ML20244B104

Application for Amend to License NPF-43,clarifying Tech Specs 3/4.7.1.2, Emergency Equipment Cooling Water Sys, 3/4.7.1.3, Emergency Equipment Svc Water Sys & 3/4.7.1.5, Uhs

ML20244B104
Person / Time
Site:	Fermi
Issue date:	05/31/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20244B106	List: ML20244B104 ML20244B109
References
CON-NRC-89-0042, CON-NRC-89-42 NUDOCS 8906120279
Download: ML20244B104 (11)

Text

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J. Ralph' Sylvia Sernor Vice President 640D North Dixie H#ghway Newport, %chegan 48166 1313) 604 4160 May 31,1989 NIC-89-0042 U. S. Ibclear Regulatory Commission Attn: Document Control Desk Washington, D. C.

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References:

1) Fermi 2 NIC Docket No. 50-341 IGC License No. IFF-43

2) Detroit Edison Letter to NIC, NIC-87-0244,

" Proposed Technical Specification Change (License Amendment) - Emergency Equipment Cooling Water System (3/4.7.1.2), Dergency Equipment Service Water System (3/4.7.1.3), and Ultimate Heat Sink (3/4.7.1.5)", dated March 10, 1988

3) Detroit Edison Letter to IGC, NIC-80-0255,.

" Proposed Technical Specification Change (License AmeMnent) - Ultimate Heat Sink (3/4.7.1.5)", dated September 30, 1988

4) Detroit Edison Letter to NIC, NIC-88-0281,

" Proposed Technical Specification Change (License AmeMment) - Appendix R Alternative Shutdown System", dated December 22, 1988

Subject:

Proposed Technical Specification Change (License Amendnent) - Em2rgency Equip:ent Cooling Water System (3/4.7.1.2), Emergency Equipment Service Water System (3/4.7.1.3), and Ultimate Heat Sink (3/4.7.1.5)

Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to agend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications. In addition, an appropriate change to the bases is proposed. The proposed change provides clarification of the action requirements for an inoperable Emergercy Equipment Cooling Water System subsystem, Dergency Cooling Service Water System subsystem, or Ultimate Heat Sink. This proposal supercedes the Reference 2 proposal in its entirety.

Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant fl 8906120279 890531 ADOCK0500g1 PDR f

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hazards consideration' n is involved. The Fermi 2 Chs'ite Review Organization has approved and the Nuclear Safety Review Group has reviewed the proposed Technical Specifications 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 further questions, please contact'Mr. Glen Ohlemacher at (313) 586-4275.

Sincerely, b

Enclosure cc:.A. B. Davis

.R. C. Knop W. G. Rogers J. F. Ctang Supervisor, Advanced Planning and Review Section Michigan Public Service Camnission-L-

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May: 31c 1989-P NRC-89-0042 '

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1 I, B.' RALPH SYLVIA,"do hereby. affirm that the foregoing statements are-based on facts and circumstances which are true and' accurate to the best of my knowledge and belief.

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'B. PAuWSrLvy

. Senior Vice President'-

On this 3 day of Y

1989, before me personally appeared B. Ralph Sylvia, tWing first duly sworn and says that he' executed the. foregoing as his free act and deed. -

4% 0. 0W Notary Public ROSAUE A ARMETTA Notary Pubile, Monroe County.14 MyCommissionExpiresJan.11,1992 l

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Enc 1 cura ta NRC-89-0042 Page 1 INTRODUCTION The Limiting Conditions for Operation for Technical Specifications 3/4.7.1.2 - Emergency Equipment Cooling Water System (EECW),

3/4.7 1 3 - Emergency Equipment Service Water System (EESW) and 3/4.7.1.5 - Ultimate Heat Sink currently provides ACTION requirements that are ambiguous in regard to when associated safety-related equipment is declared inoperable. The proposed change will revise the ACTION requirements for the EECW and EESW systems and Ultimate Heat Sink.

The configuration of safety-related cooling water systems at Fermi 2 is described in UFSAR Sections 9.2.2 and 9.2.5 A RHR reservoir acts as the ultimate heat sink for each division of cooling systems. Each RHR reservoir directly cools that division's RHR Service Water (RHRSW) system subsystem, EESW system subsystem and the service water subsystems for the division's two Emergency Diesel Generators (EDGs).

The EESW system subsystem in turn directly cools the division's EECW system subsystem.

The ACTION requirements for Specifications 3 7.1.2 and 3 7 1 3 and ACTION requirement a. of Specification 3 7 1.5 are written such that the associated safety-related equipment is declared inoperable and the respective ACTION requirements are performed following the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period allowed to return the inoperable cooling subsystem (EECW/EESW subsystem or RHR reservoir) to an OPERABLE status.

Under the current Tecnnical Specifications 3/4.7.1.2, 3/4.7 1 3 and 3/4.7.1.5 declaring the associated safety-related equipment inoperable at the time of the discovery of the division's cooling subsystems being inoperable (one EECW/EESW system subsystem or RHR reservoir inoperable) requires the plant to comply with Specification 3 0 3 because the ACTION requirements in Specification 3 5.1 (ECCS -

Operating) do not include provisions which address the combination of various inoperable Emergency Core Cooling System (ECCS) equipment.

Compliance with Specification 3 0 3 would require an unnecessary plant shutdown witnout regard for the need of a reasonably determined allowable out-of-service time for one inoperable division of cooling subsystems.

In the event of either division of cooling subsystems being inoperable, one Core Spray System subsystem and one Low Pressure Coolant Injection System subsystem becomes inoperable and, for Division II, the High Pressure Coolant Injection system also becomes inoperable due to the lack of emergency cooling to the room in which the systen q uipment is located. Since the EECW/EESW system and the RHR reservoir cooling towers require periodic preventive maintenance to attain the maximum possible availability and reliability, there are

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NRC-89-0042 Page 2 occasions when one division is taken out-of-service and subsequently-declared inoperable.

Detroit Edison believes that neither of the two alternatives detailed above are desirable. Waiting 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to declare inoperable the-supported equipment of an inoperable EECW system subsystem, as stated by the current ACTION statements, is contrary to the intent of the definition of OPERABILITY contained in Specification 1.25.

Inoperabilities of support equipment and' systems are intended to be' promptly evaluated in regards to the impact upon the supported systems and any appropriate ACTION promptly taken. However, for the reasons stated above, this alternative is also not desirable.

Detroit Edison believes that this situation is most closely analogous to that of the Emergency Diesel Generators (EDGs).

In this case, the ACTION requirements allow continued operation with one inoperable.

division for a limited time provided the OPERABILITY of all required system, subsystems, trains, components and devices that depend on the remaining OPERABLE division are verified to be OPERABLE. This proposal provides ACTION requirements for the EECW system similar to those for the EDG's.

The current Technical: Specifications for cooling water systems refer the operator to ACTION requirements entered due to the inoperability of systems directly cooled by the system covered by the Limiting Condition for Operation (LCO). Also, ACTION requirements entered due to inoperability of systems indirectly cooled by the system are referred to. Detroit Edison believes that the operator should evaluate the impact of an inoperable cooling water system in a systematic manner based upon the plant configuration. The inoperable cooling system should be evaluated in terms of what directly cooled components are inoperable, which in turn should be evaluated as to the impact upon the OPERABILITY of components or systems which they support. Detroit Edison proposes to structure the Technical Specifications for these interrelated cooling water systems to support this evaluation process. Therefore, this proposal provides ACTION requirements for inoperable cooling water systems which only include references to ACTIONS for directly cooled components.

EVALUATION The proposed EECW Technical Specification ACTION statements are subdivided into two sections depending upon OPERATIONAL CONDITION.

In OPERATIONAL CONDITION 1, 2 or 3 the requirements are further subdivideo into three subsections.

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n NRC-89-0042 Page 3 First, any ACTION required by Specification 3 4.9 1, Residual Heat Removal - HOT SHUTDOWN, is taken. Since the EECW system provides cooling to the RHR pump motors, it is necessary to direct attention to the immediate ACTIONS which may be required by Specification 3.4.9 1.

Clearly directing the operator to these immediate ACTIONS enhances safety by eliminating.the possibility of interpretation that the current requirements allow this ACTION to be delayed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Second, all required systems, subsystems, trains, components and devices which depend on the remaining OPERABLE EECW system subsystem are verified to be OPERABLE within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The Automatic Depressurization System (ADS) is also verified to be OPERABLE whenever it is required to be OPERABLE. ADS is verified due to its close relationship to the affected ECCS systems.

If this verification cannot be done then the plant is required to be promptly shutdown, except as allowed by the ## footnote which is discussed below.

Finally, if the plant is allowed to continue in operation following the verification required by the second subsection then the third subsection provides for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable EECW system subsystem to OPERABLE status prior to requiring a prompt plant shutdown. The verification required in the second subsection serves to ensure that sufficient equipment is available to safely shutdown the plant during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period assuming that the normal cooling system, the nonsafety-related Reactor Building Closed Cooling Water (RBCCW) System, fails.

As discussed above, the ACTIONS specified in the second and third subsections are patterned after the ACTIONS for the EDGs. Detroit Edison believes the situation of the EDGs is closely analogous to the EECW situation for the following reasons:

1) Both systems provide support to a wide range of safety-related equipment in one division, including ECCS systems.

2) Both systems are a backup to other systems which would normally perform the system's support function. The EDGs backup the normal AC power supply from off-site and is used in the event of the loss of off-site power in that division. EECW is the backup for the RBCCW system. The EECW system provides cooling to essential components whenever failure of RBCCW is indicated by loss of power supply or low system differential pressure (indicative of loss of RBCCW cooling flow).

3) For both systems, if the ACTIONS for the equipment and systems which are supported were to be applied whenever an EDG or EECW

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Encir ure to NRC-89-0042 Page 4 system subsystem is inoperable then the provisions of Specification 3 0 3 would require an immediate plant shutdown.

4) For both systems, periodic equipment outage periods for. purposes such as surveillance testing or preventive maintenance are necessary to attain the maximum possible system availability and reliability. Therefore, there are occasions where one division must be taken out-of-service and made inoperable.

The RBCCW system will normally be available to provide cooling to the components cooled by an EECW system subsystem while the subsystem is inoperable. Most EECW system subsysten outages involve maintenance to the EECW pumps or heat exchangers, which does not affect the RBCCW system's ability to provide cooling._ Further, the RBCCW system has been found to be reliable during plant operation. However, there is a possibility the RBCCW system will be unable or unavailable to supply cooling to the affected components during an EECW system subsystem outage. Detroit Edison considers this acceptable since for the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period sufficient equipment to support a safe plant shutdown cooled by the remaining OPERABLE EECW system subsystem is verified to OPERABLE.

Based on the above, Detroit Edison believes that the ACTION provisions for an inoperable EECW system subsystem in OPERATIONAL CONDITION 1, 2, or 3 should be similar to those for an inoperable division for AC on-site power sources (EDGs). Specification 3/4.8.1.1 ACTIONS b and c allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore a division of on-site AC power source if provisions similar to what are proposed herein for the EECW system are met.

Detroit Edison believes the proposed ACTION requirements for an inoperable EECW system subsystem in OPERATIONAL CONDITION 1, 2 or 3 are acceptable since:

1) The importance of immediately taking any required ACTION for loss of Residual Heat Removal capability in OPERATIONAL CONDITION 3 is explicitly recognized.

2) The provisions are similar to the analogous situation of the EDGs.

3) The proposal provides the safety benefits of increased availability and reliability for the EECW system from preventive maintenance during plant operation.

4) The availability of sufficient equipment to safely shutdown the plant during the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> out-of-service time is verified.

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5) The proposal allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to perform corrective maintenance on an EECW system subsystem. This reduces the number of plant shutdowns when compared to the number which would be required if Specification 3 0 3 were applied. This reduces the number of plant evolutions which challenge the operators, reducing the risk of a plant transient.

The ** footnote provides an exception for Appendix R Alternative Shutdown to the requirement to shutdown the plant if the verification of the equipment supported by the remaining OPERABLE EECW system subsystem cannot be completed because the Drywell Cooling Unit supported by the remaining OPERABLE EECW System subsystem is inoperable.

In this case, the ACTION for the inoperability of both divisions of supported equipment (drywell cooling units) is explicitly provided. This ACTION takes into account the requirements due to the degraded Appendix R Alternative Shutdown capability from loss of both drywell cooling units.

The EECW system is not utilized in any other manner in the Appendix R Alternative Shutdown scenario. Since the required ACTION for Appendix R considerations is already specified and there are no other compounding relationships between the inoperable Drywell Cooling Units and the remaining EECW supported equipment, Detroit Edison believes there is no safety benefit from requiring a plant shutdown in this case.

The provisions of the ** footnote are contingent upon the approval of the Reference 4 proposal.

If the Reference 4 proposal is not incorporated into the Technical Specifications at the time of approval of this proposal then the ** footnote should be incorporated when the Reference 4 proposal is approved.

In OPERATIONAL CONDITIONS 4 or 5, no consideration need be given to continuing plant operation. Therefore, the proposal requires the safety-related equipment associated with an inoperable EECW system subsystem be declared inoperable and the appropriate ACTION taken per the applicable specifications. Detroit Edison believes this is l

acceptable since it appropriately applies the intent of the definition of OPERABILITY (Specification 1.25).

Specifications 3 7 1 3 and 3.7.1.5 have been restructured such that these Specifications, which cover the EESW system and Ultimate Heat Sink respectively, no longer refer in their ACTION requirements to equipment or systems which are not directly supported by the system covered by the Specification. This restructuring of the ACTIONS alone does not change the requirements from the current Technical Specification requirements. The inoperability of an EESW system

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Page 6 subsystem or the Ultimate Heat Sink will still require the appropriate ACTION for the inoperability of the affected supported systems. The proposed structure supports a more systematic evaluation of the impact of the inoperability of these systems.

In this way, the proposal provides a safety enhancement while still applying the requirements for the affected supported systems.

In Reference 3, Detroit Edison proposed modifications to Specification 3 7 1.5 which in part apply this systematic structure to that Specification. Therefore, if approval of the Reference 3 proposal precedes approval of this proposal, the changes proposed herein for Specification 3 7.1.5 will not be necessary.

SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50 92, Detroit Edison has made a determination that the proposed amendment ir.volves no significant hazards considerations. To make this determination, Detroit Edison has established 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.

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The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change to the EECW/EESW system and Ultimate Heat Sink ACTION requirements do not create any new initiating mechanisms or affect any postulated initiating mechanisms for evaluated accidents. The proposed change ensures that sufficient safety-related equipment will be maintained and will be available to initiate safe shutdown of the plant during the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed out-of-service time.

In fact, the consequences of an accident may be decreased by implementing compensatory actions at the time of discovery of an inoperable EECW system subsystem rather than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following the discovery as currently stated in the Technical Specifications. The proposed change also promotes safe plant operation by giving a i

I reasonable out-of-service time for corrective and preventive maintenance on the EECW/EESW and Ultimate Heat Sink systems without requiring unnecessary reactor shutdowns.

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The proposed changes do not create the possibility of e.

new or different kind of accident from any accident previously evaluated. The proposed changes to the EECW/EESW system and Ultimate Heat Sink. ACTION requirements do not result in any modifica;,1ons to the plant design or manner of system operation and no safety-related equipment or function will-be altered.. As stated in (1) above, sufficient' equipment will be maintained and will be available to. initiate safe shutdown of the plant during-the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed out-of-service time. -The requested changes do not create any new accident mode.

3 The proposed changes do not involve a significant reduction in a margin of' safety. The proposed changes to the EECW system ACTION requirements may in fact increase the margin of safety as compensatory action will be implemented at the time that the EECW system subsystem is.

discovered inoperable rather than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following the discovery.

The restructuring to reference ACTION requirements for only directly cooled components in the ACTION statements for an inoperable cooling water. system is an administrative change made to promote consistency in the Technical Specifications and thus falls under example (i) of Examples Of Amendments Not Likely To Involve Significant Hazards Considerations listed in 51 FR 7751.

Due to its administrative nature, the change does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Involve a significant reduction in a margin of safety.

Based on the above, Detroit' Edison has determined that the proposed amendment does not involve a significant hazards consideration.

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor significantly change the types or I

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significantly increase the 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 Impact Statement.

CONCLUSION 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 compliance with the Commission's regulations and the proposed amendment will.not be inimical to the common defense and security or to the health and safety of the public.

In' summary, the proposed amendment clarifies the compensatory actions that should be taken'in the event of an inoperable EECW/EESW system subsystem or RHR reservoir. The amendment also promotes safe plant operation by giving a reasonable out-of-service time for'the EECW/EESW system and. Ultimate Heat Sink without requiring unnecessary' reactor shutdowns. line structure of the related Technical Specifications is also modified to support consistent operator usage.

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