View source for NRC-97-0080, Responds to NRC Re Violations Noted in Insp Rept 50-341/96-17.Corrective Actions:Ts Clarification Cancelled & Procedure Governing TS Clarifications Has Been Reviewed Against NRC Insp Guidelines on TS Interpretations

{{Adams
| number = ML20216D105
| issue date = 09/02/1997
| title = Responds to NRC Re Violations Noted in Insp Rept 50-341/96-17.Corrective Actions:Ts Clarification Cancelled & Procedure Governing TS Clarifications Has Been Reviewed Against NRC Insp Guidelines on TS Interpretations
| author name = Gipson D
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-97-0080, CON-NRC-97-80
| document report number = 50-341-96-17, NUDOCS 9709090215
| title reference date = 08-01-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 11
}}

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Doug!u R. Gipson
  .,--                                                                      Seni ir Viec l'rnident, Nutlear Generation ferrai 2 6100 krth liisie ifwh Newpirt, Michigan 4s100, Td 3(3 FMT,2nl Fat 31WC.4172 Detroit Edison September 2,1997 NRC-97-0080 U. S. Nuclear Regulatory Commission i
Attn: Document Control Desk Washington D. C. 20555

==References:==
: 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
: 2) NRC Special Inspection Report No. 50-341/96017, dated February 3,1997
: 3) NRC Notice of Violation (NRC Inspection Report 96017),
dated August 1,1997
: 4) Detroit Edison letter, NRC-96-0092, Licensee Event Report, g
No. 96-014, dated November 4,1996                                                    Q~!
7
: 5) Detroit Edison letter, NRC-96-0104, Licensee Event Report, No. 96-018, dated December 5,1996

==Subject:==
Reply to Notices of Violation finspection Report No. 50-341/96017'l Enclosed is Detroit Edison's response to the apparent Violations contained in Reference 2 and issued as Notices of Violation in Reference 3.
Detroit Edison :ecognizes the existence of the work management issues described in the cover letter to the Notices of Violation and has taken corrective action to stem conti nued problems in this area. Specifically, a number ofinitiatives have been
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  ,                     NRC-97-0080 Page 2 implemented to improve Technical Specification impact statements in work packages and to ensure that all applicable Technical Specification action statements are appropriately entered and exited. An Operations Work Control Group, consisting of two licensed Senior Reactor Operators (SRO) and two licensed Reactor Operators, has been formed, This group, rather than the normal, previously unlicensed work control personnel, has responsibility for ensuring that the Technical Specification impact statements in work packages are correct. Additionally, an administrative SRO position, staffed 24 hours per day Monday through Friday, has been established in the Tagging Center to maintain control and coordination of work packages and impact statement execution. This provides an additional SRO review of the Technical Specification implications of proposed work package execution, and allows the Nuclear Shift Supervisor to remain focused on normal plant operation.
Another recent initiative is the Critical Work Review which is conducted approximately two weeks prior to work execution, to ensure the necessary coordination for Technical Specification impacted activities currently scheduled.
This meeting is chaired by the Operations Work Control Supervisor, and is attended by Work Control, Maintenance, System Engineering and the Work Week Manager, with support from other functional areas as required. This synergistic approach is intended to provide yet another opportunity to identify and resolve potential coordination problems associated with Technical Spec #ication impacts.
There have been several general improvements made to the work control process as well. These include formation of a Work Management Improvement Committee to provide input and review for improvements in work management practices, a Maintenance Work Package Walkdown Checklist to help in identifying potential problems before ajob is started, and designation of Work Week Managers to help oversee and coordinate scheduled work. These improvements are intended to help ensure that work is thoroughly planned, scheduled and executed in a manner consistent with the requirements of the Technical Specifications.
Regarding the Detroit Edison presentation of a complex legaljustification at the predecisional enforcement conference for the actions of the Fermi 2 staff, we agree that the Fermi 2 staff should have contmunicated better with the NRC prior to implementation of the Technical Specification clarification. We believed, however, that the detailed discussion presented at the predecisional enforcement conference was needed to allow NRC senior management to understand the complex interrelationships associated with the various Technical Specifications. In the future, we will communicate with the NRC staff, should a similar situation arise.
Iminediate and short term corrective actions have been completed as discussed in this response. The following commitments are being made in this letter:
: 1. The wording in the procedure governing Technical Specification Clarifications is being strengthened to specifically state that Technical

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  .       NRC 97-0080 Page 3 Specification Clarifications must never contradict or change the s 3rding of a    1 Technical Specification requirement. This revision will be completed by           l Octoler 31,1997.                                                                  I
                                                                                                    -l 1
: 2. A license amendment will be prepared to allow the interpretation discussed in      l Violation 50-341/96017-Ol A to be implemented into the current Fermi 2            j Technical Specifications, prior to the implementation of the ITS.                 l
: 3. Violation 50-341/96017-Ol A will be discussed in Operations Continuing             '
l                  Training with emphasis on literal compliance with Technical Specifications.
l                  This training is expected to be completed by December 19,1997.
If there are any' questions, please contact Norm Pet rson, Director- Nuclear j         Licensing, at (313) 586-4258.
Sincerely,        .
h Enclosure ec:    A. B. Beach O. A. Harris M. J. Jordan A. J. Kugler M. V. Yudasz, Jr.
Region llI Wayne County Emergency Management Division

i
     ,     Enclosure to NRC-97-0080 Page1 4
JtESPONSE TO VIOLATIONS Violation (50-341/96017-01 A)
Technical Specification 3.9.10.2. permits any number of control rods and/or control rod drive mechanisms be removed from the core and/or reactor pressure vessel provided that at least the following requirements are satisfied until all control rods and control rod drive mechanisms are reinstalled and all control rods are inserted in the core.
Technical Specification 3.9.10.2.a. requires that the reactor mode switch be OPERABLE and locked in the Shutdown position or in the Refuel position per Specification 3.9.1, except that the Refuel position "one-rod-out" interlock may be bypassed, as required, for those control rods and/or control rod drive mechanisms to be removed, after the fuel
!          assemblics have been removed as specified in Technical Specification 3.9.10.2.b l          through e.
Section 7.6.1.1.3.4 of the Fermi Updated Final Safety Analysis Repoit (UFSAR) l          desci.i ms the ftmetional testing of refueling interlocks. The UFSAR did not describe the acceptabilit" of performing this test under conditions where multiple control rods are already withdrawn when the test is made.
Contrary to the above, on October 13,1996, the licensee performed a functional test of refueling interlocks under conditions which were not permitted by Technical Specification 3.9.10.2. Specifically, the test was performed under conditions where multiple control rods were already withdrawn from the core, and the reactor mode switch was not locked in either the Shutdown position or the Refuel position.
Reason for Violation Following repairs to the refueling bridge, surveillance testing in accordance with Technical Specifications was required in order to demonstrate operability of the Mode Switch and refueling interlocks. Portions of this testing require the Mode Switch to be placed in the STARTUP/ HOT STANDBY and RUN positions. However, with the reactor partially defueled, multiple control rods had been withdrawn and could not be reinserted without first installing fuel or blade guides in the affected core cells.
Following a review of the Fermi 2 Technical Specifications and the improved Standard Technical Specifications (ISTS), NUREG-1433, Revision 1, Detroit Edison concluded that the required surveillance testing could be perfomied within the intent of the existing Technical Specifications. A Technical Specification Clarification was developed and approved allowing the required surveillance testing. This clarification provided a
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.-                  Enciccure to NRC 97-0080 Page 2
:c rationalization for concluding that the mode switch could be moved from the SilUTDOWN or REFUEL position to the STARTUP/IlOT STANDBY and RUN positions, consistent with the position taken in NUREG 1433, Revision I that with no fuel assemblies in the core cell, the associated control rod has no reactivity control function and is not required to remain inserted. This rationalization and the resulting activities were not consistent with the literal requirements of Technical Specification 3.9.10.2.a however, and the Detroit Edison staff should have contacted the NRC to obtain the appropriate regulatory exemptions.
Corrective Stens that have been Taken and the Results Achieved The Technical Specification Clarification in question has been canceled. All other active Technical Specification Clarifications have been reviewed to identify any similar cases where a clarification was developed relying on the ISTS. No other examples were identified.
Personnel involved in the review and approval of Technical Specification Clarifications have been made aware of this violation end t.aderstano that Technical Specification Clarifications cannot be written to provide any relief from literal compliance with Technical Specification requirements.
Corrective Stens that will be Taken to Avoid Further Violations The procedure goveming Technical Specification Clarifications has been reviewed against NRC inspection guidelines on Technical Specification Interpretations. The
                   - procedure was determined ta appropriately prohibit the use of clarifications to provide relief from Technical Specification requirements. However, as a result of this review, the procedural wording is being strengthened to specifically state that Technical Specification Clarifications must never contradict or change the wording of a Technical Specification requirement. This revision will be completed by October 31,1997.
A license amendment to implement improved Technical Specifications (ITS) at Fermi 2 is being developed. Implementation ofITS is expected to reduce the need for Technical Specitication Clarifications and also to reduce the possibility of this type ofinterpretation error in the future. A license amendment will be prepared to allow the interpretation discussed in this event to be implemented into the current Fermi 2 Technical Specifications, prior to the implementation of the ITS.
This event will be discussed in Operations Continuing Training with emphasis on literal compliance with Technical Specifications. This training is expected to be completed by December 19,1997.

   ,             Enclosure to NRC-97 0080 Page 3
                 ] late When Full Compliance will be Achieved Full compliance was achieved on December 10,1996 when this Technical Specification Clarification was canceled. Additional corrective actions will ensure continued compliance.

  .         Enclosure to NRC-97-0080 Page 4 Violation (50 341/96017-01111 Technical Specification 4.0.4 requires, in part, that entry into an OPERATIONAL CONDITION shall not be made unless the surveillance requirements associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified.
Technical Specification 3.3.6 requires, in part, that the control rod block instrumentation channels shown in Table 3.3.61 shall be OPERABLE consistent with the applicability listed in that table. Table 3.3.6-1 requires that intermediate Range hionitors be OPERABLE in OPERATIONAL CONDITION 5.
Contrary to the above, on November 5,1996, OPERATIONAL CONDITION 5 was entered without performing the surveillance requirements for Technical Specification 3.3.6. Specifically, a current surveillance was not made for any of the required channels of the Intermediate Range hionitoring instrumentation, prior to entry into OPERATIONAL CONDITION 5 as required by Table 3.3.6-1 and Technical Specification 4.0.4.
Reason for Violation As described in Licensee Event Report (LER) 96-018, the reason for the violation was that a transposition error occurred when the initial set of dial indicator readings were being taken during tensioning of the Reactor Pressure Vessel (RPV) studs. The transposition error was due to a poor transfer ofinformation between personnel when the dial indicator reading in question was transmitted by technicians via radio communication from the reactor cavity to the official record on the Refueling Floor. The actual reading of 0.8060 inches was transposed to be 0.8600 inches on the official record. This resulted in RPV llead stud number 27 being detensioned during the final trim pass causing an unrecognized entry into OPERATIONAL CONDITION 5 (REFUELING). Because the mode change was not recognized, the surveillance requirements for the Intermediate Range hionitoring Instrumentation of Technical Specification Table 3.3.6-1 were not performed. A contributing factor for this lack of recognition was that the personnel involved did not adequately review or question the inconsistency in the dial indicator readings or the number of turns required for the trim adjustment.
Corrective Steps that have been Taken and the Results Achieved As described in LER 96-018, the immediate corrective action taken was to retension stud number 27 to within specified tolerances.
1

 .                Enclosure to NRC-97-0080 Page 5 During the investigation it was determined that a declaration of OPERATIONAL CONDITION 4 (COLD SHUTDOWN) is more appropriate af ter the trim pass adjustment when all stud elongation is verified to L: within tolerances. Operations has changed the declaration of a mode change from OPERATIONAL CONDITION 5 to OPERATIONAL CONDITION 4 to be when stud elongation is verified to be within tolerance.
The Reactor Vessel llead Detensioning and Tensioning procedure has been revised to incorporate the following considerations:
Elongation data recorded by technicians in the reactor cavity and reported via radio communications will be compared to the reading recorded on the official records. Any discrepancies will be resolved prior to subsequent clongation adjustments.
Trim adjustments requiring more than one turn will be evaluated by the Refueling Floor Coordinator prior to proceeding with trim adjustments.
e            The definition for a fully tensioned Reactor Vessel Head will be when all studs are verified to be within elongation tolerances.
                       .             The NSS will be notified when the studs are ready for trim adjustments to assure the plant is ready to enter OPERATIONAL CONDITION 4.
* The NSS will also be notified when all studs have been elongated and are verified to be within tolerance.
A three way communications process has been implemented as part of the Operational Excellence Plan into the Operations Department Instructions (ODI), specifically ODI-006," Operations Department Communications," and ODI-007," Command and Control."
This communication technique is used by operations and maintenance personnel and should help to ensure that errors such as the one cited in the violation are minimized.
Corrective Steps that will he Taken to Avoid Further Violations All corrective actions connected with this event have been completed.
Date When Full Compliance wilife Achieved Full compliance was achieved when stud number 27 was retensioned to within tolerances and Technical Specification surveillance requirements were met.

d
.         Enclosure to NRC-97 0080 Page 6 Violation (50 341/96017-01C)
Technical Specification 3.7.1.5 requires, in part, that the Ultimate lleat Sink, comprised of two one half capacity residual heat removal (RHR) reservoirs with the capability of being cross-connected, shall be OPERABLE with two reservoir cross-connect lines, each with two OPERABLE motor operated cross-connect valves.
Action "c" of Technical Specification 3.7.1.5 requires, in part, that with one or more reservoir cross-connect valves inoperable, within 8 hours open and de-energize both valves in at least one cross-connect line and verify that these valves remain open and de-energized at least once per 7 days. Othenvise, declare both reservoirs inoperable and take the action of e. below.
Action "e.2" of Technical Specification 3.7.1.5 requires, in part, that in OPERATIONAL CONDITIONS 4 or 5, declare RIIRSW system (residual heat removal service water), the EESW system (emergency equipment service water) and the diesel generator cooling water systems inoperable and take ACTION required by Technical Specifications 3.7.1.1, 3.7.1.3 and 3.7.1.4.
Contrary to the above, on October 4,1996, through October 5,1996, while in OPERATIO'NAL CONDITION 5, the Ultimate lleat Sink was not OPERABLE because two reservoir cross-connect lines, each with two OPERABLE motor operated cross-connect valves, were not available. The Division 2 valves (El150-F602A and F602B) were rendered inoperable by operators and one of the Division 1 valves (F601 A) failed to open. At that time, the licensee failed to declare the RilRSW, EESW, and the diesel generator cooling water systems inoperable and failed to take the actions required by Technical Specifications 3.7.1.1,3.7.1.3 and 3.7.1.4.
Reason for Violation The reasons for the violation are:
: 1. The failure of the control room operator to recognize that deenergization of bus 72ED caused the closed RilR reservoir cross-connect valve (El 150-F0602B) to be inoperable, thereby resulting in a failure to enter action c, and subsequently action e, of Technical Specification 3.7.1.5;
: 2.      The failure of valve El 150-F0601 A to open such that a cross-connect between the RIIR reservoirs was not established; and

e               Enclosure to NRC-97 0080 Page 7
: 3.                 The failure of the control room operator to realize that valve Ell 50-F0601 A had not opened, thereby resulting in another failure to enter action e of Technical Specification 3.7.1.5.
The control room operator cited in 1) above and as described in Licensee Event Report (LER) 96-014 failed to enter the appropriate Technical Specification action statement because the Limiting Condition for Operation (LCO) tracking sheet prepared by licensed and non-licensed operators was based on the assumption that the other cross-connect function was OPERABLE with the other division of power available. Proper attention was not paid to the LCO requirements of the Technical Specifications which required that
,                 this OPERABLE cross-connect line have both valves in the line open and de-energized.
The failure of valve El 150-F0601 A , a ball valve, to open as cited in 2) above and described in LER 96-014 was due to a loose set screw on the valve operator spline bushing, resulting in the spline bushing becoming disengaged from the drive spline of the operator bull gear. The valve position indication was indicating changing valve position by rotation of the valve operator stem which was not connected to the valve.
The failure of the control room operator cited in 3) above to recognize that valve El150-F0601 A had failed to open, although valve position indicated open, was inadequate interpretation of the information available concerning RHR reservoir levels. Therefore, only when water was added to the Division I reservoir with no change in the level of the cross-connected Division 2 reservoir, and further confirmed when the opposite division closed valve (El150-F0602B) was opened, was it recognized that El150-F0601 A&B cross-connect line had not provided a flow path.
Corrective Steps that have been Taken and the Results Achieved As described in LER 96-014, a cross-connect path was established on October 5,1996, at 1549 hours when El150-F602B was manually opened. The El150 F601 A valve operator was repaired prior to restart from the fifth refueling outage by providing a small recess for the spline bushing set screw and by securing the set screw in place. The other cross-connect valves have also been modified with the set screw recess.
The appropriate operations personnel involved in this event received discipline in accordance with Detroit Edison's Positive Discipline Program. A lessons learned document was prepared for the Operations department and this event was discussed with shitt operations personnel.
The bus shutdown procedures have been evaluated. No changes to these procedures were deemed appropriate due to the potential for varying combinations of plant conditions and equipment availability. However, work control documents will incorporate specific

  $       Enclosure to l     NRC 97-0080 Page 8 component impacts during bus shutdown. These work control documents will be reviewed by the Operations Work Control Group. This group, rather than the normal, previously unlicensed work control personnel, has responsibility for ensuring that the Technical Specification impact statements in work packages are correct.
The Ultimate IIcat Sink cross-connect valve surveillance procedures have been evaluated to detennine the need to provide positive indication that a cross connect path is established when the associated cross-connat path valves are in the open position as indicated in the control room. These procedures were revised prior to the first quarterly performance of the surveillance after restart from the fifth refueling outage.
Corrective Steps that will he Taken to Avoid Further Violations All corrective actions connected with this event have been completed.
Date When Full Compliance will be Achieved Full compliance was achieved on October 5.1996 when a cross-connect between the RHR reservoirs was established.
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