IR 05000341/2023010
| ML23340A032 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/08/2023 |
| From: | Billy Dickson NRC/RGN-III/DORS/RPB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2023010 | |
| Download: ML23340A032 (1) | |
Text
SUBJECT:
FERMI POWER PLANT, UNIT 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000341/2023010
Dear Peter Dietrich:
On October 24, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Fermi Power Plant, Unit 2 and 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.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
The team identified a finding in problem identification, implementation of the process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken to resolve these problems.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. However, the team found evidence of challenges to your organizations safety-conscious work environment.
Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
December 8, 2023 If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.
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. NPF-43
Enclosure:
As stated
Inspection Report
Docket Number:
05000341
License Number:
Report Number:
Enterprise Identifier:
I-2023-010-0043
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
September 18, 2023 to October 06, 2023
Inspectors:
T. Briley, Senior Project Engineer
J. Corujo-Sandin, Acting Branch Chief
J. Gewargis, Resident Inspector
I. Hafeez, Senior Reactor Inspector
C. Norton, Senior Resident Inspector
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 a biennial problem identification and resolution 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
Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate Heat Sink) Roof Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/2023010-01 Open/Closed
[H.12] - Avoid Complacency 71152B The inspectors identified a finding of very low safety significance for the licensee's failure to document housekeeping findings and initiate a condition report for discrepancies on the residual heat removal complex roof in accordance with licensee procedure MOP 21,
"Housekeeping." Specifically, the inspectors identified miscellaneous debris (such as tie wraps, earplugs, cigarette butts, tape, candy wrapper, plastic water bottle caps, miscellaneous broom pieces, and other small, loose metallic parts) that had not been documented by the licensee despite multiple individuals touring the area.
Failure to Screen Transient Combustible Program Administrative Controls Issues, Under the Purview of the Quality Assurance Program, as Conditions Adverse to Regulatory Compliance (CARCs)
Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000341/2023010-02 Open/Closed
[H.9] - Training 71152B The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program" when the licensee failed to screen administrative controls issues, under the purview of the quality assurance program, as CARCs. Specifically, the inspectors identified various examples of problems with the implementation of the fire protection transient combustible permit program. These problems were documented in numerous condition reports which were incorrectly classified as Non-Corrective Action Program (NCAP), therefore excluded from the corrective action program (CAP). This was contrary to procedure MQA11-300 "Quality Assurance Conduct Manual Implementing Procedure - Screening and Assignment," the sites quality assurance program, and 10 CFR Part 50 Appendix B Criterion II, Quality Assurance Program."
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review on the mechanical draft cooling tower system. The corrective actions for selected non-cited violations were evaluated as part of the assessment.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness Based on the samples reviewed, the inspectors concluded that the licensee's implementation of the corrective action program was generally effective and adequately supported nuclear safety.
Effectiveness of Problem Identification:
Based on the samples reviewed, the inspectors determined that the licensee continued to identify issues at a low threshold and appropriately entered those issues into the corrective action program. The inspectors also determined that the licensee usually entered problems into the corrective action program completely and accurately.
The inspectors noted that staff, supervisors, and management were identifying issues with varying degrees of safety significance. External organizations, including the NRC identified some deficiencies, and the licensee subsequently entered into the deficiencies into corrective action program for resolution. The licensee also utilized several corrective action program support processes to identify problems, including the self-assessment and audit processes and the operating experience program. For example, the licensee performed department self-assessments and nuclear quality assurance audits to identify issues in site processes.
The licensee entered the identified deficiencies and improvement opportunities into the corrective action program for resolution. Similarly, the licensee screened issues from the NRC and industry operating experience programs and entered them into the corrective action program when they were applicable to the site.
The inspectors determined that the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the corrective action program to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The inspectors performed a five-year review of the mechanical draft cooling tower system.
Specifically, the inspectors focused on any recurring or age-related issues of the system. The inspectors reviewed plant health reports and selected corrective action and condition evaluation documents as part of this review. The inspectors also performed a partial system walkdown to assess the material condition of selected components and surrounding areas.
The inspectors noted miscellaneous debris on the residual heat removal complex roof during the walkdown. As a result, an NRC finding is documented in this report.
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the inspectors determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. In general, once a degraded or non-conforming issue was identified, the corrective action program process effectively directed equipment operability or functionality reviews. The ownership screening committee and management review committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. In addition, the inspectors observed healthy dialog and good interactions among the members of these committees. The members came prepared and challenged each other on the disposition of the identified conditions. The licensee generally prioritized actions based on the safety significance of the issues. The inspectors identified a programmatic issue for failure to screen transient combustible program administrative controls issues, under the purview of the quality assurance program, as conditions adverse to regulatory compliance (CARCs). As a result, a finding and associated non-cited violation (NCV) is documented in this report.
Effectiveness of Corrective Actions:
Based on the samples reviewed, the inspectors determined that the licensee was generally effective in corrective action implementation. In general, the licensee promptly implemented corrective actions for deficiencies that were safety significant. The licensee resolved problems requiring the performance of a root cause evaluation or other causal evaluation methodologies following their corrective action program requirements. The inspectors reviewed a root cause evaluation for a mechanical draft cooling tower fan brake system speed controller circuit failure, a significant condition adverse to quality that rendered all four mechanical draft cooling towers inoperable. A finding and associated NCV (05000341/2023003-02 Inoperable Mechanical Draft Cooling Towers Following Modification to Brake Control Circuit) surrounding the technical details of that issue was documented in inspection report 2023003 (ADAMS Accession ML23304A155). The inspectors sampled corrective actions associated with violations previously identified by the NRC and with licensee event reports. The inspectors determined that the corrective actions sampled were generally effective and timely.
Assessment 71152B Use of Operating Experience Based on the samples reviewed, the inspectors determined that the licensee's performance in using operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to the site. When applicable, the licensee wrote condition reports and developed and implemented actions to prevent similar issues. The licensee generally communicated operating experience lessons learned and incorporated them into plant operations. The inspectors did not identify any concerns in this area.
Assessment 71152B Self-Assessments and Audits Based on the samples reviewed, the inspectors determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and quality assurance audits periodically. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits identified issues that were not previously known, including issues within the corrective action program. The licensee addressed those issues through the corrective action program. The inspectors did not identify any concerns in this area.
Assessment 71152B Safety Conscious Work Environment The inspectors reviewed the results from available 2021 to 2023 safety culture surveys. The inspectors conducted focus group interviews with 42 licensee staff across most departments concerning the effectiveness of the corrective action program, the ability to raise concerns, and the freedom from potential retaliation for raising issues. The inspectors also interviewed the radiation protection manager (RPM) and the employee concerns program (ECP) owner.
The inspectors determined that individuals were willing to raise safety concerns. However, the inspectors determined that there was a perceived environment that discourages radiation protection staff from initiating condition reports. Specifically, the radiation protection staff was willing to raise safety concerns to their first-line supervisors but hesitant to write condition reports for fear of retaliation, embarrassment, and/or it would be closed out to the initiator just having a beef with management with no actual resolution taken.
For example, during the planned down power and maintenance outage (August - September 2023) to investigate and repair an increase in unidentified drywell leakage, a personnel entry occurred above the drywell first floor during power operation. The radiation protection staff had safety concerns with going above the drywell first floor that included radiation protection survey and personnel monitoring instrumentation ability to work in extreme environmental conditions and accurately measure fast neutrons, site personnel having never been above the drywell first-floor at ~23 percent rated thermal power, and physical openings in the bio shield wall above the first floor providing neutron streaming paths. The radiation work permit (RWP) and "as low as reasonably achievable" (ALARA) plan developed for the drywell entry expressly prohibited personnel above the first floor for these reasons. After the initial first-floor drywell entries were inconclusive, station management desired a second-floor entry to investigate the unidentified leakage source further. An RWP job coverage record, which contained new radiation dose and dose rate setpoints authorized by the RPM and signed by a radiation protection supervisor, was used to authorize this entry. After experienced radiation protection technicians stated they would not go to the second floor of the drywell during power operation, a less experienced radiation protection technician made the second-floor entry. Upon reaching the second floor, they immediately reached the established neutron abort dose rate criteria and exited the area. Concerns were, again, raised by radiation protection staff to radiation protection supervision regarding the second-floor drywell entry for the reasons previously stated above. The staff also had concerns about using an RWP job coverage record instead of an ALARA change form which required additional signatory authorization from the RWP/ALARA plan originator.
Radiation protection staff were unwilling to write condition reports raising these concerns in the corrective action program for the above reasons. The staff indicated that they brought the concerns to the attention of radiation protection supervision and desired that radiation protection supervision write a condition report. The inspectors determined that the licensee had written no condition report, even though radiation protection staff still had concerns and sought answers from radiation protection management on the decision-making and process for authorizing the second-floor drywell entry. The licensee ultimately wrote condition report (CR-2023-33970) after inspectors discussed the safety-conscious work environment assessment above with licensee management during the inspection exit meeting. The technical details surrounding the drywell second-floor personnel entry during power operation are planned to be reviewed during a future NRC inspection.
Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate Heat Sink) Roof Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/2023010-01 Open/Closed
[H.12] - Avoid Complacency 71152B The inspectors identified a finding of very low safety significance for the licensee's failure to document housekeeping findings and initiate a condition report for discrepancies on the residual heat removal complex roof in accordance with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified miscellaneous debris (such as tie wraps, earplugs, cigarette butts, tape, candy wrapper, plastic water bottle caps, miscellaneous broom pieces, and other small, loose metallic parts) that had not been documented by the licensee despite multiple individuals touring the area.
Description:
On September 21, 2023, the inspectors performed a walkdown of the residual heat removal complex roof. The inspectors noted that the lower roof contained miscellaneous debris in the form of tie wraps, earplugs, cigarette butts, tape, candy wrappers, plastic water bottle caps, miscellaneous broom pieces, and other small, loose metallic parts. The identified debris was generally near roof drains and/or grating that led to or was directly over the Division 1 and Division 2 ultimate heat sink water reservoirs used to transfer heat from structures, systems, and components important to safety. Natural phenomena (such as rainfall or wind gusts) could transport the debris into the reservoirs and potentially challenge pump operation for residual heat removal service water, emergency equipment service water, and/or emergency diesel generator service water.
The personnel doors used routinely by various plant personnel to access the residual heat removal complex roof indicated the area was a "housekeeping category," and a sign was posted stating, "The UHS [ultimate heat sink] is a standard risk FME [foreign material exclusion] area. No foreign material shall be left on the roof including any foliage/moss etc.
A CARD [condition assessment resolution document - i.e., condition report] is required for items that cannot be removed from the roof."
Licensee procedure MOP 21, "Housekeeping," Revision 7, contains procedural guidance for ensuring adequate levels of housekeeping to ensure safe plant operation and included all activities related to controlling material in all areas of the facility. The procedure also stated, in part, that individuals are expected to maintain the same level of housekeeping inside and out of the power block. Procedure step 2.3.9 stated, in part, that persons performing a plant tour shall 1) document findings on the housekeeping inspection report form and 2) initiate a condition assessment resolution document (condition report) for discrepancies when required.
The debris identified by the inspectors had not been documented as a housekeeping finding nor entered into the corrective action program via a condition report until brought to the licensee's attention. It is unknown how long the miscellaneous debris was present on the residual heat removal complex roof. However, the inspectors determined that some of the miscellaneous debris had most likely been on the roof for an extended period based on environmental degradation (rust staining, for example).
A similar finding for failure to follow housekeeping procedure on residual heat removal complex (ultimate heat sink) roof was documented in inspection report 2022004 (ADAMS Accession ML23039A155) as FIN 05000341/2022004-02.
Corrective Actions: The licensee planned to remove the miscellaneous debris and further evaluate current practices and guidance to ensure the roof met applicable housekeeping standards.
Corrective Action References: CR-2023-33221
Performance Assessment:
Performance Deficiency: The licensee's failure to document housekeeping findings and initiate a CARD or condition report for discrepancies on the residual heat removal complex roof in accordance with licensee procedure MOP 21, "Housekeeping," was a performance deficiency. Specifically, the inspectors identified miscellaneous debris (such as tie wraps, earplugs, cigarette butts, tape, candy wrapper, plastic water bottle caps, miscellaneous broom pieces, and other small, loose metallic parts) that had not been documented by the licensee despite multiple individuals touring the area.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, debris on the residual heat removal complex roof could be washed or blown directly into the ultimate heat sink reservoirs and could potentially impact safety-related residual heat removal, emergency equipment, and emergency diesel generator service water systems. A very similar issue was identified on October 18, 2022, by NRC inspectors.
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 mitigating systems screening questions for structures, systems, and components and probabilistic risk analysis functionality were all answered no. Therefore, the finding screened as of very low safety significance (Green).
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. Specifically, multiple individuals from multiple departments routinely traversed the residual heat removal complex roof and appeared to not consider the potential undesired consequences of their actions in leaving miscellaneous debris on the roof, verify housekeeping procedure prerequisites despite being prompted by the access door signs stating "housekeeping category" and to not leave foreign material on the roof, nor performed a thorough review of the area every time work was performed (such as operator or security rounds) rather than relying on past successes and assumed conditions. The licensee had also previously developed specific instructions in operator rounds and security turnover checklists to remind individuals of the procedural requirements for the residual heat removal complex roof.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Screen Transient Combustible Program Administrative Controls Issues, Under the Purview of the Quality Assurance Program, as Conditions Adverse to Regulatory Compliance (CARCs)
Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000341/2023010-02 Open/Closed
[H.9] - Training 71152B The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program" when the licensee failed to screen administrative controls issues, under the purview of the quality assurance program, as CARCs. Specifically, the inspectors identified various examples of problems with the implementation of the fire protection transient combustible permit program. These problems were documented in numerous condition reports which were incorrectly classified as Non-Corrective Action Program (NCAP), therefore excluded from the corrective action program (CAP). This was contrary to procedure MQA11-300 "Quality Assurance Conduct Manual Implementing Procedure - Screening and Assignment," the sites quality assurance program, and 10 CFR Part 50 Appendix B Criterion II, Quality Assurance Program."
Description:
As part of the licensee's corrective action program implementation, condition reports written were screened and assigned a classification to ensure problems that warrant entry into the corrective action program were resolved using the most effective management systems and programs. An ownership screening committee with representatives from operations, maintenance, engineering, radiation protection, chemistry, and other organizations routinely met to screen condition reports for appropriate classification.
Licensee procedure MQA11-300, Quality Assurance Conduct Manual Implementing Procedure - Screening and Assignment, Revision 8, defined and provided written instructions for the ownership screening committee to classify condition reports as either Significant Condition Adverse to Quality (SCAQ), Condition Adverse to Quality (CAQ), Condition Adverse to Regulatory Compliance (CARC), or Non-Corrective Action Program (NCAP)
Condition.
When reviewing a negative trend of condition reports on various fire protection transient combustible program implementation problems, the inspectors noted multiple examples where the ownership screening committee did not correctly classify condition reports.
Specifically, condition reports involving transient combustible permits identified as either expired in the field or not posted in the field while transient combustible material was present and unattended were classified as NCAP versus CARC.
MQA11-300 specifically defines CARC and NCAP as follows:
- CARC Condition - A condition in which the licensee is not in conformance with NRC regulations; a failure to comply with a docketed commitment made to the NRC; a non-compliance with the licensees Quality Assurance program that does not consequently affect the safety-related function of a structure, system, or component.
- NCAP Condition - An issue that warrants some management resolution but does not meet requirements for resolution in the corrective action program.
Licensee procedure MOP11-100, Operations Conduct Manual - Fire Protection Implementation, Revision 9, contained requirements for transient combustible material handling. Specifically, Section 4.7 - Transient Combustible Permit Process - required permits to be developed, approved, and posted at the designated staging locations, along with verifying permits had not expired, if more time was needed, or if material was removed two days before expiration. This procedure was required to be followed per technical specification 5.4.1.d (procedures - fire protection program implementation), a regulatory requirement. In addition, License Condition 2.C.9 (Modifications for Fire Protection) incorporates this procedure into the quality assurance program as described in updated final safety analysis report (UFSAR) Section 9.A.5.c (Fire Protection Program Point by Point Comparison - Quality Assurance Program). Therefore, not complying with this administrative procedure (MOP11-100) meets the definition of a CARC as defined in MQA11-300, Enclosure A.
Examples of condition reports classified as NCAP included, but were not limited to, the following:
- 21-29224 - transient combustible permit posted in field expired (high pressure coolant injection system room)
- 22-23471 - transient combustible permit posted in field expired (division 1 switchgear room)
- 23-31183 - transient combustible permit posted in field expired (direct current motor control center area)
- 23-32161 - transient combustible permit posted in field expired (direct current motor control center area)
The licensee classified these condition report examples as NCAP primarily based on non-compliance with a technical or administrative program, process, or procedure. In general, the ownership screening committee incorrectly treated these types of transient combustible permit problems as "administrative" and not regulatory and/or quality assurance program problems. In each example, despite not having a valid permit, the inspectors confirmed the amount of unattended transient combustible material was within licensee-analyzed combustible loading limits for the respective plant areas.
Corrective Actions: Planned corrective actions included, but were not limited to, an evaluation of current ownership screening committee practices and industry benchmarking.
Corrective Action References: CR-2023-33528
Performance Assessment:
Performance Deficiency: The licensee programmatically failed to screen administrative controls issues, under the purview of the quality assurance program, as CARCs. Specifically, the inspectors identified various examples of problems with the implementation of the fire protection transient combustible permit program. These problems were documented in numerous condition reports which were incorrectly classified as NCAP, therefore excluded from the corrective action program. This was contrary to procedure MQA11-300, the sites quality assurance program, and 10 CFR Part 50 Appendix B Criterion II, The Quality Assurance Program, therefore a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, absent NRC intervention the licensee would continue to screen administrative control issues outside of the corrective action program contrary to the requirements of the fire protection program and the quality assurance program. Issues outside the corrective action program do not require the same level of programmatic controls and oversight in order to evaluate/correct them.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Specifically, the fire finding was assigned a low degradation rating based on the amount of combustible material found in the plant without proper transient combustible permits, and therefore the inspectors answered screening question 1.3.1.A (assigned a low degradation rating) as yes. As a result, the finding screened as very low safety significance (Green).
Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the ownership screening committee had an incorrect mental model that fire protection transient combustible program permit problems were simply "administrative" in nature and also took into consideration the level of significance (i.e., plant consequence), instead of recognizing that "administrative" or non-consequential program / process issues could still be regulatory and/or quality assurance program problems.
Enforcement:
Violation: 10 CFR Part 50 Appendix B, Criterion II, Quality Assurance Program, requires in part that the program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions.
Chapter 17 of the UFSAR describes the licensees quality assurance program. UFSAR Section 17.2.2.4, Program Applicability, states in part, the requirements of the quality assurance program are applicable to the fire protection program and are applied to the extent consistent with safety.
Procedure MQA11, Quality Assurance Conduct Manual - Corrective Action Program, Revision 51, Section 1.1, stated purpose, in part, is to fulfill regulatory requirements specified in 10 CFR 50 Appendix B, criterion XVI. This procedure establishes the measures for the timely identification, documentation, evaluation, classification, reporting, and resolving of Significant Conditions Adverse to Quality (SCAQ), Conditions Adverse to Quality (CAQ),
Conditions Adverse to Regulatory Compliance (CARC) and other conditions not meeting established expectations at Fermi 2.
Procedure MQA11-300, Quality Assurance Conduct Manual Implementing Procedure, Screening and Assignment, Revision 8, Enclosure A, Classification Guidelines, defines Condition Adverse to Regulatory Compliance (CARC), as a condition in which the licensee is not in conformance with NRC regulations; a failure to comply with a docketed commitment made to the NRC; a non-compliance with the licensees Quality Assurance program that does not consequently affect the safety-related function of a structure, system, or component.
MQA11-300, Section 2.1.2, states problems that do not meet the threshold for entry into CAP are addressed as non-CAP (NCAP) issues using other processes.
Technical Specification 5.4.1.d, Administrative Control - Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the following activities: Fire Protection Program Implementation.
The Operating License condition 2.C.9 requires, in part, the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report.
UFSAR Section 9.A.5.c, Quality Assurance Program, licensees response states, in part, that in view of the fact that safety-related structures, systems, and components are protected by the fire protection systems, portions of the quality assurance program for plant operation are designed to ensure that fire protection in safety related areas is maintained through requirements on design, procurement, installation, testing, and administrative controls.
UFSAR Section 9.A.5.c.8, Corrective Action, describes, in part, measures should be established to assure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material, and nonconformances are promptly identified, reported and corrected. The licensees response states this item is included in the quality assurance program.
Licensee procedure MOP11-100, "Operations Conduct Manual - Fire Protection Implementation," Revision 9 contained requirements for transient combustible material handling. Specifically, Section 4.7 - transient combustible permit process - required permits to be developed, approved, and posted at the designated staging locations; along with verifying permits had not expired, if more time was needed, or material was removed two days before expiration.
Contrary to the above, as of October 24, 2023, the licensee failed to carry out the quality assurance program in accordance with the programs written policies, procedures, or instructions. Specifically, the licensee programmatically failed to screen administrative controls issues, under the purview of the quality assurance program, as CARCs. The inspectors identified various examples of problems with the implementation of the fire protection transient combustible permit program, as described in MOP11-100. These were documented in numerous conditions reports which were incorrectly classified as NCAP, therefore excluded from the corrective action program. Examples of these included, but were not limited to:
- 21-29224 - transient combustible permit posted in field expired (high pressure coolant injection system room)
- 22-23471 - transient combustible permit posted in field expired (division 1 switchgear room)
- 23-31183 - transient combustible permit posted in field expired (direct current motor control center area)
- 23-32161 - transient combustible permit posted in field expired (direct current motor control center area)
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 24, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Peter Dietrich and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ALARA Plans
231029
Drywell / Reactor Building Steam Tunnel Emergent Work
08/18/2023
CARD 13-22655
UFSAR Section 15.6.4 Description of Main Steam Line Break
Source Term Concentrations Appears to be Incorrect
04/15/2013
CARD 13-28648
2013 NRC UHS Inspection: Potential Unanalyzed Condition
Related to Limiting Post-Tornado Suppression Pool
Temperature
2/06/2013
CARD 16-28480
Design EECW Flow Range of CCHVAC Chiller/Condensers
too Narrow
10/25/2016
CARD 17-21787
Loop Seal Checks for Secondary Containment Not Part of
TRSR Requirements
03/04/2017
CARD 19-29276
MDCT B Fan Brake BOP Nitrogen Supply Tank
2/04/2019
CARD 20-22155
Nitrogen Pressure at or Near Min. 550 psig
2/27/2020
CARD 20-23984
Unrecovered Foreign Material - Orange Zip Tie
04/07/2020
CARD 20-26507
Div 1 MDCT A N2 Bottle 'B' Needs to be Replaced
06/02/2020
CARD 21-21328
20 MMR14 Structures Monitoring Opportunistic Inspection
of Div 1 RHR SW Mechanical Draft Cooling Tower Fan Area
(In-Leakage Investigation)
2/11/2021
CARD 21-24028
Fire Protection LIR, LI-FP-06, Leaks on the Fire Protection
05/07/2021
CARD 21-24420
Failed Penetration Fire Stops
05/19/2021
CARD 21-26048
NQA-Notice of Elevation-Vulnerabilities in the Management
and Oversight of the Fire Protection Program
07/09/2021
CARD 21-26554
Internal Contamination While Performing Tagout DO74
07/28/2021
CARD 21-28223
Site Compliance Issues with MOP23 Plant
Storage/Housekeeping and MOP11 Fire Protection/Transient
Combustibles
09/17/2021
CARD 21-28888
Transient Combustibles Found Without Permit
10/06/2021
CARD 21-29196
Expired Transient Combustible Permit
10/18/2021
CARD 21-29224
Lift Found in ABSB Needs a Transient Combustible Permit or
Removed from Area
10/19/2021
CARD 21-29259
Declining Trend in CARD Quality in Radiation Protection
10/19/2021
Corrective Action
Documents
CARD 21-29466
Fire Door RHR-D36 Not Latching Properly
10/25/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 21-29516
Double Doors to DIV 2 RHR Fire Door Has Hole That Passes
Between Plane
10/26/2021
CARD 21-29550
Fire/CO2 Door RHR-D17 Has Hole That Passes Between
Plane of Door
10/27/2021
CARD 21-29774
Fire Door Sweep Missing Screw
11/03/2021
CARD 21-29778
R2-13 Fire Door has Torn Seal
11/03/2021
CARD 21-29779
TRM Fire Door RM2-2 Seal Degrading
11/03/2021
CARD 21-29820
Different Model Pump Installed Without Documentation
11/04/2021
CARD 21-29957
TRM/Halon Fire Door Has Degraded Seal
11/08/2021
CARD 21-30057
Review Recent OE for Sequoyah Apparent Violation - Failure
to Maintain Effective EP Plan
11/11/2021
CARD 21-30110
Transient Combustible Permit Posted and Not Approved by
NFPS
11/12/2021
CARD 21-30117
Transient Combustible Permit (TCP) Description of Material
is Not Accurate
11/12/2021
CARD 21-30521
Transient Combustible Permit Expire 11/29/21 with No 50.59
in place post 90 days
11/29/2021
CARD 21-30550
Transient Combustible Permits Expire 12/1/21 with No 50.59
in Place Post 90 Days
11/30/2021
CARD 21-30609
MDCT 'B' Fan Brake BOP N2 Bottle Change Out
2/01/2021
CARD 21-31105
Condition of the Alternate Diesel Fire Pump
2/16/2021
CARD 21-31190
Broken Yoke on Electric Fire Pump Discharge Strainer Drain
Valve
2/20/2021
CARD 22-10239
Radiological Contamination Concern
05/19/2022
CARD 22-20008
Investigate Not Performing Increased Frequency Testing for
G1100F019
01/02/2022
CARD 22-20233
Alternate Diesel Fire Pump Failed to Start
01/07/2022
CARD 22-20297
Alternate Diesel Fire Pump Cold Weather Maintenance Not
Performed in Timely Manner
01/11/2022
CARD 22-20302
UFSAR Figure 9.1-3 Sheet 3 Contains Statement That
Doesn't Appear to be Implemented in Plant Procedures
01/11/2022
CARD 22-20358
Transient Combustibles Found with Permit
01/12/2022
CARD 22-20361
Transient Combustibles Found Without Permit
01/12/2022
CARD 22-20406
Transient Combustible Permits Expire 1/13/22 with No 50.59
01/12/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
in Place Post 90 Days
CARD 22-20709
Expired Transient Combustible Permit
01/25/2022
CARD 22-20769
Level 2 Tagging Event: Protection Contract Not Established
01/26/2022
CARD 22-21138
Transient Combustible Permit Not Updated on Staged
Material
2/04/2022
CARD 22-21190
Extent of Condition Review of Security Rules Violation
(Tailgating) Reveal Error in Security Access
2/05/2022
CARD 22-21345
NRC Violation - 4Q2021: Improper Storage of Equipment in
Auxiliary Building
2/07/2022
CARD 22-21432
RF21-Emerging Trend-Transient Combustible Permit
Non-Adherence
2/09/2022
CARD 22-21435
RF21-Emerging Trend-Transient Combustible Permit
non-adherence
2/09/2022
CARD 22-21453
NQA-RF21-Expired Transient Combustible Permit on RB-2
2/09/2022
CARD 22-21463
Fatigue Management-Fatigue Rule Violation
2/09/2022
CARD 22-21563
Over Thrust of E1150F024A While Testing
2/11/2022
CARD 22-21630
RP Technician Received Dose Rate Alarm during Changing
Conditions Survey Under Hotwell
2/12/2022
CARD 22-21639
Security CLO-Officer Failed to Obtain Trip Ticket and
Complete Prior to RCA Entry
2/12/2022
CARD 22-21710
Combustible Material Being Stored Exclusion Area Reactor
Building 1st Floor
2/13/2022
CARD 22-21789
Failure to Identify High Risk Activity
2/12/2022
CARD 22-21813
PCEs and Room Contamination While Cutting Pipe
2/15/2022
CARD 22-21831
Transient Combustibles Found with no Permit Posted
2/15/2022
CARD 22-22189
E11A-K7A was out of Tolerance for Pick-Up
2/20/2022
CARD 22-22578
Faulted Secondary Side Cable (64 Transformer)
2/24/2022
CARD 22-22664
Transient Combustibles Found Without Permit
2/25/2022
CARD 22-22819
Expired Transient Combustible Permit
2/28/2022
CARD 22-23197
EM3-1 Removing Access Due to Personal Action Not on
Observed Behavior, Retaliation, and Retribution
09/02/2023
CARD 22-23466
Security CLO-Information Not Entered is SSIS for FFS Tests
03/11/2022
CARD 22-23471
Expired Transient Combustible Permit on Tool Box
03/11/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 22-23901
Request Engineering evaluation for Feedwater 'B' Check
Valve Closed Indication
03/19/2022
CARD 22-24042
Staged Material Has No Transient Combustible Permit (TCP)
03/22/2022
CARD 22-24043
Staged Material Has No Transient Combustible Permit (TCP)
03/22/2022
CARD 22-24511
Allegation Involving Inattentiveness in PA
03/31/2022
CARD 22-24613
As-Found Inspection of E1101B001B Indicates Bypass Flow
Present in Heat Exchanger
04/03/2022
CARD 22-24854
DIV I Pilot Cell Out of Tolerance
04/07/2022
CARD 22-25257
Transient Combustibles Found without Permit
04/15/2022
CARD 22-25338
Transient Combustibles Found without Permit
04/18/2022
CARD 22-25567
Operator Concerns
04/23/2022
CARD 22-25608
Heat Stress Event - RB
04/24/2022
CARD 22-25642
Allegation Regarding FFD Policy Violation
04/25/2022
CARD 22-25830
Abnormal Rattling Noise Coming from RPS MF Set 'A'
04/30/2022
CARD 22-26193
NRC Violation-1Q2022: Failure to Establish Periodic
Inspection and Maintenance of the Alternate Diesel Fire
Pump Engine Fuel-Water Separator
05/10/2022
CARD 22-26195
NRC Violation-1Q2022: Failure to Identify an Adverse
Containment Isolation Valve Stroke Time
05/10/2022
CARD 22-26481
PAP Radiological Alarm and Follow-up
05/20/2022
CARD 22-26548
9D14 Trip of 72EB 2D Breaker
05/25/2022
CARD 22-26597
PC PM Z250 Will be Going Past its Critical Complete Date of
06/30/2022
05/26/2022
CARD 22-26674
Oil Dipstick Detached Into Gear Reducer Reservoir
05/30/2022
CARD 22-26742
Individual Granted Unescorted Access without Proper
Background Type
06/01/2022
CARD 22-27022
Drywell Unidentified Leakage Increasing
06/10/2022
CARD 22-27121
22 Fire Protection Program Self Assessment
Recommendation-Timely Closure of Fire Impairments
06/14/2022
CARD 22-27465
Expired Transient Combustible Permit
06/27/2022
CARD 22-27469
PM Deferral of H445 Conflicts with MES83-101 Comittment
06/27/2022
CARD 22-27710
NRC Identified-Fire Protection CARDs Being Classified as
NCAP
07/05/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 22-27927
No Transient Combustible Obtained
07/14/2022
CARD 22-27982
Security Diesel Appears to Have an Auto Start Signal
07/17/2022
CARD 22-28248
Loss of power to EDG 14 Auxiliaries Skid
07/27/2022
CARD 22-28632
22 NRC DBAI Inspection: Full RCA Access Not Given to
NRC Inspector
08/10/2022
CARD 22-28638
NRC Violation-2Q2022: Unsecured and Unapproved Ladder
Near Safety Related Equipment
08/11/2022
CARD 22-28639
NRC Violation-2Q2022: Fire Protection Equipment Blocked
08/11/2022
CARD 22-28639
NRC Violation - 2Q2022: Fire Protection Equipment Blocked
08/11/2022
CARD 22-28738
22 NRC DBAI Inspection: MES27 Evaluation Does Not
Support the Immediate Operability Determination
Assumptions in CARD 22-28664
08/15/2022
CARD 22-28758
USA NSCA 2022 - Negative Observation Noted in Attribute
RC.1, SCWE Policy
08/15/2022
CARD 22-29197
FFD Policy Violation Part 26
08/31/2022
CARD 22-29495
Conflict Between MGA30 and 10CFR2.390
09/12/2022
CARD 22-29498
Uptick in Security Loggable Events of Security Rules
Violations Associated with Vital Area Doors Left Insecure
09/12/2022
CARD 22-29529
RCIC Latent Issue Review-Lower Than Expected RCIC Flow
during Latest Surveillance Run
09/13/2022
CARD 22-29722
No Transient Combustible Permit
09/20/2022
CARD 22-29893
NRC Identified Potentially Improper Fire Watch Performance
09/26/2022
CARD 22-30004
Procedure Performed Out of Sequence (Mispositioned
Component)
09/29/2022
CARD 22-30116
NRC Identified-Leaking SLC Bolted Connections Not
Inspected during RF21
10/04/2022
CARD 22-30665
Expired Transient Combustible Permits
10/27/2022
CARD 22-31017
NRC Violation-3Q022: Actuator-Yoke Separation on a Main
Steam Line Drain Primary Containment Isolation Valve
11/10/2022
CARD 22-31150
Contractor in Protected Area with Expired Training
11/16/2022
CARD 22-31461
Supplemental Employee in PA with expired PAT
11/30/2022
CARD 23-10123
New CA Process Implementation / Communication Concerns
04/19/2023
CARD 23-20148
Wrong DLR Taken at Exchange and Used for Entry into RCA
01/05/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 23-20857
PT Event Not Completed by Critical Date
01/31/2023
CARD 23-21049
Perceived Reluctance to Submit CARDs Against
Management
01/05/2023
CARD 23-21307
NRC Violation - 2022 Security Target Set
2/16/2023
CARD 23-21357
NRC Violation 4Q2022:Failure to Monitor Moderate Energy
Line Break Flood Barriers
2/17/2023
CARD 23-21360
NRC Violation - 4Q2022: Failure to Follow Housekeeping
Procedure on Residual Heat Removal Complex (Ultimate
Heat Sink) Roof
2/17/2023
CARD 23-21363
NRC Violation-4Q2022: Failure to Perform a Required Code
Evaluations for Standby Liquid Control System Leakage
2/17/2023
CARD 23-22040
Lost Indication of D MDCT Fan in High Speed
03/17/2023
CARD 23-22040
Lost Indication of D MDCT Fan in High Speed
03/13/2023
CARD 23-22088
Missing Fill Boards Found during E1156B002A MDCT
03/14/2023
CARD 23-22102
Expired Transient Combustible Permit
03/15/2023
CARD 23-22102
Expired Transient Combustible Permit
03/15/2023
CARD 23-22192
Missed hourly Firewatch Rounds in the Residual Heat
Removal Building (RHR)
03/17/2023
CARD 23-22304
Site Management Use of CARD Amnesty Program to Avoid
Addressing Employee Concerns
03/22/2023
CARD 23-22409
PTT SF10 Not Performed for South Security Diesel
Generator
03/27/2023
CARD 23-22645
Individual in the Protected Area (PA) with an Expired 5-year
Reinvestigation
04/05/2023
CARD 23-22684
License Renewal-B.1.27 Neutron Absorbing Material
Monitoring AMP-Revise Critical Dates of PTTs LE63 and
LE64
04/06/2023
CARD 23-23081
2F-3A Delayed Closure
04/26/2023
CARD-22-30462
22 NRC Heat Sink Inspection: Poor Housekeeping Noted
during Walkdown
10/18/2022
CR 2023-30373
Debris Found Floating in the CST
05/20/2023
CR 2023-32737
Locked High Radiation Area Door Was Unsecured
08/31/2023
CR-2023-30155
23 PI&R FSA - CARD 22-00396 Quality Issues
06/06/2023
CR-2023-30181
23 PI&R FSA - Minor Administrative Issue Associated with
05/15/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 21-25536
CR-2023-30306
23 PI&R FSA Deficiency - Quality Issues with CARD
21-30537
05/18/2023
CR-2023-30359
E4150F003 Packing Leak
05/19/2023
CR-2023-30416
MDCT Fan 'A' and 'D' Brake Nitrogen Pressure Low
05/22/2023
CR-2023-31183
NRC Identified: Expired Transient Combustible Permit
06/26/2023
CR-2023-31506
Individual Maintaining UAA with Expired Training
07/11/2023
CR-2023-31645
Rollup CR of Aggregate MDCT Problems
07/18/2023
CR-2023-32034
Spurious Seismic System Trouble Alarm Caused by HPCI
Room Accelerometer
08/01/2023
CR-2023-32065
Fire Protection Events Past Critical
08/02/2023
CR-2023-32161
NRC Concern: Material Staged in DC MCC Area with
Expired Transient Combustible Permit
08/07/2023
CR-2023-32316
CAP Cause Evaluation Timeliness Did Not Meet Target for
July
08/15/2023
CR-2023-32360
PO-23: 6-Hour Impact to Refuel Floor Critical Path
08/28/2023
CR-2023-32407
NRC Identified: Items Stored on RB-3 without a Posted
Transient Combustible Permit
08/18/2023
CR-2023-32672
Prioritization of Refuel Floor Work Activities Increased Both
Industrial Safety and Radiological Risk
08/29/2023
CR-2023-32778
Unnecessary Dose Received When Two Techs Were
Directed to Enter the Drywell Basement to Take Pictures of a
Condition Already Reported
09/02/2023
CR-2023-32783
23 PCE No. 2 Individual Contaminated in
Non-Contaminated Area of NW Quad Sub Basement
09/03/2023
CR-2023-32846
Evaluate Respirator Qualifications
09/06/2023
CR-2023-33107
RHR Lower Roof Walkdown Observations
09/15/2023
CR 2023-33528
23 NRC PI&R Inspection - NRC Identified: NRC Concern
Related to Current Station CARC Classification Practices
10/04/2023
CR-2023-33183
23 NRC PI&R Inspection Observation - NRC Identified:
Lack of Written Guidance for Initial ECP Screening of
Anonymous CRs
09/20/2023
Corrective Action
Documents
Resulting from
Inspection
CR-2023-33184
23 NRC PI&R Inspection - NRC Identified: Monitoring
Measures for CR Initiation Timeliness
09/20/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2023-33221
23 NRC PI&R Inspection: NRC Identified Housekeeping /
09/21/2023
CR-2023-33334
23 NRC PI&R Inspection: NRC Identified Unrequired PTT
Event Category
09/26/2023
CR-2023-33381
23 NRC PI&R - Documentation Error in Closure Summery
for CARC CARD 21-24048
09/28/2023
CR-2023-33501
23 NRC PI&R Inspection: NRC Identified: Need to
Re-screen CARD 22-20709-Expired Transient Combustible
Permit
10/03/2023
CR-2023-33970
23 NRC PI&R Inspection: PO 23-01 Drywell 2nd Floor
Entry Deviations from RWP Instructions
10/24/2023
CR-2023-33980
23 NRC PI&R Inspection: Potential Safety Culture
Concern
10/25/2023
E1151/E1156 Q1-
Q2 2020 System
Health Report
07/03/2020
E1151/E1156 Q1-
Q2 2023 System
Health Report
08/10/2023
E1151/E1156 Q2-
Q3 2021 System
Health Report
10/29/2021
E1151/E1156 Q2-
Q3 2022 System
Health Report
2/22/2023
NAQA-22-0045
22 Nuclear Safety Culture Assessment (NSCA) Report
09/19/2022
NG-22-0003
Third Trimester 2021 Nuclear Safety Culture Report
2/08/2022
NG-22-0007
First Trimester 2022 Nuclear Safety Culture Report
06/28/2022
NG-22-0011
Second Trimester 2022 Nuclear Safety Culture Report
11/21/2022
NG-23-0003
Third Trimester 2022 Nuclear Safety Culture Report
2/10/2023
NG-23-0007
First Trimester 2023 Nuclear Safety Culture Report
06/30/2023
Miscellaneous
RCE23-22040
Root Cause Evaluation Report for Lost Indication of D MDCT
Fan in High Speed
Procedures
63.000.100
Radiation Work Permits
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
63.000.200
ALARA Reviews
MLS04
Operating Experience Program
37.2
MMA17
MOP11
Fire Protection
MOP11-100
Fire Protection Implementation
MOP21
Housekeeping
MQA11
Corrective Action Program
MQA11-100
Operability Determination Process
MQA11-200
Condition Initiation
MQA11-300
Screening and Assignment
MQA11-500
Non-Corrective Action Program Condition Disposition
MQA11-600
Root Cause Evaluations
MQA13
Trending
2.1
MQA13-100
CR Trend Coding and Analysis
MQA16
Self-Assessment
16.2
MRP04
Accessing and Working in the Radiologically Controlled Area
(RCA)
MWC15
Elevated Risk Management
Radiation Work
Permits (RWPs)
231029
Drywell / Reactor Building Steam Tunnel Emergent Work
LIR - HPCI
High Pressure Injection Latent Issues Review
2/04/2022
NAPI-21-0002
Formal Self-Assessment of the Operating Experience
Program
04/08/2021
NAPI-23-0006
Problem Identification and Resolution (PI&R) Formal
Self-Assessment
07/11/2023
NJPR-23-0013
Quick Hit Self-Assessment Report: License Renewal Cable
Vault Sump Repairs
07/07/2023
NPMA-22-0050
Quick Hit Self-Assessment of Rework Program
2/20/2022
NPRP-21-0072
(QH)
Quick Hit Self-Assessment: 71124.01, Radiological Hazard
Assessment and Exposure Control
2/06/2021
NPRP-22-0062
Quick Hit Self-Assessment 2021 Online RWP Dose and
Dose Rate Set Points
09/26/2022
Self-Assessments
NPRP-22-0064
QHSA Industry Best Practice to Assess HRA/LHRA
09/28/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NPRP-23-0031
Quick Hit Self-Assessment: NRC Inspection 71124.04 -
Occupational
04/20/2023
NSSE-22-0005
Quick Hit Self-Assessment Report: Security Equipment
Performance, Testing, and Maintenance
2/01/2022
NSSE-22-0040
Formal Self-Assessment Report: Fitness For Duty Program -
08/15/2022
NSSE-22-0057
Quick Hit Self-Assessment Report: Part 37 Security Plan
2/29/2022
TMIS-22-0031
Fermi II Fire Protection Program (FPP) Self-Assessment,
May 2022
06/02/2022
TMPE-22-0095
Quick Hit Self-Assessment Report: Technical Conscience
Self-Assessment
10/12/2022
TMTE-22-0005
Quick Hit Self-Assessment Report: Equipment Reliability
Process
01/18/2022
TMTE-22-0024
Latent Issue Review Report: Reactor Core Isolation Cooling
(RCIC) Latent Issue Review
10/13/2022