NRC-02-0055, Response to the Request for Additional Information Concerning Technical Specification Change Request Related to Response Time Testing

Response to the Request for Additional Information Concerning Technical Specification Change Request Related to Response Time Testing

ML022040634
Person / Time
Site:	Fermi
Issue date:	07/16/2002
From:	O'Connor W Detroit Edison
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-02-0055, TAC MB5173
Download: ML022040634 (7)

Text

William T. O'Connor, Jr.

Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy., Newport, Michigan 48166 Tel: 734.586.5201 Fax: 734.586.4172 Detroit Edison 1 A DTE Energy Company 10CFR50.90 July 16, 2002 NRC-02-0055 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison letter to NRC, "Proposed Technical Specification Change (License Amendment)-Response Time Testing, NRC-02 0036, dated May 30, 2002

Subject:

Response to the Request for Additional Information Concerning Technical Specification Change Request Related to Response Time Testing (TAC No. MB5173)

On June 17, 2002, a teleconference between Detroit Edison and the NRC was conducted to discuss questions the NRC had pertaining to a Technical Specification change request to eliminate specific response time testing requirements (Reference 2). Detroit Edison's response to these questions is attached.

No commitments are being made in this letter.

()\

USNRC NRC-02-0055 Page 2 Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.

Sincerely, Attachment cc: T. J. Kim M. A. Ring NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-02-0055 Page 3 I, WILLIAM T. O'CONNOR, JR., do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

WILLIAM T. O'MNNOR, JR.

Vice President - Nuclear Generation On this day of ,2002 before me personally appeared William T. O'Connor, Jr., being first duly sworn and says that he executed the foregoing as his free act and deed.

otary Public KAREN M.REED

ý!OWta Public, Monroe County, My Commission Expires 09102/2005

USNRC NRC-02-0055 Page 4 bcc: G. D. Cerullo D. K. Cobb R. W. Libra S. R. Peterman N. K. Peterson L. D. Sanders S. Stasek Electronic Licensing Library (ELL) (200 TAC)

Information Management (140 NOC)

Michigan Department of Environmental Quality Radiological Protection Section NSRG Secretary/ISEG Coordinator (200 TAC)

NRR Chron File G. S. Cashell R. W. Johnson

Attachment to NRC-02-0055 Page 1 Response to Request for Additional Information-TAC MB5173 Ouestion 1:

were not In Section B of Enclosure 1 to Reference 2, Affected Instrument Channels, trip units that the listed as components specific to the time response testing elimination request. Clarify license trip units for which response time testing elimination is being requested are a part of the amendment request. Include model information on the specific components.

Response to Question 1:

The following corrects and expands on the information listed in Section B of Enclosure 1 to Reference 2, Affected Instrument Channels.

Those components applicable to the requested changes are:

Trip Units, Rosemont 51 ODU/7 1ODU Agastat EGPB relays (incorrectly listed as EGPI on the original submittal *)

GE HFA relays, 12HFAl51A9 Scram Contactor, GE CR 305

• NEDO-32291-A, Supplement 1, approves both the EGPB (24 vdc) and EGPI (120 vac)

Ouestion 2:

Provide information in Enclosure 4 to Reference 2, Response to the Conditions Included in the NRC Staff' s Safety Evaluation Accepting NEDO-3229 1-A, Supplement 1, for the trip units.

Response to Question 2:

The following expands on the information provided in Enclosure 4 to Reference 2, Response to the Conditions Included in the NRC Staff s Safety Evaluation Accepting NEDO-3229 1-A, Supplement 1, for the trip units.

The Safety Evaluation Report states:

5. For trip units if the following requirements are met, no credible failure will increase response time to more than 24 ms without being detected by tests other than RTT.

Attachment to NRC-02-0055 Page 2

a. The trip units are procured by the utility as "nuclear safety related", or are dedicated for nuclear-safety-related application under a utility dedication program.

Detroit Edison Response:

Fermi 2 trip units in the Reactor Protection System/Primary Containment Isolation Instrumentation are procured as "nuclear-safety-related".

Ouestion 3:

For the tables included in Section B of Enclosure 1 to Reference 2, Affected Instrument Channels, what are the specific manufacturer and models of components for which time response testing elimination is being requested? Include information for the sensors.

Response to Question 3:

The following expands on the information provided in Section B of Enclosure 1 to Reference 2, Affected Instrument Channels, by adding a row for component manufacturer/model, including the sensors, and a note below the tables.

The following tables show Fermi 2 BRT calculation using

Reference:

NEDO-32291-A Supplement 1, Table C.2-1 "Component Sets and Component BRT's."

Loop Type H reactor vessel steam dome pressure high Component Sensor Trip Unit TU Logic Relay Output Loop Channel (TU) Output Contactor Logic BRT Relay BRT Response 200 ms 24 ms 140 ms 40 ms 45 ms 249 ms .449 sec Time Manufacturer Rosemont Rosemont Agastat GE GE NA NA

/Model 1153GB** 510DU/ EGPB 12HFA151A9 CR305 710DU

Attachment to NRC-02-0055 Page 3 Loop Type E* (* Additional Auxiliary Relay) reactor vessel water level-low low low, level 1 Component Sensor Trip Unit TU Logic Auxiliary Output Loop Channel (TU) Output Relay Relay Relay Logic BRT Relay BRT Response 400 ms 24 ms 140 ms 40 ms 40 ms 40 ms 284 .684 sec Time ms Manufacturer Rosemont Rosemont Agastat GE GE GE NA NA

/Model 1153DB** 510DU/ EGPB 12HFAl 12HFA1 12HFA1 710DU 51A9 51A9 51A9 main steam line flow-high Component Sensor Trip Unit TU Logic Auxiliary Output Loop Channel (TU) Output Relay Relay Relay Logic BRT Relay BRT Response Horns 24 ms 140 ms 40 ms 40 ms 40 ms 284 ms .394 sec Time Manufacturer Rosemont Rosemont Agastat GE GE GE NA NA

/Model 1151DP** 510DU/ EGPB 12HFAI 12HFAI 12HFAI 1152DP** 710DU 51A9 51A9 51A9

"**Themanufacturer and model numbers for the sensors are included in Table 7-1 of NEDO 32291-A, October 1995. The sensor response times are different based on the sensor range code and the intended design function. The response time for the sensors are less than or equal to the acceptable limits specified by the manufacturer and within the Bounding Response Time (BRT) for the intended design function. This is documented in Fermi Design Calculation DC-4768 Volume I, Revision 0.