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 2

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

ML20205K784
Person / Time
Site:	Fermi
Issue date:	04/08/1999
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-99-0033, CON-NRC-99-33 TAC-MA1465, NUDOCS 9904140015
Download: ML20205K784 (8)

Text

Douglas R. Gipson Senior Vice President, Nuclear Generation Fermi 2

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6400 North Diale Hww Newport, Michigan 48166

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Tel; 734.586.5201 Fax; 734.686.4172

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DeM Edison April 8,1999

. NRC-99-0033 U. S. Nuclear Regulatory Cormnission f

Attention: Document Control Desk I

Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC Letter to Detroit Edison " Request for

. Additional Information Regarding Conversion to Improved Standard Technical Specifications, Section 3.3, for Fermi 2 (TAC No. MA1465),"

dated January 14,1999

3) NRC Letter to Detroit Edison " Request for Additional Information Regarding Conversion to hnproved Standard Technical Specifications, Section 3.5 for Fermi 2 (TAC No. MA1465),"

dated January 25,1999

4) NRC Letter to Detroit Edison " Request for Additional Infonnation Regarding Conversion to improved Standard Technical Specifications, Section 3.8 for Fermi 2 (TAC No. MA1465),"

i dated December 22,1998

5) NRC Letter to Detroit Edison '" Request for Additional Information Regarding Conversion to Improved Standard Technical Specifications, Section 3.6 for Fermi 2 (TAC No. MA1465),"

dated February 11,1999

Subject:

Initial Response to Requests for Additional Information Regarding j

Conversion to improved Technical Specifications (TAC No. MA1465) j

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• A 9904140015 990408 I

POR ADOCK 05000341; p

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A trrE Energy Company i

USNRC NRC-99-0033 Page 2 The purpose of this letter is to transmit Detroit Edison's initial response to the NRC Requests for Additional Information (RAI) concerning the Fermi 2 conversion to improved Technical Specifications (ITS) contained in References 2 through 5. The contents of these RAls have been discussed in a series of meetings between the NRC and Detroit Edison. As discussed in these meetings, the response to these RAls will be made in two parts. In this, the initial response, certain issues have been identified where additional interaction will likely be required to reach resolution.

Subsequently, in a later response, the remaining issues will be addressed along with the revision to the ITS submittal package.

This course of action makes the most effective use of both the NRC and Detroit Edison resources. In the initial response, issues that need further discussion are promptly identified. In the subsequent response, other issues are more completely developed and submitted in one action. This reduces the need for duplicative development of correspondence and subsequent duplicative NRC review effort.

Ideally, between the two submittals, the issues identified as needing further discussion can be discussed and the resolution incorporated into the second submittal.

The attachment to this letter contains the initial response to the RAI concerning ITS Section 3.3, Instrumentation (Reference 2). The update to the ITS submittal for this section is scheduled for May 28,1999.

There are no que.stions requiring further discussion in the Reference 3 RAI for ITS Section 3.5, Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC). The actions needed to complete this section depend heavily on the results of a separate technical review underway by the NRC. Detroit Edison understands that this review is nearing completion and will suppott the scheduled update of the ITS submittal for this section on June 25,1999. There are also no questions requiring further discussion in the Reference 4 RAI for ITS Section 3.8, Electrical Power Systems. The update to the ITS submittal for Section 3.8 is scheduled for June 4,1999.

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The ITS submittal update for ITS Section 3.6, Containment Systems, is scheduled for April 30,1999. This section was the subject of the Reference 5 RAL 1iS 3.6.1.3, Primary Containment Isolation Valves, is substantially affected by pending generic changes that nre expected to be resolved in the near future. The resolution of these generic changes will also affect the resolution of many of the RAI questions for this specification. Therefore, the update of the ITS submittal for ITS 3.6.1.3 a.id the response to the associated RAI questions is being delayed to allow these generic changes to be resolved. The submittal addressing ITS 3.6.1.3 is expected by May 28, l

USNRC NRC-99-0033 Page 3 1999. Due to the schedule for updating Section 3.6, an initial response to the RAI is not practical.

Detroit Edison has found the extensive dialog with the NRC that has taken place to date to be extremely fruitful in effectively managing the Fermi 2 conversion to ITS.

We look forward to continuing this dialog as the conversion nears completion.

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

Sincerely, W D

Attachment ec:

A. J. Kugler A. Vegel NRC Resident Office Regional Administrator, Region Ill Supervisor, Electric Operators, Michigan Public Service Commission i

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USNRC NRC-99-0033

' Page 4 I, 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. GIPSON Senior Vice President, Nuclear Generation On this -

day of 8

_,1999 before me personally appeared Douglas R. Gipson, being firs / duly sworn and says that he executed the foregoing as his free act and deed.

$ Mxb5

/W$

Notary Public

' ' ROSAUE A. ARMETTA NOTARY PUBUC. MONROE COUNTY, fAl MYCORAMSSION EXPlRES10/11/99 l

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l ATTAQ.'CNT TO NRC-99-0033 INITIAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATION SECTION 3.3, INSTRUMENTATION

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Attachment to t

NRC-99-0033 Page1 INITIAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATION SECTION 3.3, INSTRUMENTATION General Note: Throughout this request for additional information (RAI), references to a standard technical specification (STS) mean the standard v rsion of the TS published by the NRC in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision

1. References to an improved TS (ITS) mean the proposed converted TS submitted by the licensee.

RAI 3.3.1.I-23:

(New question developed after the December I through December 3 m eting.)

Beyond Scope Current Technical Specification (CTS) Table 4.3.1.1-1, footnote (b)

Discussion of Change (DOC) M.4 STS/ITS SR 3.3.1.1.6 Justification For Difference (JFD) P.5 Comment:

The CTS require the licensee to verify overlap between the source range monitor (SRM) and intermediate range monitor (IRM) channels during reactor startups. The STS SR 3.3.1.1.6 requires this overlap testing with the frequency stated as " Prior to withdrawing SRMs from the fully inserted position." The frequency in ITS SR 3.3.1.1.6 is revised to read " Prior to fully withdrawing the SRMs from the core." The licensee considers this interpretation to be consistent with the CTS. Ilowever, all of the recent BWRs have adopted the STS version of the SR. There are no plant-specific reasons cited by the licensee for this deviation from the STS. The licensee should adopt the STS or provide plant-specific reasons for the deviation from the STS.

Detroit Edison Response.:

JFD P.5 in Revision 0 provided a plant-specific justification with supporting rationale for the change from the STS. Detroit Edison has determined that plant startup under the requirements of STS SR 3.3.1.1.6 would either not be possible or require operation at a reactor period shorter than desired for conservative plant operation. This has been identified as problematic by other i

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ITS-converted BWRs and has resulted in an emergency Technical Specification change at one l

plant. The proposed resolution is consistent with the current usage of the CTS. This issue is f

being addressed generically in TSTF-264; however, since the proposed resolution is consistent l

Attachment to

• i NRC-99-0033 Page 2 with current practice, approval of the Fermi 2 ITS should not be tied to generic resolution of this issue.

RAI 3.3.5.1-5:

i LA.3 Comment:

ECCS manual initiation functions are included in CTS. The ITS also requires these functions to preserve the overall redundancy and diversity included as part of the licensing basis of Fermi 2.

Revise the ITS to include CTS manual initiation functions. The same situation exists in ITS 3.3.5.2 for RCIC (LA.3) and ITS 3.3.6.1 for primary containment isclation (PCI) instrumentation (LA.6). (See RAls 3.3.5.2-1 and 3.3.6.1-7)

Detroit Edison Response-Detroit Edison provided an enhanced JFD-P.1 discussion (referring to DOC LA.3) justifying not adopting the STS " Manual" initiation functions. In summary, STS provide brc keted options for the inclusion of various " Manual" initiation functions. As described in the STS Bases these functions consist of" push button channels [that) introduce signals into the appropriate...

logic... redundant to the automatic protective instrumentation. These " system level" initiation channels would be separate and in addition to the normal individual component controls (valve and pump control switches). The Fermi 2 design does not include these " system level" initiation channels. The Fermi 2 CTS requirements for Manual Initiation Function clearly (via footnote) requires only the individual component controls. If the intent of the STS was to include these controls if system level initiations did not exist, then there would not be a need to bracket

" Manual Initiation" in the STS since a " Manual Initiation" would always be available for conversion to ITS. The Fermi 2 design does not include the bracketed " Manual Initiation" function as intended by the STS; thus, these items were deleted in preparing the Fermi 2 ITS.

RAI 3.3.6.1-8:

A.12 Comment:

Retain the CTS presentation of minimum operable channels per trip system in the ITS for Functions 1.e and 1.g. Retain the CTS Table 3.3.2-1 footnote (c) in the TS or the Bases.

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Attachment to

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~ NRC-99-0033 Page 3 l

Detroit Edison Response:

The CTS footnote (c) def'mes the CTS use of" channel" for Functions 1.e and 1.g as consisting of 2-out-of-4 detectors. In the conversion to ITS, Detroit Edison has attempted to provide more consistent use of" channels" such that each individual sensor (e.g., detectors for these functions) reflect separate " channels." The CTS requirement for OPERABLE channels is maintained in the ITS, but with a more consistent and natural definition of" channels". In this case the CTS

" channel"is equivalent to the ITS " logic"; each requires 2 detectors to be OPERABLE. Detroit Edison believes this proposed presentation is equivalent to the CTS presentation and highly i

desirable in that it maintains the consistent concept of" channel" described above.

1 RAI 3.3.6.3-3:

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' Beyond Scope DOC M.1 ITS Condition B Comment:

The M-DOC can be used to justify adding functions to the LLS Instrumentation LCO, but additionaljustification is needed for proposed ITS required actions B.1, the note to B.1 and B.2.

The proposed ITS would allow operation indefinitely with 11 of 15 valves inoperable if at least the lowest SRV set point group is operable. CTS 3.4.2.2 requires the LLS function to be operable. It does not currently allow any portion of the LLS instrumentation to be inoperable without entry into an Action Statement. The proposed ITS are less restrictive and conform to neither the CTS nor the STS. Adopt either the CTS or the STS or provide a plant-specific justification for deviating from them.

Detroit Edison Response:

The STS does not reflect the Fermi 2 LLS design and is inappropriate to use as an alternative to the proposed ITS. The CTS is not specific as to the details of OPERABILITY with regard to the necessary tailpipe arming signals. ' As a result, when a tailpipe arming signal is inoperable the situation is currently evaluated on a case by case basis to determine the effect on the LLS system.

The LLS system can perform its intended safety function (i.e., be OPERABLE) with less than 15 tailpipe switches. Any added detail to the ITS reflects a new restriction. Detroit Edison believes it is highly desirable to include an appropriate restriction on inoperable tailpipe armirr 5nals and will provide additional conservatism 1o the originally proposed allowances.

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