ML20099E243

Responds to NRC 841105 Request for Info Re Generation of Potential Finding Rept Resulting from Annulus Pressurization Review Question.Cygna Expects NRC & Util to Resolve Annulus Pressurization W/O Addl Idvp Review

ML20099E243
Person / Time
Site:	Fermi
Issue date:	11/16/1984
From:	Ferg D CYGNA ENERGY SERVICES
To:	Colbert W, Youngblood B DETROIT EDISON CO., Office of Nuclear Reactor Regulation
References
NUDOCS 8411210184
Download: ML20099E243 (3)

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~ 150 North Wacker Dme, Chicago, IL 60606 - 312/236-5701 83021.057 November 16, 1984 Director of huclear Reactor Regulation Attention: Mr. B.J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William F. Colbert, General Supervisor Nuclear Safety and Plant Engineering (342 NOC)

The Detroit Edison Company Enrico Ferni-2 Nuclear Operations Center 64 North Dixie Highway Nawport, Michigan 48166

Subject:

Telephone Conversation Summary - 11/5/84 Independent Design Verification Program Detroit Edison - Enrico Fermi Unit 2 Docket #50-341

References:

1) NRC Letter from B.J. Youngblood to Wayne H. Jens of Detroit Edison and L.L. Kammerzell of Cygna dated March 27, 1984

2) Detroit edison Letter from Wayne H. Jens to B.J. Youngblood of NRC dated September 27, 1984 (EF2-72252)

Dear Mr. Youngblood:

On November 5,1984, a telephone conversation occurred between Mr. M.D.

Lynch of the NRC and Mr. D.A. Ferg of Cygna concerning the Final Report for the Independent Design Verification Program (IDVP) on Fermi-2. The discussion cen-tered on Cygna's response to Enclosure 2, Item 2 to the referenced NRC letter (Reference 1) involving annulus pressurization (A/P) loads. In the conver-sation, Mr. Lynch questioned why Cygna had not generated a Potential Finding Report as a result of the annulus pressurization review question.

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n Youngblood/Colbert' November 16, 1984 83021.057 Page 2 Cygna originally raised the question of A/P loading on piping during the

. initial IDVP review stage. At that time, Cygna noted that A/P loads were con-sidered in the support design but not in the pipe stress design. Observation PI-01-11 was written and subsequently closed based principally upon the GE design specification which explicity omitted A/P loads as a design requirement.

In reference (1), the NRC stated that A/P loads should be included in the design basis assessment and requested further study by Cygna.

As indicated in our response submitted to the NRC and Detroit Edison on October 19, 1984, Cygna found sufficient differences between the A/P analytical model geometry and the as-built configuration to preclude drawing a conclusion on structural integrity of the RHR piping element under faulted load conditions.

Furthermore, sufficient documentation for the A/P load study performed by Detroit Edison /GE was not available for Cygna to reconcile the differences in geometry. This position was first identified to the NRC and Detroit Edison in a meeting in Bethesda, Maryland on May 11, 1984.

In a subsequent telephone conversation in late May, 1984 (Attachment A),

the NRC indicated that Detroit Edison would be performing re-analyses of the reactor annulus piping for faulted loads. We were advised that the NRC and Detroit Edison had agreed to resolve this issue without further review by Cygna.

Without the A/P reanalysis results Cygna was unable to proceed further with our review activities in response to Enclosure 2, Item 2 in the referenced NRC letter.

If the review process had proceeded and a Potential Finding Report had been written, Cygna would have asked to review the reanalyses referenced in the September 27, 1984 letter from Detroit Edison to the NRC (EF2-72252, Reference 2). This requirement is contained in Cygna's methodology for conducting the IDVP and resolving Potential Finding Reports (refer to Section 3.0 in the IDVP Final Report, Volume 4). This review would be performed in order for Cygna to make a determination with respect to the effect of annulus pressurization on plant safety.

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Youngblood/Colbert November 16, 1984

-83021.057-Page 3 Reference 2 provided the NRC a specific response to Enclosure 2, Item 2 in Ref3rence 1. At this point, Cygna's expects that the-NRC and Detroit Edison

- will resohe the A/P loads issue without requiring Cygna to proceed with addi-tir.1al IDVP review. Unless Cygna is directed to review the A/P load reanalyses suamitted by Detroit Edison in Reference 2, the present documentation or infor-mation contained in the IDVP Fiaal Report should be sufficient.

If you have any further questions or comments on the A/P loads issue or if you require further clarfication of Cygna's position, please contact us as soon as possible.

Very truly yours MM David A. Fer Project Manager DAF/bw cc: M. D. Lynch (NRC,NRR-D0L)

J. G. Keppler (NRC IE, Region III)

0. K. Earle (DECO) l 4