ML20111B796
| ML20111B796 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/09/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| EF2-72236, NUDOCS 8503130230 | |
| Download: ML20111B796 (6) | |
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Wan H. Jens Vee President Nuclear Operatsns 6*
Fermb2 6400 North Ome Highway ISOn < Newport, Mchigan 48166 March 9, 1985 3133 ses.4tso EF2-72236 Mr. Harold R.
Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Denton:
Reference:
(1) Fermi 2 NRC Docket No. 50-341 (2) Detroit Edison to NRC Region III Letter,
" Post - Fuel Load Preoperational Testing," NE-84-1792, January 11, 1985 (3) Detroit Edison to NRC Letter, " Fermi 2 Technical Specification Certification,"
EF2-72019, November 26, 1984
Subject:
Request for Issuance of Operating License The Detroit Edison Company with this letter certifies that the design, construction and preoperational testing of Fermi 2 are substantially complete and we will be ready to load fuel on March 18, 1985.
We would like to receive the Operating License on or about March 15, 1985, to allow care-ful review of the license, particularly the Technical Speci-fications, before loading fuel.
The Final Safety Analysis Report and other licensing documents and letters submitted to the NRC provide an accurate description of the construct-ed plant and the organization and administration, except for j
future activities specifically noted in those documents or herein.
Inherent to this statement is the acknowledgement of the normal update process which translates current con-struction documents into submittals to the NRC, e.g.,-design drawings to FSAR figures.
Edison's position that Fermi 2 is ready for fuel load is supported by the following:
A.
Personnel Readiness The Nuclear Production Staff has completed the qualifi-cation of its Senior Reactor Operators and Reactor Operators to provide the required staffing.
Their training included the required classroom instruction f
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-Mr. Harold Denton March 9',J1985 EF2-72236 j
Page 2 and time.on shift at other(operating plants.
The opera-j ting staf f is' supplemented by contract Shif t. Operating Advisors until all.necessary Fermi 2 staff have accumu-i~
lated the required level of operating experience.- The experience and training of these individuals have been detailed in submittals to the NRC to document their j
acceptability.
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The qualifications and experience of Fermi 2 management j'
have been documented and provided to-the.NRC.-
These-1
. qualifications confirm that Fermi 2 will1 be managed and j
operated'in a safe and prudent manner.
i The engineering support staff has extensive experience 4
with the design, construction and. testing of Fermi 2.
.j This knowledge within the. Edison staffiensures that long-term operation will' be ' conducted with insight to T
l past concerns and issues.
Similarly, the administra-1-
tive staff has been trained to further ensure the appro-j priate level of' readiness.
i The security system has been activated and is operation-al.
The activation followed system testing and an extensive training program for site personnel on secur-Ity and safety.
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The June 26-27, 1984, Fermi 2 Full-Scale Emergency Exer-j cise demonstrated that Edison and the offsite agencies j
-in the EPZ can promptly and properly respond to radio-logical emergencies.
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To properly support the transition from construction to l
operation, Edison transferred, as of August 1, 1984, l
the responsibility for the project and completion of I
remaining items from the Project Management Organiza-
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tion to the Nuclear Operations Organization.. Appropri-3 ate elements of the Project Organization-have been i
retained under Nuclear Operations controllto assist l
l ongoing. construction' activities and to' help resolve issues which~may arise during power ascension tests.
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B.
Design / Construction Readiness-I The Fermi ~2 design and construction are in accordance i
with~the Final Safety Analysis Report (FSAR) and correspondence submitted to the 2Htc.
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Mr.-Harold Denton 1
March:9, 1985 i
EF2-72236 Page 3 Outstanding work activities identified by the NRC or Edison as restraints to fuel load are being completed accordingly.
With reference to the operability of the emergency diesel generators, the damaged units.have been repairedLand will be tested and ready to support plant operations before fuel load.. In addition, the electrical and instrumentation and controls drawing /
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as-built deviations, as agreed in the. February 20 meeting (Category A and Category B hardware items),
will be corrected before loading fuel.
Other work items.have been reviewed, evaluated and concurred-that j
they are not required for safe operation at-fuel load.
l They.have been reviewed with the.NRC Resident Inspector and.are being tracked on the Milestone Report against-appropriate completion milestones, j
C.
Preoperational Tests The preoperational tests to date confirm the capability I
of those ' systems tested to perform their design func-
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tions.
Preoperational tests of systems required to j
support fuel load have been completed.
'A few systems, j
not' required for fuel load'and/or which require _ reactor l
steam to be fully _ tested, will be tested at a later
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date as noted to you in Reference (2).
l D.
Procedures j
Procedures necessary for fuel load have been identified.
i They will be reviewed and approved and will'be' effec-1 tive before fuel load.
The remaining procedures will be_ completed commensurate with operating needs.
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E.
Licensing Issues Edison has maintained active communication with both
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i NRR and Region III to ensure open. items are mutually understood and resolved in an expeditious manner.
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The general areas requiring Edison action are discussed below.
NRR Itemst. Continuous dialogue has occurred with the l
NRR Project Manager'(Mr. M. D. Lynch)?to' discuss and~
status open items requiring resolution.
There are I
currently no fuel-load related open items from'NRR that l
require an. Edison response.
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lMr.rHarold Denton March 9, 1985'
.EF2-72236 Page 4 1
j 10CFa50.55(e) Items:
Edison has provided to the NRC l:
either an interim or final response to-the open i
50.55(e) concerns.
Edison considers that-none of the open 50.55(e); items are constraints to fuel. load..
Inspection 'P,eport Noncompliances:
Edison has provided 1-comprehensive, responses to the open noncompliances in i
accordance with the federal requirements.
Where re-l sponses have not been submitted, due to either time constraints (i.e., a 30-day response is not~ required until post fuel load) or the nature of.the issue, the items have been discussed with the NRC Resident-Inspec-1-
tor and Region III Project Management and' concurrence has been-reached as to appropriate milestone dates for 1
i the items.
None of the open items are judged to be of sufficient concern to be a constraint to fuel load.
l This applies to noncompliances, open and unresolved items.
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Technical Specifications:' The final draft of the Fermi 2 Technical Specifications was certified by Elison in Reference (3).
Since then, Edison has requested several modifications to the draft Fermi 2
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Technical-Specifications to reflect the results of preoperational and surveillance testing, to improve clarity, and to correct minor typographical errors.
Each of'the proposed changes has been carefully i
reviewed and found to be necessary to reflect the plant design and procedures..
Accordingly, incorporation of 1
these items into final Technical Specifications issued as Appendix A to the' License.is considered essential.
F.
Design / Construction Assurance Reviews Fermi 2 has undergone several independent reviews a$d i.
many internal reviews to verify it was designed and i
built in accordance with the applicable codes, stand-ards and procedures.
A brief-description of the inde-g ',
pendent-reviews and their results follows.
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CYGNA Independent Design Review:
CYGNA Energy Services, Inc., performed an independent' assessment of key elements -in the shutdown cooling. path and the 2
design control process at Fermi 2.
.The multi--
i disciplined' assessment concluded the_" design'and design i
control activities on Fermi-2 have-been-' adequately i
performed in accordance with the project commitments I
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I Mr. Harold Denton March 9, 1985 EF2-72236 Page 5 and standard engineering practice.
Furthermore, suf ficient assurance exists that the public health and safety will be protected."
The initial report and supplements have been provided to the NRC as well as applicable Edison responses.
Final Construction Assessment:
Duke Power Company
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conducted an assessment of the constructed plant.
The main purposes of this assessment were to:
(1) make a final walkdown of parts of the safety-related systems and structures in the Reactor and Auxiliary Buildings to determine if significant deviations from final design disclosure documents exist; (2) review and evaluate previous " third-party" assessment reports to determine whether they can be incorporated into the conclusions of the final assessment of the construction report; and (3) provide a report on " Fermi 2 Final Assessment of Construction" to Edison and the NRC.
The Duke Power report concluded that the construction of Fermi 2 was conducted in an acceptable manner and in conformance with the design-documents, subject to the resolution of specific concerns.
The individual concerns have been closed by the NRC (21 of 24), are resolved within Edison and available for NRC review (2), or are agreed to be a post-fuel load item.
SAFETEAM:
An organization independent from the project has the opportunity to interview all personnel (craft, technical and administrative) when they leave the Fermi 2 project.
In addition, QA/QC personnel are periodically interviewed to confirm that adequate cor-rective actions are being initiated in response to their concerns.
Concerns identified in these inter-views and their resolution are formally documented.
This program has been audited by the NRC and is moni-tored by the NRC Senior Resident Inspector.onsite.
In addition to the independent reviews described above, Detroit Edison has completed an extensive walkdown pro-gram to assure that lead design documents and drawings are adequately updated and reconciled with the as-constructed unit in order to support efficient opera-tion and maintenance of the plant.
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Mr. Harold Denton March 9, 1985 EF2-72236 Page 6 In addition to the above, Edison has performed various inter-nal ' readiness-for-fuel load' evaluations.
These evalua-tions, including one performed by an independent contractor, enabled me to inform the Nuclear Review Committee of the Board of Directors of Detroit Edison at their meeting on December 19, 1984, that Fermi 2 was closely approaching
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readiness to load fuel.
Assuming receipt of the Operating License by March 15, 1985, a conference call will be held on that date with the Nuclear Review Committee members to allow me to complete my recommendation that Fermi 2 is ready to load fuel.
Notwithstanding, once the operating license is issued, the' Plant Superintendent, the Manager of Nuclear Operations, and I will~ withhold permission to load fuel until we are convinced that the plant and plant staff are ready.
2 To the best of my knowledge, the foregoing paragraphs address the major activities which bear on your issuance of the Fermi 2 Operating License.
Accordingly, we respectfully request issuance of the operating license by March 15, 1985, so that this activity may proceed as planned.
Sincerely, i
cc:
Mr. P.
M.
Byron Mr. J. G.
Keppler j-Mr.
R. C.
Knop Mr. M. D. Lynch Youngblood Mr.
B. J.
USNRC Document Control Desk i
Washington, D. C.
20555 J
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