ML19241B677
| ML19241B677 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/29/1979 |
| From: | Voigt H LEBOEUF, LAMB, LEIBY & MACRAE |
| To: | |
| References | |
| NUDOCS 7907200214 | |
| Download: ML19241B677 (23) | |
Text
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NUCLEAR REGULATORI COMMISSION i, BEFORE. THE ATOMIC SAFETY AND LICENSING BOARD' d In the Matter of )
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THE DETROIT EDISOR COMPANY ) Docket No 50-341 (Enrico Fermi. Atomic Power ) (Operating License)
Plant, Urtit 2) )
APPLICANTS' RESPONSES TO CHE. INTERROGATORIES Introduction Ort May 25, 1979, the intervenora in. this prcceed-ing, Citizens for Employment and Energy (*CEE*), served a doct.anent. entitled. "CEE Interrogatories te Applicant "
On. June 25, 19r79,ApplicantsM filed. with. the. Atomic Safety and Licensing Boar.1 (" Board"), and served on the other parties to the proceeding, a number of objections to the document pursuant to S2.740b(6) and S2.741(d) of the Commission's Rules of Practice.
Pursuant to the Board's Order of March 21, 1979, Applicants herewith submit responses to the interrogatories, or portions of interrogatories, to which objections have not been made.
1/ The Detroit Edison Ccmpany, Northern Michigan Electric Cooperative, Inc, and Wolverine Electric Cooperative, Inc.
are joint applicants for an operating license for the Enrico Fermi Atomic Power Plant, Unit No. 2 (" Fermi 2") and are collectively referred to as " Applipants" .
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Interrogatory 1 Records concerning physical intrusions of the construction site are maintained only for the most recent three years., Records over three years old are routinely discarded.
Applicants have objected. to CEE's request that Applicants develop and provide a list of all intrusions.
Applicants will, however, make; available for inspection and copies of all ricords of intrusions that are kept.
App 1tcants are not aware of any damage or suspected damage caused by any intrusions. It should be noted that because Ferr,i 2. is located on. Lake Erie, some of the intrusions reported by the constructiori site security personnel are harmless acts without criminal intent, such as fishermen fleeing a storm, boaters with motor trouble, curiousity seekers, and the like. Steps are not generally taken to prevent intrusions of this type. Because the physical protection of the constructiori site conforms to current industry practice, additional security measures are not considered appropriate or necessary.
The security related documents which.are presently in use do not constitute a security plan. The documents which set forth the current precautions against unauthorized intrusions are more properly characterized as general instruction manuals for certain employees responsible for O (?i: {. "' O. p;] /
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some aspects of security. These documents will be available for inspection by CEE.
Interrogatory 2 The Quality Assurance Inspection Progran Plan, identified as " Quality Assurance Procedure 11 - Inspection"
(" Procedure 11"), is part of the Fermi 2. Project Quality Assurance Manual. Procedure 11 is available for inspection and copies of it will.be made at CEE's expense, upon request.
No changes to Drocedure 11 have been required.by the Nuclear Regulato y Commission ("NRC") or any "other appropriate body". The adequacy of Procedure 1 T , moreover, has never been questioned or challenged by a responsible agency. The implementation, of Procedure 1i is audited by the NRC.
Some work has been required to be redone All work redone is reinspected upon completion to assure that it was redone properly. All inspections of such rework are documented in Deviation Disposition Requests (DDRs). An inder of 2.1 DRRs is maintained and CEE will be provided an opportunity to review this index. to identify the documents pertaining to large and small bore pipe hangers and welds of safety related components. If after review of the list of DDRs specific DDRs are requested. the actual document will be made available for c h mem . %w~
Interrogatory 3 Detroit Edison is in the process of preparing for its own use a list of all quality verification records, identified by Plant Identification System (PIS) numbers, which are being entered into the Automatic Record Manage-ment System (ARMS) computer program. To the extent the list has been completed, it will be available for inspec-tion by CEE.
Applicants are not aware of any documents required to be kept by NRC that have been destroyed, mis, ____J, or lost, with one exception. On December T6, 1978, a fire occurred at the site which damaged certain documents. All damaged documents have been identified and replaced and are available for inspection. In addition, this fire completely destroyed two weld process control sheets. Detroit Edison, therefore, was not able to reconstruct them as it had been able to do with the documents that were only damaged. Since these two documents were required to be kept, Detroit Edison policy required that a DDR be written for the destruction of the two documents. It has been written and Detroit Edison is evaluating solutions to the problem.
Detroit Edison does not maintain what is identi-fied or considered to be a daily site log.
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Detroit Edison prepares and maintains "sig-nificant deficiency reports" as required by 10 C.F.R.
S50.55(e). Follow up reports, which are transmitted to the Nuclear Regulatory Commission, always describe action taken to correct deficiencies. Using these documents, one can determine that deficiencies were corrected.
These documents are not classified as being confidential. The documents are available to the public in the Monroe County Public Library and in the Public Document Room of the NRC in Washington.
Detroit Edisor. is solely responsible for the establishment and execution of the Quality Assurance Progran and specificially Paragraph XVII of Appendix B to 10 C.F.R. Part 50.
Interrogatory 4 Detroit Edison requested that two Project Mara-gers for the Ralg t M. Parsons Company be replaced. Mr. O.
M. Hockensmith was replaced in April 1972 at Detroit Edison's request because of his poor attendance at the Fermi 2 site. In October 1973, Detroit Edison requested that the then Project Manager, Mr. C. B. Antill, be replaced because of his inability to maintain labor harmony at the Fermi 2 site. He also was dismissed by the Parsons Ccmpany. There are no documents regarding these replacement actions.
EC80CG The Ralph M. Parsons Company was teaminated when construction was being curtailed due to Detroit Edison's
^hange in load forecast and change in financial circumstances.
This curtailment in construction activities afforded Detroit Edison an opportunity to proceed with engineering and to con, art to a firm-price competitive bidding system using a construction-manager. The Parsons Company was a general contractor with a time-and-materials type of contract. With a slowdown in activities, Detroit Edison felt that greater economies could be realized by putting work out for competitive bidding. Therefore, the contract with Parsons was terminated, as Detroit Edison had a right to do under the terms of that contract. After Detroit Edison had re-let the prime contract as a construction-management contract and had begun competitive bidding, the Parsons Company was invited to bid competitively as a piping contractor, but it declined to do so.
Detroit Edison is not ai'are of any complaint by any Parsons Company emloyee made to the Parsons Company or Detroit Edison relating to Tuality assurance. All quality assurance concerns that arise during normal construction activities at the site are followed up by audits, inspection or surveillance. Deviations are identified in inspection repcrts and dispositioned through DDRs for corrective cetion.
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Interrogatory 5 All inspection or reinspection records related to specific " construction flaws" alleged in Contention 4(e)(1) and ( 2) will be available to CEE for inspection and copying.
a) Cracks in Base Slab of Reactor Building Surveys and studies were conducted to determine the nature and extent of the cracking and a program for repair was established. A fully qualified grouting contractor was selected and the repairs were conducted under the direct surveillance of Detroit Edison. The repairs were inspected and determined acceptable by Detroit Edison. The Atonic Energy Commi ssion (now the Nuclear Regulatory Commission) was kept informed (EF2-9933, May 12, 1972).
b) Hairline Cracks in Structural Steel Sorrounding the Drywell The difficulties that were experienced with the clip angles used in the steel support framing for the slab o~rer the torus are discussed in a report ("F2-12469, October 23, 1972) prepared by a Detroit Edison Quality Assurance Engineer. The entire matter was discussed with the Atomic Energy Commission, which concurred with the determination that this natter was properly characterized as a normal construction problem and was not a constrrction deficiency under 10 C.F.R. S50.55(e).
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Interrogatory 6 This response is limited to the issues set forth La Contention 5 and, therefore, covers only the effluent monitors that are associated with normal operation and offsite emergency actions.
Table 1, attached below, lists the radiation monitors that are associated with the gaseous and liquid effluent streams from the Fermi 2 plant.
Radiolcgical analysis based on readings from monitors, in conjunctior. with other plant and environmental parameters, is used to demonstrate compliance with 10 C.F.R. Part 20 and 10 CeF.R. Part 50, Appendix I, and to assess offsite emergency situations.
The radiological anvironmental monitoring program as proposed is in conformance with the requirements of the Radiological Effluent Technical Specifications (NOREG-0473, Revision 1). The program as defi"sd in NUREG-0473 does not include remote readout monitoring devices for sampling air at the site boundary or air and water on the lake, and E etroit Edison does not consider them necessary.
A monitoring system incorporating remote readout has not been proposed by the NRC, any other regulatory body, or any employee of Detroit Fdison or its contractors.
Interrogatory 7 Detroit Edison is aware of problems due to stress corrosion cracking. Detroit Edison, morec er, has been bbb i)Cb
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- 1. Citeuteting kater Cell tieeltonle systerd Cae6el stint lll4tlen Ceessi teen Continueve Sa'** se A.l Reservolt Decent C0 III Line Co 40 let to ineute the equipment le properly fundtioning, the Seteelltence taggitemente tre evite opptopriate then a maintenence plan.
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actively engaged in studying the effects and inplications of stress corrosion cracking in stainless steel. The following design modifications or investigations hcie been made to remove or minimize the vulnerability to this phenomenon:
- 1) Stainless steel safe-ends were not heated during vessel stress relieving and, therefore, are not sensitized.
- 2) The 4-inch bypass lines around the 23-inch discharge valves in the recirculation 7ystem have been removed.
- 3) The core spray piping has been changed to carbon steel.
- 4) In the recirculation system:
a) the 12-inch risers have been solution annealed and a corrosion-resistant cladding applied to spool piece ends. b) field welding procedures have been changed to minimize residual stresses. Volumetric inspection techniques will readily detect undercu*
- ing . No te : Undercuts are not allowed.
- 5) Small lines connecting the reactor system have been changed to L-grade material where feasible. y
- 6) Improved feedwater spargers are being used.
- 7) A design review on Inconel safe-ends showed those used on Fermi 2 are satisfactory and not in need of replacement.
- 8) The Ccntrol Rod Drive ("CRD") return line has been removed.
- 9) The water supply for the CRD system has been changed to a very low oxygen source during plant operation.
- 10) Additional oxygen monitoring instruments have been incorporated on the reactor and CRD systems.
- 11) Configuration of reactor water clean-up system has been modified to eliminate the resin carry-over experienced at some f acilities of earlier design.
T2) The ultrasonic testing ("UT") preservice examination of the recirculation system used the equipment and technique which optimizes detectior. of intergrantlar stress corrosion cracking. Protection against essentially all the problems encountered in other facilities to date has been made and many mitigating conditions have been incorporated. The Electric Power Research Institute ("EPRI") has an intensive program investigating the problem, developing detection methods, investigating alternate materials, and developing methcds to decrease susceptibility of installed UdO12 piping. To accelerate that program, an ad hoc BWR Owner's Group has been formed to give extra financial support anu technical advice to EPRI. The Detroit Edison Company is a member of that group. In cddition, three Detroit Edison engineers are members of EPRI task groups directing various aspects of the program. It is anticipated that some methods and techniques proven by the EPRI program will be practical and feasible for incorporation on Fermi 2 and will further reduce its vulnet Lbility. All documents relating to stress corrosion cracking of reactor coolant piping will be made available. Interroaatory 8 Detroit Edison is aware of problems related to cable deterioration. All- cables are subject to deteriora-tion which is accelerated by certain environmental conditions. The cables for Fermi 2 were selected on a generic basis considering anticipated environmental conditions and are expected to provide at least forty years of service. The electrical and physical stability of various possible cable constructions in normal rigorous service are straightforward. However, a nuclear facility, and its drywell area in particular, add factors which required additional consideration. In particular, cable constructions must exh ibit an ability to withstand radiation from 1) ambient EfCh<3 t
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conditions in nuclear plants; 2) design basis events such as a loss of coolant accident; and 3) total accumulated radiation over a 40 year period. In addition, cablos must be flame resistant and effective fire stops must be built into the cable system. These problems have been addressed by Detroit Edison both at Fermi 2 and through participation in the development of industry standards. These efforts are reflected in the Ferni 2 cable specifications. The principal cable problem encountered in nuclear power plants is fire. Applicants have followed closely various incidents of fires at other facilities and the lessons learned have been incorporated in the selection and evaluation of the Fermi 2 cables. Detroit Edison has conducted an exhaustive in-house testing program, actively participated in various industry developments relating to test procedures, and closely followed various incidents involving fires at various fossil and nuclear power plants. In the late 1960's, Detroit Edison launched cn extensive flame test program involving cables from various potential manufact'arers. Before this comprehensive flame test program was embarked upon, all the available flame test procedures were critically analyzed so that important t - C rs e
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features could be incorporated in the Detroit Edison flame test. The test procedures consulted included flame tests from Baltimore Gas & Electric Company, Anaconda, and General Electric Company. Initial testing included Insulated Power Cable Engineers Ascociation ("IPCHA") vertical flame tests, while subsequent tests were based on flame tests in cable trays utilizing flame sources as high as 120,000 BTUs. The latter tests were performed in close collaboration with the Nuclear Energy Liability and Property Insurance Association. L1, Jdition to flame tests, tests were conducted on cable penetration and fire stops to ensure that Fermi 2 cables are not in any way overloaded. It is noteworthy that a great deal or the work was performed at the Engineering Research. Department of Detroit Edison before a major fire occurred a l T7A's Brown 's Ferry nuclear plant in 1975. Detroit Edison has actively participated in various industry committees. This involvement enabled Detroit Edison to incorporate important features into its own test procedures meant for Fermi 2 cable systems. In particular, Detroit Edison participated in Project 12-32 of the Insulated Conductors Committee of the Institute of Electronic and Electrical Engineers. The work carried out bbt 315
by Project 12-31 resulted in the preparation of the stand-ard (IEEE Std. 383-1974) which forms the basis of all test procedures relating to nuclear cable systems. The numerous flame testa conducted by Detroit Edison significantly contributed. towards the flame testing portion of the IEEE Std. 383-1974. In addition, Detroit Edison significantly contributed towards the preparation of the following documents:
. Guide for Design and Installation of Wire and Cable Systems in Power Generating Stations presented at IEEE in January 1971 ( 71 CP T 54-P;7R)
. IEEE Standard Cable Penetration Fire Stop Qualification Test (IEEE Std. 639-T978).
Cables do not require inspection or maintenance in the manner normally associated with active equipment. Visible cables are given cursory inspections during routine operator inspection patrols. Occasionally, a cable will fail (about one per plant each ten years), but generally only after it has been mechanically damaged. Suc. failure is detected and isolated in a fraction of a second. A failed cable would be replaced. The repair would then be tested by the Cable Cast Division of the Equipment Per-formance Division. Documents relating to cable composition and installar. ion and inspection procedures will be made available to CEE. Et01G
Interrogatory 9 Standard Review Plan 9.5.1, Section IV, indicates that the appropriate fire protection criteria for construction permit applications dated prior to July 1, 1974 is Appendir A to BTP ASB 9.5-1. The Fermi 2 design has been evaluated against the recommendations of Appendix A to BTP ASB 9.5-1. That evaluation is provided in Appendix 9B of the FSAR. Fermi 2 mt >ts the recommendations of Appendir A relating to adequate isolation, spacing, and delineation of caole trays. Separation of cable trays, therefore, has been intentionally incorporated into the cable tray design. Procedures have been established ta detect im-proper separation in the Reactor Building and the Auxiliary Building. Each drawing is reviewed by a Detroit Edison engineer to assure compliance with all da sign criteria. Stone & Webster provides an independent review of the Reactor Building and Auxiliary Building cable tray drawings for compliance with separation criteria. A final check is acccmplished when the quality cont ol department of the electrical contractor checks the as-built condition of the trays to assure their compliance with all design require-ments. If improper separation is detected, a Deviation Disposition Request is issued that requires an engineering solution to clear the problem. b'd 17
In the final des'.gn for acceptable fire barriers, Flamemastic 77 has been chosen as the material to be used to coat all cable in trays not meeting spatial separation criteria. The electrical installation specification will be revised when necessary to specify the extent to which Flamemastic need be applied. Electrical cable trays themselves are passive and do not require inspection per se. However, they are observed where visible during routine inspections. Main-tenance of cable trays is not anticipated unless they were to be accidently damaged in the process of doing maintenance on adjacent equipment. Any damage would be reviewed by staff maintenance personnel, supplemented where necessary by engineers from appropriate disciplines. Detailed repair procedures would be prepared, and these would be reviewed and need approval or revision by the On Site Review Organization and necessary experts before repairs would be allowed. Additional information related to this interrogatory can be found in FSAR subsections 8.3.1.4.1.1 and 8.3.1.4.5.2. The fire protection review, documented in FSAR Appendix 9B (Amendment 10, October 1977), indicates all areas where sprinklers are used in Fermi 2. h U$ b Interrogatory 10 In normal evacuation modes, some residents of the Stony Point area would travel toward the Fermi 2 facility for a short distance. This evacuation route is adequate because La such a route the evacuating residents would not be exposed to radiation in excess of the limits permitted by 10 C.F.R. Part 100.
' Calculations show that if a person stood on the site boundary nearest to the plant (about 0.6 miles north-west of the reactor) for 2 hours during the worst conditions assemed for the design basis loss of coolant accident, that person's whole body dose would not exceed 6.5 rems. (See FSAR Table 15B.6.5-4). The- soutL?rn-most resident of Stony Po int , the resident farthest from Point Aux Peaux Road, is abeit 1.1 miles from Pointe Aux Peaux Road. The road itself comes no closer than about T.1 miles from the plant. It is reasonable to expect people to travel the 1.1 miles toward the plant and evacuate the area in a period of time shorter than 2 hours, as most of them do every day during normal activities. Any evacuee traveling along Pointe Aux Peaux Road for a few blocks would then be completely out of the plume.
FSAR Chapter 15 and Appendix 13A contain additional information concerning accident analysis and emergency plans. SG@319 Interrogatory 1_1 _ Design parameters for high water, established by ngineering logic, are contained in Section 2.4 of the FSAR, Bydrologic Engineering. Specifically, maxim: m cast lake levels are discussed in FSAR subsection 2.4.2.1 includi'ng a discussion af recent significant storms. The criteria for flood design. are included in FSAR subsection 2.4.2.2 exclusive of Seiche effects. The basic design flood elevation is 588.0 feet, or 5.0 feet above site grade. Maximum surge and Seiche effects are discussed in FSAR subsection 2.4.5.3 with Probable Maximum Meteorological Event ("FMME*) levels of 586.9 feet still water elevation. Wave effects and run-up (subsection 2.4.5.6.2; dictate a flood design level of 593.0 feec for the exposed faces of the Reactor Building, Auxiliary Building and RHR Complex. During the month of June 1973, the mean lake level was recorded at el'evation 575.4 feet with the high-est instantaneous peak elevation 578.7 feet. The flood design level has never been exceeded in the immediate past or since records have been kept. The flood design level for the plant is greater than the PMME value which, in turn, is riuch greater than the highest recorded flood elevatior and thus the flood design level has never been approached. 56SG20 Interrogatory 12 Detroit Edison has not separately analyzed the environmental effects of the uranium fuel cycle. The- environmental effects of the uranium fuel cycle have been considered generic. Thus, Table S-3 of 10 C.F.R. 51.20 has been utilized. A revised interim Table S-3 was published by the' NRC in March 1977 (42 FR 13803, March 14, 1977) and was further amended in April 1978 (43 FF. 15613, April 14, 1978). The interim Table S-3, as amended, is still in effect for licensing proceedingc. On the question of the effects of radon-222 in the front-end of the uranium fuel cycle, Detroit Edison relies on the record developed in the proceeding Duke Power Ccmpany (Perkins Power Plant, Units 1, 2, and 3), Docket Nos. STN 50-488, STN 50-489, and STN 50-490. A copy of that record will be made available to CEE by Applicants. It is also available in the Public Document Room of the Nuclear Regulatory Commission. Interrogatory 13 Applicants cannot at this time respond specifically to this interrogatory because Applicants have not determined yet what direct testimony will need to be made on their be-half. Obviously, Applicants cannot identify the individuals G ,d-Onoq t t Ur.e n who would present such testimony. Specific responses to this interrogatory will be made, pursuant to 10 C.F.R. 52.740(d), when the information is available. Applicants will make the relevant documents available for inspection and copying at that time. LeBOEUF, LAMB, LEIBY & MacRAE By mor gartner ~~g 1333 New Hampshire Avenue, N.li. Washington, D.C. 20036 (202) 457-7500 Attorneys for Applicants Of Counsel _- Patrick K O' Hare L. Charles Landgraf Peter A. Marquardt 2000 Second Avenue Detroit, Michigan June 29, 1979 St9C.22
DISTRICT OF COLUMBIA ) ss-LARRY E. SCHUERMAN, being duly sworn, says: I am the Licensing Engineer in the Enrico Fermi Atomic Power Plant Project Management Organization for The Detroit Edison Company. I have read the foregoing Answers to in-terrogatories and they are true and correct to the best of my knowledge, information and belief.
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' Larry W. Schuerman Sworn to before me on June .7), 1979.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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THE DETROIT EDISON CCMPANY ) Docka t No . 50-341 (Enrico Fermi Atomic Power ) (Operating License) Plant, Unit 2) ) CERTIFICATE OF SERVICE I hereby certify that I have this 29th day of June, 1979 served the foregoing document entitled
" Applicants' Responses to CEE's Interrogatories" by mailing copies thereof, first class mail, postage prepaid and properly addressed, or by personal delivery, as F-indicated, to the following nersons:
Charles Bechhoefer, Esq. Dr. David R. Schink Chairman, Atomic Safety and Department of Oceanography ' Licensing Board Texas A&M University U.S. Nuclear Regtdatory College Station, Texas 77840 Commission (mail) Washington, D.C. 20555 (personal delivery) Richard Black, Esq. Office of the Executive Mr. Frederich J. Shon Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission (mail) Washington, D.C. 20555 (personal delivery) Mr. Delbert J. Hoffman Supervisor, Frenchtown Chairman, Atomic Safety and Township Licensing Appeal Board Panel Frenchtown Township Hall U.S. Nuclear Regulatory 2665 Vivian Road Commission Monroe, Michigan 48161 Washington, D.C. 20555 (mail) (mail) E(, U.Cd
Kim Arthur Siegfried Secretary 10084 Lincoln U.S. Nuclear Regulatory Huntington Woods, Michigan 48070 Commission (mail) Washington, D.C. 20555 Attn: Docketing and Service Monroe County Library System Sect on Reference Department (original pris 20) 3700 South Custer Road (personal 4.clivery) Monroe, Michigan 48161 (mail) L. Charles Landgraf /' LeBOEUF, LAMB, LEIBY & MacRAE Attorneys for Applicants tc,6 e nor G.~ < d; P 6}}