NRC-88-0027, Application to Amend License NPF-43 Changing Tech Specs to Modify Footnote Number to Include Provisions to Place Mode Switch in Refuel Position to Facilitate Source Range Monitor & Intermediate Range Monitor Operability Testing.Fee Paid
| ML20148K989 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/28/1988 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20148K995 | List: |
| References | |
| CON-NRC-88-0027, CON-NRC-88-27 NUDOCS 8804010090 | |
| Download: ML20148K989 (7) | |
Text
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B. Ralph Syms Group Vice President 7
MQ 640) North Ome High*ay I
n Newport, %chigan 48166 (313) 586-4150 March 28, 1988 NRC-88-0027 U. S. Nuclear Regulatory Commission Attn: Dccument Control Desk Washington, D. C.
20555
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Proposed Technical Specification (License Amendment)
Change - 1.0 Definitions (Table 1.2 Operational Conditions)
Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into Technical Specification 1.0 Definitions -
Table 1.2 Operational Conditions. The proposed change modifies Footnote i to include the provisions to place the mode switch in the Refuel position to facilitate Source Range Monitor and Intermediate Range Monitor operability testing.
Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Organization has approved and the Nttelear Safety Review Group has reviewed these proposed Technical Specification changes and concurs with the enclosed determinations.
Pursuant to 10CFR170.12(c), enclosed with this amendment i.s a check for one hundred fif ty dollars ($150.00). In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.
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USNRC March 28, 1988 NRC-88-0027 Page 2 If you have any questir,ns, please contact Mr. Glen Ohlemacher at (313) 586-4275.
Sincerely, Y
Enclosure cc:
Mr. A. B. Davis Mr. E. G. Greenman Mr. T. R. Quay Mr. W. G. Rogers Supervisor, Advanced Planning and Review Section, Michigan Public Service Commission J
USNRC March 28, 1988 5
NRC-88-0027 Page 3 I. B. RALPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to tha best of my knowledge and belief.
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, 1988, before me personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act rnd deed, f/*
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1mC-88-0027 Page 1 BAMGROUP0/ DISCUSSION Technical Specification 1.0 Definitions - Table 1.2 Operational Conditions, Footnote # currently does not include provisions to place the mode switch in the Refuel position to facilitate testing Source Range Monitor (SRM) and Intermediate Range Monitor (IRM) instrumentation. The proposed change modifies Footnote # to include these provisions. The change also facilitates other testing o' rod block actuation instrumentation during Operational Conditions. and 4.
Detroit Edison has recognized the need to clarify Footnote f to allow for expedited SRM and IRM oprrability testing. SRMs and IRMs are not required to be operable in Operational Condition 1 and, therefore, may require channel functional or calibration testing immediately following a plant shutdown or scram.
Performing SRM and IRM surveillances with the reactor mode switch in the Shutdown position precludes testing of the control rod block function, since the Shutdown position of the reactor mode switch also provides a control rod block. The control rod block function, on the other hand, must be tested prior to entering Operational Condition 2 or 5.
To complete the required testing, the reactor mode switch must be placed in a position which does not create a rod block (position other than Shutdown). Testing of the rod block function is currently done using the Start-up/ Hot Standby position because there is no provision for using the Refuel position. This situation exists primarily when attempting IRM and SRM surveillances but is also applicable to any rod block testing which may be necessary in Operational Conditions 3 and 4 Detroit Edison believea that the Refuel position is the most conservative switch position to use for this purpose. The Refuel position maintains the scram pretective features which are also available in the Start-up/ Hot Standby and Shutdown positions.
However, the Refuel position replaces the control rod block with a one-rod-out permissive feature. The Start-up/ Hot Standby position does not provide a feature to limit control rod withdrawal.
Detroit Edison also proposes to clarify the intent that r:ovement of the mode switch be allowed in order to test instrumentation affected by the mode switch interlocks by including the phrase "and related instrumentation" in the footnote.
The Technical Specification change request would allow performance of surveillance requirements with the mode switch in the Refuel position. The Footnote f in Table 1.2 would be revised as follows:
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"# The reactor mode switch may be placed in the Run, Startup/ Hot Standby, or Refuel position to test the cuitch interlock functions and related instrumentation provided that the control rods are verified to remain fully inserted by a second licensed operator or other technically qualified member of the unit technical staf f."
This provision, in Table 1.2, would allow the performance of surveillance testing with the mode switch in the Refuel position to facilitate rendering the affected instrumentation operable.
SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edisor must i
establish that operation in accordance with the proposed atendment would not:
- 1) involve a significant increase in the probalility or consequences of an accident previously evaluated, or 2) cre ate the possibility of a new or dif ferent kind of accident from any accident previously evaluated, or, 3) involve a significant reduction in a margin of safety, i
- 1) The proposed change to include provisions to place the mode switch in the Refuel position to facilitate surveillance testing of instrumentation does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The change involves placing the mode switch in the Refuel position during shutdown (Operational Conditions 3 and 4) to expedite testing of rod block functions. The probability and consequences of an accident have not been increased as the Technical Specificationa continue to ensure that the one-rod-out interlock is operable prior to plenned rod withdrawal. This prevents the withdrawal of more than one control rod from the core.
Placing the mode switch in the Refuel position is thus a more conservative action than placing it in the Run or Startup/ Hot Standby position as currently allowed.
In addition, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered.
- 2) The proposed change to include provisions to place the mode switch in the Refuel position to facilitate surveillance testing of instrumentation does not create the possibility of a new or different kind of accident from any accident previously evaluated. Ac in 1) above, the change does not result in any modifications to the plant or system operation and no g
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Enclosure to NRC-88-0027 Page 3 safety-related equipment is altered. The requested change does not create any new accident mode.
- 3) The proposed change to include provisions to place the mode switch in the Refuel position to facilitate surveillance testing of instrumentation does not involve a significant reduction in a l
margin of safety. As stated in 1) above, placing the mode switch in the Refuel position to perform SRM and IRM operability testing continues to ensure that no more than one control rod could be withdrawn frcm the core due to the operability requirements of the one-rod-out interlock. Further, the use of the Refuel position is more conservative than the Run or Startup/ Hot Standby positions, which are currently allowed by the Technical Specifications.
Based upon the above reasoning, Detroit Edison has determined that the p;oposed amendment does not involve a significant hazards consideration.
ENVIRO)GGDffAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental consideratione. As shown above, the proposed change does not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
4 CONCLUSION Based on the evaluations above:
(1) there is 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 proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.
4 The change requested herein permits surveillance testing with the mode switch in the Refuel position. The change will expedite the testing procedure to declare these instruments operable. This change has been approved and issued en recently licensed BWR plants and does not involve a significant hazards consideration.
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