NRC-87-0244, Application for Amend to License NPF-43,clarifying Action Requirements for Inoperable Emergency Cooling Water Sys Subsys,Emergency Cooling Svc Water Sys Subsys or Uhs.Fee Paid

Application for Amend to License NPF-43,clarifying Action Requirements for Inoperable Emergency Cooling Water Sys Subsys,Emergency Cooling Svc Water Sys Subsys or Uhs.Fee Paid

ML20196J966
Person / Time
Site:	Fermi
Issue date:	03/10/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196J969	List: ML20196J983 NRC-87-0244, Application for Amend to License NPF-43,clarifying Action Requirements for Inoperable Emergency Cooling Water Sys Subsys,Emergency Cooling Svc Water Sys Subsys or Uhs.Fee Paid
References
CON-NRC-87-0244, CON-NRC-87-244 NUDOCS 8803150117
Download: ML20196J966 (9)

Text

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• 8. Ralph Sylvb

,3 Group Vice Presedent Detroit Ecison EDI5=

March 10, 1988 NIC-87-0244 U. S. melear Regulatory Comission Attn: Docunent Control Desk Washington, D. C. 20555

Reference:

Fermi 2 NEC Docket No. 50-341 NIC License No. IPF-43

Subject:

Proposed 'I4chnical Specification Change (Licente Amendment) - Dergency Equipment Cooling Water System (3/4.7.1.2) , Emergency Equipnent Service Water System (3/4.7.1.3) and Ultimate Heat Sink

( 3/4. 7.1. 5)

Pursuant to 10CFR50.90, Detroit Mison Conpany hereby proposes to anend Operating License tPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications. In 5 codition, an appropriate change to the bases is proposed. The proposed change provides clarification of the action requirements for an inoperable Dergency Equipment Cooling Water System subsystem, Dergency cooling Service Water System subsystem, or Ultimate Heat Sink.

Detroit Mison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hasards consideration is involved. The Fermi 2 Chsite Review organization has approved and the melear Safety Review Group has reviewed the proposed Technical specifications and concurs with the enclosed determinations.

Pursuant to 10CFR170.12(c), enclosed with this amerdment request is a check for one hundred fifty dollars ($150.00) . In accordance with .

10CFR50.91, Detroit Mison has provided a copy of this letter to the l State of Michigan. .  !

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8803150117 880310 PDR i

P ADOCK 05000341 l DCD i h

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March 10,1988 t NIC-87-0244 Page 2 i r

If you have any cpestions, please contact Mr. Glen D. Ohlemacher at I (313) 586-4275.

i Sincerely,  !

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-[ i e Enclosure j oct A. B. Davis 1 E. G. Greenman

T. R. O.iay W. G. Pogers 92pervisor, Advanced Planning and Review Section, Michigan Public Service Comnission - -

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ggrec March 10,1988 NRC-87-0244 Page 3 I, B. IRIPH SYIVIA, do hereby affirm that the foregoing statements are based on facts and circunstances which are true and accurate to the best of my knowledge and belief.

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f. IW3&H % IA Group Vice President On this lO 1 day of W1 aA* _

, 1988, before me personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act and deed.

%s O .b Notary Public KAREN M. REED Netary Putlie, Mor:ros County, Mi:.t My Ccmmi:sicn Egires Ray 14, ISM I

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Enclosure to hTC-87-0244 Page 1 BACEGBOUt0/DIKUMJON The Limiting CoMitions for Operation for Technical Specification V4 7.1.2 - Energency Equipnent Cooling Water System (EECW),

3/e.iJ.3 - Energency Ecpipnent Service Water System (EESN) and 3/4.7.1.5 - Ultimate Heat Sink currently provides ACTION recpirenents that are anbiguous in regard to when associated safety-relatcd equipnent is declared inoperable. The proposed change will clarify the ICTION requirenents of the EICW aM EEE systens aM Ultimate Heat Sink to be consistent with the definition of OPEPABILITY (Specification 1.25) .

The configuration of safety-relat(d cooling water systens at Fermi 2 is described in UPSAR Sections 9.2.2 aM 9.2.5. An Rim reservoir acts as the ultimate heat sink for etch division of cooling systens. Each Mm reservoir directly cools that division's Mm Service Water (MmSW) system subsystem, EESW system subsystem and the service water subsystens for the division's 2 Energency Diesel Generators (EDGs) .

The EESW system subsystem in turn dir(ctly cools the division's EIEW system subsystem.

The ICTION recpirenents for fpecifications 3.7.1.2 aM 3.7.1.3 ard ACTION requirenent a. of Specification 3.7.1.5 are written such that the asscciated safety-relatcd equipment is declar(d inopertble aM the respective ACTICN requirenents 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 (EICW/EESW subsystem or Mm reservoir) to an TEPABLE status. Detroit IBison believes, however, that it is prudent and consistent with the definition of TEPABILITY, as applied throughout the Technical Specifications, to declare the asscciatcd safety-relatcd ecpipment inoperable at the tine of discovery of the inoperable cooling subsystem.

UMer the current Technical Specification 3/4.7.1.2, 3/4.7.1.3 ard 3/4.7.1.5 declaring the associated safety-related ecpipnent inoperable at the tine of the dircovery of the division's cooling subsystens being inoperable (one EECW/EESW system subsystem or Mm reservoir inoperable) requires the plant to cocply with Specification 3.0.3 txcause the ACTION requirerents in Specification 3.5.1 do not include provisions which Mdress the conbination of various inopertble DTergency Core Cooling System (EICS) equipnent. Conpliance with Specification 3.0.3 would recpire an unnccessary plant stutdown without regard for the need of a reasonably determined allowable out-of-service tine for one inopertble division of cooling subsystems. In the event of either division of cooling subsystens being inoperable, one Core Spray System subsystem and one Iow Pressure Coolant Injection System subsystem becones inoperable aM, for

l 9 Enclosure to IEC-87-0244 Page 2 Division II, the High Pressure Coolant Injection system also becones inoperable due to the lack of energency cooling to the room in which the system equipnent is located. As the EECW/EESW system and RHR reservoir cooling towers require periodic surveillance testing and preventive maintenance to attain the noxinum possible availability ard reliability, there are nurerous tines when one division is taken out-of-service and subsequently declarcd inoperrble. Detroit Edison believes that when one of a division's cooling subsystens is declared inoperable, the associatcd safety-relatcd equipnent should be declared inoperable. Howver, the ACTION requirenents of the Technical Specification were not interded to place the unit in Specification 3.0.3 in and of itself. Therefore, Detroit Edison proposes to (A) Declare the associatcd safety-relatcd equipnent inoperrble at the tine of discovery of the inoperable EECW system subsystem and restore the inoperable syst m subsystem to an TEPABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. When the associated safety-relatcd equipnent is declarcd inoperable, providing the safety-relatcd system is otherwise TEPABLE, the applicable ICTION statenents of the safety-relatcd equipnent are not required to be taken.

(B) Verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of declaring the EECW system subsystem inoperable that the Autonatic Depressurization System (ADS) is TEPABLE ard that all requircd safety-relatcd equipnent that depend on the remaining TEPABLE EECW system subsystem for cooling is also TEPABLE. The term "verify" as used in this context neans to administrative 1y check by examining logs or other information to determine if certain systems, subsystens, trains, and, r corponents are out-of-service for maintenance or other reasons. It does not rean to perform the surveillance requirenents needed to denonstrate the TEPABILITY of the conponent. Idditionally, to be consistent with Specification 3.5.1, the ADS is not required to be TEPABLE when rezctor steam done pressure is less than or  ;

equal to 150 psig, i The ICTION requirenents for the inoperrble cooling subsystems were not intended to p12ce the unit in Specification 3.0.3 in ard of itself.

However, reliance on safety-relatcd equiprent serviced by a degraded cooling water system is not pernatted. 'Iherefore, Detroit Edison has proposed to inplenent cdditional requirenents to declare the affectcd  !

safety-related equipnent inoperable and to verify the requircd safety-related equipnent, that deperd on the remaining TEPABLE division of cooling subsystens, TEPABLE. Providing that the  !

safety-relatcd systens are otherwice TEPABLE, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ICTION time '

to restore the inoperable cooling subsystens to TFSABLE status is 1

Ehclosure to NIC-87-0244 Page 3 appropriate and consistent with the results of the hTC sponsored mini-PFA perforned by SAIC in Decenber 1975, which is tre present basis for the allowable out-of-service tines in the existing Standard Technical Specifications.

If during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowable out-of-service tine either Division (including degrMed) of associated safety-relat(d equipnent serviced by the EECW systens becone inoperable for reasons other than the inoperability of the EIEW system, then this safety-relat(d equipnent is declared inoperable and the respective 7CTION statenents entered.

Since no credit can be taken for those safety-related systens serviced by a degraded EECW system subsystem, then this inoperability may be beyond those conditions addressed or permitted by the affectcd safety-related equipnent PCTION statenents, and in those cases the provisions of Specification 3.0.3 shall be invoked.

As an exagle, should Division I EECW becone inoperable, the applicable PCTION statenents are entered and the safety-relattd equipnent serviced by this cooling water system is declared inoperable. If during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowable out-of-service tire it is determined that a Division II safety-related equipnent is inoperable, then the affectcd Division II equipment is declared inoperable. The corresponding Division I equipnent was earlier declared inoperable; howver, 7CTION requirenents for degraded cooling of associated safety-related equipnent was not taken. The applicable PCTION statenents are now entercd for the inoperability of the equipnent with degraded cooling from Division I EECW and the inoperable Division II safety-related egalpnent. Should this result in a cordition not addressed or permitted by the 7CTION statenents, the previsions of Spccification 3.0.3 would be invoked.

Moreover, as a second exanple, should Division I EECW becone inoperable, the applicable cooling water ICTION statenents are cntertd ard the safety-related equipnent serviced by this cooling water system is declartd inoperable. If during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowable cut-of-service tine it is determined that a Division I affected safety-related equipnent is inoperable for remons other than the inoperability of the EECW system subsystem, then the @plicable 7CTION statenents are entertd for the affected Division I equipment. Should this result in a cordition not addressed or permitted by the PCTION statenents, the provisions of Specification 3.0.3 would be invoked.

The current Technical Specifications for cooling water systens refer the operator to TCTION requirenents entercd due to the inoperability of systene directly cooled by the system covered by the Limiting Cordition for Operation. Alse., PCTION requirtsrents enter (d due to inoperability of systens ird!rectly cooled by the system are referred

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9 e e e Enclosure to 10C-87-0244 Page 4 to. Detroit Edison believes that the operator should evaluate the inpact of an inoperable cooling water system in a systematic nmner based upon the plant configuration. The inoperable cooling system should be evaluated in terns of what directly cooled conponents are inoperable, which in turn should be evaluated as to the irpact upon the operability of conponents or systems which they support. Detroit IBison prcposes to structure the Technical Specifications for these interrelated cooling water systens to support this evaluation process. .

Proposed ACTION requirenents for inoperable cooling water systems therefore include only references to ACTIONS for directly cooled conponents.

SI9t4EICBMI.RGN06_C0tEIDERTIGI In accordance with 10TR50.92, Detroit Edison has rade a determination that the proposed amendnent involves no significant hasark considerations. To nake this determination, Detroit Edison has established that operation in accordance with the proposed amendnent 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 '

nargin of safety. ,

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previcusly evaluated . The proposed change to the EICW/EESR system ard Ultimate Heat Sink ACTION requirenents do not create any new initiating mechanisne or affect any postulated initiating nechanisns for evaluated accidents. The proposed change ensures that sufficient safety-related equipment would be

raintained and is available to initiate safe shutdown of the plant. In fact, the consequences of an accident way be

, decreased by inplenenting the conpensatory actions ard declaring the safety-related equipment inoperable at the tire

, 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 'nchnical Specifications. The proposed change also pronotes safe plant operation by giving a reasonable out-of-service tine for surveillance testing and preventive l maintenance on the EECW/EESW and Ultimate Heat Sink systems without requiring unnecessary reactor shutdowns.

2. The proposed changes do not create the possibility of a new

, or different kind of accident from any accident previously evaluated. We proposed changes to the EICW/EESW system ard Ultirate Heat Sink ACTION requirenents do not result in any 1

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Enclosure to hTC-87-0244 Page 5 nodifications to the plant or system operation and no safety-related equipment or function will be altercd. As statcd in (1) above, sufficient equipnent would be maintained and is available to initiate safe shutdown of the plant. The requestcd changes do not create any new rccident utde.

3. The proposed changes do not involve a significant rcduction in a margin of safety. The proposed changes to the EECW system ICTION requirenents may in falt incresce the Irargin of safety as cogasatory actions will he inplenentcd at the tine that the EEEW bystem subsystem is discovercd 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 ICTION requirenents for only dire:tly cooled congonents in the 7CTION statenents for an inopt rable cooling water systcra is an tdministrative change made to pronote cor sistency in the Technical Specifications and t/us falls unde r exanple (1) of Exanples Of Anerdnents Not LLkely To Invo!.ve Significant Hazards Considerations listeJ in 51 FR 7731.

EWIIONUNmL INNT Detroit IBison has reviewd the proposed Technical Specification changes against the criteria of ICCFR51.22 for environnental consideraticos . As shown above, the proposcd changes do not involve a significant hazards consideration, nor significantly change the types or significantly ircrease the amounts of effluents that may be released ofit.ita, nor significantly increase irdjvidual or cunalative occupational ra31ation exposures. Bascd on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do neet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirenents for an Environnmtal Inpact Statenent.

C0tCLUSICH ,

Based on the evaluations above: (1) there is reasonable assurance I that the health and safety of the public will not be endangered by operation in the proposed na tner, ard (2) such retivities will be corducted in conpliance with the consnission's regulations ard the proposcd anerdnent will not be inimical to the connon defense ard l security or to the health and safety of the public.

In sunrnary, the proposcd ancrdnent clarifies ehe conpensatory totions that should be taken in the event of an inoperable EECW/EESW system subsystem or EHR reservoir. The anendnent also pronotes safe plant operatim by giving a reasonable cut-of-service tine for surveillance i testing ard preventive maintenance on the EECW/EPS4 systcen ard l Ultin:ste Heat Sink without requiring unnecessary reactor shutdowns.

The strveture of the relatcd Tcchnical Specifications is also nodificd l to support consistent operator usage. J I

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• e Drlosure to PUC-87-0244 Page 6 PRPOSED PAGE CIR?IiES