ML20199E502

Application for Amend to License NPF-43,extending Schedule for Submittals of Procedures Generation Package from 860731 to 870331 & Summary Rept on Dcrdr from 861130 to 870731,per Sser 6 (NUREG-0798).Fee Paid

ML20199E502
Person / Time
Site:	Fermi
Issue date:	06/19/1986
From:	Agosti F DETROIT EDISON CO.
To:	Adensam E Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-0798, RTR-NUREG-737, RTR-NUREG-798 VP-86-0043, VP-86-43, NUDOCS 8606230315
Download: ML20199E502 (8)

Text

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L Edison EIB" wrL June 19, 1986 l VP-86-0043 Director of Nuclear Reactor Regulation Ms. Elinor G. Adensam, Director Project Directorate No. 3 Division of BWR Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

1) Fermi 2 NRC License No. NPP-43 NRC Docket No. 50-341

2) NUREG-0798, Supplement No. 6, " Safety Evaluation Related to the Operation of Fermi 2", USNRC, dated July, 1985

3) Detroit Edison to NRC Letter, " Edison Schedule for Response to Items in Supplement 1 to NUREG-0737", dated May 21, 1985

Subject:

Request for License Amendment to Modify License Conditions on Emergency Operating Procedures (EOPs) and Detailed Control Room Design Review (DCRDR)

Fermi 2 Operating License Condition 2.c.(17) which incorporates Attachment 2 to the Fermi 2 Operating License identifies the schedule for Detroit Edison to complete certain requirements of NUREG-0737, Supplement

1. Attachment 2, Item 1(a) indicates that Detroit Edison shall submit a summary report of its Detailed Control Room Design Review (DCRDR) prior to November 30, 1986. Item 3(a) indicates that prior to July 31, 1986, Detroit Edison shall provide a Procedures Generation Package (PGP) for NRC staff review and approval. These dates, provided by Detroit Edison in the Reference 3 letter, were based on information available at that time which indicated that Revision 4 of the BWR Owners Group Emergency Procedures Guidelines (BWROG EPGs) would be available by December, 1985 and that Fermi 2 would achieve commercial operation by the end of 1985. As the Commission is aware, these events have not occurred on the schedules anticipated. Accordingly, Detroit Edison <

requests:

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i iMs. Elinor G. Adensam

June,19, 1986

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(1) ~ that- the schedule for submittal.of. the: PGP:be' _

extended-from JulyL31,-1986 to March ~31, 1987,

. assuming.submittallof BWROG EPG Revision 4 to.NRC'

.in August,11986 and issuance.of NRC's, Safety.

' Evaluation. Report'-(SER) on BWROG EPG Revision 4 by September'30, 1986.

(2).that the schedule for submittal of1the summary.

nreport on the DCRDR.'be' extended from: November.30, 1986, to July' 31, 1987, assuming issuance,of.

-NRC's SER on BWROG.EPG Revision 4 by November

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30, 1986 and submittal.of the Fermi;:2 PGP by March.31, 1987. '

The basis :for this' request and the Significant1 Hazards Consideration-are provided in the Attachment. Detroito Edison has-evaluated-this request.for license amendment.

against 10CFR170.21 and has enclosed a check in the amount of one_hundred fifty dollars ($150.00) for the application fee. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan. If you have any questions, please. contact Mr. R. L. Woolley at (313)c586-4211.

Sincerely, 1-- kl E

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Mr. M. D. Lynch

. -Mr. W. G. Rogers.

l Supervisor, Advance Planning and Review Section i Michigan Public Service Commission

!- -USNRC Document Control Desk Washington, D.C. 20555 l

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Ms. El'inor G. Adensam June 19, 1986 VP-86-0043 Page 3 I, FRANK E. AGOSTI, do hereby affirm that the foregoing statements are based on facts:and circumstances which are true and accurate to the best of my knowledge and belief.

-1 Z FRANK E. - AGOSTI

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Vice President Nuclear Operations

-On'this' N day of , 1986, before me personally appeared F # k E. Agosti, being first duly sworn and-~says that ife executed the foregoing as his free act and deed.

i Notary Public f' ARC!A CUCK -

Notary Public, Viushtenn County, MI My Commission Expire; Dec.23,1537 mx i

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'Ms.fElinor'G.'Adsnsam-

, June'19,51986

-VP-86-0043 -

EAttachment

~Page l , ,

Technical l Basis:and Significant Hazards Consideration for'RequestEto Amend Fermi 2 License Conditions for Submittal of:

Procedures Generation Package (PGP) an'd Summary Report-.on Detailed Control Room Design Review _(DCRDR)

Procedures Generation Packace (PGP)

-Item.3(a) of Attachment 2 to.the Fermi 2 Operating

-License requires Detroit. Edison to submit a Procedures-Generation Package (PGP) for' Emergency Operating Procedures-(EOPs)~by July 31, 1986. . Item 3(b)1of the same' attachment requires implementation of Emergency

Operating Procedures based on'the PGP prior to startup following the,first refueling-outage.- These schedules were predicated on issuance of Revision 4 of.the BWROG EPGs by December, 1985 and NRC approval tar March 31, 1986. (Revision 4'of the BWROG EPGs has'not yet been submitted.to the NRC. Detroit Edison is. working'with the BWROG Emergency Procedure Committee to resolve the-few remaining open items in Revision-4. Detroit Edison expects the BWROG to approve Revision 4 for' formal submittal to the NRC during the month of August, 1986.

Detroit Edison's past. work on the Fermi 2'EOPs and related experience indicate thatLthe plant-specific analyses required to prepare the PGP.can be' completed l' within four months after~NRC' approval of the BWROG.

F EPGs. Detroit Edison, therefore, requests that.

7 Attachment 2, Item 3(a) requiring submittal of the PGP be revised to read as shown below:

I (a). Prior to March 31, 1987, Detroit Edison shall l provide for NRC staff review and approval a' Procedures-Generation Package (PGP) to meet the requirements of Section 7.to Supplement 1 to NUREG-0737.

i Detailed Control Room Desian Review (DCRDR)

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Item 1(a) on Attachment 2 to the Fermi 2 Operating License requires submittal of the Detailed Control Room Design Review (DCRDR) summary report by November 30, 1986. Detroit Edison requests that this date be revised

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to require submittal of the DCRDR summary report prior to July 31, 1987 assuming NRC approval of the BWROG EPG

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Ms.LElinor G.-Adensam 7  :

June 19, 1986:

VP-86-0043' Attachment-

Page 2.

! Revision 4 by November 30, 1986.- This represents am L eight month slip corresponding to the.eight month delay j in submittal of the BWROG EPGs.

The-need:for the requested schedule revision is predicated on the:following two points._ First, in .

Supplement 6 to.the Fermi 2 Safety. Evaluation Report-(Section 22.2, -Item I.D.1, paragraphs 3. and 4) the NRC '

! states:-

"MostLimportantly, weirequire the'DCRDR to be' performed' based on app' roved Emergency Procedures

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Guidell'nes (EPGs)~whichEin t' urn are related to a -

function analysis used to identify _information and

. control needs.)(Moreover,fa~ plant specific analysis E i must be performed-toitranslate the EPGs into plant specific technical guidelines which.will be then used, via'a task. analysis to develop-the control and information needs applicable to the Fermi 2 , .

. facility. An-approved set of EPGs will1not~be available-until about' fall-1985."

i "A DCRDR performed at the'-Fermi 2 facility prior to

? _ the development of an approved. set of EPGs_would have

to:be repeated:later, thereby significantly increasingethe licensee's effort and our: review-with

'very little advantage since we have conducted a . .

- preliminary review of:the Fermi 2 control-room design:

c. which.we found supported the issuance of.a full power

(, license."

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' The most recent set of BWROG EPGs approved by NRC is Revision 3. As the NRC Staff knows, the BWROG'is preparing Revision 4 of the BWROG EPGs.. Drafts of r . Revision 4 which Detroit Edison has reviewed show L substantial improvement over Revision-3 EPGs. An NRC approved set of'BWROG EPGs Revision 4 is not available' '

' to allow' completion of the Fermi 2 DCRDR on the schedule

[ shown in the Operating License. ,

o Detroit Edison has proceeded 'in good faith with the work j' ,

described in the DCRDR-Program Plan (submitted August 16, 1984) using drafts of Revision 4 BUROG EPGs. For i example, at Detroit Edison's' request, General Electric l has initiated development of plant-specific EPGs and the t -- Task. Analysis needed for the DCRDR.

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~Ms. Elinor G. Adensam June 19, 1986 VP-86-0043 Attachment Page 3 Detroit Edison anticipates.that the BWROG will submit

-Revision 4 of the BWROG EPGs to URC during August,.

1986. ' Detroit Edison believes that'there will be a few differences between the draft Revision 14 EPGs used in the work to date and the final Revision 4 EPGs submitted by1the BWROG. Further changes in,the Revision 4 EPGs may result from NRC review. Thus, if Detroit Edison continues working toward submittal of.the.DCRDR Summary Report on the schedule specified in the Fermi 2-Operating License, it is likely that portions of the DCRDR-will-have to be repeated. This may also require NRC Staff to repeat part or all of its review.

Second, NUREG-0737, Supplement'1, Item I.D.1, paragraph 5.1.b(iv) requires an extensive survey of various facets of the control room to identify any deviations from accepted human factors principles. To properly support the intent of this survey, an appreciable amount of operating experience is required. Due to the extended duration of the current Fermi 2 outage, the startup test-program has not been completed, and the desired level of operating experience will not be achieved in a time frame that would properly support the goals of the DCRDR. .This issue was also addressed in.Section 22.2, Item I.D.1 of SSER 6. In the SSER, the NRC reaffirmed the need for "... considerable operating experience with

. plant systems and the control room in the operational mode".

Based on the foregoing, Detroit Edison believes that-it is more practical for both Detroit Edison and the NRC staff, for the NRC to revise the schedule for submittal

'of the DCRDR summary report to reflect the schedule.for NRC approval of the BWROG EPGs. Therefore, Detroit Edison requests that the DCRDR summary report-license condition [i.e., Attachment 2, Item 1(a)) be revised to read:

Deco shall comply with the NRC staff requirements for.

the conduct of a Detailed Control' Room Design Review (DCRDR) contained in Supplement 1 to NUREG-0737.

DECO shall submit a summary report of its DCRDR prior to July 31, 1987.

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1. 4 Ms.fElinor G.-Adensam June 19, 1986-VP-86-0043

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' Attachment-

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Sionificant Hazards Consideration

- The preceding license amendment-requests.have been reviewedLagainst.the criteria in 10CFR50.92,,and.were -

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r determined not to represent a significant~ hazards-consideration as delineated below.

a)-lThe proposed amendments do notlinvolve a significant increase in:the probability.or-consequences of an accident-previously evaluated..

In regards to_the Procedures. Generation Package amendment, the' schedule ~ extension requested _does not affect.the probability or consequences ~of-accidents previously evaluated. The-Procedures-

1. Generation Package.will ensure that future

. revisions to-the EOPs properly reflect-plant-specific aspectstof Fermi 2:.-It does not affect current plant operations or procedures.

'In regards to the DCRDR amendment request,'

-Detroit-Edison has performed several reviews of l the. control room to identify and disposition any human factors deficiencies present._ The_NRC's favorable review of these reviews are-discussed i in the SER'and SSERs 1 and 5. As noted iniSSER.

L 5,>the Fermi 2 reviews to date have "... minimized F _the~ potential for operator error leading to i serious consequences as a result of human ~ factors considerations in the Fermi'2 control room".

'Therefore, the deferral in conducting the subject L 'DCRDR

will not result in a significant-increase

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in-the probability or consequences of an accident >

previously evaluated.

! b) The' subject license amendments do not create the possibility of a new or different kind of accident from any previously evaluated.

The DCRDR schedule amendment' requested ensures that the proper EPGs.and operating experience are considered in the evaluation of the control room. The amendment does not introduce the possibility of a new or different. kind of accident since previous control room reviews have led to the approval of plant operation with the current control room configuration.

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Ms. Elinor-G. Adensam

-June:19,'1986 Attachment' Page 5

.The Procedures Generation Package amendment.does not create-the possibility of,a new or different kind of accidentssince. existing emergency operating . procedures adequately address plant.

operationfand enveloptmitigation'of' accidents.-

c) -The requested license amendments do not' involve a significantereduction in;the: margin,of safety.

The requested amendments lactually only, defer-to a

, .later time both the conduct of a control room review and the revision of emergency operating

_ procedures which are designed to'further enhance safe plant operation'beyond the current levels.

Based on the foregoing, Detroit Edison concludes that issuance of the proposed license amendment involves no significant hazards considerations.

It should be noted that granting of the requested license amendments.is expected to result in the

' implementation of the subject activities at the same point in the plant's operating history as was: envisioned when the existing license conditions were developed.

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