IR 05000341/2023003
| ML23304A155 | |
| Person / Time | |
|---|---|
| Site: | Fermi, 07200071  |
| Issue date: | 11/07/2023 |
| From: | Karla Stoedter NRC/RGN-III/DORS/RPB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| EA-23-091 IR 2023003 | |
| Download: ML23304A155 (32) | |
Text
November 7, 2023
SUBJECT:
FERMI POWER PLANT, UNIT 2-INTEGRATED INSPECTION REPORT 05000341/2023003 AND 07200071/2023001
Dear Peter Dietrich:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On October 20, 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.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements one was determined to be Severity Level IV.
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 in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Stoedter, Karla on 11/07/23 Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety
Docket Nos. 05000341 and 07200071 License No. NPF-43
Enclosure:
As stated
Inspection Report
Docket Number:
05000341 and 07200071
License Number:
Report Number:
Enterprise Identifier: I-2023-003-0052 and I-2023-001-0102
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
July 01, 2023 to September 30, 2023
Inspectors:
T. Taylor, Senior Resident Inspector
T. Briley, Senior Project Engineer
J. Bozga, Senior Reactor Inspector
L. Rodriguez, Senior Reactor Inspector
E. Fernandez, Senior Reactor Inspector
J. Gewargis, Resident Inspector
T. Hooker, Health Physicist
R. Ng, Senior Project Engineer
J. Reed, Health Physicist
D. Sargis, Health Physicist
A. Shaikh, Senior Reactor Inspector
Approved By:
Karla K. Stoedter, Chief
Engineering Branch 1
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
Mechanical Draft Cooling Tower Bolt Repair Lacks Engineering Documentation Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems Green Severity Level IV NCV 05000341/202300301 Open/Closed
[H.6] - Design Margins 71111.18 The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to mechanical draft cooling tower (MDCT) fan D anchorage completed on July 21, 2023, did not require a license amendment. Specifically, the licensee made a change to the MDCT fan D anchorage design pursuant to 10 CFR 50.59(c). This change involved going from one existing American Society of Testing and Materials (ASTM) A36 anchor bolt as the anchorage design to the full penetration welding of an ASTM A193 Grade B7 anchor bolt to an existing damaged piece of ASTM A36 anchor bolt. However, no written evaluation was provided describing the basis for determining that this change would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety.
Inoperable Mechanical Draft Cooling Towers Following Modification to Brake Control Circuit Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300302 Open/Closed None (NPP)71152A A finding of very low safety significance (Green) with an associated non-cited violation of 10 CFR 50 Appendix B, Criterion III, "Design Control," was self-revealed when all four MDCTs were declared inoperable due to the licensee's failure to verify or check the adequacy of the design of new speed switches installed as part of Engineering Design Package 80072.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000341/202300201 Review of Increasing Differential Pressures on the Division 1 Emergency Equipment Service Water/Emergency Equipment Cooling Water Heat Exchangers 71111.07A Open
URI 05000341/202300303 Mechanical Draft Cooling Tower 'D' Inoperable due to High Vibrations 71153 Open
PLANT STATUS
Unit 2 began the inspection period at or near 100 percent power. On July 23, 2023, power was reduced to approximately 88 percent following high temperatures on the center condenser pump motor. On July 31, power was further reduced to approximately 58 percent to facilitate repairs to the center condenser pump motor. Power was restored to 100 percent on August 3, following repairs. On August 6, power was reduced to approximately 90 percent and then returned to 100 percent as part of a planned rod pattern adjustment. On August 9, power was reduced to approximately 90 percent and returned to 100 percent for planned maintenance/testing. On August 19, power was reduced to approximately 23 percent to facilitate a search for increased drywell unidentified leakage. On August 20, the plant was shut down to repair the source of leakage in the drywell. The planned outage concluded on September 8, when the plant was synchronized to the grid. The plant returned to 100 percent power on September 9,
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed onsite portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency diesel generator (EDG) division 1 and division 2 ventilation during hot weather on July 26, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (10 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) Fire protection walkdown of EDG 12 engine room prior to slow start run during the week ending July 8, 2023
- (2) Auxiliary building (AB) 1 walkdown to include cable vaults after cable vault inspections during the week ending July 15, 2023
- (3) Reactor building, southeast corner room, basement and sub-basement during the week ending August 9, 2023
- (4) Residual heat removal (RHR) complex, EDG 14 room and fuel oil storage room during the week ending August 9, 2023
- (5) AB 2 and AB mezzanine walkdown with TRM requirement review of 28.505.09A/.09 during the week ending August 12, 2023
- (6) Turbine building, third floor during the week ending August 18, 2023
- (7) Turbine building, second floor during the week ending August 18, 2023
- (8) AB, division 2 switchgear room during the week ending August 18, 2023
- (9) Reactor building, first floor north during the week ending August 18, 2023
- (10) Reactor building, first floor south during the week ending August 18, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill of the turbine building second floor hydrogen seal oil unit during the week ending August 12, 2023
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Partial)
The inspectors evaluated readiness and performance of:
(1)
(Partial)
Inspectors continued review of issues associated with unexpectedly high differential pressures measured on the Division 1 emergency equipment service water (EESW)/emergency equipment cooling water (EECW) heat exchangers. The sample was opened in the second quarter (IR 05000341/2023002). Also refer to Unresolved Item (05000341/2023002-01).
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 up power from 64 percent to 85 percent after the center condenser pump motor replacement on August 2, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Reactor recirculation motor-generator controller replacement during the week ending July 22, 2023
- (2) Down power and at power drywell entry to investigate increasing drywell leakage during the week ending August 19, 2023
- (3) Center condenser pump motor replacement/wall removal, main steam isolation valve isolation temperature instruments, during the week ending September 30, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) EDG 12 lube oil flexible coupling leak degraded during EDG 12 run and governor level change and the damper challenges over the weekend of July 9, 2023
- (2) MDCT fan 'D' trip on July 18, 2023, in fast-mechanical issue/vibes during the week ending September 30, 2023
- (3) Reactor core isolation cooling outboard steam supply containment isolation valve E5150F008 steam leak on actuator/past operability during the week ending September 30, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Repair of MDCT 'D' bolt during the week ending September 30, 2023
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated planned outage activities to repair 'B' recirculation sample line from August 20, 2023, to September 8, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (1 Sample)
- (1) Repair and testing of recirculation sample line weld during the week ending September 16, 2023
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) EDG 14 diesel generator service water (DGSW) diesel fuel oil transfer pump and valve operability test during the week ending August 15, 2023
- (2) EDG 13 fast start run operability test during the week ending August 15,
RADIATION SAFETY
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
OTHER ACTIVITIES-BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 2 (July 1, 2022 through June 30, 2023)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) Unit 2 (July 1, 2022 through June 30, 2023)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) Unit 2 (July 1, 2022 through June 30, 2023)
===71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03)===
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Review of circumstances leading to inoperable overspeed protection circuits on the mechanical draft cooling towers.
71153 - Follow-Up of Events and Notices of Enforcement Discretion Notice of Enforcement Discretion (NOED) (IP Section 03.04)
- (1) The inspectors evaluated the licensee actions surrounding Notice of Enforcement Discretion EA-23-091, which can be accessed at http://www.nrc.gov/reading-rm/doc-collections/enforcement/notices/noedreactor.html, on July 26,
OTHER ACTIVITIES
-TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855 - Operation of an ISFSI Operation of an ISFSI
- (1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading activities from June 26 through June 30, 2023. Specifically, the inspectors observed the following activities during the loading of multipurpose canister (MPC) No. 728:
- fuel loading
- heavy load movement of loaded MPC out of the spent fuel pool
- closure welding and non-destructive evaluations
- canister processing including blowdown and vacuum drying
- radiological field surveys
The inspectors performed walkdowns of the ISFSI pad and walkdowns of the ISFSI haul path.
The inspectors evaluated the following:
- spent fuel selected for loading into dry cask storage during this loading campaign
- selected corrective action program documents
- selected 72.48 screenings
- changes to the site's 72.212 report since the previous inspection
INSPECTION RESULTS
Unresolved Item (Open)
Review of Increasing Differential Pressures on the Division 1 Emergency Equipment Service Water/Emergency Equipment Cooling Water Heat Exchangers URI 05000341/202300201 71111.07A
Description:
The inspectors continued their review of issues associated with unexpectedly high differential pressures measured on the Division 1 EESW/EECW heat exchangers as discussed in Inspection Report 05000341/2023002 and as part of Unresolved Item 05000341/2023002-01.
Planned Closure Actions: The NRC will continue to assess the licensee's potential causes and evaluate the licensee's review of this issue. If a performance deficiency is identified, the NRC will perform an assessment to determine if the performance deficiency is more-than-minor and whether a violation exists/existed.
Licensee Actions: The licensee cleaned and tested both the 'A' and 'C' Division 1 EESW/EECW heat exchangers (HXs) and instituted a formal monitoring plan to trend performance. Further, the 'D' HX on Division 2 was tested satisfactorily. The licensee plans to complete a root cause evaluation of this issue, which was still in progress as the third quarter closed.
Corrective Action References: 202330619
Mechanical Draft Cooling Tower Bolt Repair Lacks Engineering Documentation Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems Green Severity Level IV NCV 05000341/202300301 Open/Closed
[H.6] - Design Margins 71111.18 The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to MDCT fan D anchorage completed on July 21, 2023, did not require a license amendment. Specifically, the licensee made a change to the MDCT fan D anchorage design pursuant to 10 CFR 50.59(c). This change involved going from one existing ASTM A36 anchor bolt as the anchorage design to the full penetration welding of an ASTM A193 Grade B7 anchor bolt to an existing damaged piece of ASTM A36 anchor bolt. However, no written evaluation was provided describing the basis for determining that this change would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety.
Description:
Fermi Updated Safety Analysis Report (UFSAR) Section 1.2.2.3.6, Loss of Normal Heat Sink, states, The natural-draft cooling towers provide the normal heat sink for the once-through-type main unit condenser and auxiliary systems. Should this heat sink be lost, the reactor can be safely shut down and maintained using the mechanical-draft cooling towers and the residual heat removal (RHR) reservoir as a heat sink.
Fermi UFSAR Section 9.2.5, Ultimate Heat Sink, states, in part, The ultimate heat sink is provided by the RHR complex, which contains the RHR service water (RHRSW) system, the
[emergency equipment service water system] EESWS, the diesel generator service water system, the MDCTs, the emergency ac power system (diesel generators), and the reservoir.
Fermi UFSAR Table 3.2-1, "Structures, Systems, and Components Classification," delineates the MDCTs including structure fans and related hardware as Category I and meeting the Quality Assurance requirements of 10 CFR 50, Appendix B.
Fermi UFSAR Table 3.9-43, Safety-Related Mechanical Components Not Covered by ASME Code, delineates that the MDCTs have a design specification for structural steel of American Institute of Steel Construction (AISC) and a design code of reinforced concrete as American Concrete Institute (ACI).
MDCT fan D is anchored to its concrete pedestal via three mounting anchor bolts. The licensee identified during walkdowns that the front mounting anchor bolt was sheared off and not connected to the concrete pedestal. The licensee implemented Design Equivalent Change Package 700015, Repair damaged anchor for E1156B002B MDCT D gear reducer, Revision 0 that modified the MDCT fan D anchorage.
The inspectors reviewed Design Equivalent Change Package 700015, Revision 0. The licensee made the determination in Design Equivalent Change Package 700015, Revision 0 that no written evaluation was needed to determine potential impacts related to the design change. This activity involved the full penetration welding of an ASTM A193 Grade B7 anchor bolt to an existing piece of damaged ASTM A36 anchor bolt. The inspectors identified that the design verification of the new anchor bolt configuration had not considered the following:
1) The full penetration welding of the new anchor bolt ASTM A193 Grade B7 material with the existing damaged ASTM A36 material has the potential to introduce weld residual stresses which can adversely affect the yield strength of the anchor bolt material.
2) The dissimilar bolt material condition may cause an accelerated corrosion process (one anchor bolt material will be noble-cathode and the other anchor bolt material will be sacrificial-anode) at the heat affected zones.
3) The standard specification for ASTM A193 specifies that Grade B7 shall be heat treated by quenching in a medium and tempering. The AISC 9th Edition specifies that an anchor bolt that is quenched and tempered should not be welded or heat treated. The full penetration welding to the ASTM A193 Grade B7 anchor bolt material can adversely affect the mechanical properties of the bolt material which include the yield strength, ultimate strength, elongation, hardness and area.
The licensee's decision to full penetration weld the aforementioned anchor bolt materials together, as evaluated under Design Change 700015, created an anchorage design that could result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the updated final safety analysis report due to the considerations discussed above.
The licensee is permitted to make changes to the facility as described in the UFSAR without prior NRC approval provided that these changes would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of structure, system or component important to safety used in establishing the plant design bases. Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, states that the methods described in Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Evaluations, Revision 1, are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.59. NEI 96-07, Revision 1, Section 4.3.2, addresses Does the Activity Result in More Than a Minimal Increase in the Likelihood of Occurrence of a Malfunction of an SSC Important to Safety? The section states, in part: although this criterion allows minimal increases, licensees must still meet applicable regulatory requirements and other acceptance criteria to which they are committed (such as contained in regulatory guides and nationally recognized industry consensus standards, e.g., the ASME Boiler and Pressure Vessel Code and Institute of Electrical and Electronics Engineers standards). Further, departures from the design, fabrication, construction, testing and performance standards as outlined in the General Design Criteria (Appendix A to Part 50) are not compatible with a no more than minimal increase standard. In addition, changes in design requirements for earthquakes, tornadoes and other natural phenomena should be treated as potentially affecting the likelihood of malfunction. Based upon the above, the inspectors concluded that the change would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety.
Corrective Actions: The licensee sent a mock-up of the modified anchorage configuration to a vendor for testing to address the weld residual stresses, mechanical properties and galvanic corrosion.
Corrective Action References: CR 2023-33153 and CR 2023-33264
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to provide a written evaluation describing the basis for determining that the change to the MDCT fan D anchorage design, which was completed on July 21, 2023, did not require a license amendment was contrary to 10 CFR 50.59(d)(1) and was a performance deficiency.
Specifically, the licensee made a change to the MDCT fan D anchorage design pursuant to 10 CFR 50.59(c) and did not address the change in a full written evaluation.
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. In addition, the associated violation was determined to be more than minor because the inspectors could not conclude that the changes would not result in a more than minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety used in establishing the MDCT fan D anchorage design without further evaluation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Significant Determination Process (SDP). However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. The inspectors determined the finding could be evaluated using the SDP and used IMC 0609, Attachment 4, Initial Characterization of Findings, issued December 13, 2019, and Appendix A, The Significance Determination Process for Findings at Power, issued
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: In accordance with Section 6.1.d.2 of the NRC's Enforcement Policy, the violation was classified as a Severity Level IV violation because the underlying technical issue was of very low risk significance.
Violation: Title 10 CFR 50.59, Changes, Tests and Experiments, (d)(1) states, in part, a licensee shall maintain records of changes in the facility made pursuant to paragraph
- (c) of this section. These records must include a written evaluation that provides the bases for the determination that the change does not require a license amendment pursuant to 10 CFR 50.59(c)(2).
10 CFR 50.59(c)(2)(ii) states, in part, a licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated).
Fermi USAR Section 1.2.2.3.6, Loss of Normal Heat Sink, states, The natural-draft cooling towers provide the normal heat sink for the once-through-type main unit condenser and auxiliary systems. Should this heat sink be lost, the reactor can be safely shut down and maintained using the mechanical-draft cooling towers and the residual heat removal (RHR)reservoir as a heat sink.
Fermi UFSAR Section 9.2.5, Ultimate Heat Sink, states, in part, The ultimate heat sink is provided by the RHR complex, which contains the RHR service water (RHRSW) system, the
[emergency equipment service water system] EESWS, the diesel generator service water system, MDCTs, the emergency ac power system (diesel generators), and the reservoir.
November 30, 2020, to evaluate the technical issue. The finding was screened against the Mitigating Systems cornerstone. The finding screened as having very low safety significance (Green) because the MDCT fan D anchorage maintained its operability to provide sufficient cooling to permit safe shutdown and cooldown of the plant in the event of a design-basis accident. As such, the finding corresponded to a Severity Level IV violation in accordance with Example 6.1.d.2 of the NRC Enforcement Policy.
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. Specifically, the licensee failed to adequately evaluate the weld residual stresses, mechanical properties and galvanic corrosion due to the full penetration welding of an ASTM A193 B7 anchor bolt to an existing damaged ASTM A36 anchor bolt for the effect on the anchorage design margin.
Inoperable Mechanical Draft Cooling Towers Following Modification to Brake Control Circuit Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202300302 Open/Closed None (NPP)71152A A finding of very low safety significance (Green) with an associated non-cited violation of 10 CFR 50 Appendix B, Criterion III, "Design Control," was self-revealed when all four MDCTs were declared inoperable due to the licensee's failure to verify or check the adequacy of the design of new speed switches installed as part of Engineering Design Package 80072.
Description:
The MDCTs consist of four fans (two per division) that are designed to remove heat from the ultimate heat sink. The plants ultimate heat sink is a reservoir of water beneath the residual heat removal (RHR) service water complex. The fans are protected from overspeed during design basis tornadoes by a control circuit that senses fan speed via a magnetic sensor located near the gear teeth. This signal is sent to a speed switch that will apply brakes to the fan if the speed gets too high. On March 13, 2023, procedure 46.205.001, "Calibration of RHR Cooling Tower Fan Overspeed Protection System," Revision 33, was being performed on the 'D' MDCT fan. The purpose of the procedure was to test the overspeed braking system to ensure it actuated at the correct fan rotation per minute (RPM) using a simulated speed signal injected into the overspeed switch. During the test, technicians noted the RPM indication was at zero with the fan running in fast speed. Troubleshooting revealed that while the test would pass with the 4-volt peak-to-peek (4Vp-p) simulated square wave applied to the switch per the test, the brakes would not work with the actual ~9Vp-p field signal sent from the magnetic sensor. In consultation with the switch supplier, the licensee determined an appropriate voltage the switch would function at when installed in the licensees system. This information led to a design change, which was implemented by the licensee to restore the MDCT fans to an operable status (addition of an adjustable potentiometer to lower input voltage from the sensor to the switch). As a result of their discussions with the switch supplier Fermi UFSAR Table 3.2-1, "Structures, Systems, and Components Classification," delineates the MDCTs including structure fans and related hardware as Category I and meeting the Quality Assurance requirements of 10 CFR 50, Appendix B.
Fermi UFSAR Table 3.9-43, Safety-Related Mechanical Components not Covered by ASME Code, delineates that the MDCT fans have a design specification for structural steel of AISC and a design code of reinforced concrete as ACI.
Contrary to the above, as of July 21, 2023, the licensee failed to maintain records of a change to the facility made pursuant to paragraph
- (c) of this section. Specifically, the licensee changed the anchorage design for MDCT fan D and did not evaluate whether changes in the anchorage weld residual stresses, mechanical properties and galvanic corrosion constituted more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
during troubleshooting (Engine Systems International), the licensee issued a Part 21 notification (ML23159A004 and ML23177A043) due to questions regarding testing performed during their dedication of the new switches. Of note, the inoperability that occurred to the MDCT fans only applied to the overspeed braking function, which is only required during design basis tornado conditions.
The inspectors reviewed the root cause analysis performed by the licensee and the design change package (EDP 80072) which installed the new overspeed switches. The Division 1 switches (fans 'A' and 'C') were installed in December 2020. The Division 2 switches (fans 'B' and 'D') were installed in September 2022. The modification primarily affected the switches and connection to the plant power system (power supply change). The sensor and its associated wiring in the plant remained the same. Some of the original design drawings, and drawings approved for the new overspeed circuit, stated that the input voltage to the switch from the sensor should be set to 2V peak (2Vp) with the fan running at 1750 RPM (the fast speed of the fan). This is equivalent to 4Vp-p. Specifically, design drawings E-6001-01 (via EDP posting 80072.005), "Division 1 RHR Complex Cooling Towers Fan Overspeed Brake System," Revision C, and drawing E-6001-02, "Division 2 RHR Complex Cooling Towers Fan Overspeed Brake System," Revision D, stated adjustments were to be made in the field to provide a 2Vp signal from the sensor to control at 1750 RPM. Sheet 3 of Drawing M-6067-2, "RHR Complex Cooling Tower Fan Overspeed Brake Installation," Revision A, stated the 2Vp signal could be measured across terminals 10 and 11 in the control box.
During testing, ESI informed the site that they could not get the switch to work at certain input voltages, which reinforced the design concept that voltage could affect the functionality of the switch at certain speeds/RPM. ESI modified the design, stating they were able to get the switch to work at certain voltages after they added a load resistor.
However, despite approved design drawings and a report from the vendor regarding limitations on the input voltages, post-installation checks and testing did not validate that, when installed in the plant, the appropriate voltage was present. The vendor-established range was unknown and therefore was not reconciled with the voltage described on design drawings, nor in calibration/test procedures which used a simulated voltage to test the circuit following installation. Additionally, guidance in licensee post-maintenance test procedure, MMA11, "Post-Maintenance Testing," was not followed. Specifically, MMA11 indicated that for maintenance performed on fans or their control circuitry, or electric switches, affected indication was to be checked. In this case, a failure to check the RPM meters (fed from the new switches) following installation resulted in a failure to recognize the inadequate design.
Corrective Actions: The licensee entered the issue into the corrective action program and performed a root cause evaluation.
Corrective Action References: 23-22040
Performance Assessment:
Performance Deficiency: 10 CFR 50 Appendix B, Criterion III, "Design Control," requires, in part, for those structures, systems, and components for which Appendix B applies, the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. The licensee implements these requirements through site procedures. Licensee procedure MES90, "Standard Design Process Interface," Revision 1, Section 3.5.2, requires design inputs and bounding technical requirements to be properly evaluated for design changes. The licensee did not evaluate voltage limitations stipulated on the design drawings nor provided by the vendor. Further, Section 3.5.7 requires post-modification testing to verify affected SSCs perform as intended following the engineering change. This section also states that types of testing are described in utility-specific procedures. Utility-specific procedure MMA11, "Post-Maintenance Testing Guidelines," Revision 27, outlines requirements for testing fans and electric switches following maintenance, and these requirements were not followed by the licensee.
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, a design change was implemented that resulted in all four MDCT's being rendered inoperable for the design basis tornado overspeed function.
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 inspectors utilized Exhibit 2 and answered 'yes' under Section B for external event mitigating systems. Using Exhibit 4, question 1, the inspectors answered 'yes' because the condition degraded 2 or more trains of a multi-train system (cooling tower circuits in both safety divisions were impacted). As a result, a detailed risk evaluation was performed to assess the significance. A Region III senior reactor analyst performed the evaluation and concluded the finding was assumed to result in the failure of all four MDCT fans during a design basis tornado. The total exposure period modeled was limited to one year, per SDP guidance, and was based on when the modifications were installed. The Division 1 switches were installed in December 2020 while the Division 2 switches were installed in September 2022. The condition was corrected in March 2023. The SRA used the current Standardized Plant Analysis Risk model (8.81) to analyze the finding. The change in core damage frequency (CDF) due to design basis tornadoes was estimated to be less than 1E-7/year. Therefore, the finding was determined to be of very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, Engineering Design Package 80072 was approved for installation more than three years ago.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, for those structures, systems, and components to which this appendix applies, the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Licensee procedure MES90, "Standard Design Process," Revision 1, states that for design change packages, post-modification testing is required to verify that affected SSCs perform as intended and reference the use of utility-specific procedures in developing post-modification tests.
Utility-specific procedure MMA11, "Post-Maintenance Testing Guidelines," Revision 27, states, in part, following maintenance on fans or electric switches, verify indications are as expected.
Design posting 80072.005 (planned revision to drawing E-6001-01, "Division 1 RHR Complex Cooling Towers Fan Overspeed Brake System)," Revision C, states that the sensor gap shall be field adjusted to provide a 2-volt peak signal to control at 1750 RPM.
Design drawing E-6001-02, "Division 2 RHR Complex Cooling Towers Fan Overspeed Brake System," Revision D, states that the sensor gap shall be field adjusted to provide a 2-volt peak signal to control at 1750 RPM.
Drawing M-6067-2, "RHR Complex Cooling Tower Fan Overspeed Brake Installation,
" Sheet 3, Revision A, stated the 2Vp signal could be measured across terminals 10 and 11 in the control box.
Contrary to the above, on December 9, 2020 (Division 1), and September 14, 2022 (Division 2), the licensee failed to verify or check the adequacy of design, by the performance design reviews or a suitable testing program, of the operating characteristics of the new mechanical draft cooling tower fan speed switches installed per Engineering Design Package 80072. Specifically, the licensee failed to verify the voltage present at the input to the speed switch aligned with information provided in design drawing E-6001-02, design posting 80072.005, and drawing M-6067-2. Additionally, once installed, the licensee did not verify the fan RPM indicators were reading appropriately with the fans in operation, contrary to Procedure MMA11.
In addition, Technical Specification 3.7.2 requires that two emergency equipment cooling water/emergency equipment service water subsystems and the ultimate heat sink be operable when the reactor is operating in modes 1, 2, and 3.
Contrary to the above, between December 9, 2020 and March 24, 2023, two emergency equipment cooling water/emergency equipment service water subsystems and the ultimate heat sink were not operable when the reactor was operating in modes 1, 2 and 3. Specifically, from December 9, 2020 to March 24, 2023, Division 1 of the ultimate heat sink (UHS) was inoperable due to an inoperable MDCTs fan overspeed braking circuit. In addition, from September 14, 2022, until March 24, 2023, Division 2 of the UHS was also inoperable due to an inoperable MDCT fan overspeed braking circuit.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Mechanical Draft Cooling Tower 'D' Inoperable due to High Vibrations URI 05000341/202300303 71153
Description:
On July 18, 2023, the 'D' MDCT tripped on high vibrations during routine operations while running in fast speed. The MDCTs provide cooling to the plant's UHS, which is used to cool safety-related equipment under accident conditions. Investigation revealed damage to the couplings which connect the fan motor to the main shaft and the main shaft to a gearbox which drives the fan. The condition rendered Division 2 of the UHS inoperable, prompting entry into technical specification (TS) actions for LCO 3.7.2, EECW/EESW System and UHS.
Specifically, action A.1. was entered, which required operability to be restored within
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 20, 2023, the inspectors presented the integrated inspection results to P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.
- On July 27, 2023, the inspectors presented the radiation protection inspection results to P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.
- On September 1, 2023, the inspectors presented the ISFSI cask loading inspection results to P. Dietrich, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.
Corrective Action References: CR 202331630 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If operability was not restored within that timeframe, TSs would require the plant to be shutdown. Further investigation by the licensee revealed one of the three bolts used to mount the gearbox had sheared apart. The licensee requested, and was subsequently approved for, a Notice of Enforcement Discretion (NOED) from the NRC to allow for repairs to be completed beyond the 72-hour TS allowed outage time (ML23206A127). Repairs were completed and the 'D' MDCT was restored to operable status on July 22, 2023. In accordance with the NRC Enforcement Manual, the inspectors opened an Unresolved Item to track further inspector review of the issue.
Planned Closure Actions: Further NRC inspection is required to determine if a performance deficiency exists, which will include a review of licensee corrective action documents associated with the issue. If a performance deficiency is identified, an assessment would then be made to determine if it is more than minor and whether a violation exists/existed.
Licensee Actions: The licensee entered the issue into the CAP and performed repairs to restore the 'D' MDCT to an operable status.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855
ALARA Plans
63.000.200
60855
Corrective Action
Documents
24382
Reevaluate VCT Loaded Safe Operating Wind Speed Limit
06/10/2019
60855
Corrective Action
Documents
22252
NEI Published NEI22-02: Guidelines for Weather-Related
Administrative Controls for Short Duration Outdoor Dry
Cask Storage Operations
2/21/2022
60855
Corrective Action
Documents
Resulting from
Inspection
2331304
NRC Identified - Administrative Error Found in
Section 4.4.1.1.2 of 10CFR72.212 Evaluation Report
06/30/2023
60855
Corrective Action
Documents
Resulting from
Inspection
2331492
ISFSI NRC Identified - Vacuum Drying System Valve Open
Longer than 1 Minute
07/10/2023
60855
Miscellaneous
053.000.10.160606
Fuel Characterization for Cycle 16 Fuel
60855
Miscellaneous
2 Eval Report
CFR 72.212 REPORT
60855
Miscellaneous
57.000.21
Fuel Inventory
60855
Miscellaneous
2.48 Screen
230032
Helium Mass Spectrometer Leak Test
60855
Miscellaneous
2.48 Screen
230069
2 Eval Report
60855
Miscellaneous
MPC 728
Composite Cask Load Report Campaign 4 Cask 04
60855
Miscellaneous
RRTI 33370001
Tornado Wind / Missile Evaluation of Transient Cask
Configurations at Fermi
60855
NDE Reports
918622728-01
Root Layer NDE Report - Cask 728
06/29/2023
60855
Procedures
35.710.042
Multipurpose Canister (MPC) Loading
60855
Procedures
35.710.043
Blowdown, Drying, Sealing and Backfill of the MPC
60855
Procedures
35.710.058
HI-Storm Lifting Beam Inspection
0A
60855
Procedures
GQP9.2
High-Temperature Liquid Penetrant Examination and
Acceptance Standards for Welds Base Materials and
Cladding (50° - 350°F)
60855
Procedures
MSLT-MPC-
Helium Mass Spectrometer Leak Test
366502
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
HOLTEC
60855
Procedures
WIRPO047
Work Instruction for ISFSI RP Job Coverage
60855
Radiation
Surveys
PM202212143
SA-94 ISFSI Cask Pad
2/14/2022
60855
Radiation
Surveys
PM2023060711
Tech Spec MPC Contamination Survey
06/07/2023
60855
Radiation
Surveys
PM202307101
ISFSI Tech Spec MPC Contamination Survey
07/12/2023
60855
Work Orders
2427674
Perform 35.710.055 HI-Storm Monthly Screen Inspection
2/22/2023
60855
Work Orders
64134238
Neil Required/License Renewal-RB Overhead Crane PM
Inspections
01/23/2023
60855
Work Orders
64134279
Neil Required - Perform 'F' Frequent Inspection per
MIOSHA R408.11872 RULE 1872 (2) (A)
04/17/2023
60855
Work Orders
66744741
Neil Required HI-Storm Lifting Bracket Inspection
10/26/2022
60855
Work Orders
66744816
HI-Trac Lift Yoke Inspection
04/04/2023
60855
Work Orders
66745255
HI-Storm Lift Beam Inspection
10/26/2022
Procedures
23.420
RHR Complex Heating and Ventilation
Corrective Action
Documents
CR202332065
Fire Protection Events Past Critical
08/02/2023
Corrective Action
Documents
Resulting from
Inspection
2332232
NRC Identified Door Issues at RHR
08/10/2023
Corrective Action
Documents
Resulting from
Inspection
2332243
NRC Identified: Expired Fire Extinguisher Service Tags in
RHR Complex
08/10/2023
Corrective Action
Documents
Resulting from
Inspection
2332376
NRC Identified: Expired Transient Combustible Permit on
RB1
08/17/2023
Corrective Action
Documents
Resulting from
2332379
NRC Identified: Equipment Staged on "Fire Equipment Do
Not Block" Sticker
08/17/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
Corrective Action
Documents
Resulting from
Inspection
2332386
NRC Identified: Sprinkler Head in Contact with Hoist Above
MLO Tank
08/17/2023
Drawings
6A7212400
Fire Protection Evaluation Plot Plan
Q
Drawings
6A7212401
Fire Protection Evaluation Reactor Building
Subbasement - Plan - El. 540' 0"
L
Drawings
6A7212403
Fire Protection Evaluation Reactor and Auxiliary Buildings
First Floor - Plan - El. 583' 6"
T
Fire Plans
FPAB16a
Auxiliary Building Cable Tray Area North
Fire Plans
FPAB16b
Auxiliary Building Cable Entry Room Zone 6
Fire Plans
FPAB16c
Auxiliary Bridling Cable Tray Area South Zone 6
Fire Plans
FPAB16d
Auxiliary Building 1st Floor Mezzanine Zone 6
Fire Plans
FPAB29C
Auxiliary Building Cable Tunnel Zone 9
Fire Plans
FPABM11
Auxiliary Building Cable Spreading Room Zone 11
Fire Plans
FPABM9A
Auxiliary Building Second Floor Mezzanine Zone 9A
Fire Plans
FPAB314e
Auxiliary Building, Division II Switchgear Room, Zone 14,
El. 643'6"
Fire Plans
FPRB17a
Reactor Building North Control Rod Drive (CRD) Area,
Zone 7, El. 584'6"
Fire Plans
FPRB17b
Reactor Building South CRD and Railroad Bay Area, Zone
Fire Plans
Reactor Building Basement Southeast Corner Room, Zone
4, El. 562' 0"
Fire Plans
FPRHR112-EDG
Fire Plans
FPRHR114-EDG
RHR Complex, EDG 14 Room, El. 590' 0"
Fire Plans
FPRHR114-OS
RHR Complex, EDG 14 Oil Storage Room, El. 590' 0"
Fire Plans
FPRHR253
RHR Complex, EDG 12 Switchgear and Switchgear
Ventilation Rooms
Fire Plans
FPTB
Turbine Building
Miscellaneous
LPFP94001YX
Fire Drill/Evaluation: Hydrogen Seal Oil Unit, 2nd Floor
Turbine Building
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
28.502.12
Fire Protection/Detection Operability Test Zone 9A-Cable
Tray Area Aux Building 2nd Floor Mezzanine
Procedures
28.503.05
Halon Fire Suppression System Functional Test Zone
11-Cable Spreading Room
Procedures
28.503.08
Fire Protection/Detection Operability Test Zone 11-Cable
Spreading Room Aux. Building
Procedures
28.505.09
Fire Detection Zone 9 Operability Test Aux Building 2nd
Floor
Procedures
28.505.09A
Fire Detection Zone 9A Operability Test AB 2nd Mezzanine
Cable Tray Room-BOP
Procedures
28.505.11
Fire Detection Zone 11 Operability Test AB 2nd Floor
Mezzanine Cable Spreading Room-BOP
Procedures
28.506.06
CO2 Fire Suppression System Functional Test Zone
9A-Auxiliary Building 2nd Floor Mezzanine Cable Tray Area
Operability
Evaluations
TEP4423-049
Division 1 EECW Heat Exchanger Plugging Past
Operability Evaluations
71111.11Q Miscellaneous
57.000.22
A
Load Profile Plan: July 2023 Maintenance Down power
Corrective Action
Documents
21894
East HFP discharge check valve failure
03/27/2009
Corrective Action
Documents
2331974
NQA Condensate Pump Motor Winding Temperature
Impacts to Maintenance and Monitoring Strategy
07/31/2023
Corrective Action
Documents
2332000
N2000-F146A East HFP Discharge Check Valve Failure
07/31/2023
Engineering
Evaluations
TEU2223-050
Shield Blocks Removal for C Condenser Pump Motor
Replacement
Miscellaneous
Fermi 2 Safety
Handbook
Section 25-Job
Hazard Analysis
Replace Center Condenser Pump Motor
07/26/2023
Procedures
23.155
Condenser Vacuum System
Procedures
MWC15
Work Control Conduct Manual: Elevated Risk Management
Procedures
MWC18
Work Control Conduct Manual: Emergent Issues Response
10/06/2023
Work Orders
65824705
Drywell Entry and Leakage Identification
08/16/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
68936657
B31R621B-Replace Speed Controller
07/13/2023
Corrective Action
Documents
2331630
MDCT D fan tripped
07/20/2023
Corrective Action
Documents
2332431
PO 23-01 Shut Down Walkdown - E5150F008 RCIC Valve
Steam Leak
08/21/2023
Corrective Action
Documents
2332487
PO 23-01 E5150F008 As-Found Thrust Test and Inspection
Results
08/22/2023
Corrective Action
Documents
CARD1824869
EDG 11 Governor Oil Level High
06/22/2018
Corrective Action
Documents
CARD1825541
Inadequate Technical Rigor Regarding EDG 11 Governor
Oil Level
07/20/2018
Corrective Action
Documents
CARD1920385
NRC Violation-Failure to Apply Torque Values Described in
Maintenance Procedure for Flexible Couplings on EDG 12
01/17/2019
Corrective Action
Documents
CARD1921025
Oil identified on EDG 12 Auxiliary Skid Below R3000F123C
2/11/2019
Corrective Action
Documents
CARD2230749
10/31/2022
Corrective Action
Documents
CR202331488
EDG 12 Governor Oil Level Low in Band
07/10/2023
Drawings
5M7216015
4" 900# O.S.Y. Powell O.S.Y. Gate Valve with Limitorque
Operator
Engineering
Evaluations
EQ1EF2044
Qualification Evaluation Report (QER); Limitorque
J
Engineering
Evaluations
Log. No. 06054
Appendix J - Generic Letter 89-10 Correlation (Retest
Guidelines for Appendix J Valves)
Miscellaneous
NRC230049
Fermi Letter Requesting Enforcement Discretion for
Technical Specification 3.7.2, EECW/EESW System and
07/21/2023
Work Orders
270880
E5150F008 Repack / Possible Damage to Valve Stem
08/28/2023
Work Orders
286422
E5150F008 RCIC TURB STM SPLY OTBD CNTM ISO
08/28/2023
Corrective Action
Documents
2331674
Gearbox Hold Down Bolt Found Separated due to
Corrosion
07/20/2023
Corrective Action
2331707
Original Installation of the MDCT Gearbox Mounting is Not
07/21/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
in Accordance with Installation Drawings
Corrective Action
Documents
Resulting from
Inspection
2333153
Shop Work Order Needed for Anchor Bolt Testing
09/20/2023
Corrective Action
Documents
Resulting from
Inspection
2333264
Design Equivalent Change 700015 (Repair Damaged
Anchor Bolt for D MDCT) Did Not Contain Sufficient
Technical Detail
09/25/2023
Miscellaneous
Design Equivalent
Change Package
700015
Repair Damaged Anchor for E1156B002B (MDCT D Gear
Reducer)
Miscellaneous
Document No.
38021.009LR-001
Acceptability Assessment of Weld Repair to Fan Support
Anchor Bolt
09/21/2023
Miscellaneous
EDP700015.002
Mechanical Draft Cooling Tower Fan D Anchorage Detail
M
Work Orders
68994737
Repair the MDCT Fan D Gearbox Pedestal and Footing
Calculations
DC3603
DCD Volume: Pipe Stress for Line 6DI-B31-7255-1
Calculations
DC3603
Pipe Stress Analysis RRS Loop 3 Instrumentation Line
CTB316018
Corrective Action
Documents
23734
RPS-A EPA Breaker Found Tripped
04/19/2017
Corrective Action
Documents
2332654
Unsatisfactory Acceptance Criteria While Meggering
Recirculation 'B' Pump Motor B3103C001B
08/30/2023
Corrective Action
Documents
2332844
Refuel Floor High Radiation Airborne Event
09/06/2023
Corrective Action
Documents
2332852
Spent Fuel Pool Gate Leaking at 20 Drops per Minute
09/06/2023
Corrective Action
Documents
2332853
Airborne Activity on the Refuel Floor
09/06/2023
Corrective Action
Documents
25400
Spent Fuel Pool Gate Leaking at 20 Drips per Minute
04/20/2022
Corrective Action
Documents
2332813
NRC Identified - Observations during Head Lift on Refuel
Floor
09/05/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Corrective Action
Documents
Resulting from
Inspection
2332818
NRC Identified Observation: Hands on Load/FME Area
Establishment
09/05/2023
Drawings
Drywell Instrumentation Isometric Piping from B31L018 to
Penet X-29 Reactor Building Drywell
F
Drawings
6I7212045-57
Internal -External Wiring Diagram Inboard Valve Relay Cab
H11P622 Part 1 Division 1
Drawings
6I7212101-02
Schematic Diagram Recirculation Pump MG Set 'B' Drive
Motor B3103S001B
X
Drawings
6I7212101-04
Schematic Diagram Recirculation Pump Discharge Valve
B3105P031B
Drawings
6I7212101-10
Schematic Diagram Recirculation Pump B3101C001A
X
Drawings
6I7212151-01
Schematic Diagram Reactor Protection System
Drawings
6I7212151-02
Schematic Diagram Reactor Protection System
Z
Drawings
6I7212201-17
Schematic Diagram RHR Loop 'B' Recirculation INBD
Isolation Valve E1150F015B
P
Drawings
6I7212221-05
Schematic Diagram HPCI System - Pump Discharge
Isolation Valves E4150F006 and F007
Drawings
6I7212225-03
Schematic Diagram HPCI System Logic Circuit Pt 1
Drawings
6M7212035
HPCI Reactor Building
Drawings
6M7212083
Diagram RHR Division 2
Drawings
6M7212089
System Diagram Nuclear Boiler System
BP
Drawings
6M7212090
System Diagram Nuclear Boiler System
Drawings
6M7212833
Diagram Reactor Recirculation System Nuclear Boiler
System
AK
Drawings
6M7215702-1
Reactor Recirculation System Nuclear Boiler System
Functional Operating Sketch
Z
Drawings
6M7215708-1
High Pressure Coolant Injection System Functional
Operating Sketch
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
6M7215711-1
Reactor Water Cleanup Reactor Building Functional
Operating Sketch
Drawings
6M7215726
General Service Water System Functional Operating
Sketch
CG
Drawings
761E214
Recirculation Loop
Engineering
Changes
80047
Installation of Jet Pump Nozzle Plugs [PROPRIETARY]
Miscellaneous
Pressure and Temperature Limits Report [Confidential]
06/08/2020
Miscellaneous
FME Project Plan
Miscellaneous
N6661
Cases of ASME Boiler and Pressure Vessel Code
03/13/2012
Miscellaneous
ODE2
Operations Evolution Order
Miscellaneous
SHIC3310501-
001
B31 Reactor Recirculation System
Miscellaneous
TEB3123-056
Evaluation of Drywell Leak in Sampling Instrumentation
Line at Reactor Recirculation Header B31L018
Miscellaneous
TEP8023-060
TRLO 3.0.4(b) Mode Change Restraint Assessment While
Diesel Fire Pump Inoperable
Miscellaneous
TEP8023-060
TRLCO 3.0.4(b) Mode Change Restraint Assessment While
Diesel Fire Pump Inoperable
Procedures
20.205.01
Loss of Shutdown Cooling
Procedures
20.300.RPSB
Loss of RPS 'B'
Procedures
2.000.02
Plant Startup to 25 Percent Power
110
Procedures
2.000.04
Plant Shutdown From 25 Percent Power
Procedures
23.205
Residual Heat Removal System
149
Procedures
23.316, Att. 5A
Shutdown Cooling Isolation Defeat RPS Bus 'B'
Procedures
23.316, Enclosure
B
RPS Bus 'B'-Affected Equipment List
Procedures
23.316, Enclosure
C
RPS Bus 'A'-Trips
Procedures
23.623
Reactor Manual Control System
Procedures
24.137.21
Reactor Pressure Vessel System Leakage Test
Procedures
35.710.016
Installation and Removal of the Jet Pump Nozzle Plugs
Procedures
2.610.04
Division 2 Normal Supply Reactor Protection System (RPS)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Electrical Protection Assembly Calibration/Functional Test
Procedures
2.610.04
EPA Channel Functional Test and Completion of Channel
Calibration
Procedures
43.000.005
Visual Examination of Piping and Components (VF2)
Procedures
MMA17
Foreign Material Exclusion (FME)
Procedures
MMA17200
Refuel Floor FME Plan
Procedures
MMR App H
Online Core Damage Risk Management Guidelines
Procedures
MMR12
Equipment out of Service Risk Management
20A
Work Orders
274384
Repair Leak on Reactor Recirc Sample Line Tap, B31L018
08/20/2023
Work Orders
284233
B31L018 - Weld Repair (Socket)
08/21/2023
Work Orders
289464
Installation and Removal of Jet Pump Nozzle Plugs
08/22/2023
Work Orders
69301002
Replace S1 and S2 Keylock Switches, EPA Breaker, GE
Cable Assembly and Tefzel Wiring of RPS 'B'
08/23/2023
Work Orders
69301002
Replace S1 and S2 Keylock Switches, EPA Breaker, GE
Cable Assembly and Tefzel Wiring of RPS 'B'
08/23/2023
Work Orders
69372412
Leak From GSW Header on TB1 East Aisle/Temp Repair
08/31/2023
Corrective Action
Documents
2332470
Signs of Recirc Sample Line Movement in Pipe Guides
09/07/2023
Corrective Action
Documents
2332513
RF22 Work Request - Address 6DI-B31-7255-1 RRC Chem
Sample Line Vibration
09/07/2023
Miscellaneous
8MNGTAW/SMAW
ASME Section IX Welding Procedure Specification
Miscellaneous
TEB3123-057
Justify Continued Operation until RF22 After Leak
Restoration at Reactor Recirculation Header B31L018
Procedures
24.307.16
Emergency Diesel Generator 13-Start and Load Test
Procedures
24.307.37
DGSW, DFOT, and Starting Air Operability Test-EDG 14
Procedures
64991108
Perform 24.307.16 Sec. 5.2 EDG 13 Start and Load
Test-Fast Start
09/14/2023
Work Orders
64556944
Perform 24.307.37 Sec. 5.1 & 5.2 DGSW & DFOT
Pump/VLV Operability Test-EDG 14
08/15/2023
Work Orders
274384
Repair Leak on RR Sample Line Tap
08/30/2023
Corrective Action
Documents
26965
Commitment Tracking CARD for NEI 07-07
08/11/2010
Corrective Action
24718
Vendor Incorrectly Processed Radiological Environmental
05/28/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Monitoring (REMP) Samples Prior to Analysis
Corrective Action
Documents
24831
Instrument QC Check Performance Not in Line with MCE04
Requirements
06/02/2021
Corrective Action
Documents
24876
REMP Samples Mislabeled
06/03/2021
Corrective Action
Documents
Resulting from
Inspection
2331933
Minor Administrative Typographical Errors in 2022 AREOR
07/27/2023
Corrective Action
Documents
Resulting from
Inspection
2331939
Evaluate Improvements to the REMP Air Sampling
Enclosures Located Outside the Protected Area
07/27/2023
Corrective Action
Documents
Resulting from
Inspection
2331940
Provide Enclosure for REMP TLD Locations Outside the
Protected area
07/27/2023
Miscellaneous
21 Annual
Radioactive
Effluent Release
Report
Annual Radioactive Effluent Release Report for the Period
of January 1, 2021 through December 31, 2022
21
Miscellaneous
21 Annual
Radiological
Environmental
Operating Report
Annual Radiological Environmental Operating Report for
the Period of January 1, 2021 through December 31, 2021
21
Miscellaneous
22 Annual
Radioactive
Effluent Release
Report
Annual Radioactive Effluent Release Report for the Period
of January 1, 2022 through December 31, 2022
22
Miscellaneous
22 Annual
Radiological
Environmental
Operating Report
Annual Radiological Environmental Operating Report for
the Period of January 1, 2022 through December 31, 2022
22
Miscellaneous
NAQA232022
Audit Report for the DTE Audit of Environmental Dosimetry
05/23/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Company (DTE Audit No. 23001)
Miscellaneous
Technical
Requirements
Manual Volume II
Offsite Dose
Calculation Manual
Offsite Dose Calculation Manual
Procedures
2.000.301
Low Flow Groundwater Sampling
Procedures
2.000.302
Groundwater Gauging
Procedures
MES68
Groundwater Protection Program Structures, Systems, and
Components Review
2C
Procedures
MRP30
Integrated Groundwater Protection Program
Procedures
WIRPT011
Work Instruction for Voluntary Groundwater Reporting
Requirements
Self-Assessments
22 Annual
Quality Assurance
Report for the
Radiological
Environmental
Program (REMP)
GEL Laboratories Quality Assurance Review
03/17/2023
Self-Assessments
NPRP230014
Quick Hit Self-Assessment: Radiological Environmental
Monitoring Program
03/23/2023
Work Orders
285529
Perform 67.000.104 Review of Site Map Showing Areas for
Handling Licensed Material
11/10/2021
Work Orders
2:000:210
Water Sampler Weekly Flow Check and Preventive
Maintenance for June of 2023
07/03/2023
Work Orders
64012645
Perform 64.713.019 Att. 17 Gaseous Effluent Cumulative
and Projected Dose (Monthly)
06/19/2023
71151
Corrective Action
Documents
Resulting from
Inspection
2333161
NRC Identified - August 2022 RHR/RHRSW/MDCT
Performance Indicator (Unavailability) Report
Discrepancies
09/19/2023
71151
Miscellaneous
Selected Operators' Narrative Logs
Various
71151
Miscellaneous
RHR Performance Indicators
Various
71151
Miscellaneous
RCIC Performance Indicators
Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71151
Work Orders
61351087
Perform 44.020.232 NS4 RCIC Steam Line Flow, Trip Sys
B, Functional Test
11/03/2022
71151
Work Orders
63562414
Perform 44020.231 NS4 RCIC Steam Line Flow, Trip Sys
A, Functional Test
05/09/2023
Corrective Action
Documents
2330775
RCE 23-22040-Speed Switch Drawing Corrections
06/13/2023
Corrective Action
Documents
22040
Lost Indication of D MDCT Fan in High-Speed
03/17/2023
Drawings
4M7216067-2
RHR Complex Cooling Tower Fan Overspeed Brake
Installation Sheet 3 of 4
A
Drawings
5E7216001-02
Wiring Diagram RHR Complex Division 2 Cooling Towers
Fan Overspeed Brake System
A
Engineering
Changes
80072
MDCT Fan Brake Overspeed Circuit Design Change
D
Miscellaneous
Purchase Order Change
03/16/2012
Miscellaneous
Purchase Order Change
07/13/2019
Miscellaneous
P1
Quality Assurance Procurement Specification-Nuclear
Safety-Related
N
Procedures
MES07
Review, Approval, and Control of Vendor Design
Documents
Procedures
MES90
Standard Design Process Interface
Procedures
MMA11
Post-Maintenance Testing Guidelines
Procedures
MMM02
Procurement Process
Procedures
MMM11
Dedication of Commercial Grade Items
18A