IR 05000341/1988021

Informs of Postponement of Decision Re Whether or Not to Withdraw Violation Noted in Insp Repts 50-341/88-21 & 50-341/86-39.Listed Values for LPCI & Core Spray Sys Requested within 60 Days of Receipt of Ltr

ML20246A161
Person / Time
Site:	Fermi
Issue date:	06/27/1989
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Sylvia B DETROIT EDISON CO.
References
NUDOCS 8907060171
Download: ML20246A161 (2)

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NUCLEAR RE7ULATORY COMMisslON

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JUN 271989 Docket No. 50-341 l The Detroit Edison Company ATTN: B. Ralph Sylvia Senior Vice President Nuclear Operations 6400 North Dixie Highway

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Newport, MI 48166 L Subject: ECCS SETPOINT ISSUE

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Gentlemen:

This refers to the NRC Notice of Violation (341/88021-02) concerning emergency core cooling flow control setpoints issued with NRC Inspection Report N and also discussed in Inspection Report No. 86039. We have received your letters dated December 2,1988 and January 25, 1989, in response to the violation wherein Detroit Edison denies the violation and. presents justification for that position. We believe we understand your arguments with

' regard to the instrument inaccuracy allowances specified in the GE Design Specification Data Sheets and the analysis of the effects of a flow short fall

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up to the instrument inaccuracy allowance maximum for HPCI and RCIC. We have

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also received confirmation from NRR (dated June 9, 1989) that the agency's position regarding all numbers in Technical Specifications is unchanged from

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that which was stated in.IR 88021, that is, "All numbers in TSs should be considered absolute unless otherwise noted." NRR also noted, however, that

- the safety significance of the improper setting of the HPCI and RCIC flow setpoints is not great, consistent with the arguments you presented in your letters noted above. Accordingly, we believe continued debate on the specifics of this violation does not serve a useful purpose and we are postponing a decision on whether or not to withdraw the violation. The reason that we are postponing the decision is that withdrawal of the violation because the setpoints -for the specific systems cited do not have great safety significance simply foresta11s the same questions for systems of greater safety significance, such as LPCI and Core Spray. Therefore, we are requesting you to provide to us within 60 days of receipt of this letter similar values for the LPCI and the Core Spray systems. Those values are:

(1) the values of flow and pressure assumed by your accident analysis to be

necessary to be provided by LPCI and by Core Spray at the point where these systems enter the reactor vessel, (2) the values assigned for all losses (including line losses due to piping length, reducers, elbows, etc.) between the point where these two systems enter the vessel and the point where flow and pressure are measured for surveillance or other tests, and (3) the instrument inaccuracy allowance assigned to measure flow and pressure at this point in LPCI and Core Spra JFI PDR ADOCK 05000341 i Q PDC

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The Detroit Edison Company 2 JUN 2 71989 4'

It has been our experience that these values are often utilized during.the preoperational and startup testing programs in order to determine proper 1-acceptance criteria and acceptability of deviations from acceptance criteri ]

We believe that 10 CFR 50, Appendix B, Criteria III, IV, V, VI, and VII require this type information to be available, therefore, the 60 day response

. period should not be unreasonable. Further, we believe this type information to be necessary for you to have available in order to complete the Design

, Basis Document program you are currently establishing. In your response, we also request that you include a discussion regarding how the Design Basis Document program will provide a clear basis for numerical values in Technical Specification In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

'this letter and your response to this letter will be placed in the NRC Public Document Roo We will gladly discuss any questions you have concerning this subjec

Sincerely, f&k & ==

Edward G. Greenman, Director Division of Reactor Projects cc: .

Patricia Anthony, Licensing P. A. Marquardt, Corporate Legal Department

' DCD/DCBi(RIDS);.

e"p : Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Harry H. Voight, Es Michigan Department of Public Health Monroe County Office of Civil Preparedness J. Grobe, RIII M. Virgilio, NRR J. Stang, NRR l

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