IR 05000341/1998005
| ML20236Y035 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/05/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| Shared Package | |
| ML20236Y029 | List: |
| References | |
| 50-341-98-05, 50-341-98-5, EA-98-201, NUDOCS 9808110100 | |
| Download: ML20236Y035 (2) | |
Text
August 5, 1998
SUBJECT:
NRC INSPECTION REPORT 50-341/98005(DRS)
,
Dear Mr. Gipson:
On September 22,1997, the NRC completed an Engineering and Technical Support inspection (Inspection Report 50-341/97011(DRS)) at your Enrico Fermi, Unit 2, facility. One of the issues reviewed during that inspection, and subsequently addressed as an unresolved item, was your
. practice to eliminate response time testing (RTT) for cortain instruments in the Reactor Protection, Isolation Actuation, and Emergency Core Cooline Systems per 10 CFR 50.59,
!
- Changes, Tests, and Experiments." However, resolution was deferred while the NRC reviewed the generic applicability Of this issue because of similar concems at several other boiling water reactors.
l A follow-up inspection (NRC Inspection Report 50-341/98005(DRS), Marc,n 20 - April 6,1998)
formally transmitted the NRC's decision relative to the generic concerns. The conclusion was that the elimination of RTT via 10 CFR 50.59 was not appropriate. The unresolved item was addressed in the report as four apparent violations and you were requested to respond to the apparent violations.
l-We subsequently met with you on May 6,1998, to discuss your: (1) evaluation of the causes of the apparent violations, (2) corrective actions to prevent recurrence, and (3) understanding of l
the safety and regulatory significance of the apparent violations. You stated that the cause of the inadequate 10 CFR 50.59 evaluation was your staff's failure to recognize that instrument response time testing was required by technical specifications and could not be eliminated by 10 CFR 50.59. You also indicated that the failure to conduct the testing at the appropriate
' times was: (1) a direct result of an inade, ate 10 CFR 50.59 evaluation, (2) that the safety and regulatory significance were minimal since instrument response time testing wss being
,
performed using NRC accepted methodology, and (3) significant degradation would have been l
detected during other calibration and surveillance testing activities.
l l
!
l-l
!
!
9908110100 990905
!
POR ADOCK 05000341
'
G PDR
'
l
,.
- Based on the information developed during the inspection, and our consideration of the information provided in the May 6,1998, meeting, the NRC has determined that a violation of NRC requirements occurred. A detailed description of the circumstances resulting in the violation is described in the two referenced inspection reports. After our review of the information you provided during the May 6,1998 meeting, Region ill determined that the three apparent violations for failure to conduct ade tte response time testing were the direct result of an inadequate 10 CFR 50.59 evaluation.
Normally, a violation for an inadequate 10 CFR 50.59 evaluation that results in a significant failure to follow TS would be classified at Severity Level Ill. However, in this case, the NRC has I
determined that this violation does not constitute a significant regulatory concern and therefore should be classified at Severity Level IV. The basis for this determination was: (1) your staff
,
was performing 'nstrument response time testing for the affected systems in accordance with l
methodology (NEDO-32291, "BWR Owners Group Licensing Topical Report") that was approved in NRC Safety Evaluation Report, dated December 28,1994; (2) the safety significance was low, since you were conducting calibration and surveillance tests that would have detected degradation of the systems; (3) your methodology for testing was approved by the NRC in a subsequent technical specification amendment; (4) the inadequate 10 CFR 50.59 evaluation was an isolated case and not reflective of a programmatic breakdown; and (5) there was no adverse impact on plant safety or operability of the affected systems as demonstrated by the testing methodology you had implemented.
The NRC acknowledges that you identified the inadequate 10 CFR 50.59 evaluation in March l
1997, and reported the issue to the NRC as required. Additionally, the NRC finds your corrective actions, as documented in your LER and as communicated at the May 6,1998 meeting, acceptable. Accordingly, the NRC is dispositioning this non-repetitive, licensee-identified and corrected violation as a Non-Cited Violation, consistent with Section Vll.B.1 of the Enforcement Policy. Accordingly, no response is required to this correspondence.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room.
Sincerely, Original /s/ J. A. Grobe John A. Grobe, Director l
Division of Reactor Safety Docket No.: 50-341 l
License No.: NPF-43 See Attached Distribution DOCUMENT NAME: G:DRS\\FER98005.LTR to,.e.w.. copy ov ini. aocum.ni. indic.i. ia in. i.oc c. cony -incue sti.ca.w vencio.or. r, ency -in an.cnm.nie.ncio.or. w No copy OFFICE Rill:DRS C Rlll:DRS lC. Rilljp)$
l C, Rlll:D RJ f,g
,
NAME Westberg:Ic VO Jacobson VO4 BufgeE Grobd6 DATE 0F6T1/98 OgAS/98 0T/3/98 0P/5/96 OFFICE Rill:OE Rlll:EICS y
,
NAME Lieberman M;,_ Clayton 8C DATE 05W/98.ffff<M 05/3/98 F OFFICAL RECORD COPY
_-___
_ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _
-
,. cc w/ encl:
N. Peterson, Director Nuclear Licensing P. A. Marquardt, Corporate Legal Department Richard Whale, Michigan Pub'E Service Commission Michigan Department of Environmental Quality Monroe County, Emergency Management Division Emergency Management Division, Mi Department of State Police Distribution:
J. Goldberg, OGC w/enci J. Lieberman, OE w/ encl B. Boger, NRR w/enci CAC (E-Mail)
Project Mgr., NRR w/enci C. Paperiello, Rlli w/enci J. Caldwell, Rlli w/enci B. Clayton, Rlll w/enci SRI Fermi w/ encl DRP w/ encl TSS w/ encl DRS (2) w/enci Rlli PRR w/enci PUBLIC IE-01 w/enci Docket File w/enci GREENS LEO (E-Mail)
DOCDESK (E-Mail)
.
._