ML20212J833

Responds to Licensee 990924 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required in TS 3/4.6.1.8.Ltr Documents 990923 Telcon with Util in Which NRC Orally Issued NOED

ML20212J833
Person / Time
Site:	Fermi
Issue date:	09/27/1999
From:	Black S NRC (Affiliation Not Assigned)
To:	Gipson D DETROIT EDISON CO.
References
NOED-99-6-007, TAC-MA6521, NUDOCS 9910060004
Download: ML20212J833 (8)

Text

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): $ UNITED STATES J 7j. . NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enans wt 4,g /. September 27, 1999

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Mr. Douglas R. Gipson SeniorVice President

- Nuclear Generation Detroit Edison Company

'6400 North Dixie Highway Newport, Michigan 48166-

SUBJECT:

. NOTICE OF ENFORCEMENT D!SCRETION FOR THE DETROIT EDISON

' COMPANY REGARDING FERMI 2 (TAC NO. MA6521, NOED NO. 99-6-007)

Dear Mr. Gipson:

. By letter dated September 24,1999, you requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification (TS) 3/4.6.1.8. Your l letter documented information.previously discussed with the NRC in telephone conferences at j 2:00 p.m. and 4:45 p.m. on September 03,1999. The principal NRC staff members who 1 participated in the telephona conferences were: j Suzanne Black, Acting Director, Project Directorate (PD) lli, Office of Nuclear Reactor Regulation (NRR)

Claudia Craig, Chief, Section 1, PD lli, NRR Andrew Kugler, Project Manager, Section 1, PD lli, NRR George Hubbard, Chief, Balance-of-Plant and Containment Systems Section, Plant Systems Branch, NRR .

Richard Lobel, Senior Reactor Engineer, Plant Systems Branch, NRR

- Marc Depas, Deputy Director, Division of Reactor Projects, Region ill (Rlli)

Steven Reynolds, Deputy Director, Division of Reactor Safety, Rlli pg"p9 Anton Ve9el, Chief, Branch 6, Rlli David Passehl, Project Engineer, Branch 6. Rlli gh '

Steven Campbell, Senior Resident inspector, Fermi 2, Rill You stated that at 1:45 p.m. on September 22,1999, penetration X-26 (drywell air purge) failed its local leak rate test (LLRT) performed in accord:nce with TS 4.6.1.8.2, requiring entry into

.TS 3.6.1.8, Action b.' Action b. required that the inoperable (i.e., high leakage) valve (s) be repaired within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, you would be required to place the plant in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and co!d shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Your staff determined that almost all of the leakage was through the inboard isolation valve (T4803F601) on penetration X-26 and that it was not possible to repair this valve without shutting the plant down.

You requested that a Notification of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.c of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective until the associated exigent TS amendment is issued and implemented. This letter documents our telephone conversation on September 23,1999, at 5:30 p.m., when we orally' issued this NOED.

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k c D.R. Gipson Licensee Event Descriotion and Evaluation Penetration X-26 has three isolation valves that are tested concurrently. The single inboard isolation valve is a 24-inch butterfly valve (T4803F601) and the two outboard isolation valves (in parallel) are a 24-inch butterfly valve (T4800F407) and a 10-inch butterfly valve (T4800F408).

.The piping configuration is such that the T4800F407 is open directly to secondary containment on one side. This configuration lends itself to a direct visualinspection of the valve seat.

T4800F408 connects to the nitrogen supply system. During leak testing, boundary valves are used to isolate T4800F408 from the nitrogen system. A vent valve between T4800F408 and the

= test boundary valves is used to depressurize and vent the piping outboard from T4800F408.

On September 22,1999, a LLRT was performed for penetration X-26 as required by TS

- Surveillance Requirement 4.6.1.8.2. This test is performed by pressurizing between the inboard and outboard isolation valves and measuring the total !eakage of the isolation valves. The penetration exceeded its TS limit of less than 0.05 L. (equivalent to 14.87 standard cubic feet per hour (SCFH)). The penetration leakage rate was 26.7 SCFH. Based on direct observation of T4800F407 and observation of an open %-inch vent connection outboard of T4800F408, test personnel determined that the ' penetration failed itt LLRT due to seat leakage through  !

T4803F601. Subsequently, valve T4803F601 was stroked under light pressure in an attem.9t to clear the sealing surfaces of any debris. The LLRT was performed again, and the leakage from

._p enetration X-26 increased to 82.85 SCFH. Since the only evolution performed between the two LLRTs was the stroking of T4803F601, this subsequent LLRT further substantiated that the leakage was attributable to T4803F601. Visual and audio inspection by a Level ll VT Inspector (utilizing Snoop, a soap bubble-type test, to aid in leak detection) for leakage at the exposed side of T4800F407 and at the vent connection outboard of T4800F408 during both tests on  ;

September 22,1999, revealed insignificant leakage relative to the measured leakage rates. A I Level lli VT Inspector confirmed the initial visual inspection and confirmed that T4800F407 and I T4800F408 were an insignificant contributor to the leakage during the second test. Snoop was J

. utilized to aid in leak detection during both tests. Snoop was applied to the seal of T4800F407 l

and minor bubbling was observed. It was also used at the vent connection outboard of l T4800F408 and no leakage was detected through this valve.

The licensee reviewed the LLRT and maintenance records and did not find any indication of an adverse trend for this penetration. Results of previous LLRTs for the penetration ranged between approximately 0.6 SCFH and 1.75 SCFH since October of 1998 (four tests). Failure of ,

T4803F601 was not anticipated and, based on the magnitude of the leak and the change in

- leakage following valve stroke, the licensee conc!uded that the likely cause of the leakage is failure of the seal. The seal was replaced during the Sixth Refueling Outage (autumn of 1998). '

Based on the previous test results, the licensee concluded that it is unlikely that the cause of this test failure is attributable to any valve other than T4803F601.

i The overall primary containment leakage allowed by TS 3/4.6.1.1 is 0.6 L,. This equates to i

'178 SCFH. The known leakage from containment prior to September 22,1999, was 67.28 SCFH, leaving 'a margin of 110.72 SCFH. The leakage from penetration X-26 is

. 82.85 SCFH, leaving a margin of 27.87 SCFH, when considering T4803F601 as a single boundary valve (i.e., not crediting the outboard valves). The outboard valves, when closed, would serve to significantly increase this' margin, even though the leakage through the outboard 4

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<- L D.R. Gipson - valves could not be quantifiedi in addition, with the penetration X-26 outboard valves closed, the licensee concluded that the leakage for this penetration remains well within the 0.05 L, limit associated with TS 3.6.1.8. The licensee concluded that the proposed action will not change the - .!

types or amounts of effluents that may be released o# site, nor increase individual or cumulative o

occupational radiation exposures, since the proposal is expected to maintain the overall leakage ,

of the penetration within the required limits, l The licensee's safety basis for this request is summarized as follows:

j The action to isolate the affected penetration using outboard isolation valves T4800F407 and T4800F408. While leak rate testing forthis penetration can not quantify the leakage of the outboard valves individually, the leakage rate through these isolation devices is believed to be well below the acceptance enteria, as discussed above. In addition, the -

compensatory action to verify the penetration is isolated on a periodic basis supports the T safety function of the valves to isolate following an accident. Reliability of the resilient seals in these valves and the other similar. penetrations at Fermi 2 has been high, providing confidence that unexpected degradation is not occurring in these valves.

T4803F601 is not a risk-significant component in the Level 1 Fermi 2 Probabilistic Safety i Analysis' (PSA). T4803F601 is not an initiator of an event that leads to core damage .

and does not mitigate a core damage event. The failure of T4803F601 has no effect on core damage and is not modeled in the Level 1 Fermi 2 PSA.

T4803F601 is a credited component of the Level 2 Ferm! 2 PSA. T4803F601 or the outboard isolation valves must close to isolate penetration X-26. The success criterion is that either inboard or outboard isolation valves in a line noust close and remain closed for 24 hcnrs. With the penetration isolated by the outboard isolation valves, the licensee concluoed that the failure of T4803F601 has no effect on the Level 2 PSA results and the success criteria for penetration X-26 is met and, therefore, failure of T4803F601 is not risk significant.

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In conjunction with the discretion granted in the NOED, the following compensatory actions will be' taken- l I

1. Isolation valves T4800F407 and T4800F408 (both normally closed) will remain closed and be deactivated, assuring the valves remain closed until T4803F601 is repaired.

T4800F407 and T4800F408 will not be cycled until the plant is shutdown to repair the  !

T4803F601.

2. Isolation valves T4800F407 and T4800F408 will be verified closed every 31 days.

' In simple terms, the Level 1 PSA evaluates the response of the plant to transients, expressed in the form of core camage frequency. The Level 2 PSA evaluates the containment t esponse to the events developed in the Level 1 PSA.

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3. Because the leakage through the outboard isolation valves cannot be individually t

quantified, a flanged cover will be installed over the opening of T4800F407 by

September 28,1999, to provide an additionalleakage barrier. This flange will remain in place until the plant is shutdown to correct the penetration leakage.

4. Leak testing of this penetration will be performed at least every 45 days to verify that the 0.6 L, is not exceeded due to additional penetration leakage. This testing will also qualitatively verify the integrity of the outboard isolation barriers (employing the visual and audio inspection techniques and Snoop similar to techniques used on September 22,1999, as described above).

The time requested for the NOED will allow time to obtain an exigent TS change. Detroit Edison

! submitted the amendment request on September 24,1999. The licensee has indicated that the compe.nsatory measures discussed above are already being implemented.

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l Criterion 1(a) of Section B.2 of the NOED guidance in NRC Inspection Manual Part 9900 is l applicable to this request. This criterion is intended to:

L avoid undesirable transients as a result of forcing compliance with the license condition and, thus minimize potential safety consequences and operational risks...

In this case, Fermi 2 is currently operating and unless this request is granted, would be required to shutdown. Assuming a required plant shutdown carries the same risk as a given inadvertent scram, the licensee concluded that the shutdown activity increases the potential risk compared to continued plant operation with T4803F601 leaking. Thus, this situation meets a criterion given in Section B of the NRC Guidance for Issuance of Enforcement Discretion. The NOED request was reviewed and approved by the Fermi 2 On-Site Review Organization.

NRC Staff Evaluation

. The NRC staff has reviewed your request for the NOED. The staff concludes that the Snoop testing results for outboard valve T4800F408 provide reasonable assurance that this valve is leak tight. While your staff estimated that the leakage through the other outboard isolation valve (T4800F407) was very low, the compensatory action of adding a blank flange to the end of that pipe will provide further assurance that there is little or r'o leakage through this portion of the peraatration. The blank flange was installed on September 25,1999. Maintaining these valves closed and deactivated and the blank flange in place should ensure that this portion of the containment boundary performs its design safety function if it is called upon. In addition, you will be leak-testing the penetration every 45 days. It is our understanding that the leakage obtained during this testing will be combined with the known leakage and compared to 0.6 L . This testing will ensure that any degradation in the outboard isolation valves / blank flange will not go undetected. As discussed during the telephone calls on September 23,1999, the existing TS will require that the leaking valve is repaired prior to restart if the plant shuts down for any reason before the next refueling outage. The staff concludes that the existing TSs, in conjunction with the compensatory actions, provide assurance that the safety function of the

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. D.R. Gipson -S-penetration will be met if it is called upon. The staff also concludes that this requests meets Criterion 1(a) of Section B.2 of the NOED guidance.

On the basis of the NRC staff's evaluation of your request, we have concluded that a NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact, is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion tsot to enforce compliance with TS 3.6.1.8, Action b., for penetration X-26 until the associated exigent TS amendment is issued and implemented. You submitted the request for the TS amendment on September 24,1999, and the NRC staff is reviewing it. The NRC staff plans to complete its review and issue the TS amendment within 4 weeks of the date of this letter.

As stated in the Enforcement Policy, action will be taken, to the extent that violations were

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involved, for the root cause that led to the noncompliance for which this NOED was necessary.

Sincerely, d w vL h2LCk ,

Suzann'e C. Black, Acting Director Project Directorate 111 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341 cc: See next page

J Mr. Douglas R. Gipson Fermi 2 Detroit Edison Company cc:

John Flynn, Esquire Senior Attomey Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological

. Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan ~ 48166 Monroe County Emergency Management .

Division 963 South Raisinville I Monroe, Michigan 48161 '

Regfanal Administrator, Region lil U.S. Nuclear Regulatory Commission j

801'Narrenville Road i Hle, Illinois 60532-4351 Norman K. Peterson

' Director, Nuclear Licensing Detroit Edison Company Fermi 2 - 280 TAC 6400 North Dixie Highway Newport, Michigan 48166 I

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' September 27,-1999 D.R. Gipson. -+. #

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penetr'a tion will be m if it is' called upon.' The' staff also concludes that this requests meets

Criterion 1(a) of Section B.2 of the NOED guidance '

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i On the basis of thd NRC staff's evaluation of your request, we have concluded that a NOED is warranted because we are clearly satisfied that this nction involves minimal or no safety impact, is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on public health and safety. Therefore;it is our intention to exercise discretion not to enforce compliance with TS 3.6.1.8, Action b., for penetration X-26 until the associated exigent TS amendment is issued and implemented. .You submitted the request for the TS amendment on September 24,1999,~ and the NRC staff is reviewing it. The NRC staff plans to complete its review and issue the TS amendment within 4 weeks of the date of this letter.

As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

Sincerely, ORIG. SIGNED BY Suzanne C. Black, Acting Director Project Directorate lil Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341 cc: See next page DISTRIBUTION:

Docket File PUBLIC OGC ACRS PD31 r/f . SCollins/RZimmerman BSheron JZwolinski

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~ Email: NOED

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DATE 09/ 2.7/99 09/rfl/99 09/ 27 /99 09/ 27 /99 09/ 1 7/99 , _

OFFICIAL RECORD COPY j

September 27, 1999 L

, D.R. Gipson l penetration will be met if it is called upon. The staff also concludes that this requests meets Criterion 1(a) of Section B.2 of the NOED guidance.

On the basis of the NRC staff's evaluation of your request, we have concluded that a NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact, is consistent with the Enforcement Policy and staff guidance, and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.6.1.0, Action b., for penetration X-26 until the associated exigent TS amendment is issued and implemented. You submitted the request for the TS amendment on September 24,1999, and the NRC staff is reviewing it. The NRC stafiplans to complete its review and issue the TS amendment within 4 weeks of the date of this letter.

As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

Sincerely, l

ORIG. SIGNED BY Suzanne C. Black, Acting D; rector i Project Directorate lil  !

Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341

cc

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Docket File PUBLIC C C k 'j OGC ACRS PD31 r/f SCollins/RZimmerman BSheron JZwolinski i RBorchardt, OE MGamberoni l RLobel JDyer, Rlil l MDapas, Rill AVegel, Rill j SCampbell, Rlli MSatorius, EDO

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DATE 09/ 2.7/99 09/M /99 09/ 27 /99 09/ 27 /99 09/Q /99 OFFICIAL RECORD COPY