NRC-88-0001, Application for Amend to License NPF-43,changing Tech Spec Table 3.4.3.2-2 & Bases 3/4.4.3.2 to Correct Alarm Setpoints for RCS Interface Valve Leakage Pressure Monitors.Processing Per 10CFR50.91 Requested.Related Info Encl.Fee Paid
| ML20234F335 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/06/1988 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20234F337 | List: |
| References | |
| CON-NRC-88-0001, CON-NRC-88-1 NUDOCS 8801110431 | |
| Download: ML20234F335 (8) | |
Text
B. Ralph Sylvia Group vice President Detroit 6
Ec ison =400NorthDuueNghway l
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i January 6, 1988 NIC-88-0001 l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 j
References:
- 1) Fermi 2 NIC Docket No. 50-341 l
NIC License No. NPF-43 i
- 2) Detroit Riison to NFC letter NIC-87-0081, " Response to Notice of Violation and Proposed Civil Penalty," dated 1
June 12,1987
Subject:
Proposed Emergency Technical Specification (License j
Amendment) Change - Reactor Coolant System Leakage (3/4.4.3) j Detroit Edison hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into 7bchnical Specification Table 3.4.3.2-2 pursuant to 10CFR50.90, and also amend Bases 3/4.4.3.2. The proposed change corrects the alarm setpoints for the Reactor Coolant System Interface Valves Leakage Pressure Monitors (LPM). During the engineering validation portion of the Instrument and Controls surveillance procedure upgrale program committed to in l
Reference 2, these alarm setpoints were reviewed for consistency with I
the plant design. This validation determined that the RHR LPCI syste LPM setpoint in Table 3.4.3.2-2 was nonconservatively set too high.
The remaining setpoints of Table 3.4.3.2-2 were reviewed and the PJIR u
Shutdown Cooling System LPM was found similarly set too high When set in accordance with current Ubchnical Specifications, these LPMs 5
may not alarm prior to system relief valve actuation. Thus, proper m
alatn setpoints i.ust be included in Table 3.4.3.2-2 in order for thesc LPMs to be considered operable. Per Specification 3.0.4, plant 56 startup cannot commence with the LPMs inoperable. Fermi 2 is gg currently shutdown and is scheduled to restart on January 6,1988.
Detroit Edison requests that this request be processed urder the O
provisions of 10CFR50.91(a)(5) as an emergency situation in which lack.
gg of timely action would unnecessarily prevent resumption of plant co a.o.
operation.
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USNIC January 6, 1988 NEC-88-0001 '
Page 2 Detroit Riison has evaluated the proposed Technical Specification changes against the criteria of 10CFR50.92 and has determined thht no l
significant hazards consideration is involved;-
The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Deview Group has reviewed the proposed Technical Specification'-
changes and concurs with the enclosed determinations..
Pursuant to 10CFR170.12(c), enclosed with this' amendment is a check -
i for one hundred and fifty dollars ($150.00).. Pursuant to:
l 10CFR50.91(b)(1), the State of Michigan has been notified by a copy of 1
this amendment request.. Mditionally, the Regional Mministrator of Region III ard the Senior Resident Inspector have been provided copies of this application. Your pronpt attention to this application is appreciated.
If you have any questions, please conta:t Mr. Glen Ohlemacher at (313) 586-4275.
Sincerely,.
~
. Enclosure cc: A. B. Davis E. G. Greenman W. G. Rogers J. J. Stefano Supervisor, Mvanced Planning and Review Section Michigan Public Service Conmission I
USNFC January 6, 1988 NIC-88-0001 1
Page 3 i
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I, B. PALPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and scurate to the best of my knowledge and belief.
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$<A L
B. RALPli SYINfA Group Vice President 4
on this b rd day of 1988, before me personally appeared B. Ralph Sylvis, beinc})first duly sworn and says that he executed the foregoing as his free act and deed.
ri-a.
Notary Fublic gy commiss,oa lue e4 3, ajuerc tr& ores Il t 4 90
l Enclosure to NFC-88-0001 Page 1 I.
BACEGBOUW/DISCUSSIM The present alarm setpoints for the Reactor Coolant System Interface Valves Leakage Pressure Monitors (L1H) contained in Technical Specification Table 3.4.3.2-2 were in some instances found to be nonconserv:tively specified too high. The purpose of the LPMs is to provide a(ditional assurance of the integrity of the Reactor Coolant System pr assure isolation valves which form a higVlow pressure boundary.
Tha LPM is designed to alarm on increasing pressure on the low pressare side of the higVlow pressure interface to provide indication to the operator of abnormal interface valve leakage. Upon abnormal interface valve leakage, the low pressure portion of the system in question would begin to increase in pressure due to the leakage from the Reactor Coolant System. The pressure would then increase to the setpoint for the relief valve installed on the low pressure piping. This relief valve would lift to pass the leakage terminating the pressure increase. In the case of the RHR LPCI and RHR Shutdown Cooling System entries, the setpoint specified by Table 3.4.3.2-2 was such that the LPM alarm may not occur prior to system relief valve actuation. Thus, the LPM alarm may be precluded by action of the relief valve. The proposed change lowers the alarm setpoints in Table 3.4.3.2-2 to values which ensure the LPM alarm precedes relief valve actuation. Ensuring that the LPM alarms prior to the relief valve actuation will ensure that the interface valve leakage is detected by the IPM.
Presently, the alarm setpoints in Table 3.4.3.2-2 are listed as nominal values with a specified tolerance. Completion of the LPM function however, depends solely upon the alarm setpoint being less than the lowest pressure relief valve setpoint. Detroit Edison proposes to change Table 3.4.3.2-2 to specify only an upper limit.
This will allow necessary flexibility in the system design while ensuring that the LPM alarms before systam pressure rezches the required value.
The existing LPM alarm setpoint for the RHR LPCI system is 482 i12 psig. The relief valve on the RHR LPCI low pressure piping is set at 464 i 14 psig. The proposed upper limit for the alarm setpoint of RHR I!DCI LPM is 1449 psig to ensure that the LPM alarms prior to relief valve actuation. 449 psig was established on the basis of being below the lowest relief valve lift pressure of 450 psig.
Similarly, the existing RHR Shutdown Cooling system LPM alarm setpoint is 138 i 3 psig and the corresponding relief valve is set at 140 1 4.2 psig. Therefore, the upper limit for this LPM is proposed to be
Enclosure to l-NBC-88-0001 1
Page 2 1135 osig which will ensure the LPM alarms prior to tw relief valve actuation. 135 psig was established on the basis of being below the lowes,t relief valve lift pressure of 135.8 psig.
For the remaining entries in Table 3.4.3.2-2, the existing alarm setpoints were found to be below the corresponding relief valve setpoint. Thus, Detroit Edison proposes to convert the maximum allcued value of the existing alarm setpoint range to an upper limit.
The existing alarm setpoint ranges, relief valve settings and proposed equivalent upper limits are summarized below:
Existing Pressure Proposed Alarm.
' Relief Valve Upper Setpoint Setpoint Limit Sys. tem
_(pgjgl fosig)__
losia)
Core Spray 440 1 12 500 i 15 1 452 HPCI 70 i 1 100 i 3 1 71 BCIC 70 1 1 100 1 3 1 71 The existing alarm setpoint ranges for the RHR LPCI and the RHR Shutdown Cooling Systems were incorrectly determined when the Fermi 2 Technical Specifications were initially drafted. It is believed that consideration of the pressure relief valve tolerance was overlooked in establishing these setpoints. Mditionally, it appears that static head corrections were applied and reflected in the values in the Table. This resulted in further increase in the Table values which should be nominal values. The possibility of these. types of errors was the primary reason.for the validation of the setpoints used in Instrument and Controls surveillance procedures.
Changes to Bases Section 3/4.4.3.2 are also proposed to indicate the basis for the LPM alarm setpoints. - An editorial error is also corrected in this section.
FIGNIFICBNLLI!M2!DS_90NUDNMW In accordance with 10CFR50.92, Detroit R31 son ma3e a determination that the proposed amendment involves no significant hazards considerations.
'Ib make this determination, Detroit B31 son nust establish 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 j
Enclosure to NBC-88-0001 Page 3 previously evaluated, or, 3) involve a significant reduction in a margin of safety.
- 1) The proposed change to lower the alarm setpoints for these LPMs does not involve a significant increase in the probability or consequences of _ an accident previously evaluated as_ correction of these setpoints will only ensure the IlHs provide. warning to the operator of high/ low pressure interface valve leakage as intended by design. Specifying only an upper limit for the LPM setpoint does not involve a significant increase in the probability or consequences of an accident previously evaluated as the LPM remains assured of functioning as intended by design.
- 2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously-evaluated. The LPMs are passive indientions and thus 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 previously evaluated.
- 3) The proposed chage does not involve a significant reduction in a margin of safety as dctailed in 1) and 2) above. The change ensures the LPMs provide the intended margin of safety.
00PCwfLIRN 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) such activities will be conducted in conpliance with the Commission's regulations and proposed amerriments will not be inimical to the common defense and security.or to the health and safety of the public.
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EVJSED 'GCD}LICBL_SBg3EICATICIE The requested revised pages are attached.
III. BASIS FOR PLElpGEN["I CI]QMRpK'ES This situation occurred because incorrect alarm setpoints were specified in the original issuance of the Fermi 2 Technical Specifications. The incorrect values were discovered while conducting a program intended to find such problems and, once discovered, have been pronptly brought forth for resolution.
Enclosure to NRC-88-0001 Page.4 As discussed above the RHR LPCI system and RHR Shutdown Cooling-systen LPM cannot be considered operable if the alarm setpoints are' adjusted as required by Technical Specifications because.the LPM cannot be' assured of functioning in the event of higVlow pressure interface valve leakage. Fermi 2 is currently shutdown and scheduled to restart =
'on January 6, 1988. Specification 3.0.4 requires the LPMs to be operable to start up the plant. Thus, resunption of plant operation is contingent upon approval of this request.
Based on the above, Detroit Edison concludes that this request represents emergency circumstances as described in 10CFR50.91(a)(5).
IL_ MJPPMENEL DHCT
' Detroit F81 son has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental-considerations.- As shown above, the proposed changes do 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 cunulative 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 requirement for an Environmental Inpact Statenent.
L _CDIC WSION Based on the evaluations above:
(1) there is resonable 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 conpliance 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.
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4 Enclosure to MC-88-0001 Page 5 PMPOSED PET CFDUCES i
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