ML20217E688

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Responds to 990609 Request for NRR to Determine Whether Requirements in Fermi 2 TS Action 3.8.1.1.c Apply to SLC Sys
ML20217E688
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/08/1999
From: Black S
NRC (Affiliation Not Assigned)
To: Grant G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20217E572 List:
References
FOIA-99-323 NUDOCS 9910200040
Download: ML20217E688 (3)
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D UNITED STATES

. NUCLEAR REGULATORY COMMISSION

.*- wAsHINeToN, D.C. SegeHOM July 8, 1999 4

MEMORANDUM TO: Geoffrey E. Grant, Director Division of Reactor Projects, Region lli .

FROM: Suzanne C. Black, Deputy Director -

Division of Licensing Project Management

. Office of Nuclear Reactor Regulation 4

SUBJECT:

TASK INTERFACE AGREEMENT (TIA)99-014, FERMI 2

'. NONCOMPLIANCE WITH TECHNICAL SPECIFICATION (TS)

' 3.8.1.1.c WITH STANDBY LIQUID CONTROL SYSTEM *B" AND EMERGENCY DIESEL GENERATOR (EDG) 11 INOPERABLE 4-

  • By a memorandum dated June 9,1999, you requested NRR to determine whether the requirements in Fermi 2 TS Action 3.8.1.1.c apply to the standby liquid control (SLC) system.

Background

  • When one or both EDGs in one of the onsite altomating current (ac) electrical power divisions becomes inoperable, Fermi 2 TS Action 3.8.1.1.c requires that witt.in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> all required systems, subsystems, trains, components and devices that depend on the remaining ac electrical power division as a source of emergency power are also operable. If this action is not completed, the Action statement goes on to require the licensee to place the plant in at least 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 in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

On May 3,1999, at 6:30 p.m., with the plant operating st full power, the licensee declared SLC

. system *B" inoperable and entered the 7-day Action requirements of TS 3.1.5.s.1 because a fuse opened in the squib valve monitoring circuit. Plant operators discussed this situation with the system engineer and concluded that tho' system was still capable of performing its design l

'lunction. However, no formal evaluation was performed and the operators did not declare the '

system operable. .

' On May 4,1999,' at 3:00 a.m., the licensee removed EDG 11 from service for a scheduled 4-  !

. day maintenance activity. EDG 11. supplies emergency electrical power for SLC system 'A." i

' As a result, the licensee placed itself in a configuration in which SLC system 'B' was inoperable i while the emergency electrical power source for SLC system "A" was inoperable. The licensee j did not believe that TS Action 3.8.1.1.c was applicable to this situation so they did not enter the i shutdown action statement *

" CONTACT: : A. Kugler, NRR 1 (301) 415-2828 x- 1 1

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- G. Grant -

' On May 4,1999, the licensee cycled the power supply breaker for SLC system "B" to replace the fuse, but the fuse continued to open because of a ground on an ammeter in the circuit.

Later the same day, at 8:35 p.m., the licensee tagged open the SLC system "B" power. supply breaker, which rendered the system incapable of being started manually until actions were
taken to clear the tag and close the breaker, The system remained inoperable with the supply.

breaker open until questions were raised by the NRC on May 5,199g, conceming this configuration and the applicability of TS Action 3.8.1.1.c. The operators subsequently closed the affec'ed breaker, reevaluated the status of SLC system "B" as being degraded but operable, and exited the required Actions of TS 3.8.1.1.c at 10:32 a.m. on May 5,190g. The documented engineering analysis justifying the operability of SLC system B' was completed at 4:00 p.m. on the same day.

Evaluation This situa(on was reviewed by the Technical Specifications Branch (TSB). TSB is of the opinion that the licensee was in violation of TS 3.8.1.1.c when it did not commence a plant

, . shutdown after EDG11 became inoperable with SLC system *B" inoperable, it is the TSB view that TS Action 3.8.1.1.c addresses all systems / components covered by the TS without regard to whether or not they are credited in the mitigation of a design basis accident (DBA). The SLC system is required by TS, as'well as by regulation. Therefore, the SLC system is. subject to the 1 provisions of TS 3.8.1.1.c. It is also the TSB view that the Fermi TS Bases do not alter the  !

above positions.- The Bases address the " safety function of critical systerns." The Bases do not l eisborate on what constitutes a critical system and, as such, do nat limit the TS applicability to systems / components credited for mitigating the consequences of a DBA. Therefore, TSB

. concludes that SLC is a critical system because it is covered by TS and required by regulations.

The Division of Licensing Project Management adds the following observations:

1, The licensee has indicated that it treats the SLC system as non-divisional in its training and maintenance programs. .This information is not germane to the current issue since the non-divisional status was established by the licensee and neither reviewed or  !

approved by the NRC, However, this information indicates a potential weakness in the j

,  : training and maintenance programs with respect to this system. i

2. The licensee indicated that it determined that the removal of SLC system "B" from service with EDG 11' inoperable was a low risk configuration based on the licensee's probabilistic risk assessment (PRA). Again, this information is not germane to the issue of whether a violation of the TS occurred. The TS were developed before the PRA was performed and .

. do not always reflect the risk significance of a configuration. This does not release the l

licensee from the requirements of the TS. However, the risk information can be  ;

considered in order tv determine the significance of a violation.

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<-PREBEOHHONAt:-!NFORMATION - LiiviiTED Di5TRiBUTiON-G. Grant 3- i l

l Conclusion I l

The licensee inappropriately failed to implement the required actions of TS Action 3.8.1.1.c i when both SLC system "B" and EDG 11 were inoperable on May 4 and 5,1999.

Docket No. 50-341 l

cc: R. Blough, RI L. Plisco, Ril .

K. Brockman, RIV l

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9 l

- PREUtGISIONAL INFORMATION - LIMll t:U Ui5TRICUPON - l l

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