NRC-94-0124, Comments on NRC SE of Fermi 2 Restart Action Plan Issues Closeout Per Confirmatory Action Ltr on 931225 Turbine Event

Comments on NRC SE of Fermi 2 Restart Action Plan Issues Closeout Per Confirmatory Action Ltr on 931225 Turbine Event

ML20078L451
Person / Time
Site:	Fermi
Issue date:	11/22/1994
From:	Gipson D DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-94-0124, CON-NRC-94-124 NUDOCS 9411300111
Download: ML20078L451 (4)

Text

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Douglas R. Gipson sena vo P<evdern N tK Writ G e ner af er,n

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Detroit. <._ e, m n- ,-

Ecison m33msm November 22, 1994 NRC-94-0124 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

References:

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

2) NRC Letter to Detroit Edison, " Confirmatory Action Letter," dated December 28, 1993

3) Detroit Edison Letter to NRC, " Response to Confirmatory Action Letter on December 25, 1993 Turbine Event," NRC-94-0075, dated August 24, 1994

4) Detroit Edison Letter to NRC, " Supplementary Response to Confirmatory Action Letter on December 25, 1993 Turbine Event," NRC-94-0093, dated October 13, 1994

5) NRC Letter to Detroit Edison, " Fermi 2 - Restart Action Plan Issues Closecut - Safety Evaluation,"

dated November 15, 1994

Subject:

Detroit Edison Comments on the NRC Safety Evaluation of Fermi 2 Restart Action Plan Issues Closecut In Reference 3 Detroit Edison submitted its response to the NRC Confirmatory Action Letter (CAL) on the December 25, 1993 turbine event (Reference 2). This response was supplemented by Reference 4.

The purpose of this letter is to provide Detroit Edison's comments on the NRC's Safety Evaluation of Fermi 2 Restart Action Plan issues closcout provided by Reference 5 Detroit Edison has completed a review of Reference 5 which forwarded the NRC's Safety Evaluation of several Restart Action Plan Issues.

Camments resulting from that review are included in the enclosure to this letter.

In addition to these comments, we have noted that in several instances statements were made in the text of the Safety Evaluation that included the phrase "The licensee committed...". With the exception g ghe,specificcommentsintheEnclosure,DetroitEdisonisnotaware l O v0 )

9411300111 PDR 941129 -

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November 22, 1994 NRC-94-0124 Page 2 ,

of any of there statements being different than planned actions. In the interest of clarification, however, it should be noted that the only " commitments" that were intended to be formally tracked using the '

Fermi 2 Regulatory Commitment management program are those items specifically identified as commitments in the cover letters for Reference 3 and 4.

In Attachment 2 of Reference 3, Detroit Edison incorrectly used the term "hydrolyzing" to describe the method for cleaning the reactor vessel internals. The common terminology / spelling is "hydrolazing".

There were no chemicals used; water was the fluid used for the cleaning.

If you have any questions, please contact Lynne S. Goodnan at (313) -

586-4097.

Sincerely, ,

Enclosure cc: T. G. Colburn J. B. Martin M. P. Phillips A. Vegel r

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Enclosure to NRC-94-0124 Page 1.

SER COMMENTS AND ISSUES SER Pg. Item Reference 3 Detroit Edison committed to review the NRC-94-0075 extraction steam and feedwater heater Pg. 2, also drain systems and implement any Encl. 1, Pg. 9 appropriate changes prior to restart NRC-94-0093 from RF-05. This commitment was Pg. 5, 6 clarified in NRC-94-0093 to refer to specific portions of the systems. The ,

SER wording, however, implies that this ,

review has been completed.

3 Detroit Edison committed to "... moisture NRC-94-0075 carryover / removal testing..." following Pg. 2, also RF-04. The commitment did not Encl. 1, Pg. 9 specify moisture separator reheaters and extraction steam systems, and was intended to apply to the moisture separator reheaters.

3 Detroit Edison did not commit to measure NRC-94-0075 and record electrical system Encl. 1, Pg. 10, disturbances during startup and full Item 6 load to monitor torsional vibration.

This was a recommendation by a Root Cause Analysis Team in their report.

However, as noted in the referenced item, the recommendations related to torsional resonance analyses and testing on the existing machine have been dispositioned through analyses.

5 Detroit Edison mentioned that vibration NRC-94-0093 of 10 mils during initial startup would Encl. 2, Pg. 1 not be unusual. Vibration of this magnitude is possible, but not anticipated.

9 Four bundles of irradiated fuel were NRC-94-0075 inspected on site and some hardware from Encl. 2, Pg. 1, 2 4 bundles and scrapings from 3 bundles NRC-94-0093 were sent to G.E.'s laboratory, rather Encl. 1, Pg. 4 than 6 bundles being inspected at the laboratory. There were 6 bundles involved collectively, i

Enclosure to NRC-94-0124 Page 2 SER Pg. Item Reference 16 There was a potential concern expressed Inspection by the AIT on whether check valves could Report 94-005 prevent fluid draining to ECCS rooms from Radwaste. The SER implies that this.was a concern "during the event".

14 Radwaste Building separated from Turbine Final Report Building by seismic gap is not correct. Structural Also, the Radwaste Building was not Walkdown Pg. 4, 5 designed as barrier for turbine missiles. This applies to Reactor / Auxiliary Building.

5 Detroit Edison will balance the entire NRC-94-0093 T-G set during startup only if needed. Encl. 2, Pg. 2 Cover Ltr. December 25, 1993 is date of event. NRC-94-0075 12 (Cover Letter) ,

11 Detroit Edison planned to use but did Fermi 2 Chemistry not use ultrafiltration and reverse Startup Plan osmosis to remove oil. These plans Pg. 8, 9 were discussed with NRC representatives and mentioned in the Fermi 2 Chemistry Startup Plan. Instead, cellulose fiber in the condensate filter demineralizer system was used successfully as well as the other listed methods.

12 NPP-CH1-01 together with the Chemistry Fermi 2 Chemistry Startup Plan are being used for water Startup Plan chemistry control during plant startup.

These documents together were developed in accordance with EPRI guidelines.

1 Treated circulating water from Lake Erie LER 93-014-01 rather than general service water was released from the condenser tubes to the condenser hotwell.

2, 6 To be more precise, the failure initiated in blade 9 of the stage 8 blades vs. stage 8 disk. As the SER discusses, there are 6 disks and 8 stages of blades. Also, on p. 6, in Finding 6, more appropriate wording would be the disks for steges 1 through 6 blading and disks for stage 7 and 8 blading vs. stages 1 through 6 disks and stage 7 and 8 disks.

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