NRC-89-0108, Application for Amend to License NPF-43,modifying Tech Spec 3/4.3.8, Turbine Overspeed Protection Sys, to Better Specify Requirements for Sys

Application for Amend to License NPF-43,modifying Tech Spec 3/4.3.8, Turbine Overspeed Protection Sys, to Better Specify Requirements for Sys

ML20247R610
Person / Time
Site:	Fermi
Issue date:	07/24/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247R615	List: ML20247R624 NRC-89-0108, Application for Amend to License NPF-43,modifying Tech Spec 3/4.3.8, Turbine Overspeed Protection Sys, to Better Specify Requirements for Sys
References
CON-NRC-89-0108, CON-NRC-89-108 NUDOCS 8908080067
Download: ML20247R610 (7)

Text

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B. Ralph Sylyla __ __ _,._ _

senior v ce Pretudent DOITO,i,I . July 24, 1989 E a s m ~ m(313) ,g,o,,,,

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- "'c-8'-'2o8 U. S. Ibclear Regulatory Commission Attn: Document Control Desk washington, D. C. 20555

References:

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

2) NIC Generic Letter 87-09,

" Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting conditions for Operation and Surveillance Respairements",

dated June 4, .1987

3) Detroit Mison Letter to NIC, NIC-88-0062,

" Proposed Technical Specification Change (License Amendment) - Applicability (3/4.0)",

dated May'24, 1988

4) Detroit Mison J,etter to NIC, NIC-89-0047,

" Proposed hchnical Specification Cb.ange (Licenm Amendment) - Turbine Overspeed Protection System (3/4.3.8), dated March 10, 1989

Subject:

Proposed Technical Specification Change (Licenm AHerAr.-nt) - Turbine Overspeed Protection System D/4.3.8)

Pursuant to 10CFR50.90, Detroit Mison Coupany hereby proposes to amend Operating License IFF-43 for the Fermi 2 plant by, incorporating the enclosed changes into the Plant hchnical Specifications. The proposed change makes minor modifications to better specify the requiranents for the Turbine Overspeed Prote6 tion System. An associated Bases change is also included.

Detroit Mison 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 IUclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the

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July 24, 1989 NRC-89-0108 Page 2 i i h enclosed determinations. ~ In accordance with 10CFR50.91,. Detroit-

- Riison has provided a copy of this letter to the State of Michigan. ]

1 If you have any questions, please contact Mr. Glen Ohlemacher at'. (313) .

- 586-4275.  !

.I Sincerely,  !

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Enclosure-cc A. B. Das J R. C. Knop _

W. G. Rogers J. F. Stang -;

Supervisor, Advanced Planning and Review Section, .j Michigan Public Service Commission-id x-_________-.--__. ._-._- - _ - _ _ . - _ _ . - _ . , _ .___

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USNIC

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July 24, 1989 NIC-89-0108 3

' age 3 I, B. RALPH SYLVIA, do hereby ' affirm that the foregoing statenents are based on facts and circumstances which are true and-accurate to'the best of my knowledge ~and belief.

.B. RALI(I Senior Vi e President On this day of Odh . 1989, before me personally appeared B. Ralph Sylvgd,-' bejng first duly sworn and says that he executed the foregoing as his free act and deed.

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Notary Public i

D01NJE A. ARMETTA . 1 Notory Public. Monroe County.Mt MyCommissionExpiresJott 11,1992 I

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Enclosure to NBC-89-0108 Page 1

• lw m0 DUCTION Technical Specification 3/4.3.8, Turbine Overspeed Protection, provides the requirement that at least one turbine overspeed protection system be OPERABLE in OPERATIONAL CONDITIONS 1 and 2. If this is not possible, then the ACTION requirements provide that either the main turbine be isolated fram its steam supply or, in the case of an inoperable turbine valve, that the affected valve be closed.

%e proposal modifics the Applicability to better reflect when an overspeed protection system is nes3ed. The proposal also provides an exemption to Specification 3.0.4 to allow continued operation when the specified ACTION provides sufficient compensatory measures to fully restore the ability to terminate a turbine overspeed transient. We Bases are proposed to be expanded to better describe the turbine overspeed protection systems installed at Fermi 2.

EVALIRTION Specification 3.3.8 is currently applicable in OPERATIONAL CO10ITIONS 1 and 2. However, the potential for a main turbine overspeed transient is present only when steam is supplia5 to the main turbine.

The ACTION requirements also do not specify further ACTION beyond the point that the turbine is isolated from the steam supply. Therefore, it is proposed to change the Applicability to specify the additional condition "whenever steam is supplied to the main turbine". This will make the Applicability consistent with both the transient for which the Technical Specification is written to prevent and the ACTION requirements.

Detroit Edison considers this change acceptable since the safety bases of the Technical Specification is maintained by requiring the overspeed protection system to be OPERABLE whenever the possibility of an overspeed transient exists. The change further increases the consistency of the Technical Specifications and increases the flexibility for scheduling of maintenance of the overspeed protection system and associated turbine valves.

ACTION requirement a. provides compensatory measures for an inoperable valve associated with turbine overspeed protection. This ACPION allows continued operation for an indefinite period with the affected steam lead (s) closed. This ACTION restores the ability of the turbine overspeed protection systems to terminate an overspeed transient to the same level as would be achieved through full compliance with the 100.

Enclosure to NBC-89-0108 Page 2 Specification 3.0.4 provides that the applicable condition for the ICO shall not . , entered while operating under the provisions of an ACTION statement. aceptions are provided for where appropriate. Detioit Mison bel, eyes that it is appropriate to provide an exception to the provisions of Speciacation 3.0.4 for ACTION a. with the affected steam lead closed. Plant start-up and power operation at a de-rated load is possible with a turbine steam .tead closed. This may be highly desirable in the event that a long-term repair is required for a turbine valve. This operation should not be prohibited since the capabilities of the turbine overspeed protection systems have not been degraded.

Detroit niison considers this exemption from the requirements of Specification 3.0.4 acceptable because the level of protection against a turbine overspeed transient remains undiminished while operating under the ACTION requirement. Therefore, the proposal does not represent any reduction in safety. The proposal will prevent the unnecessary restriction of plant start-up and power operation in a condition where such operation should be allowed.

This exception from the provisions of Specification 3.0.4 is consistent with the NBC guidance in Generic Letter 87-09 (Reference 2). In Reference 3, Detroit Edison proposed a change to Specification 3.0.4 in accordance with the Generic Letter. Approval of the Reference 3 proposal would make the proposed change to ACTION a. '

unnecessary.

This proposal is indeperx3ent of the Technical Specification changes  !

proposed to the same Specification in Reference 4.

SIGNIFICANT HAZANDS CONbwtamTIm In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that operation in accordance with the proposed amendment  !

would not: 1) involve a significant increase in the probability or l 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.

The proposed change to limit the applicability of Specification 3.3.8 to whenever steam is supplied to the main turbine does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. Turbine overspeed i

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Enclosure to IEC-89-0108 Page 3 l

protection is only requird when the main turbine is operating.

Requiring overspeed protection at other times does not reduce the i probability or mitigate the consequences of any previously I' evaluated accident. %e elimination of the requirement, therefore, does not-increase the probability or consequences of an accident previously evaluated.

i

2) Create the possibility of a new or different kind of accident i from any accident previously evaluated. %e change solely makes '

the OPERABILITY requirements for the turbine protection system match the time period when a turbine overspeed event is possible. No credible mechanism exists to cause an overspeed condition to occur from an initial condition in which the j Specification is not applicable. The change, therefore, does not create a new or different kind of accident from any accident  ;

previously evaluated. ]

3) Involve a significant reduction in a margin of safety. The safety margin is maintained as the ICO remains applicable whenever the possibility of a main turbine overspeed exists.

%e proposed change to exclude ACTION a. of Specification 3.3.8 from j the provisions of Specification 3.0.4 wha operating with a steam lead closed does not:

1) Involve a significant increase in the probability or consequences )

of an accident previously evaluated. %e change solely allows change in OPEPATION COiOITION and entry into the applicable condition for Specification 3.3.8 when operating with an inoperable turbine valve for which the steam lead has been closed. In this situation, the ability of the turbine overspeed protection systems has not been degraded. Therefore, the  ;

proposal does not increase the probability or consequences of any previously evaluated accident.

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2) Create the possibility of a new or different kind of accident 1 from any accident previously evaluated. The proposal allows i entry into a condition under circumstances which, if they had occurred in the condition, would be allowed for an indefinite  ;

period of time. %erefore, the proposal does not create any new  ;

or different kind of accident frcan any accident previously  !

evaluated.

3) Involve a significant reduction in a margin of safety. The safety margin is maintained since the capabilities of the turbine overspecd protection systen are maintained.

Enclosure to IGC-89-0108 ~

Page 4 Based on the above, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.

ENVIRGOWNTEDOCT 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 or 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.

QQtGUSliti Based on the evaluation above: 1) there is reasonable assurance ' chat the health and safety of the public will not be endangered by operation in the prysed manner, and 2) such activities will be conducted in compliance with the Cammission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.

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