ML20206A311
| ML20206A311 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/16/1999 |
| From: | Kugler A NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9904280129 | |
| Download: ML20206A311 (12) | |
Text
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,. 37-M/
- [EI y i UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enmaa nnnt gg f April 16, 1999 ,
i 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 (the licensee) at NRC Headquarters on April 12 and 13,1999, to discuss issues related to the Fermi 2 submittal for the conversion to the improved standard technical specifications (ITS). In addition, the staff provided feedback to DECO conceming the quality of recent submittals. Enclosure 1 lists the meeting participants.
The participants discussed a number of issues related to the schedule for the conversion. The )
licensee provided some more details about the schedule for its submittal of revisions and the l staff, working from this information, developed a revised schedule for the review activities in l order to support the scheduled August 31,1999, date for issuance of the amendment.
Enclosure 2 is the revised schedule. The mutually agreeable schedule includes extensions for the dates of the licensee responses to staff requests for additionalinformation (RAls). The licensee expressed concems that if any significant problems were encountered during the ruview, the date for issuing the amendment could slip. Of particular concern to the licensee was the potential for competition for resources among the conversion submittals from various licensees. The staff agreed that this issue and others required close monitoring to ensure that the schedule is met.
The licensee also provided a status of its on-site preparations for the cor' version. For example, f approximately 93 percent of the procedures that must be revised to support the conversion have [
t been drafted. Almost 50 percent of these procedures have been approved. In addition, training )
for the operators and other plant personnel is proceeding.
The staff and the licensee discussed the status of the rulemaking to revise the Maintenance -
Rule (10 CFR 50.65) in relation to the configuration risk management program (CRMP) in the I current technical specifications (CTS). This issue was discussed in detail in the March 19,1999, A !
meeting with the licensee. In the current meeting, the licensee expressed its desire to avoid the ;
need for a separate license amendment to remove the CRMP from the TS after the conversion if possible. The staff indicated it would consider possible options that fall within the constraints of ;
current policy.
The stan and the licensee then discussed the status of beyond-scope issues under staff review and other miscellaneous items that would require resolution as the converCon proceeds.
Enclosure 3 describes the beyond-scope issues and most of the miscellaneous items that were reviewed. Comments on selected items are provided in Enclosure 4. The participants then ta!Ked about the development of the tables that will be used in the staff's safety evaluation. The licensee provided helpful information conceming similarities and differences between its submittal and recent completed conversions (e.g., Susquehanna Steam Electric Station).
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1 Finally, the staff provided feedback to the licensee concerning the quality of its licensing l submittals. This portion of the discussion did not relate directly to the conversion, but '
I considered all submittals. The staff had raised previously concerns related to submittals in a summary of a conference call dated March 5,1998. The staff reviewed the quality of more ,
recent submittals and indicated that licensee efforts to improve the quality had been, for the j most part, successful. Most of the recent submittals did not require any RAls or supplements in !
order for the staff to complete its review. The staff and the licensee agreed that continuing efforts to improve communications would aid efforts by the licensee to make quality submittals.
The licensee also described internal processes that have been modified in order to improve the submittals.
1 Andrew J. ugler, Project Manager, Section 1 l Project Directorate til j Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341
Enclosures:
As stated ;
cc w/encls: See next page l
l l
l 4
)
. April 16, 1999 Finally, the staff provided feedback to the licensee conceming the quality of its licensing submittals. This portion of the discussion did not relate directly to the conversion, but considered all submittals. The staff had raised previously concems related to submittals in a summary of a conference call dated March 5,~ 1998. The staff reviewed the quality of more recent submittals and indicated that licensee efforts to improve the quality had been, for the most part, successful. Most of the recent submittals did not require any RAls or supplements in order for the staff to complete its review. The staff and the licensee agreed that continuing efforts to improve communications would aid efforts by the licensee to make quality submittals.
The licensee also described intemal processes that have been mcdified in order to improve the submittals.
)
Original signed by:
Andrew J. Kugler, Project Manager, Section 1 Project Directorate lll Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341
Enclosures:
As stated cc w/encis: See next page DISTRIBUTION.
E-majj Paper Coov SCollins/RZimmerman (SJC1/RPZ) Docket File (50-341)
BSheron (BWS)) PUBLIC ,
JZwolinski/SBlack (JAZ/SCB) PD3-1 R/F l CThomas/GDick AKugler THiltz (TGH) OGC WBeckner (WDB) ACRS AVegel(AXV) JFoster NGilles 1Tjader DOCUMENT NAME: G:\PD3-1\WPDOCS\ FERMI \MTSSTS14.WPD To receive a copy of
- hie document,ind6cate in the box: "C" a Copy wehout artschmenuanciosure T e Copy wth attachmenuenclosure Y a No copy OFFICE PM:PD3-1 lE LA:PD3-1 l (A)SC:PD3f1 p lE NAME AKugler @v THarrisJ@ W GDick LWL ~
DATE 04/ 1 6 /99 " 04/ 4 /99 04/h /99~ !
OFFICIAL RECORD COPY m _
April 16, 1999 Finally, the staff provided feedback to the licensee concerning the quality of its licensing submittals. This portion of the discussion did not re! ate directly to the conversion, but considered all submittals. The staff had raised previously concerns related to submittals in a summary of a conference call dated March 5,1998. The staff reviewed the quality of more recent submittals and indicated that licensee efforts to improve the quality had been, for the most part, successful. Most of the recent submittals did not require any RAls or supplements in order for the staff to complete its review. The staff and the licensee agreed that continuing efforts to improve communications would aid efforts by the licensee to make quality submittals.
The licensee also described internal processes that have been modified in order to improve the submittals.
Original signed by:
{
Andrew J. Kugler, Project Manager, Section 1 1 Project Directorate lll Division of Licensing Project Management l Office of Nuclear Reactor Regulation j Docket No. 50-341
Enclosures:
As stated cc w/encls: See next page DISTRIBUTION:
E-mail Paper Com j SCollins/RZimmerman (SJC1/RPZ) Docket File (50-341)
BSheron (BWS)) PUBLIC JZwolinski/SBlack (JAZ/SCB) PD3-1 R/F CThomas/GDick AKugler THiltz (TGH) OGC WBeckner (WDB) ACRS AVegel(AXV) JFoster NGilles TTjader DOCUMENT NAME: G:\PD3-1 \WP DOCS \FE RMi\MTS STS 14.WPD To receive a copy of this document, Indicata in the box: "C" = Copy wtthout attachmenuanciosure "E" = Copy with attachmenuenclosure "N" e No copy j OFFICE PM:PD3-1 lE LA PD3-1_ l (A)SC:PD3/1 p E NAME AKugler GlYv THarrisOd W GDick h&
DATE 04/l(3 /99 " 04/ % /99 04/// /99 I
OFFICIAL RECORD COPY l
Mr. Douglas R. Gipson Detroit Edison Company Fermi 2 cc:
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 lil 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 i Newport, Michigan 48166 ]
o.a.en im I'
. MEETING ATTENDEES FOR APRIL 12 AND 13,1999, FERMI 2 MEETING ON THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS CONVERSION NAME AFFILIATION Andrew Kugler NRC/NRR/DLPM/PD31, Project Manager Jack Foster NRC/NRR/ DRIP /TSB, Conversion Lead Reviewer Bob Tjader NRC/NRR/DP.lP/TSB, Section 2.0,3.1,3.2, and 3.10 Lead Reviewer Nan Gilles NRC/NRR/ DRIP /TSB, Section 3.5 Lead Reviewer William O'Connor Detroit Edison, Asst. VP, Nuclear Assessment Glen Ohlemacner Detroit Edison, Licensing Joe Conen Detroit Edison, Licensing Charles Boyce Excel Inc. (contractor to Detroit Edison)
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FERMI 2 CONVERSION B5 YOND-SCOPE ISSUES
' April 12,1999 Definite Beyond-Scooe Issues
- 1. Item 3.3.6.3-1: Improved technical specifications (ITS) 3.3.6.3, Condition B, for safety relief valve tailpipe pressure instruments is significantly different than the current TS (CTS) and the standard TS (STS). Discussion of Change (DOC) M.1 justifies adding specific functions to the TS. But there is no justification for the less restrictive actions compared to the CTS. See request for additional information (RAl) 3.3.6.3-3. Response is expected 4/30/99. However, we will likely have a call to discuss the proposed resolution before that date. There is not a package for review by the tech staff yet. Based on a cursory review and discussion, the original proposal would not be acceptable.
)
- 2. Item 3.4.1 1: ITS 3.4.1, Justification For Difference (JFD) P.5, implementation of recommendations for avoiding thermal-hydraulic instabilities. This was identified as beyond scope in the licensee's original submittal. It is under review by Reactor Systems Branch (SRXB) (Ulses). Expected 4/15/99.
- 3. Item 3.4.1-2: ITS 3.4.1, DOCS LA.1 and A.2, JFD P.1, moving single recirculation loop operation from an action statement to the limiting condition for operation and deleting a number of CTS-required actions. This was identified as beyond scope by the staff during its review. COMBINED WITH 3.4.1-1.
- 4. Item 3.4.6-1: ITS 3.4.6, DOC L.1, deletion of STS bracketed action B.2 for reactor coolant system leakage detection systems. This was identified as beyond scope by the staff during its review, it was reviewed by Plant Systems Branch (Ordaz). Safety evaluation (SE) signed 1/28/99 indicated the change is acceptable.
- 5. Item 3.5.1-1: ITS 3.5.1, JFD P.1, addition of actions for a situation in which both a low pressure coolant injection (LPCI) and a core spray subsystem are out of service. This was identified as beyond scope in the licensee's original submitta:. It is under review by SRXB (Ulses). Discussed with the Technical Specifications Branch (TSB) 1/26/99. Gave precedent information (Duane Arnold, Brunswick) to Ulses along with historical bases for the current Fermi TS. Estimated completion date (ECD) is 4/15/99.
- 6. Item 3.5.1-2: ITS 3.5.1, JFD P.5, relocation of emergency core cooling system instrumentation response time testing to 3.5.1. This was identified as beyond scope in the licensee's original submittal. It was reviewed by instruraentation and Controls Branch (Garg). SE dated 1/13/99 indicated the change is acceptable.
- 7. Item 3.6.1.3-1: ITS 3.6.1.3, DOC A.3 (see also ITS 3.1.8), excepting the scram discharge i volume vent and drain valves from the containment isolation valve TS on the basis that ITS 3.1.8 already provides adequate controls for these valves. This was identified as beyond scope by the staff during its review. It is under review by Containment Systems Branch (SCSB) (Pulsipher). Reviewer question sent with the 3.6 RAI (see RAI 3.6.1.3-2). j ENCLOSURE 3 I
- 8. Item 3.6.1.3-2: CLOSED ITS 3.6.1.3, JFD P.5, modified actions for special case containment isolation valves. This was identified as beyond scope in the licensee's original submittal. It was under review by SCSB (Goel). Questions were sent with the 3.6 RAI (see RAI 3.6.1.3-4). However, per Bob Giardina this item was withdrawn from SCSB review on 2/9/99 because the changes are generic. A number of the changes are the subject of current Technical Specifications Task Force (TSTF) changes (e.g., TSTF-30 and TSTF-207).
l
- 9. Item 3.6.1.3-3: The licansee proposed to delete CTS 3.6.1.2.d and e, Actions d and e, and 4.6.1.2 " footnote which relate to a CTS requirement to maintain the total leakage of all hydrostatically tested valves less than 5 gpm. The licensee believes this was intended to satisfy a commitment to limit ECCS system leakage outside containment after a design-basis accident. This item was sent to SCSB 2/9/99. ECD is 5/28/99. Based on discussion with the reviewer, I mentioned to the licensee that a DOC that more directly addressed why it is not needed versus why they think it may have been there would probably resolve the issue.
- 10. Item 3.6.2.1-1: CLOSED ITS 3.6.2.1, JFD P.4, clarify actions for suppression pool temperature greater than 110*F. This was identified as beyond scope in the licensee's original submittal. It was under review by SCSB (Goel). Withdrawn from SCSB review on 2/2/99 because Bob Giardina has identified this as a generic change.
- 11. Item 3.6.2.2-1: CTS 3.6.2.2, R.10. remove drywell and suppression pool spray from the TS. This was identified as beyond scope by the staff during its review. It is under review by SCSB (Lobel). Held a call with the licensee to discuss questions from SCSB on 2/1/99.
Questions were sent with the 3.6 RAI (see RAI S3.6.2.4-1).
- 12. Item 3.8.5-1: ITS 3.8.5, JFD P.4, required DC systems with the reactor shutdown. The licensee's proposal is more restrictive than the CTS and less restrictive than the STS.
This was identified as beyond scope by the staff during its review. However, the i resolution of this generic issue is under discussion between NRC and the industry. Based i on discussions between the NRC and the industry, the TSB reviewer (Tomlinson) believes I the licensee proposal will be acceptable. He plans to review it himself (i.e., Electrical Engineering Branch review is not required). ;
- 13. Items 3.10.4-1 and 3.10.5-1: ITS 3.10.4, JFD P.7 and ITS 3.10.5, JFD P.5, clarify requirements for single control rod removal. This was identified as beyond scope in the licensee's original submittal. Under review in SRXB (Ulses). No RAI questions expected.
ECD is 4/15/99.
Potential Issues (some may become bevond-scooe issues)
- 1. ITS 3.3.1.1, JFD P.5, allowing source range monitors to be partially withdrawn when obtaining overlap with the intermediate range monitors. This was identified as a potential beyond-scope issue by the project manager during his review. TSB 3.3 lead reviewer agreed. See RAI 3.3.1.1-23.
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- 2. RESOLVED: ITS 3.4.5, JFD P.1, exception in surveillance requirement (SR) 3.4.5.1 from an allowable leakage rate based on valve size for LPCI injection isolation valves, per the -
CTS. This was identified as a potential beyond-scope issue by the project manager during his review. TSB 3.4 lead reviewer does not consider this beyond scope. See RAI 3.4-8.
s
- 3. RESOLVED: ITS 3.6.1.3, JFD P.g, exclusion of penetrations with a seal system from STS SR 3.6.1.3.11. This was identified as a potential beyond-scope issue by the project manager during his review. TSB 3.6 lead reviewer does not consider this beyond scope.
- 4. ITS 3.8.1, DOCS A.11 and LR.4, removing the CTS requirement to verify the combustion turbine-generator operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of declaring an emergency diesel generator inoperable, and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. This was identified as beyond scope by the staff during its review. The licensee will resolve in the response to RAI 3.8.1-1.
- 5. ITS 5.5.14, modifications to the configuration risk management program (CRMP) description. The program description is modified in the conversion. The staff considers this beyond scope. However, when the Maintenance Rule is resolved, the CRMP can be removed. This may be the best success path. If not, the licensen has agreed to retain the CTS version until the rule is changed. See the summary for the 3/19/99 meeting.
Other issues
- 1. Amendment 130 removes the CTS requirement to periodically verify the recirculation motor-generator set scoop tube stop settings. The licensee had already removed this SR in the ITS 3.4.1.1 and so the only effect is to modify the CTS markup and the associated DOC. Verify the changes are made.
- 2. Amendment 126 ISSUED 8/25/98. Allows a residual heat removalloop to be considered operable for LPCI when aligning to or in shutdown cooling if it can be manually realigned to the LPCI mode and is not otherwise inoperable. STS submittal reflects the change.
However, the amendment submittat discusses only remote manual realignment. The staff deleted the (STS) discussion of local realignment from the Bases. This is not reflected in the submittal.
- 3. Amendment 131 revises the minimum water level required in the CST during shutdown conditions. The CTS markup and the ITS (3.5.2) will have to be modified to reflect the new number. Verify the changes are made.
- 4. Amendment 132 modifies TS 3.7.1.2 and 3.8.1.1 with respect to actions for inoperable primary containment oxygen monitoring instrumentation. STS and ITS already address this issue, so the only effect is to modify the CTS markup and the associated DOC. Verify the changes are made.
w- 5. In CTS Table 4.4.5-1, item 5 requires an isotopic analysis of an offgas sample, including quantitative analysis for at least Xe-133, Xe-135, and Kr-88. In its conversion the licensee indicated that this item can be deleted because it is covered by ITS SR 3.7.5.1. The licensee realized that it should have documented their position in Section 3.7 (i.e., they should have had a CTS markup page from Table 4.4.5-1 showing what was deleted in reference to the subject Section 3.7.5 SR). Verify the changes are made.
4
- 6. Jim Luehman raised a concem related to the emergency equipment cooling water (EECW) system. In particular, if flow is secured to an individual safety-related EECW load, the system is still operable. However, the load should not be considered operable.
Jim wants to understand how the new TS would ensure this occurs. I have discussed this with the licensee. A fairly simple change to ITS 3.7.2, DOC L.1, should resolve this. In particular, it should indicate that ITS 3.7.2 actions in conjunction with ITS 3.0.6 are sufficient for the case of an inoperable EECW subsystem. Isolation of flow to individual loads would then be addressed for each load.
- 7. ITS 3.8.6, inclusion of new guidance on battery performance testing, as suggested by Dr. Saba. The licensee is considering whether such a change would be appropriate. It appears that the industry and the staff will not reach agreement conceming implementation of new testing requirements in time for them to be included in the conversion.
- 8. CTS 6.8.1.b refers to NUREG-0737, " Clarification of TMI Action Plan Requirements,*
November 1980. NRC STS 5.4.1.b adds reference to NUREG-0737, Supplement 1. In its conversion, the licensee chose not to add the reference to Supplement 1 to TS 5.4.1.b.
The staff recommended adding this reference since the actions described in both the NUREG and its supplement are required. In the November 9 and 10,1998, meeting, the licensee indicated it would revise the reference.
- 9. The staff identified some problems with the Revision 1 submittal. The licensee made changes to resolve these items in Revision 2. However, one item was missed. The STS markup for ITS 3.3.3.1 (the second part of attached item 4) was not corrected.
- 10. The staff identified the following problems in the Revision 4 submittal:
For ITS 3.4.1, CTS markup of page 3/4 4-2 references DOC A.1 for 4.4.1.1.2. There should not be a DOC referenced here. In addition, the reference to DOC LA.1 for 4.4.1.1.3 was inadvertently deleted.
For ITS 3.4.1, with the deletion of 4.4.1.1.2 by Amendment 130, DOC LA.2 should ,
have been deleted. l For ITS 3.4.4, DOC L.1, there is a typographical error in the first sentence in that it reads "... monitoring....be monitored...."
4 The explanation of "B" type changes in the abstract for Revision 4 indicates that the changes relate to TSTF-222. However, JFD C.1 for ITS 3.9.2 refers to TSTF-205.
- 11. The Split Report gives new locations for "R" type changes that are discussed in Appendix A of the submittal. However, some of the relocated items (CTS 3.3.6.2,3.3.6.3,
' 3.3.6.4,3.3.6.5, 3.3.6.6, and 3.3.7.1.2) are not discussed in Appendix A. Rather they have individual R-DOCS. These DOCS do not state the location to which these specifications are located.
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- DISCUSSION OF BEYOND-SCOPE ISSUES
- 1. Issue 3.3.6.3 The licensee is developing a revised proposal for the requirements !
related to the safety relief valve tailpipe pressure switches. The licensee believes that implementation of the standard technical specification (STS) version of the specification would be inappropriate based on plant-specific design factors. Current technical specifications (CTS) did not specifically address these instruments. Therefore, the i licensee believes it will be necessary to deviate from both the CTS and the STS in order to I properly address the requirements for these instruments. The licensee will probably ask for a conference call to discuss the proposal after it is developed.
- 2. Issue 3.6.1.3 The licensee expressed concern that if the STS were adopted without modification, the operators would be required to enter two different specifications (ITS 3.1.8 and 3.6.1.3) when a single piece ot~ equipment (i.e., a scram discharge volume (SDV) vent or drain valve) became inoperable. The licensee expressed its view that ITS 3.1.8 should apply to the SDV vent and drain valves since it addresses these valves specifically and that the application of ITS 3.6.1.3 would not be necessary. The staff responded that STS 3.1.8 from which ITS 3.1.8 was derived was probably written under the assumption that the SDV vent and drain valves had only one safety function - support for the operability of the SDV. It appears that the SDV vent and drain valves are not containn'.ent isolation valves at the plants that were used to develop the STS. Therefore, STS 3f;.1.3 would not apply to the valves and the completion times in STS 3.1.8 are appropriate for the SDV function. The Fermi design is different in that the SDV vent and drain valves serve a dual function - support of the SDV.pgl containment isolation. The completion times in STS 3.1.8 do not consider the containment isolation function and are significantly longer than the times that would be allowed by STS 3.6.1.3. The licensee acknowledged the staff's concems and will develop a proposed resolution to this issue.
MISCELLANEOUS ISSUE in the April 3,1998, submittal, the licensee proposed to either relocate or delete the requirements related to the emergency diesel generator service water system. In request for additionalinformation 3.8.1-17 the staff questioned the removal of the requirements for this system from the TS. The staff believes this system satisfies Criterion 3 of 10 CFR 50.36(c)(2(ii) and that the licensee should include these requirements in the ITS as a separate specification or as part of ITS 3.8.1. The licensee is evaluating this issue and, at this point, it expects to include ;
the requirements as part of ITS 3.8.1. i 1
ENCLOSURE 4 i l
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