ML20138B700
| ML20138B700 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/18/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20138B697 | List: |
| References | |
| NUDOCS 9704290240 | |
| Download: ML20138B700 (9) | |
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UNITED STATES j
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NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20666-0001 o.
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- o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.111 TO FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDIS0N COMPANY FERMI-2 i
DOCKET NO. 50-341 i
1.0 INTRODUCTION
By letter dated March 27, 1997, as supplemented on April 4, 1997, the Detroit Edison Company (DECO or the licensee) requested an amendment to the Technical Specifications (TS) appended to Facility Operating License No. NPF-43 for Fermi-2. The proposed amendment would revise TS surveillance requirement (SR) 4.3.1.3, Reactor Protection System (RPS) Instrumentation, to indicate that certain sensors are exempt from response time testing (RTT). A similar revision would be made to SR 4.3.2.3, Isolation Actuation Instrumentation.
Finally, SR 4.3.3.3, Emergency Core Cooling System (ECCS) Actuation Instrumentation, would be revised to indicate that the ECCS actuation instrumentation is exempt from RTT.
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2.0 BACKGROUND
The Boiling Water Reactor Owners Group (BWR0G), with Detroit Edison participation, performed an analysis to assess the impact of elimination of RTT for selected instrument loops. This analysis was documented as Licensing Topical Report NED0-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements," and was submitted for NRC approval in January 1994. The NRC approved NED0-32291 in a generic SER dated December 28, 1994 and approved subsequent revisions to NED0-32291 in a supplemental SER dated May 31, 1995. The generic SER included Tables 1 and 2, which respectively list the make/model of instruments / devices, and systems that were evaluated in NED0-32291 for RTT elimination. The generic SER states, "The BWROG concluded that the RTT requirements for the devices identified in Table 1 can be removed from the TSs when the devices are used in systems listed in Table 2."
In addition to approving elimination of RTT for selected instrumentation, the generic SER stipulated certain conditions that individual plant licensees must meet when implementing the NED0-32291 guidelines on a plant-specific basis.
ENCLOSURE 9704290240 97041s PDR ADOCK 05000341 P
3.0 PROPOSED CHANGE
S AND EVALUATION Detroit Edison proposed elimination of the following selected RTT requirements from the Fermi-2 TS:
1.
RPS Instrumentation - Sensors for Reactor Vessel Steam Dome Pressure-High and Reactor Vessel Low Water Level - Level 3; 2.
Isolation Actuation System Instrumentation - Sensors for Reactor Vessel Low Water Level-Level 1 and Main Steam Line Flow-High, and; 3.
ECCS Actuation Instrumentation.
As approved by the staff, NED0-32291 indicated that RTT can be eliminated for the following based on other TS testing that is sufficient to detect instrumentation response degradation:
1.
All ECCS instrument loops; 2.
. All Isolation Actuation instrument loops except for main steam line isolation valves (MSIVs);
3.
Sensors for selected RPS actuation; and 4.
Sensors for MSIV closure actuation.
The specific sections of-the Fermi-2 TS to be changed are as follows:
(a)
Section 3/4.3.1, Reactor Protection System Instrumentation, page 3/4 3-la, Surveillance Requirement 4.3.1.3, Reactor Protection System Response Time.
Prooosed Chanae: Add a footnote stating: "The sensor response time for Reactor Vessel Steam Dome Pressure - High and Reactor Vessel Low Water Level - Level 3 need not be measured and may be assumed to be the design-sensor response time."
Evaluation: This footnote will allow Fermi-2 to use manufacturers' response time data and eliminate the requirement for a separate measurement of the sensor response time.
The remainder of the channel will continue to be tested for response time.
This change is consistent with the approved NED0-32291.
Section 3/4.4, Surveillance Requirements, page 3/4 3-10, Surveillance (b)'
Requirement 4.3.2.3, Isolation System Response Time.
Proposed Chanae: Add a footnote stating: "The sensor response time for Primary Containment Isolation Reactor Vessel Low Water Level - Level 1 and Main Steam Line Flow - High need not be measured and may be assumed to be the design sensor response time."
i Evaluation:
This footnote will allow Fermi-2 to use manufacturers' response time data and eliminate the requirement for a separate measurement of the sensor response time. The remainder of the channel will continue to be tested for response time.
This change is consistent j
with the approved NED0-32291.
(c)
Section 3/4.3.3, Emergency Core Cooling System Actuation Instrumentation, page 3/4 3-23, Surveillance Requirement 4.3.3.3, ECCS j
Response Time.
Proposed Chanae: Add a footnote stating: "ECCS actuation instrumentation response time need not be measured and may be assumed to be the design i
instrumentation response time."
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Evaluation:
This footnote will allow Fermi-2 to use manufacturers' i
response time data and eliminate the requirement for a measurement of 2
the instrument channel response time.
For the ECCS functions, the i
~ entire channel is exempted from response time testing. This change is j
consistent with the approved NED0-32291.
4.0 VERIFICATION OF NED0-32291 PLANT-SPECIFIC CONDITIONS The staff stipulated several conditions in the generic SER approving NED0-32291 which must be met by the individual licensee referencing NED0-32291 before its guidance could be-implemented in plant-specific TS change proposals.
From the Fermi-2 licensee's submittals, the staff verified that l
the licensee has met the applicable conditions as follows:
4.1 Condition
. Confirm the applicability of the generic analyses to the plant.
Licensee's Response:
The licensee indicated that Fermi-2 was selected as a lead plant in the development of NED0-32291 as documented in Section 4.0 and Appendix A, B, C, and H of the NEDO document.
Therefore, the NE00-32291 analysis are applicable to Fermi-2. The staff finds this response acceptable.
4.2
. Condition: The licensee's revision request shall be submitted as shown in Appendix I of the BWROG 1etter.
Licensee's Resoonse:
The licensee stated that the March 27, 1997, submittal for proposed TS changes satisfies this condition.
The staff finds this response acceptable.
4.3 Condition
The licensee shall state that it is following the recommendations from EPRI NP-7243 and, therefore, shall perform the following 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 RTT shall be performed to determine an initial sensor-specific response time value.
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Licensee Response: Rosemount transmitters are used exclusively for the transmitter / switch channels described in NED0-32291. The a
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calibration procedures have been revised to include a step requiring an RTT to be performed prior to returning the transmitter to service after replacing the transmitter with a new i
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 4
perform RTT for the transmitter on the bench or as installed on the rack. The staff finds that this response meets the above conditions, s
(b)
For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and i
after any maintenance or modification activity that could damage the capillary tubes.
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Licensee Response: In its submittal, the licensee stated Fermi-2 i-currently does not utilize any transmitters or switches that use capillary tubes in any application that requires RTT. Therefore, this recommendation is not applicable to Fermi-2.
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4.4 Condition
The licensee must confirm the following:
i (a)
That calibration is being done with equipment designed to provide i
a step function or fast ramp in the process variable.
Licensee Response: The applicable calibration procedures will require the technicians to be in direct communication to verify that the response of the transmitter to the step input change or i
fast ramp is prompt, and in all cases less than 5 seconds. During i
this excursion the transmitter / instrument loop is observed for sluggishness or erratic operation that would be indicative of degraded transmitter / instrument loop performance. The staff finds that this response meets the above condition.
I (b)
That provisions have been made to ensure that operators and technicians, through an appropriate training program, are aware of l
the consequences of instrument response time degradation, and that applicable procedures have been reviewed and revised as necessary to assure that technicians monitor for response time degradation l
during the performance of calibrations and functional tests.
Licensee Response: Training was conducted for the operators and technicians in response to Requested Action 4.a of NRC Bulletin (NRCB) 90-01, " Loss of Fill-011 in Transmitters Manufactured by Rosemount."
In addition to addressing the symptoms that a transmitter exhibits if it is experiencing a loss of fill oil, i
J this 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 1
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. 1 technicians monitor for sluggish transmitter behavior while performing transmitter calibration. An additional provision has j
been added to the procedures to assure that technicians monitor for response time degradation during the performance of calibrations. The staff finds that this response meets the above conditions.
(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.
Licensee Resoonse: Technicians performing calibrations and functional tests are in a position to comunicate with one another.
If the technicians are in separate locations, telephones are used such that any observation by one technician can be comunicated 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 comunication to verify that the response of the transmitter to a step input change or fast ramp is prompt, and in all cases less than 5 seconds.
The. staff finds that this response meets the above conditions.
(d)
That for any request involving the elimination of RTT for Rosemount pressure transmitters, the licensee is in compliance with the guidelines of Supplement 1 to Bulletin 90-01, " Loss of Fill-011 in Transmitters Manufactured by Rosemount."
i Licensee Response: Fermi-2 compliance with the guidelines of Supplement 1 to NRCB 90-01 was reviewed and documented in a safety evaluation transmitted to Fermi by NRC letter dated June 3, 1994.
The NRC s evaluation concluded that Fermi responses to the NRCB 90-01. and Supplement I conform to the Requested Actions of NRCB 90-01, Supplement 1.
The staff finds that this response meets the above conditions.
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(e)
That for those instruments where the manufacturer recomends periodic RTT as well as calibration to ensure correct functioning,
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the licensee has ensured that elimination of RTT is nevertheless acceptable for the particular application involved.
Licensee Resoonse: Fermi-2 has reviewed the vendor recomendations for the applicable devices and confirmed that there are no manufacturer recomendations for periodic RTT.
The staff finds that this response meets the above conditions.
Based upon the above review, the staff concludes that the licensee has implemented the provisions of the generic SER for RTT elimination in accordance with NED0-32291.
Therefore, the staff finds that the proposed
. Fermi-2 TS modifications for selected instrument RTT elimination are acceptable.
5.0 EXIGENT CIRCUMSTANCES
The Comission's regulations,10 CFR 50.91, contain provisions for issuance of amendments where the Commission finds that exigent circumstances exist, in that a licensee and the Commission must act quickly and that time does not permit the Comission to publish a Federal Register notice allowing 30 days for prior public coment.
The exigency exists in this case in that the proposed amendments are needed to allow Fermi Unit 2 to resume power operation and time does not permit the Comission to publish a notice allowing 30 days for prior public comment.
The licensee was unable to make a more timely application because the licensee was not formally notified by the NRC of a possible TS non-compliance issue and need for TS amendment with regard to response time testing until March 20, 1997. The staff has determined that the licensee used its best efforts to make a timely application.
Accordingly, the Commission has determined that exigent circumstances exist pursuant to 10 CFR 50.91(a)(6) and could not have been avoided, the submittal of information was timely, and that the licensee did not create the exigency.
6.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
S DETERMINATION The Commission's regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) result in a significant reduction in the margin of safety. The NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR
'50.91.
The NRC staff's final. determination is presented below.
(1)
The proposed changes would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The purpose of the proposed TS changes is to eliminate response time testing requirements for selected instrument loops in the Reactor Protection System, Isolation System, and Emergency Core Cooling System.
However, because of the continued application of other TS testing requirements such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, the response time of these systems will be maintained within the acceptance limits assumed in plant safety analyses and required for successful mitigation of an
' initiating event. Therefore, the proposed TS changes do not affect the capability of the associated systems to perform their intended fune. tion.
within their required response time.
k l The General Electric Company and the BWROG have completed an evaluation (Reference 1 of the March 27, 1997, application) which demonstrates that response time testing of certain instruments is unnecessary due to other TS testing requirements listed in the preceding paragraph. These other tests are sufficient to identify failure modes or degradations in instrument response time and assure operation of the associated systems within acceptance limits. There are no failure modes that can be
. detected by response time testing that cannot also be detected by the other TS tests.
i (2)
The proposed changes would not create the possibility of a new or different kind of. accident from any accident previously evaluated.
j As discussed above, the proposed TS changes do not affect the capability of the associated systems to perform their intended function within the acceptance limits assumed ir, the p' ant safety analyses and required for
- accessful mitigation of an sitiating event. Other than the elimination of selected response time tests there are no changes to plant equipment or configuration.
(3)
The proposed chanjes would not result in a significant reduction in the margin of safety.
The current TS response times are be.5ed on the maximum allowable values assumed in the plant safety analyses. These analyses conservatively establish the margin of safety. As described above, the proposed Technical Specification changes do not affect the capability of the associated systems to perform their intended function within the allowed
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response time used as the basis for the plant safety analyses.
Plant end system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore, the margin j
of safety is not affected.
7.0 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.
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8.0 ENVIRONMENTAL CONSIDERATION
The amendment changes surveillance requirements. The staff has determined
,that the amendment involves no signifkart increase in the amounts, and no significant change in the types, of any cffluents that may be released offsite, 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 (62 FR 15731). Accordingly, the amendment meets the el kibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
rursuant to 10 CFR 51.22(b),- no environmental impact statement or environment.
issessment need be prepared in connection with the issuance of the amendment.
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9.0 CONCLUSION
The Commission has concluded, based o.. r.ha considerations discussed above, that: (1) there is reasonable assuranc.1 >> t the health and safety of the public will not be endangered by operativ in the proposed manner,_(2) such activities 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.
Principal Contributor:
P. Loeser j
Date: April 18, 1997 1
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