NRC-88-0004, Application for Amend to License NPF-43,changing Tech Spec Section 3/4.6.3 to Add Two Existing Automatic Primary Containment Isolation Valves for Primary Containment Radiation Monitor
| ML20148R830 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/29/1988 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20148R834 | List: |
| References | |
| CON-NRC-88-0004, CON-NRC-88-4 NUDOCS 8802020283 | |
| Download: ML20148R830 (13) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
e B. Ralph Syhla Group V<o Prndem e
640 Edison ~=0NodhOweHighway c e -'-
January 29, 1988 NIC-88-0004 U. S. !belear Regulatory Conmission Attn Document Control Desk Washington, D. C. 20555
References:
- 1) Fermi 2 NIC Docket !b. 50-341 IUC License No. NPF-43
- 2) Detroit Elisca to NIC, "Proposed Technical Specification Change - Primary Containment Isolation Valves (3/4.6.3)," dated 0:tober 22,1987 (NIC-87-0209)
- 3) Detroit Elison to NIC, "Request for Tenporary Exenption from General Design Criterion 56 - Primary Contairment Isolation," dated Octcber 27, 1987 (NIC-87-0211) 4)
NIC to Detroit Riison, "Exenption to General Design Criterion 56 of Appendix A to 10 CFR Part 50 (T7C No.
66467)," datM tbvenber 13, 1987
Subject:
Proposed Technical Specification (License AneMment) Change t
- Primary Containnent Tsolation Valves (3/4.6.3)
Pursuant to 1(CFR50.90, Detroit Edison Conpany hereby proposes to anend Operating License NPF-43 for the Fermi 2 plmt by incorporating the enclosed change into '14chnical Speciff cation 3/4.6.3 - Primary Containment Isolation Valves.
On Q:tober 22, 1987, Detroit niison requested (Reference 2) a proposed Technical Specification change to add two existing automatic primary containnent isolation valves for the Primary Containnent Radiation Monitor (PCIN;. The change was due to an oversight in incorporating into the Technical Specification a design change nale prior to the issuance of the Operating License. Subsequently, Detroit Elison recognized that the PCIM isolation design should be upgraded to neet General Design Criterion (GC) 56 and on October 27, 1987, filed a tenporary exenption request (Reference 3) which was granted on Novenber 13,1987 (Reference 4). The proposed change results from nrdifications to bring the PCIN isolation design up to the standards fid['ggo 8802020283 800129 ADOCK 050 1
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a UStGC January 29, 1988 100-88-0004 Page 2 set forth in GDC 56 and supersedes the proposed changes requested in Reference 2.
The current exenption permits postponencnt of full conpliance with CDC 56 for the PCFM until startup following planned local leakrate testing in March 1988. As such, Detroit Edison requests that this proposed anendnent be processed and become effective with startup following planned local leakrate testing in March 1988.
Detroit Elison has evaluatcd the proposed Technical Specifications gainst the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Chsite Review Organization has approved and the ibclear Safety Review Group has reviewcd these proposed Technical Specification changes and concurs with the enclosed determinations.
Pursuant to ICCFR170.12(c), erclosed with this amerdnent is a check for one hundred fifty dollars ($150.00). In accordance with ICCFR50.91, Detroit D31 son has provided a copy of this letter to the State of Michigan.
If ycu have any questions, please contzet Ms. Lynne S. Gocdtran at (313) 586-4211.
Sincerely, fh)
.l Erclosure cc: A. B. Davis E. G. Greenman T. R. Cuay W. G. Rogers Supervisor, Advanced Planning ard Review Section, Michigan Public Service commission
USNIC January 29,-1988 NIC-88-0004 Page-3 I, B. PALPH SYLVIA, do hereby affirm that the foregoing staternents are based on facts and circustances which are true and accurate to the best of my knowledge and belief.
M <A I~
B. RAIfH SYJ#IA Group Vice President on this 29 UL day of dwanur
.1988, before me personally appeared B. Ralph Sylvia, being' first duly sworn and says that he executed the foregoing as his free act and deed.
/111+t &k %Ot!
Notary Public KAREN M. REED t,ct2ry Public, f tenm County, Mich.
ay Ccnxisticn E4 ns i,by 14.19D i
Attachment to NIC-88-0004 Page 1 BACKGIODPD/DI!EUSSION
'14chnical Specification 3/4.6.3 - Pri: nary Containment Isolation Valves, Table 3.6.3-1 is revised to denote four (4) automatic isolation valves for the Primary Containnent RMiation Monitoring System (PCIES) of the Primary Containnent Atnosphere Monitoring System. The four valves (T50-F450, T50-F451, T50-F455 and T50-F456) provide automatic isolation on both high drywell pressure and low reactor vessel water level (Level 2). The proposed change results from modifications to bring the PCPMS isolation design up to the standards set forth in 10 CFR Part 50, Appendix A, General Design Criterion (@C) 56.
The Fermi 2 Prituaty Containnent Atnosphere Monitoring System (PCAMS) includes a PCIES configured in parallel with the Drywell flydrogen/ Oxygen Sanpling System. Both systerns normally operate during reactor operation and sanple the drywell atnosphere from five zones through containnent penetrations. The initial isolation design for the PCIES and the Drywell !!ydrogen/ Oxygen Sanpling System is described in Section 6.2.4 of the Fermi 2 Updated Final Safety Analysis Report.
Containnent isolation requirenents of (DC 56 were achieved using a single remote manual isolation valve and a closed piping system outside the containnent, insted of one automatic isolation valve inside and one automatic isolation valve outside containment. The original design intent was that the PCIES would operate following a loss-of-coolant accident (IICA) ard that the PCIES would be in conpliance with the closed system requirenents @ proved as an alternative to CDC 56.
In January 1984, Detroit dison determined that the PCIES did not meet the closed system design requirenents for a containnent design pressure of 56 psig. Seismic and material certifications provided by the PCIES vendor also were fouM to be deficient. Two actions w re taken by Detroit dison as a result of these findings (1) the PCPMS was re-classified as non-essential following a LOCA and, as such, should be isolated automatically upon rcceipt of a LOCA signal (the Drywell ifydrogen/ Oxygen Sanpling system retained its essential classification); and (2) one automatic isolation valve and one local manual valve were added to each of two branch lines of the PCIES to provide isolation of the re-classified non-essential PCIES. The automatic isolation valve was designed to close on a high drywell pressure signal from the Reactor Protection System. Following this nodification, the configuration provided two barriers in the event of a LOCA, one barrier consisting of the automatic isolation valve and the second barrier consisting of the renote manual isolation valve.
Attachnent to NIC-88-0004 Page 2 During an October 1987 maintenance servicing of the PCPMS, valves T50-F450 and T50-F451 were used to isolate the inlet and return lines of the system from the primary containnent. This isolation procedure was reviewed by Fermi 2 operations personnel and questioned since these valves were not indicated as containnent isolation valves in either the plant procedures or Technical Specifications. The PCBMS uses the penetration of the essential Drywell Hydrogen / Oxygen Sanpling System by tapping off between the rmote isolation valves and the panel. The valves used to isolate the PCINS are located in these tap-off. lines (see Figure 1).
In response to the questions raised by the operations personnel, Detroit B31 son submitted a Technical Specification change request on October 22, 1987, to add the above two valves into Table 3.6.3-1.
At this point in time, however, it was discovered that the use of one single automatic isolation valve per line, as a barrier for a non-essential system (such as the current PCINS isolation design), was not an acceptable alternative to the requirments of CDC 56. Thus, on October 27, 1987, Detroit Edison requested a tenporary exenption from the requirments of CDC 56 to allow for sufficient lea 3 tine necessary to conplete the nodifications necessary to bring the PCFMS isolation design back into conpliance. 'Ihe current exenption, grmted on Novenber 13, 1987, permitted postponenent of full coupliance with (DC 56, for the PCPMS, until startup following planned local leak rate testing in March 1988.
As stated in GDC 56, two isolation valves -- one inside and one outside the containnent - are required in lines that penetrate the primary containnent and connect directly to the containment atnosphere. However, CDC 56 allows for alternatives to these explicit isolation requirements where the acceptable basis for each alternative is defined. The proposed modification will neet the intent and requirements of CDC 56.
The proposed design nodification provides automatic isolation to the non-essential PCPMS from the essential PCAMS, thus maintaining PCAMS as a closed loop system outside containnent. This results in PCFMS having two redundant and divisional automatic isolation valves on the inlet line and two redundant and divisional mtomatic isolation valves on the outlet line of the system. The subject isolation valves (as shown in Figure 1) consist of the existing Division I (T50-F450 and T50-F451) valves and the addition of Division II (T50-F455 and T50-F456) valves. These inlet and outlet lines for PCPMS are connected to Division I of PCAMS. The PCAMS is a closed loop system outside containnent and is an extension of primary containnent.
Therefore, PCINS lines can be considered as lines which penetrate primary containnent.
Attachment to NIC-88-0004 Page 3 GX: 56 states that isolation valves outside containment shall be located as close to the containment as possibic. The location of the isolation.alves for the PCBMS lines are designed to be as close to primary containnent as possible, i.e. as close to the PCAMS loop as possible.
CDC 56 also requires that isolation valves outside containnent will, upon loss of actuating power, automatically isolate in a position that provides the greatest safety. As stated above, the proposed design change for PCFMS will result in two redundant and divisional automatic isolation valves on the PCFMS inlet and outlet lines. %ese valves "fail close" assuring integrity of the exteMed containment. Each isolation valve meets the design criteria established in UFSAR Section 6.2.4.2.1, and will be part of the leak rate test progrm.
The electrical actuator power for these valves will be derived from redundant portions of the Reactor Protection System. Two of these PCF24S valves (one inlet and one outlet) will be air operated. The air supply utilized will be from the interruptible air system. The automatic control logic for each division will provide a diverse valve trip / closure signal resulting from high drywell pressure and low reactor vessel water level (Level 2). Additionally, each valve will require manual operator action to reopen, providing that the logic permissive exists. This is consistent with the guidance of NUREG-0737 which states that there should be diversity in the parmeters sensed for the initiation of containnent isolation, and that resetting the isolation signal will not result in automatic reopening of the containnent isolation valves without deliberate operation action.
The addition of control room valve position indication ard control for i
the new Division II valves is included in the proposed design modification. The inpmts from the proposed change, asscciated with the conttol room, will result in changes to both sinulator and associated operator training courses.
'HCiti1 CAL _fiE2CIEICATION CBNGBS
%e Fermi 2 'Ibchnical Specifications should be modified to include two new PCPMS automatic isolation valves (T50-F455 and T50-F456) in Table 3.6.3-1 (see proposed page changes). These valves are pilot solenoid air operated ball valves which incorporate the diversified automatic high drywell pressure and Level 2 isolation signals. The valves are proposed as Group 17 automatic isolation valves which require associated maxinum isolation time of 60 secoMs. This isolation tine is based upon the guidelines established in Section 6.2.4 of the 1
Standard Revlew Plan (NURm-0800).
l i
Attachment to NBC-88-0004 Page 4 Additionally, the Fermi 2 Technical Specifications should be modified to include two PCPMS automatic isolation valves (T50-F450 and T50-F451) which had been previcusly installed. The design modification performed in January 1984 (discussed above), should have been reflected in Table 6.2.2, "Sumary of Primary Containnent Penetrations and Associated Isolation Valves," of the Final Safety Analysis Report (FSAR) to show valves T50-F450 and T50-F451 as isolation valves associated with containnent penetrations X-48 a-e aM X-215. The Fermi 2 %chnical Specifications for primary containnent isolation valves were developed primarily on the basis of FSAR Table 6.2-2.
Reviews were nade to ensure the adequacy of these documents; however, the valves were omittal from Technical Specification Table 3.6.3-1.
This proposed anendnent corrects this oversight. 'Ihese valves are solenoid operated spring-to-close valves which will be modified to incorporate the diversified automatic high drywell pressure and Level 2 isolation signals. The valves are proposed as Group 17 automatic isolation valves which require associated maxinum isolation time of 60 secoMs. This isolation tine is based upon the guidelines established in Section 6.2.4 of the Standard Review Plan (NURIE-0800).
ENNIFICNE_lB3NOS_CCHi!DRETIGi In Ecordance with 10CFR50.92, Detroit dison has made a determination that the proposed anendment involves no significant hazards considerations. % nake this determination, Detroit dison nust establish that operation in reordance with the proposed anendnent would not:
- 1) involve a significant increase in the probability or consequences of an rcident previcusly 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 change to incorporate the four PCBMS autcanatic isolation valves into Table 3.6.3-1 does not involve a significant imrease in the probability or consequerres of an accident previously evaluated. This change involves a modification that upgrades the PCPMS isolation design to the standards set forth in 10 CFR Part 50, Appendix A, General Design Criterion (CDC 56). The modification will, in fact, decrease the consequences of an accident previously evaluated as the modification provides two redundant and divisional automatic inolation valves on the inlet line and two redundant and divisional automatic isolation valves on the outlet line of the PCPMS. The automatic control logic for each division provides a diverse valve trip / closure signal resulting from high drywell pressure and low reactor water level (Level 2).
Attachment to NBC-88-0004 Page 5
'Ite previous design was an unacceptable alternative to neet the requirements of GDC 56. The modification upgrades the PCPMS isolation design to the standards set forth in (EC 56 and corrects an error in denoting the existing valves. As such, the proposed changes are like Exanples (i) and (ii) of amendments that are considerd not likely to involve a significant hazards consideration (51 FR 7751 datM March 6, 1986).
- 2) 'Ihe proposed change to incorporate the four PCBMS autctnatic isolation valves into Table 3.6.3-1 does not create the possibility of a new or different kiM of accident from any accident previously evaluated. As discussed in 1) above, these changes are changes that constitute additional limitations to ensure adequate prinary containnent isolation that are not presently included in the 'Nchnical Specifications. These changes do not result or create any new accident modes.
- 3) The proposed changes to incorporate the four PCBMS automatic isolation valves into Table 3.6.3-1 does not involve a significant reduction in a margin of safety. In fact, the margin of safety has been increased by the additional limitations to ensure adequate primary containment isolation.
Based upon the above reasoning, Detroit niison has determined that the proposed ameMnent does not involve a significant hazards consideration.
MFIDQteNRL IIRCI Detroit Edison has reviewcrl the proposM Technical Specification changes against the criteria of 10CFR51.22 for environnstal considerations. As shown above, 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 cunulative occupational radiation exposures. Based on the foregoing, Detroit nlison concludes the proposed Technical Specifications do neet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environnental Inpact Statenent.
f
Attachment to NIC-88-0004 Page 6 CGCIDSTW Based on the evaluations 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 conpliance with the Conunission's regulations and proposed amendnents will not be inimical to the conston defense and security or to the health and safety of the public.
The change requested herein results from nodifications to bring the PCBMS isolation design up to the standards set forth in (DC 56. 'Ihe change has been determined not to involve a Significant hazards Consideration as it neets Exanples (i) and (ii) of anendnents that are considered not likely to involve Significant Hazards Considerations (51 FR 7751).
Attachnent to hTC-88-0004 Page 7 FIGURB 1 l
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'11CHNICAL SPICIFICATICN PAGE CIRNE
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TABLE 3.6.3-1 (Continued)
PRIMARY CONTAINMENT ISOLATION VALVES y
MAXIMUM g
ISOLATION TIME VALVE FUNCTION AND NUMBER (Seconds)
Automatic Isolation Valves (*) (Continued)
[
A.
h 14.
Group 14 - Drywell and Suppression Pool Ventilation System (Continued)
Suppression Pool N and Air Purge Inlet Isolation Valves N
2 T48-F404 5
T48-F405 5
T48-F409 S
- 15. Group 15 - Traversing In-core Probe (TIP) System Tip System Ball Valves C51-F002 A, B, C, D and E NA 16.
Group 16 - Nitrogen Inerting System N Pressure Control Isolation Valves 2
Inboard:
T48-F455 60 1
Outboard: T48-F453 60 T48-F454 60 m
T48-F456 60 T48-F457 60 T48-F458 60 17.
Group 17 - Recirculation Pump System and PA,
,v G4~,.6 R.J.s.;
Ma.4. ;,3 5,34,,,,
Rectrculation Pumps Seal Purge Isolation Valves l
Inboard:
B31-F014A 5
B31-F0148 5
h Outboard:
831-F016A 5
a B31-F016B 5
a
. :msenta 11 18.
5Wp'I - Primary Containment Pneumatic Supply System N to Drywell Isolation Valves g
2 Inboard:
T49-F601 60 T49-F602 60
-o Outboard:
T49-F465 60 T49-F468 60
-