The Detroit Edison Company One Energy Plaza, Detroit,

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Fermi 3 - Response to NRC Request for Additional information Letter No. 12.The Detroit Edison Company One Energy Plaza, Detroit, MI 48226-1279
10CFR 52.79
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
References: 1) Fermi 3 Docket No. 52-033
2) Letter from Jerry Hale (USNRC) to Peter W. Smith (Detroit Edison), "Request for Additional Information Letter No. 12 Related to the SRP Sections 01, 9.5.4, and 14.3 for the Fermi 3 Combined License Application," dated September 2, 2009
Subject: Detroit Edison Company Response to NRC Request for Additional Information Letter No. 12
In the referenced letter, the NRC requested additional information to support the review of certain portions of the Fermi 3 Combined License Application (COLA). The responses to the following Requests for Additional Information (RAIs) are provided as Attachments 1 through 3 of this letter:
* RAI Question 14.03-1
* RAI Question 01-3
* RAI Question 09.05.04-1
Construction Costs
Emergency Diesel Engine Fuel Storage
Information contained in these responses will be incorporated into a future COLA submission as described in the RAI response.
A DTE Energy Company 95
USNRC NRC3-09-0028 Page 2
If you have any questions, or need additional information, please contact me at (313) 235-3341.
I state under penalty of perjury that the foregoing is true and correct. Executed on the 2 9 th day of September, 2009.
Sincerely,
Peter W. Smith, Director Nuclear Development - Licensing & Engineering Detroit Edison Company
Attachments: 1) Response to RAI Question No. 14.03-1 2) Response to RAI Question No. 01-3 3) Response to RAI Question No. 09.05.04-1
cc: Mark Tonacci, NRC Fermi 3 Project Manager Stephen Lemont, NRC Fermi 3 Environmental Project Manager Fermi 2 Resident Inspector NRC Region III Regional Administrator NRC Region II Regional Administrator Supervisor, Electric Operators, Michigan Public Service Commission Michigan Department of Environmental Quality
Radiological Protection and Medical Waste Section
Attachment 1 NRC3-09-0028 Page 1
Attachment 1 NRC3-09-0028
Response to RAI Question No. 14.03-1 (eRAI Tracking No. 3390)
Attachment 1 to NRC3-09-0028 Page 2
NRC RAI 14.03-1
ESBWR DCD Revision 5, Section 14.3A.5 COL Information item 14.3A-1-1, requests the applicant establish a schedule for Design Acceptance Criteria (DAC) ITAAC Closure. DTE responded that this COL Item is addressed in Appendix 14.3A.1. In Section Appendix 14.3A. 1 DTE committed that, "Fermi 3 is scheduled to be licensed subsequent to the reference ESB WR Plant, will use the standard approach, and the DA C 1TAA C completion for the first standard plant will be used [COM14. 3A. 1-001]. The first standard plant, North Anna Unit 3, R-COLA, Section 14.3A.1, stated a DAC 1TAAC closure schedule would be provided within one year after ESB WR design certification. The staff reviewfound that, for the first standard plant, for selected design acceptance criteria (DAC), a closure schedule provided within 1 year would not support the NRC's need to project staff resource and budget requirements to verify DAC/ITAAC closure.
In an ESB WR DCWGpublic meeting on September 4, 2008, the staff expressed DA C 1TAAC closure schedule concerns to industry and stated that there were unique needs associated with closing out DACfor (1) piping design, (2) human factors engineering, and (3) digital instrumentation and controls. At subsequent ESB WR DCWG public meetings, the staff and industry discussed the resolution of this DAC closure schedule issue. At the public meeting on April 1, 2009, the industry proposed resolutions for the piping design and human factors engineering that the staff determined to be acceptable. For piping DA C, the NRC staff will be notified at least 6 months before (1) scheduled completion of all ASME Code design reports for risk-significant piping packages, and (2) scheduled completion of all the pipe-break hazard analyses. For human factors engineering DAC, the NRC will be notified at least 6 months before the scheduled completion of each results summary report. At the public meeting on May 14, 2009, the industry proposed a resolution for digital instrumentation and controls that the staff determined to be acceptable. For instrumentation and controls DAC, the NRC staff will be notified at least 6 months before the scheduled completion of each baseline review report and software plan designated as DAC. The R-COL applicant agreed to incorporate the acceptable resolutions for the DAC closure schedule to address COL 14.3A-1-1 in the next revision to the NAPS-3 COLA.
The NRC Staffrequest the commitment COM14.3A.1-001 be revised to either incorporate the acceptable resolutions for the DAC closure schedule outline above OR provide an alternate resolution.
Response
It is expected that Fermi Unit 3 will be licensed subsequent to the reference ESBWR plant. Fermi Unit 3 will use the standard approach as described in the ESBWR DCD Section 14.3A for Design Acceptance Criteria (DAC) closure, i.e., resolution through DAC ITAAC after COL issuance. The DAC ITAAC completion for the first standard plant will be used under the "one issue approach for DAC ITAAC closure. As a subsequent COL applicant, Fermi Unit 3 will reference the first standard ESBWR plant Licensing Topical Reports (LTRs) and NRC closure documents for DAC ITAAC closure.
Attachment 1 to NRC3-09-0028 Page 3
If, at the time of COL issuance, Fermi Unit 3 is the reference ESBWR plant, the standard approach will be used and the following DAC closure notifications will be made:
* For piping DAC, the NRC staff will be notified at least 6 months before (1) scheduled completion of all ASME Code design reports for risk-significant piping packages, and (2) scheduled completion of all (i.e., the last) the pipe-break hazard analyses.
" For human factors engineering DAC, the NRC will be notified at least 6 months before the scheduled completion of each results summary report.
* For instrumentation and controls DAC, the NRC staff will be notified at least 6 months before the scheduled completion of each baseline review report and software plan designated as DAC.
Proposed COLA Revision
FSAR Section 14.3A. I will be revised in a future submittal as shown in the attached markup.
Attachment 1 to NRC3-09-0028 Page 4
Markup of Detroit Edison COLA (following 2 pages)
The following markup represents how Detroit Edison intends to reflect this RAI response in the next appropriate update of the Fermi 3 COLA. However, the same COLA content may be impacted by revisions to the ESBWR DCD, responses to other COLA RAI's, other COLA changes, plant design changes, editorial or typographical corrections, etc. As a result, the final COLA content that appears in a future submittal may be different than presented here.
Fermi 3 Combined License Application
Part 2: Final Safety Analysis Report
14.3.9 Site-Specific ITAAC
Delete the last sentence of the first paragraph and add the following at
the end of this section. I STD COL 14.3-2-A The selection criteria and methodology provided in this section of the
referenced DCD were utilized as the site-specific selection criteria and
methodology for ITAAC. These criteria and methodology were applied to
those site-specific (SS) systems that were not evaluated in the
referenced DCD. The entire set of ITAAC for the facility, including
DC-ITAAC, EP-ITAAC, PS-ITAAC, and SS-ITAAC, is included in
COLA Part 10.
14.3-2-A Site-Specific ITAAC
This COL item is addressed in Section 14.3.9.
Appendix 14.3A Design Acceptance Criteria ITAAC Closure Process
This section of the referenced DCD is incorporated by reference with the following departures and/or supplements.
14.3A.1 Design Acceptance Criteria ITAAC Closure Options
Replace the last two sentences of the second paragraph with the
following I EF3 COL 14.3A-1-1
iSee Ins
[START COM 14.3A.1-001] Funi 5 J, bi '.ier.mqed ,.a
Huseelue~~~~t Vto t~fl Feeee e"tPj~ B WA11 Use tH i3rC,
A . Th ,I-1a Iee tm [email protected]; TA A ee.. 1__ 1-thI. --I'll . . .
plant will b. e;zd. [END COM 14.3A.1-001]S;@R9RF9
14-7 Revision 1 March 2009
Insert 1
[START COM 14.3A.1-001] If, at the time of COL issuance, Fermi Unit 3 is the reference ESBWR plant, the standard approach will be used and the following DAC closure notifications will be made:
. For piping DAC, the NRC staff will be notified at least 6 months before (1) scheduled completion of all ASME Code design reports for risk-significant piping packages, and (2) scheduled completion of all (i.e., the last) the pipe-break hazard analyses.
For human factors engineering DAC, the NRC will be notified at least 6 months before the scheduled completion of each results summary report.
For instrumentation and controls DAC, the NRC staff will be notified at least 6 months before the scheduled completion of each baseline review report and software plan designated as DAC. ISTART COM 14.3A.1-001]
Attachment 2 to NRC3-09-0028 Page 1
Attachment 2 NRC3-09-0028
Response to RAI Question No. 01-3 (eRAI Tracking No. 3486)
Attachment 2 to NRC3-09-0028 Page 2
NRC RAI 01-3
The estimate of construction costs in the COLA does not follow the format presented in 10 CFR Part 50, Appendix C, I.A.1. Please provide the overnight capital costs broken down as: (a) total nuclear production plant costs, (b) transmission, distribution, and general plant costs, (c) nuclear fuel inventory cost for first core; and (d) total estimated cost. Also, provide the cost estimates in terms of total costs instead of as costs per kilowatt electric.
Response
Using the format presented in 10 CFR Part 50, Appendix C, I.A. 1 in conjunction with the information previously provided in COLA Part 1, the estimate of construction costs are provided as follows:
(a) Total nuclear production plant costs (Nuclear Island and Turbine Island)
(b) Transmission, distribution, and General plant costs (Balance of Plant, Circulating Water Cooling System, Site Preparation, Transmission, and Contingency)
(c) Nuclear fuel inventory cost for first core
(d) Total estimated cost
Cost per kilowatt electric
$5.6 to 7.2 billion
* Using 1535kWe as the net estimated electrical power output (DCD Rev. 6, Section 1.1.2.7)
Proposed COLA Revision
Attachment 3 NRC3-09-0028
Response to RAI Question No. 09.05.04-1 (eRAI Tracking No. 3523)
Attachment 3 to NRC3-09-0028 Page 2
NRC RAI 09.05.04-1
In response to COL Item EF3 COL 9.5.4-2-A (included twice- once for the standby diesel generators and once for the ancillary diesel generators), the Fermi 3 FSAR describes the corrosion protection providedfor the undergroundfuel oil system piping. The description in the FSAR should also include the applicable codes and/or standards for the corrosion protectionfeatures. (Note that a similar supplemental RAI was submitted for the North Anna 3 RCOLA and Dominion submitted a response on August 3, 2009)
Response
The FSAR will be revised to replace "appropriate margins" with examples of areas requiring calculated storage volume margin in FSAR Section 9.5.4.2, which is consistent with the North Anna 3 RCOLA response to RAI Question 09.05.04-7 for FSAR Section 9.5.4.2.
Proposed COLA Revision
FSAR Section 9.5.4.2 will be revised in a future revision as shown in the attached markup.
Attachment 3 to NRC3-09-0028 Page 3
Markup of Detroit Edison COLA (following 2 pages)
The following markup represents how Detroit Edison intends to reflect this RAI response in the next appropriate update of the Fermi 3 COLA. However, the same COLA content may be impacted by revisions to the ESBWR DCD, responses to other COLA RAI's, other COLA changes, plant design changes, editorial or typographical corrections, etc. As a result, the final COLA content that appears in a future submittal may be different than presented here.
Fermi 3 Combined License Application
Part 2: Final Safety Analysis Report
EF3 COL 9.5.2.5-2-A
EF3 COL 9.5.2.5-3-A
EF3 COL 9.5.2.5-4-A
EF3 COL 9.5.2.5-5-A
9.5.2.5-2-A Grid Transmission Operator
This COL item is addressed in Subsection 9.5.2.2. and Emergency Plan
Section II.F.1.
9.5.2.5-3-A Offsite Interfaces (1)
This COL item is addressed in Subsection 9.5.2.2 and Emergency Plan Sections II.E.1 and 1I.F.1.
9.5.2.5-4-A Offsite Interfaces (2)
This COL item is addressed in Subsection 9.5.2.2 and Emergency Plan
Sections II.E.1 and Il.F.1.
This COL item is addressed in Subsection 9.5.2.2.
9.5.3 Lighting System
This section of the referenced DCD is incorporated by reference with no departures or supplements.
9.5.4 Diesel Generator Fuel Oil Storage and Transfer System
This section of the referenced DCD is incorporated by reference with the
following departures and/or supplements.
9.5.4.2 System Description
Detailed System Description
Standby Diesel Generators
Replace the third to last sentence in the first paragraph with the following.
STD COL
in the tank, level instrume and the potential for future
9.5.4-1 -A Procedures require that the quantity of diesel fuel oil in the standby diesel generator (SDG) fuel oil storage tanks- is monitored on a periodic basis. The diesel fuel oil usage is tracked against planned deliveries. Regular
transport replenishes the diesel fuel oil inventory during periods of high for usable fuel demand and ensures continued supply in the event of adverse weather nt uncertainty, conditions. These procedures ensure sufficient diesel fuel oil inventory is
load growth available on site so that the SDGs can operate continually for seven days with each operating at its calculated design load, with ,pitc dc- ,OR
, a . The procedures will be developed in accordance with the milestone and processes described in Section 13.5.
9-36 Revision 1 March 2009
Fermi 3 Combined License Application
Part 2: Final Safety Analysis Report
Replace the third paragraph with the following.
EF3 COL 9.5.4-2-A The only underground component of the SDGs fuel oil storage and
transfer system is carbon steel piping. A corrosion protection system is
provided for external surfaces of buried piping systems. The buried
sections of the piping are provided with waterproof protective coating and
an impressed current type cathodic protection to control external
corrosion.
STD COL 9.5.4-1-A Delete the parenthetical "(COL 9.5.4-1-A)" at the end of the last
paragraph.
Ancillary Diesel Generators
Replace the third to last sentence in the first paragraph with the following.
STD CC
margin added to accou in the tank, level instrul and the potential for fut
)L 9.5.4-1-A Procedures require that the quantity of diesel fuel in the ancillary diesel
generator (ADG) fuel oil storage tanks is monitored on a periodic basis.
The diesel fuel oil usage is tracked against planned deliveries. Regular
transport replenishes the fuel oil inventory during periods of high demand
nt for usable fuel and ensures continued supply in the event of adverse weather ment uncertainty, conditions. These procedures ensure sufficient diesel fuel oil inventory is :ure load growth available on site so that the ADGs can operate continually for seven days
its calculated design load, with a •-1,"t~e4e. The
procedures will be developed in accordance with the milestone and
processes described in Section 13.5.
EF3 COL 9.5.4-2-A
Replace the third paragraph with the following.
The only underground component of the ADGs fuel oil storage and transfer system is carbon steel piping. A corrosion protection system is
provided for external surfaces of buried piping systems. The buried sections of the piping are provided with waterproof protective coating and an impressed current type cathodic protection to control external
corrosion.
I