ML20155B719

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Forwards RAI Re Conversion to Improved STSs for Plant,In Order to Complete Review of Util 980403 Amend Request
ML20155B719
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/26/1998
From: Kugler A
NRC (Affiliation Not Assigned)
To: Gipson D
DETROIT EDISON CO.
References
TAC-MA1465, NUDOCS 9810300245
Download: ML20155B719 (6)


Text

I 3 . October 26, 1998 (

Mr. Dougl s R. Gipson Ssnior Vice Prssid:nt Nuclear Generation Detroit Edison Company 6400 North Dixie Highway Newport, Michigan 48166

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR FERMI 2 (TAC NO. MA1465)

Dear Mr. Gipson:

On April 3,1998, the Detroit Edison Company (DECO) submitted an amendment request to convert to the improved standard technical specifications for Fermi 2. By a letter dated September 28,1998, DECO provided a supplement to the original submittal. The staff has reviewed Sections 1.0,2.0,3.0,3.1,3.2,3.10,4.0, and 5.0 of the proposed conversion. The staff does not have any questions related to Sections 1.0 and 2.0. However, additional information. as discussed in the enclosure, is requested for Sections 3.0, 3.1, 3.2, 3.10, 4.0, and 5.0 in order for the staff to complete its review.

The enclosed request was discussed with Mr. G. Ohlemacher of your staff on October 8 and 16, 1998. A mutually agreeable completion schedule of 45 days for your response was established.

If circumstances result in the need to revise the schedule, please call me at the earliest opportunity.

If you should have any questions regarding this request, please contact me at 301-415 2828.

Sincerely, ORIGINAL SIGNED BY Andrew J. Kugler, Project Manager Project Directorate lil-1 Division of Reactor Projects -lilllV Office of Nuclear Reactor Regulation Docket No. 50 341

Enclosure:

As stated cc w/enci: See next page DlSTRIBUTION:

Docket File PD3-1 RF PUBLIC BBurgess, Rill (BLB)

OGC EAdensam (EGA1) 7ep y g o w w p p.ggy ACRS JFoster j % e 8 d a O d 2 5 u ,1 bug >g g AChu TLiu TTjader JZwolinski DOCUMENT NAME: G:\WPDOCS\ FERMI \FE-STS02.RAI k m.cev. . coo, or o ;peum.at inoice. in m. oo e . cev .w .n-wieu. e . cev .* mcm.noeu. v . No con OFFICE PM:PD31 E LA:PD31 . E D:PD31 b NAME AKugler:db GA CJamerson & CACarpenter ($L DATE 10/ 2,3/98 L 10/ 23 /98 d 10/ 6 /98 OFFICIAL RECORD COPY g 9810300245 981026' i PDR ADOCK 05000341 "

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k Mr. Douglas R. Gipson Fermi 2 Detroit Edison Company f

cc:

John Flynn, Esquire SeniorAttomey Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological  :

, Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway

-Newport, Michigan 48166 Monroe County Emergency Management Division 963 South Raisinville Monroe, Michigan 48161 Regional Administrator, Region lli <

' U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 \

Norman K. Peterson Director, Nuclear Licensing Detroit Edison Company Fermi 2 - 280 TAC 6400 Nort.% Dixie Highway Newport, Michigan 48166 August 1997 I

,iJa. . _

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR FERMI 2 (TAC NO. MA1465)

General Note: Throughout this request for additional information (RAI), references to a standard technical specification (STS) mean the standard version of the TS published by the NRC in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4,"

Revision 1. References to an improved TS (ITS) mean the proposed converted TS submitted by the licensee.

All Sections RAI 0.0-1: There is a generic issue involving a number of the Less Restrictive Administrative (LA) discussions of change (DOCS)in the Fermi submittal. In a number of cases the licensee essentially stated that items "can be relocated" to the Bases or the Technical Requirements Manual. But the DOCS didn't actually state that the information was relocated there. These DOCS should be revised to explicitly state the location to which the information is moved. The following table lists those LA DOCS that the staff identified with this problem:

ITS LA DOC 3.1.2 LA.1 3.1.5 LA.1 3.2.2 LA.1 3.2.3 LA.1 5.4 LA.1 5.4 LA.3 5.5 LA.1 5.5 LA.3 5.5 LA.5 5.5 LA.8 5.5 LA.9 The licensee should also perform a general review of LA DOCS looking for this problem. Future RAls will include a table similar to that above and refer back to this RAl.

In addition, in some cases LA DOCS are used where the requirement that is being " relocated" already exists in some other controlled document or program. The definition of the LA DOC should be revised and expanded to explain this type of case.

ENCLOSURE

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Section 3.0 RAI 3.01: Insert 3.0-4 into the current technical specification (CTS) markup for CTS 3.0.4 contains wording that is different from the STS 3.0.4 markup (also referred to as the NUREG markup) and the propo. sed ITS 3.0.4. Resolve this difference.

Sections 3.1 and 3.2 RAI 3.1-1: STS surveillance requirements (SRs) 3.1.1.1 and 3.1.2.1 frequency states, in part, l "

. . after criticality following fuel movement within the reactor pressure vessel or control rod l replacement." The ITS versions of these SRs delete the words "or control rod replacement."

The licensee indicated that control rod replacement always entails removing fuel and that the l deleted words are unnecessary. Reference justification for difference (JFD) P.4 in STS 3.1.1 '

l and JFD P.S in STS 3.1.2. The licensee should submit a generic change request in relation to this change.

l RAl 3.1-2: In the ITS Bases, references to NEDE-24011-P-A, " General Electric Standard l Application For Reactor Fuel," (Reference 3 in ITS B3.1.1, Reference 1 in ITS B3.1.6, l Reference 3 in ITS B3.2.3, and Reference 1 in ITS B3.10.7) delete the specific date at the end i I

and replace it with "(latest approved version)." However, a TS reference must include the l specific date of an approved version of the reference and cannot automatically change with the )

latest update to it. To allow automatic reference updates could involve unauthorized and unacceptable changes to the TS. Therefore, wherever the STS Bases includes a specific revision or revision date, the ITS should use a similar format.

l RAI 3.13: STS 3.1.3,3.1.6, and 3.10.8 refer to the banked position withdrawal sequence (BPWS) in ITS 3.1.3,3.1.6. and 3.10.7, BPWS is replaced with the more general phrase

" prescribed withdrawal sequence." The Bases for ITS 3.1.6 provide an adequate explanation of the term " prescribed withdrawal sequence." However, the Bases for ITS 3.1.3 and 3.10.7 do not

. adequately define this term. These Bases should be revised to more clearly define what is meant by " prescribed withdrawal sequence."

RAI 3.1-4: The new scram time methodology presented in STS 3.1.4 has been adopted.

However, DOC M.3 does not discuss the applicability of $.he new methodology to Fermi 2. The DOC should be revised.

RAI 3.1-5: The SR 3.1.4.1 frequency has been changed from "2120 days"in the STS, to i

">120 days" in the ITS, with a reference to JFD P.1. However, P.1 says "Not Used." Provide the appropriate justification RAI 3.1-6: STS SR 3.1.8.2, the quarterly cycling of the scram discharge volume vent and drain l valves, has not been incorporated into the ITS. Explain the justification for not adopting this SR l

including, if appropriate, other programs that already requi.e testing these valves (e.g., inservice l testing).

l RAI 3.21: See RAI 3.1-2.

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r l Section 3.10 RAI 3.10-1: The STS 3.10.4 Bases change (JFD P.7) in the section for the limiting condition for operation (LCO) appears to be a generic change. Prepare and submit a generic change request or explain why a generic change request is not appropriate.

RAI 3.10-2: ITS 3.10.6 does not include the following from the STS:

1. LCO condition c, requiring fuel assemblies to be loaded in compliance with an approved sequence, 1 2. Required Action A.2, to suspend loading fuel, and )
3. SR 3.10.6.3, to verify that fuel assemblies are being loaded in compliance with an approved sequence.

l These requirements exist to limit reactivity additions. Provide additional justification for not i including these or similar requirements in the ITS.

I RAI 3.10 3: See RAI 3.1-3.

RAI 3.10-4: See RAI 3.12.

Section 4.0 l RAI 4.0-1: CTS 5.6 does not include any requirements related to the storage of fuel in the new

! fuel storage racks. The CTS markup does not indicate the addition of new requirements related to the new fuel storage racks. However, the STS 4.3.1 markup indicates that STS 4.3.1.2 for l fuel storage in the new fuel storage racks will be incorporated. ITS 4.3.1 does not include these j requirements. Determine whether the new requirements will be added and make the appropriate changes to the submittal.

Section 5.0 RAI 5.0-1: DOC A.3 to CTS 6.2.2.c (ITS 5.2) ends by indicating that references to health physics is revised to radiation protection. There is no specific reference to where those changes are made (i.e., CTS 6.2.1.c and 6.8.6). For clarity, specific references should be added.

l RAI 5.0 2: The " Safety Function Determination Program" (STS 5.5.12, ITS 5.5.11) is added to the Programs and Manuals section of the TS in the conversion. The staff considers this change to be an addition and DOC A.9 refers to it as a new program. On this basis, it does not appear l

that the use of an A-type DOC (administrative)is appropriate. The addition of a program appears to be more restrictive. Revise the DOC to address this.

RAI 5.0-3: DOC LR.1 to CTS 6.5.1.5.c and d discusses the removal of reporting requirements from the TS. However, the last sentence in this DOC uses the term relocation. Resolve this inconsistency.

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4 RAI 5.0-4: DOC LR.1 to CTS 6.5.1.5.c and d states, in part:

These reports involve no regulatory authority or approval.

This statement is not exactly correct in the sense that 10 CFR 50.73(a) provides requirements for the licensee to submit a licensee event report (LER) for fuel cladding failures that exceed expected values. The LER would provide the same information that is required by

CTS 6.5.1.5.c. Because there is already a regulatory provision in place, the reporting requirements are not needed in the ITS. Revise the submittal to reflect the regulatory supporting documentation as mentioned above.