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{{Adams
{{Adams
| number = ML23153A122
| number = ML23039A155
| issue date = 06/22/2023
| issue date = 02/14/2023
| title = Non-Concurrence on Fermi Power Plant, Unit 2 - Integrated Inspection Report 05000341/2022004
| title = Integrated Inspection Report 05000341/2022004
| author name = Benjamin J, Santiago E, Skokowski R
| author name = Dickson B
| author affiliation = NRC/RGN-III
| author affiliation = NRC/RGN-III/DORS/RPB2
| addressee name =  
| addressee name = Dietrich P
| addressee affiliation = Detroit Edison, Co
| addressee affiliation = DTE Electric Company
| docket = 05000341
| docket = 05000341
| license number = NPF-043
| license number = NPF-043
| contact person = Josey J
| contact person =  
| case reference number = NCP-2023-002
| document report number = IR 2022004
| document report number = IR 2022004
| package number = ML23160A152
| document type = Inspection Report, Letter
| document type = Non-Concurrence Process
| page count = 1
| page count = 1
}}
}}
Line 20: Line 18:


=Text=
=Text=
{{#Wiki_filter:NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION (06-2019)
{{#Wiki_filter:==SUBJECT:==
NRC MD 10.158 NON-CONCURRENCE PROCESS COVER PAGE
FERMI POWER PLANT, UNIT 2-INTEGRATED INSPECTION REPORT 05000341/2022004


The U.S. Nuclear Regulatory Commission (NRC) strives to establish and maintain an environment that encourages all employees to promptly raise concerns and differing views without fear of reprisal and to promote methods for raising concerns that will enhance a strong safety culture and support the agencys missio Employees are expected to discuss their views and concerns with their immediate supervisors on a regular, ongoing basis. If informal discussions do not resolve concerns, employees have various mechanisms for expressing and having their concerns and differing views heard and considered by managemen Management Directive (MD) 10.158, NRC Non-Concurrence Process, describes the Non-Concurrence Process (NCP).
==Dear Peter Dietrich:==
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On January 25, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.


The NCP allows employees to document their differing views and concerns early in the decision-making process, have them responded to (if requested), and include them with proposed documents moving through the management approval chain to support the decision-making proces NRC Form 757, Non-Concurrence Process, is used to document the proces Section A of the form includes the personal opinions, views, and concerns of a non-concurring NRC employe Section B of the form includes the personal opinions and views of the non-concurring employees immediate superviso Section C of the form includes the agencys evaluation of the concerns and the agencys final position and outcom NOTE: Content in Sections A and B reflects personal opinions and views and does not represent the official agencys position of the issues, nor official rationale for the agency decision. Section C includes the agencys official position on the facts, issues, and rationale for the final decisio. Was this process discontinued? If so, please indicate the reason and skip questions 2 and 3:
Five findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.
Process was not discontinued At the completion of the process, the non-concurring employee(s):
Continued to non-concur - Jamie Benjamin; Concurred - Richard Skokowski, Elba Sanchez Santiago For record keeping purposes:
This record has been reviewed and approved for public dissemination


NRC FORM 757 (06-2019) Page 1 of 7 Use ADAMS Template NRC-006 (ML063120159)
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NCP Tracking Number (06-2019) NCP-2023-002 NRC MD 10.158 Date NON-CONCURRENCE PROCESS (Continued) 2023-02-13
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.


Section A - To Be Completed by Non -Concurring Employee Title of Subject Document REISSUE - FERMI POWER PLANT, UNIT 2 - DESIGN BASIS ASSURANCE ADAMS Accession Number INSPECTION (TEAMS) INSPECTION REPORT 05000341/2022010 ML23163A172 Document Signer Document Signers Office Document Signers Email Karla Stoedter - BRANCH CHIEF obdflfff Karla.Stoedter@nrc.gov Name of Non-Concurring Employees Non-Concurring Employee Offices Employee Emails Jamie Benjamin - BRANCH CHIEF; Richard REGION III Jamie.Benjamin@nrc.gov;
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.


Skokowski - CHANGE PRACTITIONER; Elba Richard.Skokowski@nrc.gov; Sanchez Santiago - SENIOR PROJECT Elba.SanchezSantiago@nrc.gov
February 14, 2023 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.


ENGINEER 1 Non-Concurring Employees Role for the Subject Document aunt Ctribut 1 Name of Non-Concurring Employee Supervisors 1 Non-Concurring Employee Supervisor Offices 1 Supervisor Emails Aaron McCraw - TECHNICAL SUPPORT TEAM REGION III Aaron.McCraw@nrc.gov;
Sincerely, Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000341 License No. NPF43


LEADER; Ro bert Ruiz - BRANCH CHIEF; Matt Robert.Ruiz@nrc.gov;
===Enclosure:===
As stated


Meyer (He/Him/His) - DEPUTY ASSISTANT Matthew.Meyer@nrc.gov FOR OPERATIONS 1 I would like my non -concurrence considered and would like a written evaluation in Sections B and. When the process is complete, I would like management to determine whether public release of the NCP Form (with or without redactions) is appropriate (Select No if you would like the NCP Form to be non-public):
==Inspection Report==
Yes 1 Reasons for the Non-Concurrence, Potential Impact on Mission, and the Proposed Alternatives See attachment 1 Submitted By / Submitted On 2023 -02-13 Jamie Benjamin - BRANCH CHIEF; Richard Skokowski - CHANGE PRACTI TIONER; Elba Sanchez Santiago -
Docket Number:
05000341
License Number:
NPF-43
Report Number:
05000341/2022004
Enterprise Identifier:
I2022004-0042
Licensee:
DTE Electric Company
Facility:
Fermi Power Plant, Unit 2
Location:
Newport, MI
Inspection Dates:
October 01, 2022 to December 31, 2022
Inspectors:
T. Briley, Senior Project Engineer
R. Edwards, Branch Chief
J. Gewargis, Resident Inspector
G. Hansen, Senior Emergency Preparedness Inspector
T. Iskierka-Boggs, Senior Operations Engineer
M. Jones, Emergency Response Coordinator
J. Kutlesa, Emergency Preparedness Inspector
R. Ng, Senior Project Engineer
T. Taylor, Senior Resident Inspector
Approved By:
Billy C. Dickson, Jr., Chief
Reactor Projects Branch 2
Division of Operating Reactor Safety


SENIOR PROJECT ENGINEER
=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.


NRC FORM 757 (06-2019) Page 2 of 7 Use ADAMS Template NRC-006 (ML063120159)
===List of Findings and Violations===
NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NCP Tracking Number (06-2019) NCP-2023-002 NRC MD 10.158 Date NON-CONCURRENCE PROCESS (Continued) 2023-02-24
Failure to Monitor Moderate Energy Line Break Flood Barriers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200401 Open/Closed
[P.2] -
Evaluation 71111.06 The inspectors identified a Green finding and associated Non-cited violation (NCV) of 10 CFR 50, appendix B, criterion III, Design Control, when the licensee failed to validate the design of certain internal flood barriers protecting safety-related equipment. Specifically, the inspectors identified degraded and missing spray shields designed to protect safety-related equipment from the effects of moderate energy line breaks (MELBs).


Section B - To Be Completed by Non -Concurring Employees Supervisor Title of Subject DocumentREISSUE - FERMI POWER PLANT, UNIT 2 - DESIGN BASIS ASSURANCE 3.ADAMS Accession Number INSPECTION (TEAMS) INSPECTION REPORT 05000341/2022010 ML23163A172 Name of Non-Concurring Employees Supervisor5. Non-Concurring Employees Supervisor Email6.Office Aaron McCraw - TECHNICAL SUPPORT TEAM Aaron.McCraw@nrc.gov; REGION III LEADER; Robert Ruiz - BRANCH CHIEF; Matt Robert.Ruiz@nrc.gov; Meyer (He/Him/His) - DEPUTY ASSISTANT FOR Matthew.Meyer@nrc.gov OPERATIONS Comments for the NCP Reviewer to Consider No additional comment. The technical subject matter of this NCP is outside of my areas of expertise, as well as my supervisory oversight. My employee in this NCP was conducting work outside of their normal roles and responsibilities within my work unit and under the purview of other managers in the regio. Reviewed By / Reviewed On 2023-02-24 Aaron McCraw - TECHNICAL SUPPORT TEAM LEADER; Robert Ruiz - BRANCH CHIEF; Matt Meyer (He/Him/His) - DEPUTY ASSISTANT FOR OPERATIONS
Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate Heat Sink) Roof Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200402 Open/Closed
[H.12] - Avoid Complacency 71111.07T The inspectors identified a finding of very low safety significance for the licensee's failure to document housekeeping findings and initiate a condition assessment resolution document (CARD) for discrepancies on the residual heat removal (RHR) complex roof in accordance with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented by the licensee despite multiple individuals touring the area.


NRC FORM 757 (06-2019) Page 3 of 7 Use ADAMS Template NRC-006 (ML063120159)
Vendor Oversight Issues During RF20 Torus Recoat Project Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200403 Open/Closed
NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NCP Tracking Number (06-2019) NCP-2023-002 NRC MD 10.156 NON-CONCURRENCE PROCESS (Continued) Date 03/03/2023 Section B - To Be Completed By Non-Concurring Employee's Supervisor Title of Subject Document ADAMS Accession Number REISSUE - FERMI POWER PLANT, UNIT 2 - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000341/2022010 ML23163A172 Name of Non-Concurring Employee's Supervisor Office (Choose from the drop down list or fill in)
[H.5] - Work Management 71152A The NRC identified a Green finding associated with vendor oversight of the 2020 torus recoat project when unexpected degradation of the coating prompted a review that determined control of supplemental personnel during the 2020 outage was inadequate.
Robert Ruiz RIII Title of Non-Concurring Employee's Supervisor Supervisor's Telephone Number (Enter 10 numeric digits)
BRANCH CHIEF (630) 829-9732 Comments for the NCP Reviewer to Consider While I am Jamie Benjamin's current supervisor, Karla Stoedter (Region III DORS Branch Chief) was Jamie's supervisor at the tim It would be my recommendation to communicate with Karla on this matter going forward, as I am not knowledgeable of the issue at han. Signature and Date of Non-Concurring Employee's Supervisor Digitally signed by Robert Ruiz Date: 2023.03.03 13:06:21 -06'00'


NRC FORM 757 (06-2019) Use ADAMS Template NRC-006 (ML063120159) Page 3 of 4 NRC FORM 757 (06-2019)
Some Industry Standards Not Incorporated into Torus Recoat Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200404 Open/Closed
NRC MD 10.156 U.S. NUCLEAR REGULATORY COMMISSION 1. NCP Tracking Number NCP-2023-002 NON-CONCURRENCE PROCESS (Continued) Date 03/06/2023 Section B -To Be Completed By Non-Concurring Employee's Supervisor 3.ADAMS Accession Number 2. Title of Subject Document REISSUE - FERMI POWER PLANT, UNIT 2 - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000341/2022010 4.Name of Non-Concurring Employee's Supervisor Matt Meyer 5.Office (Choose from the drop down list or fill in)
[H.11] -
OEDO 6.Title of Non-Concurring Employee's Supervisor 7. Supervisor's Telephone Number (Enter 10 numeric digits)
Challenge the Unknown 71152A A Green finding with an associated Non-cited violation (NCV) of 10 CFR 50 appendix B, criterion V, "Instructions, Procedures, and Drawings," was self-revealed while inspecting the torus during the RF21 refueling outage (spring 2022). Some areas of degradation were observed that were unexpected given the torus had been recoated during the previous refueling outage. Upon further review, the licensee identifies that some applicable industry standards had been omitted from the torus recoat procedures, and certain portions of the work instructions were not followed.
DEPUTY ASSISTANT FOR OPERATIONS (301) 415-6198 8.Comments for the NCP Reviewer to Consider No additional comment. The technical subject matter of this NCP is outside of my areas of expertise, as well as my regular supervisory oversight. My employee in this NCP was conducting work outside of their current roles and responsibilities within my work unit and under the purview of other managers in the regio.Signature and Date of Non-Concurring Employee's Supervisor Matthew R. Meyer NRC FORM 757 (06-2019) Digitally signed by Matthew R. Meyer Date: 2023.03.06 11 :07:03 -05'00'
Use ADAMS Template NRC-006 (ML063120159) Page 3 of4 ML23163A172 NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NCP Tracking Number (06-2019) NCP-2023-002 NRC MD 10.158 Date NON-CONCURRENCE PROCESS (Continued) 2023-05-01


Section C - To Be Completed by NCP Coordinator Title of Subject DocumentREISSUE - FERMI POWER PLANT, UNIT 2 - DESIGN BASIS ASSURANCE ADAMS Accession Number INSPECTION (TEAMS) INSPECTION REPORT 05000341/2022010 ML23163A172 Name of NCP Coordinator NCP Coordinators Email Office Jeffrey Josey - BRANCH CHIEF Jeffrey.Josey@nrc.gov RIV Agreed Upon Summary of Issues The following information was agreed up on April 5, 202 During a 2022 Design Basis Assurance Inspection (DBAI) team inspec tion, the team identified an issue associated where the licensee had not adequately evaluated industry operating experience related to the adverse effects a design basis tornado induced pressure drop could have on the emergency diesel generators (EDG) functional availability and operabilit Specifically, the EDG high crankcase pressure trip is set at approximately 0.5 inches of water. The design bases tornado induced atmospheric pressure drop of 3 psi at a rate of 1 psi/second would also result in a corresponding EDG r oom pressure drop, due to the EDG room backdraft dampers that directly communicate with the outside environment. Although the EDG crankcase(s) would not be experiencing an increase in pressure (loss of vacuum), the crankcase differential pressure device itself would see the drop in pressure outside of the crankcase caused by the atmospheric pressure drop and trip (1 psi is equivalent to approximately 28 inches of water). Based on this the licensee concluded that the EDGs were susceptible to tripping during a design bases tornado event and would require operator action to restart the EDGs to provide power to the emergency safety feature (ESF)
Failure to Perform a Required Code Evaluations for Standby Liquid Control System Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200405 Open/Closed
buses (CARD 22-28738). The nonconcurrence process (NCP) authors believe the licensee should have; 1) declared (should declare)
[H.12] - Avoid Complacency 71152A The inspectors identified a Green finding with an associated Non-cited violation (NCV) of 10 CFR 50.55a, "Codes and Standards," for the licensees failure to follow the ASME Code after discovering boric acid leakage in the standby liquid control system (SLC). Specifically, a code required evaluation was not performed as an alternative to corrective actions.
the Fermi 2 EDGs inoperable after the licensee reached their conclusion documented in licensee corrective action program report CARD 22-28738, and 2) reported the condition under the requirements of 10 CFR 50.73. Specifically, the EDGs were/are no longer capable of meeting the technical specification EDG Mode 1-5 specified safety function of automatically starting, loading, and continuous operations within the parameters specified in the Fermi 2 Technical Specification Surveillance Requirements. Additionally, because the compensatory measure proposed by the licensee does not prevent the EDGs from tripping, it does not maintain operability. This compensatory measure merely reinforces the post -alarm actions already in the plant procedures and provides additional training and awarenes. Evaluation of Non-Concurrence and Rationale for Decision The submitters are to be commended for their technical acumen and level of ownership of this issue. The technical aspects of this issue require a sophisticated level of understanding of not only the engineering principles but also the application of technical specifications and the operability process. The professional ownership of this issue highlights the NRC core value An understanding of the event and its outcome is necessar The submitters have raised a concern associated with a design basis tornado strike of the residual heat removal (RHR) complex (building that houses the EDGs) coincident with a loss of offsite power (LOOP). Section 8.2. of the UFSAR states that in the case of a major earthquake, tornado, or similar cataclysmic event, the simultaneous loss of all offsite power transmission is improbable. However, should a complete loss of offsite power occur, the ESF buses will be supplied from the standby EDG Next, one must ensure that the event is within the licensing bases of the facility is require A LOOP is a credible event during a design basis tornado (UFSAR Section 8.2.2) and is assumed to occur. Section 8.3.1.1.8.1 of the UFSAR identifies that the EDGs are housed in reinforced -concrete, Category 1 structures. Each unit is completely enclosed in its own concrete cell and is isolated from the other units. Therefore, the EDGs will not be physically damaged by the design basis tornado winds or tornado generated missiles. However, the tornado will also cause an atmospheric pressure drop of 3 psi at a rate of 1 psi/second, lasting approximately 30 seconds (UFSAR Figure ), and subsequent re-pressurizatio The licensees UFSAR does not contain correct information on the depressurization that will occur in the RHR Complex. Specifically, Section 3.3.2.2 states, in part, that Category I structures have been designed to withstand the effects due to simultaneous action of tornado wind velocity pressu res, atmospheric pressure drop, and a single tornado generated missile, and Section 3.3.2.3.5 states that because of the depressurization that can occur when the very low-pressure area within the funnel of a tornado engulfs a structure, structures housing equipment necessary for safe shutdown must either be designed for the depressurization, or be vented. In the Fermi 2 design, all such structures, with the


NRC FORM 757 (06-2019) Page 4 of 7 Use ADAMS Template NRC-006 (ML063120159)
===Additional Tracking Items===
exception of the steam tunnel, are designed for the depressurization. This information is not correct and does not match how the facility is built. The inside of the RHR Complex would experience a pressure drop due to the EDG room backdraft dampers that directly communicate with the outside environment. As the pressure in the RHR Complex goes down the differential pressure sensors will trip causing all 4 EDGs to trip. So, the RHR Complex is a partially vented structure which will expose the EDGs to the drop in atmospheric pressur Based on the above discussed information the tornado, atmospheric depressurization and LOOP are within the facilities design base In response to the issue the licensee initiated CARD 22-28664 to evaluate this concern. As part of their review the licensee contacted the EDG vendor and confirmed that for this event all 4 EDGs would trip on crankcase overpressure due to the lowering atmospheric pressure. The licensee recognized that this was contrary to UFSAR section 8.3.1.1.8.2(i) which states, in part, that the EDGs are designed to be operable during and after a design-basis tornado. The licensee recognized that the presumption of operability was lost and developed an operability position which credited compensatory measures. The measure was to manually restart the EDGs post tornado event if necessary. The time critical action for this event was the need to restore torus cooling within 20 minutes. For their evaluation the licensee assumed a single active failure of a division of ESF equipment resulting from the failure of the associated EDGs. Additionally, it was assumed that both cooling tower fans initially are damaged to such an extent as to be unavailable as a result of the tornado. One fan would be restored to service after six hours, and the second fan could be restored after twelve hours. The scenario assumes one RHR pump, one RHR heat exchanger, and two RHR service water pumps are in operation (in the operable division). The atmospheric conditions last for 30 seconds, and during this time, the EDGs trip due to high crankcase pressure. Operations will receive four EDG Trouble alarms (one for each EDG), and it would be apparent to the operators that this condition was caused by the tornado depressurization. The licensee also assumed that no action could be taken for the first 10 minutes of the event (UFSAR 7.5.2.4.1). The design bases of all ESF systems to mitigate accident event conditions take into consideration that no operator action or assistance is required or recommended for the first 10 minutes of the event. This requirement makes it mandatory that all protective action necessary in the first 10 minutes be automatic. Therefore, although continuous tracking of variables is available, no operator action based upon them is intende The site made changes to station procedure 20.307.01, EMERGENCY DIESEL GENERATOR FAILURE, to capture this apparent condition to improve operator efficiency in reaching the same conclusion. In addition, there is a 2 min time delay relay from the time the EDG reset button is depressed to the time the EDG receives a start signal and then another 1Os for the engines to be started. The Torus cooling valve lineups take approximately 5 minutes to complete. The licensee concluded that it would take approximately 18 minutes to restore torus coolin The submitters have asserted that the licensee should have; 1) declared (should declare) the Fermi 2 EDGs inoperable after the licensee reached their conclusion documented in licensee corrective action program report CARD 22-28738, and 2) reported the condition under the requirements of 10 CFR 50.73. Specifically, the EDGs were/are no longer capable of meeting the technical specification EDG Mode 1-5 specified safety function of automatically starting, loading, and continuous operations within the parameters specified in the Fermi 2 Technical Specification Surveillance Requirements. Additionally, because the compensatory measure proposed by the licensee does not prevent the EDGs from tripping, it does not maintain operability. This compensatory measure merely reinforces the post-alarm actions already in the plant procedures and provides additional training and awarenes I also considered the following information in my revie General Design Criteria (GDC) 2 states: Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornados, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The design bases for these structures, systems, and components shall reflect: (1) appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity and period of time in which the historical data have been accumulated; (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena; and (3) the importance of the safety functions to be performe UFSAR Section 3.1.2.1.2 states: Criterion 2 Conformance - The design bases enumerated in this criterion are incorporated into the design of structures, systems, and components of Fermi 2. Among the natural phenomena considered are wind and tornado loadings, including static and dynamic water level loadings caused by floods, hurricanes, and other severe storms with wave runup effects; and seismic loadings. In each case the most severe of these phenomena is used as the design basis, together with appropriate combinations of normal and accident conditions. These design bases are developed from detailed analysis of the occurrence and history of these phenomena in the area surrounding the plant locatio Regulatory Information Summary (RIS) 2013-05, NRC Position on the Relationship Between General Design Criteria and Technical Specification Operability Issued to clarify the
Type Issue Number Title Report Section Status URI 05000341/202200303 Seismic Displacement for Safety-Related Piping Not Verified 71111.18 Closed LER 05000341/2021002-00 LER 2021002-00 for Fermi 2 Power Plant, Unplanned Inoperability of High Pressure Coolant Injection System Due to an Inverter Circuit Failure 71153 Closed LER 05000341/2021002-01 LER 2021002-01 for Fermi Power Plant, Unit 2,
Unplanned Inoperability of High Pressure Coolant Injection System Due to an Inverter Circuit Failure 71153 Closed LER 05000341/2021001-00 LER 2021001-00 for Fermi,
Unit 2, Unrecognized Impact of Opening of Barrier Doors on High Energy Line Break Analysis 71153 Closed LER 05000341/2022003-00 LER 2022003-00 for Fermi 2 Power Plant, Turbine Trip 71153 Closed and Subsequent Reactor Trip Due to Mayflies LER 05000341/2022001-00 LER 2022001-00 for Fermi 2 Power Plant, Reactor Scram on Low Reactor Pressure Vessel Level 71153 Closed


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=PLANT STATUS=
relationship between Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, and 10 CFR 50.36, Technical Specifications. In addition, the RIS clarified the process for addressing any structure, system, or component (SSC) nonconforming condition with GDC as incorporated into a plants current licensing basis (CLB). Identifies that the GDC, or a plant-specific equivalent as incorporated into the CLB, have an important relationship to the operability requirements of the TS. Comprehending this relationship is critical to understanding how licensees should address nonconformance with CLB design requirement Notes that the GDC and the TS differ from each other in that the GDC specify NRCs requirements for the design of nuclear power reactors, whereas the TS are included in the license and specify requirements for the operation of nuclear power reactors. As such, the GDC cover a broad category of SSCs that are important to safety, including those SSCs that are covered by TS. It is the staffs position that failure to meet GDC, as described in the licensing basis (e.g., nonconformance with the CLB for protection against flooding, seismic events, tornadoes) should be treated as a nonconforming condition and is an entry point for an operability determination if the nonconforming condition calls into question the ability of SSCs to perform their specified safety function(s) or necessary and related support function(s). If the licensee determination concludes that the TS SSC is nonconforming, but operable or the necessary and related support function is nonconforming but functional, it would be appropriate to address the nonconforming condition through the licensees corrective action program. However, if the licensees evaluation concludes that the TS SSC is inoperable, then the licensee must enter its TS and follow the applicable required action Fermi Technical Specifications (TS) define operability as: A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). From this it is understood that for a structure or system to be operable in accordance with the TS definition it must be able to perform the specified safety function. Additionally, the TS application of the defined term operable has attendant requirements in excess of those physical requirements of the system or structure that must be in place for the system or structure to perform its specified safety function (e.g., use and application rules and conservatisms or other requirements in excess of the accident analysis included in the TS). Inspection manual chapter (IMC) 0326, Operability Determinations, The definition of operability refers to the capability to perform the specified safety function. The specified safety function of a SSC is that specified safety function(s) in the CLB for the facility. Not all SSC functions described in the current licensing bases are specified safety functions required for operability. More specifically, SSCs that are not explicitly required to be operable by TS but perform necessary and related support functions for TS SSCs are required to be operable by TS. SSCs may also have design functions that do not perform a necessary and related support function for TS SSC Section 06.07 states, in part that compensatory measures may be established to restore or maintain operability of an SS Section 06.08 states, in part that compensatory measures should have minimal impact on the operators or plant operations, should be relatively simple to implement, and should be documente Section 08.05 states, in part: * It is not appropriate to consider an SSC operable by taking credit for manual action in place of automatic action for protection of safety limits, operator action cannot be a substitute for automatic safety limit protectio * For situations where substitution of manual action for automatic action is proposed for an operability determination, the evaluation of manual action must focus on the physical differences between automatic and manual action and the ability of the manual action to accomplish the specified safety function(s). The physical differences to be considered include the ability to recognize input signals for action, ready access to or recognition of setpoints, design nuances that may complicate subsequent manual operation (such as auto-reset, repositioning on temperature or pressure),
timing required for automatic action, minimum staffing requirements, and emergency operating procedures written for the automatic mode of operatio * The licensee should have written procedures in place and personnel should be trained on the procedures before any manual action is substituted for the loss of an automatic actio Based on my review of the above information I have determined the following: The specified safety functions of interest are: 1. The EDGs are designed to be operable during and after a design-basis tornado (which includes atmospheric depressurization) in accordance with UFSAR section 8.3.1.1.. Torus cooling must be started within 20 minutes of a LOOP to maintain torus temperature below 140 The submitters are correct with regards to operability and reportability for the EDGs for the period of time prior to the licensee developing the operability determination documented in CARD 22-2873. Specifically, all four EDGs at Fermi should have been considered inoperable. Therefore, the licensee should have submitted a 10 CFR 50.73 report for inoperable equipment longer than allowed by technical specification Additionally, the licensee should have reviewed this condition to determine if the actual configuration of the building versus how it is


NRC FORM 757 (06-2019) Page 6 of 7 Use ADAMS Template NRC-006 (ML063120159)
Fermi Unit 2 started the inspection period at or near 100 percent power, and remained there for the quarter.
described in the UFSAR represented and unanalyzed condition, Specifically, UFSAR 3.3.2.3.5 says that all structures are designed to withstand tornado depressurization and none are vented when in fact, the RHR Complex is a partially vented structure which exposes the EDGs to an atmospheric condition that has an effect on operatio However, after the condition was identified and evaluated the licensee demonstrated compliance with the guidance that the NRC has published in IMC 0326 and has established a reasonable expectation of operability using compensatory measures. The licensee has demonstrated that they can restore power by manually restarting the EDGs following a tornado within the critical time requirements for torus cooling. UFSAR Section 8.3.1.1.8.1 notes that the EDGs are capable of being started or of being restarted from a hot shutdown condition. Additionally, the EDGs realistically could be restarted approximately 8 minutes after the tornado (10 minute wait is an artificiality for design purposes). So, from a reasonableness standpoint the specified safety functions are maintained with crediting the compensatory measure. Coordinated By / Coordinated On 2023-05-01 Jeffrey Josey


10. Approved By / Approved On 2023-05-01 Jason Kozal (He/Him/His) - DEP DIR, DIV OPERATING REACTOR SAFETY
==INSPECTION SCOPES==
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, appendix D, Plant Status, observed risk significant activities, and completed onsite portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


NRC FORM 757 (06-2019) Page 7 of 7 Use ADAMS Template NRC-006 (ML063120159)
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
===Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)===
: (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:
General service water, circulating water, and residual heat removal service water (RHRSW) for the week ending on November 18, 2022
 
===External Flooding Sample (IP Section 03.03) (1 Sample)===
: (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding for the week ending on November 4, 2022.
 
==71111.04 - Equipment Alignment==
===Partial Walkdown Sample (IP Section 03.01) (6 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) Division 1 emergency equipment cooling water (EECW) with division 2 EECW TCV maintenance during the week ending October 21, 2022
: (2) Division 1 non-interruptible air system (NIAS) during division 2 control center heating, ventilation, and air conditioning (CCHVAC) safety system outage during the week ending October 21, 2022
: (3) Division 1 130/260 engineered safety feature direct current (DC) power and battery system during the week ending October 29, 2022
: (4) Electric fire pump while the alternate diesel fire pump was out of service on November 9, 2022
: (5) Division 2 residual heat removal (RHR) drywell spray with work on division 1 during the week ending November 26, 2022
: (6) Division 1 RHRSW with the division 2 RHR pump and valve surveillance during the week ending November 25, 2022
 
===Complete Walkdown Sample (IP Section 03.02) (1 Sample)===
: (1) The inspectors evaluated system configurations during a complete walkdown of the division 2 core spray system during the week ending on November 4, 2022.
 
==71111.05 - Fire Protection==
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)===
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
: (1) Southwest quadrant of the reactor building basement and sub-basement during the week ending October 21, 2022
: (2) Northwest quadrant of the reactor building basement and sub-basement during the week ending November 18, 2022
: (3) Reactor core isolation cooling quad sprinkler question during the week ending December 10, 2022
: (4) Reactor building 3 and reactor building 4 standby liquid control area during the week ending December 12, 2022
 
==71111.06 - Flood Protection Measures==
===Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)===
The inspectors evaluated internal flooding mitigation protections in the following:
: (1) Auxiliary building third and fourth levels, completed the week ending December 31, 2022
 
===71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)===
{{IP sample|IP=IP 71111.07|count=1}}
The inspectors evaluated heat exchanger performance on the following:
: (1) P4400B001B, EECW division 2 plate and frame heat exchanger
 
===Heat Exchanger (Closed Loop) (IP Section 03.03) (1 Sample)===
The inspectors evaluated heat exchanger performance on the following:
: (1) P5002B004, control air compressor (CAC) after cooler - north non-interruptible control air (NIAS)
 
===Ultimate Heat Sink (IP Section 03.04) (1 Sample)===
The inspectors evaluated the ultimate heat sink performance on the following:
: (1) The ultimate heat sink, specifically sections 03.04.a and 03.04.e were completed.
 
==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance==
===Requalification Examination Results (IP Section 03.03) (1 Sample)===
: (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests administered between October 11, 2022 and November 10, 2022.
 
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
: (1) The inspectors observed and evaluated licensed operator performance in the control room during a planned high pressure coolant injection system surveillance that resulted in a yellow risk condition, with complications regarding the performance of two valves in the system, on November 15, 2022.
 
===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)===
: (1) The inspectors observed and evaluated performance of an annual operating test in the control room simulator on October 26, 2022.
: (2) The inspectors observed and evaluated licensed operator requalification training for technical specifications and emergency action level entry, and simulator exercise scenarios in the main control room simulator during the week ending November 18, 2022.
 
==71111.12 - Maintenance Effectiveness==
===Maintenance Effectiveness (IP Section 03.01) (3 Samples)===
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)4160V electrical switchgear
: (2) Power supply inverters for safety-related instrumentation and control loads
: (3) Review of issues associated with the transversing incore probe system, completed the week ending December 24, 2022
 
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
===Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)===
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
: (1) Troubleshooting and electric shock associated with the reactor water cleanup system during the week ending November 12, 2022
: (2) Gland seal exhaust motor replacement on November 02, 2022
: (3) Mechanical draft cooling tower fan 'B' maintenance November 28, 2022
: (4) Approach to a leaking sensing line for reactor feed pump suction pressure, completed the week of December 31, 2022
 
==71111.15 - Operability Determinations and Functionality Assessments==
===Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
: (1) Abnormal noise from the 'B' mechanical draft cooling tower motor during the week ending December 3, 2022
: (2) Recirculation pump seal pressure changes during the week ending December 10, 2022
 
==71111.18 - Plant Modifications==
===Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)===
: (1) The inspectors verified the site SAMG were updated in accordance with the BWR generic severe accident technical guidelines and validated in accordance with NEI 1401, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1.
 
==71111.19 - Post-Maintenance Testing==
===Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)===
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
: (1) Division 1 CCHVAC outage during the week of October 3, 2022
: (2) Division 1 NIAS during the week ending November 4, 2022
: (3) Diesel fire pump post installation testing, completed during the week ending December 23, 2022
 
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
 
===Surveillance Tests (other) (IP Section 03.01) (4 Samples)===
: (1) Electrical bus 64B undervoltage testing and relay calibrations during the week ending October 8, 2022
: (2) HPCI pump and valve surveillance after pressure control valve repair and outboard main steam isolation valve packing adjustment on December 1, 2022
: (3) EECW pump and valve during the week ending December 14, 2022
: (4) Validation of acceptable level bands for oil and tank levels on select motors and tanks, completed the week ending December 24, 2022
 
===Inservice Testing (IP Section 03.01) (1 Sample)===
: (1) EDG 11 SW pump and minimum flow valve testing during the week ending October 21, 2022
 
===RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)===
: (1) RCS leakage increasing trend during the week ending October 29, 2022
 
===FLEX Testing (IP Section 03.02) (1 Sample)===
: (1) Dominator and Neptune pump run surveillances, completed by the week ending December 31, 2022
 
==71114.04 - Emergency Action Level and Emergency Plan Changes==
===Inspection Review (IP Section 02.0102.03) (1 Sample)===
: (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:
 
===202108E, Spent fuel pool level updates for RA2.3, RS2.1, and RG2.1, September 21, 2021
 
202135S, Spent fuel pool level updates for RA2.3, RS2.1, and RG2.1, September 21, 2021 This evaluation does not constitute NRC approval.
 
==71114.06 - Drill Evaluation==
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
 
===
{{IP sample|IP=IP 20210|count=1}}
: (1) The inspectors evaluated drill and exercise performance indicator opportunities associated with a licensed-operator requalification activity on October 26,
 
==OTHER ACTIVITIES-BASELINE==
===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)===
{{IP sample|IP=IP 71152|count=3}}
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
: (1) Ongoing issues with effluent sampling systems and potential impacts to declaring emergency action levels, the week ending December 10, 2022
: (2) Select review of degraded/non-conforming conditions carried by the licensee, completed the week of December 31, 2022
: (3) Review of 2020 torus recoat project following degradation identified in 2022, completed the week of December 31, 2022
 
===71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)===
{{IP sample|IP=IP 71152|count=1}}
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue.
 
===71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)===
{{IP sample|IP=IP 71153|count=4}}
The inspectors evaluated the following licensee event reports (LERs):
: (1) LER 05000341/2021001, Unrecognized Impact of Opening of Barrier Doors on High Energy Line Break Analysis (ADAMS Accession No. ML21182A291). The inspection conclusions associated with this LER are documented in Inspection Report 05000341/2021003 under Inspection Results section 71111.15 (ADAMS Accession No. ML21298A200). An analysis to assess the potential impacts on components outside the reactor building steam tunnel (RBST) during a line break in the RBST does not exist. Current analyses assume the door is shut. Subsequent to NRC identification of the issue in 2021, the licensee took steps to conduct an analysis on effects outside the RBST. This effort was not completed. As a result, the inspectors cannot validate the accuracy of several of the 10 CFR 50.73 reporting criteria, such as loss of safety functions and conditions prohibited by technical specifications (TS). While the licensee did report under those criteria (assuming a worst case scenario where all equipment required to respond to a line break in the RBST was inoperable due to the break), without an analysis on the environmental impacts outside the RBST, it is impossible to assess whether or not these criteria were actually met. Despite that, the licensee did report under criteria for an unanalyzed condition and a condition prohibited by TS 3.0.3 specifically. The inspectors determined it was appropriate to report under those criteria given the lack of analysis and multiple types and trains of equipment that may have been impacted to the point where operability was brought into question. The non-cited violation associated with this issue screened as very low safety significance given the small amount of time the door had been open in the past 3 years. The licensee instituted corrective actions to better recognize and control important doors throughout the plant. No further findings nor violations were identified.
: (2) LER 05000341/2021002-00 and 05000341/2021002-01, Unplanned Inoperability of High Pressure Coolant Injection System Due to an Inverter Circuit Failure (ADAMS Accession Nos. ML22075A087). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. The inspectors reviewed the previous, as well as the updated LER submittal.
: (3) LER 05000341/2022001, Reactor Scram on Low Reactor Pressure Vessel Level (ADAMS Accession No. ML22094A155). The inspection conclusions associated with this LER are documented in Inspection Report 0500341/2022003 under Inspection Results section 71152A. No further findings or violations were identified.
: (4) LER 05000341/2022003, Turbine Trip and Subsequent Reactor Trip due to Mayflies (ADAMS Accession No. ML22235A106). The inspection conclusions associated with this LER are documented in Inspection Report 0500341/2022003 (ADAMS Accession No. ML22311A531) under Inspection Results section 71152A. No findings nor violations were identified.
 
==OTHER ACTIVITIES==
-TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation of an ISFSI The inspectors evaluated the licensees activities related to the long-term operation and monitoring of its Independent Spent Fuel Storage Installation (ISFSI). The inspectors reviewed relevant documentation remotely during the weeks of October 10 and October 17, 2022, and were onsite on October 19, 2022. During the onsite walkdown, the inspector toured the ISFSI and evaluated the material and radiological conditions of the ISFSI pad and loaded HISTORM 100 systems. The inspectors verified radiological conditions on the ISFSI pad were as expected during the walkdown. The inspectors interviewed licensee staff regarding periodic surveillances of the loaded HISTORM casks.
 
Since the last inspection, the inspectors evaluated corrective action documents and changes performed in accordance with 10 CFR 72.48, "Changes, Tests, and Experiments."
 
==INSPECTION RESULTS==
Failure to Monitor Moderate Energy Line Break Flood Barriers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200401 Open/Closed
[P.2] -
Evaluation 71111.06 The inspectors identified a Green finding and associated Non-cited violation (NCV) of 10 CFR 50, appendix B, criterion III, Design Control, when the licensee failed to validate the design of certain internal flood barriers protecting safety-related equipment. Specifically, the inspectors identified degraded and missing spray shields designed to protect safety-related equipment from the effects of moderate energy line breaks (MELBs).
 
=====Description:=====
On November 29, 2022, the inspectors performed a walkdown of the third floor and fourth floor of the auxiliary building (AB) as part of an internal flooding inspection sample. During the walkdown, the inspectors discovered that the MELB spray shields in the division 2 switchgear room and AB fourth floor were degraded or missing from sections of emergency equipment cooling water (EECW) piping. The spray shield design consists of a fiberglass-impregnated material that encloses susceptible piping to contain and divert water away from safety-related equipment, namely electrical switchgear. The inspectors questioned the potential effects of the degraded/missing spray shields on nearby equipment. In response, the licensee performed technical evaluations that concluded that safety-related equipment remained operable in the current condition but not in accordance with the design.
 
A subsequent review by the licensee revealed that a condition assessment resolution document (CARD) had been written in 2020 documenting the degraded spray shields in the division 2 switchgear room, consistent with what was identified on the NRC walkdown almost 3 years later. While the licensee had generated a work order to fix the shields, it was still in a delay status, and no monitoring plan was in place to ensure the barrier could still fulfill its design functions (e.g., following work in the area or periodic checks of the tape holding the barrier in place at some locations). The licensee found no evidence for other piping sections that the missing shields had been identified or documented by the licensee. Through discussion with the inspectors, the licensee determined that the work activity to inspect spray shields throughout the plant had not been performed when last scheduled in July 2019.
 
During the extent of condition walkdowns following NRC's discovery of the issue, further degraded spray shields were identified; however, most were determined not be a part of the internal flooding design basis anymore. The licensee evaluated the others to ensure no impacts to safety-related equipment existed.
 
Corrective Actions: The licensee completed a technical evaluation to support the operability of the division 2 switchgear and confirmed other areas of missing/degraded spray shields did not constitute a deviation from design nor have adverse impacts on nearby equipment as part of their extent of condition walkdowns. In response to the inspectors' questions, the licensee also started a review to determine if they properly administrated the periodic inspection activity to validate the flood barrier design.
 
Corrective Action References: CARDs 2231414, 2020846, 2231541, 2231415, and 2231571.
 
=====Performance Assessment:=====
Performance Deficiency: The inspectors determined the licensee failed to perform a scheduled verification of flooding barriers. Additionally, deviations from MELB protection features were not controlled due to inspector identification of missing/degraded spray shields on EECW piping that had not been identified by the licensee nor properly monitored.
 
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, degraded MELB barriers had not been identified, monitored, and/or properly assessed that could impact nearby safety-related equipment.
 
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.
 
Specifically, the finding screened to Green (very low safety significance) because questions 2 through 6 on exhibit 2 of the mitigating systems screening were answered as No.
 
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, when degraded MELB barriers were identified, the licensee failed to ensure appropriate technical assessments were performed, that effective monitoring was in place, and an extent of condition was performed to identify other issues.
 
=====Enforcement:=====
Violation: 10 CFR 50, appendix B, criterion III, "Design Control," states, in part, that measures established shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
 
Contrary to the above, from January 24, 2020 to January 9, 2023, the licensee failed to assure that deviations from quality standards were controlled. Specifically, the licensee failed to complete a scheduled inspection of flood barriers. Further, the licensee did not perform a technical assessment nor monitoring to support shroud functionality once degradation was identified.
 
Enforcement Action: This violation is being treated as a NCV, consistent with section 2.3.2 of the Enforcement Policy.
 
Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate Heat Sink) Roof Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200402 Open/Closed
[H.12] - Avoid Complacency 71111.07T The inspectors identified a finding of very low safety significance for the licensee's failure to document housekeeping findings and initiate a condition assessment resolution document (CARD) for discrepancies on the residual heat removal (RHR) complex roof in accordance with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented by the licensee despite multiple individuals touring the area.
 
=====Description:=====
On October 18, 2022, the inspectors performed a walkdown of the residual heat removal complex roof. The inspectors noted that the lower roof contained miscellaneous debris in the form of food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips. The inspectors also noted that one of the large plastic storage bins containing ice melt material had been lined with a plastic bag and turned into a makeshift trash can. The identified debris was generally in the vicinity of roof drains and/or grating that led to or was directly over the division 1 and division 2 ultimate heat sink water reservoirs used to transfer heat from structures, systems, and components important to safety. Natural phenomena (such as rainfall or wind gusts) could potentially transport the debris into the reservoirs and potentially challenge pump operation for residual heat removal service water, emergency equipment service water, and/or emergency diesel generator service water. Periodic diving inspection records from 2020 and 2022 also indicated the presence of miscellaneous debris such as plastic signage, moss clumps, and ear plugs located under water in the reservoirs (debris was documented as removed by the divers upon discovery).
 
The personnel doors used to access the RHR complex roof indicated the area was a "housekeeping category."
 
Licensee procedure MOP 21, "Housekeeping," Revision 7, contains procedural guidance for ensuring adequate levels of housekeeping to ensure safe plant operation and included all activities related to controlling material in all areas of the facility. The procedure also stated, in part, that individuals are expected to maintain the same level of housekeeping inside and out of the power block. Procedure step 2.3.9 stated, in part, that persons performing a plant tour shall 1) document findings on the housekeeping inspection report form and 2) initiate a condition assessment resolution document (condition report) for discrepancies when required.
 
The debris identified by the inspectors had not been documented as a housekeeping finding nor entered into the corrective action program via a condition assessment resolution document until brought to the licensee's attention. It is unknown how long the miscellaneous debris was present on the residual heat removal complex roof, however, the inspectors determined that some of the miscellaneous debris had most likely been on the roof for an extended period of time based on environmental degradation.
 
Corrective Actions: The miscellaneous debris was subsequently removed from the residual heat removal complex roof and a follow-up investigation into the cause(s) was planned.
 
Corrective Action References: CARD 2230462
 
=====Performance Assessment:=====
Performance Deficiency: The licensee's failure to document housekeeping findings and initiate a CARD for discrepancies on the RHR complex roof in accordance with licensee procedure MOP 21, "Housekeeping," was a performance deficiency. Specifically, the inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented by the licensee despite multiple individuals touring the area.
 
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, debris on the residual heat removal complex roof can be washed or blown directly into the ultimate heat sink reservoirs and could potentially impact safety-related residual heat removal, emergency equipment, and emergency diesel generator service water systems. The inspectors also noted previous dive inspection records in both 2020 and 2022 of the ultimate heat sink reservoirs housed in the residual heat removal complex contained debris found such as plastic signage and bags, paint chips, and ear plugs to name a few (items were retrieved during periodic diving activities).
 
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.
 
Specifically, the mitigating systems screening questions for structures, systems, and components and probabilistic risk analysis functionality were all answered no. Therefore, the finding screened as of very low safety significance (Green).
 
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, multiple individuals from multiple organizations routinely traversed the RHR complex roof and appeared to not consider the potential undesired consequences of their actions in leaving miscellaneous debris on the roof, verify housekeeping procedure prerequisites despite being prompted by the access door signs stating "housekeeping category," nor performed a thorough review of the area every time work was performed (such as operator rounds) rather than relying on past successes and assumed conditions.
 
=====Enforcement:=====
Inspectors did not identify a violation of regulatory requirements associated with this finding.
URI Seismic Displacement for Safety-Related Piping Not Verified URI 05000341/202200303 71111.18
 
=====Description:=====
During the fourth quarter of 2022, the licensee provided additional information from a design basis calculation of record associated with the division 1 residual heat removal service water (RHRSW) supply and return piping inside the reactor building. Calculation No. DC6953, "Emergency Equipment Cooling Water System Subsystem: EX15," Revision 0 provides the design basis and licensing basis information associated with the seismic and thermal displacements of the piping and determination of whether the maximum piping displacement impacts any systems, structures, or components (SSCs).
 
The licensee provided the piping displacement information from Calculation No. DC6953 to demonstrate that the RHRSW piping will not impact any SSCs. The inspector reviewed this information and concluded this issue is closed. No performance deficiencies or findings were identified.
 
Corrective Action Reference(s): condition assessment resolution document 2227033, NRC Identified: Evaluation of Potential Rattle Space Violation, dated 06/10/2022.
 
Vendor Oversight Issues during RF20 Torus Recoat Project Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200403 Open/Closed
[H.5] - Work Management 71152A The NRC identified a Green finding associated with vendor oversight of the 2020 torus recoat project when unexpected degradation of the coating prompted a review that determined control of supplemental personnel during the 2020 outage was inadequate.
 
=====Description:=====
The unexpected torus coating degradation discovered during the 2022 refueling outage prompted an investigation by the licensee into the operability of the torus and the potential causes of the degradation. Non-cited violation (NCV) 05000341/202200404, documented in this inspection report, describes the issues with the work instructions associated with the 2020 torus project. Further investigation by the licensee as a result of NRC questions prompted a condition assessment resolution document (CARD) 2227942 to be written to explore the extent of work control/process gaps that may have existed for the torus project.
 
An organizational effectiveness evaluation determined that supplemental personnel assigned to the torus project failed to follow site processes regarding procedure use and adherence.
 
One of the potential causes for the degradation of the new torus coating was the lack of tarps to protect uncoated areas from the spraying of coating in nearby areas. Despite the work instructions calling for tarps, they were not used. A review of the work instructions later revealed steps were inappropriately marked as complete or not applicable (N/A)inappropriately.
 
Besides evaluating the extent of the condition of the failure to follow site processes for execution of the torus work instructions, CARD 2227942 sought to identify the causes of the issues. NRC review of this CARD revealed that the licensee correctly identified several instances of contractors not following site processes. Examples included how to mark steps as complete, how to use a 'N/A,' and when and by whom steps should be marked off. As a result, the inspectors determined supplemental personnel control associated with the torus recoat project was inadequate. CARD 2227942 identified a potential reason:
a new-tonuclear, non-proficient worker had been selected to ensure steps for the torus project were complete and marked appropriately. While the licensee's CARD stated it was contractor supervision who placed the worker in that position, the inspectors noted site procedure MGA31 had requirements for licensee personnel: such as ensuring contractors had specific training assigned based on needs.
 
Additionally, the procedure requires updated information to be communicated to the contractors with sufficient time so that they can acquaint workers with the new information (an apparent decision not to use tarps was made but not conveyed to the individual signing for steps in the work instructions). Step 5.4.7 requires observations of work activities to check adherence to station policies and procedures. Step 5.4.1 requires vendor oversight plans to be developed. The licensee's evaluation in CARD 2227942 did not explore if there were shortfalls with the last two requirements on behalf of licensee personnel. If observations and oversight plans were, in fact, part of the project, they were ineffective at detecting the gaps in contractor performance.
 
Corrective Actions: The licensee entered the issue into the corrective action program.
 
Corrective Action References: CARD 2227942
 
=====Performance Assessment:=====
Performance Deficiency: Contrary to requirements in MGA31, Supplemental Personnel Control Practice, the licensee did not provide adequate oversight of supplemental workers associated with the 2020 torus recoat project.
 
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, inadequate supplemental worker oversight partly contributed to degraded conditions in the torus. The issue also screened as more than minor under the barrier integrity cornerstone, as the torus forms part of the primary containment barrier.
 
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power. The end result of the performance deficiency was a questioning of the operability of the torus given the degradation that occurred. Under the mitigating systems cornerstone, questions 26 in section A of exhibit 2 were answered 'no.' Further, under the barrier integrity cornerstone, questions 12 under section C of exhibit 3 were also answered 'no.'
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Following the 2020 and 2022 refueling outages, after-action reviews and input from external stakeholders revealed weaknesses in the outage planning and preparation process that drove poor outage performance, to include planning for and managing contract work onsite.
 
=====Enforcement:=====
Inspectors did not identify a violation of regulatory requirements associated with this finding.
 
Some Industry Standards Not Incorporated into Torus Recoat Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200404 Open/Closed
[H.11] -
Challenge the Unknown 71152A A Green finding with an associated Non-cited violation (NCV) of 10 CFR 50 appendix B, criterion V, "Instructions, Procedures, and Drawings," was self-revealed while inspecting the torus during the RF21 refueling outage (spring 2022). Some areas of degradation were observed that were unexpected given the torus had been recoated during the previous refueling outage. Upon further review, the licensee identified that some applicable industry standards had been omitted from the torus recoat procedures, and certain portions of the work instructions were not followed.
 
=====Description:=====
During the spring 2022 refueling outage, RF21, the inspectors opened an indepth PI&R sample to review the effectiveness of corrective actions taken during the prior outage (spring 2020) regarding the recoating of the inside of the torus. The inspection sample involved degradation, which developed before 2020, and the licensee's inadequate tracking and assessment of that degradation over time, was the subject of an NRC special inspection in 2019. The results of the special inspection are documented in inspection report 05000341/2019050 (ML20031D253). A confirmatory action letter also resulted from the special inspection, which prompted the entire recoating of the torus in 2020.
 
Following the identification of the degradation, the licensee worked with various vendors and consultants to assess the impact on the torus's operability and to determine a cause.
 
Degradation ranged from small areas of rust deposits to small bubbles that appeared on the surface. The areas in question were spread throughout the torus in discrete locations. The licensee concluded the total degraded area was far below that which would call into question the operability of the torus. This conclusion was supported by a series of 'pull-tests,' which validated that areas surrounding the pockets of degradation had sound, tightly adhered coating. Inspection by the onsite resident inspectors, region-based inspectors involved with the 2019 special inspection, and experts from NRC headquarters did not find any issues with the licensee's conclusion. The licensee developed several theories on how the degradation originated and documented the conclusions in CARD 2222967 via an equipment cause evaluation.
 
Essentially, the licensee concluded several factors likely led to the areas of degradation.
 
Ultimately, the licensee determined inadequate work instructions for the torus recoat project were the cause because several of the contributing factors were not properly accounted for in the work instructions. One example involved time elapsed between 'stripe coating' and application of the main coating (stripe coating being areas 'cut-in' prior to the main spray of coating). The licensee concluded that during the project, between 2.5 and 7.5 hours elapsed between stripe coating and spraying in the various areas. During the licensee's investigation, several industry references discovered pointed to a much shorter time (< 10 minutes) being appropriate to prevent a phenomenon known as 'amine blush' from occurring, which can affect coating adherence. As another example, testing for specific surface contaminants such as chlorides was not directed by the work instructions. While certain industry standards regarding surface preparation were followed, the fact the torus remained 'prepped' for coating for an unexpectedly long period (due to COVID impacts) should have prompted a check for contaminants that may not have otherwise been present had the torus been promptly coated.
 
In addition, the work instructions called for tarps to protect uncoated areas from the
'overspray' of other areas being coated. Steps for installation of the tarps were marked complete; however, a later investigation by the licensee revealed the steps had not been performed. It appears that as the project was progressing, the use of tarps was being debated given a change in coating strategy that had occurred and the speed at which activities were progressing. Per licensee processes, if a decision to not use tarps had been made, the work instructions should have been updated accordingly. Areas not protected from overspray may have led to some of the degradation noted.
 
Corrective Actions: The licensee performed tests to confirm the coating in general was satisfactorily applied. Select areas were repaired, and evaluations were performed to verify operability of the coating in the asfound and goforward conditions.
 
Corrective Action References: CARD 2222967 documented an equipment cause evaluation and organizational effectiveness cause evaluation.
 
=====Performance Assessment:=====
Performance Deficiency: The implementing work instructions for the torus recoat project were inadequate and certain portions were not followed.
 
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, unexpected degradation was noted on the interior torus coating after one cycle of operation, calling into question the ability of the coating to remain intact during accident conditions (which can impact the suctions of safety related pumps aligned to the torus). The inspectors also determined the issue was more than minor under the barrier integrity cornerstone, as inadequate coating can also impact the primary containment barrier.
 
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.
 
Specifically, under the mitigating systems cornerstone, questions 26 in section A of exhibit 2 were answered 'no.' Further, under the barrier integrity cornerstone, questions 12 under section C of exhibit 3 were also answered 'no.'
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the inspectors utilized the associated common language attribute (QA.2) from NUREG2165, Safety Culture Common Language, to inform assignment of an appropriate cross-cutting aspect. Applicable tenets of QA.2 include:
 
"Leaders reinforce expectations that individuals take time to do the job right the first time, seek guidance when unsure, and stop if unexpected conditions are encountered."
 
"Individuals maintain a questioning attitude during pre-job briefs and jobsite reviews to identify and resolve unexpected conditions."
 
"Individuals stop work activities when confronted with an unexpected condition, communicate with supervisors, and resolve the condition prior to continuing work..."
 
"If a procedure or work document is unclear or cannot be performed as written, individuals stop work until the issue is resolved."
 
The dynamic nature of the COVID health emergency led to changing conditions (e.g., longer period between surface preparation and coating) that presented opportunities to revalidate appropriate standards and controls in the work instructions that may have prevented the scope of degradation. Further, work was not stopped when the instructions could not be performed as written when it was decided to not use tarps.
 
Besides the work instructions for the coating, the inspectors also broadened their review to other work activities that were part of the torus project. The attributes of H.11/QA.2 were lacking in several areas throughout the project. A worker was injured when others saw an unsafe platform but did not stop the job before the injury. When workers in the torus questioned the speed at which material was being hoisted out of the torus, workers above told them multiple times that they would not slow down. In approaching the unknowns associated with confined space rescue in a fully drained torus, the necessary practice and coordination for such a complex activity was not provided prior to start of work. This missed opportunity was only realized when the rescue team was called out for an injury after work had started.
 
=====Enforcement:=====
Violation: 10 CFR 50 appendix B, criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. Contrary to the above, during the spring 2020 refueling Outage (March 2020-August 2020) and until discovery the following refueling outage (which commenced in February 2022), the licensee did not prescribe documented instructions appropriate to the circumstances, nor accomplish activities in accordance with appropriate instructions, for activities affecting quality. Specifically, the instructions associated with recoating the safety related torus lacked steps to help prevent degradation of the coating.
 
Further, some steps intended to protect the new coating were in the instructions but not followed.
 
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
 
Failure to Perform a Required Code Evaluations for Standby Liquid Control System Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200405 Open/Closed
[H.12] - Avoid Complacency 71152A The inspectors identified a Green finding with an associated Non-cited violation (NCV) of 10 CFR 50.55a, "Codes and Standards," for the licensees failure to follow the ASME Code after discovering boric acid leakage in the standby liquid control system (SLC). Specifically, a code required evaluation was not performed as an alternative to correction actions.
 
=====Description:=====
During a review of condition assessment resolution documents (CARDs) as part of the indepth PI&R baseline inspection sample, the inspectors reviewed CARD 2230062, initiated on October 2, 2022. This licensee-identified CARD described evidence of borated water leakage from a flanged connection between the SLC system tank and heater C4101S002 during planned VT2 examinations. While no active leakage was noted, the CARD mentioned that this was a repeat issue from CARD 1927781, initiated on October 11, 2019. While reviewing 1927781, the inspectors noted that CARD 1826451 (created August 27, 2018)had also documented the same borated water leak (however, this was not during a Code VT2 exam). Per section XI of the 2013 ASME Code, specifically IWA5250 and IWA5251, leaks of this nature require one of two primary activities to be accomplished following identification. One option described in IWA5250 involves removing a bolt from the affected connection and performing a VT3 exam with a subsequent evaluation of it and the remaining bolts. Alternatively, a licensee could opt to replace all bolts. The other option, described in IAW5251, involves the performance of an evaluation of the joint following IWA5251(c).
 
Corrective action for CARD 1826451 did not involve either code-required option. The licensee generated a work order, but as of the issuance of 1927781 (a little over a year later), the work order still needed to be prepared. After identifying the issue again in 1927781, the corrective action was to create a work order to accomplish the requirements of IWA5250 during the RF20 refueling outage (spring of 2020). While the licensee provided some facts supporting operability, they did not perform an evaluation involving the criteria listed in IWA5251(c). During RF20, the licensee removed the work activity to do the repairs and/or inspections to satisfy IWA5250. An evaluation per IWA5251 was also not completed at that time.
 
NRC inspector review of the most recent CARD identifying the leakage (2230062) revealed that despite the cancellation of the work order in RF20, the licensee did not put actions in place to schedule the work during RF21, the spring 2022 refueling outage. In response to NRC questions, the licensee generated CARD 2230116 to document that fact. After further discussions with the NRC, the licensee completed an evaluation per IWA5251(c) in December 2022. The inspectors reviewed the evaluation and noted that the licensee had also identified a similar situation existed for another SLC system component. The licensee identified a possible body-tobonnet leak on C4100F001, the SLC storage tank isolation valve, on October 2, 2022. This leakage had also been identified previously in 2019, along with the C4101S002 leakage, but did not have the appropriate action taken per IWA5251(c).
 
The inspectors reviewed the evaluation performed for both components and did not have an issue with the licensee's conclusions that the components remained operable.
 
Corrective Actions: The licensee performed an evaluation per IWA5251(c) to demonstrate operability of affected components.
 
Corrective Action References: CARDs 2230062, 2230061, and 2230116
 
=====Performance Assessment:=====
Performance Deficiency: Following discovery of borated water leakage from SLC system components, the licensee did not perform the required actions set forth in the ASME Boiler and Pressure Vessel Code, section XI, 2013 edition (the edition the licensee is committed to).
 
Specifically, the evaluation described in IWA5251(c) to demonstrate acceptable continued operation after choosing to not perform the actions in IWA5250, was not performed.
 
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, continuing to not repair nor perform evaluations per the ASME Code for degraded safety-related components could lead to further degradation where operability could be a concern.
 
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.
 
Specifically, after reviewing the evaluation performed by the licensee, the inspectors answered 'no' to all of the questions in section A of exhibit 2 regarding impacts to operability.
 
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee deferred work on the degraded components but did not recognize until after the following refueling outage an opportunity had been missed to perform the work. Additionally, specific ASME Code requirements were not recognized despite multiple instances of identifying the same evidence of borated water leakage.
 
=====Enforcement:=====
Violation: 10 CFR 50.55a, Codes and Standards, incorporates by reference the ASME Boiler and Pressure Vessel Code, section XI, Rules for Inservice Inspection of Nuclear Power Plant Components-Division 1, 2013 addenda. Section IWA5251 of the Code states, in part, that as an alternative to corrective action under IWA5250 for leakage at bolted connections in systems borated for the purposes of controlling reactivity, an evaluation incorporating the criteria of IWA5251(c) can be performed to evaluate the consequences of continuing operation. Contrary to the above, since identification of conditions covered by IWA5250/5251 on October 11, 2019, for safety-related SLC components C4101S002 and C4100F001, until an evaluation was performed on December 13, 2022, the licensee did not complete evaluations in accordance with the requirements of IWA5251(c).
 
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
 
Observation: Corrective Action Program Product Quality 71152S The inspectors identified a potential negative trend in CAP execution and product quality. The issues identified by the inspectors were discussed with licensee management in the applicable departments, along with the performance improvement department. The licensee recognizes the issue and, in addition to revising some of the products in question, has created plans to improve and validate product quality. One example was the creation of a monthly condition assessment resolution document (CARD) closure quality reviews to be done by each department and NQA. Specific issues are listed below:
 
The inspectors reviewed the causal evaluation associated with the scram in June of 2022 caused by a swarm of mayflies. The evaluation indicated problems between security and operations regarding working together to establish a plant lighting strategy. Further, it identified one of the causes as not utilizing the "DTE Mayfly Infestation Plan." There were also references to other site or departmental issues unrelated to the event. After questioning the licensee for more contextual information, the inspectors learned DTE never had an infestation plan until after the event occurred. Also, there wasn't a problem of security and operations resolving differences; rather, there was no discussion following the 2020 mayfly event to explore what could be done regarding the lighting. The licensee revised the evaluation to address those items and remove references to issues not relevant to the event.
 
The inspectors reviewed the root cause evaluation associated with the February 2022 scram caused by a feedwater transient. While not having an issue with the root cause or proposed corrective actions, the inspectors uncovered more detail behind the
'legacy procedural issue' for securing a feed pump that appeared relevant to the cause and could inform future modifications to the procedure. The inspectors determined the legacy procedure issue stemmed from a specific procedure change in 2001 that changed how plant operators managed the feed pump speed and the minimum flow control valve during the shutdown.
 
The inspectors reviewed the corrective action tools used to assess the actuator/yoke separation of a primary containment isolation valve and determined the performance gap analysis was too narrowly focused for the issue. Concurrently, site management also identified the issue, and as a result, a more detailed organizational cause evaluation was conducted.
 
The licensee NQA organization identified a trend in December 2022 which highlighted several failed causal evaluation products. One particular product involved responding to an NRC non-cited violation (NCV) regarding reporting requirements. The inspectors noted that before the most recent NCV, another NCV in the same area from 2020 had been documented, indicating difficulty in achieving sustainable corrective actions for reportability issues.
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
 
On January 25, 2023, the inspectors presented the integrated inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee staff.
 
On November 4, 2022, the inspectors presented the ISFSI interim exit inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee staff.
 
On November 10, 2022, the inspectors presented the triennial heat sink inspection results to B. Sullivan and other members of the licensee staff.
 
On December 1, 2022, the inspectors presented the emergency action level and emergency plan changes inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee staff.
 
THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Operations mid-cycle assessment reports that were issued during the inspection period.
 
=DOCUMENTS REVIEWED=
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
24210
NQA - Holtec Field Condition Report
06/03/2019
2031838
ISFSI Helium Backfill Volume Calculation Uncertainty
11/02/2020
Corrective Action
Documents
2130193
MOP11 Requires Revision for Combustible Material in ISFSI
Building
11/16/2021
Corrective Action
Documents
Resulting from
Inspection
230743
No Written Evaluation Performed per 10 CFR 72.212(b)(7)
10/31/2022
CFR 72.212 Report
2.48 Screen
200003
EDP 80028
Miscellaneous
2.48 Screen
200005
WO 57799481
Procedures
MRP04
Radiation Protection Conduct Manual
PM202106286
ISFSI Pad
06/28/2021
PM202111242
ISFSI Pad
11/24/2021
PM2022062912
ISFSI Pad
06/29/2022
Radiation
Surveys
PM202210079
ISFSI Pad
10/07/2022
Self-Assessments Audit Report
20103
ISFSI Program
05/16/2022
49479374
HISTORM Annual Inspection
10/07/2019
206872
Perform 35.710.055 HISTORM Monthly Screen Inspection
03/28/2020
2805754
HISTORM Annual Inspection
11/04/2020
56125177
Perform 35.710.055 HISTORM Monthly Screen Inspection
05/19/2021
57629881
HISTORM Annual Inspection
10/20/2021
57799481
Contingency ISFSI Haul Path
06/25/2020
60855
Work Orders
58429284
Perform 35.710.055 HISTORM Monthly Screen Inspection
01/27/2022
2032050
22 Seasonal Readiness-Cold Weather Preps Milestones
Tracking - Refuel Outage Dates
11/06/2020
71111.01
Corrective Action
Documents
230324
Request Drawing Update to Shore Barrier Drawings
Following Yearly Survey
10/12/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
230675
Alternate Diesel Fire Pump Enclosure Heater Not
Functioning Correctly
10/27/2022
230812
Additional Information and Engineering Support Required to
Troubleshoot U4100F171A
11/02/2022
Corrective Action
Documents
Resulting from
Inspection
230305
NRC Identified-Bolt Missing from Pin on Door R18
10/11/2022
6A7212071
Reactor and Auxiliary Building Door Schedule and Types
09/06/2022
6M7215720
Circulating Water System Functional Operating Sketch
03/18/2022
Drawings
6M7215726
General Service Water System Functional Operating Sketch
10/10/2018
23.101
Circulating Water System
107
23.131
General Service Water System
114
23.208
RHR Complex Service Water Systems
134
35.000.242
Barrier Identification/Classification
Procedures
MWC16100
Seasonal Readiness
0900177
Packing Leak: Div. 2 Core Spray Keep Fill Isolation Valve
Has 2 dpm Packing Leak
01/05/2009
Corrective Action
Documents
CARD 1821676
Division 2 Core Spray Fill Outlet Isolation Valve Swing Bolt
Broken
2/27/2018
6M2712015
Diagram Station and Control Air
04/26/2022
6M2715706-3
RHR Service Water Make-Up Decant and Overflow Systems
Functional Operating Sketch
03/15/2022
6M7212034
Diagram Core Spray System C.S.S Reactor Building
04/09/2022
6M7212084
Diagram Residual Heat Removal (RHR) Division 1
03/17/2022
6M7212084
Diagram Residual Heat Removal Division 1
BS
6M7212135
Diagram Fire Protection System (Sheet 1)
BA
6M7212135-1
Diagram Fire Protection System (Sheet 2)
BL
6M7215444
Emergency Equipment Cooling Water Division 1
03/15/2022
6M7215707
Core Spray System Functional Operating Sketch
04/09/2022
71111.04
Drawings
6M7215721-1
Condensate Storage and Transfer System Functional
Operating Sketch
03/26/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
6M7215729-1
Emergency Equipment Cooling Water (Division 1)
Functional Operating Sketch
03/15/2022
6M7215729-2
Emergency Equipment Cooling Water (Division 2)
Functional Operating Sketch
04/23/2022
6M721N2052
P&ID RHR Service Water System Division 1 RHR Complex
03/15/2022
Miscellaneous
Division 1 RHR LPCI Standby Lineup Verification,
8A
149
23.127
Reactor Building Closed Cooling Water/Emergency
Equipment Cooling Water System
2
23.127
1A
Div. 1 EECW Valve Lineup
09/21/2021
23.127
2A
Div. 1 EECW Electrical Lineup
04/09/2006
23.127
3A
Div. 1 EECW Instrument Lineup
11/15/2010
23.127
DIV RBCCW/ECCW Standby Verification Checklist
2/11/2021
23.129
1C
NIAS Valve Lineup
07/30/2015
23.129
Station and Control Air System Electrical Lineup
04/06/2009
23.129
3A
Station and Control Air System Instrument Lineup
01/27/2009
23.129
Div. 1 Control Air Standby Verification Checklist
01/11/2010
23.203
1B
Core Spray System: Div. 2 Initial Valve Lineup
11/15/2002
23.203
1C
Core Spray System: Common Initial Valve Lineup
01/08/2001
23.203
2B
Core Spray System: Div. 2 Electrical Lineup
11/15/2005
Procedures
23.203
3B
Core Spray System: Division 2 Instrument Lineup
04/07/2009
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
23.203
5B
Core Spray System: Div. 2 Initial Fill and Vent Independent
Verification Checklist
01/11/2010
23.203
6B
Shifting Div. 2 Core Spray Suction to CST Independent
Verification Checklist
03/03/2020
23.203
6D
Shifting Div. 2 Core Spray Suction to Torus Independent
Verification Checklist
03/14/2020
23.203 Enclosure
A
Core Spray Manual Operation
11/27/2018
23.205
Residual Heat Removal System
149
23.208
RHR Complex Service Water Systems
134
23.208
1A
Div. 1 RHRSW Valve Lineup
01/24/2022
23.208
2A
Division 1 RHRSW Electrical Lineup
01/24/2022
23.208
3A
Division 1 RHRSW Instrument Lineup
01/19/2006
23.303
6B
Shifting Div. 2 Core Spray Suction to CST Independent
Verification Checklist
03/03/2020
23.309
Division 1 Distribution System Electrical Lineup
2/09/2020
6SD7212530-10
One Line Diagram 260 /130V ESS Dual Battery 2PA
Distribution-Division 1
03/16/2022
Work Orders
294552
CS Division 2 Discharge Header Keep Fill E21F026B PCV
Outlet Isolation Valve
2/19/2022
FPRBB2b
Reactor Building Basement Northwest Corner Room,
Zone 2, EL. 562'0"
FPRBB3b
Reactor Building Basement Southwest Corner Room,
Zone 3, EL. 562'0"
FPRBSB2a
Reactor Building Sub-Basement Northwest Corner Room,
Zone 2, EL. 540'0"
Fire Plans
FPRBSB3a
Reactor Building Sub-Basement Southwest Corner Room,
Zone 3, EL. 540'0"
71111.05
Procedures
FPRB315a
Reactor Building Thermal Recombiner System Area, Zone
15, EL. 641'6"
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
FPRB417a
Reactor Building SLC System Zone 17 EL. 659'6"
FPRBSB5A
Reactor Building Sub-Basement Northeast Corner Room
Zone 5 EL 540'0"
231531
Extent of Condition Walkdown Revealed More Degraded
MELB Barriers
2/02/2022
Corrective Action
Documents
231541
Walkdown of Division 1 SWRG for Possible Spray Barrier
Issues
2/02/2022
231414
NRC Identified: Spray Cover in Division 2 Switchgear Room
Degraded
11/29/2022
231415
NRC Identified: Pipe Cap Near P4400F449 Not Enclosed by
Spray Guard
11/29/2022
231417
NRC Identified: Metal Enclosure on AB4 Not Sealed at Floor
Level
11/29/2022
231419
NRC Identified: Piping Above HVAC Ducting on AB4 East
Side Is Not Fully Enclosed in Blue Spray Guard
11/29/2022
231505
NRC Identified: Degraded Spray Shield on Division 1 EECW
Piping
2/01/2022
231505
NRC Identified: Degraded Spray Shield on Division 1 EECW
Piping
2/01/2022
231518
NRC Identified: Degraded MELB Barrier on Drywell Seal
Rupture Drain to Condensate Storage Tank
2/01/2022
231571
NRC Identified: Work Order completed on 7/2/2019 Is Not
Vaulted in Webarms
2/05/2022
Corrective Action
Documents
Resulting from
Inspection
231571
NRC Identified: Work Order Completed on 7/2/2019
2/05/2022
EF2PRA011
Internal Flood Walkdown Summary Notebook
Miscellaneous
EF2PRA012
Internal Flood Analysis Notebook
71111.06
Work Orders
49771630
Perform Inspection of Spray Shrouds
01/29/2018
DC0249
RBCCW Hydraulics and Miscellaneous EECW Calculation
K
DC0559
Vol I: Volume of Reservoir
F
DC4931
Non-Interruptible Control Air System (NIAS) Calculations
J
Calculations
DC6286
EECW Heat Exchanger Performance Requirements with
Plugging
A
71111.07T
Corrective Action
1830419
MDCT A and B Fan Brake Nitrogen System Leaking
2/28/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
27521
Unexpected Increase in Div 1 EECW Heat Exchanger
Differential Pressure After Recent Swap
10/03/2019
27978
Trend in Anomalous System Parameter Measurements
During Surveillances
10/21/2019
28324
2019 NRC Triennial UHS Inspection: Average Silt
Accumulation in UHS Reservoir Was Not Calculated in WO
47534163
10/31/2019
23408
Division 1 Ultimate Heat Sink General Foreign Material
(Found and Removed During Diving)
03/28/2020
23984
Unrecovered Foreign Material - Orange Zip Tie
04/07/2020
2030217
20 MMR14 Structures Monitoring Inspection of RHR High
Roof (WO)
09/14/2020
25607
Unknown Substance Coating Corrosion Coupon Holder
06/24/2021
28982
Housekeeping Concerns on RHR Complex Roof
10/08/2021
22162
Review of RHR Div 1 Reservoir Diving Reports
2/20/2022
22580
Abnormal Moss Buildup and Debris Noted During Div 1 UHS
Diving
2/24/2022
Documents
24712
Completion of RF21 RHR Div 2 Reservoir Inspection
Reports and Videos / Photos
04/05/2022
230458
22 NRC Heat Sink Inspection: Degraded Concrete Noted
on Pedestal Supports for EDGs 11, 12, 13, and 14 Exhaust
Mufflers
10/18/2022
230462
22 NRC Heat Sink Inspection: Poor Housekeeping Noted
During Walkdown
10/18/2022
230463
22 NRC Heat Sink Inspection: Partial Blockage Noted on
South RHR Pump Pump Room HVAC Outside Air Inlet
10/18/2022
230480
WO Needed to Address Moss and Weeds on RHR Roof
10/19/2022
230492
22 NRC Heat Sink Performance Inspection: External
Corrosion Identified on Floor Penetration Sleeve
10/19/2022
230506
22 NRC Heat Sink Inspection: Nitrogen Cylinders Not
Correctly Labelled
10/22/2022
230516
22 NRC Heat Sink Performance Inspection: Enhancement
Needed to PM Events P244 and P245
10/20/2022
Corrective Action
Documents
Resulting from
Inspection
230549
Performance Engineering Extent of Condition per CARD
10/21/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
230538
230666
22 NRC Heat Sink Performance Inspection: Exterior Tape
on Service Water Piping in RHR Complex
10/27/2022
6M7212015
Diagram Station and Control Air
CU
6M7215357
Emergency Equipment Cooling Water System Division II
BW
MN2026
General Arrangement RHR Complex Basement Floor Plan
E
MN2031
General Arrangement RHR Complex Section "CC"
F
Drawings
MN2050
Equipment Drains and Floor Drains Divisions 1 and 2 RHR
Complex
O
Commercial Diving and Marine Services Fermi RF21 Outage
Diving Div 1
2/21/2022
Commercial Diving and Marine Services Fermi RF21 Outage
RHR Div 2 Dive Report
03/28/2022
Miscellaneous
Consumable
Materials
Evaluation (CME)
210011
Cryotech CMA
01/15/2021
1D88
Division 1 EECW Outlet Temp
20.127.01
Loss of Reactor Building Closed Cooling Water System
20.129.01
Loss of Station and/or Control Air
23.127
Reactor Building Closed Cooling Water / Emergency
Equipment Cooling Water System
151
23.129
Station and Control Air System
24
23.208
RHR Complex Service Water Systems
134
24.000.02
Shiftly, Daily, and Weekly Required Surveillances
161
7D3
Div 1 RHR Reservoir Level Abnormal
E11XX
Residual Heat Removal Service Water (RHRSW) System
Design Basis Document
E
MES 52
GL 8913 Safety Related Service Water Monitoring Program
10A
MES 54
Heat Exchanger Component Monitoring Program
MMA10
System Cleanliness
MMA17
Foreign Material Exclusion (FME)
Procedures
MMR14
Structures Monitoring
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MOP21
Housekeeping
2194616
License Renewal Required Perform Div 1 Reservoir Zebra
Mussel Inspection Dive
03/25/2020
2195243
License Renewal Req'd Perform Div 2 RHR Reservoir Zebra
Mussel and Ball Valve Inspection Dive
04/08/2020
269374
License Renewal - Perform Div 1 RHR Reservoir Zebra
Mussel and Ball Valve Inspection Dive [Confidential]
2/13/2022
Work Orders
269883
License Renewal - Perform Div 2 RHR Reservoir Zebra
Mussel and Ball Valve Inspection Dive
03/27/2022
71111.11A
Miscellaneous
22 LOR NRC
Annual OP Test
Summary
Fermi 2022 Licensed Operator Requalification Exam
Summary Which Provides the Exam Results for the Annual
Operating Tests Administered from 10/11/2022 - 11/10/2022
11/21/2022
LPOP2022225
Containment Tech Specs and EALs
SSOP2022243
Simulator Lesson Plan
Miscellaneous
SSOP9042283
Fermi 2 Evaluation Scenario
24.202.01
HPCI Pump and Valve Operability Test at 1025 psi
23
29.100.01 SH 1
RPV Control
29.100.01 SH 2
Primary Containment Control
29.100.01 SH 6
Curves, Cautions, and Tables
ODE10
Emergency Operating Procedure Expectations
71111.11Q
Procedures
ODE3
Communications
23026
Reactor Scram Due to Loss of 64 Transformer
04/14/2018
2000399
TIP Detectors Retracting One Inch Behind the Programmed
InShield Position
01/06/2021
21388
TIP E Flux Readings Degrading Rapidly
07/28/2020
26872
TIP C and TIP D Ball Valves Opened with TIPS InShield
06/22/2020
22080
ITE Type K600-s Breakers Failed to Close
03/08/2021
22886
Nova Inverters Found OOT
03/01/2022
23206
Bus 72EB Pos 2D Failed to open
03/07/2022
23772
Nova Inverter Tech Evaluation for Frequency Needed Due
to Frequency Adjustment Issues
03/17/2022
Corrective Action
Documents
26656
Ground Fault on 72U, Loss of Bus
05/28/2022
71111.12
Drawings
6I7212421-05
Schematic Diagram RBCCW Supplemental Cooling Division
04/08/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Cooling Pumps
N/A
R1400 Electrical Switchgear 2021 Quarters 2 and 3 System
Health Report
21
R1400
R1400 Electrical Switchgear System Get Well Plan (GWP)
Miscellaneous
VMC1545
Installation and Operations Manual for Nova Electric Galaxy
Inverter
MMR APP B
Maintenance Rule Conduct Manual Appendix B-Terms and
Definitions
Procedures
MMR APP E
Maintenance Rule Conduct Manual Appendix E-
Maintenance Rule SSC Specific Functions
R1400 Electric Switchgear System Health Q2 and Q3 2021
R1400 Electric Switchgear System Health Report Q4 2020
Self-Assessments
R1400 Electric Switchgear System Health Q4 2021
230935
Relay Room H11P613
11/07/2022
Corrective Action
Documents
231390
MDCT Fan 'B' Loud Metallic Noise
11/28/2022
6I7212045-28
Internal-External Wiring Diagram Division 1 Process
Instrumentation Cabinet H11P613 Part-3
AG
Drawings
6I7212265-02
Schematic Diagram Reactor Water Cleanup System
Instrumentation
AK
MWC15001
Risk Management Plan for South RFP Suction Line Flow
Switch Low Source Valve Leak
2/20/2022
Miscellaneous
VMR11.18
Millivolt to Current (MV/1) Transmitter
A
MMR 12
Equipment Out of Service Risk Management
20A
Procedures
MMR Appendix H
Online Core Damage Risk Management Guidelines
71111.13
Work Orders
60510175
East Gland Seal Exhaust Motor Replacement
11/02/2022
Corrective Action
Documents
Resulting from
Inspection
28738
MES27 Evaluation Does Not Support the Immediate
Operability Determination Assumptions in CARD 2228664
08/15/2022
TEE1122-034
E1156C001B Mechanical Draft Cooling Tower Noise
Engineering
Evaluations
TER3022-068
Licensing Basis for the Effect of Tornado Depressurization
on a Running EDG
A
71111.15
Miscellaneous
Adverse Condition B310F010B RRP B Seal Purge Regulating Valve
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Monitoring Plan
20010
DBD XXX02
Design Basis Document
Various
Various NRC Guidance Documents Pertaining to Operability
and the Meaning of Design Basis
Various
20.307.01
Emergency Diesel Generator Failure
2.307.01
Emergency Diesel Failure
Procedures
23.138.01
Reactor Recirculation System
119
Corrective Action
Documents
230843
PT FD76 Issues and EDM Impact
11/03/2022
230932
NRC Identified: RB5 EDM Equipment Box Label Not Correct
11/07/2022
Corrective Action
Documents
Resulting from
Inspection
231503
NRC Identified Issue: 29.EDM.07 Procedure Issue
2/01/2022
Drawings
29.200.xx
29.200 series Severe Accident Management Guidelines
Flowcharts
various
Engineering
Changes
60106
Vehicle Barrier System Modification at Entrance to Alternate
Access Portal
Miscellaneous
NEI 1401
Emergency Response Procedures and Guidelines for
Beyond-Design-Basis Events and Severe Accidents
29.EDM.03
SFP Makeup/Spray - External Strategy
29.EDM.07
Passive Ventilation of the Air Space Above the Fuel Pool
[Confidential]
78.000.69
Chemistry Special Test Procedure
71111.18
Procedures
MGA 14
Severe Accident Management Program
28853
T4100B007 Above Its Investigative Limit
08/18/2022
230081
T41N227A AsFound Condition Not Functioning During the
Performance of WO 46289018
10/03/2022
230085
T4100 Failed PMT
10/03/2022
Corrective Action
Documents
230087
Unidentified Contingency Parts / Planning Impact
10/04/2022
6I7212451-13
Schematic Diagram NIAS Div. 1 Dryer Controls
06/02/2016
6M7215707
Core Spray System Functional Operating Sketch
04/09/2022
71111.19
Drawings
6M7215730-3
Non-Interruptible Control Air System Division 1 and 2
03/29/2012
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Functional Operating Sketch
IS248103B
EDP 80165.022 (Fermi 2 Diesel Fire Pump Modification
Alarm Circuitry)
11/08/2022
Engineering
Changes
EDP 80165
Fermi 2 Diesel Driven Fire Pump Replacement Modification
44128550
Calibrate Div. 1 CCHVAC Chiller Condenser EECW Outlet
Flow Switch
10/03/2022
289018
Calibrate Div. 1 CCHVAC Emergency Make-up and Recirc
Air Temperature Switch
10/03/2022
264945
PDMA Testing (Motor Tagged) of Control Air Compressor
Room Cool Unit
11/02/2022
48640608
Replace Div. 1 Control Air Non-Interruptible Air Supply
Isolation Valve Solenoid Valve
11/02/2022
48860374
Calibrate Div. 1 CCHVAC Chiller Evaporator Low
Temperature Switch
10/03/2022
57420071
License Renewal Replace Suction and Discharge Valves
with New and Refurbished Valves
11/02/2022
58187204
Replace Non-Interruptible Air Supply Solenoid Valve
11/02/2022
58471305
Control Air Non-Interruptible North Control Air Dryer West
Chamber Relief Valve
11/02/2022
61353693
Replace Division 1 North Control Air Compressor Unloading
Cylinder Solenoid Valve
11/02/2022
61563113
Calibrate Division 1 CCHVAC Equipment Room
Temperature Switch
10/03/2022
63600050
Test Division1 CCHVAC Zone 2 Cable Spreading Room
Mixing Damper Temperature Loop
10/03/2022
64193098
7D51 Division 1 Control Air System Trouble Due to High
Differential Pressure. Calibrate or Replace
11/02/2022
Work Orders
66000026
Post Mod Testing for EDP 80165
11/23/2022
22892
EDG 11 DGSW Pump Min Flow Valve Not Indicating Fully
Closed
06/28/2004
25803
Rework EDG11, 12, and 14 DGSW Minimum Flow Valves
11/19/2004
71111.22
Corrective Action
Documents
23411
Step Change in RB Steam Tunnel Temperature Due to
Possible HPCI Steam Leak
04/16/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
26208
Rounds Needs Updated
05/11/2022
29106
Increased Unidentified Leakage in Drywell DD72 Sump
During Division 2 EECW Pump and Valve Surveillance
24.107.09 Section 5.1
08/29/2022
29187
Drywell Unidentified Leakage Update
08/31/2022
29282
Drywell Sump Leakage Increase
09/02/2022
29536
Performing MMA26 for CARD 2227022 DW Unidentified
Leakage
09/14/2022
230145
R30F402 Indicating 10 Percent Open When Valve Should
Be Closed
10/05/2022
230170
No Flow, Suspect Drain Line Clogged
10/05/2022
231365
0.8" Step Change in Drywell Floor Drain Sump Level
Following Pumpdown
11/26/2022
231450
Investigation of Parameters Around a Run of HPCI
11/30/2022
Corrective Action
Documents
Resulting from
Inspection
23089
NRC Concern - Operations Rounds Details on Safety-
Related Motor Oil Levels
03/04/2022
6I7212572-28
4160V ESS Buses 64B and 64C Load Shedding Strings
V
6I721257B-05
Relay and Metering Diagram 4160V ESS Bus 64B
U
6I721N257217
4160V ESS Diesel Bus 11EA Load Shedding Strings
Y
6I721N257806
Relaying and Metering Diagram Diesel Generator 11 Unit 2
X
6M7213361-1
Standby Liquid Control Pump, Reactor Building, Unit 2
P
Drawings
6SD7212500-03
One Line Diagram 4160V System Service Buses 64B, 64C
S
N/A
Control Room Narrative Logs from 11/13/2022 to
11/30/2022
11/30/2022
VMR147.1
Union Pump
B
VMR147.4
Gear Reducers
A
VMR162
Triclad Vertical Induction Motor
F
Miscellaneous
VMS2539
Centrifugal Water Chillers
L
24.207.09
Division 2 EECW Pump and Valve Operability
24.307.34
DGSW, DFOT, and Starting Air Operability Test EDG 11
Procedures
2.302.07
Calibration and Functional Test of Division 1 4160 Volt Bus
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
64B Undervoltage Relays
MES 49
Evaluation and Control of Leakage from Class 1, 2, and 3
Piping Systems
289097
Perform 3Year Performance Testing of N+1 Train
Dominator and Neptune Equipment
09/03/2021
264432
Perform 42.302.07 Division 1 Bus 64B 4160V Undervoltage
Relays Cal/Funct
10/06/2022
256368
Perform 3Year Performance Test of N Train Dominator and
Neptune Equipment
09/03/2021
61905540
Perform 24.307.34 Sec-5.1 and 5.2 DGSW and DFOT Pump
and Valve Operability Test - EDG 11
09/02/2022
Work Orders
66926147
Perform 24.20201 HPCI Pump/Flow Test and Valve Stroke
at 1025 psig
11/29/2022
2108E
50.54(q) Evaluation - Spent Fuel Pool Level Updates for
RA2.3, RS2.1, and RG2.1
09/21/2021
Miscellaneous
2135S
50.54(q) Screen - Spent Fuel Pool Level Updates for RA2.3,
RS2.1, and RG2.1
09/21/2021
EP101
Classification of Emergencies
43A
71114.04
Procedures
EP101
Classification of Emergencies
71114.06
Procedures
EP101
Classifications of Emergencies
24841
EDG Steady State Voltage and Frequency Tech Spec
Ranges
07/10/2013
26451
SLC Storage Tank Heater B Leak
08/27/2018
27780
VT2 Inspection Results - C4100F001
10/11/2019
27781
VT2 Inspection Results - C4101S002
10/11/2019
24915
CSRT Dry Run Findings
04/21/2020
27392
Safety Concern
06/28/2020
27659
Safety Concern - Questionable Decision Making Leading to
Error Likely Situation
07/05/2020
24291
3D17 IPCS Computer Trouble Due to Loss of SS1
05/16/2021
28792
SS1 CARD Documentation Requires Investigation
10/04/2021
21059
Product Failed EQRT
2/03/2022
71152A
Corrective Action
Documents
23915
Discrepancy Identified in RF20 Torus Recoat WO 55151575
03/19/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
25370
NQA RF21 - Complete MES 27 Risk Evaluation for CARD
24841
04/19/2022
25370
NQA RF21 - Complete MES 27 Risk Evaluation for CARD
24841
04/19/2022
28341
NQA Audit 220107 Deficiency - Untimely Actions for SPING
and SS1 Computer Replacement
07/29/2022
29030
SPING Flow Calibration Review
08/25/2022
230062
VT2 Exam Results - C4101S002
10/02/2022
230739
3D82 MS Steam Line Channel A/B/C/D Radiation Monitor
HiHi Due to Channel A
10/31/2022
231322
Non-Functional Category C EITER (EP580)
11/22/2022
231437
Evaluate Fermi Operating License 2.C.10 for Amendment
11/29/2022
230092
NRC Identified: Missed LER for Past Operability of CARD
27461
10/04/2022
Corrective Action
Documents
Resulting from
Inspection
230116
NRC Identified - Leaking SLC Bolted Connections not
Inspected During RF21
10/04/2022
6I7212095-14
Schematic Diagram Nuclear Steam Supply Shut Off System
Trip System A
O
6I7212185-03
Schematic Diagram Process Radiation Monitor SYS Main
Steam Line Rad Monitor Sub SYS D1103
N
Drawings
6I7212351-02
Schematic Diagram Condenser Vacuum Pump East
(N6101C001)
K
RERP Plan
U.S. Nuclear Regulatory Commission Regulatory Guide
2022 ISI/NDE-
IST Program
Evaluation Sheet
Standby Liquid Control Flange Leakage Evaluation
Equipment Cause
Evaluation
22967, RF21 MES 83114 Inspection - Torus Immersion
Space - Indications Identified in Coating on Bays 4 and 5
03/02/2022
HP Cause
Evaluation
24860, Worker Fell from Lower Work Platform
Miscellaneous
NEI 1503
Licensee Actions to Address Nonconservative Technical
Specifications
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RERP Plan
Radiological Emergency Response Preparedness Plan
2/18/2019
Operability
Evaluations
MGA 21
General Administrative Conduct Manual
EP101
A - Classification Matrix
EP546
RERP Plan Implementing Procedure
EP580
Equipment Important to Emergency Response (EITER)
Procedures
MGA 31
Supplemental Personnel Control Practice
27456
Ground Fault on YPhase on Output Form Main Unit
Transformer to CM and CF Output Breakers
06/27/2022
27461
FO 2201 Start Up Walkdown: MOV Actuator Disconnected
From Bonnet
06/27/2022
27473
Procedure Revision for Mayfly Infestation Preparation
Plan 27.322
06/27/2022
27475
Actuator Broke Free of Yolk Mounting Bolts - B2103F019
06/27/2022
27499
Add Circuits to 27.322 Mayfly Infestation
06/28/2022
231628
Trend in NRC Identified CARDs Related to MELB Spray
Shield Barriers
2/07/2022
231631
Procedure 23.107 Does Not Work as Written
2/07/2022
Corrective Action
Documents
231951
Evaluate Emerging Trend of Failed MRC Products
2/19/2022
Human
Performance
Cause Evaluation
230092 - NRC Identified: Missed LER for Past Operability
of CARD 2227461
09/13/2022
Miscellaneous
Organizational
Effectiveness
Cause Evaluation
27545 - Loss of 345kv Due to Mayfly Infestation
71152S
Procedures
27.322
Mayfly Infestation Preparation Plan
17, 23
Corrective Action
Documents
27388
HPCI and Div 2 EDG Sequencer Power Failures
08/22/2021
LER 2021001
Unrecognized Impact of Opening of Barrier Doors on High
Energy Line Break Analysis
LER 2022003
Turbine Trip and Subsequent Reactor Trip Due to Mayflies
71153
Miscellaneous
NRC220013
Licensee Event Report 2022001
04/04/2022
}}
}}

Latest revision as of 10:32, 27 November 2024

Integrated Inspection Report 05000341/2022004
ML23039A155
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/14/2023
From: Billy Dickson
NRC/RGN-III/DORS/RPB2
To: Peter Dietrich
DTE Electric Company
References
IR 2022004
Preceding documents:
Download: ML23039A155 (1)
v • d • e


Text

SUBJECT:

FERMI POWER PLANT, UNIT 2-INTEGRATED INSPECTION REPORT 05000341/2022004

Dear Peter Dietrich:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On January 25, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

Five findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2.

February 14, 2023 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000341 License No. NPF43

Enclosure:

As stated

Inspection Report

Docket Number:

05000341

License Number:

NPF-43

Report Number:

05000341/2022004

Enterprise Identifier:

I2022004-0042

Licensee:

DTE Electric Company

Facility:

Fermi Power Plant, Unit 2

Location:

Newport, MI

Inspection Dates:

October 01, 2022 to December 31, 2022

Inspectors:

T. Briley, Senior Project Engineer

R. Edwards, Branch Chief

J. Gewargis, Resident Inspector

G. Hansen, Senior Emergency Preparedness Inspector

T. Iskierka-Boggs, Senior Operations Engineer

M. Jones, Emergency Response Coordinator

J. Kutlesa, Emergency Preparedness Inspector

R. Ng, Senior Project Engineer

T. Taylor, Senior Resident Inspector

Approved By:

Billy C. Dickson, Jr., Chief

Reactor Projects Branch 2

Division of Operating Reactor Safety

SUMMARY

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

List of Findings and Violations

Failure to Monitor Moderate Energy Line Break Flood Barriers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200401 Open/Closed

[P.2] -

Evaluation 71111.06 The inspectors identified a Green finding and associated Non-cited violation (NCV) of 10 CFR 50, appendix B, criterion III, Design Control, when the licensee failed to validate the design of certain internal flood barriers protecting safety-related equipment. Specifically, the inspectors identified degraded and missing spray shields designed to protect safety-related equipment from the effects of moderate energy line breaks (MELBs).

Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate Heat Sink) Roof Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200402 Open/Closed

[H.12] - Avoid Complacency 71111.07T The inspectors identified a finding of very low safety significance for the licensee's failure to document housekeeping findings and initiate a condition assessment resolution document (CARD) for discrepancies on the residual heat removal (RHR) complex roof in accordance with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented by the licensee despite multiple individuals touring the area.

Vendor Oversight Issues During RF20 Torus Recoat Project Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200403 Open/Closed

[H.5] - Work Management 71152A The NRC identified a Green finding associated with vendor oversight of the 2020 torus recoat project when unexpected degradation of the coating prompted a review that determined control of supplemental personnel during the 2020 outage was inadequate.

Some Industry Standards Not Incorporated into Torus Recoat Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200404 Open/Closed

[H.11] -

Challenge the Unknown 71152A A Green finding with an associated Non-cited violation (NCV) of 10 CFR 50 appendix B, criterion V, "Instructions, Procedures, and Drawings," was self-revealed while inspecting the torus during the RF21 refueling outage (spring 2022). Some areas of degradation were observed that were unexpected given the torus had been recoated during the previous refueling outage. Upon further review, the licensee identifies that some applicable industry standards had been omitted from the torus recoat procedures, and certain portions of the work instructions were not followed.

Failure to Perform a Required Code Evaluations for Standby Liquid Control System Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200405 Open/Closed

[H.12] - Avoid Complacency 71152A The inspectors identified a Green finding with an associated Non-cited violation (NCV) of 10 CFR 50.55a, "Codes and Standards," for the licensees failure to follow the ASME Code after discovering boric acid leakage in the standby liquid control system (SLC). Specifically, a code required evaluation was not performed as an alternative to corrective actions.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000341/202200303 Seismic Displacement for Safety-Related Piping Not Verified 71111.18 Closed LER 05000341/2021002-00 LER 2021002-00 for Fermi 2 Power Plant, Unplanned Inoperability of High Pressure Coolant Injection System Due to an Inverter Circuit Failure 71153 Closed LER 05000341/2021002-01 LER 2021002-01 for Fermi Power Plant, Unit 2,

Unplanned Inoperability of High Pressure Coolant Injection System Due to an Inverter Circuit Failure 71153 Closed LER 05000341/2021001-00 LER 2021001-00 for Fermi,

Unit 2, Unrecognized Impact of Opening of Barrier Doors on High Energy Line Break Analysis 71153 Closed LER 05000341/2022003-00 LER 2022003-00 for Fermi 2 Power Plant, Turbine Trip 71153 Closed and Subsequent Reactor Trip Due to Mayflies LER 05000341/2022001-00 LER 2022001-00 for Fermi 2 Power Plant, Reactor Scram on Low Reactor Pressure Vessel Level 71153 Closed

PLANT STATUS

Fermi Unit 2 started the inspection period at or near 100 percent power, and remained there for the quarter.

INSPECTION SCOPES

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

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

General service water, circulating water, and residual heat removal service water (RHRSW) for the week ending on November 18, 2022

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding for the week ending on November 4, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (6 Samples)

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

(1) Division 1 emergency equipment cooling water (EECW) with division 2 EECW TCV maintenance during the week ending October 21, 2022
(2) Division 1 non-interruptible air system (NIAS) during division 2 control center heating, ventilation, and air conditioning (CCHVAC) safety system outage during the week ending October 21, 2022
(3) Division 1 130/260 engineered safety feature direct current (DC) power and battery system during the week ending October 29, 2022
(4) Electric fire pump while the alternate diesel fire pump was out of service on November 9, 2022
(5) Division 2 residual heat removal (RHR) drywell spray with work on division 1 during the week ending November 26, 2022
(6) Division 1 RHRSW with the division 2 RHR pump and valve surveillance during the week ending November 25, 2022

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the division 2 core spray system during the week ending on November 4, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Southwest quadrant of the reactor building basement and sub-basement during the week ending October 21, 2022
(2) Northwest quadrant of the reactor building basement and sub-basement during the week ending November 18, 2022
(3) Reactor core isolation cooling quad sprinkler question during the week ending December 10, 2022
(4) Reactor building 3 and reactor building 4 standby liquid control area during the week ending December 12, 2022

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the following:

(1) Auxiliary building third and fourth levels, completed the week ending December 31, 2022

71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)

Main article: IP 71111.07

The inspectors evaluated heat exchanger performance on the following:

(1) P4400B001B, EECW division 2 plate and frame heat exchanger

Heat Exchanger (Closed Loop) (IP Section 03.03) (1 Sample)

The inspectors evaluated heat exchanger performance on the following:

(1) P5002B004, control air compressor (CAC) after cooler - north non-interruptible control air (NIAS)

Ultimate Heat Sink (IP Section 03.04) (1 Sample)

The inspectors evaluated the ultimate heat sink performance on the following:

(1) The ultimate heat sink, specifically sections 03.04.a and 03.04.e were completed.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests administered between October 11, 2022 and November 10, 2022.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a planned high pressure coolant injection system surveillance that resulted in a yellow risk condition, with complications regarding the performance of two valves in the system, on November 15, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated performance of an annual operating test in the control room simulator on October 26, 2022.
(2) The inspectors observed and evaluated licensed operator requalification training for technical specifications and emergency action level entry, and simulator exercise scenarios in the main control room simulator during the week ending November 18, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1)4160V electrical switchgear

(2) Power supply inverters for safety-related instrumentation and control loads
(3) Review of issues associated with the transversing incore probe system, completed the week ending December 24, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Troubleshooting and electric shock associated with the reactor water cleanup system during the week ending November 12, 2022
(2) Gland seal exhaust motor replacement on November 02, 2022
(3) Mechanical draft cooling tower fan 'B' maintenance November 28, 2022
(4) Approach to a leaking sensing line for reactor feed pump suction pressure, completed the week of December 31, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Abnormal noise from the 'B' mechanical draft cooling tower motor during the week ending December 3, 2022
(2) Recirculation pump seal pressure changes during the week ending December 10, 2022

71111.18 - Plant Modifications

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site SAMG were updated in accordance with the BWR generic severe accident technical guidelines and validated in accordance with NEI 1401, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) Division 1 CCHVAC outage during the week of October 3, 2022
(2) Division 1 NIAS during the week ending November 4, 2022
(3) Diesel fire pump post installation testing, completed during the week ending December 23, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) Electrical bus 64B undervoltage testing and relay calibrations during the week ending October 8, 2022
(2) HPCI pump and valve surveillance after pressure control valve repair and outboard main steam isolation valve packing adjustment on December 1, 2022
(3) EECW pump and valve during the week ending December 14, 2022
(4) Validation of acceptable level bands for oil and tank levels on select motors and tanks, completed the week ending December 24, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) EDG 11 SW pump and minimum flow valve testing during the week ending October 21, 2022

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) RCS leakage increasing trend during the week ending October 29, 2022

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Dominator and Neptune pump run surveillances, completed by the week ending December 31, 2022

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.0102.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

===202108E, Spent fuel pool level updates for RA2.3, RS2.1, and RG2.1, September 21, 2021

202135S, Spent fuel pool level updates for RA2.3, RS2.1, and RG2.1, September 21, 2021 This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

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

=

Main article: IP 20210
(1) The inspectors evaluated drill and exercise performance indicator opportunities associated with a licensed-operator requalification activity on October 26,

OTHER ACTIVITIES-BASELINE

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Ongoing issues with effluent sampling systems and potential impacts to declaring emergency action levels, the week ending December 10, 2022
(2) Select review of degraded/non-conforming conditions carried by the licensee, completed the week of December 31, 2022
(3) Review of 2020 torus recoat project following degradation identified in 2022, completed the week of December 31, 2022

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

Main article: IP 71152
(1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue.

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

Main article: IP 71153

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

(1) LER 05000341/2021001, Unrecognized Impact of Opening of Barrier Doors on High Energy Line Break Analysis (ADAMS Accession No. ML21182A291). The inspection conclusions associated with this LER are documented in Inspection Report 05000341/2021003 under Inspection Results section 71111.15 (ADAMS Accession No. ML21298A200). An analysis to assess the potential impacts on components outside the reactor building steam tunnel (RBST) during a line break in the RBST does not exist. Current analyses assume the door is shut. Subsequent to NRC identification of the issue in 2021, the licensee took steps to conduct an analysis on effects outside the RBST. This effort was not completed. As a result, the inspectors cannot validate the accuracy of several of the 10 CFR 50.73 reporting criteria, such as loss of safety functions and conditions prohibited by technical specifications (TS). While the licensee did report under those criteria (assuming a worst case scenario where all equipment required to respond to a line break in the RBST was inoperable due to the break), without an analysis on the environmental impacts outside the RBST, it is impossible to assess whether or not these criteria were actually met. Despite that, the licensee did report under criteria for an unanalyzed condition and a condition prohibited by TS 3.0.3 specifically. The inspectors determined it was appropriate to report under those criteria given the lack of analysis and multiple types and trains of equipment that may have been impacted to the point where operability was brought into question. The non-cited violation associated with this issue screened as very low safety significance given the small amount of time the door had been open in the past 3 years. The licensee instituted corrective actions to better recognize and control important doors throughout the plant. No further findings nor violations were identified.
(2) LER 05000341/2021002-00 and 05000341/2021002-01, Unplanned Inoperability of High Pressure Coolant Injection System Due to an Inverter Circuit Failure (ADAMS Accession Nos. ML22075A087). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. The inspectors reviewed the previous, as well as the updated LER submittal.
(3) LER 05000341/2022001, Reactor Scram on Low Reactor Pressure Vessel Level (ADAMS Accession No. ML22094A155). The inspection conclusions associated with this LER are documented in Inspection Report 0500341/2022003 under Inspection Results section 71152A. No further findings or violations were identified.
(4) LER 05000341/2022003, Turbine Trip and Subsequent Reactor Trip due to Mayflies (ADAMS Accession No. ML22235A106). The inspection conclusions associated with this LER are documented in Inspection Report 0500341/2022003 (ADAMS Accession No. ML22311A531) under Inspection Results section 71152A. No findings nor violations were identified.

OTHER ACTIVITIES

-TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation of an ISFSI The inspectors evaluated the licensees activities related to the long-term operation and monitoring of its Independent Spent Fuel Storage Installation (ISFSI). The inspectors reviewed relevant documentation remotely during the weeks of October 10 and October 17, 2022, and were onsite on October 19, 2022. During the onsite walkdown, the inspector toured the ISFSI and evaluated the material and radiological conditions of the ISFSI pad and loaded HISTORM 100 systems. The inspectors verified radiological conditions on the ISFSI pad were as expected during the walkdown. The inspectors interviewed licensee staff regarding periodic surveillances of the loaded HISTORM casks.

Since the last inspection, the inspectors evaluated corrective action documents and changes performed in accordance with 10 CFR 72.48, "Changes, Tests, and Experiments."

INSPECTION RESULTS

Failure to Monitor Moderate Energy Line Break Flood Barriers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200401 Open/Closed

[P.2] -

Evaluation 71111.06 The inspectors identified a Green finding and associated Non-cited violation (NCV) of 10 CFR 50, appendix B, criterion III, Design Control, when the licensee failed to validate the design of certain internal flood barriers protecting safety-related equipment. Specifically, the inspectors identified degraded and missing spray shields designed to protect safety-related equipment from the effects of moderate energy line breaks (MELBs).

Description:

On November 29, 2022, the inspectors performed a walkdown of the third floor and fourth floor of the auxiliary building (AB) as part of an internal flooding inspection sample. During the walkdown, the inspectors discovered that the MELB spray shields in the division 2 switchgear room and AB fourth floor were degraded or missing from sections of emergency equipment cooling water (EECW) piping. The spray shield design consists of a fiberglass-impregnated material that encloses susceptible piping to contain and divert water away from safety-related equipment, namely electrical switchgear. The inspectors questioned the potential effects of the degraded/missing spray shields on nearby equipment. In response, the licensee performed technical evaluations that concluded that safety-related equipment remained operable in the current condition but not in accordance with the design.

A subsequent review by the licensee revealed that a condition assessment resolution document (CARD) had been written in 2020 documenting the degraded spray shields in the division 2 switchgear room, consistent with what was identified on the NRC walkdown almost 3 years later. While the licensee had generated a work order to fix the shields, it was still in a delay status, and no monitoring plan was in place to ensure the barrier could still fulfill its design functions (e.g., following work in the area or periodic checks of the tape holding the barrier in place at some locations). The licensee found no evidence for other piping sections that the missing shields had been identified or documented by the licensee. Through discussion with the inspectors, the licensee determined that the work activity to inspect spray shields throughout the plant had not been performed when last scheduled in July 2019.

During the extent of condition walkdowns following NRC's discovery of the issue, further degraded spray shields were identified; however, most were determined not be a part of the internal flooding design basis anymore. The licensee evaluated the others to ensure no impacts to safety-related equipment existed.

Corrective Actions: The licensee completed a technical evaluation to support the operability of the division 2 switchgear and confirmed other areas of missing/degraded spray shields did not constitute a deviation from design nor have adverse impacts on nearby equipment as part of their extent of condition walkdowns. In response to the inspectors' questions, the licensee also started a review to determine if they properly administrated the periodic inspection activity to validate the flood barrier design.

Corrective Action References: CARDs 2231414, 2020846, 2231541, 2231415, and 2231571.

Performance Assessment:

Performance Deficiency: The inspectors determined the licensee failed to perform a scheduled verification of flooding barriers. Additionally, deviations from MELB protection features were not controlled due to inspector identification of missing/degraded spray shields on EECW piping that had not been identified by the licensee nor properly monitored.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, degraded MELB barriers had not been identified, monitored, and/or properly assessed that could impact nearby safety-related equipment.

Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the finding screened to Green (very low safety significance) because questions 2 through 6 on exhibit 2 of the mitigating systems screening were answered as No.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, when degraded MELB barriers were identified, the licensee failed to ensure appropriate technical assessments were performed, that effective monitoring was in place, and an extent of condition was performed to identify other issues.

Enforcement:

Violation: 10 CFR 50, appendix B, criterion III, "Design Control," states, in part, that measures established shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

Contrary to the above, from January 24, 2020 to January 9, 2023, the licensee failed to assure that deviations from quality standards were controlled. Specifically, the licensee failed to complete a scheduled inspection of flood barriers. Further, the licensee did not perform a technical assessment nor monitoring to support shroud functionality once degradation was identified.

Enforcement Action: This violation is being treated as a NCV, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Follow Housekeeping Procedure on Residual Heat Removal Complex (Ultimate Heat Sink) Roof Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200402 Open/Closed

[H.12] - Avoid Complacency 71111.07T The inspectors identified a finding of very low safety significance for the licensee's failure to document housekeeping findings and initiate a condition assessment resolution document (CARD) for discrepancies on the residual heat removal (RHR) complex roof in accordance with licensee procedure MOP 21, "Housekeeping." Specifically, the inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented by the licensee despite multiple individuals touring the area.

Description:

On October 18, 2022, the inspectors performed a walkdown of the residual heat removal complex roof. The inspectors noted that the lower roof contained miscellaneous debris in the form of food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips. The inspectors also noted that one of the large plastic storage bins containing ice melt material had been lined with a plastic bag and turned into a makeshift trash can. The identified debris was generally in the vicinity of roof drains and/or grating that led to or was directly over the division 1 and division 2 ultimate heat sink water reservoirs used to transfer heat from structures, systems, and components important to safety. Natural phenomena (such as rainfall or wind gusts) could potentially transport the debris into the reservoirs and potentially challenge pump operation for residual heat removal service water, emergency equipment service water, and/or emergency diesel generator service water. Periodic diving inspection records from 2020 and 2022 also indicated the presence of miscellaneous debris such as plastic signage, moss clumps, and ear plugs located under water in the reservoirs (debris was documented as removed by the divers upon discovery).

The personnel doors used to access the RHR complex roof indicated the area was a "housekeeping category."

Licensee procedure MOP 21, "Housekeeping," Revision 7, contains procedural guidance for ensuring adequate levels of housekeeping to ensure safe plant operation and included all activities related to controlling material in all areas of the facility. The procedure also stated, in part, that individuals are expected to maintain the same level of housekeeping inside and out of the power block. Procedure step 2.3.9 stated, in part, that persons performing a plant tour shall 1) document findings on the housekeeping inspection report form and 2) initiate a condition assessment resolution document (condition report) for discrepancies when required.

The debris identified by the inspectors had not been documented as a housekeeping finding nor entered into the corrective action program via a condition assessment resolution document until brought to the licensee's attention. It is unknown how long the miscellaneous debris was present on the residual heat removal complex roof, however, the inspectors determined that some of the miscellaneous debris had most likely been on the roof for an extended period of time based on environmental degradation.

Corrective Actions: The miscellaneous debris was subsequently removed from the residual heat removal complex roof and a follow-up investigation into the cause(s) was planned.

Corrective Action References: CARD 2230462

Performance Assessment:

Performance Deficiency: The licensee's failure to document housekeeping findings and initiate a CARD for discrepancies on the RHR complex roof in accordance with licensee procedure MOP 21, "Housekeeping," was a performance deficiency. Specifically, the inspectors identified miscellaneous debris (such as food wrappers, ear plugs, security drill rounds, plastic bags, moss clumps, tie wraps, small plastic pieces, and paint chips) that had not been documented by the licensee despite multiple individuals touring the area.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, debris on the residual heat removal complex roof can be washed or blown directly into the ultimate heat sink reservoirs and could potentially impact safety-related residual heat removal, emergency equipment, and emergency diesel generator service water systems. The inspectors also noted previous dive inspection records in both 2020 and 2022 of the ultimate heat sink reservoirs housed in the residual heat removal complex contained debris found such as plastic signage and bags, paint chips, and ear plugs to name a few (items were retrieved during periodic diving activities).

Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the mitigating systems screening questions for structures, systems, and components and probabilistic risk analysis functionality were all answered no. Therefore, the finding screened as of very low safety significance (Green).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, multiple individuals from multiple organizations routinely traversed the RHR complex roof and appeared to not consider the potential undesired consequences of their actions in leaving miscellaneous debris on the roof, verify housekeeping procedure prerequisites despite being prompted by the access door signs stating "housekeeping category," nor performed a thorough review of the area every time work was performed (such as operator rounds) rather than relying on past successes and assumed conditions.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

URI Seismic Displacement for Safety-Related Piping Not Verified URI 05000341/202200303 71111.18

Description:

During the fourth quarter of 2022, the licensee provided additional information from a design basis calculation of record associated with the division 1 residual heat removal service water (RHRSW) supply and return piping inside the reactor building. Calculation No. DC6953, "Emergency Equipment Cooling Water System Subsystem: EX15," Revision 0 provides the design basis and licensing basis information associated with the seismic and thermal displacements of the piping and determination of whether the maximum piping displacement impacts any systems, structures, or components (SSCs).

The licensee provided the piping displacement information from Calculation No. DC6953 to demonstrate that the RHRSW piping will not impact any SSCs. The inspector reviewed this information and concluded this issue is closed. No performance deficiencies or findings were identified.

Corrective Action Reference(s): condition assessment resolution document 2227033, NRC Identified: Evaluation of Potential Rattle Space Violation, dated 06/10/2022.

Vendor Oversight Issues during RF20 Torus Recoat Project Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000341/202200403 Open/Closed

[H.5] - Work Management 71152A The NRC identified a Green finding associated with vendor oversight of the 2020 torus recoat project when unexpected degradation of the coating prompted a review that determined control of supplemental personnel during the 2020 outage was inadequate.

Description:

The unexpected torus coating degradation discovered during the 2022 refueling outage prompted an investigation by the licensee into the operability of the torus and the potential causes of the degradation. Non-cited violation (NCV) 05000341/202200404, documented in this inspection report, describes the issues with the work instructions associated with the 2020 torus project. Further investigation by the licensee as a result of NRC questions prompted a condition assessment resolution document (CARD) 2227942 to be written to explore the extent of work control/process gaps that may have existed for the torus project.

An organizational effectiveness evaluation determined that supplemental personnel assigned to the torus project failed to follow site processes regarding procedure use and adherence.

One of the potential causes for the degradation of the new torus coating was the lack of tarps to protect uncoated areas from the spraying of coating in nearby areas. Despite the work instructions calling for tarps, they were not used. A review of the work instructions later revealed steps were inappropriately marked as complete or not applicable (N/A)inappropriately.

Besides evaluating the extent of the condition of the failure to follow site processes for execution of the torus work instructions, CARD 2227942 sought to identify the causes of the issues. NRC review of this CARD revealed that the licensee correctly identified several instances of contractors not following site processes. Examples included how to mark steps as complete, how to use a 'N/A,' and when and by whom steps should be marked off. As a result, the inspectors determined supplemental personnel control associated with the torus recoat project was inadequate. CARD 2227942 identified a potential reason:

a new-tonuclear, non-proficient worker had been selected to ensure steps for the torus project were complete and marked appropriately. While the licensee's CARD stated it was contractor supervision who placed the worker in that position, the inspectors noted site procedure MGA31 had requirements for licensee personnel: such as ensuring contractors had specific training assigned based on needs.

Additionally, the procedure requires updated information to be communicated to the contractors with sufficient time so that they can acquaint workers with the new information (an apparent decision not to use tarps was made but not conveyed to the individual signing for steps in the work instructions). Step 5.4.7 requires observations of work activities to check adherence to station policies and procedures. Step 5.4.1 requires vendor oversight plans to be developed. The licensee's evaluation in CARD 2227942 did not explore if there were shortfalls with the last two requirements on behalf of licensee personnel. If observations and oversight plans were, in fact, part of the project, they were ineffective at detecting the gaps in contractor performance.

Corrective Actions: The licensee entered the issue into the corrective action program.

Corrective Action References: CARD 2227942

Performance Assessment:

Performance Deficiency: Contrary to requirements in MGA31, Supplemental Personnel Control Practice, the licensee did not provide adequate oversight of supplemental workers associated with the 2020 torus recoat project.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, inadequate supplemental worker oversight partly contributed to degraded conditions in the torus. The issue also screened as more than minor under the barrier integrity cornerstone, as the torus forms part of the primary containment barrier.

Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power. The end result of the performance deficiency was a questioning of the operability of the torus given the degradation that occurred. Under the mitigating systems cornerstone, questions 26 in section A of exhibit 2 were answered 'no.' Further, under the barrier integrity cornerstone, questions 12 under section C of exhibit 3 were also answered 'no.'

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Following the 2020 and 2022 refueling outages, after-action reviews and input from external stakeholders revealed weaknesses in the outage planning and preparation process that drove poor outage performance, to include planning for and managing contract work onsite.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Some Industry Standards Not Incorporated into Torus Recoat Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200404 Open/Closed

[H.11] -

Challenge the Unknown 71152A A Green finding with an associated Non-cited violation (NCV) of 10 CFR 50 appendix B, criterion V, "Instructions, Procedures, and Drawings," was self-revealed while inspecting the torus during the RF21 refueling outage (spring 2022). Some areas of degradation were observed that were unexpected given the torus had been recoated during the previous refueling outage. Upon further review, the licensee identified that some applicable industry standards had been omitted from the torus recoat procedures, and certain portions of the work instructions were not followed.

Description:

During the spring 2022 refueling outage, RF21, the inspectors opened an indepth PI&R sample to review the effectiveness of corrective actions taken during the prior outage (spring 2020) regarding the recoating of the inside of the torus. The inspection sample involved degradation, which developed before 2020, and the licensee's inadequate tracking and assessment of that degradation over time, was the subject of an NRC special inspection in 2019. The results of the special inspection are documented in inspection report 05000341/2019050 (ML20031D253). A confirmatory action letter also resulted from the special inspection, which prompted the entire recoating of the torus in 2020.

Following the identification of the degradation, the licensee worked with various vendors and consultants to assess the impact on the torus's operability and to determine a cause.

Degradation ranged from small areas of rust deposits to small bubbles that appeared on the surface. The areas in question were spread throughout the torus in discrete locations. The licensee concluded the total degraded area was far below that which would call into question the operability of the torus. This conclusion was supported by a series of 'pull-tests,' which validated that areas surrounding the pockets of degradation had sound, tightly adhered coating. Inspection by the onsite resident inspectors, region-based inspectors involved with the 2019 special inspection, and experts from NRC headquarters did not find any issues with the licensee's conclusion. The licensee developed several theories on how the degradation originated and documented the conclusions in CARD 2222967 via an equipment cause evaluation.

Essentially, the licensee concluded several factors likely led to the areas of degradation.

Ultimately, the licensee determined inadequate work instructions for the torus recoat project were the cause because several of the contributing factors were not properly accounted for in the work instructions. One example involved time elapsed between 'stripe coating' and application of the main coating (stripe coating being areas 'cut-in' prior to the main spray of coating). The licensee concluded that during the project, between 2.5 and 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> elapsed between stripe coating and spraying in the various areas. During the licensee's investigation, several industry references discovered pointed to a much shorter time (< 10 minutes) being appropriate to prevent a phenomenon known as 'amine blush' from occurring, which can affect coating adherence. As another example, testing for specific surface contaminants such as chlorides was not directed by the work instructions. While certain industry standards regarding surface preparation were followed, the fact the torus remained 'prepped' for coating for an unexpectedly long period (due to COVID impacts) should have prompted a check for contaminants that may not have otherwise been present had the torus been promptly coated.

In addition, the work instructions called for tarps to protect uncoated areas from the

'overspray' of other areas being coated. Steps for installation of the tarps were marked complete; however, a later investigation by the licensee revealed the steps had not been performed. It appears that as the project was progressing, the use of tarps was being debated given a change in coating strategy that had occurred and the speed at which activities were progressing. Per licensee processes, if a decision to not use tarps had been made, the work instructions should have been updated accordingly. Areas not protected from overspray may have led to some of the degradation noted.

Corrective Actions: The licensee performed tests to confirm the coating in general was satisfactorily applied. Select areas were repaired, and evaluations were performed to verify operability of the coating in the asfound and goforward conditions.

Corrective Action References: CARD 2222967 documented an equipment cause evaluation and organizational effectiveness cause evaluation.

Performance Assessment:

Performance Deficiency: The implementing work instructions for the torus recoat project were inadequate and certain portions were not followed.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, unexpected degradation was noted on the interior torus coating after one cycle of operation, calling into question the ability of the coating to remain intact during accident conditions (which can impact the suctions of safety related pumps aligned to the torus). The inspectors also determined the issue was more than minor under the barrier integrity cornerstone, as inadequate coating can also impact the primary containment barrier.

Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, under the mitigating systems cornerstone, questions 26 in section A of exhibit 2 were answered 'no.' Further, under the barrier integrity cornerstone, questions 12 under section C of exhibit 3 were also answered 'no.'

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the inspectors utilized the associated common language attribute (QA.2) from NUREG2165, Safety Culture Common Language, to inform assignment of an appropriate cross-cutting aspect. Applicable tenets of QA.2 include:

"Leaders reinforce expectations that individuals take time to do the job right the first time, seek guidance when unsure, and stop if unexpected conditions are encountered."

"Individuals maintain a questioning attitude during pre-job briefs and jobsite reviews to identify and resolve unexpected conditions."

"Individuals stop work activities when confronted with an unexpected condition, communicate with supervisors, and resolve the condition prior to continuing work..."

"If a procedure or work document is unclear or cannot be performed as written, individuals stop work until the issue is resolved."

The dynamic nature of the COVID health emergency led to changing conditions (e.g., longer period between surface preparation and coating) that presented opportunities to revalidate appropriate standards and controls in the work instructions that may have prevented the scope of degradation. Further, work was not stopped when the instructions could not be performed as written when it was decided to not use tarps.

Besides the work instructions for the coating, the inspectors also broadened their review to other work activities that were part of the torus project. The attributes of H.11/QA.2 were lacking in several areas throughout the project. A worker was injured when others saw an unsafe platform but did not stop the job before the injury. When workers in the torus questioned the speed at which material was being hoisted out of the torus, workers above told them multiple times that they would not slow down. In approaching the unknowns associated with confined space rescue in a fully drained torus, the necessary practice and coordination for such a complex activity was not provided prior to start of work. This missed opportunity was only realized when the rescue team was called out for an injury after work had started.

Enforcement:

Violation: 10 CFR 50 appendix B, criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. Contrary to the above, during the spring 2020 refueling Outage (March 2020-August 2020) and until discovery the following refueling outage (which commenced in February 2022), the licensee did not prescribe documented instructions appropriate to the circumstances, nor accomplish activities in accordance with appropriate instructions, for activities affecting quality. Specifically, the instructions associated with recoating the safety related torus lacked steps to help prevent degradation of the coating.

Further, some steps intended to protect the new coating were in the instructions but not followed.

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

Failure to Perform a Required Code Evaluations for Standby Liquid Control System Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000341/202200405 Open/Closed

[H.12] - Avoid Complacency 71152A The inspectors identified a Green finding with an associated Non-cited violation (NCV) of 10 CFR 50.55a, "Codes and Standards," for the licensees failure to follow the ASME Code after discovering boric acid leakage in the standby liquid control system (SLC). Specifically, a code required evaluation was not performed as an alternative to correction actions.

Description:

During a review of condition assessment resolution documents (CARDs) as part of the indepth PI&R baseline inspection sample, the inspectors reviewed CARD 2230062, initiated on October 2, 2022. This licensee-identified CARD described evidence of borated water leakage from a flanged connection between the SLC system tank and heater C4101S002 during planned VT2 examinations. While no active leakage was noted, the CARD mentioned that this was a repeat issue from CARD 1927781, initiated on October 11, 2019. While reviewing 1927781, the inspectors noted that CARD 1826451 (created August 27, 2018)had also documented the same borated water leak (however, this was not during a Code VT2 exam). Per section XI of the 2013 ASME Code, specifically IWA5250 and IWA5251, leaks of this nature require one of two primary activities to be accomplished following identification. One option described in IWA5250 involves removing a bolt from the affected connection and performing a VT3 exam with a subsequent evaluation of it and the remaining bolts. Alternatively, a licensee could opt to replace all bolts. The other option, described in IAW5251, involves the performance of an evaluation of the joint following IWA5251(c).

Corrective action for CARD 1826451 did not involve either code-required option. The licensee generated a work order, but as of the issuance of 1927781 (a little over a year later), the work order still needed to be prepared. After identifying the issue again in 1927781, the corrective action was to create a work order to accomplish the requirements of IWA5250 during the RF20 refueling outage (spring of 2020). While the licensee provided some facts supporting operability, they did not perform an evaluation involving the criteria listed in IWA5251(c). During RF20, the licensee removed the work activity to do the repairs and/or inspections to satisfy IWA5250. An evaluation per IWA5251 was also not completed at that time.

NRC inspector review of the most recent CARD identifying the leakage (2230062) revealed that despite the cancellation of the work order in RF20, the licensee did not put actions in place to schedule the work during RF21, the spring 2022 refueling outage. In response to NRC questions, the licensee generated CARD 2230116 to document that fact. After further discussions with the NRC, the licensee completed an evaluation per IWA5251(c) in December 2022. The inspectors reviewed the evaluation and noted that the licensee had also identified a similar situation existed for another SLC system component. The licensee identified a possible body-tobonnet leak on C4100F001, the SLC storage tank isolation valve, on October 2, 2022. This leakage had also been identified previously in 2019, along with the C4101S002 leakage, but did not have the appropriate action taken per IWA5251(c).

The inspectors reviewed the evaluation performed for both components and did not have an issue with the licensee's conclusions that the components remained operable.

Corrective Actions: The licensee performed an evaluation per IWA5251(c) to demonstrate operability of affected components.

Corrective Action References: CARDs 2230062, 2230061, and 2230116

Performance Assessment:

Performance Deficiency: Following discovery of borated water leakage from SLC system components, the licensee did not perform the required actions set forth in the ASME Boiler and Pressure Vessel Code, section XI, 2013 edition (the edition the licensee is committed to).

Specifically, the evaluation described in IWA5251(c) to demonstrate acceptable continued operation after choosing to not perform the actions in IWA5250, was not performed.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, continuing to not repair nor perform evaluations per the ASME Code for degraded safety-related components could lead to further degradation where operability could be a concern.

Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, after reviewing the evaluation performed by the licensee, the inspectors answered 'no' to all of the questions in section A of exhibit 2 regarding impacts to operability.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee deferred work on the degraded components but did not recognize until after the following refueling outage an opportunity had been missed to perform the work. Additionally, specific ASME Code requirements were not recognized despite multiple instances of identifying the same evidence of borated water leakage.

Enforcement:

Violation: 10 CFR 50.55a, Codes and Standards, incorporates by reference the ASME Boiler and Pressure Vessel Code, section XI, Rules for Inservice Inspection of Nuclear Power Plant Components-Division 1, 2013 addenda. Section IWA5251 of the Code states, in part, that as an alternative to corrective action under IWA5250 for leakage at bolted connections in systems borated for the purposes of controlling reactivity, an evaluation incorporating the criteria of IWA5251(c) can be performed to evaluate the consequences of continuing operation. Contrary to the above, since identification of conditions covered by IWA5250/5251 on October 11, 2019, for safety-related SLC components C4101S002 and C4100F001, until an evaluation was performed on December 13, 2022, the licensee did not complete evaluations in accordance with the requirements of IWA5251(c).

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

Observation: Corrective Action Program Product Quality 71152S The inspectors identified a potential negative trend in CAP execution and product quality. The issues identified by the inspectors were discussed with licensee management in the applicable departments, along with the performance improvement department. The licensee recognizes the issue and, in addition to revising some of the products in question, has created plans to improve and validate product quality. One example was the creation of a monthly condition assessment resolution document (CARD) closure quality reviews to be done by each department and NQA. Specific issues are listed below:

The inspectors reviewed the causal evaluation associated with the scram in June of 2022 caused by a swarm of mayflies. The evaluation indicated problems between security and operations regarding working together to establish a plant lighting strategy. Further, it identified one of the causes as not utilizing the "DTE Mayfly Infestation Plan." There were also references to other site or departmental issues unrelated to the event. After questioning the licensee for more contextual information, the inspectors learned DTE never had an infestation plan until after the event occurred. Also, there wasn't a problem of security and operations resolving differences; rather, there was no discussion following the 2020 mayfly event to explore what could be done regarding the lighting. The licensee revised the evaluation to address those items and remove references to issues not relevant to the event.

The inspectors reviewed the root cause evaluation associated with the February 2022 scram caused by a feedwater transient. While not having an issue with the root cause or proposed corrective actions, the inspectors uncovered more detail behind the

'legacy procedural issue' for securing a feed pump that appeared relevant to the cause and could inform future modifications to the procedure. The inspectors determined the legacy procedure issue stemmed from a specific procedure change in 2001 that changed how plant operators managed the feed pump speed and the minimum flow control valve during the shutdown.

The inspectors reviewed the corrective action tools used to assess the actuator/yoke separation of a primary containment isolation valve and determined the performance gap analysis was too narrowly focused for the issue. Concurrently, site management also identified the issue, and as a result, a more detailed organizational cause evaluation was conducted.

The licensee NQA organization identified a trend in December 2022 which highlighted several failed causal evaluation products. One particular product involved responding to an NRC non-cited violation (NCV) regarding reporting requirements. The inspectors noted that before the most recent NCV, another NCV in the same area from 2020 had been documented, indicating difficulty in achieving sustainable corrective actions for reportability issues.

EXIT MEETINGS AND DEBRIEFS

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

On January 25, 2023, the inspectors presented the integrated inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee staff.

On November 4, 2022, the inspectors presented the ISFSI interim exit inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee staff.

On November 10, 2022, the inspectors presented the triennial heat sink inspection results to B. Sullivan and other members of the licensee staff.

On December 1, 2022, the inspectors presented the emergency action level and emergency plan changes inspection results to P. Dietrich, Senior VP and Chief Nuclear Officer and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Operations mid-cycle assessment reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

24210

NQA - Holtec Field Condition Report

06/03/2019

2031838

ISFSI Helium Backfill Volume Calculation Uncertainty

11/02/2020

Corrective Action

Documents

2130193

MOP11 Requires Revision for Combustible Material in ISFSI

Building

11/16/2021

Corrective Action

Documents

Resulting from

Inspection

230743

No Written Evaluation Performed per 10 CFR 72.212(b)(7)

10/31/2022

CFR 72.212 Report

2.48 Screen

200003

EDP 80028

Miscellaneous

2.48 Screen

200005

WO 57799481

Procedures

MRP04

Radiation Protection Conduct Manual

PM202106286

ISFSI Pad

06/28/2021

PM202111242

ISFSI Pad

11/24/2021

PM2022062912

ISFSI Pad

06/29/2022

Radiation

Surveys

PM202210079

ISFSI Pad

10/07/2022

Self-Assessments Audit Report

20103

ISFSI Program

05/16/2022

49479374

HISTORM Annual Inspection

10/07/2019

206872

Perform 35.710.055 HISTORM Monthly Screen Inspection

03/28/2020

2805754

HISTORM Annual Inspection

11/04/2020

56125177

Perform 35.710.055 HISTORM Monthly Screen Inspection

05/19/2021

57629881

HISTORM Annual Inspection

10/20/2021

57799481

Contingency ISFSI Haul Path

06/25/2020

60855

Work Orders

58429284

Perform 35.710.055 HISTORM Monthly Screen Inspection

01/27/2022

2032050

22 Seasonal Readiness-Cold Weather Preps Milestones

Tracking - Refuel Outage Dates

11/06/2020

71111.01

Corrective Action

Documents

230324

Request Drawing Update to Shore Barrier Drawings

Following Yearly Survey

10/12/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

230675

Alternate Diesel Fire Pump Enclosure Heater Not

Functioning Correctly

10/27/2022

230812

Additional Information and Engineering Support Required to

Troubleshoot U4100F171A

11/02/2022

Corrective Action

Documents

Resulting from

Inspection

230305

NRC Identified-Bolt Missing from Pin on Door R18

10/11/2022

6A7212071

Reactor and Auxiliary Building Door Schedule and Types

09/06/2022

6M7215720

Circulating Water System Functional Operating Sketch

03/18/2022

Drawings

6M7215726

General Service Water System Functional Operating Sketch

10/10/2018

23.101

Circulating Water System

107

23.131

General Service Water System

114

23.208

RHR Complex Service Water Systems

134

35.000.242

Barrier Identification/Classification

Procedures

MWC16100

Seasonal Readiness

0900177

Packing Leak: Div. 2 Core Spray Keep Fill Isolation Valve

Has 2 dpm Packing Leak

01/05/2009

Corrective Action

Documents

CARD 1821676

Division 2 Core Spray Fill Outlet Isolation Valve Swing Bolt

Broken

2/27/2018

6M2712015

Diagram Station and Control Air

04/26/2022

6M2715706-3

RHR Service Water Make-Up Decant and Overflow Systems

Functional Operating Sketch

03/15/2022

6M7212034

Diagram Core Spray System C.S.S Reactor Building

04/09/2022

6M7212084

Diagram Residual Heat Removal (RHR) Division 1

03/17/2022

6M7212084

Diagram Residual Heat Removal Division 1

BS

6M7212135

Diagram Fire Protection System (Sheet 1)

BA

6M7212135-1

Diagram Fire Protection System (Sheet 2)

BL

6M7215444

Emergency Equipment Cooling Water Division 1

03/15/2022

6M7215707

Core Spray System Functional Operating Sketch

04/09/2022

71111.04

Drawings

6M7215721-1

Condensate Storage and Transfer System Functional

Operating Sketch

03/26/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

6M7215729-1

Emergency Equipment Cooling Water (Division 1)

Functional Operating Sketch

03/15/2022

6M7215729-2

Emergency Equipment Cooling Water (Division 2)

Functional Operating Sketch

04/23/2022

6M721N2052

P&ID RHR Service Water System Division 1 RHR Complex

03/15/2022

Miscellaneous

Division 1 RHR LPCI Standby Lineup Verification,

8A

149

23.127

Reactor Building Closed Cooling Water/Emergency

Equipment Cooling Water System

2

23.127

1A

Div. 1 EECW Valve Lineup

09/21/2021

23.127

2A

Div. 1 EECW Electrical Lineup

04/09/2006

23.127

3A

Div. 1 EECW Instrument Lineup

11/15/2010

23.127

DIV RBCCW/ECCW Standby Verification Checklist

2/11/2021

23.129

1C

NIAS Valve Lineup

07/30/2015

23.129

Station and Control Air System Electrical Lineup

04/06/2009

23.129

3A

Station and Control Air System Instrument Lineup

01/27/2009

23.129

Div. 1 Control Air Standby Verification Checklist

01/11/2010

23.203

1B

Core Spray System: Div. 2 Initial Valve Lineup

11/15/2002

23.203

1C

Core Spray System: Common Initial Valve Lineup

01/08/2001

23.203

2B

Core Spray System: Div. 2 Electrical Lineup

11/15/2005

Procedures

23.203

3B

Core Spray System: Division 2 Instrument Lineup

04/07/2009

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

23.203

5B

Core Spray System: Div. 2 Initial Fill and Vent Independent

Verification Checklist

01/11/2010

23.203

6B

Shifting Div. 2 Core Spray Suction to CST Independent

Verification Checklist

03/03/2020

23.203

6D

Shifting Div. 2 Core Spray Suction to Torus Independent

Verification Checklist

03/14/2020

23.203 Enclosure

A

Core Spray Manual Operation

11/27/2018

23.205

Residual Heat Removal System

149

23.208

RHR Complex Service Water Systems

134

23.208

1A

Div. 1 RHRSW Valve Lineup

01/24/2022

23.208

2A

Division 1 RHRSW Electrical Lineup

01/24/2022

23.208

3A

Division 1 RHRSW Instrument Lineup

01/19/2006

23.303

6B

Shifting Div. 2 Core Spray Suction to CST Independent

Verification Checklist

03/03/2020

23.309

Division 1 Distribution System Electrical Lineup

2/09/2020

6SD7212530-10

One Line Diagram 260 /130V ESS Dual Battery 2PA

Distribution-Division 1

03/16/2022

Work Orders

294552

CS Division 2 Discharge Header Keep Fill E21F026B PCV

Outlet Isolation Valve

2/19/2022

FPRBB2b

Reactor Building Basement Northwest Corner Room,

Zone 2, EL. 562'0"

FPRBB3b

Reactor Building Basement Southwest Corner Room,

Zone 3, EL. 562'0"

FPRBSB2a

Reactor Building Sub-Basement Northwest Corner Room,

Zone 2, EL. 540'0"

Fire Plans

FPRBSB3a

Reactor Building Sub-Basement Southwest Corner Room,

Zone 3, EL. 540'0"

71111.05

Procedures

FPRB315a

Reactor Building Thermal Recombiner System Area, Zone

15, EL. 641'6"

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

FPRB417a

Reactor Building SLC System Zone 17 EL. 659'6"

FPRBSB5A

Reactor Building Sub-Basement Northeast Corner Room

Zone 5 EL 540'0"

231531

Extent of Condition Walkdown Revealed More Degraded

MELB Barriers

2/02/2022

Corrective Action

Documents

231541

Walkdown of Division 1 SWRG for Possible Spray Barrier

Issues

2/02/2022

231414

NRC Identified: Spray Cover in Division 2 Switchgear Room

Degraded

11/29/2022

231415

NRC Identified: Pipe Cap Near P4400F449 Not Enclosed by

Spray Guard

11/29/2022

231417

NRC Identified: Metal Enclosure on AB4 Not Sealed at Floor

Level

11/29/2022

231419

NRC Identified: Piping Above HVAC Ducting on AB4 East

Side Is Not Fully Enclosed in Blue Spray Guard

11/29/2022

231505

NRC Identified: Degraded Spray Shield on Division 1 EECW

Piping

2/01/2022

231505

NRC Identified: Degraded Spray Shield on Division 1 EECW

Piping

2/01/2022

231518

NRC Identified: Degraded MELB Barrier on Drywell Seal

Rupture Drain to Condensate Storage Tank

2/01/2022

231571

NRC Identified: Work Order completed on 7/2/2019 Is Not

Vaulted in Webarms

2/05/2022

Corrective Action

Documents

Resulting from

Inspection

231571

NRC Identified: Work Order Completed on 7/2/2019

2/05/2022

EF2PRA011

Internal Flood Walkdown Summary Notebook

Miscellaneous

EF2PRA012

Internal Flood Analysis Notebook

71111.06

Work Orders

49771630

Perform Inspection of Spray Shrouds

01/29/2018

DC0249

RBCCW Hydraulics and Miscellaneous EECW Calculation

K

DC0559

Vol I: Volume of Reservoir

F

DC4931

Non-Interruptible Control Air System (NIAS) Calculations

J

Calculations

DC6286

EECW Heat Exchanger Performance Requirements with

Plugging

A

71111.07T

Corrective Action

1830419

MDCT A and B Fan Brake Nitrogen System Leaking

2/28/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

27521

Unexpected Increase in Div 1 EECW Heat Exchanger

Differential Pressure After Recent Swap

10/03/2019

27978

Trend in Anomalous System Parameter Measurements

During Surveillances

10/21/2019

28324

2019 NRC Triennial UHS Inspection: Average Silt

Accumulation in UHS Reservoir Was Not Calculated in WO 47534163

10/31/2019

23408

Division 1 Ultimate Heat Sink General Foreign Material

(Found and Removed During Diving)

03/28/2020

23984

Unrecovered Foreign Material - Orange Zip Tie

04/07/2020

2030217

20 MMR14 Structures Monitoring Inspection of RHR High

Roof (WO)

09/14/2020

25607

Unknown Substance Coating Corrosion Coupon Holder

06/24/2021

28982

Housekeeping Concerns on RHR Complex Roof

10/08/2021

22162

Review of RHR Div 1 Reservoir Diving Reports

2/20/2022

22580

Abnormal Moss Buildup and Debris Noted During Div 1 UHS

Diving

2/24/2022

Documents

24712

Completion of RF21 RHR Div 2 Reservoir Inspection

Reports and Videos / Photos

04/05/2022

230458

22 NRC Heat Sink Inspection: Degraded Concrete Noted

on Pedestal Supports for EDGs 11, 12, 13, and 14 Exhaust

Mufflers

10/18/2022

230462

22 NRC Heat Sink Inspection: Poor Housekeeping Noted

During Walkdown

10/18/2022

230463

22 NRC Heat Sink Inspection: Partial Blockage Noted on

South RHR Pump Pump Room HVAC Outside Air Inlet

10/18/2022

230480

WO Needed to Address Moss and Weeds on RHR Roof

10/19/2022

230492

22 NRC Heat Sink Performance Inspection: External

Corrosion Identified on Floor Penetration Sleeve

10/19/2022

230506

22 NRC Heat Sink Inspection: Nitrogen Cylinders Not

Correctly Labelled

10/22/2022

230516

22 NRC Heat Sink Performance Inspection: Enhancement

Needed to PM Events P244 and P245

10/20/2022

Corrective Action

Documents

Resulting from

Inspection

230549

Performance Engineering Extent of Condition per CARD

10/21/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

230538

230666

22 NRC Heat Sink Performance Inspection: Exterior Tape

on Service Water Piping in RHR Complex

10/27/2022

6M7212015

Diagram Station and Control Air

CU

6M7215357

Emergency Equipment Cooling Water System Division II

BW

MN2026

General Arrangement RHR Complex Basement Floor Plan

E

MN2031

General Arrangement RHR Complex Section "CC"

F

Drawings

MN2050

Equipment Drains and Floor Drains Divisions 1 and 2 RHR

Complex

O

Commercial Diving and Marine Services Fermi RF21 Outage

Diving Div 1

2/21/2022

Commercial Diving and Marine Services Fermi RF21 Outage

RHR Div 2 Dive Report

03/28/2022

Miscellaneous

Consumable

Materials

Evaluation (CME)

210011

Cryotech CMA

01/15/2021

1D88

Division 1 EECW Outlet Temp

20.127.01

Loss of Reactor Building Closed Cooling Water System

20.129.01

Loss of Station and/or Control Air

23.127

Reactor Building Closed Cooling Water / Emergency

Equipment Cooling Water System

151

23.129

Station and Control Air System

24

23.208

RHR Complex Service Water Systems

134

24.000.02

Shiftly, Daily, and Weekly Required Surveillances

161

7D3

Div 1 RHR Reservoir Level Abnormal

E11XX

Residual Heat Removal Service Water (RHRSW) System

Design Basis Document

E

MES 52

GL 8913 Safety Related Service Water Monitoring Program

10A

MES 54

Heat Exchanger Component Monitoring Program

MMA10

System Cleanliness

MMA17

Foreign Material Exclusion (FME)

Procedures

MMR14

Structures Monitoring

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

MOP21

Housekeeping

2194616

License Renewal Required Perform Div 1 Reservoir Zebra

Mussel Inspection Dive

03/25/2020

2195243

License Renewal Req'd Perform Div 2 RHR Reservoir Zebra

Mussel and Ball Valve Inspection Dive

04/08/2020

269374

License Renewal - Perform Div 1 RHR Reservoir Zebra

Mussel and Ball Valve Inspection Dive [Confidential]

2/13/2022

Work Orders

269883

License Renewal - Perform Div 2 RHR Reservoir Zebra

Mussel and Ball Valve Inspection Dive

03/27/2022

71111.11A

Miscellaneous

22 LOR NRC

Annual OP Test

Summary

Fermi 2022 Licensed Operator Requalification Exam

Summary Which Provides the Exam Results for the Annual

Operating Tests Administered from 10/11/2022 - 11/10/2022

11/21/2022

LPOP2022225

Containment Tech Specs and EALs

SSOP2022243

Simulator Lesson Plan

Miscellaneous

SSOP9042283

Fermi 2 Evaluation Scenario

24.202.01

HPCI Pump and Valve Operability Test at 1025 psi

23

29.100.01 SH 1

RPV Control

29.100.01 SH 2

Primary Containment Control

29.100.01 SH 6

Curves, Cautions, and Tables

ODE10

Emergency Operating Procedure Expectations

71111.11Q

Procedures

ODE3

Communications

23026

Reactor Scram Due to Loss of 64 Transformer

04/14/2018

2000399

TIP Detectors Retracting One Inch Behind the Programmed

InShield Position

01/06/2021

21388

TIP E Flux Readings Degrading Rapidly

07/28/2020

26872

TIP C and TIP D Ball Valves Opened with TIPS InShield

06/22/2020

22080

ITE Type K600-s Breakers Failed to Close

03/08/2021

22886

Nova Inverters Found OOT

03/01/2022

23206

Bus 72EB Pos 2D Failed to open

03/07/2022

23772

Nova Inverter Tech Evaluation for Frequency Needed Due

to Frequency Adjustment Issues

03/17/2022

Corrective Action

Documents

26656

Ground Fault on 72U, Loss of Bus

05/28/2022

71111.12

Drawings

6I7212421-05

Schematic Diagram RBCCW Supplemental Cooling Division

04/08/2017

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Cooling Pumps

N/A

R1400 Electrical Switchgear 2021 Quarters 2 and 3 System

Health Report

21

R1400

R1400 Electrical Switchgear System Get Well Plan (GWP)

Miscellaneous

VMC1545

Installation and Operations Manual for Nova Electric Galaxy

Inverter

MMR APP B

Maintenance Rule Conduct Manual Appendix B-Terms and

Definitions

Procedures

MMR APP E

Maintenance Rule Conduct Manual Appendix E-

Maintenance Rule SSC Specific Functions

R1400 Electric Switchgear System Health Q2 and Q3 2021

R1400 Electric Switchgear System Health Report Q4 2020

Self-Assessments

R1400 Electric Switchgear System Health Q4 2021

230935

Relay Room H11P613

11/07/2022

Corrective Action

Documents

231390

MDCT Fan 'B' Loud Metallic Noise

11/28/2022

6I7212045-28

Internal-External Wiring Diagram Division 1 Process

Instrumentation Cabinet H11P613 Part-3

AG

Drawings

6I7212265-02

Schematic Diagram Reactor Water Cleanup System

Instrumentation

AK

MWC15001

Risk Management Plan for South RFP Suction Line Flow

Switch Low Source Valve Leak

2/20/2022

Miscellaneous

VMR11.18

Millivolt to Current (MV/1) Transmitter

A

MMR 12

Equipment Out of Service Risk Management

20A

Procedures

MMR Appendix H

Online Core Damage Risk Management Guidelines

71111.13

Work Orders

60510175

East Gland Seal Exhaust Motor Replacement

11/02/2022

Corrective Action

Documents

Resulting from

Inspection

28738

MES27 Evaluation Does Not Support the Immediate

Operability Determination Assumptions in CARD 2228664

08/15/2022

TEE1122-034

E1156C001B Mechanical Draft Cooling Tower Noise

Engineering

Evaluations

TER3022-068

Licensing Basis for the Effect of Tornado Depressurization

on a Running EDG

A

71111.15

Miscellaneous

Adverse Condition B310F010B RRP B Seal Purge Regulating Valve

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Monitoring Plan

20010

DBD XXX02

Design Basis Document

Various

Various NRC Guidance Documents Pertaining to Operability

and the Meaning of Design Basis

Various

20.307.01

Emergency Diesel Generator Failure

2.307.01

Emergency Diesel Failure

Procedures

23.138.01

Reactor Recirculation System

119

Corrective Action

Documents

230843

PT FD76 Issues and EDM Impact

11/03/2022

230932

NRC Identified: RB5 EDM Equipment Box Label Not Correct

11/07/2022

Corrective Action

Documents

Resulting from

Inspection

231503

NRC Identified Issue: 29.EDM.07 Procedure Issue

2/01/2022

Drawings

29.200.xx

29.200 series Severe Accident Management Guidelines

Flowcharts

various

Engineering

Changes

60106

Vehicle Barrier System Modification at Entrance to Alternate

Access Portal

Miscellaneous

NEI 1401

Emergency Response Procedures and Guidelines for

Beyond-Design-Basis Events and Severe Accidents

29.EDM.03

SFP Makeup/Spray - External Strategy

29.EDM.07

Passive Ventilation of the Air Space Above the Fuel Pool

[Confidential]

78.000.69

Chemistry Special Test Procedure

71111.18

Procedures

MGA 14

Severe Accident Management Program

28853

T4100B007 Above Its Investigative Limit

08/18/2022

230081

T41N227A AsFound Condition Not Functioning During the

Performance of WO 46289018

10/03/2022

230085

T4100 Failed PMT

10/03/2022

Corrective Action

Documents

230087

Unidentified Contingency Parts / Planning Impact

10/04/2022

6I7212451-13

Schematic Diagram NIAS Div. 1 Dryer Controls

06/02/2016

6M7215707

Core Spray System Functional Operating Sketch

04/09/2022

71111.19

Drawings

6M7215730-3

Non-Interruptible Control Air System Division 1 and 2

03/29/2012

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Functional Operating Sketch

IS248103B

EDP 80165.022 (Fermi 2 Diesel Fire Pump Modification

Alarm Circuitry)

11/08/2022

Engineering

Changes

EDP 80165

Fermi 2 Diesel Driven Fire Pump Replacement Modification

44128550

Calibrate Div. 1 CCHVAC Chiller Condenser EECW Outlet

Flow Switch

10/03/2022

289018

Calibrate Div. 1 CCHVAC Emergency Make-up and Recirc

Air Temperature Switch

10/03/2022

264945

PDMA Testing (Motor Tagged) of Control Air Compressor

Room Cool Unit

11/02/2022

48640608

Replace Div. 1 Control Air Non-Interruptible Air Supply

Isolation Valve Solenoid Valve

11/02/2022

48860374

Calibrate Div. 1 CCHVAC Chiller Evaporator Low

Temperature Switch

10/03/2022

57420071

License Renewal Replace Suction and Discharge Valves

with New and Refurbished Valves

11/02/2022

58187204

Replace Non-Interruptible Air Supply Solenoid Valve

11/02/2022

58471305

Control Air Non-Interruptible North Control Air Dryer West

Chamber Relief Valve

11/02/2022

61353693

Replace Division 1 North Control Air Compressor Unloading

Cylinder Solenoid Valve

11/02/2022

61563113

Calibrate Division 1 CCHVAC Equipment Room

Temperature Switch

10/03/2022

63600050

Test Division1 CCHVAC Zone 2 Cable Spreading Room

Mixing Damper Temperature Loop

10/03/2022

64193098

7D51 Division 1 Control Air System Trouble Due to High

Differential Pressure. Calibrate or Replace

11/02/2022

Work Orders

66000026

Post Mod Testing for EDP 80165

11/23/2022

22892

EDG 11 DGSW Pump Min Flow Valve Not Indicating Fully

Closed

06/28/2004

25803

Rework EDG11, 12, and 14 DGSW Minimum Flow Valves

11/19/2004

71111.22

Corrective Action

Documents

23411

Step Change in RB Steam Tunnel Temperature Due to

Possible HPCI Steam Leak

04/16/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

26208

Rounds Needs Updated

05/11/2022

29106

Increased Unidentified Leakage in Drywell DD72 Sump

During Division 2 EECW Pump and Valve Surveillance

24.107.09 Section 5.1

08/29/2022

29187

Drywell Unidentified Leakage Update

08/31/2022

29282

Drywell Sump Leakage Increase

09/02/2022

29536

Performing MMA26 for CARD 2227022 DW Unidentified

Leakage

09/14/2022

230145

R30F402 Indicating 10 Percent Open When Valve Should

Be Closed

10/05/2022

230170

No Flow, Suspect Drain Line Clogged

10/05/2022

231365

0.8" Step Change in Drywell Floor Drain Sump Level

Following Pumpdown

11/26/2022

231450

Investigation of Parameters Around a Run of HPCI

11/30/2022

Corrective Action

Documents

Resulting from

Inspection

23089

NRC Concern - Operations Rounds Details on Safety-

Related Motor Oil Levels

03/04/2022

6I7212572-28

4160V ESS Buses 64B and 64C Load Shedding Strings

V

6I721257B-05

Relay and Metering Diagram 4160V ESS Bus 64B

U

6I721N257217

4160V ESS Diesel Bus 11EA Load Shedding Strings

Y

6I721N257806

Relaying and Metering Diagram Diesel Generator 11 Unit 2

X

6M7213361-1

Standby Liquid Control Pump, Reactor Building, Unit 2

P

Drawings

6SD7212500-03

One Line Diagram 4160V System Service Buses 64B, 64C

S

N/A

Control Room Narrative Logs from 11/13/2022 to

11/30/2022

11/30/2022

VMR147.1

Union Pump

B

VMR147.4

Gear Reducers

A

VMR162

Triclad Vertical Induction Motor

F

Miscellaneous

VMS2539

Centrifugal Water Chillers

L

24.207.09

Division 2 EECW Pump and Valve Operability

24.307.34

DGSW, DFOT, and Starting Air Operability Test EDG 11

Procedures

2.302.07

Calibration and Functional Test of Division 1 4160 Volt Bus

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

64B Undervoltage Relays

MES 49

Evaluation and Control of Leakage from Class 1, 2, and 3

Piping Systems

289097

Perform 3Year Performance Testing of N+1 Train

Dominator and Neptune Equipment

09/03/2021

264432

Perform 42.302.07 Division 1 Bus 64B 4160V Undervoltage

Relays Cal/Funct

10/06/2022

256368

Perform 3Year Performance Test of N Train Dominator and

Neptune Equipment

09/03/2021

61905540

Perform 24.307.34 Sec-5.1 and 5.2 DGSW and DFOT Pump

and Valve Operability Test - EDG 11

09/02/2022

Work Orders

66926147

Perform 24.20201 HPCI Pump/Flow Test and Valve Stroke

at 1025 psig

11/29/2022

2108E

50.54(q) Evaluation - Spent Fuel Pool Level Updates for

RA2.3, RS2.1, and RG2.1

09/21/2021

Miscellaneous

2135S

50.54(q) Screen - Spent Fuel Pool Level Updates for RA2.3,

RS2.1, and RG2.1

09/21/2021

EP101

Classification of Emergencies

43A

71114.04

Procedures

EP101

Classification of Emergencies

71114.06

Procedures

EP101

Classifications of Emergencies

24841

EDG Steady State Voltage and Frequency Tech Spec

Ranges

07/10/2013

26451

SLC Storage Tank Heater B Leak

08/27/2018

27780

VT2 Inspection Results - C4100F001

10/11/2019

27781

VT2 Inspection Results - C4101S002

10/11/2019

24915

CSRT Dry Run Findings

04/21/2020

27392

Safety Concern

06/28/2020

27659

Safety Concern - Questionable Decision Making Leading to

Error Likely Situation

07/05/2020

24291

3D17 IPCS Computer Trouble Due to Loss of SS1

05/16/2021

28792

SS1 CARD Documentation Requires Investigation

10/04/2021

21059

Product Failed EQRT

2/03/2022

71152A

Corrective Action

Documents

23915

Discrepancy Identified in RF20 Torus Recoat WO 55151575

03/19/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

25370

NQA RF21 - Complete MES 27 Risk Evaluation for CARD

24841

04/19/2022

25370

NQA RF21 - Complete MES 27 Risk Evaluation for CARD

24841

04/19/2022

28341

NQA Audit 220107 Deficiency - Untimely Actions for SPING

and SS1 Computer Replacement

07/29/2022

29030

SPING Flow Calibration Review

08/25/2022

230062

VT2 Exam Results - C4101S002

10/02/2022

230739

3D82 MS Steam Line Channel A/B/C/D Radiation Monitor

HiHi Due to Channel A

10/31/2022

231322

Non-Functional Category C EITER (EP580)

11/22/2022

231437

Evaluate Fermi Operating License 2.C.10 for Amendment

11/29/2022

230092

NRC Identified: Missed LER for Past Operability of CARD

27461

10/04/2022

Corrective Action

Documents

Resulting from

Inspection

230116

NRC Identified - Leaking SLC Bolted Connections not

Inspected During RF21

10/04/2022

6I7212095-14

Schematic Diagram Nuclear Steam Supply Shut Off System

Trip System A

O

6I7212185-03

Schematic Diagram Process Radiation Monitor SYS Main

Steam Line Rad Monitor Sub SYS D1103

N

Drawings

6I7212351-02

Schematic Diagram Condenser Vacuum Pump East

(N6101C001)

K

RERP Plan

U.S. Nuclear Regulatory Commission Regulatory Guide

2022 ISI/NDE-

IST Program

Evaluation Sheet

Standby Liquid Control Flange Leakage Evaluation

Equipment Cause

Evaluation

22967, RF21 MES 83114 Inspection - Torus Immersion

Space - Indications Identified in Coating on Bays 4 and 5

03/02/2022

HP Cause

Evaluation

24860, Worker Fell from Lower Work Platform

Miscellaneous

NEI 1503

Licensee Actions to Address Nonconservative Technical

Specifications

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

RERP Plan

Radiological Emergency Response Preparedness Plan

2/18/2019

Operability

Evaluations

MGA 21

General Administrative Conduct Manual

EP101

A - Classification Matrix

EP546

RERP Plan Implementing Procedure

EP580

Equipment Important to Emergency Response (EITER)

Procedures

MGA 31

Supplemental Personnel Control Practice

27456

Ground Fault on YPhase on Output Form Main Unit

Transformer to CM and CF Output Breakers

06/27/2022

27461

FO 2201 Start Up Walkdown: MOV Actuator Disconnected

From Bonnet

06/27/2022

27473

Procedure Revision for Mayfly Infestation Preparation

Plan 27.322

06/27/2022

27475

Actuator Broke Free of Yolk Mounting Bolts - B2103F019

06/27/2022

27499

Add Circuits to 27.322 Mayfly Infestation

06/28/2022

231628

Trend in NRC Identified CARDs Related to MELB Spray

Shield Barriers

2/07/2022

231631

Procedure 23.107 Does Not Work as Written

2/07/2022

Corrective Action

Documents

231951

Evaluate Emerging Trend of Failed MRC Products

2/19/2022

Human

Performance

Cause Evaluation

230092 - NRC Identified: Missed LER for Past Operability

of CARD 2227461

09/13/2022

Miscellaneous

Organizational

Effectiveness

Cause Evaluation

27545 - Loss of 345kv Due to Mayfly Infestation

71152S

Procedures

27.322

Mayfly Infestation Preparation Plan

17, 23

Corrective Action

Documents

27388

HPCI and Div 2 EDG Sequencer Power Failures

08/22/2021

LER 2021001

Unrecognized Impact of Opening of Barrier Doors on High

Energy Line Break Analysis

LER 2022003

Turbine Trip and Subsequent Reactor Trip Due to Mayflies

71153

Miscellaneous

NRC220013

Licensee Event Report 2022001

04/04/2022

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