NRC-90-0095, Provides Schedule for Implementation of Mods Re Compliance W/Reg Guide 1.97,Rev 2,per 900502 Request

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Provides Schedule for Implementation of Mods Re Compliance W/Reg Guide 1.97,Rev 2,per 900502 Request
ML20043E609
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 06/06/1990
From: Orser W
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-0095, CON-NRC-90-95, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-59620, NUDOCS 9006130196
Download: ML20043E609 (4)


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NIC-90-0095 U. S. Nuclear Regulatory Cmanission Attn Document Control Desk Washington, D. C. 20555 '

References:

1) Fermi 2 >

NIC Docket No. 50-341 NRC License No. NPF-43

2) NIC Letter, "Energency Response Capability -

Conformance to Regulatory Guide 1.97 Rev. 2 (TAC No.

59620) Datei May 2,1990 ,

3) Detroit Edison Letter NIC-89-0148, " Additional Clarification to Fermi 2 Coupliance to Regulatory Guide 1.97, Revision 2", Dated June 19, 1989
4) Detroit Edison Letter NIC-89-0201, " Regulatory Guide 1.97 Revision 2 Design Review", Dated Septenber 12, ,

1989

Subject:

Cmpliance with Regulatory Guide 1.97, Revision 2 CI'AC No. 59620)

The NIC, in a letter dated May 2,1990 (Reference 2), forwarded to Detroit Fdison the Safety Evaluation relata3 to conformance with Regulatory Guide 1.97.

I As requesta3 in the letter, please find the schedule for the inplenentation of the modifications to correct the exceptions as )

identified in the conclusion of the safety evaluation.

SAFE'IY EVALUATION COtc.USION:

l a) The staff finds acceptrble the existing neutron flux instrunentation for interim operation. It is the staff's position that the licensee should install neutron flux monitoring instrunentation which conplies with the Category 1 criteria of I R.G. 1.97, Revision 2.

1 9006130196 900606

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USNIC June 6, 1990 l NIC-90-0095 Page 2 MlTROIT_ EDISW. RESP R En Detroit Edison is participating in the Boiling Water Beactor Owners' Group (BWROG) activities on the Wide Range Neutron i Monitoring (WMM) Instrunentation. Detroit Edison will perform  :

any necessary planning and scheduling activities after final resolution is achieved for all BWRs.

SM17YlVALIRTION COtGUSION: -

i b) It is the staff's position that infornation on the coolant level in the reactor is valuable to the operator in evaluation of the acconplishnent of accident mitigation. It is also the staff's position that the 11oensee should upgrade the fuel zone instrumentation to conply with the Category 1 criteria of R.G.

1.97, Revision 2. ,

DETRmT EDISON REEPONSE:  ;

Division I Fuel Zone Level Indicator B21R610 will be upgraded to a qualified indicator. Also, the associated cables and powr supply will be upgraded to comply with the Category 1 criteria of Regulatory Guide 1.97 Revision 2.

The above nodification will be coupleted under Engineering Design Packaye (EDP) 11493 as prioritized in the 5-par plan but expectad to be no later thari the fourth refueling outage (MO4) .

SM1R LVALUNTION..COtGUSION2 c) It is the staff's positi.n that information on the status of prinary contairr..ent isolation valve position is valuable to the ,

operator in evaluation of the accomplishnent of isolation of the  ;

containnent. It is also the staff's position that the licensee should upgrade, to neet the Category 1 criteria of R.G.1.97 l Revision 2, the position indication for the following valves l B31-F019, B31-F020, B31-F014A, B31-F014B, B31-F016A, B31-F016D,

l. T49-F465, T49-F468, T46-F400, T48-F410, T46-F401, T46-F412, l T48-F404, T48-F405, T48-F409, T48-F455, T48-F453, T48-F454, L

T48-F456, T48-F457, and T48-F458.

l l DETROIT EDISON RF2QNSFa.

1. The position indication circuit (position switches, interface terminal blocks, and cables) for the following valves will be upgraded to neet the Category 1 criteria of Regulatory Guide 1.97 Revision 2, with the exception of the power supply for the B31 valves, which will remain RPS. In Reference 3, the-use of the RPS power was justified, based in part on it being divisionalized with each bus capable of receiving power from

USNRC

< June 6, 1990 NBC-90-0095 Page 3 an altemate supply that can be energized by stardby power.

Since the power supply to the limit switches is the sane as that to the solenoid valves, if the. power supply to the limit #

switches is lost, the solenoids will also lose power and the isolation valves will go closed. The 10C did not take exception to the power supply for the position indication for these valves in Beference 2.

B31-F019 B31-F014A B31-F016A T49-F465 B31-F020 B31-F014B B31-F016B T49-F468 Se above upgrade, including any modifications, will be complettd under Engineering Design Package (EDP) 11492 as prioritized in the 5. year plan but expected to be no later than the fourth refueling outage (RF04) .

2. We position indication circuit (position switches, interface terminal blocks, cables and power supply) for the following valves will be upgrade / to neet the Category 1 criteria of Begulatory Guide 1.97 kvision 2.

T46-F400, T48-F410, T45-F401, T46-F412, T48-F404, T48-F405, T4 8-F409, .

T48-F455, T48-F453, T48-F454, T48-F456, T48-F457, T48-F458 The above modifications will be inplenented during the second refueling outage (RF02) per Engineering Design Package (EDP) 10610.

SAENIY._lEABTJON CONCLUggit d) It is the staff's position that Category 1 Instrunentation should be powered from Class IE power sources. It is also the staff's position that the licensee should provide full tine Class IE 5

power sources for the containnent and drywell hydrogen corcentration, ard containnent and drywell oxygen concentration instrunentation.

DETJQ}T EDISON PNONSEr A Class IE power supp'y will be provided for the containnent and drywell hydrogen /oxyp.i concentration recorder (Division I, T50R806A) to neet the Category 1 criteria of Regulatory Guide 1.97 Revision 2.

%e above nodification will be inplenented during the third refueling outage (RF03) per Engineering Design Package (EDP) 11491.

i

UStGC s

June 6, 1990 10C-90-0095 Page 4 In the process of preparing this response, Detroit Edison felt that the following clarification for the environnental qualification colum in the tables contained in References 3 and 4 should be included. The I:nviromental Qualification (BQ) requirenent for Category 1 and 2 variables per R.G.1.97 Revision 2, paragraphs C.1.3.1.a and C.1.3.2.a is that the instrunentation from the sensor to the display are to be enviromentally qualifled in accordance with R.G.1.89 and the nethodology of NURBG-0588. "Y" in the EQ colunn indicates coupliance with this EQ requirenent as explained here.

All safety-related (QA Level 1 and Seismic Category 1) electrical )

equipnent, including post accident monitoring instrunentation, has been environnentally qualified for the conditions under which it uust operate. This is denoted with a "Y" urder the EQ colunn. For exanple, the valve position switches of containnent isolation valves that nest change state to mitigate the consequences of a Loss of Coolant Accident (IEA) or High Diergy Line Break (HILB) are qualified to the sane harsh enviroment conditions and operating tine as the valve actuator. Certain containnent isolation valves (QA Level 1 and Seismic Category 1) are not required to change state to mitigate a IC A or HELB. Consequently, the valve is not qualified to change position and the valve position switches are not qualifled to provide position indication under a harsh environnent. However, these valves and associated position switches are enviromentally qualified for the non-accident service environnent. Docunentation is maintained under the Fermi 2 EQ Program to identify operating tines and to justify excluding these itene from the harsh environnent EQ Program.

The EQ requirement for Category 3 variables is that (Reference R.G.

1.97 Revision 2, paragraph C.l.3.3.a) the instrunentation should be of high-quality comnercial grade and should be selected to withstand the specifled service environnent. "Y" in the EQ column indicates conpliance to the above requirements.

If you have any questions, please contact L)nne Goodman at (313) l 586-4211.  !

i Sincerely.

s W. S. Orser Senior Vice President l cc: A. B. Davis l l R. W. DeFayette l W. G. Rogers L J. F. Stang l

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