NRC-90-0111, Responds to Concerns Re Open Item 90-007-04,per NRC 900627 Request.Potential Enhancements to Drawings Being Reviewed & to Be Resolved by Dec 1990

Responds to Concerns Re Open Item 90-007-04,per NRC 900627 Request.Potential Enhancements to Drawings Being Reviewed & to Be Resolved by Dec 1990

ML20056A686
Person / Time
Site:	Fermi
Issue date:	08/03/1990
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-0111, CON-NRC-90-111 NUDOCS 9008090027
Download: ML20056A686 (5)

Text

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DekOll r. -i n Edison EsEni:22 August 3, iv90 W us.  :

i NRC-90-0111 i U. S. Nuclear Regulatory Commission Attention: Document Control Desk Nashington, D.C. 20555 ,

Reference:

1) Fermi 2 .

NRC Docket No. 50/341  ;

NRC License No. NPF-43 i

2) Licensee Event Report 90-003, NRC-90-0073-dated May 8, 1990 l

3) NRC Inspection Report No. 50-341/90007  !

dated June 27, 1990  !

Subject:

Response to Open Item 90-007-04 ,

In the cover letter for Reference 3, the NRC requestad that Detroit Edison provide a formal response to concerns related to Open Item 90-007-04 within 30 days. The due date for tnis response was extended by Region III management to August 3, 1990, due to a mail delay in the receipt of the Inspection Report.

There are two concerns that Detroit Edison was requested to address.

The first concern relates to actions necessary to ensure that the 1 Reactor Core Isolation Cooling System (RCIC) full flow test mode can t and will be used when operating in an emergency condition. The second l concern involves actions necessary to assure that operators are fully ',

cognizant of all Emergency Operating Procedure critical actions.

A. Use of the RCIC Test Mode An overall evaluation of the concerns noted during the use of the RCIC full flow test mode has been performed. The evaluation emphasized the i followirg three areas: '

o Verification of the procedure for use of this mode; o Evaluation of critical actions in Emergency Operating Procedures; and-o Engineering evaluation of identified system / component functional  ;

problems.

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1U. S. Nucle r Reguictory Co:cission LAugust 3,41990 NRC-90-0111-Page 2 ,

~On June 5, 1990,1the verification of procedure NPP-23 206, " Reactor  !

Core Isolation Cooling System", Section 7, (RCIC Test Mode), was  :

performed by Nuclear Operations. . The results of this verification l were as follows: -l v oi .Five' valid procedural concerns were identified, t

. o' Concerns in plant design which will require engineering evaluation {

were-identified.

fa o . Potential enhancements to drawings to clarify valve function were g identified.

!.- > None of these concerns are considered to.have identified condit, ions which hre safety significant. Four of the procedural concerns were -

l? resolved by revir'.... 't1 to NPP-23 206, which was approved on June 29, p 1990.: The remaining procedural concern will require further l evaluation prior to revising the procedure. It relates to precise pressures-when the minimum flow bypass valve operates. The procedure will~be revised to address this concern in the next major revision of l ~the procedure.

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-The design concerns which require engineering evaluation are as b Lfollows -

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$ ~o The power supply ~to the motor operator for valve E41-F011, High Pressure Coolant Injection (HPCI) pump test' return line to the t Condensate Storate Tank (CST) isolation valve, is normally de-energized. This valve must be operated to establish the test l mode flow path, o Valve E41-F011 canaot open with RCIC or HPCI discharge pressure on l

one side and the CST pressure on the-other. )

o. An additional concern on the use of RCIC with the barrmetric- ,

l condenser concensate and vacuum pumps out of service while reactor.

P -vessel ~ level is-above or below Level'1 has.been adequately evaluated. .

, Potential enhancements to drawings are being reviewed by Nuclear

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1 4 Engineering and'will be resolved by December of 1990.

. Additionally, a verification was performed for the HPCI full flow test, mode (reference NPP-23 202, Section 8) based "pon the common flow path with RCIC. As a result of this eview, several concerns aere

. identified. None of these concerns are considered to have identified conditions which are safety significant. They are categorized as follows:

o Sevenivalid procedural concerns, Several design concerns which require engineering evaluat,lon, and o.

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-_ o - ' Potential enhancements to drawings which require clarification of valve functions.

Five of the' procedural concerns were resolved in revision 38 of

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NPP-23 202, which.was approved on June 29, 1990. The remaining procedural concerns are being reviewed and will be-addressed in the.

next major' revision to the procedure. The remaining two concerns relate- to the fact that NPP-23 202 assumes that equipment is in its normal-mode of operation, which may not be the case in an emergency ocndit.ioni Specific concerns with use of the torus cooling mode and use of the turbine bypass; valves are also being addressed.

The design concerns ident'ified are the same as for RCIC with an

' ' additional concern relat,ing to the use of HPCI when the Standby Gas Treatment System is not operating. Some of the design concerns for HPCI are encompassed by one or more items relating to RCIC, which acccunts for the difference in the number of design concerns between the two systems.

Potential enhancements to-drawings are being reviewed and are expected to be resolved by December of 1990.

Following the event-described in Reference 2, NPP-23 206 was revised and Operations personnel received training on use of valve E41-F011 for reactor pressure control prior to restart of the plant. _The procedure-directs venting of the pump discharge line so that valve E41-F011 can be operated.

An evaluation of whether it is prudent to implement a design change to valve' E41-F011 is being performed. If it is decided that implementation is desirable, it will be scheduled in accordance with

-the Five Year Operating Plan for Fermi 2. If modifications are selected to resolve any of_the other design concerns, these too will be scheduled in accordance with the Fermi'2 Five Year Operating Plan,.

Upon completing an evaluation of the identified concerns, Operations personnel.will perform a re-verification of these procedures. The procedural concerns which have already been resolved enable the use of the full flow test moc ,. For any corredive actions requiring engineering design changes, this re-verification will be performed with the' system as it is currently designed to check that the full flow test mode can be used without implementation of any recommended

, design changes. Following a satisfactory verification of the

'1 procedures, the process will be validated using the simulator and/or plant as considered appropriate.

B. _ Operator Cognizance of Emergency Operating Procedures A review of the Emergency Operating Procedures (EOPs) was performed in a step-by-step process applying three critoria:

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y U. S. Nuclear Rrgu).ctory Conaission

!*- -August 3, 1990:

l{ NRC-90-0111 Page 4-o Known performance problems, o Step requires pre-planning to accomplish, and

- o Editorial - additional information needed.

If a step or section of an E0P met any of the criteria, it was flagged

, as requiring additional review.

-Review comments were categorized as follows

o Incorporation into training material, o Potential procedural' revisions, J- o Management position on method of standardization, and

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o' Potential human factors improvements.

None of the comments are considered to have identified conditions-which are safety significant.

- Recommended' areas for improvement are:

o Operator; training enhancements:-

- new or revised Job Parformance Heasures'(JPHs)~

- classroom presentation

- sia"lator training scenarios

- ' .21ator evaluation scenarios

- plant' walk-throughs

-- examination questions o Procedural enhancements:

- clarification of existing procedures:

- new procedures or sections to procedures o Determination of standard operating metbod.

6 o- Potential human factors improvements:

- new or. revised operator improvements

- plant modification tn enhance plant control Each of these items will be evaluated and a' determination will be made regarding their' benefits. Items identified as requiring action will be factored into the continuing Licensed Operator Requalification Program.

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, , . U. S. Nuclear Ragulatory CoImission-

'V August 3. 1990 NRC-90-0111-Page 5<

.- IT' there are any questions-relating to: thisiresponse, please contact

.n. PL;ricia Anthony, Compliance Engineer, at (313) 586-1617 or Terry Riley, Supervisor of Compllance, at (313) 586-1684.

Sint,erely/

J' y Oc t - A. B. Davis .

R. W. DeFayette .,

W. G.-Rogers "J. F. Stang

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Region III

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