View source for 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 Included

{{Adams
| number = ML20196F456
| issue date = 06/24/1999
| title = 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
| 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-99-0050, CON-NRC-99-50
| document report number = NUDOCS 9906290212
| package number = ML20196F465
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 26
}}

=Text=
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Douglas R. Gipson Senior Vice Preshlent, Nuclear Generatinn Fermi 2 6400 North Dixie liwy., Newport, Michigan 4S166 Tel: 734.586.5201 Fax: 734.586.4172 Detroit Edison June 24,1999 NRC-99-0050 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)-Conversion to                                                     3 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, Section 3.5, for Fermi 2 (TAC No. MA1465)",                                      ,
dated January 25,1999
: 4) NRC Letter to Detroit Edison " Request for Additional Information Regarding Conversion to Improved Standard Technical Specifications, Section 3.8, for Fermi 2 (TAC No. MA1465)",                                           .
dated December 22,1998 -
g

==Subject:==
Transmittal of Revision 7 to Fermi 2 Improved p       ,
Technical Specification Submittal (TAC No. MA1465)
Attached please find Revision 7' to the Fermi 2 Improved Technical Specification (ITS) Submittal (Reference 2). The purpose of this revision is to provide the                          :
   ' 9906290212 990624 POR  ADOCK.05000341 P                 PDR A DTE Energy Company l
j

USNRC NRC-99-0050 Page 2 l
remaining responses to the NRC Requests for Additional Information (RAI) conceming ITS Sections 3.5 (Emergency Core Cooling Systems and Reactor Core Isolation Cooling System) and 3.8 (Electrical Power Systems) contained in
- References 3 and 4. An update to the ITS submittal to reflect these responses is included. In addition, other needed changes to the afTected ITS sections are also included. Attachment I contains a brief abstract of the changes included in this revision. Attachment 2 contains the responses to the Reference 3 and 4 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 stafrat (734) 586-4258.
l Sincerely, Attachments cc:   A. J. Kugler A. Vegel NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission i
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i 7-l'      USNRC                                                                               !
NRC-99-0050 Page 3 l
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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.                                                                         l l
M DOUGLAS R. dIPSON                             l Senior Vice President, Nuclear Generation     !
On this                        day of  Id "         ,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.                                                 1 I
i Notary Public m a umvoscowg.W MycanniukaspineMW

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ATTACHMENT I TO NRC-99-0050 i
ABSTRACT OF REVISION 7 TO THE FERMI 2 IMPROVED TECHNICAL SPECIFICATION SUBMITTAL I

l                                                                                              t Abstract of Revision 7 to the Fermi 2 Improved Technical Specification Submittal 1
Revision 7 to the Fermi 2 Improved Technical Specification (ITS) submittal incorporates        )
the responses to the attached Requests for Additional Information (RAI) for ITS Sections 3.5 (Emergency Core Cooling Systems and Reactor Core Isolation Cooling) and 3.8 (Electrical Power Systems). Revision bars are provided to aid in identification of the    t l    changed material. For those changes associated with an RAI, the RAI number is included
!    with the revision bar.
l Minor corrections are included in this revision. These changes consist of various format, l    spelling, labeling, and editorial enhancement and/or technical changes (typically              l identified during implementation preparation. The revision bars for these changes are     s    !
marked with a circled "A."
The following lists specific changes in Revision 7:
1 Clean-typed pages that are Aluded for replacement solely due to "page-roll" changes from other RAI-related changes (annotated next to the page footer).
Typographical errors have been corrected in: ITS 3.5.2, DOC LA.1 and ITS 3.8.1, DOC L.2.                                                                  '
In ITS 3.5.1, the markup of CTS 4.5.1.a.2 has been annotated with DOC A.13.
This annotation was missing although DOC A.13 was included in the submittal.
In ITS 3.5.2, SR 3.5.2.4, for the LPCI swing bus automatic throwover, is removed (and other Surveillance Requirements renumbered). ITS 3.5.2, DOC A.13 addresses this change.
ITS 3.5.2 has been revised to reflect CTS Amendment #131.
ITS 3.8.1 Bases for Actions A.5 and A.6 has been editorially reformatted.
ITS provisions for Emergency Diesel Generator Lube Oil have been removed.       5 JFD P.5 addresses this change.
ITS 3.8.3 Bases for SR 3.8.3.2 has been corrected to accurately reflect applicability of ASTM-975.
ITS 3.8.4, DOC LA.3 was editorially revised based on discussions held in a meeting with the NRC.                                                             ;
ITS 2.5.1 has been revised to reflect CTS Amendment #133.
In addition, changes are made associated with generic changes to the STS. The revision bars for these changes are marked with a circled "B."
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ATTACHMENT 2 TO NRC-99-0050 DETROIT EDISON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTIONS 3.5 AND 3.8 FOR FERMI 2 (TAC NO. MA1465)

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REQUEST FOR ADDITIONAL INFORMATION REGARDING                                 -
CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SECTION 3.5 FOR FERMI 2 (TAC NO. MA1465)
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. References to an improved TS (ITS) mean the proposed converted TS submitted by the licensee.
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               i October 26,1998, RAl. Additional DOCS affected by this issue are listed in the following table:
ITS                         LA DOC                               .,
3.5.1                         LA.1 DECO response:
ITS 3.5.1 DOC LA.1 has been modified as requested.
Section 3.5, Emeraency Core Coolina Systems (ECCS) and Reactor Core isolation Coolina (RCIC) System 3.5.1 ECCS - Operating 3.5.1.-1      Current TS (CTS) 3.5.1 Action b.2 and footnote #
CTS 3.7.1.2 Action a.3 DOC L.3 ITS 3.5.1 Condition C                                                             .
Justification For Difference (JFD) P.1.a CTS 3.5.1 Action b.2 allows 7 days to restore an inoperable low pressure coolant injection (LPCI) subsystem provided both core spray system (CSS) subsystems are operable.
Footnote # to Action b.2 provides an exception that one CSS subsystem and one LPCI subsystem may be inoperable due to a lack of emergency equipment cooling water (EECW) cooling provided the Actions of CTS 3.7.1.2 are taken. CTS 3.7.1.2 Action a.3 allows 72 hours to restore an inoperable EECW subsystem. Proposed ITS 3.5.1 Condition C allows one CSS subsystem and one LPCI subsystem to be inoperable for 72 hours for any reason. The STS            ,
would require entry into limiting condition for operation (LCO) 3.0.3 in this situation.
Comment: This proposed Action is a change to the CTS and a change to the STS and is beyond the scope of the conversion review. However, the staff has previously stated in the i

safety evaluation to Amendment No. 80, dated March 9,1992, that the existing evaluation in the Updated Final Safety Analysis Report (UFSAR) of a failure of a divisional battery provides a conservative evaluation of the impact on the ECCS of a loss of a division of LPCI and CSS. The ECCS performance evaluation shows that a'l                 s ECCS acceptance criteria of 10 CFR 50.46 are met. Therefore, this proposed change has been forwarded to the appropriate NRC technical staff for review. Any questions concerning this change will be forwarded to you separately. No action on your part is               !
required at this time.
DECO response:
No action required.
3.5.1-2       CTS 3.5.1 Action c DOC L.2 ITS 3.5.1 Condition F JFD P.1.a CTS 3.5.1 Action c.1 allows 14 days to restore an inoperable high pressure coolant injection (HPCI) system provided the CSS and the LPCI system are operable. The CTS would require             ]
entry into LCO 3.0.3 for the combination of HPCI and one or more low pressure subsystems inoperable. However, footnote # to Action c provides an exception that one CSS subsystem and one LPCI subsystem may be inoperable due to a lack of EECW cooling provided the Actions of CTS 3.7.1.2 are taken. CTS 3.7.1.2 Action a.3 allows 72 hours to restore an inoperable EECW mjbsyrtem. Under those limited conditions (one CSS subsystem and one LPCI subsystem insperable due to a lack of EECW cooling), the CTS would allow the HPCI system and one CSS subsystem and one LPCI subsystem to be inoperable for 72 hours.
Proposed ITS 3.5.1 Condition F allows the HPCI system and one CSS subsystem and one LPCI subsystem to be inoperable for 72 hours for any reason. The STS would require entry into LCO 3.0.3 in this situation.
Comment: This proposed Action is a change to the CTS and a change to the STS and is beyond the scope of the conversion review. DOC L.2 states that this change is acceptable because the proposed condition results in adequate ECCS systems available to respond to a design basis loss-of-coolant accident (LOCA). The staff has previously stated in the safety evaluation to Amendment No. 80, dated March 9,1992, that the existing evaluation in the UFSAR of a failure of a divisional battery provides a conservative evaluation of the impact on    3 the ECCS of a loss of a division of LPCI and CSS. Loss of the Division 11 battery, as analyzed in the UFSAR, would cause a loss of HPC' and a division of LPCI and CSS. The ECCP performance evaluation shows that all ECCS acceptance criteria of 10 CFR 50.46 are met.                i Therefore, this proposed change has been forwarded to the appropriate NRC technical staff for review, Any questions concerning this change will be forwarded to you separately. No action on your part is required at this time.
l

DECO response:
This issue remains open pending the separate technical staff review. ITS Condition J has been modified to eliminate a contradictory requirement to enter LCO 3.0.3 for the combination of Conditions C and E (which is intended to be addressed by Condition F).
3.5.1-3       CTS 3.5.1 Action d                                                                  v DOC L.2 ITS 3.5.1 Condition H JFD P.1.a CTS 3.5.1 Action d.1 allows 14 days to restore an inoperable ADS valve provided the CSS and the LPCI system are operable. The CTS would require entry into LCO 3.0.3 for the combination of one ADS valve and one or more low pressure subsystems inoperable. Proposed ITS 3.5.1            i Condition H allows one ADS valve and one CSS subsystem and one LPCI subsystem to be inoperable for 72 hours for any reason. The STS would require entry into LCO 3.0.3 in this situation.
Ccmment: This proposed Action is a change to the CTS and a change to the STS and is beyond the scope of the conversion review. DOC L.2 states that this change is acceptable because the proposed condition results in adequate ECCS systems available to respond to a design basis LOCA. However, the staff has not specifically reviewed this combination of ECCS inoperabilities and its effect on the accident analyses. This proposed change has been forwarded to the appropriate NRC technical staff for review. Any questions concerning this        ;
change will be forwarded to you separately. No action on your part is required at this time.
DECO response:
Based upon discussions with the NRC, Condition H has been modified to eliminate the combination of one ADS valve, one CSS subsystem and one LPCI subsystem from the           i condition. This combination will now require entry into LCO 3.0.3.                            ;
3.5.1-4       CTS 4.8.3.1.2 DOC L.5 ITS SR 3.5.1.2 JFD P.1.d CTS 4.8.3.1.2 and ITS SR 3.5.1.2 require demonstration of the LPCI swing bus automatic transfer scheme. DOC L.5 and JFD P.1.d state that performance of this test requires that the swing bus (and therefore both LPCI subsystems) be made inoperable. To preclude intentional        '
entry into LCO 3.0.3, you have proposed adding a Note to SR 3.5.1.2 allowing a delay in entering the actions for the inoperability caused by (1) performing this required surveillance or (2) performing reouired testing of emergency diesel generator 12.
* Comment: Whilu the staff agrees in concept with the addition of a note, the staff is concerned that the note provides for an indefinite delay in entering the actions despite your assertion in DOC L.5 that the period of inoperability would be much less than one hour. The staff believes

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that a finite time period for delaying entry into the' actions is more appropriate. The staff also notes that JFD P.1.a and the markup of the STS Bases indicate that the Note only allows a 1-hour delay. The inconsistency between the various markups, clean copy of the ITS, the DOC, and the JFD needs to be reconciled when this issue is resolved.
DECO response:                                                                                       i
                - Based upon discussions with the NRC, the ITS now limits the use of the allowance to 12 hours. The inconsistencies noted have been reconciled.
i 3.5.1-5        CTS 4.3.3.3 & Footnote **
No DOC ITS SR 3.5.1.14 JFD P.5 -
CTS 4.3.3.3 requires demonstration that the ECCS response time of each ECCS trip function is within the limit once per 18 months. Footnote " states that ECCS actuation instrumentation response time need not be measured and may be assumed to be the design instrumentation response time. This requirement is moved to ITS SR 3.5.1.14.
i Comment: The Note to SR 3.5.1.14 states, "ECCS instrumentation response times are not required to be measured." This note is different from the CTS note and no DOC is provided to           ,
justify the difference. The ITS Bases for SR 3.5.1.14 state that the contribution of the                '
instrument response times to the overall ECCS response time are assumed based on guidance of NEDO-32291 and the safety evaluation for Fermi 2 Amendment No. iii, dated April 18.
       '1997. Please provide a DOC justifying the differences between the CTS footnote " and the g
note to lTS SR 3.5.1.14. This issue is similar to that discussed in RAI 3.3.1.1-12 and a similar -  -
resolution would be acceptable.
                                                                                                                 ]
DECO response:
                ~ The change is now addressed in a new DOC, LA.5 (to relocate this detail to the Bases),
This DOC is modeled after the same relocation for the RPS Response Time Test (DOC LA~ 12 for ITS 3.3.1.1).
l 3.5.1-6       CTS 3.5.1 Action g DOC LA.3 DOC LA.3 states that the requirements of CTS 3.5.1, Action g are adequately addressed by 10 CFR 50.73(a)(2)(iv).
       - Comment: It appears that this change would more appropriately be categorized as an "LR" change since the requirements in CTS 3.5.1, Action g, are not being relocated to a licensee-       I controlled program with regulatory program controls, but, rather, are being deleted from TS because they duplicate other requirements. Please reclassify this change or provide an explanation of why this change is appropriately classified as an "LA" change.
I
           \

{                                                                                                      s DECO response:
DOC LA.3 has been reclassified as DOC LR.3.
3.5.1-7       STS 3.5.1 Bases Background Page B 3.5-3 JFD P.6 This change adds words to the 3.5.1 Bases Background section to clarify that the full flow test lines are not required to support LPCI operability. JFD P.6 states that this is added clarification as to the relationship of the LPCI test line to ECCS-LPCI operability.
Comment: The staff would like some additional explanation as to why you feel addition of these      j words to the Bases are necessary.
DECO response:
The addition to the Bases addressed by JFD P.6 has been determined to be unnecessary and has been eliminated.
3.5.2 ECCS - Shutdown 3.5.2-1       CTS 4.8.3.2.2 DOC L.2 ITS 3.5.2.4                                                                              ,
JFD P.1 Comment: This is the same issue identified in RAI 3.5.1-4. Only one response is necessary.          .,
DECO response:
Detroit Edison has determined that the automatic throwaver surveillance requirement is not needed in ITS for the shutdown conditions. This change is addressed by DOC A.13.
3.5.2-2      CTS 3.5.2, CTS 3.5.3.b and Action b DOC A.7 ITS 3.5.2, Actions A & B and SR 3.5.2.2 CTS 3.5.2 requires two low pressure emergency core cooling subsystems to be operable. If one of the required systems is inoperable, Action a. allows 4 hours to get back to two operable subsystems. Otherwise, it requires the licensee to suspend operations with a potential for draining the reactor vessel (OPDRVs). CTS 3.5.3 requires the suppression pool to be operable
  . but allows the level to be below the limit (including completely drained) in Modes 4 and 5 provided certain conditions are met. One of these conditions is that no OPDRVs are performed.       ,
The two TS are related because the suppression pool is the suction source for the LPCI subsystems and one of the possible suction sources for the CSS subsystems. If the

i suppression pool level is below the limit in CTS 3.5.3.b, the LPCI subsystems would be inoperable and the CSS subsystems would be operable only if there was adequate water in the condensate storage tank (CST) and the CSS subsystems were aligned to take suction from the CST. With both CSS subsystems operable with suction from the CST, CTS 3.5.2 would not prohibit the licensee from performing OPDRVs. However, CTS 3.5.3.b would prohibit OPDRVs           ,
because the suppression pool level is below the limit.
In ITS 3.5.2, the aspects of CTS 3.5.2 and 3.5.3 related to the operability of ECCS are combined. SR 3.5.2.2 requires the licensee to verify that the suppression pool level is within limits or that adequate volume is available in the CST. However, a note to this SR indicates that only one CSS subsystem can take credit for the CST as a suction source during OPDRVs.
Under these circumstances (performing OPDRVs), the licensee would enter Action A for one of the two required subsystems inoperable. This would allow 4 hours to restore a second subsystem. If this time is not met (which would happen if the suppression pool is intentionally drained), Action B. requires the licensee to initiate actions to suspend OPDRVs.                       '
Comment: The staff considers this allowance of the 4-hour action time before taking action to     4 suspend OPDRVs as less restrictive than the CTS for the case in which the suppression pool             .
level is below the limit. However, you indicated it was an administrative change. Please revise the DOC for this change to a less restrictive DOC or provide additional explanation as to why I
this change is appropriately categorized as an administrative change.
DECO response:
This change has been reclassified as Less Restrictive and is now addressed in DOC L.3.
3.5.3 RCIC System No questions.
                                                                                                  ?
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REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS, I
SECTION 3.8 FOR FERMI 2 (TAC NO. MA1465)                                .
General Note: Throughout this request for additional information (RAI), references to a l  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,"
Revislon 1. References to an improved TS (ITS) mean the proposed converted TS submitted             l l  by the licensee.                                                                                    l l
All Sections l                                                                                                    s
;  RAI 0.0-1: There is a generic issue involving a number of the Less Restrictive Administrative I  (LA) discussions of change (DOCS) in the Fermi submittal. Refer to RAI 0.0-1 in the October 26,1998, .RAl. Additional DOCS affected by this issue are listed in the following table:
l ITS                         LA DOC 3.8.1                          LA.1 i
l l                              3.8.1                          LA.3                                     i 1
3.8.2                          LA.1                                     1 3.8.2                          LA.3                                     )
3.8.4                          LA.1 l                              3.8.4                          LA.3                                   '
l 3.8.5                          LA.1 1
1 l  Detroit Edison Company (DECO) Response                                                              J The affected LA DOCS have been modified as requested.                                         1 Section 3.8                                                                                         j 3.8.1-1      Current technical specification (CTS) 3/4.8.1.1 Actions b.2 and b.3 Discussion of Change (DOC) LR.4 ITS 3.8.1 Required Action A.4 and Completion Time Bases for ITS 3.8.1 Requi.ed Action A.4, STS Bases markup page B 3.8-10 insert 3a                                                        ,
Action b.2 for CTS 3/4.8.1.1 requires verifying within 8 hours and at least once per 8 hours
: 1. thereafter, that combustion turbine-generator (CTG) 11-1 is operable. In the event that this        ;
requirement cannot be met, Action b.3 for CTS 3/4.8.1.1 requires restoration of CTG 11-1 to         i Operable status within 72 hours. Required Action A.4 for ITS 3.8.1 requires the licensee to l
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determine CTG 11-1 is available with a Completion Time of 72 hours from discovery of Condition A (one or both emergency diesel generators (EDGs) inoperable in one division) concurrent with CTG 11-1 not available. The use of the term available, as defined in the Bases, in place of operable, is acceptable. However, the deletion of the CTS requirement to periodically verify CTG 11-1 is operable does not appear to be acceptable. The proposed ITS          i do not include a specific requirement to verify CTG 11-1 operability within a given period of time.
The ITS requirement is to verify CTG 11-1 availability within 72 hours of determining its           !
non-availability, but there is no requirement to determine availability at the time the EDGs become(s) inoperable. The determination of CTG 11-1 availability appears to be floating in the ITS with no specific time constraints. This is not acceptable. The licensee should revise the          l submittal to address the staff concerns. The Bases discussion of Actions A.4 and A.5 may require revision as a consequence of responses to staff comments on ITS Actions A.4 and A.S.
DECO Response:
A new Required Action A.3 has been added to " Verify the status of CTG 11-1, once per 8 hours." Also, based on discussions with the NRC involving this resolution, the original ITS Required Action A.4 (now renumbered to A.5) has been reworded to " Restore availability of CTG 11-1."
l 3.8.1-2      ITS/STS surveillance requirement (SR) 3.8.1.2 Justification For Difference (JFD) P.5 CTS 4.8.1.1.2.a.4 Bases for ITS SR 3.8.1.2, STS Bases markup page B 3.8-16                               -
The staff does not agree with deleting Note 3 from this SR. The intent of this Note is to recognize that certain EDG vendors recommend modified start procedures, and to make specific provision for using these procedures. The first sentence in the Note should be retained.
Deletion of the second sentence in the Note is acceptable based on the CTS.
DECO Response:
The first sentence of SR 3.8.1.2, Note 3, has been retained.
3.8.1-3      Resolved in the December 4,1998, meeting.                                               i 3.8.1-4      Bases Pg. B 3.8-16 ITS SR 3.8.1.2 This Bases section includes a discussion of modified DG starts. The proposed ITS deletes the        ,
Note in SR 3.8.1.2 which addresses modified starts. In light of this, the proposed Bases is not acceptable because the Bases can only include discussions of what is included in the TS. This Bases discussion would be acceptable if the licensee agrees to retain the Note in SR 3.8.1.2.
(See comment 3.8.1-2.)
DECO Response:
This Bases section has been retained based on resolution of RAI 3.8.1.2. Bases reference to Note 3 have been reinstated.
I

i 3.8.1-5      ITS/STS SR 3.8.1.7 The licensee should venfy that the mi11 mum values of 3740 VAC and 58.8 Hz are the minimum values necessary in order for the EDG to accept post accident loads.
DECO Response:
Detroit Edison has confirmed that the EDG is capable of accepting post accident loads at the specified minimum values of 3740 VAC and 58.8 Hz.
v 3.8.1-6      DOC L.5                                                                             ,
ITS Surveillance Requirements (SRs) 3.8.1.7, 3.8.1.11, and 3.8.1.14                      l Bases for ITS SRs 3.8.1.7, 3.8.1.11, and 3.8.1.14 CTS 4.8.1.1.2.a.4 and 4.8.1.1.2.e.5 STS SRs 3.8.1.7, 3.8.1.12, and 3.8.1.15                                                  l l
STS SRs 3.8.1.7,3.8.1.12, and 3.8.1.15 require the generator voltage and frequency to be            1 within specific tolerance bands within 10 seconds after the start signal. Corresponding CTS         {
4.8.1.1.2.a.4 and 4.8.1.1.2.e.5 require the generator voltage and frequency to be 4160 t 420 l
volts and 60 i 1.2 Hz within 10 seconds after the start signal. This requirement has not been       .
retained in corresponding ITS SRs 3.8.1.7,3.8.1.11, and 3.8.1.14, which require achieving a voltage 0 3740 V and a frequency 0 58.8 in 010 seconds. This proposed change appears to             4 be the incorporation of Technical Specifications Task Force (TSTF) 163, Rev. 2. However, no           l mention of the TSTF is made. Make appropriate reference to the TSTF or other basis for the change. In addition, address the following:
                                                                                                'I
: a. The TSTF revises the bases to include periodic monitoring and trending of the time the EDG takes to reach steady state in order to identify degradation of governor and voltage regulator performance. This portion of the TSTF was not incorporated,
: b. Similar changes would apply to ITS SR 3.8.1.18 but were not incorporated.
DECO Response:
TSTF-163, Rev 2 has now been fully incorporated.
3.8.1-7      Response to 3.8.1-6 will resolve this item.
3.8.1-8      STS SR 3.8.1.8 JFD P.1                                                                             i The generic JFD P.1 does not provide an adequate justification why this STS SR is not included  y
                                                                                                 ~
in the ITS. The licensee should provide the justification.                                            l 1
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7-s DECO Response:
The Fermi 2 electrical design is such that each ESF division is not allowed to be                 I transferred to the opposite division offsite source during plant operation. An offsite power      ;
source is cross-tied to the opposite division only in maintenance situations. JFD P.1 has         l been modified to reflect this justification.
r                                                                                                     ,
i 3.8.1-9 ~     Resolved in the December 4,1998, meeting.
   -3.8.1-10      CTS 4.8.1.1.2.e.7                                                                           4 ITS SR 3.8.1.12 STS SR 3.8.1.13                                                                            ..
JFD P.1 JFD P.1 does not provide a discussion on why that part of the STS SR dealing with "(actual or        I simulated loss of voltage signal) on the emergency bus concurrent with" is deleted from the SR.           l The licensee is requested to provide this justification.                                                  I DECO Response:
The bypass of Fermi 2 EDG automatic trips on ECCS initiation signals does not require a       .
concurrent bus loss of voltage signal. JFD P.1 has been modified accordingly,                i i
1 3.8.1-11'     CTS 4.8.1.1.2.a.4 and "*" footnote                                                           i Bases Pg. B 3.8-16                                                                          !
ITS SR 3.8.1.2 and SR 3.8.1.7 The CTS markup for the "*" footnote to 4.8.1.1.2.a.4 indicates that the note to ITS SR 3.8.1.7 was intended to include the phrase "and followed by a warmup period prior to loading."
However, neither ITS SR 3.8.1.7 nor its Bases reflect this portion of the note. The note to the SR and Insert B 3.8.1-6 could be expanded to include SR 3.8.1.7 A warmup period prior to             I loading would be permissible (assuming the DG vendor recommends a warmup period with the DG running at synchronous speed).
DECO Response:                                                                                       '
The phrase "and followed by a warmup period prior to loading" ;has been added to the ITS           !
Note for SR 3.8.1.7.                                                                            l  ,
3.8.1-12      STS Bases Markup, pages B 3.8-17 and B 3.8-18                                               I
                 - STS/ITS SR 3.8.1.3 and SR 3.8.1.2 There are two issues:
: a. . In the last paragraph of the discussion on SR 3.8.1.2 and the third paragraph of the discussion on SR 3.8.1.3, the licensee proposes to add "as modified by GL [ Generic
                                                                                                         ?
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Letter] 94-01" to " Regulatory Guide 1.9." The staff is not aware of any reference to Regulatory Guide 1.9 in GL 94-01. Clarify this proposed addition.
: b. The staff does not fully understand what is intended by insert B 3.8.1-4. The insert is unclear, especially with regard to that part of the insert which addresses " jeopardizing overloading the EDG." The licensee should consider revising the insert to clarify it.
DECO Response:
: a. The reference to GL 94-01 has been eliminated.
: b. As discussed with the NRC, the Insert has been modified to replace the word
             " jeopardizing" with the phrase "the risk of."
i 3.8.1-13      CTS 4.8.1.1.2.e.8 Bases Pg. B 3.8-27 ITS SR 3.8.1-13 s
The SR does not contain a requirement to conduct this SR at a specified power factor.
However, conducting this SR at a power factor of 0.9 or less is the best way to demonstrate DG OPERABILITY. Should these Bases be revised to state that, while not required, the SR is normally conducted at some target power factor?
DECO Response:
The Bases for SR 3.8.1.13 has been revised to address power factor. This revision is based on the power factor discussion in the Bases for ITS SR 3.8.1.3.
3.8.1-14      DOC L.6 ITS SR 3.8.1.14 Note 1 CTS 4.8.1.1.2.e.8 footnote
* Bases for ITS SR 3.8.1.14, STS Bases markup page B 3.8-28 Note 1 for ITS SR 3.8.1.14 refers to EDG operation for greater than or equal to 2 hours loaded greater than or equal to 2500 kW. The remainder of Note 1 states, " Momentary transients            .,
outside of load range do not invalidate this test," which is a proposed change relative to footnote
* for CTS 4.8.1.1.2.e.8. The Bases for ITS SR 3.8.1.14 also refers to a load band. DOC L.6 also refers to a load range. There is an apparent inconsistency within Note 1 in that no load range is provided. Revise the submittal to resolve this apparent inconsistency and provide the appropriate justification.
DECO Response:
The
* load band" sentence has been removed from the Bases. As agreed to in meetings           ,
with the NRC, the L.6 discussion is appropriate since it refers to the noted allowance within the SR. The " range" referred to in the DOC and the SR is a reference to a ">" load va!ue.
3.8.1-15      ITS SR 3.8.1.3 Bases for ITS SR 3.8.1.3, STS Bases page B 3.8-17, last paragraph v

r ITS SR 3.8.1.3 requires loading to greater than or equal to 2500 kW. The Bases for ITS SR 3.8.1.3 refers to a load band. There is an apparent discrepancy between ITS SR 3.8.1.3 and its Bases.' Revise the submittal to resolve this apparent discrepancy.                               9 I
DECO Response:
    ,       The " load band" sentence has been removed from the Bases.
3.8.1-18     Resolved in the December 4,1998, meeting.
3.8.1-17     DOCS A 4, LA'3, LA.4, and LR.1 CTS 3/4.7.1.4 CTS 3/4.8.1.1 CTS 3/4.8.1.2 ITS 3.8.1 CTS 3.7.1.4 provides requirements for the diesel generator cooling water system that supports CTS 3/4.8.1.1 and 3/4.8.1.2. It has been proposed to move some of these requirements to the Bases and the Updated Final Safety Analysis Report, and to delete the rest. CTS 3/4.7.1.4        il appears to satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). Revise the submittal to include an ITS specification and bases that address these requirements, or altematively, incorporate these requirements into ITS 3.8.1.
DECO Response:
Diesel generator cooling water system requirements will be incorporated into ITS Chapter 3.7. This material will be provided in the scheduled update to Chapter 3.7.
3.8.2-1      CTS 3.8.1.2, Action a DOC LA.2 DOC LA.2 should be revised to include a reference to compliance with GL 80-113 and NUREG-0612 with respect to crane operations and heavy load handling.                              1 DECO Response:
DOC LA.2 has been revised to include "...(which are in accordance with Fermi-2 positions   v on NUREG-0612 and Generic Letter 80-113)".
3.8.2-2      CTS 4.8.1.2 DOC L.1 STS/ITS SR 3.8.2.1 For consistency, unless otherwise noted this comment will discuss SRs in terms of the numbering in the ITS. CTS 4.8.1.2 requires the power sources to be demonstrated operable per (ITG) SRs 3.8.1.1, 3.8.1.2, and 3.8.1.4 through 3.8.1.18. STS SR 3.8.2.1 indicates that ITS SRs 3.8.1.1 through 3.8.1.17 are applicable. (Note that STS SRs 3.8.1.8 and 3.8.1.17 were not
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adopted because they are not in the CTS.) ITS SR 3.8.2.1 also indicates that ITS SRs 3.8.1.1 L    through 3.8.1.17 are applicable. In the STS, a note is included that indicates that (ITS) SRs 3.8.1.3,3.8.1.8 through 3.8.1.10, and 3.8.1.12 through 3.8.1.17 are not required to be l    performed. In the ITS, this note is modified to indicate that SRs 3.8.1.2,3.8.1.3, and 3.8.1.7
: l. through 3.8.1.17 are not required to be performed. The ITS note relieves the licensee from the requirement to perform three SRs (3.8.1.2,3.8.1.7, and 3.8.1.11) that are required by the STS.
DOC L.1 discusses the exclusion of SR 3.8.1.18, a change from the CTS. DOC L.1 also states that the ITS note is consistent with the STS. However, as discussed above, this is not correct.
The DOC indicates that the SRs which are not required to be performed are excepted because they would require rendering an operable EDG inoperable, de-energizing a required onsite power source, or disconnecting from a required offsite source. The staff does not consider SRs 3.8.1.2,3.8.1.7, and 3.8.1.11 to fall into this category. Modify the note to conform to the STS or  I provide additional justification for the exception for these three SRs.
DECO Response:
l          DOC L.1 has modified to provide additionaljustification. As the Bases discuss, the intent of the exception list is to exclude SRs that might result in the OPERABLE EDG being paralleled or being "otherwise rendered inoperable during the performance of the SRs", in l          the Fermi design, each EDG is rendered inoperable on sny Surveillance start. ITS SRs l          3.8.1.2,3.8.1.7, and 3.8.1.11 are SRs requiring only an EDG start. Therefore, these SRs l          are appropriate to include in the exception list.
3.8.2-3       Resolved in the December 4,1998, meeting.                                            I 3.8.3-1       Resolved in the December 4,1998, meeting.                                             I 3.8.3-2      JFD P.4 Bases for ITS SR 3.8.3.3, STS Bases markup page B 3.8-46 i-               Bases for STS SR 3.8.3.3 The Bases for STS SR 3.8.3.3 states, ". . but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days." This has been modified in the Bases for corresponding ITS SR 3.8.3.3 which states, " . but in no case is the time between sampling (and associated results) of new fuel and addition of new fuel oil to the storage tank to exceed 31
   . days." JFD P.4 does not explain why this proposed difference is acceptable. Revise the submittal to provide the appropriate justification, or conform to the STS. A time line representation of the STS and the ITS Bases descriptions should accompany the justification.
1 DECO Response:                                                                                      !
Given the varying options for " receipt" of fuel oil, there may be potential delays between
           " receipt", sampling, analysis, and addition to the EDG storage tank. Therefore, additional detailed clarification is appropriate. The Bases presented in the STS assumes that any and all fuel oil received is promptly added to the storage tanks (after initial sampling).
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I The clarification is needed specifically in the event fuel oil is " received" and stored on site for a period prior to addition to the tanks. The inference in the ITS Bases would be that a         !
fully tested sample is required within 31 days after this " receipt"; even if it is many months      l before the fuel oil is to be added to the storage tank.
The correct intent is supplied with this change (which is the same as the STS in the event          i the fuel oil is promptly added). The sample that will have a detailed follow-up analysis must be a recent sample of fuel oil; taken no more than 31 days before addition. This will leave a window for receipt of the sample analysis results from 31 days prior to addition to up to 31 days after addition.
s 3.8.3-3        JFD P.4 Bases for ITS SR 3.8.3.3, STS Bases markup pages B 3.8-47 and B 3.8-47 (insert)
Bases for STS SR 3.8.3.3 The Bases for STS SR 3.8.3.3 states, "Within [31] days following the initial new fuel oil sample,          l the fuel oil is analyzed . ." This has been modified in the Bases for corresponding ITS SR l
3.8.3.3 which has not adopted the reference to "31 days" at the beginning of the paragraph, and          i
    - has inserted, "These additional analyses are required .., to be performed within 31 days                    !
following sampling and addition." The " sampling and addition" referred to in the Bases insert for
    ' ITS SR 3.8.3.3 do not seem to be concurrent events, which would make the 31 day time limit ambiguous. JFD P.4 does not explain why this proposed difference is acceptable. Revise the submittal to provide the appropriate justification, or conform to the STS. A time line representation of the STS and the ITS Bases descriptions should accompany the justification.               i
    . DECO Response:                                                                                          1   .
See response to RAI 3.8.3-2.                                                                        !
i 3.8.3-4      ~ ITS SRs 3.8.3.1 and 3.8.3.4                                                                 I ITS SRs 3.8.3.1 and 3.8.3.4 l
CTS 4.8.1.1.2.a.2 and 4.8.1.1.2.a.7 The Frequency for STS SRs 3.8.3.1 and 3.8.3.4 is 31 days. This has been adopted as the -
    - Frequency for corresponding ITS SRs 3.8.3.1 andy.8.3.4, which are proposed changes relative
    ' to corresponding CTS 4.8.1.1.2.a.2 and 4.8.1.1.2.a.7 which are required to be performed at least once per 31 days on a Staaaered Test Basis (emphasis added). The CTS 3.8.1 markup                    i discussed the removal of the staggered test basis in DOC L.3 for that specification. Revise the
: t. submittal to provide appropriate justification or reference to the removal of the staggered test           !
basis for ITS 3.8.3 SRs.
DECO Response:                    .
New DOC (L2) now addresses this change.                                                           y I
3.8.4-1      ' The original item was for information only. There is no question.
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3.8.4-2      : ITS/STS SR 3.8.4.3 JFD C.1 CTS 4.8.2.1.c.1 The proposed changes to this SR do not reflect the changes accepted in TSTF-38 as indicated in JFD C.1. The proposed changes are not acceptable because they change the intent of the SR and because they are not consistent with TSTF-38. [The proposed SR does not require any                      l action; i.e., the requirement is to " inspect for', but imposes no action. The STS SR requires that the batteries "show no" damage that cause degradation. The STS requires that any damage be evaluated for impact on battery OPERABILITY.] The iTS SR should be revised to be consistent
      < with the STS as modified by TSTF-38.
DECO Response:
Appropriate changes have been made consistent with TSTF-38.
                                                                                                            )
3.8.4-3        STS Bases Pg. B 3.8-51 ITS SR 3.8.4.8 -                                                                                 1 JFD P.1                                                                                         j ITS SR 3.8.4.8 requires that battery capacity be demonstrated to be equal to (or greater that) 80% of rating. From this it is concluded that the battery has capacity to power all DC loads for 4 hours even when degraded to 80% of rated capacity, if this is the case, what is the justification for deleting the Bases material that discusses this capability? JFD P.1 does not provide an adequate justification.                                                                                        .
DECO Response:
I The previously eliminated Bases material has been determined to be appropriate and has                   i been included in the ITS.
      .3.8.4-4        The original item was for information only. There is no question.
3.8.5-1       STS/ITS 3.8.5 Insert 3.8.5-1 JFD P.4 DOC M.1 Bases for ITS 3.8.5, STS Bases markup page B 3.8-60 CTS 3.8.2.2 requires Division I or Division ll of the DC electrical power sources to be OPERABLE as a minimum. STS 3.8.5 requires DC electrical power subsystems to be OPERABLE to support DC electrical power distribution subsystems required by STS 3.8.10
      ' (ITS 3.8.8). CTS 3.8.2.2 and STS 3.8.5 appear to be equivalent. Proposed ITS Insert 3.8.5-1 is                  ,
similar to the CTS and the STS but differs with respect to power sources. The CTS and the                      j STS beth require both the battery and the charger associated with the DC electrical power                      i
      . subsystem to be OPERABLE. The proposed ITS would allow one of two required DC electrical n   power subsystems to be powered from either a battery or a charger, but not both. The                g l                                                                                                                . _ .

proposed ITS does not appear to reflect the CTS and differs from the STS. This issue is under review by the NRC and the industry and requires resolution before it can be implemented in the Fermi converted TS.                                                                              3 DECO Response:
The resolution of this issue is awaiting NRC disposition of TSTF-204.
3.8.5-2       Bases Pg. B 3.8-60 and 3.8-61 STS 3.8.5, insert B 3.8.5-1 and insert B 3.8.5-2 JFD P.3 Changes to the limiting condition for operation (LCO) Bases and the Actions Bases are indicated as being justified by JFD P.3. In the list of JFDs, however, P.3 is indicated as not used. What is the appropriate justification for these Bases changes? Note that the changes to the Bases for STS 3.8.5 are a subset of the changes to STS 3.8.5 identified in question 3.8.5-1, above.
DECO Response:
The standard P.3 JFD has been included.
3.8.5-3       Resolved in the December 4,1998, meeting.
3.8.6-1       ITS 3.8.6 ITS Action A JFD P.4 Deleting reference to Table 3.8.6-1 in the LCO is acceptable. However, reference to this Table must be included in Action A.
DECO Response:
The reference to Table 3.8.6-1 has been added to Condition A.
3.d.6-2       STS Table 3.8.6-1
* JFD P.1 The proposed Table would change the applicability of footnote (c) from Categories A, B, and C to only Categories A and C. This is acceptable since it represents the CTS. However, this means that specific gravity must be measured for each connected cell to demonstrate compliance with Category B limits, regardless of float current. Measurement of and compliance with Category B specific gravity limits is required at all times, including following a battery rechargo after a discharge. Given this, the licensee might want to reconsider adopting STS Note (c) in its entirety and applicable to all three categories, with appropriate justification.

DECO Response:
Detroit Edison has revitswed this issue and has determined that no change to the CTS
         . requirements that have been converted to the ITS is desired.
3.8.6-3      Bases Pg. B 3.8-69 4              Table 3.8.6-1 JFD P.3 The Bases discussion regarding the applicability of Table 3.8.6-1 footnotes to Category A, B, and C specific gravity is not consistent with proposed Table 3.8.6-1. In addition, the Bases discussion regarding float current and specific gravity is not consistent with the proposed Table.
The footnote regarding specific gravity and float current it not applicable to Category B.
DECO Response:
The Bases has been revised consistent with the resolution of RAI 3.8.6-2 above.
3.8.6-4      STS/ITS SR 3.8.6.2 & 3.8.6.3 CTS 4.8.2.1.b.1 & 3 There are two issues related to these SRs:                                                           ''
: a. The change in the overcharge voltage limit for the Division il battery incorporated by Amendment No.121 has not been incorporated. Incorporate the change into the STS markup and the ITS.
: b. In the CTS, the frequency for CTS 4.8.2.1.b.3 is at least once per 92 days and within 7 days after a deep battery discharge or battery overcharge. In the STS and the ITS the frequency is 92 days. There is no markup or justification for the deletion of the situational surveillance frequency. Adopt the CTS orjustify the less restrictive change from the CTS.
DECO Response:
: a. This change was incorporated in Revision 2 of the Fermi 2 ITS submittal.
: b. New DOC-L.3 has been added to address this change.
3.8.7-1      The original item was for information only. There is no question.
3.8.7-2      DOC L.1 JFD P.2 JFD P.5 CTS 3/4.8.3.1 Action a Bases for ITS 3.8.7 Required Action A.1, STS Bases page B 3.8-81 Bases for STS 3.8.9 Required Action A.1 CTS 3/4.8.3.1 Action b Bases for ITS 3.8.7 Required Action B.1, STS Bases page B 3.8-85 Bases for STS 3.8.9 Required Action C.1
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The Bases for Required Action A.1 for STS 3.8.9 refers to "With one or more required AC buses
  . in one division inoperable, .. " This reference has not been adopted in the Bases for Required Action A.1 for corresponding ITS 3.8.7, which refers to "With one or more required AC           l buses or MPUs [ modular power units] inoperable, and a loss of function has not yet occurred,
           " Action a for CTS 3/4.8.3.1 addresses one AC distribution system division not energized.
JFD P.5 describes editorial differences and references TSTF-16. TSTF-16 has not been approved by the NRC. Similarly, the Bases for Required Action C.1 for STS 3.8.9 states               -
" Condition C represents one division without adequate DC power . " The Bases for Required              j Action B.1 for corresponding ITS 3.8.7 states " Condition B represents one or more DC MCC               l
[ motor control center) or distribution cabinets without adequate DC power . " Action b for CTS 3/4.8.3.1 addresses one DC distribution system division not energized. JFD P.2 does not explain why the proposed Bases difference is acceptable.
DOC L.1 addresses the potential for a loss of function. However, DOC L.1 does not explain               ;
why, for both the AC and DC distribution systems, it is acceptable to have more than one l
distribution system division inoperable. Revise the submittal to provide the appropriate                i justification for the proposed changes or conform to the STS.                                           i DECO Response:
Additional justification has been provided for DOC L.1 and for JFD P.S.
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3.8.7 3              Combined with 3.8.7-2.
3.8.7-4              The original item was for information only. There is no question.
3.8.7-5             ITS 3.8.7 Completion Time for Required Actions A.1 and B.1 STS 3.8.9 Completion Time for Required Actions A.1 and C.1 CTS 3/4.8.3.1 Actions a and b The Completion Time for Required Actions A.1 and C.1 for STS 3.8.9 is "16 hours from discovely of failure to meet LCO." This has been adopted as the Completion Time for Required Actions A.1 and B.1 for corresponding ITS 3.8.7. These Completion Times are proposed changes relative to Actions a and b for corresponding CTS 3/4.8.3.1. No justification has been provided to support the proposed changes. Revise the submittal to provide the appropriate justification for the proposed changes.
DECO Response:
New DOC M.1 has been provided to address this change.                                 .,
3.8.8-1             Bases Pg. B 3.8-90 STS 3.8.8, insert B 3.8.8-1 JFD P.1

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! JFD P.1 does not provide an adequate justification for inclusion of Insert B 3.8.8-1. The l licensee should revise the JFD to specifically address this insert, including references to current licensing basis. Consideration should also be given to whether or not this permissive is appropriate for inclusion in the Bases without having the permistive included in the TS LCO.            I The licensee should also consider whether or not cross-tie breakers can be closed and still maintain the independence of the EDG.
1 DECO Response:
1 Insert B 3.8.8-1 has been eliminated.
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l 3.8.8-2      Resolved in the December 4,1998, meeting.                                              V l
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i ATTACIIMENT 3 TO NRC-99-0050 i
I INSERT AND REMOVAL SIIEETS j s}}