ML20207F995

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Safety Evaluation Supporting Amend 132 to License NPF-43
ML20207F995
Person / Time
Site: Fermi 
Issue date: 03/03/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20207F987 List:
References
NUDOCS 9903110386
Download: ML20207F995 (5)


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i UNITED STATES L;

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30086 0001

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i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l

RELATED TO AMENDMENT NO.132

' FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDISON COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated April 9,1998 (NRC-98-0071), the Detroit Edison Company (DECO or the licensee) requested an amendment to the Technical Specifications (TSs) appended to Facility j

Operating License No. NPF-43 for Fermi 2. The proposed amendment would revise TS 3.7.1.2," Emergency Equipment Cooling Water System," Action a, for the emergency equipment cooling water (EECW) system and TS 3.8.1.1, "A.C. Sources - Operating," Action c, i

for emergency diesel generators (EDGs) to be consistent with the actions required for i

inoperable primary containment oxygen monitoring instrumentation in TS 3.3.7.5, " Accident l

Monitoring Instrumentation." The existing """ footnote to TS 3.7.1.2, Action a, would be modified and a "" footnote would be added to TS 3.8.1.1, Action c.

2.0 EVALUATION 2.1' Current TS Reauirements i

Fermi TS 3.7.1.2, Action a, currently requires that:

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- Within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s: a) verify that all required systems, subsystems, trains, components and devices that depend upon the remaining OPERABLE EECW system subsystem are also OPERABLE... Otherwise", be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the

. follow;ng 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The """ footnote provides an exception for an inoperable drywell cooling unit (TS 3.7.11) in the opposite division. It allows the action for Specification 3.7.11 to be taken for the inoperable drywell cooling units rather than requiring an immediate entry into the 12-hour shutdown statement of Specification 3.7.1.2, Action a.

Current TS 3.8.1.1, Action c, states With one or both diesel generators in one of the above required onsite A.C.

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~ within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that all required systems, subsystems, trains, components and electrical power divisions inoperable, in addition to ACTION b, above, verify j

devices that depend on the remaining onsite A.C. electrical power division as a y

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~. source of emergency power are also OPERABLE; otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Under TS 3.3.7.5, Table 3.3.7.5-1, Action 83, if both primary containment oxygen monitors are inoperable, the licensee is required to restore the inoperable channel (s) to operable status -

- within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

' Under' current TS 3.7.1.2, Action a, if, for example, the Division I primary containment oxygen monitor is inoperable and the Division ll EECW system becomes inoperable, Action a.1.a i

cannot be satisfied and the licensee is required to place the plant in at least hot shutdown withh the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The shutdown action is entered in this case because both primary containment oxygen monitors are inoperable (with the Division ll monitor inoperable because its associated EECW system is inoperable).

However, this action is more restrictive than the action required by TS 3.3.7.5 which specifically addresses the primary containment oxygen monitors.

l Similarly, under current TS 3.8.1.1, Action c, if the Division I primary containment oxygen l

monitor is inoperable and one or both of the Division ll EDGs becomes inoperable, Action c requires the licensee to place the plant in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Again, the shutdown action is entered because both primary containment oxygen monitors are inoperable (with the Divisim II :nonitor inoperable because its associated EDG(s) are inoperable). However, this action is also more restrictive than the action required by TS 3.3.7.5 which specifically addresses the primary containment oxygen monitors.

2.2 Prooosed TS Reauirements The licensee proposed to revise the """ footnote to TS 3.7.1.2, Action a, to provide relief for an

. Inoperable primary containment oxygen monitor similar to the relief already provided for the drywell cooling units. Specifically, the footnote would be revised to read:

Except for an inoperable Drywell. Cooling Unit, required by Specification 3.7. i1 or an inoperable primary containment oxygen monitoring instrumentation channel, required by Specification 3.3.7.5, that depends on the remaining OFERABLE EECW system subsystem. In these cases, take the ACTION required by Specification 3.7.11 for the inoperability of both required Drywell Cooling Units or l

. Specification 3.3.7.5 for the inoperability of both required primary containment j

oxygen monitoring instrumentation channeis.

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. With this proposed change, if the Division I primary containment oxygen monitor is inoperable and the Division ll EECW system becomes inoperable, the licensee would be required to take the action prescribed by TS 3.3.7.5 (i.e., Action 83, restore the inoperable channel (s) to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least hot shutdow, within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) for the i:

two inoperable channels of primary containment oxygen monitoring instrumentation. - The p

licensee would also be required to take the actions rcquired by TS 3.7.1.2 for the inoperable

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EECW subsystem.

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3-Similarly, a "" footnote would be added to TS 3.8.1.1, Action c, to provide relief for an inoperable primary containment oxygen monitor similar to the relief provided for in TS 3.7.1.2.

Specifically, the new footnote would read:

' Except for an inoperable primary containment oxygen monitoring instrumentation -

l' channel, required by Specification 3.3.7.5, that depends on the remaining j

OPERABLE onsite A.C. electrical power division. In this case, take the ACTION.

l required by Specification 3.3.7.5 for the inoperability of both required primary d

l containment oxygen monitoring instrumentation channels.

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l With this proposed change, if the Division I primary containment oxygen monitor is inoperable and one or both of the Division 11 EDGs becomes inoperable, the licensee would be required to take the action prescribed by TS 3.3.7.5 (i.e., Action 83, restore the inoperable channel (s) to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) for the two inoperable channels of primary containment oxygen monitoring instrumentation. The licensee would also be required to take the actions required by TS 3.8.1.1 for the inoperable EDG(s).

l 2.3 Evaluation and Conclusion l

. The primary containment oxygen monitors provide indication and alarms to the operators. But l

they do not initiate any automatic functions. The data from the oxygen monitors is used by the operators to determine whether actions are necessary to reduce the oxygen concentration.

TS 3.6.6.2 requires the licensee to maintain drywell and suppression chamber atmosphere oxygen concentrations at less than 4 percent by volume. However, grab samples of the atmosphere could also be used to determine oxygen concentrations if the oxygen monitors were not available. In addition, the data from these instruments is not critical for entry into the Emergency Operating Procedures.' The entry conditions for post-accident hydrogen control are based on containment hydrogen concentrations, which are monitored separately.-

l Based on these factors, and as documented in existing TS 3.3.7.5, Action 83, the staff has previously determined that it is acceptable for both primary containment oxygen monitoring i

instrumentation channels to be inoperable for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before entering a 12-hour shutdown action statement. The reason the channels are inoperable is irrelevant to this finding.

However, the current wording in TSs 3.7.1.2 and 3.8.1.1 would lead to the more restrictive action of immediately entering a 12-hour shutdown action statement if a second channel of primary containment oxygen monitoring instrumentation is declared inoperable because of an inoperable EDG or EECW subsystem. Therefore, the action statements in TSs 3.7.1.2 and 3.8.1.1 are inconsistent with, and more restrictive than, Action 83 in TS 3.3.7.5. The revised i

""" footnote to TS 3.7.1.2, Action a, and the new "*" footnote to TS 3.8.1.1, Action c, eliminate this inconsistency by referring the operators back to TS 3.3.7.5. The staff concludes that the proposed changes are acceptable. The staff also notes that the proposed changes result in actions that are consistent with the intent of the Safety Function Determination Program that is a part of the improved standard TSs (NUREG-1433, Revision 1," Standard Technical Specifications, General Electric Plants, BWR/4," April 1995).

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3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Michigan State official was notified of the l

proposed issuance of the amendment. The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

l The amendment changee 2 toquirement with respect to the installation or use of a facility f

component located within the restricted area as defined in 10 CFR Part 20. The staff has

- determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any' effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding

. (63 FR 50937). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental l

impact statement or environmertal assessment need be prepared in connection with the l'

issuance of the amendment.

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5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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) ;he issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Andrew Kugler i

i Date: March 3, 1999

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March 3, 1999 e

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' Mr. Douglas R. Gipan

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Senior Vice President l;

Nuclear Generation l

Detroit Edison Company L

6400 North Dixie Highway Newport, MI 48166 l

SUBJECT:

FERMI 2 -ISSUANCE OF AMENDMENT RE: ACTION STATEMENTS L

RELATED TO THE PRIMARY CONTAINMENT OXYGEN MONITORING INSTRUMENTATION (TAC NO. MA1569)

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Dear Mr. Gipson:

The Commission has issued the enclosed Amendment No.132 to Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated April 9,1998 (NRC-98-0071).

The amendment revises TS 3.7.1.2," Emergency Equipment Cooling Water System," Action a and TS 3.8.1.1, "A.C. Sources - Operating," Action c, to be consistent with the actions required for inoperable oxygen monitoring instrumentation in TS 3.3.7.5, " Accident Monitoring Instrumentation." The existing """ footnote to TS 3.7.1.2, Action a, is modified and a "*"

footnote is added to TS 3.8.1.1, Action c.

A copy of our Safety Evaluation is also enclosed. The notice of issuance will be included in the Commission's biweekly Federa/ Register notice.

Sincerely, Original signed by:

1 Andrew J. Kugler, Project Manager Project Directorate ill-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No.132 to NPF-43
2. Safety Evaluation cc w/ encl:

See next page DISTRIBUTION: See attached page l

DOCUMENT NAME: G:\\PD3-1\\WPDOCS\\ FERMI \\AMDA1569.WPD

  • See previous concurrence T,eeche o copy of this docu,nent, indicate in the box: "C* e Copy without attachment / enclosure "E" = Copy with attachment /encIDeuve "N". No copy l

OFFICE PM:PD31 E

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  • C:SPLB C:EELB lC OGC g D:PD31 lC NAME AKugler:d CJamerson Hubbard for JCalvo 4 g.

CACarpen DATE 02/ l 0 /99V 02/ lo /99 I/

02/10/99 02//1 /99 d / 9/ /99 b/ % /99 OFFICIAL RECORD COPY q

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