ML20236R116
| ML20236R116 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/15/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| Shared Package | |
| ML20236R118 | List: |
| References | |
| 50-341-98-05, 50-341-98-5, EA-98-201, NUDOCS 9807210250 | |
| Download: ML20236R116 (3) | |
See also: IR 05000341/1998005
Text
.
,
July 15, 1998
EA 98-201
Mr. D. R. Gipson
Senior Vice President
Nuclear Generation
The Detroit Edison Company
6400 North Dixie Highway .
Newport, MI 48166
SUBJECT:
NRC INSPECTION REPORT 50-341/98005(DRS)
Dear Mr. Gipson:
On September 22,1997, the NRC completed an Engineering and Technical Support inspection
(Inspection Report 50-341/97011(DRS)) at your Enrico Fermi, Unit 2, facility. One of the issues
reviewed during that inspection, and subsequently addressed as an unresolved item, was your
practice to eliminate response time testing (RTT) for certain instruments in the Reactor
Protection, Isolation Actuation, and Emergency Core Cooling Systems per 10 CFR 50.59,
" Changes, Tests, and Experiments." However, resolution was deferred while the NRC
reviewed the generic applicability of this issue because of similar concems at several other
boiling water reactors.
A follow-up inspection (NRC Inspection Report 50-341/98005(DRS), March 20 - April 6,1998)
formally transmitted the NRC's decision relative to the generic concems. The conclusion was
that the elimination of RTT via 10 CFR 50.59 was not appropriate. The unresolved item was
addressed in the report as four apparent violations and you were requested to respond to the
apparent violations.
We subsequently met with you on May 6,1998, to discuss your: (1) evaluation of the causes of
the apparent violations, (2) corrective actions to prevent recurrence, and (3) understanding of
the safety and regulatory significance of the apparent violations. You stated that the cause of
the inadequate 10 CFR 50.59 evaluation was your staff's failure to recognize that instrument
response time testing was required by technical specifications and could not be eliminated by
10 CFR 50.59. You also indicated that the failure to conduct the testing at the appropriate
times was: (1) a direct result of an inadequata 10 CFR 50.59 evaluation, (2) that the safety and
, regulatory significance were minimal since instrumen' response time testing was being
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performed using NRC accepted methodology, and (3) significant degradation would have been
detected during other calibration and surveillance testing activities.
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D. Gipson
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Based on the information developed during the inspection, and our consideration of the
information provided in the May 6,1998, meeting, the NRC has determined that a violation of
NRC requirements occurred. A detailed description of the circumstances resulting in the
violation is described in the two referenced inspection reports. After our review of the
information you provided during the May 6,1998 meeting, Region 111 determined that the three
apparent violations for failure to conduct adequate response time testing were the direct result
of an inadequate 10 CFR 50.59 evaluation.
Normally, a violation for an inadequate 10 CFR 50.59 evaluation that results in a significant
failure to follow TS would be classified at Severity Level 111. However, in this case, the NRC has
determined that this violation does not constitute a significant regulatory concem and therefore
should be classified at Severity Level IV. The basis for this determination was: (1) your staff
was performing instrument response time testing for the affected systems in accordance with
methodology (NEDO-32291, *BWR Owners Group Licensing Topical Report") that was
approved in NRC Safety Evaluation Report, dated December 28,1994; (2) the safety
significance was low, since you were conducting calibration and surveillance tests that would
have detected degradation of the systems; (3) your methodology for testing was approved by
the NRC in a subsequent technical specification amendment; (4) the inadequate 10 CFR 50.59
evaluation was an isolated case and not reflective of a programmatic breakdown; and (5) there
was no adverse impact on plant safety or operability of the affected systems as demonstrated
by the testing methodology you had implemented.
The NRC acknowledges that you identified the inadequate 10 CFR 50.59 evaluation in
March 1997, and reported the issue to the NRC as required. Additional'y, the NRC finds your
corrective actions, as documented in your LER and as communicated at the May 6,1998
meeting, acceptable. Accordingly, the NRC is dispositioning this non-repetitive, licensee-
identified and corrected violation as a Non-Cited Violation, consistent with Section Vll.B.1 of the
Enforcement Policy. Accordingly, no response is required to this correspondence.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, the
enclosures, and your response will be placed in the NRC Public Document Room.
Sincerely,
Original /s/ J. A. Grobe
John A. Grobe, Director
Division of Reactor Safety
Docket No.: 50-341
License No.: NPF-43
Enclosure:
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cc w/ encl:
N. Peterson, Director
Nuclear Licensing
P. A. Marquardt, Corporate
Legal Department
Richard Whale, Michigan Public
Service Commission
Michigan Department of
Environmental Quality
Monroe County, Emergency
Management Division
Emergency Management
Division, MI Department
of State Police
Distribution:
J. Goldberg, OGC w/enci
J. Lieberman, OE w/enci
B. Boger, NRR w/enct
CAC (E-Mail)
Project Mgr., NRR w/enci
C. Paperiello, Rlli w/enci
J. Caldwell, Rlli w/ enc!
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B. Clayton, Rill w/ encl
SRI Fermi w/enci
DRP w/enct
TSS w/enci
DRS (2) w/enci
R!li PRR w/enci
PUBLIC IE-01 w/enci
Docket File w/enci
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GREENS
LEO (E-Mail)
DOCDESK (E-Mail)
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