IR 05000341/1988029
| ML20196E794 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/05/1988 |
| From: | Gardner R, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20196E783 | List: |
| References | |
| 50-341-88-29, GL-85-06, GL-85-6, NUDOCS 8812120087 | |
| Download: ML20196E794 (8) | |
Text
--
- - - -
,
'
..
.
,
-
.
,
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/88029(DRS)
Docket No. 50-341 License No. NPF-43 Licensee: The Detroit Edison Company 2000 Second Avenue Detroit, MI 48266
'
Facility Name:
Fermi 2 Nuclear Power Station Inspection At: Newport Michi9an Inspection Conducted: October 18-20, October 31 through November 3, and November 9, 1988 na.wa&g ygf, y Inspector:
R. A. Westberg O
Date h\\
11}&
l
}8 $
Approved By: F,onald N. Gardner, Chief IA/5/
Plant Systems Section Date~
'
Inspection Sunmary Inspection on October 18-20, October 31 through November 3, and November 9, 1988
'
(Report No. 50-341/88029(DRS))
Areas Inspected: Routine announced inspection of licensee compliance with ATWS Rule, 10 CFR 50.62, per TI 2500/20 (25020), (SIMS Number MPA-A-20).
Results: No violations or deviations were identified. Based on the inspection, the inspector concluded that il 2500/20 could not be closed, 6s10120087 831205 ADOCK0500gjl FDR
.
-
-- _______ _ _ _ _ _ _ _ _ _ _
_
..
,
.
-
.
,
DETAILS 1.
Personnel Contacted.
Detroit Edison Company (DECO)
- S. G. Catola, Vice President, Nuclear Engineering and Services
- D. R. Gipson, Plant Manager
- T. L. Riley, Supervisor, Compliance Licensing
- L S. Goodman, Director, Nuclear Licensing
- G. M. Trahey, Director, Special Projects
- F. J. Svetkovich, Assistant to Plant Manager
- G. V. Cranston, General Director, Nuclear Engineering
- M. K. Deora, Principal Engineer
- R. J. Ballis, Supervisor I&C
- J. H. Plonia, Operations Support Engineer
- P. M. Anthony, Compliance Engineer E. L. Opland, Nuclear Maintenance Support As sistant J. M. Molinari, Nuclear Maintenance Support Assistant R. Laubenstein, Assistant Shif t Supervisor K. J. Karnik, Nuclear Supervising Operator R. J. Trimai, Training
U. S. Nuclear Regulatory Commission (U. S. NR$
,
- W. G. Rogers, Senior Resident Inspector l
- R. N. Gardner, Chief, Plant Systems Section
- Indicates those attending the exit meeting on November 9,1988.
'
2.
Temporary Instruction (TI) 2500/20 (SIMS Number MPA-A-20) (0 pen)
10 CFR 50.62, "The ATWS Rule," requires three systerr,s to mitigate the
,
'
consequences of an ATWS event. They are Reactor Pump Trip (RPT),
Alternate Rud Insertion (ARI), and Standby Liquid Control System (SLCS)
with a minimum flow capacity and boron content equivalent in control capacity to 06 gallons per minute of 13 weight percent sodium pentaborate solution.
l The modifications that installed the required RPT and the ARI were completed during initial construction of the Fermi 2 plant.
These systems are described in the FSAR in Sections 4 and 7 and their installation preceded the ATWS Rule by three years; howevar, their design was not reviewed and approved by the NRC in e Safety Evaluation Report
(SER).
The licensee has comitted to a modification of the SLCS by increasing the boron enrichment in the SLCS Storage Tank.
The NRC staff reviewed licensing topical report No. NEDE-31096-P,
"Anticipated Transients Without Scram; Response to NRC ATWS Rule,
!
10 CFR f.,0.62," subnitteo by the BWR Owner's Group and issued a SER based
t
!
,
. -..
- - - - - _.
_
_
_ _ _ - - ___ _____________
__
--_
..
,
.
-
.
,
on the group's conceptual design. Detroit Edison Company (DECO) was a member of the owner's group but as their RPT and ARI systems were already installed, they did not formally endorse or adopt the group's design.
Therefore, the SER on the group's design is not applicable to the Fermi 2 site.
TI 2500/20 requires verification that the licensee's design as endorsed through the SER is properly implemented. Review of the ATWS mitigating systems installed at the plant indicated that the Fermi 2 09T/ARI systems are unique and could not be evaluated utilizing the SER which is on the owner's group's design.
Since a site specific SER on the ATWS mitigating systems was expected to be released during the term of this inspection, the inspector called the NRR Project Manager (PM) for the Fermi 2 site. The inspector and the PM
'
,
concluded that due to misconceptions concerning the ATWS design, TI 2500/20 could not be completed at this time.
l
!
.
The inspector rescoped the inspection and concentrated on reviewing the l
,
Fermi 2 RPT/ARI design and comparing it to designs iniplemented by the
other menibers of the owner's group in Region III.
This inspection report documents the results of the redirected inspection, i
a.
Documents Reviewed (1) Letters (a) October 12, 1985 Letter, W. Jens to Director of NRR,
"Implementation Schedule for ATWS Compliance."
[
<
j (b) December 19, 1986 Letter, NRR to B. Sylvia, "Fermi 2 l
Complience with the ATWS Rule, 10 CFR 50.62."
<
.
!
(c) February 27, 1987 Letter F. Agosti to NRR, "Fermi 2 j
Compilance with the ATKS Rule, 10 CFR 50.62."
l I
(d) March 31, 1988 Letter, NRR to B. Sylvia, "Fermt 2 ATWS
,
(TAC No. 59094)."
i i
i (e) April 20, 1988 Letter, B. Sylvia to NRR, "Fermi 2
<
j ATWS - Response to Request for Additional Information."
l (2) Safety Evaluation of Topical Report No. NEDE-31090-P (3)
Fermi 2 UFSAR
!
(a) Sections 7.1.2.1.33, 7.6.1.18, and 7.6.2.18. "Alternate Rod Insertion."
l
!
!
!
<
- - -
- - - _... _ _...
.-_
_ - -. -.
. _ _ _ _, _ _
, _. _ _ _ _,_
. - _, _ - _,,,
_ _ _ _ _ _ _ _ _ -. _ _ _ _
-
..
.
.
,
(b) Sections 7.1.1.2 and 7.7.1.3.3.1, "Recirculation Pump Trip."
(c) Section 15.8, "Anticipated Transients without SCRAM (ATWS)."
(4) Procedures (a) Emergency Operations Procedure (EOP) No NPP-29.000.01,
"RPV Control." Revision 7.
(b) E0P No. NPP-29.000.02, "Primary Containment Control (PC),"
Revision 5.
(c) Surveillance Procedures
~~
NPP-44.040.00, "ATWS/SRV Low Low Set - Reactor Vessel 1.
Pressure Division 1 Functional Test," Revision 21.
2.
NPP-44.040.005 (SQ), "ATWS/SRV Low Low Set - Reactor
,
~~
Vessel Pressure Division 1, Channel A Calibration,"
Revision 20.
3.
NPP-44.040.009 (SQ), "ATWS - Divsion 1. Logic
~~
Functional Test," Revision 20.
(5) Drawings
,
(a) 61721-2105-16, "Schematic Diagram Reactor Recirc M-G Set A&B Gen Field Breaker Trip Circuits " Revision F.
(b) 61721-2100-4, "Logic Diagram Reactor Recirculation System
{
Part 4," Revision A.
,
(c) 661721-2105-8, "Schematic Diagram Reactor Recirculation
'
System Loop A Annunc Circuits," Revision F.,
(d) 6M721-5*49, "Control Rod Drive Hydraulic System - Reactor Building Port 2 of 2," Revision G.
(e) 61721-2105-1/, "Schematic Diagram Alternate Rod Insertion Solenoid Valves," Revision D.
(6) Training Department Energency Operating Procedure Exercise Guides (a) No. 09-05-50-18. "Level / Power Control 100% ATWS "
Revision 1.
(b) No. 09-05-50-36, "Fail to Scram - RFPT Trip " Revision 0.
(c) No. 09-05-50-35. "Fail to Sc-sm - Stuck Open Relief Valve," Revision 1.
..
,
-_ -____ _-_______
._
__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,'
..
.
'
.
.
(d) No. 09-05-50-32 "Fail to Scram - SLC Injection,"
Revision O.
(e) No. 09-05-50-31, "RFPT Trip - Fail to Scram," Revision 0.
(f) No. 09-05-50-12. "Failure to Scram," Revision 1.
(7) Training Lesson Guides (a) No. 03-15-04-01, "Reactor Recirculation System,"
Revision 1.
(b) No. 08-02-05-03, "Emergency Operating Procedures - RPV Control (RC)," Revision 0.
(8) Training Records - Various b.
ATWS Design Review The NRC has published guidance regarding system and equipment criteria for ATWS in Federal Register Volume 49; No. 124 on June 26, 1984.
The inspector's review of the Fermi 2 ATWS design used the same criteria. The results of that review follow:
(1) The ARI system does not have to be safety-related; however, its installation must be such that the existing Reactor Protection System (RPS) continues to meet all applicabic safety-related criteria. At Fermi 2 the ARI sensors, transmitters trip units, associated logic and ARI valves are Class IE, Review of the systems schematics and direct inspection of a sample of the installed equipment indicated that there was no direct interface with the RPS. The inspector found this to be consistent with designs previously approved by the NRC.
(2) The ARI system must have redundant scram air header exhaust valves, but the ARI system itself does not need to be redundant.
At Femi 2 there are redundant scri.m air header exhaust valves.
1he ARI system receives a different initiation signal than the
.
RPS and has its own transmitters, trip units, and logic. The inspector found this to be consistent with previously approved designs.
(3) The ARI system should be diverse from the existing reactor trip system. The Fenni 2 ARI design employs energize-to-function valves and DC powered valves and logic. This is consistent with previously approved designs; however, both the ARI and RPS use Rosemount analog transmitters and trip units. This has previously been concluded to be unacceptable diversity by the NRC staff.
(4) The ARI system is required to be electrically independent from the RPS from sensor output to the final activation device.
Through a review of the schematics, the inspector verified that
- _ _ _ _ _ _ _ _.. _ _ _ _ _ _ -..
'
..
.
.
.
Y the Fermi 2 ARI design is powered from ECCS divisional power independent from the RPS and the wiring is run in a divisional cable tray / conduit system that is independent of the RPS.
This is consistent with the previously approved designs.
(5) The ARI system installation must be such that the physical separation criteria applied to the existiitg protection system is not violated. The Fermi 2 design has the ARI trip units, logic, and output devices installed in divisional ECCS equipment cabinets. While it is physically separate from the RPS, this design is different than those previously approved by the NRC staff.
(6) The ARI must be environmentally qualified (EQ) for anticipated operational occurrences only. At Fermi 2 the sensors, transmitters, trip units and associated logic are qualified to IEEE 323-1974. This is consistent with previously approved designs.
(7) No seismic qualification is required for ARI system hardware; however, at Fermi 2, the sensors, transmitters, trip units, and associated logic are qualified to IEEE 344-1975.
(8) The ARI system is not required to be safety-related but it must meet NRC Generic Letter 85-06. At Fermi 2 all hardware for the ARI design from sensor to final actuator was purchased as QA1 (safety-related).
(9) The AR. system n.ast be capable of performing its safety function with loss of offsite power and its power source should be independent from RPS. The inspector verified that the Fermi 2 ARI design included a Class 1E battery source independent of the RPS. This is consistent with previously approved designs.
(10) The ARI system should be testable at power and inadvertent ARI actuation which challenges other safety systems should be minimizej The inspector verified that the Fermi 2 design employs a redundant two-out-of-two logic such that each individual level and pressure instrument can be tested at power during plant operation.
Further, the two-out-of-two logic and different setpoints from RPS are such that a normal scram from the RPS should occur prior to the ARI function. This is consistent with previously approved designs.
(11) In response to the staff's request for additional information, other design features were discussed with the owner's group.
The inspector also reviewed the Fermi ARI design relative to that discussion as follows:
a.
The Fermi 2 ARI design does not have manual initiation capability from the control room. All Region III ARI designs previously approved by the staff have this feature.
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
- *
O, r
.
.
b.
The owner's group's generic design is such that once the ARI is initiated, the protection action will go to completion. The Fermi 2 has a seal-in function; however, it is located in a different location than in the generic design and it does not seal-in the initiation signals.
This is different than the designs previously approved by the staff.
Tht.'e is a reset switch in the Fermi ARI i
design at cabinet No. H11-P603.r522 and reset of the ARI system is under administrative control. The staff has previously found this acceptable.
[
c.
The Fermi 2 ARI design does not include a bypars for maintenance. The staff has previously concluded that this feature is not required.
(12) RPT designs previously approved by the NRC staff are the
"Modified Hatch Design," the "Monticello Design," and the
"Original BWR/4 Design." The Fermi 2 RPT design is similar to
the Monticello Design.
It has the following differences from
'
this design:
a.
No manual initiation switches.
!
b.
No logic reset switches.
c.
The seal-in is in a different location and
,
j does not have a timer function.
,
d.
The two-aut-of-two logic is implemented i
differently.
'
(13) Deco has comitted to a modification of the SLCS to increase the boron enrichment.
This has been previously accepted by the staff anu is consistent with other Region III designs.
!
.
l No violations or deviations were identified in this inspection area.
c.
Other Inspection Results j
1he inspector reviewed the emergency operating procedures (E0Ps) that contained the ATWS entry conditions and actions.
The inspector also
interviewed one Assistant Shift Supervisor and one Nuclear Supervising Operator relative to these E0P5 and their actions. The E0P review I
and the interviews produced one concern. The section in E0P No.
,
t NPP-29.000.01, "RPV Control" that is titled, "Alternate Control Rod Insertion," does not refer to ARI. It is referring to alternate mean?
)
to be employed to tr,v to get the control rods to insert. This
.
t j
concern was discusseu at the exit meeting and the licensee indicated that it would be reviewed.
L l
,
!
l
,
_ - -.
_
_ _ _
.
- - _ _.
-
.
.
.
-. -__ _ _ _
___
___ - __-_________ - _ _ _
__ _ _ _ _ _ _ _ _ _ _ _
__. _ _ __
_
_
_ _ _ _ _ _ _ _ _ _ _ _ _.
~
-
..
e
.
,
The inspector also reviewed ATWS tra:ning scenarios and lessan plans and verified that all licensed personnel currently on shift had been trained.
During the inspection the inspector verified through a review of the schematic diagrams and drawings that when the back-up manual scram switches are initiated a main steam isolation valve (MSIV) isolation also oce.urs because of loss of power to the NS4 isolation logic.
This was a previous concern of the Senior Resident Inspector at fermi and has been forwarded to Headquarters under AIT 03S4 dated October 27, 1988.
3.
Exit Interview The inspector met with licensee representatives denoted in Paragraph I during and at the conclusion of the inspection on November 9, 1988.
The inspector summarized the scope and results of the inspection and discussed the likely content of this inspection report.
The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
o I
i I
i l
j l
l h
.
l l
,
!
l
'
l
!
1
___