NRC-89-0265, Application for Amend to License NPF-43,revising Tech Spec Figure 3.2.3-2 Re Flow Correction Factor Concerning Cycle 2 Reload to Correct Error in Amend 42,Tech Spec 3.2.4 Re Fuel Bundle Types & Ref of New Figures in Tech Spec 4.2.3.1

Application for Amend to License NPF-43,revising Tech Spec Figure 3.2.3-2 Re Flow Correction Factor Concerning Cycle 2 Reload to Correct Error in Amend 42,Tech Spec 3.2.4 Re Fuel Bundle Types & Ref of New Figures in Tech Spec 4.2.3.1

ML19332D324
Person / Time
Site:	Fermi
Issue date:	11/16/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19332D325	List: ML19332D327 NRC-89-0265, Application for Amend to License NPF-43,revising Tech Spec Figure 3.2.3-2 Re Flow Correction Factor Concerning Cycle 2 Reload to Correct Error in Amend 42,Tech Spec 3.2.4 Re Fuel Bundle Types & Ref of New Figures in Tech Spec 4.2.3.1
References
CON-NRC-89-0265, CON-NRC-89-265 NUDOCS 8912010014
Download: ML19332D324 (10)

Text

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' ,' [ ' ' s; Ralph Sylvb

, sena vice eccene N.I ' woowonnoaeognur Edison ~ rem-  !

I Novenber 16, 1989 N10-89-0265  :

1 U. S. Ntaclear Regulatory Comnission '

Attn . Document Control Desk Washington, D. C. 20555 ,

References:

1) Fermi 2 NIC Docket No. 50-341 NIC License No.. WF-43

2) Detroit Edison Letter, NIC-89-0052, ,

" Proposed Operating License / Technical Specifications Change (License Amendnent) - Cycle 2 Beload Submittal,"

dated April 3,1989

3) " General Electric Standard Application for Beactor Fuel," NEDE-240ll-P-A ,

(Revision 9)

4) letter from G. G. Jones (General Electric) l- to A. D. Smart (Detroit Edison), " Fermi. 2, Flow-Dependent Multiplier for MCPR," dated Novenber 10, 1989-  !

Subject:

Proposed Emergency Technical Specification Change l Ricense Amramnt) - Cvele 2 Reload Snhmittn1 Pursuant to 10CFR50.90, Detroit Fdison Coupany hereby proposes.to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes -into the Plant Technical Specifications. '1he proposed change provides a revised Technical Specification Figure l 3.2.3-2, Flow Cortection (K ) Factor. The Figure requested by f

Detroit Faison in Reference 2 and issued by the NK:'as Amendnent 42 to l the Fermi 2 Operating License was recently found to be in error. When this figure was prepared from the original information provided by the fuel supplier, General Electric, it was drawn inproperly such that operation in coupliance with the figure could 'have been .

nonconservative with respect to the a:cident analysis. Further review of other figures submitted in Beference 2 determined that five other figures submitted should be modified to more clearly show the limits

they inpose upon plant operation. In addition, same administrative or typographical errors were found in the designation of fuel bundle types in Specification 3.2.4 and in the referencing of new figures in ,

Specification 4.2.3.1. Minor corrections to the Bases were also found to be necessary.

f001 8912010014 891116

• PDR ADOCK 05000341 'N P PDC ,

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.,y f USNHC D p 3. < .' November 16, 1989 ,

NHC-89-0265 -

Page 2 Fermi 2-is currently shutdown for the first refueling outage with -

reactor startup scheduled for Novenber 20, 1989. The plant is then scheduled to be prouptly escalated. in power to greater the 25% of i

- rated thermal' power. l At that' tine the requirements of: the Technical

. Specifications proposed to be modified becone applicable.- Detroit Edison believes that it isiinappropriate to operate with Technical.

Specification which are applicable yet incorrect or unclear. For this:

l reason, Detroit FAison requests that this request be processed under

the provisions of 10CFR50.91(a) (5) as an emergency situation in which ,

lack of timely action would unnecessarily prevent resunption of plant '

operation at full power. t Detroit' Edison has evaluatied the proposed Technical Specifications -

against the eriteria of 10CFR50.92 and determined .that no significant - l hazards consideration is involved. The Fermi 2 Onsite'Beview >

Organization has approved and the !bclear Safety Review Group has reviews the proposed Technical Specifications and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Fdison 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,

. Nf v .

Enclosure cc: A. B. Davis L /

R. W. Defayette W. G.-Rogers J. F. Stang Supervisor, Advanced Planning- and Review Section, Michigan Public Service Commission p

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lUSNBC R D' Novenber 16, 1989:

NRC-89-0265 Page 3 P ,

-I,-B. RALPH SYLVIA, do hereby affirm that the foregoing statenents are=

based on facts and circunstances which are true and accurate to the -;

best of my knowledge and belief.

i" k'h/?p . b '

Y. ~RAIIH SfY VIA Senior Vice President l

L.-

i- - On this day of /Ndt I--- , 1989, before me '

. personally appeared B.' Ralph hylvia, being first July sworn and says i-; > that' he executed the foregoing as his free act and deed.

Notary Pub)ic ')

ROSAUE A. ARME1TA Notory Public. Monroe County, MI

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MyCommission ExpiresJon.11.1992 U

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.gnolosuro LC

. '[, ., NRC-89-0265-Page,1

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INTRODUCTION-Detroit Edison in Reference 2 requested Technical Specification changes for Cycle 2 operation at Fermi 2. The NRC subsequently approved the requested changes by issuing Amendment 42-to the Fermi 2

-Operating License on September 13, 1989.

In preparation for startup from the current refueling outage, which will begin Cycle 2 operation, Reactor Engineering personnel began the

, process of inserting cycle-specific information into the plant process computer. Some of this information is included in the Technical i l

Specification figures which were modified by Amendment 42.

When the process computer information for Flow Correction (Kr)

Factor as a function of Core Flow was compared to the same information in Technical Specification Figure 3 2 3-2, the two sets of inrormation-were found to be different. This check was performed in accordance

-with established administrative controls to ensure that these discrepancies do-not exist prior to startup from a refueling outage.

Subsequent investigation found that the process computer information

-was technically correct. The Technical Specification figure was found to be incorrectly copied from the figure rupplied by the fuel supplier, General Electric. This occurred in the process of ensuring all figures submitted to the NRC were of suitable quality in terms of editorial standards. Subsequent reviews did not detect the-error and the incorrect figure was submitted in Reference 2.

The nature of the error in Figure 3 2 3-2 was such that operation in accordance with the figure could allow plant operatior which is j non-conservative with respect to the underlying analysis upon which the figure'is based. In other words, the flow correction factor could 3

be smaller than intended resulting in a Minimum Critical Power Ratio (MCPR) limit closer to MCPR Safety Limit than-was found to be

acceptable in the supporting analysis.

Upon the discovery of this error, Detroit Edison began a detailed review of Amendment 42 against its base-line documents. Particular attention was paid to figures. The following_ figures were found to i need modification to ensure the limits contained in the figures

clearly express the limits required by the supporting analysis. The problems were either editorial or related to the clarity of the h figure. The affected figures are:

Maximum Average Planar Linear Heat o Figure 3 2.1-3 Generation Rate (MAPLHGR) Versus Average Planar Exposure l Reload Fuel Type BC318D

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o Figure 3 2.1 Maximum Average Planar Linear Heat ,

Generation Rate (MAPLHGR) Versus Average Planar Exposure Reload Fuel Type BC318E o Figure 3 2 3-1 BOC To 12,700 WD/ST Minimum Critical Power Ratio (MCPR) Versus Tau At Rated Flow .

o Figure 3 2 3-1A 12,700 WD/ST To 13,700 WD/ST Minimum Critical Power Ratio -

(MCPR) Versus Tau At Rated Flow i o ' Figure 3 2 3-1B 13,700 WD/ST To ECC Minimum Critical' Power Ratio Versus Tau At Rated Flow Bases Section 2.0 and 3/4.13 were found to retain references to the Cycle 1 MCPR Safety Limit of 1.06. Also, Bases Section 2.1.1 refers to the GEXL correlation, which applied only to Cycle.1.. New Bases pages are attached which replace cycle-specific references with -

general references which are not cycle-specific. This is consistent with other' Bases changes made in Amendment 42. Typographical and -

editorial errors were found in Bases Section 3/4.2 3 and Table B 3 2.1-1, the errors are corrected in the attached page changes.

In addition, typographical errors were found in the designation of '

3 fue1~ bundle types in Specification 3 2.4 and a reference-to figures in

. Specification 4.2 31'was not changed to match the addition of new

• figures. -The purpose of this submittal is to correct these errors. ,

EVALUATION The changes proposed fall into four categories, each of which are addressed individually below.

Maximum Average Planar Linear Heat Generation Rate (MAPLHGR) Limit Figures These figures provide the MAPLHGR limits, in units of KW/ft, as a function of Average Planar Exposure, in units of WD/t. The information is presented graphically as a series of line segments.

Each point where the segments connect is given in tabular format.

Two new fuel types, BC318D and BC318E, have been loaded at Fermi 2 for Cycle 2; therefore, two new MAPLHGR limit figures have been proposed.

These figures are Figures 3 2.1-3 and 3 2.1-4, respectively.

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NRC-89-0265 Page.3-i' b

In both-figures, one. point specified for the joining of two line segments was'not graphically plotted consistent with the tabular information. In both figures, the point tabularly indicated to be  !

' associated with 12,500 mwd /t was graphically plotted at 12,000 MWD /t.-

Further, the heading for the MWD /t column in both figures is

< incorrectly given as "HWD/" rather than the correct units of " MWD /t".

The GE Nuclear Energy Supplemental Heload Licensing Submittal (RLS),

Q. provided as an attachment to Reference 2, gives the results of the s

1. accident analysis which is the basis for these curves. This information is~ located in Item 17 on page 15 of the RLS. The analysis results correspond to the tabular data on the figures.

This submittal contains revised Figures 3 2.1-3 and 3 2.1-4 with the graphs replotted to correctly indicate the RLS information. A corrected heading for the Average Planar Exposure column of the table is also included.

The change does not reflect any change-to the accident analysis which- 1 was reviewed and approved by the NRC in conjunction with Amendment

42. The change strictly corrects administrative errors made in the preparation of Reference 2. For these reasons, Detroit Edison believes these changes are acceptable.

Minimum Critical Power Ratio (MCPR) Versus Tau at Rated Flow Limit _

Figures Amendment 42 provided three figures, each for a specific period of core life (measured in MWD /ST), which provide MCPR operating lim.1ts as t a function of a variable, tau. Tau, is defined in Specification 3 2 3 and is a measure of the control rod scram spcod performance as related to that-assumed'in the General Elecbric analysis. Since scram times l1 can be less conservative than that assumed in the analysis, but still within those allowed by Technical Specifications, the MCPR operating limit is adjusted conservatively upward when necessary by referring to these figures.

l :.

l MCPR versus tau curves are provided in each figure for four possible

operating conditions. These conditions are combinations of Control Cell Core (CCC) or non-CCC operating modes, and the availability of turbine bypass capability or moisture separator reheater.

The nomenclature essociated with Curve C and Curve D, which appears on -

each of these figures, was found to be unclear as proposed in Reference 2 and as issued in Amendment 42. The nomenclature is proposed to more clearly indicate which equipment is assumed to be out-of-service for the two curves. Previously, the terminology

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' [, ~ ' ,. NRC-89-0265' Page 4 "without a piece of equipment" was used to mean "with the equipment out-of-service." The proposal is str!.ctly editorial and makes no change to the intent or application of the curves.

On Figure 3 2 3-1, the MCPR value for tau equal to 1.0 for the merged s

. Curve A and B is not given on the figure. This point corresponds to a MCPR of 1 32. This value is the " option A" most limiting pressurization event for the exposure range "BOC2 to EOC2 - 2000 MWD /St" located on RLS page 13

.On all three figures, Curve B is a hybrid of two limiting events. One tis the non-pressurization event of a rod withdrawal error which has a limiting MCPR of 1 30 for GE8x8EB fuel (see RLS pg. 13). The other is-

-the pressurization event for the core exposure of concern which yielded Curve A. Thus, Curve B is a constant 1 30 for tau less than

-the tau for the point where the Curve A event becomes more limiting.

On Figures 3 2 3-1A and 3 2 318 a value of less than 130 appears to be indicated for a-portion of Curve B which should be a constant 1 30. This occurs.near the point where Curves A and B join. This proposal corrects Curve B for these two figures by indicating the correct value of 130 for the constant MCPR segments of Curve B.

'In' summary, all of the changes to the MCPR limit figures are either editorial or corrections of administrative errors in the plotting of

'RLS supplied data points. There is no change in the underlying accident analysis which was reviewed and approved by the NRC in conjunction with Amendment 42. For these reasons, Detroit Edison believes these changes are acceptable.

' Flow Correction (K,) Factor j

Flow Correction (Kf ) Factor as a function of Core Flow (%) is provided in Figure 3.2 3-2. The Operating Limit MCPR determined from

~

l the use of Figure 3 2 3-1, 3 2 3-1A, or 3 2 3-1B (depending on core exposure) is multip' lied by Kr. This increases the MCPR limit further to account for a potential Reactor Recirculation Pump _ Runout  !

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transient. Since the severity of this transient depends on the Flow "

L Control Mode and, if in manual mode, the Scoop Tube Setpoint Calibration, five curves are provided to account for the possible L

configuration.

As discussed above under Introduction, this figure was incorrectly i drawn in the preparation of Reference 2. The sole change to this figure is to provide the correct curves.

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NRC-89-0265 Page 5 ,

t The new Kr values were made necessary for Cycle 2 due to the l 1

application of the GEXL-PLUS critical power correlation to the Cycle 2 reload licensing analyses. The Cycle 1 analysis used the GEXL ,

correlations. Both correlations provide a means to relate bundle critical power, that power which leads to transition boiling, to parameters which can be sensed and provided to the plant process l

computer.

The need to revise Kr values in order to apply the GEXL-PLUS '

correlation is contained in Amendment 15 to GESTAR II (Reference 3).

• t This document provided details as to the required values for Kr and

'their bases. Amendment 15 to GESTAR II was approved by the NRC staff in a Safety Evaluation dated March 14, 1988.

General Electric has reconfirmed the required Kr values for Fermi 2 and has formally transmitted them to Detroit Edison in equation form in Reference 4. Reference 4 is attached for information.

The sole purpose of the proposed change is to correct an administrative error made in the preparation of Rt.ference 2. . No '

change to the underlying accident analysis has been made. For these reasons, Detroit Edison believes the new figure is acceptable.

Administrative Errors Amendment 42 revised Specification 3.2.4 to indicate separate Linear ,'

Heat Generation Rate (LHGR) limits for different fuel bundle' types.

In Amendment 42, bundle types 8CR183 and 8CR233 were incorrectly identified as BCR183 and BCR233 Also, in Specification 4.2 3 1 reference to Figure 3 2 3-1 was not changed to include r:ew Figures 3 2 3-1A and 3 2 3-1B. The new figures were created by the

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specification of MCPR limits based upon core exposure. Specification 4.2 3 1 is proposed to be changed in a manner similar to that approved in Amendment 42 for Specification 4.2 3 2 to ensure that all of the  ;

curves are referenced. .

Bases Sections 2.0 and 3/4.1 3 were found to mention that the MCPR Safety Limit is 1.06, which was the Cycle 1 limit. These sections were not originally identified as needing changing. Elsewhere the term " Safety Limit MCPR" was inserted in Reference 2 where the specific value previously had been. These sections are now corrected to reference the Safety Limit MCPR. Also, since Bases Section 3/4.1.3 .

is being revised, the reference to Section 15B of the FSAR is being J updated to Section 15 of the UFSAR (Updated Final Safety Analysis '

Report). A-mention of the Cycle 1 GEXL analyses was inadvertently left in Bases Section 2.1.1. As discussed above, the GEXL-PLUS l

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NRC-89-0265 Page 6 correlation'was used for Cycle 2. The wording is being corrected to mention the " approved critical power correlation." On Bases Table rather .;

- B 3 2.1g", the unit This is of areacorrected.

being for a small break The last is listed as "fta administrative  ;

F than "ft .

errors needing correction are in Bases Section 3/4.2 3 The word  !

4

" extended".was mistyped in Amendment 42 as " extending". Additionally #

the descriptions.of the CCC operations mode and non-CCC mode need-

• slight changes to match descriptions provided elsewhere in the Technical Specifications. These errors are being corrected.

This proposal corrects these administrative errors. No technical

' changes are involved. On that basis, Detroit Edison believes that these changes are acceptable.

SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50 92, Detroit Edison has nade a-determination <

that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must 3 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 l margin of safety.

The proposed change makes. strictly administrative or. editorial changes to correct administrative errors in the Reference 2 application, which resulted in Fermi 2 Operating License Amendment 42. There'is no change to underlying accident and transient analysis performed to support Cycle 2 operation at Fermi 2 which was reviewed in conjunction with the issuance of. Amendment 42. The chango is administrative in nature and is' thus like example (i) of Examples.of Amendments That Arc Considered Not Likely To Involve Significant Hazards Considerations -;

listed in 51 FR 7751.

Due to its. strictly administrative nature, the change does not:

1) Involve a significant increase in the probability or consequences i

of an accident previously evaluated.

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

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

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

'L -BASIS FOR EMERGENCY CIRCUMSTANCES Fermi 2 is currently shutdown for refueling and scheduled to commence "

reactor startup on November Pn:, 1989 Escalation above 25% power-is scheduled to occur as soon at Flant conditions allow.

As described above, this change corrects or makes clear Technical Specification limits associated with the-Cycle-2 fuel loading. The affected Specifications are all applicable at greater than 25% rated thermal power. Detroit Edison does not believe operation with applicable. Technical Specifications which are non-conservatively incorrect is acceptable. Due to the schedule detailed above, adequato .;

time for the usual 30 day period for public comment does not. exist.

Therefore,. Detroit Edison believes that emergency circumstances, as '

defined in 10CFR50 91(a)(5), exist in this case.

Detroit Edison _ recognizes that the NRC expects its licensees to apply for lice ise amendments in a timely fashion. In this case, the need for the amendment arose from the diligent investigation of a recently 1 discovered discrepancy between the Technical Specifications for Cycle 2 and the process computer data for Cycle 2. Upon discovery of the

.need for a-license' amendment,-this application has been made in a prompt manner. Therefore, Detroit Edison believes that this emergency situation could not reasonably have been avoided.

ENVIRONMENTAL IMPACT ,

' Detroit Edison has reviewed the proposed Technical Specification l changes against the criteria of 10CFR51.22 for environmental <

D considerations. The proposed change is strictly administrative and-4 does not involve'a significant hazards consideration, nor significantly change the types or significantly increase the arunts-i.

P of effluents that may be released offsite, nor significantly increase i

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 L. categorical exclusion from the requirements for an Environmental Impact Statement.

CONCLUSION Based on the evaluation above:- 1) there is reasonable assurance that the health and safety of the public will not be endangered by L

3< 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.

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