ML18313A189

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Final Significance Determination of a Green Finding and NRC Integrated Inspection Report 05000341/2018003
ML18313A189
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 11/08/2018
From: Billy Dickson
NRC/RGN-III/DRP/B2
To: Polson K
DTE Energy
References
IR 2018003
Download: ML18313A189 (26)


See also: IR 05000341/2018003

Text

November 8, 2018

Keith Polson, Senior VP

and Chief Nuclear Officer

DTE Energy Company

Fermi 2 - 260 TAC

6400 North Dixie Highway

Newport, MI 48166

SUBJECT: FERMI POWER PLANT, UNIT 2FINAL SIGNIFICANCE DETERMINATION OF A

GREEN FINDING AND NRC INTEGRATED INSPECTION REPORT

05000341/2018003

Dear Mr. Polson:

The U.S. Nuclear Regulatory Commission (NRC) completed its final significance determination

of the apparent violation discussed in NRC Inspection Report 05000341/2018002. This finding

involved the licensees failure to identify a condition adverse to quality on the Division 2 residual

heat removal service water (RHRSW) outlet flow control valve. Specifically, troubleshooting and

the associated post maintenance testing failed to identify and correct a failed anti-rotation key,

which resulted in an inoperable Division 2 RHRSW system for longer than its Technical Specification 3.7.1 allowed outage time. The NRC has determined that the final significance of

this finding to be Green. On October 23, 2018, the NRC discussed the final significance

determination for the apparent violation with Mr. M. Caragher and other members of your staff.

The details of the issue is discussed in the enclosed inspection report.

On September 30, 2018, the NRC completed an integrated inspection at your Fermi Power

Plant, Unit 2. On October 4, 2018, the NRC inspectors discussed the results of the integrated

inspection with Mr. M. Caragher and other members of your staff. The results of this inspection

are also documented in the enclosed report.

Based on the results of this inspection, the NRC has identified two additional issues that were

evaluated under the risk significance determination process as having very low safety

significance (Green). The NRC has also determined that two violations are associated with

these issues.

Because you initiated condition reports to address these issues, these violations are being

treated as Non-Cited Violations (NCVs), consistent with Section 2.3.2 of the Enforcement

Policy.

If you contest the violations or significance of these NCVs, 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 the Fermi Power Plant.

K. Polson -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.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Billy Dickson, Chief

Branch 2

Division of Reactor Projects

Docket Nos. 50-341

License Nos. NPF-43

Enclosure:

IR 05000341/2018003

cc: Distribution via LISTSERV

K. Polson -3-

Letter to Keith Polson from Billy Dickson dated November 8, 2018

SUBJECT: FERMI POWER PLANT, UNIT 2FINAL SIGNIFICANCE DETERMINATION OF A

GREEN FINDING AND NRC INTEGRATED INSPECTION REPORT

05000341/2018003

DISTRIBUTION:

Christopher Cook

RidsNrrDorlLpl3

RidsNrrPMFermi2 Resource

RidsNrrDirsIrib Resource

Steven West

Darrell Roberts

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ROPreports.Resource@nrc.gov

ADAMS Accession Number: ML18313A189

OFFICE RIII RIII

NAME RNg:lg BDickson

DATE 11/8/2018 11/8/2018

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Numbers: 50-341

License Numbers: NPF-43

Report Numbers: 05000341/2018003

Enterprise Identifier: I-2018-003-0022

Licensee: DTE Energy Company

Facility: Fermi Power Plant, Unit 2

Location: Newport, MI

Dates: July 1 through September 30, 2018

Inspectors: T. Briley, Senior Resident Inspector

P. Smagacz, Resident Inspector

G. Hansen, Emergency Preparedness Inspector

J. Harvey, Resident Inspector, Davis-Besse

D. Mills, Senior Resident Inspector, Davis-Besse

V. Myers, Senior Health Physicist

R. Ng, Project Engineer

C. Norton, Senior Resident Inspector, Duane Arnold

J. Rutkowski, Project Engineer

Approved by: B. Dickson, Chief

Branch 2

Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance

by conducting an integrated quarterly 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. Findings and

violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations

Failure to Apply Torque Values Described in Maintenance Procedure for Flexible Couplings

on Emergency Diesel Generator 12

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green P.3 - Resolution 71111.12

Systems NCV 05000341/2018003-01

Closed

A finding of very low safety significance with an associated non-cited violation of Technical

Specification 5.4.1.a was self-revealed when plant operators discovered a pencil-thick lube oil

leak coming from a flexible coupling on emergency diesel generator 12 during planned

surveillance testing. Specifically, a lube oil leak developed when the flexible coupling located

between the engine driven lube oil pump and the lube oil filter failed due to improper torque

applied to the coupling.

Failure to Ensure Electrolytic Capacitors Installed in the Plant Did Not Have Expired Shelf

Lives

Cornerstone Significance Cross-Cutting Report

Aspect Section

Barrier Integrity Green H.7 - 71153

NCV 05000341/2018003-02 Documentation

Closed

A finding of very low safety significance with an associated non-cited violation of 10 CFR 50,

Appendix B, Criterion VIII, Identification and Control of Materials, Parts, and Components

was self-revealed when the reactor water cleanup system inlet flow square root converter

failed, resulting in a failure of the reactor water cleanup differential flow instrument and loss of

automatic isolation function of the reactor water cleanup isolation valves. Specifically,

electrolytic capacitors were installed in the reactor water cleanup system logic that had

expired shelf lives, resulting in failures of the automatic isolation function of the reactor water

cleanup system.

2

Failure to Identify a Condition Adverse to Quality on Division 2 Residual Heat Removal

Service Water Outlet Flow Control Valve

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Systems Green H.11 - Challenge 71153

NCV 05000341/2018003-03 the Unknown

Closed

A self-revealed Green finding and an apparent violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, and TS 3.7.1 Residual Heat Removal Service Water

(RHRSW) System, were self-revealed for the licensees failure to identify a condition adverse

to quality on the Division 2 RHRSW outlet flow control valve E1150F068B. Specifically,

troubleshooting and the associated post maintenance testing failed to identify and correct a

failed anti-rotation key which resulted in an inoperable Division 2 RHRSW system for longer

than its TS 3.7.1 allowed outage time.

Additional Tracking Items

Type Issue Number Title Report Status

Section

LER 05000341/2018-003-00 Inoperability of Reactor Water 71153 Closed

Cleanup System Isolation

Differential Flow High Function

LER 05000341/2018-004-00 Inoperability of Reactor Water 71153 Closed

Cleanup System Isolation

Differential Flow High Function

3

TABLE OF CONTENTS

PLANT STATUS ........................................................................................................................... 5

INSPECTION SCOPES ................................................................................................................ 5

REACTOR SAFETY ..................................................................................................................... 5

RADIATION SAFETY ............................................................................................................... 8

OTHER ACTIVITIES - BASELINE ........................................................................................... 9

INSPECTION RESULTS ............................................................................................................ 10

EXIT MEETINGS AND DEBRIEFS ............................................................................................ 18

DOCUMENTS REVIEWED......................................................................................................... 19

4

PLANT STATUS

Unit 2 began the inspection period at approximately 100 percent rated thermal power. On

July 3, 2018, the unit was reduced to approximately 69 percent rated thermal power to

troubleshoot a failed thyristor associated with the automatic voltage regulator. Rated thermal

power was subsequently reduced to approximately 60 percent to perform associated repairs on

July 4, 2018. The unit was returned to approximately 100 percent rated thermal power on

July 5, 2018. On July 6, 2018, the unit was reduced to approximately 87 percent rated thermal

power for a minor rod pattern adjustment and returned to approximately 100 percent rated

thermal power the same day. On July 14, 2018, the unit was reduced to approximately

53 percent power to perform a minor rod pattern adjustment and to perform repairs to an

isophase bus duct cooler. On July 15, 2018, the unit was returned to approximately 100 percent

rated thermal power. On July 23, 2018, the unit was reduced to approximately 72 percent rated

thermal power to perform a minor rod pattern adjustment. On July 24, 2018, the unit was

returned to approximately 100 percent rated thermal power. On August 18, 2018, the unit was

reduced to approximately 70 percent rated thermal power to perform a minor rod pattern

adjustment. On August 19, 2018, the unit was returned to approximately 100 percent rated

thermal power. On September 8, 2018, the unit was reduced to approximately 75 percent rated

thermal power to perform a minor rod pattern adjustment. On September 9, 2018, the unit was

returned to approximately 100 percent rated thermal power. On September 20, 2018, the unit

was reduced to approximately 95 percent rated thermal power to troubleshoot elevated moisture

carryover levels. On September 22, 2018, the reactor was shut down for a planned refueling

outage. The unit remained shut down at the end of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. 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

71111.01Adverse Weather Protection

Summer Readiness (1 Sample)

The inspectors evaluated summer readiness of offsite and alternate alternating current (AC)

power systems.

5

71111.04Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Division 2 non-interruptible air supply system during planned Division 1 non-interruptible

air supply system maintenance during the week ending July 14, 2018;

(2) Division 1 standby gas treatment system during planned Division 2 standby gas

treatment system maintenance during the week ending August 4, 2018; and

(3) Division 2 residual heat removal system after planned maintenance and prior to

establishment for shutdown cooling during the week ending September 29, 2018.

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of emergency

diesel generator systems during the weeks ending September 1, 2018 through

September 15, 2018.

71111.05AQFire Protection Annual/Quarterly

Quarterly Inspection (4 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Turbine Building First Floor lube oil storage area during the week ending

September 22, 2018;

(2) Turbine Building Basement supplemental cooling chill water chillers during the week

ending September 29, 2018;

(3) Turbine Building Second Floor isophase bus duct area during the week ending

September 29, 2018; and

(4) Radwaste Building Second Floor balance of plant switchgear and uninterruptible

power supply battery rooms during the week ending September 29, 2018.

Annual Inspection (1 Sample)

The inspectors evaluated fire brigade performance on August 22, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated a licensed operator graded simulator scenario on

August 18, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during a reactor recirculation

digital control system module replacement on August 8, 2018; a feedwater digital control

6

system restart on August 9, 2018; and plant shutdown activities for a planned refueling

outage on September 22, 2018.

71111.12Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Emergency diesel generator lube oil system following various oil leaks; and

(2) Diesel fire pump.

71111.13Maintenance Risk Assessments and Emergent Work Control (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Planned maintenance during the week ending August 4, 2018, including the Division 2

standby gas treatment system;

(2) Planned maintenance during the week of ending August 11, 2018, including emergency

diesel generator 11 safety system outage and feedwater digital control system reset; and

(3) Planned maintenance during the week of ending August 18, 2018, including reactor core

isolation cooling and Division 1 standby gas treatment system.

71111.15Operability Determinations and Functionality Assessments (2 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) High diesel fire pump coolant temperature, as documented in CARD 18-23969, during

the week ending July 28, 2018; and

(2) Potential vegetation impact on meteorological tower 10m wind speed and direction as

documented in CARD 18-25518, during the week ending September 22, 2018.

71111.18Plant Modifications (1 Sample)

The inspectors evaluated the following temporary modifications:

(1) Floor plug removal and grating installation on turbine building third floor.

71111.19Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Division 2 standby gas treatment system testing following pre-filter change out, during

the week ending August 4, 2018;

(2) Emergency diesel generator 11 testing following a planned safety system outage

including Flexmaster coupling replacement, during the week ending August 11, 2018;

(3) Reactor core isolation cooling system testing following Division 1 steam header drain pot

7

to water trap bypass air operated valve (E5150F054) repack, during the week ending

August 25, 2018;

(4) Division 1 standby gas treatment system testing following emergent vortex damper

repair, during the week ending August 18, 2018; and

(5) Division 2 residual heat removal pump B testing following relay replacement, during the

week ending September 29, 2018.

71111.20Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated refueling outage 19 activities starting September 22, 2018 to

September 30, 2018. The inspectors completed inspection procedure sections 03.01.a

and 03.01.c. This constituted a partial sample.

71111.22Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (1 Sample)

(1) Dedicated shutdown panel H21-P623 transfer switch control center isolation test, during

the week ending July 14, 2018.

In-service (3 Samples)

(1) High pressure coolant injection time response and pump operability test at 1025 psi,

during the week ending August 25, 2018;

(2) Division 2 low pressure coolant injection pump and valve operability test, during the

week ending September 1, 2018; and

(3) Division 1 core spray pump and valve test, during the week ending September 15, 2018.

71114.06Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated a graded emergency planning drill on July 24, 2018.

RADIATION SAFETY

71124.03In-Plant Airborne Radioactivity Control and Mitigation

Engineering Controls (1 Sample)

The inspectors evaluated airborne controls and monitoring.

Use of Respiratory Protection Devices (1 Sample)

The inspectors evaluated respiratory protection.

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

The inspectors evaluated the licensees self-contained breathing apparatus program.

8

71124.04Occupational Dose Assessment

Source Term Characterization (1 Sample)

The inspectors evaluated the licensees source term characterization.

External Dosimetry (1 Sample)

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) MS08: Heat Removal Systems - 1 Sample, July 1, 2017 - June 30, 2018;

(2) MS09: Residual Heat Removal Systems - 1 Sample, July 1, 2017 - June 30, 2018; and

(3) MS10: Cooling Water Support Systems - 1 Sample, July 1, 2017 - June 30, 2018.

71152Problem Identification and Resolution

Annual Follow-Up of Selected Issues (1 Sample)

The inspectors completed a review of the licensees corrective action program focused on

the licensees closure of the NRC findings and violations. The inspectors also performed a

limited assessment of the Safety Conscious Work Environment amongst the licensees Site

Leadership Team (department directors and their direct reports). The inspectors used NRC

Appendix C Inspection Procedure (IP) 93100 Safety-Conscious Work Environment Issue of

Concern Follow-up for guidance in completing this independent assessment.

71153Follow-Up of Events and Notices of Enforcement Discretion

Licensee Event Reports (2 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000341/2018-003, Inoperability of Reactor Water

Cleanup System Isolation Differential Flow High Function.

(2) Licensee Event Report (LER) 05000341/2018-004, Inoperability of Reactor Water

cleanup System Isolation Differential Flow High Function.

9

INSPECTION RESULTS

71111.12Maintenance Effectiveness

Failure to Apply Torque Values Described in Maintenance Procedure for Flexible Couplings

on Emergency Diesel Generator 12

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green P.3 - Resolution 71111.12 -

Systems NCV 05000341/2018003-01 Maintenance

Closed Effectiveness

A finding of very low safety significance with an associated non-cited violation of Technical

Specification 5.4.1.a was self-revealed when plant operators discovered a pencil-thick lube oil

leak coming from a flexible coupling on emergency diesel generator 12 during planned

surveillance testing. Specifically, a lube oil leak developed when the flexible coupling located

between the engine driven lube oil pump and the lube oil filter failed due to improper torque

applied to the coupling.

Description:

On April 20, 2018, the licensee was performing a routine slow start surveillance of emergency

diesel generator 12 (EDG-12), when plant operators noted a pencil-thick lube oil leak from

the flexible coupling fastener located between the engine driven lube oil pump and the lube oil

filter with the engine running in idle. Plant operators subsequently shut down the engine,

discontinued the surveillance, and EDG-12 was declared inoperable.

The licensee performed an investigation and found the flexible coupling fastener was torqued

to 120 in/lbs. Maintenance procedure 35.307.008, Emergency Diesel Generator - Engine

General Maintenance, Enclosure X, Revision 44 required a torque value of 240-260 in/lbs for

the size of piping the fastener was on. The coupling was last disturbed in 2011, and the

maintenance procedure at that time did not contain information regarding torque values for

flexible couplings. A similar flexible coupling fastener failed in 2016 due to inadequate work

instructions for torqueing flexible couplings (NCV 05000341/2016004-01, ADAMS Accession

Number ML17030A328), and corrective actions were developed to use the vendor

recommended values that had already been added to the maintenance procedure as

Enclosure X in 2014. However, the corrective actions did not require all flexible couplings to

be checked to ensure they were appropriately torqued. Opportunities existed for the licensee

to ensure these flexible couplings were properly torqued according to vendor

recommendations, either through scheduled maintenance online or during refueling and

forced outages. Therefore, on April 20, 2018, another flexible coupling that was not checked

as an extent of condition failed due to an under torqued condition.

Corrective Action: The licensee entered this issue into their corrective action program. The

flexible coupling was repaired and torqued to the requirements listed in the maintenance

procedure. The EDG was successfully tested and returned to an operable condition.

Corrective Action Reference: CARD 18-23217

10

Performance Assessment:

Performance Deficiency: The licensee failed to ensure that vendor recommended

torque specifications prescribed in maintenance procedure 35.307.008 were applied to

flexible coupling fasteners. Specifically, a flexible coupling fastener on EDG-12 failed

during a planned surveillance test due to being torqued to 120 in/lbs, vice the

recommended 240-260 in/lb. This resulted in the EDG to be shut down and declared

inoperable.

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the Equipment Performance attribute of the Mitigating Systems

cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, the failure to torque the flexible coupling fastener to prescribed vendor

recommended torque values led to the shutdown and inoperability of EDG-12 during a

planned surveillance test.

Significance: The inspectors assessed the significance of the finding using the IMC 0609,

Appendix A, and answered No to all the Section A questions of Exhibit 2. Therefore, this

performance deficiency screened as Green.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the Resolution component of

the Problem Identification and Resolution cross-cutting area, which states that the

organization takes effective corrective actions to address issues in a timely manner

commensurate with their safety significance. Specifically, a similar failure on another flexible

coupling occurred in 2016, but the licensee failed to ensure all flexible couplings were

appropriately torqued to the specifications included in the revised maintenance procedure.

[P.3]

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures be

established, implemented, and maintained covering the applicable procedures recommended

in Appendix A to Regulatory Guide 1.33, Quality Assurance Program Requirements,

Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a, states

maintenance that can affect the performance of safety-related equipment should be properly

preplanned and performed in accordance with written procedures, documented instructions,

or drawings appropriate to the circumstances.

Contrary to the above, written procedures were not established and implemented for

maintenance that can affect the performance of safety-related equipment appropriate to the

circumstances since 2011. Specifically, there were no torque requirements specified for

flexible coupling maintenance in 2011. As a result, on April 20, 2018, EDG-12 was shut

down and declared inoperable when a flexible coupling failed during a planned surveillance

test.

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

11

71152Problem Identification and Resolution

Observation 71152Annual Sample Review

On August 24, 2018, the inspectors completed a partial review of the licensees corrective

action program focused on the licensees closure of the NRC findings and violations.

Additionally, the inspectors conducted a limited assessment of the Safety Conscious Work

Environment (SCWE) amongst Fermis Site Leadership Team (SLT). The inspectors used

NRC Appendix C IP 93100 Safety-Conscious Work Environment Issue of Concern Follow-up

for guidance in completing this independent assessment. Specifically, the inspectors

focused on completing the inspection requirements contained in Sections 02.04 and 02.05 of

IP 93100. These sections direct inspectors to first review the licensees SCWE-related

policies, communications, and training materials and then assess SCWE by interviewing

and/or conducting focus groups with selected site personnel.

The inspectors reviewed Fermis Nuclear Safety Management Policy Statement, Revision 6,

Fermi Employee Concerns Program, Revision 4, and General Management Policy

Statement on maintaining a SCWE, Revision 10. The inspectors also reviewed the results of

pulse surveys by the Employee Concern Program coordinator conducted in June and

December 2017 and Gallup surveys (surveys conducted DTE wide) conducted in Spring and

Winter of 2017 and in Spring of 2018. Based on a review of these documents, the inspectors

did not identify any trends that would be indicative of an issue with SCWE or issues of

concern.

The inspectors also reviewed the SLTs documented reviews of products from the Nuclear

Safety Culture Monitoring Panel. Those reports appeared balanced with no indication of an

adverse work environment. The SLTs 2018 review indicated a flat or declining trend in plant

overall performance; that trend was recognized and discussed with the inspectors by a

member of the SLT. Also, a 2018 SLT review documented the following based on input from

a review by the Independent Review Group:

Site management acknowledges that the quality and rigor of Fermi causal evaluations needs

to significantly improve with regard to the identification and understanding of the underlying

organizational and behavioral shortfalls that are contributing to station events and

performance gaps.

The inspectors conducted interviews of eleven members of the licensees site leadership

team. Additionally, the inspectors completed a focus group discussion. The focus group was

made up of four supervisors from the Maintenance Department. The inspectors also

observed various work group and plant management meetings.

The inspectors did not identify a pervasive chilled work environment at Fermi. Additionally, no

violations of regulatory requirements were identified during the review of closure and follow-up

actions associated with NRC findings and violations.

12

71153Follow-Up of Events and Notices of Enforcement Discretion

Failure to Ensure Electrolytic Capacitors Installed in the Plant Did Not Have Expired Shelf

Lives

Cornerstone Significance Cross-Cutting Aspect Report

Section

Barrier Integrity Green H.7 - Documentation 71153 -

NCV 05000341/2018003-02 Follow-up of

Closed Events and

Notices of

Enforcemen

t Discretion

A finding of very low safety significance with an associated non-cited violation of 10 CFR 50,

Appendix B, Criterion VIII, Identification and Control of Materials, Parts, and Components

was self-revealed when the reactor water cleanup system inlet flow square root converter

failed, resulting in a failure of the reactor water cleanup (RWCU) differential flow instrument

and loss of automatic isolation function of the RWCU isolation valves. Specifically, electrolytic

capacitors were installed in the RWCU system logic that had expired shelf lives, resulting in

failures of the automatic isolation function of the RWCU system.

Description:

On May 27, 2018, and again on May 31, 2018, the capacitors on the square root converter of

the RWCU logic system failed, resulting in a failure of the RWCU differential flow instrument

and loss of automatic isolation function of the RWCU isolation valves. Both failures involved

capacitors that had surpassed their shelf life of 10 years. Licensee procedures contained

shelf life values for electrolytic capacitors. However, the procedures did not direct personnel

to record the date of manufacture codes of capacitors and to track those codes to ensure they

would not be installed in the plant prior to their shelf life expiration.

For the May 27, 2018 failure, the square root converter was installed on December 12, 2017,

and was a commercially dedicated component as it was originally a non-qualified component.

No capacitors were changed out during the upgrade process. Per CARD 18-24204, the

capacitor that failed had a date code from 2006. During the upgrade process under

procedure MMM04, Engineering Evaluation Disposition, the electrolytic capacitors were not

checked to ensure their date codes were still valid for further usage nor was there procedural

direction to do so. Corrective actions for this failure included revising the upgrade process to

consider replacing electrolytic capacitors. The licensee submitted Event Notification Number 53429 and Licensee Event Report 05000341/2018-003 to report the event as a

condition that could have prevented the fulfillment of a safety function needed to control the

release of radioactive material and as a condition that could have prevented the fulfillment of

a safety function needed to mitigate the consequences of an accident.

For the May 31, 2018 failure, the square root converter electrolytic capacitors were procured

on June 9, 2015. However, the electrolytic capacitors received were stamped with a date

code indicating they were manufactured in 1985. At the time of procurement in 2015,

licensee receipt inspection procedure W-ELCAP, Revision B, did not have a requirement to

verify date of manufacture codes. Revision C of the procedure did have a requirement to

check date code markings. However, that procedure was issued on May 24, 2016, and no

action was created to ensure existing stock met the requirements of the receipt inspection

procedure. Date codes were also not checked prior to installation in the plant to ensure the

13

electrolytic capacitors were still acceptable for use. The licensee submitted Event Notification Number 53435 and Licensee Event Report 05000341/2018-004 to report the event as a

condition that could have prevented the fulfillment of a safety function needed to control the

release of radioactive material and as a condition that could have prevented the fulfillment of

a safety function needed to mitigate the consequences of an accident.

Corrective Action: The licensee entered this issue into their corrective action program.

Corrective actions included revising the receipt inspection procedure W-ELCAP to Revision D

to set a clear and distinct acceptance date of manufacture at the time of receipt, inspect and

verify all inventory for capacitors with expired shelf life, and update the upgrade process to

consider shelf life date codes.

Corrective Action Reference: CARD 18-24368

Performance Assessment:

Performance Deficiency: The licensee failed to ensure that capacitors installed in the plant

for safety related applications did not have expired shelf lives. Specifically, capacitors

installed in the square root converter of the RWCU logic failed resulting in a failure of the

RWCU differential flow instrument and loss of automatic isolation function of the RWCU

isolation valves. Date codes were not inspected as part of the process for commercially

dedicating a capacitor by use of procedure MMM04 for the May 27th failure and the

procurement of capacitors by use of W-ELCAP, Revision B for the May 31st failure.

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the SSC and Barrier Performance attribute of the Barrier

Integrity cornerstone objective to provide reasonable assurance that physical design barriers

(fuel cladding, reactor coolant system, and containment) protect the public from radionuclide

releases caused by accidents or events. Specifically, the licensee did not ensure that

capacitors installed in the plant did not have expired shelf lives, which led to a loss of the

automatic isolation function of the RWCU isolation valves.

Significance: The inspectors assessed the significance of the finding using the IMC 0609,

Appendix A, and answered No to all the Section B questions of Exhibit 3. Therefore, this

performance deficiency screened as Green.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the Documentation

component of the Human Performance cross-cutting area, which states that the organization

creates and maintains complete, accurate and up to-date documentation. Specifically, when

the receipt inspection procedure was updated to include date codes, the licensee did not

evaluate the current stock to ensure no items were procured with already expired shelf lives

and the engineering evaluation procedure did not consider evaluating existing components

when upgrading component classifications. [H.7]

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion VIII, Identification and Control of

Materials, Parts, and Components requires that measures shall be established for the

identification and control of materials, parts, and components, including partially fabricated

assemblies. These measures shall assure that identification of the item is maintained by heat

number, part number, serial number, or other appropriate means, either on the item or on

records traceable to the erection, installation, and use of the item. These identification and

14

control measures shall be designed to prevent the use of incorrect or defective material,

parts, and components.

Contrary to the above, between May 24, 2016 and May 27, 2018, the licensee did not have

measures to prevent the use of incorrect or defective material, parts, and components.

Specifically, between May 24, 2016, when the receipt inspection procedure was updated to

include date codes, and the failure on May 27, 2018, the licensee did not record or track date

codes to ensure that electrolytic capacitors were not stored and installed in the plant that

exceeded their shelf lives. As a result, capacitors with expired shelf lives were installed in the

RWCU system and failed on May 27, 2018 and again May 31, 2018 resulting in a loss of the

automatic isolation capabilities of primary containment isolation valves.

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Failure to Identify a Condition Adverse to Quality on Division 2 Residual Heat Removal

Service Water Outlet Flow Control Valve

Cornerstone Significance Cross-Cutting Report Section

Aspect

Mitigating Green H.11 - Challenge 71153 - Follow-up

Systems NCV 05000341/2018003-03 the Unknown of Events and

Closed Notices of

Enforcement

Discretion

A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, and TS 3.7.1 Residual Heat Removal Service

Water (RHRSW) System, were self-revealed for the licensees failure to identify a condition

adverse to quality on the Division 2 RHRSW outlet flow control valve E1150F068B.

Specifically, troubleshooting and the associated post maintenance testing failed to identify

and correct a failed anti-rotation key which resulted in an inoperable Division 2 RHRSW

system for longer than its TS 3.7.1 allowed outage time.

Description:

On May 5, 2017, while securing Division 2 RHRSW from routine biocide treatment of the

Division 2 residual heat removal reservoir, control room operators noted abnormal indications

on the Division 2 RHRSW outlet flow control valve (E1150F068B) while the system was still in

operation. The valve indicated fully closed with approximately 8,500 gallons per minute of

flow. The Division 2 RHRSW system was shut down and declared inoperable. Initial

troubleshooting identified that the limit switches were not actuating when expected during

hand wheel operation of the valve. The limit switch assembly was replaced, limits were reset,

and the post maintenance test was performed without the system operating (static no-flow

condition). The test passed, and the valve was returned to service on May 7, 2017.

On May 22, 2017, while placing Division 2 RHRSW in service for routine biocide treatment of

the Division 2 residual heat removal reservoir, the Division 2 RHRSW outlet flow control valve

failed to fully open as evidenced by the reduced flow and full open valve indication.

Troubleshooting discovered the direct cause was the failure of the anti-rotation bushing stem

key. High vibration caused the tack welds of the key to fail. The licensee also concluded that

previous troubleshooting on the limit switch issue, discovered while the system was in

operation for routine biocide treatment on May 5, 2017, for the Division 2 RHRSW outlet flow

15

control valve was inadequate and did not identify the failure of the anti-rotation key. As a

result, the Division 2 RHRSW outlet flow control valve was returned to service on

May 7, 2017, and subsequently failed on the next on-demand stroke on May 22, 2017.

Division 1 RHRSW was available throughout the event except on two occasions. On

May 9, 2017, and May 11, 2017, the Division 1 RHRSW was unavailable for mechanical draft

cooling tower nozzle cleaning activities.

The licensee submitted LER 05000341/2017-003-00 to report this event in accordance with

10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by TS 3.7.1 and 10 CFR 50.73(a)(2)(v)(B)

as a condition that could have prevented the fulfillment of the safety function of structures or

systems that are needed to remove residual heat.

The inspectors concluded that all potential failure mechanisms were not evaluated during

troubleshooting on May 5, 2017 and the anti-rotation key failure was within the licensees

ability to foresee and correct based on the anti-rotation key failure most likely being the cause

of the abnormal indications identified on May 5, 2017. Initial licensee troubleshooting

activities did not identify a true fault mechanism and post maintenance testing was not

performed under dynamic conditions which were present at the time of failure.

Corrective Actions: The failed anti-rotation key and associated tack welds were replaced and

preventative maintenance procedures were updated to perform periodic anti-rotation key and

associated tack weld inspections. Additionally, an evaluation was performed to assess

additional training on the expectations for troubleshooting performance.

Corrective Action References: CARD 17-24236 and 17-24655

Performance Assessment:

Performance Deficiency: The licensees failure to identify a condition adverse to quality on

Division 2 RHRSW outlet flow control valve E1150F068B was a performance deficiency.

Specifically, troubleshooting and the associated post maintenance testing failed to identify

and correct a failed anti-rotation key, which resulted in an inoperable Division 2 RHRSW

system for longer than its TS 3.7.1 allowed outage time.

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the Equipment Performance attribute of the Mitigating Systems

cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (i.e. core damage).

Specifically, Division 2 RHRSW was not fully capable of performing its intended safety

function from May 3, 2017 (last successful run) to May 24, 2017.

Significance: A Senior Reactor Analyst (SRA) completed a detailed risk evaluation using the

Fermi Standardized Plant Analysis Risk (SPAR) Model, version 8.52. The following

assumptions were made to characterize the degraded condition that resulted from the

performance deficiency.

  • The Division 2 RHRSW outlet flow control valve (E1150F068B) would fail to fully open

on demand. The valve was not recoverable either from the control room or through

local manual operation due the failure mechanism.

16

  • Approximately 2800 gallons per minute RHRSW flow was observed when the valve

failed to fully open. The licensee performed thermal-hydraulic calculations using the

Modular Accident Analysis Program Version 5.03 to assess containment parameters

and the probabilistic risk assessment (PRA) success criteria for continued core cooling

with degraded containment cooling. The licensee evaluation was documented as

Technical Evaluation TE-E11-17-052, Revision B. The licensee determined that

RHRSW flow in the degraded condition was sufficient to prevent core damage due to

containment failure in sequences where the standby feedwater (SBFW) system or a

combination of other systems such as the high pressure coolant injection (HPCI) and

low pressure core spray (LPCS), reactor core isolation cooling (RCIC) and LPCS, or

RCIC and control rod drive (CRD) systems were successful in providing core cooling.

The NRC reviewed the licensees evaluation and agreed with the revised containment

cooling success criteria when the SBFW system was successful in providing core

cooling but did not fully review or agree with the revised success criteria for the other

combinations of injection systems. The SBFW can provide core cooling at both high

and low reactor coolant system pressures and has a suction source outside of

containment. The SBFW system would not be expected to be impacted by higher

containment temperatures resulting from degraded containment cooling as compared

to systems that have a suction source inside containment, or would otherwise be

affected by harsh environments in the primary or secondary containment.

  • The exposure time used in the evaluation was 18 days. On May 7, 2018, the licensee

returned the system to service without identifying and correcting the valve failure. The

valve failure was discovered on May 22, 2018, repaired and returned to service on

May 24, 2018. The exposure period is based on the period from May 7, 2018 through

May 24, 2018.

The SRA modified the SPAR model with the assistance of Idaho National Laboratory (INL) to

model the potential for common cause failure of the RHRSW flow control valves in both

divisions (E1150F068A and E1150F068B). The degraded condition was modeled as a failure

of the E1150F068B to open, which results in the failure of one division of suppression pool

cooling. Using the results of the licensee technical evaluation, the SRA reviewed the

quantitative SPAR model results and removed the core damage sequences involving

successful injection with the SBFW system.

For the exposure period, after removing the sequences with successful SBFW core cooling,

the change in core damage frequency from internal events was less than 1E-7/yr. The

dominant core damage sequence involved a loss of offsite power, successful injection with

the reactor core isolation cooling system and successful depressurization, followed by failure

of containment heat removal, leading to failure of late injection with low pressure systems.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the Challenge the Unknown

component of the Human Performance cross-cutting area, which states that individuals stop

when faced with uncertain conditions. Risks are evaluated and managed before proceeding.

Specifically, troubleshooting quickly associated an abnormality as an indication issue without

stopping and performing more thorough investigation to determine why the limit switch

settings were not correct upon discovery. Static post maintenance testing following limit

17

switch replacement was accepted as completion of troubleshooting without challenging and

understanding the true cause. (H.11)

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, states in part, that measures shall

be established to assure that conditions adverse to quality, such as failures, malfunctions,

deficiencies, deviations, defective material and equipment, and non-conformances are

promptly identified and corrected.

Technical Specification 3.7.1 Residual Heat Removal Service Water (RHRSW) System

requires, in part, that Division 1 and Division 2 RHRSW subsystems shall be operable in

Modes 1, 2, and 3. Technical Specification 3.7.1 requires that if one or more required

RHRSW subsystems are inoperable for reasons not associated with the RHRSW pumps for

more than 7 days, action must be taken to place the unit in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and

Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Contrary to the above, from May 5, 2017 to May 24, 2017, a condition adverse to quality was

not promptly identified and corrected. Specifically, an anti-rotation key failure on the

Division 2 RHRSW outlet flow control valve, a component important to safety, was not

identified and corrected.

From May 5, 2017 to May 24, 2017, Division 2 RHRSW subsystem was inoperable and action

was not taken to restore the subsystem to service in seven days or place the unit in Mode 3

within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Disposition: Because this violation was of very low safety significance and was entered into

the licensees corrective action program, this violation is being treated as a Non-Cited

Violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this finding and associated non-cited violation, closes

AV 05000341/2018002-04 as discussed in NRC Inspection Report 05000341/2018002,

(ADAMS Accession Number ML18227A091).

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public

disclosure. No proprietary information was documented in this report.

  • On July 13, 2018, the inspectors presented the radiation protection program inspection

results to Mr. K. Polson, Senior Vice President, and other members of the licensee staff.

  • On October 04, 2018, the inspectors presented the quarterly integrated inspection

results to Mr. M. Caragher, and other members of the licensee staff.

  • On October 29, 2018, the inspectors presented the final significance determination

for the apparent violation with Mr. M. Caragher and other members of the licensee

staff.

18

DOCUMENTS REVIEWED

71111.01Adverse Weather Protection

- CARD 18-25406; Potential Inconsistency in UFSAR Chapter 8 Descriptions of 120 kV Power

Lines; 07/16/18

- CARD 18-24696; Spurious 11D31 (120kV Relaying System Failure) and 11D28 (120kV

Breaker GM Trouble Alarms); 06/14/2018

- Procedure 20.300.Offsite; Loss of Offsite Power; Revision 12A

- Procedure 20.300.SBO; Loss of Offsite and Onsite Power; Revision 25A

- Procedure 20.300.120kV; Loss of 120kV; Revision 18

- 20.300.SBO Bases; Loss of Offsite and Onsite Power Bases; Revision 8

- 20.300.120kV Bases; Loss of 120kV Bases; Revision 3

- Procedure 20.300.345kV; Loss of 345kV; Revision 16

- Procedure 20.300.GRID; Grid Disturbance; Revision 7

- 20.300.345kV Bases; Loss of 345kV Bases; Revision 0

- CARD 18-24164; SOP and DCS Logic is not Compatible; 05/24/2018

71111.04Equipment Alignment

- Drawing 6I721-25491; Standby Gas Treatment System Diagram Instrumentation and Controls;

Revision P

- Drawing 6M721-2015; Station and Control Air; Revision CN

- Drawing 6M721-4615; Interruptible and Non-Interruptible Control Air; Revision AG

- Drawing 6M721-5734; Emergency Diesel Generator System Functional Operating Sketch;

Revision BF

- Drawing 6M721-5737; Standby Gas Treatment System; Revision AA

- Drawing 6M721N-2046; Diesel Generator System Division 1 RHR Complex; Revision AF

- Drawing 6SD721-2500-01; One Line Diagram Plant 416V System Service; Revision BO

- Procedure 23.129; Station and Control Air System; Revision 114

- Procedure 23.205; Residual Heat Removal System; Revision 137

- Procedure 23.307; Emergency Diesel Generator System; Revision 123

- Procedure 23.404; Standby Gas Treatment System; Revision 57

71111.05AQFire Protection Annual/Quarterly

- Fermi Fire Drill Evaluation LP-FP-940-12YX; Motor Generator Sets, Fourth Floor Reactor

Building, El 6596; Revision 0

- MOP10; Fire Brigade; Revision 9

- Procedure 20.000.22; Plant Fires; Revision 46

- Procedure FP-RB-4-17b; Reactor Building Recirculation System Motor Generator Area,

Zone 17, El 6596; Revision 4

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

- Procedure 23.138.01; Reactor Recirculation System; Revision 114

- WO 51147599; Multiple RR DCS Alarms in MCR; 06/28/2018

- WO 51192733; Main Steam Line Flow Failed for Steam Lines A and D on DCS Flat Panel

Display; 07/03/2018

19

71111.12Maintenance Effectiveness

- CARD 17-00626; Oil Leak from Lube Oil Heater; 12/24/2017

- CARD 17-26959; Lube Oil Leaking from Coupling; 08/19/2017

- CARD 17-29635; Oil Leak; 12/03/2017

- CARD 18-00399; EDG 11 Lube Oil Heater Has an Oil Leak; 04/02/2018

- CARD 18-20928; Fuel Oil Leaks Observed on EDG 14; 02/01/2018

- CARD 18-23085; Oil Leak Near Oil Filter; 04/16/2018

- CARD 18-23217; Solid Stream Pencil Thick Oil Leak on Clamped Flange Outlet of EDG 12

Filter; 04/20/2018

- CARD 18-24354; Oil Leak from Flange Supplying EDG 11 LO Filter; 06/01/2018

- CARD 18-26426; NRC Identified Discrepancy; 08/24/2018

- WO 46468420; Verify Torque on Flexible Coupling on EDG 12 to 90-100 inch - Pounds Per

Action 16-25666-12; 11/04/2016

- WO 50476401; Oil Leak Near Oil Filter; 04/20/2018

71111.13Maintenance Risk Assessments and Emergent Work Control

- CARD 18-25977; Dip Switch out of Position; 08/08/2018

- CARD 18-26024; Indicated Instantaneous CTP Exceeded 3486MWth While Transferring into

and Out of Emergency Bypass on the Feedwater DCS Controllers; 08/09/2018

- CARD 18-26093; RHR Handrail and Panel Damage Due to Fork Truck Operation; 08/13/2018

- Risk Management Plan; Feedwater MFP Module Replacement; 08/06/2018

- Risk Management Plan; MDCT Division 1 Nitrogen Tie In; 08/18/2018

- Risk Management Plan; Perform 44.030.253 Reactor Water Level (Level., 2 and 8) Division 1

Channel C Functional Test; 02/07/2017

- Risk Management Plan; Risk Management Plan for the Performance of 24.321.07 (72CF

Throwover Test); 05/11/2015

- Risk Management Plan; RR Pump B MG Set B Speed Controller Replacement; 08/15/2018

71111.15Operability Determinations and Functionality Assessments

- CARD 04-23268; Potential Tree Removal from Areas Adjacent to 60 Meter Meteorological

Tower; 07/21/2004

- CARD 10-29358; Request for Tree Clearance Near 60 Meter Meteorological Tower;

10/20/2010

- CARD 18-00383; DFP FO Gauge Sticks; 05/26/2018

- CARD 18-23969; High Coolant Temperature During Diesel Fire Pump Run; 05/18/2018

- CARD 18-23990; Failed PMT WO 50530433 DFP; 05/19/2018

- CARD 18-24008; Gauge Reading Pressure with DFP Shut Down; 05/20/2018

- CARD 18-24124; High Iron in DFP Angle Drive Oil Sample; 05/23/2018

- CARD 18-25518; Trees on the South Side of 60m Met Tower Need to be Cleared to 10 times

Distance to Height Ratio, According to RG-1.23; 07/19/2018

- CARD 18-23902; Diesel Fire Pump Failed to Start; 05/16/2018

- TE-D40-18-052; Past Operability Evaluation, Impact of Vegetation on Meteorological Tower;

Revision 0

71111.18Plant Modifications

- CARD 00-14755; Elevated TB Temps, Contingency Action Recommendation; 8/7/00

- CARD 00-17713; Remove Steam Tunnel Plugs to Support TBHVAC Fan Maintenance; 8/7/00

20

- CARD 18-22345; Guidance to Remove TB3 to Mezzanine Floor Plugs Removed in Rev 65;

3/20/18

- Document Change Request 00-1656; Turbine Building Hearing, Ventilation, and Air

Conditioning; 10/10/00

- Document Change Request 18-0068; Turbine Building Hearing, Ventilation, and Air

Conditioning; 3/14/18

- Drawing 6A721-2004-02; Auxiliary Bldg. & Turbine Hse. Steam Tunnel & Cable Tray Area -

Plans & Sections; Revision G

- Drawing 6A721-2017; Turbine House 3rd Floor Plan, El. 643-6; Revision AF

- Drawing 6A721-2017-01; Turbine Building 3rd Floor Plan, El. 643-6; Revision K

71111.19Post Maintenance Testing

- CARD 18-25955; NQA FME Barrier Located Above EDG-11 Was not Installed as an

Effective Barrier; 08/08/2018

- CARD 18-26135; Division 1 SGTS Exhaust Fan Supply vortex Damper Failed to Operate;

08/14/2018

- CARD 18-26209; E5150F054 Friction Value Lower Than Expected After Valve Repack;

08/17/2018

- CARD 18-27450; When Attempted to Start B RHR Pump for Surveillance, the Pump Tripped

on a Z51 Device (Over Current); 09/28/2018

- Procedure 24.204.06; Division 2 LPCI and Suppression Pool Cooling/Spray Pump and Valve

Operability Test; Revision 78

- Procedure 24.307.45; Emergency Diesel Generator 11 Fast Start Followed by Load Reject;

Revision 17

- Procedure 34.307.001; Emergency Diesel Generators Inspection and Preventative

Maintenance; Revision 79

- WO 46533988; Perform 43.404.001 Division 1 Standby Gas Treatment Filter Performance

Test; 08/14/2018

- WO 46534020; Perform 43.404.001 Division 1 SGTS Charcoal Sample Withdrawal;

11/16/2016

- WO 46585850; Replace SGTS Pre-Filters in T4600D002; 11/29/2016

- WO 46697020; Perform 24-Month PM Tasks Per 34.307.001 on Emergency Diesel

Generator- 11; 12/09/2016

- WO 47213441; Perform 24.206.01 RCIC System Pump Operability and Valve Test at 1000

PSIG; 08/16/2018

- WO 47277010; Perform General PM T4600C003 SGTS Division 1 Exhaust Fan;

03/13/2017

- WO 49050601; Division 1 Standby Gas Treatment System Flow Out of Spec High; 10/30/2017

- WO 49202148; Packing Leak; Repack E5150F054; 11/16/2017

- WO 51443116; 43.404.002 Division 2 SGTS Filter Performance; 07/31/2018

- WO 51525895; Repair / Replace Coupling EDG 11 Standby LO Pump; 08/08/2018

71111.20Refueling and Other Outage Activities

- CARD 18-27161; Received 3D156 Rx Water Level Low During Shutdown; 09/22/2018

- CARD 18-27181; 30 Inch Drywell Hatch Cover O-Ring Dropped Through Hatch into Drywell

Upper Elevation; 09/22/2018

- MOP05-200; RPV Water Inventory Control; Revision 0

- MOP19; Reactivity Management; Revision 26A

- MWC13; Outage Nuclear Safety; Revision 18

21

- Procedure 22.000.03; Power Operation 25% to 100% to 25%; Revision 103A

- Procedure 22.000.04; Plant Shutdown From 25% Power; Revision 84

- Procedure 22.000.05; Pressure/Temperature monitoring During Heatup and Cooldown;

Revision 50

- Procedure 23.623; Reactor Manual Control System; Revision 72

71111.22Surveillance Testing

- CARD 18-26489; E1100F074 RHRSW to RPV Emergency Line Drain Partially Plugged;

08/28/2018

- CARD 18-26495; E1100F078 Did Not Indicate Open Property During 24.204.06; 08/28/2018

- Drawing 6M721-5708; High Pressure Coolant Injection System; Revision AQ

- Procedure 24.202.01; HPCI Pump and Valve Operability Test at 1025 PSI; Revision 115

- Procedure 24.202.08; HPCI Time Response and Pump Operability Test at 1025 PSI;

Revision 18

- Procedure 24.203.02; Division 1 CSS Pump and Valve Operability, and Automatic Actuation;

Revision 59

- Procedure 24.204.06; Division 2 LPCI and Suppression Pool Cooling/Spray Pump and Valve

Operability Test; Revision 77

- Procedure 24.321.05; Dedicated Shutdown Panel H21-P623 Operability Test EF2 System

Transfer; Revision 30

- Procedure 42.321.14; Dedicated Shutdown Panel H21-P623 Transfer Switch Control Center

Isolation Test; Revision 25

- Procedure 43.000.005 ;Visual Examination Piping and Components (VT-2); Revision 36

- Procedure 43.202.001; HPCI Leakage Monitoring Test; Revision 28

- WO 47379727; Perform 47.208.01 Sec-6.3 RHR Division 2 RHRSW Crosstie Valve

E1150F073; 08/28/2018

- WO 47379768; Perform 24.204.05 Sec-5.4 Division 2 RHR Local Valve Position Indication

Verification; 08/28/2018

71114.06Drill Evaluation

- Blue Team 2018 Drill Package; 07/24/2018

71124.03In-Plant Airborne Radioactivity Control and Mitigation

- Laboratory Report Compressed Air/Gas Quality Testing; 4/16/2018

- 50.59 Screen 16-0220; EDP 37719; 12/13/2016

- CARD 18-21052; NRC Violation Failure to Perform Fit Testing on Self-Contained Breathing

Apparatus Respirators; 02/07/2018

- NIOSH Reverence TN-21331; Letter from NIOSH to Mine Safety Appliances Company;

7/25/2018

- Posi3 USB Test Results for HAWK008, HAWK014, and HAWK030; 7/21/2017

- Radiation Protection Respirator Qualification Report; 7/10/2018

71124.04Occupational Dose Assessment

- NPRP-17-0173; Annual Prospective Internal Dose Evaluation; 12/22/2017

- Pregnancy Declaration Form; 6/4/2018

- DLR/Secondary Dosimetry Comparison Resolution; 07/01/2017 to 12/31/2017

22

71151Performance Indicator Verification

- Fermi 2 RHR Performance Indicators; July 2017

71153Follow-Up of Events and Notices of Enforcement Discretion

- MMM04; Engineering Evaluation Disposition; Revision 20

- MMM13; Storage Maintenance Program; Revision 10

- MMM04; Engineering Evaluation Disposition; Revision 19

- CARD 18-24380; Steam Leak; 06/01/2018

- Fermi Operator Log

- LERs 2018-003 and 2018-004; Inoperability of Reactor Water Cleanup System Isolation

Differential Flow-High Function; Revision 0

- CARD 18-24368; Degraded Capacitor Caused Malfunction of Square Root Converter in

RWCU System; 06/01/2018

- CARD 18-24204; G33R609 RWCU Pump discharge Flow Gage Appears to Have Failed;

05/27/2018

- EN 53435; RWCU System Isolation Differential Flow - High Function was Declared Inoperable

- CARD 18-24380; Steam Leak; 06/01/2018

- CARD 18-24368; Degraded Capacitor Caused Malfunction of Square Root Converter in

RWCU System; 06/01/2018

- CARD 18-24204; G33R609 RWCU Pump Discharge Flow Gage Appears to Have Failed;

05/27/2018

23