ML19291B948

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Discusses Impact on Facility of Proposed Revision to Reg Guide 1.97.Impact Would Be Great & Require Replacement of All post-accident Monitoring Instruments & Many non- Qualified Instruments.Estimated Direct Cost $10 Million
ML19291B948
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 12/12/1979
From: Jens W
DETROIT EDISON CO.
To: Benaroya V
Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-OS, TASK-RS-917-4 NUDOCS 7912140428
Download: ML19291B948 (2)


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. iai3i 649/ean ii7 48C84 cetres .oc ;r 4 .a VIA EMERY EXPRESS December 12, 1979 EF2 - 47,214 Mr. V. Benaroya, Chief Auxiliary Systems Branch Division of System Safety U. S. Nuclear Regulatory Commission ~

7920 Norfolk Avenue Bethesda, Maryland 20014

Reference:

Enrico Fermi Atomic Power Plant - Unit 2 NRC Docket No. 50-341 -

Subject:

Proposed Revision 2 to Regulatory Guide 1.97

" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Condi-tions During and Following an Accident"

Dear Mr. Benaroya:

The impact of the proposed revision to Regulatory Guide 1.97 on Fermi 2 is very great. Detailed compliance with proposed Revi-sion 2 to Regulatory Guide 1.97 would essentially require the replacement of all post accident monitoring instruments and many non qualified instruments at Fermi 2 that are now classified as part of the instrumentation for post accident monitoring.

Detroit Edison estimates that the direct cost for implementing

- the proposed revisions to be about $10 million. Some of the i proposed equipment is not commercially available and must be developed. Several years of associated schedule delay probably would be incurred, and this could add several hundred million dollars to the cost of the Fermi 2 plant.

Engineered improvements have been considered for Fermi 2 in the past, including ir:provements made to upgrade instruments to comply with Regulatory Guide 1.97, Revision 1, which was issued after we received our construction permit and after we filed our FSAR and application for an operating license in 1974.

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Mr. V. Benaroya December 12, 1979

- EF2 - 47,214 Page 2 In addition, Fermi 2 is committed to make plant changes to comply with the safety requirements in the Short Term Lessons Learned (NUREG-0578) as required for all plants including those that are operating. Some specific requirements of proposed Revision 2 to Regulatory Guide 1.97, however, go beyond the Short Term Lessons Learned requirements and, in light of this, do not appear justi-fied for plants as near completion as Fermi 2. Fermi 2 is about 83% completed, and we feel it should be treated like an operating plant when new requirements are considered.

Edison will be prepared to discuss specific examples, based upon ~

our review, albeit preliminary, at our meeting on December 14, 1979 in Bethesda.

Sincerely, g

$Vb WHJ/LES:jl ec: D. E. Howell L. L. Kintner (via Emery Express)

  • J. F. Stolz (via Emery Express) 1581 550 i

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