NRC-90-0125, Application for Amend to License NPF-43,implementing Expanded Operating Domain for Plant.Proprietary NEDC-31843P, Fermi-2 Max Extended Operating Domain Analysis, Withheld (Ref 10CFR2.790)

Application for Amend to License NPF-43,implementing Expanded Operating Domain for Plant.Proprietary NEDC-31843P, Fermi-2 Max Extended Operating Domain Analysis, Withheld (Ref 10CFR2.790)

ML20059H214
Person / Time
Site:	Fermi
Issue date:	08/20/1990
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19302E206	List: ML20059H218 NRC-90-0125, Application for Amend to License NPF-43,implementing Expanded Operating Domain for Plant.Proprietary NEDC-31843P, Fermi-2 Max Extended Operating Domain Analysis, Withheld (Ref 10CFR2.790)
References
CON-NRC-90-0125, CON-NRC-90-125 NUDOCS 9009170046
Download: ML20059H214 (19)

Text

{{#Wiki_filter:W/ f4 a 3 Q;L d i y'.. c f ,L f,7,*d, R;',,a.4 i a i,~$\\ ' l9ermi3' s. M',t - - l .-.I L n. JOnkpTn . W.W., ; i opes not ope,retw 3 m 4 s; f1 I August 20, 1090 > NIC-90-0125~ 1 - U.' S. Mxilear Regulatory Commission Attnt: Document Control Desk . Washingtoni D. C. ' 20555.

References:

-:1)-; Fermi 2; - NBC Docket No. 50-311 NIC License No. WI ; p

2) Detroit B31 son Letter to NIC, " Proposed Technical-

- Specification Change - (License Anendnent) - Cycle 121 Extension 'Using Increased Core Flow and Final Feedwater Tenperature. RaSuction," N10-90-0080, dated! May.18,11990 g 3)V Detroit B31 son letter to NIC, " Proposed Technical l Specification Change (License Amendment) 4 . Elimination of Cycle Specific Parameter Limits"i, NBC-89-0299,' dated March 26, 1990 4)? Detroit Edison Letter to NIC,J" Proposed _ '1%chnical< Specification Changes to Allow operation with an? Extended Operating Domain", NIC-89-Oll5,: dated May 31, 1989

Subject:

Proposed Technical Specification Change (License a Amandnent)'- Maximm Fvnande I (beratina Dramin Pursuant to 10CFR50.90, Detroit Edison Coupany hereby proposes'to' anend Operating License NF-43 for the Fermi 2 plant by incorporating ' the enclosed: changes :into the Plant Technical' Specifications. The m -proposed change inplements an expanded' operating domain for Fermi 2. - Operation in the' expanded operating. domain has.been analyzed'using: methods approved by the NIC for General Electric (GE) to meet established regulatory criteria. The. expansion of the operating: domain allows the fuel cycle econcinics and plant capacity factor to be; enhanced. through inplenentation of flow control spectral shift - operation and increased core flow capability. To ensure the availability of'the expanded domain,' nodifications to the ' Average Power, Bange Monitor (APIN) and Rod Block Monitor (RIN) systems are necessary. These modifications will upgrade the RBM system to inprove the man /nachine interface making the system response more predictable and permit more direct thermal limits administration. To support the 9009170046 900820 ^ n E. PDR ADOCK 0500034.1 ,,0 1 P PDC 1 (is ( s

.k 5 + me -- ,m .s-w s z~~ ' Q Ml, gg M2 August 20,:1990 3 yj u *

• L15C-90-0125" g,

y LPage}27 g 1 QW necessary hardware modifications to be performed during Fermi < 2's ~ second ' refueling outage, issuance of the proposed anendnent by March 1, 1991 is requested. The proposed anenonent should be-n, ,v l 1

ieffective upon'startup from the second refueling outage.-

W i p ~ provides a description and evaluation of.the proposed l change. Enclosure 1 also contains further-infornation concerning the - W Reference 2 proposal. Diclosure 2 provides a sumnary of. the proposed ~ g Technical Specification changes on a page by page basis. Enclosure 3 provides:the proposed Technical Specification pages. u 4 Lh provides GC's report NEDC-31843P, " Fermi 2 Maxinum Extended' Operating Domain Analysis." This report is. considered by E to be proprietary information. Enclosure 5 provides E's affidavit to e that' effect. f Accordingly, in accordance with 10 CFR 2.790, it is requested that Enclosure 4.be withheld from public disclosure. l Enclosure 6 provides E's report NEDC-31515, Rev.,1, "Maxinum Extended Load Line Limit and Feedwater Heater Out-of-Service Analysis for r uh Enrico Fermi Atomic Power Plant Unit 2.' Enclosure '7 provides a i sanple Core ~ 0perating Limits Report which inplenents the ext.4)oed domain.- The package _ of hardware and Technical Specification chmges described p ini this submittal represent proven techniques to enhance p1mt~ T l-operation.. Similar changes have'been approved for othe : BWR plants. 1: L Detroit Edison has evaluated the proposed Technical Spacifications } against the criteria of 10CFR50.92 and determined that no significant-l hazards consideration is' involved. The Fermi 2 Chsite Review 1 m Organization has approved'and the Nuclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the i w l: enclosed determinations. In accordance 'with 10CFR50.91, Detroit L L Edison -is providing a copy of this letter to the State of Michigan. p If you.have any questions, please contet Mr. Glen D. Ohlemmber at (313) 586-4275. o Sincerely, J r l f Enclosure cc: A.'d. Davis R. W. DeFayette .W. G. Rogers J. F. Stang y Supervisor, Electric Operators, Michigan E Public Service Ccmission - J. R. Padgett r 3 x -\\; f;

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? % w7 7 Fil M 9;g W (r u.- l .o _ii I, WILLIAM S. ORSERi do hereby affirm that the foregoing statements ' are based on facts and circunstances which are true and accurate to ~ ~

the best of mf knowledge'and belief.

4 L% \\,0lY ) . _ ;\\iN lf. / 4(,,,,4/ j, "'

• WILLIAM S. ORSER.

E Senior Vice President 2,, e q .sig i Onthib day of //C/SI .-1990,-before me: personally appeared William S.' Or'ser(4eing first _ duly sworn and says that he executed the foregoing as his: free act and deed. 4,.., t s 1 I. 4 s -..,i s, t i; , jfoWb& A/RC y Notary Public' s ROSAUE A ARMETTA i Notory PubHc. Menroe County,Mi My Commission ExpuesJan.11,1992 t .} .e J

/ y ] h3 - p. // l 't' 3- . Enclo2ure 1; NRC-90-0125 ? Page-1; ,1 % s i fN INTRODUCTION The proposed amendment consists of several chang 6s that' will permit'an 1 ' expanded operating domain for Fermi 2,Ca General Electric-(GE)-BWR/4 , My . unite. The expanded operating-domain is based on analyses performed by GE using methods as described.In Enclosure 4, GE report, NEDC-31843P, c " Fermi 2 Maximus Extended Operating Domain Analysis" and Enclosure 6,- ,,S GE Report NEDC-31515 Rev.1,1"Maximun Extended Load Line Limit and Feedwater Heater Out-of-Service Analysis for_ Enrico Fermi Atomic Power' Plant Unit 2." Tha e enalytical methods have been previously' applied-1 to support changes, vhich have been approved by~the NRC, to the operating domain of other BWRs.- The Maximus' Extended Operating Domain (MEOD) includes: (1) ' Operation at rated power with up_to 105% of rated core flow. + ~L (2)- Operation with a 50 F reduction of final feedwater temperature. from normal feedwater heating.. o (3)' operation at~ rated power with core flow as low as 75% of rated. - The MEOD 1.s, applicable both during and beyond the normal fuel cycle ast supported by the cycle-specific reload analysis. 4, To ensure the availability of the MEOD, plant hardware changes to the Rod Block Monitor (RBM) and Average Power: Range Monitor (APRM) systems

are necessary. The' changes are made to allow access-to the full analyzed' domain and,.in the case of:the RBM, incorporate. advanced

= electronics'for improved' accuracy and reliability. 4 Reference 2 provided proposed Technical Specification (TS) changes to ' allow the extension of the current Fermi 2 operating: cycle using-increased core flow and final feedwater temperature-reduction techniques. ' The approval of the Reference 2 change is tnot necessary - for the approval of this submittal.. However, deletion of the L Reference 2 provisions, which will no longer'be necessary after the end_of the current operating cycle, is addressed in this proposal. Reference 3 provided proposed TS changes to relocate cycle-specific: parameter limits from the TS. This proposal is based upon the approval of this pending proposal. The attached TS'pages have been marked accordingly. F The proposed TS changes are based upon the Enclosure 4 GE report, NEDC-31843P, " Fermi 2 Maximun Extended Operating Domain Analysis." This report extends an earlier analysis, described in GE Report o h-g

i 3 Rm j M 'M 4 Encitsura 1 f NRC-90-0125i .m ,Page 2.

g., *

,y lff 1 h# NEDC-31515 Rev. 1, "Maximun Extended Load Line Limit and'Feedwater-e + Heater Out-of-Service Analysis for Enrico Fermi Atomic Power Plant: J Unit 2.": NEDC-31515L Rev. 1 is included as Enclosure 6. -This analysis was previously submitted in support of the Reference 4 request which was approved as Amendment 42 to the Ferai-2 operating license.1 UN gTogether, the. Enclosure 4 and 6 reports' provide the basis for operating in.the full Maximus Extended Operating Domain. The bounding = ,y analyses-in both reports are performed assuming the core configuration ou and conditions of the operating cycle which were current at:the time of the report; Cycle.2 and Cycle =1 respectively.in these cases. The, a * -results are then carried forward to subsequent' cycles through the use. y, WF of cycle-specific reload l! censing analyses. The cycle-specific reload. licensing analyses use assumptions land initial _ conditions consistent with the bounding MEOD~ analyses ensuring.that fuel design changes are within..the' licensing limits. In this manner, the licensed-g operating domain is maintained on a= cycle to cycle basis without-the. ym need for the: full in-depth review necessary for a change-in-licensed j . operating domain.. With the advent.of the' relocation of cycle specific parameter limits,: the means are established to accomplish the normal cycle to cycle analysis without an operating license amendment. The cycle specific information is located in a new report called the Core Operating Limits Report (COLR) ;'By the!very nature of the MEOD. improvements the [. methodology of how the core thermal' limits.are applied is altered. In order to more fully' display-how these changes are Juplemented, a i ' sample COLR for the new method is included in Enclosure 7. The Enclosure 7-sample COLR is provided solely to illustrate'the proposed changes necessary for'MEOD implementation. The initial. Limplementation of the'MEOD is anticipated in Cycle 3 and will utilize a-different COLR which will be' based upon the Cycle 3 reload licensing f_m

analyses,:which are currently in progress. However, it is anticipated M

that the Cycle 3 00LR will.be very similar in format to the Enclosure M* 7 COLR, and-therefore the Enclosure 7.COLR canibe effectively utilized (' .at Fermi 2. for the purpose of understanding the proposed implementation of MEOD. M w, l The necessary TS changes (Enclosure 3), which are described in Section 17 of the Enclosure 4 report, fall into four. categories as follows: l W (1) Delete the flow-biased APRM. scram and rod block trip setpoint A setdown requirements, delete reference to the kr flow i> adjustment-factor, introduce power and flow dependent Average l' 1 !L s M

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• \\

>x, gyf;g ~ j N !? tc .Enclosur3.1; ((i" NRC-90-0125W bl, Page J ,1 i

• [ Mh Planar Linear Heat Generation ~ Rate (APLHGR) and Minimus Critical

.i. ] -Power Ratio (MCPR) limits. 2))Modifytheflow-biasedAPRMscramandrodblocktripequations'to' (' X s E, accommodate an~ expanded operating domain. 7 (3) Modify the RBM trip setpoints and RBM systea~ operability. requirements and relocate-the RBM trip netpoints to the Core 1 . Operating Limits Report (COLR). (4). Modify setpoints associated with recirculation systea-flow to accommodate core ficy greater thna rated. In addition, eppropriate TS Bases changes are.necessary. Each-category of change is eval e ed separately below. Further, Enclosure g 2 provides a page by page braaMown of the proposed TS changes.- ETALUATION^ iProposed Change Number 1 m Delete the flow-biased-APRM scram and rod block trip setpoint setdown requirements, delete reference to the kr. flow adjustment factor,

introduce power and flow dependent Average Planar Linear Heat

Generation Rate (APLHGR) and Minimum Critical' Power Ratio (MCPR).

T limits. Basis. 'The proposed change eliminates.the requirement-for setdown of the flow-biased APRM scras and rod-block trip setpoints when the Maximum Fraction of Limiting Powe: Density (MFLPD) is greater.than the Fraction =of Rated Therns1 Power (FRTP) and substitutes adjustaents to the MCPR and APLHGR~o"erating limits that are flow and power dependent. The APRM scram and rod block setdown requirement originated from the Minimum Critical Heat Flux Ratio (MCHFR) thermal limit criterion. Since then, improved methodologies have been developed. The GESTAR II/GEIL correlation, which de-emphasized local thermal-hydraulic conditions, was accepted by the NRC as one of the criterion used to satisfy General Design Criteria 10 of 10CFR50,. Appendix A. Additionally, m. secondary relience on the flow-biased APRM flux scraa in licensing transient evaluations, for transients terminated by an anticipatory or direct scram, allows for more effective and operationally acceptable alternatives to the setdown requirement. 4 i

(; Y + y 1 s A4 y PM ~ NRC-90-0125 j@I LPage,4! ~ 3 QH ] 4 4 'An'alternat'ive method of-assuring that the safety limit MCPR and fuel-m Yl -thermal-nechanical design bases are not violated is to define the . operating limit MCPR and APLHGR' limits such that no postulated q' e Etransient event,'if initiated from other, than rated power or flow conditions,~could result in violation of either_the safety limit MCPR ~ 4 g or.the fuel thermal-mechanical design bases? Evaluations to determine g =the flow and power dependent requirements on the MCPR and APLHGR-i limits werel performed and are. described in{ detail._in the; Enclosure 4 l] W report. The results of these' evaluations were used-to determine the q g .following' set of flow and power dependent parameters for the fuel- ,de designs-present at Fermi 2:= ~ q y v '> A new power dependent MCPR limit, MCPR(P). J a) K. b). A new power dependent APLHGR limit, MAPLHGR(P). t 9., c) A new flow dependent MCPR limit, MCPR(F), which replaces the current'kr MCPR aultiplier, and: iQ d). A new flowLdependent APLHGR limit, MAPLHGR(F). 4 uL, ' Since the. MCPR(F) limit replaces the kr factor, all references to kr have been deleted. Consistent with the approach of;the a elimination of cycle specific parameters, such as kr, from the L, Technical Specifications,-the-parameters which are used:to determine j E> thermal' operating limits are reported in'the Core. Operating limits . Report for each cycle. The governing.MCPR and APLHGR limit for any. i power and flow condition is the more. limiting of the values as adjusted by the core power and flow dependent factors.. ) p, L W ^ The power dependent requirements, MCPR(P); and MAPLHGR(P), were derived-from analyses of the limiting transients,; turbine generator trip without bypass and feedwater controller failure.- The MCPR(P) bounds-4 'the' initial'MCPR needed to meet the GESTAR II requirements for each ,4 transient event. The power dependentLMCPR requirements are also (, 4 consistent with-the definition of the.RBM setpoints and.the rod. withdrawal error.(RWE) analyses described 11n Proposed Change Number 4

3. 'The MAPLHGR(P) requirement was determined from the same cransient W

evaluations used;to determine.the MCPR(P) and demonstrates compliance-Q with'the fuel thermal-mechanical design basis. m@W, The flow dependent. requirements, MCPR(F) and MAPLHGR(F), were derived- . 1 k; l m' ' P from results of' analyses of the slow-flow (recirculation flow) runout j event. The MCPR(F) requirement serves the same purpose as the current s-kr multiplier which it replaces. The MAPLHGR(F) requirements are specified in terms of a multiplier, which is applied to the full power and flow fuel type and exposure dependent APLHGR limits. This J.js t e l l~.

f: y; glb y = [ Ql !E5. ; Nil N;sur, #%o '," ,EncloIura 1' --1 f ypF", y NRC-90-0125 M %,q Page 5' O s >l{f,,, u ) n ? = multiplier has been derived such that the peak transient APLEGR during 1 'the slow-flow runout transient will not increase above the fuel i thermal-mechanical design bases values. The flow dependent APLHGR-it, . requirements.also bound-the APLHGR requirements which'are needed to-3 k,y demonstrate conformance to 10CFR50.46 and 10CFR50, Appendix K as g reported ~in Enclosure 4.. The elimination of the APRM setpoint'setdown and substitution'of core. G, 3 ?9._ flow and. power dependent ~1imits provides more direct administration ofy h@t fuel thermal limits compared with the current' practice of increasing: 1(T the APRM gain to' sake the.APRM indicate greater than the MFLPD times v1 ~ 100%. 1 Proposed Change Number 2 E K..' [ . Modify the flow-biased APRM scram and. rod block trip' equations to- 'l acconnodate;an expanded operating domain. I 1 Basis s E.C (~.' 'The current'APRM scram and rod block trip. equations do not allow full l access to the expanded operecing domain.' The. proposal provides new. "j ) 1 equations-to allow full' access to the expanded operating: domain. E The purpose of the flow-biased APRM rod block trip setpoint is to block control rod withdrawal when core power significantly exceeds-l + normal. limits and. approaches the scram. level. Should operation . continue-in a manner such that the power / flow condition exceedsithat specified by-the APRM rod block'setpoint, the flow-biased'APRM'acran. trip'setpoint would initiate'a scram.' As such, the flow-biased APRM rod block provides a buffer in power and flow conditions from the flow-biased APRM scram function.- ,4,+ Both the current and proposed formulation of the flow-blased APRM 1 scran equation are clasped such that a maximum value of the. trip setpoint is less than-the trip setpoint of the fixed neutron flux scram.. The proposed formulation does', however, reach this marinua at- 's a lower flow condition. The' current formulation of the flow-biased i 'RM rod block trip equation maintains a power and flow buffer over the entire applicable power and flow range ~without any need.for . clasping.. The' proposed formulation of the flow-biased APRM rod block /(& - trip equation. requires a clamp to provide a similar buffer. The current configuration-of. the electronics of the APRM rod block systen at Fersi'2 will require modification to accommodate this clamping function and'to establish a maximum trip value. The modification will

Y, #

consist of changes in the cards in the APRM drawers which electronically implement the required flew biased setpoint for the rod r.p> 4 I ) s

4 kk im 31% b! / r.e 1 [:W{ , Enclo: urb 1' i NRC-90-0125 1 Page 6-s 9 M, -i ei > block trip. These modifications are to be performed during the' ' upcoming second refueling outage. Proposed' Change Nunber 3 i w i Modify the'RBM trip setpoints and RBM system operability requirementat and relocate the.RBM trip setpoints to the Core Operating Limits Report (COLR). 1 %y 4 Basis <t The RBM system is explicitly designed to altigate the consequences of' i the rod withdrawal' error (RWE) event and is not assumed to be t .available-to mitigate any1other. anticipated operational occurrence.. U The current'RBM'systea configuration is described in detail in Section' t E. 15.1-of Enclosure A The modified RBM system configuration is s W -described!in Ssetion:15.2 and Appendix A of, Enclosure 4. The modified RBM systeis uses advances in' electronics:to enhance instrumentation ' accuracy and to improve the signal to' thermal margin correlation.- j W p 1 Modification ofLthe RBM trip logic provides a system response which - more accurately' reflects the actual' margin to the safety. limit at E various power conditions. r 3 The:nore accurate response of.the RBM system will reduce the number of' rod blocks which are not associated with reduced' thermal margins. The 9 operator.will-be better able to predict system response which improves .j ll -the man / machine interface and enhances safety. Coincident with the analyses of the modified RBM system, a generic RWE 7 approach was'taken'suc that neither the safaty-limit MCPR nor the -{ fuel thermal-mechanical design basis is jeopardized. This approach-n included' determining appropriate MCPR requirements and corresponding. j RBM power' dependent setpoints'for the modified ~RBM system for current = 1 fuel designs. By_an appropriate selection of the setpoints,-the RWE1 will not be the limiting. event'and will'not determine the operating , J t limit MCPR. In this respect,-the RBM setpoints are dependent upon the' operating limit MCPR values which depend on the cycle-specific l conditions. For these reasons,'the proposed change incorporates a reference to the Core Operating Limits Report for the specified'RBH setpoints. i .The proposed ~ change also modifies the RBM system operability requirements. The RBM system is onlytused to mitigate the j consequences of the RWE event. When core conditions defined by the thermal power and actual operating MCPR are such that a RWE event-cannot violate the safety limit MCPR, the RBM system is not required to be operable. The generic RWE analysis described in Enclosure 4 was o -/ .2

( y ?:% ~ " ~ '~~ ~~ ' ' ~ ~ fj;ij!p ' 9 N,'4 Encloruro 1. NRC-90-0125 %,yNT 4~

Page. 7 y

$f +

• m used to determine the initial MCPR that was needed to" assure that the:

u p complete withdrawal of any single rod would not violate the safety L L11mit MCPR. Whenever the operating MCPR is above these. values,.RBH operability is not required. For these reasons,?the proposed change pg modifes the related RBH; system operability, criteria. The proposed o change ~ specifies MCPR and' thermal power requirements that must be met-for RLM system operability requirements to:be applicable. l 7 [ Proposed Change Number 4 I Modify setpolni,s associated with recirculation system flow'to

?

1 acconnodate' core flow greater than' rated. is -Basis. [ o u The setpoint for the: Reactor Coolant System Flow Upscale rod block:Is currently low enough to potentially restrict access to'the full MEOD.. V Since the purpose.of this rod block is to indicate and terminate' , departure from the: licensed domain lit-is appropriate to. adjust-this i 4 E setpoint. The proposed setpoint'is conservatively-set'as_ recommended _ p/ tin the Enclosure ~4 report. 1 t 1 I Currently, the TS required Recirculation Pu:ip Motor Generator Set scoop-tube mechanical and electrical stop settings.will not allow i access to the full MEOD. These settings affect the' severity.of.the-o k< slow flow-runout event. This is the -limiting' event to determine the MCPR(F) and-MAPLHGR(F) values. Since the stop settings'are variable,. tthe MCPR(F)'and MAPLHGR(F) curves are provided by~GE for various h

possible settings. The TS values.are proposed to be changed to the values' recommended in-the Enclosure 4 report. These. settings provide J

a similar margin to the.sarinua allowed recirculation flow as the current TS requirements. Discussion of-Reference 2 Proposal i -The Reference 2 TS change proposal was submitted in'May.1990 in order to' apply-the cycle extension; techniques supported by the Enclosure'.4 report '_in-a ' limited manner _ to the current operating cycle.. Reference L 2 was based-upon the Enclosure 4 evaluations and analyses available at that' time. As indicated'in Reference 2, the evaluation of the impact ~ of the proposed changes on reactor internal = components and flow induced vibration.were in progress. These evaluations-have now been satisfactorily completed and are included in Sections 12.0 and 13 0 of q 4 the Enclosure 4 report. .t Reference 2 also presented the results of transient analyses to support the proposed change. The results are summarized in Table 2-2 g > !) d .D

@/( h j" d']"~~ ~ ~ ^ ^~ ~ ^ ~ ~ ~ ~ 3 ./ 1; y +, j y, i a! Yi (,9::. , \\ X Enc 1ccur3,1, ,Q 'g 'NRC-90-01251 + Page 8 w (p f ['E ' on page 30 of.the GE evaluation included in Reference-2. The Turbine: O Generator Trip.without Bypass transient of Table; 2-2 corresponds' to' ]*< 1 Case 19 of: Table 6-4 offthe Enclosure 4 report. j The Table 6-4 presentation >shows a 0.01 increase in 0perating Limit ~ i W,1 MCPR-(1.27 to 1.28 for Option B and 1 31 to 1 32 for Option A) for the' .same. transient reported in Table 2-2.. Following'the Reference 2 i submittal,:GE determined that the modeling~of Turbine Control Valve l Li ' closure associated with a recent' change in computer hardware / software jwy

required'an associated chenge in input. parameters. This; input' change 1

a had not.been made'for the Reference 2' case. The modeling discrepancies'did-not cause a variation from the expected-range-of results when analyzed.for the Reference 2 submittal. However, when. -j the off-rated cases for this report were run the variation in results; 7 D, 1 bervie significant enough to be detected. The Casez19 transient was-1 th d reanalyzed-and the result changed by 01 during the rounding off . process..The new result has been reported in Table 6-4. The results for this transient'.are still bounded by the Cycle 2 MCPR [ limits.- Therefore, the change has no effect upon the Reference 2;TS-r' jJ changes since the current Cycle 2 limits are still applicable. a SIGNIFICANT HA7ARDS CONSIDERATION. -In-accordance with 10CFR50 92, Detroit Edison has made a determination s LT' that the proposed amendment involves no significant hazards u coni:iderations. - To make this.. determination, Detroit Edison must' establish that operation in accordance with'the proposed amendment .would not:

1) involve's significant increase:in the probability' or :

consequences oflan accident previously evaluated, or 2) create thei possibility of a new or different kind of accident.from any accident r previously. evaluated, or 3) involve a significant reduction'in'a margin of. safety. The' bases for this determination are as follows: j Proposed Change Nunber 1 ~ Delete the flow-biased APRM scram and rod block trip setpoint setdown requirements, delete reference to the kr flow adjustment factor, j introduce power and: flow dependent adjustment factors to the' Average . Planar Linear Heat' Generation Rate (APLHGR) and Minimus Critical Power Ratio (MCPR) limits. t ? t r Basis The change does not involve a significant hazards consideration for i the following reasons: 6

+ w .a \\ h. 3 y w. m Lo Ml

Enclosure l' L.:

NRC-90-0125i m.

N M,. -Page 90 s + > m s'a 3) Changesfin-the operating limit values will maintain existing-

aargins to the safety limit'.,0peration within_the operating m

y' limit will ensure that the~ consequences of any accident which sA could occur would be within' acceptable limits. There will be no impact on the probability of any accident. previously evaluated 'U a; b ^' .since the change applies a new methodology for assuring that the fuel thermal't nochanical-design bases are satisfied and has no - aC effect upon any accident initiating mechanism. The proposed mj . change causes adjustaants to be made to'the:MCPR and APLHGR R1 ' limits as;specified-in the Core Operating Limits' Report (COLR) as L) 9' functions of core' flow and power. These adjustments are. determined using NRC approved methods asirequired~by the-g" TechnicaltSpecification requirements for the.COLR.- The adjustments. impose restrictive conditions _on plant-operation such that' the' consequences. of anticipated.. operational" occurrences cre. no more. severe than the most limiting condition using the current-Technical Specifications with flow-biased APRM scram and rod , 3. block setpoint setdown provisions. Thus, there is no significant. change in the consequences of any accident previously evaluated. 2) TheIproposed change eliminates the revirement for.setdown of-the flow-biased APRM scraa and rod block trip setpoints under specified conditions and substitutes adjustment factors for-the MCPR and'APLHGR-operating limits. 'The proposed change provides a new method of limiting. plant operation so.that the fuel thermal 'and mechanical design bases are satisfied. 'The change does not -cause"a physical change to the plant or-introduce a new mode of operation. Therefore, the proposed amendmentdoes not create the possibility of a new or different kind of accident from any, accident previously evaluated. 3) The flow and power-adjustment factors were determined using NRC approved methods and' satisfy the:same NRC approved criteria set by analyses assuming;setdown of the flow-biased APRM scran and rod block setpoints. Therefore,-the proposed amendment does not involve a significant reduction in a margin of safety. Proposed Change Number 2 Modify the flow-biased APRM scran and rod block trip equations to accommodate an expanded operating domain. Basis ,m The change does not involve a significant hazards consideration for the following reasons: 1 b

hjy?%g M6, ' 3 $$pf v, L~' g%ks;> 3 Encic2urs 1 4 A ':NRC-90-0125 1g, Page110 1 y E4 a 3-ggsi 3 j m f3 p

1). 'The proposed change expands the power and flow operating domain:

= a& by relaxing'the restrictions imposed by the formulation of the Wh/! ' flow-biased APRM rod block and scraa trip setpoints;. The-i py ( j probability of any accident is not significantly increased by. 7, operating-in the expanded operating domain because the-q - formulation of thel flow-biased ' APRM rod, block, trip. equation.. ,(y (including'a new maximum value-for the'APRM rod block) has been 3 fp, modified to still maintain sufficient margin.between the' rod-. 1 %k block setpoint and the scraa setpoint.E The consequences ofJ @fr

anticipated operation occurrences have been evaluated-using NRC

p approved. methods.and the proposed setpoint formulations have..been- '[ se1~cted so as not;to involve a significant increase in:the @yM e consequences of any: accident. pw [ 2) Changing the formulation for the flow-biased APRM rod block and= II ~ scram trip setpoints does nat change their respective functions ' and-manner of-opar:. Lion. 'lhe APhs rod block trip setpoint will-continue to block control rod withdrawal when~ core power-R

significantly exceeds normal' limits and approaches,the scram-4 l:,

level. -The'APRM scram' trip setpoint will continue.to initiate a;, O scram if the increasing power / flow condition continuos isyond' the 1 s z% 'APRM rod block setpoint. Therefore, the proposed change does not J create the possibility of a new or different kind of accident' d

from any accident previously evaluated.

f y t 3)- The APRM rod block trip setpoint will continue lto block control. rod withdrawal'when core power significantly exceeds normal 1 . limits;and approaches the scram level. The APRM scram trip: 3 p y setpoint will continue to initiate a-scram if.the increasing 1 power / flow condition continues beyond1the'APRM rod. block' i setpoint.; Operation in the new expanded operating domain haai been analyzed by General Electric and sufficient margin to' design limits was found.to exist. Therefore,:the proposed: change does l ~ not' involve a significant reduction in'a. margin of safoty. Proposed Change Number 3' i Modify the RBM trip setpoints and RBM system operability requirements [ and' relocate the RBM trip.setpoints to-the Core Operating Limits Report (COLR). 1 [

E Basis j

.i l, The change does not involve a significant hazards consideration for l the following reasons: 1 lU j 5

7, 7 -L',:t ':.t [ s [ l(

)

I ~ B- - a W Enclorura 1 WM' 3 i .NRC-90-0125M i Page?11; s w i

1). The RBM system is not involved in the' initiation of any accident.

j&,1 and therefore does not increase'the probability of the occurrence of.any accident.: The RBH system only, serves to'altigate the -consequences of-one event; the rod withdrawal error (RWE) event. . Analyses of the RWE were performed using NRC approved methods for-the nodified setpoints.and operability-requirements. The resulta demonstrate that the consequences of.the RWE event are no more severe lwith the' modified RBM system than_with the~ current configuration. Therefore,,the proposed. change does not involve a. significant increase in.the consequences'of any accident'-

previously evaluated.

2) The' proposed change does not alter the function of any component 1 orfsystem otherLthan the RBM systea. The changes to the RBH ' l system have'been designed to enhance the reliability.and accuracy.- i of the RBH system without impacting the degree of isolation of ' $' e the'RBM system from.other, plant systems. The function of the RBM y system does'not change. Therefore, the proposed chango does not 1 + create the possibility of a'new or different. kind of accident 1 from_any accident previously evaluated.- ci:l -3) The proposed change revises'the setpoints for;the RBM system: j which is solely designed to mitigate the consequences of the RWE-event. Analyses-of<the RWE event'aretused to derive the d csetpoints such that~the safety limit for the minimum critical-1 . power ratio-(MCPR) will not be. challenged. -By an appropriate' -f selection of the setpoints, the RWE will not be the limiting Ll event'and will not determine the operating limit MCPR.- In this j 1-respect, the:RBN setpoints are dependent upon the operating limit s MCPR' values which depend'on the cycle-specific conditions..For-this reason, the proposed change'also identifies that these' j setpoints are specified in'the Core Operating Limits Report l g (COLR).1 The COLR.is prepared' based on the results'of analyses' 1 t ~ using NRC approved _ methods as required by Technical-Specificationc y requirements for?the COLR. The operating limit:MCPR maintains-the.: margin of safety for this thermal limit; Thas, the proposed i change does not' involve a significant reduction in a margin of' safety. 4 f Proposed Change Number 4 0

v M"

Modify setpoints associated with the recirculation system flok to acconnodate core flow greater than rated. b l +a=- = 3

j $ pg. mi @i 8l Q g% $hi ' .Enclorur311: NRC-90-01251 @M' Page-12 ( m.4 kW ] N,l " 4 Basis y Y * #m The change does not involve a significant hazards consideration for .l the.following reasons: gA >, ' g (g # 1) The proposed change expands the power _and flow operating domain WM by relaxing the restrictions imposed by the Reactor Coolant 4 Systen Flow Upacale' rod block and-Reactor Recirculation set scoop-tube setpoints. The probability of any accident'is not p;l. g L significant1y' increased by operating at a higher core flow. f. because the Reactor Coolant Systen Flow Upscale rod block and-l\\, Reactor Recirculation Set scoop tube setpoints have been modified W .to provide the'same protection as currently exists.m The a consequences of anticipated operational occurrences have been evaluated using.NRC approved methods and the proposed setpoints have been selected so as not to involve a significant increase in s, the consequences of any accident. 2)- Changing the Reactor Coolant Systen Flow Upscale rod block and 'g Reactor. Recirculation Set scoop tube setpoints does not change their respective functions. The Reactor Coolant Systen Flow c Upscale rod 1 block trip setpoint will continue to block control i e L rod withdrawal.when core flow significantly exceeds design -i l' bases. 'The Reactor Recirculation Set scoop tube settings will y mtinue to terminate a' flow increase significantly leaving' the : .. wensed operating domain. LThe proposed change does not affect the manner of. plant' opera & ton within'the new limits. Therefore,' l .the proposed change doe' - create the possibility of a new or. .diffeeent' kind.of accif .c from any accident previously IL ' evaluated. '3) As stated above, the Reu tor Coolant.-System Flow Upscale. rod _ ll block and Reactor Recirculation Set. scoop tube setpoints will. y' ', continue to perform their respective functions. Operation with increased core flow, as. allowed by these'setpoint changes, was analyzed by General Electric and sufficient margins to design limits were found'to exist. Therefore, the proposed change does not involve.a significant reduction-in a margin of safety. Bised on the above, Detroit Edison has determined that the proposed J amendment does not involve a signific.snt hazards consideration. ,.o I~ ENVIRO 10 ENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental E considerations. The proposed change does not involve a significant I: L 0

y I' Bnclesure 1 = NRC-90-0125 Page 13 p- . ft hasards co'.isideration, nor significant1y' change the' types or f/ significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based en the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 13'FRS1.22(c)(9) for a es egorical exclusion J from the requirements for an Environmental Impact Statement. CONCLUSION Based on the evaluation above:

1) there is reasonable assurance that the health and safety of the public will not be end ngered by

? . operation in the proposed manner, and 2) such activit'as will be conducted in compliance with the Commission's regulations and the L proposed amendments'will not be inimical to the common defense and security or.to the health and safety of the public. t i i

Vl. g:- 3 l'. NRC-90-0125 Page I'- 1 r a i -1 i .3 1 L, i i f t Summary or Technical' Specification I' Change Pages - i i k i 1 1' j' s l ')i _ b, - 6 i 1 l l; l 1 e P k 'l

[.' EnclosurO 2 .NRC-90-0125 Page~2-j Page No. Specification Change } iv, xii Index Reflect deletion of Specification 3/4.2.2 APRM Setpoints. 2-4 2-2.1 Provide new flow biased APRM Scram forsulations for expanded operating h d w in. Single loop op& ration (SLO) values are based upoa a 4 W of 8% and are consistent /ith nrevious SLO Oy' values and SLO Esses (p.' B 2-7). l t B 2-7 2.2.1 (Bases) Deleted discussion of deleted requirements of Specification 3 2.2. 1 3/4 1-18 3/4.1.4 3 change rod block monitor (RBN) applicability to exclude time period I where Minimus Critical Power Ratio l is above value where RBN is needed. j l 3/4 2-5 3/4.2.2 Specification deleted. These 3/4 2-5a requirements replaced by power and i flow dependent adjusteent factors which are applied to MCPR and APLHGR limits. I 3/4 3-8 3/4 3 1 Eliminated provision related to deleted Specification 3 2.2. L 3/4 3-41 3/3 3 6 changed to reflect elimination of flow-biased RBN setpoints. 3/4 3-43 3/4 3 6 change RBN applicability consistent with change to 3/4.1.4.3 3/4 3-44 3/4 3 6 Provide reference to Core L:)erating 3/4 3-44 a Limits Report for RBM Upscala setpoints. Provide new flow-Liased APRN rod block formulations for expanded operating domain. SLO values are based upon'.d W of 8%. Footnote concerning APRN rod block mod!fird to reflect deletion of j Specification 3 2.2. Reactor Coalant Systen Recirculation Flo:*-Upscale rod block setpoints i. increased to acconnodate expanded Il operating domain. Footnoter added l. by Reference 2 are to be eliminated. 1 i i N.

m ~ l f -) lB 'kuclosure 2. p L KRC-90-0125 Y Page.3 h a Pane No. Specification Chante 3/4 3-46 3/4 3 6 Change RBM applicability to be consistent with change to 3/4.1.4 3 3/4 4-1 3/4.4.1.1 changed-to reflect elimination of-flow biased RBN setpoints.ard elimination of Specification 3/4.2.2. 3/4 4-2 3/4.4.1.1 New recirculation pump Mc set scoop tube mechanical and electrical stop overspeed setpoints provided.to F/ - accommodate expanded domain. Footnote added by Reference 2 is to be eliminated. B 3/4 2-ta 3/4.2.1 (Bases) statement added concerning the inclusion of power end flow dependent adjustaants in the 00LR.. .B3/42-2 3/4.2.2 (asses) Deleted assen which corresponds with deleted Specification 3/4.2.2. B 3/4 2-4b. 3/4 2 3 (Basesi Replace discussion of rf factor B 3/4 2-5 with reference to appropriate reports and the 00LR. Add Enclosure l 4 report t's list of referenoes. j [ l l-i 1 l l.; ) i (-}}