View source for NRC-98-0037, Responds to NRC Request That Util Amend Proposed Change to Surveillance Requirement 4.3.1.3 That Clarified That Response Time Testing Is Done Only for Applicable RPS Functions,Per Licensee 971210 Amend Request

{{Adams
| number = ML20216F693
| issue date = 04/09/1998
| title = Responds to NRC Request That Util Amend Proposed Change to Surveillance Requirement 4.3.1.3 That Clarified That Response Time Testing Is Done Only for Applicable RPS Functions,Per Licensee 971210 Amend Request
| author name = Gipson D
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-98-0037, CON-NRC-98-37
| document report number = NUDOCS 9804170206
| package number = ML20216F695
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}

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: t. N                                                               Douglas R. Gi lwnn l
Senior Vice PresHent, Nuclear Generation l
i                                                Fermi 2 6400 brth Dixic Ilay., Newport, Miduttn 48166 Tch 31UacL201 F 313M;.4172 Detroit Edison 3                                                       '
10CFR50.92 April 9,1998 NRC-98-0037 1
1 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

==References:==
: 1) Fermi 2                                                                                    I NRC Docket No. 50-341 NRC License No. NPF-43                                                                   l l
: 2) Detroit Edison Letter to NRC, NRC-97-0105," Proposed Tecimical                            l Specification Change (License Amendment)- Neutron Monitoring l                                System," dated December 10,1997                                                          l
: 3) Detroit Edison Letter NRC-98-0029," Proposed Technical
(                                Specification Change (License Amendment)-Neutron Monitoring l                                System Correction Page," dated January 28,1998
: 4) NRC Information Notice 97-80:" Licensee Technical Specification Interpretations," dated November 21,1997

==Subject:==
Proposed Technical Specification Change (License Amendment)-
Neutron Monitoring System: Withdrawal of Previously Submitted                                !
Response Time Testine Reauirement Clarification                                              '
The Reference 2 letter proposed revisions to Fermi 2 Technical Specifications (TS) in support of the planned replacement of the power range portion of the Net: tron Monitoring System. The Reference 2 proposal was subsequently supplemented by the Reference 3 letter, which provided an additional TS page needed to properly implement the change. During a recent teleconference, P. Loeser, J. Mauck, and A.
Kugler of the NRC staff requested that Detroit Edison amend the proposed change to Surveillance Requirement 4.3.1.3 th.,t clarified that response time testing is done only for applicable Reactor Protection System (RPS) functions. Detroit Edison had
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NRC-98 0037 Page 2 proposed to add the word " applicable" to the Surveillance Requirement for response time testing to be consistent with the existing Bases discussion regarding " channels                !
with response times indicated as not applicable." This letter is provided in response to the staff request.                                                                                 l i
Reference 2, Enclosure I provided the description and evaluation of the TS changes related to the implementation of the Pcwer Range Neutron Monitoring (PRNM) modifications planned for the Fermi 2 sixth refueling outage. Part III of that enclosure evaluated changes not specifically addressed in plant specific actions l          identified in the General Electric Licensing Topical Report and the associated NRC Safety Evaluations. The following change described in Enclosure 1, Evaluation Section III of the Reference 2 request is being withdrawn:
A change was made to Surveillance Requirement 4.3.1.3 to clarify that the response time testing (RTT)is done only for applicable RPS functions. The associated Bases section further clarifies the source of R'IT requirements rc. UTS AR Table 7.2-4. These changes
!                   clarify an earlier license amendment that relocated these requirements from the TS. The l                   changes are made to imnrove clarity and do not change any TS requirements and, therefore, are not specifically sidressed in the No Significant flazards Evalu . tion or Environmental l                   Impact portion onhis submittal.
t The withdrawal of this portion of the previously submitted change can be l          accomplished by removing the word " applicable" previously added to Surveillance Requirement 4.3.1.3 and removing the sentence " Response time requirements are specified in UFSAR Table 7.2-4." from Bases Section 3/4.3.1. These changes do not invalidate any of the existing TS or remaining proposed changes as described in the Reference 2 and 3 letters. Detroit Edison has reviewed the analyses pertaining to l          both the issue of Significant Hazards Consideration and Environmental Impact provided in the Reference 2 letter, and has concluded that the previously submitted analyses are applicable and bound the proposed change as amended by this letter.
The enclosure provides the marked up pages of the existing TS (to show the cumulative effect of the proposed change including those in this letter) and a typed                  ,
version of the affected TS pages with the proposed changes incorporated. These                       l pages supersede the versions of the same pages provided in the Reference 7                            l submittal.                                                                                           !
1 Detroit Edison would like to reiterate that, in accordance with the proposed revised TS bases and tabular description provided in Enclosure 2 to the Reference 2 request,                 j Response Time Testing (RTT) is not applicable to Reactor Protection System Functional Units 2.a,2.b,2.c, and 2.d as listed in TS Table 4.3.1.1-1, but RTT is applicabh- to Functional Unit 2.e, the 2-out-of-4 Trip Voters. In addition, Detroit Edison maintains that although the NRC staff has requested that the enclosed change i
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      .. u USNRC NRC-98-0037 Page 3 l
be made to facilitate the review and approval of the PRNM TS changes as described in References 2 and 3, the original intent of proposing the change that is now being withdrawn by this letter was to clarify the TS to avoid potential differences in interpretation as described in NRC Information Notice 97-80.
Should you have any questions or require additional information, pleasc contact
                                                                                                )
Mr. Norman K. Peterson of my staff at (734) 586-4258.
Sincerely, Enclosures cc: A. B. Beach B. L. Burgess G. A. Harris A. J. Kugler Supervisor, Electric Operators, Michigan Public Service Commission l
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: o. s USNRC NRC-98-0037                                                                        l Page 4 I
l 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.
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i DOUGLAS R. GIPSON Senior Vice President Nuclear Generation On this                        day of      M          ,1998 before me personally appeared Douglas R. Gipson, being first ' duly sworn and says that he executed the foregoing as his free act and deed.
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Notary Public ROSAUE A. ARMETTA NOTARYPUBUC.MONRDEChus!TY,!!.I MYCOMMI6610NEXPlRES1W1Wa 5
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