NRC-97-0105, Application for Amend to License NPF-43,revising TS to Be Consistent W/Planned Replacement of Current Power Range Monitoring Portion of Existing Nms

Application for Amend to License NPF-43,revising TS to Be Consistent W/Planned Replacement of Current Power Range Monitoring Portion of Existing Nms

ML20203F179
Person / Time
Site:	Fermi
Issue date:	12/10/1997
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20203F184	List: ML20203F194 NRC-97-0105, Application for Amend to License NPF-43,revising TS to Be Consistent W/Planned Replacement of Current Power Range Monitoring Portion of Existing Nms
References
CON-NRC-97-0105, CON-NRC-97-105 GL-94-02, GL-94-2, NUDOCS 9712170304
Download: ML20203F179 (40)

Text

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lbugin IL Gipwn Senior Vir e hesident, hudrar Generatta

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'I Olw horth Daic 119., hwport, L hihn 44t4 Tel 313 %Usl in als TA6 4172 Detroit Edison 10 CFR 50.92 December 10,1997 NRC 97 0105 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

References:

1)

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

NRC Generic Letter 94-02,"Long Term Solutions and Upgrade of Interim Operating Recommendations for Thermal-j liydraulic Instabilities in iloiling Water Reactors", dated July

)

i1,1994 3)

Detroit Edison letter to NRC, NRC-94-0089,"Detreit Edison Response to NRC Generic Letter 94-02", dated September 8, 1994 4)

Detroit Edison Letter to NRC, NRC-96-0001," Revision to implementation Schedule for Generic Letter 94 02," dated January 22,1996 5) 1.icensing Topical Report," Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM)

Retrofit Plus Option til Stability Trip Function," Volumes 1 and 2, NEDC-32410P A, October 1995 6)

Supplement I to Licensing Topical Report," Nuclear pk Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option 11! Stability

..Uu9.

Trip Function," NEDC-32410P Supplement 1, May 1996 l

P PDR A lite Enero Contany

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USNRC NRC-97-0105 Page 2 l

7)

GE Letter to NRC MFN 154 96,"Supplementalinformation Related to GE Licensing Topical Report, NEDC 32410P, Supplement 1. Nuclear Measurement Analysis und Control Power Range Neutron Monitor (NUM AC PRNM) Retrofit Plus Option 111 Stability Trip Function," dated September 30, r

1996 8)

NRC Letter, NPC Stafr Approval of GE Licensing Topical Report (LTR) NcDN1410P," Nuclear Measurement Analysis and Contr6 Nwer Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option 111 Stability Trip Function," dated September 5,1995 9)

NRC Safety Evaluation by the Office of NuElcar Reactor Regulation,"NEDC-32410P, Supplement 1, Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retront Plus Option til Stability Trip Function,"dmed August 15,1997

Subject:

Proposed Technical Specification Change (License Amendment).

Neutron Monitonne System Pursuant to 10CFR50.90, The Detroit Edison Company (Detroit Edison) hereby files an application to amend the Fermi 2 Technical Specifications (TS). The proposal revises the TS to be consistent with a planned replacement of the current Power Range Monitoring portion of the existing Neutron Monitoring System (NMS). This change is consistent with our response to Generic Letter (GL) 94-02 (References 2 and 3) and will allow Detroit Edison to proceed with implementation of the long-term solution designated as Option 111 in NEDO 31960-A and NEDO 31960 A, Supplement 1,"IlWR Owners' Group Long Term Stability Solution Licensing Methodology." More specifically, the enclosed request is based on General Electric (GE) Licensing Topical Report NEDC-32410P.A " Nuclear Measurement Analysis and Control Pawer Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option 111 Stability Trip Function" as submitted, supplemented, and clarified in References 5,6, and 7, and as approved by the NRC in References 8 (base report) and 9

.(Supplement I and clarifications).

This proposed license amendment includes only those changes associated wi h the t

planned changes to the NMS system. A proposed license amendment request associated with thermal hydraulic stability administrative controls, post accident

]

USNRC NRC-9_7-0105 i

Page 3 monitoring, and idle recirculation loop startup, which are not directly associated with the PRNM hardware, is beir.g submitted rTarately.

As described in Reference 4,' Detroit Edison plans to install the new Power Range

- Neutron Monitoring (PRNM) System during the sixth refueling outage (RF06).

RF06 is currently scheduled to begin in August 1998. Approval of this proposed license amendmeat is requested by July 1,1998, with implementation prior to startup from RFO6, to support the RFO6 outage schedule.

As also discussed in Reference 4, the Option 111 automatic trip will be installed during RFO6 in the " indica'e only" mode. Assuming successful operation of the system in the following operating cycle, the automatic trip would be activated during the seventh refueling outage (RF07). The enclosed Technical Specification changes address the scheduled RFO6 modifications. TS changes for the activation of the Option 111 trip will be submitted separately in time for the scheduled activation during RFO7, currently planned for the spring of the year 2000.

Th ough climination, simplification and reduction in number of required surveillances, preventive maintenance actions, Technical Specification requirements, and through changes in surveillance intervals, the PRNM upgrade is expected to simplify plant operation and automate a number of time-intensive periodic or startup-critical actions. The net result of these changes as reflected by the Technical Specification change translates to cost savings over the life of the plant.

Deaoit Edison has evaluated the proposed Technical Specifications against the -

criteria of 10CFR50.92 and determined thc! no significant hazards consideration is involved. The Fenni 2 Onsite Review Organization has reviewed and recommended approval, and the Nuclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison is providing a copy of this letter to the State of Michigan.

Enclosure I provides the description and regulatory analysis of the proposed Technical Specificatior changes. Enclosure 2 provides a tabular response to the NEDC-32410P-A and NEDC-32410p Supplement I required utility actions in support of the Enclosure I analysis. Proposed changes to the rechnical

. Specifications are provided in both markup and retyped form in Enclosure 3.

_J

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USNRC NRC-97-0105 Page 4 -

if you have any questions or comments, please contact Mr. Joseph Conen of my staff-.

_at (313) 5861960.

Sincerely, e

i

. Enclo'sures cc:

A. B. Beach -

B. L. Burgess G. A. liarris --

A. J. Kugler -

Supervisor, Electric Operators, Michigan Public Service Commission - J. R. Padgett l

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USNRC NRC-97-0105 Page5 i

I, DOUGLAS R. GlPSON, C a div

.rm that the foregoing statements are based e

on facts and circunistances which -

e and accurate to the best of my knowledge and belief.

~

/JJ DOUGLAS R.pf!PSON Senior Vice President On this

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day of 9997 before me personally l

appeared Douglas R. Gipson, being first duly sworn and says that he executed the foregoing as his free act and deed.

SHARON K. DUCKLEY Noizy Pvd;c,Manrm Cm4,MI

!?fCoziMcaBTrim44M U

I Enclosure I to

- NRC-97-0105 Page1 l

ENCLOSURE 1 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO REVISE TECilNICAL SPECIFICATIONS NEUTRON MONITORING SYSTEM DESCRIPTION AND EVALUATION OF TIIE PROPOSED CIIANGES

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• to NRC-97-0105 Page 2 HACKGROUND This proposed Technical Specifict tion (TS) change request is l>:ing submitted to support the replacement of the existing power range monitoring equipment. As discussed in Reference 3, Detroit Edison is planning to replace the power range monitor portion of the Neutron Monitoring, System (NMS) with a General Electric (GE) digital NUMAC Power Range Neutron Monitor (PRNM) retrofit system. The new equipment will include capability for an automatic Oscillation Power Range Monitor (OPRM) trip to detect and suppress possible thermal hydraulic instabilities in the plant. The new OPRM trip fimetion, when enabled, will implement the Boiling Water Reactor Owners Group (BWROG) defined " Stability Option Ill" alternative. However, the OPRM trip function will not be enabled during the first cycle of operation with the new equipment, and this proposed change in TS does not include revisions to incorporate the Stability Option ill automatic trip function.

The proposed modification involves replacement of the existing power range monitor electronics with new NUMAC digital PRNM hardware. The current equipment is mounted in a 5-bay panel in the Fermi 2 Contml Center. The modification removes and replaces virtually all of the existing power range monitor equipment within the confines of the control center panels, but with minor exceptions leaves the plant level detectors, cabling, and interfaces undisturbed.

Power range monitor functions are maintained, including Local Power Range Monitor (LPRM) detector signal processing, LPRM averaging, Average Power Range Monitor (APRM) trips, and Rod Block Monitor (RBM) logic and interlocks. Recirculation flow signal processing, previously accomplished using separate hardware within the power range monitor control panels, is integrated into the APRM chassis in the new PRNM system.

The six existing APRM channels and two LPRM groups in the current system are replaced with four APRM channels, each using one quarter of the total LPRM detectors.

The APRM function is retained, but four 2-out-of-4 trip voters are added to the input to the Reactor Protection System (RPS), two in each RPS trip system. The trip outputs from all four APRM channels are sent to each voter so that each of the inputs to the Reactor Protection System (RPS) is a voted result of all four APRM channels.

To support the conversion to the NUMAC-PRNM, GE Nuclear Energy submitted the Reference 5 Licensing Topical Report (LTR). The LTR covered the full scope (including

}

TS changes) of a typical utility niodification project for a PRNM retrofit.

In the Reference 8 safety evaluatior, dated September 5,1995, the NRC staff found the NUMAC-PRNM plus Option III stability trip function system to be acceptable for J

Enclosure I to NRC-97-0105 Page 3 referencing in license applications to the extent specified, and under the limitations delincated in NEDC-32410P-A and the associated NRC technical evaluation. The LTR identifies specific utility actions necessary for implementation of the modifications. In addition, the staff s evaluation contained six plant-specific actions to be addressed in license applications. These actions are addressed in Section II of the Evaluation section of this submittal.

EVALUATION This evaluation is divided into the following three sections:

1.

Plant-specific actions referenced in the Reference 5 & 6 GE LTR and its Supplement 1 II. Plant-specific actions listed in the Reference 8 and 9 NRC Safety Evaluations 111. Related Changes Made Not Specifically Addressed in Sections I and 11 I. Plant-specific actions referenced in the GE Licensing Topical Report The table prodded in Enclosure 2 lists the " Utility Action, Required" specific actions identified in the Reference 5 Licensing Topical Report (LTR) as amended by References 6 and 7, and provides the Fermi 2 response to each of the actions. The format of the information will facilitate NRC review of the proposed changes to both continn applicability of the LTR to the Fermi 2 plant and to identify and e). plain any differences.

Certain of the Fermi 2 responses that pertain to the automatic stability trip function are deferred to a future submittal, as specifically identified in the table.

~ II. Plant-specific actions listed in the NRC Safety Evaluation A. Confirm the applicability of NEDC-32410, including clarifications and reconciled differences between the specific plant design and the topical report design descriptions.

NEDC-32410P-A and NEDC-32410P, Supplement I are applicable to Femii 2.

Clarifications cid reconciliations between the plant specific design and the topical report description are detailed in the table provided in Enclosure 2 as described in Section I above.

o i

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Page 4 H. Confirm the applicability of BWROG topical reports that address PRNMS and associated instability functions, set points and margins.

The BWROG topical reports that address PRNMS and the associated instability functions, setpoints and margins are not applicable to this proposed license amendment. The applicability of these reports will be addressed in the future proposal associated with the implementation of the instability-related OPRM trips.

C. Provide plant-specific revised Technical Specifications (TS) for the PRNMS functions consistent with NEDC-32410, Appendix 11.

Revised TS for the PKNMS functions consistent with NEDC-32410P-A, Appendix 11 and NEDC-32410P Supplement 1 (except where noted in Section I of this evaluation) are provided in Enclosure 3.

D. Confirm that the plant specific environmental conditions are enveloped by the PRNMS equipment environmental qualification values.

As further discussed i.i applicable portions of the table provided in Enclosure 2, plant specific environmental conditions are enveloped by the PRNMS equipment environmental qualification values.

E. Confirm that administrative controls are provided for mhnually bypassing APRM/OPRM channels or protective functions, and for controlling eccess to the panel and the APRM/OPRM channel hypass switch.

The level and method of control of the APRM/O"RM channels is the same as for the current APRM channels. The APRM/OPRM channel bypass switch is located in the main control room and is under the direct control and supervision of a licensed operator. The bypass switch can not be accessed without the knowledge and permission of the licensed operator. The control room opnator's knowledge of TS requirements for operability of the APRM/OPRM channels, together with written guidance, provides adequate administrative controls for manually bypassing APRM/OPRM channels or protective functions, and for controlling access to the

. pan-1 and the APRM/OPRM channel bypass switch.

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F. Confirm that any changes to the plant operator's panel have received human i

factors reviews per plant-specific procedures.

A Iluman Factors review is part of the normal Fermi 2 design process and will be documented in a Design Verification Record Package that contains a Human Factors a

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- Enclosure I to l

NRC-97-0105 Page 5 Checklist. Part of this assessment will include a composite team of Operations,

- Reactor Engineering, and Plant Support Engineering personnel utilizing full size overlays at the simulator.

Ill. Related Changes Made Not Specifically Addressed in Sections I and 11 in general, changes have been saade to the TS to implement the APRM hardware changes. Both markup and retyped versions of the proposed changes are provided in. The structure of TS 3.3.1 actions was modified to make the distinction between trip system functional units and the new APRM channel based functional units.

The details regarding how the approved LTR guidance is implemented in the Fermi 2 TS is presented in applicable entries of the Enclosure 2 table. Several changes are discussed below that are not described in Enclosure 2.

A change was made to Surveillance Requirement 4.3.1.3 to clarify that the response time testing (RTT) is done only for applicable RPS functions. The associated Bases section further clarifies the source of RTT requirements as UFSAR Table 7.2-4. These changes clarify an earlier license amendment that relocated these requirements from the TS. The changes are made to improve clarity and do not change any TS requirements and, therefore, are not specifically addressed in the No Significant llazards Evaluation or Environmental Impact portion of this submittal.

A change was made to correct an error in the Table title header for tne first page of TS Table 3.3.6-2 (TS page 3/4 3-44). The change is made to improve clarity, is consistent with other portions of the TS, and does not change any TS requirements; therefore, it is not specifically addressed in the No Significant llazards Evaluation or Environmental Impact portion of this submittal.

NO SIGNIFICANT ll AZARDS CONSIDERATION EVALUATION Detroit Edison has concluded that the proposed changes to the Fermi 2 TS do not involve a Significant llazards Consideration, in support of this determination, an evaluation of each of the three criteria set forth in 10CFR50.92 is provided below.

For the proposed changes to implement the NUMAC-PRNM retrolit:

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NRC-97-0105 Page 6 1.

The proposed TS chances do not involve a sienificant increase in the probability or consequences of an accident previously evaluated, This proposed TS change is associated with the NUMAC-PRNM retrofit design.

The proposed TS change involves modificaticn of the Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) for equipment designed to mitigate events that result in power increase transients. The APRM system mitigative action is to block control rod withdrawal or initiate a reactor s m,

which terminates the power increase when setpoints are exceeded. The Rod Block Monitor (RBM) system mitigative action is to block continuous control rod withdrawal prior to exceeding the fuel design limits during a postulated Rod Withdrawal Error. The functional capability of the previous Recctor Coolant System Recirculation Flow control rod block trip functions have been incorporated into the modified APRM control rod block trip functions. The worst case failure of either the APRM or the RBM systems is failure to initiate mitigative action (failure to scram or block rod withdrawal). Failure to initiate mitigative action will not increase the probability of an accident. Thus, the proposed change does not increase the probability of nn accident previously evaluated.

For the APRM and the RBM systems, the NUMAC PRNM design, together with revised operability requirements (LCOs) and revised testing requirements (SRs),

continues to perform the same mitigation functions under identical conditions with availability comparable to the types of equipment that it replaces. Because there is no change in mitigation ftmetions and because availability of the functions is maintained, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

The pronosed TS chances do not crqate the nossibility of a new or different kind of accident from any accident previousiv evaluated.

The proposed changes involve modification and replacement of the existing power range neutron monitoring equipment, and modification of the setpoints and operational requirements for the APRM and RBM systems. These proposed changes do not modify the basic functional requirements of the affected equipment, create any new system interfaces or interactions, nor create any new system failure modes or sequence of events that could lead to an accident. The worst case failure of the affected equipment is failure to perform a mitigation action, and failure of this mitigative equipment does not create the possibility of a new or different kind of accident. The proposed change does not create the possibility of a new or ditTerent kind of accident from any accident previously evaluated.

• to NRC-97-0105 Page 7 -

3.

The oronosed TS changes do not involve a sienificantleduct in a marcin of La.feb'.

This proposed TS change is associated with the NUMAC PRNM retrofit design.

The NUMAC PRNM change does not impact reactor operating parameters nor the functional requirements of the power range neutron monitoring system. The replacement equipment continues to provide infomiation, enforce control rod blocks and initiate reactor scrams under appropriate specified conditions. The proposed change does not revise any safety margin requirements. The replacement APRMIRBM equipment has improved channel trip accuracy compared to the current system and meets or exceeds system requirements previously assumed in setpoint analysis. Thus, the ability of the new equipment to enforce compliance with margins of safety equals or exceeds the ability of the equipment which it replaces. The proposed change does not involve a reduction in a margin of safety.

Based on the above, Detroit Edison has detennined that the proposed amendinent does not involve a signincant hazards consideration.

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of ef0uents that may be released offsite. In addition, the proposed changes will not increase occupational radiation exposure and so do not involve a significant increase in individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications 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 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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- Enclosure 2 to NRC 97-0105 Page1-ENCLOSURE 2 FERMI 2 NRC DOCKET NO. 50-341 NRC LICENSE NO. NPF-43 REQUEST TO REVISE TECilNICAL SPECIFICATIONS FERMI 2 RESPONSE TO REQUIRED UTILITY ACTIONS J

.. to NRC-97-0105 Page 2 Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions.

Section No.

Utility Action Required

Response

2.3.4 Confirm that the actual plant configuration is included in the variations covered in The following LTR secoons provide design desenptions for this Report, and the configuration attemative(s) being applied for the replacement the existing and repiscement hardtvare for the Fermi 2 plant PRNM are covered by this report. Document in the plant specific licensing Existina Sys.

Replacement Sys.

submitralfor the PRNM project the actual current plant configuration of the APRMs 2.3.3.1.1-2 2.3.3.1.2-2 replacement PRNM, and document confirmation that those are covered by this RBM 2.3.3.2.1-1 2.3.3.2.2-1 report.

Flow Units 2.3.3.3.1-2 2.3.3.3.2-2 Rod Control 2.3.3.4.1-1 2.3.3.4.2-1 ARTS 2.3.3.5.1-1 2.3.3.5.2-1 Par.el Interface 2.3.3.6.1-1 2.3.36.2-2 For any changes to the plant operator's panel, document in the submittal the A Human Factors review is part of the normal design process human factors re.iew actions that were tPen to confirm compatibility with existi.b

. and will be documented in a Design Venfication Record plant commitments and procedures.

Package that contains a Human Factors Checklist. Part of this assessment will include a composite team of Operations, Reactor Engineering, and P! ant Support Engineering personnel utilizing full size overlays at the simulator.

3.4 As part of the plant specific licensing submittal, de util:ty should document the following:

The pre-modification flow channel configuration, and any changes planned Fermi-2 bas four separate transmitters on each of two (normally changes will be either adding two channels to reach four or no change Recirculation loops (8 total). No change is planned.

planned).

Document the APRM trips currently applied at the plant. If different from those APRM Neutron Flex Upscale (Setdown) Trip remains identified in this report, document the plan to change to those defined in this unchanged.

Reference:

Section 3.2.4 Report.

APRM Flow Biased Simulated Thermal Power-High and Neutron Flux - High trips will remain unchanged except fer their nomenclature and the AW implementation for single loop operation. The nomenclature is consistent with t;.0 LTR and these functions will be known as the APRM Simulated Thermal Power - Upscale Trip and the APRM Neutron Flux -

. to NRC-97-0105 :-

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Page 3 -

Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions

('

Section No.

Utility Action Required

Response

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.1 1

Upsca' Tnp.

Reference:

Seebon 3.2.5

~

e The APRM Downscale trip that is interic4ked with the IRM Upscale Trip and the Reactor Mode switch will be deleted.

Reference:

Secbon 3.2.6

)

The Non-coincidence Trip function (APRMS input only) that is implemented in the Refuel Mode Only wi!! be deleted.

Reference:

Secbon 3.2.7 The APRM Inoperative Trip remains unchanged.

See table entry 8.5.6.1 for a similar discussion of the Rod Block functions.

Document the current status related to ARTS (or as not apphcable for BWR6 ARTS is current!y implemented and will be retained in the PRNM.

pk.nts), and planned post modification status.

4.4.1.11 This section identifies requirements that are expected to encompass most specifc (See specifc requirements hsted below) plant commitments relative to the PRNM replacement project, but may not be complete and some may not apply to all plants. Therefore, the utility must confirm that the requirements identified here address all of those identifed in the plant commitments. The plant specific licensing submittal should identify the specic 1

l requirements applicable for the plant, confirm that any clarifications included here apply to the plant, and document the specife requirements that the replacement PRNM is intended to meet for the plant.

lEEE 279-1971 Reouirements General Functional Requirement (IEEE 279 Par. 4.1)

LTR clanfcaton cpplies.

Single Facure Criterion (IEEE 279 Par. 4.2)

LTR clarification applies 9xcept for the discussion of "two flow channels" Fermi 2 has four f'ow channels.

Quality of Components and Modules (IEEE 279 Far. 4.3)

LTR clarifcation applies.

Equipment Quahfication (IEEE 279 Par. 4.4)

LTR clanfcation applies.

f Channel integrity (IEEE 279 Par. 4.5)

LTR clanication applies. For additiona. support information refer to the following responses in contailed this table :

4.4.2.2.1.4. 4.4.2.3.4 and 4.4.2.4.4.

.. to NRC-97-0105 Page 4 l

' Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Section No.

Utility Action Required 1

Response

ChannalIndependence (IEEE 279 Pa' 6)

LTR clanfication apples.

Contro! and Protection Systor, Interacu - (IEEE 279 Par. 4.7)

LTR clanfication applies.

Denvation of System loputs 'yEE 279 Par. 4.8)

LTR clanfication applies.

Capabihty for Sensor Checo (IEEE 279 Par. 4.9)

LTR clanfcabon applies.

l Capabety for lest and Ca!!bration (IEEE 279 Par. 4.10)

LTil clarifcabon app 8es.

Channel Bypass or Removat from Operation (IEEE 279 Par. 4.11)

LTR clarifcation appic.

Operating Bypasses (IEEE 279 Par. 4.12)

LTR clanfication applies.

Indication of Bypasses (IEEE 279 Par. 4.13)

LTR clanfcation applies.

Access to Means for Bypassing (IEEE 279 Par. 4.14)

LTR clarifcabon apphes. Fermi 2 administrative piccedures control access to the bypass controls.

j LTR c!anfication applies. Fermi 2 adm nistrative procedures Multiple Setpoints (IEEE 279 Par. 4.15) control adjustment of the Simulated Thermal Power setpoint values for operation with a single recirculation loop, in accordance with TS requirements.

Completon of Protective Action Once it Is initiated (IEEE 279 Par. 4.16)

LTR clanfication applies.

Manual Actuation (IEEE 279 Par. 4.17)

LTR clanfcation applies.

Access to Setpoint Adjustments, Cahbration, and Test Points (IEEE 279 LTR clarificabon apphes. Fermi 2 administrative procedures Par. 4.18) control access to setpoint and cahbration controls and test l

points.

Identification of Protective Actions (IEEE 279 Par. 4.19)

LTR clarification applies.

information Readout (IEEE 279 Par. 4.20)

LTR clanfication and discussion of the digital operator's display applies to Fermi 2.

System Repair (IEEE 279 Par. 4.21)

LTR clarifcation applies.

Identification (IEEE 279 Par. 4.22)

LTR clanfication applies.

l Other Requirements US NRC Reg. Guide 1.97-1980 LTR discussion applies.

US NRC Reg. Guide 1.152-1985 (Requirement for PRNM, not PRM)

Fermi 2 has no commitments to comply with Reg. Guide 1.152. Aowever, the PRNM modifcation complies as f

discussed ir. Appendix "A" in the LTR IEEE 7-4.3.2-1993 Fermi 2 has no commitments to comply with IEEE 7-3.4.2-I r

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U'..ity Action Required

Response

1993. Used as a guidance in the replacement design.

ANSI NQA 2 Part 2.7 Fermi 2 has no commitments to comply with ANSI NOA-2, Part 2.7. Used as a guidance in the replacement design.

US NRC Reg. Guide 1.75 Rev. 2 Fermi 2 has no commitments to meet Reg. Guide 1.75. Rev.

2. The UFSAR documents comparison of the plant design to Reg. Guide 1.75. Rev.1, and identifes and justifes areas where Fermi 2 plant design is not in full compliance with Reg.

Guide 1.75. Rev.1. Design Specification 3071-128-EV defines the requirements for separation of cables, raceway and equipment in order to ensure that sufficient isolation has been provided to assure that Class 1E circuits will not be affected by other circuits. The PRNM modification uses Reg.

Guide 1.75, Rev. 2 as a guidance. To the extent that the PRNM modification affects interfaces between Class 1E circuits and others, the Design Specification 3071-128-EV will be updated / posted as part of the design process confirming that the PRNM modifcation provides the isolation mcessary to assure no detrimental affect on safety.

Other US NRC Reg. Guides Reg. Guide 1.22, Rev. O Replacement PRNM meets Fermi 2 UFSAR commitments.

Reg. Guide 1.29, Rev. 3 Replacement PRNM meets Fermi 2 UFSAR comrntments.

Reg. Guide 1.47, Rev. O UFSAR commits an attemative method to Reg. Guide 1.47.

The attemative method commitments are met by the PRNM.

Reg. Guide 1.53, Rev. O Replacement PRNM meets Fermi 2 UFSAR commitments.

Reg. Guide 1.63, Rev. 2 PRNM mod;fication Goes not impact areas addressed in this Reg. Guide, so UFSAR commitments are unaffected.

Reg. Guide 1.68, Rev. 2 PRNM modification does not impact areas addressed in this Reg. Guide, so UFSAR commitments are unaffected.

Reg. Guide 1.70, Rev. 3 UFSAR changes raquired to document the PRNM modifmation will be implement 3d using the current format, so the current UFSAR commitments for this Reg Guide are E-

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.- to NRC-97-0105 Page 6 Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Section No.

Utility Action Required

Response

. unaffected.

Reg. Guide 1.105, Rev.1 Instrument setpoint calculatons for the PRNM will be performed using the current methodology, so the current UFSAR comrnitments for this Reg Guide are unaffected.

Reg. Guide 1.118. Rev. 2 Replacement PRNM meets Fermi 2 UFSAR commitments.

Other IEEE Standards IEEE 336-1971 The PRNM mC6fication will be installed and test requirements established in accordance with current Detroit Edison Procedures, so the PRNM modification meets Fermi 2 UFSAR commrtments related to this standard.

IEEE 33E-1971 Replacement PRNM meets Fermi 2 UFSAR commitments.

IEEE 379-1972 Replacement PRNM meets Fermi 2 UFSAR commitments.

IEEE 384-1974 Replacement PRNM meets Fermi 2 UFSAR commitments.

4.4.2.2.1.4 Plant specific action will confirm that the maximum control room temperatures plus Pei UFSAR Table 3.11-5 Section 5 (Main Control Room).

mounting panel temperature rise, allowing for the heat load of the PRNMS Relative Humidity = 60% (max) which is less than 90% (Non-equipment, does not exceed the above temperatures, and that the control room condensing) humidity is maintained within the above limits. This evaluation will normal'y be Temperature (min) = 60 F is greater than 41'F accomplished by determining the operating temperature of the current equipment Temperature (max) = 120*F is less than 122'F which will be used as a bounding value because the heat load of the rep'acement Design Calculations DC 4321 Vol. I and DC 4322 Vol. I will be system is less than the current system while the panel structure, and thus cooling updated / posted as part of the normal design process to remains essentially the same.

reflect tne impact of the decrease in BTU /hr loading on panels P608 and P603. Because the temperature rise of the panels Documentation of the above action, including the specific method used for the decreases with the insta!!atiran of the new PRNM equipment required confirmation should be included in the plant specific licensing and since the new PRNM equipment is enveloped to functon submittal.

within the current contros room environment, there is no impact or change to the control room (control center) environment as desenbed in the UFSAR.

4.4.2.2.2.4 Plant specific action will confirm that the maximum control rcom pressure does not Per UFSAR Tabte 3.11-5 Secton 5 (Main Contre' Room) exceeo the above limits. Any pressure differential from inside to outside the Pressure = 0.1 inches to 0.5 inches H O gage static pressure 2

mounting panel assumed to be negligible since the panels are not sealed and there The PRNM electronics is qualified for continuos operation

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d is no forced coohng or ventilation. Documentation of *his action and the required under these conditions.

confirma*jon should be included in the plant specifu 09ns!ng submittal.

4.4.2.2.3.4 Plant specific acbon will confirm that the maximum control room radWoon levM3 do Per UFSAR Table 3.11-5 Sectron 5 (Main Control Room) not exceed the above limits. Documentation of this action and the required

' Dose Rate = SE-4 Rads /hr less than 1E-3 Rads /hr confirmation should be included in the plant spectfic licensing submittal.

Total Integrated Dose (TID) = 1.75E2 Rads less than 1E3 -

Rads Therefore, the maximum control room radiation levels do not exceed the limits as defined in the LTR.

4.4.2.3.4 Plant specific action or anafysis will confirm that the maximum seismic The OBE and SSE values for Fermi-2 are identified in Detroit accelerations at the mounting locations of the equipment (control room floor Edison Letter EF2-55599, Supplement 1, " Floor Response acceleration plus panel amplification) for both OBE and SSE spectrums do not Spectra and "rivelopes-Reactor Auxiliary Building and RHR exceed the above limits. Documentation of this action and the required Complex", d_A Feb. 25,1982. Design Calculation DC-5721 confirmation should be included in the plant specific licensing submittal.

Vol. I will be prepared as part of the normal design process to refect the relay room acceleration plus any panei amplification fcr both the OBE and SSE spectra to ensure that they do not exceed the values specified in the LTR.

~ 4.4.2.4.4 The utility should establish or document practices to control emissions sources, The PRNM equipment qualification levels documented in the maintain good grounding practices and maintain equipment and cable separation.

LTR meet or exceed the recommendations in EPRI Report The plant specific licensing submittal should identify the practices that are in No. TR-102323, with the exception of the Bulk Cable injection place or will be applied for the PRNM modification to address each of the items test. The PRNM rep!acement equipment was tested to MIL' below.

Standards 461D and 462D, specifically Test CS-114. The frequency and magnitude values rucified in the EPRI report exceed tN MIL standard values.

The levels established in the EPRI report are based on data from several plants, including actual measurement at GE BWRs of similar design. Fermi 2 has no history of significant

' performance problems in electroaic equipment and has no indication of an abnormally harsh EMI environment.

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Therefore, it is reasonable to conclude that the actual EMI environment at Fermi 2, particularty that in the cor trol room, is within the limits documented in the EPRI report The PRNM equipment is part of the GE NUMAC line of nuclear instrumentation. This equipment is specifically designed for nuclear power plant applications, including consideration for the EMI environment typically found in BVd1 power plants. Similar equipment has operated in more than 50 power plants world wide since 1986, with cumulative operating history of nearly 3000 unit-years Tb iincludes Main Steam Line Radiation Monitor chassis ano a Rod Worth Minimizer at Fermi 2 operating without any EMI related problems or malfunctions since 1986 and 1991, respectively.

The only problems reported that may have been EMI related was abnormal display computer operation in a few units due to electrostatic discharge, and some early power supply failures that may have been due to AC power line transients, ne*her of which have occurred at Fermi 2. There have been no reported cases of NUMAC equipment causing interference with other equipment To resolve the electrostaMc discharge problems, the NUMAC standard design was modified to improve the integrity of chassis grounding, and ESD qualification was added. No ESD related problems have been reported since those changes. In addition, the PRNM chassis design includes further improvements to reduce susceptibihty to a'l types of EMI.

To resolve the power supply susceptibility, improved transient suppression was added at the power supply input and the

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power supply was rep! aced with a newer power supply, specifca!!y desigced for the NUMAC application, and with greater inherent immunity. Since those changes, no field failures have been identified at any plant.

Many of th3 curremtly L,,erating applications of NUMAC in BWRs are functions with considerably more sensitive signal input characteristics than the PRNm.

.J e/C.

' er design w

that is known to have less EMI tolerance than the PRNM design. Therefore, based on the overall field experience with NUMAC instruments, the specirc expenence at Fermi 2, the improvements in the EMI resistance of the NUMAC PRNM compared to much of the earlier equipment, and the severe qualifcation levels to which the PRNM has been quahfied, it is reasonable to conclude that there is signifcant margin between the Fermi 2 EMI environment and the EMI susceptibility level of the PRNM equipment.

Finally, the NUMAC PRNM will be installed in the same cabinets as the current analog PRM equipment. The carrent equipment is known to be more sensitive to EMI than the NUMAC digital equipment, but has operated without any identified EMI proolems since ini*ial power operation of Fermi

2. The current design also includes switching power supplies of an early design, and analog flow processing hardware.

The replacement PRNM will be the only equipment in the PRNM enclosure.

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1) Controlling Emissions a)

Portable transceivers (walkle-talkles): Establish practces to prevent The qualifcation levels used for the NUMAC PRNM exceed operation of portable transceivers in close proximity of equipment sensitive to those expected to result from portable transceivers, even if such emissions.

such transceivers are operated immedstely adjacent to the NUMAC equipment. However, Detroit Edison also has in place procedures prohiDiting operation of portable transceivers in the control room and near sensitive equipment, including waming signs at entical locations throughout the olant.

b)

ARC Welding: Establish practices to assure that ARC welding activities The quahfication levels used for NUMAC PRNM minimize the do not occur in the vicinity of equipment sensitive to such emissions, particularly likelihood of determinable effects due to ARC welding as long during times when the potentially sensitive equipment is required to be as reasonable ARC welding control and shieloing practces operational for piart safety.

are ut.mi. ARC welding is only performed at Fermi 2 with specifc work orders and directions, and is known to have the potential to affect operation of I&C equipment at e number of locations in the plant. Therefore, ARC welding activity is only performed when any potential affect on ISC equipment is tolerable relatn,e to plant operation.

c)

Limit Emissions from new equipment: Establish practces for new Formal quahfication of the PRNM equipment includes equipment ared plant modifications to assure that they either do not produce emissions testing. In addition Fermi 2 has established a unacceptable levels of emissions, or installation shielding, filters, grounding or Plant Engineering Practice Standard applicable to digital other methods prevent such emissions from reaching other potentially sensitive conversions and modifications. This standard has specife equipment. These practices should address both radiated emissions and reouirements to assess electromagnetic compatibility conducted emissions, particularly conducted emissions on power lines and (including radiated and conducted errissions), and includes power distribution systems. Related to power distribution, both the effects of specific guidance on insta!!ation and design practices to new equipment injecting noise on the power system and the power system minimize both the susceptibility of the new equipment and the conducting noise to the connected equipment should be addressed.

effects of the added equipment on previously installed equipment.

' Enclosure 2 to NRC-97-0105

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2) Groundir:g Practices a)

Ex55[ng Grounding System: The specife details and The PRNM equipment is being instaHed in place of existng effectiveness of the original grounding system in BWRs varied signifcantly.

PRM electronics which is generally more sensitive to EMI As a part of the modification process, identify any known or likely problem than the NUMAC equipmer;t Because the plant has areas based on previous experience and include in the modifcation experienced no signifcant problems with the PRM, no program either an evaluation step to determine if problems actually exist, or problems are antel ated with the PRNM provided grounding include corrective acton as part of the modification.

is done in a comparable manner.

The re placement PRNM will interface with the same cabies and wiring at the panet interfaces, including ground bus connechons, as does the current system.. No problems have been identifed in the current PRNM related to groundtng or grounding practces. The original installation included specife grounding practces designed to minimize performance problems The replaceme: ' PRNM design is less sensitive to grounding issues than is the current system and will include specific actions in the wiring inside the panel to mannize shielding and grounding effectweness.

b)

Grounding Practices for new Modifications: New plant modifcabons NUMAC PRNM equipmer't quahfcation is performed in a process should include a specific evaluation of grounding methods to be panel assembly comparable to that used in the plant.

used to assure both that the new equiprnent is installed in a way equivalent to the conditions used in the qualification.

See response to ic above.

3) Equipment and Cable Separation a)

Cabling: Establish cabling practices to assure that signal cables with the The original PRM cable installabon requirements met this potential to be

• receivers" are kept separate from cables that are sources objective. The replacement PRNM uses the same cable of noise.

routes and paths, so unless some specife problem has been idenbfied in the current system, no special action should be

.~

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necessary for the PRNM rnodification.

No specific problems have been identfied with the current system.

b)

Equipment: Estabhsh equipment separaton and shielding practices for The original PRM cabinet desen met this objective. The the insta!!ation of new equipment to simulate that equipment's quahfication replacement PRNM uses the same mounting cabinet, and condition, both relative to susceptibihty and emissions.

used an equivalent nr ntir.g assembly for quahficaton. No special action should be necessary for the PRNM modification.

6.6 The utility must confirm apphcabihty of the above conclusions by:

1) Confirming that the events defined in EPRI report No. NP-2230 or Appendices The analysis in Ref.11 of the LTR evaluated the effects of F and G of Reference 11 encompass the events that are analyzed for the plant, surveillance frequency of RPS and RPS inputs on calculated RPS failure frequency. Considered in the evaluation were anticipated transients (based on EPRI Report No. NP-2230),

and unanticipated transients (events of sufficiently low frequency so that they have insignificant contribution to RPS failure frequency). Events are divided into more severe transients that require immediate scram (Appendix F), and less severe transients which do not require immediate scram, or may not even reach scram limits (Appendix G). Appendix G also discusses infrequent events, but these are not specifically listed.

The transients evaluated in Fermi 2 UFSAR Chapter 15 are included in the transients identifed in Appendix F or G of Ref.

11 to the LTR. or are encompassed by those considered

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based on the definitions in EPRI NP-2230, or are either -

infrequent events or do not require scram. For completeness, those in the latter two categories (infrequent events or no scram required) are identified below-15.4.7 Misplaced Bundle Accident (no scram required) 15.4.9 Control Rod Drop Accident (infrequent event) 15.6.2 Instrument Line Break (infrequent event, but also encompassed in other assumed transients, depending on the specific break) 15.6.4 Steam System Piping Break Outside Containment (infrequent event) 15.6.5 LOCA inside containment (infrequent event -

discussed in Appendix G) 15.6.6 Feedwater Line Break Outside Containment (infrequent event) 15.7.1 Failure of Main Turbine Steam Air Ejector Lines (no automatic scram required) 15.7.3 Hypcihetica! Liquid and Solid Radwaste System Accident Analysis (no scram required) 15.7.4 Fuel-Handling Accident (no scram required) 15.10 Intemal and Extemal Events (no scram required or encompassed by other analysis) 15.11 Failure of Gaseous Radwaste Systems (no scram required) 15.12 Malfunction of Turbine Gland Sealing System (no scram required) 15.13 Shutdown Cooling Malfunction Decreasing Temperature (encompassed by loss of Feedwater Heating Transient) 15.14 Loss of Service Water System (infrequent event) 15.15 Loss of One DC System (no scram required) i I

A.

c

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in addrbon to the above, the Fermi 2 UFSAR evaluates Turbine Trip and Generator Trip assuming the turbine bypass is failed, thus combining the " Trip with bypass' and

• Trip without Dypass" transients. Trip with typass is direct!y addressed (Appendix F of Ref.11 in LTR). Trip without bypass is included in EPRI NP-2230. but is identifed as an infrequent event. Therefore, the analysis considered in the LTR encompass the Fermi 2 anatyzed transients for Generator Trip and Turbine Trip.

2) Confirming that the configuration implemented by the plant is within the limits Fermi 2 configuration is within the variation 3 addressed in the described in this report, and LTR. See item 2.3A for specific configuration.

~

3) Preparing a plant specific 10CFR50.59 evaluation of the modifcation per A Fermi 2 specife 10CFR 50.59 evaluaton win be prepared applicable plant procedures.

as part of the design change process.

These confirmations and conclusions should be documented in the plant specific licensing submittal for the PRNM modification.

7.6 The specifc action required will vary between plants. In all cases, however, Applicable sectons of the UFSAR will be reviewed and existing FSAR documents should be reviewed to identify areas that have appropriate revisions of those sections wi!! be prepared and descriptions specific to the current PRM using the general guidance of paragraphs approved as part of the normal denp process. Fo!!owing 7.2 through 7.5 to identify potential areas impacted. The utility should include in the implement. con of the design modifcation, and closure of the plant specific licensing submittal a statement of the plans for updating the plant design package. the UFSAR revisions will be reflected in the

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FSAR for the PRNM project.

UFSAR as part of the routne update submittal.

8.3.1.4 Delete the APRM Downscale function, if currently used, from the RPS The APRM downscale functon is currently used at Fem 42 as Instrumentation "func*>on" table, the related surveillance requirements and if an interta with the IRM upscale function. However, this appitcable the related setpoint, and related descriptions in the bases sechons.

function is not part of TS Table 2.2.1-1. No changes are required to TS kble 2.2.1-1. Table 3.3.1-1. Table 4.3.1.1-1, or associated Bases in order to delete this funchon Delete the APRM Flow biased Neutron Flux Upscale funcbon, if currently used, The Fermi 2 plant uses the APRM Flow-Eased Simulated from the RPS Instrumentation " function" table, the related surveillance Thermal Power - High function rather than the Flow-Biased requirements and if applicable the related setpoint, and related descriptions in the Neutron Flux-Upscale function. Simulated Thermal Power-bases sectons. Replace these with the corresponding entries for the APRM Upscale and Neutron Flux - Upscale APRM functions have Simulated Thermal Power-High and the APRM Neutron Flux-High functions.

been retained with a nomenclature change consistent with the Peiform analysis necessary to establish setpoints for added trips.

LTR in TS Table 2.2.1-1 (setpoints), Table 3.3.1-1 (functons).

Table 4.3.1.1-1 (SRs), and associated Bases (B2.2.1.2 &

B3/4.3.1).

Add the APRM Neutron Flux-High (Setdown) function, if not currently used, to the The APRM Neutron Fiux - High (Setdown) functon is RPS Instrumentation " function" table, add the related surveillance requirements currently used at Fermi 2, so it does not need to be added to and if applicable the related setpoints, and related descriptions in the bases the tables and associated Bases. No changes have been

~

sections. Perform analysis necessary to establish setpoints for added trips.

made to the setpoints.

NOTE:

Fermi 2 TS terminology for the APRM funciens:

Simulated Thermal Power-Upscale Utilities may choose to retain existing

• names" for the APRM functions or use Neutron Flux - Upscale slightly different ones. The submittal should identify names that will be used if Neutron Flux - Upscale (Setdown) different from those in this report.

Inoperative 2-out-of-4 Trip Voter The ~2-out-of-4 Voter" pseudo functon has been added to TS Add a "2-Out-Of-4 Voter" pseudo function to the RPS Instrumentation " function' Table 2.2.1-1 (setpoints). Table 3.3.1-1 (functions), Table table.

4.3.1.1-1 (SRs), and associated Bases. The setpoints in Table 2.2.1-1 are designated 'NA." A description of what conshtutes a LOGIC SYSTEM FUNCTIONAL TEST for this function has been provided in TS 4.3.1.2.

L

o

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Modify the Bases desenptons of the APRM Inop. function as needed to reflect the The APRM Inop functon TS bases remain unchanged as a replacement PRNM system.

result of the replacement confiouration.

8.3.2.4 For the 4-APRM channel replacement configuration, revise the RPS TS Table 3.3.1-1 (Funcbons) has been revised to reflect the Instrumentation

• function

• table to show three APRM channels, shared by both tnp 4-APRM channel replacement configuration. The 2-out-of-4 systems for each APRM function shown (after any additions or deletions per Voter function has been added to TS Table 3.3.1-1 Paragraph 8.3.1.4). Add a 2-out-cf-4 Voter fur.ction with two channels under the (Functions) with minimum 2 channels operable per tnp

" minimum operable channels". For plants with Tech Specs that include a footnote system, four total. Note (k) has been added to TS Table calling for removing shorting links, remove the references to the footnote related to 3.3.1-1 to indicate that each APRM channel provides input to APRM (retain references for SRM and IRM) and delete any references to APRM both trip systems. TS Table 3.3.1-1 was also revised to show channels in the footnote. For smaller core plants, delete the notes for and a minimum of three APRM channels being shared by both trip references to special conditions related to loss of all LPRMs from the "other" systems. Reference to the APRM has been removed and APRM.

references to IRM and SRM have bes,. retained related to removing shorting links in Table 3.3.1-1 Note (d). TS Table 3.3.1-1 Note (e) is applicable to the replacement canfiguration and has been relocated to the Bases secton Fermi'!is not a small core plant.

Review action statements to see if changes are required. If the improvements improved Technical Specifcatons have not been documented in Reference 11 have not been implemented, then changes will hke!y implemented for Fermi 2 at this time. TS 3.3.1 action be required to implement the 12-hnur and 6-hour operation times discussed above statements have been revised to reflect the replacement.

for fewer than the minimum required channels. If !mproved Tech Specs are configuraten. TS 3/4.3.1 action statement a was reworded applied to the plant, action statements remain unchanged.

slightly different from the LTR to clarify the intent. Other acbon statements have been revised to reflect the new APRM functions (TS 3.3.1).

Revise the ' Bases" section as needed to replace the descriptions of the current 6 TS Bases 82.2.1.2, B3/4.3.1, and B3/4.4.1 have been revised or 8 APRM channel systems and bypass capability with a corresponding to reflect the replacement configuration. Additional description of the 4-APRM replacement system with 2-out-of-4 output voter clarification beyond the LTR was provided in the TS Bases channels (two per RPS trip system), and allowed one APRM channel bypass total.

83/4.3.1 8.3.3.4-1 APRM Neutron Flux-High (Setdown)

The Neutron Flux - Upscale (Setdown) functon speofed in Change Tech Spec

• applicable modes" entry, if required, to be Mode 2 (start-up).

TS Table 3.3.1-1 shows applicabihty in Mode 2 and Delete references to actions and surveillance requirements associated with other references to actions and SRs in other modes have been modes. Delete any references to notes associated with "non-coincidence

• mode removed from the table. There are no notes associated with -

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and correct notes as required. Revtse Bases descnptions as required.

the non. coincidence' mode. Note (k) has been re$ded to Table 3.3.1-1 to reflect that each APRM channet provides input to both trip systems. Bases 82.2.1.2 and B3/4.3.1 have been revised to reflect the APRM Neutron Flux + Upscale (Setdown) replacement configuration.

8.3.3.4-2 APRM Simulated Thermal Power-High The APRM Simulated Thermal Power - High function remains Retain as is unless this function is being added to replace the APRM Flow biased unchanged except for its nomenclature and AW Neutron Flux Trip. In that case, add requirement for operation in Mode 1 (run) and implementation for single loop operation. TS Table 3.3.1-1 add or modify Bases descriptions as required.

reflects Mode 1 applicabihty, and the Bases (B3/4.3.1) have been changed to reflect that the APRM Simulated Thermal Power Trip is credited and that performance characteristics and response times are checked for the function. Based section B2.2.1.2 has been updated to reflect the new nomenclature and AW.

8.3.3.4-3 APRM Neutron Flux-High The APRM Neutron Flux - t!pscale funcbon is retained as Retain as is unless this function is being added to replace the APRM Flow biased before in TS Table 3.3.1-1. The operable channels Neutron Flux Trip. In that case, add requirement for operation in Mode 1 (run) and information has been changed to ref' rect the replacement add or modify Bases descriptions as required.

channel architecture. Bases sections 82.2.1.2 and B3/4.3.1 have been revised consistent with the LTR.

8.3.3.4-4 APRM Inop TS Table 3.3.1-1 Item 2.d has been revised to remove all Delete any requirements for operation in modes other than Mode 1 and Mode 2 modes except 1 and 2 including the associated actions from (run and start-up). Revise the Bases description as needed.

the APRM Inoperative functional unit. The Bases section remains unchanged.

8.3.4.1.4 For plants without Channel Check requirements, add once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Channel The Fermi 2 TS Table 4.3.1.1-1 includes a Channel Check Check or Instrument requirements for the three APRM flux based functions. No column. The channel check requirements for Neutron Flux -

Channel Check requirements are added for the APRM Inop function. Plants with Upscale (Setdown), Simulated Thermal Power - Upscale, once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once per shift requirements may change them to once per day, and Neutron Flux - Upscale have been changed from once per shift to once per day. The APRM -Inoperative funebor*

2.d remains *NA."

For Plants with four full recirci bn flow channels and with Tech Specs that call for TS Table 4.3.1.1-1 did not contain charinel check daily or other channel check requirements for ficw comparisons under APRM Flow-requirements for flow comparison under the APRM Flow biased Simulated Thermal Power Trip, delete those requirements. Move any note Biased Simulated Thermal Power - High trip. Footnote (e) for

. to NRC-97-0105 Page 18

' Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Section No. '

Utility Action Required Response-reference re!ated to venfication of flow signats to Channel Functional Test entry.

the weekly tnp cnannel cabbrabon, which referred to conformance with a calibrated flow signal, was removed. A new footnote (e) was added for another purpose Note (l) has been added to TS Table 4.3.1.1-1 for the Simulated Thermal Power 'Jpscale function to state that the channel functional test include the flow input function excluding flow transmitters.

8.3.4.2.4 Delde existing channel functional test requirements and replace wrth a requirement The existing functional test requirements were deleted and for a Channel Functional Test frequency of every 184 days (6 months) (delete any replaced with a semi-annual ("SA*) requirement, including the specific requirement related to start-up or shutdown except for the APRM Neutron 2-out-of-4 Trip Voters.

Flux-High (Setdown) function as noted in Paragraph 8.3.4.2.2 (1) above]. Add a notation that both the APRM channels and the 2-out-of-4 voter channeis are to be TS Table 4.3.1.1-1 Item 2_a, note (m) has been added included in the Channel Functional Test.

consistent with the LTR to clarify when cnannel funcbonal Add a notation for the APRM Simulated Thermal Power-High function that the test tests are performed for mode changes.

shall include the recirculation flow processing, excluding the flow transmitters.

CAUTION *,

Note (I) has been added to TS Table 4.3.1.1-1 for the Simulated Thermal Power - Upscale function to state that the Plants that have not irnplemented the APRM surveillance improvements of channel functional test include the flow input function, Reference 11 [NEDC-30851P-A, "TS Improvement Analysis for BWR P.PST or excluding flow transmitters.

those that have continued to use weekly surveillance of some portion of the APRM functions to accomplish a weekly surveillance of scram contactors, may need to For Fermi 2, the scram contactors are tested weekly as part implement or modify surveillance actions to continue to provide a once per week of the manual scram functional test (TS Table 4 3.1.1-1, item functional test of scram contactors. (Prior to changes defhed in Reference 11, the 12).

weekly APRM functional test also provide a weekly tett of all automatic scram contactors.)

The functional test procedure will be established to test all of the hardware required to produce the trip functions, but not to directly re-test software controlled logic. The automatic self-test logic monitors the integrity of the EPROMs storing all of the firmware so that if a hardware fault results in a

• change

• to the software (firmware), that a fault will be ddtected by the self-test logic. The continued operation of the self-test procedures is monitored by the built-in " watch-dog timer" function, so if for some unforeseen reason the self-test

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I i funcbon powest pnoaty en the estnrneint logic) stops runneg.

that fadure w4 be detected autwns'uci=V. Hca-r, to pro % furt!'er assurance that some unforeseen failure does not result in loss of the automabc self-test funcbon, a step wiR be included in the daily APRM Channel check survei5ance to confirm that a self-test is sb5 runneg The APRM Channei Cneck surves.< w wG also include a step to confirm that the RBM self-test is sbH runneg smce the RBM hardware pedw n o the recrculation flow companson checks A suses.E ce findog that the self-test is not cpeistag in both RBMs (means the recrculabon flow w1yi.ow, functon is not available) wiH not autunsiscs!!y result in any ARF NI channel being deck ed inoperabie, but ws s*sult in an increased rate of" flow cc.T.p cocn* manual surves!!ances The flow cwivaimon survestlance win be pedvind f.!

nommatty hourly frequences to wicw.d to the self-test frequenoes assumed in the unavailabihty analyss for the PRNM system.

8.3.4.3.4 Replace current cahbration interval with either 18 or 24 months except for APRM The channel cahbrabon interval for att APRM funcbons Inop. Retain APRM inop requirement as is (i e. no requirement for cahbrahon).

(except for APRM - Inop and 2-out-of4 tnp voters, which are NA) has been chc=,ved to 2 years in TS Table 4.3.1.1-1.

Delete am Nuirements for flow cahbrabon and cahbrabon of the 6 second 2:me constant separate from overan calibrabon of the APRM Simulated Thermal Power-Footnote (h) retabng to the 6 second time constant has been High funcbon.

deleted from TS Table 4.3.1.1-1.

Replace the every-3-day frequency for cahbration of APRM power against thermal The exisbng weekly cahbration of APRM aganst thermal power wdh a 7-day frequency if applicable.

power has been retained in TS Table 4.31.1-1 in item 2b and Revise Bases text as required.

footnote (d).

TS Bases 82.2.1.2 has been revised to be consistent wth the

~

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LTR gudance 8.3.4.4.4 Delete the response tme tesbng requirement from the Tech Spec or plant Ferrrn-2 response tme tesbng (RTT) requke.nent, am procedures as appicable, for APRM funcbons Replace it with a response time presentfy contro0ed in Table 72 4 of the UFSAR and testing requirement for the 2-out-of-4 Voter" pseudo

• funcbon to include the output Tigleirsded by plant procedures. The RTT frequency wiD i

solid state relays of the voter channel through the final RPS tnp channet tactors be the same as the calibrabca frequency (24 months). In conjuncbon with the APRM t dwaia change and License j

Frequency of response time testing shan be detemm(-d using four 2-out-of-4 voter Airsdne 4. the UFSAR wd! be cisnyi-d to kK,cipviate channels, but tests may attemate use of 2-out-of-4 voter outputs prevded each requken wds for RTT of the 2-out-of4 voter trip channels, APRM/RPS interfadig relay is tested at least once per eight refuehng cyclas includir g the output sold state relays of the voter channel (based on a maximum 24 month cycle), and each RPS scram ccih.tv is tested at through the final RPS tnp channel contactors.

least once per fou* refueling cycles. Each 2-out-of-4 voter output shan te tested no less than half the frequency of the tests of the APRM!RPS interface relays. Tests There wdl be no RTT requien Ent= associated with the shal; attemate such that one logic train for each RPS trb system is tested every indivdual Simulated Thermal Power-Upscale, Neutron Flux -

two c' cles.

Upscale, or Neutron Flux - Upscale (Setdown; trip functons.

y SRs and Bases ha e ',ecn revtsed to le consistent with the LTR guidance 8.3.5.4 Revise Tech Specs to change the intervat for LSFT from 18 months to 24 months TS 4.3.1.2 for Logc System Funcbonal Tests (LSFT) has unless the uthty elects to retain the 18-month interval for plant scheduhng been revised to state that the APRM funcbons 2.a. 2.b. 2.c, purposes Delete any LSFT rc4airements associated with the APRM channels and and 2.d in TS Table 3.3.1-1 (all APRM funcbons except the 2-move it to the 2-out-of-4 voter channel. Include testng of the 2-oat-of-4 voting logic out-of-4 Tnp Voter) do not require separate LSFTs, and that a I

and any existng LSFTs covenng RPS relays.

LSFT shall be peife ined for funcbon 2.e (2-out-of-4 Tnp i

Voter) at least once every 24 months. TS 4.3.12 further states that the LSFT for funcbon 2.e includes s.muladng APRM tnp cundd,un. at the APRM channel inputs to the 2-out-of-4 Trip Voter channel to check all combinabons of two tripped inputs to the 2-out-of-4 Trip Voter logic in the voter channels.

8.3.6.1 Add to or delete trom the appiuprete docuraent any changed RPS setpoint ARTS has already been implemented, and is retained in the information. If ARTS is being implemented concurrently with the PRNM PRNM.

modification, either include the related Tech Spec submittalinformation with the PRNM information in the plant-specific submrttal, or reference the ARTS submrtta!

Existing RPS instrumentation se' point inte netui remains in the PRNM sdmittal. In the plant-scecific subrruttal sdentfy what de ges, if oncie ged and is provded in TS Table 2.2.1-1 and the 4

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Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Sectit n No. l Utikty Action Required l

.t :;--:-:.x i

any, are being ATeited and identify the bases or method used for the j assocated Bases (B2.2.12). Except for selected calculation of setpoints and where the setpoint in viu 6.cn or Gwges will be

~ im w-.cAvgy, the existng setyv.i's and E.witc3vivvy are recorded.

documented in desegn calcusabon DC-4608 Vol. I.

8A1A Add the OPRM Upscale funcbon as an "APRM funcbon"in the RPS To be ad@essed in a TS change sutmttal after RF06.

InstruireJ. ai *funcbon* table. Also add the related survei!!ance requawuwds a

and, if applicable, the related setpoint, and the related desc up^uv s in the bases secbons. Perform analysis necessary to estabfish setpoints for the OPRM Upscale Tnp. Add discussions related to the OPRM funcbon in the bases for the APR^JI

• Inop and 2-out-of-4 Voter funcbons Note: The markups in Appendix H of this supplement show the OPRM Upscale as an APRM sub-funcbon. However, individual plants may swim u.u.e that for their particular situation, additon of the OPRM to the RPS Instrumentaten table separate from the APRM, or as a separate Tech Spec better meets their need. In those cases, the basic elements of the Tech Spec as shown in this Supplement would remain, trst speofic implementation would be different.

8A.2A For the OPRM funcbons added (Seebon 8.4.1), include in the OPRM Tech Spec a To be addressed in a TS change sutmttal after RF06.

" minimum operable channels

• requirement for the three OPRM den ets, shared by both trip systems.

To be addressed a T5 change sutmttal after RF06.

Add the same acron statements as for the APRM Neutron Flux-High funcbon for OPRM Upscale fanchon in addebon, add two new acbon statements for OPRM Upscale funcbon unavailabie per Paragraph 8 4.2.2.

To be addressed in the Stability TS Sutmttal afte-RF06.

Revise the Bases secdon as needed to add desenptons of the 4-OPRM system with 2-out-of-4 voter channels (2 per RPS Trip system), and allowed one OPRM bypass total.

8A.3.4 Add the requiement for operabon of the OPRM Upscale funcbon in Mode 1 (run)

To be addrr.essed in a TS change sutmttal after RF06.

wher, Thermal Power is greater than or equal to 25% HTP, and add Bases desenabons as required.

I i

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8.4A.1 A Add once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or once per day Channel Check or Instrument Check To be addressed m a TS change subnutta! after RF06.

requirements for the OPRM Upscale functort 8AA.2.4 Add Channel Funcbonal Test requirements with a requirement for a test frequericy To be addressed in a TS change subrruttal after RF06 of every 184 days (6 months), meluding the 2-Out-Of-4 Voter functon.

Add a " confirm autoannable region" surveinance on a once per outage basis up to 24 month intervals.

_8A.4.3.4 Add cal:braton in;erva! requirement of every 24 rronths for the OPRM Upscale.

To be addressed in a TS change submittal a'ter RFOS.

Revise Bases text as required.

8.4.4A.4 Modify as necessary the response time testing procedure for the 2-Out-Of-4 Voter To be addressed in a TS change submittal after RF06 funcbon to include the voter OPRM output so!d state relays as part of the response time tests, attematmg testing of the voter OPRM output with the voter APRM output.

8.4.5.4 Add requirement for Logc Syster 1 Funcbonal Test every refueling cycle,18 or 24 To be addressad in a TS change submittal after RF06 months at the ut&ty's opton basr d on which best fits plant scheduhng.

8A.6.1 Add setpoint informadon to the appicpiiote document and identfy in the plant-To be addressed in e TS change submrtial a*ter RFOS.

specific submrttal the basis or method used for the calibration and where the setpoint informaton will be recorded-8.5.1 A If ARTS will be implemented concurrently with the PRNM m0GTe^uca, include or ARTS has already been implemented, and has been retarned reference those changes in the plant-specific PRNM submittal. Implement the in the PRNM.

applicable porton of the above desenbed changes via fruGra^uvis to the Tech Specs and related procedures and documents in the plant-specrfic submiital.

The Reactor Coolant System Recirculabon Flow funcbon has identfy functons currently in the plant Tech Specs which, if any, cierges are being been deleted from TS Table 4.3.6-1 in acx.vrdance with the implemented. For any funciens deleted from Tech Specs, idenbiy where setpoint drscussen in Secbon 5.5.1.2 of the LTR apphcable to ARTS and surveillance requirements wiu be documented. Note: A utaty may choose not piants. The APRM Rod Block funcbons, including the Flow-to delete some or aH of the stems identfed in this report from the plant Tech Specs, Upscale funcbon, win be retarned at this time.

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.- to NRC-97-0105 Page 23 Fermi 2 Respcnse to NEDC-32410P-A and Supplement 1 Required Utility Actions Sectum No.1 Utility Action Required

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8.5.2.4 Change the transmum number of APRM channels to three, if APRM funcbons are

' The APRM Rod B!o::k funcbons have been retamed in the TS.

retamed in Tech. Specs. No add:bonal acbon is required relative to rrunsmum

' TS Tabie 3.3.6-1 f.as been C=nged to reflect 3 rrurwnum operable channels beyond that required by paragraph 8.5.1.4.

Gww.eis operable for APRM funcbon 2.a through 2.e. The

Flow-Upscale red block was icini.ed and relocated as item 2.e.

8.5.3.4 No acbon required relatrve to modes dunng whch the funcbon must be avadable The APRM control rod block mstrtire J.uc, APRM functons beyond that required by Paragraph 8.5.1.4 above unless APRM funcbons are have been retained in the TS. The Mode 5.vui.usbddy has retained in Tech Specs and include operabdity requ;iernens for Mode 5. In that been deleted for a!! of the funcbons in TS Tabir 3.3 6-1 case, delete such requirements.

previously havmg Mode 5 isppk iehty (Items 2.b & 2.d), as well as for the v,.ccyce > dog survedlances in TS Table 4.3.6-1. The Flow-Upscale acoon statene-a was changed from "62* to 61* to be consstent with the other APRM rod block funcbon achon stoien.cnt since the flow funcbon is now part of the APRM chassis This change is also corsistent with the change in trarnmum number of des.w;s (3 versus 2 in current TS) for the Fhw Upscale funcbon This change is not addic= sed in the LTR.

8.5.4.1.4 Delete any requirements for instrument or channel checks related to RBM and.

The reorculabon flow funcbon has been deleted as desu 4.+J where cppleable, recirculation flow rod block furicbons (non-ARTS plants), and in 8.5.1.4 above. The APRM funcbons have been ici c.ed in APRM funcbo.is. Identify in the plant-specdic PRNM subrnsttats if any checks are TS Table 4.3.6-1 including reincoli, of the Flow-Upscale currently included in Tech Specs, and confirm that they are being deleted.

funcbon. The channel checks that have been changed from once per shift to "NK included the Simulated Thermal Power

- Upscale, Neutron Flux - Downscale, and Simdated Thermal Power-Upscale (Setdown) funcbons The channel check requien cnia for the RBM remain "NA*. These dion e= arc v

u,is.= lent with the LTR guidance 8.5.4.2.4 Change Channel Functonal Test requirements to identfy a frequency of every 184 The APRM and RBM Channel Funct(, i Test frequenoes days (6 morths).

have been uw.ged to serra-annual (*SN) to be w h4 with the LTR guidance. The APRM funcbons that have been in the plant-specific PRNM subm:ttaf. identfy current Tech Spec test frequences dw.ged from quarterfy to semi.annuaity to include the that will be changed to 184 days (6 months).

Smiu!ated Thermal Power - Upscale, Neutron Flux -

Downscaic. Simulated Thermal Poer - Upscale (Setdown).

1

.~ to NRC-97-0105 Page24 Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Section No.

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I

' Inoperatrve and Flow-Upscale The RBM funcbons that have been Ce.yed from quarterfy to sern-a'inuaDy !.M the Upscale,lacw.bve and Downscale The furn, tun : test pmcedure will be established to tes* all of

' s the te-d-are required to produce the rod block funcbons, but not to drectfy re-test software controlled logic. The automate self-testlogic monitors the integnty cf the EPROMs stonno all of the L n<=.:e so that if a todweie fault results in a

• change

• to the sc:t-e (Ln, e), that a fault wtR be detected by the self-test logc. The conbnued Oper.'e of the automabc self-test funcbons is monstored by the bui!!-in

• watetx$og t:mer" funcbon, so if for some unforeseen reason the self-test funcbon (lowest pnonty in the insbynent logic)

?

stops running. that fadure wdi be detected autvin.=,.y.

_ 8.5.4.3.4 Change channel calebraton requirements to denhfy a frequency of every 24 The APRM and RB" Channel Card,.^ucri frequences J

months.

(excluding *lacpw1 'uve* functon which is NA) have beert 4

changed to 2 years, conststent with the LTR guidance. The In the plant-speofc PRNM submittal, identdy current Tech Spec test frequences APRM funcbons that have been chargj from semt-annually that will be changed to 24 months.

to 2 years include the Simulated Thermal Power - Upscale, Neutron Flux-Dc=ns, ie and Simulated Thermal Power-1 Upscale (Sctdown). The APRM and R2M funcbors that have been dew from quarterfy to 2 years irwAde APRM Flow-Upscale, RBM-Upscale and RBM-Oc.nsco:e.

8.5.4.4.4 None.

N/A.

8.5.5.4 None.

i N/A.

)L 8.5.6.1 Add to or delete from the appropnate document any proposed Gww d control rod

• ARTS is currently Anented and wdl be retained in the e

i block setpoint infomrtaten if ARTS is being ' nplemented concurrent!y with the PRNM.

u PRNM modifcation, either include the related Tech Spec sutxnttal inicn.Wuvis with the PRNM informaton in the plant-speofic submraal, or iefeience the A.RTS The Floe-Baased Neutron Flux - High funchen has been submittalin the PRNM subrmttal. In the plant-speofc sutxnttal,identdy what re$m ed by the Simulated Thermal Power - Upscale funcbon.

4 dianyes, if any, are being knpiernented and identdy the basis or method used for The setpoint Ocinenc.:ature has been Gior@d to reflect the 4

.- to NRC-97-0105 Page 25 Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Section No. l Utility Action Required

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calcidadon of setpoints and where the setpoint infe nisoon wdl be recorded.

f.W..wicnientaden for single loop opersuca The existng setpoint values and methodology have teen retained.

8.6.2 As appicable, revise the Shutdown Margin Testrng - Refuehng (or equrvaient Tech The Ferms 2 TS does not include the SWdown Margin Spec) LCO(s), acbon statements. surveinance requiren.cnts and Bases as required Testng - Refueling o. an equivalent TS. TIis item is not to be consistent with the APRM Tech Spec changes implemented for PRNM.

appicab:e.

9.1.3 As part of the plant-specife licensing submrtial, the utisty should document the The PRNM inOd.T.ei,un is being perfvin,ed under the estabhshed prog am thalis appfcable to the project mocificaten. The submrttal estabhshed Fermi 2 Quahty Assurance Program based on should also documenoor the project what s<: ope is being peg.ned by the utihty 10CFR50 Apperxb B. Replacement PRNM hardware, and what scope is being suppled by others. For scope suppled by others, software (Tu o -ore), instat!ation nardware, and inst. atert document the utility acbons taken or planned to define or estabhsh requirements for instructens are being prowdea by GE Nuclear Energy the project, to assure those requirements are compatble with the plant-specific Desgn work for the GE scope of work is being pede u eni confguration. Actions taken or p!anned by the uthty to asstue compatibihty of the under GE's Quality Assurance Program which has been GE quahty program with the utihty program should also be documented.

revewed and approved by Detroit Edison.

Uthty planned level of parbeipaten in the overau V & V process for the project Detroit Edison witi receive software in the form of"firmware*,

should be documented, along with ublity plans for software configuraten each part of which carries unique configuraten control management and provision to support any required changes after delivery should identtes This allows Detroit Edison to control the be documented.

configuraton at site using hardware configuraton control i

procedures. Detroit Edrson has no current plans to perform software nv3iin t v..s. It is expected that any software nu3.Tn.ouens, if needed, wi!! be provided by GE.

To assure compatbaty betwean the equipment and system scope provxied by GE and the Fermi 2 plant, Detroit Edison has established a contract which defines requirements, Detroit Edrson reviews, and Detroit Edison acceptance enteria. As part of the protect, Detroit Edison provides plant as-built configurabon documentaten to define interfaces, and performs review snd pproval actantes of GE prepored requirement spec,Tn tam, system elementary modificabons, digital equipment user interface specir.cduons, ard

. to NRC-97-0105 Page 26 Fermi 2 Response to NEDC-32410P-A and Supplement 1 Required Utility Actions Sectict: No, Utility Action Required

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wGnce test procedures. Multiple techncal revew meew95 nave been conducted at stages throughout the project, includrig requa en enL> defintton, licensing revnsws, aiv;en sntaten and final testing. Detroit Edrson prsonnel have partcipated in final vardaten and accepence testrig at GE facdrbes and conducted site acceptance testnig pnor to insta!!aton of the equipment.

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.-_ to NRC 97-0105 l

h ENCLOSURE 3 FERM12 NRC DOCKET NO. 50 341 NRC LICENSE NO. NPF-43 REQUEST TO REVISE TECilNICAL SPECIFICATIONS PROPOSED TECilNICAL SPECIFICATION CilANGES (MARKUP AND RETYPED FORMATS) l to NRC.974)l05 l' hcl'OSED TECilNICA1, SI'ECIFICATION CilANGES MARK UI' FORMAT l