ML20196F570

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Forwards RAI Re Licensee 980403 Amend Request to Convert to Improved Std TSs for Fermi 2.Mutually Agreeable Completion Schedule of 45 Days for Response Was Established
ML20196F570
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 11/20/1998
From: Kugler A
NRC (Affiliation Not Assigned)
To: Gipson D
DETROIT EDISON CO.
References
TAC-MA1465, NUDOCS 9812070072
Download: ML20196F570 (4)


Text

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T l

November 20, 1998

Mr. Douglas R. Gipson Senior Vice President Nuclear Generation l

Detroit Edison Company j

l 6400 North Dixie Highway  ;

Newport, Michigan 48166 i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTION 3.7 FOR i

! l FERMI 2 (TAC NO. MA1465) l

Dear Mr. Gipson:

i On April 3,1998, the Detroit Edison Company (DECO) submitted an amendment request to l

convert to the improved standard technical specifications for Fermi 2. By a letter dated i September 28,1998, DECO provided a supplement to the original submittal. The staff has I reviewed Section 3.7 of the proposed conversion. Additionalinformation, as discussed in the j enclosure, is requested in order for the staff to complete its review.

The enclosed request was discussed with Mr. G. Ohlemacher of your staff on November 9, 1998. A mutually agreeable completion schedule of 45 days for your response was

, established. If circumstances result in the need to revise the schedt le, please call me at the ,

! earliest opportunity.

)

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

l Sincerely, ORIG. SIGNED BY l Andrew J. Kugler, Project Manager  !

Project Directorate 111-1 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

As stated cc w/ encl: See next page t

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Mr. Douglas R. Gipson Fermi 2 Detroit Edison Company cc:

John Flynn, Esquire SeniorAttomey Detroit Edison Company

-2000 Second Avenue Detroit, Michigan 48226 Drinking Water an'j 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 Rerident 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 North Dixie Highway Nev, port, Michigan 48166 t

l 4 August 1997

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTION 3.7 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. Refer to RAI 0.0-1 in the October 26,1998, RAl. Additional DOCS affected by this issue are listed in the following table:

ITS LA DOC 3.7.2 LA.1 3.7.2 LA.4 3.7.3 LA.1 3.7.4 LA.2 3.7.5 LA.1 3.7.6 LA.1 3.7.6 LA.3 3.7.7 LA.2 Section 3.7 RAI 3.7-1: There appears to be an inconsistency in the Bases for ITS 3.7.1. The background section indicate:: that each residual heat removal service water (RHRSW) subsystem has a nominal flow capacity of 9000 gpm. The applicable safety analysis section indicates that the RHRSW flow assumed in the accident analyses is initially 9000 gpm. Finally, the [ limiting condition for operation) LCO section indicates, in part, that an RHRSW subsystem is operable with flow greater than 8250 gpm. Explain or resolve this apparent inconsistency.

RAI 3.7-2: The STS markup and ITS Bases for TS 3.7.1, the bases for Action D.1 mentions the completion time for the re sidual heat removal system suppression pool spray function.

However, in its conversio.i the licensee removed this function from the TS. This reference to the completion time should be removed.

ENCLOSURE

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l RAI 3.7-3: ITS surveillance requirement (SR) 3.7.2.1 for the ultimate heat sink (UHS) verifies i "the water level of each UHS reservoir, and the average water level of each of the two  !

reservoirs, . " Are those the same thing or is the second requirement intended to measure the average level of the two together? If the latter is what is intended, it is unclear because of the use of the phrase "of each of the two.. ." From a UHS volume standpoint that latter interpretation is acceptable and consistent with the Bases statement that "If either reservoir does not meet the water level requirement, verification of the UHS combined volume is required." However, from the standpoint of the net positive suction head and pump vortexing discussed in the Bases, an average levelis not an appropriate measurement (there is either acceptable actuallevelin each reservoir to prevent vortexing/ loss of head or not). Clarify what average measurement is to be made and the intent of using an average level measurement in the SR and the Bases.

RAI 3.7-4: In the background section of the iTS 3.7.2 Bases for the emergency equipment cooling water (EECW) system, in the second paragraph, it indicates that EECW initiates, among other things, on a loss-of-coolant accident (LOCA) signal. This is only partially correct.

One of the EECW initiation signals is high drywell pressure, which is also a LOCA signal.

However, there are other LOCA signals that do not initiate the EECW system, most notably low-low reactor vessel water level. This Bases statement should be clarified. l RAI 3.7-5: The Bases for ITS SR 3.7.3.2 state the SR verifies that the control room emergency filtration (CREF) system filter tests are performed in accordance with the Ventilation Filter i Testing Program (VFTP) which is maintained in the Administrative Controls section of the ITS.

The next sentence indicates that the CREF system filter tests are performed in accordance with j Regulatory Guide 1.52 and/or the unit current licensing basis. The second sentence is extraneous and could cause confusion concerning the differences between the first and second sentences. The VFTP provides details concerning the filter tests that are performed. Remove or modify the second sentence.