NRC-98-0007, Submits Proposed Change to Administrative Controls Section of TS to Add Description of Plant Configuration Risk Mgt Program & Supporting Info,Per NRC 971223 Request Re Util 951122 License Amend Request

Submits Proposed Change to Administrative Controls Section of TS to Add Description of Plant Configuration Risk Mgt Program & Supporting Info,Per NRC 971223 Request Re Util 951122 License Amend Request

ML20216B303
Person / Time
Site:	Fermi
Issue date:	04/03/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216B309	List: ML20216B331 NRC-98-0007, Submits Proposed Change to Administrative Controls Section of TS to Add Description of Plant Configuration Risk Mgt Program & Supporting Info,Per NRC 971223 Request Re Util 951122 License Amend Request
References
CON-NRC-98-0007, CON-NRC-98-7 TAC-M94171, NUDOCS 9804130416
Download: ML20216B303 (6)

Text

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r Douglas H.Gipson Senior \ ice l'resirient, Nuclear Generation O

Fermi 2 6400 North Dixie llwy, Newport, Michigan 48166

% Tet 313M64201 Fax:313 M C.4172 Detroit Edison April 3,1998 NRC-98-0007 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20?55

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)- Emergency Diesel l Generator Action Statements, Survei!!ance Requirements and Reports," NRC-95-0124, dated November 22,1995 l

3) Detroit Edisor. Letter to NRC," Response to Questions on l

Proposed Emergency Diesel Generato- Technical Specification Change," NRC-96-0008, dated February 19,1996 ((

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4) Detroit Edison Letter to NRC," Response to Questions on Combustion Turbine Generator (CTG) 11 Unit Number 1 Reliability and System Refurbishment," NRC-96-0066, dated June 12,1996 g

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5) Detroit Edison Letter to NRC," Response to NRC Letter on k Emergency Diesel Generator Allowed Outage Time Extension (TAC No. M94171)," NRC-96 0041," dated April 19,1996 (

6) Detroit Edison Letter to NRC," Response to Probabilistic Safety Assessment Questions Related to Request for Increasing s Emergency Diesel Generator Allowed Out of Service Time  !

(TAC No. M941-'l)," NRC-96-0050", dated May 3,1996 m

9804130416 980403 PDR ADOCK 05000341 i P PDR A trn: b-ro company i

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7) Detroit Edison Letter to NRC," Revised Proposed Technical -

Specification Change (License Amendment)- Emergency Diesel Generator Action Statements, Surveillance Requirements and Reports (TAC No. M94171)," NRC-96-0069, dated June 21, 1996

8) Detroit Edison Letter to the NRC, " Additional Information Related to the License Amendment to Extend Emergency Diesel Generator Allowed Outage Times at Fermi 2," NRC-96-0133, dated December 4,1996

9) Detroit Edison Letter to NRC," Combustion Turbine Generator (CTG) Revised License Amendment to Extend EDG Allowed Outage Times at Fermi 2, NRC-97-0002, dated January 30, 1997

10) Detroit Edison Letter to the NRC, " Additional Information Related to the License Amendment to Extend Emergency Diesel Generator Allowed Outage Times at Fermi 2," l NRC-97-0088, dated August 7,1997

11) NRC Drafl Regulatory Guide DG-1065,"An Approach for Plant- Specific, Risk-Informed Decisionmaking: Technical Specifications", dated June 1997

12) NRC Letter to Detroit Edison," Request for Additional Information (RAI) Related to the Fermi-2 Submittal to Extend Emergency Diesel Generator Allowed Outage Times",

dated December 23,1997

13) Electric Power Research Institute (EPRI) TR105396, "Probabilistic Safety Assessment (PSA) Applications Guide",

dated August 1995

Subject:

Additional Information Related to the License Amendment to Extend Emergency Diesel Generator Allowed Outage Times at Fermi 2 (TAC NO. M9417D I

On November 22,1995, Detroit Edison initiated a license amendment as a Cost Beneficial Licensing Action (CBLA) request to increase the allowed out-of-service time (AOT) for an onsite AC electrical power source from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to seven days (Reference 2). ' Die license amendment was supported by a number of factors, including similar AOTs at many other units, the depth of offsite power capabilitier (5 separate transmission lines), and an assessment of Station Blackout (SBO) coping

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. NRC-98-0007 Page 3 capability. SBO was evaluated aner the original EDG AOT was established and considered capability of additional onsite power from combustion turbine generators (CTG). As a CBLA, this request was also based in part on an assessment that extending the allowed out-of-service time would have a small impact (less than 2%

increase in CDF) on plant risk during operations. The original application requested

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approval by March 31,1996 to support activities associated with the finh refueling outage, which occurred between September and November of 1996.

Since that time, NRC and industry representatives have been working to develop standards for use of risk assessment techniques in applications for license actions.

Throughout this time, Detroit Edison has provided additional information requested by NRC staff to review the application. In December of 1996 and January of 1997, )

References 8 and 9 provided additional risk information requested by NRC, j withdrew a non risk informed submittal, and provided a proposed TS requirement to )

implement Detroit Edison's commitment regarding CTO 11-1 in accordance with I NRC verbal indication that this would be necessary under new NRC policy. In August of 1997, in response to additional questions, Detroit Edison provided )

l . additional information (Reference 10) regarding risk management, risk calculations,

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and loss of power sequences.. Discussions preceding this submittal indicated that 1 NRC had not been previously aware of the robust capability to withstand multiple l failure of AC supplies implicit in previous submittals regarding risk. Reference 10 l provided information addressing this issue. Based on this formal dialogue and on j informal dialogue regarding risk based applications between June and August of 1997, Detroit Edison was confident that any remaining details (which would involve l'

implementation of a commitment regarding risk assessment when removing an EDG l from service) could have been addressed to allow NRC approval in time for planned  ;

preventative maimenance activities in February of 1998.

On December 23,1997, Reference 12 requested that Detroit Edison submit a proposed change to the administrative controls section of the Fermi 2 Technical Specifications to add a description of the Fermi 2 Configuration Risk Management Program (CRMP), and include supporting information. This request indicated that proposed text for such TS was provided by Combustion Engineering Owners Group (CEOG) with its comments regarding Reference 11. The request and additional discussions between Detroit Edison and NRC indicated that Detroit Edison's submittal should be patterned after the CEOG effort to fulfill the intent of this request. Detroit Edison is in the process of review.ing the guidance in DG-1065 and the licensing proposal from the Combustion Engineering Owners' Group and other pilot plants, and Detroit Edison expects to provide another supplement to the q L

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. NRC-98-0007 Page 4 proposed license amendment addressing this request. However, Detroit Edison's current processes for evaluating risk associated with plant configurations established to support online maintenance have been developed and refined, independently from these other efforts, to implement parts of the Maintenance Rule Program. Additional effort is anticipated to develop and implement a program which follows the requested submittal, and Detroit Edison would not be able to complete such an activity in time to support the urgent need for this license amendment.

' Therefore, Detroit Edison is proposing that an interim amendment be approved now as a "one time" extension to allow inspection of the EDGs online prior to the refueling outage. This action is necessary to allow Detroit Edison to plan, schedule, and execute its next refueling outage. Delaying these inspections until the refueling j outage would require starting the outage several days earlier than desired during a l period of relatively high electricity demand. In addition, the offsite feed for the division 2 safety related busses will be out of service during the same period of time +

that these inspections would have to be performed, resulting in a longer period of reduced electrical system redundancy (defease in depth) while this work overlaps.

Furthermore, eliminating the inspections from the refueling outage by performing 4 this work online would ease work control and coordir ation challenges during this l intense work period, and it would facilitate completion of necessary division 2 work to support its return to service before surveillance testing lapses for essential division 1 equipment.

Detroit Edison believes that the processes already in use at Fermi 2 to manage risk during online maintenance meet the overall intent of a CRMP. Based on discussions with NRC staff regarding our past submittals on this subject, Detroit Edison infers that the NRC is generally satisfied with the tools and processes Detroit Edison l utilizes to manage online risk. Furthermore, a recent inspection of Maintenance Rule  !

implementation at Fermi 2 by NRC regional and headquarters personnel identified no concerns with these tools and processes, which are part of the Fermi 2 1 Maintenance Rule Program. Therefore, as part of this request, interim proposed TS pages are provided. This modification would formalize Detroit Edison's requirement for verifying that plant configuration is appropriate to support planned inspection

, activities for the EDGs via the use of a risk matrix, as previously uescribed. By requiring that these planned system outages only occur after verification of satisfactory risk level by the risk level matrix, potentially risk significant activities as discussed in Reference 13 would be avoided. These interim pages also continue to implement a requirement to verify OPERABILITY of a black start capable combustion turbine generator (CTO 11-1), as had been the subject of previous discussions and submittals (e.g., Reference 9). This request was discussed, in concept, between Mr. W. T. O'Connor of Detroit Edison and Mr. B. A. Boger of the NRC on March 25,1998.

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Detroit Edison considers these additional changes to be consistent with previously provided evaluation of No Significant Hazards and Categorical Exclusion from Environmental Assessment. This request for a one time amendment is needed by May 29,1998 to support the necessary EDG inspection activities, and the l amendment needs to be effective until the end of September of 1998.

l If you have any questions regarding this response, please contact Mr. Norman K.

i Peterson, Director, Nuclear Licensing at (734) 586-4258. l l

l l Sincerely, i .

l Enclosure l

l cc: A. B. Beach l B. L. Burgess l G. A. Harris l A. J. Kugler l Supervisor, Electric Operators, Michigan Public Service Commission l I l

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1, DOUGLAS R. GIPSON, 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.

DOUGLAS R. dIPSON Senior Vice President, Nuclear Generation

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l On this day of s1998 before me personally appeared Douglas R. Gipson, being fi'rstDuly swMand says that he executed the foregoing as his free act and deed.

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