ML20216E549
| ML20216E549 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/10/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| References | |
| 50-341-97-11, NUDOCS 9804160240 | |
| Download: ML20216E549 (2) | |
See also: IR 05000341/1997011
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April 10, 1998
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Mr. D. R. Gipson
Senior Vice President
- Nuclear Generation
The Detroit Edison Company
6400 North Dixie Highway
Newport, MI 48166
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-341/97011(DRS)
Dear Mr. Gipson:
This will acknowledge receipt of your letter dated April 3,1998, in response to our letter
dated March 4,1998, transmitting a Notice of Violation associated with the emergency core
cooling water system at the Fermi 2 Nuclear Plant. 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 /s/ J. A. Grobe
John A. Grobe, Director
Division of Reactor Safety
Docket No.: 50-341
Enclosure:
Ltr dtd 4/3/98 from D. R. Gipson,
Detroit Edison to iJSNRC
See Attached Distribution
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April 3,1998
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 Predecisional Enforcement Conference Summary and .
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Notice of Violation (Inspection Report 50-341/97011),
, dated March 4,1997
3) Detroit Edison letter to NRC, NRC 97-0006, "The Detroit Edison
(Fermi-2) Response to Request for Information Pursuant to
10 CFR 50.54 (f) Regarding Adequacy and Availability of Design
Bases Information," dated February 6,1997
4) Detroit Edison letter to NRC, NRC 97-0039," Updated Final
Safety Analysis (UFSAR) Initiative," dated August 19,1997
Subject:
Reolv to Notice of Viobtion 50-341/EA 97-479
$nclosed is Detroit Edison's response to the Notice of Violation (NOV) contained in
Reference 2. As stated in Reference 2, the aspects of this violation and actions
being taken by Detroit Edison were presented at a predecisional enforcement
conference conducted in the NRC Region III office on November 18,1997. The
. response to this violation documents the discussions and activities as presented
during that predecisional enforcement conference. There are no new commitments
made in this letter.-
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As stated at the predecisional enforcement conference and reiterated in the cover
letter of Reference 2, Detroit Edison understands and recognizes the importance of
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the 10 CFR 50.59 process in preserving conformance with the design / licensing basis
of Fermi-2 consistent with the theme of the Reference 3. A number ofinitiatives
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presently in progress to in. prove the 10 CFR 50.59 process at Fermi-2 were
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discussed during the predecisional enforcement conference and in Reference 2.
Detroit Edison would like to clarify the statement made in the cover letter for the
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' Notice of Violation. - The cover letter states the safety evaluations at Fermi-2 are
being approved by "an engineering manager." Safety Evaluations prepared within
the engineering department are approved by a qualified member of engineering
management (supervisor, director, manager), reviewed by the Onsite Safety Review -
' Organization (OSRO); and approved by the Plant Manager.
Should you have questions regarding this response, please contact Norman K.'
Peterson, Director, Nuclear Licensing, at (734) 586-4258.
Sincerely,
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Enclosure -
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B. L. Burgess -
G. A. Harris
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Enclosure
Page1of3
Reply To Notice Of Violation 50-341/EA 97-479
Statement Of Notice Of Violation
10 CFR 50.59 permits the licensee, in part, to make changes to the facility, and procedures, as
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described in the safety analysis report, without prior Commission approval, provided the changes
do not involve an unreviewed safety question.' Records of these change's must include a written
safety evaluation which provides the bases for the determination that the changes do not involve .
an unreviewed safety question.
10 CFR 50.59(a)(2) states, in part, that a proposed change shall be deemed to involve an
unreviewed safety question if a possibility for an accident or malfunction of a different type than
any evaluated previously in the safety analysis report may be created.
The Fermi Updated Final Safety Analysis Report, Revision 7, Section 9.2.2.2, " System
Description," stated, in part, that during nonnal plant operation, both emergency equipment
cooling water divisions were isolated from the reactor building closed cooling water system.
It further noted that the emergency equipment cooling water system would automatically activate
upon failure of the reactor building closed cooling water system.
Contrary to the above, Safety Evaluation 95-0036, Revision 0, approved by the licensee on
July 14,1995, which evaluated a change to the facility as described in the updated final safety
analysis report to permit operation of the emergency equipment cooling water system during
normal plant operation to supply non-safety-related loads, was inadequate in that an incomplete
analysis was performed. Specifically, the analysis did not consider all scenarios in providing the
bases for the determination that an unreviewed safety question did not exist.' For a high energy
line break outside containment without a concurrent loss of offsite power, the change resulted in
bypassing an automatic actuation of the system due to loss of the reactor building closed cooling
water system. This resulted in operator actions being specified to resolve an apparent lack of
cooling to safety related equipment, a scenario not previously evaluated.
Reason For The Violation
'Ihe failure of Safety Evaluation (SE) 95-0036, Revision 0, to address the scenario of a high
energy line break outside containment without a loss of offsite power and its resuhing impact of
bypassing an at.tomatic actuation of the Emergency Essential Cooling Water (EECW) system to
isolate Reactor Building Closed Cooling Water (RBCCW) system loads was due to inconsistent
levels of performance in the preparation of Preliminary Evaluations (pes) and SEs at Fermi-2 at
the time of the subject SE preparation. The 10 CFR 50.59 program (PE/SE Program) at the time
placed a high degree of reliance on individual knowledge and experience in the preparation of
pes and SEs. While the overall level of performance of pes and SEs was considered adequate,
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' Enclosure
Page 2 of 3
the degree of programmatic guidance and individual knowledge created the potential for
incomplete or inadequatelyjustified pes and/or SEs. This indicated a need for improvement in
procedures and training in understanding the scope of the licensing basis documents and
' documenting this basis in pes and SEs to ensure thoroughness and consistency in answering
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Corrective Actions Taken Anti The Results Achieved
Following identification of the omission of consideration of the high energy line break scenario
in 19%, SE 95-0036 was revised .o include instructions for the re-isolation of nonessential loads
' if EECW had been initiated manually, nonessential loads had been unisolated, and a subsequent
high energy line break was experienced. Detroit Edison understands that the revision of -
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SE 95-0036 in 1996 to. include consideration of the high energy line break introduced operator
actions that were not appropriatelyjustified in the SE revision. These issues were addressed at
the predecisional enforcement conference. The SE has not yet been revi: i pending the
completion of further evaluations as cited below. In the interim, Operatic is Procedure SOP
- 23.127 has been revised to caution against the use of EECW to augment RBCCW during' normal
plant operation. The procedure also requires that the affected EECW subsystem (s) be declared
inoperable when restoring nonessential RBCCW loads.' The use of the procedure will remain
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restricted until the evaluation'of the EECW operating mode is completed and necessary licensing
document changes are made.
Immediately after the cited violation (then categorized as an apparent violation) was
. communicated to Detroit Edison on November 3,1997, Detroit Edison initiated an assessment of
past operability of the EECW. Detroit Edison considered several scenarios as tabulated on Slide
7 of the enclosure to Reference 2. From this, it was determined that past operation had not
resulted in a loss of safety function or inoperability of EECW.
The issues of this SE were communicated to personnel who were involved in the preparation and
review of the SE. Additionally, before any in-process SE was presented for approval to the
Onsite Safety Review Organization (OSRO),' personnel performinF SEs were required to attend
training sessions to be presented the lessons learned from this SE. This training was also
provided to OSRO members and Nuclear Safety Review Group (NSRG) members.
. Approximately 25 previously performed SEs were independently reviewed as part of the ongoing
10 CFR 50.59 improvement process (pursuant to Reference 3), revealing no examples of
' inadequately supported conclusions that an unreviewed safety question was not inv'olved.
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Enclosure
Page 3 of 3
Corrective Action To Be Taken To Avoid Further Violations
As another part of the aforementioned 10 CFR 50.59 improvement process, the PE/SE program
- is being upgraded to increase the level of knowledge and experience of personn-1 who may be
qualified as PE/SE preparers / reviewers. This will ensure that those who perform pes /SEs are of
the highest l quality in terms of understanding the licensing and design basis of Fermi-2.
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The PE/SE training program has been upgraded to include extensive licensing basis training.
Initial training for PE and SE preparers and reviewers is in progress and is expected to be
completed in the third quarter of 1998. In addition, segregated advanced classroom training is
provided for PE and SE qualified individuals which emphasizes written problems and exercises.
Detroit Edison is following the activities of the Nuclear Energy Institute (NEI) 10 CFR 50.59
Task Force in its interactions with the NRC As new guidance is developed on 10 CFR 50.59
performance it is reviewed and incorporated into the PE/SE Program at Fermi-2 as appropriate.
The Updated Final Safety Analysis Report (UFSAR) Validation program, as cited in Reference 3,
is intended to identify and correct discrepancies in the UFSAR. -In parallel with this effort and to
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improve accessibility oflicensing basis information for PE and SE preparers and reviewers, -
docketed correspondence between NRC and Detroit Edison is being converted into an
electronically searchable format. This will expand the existing electronically searchable forms of
the UFSAR and NRC Safety Evaluation Reports and Supplements.
Date When Full Compliance Will Be Achieved
Full compliance was achieved when SE 95-0036 was revised to include consideration of the high
energy line break without loss of offsite power, and when Operations Procedure SOP 23.127 was
revised to restrict use of EECW to augment RBCCW.
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