NRC-17-0025, License Amendment Request to Revise Technical Specification Section 3.7.2 for Emergency Equipment Cooling Water / Emergency Equipment Service Water System and Ultimate Heat Sink
| ML17198C829 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/17/2017 |
| From: | Polson K DTE Electric Company, DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-17-0025 | |
| Download: ML17198C829 (27) | |
Text
Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MlI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: keith.polson qdteenergy.com DTE Energy-July 17, 2017 10 CFR 50.90 NRC-17-0025 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
License Amendment Request to Revise Technical Specification Section 3.7.2 for Emergency Equipment Cooling Water /
Emergency Equipment Service Water System and Ultimate Heat Sink In accordance with the provisions of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," DTE Electric Company (DTE) requests amendment to Appendix A, Technical Specifications of Renewed Facility Operating License NPF-43 for Fermi Unit 2 (Fermi 2).
This submittal requests modification of Technical Specification (TS) 3.7.2 for Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS). The proposed changes are to revise the TS 3.7.2 Conditions and Surveillance Requirements to reflect a proposed change to the design of the two redundant cross-tie lines that are part of the UHS.
In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan State Official. provides a detailed description and evaluation of the proposed changes, including an analysis of the significant hazards considerations using the standards of 10 CFR 50.92. DTE has concluded that the changes proposed herein do not result in a significant hazards consideration. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. provides a markup of the existing TS Bases pages. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the TS Bases Control Program. Enclosure 4 is provided for information only.
This license amendment request contains no regulatory commitments.
USNRC NRC-17-0025 Page 2 DTE requests approval of the proposed license amendment by June 30, 2018, with the amendment being implemented within 120 days.
Should you have any questions or require additional information, please contact Mr. Scott Maglio, Manager -Nuclear Licensing, at (734) 586-5076.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 17, 2017 Keith J. Polson Site Vice President Nuclear Generation
Enclosures:
- 1. Evaluation of the Proposed License Amendment
- 2. Marked-up Pages of Existing Fermi 2 TS
- 3. Clean Pages of Fermi 2 TS with Changes Incorporated
- 4. Marked-up Pages of Existing Fermi 2 TS Bases (For Information Only) cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)
Enclosure 1 to NRC-17-0025 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification Section 3.7.2 for Emergency Equipment Cooling Water / Emergency Equipment Service Water System and Ultimate Heat Sink Evaluation of the Proposed License Amendment to NRC-17-0025 Page 1 Evaluation of the Proposed License Amendment 1.0
SUMMARY
DESCRIPTION In accordance with the provisions of Title 10 of the Code of Federal Regulations (CFR) 50.90, Application for amendment of license, construction permit or early site permit, DTE Electric Company (DTE) is submitting a request for an amendment to the Technical Specifications (TS),
Appendix A of Renewed Facility Operating License No. NPF-43 for Fermi 2.
The proposed amendment would modify the Fermi 2 TS (Reference 7.1) and associated TS Bases (Reference 7.2) for Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS) (TS 3.7.2).
Specifically, the proposed changes are to revise the TS 3.7.2 Conditions and Surveillance Requirements (SRs) to reflect a proposed change to the design of the two redundant cross-tie lines that are part of the UHS.
2.0 BACKGROUND
As described in Section 9.2.5 of the Updated Final Safety Analysis Report (UFSAR)
(Reference 7.3), the Fermi 2 UHS is provided by the Residual Heat Removal (RHR) complex.
The UHS is sized to provide sufficient cooling for 7 days following a reactor shutdown without makeup water addition. The UHS consists of two one-half-capacity reinforced-concrete structures. The two reservoirs are separated by a 4-foot thick concrete wall. The two reservoirs are connected by two valved lines (through the 4-foot thick concrete wall) to permit access to the combined inventory of the two reservoirs to either RHR division in the event of a mechanical failure in one of the RHR divisions. Each line contains two isolation valves. These two lines and their valves are referred to as the UHS cross-tie lines and cross-tie valves in this license amendment request (LAR).
Prior to the refueling outage in March 2017, Fermi 2 had maintained one valve open and one valve closed in each line as indicated by UFSAR Figure 9.2-7. This allowed the two reservoirs to remain separated under normal conditions while also ensuring that a single failure could not prevent at least one of the cross-tie lines from being opened under accident conditions. This configuration also ensured compliance with TS 3.7.2 Condition A which requires the UHS to be operable by having the reservoirs cross-connected or by having cross-connect capability by both cross-tie lines, as described in the TS 3.7.2 Bases.
During an underwater inspection of the UHS in the fall of 2015, corrosion of the cross-tie piping was identified. Since the piping supports the load of the cross-tie valves, excessive corrosion of the cross-tie piping could result in failure of the cross-tie lines during a seismic event. As part of the Fermi 2 Corrective Action Program, potential corrective actions were identified, including the proposed design change to permanently remove the cross-tie valves from both of the cross-tie lines. This design change would result in the reservoirs being permanently cross-connected.
to NRC-17-0025 Page 2 This design change requires modification of TS 3.7.2, since the Conditions related to the reservoirs being separated and the SRs referring to the valves would no longer be applicable.
In the interim, Fermi 2 modified the normal valve alignment during the March 2017 refueling outage such that both cross-tie valves in both cross-tie lines are open and de-energized. This current configuration results in the reservoirs being normally cross-connected, which is in accordance with TS 3.7.2 Condition A. The current configuration ensures that the corrosion will not result in adverse plant impacts before the proposed modification is implemented prior to the next refueling outage in the fall of 2018. The current configuration is also consistent with the TS 3.7.2 Bases for SR 3.7.2.4 which states that operability of both reservoirs for the long term cooling function may be maintained by de-energizing open both cross-tie valves in one of the cross-tie lines.
3.0 DETAILED DESCRIPTION The proposed TS revisions are to reflect the UHS having two permanently cross-connected reservoirs. Specifically, the proposed changes:
- 2. Revise the lettering of TS 3.7.2 Conditions B, C, and D to be Conditions A, B, and C, respectively.
- 3. Revise the lettering of TS 3.7.2 Required Actions B.1, C.1, D.1, and D.2 to be Required Actions A.1, B.1, C.1, and C.2, respectively.
- 4. Revise SR 3.7.2.1 to clarify the wording.
- 5. Revise SR 3.7.2.4 to delete the description of UHS valves.
See Enclosure 2 for the marked-up TS pages that reflect the proposed changes described above. provides the clean TS pages with the proposed changes incorporated. Enclosure 4 provides the marked-up TS Bases pages corresponding to the proposed TS changes. Enclosure 4 is provided for information only.
4.0 TECHNICAL EVALUATION
The Fermi 2 UHS is described in Section 9.2.5 of the UFSAR. The UHS consists of two one-half-capacity reinforced-concrete reservoirs of Category I construction, each with a capacity of 3,410,000 gallons of water. The two reservoirs are connected by two valved lines to permit access to the combined inventory of the two reservoirs to either RHR division in the event of a mechanical failure in one of the RHR divisions. Each of the two lines contains two isolation valves of Category I construction; these are the valves to be removed by the proposed design change. Each reservoir has redundant water level indicators. Each reservoir is the cooling source for that divisions RHR service water subsystem, and EESW subsystem, as well as for the Emergency Diesel Generator (EDG) service water for that divisions EDGs. Although there are two reservoirs, the TS 3.7.2 Bases indicates that the UHS relies on the combined heat capacity of both reservoirs to meet its design objectives. For this reason, the UFSAR states that the UHS is a to NRC-17-0025 Page 3 single highly reliable water source capable of providing sufficient cooling for 7 days to permit safe shutdown and cooldown in the event of a design-basis accident.
The UFSAR also states that the UHS is capable of withstanding the effects of the most severe natural phenomenon associated with the site and has been analyzed for a single failure of man-made structural features. A potential breach in the reservoir retaining wall above grade elevation would not compromise the 7-day capacity since the capacity is contained below the grade elevation. In addition, a below-grade structural failure would have a limited effect since the leak would only occur until ground-water elevation is leaked and approximately 90 percent of the total water volume is stored below site ground water level. The UFSAR indicates that the UHS design of the two one-half-capacity reservoirs provides additional reliability over a single full-capacity reservoir because a below-grade structural failure would only affect one of the two reservoirs. However, the UFSAR also states that the 7-day capacity of the UHS includes allowance for a below grade structural crack in both reservoir basins. Therefore, it is not necessary for valves in the cross-tie lines to be able to be closed to meet the UHS design requirements.
UFSAR Section A.1.27 discusses the conformance of the UHS design with Regulatory Guide (RG) 1.27, Revision 2 (1976), Ultimate Heat Sink for Nuclear Power Plants. As discussed in the UFSAR, Regulatory Position 3 of RG 1.27, Revision 2, requires redundant sources of water, both of which must be capable of meeting the requirements of Regulatory Position 1, unless the extremely low probability of failure of a single source is demonstrated. The UFSAR Section A.1.27 discussion reiterates that the Fermi 2 UHS is a highly reliable single water source.
Although the division of the UHS into two reservoirs with valved lines is discussed, this configuration is not credited for meeting the Regulatory Position 3 requirement for redundant sources of water. Instead, justification is provided for the highly reliable single water source.
Therefore, it is not necessary for the Fermi 2 UHS to retain valves in the cross-tie lines to ensure continued conformance with RG 1.27, Revision 2.
In summary, the design function of the UHS cross-tie lines is to be open or capable of being opened to ensure access to the combined water volume of both reservoirs. With the four cross-tie valves removed, there is no credible failure mode to cause the reservoirs to not be cross-tied during an event. There is no design function associated with closing the cross-tie valves. The proposed design change to eliminate the cross-tie valves ensures operability of the UHS and maintains conformance with RG 1.27, Revision 2.
In order to implement this proposed design change, it is necessary to revise the TS. The specific proposed TS changes were identified in Section 3. The specific justification for each of the proposed TS changes is provided below.
- 1. TS 3.7.2 Condition A is for the condition where the UHS is inoperable due to inoperable cross-tie line(s). With the cross-tie valves removed, there is no condition which could cause the cross-tie lines to be inoperable as described above. As a result, the UHS could not be inoperable for this reason. Therefore, Condition A is no longer required and can be deleted entirely from the TS.
to NRC-17-0025 Page 4
- 2. With the deletion of Condition A, the lettering of subsequent Conditions in TS 3.7.2 can be revised. Previous Conditions B, C, and D become new Conditions A, B, and C, respectively. This is purely an administrative change.
- 3. With the deletion of Required Action A.1, the lettering of subsequent Required Actions in TS 3.7.2 can be revised. Previous Required Actions B.1, C.1, D.1, and D.2 become new Required Actions A.1, B.1, C.1, and C.2, respectively. This is purely an administrative change.
- 4. TS 3.7.2 SR 3.7.2.1 verifies the water level of each UHS reservoir and the average level of the two reservoirs. With the reservoirs cross-connected, the actual water level in the reservoirs will be the same. Since each reservoir has its own level indication, this SR is conservatively being retained to include verification of the level of both reservoirs and the average. However, the current SR wording that discusses the average of each of the two may be confusing. The intent is to determine the average level of the two reservoirs. The phrase each of is deleted as an editorial change to improve clarity of the SR.
- 5. TS 3.7.2 SR 3.7.2.4 verifies that each EECW/EESW subsystem and UHS valve is in the correct position. The only UHS valves subject to this SR are the four cross-tie valves that are being removed. Therefore, the phrase and UHS can be deleted from this SR. There are no changes being made to the EECW/EESW subsystem valves discussed in this SR.
5.0 REGULATORY ANALYSIS
5.1 Applicable Regulatory Requirements/Criteria The NRC requirements and guidance documents described below are applicable to the review of the proposed changes.
10 CFR 50, Appendix A, General Design Criterion (GDC) 2, Design bases for protection against natural phenomena, requires that structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.
10 CFR 50, Appendix A, GDC 34, Residual heat removal, requires that a system to remove residual heat be provided with a safety function to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.
10 CFR 50, Appendix A, GDC 44, Cooling water, requires that a system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink be provided with a safety function to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions. As further described in GDC 44, Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system to NRC-17-0025 Page 5 operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.
10 CFR 50.36, Technical specifications, details the content and information that must be included in a station's Technical Specifications (TS). In accordance with 10 CFR 50.36, TS are required to include (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. As described in 10 CFR 50.36(c)(2), limiting conditions for operation (LCO) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee shall shut down the reactor or follow any other actions permitted by the TS.
NUREG-1433 Volume 1, Revision 4.0, Standard Technical Specifications, General Electric BWR/4 Plants, provides the improved Standard Technical Specifications (STS) for General Electric BWR/4 plants. Requirements for the UHS are found in STS 3.7.2. The STS does not contain any Conditions, Required Actions, or SRs related to UHS cross-tie lines since this design feature was not common to BWR/4 plants. Elimination of TS requirements for the cross-tie lines makes the Fermi 2 TS more consistent with the STS in NUREG-1433.
Regulatory Guide (RG) 1.27, Ultimate Heat Sink for Nuclear Power Plants, provides regulatory guidance that may be used for implementing GDC 44. RG 1.27 indicates that the UHS should consist of at least two sources of water, unless it can be demonstrated that there is an extremely low probability of losing the capability of a single source. The Fermi 2 UFSAR has previously documented conformance with RG 1.27, Revision 2, based on a single highly reliable water source.
The proposed changes are consistent with a highly reliable single water source UHS and ensure safe operation by continuing to meet applicable regulations and requirements.
5.2 Precedent Prior to 1990, the Fermi 2 TS for the UHS were written in a manner which incorrectly implied that each reservoir could independently provide the required heat removal capability for either RHR division. To better reflect the UHS design bases, DTE submitted a license amendment request (Reference 7.4) to modify the TS to clearly indicate that the UHS is a single water source consisting of two reservoirs which must be capable of being cross-connected. The license amendment request stated that the normal system line-up was to maintain the two reservoirs not cross-connected. However, in response to one or more inoperable cross-tie valves, the proposed TS included an action to de-energize open both cross-tie valves in at least one cross-tie line. The license amendment request provided technical justification for the TS action for the reservoirs to be cross-connected in that manner indefinitely. The NRC approved the amendment in February 1990 (Reference 7.5). The NRCs Safety Evaluation Report (SER) associated with the amendment described the normal system line-up of the two reservoirs not cross-connected as a commitment. The current configuration with the valves de-energized open in response to the corroded piping is a departure from the 1990 SER commitment that is allowed by the TS. The to NRC-17-0025 Page 6 proposed design change to eliminate the valves will make the 1990 SER commitment no longer applicable.
5.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Application for amendment of license, construction permit or early site permit, DTE is requesting to amend Renewed Facility Operating License No. NPF-43 for Fermi 2.
DTE proposes to revise TS Section 3.7.2 as described in Section 3.0 above.
DTE has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92(c), Issuance of amendment, as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
Operability of the Fermi 2 UHS requires that the two reservoirs either be cross-tied or capable of being cross-tied. Fermi 2 proposes a change to the design of the reservoirs to remove the cross-tie valves. With the four cross-tie valves removed, the reservoirs are permanently cross-tied and there is no credible failure mode to cause the reservoirs to not be cross-tied during an event. A structural crack in one reservoir would result in both reservoirs being affected when they are permanently cross-connected. However, the consequences are bounded by the UFSAR which already includes allowance for a structural crack in both reservoirs.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
Operability of the Fermi 2 UHS requires that the two reservoirs either be cross-tied or capable of being cross-tied. As these valves are currently maintained normally open and de-energized, the safety limits and safety analysis assumptions associated with the design and operation of the plant will not change. Structural cracks affecting both reservoirs have already been considered as described above. Accordingly, the change to remove the cross-tie valves does not introduce any new accident initiators, nor does it reduce or adversely affect the capabilities of any plant structure, system, or component to perform their safety function.
to NRC-17-0025 Page 7 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed changes have no adverse effect on plant operation. The plant response to the design basis accidents does not change, with the exception that actions to cross-connect the reservoirs are no longer necessary. The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, DTE concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
5.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
6.0 ENVIRONMENTAL CONSIDERATION
DTE has evaluated the proposed amendment for environmental considerations. The review has resulted in the determination that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required for the proposed amendment.
to NRC-17-0025 Page 8
7.0 REFERENCES
7.1 Appendix A to Renewed Facility Operating License No. NPF-43, Technical Specifications 7.2 Fermi 2 Technical Specification Bases, Revision 70, dated April 13, 2017 7.3 Fermi 2 Updated Final Safety Analysis Report, Revision 20, dated May 2016 (ML16165A442) 7.4 DTE Letter NRC-88-0225, Proposed Technical Specification Change (License Amendment) - Ultimate Heat Sink (3/4.7.1.5), dated September 30, 1988 7.5 NRC Letter, Amendment No. 51 to Facility Operating License No. NPF-43: (TAC No.
69835), dated February 20, 1990 (ML020700563)
Enclosure 2 to NRC-17-0025 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification Section 3.7.2 for Emergency Equipment Cooling Water / Emergency Equipment Service Water System and Ultimate Heat Sink Marked-up Pages of Existing Fermi 2 TS
EECW/EESW System and UHS 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)
LCO 3.7.2 Two EECW/EESW subsystems and UHS shall be OPERABLE.
APPLICABILITY: MODES 1. 2, and 3.
ACTIONS
NOTES--------- ---------------- -------
- 1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating." for diesel generator made inoperable by UHS.
- 2. Enter applicable Conditions and Required Actions of LCO 3.4.8. "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by EECW/EESW or UHS.
Delete .-.- CONDITION REQUIRED ACTION COMPLETION TIME text
..
- ble due to A.1 Restore UHS cross-tie 1:,i inopera le cros -'lines t line(s).
One reservoir h-1 Restore reservoir to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. OPERABLE status.
One EECW/EESW C-1 Restore the EECW/EESW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem inoperable subsystem to OPERABLE for reasons other than status.
Condiins-A-and-8. [-I Condition A (continued)
FERMI - UNIT 2 3.7-3 Amendment No. 1 EECW/EESW System and UHS 3.7.2 ACTIONS (continued)
CONDITION C REQUIRED ACTION COMPLETION TIME
- Required Action and -I Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A- AND
- p-er--
not met.
A or B - Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both EECW/EESW -
so inoperable esAubsystems Delete text Cenditien-A --
OR UHS inoperable for reasons other than Conditions-A-and-B-.
Condition A /
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the water level of each UHS In accordance reservoir, and the average water level of with the eah-e-f the two reservoirs, are z 25 ft. Surveillance Delete text -Frequency Control Program SR 3.7.2.2 Verify the average water temperature of In accordance each reservoir, and combined average water with the temperature of the two reservoirs, are Surveillance s 800 F. Frequency Control Program (continued)
FERMI - UNIT 2 3.7-4 Amendment No. 134, 1-
EECW/EESW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.2.3 ------------------- NOTE--------------------
Fast speed testing not required to be performed during icing periods.
Operate each cooling tower fan on slow In accordance speed and on fast speed, each for with the z 15 minutes. Surveillance Frequency Control Program SR 3.7.2.4 ------------------- NOTE--------------------
Isolation of EECW flow to individual components does not render EECW System inoperable.
~<-D-[ee l eeetx text Verify each EECW/EESW subsystem and-UI4S In accordance manual, power operated, and automatic valve with the in the flow paths servicing safety related Surveillance systems or components, that is not locked, Frequency sealed, or otherwise secured in position, Control Program is in the correct position.
SR 3.7.2.5 Verify each EECW/EESW subsystem actuates on In accordance an actual or simulated initiation signal. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.7-5 Amendment No. -134, -261-
Enclosure 3 to NRC-17-0025 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification Section 3.7.2 for Emergency Equipment Cooling Water / Emergency Equipment Service Water System and Ultimate Heat Sink Clean Pages of Fermi 2 TS with Changes Incorporated
EECW/EESW System and UHS 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)
LCO 3.7.2 Two EECW/EESW subsystems and UHS shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTES----------------------------------
- 1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating," for diesel generator made inoperable by UHS.
- 2. Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by EECW/EESW or UHS.
CONDITION REQUIRED ACTION COMPLETION TIME A. One reservoir A.1 Restore reservoir to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. OPERABLE status.
B. One EECW/EESW B.1 Restore the EECW/EESW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem inoperable subsystem to OPERABLE for reasons other than status.
Condition A.
(continued)
FERMI - UNIT 2 3.7-3 Amendment No. 134
EECW/EESW System and UHS 3.7.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or AND B not met.
C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both EECW/EESW subsystems inoperable.
OR UHS inoperable for reasons other than Condition A.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the water level of each UHS In accordance reservoir, and the average water level of with the the two reservoirs, are 25 ft. Surveillance Frequency Control Program SR 3.7.2.2 Verify the average water temperature of In accordance each reservoir, and combined average water with the temperature of the two reservoirs, are Surveillance 80°F. Frequency Control Program (continued)
FERMI - UNIT 2 3.7-4 Amendment No. 134, 201
EECW/EESW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.2.3 -------------------NOTE--------------------
Fast speed testing not required to be performed during icing periods.
Operate each cooling tower fan on slow In accordance speed and on fast speed, each for with the 15 minutes. Surveillance Frequency Control Program SR 3.7.2.4 -------------------NOTE--------------------
Isolation of EECW flow to individual components does not render EECW System inoperable.
Verify each EECW/EESW subsystem manual, In accordance power operated, and automatic valve in the with the flow paths servicing safety related systems Surveillance or components, that is not locked, sealed, Frequency or otherwise secured in position, is in the Control Program correct position.
SR 3.7.2.5 Verify each EECW/EESW subsystem actuates on In accordance an actual or simulated initiation signal. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.7-5 Amendment No. 134, 201
Enclosure 4 to NRC-17-0025 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification Section 3.7.2 for Emergency Equipment Cooling Water / Emergency Equipment Service Water System and Ultimate Heat Sink Marked-Up Pages of Existing Fermi 2 TS Bases (For Information Only)
There is no change to this page.
It is provided for information only. EECW/EESW System and UHS B 3.7.2 B 3.7 PLANT SYSTEMS B 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)
BASES BACKGROUND The EECW/EESW System (Ref. 1) is designed to provide cooling water for the removal of heat from equipment, such as residual heat removal (RHR) and Core Spray (CS), pump coolers, and room coolers for Emergency Core Cooling System and other safety-related equipment, required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient.
Components cooled by each EECW subsystem are normally cooled by the Reactor Building Closed Cooling Water (RBCCW) system, which cools various plant equipment primarily in the Reactor Building. An EECW subsystem contains a single 1775 gpm nominal capacity pump, a heat exchanger, a make-up tank, valves, piping, and associated instrumentation. A second 100% capacity heat exchanger is also provided as a backup.
Upon receipt of a loss of off-site power, a high drywell pressure signal, or low RBCCW System pressure, both EECW subsystems are activated. Upon activation, the EECW pump starts, the EECW loop isolates from the remainder of the RBCCW system, and other system valves reposition as needed to isolate non-essential loads and configure the system for emergency operation.
Each EECW subsystem's heat exchanger is cooled by the same division's EESW subsystem. The EESW subsystem contains a single 1600 gpm nominal capacity pump that pumps from the division's RHR Reservoir through the EECW subsystem's heat exchanger and returns to the RHR Reservoir. Each EESW subsystem functions to cool the associated EECW subsystem.
The EESW pump automatically starts on the same actuation signals as the EECW System. The two EECW/EESW subsystems are separated from each other so that failure of one subsystem will not affect the OPERABILITY of the other subsystem.
The UHS (Ref. 1) is provided by a single highly reliable water supply in the form of the RHR reservoirs and a means of heat rejection in the form of mechanical draft cooling towers. The UHS consists of two one-half capacity reinforced concrete reservoirs each with a capacity of 3.41 X 106 gallons of water, corresponding to an elevation of 583 feet. The two reservoirs are connected by two FERMI - UNIT 2 B 3.7.2-1 Revision 43
EECW/EESW System and UHS B 3.7.2 BASES BACKGROUND (continued) redundant cross-tie lines to provide --- alves, to-permt access to the combined inventory to either division of cooled equipment in the event of a failure in one of the divisions. Each RHR reservoir is the cooling source for that division's RHRSW subsystem, and EESW subsystem, as well as the diesel generator service water pumps for that division's emergency diesel generators (EDGs). A two-cell mechanical draft cooling tower is located over each division reservoir. Each cooling tower is designed to cool one division of supported equipment, thus providing full redundancy.
APPLICABLE Sufficient water inventory is available for all UHS SAFETY ANALYSES supported post LOCA cooling requirements for a 7 day period with no additional makeup water source available. The ability of the UHS and associated service/cooling water systems to support long term cooling of the reactor containment is assumed in evaluations of the equipment required for safe reactor shutdown presented in the UFSAR, Chapters 4 and 6 (Refs. 2 and 3, respectively). These analyses include the evaluation of the long term primary containment response after a design basis LOCA.
The ability of the UHS and associated service/cooling water system to provide adequate cooling to the identified safety equipment is an implicit assumption for the safety analyses evaluated in References 1 and 2. The ability to provide onsite emergency AC power is dependent on the ability of the UHS to cool the EDGs. The long term cooling capability of the RHR and core spray pumps is also dependent on the cooling provided by the EECW/EESW System.
The EECW/EESW System, together with the UHS, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
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EECW/EESW System and UHS B 3.7.2 BASES LCO The EECW/EESW system consists of two completely independent subsystems. In the event of a DBA, one subsystem of EECW/EESW is required to provide the minimum heat removal capability assumed in the safety analysis for the system to which it supplies cooling water. To ensure this requirement is met, two subsystems of EECW/EESW must be OPERABLE. At least one subsystem will operate, if the worst single active failure occurs coincident with the loss of offsite power.
An EECW/EESW subsystem is considered OPERABLE when it has an OPERABLE EECW pump, an OPERABLE EESW pump, an OPERABLE EECW/EESW heat exchanger, an OPERABLE EECW makeup tank, an OPERABLE EECW makeup pump, and OPERABLE flow paths to provide cooling water flow to the supported equipment and reject the heat to the division's RHR reservoir.
The OPERABILITY of the UHS is based on the OPERABILITY of each RHR reservoir. To be OPERABLE, a RHR reservoir must have sufficient capacity to accept the design heat load from the supported equipment. To accomplish this each reservoir water volume must be greater than 2,990,000 gallons (an indication of 25 feet) and the water temperature must be s 800 F. In addition, the associated cooling tower and both fans must be OPERABLE, Since the UHS relies on the combined heat capacity of the two RHR reservoirs to accomplish its design objectives, UHS OPERABILITY must also be based on the two reservoirs having a combined water volume of 5,980,000 gallons and a combined average water temperature of s 800 F. Furthermore, the two reservoirs must be cross-connected, or eapable of being oss-connected.
The isolation of the EECW cooling to components or systems may render those components or systems inoperable, but does not necessarily affect the OPERABILITY of the EECW/EESW System.
APPLICABILITY In MODES 1, 2, and 3, the EECW/EESW System and UHS are required to be OPERABLE to support OPERABILITY of the equipment serviced by the EECW/EESW System. Therefore, the EECW/EESW System and UHS are required to be OPERABLE in these MODES.
Although the LCO for the EECW/EESW System and UHS is not applicable in MODES 4 and 5, the capability of the EECW/EESW System and UHS to perform their necessary related support functions may be required for OPERABILITY of supported systems.
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EECW/EESW System and UHS B 3.7.2 BASES ACTIONS The Required Actions are modified by two Notes indicating that the applicable Conditions of LCO 3.8.1, "AC Sources -
Operating," and LCO 3.4.8, "Residual Heat Removal (RHR)
Shutdown Cooling System - Hot Shutdown," be entered and Required Actions taken if the inoperable EECW/EESW subsystem or UHS results in an inoperable EDG or RHR shutdown cooling subsystem respectively. This is in accordance with LCO 3.0.6 and ensures the proper actions are taken for these elete text components.
OPERABILI the RHR reservoir cross-tie lines '
maintained by ha the RHR Reservoirs cro onnected or by having cross-conne apability for cross-tie lines.
With the two RHR reservoir t s-connected, and not capable of being remote-man oss-connected by both cross-tie lines, the ay not b le of meeting its assumed design o ' ive. In this conditio , PERABILITY must be restored in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Comple Time is based easonable time to effect cross-connect cap ities e low probability of event during this period.
With a single RHR reservoir inoperable, the remaining RHR Reservoir and associated supported equipment is adequate to perform the heat removal function. However, overall reliability is reduced because a single failure in the remaining division cane in losste heat reumoval function.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based upon the capabilities of the remaining equipment and the low probability of an accident during this time period.
lDelete t With one EECW/EES ubsystem inoperable for reasons other than Condition A ,the EECW/EESW subsystem must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With the unit in this condition, the remaining OPERABLE EECW/EESW subsystem is adequate to perform the heat removal function.
However, the overall reliability is reduced because a single failure in the OPERABLE EECW/EESW subsystem could result in loss of EECW/EESW function. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the redundant EECW/EESW System capabilities afforded by the OPERABLE subsystem and the low probability of an accident occurring during this time period.
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EECW/EESW System and UHS B 3.7.2 BASES ACTIONS (continued)
C.1 and C.2 ' 93and9 If the EECW/EESW subsystem cannot be restored to OPERABLE status within the associated Completion Time, or both -
EECW/EESW subsystems are inoperable for reasens-ether than Gendit-A, or the UHS is determined inoperable for reasons other than'such as not meeting the Condition A combined wate volume or average water temperature requirement, he unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies the water level in each RHR reservoir to be Since the reservoirs sufficient for the proper reservoir heat removal capability are cross-connected, and long-term cooling capability (net positive suction head the actual water and pump vortexing are considered in determining this levels inthe limit). If each reservoir meets the 25 foot level limit be the (which equates to a water volume of 2,990,000 gal or 580 ft r will belevation) rreservoirs then the average reservoir level is known to be same. However, met without also doing a specific calculation. If either each reservoir has its reservoir does not meet the water level requirement, that own indication of reservoir is inoperable. Verification of the UHS combined water level. water volume is required to assess the OPERABILITY of the entire UHS. This ensures that the heat removal capability of the UHS is within the assumptions of the long-term cooling analysis. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.7.2.2 Verification of the average water temperature in each reservoir, both individually and combined, ensures that the heat removal capability of the reservoirs and UHS are within the assumptions of the long-term cooling analysis. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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EECW/EESW System and UHS B 3.7.2 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.7.2.3 Operating each cooling tower fan from the control room on both fast speed and slow speed, each for z 15 minutes, ensures that all fans are OPERABLE and that all associated controls are functioning properly. It also ensures that fan or motor failure, or excessive vibration, can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
This SR is modified by a Note stating that testing at fast speed is not required during icing conditions. This allowance is as a result of manufacturer recommendations, due to increased stress caused by ice on the fan blades.
Icing conditions exist when ambient temperatures are s 36'F and water is being returned to the cooling towers from RHRSW, EDG service water, or EESW.
SR 3.7.2.4 Verifying the correct alignment for each manual, power operated, and automatic valve in each EECW/EESW subsystem flow path provides assurance that the proper flow paths will exist for EECW/EESW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be automatically realigned to its accident position within the required time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that Delete text cannot be inadvertently misaligned, such as check valves.
SR also applies to the RHR Reservoir cross-connec valves. ese valves are normally aligned such each cross-tie li tween the reservoirs has east one valve open, provided any ed valve(s) ERABLE for opening.
With closed cross-connec incapable of being remote-manually cross- cte ., inoperable), the continued OPERAB of both reservoi or the long term cooling f on may be maintained by de-ene 'ng open bot ss-connect valves in one cross-tie line.
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There is no change to this page. B 3.7e2 It is provided for information only.
BASES SURVEILLANCE REQUIREMENTS (continued)
This SR is modified by a Note indicating that isolation of EECW flow to components or systems may render those components or systems inoperable, but does not necessarily affect the OPERABILITY of the EECW/EESW System. As such, when all EECW pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the EECW/EESW System may still be considered OPERABLE.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.7.2.5 This SR verifies that the automatic isolation valves of the EECW/EESW System will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the EECW and EESW pumps in each subsystem.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES 1. UFSAR, Chapter 9.
- 2. UFSAR, Chapter 4.
- 3. UFSAR, Chapter 6.
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