Text

Summary of 981201-04 Meetings with Util in Rockville,Md Re Improved STS Conversion
	ML20198J691
Person / Time
Site:	Fermi
Issue date:	12/23/1998
From:	Kugler A; NRC (Affiliation Not Assigned)
To:	; NRC (Affiliation Not Assigned)
References
	NUDOCS 9812300243
	Download: ML20198J691 (41)
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December 23, 1998 LICENSEE: Detroit Edison Company (DECO)

FACILITY: Fermi 2 Nuclear Plant

SUBJECT:

MEETING WITH THE DETROIT EDISON COMPANY TO DISCUSS THE FERMI 2 IMPROVED STANDARD TECHNICAL SPECIFICATIONS CONVERSION !

The NRC staff met with DECO at NRC Headquarters on December 1 through 4,1998, to l discuss issues related to the Fermi 2 submittal for the conversion to the improved standard technical specifications (STS). The primary focus of the meeting was to discuss proposed questions for a request for additional information (RAl) for Sections 3.3 and 3.8 of the conversion. However, some more generalissues were also discussed. Enclosures 1 and 2 are the lists of questions for Sections 3.3 and 3.8, respectively, that were faxed to the licensee prior ,

to the meeting. Enclosure 3 lists the meeting participants. l in the course of the discussion concerning the questions, there were some cases in which the licensee was able to clarify the information in the submittal or point out additional information that existed in the submittal that satisfied the staff's concerns. In these cases, the questions will not be included in a formal RAI. The balance of the questions will be sent to the licensee in the near future in one or more letters requesting additional information.

Finally, the participants discussed general issues related to the staff's review, the status of RAls, and the schedule for future meetings to discuss other sections of the conversion. The more significant items are provided in Enclosure 4.

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

Enclosures:

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9812300243 981223 PDR ADOCK 05000341 P PDR

9;O Detroit Edison Company Fermi 2 cc:

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

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 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 lll 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 Newport, Michigan 48166 December 1998

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t. Farmi improvrd TS Ravinw Commants Section 3.3, Instrumentation 3.3-1 Generic LX-DOC 3.3.2.1: LA.2, LA.3, LB.1, LC.1; 3.3.3.1: LR.1, LR.2; Comment: Clarify that the proposed CTS limits described in the LX DOC can be changed without affecting safe operation of the plant. These LX discussions do not provide sufficient i supporting evaluation ( e.g., contains unsubstantiated conclusions, vague statements i.e., "This change is acceptable because the Operability for .... is unchanged") for the staff to conclude that the proposed less restrictive generic changes do not present a significant safety question in the operation of the plant and that the TS requirements that remain are consistent with current j licensing practices, operating experience and plant accident and transient analyses.

Detroit Edison Response:

l 3.3-2 Generic LA.1 DOC ITS LCOs: 3.3.1.1; 3.3.2.1; 3.3.2.2; 3.3.4.1; 3.3.5.1; 3.3.5.2;3.3.6.1; 3.3.6.2; 3.3.6.3 (LA.2); 3.3.7.1; 3.3.8.1 Comment: The CTS proposes to move Trip Setpoint LCO requirements to the TRM. DOC LA.1

does not adequately discuss the CTS Trip Setpoint changes. Provide a revised DOC that l

evaluates the CTS requirements as operational limits and the CTS Allowable Values as TS operability limits. Explain how the ITS preserves the relationship between these limits and why i

it is sufficient to rely or the Allowable Values in determining trip channel operability for RPS l instrumentation.

I Detroit Edison Response:

3.3-3 Global R-DOC Comment: R DOCS provide discussion and justification for relocating CTS requirements. The Selection Criteria is correctly applied to these relocated requirements. Provide the name of the l licensee document to which the CTS requirements are relocated and the identify the regulation that will control future changes to the relocated requirements.

Detroit Edison Response:

3.3- 4 Generic A-DOC A.10: 3.3.1.1 A.3: 3.3.2.1, 3.3.4.1, 3.3.5.1, 3.3.5.2, 3.3.6.1, 3.3.6.2, 3.3.7.1, 3.3.8.1 Comment: CTS specified Actions for setpoints not within limits are eliminated as an administrative presentation preference only. These Actions state " declare the channel inoperable until the enannelis restored to Operable status." ITS contain all the requirements and Actions for channels, including the setpoints and the usage rules of TS adequately dictate l- that channels be declared inoperable. Administrative change TS are TS changes that do not affect the operating limits or the manner in which the plant is operated (e.g., that the change represents a simple re-wording, deletion of a TS whose applicability has expired, or which duplicates regulatory or other requirements; or word changes that incorporate a previously implicit understanding of the TS.) Additionally, if the only change to the TS involves a reformatting or word difference without any change in meaning or operation of the plant, the change is administrative. Revise the above A-DOCS to show that eliminating CTS trip setpoint channel operability requirements and retaining Allowable Value setpoints in ITS are Administrative changes.

Detroit Edison Response:

fermi \rai\33.R0 1 November 17,1998 ENCLOSURE 1 l

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4 3.3-6 ccn:ric A-DOC A.11: 3.3.1.1 A.4: 3.3.5.1, 3.3.5.2, 3.3.8.1 A.5: 3.3.4.1, 3.3.6.1, 3.3.6.2 Comment: The CTS requirement to perform a " simulated automatic operation" of all channels is deleted in the ITS because "it is synonymous with the LSFT and/or Channel Functional Test."

Revise the DOC to explain how this justification relates to ITS requirements.

Detroit Edison Response:

3.3 6 Global- All DOCS Comment: Global change: Revise DOCS to replace " assure" with " ensure."

Detroit Edison Response:

3.3.1.1 1 CTS Table 2.2.1-1 DOC LR.2 Comment: LR.2 proposes to delete restrictions for APRM gain adjustment. The DOC states that APRM operability is maintained in ITS, therefore no regulatory controlfe.g., TS amendment or 10 CFR 50.59) is necessary to provide adequate protection of the public health and safety. Provide additional discussion to show the safety relationship between the two restrictions proposed to be deleted (limiting APRM gain to 100% and the notice posted in the control room) and APRM Operability in the ITS. (See also RAI 3.3.1.1-20)

Detroit Edison Response:

3.3.1.1- 2 DOC A.3 CTS 3.3.1, Actions a.2and a.3, and footnotes

and **

Comment: This DOC equates TS Action requirements with " directions on options for compliance" and states that " detailed direction for these options" are not hcluded in ITS 3.3.1.1; rather " optional Actions presented rely upon the guidance of LCO 3.0.2." Comment: This DOC provides an obscure discussion for an administrative change. It relates CTS requirements, taken out of context, to undocumented interpretations of ITS Section 3.0 generic requirements. Revise the DOC.

Detroit Edison Response:

3.3.1.1- 3 CTS Table 4.3.1.1-1, Note (f)

DOC A.8 ITS SR 3.3.1.1.3 i Comment: The LPRM calibration frequency is changed to a MWD /ST basis from a EFPH j basis. Provide supporting calculations to prove the CTS test frequency is unchanged. {

Detroit Edison Response:

3.3.1.1- 4 CTS Table 3.3.1-1, Action 5 DOC A.9 l ITS Condition H j Comment: The ITS proposes changes to CTS shutdown completion times when channels for isolating MSIVs on high radiation are not restored to operable status. The CTS requirements are to close the MSIVs in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . DOC A.9 takes the position that since either option is acceptable for meeting TS, this constitutes an implicit allowance to perform either action in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months without violating TS. Provide a less restrictive change discussion to justify extending the time allowance for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to comply with TS by isolating the MSIVs. (See also RAI 3.3.6.1-17)

Detroit Edison Response:

formi\ral\33.R0 2 November 17,1998

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ly A 1

3.3.1.1 6 CTS Table 4.3.1-1, footnote (b) l 2

DOC M.4 & LR.3, JFD P.5

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l j ITS SR 3.3.1.1.6 4

Comment: The CTS SR frequency is changed to " verify SRM/lRM overlap prior to fully withdrawing SRMs from the core" from

verify % decade overlap during each startup after .

2 entering OPERATIONAL CONDITION 2." STS require that the SRMs must remain fully l

, inserted until IRM indication has overlapped with SRMs. JFD P.5 states in part that CTS only j require that an overlap exists. The P.5 statement does not appear to accurately reflect CTS !

i requirements as statad above. In addition, P.5 states that the Fermi plant is operated with the '

! SRMs inserted to about 2/3 core height, an , withdrawal can be made and overlap established l with the SRMs partially withdrawn. It appears that the ITS proposes to drop the requirement to verify % decade os erlap. This less restrictive change is not evaluated. Identify any operational i hardships that would result if the STS frequency for SR 3.3.1.1.6 is adopted. Explain whether the preference for not adopting the ISTS is based on cycle dependent concems. Revise LCO l 3.3.1.1 DOCS. (See also RAI 3.3.1.1-14)

] Detroit Edison Response:

1 l 3.3.1.1-6 CTS Table 3.3.1-1, Action 6, footnote (e) i DOC LA.2 i Comment: Footnote (e) provides an operationallimit: "an APRM channelis inoperable if there l

} are less than two LPRM inputs per level or less than 14 LPRM inputs to an APRM Channel." j i Justify the discussion that footnote (e) is a design or descriptive detail.

I Detroit Edison Response:

i

{ 3.3.1.1- 7 CTS 3.3.1, Action a.1 .

j DOC LA 3 l J ITS Condition C

! Comment: LA.3 states: " CTS 3.3.1, Action a.1 addresses the necessary requirements for a

loss of RPS scram capability (one trip system with more than one hoperable channe! in any Functional Unit." ITS Condition C includes loss of trip capability in either one or both trip l systems. The CTS uses two Actions (a.1 and a.2) to address the same set ofinoperable conditions. Revise DOC LA.3 discussion to address loss of RPS functional capability changes included in all CTS Actions.

Detroit Edison Response

l l 3.3.1.1- 8 CTS 3.3.1 footnote "

l DOC LA.4 i Comment: Revise LA.4 to state that footnote ** is an instructional note not related to the i operational limits specified in TS and therefore this detail can be moved to the Bases.

Detroit Edison Response:

3.3.1.1- 9 DOC LA.5 i Comme.it: What is the safety basis justification for not requiring that the shorting links be removed if the shutdown margin requirements in TS are not met. What is the safety basis

justification for not increasing the required number of operable APRMs to 4 per trip system from I

three per trip system and the number of operable IRMs to 6 per trip system from three per trip system if the shorting links are removed in Mode 5. This LA DOC needs to be restructured to specifically address the safety basis for the change. A statement of the safety function of the shorting links is missing from the narrative. The focus of the DOC should prove that the TS requirements that remain in the proposed ITS are sufficient to ensure safe operation of the fermi \rai\33.P0 3 November 17,1998

q I plint. Th3 conclusion statss thit 'rrlocation of shorting link r:moval r;:quir:msnts continu:;s to provida edcquata prot:ction of tha public....." Explain how'rsmov;d requircmtnts" are able to continue to provide adequate protection of the public.

Detroit Edison Response:

3.3.1.1-10 CTS Table 4.3.1-1, footnote (f)

DOC LA.7 l Comment: Revise LA.7. Explain the safety basis for relocating the metnod for performing the TS required surveillance.

Detroit Edison Response:

3.3.1.1-11 CTS 4.3.1.3 DOC LA.10 ITS SR 3.3.1.1.17 Comment: CTS 4.3.1.3 requires "each" reactor tdp functional unit demonstrated within its Response Time limit (except Reactor Vessel Steam Dome Pressure - High and Reactor Vessel Low Water Level). Corresponding ITS SR 3.3.1.1.17 is required for all RFS functions except IRMs, APRM Neutron Flux - High Setdown, APRM-Inop, Drywell Pressure - High, Main Steam Line Radiation-High, Scram Discharge Volume Water Level- High, Reactor Mode Switch -

Shutdown Position, and Manual Scram. LA.10 specifies relocating RPS Response Time testing 1 requirements to plant procedures for those RPS trip Functions that have no specific acceptance I criteria located in the TRM. This DOC does not adequately justify the relocation of CTS l requirements, it is not clear that testing requirements moved to plant procedures are not associated with FSAR requirements, such as TRM requirements. The moved RPS testing requirements should be discussed separately, providing a technical basis for removal of each testing requirement from the ITS. Revise LA.10. l Detroit Edison Response: !

1 3.3.1.1-12 CTS 4.3.1.3, Note

DOC LA.12 ITS SR 3.3.1.1.17 Comment: The proposed CTS changes are not acceptable. The design sensor response time is the specified limit in CTS. This limit is based on staff review and acceptance of a topical report NEDO-32291 and must be retained in the note to SR 3.3.1.1.17. This precludes substituing other topical report acceptance criteria such as historical data for response time testing for manufacturers data. Revise SR 3.3.1.1.17 to include " design sensor response time."

Detroit Edison Response:

3.3.1.1-13 CTS Actions (a) and (b)

DOC LC.1 Comment: CTS 3.3.1 Actions (a) and (b), Completion Times, are increased consistent with STS 3.3.1.1 and consistent with allowed outage times analyzed per NEDO-30851-P-A,

" Technical Specification Improvement Analyses for BWR Reactor Protection System," March 1988 Provide the SER reference approving use of NEDO-30851-P-A for Fermi-2. The first bullet in this DOC should be revised to state that CTS Action a.1 is for "one or more" channels inoperable. The second bullet in this DOC should note that the iTS allows a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months repair allowed outage time (AOT) for "any" inoperable channel. Further, the bulleted discussion about ITS requirements should explain that multiple condition entry usage rules apply in the iTS. Any CTS changes that result should be discussed.

Detroit Edison Response:

fermi \rai\33.R0 4 November 17,1998

p' .I 3.3.1.1-14 CTS Table 4.3.1.1-1, footnota (b) [for IRMs and APRMs] 1 DOC LR.3 ITS SR 3.3.1.1.6 & 3.3.1.1.7 Comment: Clarify why the DOC list of reasons for " regulatory con'rol is not needed" is i germane to providing a safety basis justification for eliminating % decade overlap operability l acceptance criteria for nuclear instrumentation. (See a%o RAI 3.3.1.1-5)

Detroit Edison Response:

3.3.1.1-15 CTS Tables 3.3.1-1 and 4.3.1.1-1, Functions 1.a,2.a. 2.d,11,12 ]

DOC L.3 l Comment: Revise the DOC to clarify the meaning of the second to last sentence to the l Justification for eliminating TS requirements. l Detroit Edison Response: 1 3.3.1.1-16 CTS Action 7 DOC L.3 l Comment: This DOC states that the associated actions for the Mode Switch in Shutdown are !

! deleted consistent with NUREG-1431. NUREG-1431 requires Reactor Mode Switch -

Shutdown Position to be operable (LCO 3.3.2.1) when the mode switch is :n the shutdown position. CTS Action 7 requires verification that insertable control rods tre inserted. Action 7 becomes LCO 3.3.2.2, Required Action E.2 in the ISTS. Revise L.3 to be consistent with NUREG requirements. l l Detroit Edison Response:

3.3.1.1-17 DOC L.4 l Comment: From a practical perspective is it reasonable to expect the plant to use the ITS allowance to disable the Mode Switch in Shutdown Position enforced scram for control rods that !

have their core cells defueled? Revise DOC L.4 to correct the reference to CTS footnote (1) from CTS footnote (j) for Functions 8.a and 8.b.

Detroit Edison Response:

3.3.1.1-18 DOC L.5 Comment: Identify the control items that are included in ITS.

Detroit Edison Response: i 3.3.1.1-19 CTS Table 2.2.1-1 Comment: CTS Table 2.2.1-1 includes an Allowable Value for Function 2b.1.b, High Flow Clamped. ITS Table 3.3.1-1 omits this Function and Allowable Value without discussion or justification. Provide missing documentation.

Detroit Edison Response:

3.3.1.1- 20 CTS Table 2.2.1-1 footnote ""'

Comment: CTS Table 2.2.1-1 footnote """ allows the gain of the APRMs adjusted for a period not to exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months during single loop operation, such that the final APRM readings are at least 5.1% of rated power greater than 100% times Fraction of Rated Thermal Power (FRTP),

provided the adjusted APRM readings do not exceed 100% Rated Thermal Power.

Corresponding ITS Table 3.3.1-1 footnote (b) allows APRM gains adjusted during the initial 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of single loop operation, such that the readings are greater than or equal to 5.1% Reactor Thermal Power (RTP) above THERMAL POWER. This CTS change, resulting in a deviation from the STS, is not discussed orjustified. Provide appropriate documentation for the change.

(See also RAI 3.3.1.1-1).

Detroit Edison Response:

fermi \rai\33.R0 5 November 17,1998

l

. 3.3.1.1- 21 CTS Tcbla 2.2.1-1 j

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g ITS Tcbla 3.3.1.1-1 Ccmm:nt: CTS Tabla 2.2.1-1 includ2s e trip sstpoint of " Initiation of fast closura" for Function 10, Turbine Control Valve Fast Closure. No Allowable Value is indicated for the CTS Function.

STS Table 3.3.1.1-1 does not inclu,de an Allowable Value for the Turbine Control Valve Fast Closure Function. It is not clear why there is no Allowable Value for this RPS Function. STS Table 3.3.1.1-1 includes an allowable value for this Function [9] as a " low trip oil pressure".

There is no discussion or justification for omitting the CTS trip setpoint, nor any discussion of why the Fermi design does not allow conformance with the STS requirements. Provide discussion and justification for omitting the CTS trip setpoint and Justification for the STS deviation.

Detroit edison Response:

3.3.1.1-22 STS SR 3.3.1.1.10 Comrr.snt: STS SR 3.3.1.1.10 requires calibration of certain RPS trip units every 92 days. ITS SR 3.3.1.1.10 changes the surveillance requirement to " verify the trip unit setpoint' every 92 days. This requirement originated in CTS Table 4.3.1.1-1 as footnote k, to verify trip unit setpoints as part of a CHANNEL FUNCTIONAL TEST. It is assumed that the CTS CHANNEL FUNCTIONAL TEST provides instructions for out-of-tolerance trip settings, however, ITS SR l 3.3.1.1.10 only requires verification of trip setpoints as a stand-alone requirement. The STS SR 3.3.1.1.10 requirement to "catibrate" the trip units is a more correct translation of the CTS i

requirement. Provide additional discussion and justification for the STS deviation, or implement the STS presentation of the surveillance requirement. (RAls 3.3.1.1-22, 3.3.5.1-1, 3.3.5.2-3, 3.3.6.1-3, 3.3.6.2-1, and 3.3.7.1-2 are related.)

Detroit Edist n Response:

l 3.3.1.2-1 CTS 4.3.7.6.b.2,4.3.7.6.a.2 ITS SR 3.3.1.2.6, SR 3.3.1.2.7 DOC L.3 Comment: The ITS proposes to modify these SRs with a note that allows entry into the applicable mode for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months before the TS SR is required to be met. The CTS do not contain this allowance. The STS Bases justifies the allowance as necessary because of the inability to perform the surveillance while at higher power levels. The ITS proposed to delete the justification for the note. The justification for the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed outage time (AOT) based on the submittal which does not include supporting Bases statements that the AOT is necessary for Fermi 2. Revise the ITS to delete the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AOT from SRs 3.3.1.2.6 and 3.3.1.2.7.

Detroit Edison Response:

3.3.1.22 CTS ITS DOC A.3 Comment: DOC A.3 justifies adding limitations and restrictions to the CTS even though CTS can be interpreted to include these allowances. Comment: Revise as an M-DOC.

Detroit Edison Response:

3.3.1.2-3 CTS ITS DOC L.5 Comment: Revise L.S to make a sa%ty basis statement that the new action will ensure minimum core reactivity given fuel is in the reactor.

Detroit Edison Response:

fermi \rai\33.R0 6 November 17,1998

%- 3.3.1.2 4 CTS ITS DOC L.6 Comment: Provide additional safety basis justification to explain why special detectors provide an equivalent level of monitoring. This justification should be consistent with the Bases for ITS Table 3.3.1.2-1, Note (c).

Detroit Edison Response:

l 3.3.1.2-5 CTS ITS l DOC LR.1

1. Comment: LR.1 deletes details of SRM detector operation that are related to plant design.

Revise the DOC to provide a safety basis for not controlling instructiont, for SRM detector l operation in the TS. I l Detroit Edison Response:

3.3.1.2-6 DOC L.1 Comment: Revise DOC L.1 to provlde a explanation cf why CTS actions can be replaced with ITS actions without affecting safe operation of the plant.

Detroit Edison Response:

3.3.1.2-7 DOC L.2

! Comment: DOC L.2 does not state why eliminating requirements to lock the mode switch in shutdown will not adversely impact safe operation of the plant.

Detroit Edisoa Response:

3.3.1.28 ITS SR 3.3.1.2.5 and SR 3.3.1.2.6 DOC A.2 Comment: A Note is added to ITS SR 3.3.1.2.5 and SR 3.3.1.2.6 which deletes signal-to-noise ratio determination when the SRM count rate it. greater than, or equal to,3.0 cps. This change, classified as an administrative change (DOC A.2). actually results in a less restrictive requirement, and should be discussed and justified as a less restrictive change. CTS 4.3.7.6 (c) and CTS 4.9.2 (c) require verification that the SRM count rate is at least 3.0 cps with the detector fully insertad, and does not omit the requirement to verify the count rate under any condition. Therefore, the Note added to ITS SR 3.3.1.2.5 and SR 3.3.1.2.6 is less restrictive.

Addition of this SR Note also results in a deviation from the STS which is not technically justified. Provide additional discussion and justification for the less restrictive CTS change and provide justification for the STS deviation based on specific system design.

Detroit Edison Response:

3.3.2.1-1 CTS 3.1.4.3, CTS Table 3.6-1, and CTS Table 4.3.6-1 ITS 3.3.2.1 Comment: CTS 3.1.4.3, CTS Tabio 3.6-1, and CTS Table 4.3.6-1 Rod Block Monitor Applicability is " OPERATIONAL CONDITION 1 when THERMAL POWER is greater than or -

equal to 30% RATED THERMAL POWER". The corresponding ITS 3.3.2.1 Applicability for the

. Rod Block Monitor is " THERMAL POWER greater than or equal to 30%". It is assumed that when THERMAL POWER is at 30%, the plant is always in MODE 1 and it it assumed that 30%

i THERMAL POWER is equal to 30% RATED THERMAL POWER. However this diiference in Applicability is not discussed or justified. Correct the ITS 3.3.2.1 Applicab!Iity or provide change documentation.

Detroit Edison Response:

fermi \rai\33.R0 7 November 17,1998

\

3.3.2.1-2 CTS 3.1.4.1 ACTION (a[

ITS 3.3.2.1 Required Action C.2.1.2 i l DOC A.4 Comment: CTS 3.1.4.1 ACTION (a) states: The use of this provision during reactor startup prior to the first 12 control rods being fully withdrawn is restricted to one startup "per calendar

year". The corresponding STS 3.3.2.1, Required Action C.2.1.2, also uses "per calender year" l I for this presentation. ITS 3.3.2.1 Required Action C.2.1.2 changes this presentation to "in the l previous 12 months". DOC A.4 discussed this change as being an editorial wording preference.

This change is considered unnecessary but requires a generic change before implementation.

Detroit Edison Response:

l 3.3.2.1-3 CTS 4.1.4.1.d,3.1.4.1 Action a.

ITS Ac60n C.2.2, D.1, SR 3.3.2.1.7 DOC L.3, P.5 Comment: CTS require compliance with the " prescribed control rod pattem" by a second licensed operator or other technically qualified number of the unit technical staff when the RWM i is inoperable. CTS surveillance 4.1.4.1.d establishes the prescribed control rod pattem as the

" Banked Position Withdrawal sequence." Fermi ITS however propose to deviate from the ISTS BFWS actions. Revise the ITS to adopt the ISTS actions C.2.2 and D.1.

Detroit Edison Response:

3.3.2.14 CTS 3.3.1, Action 7; Table 3.3.6-1, Action 63 DOC A.1, JFD P.1 Comment: The ITS justifications state that the actions for the Control Rod Block L Instrumentation Mode Switch in Shutdown position are consistent with CTS. In adopting CTS, i ITS deletes LCO 3.3.2.1 Action E.1 (Suspend control rod withdrawal) and E.2 (initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies) and replaces these actions with proposed Action E.1, " initiate action to insert a control rod block." i ITS Action E.1 is not acceptable as a plant specific replacement for NUREG-1431 Action E.1.

Howevnr, CTS Table 3.3.1-1 (Reactor Mode Switch-Shutdown Position) Action 7 requirements !

are cc. astent with NUREG-1431 LCO 3.3.2.1 Condition E.2; CTS Action 7 requires verification that insertable control rods are inserted. Therefore the proposed deviation from NUREG-1431 Action E.1 TS is not acceptable. Revise L.3 to be consistent with NUREG requirements.

Detroit Edison Response:

l 3.3.2.1-5 ITS Bases references DOC Comment: ITS proposes to adopt topical reports included in the ISTS. Provide references of staff SERs appmving topical reports NEDO-21231, NEDC-30851 and GENE-770-06-01 for use at Fermi-2.

Detroit Edison Response:

3.3.2.1-6 DOCS A.3, A.5 Comment: Revise 3.3.2.1, DOC A.3. Clarify how " transferring actions" are administrative changes. Revise 3.3.2.1, DOC A.S. The first two sentences do not make sense.

Detroit Edison Response:

fermi \rai\33.R0 8 November 17,1998 i

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o I 3.3.2.2-1 CTS 3/4.3.9 ITS 3.3.2.2 l DOC L1, L.3 Comment: ITS propose to adopt topical report GENE-770-06-01 (included in the ISTS) in LCO l 3.3.2.1 for rod block instrumentation. GENE-770-06-01 also applies to Feedwater Main Turbine j Trip instrumentation (LCO 3.3.2.2); however, the ITS does not propose application of the i topical to this LCO. Provide additional discussion for this selective use of topical report AOT l and STI extensions. l Detroit Edison Response- '

l 3.3.2.2-2 CTS 3/4.3.9 Actions (b) and (c)

! ITS 3.3.2.2 DOC L.3 l Comment: The ISTS LCO 3.3.2.2 is written for a three channel feedwater/ main turbine trip plant design. Fermi-2 uses_ a 4 channel (one-out-two taken twice) actuation logic with a CTS AOT allowance of 7 days for one inoperable channel and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT allowance for two inoperable channels. LCO 3.0.3 applies if more than two channels are inoperable. The ITS proposes to extend the CTS AOT to allow 7 days for a second inoperable channel as long as trip capability is preserved. This proposed change deviates from the CTS and ISTS. The justification provided in DOC L.3 is based on NUREG-1433 as a " " standard" provisions for !

inoperabilities that result in the remaining Operable logic constituting a 2-out-of 2 trip." Revise i l L.3 to delete the reference to the NUREG as a pre-approved regulatory document for CTS changes and provide reliability and safety discussions to justify extending the repair time for the second inoperable channel to 7 days from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Detroit Edison Response: j 3.3.2.2-3 CTS 4.3.9.2 ITS SR 3.3.2.2.4 DOC A.4 Comment: CTS 4.3.9.2 requires an LSFT "and simulated automatic operation" of all channels.

ISTS SR 3.3.2.2.4 requires an LSFT " including valve actuation." The CTS change is justified as based on a more clear interpretation. SR 3.3.2.2.4 hat, the provision " including valve actuation" because the definition of LSFT would otherwise exclude valve actuation. Provide revised justification to address deletion of " simulated automatic operation" and the addition of " including valve actuation" as changes to CTS requirements.

Detroit Edison Response:

3.3.3.1-1 ITS 3.3.3.1, Table 3.3.3.1-1 DOC R.1 i Comment: Primary Containment Pressure is included in the Category 1 functions required by STS 3.3.3.1. This variable was not in the CTS. Why is this function deleted in the ITS Markup?

Detroit Edison Response:

3.3.3.1-2 ITS 3.3.3.1. Table 3.3.3.1-1 DOC L.2 Comment: CTS Table 4.3.7.5-1 requires MODE 3 Applicability for the Containment High '

Range Radiation Monitor and Primary Containment Isolation Valve Position. ITS 3.3.3.1 deletes the MODE 3 Applicability for these Functions. DOC L.2 states that the initial conditions for the DBAs that rely on these monitoring functions " typically" assume power operation.

MODES 1 and 2 Applicability is consistent with the STS for PAMS Functions. However, fermiVal\33.R0 9 Novernber 17.1998

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" Typically assuma pow 2r operation"is not adrquats justification for tha CTS changa. Provida additional documtntation for this chtnga

( Detroit Edison Response:

3.3.3.1-3 Comment: ITS 3.3.3.1 Conditions A and B are marked up with a reference to DOC M.1. DOC M.1 is not included in the submittal. (Assumed editorial error only)

- Detroit Edison Response:

3.3.3.1-4 DOC A.4 Comment: CTS Table 3.3.7.5-1 Action 82.b applies to inoperable PAM PCIV position indication.

j If PAM position indication is not restored in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months CTS require that the affected isolation l valve be declared inoperable and the containment isolation valve TS actions met. The CTS i

requirement is an attemate to a shutdown when a valve position channel cannot be restored to operable status. ITS requires entry into Mode 3 if the PAM repair AOT is not met. ITS also states in the required channels note that isolated valves are not required to have operable i position indication. A.4 characterizes addition of the note and deletion of the instruction to l isolate the valve is an administrative preference. It appears the ITS results in a preference for l operating the plant, thus the change is not administrative. Elaborate on the administrative

! preference of translating CTS direction to isolate valves with inoperable indication into the ITS table note to not require indication for channels for isolated valves.

Detroit Edison Response:

3.3.3.1-5 L.1 Comment: Add discussion to the justification relating PAM instrumentation to criterion 4 and the

! extended AOT for channel repair. Delete L.1a) discussion in DOC L.1. The NUREG is a staff technical position which cannot be referenced in an SER as a basis for proposed CTS changes.

Detroit Edison Response:

3.3.3.1 -6 L.3 Comment: Proposed Condition B represents a degraded plant condition. Revise L.3 to include a safety basis discussion that explains why the less restrictive action limits are safe. ]

Detroit Edison Response: 1 3.3.3.1-7 L.5 I

Comment: Provide a safety basis justification for proposed CTS AOT extensions. Clarify the L.5 discussion: "While this presentation is an administrative presentation preference, it is provided to assist clarificatM of the ITS 3.3.3.1 Actions, whien are less restrictive." l Detroit Edison Response: 1 3.3.3.2-1 Comment: CTS LCO 3.3.7.4 states the " remote shutdown system instrumentation and controls ]

shall be OPERABLE". STS LCO 3.3.3.2 states that the " remote shutdown system functions !

shall be OPERABLE *. However, ITS 3.3.3.2 adds Division 1 to the LCO as follows: The Division 1 Ramote Shutdown System Function shall be OPERABLE". There is no discussion or

, justification for the CTS change or the STS deviation. This proposed change will obviate the l lSTS allowance to have any sinale division of instrumentation operable and still meet TS.

j Provide discussion and justification for the change.

Detroit Edison Response:

i femSrai\33.R0 10 November 17,1998 l

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3.3.3.2-2 DOC L.1 Comment: Revise L.1 to explain why the 30 day AOT is appropriate for this instrumentation.

4 Detroit Edison Response:

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3.3.4.1-1 DOC A.4

Comment: CTS Action b requires placing inoperable channels in trip whereas ITS (Action A.2) j precludes the allowance to trip the inoperable channels if those channels are inoperable as a l result of inoperable RPT breaker (s). DOC A.4 states this change is a clarification that would be

imposed by CTS actions. Provide CTS action (s) citations to document that ATWS-RPT l channels made inoperable by an RPT breaker would not be required to be tripped. Explain the l clarification. Note that administrative TS changes do not affect the operating limits or the

manner in which the plant is operated (e.g., that the change represents a simple re-wording,

! deletion of a TS whose applicability has expired, or which duplicates regulatory or other requirements; or word changes that incorporate a previously implicit understanding of the TS.)

4 Additionally, if the only change to the TS involves a reformatting or word difference without any change in meaning or operation of the plant, the change is administrative.

j Detroit Edison Response:

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i 3.3.4.1-2 DOC L.1 Comment: DOC L.1 refers to CTS Actions b, c.1 and d. The CTS markup also shows that L.1 4

applies to action c.2. Provide CTS Action (s) citations and concomitant discussions to document

! the actual relaxation of TS requirements. Additionally, DOC L.1 states that the pressure and l level functions are arranged in a 1-out of-2 twice trip logic for each ATWS function, whereas the j Bases state the actuation logic is 2-out-of-2 for either function in a trip system. Explain this i difference.

l Detroit Edison Response:

DOC L.2 3.3.4.1 -3 Comment: The proposed note to SR 3.3.4.1.5 is a change to the STS. This note duplicates l

allowances permitted under ITS SR 3.0.1 and represents a generic change. Revise the ITS to adopt ISTS SR 3.3.4.1.5 per NUREG 1433. Also, references to ITS SR 3.3.4.1.5 should be changed to SR 3.3.4.1.4.

l Detroit Edison Response: '

i i 3.3.5.1 -1 JFD P.1 l

] ITS SR 3.3.5.1.3 Comment: STS SR 3.3.5.1.3 require: calibration of certain ECCS trip units every 92 days. ITS S

SR 3.3.5.1.3 proposes to change the surveillance requirement to " verify the trip unit setpoint' I every 92 days. This requirement originated in CTS Table 4.3.3.1-1 as footnote ##, to verify trip unit setpoints as part of a CHANNEL FUNCTIONAL TEST. It is assumed that the CTS CHANNEL FUNCTIONAL TEST provides instructions for out-of-tolerance trip settings, however, proposed ITS SR 3.3.5.1.3 only requires verification of trip setpoints as a stand alone j requirement. The STS SR 3.3.5.1.3 requirement to " calibrate" the trip units is a more correct translation of the CTS requirement. Provide additional discussion and justification for the STS

deviation. (RAls 3.3.1.1-22, 3.3.5.1-1, 3.3.5.2-3, 3.3.6.1 3, 3.3.6.2-1, and 3.3.7.1-2 are d

related.)

4 Detroit Edison Response:

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fermi \rai\33.R0 11 November 17,1998 l

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3.3.6.1- 2 DOC M.4 Comment: The CTS Table 3.3.3-2 Al:owable Value for Core Spray System actuation on Reactor Steam Dome Pressure - Low, and the Allowable Value for the Low Pressure injection Mode of RHR actuation on Reactor Steam Dome Pressure - Low is " greater than or equal to 441 psig.

. ITS Table 3.3.5.1-1 changes the Alloweble Value for these Functions to " greater than or equal to 441 psig, and less than or equal to 480 psig.

The CTS Tab le 3.3.3-2 Allowable Value for ADS System actuation on Core Spray Pump Discharge Pressure - High is

greater than or equal to 125 psig, increasing', and the Allowable Value for ADS System actuation on RHR LPCI Mode Pump Discharge Pressure - High is

' greater than or equal to 115 psig, increasing'. ITS Table 3.3.5.1-1 changes the Allowable Values for these Functions by listing the Allowable Values with upper and lower limits. Provide source documentation for the Setpoint Allowable Value change.

Detroit Edison Response:

3.3.5.1-3 DOC L.2 Comment: ITS Table 3.3.5.1-1 provides a 7-day AOT for inoperable pump minimum flow instrurnentation: Core Spray Pump Discharge Flow - Low, Low Pressure Coolant injectio:1 Discharge Flow - Low, and High Pressure Coolan'. Injection Pump Discharge Flow - Low ECCS.

This discussion justifies the 7-day period for power and shutdown operations. The L-DOC lacks specific safety basis discussions for situations to which the 7-day period applies. Provide additional discussion. The ITS includes new TS Allowable Values for pump flow rates. Provide source documentation for the Setpoint Allowable Values.

Detroit Edison Response:

3.3.5.1-4 ITS Action A, B and C

, Comment: CTS Action 30 applies to Core Spray, LPCI and HPCI instrument functions which detect plant conditions requiring ECCS actuation. Action 30 becomes Actions A, B and C in ITS. The Bases support the ITS 24-hour period to repair or trip inoperable channels as allowances that accommodates the Fermi 2 design for Functions 2.e,2.f and 2.g which detect breaks and Function 2.d for loop select logic. The Bases references topical report NEDC-30936-P A. Provide a NEDC-30936-P-A citation giving the staff approved 24-hour repair or trip times, as applicable, for ITS functions 2.d. 2.e,2.f and 2.g.

Detroit Edison Response:

3.3.5.1- 5 LA.3 Com ent: ECCS manualinitiation functions are included in CTS. The ITS also requires these funce.is to preserve the overall redundancy and diversity included as part of the licensing basis of Fermi 2. Revise the ITS to include CTS manualinitiation functions. (See also RAls l 3.3.5.2-1 and 3.3.6.1-7) l Detroit Edison Response 3.3.5.1-6 Comment: Core Spray initiates the EDG on level 1 and drywell pressure. This design feature is shown as a footnote to the " Required Channels per Function" column for Functions 1.a and 1.b in Table 3.3.5.1-1. LPCI includes the same design feature as Functions 2.a and 2.b, however, Table 3.3.5.1-1 does not include the footnote for level 1 and drywell pressure sensors. Provide discussion to justify omitting Table 3.3.5.1-1 footnotes for Functions 2.a and 2.b. l Detroit Edison Response:

4 fermi \rai\33.R0 12 November 17,1998

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3.3.5.1- 7 A.11 Comment: Provide additional discussion to elaborate on "go, no. go.' type of function. Discuss the safety basis for not including the CTS Channel Functional Test in ITS.

Detroit Edison Response:

, 3.3.5.1- 8 DCC A.8 l

Comment: CTS Action 30.b is shown to become ITS Conditions B.1, C.1, B.2 and F.1. CTS Action 30.b applies to inoperable channels in both trip systems without specifying one or both channels of a trip system. The ITS requirements for one inoperable channelin both trip systems require tripping the channels within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (B.3) or 8 days (F.2) or restoring the ,

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inoperable channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (C.2). The ITS requirement for more than one inoperable channel in both trip system is to enter the appropriate actions for each channel (separate condition entry) and if a loss of function condition exists then as stated in DOC A.8 take the actions in B.1, B.2, C.1 and F.1. Provide a DOC for CTS changes that result from adopting ISTS Required Actions for one inoperable instrument channel in each trip system for Table 3.3.5.1 functions that specify Actions B, C and F. l Detroit Edison Response:

l 3.3.5.1- 9 L.1,L.4 i Comment: DOCS L.1 and L.4 address murtiple changes to CTS 3.3.3, action c, Table 3.3.3-1, I

Actions 30 and Action 31 requirements. The change discussion is too general to establish a clear safety basis conclusion for each CTS change resulting from adopting ITS actions (i.e., the !

DOC does not explain what changed and why there is no safety impact). Provide a re/ised i CTS markup to clearly show the translation of CTS actions into ITS actions. Ensure the DOCS 1 justify each proposed change.

Detroit Edison Response:

1 3.3.5.1-10 2

A.8 l

Comment: ITS markup shows that Condition F.1 is derived from CTS Action 30.b. This does not agree with stritements in A.8 and the CTS markup does not show F.1 as included in the A.8 l 3 change. Rev' te DOC A.8 change discussion and include specific discussion of the CTS to ITS l changes addressed by A.8 together with a safety basis conclusion.

] Detroit Edison Response:

3.3.5.1-11 A.10 Comment: DOC A.10 addresses CTS 3.3.3-1 Action 30.a requirements for the ADS to declare the ECCS system inoperable. Action 30.b also applies to ADS action requirements to declare the ECCS inoperable. Action 30.b is not discussed. Revise A.10.

Detroit Edison Response:

h 3.3.5.1-12 LA2 Comment: CTS Table 3.3.3-1 Functions ic,2.c,2.d,4.d and 4.e state the Allowable Value

. limits as " decreasing." This does not represent a design detail that can be relocated. Provide a j DOC for eliminating this TS limit.

l Detroit Edison Response:

3.3.5.1-13 LC.1 j Comment: CTS Table 3.3.3-1 Footnote (a) provides a testing allowed outage time before j channels are declared inoperable and TS actions are required. ITS allowances are less j restrictive than CTS allowances for HPCI Functions 3.c,3.f,4.h, and 5.h based on topical report i

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fermi \rai\33.R0 13 November 17,1998 4

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'. 1 NEDC-30936-P-A. Provida a licensa amindm:nt citation for Fcrmi-2 that approvtd TS bistd on NEDC-30936-P-A.

Detroit Edison Response:

3.3.5.2- 1 LA.3 Comment: RCIC manual initiation functions are included in CTS. The ITS also requires these functions to preserve the overall redundancy and diversity included as part of the licensing basis of Fermi 2. Revise the ITS to include manualinitiation functions. (See also RAls 3.3.5.2-1 and 5.3.6.1-7)

Detroit Edison Response:

3.3.5.2- 2 Comment: CTS Action 50 is shown to become ITS Conditions B, C and E. CTS Action 50.b applies to inoperable channels in both trip systems. The ITS requirements for one inoperable channel in both trip system requires tripping the channels within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (B.2) or declare the RCIC system inoperable (E.1). The ITS requirement for more than one inoperable channel in both trip system is to declare RCIC inoperable (B.1). Provide a DOC for TS changes that result from adopting ISTS Required Action B.2 for one inoperable Level 2 instrumentation channel in each trip system.

Detroit Edison Response:

1 3.3.5.2- 3 ITS SR 3.3.5.2.3 Comment: STS SR 3.3.5.2.3 requires calibration of certain ECCS trip units every 92 days.

ITS SR 3.3.5.2.3 changes the surveillance requirement to " verify the trip unit setpoint" every 92 days. This requirement originated in CTS Table 4.3.5.1-1 as footnote #, to verify trip unit setpoints as part of a CHANNEL FUNCTIONAL TEST. It is assumed that the CTS CHANNEL FUNCTIONAL TEST provides instructions for out-of-tolerance trip settings, however, ITS SR 3.3 5.2.3 only requires verification of trip setpoints as a stand-alone requirement. The STS SR 3.3.5.2.3 requirement to " calibrate" the trip units is a more correct translation of the CTS requirement. Provide additional discussion and justi5 cation for the STS deviation. (RAls ,

3.3.1.1-22, 3.3.5.1-1, 3.3.5.2-3, 3.3.6.1-3, 3.3.6.2-1, and 3.3.7.1-2 are related.) ,

Detroit Edison Response:

3.3.6.1 - 1 A.4 Comment: Revise /t 4 to agree with CTS markup by discussing that the directions for compliance contained in CTS 3.3.2, Actions b, b.1, b.2 and c as well as footnote

are provided for inoperable channels in one trip system and in two trip systems. (See also RAI 3.3.6.2 2)

Detroit Edison Response:

3.3.6.1- 2 LA.1 Comment: CTS Table 3.3.2-1 Function 2.a, RWCU Differential Flow - High footnote # states that the function has a time delay of 45 seconds. DOC LA.1 states that the allowable value is actually 48 seconds and that 45 seconds is considered a r ominal value which is relocated to the TRM. ITS Table 3.3.6-1 Function 5.a, RWCU Differential Flow - High does not specify a time delay of either 48 seconds or 45 seconds. This value is not specified in ITS 3.3.6.1 Bases.

Provide discussion and justification for proposed changes to CTS time delay requirements.

Detroit Edison Response:

3.3.6.1 3 ITS SR 3.3.6.1.3 Comment: ISTS SR 3.3.6.1.3 requires calibration of certain PCI trip units every 92 days. ITS SR 3.3.6.1.3 changes the surveillance requirement to " verify the trip unit setpoint" every 92 days, fermi \rai\33.R0 14 November 17,1998

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l* This rsquirsmant originat:d in CTS Tabla 4.3.2.1-1 as footnota #, to vsrify trip unit s:tpoints as

, part of a CHANNEL FUNCTIONAL TEST. It is assumed that the CTS CHANNEL

! FUNCTIONAL TEST provides instructions for out-of-tolerance trip settings, however, ITS SR 3.3.6.1.3 only requires verification of trip setpoints as a stand-alone requirement. The ISTS SR

3.3.6.1.3 requirement to " calibrate" the trip units is a more correct translaiion of the CTS

requirement. Provide additional discussion and justification for the STS deviation, or implement

the STS presentation of the surveillance requirement. (RAls 3.3.1.1 22, 3.3.5.1-1, 3.3.5.2-3,

! 3.3.6.1-3, 3.3.6.2-1, and 3.3.7.1-2 are related.)

I Detroit Edison Response:

2 3.3.6.1- 4 DOC LC.1

"first bullet"- CTS 3.3.2 Action b.1 requires compensatory action be completed in 6 j hours with inoperable channel (s) in one trip system, when tripping that channel would j cause an isolation, while Action b.2 requires compensatory action be completed in 12 or

. 24 t ours with inoperable channel (s) in one trip system, when tripping that channel would not cause an isolation. ITS 3.3.6.1 Action A allows either 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for one 4 inoperable channel in one trip system regardless of the effect of tripping that channel.

4 j LC.1 concludes that these increased allowed Completion Times and testing times are

consistent with the allowed outage times and testing allowances reviewed and approved 1

in NEDO-30851-P-A, Supplement 2, " Technical Specification Improvement Analyses for i BWR isolation Instrumentation Common To RPS And ECCS Instrumentation," and are j considered appropriate based on the remaining capability to trip, the diversity of the sensors available to provide the trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event l requiring the initiation of an isolation. Since a loss of trip function continues to require immediate (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) restoration (ITS Action C), this extension to 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for

! inoperabilities that still retain trip capability will not adversely affect safety.

! Comment: STS LCO 3.3.6.1 includes repair allowances based on adopting NEDO-30851-P-A.

1 Confirm that use of NEDO-30851 is approved for Fermi 2 CTS and provide topical report NEDO-30851 citations to show that the topical report does not credit a 6-hour repair AOT for channels that when tripped would cause an isolation. Revise DOC LC.1 to replace reference to ITS Action B with Action C. (See also RAI 3.3.6.2-4)

Detroit Edison Response: -

3.3.6.1-5 DOC LC.1 "second bullet" - CTS 3.3.2 Action c requires placing one trip system in trip within i hour when both trip systems have inoperable channel (s); and furthermore, requires commencing the actions specified in CTS Table 3.3.2-1 within the same hour. ITS 3.3.6.1 Action C addresses the same condition of inoperable channels in both trip systems (i.e., this would result in a loss of automatic isolation capability) allows restoration of isolation capability, without requiring additional actions. Furthermore. after restoring isolation capability (e.g., tripping one trip system with inoperable channel (s)),

ITS 3.3.6.1 Action A would continue to apply to any remaining untripped channels; thereby allowing 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to commencing additional actions.

LC.1 concludes that these increased allowed Completion Times and testing times are consistent with the allowed outage times and testing allowances reviewed and approved in NEDO-30851-P-A, Supplement 2, " Technical Specification Improvement Analyses for BWR isolation instrumentation Common To RPS And E CCS Instrumentation," and are fermi \rai\33.R0 15 November 17,1998

considir2d appropriata bis:;d on tha rzmaining capibility to trip, tha divsrsity of th3 sensors available to provide the trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of an isolation. Since a loss of trip function continues to require immediate (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) restoration (ITS Action C), this extension to 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for inoperabilities that still retain trip capability will not adversely affect safety.

l Comment: Revise DOC LC.1 to replace reference to ITS Action B with Action C. LC.1 states that ITS 3.3.6.1 Action C addresses the same condition of inoperable channels in both trip systems (i.e., this would result in a loss of automatic isolation capability) allows restoration of isolation capability, without requiring additional actions. Explain how ITS Action B address the

, same condition of inoperable channels provided for in CTS Action e in terms of the isolation l logic configurations for MSL, PCI, HPCI, RCIC, RWCU and Shutdown Cooling functions l specified in ITS Table 3.3.'6.1-1. Provide safety basis discussion to show that remaining capability to trip, the diversity of the sensors available to provide the trip signals, the low .

l probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low l probability of an event requiring the initiation of an isolation are adequate to ensure safe i

operation of the plant for each proposed change. (See also RAI 3.3.6.2-5)

Detroit Edison Response:

3.3.6.1 6 LA.2 Comment: CTS 4 3.2.3 requires performance of a Response Time Test at least once per 18 months on "each" Primary Containment isolation (PCI) Function. The requirement to perform Response Time Testing on each PCI function is deleted in the ITS. DOC LA.2, states that the requirements are relocated to the TRM and justifies the relocation on the fact that there is no acceptance criteria for these requirements contained in the TRM. This DOC does not adequately justify the relocation of CTS requirements. A technical basis for the removal of CTS requirements to perform response time testing on "each' function to ITS requirements to perform response time testing on selected functions should be discussed in a revised LA.2 DOC. (See also RAI 3.3.6.2-3)

Detroit Edison Response:

3.3.6.1- 7 LA 6 Comment: PCI instrumentation manual initiation functions are included in CTS. The ITS a!so requires these functions to preserve the overall redundancy and diversity included as part of the licensing baris of Ferrri 2. Revise the ITS to include CTS manual functions. (See also RAls 3.3.5.2-1 and 3.3.6.1-7)

Detroit Edison Response:

3.3.6.1-8 A.12 Comment: Retain the CTS presentation of minimum operable channels per trip system in the ITS for Functions i.e and 1.g. Relocate the CTS Table 3.3.2-1 footnote (c) to the Bases. (See also RAI 3.3.6.1-16)

Detroit Edison Response:

3.3.6.1- 9 A.13 Comment: Provide a diagram showing the calentation of the sensors in the areas monitored by these instrument channels.

Detroit Edison Response:

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fermi \rai\33.R0 16 November 17,1998

3.3.6.1-10 A.14 Comment: CTS are changed to add two required channels for the SLCS instrument function.

This is an additional requirement and is more restrictive that current TS. Resubmit A.14 as an M-DOC.

Detroit Edison Response: .

3.3.6.1-11 L1 Comment: Revise DOC L.1 to provide safety basis justification for the proposed change to delete Mode 3 requirements for SLCS.

Detroit Edison Response:

3.3.6.1 12 L.2 Comment: CTS Table 3.3.2-1, item 2.d ACTION 23 requires that if there is a loss of RWCU

. Isolation on a SLCS initiation, close the affected system (RWCU) isolation valves within one

. hour and (empha. sis added) declare the affected system inoperable. ITS 3.3.6.1 Action H (STS Action 1) requires for the same SLCS initiation condition, either isolate the RWCU system or declare the SLCS system inoperable. DOC L.2 incorrectly cites the CTS as only requiring isolation of the affected system. Correct the DOC L.2 citation of CTS requirements.

Detroit Edison Response:

3.3.6.1-13 L.3 Comment: DOC L.3 discusses elimination of CTS requirements to have the RHR shutdown cooling isolation instrumentation for Level 3 operable in Modes 1 and 2. Level 3 is noted in Table 3.3.2-1 to be a common instrument with the RPS which requires operability of this function in Modes 1 and 2. DOC L.3 does not discuss the safety importance of the isolation requirement (Action 25) and why this particular protection is not required for safe operation of the plant. Revise L.3 to provide analysis of the safety impact of proposed changes to eliminate the CTS actions for Modes 1 and 2 which require deactivation and isolation of RHR shutdown coohng isolation valves within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Detroit Edison Response:

3.3.6.1-14 L.4 Comment: DOC L.4 applies to RHR shutdown cooling instrumentation changes to CTS action requirements for Mode 3 which currently require deactivation and isolation of RHR shutdown cooling isolation valves within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The DOC analysis should specifically state that an option is provided to allow repair of the instrumentation if isolation is not desired. The L.4 DOC should link the safety basis justification specifically to Mode 3.

Detroit Edison Response:

3.3.6.1-16 L.6 Comment: Add a citation for Level 3 (CTS Table 3.3.2-1, Function 5.a) to this DOC becauss Action 25 also applies to this function.

Detroit Edison Response:

3.3.6.1-16 A.12 Comment: Table 3.3.2-1, footnote (c) is deleted. Provide an LA-doc for this proposed change.

(See also RAI 3.3.6.1-8)

Detroit Edison Response:

fermi \rai\33.R0 17 November 17,1998

, 3.3.6.1-17 A.8 Camm:nt: This DOC discussIs extInding CTS rsquirsmsnts to isolate MSIVs to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months fram 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months as an administrative change based on the licensee's interpretation of compliance with

their CTS. Provide documentation of staff approval of the TS interpretation presented in DOC A.8; otherwise, provide an L-DOC for this change. (See also RAI 3.3.1.1-4) l Detroit Edison Response

4 3.3.6.1-18 LR.1 Comment: CTS Table 3.3.2-1, footnote " establishes applicability limits for condenser high

, pressure in Modes 2 and 3. The isolation function may be bypassed when the condenser pressure is above the trip setpoint during a reactor startup or shutdown. CTS Table 4.3.2.1-1,

footnote " establishes surveillance applicability limits for condenser high pressure in Modes 2 and 3. Footnote " requires the SRs to be current unless the function is bypassed. DOC LR.1 discusses combining these allowance into one phrase as ITS Table 3.3.6.1-1 Note (a), but does not justify the equivalency of the two phrases. The proposed ITS footnote for the condenser

high pressure isolation applicability, becomes, "When not bypassed under administrative 4

control." Revise the ITS to adopt Table 3.3.2.-1, footnote ".

Detroit Edison Response:

i j 3.3.6.1 19 A.11 i Comment: ITS proposes to replace CTS channel functional testing of RWCU isolation on

initiation of SLCS with a LSFT because the LSFT is already required by CTS and channel

functional testing a manual actuation channel is completely met by the requirements of a LSFT.

Provide an analysis to support the position that all CFT requirements are met by the LSFT.

Detroit Edison Response:

! 3.3.6.1- 20 JFD P.1 l Comment: ITS Bases insert B 3.3.6.1-9 states that HPCI and RCIC steam supply line pressure-i Iow signals are combined with ECCS drywell pressure-high signals to isolate HPCI and RCIC l turbine exhaust line vacuum breaker (ITS functions 3.c and 4.c). Provide supporting i arguments to justification P.1 for not including drywell pressure-high (ISTS function 3.d and 4.d) in ITS Functions which isolate HPCI and RCIC.

l Detroit Edison Response:

3.3.6.21 ITS SR 3.3.6.2.3 Comment: SR 3.3.6.2.3 requires calibration of certain secondary containment isolation 4

instrument trip units every 92 days. ITS SR 3.3.6.2.3 proposes to change the surveillance

] requirement to " verify the trip unit setpoint" every 92 days. This requirement originated in CTS

} Table 4.3.2.1-1 as footnote #, to verify trip unit sNoints as part of a CHANNEL FUNCTIONAL TEST. It is assumed that the CTS CHANNEL FUNCTIONAL TEST provides instructions for 1 out-of tolerance trip settings, however, ITS SR 3.3.6.2.3 only requires verification of trip l setpoints as a stand-alone requirement. The STS SR 3.3.6.2.3 requirement to " calibrate" the trip units is a more correct translation of the CTS requirement. Provide additional discussion and justification for the STS deviation. (RAls 3.3.1.1-22,3.3.5.1-1,3.3.5.2-3,3.3.6.1-3, 3.3.6.2-1, and 3.3.7.1-2 are related.)

Detro!t Edison Response:

) 3.3.6.2- 2 DOC A.4 i Comment: Revise DOC A.4 to agree with CTS markup by discussing that the directions for

{ compliance contained in CTS 3.3.2, Actions b, b.1, b.2 and c as well as footnot3

are provided

_ for inoperable channels in one trip system and in two trip systems. (See also RAI 3.3.6.1-1) j Detroit Edison Response

fermi \rai\33.R0 18 November 17,1998 4

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l 3.3.6.2-3 LA.2 Comment: 4.3.2.3 requires performance of a Response Time Test at least once per 18 months on "each' Primary Containment Isolation (PCI) Function. The requirement to perform Response Time Testing on each PCI function is deleted in the ITS. DOC LA.2, states that the requirements are relocated to the TRM and justifies the relocation on the fact that there is no acceptance criteria for these requirements contained in the TRM. This justification is not adequate for this Less Restrictive change from CTS requirements to perform response time testing on "each' function to ITS requirements to perform response time testing on selected functions. (See also RAI 3.3.6.1-6)

Detroit Edison Response:

3.3.6.2- 4 DOC LC.1 "first bullet"- CTS 3.3.2 Action b.1 requires compensatory action be completed in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months with inoperable channel (s) in one trip system, when tripping that channel would cause an isolation, while Action b.2 requires compensatory action be ccmpleted in 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with inoperable channel (s) in one trip system, when tripping that channel would not cause an isolation. ITS 3.3.6.1 Action A allows either 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for one inoperabk channelin one trip system regardless of the effect of tripping that channel.

LC.1 concludes that these increased allowed Completion Times and testing times are consistent with the allowed outage times and testing allowances reviewed and approved in NEDO-30851 P-A, Supplement 2, " Technical Specification Improvement Analyses for BWR lsolation Instrumentation Common To RPS And ECCS Instrumentation," and art considered appropriate based on the remaining capability to trip, the diversity of the sensors available to provide the trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of an isolation. Since a loss of trip function continues to require immediate (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) rntoration (ITS Action C), this extension to 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for inoperabilities that still retain trip capability will not adversely affect safety.

1 Comment: STS LCO 3.3.6.2 includes repair allowances based on adopting NEDO-30851-P-A.

Confirm that use of NEDO-30851 is approved for Fermi 2 CTS and provide topical report NEDO-30851 citations to show that the topical report does not credit a 6-hour repair AOT for l

channels that when tripped would cause an isolation. (See also RAI 3.3.6.1-4)

Detroit Edison Response:

3.3.6.2-5 DOC LC.1 l "second bullet" - CTS 3.3.2 Action c requires placing one trip system in trip within 1

! hour when both trip systems have inoperable channel (s); and furthermore, requires commencing the actions specified in CTS Table 3.3.2-1 within the same hour. ITS 3.3.6.2 Action C addresses the same condition ofinoperable channels in both trip systems (i.e., this would result in a loss of automatic isolation capability) allows restoration of isolabon capability, without requiring additional actions. Furthermore, after

, restoring isolation capability (e.g., tripping one trip system with inoperable chmnel(s)),

I ITS 3.3.6.1 Action A would continue to apply to any remaining untripped channels; thereby allowing 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to commencing additional actions.

LC.1 concludes that these increased allowed Completion Times and testing times are i consistent with the allowed outage times and testing allowances reviewed and approved

! In NEDO-30851-P-A, Supplement 2, " Technical Specification improvement Analyses for fermi \rai\33.R0 19 November 17,1998

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

BWR isolition Instrumsntation Common To RPS And ECCS Instrumentation," and cra considered appropriate based on the remaining capability to trip the diversity of the sensors available to provide the trip signals, the low probabilitt of extensive numbers of inoperabilities affecting all diverse Functions, and the low pro'oability of an event requiring the initiation of an isolation. Since a loss of trip function continues to require immediate (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) restoration (ITS Action C), this extension to 12 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for inoperabilities that still retain trip capability will not adversely affect safety. !

Comme :t: LC.1 states that ITS 3.3.6.1 Action C addresses the same condition of inoperable channels in both trip systems (i.e., this would result in a loss of automatic isolation capability) allows restoration of isolation capability, without requiring additional actions. Explain how ITS I Action C address the same condition of inoperable channels provided for in CTS Action c in j terms of the isolation logic configurations for secondary containment functions specified in ITS Table 3.3.6.2-1. Provide safety basis discussion to show that remaining capability to trip, the ;

diversity of the sensors available to provide the trip signals, the low probability of extensive '

numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of an isolation are adequate to ensure safe operation of the plant for each proposed change. (See also RAI 3.3.6.1-5)

Detroit Edison Response:

3.3.S.2- 6 L.2 j DOC L.2 concludes that ITS Required Actions C.1.1 and C.2.1 implement CTS Table 3.3.2-1, Actions 24 and 27 to require Secondary Containment Integrity be established with standby gas l treatment operating. L.2 states that ITS Required Actions C.1.2 and C.2.2 provide options to I declare the associated secondary containment isolation valves inoperable and/or declare associated SGT subsystem inoperable. Further, L.2 concludes that these attemate Actions for the loss of secondary containment isolation function will ensure continued safe operation, consistent with the allowed actions for inoperabilities of the systems affected by the inoperable l instrumentation. Therefore, thic less restrictive change will have a negligible impact on safety.

Comment: ITS Actions provide three options to placing the plant in a safe condition if secondary containment isolation instrumentation cannot be restored to operable status or ,

tripped. The options are to isolate secondary containment, or declare the secondary CIVs inoperable and start one SGT subsystem or declare SGT inoperable. Revise DOC L.2 to ;

discuss the less restrictive ITS requirements that result from replacing the requirement to i establish Secondary Containment integrity with standby gas treatment operating to each of the requirements provided by ITS required actions C.1, C.2 and C 3. Additionally, L.2 needs to state why proposed ITS actions are safe, not simply provide a statement that ITS actions are safe.

Detroit Edison Response:

3.3.6.27 A.6 Comment: CTS Table 3.3.2-1 Action 27 allows an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months restoration period for the manual initiation function which is applied after a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance of CTS 3.3.2 Action b.1 thus :

providing an overall 14 hour1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months restoration time. ITS 3.3.6.2 Condition A allows for a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration time for this function and is consistent with the STS. DOC A.6 discusses this change as Administrative however this change is Less Restrictive. Provide additional discussion and justification for a less restrictive change to the restoration period for the manual l initiation function required by CTS Table 3.3.2-1 Action 27.

l Detroit Edison Response:

l fermi \rai\33.R0 20 November 17,1998

l d

l' 3.3.6.3- 1 JFD P.4, Comment: This DOC justifies adopting the 92-day test frequency for performing ITS SR 3.3.6.3.2 which requires a CFT on the portion of the LLS instrument channel that is outside of containment. The justification is that GENE-770 provides the industry a " standard time."

Presently there is no such required CTS test. In order to adopt GENE-770 test frequencies, provide an analysis similar to that required to adopt GENE-770, otherwise adopt the standard CFT 31-day test frequency.

Detroit Edison Response:

3.3.6.3- 2 JFD P.4 Comment: The LLS instrumentation Bases state that LLS valves actuate on a 2-out-of-2 channellogic on high pressure once the valves are armed. Revise ITS Table 3.3.6.3-1 required channels for Function 1, Reactor Steam Dome Pressure - High to 2 per LLS valve from 1 per LLS valve.

Detroit Edison Response:

3.3.6.3- 3 Beyond Scope DOC M.1 ITS Condition B Comment: The M-DOC can be used to justify adding functions to the LLS Instrumentation LCO, but additionaljustification is needed for proposed ITS required actions B.1, the note to B.1 and B.2. The proposed TS would allow operation indefinitely with 11 of 15 valves inoperable if at least the lowest SRV setpoint group is operable.

Detroit Edison Response:

3.3.7.1- 1 DOC M.4 JFD P.4 Comment: ITS Table 3.3.7.1-1 lists the requirements for the CREFS instrumentation. Function 1 is Reactor Vessel Water Level- Low, Low Level 2 , Function 2 is drywell pressure and Function 3 is Fuel Pool Ventilation Exhaust - Radiation High. The FSAR assumes these functions initiate CREFS, but they do not appear in the CTS. The ITS assigns the STS 24-hour repair AOT (Condition B) and 6-hour test AOT for each function and a 92-day test frequency for Functions

.1 and 2. In the STS the 24-hour repair AOT, the 92-day surveillance test interval and the 6-hour test AOT are based on topical report GENE-770. The ITS justifications discussed in DOC M.4 and JFD P.4 do not establish a clear safety-basis for proposed CTS changes. M.4 is a general statement that the added functions do not impact safe operation of the plant. DOC P.4 states that GENE-770-01 in not adopted for Function 1 of CREFS. This P-4 statement implies that GENE-770 is adopted for Functions 2 and 3 since these functions share Condition B which allows a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restoration time. Provide justification for proposing a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months repair AOT and 6-hour test AOT for Functions 1,2 and 3. Provide justification for proposing a 92 day test frequency for Functions 1 and 2.

Detroit Edison Response:

3.3.7.1- 2 ITS SR 3.3.7.1.3 DOC M.4 JFD P 4 Comment: STS SR 3.3.7.1.3 requires calibration of certain CREF System trip units every 92 days. The corresponding ITS SR 3.3.7.1.3 changes the surveillance requirement to " verify the trip unit setpoint" every 92 days. CTS Table 4.3.7.1-1 did not provide specific requirements for calibrating these trip units (or the additional ITS Functions 1,2, and 3). However, the CTS fermi \ral\33.R0 21 November 17,1998

j rsquires a CHANNEL FUNCTIONAL TEST for thiss trip functions in oth3r ECCS systems, including instructions for out-of-tolerance trip settings. ITS SR 3.3.6.2.3 only requires verification of trip setpoints as a stand-alone requirement. The STS SR 3.3.6.2.3 requirement to " calibrate" the trip units is a more correct translation of CTS requirements. Provide additional discussion and justification for the STS deviation, or implement the STS 3.3.7.1.3 presentation of the st.rveillance requirement. (RAls 3.3.1.1 22,3.3.5.1-1,3.3.5.2-3,3.3.6.1-3,3.3.6.2-1, and 3.3.7.1-2 are related.)

Detroit Edison Response:

3.3.7.1- 3 LR.1 Comment: CTS Table 3.3.7.1-1 Action 70.a for one inoperable makeup air radiation channel requires placing that channel in the downscale tripped condition. ITS 3.3.7.1 Actions do not include this requirement for Function 4 as discussed and justified by DOC L.R.1. DOC LR.1 states this action is proposed to be administratively controlled by plant personnel. DOC LR.1 restates CTS actions, describes the system operation on high and downscale trips, then states that the "downscale" trip is not an assumed or credited function. Based on the information in this discussion, the downscale trip is a design feature of the system used by CTS for remedial actions thus, proposed changes to modify CTS requirements is not acceptable. Revise the ITS to adopt CTS or NUREG-1433.

Detroit Edison Response:

3.3.7.1 4 L.1 Comment: Revise L.1 to make a clear safety basis argument for changing CTS Mode 5 requirements to the ITS applicability requirements that replace Mode 5. What is the safety analysis that supports the " expected potential releases" justification.

Detroit Edison Response:

3.3.7.1-5 LA.1 Comment: Provide a unique LA.1 DOC for LCO 3.3.7.1which discusses the proposed change to eliminate the alarm setpoint. The DOC discussion incorrectly addresses isolation instrumentation.

Detroit Edison Response:

3.3.7.1 6 P.1, A.4 Comment: Changes to NUREG-1433 (STS) Conditions B.1, B.2, C.1 and C.2 required actions are generic and justifications for NUREG/ CTS changes are not complete. The proposed ITS Babes adopt the basis statements provided for the STS Actions without adopting the STS Actions. The proposed ITS Action B.2 24-hour repair AOT is retained from the STS but the STS action to " trip the channel" is replaced with " restore the channel." The 6-hour repair AOT in proposed ITS Action C.2 is retained from the STS but the STS action to " trip the channel" is replaced with " restore the channel." The STS actions are based on the remaining redundancy and diversity of the instrumentation available to provide CREFS actuation. The STS repair AOTs are based on topical reports. The topical reports are referenced in the Bases without a DOC reference to a staff SE approving use of the topical reports for Fermi-2. Therefore, these preferences to changing the NUREG are not acceptable based on current documentation.

Detroit Edison Response:

3.3.8.11 LA.1 Comment: CTS 3.3.3 requires that ECCS actuation instrumentation trip setpoints to be set l within the Trip Setpoint column values of CTS Table 3.3.3-2 (which also includes trip setpoints and allowable values for LOP instrumentation). Additionally, CTS 3.3.3 Action a defines a fermi \rai\33.R0 22 November 17,1998

channel to be in percbla when the trip setpoint is less conssrvativs than tha trip sttpoint. CTS 3.3.3 Action a requires that an inoperable LOP instrument channel setpoint be restored consistent with the trip setpoint value. ITS 3.3.8.1 proposes to relocate trip setpoints and the 120V-basis allowable values to the Technical Requirements Manual (TRM), which requires revisions be controlled by 10 CFR 50.59. DOC LA.1 states that the trip setpoint and 120V-basis allowable values are established based on a combination of instrument design factors, environmental factors, and the allowable value is conservatively derived from the value assumed in the safety analyses. The staff cannot agree that the proposed relocation of the 120 voit basis TS will provide adequate protection of the public health and safety since the requirement for instrument channel operability at the 120 volt level is required by the criteria in 10 CFR 50.36. Revise the ITS to include 120 voit basis LOP instrumentation.

Detroit Edison Response:

3.3.8.2- 1 L.3 -

j Comment: Revise L.3 to clarify the justification regarding " intermediate step" and ' additional actions are required."

Detroit Edison Response:

l l

l

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i.

formi\rai\33.R0 23 November 17,1998

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

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I Proposed Request For Additional Information For Fermi i

Technical Specifications Conversion, Section 3.8. Electrical Power

)

General Note: Throughout this request for additional information (RAl), references to a standard technical specification (STS) mean the standard version of the TS published by the l 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.

3.8.1-1 Current technical specification (CTS) 3M.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 l Bases for ITS 3.8.1 Required Action A.4, STS Bases markup i page B 3.8-10 insert 3a l Action b.2 for CTS 3/4.8.1.1 requires verifying within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, that combustion turbine-generator (CTG) 11-1 is operable. In the event that this requirement cannot be met, Action b.3 for CTS 3/4.8.1.1 requires restoration of CTG 11-1 to Operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Required Action A.4 for ITS 3.8.1 requires the licensee to determine CTG 11-1 is available with a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of Condition A concurrent with CTG 11-1 not available. Deletion of the CTS requirement to verify 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of determining its non-availability, but there is no requirement to determine availability at the time the emergency diesel generator (s) (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.5.

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 Note should be retained.

DECO Response:

ENCLOSURE 2

i 3.8.1-3 ITS SR 3.8.1.2 CTS 4.8.1.1.2.a.4 Bases for ITS SR 3.8.1.2, STS Bases markup page B 3.8-16 STS SR 3.8.1.2 CTS 4.8.1.1.2.a.4 requires the diesel generator start from ambient conditions. This requirement has not been retained in corresponding ITS SR 3.8.1.2, which does not specify start conditions.

STS SR 3.8.1.2 requires each DG start from standby conditions.- The Bases for ITS SR 3.8.1.2 states, "... the EDG are staried anywhere from standby to hot conditions ...." The CTS markup does not show this proposed change, and no justification has been provided to support the proposed change. Revise the submittal to show the proposed change on the CTS markup, and provide the appropriate justification.

Deco Response:

3.8.1-4 Bases Pg. B 3.8-16 ITS SR 3.8.1.2 This Bases section includes 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 could be acceptable if the licensee agrees to retain the Note in SR 3.8.12.

(See comment 3.8.1-2.) .

DECO Response:

3.8.1-8 ITS/STS SR 3.8.1.7 i

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:

l 3.8.1-6 DOC L.5 ITS 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 1

. 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 5 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

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

4 l

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3 voltage a 3740 V and a frequency a 58.8 in s 10 seconds. This proposed change appears to be 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. See the following (related) question.

Deco Response:

3.8.1-7 DOC L.4 ITS SR 3.8.1.18 CTS 4.8.1.1.2.f STS SR 3.8.1.20 STS SR 3.8.1.20 requires verifying each EDG achieves frequency a [58.8) Hz and s [61.2] Hz This requirement has not been adopted in corresponding ITS SR 3.8.1.18, which requires verifying each EDG achieves frequency a 58.8 Hz. This is a proposed change relative to corresponding CTS 4.8.1.1.2.f, which requires verifying that all four diesel generators accelerate to at least g00 rpm. DOC L.4 states that 900 rpm corresponds to a generator frequency of 60 Hz. This proposed change appears to be beyond the conversion review scope (i.e., it corresponds to neither the CTS or STS) and has not been identified as such by the licensee. If the licensee was attempting to incorporate TSTF 163, Rev. 2, portions of the changes associated with the TSTF were not incorporated and the TSTF is not mentioned.

DECO Response:

3.8.1-8 STS SR 3.8.1.8 JFD P.1 The gencic 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-

y s 3.8.1-9 DOC LA.7 ITS SR 3.8.1.8 Bases for ITS SR 3.8.1.8, STS Bases markup page B 3.8-21 CTS 4.8.1.1.2.e.2 ITS SR 3.8.1.8 requires verifying the frequency is s 66.75 Hz following a load rejection. CTS 4.8.1.1.2.e.2 requires maintaining the engine speed less than the nominal speed plus 75% of

- the difference between nominal speed and the overspeed trip setpoint or 115% of nominal speed whichever is lower. DOC LA.7 states that the most limiting value is presented in the ITS.

DOC LA.7 does not fully explain why 66.75 Hz is an acceptable value. Revise the submittal to provide the appropriate justification for the proposed change.

DECO Response:

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

However, neither ITS SR 3.8.1.7 nor its Bases reflect this portion of the note. The note to the SR 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 period with the DG running at synchronous speed).

DECO Response:

3.8.1-12 STS Bases Markup, Pgs. B 3.8-17 and B 3.8-18 STS/ITS SR 3.8.1.3 and SR 3.8.1.2 There are two lasues:

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

i !

Letter) 94-01" to ' Regulatory Guide 1.9." The staff is not aware of any reference to Regulatory Guide 1.9 in GL 94-01. This proposed addition should be deleted,

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

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l t 3.8.1-13 CTS 4.8.1.1.2.e.8 l- Bases Pg. B 3.8-27 ITS SR 3.8.1-13 The SR does not contain a requirement to conduct this SR at a specified power factor. l 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 required, the SR is normally conducted at some target power factor?

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 Bases 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded a 2500 kW. The remainder of Note i states, " Momentary transients outside of load range do not invalidate this test," which is a proposed change relative to footnote

for CTS 4.8.1.1.2.e.8. 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:

3.8.1-15 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:

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3.8.1-16 DOC A.8 ITS SRs 3.8.1.10, 3.8.1.11, 3.8.1.17, and 3.8.1.18 Note Bases for ITS SRs 3.8.1.10, 3.8.1.11, 3.8.1.17, and 3.8.1.18 CTS 4.8.1.1.2.e.4, 4.8.1.1.2.e.5, 4.8.1.1.2.e.6, and 4.8.1.1.2.f STS SRs 3.8.1.11,3.8.1.12, and 3.8.8.19 Note 1 STS SR 3.8.1.20 Note Note 1 for STS SR 3.8.1.11, 3.8.1.12, and 3.8.8.19, and the Note for STS SR 3.8.1.20 state, "All DG starts may be preceded by an engine prelube period." This has been adopted as the Notes for corresponding ITS SR 3.8.1.10,3.8.1.11,3.8.1.17, and 3.8.1.18. These proposed changes have been categorized as administrative. In DOC A.8 the licensee indicated that this is consistent with the intent and interpretation of the CTS. However, the staff notes that while CTS l 4.8.1.1.2.a.4 surveillance has a footnote that specifically allows an engine prelube period, CTS

, 4.8.1.1.2.e.4,4.8.1.1.2.e.5,4.8.1.1.2.e.6, and 4.8.1.1.2.f surveillances do not. The proposed changes are less restrictive. Revise the submittal to provide the appropriate justification for the ;

proposed changes. l DECO Response:

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 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 Aanalysis 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 submittal to include an ITS specification and bases that address these requirements, or alternatively, incorporate these 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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I l 3.8.2-2 CTS 4.8.1.2 DOC L.1 STS/ITS SR 3.8.2.1 l 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 that ST.S 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 I performed. In the ITS, this note is modified to indicate that SRs 3.8.1.2,3.8.1.3, and 3.8.1.7 l

through 3.8.1.17 are not required to be performed. The ITS note relieves the licensee from the l requirement to perform three SRs (3.8.1.2,3.8.1.7, and 3.8.1.11) that are required by the STS.

l DOC L.1 discusses the exclusion of SR 3.8.1.18, a change from the CTS. DOC L.1 also states )

I that the ITS note is consistent with 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, deenergizing a required onsite i 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 fallinto ihis category. Modify the note to conform to the STS or l

provide additional justification for the exception for these three SRs.

DECO Response:

3.8.2-3 JFD P.1 ITS 3.8.2 Actions Note I Bases for ITS 3.8.2 Actions, STS Bases markup page B 3.8-38 (insert)

CTS 3.8.1.2 Action b Bases for ITS 3.8.2 Required Action A.2.2, STS Bases markup page B 3.8-39 Action b for CTS 3.8.1.2 states,"The provisions of Specification 3.0.3 are not applicable." This allowance has been retained as the Actions Note for corresponding ITS 3.8.2. The Bases for ITS 3.8.2 Required Action A.2 states that suspension of that activity shall not preclude completion of actions to establish a safe conservative condition. The Bases for ITS 3.8.2 Actions (Insert B 3.8.2-1) states, "... Inability to suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown." Revise the submittal to expand the Bases to provide examples of events that would result in the inability to suspend movement of irradiated fuel, in order to strengthen the Bases description. (See also RAls 3.8.5-3 and 3.8 'L2.)

DECO Response:

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3.8.3-1 Bases for ITS SR 3.8.3.4, STS Bases markup page B 3.8-48 Bases for STS SR 3.8.3.4

The Bases for STS SR 3.8.3.4 states, "[A start cycle is defined by the DG vendor, but usually is j measured in terms of time (seconds of cranking) or engine cranking speed.]" This has not been j adopted in the Bases for corresponding ITS SR 3.8.3.4. No justification has been provided to i support this proposed difference. Revise the submittal to provide the ap: .ropriate justification, or expand the Bases to address this issue.

4 DECO Response:

, 3.8.3-2 JFD P.4 l Bases for ITS SR 3.8.3.3, STS Bases markup page B 3.8-46 Bases for STG SR 3.8.3.3 The Bases for STS SR 3.8.3.3 states, "... but in no case is the time between receipt of new fuel l and conducting the tests to exceed 31 days." This has been modified in the Bases for cc.vesponding ITS SR 3.8.3.3 yhich states, "... but in no case is the time between sampling

(and associated results) of new fuel and addition of new fuel oil to the storage tank to exceed l 31 days." JFD P.4 does not explain why this proposed difference is acceptable. Revise the i

submittal to provide the appropriate justification, or conform to the STS. A time line i representation of the STS and the ITS Bases descriptions should accompany the justification.

j DECO Response:

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3.8.3-3 JFD P.4 Bases for ITS SR 3.8.3.3, STS Bases markup pages i

B 3.8-47 and B 3.8-47 (insert)

Bases for STS SR 3.8.3.3 i

j The isases for STS SR 3.8.3.3 states, "Within [31] days following the initial new fuel oil sample,

! the fuel oilis 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 i has ir;serted, "These additional analyses are required ... to be performed within 31 days

following sampling and addition." The ' sampling and addition";oferred to in the Bases insert for I 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 submittet to provide the appropriate justification, or conform to the STS. A time line j.. representation of the STS and the IT G dases descriptions should accompany the justification.

1 DECO Response:

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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 Tne 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 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 Staggered Tect Basis (emphasis added). The CTS 3.8.1 markup ;

(19 cussed the removal of the staggered test basis in DN L.3 for that specification. Revise the l subnittal to provide appropriate justification or reference to the removal of the staggered test i basis for ITS 3.8.3 SRs.

DECO Response:

3.8.4-1 CTS 3.8.2.1 Action b, footnote # l The CTS markup indicates that this CTS permissive is to be moved to ITS Section 3.7. ,

I However, a quick review of 3.7 showed that the CTS battery charger operability associated with emergency equipment cooling water (EECW) system 's deleted. The acceptability of this change and any impact on Section 3.8 will be addressed during the review of Section 3.7.

DECO Response: N/A ,

l 3.8.4-2 ITS/STS SR 3.8.4.3 !

JFD C.1 CTS 4.8.2.1.c.1 i

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 degradatiori. 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:

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 demonstrata d to be equal to (or greater that)

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.- j 80% of rating. From this it is concluded that the battery has capacity to power all DC loads for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months even when degraded to 80% of rated capacity. If this is the case, what is the justification for deleting the Bases material that discusses this capability? JFD P.1 does not provide an adequate justification, i

DECO Response: i 3.8.4 4 CTS 3.8.2.1 Action b, footnote #

Deletion of footnote # will be reviewed as part of the staff review of Section 3.7. Any changes required in Section 3.8 will be identified at that time.

\

DECO Response: N/A

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3.8.5-1 STS/ITS 3.8.5 Insert 3.8.5-1 ,

JFD P.4 DOC M.1 i Bases for ITS 3.8.5, STS Bases markup page B 3.8-60 CTS 3.8.2.2 requires Division I or Division ll of the DC electrical power sources to be ,

OPERABLE as a minimum. The staff interprets this to mean that Division I and_ Division ll may be required at times. STS 3.8.5 requires DC electrical power subsystems to be OPERABLE to l

support DC electrical power distribution subsystems required by STS 3.8.10 (ITS 3.B.8). In the staffs view, CTS 3.8.2.2 and STS 3.8.5 are 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 l subsystems to be powered from either a battery or a charger, but not both. The proposed ITS does not reflect either the CTS or the STS and is, therefore, considered a beyond scope issue.

DECO Response:

3.8.5-2 Bases Pg. B 3.8-60 and 3.8-61 STS 3.8.5, Insert B 3.8.5-1 and insert B 3.8.5-2 JFD P.3 Changes to the limiting condition for operation (LCO) Bases and the Actions Bases are l Indicated as being justified by JFD P.3. In the list of JFDs, however, P.3 is indicated as not

i. used. What is the appropriate justification for these Bases changes? Note that the changes to i 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.

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DECO Response:

3.8.5-3 JFD P.1 ITS 3.8.5 Actions Note Bases for ITS 3.8.5 Actions, STS Bases markup page B 3.8-61 (insert)

CTS 3.8.2.2 Action b Bases for ITS 3.8.5 Required Action A.2.2, STS Bases markup page B 3.8-62 ,

Action b for CTS 3.8.2.2 states, "The provisions of Specification 3.0.3 are not applicable." This allowance has been retained as the Actions Note for corresponding ITS 3.8.5. The Bases for ITS 3.8.5 Required Action A states that suspension of that activity shall not preclude completion of actions to establish a safe conservative condition. The Bases for ITS 3.8.5 Actions (Insert B 3.8.5-2) states, "... inability to suspend movement of irradiated fuel assemb les would not be sufficient reason to require a reactor shutdown." Revise the submittal to expand the Bases to provide examples of events that would result in the inability to suspend movement of irradiated fuel, in order to strengthen the Bases description. (See also RAls 3.8.2-3 and 3.8.8-2.)

DECO Response:

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

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:

t 3.8.6-2 STS Table 3.8.6-1 JFD P.1 The proposed Table would change the applicability of footnote (c) from Categories A, B, and C l 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:

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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 footnotes to Category A, B, and C specific gravity is 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 Re3ponse:

-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 il battery incorporated by Amendment No.121 has not been incorporated, incorporate the change into the STS markup and the ITS.

b. In tne 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 'ustification for the deletion of the situational surveillance frequency. Adopt the ';TS orjustify the less restrictive change from the CTS.

DECO Response:

3.8.7-1 CTS 3.8.3.1.a.3 Action c, it does not appear that this CTS requirement is adequately addressed in proposed ITS 3.5.1.

The proposed LCO includes two curveillance requirements associated with the swing bus, but does not include a specific requirement to declare the low pressure coolant injection .

subsystems inoperable if the swing bus is deenergized or the automatic throwover scheme is '

inoperable. This issue will be addressed in more detail during the staff's review of Section 3.5 of the ITS submittal. Any changes or modifications required in Section 3.8 will be identified at that time.

DECO Response: N/A

'g, **

i 3.8.7-2 DOC L.1 l

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 3.3-81 Bases for STS 3.8.9 Required Action A.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 l accepted. DOC L.1 addresses the potential for a loss of function. However, DOC L.1 does not l explain why it is acceptable to have more than one AC distribution system division inoperable.

Revise the submittal to provide the appropriate justification for the proposed changes or conform to the STS.

DECO Response:

3.8.7-3 DOC L.1 JFD P.2 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 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 proposeo Bases difference is acceptable. DOC L.1 addresses the potential for a loss of function. F .a.e ~

DOC L.1 does not explain why it is acceptable to have more than one DC distributa.. system division inoperable. Revise the submittal to provide the appropriate justification for the proposed changes or conform to the STS.

DECO Response:

3.8.7-4 CTS 3.8.3.1 Action a, footnote #

The proposed change, which deletes the CTS requirement to declare the affected AC

distribution system inoperable when the EECW cooling is inoperable will be addressed as part l of the staff rcview of Section 3.7. Any changes or modifications required in Section 3.8 will be identified at that time.

l DECO Response: N/A i

13-l

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 Comp!etion Time for Required Actions A.1 and C.1 for STS 3.8.9 is "16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from 1 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

'l changes relative to Actions a and b for corresponding CTS 3/4.8.3.1. No justification has been provided to support the proposed changes. Revise the submittal to provide the appropriate i justification for the proposed changes.

] DECO Response:

i 3.8.8 1 Bases Pg. B 3.8-90 3

STS 3.8.8, insert B 3.8.8-1 j; 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 thir permissive is j appropriate for inclusion in the Bases without having the permissive included in the TS LCO.

i The licensee should also consider whether or not cross-tie breakers can be closed and still

! maintain the independence of the EDG.

Deco Response:

l 1 l 3.8.8 2 JFD P.1

ITS 3.8.8 Actions Note j Bases for ITS 3.8.8 Actions, STS Bases markup page B 3.8-91 (insert)

! CTS 3.8.3.2 Action d i Bases for ITS 3.8.8 Required Action A.2.2, STS Bases markup i page B 3.8-91 l

l Action d for CTS 3.8.3.2 states, "The provisions of Specification 3.0.3 are not applicable." This allowance has been retained as the Actions Note for corresponding ITS 3.8.8. The Bases for i ITS 3.8.8 Required Action A.2.2 states that suspension of that activity shall not preclude completion of actions to estabi;sh a safe conservative condition. The Bases for ITS 3.8.8 Actions states, "... Inability to suspend movement of irradia%d fuel assemblies would not be sufficient reason to require a reactor shutdown." Revise the 4 Jbmittal to expand the Bases to provide examples of events that would result in the inability to suspend movement of irradiated fuel, in order to strengthen the Bases description. (See also RAls 3.8.2-3 and 3.8.5-3.)

DECO Response:

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w ., e.-se ,s,- - ,- - t------.- - ,i+-.-i-. . - - - - , - - - - - .,%- y m v-e y, w- - - - . - +_w -a,m vi m. m p-e-

y ss i MEETING ATTENDEES i l

FOR DECEMBER 2 THROUGH 4,1998, FERMI 2 MEETING ON THE l l

lMPROVED STANDARD TECHNICAL SPECIFICATIONS CONVERSION I

NAR AFFILIATION I

Andrew Kugler NRC/NRR/DRPW/PD31, Project Manager Jack Foster

NRC/NRR/ADPR/TSB, Conversion Lead Reviewer Carl Schulten* NRC/NRR/ADPR/TSB, Section 3.3 Lead Reviewer Ed Tomlinson* NRC/NRR/ADPR/TSB, Section 3.8 Lead Reviewer Clifford Doutt NRC/NRR/HICB, Instrumentation and Controls Branch Glenn Ohlemacher Detroit Edison, Licensing Charles Boyce* Excel Inc. (contractor to Detroit Edison)

Dan Williamson Excel Inc. (contractor to Detroit Edison) 4 i

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Part-time participant a

ENCLOSURE 3 i

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l p io l MISCELLANEOUS ITEMS DISCUSSED RELATED TO r

~ THE FERMI-2 TECHNICAL SPECIFICATIONS CONVERSION SUBMITTAL, DECEMBER 1 THROUGH 4,1998

1. The mid-December meeting to discuss the remaining sections (3.5 and 3.6) has been postponed due to scheduling conflicts. The meeting will be rescheduled for January, possibly the week of January 11.

2. The licensee expects to provide revision 2 of the submittalin early January. The licensee's response to the October 26,1998, request for additional information (covering Sections 1.0,2.0,3.0,3.1,3.2,3.10,4.0, and 5.0) is expected the week of December 14.

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l ENCLOSURE 4

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ML20198J691

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SUBJECT:

Enclosures:

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