ML081090197
| ML081090197 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/11/2008 |
| From: | Plona J DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, NRC-08-0032 | |
| Download: ML081090197 (8) | |
Text
Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax 734.586.4172 DTE Energy-GL 2008-01 April 11, 2008 NRC-08-0032 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001
References:
- 1) Fermi 2.
Docket No. 50-341 License No. NPF-43
- 2) NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008
Subject:
Three Month Response to NRC Generic Letter 2008-01 The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 2) to request that each licensee, evaluate the licensing basis, design, testing, and corrective action documents for the Emergency Core Cooling Systems (ECCS), Decay Heat Removal (DHR) systems, and Containment Spray systems, to ensure that gas accumulation is maintained, less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.
The NRC, in GL 2008-01, requested each licensee to submit a written response in accordance with 10 CFR 50.54(f) within 9 months of the date of the GL to provide the following information:
(a) A description of the results of evaluations that were performed pursuant to the requested actions of the GL. This description should provide sufficient information to demonstrate present or future compliance with the quality assurance criteria in Sections lI, V, XI, XVI, and XVII of Appendix B to 7Z/i3(/
USNRC NRC-08-0032 Page 2 10 CFR Part 50 and the licensing basis and operating license as those requirements apply to the subject systems of the GL; (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that are determined to be necessary to assure compliance with these regulations; and, (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
Additionally, the NRC requested that if a licensee cannot meet the requested response date, the licensee "shall provide a response within 3 months of the date of the GL". In the 3 month response, licensees were requested to describe the alternative course of action that they propose to take, including the basis for the acceptability of the proposed alternative course of action. to this letter contains the 3 month response to the requested information in NRC GL 2008-0 1 for Fermi 2.
This letter contains the following new commnitment:
Detroit Edison will provide all requested information in GL 2008-01 within 9 months of the date of the GL with the exception of information related to portions of the systems that are inaccessible during plant power operation.
Detroit Edison will provide the remainder of the requested information by July 31, 2009.
Should you have any questions regarding this submittal, please contact Mr. Ronald W. Gaston, Manager, Nuclear Licensing at (734) 586-5197.
Sincerely, Enclosures cc:
NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III1 Supervisor, Electric Operators, Michigan Public Service Commission
USNRC NRC-08-0032 Page 3 I, Joseph H. Plona, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
JOSEPH H. PLONA Site Vice President - Nuclear Generation On this
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, 2008 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.
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ENCLOSURE 1 TO NRC-08-0032 3 MONTH RESPONSE TO GENERIC LETTER 2008-01 to NRC-08-0032 Page 1 This response to Generic Letter (GL) 2008-01, "Manaiging Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," provides the 3 month optional response requested in the GL. This response discusses:
- 1. The required evaluations that will not be complete within 9 months from the date of GL 2008-01,
- 2. The alternative course of action planned, and
- 3. The basis for the acceptability of the alternative course of action.
Evaluations Deferred Beyond 9 Months:
Detroit Edison plans to complete the requested reviews of licensing basis, design documents, testing requirements and corrective action documents for Fermi 2 within 9 months of the date of GL 2008-01. However, physical walkdowns of the subject systems to confirm pertinent design details (e.g., locations of high point vents) and as-built configurations (e.g., pipe elevations and slopes) will not be performed on portions of the piping systems within the 9 month period because of inaccessibility to certain areas and locations of the plant under power operation. The first opportunity to access these areas is during the 13th refuel outage (RF13) currently planned to start on March 28, 2009. Therefore, the requested evaluations for these piping segments will not be completed and provided to NRC within the 9 month period due to the inability to complete the walkdowns. The walkdowns for these piping segments will not be completed due to one or more of the following reasons:
Need to erect scaffolding Need to remove insulation from piping Location of segments in high radiation areas during power operation Location of segments inside primary containment Plans are currently being formulated to conduct preliminary "scoping walkdowns" to confirm design information on drawings, look for obstructions or clearance problems that could interfere with the more detailed evaluation walkdowns, and to identify and develop plans for erecting required scaffolding. Should scoping walkdowns reveal other portions of the piping systems that are also inaccessible due to physical interference or other reasons, they will be added to the scope of inaccessible portions of the systems and will be deferred to RF13. Scoping walkdowns are essential steps for performing the more detailed evaluation walkdowns required for the GL response.
Alternative Course of Action Detroit Edison will provide all requested information in GL 2008-01 within 9 months of the date of the GL with the exception of information related to portions of the systems that are inaccessible during plant power operation as stated above. Detroit Edison will provide the to NRC-08-0032 Page 2 remainder of the requested information by July 31, 2009. This schedule will allow time to complete the evaluations after performing the walkdowns during RF 13.
Basis for Acceptability of Alternative Course of Action Detroit Edison has performed several system evaluations of the ECCS, Decay Heat Removal (RHR - Shutdown Cooling and RHR - Suppression Pool Cooling) and Containment Spray Systems over the past years. These evaluations were performed based on internal or external program requirements. Examples include self assessments, Safety System Design and Performance Capability Inspections, Component Design Basis Inspections Evaluations for NRC Bulletin 88-04, "Potential Safety Related Pump Loss,"Bulletin 93-02, "Debris Plugging of Emergency Core Cooling Suction Strainers," and Bulletin 96-03, "Potential Plugging of --..
Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors," NRC Generic Letter 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," including supplements 1 through 5, and Generic Letter 96-06, "Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions," including supplement 1.
These evaluation programs, operating experience, system walkdowns and periodic testing provide assurance that deferring certain portions of the evaluations required by GL 2008-01 beyond the 9 month period as requested in the GL will not affect performance of these systems during the proposed time extension. Detailed design and system operation reviews of these systems will accomplish the intent of the evaluations required in the GL. The upcoming refuel outage walkdowns are expected to provide validation of the design and system operation reviews.
Based on the discussion provided herein, the proposed alternative course of action in this letter should be acceptable since it will provide a high level of confidence in the ability of these systems to perform their intended safety function by the 9 month date requested, and will only defer certain evaluations due to the inability to perform walkdowns until the first available opportunity after the 9
- month period.
ENCLOSURE 2 TO NRC-08-0032 REGULATORY COMMITMENTS to NRC-08-0032 Page 1
SUMMARY
OF REGULATORY COMMITMENTS The following table identifies those actions conmmitted to by Detroit Edison in this letter. Any other statements in this submittal are provided for information purpose and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Ronald W.
Gaston, Manager - Nuclear Licensing, at (734) 586-5197.
REGULATORY COMMITMENT DUE DATE
- 1. Detroit Edison will provide all requested information in Generic Letter (GL) 2008-01 within 9 months of the date of the GL with the exception of information related to portions of the systems that are inaccessible during plant power operation. Detroit Edison will provide the remainder of the requested information by July 3 1, 2009.
The 9 month response will be provided by October 13, 2008.
The remainder of the information will be provided by July 31, 2009.