ML20216E790
| ML20216E790 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/10/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216E774 | List: |
| References | |
| 50-341-98-05, 50-341-98-5, NUDOCS 9804160298 | |
| Download: ML20216E790 (5) | |
See also: IR 05000341/1998005
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U.S. NUCLEAR REGULATORY COMMISSION
REGIONlil
Docket No:
50-341
License No:
Report No:
50-341/98005(DRS)
Licensee:
Detroit Edison Company (DECO)
Facility:
Enrico Fermi, Unit 2
Location:
6400 N. Dixie Hwy
Newport, MI 48166
Dates:
March 20 - April 6,1998
Inspectors:
R. A. Westberg, Reactoi L, gineer, Rill
Approved by:
John M. Jacobson , Chief, Lead Engineers Branch
Division of Reactor Safety
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EXECUTIVE SUMMARY
Enrico Fermi, Unit 2
NRC inspection Report 50-341/98005
This inspection reviewed and assessed a generic concern with the apparent inappropriate
removal of Response Time Testing from the Technical Specifications for sensors in the ECC,
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isolation actuation, and RP systems via the 50.59 process.
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Failure to demonstrate that reactor protection system trip function units were within their
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response time limit at least once per 18 months was an apparent violation of TS 4.3.1.3
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(Section E8.1).
Failure to demonstrate that isolation actuation trip units were within their response time
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limit at least once per 18 months was an apparent violation of TS 4.3.2.3 (Section E8.1).
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Failure to demonstrate that isolation emergency core cooling system trip units were
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within their response time limit at least once per 18 months was an apparent violation of
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TS 4.3.3.3 (Section E8.1).
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Removal of response time testing for sensors in the reactor protection, emergency core
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cooling, and isolation actuation systems from the technical specifications, without prior
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NRC approval, was an apparent violation of 10 CFR 50.59 (Section E8.1).
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Report Details
Engineering
E8
Miscellaneous Engineering issues
E8.1
(Closed) Unresolved item 50-341/97011-01: Generic concem with removal of response
time testing from the technical specifications (TS) for sensors in the emergency core
cooling system (ECCS), isolation actuation, and reactor protection system (RPS) via the
50.59 process.
On June 29,1994, the NRC issued Amendment 100 to the Fermi 2 Operating License,
consisting of a TS revision to relocate the response time limit tables to the updated final
safety analysis report (UFSAR).
On August 22,1994, the licensee relocated response time tables for the ECCS, RPS,
and isolation actuation instrumentation from the TS to the UFSAR to allow RTT limits to
be controlled in accordance with provisions of 10 CFR 50.59 in Licensing Change
Request 94-054-UFS.
On January 26,1996, the licensee prepared Safety Evaluation 95-0053 Revision 0, to
revise the UFSAR and technical requirements manual to eliminate RTT for selected
instruments.
On February 6,1996, the onsite review organization approved Safety Evaluation
95-0053.
On February 29,1996, the licensee issued Licensing Change Request 95-113-UFS to
eliminate selected RTT requirements from the UFSAR.
On June 26,1996, the licensee did not perform RTT procedures 44.010.009,010,023,
and 024; 44.020.011,014,045, & 046; and 44.030.261, and 262 prior to their critical
performance date.
On June 28,1996, the licensee did not perform RTT procedure 44.030.308 prior to its
critical performance date
On July 16,1996, the licensee did not perform RTT procedure 44.030.307 prior to its
critical performance date.
a.
Technical Specification 4.3.1.3 requires that the reactor protection system response
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time of each reactor trip functional unit shall be demonstrated to be within its limit at
least once per 18 months.
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Technical Specification 1.33 defines reactor protection system response time to be the
time interval from when the monitored parameter exceeds its trip setpoint at the channel
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sensor until deenergization of scram pilot valve solenoids. The response time may be
measured by any series of sequential, overlapping or total steps such that the entire
response tim'e is measured.
As of March 19,1997, the licensee had not demonstrated that each reactor trip
functional unit was within its response time limit at least once per 18 months, because
the sensor v!as not included in the demonstration of response time. Specifically, the
licensee performed measurements in 1996 which were not in accordance with the above
technical specification requirements, in that the measurements did not include the time
interval for sensor response in the reactor protection system reesponse time
measurement. Instead, the licensee qualitatively confirmed sensor response to an
input, which did not demonstrate that the response time limits required by the technical
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specifications were met. The affected reactor trip functional units are Reactor Vessel
Steam Dome Pressure - High and Reactor Vessel Low Water Level- Level 3.
Failure to demonstrate that these RPS trip function units were within their response time
limit at least once per 18 months is an apparent violation of TS 4.3.1.3 (eel
50-341-98005-01)
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b.
Technical Specification 4.3.2.3 requires that the isolation system response time of each
isolation trip function shall be demonstrated to be within its limit at least once per 18
months.
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Technical Specification 1.16 defines isolation system response time to be the time
interval from when the monitored parameter exceeds its isolation actuation setpoint at
the channel sensor until the isolation valves travel to their required positions. The
response time may be measured by any series of sequential, overlapping or total steps
such that the entire response time is measured.
As of March 19,1997, the licensee had not demonstrated that each isolation trip
function was within its response time limit at least once per 18 months, because the
sensor and related instruments were not included in the demonstration of response
time. Specifically, the licensee performed measurements in 1996 which were not in
accordance with the above technical specification requirements, in that the
measurements did not include the time interval for sensor and related instrument
response in the isolation system response time measurement. Instead, the licensee
qualitatively confirmed sensor and related instrument response to an input, which did
not demonstrate that the response time limits required by the technical specifications
were met. The affected primary containment isolation trip functions were Reactor
Vessel Low Water LeveJ - Level 1 and Main Steam Line Flow - High.
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Failure to demonstrate that these isolation trip functions were within their response time
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limit at least once per 18 months is an apparent violation of TS 4.3.2.3 (eel
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50-341-98005-02)
c.
Technical Specification 4.3.3.3 requires that the ECCS response time of each ECCS trip
function shall be demonstrated to be within its limit at least once per 18 months.
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TS 1.11 defined the ECCS response time as that time interval from when the monitored
parameter exceeded its actuation setpoint at the channel sensor until the ECCS
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equipment was capable of performing its safety function, i.e., the valves traveled to their
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required positions, pump discharge pressures reached their required values, etc. Times
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included diesel generator starting and sequence loading delays, where applicable. The
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response time might be measured by any series of sequential, overlapping or total steps
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such that the entire response is measured.
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As of March 19,1997, the licensee had not demonstrated that each ECCS trip function
was within its response time limit at least once per 18 months, because the actuation
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instrumentation was not included in the demonstration of response time. Specifically,
the licensee performed measurements in 1996 which were not in accordance with the
above technical specification requirements, in that the measurements did not include the
time interval for actuation instrumentation response in the ECCS response time
measurement. Instead, the licensee qualitatively confirmed actuation instrumentation
response to an input, which did not demonstrate that the response time limits required
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by the technical specifications were met. The affected ECCS trip functions were
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Reactor Vessel Low Water Level - Level 1, Drywell Pressure - High, and Reactor Vessel
Low Water Level - Level 2.
Failure to demonstrate that these ECCS trip functions were within their response time
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limit at least once per 18 months is an apparent violation of TS 4.3.3.3 (eel
50-341-98005-03)
d.
10 CFR 50.59 states, in part, that a licensee may make changes in procedures as
described in the safety analysis report without prior Commission approval, unless the
proposed change involves a change in the technical specifications incorporated into the
license.
In February 1996, the licensee made changes to Procedure Nos. 44.010.009-12;
44.010.021-024; 44.020.011-014; 44.020.043-046; 44.030.259-262; and 44.030.307-
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310, which are described in the safety analysis report, to eliminate RTT for trip
functional units in the RPS and for trip units in the isolation and core cooling systems.
Prior Commission approval was not sought and these changes had the effect of
changing technical specification requirements. This is considered an apparent violation
of 10 CFR 50.59 (eel 50-341-98005-04).
V. Management Meetings
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Exit Meeting Summary
The inspectors conveyed the NRC's conclusion regarding four apparent violations involving
inappropriate elimination of response time testing from the technical specifications via the 50.59
process to licensee representatives during a telephonic exit on April 6,1998. The licensee
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acknowledged the findings and did not indicate that any materialr examined during the
inspection should be considered proprietary.
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