ML20081H441
| ML20081H441 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/01/1983 |
| From: | Tauber H DETROIT EDISON CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0588, RTR-NUREG-0737, RTR-NUREG-588, RTR-NUREG-737 EF2-65-629, NUDOCS 8311070439 | |
| Download: ML20081H441 (7) | |
Text
.
Harry Tauber Group Vce President Detroit Edison EE!i==
November 1, 1983 EF2 - 65,629 Director of Nuclear Reactor Regulation Attention:
Mr.
B. J.
Youngblood, Chief Licensing Branch No. 1 Division of Licensing U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555
Dear Mr. Youngblood:
Reference:
Enrico Fermi Atomic Power Plant, Unit 2 NRC Docket No. 50-341
Subject:
D,etroit Edison Response to 10CFR 50.49 This letter summarizes Detroit Edison's program for complying with 10CFR 50.49 for Enrico Fermi Atomic Power Plant, Unit 2. provides a summary of Detroit Edison's compliance with the rule emphasizing paragraph (b) relating to the scope of electric equipment important to safety.
provides a detailed review of all aspects of 10CFR 50.49 as they relate to the Fermi-2 EQ program.
This fulfills our commitment to address the new Equipment Qualification Rule as discussed in Detroit Edison's trans-mittal letter of the Enrico Fermi NUREG-0588 EQ submittal dated July 19, 1983 (EF2-63957).
Should you have any questions, please contact Mr.
O.
Keener Earle (313) 586-4211.
Sincerely,
[
[
C N Attachments cc:
Mr.
P.
M.
Byron Mr. M.
D.
Lynch Mr. A.
S. Masciantonio 0311C70439 831101 PDR ALOCK 05000341 NO A
PDR D
1i
Summary of Detroit Edison's Compliance with The Environmental Qualification Rule 10CFR 50.49 Enrico Fermi Atomic Power Plant, Unit 2 The Detroit Edison program for environmental qualification of electrical equipment has been reviewed against the requirements of 10CFR 50.49 (Attachment 2).
The final rule establishes a new licensing requirement of identifying and qualifying a category of equipment important to safety which includes "nonsafety-related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions (paragraph (b) (2), 10CFR 50.49).
In order to clarify Detroit Edison's position on paragraph (b) of 10CFR 50.49, the following information is provided.
o With regard to 10CFR 50.49 (b) (1), safety-related elec-trical equipment located in a harsh environment is identified in Detroit Edison's July, 1983 NUREG-0588 submittal for the Enrico Fermi Atomic Power Plant, Unit 2.
o With regard to 10CFR 50.49 (b) (2), Detroit Edison has completed a review of design practices for Fermi-2 to address this issue.
The Fermi-2 safety-related elec-trical power and instrumentation and control systems are designed in accordance with IEEE 279-1971 and IEEE 308-1971 (Criteria for Protection Systems and Class IE Power Systems respectively), as discussed in the Fermi-2 FSAR.
These two standards place strict requirements on the interfacing of safety-related and non-safety related electrical equipment and are discussed in FSAR Section 3.12.3.2.3 for physical separation; FSAR Section 8.3.1.4 l
for electrical power systems; and FSAR Chapter 7 for Instrumentation and Control Systems.
These sections have previously been reviewed and accepted by the NRC Staff j
(Ref. Fermi-2 SER, NUREG-0798, dated July, 1981).
In addition to the above design practices implemented i
at Fermi-2, Detroit Edison performed an analysis of control systems in response to an NRC request referenced in the Fermi-2 SER, dated July, 1981, page 7-22; NRC l
Staff question Item 222.53, Fermi-2 FSAR, Appendix E, page E.5.222-32; and NRC IE Information Notice 79-22.
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The purpose of the analysis was to assure that non-safety grade equipment subjected to a high energy line break would not impact the protective functions per-formed by safety grade equipment in such a manner as to cause consequences more severe than those found in the safety analysis.
The results of this review have been previously accepted by the NRC Staff (Ref. Fermi-2 SER, Supplement 1, dated September, 1981)
The safety implications of Control Systems failures due to transients and accidents is also being addressed by the NRC as Unresolved Safety Issue A-47 discussed in Fermi-2 SER dated July, 1981.
Detroit Edison is follow-ing the status of this ongoing generic issue and will take action as appropriate when the issue is completely evaluated by the NRC.
Based on the design practices and various related analyses previously performed for Fermi-2 as discussed above, Detroit Edison concludes that section 10CFR 50.49 (b) (2) has been adequately addressed.
o With regard to 10CFR 50.49 (b) (3), Enrico Fermi, Unit 2 Technical Specification Table 3.3.7.5-1 identifies accident monitoring instrumentation and serves as the basis for accident monitoring requirements.
All items identified in this taole are located in a harsh envir-onment and are listed in the July 1983 NUREG-0588 sub-mittal as either qualified or justified for interim operation pending qualification, except for the standby gas treatment system radiation monitors, the reactor vessel pressure monitors, and the suppression chamber pressure monitors.
The standby gas treatment system radiation monitors are located in a mild environment and therefore are not subject to the requirements of 10CFR 50.49.
The reactor vessel pressure and suppression chamber pressure monitors are not required to function for the postulated events which cause the harsh environment and therefore have been reclassified.
(Refer to Component Reclassification in Volume III of the July, 1983 NUREG-0588 submittal).
Additional post accident monitoring equipment has been provided in response to NUREG-0737.
This equipment is discussed in Appendix H of the Fermi-2 FSAR and Detroit Edison's Response to NUREG-0737, Supplement 1, dated April 15, 1983 (EF2-62262).
As with the items discussed Page 2 of 3
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1 in Technical Specification Table 3.3.7.5-1, all additional 4
post accident monitoring equipment provided in response i
to NUREG-0737 is located in a harsh environment and is either qualified or justified for interim operation except for the radioactive noble gas, iodine, and particu-late effluent monitors and the narrow range drywell pressure monitors.
The radioactive effluent monitors are located in a mild environment and therefore are not subject to 10CFR 50.49 requirements.
The narrow range drywell pressure monitors are not required to function for the postulated events which cause the harsh environment and therefore have been reclassified (See Component Reclassification in Volume III of July, 1983 NUREG-0588 submittal).
Based on the discussion provided, Detroit Edison concludes that the equipment covered by paragraph (b) (3) of 10CFR 50.49 has been adequately addressed by Detroit Edison's July, 1983 NUREG-0588 submittal and Response to NUREG-0737, Supple-ment 1.
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l Review of 10CFR 50.49 I
10CFR 50.49 Section
. Fermi-2 EO Program a.
Applicant for a license shall establish Fermi-2 ED program has been established and an E0 Program for paragraph (b) equipment is described in Volume 1 of its Response to NUREG-0588, submitted to the NRC for review and audit in December, 1981.
This program was accepted by NRC via SER Supplement 1, dated January 1982.
A revision to the program responding to open items identified in the supplement and subsequent meetings was filed by EF2-63957, July 19, 1983.
i b.
Electric equipment important to safety Fermi-2 ED program identifies safety-related must be addressed and includes:
equipment and assigns operability codes "2A",
j "2B", "2C" and "2D" as per NUREG-0588, i
(b) (1) safety-related electric equipment Appendix E, for LOCA and HELB.
relied on to remain functional (See also Attachment 1) during and after design basis events to ensure:
1 l
(i) the integrity of the reactor coolant pressure boundary (ii) the capability to shutdown the reactor and maintain it in a safe shut-down condition l
(iii) the capability to prevent or j
mitigate the consequences I
of accidents that could result t
}
in potential offsite exposures.
(b) (2)
Nonsafety-related equipment whose (See response in Attachment 1) failure, under postulated environ-z mental conditions, could prevent satisfactory accomplishment of
}
safety functions (1), (ii), and (iii) -in (b) (1).
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Review of 10CFR 50.49 10CFR 50.49 Section Fermi-2 EO Program (b) (3)
Certain post-accident monitoring (See response in Attachment 1) equipment, c.
Requirements for (i) dynamic and seismic No new requirements defined in this rule.
qualification, (ii) protection against "other" phenomena, and (iii) mild environ-ment qualification not included in the scope of the final rule, d.
Prepare list of equipment important to This is Volume II of Fermi-2 NUREG-0588 safety identified in (b) (1), (b) (2), and submittal dated July, 1983.
The July, 1983 (b) (3).
The following information is to submittal is a revision of the December, be included in the qualification file:
1981 submittal.
(d) (1)
Performance specifications under Fermi-2 includes these requirements in conditions existing during and equipment qualification files, following design basis accidents.
(d) (2)
Electrical characteristics to meet Fermi-2 includes these characteristics in performance requirements of (d) (1).
equipment qualification files.
(d) (3)
Environmental conditions at the Environmental conditions are defined by zone location where the equipment must as discussed in Fermi-2 NUREC-0588 submittal perform as specified in (d) (1) and dated July, 1983 Volume I, Sect.
4.0.
(d) (2).
e.
Qualification program shall include assess-Fermi-2 ED program complies to the extent of ment of electric equipment to temperature, NUREG-0588, Category I and II requirements pressure, humidity, chemical effects, respectively.
radiation, aging, submergence, synergistic effects, and margins.
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Review of 10CFR 50.49 l
10CFR 50.49 Section Fermi-2 EO Program f.
Qualification methods defined for electric Fermi-2 EO program complies.
equipment.
g.
Holder of an operatin9 license shall identify All equipment, with its present status, by May 20, 1983, equipment important to safety either qualified or Justified for Interim with schedule for complete qualification.
Operation (JIO), is listed in Fermi-2's The schedule shall be either the end of the Response to NUREG-0588 dated July, 1983, 2nd refueling outage after 3/31/82 or by Volume I (Qualification Action Plans).
All 3/31/85 whichever comes earlier.
The Director JIO components have an established schedule i
of the Office of NRR may grant requests for for completion of qualification by extension of this deadline to a date no later March 30, 1985.
i than 11/30/85 for specific pieces of equipment.
In exceptional cases, the Commission may consider and grant extensions beyond 11/30/85 for comple-tion of Environmental Qualification.
h.
Notification to NRC of significant problems Fermi-2 will comply as required.
to meet EO schedule within 60 days of its discovery, i.
Applicant for operating licenses shall submit This is contained in Volume III of Fermi-2 Jusification for Interim Operation (JIO) for NUREG-0588 submittal dated July, 1983 equipment not qualified prior to fuel load.
j.
Record of qualification shall be maintained in Qualification document packages are an auditable form.
included in the Fermi-2 Environmental Qualification File.
k.
No requirement to re-qualify if NUREG-0588 Fermi-2 EO program complies.
was the previous basis for qualification.
1.
Replacement equipment is required to be Fermi-2 EO program complies to the qualified to final rule unless sound extent of NUREG-0588 requirements, reasons to contrary exist.
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