NRC-88-0049, Requests one-time Exemption from 10CFR50,App J,Paragraph III.D.3 for Three RHR Shutdown Cooling Inboard Isolation Valves,Extending Valves Local Leak Rate Test Interval Until Refueling Outage in 1989.Fee Paid

Requests one-time Exemption from 10CFR50,App J,Paragraph III.D.3 for Three RHR Shutdown Cooling Inboard Isolation Valves,Extending Valves Local Leak Rate Test Interval Until Refueling Outage in 1989.Fee Paid

ML20149M611
Person / Time
Site:	Fermi
Issue date:	02/22/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-88-0049, CON-NRC-88-49 NUDOCS 8802260180
Download: ML20149M611 (4)

Text

l l . *w B. Ralph Sytyh i

• Group Vice Presadant t-6400 North Dme Highway g' gporiggen 48$68 February 22, 1988 NIC-88-0049 U. S. Nuclear Regulatory Comnission Attn Document Control Desk Washington, D. C. 20555

References:

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

2) Detroit B31 son Letter to NIC, "Proposed Tecimical Specification (License Amendnent) Change - Primary Containment Isolation valves (3/4.6.3)," data 3 February 10,1988 (NIC-88-0031) .

Subject:

Request for hnporary Exenption from 10CFR50 Appendix J - Primary Containment Isakage Testing ,

on the Residual Heat Renomi Shutdown Cooling +

Inboard Isolation Valves In accordance with 10CFR50.12 (a) (2)(iv), Detroit Elson hereby '

requests a one-tine exenption from the requirement of 1(CFR50, Appendix J, Paragraph III.D.3 for three Residual Heat Bemoval (RHR) '

Shutdown Cooling inboard isolation valves (Ell-F009, Ell-F408 and Ell-F608) . The one-time exenption request will extend the valves local leak rate test (LIRr) intervals until the first refueling outage, currently scheduled for 1989.

The requirement of 10CFR50, Appendix J, Paragr@h III.D.3 specifies '

that:

"Type C tests shall he performed during each rezetor stutdown for

refueling but in no case at intervals greater than 2 years".

This requirenent is also reflected in Technical Specification  !

4.6.1.2.b for primary containment isolation valves listed in Table 3.6.3-1.

Detroit H31 son requests this one-tine exenption from the requirements of 10CFR50, Appendix J in accordance with 1(CFR50.12(a) based upon the specific exenptions contained herein. The one-tine exenption request will not present an undue risk to the public health and safety, and is consistent with the comnon defense and security. The extension of the 8802260100 880222 PDR p

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h USNEC February 22, 1988 NEC-88-0049 Page 2 required testing interval will not be contrary to the basic intent of the 10CFR50, Apperdix J requirements, i.e. to leak test the valves after a nominal two years of operation. Detroit Plison concludes, based upon past leakage rate performance for these valves and based upon the fact that these valves have not been exposed to a significant powr operating environment, that the increased probability of containnent leakage is not significant and that no neasurable inpact would result from the proposed extension of time. Since the basic intent of the regulation is not violated, there is no urdue risk to public health and safety involved with plant operation with the requested exenption in place. Nothing is contained in the exenption request that is inconsistent with the connon defense and security.

The special circunstances present which justify the Commission's consideration of this exenption request conform to the following paragraphs of 10CFR50.12(a.) .

50.12(a) (11) - Application of the 10CFR50, Appendix J requiranents in this situation for testing within two years would not serve the underlying purpose of the regulation, which is to ensure testing after two years in an operating environment. Since Fermi 2 did not exceed 5% pomr until Septenber 1986 ard 50% power until Decenber 1987, none of the valves in question will have been exposed to a significant operating pressure environnent. The core average exposure through February 22, 1988 was only 112 EPPD.

This is conpared to approximately 335 EFPD remaining in the cycle. The requested extension of tine does not conflict with the intent of the rule arrl defers the testing requirenent intended by 10CFR50, Appendix J to the first refueling outage.

50.12 (a) (2) (iv) - The requested exenption would result in benefit to the public health and safety that conpensates for any decrease in safety that may result from the granting of the exenption. The increased benefit would be from not having to renove both loops of RHR from operation in order to perform the testing from which Detroit B31 son is asking to be exenpted. Removal of both RHR loops necessitates reliance solely on alternate means of reactor core cooling (decay heat removal) .

,, USNIC February 22, 1988 NIC-88-0049 Page 3

'HCWICPItCggilDEIBIERE As the end of the initial 24-month testing intervals for many of the Fermi 2 containment isolation valves is appromhing in early 1988, Detroit Eison has scheduled an LLRT outage for March 1988. % sting of the above specified mm shutdown cooling inboard isolation valves, ,

however, will require one or more of the following conditions:

1) Reactor vessel hea3 removal

2) Both mm shutdown cooling loops rendered inoperable reducing the nunber of prinary shutdown cooling loops below the Technical Specification Limiting Condition for Operation Detroit Elson does not plan to remove the reactor vessel head until the first refueling outage. Performance of this test would require the inoperability of both loops of Mm shutdown cooling. Therefore, Detroit B31 son would be required to either remove the reactor vessel head aM flood the vessel, or to solely utilize alternate mems for renoving decay heat. Typically, a single mm shutdown cooling mode loop provides sufficient heat removal capability for removing core decay heat and mixing to assure accurate tenperature indication. As required by Technical Specification 3/4.4.9.2, two mm shutdown cooling mode loops nust be TERABLE or alternate nethods capablo of decay heat removal nust be verified @EFABLE and an alternste method of coolant mixing be in operation. During the LLRT outage in March 1988, it is expected that only one RHR lovp would be operable and an alternate means specified. Without the approval of the requested exenption, all primary means of decay heat removal would be lost during the preparation and coMuct of the testing. The plant would be forced into utilizing its first alternate nethod as the primary cooling mode and verifying a second alternate means as a backup.

While suitable alternate methods are available, they are not as desirable and would require unusual equipment operation and coolant flowpaths. It is preferred to use the RHR shutdown cooling node and to maintain the alternate decay heat removal nothods as bxk-ups, not as the primary nethod of decay heat removal and coolant circulation.

The mm shutdown cooling inboard isolation valves (Ell-F009, Ell-F408 and Ell-F608) become overdue for testing on April 28, 1988. The 24-rxinth testing intervals for primary containment isolation valves is intended to be often enough to prevent significant deterioration from occurring and long enough to permit LLETs to be performed during plant outages. The valves were successfully tested on 8/27/84 during preoperational testing resulting in a conbined penetration leakage of 0.35 scfh, on 5/28/85 resulting in a conbined penetration leakage of 1.59 scfh, and on 4/28/86 resulting in a conbined leakage of 1.68

. . USNIC February 22, 1988 NBC-88-0049 Page 4 .

scfh. The total of the Type C leakage rates for these valves is not a significant portion (0.94%) of the allowable leakage limit (0.6 La) .

These valves are normally closed at power operation and any deterioration in the overall integrity of these valves is expected to be a gradual process. The penetration valves Ell-F008, Ell-F009 and Ell-608 are also leak tested as reactor coolant system pressure isolation valves in accordance with 'Itchnical Specification 4.4.3.2.2. This test requires pressurizing the valves to 1040 110 psig with water and measuring valve seat leakage. Valve leakage is limited to 1 gpm per valve and is performed on an 18-month plus 25%

extension interval. These valves were last tested on 5/30/86 resulting in a leakage of 0.029 gpm. Additionally, the Rim system is nonitored for leakage in accordance with the Fermi 2 Leakage Reduction Program. This program is required by Technical Specification 6.8.5 and requires measuring and recording any leakage from the system and its conponents during operation in various operating configurations.

Testing these valves in accordance with Technical Specification 4.4.3.2.2 and monitccing of the system in accordance with Technical Specification 6.8.5 will continue to be performed.

Detroit Edison has provided to the NBC (Reference 2) a letter requesting renoval of the 10CFR50 Appendix J Type C leakage test requirements on the Ell-F009, Ell-F408 and Ell-F608 valves. The basis of the requested change is that the Rim system is considered a closed system outside containment and that only one isolation valve (Ell-F008) is required. This request for a one-time exenption to Appendix J testing interval is not to be in lieu of the Technical Specification change request (Reference 2) .

Detroit n31 son anticipates that the circumstances expecta3 during the upcoming Local I.cak Rate Test outage scheduled for March 1988 will require this exenption. Therefore, your pronpt consideration is requested.

Pursuant to 10 CFR 70.12(c), enclosed with this request for exenption is a check for one hundred fifty dollars ($150.00) .

If you have any questions, please contact Ms. Lynne S. Gocdman at (313) 586-4211.

Sincerely, f.a0 ^

cc: Mr. A. B. Davis Mr. E. G. Greenman Mr. T. R. Quay Mr. W. G. Togers

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