Letter Sequence Response to RAI |
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Results
Other: ML20202H611, ML20239A178, NRC-98-0123, Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 1999, NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions, NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS, NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev, NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev
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MONTHYEARML20239A1781998-09-0303 September 1998 Requests Addl Info Re Licensee Commitments Related to Plant Staff Qualifications.Response Requested within 45 Days of Receipt of Ltr Project stage: Other NRC-98-0123, Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 19991998-10-19019 October 1998 Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 1999 Project stage: Other ML20155B7191998-10-26026 October 1998 Forwards RAI Re Conversion to Improved STSs for Plant,In Order to Complete Review of Util 980403 Amend Request Project stage: RAI ML20196F5701998-11-20020 November 1998 Forwards RAI Re Licensee 980403 Amend Request to Convert to Improved Std TSs for Fermi 2.Mutually Agreeable Completion Schedule of 45 Days for Response Was Established Project stage: RAI ML20198B8741998-12-0404 December 1998 Forwards RAI Re 980403 Amend Request to Convert Improved Std TSs Sections 3.4 & 3.9.Completion Schedule of 60 Days for Response Established Per Discussion with G Ohlemacher on 981109 & 10 Project stage: RAI NRC-98-0150, Forwards Response to NRC 981026 RAI Re Fermi 2 Conversion to Improved Std Ts.Responses Reflect Results of Series of Meetings Between Util & NRC1998-12-10010 December 1998 Forwards Response to NRC 981026 RAI Re Fermi 2 Conversion to Improved Std Ts.Responses Reflect Results of Series of Meetings Between Util & NRC Project stage: Meeting ML20198J6761998-12-22022 December 1998 Forwards Request for Addl Info Re Conversion to Improved STS Section 3.8.Response Requested within 60 Days Project stage: RAI NRC-99-0001, Forwards Response to NRC 981120 RAI Re Fermi 2 Conversion to Improved Std Tech Specs.Plant ITS Submittal Will Be Revised to Reflect Response to RAI Following Completion of Remaining RAIs Re ITS Submittal,As Agreed Upon in Meetings with N1999-01-0808 January 1999 Forwards Response to NRC 981120 RAI Re Fermi 2 Conversion to Improved Std Tech Specs.Plant ITS Submittal Will Be Revised to Reflect Response to RAI Following Completion of Remaining RAIs Re ITS Submittal,As Agreed Upon in Meetings with NRC Project stage: Response to RAI ML20199G7561999-01-14014 January 1999 Forwards Request for Addl Info Re Conversion to Improved Stds Tss,Section 3.3 for Plant Project stage: RAI ML20202H6111999-01-25025 January 1999 Requests Addl Info Re Conversion to Improved Std Tss, Section 3.5 for Fermi 2 Project stage: Other ML20202H8881999-02-0404 February 1999 Clarifies Intent of RAI Re Plant Staff Qualifications & Reg Guide 1.8,Rev 2, Qualification & Training of Personnel for Nuclear Power Plants, Dtd Apr 1987.Staff Position on Issue Neither New Nor Different Position from Previous Position Project stage: RAI ML20203F6761999-02-11011 February 1999 Forwards Request for Addl Info Re Conversion to Improved Standard Ts,Section 3.6 for Fermi 2 Project stage: RAI NRC-99-0032, Forwards Rev 4 to Fermi 2 Its,Per Submittal .Rev Provides Responses to NRC RAI Re ITS Sections 3.4 & 3.9 Contained in Ltr1999-03-30030 March 1999 Forwards Rev 4 to Fermi 2 Its,Per Submittal .Rev Provides Responses to NRC RAI Re ITS Sections 3.4 & 3.9 Contained in Ltr Project stage: Response to RAI NRC-99-0033, Submits Initial Responses to RAIs Re Conversion to Improved Tech Specs Contained in Noted Refs 1-5.Util Has Found Extensive Dialog with NRC That Has Taken Place to Date to Be Extremely Fruitful in Effectively Managing Fermi 21999-04-0808 April 1999 Submits Initial Responses to RAIs Re Conversion to Improved Tech Specs Contained in Noted Refs 1-5.Util Has Found Extensive Dialog with NRC That Has Taken Place to Date to Be Extremely Fruitful in Effectively Managing Fermi 2 Project stage: Response to RAI NRC-99-0044, Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses1999-04-30030 April 1999 Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses Project stage: Response to RAI NRC-99-0045, Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl1999-05-0707 May 1999 Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl Project stage: Response to RAI NRC-99-0046, Forwards Rev 6 to Fermi 2 ITS Submittal ,to Provide Remaining Responses to NRC RAI Re ITS Section 3.3, & Update ITS Submittal to Reflect Responses.Brief Abstract of Changes Contained in Attachment 11999-06-0202 June 1999 Forwards Rev 6 to Fermi 2 ITS Submittal ,to Provide Remaining Responses to NRC RAI Re ITS Section 3.3, & Update ITS Submittal to Reflect Responses.Brief Abstract of Changes Contained in Attachment 1 Project stage: Response to RAI NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions1999-07-0707 July 1999 Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions Project stage: Other NRC-99-0054, Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal1999-07-13013 July 1999 Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal Project stage: Request ML20216D6091999-07-26026 July 1999 Rev 11 to ITS Submittal,Dtd 980403,providing Update to ITS Sections 3.5,3.6 & 3.8 Project stage: Request NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS1999-07-26026 July 1999 Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS Project stage: Other ML20211C4761999-08-0606 August 1999 Forwards Draft Safety Evaluation Re Proposed Conversion of Current TS to Improved Standard TS Project stage: Draft Approval IR 05000341/19990061999-08-0606 August 1999 Insp Rept 50-341/99-06 on 990712-0716.No Violations Noted. Major Areas Inspected:Review of Various Aspects of Licensee Chemistry & Radiation Protection Programs,Specifically in Listed Areas Project stage: Request ML20211C0521999-08-17017 August 1999 Forwards Tables for Sections 3.6 & 3.7 of Draft Safety Evaluation of Proposed Conversion of Current TS to Improved Standard TS Project stage: Draft Approval NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-08-17017 August 1999 Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev Project stage: Other NRC-99-0078, Rev 14 to Application for Amend to License NPF-43,providing Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Brief Abstract of Changes Included in Rev & Revised Pages for Submittal & Rev Instructions,Included1999-08-25025 August 1999 Rev 14 to Application for Amend to License NPF-43,providing Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Brief Abstract of Changes Included in Rev & Revised Pages for Submittal & Rev Instructions,Included Project stage: Request NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-09-0808 September 1999 Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev Project stage: Other 1999-02-04
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Similar Documents at Fermi |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N4261999-10-25025 October 1999 Forwards Amend 17 to License DPR-9 & Safety Evaluation. Amend Revises TS by Deleting SR D.3.c,which Required Weekly Observation of Nitrogen Cover Gas Pressure within Sodium Storage Tanks Located in Sodium Building NRC-99-0085, Forwards Rev 15 to Fermi 2 Security Personnel Training & Qualification Plan, IAW 10CFR50.54(p)(2).Without Encl1999-10-22022 October 1999 Forwards Rev 15 to Fermi 2 Security Personnel Training & Qualification Plan, IAW 10CFR50.54(p)(2).Without Encl NRC-99-0094, Forwards Safeguards Event Rept 99-S01-00 for Reportable Event That Occurred on 990922.Commitments Made by Util Listed1999-10-22022 October 1999 Forwards Safeguards Event Rept 99-S01-00 for Reportable Event That Occurred on 990922.Commitments Made by Util Listed ML20217P1661999-10-21021 October 1999 Forwards Insp Rept 50-341/99-17 on 990927-1005.No Violations Noted ML20217M0771999-10-19019 October 1999 Confirms Discussion Between GL Shear,M Mitchell,E Kosky, D Williams,B Rumins,D Harmon & W Rutenberg in Public Meeting on 990923.Purpose of Meeting Was to Discuss Current Status RP Program at Enrico Fermi 2 ML20217N9231999-10-15015 October 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 40 ML20217E5671999-10-14014 October 1999 First Partial Response to FOIA Request for Documents.Records in App a Already Available in Pdr.App B Records Encl & Being Released in Entirety NRC-99-0087, Responds to NRC Re Violations Noted in Insp Rept 50-341/99-10.Licensee Contests Subject Violation,Due to Listed Reasons1999-10-12012 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-341/99-10.Licensee Contests Subject Violation,Due to Listed Reasons NRC-99-0083, Submits Requested Response to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal1999-10-0707 October 1999 Submits Requested Response to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal ML20217D5331999-10-0707 October 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 39 ML20217F5931999-10-0707 October 1999 Forwards Insp Rept 50-341/99-11 on 990724-0908.Two Violations Re Failure to Follow Procedures While Sampling Standby Liquid Control Tank & Wear Dosimetry Properly Being Treated as Noncited Violations ML20217B8261999-10-0404 October 1999 Forwards Summary of Decommissioning Insp Plan for Fy 2000. Plan Will Be Updated Annually & May Be Revised at Any Time Based Upon Future Insp Findings,Events & Resource Availability ML20212J8121999-10-0101 October 1999 Discusses Plant,Unit 2 Completion of Licensing Action for GL 98-01 & Suppl 1, Y2K Readiness of Computer Sys at Npps. Ack Efforts That Licensee Have Completed to Date in Preparing Plant for Y2K Transition ML20212K8881999-09-30030 September 1999 Refers to 990928 Meeting Conducted at Fermi Unit 2 to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PSA Staff ML20217A3261999-09-30030 September 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 38 NRC-99-0091, Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations1999-09-27027 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations ML20212J8331999-09-27027 September 1999 Responds to Licensee 990924 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required in TS 3/4.6.1.8.Ltr Documents 990923 Telcon with Util in Which NRC Orally Issued NOED ML20216G9791999-09-24024 September 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 37 NRC-99-0092, Documents Util Request for Enforcement Discretion with Respect to Requirements of TS 3/4.6.1.8 Re Drywell & Suppression Chamber Purge Sys1999-09-24024 September 1999 Documents Util Request for Enforcement Discretion with Respect to Requirements of TS 3/4.6.1.8 Re Drywell & Suppression Chamber Purge Sys ML20216H3561999-09-23023 September 1999 Informs That During 990914 Telcon,L Sanders & M Bielby Made Arrangements with NRC to Inspect Licensed Operator Requalification Program at Fermi Nuclear Station for Week of 991129 Which Coincides with Util Regularly Scheduled Exam ML20216H4541999-09-23023 September 1999 Informs That During 990914 Telcon L Sanders & M Bielby Made Arrangements for Administration of Licensing Exams at Fermi Nuclear Station for Week of Jan 31,2000.NRC Will Make Exam Validation Visit to Facility During Week of Jan 10,2000 ML20212F3241999-09-20020 September 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 36 NRC-99-0081, Submits Eight Relief Requests Associated with Containment Inservice Exam Program for Fermi 2 Plant,Per Provisions of 10CFR50.55a(g)(5)(iv).Requested Relief Does Not Adversely Affect Health & Safety of Public1999-09-17017 September 1999 Submits Eight Relief Requests Associated with Containment Inservice Exam Program for Fermi 2 Plant,Per Provisions of 10CFR50.55a(g)(5)(iv).Requested Relief Does Not Adversely Affect Health & Safety of Public ML20217A9421999-09-0909 September 1999 Informs That NRC Plan to Conduct Addl Resident Insps Beyond Core Insp Program Over Next 6 Months to Assess Improvements in Areas of Procedural Compliance & Quality of Work. Historical Listing of Plant Issues Encl NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-09-0808 September 1999 Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev ML20211Q0991999-09-0303 September 1999 Forwards Rev 35 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0090, Forwards Proprietary Operator License Renewal Application, NRC Forms 398 & 396 for SW Burt,License SOP-30199-3. Proprietary Encls Withheld1999-09-0303 September 1999 Forwards Proprietary Operator License Renewal Application, NRC Forms 398 & 396 for SW Burt,License SOP-30199-3. Proprietary Encls Withheld NRC-99-0066, Forwards semi-annual fitness-for-duty Rept for Fermi 2 for Period of 990101-0630,IAW 10CFR26.71(d)1999-08-30030 August 1999 Forwards semi-annual fitness-for-duty Rept for Fermi 2 for Period of 990101-0630,IAW 10CFR26.71(d) ML20211G4951999-08-24024 August 1999 Forwards Rev 34 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0055, Forwards Rev 5 to Inservice Testing Program for Pumps & Valves for Fermi 2 Second 10-Year Interval, Per Provisions of 10CFR50.55a(f)(5)(iv).Rev Includes Four Pump Relief Requests & Ten Valve Relief Requests Requiring NRC Approval1999-08-19019 August 1999 Forwards Rev 5 to Inservice Testing Program for Pumps & Valves for Fermi 2 Second 10-Year Interval, Per Provisions of 10CFR50.55a(f)(5)(iv).Rev Includes Four Pump Relief Requests & Ten Valve Relief Requests Requiring NRC Approval IR 05000341/19990131999-08-19019 August 1999 Discusses Insp Rept 50-341/99-13 & OI Rept 3-98-039 Conducted Into Potential Misconduct of Operator Formerly Employed by De.Nrc Determined That Violation of NRC Regulations Occurred.Synopsis of IO Rept Encl NRC-99-0056, Forwards Rev 2,change 0 to ISI-Nondestructive Exam (ISI-NDE) Program (Plan) for Piping,Components & Integral Attachments, for Second ten-year Interval of Fermi 2 Plant Operation1999-08-19019 August 1999 Forwards Rev 2,change 0 to ISI-Nondestructive Exam (ISI-NDE) Program (Plan) for Piping,Components & Integral Attachments, for Second ten-year Interval of Fermi 2 Plant Operation ML20211C0521999-08-17017 August 1999 Forwards Tables for Sections 3.6 & 3.7 of Draft Safety Evaluation of Proposed Conversion of Current TS to Improved Standard TS NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-08-17017 August 1999 Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev ML20217E6181999-08-13013 August 1999 FOIA Request for Documents Re Implementing Regulations in 10CFR & Requesting That Region III Task Interface Agreement (TIA) Related to Fermi 2 Plant Be Made Available IR 05000341/19990011999-08-10010 August 1999 Forwards Insp Rept 50-341/99-01 on 990619-0723 & Nov. Violation of Concern Because Operators Did Not Understand License Requirements & Placed Plant in Configuration Where EDG 11 Was Removed from Service IR 05000341/19990121999-08-0606 August 1999 Forwards Insp Rept 50-341/99-12 on 990712-0716.No Violations Noted.Insp Focused on Implementation of Plant Chemistry & Radiological Environ Monitoring Programs & Operation of post-accident Sampling Sys ML20211C4761999-08-0606 August 1999 Forwards Draft Safety Evaluation Re Proposed Conversion of Current TS to Improved Standard TS NRC-99-0057, Forwards Rev 12 to ITS 980403 Submittal,Providing Update to Submittal for ITS Section 3.3,including Changes Associated with NRC Review of Rev 6 ITS1999-08-0404 August 1999 Forwards Rev 12 to ITS 980403 Submittal,Providing Update to Submittal for ITS Section 3.3,including Changes Associated with NRC Review of Rev 6 ITS ML20210N5451999-08-0303 August 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 33 NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS1999-07-26026 July 1999 Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS ML20210J2121999-07-23023 July 1999 Discusses NRC OI Investigation Rept 3-98-039 Completed on 990524 & Forwards Notice of Violation NRC-99-0053, Forwards Rev 14 to Fermi 2 Security Personnel Training & Qualification Plan, Per 10CFR50.54(p)(2).Changes Do Not Decrease Effectiveness of Plan.Summary of Changes Also Encl1999-07-15015 July 1999 Forwards Rev 14 to Fermi 2 Security Personnel Training & Qualification Plan, Per 10CFR50.54(p)(2).Changes Do Not Decrease Effectiveness of Plan.Summary of Changes Also Encl ML20209H7211999-07-14014 July 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 32 NRC-99-0054, Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal1999-07-13013 July 1999 Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal ML20209F6571999-07-12012 July 1999 Forwards Insp Rept 50-341/99-09 on 990516-0618.No Violations Noted.Weak Procedural Guidance,Communications Issues & Configuration Control Weaknessess Were Evident NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions1999-07-0707 July 1999 Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions ML20196J5511999-07-0202 July 1999 Discusses GL 92-01,Rev 1,Supp 1, Rv Integrity, Issued by NRC on 950519 & DE Responses & 980729 for Fermi 2.Informs That Staff Revised Info in Rvid & Released Info as Rvid Version 2 as Result of Review of Responses ML20209C6141999-07-0101 July 1999 Rev 31 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0076, Forwards Rev 8 to ITS Submittal to Provide Update to ITS Submittal for ITS Section 3.7.Brief Abstract of Changes Included1999-06-30030 June 1999 Forwards Rev 8 to ITS Submittal to Provide Update to ITS Submittal for ITS Section 3.7.Brief Abstract of Changes Included 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARNRC-99-0094, Forwards Safeguards Event Rept 99-S01-00 for Reportable Event That Occurred on 990922.Commitments Made by Util Listed1999-10-22022 October 1999 Forwards Safeguards Event Rept 99-S01-00 for Reportable Event That Occurred on 990922.Commitments Made by Util Listed NRC-99-0085, Forwards Rev 15 to Fermi 2 Security Personnel Training & Qualification Plan, IAW 10CFR50.54(p)(2).Without Encl1999-10-22022 October 1999 Forwards Rev 15 to Fermi 2 Security Personnel Training & Qualification Plan, IAW 10CFR50.54(p)(2).Without Encl ML20217N9231999-10-15015 October 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 40 NRC-99-0087, Responds to NRC Re Violations Noted in Insp Rept 50-341/99-10.Licensee Contests Subject Violation,Due to Listed Reasons1999-10-12012 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-341/99-10.Licensee Contests Subject Violation,Due to Listed Reasons NRC-99-0083, Submits Requested Response to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal1999-10-0707 October 1999 Submits Requested Response to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal ML20217D5331999-10-0707 October 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 39 ML20217A3261999-09-30030 September 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 38 NRC-99-0091, Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations1999-09-27027 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations ML20216G9791999-09-24024 September 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 37 NRC-99-0092, Documents Util Request for Enforcement Discretion with Respect to Requirements of TS 3/4.6.1.8 Re Drywell & Suppression Chamber Purge Sys1999-09-24024 September 1999 Documents Util Request for Enforcement Discretion with Respect to Requirements of TS 3/4.6.1.8 Re Drywell & Suppression Chamber Purge Sys ML20212F3241999-09-20020 September 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 36 NRC-99-0081, Submits Eight Relief Requests Associated with Containment Inservice Exam Program for Fermi 2 Plant,Per Provisions of 10CFR50.55a(g)(5)(iv).Requested Relief Does Not Adversely Affect Health & Safety of Public1999-09-17017 September 1999 Submits Eight Relief Requests Associated with Containment Inservice Exam Program for Fermi 2 Plant,Per Provisions of 10CFR50.55a(g)(5)(iv).Requested Relief Does Not Adversely Affect Health & Safety of Public NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-09-0808 September 1999 Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev NRC-99-0090, Forwards Proprietary Operator License Renewal Application, NRC Forms 398 & 396 for SW Burt,License SOP-30199-3. Proprietary Encls Withheld1999-09-0303 September 1999 Forwards Proprietary Operator License Renewal Application, NRC Forms 398 & 396 for SW Burt,License SOP-30199-3. Proprietary Encls Withheld ML20211Q0991999-09-0303 September 1999 Forwards Rev 35 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0066, Forwards semi-annual fitness-for-duty Rept for Fermi 2 for Period of 990101-0630,IAW 10CFR26.71(d)1999-08-30030 August 1999 Forwards semi-annual fitness-for-duty Rept for Fermi 2 for Period of 990101-0630,IAW 10CFR26.71(d) ML20211G4951999-08-24024 August 1999 Forwards Rev 34 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0056, Forwards Rev 2,change 0 to ISI-Nondestructive Exam (ISI-NDE) Program (Plan) for Piping,Components & Integral Attachments, for Second ten-year Interval of Fermi 2 Plant Operation1999-08-19019 August 1999 Forwards Rev 2,change 0 to ISI-Nondestructive Exam (ISI-NDE) Program (Plan) for Piping,Components & Integral Attachments, for Second ten-year Interval of Fermi 2 Plant Operation NRC-99-0055, Forwards Rev 5 to Inservice Testing Program for Pumps & Valves for Fermi 2 Second 10-Year Interval, Per Provisions of 10CFR50.55a(f)(5)(iv).Rev Includes Four Pump Relief Requests & Ten Valve Relief Requests Requiring NRC Approval1999-08-19019 August 1999 Forwards Rev 5 to Inservice Testing Program for Pumps & Valves for Fermi 2 Second 10-Year Interval, Per Provisions of 10CFR50.55a(f)(5)(iv).Rev Includes Four Pump Relief Requests & Ten Valve Relief Requests Requiring NRC Approval NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev1999-08-17017 August 1999 Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev ML20217E6181999-08-13013 August 1999 FOIA Request for Documents Re Implementing Regulations in 10CFR & Requesting That Region III Task Interface Agreement (TIA) Related to Fermi 2 Plant Be Made Available NRC-99-0057, Forwards Rev 12 to ITS 980403 Submittal,Providing Update to Submittal for ITS Section 3.3,including Changes Associated with NRC Review of Rev 6 ITS1999-08-0404 August 1999 Forwards Rev 12 to ITS 980403 Submittal,Providing Update to Submittal for ITS Section 3.3,including Changes Associated with NRC Review of Rev 6 ITS ML20210N5451999-08-0303 August 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 33 NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS1999-07-26026 July 1999 Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS NRC-99-0053, Forwards Rev 14 to Fermi 2 Security Personnel Training & Qualification Plan, Per 10CFR50.54(p)(2).Changes Do Not Decrease Effectiveness of Plan.Summary of Changes Also Encl1999-07-15015 July 1999 Forwards Rev 14 to Fermi 2 Security Personnel Training & Qualification Plan, Per 10CFR50.54(p)(2).Changes Do Not Decrease Effectiveness of Plan.Summary of Changes Also Encl ML20209H7211999-07-14014 July 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 32 NRC-99-0054, Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal1999-07-13013 July 1999 Forwards Rev 10 to Fermi 2 ITS Submittal, , Providing Update to Submittal for ITS Section 3.4,RCS.Update Includes Changes Associated with NRC Review of Util Transmittal of Rev 4 to ITS Submittal NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions1999-07-0707 July 1999 Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions ML20209C6141999-07-0101 July 1999 Rev 31 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0049, Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure Encl1999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure Encl NRC-99-0076, Forwards Rev 8 to ITS Submittal to Provide Update to ITS Submittal for ITS Section 3.7.Brief Abstract of Changes Included1999-06-30030 June 1999 Forwards Rev 8 to ITS Submittal to Provide Update to ITS Submittal for ITS Section 3.7.Brief Abstract of Changes Included ML20209C1081999-06-29029 June 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section), Rev 30 NRC-99-0050, Forwards Rev 7 to ITS Submittal of 980403,to Provide Remaining Responses to NRC RAIs Re ITS Sections 3.5 & 3.8. Revision Instructions Included1999-06-24024 June 1999 Forwards Rev 7 to ITS Submittal of 980403,to Provide Remaining Responses to NRC RAIs Re ITS Sections 3.5 & 3.8. Revision Instructions Included NRC-99-0075, Forwards Operator License Renewal Application,Nrc Forms 398 & 396 for CR Effan,License SOP-30186-3.Encl Withheld1999-06-22022 June 1999 Forwards Operator License Renewal Application,Nrc Forms 398 & 396 for CR Effan,License SOP-30186-3.Encl Withheld ML20212J3861999-06-18018 June 1999 Forwards Rev 29 to Approved UFSAR LCR That Have Not Been Incorporated Into UFSAR Hardcopy (Sorted by Section) NRC-99-0047, Responds to NRC 990513 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions. Revised Design Calculation DC-5957, GL 96-06 Calculations, Encl1999-06-0909 June 1999 Responds to NRC 990513 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions. Revised Design Calculation DC-5957, GL 96-06 Calculations, Encl ML20195G2001999-06-0808 June 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy & Approved TRM Lcrs (Sorted by Section), Rev 28 ML20195E7391999-06-0303 June 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy & Approved TRM Lcrs (Sorted by Section), Rev 27 NRC-99-0046, Forwards Rev 6 to Fermi 2 ITS Submittal ,to Provide Remaining Responses to NRC RAI Re ITS Section 3.3, & Update ITS Submittal to Reflect Responses.Brief Abstract of Changes Contained in Attachment 11999-06-0202 June 1999 Forwards Rev 6 to Fermi 2 ITS Submittal ,to Provide Remaining Responses to NRC RAI Re ITS Section 3.3, & Update ITS Submittal to Reflect Responses.Brief Abstract of Changes Contained in Attachment 1 ML20207D9631999-05-26026 May 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy & Approved TRM Lcrs (Sorted by Section) ML20195B3381999-05-19019 May 1999 Forwards Rev 25 to Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy & Approved TRM Lcrs (Sorted by Section) NRC-99-0040, Requests NRC Approval of Revs to Weld Tables of Encl Relief Requests RR-A21,rev 1 & RR-A22,rev 1.Revs Do Not Impact Basis for Original Requests for Relief Because There Is No Change to Technical Basis or Proposed Alternative1999-05-14014 May 1999 Requests NRC Approval of Revs to Weld Tables of Encl Relief Requests RR-A21,rev 1 & RR-A22,rev 1.Revs Do Not Impact Basis for Original Requests for Relief Because There Is No Change to Technical Basis or Proposed Alternative NRC-99-0039, Requests Relief from ASME Section XI Requirement to Examine Essentially 100% of Selected Category B-J Pipe Welds,Per 10CFR50.55a(g)(5)(iii).Relief Request RR-A23,encl1999-05-14014 May 1999 Requests Relief from ASME Section XI Requirement to Examine Essentially 100% of Selected Category B-J Pipe Welds,Per 10CFR50.55a(g)(5)(iii).Relief Request RR-A23,encl NRC-99-0041, Requests Relief from ASME Section XI Requirements to Examine Essentially 100% of Accessible Category B-D Nozzle Welds,Per 10CFR50.55a(g)(5)(iii).Rev 1 to Relief Request RR-A6,encl1999-05-14014 May 1999 Requests Relief from ASME Section XI Requirements to Examine Essentially 100% of Accessible Category B-D Nozzle Welds,Per 10CFR50.55a(g)(5)(iii).Rev 1 to Relief Request RR-A6,encl NRC-99-0038, Requests Relief from ASME Section XI 1980 Requirement to Examine Essentially 100% If Category B-A RPV Shell Weld Lengths,Per 10CFR50.55a(g)(5)(iii)1999-05-14014 May 1999 Requests Relief from ASME Section XI 1980 Requirement to Examine Essentially 100% If Category B-A RPV Shell Weld Lengths,Per 10CFR50.55a(g)(5)(iii) NRC-99-0045, Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl1999-05-0707 May 1999 Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl NRC-99-0044, Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses1999-04-30030 April 1999 Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses NRC-99-0059, Provides Notification Required by 10CFR50.82(a)(7) of Changes to Fermi 1 Decommissioning Cost Estimate1999-04-29029 April 1999 Provides Notification Required by 10CFR50.82(a)(7) of Changes to Fermi 1 Decommissioning Cost Estimate ML20206E2941999-04-28028 April 1999 Forwards Approved UFSAR Lcrs That Have Not Been Incorporated Into UFSAR Hardcopy & Approved TRM Lcrs (Sorted by Section), Rev 24 NRC-99-0037, Forwards Rev 9 to Fermi 2 Ufsar,Per 10CFR50.71(e) & 10CFR50.4(b)(6).Summary of Changes to QA Program & Vol 1 of Technical Requirements Manual,Encl1999-04-26026 April 1999 Forwards Rev 9 to Fermi 2 Ufsar,Per 10CFR50.71(e) & 10CFR50.4(b)(6).Summary of Changes to QA Program & Vol 1 of Technical Requirements Manual,Encl 1999-09-08
[Table view] |
Text
Douglas R.Gipson Senior Vice President, Nuclear Generation Fenni 2 6400 North Dixie Hwy., Newport, Michigan 48166 Tel: 734.586.5201 Far 734MG.4172 Detroit EsKeen
. 9))
9 March 30,1999 NRC-99-0032 U. S. Nuclear Regulatory Commission 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 1
(License Amendment)- Conversion to Improved Standard Technical Specifications," i dated April 3,1998
- 3) NRC Letter to Detroit Edison " Request for Additional Information Regarding Conversion to Improved Standard Technical Specifications, Sections 3.4 and 3.9 for Fermi 2 (TAC No. MA1465),"
dated December 4,1998 0
Subject:
Transmittal of Revision 4 to Fermi 2 Improved P;hnical Specification Submittal (TAC No. MA1465)
Attache'dplease find Revision 4 to the Fermi 2 Improved Technical Specification (ITS) Submittal (Reference 2). The purpose of this revision is to provide responses to the NRC Requests for Additional Information (RAI) concerning ITS sections 3.4 and 3.9 contained in Reference 3.and an update the ITS submittal to reflect these responses. In addition, other needed changes to the affected ITS sections are ra n- . _
9904050066 990330 PDR ADOCK 05000341 -
P PDR A DTE EnergyCompany
r:
USNRC NRC-99-0032 Page 2 included. Attachment I contains a brief abstract of the changes included in this revision. Attachment 2 contains the responses to the Reference 3 RAI. Attachment 3 contains the revised pages for the submittal along with revision instructions.
Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.
Sincerely, Attachments cc: A. J. Kugler A. Vegel NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission I
4
7 USNRC NRC-99-0032 1 i Page 3 {
I 1, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements ere based on facts and circumstances which are true and accurate to the best of my knowledge l and belief.
! DOUGLAS RfGIPSON Senior Vice President, Nuclear Generation l On this M day of NLidI< 1999 before me personally l
appeared Douglas R. Gipson, being first duly sworn and says that he executed the ;
foregoing as his free act and deed. I l
i dAlY Notary Public WW ,
ROSAUE A. ARME1TA NOTARY PUBUC-MONRDE COUNTY.Mi MYCOMMISSION EXPlRES10nLG9 ,
1 ATTACHMENT I TO l NRC-99-0032 ABSTRACT OF REVISION 4 TO THE FERMI 2 IMPROVED TECHNICAL SPECIFICATION SUBMITTAL :
1
' Attachment I to NRC-99-0032 Page1 of1 Abstract of Revision 4 to the Fermi 2 Improved Technical Specification Submittal Revision 4 to the Fermi 2 lmproved Technical Specification (ITS) submittal incorporates the responses to Requests for Additional Information (RAI) contained in Attachment 2 that affect ITS Sections 3.4, Reactor Coolant System and 3.9, Refueling Operations. Revision bars are provided to aid in identification of the changed material.' For those changes associated with an RAI, the RAI number, as used in Reference 3, is included with the revision bar.
Minor corrections are included in this revision. These changes are primarily non-technical, format, spelling, labeling, and editorial enhancements. The revision bars for these changes are 1 marked with a circled "A." These changes are as follows:
The LCO statement for LCO 3.4.1 is reformatted for clarity. The previous draft was
. difficult to read. Additionally, that draft inappropriately appeared to associate the resetting of the RPS APRM setpoint with the prohibition on operating in the " Scram" or
" Exit" Regions. The reformatting clarifies the stability limitation applies at all times.
The CTS Figure for Stability Regions is relocated. Previous revisions stated the details were in both the TRM and the Bases. This has been corrected to reference only the Bases (which contains all the relocated material).
ITS Bases for SR 3.4.3.2 revises the appropriate bypass valve opening (from 10% to 20%) for " adequate steam flow" to test SRVs.
CTS markup of page 3/4 4-12 for ITS 3.4.5, contained an incorrect cross reference (SR j 3.4.5.1.q), which is changed to SR 3.4.5.1.h.
ITS 3.4.6 DOC L.1 has a sentence revised for clarity. Previous wording was fragmented and confusing.
ITS SR 3.4.6.2 Bases is modified to delete a sentence that incorrectly describes verification of alarm setpoint and string accuracy. A revised JFD P.2 is also provided discussing the change.
ITS 3.4.10 DOC A.3 is rev' sed to correct the spelling of" action." l ITS 3.9.4 DOC L.1 (and NS11C) incorrectly stated "no more than one" instead of"all but one".
. ITS 1.9.8 DOC LA.3 corrects a reference from "3.4.9" to "3.9.8".
In addition, changes are made to more closely incorporate the provisions of generic change TSTF-222, that received NRC approval after the original Fermi 2 ITS submittal. The revision bars for these changes are marked with a circled "B."
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l ATTACHMENT 2 TO NRC-99-0032 l
l DETROIT EDISON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTIONS 3.4 AND 3.9 FOR FERMI 2 (TAC NO. MA1465)
' Attachment 2 to NRC-99-0032 n Page1 of11 General Note: Throughout this request for additional information (RAI), references to a standard technical specification (STS) mean the standard version of the TS published by the
'NRC in NUREG-1433,
- Standard Technical Specifications, General Electric Plants, BWR/4,"
Revision 1. 8teforences to an improved TS (ITS) mean the proposed converted TS submitted l by the licorhee. RAI numbers (e.g., RAI 3.4.5-1) refer to the numbers used in the November 9 i and 10,1996l meeting.
All Sections RAI 0.0-1: There is a generic issue involving a number of the Less Restrictive Administrative (LA) discussions of change (DOCS) in the Fermi submittal. Refer to RAI 0.0-1 in the October 26,1998, request for additional information. Additional DOCS affec ted by this issue .
are listed in the following table:
ITS M DOC 3.4.3 - LA.2 3.4.6 LA.2 3.4.9 LA.2 Detroit Edison Response As requested, the affected discussions have been modified to more clearly indicate the ultimate location of the requirement being relocated.
)
Section 3.4 Generic (ITS 3.4.5. 3.4.8. and 3.4.9:
RAI 3.4-1: DOCS LR.1 fcr current TS (CTS) 3.4.3.2 (ITS 3.4.5), LR.2 for CTS 4.4.3.2.2.b (ITS I 3.4.5), LR.1 for CTS 4.4.9.1.2 (ITS 3.4.8), and LR.1 for CTS 4.4.9.2.3 (ITS 3.4.9) discuss the l change in the context of a relocation. However, LR DOCS are supposed to be used for the j deletion of information that does not need to be relocated to a licensee-controlled program with I regulatory program controls. If these DOCS are meant to be deletions, the use of the term relocation is incorrect. If they are relocations, they should be LA DOCS and they should clearly ,
state the program to which the information is relocated. Revise these DOCS to clearly state )
- the disposition of the affected information.
Detroit Edison Rvw: The referenced DOCS have been modified to clearly indicate that .
the requirements are being removed from the Technical Specifications and will not be !
controlled by a program with regulatory program contre!s. l i
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~ Attachment 2 to NRC-99-0032 Page 2 of11 ITS 3.4.1
- 1. RAI 3.4-2: Because of the many changes from the STS and the CTS, this specification is considered beyond scope and will be reviewed by the technical staff. No comments are provided.
ITS 3.4.2 No comments ITS 3.4.3
- 2. RAI 3.4-3: CTS 3.4.2.1 Action c provides Action requirements for inoperable safety relief valve (SRV) position indicators and CTS 4.4.2.1.1 specifies surveillance requirements for SRV valve position indicators. These are not contained in ITS 3.4.3.
DOC LA.2 justification states that the position indicators do not impact Operability of the SRVs but CTS 3.4.2.1 Action c and CTS 4.4.2.1.1 had val;d justification for their inclusion in the CTS such that COLD SHUTDOWN is required if one or more position
. indicators can not be restored to OPERABLE status within the given time frame.
Possibly the reason for CTS 3.4.2.1 Action c, and CTS 4.4.2.1.1 Surveillance is to support CTS 3.4.2.1 Action b which has been eliminated from the ITS. The justification for deleting CTS 3.4.2.1 Action c and CTS 4.4.2.1.1 Surveillance from ITS 3.4.4 that counters the reason why SRV position indicator requirements were previously included in CTS 3.4.2.1, has not been addressed by DOC LA.2. Provide additional justification for removing SRV position indicator requirements from ITS 3.4.3 that counters the reason why they were included in the CTS and are no longer required in the ITS.
In addition, see RAI 0.0-1 for an issue related to DOC LA.2.
Detroit Edison Response: The SRV position indicator requirements were included in the Fermi 2 CTS (as well as other plants licensed in the same time frame) based upon their being induded in the Standard Technical Specifications for BWR/4 plants in use at that time. The DOC provided for this change addresses why the requirement is no longer required to be retained in the ITS. Since there are no plant-specific reasons to retain this requirement, the DOC has been modified to indicate this.
I ITS 3.4.4
. 3. RAi 3.4 4: CTS 3.4.3.2.c and CTS 3.4.3.2.e specify limits on reactor coolant system (RCS) leakage "within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period." ITS 3.4.4.c and ITS 3.4.4.d change the wording for this limiting condition for operation (LCO) to "within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period" which is consistent with the STS. However, there is no DOC addressing this l
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NRC-99-0032 Page 3 of11 l
L wording change. Provide discussion and justification for the equivalency of this wording change.
Detroit Edison Respor,se: New DOC A.2 has been created to include justification for this wording change.
- 4. RAI 3.4-5: STS 3.4.4 Action B1 requires
- Reduce LEAKAGE to within limit in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."
iTS 3.4.3 Action B deletes this requirement per Justification For Difference (JFD) P.5.
JFD P.5 states that when there is an acceptable compensatory action to take (in this case STS Required Action B.2), the NUREG does not include actions that provide an explicit option to restero LCO compliance. This justification in JFD P.5 is in error '
because STS 3.4.4 Req. sired Action B.1 does exist in the NUREG (STS) but is deleted from the ITS in the STS markup. This would be a generic change. Make ITS 3.4.4 Required Actions consistent with the STS.
Detroit Edison Response: The JFD was intended to indicate that STS Action B1 should not have been included in the NUREG since it is in violation of the ITS Writer's Guide.
Writer's Guide Section 4.1.6.g, page 43 of 51, discusses the elimination actions of this nature. As discussed in a meeting with the NRC, the change will be submitted to the BWR Owners' Group to be considered for a formal generic change to the NUREG.
- 5. RAI 3.4-6 & 7: CTS 4.4.3.2.1.a requires monitoring the primary containment atmospheric gaseous radioactivity at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS surveillance requirement (SR) 3.4.4 requires verifying RCS leakage is within limits each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
This change to the frequency of monitoring for gaseous radioactivity is justified by DOC L1. However, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> only applies to MODE 1. MODES 2 and 3 are 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Provide discussion and justification for the differences.
Detroit Edison Response: DOCS L.1 & L.2 have been revised to address these concems. ;
i
. ITS 3.4.5
- 6. RAI 3.4-8: ITS SR 3.4.5.1 specifies pressure isolation valve (PlV) leakage limits, that are based on valve size. ITS SR 3.4.5.1 Insert 3.4.5-1 is added to it and provides exceptions by stating "for PlVs other than LPCl [ low pressure coolant injection) loep A l and B injection isolation valves." iTS 3.4.5.1 insert 3.4.f 3 orovides these exceptions l with specific leakage limits for both the LPCI loop A and L enjection isolation valves and the LPCl loop A and B inboard injection isolation testable check valves. Should ITS SR 3.4.5.1 Insert 3.4.5-1 include the LPCI loop A and B inboard injection isolation testable check valves if so, provide additional wording in insert 3.4.5-1 that includes the LPCI loop A and B inboard injection isolation testable check valves. Some of these changes appear to be different than the CTS and the STS. Also, SR 3.4.5.1 is not clear, perhaps restructuring might help.
l-Attachment 2 to NRC-99-0032 Page 4 of 11 l
Detroit Edison Response: SR 3.4.5.1 has been restructured to clarify the proposed
. requirements in a manner that t.ddresses these concems.
- 7. RAI 3.4-9 & 10: With one or more RCS PlVs not within limit, STS 3.4.5 Actien A specifies Required Action A.1 as well as Required Action A.2. ITS A4.5 Condition A contains Required Action A.1 which is correctly dcrived from CTS 3.4.3.2 Action c, but STS 3.4.5 Required Action A.2 is deleted including the referena to it in the ITS 3.4.5 NOTE for Required Actions. In addition, the NOTE for STS 3.4.5 Required Actions contains the sentence "and be in the reactor coolant pressure boundary [or the high pressure portion of the system).".This sentence is also deleted from the ITS 3.4.5 Required Action NOTE . The justification for these deletions is shown as JFD P.1 which is fundamentally a generic justification and does not specifically address these deletions. There is no justification for why the Note should not 71y to you. Retain the one or the other of the phrases "and be in the reactor coolant , - ure boundary [or the high pressure portion of the system)." include an explanation of wnat *at least one other closed manual... " means in 3.4.3.2 ACTION c. Does this imply two valves. Also, the asterisk refers only to the " Check Valve." is this the only valve in question here?
Detroit Edison' Response: The CTS wording clarifies that the valve used for isolation purposes is different from the valve that is leaking beyond its limit. The CTS does not I refer to two separate isolations. Note that the ITS wording was chosen to match these j CTS words verbatim. Similarly, the Action A.1 Note has been revised to reflect the
{
current licensing basis contained in the CTS. JFD P.1 has been modified to specifically ;
address these differences from the NUREG. i
- 8. See generic RAI 3.4-1 for an issue related to DOCS LR.1 and LR.2.
- 9. RAI 3.4-11: See RAI 3.4-1 for a generic issue related to LR DOCS. In addition, CTS 3.4.3.2 Action d, CTS 4.4.3.2.3, and CTS Table 3.4.3.2-2 contain actions, surveillance details, and a specific list of PlV leakage pressure monitors related to alarm-only functions. DOC LR.1 justification states that the alarm functions do not relate directly to ;
the Operability requirements for the RCS but, CTS 3.4.3.2 Action d had valid justification ;
for ine,lusion in the CTS such that COLD SHUTDOWN is required if one or more pressure interface valve leakage pressure raonitors can not be restored to OPERABLE status within the given time frame. Should this requirement be retained in the j Instrumentation Section? This question will be referred to the reviewer for Section 3.3. l Detroit Edison Response: None required. 1 ITS 3.4a3
- 10. RAI 3.4-12: CTS 3.4.3.1.a requires the Operability of the primary containment atmosphere gaseous radioactivity monitoring system channel. ITS 3.4.6. b changes the wording of this requirement to one channel of primary containment atmosphere gaseous j radioactivity monitoring system. ITS 3.4.6 nnd its bases do not indicate that this i
Attachment 2 to NRC-99-0032 i Page 5 of11 !
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equipment has two channels, rather in most plants it has one channel as identified (gaseous) and the other channelis an " atmospheric particulate monitoring" channel.
The reworded term "one channel of" in ITS 3.4.6.b can be misleading giving rise to an error of using the atmospheric particulate channel as the "one channel of". Consider rewording ITS 3.4.6.b consistent with and equal to CTS 3.4.3.1.a.
Detroit Edison Response: ITS 3.4.6.b has been revised to be consistent with CTS 3.4.3.1.a.
- 11. See generic RAI 0.0-1 for an issue related to DOC LA.2.
- 12. RAI 3.4-13: ITS 3.4.6, Condition C, is missing the word " inoperable" at the end of the l
sentence as shown in the STS 3.4.6, Condition C, markup. Correct the wording of ITS 3.4.6, Condition C.
Detroit Edison Response: Condition C has been corrected as requested.
- 13. RAI 3.4-14: CTS 3.4.3.1 Action requires two leakage detection systems to remain Operable and allows a 30 day restoration time for any individual system inoperability.
ITS 3.4.6 Action statements change this requirement to allow unlimited continued operation with either the primary containment atmosphere gaseous radioactivity monitor or drywell floor drain sump level monitoring system inoperable. STS 3.4.6 does not allow this less restrictive requirement and requires restoration within 30 days of any inoperable system even if only one system is inoperable. ITS 3.4.6 Action statements are a less restrictive change that is also a deviation from the STS.
l DOC L1 provides explanation by stating that the primary system for identifying and quantifying unidentified leakage in the containment is the drywell floor drain sump flow i monitoring system and thus restoration within 30 days of the other two systems is only required if both nf them are inoperable at the same time. This change is not consistent l with the STS and appears to be a less restrictive Required Action and presentation i preference. Provide additional discussion and justification for the less testrictive change and a justification for deviation from the STS. This item is under review by the technical !
staff as a beyond scope issue. l l
Detroit Edison Response: None .equired.
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Attachment 2 to NRC-99-0032 Page 6 of11 ITS 3.4.7
- 14. RAI 3.415: CTS Table 4.4.5-1 item 5 requires Isotopic Analysis of an off-gas sample including Quantitative Measurements for at least Xe-133, Xe-135 and Kr-88 each 31 days ITS 3.4.7 does not retain this requirement. DOC A.3 states that deletion of CTS Table 4.4.5-1 item 5 is acceptable because it is the same surveillance requirement as ITS SR 3.7.5.1 and therefore this deletion is an administrative change. This change does not appear to be administrative because ITS SR 3.7.5.1 requires verification that 7
the gross radioactivity rate of noble gases is less than 340 milliCurins/second after decay of 30 miquies. These two surveillances do not appear to be the same or equivalent sample analyses. Clarify the justification.
Detroit Edison Response: The Bases for ITS SR 3.7.5.1 clarifies that SR 3.7.5.1 does require isotopic analysis for "at least Xe-133, Xe-135, and Kr-88." This is the same requirement as CTS item 5. This is also consistent with the ISTS Bases. To clarify this relation, CTS page 3/4 4-18 will be included in the markup for ITS 3.7.5, along with a new LA-DOC to address these details being relocated to the ITS Bases. These changes will be included in the scheduled update to ITS Section 3.7.
- 15. RAI 3.4-16: CTS 3.4.5 Action c requires sampling and analysis for lodine per item 4.b of CTS Table 4.4.5-1 when in Operational Condition 1 or 2 following changes in thermal power or off-gas level. ITS 3.4.7 eliminates this requirement. DOC A.2 states that the sampling requirements of CTS Table 4.4.5-1 item 4.a encompasses the requirements of item CTS Table 4.4.5-1 item 4.b and CTS 3.4.5 Action c, because it requires lodine sampling each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when activity exceeds a limit. This justification seems to be in i error because the basic lodine sampling requirements, per ITS SR 3.4.7.1, is required only once per 7 days and then it is only required in Mode 1. There is no requirement within the 7-day interval, or during changing power levels, or increasing off-gas levels, to determine if lodine levels are increasing. The proactive CTS sampling requirement in response to transient precursors such as power changes and increasing off-gas levels is thus eliminated without justification of why they are no longer needed. Provide additical discussion and justification for this less restrictive change. i Detroit Edison Response: The change addressed by DOC A.2 is now being addressed as a Less Restrictive change in DOC L.4. However, in accordance with CTS 3.0.1, action c of CTS 3.4.5 is only required to be followed if LCO 3.4.5 is not being met. - Thus there is no current requirement to determine lodine levels within the normal 7 day monitoring interval For this reason CTS Table 4.4.5-1 items 4 b and 4.c are viewed to contain equivalent requirements. DOC L.4 addresses the change in this manner. l
- 16. RAI 3.4-17: CTS 3.4.5, Action c, Note
- states "Not applicable during the startup test program." This note is deleted in ITS 3.4.7 with justification per DOC A.2 However, DOC A.2 doesn't address this deletion. Provide discussion and justification for deleting ;
CTS 3.4.5 Action c Note
Detroit Edison Response: DOC A.2 has been revised to specifically include the
~ footnote.
17.' RAI 3.418: DOC L1 provideo a lengthy justification for deleting CTS LCO 3.4.5.b and its associated Actions and Surveillance Requirements. This involves the 100/E bar microcuries per g am limit and translates into deleting the sampling requirements of CTS Table 4.4.5-1 item 3 (Radiochemical for E bar determination). DOC L1 does not address deleting CTS Table 4.4.5-1 item 1 (Gross Beta and Gamma Activity Determination) although the CTS markup shows DOC L1 as the justification. While the
. change appears to be acceptable, provide the discussion and justification for deleting CTS Table 4.4.5-1 item 1.
Detroit Edison Response: DOC L.1 has been revised to address item 1 as well as item 3 of CTS Table 4.4.5-1.
ITS 3.4.8
- 18. See generic RAI 3.4-1 for an issue related to DOC LR.1.
ITS 3.4.9
- 19. RAl 3.4-19: CTS 3.4.9.2 Applicability states " Operational Condition 4 when irradiated fuel is in the reactor vessel and the water level is less than 20 feet 6 inches above the top of the reactor pressure vessel flange". This requirement is eliminated from ITS 3.4.9 Applicability. DOC A.3 provides discussion and justification for deleting the water level requirement but it does not address d6leting the phrase "when irradiated fuel is in the reactor pressure vessel". Provide additional discussion and justification for deleting the phrase "when irradiated fuel is in the reactor pressure vessel" from ITS 3.4.9 Applicability. This is a less restrictive change.
Detroit Edison Response: The definition of Operational Condition 4 contained in CTS Section 1.0 (as well as the definition of Mode in ITS Section 1.0) applies only with fuel in the vessel. DOC A.3 has been revised to explicitly address this administrative change to eliminate the duplication of this applicability within ITS 3.4.9.
- 20. See generic RAI 0.0-1 for an issue related to DOC LA.2.
- 21. See generic RAI 3.4-1 for an issue related to DOC LR.1.
[ ITS 3.4.10
- 22. RAI 3.4-20: STS 3.4.10, .RCS Pressure and Temperature (P/T) Limits, is written with the actual pressure / temperature limits being specified in the Pressure / Temperature Limits
y H
Attachment 2 to l NRC-99-0032 Page 8 of11 l
l Report (PTLR). ITS 3.4.10 does not use the PTLR to specify limits but does not provide l
reference to the source that is used (e.g., Figure 3.4.10-1, etc.). Add the appropriate references.
- Detroit Edison Response
- In accordance with the ITS Writer's Guide Section 4.1.4.b, i page 40 of 51, "LCOs which require more than one parameter limit to be met will only l refer to the parameters as required to be 'within limits.'" This case applies to ITS 3.4.10 which has several parameter limits contained in the associated SRs. Since SR 3.0.1 requires the SRs to be met in order to meet the associated LCO, a specific reference in the LCO to the limits is not necessary. l l
l: 23. - RAI 3.4-21: CTS 3.4.1.4.a begins with the conditional phrase "When both loops have {
been idle" and CTS 3.4.1.4.b begins with the conditional phrase "When only one loop j has been idle" These phrases are deleted in the CTS markup and are marked with DOC i A.2 forjustification. - DOC A.2 provides discussion and justification for the combination of i these CTS section requirements being equivalent to ITS SR 3.4.10.4 but does not address deleting these conditional phrases. In addition, ITS SR 3.4.10.4 is more restrictive than CTS 3.4.1.4.a because it applies at all times, not only when both loops have been idle. Provide discussion and justification for deleting the CTS 3.4.1.4.a and CTS 3.4.1.4.b phrases "When both loops have been idle" and "When only one loop has been idle" from ITS SR 3.4.10.4.
Detroit Edison Response: DOC A.2 has been revised to address these corcems. l
- 24. RAl 3.4-22: CTS Figure 3.4.1.4-1 and reference to it, is contained within the CTS 3.4.1.4 markup under ITS specification ITS 3.4.10 and are deleted with DOC LR.1 shown ras the justification. DOC LR.1 for ITS 3.4.10 addresses deleting this table with I reference to ITS 3.4.1 " Scram" and " Exit" regions. Use of the terms " Scram" and i
- Exit" regions will be reviewed under comment #1 for ITS 3.4.1. Although the justification l contained in DOC LR.1 is reasonable, the power to flow map (CTS Figure 3.4.1.4-1) j should be retained. ;
1 Detroit Edison Response: It is Detroit Edison's understanding that this issue will be )
reviewed in conjunction with the review of ITS 3.4.1 discussed in comment #1 above. !
However, it should be noted that CTS Figure 3.4.1.4-1 is now retained in the ITS Bases.
This change was made in the incorporation of CTS amendment 128 into the ITS in ITS submittal revision 2.
- 25. RAl 3.4-23 and RAI 3.4-24: CTS 3.4.6.1 Action requires that when in MODES 1,2, or 3, 1 if any of the CTS 3.4.3.1 limits are exceeded, perform an engineering evaluation to determine the effects of the out-of-limit condition on the structuralintegrity of the RCS
. and determine that the RCS acceptable for [ continued] operation, but the CTS does not i establish a specific completion time. ITS 3.4.10 Required action A.2 establishes 72 j hours to determine that the RCS is acceptable for continued operation when in MODE 1, !
2, or 3 and for other than MODE 1,2, or 3, ITS 3.4.10 Required Action C.2 establishes, j i
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- p. _
1 Attachm:nt 2 to NRC-99-0032 Page 9 of 11 prior to entering MODE 2 or 3. These changes are justified by the discussions in DOC A.5. These changes are more restrictive and not administrative.
In addition, ITS 3.4.10 Required Actions A.2 and C.2 only require determining that the RCS is acceptable for [continuedj operation. The CTS phrase " perform an engineering evaluation to determine the effects of the out-of-limit condition on the structuralintegrity of the RCS"is deleted without discussion. This appears to be a less restrictive change.
Provide appropriate discussion and justification (more/less restrictive) for CTS 3.4.6.1 Action requirements changing to ITS 3.4.10 Required Actions A.2 and C.2. l Detroit Edison Response: DOC A.5 has been replaced by DOC M.1 to address the 1 addition of the time limits for the required actions as a more restrictive change as requested. In addition, DOC LA.2 has been added to address that the details of how )
effects of the out-of-limit condition on the structuralintegrity of the RCS is determined ;
has been relocated to the ITS Bases. I
- 26. RAI 3.4-25: CTS 4.4.6.1.2 specifies being to the right of CTS Figure 3.4.6.1-1 curve C which makes clear the safe area of the criticality limit curve. By implication the same applies (being to the right) to curve A and B although CTS 3.4.6.1 does not explicitly l state to the right. ITS 3.4.10, as well as ITS Figure 3.4.10-1 (which is exactly the same l as CTS figure 3.4.6.1-1), and ITS 3.4.10 Bases do not specify anywhere that the safe area relative to curve A, B, or C is to the right. ITS 3.4.10 simply requires maintaining pressure and temperature within limits. The clarification previously contained in the CTS is not carried forth in ITS 3.4.10. Provide clarification in ITS 3.4.10 of the safe area relative to ITS Figure 3.4.10-1 curves A, B, and C.
Detroit Edison Response: ITS SR 3.4.10.1 has been modified to clearly state that the acceptable region for operation is to the right of the curves in ITS Figure 3.4.10-1.
ITS 3.4.11
- 27. RAI 3.4-26: CTS 3.4.6.2 requires reactor steam dome pressure "less than" 1045 psig and CTS 3.4.6.2 Action applies with pressure " exceeding" 1045 psig. The CTS Action statement with pressure " equal to" 1045 psig is not specifically addressed in the CTS but '
CTS 4.4.6.2 surveillance also specifies pressure shall be verified to be "less than" 1045 psig. ITS 3.4.11 LCO and ITS SR 3.4.11.1 require reactor steam dome pressure "less than or equal to" 1045 psig. Adding " equal to" to ITS 3.4.11 LCO and ITS SR 3.4.11.1 is ;
discussed within DOC A.2 as a resolution of a discontinuity within CTS 3.4.6.2 Action i presentation. However, adding " equal to" in the ITS LCO and Surveillance is less restrictive and not administrative based upon the requirements of CTS 3.4.6.2 LCO and CTS 4.4.6.2 DOC A.2 does not state that the condition of being " equal to" 1045 psig is analyzed within safety bounds as acceptable and CTS 3.4.6.2 LCO and CTS 4.4.6.2 imply otherwise. Provide additional discussion and justification for adding " equal to" to i ITS 3.4.11 LCO and ITS SR 3.4.11.1 as a less restrictive change.
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l Detroit Edison Response: DOC L.1 has been included to address the condition of RCS pressure being axactly equal to 1045 psig.
Section 3,9 ITS 3.9.4
- 1. RAI 3.9-1: Bases insert B 3.9.4.-1 indicates that the insert is to clarify detail (see JFD P.6). The actual wording provides exception to the SR. This is a generic change because it is not in the CTS. Use the STS wording or obtain generic approval for the change.
Detroit Edison Response: A generic change will be submitted to the BWR Owners' i Group for consideration, '
ITS 3.9.5
- 2. RAI 3.9-2: In the Bases for ITS 3.9.5, the reference to LCO 3.1.2 is deleted. JFD P.4 indicates that LCO 3.1.2 does not contain requirements for control rods. However, SR 3.1.2.1 does reference frequency requirements following control rod replacement.
Retain the reference.
Detroit Edison Response: The Bases have been changed to include the reference to ]
LCO 3.1.2. !
- 3. - RAI 3.9-3: In JFD P.5, the licensee indicated that the changes to the Bases for ITS 3.9.5 are consistent with other ITS Bases. T he BWR/6 has the same language. Further, the control rods are not a system. Specifications 3.9.1,3.9.2,3.9.3, and 3.9.4 refer to control rods. Any correction should be made consistently.
Dstroit Edison Response: The reference to " system"is consistent with the GDC ,
referenced (which requires two " systems"). The reference serves solely to make this ,
connection and is not a reference to a plant defined " system". This item will be I submitted to the BWR Owners' Group for consideration as a generic change. l 1
ITS 3.9.6 i
- 4. RAI 3.9-4: Are all of me changes to the first paragraph of the Applicat le Safety Analysis l justified by P.47 in general, clarify which JFDs apply to which changes in this section j (e.g., does JFD P.2 apply to all of the changes in the latter half of the first paragraph on ,
STS Bases page B 3.9-20). Should the reference to 23 feet of water in this sect:on be your licensing basis as opposed to the references to 20 feet 6 inches elsewhere?
I Attachment 2 to NRC-99-0032 Page11of11 l
Detroit Edison Response: The licensing bases for spent fuel pool level at Fermi 2 is 20 .
l feet 6 inches of water. An additional P.2 mark up has been added for Insert B3.9.6-1 to clarify this. The P.2 mark up is applied to changes associated with 20 feet 6 inches of water being the required level at Fermi 2. P.4 mark ups are applied to other differences that are associated with the Fermi 2 specific application of Regulatoy Guide (RG) 1.25 (including those associated with the RG 1.25 references to 23 feet of water).
ITS 3.9.7
- 5. RAI 3.9-5: The Applicability statements for ITS 3.9.7 and 3.9.8 include a note describing an exception to the stated applicability. In the STS/ITS, exceptions are addressed directly in the Applicability statement. Relocate the information in the notes into the Applicability statements. l 1
Detroit Edison Response: The Applicability has been modified to eliminate the use of a )
note.
l ITS 3.9.8 l
- 6. See RAI 3.9-5.
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