ML20216B529
| ML20216B529 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/04/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| Shared Package | |
| ML20216B533 | List: |
| References | |
| 50-341-97-11, EA-97-479, NUDOCS 9803130111 | |
| Download: ML20216B529 (4) | |
See also: IR 05000341/1997011
Text
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March 4, 1998
EA 97-479
,
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:
, NRC PRE-DECISIONAL ENFORCEMENT CONFERENCE SUMMARY AND
NOTICE OF VIOLATION (INSPECTION REPORT NO. 50-341/97011(DRS))
Dear Mr. Gipson:
This refers to an inspection conducted from August 4,1997 through October 10,1997 at the
Enrico Fermi 2 Nuclear Power Plant (Fermi 2). An apparent violation, involving a change to the
emergency equipment cooling water (EECW) system that appeared to represent an unreviewed
safety question (USQ), was identified during this inspection. The exit meeting for this
- inspection was conducted on October 10,1997. The inspection report was mailed to Fermi 2
by letter dated October 29,1997. On November 18,1997, a predecisional enforcement
conference (PEC) was held in the NRC Region Ill office to discuss the apparent violation. The
attendance list and the slides used during your portion of the conference presentation are
enclosed with this letter.
Based on the information developed during the inspection and the information provided by
representatives of Fermi 2 at the PEC, the NRC has determined that a violation of NRC
requirements occurred. This violation involves the failure to perform an adequate safety
evaluation, such that it was not readily apparent that an USQ did not exist. During and after the
conference, members of the Fermi 2 staff presented additional information as to why an USQ
did not exist.
The issue involved a 1995 safety evaluation for a modification to the plant to allow use of the
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safety-related EECW system to supplement the non-safety-related reactor building closed
cooling water (RBCCW) system during normal operation. This operational modification was
primarily to ensure adequate drywell cooling during hot weather conditions. Prior to that time,
EECW would be automatically initiated on: (1) high drywell pressure, (2) loss of offsite power,
and (3) loss of RBCCW. Although manualinitiation was available, it was not used during
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normal operation, other than for testing purposes. Initiation of EECW, either by automatic or
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manual means, would isolate several non-ssfety-related loads, especially control rod drive
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motor cooling. In order to use the EECW to augment RBCCW, operators would be required to
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restore these non-safety-related loads following manual initiation. When the safety evaluation
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was first approved, the Fermi 2 engineering staff assumed that any accidents would result in
automatic initiation of EECW, along with re-isolation of the non-safety-related loads.
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D. R. Gipson
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March 4, 1998
In 1996, the NRR Project Manger identified the potential for an accident scenario outside
containment which would not re-isolate the non-safety-related loads. In following up on this
concem, engineering personnel performed a worst-case computer analysis and determined
that, during a high energy line break and without a concurrent loss of offsite power, some
components cooled by EECW apparently would not reosive adequate flow to handle their
design-basis heat load. To rectify this condition, the engineers determined that operator action
to rainitiate EECW following a high energy line break was necessary. The safety evaluation
was revised accordingly.
During review of the revised safety evaluation, the inspectors questioned whether a new EECW
failure mode had been introduced. The change to the facility to permit augmentation of
RBCCW normal loads by the EECW system potentially introduced an USQ because there was
now a possibility of a malfunction of a safety-related system that was different than that
evaluated in the safety an.Jysis report. It appeared that, when EECW augmented RBCCW, a
loss of RBCCW would not automatically start EECW and the non-safety-loads would not be
isolated, depriving the essentialloads of adequate cooling. This scenario was not previously
evaluated.
During the PEC, members of the Fermi 2 staff presented the results of additional analyses
which showed that the operator actions were not actually necessary following a high energy line
break. Based on this more realistic modeling of the post-accident heat sources, the staff was
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able to confirm that the safety related loads would still have received adequate cooling, even if
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the operators had not taken the procedurally required actions. Although this end result was
fortunate, the NRC is concemed that the Fermi 2 staff did not recognize that the Interim safety
evaluation, which concluded that operator action was necessary to ensure adequate cooling to
safety-related loads, posed an apparent USQ, based upon procedural guidance, and did not
take steps to resolve that discrepancy. The NRC depends on a licensee performing an
adequate safety analyses to determine whether or not an USQ exists. A licensee's safety
analysis for the existence of an USQ is fundamental to ensuring the bases on which the plant
was licensed are maintained. NRC determined that a major factor leading to the inadequate
analysis was an engineering mind set that use of operator actions was acceptable. Therefore,
the initial Fermi 2 analyses were done to show that sufficient time existed for the operator to
take action under an extreme set of heat load conditions, rather than to evaluate whether
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operator actions were truly necessary. Once NRC questioned this premise, the Fermi 2
engineers identified the conservatism in the analyses, and, based on engineering judgement of
the extent of the conservatisms, determined that sufficient flow would be available for
equipment cooling. This engineering judgement was then promptly confirmed through
computer analyses.
Therefore, after consultation with the Director, Office of Enforcement and in accordance with
the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600
(Enforcement Policy), the violation was categorized at Severity Level IV. This decision was
based on: 1) a detailed evaluation not being needed to resolve the matter; 2) the operator
actions not being necessary; and 3) given the time frame available, had the operators taken the
actions specified by the procedure, there was little likelihood of either operator error or adverse
consequences in taking the actions specified.
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D. R. Gipson
3
March 4, 1998
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During the conference, members of the Fermi 2 staff identified immediate corrective actions
including: restricting use of the EECW system in the augmentation mode, communication of
the safety evaluation deficiencies to all preparers and a review of other safety evaluations as
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part of the overall 10 CFR 50.59 upgrade program. The staff members also noted that all
safety evaluations were being approved by an engineering manager to ensure overall quality.
Also discussed were efforts to upgrade the 10 CFR 50.59 process. These included a reduced
number of preparers; additional training, with an emphasis on licensing basis documents;
procedural upgrades; and updated search capabilities. Finally, the staff noted that Fermi 2 was
participating in the industry initiatives on 10 CFR 50.59, and were performing a validation of the
updated final safety analysis report to remove inconsistencies. These corrective actions appear
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acceptable.
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You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. In your response, you should document the
specific actions taken and any additional actions you plan to prevent recurrence. Your
response may reference or include previous docketed correspondence, if the correspondence
adequately addresses the required response. After reviewing your response to this Notice,
including your proposed corrective actions and the results of future inspections, the NRC will
determine whether further NRC enforcement action is necessary to ensure compliance with
NRC regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules and Practice," a copy of this letter and its
enclosures will be placed in the NRC Public Document Room (PDR). To the extent possible,
your response should not include any personal privacy, proprietary, or safeguards .nformation
so that it can be placed in the PDR without redaction.
Sincerely,
original signed by H. O. Christenseng
John A. Grobe, Director
Division of Reactor Safety
Docket No. 50-341
License No. NPF-43
Enclosures:
2. List of Attendees at Predecisional Enforcement Confesace
3. Licensee Slides Presented at Predecisional Enforcement Conference
cc w/encis:
N. Peterson, Supervisor of Compliance
P. A. Marquardt, Corporate Legal Department
Richard Whale, Michigan Public
Service Commission
Michigan Department of Public Health
Monroe County, Emergency Management Division
See Attached Distribution
DOCUMENT NAME: G:\\DRS\\FER02278.DRS
To receive a copy of this document. Indicate in the box "C" = Copy w/o attach /enci"E" = Copy w/ attach! enc'"N" = No copy
OFFICE
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DATE
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OFFICIAL RECORD COPY
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D. R. Gipson
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March 4, 1998
Distribution
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Rlli Enf. Coordinator w/encls
PUBLIC IE-01 w/encls
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