NRC-97-0039, Provides Description of Fermi 2 UFSAR Review Initiative on Docket to Make Review Publicly Available & Comply W/Enforcement Policy Criteria,Per NUREG-1600

Provides Description of Fermi 2 UFSAR Review Initiative on Docket to Make Review Publicly Available & Comply W/Enforcement Policy Criteria,Per NUREG-1600

ML20217N157
Person / Time
Site:	Fermi
Issue date:	08/19/1997
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-97-0039, CON-NRC-97-39, RTR-NUREG-1600 NUDOCS 9708260050
Download: ML20217N157 (3)

Text

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Docgle R. G1pson Senior vice l* resident. Nu&ar 'leneration Termi!-

6-l% North Dixie llay., Newport, Michigan 48166

• Tel 31:1W4201 Fat 311E41*2

- Detroit Edison August 19,1997 NRC-97-0039 U. S. Nuclear Regulatory Commission Attn: Doci ment Control Desk Washington, D.C, 20555

References:

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

2) Detroit Edison Letter to NRC, NRC-97-0006, "The Detroit Edison Company (Fermi 2) Response to Request for Information Pursuant to 10 CFR 50.54 (O Regarding Adequacy and Availability of Design Bases Information," dated February 7,1997

Subject:

Undated Final Safety Analysis Report (UFS AR) Validation initiedve in the NRC's revised Enforcement Policy, NUREG-1600, effective October 18, 1996, changes were made to provide for a two year enforcement discretion period applicable to voluntary licensee initiatives that identify and correct FSAR discrepancies. In order to qualify for enforcement discretion under the revised policy, licensees' improvement initiatives must be described in writing and publicly available. The initiatives must also include comprehensive corrective actions. The purpose of this letter is to provide a description of the Fermi 2 UFSAR review initiative on the docket to make it publicly available and thus comply with the g Enforcement Policy criteria. Q7 '

In Reference 2, Detroit Edison identified four initiatives that were being taken to provide increased assurance that Fermi 2 will continue to be configured, operated and maintained within the design bases. One of these four initiatives involved completion of an Updated Final Safety Analysis Report review. This review is a  :

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USNRC NRC-97-MS Page 2 voluntary initiative of the type encouraged by the Enforcement Policy and is designed to identify and correct discrepancies.

As discussed in Reference 2, Detroit Edison had previously initiated a focused review of the UFSAR in May 1996 aller informationNotice 96 17 was issued. This initiative was referred to as the UFSAR Overview because the nature of the review was largely an overview of UFSAR sections intended to identify obvious discrepancies based on the knowledge of the individual reviewers, as opposed to an in-depth validation of each statement in the UFSAR. After evaluating the results of the Overview and other 1996 inspection findings, Detroit Edison elected to proceed with a more comprehensive review, or validation, to improve UFSAR accuracy.

The scope and schedule of the proposed UFSAR Validation was described in Reference 2 as follows:

"In order to improve UFSAR accuracy, a further review is being planned. This review will involve comparison of the original FSAR and the NRC SER along with its supplements, with the current UFSAR and plant procedures and design documents. This comparison will result in a rebaselining of the UFSAR to provide further assurance that it is reflective of the plant and procedures, and that changes made since issuance of the Operating License have been appropriately documented. Detroit Edison expects to derive additional benefit beyond the direct improvement in UFSAR accuracy anticipated from this effort. This is expected tc include organizational performance enhancements resulting from improved institutional knowledge of the UFS AR and greater site sensitivity in the evaluation of future changes. The validation is expected to be completed by ,

February 7,1999. Discrepancies identified during the validation will be resolved l as provided by the Fenni 2 corrective action process, and necessary updates to the UFSAR will be scheduled in accordance with the requirements of 10 CFR s 50.71(e)."

The scope of the review is essentially as stated above in the quote from Reference 2 except that some specific sections of the UFSAR may be excluded. For example, Chapter 17, which describes the Quality Assurance Program, may not be included in the UFSAR Validation Project (UVP). Also, historical information included in the FSAR for the sole purpose of the licensing review process will not be verified nor will information on Detroit Edison controlled design drawings (e.g., P&ID's) that are reprinted in the UFSAR. The reason for this exclusion is that the UVP's primary I

objective is finding and correcting UFSAR accuracy problems or discrepancies and not to perfonn a configuration control audit or inspection of the plant against the UFSAR.

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USNRC NRC-97-0039 Page 3 The detailed schedule for the UVP is still being developed; however, the goal is to have discrepancies identified and corrected by October 18,1998 consistent with the NRC Enforcement Policy. Detroit Edison recognizes, however, that this schedule may be impacted by actions currently being considered by the NRC with regard to tile Millstone Lessons Learned Report, Part 2 (SECY-97-036).

The Enforcement Policy also notes that to justify the exercise of discretion, licensees must take broad and comprehensive corrective action to ensure that the licensing basis is being met. The Fermi 2 UVP meets this criteria. As described herein and in more detail in Reference 2, the UFSAR Overview identified a number of specific discrepancies in the UFSAR. Detroit Edison's corrective action was to initiate the UVP which is a significant expansion of the initial review. Additional corrective actions will be taken based on the significance of specific discrepancies identified during the UVP.

In summary, Detroit Edison believes that the UFSAR Validation Project described herein meets the criteria set forth in the Enforcement Policy. This Project, combined with the other initiatives discussed in Reference 2, will provide additional confidence in the accuracy of the UFSAR and that Fermi 2 continues to be in compliance with its licensing basis, if you have any questions, please contact Robert A. Newkirk, Supervisor, UFSAR Validation Project at (313) 586-4211.

Sincerely, , f

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cc: A.B.Heach G. A. Ilarris M. J. Jordan A. J. Kugler

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