IR 05000341/1987006

Errata to Insp Rept 50-341/87-06 on 861229-870209.Violations Noted:Failure to Verify Adequacy of Design,Failure to Perform Preoperational Test & Surveillance Test of Hydrogen Recombiner Sys & Plant Entering Operation Condition 2

ML20245A259
Person / Time
Site:	Fermi
Issue date:	02/20/1987
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212C621	List: IR 05000341/1987006 ML20212C616
References
50-341-87-06, 50-341-87-6, NUDOCS 8703030833
Download: ML20245A259 (2)

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U.S NUCLEAR REGULATORY COPHISSION

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REGION III

I Report No. 50-341/87006(DRP)

Docket No. 50-341 Operating License No. NPF-43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name:

Fermi 2

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Inspection At:

Fermi Site, Newport, Michigan Inspection Conducted: December 29, 1986, through February 9, 1987 Inspectors:

W. G. Rogers M. E. Parker E. & k. k =,,. = a

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Approved By:

G. Greenman, Deputy Director

.2-20-17 Division of Reactor Projects Date Inspection Summary Inspection on December 29, 1986, through February 9, 1987 (Report No. 50-341/87006(DRP))

Areas Inspected: Special unannounced inspection by two resident inspectors of the events surrounding the discovery on December 26, 1986, of both divisions of hydrc a n thermal recombiners being inoperable.

Results: Three violations were identified (failure to verify the adequacy of. design, failure to preoperational test and surveillance test the hydrogen recombiner system utilizing the designed cooling water system, and the plant entered Operation Condition 2 on eleven occasions with Division II of the hydrogen recombiner system inoperable - Paragraph 2).

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r A review of the preoperational test program identified that the thermal recombiner preoperational test, "T4804 Thermal Recombiner System PRET T4804.001," Revision 2, allowed the use of the RHR system or an alternate source if needed.to supply cooling water.

The PRET identified that the RHR keep-fill system was utilized in the preoperational test and that no specific intent was made to utilize the higher RHR pressures to verify proper system operation. The system was operated on several occasions and each time the RHR keep-fill system was used as a source of cooling water.

Through discussions with personnel there were several reasons that the RHR was not utilized:

(1) RHR pump availability; (2) economic factors, and (3) RHR keep-fill availability.

As a result, the hydrogen recombiner system was never tested utilizing the higher RHR pressures. Additionally, functional surveillance Procedure No. 24.409.01, " Post LOCA Thermal Recombiner Functional Test," Step No. 5.3, allowed the RHR keep-fill system to be in service to provide water to the blower and spray cooler during the test. A temporary change to this procedure, effective December 26, 1986, deleted the use of the RHR keep-fill system. This is considered a violation (341/87006-02(DRP))

of 10 CFR 50, Appendix B, Criterion XI, Test Control, for failure to preoperational test and surveillance test utilizing the designed cooling water system.

On January 9, 1987, the licensee identified that while utilizing the RHR system as a source of cooling water, the Division II hydrogen recombiner-system only heated up to 761 F within the required 75 minute time period.

Technical Specification 4.6.6.1 requires the outlet gas temperature to increase to greater than or equal to 1150 F within 75 minutes. The inability to obtain the required gas temperature was due to excessive internal cooling water seal leakage at the higher RHR pressures. As a result, the Division II hydrogen recombiner system was inoperable and unable to satisfy the surveillance requirements of Technical Specification 4.6.6.1 utilizing the designated source of cooling water.

Ever since the last seal replacement on August 29, 1985, the licensee has noticed external seal leakage with the Division II recombiner. Therefore, the Division II hydrogen recombiner system was considered inoperable since the seal replacement on August 29, 1985, i

Technical Specifications 3.6.6.1 states that "Two independent drywell and suppression chamber hydrogen recombiner systems shall be OPERABLE in Operational Conditions 1 (power operation) and 2 (startup).

Technical Specification 3.0.4 states in part, " Entry into an OPERATIONAL CONDITION or other specified condition shall not be made unless the i

conditions for the Limiting Condition for Operation are met without j

reliance on provisions contained in the ACTION requirements."

During the time period from August 29, 1985, to January 8, 1987, the plant entered Operational Condition 2 (Startup) on eleven occasions (October 3, 1985, August 4, 1986, August 11, 1986, August 30, 1986, September 6, 1986, October 3, 1986, October 7, 1986, October 14, 1986, October 19, 1986, October 29, 1986, and December 19,1986) without both divisions of hydrogen recombiner systems operable. This is considered a violation of Technical Specifications 3.0.4 (341/87006-03(DRP)).

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