Text

Application for Amend to License NPF-43,modifying Drywell Oxygen Monitoring Instrumentation Action Requirements to Be Consistent W/Those Contained in NUREG-1433,Rev 1, STS GE Plants,BWR/4
	ML20217P056
Person / Time
Site:	Fermi
Issue date:	04/02/1998
From:	Gipson D; DETROIT EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217P061	List: ML20217P063; NRC-98-0062, Application for Amend to License NPF-43,modifying Drywell Oxygen Monitoring Instrumentation Action Requirements to Be Consistent W/Those Contained in NUREG-1433,Rev 1, STS GE Plants,BWR/4;
References
	CON-NRC-98-0062, CON-NRC-98-62, RTR-NUREG-1433 NUDOCS 9804090302
	Download: ML20217P056 (14)
	v • d • e

,. ,

Douglas R. Gipwn

. Senior Vice l' resident, Nuclear Generation

(

Ferns 2 6400 North Dixie llwy., Newport, Michican 48160

., Tel:313.586.5201 Fax: 313.586.4173 l Detroit Edison 10CFR50.92 l 4

(

l- <

April 2,1998

NRC-98-0062 l

l U. S. Nuclear Regulatory Commission 3 Attention: Document Control Desk Washington D C 20555-0001

References:

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

]

2) NUREG 1433, Revision 1," Standard Technical Specifications General Electric Plants, BWR/4"

Subject:

Proposed Emergency Technical Specification Change (License Amendment) to Modify the Drywell Oxygen Monitoring Instrumentation Action Requirements to be Consistent with those Contained in NUREG 1433, Revision 1 " Standard Technical Soecifications General Electric Plants. BWR/4" Pursuant to 10CFR50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating License NPF-43, Appendix A, Technical Specifications (TS). Technical i Specification Limiting Condition for Operation 3.3.7.5, Table 3.3.7.5-1, Action 80 currently requires that "with the number of OPERABLE accident monitoring instrumentation channels less than the Required Number of Channels shown in Table 3.3.7.5-1, restore the inoperable channel (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." The proposed change increases the time allowed for a primary containment oxygen monitoring instrumentation channel to remain inoperable to 30 days, and requires a report within l the following 14 days discussing the results of the root cause evaluation and identifying proposed restorative actions, rather than a plant shutdown.

Detroit Edison is requesting that this license amendment request be processed as an

\\ g\

emergency Technical Specification change in accordance with 10CFR50.91(a)(5) to 0 i prevent a plant shutdown should troubleshooting and repair of a spiking condition on j

! 1

.n 9804090302 980402 PDR ADOCK 05000341 i P PDR ,

AIrfE Energy Company J

USNRC NRC-98-0062 Page 2 one channel of the Drywell Oxygen Monitoring System not be completed in the drywell inerted, and with one channel of the D power with the fully operable and the other channel functional but periodicallen M the interrelationship of the primary containment hyd of y spiking. Because oxygen monitoring system,ryitcontainment may be necessar to the primary containment hydrogen monitoring syst arreliefwith respect em in the future.

In support of this emergency license amendment request D t to a License Condition requiring the return ,

e roitofEdison the Di willi icommit oxygen monitoring instnunent to operable status prior to stv s on 2 primary this problem in camest during read as follows: .

thetointerim and attempt correct The sure ggested License Condition would 2,C (19) - DECO shall retum the Division 2 primary contai nment oxygen sixth refueling outage. monitoring subsystem ng the to operab Additionally, until the Division 2 primary containment oxy operable status, the monthly channel check of the Division 1 gen monito oxygen monitor will be validated with a grab sample.

primary containment Enclosure 1 provides a description and evaluation of the p Enclosure 2 provides an analysis ofroposed the TS issue change.ofsignificant h using the standards of10CFR50.92.azards Enclosure 3 provides th consideration e rationale for provides the marked up pages .

typed version of the affected TS pages with the pro a

. Enclosureof4 posed change and a the existing posed changes incorporated.

Detroit Edison has reviewed the proposed TS changes a involve a significant hazards ,

posed changes consideration do not nor do types or significantly increase the amounts of efflu ey significantly change the The proposed changes also do not significantly increase i di ident occupationalradiation exposures. Based on the foregoing D t n v ualorcumulative that the proposed TS changes ve meet the criteria pro id d i e roit Edison concludes

( categorical exclusion from the requirements for an Environn 10CFR51.22(c or an Environmental Assessment. mentalImpact Statement

~

i: l

s. .

l- USNRC E '

NRC-98-0062 Page 2 l .

one channel of the Drywell Oxygen Monitoring System not be completed in the currently required 7 days. The plant is currently operating at 96% power with the drywell inerted, and with one channel of the Drywell Oxygen Monitoring System.

L fully operable and the other channel functional but periodically spiking. ' Because of L the interrelationship of the primary containment hydrogen and oxygen monitoring

. systems, and to support troubleshooting of the Division 2 primary containment oxygen monitoring system, it may be necessary to ask for similar relief with respect to the primary containment hydrogen monitoring system in the future.

I' In support of this emergency license amendment request, Detroit Edison will commit l- to a License Condition requiring the return of the Division 2 primary containment.

oxygen monitoring instrument to operable status prior to startup following the next refueling outage. Of course we will continue to troubleshoot and attempt to correct this problem in earnest during the interim. The suggested License Condition would l l read as follows

! 2,C (19) - DECO shall retum the Division 2 primary containment oxygen l monitoring subsystem to operable status prior to startup following the sixth refueling outage.

Additionally, until the Division 2 primary containment oxygen monitor is restored to operable status, the monthly channel check of the Division 1 primary containment i

!. Oxygen monitor will be validated with a grab sample.

Enclosure 1 provides a description and evaluation of the proposed TS change.

Enclosure 2 provides an analysis of the issue of significant hazards consideration g using the standards of 10CFR50.92. Enclosure 3 provides the rationale for supporting an emergency change as described in 10CFR50.91(a)(5). Enclosure 4 L provides the marked up pages of the existing TS to show the proposed change and a E typed version of the affected TS pages with the proposed changes incorporated.

Detroit Edison has reviewed the proposed TS changes against the criteria of j 10CFR51.22 for environmental considerations. The proposed changes do not

')

involve a significant hazards consideration, nor do they significantly change the i types or significantly increase the amounts of effluents that may be released offsite.

The proposed changes also do not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes ,

?

that the proposed TS changes meet the criteria provided in 10CFR51.22(c) (9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

I s

l

. , a 3

y, -

USNRC-NRC-98-0062 Page 3 I

~ On March 30,1998 at 0825 hours0.00955 days 0.229 hours 0.00136 weeks 3.139125e-4 months , the spiking exceeded the predetermined level at which it was decided the Division 2 containment oxygen monitor would be declared inoperable. This placed the plant in a 7-day Limiting Condition for Operation (LCO L 3.3.7.5). The Action for this LCO, Table 3.3.7.5-1 Action 80, requires that the inoperable channel be restored to OPERABLE status within 7 days or be in at least

. HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .- Detroit Edison therefore requests that L the NRC approve and issue these changes by 0800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months on April 6,1998 with L' . implementation immediately following NRC approval.-

The following two commitments are being made in this letter:

1. The Division 2 primary containment oxygen monitoring channel will be returned to operable status prior to startup following the sixth refueling outage.

l L 2.' Until the Division 2 primary containment oxygen monitoring channel is restored -

to operable status, the monthly channel check of the Division 1 primary L 3 containment oxygen monitor will be validated with a grab sample.

l I'

Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.

I r

l Sincerely,

[ -

l l

h Enclosures L cc: A. B. Beach B. L. Burgess G. A. Harris

[ A. J. Kugler l Supervisor, Electric Operators, .

L Michigan Public Service Commission l'

l ls .

USNRC NRC-98-0062 i . Page 4 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.

DOUGLAS R.TilPSON Senior Vice President, Nuclear Generation l

On this M day of .1998 before me personally appeared Douglas R. Gipson, being first duly sworn and says that he executed the !

foregoing as his free act and deed.

1

-lU- L Notary Public N A. MM

, ROWWPUBUC.M0M0E 000m,MI l WO(ReimilWEXPWM10fl140 I

J

Enclosure 1 to l NRC-98-0%2 ,

Page 1 l i

I I

i l

1 l

I ENCLOSURE 1 l

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

j REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

I i

l Modification of the Drywell Oxygen Monitoring Instrumentation l Action Requirements to be Consistent with those Contained in NUREG 1433 Revision 1," Standard Technical Specifications l General Electric Plants, BWR/4" i ,

DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES l

l l

E l- Enclosure 1 to NRC-98-0062 l Page 2 l ,

DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE (S)

DESCR1PTION Technical Specification Limiting Condition for Operation 3.3.7.5, Table 3.3.7.5-1 specifies the " Required Number of Channels" of Drywell Oxygen Concentration as 2

) in Operational Conditions 1 and 2. Table 3.3.7.5-1, Action 80 requires that "with the number of OPERABLE accident monitoring instrumentation channels less than the Required Number of Channels shown in Table 3.3.7.5-1, restore the inoperable channel (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ." The proposed change increases the time allowed for a channel to remain inoperable to 30 days and requires a report within the following 14 days discussing the results of the root cause evaluation and identifying proposed restorative actions, rather than a plant shutdown, if the instrumentation is not returned to operable status.

There are two divisions of the Primary Containment Monitoring System. The hydrogen and oxygen monitors are part of the Primary Containment Monitoring

, System (PCMS). The PCMS hydrogen and oxygen monitors provide control room l-operators with information regarding hydrogen and oxygen concentration following

! an accident. As described in the UFSAR, the primary containment hydrogen and oxygen monitoring system consists of two divisions, each division including one i channel for each parameter. The system continuously samples the containment y atmosphere during Operational Conditions 1 and 2 when required to be operable by the Technical Specifications. Each division can be aligned to monitor either the 1 l dryw ell or the suppression chamber. One division is normally aligned to the drywell, l with the other division aligned to the suppression chamber.

t l

l The primary containment hydrogen and oxygen monitors are classified as Regulatory

' l Guide 1.97, " Instrumentation for Light Water Cooled Nuclear Power Plants to I J Assess Plant and Environs Conditions During and Following an Accident," Category

I, Type C instruments. Type C instruments provide infonnation to indicate the

! potential for breaching or the actual breach of the barriers to fission product release.

The primary containment hydrogen and oxygen monitors are used to detect high hydrogen and oxygen concentrations in primary containment which could lead to a containment breach. The primary containment hydrogen and oxygen monitors are also used for verifying the adequacy of mitigating actions following an accident. l They provide an alarm in the main control room on high hydrogen or high oxygen

)

concentration, but provide no automatic function to prevent or mitigate any of the i Updated Final Safety Analysis Report (UFSAR) analyzed accidents. 1 t

c ;

l -

[ Encl:sure 1 to NRC-98-0062 Page 3 -

l-

, ~ A change to the Technical Specification Action requirements is being requested l because recent guidance fmm Reference 2 no longer requires a plant shutdown when one channel of this Regulatory Guide 1.97, Category 1, Type C post accident H monitoring instrumentation has been inoperable in excess of 7 days. This change l 2

will allow continued operation in Operational Conditions 1 and 2 with one of the two oxygen monitoring channels inoperable, provided a report is submitted to the NRC discussing the results of the root cause evaluation and identifying proposed

restorative actions. Should the redundant oxygen monitor also become inoperable, l' current Technical Specifications as well as this requested change, will still require

' the plant to be shut down within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , if one channel cannot be restored to operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

EVALUATION l

l Fermi 2 has an inerted primary containment atmosphere during reactor operation.

Because of this, in the event of a LOCA, the oxygen concentration is the limiting parameter for preventing the accumulation of an explosive gas mixture. The i hydrogen and oxygen concentrations are monitored during operation and following a l LOCA by the primary containment hydrogen and oxygen monitors, and'are l displayed in the control room. The primary containment hydrogen and oxygen j' monitors are part of the Primary Containment Monitoring System (PCMS). The

! ' primary containment hydrogen and oxygen monitoring systems consist of two l- divisions, each division including one channel or subsystem for each function. The primary containment hydrogen and oxygen monitoring systems continuously sample the containment atmosphere during Operational Conditions 1 and 2 when required to j be operable by the Technical Specifications. One division for each function is l- normally aligned to the drywell, with the other division aligned to the suppression chamber. The primary containment hydrogen and oxygen monitors provide information to the control room operators for monitoring hydrogen and oxygen x, L concentrations in the primary containment so that actions can be initiated, if

necessary, to prevent the accumulation of an explosive gas mixture. Technical I

l. Specification 3.3.7.5 requires the primary containment hydrogen and oxygen monitors to be operable in Operational Conditions 1 and 2. In addition, Technical Specification 3.6.6.2 requires the drywell and suppression chamber atmosphere oxygen concentration to be less than 4% by volume. l I

With one channel of the oxygen monitoring system inoperable, the remaining l operable, redundant channel is suflicient to provide the monitoring function this l instrumentation is intended to perfonn Increasing the allowed outage time to 30 )

days has been determined to be acceptable in Reference 2 based upon operating l experience, due to the passive function of the instrumentation (there are no critical !

l.

I I

J

f Enclosure I to NRC-98-0062 Page 4 automatic actions associated with these instruments); the operators' ability to diagnose an accident using attemative instruments and methods (grab samples and laboratory analytical equipment); and the low probability of an event requiring post accident monitoring instrumentation during this interval. Submittal of a report discussing the results of the root cause evaluation and identifying proposed restorative actions has been determined to be acceptable in lieu of a plant shutdown in Reference 2 based upon the requirement for attemative actions (to be identified in the required report), and given the low likelihood of plant conditions that would I

require information pmvided by this instrumentation.

Because these instruments provide no automatic function in preventing or mitigating any of the Updated Final Safety Analysis Report (UFSAR) analyzed accidents, no analysis of accident mitigation functions for these instruments is needed. Technical l

Specification 3.6.6.2 continues to require the drywell and suppression chamber atmosphere oxygen concentration to remain less than 4% by volume during Operational Conditions 1 and 2. The redundant oxygen analyzer is adequate for

{

monitoring this parameter. The loss of one or both of the oxygen analyzers is not l

. critical for entry into the Emergency Operating Procedures. Entry conditions for the .

post accident control of hydrogen are based upon the primary containment hydrogen monitors, and both channels of primary containment hydrogen monitoring l

instmmentation are still required to remain operable in accordance with Technical Specification 3.3.7.5. Additionally, alternate methods using grab samples and -

laboratory analytical equipment are available for obtaining hydrogen and oxygen concentrations if the respective instruments are not available.

i l

I !

i

!- j I

i

Enclosure 2 to NRC-98-0062 I Page1 i

l l

l l ENCLOSURE 2 l

l FERMI 2 NRC DOCKET NO. 50-341 N.RC LICENSE NO. NPF-43 '

REQUEST TO REVISE TECIINICAL SPECIFICATIONS:

Modification of the Drywell Oxygen Monitoring Instrumentation Action Requirements to be Consistent with those Contained in NUREG 1433 Revision 1," Standard Technical Specifications -

General Electric Plants, BWR/4" 10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION e

(

~

' Enclosure 2 to NRC-98-0062

! Page 2 l

1 10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION

' In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards consideration. The proposed Technical Specification (TS) changes described above do not involve a significant hazards consideration for the following reasons:

1. The change don not involve a significant increase in the probability or /

consequences of an accident previously evaluated.

The proposed change will permit operation with one of the primary containment .!

oxygen monitoring channels inoperable for greater than 7 days without requiring l a plant shutdown. The primary containment oxygen monitors provide the control !

room operators with indication and alarm of the oxygen concentration in the l L primary containment, but do not provide any automatic function to mitigate an )

accident. Because they perform only a monitoring function, the oxygen monitors are not associated with the initiation of any previously evaluated accident; p therefore, there is no change in the probability of an accident previously evaluated.

,o L The indication provided by the primary containment oxygen monitors is used by the control room operators to ensure that the oxygen concentration remains '

within limits and to help make decisions regarding the use of the Combustible !

Gas Control System, if necessary. The remaining operable channel of primary

containment oxygen monitoring instrumentation is sufficient to provide the ,

i. necessary monitoring capability. Additionally, the loss of one or both oxygen 1 analyzers is not critical for entry into the Emergency Operating Procedures. !

p Entry conditions for the post accident control of hydrogen are based upon the primary containment hydrogen monitor readings, and both channels of primary L containment hydrogen monitoring instrumentation are still required to remain operable in accordance with Technical Specification 3.3.7.5. - Additionally, ,

altemate methods using grab samples and laboratory analytical equipment are l available for obtaining primary containment oxygen concentration if no primary o'

containment oxygen monitoring instnnnentation is available. Therefore, this change will not involve a significant increase in the consequences of a previously i evaluated accident.

o

+- Encl:sure 2 to NRC-98-0062 Page 3

i. -

I

2. The change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

f

- As discussed above, the primary containment oxygen monitors are indication and I

alarm only instruments which provide information to the control room operators.

The proposed change does not introduce a new mode of plant operation, nor does i it involve a physical modification to the plant. Therefore, the proposed change

does not create the possibility of a new'or different kind of accident from any previously evaluated.

3. The change does not involve a significant reduction in the margin of safety.

i-L:

The proposed change involves the length of time that a primary containment -

- oxygen monitoring instrument channel may be out of service. The primary j containment oxygen monitors are indication and alarm only instruments which l . do not affect any parameters or assumptions used in the calculation of any safety l margin associated with Technical Specification Safety Limits, Limiting Safety :

L System Settings, Limiting Control Settings or Limiting Conditions for Operation, or other previously defined margins for any structure, system, or -

component.' Therefore, the proposed changes do not involve a significant reduction in a margin of safety. I L

L l l h

i l l L

l c l l

t-1

(- ,

. l l Enclosure 3 to NRC-98-0062 Page1 i

ENCLOSURE 3 i FERMI 2 l NRC DOCKET NO. 50-341 i l OPERATING LICENSE NPF-43 l l 1 j REQUEST TO REVISE TECHNICAL SPECIFICATIONS !

l l

l Modification of the Drywell Oxygen Monitoring Instrumentation Action Requirements to be Consistent with those Contained in l NUREG 1433 Revision 1," Standard Technical Specifications ,

l General Electric Plants, BWR/4"

! i l l RATIONALE FOR SUPPORT OF EMERGENCY CHANGE l i l

l

(

l l

l

Enclosure 3 to

!! ! NRC-98-0062 L'

Page 2 RATIONALE FOR SUPPORT OF EMERGENCY CHANGE Detroit Edison request , that this license amendment request be processed in an .

emergency manner an allowed by 10CFR50.91(a)(5) because delay in granting this amendment could lead to a plant shutdown. 10CFR50.91(a)(5) requires that license amendments applied for under this criterion be 'done so in a timely manner. It also -

requires that the licensee explain why the emergency situation occurred and why it '

could not be avoided. Thejustification for this emergency request is provided below.

Spiking has been observed in the Division 2 oxygen monitor circuitry since' February

'1998. - Several sensor and component replacements have been made in an attempt to eliminate the spiking. It was thought that the spiking problem had been corrected ~

~ during a system outage conducted the week ofMarch 23,1998. However, the spiking was again observed on March 28,1998. On March 30,1998, the spiking exceeded the predetermined level at which it was decided the Division 2 containment oxygen monitor would be declared inoperable. This placed the plant in a 7-day Limiting Condition for Operation (LCO 3.3.7.5). The Action for this LCO, Table 3.3.7.5-1 Action 80 requires that the inoperable channel be restored to operable status g within 7 days or be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

~

An extensive troubleshooting effort has been underway to determine the cause of the spiking and to repair it. However, at this point, the cause has not been determined.

l Detroit Edison is concemed that should continued efforts not identify the cause, l which could lead to the appropriate repairs, the plant would be required to be shut I down by 2025 hours0.0234 days 0.563 hours 0.00335 weeks 7.705125e-4 months on April 6,1998 in accordance with the current Technical Specifications. Recent guidance from Reference 2 no longer requires a plant shutdown when one channel of this Regulatory Guide 1.97, Category 1, Type C post accident monitoring instrumentation has been inoperable in excess of 7 days.

Additionally, troubleshooting would best be continued with the plant remaining in the current inerted steady state condition.

As described above, Detroit Edison has used its best efforts to correct the spiking problem and to make a timely application for this amendment. However, this short time frame will not allow the normal oublic notice and comment period described in I 10CFR50.92(a)(2), and still ensure receipt of the license amendment in time to .

prevent a plant shutdown. The requested emergency treatment of this license amendment could not be avoided. The instrument became inoperable on March 30, 1998 at 0825 hours0.00955 days 0.229 hours 0.00136 weeks 3.139125e-4 months , and the troubleshooting efforts have been intensive. It should be noted that Detroit Edison is submitting its license amendment application for incorporation of the Improved Technical Specifications, consistent with NUREG 1 1433, Revision 1 within the next week also. The Improved Technical Specifications

l 1

Enclosure 3 to NRC-98-0062 Page 3 incorporate the relief requested in this emergency license amendment. This license amendment has been discussed with the NRC Staff, and the license amendment request was prepared and reviewed in an expeditious manner. Therefore, Detroit

- Edison requests that this license amendment be handled in an emergency manner as allowed by 10CFR50.91(a)(5), and that it be approved by 0800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months on April 6, 1998. This will allow time for an orderly shutdown should this license amendment request not be granted.

I 1

i l

I l

1 i

]

NRC-98-0062, Application for Amend to License NPF-43,modifying Drywell Oxygen Monitoring Instrumentation Action Requirements to Be Consistent W/Those Contained in NUREG-1433,Rev 1, STS GE Plants,BWR/4

Text

References:

Subject:

Navigation menu

Search