NRC-88-0057, Application for Amend to License NPF-43,revising Tech Spec Section 3/4.0 to Provide Provisions to Reset Instrument Channels &/Or Trip Sys & Remove Requirement to Place Channels &/Or Trip Sys in Unwarranted Tripped Condition
| ML20196H905 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/29/1988 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20196H910 | List: |
| References | |
| CON-NRC-88-0057, CON-NRC-88-57 NUDOCS 8807060279 | |
| Download: ML20196H905 (13) | |
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B. Ralph Sylvla F
Senor %ce Presadent d,I 6400 Noith Dime Hghway ISOn Newport.Michgan 48166 (313) 586-4150 June 29,1988 NRC-88-0057 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555
Reference:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43.
- 2) Detroit Edison letter to NRC, NRC 88-0062, "Proposed Technical Specification (License Amendment) Change - Applicability (3/4.0),"
dated May 24, 1988.
Subject:
Proposed Technical Specification Change (License Amendment) - Rod Block Monitcr (3/4.1.4.3) Reactor Protectico System Instrumentation (3/4.3.1).
Isolation Actuation Instrumentation (3/4.3.2),
Control Rod Block Instrumentation (3/4.3.6) and Source Range Monitors (3/4.3.7.6)
Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes amend Operating License NPF-43 for the Fermi 2 plant by incorpo.ating the enclosed changes into the Plant Technical Specifications. The proposed changes provide provisions to reset instrument channels and/or trip systems, which are tripped to comply with Action Statements, in order to restore the opetability of the associated instrumentation. In addition, changes have been proposed to remove the requirement to place channels and/or trip systems in the tripped condition when such action is not warranted.
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 Nuclear Safety Review Oroup has reviewed the proposed Technical Specifications and concurs with the enclosed determinations.
Pursuant to 10CFR170.12(c). Detroit Edison has previously submitted a fee of one hundred fifty dollars ($150.00) via a wire transfer of I
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June 29.-1988-NRC-88-0057 Page 2
- funds.. In accordance 'with 10CFR50'.91, Detroit Edicon 'has provided a
- copy of this. letter to the State of Michigan.
4 If you have any questions, please contact Mr. Glen D. 0hlemacher at (313) 586-4275.
Sincerely, Enclosure ec: Mr. A. B. Davis Mr. R. C. KnopL Mr. T. R. Quay Mr. W. G. Rogers Supervisor, Advanced Planning and Review Section, Michigan Public Survice Commission il
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B. RALPH SYLVIA, do hereby af firm that the' foregoing statements are i
based on facts and circumstances which are true and accurate to the '
best of my knowledge and belief.
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aA L~RALPflSYLJfA Sanior Vic VPresident On'this.
1i day of ONU 1988, before me personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act and deed.
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&.sc.c ) f&u.Av Notary Public MARCtA BUCK Notory Pubile Washtonow County, MI MyCommisskm ExpiresJon.11,1992 cle ic } & 7 %. m
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e lj Enclosure to NRC-88-0057 Page 1 BACKGROUM)/ DISCUSSION Technical Specifications 3.3.1, Reactor Protection System Instrumentation, and 3.3.7.6 Source Range Monitors, have Action statements to lock the reactor mode switch in the Shutdown position within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. These specifications currently do not include explicit provisions to allow the reactor modo switch to be placed in the Run, Startup/ Hot Standby, or Refuel positions to perform testing necessary for restoring the OPERABILITY of the applicabic instrumentation after the Action requirements have been completed. Currently, the only provisions for such testing is footnote i of Table 1.2 which provides reactor mode switch requirements for each OPERATIONAL CONDITION.
Detroit Edison believes that provisions for reactor mode switch movement for necessary testing should be explicitly stated when an Action statement explicitly specifies a mode switch position.
Similarly, Technical Specifications 3.1.4.3 Rod Block Monitor 3.3.1 Reactor Protection System Instrumentation, and 3.3.6 Control Rod Block Instrumentation have Action statements to place the channel and/or trip system in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. These specifications currently do not include provisions to allow resetting the channel and/or the trip system to permit testing associated with restoring the OPERABILITY of the applicable instrumentation after the Action requirements have been completed.
Currently, following completion of the Action, corrective action and retesting to the extent allowed by being in the tripped condition is completed. At that time the channel and/or trip system is considered OPERABLE for the purpose of resetting and immediate completion of testing. Detroit Edison believes that explicit provisions for resetting a channel and/or trip system for testing is highly desirable.
Additionally, Technical Specification 3.3.1, Reactor Protection System Instrumentation, requires placing one trip system in the tripped condition if both trip systems are inoperable, regardless of the OPERATIONAL CONDITION. If the reactor is already in OPERATIONAL CONDITION 3. HOT SHUTDOWN, OPERATIONAL CONDITION 4 COLD SHUTDOWN, or OPERATIONAL CONDITION 5, REFUELING, this could result in the reactor mode switch being in the chutdown position, all installed control rods full in, snd a half scram (one trip system tripped) as a result of placing the trip system in the tripped condition. Detroit Edison believes that requiring a half scram when the plant is in OPERATIONAL CONDITIONS 3, 4, or 5 is unnecessarily restrictive when it is verified that the control rods required to be inserted are and will remain fully inserted. The half scram often precludes necessary RPS system maintenance and testing resulting in unnecessary schedule delays.
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Enclosure to NRC-88-0057 Page 2
-Detroit Edison'~is proposing these changes to provide clearer Technical Specification guidance to the plant operators for situations which have been found troublesome due to lack of explicit provisions for necessary activities or where required actions have precluded
' desirable activities. Detroit Edison' believes these changes will enhance plant operation and_ improve operator understanding of Technical Specifications.
Prompt consideration of these proposals is requested.-
TECHNICAL SPECIFICATION CHANGES The Technical Specification change request would specifically change the following items:
(new language is underscored)
(1) 3.1.4.3, ACTION a. and b., page 3/4 1-18
- a.... 0therwise, place the inoperable rod block monitor channel in the tripped condition
- within the next hour,
- b. With both RBM channels inoperable, place at least one inoperable rod block monitor channel in the tripped condition
- within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
- An inoperable channel may be reset to permit testing associated with restoring the Rod Block Monitor to OPERABLE status.
This footnote was added to allow testing necessary to restore the Rod Block Monitor to service after it has been placed in the tripped condition.
(2) 3.3.1 ACTION.a. and b., page 3/4 3-1 ACTION:
- a. With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement for one trip system, place the inoperable channel (s) and/or that trip system in the tripped condition *1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The provisions of Specification 3.0.4 are not applicable.
- b. With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement for both trip systems, place at least one trip system ** in the tripped condition { within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and take the ACTION required by Table 3.3.1-1.
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Enclosure to NRC-88-0057 Page 3
- An inoperable channel and/or trip system may be reset to permit testing associated with restoring the Reactor Protection System Instrumentation to OPERABLK status.
This footnote was.added to allow testing necessary to. restore Reactor Protection System Instrumentation OPERABILITY.
(3) 3.3.1, footnote
- and **, page 3/4 3-1
- An inoperable:r.hannel need not be placed in the tripped condition where this would cause the Trip Function to occur. In tbase cases, the inoperable channel shall be restored to OtERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the ACTION required by Table 3.3.1-1 for that Trip Function shall be taken. In OPERATIONAL CONDITION 3, 4, or 5, an inoperable channel and/or trip system need not be placed in the tripped condition provided that all control rods, with the except. ion of control rods removed per Specifications 3.9.10.1 or 3.9.10.2, are verified to be fully inserted and remain fully inserted.
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- The trip system need not be placed in the tripped condition if this would cause the Trip Function to occur.
When a trip system can be placed in the tripped condition without causing the Trip Function to occur, place the trip system with the most inoperable channels in the tripped condition; if both systems have the same number of inoperable channels, place either trip system in the tripped condition. In OPERATIONAL CONDITION 3, 4, or 5, an inoperable channel and/or trip system need not be placed in the tripped condition provided that all control rods, with the exception of control rods removed per Specifications 3.9.10.1 or 3.9.10.2, are verified to be fully inserted and remain fully inserted.
This statement was added to both footnotes to not require the placing of the channel and/or trip system in the tripped condition in OPERATIONAL CONDITION 3, 4 or 5 when it is verified that all control rods required to be inserted are in fact inserted and that they will remain fully inserted, ensuring adequate SHUTDOWN MARGIN. When one control rod is removed per Specification 3.9.10.1 or multiple control rods are removed per Specifications 3.9.10.2, these Specifications ensure that SHUTDOWN MARGIN requirements are met.
This will allow necessary flexibility in the maintenance, operation, and testing of the Rcector Protection System while at the same time ensuring that all required control rods remain fully inserted.
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Enclosure to NRC-88-0057 Page 4 (4) 3.3.1 Table 3.3.1-1, ACTION 2, 8, and 9, page 3/4 3-4 ACTION 2 - Verify all insertable control rods to be inserted in the core and lock the reactor mode switch in the Shutdown position
- within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
ACTION 8 - Lock the reactor mode switch in the Shutdown position
- within i hour.
ACTION 9 - Suspend all operations involving CORE ALTERATIONS, and insert all insertable control rods and lock the reactor mode switch in the Shutdown position
- within i hour.
- The reactor mode switch may be placed in the Run, Startup/ Hot Standby, or Refuel position to permit testing associated with restoring the Reactor Protection System Instrumentation to OPERABLE status provided that all insertable control rods remain fully inserted.
This footnote was added to allow the reactor mode switch to be moved from the Shutdown position for the purpose of testing after the Action requirements have been completed.
(5) 3.3.2, Action b. and c., page 3/4 3-9
- b. With the number of OPERABLE channels less than required by the Minimum "0PERABLE Channels per Trip System requirement for one trip system, place the inoperable channel (s) and/or that trip system in the tripped condition *# within one hour. The provisions of Specification 3.0.4 are not applicable.
- c. With the number of OPERABLE channels less than required ';y the Minimum OPERABLE Channels per Trip System requirement for both trip systems, place at least one trip system ** in the tripped condition # within one hour and take the ACTION required by Table 3.3.2-1.
- An inoperable channel and/or trip system may be reset to permit testing associated with restoring the Isolation Actuation Instrumentation to OPERABLE status.
This footnote was added tr allow the channel and/or trip sys*.em to be reset for the purpose of testing in order to restcre the inoperable channel and/or trip system to an OPERABLE status after the Action requirements have been completed.
?g Enclosure to NRC-88-0057' Page 5 (6) 3.3 6, Table 3.3.6-1 Action 61a, 61b, and 62, page 3/4 3-43 ACTION 61 - With the number of OPERABLE Channels:
- a. One less than required by the Minimum OPERABLE Channels per Trip Function requirement, restore the inoperable channel to OPERABLE otatus within 7 days or place the inoperable channel in the tripped conditionf within the next hour.
- b. Two or more less than required by the Minimum OPERABLE
' Channels per Trip Function requirement, place at least one inoperable channel in the tripped condition # within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
ACTION 62 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip Function requirement, place the inoperable channel i ~
in the tripped condition { within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
- An inoperable channel may be reset to permit testing associated with restoring the Control Rod Block Instrumentation to OPERABLE status.
This footnote was added to allow the channel to be reset for l
the purpose of testing in order to restore Control Rod Block Instrumentation OPERABILI1T, af ter the Action requirements have been completed.
(7) 3.3.7.6, Action b., page 3/4 3-64 s
- b. In OPERATIONAL CONDITION 3 or 4 with one or more of the above required source range monitor channels inoperable, verify all insertable control rods to be inserted in the core and lock the reactor mode switch in the Shutdown position # within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
- The reactor mode switch may be placed in the Startup/ Hot l
Standby or Refuel position to perform testing associated with restoring the Source Range Monitors to OPERABLE status provided that all insertable control rods remain fully inserted.
This footnote was added to allow the reactor mode switch to be moved from the Shutdown position for the purpose of tecting in order to restore the Source Range Monitors OPERABILITY. All l
insertable control rods will be verified to remain fully l
inserted while the channel is reset.
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'NRC-88-0057 Page 6 Action a. of Specification 3.3.1 and Action b. of Specification 3.3.2 include statements that the provisions of Specification 3.0.4 are not applicable. In reference 2, Detroit Edison requested that these statements be deleted to be consistent with a proposed change to Specification 3.0.4 This proposal does not affect the reference 2 proposal, thus the exceptions to Specification 3.0.4 should be deleted upon approval of the proposed change to Specification 3.0.4 SIGNIFICAFF 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 Edison must establish that operation in accordance with the proposed amendment would not:
- 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or differe"t kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a margin of safety.
- 1) The proposed change to allow resetting a channel and/or trip system to permit testing associated with restoring the OPERABILITY of Rod Block Monitor, Reactor Protection System. Isolation Actuation, and Control Rod Block instrumentation-does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change involves tesetting the channel and/or trip system af ter the Action requirements have been completed.
This is necessary in order to permit required testing. The probability and consequences of an accident has not been increased as the channel will only be reset for necessary testing when the equipment is otherwise considered OPERABLE. In addition, the change does not result in any modifications to the plant or system operation or testing and no safety-related equipment is altered.
The proposed change to allow placing the reactor mode switch to a position other than Shutdown to permit testing necessary to restore the OPERABILITY of Reactor Protection System Instrumentation and Source Range Monitors, provided that all insertable control rods remain fully inserted, does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change allows the reactor mode switch to be placed in the Run, Startup/ Hot Staadby, or Refuel position to test Reactor Protection System Instrumentation and allows the reactor mode switch to be placed in the Startup/ Hot Standby or Refuel position to test Source Range Monitors, af ter the Action requirements have been completed. This
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Enclosure to NRC-88-0057 Page 7-is necessary in order to permit required testing. The probability and consequences of an accident has not been increased as all insertabic control rods are verified to remain fully inserted. In addition -change does not result in any modifications to the plant or system operation or testing and no safety-related equipment is altered.
The proposed change to the Reactor Protection System Instrumentation Action statement footnotes in OPERATIONAL CONDITIONS 3, 4, or 5, to allow verification that all control rods required to be inserted are fully inserted and remain fully inserted in lieu of placing an inoperable channel and/or trip system in the tripped condition does not involve a significant increase in the probability or consequences of an accidsnt previously evaluated. ~ The proposed change provides an option, when in OPERATIONAL CONDITIONS 3, 4. or 5, of verifying that the required control rods are. fully inserted and remain fully inserted in lieu of placing the channti and/or trip system in the tripped condition. The probability and consequences of an accident has not been increased. Control rods which are removed from the core per Specifications 3.9.10.1 or 3.9.10.2 are not required to be inserted.
Specifications 3.9.10.1 and 3.9.10.2 ensure that SHUTr0WN MARGIN requirements are met.
As currently written, with a channel and/or trip system in the tripped condition, a half-scram exists. Also, a control rod could be withdrawn in the Refuel position for testing. The condition where all control rods required to be inserted are verified to be fully inserted is actually more conservative. 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 the Technical Specifications for Rod Block Monitor, Reactor Protection System, Isolation Actuation, and Control Rod Block instrumentation to allow resetting the channel and/or trip system to permit testing associated with restoring OPERABILITY does not create the possibility of a new or different kind of accident from any accident previously evaluated. As stated in 1) above, the change does not result in any modifications to the plant or system operations or testing and no safety-related equipment is altered. The requested change does not create any new accident mode.
The proposed change to allow placing the reactor mode switch to a position other than Shutdown to permit testing necessary to restore the OPERABILITY of Reactor Protection System Instrumentation and Source Range Monitors, provided that all insertable control rods remain fully inserted, does not create the
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Enclosure to NRC-88-0057 Page 8 possibility of a new or different kind of accident from any l
accident previously evaluated. As stated in 1) above the change does not result in any modifications to the plant or system operation or testing and no safety-related equipment is altered.
The requested change does not create any new accident mode.
The proposed change to the Technical Specification for the Reactor Protection System Instrumentation Action statement footnotes in OPERATIONAL CONDITIONS 3, 4 or S, to allow verifying all control rods required to be fully inserted are fully inserted and remain fully inserred in lieu of placing an inoperable channel and/or trip system in the tripped condition does not create the possibility of a new or differant kind of accident from any eccident previously evaluated. As in 1) above, the change does not result in 'any modifications to the plant or system operation and no safety-reinted equipment le 11tered. The requested change does not create any new accident u (.,
- 3) The proposed change to the Technical Specifications for Rod Block Monitor, Reactor Prote-tion System, Ianlation Actuation, and Cont of Ro? Ilock i.utr' mentation to a'. lor resetting the channel and/or trip dystem to permit testing associated with restoring OPERABILITY does not involve a significant reduction in a margin of safety. As stated in -1) above, this allowance applies only after the Action re uirements have been completed. The testing is s
undertaken on equipment that is believed to be OPERABLE but has not been tested. The proposed change only gives explicit provision for a required activity.
The proposed change to allow placing the reactor mode switch to a position other than Shutdown to permit testing necessary to restore the OPERABILITY of Reactor Protection System Instrumentation and Source Range Monitors, provided that all insertable control rods remain fully inserted, does not involve a significant reduction in a margin of safety. As stated in 1) above, this allowance applies only after the Action requirements have been completed. The testing is undertaken on equipment that is believed to be OPERABLE but has not been tested. The proposed change only gives explicit provision for a required activity.
The proposed change to the Technical Specification for the Reactor Protection System Instrumentation Action statement footnotes in OPERATIONAL CONDITIONS 3, 4, or 5, to allow verifying all control rods required to be inserted are fully inserted and remain fully inserted in lieu of placing an inoperable channel and/or trip system in the tripped condition, does not involve a significant reduction in a margin of safety. As stated in 1) above, the
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change only applies in OPERATIONAL CONDITIONS 3, 4 or 5.
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- half-scram due to placing the trip system in the tripped condition does not ensure all required control rods are fully inserted.
Thus, the change provides a greater margin of safety.
Based on the above, Detroit Edisor. has determined that the proposed amendment does not involve a significant hazards consideration.
ENVIROMGDrrAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. 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.
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 Ccmmission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.
The changes requested herein permits surveillance testing necessary to restore OPERABILITY of instrumentation. The changes will expedite the completion of testitig procedures and does not involve a significant hazards consideration.
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