View source for NRC-92-0001, Application for Amend to License NPF-43,changing TS to Eliminate Number of Response Time Testing Requirements Based on BWR Owners Group Topical Rept NEDC-32013P, Sys Analyses for Elimination of Selected Response Time..

{{Adams
| number = ML20094P515
| issue date = 03/27/1992
| title = Application for Amend to License NPF-43,changing TS to Eliminate Number of Response Time Testing Requirements Based on BWR Owners Group Topical Rept NEDC-32013P, Sys Analyses for Elimination of Selected Response Time..
| author name = Orser W
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-92-0001, CON-NRC-92-1
| document report number = NUDOCS 9204080192
| package number = ML20094P518
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 11
| project = 
| stage = Request
}}

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:d:       son rv'                                                                           sLma, March 27, 1992 NRC-92-Old!
U. S. Nuclear Regulatory Commission Attn     Document Control Deck Washingt on, D. C. 20555

==References:==
: 1)   Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
: 2) General Elect ric BWR Owners' Group Topical Report, NEDC-3 2013 P.
                                               " System Analyses for the Elimination of Selected Response Time Testing Requirements,"
March 1992 (proprietary)

==Subject:==
Proposed Technical Specification Change (License Amendment) for Selected Response Time Testing Requirements        _ , _ , _
Pu'esuant t o 10CFR50.90, Det roit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications. The proposed changes eliminate a number of response time testing requirenente based on the Reference 2 BWR Owners' Group Topical Report which provides the technical justification for these removals.            The Reference 2 Topical Keport has been submit ted for review under separate cover by the 3WR Owners' Group. Additionally. It has been determined appropriate to add an inst rucer,tation response time requirement to the Isolation Actuation System Response Time table for the Main Steam Line Flow-High signal.          This new surveillance requirement has already been incorporated into the plant surveillance procedures.
This amendment eliminates unuccessary response time testing. thereby eliminating all inadver tent safety system actuation risk caused by installation and renoval of temporary test jumpers used for response time testing. Out of service time for the instrumentation channels due to this unnecessary testing is also eliminated. Additionally, a significant reduction in I&C technician outage work scope will occur which will allow deployment of those resources to other more import an t activities.       For these reasons, approval of these changes is requested prior to the plant's third refueling outage which is scheduled to
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                               .                     USNRC
(                                F6tch'27, 1992 NRC-92-0001 Page 2 begin in September,1992. In order to allow for cite doeurent                                                              changen                          ,
a 30 -day implementation period is requested for this proposal.
* Enclosure 1 provides a deceription and evaluation of the proposed changes.
,'                                                    Enclosure 2 provides an analysis of the significant hazards consideration assesscent using the standards in 10CFR50.92.
Enclosure 3 provides marked up pages of the existing Technical Specifications te show the proposed changes and a typed version of the af fected Technical Specification pages with the proposed changes inc o rporat ed.
Detroit Edison has evaluated the proposed Technical Specifications against -the criteria of .10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Revier_ Group has reviewed the proposed Technical Specifications and concurs with the enclosed determinations. In accordance with 100FR50.91. Detroit Edison has provided a copy of this letter to the State of Michigan.
If you have any questions, please contact Mr. Glen D. Ohlemacher at                                                                                       -
(313) 586-4275.
Sincerely.
Enclosures cc:     T. G. Cc1 burn R. W. DeFayette J. F. Starg S. Stasek Supe rvisor, tectric Operators Michigan Public Service Commission - J. R. Padget t 1
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                            -   USNRC
* March 27, 1992                                                                                                                                                            l' NRC 92-0001 Page 3 h
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I, WILLIAH S. ORSER. do hereby af firm that the foregoing statements 2
are based on facto and circumstances which are true and accurate to the best of my knowledge and belief.
                                                                                                                                                                                                          +
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                                                                                                                                                               '/
b      b{                  ..            l' WILLIAM S. ORSER                                                                                     '
Senior Vice President On this - c: 7+                                        day of I /d > ,, 1992, before me personally appeared William S. Or 'er, being first duly sworn-and says that he executed the foregoing a his free act and deed.
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4 IX 105URE 1 t
DF3CRIPTION AND EVALUATION OF THE PHOPOSF3) CilANGF3 1

      .                 Enclotura 1 to NRC-92-0001
                      -Page 1 ENCLOSU.'E 1 FERNI 2 NHC DOCKET 50-341 OPERATING LICENSE NPF-43 RtX)UEST 'IO REVISE TECHNICAL SPECIFICATIONS:
RESPONSE TIME 'IESTING BASIS l@R CHANGE REQUEST HACKGROUNDi This proposed change is to eliminate from Technical Specifications selected response time testing requirements. Specifically, the response time testing requirements-to be eliminated are for the 1) Reactor Protection System instrumentation, 2) Isolation System instrumentation, and 3) Energency Core Cooling System instrumentation. An analysis has been performed demonstrating that response time testing is redundant to other periodic touts required by
                        ~ Technical Specifications, such as channel calibrations, channel checks, channel g                        functional tests, and logic system functional tests, which provide adequate 1
assurance that instrument response times are within acceptance-limits in place of response time testing.
In addition to the deletions it has been determined that a 0.5 second response time testing requirement should be added for the Main Steam Line Flow-High isolation actuation instrumentation.
BASIS:
Regulatory Guide 1.118 (Revision 2) states:
                                 "Rusponse time testing of all safety related equipment, per so, is not required if, in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine tests." -
An analysis has been performed by Genercl Electric (GE) and the BWR Owners' Group which provides the basis for eliminating selected response time testing requirements (see Reference 1). The analysin was performed for two representative BWRs, one of which is Fermi 2. The applicability of this analysis to Fermi 2 has been verified by GE.
The analysis includes the identification of all potential failure modes of all
                         -components in the affected instrumentation loops which could potentially impact the instrument loop response time. ..In addition, plant operating experiences were reviewed to identify response time failures and how they were detected.
                         .The failure. modes identified were then evaluated to determine if the effect on o-    .,      . , . .        .

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Eaclo:uro 1 to
* NRC-92-0001 Page 2 response time would be detected by other testing requirements contained in Technical Specifications.
The results of the analysis aemonstrate that response time testing is redundant to the other Technical Specification testing requirements (channel calibration, channel check, channel functional test, and logic oystem functional test).
These other s                     'ts are sufficient to ident.ify failure modes or significant degradationr.                        instrument response time and assure operation of the analyzed instrument loops within acceptance !!mits. Furthermore, there are no failure modes that can be dettcted by response time testing that cannot also be detected by other Technical Specification tests.
The Reference i evaluations demonstrc'' that response time testing can be eliminated for the following:
: 1) All Emergency Core Cooling System instrument loops;
: 2) All Isolation System actuation instrument loopa except for main steam line isolation valves (MSIVs);
: 3) decenra for selected Reactor Protection System actuation; and
: 4) Sensors for MSIV closure actuation.
EPRI Report NP-7243 (Reference 2) identified cases where response time testing did not detect the slow loss of instrument transmitter fill oil. However, Drift Analysis and other techniques are available to detect the resulting change in instrument performance. Detroit Edison has addressed slow loss of fill oil in response to NRC Bulletin 90-01 (Reference 3).
The addition of the main steam line flow isolation response time requirement of less than or equal to 0.5 seconds is necessary because that time is consistent with the assumptions used in the main steam line break accident analyses in the plant's Updated Final Safety Analysis Tieport (Ref. UFSAR Table 15.6.4-1).
Response time testing of this 0 5 second requirement is also consistent with the standard technical specifications and industry practice for plants of similar vintage and elimination of the requirement has not been justified by the referenced BWR Owners' Group report. Accordingly, the requested 0.5 second instrumentation response time requirement tc the Main Steam Isolation Valves (HSlVs) has already been added to the plant surveillance procedure requirements.
SIGNIFICANT HAZARu3 CONSIDERATION TPa significant hazards consideration assessment is presented in Enclosure 2 and concludes that the proposed amendment doca not involve a significant hazards consideration.

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                  ,,                     Enclosure 1 to NRC-92-0001 Page 3 ENVIRONMENTAL, IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. The proposed it                            change does not 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 cumulativo a                                     occupational radiation exposures. Based on the foregoing, Detroit Edison                         ,
fW                                       concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
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                                              $CLilSION to
         **                                                                                                                              ?
m sed on the evaluacion above:            1) there is reasonable assurance that the health O Y  'k '                             .ad safety of the public will not be ondangered by operation in the proposed manner, and 2) such activities will be conducted in compM ance with the
                                           %sission's regulations and proposed amendments will not be inimical tr< the ammon defense and securfty or to the health and safety of the public.
hererent.e:
: 1. NEDC-32000, " System Analyses for the Elimination of Selected Response Time Testing S quirements", March 1992.
: 2. EPHI NP-7243, " Investigation of Response Time Testing Roquirements", May 1991.
3     Detroit Edison Letter to FRC, NRC-90-0179, " Updated Response to NRC B( M in K -01," dated January 18, 1991.
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Er, closure 1 to NRC-92-0001 Page 3 ENVIRONMENTAL IMPACr _
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 effluents that may be released offsite, nor significantly increase individual er cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
CONCLUSION Based on the evaluation above:      1) there is reascr.able 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.

==Reference:==
: 1. NEDC-32013P, " System Analyses for the Elimination of Selected Response Time Testing Requirements", March 1992.
: 2. EPRI NP-7243, " Investigation of Response Time Testing Requirements", May 1991.
3     Detroit Edison Letter to NRC, NRC-90-0179, " Updated Response to NRC Bulletin 90-01," dated January 18, 1991.

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                                                                       'GCIA)SURE 2 SIGNIFICANT IIAZLRDS CONSIDERATION ASSESSMENT o
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Enclosure 2 to
         .      NRC-92-0001
              -Page-1 ENCLOSURE 2 FERNI 2
       ^
NRC DOCKET 50-341                                 ;
OPERATING LICENSE NPF-43 REQUEST TO-REVISE TECHNICAL SPECIFICATIONS:
P.ESPONSE TIIN! TESTING 10CFH50 92 EVALUATION BASIS FOR SIGNIFICANT HAZARDS DETERMINATION:                                                ,
The proposed Technical Specification changes described in Enclosure 1 do not involve a significant hazards consideration for the following reasons:
: 1.       The changes-do not involve a significant. increase in the probability or consequences of an accident previously evaluated.
The purpose of the . proposed Technical Specification changes is to eliminate response time-testing requirements for selected instrument loops in the Reactor Protection Systed, Isolation System, and Emergency Core Cooling System. . However, because of the continued application of other, redundant Technical. Specification testing requirements such as enannel calibrations, channel _ cheeks, channel functional tests, and logic system functional tests, and other techniques employed to detect the slow loss of oil in selected sensors,'the response time of these' systems will be maintained within the acceptance limits assumed in plant safety analyses and required
                  ,-     for-successful mitigation of an initiating event. The proposed Technical
,                      . Specification changes do not affect the capability of the associated systems to perform their intended function within their required response time.
GE and the BWR Owners' Group have completed an evaluation (Reference 1) which: demonstrates that response time testing is redundant to the other
                       - Technical-Specification testing requirements and other tecnniques listed in the preceding paragraph. _These other tests and/or tecnniques are sufficient to identify failure modes or degradations in instrument response time and assure operation of the associated systems within acceptance               i limits.- There are no failure modes that can be detected by response-time
                       -testing that cannot also be detected by.the other Technical Specification tests.
1
_ The proposed more stringent-requirements of _less than 0.5 second
                       -instrumentation response time to MSIV actuation for the main steam line              i flow-high instrumentation is identical to the time used in the safety analyses and thus has no effect on the prooability or consequences of
                        . accidents evaluated by those analyses.                                             l u                   a          n           ,  a                  s v ,    , a-

Encloruro 2 to
          ,   NRC-92-0001 Page 2
: 2. The changes do not create the-possibility of a new or different kind of accident from any accident previously evaluated.
As discussed above, the proposed Technical Specification changes do not affect the capability of the associated systems to perform their intended function within the acceptance limits assumed in plant safety analyses and required for successful mitigation of an initiating event. Other than the elimination of selected response time tests and the addition of the more stringent main steam line flow-high instrumentation response time acceptance critoria, there are no changes to plant equipment or procedures.
3    The changes do not involve a significant reduction in the margin of safety.
The current Technical Specification response times are based on the maximum allowable values assumed in the plant safety analyses. These analyses conservatively establish the margin of safety. As described above, the           -
proposed Technical Specification changes do not affect the capability of the associated systems to perform their intended function within the allowed response time used as the basis for the plant safety analyses.
Plant and system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore the margin of 1                   safety is not affected.
Although not explicitly evaluated, the proposed Technical Specification changes may increase the margin of safety, by:
a)       Reducing the amount of time that systems are out-of-service for the performance of response time testing; b)       Eliminating inadvertent actuations of Engineered farety Features       _
caused by temporary circuit alterations installed and removed to accomplish response time testing; and c)       Reducing wear-and-tear on instrumentation resulting from               -
unnecessary (as demonstrated by heference 1) additional testing.

==Reference:==
: 1. NEDC-32013P, " System Analyses for the Elimination of Selectad Response Time Testing Requirements", March 1992.
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Enclosure 3 to
             ,         'NRC-92-0001 Page 1-DiCIASURE 3 FERMI 2 Nhc DOCKET 50-341 OPERATING LICENSE NFF-43 HEQUEST TO REVISE TECHNICAL SPECIFICATIDilS:
RESPOllSE TIME TESTING TECIDilCAL SPECIPICATION CHANGES AND PAGE CHANG 5TMSTRUCTIOllS Attached are mark-uas of the existing Technical Specifications, indicating the-proposed _ changes :ar.d a typed version of the Technical Specifications incorporating the preposed changes. Provided.below are instructions for incorporating these peges into the Technical Specifications.
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