ML101180295
| ML101180295 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/27/2010 |
| From: | Lougheed V NRC/RGN-III/DRS/EB2 |
| To: | Jennifer Davis Detroit Edison |
| References | |
| IR-10-006 | |
| Download: ML101180295 (46) | |
See also: IR 05000341/2010006
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352
April 27, 2010
Mr. Jack M. Davis Senior Vice President and
Chief Nuclear Officer
Detroit Edison Company
Fermi 2 - 210 NOC
6400 North Dixie Highway
Newport, MI 48166 SUBJECT: FERMI POWER PLANT, UNIT 2 NRC COMPONENT DESIGN BASES INSPECTION (CDBI) INSPECTION REPORT 05000341/2010-006(DRS) Dear Mr. Davis: On April 5, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a component design bases inspection at your Fermi Power Plant, Unit 2. The enclosed report documents the inspection findings, which were discussed on February 26, 2010, with Mr. J. Plona and other members of your staff, and on April 26, 2010 with Mr. J. Plona, Mr. M. Caragher, and other
members of your staff. The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, six NRC-identified findings of very low safety significance were identified, six of which involved violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your
corrective action program, the NRC is treating the issues as Non-Cited Violations in accordance with Section VI.A.1 of the NRC Enforcement Policy. If you contest the subject or severity of any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-
0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Fermi Power Plant. In addition, if you disagree with the
characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional
Administrator, Region III, and the NRC Resident Inspector at the Fermi Power Plant. The information that you provide will be considered in accordance with Inspection Manual
Chapter 0305.
J. Davis -2- In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management
System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/ V. Patricia Lougheed, Acting Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-341 License No. NPF-43 Enclosure: Inspection Report 05000341/2010-006 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-341 License No: NPF-43 Report No: 05000341/2010-006(DRS)
Licensee: Detroit Edison Company Facility:
Fermi Power Plant, Unit 2 Location: Newport, MI Dates: January 25 through April 5, 2010 Inspectors: Z. Falevits, Senior Reactor Inspector, Lead C. Brown, Reactor Inspector, Electrical B. Jose, Senior Reactor Inspector, Electrical
M. Jones, Reactor Inspector, Mechanical
C. Moore, Reactor Inspector, Operations G. Skinner, Electrical Contractor C. Baron, Mechanical Contractor
L. Kozak, Senior Reactor Analyst Approved by: V. Patricia Lougheed, Acting Chief
Engineering Branch 2 Division of Reactor Safety
Enclosure
1SUMMARY OF FINDINGS
01/25/2010 - 04/05/2010; Fermi Power Plant, Unit 2; Component Design Bases Inspection (CDBI). The inspection was a 3-week onsite baseline inspection that focused on the design of components that are risk-significant and have low design margin. The inspection was
conducted by regional engineering inspectors and two consultants. Six findings of very low
safety significance were identified with six associated Non-Cited Violations (NCVs) of NRC
regulations. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"
Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealed Findings
Cornerstone: Initiating Events Green. The inspectors identified a finding having very low safety significance with an Non-Cited Violation (NCV) of 10 CFR 50.65(b)(2)(iii), for the licensee's failure to include turbine building heating ventilation and air conditioning (TBHVAC) fans in the scope of
their maintenance rule program. Specifically, the licensee failed to effectively control
TBHVAC system components condition through the implementation of appropriate preventive maintenance as directed by the requirements of the maintenance rule. The TBHVAC system is used to maintain the turbine building at a negative pressure for radiological considerations and room and area temperature below design limits to
prevent a Group 1 Isolation resulting in main steam isolation valves (MSIV) closure and
a reactor trip. The licensee entered the issue into their corrective action program for
further evaluation. This finding was more than minor because it was associated with the Initiating Events cornerstone attribute of equipment performance, and affected the cornerstone objective to limit the likelihood of those event that upset plant stability and challenge critical
safety functions during shutdown, as well as power operations. This finding is of very
low safety significance (Green), because it does not contribute to the likelihood that
mitigation equipment or functions will not be available. The inspectors determined there was no cross-cutting aspect associated with this finding because the system was initially scoped out during the initial baseline evaluation for maintenance rule in June 1995 and
was not reflective of current performance. (Section 1R21.3.b.(4)) Cornerstone: Mitigating Systems Green. The inspectors identified a finding having very low safety significance with an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to perform adequate calculations to ensure the availability of offsite
power. Specifically, on two occasions the licensee failed to perform adequate calculations to demonstrate the availability of 120kV system offsite power. The first occasion was related to the analysis in calculation DC-0919 for conditions when the
System Service (SS) Transformer No. 64 load tap changer (LTC) was in service. The
Enclosure
2second occasion was related to TSR-35286, which analyzed conditions for placing the SS Transformer No. 64 LTC in manual. This finding was entered into the licensee's
corrective action program to revise the calculations and perform an Engineering Functional Analysis (EFA) to demonstrate operability. The finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstone objective of ensuring
the availability, reliability, and capability of safety-related equipment to respond to
initiating events to prevent undesirable consequences. Specifically, there was
reasonable doubt as to whether the offsite power supply would remain operable during a design basis event pending re-analysis. This finding is of very low safety significance (Green) because the design deficiency was confirmed not to result in loss of operability
or functionality. This finding has a cross-cutting aspect in the area of Human
Performance, Resources, because the licensee did not provide a complete, accurate,
and up-to-date design documentation, to assure nuclear safety. (IMC 0310, Section 06.01.b.(3) H.2(c)) (Section 1R21.3.b.(1)) Green. The inspectors identified a finding having very low safety significance (Green) with an associated NCV of Technical Specifications 5.4.1.a, "Procedures" for the licensee's failure to translate the design requirements for the availability of the 120kV
offsite power into station operating procedures, which are used to control voltages on the
offsite power system within acceptable ranges. Specifically, the licensee failed to
translate the 2.1 percent switchyard voltage drop criteria assumed in calculation DC-0919 into station operating procedures. This finding was entered into the licensee's corrective action program to revise the calculations and perform an EFA to demonstrate
operability. The finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstone objective of ensuring the availability, reliability, and capability of safety-related equipment to respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not ensure the availability of the 120kV power source to 4160V safety buses by
implementing procedural controls to ensure that the step voltage decrease on the trip on
the Fermi generating unit did not exceed the 2.1 percent value analyzed in calculation
DC-0919. This finding is of very low safety significance (Green), because the design deficiency was confirmed not to result in loss of operability or functionality. The inspectors concluded that the cause of the finding was related to the cross-cutting
aspect of Human Performance, Resources, because the licensee did not provide
complete, accurate, and up-to-date design documentation to assure nuclear safety.
(IMC 0310, Section 06.01.b.(3) H.2(c)) (Section 1R21.3.b.(3)) Green. The inspectors identified a finding having very low safety significance with an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the
licensee's failure to accurately account for the cable resistance for the reactor core isolation cooling (RCIC) and high pressure core injection (HPCI) dc Motor Operated Valves (MOVs) in the DC short circuit calculation. The issue, along with other related
electrical calculational errors, was entered into the licensee's corrective action program.
Enclosure
3The finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstone objective of ensuring
the availability, reliability, and capability of safety-related equipment to respond to initiating events to prevent undesirable consequences. This finding is of very low safety significance (Green) because the design deficiency was confirmed not to result in loss of operability or functionality. The inspectors concluded that the cause of the finding was
related to the cross-cutting aspect of Human Performance, Resources, because the
licensee did not provide complete, accurate, and up-to-date design documentation to
assure nuclear safety. (IMC 0310, Section 06.01.b.(3) H.2(c)) (Section 1R21.3.b.(6)) Green. The inspectors identified a finding of very low safety significance (Green) for the licensee's failure to adhere to operating experience program procedural requirements. Specifically, the inspectors identified three instances where the licensee failed to adequately evaluate and take appropriate corrective actions on industry operating
experience contrary to the requirements in licensee's operating experience Procedure MLS04, Revision 22. Also, based on the inspectors' finding, the licensee performed an
extent of condition and identified approximately 30 more operating experience reviews performed within the last two years as less than adequate. No violation of NRC
requirements occurred. The finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective
of ensuring equipment availability and reliability. Specifically, multiple examples were identified where the licensee failed to ensure that problems identified in industry
operating experience were evaluated for applicability to Fermi and corrective actions
implemented. This finding is of very low safety significance (Green) because the design deficiency was confirmed not to result in loss of operability or functionality. The
inspectors concluded that the cause of the finding was related to the cross-cutting
element of Problem Identification and Resolution, Operating Experience, because the licensee failed to systematically collect, evaluate, and communicate to affected internal stakeholders in a timely manner relevant internal and external operating experience to support plat safety. (IMC 0310, Section 06.02.b.(1) P.2(a)) (Section 1R21.4.b)
Green. The inspectors identified a finding of very low safety significance (Green) with an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," having
very low safety significance with two examples, for failing to perform adequate electrical design calculations to support modifications to the degraded voltage protection scheme. The first example involved the failure to analyze motor starting capability based on
voltages afforded by the degraded voltage relay scheme. The second example involved
the failure to perform conservative calculations to show that spurious grid separation
would not occur during accidents due to action of the degraded voltage relays. This
finding was entered into the licensee's corrective action program to revise the
calculations and perform an EFA to demonstrate operability. The finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control and affected the cornerstone objective of ensuring
the availability, reliability, and capability of safety-related equipment to respond to
initiating events to prevent undesirable consequences. Specifically, the licensee failed
to confirm the adequacy of new degraded voltage relay set-points by ensuring motors had adequate voltage to start if safety buses remained connected to offsite power during a LOCA with degraded voltage. In addition, the licensee failed to ensure that spurious
Enclosure
4grid separation would not occur during accidents due to action of the degraded voltage relays. This finding is of very low safety significance (Green) because the design
deficiency was confirmed not to result in loss of operability or functionality. The inspectors concluded that the cause of the finding was related to the cross-cutting aspect of Human Performance, Resources, because the licensee did not provide
complete, accurate, and up-to-date design documentation to assure nuclear safety.
(IMC 0310, Section 06.01.b.(3) H.2(c)) (Section 1R21.5.b) Cornerstone: Barrier Integrity Green. The inspectors identified a finding of very low safety significance (Green) with an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for failing to perform proper motor starting studies to demonstrate that motors would successfully start when connected to the offsite power supply. This finding was entered into the licensee's corrective action program to revise the calculations and perform an EFA to
demonstrate operability.
The finding was more than minor because it was associated with the Barrier Integrity cornerstone attribute of design control and affected the cornerstone objective to provide
reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, failing to demonstrate that the approved design was adequate to ensure safety-related motors have sufficient voltage
to start created a reasonable doubt as to the operability of the control complex hearing
ventilation and air-conditioning system needed to provide a radiological barrier for
control room personnel during an accident. The inspectors determined that this finding is of very low safety significance (Green) because the radiological function of the control complex was not affected. The inspectors concluded that the cause of the finding was related to the cross-cutting aspect of Human Performance, Resources, because the
licensee did not provide complete, accurate, and up-to-date design documentation to
assure nuclear safety. (IMC 0310, Section 06.01.b.(3) H.2(c)) (Section 1R21.3.b.(2))
B. Licensee-Identified Violations
No violations of significance were identified.
Enclosure
5REPORT DETAILS
1. REACTOR SAFETY Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity 1R21 Component Design Bases Inspection (71111.21)
.1 Introduction
The objective of the component design bases inspection is to verify that design bases
have been correctly implemented for the selected risk-significant components and
that operating procedures and operator actions are consistent with design and
licensing bases. As plants age, their design bases may be difficult to determine and an important design feature may be altered or disabled during a modification. The probabilistic risk-assessment (PRA) model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable
area verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure performance. Specific documents reviewed during the inspection are listed in the Attachment to this
report. .2 Inspection Sample Selection Process
The inspectors selected risk-significant components and operator actions for review using information contained in the licensee's PRA and the Fermi Standardized Plant Analysis Risk (SPAR) Model, Revision 3.5.
In general, the selection was based upon the components and operator actions having a
risk achievement worth of greater than 1.3 and/or a risk-reduction worth greater than 1.005. The operator actions selected for review included actions taken by operators both inside and outside of the control room
during postulated accident scenarios. In addition, the inspectors selected operating
experience issues associated with the selected components. The inspectors performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design reductions
caused by design modification, power uprates, or reductions due to degraded material
condition. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as performance test results, significant corrective action, repeated maintenance activities, Maintenance Rule (a)(1)
status, components requiring an operability evaluation, NRC resident inspector input of
problem areas/equipment, and system health reports. Consideration was also given to
the uniqueness and complexity of the design, operating experience, and the available
defense in depth margins. A summary of the reviews performed and the specific inspection findings identified are included in the following sections of this report. This inspection constituted 26 samples as defined in Inspection Procedure 71111.21-05.
Enclosure
6.3 Component Design
a. Inspection Scope
The inspectors reviewed the updated final safety analysis report (UFSAR), Technical Specifications (TS), design basis documents, drawings, calculations and other available
design basis information, to determine t
he performance requirements of the selected components. The inspectors used applicable industry standards, such as the American Society of Mechanical Engineers (ASME) Code, Institute of Electrical and Electronics
Engineers (IEEE) Standards and the National Electric Code, to evaluate acceptability of
the systems' design. The NRC also eval
uated licensee actions, if any, taken in response to NRC issued operating experience, su
ch as Bulletins, Generic Letters (GLs), Regulatory Issue Summaries (RISs), and Information Notices (INs). The review was to verify that the selected components would function as designed when required and support proper operation of the associated systems. The attributes that were needed for a component to perform its required function included process medium, energy sources, control systems, operator actions, and heat removal. The attributes to verify that the component condition and tested capability was consistent with the design bases and
was appropriate may include installed configuration, system operation, detailed design, system testing, equipment and environmental qualification, equipment protection, component inputs and outputs, operating experience, and component degradation. For each of the components selected, the inspectors reviewed the maintenance history, system health reports, operating experience-related information and licensee corrective
action program documents. Field walkdowns were conducted for all accessible
components to assess material condition and to verify that the as-built condition was
consistent with the design. Other attributes reviewed are included as part of the scope
for each individual component. The following 15 components were reviewed: Reactor Core Isolation Cooling (RCIC) Pump (E5101C001): The inspectors reviewed RCIC pump and turbine data to ensure compatibility so that the intended safety function of the system can be met. Hydraulic calculations were reviewed to assure that the flow requirements were met and that sufficient net
positive suction head (NPSH) was available from both the RCIC tank and the
suppression pool. The water supply was further examined to assure that a reliable water supply was available and that transfer from the RCIC tank to the suppression pool could be accomplished without pump damage and within
acceptable transfer times. An interview was conducted with systems engineers
to discuss testing, reservoir capacity and maintenance history. The requirements
from both the UFSAR and TS were reviewed to assure that the design conformed to the licensing commitments. Core Spray (CS) Pump (E2101C001C)
- The inspectors reviewed the system hydraulic calculations including NPSH, system flow, and potential vortexing to ensure the pump was capable of providing sufficient flow under accident conditions. The inspectors reviewed surveillance test procedures and the bases
for the acceptance criteria to verify that the tests would ensure the pumps were
capable of their required performance. The inspectors also reviewed aligning the
pump to an alternate water source and the minimum flow protection for the pump
Enclosure
7to verify performance under all conditions. The inspectors performed a walkdown of the pump and associated equipment to verify the material condition
and verify that no hazards existed in the area. The inspectors reviewed a sample of past corrective action documents, the system health report, training documents, the TS, and the design basis document. In addition, the inspectors
reviewed electrical load flow and voltage drop calculations to determine whether
the CS Pump 1C motor would have adequate voltage to start and run during
design basis accident conditions. In addition, the inspectors reviewed electrical
schematic and logic diagrams to determine whether automatic and manual control functions for the motors were as described in the design bases. The inspectors also reviewed the 130Vdc control voltage drop calculation and verified
that the pump breaker control components would have sufficient voltage to close the breaker when the source (associated 130Vdc battery) was at its minimum
voltage. Core Spray Division 1 Outboard Isolation Motor Operated Valve (MOV) (E2150F004A): The inspectors reviewed the calculations including required thrust, structural weak link analysis, and maximum differential pressure, to
ensure the valve was capable of functioning under design conditions. The
system engineer was interviewed, primarily to discuss overall health and issues associated with the identified voiding and potential binding concerns. Periodic
verification diagnostic and in-service testing (IST) results were reviewed to verify acceptance criteria were met and performance degradation would be identified. Emergency Diesel Generator (EDG) 12 (R3001S002): The inspectors reviewed the mechanical aspects of the EDG, including the fuel system, the cooling system, and the building ventilation system. The inspectors reviewed the
capacity of the fuel-oil storage system and the design of the fuel-oil transfer
system to verify that they meet their design basis requirements. This review
included the fuel consumption rate of the EDG and the minimum allowable tank
levels to preclude vortexing. The inspectors reviewed the design of the EDG cooling system to verify that adequate cooling water would be provided. The inspectors reviewed the design of the EDG area ventilation system to verify that
the system was capable of maintaining an acceptable environment for the
operating equipment. In addition, the inspectors reviewed the capability of the EDG to perform its design function in the event of a postulated tornado event. This review included the capability of interior building walls to withstand pressure differentials and the required response of the operators to damaged ventilation
equipment. The inspectors also performed a walkdown of the EDG and
associated equipment to verify the material condition and to verify that no
hazards existed in the area. The inspectors reviewed a sample of past corrective
action documents, to determine whether there had been any adverse operating trends; the system health report; training documents; the TS, and the design basis documents. In addition, the inspectors reviewed the EDG output breaker
control logic; verified the minimum voltage requirements of the control
components and compared the minimum voltage requirement to the minimum
available voltage when the associated 130Vdc battery was at its lowest voltage to ensure that the EDG output breaker will close when required.
Enclosure
8 Fire Protection Diesel Fire Pump, (P8000C001): The inspectors reviewed the pump start schematic diagrams, the 48Vdc start up battery requirements, and the battery condition and verified that sufficient power and control source was available
to start the pump and maintain the engine auxiliary components that require dc
control power. In addition, the inspectors reviewed the motor nameplate data to
determine compatibility with the pump and power supply requirements. The
schematic diagram was reviewed to verify manual and automatic operation of the
pump. The inspectors reviewed the vendor manual and the pump curve to verify
pumping capability. The interaction between the fuel-oil day tank level indicator
and the fuel oil transfer pump was reviewed to verify continual compliance with the
system design requirements. Fuel-oil storage tank design was reviewed to ensure usable volume was consistent with design calculations and surveillance results. The inspectors reviewed the maintenance rule scoping documents used for re-classifying the system to (a)(1) status and the associated corrective actions and pending revisions to the "Get Well Plan." Due to pending actions associated with
the maintenance rule status change, only a limited review of the licensee's most recent root cause report could be performed. A walkdown was conducted with the systems engineer to assess the material condition of the pump and diesel. System Service (SS) Transformer No. 64 (R1200S002): The inspectors reviewed the calculations and operating procedures to determine whether bus voltages
maintained by the automatic load-tap changer were adequate to assure the
availability of offsite power during low voltage conditions. The inspectors reviewed
sources of power for automatic control equipment to determine whether the transformer would operate properly during low voltage conditions. The inspectors reviewed maintenance schedules, procedures, vendor manuals, and completed
work records to determine whether the transformer was being properly maintained.
The inspectors reviewed corrective action histories to determine whether there had
been any adverse operating trends. In addition, the inspectors performed a visual
inspection of SS Transformer No. 64 to assess material condition and the presence
of hazards. Division 1 Essential Safety Feature (ESF) Bus 64C 4.16 kV (R1400S001C)
- The inspectors reviewed bus loading calculations to determine whether the 4160Vac system had sufficient capacity to support its required loads under worst case
accident loading and grid voltage conditions. The inspectors reviewed the design
of the 4160Vac bus degraded voltage protection scheme to determine whether it
afforded adequate voltage to safety-related devices at all voltage distribution levels. This included review of degraded voltage relay setpoint calculations, motor starting and running voltage calculations, and motor control center (MCC) control-
circuit voltage drop calculations. The inspectors reviewed procedures and
completed surveillances for calibration of the degraded voltage relays to determine
whether acceptance criteria was consistent with design calculations, and to determine whether relays were performing satisfactorily. The inspectors reviewed operating procedures to determine whether the limits and protocols for maintaining offsite voltage were consistent with design calculations. The inspectors reviewed
the Fermi response to NRC Generic Letter 2006-02 to determine whether current
procedures for maintaining the availability of offsite power were consistent with
licensee responses. The inspectors reviewed protective relaying schemes and calculations to determine whether equipment such as motors and cables were
adequately protected, and to determine whether protective devices featured proper
Enclosure
9selective tripping coordination. The inspectors reviewed system health reports, corrective action documents and maintenance records to determine whether there
were any adverse operating trends. The inspectors reviewed approved modification packages to address deficiencies in the degraded voltage protection
scheme subject to NRC backfit requirements issued in June 2008. In addition, the inspectors performed a visual inspection of the 4160Vac safety buses to assess
material condition and the presence of hazards. In addition, the inspectors
reviewed the 130Vdc control voltage drop calculation and verified that sufficient
control voltage would be available for the breaker trip and close components for both the incoming lines and the associated EDG breaker. ESF Bus 72C 480Vac Switchgear and 72C-2A MCC: The inspectors reviewed the degraded voltage protection scheme to determine whether the voltage setpoints were selected based on the voltage requirements for safety-related loads at the
480Vac level. The inspectors reviewed 480Vac short circuit calculations to
determine whether protective devices were applied within their ratings and whether
appropriate fault values were used in protective relaying calculations. The inspectors reviewed maintenance procedures, and schedules for the 480Vac load centers and MCC to determine whether equipment was being properly maintained.
The inspectors reviewed system health and corrective action documents to
determine whether there were any adverse operating trends. In addition, the
inspectors performed a visual inspection of the 480Vac safety buses to assess material condition and the presence of hazards. Residual Heat Removal Service Water (RHRSW) Division 2 Pump E1151C001B Minimum Flow Air Operated Valve (E11F400B)
- The inspectors reviewed the system description for the control air system to determine the valves ability to maintain line pressure on the interruptible control air system. The inspectors
reviewed valve and actuator design data to verify compatibility. The inspectors
reviewed corrective action documents to ensure condition reports were
appropriately addressed and resolved or closed. The inspectors reviewed piping and instrumentation diagrams for the control air system, where the valve was located, and performed a system walkdown with licensee staff to verify the valve's
position in the system lineup. Division 1 RHRSW Pump A (E1151C001A): The inspectors reviewed the 130Vdc control voltage drop calculation and verified that sufficient control voltage would be
available for the pump start breaker control components when the associated
130Vdc battery was at its minimum voltage. In addition, the inspectors reviewed
the system hydraulic calculations in
cluding NPSH, system flow, and submergence to ensure the pump was capable of providing sufficient flow under normal and
accident conditions. The inspectors reviewed the design of the pump area
ventilation system to verify that the system was capable of maintaining an
acceptable environment for the operating equipment. The inspectors reviewed surveillance test procedures and the bases for the acceptance criteria to verify that the tests would ensure the pumps were capable of their required performance.
The inspectors also reviewed the minimum flow protection for the pump to verify adequate performance under all conditions. The inspectors reviewed a design change associated with replacing the pump. The inspectors performed a
walkdown of the pump and associated equipment to verify the material condition and verify that no hazards existed in the area. The inspectors also reviewed a
Enclosure
10sample of past corrective action documents, the system health report, training documents, the TS, and the design basis document. Residual Heat Removal (RHR) Division 1
Heat Exchanger Outlet Isolation Valve (E1150F068A): The inspectors reviewed the thrust and differential pressure calculations associated with this motor operated valve to verify its capability to perform its function during normal and accident conditions. The inspectors reviewed the applicable surveillance test procedure and completed surveillances to
ensure actual performance was acceptable. Post-accident operating procedures
related to the valve's operation were also reviewed. The inspectors reviewed the
voltage used in the MOV calculations to verify consistency with the associated
electrical distribution calculations. The inspectors performed a walkdown of the pump and associated equipment to verify the material condition and verify that no hazards existed in the area. The inspectors also reviewed a sample of past
corrective action documents, the system
health report, training documents, the TS, and the design basis document. Battery 2PA 130/260Vdc (R3200S003)
- The inspectors reviewed calculations and analyses relating to battery sizing and capacity, hydrogen generation, and station
blackout (SBO) coping. The review was performed to ascertain the adequacy and appropriateness of design assumptions, and to verify that the battery was adequately sized to support the design basis required voltage requirements of the 130/260Vdc safety-related loads under both design basis accident and SBO
conditions. The inspectors also reviewed a sample of completed surveillance
tests, service tests, performance discharge tests, and modified performance tests. The review of various discharge tests was to verify that the battery capacity was adequate to support the design basis duty cycle requirements and to verify that the battery capacity meets TS requirements. Division 1 dc Bus 2PA-2 (R3200S026): The inspectors reviewed 130Vdc short circuit calculations and verified that the interrupting ratings of the fuses were well above the calculated short circuit currents. The 130Vdc voltage drop calculations
were reviewed to determine if adequate voltage would be available for the 4.16kV
breaker open and close coils and spring charging motors. The inspectors reviewed the 4.16kV motor control logic diagrams and the 130Vdc voltage-drop calculation to ensure adequate voltage would be available for the control circuit components
under all design basis conditions. The inspectors also reviewed the dc equipment
operability calculation and the dc MOV mechanical thrust calculation to ensure that
the RCIC and high pressure coolant injection (HPCI) MOVs would develop sufficient thrust under worst case voltage conditions. Division 1 Battery Charger 2A-1 (R3200S020): The inspectors reviewed calculations relating to sizing and current limit setting to ascertain the adequacy and appropriateness of design assumptions, and to verify that the charger was
adequately sized to support the design basis duty cycle requirements of the
130Vdc safety-related loads and the associated battery under both normal and
design basis accident conditions. In addition, the test procedures were reviewed to determine whether maintenance and testing activities for the battery charger were in accordance with vendor's recommendations. The inspectors also reviewed
preventive maintenance activities to verify that the electrolytic capacitors installed
in the battery charger were replaced with appropriate frequency.
Enclosure
11 Turbine Building HVAC Exhaust Fan (U4100C006
): The inspectors reviewed system health reports and corrective actions program documents for the turbine building HVAC (TBHVAC) system. The inspectors reviewed maintenance rule scoping documents and the basis for the systems exclusion. The inspectors
reviewed vendor manuals and performance curves to verify the system was capable of meeting its intended function when in operation. The TBHVAC system
engineer was interviewed and the overall health of the TBHVAC system, with an emphasis on exhaust fan failures, was discussed. The inspectors performed a
walkdown with the system engineer and maintenance personnel of the plenum
area and of the failed TBHVAC fans.
b. Findings (1) Inadequate Calculations for Availability of 120kV System Offsite Power
Introduction: The inspectors identified a finding of very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III,
"Design Control," for the licensee's failure to perform adequate calculations to ensure the
availability of offsite power. Specifically, on two occasions the licensee failed to perform adequate calculations to demonstrate the avail
ability of 120kV system offsite power. The first occasion was related to the analysis in calculation DC-0919, for conditions when the
service system (SS) transformer No. 64 LTC was in service. The second occasion was
related to TSR-35286, which analyzed conditions for placing the SS transformer No. 64
LTC in manual operation.
Description: The inspector reviewed calculation DC-0919, "Undervoltage Relay Setpoints." This calculation relied, in part, upon computer databases ETAP and LOFSTAB, which were not maintained as independent calculations such that the
assumptions and inputs could not be independently verified. This increased the difficulty
in reviewing the many permutations presented in the DC-0919 calculation. The inspector
identified numerous errors with this calculation including unverified assumptions and unsupported conclusions. The inspector specifically identified a concern with the analysis of SS transformer No. 64 LTC performance in Section 9.13 of DC 0919, "Undervoltage
Relay Setpoints," which resulted in the analysis being non-conservative. Major errors
included failure to properly account for the 2.1 percent step voltage decrease on the trip of the unit, and failure to account for the two percent LTC deadband. The calculation determined the degraded voltage relay time delay necessary to permit the SS transformer No. 64 LTC to compensate for voltage drops on the 4160V safety-related
buses at the onset of an accident, with the associated trip of the main generator. Although
the calculation described the need to consider a 2.1 percent step voltage decrease on the
trip of the unit, it was not clear in the calculation how this was actually accomplished. The
calculation included a two-tap margin above the eight taps shown to be needed by voltage results from ETAP runs in Attachment "I." The ETAP runs did not account for the 2.1 percent step voltage decrease, and also considered an initial bus voltage slightly above
the center of the LTC deadband, instead of conservatively at the low-end of the band. In
addition, because the low-end of the LTC deadband was 99 percent, the LTC might not
act to improve voltage any further once the 4kv bus reached this level. The acceptance criteria in calculation DC-0919 required voltage to recover to 99.8 percent; therefore, voltage might not recover, regardless of the time afforded for LTC action, the inspector
noted that this error adversely affected the licensee's response to Generic Letter (GL)
Enclosure
122006-002 Item 2c. Had the error been known at the time the licensee responded to the GL, the response to Item 2c should probably have been answered negatively. The
licensee addressed this condition in EFA-R14-10-004, Revisions 0 and A, and took credit for degraded voltage relay tolerances from surveillance results that were more favorable than the values used in the calculation. The EFA-R14-10-004, Revision 0, was
superseded by EFA-R14-10-004, Revision A after the end of the inspection period so a
detailed assessment of this revision was not made. Additionally, Technical Service Request (TSR)-35286 analyzed conditions for placing the SS transformer No. 64 LTC in manual. This condition could occur while the offsite voltage is within its expected voltage range as defined in the UFSAR. The technical approach in the TSR was to select a manually adjusted target voltage for the Division-1 4160V buses
that was approximately 2.64 percent higher than normal (4270V minimum versus 4160V
+/-1 percent with the LTC in automatic). This was done in order to compensate for the
increased post LOCA loading on the buses, thus enabling the degraded voltage relays to reset. The TSR included a steady state ETAP run that showed bus voltage with LOCA loads would recover to 4188V, which was considered to be sufficient to reset the relays,
because they reset at approximately 4160V. However, the analysis failed to consider the step voltage decrease that could occur on the trip of the unit, which was assumed to be 2.1 percent in calculation DC-0919. Consequently, the analysis was non-conservative. Preliminary calculations by the inspectors showed that compensation of approximately 2.64 percent above the normal bus voltage range would not be sufficient to offset the approximately 4.3 percent drop that would occur due the combined effects of LOCA bus
loading and the 2.1 percent step voltage decrease on the trip of the unit. In response to
the inspectors concerns, the licensee initiated a CARD and implemented restrictions on
placing the LTC in manual, pending reanalysis.
Analysis: The inspectors determined that the failure to perform adequate analyses for availability of the120kV offsite power supply wa
s contrary to 10 CFR Part 50, Appendix B, Criterion III, "Design Control," and was a performance deficiency. The performance deficiency was determined to be more than minor because the finding was associated with
the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, there was
reasonable doubt as to whether the offsite power supply would remain operable during a
design basis event pending reanalysis. The finding was also similar to Example 3.j. of
IMC 0612, Appendix E, Based on additional information provided by the licensee after the exit, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening
and Characterization of findings," Table 4a for the Mitigating Systems Cornerstone. The
inspectors answered "No" to each of the questions in Column 2. Therefore, the finding
screened as having very low safety significance (Green). The inspectors determined the primary cause of this issue was related to Human Performance, Resources, which requires complete, accurate, and up-to-date design
documentation, including calculations and procedures, to assure nuclear safety.
(IMC 0310, Section 06.01.b.(3) H.2(c))
Enclosure
13 Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, as of January 25, 2010, the licensee failed to ensure that the design basis for the degraded voltage relay setpoint was correctly translated into
procedures. Specifically, on two occasions the licensee failed to perform conservative calculations to show that the Division 1 degraded voltage relays would reset when
required to maintain the availability of offsite power. Because this violation was of very low safety significance and was entered into the licensee's corrective action program as CARD 10-21733, this violation is being treated as an Non-Cited Violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000341/2010006-01,
Inadequate Calculations for Availability of 120kV System Offsite Power).
(2) Inadequate Motor Starting Voltage Calculations
Introduction: The inspectors identified a finding having very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the
licensee's failure to perform proper calculations to demonstrate that motors would
successfully start when connected to the offsite power supply.
Description: The NRC previously determined that the design of the Fermi degraded voltage protection scheme had failed to consider a simultaneous LOCA with a degraded voltage, in that, the time delay for actuation of the degraded voltage protection exceeded
the time delay assumed in the UFSAR accident analysis (see Inspection Report 05000341/2008-008). The NRC required that the licensee rectify this design oversight. The modifications are scheduled for implementation in the fall of 2010, during Refueling
Outage 14.
The electrical system design in place prior to the modifications being implemented was based on offsite power system voltages no lower than the administrative limits listed in
UFSAR Section 8.2.2.5.1 as follows: 120kV system - 112kV minimum and 345kV system - 339.5kV minimum. Calculation DC-0919 determined the onsite electrical system bus voltages available with these voltages on the offsite power system based on the starting voltage requirements for motors, and compared to available bus voltages. The inspectors determined that these calculations were non-conservative because motor starting voltage
requirements were based on 70 percent of motor rated voltage at the terminals, rather
than on the voltages stipulated in the motor specifications. These voltages were as
follows: RHR Motors 80 percent (Specification 3037-A); Core Spray Motors 90 percent (Specification 3037-A); and 460V Motors (except MOVs) 85 percent (Specification 3067). The inspectors determined that this error stemmed, in part, from the licensee canceling calculation DC-5264, which analyzed 460Vac motor starting capability during accident
load sequencing.
Enclosure
14Motor starting voltage less than the specified minimum could result in inadequate load torque, slow starting, overheating, or tripping of overcurrent protective devices. These
factors were not evaluated in the calculation. The inspectors noted that DC-0919, Attachment "I," Revision F, which contained the static motor starting results, and DC-0919, Attachment "O" (from ECR 35621-1), which was a dynamic study, showed considerably
different results. For example, the minimum voltage at the terminals of RHR Pump "A"
during starting in Attachment "O" was 85.48 percent, whereas the voltage shown in
Attachment "I" was 82.54 percent. The licensee confirmed that the dynamic analysis in
Attachment "O" was non-conservative due to incorrect modeling of the SS Transformer No. 64 transformer automatic LTC. In addition, Attachment "I" was determined to be non-conservative because it did not take the 2.1 percent step voltage decrease at the start of
an accident described in calculation DC-0919, Assumption 5.1, and did not take into
account the effect of the two percent deadband on the SS Transformer No. 64 LTC. The
licensee performed an operability evaluation, EFA-R14-10-004, which the inspectors determined to be incomplete because it did not address the case where 480V motors were started simultaneously with the large ESF motors during accident load sequencing, did not
address the step voltage decrease occurring on the trip of the unit, and did not address the
transient response time of voltage regulators on the Division 2 480V buses. The licensee revised the operability analysis and was able to demonstrate operability; however a detailed review of the operability analysis was not completed. The inspectors determined that the components with the lowest margin were the control complex HVAC chiller supply
and return motors.
Analysis: The inspectors determined that the failure to perform adequate calculations to demonstrate that motors had sufficient voltage to start during accidents was contrary to 10 CFR Part 50, Appendix B, Criterion III, "Design Control," and was a performance deficiency. The performance deficiency was determined to be more than minor because the finding was associated with the Barrier Integrity cornerstone attribute of design control
and affected the cornerstone objective of provide reasonable assurance that physical
design barriers (fuel cladding, reactor coolant system, and containment) protect the public
from radionuclide releases caused by accidents or events. Specifically, the licensee failed to demonstrate that the approved design was adequate to ensure safety-related motors
had sufficient voltage to start if safety buses remained connected to offsite power during a
LOCA with normal offsite power system voltages. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 04, and Table 4a for the Barrier Integrity Cornerstone. The
inspectors determined that there was only a degradation of the radiological barrier function provided for the control room. As such, the finding was determined to be of very low
safety significance (Green). The inspectors determined the primary cause of this issue was related to Human Performance, Resources, which requires complete, accurate, and up-to-date design
documentation, including calculations and procedures, to assure nuclear safety. (IMC 0310, Section 06.01.b.(3) [H.2.(c)])
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified
calculational methods, or by the performance of a suitable testing program.
Enclosure
15Contrary to the above, as of January 25, 2010, the licensee's design control measures failed to verify the adequacy of design of the onsite electrical distribution system.
Specifically, the inspectors identified that the licensee failed to properly analyze motor starting voltage requirements while the safety buses were connected to offsite power. Because this violation was of very low safety significance and was entered into the
licensee's corrective action program as CARDs 10-20748, and 10-21733, this violation is
being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.
(NCV 05000341/2010006-02, Inadequate Motor Starting Voltage Calculations) (3) Inadequate Procedures for Controlling Availability of 120kV System Voltage
Introduction: The inspector identified a finding of very low safety significance with an associated NCV of TS 5.4.1.a, "Procedures" for the licensee's failure to translate design
requirements for the availability of offsite power into procedures. Specifically, the licensee
failed to translate the 2.1 percent switchyard voltage drop criteria assumed in calculation
DC-0919 into station operating Procedures ODE-12, "Operations Department Expectations," Revision 18; MOP05, "Control of Equipment," Revision 30, and
20.300.Grid, "Grid Disturbance," Revision 2.
Description: Calculation DC-0919, Assumption 5.1, identified that a 2.1 percent step voltage decrease could occur on the 120kV offsite power system on the trip of the unit. This assumption was necessary because SS Transformer No. 64, which supplies power to the Division 1 buses from the 120kV switchyard, was equipped with an automatic LTC. During normal operation, the LTC normalizes voltage on the 4160V bus. When a sudden
switchyard voltage decrease occurs, such as may occur on the trip of the unit, the voltage
decrease is reflected onto the 4160V buses. The degraded voltage relays on the Division
1 4160V safety buses featured a nominal 44 second time delay to afford time for the LTC
to compensate for this voltage decrease and raise the bus voltage above the reset setpoint (99.8 percent of bus rated voltage) of the relays. If the voltage decrease exceeded the value assumed in the calculation, the LTC might not have sufficient time to adjust voltage to the required value before the degraded voltage relay scheme times out, and grid separation occurs. The inspectors noted that station and system operations procedures intended to control voltages on the offsite power system within acceptable ranges only addressed the minimum and maximum discrete voltages for the 120 kV systems, and did not address the
magnitude of the sudden voltage decrease that could be tolerated. Specifically, Procedure
ODE-12, Section 7, Table 1 provided values from which the licensed limits for operability
were derived. Table 1 identified the minimum and maximum discrete values (112kV and
126kV, respectively) for 120kV system voltage and did not address the sudden decrease in voltage that could be tolerated, as discussed in calculation DC-0919. Similarly, Procedure 20.300.GRID provided criteria for assessing operability of the offsite power
supplies based on minimum voltages only, instead of including voltage drop criteria for the
120kV system. Procedure MOP5, Section 6.13 discussed conditions where the offsite
power supplies would be considered inoperable, but these did not include exceeding the voltage drop criteria analyzed in Calculation DC-0919. In response the inspectors concerns, the licensee issued a CARD and initiated monitoring of voltage drop criteria.
The CARD stated that as of March 3, 2010, ITC Transmission added the 2.1 percent
voltage drop limits on Buses 101 and 102 for real time contingency analysis.
Enclosure
16 Analysis: The inspectors determined that the failure to translate design criteria for the operability of 120kV offsite power supply into procedures was contrary to TS 5.4.1a, "Procedures," and was a performance deficiency. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems
cornerstone attribute of Design Control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences.
Specifically, the licensee did not ensure the availability of the 120kV power source to
4160V safety buses by implementing procedural controls to ensure that the step voltage decrease on the trip on the Fermi generating unit did not exceed the 2.1 percent value analyzed in calculation DC-0919. The finding was also similar to Example 3.j. of IMC 0612, Appendix E. The inspectors determined the finding could be evaluated using the
SDP in accordance with IMC 0609, Attachment 04, and Table 4a for the Mitigating
Systems Cornerstone. The inspectors answered "No" to each of the questions in Column 2. Therefore, the finding screened as having very low safety significance (Green). The inspectors determined the primary cause of this issue was related to Human Performance, Resources, which requires complete, accurate and up-to-date design
documentation, including calculations and procedures, to assure nuclear safety.
(IMC 0310, Section 06.01.b.(3) H.2(c))
Enforcement: Technical Specification 5.4.1.a, requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Paragraph 6, "Procedures for Combating Emergencies and Other Significant Events," Item c addresses loss of electrical power and
degraded power sources. Licensee Procedures ODE-12, "Operations Department Expectations," Revision 18, MOP05, "Control of Equipment," Revision 30, and 20.300.Grid, "Grid Disturbance," Revision 2, address loss of electrical power and degraded power sources. Contrary to the above, as of January 25, 2010, the licensee failed to establish a procedure to address degraded power sources. Specifically, the licensee failed to translate switchyard voltage drop criteria determined in calculation DC-0919 into Procedures ODE-12, MOP05, and 20.300.Grid. Because this violation was of very low
safety significance, and was entered into the licensee's corrective action program as
CARD 10-21791, this violation is being treated as an NCV, consistent with Section VI.A.1
of the NRC Enforcement Policy. (NCV 05000341/2010006-03, Inadequate Procedures for
Controlling Availability of 120kV System Voltage)
Enclosure
17 (4) Failure to include Turbine Building Heating, Ventilation and Air Conditioning Fans in the Scope of the Maintenance Rule Program
Introduction: The inspectors identified a finding of very low safety significance (Green)
with and associated NCV of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for the failure to include the
TBHVAC fans within the scope of the Maintenance Rule program. Failure of all three
fans could cause an increase in steam tunnel temperatures that would lead to a forced
shutdown, i.e., manual scram, in anticipation of a Group 1 isolation (MSIV closure)
resulting in a reactor trip.
Description: As a part of the inspection sample and discussions with the resident inspectors, the inspectors selected the TBHVAC system for review based on the historical events and evaluations of recent failures of the systems exhaust fans. The
inspectors reviewed corrective action program documents, root cause evaluations,
maintenance rule procedures and scoping documents, preventive maintenance procedures, system operating procedures, and system design documents. The TBHVAC system exhaust fans have experienced approximately 10 catastrophic failures since 1990, with an increase in the frequency of failure or periodicity of operation
with degraded fans, over the past ten y
ears from 1999-2010. The TBHVAC system
recently degraded to a point where no exhaust fans were operable and the licensee was forced to take compensatory action to limit and monitor the temperature in the turbine building steam tunnel for any increase, which might have challenged trigger points established in the operational decision making issue (ODMI) plan, which could have spurred the licensee into a forced shutdown in anticipation of a reactor trip. The inspectors reviewed Maintenance Rule (MR) Evaluation 95-010, which provides the basis for not including the TBHVAC system in scope of the program. The licensee stated that the TBHVAC system did not meet any of the requirements in 10 CFR 50.65 to be a MR system. The licensee considered that for non-safety-related systems, structures, or components (SSCs) to be considered important, they must add significant value to the mitigation function of an emergency operating procedure by providing the
total or a significant fraction of the total functional ability required to mitigate core damage or radioactive release where the significance determination was made based on utility specific technical judgment. The licensee provided additional justification for excluding the TBHVAC system from the MR program in MR Program position papers97-006 and 98-023. The inspectors identified that the licensee referenced a modification plan that was never implemented, that would have been credited for alleviating high steam tunnel temperatures. The licensee entered this issue into their corrective actions program for evaluation. The inspectors also identified in the licensee's consideration of the criteria in (b)(2) of
10 CFR 50.65, instead of asking if failure of the SSC would cause a scram or actuation
of a safety-related system, the licensee asked, "would failure of the SSC cause a
safety-related SSC to fail to perform its function"? The inspectors identified that 10 CFR 50.65(b)(2)(iii), "Requirements for Monitoring Maintenance at Nuclear Power Plants," states that non-safety-related SSCs whose failure could cause a reactor scram
or actuation of safety-related systems shall be included in the MR program. The
licensee stated in its basis document, and in more recent ODMIs, that if all three
fans in the TBHVAC system fail, plant shutdown would commence at 193 degrees
Enclosure
18Fahrenheit (°F) and at 195°F the reactor mode switch would be placed in shutdown. At temperatures greater than 200°F, group one isolation could occur, causing a reactor
scram. Analysis: The inspectors determined that the licensee's failure to scope the TBHVAC system into its maintenance rule program is a performance deficiency. The performance deficiency was determined to be more than minor because it was
associated with the Initiating Events cornerstone attribute of Equipment Performance,
and affected the cornerstone objective to limit the likelihood of those events that upset
plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, because the TBHVAC fans were initially not scoped into the Maintenance Rule program, the licensee could not provide reasonable assurance that
the preventive maintenance being performed ensured the system remained capable of
performing its intended function. The finding was also similar to Example 7.d. of
IMC 0612, Appendix E. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 04, and Table 4a for the Transient Initiators Cornerstone.
The inspectors determined that the finding did not contribute to the likelihood that
mitigation equipment or functions would not be available. Therefore, the finding
screened as having very low safety significance (Green). The inspectors determined there was no cross-cutting aspect associated with this finding because the system was originally scoped out during the initial baseline evaluation for Maintenance Rule in June 1995; therefore, was not reflective of current performance.
Enforcement: Title 10 CFR 50.65(b)(2)(iii) "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," states that non-safety-related SSCs whose failure could cause a reactor scram or actuation of a safety-related system shall be scoped in the monitoring program as specified in 10 CFR 50.65(a)(1). Contrary to the above, from June 1995 through January 25, 2010, the licensee failed to adequately scope into the Maintenance Rule program the TBHVAC fans, whose
intended function is to control temperature and building pressure below design limits to
preclude reaching temperatures that could lead to the initiation of manual or automatic reactor trips. Because this violation was of very low safety significance and was entered into the licensee's corrective actions program as CARDs 10-21757, 10-21761, and 10-21777, this violation is being treated as a NCV with Section VI.A.1 of the Enforcement Policy. (NCV 05000341/201006-04, Failure to include Turbine Building
Heating Ventilation and Air Conditioning Fans in the Scope of the Maintenance Rule
Program).
(5) Inadequate Calculation for DC Short Circuit Analysis
Introduction: The inspectors identified a finding of very low safety significance with an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control" for the
licensee's failure to correctly translate cable resistances into dc calculations. The
inspectors noted that the licensee failed to use conservative assumptions, verify the accuracy of design inputs and parameters, and avoid conceptual errors, which led to a decrease in margin in the short circuit calculation.
Enclosure
19 Description: During review of calculation, DC-0214, "Short Circuit Calculation for dc System," the inspectors identified several errors which reduced the overall margin of the dc system. Specifically, the inspectors determined that the licensee did not recognize the actual cable wiring configuration and instead incorrectly calculated the cable resistance for HPCI and RCIC MOVs by taking the individual length of a feed
cable conductor and multiplying it by four. The inspectors determined that this resulted
in overestimating the cable resistance by a factor of 2.285 which resulted in reduction in
the short-circuit current available to the breakers. The inspectors determined that the
incorrect and non-conservative methodology affected the breaker short-circuit rating not only for the individual MOV breakers, but also the main feed breakers for both divisions. In addition to this error, the inspectors also identified that the short circuit calculation used non-conservatively high values for battery inter-cell connection resistance and omitted the battery terminal connection resistance, which again decreased the available
short-circuit current to the breakers. The inspectors identified a third error - using only half of the MOV circuit resistance values -- that was conservative. The inspectors determined that the current configuration was still acceptable; however, future load
additions could result in exceeding the short circuit rating of the main feed breakers
resulting in the potential for a loss of either dc division. In addition to the errors in the short circuit calculation, the inspectors identified that the incorrect methodology for calculating cable resistance was also used in calculations DC-4943, "DC Equipment Operability, DC-5351, "DC Voltage Drop, DC-0213, "Battery
and Charger Sizing," and mechanical calculation 021-014-AWI for computing dc MOV
thrust margins. The inspector determined that the methodology, while still incorrect,
resulted in conservative results for these
calculations. Similarly, the licensee also failed to include the battery inter-cell and terminal connection resistance in calculation DC-0213. The inspectors identified additional errors in the above calculations, which either had minor effects or did not result in a significant loss of margin. These errors
ranged from simple arithmetic issues to failing to select the worst case first minute
battery terminal voltage to listing timing sequences and corresponding voltages that did
not agree with the UFSAR accident sequences. Based on the extent of the issues, and when combined with the errors discovered in the ac electrical calculation DC-0919, as described above, the inspectors determined that there was a concern with the licensee's
design control process in the electrical area. The inspectors noted that all the calculations were revised within the last two years, with calculation DC-4943 having been revised several times without identifying and correcting the incorrect timing
sequences.
Analysis: The inspectors determined that the licensee's failure to incorporate conservative cable resistance values into the dc short circuit calculation was contrary to 10 CFR Part 50, Appendix B, Criterion III, "Design Control," and was a performance
deficiency. The performance deficiency was determined to be more than minor because
the issue was associated with the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, if the errors were not corrected, they could lead to one or
both dc divisions being lost if additional loads were added to the main feed breakers.
The finding was also similar to Example 3.j of IMC 0612, Appendix E.
Enclosure
20The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 04, Table 4a for the Mitigating Systems Cornerstone. The
inspectors answered "No" to each of the questions in Column 2. Therefore, the finding screened as having very low safety-significance (Green). The inspectors concluded that the primary cause of the finding was related to the cross-cutting element of Human Performance, Resources, which requires complete, accurate
and up-to-date design documentation, including calculations and procedures, to assure
nuclear safety. (IMC 0310, Section 06.01.b.(3) H.2(c))
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control" requires, in part, that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or
simplified calculational methods, or by the performance of suitable testing program. Contrary to this requirement, as of January 25, 2010, the licensee's design control measures failed to ensure the adequacy of the design for the RCIC and HPCI MOVs. Specifically, the licensee failed to ensure that the cable resistances used in the short circuit analysis were conservative to ensure adequate current to the main feed breakers.
Because this violation was of very low safety-significance and because the issues were
entered into the licensee's corrective action program, as CARDS 10-20981, 10-20982, 10-20992, 10-21209, 10-21265, 10-21285, 10-21311, 10-21564, 10-21567, and 10-21591, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000341/2010006-05, Inadequate Calculation for DC
Short Circuit Analysis) .4 Operating Experience
a. Inspection Scope
The inspectors reviewed five operating experience issues to ensure that NRC generic concerns had been adequately evaluated and addressed by the licensee. The operating
experience issues listed below were reviewed as part of this inspection: IN 2009-02, "Biodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance"; OE 28932, "Higher than Expected Failure Rate on Initial License Training Exam (Catawba)"; IN 2009-09, "Improper Flow Controller Settings Renders Injection Systems Inoperable and Surveillance Did Not Identify"; IN 2008-02, "Findings Identified During Component Design Bases Inspections";
and GL 2007-001, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Trip."
Enclosure
21 b. Findings (1) Failure to Adequately Evaluate Industry Operating Experience for Applicability to Fermi 2
Introduction: The inspectors identified a finding of very low safety significance for the failure to follow procedures when evaluating industry operating experience for applicability to Fermi 2 Power Plant. Specifically, the inspectors identified three
instances where the licensee did not evaluate and take corrective actions on industry
operating experience that was applicable to the Fermi 2 site. This did not meet the
requirements in licensee's operating experience Procedure MLS04, "Fermi 2
Licensing/Safety Engineering Conduct Manual
for Operating Experience Program,"
Revision 22.
Description: The inspectors identified three examples where the licensee did not follow its internal procedure for review and disposition of industry operating experience.
1. On February 4, 2008, the licensee initiated CARD 08-20775 in response to
industry operating experience regarding "digital feed water control system power supply failures causing automatic reactor scram with complications including RCIC trip while injecting into the reactor vessel." On July 28, 2008, this CARD
was closed out without addressing RCIC trip while injecting into the reactor
vessel due to changes made to the RCIC flow controller tuning parameters.
Specifically, no attempt was made to address the applicability of RCIC flow controller tuning parameters to Fermi 2. 2. On February 21, 2008, the licensee initiated CARD 08-21245 after learning about "changes to flow controller tuning parameters contributed to RCIC pump trip at Perry." This CARD was closed out on April 17, 2008, without clearly reviewing
and determining its applicability to Fermi 2 despite the fact that a note was added
to the CARD that stated "CARD 07-24478 was written to address concerns regarding HPCI/RCIC system tuning based on OE 25305 and OE 15574 and that CARD was closed without action." The licensee issued CARD 09-24985 on
June 25, 2009, in response to NRC Information Notice (IN) 2009-09 "Improper
Flow Controller Settings Renders Injection Systems Inoperable and Surveillance
Did Not Identify" to review for impact to Fermi. This appeared to be the fourth CARD in a series that the licensee initiated on the same issue dealing with the HPCI and RCIC controller tuning parameters. The action plans described in this
CARD appeared to be reasonable in resolving the issue. However, as of
February 26, 2010, this CARD was still open and the issue unresolved. 3. On April 22, 2008, the licensee initiated CARD 08-22662 in response to NRC IN-2008-02 "Findings identified during component design bases inspections." This CARD was closed out on June 17, 2009, without addressing all the issues identified in the NRC IN. Specifically, the IN had described a finding at Quad
Cities related to the Quad Cities safety-related Division 1 and 2 batteries having
non-conservative inter-cell and terminal connection resistance values ( 150 micro-ohms (µ) per connection) prescribed in the Quad Cities TS. Fermi had the same resistance values in its TS and failed to evaluate this finding for
applicability to Fermi. During the inspection, the inspectors brought the issue to
the attention of the licensee and the licensee indicated that they had initiated
CARD 09-27471 on September 25, 2009, in preparation for the CDBI but had not
Enclosure
22resolved the issue. The inspectors performed a quick calculation and determined that the Fermi Division 2 safety-related 130/260 VDC battery would become inoperable due to negative voltage margin if every inter-cell and terminal connection resistances was allowed to reach 150 µ as allowed by the Fermi Technical Specifications. Based on the inspectors' findings, the licensee performed a formal evaluation and took appropriate corrective actions. The licensee also performed an extent of condition
review and identified approximately 30 additional operating experience reviews
performed within the last 2-year period, which did not meet licensee expectations.
Analysis: The inspectors determined that the licensee's failure to follow operating experience Procedure MLS04 in evaluating industry operating experience for applicability to Fermi on several occasions in the recent past was a performance
deficiency warranting a significance evaluation. The finding was more than minor
because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring equipment availability and reliability. Specifically, multiple examples were identified where the licensee failed to ensure that problems identified in industry operating experience were
evaluated for applicability to Fermi and corrective actions implemented. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 04, and Table 4a for the Mitigating Systems Cornerstone. The inspectors answered "No" to each of the questions in Column 2. Therefore, the finding screened as having very low safety significance (Green).
The inspectors concluded that the cause of the finding was related to the cross-cutting element of Problem Identification and Resolution, Operating Experience, because the
licensee failed to systematically collect, evaluate and communicate to affected internal stakeholders in a timely manner relevant internal and external operating experience to
support plat safety (IMC-0310, Section 06.02.b.(1) P.2(a))
Enforcement: The inspectors determined that no violation of regulatory requirements had occurred. The licensee entered these issues in their corrective action program as CARDs 10-20898, 10-20912, and 10-21122. (FIN 0500341/2010006-06, Failure to Adequately Evaluate Industry Operating Experience for Applicability to Fermi 2). .5 Modifications
a. Inspection Scope
The inspectors reviewed 11 permanent plant modifications related to selected
risk-significant components to verify that the design bases, licensing bases, and
performance capability of the components had not been degraded through modifications. The modifications listed in the "List of Documents Reviewed" of this report, were reviewed as part of this inspection effort.
Enclosure
23 b. Findings (1) Inadequate Calculations for Backfit Modifications
Introduction: The inspectors identified a finding very low safety significance with an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for failing to perform adequate calculations to support modifications to the Fermi 2 degraded
voltage protection scheme. The first example involved the failure to analyze motor
starting capability based on voltages afforded by the degraded voltage relay scheme.
The second example involved the failure to perform conservative calculations to show that spurious grid separation would not occur during accidents due to action of the degraded voltage relays.
Description: The NRC previously determined that the design of the Fermi degraded voltage protection scheme had failed to consider a simultaneous LOCA with a degraded voltage, in that the time delay for actuation of the degraded voltage protection exceeded
the time delay assumed in the UFSAR accident analysis (see Inspection Report 05000341/2008-008). The NRC required that the licensee rectify this design oversight. Modification EDP-35621, Revision 0 (dated March 02, 2009), changed the time delay of the degraded voltage relay scheme from a maximum of 46.2 seconds to a maximum of
8.4 seconds, to ensure that if a degraded grid condition occurred concurrent with a
LOCA, the safety-related buses would be disconnected from the degraded offsite power source and ESF loads would have power available from the diesel generators within the time assumed in the accident analysis. However, EDP-35621 also concluded that grid separation and load shedding might occur for large motor starting with initial bus voltage
at the lower end of the range above the secondary voltage relay settings. The "lower
end of the range" referred to was the allowable range of switchyard voltage defined in
UFSAR Section 8.2.2.5.1. Since a design that would allow separation of the offsite power supply if an accident occurred with switchyard voltage within its expected range was not acceptable, EDP-36014, dated September 22, 2009, was issued to replace the
existing ITE 27-D degraded voltage relays with Model ABB 27-N relays. The new relays
would feature a smaller deadband, thereby providing a lower voltage for relay reset, and
more margin for spurious grid separation avoidance. The revised setpoints of the new relays were evaluated in ECR-35621-1, Revision A, dated September 11, 2009, by performing dynamic motor starting studies using ETAP. The inspectors determined that
these motor starting studies were not adequate because they did not address whether
motors had adequate voltage to start based on voltage afforded by the new degraded
voltage relays. In addition, the studies were non-conservative for purposes of showing
that the relays would be able to reset and avoid spurious grid separation if offsite voltage remained within its expected range during accidents.
Motor Starting Voltage
None of the approved modification packages described above evaluated whether safety-related motors would have adequate voltage to start, considering the worst case
voltages that could exist on the safety-related buses during an accident. During transient conditions at the onset of an accident, starting the large ESF motors would cause the degraded voltage relays to drop out, initiating the delay timers. If voltage
recovered above the relay reset setpoint before the time delay expired, then the
safety buses would remain connected to offsite power. Engineering Change Request
Enclosure
24(ECR)-35621-1 revised the nominal reset setpoint for the Division 1 degraded voltage relays from 95 percent X 103 percent = 97.85 percent to 95 percent X 101 percent = 95.95 percent. Calculation DC-0919, Appendix C, established a two percent tolerance for the degraded voltage relays that was also adopted in ECR-35621-1. Applying the
tolerance in the negative direction, the Division 1 relays could reset as low as 95.95
percent X 98 percent = 94.03 percent. This is lower than the minimum voltage that would occur with the existing design, 97.85 percent X 98 percent = 95.89 percent. Because the degraded voltage modifications have not yet been installed in the field, this
issue did not affect current operability.
Spurious Grid Separation
ECR-35621-1 evaluated the time delay and reset setpoints of the new ABB-27N relays scheduled to be installed by EDP-036014 as part of the modifications to comply with
NRC backfit orders relating to degraded voltage concerns. The ECR added
Attachment "O" to Calculation DC-0919. This attachment was a dynamic ETAP motor starting study intended to demonstrate the adequacy of the revised relay reset setpoint and time delays. Because Attachment "O" was a dynamic model, it showed both the
magnitude and duration of the voltage dips and was used in lieu of the separate static
and dynamic models used in the previous version of the calculation. As stated above, ECR-35621-1 revised the nominal reset setpoint for the degraded voltage relays and adopted a two percent tolerance for the degraded voltage relays. Applying the tolerance in the positive direction, a maximum reset voltage was determined as 95.95 percent X 102 percent = 97.87 percent. The Attachment "O" showed that the voltage on Buses 64B and 64C recovered to 97.89 percent within 3.5 seconds following the start of the Core Spray Pumps during an accident, providing
voltage margin of 0.02 percent. The inspectors compared the static motor starting results from calculation DC-0919, Revision F, Attachment "I" to the dynamic
study contained in Attachment "O" from ECR-35621-1. The inspectors noted that the Attachment "I" and Attachment "O" showed
considerably different results. For example, the minimum voltage at the terminals of
RHR Pump "A" during starting in Attachment "O" was 85.48 percent, whereas the voltage shown in Attachment "I" was 82.54 percent. The inspectors determined that the dynamic analysis in Attachment "O" was non-conservative due to incorrect modeling of the SS Transformer No. 64 transformer automatic LTC. Consequently, considering the approximately 3 percent error in the Attachment "O" results versus the calculated reset
margin of 0.02 percent, the inspectors determined that the conclusion in ECR-35621-1
that the new design would prevent spurious grid separation were not justified. Because the degraded voltage modifications have not yet been installed in the field, this issue did not affect current operability.
Analysis: The inspectors determined that the failure to perform adequate calculations to support modifications to the Fermi 2 degraded voltage protection scheme was contrary
to 10 CFR Part 50, Appendix B, Criterion III, "Design Control," and was a performance
deficiency.
Enclosure
25The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems
cornerstone attribute of Design Control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to confirm the adequacy of new degraded voltage relay
setpoints by ensuring motors had adequate voltage to start if safety buses remained
connected to offsite power during a LOCA with degraded voltage. In addition, the
licensee failed to ensure that spurious grid separation would not occur during
accidents due to action of the degraded voltage relays. The finding was also similar to Example 3.j. of IMC 0612, Appendix E. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Attachment 04, and Table 4a for the Mitigating Systems Cornerstone.
The inspectors answered Question 1 positively. Therefore, the finding screened as
having very low safety significance (Green). The inspectors determined the primary cause of this issue was related to Human Performance, Resources, which requires complete, accurate, and up-to-date design documentation, including calculations and procedures, to assure nuclear safety. (IMC 0310, Section 06.01.b.(3) H.2(c))
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or
simplified calculational methods, or by the performance of a suitable testing program. Contrary to the above, as of January 25, 2010, the licensee's design control measures failed to verify the adequacy of design of the safety-related degraded voltage protection
scheme scheduled to be installed during RFO14, in October 2010. Specifically, the inspectors identified that the licensee failed to analyze motor starting voltage requirements, and to ensure that spurious grid separation would not occur in calculations
to support modifications for the degraded voltage protection scheme. Because this violation was of very low safety significance, and was entered into the licensee's corrective action program as CARDs 10-21733 and 10-21792, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000341/2010006-07, Inadequate Calculations for Backfit Modifications) .6 Risk-Significant Operator Actions
a. Inspection Scope
The inspectors performed a margin assessment and detailed review of six risk-
significant, time critical operator actions (six samples). These actions were selected from the licensee's PRA rankings of human action importance based on risk achievement worth values. Where possible, margins were determined by the review of
the design basis and USAR response times and performance times documented by job
performance measures results. For the selected operator actions, the inspectors
performed a detailed review and walk through of associated procedures, including observing the performance of some actions in the station's simulator and in the plant for other actions, with an appropriate plant operator to assess operator knowledge level,
adequacy of procedures, and availability of special equipment where required.
Enclosure
26The following operator actions were reviewed: Action to Locally Operate an RHR Motor Operated Valve; Action to Locally Tie in an Alternate Battery Charger; Action to Locally Cross-Tie Division 1 to Division 2 NIAS Control Air; Action to Align 4160V Maintenance Cross-Tie Breakers 64T/65T to Cross-Tie Division 1 to Division 2 Following a Loss Of Offsite Power and the Failure of Diesel Generators on One Division of ESF Power; Action to Keep MSIV's Open Following a Reactor Scram; and Action to Start the Standby Feedwater Pump to Maintain RPV Water Level.
b. Findings No findings of significance were identified. 4. OTHER ACTIVITIES 4OA2 Identification and Resolution of Problems
.1 Review of Items Entered Into the Corrective Action Program
a. Inspection Scope
The inspectors reviewed a sample of the selected component problems that were identified by the licensee and entered into the corrective action program. The inspectors
reviewed these issues to verify an appropriate threshold for identifying issues and to
evaluate the effectiveness of corrective actions related to design issues. In addition,
corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the corrective action program. The specific corrective action documents that were
sampled and reviewed by the inspectors are listed in the Attachment to this report.
b. Findings No findings of significance were identified. 4OA6 Meeting(s)
.1 Exit Meeting Summary
On February 26, 2010, the inspectors presented the inspection results to Mr. J. Plona
and other members of the licensee staff. On April 26, 2010, the inspectors conducted a
re-exit of the inspection results with Mr. J. Plona, Mr. M. Caragher, and other members
of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Several documents reviewed by the inspectors were considered
proprietary information and were either returned to the licensee or handled in
accordance with NRC policy on proprietary information. ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
1SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT
Licensee J. Plona, Site Vice President
M. Caragher, Nuclear Engineering Director
T. Conner, Plant Manager
K. Howard, Manager, Plant System Engineering
J. Davis, Manager, Nuclear Training
R. Johnson, Manager, Licensing S. Hassoun, Supervisor, Licensing and Compliance R. Salmon, Principal Engineer, Licensing
J. Tigai, Engineering Supervisor, NQA
J. Moyers, Manager, NQA
J. Ellis, Work Management, Manager
G. Strobel, Operations Manager W. Meath, Operations Department
J. Dudlets, Supervisor, PSE, Electrical/I and C
K. Lawson, Principal Engineer, PSE
B. Sanders, PSE Mechanical Engineering B. Waybright, PSE Electrical/I and C P. Temple, PSE Mechanical Civil
J. Korte, Manager, Nuclear Strategy
Nuclear Regulatory Commission
M. Morris, Senior Resident Inspector
J. Benjamin, EB2 Acting Branch Chief, RIII F. Tran, Projects Inspector, RIII LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
NCV Inadequate Calculations for Availability of 120kV System
Offsite Power 05000341/2010006-02
NCV Inadequate Motor Starting Voltage Calculations05000341/2010006-03
NCV Inadequate Procedures for C
ontrolling Availability of 120kV System Voltage 05000341/2010006-04
NCV Failure to include Turbine Building Heating Ventilation and Air Conditioning Fans in the Scope of the Maintenance Rule
Program.05000341/2010006-05
NCV Adequate Calculation for DC Short Circuit Analysis05000341/2010006-06
FIN Failure to Adequately Evaluate Industry Operating
Experience for Applicability to Fermi 2 05000341/2010006-07
NCV Inadequate Calculations for Backfit Modifications
Attachment
2LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report. CALCULATIONS
Number Description or Title
Revision DC-0106 Vol. 1 Control Valve Sizing and Selection RHR, RHRSW, EESW, & DGSW Systems
D DC-0213 Sizing of 130/260 V Batteries
U DC-0214 Short Circuit Calculation For DC System
H DC-0230 Vol. 1 Core Spray System Design Calculations
G DC-0559 Vol. 1 Volume of Reservoir - RHR Complex
C DC-0835 System Voltage Study (superseded)
E DC-0919 Undervoltage Relay Setpoints
F DC-2712 Vol. 1 Specifications of Motor Operated Valve Stroke Times X DC-3141 Vol.1A
Piping Stress Report
04/14/86 DC-4388 Protective Relay Settings for 13.2KV 4.16KV and 480V
Auxiliary Equipment
G DC-4943 DC Equipment Operability
O DC-5036 Vol. 1 Maximum Differential Pressure for MOVs E1150-F068A &
E1150-F068B
0 DC-5041 Maximum Expected Differential Pressure for Valves
E2150F004A and E2150F004B
A DC-5079 Vol. 1 LPCI and CS Pump Acceptance Criteria and LOCA Input
Verification
D DC-5084 Vol. 1 Seismic Review of Hoist Chains in Safety Related Buildings
A DC-5111 RHR and CS Pump Motor Overcurrent Relay Time Current
Curve A DC-5264 Operability Evaluation of Electrical Equipment During System Transient due to LPCI & LPCS Initiation Following DBA-LOCA
with Degraded Grid (canceled)
A DC-5351 DC Control Voltage Calculation for Division 1
G DC-5405 Vol. 1 Third Party Review of Thrust Capacities of Wm. Powell Co. MOVs (Report No. 455597)
G DC-5424 Vol. 1 Ventilation Air Quantity Required for RHR Complex Rooms
C DC-5489 Vol. 1 Ventilation Air Quality for Diesel Generator Room 11
A DC-5719 Vol. 1 Minimum Required Target Thrust (MRTT) for Generic Letter 89-
10 Gate, Globe, and Quarter-Turn Valves (torque)
P DC-5894 Vol. 1 RHR Reservoir Replenishment Requirements
A DC-5945 Vol. 1 Design Basis System Parameters for AOVs E11F400A, E11F400B, E11F400C and E11F400D
A
Attachment
3 DC-5986 AOV Stem Force Requirement and Actuator Capability Calculation for E11F400A, E11400B, E11400C, E11400D
A DC-6186 Electrical Loading Short Circuit Current and Running Voltages for 4.15kV 480 Volt and 120 Volt System using ETAP Power Station (superseded)
C DC-6249 Vol. 1 Service Water Systems Calibrated Hydraulic Model
0 DC-6258 Division I and Division II Switchgear Rooms Components
Operability Evaluation at 122°F (50°C)
--- DC-6309 Vol. 1 Design Basis of EDG Fuel Oil and Day Tank Level Requirements and Setpoints
0 DC-6348 QL1 MOV Thermal Overload Heater Sizing
O DC-6397 Vol. 1 Calculation of Safety Related GL 89-10/96-05 and non-GL 89-10/ 96-05 ACMOV Motor Terminal Voltages
0 DE-FR-041 Seismic and Weak Link Analysis of 3" Fisher Air Operated
Valves 1 DSN 455597 Reevaluation of Thrust Capacities for Powell Valves
09/21/94 DSN 729190 Survivable Thrust Capacities for Powell Valves
08/24/94 021-014-AWI DC MOV Thrust Margins
1 CORRECTIVE ACTION PROGRAM DOCUMENTS GENERATED AS A RESULT OF THE
INSPECTION
Number Description or Title
Date 10 20695 Potential Safety Concern: Loose Cabinet Screws Unable to be
Tightened
01/27/10 10-20700 NRC Concern: DFP Tach Generator Wiring
01/27/10 10-20716 4160V Breaker Not Properly Staged After Being Racked Out.
01/27/10 10-20720 NRC CDBI Inspection Identified Corrosion on RHRSW Pump 'A'
Pedestal
01/27/10 10-20723 2010 CDBI Item: Evaluate the Effect of P43R403C Reading Below 0
psid 01/27/10 10-20746 4160V Breaker Not Properly Staged After Being Racked Out
01/27/10 10-20747 2010 CDBI Div I/II Switchgear Room Cabinets Have Loose Knob
Screws 01/28/10 10-20748 CDBI Identified Canceled DC-5264 May Have To Be Reinstated
01/28/10 10-20764 2010 CDBI issue - Catch Hose Not Tracked In Accordance With
RWWI-02 01/28/10 10-20771 DC-4943 Vol I Issued with TSR-Config Instead of TSR-ABN
01/29/10 10-20776 2010 CDBI, Enhancements for 23.309, 260/130V DC ELECTRICAL
SYSTEM 01/29/10 10-20784 2010 CDBI - Missing Continuation Arrow on Dwg. M-2135-1
01/29/10 10-20787 2010 CDBI - Water under Diesel Fire Pump Battery Box
01/29/10 10-20793 2010 CDBI - Revise Hoist And Rigging Procedures
01/29/10 10-20819 CDBI Question on Fuel Clad Temp
01/29/10
Attachment
4CORRECTIVE ACTION PROGRAM DOCUMENTS GENERATED AS A RESULT OF THE
INSPECTION
Number Description or Title
Date 10-20823 CDBI 2010 Concern Revise DC-0919 to Include Correct LTC volts per
Tap 01/29/10 10-20861 2010 CDBI - Minor Changes Required to Operator Action HERFACHRPLNT
02/01/10 10-20888 2010 CDBI Revise DC-6397 to Include Voltage Bounding Condition Discussion
02/02/10 10-20894 2010 CDBI DC-0919 Requires Revision To Properly Verify Design
Inputs 02/02/10 10-20898 2010 CDBI, Operating Experience Review
02/02/10 10-20912 Reevaluate INPO SEN 271, Digital
Feedwater Control System Power
Supply Failures Cause Automatic Reactor Scram with Complications,
for Impact to Fermi
02/02/10 10-20928 Evaluate Improved Trending Method for Key Calculation
Reviews/Design Calc Project
02/02/10 10-20981 2010 CDBI - Design Calculation Improvements for DC-4943 "DC
Equipment Operability
02/04/10 10-20982 2010 CDBI DC-0213 Improvement
02/04/10 10-20992 2010 CDBI RFI No -G027-4 (CDBI -0127) NRC Inspection Question
Regarding Temperature Requirement for DC-4943
02/04/10 10-21038 2010 CDBI Procedure Changes associated with 64 Xfmr Load Tap
Changer Manual Ops
02/05/10 10-21101 2010 CDBI ETAP Calculation Process Question
02/08/10 10-21122 2010 CDBI Inspection Item - Missed Opportunity during 2009 CDBI
Self-Assessment
02/08/10 10-21209 2010 CDBI - Discrepancy Found in Design Calculation DC-4943 "DC
Equipment Operability
02/11/10 10-21212 2010 CDBI - Review Manipulation Timing Analysis of Operator Action
HERFRMOVPLNT
02/10/10 10-21256 2010 CDBI Inspection Item - Error Found in RID-78612
02/11/10 10-21265 2010 CDBI DC-4943 Needs Revision
02/11/10 10-21283 2010 CDBI Questions On The Voltage Boundaries in DC-0919 Volume
1 Revision F
02/11/10 10-21285 2010 CDBI - Discrepancy Found During Document Review
02/11/10 10-21287 2010 CDBI - Installation of Washers on 2PA Found Reversed
02/11/10 10-21311 2010 CDBI DC-0214 Validation of Battery Resistance
02/12/10 10-21317 CDBI 2010 - Data Recorded in ICSS is Inconsistent with Loop
Instructions
02/12/10 10-21320 2010 CDBI - Design Calc Discrepancy
02/12/10 10-21332 Enhancement to Various IST-Related Surveillance Procedures
02/12/10 10-21564 Improper Output Torque Capability Used for MOV E4150F012 Margin
Determination
02/19/10
Attachment
5CORRECTIVE ACTION PROGRAM DOCUMENTS GENERATED AS A RESULT OF THE
INSPECTION
Number Description or Title
Date 10-21567 2010 CDBI Inspection - Design Specification 3071-128-EP
Discrepancy
02/19/10 10-21591 2010 CDBI - Found Minor Inconsistencies in DC-0214
02/22/10 10-21733 2010 CDBI DC-0919 LTC and Motor Starting
02/25/10 10-21749 2010 CDBI, Tornado Action Enhancement Associated with RHR Complex HVAC
02/25/10 10-21757 CDBI 2010: Evaluate Previous Maintenance Rule Scoping of U4100
System 02/25/10 10-21761 Re-Evaluate the TBHVAC System Exclusion From the Maintenance
Rule scope
02/25/10 10-21777 2010 CDBI - Re-evaluate PM Classification and PM Work for TBHVAC
Fans 02/25/10 10-21791 2010 CDBI Voltage Drop Limits Not Used at Fermi to Assess 120 Kv
Offsite Power
02/26/10 10-21792 2010 CDBI - EDP 35621 Backfit Mod Issue
02/26/10 10-21920 2010 CDBI NRC Questioned Completeness of EFA-R14-10-004
03/03/10 10-21332 Enhancement to Various IST Related Procedures
02/12/10 10-22135 NRC CDBI Item -- Completeness and Accuracy of Information
Provided to the NRC
03/12/10 CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title
Date 98-13970 Ground Detected on 2PC3-14 05/15/98 99-11707 RHRSW Pump Discharge Pressure Gauges No Longer Used in
Surveillances
02/08/9904-01842 Ground Detected on BOP Battery System 11/14/0404-23862 CTG 11-2 through CTG 11-4 Auto-Started with NO Operator Action 08/25/04 05-10283 Procedure Enhancement for 23.412
01/13/05 05-26492 Design Calculation for RHR Complex Depressurization Is Not
Available
11/17/05 06-20446 AFCC 3 Relay OTH Failed During Testing; Event R295060100
01/30/06 06-20534 EDG 12 Trip On Overvoltage When Exciter Reset During Pmt Test
Sequence 02/02/06 06-20574 EDG 12 Output Breaker Fails to Open
02/03/06 06-20584 After AVR Replacement, Generator Voltage Could Not be Adjusted Above ~3000V From Local Control Panel
02/05/0607-10001 NQA Surveillance 06-0125, Fermi Vulnerability to Underground Cable Failures 01/05/0707-10001-01 Complete Effectiveness Review 10/13/08
Attachment
6CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title
Date 07-20860 Information Notice 2007-05 Vertical Deep Draft Pump Shaft and
Coupling Failures
02/13/07 07-22460 Minimum CST Level for Pump Starting Does Not Protect Minimum Submergence Requirements for CS and SBFW Pumps
05/04/07 07-22838 WANO/IMPO AFI CM.3-1 Calculation Errors
05/22/07 07-23630 UFSAR Anti-Vortex Methodology Non-Conservative
06/11/09 07-23998 CDBI RAI on Two RHR Safety Evaluations
09/23/09 07-27685 Inadequate EDP
11/29/07 08-20544 Test 4.16KV Unshielded RHR Div. 1 Anaconda Cables in RF13
01/29/08 08-22662 NRC Information Notice, IN-2008-02 Findings Identified During Component Design Bases Inspections
04/22/08 08-25007 DC-5003 Enhancements Identified by PSE Independent Challenge
Board 08/04/08 08-27182 Declining Trend in RHRSW Pump A Hydraulic Performance
10/29/08 08-27295 RCIC Hydraulic Calculation Quality Review
11/03/08 08-28060 DC-0230 Vol. 1, Core Spray System Key Calculation Review
Results 12/03/08 08-28393 WGI Review of Calculation DC-2913, Vol. 1, Rev. N
12/15/08 09-20006 WGI Review Of Design Calculation DC-4943, Vol. I, Revision N
01/02/09 09-21353 Investigate Two NRC Issues Related to PI&R Cross Cutting Aspect
of Corrective Action
03/04/09 09-21669 Evaluate NRC IN 2009-02
03/18/09 09-22161 MOV Actuator Very Difficult To Get Into Manual Operation
04/02/09 09-24210 Trip of N. TBHVAC Exhaust Fan Root Cause Team Report
07/10/09 09-24325 Operations Training Review of OE28932 - Initial License Exam High Failure Rate
06/04/09 09-24985 Improper Flow Controller Settings Renders Injection Systems Inoperable and Surveillance Did Not Identify
06/29/09 09-26366 Key Calc Review of DC-5489 Vol. 1, Ventilation Air Quality for
EDGs 08/19/09 09-27471 Cell To Cell and Terminal Connection Resistance May Need To Be Addressed In DC-0213
09/25/09 09-28748 Underground Cable Manholes Sump Pump Monitoring 11/11/09 09-28894 EDG 12 Output Breaker Fuse Clips, RM, Loose
11/16/09 09-29829 While Performing 24.307.15 for EDG 12 Observed Lowering Load With No Operator Action
12/23/09 09-29830 EDG 12 Load Not Stable (Decreased Without Demand) During
Surveillance Test
12/24/09 09-29843 Failed PMT - EDG 12 Load Not Stable After Replacement of Digital
Reference Unit
12/25/09 09-29856 Catastrophic Failure of the North Turbine HVAC Exhaust Fan.
Repeat Occurrence
12/27/09
Attachment
7CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title
Date 10-20147 Battery Operated Emergency Light Fails Discharge Test
01/07/10 10-20432 High Viscosity in EDG 13 Starting Air Compressor
01/19/10 10-20519 Cracked Battery Fill Caps
01/21/10 10-20539 Green Trickle Charge Light is Burned out
01/22/10 10-21657 Center TBHVAC Exhaust Fan Nose Cone Failure
02/23/10 DRAWINGS
Number Description or Title
Revision E21-3144-G33 Support Drawing
B 6C721N-2273 RHR Complex Framing Plan EL 590'-0" - Center South Area
AC 6C721N-2274 RHR Complex Framing Plan EL 590'-0" - Center North Area
AF 6C721N-2277 RHR Complex Framing Plan EL 617'-0" - Center South Area
AA 6C721N-2296 RHR Complex Framing Area South Area
0 6I721-2231-01 S/D RCIC Turbine Gland Seal Condenser and Vacuum Pumps
U 6I721-2231-03 S/D RCIC Steam Line Inboard Isolation Valve and Trip and
Throttle Valve
Y 6I721-2231-04 S/D RCIC Steam Line Outboard Isolation Valve and
Condenser Tank Pump Suction Valve
W 6I721-2231-05 S/D RCIC Pump Discharge Valves to Feed water Header X 6I721-2231-06 S/D RCIC suppression Pool Isolation Valves
S 6I721-2231-07 S/D RCIC Valves E51F045 and F046
AA 6I721-2231-08 S/D RCIC Minimum Flow Bypass and Test Valves
AA 6I721-2231-09 S/D RCIC Vacuum Breaker Isolation Valves F062 and F084
T 6I721-2231-10 S/D RCIC Turbine Exhaust and Vacuum Pump Discharge
Valves F001 and F002
J 6I721-2231-11 S/D RCIC Steam Inlet Bypass Valve F095
C 6I721-2421-01 Schematic Diagram Reactor Building Closed Cooling Water Pump North P4200C001
Schematic Diagram Emergency Equipment Cooling Water System Pump "A" P4400C001A
R 6I721-2571-01 One Line Synchronizing Diagram 4160V System Service and
EDG Breakers
E 6I721-2571-2B One Line Diagram 4160V Bus and Line Potential Connecting
Division 1
E 6I721-2572-13 Schematic Diagram 4160V ESS Bus 64C Pos "C8"
P 6I721-2572-14 Schematic Diagram 4160V ESS Bus 64C Pos "C9"
P 6I721-2572-15 Schematic Diagram 4160V ESS Bus "64C" -Pos "C6"
S 6I721-2572-16 Schematic Diagram 4160V ESS Bus 64C Pos "C11"
H 6I721-2572-28 Schematic Diagram 4160V ESS Buses 64B & 64C - Load
Shedding Strings
R
Attachment
8DRAWINGS Number Description or Title
Revision 6I721-2572-29
Schematic Diagram 4160V ESS Buses 64E and 64F - Load
Shedding Strings
M 6I721-2573-07 Schematic Diagram 480V ESS Bus 72C Pos "1B" and "1C"
K 6I721-2573-08 Schematic Diagram 480V ESS Bus 72C Pos "2A" and "2B"
J 6I721-2578-07 Relay and Metering Diagram 4160V ESS Bus 64C
N 6I721-2578-19 Relay and Metering Diagram 480V ESS Bus 72EA EB B, C, and S L 6I721-2581-02 Schematic Diagram - Cooling Circuit 4160V SS Transformer
No. 64 B 6I721-2581-03 Schematic Diagram - Cooling Circuit 4160V SS Transformer
No. 64 D 6I721-2581-04 Schematic Diagram - Cooling Circuit 4160V SS Transformer
No. 64 B 6I721-2581-05 Schematic Diagram - Annunciator Circuit 4160V SS
Transformer No. 64
F 6I721-2611-35 Schematic Diagram Main Control Room A/C Chiller
Compressor T4100B009 Div. 1
Z 6I721-2641-01 Schematic Diagram Standby Gas Treatment Cont Panel 1 and 2 480V Bus 72C Pos 4D and ESS Bus 72F Pos 3A
J 6I721N-2572-11 Schematic Diagram 4160V ESS Diesel Bus 12EB Pos EB3 X 6I721N-2572-12 Schematic Diagram 4160V ESS Diesel Bus 12EB Pos EB5
Relay and Metering Diagram Diesel Generator No. 12
Y 6M721-2015 Station and Control Air
CB 6M721-2034 Core Spray System - CSS Reactor Building
AN 6M721-2045 Reactor Core Isolation Cooling (RCIC) System Barometric
Condenser
AQ 6M721-2083 Residual Heat Removal System Division 2
BL 6M721-2084 Residual Heat Removal System Division 1
BF 6M721-2135-01 Diagram Fire Protection System
AY 6M721-2135-02 Diagram Fire Protection System
AY 6M721-2656 Ventilation - Duct Layout 3
rd FL N 6M721-3144-1 North Core Spray Pump Discharge to RPV Penetration
V 6M721-3144-2 Hanger Piping Isometric North Core Spray Pump Discharge to RPV Penetration Reactor Building
L 6M721-5357 Emergency Equipment Cooling Water System Division II
BJ 6M721-5728-1
TBCCW System 2
nd and 3 rd AH 6M721-5734 Emergency Diesel Generator System Functional Operating
Sketch BB 6M721N-2052 RHR Service Water System Division 1 RHR Complex
AD 6M721N-2053 RHR Service Water System Division 2 RHR Complex
One Line Diagram Plant 4160V and 480V System Service Unit
2 AK 6SD721-2500-02
One Line Diagram 13.8kV
Attachment
9DRAWINGS Number Description or Title
Revision 6SD721-2500-03
One Line Diagram 4160V System Service Buses 64B 64C
One Line Diagram 4160V System Service Buses No. 64E 65F
65G - Reactor Bldg. Unit No. 2
One Line Diagram 4160V System Service Buses 64A 64D 64L
One Line Diagram 4160V Diesel Gen. Buses No. 11EA 12EB
13EC and 14ED Diesel Generator Building
O 6SD721-2500-09 Phasing Diagram Main Power System
N 6SD721-2510-01 One Line Diagram 480v E.S.S. Bus No. 72B 72C 72E and 72F
One Line Diagram Diesel Gen Buses No. 72EA 72EB T2EC
72ED M 6SD721-2530-10 One Line Diagram 260/130V ESS Dual Battery 2PA Distribution Division 1
AK MISCELLANEOUS
Number Description or Title
Date or Revision Fermi Grid Adequacy Study
12/08 & 11/09 Black & Veatch Project 27022 Fermi 2 TBHVAC Fan Test Study
06/16/95 CI-7281 RF-13 Cable Monitoring Program Summary
10/23/09 DBD E11-XX Residual Heat Removal Service Water System
B DBD E21-00 Core Spray System
C DBD R30-00 Emergency Diesel Generator
Piping Stress Analysis Report
06/14/78 E11-XX Residual Heat Removal Service Water System
B E21-00 Core Spray System
C GEK-5651A
Load-Tap-Changing
Equipment
A GEK-6143C
Automatic Static Control for Load-Tap-Changer
Equipment, Revision
C HEOFMSOVOM1 Operator Fails To Keep MSIV's Open Following Scram
12/06/09 HEOFSBFWHESF1 Operator Fails To Start SBFW System
12/06/09 HERFACHRPLNT Operator Fails To Tie In Alternate Charger
12/06/09 HERFCACSHEOLB Failure To Manually Crosstie Div. 1 And 2 Control Air
12/06/09 HERFRMOVPLNT Failure To Manually Operate An RHR MOV Locally
12/06/09 HERFXMXTPLNT4H Operator Fails To Align 4160V Maint X-Tie 65T/64T
Within 4 Hours
12/06/09 MES60 Electrical Cable Monitoring Program
1 NQA Report 09-11 NQA Quarterly Report October - December 2009
01/27/10 NRC-07-0017 Detroit Edison's 90-Day Response to Generic Letter 2007-01 05/04/07
Attachment
10MISCELLANEOUS
Number Description or Title
Date or Revision ODE-15 Compensatory Monitoring Plan - TBHVAC Exhaust Fan
Differential Pressure
02/03/10 P.O. 1E87829 VertiLine Fire Pump Performance and Construction Data
Sheet 09/21/10 R1200S002
Maintenance Strategy
01/26/10 SE 95-0017 LCR 95-049-UFS
0 Spec. 3037-A Horizontal and Vertical A.C. Electric Motors 2300 Volts and Above for Power Plant Duty Standard Specification
Addendum C Spec. 3067
460 Volt AC Motors Power Plant Service
03/68 TDDATA Nuclear Plant Operating Agreement
4 TE-E11-08-078 Removal of RHR Complex Pump Room Plugs under
A TE-U41-09-049 Evaluate Operation on the Center TBHVAC Exhaust Fan
with a Missing Hub Nose Cone
0 TM-09-0030 Nuclear Engineering Plant Indicators - November 2009
12/17/09 TMPE-09-0227 2009 Component Design Bases Inspection (CDBI) Self-Assessment Final Report
11/24/09 VME8-11 General Electric Inductrol Type AIRT Voltage Regulators
F 95-010 Maintenance Rule Program Position Paper
0 97-006 Maintenance Rule Program Position Paper
0 MODIFICATIONS
Number Description or Title
Date or Revision ECR-35621-1 Revision of Calculation DC-0919 Vol I to Reflect Minimum And Maximum Error Evaluation and Motor Starting Transient Study
A EDP 4921 Removal of Clutch Trippers from Fifteen Limitorque Valve
Motor Operators
A EDP 30405 Replacement of Division 1, 130/260 VDC batteries
12/10/99 ERE 32781 Replacement Pump Column Assemblies and Stuffing Boxes for Three RHR Complex Pumps
B EDP-35621 DC-0919 Vol. 1 Under-Voltage Relay Setpoints
0 EDP-36014 DC-0919 Vol. 1 Under-Voltage Relay Setpoints
0 EDP-35607 Replace EDG Feeder Cables to 4.16kV Buses
B RID-78612 Replace Relay E21A-K16C in panel H11P626
0 TSR-35286 Incorporate Revisions into DC-4388, Vol. I and DC-0919 Vol I
0 TSR-35664 Clarify HPCI and RCIC Pump Suction and Discharge Design
Temperature
A TSR-35792
Revise HPCI/RCIC DBD's
A
Attachment
11MODIFICATIONS
Number Description or Title
Date or Revision TSR-36184 Suggested Improvement for DC-0106 Vol. 1 RHRSWS Minimum Flow Analysis
0 TSR-36383 Update of DC-5424 for CARD 09-22041
0 OPERABILITY EVALUATIONS
Number Description or Title
Date EFA-R14-10-002 Analysis to determine Electrical Equipment Functionality During a Transient due to LPCI and LPCS Initiation for a DBA-LOCA
with Degraded Grid (canceled)
A EFA-R14-10-004 Analysis to Determine Electrical Equipment Functionality of
4160 Volt 480 Volt Motors and SS64 LTC
A EFA-R16-07-003 Analysis of the Fermi 5kV 3/C 500 MCM Copper Non-Shielded Cables to Perform Their Safety-Related Functions While
Operating In Continuously Wetted Environment.
A EFA-R32-10-003 Engineering Functional Analysis To Determine Battery Functionality Due To Incomplete Accounting Of Inter-Cell
Resistance In The DC-0213 Vol. 1 Calculation For Terminal
Voltage 0
PROCEDURES
Number Description or Title
Revision ARP 3D18 IPCS Monitored Inputs Abnormal
25 ARP 7D3 Div I RHR Reservoir Level Abnormal
15 ARP 7D4 Div II RHR Reservoir Level Abnormal
16 ARP 9D22 Div I Bus Voltage Low
15 ARP 10D43
Div II Bus Voltage Low
14 FIP-OP1-04 Equipment Labeling and Signs
5 MES02 Design Configuration Management
19 MES06 Preparation and Control of Design Basis Documents
6 MES15 Design Calculations
26 MGA03 Procedure Use and Adherence
20 MLS04 Fermi 2 Licensing/Safety Engineering Conduct Manual for
Operating Experience Program
22 MOP App B Plant Labeling Guidelines
1 MOP03 Operations Conduct Manual Chapter 3 - Policies and Practices
26 MOP05 Control of Equipment
30 MOP17 Plant Labeling
4 MMA08 Scaffolding
13 MMR03 Maintenance Rule Conduct Manual
1
Attachment
12 PROCEDURES
Number Description or Title
Revision MMR10 Maintenance Rule Conduct Manual Monitoring
7 MMR App C
Maintenance Rule Scoping Summary Report
2 MQA11 Fermi 2 Quality Assurance Conduct Manual for Condition Assessment Resolution Document
29 ODE-2 Operations Department Expectation Operations Conduct
22 ODE-12 Operations Department Expectations
18 ODMI-09-006A
South TBHVAC Exhaust Fan
08/28/09 ODMI-10-001
TBHVAC System Reliability
02/11/10 PEP 47.306.01
Signature Analysis of Motor-Operated Valves
28 20.300.GRID Grid Disturbance
2 20.300.65E
Att. 1, Bus 65E De-Energized Loads - MCR
4 23.106 Control Rod Drive Hydraulic System
95 23.127 Reactor Building Closed Cooling Water / Emergency Equipment
Cooling Water System
118 23.129 Station and Control Air System
92 23.138.01
Reactor Recirculation System
101 23.138.02 Operation of Recirculation System Motor Generator Set Fan Coil
Units 17 23.203 Core Spray System
42 23.208 RHR Complex Service Water Systems
97 23.307 Emergency Diesel Generator System
108 23.308 120V AC Instrument and Control Power System
61 23.309 260/130V DC Electrical System
56 23.310 48/24V DC Electrical System
25 23.316 RPS 120V AC and RPS MG Sets
51 23.320 Balance of Plant Auxiliary Electrical Distribution System
46 23.321 Engineered Safety Features Auxiliary Electrical Distribution
System 46 - 48 23.412 Turbine Building Heating, Ventilation, and Air Conditioning
System 50 23.413 Control Center HVAC
83 23.414 Steam Tunnel Cooling
17 23.420 RHR Complex Heating and Ventilation
33 23.426 Reactor Building Heating Ventilation Air Conditioning
54 23.707 Reactor Water Cleanup
126 23.708 Fuel Pool Cooling and Cleanup System
68 24.206.01 RCIC System Pump and Valve Operability Test
69 35.LIM.003 Limitorque SMB-0 Through SMB-4 and 4T Operator -
Maintenance
35 35.301.001 4160V Switchgear
34 35.304.006
ITE Circuit Breaker Types 5HK250 and 5HK350 General Maintenance and Inspections
22
Attachment
13 PROCEDURES
Number Description or Title
Revision 35.304.010 Refurbishing 5HK Air Circuit Breakers
13 35.306.001
480 Volt Switchgear Breaker and Relay Control Testing
37 35.306.005 MCC Bus and Compartment General Inspection and
Maintenance
30 35.306.006
Motor Operated Valve Setup Verification
35 35.306.012 Stroke Trace Recording of Motor Operated Valves
8 35.306.020 Motor Operated Valve Mini Periodic Inspection
4 35.318.014 Medium Voltage Switchgear Breaker and Relay Control
35 42.302.07 Cal and Functional Test of Div 1 4160 V Bus 64B Undervoltage
Relays 33 42.302.08 Cal and Functional Test of Div 1 4160 V Bus 64C Undervoltage
Relays 34 42.302.09 Cal and Functional Test of Div 2 4160 V Bus 65E Undervoltage
Relays 32 42.302.10 Cal and Functional Test of Div 2 4160 V Bus 65F Undervoltage
Relays 32 42.309.02 Division 1/2 Quarterly 130/260 VDC Battery Check
36 47.000.20 Diagnostic Testing of Medium Voltage Cables
2 SURVEILLANCES (COMPLETED)
Number Description or Title
Date or Revision 42.309.02 Division 1/2 Quarterly 130/260 VDC Battery Check
12/28/09 42.309.05 Division 1 (5 year) 130/260 VDC Battery Check
04/06/06 42.309.03
Division 1 18 month 130/260 VDC Battery Check
04/07/09 24.203.02 Division 1 CSS Pump and Valve Operability, and Automatic
Actuation
48 24.203.03 Division 2 CSS Pump and Valve Operability, and Automatic
Actuation
50 24.205.05 Division 1 RHRSW Pump and Valve Operability Test
47 24.205.06 Division 2 RHRSW Pump and Valve Operability Test
46 WORK ORDERS/WORK REQUESTS
Number Description or Title
Date or Revision Double Test Report
04/04/06 A839050100 Perform Mini Periodic MOV Inspection and MPM Stroke Test
03/13/05 E581961116 Inspect Lube and Test Motor Op Valve, Test, Associated
Feeder Position
02/02/00
Attachment
14WORK ORDERS/WORK REQUESTS
Number Description or Title
Date or Revision WO R05070100 Inspect, Clean, Megger Bus 64C and Calibrate Current Indicator
04/06/09 WO 26926949 Perform Mini Periodic MOV Inspection And VPM Stroke Test
02/12/08 WO 27035002 Perform 24.203.02 Sec-5.1 CSS Pump and Valve Operability
Test 12/23/08 WO 27067666 Perform 24.203.02 Sec-5.1 CSS Pump and Valve Operability
Test 04/11/09 WO 27303748 Perform 24.203.02 Sec-5.1 Division 1 CSS Pump and Valve
Operability Test
06/23/09 WR E200070100 Perform MOV Thrust (Viper) Testing Per GL 96-05 Program
09/09/07 WRR371940708 Inspect 72C-2A for Cleanliness Damage and Megger Bus
11/24/04 WRR517070100 Inspect and Test 480V Unit Substation
11/19/04 WRZ325100100 PM Inspect, Clean, Test and Functionally Check SS Xfmr No. 64 and its Components
04/12/06
Attachment
15 LIST OF ACRONYMS USED AC Alternating Current ACE Apparent Cause Evaluation ADAMS Agencywide Document Access Management System CAP Corrective Action Program CARD Condition Assessment and Resolution Document
CDBI Component Design Bases Inspection
CFR Code of Federal Regulations
DC Direct Current ECR Engineering Change Request EDG Emergency Diesel Generator
EECW Emergency Equipment Cooling Water
EFA Engineering Functional Analysis
HPCI High Pressure Cooling Injection IN Information Notice IP Inspection Procedure IST Inservice Testing kV Kilovolt LCO Limiting Conditions of Operations LOCA Loss of Coolant Accident LOOP Loss of Off-site Power
LTC Load Tap Changer
NCV Non-Cited Violation
NPP Nuclear Power Plant NRC
ODE Operations Department Expectation ODMI Operational Decision Making Issue PM Preventative Maintenance
PMT Post Maintenance Test
RCIC Reactor Core Isolation Cooling SBO Station Blackout SDP Significance Determination Process
SS System Service
SSC Systems, Structures, and Components
TBHVAC Turbine Building Heating Ventilation and Air Conditioning
TS Technical Specification TSR Technical Service Request TSO Transmission System Operator UFSAR Updated Final Safety Analysis Report URI Unresolved Item
Vac Volts Alternating Current Vdc Volts Direct Current WO Work Order
WR Work Request
Attachment
16 Bob, Following the referenced evaluation of EFA-R14-10-004 Revision A by the CDBI team, I am forwarding a question and a comment. Please advise CDBI Lead, Zelig Falevits, and the Residents of your reply.
Thx.
Bob Jones
Resident Inspector
APPENDIX
Ref: Evaluation of EFA-R14-10-004 Revision A, George Skinner
QUESTION Section 4.1 of Revision 0 of the EFA addressed the implementation of administrative controls to ensure that the relays remain within the values evaluated in the EFA, in lieu of the criteria in the current surveillance procedures. Inexplicitly, this provision has been removed from Revision A of the EFA. Similarly, neither Revision 0 nor Revision A lists the requirement to implement alternate criteria as a compensatory action in Section 5.0 of the EFA. In order to establish reasonable assurance of continued operability of the offsite power sources, the EFA needs to
address what measures are being implemented to assure that the relays will not drift above their
new limits. This affects the conclusion of the finding on Offsite Power Calculations.
COMMENT
Attachment 7 compared 460V motor protective device trip times with motor start times. The
attachment referred to the ETAP static motor starting analysis for motor start durations but
these values were artificial since they were manually entered based on assumed values described in Section 3.1.1, not calculated based on a dynamic analysis. The dynamic ETAP case in Attachment 17 could not be used to determine start durations because it only modeled
the 4kV RHR and Core Spray pumps starting and did not model 460V motors starting. Start
durations for 460V motors were affected by the starting durations of the RHR and CS motors,
but these may also be non-conservative, as described in the next item. The margins for
spurious trip avoidance listed in Attachment 8 were small for some motors. (Motor T4100C041 showed negative margin but this was determined to be a typographical error.) Consequently, it
was not clear that 460V motor would accelerate without activating their protective devices. This item affects the conclusion of the finding on Motor Starting Voltage Calculations. Affected
motors are listed in Attachment 8 of the EFA.
J. Davis -2- In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide
Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ V. Patricia Lougheed, Acting Chief
Engineering Branch 2
Division of Reactor Safety Docket No. 50-341 License No. NPF-43 Enclosure: Inspection Report 05000341/2010006 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ DISTRIBUTION
- Susan Bagley
RidsNrrDorlLpl3-1 Resource RidsNrrPMFermi2 Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
DRPIII DRSIII Patricia Buckley Tammy Tomczak
ROPreports Resource
DOCUMENT NAME: G:\DRS\Work in Progress\FERMI 2010-006 CDBI ZXF.doc Publicly Available Non-Publicly Available Sensitive Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE RIII RIII RIII NAME ZFalevits (via
phone) VPLougheed
DATE 04/27/10 04/27/10 OFFICIAL RECORD COPY