ML20206U576

Application for Amend to License NPF-43,revising Tech Spec 4.8.4.3 Re Testing for Operability of motor-operated Valves Thermal Overload Protection.Fee Paid

ML20206U576
Person / Time
Site:	Fermi
Issue date:	09/30/1986
From:	Agosti F DETROIT EDISON CO.
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20206U578	List: ML20206U576 ML20206U599
References
VP-86-0134, VP-86-134, NUDOCS 8610080034
Download: ML20206U576 (8)

Text

.g EcNTi Nuclear Operations s

Detroit - - r.r .

ENO$,I7'[aIE5 enn l puum&cw Nuclear lQVi opneuone September 30, 1986 VP-86-0134 Director of Nuclear Reactor Regulation Ms. Elinor G. Adensam, Director Project Directorate No. 3

vision of BWR Licensing J. S. Nuclear Regulatory Commission Uashington , D. C. 20555

Reference:

Fermi 2 NRC Dochet No. 50-341 NRC License No. UPF-43

Subject:

Proposed Technical Specification Change-Motor-operated Valves Thermal Overload Protection 3.8.4.3.

Pursuant to 10CFR50.90, the Detroit Edison Company hereby proposes to amend Operating License No. NPF-43 for the Fermi 2 Plant Technical Specifications. The proposed change revises Technical Specification 4.8.4.3, motor-operated valves thermal overload protection. This change vill clarify the testing required when a motor-starter has been repaired in order to declare it OPERABLE.

Detroit Edison has evaluated the proposed Technical Specification against the criteria of 10CFR50.59 and 10CFR50.92 and determined that no unreviewed safety question nor significant hazards considerations are involved.

The Fermi 2 Onsite Reviou Organization has approved and

the Muclear Safety Revicu Group has revicued this proposed Technical Specification and concurred with the enclosed determinations.

Pursuant to 10CFR170.12 (c), enclosed with this amendment request, is a fee of one-hundred fifty dollars (0150.00).

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Mc. Elinor G. Adensam September 30, 1986 VP-86-0134 Page 2 In accordance with 10CFR50.91, Detroit Edison has provided a copy of thin letter to the State of Michigan.

If you have any questions, please contact Mr. Steven Front at (313) 586-4210.

Sincerely,

^ME d l

Enclosure cc: Mr. M. D. Lynch Mr. U. G. Rogerc Mr . G. C . Uright Supervicor, Advanced Planning and Review Section, Michigan Public Service Commission USNRC Document Control Denk, Washington, D. C. 20555

r' fis. Elinor G. Adensam September 30, 1986 VP-86-0134 Page 4 I, FRANK E. ACOSTI, do hereby affirm that the foregoing statements are baced on facts and circumstances which are true and accurate to the best of my knowledge and belief.

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FRANK E. AG'OSTI Vice President 1uclear Operations On thin Mbb day of pdtntluA , 1906, before ne personally appeared Frank E. Agosti, being first duly suorn and says that he executed the foregoing ac his free act and deed.

bA ML l Notary Public KAREN M. REED Netzry Public, Monroe County, Mic![

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Enclosure to-VP-86-0134 Page 1 BACKGROUND / DISCUSSION Detroit Edison utilized- the GE Standard Technical Specifications (STS) as a starting point for developing the Fermi 2 Technical Specifications. During this development phase.GE-STS (BUR /4) 3.3.4.3.

Motor Operated Valve Thermal Overload Protection (not-bypassed) was determined to be applicable to our plant. Since this Technical Specification was applicable, the Surveillance Test (GE-STS DWR/4 4.8.4.3) was also applicable which states:

"The thermal overload protection for the above required valves shall be demonstrated OPERADLE at least once per 18 months and following maintenance on the motor starter by the performance of a CHANNEL CALIBRATION of a representative cample of at least 25%

of all thermal overloads for the above required valves".

During the development stage, this requirement uns interpreted by the NRC Tech. Spec. reviewers and Permi operations to mean that 25% of the thermal overload protection devices to be tested once per 18 months and if maintenance was required on a motor starter, only that motor starter would be tested by the performance of a CHANNEL CALIBRATION Test.

As we obtained more experience using the Technical Specifications and personnel changed, deviation from the original interpretation has occurred. Upon reading the words, it appears that whenever a motor starter undergoes any maintenance, that 25% of the thermal overload devices must be tested even if nothing was done to affect them. This is an excessive requirement that requires additional manhours, does not enhance the operation of the motor starter being repaired or the safety and operation of the plant. The manhours spent in testing the additional motor starters after maintenance has been performed on a single starter detracts the attention and time that coeld be spent on more significant issues.

The current Permi 2 Technical Specification (3.0.4.3) states that the thermal overload protection for each valve shoun in table 3.8.4.3-1 shall be OPERAnLE. This requirement applies whenever any motor operated valve (MOV) shoun in this table is required to maintain its associated system OPERABLE.

The ACTION statement allous bypassing of an inoperable thermal overload protection device to maintain MOV OPERADILITY. This is allowed for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> otherwise the af fected valve (s) must be declared inoperable.

The Technical Specification goen on to state that a reprocentative sample of 25% of all thermal overloads for the above required valves will be tested. The representative cample will be dif ferent each 18

Enclosure to

~VP-06-0134 Page 2 months in order to test 100% of the accessible MOVs and their associated thermal overload protective devices. This will ensure that a good baseline for each accessible MOV is obtained.

Design-Bases Motor operated valves (MOV) with thermal overload protection devices for the valve motors are used in various safety systems. These thermal overload relays are designed to protect these motors while they are running. The OPERABILITY of the MOV thermal overload protection ensures that the thermal overload protection will not prevent safety related valves from performing their intended function.

The primary design function of a thermal overload is to protect the motor windingc against excessive heating.

This proposed change will not change the ability of the HOVs to perform the intended safety functions nor to comply with the appropriate NRC Regulations (i.e. Regulatory Guide 1.106) .

Safety Evaluatiqn In accordance with 10CFR50.59, DECO has reviewed the attached proposed Technical Specification and has concluded that there is no unreviewed cafety question.

1) Is the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report increased?

Mo. Operation of Permi 2 in accordance with the proposed Technical Specification vill not involve an increase in the probability of occurrence or consequence of an accident previoucly evaluated. The thermal overload devices are to provide appropriated protection to encure that the motor operated valves perform their intended safety function.

This proposed change does not change any of the design functions of the MOV, thermal overload protection system, cignals or circuitry. The MOV's will still perform their intended / designed cafety functions as previously evaluated in the cafety analysis.

2) Is there a possibility for an accident or malfunction of a different type than evaluated previously in the safety analysis report being created?

No. Operation of Fermi 2 in accordance with the propoced Technical Specification will not create the poasibility of a new or different kind of accident f rom any accident previoucly

Enclosure to VP-GG-0134 Page 3 evaluated. .The proposed Technical Specification does not add any new equipment or' alter the operation of any of the MOV's or associated equipment. Operation or malfunction events for MOV's in safety related systems have been previously evaluated in the design phase of Fermi 2. Since this proposed change has not affected any assumptions or equipment the initial evaluation is valid and therefore does not create any potential of an event of a different type.

3) Is the margin of safety as defined in the basis for any Technical Specifications reduced?

No. Operation of Fermi 2 in accordance with the proposed Technical Specification vill not involve a significant reduction in margin of cafety. Since the intent of the existing. Technical Specification has not changed the margin of cafety will not be reduced. This proposed change only clarifies the original intent of the Technical Specification. In fact an interpretation of the current Tech. Spec. over tects the equipment and incroaces the potential for personnel error.

Sionific3nt Hazards Considerations In accordance with 10CFR50.92, Detroit Edison has revicued the attached propoced Technical Specification and has concluded that it does not involve a significant hazards consideration. The basis for this

. conclusion ic that the three criteria of 10CFR50.92(c) are not compromised, a conclusion of which in supported by our determination made pursuant to 10CFR50.59 and which is discussed below:

1) The proposed-change does not involve a significant increase in the probability or consequences of an accident previously evaluated. Thin propoced change does not affect or change any equipment, valve closure /renponse times or modify any circuitry logic. The Mov'c will ctill be able to perform their cafety function an designed and previously evaluated. The eventa analyzed in the Fermi 2 FSAR are not affected in anyuay and the accumptionn and outcomec previously discusced in the FSAR are still valid.

2) The propoced change does not create the possibility of a new or dif ferent kind of accident from any previously evaluated. This proposed change does not mechanically modify cnything in the current design, analysic or operation of the MOV's and their thermal overload protective devicec. The poccibility of a new or different kind of accident in not created.

Enclocure to VP-86-0134 Page 4

3) The proposed change does not involve a significant reduction in safety margin. The proposed change may increase the margin of cafety since the frequency of testing the MOVs and their thermal overload protective devices vill be reduced causing lecc voar, minimising the human / equipment inte-face to lencen error potential and allowing plant personnel more time to attend to other important functions.

Thic propocod change in like the URC example presented in the Federal Register Vol. 67 pg. 14870 Item (i) which states; "A purely administrative change to the Technical Specifications: For example, a change to achieve conciatency throughout the Technical Specifications, correction of an error, or a change in nomenclature." This is an adminictrative type change to achieve concintency and a clearer understanding of a curveillance tect requirement.

o Ertvjnonmental Impact Detroit Edicor han reviewed the propoced Technical Specification againct the criteria of 10CFRSl.22 for environmental considerations.

As shoun above, the proposed change concerns curveillance tecting and clarifying actions to be taken after maintenance is performed on a notor starter. Thic doec not involve a significant hasards consideration, nor increase the types and amounts of effluents that may be released off aite, nor significantly increase individual or cumulative occupationa? radiation expocurec. Daced on the foregoing, Detroit Edison concluded that the proposed Technical Specification meets the criteria given in 10CFRSl.22 (c) (9) for a categorical exclucion from the requirement for an Environmental Impact Statement.

C_o3clu_qign Daced on the evaluations above: (1) there in reasonable accurance that the health and cafety of the public vill not be endangered by operation in the propoced manner, and (2) cuch activitien vill be conducted in compliance with the commincion's Regulations and thic proposed amendment vill not be inimical to the common defence and cocurity or to the hocith and cafety of the public. Detroit Edison believen that thic proposed Technical Specif f cation vill add to the cafety of Fermi 2 by not over operating / testing equipment for no opparent reasonc, thus minimising potential malfunctionc and human error and vill allou plant perconnel to attend to more plant activities.