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

{{Adams
| number = ML20078L451
| issue date = 11/22/1994
| title = Comments on NRC SE of Fermi 2 Restart Action Plan Issues Closeout Per Confirmatory Action Ltr on 931225 Turbine Event
| author name = Gipson D
| author affiliation = DUQUESNE LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-94-0124, CON-NRC-94-124
| document report number = NUDOCS 9411300111
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 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                                                     -
ADOCK 05000341 PDR

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USNRC                                                                     -
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
u

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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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