IR 05000341/2015007

Fermi, Unit 2 - NRC Problem Identification and Resolution Inspection Report 05000341/2015007, November 30, 2015, through December 18, 2015

ML16032A591
Person / Time
Site:	Fermi
Issue date:	01/29/2016
From:	Billy Dickson NRC/RGN-III/DRP/B5
To:	Fessler P DTE Electric Company
References
IR 2015007
Download: ML16032A591 (36)

Text

January 29, 2016

Mr. Paul Fessler Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT: FERMI-2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000341/2015007

Dear Mr. Fessler:

On December 18, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Fermi-2 facility. The enclosed inspection report documents the inspection results, which were discussed at the exit meeting on December 18, 2015, with Mr. M. Philippon and other members of your staff. The inspectors examined activities conducted under your license as they relate to safety and 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 samples selected for review, the team concluded that the corrective action program (CAP) at Fermi-2 was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP. A qualitative risk and uncertainty based approach was used to determine the significance of the issues, the priority and the method for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to the corrective action program requirements. The use of operating experience was integrated into daily activities and was generally effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments. The assessments and audits reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Fermi-2. Licensee staff was generally aware of and familiar with the CAP and other station processes, including the employee concerns program, through which concerns could be raised. The team determined that your station's performance in each of these areas supported nuclear safety. Based on the results of this inspection, one NRC identified finding of very low safety significance (Green) was documented in this report. The finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III and the NRC resident inspector at the Fermi-2.

In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Billy Dickson, Chief Branch 5 Division of Reactor Projects Docket No. 50-341 License No. NPF-43

Enclosure:

Inspection Report No. 05000341/2015007 cc: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 50-341 License Nos: NPF-43 Report No: 05000341/2015007 Licensee: DTE Electric Company Facility: Fermi-2 Location: Newport, MI Dates: November 30, 2015, through December 18, 2015 Team Leader: R. Ng, Project Engineer Inspectors: P. Smagacz, Resident Inspector T. Bilik, Senior Reactor Inspector R. Baker, Operations Engineer Approved by: B. Dickson, Chief Branch 5 Division of Reactor Projects 2

SUMMARY OF FINDINGS

Inspection Report 05000341/2015007; 11/30/2015-12/18/2015; Fermi-2; Identification and Resolution of Problems. This inspection was performed by three region-based inspectors and the Fermi Resident

Inspector. One Green finding was identified by the inspectors. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process (SDP)," dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310; "Aspects Within Cross-Cutting Areas," dated December 4, 2014. All violations of the U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRC's Enforcement Policy dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process" Revision 5, dated February 2014. Identification and Resolution of Problems Based on the samples selected for review, the team concluded that the corrective action program (CAP) at Fermi-2 was generally effective in identifying, evaluating and correcting issues. The licensee had a low threshold for identifying issues and entering them into the CAP.

A qualitative risk and uncertainty based approach was used to determine the significance of the issues, the priority and the method for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to the corrective action program requirements. The use of operating experience was integrated into daily activities and was generally effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments. The assessments and audits reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Fermi-2. Licensee staff was generally aware of and familiar with the CAP and other station processes, including the employee concerns program, through which concerns could be raised. The team determined that your station's performance in each of these areas supported nuclear safety. Although implementation of the CAP was determined to be effective generally, the inspectors identified several issues that were minor violations and/or represented potential weaknesses of the program.

NRC-Identified

and Self-Revealed Findings Cornerstones: Initiating Events

Green.

The inspectors identified a finding of very low safety significance for the licensee's failure to meet American Society of Mechanical Engineers (ASME) Code requirements to perform planned engineering lifts of loads that exceeded a hoist's rated capacity.

Specifically, on September 25 and September 26, 2013, the licensee used the Unit 2 turbine building reactor feed pump monorail hoist to perform multiple lifts of floor plugs. The weight of the floor plugs exceeded the rated capacity of the hoist and the licensee did not follow the requirements of ASME Code B30.16, Section 16-3.4, "Planned Engineered Lifts," for lifts in excess of the rated load. These requirements include, in part, inspections, calculations, test lifts, distances traveled, and record keeping and retention. The Code also limits the number of lifts to two within any continuous 12-month period without meeting additional requirements. The licensee captured this issue in their CAP as Condition Assessment Resolution Document (CARD) 15-30077. No violation of regulatory requirements was identified. The performance deficiency was of more than minor safety significance because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, if the hoist failed, and a heavy object were to fall through the turbine building hatch opening, it could cause a loss of condenser vacuum and subsequent plant trip or possibly a steam leak into the turbine building. The finding was of very low safety significance because it did not cause a reactor trip. The inspectors determined this finding affected the cross-cutting aspect of problem identification and resolution, evaluation (P.2) due to the failure of the organization to thoroughly evaluate issues to ensure resolutions address causes and extend of condition commensurate with their safety significance.

Specifically, the licensee failed to evaluate thoroughly the causes for not complying with ASME Code requirements once a lift exceeded a hoist's rated capacity had occurred.

Therefore, effective corrective actions and an extent of condition were not identified. (Section 4OA2.1.b.3.ii)4

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of problem identification and resolution (PI&R) inspection as defined by Inspection Procedure 71152, "Problem Identification and Resolution." Documents reviewed were listed in the Attachment to this report.

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the corrective action program (CAP) at Fermi-2 to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," were met. The inspectors observed and evaluated the effectiveness of meetings related to the CAP, such as the Condition Assessment Resolution Document (CARD) Ownership Screening Committee meeting and the Management Review Committee meeting. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the CAP. The inspectors reviewed selected CARDs across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensee's CAP. The majority of the risk-informed samples of CARDs reviewed were issued since the last NRC biennial PI&R inspection completed in November of 2013. The inspectors also reviewed selected issues that were more than five years old. The inspectors assessed the licensee's characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, common cause evaluations and direct cause evaluations. The inspectors assessed the scope and depth of the licensee's evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensee's corrective actions to prevent recurrence and for less significant issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance. The inspectors selected the preventive maintenance program to review in detail based on input from the resident staff. The preventive maintenance program covered both safety-related and nonsafety related systems and is a risk significant equipment management program. The primary purpose of this review was to determine whether the licensee was monitoring and correcting equipment performance issues at both the system and component levels. The inspectors reviewed the licensee staff's ability to characterize and resolve instances involving equipment unavailability or degradation, identified through operating experience or actual events, by effective revision or augmentation of the preventive maintenance program, as appropriate. A five year review of the safety-related service water system was undertaken to assess the licensee staff's efforts in monitoring for age-related piping system degradation. The inspectors' review was to determine whether the licensee staff was properly monitoring and evaluating the performance of the system through effective implementation of station monitoring program, such as identifying and correcting issues. The inspectors performed walkdowns, as needed, to verify the resolution of issues. The inspectors examined the results of self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the licensee's corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors performed walkdowns, as necessary, to verify the resolution of the issues. The inspectors also reviewed the open corrective action items related to the Greater-than-Green security finding that were not completed by the end of the associated 95001 supplemental inspection (Inspection Report 05000341/2014408, ADAMS Accession Number ML15015A739). b. Assessment (1) Problem Identification Based on the results of the inspection, the inspectors concluded that, in general, the station was effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were identified and captured in a complete and accurate manner in the CAP. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the CAP for resolution. The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors performed a five-year review of the safety related service water system. The inspectors interviewed program owner and reviewed corrective action documents, inspection reports, inspection procedures, as well as quarterly NRC Generic Letter 89-13 and buried piping program health reports. The inspectors also reviewed a life-cycle management report prepared by Structural Integrity Associates, which discussed modeling of internal and external corrosion and water chemistry. The inspectors evaluated repair/replacement plans going forward and performed a partial system walkdown of visible parts of the system, including piping recently replaced, and a portion of the cathodic protection system.

The inspectors determined that there was an improving trend in the overall health of the program over the last five years. While outer diameter corrosion had been minimal, due in large part to the station's soil characteristics and a well-maintained cathodic protection system, internal corrosion was an ongoing issue. As a result, the licensee had implemented additional monitoring/inspections, water chemistry additions, computer modeling, cleaning, as well as ongoing repair/replacement of piping and system components. As such, the inspectors concluded that the licensee staff were properly monitoring and evaluating the performance of the system through effective implementation of the monitoring program and that internal corrosion degradation should improve.

i) Observations Change in Identification Rate During the previous PI&R inspection, the inspectors identified a negative trend related to self-identification rate compared to the outside identification rate. The licensee implemented a number of corrective actions to address that trend. The inspectors reviewed the licensee's performance indicators during this inspection. The self-identification rate compared to the outside identification rate improved since the last PI&R inspection. The licensee continues to address the issue with training and group discussions, and the inspectors noted that management remains sensitive to the issue. The inspectors also identified a small decline in CARD generation rates in the last five years. The licensee attributed that partially to process changes in how low level conditions were captured. The licensee continued to monitor the generation rates.

Based on a review of the issues reported in the CAP, the inspectors did not identify any issues affecting the overall effectiveness of the program. The licensee needed to be cognizant of this issue and to address the decline before it affected the CAP. Effectiveness of the Preventative Maintenance Program The inspectors noted that the licensee recently became aware of, through both external agency assessments and internal self-assessments/equipment failures, shortcomings in their preventive maintenance program effectiveness. For example, CARD 15-22997, "MES51 Does Not Define SPV/Single Point Vulnerabilities," identified a preventive maintenance program deficiency, which had resulted in a missed opportunity to preclude an unidentified single point vulnerability from initiating a significant event that challenged operators and subsequently led to an automatic scram. Also, CARD 15-23217, "Self-Assessment Deficiency: Critical PM Deferral Process," and CARD 15-23701, "NQA Audit Deficiency - MES51 Does Not Provide for Repeat Extension of PMs," were examples of internal processes that identified program deficiencies and led to exacerbate efforts to manage and resolve engineering backlogs. Lastly, CARD 15-23465, "Trip of RBHVAC, Autostart of Div. 1 SGTS and CCHVAC Auto Swap to Recirc," and CARD 15-23626, "Loss of RPS 'B'," were examples of missed opportunities to incorporate an effective revision or augmentation of the preventive maintenance program, based upon available industry operating experience events, potentially precluding equipment failures. Additionally, the inspectors noted that external agency evaluations performed in 2015 also characterized the recent equipment failures potentially resulted from maintenance program strategies implemented at the time of the events. The licensee captured the highlights of these assessments in CARDs 15-25138 and 15-25139, and performed investigations to determine the underlying causes and corrective actions appropriate to resolve identified programmatic issues. The inspectors noted that the planned corrective actions to address programmatic issues would be implemented over the next calendar year. The inspectors considered this an improvement opportunity for the preventative maintenance program. ii) Findings No findings were identified. (2) Problem Prioritization and Evaluation Based on the results of the inspection, the inspectors concluded that the station was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk. In particular, the inspectors observed that the majority of the low level issues were either closed at a level appropriate for a condition evaluation or closed to a trend. The inspectors determined that the CARD Ownership Screening Committee meetings and the Management Review Committee meetings were generally thorough and maintained a high standard for evaluation quality. Members of the committees discussed selected issues in sufficient detail and challenged each other regarding their conclusions and recommendations. The inspectors did not identify any significant issues with those items assigned an apparent cause evaluation, root cause evaluation, or common cause evaluation.

The inspectors reviewed the licensee's work order backlog and concluded that equipment issues were generally being addressed appropriately. The inspectors determined that the licensee usually evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified. In general, appropriate actions were assigned to correct the degraded or non-conforming condition.

There were no open items identified by the inspectors in operations, emergency preparedness, engineering, or maintenance backlogs that were risk-significant, either individually or collectively. i) Observations Classification Error The inspectors identified that a number of the Level 4 CARDs should have been classified as Level 3 items. These issues were conditions adverse to quality but were classified as enhancements that did not require any corrective action. The inspectors determined these issues were minor procedural errors because no current safety concerns existed. However, these deficiencies had the potential to lead to degraded or inoperable conditions not being recognized. One such example was CARD 14-10011, "Inadequate Margin for Load Shed Action to Preclude Exceeding Design Basis during MPC Movement." In this case, the licensee identified that the current procedure did not take into account for temperature sensor uncertainty and spent fuel cask temperature margin to initiate actions to prevent exceeding the safety analysis temperature input value of the Reactor Building temperature during spent fuel cask loading activities. An evaluation of the spent fuel loading was performed and determined that heat load from the spent fuel for the loading campaign would not cause the temperature limit to be exceeded. However, an evaluation had to be completed for future loading campaign until the procedure was changed. The inspectors determined that this was a condition adverse to quality and that the CARD should have been classified as Level 3. The licensee entered this issue into the CAP as CARD 15-29884 and re-evaluated the level classification. Since no loading campaign was currently planned, the inspectors considered this classification error issue minor. Engineering Evaluation The inspectors noted that the engineering backlog has increased in volume over the inspection period and questioned the licensee on its ability to effectively control the backlog. The increase in backlog could potentially distract the licensee from effectively monitoring the long term safety systems' health and affect proper resource utilization. The licensee provided the inspectors with their plan to reduce the backlog and discussed timelines and the prioritization issues to clear the backlog. The inspectors concluded that the plan could be successful in reducing the engineering backlog. A more detailed discussion on outstanding corrective action items is provided in Section 4OA2.1.b.3 below. Due Date Extensions Licensee procedure MQA11, Condition Assessment Resolution Document, requires justification for each due date extension request for corrective actions. However, the inspectors identified in selected CARDs that justification provided for due date extensions appeared to lack details. Normally, the reason for extending the due date, the reason why it was acceptable to extend the due date in terms of the impact to plant safety, and the reason why the due date requested was the best estimate when all the actions could be completed would be documented. However, for a number of the outstanding CARDs, the inspectors could not identify any discussion related to the due date impact to plant safety nor why all the actions could be completed by the requested dates. For example, in CARD 06-22176, "Additional Penetrations Identified that Require Post LOCA Radiation Shine Evaluation," corrective actions were assigned in 2011 to update the penetrations dose evaluation. In November 2012, the due date was extended to first quarter of 2014 for the work to be incorporated with the power uprate project. In first quarter of 2014, the due date was further extended to December 2015 to obtain a separate contractor engineering service, as it was not incorporated into the power uprate project. The licensee stated at the time that funding for the service had not been obtained and the effort was expected to take approximately seven months. In December of 2015, the due date was extended again to December 2016, citing the need for contractor proposals to be received by the end of first quarter of 2016. The licensee again stated that the project was expected to take approximately seven months. For the most recent extension, the licensee documented the reason why the impact to the plant was minimal.

The inspectors concluded that none of the three extensions documented why the due date could be feasible when the funding for the work had not even been approved. The impact to plant safety for delaying the work was also not documented except for the last request. Even though the requests were approved by the appropriate licensee management and met the minimum requirements for extension per procedure, the inspectors reasoned that the due dates requested appeared to be arbitrary without the full details documented. The licensee acknowledged this issue and planned to improve the documentation for due date extensions. ii) Findings No findings were identified. (3) Effectiveness of Corrective Action Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk. Problems identified using root or apparent cause methodologies were resolved in accordance with the CAP procedural and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely. The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely. A five-year review was performed on the licensee's implementation of their preventive maintenance program and the licensee staff's ability to incorporate revisions or augmentations of the program to resolve instances involving equipment unavailability or degradation. The inspectors reviewed issues dated back to January 2011 and assessed the effectiveness of the licensee staff's ability to characterize and resolve issues that were identified through operating experience or actual events.

The inspectors noted several examples where the initial evaluations of operating experience and industry best practices/standards did not identify or proactively address potential improvements to the licensee's preventive maintenance program. However, the licensee's corrective actions to address program deficiencies, once identified as a result of equipment failures, appear generally effective based on the program's procedural revisions the inspectors reviewed. The inspectors' review of the previous five years of the licensee's efforts to address issues with the safety-related service water system did not identify any negative trends or inability by the licensee to address long term degradation issues. The inspectors' review of the previous five years of the licensee's efforts to address issues identified with the preventive maintenance program's implementation and the licensee staff's ability to incorporate revisions or augmentation of the program to resolve instances involving equipment unavailability or degradation, did not identify any negative trends or inability by the licensee to address long-term issues.

i) Observations Outstanding Correction Action Items During this inspection, the inspectors recognized that there was a large population of outstanding correction action items. Specifically, there were over 3000 open corrective action items at the time of the inspection. More than 500 of these open corrective action items were Level 3 to Level 1 items, which the licensee considered conditions adverse to quality or significant conditions adverse to quality. About 13 percent of these items (68)were greater than 2 years old. There were also seven Level 1 CARDs, which were considered significant conditions adverse to quality by the licensee, and five of these were over 1000 days old.

The inspectors verified a sample of these CARDs were evaluated and actions assigned appropriately. In general, these open CARDs were being tracked by the responsible department. The inspectors reviewed a sample of the corrective action items and determined that most of the remaining actions were design non-conformances, which required updating design calculation or performing modification to restore compliance. The due dates for these action items had been extended a number of times due to resource limitations or other emergent issues. For those corrective actions that were safety significant, the inspectors evaluated whether the due dates were reasonable and whether the licensee had appropriate compensatory actions in place. For those items that affected safety related equipment, the inspectors determined that the corrective actions were untimely and the issues were minor violations of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," because the equipment affected were either operable or operable with appropriate compensatory actions in place. While the total number of outstanding actions was still manageable, they could potentially affect the licensee's understanding of the design basis of the plant and complicate future equipment issue resolution. The licensee acknowledged the inspectors' concern and was working on a plan to reduce the backlog.

Effectiveness Review The inspectors noticed several examples where the effectiveness review only measured success of corrective actions by the absence of a recurring event. In one example, CARD 15-21792, "72CF Failed to Throwover," the issue was the result of an increase resistance across a contact that had accumulated over many years. The effectiveness review only called for noting the absence of trips over an 18-month span to demonstrate effectiveness of the corrective actions. Since this was a long developing issue, an 18-month span would not allow sufficient time for the problem to recur. Licensee procedure MQA-11, "Condition Assessment Resolution Document," Section 7, addresses effectiveness reviews and denotes that effectiveness reviews should include, where possible, specific and measurable criteria. The inspectors questioned whether a quantitative approach was plausible by measuring resistances during the monthly surveillance test. The licensee initiated CARD 15-30098 to document the inspectors' observations and to evaluate future effectiveness reviews for including quantitative results vice the absence of failure.

ii) Findings Failure to Comply with ASME B30.16 for Planned Engineered Lifts

Introduction:

The inspectors identified a finding of very low safety significance for the licensee's failure to meet the American Society of Mechanical Engineers (ASME) Code requirements to perform planned engineered lifts of loads that exceeded a hoist's rated capacity. Specifically, on September 25 and 26, 2013, the licensee used the Unit 2 turbine building reactor feed pump (RFP) monorail hoist to perform multiple lifts of floor plugs without meeting the requirements of ASME Code B30.16, Section 16-3.4, "Planned Engineered Lifts." The weight of the floor plugs exceeded the rated capacity of the hoist. No violation of regulatory requirements was identified.

Description:

While reviewing CARD 13-26948, "Underhung Hoist used Over "Rated Capacity" Without Meeting ASME B30.16," as part of the biennial PI&R team inspection, the inspectors noted that the licensee failed to comply with the requirements of ASME B30.16, Section 16-3.4, for "Planned Engineered Lifts" when performing lifts of RFP floor plugs. Discussions with the licensee revealed that on September 25 and 26, 2013, the licensee conducted multiple lifts of the Unit 2 south turbine building RFP floor plugs using underhung hoist U3100-E031B, which had a rated capacity of 30,000 lbs. At one point, personnel performing the lifts questioned the capacity of the hoist versus the weight of the plugs being moved. They reported that the weight (32,000 lbs.) of one of the blocks dyno tested during the plug movements was in excess of the hoist's rated capacity.

ASME Code B30.16 permits lifts that exceed the rated capacity of the hoist if the requirements of Section 16-3.4, "Planned Engineered Lifts" are met. Licensee personnel, without verifying, mistakenly believed that an evaluation of the hoist capacity had been performed in CARD 12-22088, "Weight of Floor Plugs above the South RFPT may Exceed Capacity of Installed Overhead Hoist and deemed adequate. Therefore, instead of stopping and performing the Code required actions before proceeding, licensee personnel continued to complete the plug lifts. Subsequent to the lifts, CARD 13-26948 was initiated to document the non-conformance and to take corrective actions to restore compliance with the Code.

As noted above, the inspectors reviewed CARD 13-26948 and identified that the corrective actions taken were inadequate to restore compliance with the Code.

Specifically, the licensee limited corrective action just to a visual examination of the hoist. Additional Code requirements included in part, inspections, calculations, test lifts, distances traveled, and record keeping and retention. The Code also limits the number of lifts to two within any continuous 12-month period without meeting additional requirements. The licensee also failed to evaluate the north turbine building hoist, as the same conditions existed for the hoist previously. The inspectors determined that the hoists were never in compliance with the Code requirements even though multiple lifts exceeding the hoists' rated capacity had been completed. If the hoist failed, and a heavy object were to fall through the turbine building hatch opening, it could have resulted in a loss of condenser vacuum and subsequent plant trip or possibly a steam leak into the turbine building.

Analysis:

The inspectors determined the licensee's failure to comply with the requirements of ASME B30.16 for "Planned Engineered Lifts" to life RFP floor plugs was a performance deficiency warranting a significance evaluation. The inspectors reviewed the examples of minor issues in IMC 0612, "Power Reactor Inspection Reports," Appendix E, "Examples of Minor Issues," dated August 11, 2009, and found no similar examples. Consistent with the guidance in IMC 0612, Appendix B, "Issue Screening,"

dated September 7, 2012, the inspectors determined the performance deficiency was of more than minor safety significance because if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. Specifically, if the hoist failed, and a heavy object were to fall through the turbine building hatch opening, it could have resulted in a loss of condenser vacuum and subsequent plant trip or possibly a steam leak into the turbine building. In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," Table 3, "SDP Appendix Router," the inspectors determined this finding affected the Initiating Events Cornerstone, specifically the Transient Initiator contributor, and would require review using IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power,"

dated June 19, 2012. The inspectors performed a Phase 1 SDP review of this finding using the guidance provided in IMC 0609, Appendix A, Exhibit 1, "Initiating Events Screening Questions," and determined this finding was a licensee performance deficiency of very low safety significance (Green) because it did not cause a reactor trip. The inspectors determined this finding affected the cross-cutting area of problem identification and resolution, evaluation (P.2) due to the failure of the organization to thoroughly evaluate issues to ensure resolutions address causes and extend of condition commensurate with their safety significance. Specifically, the licensee failed to evaluate thoroughly the causes for not complying with Code requirements once a lift that exceeded a hoist's rated capacity had occurred. Therefore, effective corrective actions and an extent of condition were not identified.

Enforcement:

The licensee's failure to comply with ASME Code requirements to conduct planned engineered lifts of RFP floor plugs did not affect 10 CFR 50, Appendix B, components; therefore, no violation of regulatory requirements occurred. The licensee entered this finding into its corrective action program as CARD 15-30077. (FIN 05000341/2015007-01, Failure to Comply with ASME B30.16 for Planned Engineered Lifts)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed the operating experience program implementing procedures, and completed evaluations of operating experience issues and events. The inspectors also attended the weekly operating experience meeting to observe the screening of OE information and reviewed selected monthly assessments of the OE performance indicators. The inspectors discussed OE program activities with the facility's OE coordinator, and observed daily activities such as pre-job briefs for the use of operating experience information. The intent was to determine if the licensee was effectively integrating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of operating experience experience, were identified and implemented effectively and in a timely manner. b. Assessment Based on the results of the inspection, the inspectors concluded that in general, operating experience was effectively utilized at the station. Both internal and external operating experience was being incorporated into station activities. The inspectors observed that operating experience was discussed as part of the daily and pre-job briefings. Industry operating experience was effectively disseminated across plant departments and was used to assist with resolving equipment issues. No significant issues were identified during the inspectors' review of selected licensee operating experience evaluations.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments and Nuclear Quality Assurance (NQA) audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs. b. Assessment Based on the self-assessments and audits reviewed, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. These audits and self-assessments were completed by personnel knowledgeable in the subject area. The inspectors concluded that the NQA audits were generally thorough and critical based on the number and nature of issues identified as well as the recommendations proposed. The inspectors observed that CARD items had been initiated for issues identified through NQA audits and self-assessments. Corrective actions developed from these assessments were tracked for resolution in the CAP and enhancement actions were assigned in the Action Item Management System. The inspectors reviewed the self-assessment performed on the CAP itself and generally agreed with the overall results and conclusions drawn.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed selected Fermi personnel to determine if there were any indications that licensee personnel were reluctant to raise safety concerns to either their management or the NRC due to fear of retaliation. The inspectors reviewed selected employee concern program (ECP) case files to identify any emergent issues or potential trends. The inspectors also assessed the licensee's safety conscious work environment through a review of ECP implementing procedures, discussions with the Fermi ECP coordinator, interviews with personnel from various departments, and reviews of corrective action documents. The inspectors reviewed licensee's self-assessments and assessments by external organizations of safety culture to determine if there were any organizational issues or trends that could affect the licensee's safety performance. b. Assessment The inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety conscious work environment at Fermi-2. Licensee staff members were aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. In addition, a review of the types of issues in the ECP indicated that the licensee staff members were appropriately using the CAP and ECP to identify issues. The licensee staff also indicated that management had been supportive of the CAP by providing time and resources for employee to generate their CARDs.

The staff generally expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be communicated to supervision and safety significant issues were being corrected. Some employees indicated that training and retraining of the CAP process were not performed and they lacked the proficiency to navigate the computerized CAP efficiently. The inspectors considered that an improvement opportunity for the CAP implementation. Since the beginning of 2014, two major safety culture assessments had been performed by the licensee's staff, and a nuclear plant owner/operators organization. The results indicated that there were no impediments to the identification of nuclear safety issues.

However, the inspectors reviewed these surveys and identified that there was a slight disconnect on a number of issues between staff and management. These issues were related to resource utilization and corrective action effectiveness. The inspectors determined that these issues did not result in a chilled environment as the staff still exhibited and expressed a willingness to bring up safety issues. The licensee acknowledged the discrepancies and was developing a plan to address the issues.

c. Findings

No findings were identified.

4OA6 Management Meetings Exit Meeting On December 18, 2015, the inspectors presented the inspection result to

Mr. M. Philippon and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Philippon, Plant Manager

L. Peterson, Engineering Director

J. Davis, Training Manager

M. O'Connor, Security Manager

W. Colonnello, Work Management Director

E. Kokosky, Organizational Effectiveness Director

W. Raymer, Maintenance Manager

J. Louwers, Quality Assurance Manager

R. Laburn, Radiation Protection Manager

C. Harris, Performance Improvement Manager

A. Hassoun, Licensing Manager

NRC

B. Dickson, Branch Chief

B. Kemker, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000341/2015007-01 FIN Failure to Comply with ASME B30.16 for Planned Engineered Lifts (Section 4OA2.1.b.3.ii)

Closed

05000341/FIN-2015007-01 FIN Failure to Comply with ASME B30.16 for Planned Engineered Lifts (Section 4OA2.1.b.3.ii)

Discussed

None

LIST 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 or 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.

Condition Reports

CARD 06-20273 General Electric Safety Information Communication: SC06-01 - Non-Conservative Single Failure Assumption in GE Analysis for Post-LOCA Long-

Term Suppression Pool Temperature January 20, 2006 CARD 06-22179 Additional Penetrations Identified that Require Post-LOCA Radiation Shine Evaluation April 11, 2006 CARD 06-26469 000Z051404 Did Not Obtain Desired Results for

EDG 13 Voltage Droop October 5, 2006 CARD 08-20821 NRC Concern: Review of Tornado Missile Hazard Analysis February 5, 2008 CARD 08-26828 Non-Qualified Support System to Ensure Adequate Post-LOCA Emergency Depressurization October 15, 2008 CARD 09-27724

CSCCD-N30R827 Needs Revision October 4, 2009 CARD 09-27876 2009 Configuration Design Basis Inspection (CDBI) Self-Assessment - Additional Unanalyzed

HPCI/RCIC and Room LOCA Heat Load October 8, 2009 CARD 09-28785 Design Modifications are Needed for the Cables Routed Outside the Raceways November 12, 2009 CARD 10-22001 Failure of Center TBHVAC Exhaust Fan March 7, 2010 CARD 10-23191 Need to Establish Band for EDG Standby Lube Oil Level April 15, 2010 CARD 10-28090 Reactor Building Superstructure Re-analysis September 14, 2010 CARD 10-28232 2010 FPSA Concern - Fire Suppression Effects Analysis September 17, 2010 CARD 10-29525 Request Evaluation of Specific Core Spray/RHR Alignment Impact on EDG Operability October 26, 2010 CARD 10-31273 Review PM Maintenance Strategy for RPS Reactor Auto SCRAM Trip Logic Relays

K14A - K14H November 28, 2010 CARD 11-20548 Effectiveness Review of CARD 09-23344, INPO Identified

ER.2-1 - Preventive Maintenance Strategies Effectiveness Measures Not Met January 18, 2011 CARD 11-20883 Critical PM Coding - CTGs January 27, 2011 CARD 11-21479 Core Spray Pump Interactions Affecting Minimum Flow Line Effectiveness February 8, 2011 CARD 11-22539 Actions Credited in CARD 10-29668 Have Not Occurred to Date March 9, 2011

CARD 11-25162 Revise PM Frequencies for Non-Critical MOVs to Align with Industry Standards May 20, 2011 CARD 11-25492 MES51 PM Changes Revision Needed (NRC Identified) May 31, 2011 CARD 11-28413 Establish PM for EDG Flexible Pipe Couplings September 13, 2011 CARD 11-30644 Technical Specification Curves for Pressure / Temperature for Core Critical and Core Not Critical Determined to be Non Conservative December 1, 2011 CARD 12-20055 Clarification Required for Scheduling of

RM-Repetitive and

SM-Scheduled Type PMs by Maintenance January 4, 2012 CARD 12-20586 MES51 (PM Program) Changes to PM Event Technical Requirements January 24, 2012 CARD 12-20969 Due to PM Program Frequency Changes, Managing 50% of Grace is Driving Higher Unavailability of Safety Systems February 6, 2012 CARD 12-21817 Scheduling of Preventive Maintenance (PM) Work on Fuel Pool Cooling and Clean Up (FPCCU) and Recommendation 2 of

IER-1-11-2 March 6, 2012 CARD 12-22088 Weight of Floor Plugs Above the South RFPT may Exceed Capacity of Installed Overhead Hoist March 19, 2012 CARD 12-22833 Two Individuals Enter a High Radiation Area Without being Briefed on Radiological Conditions April 6, 2012 CARD 12-23041 No Clearly Defined Process Governing Repetitive Maintenance Work April 10, 2012 CARD 12-23649 Develop PMs for GE HFA Relays April 23, 2012 CARD 12-24409

NQA-Recirculation Pump Seal PM Extension Lacks Technical Justification May 11, 2012 CARD 12-24725 Design Calculation (DC-6447) Voltage Requirement for EDGs (CDBISA Questions 047 & 056) May 25, 2012 CARD 12-26184 Blown Fuses for E4150F002 While Placing HPCI in STBY

IAW 23.202 and 22.000.02 July 23, 2012 CARD 12-27397 MES51 (Preventive Maintenance Program) Recommended Enhancements September 6, 2012 CARD 12-28553 Replace EDG Thermometer R30RA25A October 17, 2012 CARD 12-29498 Contamination Buildup in Max Air Hood November 26, 2012 CARD 12-29724 Determine if EPA Testing Has Missed Performing Required Activities Per Commitment December 4, 2012 CARD 12-30168 Maintenance Rule Expert Panel Has Determined the A7100 System is a(1) Under Maintenance Rule December 21, 2012 CARD 13-10103 Main Steam Piping Support Exceeds Design Load June 7, 2013 CARD 13-20462 GE Calculation for RPV Head Strongback January 17, 2013 CARD 13-20522 Unusual RBHVAC Damper Alignment Caused Entry into EOPs January 22, 2013

CARD 13-20758 Self-Assessment Recommendations for 2013 Preventive Maintenance Program Self-Assessment January 31, 2013 CARD 13-21183 Evaluate Additional Relays to Be Included in PM F879 February 16, 2013 CARD 13-23039 NQA Identified - Issues with Reassembly of P4400B001B (Div. 2 EECW Heat Exchanger) April 30, 2013 CARD 13-24461 NQA Audit Recommendation-Evaluate the PM Deferral Review and Approval Period June 21, 2013 CARD 13-24513

EDG 13 Overspeed Trip Alarm During Standby Checks June 24, 2013 CARD 13-24841 EDG Steady State Voltage and Frequency Tech Spec Ranges July 10, 2013 CARD 13-24868 2013 CDBI: Re-evaluation of Classification and Maintenance Strategies of RHR Heat Exchangers July 11, 2013 CARD 13-25347 Station Air to IAS Bypass Valve P5000F1041C Change to Normally Open Per

EDP-37169 July 31, 2013 CARD 13-25348 E1100F069A, the Div 1 RHR Heat Exchanger Service Water Supply Drain Isolation Valve has Seat Leakage July 31, 2013 CARD 13-26090 Verify and Create PMs to Replace Station Batteries at End of Life August 29, 2013 CARD 13-26123 Deficiencies with Canberra 5XLB TENNELEC August 30, 2013 CARD 13-26398 Potential Unattended Pathway Discovered September 11, 2013 CARD 13-26771 Written PM Feedback Program Outlined in MWC14 Has Stalled September 22, 2013 CARD 13-26923 NRC Issue-Radiation Monitor Ranges Do Not Support EAL and EOP Prompt Actions September 26, 2013 CARD 13-26948 Underhung Hoist used Over "Rated Capacity" Without Meeting ASME B30.16 September 27, 2013 CARD 13-27100 Security Concern Storm Drain System October 4, 2013 CARD 13-27397 Fire Protection Detectors Not Able to be Tested Due to Being Inaccessible October 16, 2013 CARD 13-28406 ED Set-points for HPCI Run were Inadequate November 26, 2013 CARD 13-28624 UHS Level and Temperature Instrument Inaccuracies Not accounted for in 24.000.02 December 5, 2013 CARD 13-28993 Lead Blankets Dropped from RB2 - (Near Miss) December 21, 2013 CARD 14-10011 Inadequate Margin for Load Shed Actions to Preclude Exceeding Design Basis During MPC

Movement October 12, 2014 CARD 14-20250 Reactor Building Crane Cab Lost Power January 14, 2014 CARD 14-20458 Dose Rates Higher Than Expected January 23, 2014 CARD 14-20673 NRC Identified-HPCI and RCIC Drain Pot Valves Must Be Included in IST Program January 31, 2014

CARD 14-20779 Formalize a Process for Reopening of a PM Deferral February 4, 2014 CARD 14-20833 Mispositioned Component Event-Div. 2 EECW Isolation Override Switch February 6, 2014 CARD 14-20886 Personnel Contamination Event (PCE #9) February 8, 2014 CARD 14-21183 Personnel Contamination <100 CCPM - Non-Reportable of Worker Performing IVVI in RCWP February 16, 2014 CARD 14-21191 72E Bus Voltage Reading 128 Volts February 16, 2014 CARD 14-21215 Unexpected Electronic Dosimeter Dose Rate Alarm - Bumped ED February 16, 2014 CARD 14-21352 Worker Received Electronic Dosimeter Dose Alarm February 19, 2014 CARD 14-21455 Increasing Dose Rates on Fuel Pool Demin Inlet Piping Initiates High Radiation Area Controls February 20, 2014 CARD 14-21591 ED Dose Rate Alarm

RB-1 Steam Tunnel February 23, 2014 CARD 14-21778 Mispositioned Component: Valve Repositioned by MOV Group Without Notifying OPS February 27, 2014 CARD 14-21795 Delta Suit Process Improvements February 28, 2014 CARD 14-21867 Worker in Containment Area without Protective Clothing March 1, 2014 CARD 14-21881 Recirc Seal Does not Meet Acceptance Criteria March 2, 2014 CARD 14-21892 Unsatisfactory Pee-Check for HEPA Unit March 2, 2014 CARD 14-21948 SSPV Appears to be Wired Incorrectly March 4, 2014 CARD 14-22256 PMs Completed in 2nd Half of Grace March 11, 2014 CARD 14-22547 Blown Fuse Causes Loss of RPS B March 18, 2014 CARD 14-22610 Repetitive Failures of RPS Relay K17B March 20, 2014 CARD 14-22612

EDG 11 Manually Tripped During Surveillance Test Due to Fire From Turbo Lagging March 20, 2014 CARD 14-22855 DC Procedures Do Not Meet SR Requirements March 26, 2014 CARD 14-22932 Need to revise 24.206.04 RCIC System Automatic Actuation and Flow Test Temperature Correction Table March 29, 2014 CARD 14-23141 DOSE Alarm Received While Performing S/U Walkdowns April 5, 2014 CARD 14-23220 NRC Concern: Request PSE Review Adequacy of Fermi 2 Programmatic Implementation of

IMC 0326 Timing of Corrective Actions Reviews April 9, 2014 CARD 14-23444 Enhancement - Pursue a Modification of the RBHVAC Trip Function April 17, 2014 CARD 14-23574 Latent PADS Data Entry Error April 23, 2014

CARD 14-23680 RERP Drill April 15th 2014: Failed Objective E1 for Timely Initial Notifications April 27, 2014 CARD 14-23894 Revise3 MES51 to Address MR Impact for PMs Past Critical Date May 5, 2014 CARD 14-23972 FERMEX 2014: Drill Control Issues-Internal-TREND May 8, 2014 CARD 14-24066 Failed Upper Main Bearings May 12, 2014 CARD 14-24187 Potential Emerging Trend: Human Performance-Avoid Complacency May 15, 2014 CARD 14-24357 NQA Identified: Proposed New Emergency Action Level Electrical Scheme Would Drive Inappropriate Classifications May 22, 2014 CARD 14-24717 Tracking CARD for ISFSI Procedural Requirements November 7, 2014 CARD 14-25103 IST Program Self-Assessment Deficiencies June 19, 2014 CARD 14-25242 NRC Finding-Application of SR 3.0.3 June 26, 2014 CARD 14-25468 Request Changing the P4400F606A and F606B to Throttle Open Valves July 3, 2014 CARD 14-25576 NRC Non-Cited Violation Cross Cutting Aspect Evaluation July 10, 2014 CARD 14-25659 CAP Program Behavior Changes July 11, 2014 CARD 14-25665 Self-Assessment Deficiency: Establish PMs on the EDG Load Sequencer Components July 11, 2014 CARD 14-25679 OE309283 Enhancement for Dry-Type Transformers July 11, 2014 CARD 14-25823 Jumper Contact with Unintended Terminal July 17, 2014 CARD 14-26326 First Time PMs Not Being Flagged and Managed As Intended August 8, 2014 CARD 14-27157 NRC Identified Safety Concern About Storage of ISFSI-related Material Near 345kV Mat September 10, 2014 CARD 14-27160 NRC Identified Safety Concern About Storage of Material Near 120kV Mat September 10, 2014 CARD 14-27420 NQA - Radiological Control Boundaries and Posting Issues Identified on the Refuel Floor September 18, 2014 CARD 14-28232 NRC Issue-Failure to Perform Immediate Operability Review October 21, 2014 CARD 14-28301 2014 NRC Triennial FP Green Non-Cited Violation on Valve Location October 23, 2014 CARD 14-28567 NRC Cross-Cutting Aspect Review OE (RPS Blown Fuse Finding 3Q2014) November 3, 2014 CARD 14-28568 NRC Cross-Cutting Aspect Review Work Management (EDG 11 Fire Finding 3Q2014) November 3, 2014 CARD 14-29030 Green Finding for Dose Overage on

RWP 14-5002 November 25, 2014 CARD 14-29223 Total Number of PMs Deferred at 4th Quartile When Compared to PIC Data December 5, 2014

CARD 15-10052 Investigate Why Security Personnel that have Left the Access Portal are Allowed to Pass Metal Detectors Armed March 3, 2015 CARD 15-20207 NQA Audit Deficiency-2014 Audit Deficiency CARD Closed Without Correcting the Identified Condition January 9, 2015 CARD 15-20234 Request Removal of Material Near 345 kV Mat January 11, 2015 CARD 15-20637 2014 LOR Annual Operating Exam Opportunities January 27, 2015 CARD 15-20847 Evaluate the Root Cause Evaluation (RCE) Process Requirement to Assign CATPRs for all RCEs February 2, 2015 CARD 15-20848 NRC Identified Concern with Floor Drain 75-29 History February 2, 2015 CARD 15-20962 NRC Green Violation Cross Cutting Aspect Review for CARD 14-28232 February 5, 2015 CARD 15-21129 2015 Modification and 50.59 NRC Inspection-Review CPTs (150VA & 250VA) Test Requirements February 12, 2015 CARD 15-21179 NQA Recommendation:

Upgrade CARD 14-25625 to Level 3 and Enhance it to Indicate the Actions Being Taken to Address the Ineffective Actions Identified in Level 3 CARD 14-20082 February 13, 2015 CARD 15-21186 Degraded OREX Coveralls February 13, 2015 CARD 15-21326 NQA Deficiency:

Untimely Processing of Newly Initiated CARDs February 18, 2015 CARD 15-21350 RBHVAC Tripped from Freezestat H February 19, 2015 CARD 15-21354 Additional Barrier Preventing Timely Reviews February 19, 2015 CARD 15-21792 72CF Failed to Throwover March 9, 2015 CARD 15-21796 Revision to the NRC Branch Technical Position on Waste Classification March 10, 2015 CARD 15-21797 NRC

RIS 2015-02 March 10, 2015 CARD 15-21824 Crew Learning Opportunity,

CTP 10 Min Avg Exceeded Following Power Ascension March 11, 2015 CARD 15-22029 RBCCW/EECW Drywell Leak Causes Single Loop Operation and Reactor Scram March 19, 2015 CARD 15-22090 Evaluate Reactor Scram from OPRM Upscale During Single Loop Operation March 21, 2015 CARD 15-22231 Surveillance PT: RW07 not Completed by Critical Date March 26, 2015 CARD 15-22419 Inconsistent Implementation of Actions from Assessment of EP Qualification Process Weakness April 2, 2015 CARD 15-22559 NRC Green Violation Cross Cutting Aspect Review for CARD 15-21129 April 8, 2015 CARD 15-22778 Issued Parts not Returned to the Warehouse Resulting in Improper Storage and Controls of Safety Related QA Level 1 (Q) Parts June 15, 2015

CARD 15-22997 MES51 Does Not Define SPV/Single Point Vulnerabilities April 27, 2015 CARD 15-23051 Request Clarification: Application of 10CFR50.54x and 50.54y April 29, 2015 CARD 15-23062 NRC Region 3 LRA Inspection Recommendation: PM Program Procedure Update April 29, 2015 CARD 15-23111 Safety Incidents Not Reported in a Timely Manner at Fermi Leading to a Lack of Safety Culture April 30, 2015 CARD 15-23159 2015 License Renewal Inspection NRC Identified Discrepancy-Spring Can Setting May 1, 2015 CARD 15-23217 Self-Assessment Deficiency: Critical PM Deferral Process May 5, 2015 CARD 15-23459 NQA Audit Trend Only - QA Hold Point N/A'ed and Signed off by Maintenance May 15, 2015 CARD 15-23465 Trip of RBHVAC, Autostart of Div. 1 SGTS and CCHVAC Auto Swap to Recirc May 16, 2015 CARD 15-23510 Overdue Rebuild Requirement on Spare Regulators May 19, 2015 CARD 15-23598 Upgrade Simulator to Show THI Without Instructor Manual Input May 22, 2015 CARD 15-23626 Loss of RPS B May 25, 2015 CARD 15-23701 NQA Audit Deficiency-MES51 Does Not Provide for Repeat Extension of PMs May 28, 2015 CARD 15-24418 Need PM Events / Work Orders for Disassembly and Inspection of Chilled Water Pump Discharge Checks June 25, 2014 CARD 15-24451 Oil Leaking from Primary Disconnect June 26, 2015 CARD 15-24660 Loss of Secondary Containment during PMT July 7, 2015 CARD 15-24840 Tele-Pole Failed after Use Response Checks July 14, 2015 CARD 15-25138 INPO 2015 Plant Evaluation AFI

ER.2-1, Engineers are not Actively Identifying Single-Point Vulnerabilities (SPV) and Developing Commensurate Mitigating Strategies to Prevent Equipment Failures July 24, 2015 CARD 15-25138 INPO 2015 Plant Evaluation AFI

ER.2-1, Engineers Are Not Actively Identifying Single-Point Vulnerabilities (SVP) and Developing Commensurate Mitigating Strategies to Prevent Equipment Failures July 24, 2015 CARD 15-25139 INPO 2015 Plant

Evaluation AFI ER 3-2, Aging Management Strategies for Many Circuit Cards and Relays that Support Equipment with Operational Impact are not Adequate to Preclude Failures July 24, 2015 CARD 15-25139 INPO 2015 Plant Evaluation AFI

ER.3-2, Aging Management Strategies for Many Circuit Cards and Relays That Support Equipment with Operational Impact Are Not Adequate to Preclude Failures July 24, 2015

CARD 15-25224 NQA - QA Inspections Could not be Performed due to Inaccessibility July 28, 2015 CARD 15-25228 NQA - Missed QA Hold Point for

EDP 37122 - FLEX Back-Up Power July 28, 2015 CARD 15-25299 RHRSW Supply Pipe Wall Thinning Re-Inspection Results July 30, 2015 CARD 15-25544 Why Are We Not Submitting Cards for Low Level Issues August 12, 2015 CARD 15-25570 Potential Issues with the Timing of the RBHVAC Damper Actuations for the East Train of RBHVAC August 12, 2015 CARD 15-26003 Hard Card Found Marked Up in Simulator During 2015 ILO Exam August 27, 2015 CARD 15-26093 Unsat Specific Gravity in Two Stored Batteries at the NOC August 28, 2015 CARD 15-26238 2015 PI&R FSA Deficiency:

Ineffective NSCA CARD 14-27165 Resolution September 3, 2015 CARD 15-26240 2015 PI&R FSA Deficiency:

Weaknesses in Manager/Supervisor CAP Oversight September 3, 2015 CARD 15-26299 New Modification Interferes with Nitrogen Cabinet Door September 5, 2015 CARD 15-27174 Concern Related to Issue Reporting and Documentation in CAP October 2, 2015 CARD 15-27334

NQA-FLEX Building Door Chugger Modification October 5, 2015 CARD 15-27552 Perform NQA Missed Opportunity Assessment on NRC Finding Concerning MSA Ultralite SCBAs October 9, 2015 CARD 15-27584 NRC Residents 3Q15 Exit Observation - Common Cause Evaluations Performed Less Frequently October 10, 2015 CARD 15-27661 NRC Severity Level IV NCV for Integrity of Exams and Tests at Fermi 2 October 12, 2015 CARD 15-27861 Safety Conscious Work Environment Concern October 16, 2015 CARD 15-28065 Wrong Oil Used in Recirc Pump A Lower Bearing October 21, 2015 CARD 15-28156 Added Dose Due to Extended Scope and Failed Inspection October 23, 2015 CARD 15-28405 NDE Hold Point Missed October 29, 2015 CARD 15-28439 NQA Audit Deficiency: Technical Requirements Have Not Been Revised in the PM Program for

MOVs October 30, 2015 CARD 15-28711 USA

KPI-OWM-TECH-PMP1 - Total PMs Delinquent Performance November 6, 2015 CARD 15-28719 Actual Test Uncertainty Exceeds the Acceptable Test Uncertainty of 47.205.01 from

RFO-17 for Case 2 Evaluation November 6, 2015 CARD 15-29126 Revise MQA11 to Provide Vulnerability Assessment Guidance When Processing CARD Extensions November 19, 2015 CARD 15-29322 Decline in Condition Identification November 25, 2015

CARD 15-29392 Previous CARD Disposition Without Adequate Investigation November 26, 2015

DER 90-0223 VEN

SIL 508 Scram Contactor Coil Life and Maintenance March 20, 1990

Apparent Cause Evaluation

ACE 13-28993 Lead Blankets Dropped from RB2 December 21, 2013

ACE 14-20833 Mispositioned Component Event - Div. 2 EECW Isolation Override Switch March 8, 2014

ACE 14-24066

EDG-11 Flashed #2 and #3 Upper Main Bearings July 10, 2014

ACE 14-27086 Safety Tagging Issue Encountered While Performing Work September 8, 2014

ACE 15-21742 NQA Audit Finding: Operations Procedure Implementation Requirements and Commitments Contained in Operations Department Expectations

(ODEs) is Contrary to the Quality Assurance Program April 9, 2015

ACE 15-21792 72CF Failed to Throwover April 7, 2015

ACE 15-24660 Loss of Secondary Containment During PMT July 7, 2015

Common Cause Evaluation

CCA 14-20706 D1100 (a)(1) Common Cause GWP February 20, 2014

CCA 14-23428 First Quarter 2014 Aggregate Industrial Safety Review April 17, 2014

CCA 14-23428 First Quarter Industrial Safety Aggregate Review June 9, 2014

CCA 14-23509 Plant Status Control Behaviors April 21, 2014

CCA 14-24143 Safety Tagging and Clearance Behaviors May 14, 2014

CCA 14-29107 NQA - QA Step/Hold Point N/A'd by Work Group December 1, 2014

CCA 15-23909 Perform Common Cause Analysis on 2015 Consequential Failure Events June 3, 2015

CCA 15-25324 Operations Trend Less Than Adequate July 31, 2015

CCA 15-25825 Adverse Trend in Foreign Material Exclusion August 21, 2015

Audit, Assessment and Self-Assessments NAPI 15-0012 2015 PI&R focused Self-Assessment September 3, 2015

NPOP 15-0047 Focused Self-Assessment - Station Blackout and Extreme Damage Mitigation August 12, 2015

NQA 14-0101 Quality Assurance Audit of the Emergency Preparedness (EP) Program January 27, 2014

NQA 14-0102 Quality Assurance Audit of the Evaluation & Corrective Action and Operating Experience Programs February 7, 2014

NQA 14-0111 Audit of the Radiological Effluents Program and the Radiological Material Transfer & Disposal Program August 4, 2014

NQA 14-0112 Audit of the Radiological Protection Program October 6, 2014

NQA 15-0101 Quality Assurance Audit of the Radiological Emergency Response Preparedness Program January 27, 2015

NQA 15-0102 Quality Assurance Audit of the Evaluation & Corrective Action and Operating Experience Programs February 16, 2015

NQA 15-0103 Quality Assurance Audit of the Operations Program and Emergency Operating Procedures March 9, 2015

NQA 15-0106 Quality Assurance Audit of the Maintenance, M&TE, and Work Control Programs June 22, 2015 Report Number: 1000128.405 Life Cycle Management and Buried Piping Evaluation Report for Fermi-2 Nuclear Generating Station Revision 1 TMFT 15-0072 Quick Hit Self-Assessment on Declining Trend in ERE Quality April 16, 2015 TMIS 14-0064 2014 IST Program Self Assessment July 7, 2014 TMIS 15-0033 2015 Flow Accelerated Corrosion (FAC) Program Focused Self-Assessment Report March 21, 2015 TMTE 13-0029 Focused Self-Assessment - Preventive Maintenance Program February 28, 2013

Miscellaneous

ASME B30.16 Overhead Hoists (Underhung) 2012 Report Number

1401176.401 gPIMS Re-Inspection and SHM at Enrico Fermi Power Plant 2 September 23, 2015 Work Order

C421130100 Replace SSPV's with New Pretested Valves January 27, 2014 Work Order

34683126 Remove/Reinstall TB2 Floor Support for

WO 34682823 June 29, 2012 Work Order

37607773 Underhung Hoist Used Over "Rated Capacity" without Meeting ASME B30.16 February 7, 2014 Work Order

37662167 Implement Mounting Configuration Change for

EDG 11 Emergency Overspeed Switch (EOS) November 25, 2014 Work Order

37662214 Implement Mounting Configuration Change for

EDG 12 Emergency Overspeed Switch (EOS) October 4, 2015

Work Order

37662340 Implement Mounting Configuration Change for

EDG 14 Emergency Overspeed Switch (EOS) May 8, 2015 Buried Pipe Inspection Program Report Fourth Quarter 2014 Buried Pipe Inspection Program Report First Quarter 2015

LER 2013-003-00 - Loss of Secondary Containment Function Due to Exceedance of Technical Specification Required Vacuum Pressure November 24, 203

LER 2013-004-00 - Condition Prohibited by Technical Specifications for 480 Volt Bus Inoperable due to Failed Voltage Regulator December 14, 2013

LER 2015-001-01 - Secondary Containment Declared Inoperable After Loss of Reactor Building Ventilation and Freeze Protection Actuation February 19, 2015

LER 2015-002-00 - Loss of Both Divisions of the Residual Heat Removal Low Pressure Coolant Injection Functions due to 480 Volt Swing Bus Inoperable March 9, 2015

LER 2015-003-00 - Oscillation Power Range Monitor Upscale Reactor Scram During Single Loop Operation March 19, 2015

LER 2015-004-00 - Secondary Containment Declared Inoperable due to Reverse Rotation of Normal Exhaust Fan During Post-

Maintenance Testing July 7, 2015

LER 2015-005-00 - Secondary Containment Declared Inoperable due to RBHVAC Damper Malfunction August 12, 2015 Maintenance Strategy: Contactor - RPS AB PWR Distribution Cabinet August 8, 2014 Management Review Committee (MRC) Checklist and Grade Sheet Revision 1 Management Review Committee (MRC) Job Aid - Root Cause Evaluation Report Key Concepts to Review Revision 1 Management Review Committee Agenda Various Dates Nuclear Safety Culture Assessment July 2014 Operating Experience Review Committee Agenda December 14, 2015 Organizational Effectiveness Survey Results April 2015 Ownership Screening Committee Agenda Various Dates Program Health Report,

GL 89-13 Safety Related Service Water (SRSW) Program First Quarter 2015 Program Health Report,

GL 89-13 Safety Related Service Water (SRSW) Program Second Quarter 2015

Operating Experience

CARD 14-20973 NRC Regulator Issue Summary (RIS) 2014-01 Received - Review Against MGA30 Process February 11, 2014 CARD 14-22648 NRC Regulatory Issue Summary (RIS) 2014-03 Received - Review Against Part 37 Implementation March 21, 2014

CARD 14-23101 IER L3-14-8 Airborne Contamination on the Refuel Floor April 4, 2014 CARD 14-23102 IER L4-14-10 Improper Setting of Electronic Alarming Dosimeters April 4, 2014 CARD 14-24809 NRC

RIS 2014-06 Consideration of Current Operating Issues and Licensing Actions in License Renewal June 9, 2014 CARD 14-25114

GL 89-13 Program Enhancement from 2014 EPRI Heat Exchanger Performance Users Group June 20, 2014 CARD 14-25187 NRC - IAT Advisory

IA-14-01 "Situational Awareness - Cyber Security Event at NRC Licensed Facility" June 24, 2014 CARD 14-25200 Revise Licensing Work Instruction to Include Guidance on Proprietary Information (RIS 2014-01) June 24, 2014 CARD 14-26115 NRC Regulatory Issue Summary (RIS) 2014-02 Received July 29, 2014 CARD 14-26776 Applicability of NRC Regulatory Issue Summary (RIS) 2014-09 Regarding License Renewal August 27, 2014 CARD 14-27535 NRC Information Advisory (IA) 14-02 - "Situational Awareness - Returning Foreign Fighters Pose Potential Threat" September 24, 2014 CARD 14-27693 Review

NUREG-1022 Revision 3 Supplement 1 for Impact September 30, 2014 CARD 14-28478

IN 2014-11: Recent Issues Related to the Qualification of Safety-Related Components October 30, 2014 CARD 14-28825 IER L3-14-49 Highly Radioactive Components Inadvertently Left on Fuel Transfer Canal Floor not Identified Until Drain-Down November 14, 2014 CARD 14-28942 NRC Information Notice 2014-12: Crane Heavy Lift Issues Identified During NRC Inspections November 20, 2014 CARD 14-29336 NRC Withdrawal of Regulatory Guide 1.56 "Maintenance of Water Purity in Boiling Water Reactors" December 11, 2014 CARD 15-20551 NRC - Regulatory Issue Summary 2009-10 Communications Between NRC & Reactor Licensees During Emergency & Significant Incidents January 22, 2015 CARD 15-20552 Receipt of NUREG 2155, Revision 1 - Implementation Guidance for 10 CFR Part 37 January 22, 2015 CARD 15-21044 NRC Regulatory Issue Summary 2015-01 Enforcement Guidance

Memorandum

EGM 14-003

Against the EPRI PDI Bolting Qualification Program February 9, 2015 CARD 15-21796 Revision to the NRC Branch Technical Position on Waste Classification March 10, 2015 CARD 15-21797 Nuclear Regulatory Commission Regulatory Issue Summary (RIS) 2015-02 March 10, 2015 CARD 15-21935 NRC Regulatory Issue Summary 2015-03 "Identifying & Reporting Security Incidents Under Part 37" March 16, 2015 CARD 15-22704 NRC Letter to Licensees on Proposed Director's Decision Regarding 2.206 Petition April 14, 2015 CARD 15-22916 Evaluate NUREG/CR-6726 for Applicability to Fermi 2

IWE-Program April 23, 2015

CARD 15-24149 Receipt of NRC

RIS 2015-06 Tornado Missile Protection June 11, 2015 CARD 15-27246 NRC Issues

IN 2015-09, "Mechanical Dynamic Restraint (Snubber) Lubricant Degradation not Identified due to Insufficient Service Life Monitoring" October 4, 2015 CARD 15-28363 NRC Security Advisory

SA-2015-11: Situation Awareness - Security Concerns Related to Geocaching and Other Similar Geolocating Game Activity Near Critical Infrastructure Facilities October 28, 2015

MFN 15-042 R2 Closure of Part 21 60-Day Interim Report Notification: Potential Failure of Electromatic Relief Valve Cutout Switch September 10, 2015

OE 2014-0100 IER L3-14-5, Flashover During Pressure Washing of 500-kV Insulators by Supplemental Personnel February 6, 2014

OE 2014-0166 IER L3-14-11, Inadequate Communications Resulted in Cable Support Structure Damage March 6, 2014

OE 2014-0179 IER L3-14-12, Water Intrusion into Relay Box Causes Main Feedwater Isolation Valve Closrue and Manual Scram March 18, 2014

OE 2014-0577 IER L3-14-29, Incorrect Valve Stroke Setting Contributes to an Uncontrolled Dilution Event July 24, 2014

OE 2015-0133 IER L3-15-5, Foreign Material Damages Steam Generator Tube Sheet March 12, 2015

OE 2015-0279 IER L3-15-19, Work in Switchyard Causes Dual-Unit Power Outage May 21, 2015 PART 21 Report Event # 51458 Electromatic Relief Valve (EMRV) Cutout Switch October 6, 2015

Procedures

35.CON.027 Raychem Installation and Removal Revision 2 20.300.SBO Loss of Offsite and Onsite Power Revision 22 29.ESP.08 Drywell Cooling Water Restoration Revision 13 35.RIG.012 Trolley and Trolley Beam Inspection Revision 30 47.205.01 Residual Heat Removal Division 1 (North) Heat Exchanger Performance Test Revision 21, Revision 12 65.000.146 Operation of the Canberra Series 5XLB TENNELEC Revision 3

AOP 20.107.02 Loss of Feedwater Heating Revision 25

AOP 20.138.01 Recirculation Pump Trip Revision 47

AOP 20.138.02 Jet Pump Failure Revision 27

AOP 20.138.03 Uncontrolled Recirculation Flow Change Revision 16

MES 51 Preventive Maintenance Program Revision 16

MGA12 Fermi Employee Concerns Program Revision 3 MLS04 Operating Experience Program Revision 28 MMA07 Maintenance Conduct Manual, Chapter 7- Hoisting, Rigging and Load Handling Revision 20 MMR12 Equipment Out of Service Management Revision 17 MMR02 Maintenance Rule Conduct Manual Revision 5 MQA11 Condition Assessment Resolution Document Revision 39 MQA12 Root Cause Evaluations Revision 19 MQA13 Trending Revision 11 MQA13-100 CARD Trending Coding and Analysis Revision 0 MQA15 Apparent Cause Evaluations Revision 17 Revision 15 MQA18 Common Cause Analysis Revision 2 ODE11 CARD Operability/Reportability Determination Expectations Revision 17 Revision 16 ODE6 Operator Challenges Revision 14

Root Cause Evaluations

RCE 13-26398 Potential Unattended Pathway Discovered November 19, 2014

RCE 14-23163 Electricians Informed RTC of Oil Leak on Center Phase of Transformer 2B at 90% Power November 24, 2014

RCE 15-20129 2014 OSHA Injury Analysis March 10, 2015

RCE 15-20298 2015 Operations Training Assignment Tracking January 13, 2015

RCE 15-22090 Evaluate Reactor Scram from OPRM Upscale during Single Loop Operations March 21, 2015

RCE 15-24129 INPO Identified - Incomplete Alignment Between Root Cause and Effectiveness

June 11, 2015

Condition Reports

Generated for this Inspection

CARD 15-29683 E1100F012B Packing Leakage Identified During 2015 NRC PI&R Walkdown December 4, 2015 CARD 15-29729 2015 NRC PI&R Inspection Recommendations for ECP (Employee Concerns Program) December 7, 2015

CARD 15-29884 2015 NRC PI&R Inspection NRC Identified Issue:

Initial CARD 14-10011 Level Classification was Inappropriately Assigned December 11, 2015 CARD 15-29971 2015 NRC PI&R Inspection NRC Observation from SCWE Interviews December 15, 2015 CARD 15-30009 2015 PI&R Inspection Observation - Ops CARD Closed Without Procedure Change December 15, 2015 CARD 15-30054 2015 NRC PI&R Inspection Recommendations for ECP (Employee Concern Program) December 17, 2015 CARD 15-30075 Minor Revision to CARD 12-24725 Action Item 02 December 17, 2015 CARD 15-30077 2015 NRC PI&R Inspection Issue - Floor Plug Lift Not in Compliance with ASME B30.16 for Planned Engineered Lifts December 17, 2015 CARD 15-30098 2015 NRC PI&R Observation December 18, 2015 CARD 15-30125 2015 NRC PI&R Inspection Observation on Fermi Threshold for Generating Outgoing OE December 18, 2015 CARD 15-30220 10CFR50.65(a)(3) Assessment Recommendation: Evaluate Gaps in Incorporating OE into the PM

Program December 23, 2015

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

ASME American Society of Mechanical Engineers

CAP Corrective Action Program

CFR Code of Federal Regulations

CARD Condition Assessment Resolution Document

ECP Employee Concern Program

IMC Inspection Manual Chapter

NQA Nuclear Quality Assurance

NRC Nuclear Regulatory Commission

OE Operating Experience

PARS Publicly Available Records

RFP Reactor Feed Pump

PI&R Problem Identification and Resolution

SDP Significance Determination Process

P. Fessler -2-

Based on the results of this inspection, one

NRC identified finding of very low safety significance (Green) was documented in this report. The finding did not involve a violation of

NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement in this report, you should provide a response within 30 days of the date

of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region

III and the

NRC resident inspector at the Fermi-2.

In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS).]]

ADAMS is accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ Billy Dickson, Chief Branch 5 Division of Reactor Projects Docket No. 50-341 License No. NPF-43

Enclosure: Inspection Report No. 05000341/2015007 cc: Distribution via

LISTSE RV

ADAMS Accession Number:

ML 16032A591 Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFC [[]]

RIII [[]]

RIII [[]]

NAME RNg:bw BDickson

DATE 01/26/16 01/29/16

OFFICI AL

RECORD [[]]

COPY

Letter to Paul Fessler from Billy Dickson dated January 29, 2016

SUBJEC T: FERMI-2 -

NRC [[]]

PROBLE M IDENTIFICATION

AND [[]]

RESOLU TION INSPECTION REPORT 05000341/2015007