ML20236R142

Safety Evaluation Supporting Amend 122 to License NPF-43

ML20236R142
Person / Time
Site:	Fermi
Issue date:	07/13/1998
From:	NRC (Affiliation Not Assigned)
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ML20236R140	List: ML20236R139 ML20236R142
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NUDOCS 9807210263
Download: ML20236R142 (21)

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UNITED STATES g

NUCLEAR REGULATORY COMMIS810N WASHINGTON, D.C. 30086 0001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l

RFI ATED TO AMENDMENT NO.122 TO FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDISON COMPANY FERMI 2 DOCKET NO. 50-341 l

l

1.0 INTRODUCTION

I By letter dated December 10,1997 (NRC-97-0105), as supplemented January 28 and April 9, 1998, 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.

j The proposed amendment would revise the TS to reflect design changes that upgrade the l

l analog-based average power range monitor (APRM) system in Fermi 2 with a General Electric

{

(GE) Company Nuclear Measurement Analysis and Control Power Range Neutron Monitor

]

- System (NUMAC-PRNMS), including an Oscillation Power Range Monitor (OPRM) function.

The January 28 and April 9,1998, letters provided clarifying information and updated TS pages l

that were within the scope of the original FederalRegister notice and did not change the staff's initial proposed no significant hazards considerations determination.

The proposed license amendment is applicable to the APRM and the licensee will implement it after the NUMAC-PRNMS is installed. The licensee will operate the OPRM functions in the

" indicate only" test mode for one fuel cycle. During this test period, the existing interim corrective actions for determining and mitigating power oscillations will remain in effect. Before it connects the OPRM trip function to the reactor protection system (RPS), the licensee will have to submit, and the NRC staff will have to review and approve, the operating data and an OPRM-specific TS amendment.

By letter dated September 5,1995, the staff approved GE licensing topical report (LTR)

. NEDC-32410P, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor

. (NUMAC-PRNM) Retrofit Plus Option lll Stability Trip Function," [ Proprietary - not available for public disclosure). The staff determined that this topical report contains acceptable guidance for replacing the existing power range monitors in a boiling water reactor (BWR) with a digital NUMAC-PRNMS. The approved topical report, NEDC-32410P-A [ Proprietary - not available for pLblic disclosure), also contains guidance to ensure digital upgrade issues, relevant standards and guidelines, and TS are adequately addressed.

In accordance with commitments in the submittal dated December 10,1997, the licensee will prepare Design Calculation DC-5721, Volume I, for the installation of the plant modification to

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reflect the relay room seismic acceleration plus any panel amplification for both the operating basis earthquake and safe shutdown earthquake seismic response spectra to ensure they do 9807210263 990713 PDR ADOCK 05000341 P

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. not exceed the values in the applicable licensing topical report. The licensee will also perform a human factors review for the installation of the plant modification. In approving the proposed action, the staff relied upon these commitments and they are incorporated into this Safety Evaluation. ' information related to the commitments is also incorporated in the paragraphs of the amendment that describe the changes and the implementation of the amendment. These commitments will be completed prior to restart from the sixth refueling outage. Changes to the commitments require prior NRC approval.

The following safety evaluation addresses the APRM portian of the NUMAC-PRNMS implementMion for Fermi 2. Because the implementation date for the amendment is tied to the outage, the NRC requests that the licensee submit a letter informing the staff when the amendment is implemented.

2.0 SYSTEM DESCRIPTION The NUMAC-PRNMS uses the existing local power range monitors (LPRMs) and the reactor coolant system (RCS) recirculation loop flow instrumentation to provide APRM and OPRM trip signals to the RPS. The APRM system averages LPRM signals and processes RCS recirculation loop flow signals, and then compares the results to RPS trip set points. The OPRM detects and suppresses reactor core power instabilities using the Option lli approach described in LTR NEDO-31960, "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," dated June 1991, which was approved by the staff by a letter dated July 12,1993.

The GE NUMAC-PRNMS consists of four APRM channels and four voter channels. Trip signals from each of the four APRM channels are sent to all four voter channels. One voter module is dedicated to each RPS trip relay. A trip from any one unbypassed APRM will result in a " half-trip" in all four of the voter channels, but no trip inputs to either RPS trip system. A reactor trip occurs when two or more of the four APRM functions or two or more of the four OPRM functions calculate a trip condition. The voters perform a vote of the OPRM channel trip outputs separate from the APRM trip outputs (i.e., an OPRM trip in one channel and an APRM trip in another channel will not result in a reactor trip from two of four voters in a trip state).

The NUMAC-PRNMS also provides, in digital form, LPRM, APRM, recirculation flow values, APRM upscale, downscale, bypass, and inoperative; rod block monitor upscale, downscale, bypass, and inoperative; flow reference; and flow comparator signals. With the exception of the sequence of events monitoring, this information is provided to the plant computer through a multiplexed fiber-optic data link, The existing interfaces are being retained for the sequence of events monitoring.

3.0 EVALUATION

' As stated in the staffs safety evaluation in NEDC-32410P-A, to receive NRC approval of a NUMAC-PRNMS installation, the licensee must confirm:

1.

The applicability of NEDC-32410P, including clarifications and reconciled differences between the specific plant design and the topical report design descriptions,

3-2.

The applicability of the BWR Owners' Group topical reports that address the NUMAC-PRNMS and associated instability functions, set points and margins, 3.

Plant-specific revised TSs for the NUMAC-PRNMS functions are consistent with NEDC-32410P, Appendix H, and Supplement 1, 4.

Plant-specific environmental conditions are enveloped by the NUMAC-PRNMS l

equipment environmental qualification values, 5.

Administrative controls are provided for manually bypassing APRM/OPRM channels or protective functions, and for controlling' access to the APRM/OPRM panel and channel bypass switch, and 6.'

Any changes to the plant operator's panel have received human factors reviews per plant-specific procedures.

. The licensee's actions with regard to the above conditions are discussed in the following sections.

3.1 Analic=N!ity of the NUMAC-PRNMS Desian to the Fermi 2 Plant Dasign The staff compared the applicable Fermi 2 design features with the corresponding design features in NEDC-32410P-A. Fermi 2 is a GE BWR/4; a BWR design addressed in NEDC-32410P-A. Consistent with the system description in NEDC-32410P-A, the six APRM channels currently used in Fermi 2 will be combined into four 2-out-of-4 logic channels that will provide inputs through dedicated RPS channel voters to the four RPS channels. Four separate recirculation flow transmitters are located in each recirculation flow loop. These proposed design modifications and features conform to the NUMAC-PRNMS design description in NEDC-32410P-A, and are compatible with the existing plant neutron monitoring system and 3

RPS. Therefore, the staff finds that the NUMAC-PRNMS design is applicable to Fermi Unit 2.

i 3.2 PRNMS Instability Functions. Set Points. and Marains Thef

,see will test the NUMAC-PRNMS instability function (OPRM), including the adequacy

- of the etpoint values and margins during the first fuel cycle of OPRM operation. At the end of the fuel cycle, following NRC staff review and approval of the operating data, thn OPRM trip function will be connected to the RPS, and OPRM TS changes will be implemented. The staff approved the initial period for OPRM confirmatory testing in the safety evaluation of NEDC-32410P, and, therefore, finds the licensee approach acceptable.

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3.3 Plant-Soecdic Revised Technical Specifications The following section describes the licensee's proposed TS amendments and the NRC staff's evaluation of each proposed change.-

1

. 3.3.1 Chances to Limitina Safety System Settinas The licensee changed the Action footnote for the Limiting Safety System Settings (LSSS) for Reactor Protection System Instrumentation Setpoints (LSSS 2.2.1) to replace the reference to APRM flow-biased instrumentation with a reference to the APRM Simulated Thermal Power-Upscale Functional Unit. Additionally, the licensee changed 'setpoints' to ' Flow Biased setpoints' and replaced ' adjusted within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />' with ' changed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />'. These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

3.3.2 Pronosed Chanoes to TS Table 2 21-1. Reactor Protection System Instrumentation Seipoints The licensee changed the name of Functional Unit 2.a from " Average Power Range Monitor Neutron Flux-Upscale, Setdawn" to " Average Power Range Monitor Neutron Flux-Upscale (Setdown)". This change is (onsistent with NEDC-32410P-A and, therefore, is acceptable.

The licensee changed the name of Functional Unit 2.b from " Flow Biased Simulated Thermal Power-Upscale" to " Simulated Thermal Power-Upscale". This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

The licensee deleted reference to Functional Unit 2.b.1, which stated, "During two recirculation loop operatiori:" This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

The licensee changed the number of Functional Unit 2.b.1.a " Average Power Range Monitor Simulated Thermal Power-Upscale Flow Biased", to 2.b.1. The trip setpoint algorithm for this function was changed from s0.63W+61.4% to 50.63(W-AW)+61.4%.

The allowable value was changed from 0.63W+64.3% to 0.63(W-AW)+64.3%. The licensee added a footnote for this function. The footnote states, The Average Power Range Monitor Simulated Thermal Power-Upscale Flow Biased scram setpoint varies as a function of recirculation loop drive flow (W).

AW is defined as the difference in indicated drive flow (in percent of drive flow which produces rated core flow) between two loop and single loop operation at the same core flow. AW=0% for two loop operation. AW=8% for single loop operation.

l The revised setpoint and allowable value algorithms for two loop operation (AW=0%) remain the same as the existing getpoint and allowable value and, therefore, are ecceptable. Using AW=B% in the proposed trip setpoint algorithm yields a trip setpoint slightly more conservative l

than the existing single loop setpoint. These changes, therefore, are acceptable.

The licensee changed the number of Functional Unit 2.b.1.b, " Average Power Range Monitor Simulated Thermal Power-Upscale High Flow Clamped," to 2.b.2. Additionally, the licensee combined the setpoint and allowable valuelimits for Functional Units 2.b.1 and 2.b.2. These changes are consistent with NEDC-32410P-A, and, therefore, are acceptable.

. The licensee deleted reference to Functional Unit 2.b.2, " Average Power Range Monitor Simulated Thermal Power-Upscale During Single Recirculation Loop Operation," subfunctions

. 2.b.2.a and 2.b.2.b, and the associated footnote. These functions were replaced by reference to amended Functional Units 2.b.1 and 2.b.2 These changes are consistent with NEDC-32410P-A and the amended Functional Unit 2.b, and, therefore, are acceptable.

The licensee changed the name of Functional Unit 2.c from " Average Power Range Monitor Fixed Neutron Flux-Upscale" to " Average Power Range Monitor Neutron Flux-Upscale." This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

The licensee added Functional Unit 2.e, "2-Out-Of-4 Voters," and specified *NA" for the trip

~

. setpoint and allowable value. These changes are consistent with NEDC-32410P-A, and,'

therefore, are acceptable.

-3.3.3 Prooosed Chances to Limitina Condition for Ooeration 3 3.1. Rametor Protection Svstem Instrumentation The licensee added Action c to Limiting Condition for Operation (LCO) 3.3.1. Action c states,

c. With one or more channels required by Table 3.3.1-1 inoperable in one or more APRM Functional Units 2.a, 2.b, 2.c, or 2.d:

1.

Within one hour, verify sufficient channels remain OPERABLE or tripped *" to '

1 maintain trip capability in the Functional Unit, and 2.

Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, restore the inoperable channels to an OPERABLE status or tripped *".

The footnote, *", states, An inoperable channel need not be placed in the tripped condition where this would cause a scram to occur. In these cases, if the inoperable channel is not restored to OPERABLE status within the required time, the I

ACTION required by Table 3.3.1-1 for the Functional Unit shall be taken.

Action c, with the footnote, is consistent with NEDC-32410P-A TS Actions and associated footnotes, and, therefore, is acceptable.

The licensee added a footnote (#) to LCO 3.3.1, Action a and Action b. The footnoto states, Actions a and b not applicable to APRM Functional Units 2.a. 2.b,2.c, and 2.d.

Action c applies only to APRM functions 2.a,2.b, 2.c and 2.d.

i i

. Th s footnote s consistent with NEDC-32410P-A and the licensee's proposed Action c, and, l

therefore, is acceptable. The staff noted that the wording in the footnote in the markup of the TF pages in Enclosure 3 to the January 28,1998, submittef diffe:ed slightly from the wording in

. the retyped TS pages in the enclosure without changing the meaning. The staff discussed this issue with the licensee and, per that discussion, used the retyped version for the amendment.

3.3.4 Prooosed Channes to Randor Protection Svatem Instrumentation Surveillance RRQuire"lents The licensee changed TS Surveillance Requirement (SR) 4.3.1.2, as RPS functions 2.a. 2.b, 2.c, and 2.d do not require separate logic system functional tests. The existing TS SR 4.3.1.2

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

The proposed TS SR 4.3.1.2 states, 4.3.1.2 LOGIC SYSTEM FUNCTIONAL TESTS and simulated automatic operation of all channels shall be performed at least once per 18 months, except Table 4.3.1.1-1, items 2.a,2.b,2.c,2.d, and 2.e. Functions 2.a,2.b,2.c, and 2.d do not require separate LOGIC SYSTEM FUNCTIONAL TESTS. For Function 2.e, tests shall be performed at least onco per 24 months. The LOGIC SYSTEM FUNCTIONAL TEST for Function 2.e includes simulating APRM trip conditions at the APRM channel inputs to the 2-out-of-4 Trip Voter channel to check all combinations of two tripped inputs to the 2-out-of-4 Trip Voter logic in the Voter channels.

This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

q Section 8.3.4.4.2 of NEDC-324 20P-A recommended deletion of the response time testing requirements for the APRM electronics and the 2-out-of-4 logic module portion of the APRM functions. The topical report further recommended that licensees retain the requirement for response time testing from the 2-out-of-4 logic module output relays through the RPS contactors (0.05-second of the 0.09-second response time requirement). Additionally, the APRM 2-out-cf-4 logic module portion of the APRM reactor functional units does not have an associated response time requirement. The licensee initially proposed a change to TS SR 4.3.1.3 to clarify that response time testing would be performed only for applicable RPS functions. The staff requested removal of the word " applicable" from the proposed TS SR 4.3.1.3. The licensee subsequently withdrew this requested change by letter dated April 9, 1998.. This response to the staffs concern regarding the proposed wording is acceptable to the staff.

3.3.5 Pronosed Chanaes to TS Table 3.3.1-1. Reactor Protection Svatem Instru.naniahon (Limitina Conditions for Operatiarn 4

The licensee revised the required operating conditions (OCs) for the APRM functions by eliminating the requirement for operable APRM functions in OC 5. Consequently, the licensee changed Note (d) to remove the reference to the APRMs. This change is consistent with l

NEDC-32410P-A, and, therefore, is acceptable.

l

l Any two of the four APRM channels and one 2-out-of-4 voter channel in each RPS trip system are required to function for the APRM safety function to be operable. Consequently, the proposed TS Table 3.3.1-1 requires three of the four APRM channels and all four voter channe!s to be operable. The voter functional units are required in OC 1 and OC 2. These l

changes are consistent with NEDC-32410P-A, and therefore, are acceptable.

Note "e" to Table 3.3.1-1 requires a minimum of 2 LPRM inputs per level and 14 LPRM inputs to an APRM channel for an APRM channel to be operable. The licensee relocated this note l

from Table 3.3.1-1 to the TS Bases section, and changed the note to reflect a NUMAC-PRNMS l'

configuration requiring 3 LPRM inputs per level and 20 LPRM inputs per APRM channel. This change is consistent with NEDC-32410P-A, and therefore, is acceptable.

l The licensee proposed the addition of Note (k) to TS Table 3.3.1-1 to describe the NUMAC-PRNMS channel configuration and to reference TS Table 3.3.1-1 Note (a). Note (k)

states, (k) Since each APRM channel provides input to both trip systems, the minimum operable channels specified in Table 3.3.1-1 are the total APRM channels required (i.e., it is not on a trip system basis). The 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowed test time to i

complete a channel surveillance test (note (a) above) is applicable provided at least two OPERABLE channels are monitoring that parameter.

This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

l 3.3.6 Chances to TS Table 4.3.1.1-1. Reactor Protection Instrumentation Surveillance Requirements (Channel Check. Channel Functional Test. Channel Calibration) and i

Asscciated Table Notations The existing TS Table 4.3.1.1-1 requires channel checks of the RPS APRM functions (except for the Inoperative function) at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and a channel check of the Neutron Flux-Upscale, Setdown function prior to each startup. The licensee added the 2-out-of-4 voter function to TS Table 4.3.1.1-1 and changed the channel check frequency from S (at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) to Daily for all APRM functions except Functienal Unit 2.d, Inoperative. These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

For the Neutron Flux-Upscale (Setdown) function and the Inoperative function, the licensee l

deleted OCs 3 and 5 from the operational condition requirements for which APRM surveillance are required. These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

For the Neutron Flux-Upscale (Setdown) function, the Simulated Thermal Power-Upscale function, and the Neutron Flux-Upscale function, the licensee changed the semiannual channel calibration frequency to 2 years (refueling interval). This change is consistent with NEDC-32410P-A, and, therefore, is acceptable.

The licensee changed Note (e), which is applicable to channel calibrations of the Simulated Thermal Power-Upscale function. The existing Note (e) states,

h

.. (e) This calibration shall consist of the adjustment of the APRM flow biased channel to

,onform to a calibrated flow signal.

The revised Note (e) states, (e) Calibration includes flow input function, including flow transmitters.

This change is consistent with NEDC-32410P-A, and, therefore, is acceptable.

The licensee deleted Note (h) from TS Table 4.3.1.1-1. Note (h) required a verification of the 6 i 1 second simulated thermal power time constant. The NUMAC-PRNMS implements this time constant in software, which eliminates the need for time constant verification. This change, therefore, is acceptable.

. The licensee added Note (I) for the APRM Simulated Thermal Power-Upscale Channel Functional Test (CFT). Note (i) states that a CFT shall include the flow input function, excluding l

flow transmitters. This change is consistent with NEDC-32410P-A and, therefore, is acceptable, j

The licensee added Note (m) for the APRM Neutron Flux-Upscale (Setdown) Channel Functional Test (CFT). Note (m) states that a CFT is not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 1. This change is L

consistent with NEDC-32410P-A, and, therefore, is acceptable.

The licensee also changed the Channel Test frequency for the APRM functions to semiannual.

This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

3.3.7 ChADoes to LCO 3.3.6. Control Rod Block Instrumentation The licensee changed the footnote for LCO 3.3.6, Control Rod Block Instrumentation, Action a.

The existing footnote states,

• The APRM Flow Biased Neutron Flux-High instrumentation need not be declared inoperable upon entering single reactor recirculation loop operation provided the setpoints are adjusted within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per Specification 3.4.1.1.

l The revised footnote states, l

• The APRM Simulated Thermal Power-Upscale Functional Unit need not be declared L

inoperable upon entering single reactor recirculation loop operation provided the flow L

biased setpoints are changed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per Specification 3.4.1.1.

This change is consistent with the NUMAC-PRNMS implementation and proposed TS in NEDC-32410P-A, and therefore, is acceptable.

l l

.g.

3.3.8 Chances to TS Table 3.3.6-1. Control Rod Block Instrumentation (Limitina Conditions for Operation)

The licensee changed Table 3.3.6-1 Trip Function 2 names to be consistent with the NUMAC-PRNMS APRM function names. The licensee changed the required number of minimum channels to three channels per trip function, and removed OC 5 as an applicable OC.

Additionally, the licensee relocated the Reactor Coolant Recirculation Flow-Upscale function from Trip Function 6.a to Trip Function 2.e, changed the minimum operable channels requirement from 2 channels to 3 channels, revised the required action from 62 to 61 to be consistent with the other APRM rod block functions, and, consistent with NEDC-32410P-A, deleted the remaining Reactor Coolant Recirculation Flow trip functions. NEDC-32410P-A does not restrict the licensee from continuing to use the Reactor Coolant Recirculation Flow-Upscale function and the APRM functions. The proposed changes, therefore, are acceptable.

3.3.g Chances to TS Table 3.3.6-2. Control Red Block Instrumentation (Limitina Conditions for Operation)

The licensee corrected the numbering of Table 3.3.6-2, Control Rod Block Instrumentation Setpoints, which had been incorrectly numbered Table 4.3.6-2. This is an administrative change that corrects an error in the table number, and, therefore, is acceptable.

The licensee changed Trip Function 2.a.1, which stated, "During two recirculation loop operation" to " Flow Biased." This change is consistent with NEDC-32410P-A and, therefore, is acceptable.

The trip setpoint algorithm for Trip Function 2.a.1 was changed from 50.63W+55.6% to s0.63(W-AW)+55.6%. The allowable value was changed from 0.63W+58.5% to 0.63(W-AW)+58.5%. The licensee replaced the footnote for these algorithms with the following footnote:

The Average Power Range Monitor Simulated Thermal Power-Upscale Flow Biased and Rod Block setpoint varies as a function of recirculation loop drive flow (W). AW is defined as the difference in indicated drive flow (in percent of drive flow which produces rated core flow) between two loop and single loop operation at the same core flow. AW=0% for two loop operation. AW=8% for single loop operation.

The revised setpoint and allowable value algorithms for two loop operation (AW=0%) remain the same as the existing setpoint and allowable value and, therefore, are acceptable. Using AW=8% in the proposed trip setpoint algorithm yields more conservative setpoint and aliewable values. These changes, therefore, are acceptable.

The licensee deleted Trip Function 2.a.2, Average Power Range Monitor Simulated Thermal Power-Upscale During Single Recirculation Loop Operation, and the associated footnote. This trip function was replaced by Trip Function 2.a.2, High Flow Clamped. The licensee changed the trip setpoint phrase, "with a maximum of 108% RATED THERMAL POWER," to "with a maximum of 108% of RATED THERMAL POWER." The licensee changed the allowable value phrase, "with a maximum of 110% RATED THERMAL POWER," to "with a maximum of 110%

l

^

. of RATED THERMAL POWER.* The licensee made the trip setpoint algorithm and the allowable value algorithm applicable to both the Flow Biased trip function and the High Flow Clamped trip function. These changes are consistent with the licensee's existing TS and the NUMAC-PRNMS configuration and, therefore, are acceptable.

The licensee changed the name of Trip Function 2.c from Downscale to Neutron Flux-Downscale. The licensee changed the name of Trip Function 2.d from Neutron Flux-Upscale, Setdown to Simulated Thermal Power-Upscale (Setdown). The licensee

- relocated the Reactor Coolant Recirculation Flow-Upscale Trip Function and associated trip 1

setpoint and allowable value from Trip Function 6.a to Trip Function 2.e. The licensee deleted Trip Function 6b, Reactor Coolant System Recirculation Flow Inoperative, and Trip Function Sc, Reactor Coolant System Recirculation Flow Comparator. These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

3.3.10 Channes to TS Table 4.3.6-1. Control Rod Block Instrumentation Surveillance Requirements The licensee deleted the Reactor Coolant System Flow function from TS Table 4.3.6-1 in accordance with the discussion NEDC-32410P-A, Section 5.5.1.2. The licensee retained the APRM Rod Block functions, including the Flow-Upscale function. These changes are consistent with NEDC-32410P-A, and, therefore, are acceptable.

The licensee changed the name of Trip Function 2, APRM, to Average Power Range Monitor.

This is an administrative change and is acceptable.

The licensee changed the name of Trip Function 2.c from Downscale to Neutron -

Flux-Downscale. The licensee changed the name of Trip Function 2.d from Neutron Flux-Upscale, Setdown to Simulated Thermal Power-Upscale (Setdown). The licensee relocated the Reactor Coolant Recirculation Flow-Upscale Trip Function and associated surveillance requirements from Trip Function 6.a to Trip Function 2.e. The licensee deleted Trip Function 6b, Reactor Coolant System Recirculation Flow Inoperative, and Trip Function Sc, Reactor Coolant System Recirculation Flow Comparator. These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

The licensee changed the Rod Block Monitor Upscale, Inoperative, and Downscale trip function CFT from Startup and Quarterly to Semiannual. The licensee changed the Rod Block Monitor Upscale, Inoperative, and Downscale trip function channel calibration frequency from Quarterly to 2 years (refueling interval). These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

The licensee changed from S (at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) to NA the channel check frequencies i

' for the Simulated Thermal Power-Upscale, Neutron Flux-Downscale, Simulated Thermal

]

Power-Upscale (Setdown), and Reactor Coolant System Recirculation Flow-Upscale Roc Block i

Monitor trip functions. The licensee also removed OC 5 from the OCs for which surveillance are required. These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

I

. 3.3.11 Channes to LCO 3.4.1.1. Recirmlation Svstem RecirenIntion Loons Limitina Conditions for Operation The licensee deleted the footnote associated with LCO 3.4.1.1 Action a.1.e, and changed the Action statement. The existing TS states, e) Reduce the Average Power Range Monitor (APRM) Scram and Rod Block Trip Setpoints and Allowable Values to those applicable for single recirculation loop operation # per Specifications 2.2.1 and 3.3 6.

i The revised Action a.1.e states, e) Reduce the Average Power Range Monitor (APRM) Simulated Thermal Power-Upscale Flow Biased Scram and Rod Block Trip Setpoints and Allowable Values to those applicable for single recirculation loop operation per Specifications 2.2.1 and 3.3.6.

These changes are consistent with NEDC-32410P-A and, therefore, are acceptable.

3.3.12 Changes to TS Bases 1

The licensee revised the TS Bases to describe the NUMAC-PRNMS. These Bases discussions are consistent with NEDC-32410P-A and the NUMAC-PRNMS configuration in Fermi 2, and, therefore, are acceptable. The staff noted that the wording in the first paragraph of insert "A" to the markup of the page B 2-7 in Enclosure 3 to the January 28,1998, submittal differed slightly from the wording in the retyped page in the enclosure without changing the meaning. In addition, the staff noted that the retyped page B 3/4 3-1 corrected a typographical error in item

c. (the word adsorbed was corrected to read absorbed). The staff discussed these items with the licensee and, per that discussion, used the retyped version of these pages for the amendment. Finally, the last sentence of Insert "C" to page B 3/4 3-1 introduced a typographical error at the end of the last sentence. As-written it says, in part, " redundancy with 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." It should have read, " redundancy within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." The staff discussed this issue with the licensee and, per that discussion, corrected this typographical error in the amendment.

3.4 Plant-Soecific Environmental Conditions The licensee will prepare Design Calculation DC-6012, Vol.1, as part of the normal design process to reflect the relay room seismic acceleration plus any panel amplification for both the operating basis earthquake and safe shutdown earthquake seismic response spectra to ensure -

that these spectra do not exceed the generic seismic qualification of the NUMAC-PRNMS. This activity may be confirmed by staff review after the equipment is installed in Fermi Unit 2. The staff has relied on this commitment in approving the amendment. This commitment will be completed prior to restart from the sixth refueling outage. Changes to the commitment require prior NRC approval.

In Table 1 below, the Fermi 2 plant-specific environmental conditions for temperature, humidity, pressure, and radiation are compared to the NUMAC-PRNMS environmental qualification

. values. As shown in Table 1, the Fermi 2 environmental conditions are enveloped by the generic NUMAC-PRNMS qualification values, and, therefore, are acceptable.

Table 1. Comparison of Fermi 2 Environmental Conditions with I

NUMAC-PRNMS Environment Qualification Values I

FERMI UNIT 2 NUMAC-PRNMS Temperature 15.6*C to 48.9'C 5'C to 50*C 4

(60'F to 120*F)

(41*F to 122*F)

Humidity 60% RH (max) 10% to 90% RH (noncondensing) i l

Pressure 0.1 in (H O) to 0.5 in (H O) 13 psia to 16 psia j

2 2

14.7 psia Radiation

<0.005 mGy/hr dose rate 1E-4 Gy(Carbon)/hr dose rate

)

1.75 Gy TID 1E+2 Gy (Carbon) TID NEDC-32410P-A states that new equipment and plant modifications should not produce unacceptable levels of noise emissions (electromagnetic interference) that could advtsrsely affect NUMAC equipment, or the licensee is to take action to prevent these emissions from reaching potentially sensitive equipment. These measures apply for both noise susceptibility and emissions. The licensee evaluated the susceptibility of other GE NUMAC equipment installed in Fermi 2. The licensee states that there have been no electromagnetic interference (EMI) problems with other NUMAC equipment installed in locations similar to the NUMAC-PRNMS installation at Fermi 2 since 1991. The licensee stated that the only potential EMI-related problems were related to power supply problems and an abnormal computer display problem that may have been caused by electrostatic discharge. The power supply ar,J electrostatic problems have been addressed in the NUMAC-PRNMS design. As described in NEDC-32410P-A, the NUMAC-PRNMS uses the same panel interfaces as the existing power range monitor equipment. High frequency filters are installed on the ac power supply, and shielded cables for all signal leads will be used in lieu of testing nonsafety equipment noise effects on the NUMAC-PRNMS. The staff finds the licensee's evaluation of the EMI environment and the measures taken to reduce adverse EMI affects in the NUMAC-PRNMS installation to meet the staff guidance on EMI qualification, and therefore, acceptable.

3.5 Administrative controls in the safety evaluation of NEDC-32410P, the staff found acceptable the NUMAC-PRNMS design features that control access to setpoint adjustments, calibrations, and test points. The licensee states that administrative procedures will provide controls for manually bypassing APRM/OPRM channels or protective functions and wi'l control access to the bypass controls.

These activities are acceptable to the staff.

l l

O 4 3.6 Cor firmat'on of Human Fardars Review The licensee stated that the Fermi 2 design change process and implementing procedures require completion of a Human Facters Checklist and performance of a human factors evaluation (HFE) review of changes to the plant operator's panel. The licensee further stated that an HFE review, per applicable Fermi 2 procedures, of the proposed changes to the operator's panel will tm performed, and documentation of that review will be included in the final-design package (s) for the NUMAC-PRNMS. These activities are acceptable to the staff. The staff has relied on this commitment in approving the amendment. This commitment will be

- completed prior to restart from the sixth refueling outage. Changes to the commitment require pr;or AC approval.

3.7 Conclusion I

Based on the above review and justifications for TS changes, the staff concludes that the licensee's proposed TS changes for Farmi 2 are consistent with the staff-approved guidance in NEDC-32410P-A and Supplement 1 to NEDC-32410P-A. The staff further concludes that the licensee has properly addressed the plant-specific conditions described in the staffs safety evaluation for NEDC-32410P, and, therefore, finds the NUMAC-PRNMS modification and associated TS changes to be acceptable.-

4.0 STATE CONSULTATION

I lo etccordance with the CommMion's regulations, the Michigan State official was notified of Jie 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 and changes surveillance requirements. The staff has determined that the amendment involves no significant increase in the amounts, and ne significant change in the types, of any effluents that may be redessed offsite, and that there is no significant increase in individual or cumulative occupational radiaCon 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 (63 FR 2279). 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 cons!derations 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 l

common defense and security or to the health and safety of the public.

Principal Contributor. M. Waterman Date: July 13,1998