ML20235A144
| ML20235A144 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/15/1987 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20235A148 | List: |
| References | |
| CON-NRC-87-0164, CON-NRC-87-164 NUDOCS 8709230220 | |
| Download: ML20235A144 (14) | |
Text
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4.
G. R;lph SylvL:
Group Vice President 6400 North Drxie Hi Ec ison==
ghway L
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Septenber 15, 1987 NIC-87-0164 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
Reference:
Fermi 2 NIC Docket No. 50-341 IEC License No. NPF-43
Subject:
Proposed Exigent Technical Specification (License Amendment) Change - Primary Containment Isolation Valves (3/4.6.3)
Pursuant to 1(CFR50.90, Detroit Edison Conpany hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into Technical Specification 3/4.6.3 - Primary Containment Isolation valves. The proposed change corrects footnotes which specify the type of leakage test required for various valves in Table 3.6.3-1. provides a request to modify the notation on six (6) primary containment isolaticn valves to require Type C air leakrate testing. Enclosure 2 provides a request to modify the notation on five (5) primary containment isolation valves to require Type C hydrostatic leakrate testing. Enclosure 3 provides a request to modify three (3) editorial corrections to Table 3.6.3-1.
Enclosure 4 provides the proposed page changes identified in each of the previous enclosures. The revisions discussed herein are required for l
returning the respective valves to an operable status and resuming i
Fermi 2 operation. Detroit Edison requests this proposed change be processed under an exigent authorization in order to facilitate a restart of Fermi 2.
The exact date of restart is dependent upon further interaction between Detroit Edison and the NIC. However, the expected date of restart is prior to the 30-day require 3 notice as discussed in 10CFR50.91(a) (2) (ii). Thus, this represents exigent circumstances as discussed in 10CFR50.91(a) (6).
Detroit Edison has evaluated the proposed 'Ibchnical Specification changes against the criteria of 10CFR50.59 ard 10CFR50.92 and determined that no unreviewed safety question or significant hazards consideration is involved. As a result of the discrepancies identified by the surveillance procedure review, Detroit Edison performed a review of Table 3.6.3-1 and concludes that no additional
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USNIC September 15, 1987 NIC-87-0164 Page.2
- discrepancies exist between the Technical Specifications, the Inservice 'Ibsting Program and the Updated Final Safety Analysis Report. Detroit Edison is also evaluating the effectiveness of previous reviews of the Fermi 2 Technical Specifications and the subsequent need for any additional reviews.
The Fermi 2'Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed the proposed _ Technical Specification changes and concurs with the enclosed determinations.
Pursuant to 10CFR170.12(c), enclosed with this amendment is a check for one hundred and fifty dollars ($150.00). Pursuant to 10CFR50.91(b) (1), the State of Michigan has been notified by copy of this amendment request. Mditionally, the Regional Mministrator of, Region III and the Senior Resident Inspector have been provided copie -
of this application. Your pronpt attention to this application is appreciated.
If you have any questions, please contact Mr. John Price at (313) 586-4513.
Sincerely, fal
(
Enclosures cc: Mr. A. B. Davis Mr. E. G. Greenman Mr. W. G. Rogers Mr. J. J. Stefano s
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b.
L' USNIC Septenber 15i 1987 NIC-87-0164 Page 3 L
'I, B. IRLPH SYLVIA, do"hereby affirm that the foregoing statements are based on facts and circumstances which are true and a:: curate to the best of my knowledge and belief.
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~B. RAIIH SYJgIA Group Vice President on this
'/ 6A day of tb' o fen h / A -, 1987, before me personally appeared B. Ralph Sylv'ia, being first duly sworn and says that he executed the foregoing as his free act and deed.
4')1 kud.
%faAnn Notary Public KAREN M. REED Nettry Public, Monroe County, Mich.
Cur.rrirsion Excites May 14,19H i
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I B U G DBE_1 l
I.
BacxGnopto/bISCUSSION The present Primary Containment Isolation Valve Technical Specification (3/4.6.3), Table 3.6.3-1, Item A.3, Group 3 -
Residual Heat Removal (RHR) System, RHR Containment Cooling / Test Isolation Valves (Ell-F024A and Ell-F024B) and Item A 17, Group 17 - Recirculation Punp System, Recirculation Punps SetJ. Purge Isolation Valves (B31-F014A, B31-F014B, B31-F016A and B31-F016B) currently require a Type C hydrostatic leakage test as specified by Footnote (b). The proposed change would delete the application of Footnote (b) to the valves listed sbove, thereby requiring.a Type C air leakage test consistent with 10CFR50 Appendix J.
While conducting a surveillance procedure review, several discrepancies were identified in Technical Specification Tabla 3.6.3-1.
We Technical Specification Table 3.6.3-1 requires a Type C hydrostatic leakage test to val"es E11-F024A & B, B31-F014A & B, and B31-F016A & B.
%e hydrotitatic leakage test required by the Technical Specifications conflicts with the requirements specified in 1(CFR50 Appendix J.
The Updated Final Safety Analysis Report (UFSAR) on page 6.2-92, specifies that a Type C air leakage test must be performed unless a 30-day. water seal can be maintained on the valve after an accident requiring containment isolation. We valves noted above cannot maintain this 30-day water seal and thus are required to be Type C air leak tested.
Detroit Riison implemented an Inservice Testing (IST) Program for Punps and Valves to measure containment leakage rates and to verify that these rates are within allowable limits. This is performed prior to initial operation of the plant and periodically throughout the operating life of the plant. The Detroit Edison Preservice Program baseline test and the on-going surveillance test performed to date have utilized the Type C air leakage test which is a more stringent and conservative leakrate test. The requested change is consistent with the Fermi 2 IST Program, Surveillance Test Program, UFSAR, and the requirements of 10CFR50 Appendix J.
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.Septenber 15, 1987 NBC-87-0164 Page 2 Enclosure?1 SIGNIFICMFf HMNDS 0016IDEEUG'IOi In accordance with 10CFR50.92, Detroit Edison made a determination that the proposed amendment involves.no significant - hazards. considerations. To make this determination, Detroit Edison nust 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 from any accident previously evaluated, or, 3). involve a significant reduction in a margin of safety.
1)- The proposed change to delete the application of Footnote (b) to valves Ell-F024A & B, B31-F014A & B and B31-F016A &
B, thereby requiring a Type C air leakage test rather than a Type C hydrostatic leakage test does not involve a significant increase in the probability or consequences of an rcident previously evaluated. The correct application of 10CFR50 Appendix J would in fact require a Type C air leakage test. The Type C air leakage test results would be more conservative than those results of a Type C hydrostatic leakage test.
2)
The proposed change does not create the possibility of a new or different kind of scident from any mcident previously evaluated. The analysis described in the UFSAR does not take credit for a Type C hydrostatic leakage test for these valves unless a 30-day water seal can be maintained on the valve after an accident requiring containment isolation.
These valves cannot maintain this 30-day water seal and thus are required to be Type C air leak tested in accordance with 10CFR50 Appendix J.
Mditionally, the change does not add any new equipment, does not affect the operation of any of the systems, or alter any of the design assumptions previously evaluated.
- 3) The proposed change does not involve a significant reduction in a margin of safety as detailed in 1) and 2) above.
Performing a Type C air leakage test rather than a Type C hydrostatic leakage test actually increases the margin of safety.
CGCLDSEM Based on the evaluations above:
(1) there is reasonable assurance that the health and safety of the public will not be
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Septenber ~15,1987 NRC-87-0164
' Page 3 Enclosure 1 i
endangered by operation in the proposed manner, and (2) such.
1 activities will be conducted. in coupliance with the Commission's regulations ~ and proposed amendments will not be. inimical to the comon defense and security or to the health and safety of the public.
j II.
REVISED TIEEINICAL SPIEIFICRTIGEi
.The requested revision is provided as Enclosure 4.
j III. INIIDUM COEENSMGtY NBASURES Fermi 2 currently does not meet the requirements of the Technica1' Specifications. The valves have been successfully tested utilizing a more conservative Type C air leakage test.
In the interim, however, these valves will remain administratively inoperable until approval of this request is received, or ~otherwise notified by the Nuclear Regulatory Commission.
IV.
BASIC FCR EKIG50'_CIKDISDiCES The revisions discussed herein are requird for returning the
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valves to an operable status and resuming Fermi 2 operation.
Detroit Edison requests this proposed change be processed under an exigent authorization in order to facilitate a restart of Fermi 2.
The exact date of restart is dependent upon further interaction between Detroit Edison and the NIC. However, the expected date.of restart is prior to the 30-day require 3 notice as discussed in 10CFR50.91(a) (2) (ii). Performing the stated requirements of the current Fermi 2 Technical Specifications would be inconsistent with the requirements of 10CFR50 Appendix J.
Therefore, the proposed change represent exigent circumstances as discussed in 10CFR50.91(a) (6).
V.
SCHEDULE FGt NrmINIE COE%IAICB As indicated in Item III above, these valves will renain administrative 1y inoperable until approval of this request is received, or otherwise notified by the Nuclear Regulatory Commission.
VI.
NOTIFICATION GP SUtrB PEREGG4BL The State of Michigan has been notified by copy of this amendment request.
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September 15, 1987-NBC-87-0164 f.
Page 4 Enclosure 1
-VII.
EIWI1OBEENEL IDESCT Detroit B31 son 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 increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Inpact Statement.
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I EENOSURE 2 l
I.
BACKGROUtO/bISCUSSIGT The present Primary Containment Isolation Valve Technical Specification (3/4.6.3), Table 3.6.3-1, Item B.5, Warmup and Flush Line Isolation Valve (Ell-F026B); Item D.12, HPCI Turbine Exhaust Drain Pot Drain to Suppression Chamber Reverse Stop Check Valve (E41-F022); Item D.13, BCIC Turbine Exhaust Line Isolation Check Valve (E51-F001); Item D.14, HPCI Turbine Exhaust Line Isolation Valve (E41-F021); and Item D.15, ICIC Barometric Condenser Vacuum Punp Discharge Stop Check Valve (E51-F002) currently requires a Type C air leakage test. The proposed change would add Footnote (b) specifying that these valves be hydrostatic leakrate tested.
While perfora: fag a surveillance proce3ure review, several discrepancies were identified in Technical Specification Table 3.6.3-1.
The Technical Specification Table 3.6.3-1 requires a Type C air leakage test to valves Ell-F026B, E41-F022, E51-F001, E41-F021, and E51-F002. The air leakage test required by the Technical Specification conflicts with Detroit H31 son's Inservice Testing (IST) Program for Punps and Valves.
The requirements of 10CFR50 Appendix J, as notei on page 6.2-92 of the Updated Final Safety Analysis Report (UFSAR), specify that a Type C air leakage test must be performed unless a 30-<1ay water seal can be maintained on the valve after an mcident requiring containment isolation. Each valve noted above is referenced in UFSAR Table 6.2-2 by reference Note 26. This reference notation (page 6.2-203 of the UFSAR) indicates that the flowpath associated with the valve penetration insido containment is terminated below the low water level in the suppression pool. Thus, a water seal is assured during r ormal plant operation and for more than 30 daya following an accident requiring containment isolation. It is not credible that these isolation valves will be exposed to the containment atmosphere at any time following the mcident. The UFSAR also indicates that these containment isolation valves will be Type C leak tested using either water or air. This testing is consistent with that allowed by 10CFR50 1ppendix J.
Detroit B31 son implemented an Inservice Testing (IST) Pr > gram for Pumps and Valves to measure containment leakage rates and to verify that these rates are within allowable limits. This is
September 15, 1987 1mC-87-0164 Page 2 Enclosure 2 performed prior to initial operation of the plant aM periodically throughout the operating life of the plant. The Detroit B31 son Preservice Program baseline test and the on-going surveillance test performed to date have utilized a Type C hydrostatic leakage test. Performing a Type C air leakage test at this time is not preferred for the following reasons:
1)
These valves neet the criteria of 10CFR50 Appendix J for utilizing a Type C hydrostatic leakage test. Performing a Type C air leakage test would require adjustment to the overall leakage program for air tested valves.
2)
These valves were baseline tested with a Type C hydrostatic test. Performing a Type C air leakage test at this time would invalidate the baseline test aM would invalidate any data obtained for trending leakage from these valves.
S7CNIFICANP HAZAIOS CChwNATION In accordance with 10CFR50.92, Detroit B31 son has made a determination that the proposed anendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that operation in scordance 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 from any accident previously l
evaluated, or, 3) involve a significant reSuction in a margin of safety.
1)
The proposed change to add the application of Footnote (b) to valves Ell-F026B, E41-F022, E41-F021, E51-F001 and E51-F002, thereby requiring a Type C hydrostatic leakage test rather than a Type C air leakage test does not involve a significant increase in the probability or conseyences of an tccident previously evaluated. The application of a Type C hydrostatic leakage test is consistent with 10CFR50 Appendix J and the analysis detailed in the UFSAR. The surveillance requirement provides appropriate testing to demonstrate and measure containment leakage rates. The change does not change any of the design features or any of the intended safety functions of the respective valves.
2)
The proposed change does not create the possibility of a new or different kind of accident from any cccident previously evaluated. The analysis described in the UFSAR 1
Septenber ~ 15,.1987 '
.NBC-87-0164
.Page 3 Enclosure-2 takes credit for a Type C hydrostatic. leakage test when a 30-day water seal can be maintained on the valve after an-accident requiring containment isolation. Mditionally, the change does not ' add any new' equipment, does not affect the operation of any of the systems, or alter any'of the design assumptions previously evaluated.
3)
The proposed change does not involve a significant reduction in a margin of safety as detailed in 1) and 2) above.
CGCLUSION 1
-i 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 Commission's regulations and proposed amendnents will not be inimical to the commn defense and security or to the health and safety of the public.
II.
EtWIfiB). 'DCIMICM. SPICIFICATIGE The requested revision is provided as Enclosure 4.
III. IMIEluMpr3EgggggELINESHES Fermi 2 currently does not meet the requirements of the Technical Specifications. W e valves have been successfully tested utilizing a Type C hydrostatic leak test. In the interim, however, these valves will remain administrative 1y inoperable until approval of this request is received, or otherwise notified by the Nuclear Regulatory Commission.
IV.
BASIS FOR EKIGENT CIICGIMNCES The revisions discussed herein are required for returning the valves to an operable status and resuming Fermi 2 operation.
Detroit Edison requests this proposed change be processed under an exigent authorization in order to facilitate a restart of Fermi 2.
%e exact date of restart is dependent upon further interaction between Detroit Mison and the NIC. However, the expected date of restart is prior to the 30-day required notice as discussed in 10CFR50.91(a) (2) (ii). Performing the stated requirements of the current Fermi 2 Technical Specifications would invalidate the baseline preservice combined leakrate test and require adjustment to the overall leakrate testing program I
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Septenber 15, 1987 15C-87-0164 Page 4 Enclosure 2 for air. tested valves. Therefore, the proposed change represents exigent circumstances as discussed in 10CFR50. 91(a) (6).
V.'
SCHEDULE FGt ATRINIIC CGE'LIAPCE As indicated in Item III above, these valves will remain administratively inoperable until approval of this request is received, or otherwise notified by the Nuclear Regulatory Commission.
VI.
NOTIFICATION T STM PERSOINE The State of Michigan has been notified by copy of this amendment request.
VII. ]R57NyqpRhL ~DESCT Detroit niison 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 sigt.ificant hazards consideration, nor increase the types and amounts of effluents that may be. released offsite, nor significantly increase individual or cumulative occupational-radiation exposures. Based on the foregoing, Detroit Edison concludes. that the proposed Technical Specifications do reet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Inpact Statement.
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F> CLOSURE 3 I.
D80KGROUFO/bISCUSSION While performing a surveillance procedure review, several editorial and typographical discrepancies were identified in Technical Specification Table 3.6.3-1 and are noted below:
A)
The present Primary Containment Isolation Valve Technical Specification (3/4.6.3), Table 3.6.3-1, Item D.16, Combustible Gas Control System Return Line Relief Valves (T48-F016A and T48-F016E) currently do not require a Type C leakage test as denoted by Footnote (r). The proposed change would delete the application of Footnote (r) to the valves listed above, thereby requiring a Type C air leakage test consistent with 10CFR50 Appendix J.
The Technical Specification Table 3.6.3-1 does not require a Type C leakage test to valves T48-F016A & B.
The application of Footnote (r) in the Technical Specifications, identifying that these valves are net subject to Type C leakage tests, conflicts with the requirements specified in 1(CFR50 AppeMix J, the Fermi 2 Inservice Testing (IST) Program for Ptmps and Valves, the Surveillance Test Program, an3 the Updated Final Safety Analysis Report.
Detroit Edison implemented the IST Program to measure containment leakage rates and to verify that these rates are within allowable limits. This is performed prior to initial operation of the plant and periodically throughout the operating life of the plant. The Detroit Edison Preservice Program baseline test and the on-going surveillance test performed to date have utilized the Type C air leakage test which is beyond that currently required by the Technical Specifications.
B)
The present Primary Containment Isolation Valve Technical Specification (3/4.6.3), Table 3.6.3-1, Item A.10, Group 10 - Reactor Water Cleanup (RWCU) System (Inboard Valve G33-F001) currently is not designated by Footnote (c). The proposed change would aid the application of Footnote (c) to valve G33-F001 consistent with its own notation.
The 'Ibchnical Specification Table 3.6.3-1, Footnote (c) states that "FHCU Water Temperature - High automatically closes G33-F004, outboard isolation, and G33-F001, inboard isolation." The application of this notation is applied to
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Septeaber 15, 1987-NBC-87-0164 Page 2 to Enclosure 3 i
the G33-F004 valve but was inadvertently omitted to the l
G33-F004 valve. This is clearly an editorial oversite and a purely administrative correction.
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C)
The present Primary Containment Isolation Valve Technical ~
Specification (3/4.6.3), Table 3.6.3-1, Item B.5, Warmp and Flush Line Isolation Valve (Ell-F026B) currently is i
designated as Ell-F026. The proposed change would corre::t j
this typographical error.
j SIGNIFICMrf HUMOS CCEIDEIRTION In accordance with 10CFR50.92, Detroit Edison has made.a determination.that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that operation in s cordance with the proposed amendment would not: 1) involve a significant j
increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or i
different kind of accident from any mcident previously evaluated, or, 3) involve a significant reduction in a margin of safety.
1)
The proposed change to A) delete the application of Footnote (r) to valves T48-F016A & B, thereby requiring a Type C air leakage test, B) add Footnote (c) to valve i
G33-F001, and C) correct the identification of valve
- Ell-F026B does not involve significant increase in the probability or consequences of an accident previously evaluated, nor creates the possibility of a new or
.i different kind of meident from any accident previously l
evaluated, nor involves a significant ra3uction in a margin l
of safety. These changes are editorial corrections only and purely administrative, and therefore, falls into the i
category of amendments that are considered not likely to involve Significant Hazards Consideration (14870 FR Vol. 48 No. 67 (i)). The changes do not involve a physical change j
to the plant, change a limiting condition of operation, or change any operating practice.
00K10SION Based on the evaluations above:
(1) there is reasonable assurance that the health and safety of the public will not be j
endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and proposed amerdments will not be inimical to the common defense and security or to the health and safety of the public.
September 15, 1987 NIC-87-0164 Page 3 to Enclosure 3 II.
REVISED TBCtlNICAL m'annCATICRE The requested revision is provided as Enclosure 4.
III. INTERIM CO@EREMUE BERSURES l-Fermi 2 currently meets the requirements of the Technical Specifications. Therefore, no interim compensatory measures are l
required.
IV.
BASIS PGt EKIGIBFT CIICLMSMICES
'Ihe revisions discussed herein are required to correct editorial discrepancies in the Technical Specification Table 3.6.3-1.
As discussed with the Nuclear Regulatory Commission these revisions are being provided as an attachment with this exigent request to ensure all corrections to Table 3.6.3-1 are incorporated at this time.
V.
!QFWIAJIR ATRINIfG CQH.IMCE As indicated in Item III above, Fermi 2 is currently in conpliance with the applicable Technical Specifications.
VI.
NWIFICATION & SMTE PERS0tHE The State of Michigan has been notified by copy of this amendment request.
VII. NWIlotR2mL_DFK't Detroit B31 son 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 increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c) (9) for a categorical exclusion from the requirement for an Environmental Inpact Statenent.