ML20101A135
| ML20101A135 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/12/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Novak T Office of Nuclear Reactor Regulation |
| References | |
| EF2-72028, NUDOCS 8412180175 | |
| Download: ML20101A135 (11) | |
Text
r Wayne H. Jens Vics Prtsident Nuclear Operatens M
Edison =r!.orin on.. sign.y i
= " " -
December.12, 1984 EF2-72028 f
Director of Nuclear Reactor Regulation
.)S' Attention:
Mr T. M. Novak, Assistant Director for Licensing
', l/ '
Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Novak:
References (1)
Fermi 2 NRC Docket No. 50-341 (2)
NRC letter to Detroit Edison, "Enrico Fermi Atomic Power Plant, Unit 2 - Draft License" l
dated November 27, 1984
Subject:
Comments on Draft Operating License In response to Reference 2, Detroit Edison has reviewed the draft operating License for Fermi-2 and comments are provided in Attachment A.
As Edison is provided drafts of elements of the license not reflected in Reference 2, additional comments may be forthcoming.
Please direct any questions to Mr. O. K. Earle at (313) 586-4211.
Sincerely I
cc:
(All with Attachments) kM) #
Mr.
P. M. Byron U
Mr. R. C. Knop (NRC-RIII)
Mr. M. D. Lynch Mr. J. N. Reyes Jr. (NRC-RIII)
Mr. B. J. Youngblood USNRC Document Control Desk Washington, DC 20555
$9 d40 0412180175 041212 PDR ADOCK 05000341
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A PDR
ATTACHMENT A:
Detroit Edison
' Comments on Draft OL 1.-
Paragraph:
Entire License Discussion:
The draft Operating License (OL) references the plant as "Enrico Fermi Atomic Power Plant, Unit 2".
In accordance with Edison's transmittal letter for Amendment 53 to the OL application and FSAR (dated February 22, 1984), the project name was changed to
" Fermi-2".
The OL should reflect this change.
2.
Paragraph:
1.A through 1.I Discussion:
Detroit Edison has no comment 3.
Paragraph:
2.A and 2.B (1), (2), (3), and (5)
Discussion:
Detroit Edison has no comment 4.
Paragraph:
2.B(4)
Discussion:
The sentence should be revised to read:
" DECO, pursuant to the Act and 10CFR Parts 30, 40 and~70, to receive, possess, and use in amounts as required any by product, source or special nuclear material..."
5.
Paragraph:
2.C (1)
Discussion:
Paragraph 2.C (11) addresses the Post-Fuel-Loading Initial Test Program, ie, the Startup Test program.
Reference to startup tests in paragraph 2.C (1) should be deleted.
Attachment B to this letter provides a list of preoperational tests which may not be completed at fuel load.
It is presented as a draft of to the OL.
It is anticipated that the number of post fuel load preoperational tests will decrease.
l Detroit Edison will keep the NRC informed on the status of this item.
Attachment C to this letter provides discussion on the justification of the tests being performed after fuel load.
6.
Paragraph:
2.C (2), (3) and (4)
Discussion:
Detroit Edison has no comment L
^
e 4
\\
- 7..
Paragraph:
2.C-(5)
Discussion:
This issue was previously discussed in the SER and_ supplements 1, 3 and 4.
SSER 4 closed the discussion of this issue saying:
"After'the issuance of the generic-SER containing the resolu-tion of our concerns.in NUREG-0803, the applicant will be required to make any changes necessary to protect the health and safety of the public." -(The' draft IOL references SSER 5 as detailing the
' license condition.
This supplement has not been issued-yet.)
Edison considers the SSER 4 write-up sufficient since it
- acknowledges that Edison's response to the generic SER will document how Fermi 2 will address this concern and the current status of this indicates that the level of the concern is such that it does not warrant a license condition
[See NRC (Schwencer) to PP & L Letter,
" Resolution of BWR Scram Discharge Volume (SDV) Pipe Break, NUREG 0803",.
October 17, 1984.]
If a license
' condition-is considered necessary, it should be revised as follows in order to provide flexibility for acceptable alteration:
s
^
"Within two years or prior to startup following the next refueling outage, whichever is later,.or on a schedule proposed by DBCo acceptable to the NRC after' the issuance of the generic SER to licensees resolving the NRC staff concerns in NUREG-0803, DECO shall have implemented the actions and modifications specified by the NRC staff applicable to Fermi 2 which are in its generic SER or acceptable alternatives."
8.
Paragraph:
2.C (6)
Discussion:
Detroit Edison has no comments 9.
Paragraph:
2.C (7) (a)
Discussion:
In accordance with the recommendation in Item 10 below to delete Paragraphs 2.C (7) (b) and (c), Paragraph 2.C (7) (a) would require revision to delete the phrase "... subject to provisions (b) and (c) below."
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i g
10..
Paragraph:
2'.C (7) (b) and!(c) l; Discutuion:
In accordance with 10CFR50.59, Detroit Edison will notify the NRC-of any< pro-posed tests, modifications or experi E
ments that involve a change in'the P
Technical Specifications or an unre-L Lviewed safety question either prior to implementation or via an annual report to NRC I & E (as delineated by-50.59)..
In accordance with 10CFR50.71-(e),
. Edison will notify NRC-NRR via:the-annual FSAR revision of changes made to
~ plant or procedures, safety evaluations' L
. performed and analyses performed by anc for the NRC.
Due to the referenced regulations, and the fact that other recently' licensed BWRs* do not reflect.
requirements similar to that provided in paragraphs 2.C (7) (b) and 2.C:(7)-(c),
Edison requests-the deletion of these license conditions.
In addition, a recommended license condition for-installation of the alternative shutdown-l concept is contained in Detroit Edison to NRC. Letter, EF2-72025, December' 7, 1984.
11.
Paragraph:
2.C (8) l Discussions-This license condition-was not provided in the draft OL.
SER Section 10.2.2 l
indicates the license condition will.
require "...an inspection of the lower pressure turbine discs,during the second refueling outage..."
12.
Paragraph:
2.C (9) l Discussion:'
Detroit Edison interprets the phrase
" required experience" in the fourth line from the bottom of the license condition-to refer to the first sentence of L
license' condition.
If this is not the l
case, clarification is required.
In addition, the 30 day prior reporting requirement in the last sentence does I
not recognize conditions outside of the control of the utility, ie, an N80A leaves prematurely.
Accordingly, Detroit Edison requests modifying the last sentonce as follows:
- Facility licenses reviewed were for LaSalle 1, Grand Gulf j
1, Susquehanna 1, and WNP 2.
t
"The NRC staff shall be.uotified at least 30 days prior to the. release of any special assigned advisor who has been provided in accordance with this program or, as soon as practical, if knowledge of an imminent departure of a shift advi-sor is'not obtained until within the 30 dsys period."
'13.
Paragraph:
2.C (10)
Discussion:
This license condition was not provided for Edison review in the draft OL.
SSER 2, Section 13.5 indicated that:
...the operating license will be conditioned to require the licensee to fully implement and maintain in effect all provisions of these approved plans."
This condition appears to be redundant with 10CFR73 and 10CFR 50.54 and, therefore, should not be necessary.
14.
Paragraph:
2.C (11)
Discussion:
It is Edison's belief that the intent of paragraph 2.C (ll)(e) is enveloped by the requirements of 10CFR 50.59 and 10CFR 50.54, paragraph (a) (3).
Using
" deviation" as a criteria places unnecessary constraints and burdens on the Startup Test Program.
The conduct of the Startup Test Program with the inherent constraints on ascending power levels, provides adequate controls to assure that the health and safety of the public will not be endangered.(Refer to Fermi-2 FSAR, l
paragraph 14.1.4.7).
It is requested that paragraphs 2.C(ll)
('
(e) and (f) be deleted from the Fermi-2 Operating License.
Additionally, requirements 2.C.(11)(e) and (f) were not part of the operating licenses for LaSalle Unit 1, Grand Gulf Unit 1, Susquehanna Unit 1 or WPPSS Nuclear Project No. 2.
U
15.
Paragraph:
2.C-(12)
. Discussion:
For clarification, Detroit Edison recommends the following wording to the subject paragraph:
" Deco shall complete related installation, procedures and training and have operational in the Fermi-2 facility, its post-accident' sampling system prior to operating the facility at power levels greater than five percent of full power."
16.
Paragraph:
2.C (13)
Discussion:
.As discussed in Detroit Edison to NRC
'*1etter EF2-72013, dated November 28, 1984, this license condition should be deleted.
- 17. ' Paragraph:
'2.C (14) (a)
Discussion:
Revision of the second sentence to read as indicated below would clarify the format of the DCRDR to be submitted.
" Deco.shall submit a summary report of its DCRDR based on the BWR Owners Group methodology prior to September 30, 1985."
18.
Paragraph:
2.C (14) (b)
Discussion:
As indicated in Detroit Edison letter to NRC, EF2-72259, dated September 27, 1984, Edison has requested the reprioritization of items 5.5, 5.6, 10.1 and 10.2 to Priority 3 rating.
These items, plus the balance of Priority 3 items, will be reported in accordance with this license condition (i.e.,
Paragraph 2.C (14)].
(Also please note the referenced June 9, 1981 letter should read June 4,1981. )
19.
Paragraph:
2.C (15)
Discussion:
Subsequent to Edison's submittal to NRC dated October 11, 1984 (letter number EF2-72271), Edison has received no questions or comments from the NRC
q,o,
3 s'gl 2 '/
y on.this issue.
The draft OL references L"
SSER S which, similiarly, has not been issued.- Edison requests an expedited response from the NRC staff'so that subsequent discussions might alleviate the need for any license condition.
20.
Paragraph:
2.D.
Discussion:
Similar<to exemptions' allowed for Appendix G to 10CFR50, the Safety Evaluation Report (including supplements) described other acceptable exemptions.
Paragraph 2.D should be revised as follows:
" Exemptions from certain require-ments of Appendices G, H and J and Section 50.55(a) to 10 CFR Part 50
- are described in the' Safety Evaluation' Report.
The' exemptions' are authorized by law and will not endanger life or property or,the common defense and security and are otherwise in the public interest.
+
Therefore, the exemptions are hereby granted pursuant to 10 CFR 50.12.
With the granting of the exemptions,.the facility will operate, to the extent authorized herein, in conformity with the application, as amended the provisions of the Act, uu! the rules and regulations o f the Commission."
It should be also noted in this regard that Detroit Edison to NRC letter, EF2-72283, October 22, 1984 requested another exemption which should be included in SSER 5.
21.
Paragraph:
2.E Discussion:
Refer to Edison's comment on Paragraph 2.C (10) 22.
Paragraph 2.F and 2.G Discussion:
Detroit Edison has no comment
(
Attachment B ATTACHMENT 1 TO FERMI-2 OPERATING LICENSE NPF-33 The licensee shall complete the following requirements within the schedule noted' belows a.
The licensee shall successfully complete the following preoperational tests before initialL criticality:
E1010.001 Primary Containment Leak Detection B3100.001 Reactor Recirculation T4500.001 Reactor Building Floor Drain T4804.001 Thermal Recombiners T5000.001 Primary Containment Monitoring (except for oxygen concentration)
Gil20.001 Waste Collection Gil25.001 Floor Drain Collection b.
The licensee shall successfully complete the following preoperational tests before heatup:
C5116.001 Traversing Incore Probe-(TIP)
N6200.001 Off-Gas V4100.001 Radwaste Building HVAC X4106.001 On-site Storage Building HVAC c.
The licensee shall complete P3323.001, Post-Accident Sampling, and E1000.001, ECCS Pipe Leak Detection (moisture sensitive tape), before exceeding 54 power.
d.
The licensee shall complete C9400.001 (SPDS/ERIS) by December, 19 85.
e.
The licensee shall complete the oxygen concentration portion of T5000.001 by six (6)-
months after initial criticality.
f.
The licensee shall complete the following preoperational tests before completion of the warranty run G1135.001 Liquid and Solid Radwaste
4
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- u ATTACEIENT C
~
. Sneet :1.of 3
,=
FOST FUEL IAAD FREOFERATIOIII6L TESTIIS
,n TEST ID.
DISCUSSION -
COIE'LETION E1000.001 BCCS This detection system is only applicable to'the 51 power-Fipe Imak Detec-ECCS suction liws from the torus and is not required.
tion (anisture-for fuel load or the power ascension test program per sensitive tape) the Fermi 2 Technical Specifications. Identified and umidentified leak detection functions are add ressed by temperature and line-flow lacreases, sump-level cheages, and other methods. This system provides
~
refined leak detection information to assist operator response.
G1120.001 During the interia, a temporary vender radunste Warranty Rua C1125.001 system will be used. h vendor's Process Con-G1135.001 trol Program and description details of the sys-Liquid and Solid tem were provided to the IRC by latter EF2-71992, l
Radunste dated October 11, 1984. - h temporary system l
meets all process quality requirements and will i
support,the plant needs until the parasneat system is installed aad tested. h portions of the system.
l necessary to support the vender redunste system will he complete before initial criticality.
33100.001 h system logic-and:iaterlocks, lobe oil sub-Operationsi Condi-Reactor Recircu-system and 3C sets will have been tested before tion 2, refer to lation fadi load, although not required by Fermi 2 Tech-3.4.1.la alcal Specifications. h flow and pump operation tests will be performed during startup testing due to the core-configuration limitation, i.e.,
core F.
.The preoperational test results will be reviewed and approved between. fuel load and initial criticality.
l P
(a) Typical reference to Fermi 2 Technical Specification paragraph.
~-_....,
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ATTACRMENT C Sheet 2 cf 3 POST FUEL LDAD PREOPERATIONAL TESTING TEST NO.
DISCUSSION COMPLETION P3323.001 Post-The preoperational testing of PASS will be per-5% power Accident Sampling formed in conjunction with completion of related System (PASS) construction activities. The steps involved with PASS becoming operational have been discussed in detail with NRC Region III and documented in letter EF2-70036, dated October 31, 1984.
V4100.001 Rad-The subject HVAC systems are necessary to support Reactor Cool-waste Bldg. HVAC radwaste processing operations. The preoperational ant Heatup X4106.001 On-site testing should therefore be completed before reactor Storage Bldg.
coolant heatup.
BVAC E1010-001 The Drywell/ Reactor Building Leak Detection Systems Initial Criticality Containment Leak are not required until Initial Criticality (Modes 1, 2 Detection and and 3 per Technical Specification 3.4.3.1).
Until that T4500-001 Reactor time there will be open access to containment for visual Building Floor detection of leakage plus any leakage will have minimal Drain or no contamination.
T4804.001 The system is not necessary until af ter initial Operational Con-Thermal Recom-criticality. The postulated cor.ditions to produce dition 2, refer biners substantial hydrogen through a metal-water reaction to 3.6.6.1.
and radiolytic decorposition can not exist before-hand.
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a
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L ATTACHIENT C.
'Sheetl3 cf 3' 9
- t
~
~.d POST FUEL IAAD j
-PREOFERATIONAL TRSTING 4
4 g
ri-TEST E.
DISCUSSION COW 127105 T5000.001 Frimary This system is not necessary unless the plant is Operations 1 Containment ^m ai-operating or there is irradiated fuel.
Condition 2, toring- -
refer to 3.3.7.5,
~
except for 0 '
2 concentration.
which shall be operational six
^
(6) months af ter initial critical-ity, refer to 3.10.5.
C5116.001 The TIF systes.is used for recalibration of the Reactor Coolant Traverslag In-URM detectors and for monitoring the AFLNGR, Neatup core Probe (TIP)
LNGE.- EPR and IErWD, refer to 3.3.7.7.
It.
serves no function until the reactor is in the-power range.
N6200.001 Off-This. system has no function unless the asia con-Reactor Coolant gas denser steaa jet air ejectors are in operation, Neatup l
also refer to 3.11.2.4.
l C9600.001 ERIS/
The schedule for completion of ERIS/SPDS activi-December 1985-SPDS ties has been discussed with the MC and was docu-mested in letter EF2-71999, dated November 12, 1984.
F r