ML081560766
| ML081560766 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/19/2008 |
| From: | Justin Poole NRC/NRR/ADRO/DORL/LPLIII-1 |
| To: | Jennifer Davis Detroit Edison |
| Poole Justin/DORL/LPL3-1/ 301-415-2048 | |
| References | |
| GL-08-001, TAC MD7827 | |
| Download: ML081560766 (7) | |
Text
September 19, 2008 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166
SUBJECT:
FERMI 2 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NO. MD7827)
Dear Mr. Davis:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated April 11, 2008, Detroit Edison (the licensee) submitted a 3-month response to GL 2008-01 for Fermi 2. The NRC staffs assessment of the responses for Fermi 2 is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for Fermi 2, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure.
J. Davis If you have any questions regarding this letter, please feel free to contact me at (301) 415-2048.
Sincerely,
/RA/
Justin C. Poole, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341 cc: See next page
J. Davis If you have any questions regarding this letter, please feel free to contact me at (301) 415-2048.
Sincerely,
/RA/
Justin C. Poole, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341 cc: See next page Distribution:
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Fermi 2 cc:
David G. Pettinari Legal Department 688 WCB Detroit Edison Company 2000 2nd Avenue Detroit, MI 48226-1279 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Radiological Protection and Medical Waste Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 U.S. Nuclear Regulatory Commission Resident Inspector's Office 6450 N Dixie Highway Newport, MI 48166 Mr. M. V. Yudasz, Jr., Director Monroe County Emergency Management Division 965 South Raisinville Road Monroe, MI 48161 Ronald W. Gaston Manager, Nuclear Licensing Detroit Edison Company Fermi 2 - 200 TAC 6400 North Dixie Highway Newport, MI 48166 Supervisor - Electric Operators Michigan Public Service Commission P.O. Box 30221 Lansing, MI 48909 Wayne County Emergency Management Division 10250 Middlebelt Road Detroit, MI 48242 Mr. Joseph H. Plona Vice President - Nuclear Generation Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166
Enclosure U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 FERMI 2 DOCKET NO. 50-341
- 1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008, Detroit Edison (the licensee) submitted a 3-month response to GL 2008-01 for Fermi 2. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of Fermi 2 cannot be completed because portions of the GL subject systems are inaccessible during power operation. These sections of piping are inaccessible for the following reasons: (1) the need to erect scaffolding; (2) need to remove insulation from piping; (3) locations of segments in high radiation areas; and (4) location of segments inside primary containment.
The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage for Fermi 2 scheduled to start in the spring of 2009. The licensees letter dated April 11, 2008, listed the following commitment:
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.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. evaluation programs,
- 2. operating experience,
- 3. system walkdowns, and
- 4. periodic testing.
Based on the above considerations, the licensee stated that the proposed alternative course of action should be acceptable since it will provide a high level of confidence in the ability of the subject systems to perform their intended safety function. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, evaluation programs, and system walkdowns associated with managing gas accumulation at Fermi 2.
The NRC staff notes an example where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, although the licensees submittal stated it would provide the remainder of the GL requested information by July 31, 2009, it is not clear if that schedule is within 90 days following startup from the Fermi 2 refueling outage that is scheduled to start in the spring of 2009.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Fermi 2 refueling outage scheduled to start in the spring of 2009, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC by July 31, 2009, or within 90 days following startup from the next refueling outage scheduled to start in the spring of 2009, at Fermi 2, whichever is sooner.
For each of these two submittals (the 9-month initial and supplemental submittal), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a
statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force Traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.