View source for NRC-98-0008, Application for Amend to License NPF-43,revising Footnotes Specifying Conditions Under Which SRs Associated W/Ts 3/4.9.1, Reactor Mode Switch, Can Be Performed

{{Adams
| number = ML20199G174
| issue date = 01/28/1998
| title = Application for Amend to License NPF-43,revising Footnotes Specifying Conditions Under Which SRs Associated W/Ts 3/4.9.1, Reactor Mode Switch, Can Be Performed
| author name = Gipson D
| 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-98-0008, CON-NRC-98-8
| document report number = NUDOCS 9802040234
| package number = ML20199G181
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 11
| project = 
| stage = Request
}}

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MI! Nort h lM.le llH7, ht MlMtI, SIN higdf) 44l M Tel. 313 fMfaul far 313 TM41~2 Detroit Edison January 28,1998 NRC 98-0008 U. S. Nuclear Regulator / Commission Attention: Document Cor. trol Desk                                                                      ,
Washington, D C 20555 0001

==References:==
: 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
: 2) NRC Special inspection Report No. 50 341/96017, dated February 3,1997
: 3) NRC Notice of Violation (NRC Inspection Report 96017),
dated August 7,1997
: 4) Detroit Edison Letter, NRC-97-0080, Reply to Notice of Violation (Inspection Report 50 341/96017),
dated September 2,1997

==Subject:==
Proposed Technical Specification Change (License Amendment) to Permit Testing of Reactor Mode Switch Refuel Position Interlocks with One or More Control Rods Withdrav n from Defueled Cells in accordance with the requirements of 10CFR50.90, the Detroit Edison Company hereby proposes to amend the Fermi 2 plant Operating License NPF-43, Appendix A, Technical Specifications (TS), by revising footnotes specifying conditions under
,              which surveillance requirements associated with Technical Specifications 3/4.9.1, Reactor Mode Switch, can be performed. The proposed revisions correct a deficiency in the TS. The deficiency involves conditions under which the reactor mode switch may be repositioned to accommodate required testing of the refueling equipment interlocks.
Enclosure I provides a description and evaluation of the proposed TS change.
Enclosure 2 provides an analysis of the issue of significant hazards consideration using the standards of 10CFR50.92. Enclosure 3 provides marked up pages of the Ea<                             lllll!lilli- ll lIll ll
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USNRC                                                                                     i
   .      NRC-98 0008 Page 2                                                                                    l 1
l existing TS to show the proposed changes and a typed version of the affected Technical Specification pages with the proposed changes incorporated.                     l l
Detroit Edison has evaluated the proposed TS change against the criteria of               i 10CFR50.92 and determined that the proposed change does not involve a significant         !
hazards consideration. The Fenni 2 Onsite Review Organization has reviewed and recommended approval of the proposed TS change. The Nuclear Safety Review Group has reviewed the proposed TS change and concurs with the enclosed determinations. In accordance with 10CFR50.91," Notice for Public Comment; State Consultation," Detroit Edison is providing a copy of this letter to the State of Michigan.
Detroit Edison requests that the NRC approve and issue these changes by June 30,1998 with an implementation period of within 60 days following NRC                i approval. The requested approval date will permit implementation prior to the next Fermi 2 efueling outage, the next opportunity where the conditions addressed by the proposed change could be encountered. Although this proposed change is encompassed by conversion to the Improved Standard Technical Specifications (ISTS), the ISTS conversion for Fermi 2 will not be completed prior to the next refueling outage.
Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586 4258.
Sincerely, lD Enclosures cc:     A. B. Ileach B. [.. Burgess O. A. llarris A. J. Kugler Supervisor, Electric Operators, Michigan Public Service Commission

USNRC                                                                                                                                                                  I
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I, DOUOLAS R. OIPSON, do hereby affinn that the foregoing statements are based                                                                                         j
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DOUGLAS R, GIPSON -                                                                                  i t-Senior Vice President                                                                                l Nuclear Generation                                                                                   .
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Enclosure I to
. NRC.98-0008 Page1 9
ENCLOSURE 1 FERMI 2 NRC DOCKET NO. 50-34i NRC LICENSE NO. NPF-43 DESCRIPTION AND EVALUATION OF REQUEST TO REVISE TECilNICAL SPECIFICATIONS TO PERMIT TESTING OF REACTOR MODE SWITCil REFUEL POSITION INTERLOCKS WITil ONE OR MORE CONTROL RODS WITIIDRAWN FROM DEFUELED CELLS 4
                                                                    /

Enclosure I to NRC 98-0008' Page 2 DESCRIPTION AND EVAL,UATION OF Tile PROPOSED CIIANGES DESCRIPTION:
The purpose of this proposed license amendment is to modify the Fermi 2 Operating License NPF-43, Appendix A, Technical Specifications (TS) to correct an existing deficiency in the TS. The deficiency involves circumstances permitted by TS during refueling, where the TS require that certain surveillance tests be performed, but TS prevent the establishment of the conditions necessary to perform the surveillance tests.
Specifically, TS 3.9.10.1 and 3.9.10.2 permit one or more control rods to be removed from the core during the conduct of refueling operations, provided that certain conditions are satisfied. TS 3.9.1 requires the Reactor Mode Switch to be locked in the Shutdown or Refuel position when the plant is in Operational Condition 5, Refueling, and requires the Reactor Mode Switch Refuel position interlocks to be operable during core alterations.
Surmilance requirements 4.9.1.2 and 4.9.1.3 require that operability of the Reactor Mode Switch Refuel position interlocks be demonstrated OPERABLE prior to and periodically (at least once per seven days) during CORE ALTERATIONS, and after maintenance or repairs that could affect the Refuel position interlocks.
Performance of Surveillance requirements 4.9.1.2 and 4.9.1.3 necessitates moving the Reactor Mode Switch to the Run or Startup/llot Standby position. Footnotes to Table 1.2 and Surveillance requirements 4.9.1.2 and 4.9.1.3, permit the Reactor Mode Switch to be moved from the Refuel or Shutdown position provided that all coatrol rods are verified to remain fully inserted. The footnote does not address the situation where one or more control rods are removed from the core as permitted by TS 3.9.10.1 and 3.9.10.2.
Consequently, if the Refuel position interlocks surveillance requirements lapse or repairs affecting the interlocks are required while one or more rods are removed from the core, TS would not permit moving the Reactor Mode Switch to perform the surveillance test. With the interlocks inoperable due to the lapsed surveillance, TS 3.9.1 would prohibit cere alterations thm may be necessary to install or insert control rods to restore an all coutrol rods inserted configuration, even ifit were practical to do so. The current TS do not provide an avenue to recover from this situation.
This situation could reasonably be expected to occur. One or more control rods are routinely removed from the reactor during the course of refueling operations, as permitted by TS. While in this condition, corrective maintenance which may affect the interlocks, or any other unforeseen delay causing the surveillance to lapse could necessitate the performance of the interlock surveillance test. As discussed above, the interlock surveillance test cannot be accomplished within the current TS in this situation.

linclosure I to l        NitC 98 0008 Page 3 The proposed change to the TS corrects this deficiency by modifying the "#" footnote to Table 1.2 and the "*" (botnote to Surveillance Requirements 4.9.1.2 and 4.9.1.3.
Specifically, the footnotes are modified to permit the Reactor hiode Switch to be placed in the Run or Stadup/llot Standby positions to test the switch interlock functions provided that all control rods are verified to remain fully insened in core cells containing one or more fuel assemblies. The current footnote requires verification that all control rods remain fully inserted and dces not address control rods removed from defueled cells, a condition permitted by the TS 3.9.10.1 and 3.9.10.2.
This deficiency in the current TS is corrected by the Improved Standard Technical Specifi:ations (IS18), NUlt!!U 1433,llevision 1," Standard Technical Specifications, Ocneral lilectric Plants, llWR/4," Revision 1, dated April 1995. The proposed change is consistent with the ISTS.
EVAL,UATIOM When the plant is in Operational Condition 5, 'lefueling, the TS require the Iteactor hiode Switch to be locked in either the Shutdown or Refuel position. When in the Refuel position, the Reactor Mode Switch enables Refueling equipment interlocks which restrict the operation of the refueling equipment and the withdrawal of control rods. The purpose of the Refueling equipment interlocks is to reinforce procedures that prevent inadvertent criticality during refueling. The TS require surveillance tests to demonstrate the operability of the refueling equipment interlocks. The Reactor Mode Switch must be moved from the Shutdown and Refuel positions to perfbrm the tests. A footnote to TS Table 1,2, and Surveillance Requirements 4.9.1.2 and 4.9.1.3 permit the Reactor hiode Switch to be placed in the Run or Startup/Ilot Standby positions to test the switch interlock functions provided that all control rods are verified to remain fully inserted by a second licensed operator or other technically qualified member of the unit technical staff.
The proposed change would permit the Reactor Mode Switch to be placed in the Run or Startup/Ilot Standby positions to test the switch interlock functions provided that all control rods are verified to remain fully inserted in core cells containing one or more fuel assemblics. This change would accommodate the eventuality that the interlock tests are required while one or more control rods / drive mechanisms are removed pursuant to TS
         - 3.9.10.I and 3.9.10.2.
One provision of TS 3.9.10.1 and 3.9.10.2 which allows control rod / drive mechanism removal,is the requirement that all four fuel anemblies surrounding the control rod are removed from the associated core cell. With ", fuel assemblics in the core cell, the associated control rod has no reactivity control function. The revised footnote requires

Enclosure i to
.      NRC 98 0008 Page 4 e
that all control rods remain fully inserted in core cells with one or mora fuel assemblies while the mode switch is moved to support interlock testing. Additionally, when the reactor mode switch is unlocked to support interlock testing, TS 3.9.1, prohibits core alterations. With all control rods fully inserted in core cells containing one or more fuel assemblies, and no corc alterations in progress, there are no credible mechanisms to initiate a reactivity excursion during the interlock testing.
The proposed change is consistent with the ISTS, NUREG-1433, Revision 1," Standard Technical Specifications, General Electric Plants, llWR/4," Revision 1, dated April 1995.
The ISTS implement the proposed change via Limiting Condition for Operation (LCO) 3.10.2, Reactor Mode Switch Interlock Testing. The ISTS I CO 3.10.2 permits the reactor mode switch to be moved fmm its specified position to allow testing ofinterlock functions provided:
: 1. All control rods remain fully inserted in core cells containing one or more fuel assemblies; and,
: 2. No core alterations are in progress, lloth of these provisions are implemented as discussed above for the proposed change.
The ISTS does not require a second licensed operator or other technically qualified member of the unit technical staff to verify that the conditions are satisfied, in this regard, the proposed change includes more stringent administrative controls on the conduct of interlock testing than the ISTS.
EIGNIFICANT llAZAllDS CONSIDERATION:
In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards consideration. To make this determination, Detroit Edison has established that operation in accordance with the proposed TS nmendment would not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or
: 3. Involve a significant reduction in a margin of safety.

Enclosure 1 to l         NRC 98 0008 Page5 The significant hazards consideration assessment is provided in Enclosure 2.
ENVIRONMENTAL IMPACT:
Detroit Edir,on has reviewed he proposed TS changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do 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 cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed TS changes meet the criteria provided in 10CFR$1.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.
CDNCLUSION -
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 NRC's regulations and the proposed amendment will not be inimical to the common defense and security, or to the health and safety of the public.-
Detroit Edison requests that the proposed license amendment be approved by the NRC, with implementation to occur within the following 60 days.
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Enclosure 2 to
   ,              NRC 98 0008 PageI                                                                                                       ,
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                                                                                                                              ?
i ENCLOSURE 2 FERMI 2 NRC DOCKET NO. 50 341 NRC LICENSE NO. NPF-43 REQUEST TO REVISE TECilNICAL SPECIFICATIONS:
10CFR50.92 EVALUATION i
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Enclosure 2 to
.'       NRC 98 0008 Page 2 4
6 10CFR50.92 EVAL,UATION llASIS FOR SIGNIFICANT llAZARDS DETERMINATION The proposed Technical SpeciGcation (TS) changes described in Enclosure 1 do not involve a significant hazards consideration for the following reasons:
: 1. The proposed change does not involve a signincant increase in the probability or consequences of an accident previously evaluated.
The proposed change would permit the Reactor Mode Switch to be placed in the Run or Startup/llot Standby positions to test the switch interlock functions provided that all control rods are verified to remain inserted in core cells containing one or more fuel assemblics. The existing TS requires that all control rods be verined to remain inserted regardless of whether core cells are defueled. T he reactor mode switch refuel position interlocks restrict the operation of refueling equipment or withdrawal of control rods to reinforce unit procedures that prevent the reactor from achieving
:riticality during refueling operations. As such, the refueling equipment interlocks preserve the assumptions for the analyses of a control rod withdrawal event or loading of a fuel assembly into an uncontrolled cell dut:ng refueling operations. The reactor mode switch refuel position interlocks are not initiators of any previously evaluated accident. The revised footnote requires that all control rods remain fully inserted in core cells containing one or more fuel assemblics while the mode switch is moved to support interlock testing. Additionally, when the reactor mode switch is unlocked to support interlock testing, TS 3.9.1 prohibits core alterations. With all control rods fully inserted in core cells containing one or more fuel assemblies and no core alterations in progress, there are no credible mechtnisms to initiate a reactivity excursion during the interlock testing. Therefore, the proposed change does not involve a signincant increase in the probability of a previously evaluated accident.
The proposed change accommodates reactor mode switch refuel position interlock testing with one or more control rods removed as permitted by TS 3.9.10.1 and 3.9.10.2. In addition to requiring all fuel assemblies to be removed from core cells associated with removed control rods, TS 3.9.10.1 and 3.9.10.2 require minimum shutdown margin to be maintained in accordance with TS 3/4.1.1. Under these conditions, it is not possible for criticality to occur in the event of a withdrawal of a single control rod or loading of fuel assemblies into a single core cell with no control rod insened. Therefore, the proposed change does not involve a significant increase in the consequences of a previously evalua. tad acebt.

F.nclosure 2 to
.'     NRC-98 0008 Page 3
: 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Repositioning of the reactor mode switch to test refueling position interlocks is pennitted by both the existing and proposed TS. The proposed change alTects only the conditions unde. which the mode switch can be repositioned. The proposed changes do not change underlying principles affecting the way in which the plant is operated and no new or different failure modes are introduced by the proposed change for any plant system or component. No new limiting single failure has been identified as a result of the proposed changes. Therefore, no new or different types of failures or accident initiators are introduced by the proposed changes.
: 3. The change does not involve a significant reduction in the margin of safety.
The proposed change described above affects the conditions under which the reactor mode switch can be repositioned to accommodate refuel position interlock testing.
The proposed change in combination with existing restrictions within the TS provide assurance that there is no credible mechanism to initiate a reactivity excursion during interlock testing. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
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