NRC-87-0211, Requests Temporary Exemption from Requirements of 10CFR50, App a Criterian 56 (GDC 56).Util Intends to Return Primary Containment Radiation Monitor to Svc Utilizing Current Isolation Design While 871022 Tech Spec Change Under Review

Requests Temporary Exemption from Requirements of 10CFR50, App a Criterian 56 (GDC 56).Util Intends to Return Primary Containment Radiation Monitor to Svc Utilizing Current Isolation Design While 871022 Tech Spec Change Under Review

ML20236F949
Person / Time
Site:	Fermi
Issue date:	10/27/1987
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-87-0211, CON-NRC-87-211 NUDOCS 8711020349
Download: ML20236F949 (7)

Text

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D. Ralph SyMo Oroup Vice President Detrot 641)0 North Dixie Highwa Ecison =r y

October 27, 1987 NIC-87-0211 l

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

References:

1) Fermi 2

!EC Docket No. 50-341 IHC I icense No. NPF-43

2) Detroit B3ison letter 1HC-87-0209, " Proposed Technical Specification (License Amendnent) Change - Primary Containment Isolation Valves (3/4.6.3)," dated October 22, 1987

Subject:

Request for Temporary Exenption From General Desion Criterion 56 - Primary Containment Tsolation In accordance with 1(CFR50.12(a) (2) (v), Detroit Edison hereby requests a temporary exemption from the requirements of 10CFR50, App. A (V.)

Criterion 56 (GDC 56). Reference 2 requested a Technical Specification change to a3d two existing automatic primary containment isolation valves for the Primary Containment Radiation Monitor (Prm) to Technical Specification Table 3.6.3-1.

This change was due to an oversight in incorporating a design change made prior 'to Operating License issuance into ~ the Technical Specifications. Further review of the isolation scheme for the PCm indicates that the current design should be upgra3ed to meet GDC 56. The following presents the basis for the current system design and justification for tenporary exenption until such tine as modifications can be made to bring the design up to those standards set forth in CDC 56. A description of the design modifications and inplenentation schedule is also included.

Reference 2 indicated that Detroit Edison intended to return the PCM to service utilizing the current isolation design while the requeste3 Technical Specification change was being processed. Such a course of action has not taken plcre and will only occur if the temporary exenption requested herein is granted.

Nk O&Q 050 B71027 P

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UStHC October 27, 1987 NFC-87-0211 Page 2 BACKGROUf0/bIfrUSSTON The PCM was removed from service for maintenance on October 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 reviewing 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 indicated to be primary containment isolation valves in any available documentation.

i The ICM (H21-P284 on the attached figure) is configured in a parallel arrangement with the Drywell Hydrogen / Oxygen Sanple Panel (H21-P282).

Both systems normally operate continuously during remtor operation and sanple the Drywell atmosphere from five zones through Primary j

Containment penetrations X-48 a through e.

Each of these five penetrations has an associated local manual valve (T50-F033A, F034A, F035A, F036A and F037A) and air operated remote manual isolation valve (T50-F401A, F402A, F403A, F404A and F405A). Torus atmosphere sanpling capability is provided by a similar arrangement through a single tap at containment penetration X-230. Connections are provided at valves T50-F047A and T50-F071A for penetration leak rate testing. The sample flow returns to the torus atnosphere through penetration X-215 which is provided with an air operata3 remote manual isolation valve (T50-F408A) and a locc". manual valve (T50-F050A).

The initial isolation design for the PCM and Drywell Hydrogen / Oxygen Sanpling Systems was a justified alternative to GDC 56 described in UFSAR Section 6.2.4.

Containment isolation requirements were achieved using a single isolation valve and a closed system outside the containment. The use of a single remote manual isolation valve was based on:

(Reference Note 12 of UFSAR Table 6.2.2 and UFSAR Section 6.2.4.2.2.3.2.)

a. The line is in an ESF or ESF-relata3 system.

b. System reliability is greater with one isolation valve.

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

d. A single active failure can be mcommodated with one isolation valve in the line,

e. The specific closed system requirements met by this system outside the containment include missile protection, Category 1, arri Quality Group B design standards.

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e UStHC October 27, 1987 tHC-87-0211 Page 3

f. For instrumentation piping, t he system is designed ard installed as Quality Group B, up to and. including the isolation valves. The balance of the instrument piping is designcd to meet Quality Group B design criteria. These design criteria include stress analysis with consideration given to dead-weight, thermal, and seismic corditions. 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.

The original design intent was that the PCR4 would operate following a Loss-of-Coolant-Accident (LOCA) and that the PCai would be in conpliance with the closed system requirements included in the alternative to GDC 56.

In January 1984, it was determined that the PCai did not conply with the specific closed-system requirements detailed above. Specifically,

-in order to meet a containment design pressure of 56 psig, the closure of the vendor-provided skid-mounted motor operated valves T50-F040 and F046 was required. These valves automatically close when a pressure signal sensed immediately inboard of the valves reaches two psig.

Further problems were noted in the seismic and material certifications provided by the vendor. Two actions were taken as a result of the January 1984 determination:

a. It was determined that the PCMi was non-essential following a LCCA and as such should be automatically isolated upon a LOCA signal. The Hydrogen / Oxygen sampling system retained its essential classification.

b. Two solenoid-operated automatic isolation valves (T50-F450 and F451) and two local manual valves (T50-F063 and F064) wre added to the branch lines to the PCMi.

The automatic isolation valves were a3ded to provide the isolation of the now non-essential PCR4. The addition of these valves was also intended to return the system configuration to that of a closed system and as such it was determined that the alternative to GDC 56 detailed above still applied.

The new automatic isolation valves added in 1984 receive a closure signal on the Drywell Pressure - High signal from the Reactor Protection System (RPS) A ard B trip systems. A diverse signal (such as Reactor Water Level) was not included as it was reasoned that this would result in an unacceptable degradation in availability of the l

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' USNIC '

October 27, 1987' NIC-87-0211 '

Page 4.

PCIN. Further, a lowering reactor water level did not pose a direct l'

~ hreat' to the PCIN's integrity and, under such corditions, operation

]

t of the PCIN was considered beneficial in determining reactor coolant-i

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leakage.

-The configuration which resulted provides two barriers in the event' of a LOCA and failure of the PCIN boundary. One barrierJis the automatic isolation valves,; T50-F450 and F451, and the second barrier is-provided by the remote manual isolation valves, T50-F401A, F402A, F403A, F404A, F405A,' F407A and F408A.- This configuration was found to

- be. acceptable to Detroit Eison; however, formal NIC review of the -

configuration cannot be verified. The use of a remote manual isolation valve as a barrier. In the case of a non-essential system is not an approved alternative to the GDC 56 requirements and tims the existing isolation design for the PCIN must be upgraded to an approved

-standard.

PIAIE TO DEGRDE DESIGN Detroit Mison will provide a primary containment isolation design for the PCIN to meet the requirements of GDC 56. This design will provide two barriers each consisting of two automatic isolation valves which' will receive isolation signals from diverse sources.

i Due to the scope of_ this modification and the lead time involved in the design and procurement activities required, conpliance with CDC 56-will' be achieved during the outage scheduled for Local. Leak Rate Testing scheduled 'in March 1988. The new design includes seismic support calculations, power and control cabling and Control Room human factors considerations. Therefore, Detroit Edison proposes to install the new PCIN isolation design prior to restart from the March 1988

)

outage.

JUSTIFICATION POR INIERIM EXEB@ TION j

Valves T50-F450 and T50-F451 have been subsequently leak rate tested

-with satisfactory results. In the interim, valves T50-F450, T50-F451, j

T50-F063 and T50-F064 have been maintained in the closed position i

pending resolution of this matter. Detroit Idison requests a tenporary exenption to GDC 56 until such time as design changes can be implemented to bring the design 'into conpliance.

10CPR50.12 allows the granting of a specific exenption under special circumstances if the exenption does not present an undue risk to the public health and safety and is consistent with the conmon defense and security.

USNIC October 27, 1987 15C-87-0211 Page 5 10CFR50.12(a) (2)(v) states that special circumstances exist when the exemption provides only temporary relief and a goos faith effort has been made to conply with the requirements.

The situation in question arises from a good. faith effort to meet the requirements of GDC 56 following a design change made in January 1984.

Subsequent review indicates that these requirements were misinterpreted at that time. This review was initiatal in a tinely fashion and the time period requested for exenption is considered by Detroit Elison to be a reasonable period to install an isolation design which meets all requirements while minimizing the duration of the exenption.

As described above, the existing design has one set of automatic containment isolation valves (T50-F450 and F451) and one set of renote manual containment isolation valves (T50-F401A, F402A, F403A, F404A, F405A, F407A, and F408A) which requires operator action to close. Any failure of the first barrier (T50-F450 and F451) would be indicated by 1mk of a closed ' indication for these valves in the Control Room. At that time, the Control Room operator would attempt to close these valves by actuating them from the Control Room and, if unsuccessful, could effect isolation of the penetration with the set of remote manual isolation valves. This would isolate the Division I Orywell Hydrogen / Oxygen sampling system, however, this function would be fulfilled by the redundant Division II system. Area Radiation Monitors would indicate if the containment penetration were to remain unisolated, in which case, operator action would be taken to shut the local manual valves associated with the penetrations.

Prior to placing valves T50-F450 and F451 in service fcuowing approval of this exenption request, the In-service Testing' Program, which inplenents the requirements of Appendix J of 10CFR50 and Section XI of the ASME Boiler and Pressure Vessel Code will be revised.

Surveillance proced'ures which inplement these requirements and the testing requirements associated with the addition of these valves to the Technical Specifications have been revised. Leak, rate tests for these valves were satisfmtorily conpletal on October 19, 1987. Valve T50-F450 leakage measured 0.32 SCFH and T50-F451 leakage measured 0.05 SCPH. This is less than the maxinum acceptable leakage of 1.00 SCFH.

Detroit Edison will also, as committed to in Reference 2, complete all required testing prior to returning these valves to service and treat the valves in a manner identical to which they would be treated if they were included in Technical Specifications.

h

USNIC October 27, 1987 NIC-87-0211 Page 6 COtCWSION Detroit Riison believes that this temporary exenption request meets the requirements of 10CFR50.12 and for the reasons stated above, does not present an undue risk to the public health and safety and is consistent with the connon defense and security.

g L

While this matter is being resolved valves T50-F450 and F451 have been l

maintained in the closed position. Operations has thus been following the action prescribed in Specification 3.4.3.1 for an inoperable Leakage Detection System. This action statement will expire on Novenber 15, 1987, following which, a plant shutdown will be required if this exemption is not granted.

{#

Your pronpt attention to this matter is appreciate 3.

If you have further questions, please contact Mr. Glen Ohlemacher at (313) 586-4275.

Sincerely, Attachment cc:

A. B. Davis E. G. Greenman W. G. Rogers J. J. Stefano

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