NRC-95-0123, Forwards Rev 1 to Radiological Emergency Response Preparedness Plan & RERP Implementing Procedures
| ML20094F858 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/03/1995 |
| From: | Mckeon R DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20094F861 | List: |
| References | |
| CON-NRC-95-0123, CON-NRC-95-123 NUDOCS 9511090107 | |
| Download: ML20094F858 (6) | |
Text
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4 Robert McKeon Assistant Vos President and Manager, operations 6400 North Dixie Hwy Edison an"r"'"
W a-4 November 3,1995 NRC-95-0123 U. S. Nuclear Regulatory Commission
/,ttn: Document Control Desk Washington. D. C. 20555
References:
1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 2)
Detroit Edison Letter to NRC," Submittal and Request for Review. " vision 13 to the Fermi 2 Radiological Emergency Respon
- paredness Plan", NRC-95-0040, dated April 10,1995 3)
NRC Letter to Detroit Edison," Request for Additional Information Regarding Revision 13 to the Fermi 2 Radiological Emergency Response Preparedness Plan (TAC No. M92348)",
dated August 16,1995
Subject:
Detroit Edison Response to the NRC Request for Additional l
Information Regarding Fermi 2 Radiological Emergency Response l
Preparedness Plan The purpose of this letter is to provide the response to the NRC Request for Additionel Information (Reference 3) regarding Fermi 2 Radiological Emergency Response Preparedness Plan Revision 13 (Reference 2) to implement Emergency Action Level changes in accordance with NUMARC/NESP-007. In response, Detroit Edison submits the following: : Responses to each of the numbered requests contained in Reference 3. : The revised Technical Basis Document.
(. '4 0 v s."r 1 r 3 i
4fl11090107 951103 POR ADOCK 05000341 ll F
PDR s
.... s USNRC November 3,1995 NRC-95-0123 Page 2 : Draft copy of EP-101, Classification of Emergencies. : Radiological Emergency Response Preparedness Plan Rev.17, section D.
Please note that EP-101 is submitted as a draft only and that minor changes may be incluried in the final version. Revision 17 of the Radiological Emergency Response Preparedness Plan, Section D includes the revisions made as a result of the NRC request. Prompt approval is requested.
If you have any questions related to this submittal, please contact Kevin Morris at (313) 586-4327.
Sincerely, 41/afmv%
Attachment cc: T. G. Colburn M. J. Jordan f
- 11. J. Miller i
A. Vegel l
4 1
s 1
Attachment I to NRC-95-0123 Responses to each of the numbered requests contained in the NRC Request for Additional Information 1
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Attachment I to NRC-95-0123 Page1-Detroit Edison Response to NRC Reauest for Additional Information Renarding Fermi 2 EAL Revision to NUM ARC /NESP-007 Methodology The following responses are numbered to correspond to the NRC request for additional information:
1 Changed AA2 EALs 1 and 2 to replace the word " unanticipated" with " unplanned".
- 2. The number 29.100.01 is readily recognized by personnel responsible for classifying emergencies as the Emergency Operating Procedure (EOP) Flowcharts. Table 14 of 29.100.01 contains the maximum normal and maximum safe operating radiation levels. The Fermi 2 EAL AA3-2 contains a concise and accurate description of the action level. As a matter of policy, Fermi 2 prefers to not copy tables from EOPs into the EAL as a means to prevent future inaccuracies. The EOPs, including tables and curves, are available in the Control Room and TSC and are monitored by personnel in L
those facilities.
- 3. Revised EAL FCl to add " Primary coolant activity level greater than" prior to "300 uCi/gm DE I-l31".
- 5. In addition to the human factor and comprehensiveness considerations previously submitted, we disagree with weighting the containment barrier less than the fuel clad and reactor coolant when combined with other barrier failures. As stated in NESP-007, Section 3.8, containment failure is a component of the leading contributors to latent fatalities. We further assert that any loss or potential loss of two fission product barriers satisfies the definition of Site Area Emergency (from NUREG-0654)in that it involves actual or likely major failures of plant functions needed for the protection of j
the public. We have revised our Technical Basis Document to reflect the above i
argument.
3
- 6. Deleted RCS Loss EAL 1 and added SA6 - Main Steam Line Break.
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- 7. The initiating condition llAl is " Natural and Destructive Phenomena Affecting the Plant Vital Area". At Fermi 2, all plant vital areas containing safety systems are within the Reactor Building, Auxiliary Building, or R11R Complex. Therefore, no other areas need be included. EAL 4 is intended to reflect the judgment of Control Room personnel since all other readily identifiable instrumentation are contained in other EALs. EAL 4 was reworded as follows: " Control Room indications that in the i
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- to NRC-95-0123 Page 2 judgment of Control Room personnel cflect damage to the Reactor 13uilding, Auxiliary Building, or RilR Complex.
- 8. NESP-007 states in the basis for IIA 6 that "This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the Alert emergency class" Fermi 2 believes the best description of those conditions is the definition of Alert as stated in NUREG-0654 (and referenced in NESP-007, Section 3.2). Therefore, Fermi 2 uses the definition of Alert as the EAL for liA6.
9 Deleted mode 4 from SUS.
- 10. Deleted loss of non-technical specification systems from SA3.
- 11. Revised SS6 EAL 1 third "and" statement to read " Indications needed to monitor safety functions associated with lost annunciators unavailable" The statement now clearly refers to safety systems with annunciation on panels P-601,602, or 603. The applicable indications for those systems is common operator knowledge.
- 12. Revised Technical Basis Document to include that emergency depressurization is used as an indication of degraded core cooling because it is readily recognized and it assumes all compensatory actions have been taken.
- 13. As explained in the NESP-007 SG2 basis, for BWRs, considerations include inability to remove heat via the condenser, or via the torus. Extreme challenges to containment result in emergency depressurization and therefore we feel are appropriate to include in the EAL. Also, as stated in Response 12, conditions requiring emergency depressurization are readily recognized and assume all compensatory actions have been taken.
Additionally, as part of the review process to address the NRC request for additional infonnation, minor editorial changes unrelated to the NRC comments were made to the RERP Plan and Technical Basis Document.
J to NRC-95-0123 i
i The revised Technical Basis Document 4
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