IR 05000341/1986036

Insp Rept 50-341/86-36 on 861113-870114.No Violations or Deviations Noted.Major Areas Inspected:Startup Test Phase Result Evaluation & Verification & Changes in Startup Test Phase Program

ML20210S284
Person / Time
Site:	Fermi
Issue date:	02/06/1987
From:	Dupont S, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210S228	List: IR 05000341/1986036 ML20210S224
References
50-341-86-36, NUDOCS 8702170597
Download: ML20210S284 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/86036(DRS)

Docket No. 50-341 License No. NPF-43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48224 Facility Name: Fermi 2 Inspection At: Fermi 2 Site, Monroe, Michigan Inspection Conducted: November 13, 1986 through January 14, 1987 Inspectof:S& 'WQQ $

S. G. DuPont s/r/97 l

Date/ [

Q &n/Al Approved By: G. C. Wright, ief Test Programs Section

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Date 8h[b Inspection Summary Inspection on November 13, 1986 through January 14, 1987 (Inspection Report No. 461/86036(DRS))

Areas Inspected: Startup test phase result evaluation, startup test phase result verification, and changes in startup test phase progra Results: No violations or deviations were identified.

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~ DETAILS 2 ' Persons Contacted

• + W.~ Shields,~ Startup' Test Director

. G. J. Debner,-Startup Engineer

• F. H. Sondgeroth, Licensing Engineer The inspector also met 'with members of the' engineering and startup staf * Denotes those attending the exit meeting on November 19, 1986.-

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+ Denotes those attending the exit meeting via telecommunications on January 14, 198 . Startup Test Phase Result Evaluation .

The inspector reviewed the following startup test results.to ascertain that the acceptance criteria and testing requirements of Chapter 14 of the FSAR were met and that the testing objectives of Regulatory Guide 1.68,-

Technical Specifications and the operating license were also me ,

STUT.0VB.005, ." Control Rod Drive System '- Friction Testing" STUT.0VC.005, " Control Rod Drive System Scram Timing" STUT.HUA.005, " Control Rod Drive System - Insert / Withdraw Timing" STUT. HUB.005, " Control Rod Drive System - Friction Testing" STUT.HUC.005, " Control Rod Drive System - Scram Timing (Sequence B)"

STUT. HUE.005, " Control Rod Drive System - Scram Timing (Sequence A)"

STUT.010.005, " Control Rod Drive System - Planned Reactor Scram Timing Data-(4 Rods)"

STUT.HUA.011, "LPRM Calibration - Flux Response Verification" STUT.01B.011, "LPRM Calibration - BUCLE Determination" STUT.HUA.012, " Average Power. Range Monitor'(APRM) Calibration -

Heatup Rate Determination" STUT.018.012, "APRM Calibration - Process Computer Determination"

.STUT.HUA.014,"RCICSystem-1000PSIGHotCST' Injection" STUT. HUB.014, "RCIC System - 1000 PSIG Hot CST Injection (Extended

' Operation)"

STUT.HUC.014,'"RCICSystem-150PSIGHotCSTInjection" STUT.HUD.014, "RCIC System - 150 PSIG Vessel Injection" STUT. HUE.014, "RCIC System - 150 PSIG Cold CST Injection" STUT.01F.014, "RCIC System - 1000 PSIG Hot Vessel In-STUT.01G.014,"RCICSystem-ColdVesselInjection"jection" STUT.01J.014, "RCIC System - Cold Vessel Injection (Second Run)"

STUT.01A.019, " Core Performance - Bucle Determination" STUT.HUA.023, "Feedwater System - Startup LCV Testing" STUT.01A.023, "Feedwater System - Startup LCV Testing STUT. HUB.025, "MSIV Functional Test - 10% Slow Closare" STUT.HUO.026, " Relief Valve Testing" STUT.01A.028,' " Shutdown From Outside Control Rcom - Hot Shutdown Demonstration" No violations or deviations were identifie . .

3. ' Startup Test Phase Results Verific_ation The inspector verified that the following startup test results were reviewed and accepted by the licensee in accordance with the requirements

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of the Startup Manu 1, Regulatory Guide 1,68 and the Quality Assurance Manual:

STUT.0VA.002, " Radiation Measurements" STUT.HUA.002, " Radiation Measurements" STUT.HUA.006, " Source Range Monitor (SRM) Performance and Control Rod Sequence - Initial Criticality" STUT.HUD.006, "SRM Performance and Control Rod Sequence A" STUT.018.006, "SRM Performance and Control Rod Sequence B" STUT.01C.006, "SRM Performance and Control Rod Sequence A" STUT.HUA.010 "IRM Performance - SRM/IRM Overlap" STUT. HUB.010, "IRM Performance - Range 6/7 Overlap" STUT.01C.010, "IRM Performance - IRM/APRM Overlap" STUT.01B.013, " Process Computer - TIP Interface Checkout" STUT.HUA.015, "HPCI System - 1000 PSIG Hot CST Injection" STUT.h0B.015, "HPCI System - Hot CST Injection (Extended Operation)"

STUT.HUC.015, "HPCI System - 150 PSIG CST Injection" STUT.HUD.015. "HPCI System - Cold CST Injection" STUT.HUA.016 " Selected Process Temperatures" STUT. HUB 016 " Selected Process Temperatures" STUT.HUA.017, " System Expansion - Visual Inspection" STUT. HUB.017, " System Expansion - Sensor Readings" STUT.HUC.017, " System Expansion - Cooldown Sensor Readings" STUT.010.022, " Pressure Regulator" STUT.HUA.070, " Reactor Water Cleanup System (RWCU)"

STUT. HUB.070, "RWCU - Bottom Head Flow Calibration" STUT.HUA.071, " Residual Heat Removal System" No violations or deviations were identifie . Startup Test Phase Program Changes The inspector reviewed the licensee's proposed startup test phase program changes contained in their letter of October 17, 1986, which submitted required Safety Evaluation Sumaries (50.59 reviews) for each chang The submittals are required by the Fermi 2 License, Condition No. 2.C(14).

The proposed changes were in two parts. The first part pertained to revising or deleting eight startup tests while the second part pertained to extending the power range for acceptance of testing during Tes Condition No. 6 (100% rated power at 100% recirculation flow). The extended range would allow Detroit Edison to extrapolate the test results from a lower power level (7 70% rated) to the higher power condition (100% rated) should an inaifvertent turbine / generator trip, full MSIY isolation, or recirculation pump run back occur at a power level less than 100% rated. The inspector fcund that the proposed changes were acceptable, with the exception of the extended power range for Test Condition No. _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ - _ ____- _-

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Provide below is a brief description of the proposed changes to the existing startup tests and the justification for acceptability: Startup Test 1 (FSAR Section 14.1.4.8.1), Test Procedure STVT.000.001,

" Chemical and Radiochemical." Detroit Edison proposes deletion of the testing during Test Condition No. 5 without Reactor Water Cleanu The deletion is based upon repeating the test objectives during Test Condition No. 6 since the ability of the systems to adequately manage coolant chemistry will be demonstrated at the most demanding plant operation condition (rated power /and ficw). Review of the Test Condition No. 6 test and Detroit Edison's Safety Evaluations (10 CFR 50.59) provide adequate justification that this deletion is acceptable, Startup Test No. 16 (FSAR Section 14.1.4.8.16), Test Procedures STUT.030.018 and STVT.060.018, " Core Power Distribution - TIP Uncertainty" scheduled during Test Conditions No. 3 and 6. Detroit Edison's proposed deletion of the TIP uncertainties is based upon the last 23 test results perfonned at 10 BWR plants. The criteria for the test is less than 6% total uncertainty. The collected test results showed that gecretric uncertainties were between 0.7% and 4.80% and random uncertainties were between 0.617 and 1.54%, with the total uncertainties between 1.14% and 4.86%. Based upon this data and Detroit Edison's Safety Evaluation, deletion of STUT.030.018 and STUT.060.018 is acceptabl Startup Test No. 19 (FSAR Section 14.1.4.8.19), Test Procedures STUT.040.021 and STUT.050.021, " Core Power Void Mode Respcnse,"

scheduled during Test Conditions No. 4 and 5. Detroit Edison's proposal to delete these tests is based on the Safety Evaluation that den.onstrated that the test objective of verifying system stability by control rod movement is not representative of a large reactor core, such as Fermi, and that testing during Test STUT.050.022, " Pressure Regulator" wculd measure core wide response from pressure disturbances and as such would be representative of system response and stability. Review of Detroit Edison's Safety Evaluation demonstrated that control rod movement would only result in small local void response compared to the void response (core wide) that would be demonstrated frcm pressure disturbances provided during test STUT.050.022. This is acceptable since the data collected during STUT 050.022 would be niore meaningful than STUT.040.021 and STUT.050.021 data, and as such would cenonstrate core wide stability, Startup Test No. 20 (FSAR Section 14.1.4.8.20), Test Procedure g STUT.040.022 and STUT.050.022, " Pressure Regulator." Detroit Edison's proposal is to delete STUT.040.022 and revise STUT.050.022. The basis for deleting STUT.040.022 during Test Condition No. 4, is that overlap data is collected in Test Conditions No. 2, 3, 5, and 6 for control valve and bypass valve setpoints to demonstrate the stability of the pressure regulator during step changes and to verify operability of backup pressure regulator during failure of the primary pressure regulato _ - _ _ _ _ - - - - - - - - - _-

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Revising STUT.050.022 involved deleting the b"ackup pressure regulator portion only. This revision is based upon adequate and repeated demonstration of the capability of the backup pressure regulator during Test Conditions No. 2, 3, and 6. Also the test

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conditions bound or overlap Test Condition No. 5. Both of these changes, deletion of STUT.040.022 and revising STUT.050.022-by deleting the backup, pressure regulator portion are acceptable. In the revision to STUT.050.022 was verified not to affect-addition,fication thejusti for deletions-of STUTs .040.021 and 050.021 in-startup test No. 1 Startup Test No. 21 (FSAR Section 14.1.4.8.21),' Test-Procedure STUT.04B.023, "Feedwater System." Detroit Edison's' proposal is to delete the feedwater system testing during Test Condition No. 4 (TC 4)' based upon testing scheduled during Test Conditions No. 2,'3, 5, and 6 which bounds the power level during Test Condition No. ThisisacceptablesincethetestobjectiveofSTUT.04B.023isto maintain the mass balance of the reactor vessel (steam out and feedwater into the vessel-to maintain mass or vessel level) and the power level of-TC 4 (50% rated).is bound by TC 2 (24% to 45% rated),

TC 5 (55% to 60% rated) and overlapped by TC 3-(34% to 70% rated). Startup Test No. 22 (FSAR Section 14.1.4.8.22), Test Procedure STUT.030.034, " Turbine Valve Surveillance." Detroit Edison's proposal is to delete the turbine valve surveillance during Test Condition No. 3. Since STUT.030.024 is a repetition of routine testing (surveillances) of the individual main turbine control, stop and bypass valves conducted during-plant operation and its objective of determining the maximum aower level to perform the surveillance can be (55% or 60% rated) andaccomp(100% 6 rated) STUT.xxx.024 w testslished by tie Test Co boundTC3(35%to70% rated);thisdeletionisacceptablehich Startup Test No. 28 (FSAR Section 14.1.4.8.28),-TestProcedure STUT.038.024, " Recirculation System - One Round Trip." ' Detroit Edison's proposal to delete this Test Condition No. 3 test is based upon adequate demonstration of the response of the system during a single pump trip during Test Condition No. 6. Additionally, the testing is not required to verify FSAR transient analysis since it has been demonstrated by previous BWR/4 startup testing that the single pump trip has a negligible impact on safety limit This is acceptable based on the Test Condition No. 6 test and General Electric's data verifying the negligible effect upon safety limits during single pump trip StartupTestNo.28(FSARSection 14.1.4.8.28), Test Procedure STUT.030.030, " Recirculation System - Recirculation Pump Runback."

Detroit Edison's deletion of this test is based upon the Feedwater Pump trip testing during Test Condition No. 6 which will adequately demonstrate the test ob ectives of STUT.03D.030 since a recirculation pump runback will resul;t at 100% rated power and core flow with a trip of a feedwater pump. This deletion is acceptable; however, the inspector did not agree with accepting an inadvertent feedwater )um trip event to demonstrate the actuation of the recirculation run)ac(

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L circuits because.no test conditions or acceptance criteria were

~provide The licensee agreed that an additional Safety Evaluation

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will have to be performed,' prescribing initial conditions and acceptance criteria for extrapolating the data should an inadvertant:

feedwater pump trip occu In addition to the above proposed startup testing deletion, the

extending of the power range from 100% rated to greater thanwas 70% proposed reviewed. -The purpose of extending the power range was to allow the possibility.of extrapolating data for the-following inadvertent events to meet the requirements of scheduled startup testing:

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Startup Test No. 23'(FSAR Section 14.1.4.8.23), Test Procedure STUT.06C.028, "MSIV Full Isolation." Detroit Edison's-propcsal to extrapolate data from an inadvertent MSIV isolation is acceptable as-a concept; however, it is not acceptable to the NRC to provide deletion of the scheduled test only on the data collected from an -

inadvertent isolation. One of the requirements of the scheduled

. test (STUT.06C.025) is to verify that, "the positive change in vessel dome pressure occurring within 30 seconds after the simultaneous full closure of all MSIVs must not exceed the level 2 criteria by more than 25 psi." To verify this acce the " Fractional Change Relative to Base Case 1 (Kderived is )" ptance fromcriteria, a

curve supplied by General Electric. This curve is based upon the actual design and the model for the transient. Since this curve is only for the power range of 84% to 100% rated, a new model will have to be developed to provide the means to extrapolate data from an inadvertent isolation between 70% and 84% rated power. This is also the case for expanding the )ower window for Detroit Edison's second test; Startuo Test No. 25 (:SAR Section 14.1.4.8.25), Test Procedure STUT.06B.027 " Turbine Stop Valve and Control Valve Fast Closure'

Trips" since the same acceptance criteria and fractional change factor (K)1 applie Detroit Edison's proposals to delete those scheduled startup tests listed in their October 17, 1986, letter are acceptable; however approval for extrapolating inadvertent events for scheduled tests will,have to be done on a case-by-case basis with appropriate 10 CFR 50.59 reviews and extrapolations submitted for review by the NR No violations or deviations were identifie . Exit Meetings Theinspectorsmetwiththelicenseerepresentatives(denotedin Paragraph 1)attheconclusionoftheins)ectiononNovember 19, 1986, and via telephone on January 14, 1987. T1e inspector summarized the scope and findings of the inspection.- The licensee acknowledged the i inspector's findings. The licensee did not indicate that any of the i, information disclosed during the inspection could be considered r proprietary.

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