NRC-88-0241, Application for Amend to License NPF-43,incorporating Changes Into Tech Specs 3/4.1.5 & 3/4.8.4.5 Re Standby Liquid Control Sys.Fee Paid

Application for Amend to License NPF-43,incorporating Changes Into Tech Specs 3/4.1.5 & 3/4.8.4.5 Re Standby Liquid Control Sys.Fee Paid

ML20206E118
Person / Time
Site:	Fermi
Issue date:	11/14/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206E121	List: ML20206E125 NRC-88-0241, Application for Amend to License NPF-43,incorporating Changes Into Tech Specs 3/4.1.5 & 3/4.8.4.5 Re Standby Liquid Control Sys.Fee Paid
References
CON-NRC-88-0241, CON-NRC-88-241 NUDOCS 8811170408
Download: ML20206E118 (10)

Text

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}bverber 14, 1988 '

NIC-88-0241 U. S. !L/ lear Regulatory Cocnission Attn Docunent Control Desk Washington, D. C. 20555 '

Reference:

Fermi 2 13C Docket tb. 50-341 100 License No. tPF-43 ,

Subject:

Propostd Technical Specifications Chmge (Licente Anerdnent) StaMby Liquid Control System (3/4.1.5 ard 3/4.8.4.5) ,

Pursuant to 10CPR50.90, Detroit niison Corpany hereby properes to anord Operating License iPF-43 for the Fermi 2 plant by incorporating ,

the encloscd chmges into the Technical Specifications 3/4.1.5, Stardby Liquid Control System aM 3/4.8.4,5, Stardby Liquid Control Syst m Associatai Isolation Devices. The proposei Tccinical I Specification changes resolve 3tardby Liquid Control System irconsistencies by rtdifying 7CCION stat &cnts ad surveillarre requirerent wording to note clearly wl M:curately reflect the system configuration ard opersility Lequirwents. The pry 0N1 aids four 7CTION staterents which will reduce unnecessary plant shutdowns while malataining system reliability ard availability.

Detroit niison has evaluated the prcnosal Technical Specifications against the criteria of 10CFD50.92 aM determinM that no significant hazards consideration is involved. The Fermi 2 Onsite Review orgar.iration has mproval ard the tbeleae Safety Review Group hm reviewed these prcposcd Technical Spccifications ud concurs with the encloud determinations.

Pursuant to 10CFR170.12(c), enclosni with this arcrdnent repost is a check for one rundred fifty dollars ($150.00) . In accordance with 10CPR50.91, Detroit niison han provided a copy of this letter to the State of Michigan, y

8811170408 881114 PDR ADOCK 05000341 h y D h@ '

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US!UC Novenber 14, 1988

!ac-88-0241 Page 2 If you have any qucstions, please contact Mr. Gordon Na3er at (313) 586-4513.

Sincerely, ,

MU E:nclosure cci A. B. Dav!s R. C. Knop J. F. Stang W. G. Rogers Supervisor, Mvanced Planning and Review Section, ,

Michigan Public Service Ccanission  ;

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UStac Novenber 14, 1988 100-88-0241 Ptv)e 3 I, B. PALPil SYLVIA, do hercby affirm that the foregoing statenents are based on facts ani circarritances which are true and scurate to the '

best of ny knowledge an1 belief.

k 6'l .h C

'B.FALPf!SYlffA Senior Vice Presid m t

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"' ' *d . 1988, before ne On thin day of personally appearal B. Ralph Sylvia, beiro first duly sworn an! says that he executed the foregoing as his free act an1 decd.

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'. Novenber 14, 1988 NIC-88-0241 Page 4 boca C. Dorr (WP!C, Inc.)

S. G. Catola G. Cranston P. Pensler J. H. Flynn D. R. Gipnon L. S. Goodmn D. Halm (Michigan Dcpt./Public Health)

C. A. Naegeli W. S. Orser C. Settles R, D. Stafford F. J. Svetkovich B. R. Sylvia R. J. Szkotnicki/H. Whitcorb G. M. Trahey W. ' nicker /G. Prestort/ J. Plona Informtion Manslenent - 140 tKC Secretary's Office (2412 .CB)

NRR Chron File NSIG Secretary RACTS Coordinator t;FSAR Coordinator Author Routing Copy i

J

Enclo:ura to NRC-88-0241 Page 1 BACKGROUND / DISCUSSION The Standby Liquid Control (SLC) System is a special event backup system which provides an independent and diverse means for shutting down the reactor from full power to a cold Xenon-free shutdown, in the postulated event that the control rods cannot be inserted. The system is not an automatic scram or backup scram system, but is a manually actuated and controlled system for shutting down the reactor. The system is designed with a high degree of reliability and with certain narety features (e.g., the power supplies are either automatically restored or manur,11y connected to engineered safety feature busses).

The system was not originally intended, procured, designed, or classified as safety related but is maintained and tested as a safety-related syster The. SLC System is not completely single failure proof. Ho n e, the power supplies, pumps, explosive discharge valves, hu tracing, and tank heaters have redundant or diverse components such that any one of these components can be out of service and the system can still perform its design function.

The proposed changes affect two SLf' System Technical Specifications -

3/4.1.5, Standby Liquid control Syates and 3/4.8.4.5, Standby Liquid Control System Associated Iaolation Devices. Technical Specification 3/4.1.5 is very sintiar to its associated ceneral Electric Standard l

Technical Specification. but Technical Specification 3/4.8.4.5 is l

Ferci 2 specific. Subsequent to the NRC review of this systum (as documented in Safety Evaluation Report Supplement #5 - NUREG 0798),

Detroit E.dison proposed Technical Specification 3/4.8.4.5 to ensure the reliability and availability of the system by periodic testing of the SLC non-class 1E isolation devices. The non-class 1E circuit breakers, actuated by fault currents, are t. sod as isolation devices to protect equipment associated with the SLC System. The operr.bility requirements of these circuit breakers ensure that the SLC System equipment is protected in the event of faults in the loads powered by these circuit breakers.

Technical Specification 3 8.4.5 requires OPERABLE SLC circuit breakers for pumps A and B, tank heaters A and B, and heat tracing circuits A and B. ACTION statement 3 8.4.5.b must be entered if one or more of the above breakers is inoperable. This ACTION statement requires, among other things, that the SLC System bo declared inoperable and the appropriate SLC System ACTION statement be entered. The appropriate ACTION statement that must be entered with the SLC System declared inoperable is 3 1.5.a.2 (or 3 1.5.b.2 depending on the plant's OPERA'tIONAL CONDITION). Thus, in accordance with ACTION statement 3 1.5.a.2 a plant shutdown must be initiated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if sny one of the SLC System circuit breakers listed in Technical Specifications 3 8.4.5 becomes inoperable, i

'~.

. Enclosuro tu NRC-88-0241 Page 2 It is ove.ly conservative to declare the entire SLC System inoperable and shut down the plant (or insert all insertable control rods), in a relatively short period of time, when one redundant or diverse component is inoperable. All of the circuit breakers required operable by Technical Specifications 3 8.4.5 have either redundant or diverse equipment as t back up such that any one of these components (and in some cases two components concurrently) can be out of service and not effect the SLC System from performing its design function.

Similarly, an inconsistency exists between current ACTION statements 3 1.5.o.1 &nd 3 8.4 5.b. ACTION 3 1 5.a.1 nilows seven days to return one SLC pump to operability, should its motor circuit breaker fail.

ACTION 3.8.4.5.b allows only e pht hours to return the SLC pump to operability, should the same . mr fail, because this ACTION ,

4 declares the entire SLC System anoperable and subsequently invokes ACTION 3 1.5.a.2 (eight hours to restore to OPERABLE status or shut down).

Only one of the two SLC pumps and one of the two SLC discharge valves are needed for system operation and to meet the design flow requirements. To further assure the availability of the SLC System, cross piping and check valves provide for a flow path through either pump or explosive discharge valve. SLC pumps are powered from separate power supplies and each explosive discharge valve has dual ignition primers.

Likewise, only one of the two SLC heat tracing circuits and one of the two tank heaters are required OPERABLE to maintain the required sodium pentaborate solution temperature. Heat tracing circuits are duplicated, controlled from separate panels, and connected to separate powe? sources. Two tank heaters exisc but only one is needed to maintain normal tank temperatures. Both heaters can be manually controlled and one can also be automatically controlled.

Instrumentation exists to manually control the tank's temperature should the automatically controlled heater circuit become inoperable.

The SLC heaters are also powered from separate power supplies.

There are sufficient backup components in the SLC System to preclude a plant shut down in a short period of time (within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) resulting from the inoperability of one circuit breaker as currently required by existing Technical Specifications 3 8.4.5 and 3 1.5. Additionally, it is unnecessary to enter existing ACTION statement 3 1.5.a.2 and shut down the plant because no specific ACTION statement addresses the inoperability of a SLC heat tracing train or a tank heater.

To correct these unnecessary conservatisms and maintain the high level of assurance that the SLC System is available to perform its design function, the proposed changes have modified ACTION statement 3 8.4.5.b, added four new ACTION statements to Technical

. Enclo:ure to NRC-88-0241 Page 3 Specification 31.5 and reformated the existing ACTION statements (see attached Technical Specifications). ACTION statement 3 8.4.5.b has been modified to require that only the affected component has to be declared inoperable as a result of an inoperable circuit breaker.

This change will allow the applicable component level ACTION statement of Technical Specification 3 1.5 to apply reducing unnecessary plant shutdowns.

The four ACTION statements added to Technical Specification 3 1.5 allow plant operation to continue with one-out-of-two trains of heat tracing or one-out-of-two tank heaters inoperable provided the associated ACTION statement's compensatory requirements are successfully performed. These compensatory requirements are performed at an increased frequency over the "normal" 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance frequencies. While these four ACTION statements will allow plant operation to continue with out of service SLC heating equipant, the required increase in surveillance requirements and surveillance frequency compensates for any loss of system reliability attributed to the out of service equipment.

The initial out-of-service time (7 days) for the four proposed ACTION statements is consistent with the existing Technical Specification ACTION statement 3 1.5.a.1 and the associated ceneral Electric Standard Technical Specification for an inoperable SLC pump and/or explosive valve. khen complying with the 7 day out-of-service time of existing ACTION statement 3 1.5.a.1, the failure of the second SLC pump or esplosive valve is more detrimental than the failure of both trains of heat tracing or both tank heaters because the failure of both pumps or both valves renders the SLC system immediately non-functional; aowever, failure of both heat tracing trains or both tank heaters does not immediately render the SLC system non-functional and may not degrade the functionality of the system at all if normal Reactor Building air temperatures are maintained. SLC System functionality is based on the sodium pentaburate solution temperature not the number of redundant or diverse equipment available to maintain that temperature. Furthermore, the saturation temperature of the recomaended sodiun pentaborate solution is 59 F. The equipment containing the solution is installed in a room in0 which the air temperature is maintained within the range of 70 F to 100 F.

Successful p;rformance of existing surveillance requirenent 4.15.a.3 is not an accurt.te assessment that the heat tracing is maintaining all of the heat traced piping above the required temperature because the piping temperature is only verified at a single point. There is SLC heat traced piping on three floors of the Reactor Building with no fluid flow to assist in a uniform heat distribution. The existing surveillance requirement may not identify a low temperature condition thtch could lead to sodium pentaborate precipitation if a portion of l the heat tracing becomes inoperable and the ambient temperature falls l

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Enclosuro to NRC-88-0241 Page 4 below 70 0 F. The proposed wording (see attached Technical l Specification) nodifies the existing surveillance requirement by adding a requirenent to verify that the heat tracing's continuity monitoring lights are energized. De continuity monitoring lights verify that the heat trace circuit is continuous und power is present  ;

to the heat tracing cable. The heat tracing cable is a self regulating parallel circuit which varies its resistance with temperature. When the temperature drops the heat output increases; conversely, as temperaturn rises the heat output decreases. This self regulating phenomenon occurs independently along each section of .

heating cable (each heat tracing train has 13 sections with individual continuity monitoring lights). The continuity monitoring lights are ener;;1 zed as long as the heat tracing is functional. Successful completion of the proposed surveillance requiruent ensuras that the SLC heat tracing it functional and maintaining the heat traced piping at or above the required temperature.

The pa posed Technical Specification changes are more representative of SLC System design and capabilities than the cristing Technical Specification requirements. There is sufficient backup equipment or Technical Specification required compensatory measures (e.g., increase in surveillance requirement frequency) to allow continued plant operation with specified SLC equipment out of service wit.hout loss of system reliability.

SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50.92. Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must ,

establish that operation in accordance witt the proposed amendment would nott 1) involve a significant increase in the probability or consequencer 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) We proposed chani,es and additions to the SLC System Technical Specifications ACTION statements and surveillance requirement do not involve a significant increas in the probability or consequerces of an accident previously evaluated. The proposed ACTION statement additions do not significantly reduce the reliability or availability of the SLC Systen even though they allow one of the two SLC heat I tracing circuits or one of the two tank heaters out of service without l requiring the plant to be shut down or that insertion of all insertable

! control rods. The proposed ACTION statenents increase surveillance l requirements and surveillance frequency which will result in earlier l

detection of degrading sodium pentaborate solution temperatures in the unlikely event that the remaining equipment fails and is not

l Enclosuro to NRC-88-0241 i

Page 5 l immediately identified, and normal Reactor Building temperatures are not, maintained. The earlier detection of degrading solution  !

temperatures also allows the operations staff more Line to correct the situation or shut down the plant with the SLC Systen .:,till capable of performing its function.

The proposed ACTION statement's out-of-service time (T days) without ,

initiation of compensatory measures is consistent with a,cepted 1 industry standards for SLC equipment whose redundant equipment failurs i (eg. both SLC pumps inoperable) is more detrimental than the failure i of both heat tracing trains or both tank heaters. In the unlikely event that both heat tracing trains or both tank heaters fail within this 7 day period, normal Reactor Building air temperatures will maintain th9 sodium pentaborate solution above its saturation  :

temperature until the plant can be shut down. During this 7 day pet tod, monitoring of the remaining heat tracing circuits and solution I temperature is still required every 9.4 houra in accorr'ance with the periodic survai'. lance requir2aent. ,

The pt oposed changes to ACTION statement 3 8.4.5.b will reduce  !

)

unnecessary pit.nt shutdowns by allowing the appropriate cosponent level ACTIOS statement, requirements of Techr.ical Specification 31.5 to apply and control equipment declared out of service. The proposed  !

surveillance requirersnt provides greater assurance that all of the hest traced piping is maintained at or above the required temperature than the existing surveillance requirement, by requiring tnat the heat traced continuity monitoring lights are energized.

2) The proposed changes and adt'itions to the 3LC Syster. Technical Specification ACTION statements and surveillance requirc2ent do not create the possibility of a new or ditferent kind of accident from any accident previously e'raluated because these changes introduce no new i node of plant operation nor involve a physical modification to the plant.

i 3) The proposed changet, and additions to the sLC Systen Technical Specification ACTION statements and surveillance requirenent do not i

involve a significant reduction in safety because the reliability and ,

availability of the SLC Syster is not significantly reduced. The z l

reliability and availability 1.s not significantly affected with the specified equipment out or service becaase the required increase in i surveillance requirements and surveillance frequency will detect ,

degrading conditions shoubt the remaining component fail coincident with abnormall, Icw Reactor building air tenperatures. Earlier detection of degraling temperatures also allo'#J more time to correct j the situation or safely shut down the plant. The proposed ACTION  ;

a statement's out-of-service time (7 days) without initiation of i 2

compensatory measures is consistent with accepted industry standards j j for St.C equipment. Normal Reactor Building air temperatures, backup i j i i

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Encloruro to NRC-88-0241

, Pace 6 equipment and routine surveillance requirements ensure that the SLC Systee. will be OPERABLE during this 7 day out-of-service period.

These changes will reduce unnecessary plant shut downs and provide greater ussurance that all of the heat traced piping is maintained at or above its required tenperature.

Based on the above, Detroit Edison has determined that the proposed ar,endment does not involve a significant hazards consideration.

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 fo' environmental considerations. The proposed change does 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 cumulative occupat*onal radiaticn exposures. Based on the forogoing, Detroit Edison *,oncludes that the proposed Technical Specif'. cations do meet the '.riteria.given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

CONCLUSION Based on the evaluation abovet 1) there is reasonable assurance that tt.e health and safety of the public will ret be endangered by operation in the proposei manner, and 2) such activities will be conducted in compliance with the Connission's regulations and proposed amendment.s will not be inimical to tt.e common defense and security or to the health and safety of the publia.