ML20236R125

Notice of Violation from Insp Completed on 970922.Violation Noted:Licensee Made Revs to Procedures as Described in Safety Analysis Rept W/O Receiving Prior Commission Approval

ML20236R125
Person / Time
Site:	Fermi
Issue date:	07/15/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236R118	List: ML20236R116 ML20236R125
References
50-341-98-05, 50-341-98-5, NUDOCS 9807210253
Download: ML20236R125 (2)

Text

NOTICE OF VIOLATION Detroit Edison Company Docket No. 50-341 Fermi 2 License No. NPF-43 As a result of an NRC inspection completed April 13,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

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 Speci5 cations (TS).

Technical Specification 4.3.1.3 (License Amendment No.100) required that the REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip functional unit shall be demonstrated to be within its limit at least once per 18 months.

Technical Specification 4.3.2.3 (License Amendment No.100) required 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.

Technical Specification 4.3.3.3 (License Amendment No.100) required that the ECCS RESPONSE TIME of each ECCS trip function shall be demonstrated to be within its limit at least once per 18 months.

Contrary to the above, in February 1996, the licensee made revisions to procedures as described in the safety analysis report without receiving prior Commission approval, and the revisions had the effect of changing the Technical Specifications requirements.

Specifically, the licensee changed surveillance procedures which implemented the provisions of the Fermi 2 Technical Specifications 4.3.1.3,4.3.2.3, and 4.3.3.3. This resulted in the performance of instrument response time measurements during 1996, which were not in accordance with the above Technical Specifications requirements.

The testing did not include the time interval for sensor response in the response time measurement for certain instruments in the Reactor Protection System, Isolation Actuation System and the Emergency Core Cooling System. (01014)

This is a Severity Level IV Violation (Supplement 1)

Pursuant to the provisions of 10 CFR 2.201, Detroit Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility that is the i

subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the i

results achieved, (3) the corrective steps that will be taken to avoid further violations, and I (4) the date when full compliance will be achieved. Your response may reference or include l 9807210253 980715 PDR ADOCK 05000341 G PDR

i l

Notice of Violation previous docketed correspondence,if the correspondence adequately addresses the required response if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

l If you contest this enforcement action, you should also provide a copy of your response to the l Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001. l l

Because your response will be placed in the NRC Public Document Room (PDR), to the extent I possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your sesponse that deletes such information. If you request withholding of such material, you muit specifically identify the portions of your response that you week to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 15th day of June 1998 I

l i

I

_ _ _ _ _ - _ _ _ _ - - - _