NRC-89-0043, Application for Amend to License NPF-43,revising Tech Spec 3/4.6.3.1 to Delete Traversing in-core Probe Primary Containment Isolation Valve Since Penetration Will Be Sealed Closed Per Design Change

Application for Amend to License NPF-43,revising Tech Spec 3/4.6.3.1 to Delete Traversing in-core Probe Primary Containment Isolation Valve Since Penetration Will Be Sealed Closed Per Design Change

ML20236E277
Person / Time
Site:	Fermi
Issue date:	03/10/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236E279	List: ML20236E281 NRC-89-0043, Application for Amend to License NPF-43,revising Tech Spec 3/4.6.3.1 to Delete Traversing in-core Probe Primary Containment Isolation Valve Since Penetration Will Be Sealed Closed Per Design Change
References
CON-NRC-89-0043, CON-NRC-89-43 NUDOCS 8903240048
Download: ML20236E277 (6)

Text

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s' E. 8. RIlph Sylvb ^

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.,< f* ' Senior Vice President

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! 6400 Norin odie Hignaay EEdison1tr=- . j j

q March 10, 1989- j tmC-89-0043 1 1

U. S. tbclear Regulatory Commission Attn: ' . Document Control Desk 1 Washington, D. C. 20555

References:

'l) Fermi 2 NFC License No. 50-341 IEC Docket No. NPF-43

2) Detroit Edison Let to NIC, VP-85-0237, dated December 31, 1985 3

3) tEC Letter to Detroit Edison, " Issuance of and Exemption to General Design Criterion 56 of Appendix A to 10CFR Part 50", dated July 31, 1986

Subject:

Proposed Technical Specification Change (License Amendmnt) - Primary Containment Isolation Valves (3/4.6.3.1)

Pursuant to 10CFR50.90, Detroit Falson Conpany hereby proposes to amend Ooerating License NPF-43 for ' the Fermi 2 plant by incorporating the enclosed changes to Technical Specification 3/4.6.3.1. The proposed change deletes the Traversing Incore Probe (TIP) Primary Containment Isolation Valve, C51-F008 "TIP Purge System Isolation valve", listed in Technical Specification Table 3.6.3-1 (Item D.22) .  ;

This valve is located outside of primary containment and serves to .j isolate Penetration X-35G. Penetration X-35G is the primary containment penetration for the TIP Nitrogen Purge line. The nitrogen line from the TIP Purge Panel, located in the Peactor Building, passes through this penetration to the TIP Indexing Mechanisms, located inside primary containment, q The purpose of this Technical Specification change is to remove the  !

TIP Purge System Isolation Valve from the Technical Specifications  ;

because the subject penetration will be sealed closed in accordance  ;

with a design change. This design change is scheduled for the first 4 refueling outage. Per Reference 3, penetration X-35G is exempt from  ;

full compliance with General Design Criteria (GEC) 56 until the first ,

scheduled refueling outage. (Reference 2 provides the basis for the f 4

existing design) . In order to resolve our future conpliance concerns

! with GDC 56, our Engineering department has evaluated the design and h0bql ,

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determined Lto relocate the TIP. Purge. Panel inside containment. The

, nitrogen supply to the TIP_ Purge panel will be fed from an existing nitrogen line also located inside containment. Thus, penetration

' X-35G and containment isolation valve C51-F008 will no longer be necessary. Penetration X-35G will be sealed with a qualified. welded cap. and leak tested per 10CFR50 Appendix J during the first refueling outage.

. Please note that in Reference 2, . Detroit Edison committed to revise the isolation design of'the TIP Nitrogen Purge Line .to comply with GDC

56. Our planned design change, as outlined, will , supersede the change described in Reference 2.

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We are requesting -the approval of this proposed amendment be effective -l upon startup from Fermi 2 first refueling outage.

Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review organization' has approved and the Nuclear Safety Review Group has reviewed the proposed Technical Specification change and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

If you have any questions, please contuct Mr. Gordon Nader.at (313) 586-4513.

Sincerely, b

Enclosure cc: A. B. Davis R. C. Knop )

W. G. Bogers ]'

J. F. Stang Supervisor, Advanced Planning and Review Section, Michigan Public Service Commission i

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March 10,1989 .

IEC-89-0043 , j Page 3  ;

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I I, B. RALPH 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. .

afb B. RALPff SYLyfA  !

Senior Vic(President i

j On this /d day of YbCL , 1989, before me personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act and deed.

l l4%lt.o k. . M Notary Public l

flO2Allii A. ARMETTA Notary Pub!!c. Montoo County.Mi l MyCommisc!onExpkosJon.1t1992 l

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. i Enclosure to NIC-89-0043 Page 1 l

BACKGRIRO/b19CUSSION To prevent corrosion of the Traversing In Core Probe (TIP) systen 's steel drive cable and associated Indexing Mechanism, the TIP guidi tubes and indexers are constantly purged with nitrogen. Nitrogen is currently supplied to the TIP Purge Panel, located outside primary containment, by the Plant's nitrogen system. The TIP Purge Panel controls the nitrogen supply to the TIP Indexers located inside primary containment. The nitrogen line between the TIP Purge Panel and Indexers is isolated by containment isolation valve C51-F008 "TIP g Purge System Isolation Valve" and passes through primary containment penetration X-35G. The purpose of this Technical Specification change is to remove this containment isolation valve from Technical Specification Table 3.5.3-1 because the subject penetration will be sealed closed during the first refueling outage; thus, the need for a containment isolation valve is no longer required.

A design change is planned for the 1st Refueling Outage that will relocate the TIP Purge Panel inside containment. The nitrogen supply to this panel will be fed from an existing nitrogen line also located inside containment. Eliminaticit of the existing TIP purge line and  ;

its associated valves and containment penetration is expected to  ;

enhance the overall safety and operation of the plant because: i

1) Active components associated with primary containment isolation of the TIP Purge line have been reduced. This will reduce the probability of release of radioactivity that could be expected from the failure of any active components.

(Active components include the two ball valves, C51-F0ll &

C51-F012, located outside primary containment between containment isolation valve C51-F008 and the primary containment penetration. These valves are QA Level 1 and are powered from, and receive containment isolation signals from 1 the same circuits which power and isolate the balance of the TIP system containment isolation valves. These valves are part of an interim design associated with an exemption from General Design Criterion 56. A more detailed description of j the existing design and its basis is outlined in References 2 and 3) .

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2) The elimination of X-35G penetration containment isolation ]

valves and sealing the penetration with a qualified welded cap will prevent leakage from this potential leakage path.

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3) A reduction in nan-rem exposure is expected because of lower maintenance, inspection and testing requirements of the new design.

Enclosure to T fac-89-0043 l Page 2  !

4) The nitrogen line for the TIP purge (located inside primary )

containment) will be provided with a restrictive orifice. {

This orifice is designed such that a rupture of the TIP purge I line will not degrade the function of other equipment that  !

depend on the main nitrogen feed line located inside primary containment. The design also assures that when the main ]

i nitrogen line is at its minimum design supply pressure, sufficient capacity exists to supply all of the TIP Purge Indexers.

SIGNIFICANT IRZAIDS CONSIDERATION 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 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 Technical Specification 3/4.6.3.1 does not involve a significant increase in the possibility or consequences of an accident previously evaluated. The elimination of the TIP purge line and its associated valves will be expected to reduce the probability of a radioactive release because of the elimination of active components that could fail. Actual radiation leakages are also expected to be less because the integrity of the penetration has been increased. The penetration will be sealed with a qualified welded cap and leak tested to ,

10CFR50 Appendix J. I

2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. Elimination of these valves does not introduce new or different accident initiators. The penetration will be sealed with a qualified welded cap and tested to 1(CFR50 AppeMix J. The nitrogen line for the TIP purge (located inside primary containment) will be provided with a restrictive orifice. This orifice is designed such that a rupture of the TIP purge line will not degrMe the function of other equipment that depend on the main nitrogen feed line located inside primary containment. The design also assures that when the main nitrogen line is at its minimum design supply pressure, sufficient capacity exists to supply all of the TIP Purge Indexers.

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f Enclosure to NPC-89-0043 Page 3 i

3) The proposed change does not involve a significant reduction in a margin of safety because active components which could fail have been reduced, the integrity of a potential leakage path has been increased and a reduction in man-rem is expected because of lower maintenance, inspection and testing requirenunts of the new design. I i

Based on the above, Detroit EJinon has determined that the proposed anendnent does not involve a significant hazards consideration. ,

ENVIIKN1 ENTAL IMP /CT Detroit Edison has reviewed the proposed Technical Specification change against the criteria of 10CFR51.22 for environmental considerations. 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 cumulative occupational ra11ation exposilres. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specification meets the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the require: rents for an Environmental Inpact Statenent.

CDFCLUSION i Based on the evaluation 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) stv::h activities will be conducted in compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.

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