NRC-98-0100, Forwards Revised Key Element 2 Description for Addition of Configuration Risk Mgt Program to Administrative Section of Plant Tech Specs

Forwards Revised Key Element 2 Description for Addition of Configuration Risk Mgt Program to Administrative Section of Plant Tech Specs

ML20247R456
Person / Time
Site:	Fermi
Issue date:	05/22/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-98-0100, CON-NRC-98-100 NUDOCS 9805290151
Download: ML20247R456 (6)

Text

• . Ikmglas R. Gipson Senior Vir e President, Nudear Generation F2rmii 0490 North !)ixie llwy., Newport, Mithican 4816G

. . Tel: 313.MCla01 Fax:3131 M 4172 Detroit Edison 10CFR50.92 May 22,1998 NRC-98-0100 U. S. Nuclear Regulatory Commissien 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)- Emergency Diesel Generator Action Statements, Surveillance Requirements and Reports," NRC-95-0124, dated November 22,1995

3) Detroit Edison Letter to NRC," Response to Questions on Proposed Emergency Diesel Generator Technical Specification Change," NRC-96-0008, dated February 19,1996

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

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

6) Detrol: Edison Letter to NRC," Response to Probabilistic Safety Assessment Questions Related to Request for Increasing

,, .g Emergency Diesel Generator Allowed Out of Sersice Time (TAC

,, / J G J No. M94171)," NRC-96-0050, dated May 3,1996 l

7) Detroit Edison Letter to NRC," Revised Proposed Technical t Specification Change (License Amendment)- Emergency Diesel W)b 9905290151 990522 I" Am O f

1 A !)TE Enere company

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USNRC NRC-98-0100 Page 2 l I

Generator Action Statements, Surveillance Requirements and Reports (TAC No. M94171)," NRC-96-0069, dated June 21,1996 )

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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 l

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,"

NRC-97-0088, dated August 7,1997

11) NRC Draft 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

14) 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-98-0007 dated April 3,1998

15) Detroit E<lison Letter to the NRC, " Proposed Technical Specificatan Change (License Amendment)- Addition of the Configuration Risk Management Program (CRMP) to the Administrative Section of the Technical Specifications",

NRC-97-0065, dated April 27,1998

Subject:

Revised Key Element 2 Description for the Addition of the Configuration Risk Management Program (CRMP) to the Administrative Section of Fermi 2 Technical Specifications

USNRC NRC-98-0100 l Page 3 In Reference 15, Detroit Edison proposed a change to the administrative controls section of the Fermi 2 Technical Specifications (TS). The proposed change added a description of the Configuration Risk Management Program (CRMP). On May 18, 1998, during a conference call with Andrew J. Kugler of the NRC, Detroit Edison agreed to revise the description of Key Element 2. Procedure changes will be monitored, assessed, and dispositioned as part of the normal Probabilistic Risk Assessment (PRA) update process. This process will become effective with the next major PRA model update following the 6th Refueling Outage. The Enclosure contains the revised page 4 from Reference 15 Enclosure 1(Key Elements 3 and 4 on l

this page remain unchanged from Reference 15). Please replace the Reference 15 page with this new page.

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

Sincerely,

/

Enclosure cc: A. B. Beach B. L. Burgess G. A. Ilarris A. J. Kugler Supervisor, Electric Operators, Michigan Public Service Commission

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USNRC NRC-98-0100 Page 4 I, DOUGLAS R. GIPSON, do hereby aflirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

DOUGLAS II. GIPSON Senior Vice President, Nuclear Generation On this day of 4t[,1998 before me personally

! l appeared Doug as R. Gipson, being first' duly swfrn and says that he executed the foregoing as las free act and deed.

b ,lA $a - 17 WL Notary Public ROMUE A. ARME1TA .

sounrmauc.MONROECOUm.04 m rammar* EXP1RI.$ 1W11M L_ _____ _ _ _ _ _ _ _ _ _ - . - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _ - - - - _ - - - - - - - - - - - - -

Enclosure to NRC-98-0100 Page1 ENCLOSURE FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REVISED PAGE FOR KEY ELEMENT 2

. Enclosure 1 to

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. NRC-98-0065 Page 4.-

Key Element 2. Control and Use of the CRMP Assessment Tool a) Plant Modifications and Procedure changes will be monitored, assessed, and dispositioned as part of the normal PRA update process.

Evaluation of the changes in plant configuration or PRA model features can be dispositioned by implementing PRA model changes or by the i

qualitative assessment of the impa::t of the changes on the CRMP l assessment tool. This qualitative assessment recognizes that changes can be effectively compensated for without compromising the ability to make sound engineeringjudgments.

Limitations of the CRMP assessment tool are identified and understood l for each specific AOT extension.

b) Procedures exist for the control and application of CRMP assessment tools, including description of process when outside the scope of the primary CRMP assessment tocl.

Kev Element 3. Level 1 Risk-Informed Assessment The CRMP risk assessment tool is primarily based on a Level 1, at power, internal events PRA model. The CRMP assessment may use any combination of quantitative

i. and qualitative input. Quantitative assessments can include reference to a risk l l

matrix, pre-existing calculations, or new PRA analyses.  ;

a) Quantitative assessments should be performed whenever necessary for sound i decision making.

1 b) When quantitative assessments are not necessary for sound decision making, or are beyond the scope of the PRA model, qualitative assessments may be performed. Qualitative assessments will consider applicable or existing insights from quantitative assessments previously performed.

. Kev Element 4 Level 2 Issues / External Events External events and Level 2 PRA issues, as a minimum, are treated when these considerations arejudged to be important using either qualitative or quantitative

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. approaches; Guidance for implementing the CRMP is provided by plant procedures

- and programs.

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