NRC-08-0049, Response to NRC Unresolved Item Resolution Inspection Report 05000341-08-008

Response to NRC Unresolved Item Resolution Inspection Report 05000341-08-008

ML082250256
Person / Time
Site:	Fermi
Issue date:	08/04/2008
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-08-0049 IR-08-008
Download: ML082250256 (2)

Text

Joseph H. Plona Site Vice President 6400 N.Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 DTE Energy-10 CFR 50.109 August 4, 2008 NRC-08-0049 U. S. Nuclear Regulatory Commission Attention: Document Control Desk.

Washington D C 20555-0001

References:

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

2) USNRC Letter to Detroit Edison ,"Fermi 2 - NRC Unresolved Item Resolution Inspection Report 05000341/2008008," dated June 20, 2008

Subject:

Response to NRC Unresolved Item Resolution Inspection Report 05000341/2008008 In Reference 2, the NRC closed unresolved item 05000341/2005016-06, however, the NRC determined that the undervoltage protection scheme does not meet regulatory requirements, and the plant design should be modified to bring the facility in compliance with 10 CFR 50 Appendix A, General Design Criterion (GDC) 17.

Reference 2 requested a response within 30-days to either appeal the staff s determination or to describe the intended actions to address the non-compliance and the proposed schedule to complete those actions. Due to transmittal problems, Reference 2 was not received by Fermi 2 until July 9, 2008. The Fermi 2 Licensing Manager discussed the situation with the NRC Region III Engineering Branch 2 Chief on July 9, 2008, and it was agreed that Detroit Edison's response would be provided by August 11, 2008.

Detroit Edison does not intend to appeal the NRC's backfit determination. A plant modification design is in progress to provide additional degraded voltage logic that will separate the plant from the electrical grid if a degraded voltage is present for approximately 6-10 seconds concurrent with a safety injection / loss of coolant accident (LOCA) signal. This time delay is short enough to ensure the loads are powered by the Emergency Diesel Generators within the time assumed in the safety analysis if a LOCA occurs during degraded voltage conditions. After implementation of the modification, the additional time delay will be

USNRC NRC-08-0049 Page 2 administratively controlled under the provisions of Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety" until a corresponding License Amendment is approved and implemented.

This modification is to be installed during a refueling outage to preclude the risks associated with tripping the plant and inadvertent separation from the electrical grid during installation. Detroit Edison proposes to perform work over the next two refueling outages with completion by the fourteenth refueling outage in the Fall of 2010. Until the modification is installed and put in service, Fermi 2 will continue to be operated as currently designed.

The following commitment is made by this letter: Detroit Edison will install a modification which will bring the plant into full compliance with GDC 17 by the completion of the fourteenth refueling outage in 2010.

Should you have any questions or require additional information, please contact Mr.

Ronald W. Gaston of my staff at (734) 586-5197.

Sincerely, cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission