ML20236A905
| ML20236A905 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/09/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236A887 | List: |
| References | |
| NUDOCS 8710230226 | |
| Download: ML20236A905 (6) | |
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'o, UNITED STATES 37 (,g NUCLE AR REGULATORY COMMISSION g g^
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.10 TO FACILITY OPERATING LICENSE NO. NPF-43 DETROIT-EDISON COMPANY WOLVERINEPOWERSUPPLkCOOPERATIVE, INCORPORATED FERMI-2 DOCKET NO. 50-341
1.0 INTRODUCTION
By letter dated September 15, 1987, Detroit Edison Company-fthe licensee) proposed the following changes to Table 3.6.3-1 of the Frim;-2 Technical Specifications (TSs) which specify the leakage testing requirements for the containment isolation valves in accordance with the provisions of 10 CFR 50, Appendix J:
Delete the application of Footnote (b) for the Residual Heat Removal System, Containment Cooling / Test Isolation Valves (E11-F024A/F024B),
and the-Recirculation Pump System, Recirculation Pumps. Seal Purge Isolation Valves (B31.-F014A, F0148, F016A and F0168), which currently requires these valves to be Type C hydrostatically leak tested per 10 CFR 50, Appendix J.
The deletion of Footnote (b) would require these valves to be Type C air Jeak tested.
Add the application of Footnote (b) for the Warmup and Flush Line Isola-
. tion Valve (E11-F026B), the High Pressure Coolant Injection (HPCI)
Turbine Exhaust Drain Pot Drain to Suppression Chamber Reverse Stop Check Valve (E41-F022), the Reactor Core Isolation Cooling (RCIC)
Turbine Exhaust Line Isolation Check Valve (E51-F001), the HPCI Turbine Exhaust Line Isolation Valve (E41-F021), and the RCIC Barometric Condenser Vacuum Pump Discharge Stop Check Valve (E51-F002). The addition of Footnote (b) would require these valves to be Type C hydrostatically leak tested per 10 CFR 50, Appendix J, in lieu of the currently required air leak tests.
Delete the application of Footnote (r) for the Combustible Gas Control System Return Line Relief Valves (T48-F016A and T48-F0168).
The deletion of Footnote (r), which stipulates that a Type C leak test is not required, would change the Technical Specification for these valves requiring them to be Type C air leak tested per 10 CFR.50, Appendix J.
Add the application of Footnote (c) to the Reactor Water Cleanup (RWCU)
System Inboard Valve G33-F001, consistent with its own notation.
Correct.a typographical error in the designation of the Warm up and Flush Line Isolation Valve (E11-F026B) which is incorrectly designated E11-F026 in the current TSs.
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- 2. 0 EVALUATION We.have reviewed the proposed changes to Table 3.6.3-1 of.the Plant.TSs as described in the licensee's letter' dated September. 15, 1987.
Our findings and determinations based on that. review follow:
Deletion of Footnote (b) to Valves E11-F024A/F0249, B31-F014A/F0148, and a.
B31-F016A/F0168 1
The licensee stated'that, while conducting a surveillance procedure. review, several discrepancies were' identified in TS Table 3.6.3-1.
Table 3.6.3 erroneously requires the above valves to be. Type C hydrostatically leak tested, contrary to the analyses detailed in the' Fermi-2 Updated Final Safety Analysis Report (UFSAR) en page 6.2-92.
The UFSAR stipulates that.a Type C air-leak test must be perform J Jnless a'30-day water seal can be maintained on the valves after an accident requiring co_ntainment isolation.
These. valves.are not designed to maintain'a 30-day water seal and thus'must be Type C air leak tested.
The Fermi-2-Inservice Testing Program for Pumps and Valves-(the IST Program)'was implemented by the licensee to measure containment' leakage rates and to verify that these rates are within allowable limits.. These tests are performed prior to initial operation of the plant and periodically throughout the operating life of the plant.
The licensee's Preservice Program baseline test and the on going surveillance test program performed to date have utilized the Type C air leak test for these valves'which is a more stringent and l -
a
. conservative leak rate test.
.i The proposed change'to require these valves to be Type C air leak tested is consistent'with the design basis for these valves as described inithe UFSAR, and consistent with the Fermi-2'IST Program, Surveillance Test Program, and the requirements of 10 CFR 50, Appendix J.
The proposed change 1
is therefore acceptable to the NRC staff.
b.
Addition of Footnote (b) to Valves E11-F0268, E41-F021/F022, and E51-F001/F002 The licensee stated that a surveillance procedure review. identified several discrepancies in TS Table 3.6.3-1.
i Table 3.6.3-1 requires the'above. valves to be Type C air leak tested, contrary to.the design basis analysis detailed in the Fermi-2 UFSAR on page 6.2-92.
The UFSAR specifies that a Type C i
air leak test must be performed unless a 30-day water seal can be maintained on the valve after an accident requiring containment isolation.
Each of these valves is referenced in Table 6.2-2 of the UFSAR by reference Note' 26.
'This reference notation (page 6.2-203 of the UFSAR) indicates that the flowpath associated with these valve penetrations inside containment is terminated below the low water level in the suppression pool..Thus a water seal is assured during normal plant operation and for more than 30 days'following an accident requiring containment isolation.
The licensee states, and we agree, that it is not credible that these isolation valves.will be exposed to the containment i.
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atmosohere at any time following an accident.
The Fermi-2 IST Program and the l
licenseeLs Preservice Program baseline test and the on going surveillance tests l
performed to date on these valves have utilized a Type C hydrostatic leak test.
Performance of a Type C air leak test of these valves at this time is not i
preferred since:
(1) these valves meet the criteria of 10 CFR 50, Appendix J, for utilizing a Type C hydrostatic leak test, and the performance of a Type C l
air leak test would require an unnecessary adjustment to the overall leakage programforairtestedvalves;and(2)linetestdataobtainedfortrending performance of a Type C air leak test at this time would invalidate the base leakage from these valves.
The proposed addition of Footnote (b), which will require these valves to be Type C hydrostatically leak tested as designed, is consistent with the design l
basis analysis detailed in the UFSAR, the approved Fermi-2 IST Program and l
the Surveillance Test Program, and is therefore acceptable to the NRC staff.
j c.
Deletion of Footnote (r) to Valves T48-F016A/F0168 The application of Footnote (r) to the above containment isolation valves indicates that Type C leakage tests are not required, which conflicts with the l
requirements for the air or hydrostatic leak testing of containment isolation l
valves specified in 10 CFR 50, Appendix J, and is inconsistent with the FSAR l
design basis, the Fermi-2 IST Program, and the Surveillance Test Program l
which stipulate that these valves be Type C air leak tested.
Therefore, the j
deletion of Footnote (r), as proposed by the licensee, is acceptable to the staff.
d.
Add Footnote (c) to the RWCU System Inboard Valve G33-F001 Footnote (c) of Table 3.6.3-1 of the Plant TSs states that "RWCU Water Temperature-High automatically closes G33-F004, outocard isolation, and l
G33-F001, inboard isolation," but there is no application of Footnote (c) to the G33-F001 inboard isolation valve.
This is an error which the licensee proposes to correct, and is acceptable.
e.
Correction in Designation of Valve E11-F0268 The licensee proposes to correct a typographical error in Table 3.6.3-1 of the Plant TSs.
The change would correctly identify the Warmup and Flush Line Isolation Valve as E11-F0268.
We find this correction acceptable.
3.0 EMERGENCY CIRCUMSTANCES l
In its October 9, 1987 letter, the licensee requested that this amendment be treated as an emergency because insufficient time exists for the Commission's usual 30-day notice without extending the current outage.
Because the containment isolation valves are required to be returned to operable status prior to startup of Fermi-2, the licensee has determined that emergency circumstances exist for approval of these proposed revisions to resume Fermi-2 I
operation.
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In accordance with 10 CFR 50.91(a)(5), the licensee has explained that it could not have avoided this emergency situation because it was unknown to the licensee as to when NRC would allow restart.
This permission was only provided 1
on October 9, 1987.
The only obstacle to restart is this license amendment.
i The Commission has detern.ined that emergency circumstances exist in that swift action is necessary.to avoid a delay in startup not related to safety,
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In connection with a request indicating an emergency, the Commission expects its licensees to apply for license amendments in a timely fashion.
- However, with this consideration in mind, it has been determined that a circumstance has arisen where the licensee and the Commission must'act quickly, and the licensee has made a good effort to make a timely application.
- 4. 0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations if operation of the facility, in accordance with the 4
amendment, would not:
(1) Involve a significant increase in the probability or consequences of any 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.
With respect to the leak test require ~ ment change for valves E11-F024A and B, B31-F014A and B and 831-F016A and B:
(1) The proposed change does not increase the probability or consequences of an accident previously evaluated.
The licensee proposes to perform a Type C air leakage test rather than a Type C hydrostatic leakage test, currently specified by the Plant j
TSs. The Commission's regulations in 10 CFR 50, Appendix J, " Primary i
Reactor Containment Leakage Testing for Water-Cooled Power Reactors,"
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require a Type C air leakage test unless valves meet certain criteria 1
for allowing a less restrictive hydrostatic test.
By performing a Type C air leakage test on these valves, the licensee will be performing a test consistent with 10 CFR 50, Appendix J, requirements and the design basis analysis detailed in the Fermi-2 UFSAR.
(2) The proposed change does not create a new or different kind of accident from any accident previously evaluated.
The design basis analysis in the. licensees' UFSAR provides for a Type C air j
leakage test consistent with 10 CFR 50, Appendix J. -In addition, the change does not result in any modification to the plant design or system operation, and would continue to provide the appropriate surveillance testing to demonstrate and measure containment leakage rates for the systems with which these valves are associated.
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-S-(3) The proposed change'does not. involve.'a'significant reduction in la margin of safety.
As stated above,-performing a Type C air leakage test rather than the specified Type C hydrostatic
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leakage' test would in fact increase the margin of sofety.
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With respect to valves E11-F0268, E41-F021 and F022, and E51-F001 and F002:
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(1) The proposed change 'does not increase the probability or consequences of an accident previously evaluated. -The licensee-proposes to perform a Type C hydrostatic leakageitest rather than a Type C-air. leakage : test currently specified by the Plant' TSs. The' 1
Commission's regulations in 10 CFR 50, Appendix J,." Primary Reactor j
Containment Leakage Testing'for Water-Cooled Power Reactors," allow either a Type C hydrostatic leakage test or-a Type C air leakage. test-for valves that maintain a 30-day water seal after an accident requiring containmentcisolation.
By. performing a Type C hydrostatic.
leakage test'on these valves, the' licensee will be performing a test consistent with 10 CFR 50, Appendix J, requirements and the analysis y
detailed in the Fermi-2 UFSAR.'
(2) The proposed change does not create a new or'different kind of
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accident from any accident previously evaluated.
The analysis.
J detailed in the licensee's UFSAk provides for'a Type'C hydro-static test consistent with 10 CFR 50, Appendix J.
In' addition, L
the change does not result'in any modification to the' plant design or system operation.
(3) The proposed change does.not involve.a significant reduction in a margin of safety as stated.above.
Performing a Type C hydro-static leakage test provides appropriate testing to demonstrate and measure containment leakage rates.
The proposed change to delete the application of. Footnote (r) to valves T48-F016A' and B, thereby denoting a Type C air leakage test; the change to Footnote (c) to valve G33-F001; and.the change to correct. the. identification of valve E11-F0268, do not increase the probability or consequences of an ' accident previously evaluated, create a new or different kind of. accident from any accident previously evaluated or involve a significant reduction in a margin of safety.
These changes are administrative in nature to, confirm leak. testing consistent with the analysis detailed in the Fermi-2 UFSAR, and are considered not to involve a significant hazards consideration.
As such, they meet Example X
(i) of amendments that are considered not likely to involve significant' hazards-considerations (51'FR 7751).
In addition, the changes do not result in any modification to the plant or system operation.
Therefore, based on these considerations and the three criteria given above, the Commission'has made a final determination'that the amendment-request involves no significant hazards consideration.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, efforts were made to contact
.the Michigan representative.
The state representative was contacted and had no comments.
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6.0 ENVIRONMENTAL CONSIDERATION
This amendment involves changes-to requirements with respect to the.installa-tion or use of facility. components located within the restricted area as defined in 10 CFR Part 20.
We have determined that the amendment involves no signifi-cant 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 made a final no significant hazards consideration finding with respect to this' amendment.
Accordingly, this amendment meets the eligibility criteria for cate-gorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement nor environmental assessment need be prepared in connection with the issuance of this amendment.
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- 7. 0 CONCLUSION
'I We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be l
endangered by operation in the propcsed manner,=and (2) such activities will be conducted in compliance with' the Commission's regulations, and the issuance of this amendment will not be inimical to:the common defense and security or to the health and safety of the public.
Principal Contributor:
John J. Stefano, NRR i
Oated:
October 9, 1987 i
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