NRC-89-0086, Suppl to 881222 Application for Amend to License NPF-43, Revising Tech Spec 3/4.4.8, Structural Integrity to Be Consistent W/Revised Spec 4.0.5

Suppl to 881222 Application for Amend to License NPF-43, Revising Tech Spec 3/4.4.8, Structural Integrity to Be Consistent W/Revised Spec 4.0.5

ML20247E116
Person / Time
Site:	Fermi
Issue date:	05/10/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247E120	List: ML20247E123 NRC-89-0086, Suppl to 881222 Application for Amend to License NPF-43, Revising Tech Spec 3/4.4.8, Structural Integrity to Be Consistent W/Revised Spec 4.0.5
References
CON-NRC-89-0086, CON-NRC-89-86 GL-88-01, GL-88-1, TAC-72052, NUDOCS 8905260127
Download: ML20247E116 (5)

Text

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NIC-89-0006 U. S. Nuclear Regulatory Commission TAttn: Document Control Desk Washington, D. C. 20555

References:

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

2) Detroit' Edison Letter to NIC, " Proposed Technical Specifications Change (License amendment) Change - Applicability (3/4.0)",

NIC-88-0243, dated December 22, 1988

Subject:

Supplement to Proposed Technical Specification Change (License Amendment) - Applicability (3/4.0) (TAC No. 72052)

Detroit Edison, in Reference 2, submitted a proposal to change Technical' Specification 4.0.5 to incorporate the NRC staff positions given .in NIC Generic Letter 88-01 concerning the. inspection schedule, methods and personnel, and sample expansion for piping ide'tified n as

. potentially susceptible to Intergranular Stress Corrosion Cracking (IGSCC).- Subsequently, Detroit Riison determined that Specification 3/4.4.8, Structural Integrity, requires modification to be consistent with the revised ' Specification 4.0.5. 'Iberefore, Detroit Edison is submitting herein the necessary change to specification 3/4.4.8.

The No significant Hazards Analysis contained ~ in Reference 2 remains applicable for the proposed change as modified in this supplement.

The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed the modified proposal and concurs with the enclosed determinations.

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' May 10,.1989; NHC-89-0086

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Page 2

. If you' have any questions regarding this matter, please contact ~

Mr. Glen Ohlemacher at (313) 586-4275. .

Sincerely, ,

jf Enclosure cc: A. B. Davis R. C. Knop W. G. Rogers J. F. Stang Supervisor, Mvanced Planning and Review Section, Michigan Public Service Commission

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.USNBC May 10, 1989 NRC-89-0086 Page 3 f

.s I, B. RALPH SYLVIA,' do hereby affirm that the foregoing statements are based on facts and circastances which are true and accurate to the best of my knowledge and belief.

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B. RAIhH SVE7IA Senior Vice President On this- / day of d h , 1989, before me personally appeared B. Ralph Sylvia, %g first duly sworn'and sc.ys that he executed the foregoing as his free act and deed.

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Yk Y Notary Public i

ROSAUC A. ARMETrA Notary Pubi c, Monroe County. Mi MyComrnission ExpirosJan. ii.1992 L_ _ _ _ i_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ ___ __ _ _____________._______ ___ ____.________ _____________ _ _____ _ _

Enclosure to tac-89-0086 Page 1 BAGGHOUf0/bISCUSSIN The NBC staff, in Generic Letter 88-01, required power reactor licensees to submit changes to Specification 4.0.5 to incorporate the staff's positions given in the generic letter for inspection schedule, methods and personnel, and sample expansion for piping potentially susceptible to Intergranular Stress Corrosion Cracking (IGSCC) .

Detroit Edison submitted the requested change in Reference 2.

Specification 3/4.4.8, Structural Integrity, also provides requirements concerning ASME Class 1, 2 and 3 components.

Surveillance Requirement 4.4.8 includes reference to NUREG-0313,

'Ibchnical Report on Material Selection and Processing Guidelines for BNR Coolant Pressure Boundary Piping, Revision 1, which was published in July 1980. Revision 2 of NUREG-0313 was developed and issued by the NDC in conjunction with Generic Letter 88-01 in January 1988.

The Abstract for NUREG-0313, Revision 2 states:

This report updates and supersedes the technical recommendations of NUREG-0313, " Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping,"

published in July 1977, and its subsequent revision published in July 1980....This revision also includes guidance and NIC staff recommendations (not requirements) regarding crack evaluation and weld overlay repair methods for long-term operation or for continuing interim operation of plants until a more permanent solution is implemented.

The Executive Summary also states:

The approved Staff Positions derived from the recommendations in this Report are implemented by Generic Letter 88-01.

Detroit Edison is therefore proposing to eliminate the reference to the superseded document, IUREG-0313, Revision 1. The replacement document (NURB3-0313, Revision 2) does not in itself impose any requirements, any requirement is implemented by Generic Letter 88-01.

NURD3-0313, Revision 2 provides the technical bases for Generic Letter 88-01. Detroit Edison is fully implementing the Staff Positions of Generic Letter 88-01 (in regards to structural integrity) in the change to Specification 4.0.5. Detroit Edison therefore believes that it is not necessary to replace the eliminated reference with any alternative active document since all requirements are implemented in Specification 4.0.5.

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' Enclosure to NRC-89-0086 Page 2 Thus,' the new Surveillance Requirement 4.4.8 will read:

No requirements other .than Specification .4.0.5.

This wording brings Fermi 2 'Ibchnical Specifications into conformance with BNR Standard 'Ibchnical Specifications.

In summary, the proposed change to eliminate the reference to NURB3-0313, Revision 1 from Surveillance Requirement 4.4.8 is not a safety concern because:

o NUREG-0313, Revision 1 has been superseded.

o The Staff Positions regarding structural integrity developed from NUREG-0313, Revision 2 and implemented in Generic Letter 88-01 are included in the proposed change to Specification 4.0.5. Further, Specification 4.0.5 is referenced in Surveillance Requirement 4.4.8.

o The change is in conformance with BWR Standard Technical Specifications.

The proposed Technical Specification page change for Specification 4.4.8 is attached. The page changes for Specification 4.0.5 contained in Reference 2 remains unchanged and are attached for reference.

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