ML20198F920

Forwards RAI Related to FERMI-2 Amend Request to Extend EDG Allowed Outage Times.Response Requested within 30 Days

ML20198F920
Person / Time
Site:	Fermi
Issue date:	12/23/1997
From:	Kugler A NRC (Affiliation Not Assigned)
To:	Gipson D DETROIT EDISON CO.
References
TAC-M94171, NUDOCS 9801120210
Download: ML20198F920 (3)

Text

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December 23, 1997 Mr. Douglas R. Gipson Senior Vice President Nuclear Generation Detroit Edison Company.

6400 North Dixie Highway Newport, Michigan 48166_  :

SUBJECT:

- REQUEST FOR ADDITIONAL INFORMATION (RAI) RELATED TO THE FERMI 2 SUBMITTAL TO EXTEND EMERGENCY DIESEL GENERATOR ALLOWED OUTAGE TIMES (TAC NO. M94171)

Dear Mr. Gipson:

On November 22,1995, Detroit Edison submitted an amendment request to extend the allowed outage times for the emergency diesel generators for NRC staff review. Detroit Edison provided supplemental information related to the amendment request in letters dated February 19 and June 12,1996, and January 30,1997. Detroit Edison also provided supplemental information related to the amendment request in letters dated April 19, May 3, and December 4,1996, and August 7,1997, responding to NRC requests for additional information.

Additionalinformation, as discussed in the enclosure, is requested in order for the staff to complete its review. NRC requests that Detroit Edison respond within 30 days.

If you have any questions concerning this request, please contact me at (301) 415-2828.

Sincerely, ORIGINAL SIGNED BY Andrew J. Kugler, Project Manager Project Directorate ill-1 Division of Reactor Projects lil/IV Office of Nuclear Reactor Reguluion g[

Dockst No. 50-341  !

Enclosure:

As stated 5lI cc w/ encl: See next page DlSTRIBUTION:

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1- Mr. Douglas R. Gipson - Fermi 2 Detroit Edison Company cc:

John Flynn, Esquire

. Senior Attorney Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther r0ng Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 U.S. Nuclear Regulatory Commission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Monroe County Emergency Management Division 963 South Raisinville Monroe, Michigan 48161 Regional Administrator, Region til U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Norman K. Peterson Director, Nuclear Licensing Detroit Edison Ccmpany Fermi 2 - 280 TAC 6400 North Dixie Highway Newport, Michigan 48166 '

August 1997 m.

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l-REQUEST FOR '.DDITIONAL INFORMATION (RAI) RELATED TO 5

THE FERMI 2 SUBMfiTAL TO EXTEND EMERGENCY DIESEL GENERATOR ,

ALLOWED OUTAGE TIMES (TAC NO. M94171)

The staff requests that Detroit Edison submit a proposed change to the admin strative controls section of the technical specifications (TS) that adds a description of the licensee's configuration risk management program (CRMP). The submittal should also include a discussion that provkles supporting information for the proposed change.

As discussed during a telephone conversation between the NRC and Detroit Edison on December 1,1997, one of the elements required to support risk-informed TS allowed outage time (AOT) extensions is the implementation of a CRMP. The NRC has determined that a brief description of the CRMP must be added to the administrative controls section of the TS. For further information see SECY-97-095, "Probabilistic Risk Assessment implementation Plan Pilot Application for Risk-Informed Technical Specifications,' dated April 30,1997. The third paragraph on page 3 of the SECY paper reads,in part, in approving the proposed TS changes, the staffis relying on a commitment made by the licensee, as described in the attached safety evaluation, specifically, with respect to utilization of a risk informed configuration control technique to assess the risk associated with removal of equipment fron wervice during the proposed AOT.

Because this is a new commitment specific to risk informed TS changes, the staff will ensure that the commitment is incorporatedinto the ANO 2 operating license This may be done by incorporating the commitment as a license condition or in the administrative controls section of the TS. (Emphasis added)

As the pilot program proceeded, the staff determined that the use of th6 administrative controls section of the TS provided a better option.

On September 26,1997, the Combustion Engineering Owners Group (CEOG) provided comments on various draft regulatory guides and Standard Review Plan sections related to risk-informed regulation, included in its comments on Draft Regulatory Guide DG-1065, "An Approach for Plant Specific, Risk Informed, Decisionmaking: Technical Specifications," CEOG provided proposed text for the description of the CRMP in the administrative section of the TS.

This text was carefully crafted by CEOG in cooperation with the NRC staff to meet the intent of the staffs commitment to the Commission.

ENCLOSURE i

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