NRC-89-0158, Application for Amend to License NPF-43,modifying Tech Specs 3/4.3.5 Re Reactor Core Isolation Cooling Sys Actuation Instrumentation & 3/4.3.9 Concerning Feedwater/Main Turbine Trip Sys Actuation Instrumentation,Per GE STS

Application for Amend to License NPF-43,modifying Tech Specs 3/4.3.5 Re Reactor Core Isolation Cooling Sys Actuation Instrumentation & 3/4.3.9 Concerning Feedwater/Main Turbine Trip Sys Actuation Instrumentation,Per GE STS

ML20247R186
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
ML20247R193	List: ML20247R199 NRC-89-0158, Application for Amend to License NPF-43,modifying Tech Specs 3/4.3.5 Re Reactor Core Isolation Cooling Sys Actuation Instrumentation & 3/4.3.9 Concerning Feedwater/Main Turbine Trip Sys Actuation Instrumentation,Per GE STS
References
CON-NRC-89-0158, CON-NRC-89-158 NUDOCS 8908070381
Download: ML20247R186 (10)

Text

ma.--~~,.-.~- - -- -. - - - - - _ _ _ _ . . _ . . __ ___ __ _

. B. R 1ph CylAs Sen or vu.e Prewent tierroit -

Ec ison _=,..o_,,_, = "- -

t July 24,1989 I l@C-8!r-0158 L'

U. S. tar.: lear Regulatory Commission l Attention: Document Control Desk Washington, D.C. 20555 l

References Fermi 2 ,

NIC Docket No. 50-341 NRC License No IFF-43

Subject:

Proposed Teich".ical Specification Change (License Amendment) - Reactor Core Isolation Cooling System Actuat!on Instrumentation (3/4.3.5) and Feedwater/ Main l

Turbine Trio 91 stem Actuation Tnatrimmantation (3/4.3.9)

Persuant to 10CPR50.90, Detroit B51 son Ce=any hereby proposes to l

amerd Operating License NPF-43 for the Fermi 2 liiant by incorporating l the enclosed changes into the Plant Technical Specifications.

The change modifies the Technical ! specification provisions for the Reactor Core Isolation Cooling System Actuation Instrumentation and Foedwater/ Main Turbine Trip System Actuation Instrumentation to be more consistent with GE Standard 'hchnical- Specifications and to make the requirements clearer in regards to the required nunber of CPERhBLE instrument channels and the rquired ACI' IONS in the event of an inoperable channel (s) .

Detroit B$ison has evaluate $ 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 142 clear Safety Review Group has l revieweS the proposed Technical Specifications and concurs with the enclosed determination. In accordance with 10CFR50.91, Detroit B51 son has provided a copy of this letter to the State of Michigan.

A0Of J

B90B0703S2 890724 W PDR ADOCK 05000341Q s

P PNUij

" . .j .. .

USNBC July 24, 1989 NBC-89-0158 Page 2 If you have any questions, please contact Mr. Glen Ohlemacher at (313) 586-4275.

Sincerely, Enclosure cc: A. B. Davis R. C. Knop W. G. Rogers J. F. Stang Supervisor, Mvanc.ed Planning and Review Section, Michigan Public Service Canission l

k.

k - ;;i p7 5 9 'f ,

. -4

%l ,

i 4 .USNRC' 1 ~ ? July:24,1989c' NRC-89 0158

.Page 3 >

t

< 13 3 I, B. RALPH SYLVIA, do' herd >y affirm that' the' foregoing statenents are based on facts and circumstances which are true and accurate to the

'best of my knowledge and belief.

zy/ '

o B'.' RALPfi SYLp Senior Vice President f

7 1

- On this day of b n /)/ , 1989, before me personally appeared B. Ralph Sylpia,' t ing first duly sworn and says

' that-he executed the foregoing as his(wj ree act and deed.

A catY h.0Af)t W '

Notary Public RO"AE A ADMETTA Notory Public. Monroo County Mt MyCommissionExpirasJan. it 1992 l

1 l

I l'

[

l . - .

Enclosure to 4C-894158 Page 1 IN21GOCTION Fermi 2 Technical Specification 3/4.3.5 provides requirements for the Reactor Core Isolation Cooling (ICIC) System Actuation Instrumentation. We ICIC system provides core cooling in the event of reactor isolation from its primary heat sink and the loss of feedwater flow to the reactor vessel without providir;g actuation of any of the emergency core cooling equipment. This proposal concerns the requirements for the autmatic ICIC system initiation signal, Reactor Water Level-Low Level 2.

Fermi 2 Technical Specification 3/4.3.9 provides requirements for the Feedwater/ Main Turbine (NNT) Trip System Actuation Instrumentation.

The Fee 3 water / Main Turbine Trip System initiates a trip of the Feedwater Pump Turbine and Main Turbine on a High Reactor Water Level

- Level 8 signal. This proposal concerns the requirements for this initiating signal.

Tha low water level ICIC initiation logic and the high water level W/MT trip initiation logic each consist of four instrument channels arranged as shown in Figure 1. This configuration is commonly referred to as a "one-out-of-two taken twice" logic. We logic is energize-to-actuate. For the logic to actuate at least one channel output contact in the upper logic pair must close and at least one channel output contact in the lower logic pair must close.

This proposal modifies the manner in which the requirsents for the number of OPEPMLE instrument channels for these two trip functions are specified. The ACTION requirsents for one or more inoperable channels are also proposed to be modified. These changes are proposed to make these requirements more clear and more consistent with the GE Standard Technical Specifications.

EVAMRTION l The ICIC System Initiation (Beix: tor Water Level-Low Level 2) and the l W/MT Trip System Initiation (Reactor Water Level-High Level 8) logics j are both currently specified to have a Mininum Channels OPERABLE per j trip system requirement of 2 channels. Each logic consists of 4 channels in one trip system; therefore, this proposal increases the Minimum Channels OPERABLE per Trip System requirment for these two functions to 4 to ensure all of the channels are normally OPEPMLE.

Informational footnotes are also proposed to be included to ensure that the logic arrangement is clear.

I 1

l

)

n1 closure to IGC-89-0158 Page 2 Fermi 2 Technical Specifications were written with the philosophy that each logic pair (upper and lower) constituted a trip system. However, the conventional definition of a trip system is an interconnected arrangement of cmponents making use of instrunent channel outputs in the generation of a trip function when appropriate logic is satisfied. This change is being proposed to bring the use of the term

" trip system" in the Fermi 2 Technical Specifications into agrement with the conventional definitions of trip system, which is the philosophy used in GE Standard Technical Specifications and other BWR plant Technical Specifications.

Under both the existing Technical Specification philosophy ard the proposed conventional philosophy, 4 channels are required (2 channels in 2 trip systems versus 4 channels in 1 trip system) . Thus, the sole result of this change is to apply the conventional philosophy to Fermi

2. If the conventional philosophy were applied to the current requirements then the conclusion could be reached that only 2 channels in total are required. The proposal eliminates that possibility and thus provides a safety benefit by eliminating this possible misinterpretation and potential misapplication of the requirements.

~

The ACTION requirements for one or more inoperable channels in each of these trip systma must also be revised to reflect the proposed conventional definition of a trip system. For the ICIC system initiation, the IC' ION is specified in ACTION 50 of Table 3.3.5-1.

ACTION 50 also applies to the High Reactor Water Level - Level 8 ICIC System Trip signal item in Table 3.3.5-1. The current Specification correctly reflects the Level 8 ICIC System Trip logic. 'Ibe changes proposed below for ACTION 50 apply to both Functional Units.

Currently ACTION 50 is written based upon the existence of two trip systems in the Functional Unit logics for which it applies. Under the proposed use of the term trip system only one trip system exists in both affected logics. Therefore, the provisions no longer address two trip systems. Further, under the proposed philosophy, tripping the trip syrtem causes the actuation. This clearly is undesirable and has been eliminated as an option. l The proposed new ACTION 50 reflects the action which would currently be taken utilizing the trip system concept upon which the 'Ibchnical Specifications are currently based. This is to place the inoperable channel (s) in the tripped condition as lcng as the Functional Unit dces not actuate. If this is not done, the PCIC system is declared p inoperable since the ability of the actuation instrumentation to function i ccapramised. If the inoperable channel (s) is plzced in the tripped condition, then the remaining OPERABLE channel (s) preserve

Enclosure to NIC-89'-0158 Page 3 i the ability of the actuation instrumentation to function. This is l

consistent with the philosophy to allow continued operation with instrumentation logic partially actuated which is applied throughout the Instrumentation 'Iuchnical Specification section.

Table 3.3.5-1 footnote (a) currently contains a provision to allow l requird surveillance without requiring the trip systms to be tripped for a period of up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This proposal changes the footnote to l' reflect that the requirment being exempted is now to place the channel in the tripped conditicn.

L The ACTION statments for N/MT Trip Systm Actuation Instrumentation currently consist of three sections. ACTION a. provides that a channel is inopertble if its trip setpoint is less conservative than its specified allowable value. ACTION a. then further reg' tires tripping the channel or declaring the associate systes inoperable.

ACTIONS b. and c. currently provide allowed outage times for one and two inoperable channels respectively.

Rose ACTIONS are modeled after the GE Standard Technical Specifications (GE-STS) Specification 3/4.3.9; which is a standard for Plant Systems Actuation Instrument action. The GE-STS Specification is atttchd for reference. The W/MT Trip Systs is one of the systems covered in this GE-STS Specification.

The GE-STS ACTION a. is identical to the Fermi 2 ACTION a However, the subsequent GE-STS ACTIONS are separated by the Plant System of concern. STS ACTIONS c.1 and c.2 correspond to the Fermi 2 ACTIONS b.

and c.

The intent of the GE-S'IS ACTIONS is for ACTION a. to be entered first. An inoperable channel would either be tripped or the associated systs declared inoperable. If the associate systms were declared inoperable, then the appropriate subsequent AC ION would be entered. The subsequent ACTIONS were included in the STS since not all of the Plant Systms have STS specifications covering them. This is the case for the N/MT Trip System in both GE-STS ard Fermi 2 Technical Specifications.

The subsequent STS ACTIONS for the N/MT Trip System provide requirements with the number of OPERABLE channels one and two less than required. The two less than required case allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to at least restore 1 channel to OPERABLE status and thus be in one less than required case which has a 7 day allowance to restore the remaining inoperable channel to OPERABM status.

o eg[ .

Biclosure to NRC-894158 -

.Page 4 I %e Fermi 2 ACTIONS are proposed to follow the intended course of the GE-STS ETIONS as closely as practical. ACTION a. solsly requires a channel with a trip etpoint set less conservative than the allowable-

.value to be declared inoperable. Provisions for tripping inoperable

channel (s) are now included in ACTIONS, which covers the ACTION for an .

inoperable channel (s) .

, Since there are no Fermi 2 Technical Specification requirements for b the IM/MP Trip System, the option of declaring the associated system inoperable has been deleted.

ACTION b. first provides the option of tripping' the inoperable channel (s), provided that this does not cause an actuation of the FW/Mr Trip System. If this is done the ACTION is complete and the functional ability of the IV/Wr Trip System is maintained. n is is consistent with the concept that if the instrumentation function can be maintained by tripping a channel then continued operation is acceptable. This corcept is applied throughout the Instrumentation

'abchnical Specification Section.

If the channel (s) is not tripped then the allowable outage times in GE-STS and current Fermi 2 Technical Specifications are applied in proposed ACTIONS b.1 arx1 b.2.

~ ACTION b'.2 is reworded to cover the p wibility of more than 2 inoperable channels. Wis was not possible under the current 2 channels per trip system requirement. The wording now clearly indicates that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to either restore compliance with the mininum channels requirement or to restore partial compliance such that ACTION b.1 applies.

The end result of the proposed new ACTIONS is that the requirements ,

are clearer and more consistent with GE-STS and concepts used throughout the Instrumentation Technical Specifications.

SIGEFICMrF IR7JdOS CGEIDEIRTION In accordance with 10CFR50.92 Detroit B31 son 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 consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident frcan any accident previously evaluated, or 3) involve a significant reduction in a margin of safety.

- .. I Enclosure to NRC-894158 Page 5

%e proposed changes affect the system initiation signals for the Reactor Core Isolation Cooling (FCIC) System and the Feedwater/ Main Turbine (NAff) Trip System. We changes are made to better reflect the conventional use of the term " trip system" and make changes to clarify the required ACTIONS for an inoperable channel or channels.

%e changes do not  ;

1) Involve a significant increase in the probability or consequences of an accident oreviously evalw.ted. W e change does not affect the actual ranber of requircd instrument channels for the BCIC or WAfr Trip Systms. % e changes in the ACTION requirements for an inoperable TCIC initiation channel do not represent a change in the actual requirements.

The changes reflect the use of the conventional concept of a trip system. The WAfr Trip System ACTIONS have also been modified to reflect the conventional trip systs concept and also to more clearly indicate the intent that if tripping an inoperable channel (s) allows for the Trip Function to continue to provide a trip signal when called for then continued operation is acceptable. Therefore, the proposal does not affect the probability or consequences of any cccident.

2) Create the possibility of new or different kind of accident from any accident previously evaluated. As described in 1) above the proposed change does not affect the manner of plant operation. Further, the proposed change does not involve a change in plant design and no safety-related equipment is altered. Thus, the proposed change does not create any new accident scenarios.

3) Involve a significant reduction in a margin of safety. The proposal results in Technical Specification requirements which are clearer and more consistent with the conventions and concepts of the Standard Technical Specifications. In this manner, the overall nargin of safety is increased.

Based on the above, Detroit Edison has determined that the proposed l

amendment does not involve a significant hazards considerat.aon.

i Dt010MM1N, IWpCT Detroit D31 son has reviewed the prvposed Technical Specification changes against the criteria of 10CFR51.2% for environmental considerations. The prcrposed change does not invalve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released l

.n Enclosure to ImC-894158 SPage 6 offsite, nor significantly increase individual or cumulative occupational' radiation exposures. . Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do neet.

the criteria given in 10CFRSI.22(c) (9) ' for a categorical exclusion =

from the requirements for an Environmental Impact Statenent.

M 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 cmpliance with the Commission's regulations and proposed anendments will not be inimical to the comnon defenm and security or to the health and safety of the public.

s.

e

_ FfGtIRE 4 6

6 -

T~ r TAIP SYSTEM Lostc a

I .

_ i I .

l .

,r-,,-----------a.

I

.. ., 8 I g I LOGIC FNVILLEL PKIfLS  !

130VDC But I I

: 'b . l II.C.::

.. . . . . . . . . . . . . .s. g I

i g I .

i 1

- s -

L...__. .._.....J v .

v .- .

- 4 1

i i

Aicts : A,f,C, and L alssigsa+s. caauneI eaffads. .

. I

. 1

. j

& i

f. .

9 1