ML20073S829

Safety Evaluation Supporting Amend 99 to License NPF-43

ML20073S829
Person / Time
Site:	Fermi
Issue date:	06/28/1994
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20073S827	List: ML20073S825 ML20073S829
References
GL-93-05, GL-93-5, NUDOCS 9407060275
Download: ML20073S829 (5)

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[W ietter dated March 29, 1994, as corrected April 25, 1994, the Detroit (dison company (DLCo or the licensee) requested an amendment to the lechnical Spettf:tations (15) appended to facility Operating License Na. NPF-43 for fern 1-2.

The proposed amendment would modify surveillance requi,c.ments for

< cran discharge vent and drain valves and isolation actuat ion instrumentation, and m0Jify the required actions and surveillance req.irements for the en+rgen:y diesel generators, lhe proposed amendment was submitted in accordance with the guidance contained in Generic Letter (GL) 93-05. "Line-lien Tec & cal Specifications Improvements to Reduce Surveillar.ce Requirements i

for lestina During power Operation,' dated September 27, 1993.

2.0 Dli4UMl0N lhe NRL st af f tempitted a comprehensive examination of surveillanc,e requirements in TS that require testing during power operation.

The result <

of this study were reported in NUREG-1366, " Improvements to Tett.nical Spec i f icat ions Surveillance Requirements," December 1992, in performing this

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the statt 'ound that, while the majority of the testing at power is impultant, safety can be improved, equipment degradation decreased, and an unnete3sary horden on personnel resources eliminated by reducing the amount of te, ting that the 15 require during power operation.

Only a small fraction of the 15 surveillance intervals warranted relaxation.

The staff issued GL 93-05 to provide licensees guidante in preparing a license amendment request to in p ),; men t the recommendations of NUREG-1366 as 1ine-item improvements to the iS.

3.0 [VlAUMlQN The licensee's proposed changes to the TS would modify the surveil'ance requirements for the scram discharge volume vent and drain valves and the isolation actlatten instrumentation, and modify the required actions and surveillance requirements for the emergency diesel generators to reduce required testing during power operation.

940706027g % $ 41 PDg ADE PDR P

_ 15 4.1.3.1.1.b requires that each scram discharge volume (SDV) vent and drain valve be cycled through at least one full cycle of travel at least once per 92 days.

The proposed chance would require an evaluation of the SDV system response prior to plant startup after each scram to verify that no abnormalities exist.

This is in accordance with the guidance of item 4.5 of GL 93-05 and is, therefore, acceptable.

The 18-month surveillance requirement of TS 4.1.3.1.4 described below combined with an evaluation of the SDV system response af ter each scram to verify that no abnormalities exist is considered adequate to demonstrate the operability of the SDV vent and drain valves, 15 4.1.3.1.4 requires that at least once every 18 months each SDV vent and drain valve be tested to assure that it will close within 30 seconds after receipt of a signal for control rods to scram and will open when the scram signal is reset.

The star.dard technical specifications ($15) for boiling Wdter reaClors (BWR) of this design (BWR-4), required that this 18-month sm.eillance requirement be performed when control rods are scram tested from "a 50 perc ent rod density or less."

GL 93-05 proposed guidance that the "50 percent rod density or less" requirement be eliminate; and replaced with a requirement that the surveillance be performed when c trol rods are scram test,d from 'a shutdown condition."

N '50 percent rod density or less" requirement was e iminated from the ferni 2 Operating License with the issuance of the Full Power Operating ticrnse The licensee's,cactice has been to perform this surveillance during shutdown conditions.

However, the requirement to perform this surveillance exclusively during shutdown conditions was removed with the issuance of cendmnt 95 to the Fermi 2 Operating License on October 29. 1993.

That cendment h e neer, requested in accordance with the guidance contained in GL 91-04

" Changes in T(chnical Specification Surveillance Intervals to Accommodate a 24-Month fuel Cycle."

Based on the above, the licensee has determined that the current wording of the Fermi IS is more appropriate for this line item improvement and therefore, the licensee has not requested a change.

IS 4.1.3.1.2.b requires that, when abovs the preset power level of the RWM

[ rod worth minimizer), all withdravm control rods not required to have their directional control valves disarr.ied electrically or hydraulically be demonstrated OPERABLE by moving each control rod at least one notch at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when any control rod is immovable as a result of excessive frictton or mechanical interference The proposed change would require that the control rod be moved only once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

GL 93-05 recommends that the TS should be changed to require that if a control rod is immovable because of friction or mechanical interference, the other control rods should be tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and every 7 days thereafter.

The recommendation to change the frequency for tests that apply when a control rod is immovable to include "once every 7 days thereaf ter," is already covered by the existing requirements of TS 4.1.3.1.2.a and no additional change is needed.

The licensee provided justification for the change from "at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." This single test should provide sut*icient information to determine if any additional control rods have become immovable as a result of friction or mechanical interference and allow a

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'i return to the normal 7-day testing frequency. Additionally, this proposed change is in accordance with the guidance contained in item 4.2.2 of GL 93-05 and is, theref ore, acceptable.

15 4 3.2.3 requires that the isolation system response time of each isolation trip function shown in Table 3.3.2-3 be demonstrated for each trip function, to be within its limit at least once per 18 months.

The proposed TS change would remove those limits that correspond to the emergency diesel generator (EDG) start and sequencing times.

The EDG start and sequencing of loads are tested in accordance with TSs 4.8.1.1.2.a.4 and 4.8.1.1.2.e.ll.

The additional testing required by TS 4.3.2.3 increases the risk of plant trips and equipment challenges Jue to the large number of lif ted leads, jumpers and pulled fuses required to simulate the necessary conditions.

Additionally, the safety analyses for the plant assume that the instrument channel actuation for non-MSIV [ main steam isolation valves) channels occurs simultaneously with EDG start and sequencing, it is unlikely that the typical response time (less than a second) would degrade to where it exceeds the diesel start time of 13 seconds without a failure that is noticeable in other wa s.

This proposed change also meets the guidance of item 5.9 of GL 93-05 and is, therefore, acceptable.

TS 3.8.1.1, Action Statement a, requires testing of the operable EDGs within

- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the offsite circuit is determined to be inoperable.

The proposed change would eliminate this testing requirement.

l In. rewtrbment to test the EDGs when the offsite circuit is unavailable may result i n an increased potential for an EDG to become unavailable at a time when its potential for need is greatest.

The licensee-cites an analysis of relative unavailabilities from EDG testing performed by Vermont Yankee as basis for the proposed change.

The analysis yields'a factor of_3 higher unavailability for the case where testing followed an offsite! circuit being inoperable than for normal monthly EDG testing. :The proposed change also meet s the guidance of item.0.1 of GL 93-05,- and is, therefore, acceptable.

'S 3.8.1.1 ' Action Statement b, requires testing of the remaining EDGs within

. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when an EDG is determined to be inoperable.

The proposed change would eliminate this testing _ requirement if the inoperable EDG is determ ned j

to be inoperable due to an inoperable support system, an_ independently _

testable component, or preplanned preventive maintenance or testing, or if the absence of any potent!*t common mode failure for the remaining EDGs is

- determined.

The proposed change makes two exceptions to the guidance contained in item 10.'l of GL 93-05.

The licensee retains the current completion time of the testing, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, rather than change to the 8-hour.

completirn-time recommended in GL 93-05.

The i censee also proposes that the.

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absence of any potential common mode-failure be " determined" rather than-l-

"cemon s t ra t ed.

l lhe-licensee states that the fermi 2 design includes four EDGs in total, two per division.

This means that three EDGs will normally require testing per this requirement.

The licensee states that the 24-hour completion time is needed to effectively test the remaining EDGs.

The licensee also points out I'?t"--'

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that the exceptions are consistent with the completion time and required actions provided in the recently issued improved STS and are consistent with the Boses for that document as well.

The staff has reviewed the licensee's proposed change and determined that, except as noted, the proposed change conforms with the guidance in item 10,1 of GL 93-05.

The staff has reviewed the exceptions in the licensee's proposal and determined th" t':ey 4re in accordance with other approved guidance and, therefore, are acc-s ~ able TS 4.8.1.1 a.5 regt.

loading of the EDGs within 150 sece 4-The proposed cn2 g woulr icading of the EDGs to be conducted in accordar ' with 'w

's recommendations (with the exception of the 18-mon' - ' 4s of

.e pt.tr (LOOP) tests both with and without a loss of coolant accident

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The licensee states that several progiam studies have determined that fast loading during surveillance testing is the most sicnificant cause of acce'erated degradation of an EDG.

It_can cause rapid piston ring and r,liider liner wear up to 40 times greater thae normal.

The proposed change in accordance with the guidance rentained in item 10.1 of GL 93-05.

is a: su Ine staff has reviewed the licensee's proposed change and has determined that it is acceptable.

TS 4.8.1. l.2.e.8 requires the conduct of a simulated LOOP test (TS 4.8.1.1.2.e.4.b) within 5 minutes of a 24-hour run test.

The proposed change would require that the test following the 24-hour run test to be the EDG start test (i$ 4.8.1.1.2.a.4).

-The proposed change would also require running-the EDG for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if the hot restart test is conducted at a time other:

than following the 24-hour run test.

The 24-hour run test is set up such that the EDG is run for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at 2500-26GO kW load and then 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 2800-2900 kW load.

TS 4.8.1.1.2.e.8 requires that within 5 minutes-after completion of the 24-hour run test, the emergency buses must be de-energized and loads shed with a subsequent fast start md '

full load acceptance This latter stai and load is currently required oy conouc t ing the LOOP test of TS 4.8.1.1.2.e.4.b.

The licensee states that schoduling these tests during a time when_all engineered safety features:(ESF) loads are available generally requires 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (24_per division) where no other testing can be performed-on the full complement of ESF necessary for these combined tests.

The licensee proposes to separate these two tests (the 24-hour run and LOOP test) to provide additional flexibility during refueling outages.

The licensee proposes to do this by revising the hot start test to include only starting the EDG as per TS 4.8.1.1.2.a.4 and conducting _the LOOP test without consideration of the 24-hour test.

The licensee also states that performing these tests in quick succession requires shutdown of the EDG faster than recommended in the EDG shutdown procedure.

Because the Fermi 2 EDGs are water cooled, and maintained in hot standby conditions, they are not expected to experience the temperature rise-transients associated with small forced air-cooled EDGs which may lead to failure to restart when hot or extended oelay in restarting.

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, The licensee is also proposing to modify the note which allows repeating the hot restart test, if unsuccessful, without first conducting the 24-hour test.

The repeated test must be preceded by running the EDG for "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 2500-2600 kW or until' temperature has stabilized." The licensee proposes to change the run time to "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />...or until temperature has ;tabilized" consistent with the manufacturer's recommendations.

The above changes are consistent with the guidance in item 10.1 of.GL 93-05.

The staff has reviewed the proposed changes and determinti that they are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment.

The State official had no comments.

5.0 (Ny!RONMENTAL CONSIDERATION 1% amendment changes requirements with respect to the installation or use of tacility component located within the restricted area as defined in 10 CFR a

' art 20 and changes surveillance requirements.

The staff has determined that ttie amendment involves no significant increase in the amounts, and no

$1gnificant change in the types, of any effluents that may be released ottsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the 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 environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The staff 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 act tvities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Pr incipal Contributor Timo+hy G. Colburn Date: June 28, 1994 s

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