IR 05000341/2021002

Integrated Inspection Report 05000341/2021002

ML21216A213
Person / Time
Site:	Fermi
Issue date:	08/06/2021
From:	Nestor Feliz-Adorno Reactor Projects Region 3 Branch 4
To:	Peter Dietrich DTE Electric Company
References
IR 2021002
Download: ML21216A213 (23)

Text

August 6, 2021

SUBJECT:

FERMI POWER PLANT, UNIT 2 - INTEGRATED INSPECTION REPORT 05000341/2021002

Dear Mr. Dietrich:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2. On July 27, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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

Licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2 of the Enforcement Policy.

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

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

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Fermi Power Plant, Unit 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Feliz-Adorno, Nestor on 08/06/21 Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Docket No. 05000341 License No. NPF-43

Enclosure:

As stated

Inspection Report

Docket Number: 05000341 License Number: NPF-43 Report Number: 05000341/2021002 Enterprise Identifier: I-2021-002-0134 Licensee: DTE Electric Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Inspection Dates: April 01, 2021 to June 30, 2021 Inspectors: T. Briley, Senior Resident Inspector T. Taylor, Resident Inspector Approved By: Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Fermi Power Plant, Unit 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Licensee-identified non-cited violations are documented in report section: 71111.1

List of Findings and Violations

Multiple Hourly Fire Watch Tours Not Performed at the Emergency Diesel Generator 11, 12, and 13 Fuel Oil Storage Tank Rooms Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.05 Systems NCV 05000341/2021002-01 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) with an associated Non-Cited Violation (NCV) of Technical Specification (TS) 5.4.1, "Procedures," for the failure to perform multiple hourly fire watch tours at the EDG 11, 12, and 13 fuel oil storage tank rooms in accordance with Fire Protection Program procedures.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On May 15, 2021, the unit commenced a planned shutdown to address a steam leak in the reactor building steam tunnel.

Following completion of maintenance activities, the reactor was restarted and taken critical on May 22, 2021. The main generator was synchronized to the power grid on May 23, 2021. The unit returned to rated thermal power on May 24, 2021. The unit remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

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

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

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

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the following systems:

(1) Division 1 120 kV switchyard and Division 2 345 kV switchyard during the week ending June 30, 2021

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Standby feedwater (SBFW) system 'A' while SBFW system 'B' was out of service for planned maintenance during the week ending May 15, 2021

(2) Division 1 standby gas treatment (SBGT) system following planned maintenance and surveillance testing during the week ending May 15, 2021

(3) Division 1 core spray system while Division 2 core spray system was out of service for planned maintenance during the week ending June 19, 2021

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

(1) The inspectors completed an evaluation of system configuration during a complete walkdown of the reactor core isolation cooling (RCIC) system on June 30, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

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

(1) Residual heat removal (RHR) complex, emergency diesel generator (EDG) 11 engine room and fuel oil storage tank room during the week ending February 19, 2021

(2) RHR complex, EDG 12 engine room and fuel oil storage tank room during the week ending February 19, 2021

(3) RHR complex, EDG 13 engine room and fuel oil storage tank room during the week ending March 13, 2021

(4) Reactor building fourth floor, reactor recirculation motor generator set area during the week ending May 1, 2021

(5) Reactor building sub-basement, high pressure coolant injection pump room during the week ending May 1, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated fire brigade training and performance during an offsite live burn training scenario on June 25, 2021

71111.06 - Flood Protection Measures

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

The inspectors evaluated internal flooding mitigation protections in the:

(1) High pressure coolant injection (HPCI) room following identification of a degraded HPCI flood seal during the week ending May 15, 2021

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) P4400B001A heat exchanger on Division 1 emergency equipment cooling water (EECW)

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during shifting of reactor recirculation pump motor generator set ventilation fans during the week ending April 10, 2021

(2) The inspectors observed and evaluated licensed operator performance in the control room during a planned downpower evolution for a steam leak investigation in the reactor building steam tunnel on May 15, 2021

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training in the simulator on June 1, 2021

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Partial)

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

(1) (Partial)

General Electric HFA relays (multiple plant systems)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

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

(1) Emergent work on temporary in-core probes and associated risk assessment for scheduled local power range monitor testing and calibration during the week ending May 1, 2021

(2) Emergent work to diagnose and repair separator seal tank level issue during the week ending May 1, 2021

(3) Emergent work to diagnose and repair an underground cable fault that resulted in loss of 13 kV tag line and control power to transformer 1 in the Division 1 120 kV switchyard

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)

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

(1) Operability and functionality of the alternate diesel fire pump with less than design discharge flow, as documented in CARDs 21-21167 and 21-21704

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

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

(1) Emergency core cooling system (ECCS) reactor water level 2 relay (B21K202C)testing following relay replacement during the week ending April 17, 2021

(2) EDG 11 testing following an overspeed reset failure during the week ending May 8, 2021

(3) East turbine bypass valve testing following failure to properly open during the week ending May 22, 2021

(4) Division 1 control complex heating ventilation and air conditioning (CCHVAC) chiller adjustments following high oil temperature trip during the week ending June 12, 2021

(5) Reactor core isolation cooling steam line outboard containment isolation valve (E5150F008) testing following packing leak repairs during the week ending June 30, 2021

(6) Reactor protection system 'B' system testing following electrical protection assembly breaker repair during the week ending June 30, 2021

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated mid-cycle outage activities associated with a reactor building steam tunnel steam leak from May 16, 2021 to May 23, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Main steam isolation valve and turbine stop valve testing during the week ending May 29, 2021

(2) Local power range monitor testing with degraded in-core probe system during the week ending June 30, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Standby gas treatment system valve operability test during the week ending May 8,

OTHER ACTIVITIES - BASELINE

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

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Unit 2 (April 1, 2020 - March 31, 2021)

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

(1) Unit 2 (April 1, 2020 - March 31, 2021)

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) Unit 2 (April 1, 2020 - March 31, 2021)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

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

INSPECTION RESULTS

Multiple Hourly Fire Watch Tours Not Performed at the Emergency Diesel Generator 11, 12, and 13 Fuel Oil Storage Tank Rooms Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.05 Systems NCV 05000341/2021002-01 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) with an associated Non-Cited Violation (NCV) of Technical Specification (TS) 5.4.1, "Procedures," for the failure to perform multiple hourly fire watch tours at the EDG 11, 12, and 13 fuel oil storage tank rooms in accordance with Fire Protection Program procedures.

Description:

On February 8, 2021, the licensee initiated fire impairment 2021-0028 after identifying a degraded alternate diesel fire pump (ADFP). The ADFP had just been installed as a backup system to a non-functional permanently installed diesel fire pump. The ADFP was degraded because it produced less than the required design flow rate due to a pump suction configuration problem. The licensee performed a fire protection engineering evaluation (i.e.,

FPEE 21-0003) of the fire water suppression system with the ADFP degraded flow rate and determined the minimum sprinkler system flow in several plant locations could not be met if the ADFP was placed in service without the electric fire pump. These locations included the Division 1 EDG 11 and EDG 12 fuel oil storage tank rooms (two physically separate spaces)and the Division 2 EDG 13 fuel oil storage tank room. The compensatory fire impairment specified hourly fire watch tours in those locations until the ADFP pump was fully capable of producing the fire water suppression system design flow rate. Licensee procedure MOP 11-100, Fire Protection System Implementation, Revision 7, step 4.4.1 stated, "an hourly fire watch is a tour of all items/areas on the Out of Specification Log Sheet. These tours are to be performed within a one-hour period and will begin approximately on the hour and terminate before the next hour. Tours will terminate in the control room."

The inspectors performed a historical review of the key card reader data for each affected location. They noted several hourly fire watches where it appeared the individual assigned fire watch duties did not enter the location as needed to perform the fire watch tours of the EDG 11, 12, and 13 fuel oil storage tank rooms. Subsequent investigation by the licensee confirmed four fire watch tours (i.e., February 19, 2021, 3:00 p.m. for Division 1 EDG 11 and 12 fuel oil storage tank rooms and 6:00 p.m., 7:00 p.m., and 8:00 p.m. for Division 2 EDG 13 fuel oil storage tank room) were inadvertently not performed. The inspectors also noted multiple fire watch tours that had questionable tour performance completion times.

Specifically, the inspectors questioned the licensee on the feasibility of traversing to the specified rooms given the tour completion times as indicated by key card reader history. The licensee investigated the questionable times and determined a programmatic fire watch implementation problem existed. Specifically, multiple individuals assigned fire watch duties were not performing the tours properly. These improper tours were generally the result of personnel going to the incorrect location. For example, some individuals walked down the EDG 13 engine room instead of the assigned EDG 13 fuel oil storage tank room. The licensee determined multiple assigned fire watch personnel did not thoroughly review or have the written list of assigned fire watch tour locations in hand while in the field, did not fully utilize available human performance practices for verification, and performed less than adequate turnovers discussing assigned fire watch duties and programmatic responsibilities.

It was also determined that fire watch training and procedural guidance did not specify how to perform a fire watch tour once an individual arrived at the correct location (e.g., what to look for and how extensive of a room walkdown is to be performed based on the type of fire impairment). The inspectors noted that multiple divisional fire watch tours were not performed at the specified locations based on independent inspector time trials and data analytics of the key card reader time stamps for the assigned fire watch personnel between February 8, 2021 and February 25, 2021.

Corrective Actions: The licensee corrective actions included, but were not limited to, development of a new fire protection procedure that specified specific fire watch roles and responsibilities, including how to properly conduct an hourly fire watch tour; additional supervisory checks and balances to ensure fire watch tours are being properly performed; and enhancements to fire watch turnovers, including utilization of a copy of the specified fire watch location paperwork.

Corrective Action References: CARD 21-22547

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's failure to perform hourly fire watch tours at the EDG 11, 12, and 13 fuel oil storage tank rooms was contrary to revision 7 of procedure MOP11-100 and was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform multiple hourly fire watch tours as a compensatory measure for the degraded fire water suppression system does not ensure the EDGs 11, 12, and 13 would remain available to perform their accident mitigating function.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC)0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.4.2, Fixed Fire Protection Systems, the inspectors determined that the finding was of very low safety significance (i.e.,

Green). Specifically, the degraded AFDP did not adversely affect the ability of the fixed fire protection system to protect any equipment important to safe shutdown. The electric fire pump was available (and starts first on lowering fire water suppression system header pressure) to provide full design flow for the duration of the compensatory fire watches.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, assigned fire watch personnel did not use human performance practices for task execution and verification, and turnovers.

Enforcement:

Violation: Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. The licensee established MOP11-100, "Fire Protection System Implementation," Revision 7 as a fire protection program implementation procedure. Step 4.4.1 of this procedure was applicable for implementation of compensatory fire watches. It stated "an hourly fire watch is a tour of all items/areas on the Out of Specification Log Sheet. These tours are to be performed within a one-hour period and will begin approximately on the hour and terminate before the next hour.

Tours will terminate in the control room."

Contrary to the above, from February 8, 2021 to February 25, 2021, the licensee failed to implement written procedures covering fire protection program implementation. Specifically, the licensee included the EDG 11, 12, and 13 fuel oil storage tank rooms in the Out of Specification Log Sheet. However, the licensee did not perform multiple hourly fire watch tours on these locations. On February 19, 2021, the 3:00 p.m. assigned fire watch did not enter the Division 1 EDG 11 and 12 fuel oil storage tank rooms. Similarly, on February 19, 2021, the 6:00 p.m., 7:00 p.m., and 8:00 p.m. assigned fire watch did not perform the Division 2 EDG 13 fuel oil storage room tour. In addition, multiple hourly fire watches between February 8, 2021, and February 25, 2021, were not performed by the assigned hourly fire watch in the Division 1 EDG 11 and 12 fuel oil storage tank rooms and Division 2 EDG 13 fuel oil storage tank room based on performance completion times that were determined not to be feasible (i.e., could not reasonably get to the specified rooms in the logged completion times).

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

Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation.

Contrary to the above, from April 30, 2007, to February 8, 2021, the licensee did not maintain written procedures covering fire protection program implementation. Specifically, the licensee established 28.504.03, Fire Suppression Water System Simulated Automatic Actuation Test, as a fire protection program implementing procedure. It contained acceptance criteria for electric fire pump, diesel fire pump, and alternate diesel fire pump (when installed as a temporary backup system) water flow and discharge pressure to verify that the water supply for the fire suppression water systems were consistent with plant design calculations. Design Calculation 5713 Volume 1, Hydraulic Evaluation of the Fire Distribution Loop, established the acceptance criteria to meet various regulatory and National Fire Protection Association (NFPA) code requirements. However, revisions 18 through 30 of procedure 28.504.03 did not have its acceptance criteria revised when the acceptance criteria derived by revision C of Design Calculation 5713 was revised with more restrictive values.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.4.3 Fire Water Supply, the inspectors determined that the finding was of very low safety significance (i.e., Green). Specifically, adequate fire water capacity was still available for protection of equipment important to safe shutdown in the most limiting location onsite as one or more fire pumps met the applicable acceptance criteria values based on review of surveillance record history.

Corrective Action References: CARD 21-21583 Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: License condition 2(C)(9), Modifications for Fire Protection, states, in part, DTE Electric Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR).

Contrary to the above, from February 7, 2021, to February 24, 2021, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR. Specifically, Updated Final Safety Analysis Report (UFSAR) section 9.5.1.1, Fire Protection Program Design Basis, states, in part, the Fermi 2 fire protection system was designed and developed using National Fire Protection Association (NFPA)standards. UFSAR section 9.5.1.1.2, Codes and Standards, references NFPA 20 (1970 edition), Standard for the Installation of Centrifugal Fire Pumps, as a code and standard used for guidance in the design of the fire protection system. UFSAR 9.5.1.2.1 states the fire pumps meet the intent of NFPA 20. NFPA 20 (1970 edition), section 143.l, Suction Connections, states, in part, suction inlets should be at least 12 inches above the bottom of sump or suction well to avoid obstruction. However, the alternate diesel fire pump (ADFP)suction inlet was installed on the bottom of the general service water pump pit. This resulted in degraded ADFP discharge flow rates requiring compensatory actions.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.4.3 Fire Water Supply, the inspectors determined that the finding was of very low safety significance (i.e., Green). Specifically, adequate fire water capacity was still available for protection of equipment important to safe shutdown in the most limiting location onsite, despite the degraded ADFP discharge flow, as the electric fire pump remained available to meet full system design parameters.

Corrective Action References: CARD 21-21704 Observation: Semiannual Trend Review 71152 The inspectors identified a negative trend in the thoroughness of the licensee's review of several operational issues. The inspectors also noted a number of human performance issues over the last several months that were, in part, attributed to a lack of attention to detail, and/or complacency. While some issues were identified by the licensee as they occurred, others were identified by the inspectors as they performed an independent review. Examples included but were not limited to:

The inspectors identified that an Engineering Functional Analysis (EFA) for a degraded flooding seal in the high pressure coolant injection pump room established a compensatory measure that did not support operability. The licensee subsequently implemented an appropriate compensatory measure. Further, the inspectors identified the licensee incorrectly assumed a normal shutdown would commence versus a reactor scram per licensee emergency procedures when determining the time water would reach a certain height after a hypothetical torus rupture. This error did not affect the outcome of the evaluation. The inspectors did not identify a violation of regulatory requirements associated with this example.

The licensee performed a past operability evaluation for a violation associated with the improper storage of nitrogen bottles documented in NRC inspection report 05000341/2021001 (ADAMS Accession: ML21124A128) as NCV 05000341/2021001-01. However, the inspectors identified that the licensee evaluation of an affected location was an existing analysis performed on a different plant location that was not applicable for the operability evaluation. This error did not affect the outcome of the evaluation. The inspectors did not identify a violation of regulatory requirements associated with this example.

The licensee, at times, maintained a door to the steam tunnel from the reactor building first floor open in Mode 1. The licensee maintained the door open when personnel were inside the area investigating elevated area temperatures in the reactor building steam tunnel. The door served several functions, which included a high-energy-line-break (HELB) barrier. However, the inspectors noted the licensee did not evaluate the impact of maintaining the door open on its function. After questioning by the inspectors, the licensee determined that maintaining the door open for reasons other than momentary transit constituted an unanalyzed condition. As a result, the licensee submitted an eight-hour non-emergency event notification to the NRC (EN 55231) and a corresponding license event report (LER 2021-001-00). The inspectors plan to perform additional review of the circumstances discussed in the event report.

Air-operated valve T4600F407 had a function to isolate the non-safety-related reactor building ventilation system from the safety-related standby gas treatment system (SBGT). It failed to stroke closed during a planned surveillance test. The licensee replaced an air cylinder and some internal components on the actuator. The licensee did not perform a post-maintenance test to verify proper operation of the valve and left it in the open position with the pneumatics to close the valve isolated. The licensee stated they were concerned that if the valve failed to reopen during testing or was inadvertently closed, the operability of both divisions of SBGT could be impacted.

However, the inspectors noted that, while the valve was failed into its safety position to support SBGT system operability, it had a required FLEX function to close during beyond-design-basis events to vent primary containment. While the licensee had concluded pneumatics could be restored during a beyond-design-basis event, the inspectors identified the condition was not documented per site procedure MOP25, "Beyond-Design-Basis Event Coping Strategies Program Document," as a condition affecting hardened vent capability for in excess of 30 days. Additionally, the licensee later determined their initial assessment of the impact on the SBGT system was incorrect, in that failure of the valve to open would impact only one division of the SBGT system. The valve was subsequently successfully tested. The inspectors did not identify a violation of regulatory requirements associated with this example.

EXIT MEETINGS AND DEBRIEFS

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

On July 27, 2021, the inspectors presented the integrated inspection results to Mr. P. Dietrich, Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 21-22519 3 Ceramic Insulators Missing Parts 03/21/2021

Documents 21-25739 Breaker A7 open (Bus 1-2B) Overcurrent on X Phase 06/29/2021

Miscellaneous Main Turbine S1100 Main Turbine Generator Transformers System Health 05/03/2021

Generator Report 1Q2021

Transformers

S2000 345kV 345kV Switchyard System Health Report 1Q2021 05/03/2021

Switchyard

Procedures MWC16-100 Seasonal Readiness 2

71111.04 Corrective Action 21-25340 NRC Identified E2100-F010A Missing Handwheel Stem Nut 06/16/2021

Documents

Resulting from

Inspection

Drawings 6M721-2034 Diagram Core Spray System AS

6M721-2044 Reactor Core Isolation Cooling System BE

6M721-2045 Reactor Core Isolation Cooling (RCIC) System Barometric AT

Condenser

6M721-2709 Standby Gas Treatment and Primary Containment Purge AI

System Reactor Building

6M721-5083 Piping and Instrument Diagram Standby Feedwater System U

6M721-5737 Standby Gas Treatment System AA

Procedures 23.107.01 Standby Feedwater System 45

23.203 Core Spray System 70

23.206 Reactor Core Isolation Cooling System 105

23.404 Standby Gas Treatment System 60

71111.05 Corrective Action 16-29844 Expectations for Fire Watch Rounds Requires Clarification 12/11/2016

Documents and Documentation

20-28405 Fire Brigade Annual Live Burn Requirement Will go Overdue 07/20/2020

due to COVID-19 on 8/22/2020

21-22116 Door Modified 03/08/2021

21-23702 Water-Tight Penetration 04/27/2021

Corrective Action 21-22547 Failure to Compensatory Fire Watch Inspections - NRC 03/22/2021

Documents Identified

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from 21-23889 Several Sprinklers in Close Proximity to HVAC Ducting - 05/04/2021

Inspection NRC Identified

21-24760 NRC Question - Extent of Condition Review for Modified 05/31/2021

Door (RHR - D26)

Drawings 6A721-2351 Reactor and Auxiliary Building Sub-Basement Walls M

6A721-2401 Fire Protection Evaluation Reactor Building Sub-Basement L

6M721N-2027 General Arrangement RHR Complex Grade Floor Plan I

A-N-2641 Fire Protection Residual Heat Removal Complex Floor Plan 0

EL. 590'-0"

Fire Plans FP-RB-4-17b Reactor Building Recirculation System Motor Generator 5

Area, Zone 17, Elevation 659'6"

FP-RB-SB-4a High Pressure Coolant Injection Pump and Turbine Room, 5

Zone 4

FP-RHR-1-11- RHR Complex, EDG 11 Room, El. 590'-0" 5

EDG

FP-RHR-1-11-OS RHR Complex, EDG 11 Oil Storage Room, El. 590'-0" 5

FP-RHR-1-12- RHR Complex, EDG 12 Room, El. 590'-0" 7

EDG

FP-RHR-1-12-OS RHR Complex, EDG 12 Oil Storage Room, EL. 590'-0" 4

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

EDG

FP-RHR-1-13-OS RHR Complex, EDG 13 Oil Storage Room, El 590'-0" 4

FPEE-05-0020 NFPA 13-1980 Non-Compliances for Several Sprinkler 2

Systems

Procedures 23.501.01 Fire Water Suppression System 64

28.507.03 Fire Door Inspection - BOP 34

35.000.242 Barrier Identification and Classification 58

MOP11-100 Fire Protection Implementation 7

71111.06 Calculations DC-4689 Flood Depth in the Torus Room Assuming a Torus Rupture A

Corrective Action 21-23702 Water-Tight Penetration 04/27/2021

Documents 21-23890 Tracking CARD for EFA-E41-21-03, High Pressure Coolant 05/04/20201

Injection Wall Penetration Gap, Comp Measure

21-23932 Potential Confusion Associated with Operability 05/05/20201

Determination of CARD 21-23702

Inspection Type Designation Description or Title Revision or

Procedure Date

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

71111.07A Corrective Action 19-24051 Recommend Scheduling Swap of the Division 1 EECW Heat 05/28/2019

Documents Exchangers

19-27521 Unexpected Increase in Division 1 EECW Heat Exchanger 10/03/2019

Differential Pressure After Recent Swap

20-29940 Division 1 EECW Plat/Frame Hx Cleaning WO Scope 09/03/2020

Deleted and Rescheduled Numerous Times

Miscellaneous Heat Exchanger EECW Division 1 Plate Frame Hx, WO 54099224 03/01/2021

Inspection Report

VMB9-37 Alfa Laval MX25-BFD Plate Heat Exchanger Instruction A

Manual

Work Orders 54099224 Clean EECW Division 1 'A' Plate Type Heat Exchanger 03/02/2021

71111.11Q Miscellaneous Training Change Simulator Lesson Plan 0

Request SS-OP-

2-2066

Training Change Simulator Lesson Plan 0

Request SS-OP-

2-2068

Procedures 20.107.02 Loss of Feedwater Heating 26

2.000.03 Power Operation 25% to 100% to 25% 106

29.100.01 SH 1 RPV Control 18

29.100.01 SH 1A RPV Control - ATWS 17

71111.12 Corrective Action 21-24863 E4150F042 Valve Slow to Open During 44.030.153 06/03/2021

Documents

Corrective Action 21-25339 Response to NRC Question Regarding HFA Relays Extent 06/16/2021

Documents of Condition

Resulting from

Inspection

Procedures 35.318.017 Inspection and Testing of Multi-Contact Auxiliary Relays 53

71111.13 Corrective Action 21-21105 TIP 'D' Squib Valve Partial Discharge During 02/04/2021

Documents Troubleshooting

21-23548 Air Line Disconnected on N22F414B Causing the Valve to 04/21/2021

Fail Open

21-23562 I/V Curve Unsuccessful I/V Curve on TIP 'E' 04/22/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

21-25739 Breaker A7 Open (Bus 1-2B) Overcurrent on X Phase 06/29/2021

Drawings SD-2500-01 One Line Diagram Plant 4160V & 480V System Service CD

SD-2500-02 One Line Diagram 13.8 kV BE

Miscellaneous ODE-2 Operations Evolution Order 20

Risk Management TIP Detector Isolation 04/22/2021

Plan

71111.15 Calculations DC 5713 Volume Hydraulic Evaluation of the Fire Distribution Loop C-F

Corrective Action 21-21167 Alternate Diesel Fire Pump Flow Concern 02/07/2021

Documents 21-21191 Alternate Diesel Fire Pump Did Not Achieve 2500 gpm @ 02/08/2021

150 psig

21-21250 Indications of a Partially Plugged Suction Line During 02/10/2021

Alternate Diesel Fire Pump Run

21-21583 Investigation into TRSR 3.12.2.13 02/18/2021

21-21704 Suction Hoses Installed Beyond Expected Depth 02/23/2021

Procedures 28.504.03 Fire Suppression Water System Simulated Automatic 18-30

Actuation Test

71111.19 Corrective Action 13-24513 EDG 13 Overspeed Trip Alarm During Standby Checks 06/24/2013

Documents 17-23166 Recommend Enhancement on EDG Overspeed Switch 04/06/2017

21-22187 EDG 11 Overspeed Will Not Reset 03/09/2021

21-23248 Contacts Slow to Close 04/13/2021

21-24247 T100B009 Division 1 CCHVAC Chiller Trip 05/14/2021

(MCR Alarm 8D5)

21-24290 Leak Walkdown - Valve Packing Leak on E5150F008 "RCIC 05/16/2021

Turbine Steam Supply OTBD CNTM ISO MOV"

21-24307 CCHVAC EIT Request Spec Sheet Change to Adjust 05/16/2021

Division 1 CCHVAC Oil Cooler Set Point

21-24355 N1100F059A MS East Bypass Valve Discrepancies During 05/17/2021

24.109.02

21-24365 NQA - Forced Outage 21-01 Contingency Work Order 05/18/2021

221325 - Replace Heat Stressed Cables to E5150008

Was Not Routed to QA for Review

21-24383 Leadership Gap - Maximum Appropriate Involvement Not 05/18/2021

Achieved During Evaluation of E5150F008 MOV As-Found

Inspection Type Designation Description or Title Revision or

Procedure Date

Conditions

21-24386 E5150F008 As-Found Condition FO 2021-01 05/18/2021

21-24416 Work Order Revision Recommended 05/19/2021

21-24430 Trip of RPS B, 'B' EPA Breaker Tripped Causing Loss of 05/18/2021

RPS B

21-24511 Failed PMT During EPA B Channel Functional - 61260479 05/21/2021

Drawings 6I721-2095-29 NBS ANN Inputs and Relay Tabulation Testability AH

Modification

6I721-2151-02 Reactor Protection System Motor Generator Set B Z

6M721-4325 Water, Side and Miscellaneous Chiller Inst. Control Center AG

A/C System Reactor Building

AMD-4312 Elec Protection Assembly F

Miscellaneous ACMP 21-07 Division 1 CCHVAC Chiller 0

LCO 2021-0178B Operations Log 0

VMS25-49 Centrifugal Water Chillers L

Procedures 24.109.02 Turbine Bypass Valve Operability Test 37

44.30.253 ECCS - Reactor Vessel Water Level (Levels 1, 2, and 8), 57

Division 1, Channel C Functional Test

Work Orders 43041256 Contingency Work Order Requested for 44.030.253; Level 1, 08/13/2015

2, and 8 Channel C Functional

210452 Received 8D5 Division 1 Control Room A/C Trouble in the 05/14/2021

MCR

217916 Received D5 Division 1 Control Room A/C Trouble in the 05/15/2021

MCR

221106 E5150F008 Damage to Valve Stem 05/17/2021

222390 Install Monitoring Equipment and Adjust Lube Oil Pressure 05/17/2021

249461 N1100F059A MS East Bypass Valve Discrepancies During 05/19/2021

24.109.02

71111.20 Corrective Action 21-24268 Water Leaks Identified from Three Drywell Penetrations 05/15/2021

Documents 21-24276 TB2 Steam Tunnel 05/15/2021

21-24277 Steam Leak Noted in TB2 Steam Tunnel, N2200F64 05/15/2021

21-24278 Steam Leak Noted in TB2 Steam Tunnel, N200F349 05/15/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

21-24302 Main Turbine Generator Rubbing Observed During Coast 05/16/2021

Down After Trip

21-24303 Control Rod 06-27 Over Inserted During Scram 05/16/2021

21-24374 Request Work Order to Support Transducer Calibration 05/18/2021

Check of MTG Instrumentation

21-24386 E5150F008 As-Found Condition FO 2021-01 05/18/2021

21-24494 Untimely Issue Resolution and/or Poor Communications 05/21/2021

Associated with G3352F220 Results in Increased Dose and

Radiological Risk

21-24506 Untimely Identification of Issues in Corrective Action 05/21/2021

Program and to OCC

Corrective Action 21-24360 NRC Concern 05/17/2021

Documents

Resulting from

Inspection

Engineering FPEE-02-0020 Fire Barrier Evaluation for Turbine Building Steam Tunnel 0

Evaluations Penetration Seals to the Torus Room Ceiling

Miscellaneous Reactivity FO 21-01 Reactor Startup 0

Maneuvering

Plan

Procedures 22.000.04 Plant Shutdown from 25% Power 89

2.000.05 Pressure and Temperature Monitoring During Heat up and 53

Cooldown

23.205 Residual Heat Removal System 148

23.623 Reactor Manual Control System 75

54.000.01 Shutdown Margin Check 36A

71111.22 Corrective Action 20-29133 TIP 'E' Flux Lower than Expected on TIP Run 08/09/2020

Documents 21-22988 T4600F407 Failed to Stroke During 24.404.03 04/04/2021

21-23507 TIP 'E' Signal Cable TDR and Detector I/V Curve Tests 04/21/2021

Reveal TIP 'E' Detector is Functional

21-23754 Unexpected Message Received from 3DMonicore When 04/28/2021

Reprocessing TIPs

Drawings D-35730 Assembly Drawing T4XXB-SR (CW) and T4XXB-SR (CW) - J

M3

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous T4600-000149 Configuration Control of T4600F407 due to Failing to Stroke 05/04/2021

Closed During Surveillance Test 24.404.03

Procedures 23.206 Traversing In-Core Probe (TIP) System 39

24.110.05 RPS - Turbine Control and Stop Valve Functional Test 48

29.FSG.13 FLEX Containment Venting 6

54.000.05 LPRM Calibration 53

MOP 25 Beyond-Design-Basis Event Coping Strategies Program 8

Document

71151 Miscellaneous Fermi 2 EDG MSPI and WANO Performance Indicators 04/2020 -

03/2021

Fermi 2 HPCI Performance Indicators 04/2020 -

03/2021

RCS Leakage Data 2020

RCS Leakage Data 2021

MSPI Mitigating Systems Performance Index (MSPI) Basis 8

Document

Procedures 24.000.02 Shiftly, Daily, and Weekly Required Surveillances 159

71152 Corrective Action 21-22988 T4600F407 Failed to Stroke During 24.404.03 04/04/2021

Documents 21-23702 Water-Tight Penetration 04/27/2021

21-23782 Crew Learning Opportunity, Incorrect Clearance Authorized 04/29/2021

for Work (Level 4 Tagging Issue)

Corrective Action 21-23235 NRC Identified: Inadequate Communications Results in 04/12/2021

Documents Revision to Technical Evaluation (TE-A30-21-005) for Past

Resulting from Operability of N2 Bottle Rack

Inspection 21-23817 NRC Concerns Regarding Steam Tunnel Entries 04/30/2021

Miscellaneous CLO Worksheet 21-23703 MCR Received 17D21 Division 2 SGTS CO2 04/27/2021

Storage Vessel Press High/Low

Work Orders 46479459 Replace Defective Terminal Blocks at T46P408B 04/27/2021

20