NRC-89-0152, Application for Amend to License NPF-43,removing Inequality Indicators from Numerical Values in Trip Setpoint Column of Instrumentation Tech Specs

Application for Amend to License NPF-43,removing Inequality Indicators from Numerical Values in Trip Setpoint Column of Instrumentation Tech Specs

ML20247Q928
Person / Time
Site:	Fermi
Issue date:	07/24/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247Q934	List: ML20247Q937 NRC-89-0152, Application for Amend to License NPF-43,removing Inequality Indicators from Numerical Values in Trip Setpoint Column of Instrumentation Tech Specs
References
CON-NRC-89-0152, CON-NRC-89-152 NUDOCS 8908070289
Download: ML20247Q928 (7)

Text

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l ', B. Ritph Sybla s

' Senior Vice President

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• 6 do North Omne Highway Q - Piewport. %chegan 48106

.  %.r (313) 58& 4150 July 24, 1989 NIC-89-0152 s U. S. melear Regulatory Comnission Attn: Document Cmtrol Desk Washington, D. C. 20555

Reference:

Fermi 2 NIC Docket No. 50-341 NIC License No. !@F-43

Subject:

Proposed Technical Specification Change frdrwise Amarwhnant) - Instrim'ntation SetDoints Pursuant 'co 10CFR50.90,' Detroit Eison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant 'Ibchnical Specifications. An associata3 change to the Bases is also proposed.

'Ibe proposed change removes the inequality indicators from the numerical values provided in the Trip Setpoint column of the various tables in the Ins *mtation Technical Specifications. 'Ihe change makes these tables consistent with the analytica methodology which established tpe Trip Setpoint values.

Detroit Eison 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 melear Safety Review Group has reviewed the proposed Technical Specifications ard concurs with the enclosed determination. in accordance with 10CPR50.91, Detroit B51 son has provided a. copy of this letter to the State of Michigan.

If you have any questions, please contact Mr,. Glen Ohlemacher at (313)  !

586-4275.

Sincerely, af Enclosure cc: A. B. Davis R. C. Knop W. G. Rogers J. F. Stang Supervisor, Advanced Planning and Review Section, Michigan Public Service Commission s90B070289 890724 1, poti POR ADOCK 050 ]

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c UStGC July 24, 1989 MC-89-0152 Page 2 I, B. FALPII SYLVIA, do hereby affirm that the foregoing statments are based on facts and circumstances which are true and accurate to the best of my knowledge and belief, b 1ln B.' RALPfSYLVg Senior Vice President On this O day of /dd- , 1989, before me personally appeared B. Ralph Sylv)f' , befLnh first duly sworn and says that he executed the foregoing afbis free act and decd.

edo Notary Public

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ROLollE A /RMDTA f 4otary Public. Monroe CountW94 My commician Dalrouan.it.1972 1

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Enclosure'to NBC-89-0152 -

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NM Instrumentation Trip Setpoints are currently, specified'in Fermi 2 Technical. Specifications for a variety of instruments for which a Technical Specification requirement for the CPmABILITY of the t instrument exists. Also, specified is an Allwable Value for the.-

instrumentation setpoint. In general, each Limiting Cordition for Operation (ICO) for instrumentation requires that the instrtment setpoint be set consistent with the Trip Setpoint column of a table listing of required trip functions. Se ACTION requirements require remedial action to be taken 1. the trip setpoint is less conservative than the specified Allowable value. No ACTION is specified for a trip setting found between the Trip Setpoint and the Allwable Value.-

22 Technical Specification Bases-indicate that:

Operation with a trip set less conservative than its Trip Setpoint but within its specified Allowable value is acceptable' on the basis that the difference between each Trip setpoint and the Allwable Values is equal to or less than the drift allowance assumed for each trip in the safety analyses.

%e Trip Setpoint listings currently contsin inequality indicators to show the more conservative side of the Trip Setpoint. %e resulting implication is that the Trip Setpoint value is the least conservative possible setting which the instrument should be adjusted to whenever such adjustments are made. .

In actuality, the analytical methodology which was utilized to establish the Trip Setpoints and Allowable Values derives a Trip Setpoint which is the nominal setting for the trip. A tolerance bard around tl.e Trip Setpoint is also developed by the methodology.

his proposal eliminates the inequality indicators from the Trip Setpoints specified in the %chnical Specifications in order to be consistent with the analytical methodology. We follwing Tables are affected:

Table 2.2.1-1, Reactor Protection Systm Setpoints Tchle 3.3.2-2, Isolation Actuation Instrumentation Setpoints Table 3.3.3-2, Emergency Core Cooling Syste Actuation Instrumentation Setpoints 1

. Table 3.3.4-2, A'NS Recirculation Pump Trip System Instrumentation l Setpoints L

Table 3.3.5-2, Reactor Core Isolation Cooling System Actuation Instrumentation Setpoints Table 3.3.6-2, Control- Rod Block Instrumentation Setpoints

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p Page 2' Table 3.3.9-2, Feedwater/ Main Tr.rbine Trip System Actuation Instrumentation Setpoints Also, the Trip Setpoints specified in Specification 3.2.2, APM Setpoints, are affected.

W MBRTIGi We analytical methodology for determining instrument Trip Setpoints and Allowable values for the Fermi 2 Technical Specifications begins with the determination of an Analytical Limit. Wis is the value for the parameter of concern assumed in the safety analysis for which the j trip function has a role in mitigating the analyzed event. 1 An Allowable value:is then established. Se Allowable Value is based upon essuring that, if the instrument setpoint is fourd at the Allowable Value, the trip will occur with a greater than or equal to 95% probability prior to reaching the Analytic Limit.  !

%e Trip Setpoint is then determined such that, if the instrunent setting is adjusted to within the established tolerance band around the Trip Setpoint, then the actual instrtment setting will not (with at least a 90% probability) drift to the associated Allowable value during the calibration interval. Also, the Trip Setpoint is established such that the instrument will not (with at least a 95%

probability) trip when the process parameter is at its most extreme normal value. mis provides assurance against spurious actuation from normal operation. i The Trip Setpoint and Allowable Value for each of the Instrumentation Trip Functions for which this proposal applies is determined in a

. Design Calculation; Each Design Calculation derives the nunerical values and provides documentation of the bases of each value. We Design Calculation also provides the numerical values for irclusion in the procedures used in the field for instrument calibration.

The Trip Setpoint values in the Technical Specification Instrumentation Tables are not related to any ACTION requirement and, as long as the Allowable value is not exceeded, no ACTION is specified and the instrumentation is considered to have been OPERABLE. We purpose of the Trip Setpoint listing is to provide the nominal setpoint which gives confidence that the Allowable Value is not exceeded during a future calibration interval.

As described above, Detroit Edison has established a controlled program to assure that the Technical Specification Allowable values I

are not exceeded and thus ensuring the paraneters in question cause l

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the associated. trips and actuations consistent with the assumptions of the associated safety analysis. his program determines a n minal Trip Setpoint and an associated tolerance band thereby making the inclusion of inequality indicators in the Technical Specifications Trip Setpoint listings inappropriate. Detroit Edison proposes to remove this inconsistency by eliminating the inequality indicators.

Wis.will eliminate potential confusion concerning these i.equirments and reduce the potential for unnecessary or inappropriate adjust:::ent '

of the instrumentation. By so doing, the proposal provides an enhancement to safety. -

l %e Bases of each of the'affected Technical Specifications is proposed to be mx'lified to reflect the setpoint methodology.

SEIND'IQurf HMNES CmtSIMERTIGI In accordance with 10CFR50.92, Detroit Edison has made e determination that the proposed anendnent 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 mugin of safety.

The proposed change to eliminate the inequality indicators from the Trip Setpoint values contained in the Instrumentation Technical Specifications does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluatM. %e change reflects the program in place to ensure that tne instrumentation of concern trips prior to the value for the parameter of concern assumed in the associated accident analysis. %erefore, the proposal has no effect on the results of any accident analysis.

2) Create the possibility of a new or different kind of accident from any accident previounly evaluated. We change solely provides consistency between the Trip Setpoint listings and the methodology used to establish the values. %e change will have no impact on the manner of plant operation and causes no new accident mode.a. Berefore, no new or different kind of accident is created.

.3) Involve a significant reduction in a margin of safety. The instrumentation setpoints will continue to be set consistent with

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the methodology which established the settings. Sus, the interded assurance that the trip occurs at the point assumed in the accident analysis'is maintained. We overall margin of safety is inproved by the improvement in consistency between Technical Specifications with the setpoint methodology. Wis will reduce the possibility of unnecessary or inappropriate -

adjustment of the instrumentation.

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

IBFIBGRErmL INNCT Detroit Edison has reviewed the proposed hchnical Specification changes against the criteria of 10CFR51.22 for environmental considerations. We proposed change does not involve a significant hazards considerations, 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 naet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

CCBE w SImt Based on the evaluation 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 Connuission's regulations and proposed amendments will not be inimical to the comnon defense and security or to the health and safety of the public.

This proposal is independent of any previous or future Technical Specification change proposals which affect the same Specifications. .

Any proposal which contains inequality indicators within the Trip .

Setpoint listing should be incorporated into the Technical ,

Specifications without the inequality indicators if approved following i the approval of this proposal. Further, for any such proposals approved prior to the approval of this proposal, the associated inequality indicators should be removed when this proposal is incorporated into the Technical Specifications.

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