ML20198B874

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Forwards RAI Re 980403 Amend Request to Convert Improved Std TSs Sections 3.4 & 3.9.Completion Schedule of 60 Days for Response Established Per Discussion with G Ohlemacher on 981109 & 10
ML20198B874
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 12/04/1998
From: Kugler A
NRC (Affiliation Not Assigned)
To: Gipson D
DETROIT EDISON CO.
References
TAC-MA1465, NUDOCS 9812210209
Download: ML20198B874 (12)


Text

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l .. . Mr. Douglis R. Gipson December 4, 1998 I

Senior Vice Pr:sid:nt l

Nuclear Generation

Detroit Edison Company 6400 North Dixie Highway Newport, Michigan 48166

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTIONS 3.4 AND 3.9 FOR FERMI 2 (TAC NO. MA1465) l

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 3.4 and 3.9 of the proposed conversion. Additionalinformation, as i discussed in the enclosure, is requested in order for the staff to complete its review.

l The enclosed request was discussed with Mr. G. Ohlemacher of your staff on November 0 and 10,1998. A mutually agreeable completion schedule of 60 days for your response was established. If circumstances result in the need to revise the schedule, please call me at th'eearliest opportunity. Note that the format and text of the questions differs from l the version discussed at the meeting. The enclosure reflects the questions as prepared by the section lead reviewer.

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 -lil/IV Docket No. 50-341

Enclosure:

As stated I cc w/ encl: See next page DISTRIBUTION Docket File PD3-1 RF AVegel, Rill (AXV)

PUBLIC _ OGC ACRS EAdensam (EGA1)

JZwolinski MWeston JFoster DOCUMENT NAME: G:\PD3-1\WPDOCS\ FERMI \FE-STSO4.RAI To receive a copy of th a document, indicate in the t>on *C"

  • Copy without attachmr.t/ enclosure "P a Copy with attachment / enclosure "N" = No copy l OFFICE PM:PD31 E LA:PD31 , E D;PD31 l IJ NAME AKugler:db Qg4 CJamerson Q / CACarpenter CM-.

t1 -/ I /98 /

DATE lE / l /98 V \2 / 4- /98

_,,,co OFFICIAL REC @D COPY 9812210209 981204 PDR ADOCK 05000341

1. u

.. . Mr. Douglas R. Gipson December 4, 1998 '

  • S:nior Vice Presid:;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, SECTIONS 3.4 AND 3.9 FOR FERMI 2 (TAC NO. MA14BS)

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 3.4 and 3.9 of the proposed conversion. Additionalinformation, as discussed in the 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 and 10,1998. A mutually agreeable completion schedule of 60 days for your response was established. If circumstances result in the need to revise the schedule, please call me at the earliest opportunity. Note that the format and text of the questions differs from the version discussed at the meeting. The enclosure reflects the questions as prepared by the section lead reviewer.

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

Enclosure:

As stated cc w/ encl: See next page DISTRIBUTION: Docket File PD3-1 RF AVegel, Rill (AXV)

PUBLIC OGC ACRS EAdensam (EGA1)

JZwolinski MWeston JFoster j DOCUMENT NAME: G:\PD3-1\WPDOCS\ FERMI \FE-STS04.RAI l To receive e copy of this document, indicate in the non c . copy without ottachment/ enclosure "E" = Copy wtm ettachment/ enclosure "N"

  • No copy l OFFICE PM:PD31 lE LA:PD31 r E D:PD31 l LJ NAME AKugler:db Q$, CJamerson Q/ CACarpenter C(6 DATE lt / l /98 V 12 / l /98 / 12 / 4. /98 OFFICIAL REC (TRD COPY

. - . . _ . - _ . . . - - . . _ . ~ ~ . ~ . . . _ . - . . . . . . . . - . - . . . . - -.. ..

.. pm At! i g \ UNITED STATES i

. j 2

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 3000H001 k,

...../ December 4, 1998 l '

Mr. Douglas R. Gipson Senior Vice President l Nuclear Generation l Detroit Edison Company 6400 North Dixie Highway Newport, Michigan 48166 l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO l l lMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTIONS 3.4 AND 3.9 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 3.4 and 3.9 of the proposed conversion. Additionalinformation, as discussed in the 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 and 10,1998. A mutually agreeable completion schedule of 60 days for your response was established. If circumstances result in the need to revise the schedule, please call me at the earliest opportunity. Note that the format and text of the questions differs from the version discussed at the meeting. The enclosure reflects the questions as prepared by the section lead reviewer.

If you should have any questions regarding this request, please contact me at 301-415-2d28.

Sincerely, 1

Andrew J. gjer, roject Manager Project Directorate Ill-1 Division of Reactor Projects -lil/lV Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

As stated

! cc w/ encl: See next page i

. - . . . . ~ . . . . . . _ . - - - . - _ . . . - - - . .. .. . ..

t .

1-1 .

Mr. Douglas R. Gipson Fermi 2 l Detroit Edison Company I

cc:

L John Flynn, Esquire Senior Attorney Detroit Edison Company 2000 Second Avenue l _ Detroit, Michigan 48226 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality l 3423 N. Martin Luther King Jr Blvd -

P. O. Box 30630 CPH Mailroom Lansing, Michigan 4E309-8130 i U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Monroe County Emergency Management l

Division 963 South Raisinville '

l Monroe, Michigan 48161 Regional Administrator, Region ill U.S. Nuc! ear Ftsgulatory 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 Newport, Michigan 48166 t

August 1997 l

._ . _. _ _ . .. _ .._. ~ . _ __ . _ . _ _ _ . __ _._

I

! REQUEST FOR ADDITIONAL INFORMATION REGARDING  ;

CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, i SECTIONS 3.4 AND 3.9 FOR FERMI 2 (TAC NO. MA1465) 4 General Note Throughout this request for additior.al 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 i by the licensee. RAI numbers (e.g., RAI 3.4.5-1) refer to the numbers used in the November 9 '

and 10,1998, meeting.

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, request for additional information. Additional DOCS affected by this issue are listed in the following table:

ITS LA DOC  !

3.4.3 LA.2 3.4.6 ' LA.2 3.4.9 LA.2 Section 3.4 Generic flTS 3.4.5. 3.4.8. and 3.4.9)

RAI 3.4-1: DOCS LR.1 for current TS (CTS) 3.4.3.2 (ITS 3.4.5), LR.2 for CTS 4.4.3.2.2.b (ITS 3.4.5), LR.1 for CTS 4.4 9.1.2 (ITS 3.4.8), and LR.1 for CTS 4.4.9.2.3 (ITS 3.4.9) discuss the change in the context of a relocation. However, LR DOCS are supposed to be used for the deletion of information that does not need to be relocated to a licensee-controlled program with regulatory program controls. If these DOCS are meant to be deletions, the use of the term relocation is incorrect. If they are relocations, they should be LA DOCS and they should clearly state the program to which the information is relocated. Revise these DOCS to clearly state the disposition of the affected information.

ITS 3.4.1

1. RAI 3.4-2: Because of the many changes from the STS and the CTS, this specification is considered beyond scope and will be reviewed by the technical staff. No comments are provided.

ENCLOSURE

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d j ... . ... ._ _ _ .

No comments.

ITS 3.4.3

2. RAI 3.4-3: CTS 3.4.2.1 Action c provides Action requ'rements for inoperable safety relief valve (SRV) position indicators and CTS 4.4.2.1.1 specifies surveillance requirements for SRV valve position indicators. These are not contained in ITS 3.4.3. DOC LA.2 justification states that the position indicators do not impact Operability of the SRVs but CTS 3.4.2.1 Action c and CTS 4.4.2.1.1 had valid justification for their inclusion in the CTS such that COLD SHUTDOWN is required if one or more position indicators can not be restored to OPERABLE status within the given time frame. Pocsibly the reason for CTS 3.4.2.1 Action c, and CTS 4.4.2.1.1 Surveillance is to support CTS 3.4.2.1 Action  :

b which has been eliminated from the ITS. The justification for deleting CTS 3.4.2.1 Action c and CTS 4.4.2.1.1 Surveillance from ITS 3.4.4 that counters the reason why j SRV position indicator requirements were previously included in CTS 3.4.2.1, has not been addressed by DOC LA.2. Provide additionaljustification for removing SRV position indicator requirements from ITS 3.4.3 that counters the reason why they were included in the CTS and are no longer required in the ITS.

In addition, see RAI 0.0-1 for an issue related to DOC LA.2.

ITS 3.4.4

3. RAI 3.4-4: CTS 3.4.3.2.c and CTS 3.4.3.2.e specify limits on reactor coolant system  !

(RCS) leakage "within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period." ITS 3.4.4.c and ITS 3.4.4.d change the l wording for this limiting condition for operation (LCO) to "within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period" which is consistent with the STS. However, there is no DOC addressing this wording change. Provide discu1sion and justification for the equivalency of this wording change.

4. RAI 3.4-5: STS 3.4.4 Action B1 requires " Reduce LEAKAGE to within limit in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."

ITS 3.4.3 Action B deletes this requirement per Justification For Difference (JFD) P.S.

JFD P.5 states that when there is an acceptable compensatory action to take (in this case l STS Required Action B.2), the NUREG does not include actions that provide an explicit '

option to restore LCO compliance. This justification in JFD P.5 is in error because STS 3.4.4 Required Action B.1 does exist in the NUREG (STS) but is deleted from the ITS in <

the STS markup. This would be a generic change. Make ITS 3.4.4 Required Actions consistent with the STS.

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5. RAI 3.4-6 & 7: CTS 4.4.3.2.1.a requires monitoring the primary containment atmospheric gaseous radioactivity at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS surveillance requirement (SR) 3.4.4 requires verifying RCS leakage is within limits each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change to the frequency of monitoring for gaseous radioactivity is justified by DOC L.1. However, the l

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3-l 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> only applies to MODE 1. MODES 2 and 3 are 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Provide discussion and justification for the differences.

ITS 3.4.5

, 6. RAI 3.4-8: ITS SR 3.4.5.1 specifies pressure isolation valve (PlV) leakage limits that are based on valve size. ITS SR 3.4.5.l insert 3.4.5-1 is added to it and provides exceptions l by stating "for PlVs other than LPCI [ low pressure coolant injection] loop A and B injection isolation valves." ITS 3.4.5.1 insert 3.4.5-2 provides these exceptions with specific leakage limits for both the LPCI loop A and B injection isolation valves and the LPCI loop A and B inboard injection isclation testable check valves. Shoulo ITS SR 3.4.5.1 Insert 3.4.5-1 include the LPCI loop A and B inboard injection isolation testable check valves. If so, provide additional wording in insert 3.4.51 that includes the LPCI loop A and B inboard injection isolation testable check valves. Some of these changes appear to be different than the CTS and the STS. Also, SR 3.4.5.1 is not clear, perhaps restructuring might help.

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7. RAI 3.4-9 & 10: With one or more RCS PlVs not within limit, STS 3.4.5 Action A specifies Required Action A.1 as well as Required Action A.2. ITS 3.4.5 Condition A contains Required Action A.1 which is correctly derived from CTS 3.4.3.2 Action c, but STS 3.4.5 Required Action A.2 is deleted including the reference to it in the ITS 3.4,5 NOTE for Required Actions. In addition, the NOTE for STS 3.4.5 Required Actions contains the sentence "and be in the reactor coolant pressure boundary (or the high pressure portion of the system)." This sentence is also deleted from the ITS 3.4.5 Required Action NOTE . The justification for these deletions is shown as JFD P.1 which is fundamentally a generic justification and does not specifically address these deletions.

There is no justif: cation for why the Note should not apply to you. Retain the one or the other of the phrases "and be in the reactor coolant pressure boundary [or the high

. pressure portion of the system]." include an explanation of what "at least one other closed manual...." means in 3.4.3.2 ACTION c. Does this imply two valves. Also, the asterisk refers only to the " Check Valve. Is this the only valve in question here.

8. See generic RAI 3.4-1 for an issue related to DOCS LR.1 and LR.2.
9. RAI 3.4-11: See RAI 3.4-1 for a generic issue related to LR DOCS. In addition, CTS 3.4.3.2 Action d, CTS 4.4.3.2.3, and CTS Table 3.4.3.2-2 contain actions, surveillance details, and a specific list of PlV leakage pressure monitors related to alarm-only functions. DOC LR.1 justification states that the alarm functions do not relate directly to the Operability requirements for the RCS but, CTS 3.4.3.2 Action d had valid justification for inclusion in the CTS such that COLD SHUTDOWN is required if one or more pressure interface valve leakage pressure monitors can not be restored to OPERABLE status within the given time frame. Should this requirement be retained in the instrumentation Section? This question will be referred to the reviewer for Section 3.3.

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10. RAI 3.4-12: CTS 3.4.3.1.a requires the Operability of the primary containment atmosphere gaseous radioactivity monitoring system channel. ITS 3.4.6. b changes the wording of this requirement to one channel of primary containment atmosphere gaseous radioactivity monitoring system. ITS 3.4.6 and its bases do not indicate that this equipment has two channels, rather in most plants it has one channel as identified (gaseous) and the other channelis an " atmospheric particulate monitoring" channel. The reworded term "one channel of" in ITS 3.4.6.b can be misleading giving rise to an error of using the atmospheric par 1iculate channel as the "one channel of". Consider rewording ITS 3.4.6.b consistent with and equal to CTS 3.4.3.1.a.

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11. See generic RAI 0.0-1 for an issue related to DOC LA.2.

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12. RAI 3.4-13: ITS 3.4.6, Condition C, is missing the word " inoperable" at the end of the -

sentence as shown in the STS 3.4.6, Condition C, markup. Correct the wording of  !

ITS 3.4.6, Condition C.

13. RAI 3.4-14: CTS 3.4.3.1 Action requires two leakage detection systems to remain Operable and allows a 30 day restoration time for any individual system inoperability. ITS 3.4.6 Action statements change this requirement to allow unlimited continued operation with either the primary containment atmosphere gaseous radioactivity monitor or drywall floor drain sump level monitoring system inoperable. STS 3.4.6 does not allow this less restrictive requirement and requires restoration within 30 days of any inoperable system even if only one system is inoperable. ITS 3.4.6 Action statements are a less restrictive change that is also a deviation from the STS.

DOC L.1 provides explanation by stating that the primary system for identifying and quantifying unidentified leakage in the containment is the drywell floor drain sump flow monitoring system and thus restoration within 30 days of the other two systems is only required if both of them are inoperable at the same time. This change is not consistent with the ST.S and appears to be a less restrictive Required Action and presentation preference. Provide additional discussion and justification for the less restrictive change and a justification for deviation from the STS. This item is under review by the technical staff as a beyond scope issue.

ITS 3.4.7

14. RAI 3.4-15: CTS Table 4.4.5-1 item 5 requires isotopic Analysis of an off-gas sample including Quantitative Measurements for at least Xe-133, Xe-135 and Kr-88 each 31 days. ITS 3.4.7 does not retain this requirement. DOC A.3 states that deletion of CTS Table 4.4.5-1 item 5 is acceptable because it is the same surveillance requirement as ITS S'R3.7.5.1 and therefore this deletion is an administrative change. This change does i not appear to be administrative because ITS SR 3.7.5.1 requires verification that the

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gross radioactivity rate of noble gases is less than 340 millicuries /second after decay of

30 minuterr These two surveillances do not appear to be the same or equivalent sample l

analyses. Clarify the justification.

15. RAI 3.4-16: CTS 3A.5 Action c requires sdbpiing and analysis br lodine per item 4.b of CTS Table 4.4.5-1 when in Operational Condition 1 or 2 following changt:s in thermal power or off-gas level. ITS 3.4.7 eliminates this requirement. DOC A.2 states Sat the sampling requirements of CTS Table 4.4.51 item 4.a encompasses the requirements of item CTS Tab!9 4.4.5-1 item 4.b and CTS 3.4.5 Action c, because it requires lodine sampling each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when activity exceeds a limit. This justification seems to be in error because the basic lodine sampling requirements, per ITS SR 3.4.7.1, is required only once per 7 days and then it is only required in Mode 1. There is no requirement within the 7-day interval, or during changing power levels, or increasing off-gas levels, to determine it lodine levels are increasin2. The proactive CTS sampling requirement in response to transient precursors such as power changes and increasing off-gas levels is thus eliminated without justification of why they are no longer needed. Provide additional discussion and justification for this less restrictive change.
16. RAI 3.4-17: CTS 3.4.5, Action c, Note
  • states "Not applicable during the startup test program." This note is deleted in ITS 3.4.7 with justification per DOC A.2 However, DOC A.2 doesn't address this d<3letion. Provide discussion and justification for deleting CTS 3.4.5 Action c Note *

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17. RAI 3.4-18: DOC L.1 provides a lengthy justification for deleting CTS LCO 3.4.5.b and its associated Actions and Surveillance Requirements. This involves the 100/E bar microcuries per gram limit and translates into deleting the sampling requirements of CTS Table 4.4.5-1 item 3 (Radiochemical for E bar determination). DOC L.1 does not address deleting CTS Table 4.4.51 item 1 (Gross Beta and Gamma Activity Determination) although the CTS markup shows DOC L.1 as the justification. While the change appears to be acceptable, provide the discussion and justification for deleting CTS Table 4.4.5-1 item 1.

ITS 3.4.8

18. See generic RAI 3.4-1 for an issue related to DOC LR.1.

ITS 3.4.9

19. RAI 3.4-19: CTS 3.4.9.2 Applicability states " Operational Condition 4 when irradiated fuel is in the reactor veasel and the water level is less than 20 feet 6 inches above the top of the reactor pressure vessel flange". This requirement is eliminated from ITS 3.4.9 Applicability. DOC A.3 provides discussion and justification for deleting the water level requirement but it does not address deleting the phrase "when irradiated fuel is in the t reactor pressure vessel". Provide additional discussion and justification for deleting the l phrase "when irradiated fuel is in the reactor pressure vessel" from ITS 3.4.9 i Applicability. This is a less restrictive change.

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20. See generic RAI 0.0-1 for an issue related to DOC LA.2.
21. See generic RAI 3.41 for an issue related to DOC LR.1.
22. RAI 3.4 20: STS 3.4.10, RCS Pressure and Temperature (P/T) Limits, is written with the actual pressure / temperature limits being specified in the Pressure / Temperature Limits Report (PTLR). ITS 3.4.10 does not use the PTLR to specify limits but does not provide reference to the source that is used (e.g., Figure 3.4.10-1, etc.). Add the appropriate references.
23. RAI 3.4-21: CTS 3.4.1.4.a begins with the conditional phrase "When both loops have 4

been idle" and CTS 3.4.1.4.b begins with the conditional phrase "When only one loop has been idle" These phrases are deleted in the CTS markup and are marked with DOC A.2

for justification. DOC A.2 provides discussion and justification for the combination of
these CTS section requirements being equivalent to ITS SR 3.4.10.4 but does not address deleting these conditional phrases. In addition, ITS SR 3.4.10.4 is more restrictive than CTS 3.4.1.4.a because it applies at all times, not only when both loops have been idle. Provide discussion and justification for deleting the CTS 3.4.1.4.a and CTS 3.4.1.4.b phrases "When both loops have been idle" and "When only one loop has been idle" from ITS SR 3.4.10.4. J
24. RAI 3.4-22: CTS Figure 3.4.1.4-1 and reference to it, is contained within the CTS 3.4.1.4 markup under ITS specification ITS 3.4.10 and are deleted with DOC LR.1 shown as the justification. DOC LR.1 for ITS 3.4.10 addresses deleting this table with reference to
ITS 3.4.1 " Scram" and " Exit" regions. Use of the terms " Scram" and " Exit" regions will j be reviewed under comment #1 for ITS 3.4.1. Although the justification contained in DOC LR.1 is reasonable, the power to flow map (CTS Figure 3.4.1.4-1) should be retained.

4 25. RAI 3.4-23 and RAI 3.4-24: CTS 3.4.6.1 Action requires that when in MODES 1,2, or 3, if any of the CTS 3.4.3.1 limib are exceeded, porform an engineering evaluation to determine tho effects of the out-of limit condition on the structuralintegrity of the RCS and determine that the RCS acceptable for (continued) operation, but the CTS does net );

establish a specific completion time. ITS 3.4.10 Required action A.2 establishes 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to determine that the RCS is acceptable for continued operation when in MODE 1, 2, or 3 and for other than MODE 1,2, or 3, ITS 3.4.10 Required Action C.2 establishes,  !

prior to entering MODE 2 or 3. These changes are justified by the discussions in DOC  !

A.S. These changes are more restrictive and not administrative. I in addition, ITS 3.4.10 Required Actions A.2 and C.2 only require determining that the RCS is acceptable for [ continued] operation. The CTS phrase " perform an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the RCS"is deleted without discussion. This appears to be a less restrictive change.

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. o Provide appropriate discussion and justification (more/less restrictive) for CTS 3.4.6.1 Action requirements changing to ITS 3.4.10 Required Actions A.2 and C.2.

26. RAI 3.4-25: CTS 4.4.6.1.2 specifies being to the right of CTS Figure 3.4.6.1-1 curve C which makes clear the safe area of the criticality limit curve. By implication the same applies (being to the right) to curve A and B although CTS 3.4.6.1 does not explicitly state to the right. ITS 3.4.10, as well as ITS Figure 3.4.10-1 (which is exactly.the same as CTS figum 3.4.6.1-1), and ITS 3.4.10 Bases do not specify anywhere that the safe area relative to curve A, B, or C is to the right. ITS 3.4.10 simply requires maintaining pressure and temperature within limits. The clarification previously contained in the CTS is not carried forth in ITS 3.4.10. Provide clarification in ITS 3.4.10 of the safe area relative to ITS Figure 3.4.10-1 curves A, B, and C.

num:s ITS 3.4.11

27. RAI 3.4-26: CTS 3.4.6.2 requires reactor steam dome pressure "less than" 1045 psig and CTS 3.4.6.2 Action applies with pressure " exceeding" 1045 psig. The CTS Action statement with pressure " equal to" 1045 psig is not specifically addressed in the CTS but CTS 4.4.6.2 surveillance also specifies pressure shall be verified to be "less than" 1045 psig. ITS 3.4.11 LCO and ITS SR 3.4.11.1 require reactor steam dome pressure "less than or equal to" 1045 psig. Adding " equal to" to ITS 3.4.11 LCO and ITS SR 3.4.11.1 is discussed within DOC A.2 as a resolution of a discontinuity within CTS 3.4.6.2 Action presentation. However, adding " equal to"in the ITS LCO and Surveillance is less

. restrictive and not administrative based upon the requirements of CTS 3.4.6.2 LCO and CTS 4.4.6.2. DOC A.2 does not state that the condition of being " equal to" 1045 psig is analyzed within safety bounds as acceptable and CTS 3.4.6.2 LCO and CTS 4.4.6.2 4

imply otherwise. Provide additional discussion and justification for adding " equal to" to ITS 3.4.11 LCO and ITS SR 3.4.11.1 as a less restrictive change.

Section 3.9

] iTS 3.9M

1. RAI 3.91: Bases insert B 3.9.4.-1 indicates that the insert is to clarify detail (see JFD P.6). The actual wording provides exception to the SR. This is a generic change because it is not in the CTS. Use the STS wording or obtain generic approval for the change.

ITS 3.9.5

2. RAI 3.9-25 in the Bases for ITS 3.9.5, the reference to LCO 3.1.2 is deleted. JFD P.4 indicates that LCO 3.1.2 does not contain requirements for control rods. However, SR 3.1.2.1 does referenEe frequency requirements following control rod replacement. Retain the reference.

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3. RAI 3.9-3: In JFD P.5, the licensee indicated that the changes to the Bases for ITS 3.9.5 are consistent with other ITS Bases. The BWR/6 has the same language. Further, the control rods are not a system. Specifications 3.9.1,3.9.2,3.9.3, and 3.9.4 refer to control rods. Any correction should be made consistently.

ITS 3.9.6

4. RAI 3.9-4: Are all of the changes to the first paragraph of the Applicable Safety Analysis justified by P.47 in general, clarify which JFDs apply to which changes in this section l (e.g., does JFD P.2 apply to all of the changes in the latter half of the first paragraph on l STS Bases page B 3.9-20). Should the reference to 23 feet of water in this section be your licensing basis as opposed to the references to 20 feet 6 inches elsewhere?

l ITS 3.9.7 '

5. RAI 3.9-5: The Applicability statements for ITS 3.9.7 and 3.9.8 include a note describing l an exception to the stated applicability. In the STS/ITS, exceptions are addressed directly in the Applicability statement. Relocate the information in the notes into the Applicability statements.

ITS 3.9.8

6. See RAI 3.9-5.

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