ML23039A155
| ML23039A155 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/14/2023 |
| From: | Billy Dickson NRC/RGN-III/DORS/RPB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2022004 | |
| Download: ML23039A155 (1) | |
See also: IR 05000341/2022004
Text
February 14, 2023
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-INTEGRATED INSPECTION REPORT
Dear Peter Dietrich:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Fermi Power Plant, Unit 2. On January 25, 2023, 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.
Five findings of very low safety significance (Green) are documented in this report. Three of
these findings involved violations of NRC requirements. We are treating these violations as
non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector
at Fermi Power Plant, Unit 2.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant,
Unit 2.
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,
Signed by Dickson, Billy
on 02/14/23
Billy C. Dickson, Jr., Chief
Reactor Projects Branch 2
Division of Operating Reactor Safety
Docket No. 05000341
License No. NPF43
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RIII RIII
NAME RNg:mb BDickson
DATE 02/10/2023 02/14/2023
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000341
License Number: NPF-43
Report Number: 05000341/2022004
Enterprise Identifier: I2022004-0042
Licensee: DTE Electric Company
Facility: Fermi Power Plant, Unit 2
Location: Newport, MI
Inspection Dates: October 01, 2022 to December 31, 2022
Inspectors: T. Briley, Senior Project Engineer
R. Edwards, Branch Chief
J. Gewargis, Resident Inspector
G. Hansen, Senior Emergency Preparedness Inspector
T. Iskierka-Boggs, Senior Operations Engineer
M. Jones, Emergency Response Coordinator
J. Kutlesa, Emergency Preparedness Inspector
R. Ng, Senior Project Engineer
T. Taylor, Senior Resident Inspector
Approved By: Billy C. Dickson, Jr., Chief
Reactor Projects Branch 2
Division of Operating Reactor Safety
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.
List of Findings and Violations
Failure to Monitor Moderate Energy Line Break Flood Barriers
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [P.2] - 71111.06
Systems NCV 05000341/202200401 Evaluation
Open/Closed
The inspectors identified a Green finding and associated Non-cited violation (NCV) of
10 CFR 50, appendix B, criterion III, Design Control, when the licensee failed to validate the
design of certain internal flood barriers protecting safety-related equipment. Specifically, the
inspectors identified degraded and missing spray shields designed to protect safety-related
equipment from the effects of moderate energy line breaks (MELBs).
Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate
Heat Sink) Roof
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.12] - Avoid 71111.07T
Systems FIN 05000341/202200402 Complacency
Open/Closed
The inspectors identified a finding of very low safety significance for the licensee's failure to
document housekeeping findings and initiate a condition assessment resolution document
(CARD) for discrepancies on the residual heat removal (RHR) complex roof in accordance
with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified
miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags,
moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented
by the licensee despite multiple individuals touring the area.
Vendor Oversight Issues During RF20 Torus Recoat Project
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.5] - Work 71152A
Systems FIN 05000341/202200403 Management
Open/Closed
The NRC identified a Green finding associated with vendor oversight of the 2020 torus recoat
project when unexpected degradation of the coating prompted a review that determined
control of supplemental personnel during the 2020 outage was inadequate.
2
Some Industry Standards Not Incorporated into Torus Recoat Procedures
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.11] - 71152A
Systems NCV 05000341/202200404 Challenge the
Open/Closed Unknown
A Green finding with an associated Non-cited violation (NCV) of 10 CFR 50 appendix B,
criterion V, "Instructions, Procedures, and Drawings," was self-revealed while inspecting the
torus during the RF21 refueling outage (spring 2022). Some areas of degradation were
observed that were unexpected given the torus had been recoated during the previous
refueling outage. Upon further review, the licensee identifies that some applicable industry
standards had been omitted from the torus recoat procedures, and certain portions of the
work instructions were not followed.
Failure to Perform a Required Code Evaluations for Standby Liquid Control System Leakage
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.12] - Avoid 71152A
Systems NCV 05000341/202200405 Complacency
Open/Closed
The inspectors identified a Green finding with an associated Non-cited violation (NCV) of
10 CFR 50.55a, "Codes and Standards," for the licensees failure to follow the ASME Code
after discovering boric acid leakage in the standby liquid control system (SLC). Specifically, a
code required evaluation was not performed as an alternative to corrective actions.
Additional Tracking Items
Type Issue Number Title Report Section Status
URI 05000341/202200303 Seismic Displacement for 71111.18 Closed
Safety-Related Piping Not
Verified
LER 05000341/2021002-00 LER 2021002-00 for Fermi 71153 Closed
2 Power Plant, Unplanned
Inoperability of High
Pressure Coolant Injection
System Due to an Inverter
Circuit Failure
LER 05000341/2021002-01 LER 2021002-01 for Fermi 71153 Closed
Power Plant, Unit 2,
Unplanned Inoperability of
High Pressure Coolant
Injection System Due to an
Inverter Circuit Failure
LER 05000341/2021001-00 LER 2021001-00 for Fermi, 71153 Closed
Unit 2, Unrecognized Impact
of Opening of Barrier Doors
on High Energy Line Break
Analysis
LER 05000341/2022003-00 LER 2022003-00 for Fermi 71153 Closed
2 Power Plant, Turbine Trip
3
and Subsequent Reactor
Trip Due to Mayflies
LER 05000341/2022001-00 LER 2022001-00 for Fermi 71153 Closed
2 Power Plant, Reactor
Scram on Low Reactor
Pressure Vessel Level
4
PLANT STATUS
Fermi Unit 2 started the inspection period at or near 100 percent power, and remained there for
the quarter.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
appendix D, Plant Status, observed risk significant activities, and completed onsite portions of
IPs. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel to assess licensee performance and compliance with Commission rules
and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to
the onset of seasonal cold temperatures for the following systems:
General service water, circulating water, and residual heat removal service water
(RHRSW) for the week ending on November 18, 2022
External Flooding Sample (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures,
and equipment are consistent with the licensees design requirements and risk
analysis assumptions for coping with external flooding for the week ending on
November 4, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Division 1 emergency equipment cooling water (EECW) with division 2 EECW TCV
maintenance during the week ending October 21, 2022
(2) Division 1 non-interruptible air system (NIAS) during division 2 control center heating,
ventilation, and air conditioning (CCHVAC) safety system outage during the week
ending October 21, 2022
5
(3) Division 1 130/260 engineered safety feature direct current (DC) power and battery
system during the week ending October 29, 2022
(4) Electric fire pump while the alternate diesel fire pump was out of service on
November 9, 2022
(5) Division 2 residual heat removal (RHR) drywell spray with work on division 1 during
the week ending November 26, 2022
(6) Division 1 RHRSW with the division 2 RHR pump and valve surveillance during the
week ending November 25, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
division 2 core spray system during the week ending on November 4, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) Southwest quadrant of the reactor building basement and sub-basement during the
week ending October 21, 2022
(2) Northwest quadrant of the reactor building basement and sub-basement during the
week ending November 18, 2022
(3) Reactor core isolation cooling quad sprinkler question during the week ending
December 10, 2022
(4) Reactor building 3 and reactor building 4 standby liquid control area during the week
ending December 12, 2022
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the following:
(1) Auxiliary building third and fourth levels, completed the week ending
December 31, 2022
71111.07T - Heat Exchanger/Sink Performance
Heat Exchanger (Service Water Cooled) (IP Section 03.02) (1 Sample)
The inspectors evaluated heat exchanger performance on the following:
(1) P4400B001B, EECW division 2 plate and frame heat exchanger
Heat Exchanger (Closed Loop) (IP Section 03.03) (1 Sample)
The inspectors evaluated heat exchanger performance on the following:
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(1) P5002B004, control air compressor (CAC) after cooler - north non-interruptible
control air (NIAS)
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
The inspectors evaluated the ultimate heat sink performance on the following:
(1) The ultimate heat sink, specifically sections 03.04.a and 03.04.e were completed.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1) The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating tests administered between
October 11, 2022 and November 10, 2022.
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 a planned high pressure coolant injection system surveillance that
resulted in a yellow risk condition, with complications regarding the performance of
two valves in the system, on November 15, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
(1) The inspectors observed and evaluated performance of an annual operating test in
the control room simulator on October 26, 2022.
(2) The inspectors observed and evaluated licensed operator requalification training for
technical specifications and emergency action level entry, and simulator exercise
scenarios in the main control room simulator during the week ending
November 18, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1) 4160V electrical switchgear
(2) Power supply inverters for safety-related instrumentation and control loads
(3) Review of issues associated with the transversing incore probe system, completed
the week ending December 24, 2022
7
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Troubleshooting and electric shock associated with the reactor water cleanup system
during the week ending November 12, 2022
(2) Gland seal exhaust motor replacement on November 02, 2022
(3) Mechanical draft cooling tower fan 'B' maintenance November 28, 2022
(4) Approach to a leaking sensing line for reactor feed pump suction pressure, completed
the week of December 31, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Abnormal noise from the 'B' mechanical draft cooling tower motor during the week
ending December 3, 2022
(2) Recirculation pump seal pressure changes during the week ending
December 10, 2022
71111.18 - Plant Modifications
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
(1) The inspectors verified the site SAMG were updated in accordance with the BWR
generic severe accident technical guidelines and validated in accordance with NEI
1401, Emergency Response Procedures and Guidelines for Beyond Design Basis
Events and Severe Accidents, Revision 1.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1) Division 1 CCHVAC outage during the week of October 3, 2022
(2) Division 1 NIAS during the week ending November 4, 2022
(3) Diesel fire pump post installation testing, completed during the week ending
December 23, 2022
8
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system
operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (4 Samples)
(1) Electrical bus 64B undervoltage testing and relay calibrations during the week ending
October 8, 2022
(2) HPCI pump and valve surveillance after pressure control valve repair and outboard
main steam isolation valve packing adjustment on December 1, 2022
(3) EECW pump and valve during the week ending December 14, 2022
(4) Validation of acceptable level bands for oil and tank levels on select motors and
tanks, completed the week ending December 24, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
(1) EDG 11 SW pump and minimum flow valve testing during the week ending
October 21, 2022
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1) RCS leakage increasing trend during the week ending October 29, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
(1) Dominator and Neptune pump run surveillances, completed by the week ending
December 31, 2022
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.0102.03) (1 Sample)
(1) The inspectors evaluated the following submitted Emergency Action Level and
Emergency Plan changes:
202108E, Spent fuel pool level updates for RA2.3, RS2.1, and RG2.1,
September 21, 2021
202135S, Spent fuel pool level updates for RA2.3, RS2.1, and RG2.1,
September 21, 2021
This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
(1) The inspectors evaluated drill and exercise performance indicator opportunities
associated with a licensed-operator requalification activity on October 26, 2022.
9
OTHER ACTIVITIES-BASELINE
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Ongoing issues with effluent sampling systems and potential impacts to declaring
emergency action levels, the week ending December 10, 2022
(2) Select review of degraded/non-conforming conditions carried by the licensee,
completed the week of December 31, 2022
(3) Review of 2020 torus recoat project following degradation identified in 2022,
completed the week of December 31, 2022
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1) The inspectors reviewed the licensees corrective action program for potential
adverse trends that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (4 Samples)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 05000341/2021001, Unrecognized Impact of Opening of Barrier Doors on High
Energy Line Break Analysis (ADAMS Accession No. ML21182A291). The inspection
conclusions associated with this LER are documented in Inspection
Report 05000341/2021003 under Inspection Results section 71111.15 (ADAMS
Accession No. ML21298A200). An analysis to assess the potential impacts on
components outside the reactor building steam tunnel (RBST) during a line break in
the RBST does not exist. Current analyses assume the door is shut. Subsequent to
NRC identification of the issue in 2021, the licensee took steps to conduct an analysis
on effects outside the RBST. This effort was not completed. As a result, the
inspectors cannot validate the accuracy of several of the 10 CFR 50.73 reporting
criteria, such as loss of safety functions and conditions prohibited by technical
specifications (TS). While the licensee did report under those criteria (assuming a
worst case scenario where all equipment required to respond to a line break in the
RBST was inoperable due to the break), without an analysis on the environmental
impacts outside the RBST, it is impossible to assess whether or not these criteria
were actually met. Despite that, the licensee did report under criteria for an
unanalyzed condition and a condition prohibited by TS 3.0.3 specifically. The
inspectors determined it was appropriate to report under those criteria given the lack
of analysis and multiple types and trains of equipment that may have been impacted
to the point where operability was brought into question. The non-cited violation
associated with this issue screened as very low safety significance given the small
amount of time the door had been open in the past 3 years. The licensee instituted
10
corrective actions to better recognize and control important doors throughout the
plant. No further findings nor violations were identified.
(2) LER 05000341/2021002-00 and 05000341/2021002-01, Unplanned Inoperability of
High Pressure Coolant Injection System Due to an Inverter Circuit Failure (ADAMS
Accession Nos. ML22075A087). The inspectors determined that it was not
reasonable to foresee or correct the cause discussed in the LER therefore no
performance deficiency was identified. The inspectors did not identify a violation of
NRC requirements. The inspectors reviewed the previous, as well as the updated
LER submittal.
(3) LER 05000341/2022001, Reactor Scram on Low Reactor Pressure Vessel Level
(ADAMS Accession No. ML22094A155). The inspection conclusions associated with
this LER are documented in Inspection Report 0500341/2022003 under Inspection
Results section 71152A. No further findings or violations were identified.
(4) LER 05000341/2022003, Turbine Trip and Subsequent Reactor Trip due to Mayflies
(ADAMS Accession No. ML22235A106). The inspection conclusions associated with
this LER are documented in Inspection Report 0500341/2022003 (ADAMS Accession
No. ML22311A531) under Inspection Results section 71152A. No findings nor
violations were identified.
OTHER ACTIVITIES-TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855 - Operation of an ISFSI
The inspectors evaluated the licensees activities related to the long-term operation and
monitoring of its Independent Spent Fuel Storage Installation (ISFSI). The inspectors reviewed
relevant documentation remotely during the weeks of October 10 and October 17, 2022, and
were onsite on October 19, 2022. During the onsite walkdown, the inspector toured the ISFSI
and evaluated the material and radiological conditions of the ISFSI pad and loaded HISTORM
100 systems. The inspectors verified radiological conditions on the ISFSI pad were as expected
during the walkdown. The inspectors interviewed licensee staff regarding periodic surveillances
of the loaded HISTORM casks.
Since the last inspection, the inspectors evaluated corrective action documents and changes
performed in accordance with 10 CFR 72.48, "Changes, Tests, and Experiments."
INSPECTION RESULTS
Failure to Monitor Moderate Energy Line Break Flood Barriers
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [P.2] - 71111.06
Systems NCV 05000341/202200401 Evaluation
Open/Closed
The inspectors identified a Green finding and associated Non-cited violation (NCV) of
10 CFR 50, appendix B, criterion III, Design Control, when the licensee failed to validate the
design of certain internal flood barriers protecting safety-related equipment. Specifically, the
11
inspectors identified degraded and missing spray shields designed to protect safety-related
equipment from the effects of moderate energy line breaks (MELBs).
Description:
On November 29, 2022, the inspectors performed a walkdown of the third floor and fourth
floor of the auxiliary building (AB) as part of an internal flooding inspection sample. During the
walkdown, the inspectors discovered that the MELB spray shields in the division 2 switchgear
room and AB fourth floor were degraded or missing from sections of emergency equipment
cooling water (EECW) piping. The spray shield design consists of a fiberglass-impregnated
material that encloses susceptible piping to contain and divert water away from safety-related
equipment, namely electrical switchgear. The inspectors questioned the potential effects of
the degraded/missing spray shields on nearby equipment. In response, the licensee
performed technical evaluations that concluded that safety-related equipment remained
operable in the current condition but not in accordance with the design.
A subsequent review by the licensee revealed that a condition assessment resolution
document (CARD) had been written in 2020 documenting the degraded spray shields in the
division 2 switchgear room, consistent with what was identified on the NRC walkdown almost
3 years later. While the licensee had generated a work order to fix the shields, it was still in a
delay status, and no monitoring plan was in place to ensure the barrier could still fulfill its
design functions (e.g., following work in the area or periodic checks of the tape holding the
barrier in place at some locations). The licensee found no evidence for other piping sections
that the missing shields had been identified or documented by the licensee. Through
discussion with the inspectors, the licensee determined that the work activity to inspect spray
shields throughout the plant had not been performed when last scheduled in July 2019.
During the extent of condition walkdowns following NRC's discovery of the issue, further
degraded spray shields were identified; however, most were determined not be a part of the
internal flooding design basis anymore. The licensee evaluated the others to ensure no
impacts to safety-related equipment existed.
Corrective Actions: The licensee completed a technical evaluation to support the operability
of the division 2 switchgear and confirmed other areas of missing/degraded spray shields did
not constitute a deviation from design nor have adverse impacts on nearby equipment as part
of their extent of condition walkdowns. In response to the inspectors' questions, the licensee
also started a review to determine if they properly administrated the periodic inspection
activity to validate the flood barrier design.
Corrective Action References: CARDs 2231414, 2020846, 2231541, 2231415, and
2231571.
Performance Assessment:
Performance Deficiency: The inspectors determined the licensee failed to perform a
scheduled verification of flooding barriers. Additionally, deviations from MELB protection
features were not controlled due to inspector identification of missing/degraded spray shields
on EECW piping that had not been identified by the licensee nor properly monitored.
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
12
consequences. Specifically, degraded MELB barriers had not been identified, monitored,
and/or properly assessed that could impact nearby safety-related equipment.
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 to Green (very low safety significance) because questions 2
through 6 on exhibit 2 of the mitigating systems screening were answered as No.
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, when degraded MELB barriers were identified, the licensee
failed to ensure appropriate technical assessments were performed, that effective monitoring
was in place, and an extent of condition was performed to identify other issues.
Enforcement:
Violation: 10 CFR 50, appendix B, criterion III, "Design Control," states, in part, that measures
established shall include provisions to assure that appropriate quality standards are specified
and included in design documents and that deviations from such standards are controlled.
Contrary to the above, from January 24, 2020 to January 9, 2023, the licensee failed to
assure that deviations from quality standards were controlled. Specifically, the licensee failed
to complete a scheduled inspection of flood barriers. Further, the licensee did not perform a
technical assessment nor monitoring to support shroud functionality once degradation was
identified.
Enforcement Action: This violation is being treated as a NCV, consistent with section 2.3.2 of
the Enforcement Policy.
Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate
Heat Sink) Roof
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.12] - Avoid 71111.07T
Systems FIN 05000341/202200402 Complacency
Open/Closed
The inspectors identified a finding of very low safety significance for the licensee's failure to
document housekeeping findings and initiate a condition assessment resolution document
(CARD) for discrepancies on the residual heat removal (RHR) complex roof in accordance
with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified
miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags,
moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented
by the licensee despite multiple individuals touring the area.
Description:
On October 18, 2022, the inspectors performed a walkdown of the residual heat removal
complex roof. The inspectors noted that the lower roof contained miscellaneous debris in the
form of food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps,
small plastic pieces, and paint chips. The inspectors also noted that one of the large plastic
storage bins containing ice melt material had been lined with a plastic bag and turned into a
makeshift trash can. The identified debris was generally in the vicinity of roof drains and/or
grating that led to or was directly over the division 1 and division 2 ultimate heat sink water
reservoirs used to transfer heat from structures, systems, and components important to
13
safety. Natural phenomena (such as rainfall or wind gusts) could potentially transport the
debris into the reservoirs and potentially challenge pump operation for residual heat removal
service water, emergency equipment service water, and/or emergency diesel generator
service water. Periodic diving inspection records from 2020 and 2022 also indicated the
presence of miscellaneous debris such as plastic signage, moss clumps, and ear plugs
located under water in the reservoirs (debris was documented as removed by the divers upon
discovery).
The personnel doors used to access the RHR complex roof indicated the area was a
"housekeeping category."
Licensee procedure MOP 21, "Housekeeping," Revision 7, contains procedural guidance for
ensuring adequate levels of housekeeping to ensure safe plant operation and included all
activities related to controlling material in all areas of the facility. The procedure also stated, in
part, that individuals are expected to maintain the same level of housekeeping inside and out
of the power block. Procedure step 2.3.9 stated, in part, that persons performing a plant tour
shall 1) document findings on the housekeeping inspection report form and 2) initiate a
condition assessment resolution document (condition report) for discrepancies when
required.
The debris identified by the inspectors had not been documented as a housekeeping finding
nor entered into the corrective action program via a condition assessment resolution
document until brought to the licensee's attention. It is unknown how long the miscellaneous
debris was present on the residual heat removal complex roof, however, the inspectors
determined that some of the miscellaneous debris had most likely been on the roof for an
extended period of time based on environmental degradation.
Corrective Actions: The miscellaneous debris was subsequently removed from the residual
heat removal complex roof and a follow-up investigation into the cause(s) was planned.
Corrective Action References: CARD 2230462
Performance Assessment:
Performance Deficiency: The licensee's failure to document housekeeping findings and
initiate a CARD for discrepancies on the RHR complex roof in accordance with licensee
procedure MOP 21, "Housekeeping," was a performance deficiency. Specifically, the
inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill
rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had
not been documented by the licensee despite multiple individuals touring the area.
Screening: The inspectors determined the performance deficiency was more than minor
because if left uncorrected, it would have the potential to lead to a more significant safety
concern. Specifically, debris on the residual heat removal complex roof can be washed or
blown directly into the ultimate heat sink reservoirs and could potentially impact safety-related
residual heat removal, emergency equipment, and emergency diesel generator service water
systems. The inspectors also noted previous dive inspection records in both 2020 and 2022
of the ultimate heat sink reservoirs housed in the residual heat removal complex contained
debris found such as plastic signage and bags, paint chips, and ear plugs to name a few
(items were retrieved during periodic diving activities).
14
Significance: The inspectors assessed the significance of the finding using IMC 0609
appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the mitigating systems screening questions for structures, systems, and
components and probabilistic risk analysis functionality were all answered no. Therefore, the
finding screened as of very low safety significance (Green).
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the
possibility of mistakes, latent issues, and inherent risk, even while expecting successful
outcomes. Individuals implement appropriate error reduction tools. Specifically, multiple
individuals from multiple organizations routinely traversed the RHR complex roof and
appeared to not consider the potential undesired consequences of their actions in leaving
miscellaneous debris on the roof, verify housekeeping procedure prerequisites despite being
prompted by the access door signs stating "housekeeping category," nor performed a
thorough review of the area every time work was performed (such as operator rounds) rather
than relying on past successes and assumed conditions.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
URI Seismic Displacement for Safety-Related Piping Not 71111.18
Verified
URI 05000341/202200303
Description:
During the fourth quarter of 2022, the licensee provided additional information from a design
basis calculation of record associated with the division 1 residual heat removal service water
(RHRSW) supply and return piping inside the reactor building. Calculation No. DC6953,
"Emergency Equipment Cooling Water System Subsystem: EX15," Revision 0 provides the
design basis and licensing basis information associated with the seismic and thermal
displacements of the piping and determination of whether the maximum piping displacement
impacts any systems, structures, or components (SSCs).
The licensee provided the piping displacement information from Calculation No. DC6953 to
demonstrate that the RHRSW piping will not impact any SSCs. The inspector reviewed this
information and concluded this issue is closed. No performance deficiencies or findings were
identified.
Corrective Action Reference(s): condition assessment resolution document 2227033,
NRC Identified: Evaluation of Potential Rattle Space Violation, dated 06/10/2022.
Vendor Oversight Issues during RF20 Torus Recoat Project
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.5] - Work 71152A
Systems FIN 05000341/202200403 Management
Open/Closed
The NRC identified a Green finding associated with vendor oversight of the 2020 torus recoat
project when unexpected degradation of the coating prompted a review that determined
control of supplemental personnel during the 2020 outage was inadequate.
15
Description:
The unexpected torus coating degradation discovered during the 2022 refueling outage
prompted an investigation by the licensee into the operability of the torus and the potential
causes of the degradation. Non-cited violation (NCV) 05000341/202200404, documented in
this inspection report, describes the issues with the work instructions associated with the
2020 torus project. Further investigation by the licensee as a result of NRC questions
prompted a condition assessment resolution document (CARD) 2227942 to be written to
explore the extent of work control/process gaps that may have existed for the torus project.
An organizational effectiveness evaluation determined that supplemental personnel assigned
to the torus project failed to follow site processes regarding procedure use and adherence.
One of the potential causes for the degradation of the new torus coating was the lack of tarps
to protect uncoated areas from the spraying of coating in nearby areas. Despite the work
instructions calling for tarps, they were not used. A review of the work instructions later
revealed steps were inappropriately marked as complete or not applicable (N/A)
inappropriately.
Besides evaluating the extent of the condition of the failure to follow site processes for
execution of the torus work instructions, CARD 2227942 sought to identify the causes of the
issues. NRC review of this CARD revealed that the licensee correctly identified several
instances of contractors not following site processes. Examples included how to mark steps
as complete, how to use a 'N/A,' and when and by whom steps should be marked off. As a
result, the inspectors determined supplemental personnel control associated with the torus
recoat project was inadequate. CARD 2227942 identified a potential reason:
a new-tonuclear, non-proficient worker had been selected to ensure steps for the torus
project were complete and marked appropriately. While the licensee's CARD stated it was
contractor supervision who placed the worker in that position, the inspectors noted site
procedure MGA31 had requirements for licensee personnel: such as ensuring contractors
had specific training assigned based on needs.
Additionally, the procedure requires updated information to be communicated to the
contractors with sufficient time so that they can acquaint workers with the new information (an
apparent decision not to use tarps was made but not conveyed to the individual signing for
steps in the work instructions). Step 5.4.7 requires observations of work activities to check
adherence to station policies and procedures. Step 5.4.1 requires vendor oversight plans to
be developed. The licensee's evaluation in CARD 2227942 did not explore if there were
shortfalls with the last two requirements on behalf of licensee personnel. If observations and
oversight plans were, in fact, part of the project, they were ineffective at detecting the gaps in
contractor performance.
Corrective Actions: The licensee entered the issue into the corrective action program.
Corrective Action References: CARD 2227942
Performance Assessment:
Performance Deficiency: Contrary to requirements in MGA31, Supplemental Personnel
Control Practice, the licensee did not provide adequate oversight of supplemental workers
associated with the 2020 torus recoat project.
16
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Human Performance attribute of the Mitigating Systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, inadequate supplemental worker oversight partly contributed to
degraded conditions in the torus. The issue also screened as more than minor under the
barrier integrity cornerstone, as the torus forms part of the primary containment barrier.
Significance: The inspectors assessed the significance of the finding using IMC 0609
appendix A, The Significance Determination Process (SDP) for Findings At-Power. The end
result of the performance deficiency was a questioning of the operability of the torus given the
degradation that occurred. Under the mitigating systems cornerstone, questions 26 in
section A of exhibit 2 were answered 'no.' Further, under the barrier integrity cornerstone,
questions 12 under section C of exhibit 3 were also answered 'no.'
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of
planning, controlling, and executing work activities such that nuclear safety is the overriding
priority. The work process includes the identification and management of risk commensurate
to the work and the need for coordination with different groups or job activities. Following the
2020 and 2022 refueling outages, after-action reviews and input from external stakeholders
revealed weaknesses in the outage planning and preparation process that drove poor outage
performance, to include planning for and managing contract work onsite.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Some Industry Standards Not Incorporated into Torus Recoat Procedures
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.11] - 71152A
Systems NCV 05000341/202200404 Challenge the
Open/Closed Unknown
A Green finding with an associated Non-cited violation (NCV) of 10 CFR 50 appendix B,
criterion V, "Instructions, Procedures, and Drawings," was self-revealed while inspecting the
torus during the RF21 refueling outage (spring 2022). Some areas of degradation were
observed that were unexpected given the torus had been recoated during the previous
refueling outage. Upon further review, the licensee identified that some applicable industry
standards had been omitted from the torus recoat procedures, and certain portions of the
work instructions were not followed.
Description:
During the spring 2022 refueling outage, RF21, the inspectors opened an indepth PI&R
sample to review the effectiveness of corrective actions taken during the prior outage (spring
2020) regarding the recoating of the inside of the torus. The inspection sample involved
degradation, which developed before 2020, and the licensee's inadequate tracking and
assessment of that degradation over time, was the subject of an NRC special inspection in
2019. The results of the special inspection are documented in inspection
report 05000341/2019050 (ML20031D253). A confirmatory action letter also resulted from the
special inspection, which prompted the entire recoating of the torus in 2020.
Following the identification of the degradation, the licensee worked with various vendors and
17
consultants to assess the impact on the torus's operability and to determine a cause.
Degradation ranged from small areas of rust deposits to small bubbles that appeared on the
surface. The areas in question were spread throughout the torus in discrete locations. The
licensee concluded the total degraded area was far below that which would call into question
the operability of the torus. This conclusion was supported by a series of 'pull-tests,' which
validated that areas surrounding the pockets of degradation had sound, tightly adhered
coating. Inspection by the onsite resident inspectors, region-based inspectors involved with
the 2019 special inspection, and experts from NRC headquarters did not find any issues with
the licensee's conclusion. The licensee developed several theories on how the degradation
originated and documented the conclusions in CARD 2222967 via an equipment cause
evaluation.
Essentially, the licensee concluded several factors likely led to the areas of degradation.
Ultimately, the licensee determined inadequate work instructions for the torus recoat project
were the cause because several of the contributing factors were not properly accounted for in
the work instructions. One example involved time elapsed between 'stripe coating' and
application of the main coating (stripe coating being areas 'cut-in' prior to the main spray of
coating). The licensee concluded that during the project, between 2.5 and 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> elapsed
between stripe coating and spraying in the various areas. During the licensee's investigation,
several industry references discovered pointed to a much shorter time (< 10 minutes) being
appropriate to prevent a phenomenon known as 'amine blush' from occurring, which can
affect coating adherence. As another example, testing for specific surface contaminants such
as chlorides was not directed by the work instructions. While certain industry standards
regarding surface preparation were followed, the fact the torus remained 'prepped' for coating
for an unexpectedly long period (due to COVID impacts) should have prompted a check for
contaminants that may not have otherwise been present had the torus been promptly coated.
In addition, the work instructions called for tarps to protect uncoated areas from the
'overspray' of other areas being coated. Steps for installation of the tarps were marked
complete; however, a later investigation by the licensee revealed the steps had not been
performed. It appears that as the project was progressing, the use of tarps was being
debated given a change in coating strategy that had occurred and the speed at which
activities were progressing. Per licensee processes, if a decision to not use tarps had been
made, the work instructions should have been updated accordingly. Areas not protected from
overspray may have led to some of the degradation noted.
Corrective Actions: The licensee performed tests to confirm the coating in general was
satisfactorily applied. Select areas were repaired, and evaluations were performed to verify
operability of the coating in the asfound and goforward conditions.
Corrective Action References: CARD 2222967 documented an equipment cause evaluation
and organizational effectiveness cause evaluation.
Performance Assessment:
Performance Deficiency: The implementing work instructions for the torus recoat project were
inadequate and certain portions were not followed.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Procedure Quality 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, unexpected degradation was noted on the interior torus coating
18
after one cycle of operation, calling into question the ability of the coating to remain intact
during accident conditions (which can impact the suctions of safety related pumps aligned to
the torus). The inspectors also determined the issue was more than minor under the barrier
integrity cornerstone, as inadequate coating can also impact the primary containment barrier.
Significance: The inspectors assessed the significance of the finding using IMC 0609
appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, under the mitigating systems cornerstone, questions 26 in section A of exhibit 2
were answered 'no.' Further, under the barrier integrity cornerstone, questions 12 under
section C of exhibit 3 were also answered 'no.'
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically,
the inspectors utilized the associated common language attribute (QA.2) from NUREG2165,
Safety Culture Common Language, to inform assignment of an appropriate cross-cutting
aspect. Applicable tenets of QA.2 include:
"Leaders reinforce expectations that individuals take time to do the job right the first
time, seek guidance when unsure, and stop if unexpected conditions are
encountered."
"Individuals maintain a questioning attitude during pre-job briefs and jobsite reviews to
identify and resolve unexpected conditions."
"Individuals stop work activities when confronted with an unexpected condition,
communicate with supervisors, and resolve the condition prior to continuing work..."
"If a procedure or work document is unclear or cannot be performed as written,
individuals stop work until the issue is resolved."
The dynamic nature of the COVID health emergency led to changing conditions (e.g., longer
period between surface preparation and coating) that presented opportunities to revalidate
appropriate standards and controls in the work instructions that may have prevented the
scope of degradation. Further, work was not stopped when the instructions could not be
performed as written when it was decided to not use tarps.
Besides the work instructions for the coating, the inspectors also broadened their review to
other work activities that were part of the torus project. The attributes of H.11/QA.2 were
lacking in several areas throughout the project. A worker was injured when others saw an
unsafe platform but did not stop the job before the injury. When workers in the torus
questioned the speed at which material was being hoisted out of the torus, workers above
told them multiple times that they would not slow down. In approaching the unknowns
associated with confined space rescue in a fully drained torus, the necessary practice and
coordination for such a complex activity was not provided prior to start of work. This missed
opportunity was only realized when the rescue team was called out for an injury after work
had started.
Enforcement:
Violation: 10 CFR 50 appendix B, criterion V, Instructions, Procedures, and Drawings,
requires, in part, that activities affecting quality shall be prescribed by documented
instructions of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions. Contrary to the above, during the spring 2020 refueling
19
Outage (March 2020-August 2020) and until discovery the following refueling outage (which
commenced in February 2022), the licensee did not prescribe documented instructions
appropriate to the circumstances, nor accomplish activities in accordance with appropriate
instructions, for activities affecting quality. Specifically, the instructions associated with
recoating the safety related torus lacked steps to help prevent degradation of the coating.
Further, some steps intended to protect the new coating were in the instructions but not
followed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Perform a Required Code Evaluations for Standby Liquid Control System Leakage
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.12] - Avoid 71152A
Systems NCV 05000341/202200405 Complacency
Open/Closed
The inspectors identified a Green finding with an associated Non-cited violation (NCV) of
10 CFR 50.55a, "Codes and Standards," for the licensees failure to follow the ASME Code
after discovering boric acid leakage in the standby liquid control system (SLC). Specifically, a
code required evaluation was not performed as an alternative to correction actions.
Description:
During a review of condition assessment resolution documents (CARDs) as part of the
indepth PI&R baseline inspection sample, the inspectors reviewed CARD 2230062, initiated
on October 2, 2022. This licensee-identified CARD described evidence of borated water
leakage from a flanged connection between the SLC system tank and heater C4101S002
during planned VT2 examinations. While no active leakage was noted, the CARD mentioned
that this was a repeat issue from CARD 1927781, initiated on October 11, 2019. While
reviewing 1927781, the inspectors noted that CARD 1826451 (created August 27, 2018)
had also documented the same borated water leak (however, this was not during a Code
VT2 exam). Per section XI of the 2013 ASME Code, specifically IWA5250 and IWA5251,
leaks of this nature require one of two primary activities to be accomplished following
identification. One option described in IWA5250 involves removing a bolt from the affected
connection and performing a VT3 exam with a subsequent evaluation of it and the remaining
bolts. Alternatively, a licensee could opt to replace all bolts. The other option, described in
IAW5251, involves the performance of an evaluation of the joint following IWA5251(c).
Corrective action for CARD 1826451 did not involve either code-required option. The
licensee generated a work order, but as of the issuance of 1927781 (a little over a year
later), the work order still needed to be prepared. After identifying the issue again in
1927781, the corrective action was to create a work order to accomplish the requirements of
IWA5250 during the RF20 refueling outage (spring of 2020). While the licensee provided
some facts supporting operability, they did not perform an evaluation involving the criteria
listed in IWA5251(c). During RF20, the licensee removed the work activity to do the repairs
and/or inspections to satisfy IWA5250. An evaluation per IWA5251 was also not completed
at that time.
20
NRC inspector review of the most recent CARD identifying the leakage (2230062) revealed
that despite the cancellation of the work order in RF20, the licensee did not put actions in
place to schedule the work during RF21, the spring 2022 refueling outage. In response to
NRC questions, the licensee generated CARD 2230116 to document that fact. After further
discussions with the NRC, the licensee completed an evaluation per IWA5251(c) in
December 2022. The inspectors reviewed the evaluation and noted that the licensee had also
identified a similar situation existed for another SLC system component. The licensee
identified a possible body-tobonnet leak on C4100F001, the SLC storage tank isolation
valve, on October 2, 2022. This leakage had also been identified previously in 2019, along
with the C4101S002 leakage, but did not have the appropriate action taken per IWA5251(c).
The inspectors reviewed the evaluation performed for both components and did not have an
issue with the licensee's conclusions that the components remained operable.
Corrective Actions: The licensee performed an evaluation per IWA5251(c) to demonstrate
operability of affected components.
Corrective Action References: CARDs 2230062, 2230061, and 2230116
Performance Assessment:
Performance Deficiency: Following discovery of borated water leakage from SLC system
components, the licensee did not perform the required actions set forth in the ASME Boiler
and Pressure Vessel Code, section XI, 2013 edition (the edition the licensee is committed to).
Specifically, the evaluation described in IWA5251(c) to demonstrate acceptable continued
operation after choosing to not perform the actions in IWA5250, was not performed.
Screening: The inspectors determined the performance deficiency was more than minor
because if left uncorrected, it would have the potential to lead to a more significant safety
concern. Specifically, continuing to not repair nor perform evaluations per the ASME Code for
degraded safety-related components could lead to further degradation where operability
could be a concern.
Significance: The inspectors assessed the significance of the finding using IMC 0609
appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, after reviewing the evaluation performed by the licensee, the inspectors
answered 'no' to all of the questions in section A of exhibit 2 regarding impacts to operability.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the
possibility of mistakes, latent issues, and inherent risk, even while expecting successful
outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee
deferred work on the degraded components but did not recognize until after the following
refueling outage an opportunity had been missed to perform the work. Additionally, specific
ASME Code requirements were not recognized despite multiple instances of identifying the
same evidence of borated water leakage.
Enforcement:
Violation: 10 CFR 50.55a, Codes and Standards, incorporates by reference the ASME Boiler
and Pressure Vessel Code, section XI, Rules for Inservice Inspection of Nuclear Power Plant
Components-Division 1, 2013 addenda. Section IWA5251 of the Code states, in part, that as
an alternative to corrective action under IWA5250 for leakage at bolted connections in
21
systems borated for the purposes of controlling reactivity, an evaluation incorporating the
criteria of IWA5251(c) can be performed to evaluate the consequences of continuing
operation. Contrary to the above, since identification of conditions covered by IWA5250/5251
on October 11, 2019, for safety-related SLC components C4101S002 and C4100F001, until
an evaluation was performed on December 13, 2022, the licensee did not complete
evaluations in accordance with the requirements of IWA5251(c).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Observation: Corrective Action Program Product Quality 71152S
The inspectors identified a potential negative trend in CAP execution and product quality. The
issues identified by the inspectors were discussed with licensee management in the
applicable departments, along with the performance improvement department. The licensee
recognizes the issue and, in addition to revising some of the products in question, has
created plans to improve and validate product quality. One example was the creation of a
monthly condition assessment resolution document (CARD) closure quality reviews to be
done by each department and NQA. Specific issues are listed below:
The inspectors reviewed the causal evaluation associated with the scram in June of
2022 caused by a swarm of mayflies. The evaluation indicated problems between
security and operations regarding working together to establish a plant lighting
strategy. Further, it identified one of the causes as not utilizing the "DTE Mayfly
Infestation Plan." There were also references to other site or departmental issues
unrelated to the event. After questioning the licensee for more contextual information,
the inspectors learned DTE never had an infestation plan until after the event
occurred. Also, there wasn't a problem of security and operations resolving
differences; rather, there was no discussion following the 2020 mayfly event to
explore what could be done regarding the lighting. The licensee revised the evaluation
to address those items and remove references to issues not relevant to the event.
The inspectors reviewed the root cause evaluation associated with the February 2022
scram caused by a feedwater transient. While not having an issue with the root cause
or proposed corrective actions, the inspectors uncovered more detail behind the
'legacy procedural issue' for securing a feed pump that appeared relevant to the
cause and could inform future modifications to the procedure. The inspectors
determined the legacy procedure issue stemmed from a specific procedure change in
2001 that changed how plant operators managed the feed pump speed and the
minimum flow control valve during the shutdown.
The inspectors reviewed the corrective action tools used to assess the actuator/yoke
separation of a primary containment isolation valve and determined the performance
gap analysis was too narrowly focused for the issue. Concurrently, site management
also identified the issue, and as a result, a more detailed organizational cause
evaluation was conducted.
The licensee NQA organization identified a trend in December 2022 which highlighted
several failed causal evaluation products. One particular product involved responding
to an NRC non-cited violation (NCV) regarding reporting requirements. The inspectors
noted that before the most recent NCV, another NCV in the same area from 2020 had
been documented, indicating difficulty in achieving sustainable corrective actions for
reportability issues.
22
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 25, 2023, the inspectors presented the integrated inspection results to
P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee
staff.
On November 4, 2022, the inspectors presented the ISFSI interim exit inspection results
to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee
staff.
On November 10, 2022, the inspectors presented the triennial heat sink inspection
results to B. Sullivan and other members of the licensee staff.
On December 1, 2022, the inspectors presented the emergency action level and
emergency plan changes inspection results to P. Dietrich, Senior VP and Chief Nuclear
Officer and other members of the licensee staff.
THIRD PARTY REVIEWS
Inspectors reviewed Institute on Nuclear Power Operations mid-cycle assessment reports that
were issued during the inspection period.
23
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
60855 Corrective Action 1924210 NQA - Holtec Field Condition Report 06/03/2019
Documents 2031838 ISFSI Helium Backfill Volume Calculation Uncertainty 11/02/2020
2130193 MOP11 Requires Revision for Combustible Material in ISFSI 11/16/2021
Building
Corrective Action 2230743 No Written Evaluation Performed per 10 CFR 72.212(b)(7) 10/31/2022
Documents
Resulting from
Inspection
Miscellaneous 10 CFR 72.212 Report 3
72.48 Screen EDP 80028 0
200003
72.48 Screen WO 57799481 0
200005
Procedures MRP04 Radiation Protection Conduct Manual 47
Radiation PM202106286 ISFSI Pad 06/28/2021
Surveys PM202111242 ISFSI Pad 11/24/2021
PM2022062912 ISFSI Pad 06/29/2022
PM202210079 ISFSI Pad 10/07/2022
Self-Assessments Audit Report ISFSI Program 05/16/2022
220103
Work Orders 49479374 HISTORM Annual Inspection 10/07/2019
52206872 Perform 35.710.055 HISTORM Monthly Screen Inspection 03/28/2020
52805754 HISTORM Annual Inspection 11/04/2020
56125177 Perform 35.710.055 HISTORM Monthly Screen Inspection 05/19/2021
57629881 HISTORM Annual Inspection 10/20/2021
57799481 Contingency ISFSI Haul Path 06/25/2020
58429284 Perform 35.710.055 HISTORM Monthly Screen Inspection 01/27/2022
71111.01 Corrective Action 2032050 2022 Seasonal Readiness-Cold Weather Preps Milestones 11/06/2020
Documents Tracking - Refuel Outage Dates
2230324 Request Drawing Update to Shore Barrier Drawings 10/12/2022
Following Yearly Survey
24
Inspection Type Designation Description or Title Revision or
Procedure Date
2230675 Alternate Diesel Fire Pump Enclosure Heater Not 10/27/2022
Functioning Correctly
2230812 Additional Information and Engineering Support Required to 11/02/2022
Troubleshoot U4100F171A
Corrective Action 2230305 NRC Identified-Bolt Missing from Pin on Door R18 10/11/2022
Documents
Resulting from
Inspection
Drawings 6A7212071 Reactor and Auxiliary Building Door Schedule and Types 09/06/2022
6M7215720 Circulating Water System Functional Operating Sketch 03/18/2022
6M7215726 General Service Water System Functional Operating Sketch 10/10/2018
Procedures 23.101 Circulating Water System 107
23.131 General Service Water System 114
23.208 RHR Complex Service Water Systems 134
35.000.242 Barrier Identification/Classification 62
MWC16100 Seasonal Readiness 2
71111.04 Corrective Action 0900177 Packing Leak: Div. 2 Core Spray Keep Fill Isolation Valve 01/05/2009
Documents Has 2 dpm Packing Leak
CARD 1821676 Division 2 Core Spray Fill Outlet Isolation Valve Swing Bolt 02/27/2018
Broken
Drawings 6M2712015 Diagram Station and Control Air 04/26/2022
6M2715706-3 RHR Service Water Make-Up Decant and Overflow Systems 03/15/2022
Functional Operating Sketch
6M7212034 Diagram Core Spray System C.S.S Reactor Building 04/09/2022
6M7212084 Diagram Residual Heat Removal (RHR) Division 1 03/17/2022
6M7212084 Diagram Residual Heat Removal Division 1 BS
6M7212135 Diagram Fire Protection System (Sheet 1) BA
6M7212135-1 Diagram Fire Protection System (Sheet 2) BL
6M7215444 Emergency Equipment Cooling Water Division 1 03/15/2022
6M7215707 Core Spray System Functional Operating Sketch 04/09/2022
6M7215721-1 Condensate Storage and Transfer System Functional 03/26/2021
Operating Sketch
25
Inspection Type Designation Description or Title Revision or
Procedure Date
6M7215729-1 Emergency Equipment Cooling Water (Division 1) 03/15/2022
Functional Operating Sketch
6M7215729-2 Emergency Equipment Cooling Water (Division 2) 04/23/2022
Functional Operating Sketch
6M721N2052 P&ID RHR Service Water System Division 1 RHR Complex 03/15/2022
Miscellaneous Division 1 RHR LPCI Standby Lineup Verification, 149
Attachment 8A
Procedures 23.127 Reactor Building Closed Cooling Water/Emergency 152
Equipment Cooling Water System
23.127 Div. 1 EECW Valve Lineup 09/21/2021
Attachment 1A
23.127 Div. 1 EECW Electrical Lineup 04/09/2006
Attachment 2A
23.127 Div. 1 EECW Instrument Lineup 11/15/2010
Attachment 3A
23.127 DIV RBCCW/ECCW Standby Verification Checklist 02/11/2021
Attachment 4
23.129 NIAS Valve Lineup 07/30/2015
Attachment 1C
23.129 Station and Control Air System Electrical Lineup 04/06/2009
Attachment 2
23.129 Station and Control Air System Instrument Lineup 01/27/2009
Attachment 3A
23.129 Div. 1 Control Air Standby Verification Checklist 01/11/2010
Attachment 4
23.203 Core Spray System: Div. 2 Initial Valve Lineup 11/15/2002
Attachment 1B
23.203 Core Spray System: Common Initial Valve Lineup 01/08/2001
Attachment 1C
23.203 Core Spray System: Div. 2 Electrical Lineup 11/15/2005
Attachment 2B
23.203 Core Spray System: Division 2 Instrument Lineup 04/07/2009
Attachment 3B
26
Inspection Type Designation Description or Title Revision or
Procedure Date
23.203 Core Spray System: Div. 2 Initial Fill and Vent Independent 01/11/2010
Attachment 5B Verification Checklist
23.203 Shifting Div. 2 Core Spray Suction to CST Independent 03/03/2020
Attachment 6B Verification Checklist
23.203 Shifting Div. 2 Core Spray Suction to Torus Independent 03/14/2020
Attachment 6D Verification Checklist
23.203 Enclosure Core Spray Manual Operation 11/27/2018
A
23.205 Residual Heat Removal System 149
23.208 RHR Complex Service Water Systems 134
23.208 Div. 1 RHRSW Valve Lineup 01/24/2022
Attachment 1A
23.208 Division 1 RHRSW Electrical Lineup 01/24/2022
Attachment 2A
23.208 Division 1 RHRSW Instrument Lineup 01/19/2006
Attachment 3A
23.303 Shifting Div. 2 Core Spray Suction to CST Independent 03/03/2020
Attachment 6B Verification Checklist
23.309 Division 1 Distribution System Electrical Lineup 12/09/2020
Attachment 1
6SD7212530-10 One Line Diagram 260 /130V ESS Dual Battery 2PA 03/16/2022
Distribution-Division 1
Work Orders 29294552 CS Division 2 Discharge Header Keep Fill E21F026B PCV 02/19/2022
Outlet Isolation Valve
71111.05 Fire Plans FPRBB2b Reactor Building Basement Northwest Corner Room, 3
Zone 2, EL. 562'0"
FPRBB3b Reactor Building Basement Southwest Corner Room, 4
Zone 3, EL. 562'0"
FPRBSB2a Reactor Building Sub-Basement Northwest Corner Room, 4
Zone 2, EL. 540'0"
FPRBSB3a Reactor Building Sub-Basement Southwest Corner Room, 5
Zone 3, EL. 540'0"
Procedures FPRB315a Reactor Building Thermal Recombiner System Area, Zone 4
15, EL. 641'6"
27
Inspection Type Designation Description or Title Revision or
Procedure Date
FPRB417a Reactor Building SLC System Zone 17 EL. 659'6" 5
FPRBSB5A Reactor Building Sub-Basement Northeast Corner Room 6
Zone 5 EL 540'0"
71111.06 Corrective Action 2231531 Extent of Condition Walkdown Revealed More Degraded 12/02/2022
Documents MELB Barriers
2231541 Walkdown of Division 1 SWRG for Possible Spray Barrier 12/02/2022
Issues
Corrective Action 2231414 NRC Identified: Spray Cover in Division 2 Switchgear Room 11/29/2022
Documents Degraded
Resulting from 2231415 NRC Identified: Pipe Cap Near P4400F449 Not Enclosed by 11/29/2022
Inspection Spray Guard
2231417 NRC Identified: Metal Enclosure on AB4 Not Sealed at Floor 11/29/2022
Level
2231419 NRC Identified: Piping Above HVAC Ducting on AB4 East 11/29/2022
Side Is Not Fully Enclosed in Blue Spray Guard
2231505 NRC Identified: Degraded Spray Shield on Division 1 EECW 12/01/2022
Piping
2231505 NRC Identified: Degraded Spray Shield on Division 1 EECW 12/01/2022
Piping
2231518 NRC Identified: Degraded MELB Barrier on Drywell Seal 12/01/2022
Rupture Drain to Condensate Storage Tank
2231571 NRC Identified: Work Order completed on 7/2/2019 Is Not 12/05/2022
Vaulted in Webarms
2231571 NRC Identified: Work Order Completed on 7/2/2019 12/05/2022
Miscellaneous EF2PRA011 Internal Flood Walkdown Summary Notebook 0
EF2PRA012 Internal Flood Analysis Notebook 4
Work Orders 49771630 Perform Inspection of Spray Shrouds 01/29/2018
71111.07T Calculations DC0249 RBCCW Hydraulics and Miscellaneous EECW Calculation K
DC0559 Vol I: Volume of Reservoir F
DC4931 Non-Interruptible Control Air System (NIAS) Calculations J
DC6286 EECW Heat Exchanger Performance Requirements with A
Plugging
Corrective Action 1830419 MDCT A and B Fan Brake Nitrogen System Leaking 12/28/2018
28
Inspection Type Designation Description or Title Revision or
Procedure Date
Documents 1927521 Unexpected Increase in Div 1 EECW Heat Exchanger 10/03/2019
Differential Pressure After Recent Swap
1927978 Trend in Anomalous System Parameter Measurements 10/21/2019
During Surveillances
1928324 2019 NRC Triennial UHS Inspection: Average Silt 10/31/2019
Accumulation in UHS Reservoir Was Not Calculated in WO 47534163
2023408 Division 1 Ultimate Heat Sink General Foreign Material 03/28/2020
(Found and Removed During Diving)
2023984 Unrecovered Foreign Material - Orange Zip Tie 04/07/2020
2030217 2020 MMR14 Structures Monitoring Inspection of RHR High 09/14/2020
Roof (WO)
2125607 Unknown Substance Coating Corrosion Coupon Holder 06/24/2021
2128982 Housekeeping Concerns on RHR Complex Roof 10/08/2021
2222162 Review of RHR Div 1 Reservoir Diving Reports 02/20/2022
2222580 Abnormal Moss Buildup and Debris Noted During Div 1 UHS 02/24/2022
Diving
2224712 Completion of RF21 RHR Div 2 Reservoir Inspection 04/05/2022
Reports and Videos / Photos
Corrective Action 2230458 2022 NRC Heat Sink Inspection: Degraded Concrete Noted 10/18/2022
Documents on Pedestal Supports for EDGs 11, 12, 13, and 14 Exhaust
Resulting from Mufflers
Inspection 2230462 2022 NRC Heat Sink Inspection: Poor Housekeeping Noted 10/18/2022
During Walkdown
2230463 2022 NRC Heat Sink Inspection: Partial Blockage Noted on 10/18/2022
South RHR Pump Pump Room HVAC Outside Air Inlet
2230480 WO Needed to Address Moss and Weeds on RHR Roof 10/19/2022
2230492 2022 NRC Heat Sink Performance Inspection: External 10/19/2022
Corrosion Identified on Floor Penetration Sleeve
2230506 2022 NRC Heat Sink Inspection: Nitrogen Cylinders Not 10/22/2022
Correctly Labelled
2230516 2022 NRC Heat Sink Performance Inspection: Enhancement 10/20/2022
Needed to PM Events P244 and P245
2230549 Performance Engineering Extent of Condition per CARD 10/21/2022
29
Inspection Type Designation Description or Title Revision or
Procedure Date
2230538
2230666 2022 NRC Heat Sink Performance Inspection: Exterior Tape 10/27/2022
on Service Water Piping in RHR Complex
Drawings 6M7212015 Diagram Station and Control Air CU
6M7215357 Emergency Equipment Cooling Water System Division II BW
MN2026 General Arrangement RHR Complex Basement Floor Plan E
MN2031 General Arrangement RHR Complex Section "CC" F
MN2050 Equipment Drains and Floor Drains Divisions 1 and 2 RHR O
Complex
Miscellaneous Commercial Diving and Marine Services Fermi RF21 Outage 02/21/2022
Diving Div 1
Commercial Diving and Marine Services Fermi RF21 Outage 03/28/2022
RHR Div 2 Dive Report
Consumable Cryotech CMA 01/15/2021
Materials
Evaluation (CME)
210011
Procedures 1D88 Division 1 EECW Outlet Temp 21
20.127.01 Loss of Reactor Building Closed Cooling Water System 31
20.129.01 Loss of Station and/or Control Air 38
23.127 Reactor Building Closed Cooling Water / Emergency 151
Equipment Cooling Water System
23.129 Station and Control Air System 124
23.208 RHR Complex Service Water Systems 134
24.000.02 Shiftly, Daily, and Weekly Required Surveillances 161
7D3 Div 1 RHR Reservoir Level Abnormal 19
E11XX Residual Heat Removal Service Water (RHRSW) System E
Design Basis Document
MES 52 GL 8913 Safety Related Service Water Monitoring Program 10A
MES 54 Heat Exchanger Component Monitoring Program 8
MMA10 System Cleanliness 12
MMA17 Foreign Material Exclusion (FME) 17
MMR14 Structures Monitoring 8
30
Inspection Type Designation Description or Title Revision or
Procedure Date
MOP21 Housekeeping 7
Work Orders 52194616 License Renewal Required Perform Div 1 Reservoir Zebra 03/25/2020
Mussel Inspection Dive
52195243 License Renewal Req'd Perform Div 2 RHR Reservoir Zebra 04/08/2020
Mussel and Ball Valve Inspection Dive
57269374 License Renewal - Perform Div 1 RHR Reservoir Zebra 02/13/2022
Mussel and Ball Valve Inspection Dive [Confidential]
57269883 License Renewal - Perform Div 2 RHR Reservoir Zebra 03/27/2022
Mussel and Ball Valve Inspection Dive
71111.11A Miscellaneous 2022 LOR NRC Fermi 2022 Licensed Operator Requalification Exam 11/21/2022
Annual OP Test Summary Which Provides the Exam Results for the Annual
Summary Operating Tests Administered from 10/11/2022 - 11/10/2022
71111.11Q Miscellaneous LPOP2022225 Containment Tech Specs and EALs 0
SSOP2022243 Simulator Lesson Plan 0
SSOP9042283 Fermi 2 Evaluation Scenario 0
Procedures 24.202.01 HPCI Pump and Valve Operability Test at 1025 psi 123
29.100.01 SH 1 RPV Control 19
29.100.01 SH 2 Primary Containment Control 17
29.100.01 SH 6 Curves, Cautions, and Tables 19
ODE10 Emergency Operating Procedure Expectations 36
ODE3 Communications 75
71111.12 Corrective Action 1823026 Reactor Scram Due to Loss of 64 Transformer 04/14/2018
Documents 2000399 TIP Detectors Retracting One Inch Behind the Programmed 01/06/2021
InShield Position
2021388 TIP E Flux Readings Degrading Rapidly 07/28/2020
2026872 TIP C and TIP D Ball Valves Opened with TIPS InShield 06/22/2020
2122080 ITE Type K600-s Breakers Failed to Close 03/08/2021
2222886 Nova Inverters Found OOT 03/01/2022
2223206 Bus 72EB Pos 2D Failed to open 03/07/2022
2223772 Nova Inverter Tech Evaluation for Frequency Needed Due 03/17/2022
to Frequency Adjustment Issues
2226656 Ground Fault on 72U, Loss of Bus 05/28/2022
Drawings 6I7212421-05 Schematic Diagram RBCCW Supplemental Cooling Division 04/08/2017
31
Inspection Type Designation Description or Title Revision or
Procedure Date
2 Cooling Pumps
Miscellaneous N/A R1400 Electrical Switchgear 2021 Quarters 2 and 3 System 2021
Health Report
R1400 R1400 Electrical Switchgear System Get Well Plan (GWP) 6
VMC1545 Installation and Operations Manual for Nova Electric Galaxy 0
Inverter
Procedures MMR APP B Maintenance Rule Conduct Manual Appendix B-Terms and 8
Definitions
MMR APP E Maintenance Rule Conduct Manual Appendix E- 27
Maintenance Rule SSC Specific Functions
Self-Assessments R1400 Electric Switchgear System Health Q2 and Q3 2021
R1400 Electric Switchgear System Health Report Q4 2020
R1400 Electric Switchgear System Health Q4 2021
71111.13 Corrective Action 2230935 Relay Room H11P613 11/07/2022
Documents 2231390 MDCT Fan 'B' Loud Metallic Noise 11/28/2022
Drawings 6I7212045-28 Internal-External Wiring Diagram Division 1 Process AG
Instrumentation Cabinet H11P613 Part-3
6I7212265-02 Schematic Diagram Reactor Water Cleanup System AK
Instrumentation
Miscellaneous MWC15001 Risk Management Plan for South RFP Suction Line Flow 12/20/2022
Switch Low Source Valve Leak
VMR11.18 Millivolt to Current (MV/1) Transmitter A
Procedures MMR 12 Equipment Out of Service Risk Management 20A
MMR Appendix H Online Core Damage Risk Management Guidelines 17
Work Orders 60510175 East Gland Seal Exhaust Motor Replacement 11/02/2022
71111.15 Corrective Action 2228738 MES27 Evaluation Does Not Support the Immediate 08/15/2022
Documents Operability Determination Assumptions in CARD 2228664
Resulting from
Inspection
Engineering TEE1122-034 E1156C001B Mechanical Draft Cooling Tower Noise 0
Evaluations TER3022-068 Licensing Basis for the Effect of Tornado Depressurization A
on a Running EDG
Miscellaneous Adverse Condition B310F010B RRP B Seal Purge Regulating Valve 2
32
Inspection Type Designation Description or Title Revision or
Procedure Date
Monitoring Plan
20010
DBD XXX02 Design Basis Document 26
Various Various NRC Guidance Documents Pertaining to Operability Various
and the Meaning of Design Basis
Procedures 20.307.01 Emergency Diesel Generator Failure 21
22.307.01 Emergency Diesel Failure 22
23.138.01 Reactor Recirculation System 119
71111.18 Corrective Action 2230843 PT FD76 Issues and EDM Impact 11/03/2022
Documents
Corrective Action 2230932 NRC Identified: RB5 EDM Equipment Box Label Not Correct 11/07/2022
Documents 2231503 NRC Identified Issue: 29.EDM.07 Procedure Issue 12/01/2022
Resulting from
Inspection
Drawings 29.200.xx 29.200 series Severe Accident Management Guidelines various
Flowcharts
Engineering 60106 Vehicle Barrier System Modification at Entrance to Alternate 0
Changes Access Portal
Miscellaneous NEI 1401 Emergency Response Procedures and Guidelines for 1
Beyond-Design-Basis Events and Severe Accidents
Procedures 29.EDM.03 SFP Makeup/Spray - External Strategy 5
29.EDM.07 Passive Ventilation of the Air Space Above the Fuel Pool 1
[Confidential]
78.000.69 Chemistry Special Test Procedure 27
MGA 14 Severe Accident Management Program 6
71111.19 Corrective Action 2228853 T4100B007 Above Its Investigative Limit 08/18/2022
Documents 2230081 T41N227A AsFound Condition Not Functioning During the 10/03/2022
Performance of WO 46289018
2230085 T4100 Failed PMT 10/03/2022
2230087 Unidentified Contingency Parts / Planning Impact 10/04/2022
Drawings 6I7212451-13 Schematic Diagram NIAS Div. 1 Dryer Controls 06/02/2016
6M7215707 Core Spray System Functional Operating Sketch 04/09/2022
6M7215730-3 Non-Interruptible Control Air System Division 1 and 2 03/29/2012
33
Inspection Type Designation Description or Title Revision or
Procedure Date
Functional Operating Sketch
IS248103B EDP 80165.022 (Fermi 2 Diesel Fire Pump Modification 11/08/2022
Alarm Circuitry)
Engineering EDP 80165 Fermi 2 Diesel Driven Fire Pump Replacement Modification 0
Changes
Work Orders 44128550 Calibrate Div. 1 CCHVAC Chiller Condenser EECW Outlet 10/03/2022
Flow Switch
46289018 Calibrate Div. 1 CCHVAC Emergency Make-up and Recirc 10/03/2022
Air Temperature Switch
47264945 PDMA Testing (Motor Tagged) of Control Air Compressor 11/02/2022
Room Cool Unit
48640608 Replace Div. 1 Control Air Non-Interruptible Air Supply 11/02/2022
Isolation Valve Solenoid Valve
48860374 Calibrate Div. 1 CCHVAC Chiller Evaporator Low 10/03/2022
Temperature Switch
57420071 License Renewal Replace Suction and Discharge Valves 11/02/2022
with New and Refurbished Valves
58187204 Replace Non-Interruptible Air Supply Solenoid Valve 11/02/2022
58471305 Control Air Non-Interruptible North Control Air Dryer West 11/02/2022
Chamber Relief Valve
61353693 Replace Division 1 North Control Air Compressor Unloading 11/02/2022
Cylinder Solenoid Valve
61563113 Calibrate Division 1 CCHVAC Equipment Room 10/03/2022
Temperature Switch
63600050 Test Division1 CCHVAC Zone 2 Cable Spreading Room 10/03/2022
Mixing Damper Temperature Loop
64193098 7D51 Division 1 Control Air System Trouble Due to High 11/02/2022
Differential Pressure. Calibrate or Replace
66000026 Post Mod Testing for EDP 80165 11/23/2022
71111.22 Corrective Action 0422892 EDG 11 DGSW Pump Min Flow Valve Not Indicating Fully 06/28/2004
Documents Closed
0425803 Rework EDG11, 12, and 14 DGSW Minimum Flow Valves 11/19/2004
2123411 Step Change in RB Steam Tunnel Temperature Due to 04/16/2021
Possible HPCI Steam Leak
34
Inspection Type Designation Description or Title Revision or
Procedure Date
2226208 Rounds Needs Updated 05/11/2022
2229106 Increased Unidentified Leakage in Drywell DD72 Sump 08/29/2022
During Division 2 EECW Pump and Valve Surveillance
24.107.09 Section 5.1
2229187 Drywell Unidentified Leakage Update 08/31/2022
2229282 Drywell Sump Leakage Increase 09/02/2022
2229536 Performing MMA26 for CARD 2227022 DW Unidentified 09/14/2022
Leakage
2230145 R30F402 Indicating 10 Percent Open When Valve Should 10/05/2022
Be Closed
2230170 No Flow, Suspect Drain Line Clogged 10/05/2022
2231365 0.8" Step Change in Drywell Floor Drain Sump Level 11/26/2022
Following Pumpdown
2231450 Investigation of Parameters Around a Run of HPCI 11/30/2022
Corrective Action 2223089 NRC Concern - Operations Rounds Details on Safety- 03/04/2022
Documents Related Motor Oil Levels
Resulting from
Inspection
Drawings 6I7212572-28 4160V ESS Buses 64B and 64C Load Shedding Strings V
6I721257B-05 Relay and Metering Diagram 4160V ESS Bus 64B U
6I721N257217 4160V ESS Diesel Bus 11EA Load Shedding Strings Y
6I721N257806 Relaying and Metering Diagram Diesel Generator 11 Unit 2 X
6M7213361-1 Standby Liquid Control Pump, Reactor Building, Unit 2 P
6SD7212500-03 One Line Diagram 4160V System Service Buses 64B, 64C S
Miscellaneous N/A Control Room Narrative Logs from 11/13/2022 to 11/30/2022
11/30/2022
VMR147.1 Union Pump B
VMR147.4 Gear Reducers A
VMR162 Triclad Vertical Induction Motor F
VMS2539 Centrifugal Water Chillers L
Procedures 24.207.09 Division 2 EECW Pump and Valve Operability 47
24.307.34 DGSW, DFOT, and Starting Air Operability Test EDG 11 58
42.302.07 Calibration and Functional Test of Division 1 4160 Volt Bus 38
35
Inspection Type Designation Description or Title Revision or
Procedure Date
64B Undervoltage Relays
MES 49 Evaluation and Control of Leakage from Class 1, 2, and 3 9
Piping Systems
Work Orders 56289097 Perform 3Year Performance Testing of N+1 Train 09/03/2021
Dominator and Neptune Equipment
60264432 Perform 42.302.07 Division 1 Bus 64B 4160V Undervoltage 10/06/2022
Relays Cal/Funct
61256368 Perform 3Year Performance Test of N Train Dominator and 09/03/2021
Neptune Equipment
61905540 Perform 24.307.34 Sec-5.1 and 5.2 DGSW and DFOT Pump 09/02/2022
and Valve Operability Test - EDG 11
66926147 Perform 24.20201 HPCI Pump/Flow Test and Valve Stroke 11/29/2022
at 1025 psig
71114.04 Miscellaneous 202108E 50.54(q) Evaluation - Spent Fuel Pool Level Updates for 09/21/2021
RA2.3, RS2.1, and RG2.1
202135S 50.54(q) Screen - Spent Fuel Pool Level Updates for RA2.3, 09/21/2021
RS2.1, and RG2.1
Procedures EP101 Classification of Emergencies 43A
EP101 Classification of Emergencies 44
71114.06 Procedures EP101 Classifications of Emergencies 44
71152A Corrective Action 1324841 EDG Steady State Voltage and Frequency Tech Spec 07/10/2013
Documents Ranges
1826451 SLC Storage Tank Heater B Leak 08/27/2018
1927780 VT2 Inspection Results - C4100F001 10/11/2019
1927781 VT2 Inspection Results - C4101S002 10/11/2019
2024915 CSRT Dry Run Findings 04/21/2020
2027392 Safety Concern 06/28/2020
2027659 Safety Concern - Questionable Decision Making Leading to 07/05/2020
Error Likely Situation
2124291 3D17 IPCS Computer Trouble Due to Loss of SS1 05/16/2021
2128792 SS1 CARD Documentation Requires Investigation 10/04/2021
2221059 Product Failed EQRT 02/03/2022
2223915 Discrepancy Identified in RF20 Torus Recoat WO 55151575 03/19/2022
36
Inspection Type Designation Description or Title Revision or
Procedure Date
2225370 NQA RF21 - Complete MES 27 Risk Evaluation for CARD 04/19/2022
1324841
2225370 NQA RF21 - Complete MES 27 Risk Evaluation for CARD 04/19/2022
1324841
2228341 NQA Audit 220107 Deficiency - Untimely Actions for SPING 07/29/2022
and SS1 Computer Replacement
2229030 SPING Flow Calibration Review 08/25/2022
2230062 VT2 Exam Results - C4101S002 10/02/2022
2230739 3D82 MS Steam Line Channel A/B/C/D Radiation Monitor 10/31/2022
HiHi Due to Channel A
2231322 Non-Functional Category C EITER (EP580) 11/22/2022
2231437 Evaluate Fermi Operating License 2.C.10 for Amendment 11/29/2022
Corrective Action 2230092 NRC Identified: Missed LER for Past Operability of CARD 10/04/2022
Documents 2227461
Resulting from 2230116 NRC Identified - Leaking SLC Bolted Connections not 10/04/2022
Inspection Inspected During RF21
Drawings 6I7212095-14 Schematic Diagram Nuclear Steam Supply Shut Off System O
Trip System A
6I7212185-03 Schematic Diagram Process Radiation Monitor SYS Main N
Steam Line Rad Monitor Sub SYS D1103
6I7212351-02 Schematic Diagram Condenser Vacuum Pump East K
(N6101C001)
Miscellaneous RERP Plan 49
U.S. Nuclear Regulatory Commission Regulatory Guide 3
22022 ISI/NDE- Standby Liquid Control Flange Leakage Evaluation 0
IST Program
Evaluation Sheet
Equipment Cause 2222967, RF21 MES 83114 Inspection - Torus Immersion 03/02/2022
Evaluation Space - Indications Identified in Coating on Bays 4 and 5
HP Cause 2024860, Worker Fell from Lower Work Platform 1
Evaluation
NEI 1503 Licensee Actions to Address Nonconservative Technical 2
Specifications
37
Inspection Type Designation Description or Title Revision or
Procedure Date
RERP Plan Radiological Emergency Response Preparedness Plan 12/18/2019
Operability MGA 21 General Administrative Conduct Manual 9
Evaluations
Procedures EP101 Enclosure A - Classification Matrix 44
EP546 RERP Plan Implementing Procedure 8
EP580 Equipment Important to Emergency Response (EITER) 10
MGA 31 Supplemental Personnel Control Practice 4
71152S Corrective Action 2227456 Ground Fault on YPhase on Output Form Main Unit 06/27/2022
Documents Transformer to CM and CF Output Breakers
2227461 FO 2201 Start Up Walkdown: MOV Actuator Disconnected 06/27/2022
From Bonnet
2227473 Procedure Revision for Mayfly Infestation Preparation 06/27/2022
Plan 27.322
2227475 Actuator Broke Free of Yolk Mounting Bolts - B2103F019 06/27/2022
2227499 Add Circuits to 27.322 Mayfly Infestation 06/28/2022
2231628 Trend in NRC Identified CARDs Related to MELB Spray 12/07/2022
Shield Barriers
2231631 Procedure 23.107 Does Not Work as Written 12/07/2022
2231951 Evaluate Emerging Trend of Failed MRC Products 12/19/2022
Miscellaneous Human 2230092 - NRC Identified: Missed LER for Past Operability 09/13/2022
Performance of CARD 2227461
Cause Evaluation
Organizational 2027545 - Loss of 345kv Due to Mayfly Infestation 2
Effectiveness
Cause Evaluation
Procedures 27.322 Mayfly Infestation Preparation Plan 17, 23
71153 Corrective Action 2127388 HPCI and Div 2 EDG Sequencer Power Failures 08/22/2021
Documents
Miscellaneous LER 2021001 Unrecognized Impact of Opening of Barrier Doors on High 0
Energy Line Break Analysis
LER 2022003 Turbine Trip and Subsequent Reactor Trip Due to Mayflies 0
NRC220013 Licensee Event Report 2022001 04/04/2022
38