ML20070D365
| ML20070D365 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/29/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20070D363 | List: |
| References | |
| NUDOCS 9407080041 | |
| Download: ML20070D365 (4) | |
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SAFETY EVALUATION BY THE OfflCE OF NUCLEAR REACTOR REGULATICtl RELATED TO AMENDMENT NO. 100 TO FACILITY OPERAT!NG LICENSE NO. NPF-43 RELOCATION Of INSTRUMENT RESPONSE TIME LIMIT TABLES
[ERMI 2 DOCKET NO. 50-341 r
1.0 JNTRODUCT103 By letter dated April 26, 1994, Detroit Ediv. Company (the licensee),
submitted a request for changes to the fermi 2 nuclear plant Technical Specifications (TS).
The requested amendment would change the TS to modify l
the requirements of TS 3.3.1, 4.3.1.3, 3.3.2, 4.3.2.3, 3.3.3, and 4.3.3.3 and relocate Tables 3.3.1-2, 3.3.2-3, and 3.3.3-3 which provide the response time limits for the reactor protection system (RPS), the isolation actuM%n system (IAb) instruments, and the emergency core cooling system (ECCS) fr he TS to the Updated final Safety Analysis Report (UFSAR).
The licensee ha stated that the next update of the UfSAR will include these tablas.
The NRC pr'ovided guidance to all holders of operating licenses or construction permits for nuclear power reactors on the proposed TS changes in Generic letter 93-08, "Pelocation of Technical Specification lables of instrument Response Time Limits," dated December 29, 1993.
2.0 MCKGROUND The NRC staff undertook efforts in the early 1980's to addreas proolems related to the content of nuclear power plant TS.
These projects have re:.ulted in the issuance of various reports, proposed rulemakings, and Commission policy statements.
Line item improvements became a mechanism for-TS improvement as part of the implimentation of the Commission's interim policy statement on TS improvements published on February 6, 1987 (52 FR:
3788).
The final Commission policy statement _on TS improvements wat published-July 22, 1993 (58 FR 39132).- The final policy statement _provided criteria s hich can be used to-establish, more clearly, the framework for TS.
The staff i
i.
hes maintained the line item improvement process, through the issuance of l~
_ generic letters, in order to improve the content'and consistency of TS and to I
reduce the licensee and staff resources required to process amendments related to those specifications being relocated from the TS.to other licensee documents as a result of the implementation of the Commission's final policy statement.
Section 50.36 of Title 10 of the Code of Federal Regulations establishes the L
regulatory requirements for. licensees to include TS as part of_ applications for operating licenses.
The rule requires that TS include items in five specified categories: (1)-safety limits, limiting safety system settings, and 9407080041 9406p9 yDR ADOCK 05000341 PDR-
. limiting controi settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative c ont rol s.
in addition, the Commission's final policy statement on TS improvements and other Commission documents provide guidance regarding the required content of TS.
The fundamental purpose of the TS, as described in I
the Commission's final policy statement, is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval.
The Commission's final policy statement recognized, as had previous statements related to the staff's TS improvement program, that implementation of the policy would result in the relocation of existing TS requirements to licensee-controlled documents such as the UFSAR.
Those items relocated to the UFSAR would in turn be controlled in accordance with the requirements of 10 CFR 50.59, " Changes, tests and experiments." Section 50.59 of Title 10 of the Code of Federal Regulations provides criteria to determine when facility or operating changes planned by a licensee require piior Commission approval in the form of a license amendment in order to address any unreviewed safety questions.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to UFSAR commitments and to take any remedial action that may be appropriate.
3.0 [VMLAIL03 0
The licensee has proposed changes to TS 3.3.1, 4.3.1.3, 3.3.2, 4.3.2.3, 3.3.3, and 4.3.3.3 and that remove the references to lables 3.3.1-2, 3.3.2-3, and 3.3 3-3 and deletes these tables from the TS.
The licensee committed to relocate the tables on response time limits to the UFSAR in the next periodic update.
lables 3.3.1-2, 3.3.2-3, and 3.3.3-3 contain the values of the response time limits for the RPS. IAS, and ECCS instruments.
The limiting conditions for operation for the RPS, IAS, and ECCS instrumentation specify these systems shall be operable with the response times as specified in these tables.
These limits are the acceptance criteria for the response time tests performed to satisfy the surveillance requirements of TS 4.3.1.3, TS 4.3.2.3, and TS 4.3.3.3 for each applicable RPS, IAS, and ECCS trip function.
These i;rveillances ensure that the response times of the RPS, lAS and ECCS instruments are consistent with the assumptions of the safety analyses performed for design basis accidents and transients. The changes associated with the implementation of Generic Letter 93-08 involve only the relocation of the RPS, lAS, and ECCS response time tables but retain the surveillance requirement to perform response time testing.
The UFSAR will now contain the acceptance criteria for the required RPS, IAS, and ECCS response time l
surveillances. Because it does not alter the TS requirements to ensure that the response times of the RPS, IAS, and ECCS instruments are within their limits, the staff has concluded that relocation of these response time limit tables from the TS to UFSAR is acceptable.
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The staff's dettemination is based on the fact that the removal of the specific response time tables does not eliminate the requirements for the licensee to ensure that the protection instrumentation is capable of performing its safety function. Although the tables containing the specific response time requirements are relocated from the TS to the UFSAR, the licensee must continue to evaluate any changes to response time requirements in accordance with 10 CFR 50.59. Should the licensee's determination conclude that an unreviewed safety question exists, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or melfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
The staff's review concluded that 10 CFR 50.36 does not require the response time tables to be retained in TS.
Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure response times, for RPS, IAS, and ECCS systems are retained due to those systems' importance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of specific response time reouirements for the various instrumentation channels and components addressed e Gw.eric Letter 93-08 was not required.
The response times are considered to be an operational detail related to the licensee's safety analyses which are' adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected instrument or component response times, where the revisions to those requirements e not involve an unreviewed safety question under 10 CFR 50.59, would afford ro significant benefit with regard to protecting the public hem th and safity.
Further, the response time requirements do not constitute a condition or limitation on operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the i
public health and safety, in_that the ability of the RPS, IAS, and ECCS systems to perform their safety functions are not adversely impacted by the relocation of the response time tables from the TS to the UFSAR.
These TS changes are consistent with the guidance provided in Generic letter 93-08 and the TS requirement of 10 CFR 50.36.
The staff has determined' that the proposed changes to the TS for the Fermi 2 nuclear plant are acceptable.
4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the State of Michigan official was not ified of the pr' posed issuance of the amendment.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a-facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance reonirements.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant thange in the types, of any effluents that may be released:
offsite, and that there is no significant increase in-individual or cumulative i
a
. cccupational radiation exposure.
The Connission has previously issued a proposed finding that tne amendment involves no significant hazards consideration, and there has been no public comment on such finding (59 FR 27053). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no ens;ruamental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducts d in compliance with the Commission's regulations, and (3) the issuance of the amendment vill not be inimical to the common defense and security or to the health und safety of the public.
Principal Contributors:
Timothy G. Colburn William Reckley Date: June 29, 1994
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