NRC-98-0083, Responds to 980213 RAI Re Amend Request to Relocate Reactor Recirculation Sys motor-generater Set Scoop Tube Stop Setting Surveillance

Responds to 980213 RAI Re Amend Request to Relocate Reactor Recirculation Sys motor-generater Set Scoop Tube Stop Setting Surveillance

ML20216F706
Person / Time
Site:	Fermi
Issue date:	04/09/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-98-0083, CON-NRC-98-83 NUDOCS 9804170212
Download: ML20216F706 (4)

Text

9 Douglas R. Gipson Senior Vice President, Nuclear Generation Ferrni 2 MOO North Dixie llwy, Newport, Michigan 48166 Teh 313MG.5201 Fax:313.586.4172 Detroit Edison April 9,1998 NRC-98-0083 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington DC 20555

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) for Relocation of Reactor Recirculation System Motor-Generator (MG) Set Scoop Tube Stop Setting Surveillance," NRC-97-0037, dated June 20,1997

3) Detroit Edison Letter to NRC," Correction to Detroit Edison Letter NRC-97-0037," NRC-97-0066, dated J aly 2,1997

4) NRC Reque. for Additional Informati.)n (RA0 Related to the Fermi-2 Submittal to Relocate the Reactor Recirculation System Motor-Generator Set Scoop Tube Stop Setting Surveillance (TAC No. M99071), dated February 13,1998

5) NEDC-31681,"BWR Owners' Group Improved BWR Technical  ;

Specifications," dated April 1989 l

Subject:

Response to Request for Additional Information Related to the Fermi-2 Submittal to Relocate the Reactor Recirculation System Motor Generator Set Scoon Tube Stoo Settine Surveillance in References 2 and 3, Detroit Edison submitted a request to change the Fermi 2  ;

Technical Specincations (TS). In a Request for Additional Information, Reference 4, the NRC stated that because the mechanical stops are relied upon to terminate the slow flow increase event prior to exceeding a fuel safety limit, it appears that this

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f, b USNRC NRC-98-0083 Page 2 component satisfies Criterion 3 of 10CFR50.36(c)(2)(ii) which indicates that a TS limiting condition for operation (LCO) must be established and requested that Detroit Edison provide an evaluation of the applicability of the four criteria in 10CFR50.36(c)(2)(ii) to the Motor Generator (MG) set scoop tube mechanical stops.

10CFR50.36(c)(2)(iii) clearly exempts the Fermi 2 Reactor Recirculation System MG set stops from the evaluation requested. The statements ofconsideration published in the Federal Register Volume 60, No.138, dated Wednesday, July 19, 1995 for the most recent change to 10CFR50.36(c)(2)(iii) reinforce this exemption and place the burden of analysis in accordance with the backfit rule on the Commission by stating "This change was made to clarify that a licensee would be required to modify their Technical Specifications if the Commission detemlined that a new requirement was necessary in accordance with the backfit rule and the new requirement met one of the four criteria contained in paragraph 10CFR50.36(c)(2)(ii)."

The intent of the Fermi 2 Technical Specification change request is not to eliminate, but to relocate the surveillance requirement associated with demonstrating the setting of the reactor recirculation system motor-generator set scoop tube mechanical stops from the Technical Specifications to the Updated Final Safety Analysis Report (UFS AR). This specific relocation has already been reviewed and implicitly approved by the NRC, as evidenced by its inclusion in NUREG-1433, " Standard Technical Specifications General Electric Plants, BWR/4." As stated in the preface to NUREG-1433, Revision 1, "This NUREG is the result of extensive public technical meetings and discussions between the Nuclear Regulatory Commission (NRC) staff and various nuclear power plant licensees, Nuclear Steam Supply System (NSSS)

Owners Groups, specifically the GE Owners Group, NSSS vendors, and the Nuclear Energy Institute (NEI). The Improved STS were developed based on the criteria in the Final Commission Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22,1993 (58 FR 39132)." Topical Report

, NEDC-31681 (Reference 5) was the document used to bridge the Standard Technical Specifications (STS) and the Improved STS (NUREG-1433), and which formed the basis for the meetings and discussions referred to in the preface to the NUREG discussed above. This Topical Report contained the specific relocation that we are l requesting. Detroit Edison submitted a license amendment request on April 3,1998 '

to convert the Fermi 2 Tecimical Specifications to the Improved Technical l Specifications.

The basis for the relocation of this surveillance, as presented in Reference 5, is as follows: " Design basis transient analyses (slow flow runout event) establish l

Minimum Critical Power Ratio (MCPR) limits (LCO 3.2.2) as a function of the MG set scoop tube stop setpoints. No specific setpoint is required for the MG set scoop  !

tube stops provided an appropriate limit is chosen for MCPR. Verification of MG l set scoop tube stop setpoints is relocated to plant specific administrative controls and l

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is an implicit assumption in the determination of appropriate MCPR limits." The flow-dependent MCPR and Maximum Average Planar Linear Heat Generation Rate (MAPLIIGR) limit coefficients, including maximum core flow which is dependent upon the MG set scoop tube stop setting, are specified in the Core Operating Limits Report (COLR) as are the other parameters used to calculate the appropriate MCPR 1 and MAPLHGR limits. Operation within these limits is required by Technical j Specifications 3.2.1 and 3.2.3. Inclusion of these limits within the COLR, combined with the proposed relocation of the surveillance requirement to the UFSAR, will continue to ensure that the MG set speed stop settings are maintained at or below the required limits. This change is consistent with the Improved STS, Based on the foregoing, Detroit Edison requests that the NRC approve and issue this change.

Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258. l l

l Sincerely, c l

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

% 4 USNRC NRC-98-0083 Page 4 I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based  ;

on facts and circumstances which are true and accumte to the best of my knowledge and belief.

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DOUGLAS R. GTPSON Senior Vice President, Nuclear Generation On this day of [ /.1998 before me personally i appeared Douglas R. Gipson, being first' duly sworn and says that he executed the foregoing as his free act and deed.

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h L Notary Public ROSAUE A. ARMETTA NOTARYPUBUC MONFt0ECOUNTY.Mt M': COMMIS$10N EF6F4310/1140