ML20235Z323
| ML20235Z323 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/09/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235Z318 | List: |
| References | |
| NUDOCS 8903150327 | |
| Download: ML20235Z323 (3) | |
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.I UNITED STATES
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g RIUCLEAR REGULATORY COMMISSION g
j WASHINGTOM, D. C. 20555 y.
j SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION I
SUPPORTING Ai4 ENCL'ENT NO.31 TO FACILITY CPERATIllG LICENSE NO. !!PF-43 DETROIT EDISON COMPANY WOLVERINE POWER SUPPLY COOPERATIVE, If?CORPORATED s
FERMI-2 DOCKET NO. 50-341
1.0 INTRODUCTION
(DECO or the licensee) the Detroit Edison Company (TSs) appended to Py letter dated May 24, 1988, requested an amendment to the Technical Specifications l
Facility Operating License No. NPF-43 for Fermi-2.
The proposed amendment would revise the TSs based en the guidance provided by the NRC staff in the portions of Generic Letter 87-09 (GL 87-09) pertaining to TSs 4.0.3 and 4.0.4 These proposed changes would allow a 24-hour delay in implementing ACTION requirements due to a missed surveillance when the ACTION requirements provice a restoration time which is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and would resolve interpretation ccnflicts between TSs 4.0.3 and 4.0.4.
The licensee's May 24, 1988 letter also proposed other changes to the TSs which will be handled separately.
l 2.0 EVALUATION TS 4.0.3 establishes the failure to perform a surveillance requirement within its specified time interval as non-compliance with the associated Limiting Condition for Operation (LCO).
In their submittal, Deco stated that assuming the equipment to be inoperable because a surveillance is m1ssed 5s overly l
conservative since a missed surveillance does not provide any real evidence that the function to be tested is actually inoperable.
This conservatism becomes a problem in instances where the LCO restoration time is short, thereby forcing testing (of
'l component that is probably OPERABLE) to be completed on an urgent basis in order to avoid a shutdown.
DECO proposed a revision to Technical Sgcification 4.0.3 to resclve this conservatism problem and to avoid unnecessary shutdown when the surveillance intervals are inadvertently exceeded.
The essence of the change to TS 4.0.3 proposed by DECO is to provide a reasonable amount of time (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) to perform a missed surveillance in recognition of the fact that in most cases a surveillance verifies the OPERABILITY, rather than inoperability, of a component. This allowance would only be provided when the existing actico statement time limits are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This revision is based on the NRC GL 87-09 guidance.
8903150327 890309 PDR ADOCK 05000341 P
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' The basis for the 24-hour limit, as stated in the Generic Letter and reiterated by DECO, is that it "would balance the risks associated with an allowance for completing the surveillance within this_ period aga1nst the risks associated with the potential fcr plant upset and challenge to safety systems. " The NRC staff concluded in the Generic Letter that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is appropriate based on consideration of plant' safety conditions, adequate l
planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completion of the surveillance.
TS 4.0.4 prohibits entry into an OPERATIONAL CONDITION or. cther specified condition until all required surveillance have been performed.
This could cause an interpretation. problem when OPERATIONAL CONDITION changes are required in order to comply with ACTION statements.
Specifically, two possible conflicts between TSs 4.0.3 and 4.0.4 could exist. The first conflict arises because TS 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements havc rot been performed within the specified surveillance interval. The Deco proposed modification to resolve this conflict involves the revision to TS 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the Action Requirements, as explained-above, and a clarification of TS 4.0.4 to allow passage through or to operational modes as recuired to comply with Action Requirements.
The second potential conflict between TSs a.0.3 and 4.0.4 arises because an exception to the requirements of 4.0.4'is allowed when surveillance requirements can only be completed after entry into a mode or condition.
However, after entry into this mode or conditior, the requirements of TS 4.0.3 may not be met because the surveillance requirements may not have been performed within the allowable surveillance interval.
DECO proposes to resolve these conflicts by providing the following clarifying statement to TS 4.0.4:
"This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements."
The NPC staff has provided in GL 87-09 a clarification that:
(a) it is not the intent of 4.0.3 that the Action Requirements preclude the performance of surveillance allowed under any exception to TS 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in TS 4.0.3 for the applicability of Action Requirements provides an appropriate time limit for the completion of surveillance requirements that become applicable as a consequence of any exception to TS 4.0.4.
Consequently, the NRC staff finds the proposed changes to TSs a.0.3 and 4.0.4 acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change in the surveillance requirements.
We have i
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.* determined that this amendment _ involves no.significant. increase in the
. amounts,land no significant change in'the types, of any effluents which may be released offsite, and that there is 'nci significant increase in individual or. cumulative occupational radiation exposure..The Commission has previously.
issued a proposed finding.that this amendment involves no significant hazards consideration and there has been' no public comment on such finding.
-- Accordingly, ~ this amendment meets the eli
' exclusion set'forth in 10 CFR 51.22(c)(9)gibility-criteria for ca~tegoricalPursuant to 10 C environmental impact statement or environmental assessment need be prepared-in connection with the' issuance of this amendment.
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4.0 CONCLUSION
We have concluded, based on the considerations discussed above, that (1)~
thereLis reasonable assurance that the health and safety of the public will not be endangered by operation'in the proposed manner, and (2) such activities will be conducted in compliance'with the Commission's regulations, and'the issuance of this amendment will not be inimical to.the common defense and security or to the health and safety of the public.
Principal Contributor:
Lynn Kelly Dated: March 9,1989
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