Text

Proposed Tech Specs 3/4.3 Re Instrumentation Surveillance Requirements
	ML20137K080
Person / Time
Site:	Fermi
Issue date:	03/27/1997
From:	; DETROIT EDISON CO.
To:	;
Shared Package
ML20137K076	List: ML20137K080; NRC-97-0031, Application for Amend to License NPF-43,requesting Elimination of Selected Response Time Testing Requirements;
References
	NUDOCS 9704040235
	Download: ML20137K080 (15)
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3/4.3 INSTRUNINTATION i

- 3/4.3.1 REACTOR PROTEC' TION SYSTEM INSTRUMENTATION ,

$UeVE1LLANCE REOUTREMENTS 4.3.1.1 Each reactor protection system instrumentation channel shall be !

demonstrated OPERABLE by the performance of the CHANNEL CHECK. CHANNEL FUNCTIONAL TEST, and CHANNEL CALIBRATION operations for the OPERATIONAL :

CONDIT10NS and at the frequencies shown in Table 4.3.1.1 1.

4.3.1.2 LOGIC $YSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed at least once per 18 months.

4.3.1.3 The REACTOR PROTECTION SYSTEN RESPONSE TIME of each reactor trip functional unit'shall be demonstrated to be within its limit at least once per 38 months. Neutron detectors are exempt from response time testing. Each ,

test shall include at least one channel per trip system such that all channels !

are tested at least once every N times 18 months where N is the total number of redundant channels-in'a specific reactor trip system.

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FERMI - UNIT 2 3/4 3 la Amendment No. 3 ,100 w ;

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i INSTRUptNTATIM IU8vffttaw!E Itt00fetMrwis 4.3.2.1 Each 1selatten actuation instrumentatten channel shall be demonstrated DPERABLE by the performance of the CHANNEL CHECK, DIANNEL e

FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPEAATIONAL CONDITIONS and at the frequencies shown la Table 4.3.2.1 1.

4.3.2.2 LOGIC SYSTEN FUNCTIONAL TESTS and simulated asteestic operatten of all channels shall be performed at least once per 18 months.

4.3.2.3 The ISOLATION SYSTDI Resp 0NSE TIME of each 1seletten trip furetion shall be demonstrated to be within its limit at least once per 18 months.

Radiatten detectors are emespt free response 11ee testing. Each test shall Include at least one channel per trip system such that all channels are tested at least once every N times 18 months, where N is the total ember of redundant channels in a specific isolation trip system.

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FERN! . UNIT 2 3/4330 Amendment No.100 i

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. , - ]NSTDUutNTET10N 3/4.3.3

~ EMEDGENCY C0:E COOLING SVSTEM ACTUAT10N INSTR LIMITING CONDITION FOR OPEDATION 3.3.3 The emergency core cooling system (ECCS) actuation instrumentation channels shown in Table 3.3.31 shall be OPERABLE with their trip setpoints consistent with the values shown in the Trip Setpoint column of Table 3.3.3 2.

APPLICABILITY: As shown in Table 3.3.3-1.

ACTION:

a.

With an ECCS actuation instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column o Table 3.3.3 2, declare the channel inoperable until the channel is restored to OPERABLE status with its trip setpoint adjusted consistent with the Trip Setpoint value. ;

b.

With one or more ECCS actuation instrumentation channels inoperable, '

take the ACTION required by Table 3.3.3 1.

c. With either ADS trip system "A" or "B" inoperable, restore the ,

inoperable trip system to OPERABLE status within:

1.

7 days, provided that the HPCI and RCIC systems are OPERABLE, otherwise,

2. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

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Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reducethe within reactor steam following dome pressure to less than or equal to 150 psi 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

MyJTt1 ANCE RE0VIREMENTS

4.3.3.1 Each ECCS actuation instrumentation channel shall be demon CHANNEL CAllBRATION operations for the OPERATIO frequencies shown in Table 4.3.3.1-1.

4.3.3.2 channels shall be performed at least once per 18 months.* LOG j

4.3.3.3 to be within the limit at least once per 18 months.The ECCS RESP least cae ch taael pe* t-ip syfta= s'Jc h 'htt ?11 h E::h t::t :hil in:hd: et t eaaels ?re terted at les:t once-svary in W ti=e!

p;;iff: ECC tri;!! :y:t::.

= cath! Here " is the tet:1 "M:r ef rededirt Wrr:1s

For the diesel generator output breakers:

Completion of logic system ' .

the breaker reclosure permissive relay (52XX) is re-e I I

re energized by a parallel path, may be deferred andI m I later than during the first plant outage after September 29. 1995.

l FERMI - UNIT 2 3/4 3-23 Amendment No. JJ),

105 H ECCS Gc.ibqfIon iM to e eh b'on is dice f f % v1 response tk e. tuHy,

Enclosure 3 NRC-97-0031 Page 3 ENCLOSURE 3 - PART 2 PROPOSED TECIINICAL SPECIFICATION REVISED PAGES n

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. 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION l

SURVEILLANCE REOUIREMENTS l

4.3.1.1 Each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, and CHANNEL CALIBRATION operations for the OPERATIONAL

. CONDITIONS and at the frequencies shown in Table 4.3.1.1-1.

l 4.3.1.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed at least once per 18 months.

4.3.1.3 The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip !

functional unit

shall be demonstrated to be within its limit at least once j i per 18 months. Neutron detectors are exempt from response time testing. Each i test shall include at least one channel per trip system such that all channels 1 are tested at least once every N times 18 months where N is the total number i of redundant channels in a specific reactor trip system. j j

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Sensors for Reactor Vessel Steam Dome Pressure - High and Reactor Vessel Low '

Water Level - Level 3_are exempt from response time testing. l FERMI - UNIT I- 3/43-la Amendment No. 7), Jpp

. INSTRUMENTATION SURVEILLANCE RE0UIREMENTS 4.3.2.1 Each isolation actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL '

CONDITIONS and at the frequencies-shown in Table 4.3.2.1-1.

4.3.2.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of !

all channels shall be performed at least once per 18 months. ;

4.3.2.3 The ISOLATION SYSTEM RESPONSE TIME of each isolation trip function

l shall be demonstrated to be within its limit at least once per 18 months.

Radiation detectors are exempt from response time testing. Each test shall include at least one channel per trip system such that all channels are tested :

at least once every N times 18 months, where N is the total number of !

redundant channels in a specific isolation trip system.

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Sensors for Primary Containment Isolation Reactor Vessel Low Water Level - Level I and Main Steam Line Flow - High are exempt from response time testing.

FERN! - UNIT 2 3/4 3-10 Amendment No. J#S,

INSTRUMENTATION ,

. 3/4.3.3 EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION r

LIMITING CONDITION FOR OPERATION 3.3.3 The emergency core cooling system (ECCS) actuation instrumentation channels shown in Table 3.3.3-1 shall be OPERABLE with their trip setpoints set consistent with the values shown-in the Trip Setpoint column of Table 3.3.3-2.

' APPLICABILITY: As shown in Table 3.3.3-1.

ACTION

a. With an ECCS actuation instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column -

of Table 3.3.3-2, declare the channel' inoperable until the channel is restored to OPERABLE status with its trip setpoint adjusted consistent with the Trip Setpoint value. ,

b. With one or more ECCS actuation instrumentation channels inoperable, take the ACTION required by Table 3.3.3-T. t

c. With either ADS trip system "A" or "B" inoperable, restore the inoperable trip system to OPERABLE status within: l

1. 7 days, provided that the HPCI and RCIC systems are OPERABLE, otherwise, ,

2. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduce reactor steam dome pressure to less than or equal to 150 psig within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE RE0VIREMENTS 4.3.3.1 Each ECCS actuation instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK,_ CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.3.1-1.

4.3.3.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed at least once per 18 months.*

4.3.3.3 The ECCS RESPONSE TIME of each ECCS trip function ** shall be demonstrated to be within the limit at least once per 18 months.

For the diesel generator output breakers: Completion of logic system functional testing, for the loss of power function, to positively verify that

'the_ breaker reclosure permissive relay (52XX) is re-energized by the :

associated bus load shedding logic contact closing, rather than the 52XX being re-energized by a parallel path, may be deferred and must be completed

.no later than during the first plant outage after September 29, 1995. l

- ECCS actuation instrumentation is exempt from response time testing, j FERMI -. UNIT 2 3/4 3-23 Amendment No. Jpp, Jp),

Enclosure 4

'NRC 97 0031 Page1 i

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ENCLOSURE 4 RESPONSE TO TIIE CONDITIONS INCLUDED IN ,

THE NRC STAFF'S SAFETY EVALUATION [

ACCEPTING NEDO-32291 A ,

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l Enclosure 4 '

NRC-97-0031 ,

Page 2-k ENCLOSURE 4 RESPONSE TO TIIE CONDITIONS INCLUDED IN Tile NRC STAFF'S SAFETY EVALUATION ACCEPTING NEDO-32291 A

1. Confirm the applicability of the generic analysis of NEDO-32291 A to their plant; NEDO-32291 A is applicable to Fermi 2. Fermi was selected as a lead plant in the development of NEDO-32291 A as documented in Section 4.0 and Appendix A, B, C and 11 of the NEDO document.

2. Include a change request as shown in Appendix I of NEDO-32291A; This submittal satisfies this condition.

3. Include Technical Specification i age markups as shown in Appendix H to NEDO-32291A; The NRC has approved the relocation of Response Time Testing Tables from TS to UFS AR, (Amendment 100 to the Fermi 2 Operating license). The relocation of ,

Response Time Testing Tables to the UFSAR requires the Technical Specification I l

page markups to change from those shown in Appendix H to NEDO-32291 A.

The needed changes are now implemented through footnotes to the specific response time testing surveillance requirements instead of through footnotes to the Tables specifying response time limits.

In addition since all response time testing for ECCS actuation instrumentation channels is eliminated, it is no longer necessary to specify a testing scheme based on staggering testing based on the channels in the trip systems. This provision is deleted.

The required changes are included in Enclosure 3 to this submittal.

4. Include a list of affected instrument loop components as shown in . Appendix C to NEDO 32291 A;

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Enclosure 4 f NRC-97-0031 Page 3 Fermi 2 was selected as a lead plant for the analyses that are documented in NEDO-32291 A. The components are already identified in Appendix C.1 of NEDO-32291A.

5. State f hat the plant is following the recommendations from EPHI NP-7243 "Inw stigation of Response Time Testing Requirements and are therefore ,

re;uired to perform the foHowing actions:

(a) Prior to installation of a new transmitter / switch or following refurbishment of a transmitter / switch (e.g., sensor cell or variable damping components). A hydraulic response time test (RTT) shall be performed to determine an initial sensor-specific response time value, and >

Rosemount transmitters are used exclusively for the " transmitter / switch" channel described in NEDO-32291 A. The calibration procedures have been revised to include a step requiring response time test to be performed, prior to return of the transmitter to service when replacing the transmitter with a new or refurbished transmitter (e.g., sensor cell or variable damping components).

The test is required " prior to return to service" rather than " prior to installation" since it is acceptable to perform response time testing for the transmitter on the bench or as installed on the rack.

(b) For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage the lines.

Fermi 2 currently does not utilize any transmitters or switches that use capillary tubes in any application that requires response time testing.

Therefore, ' !s recommendation is not applicable to Fermi 2.

Furthermore, the NRC staffis requesting that the licensee must state the following:

(a) That calibration is being done with equipment designed to provide a step function or fast ramp in the process variable, The applicable calibration procedures that will require the technicians be in direct communication to verify that the response of the transmitter to the step input change or fast ramp is prompt, and in all cases less than five seconds. During this excursion the transmitter / instrument loop is observed for sluggishness or erratic operation that would be indicative of degraded transmitter / instrument loop performance. .

Enclosure 4 NRC-97-0031 Page 4 i

I (b) That provisions have been made to ensure that operators and technicians, through an appropriate training program, are aware of the consequences of 6 instrument response time degradation, and that applicable procedures have been reviewed and revised as necessary to assure that technicians monitor for response time degradation during the performance of calibrations and !

functional tests, Training was conducted for the operators and technicians in response to Requested Action 4.a of NRC Bulletin (NRCB) 90-01," Loss of Fill-Oil in Transmitters Manufactured by Rosemount." In addition to addressing the ;

symptoms that a transmitter exhibits ifit is experiencing a loss of fill oil, this i training also addressed the consequences of instrument response time degradation. Completion of this training was documented in Fermi's response to !

NRCB 90-01 (Reference letter: NRC-90-0179, dated January 18,1990).

Procedures require that the technicians monitor for sluggish transmitter behavior while performing transmitter calibration. An additional provision has been added to the procedures to assure that technicians monitor for response time degradation during the performance of calibrations.

(c) That surveillance testing procedures have been reviewed and revised if necessary to ensure calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of units under test, Technicians performing calibrations and functions tests are in a position to communicate to one another. If the technicians are in separate locations telephones are used such that any observation by one technician can be communicated to the other. Procedures require that the technicians monitor for sluggish transmitter behavior while performing transmitter calibration. The applicable calibration procedures have been revised to require the technicians at different locations to be in direct communication to verify that the response of the transmitter to a step input change or fast ramp is prompt, and in all cases less than five seconds.

(d) Thd for any request involving the elimination of response time testing for Rosemount pressure transmitters, the licensee is in compliance with the gui0 lines of Supplement I to Bulletin 90-01," Loss of Fill Oilin Transmitters Manufactured by Rosemount, and Fermi 2 compliance with the guidelines of Supplement I to NRCB 90-01 was reviewed and documented in a safety evaluation transmitted to Fermi by NRC

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Enclosure 4-NRC-97-0031

. Page 5 letter dated June 3,1994. The NRC's evaluation concluded that Fermi's responses to the NRCB 90-01 and Supplement 1 conform to the Requested Actions of NRCB 90-01, Supplement 1.

(e) That for those instruments where the manufactured recommends periodic response time testing as well as calibration to ensure correct functioning, the licensee has ensured that elimination of response time testing is nevertheless acceptable for the particular application involved.

Fermi 2 has reviewed the vendor recommendations for these devices and confirmed that they do not contain recontmendations for periodic response time testing.

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Enclosure 5 -]

l- NRC-97-0031 Page 1 l 1

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ENCLOSURE 5 l 1

HASES FOR APPLYING 1

THE PROVISIONS FOR -

EXIGENT PROCESSING PER )

10CFR50.91(a)(6) ,

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ENCLOSURES HASES FOR APPLYING THE PROVISIONS FOR EXIGENT PROCESSING PER 10CFR50.91(a)(6)

Subsequent to the development and submittal of the BWR Owners' Group topical report for elimination of response time testing requirements, the NRC issued Generic letter 93-08 which albwed the relocation of Technical Specification (TS) Tables containing response time testing limits to the UFSAR. Fermi 2 implemented these GL 93 08 provisions in the Fermi 2 Operating License.

The NRC approval of the BWROG topical report then followed in late 1995 and ;

Fermi 2 began the process of applying the topical report to the plant. The pages affected (as marked up it Appendix H of the topical report) had now all been relocated to the UFSAR. An evaluation per 10CFR50.59 was then performed and established that the proposed change did not result in an unreviewed safety question. ;

in addition, since the changes (pa the topical report) were restricted to UFSAR pages, no TS changes were seen to be needed, i Thus the provisions requested by this submittal were implemented in early 1996 prior ;

to the next normally required perfonnance of the tests in the refueling outage of 1996. l Appropriately procedures were changed and the testing not performed in the fall 1996 '

l refueling outage.

On March 19,1997, the NRC informed Detroit Edison that it was the NRC position that the implementation of the topical report required a TS change.

At this time, Fermi 2 is shut down and scheduled to restart in late April 1997. Any testing required by the application of the NRC position on implementing the topical ;

report for the current operational condition is being performed and, until it is completed, the TS action requirements are being followed. This impacts two channels of ECCS Actuation Instrumentation for low reactor vessel water level. The remaining testing that had not been completed in the fall 1996 refueling would need to 1 be completed prior to plant startup unless a TS change is approved implementing the ;

I elimination of this testing (as proposed by this submittal).

Performing this testing would entail recreating the necessary procedures and subsequent perfonnance of the tests. Following the approval of this submittal the procedures would then revert to their current state. Detroit Edison believes that this sequence of events is unnecessary and undesirable. Although relatively small, there l

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NRC-97-0031 -

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- exists a risk in the formulation of the procedures or the conduct of the tests for an error to occur that could result in an condition adverse to safety.. In addition, these activities will divert personnel from tasks that are more safety significant and the testing evolution will subject plant equipment to unnecessary wear and entail

- additional radiation exposure.

Therefore, Detroit Edison is requesting that this proposal be handled under the

_ provisions of 10CFR50.91(a)(6) us an exigent change.

The need for this exigent processing came about due to the formulation and forwarding of an NRC position that could not be anticipated and the lack of time to process a change under normal processes prior to plant startup. Thus, Detroit Edison believes that the exigency could not be avoided by making a more timely application to be handled under the normal process.

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ML20137K080

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