View source for NRC-02-0055, Response to the Request for Additional Information Concerning Technical Specification Change Request Related to Response Time Testing

{{Adams
| number = ML022040634
| issue date = 07/16/2002
| title = Response to the Request for Additional Information Concerning Technical Specification Change Request Related to Response Time Testing
| author name = O'Connor W
| author affiliation = Detroit Edison
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000341
| license number = NPF-043
| contact person = 
| case reference number = NRC-02-0055, TAC MB5173
| document type = Letter type:NRC
| page count = 7
| project = TAC:MB5173
| stage = Request
}}

=Text=
{{#Wiki_filter:William T. O'Connor, Jr.
Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy., Newport, Michigan 48166 Tel: 734.586.5201 Fax: 734.586.4172 Detroit Edison 1                A DTE Energy Company 10CFR50.90 July 16, 2002 NRC-02-0055 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 (License Amendment)-Response Time Testing, NRC-02 0036, dated May 30, 2002

==Subject:==
Response to the Request for Additional Information Concerning Technical Specification Change Request Related to Response Time Testing (TAC No. MB5173)
On June 17, 2002, a teleconference between Detroit Edison and the NRC was conducted to discuss questions the NRC had pertaining to a Technical Specification change request to eliminate specific response time testing requirements (Reference 2). Detroit Edison's response to these questions is attached.
No commitments are being made in this letter.
()\

USNRC NRC-02-0055 Page 2 Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.
Sincerely, Attachment cc:    T. J. Kim M. A. Ring NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-02-0055 Page 3 I, WILLIAM T. O'CONNOR, JR., 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.
WILLIAM T. O'MNNOR, JR.
Vice President - Nuclear Generation On this                        day of          ,2002 before me personally appeared William T. O'Connor, Jr., being first duly sworn and says that he executed the foregoing as his free act and deed.
otary Public KAREN M.REED
                                          &#xfd;!OWta Public, Monroe County, My Commission Expires 09102/2005

USNRC NRC-02-0055 Page 4 bcc:   G. D. Cerullo D. K. Cobb R. W. Libra S. R. Peterman N. K. Peterson L. D. Sanders S. Stasek Electronic Licensing Library (ELL) (200 TAC)
Information Management (140 NOC)
Michigan Department of Environmental Quality Radiological Protection Section NSRG Secretary/ISEG Coordinator (200 TAC)
NRR Chron File G. S. Cashell R. W. Johnson

Attachment to NRC-02-0055 Page 1 Response to Request for Additional Information-TAC MB5173 Ouestion 1:
were not In Section B of Enclosure 1 to Reference 2, Affected Instrument Channels, trip units that the listed as components specific to the time response testing elimination request. Clarify license trip units for which response time testing elimination is being requested are a part of the amendment request. Include model information on the specific components.
Response to Question 1:
The following corrects and expands on the information listed in Section B of Enclosure 1 to Reference 2, Affected Instrument Channels.
Those components applicable to the requested changes are:
Trip Units, Rosemont 51 ODU/7 1ODU Agastat EGPB relays (incorrectly listed as EGPI on the original submittal *)
GE HFA relays, 12HFAl51A9 Scram Contactor, GE CR 305
* NEDO-32291-A, Supplement 1, approves both the EGPB (24 vdc) and EGPI (120 vac)
Ouestion 2:
Provide information in Enclosure 4 to Reference 2, Response to the Conditions Included in the NRC Staff' s Safety Evaluation Accepting NEDO-3229 1-A, Supplement 1, for the trip units.
Response to Question 2:
The following expands on the information provided in Enclosure 4 to Reference 2, Response to the Conditions Included in the NRC Staff s Safety Evaluation Accepting NEDO-3229 1-A, Supplement 1, for the trip units.
The Safety Evaluation Report states:
: 5. For trip units if the following requirements are met, no credible failure will increase response time to more than 24 ms without being detected by tests other than RTT.

Attachment to NRC-02-0055 Page 2
: a. The trip units are procured by the utility as "nuclear safety related", or are dedicated for nuclear-safety-related application under a utility dedication program.
Detroit Edison Response:
Fermi 2 trip units in the Reactor Protection System/Primary Containment Isolation Instrumentation are procured as "nuclear-safety-related".
Ouestion 3:
For the tables included in Section B of Enclosure 1 to Reference 2, Affected Instrument Channels, what are the specific manufacturer and models of components for which time response testing elimination is being requested? Include information for the sensors.
Response to Question 3:
The following expands on the information provided in Section B of Enclosure 1 to Reference 2, Affected Instrument Channels, by adding a row for component manufacturer/model, including the sensors, and a note below the tables.
The following tables show Fermi 2 BRT calculation using 

==Reference:==
NEDO-32291-A Supplement 1, Table C.2-1 "Component Sets and Component BRT's."
Loop Type H reactor vessel steam dome pressure high Component      Sensor      Trip Unit   TU         Logic Relay   Output      Loop    Channel (TU)       Output                    Contactor  Logic   BRT Relay                                BRT Response       200 ms       24 ms       140 ms    40 ms          45 ms      249 ms  .449 sec Time Manufacturer Rosemont       Rosemont Agastat      GE             GE         NA      NA
 /Model          1153GB**    510DU/     EGPB       12HFA151A9     CR305 710DU

Attachment to NRC-02-0055 Page 3 Loop Type E* (* Additional Auxiliary Relay) reactor vessel water level-low low low, level 1 Component      Sensor       Trip Unit  TU       Logic    Auxiliary  Output    Loop    Channel (TU)       Output   Relay    Relay      Relay     Logic   BRT Relay                                  BRT Response       400 ms       24 ms      140 ms   40 ms    40 ms      40 ms     284     .684 sec Time                                                                          ms Manufacturer   Rosemont     Rosemont   Agastat  GE       GE         GE        NA     NA
 /Model         1153DB**     510DU/     EGPB     12HFAl   12HFA1     12HFA1 710DU               51A9     51A9       51A9 main steam line flow-high Component      Sensor     Trip Unit   TU       Logic   Auxiliary   Output    Loop    Channel (TU)        Output   Relay    Relay      Relay     Logic   BRT Relay                                  BRT Response        Horns      24 ms       140 ms   40 ms   40 ms       40 ms     284 ms  .394 sec Time Manufacturer    Rosemont   Rosemont    Agastat  GE      GE          GE        NA      NA
/Model          1151DP**   510DU/      EGPB     12HFAI   12HFAI     12HFAI 1152DP**   710DU                51A9    51A9        51A9
"**Themanufacturer and model numbers for the sensors are included in Table 7-1 of NEDO 32291-A, October 1995. The sensor response times are different based on the sensor range code and the intended design function. The response time for the sensors are less than or equal to the acceptable limits specified by the manufacturer and within the Bounding Response Time (BRT) for the intended design function. This is documented in Fermi Design Calculation DC-4768 Volume I, Revision 0.}}