NRC-98-0117, Application for Amend to License NPF-43,revising Table 4.0.2-1 to Include Two Functional Units for TS 4.3.1.3 (RPS Response Time Testing) & Allowing one-time Extension of Respective Surveillance Intervals

Application for Amend to License NPF-43,revising Table 4.0.2-1 to Include Two Functional Units for TS 4.3.1.3 (RPS Response Time Testing) & Allowing one-time Extension of Respective Surveillance Intervals

ML20236U457
Person / Time
Site:	Fermi
Issue date:	07/23/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236U459	List: ML20236U460 NRC-98-0117, Application for Amend to License NPF-43,revising Table 4.0.2-1 to Include Two Functional Units for TS 4.3.1.3 (RPS Response Time Testing) & Allowing one-time Extension of Respective Surveillance Intervals
References
CON-NRC-98-0117, CON-NRC-98-117 NUDOCS 9807300176
Download: ML20236U457 (8)

Text

.

Douglas R. Gipson Senior Vi< e President. Nue: ear Generation d

Fenni2 6400 North Dixie llwy , Newport, Michigan 48166 Tel: 313.586.5201 Fax: 313.586 4172 g a Detroit Edison 10CFR50.92 July 23,1998 NRC-98-01 l'/

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,"One-Time Technical Specifications Revision to Allow Extension of the Current Fermi 2 Operating Cycle 6", NRC-98-0040, dated June 26,1998

3) Detroit Edison Letter to NRC,"One-Time Technical Specification Revision to Allow Extension of the Fermi 2 Operating Cycle",

NRC-95-0096, dated September 20,1995

Subject:

One-Time Technical Specifications Revision to Allow Extension of the Current Fermi 2 Operatine Cycle 6 - Additional items i

The Detroit Edison Company (Detroit Edison) hereby files an addition to its application to amend the Fermi 2 Technical Specifications (TS) to allow extension of the current Operating Cycle 6 as submitted in Reference 2. This addition revises {)

) 3 Table 4.0.2-1 to include two functional units for TS 4.3.1.3 (Reactor Protection System (RPS) Response Time Testing) and allow a one-time extension of the ho respective surveillance intervals. The proposed extensions are similu to a previous request approved for Fermi 2 for extension ofOperating Cycle 5 (Reference 3).

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9807300176 990723341 I PDR ADOCK O P

A trfE Eners Company L .. _ _ _ _

r USN~RC NRC-98-Oll7 Page 2 e 9 These additions do not affect the No Significant Hazard Consideration evaluation or l Environmental Impact Categorical Exclusion determination as presented in Reference

2. The enclosed TS insert page (Table 4.0.2-1) reflects these changes and replaces the page as transmitted by Reference 2.

Consistent with Reference 2, Detroit Edison requests that the NRC approve and issue these changes,in conjunction with the Reference 2 changes, by August 1,1998, to allow time for orderly preparation of the outage work required during RF06.

If you have any questions or require additional information, please contact Mr.

~ Norman K. Peterson, Director - Nuclear Licensing at (734) 586-4258.

Sincerely, Attachment Enclosure cc: B. L. Burgess G. A. Harris A. J. Kugler l Regional Administrator, Region 111 I Supervisor, Electric Operators Michigan Public Service Commission l

l l

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USNRC NRC-98-0117 Page 3

, 1 I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are tme and accurate to the best of my knowledge and belief.

I I

,As  !

DOUGLAS R.'GIPSON l Senior Vice President, Nuclear Generation I

On this A5" day of ex[c/ ;-1998 before me personally appeared Douglas R. Gipson, being firsty sw g and says that he executed the foregoing as his free act and deed.

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Notary Public D ROSALE A. ARMETTA gewypusuc.goWWECWiTY,K

l. gmunamnanflEXPWE810/1149

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I Attachment I to NRC-98-0117 I

e 1 l

1 I

ATTACIIMENT 1 1

FERMI 2 NRC DOCKET NO. 50-341 j OPERATING LICENSE NO. NPF-43 I l

' REQUEST TO REVISE TECilNICAL SPECIFICATIONS !

"ONE-TIME TECHNICAL SPECIFICATIONS REVISION TO ALLOW EXTENSION OF THE FERMI 2 OPERATING CYCLE 6 - ADDITIONAL ITEMS" DESCRIPTION AND EVALUATION OF THE PROPOSED CIIANGES

Attachment I to NRC-98-0117 Page1 1

- 1 DESCRIPTION AND EVAL,UATION OF i THE PROPOSED CHANGES (S)

BACKGROUND:

As described in Reference 2, both the availability of external power and its delivery through the transmission interconnections may become questionable during the peak j demand period of this summer. Postponing the outage until September will significantly '

alleviate this problem, and will allow Detroit Edison to be able to meet its power demands .

without being concerned about availability of external power or its delivery during the l peak periods. Therefore, Detroit Edison is proposing these additional revisions to Fermi 2 Technical Specifications change request submitted by Reference 2, which would allow plant shutdown to be delayed until September 4,1998.

A revision is proposed for Table 4.0.2-1, previously submitted in Reference 2, showing the additional affected specifications and new completion date for these surveillance. The Fermi 2 Technical Specifications (TS) require the performance of Operating Cycle surveillance requirements (SRs), including response time testing. The SRs specify that the required response time testing be conducted nominally at refueling intervals but at least once every 18 months. TS 4.0.2 allows a 25% extension of the surveillance interval to 22.5 months, if required, to provide some flexibility in cycle lengths.

Specifically by this addition to Reference 2, a one-time change is requested to extend the surveillance intervals for TS SR 4.3.1.3, Table 4.3.1.1-1, Items 2.b (APRM Flow biased thermal power - high) and 2.c. (APRM fixed neutron flux - high). This extension is being requested consistent with other surveillance, addressed in Reference 2, for equipment l required to be operable in Operational Conditions 1, 2 and 3 to a date of Septeinber 14, l

1998, which corresponds to the anticipated shutdown date of September 4,1998 but considers flexibility in shutdown dates and time to cooldown to Operational Condition 4.

DESCRIPTION:

The following section provides a description of the proposed TS change addition cited above. The Enclosure to this Attachment describes the justification for the proposed additional extensions.

Reactor Protection System Response Tirine Testing (TS SR 4.3.1.3)

Technical Specification SR 4.3.1.3 requires the RPS response time testing of the functional units to be demonstrated within the limits at least once per 18 months (with a maximum allowable surveillance interval extension of 4.5 months per TS 4.0.2). The SR also requires that the response time test include at least one channel per trip system such

(

Attachment I to NRC-98-0117 Page 2

, a that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific trip system. This SR becomes due for Items 2.b (APRM flow biased thermal power - high) and 2.c (APRM fixed neutron flux - high) of Table 4.3.1.1-1 on August 28,1998 and requires an extension of18 days to reach September 14,199E. Thejustification for this extension is provided in the Enclosure.

Attachment I to NRC-98-0117 Page 3

. s ENCLOSURE JUSTIFICATION FOR SURVEILLANCE INTERVAL EXTENSION TECilNICAL SPECIFICATION SR 4.3.1.3, Table 4.3.1.1-1, Items 2.h and 2.c RESPONSE TIME TESTING REACTOR PROTECTION SYSTEM INSTRUMENTATION Extension of the surveillance intervals for Items 2.b (APRM flow biased thermal power -

high) and 2.c (APRM fixed neutron flux - high) would have no substantial measurable effect on plant safety because:

a. There are redundant sensors that can initiate the scram operation.

b. Redundancy exists for every individual instrument channel within each trip function.

Only one of the channels per trip system is required to be tested during each surveillance period.

c. The instrumentation failure probability is a very small fraction of the total control rod insertion (scram failure probability).

d. There are several redundant and diverse instrument channels which can detect and generate a scram signal (e.g., flux, pressure, etc.)

e. The failure ofinstrumentation in the sluggish responding mode is a small fraction of its overall failure.

Extension of the Peach Bottom Atomic Power Station Units 2 and 3 surveillance intervals for RPS response time testing from 18 months to 24 months was accepted by the NRC in  ;

the Safety Evaluation Report dated August 2,1993. Thejustification cited above is very 1 sndlar to that provided in the NRC Safety Evaluation Report which states: l l

The RPS system consists of two independent trip systems with at least two subchannels of a parameter per trip system. The logic of the RPS system is such that either subchannel can trip a trip system and that both trip systems must trip to cause a reactor trip. The logic is such that a single failure will neither cause nor prevent a required reactor scram. The licensce states that, based on the inherent redundancy in the RPS system, the impact o.' extending the response time surveillance interval on system availability is small. l l A historical search of the 18 month surveillance for response time testing for the last three l

refueling outages was performed. The search criteria was to identify all failed or partially failed tests for further review and evaluation. The purpose of this evaluation was to  ;

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