NRC-97-0104, Responds to NRC Re Violations Noted in Insp Rept 50-341/97-11.Corrective Actions:Implemented New Corrective Action Program & Developed & Issued Procedure Re Effective Cause Analysis of Identified Conditions

Responds to NRC Re Violations Noted in Insp Rept 50-341/97-11.Corrective Actions:Implemented New Corrective Action Program & Developed & Issued Procedure Re Effective Cause Analysis of Identified Conditions

ML20202A733
Person / Time
Site:	Fermi
Issue date:	11/26/1997
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-97-0104, CON-NRC-97-104 50-341-97-11, NUDOCS 9712020204
Download: ML20202A733 (5)

Text

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. IMurJos R. Gipson

., Serder Vh e l'reshfent, Nm 1rar Generation fernd 2 rei North Irnie ltw) , New p,rt, W hic in 4 s t u; -

. . Tel 313 rM h201 rat ;tt a w 4172 Detroit Edison 10 CFR 2.201 November 26,1997 NRC-97-0104 U. S. Nuclear Regulatory Commission ,

Attn: Document Control Desk Washington D.C. 20555 1

References:

1) Fermi 2 NRC Docket No. 50 341 NRC Licerise No. NPF-43

2) NRC Inspection Report No. 50-341/97011 dated October 29,1997

3) NRC Letter dated October 9,1996, Request for Information Pursuant to 10 CFR 56.54(f) Regarding Adequacy and Availability of Design Basis information

4) Detroit Edison Letter to NRC, NRC-97-0039," Updated Final Safety Analysis R ;p% (USFAR) Vrjidation Initiative," date August 19,1997

Subject:

Reolv to Nctice of Violation 50-341/97011-02 Enclosed is Detroit Edison's response ta the Notice of Violation (NOV) contained in Reference 2. The following commitment is being made in this letter:

• A Technical Specification 'TS) change will be prepared and sut.mitted by April 1,1998 to revise TS 3.5.3.b.3 and other effected TS sections. Since changes to the Updated Final Safety Analysis Report (UFSAR) Sections 6.3.2.6 and 9.2.6.1 involve a change to the TS, they will be completed upon implementation of the TS change. g 9712020204 971126 1 PDR ADOCK 05000341 lhllhlllh hllfll

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1 NRC-97-0104 Page 2

.Should you have any questions regarding this respoase, please contact Noiman K.

Peterson, Director - Nuclear Licensing, at (313) 586-4258.

k Sincerely, ff Enclosure cc: A.B.Ileach

13. L. burgess D. R. Ilahn G.11arris A. J. Kugler M. V. 'ludasz, Jr.

Region til W .yne County Emergency Management Division o

t

Enclosure to NRC-97-0104 Page 1 of 3 Reply to Notice of Violation 97011-02 -

Statement of Notice of Violation:

10 CFR 50.9(a) requires, in part, that information required by statute, or by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.

The Technical Specifications are required by 10 CFR 50.36, while the Updated Final Safety Analysis Report is required by 10 CFR 50.34 and 50.71(e)

Contrary to the above, as of September 22,1997, information in the Technical Specifications and Updated Final Safety Analysis Report was not complete and accurate in all material respects. Specifically:

a) Technical Specification 3.5.3.b.3 was inaccurate in that it stated that the Condensate storage tank contained 300,000 available gallons, equivalent to a level of 18 feet.

Ilowever, a level of I 8 feet corresponded to, approximately, a maximum of 293,000 available gallons, b) Updated Final Safety Analysis Report Section 6 'l.2.6 was inaccurate in that it stated that the Condensate Storage Tank was designed to retain a minimum reserve of 150,000 gallons for use by the high pressure coolant injection or reactor core isolation cooling system.

c) Updated Final Safety Analysis Report Section 9.2.6.1 was inaccurate in that it stated that the Condensate Storage Tank was designed to deliver its last 150,000 gallons only to the high pressure coolant injection or reactor core isolation cocling systems.

In actuality, only approximately 105,000 gallons of the last 150,000 gallons could be delivered to the high pressure coolant injection or reactor core isolation cooling sys: cms.

Reason For The Violation:

This violation was the result ofinadequate Updated Final Safety Analysis Report (UFS AR) and Technical Specification (TS) review and inadequate implementation of corrective actions for discrepancies identified.

NRC Team Inspection was conducted at the Fermi 2 Nuclear Plant between July and September,1996. This inspection included a review of UFSAR and Design Basis Documents (DBDs) for the High Pressere Cooling Injection (HPCI) and Non-Interruptible Air Supply (NIAS) systems. As a result of the inspection, several errors and

Enclosure to NRC-97-0104 Page 2 of 3

' inconsistencies in these documents were identined. Deviation Event Reports (DERs) were initiated to address these and other inconsistencies. The results of the DER investigations relating to the Condensate Storage Tank (CST)" usable" volume cencluded that, from a technical standpoint, the CST met its design requirements because adequate water was available for operation of the systems it supported. No changes to the UFSAR or Technical Specifications were deemed necessary. The conclusion that no changes to the UFSAR or TS was based on the explanation that the CST "available" volume describes a gross available volume instead of a "usible" volume. This conclusion was erroneous.

Corrective Steps That llave then Taken and the Results Achb_ed On February 7,1997, Detroit Edison submitted its response to the NRC request for information regarding adequacy and accessibility of design bases inf 3rmation (Reference 3), in order to increase the level of confidence in the accuracy of the UFSAR, Detroit Edison committed to perform validation of the UFSAR and tc, improving the Corrective Action Program. While these initiatives may not have identified and corrected the specific discrepancies cited in this violation, they clearly indicate the ;evel ofimportance that Detroit Edison is placing on the accuracy of the UFSAR and Corrective Action Program. These two initiatives are summarized in the following pangraphs.

The plan for the UFSAR Validation Project (UVP) involves comparison of the ori;inal Final Safety Analysis Report (FSAR) and the NRC Safety Evaluation Report (SER) along with its suppkments, with the current UFSAR, plant procedures, and design documents. This comparison will result in a rebaselining of the UFSAR to provide further assurance that it is reDective of the plant and procedures, and that changes made since issuance of the 0,mrating License have been appropriately documented. Necessary updates to the UFSAR will be scheduled in accordance with the requirements of 10 CFR 50.71(e). Additional details are provided in Reference 4.

A new corrective action program was implemented on September 8,1997. This program has a lower threshold for conditions to be identified and entered into the corrective action system. In addition, a procedure was developed and issued which provides instructions, reviews, and other controls for effective cause analysis ofidentified conditions.

A Condition Assessment Resolution Document (CARD) has been written to address this specific issue and to track corrective actions. As a result of the initial operations assessment of this CARD, level in the Condensate Storage tank is being maintained at a level that ensures operability of the affected systems.

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Enclosure to NRC-97-0104 Page 3 of 3

' Corrective Steps That Will lie Taken To Avoid Further Violations A Technical Specification (TS) change will be prepared and submitted by April 1,1998 to revise TS 3.5.3.b.3 and other TS sections. Since changes to the Updated Final Safety Analysis Report (UFSAR) Sections 6.3.2.6 and 9.2.6.1 involve a change to the TS, they will be completed upon implementation of the TS change.

These changes will also address other references to CST volume contained in the TS and UFSAR.

Date When Full Compliance Will lle Achieved Full compliance will be completed when the UFSAR and TS changes are approved and implemented.

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