ML20117P462

Responds to Open Items Identified in Section 22,of Sser 5 (NUREG-0798) Re Leakage Reduction Program Requirements of NUREG-0737,Item III.D.1.1

ML20117P462
Person / Time
Site:	Fermi
Issue date:	06/03/1985
From:	Jens W DETROIT EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-0798, RTR-NUREG-737, RTR-NUREG-798, TASK-3.D.1.1, TASK-TM NE-85-0391, NE-85-391, NUDOCS 8506060392
Download: ML20117P462 (4)

Text

- ., f -: ' Wayne H. Jens

. 4,6 M:0 Vice President '

huclear Operatons -

Fermi-2 6400 North Dzie Hghway June 3, 1985 n (Newport, Michsan 48166 313> s86-4150 NE-85-0391 h

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:

References (1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-33 (2) NUREG-0798, Supplement 5,

-Safety Evaluation' Report Related to the Operation of-Fermi 2, dated March 1985 (3) Detroit Edison letter to NRC,

" Clarification of Position on Silicone Duct Sealant and Other Issues", EF2-72039, dated January 8, 1985

Subject:

-Additional.Information Regarding Fermi 2 Leakage Reduction Program Section 22, Item III.D.l.l. of Reference 2 identifies open items related to the Fermi 2 Leakage Reduction Program which require resolution prior to issuance of a full power license.

In response to these items, the enclosure provides-addition-al information regarding our Leakage Reduction Program.

We trust this letter satisfactorily' responds to your con-cerns. If you have any ' questions regarding this matter, please contact Mr. O. K. Earle.

Sincerel ,

70 e 40 cc: Mr. P. M. Byron Mr. C. R. Nichols  !

USNRC, Document Control Desk q]

. Washington, D.C. 20555 Enclosure

-8506060392 850603 I PDR ADOCK 05000341- I E PDR- i I

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.o RESPONSE TO LEAKAGE REDUCTION PROGRAM OPEN ITEMS s

Statement of NRC Open Item III.D.l.l.(a)~

- The-applicant _has stated that inspecting:for leaks using the

- helium leak detection method may be_ considered for some gas-

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eous;; systems whereas weirequire in NUREG-0737 that testing:

of ga'seous systems should include helium leak detection orc equivalent methods.

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Detroit Edison Response-The'-current' Fermi 2 Leakage Reducti'on Program. tests; gaseous

- systems .by pressurizing ' th,e system .with . air: or nitrogen to at specified pressure (usually accident pressure of -56.5 psig or thel system' relief valve set pressure)_and measuring to within 2 SCCM the flow required 7to maintainftest pressure using a11ocal leak rate test panel. The' makeup. flow is-

' equivalent to tho ~ system leakage ? rate. . This method of . leak

' testing is similar to that required. by.10CFR50 App. J for leak rate. testing of the primary containment. If_ flow is

~ detected, each' system l component will be tested with a soapy -

liquid-per--procedure to identify sources ofileakage..

. Corrective action will be taken as warranted to reduce'the~

- leakage: from each ' source, and the system will' be retested to yield.a quantitative: indication of the leakage reduction-achieved.1 This measuring methodology, leakage sourcecidenti-fication-procedure, and corrective action will ensure that leakage is reduced to the lowest practical level; as dictated by system hardware limitations.- Detroit Edison.

believes-that'this method of test is more practical than the.

helium leak 1 detection' method and is equivalent to the . helium

' leak detection method:for measuring overall. system leakage

- and for identifying and reducing individual leaks to their -

lowest practical level.

Th ough leakage will be maintained as low as practical;-for systems encompassed by the Leakage Reduction Program,' the effectsof leakage of these systems on operator exposure is

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further limited-in two ways. . These systems are located almost entirely within secondary containment.- Therefore, direct exposure of the operators is avoided because no

. operator action inside secondary containment is required directly following severe accidents or transients involving

. significant contamination'of these systems. In addition, gaseous / particulate leakage into the secondary containment would be treated by the Standby Gas Treatment System before.

being-released thereby reducing the indirect exposure from this source.

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v l RESPONSE TO LEAKAGE REDUCTION PROGRAM OPEN' ITEMS

' Statement of NRC'Open Item III.D.1.l','(b)

The applicant has not described, as we require in NUREG-0737, a program to reduce potential paths due~to design and/or operator deficiencies as discussed in.our generic letter dated October 17, 1979, to all operating.

nuclear power plants regarding the North Anna and other related incidents.

Detroit Edison Response Fermi 2 has considered the implications of NRC generic letter. dated October'17, 1979 and the subsequent-NRC IE Circular.79-21, " Prevention of Unplanned Releases of

-Radioactivity" in the initial selection of systems included in the Fermi.2 specific Leakage Reduction Program described in the FSAR. In addition, Fermi'2 design has incorporated similar' measures as those described in the above NRC docu-ments. Also, the associated open item (341/79-21-CC) was closed out by NRC Region III in NRC Inspection Report .

50-341/84-05. Based on the above Detroit Edison believes the Leakage Reduction Program currently described in the EF-2 FSAR adequately describes a program to' reduce potential paths due to design and/or operator-deficiencies.

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-RESPONSE'TO LEAKAGE REDUCTION PROGRAM OPEN ITEMS Statement'of NRC Open Item-III.D.l.l.(c)

The' applicant has statedithat a' report will be submitted to l

.the NRC staff about.the time when full power will be achi-evedzin-the Fermi 2 facility,-of.the recorded leakage'and the preventive / corrective maintenance performed as a direct result of the. applicant?s evaluation of this leakage, whereas we require in NUREG-0737 that this matter ~be imple-

~ imented by; applicants for an operating-license prior to issu .

ance of a. full power-license.

Detroit Edison Response J- .

In Enclosure D.of' Reference 3, Detroit. Edison committed to strive to' submit an advance copy of test results for 2-3 i- systems at a time, as they became available. The reason for this is that many of the systems. required to be tested will

'not:be available for test until after the initial-~ stages of ,

. heatup. ~For example the HPCI and RCIC systems require

. nuclear steam to be tested.- Also, systems such as Reactor

. Water Cleanup'and Process Sampling will'not be_ operated-at i~

normal reactor pressure until late in the heatup testing phase. Current pressure on these systems is well below

. normal 1 reactor pressure and therefore test results would be of little value at this. time.

1 2 It is expected that approximately;50% of the required leak-age testing and related leakage reduction maintenance work will'be completed during heatup and Test-Condition 1 (less

than 20% power) periods. Advance copies of these test results will.be forwarded to you within approximately 2 to 3 weeks of completion of these tests.

Advance copies of the results from the balance of these tests will also be. submitted as they become.available, and

, the overall report on the leakage reduction program will be submitted prior to commercial operation as described in the ,

Fermi 2 FSAR.

, In conclusion we believe that the Leakage Reduction Program submitted in'the EP-2 FSAR is an adequate and realistic t approach to Leakage Reduction Program' requirements and meets the intent of NUREG 0737.

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