ML20217A792
| ML20217A792 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/17/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217A790 | List: |
| References | |
| NUDOCS 9803250244 | |
| Download: ML20217A792 (10) | |
Text
'.
t c,# " '8
-p t
UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 3085H001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.115 TO FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDISON COMPANY FERMI 2 DOCKET NO. 50-341
1.0 INTRODUCTION
By letter dated September 29,1997, as supplemented on March 10,1998, the Detroit Edison Company (DECO or the licensee) requested an amendment to the Technical Specifications (TSs) appended to Facility Operating License No. NPF-43 for Fermi 2. The March 10,1998, 4
supplement requested a change in the implementation period and was not outside the scope of the initial proposed no significant hazards consideration determination.
The proposed amendment would revise the TS and the associated bases by relocating the requirements for selected instrumentation to the updated final safety analysis report (UFSAR).
The affected TSs are:
TS 3/4.3.7.2, Seismic Monitoring Instrumentation TS 3/4.3.7.3, Meteorological Monitoring instrumentation TS 3/4.3.7.7, Traversing In-Core Probe System TS 3/4.3.7.8, Chlorine Detection System TS 3/4.3.7.10, Loose-Part Detection System These changes would be made in accordance with the guidance in Generic Letter (GL) 95-10,
" Relocation of Selected Technical Specifications Requirements Related to Instrumentation,"
dated December 15,1995.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plant operating licenses to include TSs as part of the license. In Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36), the Commission established the regulatory requirements related to the content of TSs. That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the
. particular requirements to be included in TSs.
9803250244 990317 PDR ADOCK 05000341 P
I
. The NRC developed criteria, as described in the " Final Policy Statement on Technical Specifications improvements for Nuclear Power Reactors" (58 FR 39132), to determine which of the design conditions and associated surveillances should be located in the TSs as limiting conditions for operation. Four criteria were subsequently incorporated into the regulations by
- an amendment to 10 CFR 50.36 (60 FR 36953):
1.
installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; 2.
a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; 3.
a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; 4.
a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
The Commission's Final Policy Sta'ement and documentation related to the revision of 10 CFR 50.36 acknowledged that implementation of these criteria may cause some requirements presently in TSs to be moved out of existing TSs to documents and programs
{
controlled by licensees.
GL 95-10 addresses the relocation of selected TS requirements related to instrumentation as a result of applying the 10 CFR 50.36 criteria. On reviewing typical TSs for nuclear power reactors, the staff determined that, in accordance with the 10 CFR 50.36 criteria, several specifications did not warrant inclusion in TSs. The staff also concluded that the instrumentation addressed by these specifications are not related to dominant contributors to plant risk. The following typical TSs are among the candidates for relocation to i
licensee-controlled documents:
incore Detectors (Movable incore Detectors, Traversing incore Probe) e
^
Seismic Monitoring Instrumentation e
Meteorological Monitoring Instrumentation Chlorine Detection System e
e Loose-Part Detection System e'
Explosive Gas Monitoring Instrumentation e
Turbine Overspeed Protection The generic letter indicated that licensees could request a license amendment to relocate selected instrumentation requirements of this type from the TSs to licensee-controlled documents or programs.
3.0 EVALUATION in GL 95-10, NRC requested licensees that request an amendment to relocate instrumentation requirements to include a commitment to relocate each selected requirement to a particular licensee-controlled document or program, (e.g., the UFSAR or the emergency plan) and to address the submittal of the revised documents to the NRC in accordance with the applicable regulation (e.g.,10 CFR 50.71(e)). In addition, the licensee should clearly describe the program it will use to control changes to relocated provisions (e.g.,10 CFR 50.59 or 50.54(q)).
In its submittal, Detroit Edison stated that, contingent upon NRC approval, it committed to relocate the five subject TSs to the UFSAR (except for Special Report requirements) and control their future changes pursuant to the requirements of 10 CFR 50.59. The licensee stated that NRC reporting criteria of 10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Reactors," and 10 CFR 50.73, " Licensee Event Report Systems" provide appropriate requirements for reporting degraded and nonconforming conditions to the NRC and that the elimination of such Special Reports is an administrative change and co,sistent with NUREG-1433, " Standard Technical Specifications - General Electric Plants, BWR/4," April 1995. In addition, the licensee stated that the NRC will receive, in accordance with 10 CFR 50.71(e), future changes to these relocated TSs in the form of UFSAR revisions.
The information supplied by the licensee satisfies the request in GL 95-10. In addition, the staff has concluded that eliminating the special reporting requirements is an administrative change that will be replaced by the reporting requirements of 10 CFR 50.72 and 10 CFR 50.73. This noministrative change will have no effect on the health and safety of the public. Therefore, the staffinds this change acceptable. The following sections provide the staff's evaluation of the relocation for each of the affected instruments.
3.1 ' Seismic Instrumentation in its submittal the licensee stated:
The Seismic Monitoring instrumentation is described in Fermi 2 UFSAR Section 3.7.4,
" Seismic Instrumentation Program." This instrumentation is provided in accordance with 10 CFR 100, " Reactor Site Criteria," Appendix A, Section Vl(a)(3), " Required Seismic Instrumentation," to promptly determine the magnitude of a seismic event so the effect on those plant features important to safety may be evaluated. This capability is provided to permit comparison of the measured response to that used in the design basis for the plant.
Comperison of such data is used to determine whether the plant can operate safely, and permit timely action as may be appropriate. The Seismic Monitoring Instrumentation has no nuclear safety related function and does not automatically shut down the plant when an earthquake occurs which exceeds a predetermined intensity.
An evaluation of the Seismic Monitoring Instrumentation with respect to the four criteria of I
1pR 50.36(c)(2)(ii) follows:
j I
l.
\\
Criterion 1: Seismic Monitoring instrumentation is not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. The instrumentation is not installed for, or capable of, detecting reactor coolant leakage.
The NRC's Final Policy Statement and GL 95-10 explicitly identify the Seismic Monitoring Instrumentation as an example of contro's that are not required to be retained in the TS. This instrumentation does not meet Criterion 1 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 2: Seismic Monitoring Instrumentation is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. It is provided to promptly detect and determine the magnitude of a seismic event so that the effect on those plant features, important to safety, may be evaluated. This instrumentation does not meet Criterion 2 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 3: The Seismic Monitoring instrumentation is not a component that is part of the primary success path and it does not provide a function or actuation in order to mitigate the consequences of a Design Basis Accident or Transient. This instrumentation does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 4: The Seismic Monitoring Instrumentation has not been shown to be significant to public health and safety by either operational experience or probabilistic risk assessment. Seismic Monitoring Instrumentation was not included in the scope of the Fermi 2 Individual Plant Examination or the Individual Plant Examination for External Events, nor is it " risk significant" under the Fermi 2 Maintenance Rule Program. This instrumentation does not meet Criterion 4 of 10 CFR 50.36 (c)(2)(ii) for inclusion in TS.
In GL 95-10, the NRC staff also evaluated the seismic monitoring instrumentation with respect to the 10 CFR 50.36 criteria. The stvf concluded that the seismic instrumentation does not serve as a protective design feature or part of a primary success path for events that challenge fission product barriers and that the seismic nionitoring instrumentation does not satisfy the 10 CFR 50.36 criteria and need not be included in the TSs Based on the generic staff review and the licensee's submittal, the staff concludes that relocating the seismic instrumentation requirements from the TSs to the UFSAR is acceptable.
3.2 Meteoroloaical Monitorina Instrumentation In its submittal the licensee stated:
The Meteorological Monitoring Instrumentation is described in Fermi 2 UFSAR Section 2.3.3.2, " Operational Meteorological Monitoring System."
The Meteorological Monitoring Instrumentation is used to measure environmental parameters (wind speed, wind direction and air temperature differences) which may affect the distribution of radioactive effluents following a release of radioactive material. In
'10 CFR 50.47, " Emergency Plans," and 10 CFR 50, Appendix E," Emergency Planning and 1
4 l
l !
Preparedness for Production and Utilization Facilities," the NRC requires that licensees provide reasonable assurance that adequate protective measures can and will be taken in l
the event of a radiological emergency. Timely access to accurate local meteorological data is important for estimating potential radiation doses to the public and for determining appropriate protective measures.
I in 10 CFR 50.36a(a)(2), " Technical Specifications on Effluents from Nuclear Power Reactors," the NRC requires licensees to submit annual reports specifying the quantity of each of the [ principal] radionuclides released to unrestricted areas in liquid and airborne effluents, and such other information as may be required by the NRC to estimate maximum potential annual doses to the public. A knowledge of meteorological conditions in the vicinity of the plant is important in providing a basis for estimating annual radiation doses to the public from either routine or accidental releases of radioactive materials to the atmosphere.
An evaluation of the Meteorological Monitoring Instrumentation with respect to the four criteria of 10 CFR 50.36(c)(2)(ii) follows:
Criterion 1: The Meteorological Monitoring Instrumentation is not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. This instrumentation is not installed for, or capable of, detecting reactor coolant leakage. It is used to assess the need for recommending protective measures following an accident. This instrumentation does not meet Criterion 1 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 2: The Meteorological Monitoring Instrumentation is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This instrumentation does not meet Criterson 2 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 3: The Meteorological Monitoring Instrumentation is not a component that is part of the primary success path and it does not provide a function or actuation in order to mitigate the consequences of a Design Basis Accident or Transient. This instrumentation does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 4: Although important for use in estimating potential radiation doses to the public and for determining appropriate protective measures, the Meteorological Monitoring Instrumentation has not been shown to be significant to public health and safety by either operational experience or probabilistic safety assessment. This instrumentation cannot be used to predict, prevent, or directly mitigate the consequences of a Design Basis Accident. This instrumentation was not included in the scope of the Fermi 2 Individual Plant Examination or the Individual Plant Examination for External Events, l
nor is it " risk significant" under the Fermi 2 Maintenance Rule Program. This 1
instrumentation does not meet Criterion 4 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
I
~
t c'
in GL 95-10, the NRC staff also evaluated the meteorological monitoring instrumentation with respect to the 10 CFR 50.36 criteria. The staff concluded that this instrumentation does not I
sente to ensure that the plant is operated within the bounds of initial conditions assumed in design-basis accident and transient analyses or that the plant will be operated to preclude i
transients or accidents. Likewise, the meteorologicalinstrumentation does not serve as part of the primary success path of a safety sequence analysis used to demonstrate that the consequences of these events are within the appropriate acceptance criteria. Accordingly, the staff concluded that the meteorological instrumentation does not meet the 10 CFR 50.36 criteria and need not be included in TSs. Based on the generic staff review and the licensee's submittal, the staff concludes that relocating the meteorological monitoring instrumentation requirements from the TSs to the UFSAR is acceptable.
3.3 Traversina In-Core Probe System in its submittal the licensee stated:
The Traversing In-Core Probe System is described in the Fermi 2 UFSAR, Sections 7.1.2.1.4.6, " Traversing in-Core Probe System," and 7.6.1.13.8, " Traversing in-Core Probe System."
The Traversing in-Core Probe System provides a signal proportional to the axial neutron flux distribution over the regions of the core where the Local Power Range Monitor System detection assemblies are located. This signal is of high precision to allow reliable calibration of the Local Power Range Monitor System. These signals do not provide direct I
input to the Reactor Protection System, the isolation actuation irstrumentation, or the Emergency Core Cooling System actuation instrumentation.
An evaluation of the Traversing in-Core Probe System with respect to the four criteria of 10 CFR 50.36(c)(2)(ii) follows:
Criterion 1: The Traversing In-Core Probe System is not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. It is used as a calibration and measurement tool. This system is not installed for, or capable of, detecting reactor coolant leakage. This system does not meet Criterion 1 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 2: This system is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Although the core power distributions (measured by the in-core probe) constitute an important initial cotidition to Design Basis Accidents and, therefore, will continue to be addressed by TS 3/4.2, " Power Distribution Limits," the probe itself is not an active design feature needed to preclude analyzed accidents or transients. The Local Power Range Monitor System itself will continue to be required to be operable per TS 3/4.3.1, " Reactor Protection System," and calibrated at least once per 1000 effective full power hours using the Traversing In-Core Probe System under TS Table 4.3.1.1-1, " Reactor Protection System Instrumentation Surveillance
. Requirements." Therefore, this system does not meet Criterion 2 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 3: This system is not part of the primary success path and does not provide a function or actuation in order to mitigate the consequences of a Design Basis Accident or Transient. This system does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 4: This system has not been shown to be significant to public health and safety by either operational experience or probabilistic safety assessment. This system was not included in the scope of the Fermi 2 individual Plant Examination or the Individual Plant Examination for External Events, nor is it " risk significant" under the Fermi 2 Maintenance Rule Program. This system does not meet Criterion 4 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
In GL 95-10, the NRC staff also evaluated the traversing in-core probe system with respect to the 10 CFR 50.36 criteria. The staff concluded that these instruments are neither used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary before a design-basis accident, nor do they function as a primary success path to mitigate events that assume a failure of or a challenge to the integrity of fission product barriers.
Although the core power distributions (measured by the incore detectors) constitute an important initial condition to design-basis accidents and therefore need to be addressed by TSs, the detectors themselves are not an active design feature needed to preclude analyzed accidents or transients. The staff determined, therefore, that the incore detector requirements do not meet the criteria of 10 CFR 50.36 for inclusion in TSs. Based on the generic staff review and the licensee's submittal, the staff concludes that relocating the traversing in-core probe system requirements from the TSs to the UFSAR is acceptable.
3.4 Chlorine Detection Svstem In its submittal the licensee stated:
The Chlorine Detection System is described in Fermi 2 UFSAR Sections 6.4.2.3, " Air Conditioning System," and 6.4.3.4, " Air Conditioning System - Centrol of Main Control Room Chemical Environment." The Chlorine Detector System is consistent with the recommendations of Regulatory Guide 1.95, " Protection of Nuclear Power Plant Control Room Operators against an Accidental Chlorine Release," Revision 1, January 1977.
Quick-response chlorine detectors are located in the normal air intake to the Control Center Air Conditioning System (CCACS). On detection of chlorine concentrations greater than or equal to 5 ppm, the detectors automatically initiate complete isolation of the main control room. Therefore, the Chlorine Detection System ensures that an accidental chlorine release will be promptly detected and the protective actions will be automatically initiated to provide protection for control room personnel.
An evaluation of the Chlorine Detection System with respect to the four criteria of 10 CFR 50.36(c)(2)(ii) follows:
c-4
- Criterion 1: The Chlorine Detection System is not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. This system is not installed for, or capable of, detecting reactor coolant leakage. It is used to automatically initiate isolation of the CCACS in the event of an accidental release offsite of chlorine. This system does not meet Criterion 1 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 2: The Chlorine Detection System is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This system does riot meet Criterion 2 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 3: The Chlorine Detection System is not a component that is part of the primary success path and it does not provide a function or actuation in order to mitigate the consequences of a Design Basis Accident or Transient. The Control Center Air Conditioning System will continue to be required by TS 3/4.7.2, " Control Room Emergency Filtration System," Surveillance Requirement 4.7.2.1.e.3 to automatically switch to the chlorine mode of operation upon a chlorine actuation signal. However, this system does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 4: The Chlorine Detection System has not been shown to be significant to the public health and safety by either operational experience or probabilistic safety assessment. This system was not included in the scope of the Fermi 2 Individual Plant Examination or the Individual Plant Examination for External Events, nor is it " risk significant" under the Fermi 2 Maintenance Rule Program. This system does not meet Criterion 4 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
In GL 95-10, the NRC staff also evaluated the chlorine detection system with respect to the 10 CFR 50.36 criteria. The staff concluded that the system may serve an important role in protecting control room personnel from intemal or external hazards related to toxic gases.
However, the release of chlorine or other hazardous chemicals is not part of an initial condition of a design-basis accident or transient analysis that assumes a failure of or presents a challenge to the integrity of a fission product barrier. Since the release of toxic gases is not assumed to initiate or occur simultaneously with design-basis accidents or transients involving challenges to fission product barriers, the chlorine detection system is not part of a success path for the mitigation of those accidents or transients. The staff concluded that requirements for this system do not meet the 10 CFR 50.36 criteria and need not be included in TSs. Based on the generic staff review and the licensee's submittal, the staff concludes that relocating the chlorine detection system requirements from the TSs to the UFSAR is acceptable.
3.5 Loose-Part Detection Svstem in its submittal the m.ensee stated:
The Loose-Part Detection System is described in UFSAR Section 4.4.6.2, " Loose-Part Monitoring System." This system is provided in response to the recommendations of
.g.
Regulatory Guide 1.133, " Loose-Part Detection Program for the Primary System of Light-Water-Cooled Reactors", May 1981. The purpose of this system is to identify the existence of possible loose parts in the Reactor Coolant System. Early detection can provide operators time to take corrective actions and to avoid or mitigate damage to or malfunctions of primary system components.
An evaluation of the Loose-Parts Detection System with respect to the four criteria of 10 CFR 50.36(c)(2)(ii) follows:
Criterion 1: The Loose-Parts Detection System is not installed instrumentation that is used to detect a significant abnormal degradation of the reactor coolant pressure boundary. This system is not installed for, or capable of, detecting reactor coolant leakage. The NRC's Final Policy statement and GL 95-10 explicitly identify this system as an example of controls that are not required to be retained in the TS. This system does not meet Criterion 1 of 10 CFR 50.36(c)(2)(ii) for inclusion in the TS.
Criterion 2: This system is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This system does not meet Criterion 2 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 3: This system is not a component that is part of the primary success path and it does not provide a function or actuation in order to mitigate the consequences of a Design Basis Accident or Transient. This system does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
Criterion 4: This system has not been shown to be significant to public health and safety by either operational experience or probabilistic safety assessment. This system was not included in the scope of the Fermi 2 individual Plant Examination or the Individual Plant Examination for Extemal Events, nor is it " risk significant" under the Fermi 2 Maintenance Rule Program. This system does not meet Criterion 4 of 10 CFR 50.36(c)(2)(ii) for inclusion in TS.
In GL 95-10, the NRC staff also evaluated the loose-part detection system with respect to the 10 CFR 50.36 criteria. The staff concluded that the system does not function to detect significant abnormal degradation of the reactor coolant pressure boundary and that it does not serve as an active design feature for establishing initial conditions or mitigation of design basis accidents or transients. The staff concluded that requirements for this system do not satisfy the 10 CFR 50.36 criteria and need not be included in TSs. Based on the generic staff review and the licensee's submittal, the staff concludes that relocating the loose-part detection system requirements from the TS to the UFSAR is acceptable.
3.6 Overall Conclusion The licensee has provided justification, consistent with GL 95-10, for the relocation of the subject instrumentation requirements from the TSs to the UFSAR. The staff has concluded that
e the control of the relocated provisions in accordance with the applicable regulation ensures that NRC review and approval will be requested for changes exceeding the stated regulatory threshold (e.g., an unreviewed safety question). In addition, the s,taff has concluded that the elimination of the special reporting requirements is an administrative change that will be replaced by the reporting requirements of 10 CFR 50.72 and 10 CFR 50.73. Updating the TS Index and List of Tables is also an administrative change to reflect the relocation of the above TSs and their associated bases. Therefore, the staff conJudes that the proposed changes 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 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents 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 54870). 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 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 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: Andrew J. Kugler Date: March 17, 1998