ML20080Q105

Responds to Generic Ltr 83-24 Re TMI Action Item I.G.1, Special Low Power Testing & Training. Util Will Comply W/Bwr Owners Group Position W/Special Test Incorporated. FSAR App H Will Be Revised

ML20080Q105
Person / Time
Site:	Fermi
Issue date:	10/05/1983
From:	Jens W DETROIT EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
TASK-1.G.1, TASK-TM EF2-65-898, GL-83-24, NUDOCS 8310120190
Download: ML20080Q105 (2)

Text

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Detroit* , P/; ta yt1 A, rr p 31 1 8 October 5, 1963 EF2 - 65,898 Director of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

(1) Enrico Fermi Atomic Power Plant, Unit 2 NRC Docket No. 50-341 (2) Letter H. Tauber to R. L. Tedesco, EF2-53285, dated May 14, 1981, "TMI Task Action Item I.G.1, Special Low Power Test Program for BWR's" (3) Letter W. F. Colbert to L. L. Kintner, EF2-53430, dated June 3, 1981, " Simulated Loss of AC Power Special Test" (4) Letter W. F. Colbert to L. L. Kintner, EF2-53825, dated June 22, 1981, " Position on I.G.1 Special Test" (5) Letter H. Tauber to B. J. Youngblood, EF2-60717, dated February 14, 1983,

" Simulated Loss of AC Power Test" (6) Letter D. B. Waters to U. S. Nuclear Regulatory Commission, Attn: D. G. Eisenhut, BWROG-8120, dated February 4, 1981 "BWR Owners' Group Evaluation of NUREG-0737 Requirement I.G.1, Training During Low Power Testing" (7) Letter D. G. Eisenhut to all BWR Operating License Applicants, Generic Letter 83-24, dated June 29, 1983, "TMI Task Action Plan Item I.G.1, 'Special Low Power Testing and Training,' Recommendations for BWR's"

Subject:

Commitment to BWR Owners' Group Position in Accordance with Generic Letter 83-24 1

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Mr. B. J. Youngblood October 5, 1983 EF2 - 65,898 Page 2 The following is submitted in response to Generic Letter 83-24 (Reference 7) dealing with TMI Action Plan I.G.1, Special Low Power Testing and Training.

Detroit Edison has confirmed an earlier statement (Reference 5) that the station blackout test would pose c risk to drywell equipment. Calculations indicate that the non-safety related equipment in the drywell would reach a limiting temperature (185 degrees F) within approximately three (3) minutes. Therefore, since the test would provide little if any meaningful data but has a high potential of damaging equipment, Detroit Edison will comply with the BWR Owners' Group recommendation to constitute compliance with Item I.G.l.

This position has been confirmed in analysis performed for the Susquehannah and LaSalle plants.

As noted on page 20 of Reference 6, Detroit Edison has supported the BWR Owners' Group position as being necessary and sufficient to meet the requirement of Item I.G.l. Detroit Edison reaffirms this position and commits to comply with the Owners' Group position detailed in Reference 6. The special tests so defined will be incorporated into our present programs for preoperational and startup testing and will be handled in the same manner as the other tests and test procedures within this programming in accordance with the requirements of Regulatory Guide 1.68.

It is the position of Detroit Edison that the above commitment supersedes previous commitments made in References 2, 3, 4, and 5. Section H.I.G.1 in appendix H of our FSAR will be revised to replace all l

previous commitments related to the Station Blackout test with a commitment to comply with the BWR Owners' Group position.

If you have any questions, please contact Mr. O. Keener Earle (313) 586-4211.

Sincerely, cc: Mr. P. Byron Mr. M. D. Lynch

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