NRC-87-0209, Application for Amend to License NPF-43,adding Two Primary Containment Isolation Valves to Tech Spec 3/4.6.3.Fee Paid

Application for Amend to License NPF-43,adding Two Primary Containment Isolation Valves to Tech Spec 3/4.6.3.Fee Paid

ML20236D074
Person / Time
Site:	Fermi
Issue date:	10/22/1987
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236D075	List: ML20236D083 NRC-87-0209, Application for Amend to License NPF-43,adding Two Primary Containment Isolation Valves to Tech Spec 3/4.6.3.Fee Paid
References
CON-NRC-87-0209, CON-NRC-87-209 NUDOCS 8710280011
Download: ML20236D074 (10)

Text

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Nuclear Operations Detroit r.,.

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Edison EEEFm em M A D Q N @% !

October 22, 1987 j NIC-87-0209 1 l

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U. S. Ibclear Regulatory Commission  !

Attn: Document Control Desk l Washington, D. C. 20555 {

Reference:

Fermi 2 {

NIC Docket No. 50-341 NIC License No. NPF-43 1

Proposed Technical Specification

Subject:

(License Amendment) Change - Primary Containment ,

laqlation Valves (3/4.6.3) 4 Pursuant to 10CFR50.90, Detroit R1ison Company hereby proposes to i amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed change into Technical Specification 3/4.6.3 - Primary Containment Isolation Valves.

The proposed change adds two valves to Table 3.6.3-1 in valve group 13. These valves were incorporated into the plant design during the time period in which the Fermi 2 Technical Specifications were being developed prior to issuance of the Fermi 2 Operating License.

However, the design change was not incorporatal into the Technical Specifications.

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Detroit Edison has evaluated the proposed Technical Specification I change against the criteria of 10CFR50.92 and has determined that no significant hazards consideration is involved.

The Fermi 2 Onsite Review Organization has approved and the Ibclear Safety Review Group has reviewed the proposed Technical Specification change and concurs with the enclosed determinations.

Pursuant to 10CFR170.12(c) , enclosed with this amerdment 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. Additionally, the Regional Administrator of Region III and the Senior Resident Inspector have been provided copies of this application. Your pronpt attention to this application is appreciated.

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If you have any questions, please contact Mr. Glen Ohlemacher at (313)

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' Sincerely,- ,

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Enclosures i s...,,

R cc t . A'. B. Davis E. G. Greenman W. G.. Rogers J. J. Stefano .

Supervisor, Advanced Planning and Review Section Michigan Public. Service Commission l

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.l PageT3 l I, WILLIAM S. ORSER, 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.

I WILLIAM S. ORSER Vice President' Nuclear. Operations -

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On this MMd day of *) , 1987, before me personally appeared William's. Orser, being l first duly sworn and says that he' executed the foregoing L as his free act and deed. 'l 1

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Notary Public ,

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Enclosure to.

NRC-87-0209 .

-Page 1-EKIOSURE I. BACKGROUtDAISCUSSION ,

The proposed change adds two primary containment isolation valves, T50-F450 and T50-F451, to 'Nchnical Specification Table 3.6.3-1.

These valves provide automatic isolation on a High Drywell Pressure e signal to the Primary Contain it Radiation Monitor- (PCFM) of the Primary Containment Atmosphere Monitoring System (PCAMS) (see attached j

' figure).

The PCRM -is a skid-nounted unit which is used as a means of detecting reactor coolant' leakage in Primary Containment during normal operation. The PCBM is installed in parallel with the Division I  !

containment Hydrogen / Oxygen Monitoring Subsystem of PCAMS. The unit I was purchased to meet all quality and seismic requirements; however, in January 1984 it was determined that the PCPM could not meet the l appropriate requirements.- As a result, the PCRM subsystem was  ;

functionally downgraded and Mditional valves were Mded. These valves, T50-F450 and F451, were inteMed to isolate the post-accident .  !

essential instrumentation (Oxygen / Hydrogen monitoring) from the nonessential PCPM instrumentation. The Oxygen / Hydrogen analyzer aM PCBM share penetrations X-48 a-e. This design provides capability, via switch selectable position, to sample from five containment zones. Manual valves T50-F063 and T50-F064 were also Mded at this j time.  !

The original design was a justified exemption to General Design criteria (GDC) 56 containment isolation requirements using a single isolation valve and closed system outside the containment. The use of a single isolation valve was based on: (Reference Note 12 of UFSAR Table 6.2.2) l i

a. The line is in an ESF or ESF-relatM system. l

b. System reliability is greater with one isolation valve.

c. The system is a closed system outside the containment. fi

d. A single active failure can be accommodated with one l isolation valve in the line. l l

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Enclosure to  !

tmC-87-0209  !

Page 2

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-e. The specific closed system requirements met by this system j outside the containment include missile protmtion, Category i I, and Quality Group B design standards.

f. For instrumentation piping, the system is designed ard installed as Quality Group B, up to ard including the isolation valves. The balance of the instrument piping is designed to meet Quality Group a design criteria. These design criteria include stress analysis with consideration given to dead-weight, thermal, and seismic conditions. The system is seismically supported. Nuclear grade material is ,

used throughout the fabrication of the piping system.

g. The design temperature and pressure ratings of the systems

, are greater than those of the containment.

Subsequent to determining that the PCR4 nust be downgraded, valves T50-F450 and F451 were added to provide automatic isolation on high drywell pressure. The system configuration for the oxygen / Hydrogen monitor remains in conpliance with the closed system criteria. The l remote manual isolation valves for the oxygen / Hydrogen system provide the redundant means of effecting the isolation of the PCR4. For a design basis event the PCR4 skid would be automatically isolated by valves T50-F450 ard F451. For a postulated single failure of these valves to isolate, the PCR4 would be unable to contain the containment pressure and result in a 3/4 inch diameter leak into Secordary Containment. Such a failure is identical to any other postulated single failure in the closed system and bourded by the Steam Line Break Outside Containment Transient detailed in UFSAR Section 15.6.4.

If the automatic isolation valves did not isolate, operator action would be required to verify isolation ne ig control room indication  !

and initiate closure of the valves. Suf dicient secondary irdication is available for operator action to mitigate the leakage by shutting -

remote manual isolation valves T50-F401A, F402A, F403A, F404A, F405A, I F407A and F408A. This action is the same as for any other postulated j single failure within the closed system. ]

For the reasons stated above, Detroit Edison believes the system as presently designed has functionally equivalent containment isolation capability as the previous design and is, therefore, an meeptable design.

The design change, which was conpletcd in early 1984, should have been incorporated into the Final Safety Analysis Report (FSAR) in Table 6.2.2, " Summary of Primary Containment Penetrations and Assoc 'tcd Isolation Valves," to show valves T50-F450 and T50-F451 as iso.:_ation valves associated with containment penetrations X-48 a-e and X-215.

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Enclosure to

' NIC-87-0209 Page 3.

, As solenoid operated spring-to-close valves, the concept of a maxinum

' isolation time requirement is not applicable to these valves. This is consistent with similar style valves currently listed in Table 3.6.3-1. These valves fail to the closed position ard remote position indication is provided in the Main Control Room.

The plant Technical Specifications for primary containment isolation valves were developed primarily on the basis of FSAR Table 6.2.2.

Reviews were made to ensure the adequacy of these docunents, however, this design change was not' properly reviewed or noted and the valves were omitted from the Technical Specifications. This proposed I amendment corrects this oversight. 1 SIGNIFICANT IRZAIDS CatEIDERATION In accordance with 1CCFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards . J 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.

1) The proposed change to add valves T50-F450 and T50-F451 to <

Table 3.6.3-1 does not involve a significant increase in the i probability or consequences of an accident previously j evaluated. The application of Technical Specification j surveillance, testing and action requirements to these valves  !

ensures that the probability or consequences of evaluated i accidents is not increased. ,

2) The proposed change does not create the possibility of a new or different kind of accident previously evaluated. 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 I previously evaluated.

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3) The proposed change does not involve a significant reduction in j a margin of safety as detailed in 1) and 2) above. Application j of the Technical Specification requirements to these valves  !

ensures the margin of safety is in fact maintained.

In summary, the proposed amerdment corrects the oversight in not I including these two valves in Technical Specifications and, as such, ensures required surveillance and testing takes plcre on these i

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t Enclosure t'o NIC-87-02091 Page"4- 'h

. valves. .Thereforehthe amerdent involves pofsignificant hazards considerations. '

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CONCwSION O Based on the evaluations above: -(l) there is reasonable assurance 1  !

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 Canmission's regulations and the  !

proposed amendment will not be inimical toJhe comnon defense and securityortothehealthandsafety'ofthpbublic.

II. REVISED THCHNICAL SPECIFICATIONS

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The requested revision is attached. L III. INIERIM (XMPfNSMORf MEASURES 4

The PCIN was removed $ rom service for maintenance on (

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Q:tober 16,1987_using valves T50-F450 and T50-F451 for isolation from the primary containment atmosphere. Fermi 2 was operating at approximately 50% reactor power. In revhwing a work request on October 17, 1987, operations personnel properly questioned the use of these valves to maintain primary containment integrity as they were. ,

not indicatedito be primary containment. isolation valves in any I available documentation. The resulting investigation revealed the i situation described in Section I above. Valves T50-F450 and T50-F451 j were subsequently leak rate tested with satisfw tory results. In the e ( I interim, valves T50-F450, T50-F451, T50-F063 and T50-F064 have been i !r j maintained in the closed position pending resolution of this matter y and Operations is followingjthe action prescribed in Specification '

i 3.4.3.1 for an inoperable Ieakage Detection System.

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i Valves T50-F450 and T50-F451 will be a3ded to the Containment Leak Rate Testing Program required by Apperdix4 of 10CFR50. The '

appropriate surveillance procedures which  !

coter the testing of the ,

mtuation instrumentation for these valves wh1 be revised to test tice. '  ;

I actuation of these valves. The Inservice Testing Program for Punps and Valves required by Section XI of the ASME Boiler and Pressure '

Vessel Code and Specification 4.0.5 will be modified to include these J valves. , {

, l Upon the satisfmtory conpletion of the above changes and the ]

satisfactory conpletion of the subsequentiequized testing, valves 1 T50-F450, T50-F451, T50-F063, ard T50-F064 will be opened and the PCR4 ,

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4 the period.this amend e nt' request is.being c;

1 processed'1all requirements inposed by the above programs will be-

"' - ;inplemnts1.in a manner' identical to that which would be required if -

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.IV."waractesNML DEPRCT y7 Detroit Bilson has reviewed the proposed Technical Specification:.

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changes against the criteria of 10CFRSl.22 for environmental.

> 4Q', , l considerations.,. As shown above, the proposed changes do not involve a i(!.b significant hazards consideration,.nor increasepthe types and an.ounts of-effluents that may be released offsite, nor significantlindividual Based onor cunulative oc

? the foregoing, Detroit Edison concludes that the proposed Technical

/ Specifications do meet the criteria given in 10CFR51.22(c) (9) for a -

TS categorical exclusion from the requirements for an Environmental I Inpact Statement. g-t s

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