ML22313A103
| ML22313A103 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/09/2022 |
| From: | Karla Stoedter NRC/RGN-III/DORS/EB1 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2022010 | |
| Download: ML22313A103 (18) | |
See also: IR 05000341/2022010
Text
Mr. Peter Dietrich
Senior VP and Chief Nuclear Officer
DTE Electric Company
Fermi 2 - 260 TAC
6400 North Dixie Highway
Newport, MI 48166
SUBJECT:
FERMI POWER PLANT, UNIT 2 - DESIGN BASIS ASSURANCE INSPECTION
(TEAMS) INSPECTION REPORT 05000341/2022010
Dear Peter Dietrich:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Fermi Power Plant, Unit 2 and discussed the results of this inspection with
Mr. E. Olson, Site Vice President 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.
If you contest the violation or the significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector
at Fermi Power Plant, Unit 2.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant,
Unit 2.
November 9, 2022
P. Dietrich
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,
Karla K. Stoedter, Chief
Engineering Branch 1
Division of Operating Reactor Safety
Docket No. 05000341
License No. NPF-43
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by Stoedter, Karla
on 11/09/22
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RIII
RIII
NAME
ESanchez-
Santiago:mb
KStoedter
DATE
11/09/2022
11/09/2022
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000341
License Number:
Report Number:
Enterprise Identifier:
I-2022-010-0048
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
August 08, 2022 to September 30, 2022
Inspectors:
C. Baron, Mechanical Contractor
J. Benjamin, Senior Resident Inspector
B. Daley, Senior Reactor Inspector
M. Domke, Reactor Inspector
K. Fay, Reactor Inspector
B. Jose, Senior Reactor Inspector
E. Sanchez Santiago, Senior Project Engineer
Approved By:
Karla K. Stoedter, Chief
Engineering Branch 1
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a design basis assurance inspection (teams) inspection at Fermi
Power Plant, Unit 2, in accordance with the Reactor Oversight Process. The Reactor Oversight
Process is the NRCs program for overseeing the safe operation of commercial nuclear power
reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Ensure Operating Experience Review of NRC Information Notice 2017-06 was
Completed with Appropriate Rigor
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.14] -
Conservative
Bias
The inspectors identified a finding of very low safety significance (Green), that was not
associated with a violation of NRC requirements, for the licensees failure to perform a review
of Operating Experience (OPEX) with appropriate rigor to ensure risk to the station was
minimized or eliminated as specified in Fermi 2 Licensing/Safety Engineering Conduct
Manual MLS04, Operating Experience Program, Revision 36. Specifically, the licensee failed
to perform a thorough review for NRC Information Notice (IN) 2017-06, "Battery and Battery
Charger Short-Circuit Current Contributions to a fault on the Direct Current (DC) Distribution
System," with appropriate rigor to ensure the risk to the station from a higher than expected
short circuit current contribution from the battery chargers to the DC system was appropriately
minimized or eliminated.
Failure to Identify Potential Tripping of Emergency Diesel Generators (EDGs) during Tornado
Pressure Transients
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title 10
of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective
Action, for the licensees failure to identify a condition adverse to quality. Specifically, the
licensee failed to identify the emergency diesel generators (EDGs) could inadvertently trip
during a tornado due to the rapid reduction of pressure in the EDG rooms and the actuation of
the high crankcase pressure trip. This is a non-conforming condition. The licensee had an
opportunity to identify and correct this vulnerability in response to Corrective Action Review
Document 16-29153 but failed to critically review information provided by the EDG supplier.
Additional Tracking Items
None.
3
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.
REACTOR SAFETY
71111.21M - Design Bases Assurance (DBA) Inspection
The inspectors evaluated the following components and listed applicable attributes, permanent
modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02)
(4 Samples)
(1)
Bus 72F and Bus Regulators, R14005021 and R14005021B
Updated Final Safety Analysis Report, Technical Specifications, Technical
Requirements Manual reviews for license basis requirements
Minimum and maximum short circuit current available at the bus
Minimum voltage available during degraded voltage conditions
Minimum voltage available at the loads fed by the bus
Load breakers coordination with the upstream supply breaker
Short circuit carrying capacity of the supply breaker compared to the available
fault current
Testing or preventive maintenance on the bus and the regulators
Functions of the regulators, how they are monitored, calibrations if any, and
their frequency
Vendor recommended maintenance/regulator replacement frequency.
Review bus and regulator related condition reports.
(2)
Reactor Core Isolation Cooling Pump Discharge Valve, E5150F012
Updated Final Safety Analysis Report, Technical Specifications, Technical
Requirements Manual reviews for license basis requirements
Field walkdown of component E5150F012
Testing and Inspection procedure reviews including acceptance criteria and
recent results for leak rate, in-service testing, and leakage
Translation of vendor specifications to associated procedures
System health (failures, operability evaluations, corrective action review
documents)
Condition Report reviews related to component E5150F012
Licensing changes to reclassify valve from a pressure isolation requirements
due to undersized actuator
4
(3)
Emergency Diesel Generator (EDG) 13,
Updated Final Safety Analysis Report, Technical Specifications, Technical
Requirements Manual reviews for license basis requirements
Evaluation of internal/external flood protection
Evaluation of potential seismic hazards
Evaluation of expendables stored on site
Susceptibility of emergency diesel generator heating and ventilation system to
tornado depressurization transient
EDG area ventilation system design
Air start check valve testing and acceptance criteria basis
Evaluation of EDG frequency and voltage variations
EDG heat exchanger cooling water flow requirements
Fuel oil consumption
Walkdowns to evaluate material condition
Engine trip parameters
Evaluation of operating procedures to manually load/shed loads after accident
Service condition of components
(4)
Division 1 and 2 Battery Chargers
Updated Final Safety Analysis Report, Technical Specifications, Technical
Requirements Manual reviews for license basis requirements
Translation of vendor specifications to associated procedures
System health (failures, operability evaluations, corrective action review
documents)
Electrical design calculations for:
o
Sizing
o
Current limiting setting
o
Duty cycle
o
Short circuit
o
Voltage drop
o
Circuit coordination
o
Fuse sizing and ratings
Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02) (1 Sample)
(1)
Residual Heat Removal Service Water Pump A, E115C001A
Updated Final Safety Analysis Report, Technical Specifications, Technical
Requirements Manual reviews for license basis requirements
Field walkdown
System health (failures, operability evaluations, corrective action review
documents)
Review of condition reports related to the pump and appurtenances
Mechanical design calculations including flow capacity, runout flow, minimum
flow, required submergence, and flow balance
Testing and IPs, acceptance criteria and recent results for quarterly and
comprehensive in-service testing surveillances
5
Modification reviews including pump replacement work order for E115C001A
in 2020
Maintenance effectiveness including Maintenance Rule reviews and
Maintenance procedure reviews
Translation of vendor specifications to associated procedures
Operating procedure reviews during normal, abnormal or accident operations
Modification Review - Permanent Mods (IP Section 02.03) (5 Samples)
(1)
70039; Replacement of Various Circuit Breakers and Power Shields
(2)
80065; Permanent Plant Mod to Ensure that the 4160 ESF Bus Degraded Voltage
Load Shed Logic is Inhibited
(3)
70015; E1150F068B-004 Replacement of Lower Stem Bushing for RHR Division 2
Heat Exchanger Service Water Outlet Isolation Motor Operated Valve
(4)
80127; ECCS [Emergency Core Cooling System] Pump CST [Condensate Storage
Tank] Vortex Suppression Device
(5)
37362; Residual Heat Removal and Core Spray Strong Pump/Weak Pump Interaction
Review of Operating Experience Issues (IP Section 02.06) (2 Samples)
(1)
OE-2020-0175; Grid Disturbance Causes Loss of Spent Fuel Pool Cooling Pump
(2)
NRC Information Notice 2017-06, Battery and Battery Charger Short-Circuit
Contribution to a Fault on DC System
INSPECTION RESULTS
Failure to Ensure Operating Experience Review of NRC Information Notice 2017-06 was
Completed with Appropriate Rigor
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.14] -
Conservative
Bias
The inspectors identified a finding of very low safety significance (Green), that was not
associated with a violation of NRC requirements, for the licensees failure to perform a review
of Operating Experience (OPEX) with appropriate rigor to ensure risk to the station was
minimized or eliminated as specified in Fermi 2 Licensing/Safety Engineering Conduct
Manual MLS04, Operating Experience Program, Revision 36. Specifically, the licensee
failed to perform a thorough review for NRC Information Notice (IN) 2017-06, "Battery and
Battery Charger Short-Circuit Current Contributions to a fault on the Direct Current (DC)
Distribution System," with appropriate rigor to ensure the risk to the station from a higher than
expected short circuit current contribution from the battery chargers to the DC system was
appropriately minimized or eliminated.
Description:
IN 2017-06 discussed test results published in NUREG/CR-7229 by Brookhaven National
Laboratories on different types of battery chargers under short circuit conditions. The test
results showed short circuit current contribution from a Silicon Controlled Rectifier (SCR) type
6
battery charger could be as high as 7 to 10 times the charger's full load rating during the first
100 milliseconds. Fermi 2 has 100 ampere SCR type battery chargers and therefore, the
short circuit current could contribute approximately 700 to 1000 amperes if a fault occurred in
the DC system. NRC inspectors reviewed the licensees response to the IN titled, "OPEX
review of NRC IN 2017-06." During this review, the inspectors noted the original review
performed by the licensee under Corrective Action Report Document
(CARD) 18-21882 was questioned by the 2019 Design Basis Assurance Inspection (DBAI)
team for its adequacy. Subsequently, the licensee revised the OPEX review under
CARDs 19-23579 and 19-23651. During the review of CARD 19-23651, the 2022 DBAI team
identified the licensee had not properly calculated the maximum short circuit current.
Specifically, the licensee had only looked at the maximum short circuit current at the
non-safety-related volt meters closest to the batteries and chargers. Because of the cables
feeding the volt meters were number 12 American Wire Gage (AWG), the maximum fault
current calculated was incorrectly determined to be less than 10,000 Amperes. Since the DC
distribution panel busses were rated for 10,000 Amperes, the licensee concluded that higher
fault current contribution from the battery chargers would only result in loss of one DC division
and no additional damage would occur. However, as a conservative measure, the licensee
replaced the DC distribution panel feeder fuses with 20,000 ampere interrupting capacity. The
inspectors noted the licensees conclusion may not be appropriate as they had neither
evaluated the maximum fault current at the DC busses nor did they verify interrupting ratings
of the battery charger internal fuses and the charger output breaker.
Based on the concerns raised by the 2022 DBAI team, the licensee performed additional
analysis which resulted in fault currents exceeding 10,000 amperes at the Division 2 DC
busses. The licensee-initiated CARDs 22-2900, "2022 NRC DBAI Inspection: NRC identified
technical error in Engineering Design Package (EDP) 70287, Revision 0," and 22-29053
"2022 NRC DBAI Inspection NRC Identified: Information Notice 17-06 not appropriately
evaluated/resolved." The licensee also contacted Sargent and Lundy Engineers to review the
Fermi 2 DC short circuit calculations to see if a more realistic loading pattern could be used in
the calculation. Sargent and Lundy Engineers removed certain DC loads to mimic a more
realistic loading scenario under various conditions and revised the DC load model in the
Electrical Transient Analyzer Program (ETAP) which resulted in less than 10,000 ampere
short circuit current at the Fermi 2 Division 2 DC Busses. As a long-term solution, the
licensee plans to replace the Division 2 DC Busses with more than 10,000 Ampere fault
current carrying capacity. The inspectors did not identify any other technical concerns. The
inspectors reviewed the battery chargers internal fuse characteristics and coordination with
the downstream protective devices and did not identify any concerns.
Section 4.4.4 of Fermi 2 Licensing/Safety Engineering Conduct Manual MLS04, Operating
Experience Program, Revision 36, stated, "Complete CARD evaluations with appropriate
rigor to ensure risk to the station is minimized or eliminated." The inspectors determined the
licensee's initial and subsequent OPEX evaluations for IN 2017-006 did not meet the
licensee's standard for OPEX review stated in MLS04, Section 4.4.4 because the evaluation
was not completed with appropriate rigor to determine the short circuit current contribution
was exceeded 10,000 amperes and impacted the operation of the Division 2 DC busses. The
licensees failure to perform the OPEX reviews within CARDs 18-21882, 19-23579, and
19-23651 with appropriate rigor to minimize or eliminate risk to the station was contrary to the
Fermi 2 Procedure MLS04 and was a performance deficiency. No violations of NRC
requirements were identified since this procedure was not safety-related and, therefore, not
subject to 10 CFR Part 50 Appendix B requirements.
7
Corrective Actions: The licensee revised the OPEX evaluation for IN 2017-06 and concluded
the larger short circuit current contribution from the charger did not exceed the interrupting
ratings of equipment/isolation devices.
Corrective Action References: CARD 22-29053; 2022 NRC DBAI Inspection NRC Identified:
IN 17-06 not Appropriately Evaluated/Resolved.
Performance Assessment:
Performance Deficiency: The inspectors determined the licensees failure to perform a
rigorous OPEX evaluation for IN 2017-06 which minimized or eliminated risk to the station
was contrary to Fermi 2 Procedure MLS04, Operating Experience Program. Specifically, the
licensee failed to appropriately calculate the short circuit current expected and determine the
impact on the Division 2 DC busses.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control attribute of the Mitigating Systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the failure to perform a rigorous OPEX evaluation for
NRC IN 2017-06 resulted in a condition where there was a reasonable doubt that
equipment/isolation devices were able to withstand the larger short circuit conditions provided
by the chargers as described in the IN.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the finding screened as very low safety significance (Green) because the
inspectors answered 'yes' to the question: "If the finding deficiency affecting the design or
qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality?
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices
that emphasize prudent choices over those that are simply allowable. A proposed action is
determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically,
the licensee's initial and subsequent evaluations for IN 2017-06 failed to evaluate the effect of
the larger short circuit current contribution from the charger on the interrupting rating of the
equipment/isolation devices. Instead, the licensee only verified that the short circuit current as
specified in the revised calculation did not exceed the plant equipment/isolation devices
interrupting rating.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Identify Potential Tripping of Emergency Diesel Generators (EDGs) during Tornado
Pressure Transients
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Title
10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI,
8
Corrective Action, for the licensees failure to identify a condition adverse to quality.
Specifically, the licensee failed to identify the emergency diesel generators (EDGs) could
inadvertently trip during a tornado due to the rapid reduction of pressure in the EDG rooms
and the actuation of the high crankcase pressure trip. This is a non-conforming condition. The
licensee had an opportunity to identify and correct this vulnerability in response to Corrective
Action Review Document 16-29153 but failed to critically review information provided by the
EDG supplier.
Description:
The inspectors reviewed the design of the EDGs, including their automatic trip features. The
inspectors noted the high crankcase pressure trip (two out of three logic for each EDG) was
considered essential and would not be bypassed during an emergency EDG start in the event
of an accident or loss of offsite power (LOOP). Because the high crankcase pressure trip
instruments measure the pressure difference between the diesel engine crankcases and the
EDG rooms, the inspectors questioned if the EDGs could be subject to an inadvertent trip if
the room pressures were suddenly reduced as a result of a postulated tornado event.
Updated Final Safety Analysis Report (UFSAR) Section 8.3.1.1.8.2 stated, "the RHR complex
structure serves to contain, protect, house, and support the equipment of the EDG system
and protect it from the outdoor environment." Section 8.3.1.1.8.2.i states, "the EDG system is
designed to be operable during and after a design-basis tornado that has the following
characteristics Differential pressure between inside and outside of fully enclosed areas -
3 lb/in.2 All building structures housing equipment necessary for safe shutdown are designed
to withstand a tornado-induced depressurization rate of 1 lb/in.2/sec for 3 seconds."
The inspectors questioned if the EDG rooms in the RHR complex were considered to be fully
enclosed areas and if the tornado-induced depressurization rate of those rooms had been
previously analyzed to determine if the EDGs could inadvertently trip. In response, the
licensee stated an evaluation had been performed in 2016 based on industry experience.
Corrective Action Review Document (CARD) 16-29153 had been initiated on November 14,
2016, to investigate the potential impact of a tornado on the EDGs. This investigation was a
result of a similar concern at another facility where high crankcase pressure switches, as
originally supplied by the diesel generator vendor, which are susceptible to actuation due to
pressure differentials during a tornado event. The consequence is that a trip of the crankcase
pressure switch, while in standby, causes actuation of the shutdown relays. This in turn
causes a lockout, keeping the EDG from being able to start during an emergency condition.
The cause was that the design of the crankcase pressure switch trip logic did not consider the
effect of outside atmospheric pressure during a tornado event." This CARD concluded that
there was no design deficiency present in the Fermi EDGs and no engineered/installed
modifications were required. This conclusion was based on input from the EDG supplier,
Fairbanks-Morse Engine.
The licensee also provided correspondence from the EDG supplier, dated November 17,
2016, which explained why the specific concern addressed on the CARD (activation of a
crankcase pressure switch when the EDG is in standby) was not applicable to Fermi.
However, this correspondence also addressed the potential of a trip when an EDG was
already operating. This portion of the correspondence was based on an unsubstantiated
assumption. Specifically, it stated the crankcase pressure switches are within the engine
room (the engine space) and are monitoring the differential between the pressure in the room
and the pressure (vacuum) in the crankcase. Even with the engine in operation, the pressure
outside of the building should not have an effect on the operation of these pressure switches.
9
And, in fact, because the outlet of the ejector is in the exhaust system (subject to the
pressure outside the building), the lower pressure created by the tornado would have a
tendency to lower the pressure at the outlet of the ejector which would in turn tend to lower
the pressure in the crankcase.
The inspectors questioned whether the assumption that the pressure outside of the building
should not have an effect on the operation of these pressure switches, which was implied in
the vendors correspondence, had been verified by the licensee. Specifically, the inspectors
asked if the EDG rooms were isolated from the outside atmospheric pressure and if the EDG
crankcase air ejector had sufficient capacity to reduce the crankcase pressure and prevent a
trip during a design basis tornado pressure transient event. The licensee stated a quantitative
analysis had not been performed and stated the vendor would be contacted for additional
information.
After performing additional investigation, the licensee-initiated CARD 22-28738 on August 15,
2022. The CARD stated that it is clear the high crankcase pressure trip would be activated if
the EDG were operating prior to the depressurization of the RHR complex (which houses all
four EDGs). In addition, the licensee-initiated CARD 22-28763 on August 16, 2022, to
evaluate elimination of the EDG crankcase pressure trips or converting the trips to
non-essential (bypassed on an emergency start).
Corrective Actions: CARD 22-28738 was initiated on August 15, 2022, to address this issue.
Corrective Action References: CARDs 22-28664, "Previous Fermi Evaluation of OE in
Regard to Potential for Tornado," 22-28738, "IOD Not Supported"
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to identify the
potential tripping of the EDGs due to atmospheric pressure transients caused by a postulated
tornado is a performance deficiency. Specifically, the licensee failed to identify a design
vulnerability that could result in the inadvertent tripping of one or more EDGs. The licensee
had an opportunity to identify and correct this vulnerability in response to CARD 16-29153 but
failed to critically review information provided by the EDG supplier.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control attribute of the Mitigating Systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the atmospheric pressure transient resulting from a design basis
tornado could result in the inadvertent tripping of one or more EDGs.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the finding screened as having very low safety significance (Green) because
they answered 'yes' to the questions: "If the finding is a deficiency affecting the design or
qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality?
The inspectors determined the finding did not cause a loss of PRA functionality.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
10
performance. The last update of the crankcase pressure trip setpoints and associated
analysis was greater than 3 years ago.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part,
measures shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected.
Contrary to the above, on November 14, 2016, the licensee failed to identify a condition
adverse to quality. Specifically, the licensee performed a review of CARD 16-29153 as a
result of operating experience related to the potential impact of a tornado on the EDGs and
failed to identify the effects of a tornado could cause the EDGs to trip during a LOOP due to a
high crankcase pressure signal. The EDGs tripping during a tornado event is nonconforming
with Section 8.3.1.1.8.2.i of the UFSAR which states, "the EDG system is designed to be
operable during and after a design-basis tornado that has the following characteristics
Differential pressure between inside and outside of fully enclosed areas -3 lb/in.2 All building
structures housing equipment necessary for safe shutdown are designed to withstand a
tornado-induced depressurization rate of 1 lb/in.2/sec for 3 seconds."
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 September 30, 2022, the inspectors presented the design basis assurance
inspection (teams) inspection results to Mr. E. Olson, Site Vice President and other
members of the licensee staff.
On August 26, 2022, the inspectors presented the interim design basis assurance
inspection (teams) inspection results to Mr. E. Olson, Site Vice President and other
members of the licensee staff.
11
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DC-4953
RHR Complex - Abnormal Operation Damper Lineups
I
DC-5367
Seismic Evaluation of 480V and 4160V Switchgears and
Motor Control Center Breakers
0
DC-5426
PBOC - High and Moderate Energy Line Break Evaluation
D
DC-5489
Ventilation Air Quality for Diesel Generator Room 11
B
DC-5803
RHRSW Design Basis Requirements
C
DC-5804
DGSW Design Basis Requirements Calculation
F
DC-5866
RHR Complex Evaluation During Site Flood
0
DC-6249
Service Water Systems Calibrated Hydraulic Model
0
DC-6309
Design Basis of EDG Fuel Oil and Day Tank Level
Requirements and Setpoints
B
DC-6447
Auxiliary Power System Analysis
F
DC-6480
130/260V DC System Analysis
C
DC-6482
260/130V and 48/24V DC Protective Device Coordination
Calculation
D
Calculations
DC-6774
Fuel Oil Storage Tank Room Minimum Temperature
0
05-26492
Design Calculation for RHR Complex Depressurization is not
Available
11/17/2005
13-24840
EDG Steady State Voltage and Frequency Tech Spec
Ranges
07/10/2013
16-29153
Potential Impact of a Tornado on the Emergency Diesel
Generator
11/14/2016
17-28611
E1150F068B Packing Leak
1
19-28434
Request Revision to Scope of Outage Work Orders for Bus
Inspections
05/11/2019
20-20568
Request Work Orders for Replacement of 1SA62 and 1SB62
Relays
01/17/2020
20-20637
Tracking CARD for Revision of 24.205.05
06/22/2020
20-22467
IST to Investigate Implementing 2 Pump Testing of the RHR
SW Pumps
03/06/2020
Corrective Action
Documents
20-25227
Shoulder Bolt for Breaker Slide Bracket Stripped - 72F
Position 2B
04/26/2020
12
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20-25312
Open Light Socket Failure on 72F Position 3A Breaker
04/28/2020
20-25559
Blown Fuse Found for ESF 2B1-2 Battery Charger
05/05/2020
21-20678
While Racking out 72F Position 5A (Feed to MCC 72F-5A),
the Racking Shutter would not Fully Close
01/25/2021
22-28575
Indication Lights were Burnt Out on X4103F130
08/08/2022
22-28576
POS 2A Was Illuminated However it Was Very Dim
08/09/2022
22-28577
X41K003B TCE Flashing Low Battery
08/09/2022
22-28616
2022 NRC DBAI Inspection (NRC Identified): 72F Position
5B Racked out with no Tag Nearby
08/10/2022
22-28627
08/10/2022
22-28664
Previous Fermi Evaluation of OE in Regard to Potential for
Tornado
08/11/2022
22-28687
2022 DBAI Inspection -Revise Procedure 43.401.515 "RCIC
Pressure Isolation Valve Test"
08/12/2022
22-28738
IOD Not Supported
08/15/2022
22-28763
Evaluate EDG Crankcase Trips
08/16/2022
22-28800
Evaluate EDG Essential Trips
08/17/2022
Corrective Action
Documents
Resulting from
Inspection
22-28801
2022 DBAI Inspection: 3071-128-EZ-01 Discrepancy
08/17/2022
260/130V ESS Dual Battery 2PA Distribution - Division 1
Schematic Diagram/Wiring Diagram, 1500 KVA Regulator
Bus 72F R1400S021B
0
Drawings
M-5734
Emergency Diesel Generator - Functional Operating Sketch
BL
37362
RHR and Core Spray Strong Pump/Weak Pump Interaction
B
70130
Replacement of EDG 14 Fuel Oil Transfer Pump Flowmeter
R30R411D
0
80122
Update Design Specification 3071-012 -Valves with Anti-
Rotation Key Repair or Upgrade Guidance for Safety
Related Powell Globe Valves
0
80122.001
Guidance for Safety Related Powell Globe Valve Anti-
Rotation Key Repair or Upgrade
0
80127
ECCS Pump CST Vortex Suppression Device
C
Engineering
Changes
80142
Replacement of Residual Heat Removal Service Water
(RHRSW) Valve E1150F068A
0
13
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Evaluations20-001
ISI/NDE-IST Program Evaluation
0
3071-019
Design Specification - RHR Complex
E
3071-517
Design Specification - RHR Complex
E
DBD R32-00
DC Electrical System Design Basis Document
B
FAI/20-0183
Testing Results CST Vortex Suppressors
2
Fairbanks Morse
Letter, Response
to FQ13-46
Postulated Tornado Crankcase Pressure Trip
11/17/2016
LCR 20-025-ISI
TSR-38230 changed the Pressure Isolation Boundary in the
06/29/2020
MES54001
0
MES54001
EDG 13 Jacket Coolant Hx
0
MES54001
0
R30-00
DBD for Emergency Diesel Generator
I
TMPE-02-0342
Evaluation of Increased Ambient Temperature in the RHR
Complex
12/13/2002
TSR-38268
Technical Service Request, Thermal Recombiner System
Abandonment per License Amendment 159
0
VME 11-2
C&D 3Phase, 6 Pulse SCR Float Chargers
09/05/2007
VME 5-12
Main DC Fuse Cabinets
0
VME 8-1.1
Vendor Manual Emergency Diesel Generators
VMS22-1.3
2 Stage Vertical Pump Instruction Manual
0
X41-03
DBD for Residual Heat Removal Complex Heating and
Ventilating System
B
Miscellaneous
XXX-02
DBD for Design Basis Event Combinations
A
23.307
Emergency Diesel Generator System
135
23.324.01
Operation of CTG 11-1 from CTG 11 Peaker Yard
4
23.324.05
Supervisory Control- Standby Diesel Operation
3
24.307.001
Emergency Diesel Generators - Inspection and Preventive
Maintenance
86
Procedures
24.307.12
Emergency Diesel Generator 13 - ECCS Start Test and
Logic Functional Tests of Bus 65E Breakers
48
14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
24.307.16
Emergency Diesel Generator 13 - Start and Load Test
61
24.307.37
DGSW, DFOT and Starting Air Operability Test - EDG 14
63
35.205.011
E1150F068A(B) Globe Valve Maintenance
0
74.000.18
Chemistry Shift, 72 Hour, and Situation Surveillances
60
ARP 1D73
RCIC Pump Suction Pressure High/Low
14
MLS04
Operating Experience Program
36
37526767
REPLACE FRN-R-400 FUSE PER ERE 45322 AT
R3200SO07A (2A-1 BATT')
10/22/2013
37526832
REPLACE FRN-R-400 FUSE PER ERE 45322 AT
R3200SO07B (2A-2 BATT)
10/22/2013
44152012
Perform 24.206.02 SEC-5.2 RCIC Valve Position Indication
Verification/Manual Initiate
04/16/2017
46456433
Perform 5-Year verification of time critical actions
08/30/2017
47548189
Final 43.401.515 RCIC Pressure Isolation Valve Leakage
(Test-2:E5150F012)
04/19/2020
48650178
Perform 42.309.04 Div 1 Battery Charger Load Test -2A-2
Only
09/10/2019
48778616
Remove/Reinstall Actuator in Support of WO 48774938
10/02/2017
50084239
Perform 24.206.01 RCIC System Pump Operability and
Valve Test at 1000PSIG
08/17/2019
50917153
Perform 24.206.01 RCIC System Pump Operability and
Valve Test at 1000PSIG
11/08/2019
51561321
Perform 42.309.04 Div 1 Battery Charger Load Test - 2A-1
Only
09/10/2020
51745473
Perform 24.206.01 RCIC System Pump Operability and
Valve Test at 1000PSIG
02/04/2020
52178219
Perform 24.206.02 Sec-5.2 RCIC Valve Position Indication
Verification/Manual Initiate
07/20/2020
52866184
Perform 42.309.04 Div 1 Battery Charger Load Test - 2A1-2
Only
09/08/2020
53719849
Partial 24.205.05, PMT Strokes for E1150F068A
04/17/2019
54453528
Perform 42.309.04 Div 1 Battery Charger Load Test - 2A-2
Only
05/10/2021
Work Orders
54529464
Perform 24.205.05 Partial for E1150F068A
07/16/2019
15
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
54768485
Perform 24.205.05 Division 1 RHRSW Pump and Valve
Operability
01/13/2021
54796258
Replace RHRSW Pump A
01/16/2020
57114597
Perform 42.309.04 Div 1 Battery Charger Load Test - 2A-1
Only
06/01/2021
57242836
Perform 42.309.06 DIV 2 18 Month 130/260 VDC Battery
Check (2B-2 Only)
04/09/2022
57243522
Perform 42.309.06 DIV 2 18 Month 130/260 VDC Battery
Check (2B-1 Only)
04/08/2022
58276397
Perform 24.205.05 Division 1 RHRSW Pump and Valve
Operability
01/10/2022
59933741
Perform Partial 24.205.05 to Stroke Test E1150F068A
01/12/2021
60290633
Perform 24.205.05 Division 1 RHRSW Pump and Valve
Operability
07/12/2022
64803407
Perform 24.205.05 Division 1 RHRSW Pump and Valve
Operability
03/24/2022