IR 05000341/2021003

Integrated Inspection Report 05000341/2021003

ML21298A200
Person / Time
Site:	Fermi
Issue date:	10/28/2021
From:	Nestor Feliz-Adorno Reactor Projects Region 3 Branch 4
To:	Peter Dietrich DTE Electric Company
References
IR 2021003
Download: ML21298A200 (29)

Text

October 28, 2021

SUBJECT:

FERMI POWER PLANT, UNIT 2 - INTEGRATED INSPECTION REPORT 05000341/2021003

Dear Mr. Dietrich:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On October 14, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

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. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Feliz-Adorno, Nestor on 10/28/21 Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Docket No. 05000341 License No. NPF-43

Enclosure:

As stated

Inspection Report

Docket Number: 05000341 License Number: NPF-43 Report Number: 05000341/2021003 Enterprise Identifier: I-2021-003-0087 Licensee: DTE Electric Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Inspection Dates: July 1, 2021 to September 30, 2021 Inspectors: S. Bell, Health Physicist T. Briley, Senior Resident Inspector G. Hansen, Sr. Emergency Preparedness Inspector R. Ng, Project Engineer T. Taylor, Acting Senior Resident Inspector D. Turpin, Reactor Engineer Approved By: Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Fermi Power Plant, Unit 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71111.1

List of Findings and Violations

Failure to Adequately Position Alternate Diesel Fire Pump Suction Hose and Strainer Resulted in Equipment Damage During General Service Water Sluice Gate Operation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.15 Systems FIN 05000341/2021003-01 Evaluation Open/Closed A self-revealed finding of very low safety significance (Green) was identified when the licensee failed to adequately position the alternate diesel fire pump (ADFP) suction hose and strainer to prevent interference with plant equipment as specified in Temporary Modification 21-0001. Specifically, during performance of routine general service water sluice gate operation, the ADFP suction hose and strainer were caught on a sluice gate and subsequently damaged. As a result, the ADFP was declared non-functional.

Unanalyzed Condition due to Open Steam Tunnel Door Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.13] - 71111.15 Systems NCV 05000341/2021003-02 Consistent Open/Closed Process The inspectors identified a finding of very low safety significance with an associated non-cited violation of 10 CFR 50.65 (a)(4) for the licensee's failure to assess and manage the risk associated with maintaining the reactor building steam tunnel (RBST) door open for longer than needed for normal ingress/egress. As a result, an unanalyzed condition was created regarding high energy and medium energy line breaks (HELBs and MELBs), and internal flooding.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On July 2, 2021, the plant commenced a power reduction to approximately 58 percent to address a main condenser tube leak. The leak was repaired, and the plant returned to rated thermal power on July 11, 2021.

On August 27, 2021, plant power was reduced due to an unexpected loss of the center heater drain pump. The plant was stabilized at approximately 55 percent power, the north heater drain pump was placed in service, and the plant was returned to rated thermal power later the same day. On September 16, 2021, the plant commenced a power reduction to approximately 47 percent for the repair of non-safety-related steam leaks and a rod pattern adjustment. The plant returned to rated thermal power on September 17, 2021 and remained there for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending storms forecasted during the week ending September 18, 2021.

71111.04 - Equipment Alignment

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

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

(1) Division 2 residual heat removal/residual heat removal service water during emergency diesel generator (EDG) 12 maintenance during the week ending August 7, 2021

(2) Standby feedwater (SBFW) during unplanned high pressure coolant injection (HPCI)inoperability during the week ending August 14, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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) Relay room during the week ending August 14, 2021

(2) EDG 13 and fuel oil storage tank (FOST) room during the week ending September 18, 2021

(3) EDG 14 and FOST room during the week ending September 18, 2021

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during placement of the north heater drain pump (HDP) in service and the associated power ascension following the center HDP trip and unplanned power reduction on August 28, 2021. Additionally, the inspectors observed a planned power reduction on September 16, 2021 to address non-safety-related steam leaks and a rod pattern adjustment.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples 1 Partial)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) General Electric type HFA relays

(2) Standby gas treatment system (3) (Partial)

Residual heat removal service water system

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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) Planned EDG 11 and reactor core isolation cooling system work the week ending April 10, 2021

(2) Main condenser tube leak and associated emergent work activities for investigation and repair during the weeks ending July 3 and July 10, 2021

(3) Unplanned HPCI inoperability during the week ending August 14, 2021 due to an error signal on the controller

(4) Trip of the center HDP on August 27, 2021

(5) Removal of the southeast reactor building subbasement sump covers during maintenance during the week ending September 4, 2021

(6) Swap of reference leg backfill system the week ending September 25, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

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

(1) Alternate diesel fire pump suction hose damaged by general service water sluice gate during the week ending April 24, 2021

(2) Spent fuel pool Boral test coupon results during the week ending July 24, 2021

(3) Operability and functionality of reactor building steam tunnel equipment with area temperatures above the administrative design limit due to a steam leak, completed May 8, 2021

(4) Mechanical draft cooling tower (MCDT) fan 'C' low oil level during the week ending July 31, 2021

(5) Reactor water cleanup system (RWCU) isolation operability based on design calculation questions on September 2, 2021

(6) Impact of maintaining the reactor building steam tunnel door open during at-power operations during the week ending October 2, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Planned maintenance on EDG 12 during the week ending August 21, 2021

(2) HPCI run following orifice plate inspections during the week ending September 18, 2021

(3) Emergent DC power issue during the week ending September 18, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Jet pump 5 calibration during the week ending July 17, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) EDG 14 diesel generator service water test (w/ fuel oil and air testing) during the week ending August 7, 2021

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:

Annual siren inspection and maintenance records for the period from June 2019 to June 2021 Monthly alert notification system (siren) tests for the period from June 2019 to June 2021

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

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

71114.05 - Maintenance of Emergency Preparedness

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

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

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Emergency preparedness drill on August 10,

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensees radiological work planning. The inspectors reviewed the following activities:

(1) RWP 20-2040; Torus Recoat Project - Overall Diving, Decon, Wash Down, Water Management and Associated Work

(2) RWP 20-2042, Torus Recoat Project - Grit Blasting, Painting, Demob, Shipping and Associated Work

(3) RWP 20-2043, Downcomer Vent Header Emergent Repairs Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (5 Samples)

The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following as low as reasonably achievable (ALARA) planning documents and the associated radiological outcome evaluations:

(1) RWP 20-2040; Torus Recoat Project - Overall Diving, Decon, Wash Down, Water Management and Associated Work; ALARA Plans, Work in Progress Reports, and Post Job Completion ALARA Evaluations

(2) RWP 20-2042, Torus Recoat Project - Grit Blasting, Painting, Demob, Shipping and Associated Work, ALARA Plans, Work in Progress Reports, and Post Job Completion ALARA Evaluations

(3) RWP 20-2043, Downcomer Vent Header Emergent Repairs., ALARA Plans, Work in Progress Reports and Post Job Completion ALARA Evaluations

(4) RWP 20-2025, G33 (RWCU), P73 (HWC) System Maintenance and Inspection, ALARA Plans, Work in Progress Reports and Post Job Completion ALARA Evaluations

(5) RWP 20-4002, RB5 - Reactor Core Alterations, Bridge Maintenance, LPRM Replacement and Support Activities, ALARA Plans, Work in Progress Reports and Post Job Completion ALARA Evaluation

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (2 Samples)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls. The inspectors reviewed the following activities:

(1) RWP 21-1031, G33 (RWCU) System Maintenance and Inspection

(2) RWP 21-013, Scaffold Group Tasks

Radiation Worker Performance (IP Section 03.04) (1 Sample)

The inspectors observed the following activities:

(1) The build of scaffolding in the drywell personnel access area which was located in a high radiation area

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

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

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

(1) Radioactive Waste Building Ventilation Turbine Building Ventilation

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices including the observation of quantitative respirator fit tests

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

(1) The inspectors observed the licensees inspection of the MSA Air Hawk self-contained breathing apparatuses.

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (5 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) The inspectors observed the operation of the Atlan-Tech Whole Body Counter

(2) The inspectors observed the operation of the Hopewell Designs instrumentation calibrator

(3) The inspectors observed the instrumentation available for use at the RP instrumentation calibration facility and the Radiologically Controlled Area (RCA) exit

(4) The inspectors observed the operation of the continuous air monitors located within the Turbine Building

(5) The inspectors observed the radioactive source response checks of the instrumentation located at the alternate RCA access facility

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (2 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) Liquid radioactive effluent release system including release tanks and liquid effluent release monitor

(2) Gaseous effluent off gas system

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) July 1, 2020 through June 30, 2021

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

(1) July 1, 2020 through June 30, 2021

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

(1) July 1, 2020 through June 30, 2021

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

(1) October 1, 2020 through March 31, 2021 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)

(1 Sample)

(1) October 1, 2020 through March 31, 2021 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) October 1, 2020 through March 31, 2021

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Scaffold and storage issues during the week ending September 18, 2021

(2) E5150F008 reactor core isolation cooling valve packing leak during the week ending September 18,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.13 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR 50.65(a)(4) states, in part, before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

Contrary to the above, on April 4, 2021, the licensee did not assess and manage the increase in risk before performing planned lockout relay surveillance testing associated with emergency diesel generator (EDG) 11 and planned corrective maintenance on the reactor core isolation cooling (RCIC) warmup bypass inlet motor operated valve E5150F095 at the same time. Specifically, the licensee listed only valve E5150F095 as unavailable in the maintenance work order. However, the entire RCIC system was unavailable due to the clearance and tagging boundary impacting other RCIC structures, systems, and components.

Therefore, the online probabilistic risk model was updated during work implementation to only show both EDG 11 and E5150F095 as unavailable. This resulted in a green probabilistic risk classification. After work had already commenced rendering both EDG 11 and RCIC systems unavailable, an on-shift senior reactor operator recognized the entire RCIC system should have been input to the online probabilistic risk model as unavailable. The result was a model output of a yellow probabilistic risk classification, which was an unplanned change in risk classification and missed opportunity to manage the increase in risk that resulted from the proposed maintenance activities beforehand.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process." Because the performance deficiency was associated with 10 CFR 50.65(a)(4) performance (Flow Chart 1), the incremental core damage probability deficit was <1E-6 and the incremental large early release probability deficit was <1E-7, the finding screened to Green.

Corrective Action References: CARD 21-23130 Failure to Adequately Position Alternate Diesel Fire Pump Suction Hose and Strainer Resulted in Equipment Damage During General Service Water Sluice Gate Operation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.15 Systems FIN 05000341/2021003-01 Evaluation Open/Closed A self-revealed finding of very low safety significance (Green) was identified when the licensee failed to adequately position the alternate diesel fire pump (ADFP) suction hose and strainer to prevent interference with plant equipment as specified in Temporary Modification 21-0001. Specifically, during performance of routine general service water sluice gate operation, the ADFP suction hose and strainer were caught on a sluice gate and subsequently damaged. As a result, the ADFP was declared non-functional.

Description:

On August 27, 2019, an ADFP was temporarily installed due to an equipment problem with the permanently installed diesel fire pump. The ADFP suction line was routed through the general service water pump house and into the general service water pump pit using flexible hoses with an attached suction strainer via temporary modification 19-0014. The general service water pump pit contained two motor operated sliding sluice gates that were used to physically isolate the general service water pump pit from Lake Erie if needed (such as during low lake level conditions). On October 20, 2020, during periodic general service water east and west sluice gate cycling operation, the west sluice gate was observed by local equipment operators to be catching on the ADFP flexible suction hose. Sluice gate operation was subsequently stopped prior to any equipment damage to the suction hose or sluice gate.

CARD 20-31437 was generated to document the issue and corrective action was taken to physically remove the ADFP suction hose from the general service water pump pit. The ADFP was not in service at the time, nor required to be functional, as the permanently installed diesel fire pump had been returned to functional status on August 27, 2020 following maintenance. The licensee did not perform additional evaluation to determine the cause of the ADFP suction hose interference with the west general service water sluice gate since the temporary equipment had been removed.

On February 7, 2021, the ADFP was re-installed via temporary modification 21-0001 due to an equipment problem with the permanently installed diesel fire pump. Temporary modification 21-0001 listed CARD 20-31437 as applicable operating experience and stated, in part, the ADFP suction line will be routed to avoid interference with other plant equipment.

In addition, it included a special precaution to ensure the suction hose strainer was positioned to preclude catching/interfering with the sluice gates.

On April 20, 2021, while performing routine general service water sluice gate operation, the ADFP suction hose was observed by local equipment operators to be catching on the west general service water sluice gate and an abnormal noise was heard. The ADFP was subsequently declared non-functional. Visual inspection of the ADFP suction line revealed damage to the flexible hose and the suction strainer had become detached. Technical Requirements Manual Limiting Condition for Operation 3.12.2, Condition A, allows up to a 14-day completion time to either restore or provide an alternate backup pump with one fire suppression pump non-functional. The ADFP was declared functional on April 28, 2021 following repair and installation of an additional suction line restraint to prevent catching on the general service water sluice gates.

Corrective Actions: The licensee's corrective actions included, but were not limited to, an investigation into the causes of the circumstances that led to the damaged ADFP suction line, installation of an additional ADFP suction line restraint, and additional written notes in the work instructions associated with periodic sluice gate operation for awareness of the potential for interference with the sluice gate when the ADFP is installed.

Corrective Action References: CARD 21-23483

Performance Assessment:

Performance Deficiency: The licensee's failure to adequately position the ADFP suction hose and strainer to prevent interference with plant equipment was contrary to Temporary Modification 21-0001 and was a performance deficiency. As a result, during performance of routine general service water sluice gate operation, the ADFP suction hose and strainer were caught on a sluice gate and subsequently damaged.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to adequately position the ADFP suction hose and strainer resulted in the ADFP being declared non-functional due to interference with the west general service water sluice gate and subsequent equipment damage.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. In accordance with Step 1.4.3, Fire Water Supply, the inspectors determined that the finding was of very low safety significance (Green). Specifically, the electric fire pump was available to provide adequate fire water capacity for protection of equipment important to safe shutdown in the most limiting location onsite for the duration that the ADFP was non-functional.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, an evaluation was not performed to determine the cause of the ADFP suction hose catching on the west general service water sluice gate in 2020. As a result, the ADFP suction line was re-installed in a similar manner in 2021 and the ADFP suction hose was caught again on the west general service water sluice gate.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Unanalyzed Condition due to Open Steam Tunnel Door Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.13] - 71111.15 Systems NCV 05000341/2021003-02 Consistent Open/Closed Process The inspectors identified a finding of very low safety significance with an associated non-cited violation of 10 CFR 50.65 (a)(4) for the licensee's failure to assess and manage the risk associated with maintaining the reactor building steam tunnel (RBST) door open for longer than needed for normal ingress/egress. As a result, an unanalyzed condition was created regarding high energy and medium energy line breaks (HELBs and MELBs), and internal flooding.

Description:

In April of 2021, the licensee noted indications of a steam leak in the RBST based on an upward trend in steam tunnel temperatures. Over the course of about a week, the licensee conducted three planned entries of personnel into the RBST to try to identify the leak source.

The normally closed watertight door R1-11 was maintained open for longer than needed for normal ingress/egress but less than an hour for each entry. This door provided access from the reactor building first floor to the RBST and protected safety-related equipment in the reactor building from the effects of a HELB, MELB, and flooding from pipes in the RBST.

Door R1-11 was listed as a barrier for these events in licensee procedure 35.000.242, "Barrier Identification and Classification," Revision 58.

While the licensee considered the industrial, radiological, and fire protection aspects of entering the RBST, the inspectors noted the licensee did not evaluate the impacts of maintaining door R1-11 open on temperature instruments inside the RBST and on components outside the RBST should a HELB, MELB, or flood occur. After evaluating the inspectors concern, the licensee determined maintaining the door open for longer than normal ingress/egress was an unanalyzed condition due to the lack of an evaluation for these events with the door open at full power. The licensee also noted four other occasions within the past three years that the door was maintained open at power for longer than needed for ingress/egress, including an occasion that lasted 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. On May 3, 2021, the licensee submitted a notification to the NRC regarding the unanalyzed condition (i.e., Event Notification 55231) and stopped maintaining the RBST door open. The licensee later completed a planned shutdown and repaired a leak from the packing area of a valve in the steam tunnel.

Corrective Actions: The licensee performed a root cause evaluation and initiated an analysis to determine the effects of maintaining door R1-11 open on components outside the RBST.

Corrective Action References: CARD 21-23855

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to assess and manage the increase in risk before maintaining door R1-11 open for longer than needed for ingress and egress as part of maintenance activities was contrary to 10 CFR 50.65 (a)(4) and was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to assess and manage the increase in risk before maintaining door R1-11 open for longer than needed for ingress and egress did not ensure multiple mitigating systems remained available, reliable, and capable of responding to pipe breaks originating in the RBST.

Significance: The inspectors assessed the significance of the finding using Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors first referred to IMC 0609 Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," as the finding involved the licensees assessment and management of risk associated with performing maintenance activities in accordance 10 CFR 50.65(a)(4).

Appendix K contains a note that states it does not apply for situations where the licensee only performed qualitative analyses of plant configuration risk due to maintenance activities. For this finding, the risk was qualitative as it dealt with a degraded barrier (door R1-11). Per the note, the significance of this finding must be determined by an internal NRC management review using risk insights where possible. The inspectors utilized IMC 0612 Appendix M, to determine the significance of the finding.

The inspectors performed an initial evaluation per step 4.1 of Appendix M which had several qualitative considerations. The door to the steam tunnel was not blocked open, rather, it was held open by licensee personnel. It was designed to close in the outward direction, thereby offering a reasonable chance of being shut by any pressure buildup. Additionally, the steam tunnel contains blowout panels that are designed to relieve pressure to the turbine building.

Severe ruptures would likely blow the panels out and divert a significant amount of energy to the turbine building which is devoid of safety related components. Each period of time the door was open recently was less than one hour. Although there was a time in 2018 the door was open for approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, the plant was at low power for that entry. Given the low probability of a rupture in those time windows and the fact there was operable temperature detection instrumentation that would have isolated most ruptures in the steam tunnel quickly, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the licensee root cause evaluation determined that individuals inconsistently referenced the applicable precautions and limitations contained in revision 58 of procedure 35.000.242 when managing the risk of HELB/MELB/flood barriers.

Enforcement:

Violation: 10 CFR 50.65 (a)(4) states, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The licensee implemented this requirement, in part, with procedure 35.000.242, "Barrier Identification and Classification," Revision 58. It listed door R1-11 as a HELB/MELB/flood barrier and stated that doors in the power block should remain closed in Modes 1, 2, and 3 except for normal ingress and egress.

Contrary to the above, on April 17, 18, and 21 of 2021, the licensee did not assess and manage the increase in risk that may result from maintaining RBST door R1-11 open while performing a maintenance activity. Specifically, the licensee maintained door R1-11 open for longer than needed for ingress and egress while performing corrective maintenance inside the RBST. However, the licensee did not assess and manage the impact of a HELB, MELB, or flood originating in the RBST would have on safety-related components in the reactor building.

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

EXIT MEETINGS AND DEBRIEFS

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

On October 14, 2021, the inspectors presented the integrated inspection results to Mr. P. Dietrich, Chief Nuclear Officer, and other members of the licensee staff.

On July 16, 2021, the inspectors presented the emergency preparedness baseline inspection results to Mr. P. Dietrich, Chief Nuclear Officer, and other members of the licensee staff.

On August 11, 2021, the inspectors presented the radiation protection baseline inspection results to Mr. E. Olson, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Date

Procedure

71111.01 Miscellaneous Risk Replace Reference Leg Backfill Train Filter 08/03/2021

Management

Plan

Procedures 20.000.01 Acts of Nature 56

46.000.046 Operation of the Reactor Reference Leg Backfill System 43

MOP01-200 Severe Weather Guidelines 4

71111.04 Drawings 6M721-2006 Condensate Storage and Transfer System Diagram BJ

6M721-5083 Piping and Instrument Diagram Standby Feedwater U

System

M-5706-03 RHR Service Water Make Up Decant and Overflow AH

Systems Functional Operating Sketch

Procedures MMA 08 Scaffolding 20

71111.05 Corrective Action 21-23209 Relay Room Main Halon Cylinder 'D' Indicating Low 04/11/2021

Documents Pressure

Corrective Action 21-28273 NRC Identified Label and or Fire Pre Plan Deficiencies 09/20/2021

Documents

Resulting from

Inspection

Fire Plans FP-AB-2-8 Relay Room, Zone 8, Elevation 613'6" 7

FP-RHR-1-13- RHR Complex, EDG 13 Room, Elevation 590'0" 7

EDG

FP-RHR-1-13- RHR Complex, EDG 13 Oil Storage Room, Elevation 4

OS 590'0"

FP-RHR-1-14- RHR Complex, EDG 14 Room, Elevation 590'0" 6

EDG

FP-RHR-1-14- RHR Complex, EDG 14 Oil Storage Room, Elevation 5

OS 590'0"

71111.11Q Procedures 22.000.03 Power Operation 25 Percent to 100 Percent to 107

Percent

23.108 Extraction Steam and Heater Drains 94

71111.12 Corrective Action 18-25702 N2 Rack Very Low Margin for the Nitrogen Bottles 07/26/2018

Documents 18-27012 Pressure Low for Nitrogen Bottles (20" Torus 09/18/2018

Inspection Type Designation Description or Title Revision or Date

Procedure

Purge/Exhaust and Control for HCVS)

20-33146 Upgrade T4600F420 from Category 3 to Category 2A in 12/22/2020

AOV Program

21-22837 Secondary Containment Hardened Vent and RB HVAC 03/30/2021

High Pressure N2 Supply Pressure Low

21-22988 T4600F407 Failed to Stroke During 24.404.03 04/04/2021

21-22997 Vent Header Recoat Project Requires SGTS Division 1 04/05/2021

and Division 2 Charcoal Replacement

21-24863 E4150F042 Valve Slow to Open During 44.030.153 06/03/2021

21-25328 Identified Enhancements for HFA Relay Contact 06/16/2021

Inspections

21-26025 E4150F042 Extent of Condition 07/08/2021

21-26058 New Relay Procedure 07/09/2021

Corrective Action 21-25339 Response to NRC Question Regarding HFA Relays 06/16/2021

Documents Extent of Condition

Resulting from 21-28269 NRC Question: Accuracy of MRFF for CARD 21-22988 09/20/2021

Inspection

Engineering TE-ELC-17-046 Evaluation of GE HFA Relay Service Life 0

Evaluations TE-T46-21-026 T46K008A, Division 1 SGTS Exhaust Fan Vortex 0

Damper E/P Transmitter, Out of Calibration

Miscellaneous T4600 - (a)(1) Division 1 SGTS Flow Out of Spec High 2

Action Plan

Procedures 29.ESP.07 Primary Containment Venting 12

35.318.017 Inspection and Testing of Multi-Contact Auxiliary Relays 53

MMR Appendix Maintenance Rule SSC Specific Functions 27

E

MMR 03 Scoping 6

71111.13 Corrective Action 21-23130 Unplanned Risk Change from Green to Yellow 04/08/2021

Documents 21-25888 Main Condenser Tube Leak (SW Quad) 07/03/2021

21-26061 Leaking Tube in Main Condenser Located with Helium 07/09/2021

21-26388 Step Change in Division 1 Reference Leg Backfill 07/22/2021

21-26554 Internal Contamination While Performing Tagout D074 07/28/2021

21-26581 Unplanned Contaminated Area Greater Than 07/29/2021

100 Square Food RBB SE Quad

Inspection Type Designation Description or Title Revision or Date

Procedure

21-26582 Crew Learning Opportunity: D074 Sump Cover 07/29/2021

Removed and Clearance Hung Without Engineering

Evaluation

21-26646 Temporarily Removing Sump Covers for Inspections 07/31/2021

Needs to be Evaluated

21-27053 HPCI Flow Controller E4-K615 has "Flow Bad" Alarm 08/11/2021

Locked In

Corrective Action 21-26574 NRC Identified Transient Combustibles RB-1 07/28/2021

Documents 21-26575 NRC Identified Inconsistent Labeling for G1103-C037B 07/28/2021

Resulting from RB SE Equipment Drain Sump G1101-D074 West Pump

Inspection 21-26577 NRC Identified: Removed Cover for RB SE Equipment 07/29/2021

Drain Sump 74 is a HELB/MELB/Flood Barrier

Drawings 6M721-2004 Condensate System BC

6M721-2007 Circulating Water System BZ

6M721-2032 Sump Pump Diagram Radwaste System AL

6M721-2223 Equipment Drains All Floors Auxiliary and Reactor Y

Buildings

Engineering TE-G11-08-030 Justification for Why D073 Sump Cover is not a 0

Evaluations HELB/MELB Barrier

TE-N61-15-078 Condenser Tube Plugging Limit 0

Miscellaneous EF2-PRA-011 Internal Flood Walkdown Summary Notebook 0

Operator Log 08/10/2021

Procedures 22.000.03 Power Operation 25% to 100% to 25% 107

23.101 Circulating Water System 105

23.108 Extraction Steam and Heater Drains 94

46.000.046 Operation of the Reference Leg Backfill System 43

MCE 03 Chemistry Sampling and Analysis 16

MCE 03002 Chemistry Excursion Engineering Evaluation Report 4

MMR APP H Maintenance Rule Conduct Manual - Appendix H - On- 16

Line Core Damage Risk Management Guidelines

MMR 12 Equipment Out of Service Risk Management 20A

MOP 05 Control of Equipment 57

ODE-20 Protected Equipment 27

Inspection Type Designation Description or Title Revision or Date

Procedure

ODE-8 Administrative Guidelines and Desk Instructions 05/27/2021

Work Orders 53648451 Replace E41K615 02/15/2021

278418 Functionally Test Undervoltage LOR 27X-72EA 04/08/2021

58655283 G1101D074 Requires Cleaning to Mitigate Dose Rates 07/26/2021

on Sump Transfer Line

266679 E5150F095 Is Leaking Steam 04/08/2021

61684950 Main Condenser Tube Leak (SQ Quad) 07/04/2021

71111.15 Calculations DC-5426 PBOC - High and Moderate Energy Line Break 08/14/2015

Evaluation

DC-5589 Reactor Building Environmental Response for HELB and 08/04/2007

LOCA Conditions

DC-5779 Calculation of Mass and Energy Release Rates for High 11/12/1999

Energy Line Breaks (HELB)

DECO-04-4653 Enrico Fermi Atomic Power Plant, Unit 2 RWCU Line June 1986

Break Effects Evaluation of the Leak Detection

Thermocouples on the Reactor Building Second Floor

Corrective Action 10-25814 RB-1 Steam Tunnel Temperature is at the Max Design 07/10/2010

Documents Temperature

19-27887 RWCU HELB Analysis in Torus Room did not Consider 10/16/2019

the Effects of Jet Impingement

20-31437 West GSW Sluice Gate Catching on ADFP Suction 10/20/2021

Hose

21-23483 West GSW Sluice Gate Catching on ADFP Suction 04/20/2021

Hose

21-23574 CLO: Poor Communication Causes Repeat Event on 04/22/2021

Surveillance

21-23904 Non-conservative Assumption in MSLB/FWLB Design 05/04/2021

Calcs

21-25105 Review of Vendor Inspection Report of Boral Test 06/09/2021

Coupons

21-25216 Oil Level 'C' MDCT Fan Gear Reducer is Low 06/12/2021

21-26041 RB1 Temperature Excursion Long Term EQ Impact 07/09/2021

21-26119 Lowered MDCT Oil Level 07/12/2021

21-27125 RWCU HELB Analysis in Torus Room Suggested 08/12/2021

Inspection Type Designation Description or Title Revision or Date

Procedure

Approach for Resolution of Jet Impingement

(CARD 19-27887)

21-27168 Operability Determination Potentially Impacted by On- 08/13/2021

Going Investigation Information Entered as CARD Note

Drawings 2359 Rack Construction BWR Spent Fuel Storage Racks 4

27 Rack Construction BWR Spent Fuel Storage Racks 6

2515 Test Coupon and Coupon Tree Spent Fuel Storage 2

Racks

M-S-2000 General Service Water Pump House Mechanical E

Equipment Layout

Engineering TM 19-0014 Alternate Diesel Fire Pump F

Changes TM 21-0001 Alternate Diesel Fire Pump A

Engineering Root Cause Potential Unanalyzed Condition Following Opening of 08/30/2021

Evaluations Evaluation Door R1-11

Report

TE-T22-21-019 PSA Risk Evaluation of Door R1-11 Open 0

Miscellaneous Site EFD Reset - HU Reset Briefing Sheet 08/30/2021

0000 0024 8320 J1100Y000, F1600E011, A, B, C, D, E, F, G, H, I 3

SFP [Confidential]

3002013119 Evaluation of the Impact of Neutron Absorber Material May 2018

Blistering and Pitting on Spent Fuel Pool Reactivity

NET-28084-002- Inspection and Testing of BORAL Surveillance Coupons 0

from Fermi 2 Generating Station [Proprietary]

Procedures 35.000.242 Barrier Identification/Classification 59

MMR 12 Maintenance Rule Conduct Manual 20A

Work Orders 60388549 Implement AWA Number 1 for TM 21-0001 Rev A 02/24/2021

60987174 West GSW Sluice Gate Catching on ADFP Suction 04/28/2021

Hose

71111.19 Corrective Action 21-26665 PI Testing 08/02/2021

Documents 21-26702 RHR 2 EDG 12 Switchgear 08/02/2021

21-26721 Significant Wear on 2 and 10 Lower Pistons 08/03/2021

21-26804 R30FA04C and R30FA05C are Continuously Leaking 08/06/2021

Air Through their Vent Ports

21-26860 EDG 12 Starting Air Compressor Lube Oil Moisture 08/07/2021

Inspection Type Designation Description or Title Revision or Date

Procedure

Greater Than Expected

21-26991 EDG12 SAC Increased Run Times Post SSO 08/09/2021

21-27388 HPCI and Division 2 EDG Sequencer Power Failures 08/22/2021

21-27395 130V Battery Charger 2B-2 Low Voltage 08/23/2021

21-27397 Division 2 EDG Automatic Load Sequencer Power 08/23/2021

Supply (PS-2) Failed

21-27428 Bench Calibration Found OOT for New Inverter 08/24/2021

21-27683 Equalize Timer will Spuriously go into Equalize 08/31/2021

Drawings 6I721-2225-02 HPCI System Power Distribution S

6I721-2714-40 EDG Automatic Digital Load Sequencing System G

H11P898B

6M721-2035 High Pressure Coolant Injection System Reactor BQ

Building

6M721-2043 High Pressure Coolant Injection System Barometric AJ

CNDR Reactor Building

6SD721-2530-11 260/130V Essential Dual Battery 2PB Distribution - AS

Division 2

Miscellaneous Plan of the Day E4100 - High Pressure Coolant Injection General 08/16/2021

VME8-1.1 Colt Industries 12 Cylinder Model 38TD8-1/8 Emergency AC

Diesel Generators [Confidential]

Procedures 24.202.01 HPCI Pump and Valve Operability Test at 1025 PSI 122

34.307.001 Emergency Diesel Generators - Inspection and 84

Preventive Maintenance

35.307.017 Emergency Diesel Generators - Electrical Inspection 6

and Preventive Maintenance

MMA 17 Foreign Material Exclusion (FME) 16

Work Orders 56641508 Replace 2301A and (DRU) Unit in EDG 12 Control 08/02/2021

Panel

56973956 Perform 24.202.08 Sec-5.2 HPCI LSFT and Pump 08/17/2021

Operability at 1025 PSIG

57163006 EDG 12 48 Month Mechanical PM 08/04/2021

210107 Disassemble, Inspect and Reassemble Spectacle 08/16/2021

Flanges (LR, OTL, AMP) E4150D016

61945080 EDG 12 Significant Wear on 2 and 10 Lower Pistons 08/02/2021

Inspection Type Designation Description or Title Revision or Date

Procedure

71111.22 Corrective Action 21-26565 NRC Identified: Adding Vibration Analysis Point Diagram 07/28/2021

Documents to 24.307.37

Resulting from

Inspection

Procedures 47.000.02 Mechanical Vibration Measurements for Trending 46

Work Orders 56787386 Perform 24.307.37DGSW, DFOT and Starting Air 07/28/2021

Operability Test - EDG 14

60331762 Calibrate RPV Jet Pump 5 Flow/Pressure Indicating 07/15/2021

Loop

71114.02 Corrective Action CARD 20-23535 Monroe County Central Dispatch Encoder 03/30/2020

Documents CARD 20-29639 Siren 32 Rotation Fail 08/26/2020

CARD 20-31696 Unexpected Results During Monthly Siren Test 10/28/2020

CARD 20-31697 Monroe County Central Dispatch Encoder 03/30/2020

CARD 21-23363 Evaluate ANS Siren Failures to Determine Reliability 04/15/2021

Improvement Actions

Miscellaneous FEMA Approval Letter for Fermi 2 ANS Design Report, 11/30/2015

Revision 1

Siren Test Results 05/01/2019-

05/31/2021

Siren Annual Preventative Maintenance Records 09/01/2019-

06/30/2021

DTE Energy Emergency Preparedness for Monroe and

Wayne Counties 2021 (Handbook)

Procedures Fermi 2 Radiological Emergency Response 48

Preparedness Plan

Alert and Notification System (ANS) Design Report 1

Alert and Notification System (ANS) Design Report 2

EP-560 Alert and Notification System Operation and 7

Maintenance

71114.03 Corrective Action CARD 19-27240 Post ECOS Test Result Roll Up - Blue Team 09/25/2019

Documents CARD 19-27945 Suggestion to Improve Usability of ECOS 10/18/2019

CARD 20-31620 Red Team I and C Engineer Failed to Respond to ECOS 10/27/2020

CARD 21-23024 Two RERP EOF Team Members did not Respond to 04/05/2021

ECOS Call-Out (Red Team)

Inspection Type Designation Description or Title Revision or Date

Procedure

Miscellaneous Fermi 2 On-shift Staffing Analysis 12/20/2012

Fermi 2 ERO Team List 06/21/2021

ERO Team Training and Qualification Records 07/14/2021

(Sample - 12)

ERO Quarterly Augmentation Drill Records 06/01/2019-

06/30/2021

Procedures Fermi 2 Radiological Emergency Response 48

Preparedness Plan; Section B, Emergency Response

Organization

EP-290 Emergency Notifications 62

EP-292 Emergency Call Out - Backup Method 32

EP-540 Drills and Exercises 41

EP-550 RERP Training Program 5B

EP-570 Emergency Call Out System - Testing and Maintenance 6A

EP-570, ECOS Test Reviews (Quarterly) June 2019-June

2021

QP-ER-670 Radiological Emergency Response Preparedness 8

Selection, Training and Qualification Program

Description

71114.05 Corrective Action 19-28480 RERP Drill 10/13/2019: Weaknesses Observed in Dose 11/06/2019

Documents Assessment - Marginal Performance

20-32545 Missed EAL Classification (DEP Opportunity) During 12/01/2020

LOR Annual Exam

21-10089 The Intent of EP-204-01, Damage Control and Rescue, 05/20/2021

Section 4.2 is not Being Met Based on Current

RERP/DCRT Staffing/Canvassing Practices

EP-290 Emergency Notifications 62

EP-292 Emergency Call Out - Backup Method 32

EP-580 Equipment Important to Emergency Response (EITER) 10

EP-590 10 CFR 50.54(q) Screens and Evaluations 1

Miscellaneous Emergency Preparedness Letters of Agreements with 09/01/2019-

Off-Site Response and Support Organizations 09/30/2020

Select Exercise and Drill Evaluation Reports 09/01/2019-

04/30/2021

Inspection Type Designation Description or Title Revision or Date

Procedure

Quarterly Control Room ERF Testing and Maintenance 09/01/2019-

Records 04/30/2021

Quarterly Emergency Operations Facility ERF Testing 09/01/2019-

and Maintenance Records 04/30/2021

Quarterly Technical Support Center ERF Testing and 09/30/2019-

Maintenance Records 04/30/2021

Quarterly Operations Support Center ERF Testing and 09/30/2019-

Maintenance Records 04/30/2021

Audit Report 19- Quality Assurance Audit of the Emergency 09/27/2019

0109 Preparedness Program

Audit Report 20- Quality Assurance Audit of the Emergency 10/08/2020

0111 Preparedness Program

KLD TR-1137 Fermi 2 Nuclear Power Plant 2020 Population Update 09/26/2020

Analysis

Procedures EP-101 Classifications 43A

EP-601 Public Education and Information 11

71114.06 Miscellaneous August 10, 2021 Emergency Preparedness Drill 08/10/2021

Package

Procedures EP-101 Classification of Emergencies 43A

71124.02 ALARA Plans 20-2025 G33 (RWCU), P73 (HWC) System Maintenance and Various

Inspection - ALARA Plans, Work in Progress Reports,

and Post Job Evaluation

20-2040 Torus Recoat Project - Diving, Decon, Wash Down, Various

Water Management, and Associated Work - ALARA

Plans, Work in Progress Reviews, and Post Job

Evaluation

20-2042 Torus Recoat Project - Grit Blasting, Painting, Demob, Various

Shipping and Associated Work - ALARA Plans, Work in

Progress Reviews, and Post Job Evaluation

20-2043 Torus Downcomer Vent Header Emergent Repairs - Various

ALARA Plans, Work in Progress Reviews, and Post Job

Evaluation

20-4002 RB5 - Reactor Core Alterations, Bridge Maintenance, Various

LPRM Replacement and Support Activities - ALARA

Inspection Type Designation Description or Title Revision or Date

Procedure

Plans, Work in Progress Reviews and Post Job ALARA

Evaluation

21-1031 June 2021 RWCU System Outage 0

Corrective Action 20-25334 RWCU Line Hydrolazing Evolutions Lessons Learned 04/28/2020

Documents 20-32652-02 SAC Benchmarking Improvements 01/15/2021

20-32652-08 Self-Assessment Recommendation - Improvements in 04/23/2021

Outage RWP Dose Estimates

21-23101 Self-Assessment Deficiency - Gap in RF20 Work in 04/07/2021

Progress Quality

Miscellaneous Station ALARA Committee Reports for Refueling Outage Various

RF20

Procedures 63.000.200 ALARA Reviews 46

MRP 05 ALARA/RWPS 16

Radiation Survey P-M- Q-35 DW Personnel Access 06/16/2021

Surveys 20210616-7

Self- NPRP-21-0037 QHAS - Occupational ALARA Planning and Controls 05/23/2021

Assessments (Inspection Plan 71124.02)

71124.03 Miscellaneous Grade D Air Sample Analysis for the Scott Air Various

Compressor System (Second Quarter 2019 through

Second Quarter 2021)

MSA SCBA Inspection Records (First Quarter 2021) Various

MSA SCBA Annual Calibration and Flow Tests 05/13/2021

SCBA Qualification Records for the SRO/ROs On Shift Various

06/21/2021

Procedures 65.000.704 Issuance of Respiratory Protection Equipment 19

65.000.717 Inspection, Maintenance and Hydrostatic Testing of 12

Breathing Air Cylinders

MRP 09 Respiratory Protection 18

WI-RH-018 Work Instruction for Performing Quantitative Respiratory 14

Fit Testing Using the TSI Model 8030 Portacount

Radiation RWP 21-1031, RWCU System Outage, Airborne 06/21/2021 -

Surveys Radioactivity Determinations 06/22/2021

Self- NPRP-21-0038 Quick Hit Self-Assessment 71124.03 - In Plant Airborne 06/03/2021

Assessments Radioactivity Control and Mitigation and 71124.04 -

Inspection Type Designation Description or Title Revision or Date

Procedure

Occupational Dose Assessment

71151 Corrective Action CARDs related to E5100 07/01/2020-

Documents 6/30/2021

EP-540, NRC Performance Indicators-RERP 41

D

Corrective Action 21-28580 NRC Identified Error in RHRSW MSPI Hours for 09/28/2021

Documents February 2021

Resulting from

Inspection

Miscellaneous Fermi 2 - Mitigating Systems Performance Index (MSPI) 8

Basis Document

MSPI Derivation Report - Cooling Water System 06/2021

Unavailability Index

MSPI Derivation Report - Cooling Water System 06/2021

Unreliability Index

MSPI Derivation Report - Residual Heat Removal 06/2021

System Unavailability Index

MSPI Derivation Report - Residual Heat Removal 06/2021

System Unreliability Index

Site MSPI Submittals for Heat Removal System July 2020 - June

21

ALC Narrative Logs Containing E5100 7/1/2020 - 09/20/2021

9/1/2020; 12/1/2020 - 2/1/2021; 5/1/2021 - 7/1/2021

Alert and Notification System Reliability Records 10/01/2020-

03/31/2021

Emergency Response Organization Drill Participation 10/01/2020-

03/31/2021

Drill and Exercise Performance Records 10/01/2020-

03/31/2021

71152 Corrective Action 21-24269 Observed Change in IPCS RCIC Steam Flow Indication 05/15/2021

Documents 21-24290 Leak Walkdown - Damage to Valve Stem 05/16/2021

21-27280 APS: Removal of Scaffolds Pending Engineer Approved 08/18/2021

Permanent Platforms

Corrective Action 21-26212 NRC Identified Missing Reviews on the 50-59 Form on a 07/15/2021

Inspection Type Designation Description or Title Revision or Date

Procedure

Documents Scaffold, WO 59193074

Resulting from 21-26754 NRC Identified 4 Scaffolds Constructed > 90 Days Ago 08/04/2021

Inspection

Drawings 5M721-6015 4" 900 OSY Powell OSY Gate Valve with Limitorque 0

Operator

Miscellaneous Fermi Plant Log Scaffold Log August/September

21

PEP 33 Valve Packing Guide 0

Procedures MMA 08 Scaffolding 20

MOP 23 Plant Storage 7

26