IR 05000341/2023004

From kanterella
Jump to navigation Jump to search
Integrated Inspection Report 05000341/2023004
ML24031A549
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/05/2024
From: Billy Dickson
NRC/RGN-III/DORS/RPB2
To: Peter Dietrich
DTE Electric Company
References
EA-23-091, EA-23-067
Download: ML24031A549 (1)


Text

SUBJECT:

FERMI POWER PLANT, UNIT 2-INTEGRATED INSPECTION REPORT 05000341/2023004

Dear Peter Dietrich:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On January 17, 2024, 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.

Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

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

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.

February 5, 2024 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, Billy C. Dickson, Jr., 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:

NPF-43

Report Number:

05000341/2023004

Enterprise Identifier:

I2023004-0051

Licensee:

DTE Electric Company

Facility:

Fermi Power Plant, Unit 2

Location:

Newport, MI

Inspection Dates:

October 01, 2023 to December 31, 2023

Inspectors:

R. Cassara, Resident Inspector

J. Gewargis, Resident Inspector

G. Hansen, Sr. Emergency Preparedness Inspector

J. Masse, Resident Inspector

R. Ng, Senior Project Engineer

J. Reed, Health Physicist

G. Roach, Senior Operations Engineer

T. Taylor, Senior Resident Inspector

T. Wingfield, Operations Engineer

Approved By:

Billy C. Dickson, Jr., 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

Division 1 Emergency Equipment Cooling Water/Service Water (EECW/EESW) Heat Exchangers Found Above Operability Limit Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300401 Open/Closed

[H.1] -

Resources 71111.07A A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50,

Appendix B, Criterion XI, Test Control, occurred when the licensee failed to implement an appropriate test program for the EECW/EESW heat exchangers (HXs). The licensee did not have test procedures for the HXs which incorporated requirements and acceptance limits contained in applicable design documents. Additionally, the licensee did not evaluate test results associated with the C EECW HX to ensure that test requirements were satisfied following a surveillance test on August 31, 2022.

Failure to Identify Conditions Adverse to Quality Associated with Gear Reducer Foot Supports for the Mechanical Draft Cooling Towers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300403 Open/Closed

[H.12] - Avoid Complacency 71152A A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50,

Appendix B, Criterion XVI, "Corrective Actions," occurred when the licensee failed to promptly identify conditions adverse to quality (CAQs) associated with the mechanical draft cooling tower (MDCT) fan gear reducer pedestal supports. Specifically, the licensee failed to identify the gear reducer feet were nonconforming with respect to design requirements for the MDCTs and that the deficient corroding foot support for the 'D' MDCT was not entered into the corrective action program (CAP).

Vibration-Induced Fatigue Failure Results in Pressure Boundary Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000341/202300404 Open/Closed None (NPP)71152A A Green finding with an associated non-cited violation of 10 CFR 50, Appendix B, Criterion III,

"Design Control," was self-revealed on August 20, 2023, when reactor coolant pressure boundary leakage was discovered coming from the 'B' reactor recirculation loop chemistry sampling line inside the drywell. The licensee identified this location as being susceptible to fatigue failure in 2000 but did not monitor or evaluate the issue further.

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 Closed URI 05000341/202300402 Access Control for Locked High Radiation Area 71151 Open URI 05000341/202300303 Mechanical Draft Cooling Tower 'D' Inoperable due to High Vibrations 71152A Closed

PLANT STATUS

Fermi Unit 2 began the inspection period at or near 100 percent power. On November 10, 2023, the plant reduced power to approximately 72 percent for routine maintenance and surveillances.

The plant was returned to 100 percent power on November 12, 2023, and 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

71111.01 - Adverse Weather Protection

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

(1) The inspectors evaluated readiness for seasonal extreme winter weather for the following systems:

circulating water, residual heat removal service water (RHRSW), general service water, 120 kV switchyard, 345 kV switchyard, auxiliary boiler, circulating water deicing system, and the condensate storage tank completed on December 13, 2023

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1) Division 1 residual heat removal (RHR) system following the RHR safety system outage during the week ending on October 21, 2023
(2) Standby liquid control system on November 28, 2023

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

(1) Division 1 emergency equipment cooling water/service water (EECW/EESW) heat exchangers following unexpectedly high differential pressures from May 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam and the biennial written examinations administered between September 28, 2023, and November 21, 2023.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on September 28, 2023.

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

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

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

Remedial Training and Reexaminations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of reexaminations for licensed operators who did not pass a required requalification examination.

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

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

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 the planned down power for main steam line isolation valve functional surveillances on November 10, 2023

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

(1) The inspectors observed and evaluated a control room simulator scenario associated with the annual requalification exam on November 7, 2023
(2) The inspectors observed and evaluated training on abnormal operating procedures associated with shutdown cooling the week ending on November 25, 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) Reactor water cleanup (RWCU) system completed the week ending on November 18, 2023
(2) RHRSW complex heating, ventilation, and air conditioning (HVAC) hydramotors and dampers completed the week ending on December 9th, 2023
(3) High pressure coolant injection (HPCI) system completed the week of December 31, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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) Motor control center 72F5A position 1B bucket repair concurrent with the division 2 control center (CC)HVAC fan belt repairs during the week ending on October 28, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

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

(1) HPCI and reactor core isolation cooling (RCIC) steam isolation logic power inverter failure during the week ending on August 12, 2023
(2) Diesel fire pump (DFP) failure to start due to low cold crank amperage from the starting batteries on November 29, 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) (10 Samples)

(1) RHRSW and EESW piping hydrostatic pressure test during the week ending on October 21, 2023
(2) Division 2 EECW pump room cooler fan belt inspection, tensioning, and alignment during the week ending on October 28, 2023
(3) Division 2 CCHVAC inspection, fan belt replacement, tensioning, and alignment due to fan vibrations during the week ending on October 28, 2023
(4) Division 2 non-interruptible air system power panel inspections and restoration during the week of November 4, 2023
(5) Division 1 CCHVAC makeup radiation monitor calibration functional surveillance after replacement of the radiation monitor pump completed on November 22, 2023
(6) Emergency diesel generator (EDG) 11 diesel room return air damper temperature controller and hydramotor replacement completed on November 27, 2023
(7) EDG 14 jacket coolant pump replacement, operational run and leak check due to pump leakage completed on November 27, 2023
(8) Average power range monitor (APRM) 3 communication card troubleshooting, and replacement completed on November 27, 2023
(9) RCIC safety system outage completed on December 1, 2023
(10) Division 2 EESW safety system outage completed on December 11, 2023

Surveillance Testing (IP Section 03.01) (2 Samples)

(1) Recirculation loop 'A' drive flow to suction flow ratio degradation during the week ending on October 28, 2023
(2) EDG14 slow speed start surveillance completed the week of November 25, 2023

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) FLEX diesel full load test completed on November 24, 2023

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.0102.04) (1 Sample)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:
  • Annual siren inspection and maintenance records for the period from September 2021 to September 2023
  • Monthly alert notification system (siren) tests for the period from September 2021 to September 2023

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.0102.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.0102.03) (1 Sample)

(1) The inspectors completed the review and evaluation of emergency action level (EAL)and Emergency Plan changes on December 1, 2023. For the inspection period from July 01, 2022 through June 30, 2023, the licensee did not make any changes to the site Emergency Plan and EAL Bases/Matrix documents. The inspectors independently reviewed the current revisions of these documents to verify no changes were completed.

This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

The inspectors evaluated:

(1) Tabletop drill conducted on October 26, 2023
(2) Tabletop drill conducted on November 2,

RADIATION SAFETY

71124.03 - InPlant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Control room emergency filtration system

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

The technical details for an atpower drywell entry under Radiation Work Permit (RWP) 231029 titled, "DW / RBST Emergent Work," were reviewed as referenced in the Biennial Problem Identification and Resolution inspection report 05000341/2023010 (ADAMS Accession ML23340A032).

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

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

External Dosimetry (IP Section 03.02) (1 Sample)

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

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Internal Dose Assessment 52572
(2) Internal Dose Assessment 94872

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

The inspectors evaluated the following special dosimetric situations:

(1) Declared Pregnant Worker (DPW) from January 2022
(2) DPW from March

OTHER ACTIVITIES-BASELINE

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

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

(1) July 1, 2022 through September 30, 2023

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

(1) July 1, 2022 through September 30, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1) July 1, 2022 through September 30, 2023

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) July 1, 2022 through June 30, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
(1) July 1, 2022 through June 30, 2023 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
(1) 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 CAP related to the following issues:

(1) The inspectors reviewed the licensee's response to reactor coolant pressure boundary leakage from sample line CT B310L018 inside the drywell. The inspectors reviewed the licensee's root cause evaluation as part of the sample.
(2) The inspectors reviewed the licensee's adherence to CAP procedures with regard to anonymous condition report.
(3) The inspectors reviewed the licensee's corrective action in response to the failure of the 'D' mechanical draft cooling tower (MDCT) due to a sheared bolt on the gear reducer pedestal. As part of the sample, the inspectors reviewed licensee's causal evaluation for the MDCT and past condition reporting relating to the equipment reliability and health the MDCTs.

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Division 1 Emergency Equipment Cooling Water/Service Water (EECW/EESW) Heat Exchangers Found Above Operability Limit Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300401 Open/Closed

[H.1] -

Resources 71111.07A A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, occurred when the licensee failed to implement an appropriate test program for the EECW/EESW heat exchangers (HXs). The licensee did not have test procedures for the HXs which incorporated requirements and acceptance limits contained in applicable design documents. Additionally, the licensee did not evaluate test results associated with the C EECW HX to ensure that test requirements were satisfied following a surveillance test on August 31, 2022.

Description:

On May 31, 2023, the licensee performed a surveillance test on division 1 of the safety-related EESW system with the A HX in service. Each division of EESW has two plate and frame HXs, one valved in and ready for use, the other isolated and in standby. The EESW is used to cool the safety-related EECW closed cooling water system via the heat exchanger and is only periodically run unless accident conditions exist. The measured differential pressure (dP) for A heat exchanger exceeded the operability limit of 10.18 psid (11.04 psid). When the C HX for division 1 was placed in service so A could be isolated and cleaned, the licensee discovered it was also above its operability limit of 10.14 psid (10.73 psid). While maintaining the system with the C HX in service, the licensee inspected and cleaned the A HX. Corrosion deposits had accumulated on the inlet of the HX and were obstructing some of the channels. The licensee cleaned the plates, and the HX was made available for operation.

Meanwhile, the C HX dP had increased to approximately fourteen psid. During the investigation and repair attempts, the licensee requested a Notice of Enforcement Discretion (NOED) from the NRC, documented in EA-23-067, ML23157A026 and ML23158A133.

Subsequently, enforcement discretion was not required, as the licensee was able to restore the system to an operable status with a clean A HX within the 72-hour completion time allowed by the technical specifications. When the licensee placed the A HX in service, the dP had returned to normal levels with no adverse trends. The licensee then inspected and cleaned the C HX, which had similar amounts of debris. When the licensee tested the C HX later, the dP had also returned to normal levels. Based on the NOED request, the NRC performed inspection procedure 71153, as documented in inspection report 05000341/2023002. The NRC also opened and discussed an unresolved item (URI)associated with the inoperable HXs in inspection reports 05000341/2023002 and 05000341/2023003, respectively, pending review of the licensee's completed root cause evaluation.

The licensee had replaced the original shell and tube HXs for the EECW/EESW system with plate and frame HXs (one per division) in 2000. Between 2000 and 2006, the licensee noted that the plate and frame HXs were much more susceptible to plugging due to the small fluid channels, especially on the EESW side, because it was an open system. Recognizing that the heat exchanger may require more frequent maintenance, a backup HX was installed in each division in 2006. Additionally, a design calculation, DC6286, EECW HX Performance Requirements with Plugging, Volume 1, was implemented that acknowledged the susceptibility to plugging and established measurable criteria important to support thermal performance, one of which was an assumed maximum rate of plugging. The licensee established Procedures 47.207.01 and 47.207.02 to measure the plugging rate periodically.

Surveillance procedures 24.208.02 and 24.208.03 also measured the dP across the HXs while testing other system components. The licensee established a dP maintenance limit so the operators could take action to swap to the clean backup HX while scheduling work to isolate and clean the inservice HX. The licensee established an operability limit to alert operators that an HX could no longer perform its safety functions for a presumed 100-day post-accident mission time. Performance of the above procedures and evaluation of the results ensured that the assumptions in DC6286 remained met and that the operators could take proactive action to maintain an operable HX in each division.

In 2015, the licensee canceled procedures 47.207.01 and 47.201.02 under the incorrect assumption that the plugging rate would still be calculated and evaluated in the surveillance procedures 24.208.02 and 24.208.03. However, the surveillance procedures did not contain steps to calculate the plugging rates. Therefore, since 2015, the assumed plugging rate was not formally checked and evaluated against the limit established in DC6286. Licensee investigation revealed that after 2015, the system/strategic engineers informally kept tabs on the dP trends and prompted the organization to swap and clean HXs when they determined it was necessary.

The licensees inspection of the A and C HXs revealed that a buildup of corrosion products in the HXs caused the high dPs on May 31, 2023. The corrosion products were typical of what had been found during routine cleanings and consisted mainly of non-biologic deposits from the inside walls of the EESW carbon steel piping. However, in this case, the deposits had accumulated much more rapidly. A HX would typically be in service for 24 years before reaching the maintenance limit. As discussed below, both Division 1 HXs reached their maintenance limits within six months. During the spring 2022 refueling outage, the licensee replaced the division 1 EESW system underground piping between the residual heat removal/service water complex and the reactor building. The evaluation ruled out the new piping as a source and concluded that the corrosion deposits were from existing (i.e.,

non-replaced) EESW piping. The evaluation determined that two phenomena contributed to the large, rapid release of corrosion products.

During the pipe replacement project, a 120-foot-long section of original piping, common to the inlets of the A and C HXs, remained drained for most of the refueling outage in the reactor building. In consultation with industry experts, the licensee determined that, eventually, the pipe dried out and allowed existing tubercles to become brittle, cracked, and relatively easy to remove. When the operators restored the system, corrosion products were flushed and accumulated in the C HX. While the initial dP reading at the end of the refueling outage in June 2022 was normal, the following reading in August 2022 was 0.77 psid higher, indicating an increase of nearly twice the rate assumed in the design calculation. While below the maintenance limit, the data was not reviewed nor trended by engineering following the test, so the licensee did not recognize the increase outside the assumptions of DC6286. The root cause evaluation determined that a poor turnover and a large number of systems to monitor, per engineer, contributed to the lack of sensitivity to the data within engineering. The heat exchanger exceeded the maintenance limit when the operators measured the dP in December 2022 (approximately six months with C in service). At this point, plant staff reviewed the August 2022 data for the first time but did not realize the adverse trend in dP and the abnormally short time to reach the maintenance limit.

The evaluation attributed the other contributor to the significant release of corrosion products to a change in the type of corrosion inhibitor used. In December 2022, the licensee added a new inhibitor to the system via the ultimate heat sink reservoir. In consultation with industry experts, the licensee determined that newly exposed corrosion layers/piping, due to the dry-out phenomena, came in contact with this different chemical, which could also lead to the release of corrosion products. After the maintenance limit was reached for the C HX, despite the direction of the surveillance test procedure to place the clean, spare HX in service, the C HX remained in service for approximately one month. The licensee believes the remaining corrosion products, due to dry-out, continued to plug the HX during this time. The licensee lined up the A HX for service in January 2023 but did not schedule the C HX for cleaning, contrary to work prioritization guidelines. As a result, when the A HX reached the operability limit in May of 2023, a clean C HX was unavailable for service. For the A HX, the licensee concluded that the new chemical prompted the release of more corrosion products, which contributed to plugging the A HX between January and May 2023. While the January and March 2023 dPs for the A HX appeared normal, the new chemical was reacting with the pipe wall/newly exposed corrosion layers. Eventually, it caused a burst of corrosion products to be released, resulting in the operability limit being exceeded for A after only five months of service. Since C had not been cleaned when the operators placed it in service, this operation exposed this heat exchanger to remaining corrosion products released from the chemical interaction. This condition resulted in the 'C' HX exceeding its operability limit simultaneously as A.

Corrective Actions: The licensee cleaned the 'A' and 'C' HXs, confirmed the dP trends were normal, and performed a root cause evaluation.

Corrective Action References: CR 202330619

Performance Assessment:

Performance Deficiency: 10 CFR 50, Appendix B, Criterion XI, "Test Control," requires that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents. Licensee calculation DC6286 identifies system parameters necessary to ensure that the EESW/EECW HXs remain operable, which include an assumed rate of plugging. By eliminating test procedures that verified the plugging rate, and not evaluating test data that revealed abnormal rates of plugging, the licensee failed to meet the requirements of 10 CFR 50, Appendix B, Criterion XI. As a result, degraded conditions were not recognized, and action not taken to ensure one of the two HXs remained operable in division 1 of the EESW system.

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, the failure to monitor and evaluate system performance against design criteria important to operability of the EESW/EECW HXs resulted in both HXs in division 1 becoming inoperable at the same time.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, all questions in Exhibit 2 were answered 'no.' The inspectors reviewed the licensee's evaluation and determined given the assumed conditions in the EESW system, division 1 EESW would have still been able to perform its PRA functions for the PRA mission time.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

Specifically, poor turnover between strategic engineers and ownership of a large number of systems to monitor were contributors to not properly evaluating the EESW system data.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion XI, "Test Control," states, in part, a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents. Further, test results will be evaluated to assure that test requirements have been satisfied.

Contrary to the above, from approximately 2015 through June 3, 2023, a testing program that ensures all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service was not established and the test results were not evaluated.

Specifically, the licensee did not have test procedures for the EESW/EECW HXs which incorporated requirements and acceptance limits contained in applicable design documents.

Additionally, the licensee did not evaluate test results associated with the C EECW heat exchanger to ensure that test requirements were satisfied following a surveillance test on August 31, 2022.

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

The disposition of this finding and associated violation closes URI: 05000341/2023002-01.

Unresolved Item (Closed)

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:

A finding/violation was identified as described above.

Corrective Action Reference(s): 202330619 Unresolved Item (Open)

Access Control for Locked High Radiation Area URI 05000341/202300402 71151

Description:

NRC inspectors reviewed condition report CR202332737, titled Locked High Radiation Area door was unsecured. The condition report described a locked high radiation area (LHRA) access control guard who left their position for approximately 30 minutes on August 31, 2023. Discussions with the licensee have led to the following understanding of the event.

On August 31, 2023, Fermi Unit 2 was in planned outage 2301. The Unit 2 drywell had radiological conditions requiring controls from Fermi Unit 2 Technical Specifications 5.7.1 and 5.7.2. The drywell personnel hatch, which is normally locked and posted as a LHRA, was unlocked and had a rope across the door with a LHRA posting on the rope. To gain access to the personnel hatch, individuals had to first pass through an electronic turnstile that was programmed to allow access via use of only Radiation Work Permit (RWP) 231033, titled Planned outage 23-01. After proceeding through the electronic turnstile, a high radiation area (HRA) swing gate was present with a carbineer to secure access. An individual would then be able to approach the drywell personnel hatch.

The LHRA access control guard was stationed between the electronic turnstile and the HRA swing gate. The responsibilities of the door guard were described in station procedure 68.000.004, revision 3, titled RADIOLOGICAL POSTING AND LABELING (NISP-RP-04).

The LHRA access control guard left their post at approximately 16:00 after a discussion with a Foreign Material Exclusion (FME) monitor. The LHRA access control guard misunderstood what the FME monitor stated and assumed they were able to leave their post. The licensee verified that no unauthorized access to the LHRA was made by reviewing the electronic turnstiles access logs.

Fermi Unit 2 Technical Specification Section 5.7.2 says in part Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for individuals in those areas. The licensees position is that the periods of access was characterized as the duration of planned outage 2301. Consequently, the licensee considers requirements of Fermi Unit 2 Technical Specification Section 5.7 were followed during the event.

Planned Closure Actions: This issue requires further review and evaluation by NRC staff related to the licensees interpretation and implementation of Fermi Technical Specification 5.7 in lieu of requirements in 10 CFR 20.1602 Control of access to high radiation areas.

This issue is unresolved pending the NRCs review and evaluation.

Licensee Actions: The licensee has revised the access control guard briefing form in procedure 68.000.04 and developed a LHRA control plan for future outages.

Corrective Action References: CR202332737 Failure to Identify Conditions Adverse to Quality Associated with Gear Reducer Foot Supports for the Mechanical Draft Cooling Towers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300403 Open/Closed

[H.12] - Avoid Complacency 71152A A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," occurred when the licensee failed to promptly identify conditions adverse to quality (CAQs) associated with the mechanical draft cooling tower (MDCT) fan gear reducer pedestal supports. Specifically, the licensee failed to identify the gear reducer feet were nonconforming with respect to design requirements for the MDCTs and that the deficient corroding foot support for the 'D' MDCT was not entered into the corrective action program (CAP).

Description:

The plant's safety-related ultimate heat sink (UHS) comprises of two large reservoirs (one for each division) of treated water that accept rejected heat from safety-related heat loads. Each of these reservoirs is equipped with two MDCTs, two per division. The MDCTs contain a fan, gear reducer, shaft, and motor for forced draft convection of the heat rejected from the safety-related heat loads. These components are all required to be operable for the associated division of the UHS to be operable. The MDCT components are regularly inspected to monitor equipment conditions.

On March 7, 2019, as part of a system review for the UHS, the site determined that the regularly scheduled inspection of the MDCTs needed additional details to inspect the gear reducers and gear reducer feet specifically. The specific instructions, or the technical requirements, of the preventative maintenance items for inspecting the MDCTs were updated for all the MDCT to include inspections of the gear reducer and gear reducer feet conditions.

However, the jobs plan, which implements the inspection for each specific MDCT was not all updated with the new inspection requirements. The job plans for the work orders of the Division 1 ('A' and 'C') MDCTs were updated with the new technical requirements, but the licensee did not the update work order job plans for the Division 2 ('B' and 'D') MDCTs with the new technical requirements.

On July 18, 2023, the licensee was running the 'D' MDCT fan at high speed for routine cooling of the residual heat removal (RHR) reservoir when the fan unexpectedly tripped. The licensee restarted the fan, which ran at high speed, and subsequently tripped after one minute of running. The licensee's investigation revealed a sheared-off mounting bolt on a front support foot of the 'D' MDCT gear reducer, and the rubber bushings on the gear reducer coupling were also damaged. In response to the failure, the licensee requested and received a Notice of Enforcement Discretion (NOED), documented in EA23091, ML23206A127, to support repair efforts of the front foot bolt beyond the technical specification required action time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an inoperable UHS. The licensee repair efforts replaced the degraded bolt portion with a new bolt that was welded to the non-corroded portion of the old support bolt. An NRC identified issue specific to the repair was documented in inspection report 05000341/2023003, ML23304A155.

While investigating the cause of the corroded and sheared bolt, the licensee determined the MDCT gear reducer front foot supports were not in compliance with design drawing C-N6004. Specifically, CN6004 requires a 1-inch-grout pad as the support material for the front foot of each MDCT gear reducer. However, the supports for the front feet were primarily composed of metal shims in place of some of the grout, reducing the amount of support underneath. The shims' corrosion compounded the lack of support. Also, despite inspections performed on the 'A' and 'C' feet on February 9, 2021, and February 11, 2021, respectively, the nonconformance was not recognized even though the licensee noted the corroded/deficient shims were noted while inspecting per the updated technical requirements from the system review.

Regarding the 'D' MDCT, steps to inspect the gear reducer feet per the updated technical requirements during the inspection performed on September 9, 2020, were inadvertently omitted from the implementing WOs due to the failure to update the WO job plans for the Division 2 ('B' and 'D') MDCTs. Therefore, neither the nonconformance nor the deficient condition of corroding supports were dispositioned in the CAP or identified as CAQs for the

'D' MDCT gear reducer feet. Overall, from February 11, 2021, to July 18, 2023, the nonconformance of all MDCT gear reducer feet was not discovered nor entered into the CAP and identified as CAQs. The licensee did not enter the corroded condition for the 'D' MDCT into the CAP, nor was it also recognized as a CAQ. The 'D' MDCT fan failed on July 18, 2023, due to excessive vibrations caused by deficient and nonconforming gear reducer feet.

After the licensee completed repairs for the 'D' MDCT foot, the licensee performed inspections of the 'C' and 'A' gear reducers during the week of October 30, 2023, and November 6, 2023, respectively. To complete the inspections on the 'A' and 'C' MDCTs, the licensee requested and received a onetime exigent license amendment found in ML23243A885 and ML23297A051. While the bolts were intact, the licensee noted some plastic deformation (i.e., stretching). The licensees investigation concluded that a lack of proper support caused by the design nonconformance, and the shims' corrosion led to excessive gear reducer movement, which impacted the bolts on the 'A,' 'C,' and 'D' MDCTs.

Unlike MDCTs 'A,' 'C,' and 'D,' the licensee replaced 'B' MDCT pedestal foot since the plant's original construction and will be inspected in the upcoming refueling outage.

Corrective Actions: The licensee repaired 'A,' 'C,' and 'D' MDCT gear reducer supports and initiated corrective actions to review the inspection and maintenance strategies for the MDCT fan components. The 'B' MDCT pedestal will be inspected and repaired as necessary in the upcoming refueling outage in the spring.

Corrective Action References: CR202331630

Performance Assessment:

Performance Deficiency: The licensee's failure to promptly identify conditions adverse to quality, such as nonconformances and deficiencies in accordance with 10 CFR 50, Appendix B, Criterion XVI, was a performance deficiency. Specifically, the licensee failed to identify the that the use of shims in place of grout for the gear reducer front foot supports was a nonconforming condition on all the MDCTs. Further, corrosion on the MDCT 'D' front foot support was never identified and entered into the CAP.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to promptly identify the design nonconformance and degraded gear reducer supports as CAQs allowed the 'D' bolt to shear and the 'A' and 'C' bolts to plastically deform.

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 finding was screened to Green (very low safety significance) because all the questions in IMC 0609, Appendix A, Exhibit 2A, "Mitigating Systems Screening Questions:

Mitigating SSCs and PRA Functionality" were all answered No. More specifically, the PRA function is maintained with one MDCT functional per division, leading to all the questions being answered No.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. More specifically, there was opportunity in 2021, when the 'A' and 'C' MDCT corroded, feet were discovered to more thoroughly review for the possibility of latent issues and possibility of mistakes with respect to a more robust extent of condition.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, measures be established to ensure that conditions adverse to quality, such as deficiencies and nonconformances, are promptly identified.

Contrary to the above, from February 11, 2021, to July 18, 2023, the licensee failed to promptly identify deficiencies and nonconformances associated with mounting feet for the MDCT gear reducers. Specifically, the licensee failed to recognize that the MDCTs grout pads were not in conformance with their design. Instead of a solid block of grout for the feet to be bolted to, as depicted on design drawing CN6004, corroded shims were found embedded in the grout, reducing the effective volume of grout. The nonconformances were not entered in the CAP or determined to be CAQs. In addition, deficiencies of the 'D' MDCT gear reducer feet were never documented in the CAP or dispositioned as a CAQ.

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

The disposition of this finding and associated violation closes URI: 05000341/2023003-03.

Vibration-Induced Fatigue Failure Results in Pressure Boundary Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000341/202300404 Open/Closed None (NPP)71152A A Green finding with an associated non-cited violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," was self-revealed on August 20, 2023, when reactor coolant pressure boundary leakage was discovered coming from the 'B' reactor recirculation loop chemistry sampling line inside the drywell. The licensee identified this location as being susceptible to fatigue failure in 2000 but did not monitor or evaluate the issue further.

Description:

During the current operating cycle on June 10, 2022, the licensee noted an initial increase in drywell unidentified leakage. Leakage was approximately 0.12 gallons per minute (gpm).

Technical specification (TS) limits for reactor coolant system leakage are five gpm for unidentified leakage, less than 25 gpm total leakage averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and less than a 2 gpm increase in unidentified leakage over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Leakage trended upward, reaching a value of approximately 0.50 gpm on June 26, 2023. The licensee developed operational decision-making guidance and continued investigating potential sources of the leakage.

Drywell unidentified leakage continued to rise, reaching a value of approximately 2.25 gpm on August 18, 2023. At that point, the licensee decided to reduce power to roughly 23 percent to send personnel into the drywell to search for the leak location. To facilitate more search time while remaining at power, the licensee submitted a license amendment request to extend the completion time of TS Limiting Condition of Operation (LCO) 3.6.3.1 Condition A from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. LCO 3.6.3.1 limits oxygen concentration in the drywell at power (the drywell is normally inerted with nitrogen). The NRC approved the request. Relevant correspondence is documented in ADAMS under ML23229A012.

On August 19, 2023, the licensee performed a reactor down power. Between August 19 and August 20, the licensee made several entries into the drywell to identify the leak location.

Plant staff observed leakage from higher elevations in the drywell above the 'B' recirculation pump. However, due to elevated neutron dose rates since the plant was still at power, personnel could not perform a thorough search for the exact leak location at the higher elevations. Based on that, operators shut down the plant at 1438 on August 20 so plant staff could search the higher elevations. At 1600, the licensee discovered the leakage from CT B31L018, the 3/4-inch sampling line connection to the 'B' recirculation loop 22" manifold.

The leak came from a crack at the toe of the socket weld. The licensee assessed repair options allowed by the ASME code and decided to transition the plant to cold shutdown to affect repairs. The licensee performed the repairs and assessed wetted equipment in the drywell. The plant returned to full power on September 9, 2023.

The inspectors reviewed the licensee's root cause evaluation, which described several documented leaks from small-bore piping in the drywell due to fatigue failure early in the plant's operational history. In 2000, the licensee generated a corrective action program document, CARD 0010008, documenting the history of those leaks and the operating experience of similar leaks at other plants. The licensee's investigation in CARD 0010008 examined the susceptibility of existing piping in the drywell to fatigue failure. References were made to modifications performed to address the potential for fatigue failure on some lines and explained how some utilized flexible connections to address the potential for fatigue failure.

Based on their configuration, the CARD also pointed out existing lines particularly susceptible to fatigue failure, including CT B31L018. UFSAR Section 3.9, Mechanical Systems and Components describes design requirements for small-bore piping connected to certain systems, including the reactor recirculation system. Specifically, it is stated that no damage (such as fatigue failure) is to occur where small-bore piping attaches to the larger piping.

Despite internal and external operating experience supporting the licensee's assessment that line CT B31L018 was susceptible to fatigue failure, the licensee took no action to evaluate the line further or ensure it would satisfy the design requirements regarding fatigue failure.

Corrective Actions: The licensee repaired the connection in accordance with the ASME code and performed a root cause evaluation.

Corrective Action References: CR202332454

Performance Assessment:

Performance Deficiency: 10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, the licensee provide for verifying or checking the adequacy of design. UFSAR Section 3.9, Mechanical Systems and Components, requires that small-bore piping attached to larger piping (such as reactor recirculation piping) will not cause damage due to fatigue failure. When the licensee identified a small-bore pipe connected to the reactor recirculation system that was susceptible to fatigue failure, no action was taken to further assess the pipe.

Therefore, the failure to take any action to verify the adequacy of the design is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to verify the adequacy of design of a small-bore pipe connected to the reactor recirculation system resulted in a reactor coolant pressure boundary leak.

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 answered 'no' to questions 1 and 2 of Exhibit 1, Section A. The leakage rate expected from a failure of the small-bore pipe would be within the capacity of normal reactor coolant makeup sources (i.e., the control rod drive system).

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

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, the licensee provide for verifying or checking the adequacy of design.

TS 3.4.4 requires there to be no leakage from the reactor coolant system pressure boundary in Modes 1, 2, and 3. The TS action statement requires that if pressure boundary leakage exists, be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Contrary to the above, from December 4, 2000 through September 7, 2023, the licensee failed to verify or check the adequacy of design of the B recirculation loop tap CT B31L018.

UFSAR Section 3.9.1.1.3 requires, in part, safety-related small-bore piping, such as CT B31L018, be designed such that there will be no damage, such as fatigue failure, to the primary system at junctions with large piping. CARD 0010008 documented several industry and Fermi-specific fatigue failures of small-bore piping that resulted in reactor coolant pressure boundary leakage. CARD 0010008 concluded that line CT B31L018 was particularly susceptible to fatigue failure due to its size reduction near the large piping connection. Despite the design requirements and operating experience regarding fatigue failure, no action was taken to validate whether, in fact, the line would be subject to fatigue failure. Further, no action was taken to modify the design, as had been done for other susceptible small-bore piping components. In addition, between approximately June 10, 2022, and August 21, 2023, reactor coolant pressure boundary leakage existed, and the plant was not placed in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> nor Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

Unresolved Item (Closed)

Mechanical Draft Cooling Tower 'D' Inoperable due to High Vibrations URI 05000341/202300303 71152A

Description:

A finding/violation was identified as described above.

Corrective Action Reference(s): CR 202331630 Observation: Adherence to Corrective Action Program Process for an Anonymous Condition Report 71152A The inspectors performed a detailed review of an anonymous condition report written in May 2022 related to a radiation protection issue. The inspectors selected this issue to review the licensees handling of anonymous issues in the corrective action program.

On May 13, 2022, facilities personnel used a vacuum cleaner outside of the radiologically controlled area (RCA) and it set off a portal monitor alarm while leaving the protected area.

Security contacted radiation protection (RP) personnel. RP technicians arrived and investigated the alarm, brought the vacuum into the RCA main control point, and discovered contamination inside the vacuum bag. On May 19, 2022, the licensee submitted an anonymous condition report describing the issue.

After submitting the condition report, the licensee reviewed it to see if any reportability or operability concerns existed. The event was not associated with plant systems, so there were no operability concerns. Additionally, no contamination left the protected area, and the event was determined not to be reportable.

The Ownership Committee reviewed the condition report following licensee procedure MQA11300, Screening and Assignment. The issue did not affect quality-related structures, systems, or components or processes and was therefore not classified as a condition adverse to quality. Additionally, the issue did not have associated nonconformances with NRC regulations, so the condition was not classified as a condition adverse to regulatory compliance. Therefore, the condition was screened as a non-corrective action program condition per the definitions contained in licensee procedure MQA11, Corrective Action Program. The Ownership Committee assigned Correct Condition as the actions required for the condition report using the guidance in MQA11300. When the licensee assigns Correct Condition, the required actions are for the licensee to restore the condition to an acceptable configuration and not to expend additional resources beyond the restoration.

Site personnel assigned to the condition report reviewed the issue and determined that RP personnel properly supported the surveying and controlling of the vacuum cleaner. The only issue the inspectors identified was that the licensee did not promptly generate a condition report. RP performed a crew learning opportunity discussion to encourage the timely initiation of condition reports.

Based on the anonymous condition report review, the inspectors did not identify any performance deficiencies concerning the condition itself or how it was routed through the corrective action program. Additionally, the inspectors did not identify violations of NRC requirements.

Observation: Welding Issues Entered into Corrective Action Program 71152S The inspectors noted several licensee identified CRs initiated from multiple departments describing various issues with the implementation of the welding program. The inspectors reviewed the issues and discussed them with licensee personnel. Some examples included a failure to utilize a site procedure when implementing ASME code-related post-maintenance tests, a Nuclear Quality Assurance (NQA) identified issue regarding an incorrect ASME Section XI repair/replacement plan for upcoming work during the refueling outage, and NQA-identified issues with the completeness of welding paperwork for upcoming work.

During the prior six months, the NRC also identified an NCV associated with weld repairs on bolting for one of the mechanical draft cooling towers (inspection report 05000341/2023003, ML23304A155). The inspectors validated that there were no operability concerns for each example and that the licensee had taken appropriate corrective actions.. Further, NQA personnel and plant management indicated they planned additional welding program reviews.

EXIT MEETINGS AND DEBRIEFS

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

  • On January 17, 2024, the inspectors presented the integrated inspection results to P. Dietrich, Senior VP and CNO, and other members of the licensee staff.
  • On October 19, 2023, the inspectors presented the emergency preparedness inspection results to C. Domingos, Site Vice President, and other members of the licensee staff.
  • On November 3, 2023, the inspectors presented the biennial licensed operator requalification inspection results to C. Domingos, Site Vice President, and other members of the licensee staff.
  • On December 1, 2023, the inspectors presented the emergency action level and emergency plan change review inspection results to A. Mann, Radiological Emergency Response Preparedness Manager, and other members of the licensee staff.
  • On January 16, 2024, the inspectors presented the radiation protection inspection results to C. Domingos, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2332291

NQA2023 Seasonal Readiness Surveillance 231003-Cold

Weather Preparations Scheduling Gaps

08/14/2023

2332746

Missed Milestone for Cold Weather Preps IAW MWC16100

09/01/2023

2333399

W24P400 Circ Water DeIce PLC Non-Responsive

09/29/2023

2333577

Failed PMT for WO 67715740 (Water Spray Noted from

Both Pump Seals)

10/07/2023

2333594

NQA2023 Seasonal Readiness Surveillance 231003

Cooling Tower DeIce Scope not Completed as Scheduled

10/09/2023

2333620

Seasonal Readiness Preparation Impacts to Auxiliary Boiler

System

10/10/2023

2333647

North Auxiliary Boiler Lower Manway Cover Leaking

10/11/2023

2333672

Fermi 1 Heating Steam Boiler Safety Valve Leaking

10/11/2023

2333725

North Auxiliary Boiler Failed to Start

10/14/2023

2334202

Cooling Tower Ice Prevention Still Not Working

11/03/2023

2335004

South Cooling Tower DeIce Reservoir Level Switches Not

Functioning

2/11/2023

2335055

Low Glycol Levels on North Cooling Tower

2/13/2023

2300292

Heater Non-Functional

03/20/2023

Corrective Action

Documents

2300293

Electric Heater Not Functioning

03/20/2023

Procedures

MWC16100

Seasonal Readiness

71111.01

Work Orders

67949569

Division 2 RHRSW Pump Room Heater X4103B236

04/20/2023

6M7215704

Standby Liquid Control System Functional Operating Sketch

6M7215706-2

Residual Heat Removal Division 1 Functional Operating

Sketch

Drawings

6M7215706-3

RHR Service Water Make Up Decant and Overflow Systems

Functional Operating Sketch

AI

23.139

Standby Liquid Control System

23.205

Residual Heat Removal System

149

71111.04

Procedures

23.208

RHR Complex Service Water Systems

135

Calculations

DC6286

EECW HX Performance Requirements with Plugging

A

71111.07A

Corrective Action

27528

Recommend Scheduling Swap of the Division 2 EECW Heat

07/01/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Exchangers

2330619

P4400B001A Division 1 EECW Heat Exchanger, Service

Water Side Measured Differential Pressure Greater than

Maintenance/Operability Limit

08/23/2023

231651

Performing 24.208.02 P4400B001C EECW Backup HX D/P

is Greater than Maintenance Limit and Less than Operability

Limit

2/08/2022

Documents

231774

Enhancement Recommended for System Monitoring Plan

Enhancement; P4400 Emergency Equipment Cooling Water

System (EECW)

2/12/2022

Engineering

Evaluations

TEP4423-049

Division 1 EECW HX Plugging Past Operability Evaluations

71111.11A

Miscellaneous

IP 71111.11

Table 03.031

Fermi 2023 Licensed Operator Annual Examination Results

11/21/2023

Corrective Action

Documents

Audit 220109

Nuclear Quality Assurance Audit of the Training and

Qualification of Unit Staff (Operations) Program

09/12/2022

Biennial

Comprehensive

LOR Written

Exam

Exam Week 4

10/30/2023

CR 6619

Simulator Change

Request (CR)

Modification-1 APRM in B/P, P/F Map Power Went to 70%

vs. 95%

2/16/2021

CR 6681

Operator Questioned Response of simulator to a Loss of

MPU3

2/20/2021

CR 6687

C7100M601 Reactor Mode Switch Does Not Click into

Position

01/27/2022

CR 6691

Perform WI 1.20 for Loss of Feed SCRAM during Shutdown

2/22/2022

CR 6695

Verified Simulator Response to 24.206.08 is Similar to the

Actual Plant Response

04/26/2022

CR 6702

HPCI Controller is Currently Set to Raw Linear

05/02/2022

CR 6707

Instructor Questioned Whether the Simulator Should Trip the

Turbine with a Loss of MPU3

05/12/2022

71111.11B

Miscellaneous

CR 6724

Reactor Flow Limit Indicator-Needle Fluctuating at Bottom

07/05/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

of Scale and does Not Change

CR 6746

Crew Questioned Simulator Response to a Loss of Bus 72B

09/09/2022

CR 6757

No Rod Block on Loss of Retract Permit when Withdrawing

SRM B

11/01/2022

CR 6767

Turbine Trip on Loss of TBCCW Occurred at 195 Degrees F

(Should Have Tripped at 131 Degrees F)

2/07/2022

CR 6780

Mode switch Rotated from Run to Shutdown and did Not

Initiate a Shutdown

03/01/2023

JPM

ARJP3006.401

Perform Torus Water Average Temperature Calculation

JPM

ARJP4101.193

Est Dose and Determine if Dose Ext Needed

JPM

ASJP4101.102

Evaluate Degraded Power Sources

JPM

ASJP4101.194

Auth to Exceed Dose Threshold

JPM

PXJP0005.203

Pull Fuses for Stuck SRV

JPM

PXJP3006.321

Defeat RBCCW.EECW Isolations

JPM

SXJP0043.407

Inject with RCIC

JPM

SXJP0139.181

Shutdown HPCI from Test

JPM

SXJP0141.181

Place RHR in LPCI Mode

JPM

SXJP2104.212

Multiple Rod Drifts

LOR Annual

Operating Test

Results

22 LOR Annual Operating Test Performance Records by

Operator

11/11/2022

LOR Cycle

Schedule

22 - 2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ODE8

Return to Shift Checklist

07/24/2023

Remediation

Record

Remediation of a Failed JPM

03/17/2023

Remediation

Record

Remediation of a Failed Cycle RO Exam

05/09/2023

Remediation

Record

Remediation of a Failed Cycle SRO Exam

04/14/2023

Scenario

SSOP9042383

Loss of Recirc, LOCA, and Loss of Feed

Scenario

SSOP9042388

Trip of bus 65G, ATWS, SLC Failure, and MT Trip

Scenario

SSOP9042390

Seismic Event, RCIC and RB Steam Tunnel Leaks

Scenario

SSOP9042393

Stuck Open SRV and Torus Leak

Simulator

Deviation List

Current List Simulator Deviations

10/23/2023

Simulator Review

Board

Meeting Minutes

2/04/2022

Simulator Review

Board

Meeting Minutes

2/22/2022

Simulator Review

Board

Meeting Minutes

07/18/2023

Simulator

Surveillance

Testing (Various

24Series)

Simulator 2023 Surveillance Testing

Multiple

Dates

SM6

Steady State Operations Performance Testing (Low Power

27%)

2/02/2022

SM6

Steady State Operations Performance Testing (Mid Power

76%)

2/05/2022

SM6

Steady Operations Performance Testing (High Power 100%)

2/05/2022

Test Data - Event

005

Event 005 Spurious Main Steam Isolation

07/14/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Test Data - Event

008

Event 008 Manual scram

07/14/2023

Test Data - Event

013

Event 013 Recirc Pump A Trip

07/14/2023

Test Data - Event

014

Event 014 Loss of Both Recirc Pumps

07/17/2023

Test Data - Event

045

Event 045 Steam Line Rupture in the Drywell

01/14/2022

Test Data - Event

2

Event 052 Loss of Feed

01/19/2022

Test Data - Event

053

Event 053 Main Turbine Trip at 25%

08/09/2023

Test Data - Event

054

Event 054 Flow Control Transient

08/09/2023

Test Data - Event

055

Event 055 Recirc Loop Rupture with Loss of All Offsite

Power

08/09/2023

Test Data - Event

056

Event 056 MSIV Closure with Stuck Open SRV, Failed

Closed SULCV and Failure of HPCI/RCIC

08/09/2023

Transient Test

(2221157)

2/04/2022 Reactor SCRAM on Loss of Feed, Turbine

Generator Failed to Trip on Reverse Power

08/03/2022

Transient Test

(2227403)

06/24/2022 Turbine Trip and Reactor SCRAM

07/28/2022

Transient Test

(2227668)

06/24/2022 Turbine Trip and Reactor SCRAM (APRM

Response Fidelity Questioned)

2/22/2022

Transient Test

(23Ctr Cond

Pump Trip)

07/24/2023 Center Condenser Pump Tripped While at 88%

Power

07/26/2023

Self-Assessments NANT230070

Formal Self-Assessment Report (Licensed Operator

Requalification Program)

09/28/2023

October 2023

RPA

October 2023 Downpower Profile

SSOP2022416

Licensed Operator Training Simulator Lesson Plan

Miscellaneous

SSOP9042389

Fermi 2 Evaluation Scenario

71111.11Q

Procedures

2.000.03

Power Operations 25% to 100% to 25%

108

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

5D32

N/S RFPT Lube Oil Reservoir Level Low

22827

Damper Position Issues with RHR Complex HVAC Fans

Out-ofService (CDBI Self-Assessment Item)

05/22/2007

20728

Calculation for RHR Complex Abnormal Op. Damper

Lineups App Determ LTA

2/04/2009

20091

Division 1 RHR Pump Room Dampers

01/06/2020

2031449

RWCU Differential Flow Degrading (G33R800)

10/21/2020

2330032

EDG 13 Switchgear Room Return Air Damper Failed Open

08/31/2023

2330948

X4103F157 Division 1 RHR Pump Room Outdoor Air

Damper Not Fully Stroking When Expected

10/24/2023

2331404

EDG 13 Engine Room Return Air Damper Stayed Fully

Open When the Fan Started

10/24/2023

2331499

EDG 12 Engine Room Outdoor Air Dampers

X4103F151C&D Not Stroking Open at All

11/13/2023

2332360

X4103F150 EDG 11 Engine Room Return Damper is Failed

Open

08/16/2023

2332363

Hydramotor Failures Requiring Unplanned Inoperability

of EDGs or EDG Switchgear

08/16/2023

2332434

PO 2301 Shut Down Walkdown - E4150F600 HPCI Bypass

MOV Packing Leak

2/15/2023

2333511

WO for RWCU Septa Replacement

10/17/2023

2334952

X4103F127 - EDG 13 SWGR Room Outside Air Damper

2/08/2023

20414

Received 2D65 HPCI Turbine Exh Dm Pot Level High

01/13/2021

21470

UNSAT Blue Check on WO 46256018

2/15/2021

21787

Potential Refurbishment Process for GEMAC

2/25/2021

24438

Request Engineering Review for E4150F600: As Found

Torque Was 75 in/lbs.; No Live Load Assembly Currently

Installed on this Valve; The Packing Follower Has Approx.

1/16" of Travel Remaining, Valve Shows Signs of Leakage

at Some Point

05/20/2021

24440

Request Engineering Review for G3352F220; Stem Has

Raised Metal in Two Locations

05/20/2021

71111.12

Corrective Action

Documents

25049

Request Review of Past Operability/Usage of Doors

06/08/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

28177

Evaluate G3352F220 Stem Damage Found during

FO2101 per 2124440

09/16/2021

29277

Chemistry RWCU Demin 'A' Co60 Removal Efficiency Still

Degraded After Performing MMA26001

10/20/2021

22928

Conduit Separated from Actuator for G3352F220 "RWCU

DIV2 CNTM ISO MOV"

03/02/2022

23699

Anti-Rotation Pin on the HPCI E4100F068 is Not Engaged in

the No. 1 Pilot Valve Stem

03/15/2022

26750

EDG11 Switchgear Room Division 1 Temp Controller

Display is Blank

06/01/2022

232183

Plan Needed to Support Isolation of Sample Point 37

(Reactor Recirc. Sample Line) for the Remainder of the

Cycle

2/29/2022

22652

EDG 12 Switchgear Outdoor Air Damper, X4103F115

Failed Closed

04/05/2023

23262

EDG 11 Outdoor Air Damper Failed to Stroke

05/02/2023

45.419.002

RHR Damper Blocking

2331094

NRC Identified: EDG 13 South Switchgear Supply Fan

Discharge Damper Failed Closed

10/24/2023

Corrective Action

Documents

Resulting from

Inspection

2335150

NRC Identified: Bridging/Mitigation Strategy Not Developed

for Missing Anti-Rotation Pin on the HPCI E4100F068 No. 1

Pilot Venture Valve (CARD 2223699)

2/19/2023

6M7212035

HPCI Reactor Building

6M7212043

High Pressure Coolant Injection System Barometric CNDR

(HPCI) Reactor Building

AJ

6M7215711-1

Reactor Water Clean Up Reactor Building Functional

Operating Sketch

Drawings

6M7215711-2

Functional Operating Sketch Reactor Water Clean Up Filter

Demineralizers

W

Engineering

Evaluations

TEE4117-036

High Pressure Coolant Injection (HPCI) 1 Pilot Venturi Valve

23008

Adverse Condition Monitoring Plan

10/05/2021

Miscellaneous

23.707

Reactor Water Clean Up

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

E4100

High Pressure Coolant Injection System

G

System Health

Report

High Pressure Coolant Injection

23

System Health

Report

Reactor Water Clean Up System G3300

Q1/2 2023

X4103

Design-Basis Document: Residual Heat Removal Complex

Heating and Ventilation System

B

X4103 System

Performance

Monitoring Plan

X4103 System Performance Monitoring Plan

23.420

RHR Complex Heating and Ventilation

45.419.001

ITT General Control HVAC Damper Actuator Model NH91

and NH95 Maintenance

31A

46.000.105

ITT General Control Milliampere Hydramotor Actuator Model

MMA02

Maintenance Program

MMR Appendix D

Revision 22

Guidelines for Determining Functional Failures and

Maintenance Preventable Functional Failures

MMR Appendix E

Maintenance Rule SSC Specific Functions

MMR Appendix E

Maintenance Rule SSC Specific Functions

MMR Appendix F

Maintenance Rule Performance Criteria

MMR08

SSC Classification

MMR09

Establishment of Get Well Plans

MMR10

Monitoring

MQA11300

Screening and Assignment

Procedures

VMB91.1

ITT General Controls: Milliampere Hydramotor Actuators NH

and NH 93

01/14/1986

41941473

Calibrate Division 1 RHR EDG 11 Room Temperature

Control Loop

01/09/2017

47849469

E4150F021 Extent of Condition Inspections

2/18/2023

53135797

Calibrate Division 1 RHR EDG 11 Room Temperature

Control Loop

05/02/2023

Work Orders

68325483

EDG 11 Outdoor Air Damper Failed to Stroke. Replace

X4103F149C

05/02/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Calculations

DC4953 Volume

I

RHR Complex Abnormal Damper Lineups

I

28861

X4103F152 Failed to Stroke While Performing IC13 Work Order 36657916

11/16/2014

Corrective Action

Documents

2334009

MCC 72F5A Position 1B Will Not Open

10/26/2023

Drawings

6SD7212510-01

One Line Diagram 480V E.

S.S Bus 72B, 72C, 72E, and 72F

BC

71111.13

Work Orders

69923551

MCC 72F5A Position 1B Will Not Open

10/26/2023

21759

Evaluate Material Condition of R1700 RHR Inverters

03/12/2008

21170

R1700S011A Inverter Not Outputting as Expected

2/09/2017

2332208

1D58STM LK DET RCIC Logic Power Failure and

1D62STM LK DET HPCI Logic Power Failure received

simultaneously

08/09/2023

2332802

Diesel Fire Pump Failed to Start

09/04/2023

Corrective Action

Documents

2333019

Diesel Fire Pump Failed to Start during 28.504.02

09/12/2023

ERE 35597

Replacement MDCT Brake Inverter

ERE 35610

Replacement MDCT Brake Inverter

Engineering

Evaluations

SIEE 900082

Replacement DFP Battery Item Equivalency

1D58

STM LK Detection RCIC Logic Power Failure

1D62

Steam Leak Detection HPCI Logic Power Failure

Procedures

47.501.03

Diesel Fire Pump Battery Inspection-Weekly

31.1

54995109

Replace The Diesel Fire Pump Starting Batteries

07/22/2020

61667951

MWO for EDP 80165

07/01/2021

65708893

Install NEW COMPONENTS for EDP 80165 (Electrical)

11/18/2022

71111.15

Work Orders

65824979

Prep/Charge & Install/Terminate Batteries for DFP

07/21/2022

29405

Request Formal Disposition of Most Recent UHS Diving

Inspection Reports

2/09/2019

2333278

Abnormal Noise Coming From Division 2 EECW Pump

Room Cooler

09/23/23

2333581

Lower than Normal Margin for Recirc. Loop A During

Performance of 27.138 Reactor Recirculation Jet Pump

Riser Integrity Test (Again)

10/08/2023

71111.24

Corrective Action

Documents

2333754

Hydrostatic Test Pressure Exceeded on New EESW and

RHRSW Piping

10/16/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2333897

Recirculation Loop 'A' Drive Flow vs. Suction Flow Ratio

Below Acceptance Criteria

10/21/2023

2333966

Slight Ticking Noise Coming from T4100B035

10/24/2023

2333988

CCHVAC West Return Fan Found Above Investigative Limit

of.314 IPS

10/25/2023

2334850

E5150F026 Packing Leak has Increased

2/04/2023

2334893

Unknown Loose Material Found in E5150F029 Motor

2/06/2023

2334928

E5150F022 RCIC Test Line Isolation Valve Wont Stroke

Open from the MCR

2/07/2023

2334949

RCIC SSO-Backseat of E5150F008 Not Performed as

Desired

2/07/2023

2335054

WO 56379504 PMT Failure - 4 DPM Leak from Packing on

P4400F605B

2/13/2023

2335067

24.208.03 Failed Acceptance Criteria in Section 5.2

Requiring Section 5.3 to be Performed

2/14/2023

6M7215702-1

Reactor Recirculation System Nuclear Boiler System

Functional Operating Sketch

Z

5I7212600-03

One Line Diagram Reactor Building 120 VAC Distribution

Divisions 1 and 2 - Local Panels

P

5M7216150

Rockwell Edward Forged Steel Univalve Stop Valve

617212095-25

Schematic Diagram Jet Pump Instrumentation System

R

6I7212221-06

Schematic Diagram HPCI System Test Return Line to

Condensate Storage Valves F008 and F011

Z

6I7212225-03

Schematic Diagram HPCI System Logic Circuit Part 1

AA

6I7212231-06

Schematic Diagram RCIC System Suppression Valves

E5150F029 and E5150F031

T

6I7212231-08

Schematic Diagram Min Flow Bypass and Test Valves

E5150F019 and E5150F022

AB

6I7212235-02

Schematic Diagram RCIC System Logic Circuit Part 1

S

6I7212235-03

Schematic Diagram RCIC System Logic Circuit Part 2

AA

6I7212276-03

Schematic Diagram FPC/CU System Filtration Demin 'B'

M

6M7212090

System Diagram Nuclear Boiler System

AP

Drawings

6M7212833

Diagram Reactor Recirculation System Nuclear Boiler

AK

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

System

6M7215706-3

RHR Service Water Make Up Decant and Overflow Systems

Functional Operating Sketch

AI

6M7215709-1

Reactor Core Isolation Cooling Functional Operating Sketch

6M7215729-2

EECW Division 2 Functional Operating Sketch

6SD7212530-01

One Line Diagram 120 VAC Inst. and Cont. Power Feeders

Division 1 and 2 Reactor Building

AC

6WM-

R30N52081

Piping Isometric EESW Pump and EDG Service Water

Pump Back Pressure Regulator to Reservoir RHR Complex

Div. 2

E

EDP 80027

Division 2 Online Buried Pipe Replacement for RHRSW and

EESW Systems

Miscellaneous

VMR182.3

Two-Out-OfFour Logic Module

A

23.129

Station and Control Air System

25

23.307

Emergency Diesel Generator System

135

24.207.09

Division 2 EECW Pump and Valve Operability Test

24.307.17

Emergency Diesel Generator 14 - Start and Load Test

44.010.139

Two-Out-OfFour Logic Module RPS B2 Response Time

Test

37A

44.010.143

Division 2 RPS - Two-Out-Of-Four Logic Module Channel

Functional Test

44.080.401

Control Center Makeup Air Manifold Radiation Monitor

Division 1 Functional Test

44A

47.000.02

Mechanical Vibration Measurements for Trending

46A

Procedures

ARP 7D51

Division 1 Control Air System Trouble

24.208.03

Division 2 EESW and EECW Make up Pump and Valve

Operability Test

47006971

Perform 550kW Diesel K1101S001A Full Load Test 887200

08/22/2018

205688

Perform 550kW N+ 1 Diesel K1101S001B Full Load Test

887200

08/22/2018

2497363

ECN80027DIV 2 Phase 5Cycle 22RHRSW/EESW-Buried

Pipe-PMT Hydro

10/17/2023

71111.24

Work Orders

56344080

Replace EESW Pump B Min Flow Line

2/13/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

56562475

Perform 550kW Diesel K1101S001A Full Load Test 887200

07/12/2021

56838788

Perform 550kW N+ 1 Diesel K1101S001B Full Load Test

887200

07/14/2021

57138764

D1 CCHVAC MUARM Replace Starter Switch and

Inspect/Clean Contactor

2/06/2021

63941027

EQ Required - Inspect and Clean Panel H21P561 -

NE6.6EQMS.050

10/30/2023

65408657

IST Req'd: Perform MOV Diagnostic Testing

2/07/2023

65808356

Perform 24.208.03 D2 EECW M/U Pump and Valve

Operability

2/13/2023

66164108

Perform 24.206.01 RCIC System Pump Operability and

Valve Test @ 1000 PSIG

2/07/2023

66977690

Jacket Coolant Leak EDG 14 JC Pump

11/28/2023

270819

X4103F150Replace Hydramotor

11/09/2023

69608650

Abnormal Noise Coming From Div. 2 EECW Pump Room

Cooler

10/24/2023

69762640

3D42 Cont Center / RB Vent Radn Mon Flow Low due to D1

CCHVAC Sample Pump Tripped

11/04/2023

69915936

High Vibes on CCHVAC West Return Fan

10/25/2023

70159398

C51K618 - Troubleshoot 3D103

2/15/2023

Corrective Action

Documents

27922

Evaluate Industry Emergency Siren Performance Trend

07/14/2022

Fermi 2 Radiological Emergency Response Preparedness

Plan

Alert and Notification System (ANS) Design Report

23 Monroe County Monthly Siren Test Schedule

01/01/2023

23 Wayne County Monthly Siren Test Schedule

01/01/2023

Siren Annual Preventative Maintenance Records

10/01/2021-

10/01/2023

Miscellaneous

Monthly Siren Test Results

10/01/2022-

08/31/2023

71114.02

Procedures

EP560

Alert and Notification System Operation and Maintenance

71114.03

Corrective Action

25507

Challenges to ERO Staffing due to Attrition and Reduced

04/22/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Staffing

29735

Fermex 2022 - Marginal Drill Objective (H1.3) - DCRT Team

Status Tracking

09/20/2022

29740

RERP Exercise 09/20/22 -Lack of Questioning Attitude

09/20/2022

Documents

22173

RERP Drill Marginal Objective J.1 Identifying and

Communicating Protective Actions

03/17/2023

Fermi 2 Radiological Emergency Response Preparedness

Plan; Section B, Emergency Response Organization

Fermi 2 Onshift Staffing Analysis

2/20/2012

Fermi 2 ERO Team List

08/31/2023

ERO Team Training and Qualification Records (Sample-15)

10/17/2023

Miscellaneous

ERO Quarterly Augmentation Drill Records

10/01/2021-

06/30/2023

EP290

Emergency Notifications

63A

EP292

Emergency Call Out-Backup Method

EP540

Drills and Exercises

EP550

RERP Training Program

5B

Procedures

EP570

Emergency Call Out System-Testing and Maintenance

6A

CFR 50.54(q) Reviewer Qualification Records

07/11/2023

EP101

Classification of Emergencies

LPER8740001

CFR 50.54(Q) Compliance Reviews Training Lesson

Plan

71114.04

Procedures

RERP Plan

Fermi 2 Radiological Emergency Response Preparedness

Plan

27922-01

Inadvertent Notifications

07/21/2022

28855

Operating Experience Review-Failure to Make Four Hour

Report for Spurious Siren Activation

08/18/2022

29747

NRC ENS Lines Not Functioning

09/21/2022

29779

Minor Proficiency Issues with Vaporstream

09/21/2022

Corrective Action

Documents

22638

Self-Assessment Recommendation: Update ANS Design

Report Backup Method

04/05/2023

71114.05

Miscellaneous

Emergency Preparedness Letters of Agreements with

Off-Site Response and Support Organizations

10/01/2021-

10/01/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Select Exercise and Drill Evaluation Reports

10/01/2021-

10/01/2023

Quarterly Control Room ERF Testing and Maintenance

Records

10/01/2021-

10/01/2023

Quarterly Emergency Operations Facility ERF Testing and

Maintenance Records

10/01/2021-

10/01/2023

Quarterly Technical Support Center ERF Testing and

Maintenance Records

10/01/2021-

10/01/2023

Quarterly Operations Support Center ERF Testing and

Maintenance Records

10/01/2021-

10/01/2023

KLD TR1351

Fermi 2 Nuclear Power Plant 2023 Population Update

Analysis

08/14/2023

EP101

Classifications

EP290

Emergency Notifications

63A

EP292

Emergency Call Out-Backup Method

EP580

Equipment Important to Emergency Response (EITER)

Procedures

EP601

Public Education and Information

EP101

Classification of Emergencies

71114.06

Procedures

EP101

Classification of Emergencies

Corrective Action

Documents

22920

MaxAir Walkdown Issues

04/18/2023

Corrective Action

Documents

Resulting from

Inspection

2334437

Improper PUA during Respirator Fit Test

11/14/2023

FireHark M7XT

Air Mask

Vendor Manual

S/N:

LAE117743SM

Regulator Flow Test for SCBA

07/13/2022

Miscellaneous

S/N:

LAJ209537RAA

Regulator Flow Test for SCBA

07/13/2022

71124.03

Procedures

65.000.541

Filter Leak Testing of Portable HEPA Ventilation Units and

HEPA Vacuums

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

65.000.734

Performing Respirator Fit Testing Using the TSI Portacount

65.000.768

Inspection of MSA Firehawk M7 Self-Contained Breathing

Apparatus

MRP09

Respiratory Protection

Self-Assessments NPRP230030

Quick Hit Self-Assessment: NRC Inspection 71124.03 -

InPlant Airborne

04/20/2023

Work Orders

243419

Control Room Emergency Filter Performance Testing

05/03/2022

25860

Worker Received Dose Rate Alarm

04/30/2022

29774

Worker Received Dose Rate Alarm

09/20/2022

20148

Wrong DLR Taken at Exchange and Used for Entry into

RCA

01/04/2023

Corrective Action

Documents

20547

DMC 3000 Malfunction Resulted in Erroneous Exposure for

an Entry

01/19/2023

Declared Pregnant Worker Evaluation

10/28/2022

23 Dosimetry

NVLAP

Accreditation

NVLAP Accreditation for InLight LDR Model 2 OSLN-L11N

01/01/2023

65.000.262

23 Whole Body Counter Log Sheet

2/13/2023

MRP10004

Declared Pregnant Worker Evaluation

2/19/2022

RPID 52572

Internal Dose Assessment

03/23/2022

Miscellaneous

RPID 94872

Internal Dose Assessment

03/19/2022

65.000.200

Initiating Personnel Radiation Monitoring

65.000.201

Assembly, Issuance, and Return of Multiple Whole Body and

Extremity Dosimetry

65.000.267

Whole Body Count Protocol and Evaluation of Bioassay

Results

Procedures

67.000.400

Personnel Contamination Event Dose Assessment

Radiation

Surveys

NPRP230065

Prospective Evaluation of Fermi 2 Internal Dose

10/24/2023

22 NQA Audit

Report

Nuclear Quality Assurance Audit of the Radiation Protection

Program

07/04/2022

71124.04

Self-Assessments

NPRP230031

Quick Hit Self-Assessment: NRC Inspection 71124.04 -

Occupational

04/20/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

2332737

Locked High Radiation Area Door Was Unsecured

08/31/2023

Alert and Notification System Reliability Records

07/01/2022-

06/30/2023

Emergency Response Organization Drill Participation

07/01/2022-

06/30/2023

Drill and Exercise Performance Records

07/01/2022-

06/30/2023

Procedures

EP540

D NRC Performance Indicators-RERP

DC3603

Small-Bore Piping Stress Analysis for Isometrics

CTB31L018 to Penet X2914 DWG 6DI-B3172554

A

Calculations

DC5358

Small-Bore I&C Pipe Stress Margin Screening Inside

Drywell for Power Uprate

0000812

Leaking Weld at Elbow

04/08/2000

0010008

Increased Speed and Vibration of RRS Pumps at

Susquehana Z Caused Weld Fatigue Crack in Instrument

Piping

01/12/2000

27839

Corroded Shims on MDCT Fan 'B' Gear Reducer

2/11/2006

27842

Cleanup and Paint MDCT Fan 'D' Gear Reducer

2/11/2006

26653

Corroded Shims for MDCT Fan 'B' Gear Reducer

10/08/2008

28252

Purchase Spare Gear Box

09/07/2011

26836

MMR14 Structures Monitoring Walkdown - RHR Division 1

Findings

08/28/2014

28239

MDCT Fan Gearbox Has Elevated Particle Count/Lead

10/09/2017

1830115

WO to replace MDCT 'D' fan reduction gear

2/14/2018

1830422

Request WOs to Paint MDCT Fan Gear Reducers

2/28/2018

20770

RHRSW LIR Deficiency - MDCT Reducing Gear

Maintenance

2/04/2019

22422

Inspection WOs are Needed for Div 1 and Div 2 RHRSW

MDCT Penetrations MK151 and MK183

03/29/2019

25449

RF20 Contingency WOs to Replace Division 2 MDCT Gear

Reducers

07/18/2019

71152A

Corrective Action

Documents

20848

Walkdown Required for Contingent RF20 Work (MDCT Gear 01/24/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Reducer)

2331630

MDCT 'D' Fan Tripped

07/18/2023

2331707

Original Installation of the MDCT Gearbox Mounting is Not in

Accordance with Installation Drawings

07/21/2023

2333257

Risks Identified with PTB31L015A and PTB31Lo15B

09/27/2023

2333328

RF22 Scope Add Request for Weld Connections Identified

by Root Cause Evaluation Team

09/27/2023

2333713

ITPR Comments in Support of RCE202332454: DC363

Vol IB

10/16/2023

2333715

ITPR Comments in Support of RCE202332454: CARD

0010008

10/16/2023

2333719

Reactor Recirculation System Latent Issues Review Gap

Identified

10/16/2023

2333739

Review of Vendor Inspection Report - Recirc Sample Line

Weld Failure Analysis

10/16/2023

21243

MDCT 'A' Gear Reducer Needs to be Painted

2/09/2021

21308

MDCT 'C' Gear Box Needs to be Replaced

2/11/2021

21666

MDCT 'A' Gear Reducer Needs to be Painted

2/28/2023

22076

Abnormal Engineering Readings on E1156C001B

03/14/2023

9816712

Vibration-Induced Fatigue Cracks

01/15/1999

FBP70

Strategic Engineering Fundamentals

Drawings

CN6004

Marley Co. RHR Cooling Tower Eliminator Installation

Details Sheet 5

AsBuilt 136091

To Incorporate EDP 13609 Rev 0 Index Items (11, 12) No

ECRs Written

10/31/1992

DER 880401

Crack in a Socket Weld on the 3/4" Lantern for Valve

31F023B

03/03/1988

DER 882137

SIL 22: Reactor Recirculation System Valves

2/22/1988

DER 900333

VEN SIL No 512 Recirculation Loop Unisolable Leakage

06/19/1990

DER 920586

B31F023B RX Recirc Pump Suction Valve Leakage

10/26/1992

DER 950284

Notice 9516: Vibration Caused by Recirculation Flow in a

BWR and SIL 600

04/20/1995

Miscellaneous

FBP87

Latent Issues Review

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

NRC Information

Notice 9516

Vibration Caused by Increased Recirculation Flow in a

Boiling Water Reactor

03/09/1995

Nuclear

Generation

Memorandum

To

M. Kirschenheiter from I. Finney, Latent Issue Review:

Reactor Recirculation System

2/28/2019

OE 20150241

IN1504, Fatigue in Branch Connection Welds

05/01/2015

35.205.003

RHR Cooling Tower Fan, Drive Shaft Maintenance

FBP41

Equipment Reliability Program

MAQ13

Trending

2.1

MAQ13100

CR Trend Coding and Analysis

MES51

Preventative Maintenance Program

MGA12

Fermi Employee Concerns Program

MQA11

Corrective Action Program

MQA11200

Condition Initiation

MQA11300

Screening and Assignment

MQA11400

Corrective Action Program Condition Disposition

MQA11500

Non-Corrective Action Program Condition Disposition

Procedures

MQA14

Nuclear Quality Assurance Oversight Activities

Work Orders

69007143

Perform Repairs to MDCT Fan 'C' Gear Reducer Pedestal

11/01/2023

2332326

Emerging Trend: Maintenance Mods Planning and Workflow

Discrepancies

2/20/2023

2332970

GSWPH Door D7 Lock Degraded

2/13/2023

2333343

DFP Door Tamper Seal Found Broken

2/13/2023

2333356

NQA Notice of Escalation - Deficiencies in Fire Protection

09/28/2023

2333368

Diesel Fire Pump South Door D7 Condition Further

Degraded

2/13/2023

2333495

NQA - Quality Concerns Identified during Review of RFO22

Work Order 69262266 EDP 70368 - Inspection and Weld

Repairs - Drywell Moisture Barrier Replacement

2/19/2023

2333832

NQA - 2:1 Taper Weld Requirement Added to All Socket

Welds on the WPCS's for the Div 2 Core Spray High Point

Vent Lines Without Justification

2/19/2023

71152S

Corrective Action

Documents

2333918

43.000.007 Not Used for EESW/RHRSW Hydrostatic Tests

2/20/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2333963

NQ - NQA Area of Concern - Continued Gaps in

Supplemental Work Order Planning Quality for RF022

2/19/2023

2334400

CAP Quality Gap for CAP CR202333343: DFP Door

Tamper Seal Found Broken

2/13/2023

2334428

Revise Weld Process Control Sheet Forms

2/19/2023

2334787

NQA - ANII review Not Completed on Welding Process

Control Sheets for RHRSW Buried Pipe Project

2/19/2023

2334981

DFP Double Doors Left Unlocked and Unattended

2/11/2023

2335016

Weld Engineer Not on Site to Perform Responsibilities of

MMA09

2/19/2023

2335047

Valve Team RF22 - Precursors Showing Coordination

Weakness

2/20/2023

71152S

Corrective Action

Documents

Resulting from

Inspection

2334342

NRC Violation - Integrated Inspection: MCDT Bolt Repair

Lacks Engineering Documentation

2/19/2023

71152S

Miscellaneous

Nuclear

Generation

Memorandum

To Timothy Barlow from Teresa Werling, Refuel Outage 22 -

NQA Independent Review for Work Order Quality

09/13/2023