IR 05000341/2024003
| ML24311A149 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/06/2024 |
| From: | Dariusz Szwarc NRC/RGN-III/DORS/RPB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2024003 | |
| Download: ML24311A149 (1) | |
Text
SUBJECT:
FERMI POWER PLANT, UNIT 2 - INTEGRATED INSPECTION REPORT 05000341/2024003
Dear Peter Dietrich:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On October 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.
Four findings of very low safety significance (Green) are documented in this report. Two 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 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.
November 6, 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, Dariusz Szwarc, 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:
NPF-43 Report Number:
05000341/2024003 Enterprise Identifier:
I2024003-0060 Licensee:
DTE Electric Company Facility:
Fermi Power Plant, Unit 2 Location:
Newport, MI Inspection Dates:
July 01, 2024, to September 30, 2024 Inspectors:
J. Gewargis, Resident Inspector R. Ng, Senior Project Engineer J. Reed, Health Physicist T. Taylor, Senior Resident Inspector B. Towne, Senior Resident Inspector Approved By:
Dariusz Szwarc, 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
Transient Combustibles in Reactor Building without Permits Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000341/202400301 Open/Closed
[H.8] -
Procedure Adherence 71111.05 The inspectors identified a Green finding and associated NCV of license condition 2.C.(9),
Modifications for Fire Protection, when the licensee failed to implement their combustible material control program. Specifically, transient combustible material was found in several areas of the reactor building without transient combustible permits.
Failed Safety-Related Inverter due to Inappropriate Preventative Maintenance Scheduling Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202400302 Open/Closed
[H.4] -
Teamwork 71111.12 A Green finding with an associated NCV of Technical Specification 5.4.1, Procedures, was self-revealed when inverter R31K005001, VITAL PWR DIST 120 VAC DIV2 2KVA INVERTER, failed. The preventative maintenance (PM) frequency for inverter replacement was extended outside the requirements of licensee procedure MES51, Preventative Maintenance Program.
Operability Determination Lacking Technical Basis for a Control Center Heating, Ventilation, and Air Conditioning Chilled Water Instrument Line Leak Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202400303 Open/Closed
[H.1] -
Resources 71111.15 The inspectors identified a Green finding when the licensee failed to follow site procedure MQA11100, Operability Determination Process. Specifically, the licensee did not complete a comprehensive and thorough examination of the impact chilled water leakage had on the operability of the division 2 control center heating, ventilation, and air conditioning (CCHVAC)system following identification of the leakage in condition report (CR) 202440402.
Failure of Relay in Main Turbine Control Circuit Causes a High-Pressure Scram Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000341/202400304 Open/Closed None (NPP)71152A A self-revealed Green finding was identified when the licensee failed to identify a single point vulnerability (SPV) in accordance with Fermi Business Practice (FBP)-65,
Single Point Vulnerabilities. Specifically, the licensee failed to identify the RL16 load block relay as a vulnerability in the main turbine control (MTC) system, leading to a high-pressure scram when it failed during the planned reactor shutdown for refueling outage 22 (RF22).
Additional Tracking Items
None.
PLANT STATUS
Fermi Unit 2 began the quarter at or near 100 percent rated thermal power and remained at that level for the remainder of the period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed onsite portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Standby Feedwater (SBFW) during the week ending July 20, 2024
- (2) Emergency diesel generator (EDG) 11 walkdown during D2 crankcase mod the week ending July 27, 2024
- (3) Electric fire pump during maintenance on the diesel fire pump, completed the week ending August 10, 2024
- (4) Division 2 emergency equipment cooling/service water during division 1 maintenance, completed the week ending September 28, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Reactor water cleanup (RWCU) heat exchanger room during the week ending July 27, 2024
- (2) Reactor building 4 - reactor recirculation motor generator set area during the week ending July 27, 2024
- (3) High pressure coolant injection (HPCI) during the week ending July 27, 2024
- (4) EDG 13 engine room, residual heat removal service water ceiling louvers open and implication to carbon dioxide suppression during the week ending August 17, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the fire brigade training and performance during an onsite storage facility class A fire drill on August 8, 2024.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated an asfound scenario associated with the emergency preparedness (EP) drill on August 13, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 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) EDGs during the week ending July 20, 2024
- (2) Review of preventative maintenance activities not included in 2024 refueling outage scope, completed the week of September 30, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Loss of testability power supply inverter during the week ending August 17, 2024
- (2) Failed master trip unit associated with condensate storage tank/torus suction swap circuitry the week ending September 14, 2024
- (3) Steam tunnel temperature online risk initiating event frequency adjustment and effect on the EDG 11 safety system outage during the week ending August 31, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Past/post modification operability of EDG alarm/trip circuits during the week ending July 27, 2024
- (2) Review of environmental quality requirements for temperature instruments in the turbine building steam tunnel, completed the week ending September 21, 2024
- (3) CCHVAC chilled water leakage identified in CR202440402, during the week ending September 30, 2024
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) (5 Samples)
- (1) EDG 12 crankcase circuit modification during the week ending July 13, 2024
- (2) Diesel fire pump maintenance during the week ending September 28, 2024
- (3) Failed HPCI valve E4150F042 (fail to close) during the week ending August 31, 2024
- (4) E1150F004 Division 2 RHR torus suction isolation valve fuse replacement and restoration during the week ending September 6, 2024
- (5) EDG 13 safety system outage during the week ending September 30, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
(1)65 F bus under voltage surveillance during the week ending July 27, 2024
- (2) HOCI response time test and pump and valve operability surveillance during the week ending August 17, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Reactor core isolation cooling (RCIC) pump and valve surveillance during the week ending August 17, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) EP drill conducted on August 13,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit 2, onsite storage facility (OSSF) ventilation
- (2) Unit 2, reactor building ventilation
- (3) Unit 2, turbine building ventilation
- (4) Unit 2, division 2 standby gas treatment system
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
- (2) Radioactive waste building SPING compensatory sampling
- (3) Unit 2, division 2 standby gas treatment system SPING sample
- (4) Unit 2, containment pre-release permit and discharge
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Turbine building gaseous weekly dose calculation
- (2) Containment purge dose calculation
OTHER ACTIVITIES-BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 2 (July 1, 2023, through June 30, 2024)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) Unit 2 (July 1, 2023, through June 30, 2024)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) Unit 2 (July 1, 2023, through June 30, 2024)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) The inspectors completed their review of the information associated with the high-pressure reactor protection system (RPS) scram that occurred during the shutdown of the plant for the refueling outage.
INSPECTION RESULTS
Transient Combustibles in Reactor Building without Permits Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000341/202400301 Open/Closed
[H.8] -
Procedure Adherence 71111.05 The inspectors identified a Green finding and associated NCV of license condition 2.C.(9), Modifications for Fire Protection, when the licensee failed to implement their combustible material control program. Specifically, transient combustible material was found in several areas of the reactor building without transient combustible permits.
Description:
The inspectors performed a walkdown of the reactor water cleanup heat exchanger room on July 18, 2024. The room is located in the reactor building, a safety-related structure within the secondary containment. Upon entry, the inspectors noted piles of material throughout the room, generally consisting of plastic tubing, extension cords, portable lights, personnel protective gear, plastic sheets, a temporary ventilation fan and ductwork, rags, and various trash. The material had been brought in to perform various work activities, primarily during the refueling outage, but had never been removed from the space. The material did not constitute incidental transient combustible material, or that which could be left in the space unattended.
The inspectors inquired whether or not a transient combustible permit had approved the material to be left in the space. Discovering there was no transient combustible permit, the inspectors questioned whether or not other spaces in the reactor building, similar to the reactor water cleanup heat exchanger room (a locked high radiation area not frequently traversed), might have similar material without transient combustible permits. The licensee performed walkdowns of similar rooms in the reactor building and discovered transient combustibles being left in multiple areas without transient combustible permits.
Procedure MOP11100, Fire Protection Implementation, Section 4.1.1.3, requires individuals to not leave combustible material in the plant unless it is approved on a transient combustible permit. Permits are used to account for the total transient combustible material accumulating in various spaces of the reactor building, to ensure the overall fire loading assumptions for the reactor building continue to be met.
Corrective Actions: The licensee developed a plan to inspect and cleanup other rooms in the reactor building. The licensee evaluated the weight of the combustible materials discovered and compared it to the limits in the fire loading analysis.
Corrective Action References: CR 202441033, CR 202441459
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to implement the fire protection program is a performance deficiency that is within licensees ability to foresee and correct and should have been prevented. Specifically, transient combustible material was found in several areas of the reactor building without transient combustible permits.
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, continued failure to account for transient combustibles in multiple areas of the reactor building could adversely impact the initiating events cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Specifically, the inspectors utilized Figure F.1. The inspectors conservatively answered no to Step 1.3, because the examples provided did not match the materials found in the plant. Proceeding to step 1.4, the inspectors answered no to question 1.4.1A, screening the issue to Green. Specifically, the amount of transient combustibles found did not exceed the weights assumed in the fire hazards analysis.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, individuals did not follow procedures associated with transient combustible controls.
Enforcement:
Violation: License condition 2.C.(9) requires, in part, that DTE Electric Company shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report (FSAR). FSAR Section 9A.1.3.2 states, in part, that the fire protection program consists of administrative controls to minimize the amount of combustibles that safety-related areas may be exposed to. Procedure MOP11100, Fire Protection Implementation, implements the administrative controls regarding combustible materials. Section 4.1.1.3 of MOP11100 states that combustible material is not to be left in the plant unattended unless it is approved on a transient combustible permit.
Contrary to the above, from approximately May 2024 (end of the refueling outage) until approximately August 2024 (when the site completed cleanup and extent of condition walkdowns in the reactor building), combustible material was left unattended in safety-related areas of the plant without an approved transient combustible permit.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failed Safety-Related Inverter due to Inappropriate Preventative Maintenance Scheduling Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202400302 Open/Closed
[H.4] -
Teamwork 71111.12 A Green finding with an associated NCV of Technical Specification 5.4.1, Procedures, was self-revealed when inverter R31K005001, VITAL PWR DIST 120 VAC DIV2 2KVA INVERTER, failed. The preventative maintenance (PM) frequency for inverter replacement was extended outside the requirements of licensee procedure MES51, Preventative Maintenance Program.
Description:
On August 10, 2024, operators received an alarm and discovered Nova inverter R31K005001 had failed. Loads supplied from the inverter included various safety-related division 2 instruments associated with the following systems: core spray, automatic depressurization, high pressure coolant injection, reactor core isolation cooling, low level set, reactor recirculation motor generator sets, and high reactor water level trip circuits.
Generally, the loads were associated with various safety-related trip and isolation functions covered under Technical Specifications. However, the loads remained powered and functional because power was auctioneered from another inverter. No Technical Specification action statements were entered. The licensee developed a plan and successfully replaced the failed inverter online (normally the PM activity to replace the inverter was performed during plant outages due to the risk to nearby circuits).
The inspectors noted a maintenance department memo (NPMA240017) approving deferral of non-critical low PM activities was published on March 20, 2024, a few days before the spring 2024 refueling outage. The memo contained a list of PMs generally performed during refueling outages. The PMs were originally intended to be performed during the spring 2024 refueling outage to ensure they would be complete prior to their critical dates, which generally fell before the next refueling outage opportunity (~ spring 2026). However, since the approved outage scope ended up not including the PMs, the memo served as justification to defer the PMs up to the end of the spring 2026 refueling outage. One of the PMs was C803, which was the replacement of inverter R31K005001.
The inspectors reviewed licensee procedure MES51, Preventative Maintenance Program, which contains requirements for deferring PMs. This procedure states that engineering department is the overall authority for critical and non-critical high components. More importantly, MES51 Section 5.4 discusses the deferral evaluation request (DER) process, which provides timelines and a structured means to evaluate the adjustment of critical dates, and includes reviews of operating experience, mitigation strategies, condition evaluations, and other facets of equipment performance. MES51 also states that equipment failure mode effects be evaluated such that input can be provided to determine preventative maintenance frequency. This process was not followed for deferral of the PMs (including C803), as the site relied on issuance of memo NPMA240017 instead. Additionally, inverter R31K005001 was a non-critical high component, which would have required engineering department approval to defer versus the maintenance department. Subsequent review by the licensee revealed approximately 20 other non-critical high activities that were inadvertently on the maintenance department list for deferment.
The inspectors also reviewed CR 202332208, which documented the failure of a different Nova inverter approximately a year prior. This CR referenced other Nova inverter failures in the past and concluded the 2023 failure was maintenance-preventable due to not incorporating an 8-year mean-time-between-failures for the PM replacement interval.
Corrective actions included a review of other Nova inverter PMs and a reduction of the replacement interval from 10 years to 8 years, with no grace. Despite these corrective actions, the critical date remained 10 years for R31K005001, and memo NPMA240017 approved an extension to essentially 12 years, since it was not scoped into the outage.
R31K005001 failed approximately 3 months after the spring 2024 refueling outage, or at approximately the 10-year point from its 2014 installation. Following the failure of R31K005001, the licensee reviewed the scheduled replacement dates for similar inverters and is developing a plan to potentially move up (and perform online) replacements for inverters currently installed that are beyond the 8-year point. Further, the licensee initiated action to review other PMs listed in memo NPMA240017 per procedure MES51.
Corrective Actions: The licensee replaced the failed inverter and is reviewing the currently scheduled replacement dates for other inverters to assess whether the dates need to be moved up.
Corrective Action References: CR 202441640, CR 202441493.
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to implement the Preventative Maintenance Program is a performance deficiency that is within licensees ability to foresee and correct and should have been prevented. Specifically, PM activity C803 to replace inverter R31K005001, was deferred without accounting for the 8-year mean-time-between-failures and the deferral was approved by the incorrect department.
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, a safety-related inverter failed, leaving one remaining auctioneered power supply to numerous safety-related instruments, prompting emergent online work to repair. Further, if left uncorrected, the performance deficiency could become a more significant safety concern. Specifically, not following procedures for changing PM critical dates could lead to further equipment issues, adversely affecting the Mitigating Systems cornerstone.
Significance: 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 were answered no under Exhibit 2 (mitigating systems screening questions).
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, better coordination and understanding of roles between departments involved in scoping outage work and ensuring DERs were performed may have ensured the inverter was replaced before failure.
Enforcement:
Violation: Technical specification 5.4.1, Procedures, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, Appendix A. Regulatory Guide 1.33 Section 9.b. states, in part, that preventive maintenance schedules should be developed to specify inspection or replacement of parts that have a specific lifetime. Contrary to the above, from March 20, 2024, until August 10, 2024, the licensee did not develop a preventative maintenance schedule for inspection or replacement of parts that have a specific lifetime.
Specifically, inverter R31K005001, VITAL PWR DIST 120 VAC DIV2 2KVA INVERTER, was inappropriately deferred despite being beyond the licensee-established 8-year lifetime.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Operability Determination Lacking Technical Basis for a Control Center Heating, Ventilation, and Air Conditioning Chilled Water Instrument Line Leak Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202400303 Open/Closed
[H.1] -
Resources 71111.15 The inspectors identified a Green finding when the licensee failed to follow site procedure MQA11100, Operability Determination Process. Specifically, the licensee did not complete a comprehensive and thorough examination of the impact chilled water leakage had on the operability of the division 2 control center heating, ventilation, and air conditioning (CCHVAC)system following identification of the leakage in condition report (CR) 202440402.
Description:
On June 19, 2024, while performing a test on the division 2 CCHVAC system, a 10 drop per minute (dpm) leak was discovered coming from an instrument line associated with the CCHVAC chilled water subsystem. The licensee-initiated CR202440402, and the operability determination incorrectly concluded the leakage was minor and would not impact the safety function of the division 2 CCHVAC system because the chilled water expansion tank would make up for the minor leakage. The chilled water system is a closed system with a non-safety-related makeup source supplied from the demineralized water system.
MQA11100, Enclosure C, is the licensees standard on what is considered non-substantive leakage for various systems. The enclosure states that for the CCHVAC chilled water system, a leakage of less than 2 dpm is non-substantive. The basis for MQA11100 Enclosure C comes from Corrective Action Record Document (CARD) 1928092, which was created in response to the NRCs revision of Inspection Manual Chapter 0326, Operability Determinations. The goal of CARD 1928092 was to create a document that operators would have as a reference when determining if a specific amount of leakage from safety-related systems were substantive enough to potentially impact operability. CARD 1928092 broadly rationalized that since the site is licensed to be able to restore ultimate heat sink (UHS)water inventory within 7 days, by crediting restoration of offsite power and non-safety-related general service water makeup to the UHS reservoirs, the site could also restore level in the CCHVAC expansion tank within 10.5 days. These 10.5 days would be the time to empty the expansion tank with a 2 dpm leak. However, the leakage identified in CR 202440402 was 10 dpm. No further evaluation was performed to demonstrate system operability with the increased leakage.
MQA11100 Section 3.3.1 requires, in part, that operability determinations be thorough and comprehensive. CR202440402 did not reference MQA11100 Enclosure C, nor CARD 1928092, while attempting to justify continued operability of the CCHVAC system with the chilled water leak. Even if referenced, CARD 1928092 provided no explanation of how makeup to the expansion tank would be accomplished through site procedures, processes, or actions. CARD 1928092 also did not provide information for why the FSAR-described actions to restore makeup to the UHS applied to the CCHVAC chill water system.
Approximately a month after the 10 dpm leakage was identified, an operator on rounds noted the leakage had increased to ~180 dpm. The licensee isolated the instrument line to stop the leakage. Since the line was only used during testing, the system became operable after isolation. The leaking fitting was subsequently repaired in accordance with site processes.
The inspectors questioned the operability of the system given the 10 dpm leakage over the 30-day mission time of the CCHVAC system. Responding to the inspectors questions regarding the operability determination made for the 10 dpm leak, the licensee performed a technical evaluation to assess past operability of the system. The evaluation discovered the water volume in the chilled water expansion tank was actually half the size assumed in CARD 1928092 (0.9 gallons versus 2 gallons). At a rate of 10 dpm, the evaluation concluded the tank would be empty in ~22 hours. The licensees past operability evaluation ultimately concluded the CCHVAC system remained operable after a review of operator actions driven from existing abnormal operating procedures expected to be entered following design-basis accidents.
Corrective Actions: The licensee isolated the line and repaired the leak. A technical evaluation and past operability assessment was performed to reevaluate the operability determination in CR 202440402.
Corrective Action References: CR202440402, CR202441183, CR202442530
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to perform a complete and thorough examination of the CCHVAC chilled water instrument line leak was a performance deficiency that is within licensees ability to foresee and correct and should have been prevented. As a result, reasonable assurance of the original determination of operability was lost following inspector questioning. This prompted the licensee to reevaluate the operability determination in CR 202440402 via an engineering technical evaluation and past operability review by operations.
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, inspector questioning led to the loss of reasonable assurance of operability, prompting additional review by the licensee. This determination was supported by the front matter of IMC 0612 Appendix E regarding inoperability not being a prerequisite for a performance deficiency to be more-than-minor, and examples 1.a, 3.a, and 3.k of IMC 0612 Appendix E.
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. Specifically, the CCHVAC chilled water systems safety function is not modeled in the PRA analysis.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the site did not ensure that MQA11100 Enclosure C and CARD 1928092 provided accurate and sufficient information to support nuclear safety with respect to system leakage guidance.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure of Relay in Main Turbine Control Circuit Causes a High-Pressure Scram Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000341/202400304 Open/Closed None (NPP)71152A A self-revealed Green finding was identified when the licensee failed to identify a single point vulnerability (SPV) in accordance with Fermi Business Practice (FBP)-65, Single Point Vulnerabilities. Specifically, the licensee failed to identify the RL16 load block relay as a vulnerability in the main turbine control (MTC) system, leading to a high-pressure scram when it failed during the planned reactor shutdown for refueling outage 22 (RF22).
Description:
On March 23, 2024, the reactor automatically scrammed on high pressure during the planned shutdown for RF22. At approximately 22 percent power, operators were unloading the turbine by gradually closing the turbine control valves (TCVs), causing the turbine bypass valves (TBVs) to gradually open for pressure/temperature control of the reactor following shutdown.
During this time, the TBVs unexpectedly and rapidly went closed. The sudden closure of the TBVs led to an increase in reactor pressure, causing the reactor protection system to initiate a reactor scram. The operators responded to the scram in accordance with site procedures and no challenges were encountered in achieving shutdown or stabilizing the plant.
Subsequent licensee investigation of the turbine control circuitry revealed the RL16 relay in the narrow range speed governing (NRSG) circuit failed, causing the TBVs to close.
The RL16 relay provides a signal to add load to the turbine during synchronization to prevent reverse-powering the generator. While always present when the generator is online, the signal has a more profound impact on TBV and TCV positions at low power. Multiple contacts in the relay developed a high resistance, which the control system interpreted as an error, leading to TBV closure as designed. The relay had never been replaced nor tested since original installation of the turbine controls system.
The licensees root cause evaluation identified several issues with the sites implementation of programs to identify subcomponents in critical systems that could lead to reactor scrams.
In 2015, the licensee generated CARD 1525138 and CARD 1525139 in response to industry feedback regarding weaknesses in identifying such vulnerabilities. The CARDs drove development and review of several site programs to look at aging and other vulnerabilities in critical systems, such as the turbine controls system. Licensee program FBP65, Single Point Vulnerability, was utilized to look for and manage previously unidentified single point vulnerabilities at the subcomponent level. Specifically, FBP65 Section 1.2 requires that SPVs are identified, available for reference, and recognized by plant personnel. Further, processes are in place to recognize when a situational SPV is present and that risk mitigation actions are taken during the period of time when a situational SPV exists. While other portions of the turbine control circuitry were scrutinized (including those functionally tested by existing surveillance procedures), the NRSG portion of the turbine control circuitry was not reviewed. Of note, the RL16 relay function had never been challenged, as it was not part of the routine surveillance procedures. Therefore, no mechanism existed to check the health of this function, nor its potential impact should a failure occur.
Additionally, the root cause evaluation identified that the 2015 vulnerability assessment was inadequate due to improperly assuming the multi-channel nature of the control circuitry would negate impacts of failures from relays such as RL16. However, the relay was common to all three channels which allowed the specific failure mechanism to defeat the three-channel redundancy.
Corrective Actions: The failed relay was replaced, and corrective actions exist to reassess the turbine controls system for vulnerabilities. Specifically, a corrective action exists to review these relay types for potential inclusion in the preventative maintenance program going forward.
Corrective Action References: CR202437148
Performance Assessment:
Performance Deficiency: The inspectors determined the licensees failure to follow FBP65, Single Point Vulnerabilities, was a performance deficiency. Specifically, the licensee failed to identify and recognize the RL16 relay as a vulnerability and failed to implement processes that mitigate times when a situational vulnerability exists.
Screening: The inspectors determined the performance deficiency was more-than-minor because it was associated with the Equipment Performance 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 identify and implement processes to mitigate relay RL16 as a single point vulnerability led to a high-pressure reactor scram.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, Exhibit 1, Initiating Events Screening Questions, Section B, Question 1, was answered no. The finding did cause a reactor trip but not a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
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:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 17, 2024, the inspectors presented the integrated inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer, and other members of the licensee staff.
- On August 2, 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
CARD 1928718
SBFW Exceeded its Maintenance Rule Performance
Criteria
11/13/2019
CARD 2231714
Inadequate Monitoring of CST Level
2/10/2022
CARD 2320712
Maintenance Rule Evaluations Not Identified at Time of
Event
01/26/2023
Corrective Action
Documents
CR202330109
SBFW System Exceeded MR Criteria for Out of Service
Hours
05/10/2023
M2046
P&ID Diesel Generator System Division 1 RHR Complex
M2048
P&ID Diesel Fuel Oil System and Lube Oil Division 1 RHR
Complex
M21351
Diagram-Fire Protection System-Sheet 2
M57153
Standby Feedwater System Functional Operating Sketch
O
Drawings
M57292
Emergency Equipment Cooling Water (Division 2)
Functional Operating Sketch
BE
Procedures
23.307
Emergency Diesel Generator System
Calculations
DC5702
Fire Loading Calculation
N
CR202439807
EDG13 Engine Room Return Air Damper Failed Open
05/23/2024
Corrective Action
Documents
CR202441459
Potential Trend in Housekeeping Issues Identified in
Locked Areas of Reactor Building
08/08/2024
Corrective Action
Documents
Resulting from
Inspection
CR202441033
NRC Identified: Material Stored in RWCU Hx Room
Appears Not to be in Compliance with Plant Procedures
07/18/2024
IN276103
Schematic Diagram: RHR DG Room Vent Supply Fans
X4103C005 and X4103C006
T
Drawings
IN286803
Schematic Diagram Diesel Generator 13 Room CO2 Fire
Protection System and Fire Protection Sprinkler System
Alarm-Division II
O
FPOSSF146
Onsite Storage Facility, Zone 46
Fire Plans
FPRB417b
Reactor Building Recirculation System Motor Generator
Area, Zone 17, EL. 659'6"
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
FPRB-SB4a
High Pressure Coolant Injection Pump and Turbine Room,
Zone 4
FPRHR113-EDG
RHR Complex, EDG 13 Room, El. 590'0"
Miscellaneous
LPFP9400234
Fire Drill: Drum Compactor Room, Onsite Storage Facility
El. 503' 6"
MOP11
Fire Protection
Procedures
MOP11100
Fire Protection Implementation
Miscellaneous
Scenario
SSER8802403
100% Power/EDG14 OOS
08/04/2024
CARD 0012429
Mild Environment Qualified Life for Governor Components
to be Installed as Part of EDP 27238 is Less Than
Years
03/24/2000
CARD 0116009
EDG Reliability Review-PM Program
06/11/2001
CARD 0212802
Evaluate NRC Information Notice 200207
2/13/2003
CARD 0213774
Evaluate MPR EDG PM Recommendations
03/15/2002
CARD 0821759
Evaluate Material Condition of R1700 RHR Inverters
03/12/2008
CARD 1327891
Technical Requirements Not Meet on PM I095
11/02/2013
CARD 1427068
Light Lit on Div. 2 Digital Load Sequencer
09/08/2014
CARD 1427952
Self-Assessment Deficiency: CT1, CT2, CT3, CT4, CT5
PM Enhancement
10/09/2010
CARD 1721170
R1700S011A Inverter Not Outputting as Expected
2/09/2017
CARD 2126696
Degraded Coating Identified EDG 12 Expansion Tank
During License Renewal Inspection
08/02/2021
CARD 2126707
Chipped Gear on Vertical Drive Ring and Pinion
08/03/2021
CARD 2127397
Division 2 EDG Automatic Load Sequencer Power Supply
(PS2) Failed
08/23/2021
CARD 2128107
EDG13 Fast Start Time 8.76 s
09/13/2021
CARD 2129215
Degraded Coating Identified in EDG14 Expansion Tank
During License Renewal Inspection
10/18/2021
CARD 2129384
Evaluation of Existing PMs for EDGs
10/22/2021
CARD 2131211
9D21 Div. I EDG Sequencer Trouble
2/20/2021
Corrective Action
Documents
CARD 2220343
EDG 12 Was Declared Inoperable Due to the Standby
Lube Oil Pump Degrading
01/11/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 2228021
Camshaft Thrust Collar Locknut Found Loose but Secure
During 24Month Inspection
07/19/2022
CARD 2228022
EDG 13 Generator Rotor Field Poles Possible
Abnormalities
07/19/2022
CARD 2228248
Loss of Power to EDG 14 Auxiliaries Skid
07/27/2022
CARD 2229684
Degraded Trend in EDG14 Fast Start Time
09/19/2022
CARD 2230875
Fairbanks Morse Part 21 on 2301A Governor Modules
11/04/2022
CARD 2321595
Lube Oil Leak Worsened from EDG 12 Flexible Coupling
2/26/2023
CR202332208
1D58 - STM LK DET RCIC LOGIC POWER FAILURE and
1D62 - STM LK DET HPCI LOGIC POWER FAILURE
Received Simultaneously
08/09/2023
CR202435655
LRI OE Review: External Surfaces Monitoring: Emergency
Diesel Generator Exhaust Fire
01/17/2024
CR202436826
Critical and Non-Crit High Equipment Not Scoped in F22
are Recommended to be Reviewed for Monitoring Plan
03/11/2024
CR202438990
EDG 13 Start and Load Time Degradation
05/01/2024
CR202440450
Nuclear Oversight - Risks Unclear in Memo Addressing
PMs Not Selected for RF22 Scoping
06/21/2024
CR202441493
2D5 Testability Div 2 ECCS Power Failure
08/10/2024
CR202441640
Non-Critical High PM Deferred Improperly as Non-Critical
Low
08/17/2024
CR202441758
PMs Incorrectly Identified as Non-Crit Low
08/23/2024
CR202442042
Not in Compliance with MES51 - PM Program R22 PMs
09/05/2024
CR202442320
Extent of Condition Results for RF21 Deferred
09/18/2024
CR202441082
NRC Identified-Mismatch Between PM Frequency and
Capacitor Lifespan for PM I935 and I936
07/22/2024
Corrective Action
Documents
Resulting from
Inspection
CR202441142
NRC Identified - PM Criticality on R3001B033B036 EDG
Generator Space Heaters is Incorrect
07/24/2024
I257343
Schematic Diagram 480V ESS Bus 72B and 72C Load
Shedding Strings
P
Drawings
IN257251
Schematic Diagram 4160V ESS Diesel Bus 11EA Pos EA3
X
Engineering
Evaluations
TEELC17046
Evaluation of GE HFA Relay Service Life
09/30/2010
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
EFA-R1708-005
Evaluate Material Condition of Invertor R1700S01B to
Support Division 2 RHR Cooling Tower Fan Overspeed
Protection System
Miscellaneous
Nuclear Generation
Memorandum
NCL PM Request or Deferrals
03/20/2024
34.307.001
Emergency Diesel Generators-Inspection and
Preventative Maintenance
Procedures
MES51
Preventive Maintenance Program
24.1
43792728
Replace EDG DIV 2 Load Sequencer Power Supplies
01/21/2018
2424430
Refurbish 2301A and (DRU) Unit in EDG13 Control Panel
01/27/2020
56641508
Replace 2301A and DRU Unit in EDG 12 Control Panel
08/02/2021
E670200100
Refurbish EDG11 Air Coolant Temperature Control Valve
05/01/2023
Work Orders
F262140100
EDG 13 Main Fuel Oil Tank Cleaning
01/25/2016
CR202441493
2D5 Testability Div 2 ECCS Power Failure
08/10/2024
CR202441501
Evaluation of E21K601A/B (Div 1/2 CS DC & AC
INVERTER PWR SPLY) Component Criticality is Needed
08/12/2024
Corrective Action
Documents
CR202442192
Blown Fuse E41F2B in H21P081 Panel
09/12/2024
Corrective Action
Documents
Resulting from
Inspection
CR202441390
CLO-Sh 3 Failure to Update a Risk Condition from Phoenix
08/06/2024
Drawings
I222510
HPCI System T/U CAB PWR DISTR Testability
Modification
Z
MWC15001:
262.05.01
Risk Management Plan: 44.040.001 ATWS/SRV Low Low
Set Rx Pressure, Div. I, Functional Test
07/23/2024
Miscellaneous
MWC15001:
262.05.01
44.030.263 ECCS-Reactor Vessel Water Level
(ADS Level 3 and Feedwater/Main Turbine Level 8)
Division I, Channel Functional Test
07/23/2024
23.601
Instrument Trip Sheets
MMR Appendix H
Online Core Damage Risk Management Guidelines
Procedures
MMR12
Equipment Out of Service Risk Management
20A
Work Orders
46697020
Perform 24 Month PM Task Per 34.307.001 on Emergency
Diesel Generator-11
08/06/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 1928092
IMC 0326 Regarding Operability Determinations has been
Revised
10/24/2019
CR202331907
EQ Margin for Design and Licensing Basis of RB1 and TB
Steam Tunnel Normal Temperatures
07/26/2023
CR202440402
Approximately 10 DPM Water Leak from Div. 2 CCHVAC
Chilled Water Pump Instrument Line
06/19/2024
CR202440830
Field Wiring Discrepancies from W/D IN271251
07/10/2024
CR202440891
Wiring Discrepancies Found During EDG 12 Crank Case
Pressure Logic Change - 66283065
07/15/2024
Corrective Action
Documents
CR202441183
Leak from T4100F375 Instrument Line
07/26/2024
Corrective Action
Documents
Resulting from
Inspection
CR202442530
NRC Identified Operability Quality for CR202440402 Did
Not Provide Enough Detail to Explain Bases for Operability
09/27/2024
EDP80187C02.001
Diesel Generator
Drawings
EDP80187C02.002
EDG 12
Engineering
Evaluations
TET4124-031
Leak in T4100F375 Instrumentation Line Past Operability
Evaluation
08/12/2024
Various Shiftly/Daily - Mode 1, 2, 3 - Plant Logs
May -
August 2024
Miscellaneous
EQ1EF2260
Resistance Temperature Detector (RTD)
D
CARD 2121692
Loss of Indication E1150F004B RHR Pump B Torus
Suction Isolation Valve
2/23/2021
CR202440874
Critical Path Delays for EDG12 Crankcase EDP SSO
07/12/2024
CR202441282
E5150F025 RCIC Turb Steam Drain Pot Inboard Isolation
Valve Exceeded Owner Specified Stroke Time Open
08/01/2024
CR202441445
Procedure Change Needed for DFP SOP Run with
23.501.01
08/07/2024
CR202442155
Wiring Error
09/11/2024
Corrective Action
Documents
CR202442162
Wiring on Wrong Terminal
09/12/2024
6I721N271124
Schematic Diagram Diesel Generator 12 Control Part 1
AJ
Drawings
Piping Isometric-Drain Pot Drain Line to Main Condenser
Reactor Building
P
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
I220107
Schematic Diagram Suppression Pool to
Pump B Valve E1150F004B
R
I222108
Schematic Diagram HPCI System Suppression Pool
Isolation Valves E4150F041 and E4150F042
Z
I2335062
Control Module B709565
D
I233510
Maintenance Drawing Cubicle Location 11-05
C
IN271130
Schematic Diagram Diesel Generator 13 Control Part 1
AG
IN271131
Schematic Diagram Diesel Generator 13 Control Part 2
IN271260
Wiring Diagram Diesel Generator #13 RLY Cabinet
R30P331
N
M57091
Reactor Core Isolation Cooling (RCIC) System Sketch
MOP01
Conduct of Operations
Engineering
Evaluations
IST Evaluation:
24019
IST Evaluation: RCIC E5150F025 Stroke Time
10/17/2024
DCP80187
Change EDG Crankcase Overpressure Trips from
Essential to Non-Essential
DCP80187C02
Logic Changes for EDG 12 Crankcase Pressure Trip
Moved to Non-Essential Trip
SOE2405
Test and Review PMT logic function of
Modified EDG 12 Logic
Miscellaneous
SOE: 2406
Logic System Functional Test of Division 2 EDG ECCS
Emergency Start Circuits and Auto Trip/Bypass Circuits
24.202.08
HPCI Time Response and Pump Operability Test at
25 PSIG
24.206.01
RCIC System Pump and Valve Operability Test
24.307.11
Emergency Diesel Generator 12 - ECCS Start Test and
Logic Functional Tests of Bus 64C Breakers
28.504.02
Diesel Fire Pump Engine Weekly Operability Test
34.501.002
Fire Pump (Diesel) Inspection
2.302.12
Channel Functional Test of Division 2 4160 Volt Bus 65F
Undervoltage Circuits
Procedures
47.501.03
Diesel Fire Pump Battery Inspection - Weekly
31.1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
IST Program Valve
Basis
IST Program Valve Basis
IST Program Valve
Basis
IST Program Valve Basis
55951429
License Renewal - Perform Annual PM Tasks on the
Diesel Fire Pump
08/09/2024
60413741
Loss of Indication E1150F004B
2/23/2021
64760436
Perform 24.202.08 Sec-5.1 HPCI RTT and Pump
Operability at 1025 PSIG
08/14/2024
283065
EDP 80187C02 - EDG 12 Change Crank Case Pressure
Logic
07/08/2024
283117
EDP 80187C03EDG 13 change Crank Case Pressure
Logic
09/12/2024
67332123
Perform 24.206.01 RCIC System Pump Operability and
Valve Test @ 1000 PSIG
08/01/2024
Work Orders
73488648
HPCI Inboard Torus Suction Isolation Valve Abnormal
Stroke
08/15/2024
Drill Messages
8.13.24 Drill Messages
Drill Package
8.13.24 Drill Package
Miscellaneous
Drill Package
August 13, 2024, Drill Scenario Package
08/13/2024
EP101
Classification of Emergencies
Procedures
ODE10
Emergency Operating Procedure Expectations
CR202331880
TB and RB SPING Surveillances Exceeding Critical Dates
07/25/2023
CR202333389
RB Exhaust Plenum SPING Inoperable
09/29/2023
Corrective Action
Documents
CR202438128
Abnormal Buildup of Particulate on RB SPING Particulate
Filter Negatively Impacting SPING Performance
04/10/2024
Engineering
Evaluations
LCR 22022-ODM
Fermi 2 Offsite Dose Calculation Manual Revision
07/17/2023
2000-100
Radioactive Effluent and Dose Tracking
2000-110
Evaluation of Dose Rate Due to Radioactive Particulates,
Iodine, and Tritium in Gaseous Effluents
Procedures
2.000.112
Noble Gas Site Boundary Dose Rate and
Setpoint Evaluation
07A
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
64.713.018
Radiological Effluents Situational Surveillances
67.000.502
Eberline SPING Radiation Monitors General Sampling
24B
Technical
Requirements
Manual Volume II
Offsite Dose Calculation Manual
Self-Assessments NPRP240003
QHSA: Radioactive Gaseous and Liquid Effluent
Treatment System
01/16/2024
67330437
Perform 73.713.02 Sampling of Division 2 EECW
06/18/2024
69689702
SPING Noble Gas Monitor Inoperable - Rad Waste
Building
06/26/2023
70062567
Perform 78.000.09 Sampling Off-Gas for Fuel Performance
Rad Rate @ 25% Power
05/12/2024
70958864
Perform 64.713.019 Att 6 Turbine Bldg SPING Gaseous
Effluents Weekly
07/30/2024
Work Orders
2614409
Planned Vent/Purge of Primary Containment Atmosphere -
Drywell - 74.000.18
05/08/2024
MSPI Derivation Report - Reactor Core Isolation Cooling
System Unreliability Index
06/2024
MSPI Derivation Report - Reactor Core Isolation Cooling
System Unavailability Index
06/2024
MSPI Derivation Report - Residual Heat Removal System
Unreliability Index
06/2024
MSPI Derivation Report - Residual Heat Removal System
Unreliability Index
06/2024
MSPI Derivation Report - Cooling Water System
Unreliability Index
06/2024
MSPI Derivation Report - Cooling Water System
Unavailability Index
06/2024
Fermi 2 RHR Performance Indicators
Various
Miscellaneous
Fermi 2 RCIC Performance Indicators
Various
71151
Procedures
23.208
RHR Complex Service Water Systems
137
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARD 1525138
INPO 2015 Plant Evaluation AFI ER.21, Engineers are not
Actively Identifying Single Point Vulnerabilities (SPV) and
Developing Commensurate Mitigating Strategies to
Prevent Equipment Failures
07/24/2015
CARD 1525139
INPO Plant Evaluation AFI ER.32, Aging Management
Strategies for Many Circuit Cards and Relays That Support
Equipment with Operational Impact are not Adequate to
Preclude Failures
07/24/2015
CR202437148
Automatic RPS Scram on High RPV Pressure While
Attempting to lower Generator MW to 55 MWe
per 22.000.04
03/23/2024
Corrective Action
Documents
CR202441474
2015 AFI Action Item Not Completed
08/09/2024
Miscellaneous
RCE 202437148
Root Cause Evaluation Report: Automatic RPS Scram on
High RPV Pressure While Attempting to Lower Generator
MW to 55 MWe Per 22.000.04
FBP65
Fermi Business Practice 65: Single Point Vulnerabilities
FBP65
Fermi Business Practice-65: Single Point Vulnerabilities
MWC15
Elevated Risk Management
MWC15
Elevated Risk Management
71152A
Procedures
MWC15
Elevated Risk Management
24