NRC-88-0193, Application for Amend to License NPF-43,revising ATWS Recirculation Pump Trip Sys Instrumentation Based on Mod to Reactor Recirculation Pump Trip Logic.Fee Paid

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Application for Amend to License NPF-43,revising ATWS Recirculation Pump Trip Sys Instrumentation Based on Mod to Reactor Recirculation Pump Trip Logic.Fee Paid
ML20207K223
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/21/1988
From: Sylvia B
DETROIT EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154M412 List:
References
CON-NRC-88-0193, CON-NRC-88-193 NUDOCS 8809280281
Download: ML20207K223 (11)
v • d • e


Text

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. D. Ralph Sylvia

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Detrol,t a n ,u - . . ,+ . ,

Ecison ==~~

Septmber 21, 1988 1GC-88-0193 U. S. }bclear Regulatory Ccmission Attn Document Control Desk Washington, D. C. 20555 Refererre Fermi 2 NRC Docket tb. 50-341 NRC License ?b. NPF-43 l

Subject:

Proposed Technical Specification Change (License knendment) - NIWS Recirculation Pump Trip System InstnUCDtAtlon Pursuant to 10CFR50.90, Detroit Edison Company hercby proposes to amerd Operating License ter-43 for the Fermi 2 plant by incorporating the enclosed change into the Plant Technical Specifications. %e proposed change would revise Specification 3/4.3.4, ,'M Recirculation Ptrrp Trip Systen Instrumentation based on a modifiertion to the Reactor Recirculation Pump trip logic. The rodification deleted the Motor Generator (MG) set drive motor breaker trip which utilized a one-out-of-two trip logic. The MG set generator field breaker, which utilizes a two-cutef-tw trip logic for each trip function (Reactor Vessel Water Level-Low and Reactor Vessel Pressure-High) in each trip cysten remins unchanged. W e proposed Technical Specification changes provide appropriate provisions for the two-out-of-two trip logic and will allow the Fermi 2 Technical Specifications to better reflect the as-codified plant design.

Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. %e Fermi 2 Cusite Review I

organization has approved and the !belear Safety Review Group has l

reviewed the proposed Technical Specifications ard concurs with the enclosed deterininations.

Fursuant to 107R170.12(c) enclosed with this amendment request is a check for one hundred fifty dollars ($150.00) . In accordance with 10CFR50.91, Detroit Pdison has provided a copy of this letter to the State of Michigan.

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'I f O 41 PMJ vs C NLI P

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. B. Ralph Sybla Sen.or v.ce heseent Detroit u Edison =_=ms.,.., "-

Septanber 21, 1988 NFC-88-0193 U. S. Ibclear Regulatory Ccrrnission Attn Document Control Desk Washington, D. C. 20555

Reference:

Fermi 2 PGC Docket tb. 50-341 tac License !b. !PP-43

Subject:

Proposed Technical Specification Change (License Amendment) - A%S Recirculation Punp Trip System IDSinEentAtion Pursuant to 10CFR50.90, Detroit FAison Ccrnpany hereby proposes to amend Operating License NPF-43 for the Permi 2 plant by incorporating the enclosed change into the Plant Technical Specifications. The proposed change would revise Specification 3/4.3.4, A%S Recirculation Pump Trip System Instrumentation based on a modification to the Reactor Recirculation Pump trip logic, he rodification deleted the Motor Generator (MG) set drive motor breaker trip which utilized a one-out-of-two trip logic. The MG set generator field breaker, which utilizes a two-cut-of-two trip logic for each trip function (Reactor Vessel Water Level-Im and Reactor Vessel Pressure-High) in each trip systen renains unchanged. The proposed Technical Specification changes provide appropriate provisions for the two-out-of Lw trip logic and will allow the Fermi 2 Technical Specifications to better reflect the as-todified plant design.

Detroit Edison has evaluate the proposai Technical 3recificationc against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. % e Fermi 2 Cnsite Review organization has approved and the !bclear Safety Review Group has reviewed the proposed Technical Specifications and concure with the encloced detenninations.

Pursuant to 10CFR170.12(c) enclosed with this amendment request is a check for one hundred fifty dollars ($150.00) . In accordance with 10TR50.91, Detroit Edison has provided a .f of ' W 1ettet to the State of Michigan, f cci

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. USNRC Septater 21, 1988 ~

l NRC-88-8193 Page 2 i l

l If you have any questions, please contact Mr. Glen D. Chlemccher at (313) 586-4275. l i

l Sincerely,  :

l Enclosures cc Mr. A. B. Davis j Mr. R. C. Knop  :

Mr. T. R. Quay Mr. W. G. Rogers <

Supervisor, Advanced Planning and Review Section, i Michigan Public Service Comission

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. USNRC Septmber 21, 1988 NRC-88-6193 .

Page 3 1 1 I

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l I, B. RALPH SYLVIA; do hereby affirm that the foregoing statements are ,

based on facts and circumstances which are true and accurate to the best of my knowledge and belief. l

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f v i B. RAIMI SYLT/IA i Senior Vice President i I

4 On this 2/' t day of (4<*8/c d t u ,1988, refore 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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Notary Public ,

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Encloruro to

. NRC-88-0193 Page 1 BACKGROUND / DISCUSSION Technical Specification 3 3 4, ATWS Recirculation Pump Trip System Instrumentation, ACTION b. states that with the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels per Trip System Requirement for one trip function in one trip syt, tem, restore the inoperable channel to OPERABLE status within 14 days or be in at least STARTUP within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. At the time of licensing, the Fermi 2 Reactor Recirculation Pumps were provided with two separate means of tripping, namely field breaker trips and drive motor breaker trips. The drive motor breaker trips were subsequently .

removed in 1985 in order to resolve concerns regarding adequate electrical separation criteria. This concern was identified in Region ,

III Inspection Item 85-009-01.

The Motor Generator (MG) set generator field breakers for both Reactor Recirculation Pumps (A and B) will trip in a two-out-of-two logic on either Reactor Pressure Vessel (RPV) Pressure-High or on RPV Water Level Low-Level 2 after an 8 to 10 second time delay (see attached figure). This trip Pgic remains unchanged. The MG set drive motor breaker trips were ve inged in a one-out-of-two logic such that the Reactor Recirculation Pump MG Set drive motor breaker was tripped by any one channel of eitner 1) RPV Water Level Low-Level 2 or 2) RPV Pressure-High. Reactor Recirculation Pump "A" was tripped by the Division 1 trip system and Pump "B" was tripped by the Division 2 trip system.

Due to the configuration of the drive motor breaker trip logic (only one channel required for a trip), ACTION b. did not require placing the inoperable channel in the tripped condition. Wnen the drive motor trips were removed, Detroit Edison determined that the existing a

Technical Specification remained applicable. The exieting Technical l Specifications, however, require a plant shutdown per Specification l 3 0 3 in the event an additional channel becomes inoperable during the 14 day allowable outage time. Further, no provision exists for surveillance testing during this period. Subsequent review has shown that ACTION statements which specify placing an inoperable channel in the tripped condition are also appropriate for the as-modified design. These ACTIONS can overcome these drawbacks of th6 existing Technical Specifications.  ;

During the Fermi 2 Technical Specification Improvement Program review of this specification, a comparison was performed between the current specification and those of the GE Standard Technical Specification (BWR/4) and Technical Specifications from other BWR's with similar l

design. The review concluded that all other Ttchnical Specifications reviewed are worded identically and are appropriate as a replacement for ACTION b. in Fermi-2 Technical Specification 3/4 3 4 given that the drive motor breaker trips have been removed.

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  • Enclo:uro to ,

NRC-88-0193 l Page 2 l 4

i I The current footnote in Table 3 3 4-1, ATWS Recircula& ion Pump Trip System Instrumentation, addresses a channel taken out of service for  !

< surveillance testing. This footnote is proposed to be revised in order to be consistent with the proposed ACTIONS.

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Detroit Edison has recognized the need to revise the ACTION statements and the surveillance footnote to better reflect the as-modified plant  ;

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design. The proposed Technical Specifications changes are attsched. l l

1 TECHNICAL SPECIFICATION CHANOES '

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t i The Technical Specification 3/4 3 4, ATWS Recirculation rump Trip l 1 System Instrumentation, proposed change would specifically change the j following itemst Delete ACTION b. (current) l l

b. With the number of OPERABLE channels one less than required l by the Minimum CPERABLE Channels per trip system requirement

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4 for one trip function in one trip system, restore the  :

i inoperable channel to OPERABLE status within 14 days or be in at least STARTUP within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. i Replace with ACTION b. through e. (proposed) l J

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b. With the number of OPERABLE channels one less than required i

! by the Minimum OPSBABTE Channels per Trip System requirement 4

for one or both M ip syt eaa, place the inoperable channel (s) }

f in the tripped condition within t hnur. }

l o. With the number of OPFP,)BLE channels two or more less than l 1 required by the Minimum CPERABLE Channels per Trip Systen requirement for one trip syt tes andt l'

1. If the inopwable channels consist of one reactor vessel i

water level channel and one reactor vessel pressure  !

j channel, place both inoperable channels in the tripped l j

condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or, if this action will  !

initiate a pump trip, declare the trip system  !

inoperable. l l

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2. If the inoperable channels include two reactor vessel water level channels or two reactor vessel pressure  ;

i channels, declare the trip systen inoperable.  ;

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d. With one trip systes inoperable, restore the inoperable trip j i

systen to CPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least (

STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. t t

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Enclosura to NRC-88-0193 Page 3

e. With both trip systems inoperable, restore at least ons trip system to OPERABLE status within I hour or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The proposed ACTION b. would require that with one inoperable channel in one or both trip systems, the inoperable channel (s) be placed in the tripped condition within I hour. This ACTION would not result in a trip of the praps, but upon receipt of the second trip signal for the same trip function (level or pressure) in the same trip system, a '

trip would occur as intended.

The proposed ACTION o. would result if more than one channel was inoperable in the same trip systra. The ACTION is subdivided depending on which channels are inoperable. 1) If the inoperable channels consist of one RPV Water Level Low-Level 2 channel and one RPV Pressure-High channel, place both channels 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 />. This ACTION will not result in a pump trip if the other channels are OPERABLE. However, if placing these channels in the tripped condition would result in a trip of the pumps (the other channel for the same trip function in the same trip system being tripped), declare the trip system inoperable. 2) If the inoperable channels include two channels for the same trip function, i.e., two RPV Water Level Low-Level 2 channels or two RPV Pressure-High channels, declare the trip system inoperable. If the channels were both placed in the tripped condition, a trip would occur.

The proposed ACTION d., for one inoperable trip systen, would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable trip systen to OPEPADLE status or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The other trip systen would be OPERABLE and capable of performing the trip actuation.

The proposed ACTION e., for both trip systens inoperable, requires i that at least one trip system be restored to OPERABLE status within 1 I hour or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This is consistent with GE-Standard Technical Specifications and those of other sinilar BWR's.

The footnote in Table 3 3 4-1, ATVS Recirculation Pump Trip Systen Instrumentation, currently reads as follows:

  • One channel in one trip system may be placed in an inoperable status for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillance without placing the trip system in the tripped condition provided that all other channels are OPERABLE.

The proposed change to this footnote would read as follows: r l

Enc 1c are to NRC-88-0193 Page 4

  • One channel may be placed in an inoperable status for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillance provided the other channel of the same trip function is OPERABLE.

Detroit Edison is proposing to change this footnote to be consistent with other footnotes within the Instrumentation Section of Technical Specifications. The change ensures another channel is monitoring the trip function being tested. The thannels for the other trip function are now covered by appropriate ACTION requirements and thus need no longer be included in the footnote. This proposed footnote is stallar to tho footnote in all other Technical Specifications researched for the ACTION statements as previously discussed except that the phrase "of the same trip function" has been added to clarify the intent.

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 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 different kind of accident from any accident previously evaluated, or, 3) involve a significant reduction in a margin of safety.

1) The proposed change to delete the present ACTION b. which allows one channel of ATWS Recirculation Pump Trip System Instrunentation in one trip system to renain inoperable for 14 days with no requirement that it be placed in the trip condition and to replace this ACTION with four action statements with an increasing progression of ACYIONS according to severity, does not involve a significant increase in the probability or consequences of an accident, previously evaluated. This proposed change is appropriate due to the deletion of the Reactor Eccirculation Pump 1 drive motor breaker trips which utilized a one-out-of-one trip i logic for each drive sotor breaker. The remaining trip of the Reactor Recirculation Pump field breakers remains unchanged. This trip utilizes a two-out-of-two trip logic of either RPV Water Level Low-Level 2 or RPV Pressure-High. The proposed ACTION b.

which addresses one inoperable channel in one or both trip systems, requires placinE the inoperable channel (s) in the tripped 4

condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This ACTION would not result in a trip i

of the punp. but upon receipt of the second trip signal for the same trip function (level or pressure) in the same trip system, a trip would result as intended. The probability and consequences of an accident has not been increased since this proposed ACTION is consistent with other instrument ACTIONS which place a channel in the tripped condition if this can be accomplished without causing the trip function to occur. In addition, the change does

Encic:uro to NRC-88-0193 Page 5 not result in any modifications to the plant or systen operation and no safety-rolated equipment is altered.

The proposed char.ge to add ACTION c., which addresses the condition of two or more channels less than required by the Minimum OPERABLE Channels per Trip Systen requirement, does not involve a significant increase in the probability or consequences of an accident previously evaluated. The ACTION is subdivided depending on which channels are inoperable. 1) If the inoperabia channels consist of one RPV Water Level Low-Level 2 channel and one RPV Pressure-High channel, both channels are placed 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 />. This ACTION will not result in a pump trip if the other channels are OPERABLE. However, if placing these channels in the tripped condition would result in a trip of the pump (the other channel for the same trip function in the same trip system being tripped), the trip system is declared inoperable. 2) If the inoperable channels include two channels for the same trip function, i.e., two RPV Water Level Low-Level 2 channels or two RPV Pressure-High channels, the trip system is declared inoperable. If the channels were both placed in the tripped condition, a trip would occur. The probability and consequences of an accident has not been increased as the ACTIONS taken are conservative with respect to the trip function and the trip will autonatically occur when actuated by the remaining OPERABLE channels. In addition, the change does not result in any modifications to the plant or system operation and no safety-related equipnent is altered.

The proposed ACTION d., for one inoperable trip systen, which would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable trip systen to l OPERABLE status or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, t does not involve a significant increase in the probability or consequences of an accident previously evaluated. The other trip systen would be OPERABLE and capable of performing the trip actuation. The probability and consequences of an accident has not been significantly increased as the proposed change requires the inoperable subsystem to be returned to OPERABLE ststus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In addition, tbc change does not result in any nodifications to the plant or systen operation and no safety-related equipaent is altered, i The proposed ACTION e., for both trip systems inoperable, which requires that at least one trip systes be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, does not involve a significant increase in the probability

' or consequences of an accident previously evaluated. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limit is appropriately conservative to return at least one trip systen to OPERABLE status. The probability and consequences of an accident has not been significantly increased as the ACTION requires the plent to be in at least STARTUP within the next 6  ;

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Encir:uro to NRC-88-0193 Page 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In addition, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered.

The proposed change to feotnote, ', in Table 3 3 4-1, ATWS Recirculation Pump Trip System Instrumentation, to allow one channel to be placed in an inoperable status for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillance provided the other channel of the same trip function is OPERABLE, does not involve a significant increase in the probability or consequences of an accident previously evaluated. The footnote, as proposed, ensures that an OPERABLE channel is monitoring a trip function during surveillance testing.

The channels for the other trip function are now covered by the ACTION requirements and thus no longer need to be included in the footnote. The probability and consequences of an accident has not been increased as the preposed change is consistent with other instrumentation Specifications for allowable surveillance time.

In addition, the change does not result in any modifications to the plant or systen operation and no safety-related equipment is altered.

2) The proposed change to replace the existing ACTION statement with the proposed four ACTION statements does not create the possibility of a new or different kind of accident from any accident previously evaluated. As in 1) above, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered. The requested change does not create any new accident mode.

The proposed change to footnote, ', in Table 3 3 4-1, ATWS Recirculation Pump Trip Syster Instrumentation, to allow one channel to be placed in an inoperable status for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillai.ce provided the other channel of the same trip function is OPERABLE, does not create the possibility of a new or

' different kind of accident from any accident previously l evaluated. As stated in 1) above, the change does not result in l

any modifications to the plant or system operation and no safety-related equipment is altered. The requested change does l not create any new accident mode.

3) The proposed change to replace the existing ACTION statement with the proposed four ACTION statements does not involve a significant reduction in a margin of safety. As stated in 1) above, the deletion of ACTION b., which does not address placing an i inoperable channel in the tripped condition, and replacing it with four ACTIONS (b. through e.) to allow placing inoperable channels l

l in the tripped condition where appropriate, allows the ACTIONS to more appropriately address the as-modified plant design.

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  • Enclesure to NRC-88-0193 Page 7 The propssed change to footnote, ', in Table 3 3 4 1, ATWS Recirculation Purp Trip bystem Instrumentation, to allow one channel to be placed in an inoperable status for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillance provided the other channel of the same trip function is OPERABLE, does not involve a rignificant reduction in a margin of safety. As stated in 1) above, the allowance for l surveillance is consistent with those in other instrumentation l Specifications and is appropriate for this Specification since the I

channels associated with the other trip function are now covared by ACTION requirements.

Based on the above reasoning, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.

ENVIRONMENTAL IMPA g Detroit Edison has reviewed the proposed Tecnnical Specification changes agati e the criteria of 10CFR$1.22 for environmental l

considerations. As shown above, the proposed change does not involve a significant hazards consideration, nor significe.ntly change the types or significantly increase the amounts of effluents that any be releasec'. off site, nor significantly increase individual or cwulative occupatic .1 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.

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CONCLUSION l

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 comp 11ence with the Consission's regulations and proposed amendments will not be inimical to the connon defense and security or to the health and safety of the pubite.

The change requested herein requires that inoperable channels be placed in the tripped condition or that the trip systen be declared inoperable. This change will impose conservative time limits for inoperable trip systems, and if not restored to OPERABLE status within those time 11 nits, will require that the reactor be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This change nakes the feral-2 Technical Specifications consistent with GE Standard Technical Specifications (BWR/4) and with Technical Specifications for sinflar BWR plants and does not involve a significant hazards consideration.

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