NRC-89-0146, Supplemental Application for Amend to License NPF-43, Revising 880804 Application to Address Recent Concerns Re thermal-hydraulic Stability & Provide Addl Info to Proposed Tech Specs Concerning Single Recirculation Loop Operation

Supplemental Application for Amend to License NPF-43, Revising 880804 Application to Address Recent Concerns Re thermal-hydraulic Stability & Provide Addl Info to Proposed Tech Specs Concerning Single Recirculation Loop Operation

ML20246C929
Person / Time
Site:	Fermi
Issue date:	08/18/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20246C934	List: ML20246C946 NRC-89-0146, Supplemental Application for Amend to License NPF-43, Revising 880804 Application to Address Recent Concerns Re thermal-hydraulic Stability & Provide Addl Info to Proposed Tech Specs Concerning Single Recirculation Loop Operation
References
CON-NRC-89-0146, CON-NRC-89-146, REF-GTECI-B-19, REF-GTECI-TH, TASK-B-19, TASK-OR IEB-88-007, IEB-88-7, TAC-69074, NUDOCS 8908250183
Download: ML20246C929 (11)

Text

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f-A ...a Ralph Sylvia

$enor WCe Pre ident 6

TOII r,4ao wonn o. s.pn..,

Corrected copy - 1ast page g An we.pon u,cn.o n ase inadvertently left off.

I %mr 8 5 (313) he the August 18, 1989 IUC-89-0146 U. S. Ibc1sar Regulatory Consnission Attn Document Control Desk Washington, D. C. 20555

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References:

1) Fermi 2

-C- IUC Docket !b. 50-341

!UC License Ib. lW-43

2) Detroit Bilson Letter to !UC, IUC-87-0132,

" Proposed Technical Specification Changes to Include Single Recirculation Loop Operation

- (Sw)", dated August 4,1988

3) Detroit Bilson Lettet to 10C,10C-86-0280,

" Technical Specification Changes for Single Q loop Operation (TAC lb. 69074)", dated

!bverber 16, 1988

4) Detroit BSAson Letter to IUC, !UC-89-0052,

" Proposed Operating License / Technical Specifications Cnange (License Amerdnent) -

Cycle 2 Reloa3 Submittal", dated Apr113,1989

5) Detroit B31 son Letter to IUC, IUC-89-0115,

" Proposed Technical Specification Cnanges to Allow Operation with an Exterded Operating Domain", dated May 31, 1989

6) N R Owners' Group Aetter, N RO3-8951, from S. F2oyd (WROG) to A,. 'IhaSana (IUC) dated June 20,1989 witn report entitled " Fuel Thernal Margin During Core Toermal Hjdlautic Osc1Alations in a Bolling Watet Rea:: tor"

Subject:

Supplenent to Tecnnical Spec 2f rations Change (License Anendment) to Inc4ude Single Recirculation Loop Coeration (TAC No. 69074)

$0 8250183 890818 p ADOCK 05000341 t'DR

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. (ENIC August 18, 1989 NIC-89-0146 Page 2 In Reference 2, Detroit Eison submitted Technical Specification t changes to support Single Ioop Operation (Sto) at Fermi 2. In Reference 3, Detroit Eison notified the IGC that the Reference 2 proposal will require modification to reflect the recent industry events involving IMR thermid-hydra 211c inst &ilities. This submittal supplemmts the Reference 2 proposat and makes the needed modifications with respect to thermal-bydrallic stability requirements.

Detroit Eison has evaluated the proposed %chnical Specifications

. against the criteria of 10CFR50.92 and determanea that no significant hazards consideration is involved. The Fermi 2 Ossite Review Organization has approved,and the Maclear Safety Review Group has reviewed-the proposed Technical Specifications and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Eison has provided a copy of this letter to the State of Michigan.

If you have any questions, please cantact Mr. Glen Ohlemacher at (313) 586-4275.

Sincerely, O

Enclosure cca A. B. Davis R. C. Knop W. G. Rogers ,

J. F. Stang Supervisor, Advanced Planning and Review Section, Michigan Public Service Commission

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-:. e . . i n-i UEnc August 18, 1989 NIC-894146 l Page 3 I I i

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I, B. RhLPH 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.

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3. m,n Swg ba i Senior Vice President l f4 On this / day of A .1989, before ne ,

personally appeared B. Ralph Sylvim/being first duly sworn and says l that he executa3 the foregoing as his free act and dead. .l I

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USNBC August 18, 1989

• - NRC-89-0146 Page 4 t

bocs 'w/o enc.

C. Borr (WPSC, Inc.) w/ enc.

S. G. Catol dG. Cranston P. Fessler D. R. Gipson L. S. M man w/ enc.

D. Bahn (Michigan Dept./Public Health) w/ enc.

-R. Matthews R. M2eort /G. Preston w/ enc.

C. A. Naegell W. S. Orser J. PlondW. Tucker w/ enc.

AcC. Settles R. B. Stafford F. J. Svetkovich B. R. Sylvia R. Thorson G. M. Trabey Information Management - 140 NOC w/ enc.

NRR Chron File w/ enc.

ISBG Coordinator (316 NOC)-

NSRG Secretary RACTS Coordinator TSAR Coordinator Author - G. Smith w/ enc.

Licensing Engineer w/ enc.

Routing Copy

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' Detroit Blison,r an Reference 2, proposed Technacal Specification changes to allow extended operation of Feral 2 at' reduced power with a single recirculation loop in operation. The proposed provisions for single loop 4peration. (SED) are based upon a GE melaar hergy analysis, which was provided in the Reference 2 s@mattat.

Generic technical issues regarding S[4 were resolved by the BBC staff in early 1986 under_ Generic Issue B-19. Che of the concerns resolved at that time was that of the potential for thermal-tydraulac

. Instability during Sto. It was determined that Sto fos extended

. periods was' generically acceptable provided .that 2schnical -

%ecificat; ions iglementing the reconnendations of GE Service Informatitic letter 330 (SIL-380). for detection and suppression of flux (oscillations in operating regions of potential instability were in place. The SIL-380 recommendations were included in the Technical

@ecifications issued with the Fermi 2 Operating License.

Recent industry events involving thermal-tydraulic instability have Andacated that actions beyond those reconnended by SIL-380 are necessary. Interim actions were developed by the WR Odners' Group (MROG) and reviewed by the 300 staff. This has resulted in the issuance of SUC Bulletins 88-07 and 8H7 hpplement 1. Detroit 351 son is participating in the WRCG efforts and has implemented the interim corrective actions of Bulletins 8H7 and 8H7 hpplement 1.

Further, Detroit 85ison informed the IOC, in Reference 3, that the Reference 2 SED proposal would likely require modifications due to these developments. -

The WROG sponsored GE thclear Ehergy analysis " Fuel Thermal Margans During Core Thermal I&draulic Oscillations in a Boiling Water Reactor" was submitted to the IGC by Reference 6. The Technicat gecification provisions related to core thermal-tydraulic stability included in thu proposal are consistent with the reconnendations in the WHOG report. The current thermal-tydraulic stability reAated requirements are based upon the concept of dete:: ting and suppressing instability henomena while operating in the high power / low flow region of related p/ flow map. The proposed requirements are Instead based upon the power probabit2ng operation in the region where instability is most likely to occur.

This submittal prov2 des the modif2 cations needed to address recent concerns regardirg thermal-tydrautre stability as well as additionat information concerning the proposed SLO TW:hnical Specif acations. Tne submittal also includes modit2 cations to reflect the 5tchnical Specification changes proposed for Cycle 2 operation (Reference 4) and

y S closure to 7

NC-894146 Page 2 for operation with an' expanded operating domain (Reference.5) . The attached proposed hchnical Specifications are a complete revision oft

- the pages provided by Reference 2.

maarmariam Each Technical Specification affected by S[O is discussed individually beloW.

2.1.2 TIBIsmL PORR, High Pressure and High Flow Safety Limit The,,MINIMM CRIT 2 CAL'POtER RTIO (MCPR) Safety Limit value is increased by 0.01 during 50 to account for increased core flow measuremertt and traversing in-core probe (TIP) measurement uncertainties. ne numerical values provided now reflect the Cycle 2 analysis for Fermi 2.

2.2.1 Emactor Protection System Instrumentation Setpoints Se Average Power Range Monitor (APM) flow biased Sinulated hermal Power - Upecale Trip Setpoints at:5 Allowabla Values have been modified to account for. SLO. he numerical values have been ad3usted to -

account for the proposso Technical Specif acations for operation in an extended operating domain (Reference 5) . The adjustment in the setpoint is necessary since, for the same indicated recirculation loop ilow, the actual core flow is less during SLO.

This core flow adjustment, which is commonly termed 5, is subtractal from the indicated core flow, W. The proposed setpoints are based ajs a af of M. The SLO flow-biased setpoints are derived by substituting the quantity W - dW for W in the two-loop setpoint equations. Se& value of M is then substituted to derive the new setpoint equations for SLO.

Following entry into SIC, the setpoints for this instrumentation (and other affected instrumentation) aust be promptly adjusted. AdJ ustment of the actual instrumentation setpoint is a couplex evalution requiring a time period beyond that which is reasonable for eplying new limits for Sto. Bowever, the new setpoints can be functionally applied by ed3 usting APM gains in a short period of time. Se proposal 1:aerefore requires the application of the new setpoints within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> but allows the adjustment of the APM gains to accouplish this end for a period up to 721mrs. (

The provisions proposed are similar to the current allowanoes for using APM gain adjustments for short-term modif acations of l

flow-blased scram trip setpoint during power ascension contained in

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! - helosure to NRC-89-4146 Page 3 Specification 3.2.2. Similar provisions for posting a notice of adjustment and limiting the adjusted APM reading are proposed. The t time period for use of APM gain adjustments is limited, to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to ensure the APM flow biase$ setpoints are adjusted and the gain adjustment removed in a reasonable time period..

Se High Flow Clamped setpoint is indicated to be not applicable during SLO. During SLO, power levels where the High Flow Clanped feature is needed emnot be attained. B erefore, it is not necessary to specify a setpoint for. this feature during 500.

. V4,2.1 Average Planar Lineer Best Canaration Rate (APLIER)

' A multiplier of 0.90 is provided to reduce the APLIGR limit during SLO. Ris reduction accounts for the marginal difference in core uncovered time and reflood tine associatal with a Loss of Coolant Accident (IOCA) during SLO.

The Specification now includes the modifications necessary for Cycle 2 operation.

V4.2.2 APM Setpoints The changes to this Specification parallel those of Specif 2 cation 2.2.1 discussed above. New SEC setpoints (based on ad W value of 8%)

are prov2ded, and numerical values have been updated in this submittal to reflect the proposed extended operating domain (Reference 5) . Se 4.6% decrease in setpoint is derived from 0.58 x 8%. S e existing provisions for APM gain adjustment have been modifico to reflect the need to use gain adjustments for an interim period upon entering SLO in order to apply the new setpoints in a timely manner. The magnitude of the require $ APM gain adjustment (5.3%) is derived from 0.66 x 8% . his is necessary since the slope of the Rod B1cnk Mnitor Setpoints were not proposed to be changed by Refererce 5.

3.3.6 Control mod Block Instrumentation te changes to this Specification also parallel those of Specification 2.2.1 discussed above. Se provisions for entering SLO are the same.

The APM flow-biased instrumentation ntmerical values have been updated to reflect tne proposed extended operating domain.

V4.4.1.1 Bacirculation Icops Reference 2 relocated the requirements related to thW-hydra 211c stability in a new Specification which was designated 3/4.3.10. In this proposal, the thermal-hydraulic stability related requirements

Ihclosure to

, . 351C-89-0146 l Page 4 i

are located in a new specification 3/4.4.10. As discussed below, the I stability requirements in this proposal have been substantially modified as well as relocated. In Reference 2, the requirements were basically relocated without change.

As before, the ACTION requirements for entcring SI4 are specified in the new ACTION a. Since the new stability requirements are independent of the nunber of recirculation loops, the stability related ACTIONS which were proposed in Beference 2 have been eliminated. he ACTIONS listed are those which are nee 3ed to establish conditions,in accordance with the initial conditions of the SLO-analysis or Cs pre'/ent temperature stratification concerns in the Reactor Pressure Vessel.

hose itetti which are adjusted arx3 are not otherwise subject to normal periodic s:2rveillance are included in a new surveillance requirennnt, 4.4.1.1.3. A surveillance (4.4.1.1.4) to assure thermal stratification has not occurred prior to power or flow increases is also included.

We recent experience concerning thermal-hydraulic stability has indicated that operation in TERATIOtEL COtOITION 1 with no recirculation loops in operation (natural circulation) should be immediately terminated by a reactor scram. his is now specified in the proposed new ACTION b. The current ACTION has been found to be acceptable for OPERATIONAL COtOITION 2 and has been retained in the proposed ACTION c.

Special Test Exception 3.10.4 is currently indicated by the

• footnote as being Applicable to TERATIONAL 00tOITION 1 and 2. Se Special Test Exception itself limits the application of the exception to during PkfYSICS TESTS in TERATIONAL COtOITION 2 except during the Startup hst Program. Since the Startup hst Program has been coupleted at Fermi 2, the Special hat Exception 3.10.4 can no longer be applied to CPERATIO!aL CO!OITION 1. %erefore, the

• footnote has been removed from TERATIOtaL COtOITION 1 in the Applicability of the now proposed Specification.

3/4.4.1.2 Jet Pugs he new provision, proposed in Reference 2, to begin get punp monitoring within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of exceeding 25% power is retained in this submittai. In addition to the adjustments made in Reference 2 to reflect SLO, this submittal clarifies that the diffuser-to-lower pienum differential pressure comparisons are meaningful only for the 3et puups in the operating loop. Se non-operating 3et punps receive

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Ehclosure to NIC-89-0146 Page 5 i

a small amount of reverse flow which is not sufficient to make a f comparison meaningful.

The provisions suspending jet puup monitoring until coupletion of the startup test progran has been eliminated. Since the startup test program has been cocpleted, the exception is no longer needed. .

.V4.4.1.3 macirculation Pumps The options proposed in Reference 2 to either restore the matched punp speeds or enter the SLO mode of operation are retained. S e change in Applicability for-Special Test Exception 3.10.4 discussed above for Specification 3/4.4.1.1 is also included in this Specification.

U V4.4.1.4 Idle nacirculation Loop Start @

This submittal now includes an a$ditional restriction for idle loop startup which is based upon recent experience concerning i thermal-hydraulic stabhity. This Specification was not proposed to be modified by Reference 2.

In additica to the concerns for thermal stresses due to thermal stratification currently reflected in tnis Specification, the potential exists for thermal hydraulic instability to occur if 'iECINAL POER is not restricted to below the 80% rod line (shown in proposed g Figure 3.4.1.4-1) during an idle loop startup. Accordingly, the Limiting Condition for Operation (ICO), ACTION, and Surveillance  ;

requirements have been modified to prohibit idle loop startup in the ,

region of concern.

3/4.4.10 (new) Core thermal-%draulic Stability This proposed Specification provides new requirements in regard to core thermal-hydraulic stability wnich are not related directly to the Aoss of recirculation flow or startup of an idle recirculation loop.

This Specification replaces proposed Specification 3/4.3.10 of Reference 2. The ICO prohibits operation in the region of low core flow ard high core power in which operation has been determined to carry susceptibility to therm &L-hydraulic instability. The ACTION requirements provide for an immediate scram (by placing the reactor mode switch in the SIUIDOiN position) when operation is discovered to be contrary to the ICO and the risk of instability is significant (Region A of proposed Figure 3.4.10-1) . In other situations (Region l

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E Rclosure to' 35C-89-4146 Page 6<

B), issuadiate corrective action 'to exit the region of concern 1s I specified.

In a$dition, it while taking the JCTIOtt required for entering Region B, instability is found-to occur as shown by APM or LPM ..

instrumentation oscillations, then an lausediate reactor scram is required.. Se Reference 6 report has determined that margin to the

' Safety Limit ICPR exists with up to 104 peak-to-peak oscillations on the APM instrumentation. Thirty percent of scale' (30 w/cm . at Fermi 2)~ oscillatics on LPM instrumentation was determinal by the Reference 6' report to be approximately equivalent to 104 peak-to-peak

' APM oscillation taring regional oscillations. These values are specitied to provide guidance for determining the presence of instabilit;y while exiting Region 3..

The current thermal-tydraalic stability. related requirements are based upon the concept of detecting and supp essing instability related phenomena while operating in the high power / low flow region of the power / flow map. Se proposed requirements are instead breed upon prohibiting operation in the region in which instability is most likely to occur. Derefore, provisions to detect and then suppress instability are no longer proposed to be included in the Technical Specifications. Plant procedures and training, however, stress the importance of maintaining the reactor h a stable condition in all areas of the 11 censed operating domain end prescribe the appropriate corrective actions to take if core oscillations are detected.

Se proposed Surveillance Beguirenants provide for monitoring that the prohibited regions of operation have not been entered.

3/4.10.4 IDecial Tinst muoeption - Recirculation Icops his Specification has been modified to reflect that the provisions which allowed application of the exception to TERATIOt&L 00tOITION 1 is no longer available. This is currently allowed during the Startup Test Program; however, the Startup Test Program has been coupleted.

Therefore, it is proposed to simplify this Specif 2 cation by eliminating reference.to the expired provisions.

Bases This proposai contains Bases which reflect the proposed Technical Specification changes for SLO. S e Bases enanges of the Reference 4 and 5 proposals are included where the sane Bases sections are inpacted.

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Belosure to NIC-85K)146 Page 7 I

EEERIFICRMF HRE&IES GEIIEElbf1CBI Except as addressed below, the Significat Hazards Consideration analysis contained in Reference 2 remains applicable to the proposal as modified by this submittal. 2e no3ified themai-bydraulic stability relata3 concerns and the administrative change to Special Test Exception 3/4.10.4 are addressed below.

The new provisions related to thermal-hydraulic stability are based upon the concept of preventing instabilities by prohibiting operations

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which have been found'to have the potential for instability. R ese operativas includes routine operation with a ccabination of low flow and high power, natural circulation operation, and startup of an idle recirculate'on loop at high power. Also, appropriate ACTION statements to terminate the undesired operation are specified. For circumstances with the greatest potential for instability, an inmediate r9 actor scram is required.

The proposed stability related Technical Specif 2 cation provisions do not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. S e changes act to prohibit operations which have been fourx3 to carry a signif 2 cant potential for the formation of core thermal-hydraulic instabilities. As such, operation in cocpliance with the proposed provisions does not affect any initiating mechanism for previously evaluated accidents or the response of the plant to a previously evaluated accident. Se ACTION requirements are those which effectively terminate the potential for thermal-bydraulic instd>ility. Se ACTIONS taken lead to placing the plant in a safer condition and are not themselves associate $ with an initiating factor for a previously evaluated acc2 dent. Berefore, the change does not represent a signif 2 cant increase in the probability or consequences of any previously evaluated accident.

2) Create the possibility of a new or different kind of accident .

from any accident previously evaluated. As discussed in 1) above, the change acts to restrict operations previously  ;

j allower3. Se change also provides remedial ACTIONS which act to place the plant in a safer con 31 tion. Se AC'3 IONS called for are l within the analyzed domain of plant operations. As such, the l l

change does not create any new accident mode or involve any modification in the plant design. Berefore, the change does not create the possibility of a new or different kind of accident.

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Biclosure to

. . . BBC-8bO146 Page 8 3)~ Involve a significant reduction in a margin of safety. The changes act to increase the margin of safety by prohibiting- 1 operations with a significant potential for core thermal-ty5raulic instab211ty and providing effective remedial g ACTIONS which promptly terminate the potential for instability.

The change in Applicability for Special Test Exception V4.10.4 ard

. the asacciated changes in the foot:ste to the Specifications which the

' Exception applies (V4.4.1.1 and 3/4.4.1.3) are administrative in nature and are made to reflect the coupletion of the Startup Ter.t

' Program. As such, the changes do nots

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1) Involve a significant increase in the probability or conseguances of an, accident previously evaluata$.

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2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Involve a significant reduction in a margin of safety.

Based on the above, Detroit B5ison has determined that the proposed amendment does not involve a significant hazards consideration.

m nencr Detroit Blison has reviewed the proposed Technical' Specif 2 cation changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do 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 rm51ation exposures. Based on the foregoing, Detroit B5ison concludes that the proposal Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Inpact Statement.

GMIBEImi 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 coupliance with the Ccquaission's regulations and the Proposed amendment will not be inim2 cal to the common defense and security or to the health and safety of tie public.

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