NRC-98-0054, Responds to NRC Re Violations Noted in Insp Rept 50-341/97-11.Corrective Actions:Initiated Assessment of Past Operability of Eecw,Communicated Issues of SE to Personnel & Reviewed 25 Previously Issued Ses,Per 10CFR50.59
| ML20217P990 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/03/1998 |
| From: | Gipson D DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-98-0054, CON-NRC-98-54 50-341-97-11, EA-97-479, NUDOCS 9804100257 | |
| Download: ML20217P990 (5) | |
Text
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Douglas it. Gipson Senior Vice President, Nuclear Generation
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fernti 2 64fH) North liixie llwy, Newport, Michigan 48166 Tel:313.M61,201 fax:313A%4172 Detroit Edison 10 CFR 2.201 April 3,1998 NRC 98-0054 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) NRC Predecisional Enforcement Conference Summary and Notice of Violation (Inspection Report 50-341/97011),
dated March 4,1997
- 3) Detroit Edison letter to NRC, NRC 97-0006, "The Detroit Edison l-(Fermi-2) Response to Request for Information Pursuant to l
10 CFR 50.54 (f) Regarding Adequacy and Availability of Design l
Bases Information," dated February 6,1997
- 4) Detroit Edison letter to NRC, NRC 97-0039, " Updated Final Safety Analysis (UFSAR) Initiative," dated August 19,1997 Srbject:
Reolv to Notice of Violation 50-341/EA 97-479 Enclosed is Detroit Edison's response to the Notice of Violation (NOV) contained in Reference 2. As stated in Reference 2, the aspects of this violation and actions being taken by Detroit Edison were presented at a predecisional enforcement conference conducted in the NRC Region III office on November 18,1997. The response to this violation documents the discussions and activities as presented i
during that predecisional enforcement conference. There are no new commitmer:ts \\f made in this letter, g
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NRC-98-0054 Page 2 4
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As stated at the predecisional enforcement conference ana reiterated in the cover letter of Reference 2, Detroit Edison understands and recognizes the importance of the 10 CFR 50.59 pmcess in preserving conformance with the design / licensing basis of Fermi-2 consistent with the theme of the Reference 3. A number ofinitiatives presently in progress to improve the 10 CFR 50.59 process at Fermi-2 were discus.=ad during the predecisional enforcement conference and in Reference 2.
Detroit Edison would like to clarify the statement made in the cover letter for the Notice of Violation. The cover letter states the safety evaluations at Fermi-2 are being approved by "an engineering manager." Safety Evaluations prepared within the engineering department are approved by a qualified member of engineering management (supervisor, director, manager), reviewed by the Onsite Safety Review
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Organization (OSRO), cad approved by the Plant Manager.
l Should you have questions regarding this response, please contact Norman K.
Peterson, Director, Nuclear Licensing, at (734) 586-4258.
i Sincerely, l
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f-Enclosure i
cc: A. B. Beach D. L. Burgess
.G. A. Harris A. J. Kugler -
M. V. Yudasz, Jr.
Region III Wayne County Emergency Management Division b
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~ Enclosure
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Renly To Notice Of Violation 50-341/EA 97-479 Statement Of Notice Of Violation 10 CFR 50.59 permits the licensee, in part, to make changes to the facility, and procedures, as described in the safety analysis report, without prior Commission approval, provided the changes do not involve an unreviewed safety question. Records of these changes must include a written safety evaluation whiah provides the bases for the determinction that the changes do not involve an unreviewed safety question.
10 CFR 50.59(a)(2) states, in part, that a proposed change shall be deemed to involve an unreviewed safety question if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.
' The Fermi Updated Final Safety Analysis Report, Revision 7, Section 9.2.2.2, " System Description," stated, in part, that during normal plant operation, both emergency equipment cooling water divisions were isolated from the resctor building closed cooling water system.
It further noted that the emergency equipment cooling water system would automatically activate upon failure of the reactor building closed cooling water system.
Contrary to the above, Safety Evaluation 95-0036, Revision 0, approved by the licensee on July 14,1995, which evaluated a change to the facility as described in the updated final safety analysis report to permit operation of the emergency equipment cooling water system during normal plant operation to supply non-safety-related loads, was inadequate in that an incomplete analysis was performed. Specifically, the analysis did not consider all scenarios in providing the j.
' bases for the determination that 'an unreviewed safety question did not exist. For a high energy l-line break outside containment without a concurrent loss of offsite power, the change resulted in bypassing an automatic actuation of the system due to loss of the reactor building closed cooling water system. This resulted in operator actions being specified to resolve an apparent lack of cooling to safety-related equipment, a scenario not previously evaluated.
Reason For The Violation
' The failure of Safety Evaluation'(SE) 95-0036, Revision 0, to address the scenario of a high energy line break outside containment without a loss of offsite power and its resulting impact of bypassing an automatic actuation of the Emergency Essential Cooling Water (EECW) system to isolate Reactor Building Closed Cooling Water (RBCCW) system loads was due to inconsistent levels of performance in the preparation of Preliminary Evalettions (pes) and SEs at Fermi-2 at the_ time of the subject SE preparation. The 10 CFR'50.59 program (PE/SE Program) at the time 4
placed a high degree of reliance on individual knowledge and experience in the preparation of pes and SEs. While the overall level of performance of pes and SEs was considered adequate, r
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NRC-98-0054 Enclosure Page 2 0f 3 the degree of programmatic guidance and individual knowledge created the potential for incomplete or inadequatelyjustified pes and/or SEs. This indicated a need for improvement in procedures and training in understanding the scope of the licensing basis documents and documenting this basis in pes and SEs to ensure thoroughness and consistency in answering each PE and SE question.
Corrective Actions Taken And The Results Achieved Following identification of the omission of consideration of the high energy line break scenario in 1996, SE 95-0036 was revised to include instructions for the re-isolation of nonessential loads if EECW had been initiated manually, nonessential loads had been unisolated, and a subsequent high energy 8.ne break was experienced. Detroit Edison understands that the revision of.
SE 95-0036 in 1996 to include consideration of the high energy line break introduced operator actions that were not appropriately justified in the SE revision. These issues were addressed at the predecisional enforcement conference. The SE has not yet been revised pending the completion of further evaluations as cited below. In the interim, Operations Procedure SOP 23.127 has been revised to caution against the use o lECW to augment RBCCW during normal r
plant operation. The procedure also requires that the affected EECW subsystem (s) be declared inoperable when restoring nonessential RBCCW loads. The use of the procedure will remain restricted until the evaluation of the EECW ' operating mode is completed and necessary licensing document changes are made.
Immediately after the cited violation (then categorized as an apparent violation) was communicated to Detroit Ejison on November 3,1997, Detroit Edison initiated an assessment of past operability of the EECW. Detroit Edison considered several scenarios as tabulated on Slide 7 of the enclosure to Reference 2. From this, it was determined that past operation had not
'resulted in a loss of safety function or inoperability of EECW.
The issues of this SE were communicated to personnel who were involved in the preparation and review of the SE. Additionally, before any in-process SE was presented for approval to the
' Onsite Safety Review Organization (OSRO), personnel performing SEs were required to attend training sessions to be presented the lessons learned from this SE. This training was also provided to OSRO members and Nuclear Safety Review Group (NSRG) members.
Approximately 25 previously performed SEs were independently reviewed as part of the ongoing 10 CFR 50.59 improvement process (pursuant to Reference 3), revealing no examples of inadequately supported conclusions that an unreviewed safety question was not involved.
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Enclosure Page 3 of 3 Corrective Action To Be Taken To Avoid Further Violations As another part of the aforementioned 10 CFR 50.59 improvement process, the PE/SE program is being upgraded to increase the level of knowledge and experience of personnel who may be qualified as PE/SE preparers / reviewers. This will ensure that those who perform pes /SEs are of the highest quality in terms of understanding the licensing and design basis of Fermi-2.
The PE/SE training program has been upgraded to include extensive licensing basis training.
Initial training for PE and SE preparers and reviewers is in progress and is expected to be completed in the third quarter of 1998. In addition, segregated advanced classroom training is provided for PE and SE qualified individuals which emphasizes written problems and exercises.
Detreit Edi::cn is following the activities of the Nuclear Energy Institute (NEI) 10 CFR 50.59 Tatk Force in its interactions with the NRC. As new guidance is developed on 10 CFR 50.59 performance it is reviewed and incorporated into the PE/SE Program at Fermi-2 as appropriate.
The Updated Final Safety Analysis Report (UFSAR) Validation program, as cited in Reference 3, is intended to identify and correct discrepancies in the UFSAR. In parallel with this effort and to improve accessibility oflicensing basis information for PE and SE preparers and reviewers, docketed correspondence between NRC and Detroit Edison is being converted into an electronically searchable format. This will expand the existing electronically searchable forms of the UFSAR and NRC Safety Evaluation Reports and Supplements.
Date When Full Compliance Will Be Acideltd Full compliance was achieved when SE 95-0035 was revised to include consideration of the high energy line break without loss of offsite power, and when Operations Procedure SOP 23.127 was revised to restrict use of EECW to augment RBCCW.