NRC-92-0053, Comment on NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us. Licensee Agrees W/ Comments Submitted by NUMARC & BWROG

Comment on NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us. Licensee Agrees W/ Comments Submitted by NUMARC & BWROG

ML20095J729
Person / Time
Site:	Fermi
Issue date:	04/29/1992
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-92-0053, CON-NRC-92-53, FRN-57FR6748, RTR-NUREG-1449 57FR6748, NUDOCS 9205040120
Download: ML20095J729 (2)

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operauone April 29, 1992 NRC-92-0053 Chief, Regulatory Publications Branch U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ca

Reference:

1) Fermi 2 M 3' NRC Docket No. 50-341 NRC License No. NPF-43 @- J

2) NUREG-1449, Draft Report for Comment b I <

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Subject:

Detroit Edison's Comments on NUREG-1449 9

" Shutdown and Low-Power Operation at Commercial J Nuclear Power Plants in the United States" Detroit Edison agrees that proper management of outage activities can reduce both the likelihood and consequences of events. Detroit Edison shares the same concerns and Senior Management from Fermi 2 have participated'in NUMARC's, " Shutdown Plant Issues Working Group".

NUMARC formed the Working Group to coordinate industry activities relating to shutdown safety. In December 1991, the Working Group published, " Guidelines for Industry Actions to Assess Shutdown Hanagement". Detroit Edison agrees with the guidance.

Detroit Edison finds that NUREG-1449 is a very comprehensive report which contains a thorough evaluatica of shutdown and low-power operations at nuclear power plants. Detroit Edison agrees that public health and safety has been adequately protected while plants were in shutdown conditions. However, safety improvements are possible and warranted. Detroit Edison certainly agrees that the premise

" shutdown" does not necessarily mean " safe".

The NRC staff, however, makes statements in the report with which Detroit Edison does not completely agree. An example of this is in the Executive Summary, page XV, " Mark I and II BWR secondary containments offer little protection", ... etc. The Fermi 2 secondary containment offers substantial processing capabilities when ventilation, heat transfer and condensation effects are realistically considered. A second example refers to Section 5.1.2 3 of NUREG-1449,

" Fire Protection".

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Chief, Regulatory Publications Branch U. S. Nuclear Regulatory Commission April.29, 1992 NRC-92-0053 Page 2 NUREG-1449 does not consider that fire protection equipment is required to be operable at all times that the technical specification equipment that it is protecting is required to be operable. Detroit Edison does agree with most of the principal findings and conclusions reached by NUREG-1449 Detroit Edison's primary concern is that all changes implemented as a result of NUREG-1449 will not have the proper regulatory review process. As an example, NUREG-1449 recommends changes to the " License Examiners llandbook", which in the past has been revised without a review by licensees. Changes to the " License Examiners Handbook" need LL be properly evaluated and validated to assure stress to operating crews is not increased. Detroit Edison believes that an open forum for all changes implemented as a result of the NUREG is the most productive approach.

NUMARC and the BWR Owners Group have commented on NUREG-1449 Detroit Edison agrees with the comments submitted by NUMARC and the BWR Owners Group.

The opportunity to comment on NUREG-1449 is appreciated by Detroit Edison. If you have any questions concerning these comments, please contact Mr. Joseph H. Pendergast, Compliance Engineer at (313) 586-1682.

Since.aely ,

cc: T. G. Colburn A. B. Davis H. P. Phillips S. Stasek Region III