NRC-97-0031, Application for Amend to License NPF-43,requesting Elimination of Selected Response Time Testing Requirements

Application for Amend to License NPF-43,requesting Elimination of Selected Response Time Testing Requirements

ML20137K072
Person / Time
Site:	Fermi
Issue date:	03/27/1997
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137K076	List: ML20137K080 NRC-97-0031, Application for Amend to License NPF-43,requesting Elimination of Selected Response Time Testing Requirements
References
CON-NRC-97-0031, CON-NRC-97-31 NUDOCS 9704040232
Download: ML20137K072 (13)

Text

-,

v'.s Dcuglas R.elpson Setuor Vce Presdont Nuclear Generaten

' Fermi 2 6400 North Dme Hghway

. Newport, Mchegan 46166 '

(313)5864249 i

March 27,1997

- NRC-97-0031 a

t U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 ,

References:

1) Ferm 2 NRC Docket No. 50-341 NRC License No. NPF-43

. 2) System Analyses for Elimination of Selected Response Time Testing Requirements, BWROG Report NEDO-32291 A, dated October 1995 j

Subject:

Proposed Technical Specification Change (License Amendment) for Selected Resnonse Time Testine Reauirements  :

I' Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend ,

Operating License NPF-43 for the Fenni 2 plant by incorporating the enclosed changes into the Plant Technical Specifications. The proposed changes climinate a  ;

number of response time testing requirements based on the BWR Owners' Group ,

Topical Report NEDO-32291 A (Reference 2) which provides the technical justification for these removals. j l

By letter dated December 28,1994, and its supplement dated May 31,1995, the NRC  ;

staff provided their acceptance of NEDO-32291 A, subject to certain conditions. .

These conditions are addressed in the enclosures to this request. l This amendment climinates unnecessary response time testing, thereby eliminating all inadvertent safety system actuation risk caused by installation and removal of temporary test jumpers used for response time testing. Out of service time for the  ;

instrumentation channels due to this unnecessary testing is also eliminated. 1 Additionally, a significant reduction in I&C technician outage work scope will occur l q g g ,j Qwhich will allow deployment of those resources to other more important activities. l D GLirrg5 0(A M /A broil /Fr/p3 [yJD/',

9704040232 970327 PDR ADOCK 05000341 4

g-gg.gg. .gg .

i i

P PDR \

f y- o USNRC- i NRC-97-0031 -i Page 2  ;

Enclosure 1 provides a description and evaluation of the proposed changes.

Enclosure 2 provides an analysis of the significant hazards consideration assessment ' l using the standards in 10CFR50.92.

Enclosure 3 provides marked up pages of the existing Technical Specifications to {

show the proposed changes and a typed version of the affected Technical l Specification pages with the proposed changes incorporated. ,

i Enclosure 4 provides responses to the conditions included in the NRC staff's safety evaluation accepting NEDO-32291 A.  ;

Enclosure 5 provides a discussion concerning the application of the provisions for exigent circumstances to this request. ,

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 . l Safety Review Group has reviewed the proposed Technical Specifications and j concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit l Edison has provided a copy of this letter to the State of Michigan.

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

Sinc rely, ,

i i

Enclosures cc: A. B. Beach G. A. Harris M. J. Jordan 1 A. J. Kugler Supervisor, Electric Operators, Michigan Public Service Commission J. R. Padgett

USNRC NRC-97-0031

• - Page 3 i

l t

W I, DOUGLAS R. GIPSON, 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.

i DOUGLAS R.DIPSON Senior Vice President On this 8 day of /A/ , 1997 before me personally -

appeared Douglas R. Gipson, being first duly sworn and says that he executed the '

foregoing as his free act and deed.

Notary Public l l

. ROSAUE A. ARMETTA >

NOTARY PUBUO-MONRGECOUNTY,f/l MYCOMM:SS;0N EXPlFES10/11/93

-]

i

)

I l

l s

e

7 9

g #b Enclosure 1 NRC-97-0031 Page1 1

ENCLOSURE 1 DESCRIIrrION AND EVALUATION OF TIIE PROPOSED CIIANGES

i Enclosure 1-

' NRC-97-0031

~

Page 2 ENCLOSURE 1 .

FERMI 2 NRC DOCKET NO 50-341 OPERATING LICENSE NPF-43

REQUEST TO REVISE TECIINICAL SPECIFICATIONS

RESPONSE TIME TESTING H ASIS FOR CIIANGE REOUEST 4

4 R

., s.

Enclosure 1 NRC-97-0031 Page 3 IIACKGROUND:

This proposed change is to eliminate from Technical Specifications selected response time testing requirements. Specifically, the response time testing requirements to be eliminated are for the:

1. Reactor Protection System instrumentation - Sensors for Reactor Vessel Steam Dome Pressure-High and Reactor Vessel Low Water Level - Level 3;

2. Isolation Actuation System instrumentation - Sensors for Reactor Vessel Low Water Level-Level 1 and Main Steam Line Flow-High, and;

3. Emergency Core Cooling System Actuation instrumentation.

An analysis has been performed demonstrating that other periodic tests required by Technical Specifications, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, provide adequate assurance that instrument response times are within acceptable limits.

llASIS:

Regulatory Guide 1.118 (Revision 2) States:

" Response time testing of all safety related equipment, per se,is not required if,in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine tests." ,

1 An analysis has been performed by General Electric (GE) and the BWR Owners' Group which provides the basis for eliminating selected response time testing requirements (see Reference 1). The analysis was performed for two representative BWRs, one of which is Fermi 2. The applicability of this analysis to Fermi 2 has been verified by GE.

The analysis includes the identification of all potential failure modes of all components in the affected instrumentation loops waich could potentially impact the instrument loop response time. In addition, industry operating experiences were reviewed to identify response time failures and how they were detected. The failures modes

7 i

.; .._ j Enclosure 1 NRC-97-0031 l Page 4 i

identified were then evaluated to determine if the effect on response time would be detected by other testing requirements contained in Technical Specifications.

The results of the analysis demonstrate that other Technical Specification testirq,  ;

requirements (channel calibration, channel check, channel functional test, and logic system function test) are sufficient to identify failure modes or significant degradations in instrument response time and assure operation of the analyzed instrument loops within acceptance limits. Furthermore, there are no failure modes that can be detected by response time testing that cannot also be detected by other Technical Specification tests.

The Reference 1 evaluations demonstrate that response time testing can be eliminated for the following:

1. All Emergency Core Cooling System instrument loops; i

2. All Isolation System actuation instrument loops except for main steam line isolation valves (MSIVs);

3. Sensors for selected Reactor Protection System actuation; and

4. Sensors for MSIV closure actuation.

The Isolation Actuation System (IAS) Instrumentation Response Time Testing except for MSIV closure (item 2 above) was eliminated in accordanor with NRC Generic Letter 93-05. By the letter dated June 29,1994, the NRC staff approved the elimination of response time testing for IAS instrument channels that correspond to the diesel generator start, (Amendment 99 to the Fermi 2 Operating License)

SIGNIFICANT II AZARDS CONSIDER ATION The significant hazards consideration assessment is presented in Enclosure 2 and concludes that the proposeo amendment does not involve a significant hazards consideration.

HASES FOR EXIGENT PROCESSING A discussion of the circumstances involved in this request is presented in Enclosure 5 and concludes that this request qualifies for exigent processing in accordance with ,

10CFR50.91(a)(6).

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental censiderations. The proposed change does

/

.-. ..o- )

Enclosure 1 NRC-97-0031 - -;

Page 5 not involve a significant hazards consideration, nor significantly change the types or l significantly increase the amounts of effluents that may be released offsite, nor = ,

significantly increase individual or cumulative occupational radiation exposures. j

. 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 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 -l

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 j to the health and safety of the public.  :

Reference:

1

1. NEDO-32291 A," System Analyses for the Elimination of Selected Response Time  !

Testing Requirements," October 1995.  !

I i

k l

l 8

f I

I h

1. 84 Enclosure 2 NRC-97-0031 2

Page1 ENCLOSURE 2 SIGNIFICANT IIAZARDS CONSIDERATION ASSESSMENT

Enclosure 2 NRC-97-0031 Page 2 ENCLOSURE 2 FERMI 2 NRC DOCKET 50-341 OPERATING LICENSE NPF-43 REQUEST TO REVISE TECliNICAL SPECIFICATIONS:

RESPONSE TIME TESTING 10CFR50.92 EVALUATION H ASIS FOR SIGNIFICANT II AZARDS DETERMINATION:

The proposed Technical Specification changes described in Enclosure 1 do not involve a significant hazards consideration for the following reasons:

1. He changes do not involve a significant increase in the probability or ,

consequences of an accident previously evaluated.

The purpose of the proposed Technical Specification changes is to eliminate  !

response time testing requirements for selected instrument loops in the Reactor i Protection System, Isolation System, and Emergency Core Cooling System. l However, because of the continued application of other Technical Specification i testing requirements such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, the response time of these systems will be maintained within the acceptance limits assumed in plant safety  !

analyses and required for successful mitigation of an initiating event. The j proposed Technical Specification changes do not affect the capability of the i associated systems to perform their intended function within their required response time, i GE and the BWR Owners' Group have completed an evaluation (Reference 1) l which demonstrates that response time testing is unnecessary due to other Technical Specification testing requirements listed in the preceding paragraph. l These other tests are sufficient to identify failure modes or degradations in j instrument response time and assure operation of the associated systems within j acceptance limits. There are no failure modes that can be detected by response i time testing that cannot also be detected by the other Technical Specification tests.

,- -- -. _ = .. .

l  ?

..'v Enclosure 2 NRC-97-0031  !

Page 3 '

.f I

i 2.' The bhanges do not create the possibility of a new or different kind.of accident f from any accident previously evaluated.

As discussed above, the proposed Technical Specification changes do not affect l the capability of the associated systems to perform their intended function within .

. the acceptance limits assumed in plant safety analyses and required for successful 1 mitigation of an initiating event. Other than the elimination of selected response -

time tests there are no changes to plant equipment or configuration.

3. The changes do not involve a significant reduction in the margin of safety.

The current Technical Specification response times are based on the maximum i allowable values assumed in the plant safety analyses. 'Ihese analyses  ;

conservatively establish the margin of safety. As described above, the proposed Technical Specification changes do not affect the capability of the associated systems to perform their intended function within the allowed response time used as the basis for the plant safety analyses. Plant and system response to an i initiating event will remain in compliance within the assumptions of the safety i

analyses, and therefore, the margin of safety is not affected.

EcicicDcm

1. NEDO-32291 A," System Analyses fer the Elimination of Selected Response Time Testing Requirements," October 1995 i

)

i I

Enclosure 3 NRC-97-0031

~

Page l' F

ENCLOSURE 3 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NPF-43 REQUEST TO REVISE TECHNICAL SPECIFICATIONS: ,

RESPONSE TIME TESTING TECHNICAL SPECIFICATION CHANGES A.NQ PAGE CIIANGE INSTRUCTIONS Attached are mark-ups of the existing Technical Specifications, indicating the proposed changes, and a typed version of the Technical Specifications incorporating the proposed changes. provided below are instructions for incorporating these pages into the Technical Specifications.

Remove Page Insert Page 3/4 3-1a 3/4 3-1a 3/4 3-10 3/4 3-10 3/4 3-23 3/4 3-23

Enclosure 3 NRC-97-0031 Page 2 ENCLOSURE 3-PART1 PROPOSED TECIINICAL SPECIFICATION PAGE MARKUPS l

l I

- - _ - _ - _ _ _ _ - - _ _ - _ _ _ _ _ - _ - _ _ - _ _ _ _ - _ _ _ _