ML20198J676

Forwards Request for Addl Info Re Conversion to Improved STS Section 3.8.Response Requested within 60 Days

ML20198J676
Person / Time
Site:	Fermi
Issue date:	12/22/1998
From:	Kugler A NRC (Affiliation Not Assigned)
To:	Gipson D DETROIT EDISON CO.
References
TAC-MA1465, NUDOCS 9812300240
Download: ML20198J676 (13)

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December 22, 1998 i

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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTION 3.8 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. Dy letter dated September 28,1998, DECO provided a supplement to the original submittal. The staff has reviewed Section 3.8 of the proposed conversion. Additional information, as discussed in the i

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 December 4, i

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.

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

l Sincerely, ORIGINAL SIGNED BY Andrew J. Kugler, Project Manager Project Directorate lil-1 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation l

Docket No. 50-341

Enclosure:

As stated cc w/ encl: See next page j

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John Flynn, Esquire Senior Attorney Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality i

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

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Monroe, Michigan 48161 Regional Administrator, Region ill U.S. Nuclear Regulatory Commission 801 Warrenville Raad Lisle, Illinois 60532-4351 Norman K. Peterson Director, Nuclear Licensing Detroit Edison Company Fermi 2 - 280 TAC 6400 North Dixie Highway Newport, Michigan 48166 o.c.mo.o ese

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REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTION 3.8 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 Secticqs RAI 0.0-1: There is a generic issue involv!ng 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 3.8.1 LA.1 3.8.1 LA.3 3.8.2 LA.1 3.8.2 LA.3 3.8.4 LA.1 3.8.4 LA.3 3.8.5 LA.1 Section 3.8 3.8.1-1 Current technical specification (CTS) 3/4.8.1.1 Actions b.2 and b.3 Discussion of Change (DOC) LR.4 ITS 3.8.1 Required Action A.4 and Completion Time Bases for ITS 3.8.1 Required Action A.4, STS Bases markup page B 3.8-10 insert 3a Action b.2 for CTS 3/4.8.1.1 requires verifying within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, that combustion turbine-generator (CTG) 11-1 is operable. In the event that this requirement cannot be met, Action b.3 for CTS 3/4.3.1.1 requires restoration of CTG 11-1 to Operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Required Action A.4 for ITS 3.8.1 sequires the licensee to determine CTG 11-1 is available with a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from discovery of Condition A (one or both emergency diesel generators (EDGs) inoperable in one division) concurrent with CTG 11-1 not available. The use of the term available, as defined in the Bases, ENCLOSURE

In place of operable, is acceptable. However, the deletion of the CTS requirement to periodically varify CTG 11-1 is operable does not appear to be acceptable. The proposed ITS do not include a specific requirement to verify CTG 11-1 operability within a given period of time. The ITS requirement is to verify CTG 11-1 availability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of determining its non-availability, but there is no requirement to determine availability at the time the EDGs become(s) inoperable. The determination of CTG 11-1 availability appears to be floating in the ITS with no specific time constraints. This is not acceptable. The licensee should revise the submittal to address the staff concems. The Bases discussion of Actions A.4 and A.5 may require revision as a consequence of responses to staff comments on ITS Actions A.4 and A.S.

i Detroit Edison Company (DECO) Response:

3.8.1-2 ITS/STS surveillance requirement (SR) 3.8.1.2 Justification For Difference (JFD) P.5 CTS 4.8.1.1.2.a.4 Bases for ITS SR 3.8.1.2, STS Bases markup page B 3.8-16 The staff does not agree with deleting Note 3 from this SR. The intent of this Note is to recognize that certain EDG vendors recommend modified start procedures, and to make specific provision for using these procedures. The first sentence in the Note should be retained.

Deletion of the second sentence in the Note is acceptable based on the CTS.

DECO Response:

3.8.1-3 Resolved irit5 December 4,1998, meeting.

3.8.1-4 Bases Pg. B 3.8-16 ITS SR 3.8.1.2 i

This Bases section ir:cludes a discussion of modified DG starts. The proposed ITS deletes the Note in SR 3.8.1.2 which addresses modified starts. In light of this, the proposed Bases is not acceptable because the Bases can only include discussions of what is included in the TS. This Bases discussion would be acceptable if the licensee agrees to retain the Note in SR 3.8.1.2.

(See comment 3.8.1-2.)

j DECO Response:

3.8.1-5 ITS/STS SR 3.8.1.7 The licensee should verify that the minimum values of 3740 VAC and 58.8 Hz are the minimum values necessary in order for the EDG to accept post accident loads.

DECO Response: -

3.8.1-6 DOC L.5 ITS Surveillance Requirements (SRs) 3.8.1.7,3.8.1.11, and 3.8.1.14 Bases for ITS SRs 3.8.1.7, 3.8.1.11, and 3.8.1.14 CTS 4.8.1.1.2.a.4 and 4.8.1.1.2.e.5 STS SRs 3.8.1.7, 3.8.1.12, and 3.8.1.15 STS SRs 3.8.1.7,3.8.1.12, and 3.8.1.15 require the generator voltage and frequency to be within specific tolerance bands within 10 seconds after the start signal. Corresponding CTS 4.8.1.1.2.a.4 and 4.8.1.1.2.e.5 require the generator voltage and frequency to be 4160

• 420 volts and 60 i 1.2 Hz within 10 seconds after the start signal. This requirement has not been retained in corresponding ITS SRs 3.8.1.7,3.8.1.11, and 3.8.1.14, which require achieving a i

voltage a 3740 V and a frequency 2 58.8 in s 10 seconds. This proposed change appears to be j

the incorporation of Technical Specifications Task Force (TSTF) 163, Rev. 2. However, no mention of the TSTF is made. Make appropriate reference to the TSTF or other basis for the change. In addition, address the following:

a. The TSTF revises the bases to include periodic monitoring and trending of the time the EDG takes to reach steady state in order to identify degradation of governor and voltage regulator performance. This portion of the TSTF was not incorporated.

b.

Similar changes would apply to ITS SR 3.8.1.18 but were not incorporated.

DECO Response:

3.8.1-7 Response to 3.8.1-6 will resolve this item.

3.8.1 -8 ST3 SR 3.8.1.8 JFD P.1 The generic JFD P.1 does not provide an adequate justification why this STS SR is not included in the ITS. The licensee should provide the justification.

DECO Response:

3.8.1-9 Resolved in the December 4,1998, meeting.

3.8.1-10 CTS 4.8.1.1.2.e.7 ITS SR 3.8.1.12 STS SR 3.8.1.13 t

JFD P.1 JFD P.1 does not provide a discussion on why that part of the STS SR dealing with "[ actual or simulated loss of voltage signal] on the emergency bus concurrent with" is deleted from the SR.

The licensee is requested to provide this justification.

DECO Response: -

3.8.1-11 CTS 4.8.1.1.2.a.4 and "" footnote Bases Pg. B 3.8-16 ITS SR 3.8.1.2 and SR 3.8.1.7 The CTS markup for the "" footnote to 4.8.1.1.2.a.4 indicates that the note to ITS SR 3.8.1.7 was intended to include the phrase "and followed by a warmup period prior to loading."

j However, neither ITS SR 3.8.1.7 nor its Bases reflect this portion of the note. The note to the GR and Insert B 3.8.1-6 could be expanded to include SR 3.8.1.7. A warmup period prior to loading would be permissible (assuming the DG vendor recommends a warmup rcriod with the DG running at synchronous speed).

DECO Response:

3.8.1-12 STS Bases Markup, pages B 3.8-17 and B 3.8-18 STS/ITS SR 3.8.1.3 and SR 3.8.1.2 i

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a.

In the last paragraph of the discussion on SR 3.8.1.2 and the third paragraph of the discussion on SR 3.8.1.3, the licensee proposes to add "as modified by GL [ Generic j

Le*ter] 94-01" to " Regulatory Guide 1.9." The staff is not aware of any reference to Regulatory Guide 1.9 in GL 94-01. Clarify this proposed addition.

b. The staff does not fully understand what is intended by insert B 3.8.1-4. The insert is unclear, especially with regard to that part of the insert which addresses " jeopardizing overloading the EDG." The licensee should consider revising the insert to clarify it.

DECO Response:

3.8.1-13 CTS 4.8.1.1.2.e.8 Bases Pg. B 3.8-27 ITS SR 3.8.1-13 The SR does not contain a requirement to conduct thit SR at a specified power factor.

1 However, conducting this SR at a power factor of 0.9 or less is the best way to demonstrate DG OPERABILITY. Should these Bases be revised to state that, while not requked, the SR is normally conducted at some target power fsetor?

4 Deco Response:

3.8.1-14 DOC L.6 ITS SR 3.8.1.14 Note 1 CTS 4.8.1.1.2.e.8 footnote

• Bases for ITS SR 3.8.1.14, STS Bates markup page B 3.8-28 Note 1 for ITS SR 3.8.1.14 refers to EDG operation for a 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded a 2500 kW. The remainder of Note 1 states, 'M mentary transients outside of load range do not invalidate this 4

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test," which is a proposed change relative to footnote

• for CTS 4.8.1.1.2.e.S. The Bases for ITS SR 3.8.1.14 also refers to a load band. DOC L.6 also refers to a load range. There is an apparent inconsistency within Note 1 in that no load range is provided. Revise the submittal to resolve this apparent inconsistency and provide the appropriate justification.

DECO Response:

3.8.1-16 ITS SR 3.8.1.3 Bases for ITS SR 3.8.1.3, STS Bases page B 3.8-17, last paragraph ITS SR 3.8.1.3 requires loading to a 2500 kW. The Bases for ITS SR 3.8.1.3 refers to a load band. There is an apparent discrepancy between ITS SR 3.8.1.3 and its Bases. Revise the submittal to resolve this apparent discrepancy.

DECO Response:

3.8.1-16 Resolved in the December 4,1998, meeting.

3.8.1-17 DOCS A.4, LA.3, LA.4, and LR.1 CTS 3/4.7.1.4 CTS 3/4.8.1.1 4

CTS 3/4.8.1.2 ITS 3.8.1 CTS 3.7.1.4 provides requirements for the diesel generator cooling water system that supports CTS 3/4.8.1.1 and 3/4.8.1.2. It has been proposed to move some of these requirements to the Bases and the Updated Final Safety Analysis Report, and to delete the rest. CTS 3/4.7.1.4 appears to satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). Revise the sv5mittal to include an ITS specification and bases that address these requirements, or alternatively, incorporate thesis requirements into ITS 3.8.1.

DECO Response:

3.8.2-1 CTS 3.8.1.2, Action a DOC LA.2 DOC LA.2 should be revised to include a reference to compliance with GL 80-113 and NUREG-0612 with respect to crane operations and heavy load handling.

DECO Response:

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3.8.2-2 CTS 4.8.1.2 DOC L.1 STS/ITS SR 3.8.2.1 For consistency, unless otherwise noted this comment will discuss SRs in terms of the numbering in the ITS. CTS 4.8.1.2 requires the power sources to be demonstrated operable per (ITS) SRs 3.8.1.1,3.8.1.2, and 3.8.1.4 through 3.8.1.18. STS SR 3.8.2.1 indicates that ITS SRs 3.8.1.1 through 3.8.1.17 are applicable. (Note thatJTS SRs 3.8.1.8 and 3.8.1.17 were not adopted because they are not in the CTS.) ITS SR 3.8.2.1 also indicates that ITS SRs 3.8.1.1 through 3.8.1.17 are applicable. In the STS, a note is included that indicates that (ITS) SRs 3.8.1.3,3.8.1.8 through 3.8.1.10, and 3.8.1.12 through 3.8.1.17 are not required to be performea. In the ITS, this note is modified to indicate that SRs 3.8.1.2, 3.8.1.3, and 3.8.1.7 through 3.8.1.17 are not required to be performed. The ITS note relieves the licensee from the requirement to perform three SRs (3.8.1.2,3.8.1.7, and 3.8.1.11) that are required by the STS.

i DOC L.1 discusses the exclusion of SR 3.8.1.18, a change from the CTS. DOC L.1 also states that the ITS note is consistent wim the STS. However, as discussed above, this is not correct.

The DOC indicates that the SRs which are not required to be performed are excepted because they would require rendering an operable EDG inoperable, de-energizing a required onsite power source, or disconnecting from a required offsite source. The staff does not consider SRs 3.8.1.2, 3.8.1.7, and 3.8.1.11 to fall into this category. Modify the note to conform to the STS or provide additional justification for the exception for these three SRs.

DECO Response:

3.8.2-3 Resolved in the December 4,1998, meeting.

3.8.3-1 Resolved in the December 4,1998, meeting.

3.8.3-2 JFD P.4 Bases for ITS SR 3.8.3.3, STS Bases markup page B 3.8-46 Bases for STS SR 3.8.3.3 The Bases for STS SR 3.8.3.3 states, "... but in no case is the time bet.veen receipt of new fuel and conducting the tests to exceed 31 days." This has been modified in the Bases for corresponding ITS SR 3.8.3.3 which states, "... but in no crse is the time between sampling (and associated resuiis) of new fuel and addition of new fuel oil to the storage tank to exceed 31 days." JFD P.4 does not explain why this proposed difference is acceptable. Revise the submittal to provide the appropriate justification, or conform to the STS. A time line representation of the STS and the ITS Bases descriptions should accompany the justification.

DECO Response:

3.8.3-3 JFD P.4 Bases for ITS SR 3.8.3.3, STS P. as markup pages B 3.8-47 and B 3.8-47 (i.wer1)

Bases for STS SR 3.8.3.3 The Bases for STS SR 3.8.3.3 states, "Within (31] days following the initial new fuel oil sample, the fuel oil is analyzed..." This has been modified in the Bases for corresponding ITS SR 3.8.3.3 which has not adopted the reference to "31 days" at the beginning of the paragraph, and has inserted, "These additional analyses are required... to be performed within 31 days following sampling and addition." The " sampling and addition" referred to in the Bases insert for ITS SR 3.8.3.3 do not seem to be concurrent events, which would make the 31 day time limit ambiguous. JFD P.4 does not explain why this proposed difference is acceptable. Revise the submittal to provide the appropriate justification, or conform to the STS. A time line representation of the STS and the ITS Bases descriptions should accompany the justification.

DECO Response:

3.8.3-4 ITS SRs 3.8.3.1 and 3.8.3.4 ITS SRs 3.8.3.1 and 3.8.3.4 CTS 4.8.1.1.2.a.2 and 4.8.1.1.2.a.7 The Frequency for STS SRs 3.8.3.1 and 3.8.3.4 is 31 days. This has been adopted as the Frequency for corresponding ITS SRs 3.8.3.1 and 3.8.3.4, which are proposed changes relative J

to corresponding CTS 4.8.1.1.2.a.2 and 4.8.1.1.2.a.7 which are required to be performed at least once per 31 days on a Staaoered Test Basis (emphasis added). The CTS 3.B.1 markup discussed the removal of the staggered test basis in DOC L.3 for that specification. Revise the submittal to provide appropriate justification or reference to the removal of the staggered test basis for !TS 3.8.3 SRs.

DECO Response:

3.8.4 1 The originalitem was for inforrnation only. There is no question.

3.8.4-2 (TS/STS SR 3.8.4.3 JFD C.1 CTS 4.8.2.1.c.1 The proposed changes to this SR do not reflect the changes accepted in TSTF-38 as indicated in JFD C.1. The proposed changes are not acceptable because they change the intent of the SR and because they are not consistent with TSTF-38. [The proposed SR does not require any action; i.e., the requirement is to " inspect for", but imposes no action. The STS SR requires that the batteries "show no" damage that cause degradation. The STS requires that any damage be evaluated for impact on battery OPERABILITY.] The ITS SR should be revised to be consistent with the STS as modified by TSTF-38.

DECO Response: _

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i 3.8.4-3 STS Bases Pg. B 3.8-51 ITS SR 3.8.4.8 JFD P.1 ITS SR 3.8.4.8 requires that battery capacity be demonstrated to be equal to (or greater that) 80% of rating. From this it is concluded that the battery has capacity to power al! DC loads for 4

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hours even when degraded to 80% of rated capacity. If this is the case, what is tha justification j

for deleting the Bases material that discusses this capability? JFD P.1 does not provide on adequate justification.

DECO Response:

i 3.8.4 4 The originalitem was for information only. There is no question.

i 3.8.5-1 STS!iTS 3.8.5 Insert 3.8.5-1 i

JFD P.4 DOC M.1 Bases for ITS 3.8.5, STS Bases markup page B 3.8-60 CTS 3,S.2.2 requires Division I or Division li of the DC electrical power sources to be OPERABLE as a minimum. STS 3.8.5 requires DC electrical pov,s subsystems to be i

OPERABLE to support DC electrical power distribution subsystems required by STS 3.8.10 (ITS 3.8.8). CTS 3.8.2.2 and STS 3.8.5 appear to be equivalent. Proposed ITS Insert 3.8.5-1 is similar to the CTS and the STS but differs with respect to power sources. The CTS and the STS both require both the battery and the charger associated with the DC electrical power subsystem to be OPERABLE. The proposed ITS would allow one of two required DC electrical power subsystems to be powered from either a battery or a charger, but not both. The proposed ITS does not appear to reflect the CTS and differs from the STS. This issue is under review by the NRC and the industry and requires resolution before it can be implemented in the Fermi converted TS.

1 DECO Response:

l E.52 Bases Pg. B 3.8-60 and 3.8-61 STS 3.8.5, insert B 3.8.5-1 and Insd B 3.8.5-2 JFD P.3 Changes to the limiting condition for operation (LCO) Bases and the Actions Bases are indicated as being justified by JFD P.3. In the list of JFDs, however, P.3 is indicated as not used. What is the appropriate justification for these Bases changes? Note that the changes to the Bases for STS 3.8.5 are a subset of the changes to STS 3.8.5 identified in question 3.8.5-1, above.

DECO Response:

3 8.5-3 Resolved in the December 4,1998, meeting.

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3.8.6-1 ITS 3.8.6 ITS Action A JFD P.4 -

Deleting reference to Table 3.8.6-1 in the LCO is acceptable.- However, reference to this Table must be included in Action A.

DECO Response:

3.8.6-2 STS Table $5.6-1 j

JFD P.1 The proposed Table would change the applicability of footnote (c) from Categories A, B, and C to only Categories A and C. This is acceptable since it represents the CTS. However, this means that specific gravity must be measured for each connected cell to demonstrate compliance with Category B limits, regardless of float current. Measurement of and compliance with Category B specific gravity limits is required at all times, including following a battery recharge after a discharge. Given this, the licensee might want to reconsider adopting STS Note (c) in its entirety and applicable to all three categories, with appropriate justification.

DECO Response:

3.8.6-3 Bases Pg. B 3.8-69 Table 3.8.6-1 JFD P.3 The Bases discussion regarding the applicability of Table 3.8.6-1 fcotnotes to Category A, B-and C specific gravity :s not consistent with proposed Table 3.8.6-1. In addition, the Bases discussion regarding float current and specific gravity is not consistent with the proposed Table.

The footnote regarding specific gravity and float current it not applicable to Category B.

DECO Response:

3.8.6-4 STS/ITS SR 3.8.6.2 & 3.8.6.3 CTS 4.8.2.1.b.1 & 3 There are two issues related to these SRs:

a. The change in the overcharge voltage limit for the Division ll battery incorporated by Amendment No.121 has not been incorporated. Incorporate the change into the STS markup and the ITS.

b. In the CTS, the frequency for CTS 4.8.2.1.b.3 is at least once per 92 days and within 7 days after a deep battery discharge or battery overcharge. In the STS and the ITS the frequency is 92 days. There is no markup or justification for the deletion of the situational surveillance frequency. Adopt the CTS or justify the less restrictive change from the CTS.

DECO Response:

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3.8.7-1 The original item was for information only. There is no question.

3.8.7-2 DOC L.1 JFD P.2 JFD P.5 CTS 3/4.8.3.1 Action a Bases for ITS 3.8.7 Required Action A.1, STS Bases page B 3.8-81 Bases for STS 3.8.9 Required Action A.1 CTS 3/4.8.3.1 Action b Bases for ITS 3.8.7 Required Action B.1, STS Bases page B 3.8-85 Bases for STS 3.8.9 Required Action C.1 The Bases for Required Action A.1 for STS 3.8.9 refers to "With one or more required AC buses

... In one division inoperable,..." This reference has not been adopted in the Bases for Required Action A.1 for corresponding ITS 3.8.7, which refers to "With one or more required AC buses or MPUs [ modular power units] inoperable, and a loss of function has not yet occurred,

..." Action a for CTS 3/4.8.3.1 addresses one AC distribution system division not energized.

JFD P.5 describes editorial differences and references TSTF-16. TSTF-16 has not been approved by the NRC. Similarly, the Bases for Required Action C.1 for STS 3.8.9 states

" Condition C represents one division without adequate DC power..." The Bases for Required Action B.1 for corresponding ITS 3.8.7 states " Condition B represents one or more DC MCC

[ motor control center) or distribution cabinets without adequate DC power..." Action b for CTS 3/4.8.3.1 addresses one DC distribution system division not energized. JFD P.2 does not explain why the proposed Bases difference is acceptable.

DOC L.1 addresses the potential for a loss of function. However, DOC L.1 does not explain why, for both the AC and DC distribitJon systems, it is acceptable to have more than one distribution system division inoperable. Revise the submittal to provide the appropri9te justification for the proposed changes or conform to the STS.

DECO Response:

3.8.7 3 Combined with 3.8.7-2.

3.8.7-4 The original item was for information only. There is no question.

3.8.7-5 ITS 3.8.7 Completion Time for Required Actions A.1 and B.1 STS 3.8.9 Completion Time for Required Actions A.1 and C.1 CTS 3/4.8.3.1 Actions a and b The Completion Time for Required Actions A.1 and C.1 for STS 3.8.9 is "16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO." This has been adopted as the Completion Time for Required Actions A.1 and B.1 for corresponding ITS 3.8.7. These Completion Times are proposed changes relative to Actions a and b for corresponding CTS 3/4.8.3.1, No justification has been -

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DECO Response:

3.8.8-1 Bases Pg. B 3.8-90 STS 3.8.8, Insert B 3.8.8-1 JFD P.1 JFD P.1 does not provide an adequate justification for inclusion of insert B 3.8.8-1. The licensee should revise the JFD to specifically address this insert, including references to current licensing basis. Consideration should also be given to whether or not this permissive is appropriate for inclusion in the Bases without having the permissive included in the TS LCO. The licensee should also consider whether or not cross-tie breakers can be closed and still maintain the independence of the EDG.

DECO Response:

3.8.8 2 Resolved in the December 4,1998, r.:ceting.

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