ML20205H185
| ML20205H185 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/13/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20205H190 | List: |
| References | |
| VP-85-0209, VP-85-209, NUDOCS 8511150008 | |
| Download: ML20205H185 (5) | |
Text
-. -
T v
2%"4"4".sbons sf '
Nuclear Oper Detroit r-E Edison me.xw! Highway 6400 North O e-Nuclear o---
November 13, 1985 VP-85-0209 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:
Reference:
(1)
Fermi 2 NRC Docket No.-50-341 NRC License No. NPF-43 (2)
Letter from Detroit Edison to NRC,
" Request for Exemption and Amendment to NPF-43 Regarding Containment Inerting",-
RC-LG-85-0052, dated October 9, 1985 (3)
Letter from NRC to Detroit Edison,
" Request for Exemption and Amendment to NPF-43 Regarding Containment Inerting",
dated November 6, 1985
Subject:
Request for Exemption and Amendment to NPF 4D'Recardina Containment Inertina 33 Reference 2 transmitted Detroit Edison's request for exemption to the requirements of 10 CFR 50.44.
The NRC's response was provided in Reference 3 noting additional
-information was required to support their review process.
The following presents a modified exemption request that
- provides the requested information.
In accordance with the Code of Federal Regulations, Title 10, Part 50.12, Detroit Edison hereby requests an exemption
- f rom the requirement of ' Part 50.44 (c) (3) (i).
<~
8511150008 B51113
~
ADOCK 0590034g 08 DR PDR
\\
'I I
Mr. B. J. Youngblood November 13, 1985-VP-85-0209 Page 2 Part 50.44 (c) (3) (i) states in part, " Effective May 4, 1982 or 6 months after initial criticality, whichever is later, an inerted atmosphere shall be provided for each boiling light-water nuclear power reactor with a Mark I or Mark II type containment".
In accordance with this requirement'-and Technical Specification 3.10.5. the Fermi 2 containment would have to be inerted by December 21, 1985.
(Initial criticality occurred on June 21, 1985.)
Detroit Edison requests an exemption from 10 CFR 50.44 (c) (3) (i) to allow
- completion of the startup test program with a non-inerted containment.
Detroit Edison similarly, requests that Technical Specification 3.10.5 be changed, as indicated in the attachment, to allow suspension of Technical
- Specification 3.6.6.2 and the related instrumentation operability requirements of specification 3.3.7.5 until completion of the startup test program, or the reactor has operated for 120 effective full power days (EFPD),
whichever is earlier.
This exemption is requested due to both a protracted startup testing program and the current outage in which fire protection system modifications (i.e., installation of the 3L panel in accordance with License Condition 2.c(9) (d} } and equipment qualification modifications are being implemented.
The end of the Startup Test Program indicated by completion of-the 100% rated thermal power trip tests' described in FSAR Chapter 14 should occur by the end of October, 1986.
This is beyond December 21, 1985, but within the 120 EPPD time frame identified in the attached draft Technical Specification revision.
The regulation'(10 CFR 50.44) established a six month l
exemption period after initial criticality when inerting is not required, with the understanding and expectation that the power ascension testing program would immediately follow initial criticality and would not be delayed or i
- interrupted.
However, delays in power ascension at Fermi 2 i_
- have impacted the startup test program schedule.
Under the
. current. requirement the Fermi 2 containment would have to be inerted prior to completion of startup testing.
An
-inerted containment would significantly hamper planned inspections and would further protract the completion of the rtartup testing program.
The exemption would allow the timely completion of this program and would provide an 7
equivalent level of protection since the remaining startup tests will be performed in essentially the same manner as originally planned with respect to the magnitude and duration of power levels for each test.
1 y
-w
---w
,,.-..,-.-----,-w--.,,,-
c,--
~.
g
~
Mr. B. J. Youngblood November 13, 1985 VP-85-0209-Page 3 This!would entail no increase in the risks of operation through completion of the startup testing program with the proposed limited extension regarding initial inerting, over-the risks that were considered for the duration of this testing. program at the time the plant was licensed.
'Sinnificant Hazards Analysis As. stated in110 CFR 50.92(c), a. proposed amendment to an operating license involves no significant hazards consideration if operation of the-facility in accordance zwithlthe proposed amendment would not:
(1) involve a
.significant11ncrease in the probability or consequences of an accident previously evaluated, (2) create the possibility.of a new or different~ kind of accident from.any accident;previously evaluated, or (3) involve a significant reduction in a margin of safety.
The proposed revision to Technical Specification 3/4.10.5 would extend.the time during which Fermi 2 may pursue the
'Startup-Test-Program without inerting the containment and.
during which the monitoring instrument, required only when containment is inerted, need not.be-operable.
The proposed revision does not involve a significant increase in the
- probabilityzor consequences of.an accident previously.
evaluated.- The regulatory requirement:(10 CFR 50.44) from
. which the~ exemption is sought to support the proposed
, revision anticipated that power ascension test programs
.could be completed within six months. ' Suspending the requirement'from inerting with the core fission product inventory and' associated decay. heat that;would build.up over the life of the program was approved by the
~
regulation.
Whileithe regulation contemplated a six month -
period, typical BWR programs have. proven to actually require an' average _of 330 days.. With this simple stretch in-time during which the program is~ performed, no significantJincrease in coreninventory occurs and the same
~
effective core history is experienced.
Accordingly, the probability or-consequences ~of a hydrogen explosion within
- fx' i~
the primary containment in the event of a
- f loss-of-coolant-accident (LOCA) would not be significantly
[$
. increased.beyond that anticipated'in support of the g
regulation.
H 2
m.
Mr. B. J. Youngblood November 13, 1985 VP-85-0209 Page 4 The absence of an inerted containment during the exemption period is further compensated for by the installed and operational hydrogen recombiners at Fermi 2.
Hydrogen recombiners accomplish the same objective as the inerting system, which is to prevent the build up of a combustible mixture of hydrogen and oxygen.
The regulatory requirement from which the exemption is sought did not anticipate the
~
i installation of hydrogen recombiners nor give credit for their operation.
The proposed amendment would not create the possibility of a new or different kind of accident from any. accident previously evaluated.
The inerting requirement was included in the regulations to reduce the probability of hydrogen explosion in the event of a'LOCA.
The regulation
. allowed for delay in performing inerting to allow for performance of startup tests.
Extending the time period i
during which the startup test program is performed will not create the possibility of a new or different kind of accident.
To require inerting before the startup test program is completed could result in less assurance of safety, because of the added time and decreased ability to directly examine
- and evaluate components and systems inside containment while the tests are underway.
Further, after the containment has been inerted, inspection personnel entering the containment may be in added danger because of the possibility that nitrogen pockets may remain.
Accordingly, the. proposed amendment would'not involve a significant reduction in a margin of safety, but instead, would result in added safety.
Based on the above, Detroit Edison has determined that the
. proposed amendment does not involve a significant hazards consideration.
This matter has been reviewed and found acceptable by the 4
L NRC in a number of prior cases.
In these cases, the NRC has found that exemption from 10 CFR 50.44 could be granted without: endangering life, property, or the common defense and security and was otherwise in the public interest.
(See LaSalle Unit 1 Operating License NPF-ll, Amendment No.
12 and supporting SER, dated December 20, 1982 and Washington Public Power Supply System Project #2, Amendment
The justification for granting these i-i exemptions is also equally applicable to Fermi 2 and should be considered in granting the' requested exemption.
i e
d y
y.
.--s e,
4--w-r*-
e-g=g-e e-e-
r--i..e---y
...y,--n9-y
---vp y
y-----ngse
Mr. B. J. Youngblood November 13, 1985 VP-85-0209 Page 5 In accordance with 10 CFR 50.91, the State of Michigan has been provided a copy of this letter.
Should you have any questions, please contact Mr.'R. L. Woolley at (313) 586-4211.
Sincerely, b%
With attachment' cc:
Mr. P. M. Byron Mr. M. Dayid. Lynch Supervisor, Advance Planning and Review Section Michigan Public Service Commission k:
. -