ML20197A790
| ML20197A790 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/17/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| References | |
| 50-341-97-11, NUDOCS 9712230188 | |
| Download: ML20197A790 (1) | |
See also: IR 05000341/1997011
Text
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Mr. D. R. Gipson ' Senior Vice President Nuclear Generation Fermi 2 Nuclear Power Plant The Detroit Edison Company 6400 North Dixie Highway . Newport, MI 48166 , SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-341/97011) i Dear Mr. Gipson: This will acknowledge receipt of your letter dated November 26,1997, in response to
our letter dated October 29,1997, transmitting a Notice of Violation associated with the above , mentioned inspection report at Fermi 2 Nuclear Power Station. We have reviewed your - corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections. Sincerely, original signed by J.M. Jacobson/for John A. Grobe, Director Division of Radiation Safety Docket No. 50 341 cc w/ encl: N. Peterson, Director, Nuclear Licensing P. A. Marquardt, Corporate Legal Department ' Richard Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Monroe County, Emergency Management Division Distribution Docket File w/ encl Rlli PRR w/ encl Rlli Enf. Coordinator w/enci PUBLIC IE 01 w/ encl SRI, Ferml w/ encl TSS w/enci . LPM, NRR w/enci J. L. Caldwell, Rlli w/ encl DOCDESK w/enci DRP w/ encl A. B. Beach, Rlli w/ encl CAA1 w/enci DRS w/enci ll I.ll ,I!I,I,Il.l!.Ill.i . DOCUMENT NAME: G:DRS\\FER12157.DRS t. ...n.e. - . ..e cm - .n. - - . v.e - .n. - ,c.%,, L OFFICE Rill /DRS It Rill \\DRV Its Rlll/DRS, gl Rlll/DRS l NAME Lougheed:sd4f*k kenkll4r (wyn Grobe Wf' DAlli 12A t/97 12/6/97 12/f/97 12/ /97 l OFRCIAL RECORD COPY 97 3330198 97 7 [
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fenvi; 04* North thue llut. Newp"t1. \\liiliigan 441% Tel. 31:1 f.% LJol fat :ll:lfM 4172 Detroit Edison 10 CFR 2.201 November 26,1997 NRCd7 0104 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555 References: 1) Fermi 2 NRC Docket No. 50 341 NRC License No. NPF-43 2) NRC Inspection Report No. 50-341/97011 dated October 29,1997 3) NRC Letter dated October 9,1996, Request for information Pursuant to 10 CFR 50.54(f) Regarding Adequacy and Availability of Design liasis information 4) Detroit Edison Letter to NRC, NRC-97-0039," Updated Final Safety Analysis Report (USFAR) Validation Initiative," date August 19,1997 Subject: Rpply to Notice of Violation 50 341/97011-02 Enclosed is Detroit Edison's response to the Notice of Violation (NOV) contained in Reference 2. The following commitment is being made in this letter: A Technical Specification (TS) change will be prepared and submitted by
April 1,1998 to revisc TS 3.5.3.b.3 and other efTected TS sections. Since changes to the Updated Final Safety Analysis Report (UFSAR) Sections 6,3.2.6 and 9.2.6.1 involve a change to the TS, they will be completed upon implementation of the TS change. [[C U 3 ITJ[ Cg Jg _ \\ llTF. Enno Gmpain
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. . ,' NRC.97 0104 . Page 2 Should you have any questions regarding this response, please contact Norman K. Peterson, Director Nuclear Licensing, at (313) 586-4258. Sincerely, hfl Enclosure ee: A. II. Ileach B. L.13urgess D. R. Ilahn G.Ilarris A. J. Kugler M. V. Yudasz, Jr. Region til Wayne County Emergency Management Division . , - - - . , - - . y --,, ,
_ _ _ _ . + . Enclosure to . NRC 97-0104 Page 1 of 3 Henly to Notlee of Violation 97011-02 Statement of Notlee of Violation: 10 CFR 50.9(a) requires, in part, that information required by statute, or by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. The Technical Specifications are required by 10 CFR 50.36, while the Updated Final Safety Analysis Report is required by 10 CFR 50.34 and 50.71(c) Contrary to the above, as of September 22,1997,information in the Technical Specifications and Updated Final Safety Analysis Report was not complete and accurate in all material respects. Specifically: a) Technical Specification 3.5.3.b.3 was inaccurate in that it stated that the Condensate storage tank contained 300,000 available gallons, equivalent to a level of 18 feet, llowever, a level of 18 feet corresponded to, approximately, a maximum of 293,000 available gallons. b) Updated Final Safety Analysis Report Section 6.3.2.6 was inaccurate in that it stated that the Condensate Storage Tank was designed to retain a minimum reserve of 150,000 gallons for use by the high pressure coolant injection or reactor core isolation cooling system. c) Updated Final Safety Analysis Report Section 9.2.6.1 was inaccurate in that it stated that the Condensate Storage Tank was designed to deliver its last 150,000 gallons only to the high pressure coolant injection or reactor core isolation cooling systems. In actuality, only approximately 105,000 gallons of the last 150,000 gallons could be delivered to the high pressure coolant injection or reactor core isolation cooling systems. Benson For Tre Violation: This violation was the result ofinadequate Updated Final Safety Analysis Report (UFSAR) and Technical Specification (TS) review and inadequate implementation of corrective actions for discrepancies identified. NRC Team inspection was conducted at the Fermi 2 Nuclear Plant between July and September,1996. This inspection included a review of UFSAR and Design Basis Documents (DDDs) for the liigh Pressure Cooling injection (llPCI) and Non- Interruptible Air Supply (NIAS) systems. As a result of the inspection, several errors and _ . . -
- . . . Enclosure to . NRC.97-0104 Page 2 of 3 inconsistencies in these documents were identified. Deviation Event Reports (DERs) were initiated to address these and other inconsistencies. The results of the DER investigations relating to the Condensate Storege Tank (CST)" usable" volume concluded that, from a technical standpoint, the CST met its design requirements because adequate water was available for operation of the systems it supported. No changes to the UFSAR or Technical Specifications were deemed necessary. The conclusion that no changes to the UFSAR or TS was based on the explanation that the CST "available" volume describes a gross available volume instead of a " usable" volume. This conclusion was erroneous. Corrective Steps That IInve (ken Taken and the Results Achieved On February 7,1997, Detroit Edison submitted its response to the NRC request for infonnation regarding adequacy and accessibility of design bases information (Reference 3). In order to increase the level of confidence in the accuracy of the UFSAR, Detroit Edison committed to perform validation of the UFSAR and to impre ving the Corrective Action Program. While these initiatives may not have identified and corrected the specific discrepancies cited in this violation, they clearly indicate the level ofimportance that Detroit Edison is placing on the accuracy of the UFSAR and Corrective Action Program. These two initiatives are summarized in the following paragraphs. The plan for the UFSAR Validation Project (UVP) involves comparison of the original Final Safety Analysis Report (FSAR) and the NRC Safety Evaluation Report (SER) along with its supplements, with the current UFS AR, plant procedures, and design documents. This comparison will result in a rebaselining of the UFSAR to provide further assurance that it is reflective of the plant and procedures, and that changes made since issuance of the Operating License have been appropriately documented. Necessary updates to the UFSAR will be scheduled in accordance with the requirements of 10 CFR 50.71(c). Additional details are provided in Reference 4. A new corrective action program was implemented on September 8,1997. This program has a lower tb eshold for conditions to be identified and entered into the corrective action system. In addition, a procedure was developed and issued which provides instructions, reviews, anJ other controls for elTective cause analysis ofidentified conditions. A Condition Assessment Resolution Document (CARD) has been written to address this specific issue and to track corrective actions. As a result of the initial operations assessment of this CARD, level in the Condensate Storage tank is being maintained at a level that ensures operability of the affected systems. l l 1 _ _ _ , ,.
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. .. . * . , Enclosure to .
NRC-97-0104
Page 3 of 3
4 Corrective Stens That Will Be Taken To Avoid Further Violations l l A Technical Specification (TS) change will be prepared and submitted by April 1,1998 to revise TS 3.5.3.b.3 and other TS sections. Since changes to the Updated Final Safety Analysis Report (UFSAR) St .tions 6.3.2.6 and 9.2.6.1 involve a change to the TS, they ! will be completed upon implementation of the TS change. . These changes will also address other references to CST volume contained in the TS and i UFSAR. l Date When Full Comoliance Will Be Achieved !
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