The Detroit Edison Company One Energy Plaza, Detroit,

The Detroit Edison CompanyOne Energy Plaza, Detroit, MI 48226-1279

10CFR 52.79

September 29, 2009NRC3-09-0028

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001

References: 1) Fermi 3Docket 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 Sections01, 9.5.4, and 14.3 for the Fermi 3 Combined License Application," datedSeptember 2, 2009

Subject: Detroit Edison Company Response to NRC Request for Additional InformationLetter No. 12

In the referenced letter, the NRC requested additional information to support the review ofcertain portions of the Fermi 3 Combined License Application (COLA). The responses to thefollowing Requests for Additional Information (RAIs) are provided as Attachments 1 through 3of this letter:

* RAI Question 14.03-1

* RAI Question 01-3

* RAI Question 09.05.04-1

Schedule for DAC ITAAC Closure

Construction Costs

Emergency Diesel Engine Fuel Storage

Information contained in these responses will be incorporated into a future COLA submission asdescribed in the RAI response.

A DTE Energy Company 95

USNRCNRC3-09-0028Page 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 ofSeptember, 2009.

Sincerely,

Peter W. Smith, DirectorNuclear Development - Licensing & EngineeringDetroit Edison Company

Attachments: 1) Response to RAI Question No. 14.03-12) Response to RAI Question No. 01-33) Response to RAI Question No. 09.05.04-1

cc: Mark Tonacci, NRC Fermi 3 Project ManagerStephen Lemont, NRC Fermi 3 Environmental Project ManagerFermi 2 Resident InspectorNRC Region III Regional AdministratorNRC Region II Regional AdministratorSupervisor, Electric Operators, Michigan Public Service CommissionMichigan Department of Environmental Quality

Radiological Protection and Medical Waste Section

Attachment 1NRC3-09-0028Page 1

Attachment 1NRC3-09-0028

Response to RAI Question No. 14.03-1(eRAI Tracking No. 3390)

Attachment 1 toNRC3-09-0028Page 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 aschedule for Design Acceptance Criteria (DAC) ITAAC Closure. DTE responded that this COL Item isaddressed in Appendix 14.3A.1. In Section Appendix 14.3A. 1 DTE committed that, "Fermi 3 is scheduled tobe licensed subsequent to the reference ESB WR Plant, will use the standard approach, and the DA C 1TAA Ccompletion for the first standard plant will be used [COM14. 3A. 1-001]. The first standard plant, NorthAnna Unit 3, R-COLA, Section 14.3A.1, stated a DAC 1TAAC closure schedule would be provided within oneyear after ESB WR design certification. The staff reviewfound that, for the first standard plant, for selecteddesign acceptance criteria (DAC), a closure schedule provided within 1 year would not support the NRC'sneed 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 scheduleconcerns to industry and stated that there were unique needs associated with closing out DACfor (1) pipingdesign, (2) human factors engineering, and (3) digital instrumentation and controls. At subsequent ESB WRDCWG public meetings, the staff and industry discussed the resolution of this DAC closure schedule issue. Atthe public meeting on April 1, 2009, the industry proposed resolutions for the piping design and humanfactors engineering that the staff determined to be acceptable. For piping DA C, the NRC staff will be notifiedat least 6 months before (1) scheduled completion of all ASME Code design reports for risk-significant pipingpackages, and (2) scheduled completion of all the pipe-break hazard analyses. For human factorsengineering DAC, the NRC will be notified at least 6 months before the scheduled completion of each resultssummary report. At the public meeting on May 14, 2009, the industry proposed a resolution for digitalinstrumentation and controls that the staff determined to be acceptable. For instrumentation and controlsDAC, the NRC staff will be notified at least 6 months before the scheduled completion of each baseline reviewreport and software plan designated as DAC. The R-COL applicant agreed to incorporate the acceptableresolutions for the DAC closure schedule to address COL 14.3A-1-1 in the next revision to the NAPS-3COLA.

The NRC Staffrequest the commitment COM14.3A.1-001 be revised to either incorporate the acceptableresolutions 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. FermiUnit 3 will use the standard approach as described in the ESBWR DCD Section 14.3A for DesignAcceptance Criteria (DAC) closure, i.e., resolution through DAC ITAAC after COL issuance. TheDAC ITAAC completion for the first standard plant will be used under the "one issue approach forDAC ITAAC closure. As a subsequent COL applicant, Fermi Unit 3 will reference the firststandard ESBWR plant Licensing Topical Reports (LTRs) and NRC closure documents for DACITAAC closure.


If, at the time of COL issuance, Fermi Unit 3 is the reference ESBWR plant, the standard approachwill 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) scheduledcompletion 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 thescheduled completion of each results summary report.

* For instrumentation and controls DAC, the NRC staff will be notified at least 6 monthsbefore the scheduled completion of each baseline review report and software plandesignated as DAC.

Proposed COLA Revision

FSAR Section 14.3A. I will be revised in a future submittal as shown in the attachedmarkup.


Markup of Detroit Edison COLA(following 2 pages)

The following markup represents how Detroit Edison intends to reflect this RAI response in thenext appropriate update of the Fermi 3 COLA. However, the same COLA content may be impactedby revisions to the ESBWR DCD, responses to other COLA RAI's, other COLA changes, plantdesign changes, editorial or typographical corrections, etc. As a result, the final COLA content thatappears in a future submittal may be different than presented here.

Fermi 3Combined 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. ISTD 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.

14.3.10 COL InformationI

I

STD COL 14.3-1-A

STD COL 14.3-2-A

14.3-1-A Emergency Planning ITAAC

This COL item is addressed in Section 14.3.8.

14.3-2-A Site-Specific ITAAC

This COL item is addressed in Section 14.3.9.

Appendix 14.3A Design Acceptance Criteria ITAAC ClosureProcess

This section of the referenced DCD is incorporated by reference with thefollowing 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 IEF3 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 eQ~@; TA A ee.. 1__ 1-thI.--I'll . . .

plant will b. e;zd. [END COM 14.3A.1-001]S;@R9RF9

14-7 Revision 1March 2009

Insert 1

[START COM 14.3A.1-001] If, at the time of COL issuance, Fermi Unit 3 is the referenceESBWR plant, the standard approach will be used and the following DAC closure notificationswill be made:

. For piping DAC, the NRC staff will be notified at least 6 months before (1) scheduledcompletion 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 beforethe scheduled completion of each results summary report.

For instrumentation and controls DAC, the NRC staff will be notified at least 6 monthsbefore the scheduled completion of each baseline review report and software plandesignated as DAC. ISTART COM 14.3A.1-001]



Response to RAI Question No. 01-3(eRAI Tracking No. 3486)


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 productionplant costs, (b) transmission, distribution, and general plant costs, (c) nuclear fuel inventory cost for firstcore; and (d) total estimated cost. Also, provide the cost estimates in terms of total costs instead of as costs perkilowatt electric.

Response

Using the format presented in 10 CFR Part 50, Appendix C, I.A. 1 in conjunction with theinformation previously provided in COLA Part 1, the estimate of construction costs are provided asfollows:

(a) Total nuclear production plant costs(Nuclear Island and Turbine Island)

(b) Transmission, distribution, andGeneral plant costs (Balance of Plant,Circulating Water Cooling System,Site Preparation, Transmission,and Contingency)

(c) Nuclear fuel inventory costfor first core

(d) Total estimated cost

Cost per kilowatt electric

$2,500 to 3,000/kWe

$1,000 to 1,500/kWe

$306 million

$3,500 to 4,500/kWe

Total Costs*

$3.8 to 4.6 billion

$1.5 to 2.3 billion

$0.3 billion

$5.6 to 7.2 billion

* Using 1535kWe as the net estimated electrical power output (DCD Rev. 6, Section 1.1.2.7)


None



Response to RAI Question No. 09.05.04-1(eRAI Tracking No. 3523)


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 andonce for the ancillary diesel generators), the Fermi 3 FSAR describes the corrosion protection providedforthe undergroundfuel oil system piping. The description in the FSAR should also include the applicable codesand/or standards for the corrosion protectionfeatures. (Note that a similar supplemental RAI was submittedfor 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 requiringcalculated storage volume margin in FSAR Section 9.5.4.2, which is consistent with the North Anna3 RCOLA response to RAI Question 09.05.04-7 for FSAR Section 9.5.4.2.


FSAR Section 9.5.4.2 will be revised in a future revision as shown in the attachedmarkup.


Markup of Detroit Edison COLA(following 2 pages)

The following markup represents how Detroit Edison intends to reflect this RAI response in thenext appropriate update of the Fermi 3 COLA. However, the same COLA content may be impactedby revisions to the ESBWR DCD, responses to other COLA RAI's, other COLA changes, plantdesign changes, editorial or typographical corrections, etc. As a result, the final COLA content thatappears in a future submittal may be different than presented here.



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 PlanSections 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.

9.5.2.5-5-A Fire Brigade Radio System

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 nodepartures 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

margin added to account 1

in the tank, level instrumeand the potential for future

9.5.4-1 -A Procedures require that the quantity of diesel fuel oil in the standby dieselgenerator (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 highfor usable fuel demand and ensures continued supply in the event of adverse weathernt uncertainty, conditions. These procedures ensure sufficient diesel fuel oil inventory is

load growthavailable on site so that the SDGs can operate continually for seven dayswith each operating at its calculated design load, with ,pitc dc- ,OR

, a . The procedures will be developed in accordance with themilestone and processes described in Section 13.5.




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 accouin the tank, level instruland 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 weatherment 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 andtransfer system is carbon steel piping. A corrosion protection system is

provided for external surfaces of buried piping systems. The buriedsections of the piping are provided with waterproof protective coating andan impressed current type cathodic protection to control external

corrosion.

I


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