NRC-98-0065, Application for Amend to License NPF-43,to Add Configuration Risk Mgt Program to TS Section 6.8.5,contingent on Approval of Previously Submitted License Amend for TS 3.8.1.1

Application for Amend to License NPF-43,to Add Configuration Risk Mgt Program to TS Section 6.8.5,contingent on Approval of Previously Submitted License Amend for TS 3.8.1.1

ML20247A722
Person / Time
Site:	Fermi
Issue date:	04/27/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247A728	List: ML20247A740 NRC-98-0065, Application for Amend to License NPF-43,to Add Configuration Risk Mgt Program to TS Section 6.8.5,contingent on Approval of Previously Submitted License Amend for TS 3.8.1.1
References
CON-NRC-98-0065, CON-NRC-98-65 NUDOCS 9805060218
Download: ML20247A722 (12)

Text

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4 Douglas R. Gipson

, Semar Vic e l're odent. N m lear Genet ation Ferriii 2 04% North Dixie lhg, Newport, h hiain Islu.

Tel: 313 FM.rdol fax: allIM 4172 Detroit Edison 1

10CFR50.92 April 27,1998 NRC-98-0065 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

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

2) Detroit Edison Letter to NRC," Proposed Technical Specification Change (License Amendment)- Emergency Diesel Generator Action Statements, Surveillance Requirements and Reports," NRC-95-0124, dated November 22,1995

3) Detroit Edison Letter to NRC," Response to Questions on Proposed Emergency Diesel Generator Technical Specification Change," NRC-96-0008, dated February 19,1996

4) Detroit Edison Letter to NRC," Response to Questions on Combustion Turbine Generator (CTG) 1 I Unit Number 1 Reliability and System Refurbishment," NRC-96-0066, dated June 12,1996

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5) Detroit Edison Letter to NRC," Response to NRC Letter on Emergency Diesel Generator Allowed Outage Time Extension

,, (TAC No. M94171)," NRC-96-0041," dated April 19,1996

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6) Detroit Edison Letter to NRC," Response to Probabilistic Safety Adf Assessment Questions Related to Request for increasing Emergency Diesel Generator Allowed Out of Service Time (TAC No. M94171)," NRC-96-0050, dated May 3,1996 9805060218 980427 PDR ADOCK 05000341-F PDR k A IrrE Enero company s

- USNRC NRC-98-0065 Page 2

7) Detroit Edison Letter to NRC," Revised Proposed Technical Specification Change (License Amendment)- Emergency Diesel Generator Action Statements, Surveillance Requirements and Reports (TAC No, M94171)," NRC-96-0069, dated June 21, 1996

8) Detroit Edison Letter to the NRC, " Additional Information Related to the License Amendment to Extend Emergency Diesel Generator Allowed Outage Times at Fermi 2," NRC-96-0133, dated December 4,1996

9) Detroit Edison Letter to NRC, " Combustion Turbine Generator (CTG) Revised License Amendment to Extend EDG Allowed Outage Times at Fermi 2", NRC-97-0002, dated January 30, 1997

10) Detroit Edison Letter to the NRC, " Additional Infom1ation Related to the License Amendment to Extend Emergency Diesel Generator Allowed Outage Times at Fermi 2,"

NRC-97-0088, dated August 7,1997

11) NRC Draft Regulatory Guide DG-1065,"An Approach for Plant- Specific, Risk-Informed Decisionmaking: Technical Specifications," dated June 1997

12) NRC Letter to Detroit Edison," Request for Additional Information (RAI) Related to the Ferrni-2 Submittal to Extend Emergency Diesel Generator Allowed Outage Times,"

dated December 23,1997

13) Electric Power Research Institute (EPRI) TR105396, "Probabilistic Safety Assessment (PSA) Applications Guide,"

dated August 1995

14) Detroit Edison Letter to the NRC " Additional Information Related to the License Amendment to Extend Emergency Diesel Generator Allowed Outage Times at Fermi 2," NRC-98-0007 dated April 3,1998

USNRC

. NRC-98-0065 Page 3

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Subject:

Proposed Technical Specification Change (License Amendment)-

l Addition of the Configuration Risk Management Program (CRMP) to the Administrative Section of the Technical Specifications j Pursuant to 10CFR50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant l Operating License NPF-43, Appendix A, Technical Specifications (TS). On December 23,1997, Reference 12 requested that Detroit Edison submit a proposed change to the administrative controls section of the Fermi 2 Technical Specifications to add a description of the Fermi 2 Configuration Risk Management Program

- (CRMP), and include supporting information. Detroit Edison is proposing an l amendment to TS Section 6.8.5 to add the CRMP, contingent on approval of the previously submitted License Amendment for TS 3.8.1.1. The enclosures describe a program and procedura which are not yet in place; they will be in place when this TS change is implemented.

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

Enclosure 2 provides an analysis of the issue of significant hazards consideration I using the standards of 10CFR50.92. Enclosure 3 provides the marked up pages of

,I l the existing TS to show the proposed change and a typed version of the affected TS l pages with the proposed changes incorporated. The enclosed TS pages submitted are in addition to the TS pages submitted in Reference 9. The revised BASES pages B 3/4 8-1 and 8-1a, replace the pages submitted in Reference 9.

I Detroit Edison has reviewed the proposed TS changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not l involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. j 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 l requirements for an Environmental Impact Statement or an Environmental Assessment.

In reference 12, the NRC has requested the inclusion of the CRMP in the Fermi 2 TS for a risk-informed TS Allowed Out of Service Time (AOT) extension. Detroit Edison anticipates that the pending revision of 10CFR50.65 to require on-line risk assessment of plant maintenance configuration will specifically require this assessment process. The pending 10CFR50.65 revision is broader in scope and will provide standards for all licensees. Detroit Edison considers this CRMP TS request as an interim action to satisfy the NRC's request, and expects to remove the CRMP

> from the TS once the 10CFR50.65 revision is approved.

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L_______________

USNRC NRC-98-0065 Page 4 Detroit Edison requests that the NRC approve and issue these changes by June 1, 1998, concurrent with the requested TS 3.8.1.1 License Amendment. An implementation period of 60 days following NRC approval is requested.

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

Sincerely, h MP Enclosures cc: A. B. Beach E B. L. Burgess G. A. Harris A. J. Kugler Supervisor, Electric Operators, Michigan Public Service Commission

l USNRC NRC-98-0065 j Page 5 I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief, I

DOUGLAS R' GIPSON Senior Vice President, Nuclear Generation l

l On this 8 day of , 1998 before me personally I

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

'b L/

Not'ary Public ROSAUE A. ARETTA unswpusuc MONROECMW MY0(BemISBNEXP9E8 W1U90 5

Enclosure 1 to

. NRC-98-0065 Page 1 l

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ENCLOSURE 1 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO REVISE TECIINICAL SPECIFICATIONS:

I Prog,osed Technical Specification Change (License Amendment)- Addition of the Configuration Risk Management Program to the Administrative Section of the Technical Specifications DESCRIPTION AND EVALUATION OF TIIE PROPOSED CIIANGES l

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Enclosure 1 to l

. NRC-98-0065 l Page 2 i

l DESCRIPTION AND EVALUATION OF TIIE PROPOSED CHANGE (S)

I DESCRIPTION: i Fermi 2 Technical Specifications (TS) currently do not include a description of the Configuration Risk Management Program (CRMP). TS 6.8.5.h," Configuration Risk I I

Management Program" will be added to the Administrative Controls (i.e., Section 6) section of the Fermi 2 TS. Fermi 2 will implement the CRMP to support entering .

into TS ACTIONS which have been amended to employ risk informed Allowed Out I of service Time (AOT). This program would be applicable only to the proposed 7 day ACTION for TS 3.8.1.1 as proposed in Reference 9.

The purpose of the CRMP is to ensure that a proceduralized Probabilistic Risk Assessment (PRA) informed process is in place that assesses the overall impact of l maintenance on plant risk. Implementation of the CRMP will enable appropriate actions to be taken or decisions to be made to manage risk when performing on-line maintenance for Systems, Structures, and Components (3SCs) with risk informed AOT.

The scope of the SSCs to be included in the CRMP will be those SSCs modeled in the Fermi 2, Level 1, PRA in addition to those SSCs considered ofIligh Safety Significance per Regulatory Guide 1.160, Revision 2, that are not modeled in the ,

PRA.

EVALUATION OF THE PROPOSED CHANGE:

Applicability:

The Configuration Risk Management Program (CRMP) ensures appropriate actions are taken and decisions are made to manage risk when performing on-line maintenance for Systems, Structures, and Components (SSCs) with a risk informed AOT. TS 6.8.5.h would be applicable to TS 3.8.1.1.b.2 because the proposed 7 day extended AOT for TS 3.8.1.1 is a Cost Beneficial Licensee Amendment (CBLA) proposal which provides risk informed justification.

The CRMP will be used when an EDG is intentionally taken out of service for a l

planned activity in accordance with proposed ACTION 3.8.1.1.b.2. This excludes

! short duration activities (e.g., less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to perform monthly start and load E surveillance). It will not be used when applying ACTIONS which have not been f extended (e.g.,3.8.1.1.a, b.1, b.3, c, d.1, and d.2). However, the CRMP will be used t

Enclosure I to NRC-98-0065 Page 3 when unplanned maintenance or repairs on an EDG require entry into ACTION 3.8.1.1.b.2.

Key Element 1. Implementation of the CRMP The intent of the CRMP is to implement 10CFR50.65(a)(3) of the Maintenance Rule with respect to on-line maintenance for risk-informed technical specification l (TS 3.8.1.1.b.2), with the following additions and clarifications:

a) The scope of the SSCs to be included in the CRMP will be those SSCs modeled in the Fermi 2, Level 1, PRA in addition to those SSCs considered of High Safety Significance per Regulatory Guide 1.160, Revision 2 (the Maintenance Rule Regulatory Guide) that are not modeled in the PRA.

b) The CRMP assessment tool is PRA informed, and may be in the form of a risk matrix, computer program, or direct risk assessment by the PRA stafT.  ;

Evaluations may have quantitative or qualitative bases. I l

c) CRMP will be invoked as follows for:

Risk-Informed Inoperability: A risk assessment will be performed prior to 1 entering the applicable LCO Action Statement for pre-planned activities. For j un-planned activities which result in LCO entry prior to assessing risk, a risk j assessment will be performed in a time frame consistent with the plant procedures and programs.

Additional SSC Inoperability and/or Loss of Functionality: When in the risk-informed AOT, if an additional SSC within the scope of the CRMP becomes inoperable /non-functional, a risk assessment shall be performed in a time frame consistent with the plant procedures and programs.

d) CRMP provides an evaluation of the risk significance of planned l maintenance associated with equipment unavailability. CRMP implementation manages scheduling maintenance on risk-significant equipment combinations. For unplanned entry into the risk-informed LCO, the same type of risk assessment is performed which considers the current plant configuration, including unavailability of SSCs defined per Key Element la above.

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l Enclosure I to

. NRC-98-0065

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l l Key Element 2. Control and Use of the CRMP Assessmem Tool l

a) Plant modifications and Emergency Operating Procedure changes will be i monitored, assessed, and dispositioned.-

Evaluation of the changes in plant configuration or PRA model features can be dispositioned by implementing PRA model changes or by the qualitative assessment of the impact of the changes on the CRMP assessment tool. This qualitative assessment recognizes that changes can be effectively compensated for without compromising the ability to make sound engineeringjudgments.

Limitations of the CRMP assessment tool are identified and understood for each specific AOT extension.

b) Procedures exist for the control and application of CRMP assessment tools, including description of process when outside the scope of the primary CRMP assessment tool, Key Element 3. Level 1 Risk-informed Assessment The CRMP risk assessment tool is primarily based on a Level 1, at power, internal events PRA model. The CRMP assessment may use any combination of quantitative and qualitative input.' Quantitative assessments can include reference to a risk l matrix, pre-existing calculations, or new PRA' analyses.

a) Quantitative assessments should be performed whenever necessary for sound decision making.

b) When quantitative assessments are not necessary for sound decision making, or are beyond the scope of the PRA model, qualitative assessments may be performed. Qualitative assessments will consider applicable or existing insights from quantitative assessments previously performed.

l Key Element 4 Level 2 Issues / External Events External events and Level 2 PRA issues, as a minimum, are treated when these considerations arejudged to be important using either qualitative or quantitative'e approaches. Guidance for implementing the CRMP is provided by plant procedures and programs.

i Enclosure 2 to NRC-98 0065 Page1 I

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i ENCLOSURE 2 FERMI 2 NRC DOCKET NO. 50-341 i NRC LICENSE NO. NPF-43 REQUEST TO REVISE TECIINICAL SPECIFICATIONS:

10CFR50.92 SIGNIFICANT IIAZARDS CONSIDERATION  !

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. Enclosure 2 to NRC-98-0065 Page 2 10CFR50.92 SIGNIFICANT II AZARDS CONSIDERATION BASIS FOR SIGNIFICANT IIAZARDS DETERMINATION 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 proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The Configuration Risk Management Program (CRMP)is an Administrative Program that assesses risk based on plant status. This proposed change does not change the design, configuration, or method of plant operation. Adding the requirement to implement this program for Technical Specification (TS) 3.8.1.1 does not affect the probability or the consequences of an accident.

2. The proposed change does not create the possibility of a new or different kind of

accident from any accident previously evaluated.

This proposed change does not change the design, configuration, or method of plant operation. Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated. l

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

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The proposed change does not involve a physical modification to the plant, a new I mode of operation or a change to the UFSAR transient analyses. The proposed change adds additional requirements to the evaluation of equipment outages.

Therefore, the proposed change does not involve a significant reduction in a l

margin of safety, i

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Enclosure 3 to l NRC-98-0065 l

Page1 l

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l ENCLOSURE 3 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NPF-43 REQUEST TO REVISE TECIINICAL SPECIFICATIONS Proposed Technical Specification Change (License Amendment)- Addition of the Configuration Risk Management Program to the Administrative Section of the Technical Spe'cifications Attached is a mark-up of the existing Technical Specifications (TSs), indicating the proposed changes (Part 1) and a typed version of the TSs incorporating the proposed I changes with a list ofincluded pages (Part 2). l i

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