ML20249A653
| ML20249A653 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/11/1998 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gipson D DETROIT EDISON CO. |
| References | |
| RTR-REGGD-01.025, RTR-REGGD-1.025 50-341-98-04, 50-341-98-4, NUDOCS 9806180049 | |
| Download: ML20249A653 (3) | |
See also: IR 05000341/1998004
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NUCLEAR REGULATORY COMMISSION
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June 11, 1998
Mr. D. R. Gipson
. Senior Vice President
Nuclear Generation
The Detroit Edison Company
6400 North Dixie Highway
Newport, MI 48166 -
SUBJECT:
CONTESTED DEVIATION FROM INSPECTION REPORT 50-341/98004(DRP)
..
Dear Mr. Gipson:
- in a letter dated April 30,1998, you provided a responte to the Notice of Deviation issued in
Inspection Report 341/98004(DRP). The response contested the deviation from the UFSAR
. commitment to Regulatory Guide 1.25 based on the fact that the fuel prep machine (FPM) was
not considered a spent fuel storage location. Your bases for the FPM not being a storage
location was your interpretation of the Fermi UFSAR commitment to Regulatory Guide 1.25.
Your response stated that this commitment applies to the design basis fuel handling accident
. (FHA) descrit'ed in UFSAR Subsection 15.7.4, and does not require that each postulated FHA be
evaluated us.ng the assumptions in Regulatory Guide 1.25. The radiological consequences of
other postulated FHAs are considered bounded by the analysis in UFSAR Subsection 15.7.4.
. Your response and Inspection Report 341/98004 were reviewed by an independent NRC
reviewer not associated with the original inspection. Based on this review, the NRC has
determined that the original deviation is valid. The following information provides the basis for
this determination.
In your response, you stated that the fuel preparation machine is not considered a spent fuel
storage location. It is our understanding that you did store, for convenience, a spent fuel bundle
ovemight in the FPM on November 14-15,1997, and over the weekend from November 15-17,
- 1997. The use of the FPM as a temporary, convenient storage location was contrary to the
functions of the FPM as stated in the first full paragraph on UFSAR Page 9.1-6 of
Section 9.1.2.2.1: "The function of the fuel-preparation machines is to remove and replace fuel
. bundle channels. The fuel preparation machines are used for fuel inspections and new fuel -
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~ receipt / transfer activities."
. A fuel bundle stored in the FPM provides only 20.5 feet of water over the bundle, compared with
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, the 22 feet of water analyzed for in the Chapter 15.7.4 FHA analysis. The level of 22 feet was
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incorporated into Technical Specification 3/4.9.9. Your contention was that in Section A.1.25 of
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Appendix A of the UFSAR, the analysis of the FHA as discussed in Section 15.7.4 is in
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conformance with the regulatory position of this guide. However, Position 1.c of the guide states
that for water depths less than 23 feet, the iodine decontamination factors will be less than those
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assumed in the guide and must be calculated on an individual case basis. Whereas the 22 feet
Technical Specification limit (being .1 foot less than the 23 feet specified in the Regulatory Guide)
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had been analyzed as required by Position 1.c, the individual case of cpent fuel stored in the
FPM at a depth of 20.5 feet and, apparently, the individual case of spent fuel being moved in the
cattle chute at a depth of 19 feet were not analyzed until the NRC raised the issue.
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D. Gipson
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Fortuitously, the radiological consequences calculated in a sensitivity study by GE determined
that both were bounded by the UFSAR Section 15.7.4 analysis. This mitigates the safety
significance but does not excuse the failure to follow the Regulatory Guide as committed to in
UFSAR, Appendix A. In cases where one or more variables change, such as water depth, an
up-front evaluation must be conducted to ensure that the original analysis remains bounding.
Sincerely,
.Lin
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offr6y E.
r lnt, Cire . tor
ision of R ctor FA/jects
Docket No.: 50-341
' License No.: NPF-43
cc:
N. Peterson, Director
Nuclear Licensing
P. A. Marquardt, Corporate
Legal Department
Richard Whale, Michigan Public
Service Commission
Michigan Department of
Environmental Quality
,
Monroe County, Emergency
Management Division
Emergency Management
. Division, MI Department
of State Police
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D. Gipson
-2-
Fortuitously, the radiological consequences calculated in a sensitivity study by GE determined
that both were bounded by the UFSAR Section 15.7.4 analysis. This mitigates the safety
significance but does not excuse the failure to follow the Regulatory Guide as committed to in
UFSAR, Appendix A. In cases where one or more variables change, such as water depth, an
up-front evaluation must be conducted to ensure that the original analysis remains bounding.
Sincerely,
/s/ Geoffrey E. Grant
Geoffrey E. Grant, Director
Division of Reactor Projects
Docket No.: 50-341
License No.: NPF-43
cc:
N. Peterson, Director
Nuclear Licensing
P. A. Marquardt, Corporate
Legal Departmsnt
Richard Whale, Michigan Public
Service Commission
Michigan Department of
Environmental Quality
Monroe County, Emergency
Management Division
Emergency Management
Division. Mi Department
of State Police
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DOCUMENT NAME: G:\\FERM\\FERMICON.DEV
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