ML20289A103

NRR E-mail Capture - Petition Review Board Initial Assessment of 2.206 Petition Regarding Fermi Unit 2

ML20289A103
Person / Time
Site:	Fermi
Issue date:	09/29/2020
From:	Scott Wall NRC/NRR/DORL/LPL3
To:	Lodge T Beyond Nuclear
Wall S
References
Download: ML20289A103 (3)

Text

From: Wall, Scott Sent: Tuesday, September 29, 2020 12:19 PM To: Terry J. Lodge Cc: Paul Gunter; Kevin Kamps

Subject:

Petition Review Board Initial Assessment of 2.206 Petition Regarding Fermi Unit 2 Mr. Lodge, The Petition Review Board (PRB) has completed its initial assessment of the petition you submitted on behalf of the organizations Beyond Nuclear and Dont Waste Michigan on April 16, 2020. The petition requested that the U.S. Nuclear Regulatory Commission (NRC) take action under Title 10 of the Code of Federal Regulations (10 CFR), Section 2.206, and included, among other requests, taking enforcement action against DTE Energy Company (DTE Energy, or the licensee) related to Fermi Unit 2 based on debris in the torus during design basis events.

The PRB performed its initial assessment to determine whether the petition meets the applicable acceptance criteria in NRCs Management Directive MD 8.11, Review Process for 10 CFR 2.206 Petitions, and its associated Directive Handbook DH 8.11,Section III.C.1. As you will recall, on June 26, 2020, I informed you that the portions of the petition requesting that the NRC take enforcement action related to tasks deferred due to the Coronavirus Disease 2019 (COVID 19) public health emergency; and COVID-19 implications on emergency planning were screened out of the 2.206 petition process consistent with the DH 8.11 Section II.A.2(d)(ii) and II.A.2(d)(v) screening criteria.

Based on its initial assessment, the PRB has determined that the issues raised in the petition, that remained after screening, have previously been evaluated/considered in NRC staff licensing reviews and none of the provisions of DH 8.11,Section III.C.1(b)(ii) apply. Accordingly, and as discussed further below, our initial assessment is to not accept the petition for review.

The primary safety concern stated in your petition is that unqualified coating above the waterline is not capable of withstanding design accident conditions, and therefore potential debris within the torus during design basis events increases the risk of blocking the suction strainers for the emergency core cooling systems (ECCS) and Reactor Core Isolation Cooling (RCIC) and increases the risk of reactor core damage. As described in the Fermi Updated Final Safety Analysis Report (UFSAR) Section 6.2.1.6, Materials, under Surfaces of Suppression Chamber (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19128A089), the coatings above and below the waterline at Fermi 2 are fully qualified coatings. Additionally, consistent with Fermi UFSAR Section 6.2.1.6, the licensee has replaced degraded coatings during the 2020 Refuel Outage. As explained in Inspection Report 2019-050, dated January 31, 2020 (ADAMS Accession No. ML20031D253), the NRC reviewed the licensees operability evaluation and concluded that even if a large area of coatings delaminated during a loss-of-coolant accident (LOCA), it would not block the ECCS strainers following a design basis accident (DBA) to the extent that functionality/operability of safety systems would be lost. Further, the quantity of coatings inside the submerged portions of the downcomers is significantly less than the amount of degraded coatings that the licensee previously analyzed as part of an operability evaluation performed during the NRC Special Inspection. Given the amount of degraded coatings below the water level that were previously shown to not challenge ECCS Operability, the NRC staff determined that it is not likely that the small amount of coatings

inside of the downcomers could pose a threat to ECCS Operability. The NRC staff remains confident that there is reasonable assurance that the public health and safety is protected.

In accordance with MD 8.11, we offer you the opportunity to clarify or supplement the petition in a public meeting with the PRB. If you decide to take advantage of this opportunity, the meeting with the PRB would be conducted consistent with the format described in MD 8.11 Section III.F (in part - you may provide any relevant additional explanation and support for your request either in person or via another agreed-upon arrangement). Please note, however, that an in-person meeting may not be possible in the next few weeks. The PRB will consider your statements and information presented at the meeting, along with the original petition, in making its final determination on whether to accept the petition for review according to the criteria in MD 8.11,Section III.C.1. Please indicate by October 9, 2020, whether you wish to have this public meeting before we close the petition.

If you have any questions regarding this e-mail, please feel free to contact me at Scott.Wall@nrc.gov.

Best regards, Scott P. Wall, LSS BB, BSP Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov

Hearing Identifier: NRR_DRMA Email Number: 819 Mail Envelope Properties (MN2PR09MB5019923251D727744C17673592320)

Subject:

Petition Review Board Initial Assessment of 2.206 Petition Regarding Fermi Unit 2

Sent Date: 9/29/2020 12:18:30 PM Received Date: 9/29/2020 12:18:31 PM From: Wall, Scott Created By: Scott.Wall@nrc.gov Recipients:

"Paul Gunter" <paul@beyondnuclear.org>

Tracking Status: None "Kevin Kamps" <kevin@beyondnuclear.org>

Tracking Status: None "Terry J. Lodge" <tjlodge50@yahoo.com>

Tracking Status: None Post Office: MN2PR09MB5019.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4863 9/29/2020 12:18:31 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: