ML20147H211

Application for Amend to License NPF-43,revising Tech Specs to Allow LPCI Sys Cross Tie Valve to Be Placed in Closed Position During Plant Shutdowns.Fee Paid

ML20147H211
Person / Time
Site:	Fermi
Issue date:	01/15/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20147H216	List: ML20147H211 NRC-87-0272, Proposed Tech Specs Allowing LPCI Sys Cross Tie Valve to Be Placed in Closed Position During Plant Shutdowns
References
CON-NRC-87-0272, CON-NRC-87-272 NUDOCS 8801220250
Download: ML20147H211 (6)

Text

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I B. Ralph SytyLa Group Vice Presdent Detroit 6 w-Edison =400NorthDixieHighway l January 15, 1988 l NIC-87-0272 U. S. Ibclear Regulatory Comission l Attn Document Control Desk Washington, D. C. 20555 l

Reference:

Fermi 2 NIC Docket No. 50-341 NFC License No. NPF-43  !

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Subject:

Proposed 'Ibchnical Specification Change (License

! Amendment) - Emergency Core Cooling 9 fstems Shutdown

( (3/4.5.2) l l Pursuant to 10CFR50.90, Detroit B31 son Coupany hereby proposes to l amend Operating License NPF-43 for the Fermi 2 plant by incorporating

the enclosed changes into the Plant Technical Specifications. The proposed change allows the Low Pressure Coolant Injection (LPCI) l system cross tie valve to be placed in the closed position during plant shutdowns.

Detroit B31 son has evaluated the proposed 'Itchnical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. 'Ihe Fermi 2 Cnsite Review organization has approved and the Naclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the enclosed determinations.

Pursuant to 10CFR170.12(c), enclosed with this amendment request is a check for one hundred fifty dollars ($150.00) . In accordance with 10CFR50.91, Detroit Bilson has provided a copy of this letter to the State of Michigan.

Detroit Edison anticipates that the circumstances expected during the upcoming Local Leak Rate Test outage scheduled for March 1988 will require this amendment. Therefore, your pronpt consideration of this proposal is requested.

8801220250 880115 PDR ADOCK 05000341

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USNBC January 15, 1988 NIC-87-0272 Page 2 If you have any questions, please contact Mr. Lewis P. Bregni at (313) 586-4072.

Sincerely, M

Enclosure cc: Mr. A. B. Davis Mr. E. G. Greenman Mr. W. G. Rogers Mr. J. J. Stefano Supervisor, Mvanced Planning and Review Section Michigan Public Service Comission

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USNFC January 15, 1988 NaC-87-0272 Page 3 I, B. PALPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best cf my knowledge and belief. '

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B . PAIMH' SEYIA Group Vice President On this d ilte rdt day of O w w , 1988, before me personally aEheared B. Palph Sylvik, being first duly sworn and says that be executed the foregoing as his free act and deed.

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Notary Public KAREN M. REED t'ctuy Public, Menros County, ML:n, niy Ccmmissicn Egites May 14,19)J l

Enclosura to NRC-87-0272 Page 1 BACIMUtD&ISPDfMON Fermi 2 %chnical Specifications currently require the LPCI systen cross-tie valve (Ell-F010) to be open as a requirement for LPCI systcm operability in all operational conditions. During Operational Conditions 4 and 5 this requirement exists since the shutdown ECCS surveillance regoireme : (4.5.2.1) specifies the application of the BCCS surveillance requirement for Operational Conditions 1, 2 and 3 (4.5.1) . Surveillance Pequitement 4.5.1.a.2 specifies the cross-tie valve to be open. During Operational Corditions 4 and 5 closure of the cross tie valve is necessary to isolate a LPCI subsystem for maintenance. We purpose of this change is to allow closure of the cross-tie valve while allowing the other LPCI subsystem to remain operable as long as it is capable of inj.ction to the reactor vessel.

In Cperational Conditions 1, 2 and 3, %chnical Specification Table 3.3.3 Emergency Core Cooling Systen Actuation Instrunentation requires the break detection instrumentation for the LPCI loop selection feature to be operable. In these operational conditions the entire LPCI system flow (from toth subsystens) would be injected through the injection valves associata3 with the recirculation loop determined by the break detection logic as being an intact loop. For this to occur the cross tie valve nust be open. For this reason Action b.3 of Specification 3.5.1 and Surveillance Requirenent 4.5.1.a.2 are included in Technical Specifications to ensure the cross-tie valve is open in Operational Conditions 1, 2 and 3.

no loop selection feaNro described above is only required to be operable in Operationa. Conditions 1, 2, and 3 as shown in Table 3.3.3-1. Wus, in Operational Corditions 4 aM 5, it is only necessary that a LPCI subsystem be capable of vessel injection to fulfill its intended function. hnporary modifications to the loop selection logic may be a Muired to ensure that the operable subsystem is capable of vessel injection. The loop selection logic temporary nodifications would ensure that the desired injection path is selected for the operable subsystem.

Technical Specification 3.5.2 requires two of the possible four Core Spray or LPCI subsystems to be operable. %is recognizes the reduced Emergency Core Cooling requirements of Operational Corditions 4 and 5 and the need to allow for maintenance outages on ECCS eq11pment.

Further, a condition in which one LPCI subsystem is operable and the other inoperable for maintenance is intended to be allowed by Technical Specificaticos. The proposed change is necessary to allow required maintenance to the inoperable subsystem while ensuring the operable subsystem has the capability of vessel injection.

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, a Enclosur@ to NIC-87-0272 Page 2

, SIGNIFICNfLJW4HMLCOMUDFNLTJW In accordance with 10CFR50.92, Detroit B31 son has made a determination that the proposed amendment involves no significant hazards considerations. 'Ib make this determination, Detroit Edison has established that operation in accordance with the proposed amendnent 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.

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. We change maintains the existing BDCS equipment requirement in cold shutdown corrlitions and solely allows alignment of LPCI subsysten to inject to the reactor vessel via an alternative flow path to allow closure of the LPCI cross-tie valve for maintenance. This alternative flow path is normally designed for full LPCI system flow during operating conditions when the path is selected by the LPCI loop selection logic. Thus, this change does not increase the probability or consequences of evaluated accidents.

2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change solely alters the alignment of LPCI equiptent which results in the same required flow capabilities for ECCS equipment in the event of a loss-of-coolant accident in cold shutdown conditions. No new accident modes are created.

3. We proposed changes do not involve a significant reduction in a margin of safety. The ECCS capability required in cold shutdown conditions remains unchanged resulting in an unchanged margin of safety.

I Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. As shown above, the proposed changes do not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantl occupational radiation exposures. yBasedincrease individual on the or cunulative foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet

Enclosuro to NIC-87-0272 Page 3 the criteria given in 10CFR51.22(c) (9) for a categorical exclusion from the requirements for an Environmental Inpact Statcnent.

00tCImtiLW Based on the evaluations abover (1) there is reasonable assulance 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 coupliance with the Comission's regulations and the e prcposed amendment will not be inimical to the cormon defense and security or to the health and safety of the public.

In summary, the proposed amendaent removes an unr:ecessary requirmer.t to maintain the LPCI cross-tie valve open during cold shutdown ,

conditions, btile ensuring the remaining LPCI system subsystem is operable, it allows the LPCI cross-tie valve to be closed to facilitate maintenance in an inoperable LPCI syste subsyste .

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