ML20197F684
| ML20197F684 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/22/1997 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| References | |
| 50-341-97-07, 50-341-97-7, EA-97-600, NUDOCS 9712300274 | |
| Download: ML20197F684 (3) | |
See also: IR 05000341/1997007
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_ December 22, 1997
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i Mr. D. R. Gipson L
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- Senior Vice President
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The Detroit Edison Company:
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6400 North Dixie Highway
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Newport, Ml 48166?
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f SUBJECT:t NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-341/97007(DRP))
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. Dear Mr. Gipson:
' This will scimowledge receipt of your letter dated September 26,1997, in response to our letter
- dated August 26,1997, transmitting a Notice of Violation associated with inspection Report
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' No. 50 341/97007(DRP).- In your letter, you stated that you do not agree with Violation
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~ No. 50 341/97007-05D Your position was that Section 6.1 of the surveillance test procedure
. 54.000.20 (Revision 24), " Reactor R3 circulation System MG Set Scoop Tube Positioner
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Operability Test," satisfied the intent and requirement of Technical Specifiention Surveillance -
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Requirement 4.4.1.1.2. Therefore, your position was that the mechanical high speed stops
(HSS)' wore demonstrated operable within the 18-month period.
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On November 4 through 7,1997, we conducted a re-inspection of the eventCOur inspector
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- reviewed the design basis of the.HSS, startup tests, completed surveillance test data, and
revisions of the surveillance test procedure 54.000.20. During the review, the inspector
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determined that the design basis for the HSS was to ensure protection of the nuclear fuel
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cladding barrier during a postulated reactor recirculation pump transient. Additionally, the original
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L intent of the surveillance requirement was to satisfy a Minimum Critical Power Ratio (MCPR) _
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. limit.' General Electric established in SIL No. 228, dated June 6,-1977, that the HSS were related -
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~ to Critical Power Ratio." After the implementation of the Average Power Range Monitor - Rod
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Block Monitor Technical Specification (ARTS) improvement program before Fuel Cycle 3, the --
surveillance requirement was determined to establish an Average Planar Linear heat Generation
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LRate (APLHGR) limit;
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in addition, the' inspector identified that during Fuel Cycle 1, surveillance test procedure
44.220.301, Revision 21. " Reactor Recirculation System MG Set Scoop Tuba positioner -
Operability Test,". was used to verify the physical position of the mechanical HSS. The inspector
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- determined that surveillance procedure 44.220.301 was similar and accomplished the activities
of Section 6.1 of surveillance procedure 54.000.20.
in 1988, your_ staff initiated a Technical Specification improvement Group (TSIG) to improve the
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ce,6,%ence of survelliance procedures to the Technical Specifications. On September 8,1988,
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~ :the TSIG reviewed surveillance procedure 44.220.301. The result of this review was'
documented as TSIG 1450. :TSIG 1450 stated that the surveillance procedure did not satisfy the
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Technical Specifications because it only verified the HSS settingsr Since the surveillance
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procedure did not account for factors that could change either core flow or pump speed, -
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operability could not be proven.
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D. R. Gipson _
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Surveillance test procedure 54.000.20, Revision 20, superseded procedure 44.220.301 and
implemented TSIG 1450 comments. Section 6.1 of 54.00.20 essentially incorporated
44.220.301. Section 6.2 was implemented to ensure compliance to Technical Specifications.
However, the procedure stated that 'either Section 6.1 or 6.2 can be used to satisfy the
surveillance requirement, but Section 6.2 should be considered as the primary instruction." This
established an option of only completing Section 6.1 to meet the surveillance requirement
because Section 6.2 was only a "should" instead of a "shall." This option was not consistent
with your staffs determination that 44.220.301 (Section 6.1] was inadequate to demonstrate
operability per the surveillance requirement (TSIG 1450).
On April 17,1997, your staff found that the 18-month period (plus the allowed 25 percent
extension) to complete the surveillance requirement would soon be overdue on May 24,1997.
In addition, the plant was shut down and conditions did not allow perforrning Section 3.2. Your
staff completed Section 6.1 and determined that the HSS were operable with intentions of
completing Section 6.2 when allowed by plant conditions. The plant was started up on May 2,
1997. However, on June 3,1997, NRC inspectors found that Section 6.2 was not done. Your
staffs position was that Section 6.1 performed on April 17,1997, satisfied the surveillance
requirement. On June 4,1997, after intercession by NRC management, Section 6.2 was
completed. The inspector determined that several opportunities existed before June 4,1997, to
conduct surveillance testing similar to Section 6.2. Additionally, the inspector determined that
opportunities existed to notify the NRC of inabilities to meet the surveillance requirement and to
request an enforcement discretion.
Our conclusion is that Section 6.1 of the surveillance test procedure 54.000.20 (Revision 24) did
not satisfy Technical Specifications. Section 6.1 does not demonstrate the correct setting of the
HSS related to core flow or pump speed. We have determined that the violation, as issued in
Inspection Report No. 50-341/97007 on August 26,1997, is valid. Your staff revised the
surveillance test procedure to ensure that Section 6.2 is completed after performing Section 6.1,
We evaluated your corrective actions and found them to be satisfactory. We have no further
questions at this time.
Sincerely,
/s/Geoffrey E, Grant
Geoffrey E. Grant, Director
Division of Reactor Projects
Docket No. 50-341
Sea Attached Continued Distribution
DOCUMENT NAME: R: Ltrs21ic\\ detroit \\fer97007.tku
To receive a copy of th&e doeurnent,inecate in the bos *C' s Copy without attachntent/ enclosure 'E' s Copy with attachrnent/ enclosure
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Distribution
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N. Peterson, Director
Nuclear Licensing
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P. A. Marquardt, Corporate
- Legal Department
Richard . Whale, Michigan Public
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Michigan Department of-
Environmental Quality _
Monroe County, Emergency
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Docket File
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