engine Systems International), the licensee issued a Part 21 notification (ML23159A004 and ML23177A043) due to questions regarding testing performed during their dedication of the new switches. Of note, the inoperability that occurred to the MDCT fans only applied to the overspeed braking function, which is only required during design basis tornado conditions.

The inspectors reviewed the root cause analysis performed by the licensee and the design change package (EDP 80072) which installed the new overspeed switches. The Division 1 switches (fans 'A' and 'C') were installed in December 2020. The Division 2 switches (fans 'B' and 'D') were installed in September 2022. The modification primarily affected the switches and connection to the plant power system (power supply change). The sensor and its associated wiring in the plant remained the same. Some of the original design drawings, and drawings approved for the new overspeed circuit, stated that the input voltage to the switch from the sensor should be set to 2V peak (2Vp) with the fan running at 1750 RPM (the fast speed of the fan). This is equivalent to 4Vp-p. Specifically, design drawings E-6001-01 (via EDP posting 80072.005), "Division 1 RHR Complex Cooling Towers Fan Overspeed Brake System," Revision C, and drawing E-6001-02, "Division 2 RHR Complex Cooling Towers Fan Overspeed Brake System," Revision D, stated adjustments were to be made in the field to provide a 2Vp signal from the sensor to control at 1750 RPM. Sheet 3 of Drawing M-6067-2, "RHR Complex Cooling Tower Fan Overspeed Brake Installation," Revision A, stated the 2Vp signal could be measured across terminals 10 and 11 in the control box.

During testing, ESI informed the site that they could not get the switch to work at certain input voltages, which reinforced the design concept that voltage could affect the functionality of the switch at certain speeds/RPM. ESI modified the design, stating they were able to get the switch to work at certain voltages after they added a load resistor.

However, despite approved design drawings and a report from the vendor regarding limitations on the input voltages, post-installation checks and testing did not validate that, when installed in the plant, the appropriate voltage was present. The vendor-established range was unknown and therefore was not reconciled with the voltage described on design drawings, nor in calibration/test procedures which used a simulated voltage to test the circuit following installation. Additionally, guidance in licensee post-maintenance test procedure, MMA11, "Post-Maintenance Testing," was not followed. Specifically, MMA11 indicated that for maintenance performed on fans or their control circuitry, or electric switches, affected indication was to be checked. In this case, a failure to check the RPM meters (fed from the new switches) following installation resulted in a failure to recognize the inadequate design.

Corrective Actions: The licensee entered the issue into the corrective action program and performed a root cause evaluation.

Corrective Action References: 23-22040

Performance Assessment:

Performance Deficiency: 10 CFR 50 Appendix B, Criterion III, "Design Control," requires, in part, for those structures, systems, and components for which Appendix B applies, the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. The licensee implements these requirements through site procedures. Licensee procedure MES90, "Standard Design Process Interface," Revision 1, Section 3.5.2, requires design inputs and bounding technical requirements to be properly evaluated for design changes. The licensee did not evaluate voltage limitations stipulated on the design drawings nor provided by the vendor. Further, Section 3.5.7 requires post-modification testing to verify affected SSCs perform as intended following the engineering change. This section also states that types of testing are described in utility-specific procedures. Utility-specific procedure MMA11, "Post-Maintenance Testing Guidelines," Revision 27, outlines requirements for testing fans and electric switches following maintenance, and these requirements were not followed by the licensee.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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, a design change was implemented that resulted in all four MDCT's being rendered inoperable for the design basis tornado overspeed function.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the inspectors utilized Exhibit 2 and answered 'yes' under Section B for external event mitigating systems. Using Exhibit 4, question 1, the inspectors answered 'yes' because the condition degraded 2 or more trains of a multi-train system (cooling tower circuits in both safety divisions were impacted). As a result, a detailed risk evaluation was performed to assess the significance. A Region III senior reactor analyst performed the evaluation and concluded the finding was assumed to result in the failure of all four MDCT fans during a design basis tornado. The total exposure period modeled was limited to one year, per SDP guidance, and was based on when the modifications were installed. The Division 1 switches were installed in December 2020 while the Division 2 switches were installed in September 2022. The condition was corrected in March 2023. The SRA used the current Standardized Plant Analysis Risk model (8.81) to analyze the finding. The change in core damage frequency (CDF) due to design basis tornadoes was estimated to be less than 1E-7/year. Therefore, the finding was determined to be of very low safety significance (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. Specifically, Engineering Design Package 80072 was approved for installation more than three years ago.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, for those structures, systems, and components to which this appendix applies, the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

Licensee procedure MES90, "Standard Design Process," Revision 1, states that for design change packages, post-modification testing is required to verify that affected SSCs perform as intended and reference the use of utility-specific procedures in developing post-modification tests.

Utility-specific procedure MMA11, "Post-Maintenance Testing Guidelines," Revision 27, states, in part, following maintenance on fans or electric switches, verify indications are as expected.

Design posting 80072.005 (planned revision to drawing E-6001-01, "Division 1 RHR Complex Cooling Towers Fan Overspeed Brake System)," Revision C, states that the sensor gap shall be field adjusted to provide a 2-volt peak signal to control at 1750 RPM.

Design drawing E-6001-02, "Division 2 RHR Complex Cooling Towers Fan Overspeed Brake System," Revision D, states that the sensor gap shall be field adjusted to provide a 2-volt peak signal to control at 1750 RPM.

Drawing M-6067-2, "RHR Complex Cooling Tower Fan Overspeed Brake Installation,

" Sheet 3, Revision A, stated the 2Vp signal could be measured across terminals 10 and 11 in the control box.

Contrary to the above, on December 9, 2020 (Division 1), and September 14, 2022 (Division 2), the licensee failed to verify or check the adequacy of design, by the performance design reviews or a suitable testing program, of the operating characteristics of the new mechanical draft cooling tower fan speed switches installed per Engineering Design Package 80072. Specifically, the licensee failed to verify the voltage present at the input to the speed switch aligned with information provided in design drawing E-6001-02, design posting 80072.005, and drawing M-6067-2. Additionally, once installed, the licensee did not verify the fan RPM indicators were reading appropriately with the fans in operation, contrary to Procedure MMA11.

In addition, Technical Specification 3.7.2 requires that two emergency equipment cooling water/emergency equipment service water subsystems and the ultimate heat sink be operable when the reactor is operating in modes 1, 2, and 3.

Contrary to the above, between December 9, 2020 and March 24, 2023, two emergency equipment cooling water/emergency equipment service water subsystems and the ultimate heat sink were not operable when the reactor was operating in modes 1, 2 and 3. Specifically, from December 9, 2020 to March 24, 2023, Division 1 of the ultimate heat sink (UHS) was inoperable due to an inoperable MDCTs fan overspeed braking circuit. In addition, from September 14, 2022, until March 24, 2023, Division 2 of the UHS was also inoperable due to an inoperable MDCT fan overspeed braking circuit.

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

Unresolved Item Mechanical Draft Cooling Tower 'D' Inoperable due to High 71153 (Open) Vibrations URI 05000341/202300303

Description:

On July 18, 2023, the 'D' MDCT tripped on high vibrations during routine operations while running in fast speed. The MDCTs provide cooling to the plant's UHS, which is used to cool safety-related equipment under accident conditions. Investigation revealed damage to the couplings which connect the fan motor to the main shaft and the main shaft to a gearbox which drives the fan. The condition rendered Division 2 of the UHS inoperable, prompting entry into technical specification (TS) actions for LCO 3.7.2, EECW/EESW System and UHS.

Specifically, action A.1. was entered, which required operability to be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If operability was not restored within that timeframe, TSs would require the plant to be shutdown. Further investigation by the licensee revealed one of the three bolts used to mount the gearbox had sheared apart. The licensee requested, and was subsequently approved for, a Notice of Enforcement Discretion (NOED) from the NRC to allow for repairs to be completed beyond the 72-hour TS allowed outage time (ML23206A127). Repairs were completed and the 'D' MDCT was restored to operable status on July 22, 2023. In accordance with the NRC Enforcement Manual, the inspectors opened an Unresolved Item to track further inspector review of the issue.

Planned Closure Actions: Further NRC inspection is required to determine if a performance deficiency exists, which will include a review of licensee corrective action documents associated with the 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 entered the issue into the CAP and performed repairs to restore the 'D' MDCT to an operable status.

Corrective Action References: CR

EXIT MEETINGS AND DEBRIEFS

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

• On October 20, 2023, the inspectors presented the integrated inspection results to P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.

• On July 27, 2023, the inspectors presented the radiation protection inspection results to P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.

• On September 1, 2023, the inspectors presented the ISFSI cask loading inspection results to P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60855 ALARA Plans 63.000.200 2023 ISFSI Campaign ALARA Plan 0

60855 Corrective Action 1924382 Reevaluate VCT Loaded Safe Operating Wind Speed Limit 06/10/2019

Documents

60855 Corrective Action 2222252 NEI Published NEI22-02: Guidelines for Weather-Related 02/21/2022

Documents Administrative Controls for Short Duration Outdoor Dry

Cask Storage Operations

60855 Corrective Action 202331304 NRC Identified - Administrative Error Found in 06/30/2023

Documents Section 4.4.1.1.2 of 10CFR72.212 Evaluation Report

Resulting from

Inspection

60855 Corrective Action 202331492 ISFSI NRC Identified - Vacuum Drying System Valve Open 07/10/2023

Documents Longer than 1 Minute

Resulting from

Inspection

60855 Miscellaneous 053.000.10.160606 Fuel Characterization for Cycle 16 Fuel 0

60855 Miscellaneous 212 Eval Report 10 CFR 72.212 REPORT 4

60855 Miscellaneous 57.000.21 Fuel Inventory 3

60855 Miscellaneous 72.48 Screen Helium Mass Spectrometer Leak Test 0

230032

60855 Miscellaneous 72.48 Screen 212 Eval Report 0

230069

60855 Miscellaneous MPC 728 Composite Cask Load Report Campaign 4 Cask 04 0

60855 Miscellaneous RRTI 33370001 Tornado Wind / Missile Evaluation of Transient Cask 0

Configurations at Fermi

60855 NDE Reports 918622728-01 Root Layer NDE Report - Cask 728 06/29/2023

60855 Procedures 35.710.042 Multipurpose Canister (MPC) Loading 14

60855 Procedures 35.710.043 Blowdown, Drying, Sealing and Backfill of the MPC 12

60855 Procedures 35.710.058 HI-Storm Lifting Beam Inspection 0A

60855 Procedures GQP9.2 High-Temperature Liquid Penetrant Examination and 2

Acceptance Standards for Welds Base Materials and

Cladding (50° - 350°F)

60855 Procedures MSLT-MPC- Helium Mass Spectrometer Leak Test 366502

Inspection Type Designation Description or Title Revision or

Procedure Date

HOLTEC

60855 Procedures WIRPO047 Work Instruction for ISFSI RP Job Coverage 5

60855 Radiation PM202212143 SA-94 ISFSI Cask Pad 12/14/2022

Surveys

60855 Radiation PM2023060711 Tech Spec MPC Contamination Survey 06/07/2023

Surveys

60855 Radiation PM202307101 ISFSI Tech Spec MPC Contamination Survey 07/12/2023

Surveys

60855 Work Orders 62427674 Perform 35.710.055 HI-Storm Monthly Screen Inspection 02/22/2023

60855 Work Orders 64134238 Neil Required/License Renewal-RB Overhead Crane PM 01/23/2023

Inspections

60855 Work Orders 64134279 Neil Required - Perform 'F' Frequent Inspection per 04/17/2023

MIOSHA R408.11872 RULE 1872 (2) (A)

60855 Work Orders 66744741 Neil Required HI-Storm Lifting Bracket Inspection 10/26/2022

60855 Work Orders 66744816 HI-Trac Lift Yoke Inspection 04/04/2023

60855 Work Orders 66745255 HI-Storm Lift Beam Inspection 10/26/2022

71111.04 Procedures 23.420 RHR Complex Heating and Ventilation 42

71111.05 Corrective Action CR202332065 Fire Protection Events Past Critical 08/02/2023

Documents

71111.05 Corrective Action 202332232 NRC Identified Door Issues at RHR 08/10/2023

Documents

Resulting from

Inspection

71111.05 Corrective Action 202332243 NRC Identified: Expired Fire Extinguisher Service Tags in 08/10/2023

Documents RHR Complex

Resulting from

Inspection

71111.05 Corrective Action 202332376 NRC Identified: Expired Transient Combustible Permit on 08/17/2023

Documents RB1

Resulting from

Inspection

71111.05 Corrective Action 202332379 NRC Identified: Equipment Staged on "Fire Equipment Do 08/17/2023

Documents Not Block" Sticker

Resulting from

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection

71111.05 Corrective Action 202332386 NRC Identified: Sprinkler Head in Contact with Hoist Above 08/17/2023

Documents MLO Tank

Resulting from

Inspection

71111.05 Drawings 6A7212400 Fire Protection Evaluation Plot Plan Q

71111.05 Drawings 6A7212401 Fire Protection Evaluation Reactor Building L

Subbasement - Plan - El. 540' 0"

71111.05 Drawings 6A7212403 Fire Protection Evaluation Reactor and Auxiliary Buildings T

First Floor - Plan - El. 583' 6"

71111.05 Fire Plans FPAB16a Auxiliary Building Cable Tray Area North 5

71111.05 Fire Plans FPAB16b Auxiliary Building Cable Entry Room Zone 6 5

71111.05 Fire Plans FPAB16c Auxiliary Bridling Cable Tray Area South Zone 6 4

71111.05 Fire Plans FPAB16d Auxiliary Building 1st Floor Mezzanine Zone 6 6

71111.05 Fire Plans FPAB29C Auxiliary Building Cable Tunnel Zone 9 4

71111.05 Fire Plans FPABM11 Auxiliary Building Cable Spreading Room Zone 11 5

71111.05 Fire Plans FPABM9A Auxiliary Building Second Floor Mezzanine Zone 9A 7

71111.05 Fire Plans FPAB314e Auxiliary Building, Division II Switchgear Room, Zone 14, 2

El. 643'6"

71111.05 Fire Plans FPRB17a Reactor Building North Control Rod Drive (CRD) Area, 5

Zone 7, El. 584'6"

71111.05 Fire Plans FPRB17b Reactor Building South CRD and Railroad Bay Area, Zone 5

71111.05 Fire Plans FP-RB-B4d Reactor Building Basement Southeast Corner Room, Zone 4

4, El. 562' 0"

71111.05 Fire Plans FPRHR112-EDG RHR Complex EDG 12 Room 7

71111.05 Fire Plans FPRHR114-EDG RHR Complex, EDG 14 Room, El. 590' 0" 6

71111.05 Fire Plans FPRHR114-OS RHR Complex, EDG 14 Oil Storage Room, El. 590' 0" 5

71111.05 Fire Plans FPRHR253 RHR Complex, EDG 12 Switchgear and Switchgear 5

Ventilation Rooms

71111.05 Fire Plans FPTB Turbine Building 11

71111.05 Miscellaneous LPFP94001YX Fire Drill/Evaluation: Hydrogen Seal Oil Unit, 2nd Floor 1

Turbine Building

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05 Procedures 28.502.12 Fire Protection/Detection Operability Test Zone 9A-Cable 13

Tray Area Aux Building 2nd Floor Mezzanine

71111.05 Procedures 28.503.05 Halon Fire Suppression System Functional Test Zone 20

11- Cable Spreading Room

71111.05 Procedures 28.503.08 Fire Protection/Detection Operability Test Zone 11-Cable 11

Spreading Room Aux. Building

71111.05 Procedures 28.505.09 Fire Detection Zone 9 Operability Test Aux Building 2nd 10

Floor

71111.05 Procedures 28.505.09A Fire Detection Zone 9A Operability Test AB 2nd Mezzanine 11

Cable Tray Room-BOP

71111.05 Procedures 28.505.11 Fire Detection Zone 11 Operability Test AB 2nd Floor 11

Mezzanine Cable Spreading Room-BOP

71111.05 Procedures 28.506.06 CO2 Fire Suppression System Functional Test Zone 24

9A-Auxiliary Building 2nd Floor Mezzanine Cable Tray Area

71111.07A Operability TEP4423-049 Division 1 EECW Heat Exchanger Plugging Past 0

Evaluations Operability Evaluations

71111.11Q Miscellaneous 57.000.22 Load Profile Plan: July 2023 Maintenance Down power 2

A

71111.13 Corrective Action 0921894 East HFP discharge check valve failure 03/27/2009

Documents

71111.13 Corrective Action 202331974 NQA Condensate Pump Motor Winding Temperature 07/31/2023

Documents Impacts to Maintenance and Monitoring Strategy

71111.13 Corrective Action 202332000 N2000-F146A East HFP Discharge Check Valve Failure 07/31/2023

Documents

71111.13 Engineering TEU2223-050 Shield Blocks Removal for C Condenser Pump Motor 0

Evaluations Replacement

71111.13 Miscellaneous Fermi 2 Safety Replace Center Condenser Pump Motor 07/26/2023

Handbook

Section 25- Job

Hazard Analysis

71111.13 Procedures 23.155 Condenser Vacuum System 66

71111.13 Procedures MWC15 Work Control Conduct Manual: Elevated Risk Management 23

71111.13 Procedures MWC18 Work Control Conduct Manual: Emergent Issues Response 10/06/2023

71111.13 Work Orders 65824705 Drywell Entry and Leakage Identification 08/16/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Work Orders 68936657 B31R621B-Replace Speed Controller 07/13/2023

71111.15 Corrective Action 202331630 MDCT D fan tripped 07/20/2023

Documents

71111.15 Corrective Action 202332431 PO 23-01 Shut Down Walkdown - E5150F008 RCIC Valve 08/21/2023

Documents Steam Leak

71111.15 Corrective Action 202332487 PO 23-01 E5150F008 As-Found Thrust Test and Inspection 08/22/2023

Documents Results

71111.15 Corrective Action CARD1824869 EDG 11 Governor Oil Level High 06/22/2018

Documents

71111.15 Corrective Action CARD1825541 Inadequate Technical Rigor Regarding EDG 11 Governor 07/20/2018

Documents Oil Level

71111.15 Corrective Action CARD1920385 NRC Violation-Failure to Apply Torque Values Described in 01/17/2019

Documents Maintenance Procedure for Flexible Couplings on EDG 12

71111.15 Corrective Action CARD1921025 Oil identified on EDG 12 Auxiliary Skid Below R3000F123C 02/11/2019

Documents

71111.15 Corrective Action CARD2230749 LO Leak from EDG12 Coupling 10/31/2022

Documents

71111.15 Corrective Action CR202331488 EDG 12 Governor Oil Level Low in Band 07/10/2023

Documents

71111.15 Drawings 5M7216015 4" 900# O.S.Y. Powell O.S.Y. Gate Valve with Limitorque 0

Operator

71111.15 Engineering EQ1EF2044 Qualification Evaluation Report (QER); Limitorque J

Evaluations

71111.15 Engineering Log. No. 06054 Appendix J - Generic Letter 89-10 Correlation (Retest 1

Evaluations Guidelines for Appendix J Valves)

71111.15 Miscellaneous NRC230049 Fermi Letter Requesting Enforcement Discretion for 07/21/2023

Technical Specification 3.7.2, EECW/EESW System and

UHS

71111.15 Work Orders 69270880 E5150F008 Repack / Possible Damage to Valve Stem 08/28/2023

71111.15 Work Orders 69286422 E5150F008 RCIC TURB STM SPLY OTBD CNTM ISO 08/28/2023

MOV

71111.18 Corrective Action 202331674 Gearbox Hold Down Bolt Found Separated due to 07/20/2023

Documents Corrosion

71111.18 Corrective Action 202331707 Original Installation of the MDCT Gearbox Mounting is Not 07/21/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents in Accordance with Installation Drawings

71111.18 Corrective Action 202333153 Shop Work Order Needed for Anchor Bolt Testing 09/20/2023

Documents

Resulting from

Inspection

71111.18 Corrective Action 202333264 Design Equivalent Change 700015 (Repair Damaged 09/25/2023

Documents Anchor Bolt for D MDCT) Did Not Contain Sufficient

Resulting from Technical Detail

Inspection

71111.18 Miscellaneous Design Equivalent Repair Damaged Anchor for E1156B002B (MDCT D Gear 0

Change Package Reducer)

700015

71111.18 Miscellaneous Document No. Acceptability Assessment of Weld Repair to Fan Support 09/21/2023

38021.009LR-001 Anchor Bolt

71111.18 Miscellaneous EDP700015.002 Mechanical Draft Cooling Tower Fan D Anchorage Detail 0

M

71111.18 Work Orders 68994737 Repair the MDCT Fan D Gearbox Pedestal and Footing 1

71111.20 Calculations DC3603 DCD Volume: Pipe Stress for Line 6DI-B31-7255-1 0

71111.20 Calculations DC3603 Pipe Stress Analysis RRS Loop 3 Instrumentation Line 0

CTB316018

71111.20 Corrective Action 1723734 RPS-A EPA Breaker Found Tripped 04/19/2017

Documents

71111.20 Corrective Action 202332654 Unsatisfactory Acceptance Criteria While Meggering 08/30/2023

Documents Recirculation 'B' Pump Motor B3103C001B

71111.20 Corrective Action 202332844 Refuel Floor High Radiation Airborne Event 09/06/2023

Documents

71111.20 Corrective Action 202332852 Spent Fuel Pool Gate Leaking at 20 Drops per Minute 09/06/2023

Documents

71111.20 Corrective Action 202332853 Airborne Activity on the Refuel Floor 09/06/2023

Documents

71111.20 Corrective Action 2225400 Spent Fuel Pool Gate Leaking at 20 Drips per Minute 04/20/2022

Documents

71111.20 Corrective Action 202332813 NRC Identified - Observations during Head Lift on Refuel 09/05/2023

Documents Floor

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

71111.20 Corrective Action 202332818 NRC Identified Observation: Hands on Load/FME Area 09/05/2023

Documents Establishment

Resulting from

Inspection

71111.20 Drawings 6DI-B317255-1 Drywell Instrumentation Isometric Piping from B31L018 to F

Penet X-29 Reactor Building Drywell

71111.20 Drawings 6I7212045-57 Internal -External Wiring Diagram Inboard Valve Relay Cab AA

H11P622 Part 1 Division 1

71111.20 Drawings 6I7212101-02 Schematic Diagram Recirculation Pump MG Set 'B' Drive X

Motor B3103S001B

71111.20 Drawings 6I7212101-04 Schematic Diagram Recirculation Pump Discharge Valve AA

B3105P031B

71111.20 Drawings 6I7212101-10 Schematic Diagram Recirculation Pump B3101C001A X

71111.20 Drawings 6I7212151-01 Schematic Diagram Reactor Protection System AL

Motor-Generator Set 'A'

71111.20 Drawings 6I7212151-02 Schematic Diagram Reactor Protection System Z

Motor-Generator Set 'B'

71111.20 Drawings 6I7212201-17 Schematic Diagram RHR Loop 'B' Recirculation INBD P

Isolation Valve E1150F015B

71111.20 Drawings 6I7212221-05 Schematic Diagram HPCI System - Pump Discharge 31

Isolation Valves E4150F006 and F007

71111.20 Drawings 6I7212225-03 Schematic Diagram HPCI System Logic Circuit Pt 1 AA

71111.20 Drawings 6M7212035 HPCI Reactor Building 70

71111.20 Drawings 6M7212083 Diagram RHR Division 2 CC

71111.20 Drawings 6M7212089 System Diagram Nuclear Boiler System BP

71111.20 Drawings 6M7212090 System Diagram Nuclear Boiler System AP

71111.20 Drawings 6M7212833 Diagram Reactor Recirculation System Nuclear Boiler AK

System

71111.20 Drawings 6M7215702-1 Reactor Recirculation System Nuclear Boiler System Z

Functional Operating Sketch

71111.20 Drawings 6M7215708-1 High Pressure Coolant Injection System Functional AS

Operating Sketch

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.20 Drawings 6M7215711-1 Reactor Water Cleanup Reactor Building Functional 40

Operating Sketch

71111.20 Drawings 6M7215726 General Service Water System Functional Operating CG

Sketch

71111.20 Drawings 761E214 Recirculation Loop 11

71111.20 Engineering 80047 Installation of Jet Pump Nozzle Plugs [PROPRIETARY] 0

Changes

71111.20 Miscellaneous Pressure and Temperature Limits Report [Confidential] 06/08/2020

71111.20 Miscellaneous FME Project Plan 3

71111.20 Miscellaneous N6661 Cases of ASME Boiler and Pressure Vessel Code 03/13/2012

71111.20 Miscellaneous ODE2 Operations Evolution Order 48

71111.20 Miscellaneous SHIC3310501- B31 Reactor Recirculation System 0

001

71111.20 Miscellaneous TEB3123-056 Evaluation of Drywell Leak in Sampling Instrumentation 0

Line at Reactor Recirculation Header B31L018

71111.20 Miscellaneous TEP8023-060 TRLO 3.0.4(b) Mode Change Restraint Assessment While 0

Diesel Fire Pump Inoperable

71111.20 Miscellaneous TEP8023-060 TRLCO 3.0.4(b) Mode Change Restraint Assessment While 1

Diesel Fire Pump Inoperable

71111.20 Procedures 20.205.01 Loss of Shutdown Cooling 23

71111.20 Procedures 20.300.RPSB Loss of RPS 'B' 1

71111.20 Procedures 22.000.02 Plant Startup to 25 Percent Power 110

71111.20 Procedures 22.000.04 Plant Shutdown From 25 Percent Power 92

71111.20 Procedures 23.205 Residual Heat Removal System 149

71111.20 Procedures 23.316, Att. 5A Shutdown Cooling Isolation Defeat RPS Bus 'B' 0

71111.20 Procedures 23.316, Enclosure RPS Bus 'B'-Affected Equipment List 0

B

71111.20 Procedures 23.316, Enclosure RPS Bus 'A'-Trips 0

C

71111.20 Procedures 23.623 Reactor Manual Control System 78

71111.20 Procedures 24.137.21 Reactor Pressure Vessel System Leakage Test 44

71111.20 Procedures 35.710.016 Installation and Removal of the Jet Pump Nozzle Plugs 24

71111.20 Procedures 42.610.04 Division 2 Normal Supply Reactor Protection System (RPS) 30

Inspection Type Designation Description or Title Revision or

Procedure Date

Electrical Protection Assembly Calibration/Functional Test

71111.20 Procedures 42.610.04 EPA Channel Functional Test and Completion of Channel 30

Calibration

71111.20 Procedures 43.000.005 Visual Examination of Piping and Components (VF2) 39

71111.20 Procedures MMA17 Foreign Material Exclusion (FME) 17

71111.20 Procedures MMA17200 Refuel Floor FME Plan 2

71111.20 Procedures MMR App H Online Core Damage Risk Management Guidelines 17

71111.20 Procedures MMR12 Equipment out of Service Risk Management 20A

71111.20 Work Orders 69274384 Repair Leak on Reactor Recirc Sample Line Tap, B31L018 08/20/2023

71111.20 Work Orders 69284233 B31L018 - Weld Repair (Socket) 08/21/2023

71111.20 Work Orders 69289464 Installation and Removal of Jet Pump Nozzle Plugs 08/22/2023

71111.20 Work Orders 69301002 Replace S1 and S2 Keylock Switches, EPA Breaker, GE 08/23/2023

Cable Assembly and Tefzel Wiring of RPS 'B'

71111.20 Work Orders 69301002 Replace S1 and S2 Keylock Switches, EPA Breaker, GE 08/23/2023

Cable Assembly and Tefzel Wiring of RPS 'B'

71111.20 Work Orders 69372412 Leak From GSW Header on TB1 East Aisle/Temp Repair 08/31/2023

71111.24 Corrective Action 202332470 Signs of Recirc Sample Line Movement in Pipe Guides 09/07/2023

Documents

71111.24 Corrective Action 202332513 RF22 Work Request - Address 6DI-B31-7255-1 RRC Chem 09/07/2023

Documents Sample Line Vibration

71111.24 Miscellaneous 8MNGTAW/SMAW ASME Section IX Welding Procedure Specification 18

71111.24 Miscellaneous TEB3123-057 Justify Continued Operation until RF22 After Leak 0

Restoration at Reactor Recirculation Header B31L018

71111.24 Procedures 24.307.16 Emergency Diesel Generator 13-Start and Load Test 61

71111.24 Procedures 24.307.37 DGSW, DFOT, and Starting Air Operability Test-EDG 14 64

71111.24 Procedures 64991108 Perform 24.307.16 Sec. 5.2 EDG 13 Start and Load 09/14/2023

Test-Fast Start

71111.24 Work Orders 64556944 Perform 24.307.37 Sec. 5.1 & 5.2 DGSW & DFOT 08/15/2023

Pump/VLV Operability Test-EDG 14

71111.24 Work Orders 69274384 Repair Leak on RR Sample Line Tap 08/30/2023

71124.07 Corrective Action 1026965 Commitment Tracking CARD for NEI 07-07 08/11/2010

Documents

71124.07 Corrective Action 2124718 Vendor Incorrectly Processed Radiological Environmental 05/28/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Monitoring (REMP) Samples Prior to Analysis

71124.07 Corrective Action 2124831 Instrument QC Check Performance Not in Line with MCE04 06/02/2021

Documents Requirements

71124.07 Corrective Action 2124876 REMP Samples Mislabeled 06/03/2021

Documents

71124.07 Corrective Action 202331933 Minor Administrative Typographical Errors in 2022 AREOR 07/27/2023

Documents

Resulting from

Inspection

71124.07 Corrective Action 202331939 Evaluate Improvements to the REMP Air Sampling 07/27/2023

Documents Enclosures Located Outside the Protected Area

Resulting from

Inspection

71124.07 Corrective Action 202331940 Provide Enclosure for REMP TLD Locations Outside the 07/27/2023

Documents Protected area

Resulting from

Inspection

71124.07 Miscellaneous 2021 Annual Annual Radioactive Effluent Release Report for the Period 2021

Radioactive of January 1, 2021 through December 31, 2022

Effluent Release

Report

71124.07 Miscellaneous 2021 Annual Annual Radiological Environmental Operating Report for 2021

Radiological the Period of January 1, 2021 through December 31, 2021

Environmental

Operating Report

71124.07 Miscellaneous 2022 Annual Annual Radioactive Effluent Release Report for the Period 2022

Radioactive of January 1, 2022 through December 31, 2022

Effluent Release

Report

71124.07 Miscellaneous 2022 Annual Annual Radiological Environmental Operating Report for 2022

Radiological the Period of January 1, 2022 through December 31, 2022

Environmental

Operating Report

71124.07 Miscellaneous NAQA232022 Audit Report for the DTE Audit of Environmental Dosimetry 05/23/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

Company (DTE Audit No. 23001)

71124.07 Miscellaneous Technical Offsite Dose Calculation Manual 26

Requirements

Manual Volume II

Offsite Dose

Calculation Manual

71124.07 Procedures 62.000.301 Low Flow Groundwater Sampling 8

71124.07 Procedures 62.000.302 Groundwater Gauging 3

71124.07 Procedures MES68 Groundwater Protection Program Structures, Systems, and 22C

Components Review

71124.07 Procedures MRP30 Integrated Groundwater Protection Program 7

71124.07 Procedures WIRPT011 Work Instruction for Voluntary Groundwater Reporting 2

Requirements

71124.07 Self-Assessments 2022 Annual GEL Laboratories Quality Assurance Review 03/17/2023

Quality Assurance

Report for the

Radiological

Environmental

Program (REMP)

71124.07 Self-Assessments NPRP230014 Quick Hit Self-Assessment: Radiological Environmental 03/23/2023

Monitoring Program

71124.07 Work Orders 57285529 Perform 67.000.104 Review of Site Map Showing Areas for 11/10/2021

Handling Licensed Material

71124.07 Work Orders 62:000:210 Water Sampler Weekly Flow Check and Preventive 07/03/2023

Maintenance for June of 2023

71124.07 Work Orders 64012645 Perform 64.713.019 Att. 17 Gaseous Effluent Cumulative 06/19/2023

and Projected Dose (Monthly)

71151 Corrective Action 202333161 NRC Identified - August 2022 RHR/RHRSW/MDCT 09/19/2023

Documents Performance Indicator (Unavailability) Report

Resulting from Discrepancies

Inspection

71151 Miscellaneous Selected Operators' Narrative Logs Various

71151 Miscellaneous RHR Performance Indicators Various

71151 Miscellaneous RCIC Performance Indicators Various

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Work Orders 61351087 Perform 44.020.232 NS4 RCIC Steam Line Flow, Trip Sys 11/03/2022

B, Functional Test

71151 Work Orders 63562414 Perform 44020.231 NS4 RCIC Steam Line Flow, Trip Sys 05/09/2023

A, Functional Test

71152A Corrective Action 202330775 RCE 23-22040-Speed Switch Drawing Corrections 06/13/2023

Documents

71152A Corrective Action 2322040 Lost Indication of D MDCT Fan in High-Speed 03/17/2023

Documents

71152A Drawings 4M7216067-2 RHR Complex Cooling Tower Fan Overspeed Brake A

Installation Sheet 3 of 4

71152A Drawings 5E7216001-02 Wiring Diagram RHR Complex Division 2 Cooling Towers A

Fan Overspeed Brake System

71152A Engineering 80072 MDCT Fan Brake Overspeed Circuit Design Change D

Changes

71152A Miscellaneous Purchase Order Change 03/16/2012

71152A Miscellaneous Purchase Order Change 07/13/2019

71152A Miscellaneous P1 Quality Assurance Procurement Specification-Nuclear N

Safety-Related

71152A Procedures MES07 Review, Approval, and Control of Vendor Design 19

Documents

71152A Procedures MES90 Standard Design Process Interface 1

71152A Procedures MMA11 Post-Maintenance Testing Guidelines 27

71152A Procedures MMM02 Procurement Process 19

71152A Procedures MMM11 Dedication of Commercial Grade Items 18A

29