IR 05000341/2019002

Integrated Inspection Report 05000341/2019002 and 07200071/2019001

ML19210D343
Person / Time
Site:	Fermi, 07200071
Issue date:	07/26/2019
From:	Eric Duncan Reactor Projects Region 3 Branch 4
To:	Fessler P DTE Energy
References
IR 2019001, IR 2019002
Download: ML19210D343 (27)

Text

uly 26, 2019

SUBJECT:

FERMI POWER PLANT, UNIT 2INTEGRATED INSPECTION REPORT 05000341/2019002 AND 07200071/2019001

Dear Mr. Fessler:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fermi Power Plant, Unit 2. On July 9, 2019, 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.

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

If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Fermi. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Eric R. Duncan, Chief Branch 4 Division of Reactor Projects Docket Nos.: 05000341 and 07200071 License No.: NPF-43

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000341 and 07200071 License Number: NPF-43 Report Numbers: 05000341/2019002 and 07200071/2019001 Enterprise Identifiers: I-2019-002-0058 and I-2019-001-0111 Licensee: DTE Electric Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Inspection Dates: April 1, 2019 to June 30, 2019 Inspectors: S. Bell, Health Physicist T. Briley, Senior Resident Inspector N. Fields, Health Physicist V. Myers, Senior Health Physicist J. Nance, Resident Inspector R. Ng, Project Engineer J. Rutkowski, Project Engineer T. Taylor, Resident Inspector Approved By: Eric R. Duncan, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY

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

List of Findings and Violations Failure to Verify the Adequacy of the Design of the Reactor Building to Suppression Chamber Vacuum Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green None (NPP) 71153 NCV 05000341/2019002-01 Open/Closed A finding of very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified by the inspectors when the licensee failed to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves automatically closed upon increasing torus pressure and remain closed during all containment high pressure conditions. Specifically, during various loss of offsite power (LOP) and loss of coolant accident (LOCA) scenarios, the butterfly valves would not close automatically without manual operator action.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000341/2018-007-00 LER 2018-007-00 for Fermi, 71153 Closed Unit 2, Reactor Building to Suppression Chamber Vacuum Breaker Condition Prohibited by Technical Specifications LER 05000341/2019-002-00 LER 2019-002-00 for Fermi 2, 71153 Closed Secondary Containment Airlock Doors Opened at the Same Time Resulting in a Condition Prohibited by Technical Specifications

PLANT STATUS

Unit 2 operated at or near rated thermal power during the entire inspection period with the exception of power changes to perform planned rod pattern adjustments.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.03)

(1) The inspectors evaluated the sites readiness for high winds potentially affecting lake level on April 11 and April 12, 2019

Summer Readiness Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the summer readiness of offsite and alternate alternating current (AC) power systems

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01)

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

(1) Reactor Core Cooling Injection system while the High Pressure Coolant Injection (HPCI) system was out-of-service for planned surveillance testing during the week ending May 25, 2019

(2) Division 1 Non-Interruptible Air System (NIAS) during planned maintenance on Division 2 NIAS during the week ending May 25, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the HPCI system during the week ending April 6, 2019

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Reactor Building First Floor, South Hydraulic Control Unit and Railroad Bay Area on April 10, 2019

(2) Reactor Building Fourth Floor, Standby Liquid Control Area on April 10, 2019

(3) General Service Water (GSW) Pump House during the week ending April 13, 2019

(4) Residual Heat Removal (RHR) Complex, Emergency Diesel Generator (EDG) 13 Room on April 24, 2019

(5) RHR Complex, EDG 11 Room on April 24, 2019

(6) Circulating Water (CW) Pump House during the week ending April 27, 2019

71111.06 - Flood Protection Measures

===Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Partial)

The inspectors evaluated internal flooding mitigation protections in the:

• Torus Room during the week ending June 29, 2019

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) The inspectors observed and evaluated licensed operator performance in the control room during a Recirculation System Digital Control System (DCS) module replacement during the week ending May 18, 2019

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Reactor Protection System (RPS) during the week ending April 13, 2019

(2) Reactor Recirculation System during the week ending April 27, 2019

(3) Primary Containment Isolation functions during the week ending May 18, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Planned Recirculation System DCS module replacement during the week ending May 4, 2019

(2) Emergent Independent Spent Fuel Storage Installation (ISFSI) Cask 1 dye penetrant testing and gas monitoring within the time-to-boil period during the week ending June 8, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations or functionality assessments:

(1) Operability and functionality of the condensate storage tank, associated tank level instrumentation, and connected systems following the identification of the potential for vortex conditions at low tank levels, as documented in Corrective Action Resolution Document (CARD) 19-23227

71111.19 - Post-Maintenance Testing

Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Reactor Water Cleanup (RWCU) isolation circuit timer following emergent maintenance during the week ending April 6, 2019

(2) Division 2 RHR Pump D Suppression Pool Suction Motor-Operated Valve (E1150-F004D) following planned maintenance during the week ending May 25, 2019

(3) 24/48 Volt Battery Charger 2IB-1 following emergent maintenance during the week ending June 1, 2019

(4) Division 2 RHR Pump B discharge pressure trip unit following emergent maintenance during the week ending April 13, 2019

71111.22 - Surveillance Testing

===The inspectors evaluated the following surveillance tests:

Inservice Testing (IP Section 03.01)===

(1) HPCI pump and valve operability test at 1025 pounds per square inch (psi) during the week ending May 26, 2019

Surveillance Tests (Other) (IP Section 03.01) (6 Samples)

(1) EDG 11 fast start and load test during the week ending April 12, 2019

(2) Division 1 Emergency Core Cooling System (ECCS) Reactor Vessel Water Level 2, Anticipated Transient Without Scram (ATWS)-Recirculation Pump Trip (RPT)functional test during the week ending April 12, 2019

(3) EDG 12 - Diesel Generator Service Water, Diesel Fuel Oil transfer, and Starting Air Compressor valve operability test on May 16, 2019

(4) Division 1 Standby Gas Treatment filter performance test during the week ending May 25, 2019

(5) Reactor Pressure Vessel Jet Pump 11 flow/pressure indication loop calibration on May 14, 2019

(6) Division 1 RHR Cooling Tower Fan Operability and RHR Service Water (RHRSW)valve line-up verification on May 15, 2019

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) The inspectors observed and evaluated an Emergency Preparedness Drill that was conducted on May 21,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02)

(1) The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

• Radwaste effluent radiation monitor

• Circulating Water System decant line effluent radiation monitor

• Onsite Storage Facility effluent radiation monitor

Dose Calculations (IP Section 02.05) (1 Sample)

The inspectors reviewed the following discharge permits to evaluate public dose calculations:

• Vent of primary containment on November 16, 2018 The inspectors also reviewed the following annual radiological effluent release reports:

• 2017 Annual Report

• 2018 Annual Report Abnormal gaseous or liquid tank discharges

• No abnormal gaseous or liquid tank discharges were available for review during this inspection

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed the following radioactive effluent discharge system surveillance test results:

(1) Standby Gas Treatment system

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed the following radioactive effluent sampling and analysis activities:

• Standby Gas Treatment effluent sampling

• Reactor Building effluent sampling

• Onsite Storage Facility effluent sampling Effluent discharges with inoperable monitors

• Reactor Building

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

• Division 1 Standby Gas Treatment System

• Division 2 Standby Gas Treatment System

• Reactor Building Ventilation System

• Onsite Storage Facility Ventilation System

71124.07 - Radiological Environmental Monitoring Program

Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)

(1) The inspectors assessed the implementation of the groundwater protection initiative

Site Inspection (IP Section 02.01) (1 Sample)

(1) The inspectors evaluated the radiological environmental monitoring program implementation Walkdowns and calibration and maintenance record review

• Air Sampling Station API-1, Estral Beach

• Air Sampling Station API-2, Site Boundary North North West

• Air Sampling Station API-3, Site Boundary North West

• Air Sampling Station API-5, Site Boundary South

• Air Sampling Station API-6, Site Boundary West North West

• Dosimeter Monitoring Station T12, Pointe Mouille Game Area

• Dosimeter Monitoring Station T22, North Side of Pointe Aux Peaux

• Dosimeter Monitoring Station T23, South Side of Point Aux Peaux

• Dosimeter Monitoring Station T25, Toll Road The inspectors observed the following environmental sample collection and preparation:

• Milk Sampling Location M-8, Calder Dairy Licensee actions in response to missed sample, inoperable sampler, lost dosimeter, or anomalous measurement

• 2017 first quarter dosimeter location T-7 found missing

• 2017 third quarter dosimeter location T-37 found missing

• 2017 fourth quarter dosimeter location T-37 found missing

• 2018 first quarter dosimeter location T-47 found missing Sampling program for the potential of licensed material entering groundwater

• Condensate Storage Tank

• Condensate Return Tank

• U2100 Cable Vault

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified the licensee performance indicators submittals listed below:

BI02: RCS Leak Rate Sample (IP Section 02.11) ===

(1) Unit 2 (April 1, 2018 - March 31, 2019)

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) Unit 2 (April 1, 2018 - March 31, 2019)

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) Unit 2 (April 1, 2018 - March 31, 2019)

71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000341/2018-007-00, Reactor Building to Suppression Chamber Vacuum Breaker Condition Prohibited by Technical Specifications (ADAMS Accession ML19036A741). The circumstances surrounding this LER are documented in the Inspection Results Section of this report.

(2) LER 05000341/2019-002-00, Secondary Containment Airlock Doors Opened at the Same Time Resulting in a Condition Prohibited by Technical Specifications (ADAMS Accession ML19112A331). The circumstances surrounding this LER are documented in the Results Section of Integrated Inspection Report

===05000341/2019001 (ADAMS Accession ML19130A097)

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants ===

(1) The inspector evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading from June 17 through June 21, 2019. Specifically, the inspector observed the following activities:

• Stack-Up and download of Multi-Purpose Canister (MPC)-596 from the transfer cask (HI-TRAC) to the storage cask (HI-STORM) at the Cask Transfer Facility (CTF)

• Removal of the loaded HI-STORM and MPC-596 from the CTF for transport to the ISFSI pad

• Heavy load movement of the HI-TRAC and empty MPC-587 up through the refuel floor hatch into the Dryer Separator Pit (DSP)

• Loading spent fuel into MPC-587

• Heavy load movement of the HI-TRAC and loaded MPC-587 out of the spent fuel pool into the DSP

• Post-hydro dye penetrant weld evaluation for MPC-587

• Blowdown, vacuum drying, and helium backfill evolutions for MPC-587

• Radiological technical specification and general area surveys The inspector performed a walkdown of the ISFSI pad, including independent radiation surveys, and a walkdown of the ISFSI haul path.

The inspector evaluated the following:

• Spent fuel selection for the 11 casks in the loading campaign

• Selected CARDs

• Selected 10 CFR 72.48 screenings and evaluations

• The licensees change in Certificate of Compliance (CoC) loading amendment from Amendment 5 to Amendment 10, including a change in MPC type from MPC-68 to MPC-68M

INSPECTION RESULTS

Failure to Verify the Adequacy of the Design of the Reactor Building to Suppression Chamber Vacuum Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green None (NPP) 71153 NCV 05000341/2019002-01 Open/Closed A finding of very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified by the inspectors when the licensee failed to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves automatically closed upon increasing torus pressure and remain closed during all containment high pressure conditions. Specifically, during various loss of offsite power (LOP) and loss of coolant accident (LOCA) scenarios, the butterfly valves would not close automatically without manual operator action.

Description:

The reactor building to suppression chamber vacuum breakers consist of a power-to-close, spring-to-open butterfly isolation valve and a testable check valve in series. The function of the reactor building to suppression chamber vacuum breakers is to relieve vacuum when primary containment depressurizes below reactor building pressure. In addition, the two vacuum breakers in series (butterfly valve and check valve) must be closed to maintain a leak tight primary containment boundary. In accordance with Fermis Updated Final Safety Analysis Report (UFSAR), the butterfly valves are normally closed and open automatically to prevent formation of a negative pressure in the torus. The butterfly valves close automatically upon increasing torus pressure and remain closed during all containment high pressure conditions.

On December 8, 2018, while in Mode 4 (cold shutdown), the licensee identified a legacy design issue since initial power operation on January 23, 1988, in the control logic circuitry for the reactor building to suppression chamber vacuum breakers that prevented automatic closure of the butterfly isolation valves following power restoration from a LOP event. The reactor building to suppression chamber vacuum breaker check valves were not impacted by the design issue and therefore there was no loss of safety function. Procedural guidance was available to manually close the butterfly valves from the main control room following a LOP event.

On February 2, 2019, the licensee submitted LER 05000341/2018-007-00 (ADAMS Accession ML19036A741) to the NRC in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition which was prohibited by the plants Technical Specifications.

Technical Specification (TS) 3.6.1.7, Reactor Building-to-Suppression Chamber Vacuum Breakers, requires, in part, that each reactor building to suppression chamber vacuum breaker shall be operable in Mode 1, 2, and 3. As a consequence of this design control issue, the licensee declared that the reactor building to suppression chamber vacuum breaker butterfly valve in each line had been inoperable since initial power operation whenever the reactor was in Modes 1, 2, or 3. LCO 3.6.1.7 did not include any associated actions for the condition (failure to reclose following restoration of power), which placed the licensee in LCO 3.0.3, which required the licensee to place the reactor in Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and Mode 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Since the licensee was not previously aware of the condition of the valve, the actions required by LCO 3.0.3 were not taken.

Although the design issue was identified by the licensee during an engineering evaluation of an unrelated issue associated with LOP/LOCA conditions, the inspectors identified inadequacies in the licensees characterization and evaluation of the issue of concern. Specifically, the licensee failed to document in their evaluation of the design issue why it was not identified during or in the years following original plant construction nor during periodic functional testing of the reactor building to suppression chamber vacuum breakers. In addition, the past operability evaluation was generic in nature stating that TS LCO 3.6.1.7 was not met (i.e. inoperable), but did not recognize that LCO 3.0.3 applied, and also was not met. When questioned by the inspectors, the licensees proposed TS actions did not involve TS LCO 3.0.3, which would have been required while the plant operated in Mode 1, 2, or 3 with the butterfly valves in their normally closed position. Therefore, the finding was considered NRC-Identified.

The licensees corrective action program ownership screening committee and management review committee both determined a formal causal evaluation was not necessary. Therefore, a qualitative description of the event stated the cause was a legacy design issue with a supporting technical justification. The design issue was corrected through a physical plant modification that included a post-maintenance functional test (open and close valve strokes)and a one-time post-maintenance test that consisted, in part, of removing and re-installing control power fuses to verify the butterfly isolation valves functioned as designed. The licensee did not document an evaluation of the effectiveness of past and present functional testing procedures until questioned by the inspectors. The inspectors determined current, post-modification reactor building to suppression chamber vacuum breaker functional test procedures (to open and close the butterfly valves) were adequate to verify automatic closure of the butterfly valves following power restoration from a LOP event.

Corrective Actions: A physical modification was implemented to re-wire the manual override portion of the vacuum breaker butterfly isolation valve control circuits so that the butterfly isolation valves would automatically re-close following the restoration of electrical power following a LOP event.

Corrective Action References: CARD 18-29870

Performance Assessment:

Performance Deficiency: The failure to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves close automatically upon increasing torus pressure and remain closed during all containment high pressure conditions (specifically following a restoration of electrical power)was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone. Specifically, the reactor building to suppression chamber vacuum breaker butterfly isolation valves would not automatically close following a LOP event in order to perform their containment isolation function during all containment high pressure conditions.

Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The inspectors concluded the issue was of very low safety significance (i.e., Green) based on answering No to Exhibit 3 Barrier Integrity Screening Questions B.1 and B.2.

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.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that 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 calculation methods, or by performance of a suitable testing program. Fermi UFSAR Table 6.2-2, Note 24 states, in part, that each reactor building to suppression chamber butterfly valve is normally closed and opens automatically to prevent formation of a negative pressure in the torus and that the butterfly valve closes automatically upon increasing torus pressure and remains closed during all containment high pressure conditions.

Technical Specification LCO 3.6.1.7 requires that each reactor building to suppression chamber vacuum breaker be operable in Mode 1, 2, and 3. Technical Specification LCO 3.0.3 requires, in part, that when an LCO is not met and an associated action is not provided, the unit shall be placed in a Mode or other specified condition in which the LCO is not applicable and that this action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and Mode 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Contrary to the above, from initial power operation on January 23, 1988, until December 19, 2018, the licensee failed to verify the adequacy of the design of the reactor building to suppression chamber vacuum breakers to ensure the associated butterfly isolation valves close automatically upon increasing torus pressure and remain closed during all containment high pressure conditions. Specifically, during various LOP and LOCA scenarios, the butterfly valve would not close automatically without manual operator action. Additionally, because the licensee was not aware of the reactor building to suppression chamber vacuum breaker inoperability since initial power operation, the licensee failed to take the actions required by TS LCO 3.0.3 whenever the reactor had been in Modes 1, 2, or 3.

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

EXIT MEETINGS AND DEBRIEFS

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

• On May 23, 2019, the inspectors presented the Radiation Protection Program inspection results to Mr. M. Caragher, Plant Manager, and other members of the licensee staff.

• On June 21, 2019, the inspectors presented the Independent Spent Fuel Storage Installation inspection results to Mr. J. Rivet, Mr. P. Crane, Mr. J. Haas, and other members of the licensee staff.

• On July 9, 2019, the inspectors presented the integrated inspection results to Mr. P. Fessler and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60855.1 ALARA Plans RWP Number: 191061 Task Description: 2019 ISFSI 02/19/2019

Campaign

Calculations HI-2125415 Thermal Evaluation of HI-STORM System in a Cask Transfer 03/25/2013

Facility (CTF) at Fermi

HI-2188547 Fermi MPC-68M Lifting Analysis 05/30/2019

RRTI-2995-05 Response to Request for Technical Information (RRTI) 06/27/2019

Holtec International Helium Backfill - NRC Question

Calibration 1043-10181460 Traceable Certificate of Calibration for 3-Button Stopwatch 02/27/2019

Records 6850-ACAL- Certificate of Calibration Accu-Flow Calibrated Leak Model #: 03/22/2019

COMP-1-135032 GPP-8-HE-QF25-110CC-SR15

KELC-592390 Certificate of Calibration Extech Easyview 11A Type K 04/18/2019

Thermometer

Corrective Action Selected ISFSI-Related CARDs Generated Since

Documents July 21, 2016

16-0104 Quality Assurance Audit of the Independent Spent Fuel 05/02/2016

Storage Installation (ISFSI) Program

18-0102 Nuclear Quality Assurance Audit of the Independent Spent 03/12/2018

Fuel Storage Installation Program

CARD 19-24551 Trend on MPC Indications - Resolution Required 06/15/2019

CARD 19-24601 NQA - Receipt Inspection of ISFSI MPCs and Lids Not 06/18/2019

Completed in Accordance with MMM12 Receipt and Source

Inspections

Drawings 6A721Y-3000 ISFSI Delivery and Cask Haul Path 01/21/2016

Miscellaneous Visual Examination Report, NDE VT Level II Personnel 04/25/2019

Certificate, NDE PT Level II Personnel Certificate, and

Certification of Inspection, Examination and Testing

Personnel for NDE Personnel

PCI Energy Services Welder Performance Qualifications and 04/25/2019

Welder Maintenance Logs for Welding Personnel

Visual Acuity Record and Non-Destructive Inspector 04/30/2019

Certification Record for Mass Spectrometer Leak Testing

Personnel

Inspection Type Designation Description or Title Revision or

Procedure Date

Quarterly TLD Data from TLD 68 for 2013, 2017, and 2018

Selected 72.48 Screenings and Evaluations Performed

Since July 21, 2016

DTE Electric Company Fermi 2 Nuclear Power Plant 04/22/2019

Independent Spent Fuel Storage Installation 10 CFR 72.212

Evaluation Report ISFSI NRC Docket 72-71

Fermi 2 UFSAR Section 17.2A Quality Assurance of the 19

Independent Spent Fuel Storage Installation

Composite Cask Load Reports for Campaign 3 Casks 1 06/10/2019

Through 11

Fermi Training Matrix 06/13/2019

Holtec International Qualification Records for Dry Cask 05/29/2019

Personnel

MC-GTAW ASME Section IX Welding Procedure Specification and 01/27/2017

Supporting Procedure Qualification Records

MN-GTAW ASME Section IX Welding Procedure Specification and 01/27/2017

Supporting Procedure Qualification Records

Certificate of Detroit Electric Company (DTE) - Enrico Fermi Power Plant 05/23/2019

Conformance Unit 2 DTE 4701334966 Change Order 1

91542-01

FER-DCS-001-R- Fermi 2 Dry Cask Storage Fuel Characterization for Cycles 1 12/30/2009

001 Through 12

Holtec HI-STORM 100 with MPC-68M Canister 02/26/2019

International PO#

4700949383

Procedures 32.RIG.17 Mobile Crane Operation 5

35.710.042 Multi-Purpose Canister (MPC) Loading 13

35.710.043 Blowdown, Drying, Sealing, and Backfill of the MPC 11

35.710.044 MPC Transport 11

35.710.045 Dry Cask Storage Equipment Preparation and Lay-Up 4

35.710.046 MPC Unloading 6

35.710.047 Responding to ISFSI Abnormal Conditions 5

35.710.048 MPC Preparation 6

35.710.049 HI-STORM Offloading and Preparation for Site Fabrication 1

Inspection Type Designation Description or Title Revision or

Procedure Date

Completion

35.710.050 MPC Offloading and Handling 1

53.000.09 Dry Cask Storage Fuel Selection for Cask Loading 7

67.000.105 HI-TRAC Radiation Survey 1

67.000.106 HI-STORM Radiation Survey 1

67.000.107 MPC/HI-TRAC Contamination Survey 1

GQP-1.0 Project Organization and Documentation 23

GQP-1.1 QA Orientation and Project Training 19

GQP-12.0 Control of Measuring and Test Equipment 23

GQP-15.0 Non-Conforming Items 22

GQP-17.0 Quality Records 18

GQP-7.1 Procurement, Receipt, Storage, and Issue of ASME III 9

Subsection NCA-3800/NCA-4200 Weld Materials

GQP-8.1 Process Traveler 21

GQP-9.0 Training, Qualification, Examination, and Certification of NDE 20

Personnel in Accordance with SNT-TC-1A and CP-189

GQP-9.1 Training, Qualification, Examination, and Certification of 6

Inspection and Testing Personnel in Accordance with

ANSI/ASME N45.2.6-1978 and ASME NQA-1

GQP-9.2 High Temperature Liquid Penetrant Examination and 10

Acceptance Standards for Welds, Base Materials and

Cladding (50°-350°F)

GQP-9.6 Visual Examination of Welds 18

GWS-1 ASME Applications 07/24/2015

MMA07 Hoisting, Rigging, and Load Handling 26A

MMM12 Receipt and Source Inspections 29

WCP-3 Weld Material Control 07/09/2015

WCP-5 Weld and Base Metal Repair 09/23/2013

WCP-8 Preheating and Postweld Heat Treatment 09/23/2013

Radiation Work 191061 2019 ISFSI Campaign 03, 04

Permits (RWPs)

Self-Assessments Surveillance ISFSI Campaign #3 Preparation Assessment Report 05/30/2019

Report 19-1003A

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders WO 45654006 Perform Licensing Renewal for HI-STORM Lifting Beam 03/20/2019

Inspection

WO 45654008 Perform Licenses Renewal Inspection/NDE of HI-TRAC Lift 04/01/2019

Link

WO 45654088 Perform Licenses Renewal Inspection/NDE of HI-STORM 03/06/2019

Lifting Bracket

WO 45662092 MPC Lifting Cleats Inspection 04/08/2019

WO 46777224 Low Profile Transporter Inspection 03/19/2019

WO 46777226 Perform License Renewal Inspection/NDE MPC Lift Lock 03/19/2019

Assembly Inspection

WO 46777470 Annual Vertical Cask Transporter Maintenance 02/05/2019

WO 48640668 NEIL Required-Perform F Frequent Inspection Per MIOSHA 02/18/2019

R408.11872 Rule 1872(2)(A)

WO 48689801 NEIL Required-RB Overhead Crane PM Inspections 04/17/2019

WO 48960565 Perform 32.717.01 Monthly Rx Bldg Crane Manipulation- 03/22/2019

SPF 2090 NEIL Required

71111.01 Corrective Action 10-20653 Engineering Evaluation of ITC Proposed Changes 01/26/2010

Documents 18-29819 Abnormal Noise on CB Disconnect Switch 12/06/2018

19-22736 Potential Degradation of Passive Vehicle Barrier System 04/11/2019

Miscellaneous NOAA Webpage NOAA Tides and Currents Webpage,

https://tidesandcurrents.noaa.gov, Position 9063090, Fermi

Power Plant

Procedures 20.000.01 Flooding 54

Work Orders 50014198 Perform Periodic Verification of Grid Adequacy 02/01/2019

218251 Perform Quarterly Walkdown of 120/345 kV Switchyards 06/20/2019

2583978 Abnormal Noise on CB Disconnect Switch 05/24/2019

71111.04 Drawings 6I721-2451-13 NIAS Division 1 Dryer P5002D012 Controls N

6M721-2015 Station and Control Air CQ

6M721-2044 Reactor Core Isolation Cooling System BE

Procedures 23.129 Station and Control Air System 116

23.206 Reactor Core Isolation Cooling System 103

71111.04S Corrective Action 19-22583 G3352F034 MOV Actuator Missing Stem Dust Cap 04/05/2019

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Drawings 6M721-2035 High Pressure Coolant Injection (HPCI) System Reactor BN

Building

6M721-2043 High Pressure Coolant Injection (HPCI) System Barometric AJ

Condenser Reactor Building

Procedures 23.202 High Pressure Coolant Injection System 114

71111.05Q Fire Plans FP-CWPH-1-32 Circulating Water Pumphouse Zone 32 Elevation 5836 6

Procedures FP-GSW-1-31 General Service Water Pumphouse Zone 31 8

FP-RB-1-7b Reactor Building South Control Rod Drive (CRD) and 4

Railroad Bay Area, Zone 7

FP-RB-4-17a Reactor Building SLC System Zone 17 El. 6596 4

FP-RHR-1-11- RHR Complex, EDG 11 Room, El. 5900 5

EDG

FP-RHR-1-13- RHR Complex, EDG 13 Room, El. 590 0 7

EDG

71111.06 Corrective Action 19-23894 NRC Identified Concern: Housekeeping in Torus 05/21/2019

Documents

Drawings 29.100.01 SH 5 Continuous Use Procedure 12

6A721-2000-01 Reactor Building Sub-Basement Plan Elevation 5400 Scale M

1/8 = 1-0

6A721-2000-02 Reactor Building Basement Plan Elevation 6520 N

6M721-2032 Sump Pump Diagram Radwaste System BR

6M721-2224 Diagram Floor Drains All Floors Auxiliary and Reactor AA

Buildings

7M721-2218 Floor and Equipment Drains Sub-Basement Plan Reactor Y

Building

Procedures ARP 2D82 Reactor Building Torus Sump Level Hi-Hi/Lo-Lo 11

ARP 2D83 Reactor Building Leakage to Torus Sump High 7

71111.11Q Miscellaneous Operations Conduct of Operations 34

Conduct Manual

MOP01

Operations Reactivity Management 26A

Conduct Manual

MOP19

Operations Operations Conduct 40

Inspection Type Designation Description or Title Revision or

Procedure Date

Depaartment

Expectation ODE-

Procedures 23.138.01 Reactor Recirculation System 115

71111.12 Corrective Action 15-23626 C7100 Functional Failure Evaluation 05/25/2015

Documents 15-29250 Found Blown Fuse on Y Phase for RPS A Alternate 11/22/2015

Transformer Feed

16-28543 Single Rod Scram of CR 26-07 10/26/2016

17-20163 Use of RPS Test Box May Cause Loss of RPS Function 01/06/2017

17-21106 Review RPS for Maintenance Rule (a)(1) Classification 02/07/2017

17-23734 RPS-A EPA Breaker Found Tripped 04/19/2017

17-29439 Significant Arching in A RRMG Set Exciter Brushes - Root 0

Cause Evaluation

17-29735 B3105 Limiter 1 Being Enforced 12/05/2017

18-23130 Root Cause Evaluation Report - North RRMG Set Tripped 0

After Attempted Start

18-29870 Reactor Building to Suppression Chamber Vacuum Breaker 12/08/2018

UFSAR Non-Conformance

19-20117 Timer G33R616A Did Not Start Timing Immediately Upon 01/04/2019

Actuation Signal during 44.020.151

19-22916 Maintenance Rule Criteria for A7100 System has been 04/17/2019

Exceeded

Miscellaneous (a)(1) Action Plan for Primary Containment Isolation 02/13/2016

Reactor Recirculation System System Health - Third Quarter

2018

Reactor Recirculation System System Health Report -

Second Quarter 2018

Maintenance Rule Monthly Evaluation Report for April 2019 05/02/2019

(a)(2) System Classification Review for Primary Containment 09/16/2016

Isolation

C7100 System Monitoring 02/20/2019

(a)(1) Action Plan RPS (C71) Get Well Plan 0

(a)(1) Action Plan B3100 Reactor Recirculation System Get Well Plan 0

MMR APP F Maintenance Rule Conduct Manual, Appendix F - 21

Inspection Type Designation Description or Title Revision or

Procedure Date

Maintenance Rule Conduct Manual

Procedures 23.628.02 Engineered Safety Features Actuation Instrumentation (RPS 9

and ECC)

71111.13 Corrective Action 19-24210 NQA - Holtec Field Condition Report to Evaluate Indication 06/03/2019

Documents Identified on Multi-Purpose Canister [MPC] S/N 0590 [PIS]

G1300A045 (CARD 19-24152) Was Not Reviewed and

Approved by Plant Support Engineering Per MES07

19-24232 Foreign Material Identified in SFP 06/04/2019

19-24266 NQA - Expired Chemical Sherwin Dubl-Chek Developer D- 06/05/2019

100 Found Staged for Use for Liquid Penetrant Testing on

Multi-Purpose Canister Welds

Miscellaneous Risk Multiple Alarms on C32K816, Replace INNIS21 and Cable 05/14/2019

Management Assembly

Plan

Work Orders 53570537 Multiple Alarms on C32-K816, RW and RR Flat Panel 05/13/2019

Display. Troubleshoot and Repair

71111.15 Corrective Action 07-23630 CDBI: UFSAR Anti-Vortex Methodology Non-Conservative 06/28/2007

Documents 07-23630-01 Prepare EDP to Increase CST Transfer Setpoint and 07/27/2007

Refueling Level Requirements

19-23227 Recommend Review of Site Response to Open CARD 07- 04/26/2019

23630

Miscellaneous Crew Learning Opportunity (CLO) Worksheet 0

50.59 Screen 19- Review of Compensatory Measures for CARD 07-23630 0

20 CST Vortex Issue

Bases 3.3.5.1 ECCS Instrumentation 0

MQA11-100 Operability Determination Process 2A

71111.19 Corrective Action 19-22486 Timer G33R616A Did Not Start Timing Immediately Upon 04/02/2019

Documents Actuation Signal during 44.020.152

19-22650 RHR Pump Discharge Pressure at 0 PSIG 04/09/2019

19-23901 Mini on Valve E1150f004d 05/21/2019

19-24070 Human Performance Issue Battery Charger 2IB-1 05/29/2019

Drawings 5M721-6045 20 and 24 - 300# Powell O.S.Y. Gate Valve with Limitorque A

Operator

6E721-2997-04 General Arrangement 24 Volt and 130 Volt Battery Chargers E

Inspection Type Designation Description or Title Revision or

Procedure Date

6M721-2083 Residual Heat Removal (RHR) Division 2 CB

6SD721-2530-17 One Line Diagram 48/24V DC Instrumentation Batteries AM

Distribution

6SD721-2531-14 Internal Wiring Diagram 24V ESF Battery Chargers I

Procedures 35.306.020 Motor Operated Valve Mini Periodic Inspection 7

Work Orders 48565660 Perform Mini Periodic MOV Inspection (E1150-F004D) 05/21/2019

244172 Inspect/Test Division 2 24 VDC Battery Charger 2IB-1 05/29/2019

53586525 Timer G33R616A Did Not Start Timing Immediately Upon 04/02/2019

Actuation Signal during 44.020.152

53654676 RHR Pump Discharge Pressure at 0 PSIG 04/10/2019

54076383 Inspect/Test Division 2 24 VDC Battery Charger 2IB-1 05/29/2019

71111.22 Corrective Action 19-23952 Small Packing Leak Coming from E4100F068 HPCI Control 05/22/2019

Documents Valve

Drawings 6M721-2035 High Pressure Coolant Injection (HPCI) System Reactor BN

Building

6M721-2043 High Pressure Coolant Injection System (HPCI) Barometric AJ

Condenser Reactor Building

Miscellaneous Plan of the Day - Tuesday May 21, 2019 05/21/2019

Procedures 24.202.01 HPCI Pump and Valve Operability Test at 1025 PSI 118

24.202.08 HPCI Time Response and Pump Operability Test at 1025 21

PSI

24.307.14 Emergency Diesel Generator 11 - Start and Load Test 60

44.030.249 ECCS - Reactor Vessel Water Level (L2), ATWS-RPT 14

Division, Functional Test

Work Orders 46360904 Perform 43.404.001 Section 5.8 Division 1 Standby Gas 08/15/2018

Treatment System Heater Operability

46533988 Perform 43.404.001 Division 1 Standby Gas Treatment Filter 08/15/2018

Performance Test

46534020 Perform 43.404.001 Division 1 Standby Gas Treatment 08/16/2018

System Charcoal Sample Withdrawal

48698659 Perform 24.202.08 Sec-5.1 (Water Level) HPCI RTT and 05/22/2019

Pump Operability at 1025 PSIG

49189307 DGSW, DFOT and Starting Air Operability Test for EDG 12 05/15/2019

49336665 Division 1 RHR Cooling Tower Fan Operability and Valve 05/16/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Line-Up Verification Test

53629338 Calibration RPV Jet Pump 11 Flow/Pressure Indicating Loop 05/14/2019

71114.06 Corrective Action 19-23913 Untimely EAL Classification during ERO Drill 05/21/2019

Documents 19-23923 May 21, 2019 RERP Drill: Green Team OSC Staff Missing 05/22/2019

Maintenance Team Members

71124.06 18-29288 Potential Knowledge Issue Identified With General 11/14/2018

Troubleshooting and Repair Of Radiation Monitors

18-30351 Onsite Storage Facility Channel 5 Alarm Setpoint Increase 12/23/2018

19-23435 2018 Annual Effluent Report Submitted to the NRC 05/03/2019

Contained Inaccuracies

19-23711 Reactor Building System Particulate, Iodine, and Noble Gas 05/14/2019

Sample Pump Failure

Miscellaneous 2017 Annual Radioactive Effluent Release Report 04/30/2018

2018 Annual Radioactive Effluent Release Report 04/30/2019

NARP-14-0195 Acceptance of Emergency Action Level Basis Calculations 10/20/2014

NPRP-18-0112 On Site Storage Facility System Particulate, Iodine, and 06/20/2018

Noble Gas Channel 5 Low Alarm Setpoint Needs to be

Adjusted

NPRP-18-0215 Alarm Setpoint Adjustments on the Onsite Storage Facility 12/21/2018

System Particulate, Iodine, and Noble Gas Monitor

Channel 5

Work Orders 46675683 Perform 64.080.110 Circulating Water System Decant Line 05/09/2018

Radiation Monitor Calibration

46782282 Perform 64.080.102 Radioactive Waste Effluent Radiation 05/30/2018

Monitor Calibration

46926507 Perform 64.713.019 Attachment 17, Gaseous Effluent 07/09/2018

Cumulative And Projected Dose (Monthly)

47166492 Perform 64.713.019 Attachment 17, Gaseous Effluent 08/15/2018

Cumulative and Projected Dose (Monthly)

51089423 Process Radiation Monitor Onsite Storage Facility Ventilation 09/12/2018

Exhaust Radiation Monitor Penthouse Instrument Rack

51433193 Perform 64.080.102 Radioactive Waste Effluent Radiation 08/03/2018

Monitor Calibration

51822541 Onsite Storage Building Ventilation Exhaust Process 09/11/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

Radiation Monitoring System Calibration

2436065 Planned Vent/Purge of Primary Containment Atmosphere 11/16/2018

71124.07 Calibration 44.100.001 Meteorological Monitoring - Wind Speed Channel Calibration 05/11/2018

Records Serial Number Radeco Model AVS-28A Calibration 04/08/2019

6387

Serial Number Radeco Model AVS-28A Calibration 04/08/2019

22

Serial Number Radeco Model AVS-28A Calibration 04/05/2019

7572

Corrective Action 19-20363 Degraded Mechanical Equipment and Support Items Found 01/16/2019

Documents in CST/CRT Valve Vaults

19-21419 Met Tower TRLCO 3.3.13 Condition B 02/24/2019

19-22281 Met Tower TRLCO 3.3.13 Condition B 03/25/2019

Miscellaneous 2017 Annual Radiological Environmental Operating Report 04/30/2018

Responses to D4000 Meteorological Questions 05/21/2019

2018 Annual Radiological Environmental Operating Report 04/30/2019

Procedures Offsite Dose Calculation Manual (ODCM) 22

2.000.200 Land Use Census 5

2.000.201 Airborne Particulate and Iodine Sampling Using RADeCo 4

Model AVS-28A Air Sampler

2.000.203 REMP Results Analysis - Review and Action 6

2.000.207 Shipping Environmental Samples 3

67.000.104 Maintenance of Decommissioning Records 9

MRP30 Integrated Ground-Water Protection Program 6

Self-Assessments Quick Hit Self-Assessment for the NEI 07-07 5-Year 01/16/2019

Groundwater Protection Structures Review

71151 Drawings 6M721-2223 Diagram All Floors Auxiliary and Reactor Buildings Y

6M721-2224 Floor Drains All Floors Auxiliary and Reactor Buildings AA

Engineering Design Change Separation of Drywell Identified and Unidentified Leakage A

Changes Package 80010

Miscellaneous EDG MSPI and WANO Performance Indicators (April 2018 -

March 2019)

HPCI Performance Indicators (April 2018 - March 2019)

Inspection Type Designation Description or Title Revision or

Procedure Date

50.59 Screen 17- Separation of Drywell Identified and Unidentifed Leakage A

280 and Update UFSAR Figures 5.5.2 and 9.3-5 to Reflect

Changes per EDP 80010

MSPI Mitigating Systems Performance Index (MSPI) Basis 8

Document

NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

Procedures 43.401.200 Local Leakage Rate Test Type B - General 36

43.401.511 Local Leakage Rate Test, Bypass Leakage Valves 41B

71153 Corrective Action 18-29870 Reactor Building to Suppression Chamber Vacuum Breaker 12/08/2018

Documents UFSAR Non-Conformance

18-56668 2018 DBAI SA: 50.59 Screen 13-0098 Did Not Identify 09/05/2018

UFSAR Impacts (Deficiency)

19-23093 LER 2019-002 Submitted to the NRC with Clerical Errors 04/23/2019

19-23095 Incorrect/Confusing Title of Licensee Event Report in NRC 04/23/2019

Submittal (NRC-19-0020)

Drawings 6I721-2678-03 Torus to Rx Building Vacuum Breaker Valves T2300F450A U

Through T2300F410

I-2678-03 U

Engineering Design Change Automatic Closure of Torus to RB Vacuum Breakers 12/19/2018

Changes Package 80071 Isolation Valves T2300F409 and T2300F410 After Loss of

AC Power

Miscellaneous LER 2019-002-00 Secondary Containment Airlock Doors Opened at the Same 00

Time Resulting in a Condition Prohibited by Technical

Specifications

Procedures 24.402.01 Drywell and Suppression Chamber Vacuum Breaker 39 & 40

Operability Test

24