NRC-97-0115, Application for Amend to License DPR-9,modifying Part 2.A in Order to Delete Reference to Six Letters Now Listed & Instead Refer to Encl Fermi 1 SAR

Application for Amend to License DPR-9,modifying Part 2.A in Order to Delete Reference to Six Letters Now Listed & Instead Refer to Encl Fermi 1 SAR

ML20197A970
Person / Time
Site:	Fermi
Issue date:	12/15/1997
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20197A976	List: ML20197A992 NRC-97-0115, Application for Amend to License DPR-9,modifying Part 2.A in Order to Delete Reference to Six Letters Now Listed & Instead Refer to Encl Fermi 1 SAR
References
CON-NRC-97-0115, CON-NRC-97-115 NUDOCS 9712230264
Download: ML20197A970 (10)

Text

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1 1p nousa it. ciron senier vice iwi<teni, Nu<icar cenmeien r'ermi 2 rg 04X; North thie lin) , Newpdrt, MittO (41f;6 Tel 311TM231 l'at 313M4172 Detroit Edison December 15,1997 NRC 97-0115 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D. C. 20555

References:

1) Enrico Fermi Atomic Power P. ant, Unit No.1 NRC Docket No. 50-16 NRC License Number DPR-9 pV

2) Detroit Edison Letter, NRC-96-0132, dated November 26,1996

3) NRC Letter," Applicability of Specific 10 CFR Requirements to Enrico Fenni Atomic Power Plant, Unit 1 Due to the Decommissioning Rule", dated June 25,1997

4) Detroit Edison Letter, NRC-97-0110, dated October 2,1997

Subject:

Application for a License Amendment -

Fermi 1 Safety Analysis Report The 1996 Decommissioning Rule included a provision added to 10 CFR 50.71 (e)(4) that permanently shutdown reactor facilities would bc

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required to file revisions to their Final Safety Analysis Reports (FSAR) every 24 g morths.

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' Detroit Edison communicated to the NRC in meetings and correspondence (Reference 2) about the new rule's provisions. Detroit Edison took the position that since Fermi 1, which has been shutdown for twenty-five years, doc.s not have kh(-

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USNRC NRC 97-0115 Page 2 -

letters are used as the licensing basis. In Reference 3, the NRC stated that Detroit Edison should provide the NRC with a comprehensim document reflecting the current condition of the facility. This document would constitute the Fermi i FSAR ar.d enable Detroit Edison to comply with NRC's power reactor decommissioning process of allowing licensees to decommission in accordance with the terms of 50.59. A public meeting was held on July 15,1997 to discuss, in part the Reference 3 letter.

Detroit Edison has now prepared a Fermi 1 Safety Analysis Report (FISAR).

The FISAR also includes a Fire Protection Program and a Quality Assurance Program, which were also needed to meet the requirements of the Decommissioning Rule per Reference 3. The Fire Protection Program was prepared commensurate with the risk associated with the radiological contamination of Fermi 1. The Quality Assurance Program was not required to meet 10 CFR 50, Appendix B per Reference 3, and it does not. It is a quality assurance program established commensurate with the risk associated with the radiological contamination of Fermi 1 and the status of the facility. It incorporates many of the existing procedural administrative controls in use and some additional requirements.

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\"j Detroit Edison proposes to amend Part 2.A of the Fermi 1 license in order to delete reference to the six letters now listed and instead refer to the Fermi 1 Safety Analysis Report. The Fermi 1 Safety Analysis Report is attached for NRC review. One additional hypothetical accident analysis is included in Section 8A of the F!SAR. It is a hypoth-tical reaction of secondary sodium stored in a secondary sodium storage tank. While the sodium is not new, the consequences of a potential reaction involving the contents of a tank were not previously explicitly addressed in the licensing basis. The potential radiological consequences are bounded by previous analyses. Since a new Fermi 1 Safety Analysis Report is being submitted, the new scenaris is twing included in the new FISAR rather than being submitted separately. The detailed analysis is included in this submittal. As addressed in Reference 4, Detroit Edison plans to remove this residual sodium during the Industrial Safety Improvement Project which is starting at Fermi 1.

It has recently come to Detroit Edison's attention that sodium-cooled breeder reactors typically have a small quantity of tritium in the 3econdary sodium. The existing documentation for Fermi I describes the Fermi I secondary sodium as being non-radioactive. The Retirement Report discusses that samples tested at three (3) laboratories showed the level of beta radioactivity was no higher than n

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inaturally occurring isotopes found in regular commercial grade clean (non =

radioactive) sodium, (fherefore, the ' attached Fermi i Safety Analysis Report and

~t he safety evaluation for the hypothetical secondary sodium reaction are based on 1 the secondary sodium being non radioactive,1 As a precaution, Detroit Edison will have a secondary sodium sample analyzed for tritium If tritium is :

identified,ihe NRC will be notified and the FISAR and safety evaluation revised accordingly. -

. Pursuant to 10 CFR 50,90, Detroit Edison hereby proposes to amend the > -

Possession Only License DPR 9 by modifying Part 2.A of the license, Detroit

- Edison requests the NRC approve the amendment with an implementation period of"wi hin t 60 days" to allow final approval of procedure changes required to implement the change, Detroit Edison will not use the new FISAR to perform

. safety evaluations until this amendment is approved and impkmented. Prompt ,

= NRC review and approval will be appreciated,  :

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Detroit Edison has evaluated the proposed change against the criteria of 10 CFR 50.92 and determined that No Significant liazards Consideration is ,

involved.- This evaluation is included in Attachment 1.

! The Fermi 1 Review Committee has reviewed and approved this license amendment request, including the Fermi 1 Safety Analysis Report. In

. - accordance with 10 CFR 50,91, Detroit Edison is providing a copy of this letter ,

to the State of Michigan. ,

If there are any questions, please contact Lynne Goodman, Director Fermi 1 at 313-586-1205.

Sincerely. - -

Attachments o

, . cc: A B. Beach S.W. Brown -

' G.A. Ilarris

- i J.E. Ilouse, NRC Region III=

l D.' Nelson, NRC Region til D.R. Ilshn (Michigan Dept /Public Ilealth)

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NRC-97-0115:  ;

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I, DOkJGLAS R. GIPSONido hereby affinn thst the foregoing statements are ; i based on facts and circumstances which are true and accurate' to the best of my knowledge and belief. jl t

O oOoot,fi a. GiPSos Senior Vice President On this /D day of Shadis ,1997 before me personally

appeared Douglas R. Gipson, being first duly swom and says that he executed the foregoing as his free act and deed.

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92[ . M.M /bD Notary Public 7

ROSAUE A. ARMETTA . \

NOTARY PUBLIC.MONA0ECOUNTY.MI MYCOMMISSION EXPlRES10/11/99 -

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1 Attschment I to NRC 97 0ll$

l' age i Attachment 1 O

Description of Proposed Amendment and No Significant llazards Consideration Rev;Av O

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Attachment 1 to NRC 97 0115

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( PROPOSED Ah1 ENDS 1ENT, Detroit Edisori proposes that Part 2.A of the Fermi 1 license read as follows:

't his amended license applies to the Emico Fermi Atomic Power Plant, Unit No.1 (the facility) owned by the Detroit Edison Company. The Facility is located at Lagoona Heach, Frenchtown Township, Monroe, Michigan and is described in the Fermi 1 barely Analysis Report as amended.

fi]GNil'ICANT ll AZARDS CONSIDER ATION in accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment i' wolves no significant hazards considerations. To make this determination, Detroit Edison must establish that conduct of activities in accordance with the proposed amendment would not: (1) involve a significant increase in the prob *1ity or consequences of an accident previously evaluated, or (2) create the pos ;ility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

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s The Fermi i Safety Analysis Report (FISAR) has been prepared based on the six letters currently referenced in the Fenni 1 license (May 17,1985; July 23,1986; September 15,1986; September 25,1987; September 15,1988; and December 22,1988), inibnnation gathered during the decommissioning evaluation completed this year, safety evaluations perfonned since the submittal of the six letters, and the current administrative control and surveillance procedure manual.

One additional hypothetical accidental analysis was added based on a safety evaluation perfbnned as a result ofidentifying apparent unreacted sodium in the secondary sodium storage tanks. A scenario was postulated that was not explicitly addressed in the SAFSTOR licensing basis. The safety evaluation concluded that the consequences of the hypothetical secondary sodium analysis were bounded by the previously nnalyzea primary sodium release and liquid waste tanl accidents. The hypothetical secondary sodium scenario is covered in Section 8.4 of the FIS AR.

As discussed in the July 15,1997 meeting with the NRC, the existing accident analysis calculations were not updated from previous subinittals. The previous analyses are still bounding since the additional decry in the last decade would result in lower radioactivity concentrations and therefore potential doses.

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Attachment I to NRC.97 0l15 Page 3 dp To detennine whether a signincant hazards is posed by the proposed amendment, three questions are answered.

1) Does the proposed change signincantly increase the probabdity or consequences of an accident previously evaluated?

No, the proposed submittal of the Fermi 1 Safety Analysis Report as the facility's licensing basis document does not significantly increase the probability of an accident. The FISAR is a compilation of previously submitted infonnation and other infonnation gathered on the conaition of the facility. Compilation of current infonnation and imposition of the new Fire Protection and Quality Assurance Frogram requirements will not increase the probability of an accident, if anything, the additional controls would reduce the probability of an event. Addition of the hypothetical secondary sodium scenario identifies one possible previously unidentified potential cause of a primar;' sodium release and/or liquid waste tank release. The previous submittal addresses the cause of the primary sodium release as being a fire or other catastrophic event and the cause of the liquid waste tank ruptures being possibly an earthquake. Recognition of a cause being the reaction of secondary sodium does not significantly increase the pV probability of a primary sodium release or liquid waste r ' case. A catastrophic event would still need to occur to cause tF r'ulated scenario, so there is no discemible increase in the proba .... of a primary sodium or liquid waste accident compared to the existing licensing basis.

For the reasons discussed above, substituting the F1SAR as the licensing basis foi Fenni 1 will not significantly increase the probability of an accident.

The proposed submittal of the FISaR as the Fermi l licensing basis document will have no impact on the consequences of an accident.

Consolidating curTent infonnation on the plant and previous submittals does not change the amount of radioactivity at the facility or the potential magnitude of any release during an accident. Since the potential accident s7urce teims were not updated as part of the submittal, the conr.couences of the accidents contained in the F1S AR match the consequences in the previous submittal. Though a new postulated hypothetical accident scenario was added, the secondary sodium involved in that accident is not radioactive, per previous submittals, and so the only potential radiological consequences of that scenario occur if the primary sodium or liquid waste is released and those consequences have already been reviewed in the NRC '

safety analysis for Amendment No. 9 to the Femii i liccase, Therefore, the o adoption of the FISAR as the facility's licensing basis will not significantly V increase the consequences of an accident at Fermi 1.

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() 2) Will the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?

No, establishment of the FISAR as the Fenni 1 licensing basis document will not create a new type of accident. The F1SAR is mainly a compilation of the previous licensing basis documents,infonnation on the facility condition and additional controls. It does not involve operating in any new type of mode and so cannot create a new or different type of accident. The new hypothetical secondary sodium accident contained in the FISAR is a sodium accident. One of the existing licensing basis accidents is the primary sodium accident resulting in release of the primary sodium and its activity. Th: hypothetical secondary sodium accident as analyzed may lead to the release of the primary sodium or liquid waste and so it is a potential precursor of an already identified accident (s).

3) Will the proposed change significantly reduce the margin of safety at the facility?

No, adopting the new FIS AR as the licensing basis document for Fenni 1 will not decicase the margin of safety. It will establish an up-to date licensing basis, so future changes can be apptc,priately evaluated against an pd up< lated safety analysis report. The FlSAR better describes the current condition of the plant. No physical changes will be implemented based on the submittal of the F1SAR. Some additional administrative requirements will be established in the new Quality Assurance program and in the need to keep the FISAR updated biannually, No new types of accidents are discussed in the FISAR the discussion of the hypothetical secondary sodium event is a more detailed discussion of what potentially could happen during a catastrophic event leading to a sodium reaction. A total primary sodium release was already established as a licensing basis event, Because the FIS AR will not, in itself, lead to physical changes, but will be the new standard to which future changes are compared, es'ablishment of this updated document as the Fenni 1 licensing basis will not significantly reduce the margin of safety af the facility.

ENVIRONMENTAL, IMPACT Detroit Edison has reviewed the proposed change against the criteria of 10CFR$1.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor significantly change the types or increase the amounts of effluents that may be released off site, nor increase individual or cumulative occupational radiation exposures. Based on the hc foregoing, Detroit Edison concludes that the proposed amendment meets the criteria given in 10CFRSI.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

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,, Attaciunent 1 to NRC.97-011$

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Page 5 O c<mewsum Ilased on the evaluations above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by conduct of activities in the proposed mariner, and (2) such activities will be conducted in compliance with the Conunission's regulations, and the proposed amendment will not be inirnical to the common defense and security or the health and safety of the public.

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