IR 05000341/2010003

IR 05000341-10-003, on 04/01/10 - 06/30/10; Fermi Power Plant, Unit 2, Plant Status

ML102110232
Person / Time
Site:	Fermi
Issue date:	07/30/2010
From:	Robert Orlikowski Reactor Projects Region 3 Branch 4
To:	Jennifer Davis Detroit Edison
References
IR-10-003
Download: ML102110232 (32)

Text

uly 30, 2010

SUBJECT:

FERMI POWER PLANT, UNIT 2, INTEGRATED INSPECTION REPORT 05000341/2010003

Dear Mr. Davis:

On June 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Fermi Power Plant, Unit 2. The enclosed report documents the inspection findings, which were discussed on June 28, 2010, with T. Conner and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved no violation of NRC requirements.

If you contest the subject or severity of this finding, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001; and the Resident Inspector Office at the Fermi Power Plant. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at the Fermi Power Plant. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by M. Kunowski Acting for/

R. Orlikowski, Acting Chief Branch 4 Division of Reactor Projects Docket No. 50-341 License No. NPF-43

Enclosure:

Inspection Report 05000341/2010003 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-341 License No: NPF-43 Report No: 05000341/2010003 Licensee: Detroit Edison Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: April 1 through June 30, 2010 Inspectors: R. Morris, Senior Resident Inspector R. Jones, Resident Inspector D. Betancourt, Reactor Engineer J. Bozga, Reactor Engineer M. Learn, Reactor Engineer V. Meghani, Reactor Inspector M. Mitchell, Health Physicist J. Neurauter, Senior Reactor Inspector B. Palagi, Senior Operations Engineer J. Rutkowski, Senior Resident Inspector, Davis-Besse C. Scott, Reactor Engineer J. Tapp, Health Physicist Approved by: R. Orlikowski, Acting Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000341/2010003; 04/01/2010 - 06/30/2010; Fermi Power Plant, Unit 2; Plant Status.

This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

A finding of very low safety significance was identified by the inspectors for the licensees failure to adequately control loose materials next to the 345kV switchyard.

Specifically, the inspectors identified tarps next to the switchyard fence. Once this condition was identified, the licensee removed the material from the switchyard area.

No violation of regulatory requirements occurred.

The finding was greater than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the loose items could affect the proper operation of the switchyard during periods of high winds. This finding was determined to be of very low safety significance because the finding was not a loss of coolant accident initiator, did not increase the likelihood of a fire or a flood, and did not contribute to the likelihood that mitigating equipment relied upon during a loss of division offsite power sources would not be available. The inspectors determined that the failure to ensure that procedure changes were incorporated in procedures following corrective actions from previous findings also affected the cross-cutting area of PI&R,

Corrective Actions (P.1(d)). (Section 4OA5.1)

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

Fermi Unit 2 started this inspection period at 100 percent power and remained there until June 6, 2010, when the reactor scrammed due to high winds. The high winds caused a loss of several offsite power sources and damaged several buildings onsite. The plant was cooled down to Mode 4 and repair activities were commenced. Repairs to the facility were completed and the main turbine was synchronized to the grid on June 16, 2010. The unit remained at 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• standby gas treatment system;

• high pressure coolant injection (HPCI), reactor core isolation cooling (RCIC)suction and recirculation to the condensate storage tank; and

• drywell cooling fans.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify there were no obvious deficiencies. The inspectors also verified the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the to this report.

These activities constituted three partial system walkdown samples as defined in Inspection Procedure (IP) 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• fourth floor, control room computer room;

• reactor building, second floor, reactor water cleanup HX room;

• reactor building, fifth floor;

• sub-basement, HPCI pump room and turbine room;

• auxiliary building, fifth floor and division 2 control center, heating, ventilation, and air conditioning (CCHVAC) room; and

• general service water pump house.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified fire hoses and extinguishers were in their designated locations and available for immediate use; fire detectors and sprinklers were unobstructed; transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP. Documents reviewed are listed in the to this report.

These activities constituted six quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On April 28, 2010, the inspectors observed a fire brigade activation in response to a reactor feed pump turbine lube oil skid scenario. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief; and took appropriate corrective actions. Specific attributes evaluated were:

• proper wearing of turnout gear and self-contained breathing apparatus;

• proper use and layout of fire hoses;

• employment of appropriate fire fighting techniques;

• sufficient firefighting equipment brought to the scene;

• effectiveness of fire brigade leader communications, command, and control;

• search for victims and propagation of the fire into other plant areas;

• smoke removal operations;

• utilization of pre-planned strategies;

• adherence to the pre-planned drill scenario; and

• drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood related items identified in the CAP program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• reactor building, sub-basement.

This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R07 Annual Heat Sink Performance

.1 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensees testing of emergency diesel generator (EDG)11 heat exchangers to verify potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed for this inspection are listed in the Attachment to this document.

This annual heat sink performance inspection constituted one sample as defined in IP 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On April 20, 2010, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification examinations to verify operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

• N3021, turbine valve actuators; and

• T4100, control room ventilation.

The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify the appropriate risk assessments were performed prior to removing equipment for work:

• risk during RCIC safety system outage;

• risk during CCHVAC, division 2, control room, west return air fan failure/repair;

• risk during EDG 12, 24-hour run and turbine building HVAC outage; and

• risk during high winds and plant loss of offsite power.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• ODMI 09-007B, Impact of Drywell Fan 10 being off;

• CARD 10-23155, NIAS Air Receiver Size and SBGT;

• CARD 10-23476, MSO Issue - RHR Flow Diversions;

• CARD 10-24065, Failure of the T41F092B SOV for the T4100F069A Division 2 CCHVAC Heating Coil Shutoff Damper; and

• CARD 10-24617, ARP 4D121 - 345 kV Breaker Position CFR Open.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure TSs operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and the UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment to this report.

This operability inspection constituted five samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modifications:

• EDP 36457, Upgrade CCHVAC Static Pressure Controller from Analog to Digital; and

• Temporary Modification 10-0019; CCHVAC, Division 2, Control Room, West Return Air Fan.

The inspectors compared the temporary configuration changes and associated 10 CFR 50.59 screening and evaluation information against the design basis, the UFSAR, and the TSs, as applicable, to verify the modification did not affect the operability or availability of the affected systems. The inspectors also compared the licensees information to operating experience information to ensure lessons learned from other utilities had been incorporated into the licensees decision to implement the temporary modification. The inspectors, as applicable, performed field verifications to ensure the modifications were installed as directed; the modifications operated as expected; modification testing adequately demonstrated continued system operability, availability, and reliability; and operation of the modifications did not impact the operability of any interfacing systems. Lastly, the inspectors discussed the temporary modification with operations, engineering, and training personnel to ensure the individuals were aware of how extended operation with the temporary modification in place could impact overall plant performance. Documents reviewed are listed in the to this report.

This inspection constituted two temporary modification samples as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance (PM) activities to verify procedures and test activities were adequate to ensure system operability and functional capability:

• WO 31022276, RCIC containment isolation valve test after maintenance;

• WO 31272982, division 2 CCHVAC fan failure;

• WO 31294288, RCIC HI Steam Line Flow Pressure; and

• WO Y750120100, Inspect AB/RB Building Metal Siding.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure the test results adequately ensured the equipment met licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with PM tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted four post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R20 Outage Activities

.1 Other Outage Activities

a. Inspection Scope

The inspectors evaluated outage activities for a forced outage that began on June 6, 2010, and continued through June 16, 2010. The inspectors reviewed activities to ensure the licensee considered risk in developing, planning, and implementing the outage schedule.

The inspectors observed or reviewed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, selected clearances, control and monitoring of decay heat removal, control of containment activities, startup and heatup activities, and identification and resolution of problems associated with the outage. The outage resulted from high wind damage to the plant structures. The licensee placed the plant in Mode 4 until the repairs were complete.

This inspection constituted one other outage sample as defined in IP 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• Procedure 24.000.02, Attachment 1, Reactor Coolant System Leakage Verification (RCS);

• Procedure 27.109.01, LPSV/LPIV Test (routine);

• Procedure 27.207.04, Division 2 EECW Throttled Valve Flow Verification (routine);

• Procedure 24.202.08, HPCI Time Response and Pump Operability Test (in-service testing); and

• Procedure 43.401.206, Sections 6.1 and 6.2, LLRT for Airlock T2301.A001D (PCIV).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• as-left setpoints were within required ranges; and the calibration frequency were in accordance with TSs, the UFSAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted two routine surveillance testing samples, one inservice testing sample, one reactor coolant system leak detection inspection sample, and one containment isolation valve sample as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on May 12, 2010, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, Technical Support Center, and Emergency Offsite Facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.

The inspectors also attended the licensee drill critique to compare any inspector observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures performance indicator for the period from the second quarter 2009 through the first quarter 2010. To determine the accuracy of the performance indicator (PI) data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of the second quarter 2009 through the first quarter 2010 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one safety system functional failures sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Reactor Coolant System Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system (RCS)leakage performance indicator for the period from the second quarter 2009 through the first quarter 2010. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the licensees operator logs, RCS leakage tracking data, issue reports, event reports, and NRC integrated inspection reports for the period of the second quarter 2009 through the first quarter 2010 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one reactor coolant system leakage sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of January 1, 2010, through June 30, 2010, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b. Findings

No findings were identified.

.4 Selected Issue Follow-Up Inspection: CARD 09-28823 with Engineering Apparent

Cause Evaluation and ACE

a. Inspection Scope

During a review of items entered in the licensees CAP, the inspectors recognized a corrective action item documenting the inability of the CCHVAC to maintain pressure in recirculation mode. The inspectors reviewed the CARD, work order, and PMT. During the walkdown following completion of the work the inspectors noted that one of the braces for the ventilation hatch cover had not been properly installed. This did not affect the operability of the system and the licensee promptly corrected the item.

This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Activation of the Emergency Response Organization due to Natural and Destructive

Phenomena Affecting the Protected Area

a. Inspection Scope

At 0238 on June 6, 2010, the inspectors responded to the plant following notification of a reactor SCRAM. At 0253 the licensee declared a Notice of Unusual Event (EAL HU1)when a tornado-like storm passed through the area causing the loss of several offsite power sources. The licensee noted that damage had occurred to the turbine building and the auxiliary building and at 0417 made an ALERT declaration (EAL HA1).

Division 2 electrical power was supplied by the EDGs and division 1 power was supplied by offsite power. No vital equipment was damaged during the storm and all shutdown systems responded normally. The plant was placed in a stable condition and a cooldown commenced as plant and site walkdowns were performed to assess the damage. At 2331 the division 2 electrical power was restored and the emergency diesel generators were shut down. The plant was cooled down to Mode 4 and repair activities were commenced. Repairs to the facility were completed and the main turbine was synchronized to the grid at 1921 on June 16, 2010.

Documents reviewed in this inspection are listed in the Attachment to this report.

This event follow-up review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Failure to Adequately Control Loose Materials near the Switchyard

Introduction:

The inspectors identified a Green finding for the licensees failure to adequately control loose materials near the 345kV switchyard. Specifically, the inspectors identified tarps covering underground cable project material along the switchyard fence. Once identified, the licensee removed the material from the switchyard area. No violation of regulatory requirements occurred.

Description:

On June 3, 2010, the inspectors conducted a walkdown, in accordance with IMC 2515, Appendix D, of the vicinity surrounding the 345kV switchyard because of on-going work in the vicinity of the switchyard. During the walkdown, the inspectors noted tarps covering material for the underground cable project next to the switchyard fence. The inspectors concluded that the loose materials near the switchyard fence combined with high velocity winds increased the potential to lose division 2 offsite power sources because the materials could become missiles and damage switchyard equipment.

The licensee had a reactive procedure for tornado watches and warnings (Procedure 20.000.01, Revision 39, Acts of Nature), which directed plant personnel to verify all outside equipment, cranes, etc., were properly secured or other compensatory measures were taken for equipment use. However, the inspectors did not identify any procedures to prepare for adverse weather conditions with respect to tornado and high wind conditions, nor did the inspectors identify any preparatory procedures to control loose materials in the protected area or switchyard. The inspectors found no specified actions or proactive elements that required the licensee to minimize the number of missile hazards prior to seasonal susceptibilities to occurrences of high winds.

Licensee Procedure MOP-21, Housekeeping, Revision 4, established responsibilities and criteria for the performance of plant material and housekeeping readiness inspections. The procedure addresses housekeeping of site areas and facilities in Section 2.2. Licensee Procedure MOP-23, Plant Storage, provides guidelines for temporary storage of material in the power block, but does not address the area in and around the switchyards. Licensee Procedure 20.000.01 discussed securing loose equipment (not material); however, this procedure would be used only if the plant were notified of a tornado watch or warning. Additionally, the licensees Quality Assurance Program Manual commits the licensee to American National Standards Institute (ANSI) N45.2.3-1973, Housekeeping during the Construction Phase of Nuclear Power Plants, during the plant operational phase. This standard required scheduled inspections of work areas and construction practices to ensure protection of installed equipment from weather-related movement of stored items.

The inspectors interviewed plant personnel and determined the licensee failed to evaluate potential effects of high winds for the tarps that were used to cover the materials stored next to the switchyard subsequent to completing assigned work activities. Specifically, the licensee placed building material for the underground cable project in the area next to the switchyard underneath the transmission lines from the main transformer to the switchyard. The material was covered with tarps to protect the material from the rain. Blocks were placed on the tarp to prevent wind from blowing the tarps off the material. When the inspector asked if the tarps and blocks had been evaluated for high winds the licensee indicated there was no evaluation.

Analysis:

The inspectors determined the licensees failure to control material near risk-significant equipment was contrary to the standards contained within ANSI N45.2.3-1973 and was a performance deficiency.

Using IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Disposition Screening, issued on December 24, 2009, the inspectors determined that the finding was more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the loose items could affect the proper operation of the switchyard during periods of high winds. The inspectors concluded this finding was associated with the Initiating Events Cornerstone.

The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -

Initial Screening and Characterization of Findings, Table 4a, dated January 10, 2008, for the Initiating Events Cornerstone. The inspectors answered No to all three screening questions because the finding was not a loss of coolant accident initiator, did not increase the likelihood of a fire or a flood, and did not contribute to the likelihood that mitigating equipment relied upon during a loss of division 2 offsite power sources would not be available. Therefore, this finding screened as Green.

This finding has a cross-cutting aspect in the area of PI&R, Corrective Actions, because the licensee did not change procedures and practices after a similar issue in 2008 (CARD 08-26161). Specifically, the licensees failure to adequately adjust procedures to include housekeeping in and around the switchyard contributed to the material being stored next to the switchyard under the power lines without proper evaluation (P.1(d)).

Enforcement:

Because no 10 CFR 50, Appendix B, components were impacted by the finding, no violation of regulatory requirements occurred. The licensee included this finding in their CAP as CARD 10-24570. (FIN 05000341/2010003-01, Failure to Adequately Control Loose Materials near the Switchyard)

These activities do not constituted a sample.

.2 Inspection of Procedures and Processes for Managing Fatigue (TI 2515/180)

a. Inspection Scope

The objective of this Temporary Instruction is to determine if the licensees implementation procedures and processes required by 10 CFR 26, Subpart I, Managing Fatigue, are in place to reasonably ensure the requirements specified in Subpart I are being addressed. The Temporary Instruction applies to all operating nuclear power reactor licensees but is intended to be performed for one site per utility. The inspector interfaced with the appropriate station staff to obtain and review station policies, procedures and processes necessary to complete all portions of this Temporary Instruction.

b. Findings

No findings were identified.

.3 Preoperational and Operational Testing of an Independent Spent Fuel Storage

Installation (60854.1)

a. Inspection Scope

An inspection of the licensees activities that support the initial loading of dry fuel storage canisters at the Fermi Unit 2 site was continued through this quarter. The inspection included in-office and on-site review of plant design calculations. The inspectors identified several technical concerns related to the reactor building crane and reactor building crane support structure calculations, the stability calculations for various configurations of canister transfer operations from a transfer cask to a storage cask, and the floor loading calculations during ISFSI operations. These calculations were performed to demonstrate compliance with the plant specific Phase I and Phase II requirements of NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, and the UFSAR licensing basis requirements. Due to these concerns and additional issues pertaining to the inadequate design implementation of the heavy loads design requirements, the licensee revised the dry cask storage schedule from summer of 2010 to spring of 2011. Due to this change in the licensees loading schedule, the inspectors activities related to the inspection are on-going and will be continued into the next several quarters inspection activities.

b. Findings

Currently NRC inspection staff is reviewing licensee responses to the identified technical concerns and will complete this review prior to the initial fuel loading campaign. The results of this inspection will be documented in the quarterly inspection report corresponding to the quarter the inspection is completed.

.4 Strike Contingency Planning

a. Inspection Scope

The Utility Workers Union of America Local 223 contract ended on June 6, 2010.

Contract negotiations extended past the contract date. Prior to the end of the contract, the resident inspectors and Region III personnel developed a strike contingency plan per IP 92709. The inspectors reviewed the licensees strike preparations, including staffing and training. The contract was ratified on July 12, 2010, without a strike.

These activities constituted one sample as defined in IP 92709.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On June 28, 2010, the inspectors presented the inspection results to T. Conner and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meeting

An interim exit was conducted for:

• Temporary Instruction 2515/180 Inspection of Procedures and Processes for Managing Fatigue with the Site Vice-President, J. Plona, on May 20, 2010.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Plona, Site Vice-President

T. Conner, Plant Manager

M. Caragher, Director, Nuclear Engineering

R. Johnson, Manager, Licensing

J. Korte, Manager Nuclear Security

C. Walker, Director, Organization Effectiveness

R. Buehler, Fatigue Management Administrator

S. Hanson, Licensing Engineer

R. Salmon, Supervisor Compliance / Licensing

Nuclear Regulatory Commission

J. Giessner, Chief, Branch 4

R. Orlikowski, Acting Chief, Branch 4

LIST OF ITEMS

Opened and Closed

0500341/2010003-01 FIN Failure to Adequately Control Loose Materials near the Switchyard Attachment