ML20198N317
| ML20198N317 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/29/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| Shared Package | |
| ML20198N324 | List: |
| References | |
| 30-341-97-11, EA-97-479, NUDOCS 9711040016 | |
| Download: ML20198N317 (4) | |
See also: IR 05000341/1997011
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October 29, 1997
EA 97-479
Mr. D. R. Gipson
Senior Vice President
Nuclear Generation
The Detroit Edison Company
6400 North Dixie Highway
Newport, MI 48166
SUBJECT:
NRC ENGINEERING AND TECHNICAL SUPPORT INSPECTION REPORT
50-341/97011(DRS) AND NOTICE OF VIOLATION
Dear Mr. Gipson:
On September 22,1997, the NRC completed the onsite portion of an inspection at your Enrico
Fermi, Unit 2, facility. The enclosed report presents the results of that inspection. These results
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were discussed with you at the conclusion of inspection, and, via telephone, on October 10,
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1997.
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Areas examined during tne inspection are identified in the report. Within these areas, the
inspection consisted of a selective examination of procedures and representative records,
observations of activities, observations of equipment material condition, and interviews with
personnel.
Overall, NRC deemed that progress had been made in control of engineering acth: .les. One
positive noted by the inspection team was the quality of the engineering calculations supporting
design decisions. Other areas where the team sensed improvement was in engineering
involvement in operability determinations and support of operations.
However, we could not assess the corrective action process, because it was being extensively
revised at the time of the inspection. Although we are cautiously optimistic about the
improvements being implemented, we cannot evaluate the new process until it has been fully
implemented.
Additionally, we identified some continuing problems with safety evaluations performed by your
staff. While we considered the increased emphasis on when to perform safety evaluations to
be positive, it appears that additional attention needs to be focused on answering the questions
posed by 10 CF*t 5159. Specifically, we identified an apparent unreviewed safety question;
this is discussed below. Furthermore, we identified an example where a required Technical
Specification change was not caught during the safety evaluation preparation and review
process. We are concerned that your staff considered it appropriate to eliminate Technical
Specification required te; ting under the auspices of 10 CFR 50.59. However, because there
are generic aspects to this issue, we are considering it unresolved, pending resolution of these
aspects. We willinform you of further developments on this issue.
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. D. R. Gipson -2- october 29, 1997 Based on the results of this inspection, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding il are described in detail in the subject inspection report. The violation is of concern due to the fact that NRC relies upon the information in the Technical Specification and Updated Safety Analysis Eeport as being complete and accurate in the case of the condensate storage tank, these documents inaccurately reflected the available volume of water contained in the tank. You are required to respond to this violation and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In addition, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600. The apparent violation involves an inadequate safety evaluation where your staff failed to recognize the possibility of an equipment malfunction of a type different from any previously analyzed in the safety analysis , ! report. Specifically, your staff changed the Updated Final Safety Analysis Report to allow operation of the emergency equipment cooling water system during normal plant operations to ' supplement the non-safety-related reactor building closed cooling water system. However, use of the emergency equipment cooling water system in this manner introduced the potential for some safety-related loads to receive less than adequate cooling water during a maximum-safeguards high energy line break outside containment. a scenario not previously evaluated by the NRC. No Notice of Violation is presently being issued for this inspection finding. In addition, please be advised tilat the number and characterization of apparent violations described in Section E3.2 of the enclosed inspection report may change as a result of further NRC review. A predecisional enforcement conference to discuss this apparent viola' ion has teen scheduled for November 12,1997. This conferer ce will be open to public observation. The decision to , hold a predecisional enforcement aanference does not mee,i that the NRC has determined that ! a violation has occurred or that enforcement action will be taken. This conference is being held to obtain information to enable the NRC to make an enforcement decision, such as a common understanding of the facts, root causes, rnissed opportunities to identify the apparent violation, corrective actions, significance of the issues and the need for lasting and effective corrective action. . . . _. . ., . . _ ,,
. _ - _ _ _ _ - _ - _ _ - _ _ - _ _ , , D. R. Gipson -3- October 29, 1997 In addition, this is an opportunity for you to point out any errors in our inspection report and for you to provide any information concerning your perspectives on (1) the severity of the violation, (2) the application of the factors that the NRC considers when it determinec the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and (3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll. . You will be advised by separate correspondence of the results of our deliberations on this matter. No response regarding the apparent violation is required at this time, in acccidance with 10 CFR 2.790 of the NRC's " Rules of Prectice," a copy of this letter, its onclosures, and your response, will be placed in the NRC Public Document Room. We will gladly discuss any questions you have conceming this inspection. l Sincerely, original signed by J. M. Jacobson John A. Grobe, Director Rr Docket No. C0-341 License No. NPF-43 i Enclosure: 1. Notice of Violation 2. Inspection Report 50-341/97011(DRS) cc w/enet: N. Peterson, Supervisor of Compliance P. A. Marquardt, Corporate Legal Department James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Monroe County, Emergency Management Division See Attached Distribution DOCUMENT NAME: G:DRS\\FER97011.DRS To recove a copy of this document, indicate b the box *C" = Copy w/o attach /enci *E" = Copy w/ attach /enci'N" a No copy OFFICE RlthDRs Rlli RS M Rill DRP e Rill EICS L RilPDRSk NAME Louk Rip 0 Jordan Clayton Grotd ' , DATE: 10fh/97 10h497 10/N97 10/Lf/97 10/)S 9'1 OFFICIAL RECORD COPY \\ l l l _
- _ . _ _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ _ - - - - - - - - - - - - - _ - - - - - - - - - - - - - ' . D. R. Gipson -4- October 29, 1997 Distribution: Docket File w/enci Rlli PRR w/enct Rill Enf. Coordinator w/enct PUBLIC IE-01 w/ enc! SR!, Fermt w/enci TSS w/enci OC/LFDCB w/enci LPM, NRR w/enci DOCDESK w/enci DRP w/enci A. B. Beach, Rill w/enci CAA1 w/ encl DRS w/enci J. L. Caldwell, Rlli w/enci R. Zimmerman, NRR J. Goldberg, OGC J. Lieberman, OE }}