Text

Application for Amend to License NPF-43,changing Tech Specs 3/4.4.7,3/4.6.3,3/4.6.4.2 & Definition 1.29 Re Containment Isolation Valves
	ML20006C055
Person / Time
Site:	Fermi
Issue date:	01/26/1990
From:	Sylvia B; DETROIT EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20006C056	List: ML20006C059; NRC-89-0273, Application for Amend to License NPF-43,changing Tech Specs 3/4.4.7,3/4.6.3,3/4.6.4.2 & Definition 1.29 Re Containment Isolation Valves;
References
	CON-NRC-89-0273, CON-NRC-89-273 NUDOCS 9002060248
	Download: ML20006C055 (10)
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senior me hes.oeni 0400 North Du m H,ghway om,wi u o ,v.n nios gp w(3t3i Mt6 4150 January 26, 1990 NIC-89-0273 U. S. Nuclear Regulatory Cmunission Attn Document Control Desk Washington, D. C. 20555 Refererce: Formi 2 NIC Docket No. 50-341 NIC Licence No. NPP-43

Subject:

Proposed Technical Specification Change (Licence Anananant) - Containnent Isolation Valven Pursuant to 10CFR50.90, Detroit Fdison Company hereby proposes to amend Operating License WF-43 by incorporating the enclosed changes into Fermi 2 Technical Specifications 3/4.4.7 " Main Steam Isolation Valve", 3/4.6.3 " Primary Containnent Isolation Valves", 3/4.6.4.2 "Ibactor Building to Suppression Chanber Vacuum Breakers" and Definition 1.29 "PRIMAIN CORTAIMENP INTERI'IY". The proposed changes resolve identified inconsistencies between the above Specifications.

Additionally, changes have been proposed to Specification 3/4.6.4.2 to add the Beactor Building to suppression chamber vzcuum breaker isolation valves to this 'Ibchnical Specification. These valves are in series with the vacuum breaker check valves. Failure of the isolation valves can adversely affect the vzcuum brezker function of the Beactor Building to suppression chanber vzcuum breaker system.

Detroit Etlison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fenni 2 Onsite Review Organization has zpproved and the tbclear Safety Review Group has reviewed these proposed Technical Specification changes and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

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

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R. W.;DeFayette:

.W. G. : Rogers J. F.'Stang, 3

Supervisor, Mvanced Planning and Revlew Section, "

. Michigan Public Service Commission -

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N10-89-0273-Page.3-V I, B.' RALPH SYLVIA, do her eby cffirm that the foregoing statements are :)

based on facts and circurstances which are-true and accurate to the .

best of my knowledge and belief.

&> ab B.'RATfHSpfIA Senior Vide President ;

On this 26th day of_ January , 1990i before me 'I personally appet red B. Ralph Sylvia, being- first duly sworn and says rg" that he executed the foregoing as his free act and deed. -

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. . . Enclocuro to

.: NRC-89-0273 Page.1-INTRODUCTION The proposed amendment corrects three inconsistencies associated.with containment isolation valves Technical Specifications (TS). The first

- inconsistency relates to_ the differences between ACTION statements ~

3 6 3.a " Primary Containment Isolation Valves" and TS 3 4.7.a " Main Steam Isolation Valves". Because the Main Steam Isolation Valves

-(NSIVs) are containment isolation valves, ACTION statements 3 6.3.a and 3 4.7.a apply to an inoperable MSIV (see attached TSs). However,

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these ACTION statements are inconsistent in the amount of time allowed to deactivate and close an NSIV whea complying with the subject ACTION statements.

The second inconsistency addressed by this proposed amendment is related to the dual function of the Reactor Building to suppression chamber vacuum breaker check valves and associated isolation valves.

This system is described in Section 6.2.1.2.1.10 of the Updated Final

. Safety Analysis Report. The Reactor Building to suppression chamber vacuum relief system consists of two redundant lines from the Reactor Building atmosphere to the suppression chamber atmosphere. Each line contains a vacuum breaker testable check valve in series with an air operated butterfly isolation valve. Both of these valves are normally closed. The vacuum breaker check valve is self-actuating, opening at a maximum differential pressure of 0.5 paid. The air operated isolation valve is actuated open by a maximum differential pressure signal of 0.5 paid. The isolation valve is designed to fail open upon loss of air pressure and/or electrical power. These valvas are containment-isolation valves and are appropriately listed in TS 3.6.3 However,_these valves are also designed to perform a vacuum relief function during accident conditions. Condensing steam from a-Loss of Coolant Accident (LOCA) could cause a drywell vacuum condition to occur beyond its design value without these vacuum breakers. With the drywell in a vacuum condition, the suppression chamber to drywell vacuum breakers open to vent non-condensables from_ the suppression chamber atmosphere to the drywell. 'This equalizes the pressure between the drywell and suppression chamber. With the suppression chamber in a vacuum condition, the Reactor Building to suppression chamber vacuum breakers are designed to open to equalize the pressure between the Reactor Building and suppression chamber.

Because of the dual function of these valves, TS 3.6 3 and TS 3.6.4.2

" Reactor Building to Suppression Chamber Vacuum Breakers" are applicable. However, ACTION statement 3 6.3.a.2 (see attached TSs) is inappropriate with respect to deactivating a Reactor Building to suppression chamber check valve or isolation valve, because the check valve is self-actuating on differential pressure and cannot be deactivated in a secured position and the isolation valve is designed to fail open if deactivated. ACTION statement 3 6 3.a.3 is inappropriate because there are no manual valves or flange connections i i

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in the vacuum relier lines. Additionally, ACTION statement times and required functions are inconsistent between ACTION statements 3 6 3.a and 3 6.4.2.a and b (see attached TSs).

The third inconsistency addressed by this proposed amendment is related to TS 3/4.6.4.2. The current TS does not specifically address the isolation valves which are in series with the vacuum breaker check valves. A reference is made to the isolation valves in ACTION statement 3.6.4.2.b but it incorrectly implies that the isolation valve is normally open. The vacuum breaker check valve and isolation

' valve are'normally closed because of their containment isolation

-function. A failure of the isolation valve to automatically open is as detrimental to the operability of the Reactor Building to suppression chamber vacuum relief system as the failure of the vacuum

-breaker check valve. Detroit Edison performs additional TS type surveillances on.these isolation valves to routinely determine their operability even though these surveillances are not currently required by the TS.

EVALUATION To correct the inconsistency between the times specified in ACTION statements 3.4.7.a and 3 6 3.a, the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months currently specified in ACTION statement 3 4.7 has been changed to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Using 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is consistent with ACTION stater.ent 3.6 3.a and thus, the majority of the containment isolation valves.

To correct the Reactor Building to suppression chamber vacuum breaker and isolation valve inconsistency, Detroit Edison proposes to exempt these valves from-compliance with ACTION statement 3 6 3.a and allow TS 3 6.4.2 ACTION statements' to govern. This position is supported by the existing Definition for PRIMARY CONTAINMENT INTEGRITY, 1.29.

Item g of this Definition states PRIMARY CONTAINMENT INTEGRITY shall exist when "the suppression chamber to reactor building vacuum-breakers are in compliance with Specification 3 6.4.2".

To correct the TS 3/4.6.4.2 inconsistency of not specifically addressing the vacuum breaker isolation valve, the proposed changes include incorporation of these valves into Specification 3/4.6.4.2.

The specific proposed changes (see attached TSs) are:

o ACTION 3 4.7.a has been modified by reducing the amount of time allowed to deactivate and close a MSIV if it.or the other MSIV in the same main steam line become inoperable.

This time has been reduced from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to be consistent with TS 3 6 3 1

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, c Enclorura to-p Dr.3 4 NRC-89-0273 P Page 3-o ACTION 3 6 3.a has been modified to allow tr.a ACTION statements' of TS 3 6.4.2 to apply. The ** footnote has been

. proposed to ACTION 3 6 3.a which stdes:

"The ACTION statement is not applicable for inoperable Reactor Building to suppression chamber vacuum breaker check valves-(T23-F450A and B) and isolation valves (T23-F409 and T23-F410). Follow the applicable ACTION statement of Specification 3.6.4.2 if any of these valves become inoperable."

This footnote is necessary because ACTION statements 3.6.3.a.2 and .3 cannot be complied with for an inoperable Reactor Building to suppression chamber check valve or isolation valve. 1 o The existing Limiting Condition for Operation (LCO) 3.6.4.2 has been rewritten to include the vacuum breaker isolation valve and to specify that both the vacuum breaker check valve and air operated isolation valve are considered a " vacuum breaker valve set." Associating these two valves with a term such as vacuum breaker valve set is consistent with the TS of another plant of similar design and enforces the current level of control to the air operated isolation valve as currently applies to the vacuum breaker check valve.

o TS 3 6.4.2 ACTION statements a), b) and d)-(current ACTION statement c) and Definition 1.29 " PRIMARY CONTAINMENT

. INTEGRITY" have been' modified to incorporate the terminology proposed for LCO 3.6.4.2 (e.g., vacuum breaker valve set).

The proposed wording' enforces the current level of control to the air operated isolation valve as currently applies to the vacuum breaker check valve.

o TS 3 6.4.2 ACTION statement c) has been added'to specify the required actions to be taken when both valves in a Reactor Building.to suppression chamber vacuum breaker set are open.

This ACTION statement is based on the PRIMARY CONTAINMENT INTEGRITY TS ACTION statement, TS 3.6.1.1.

o Surveillance Requirement (SR) 4.6.4.2 has been modified by adding " check valve and air operated isolation valve." These proposed words will specify that TS surveillances apply to-both valves (unless otherwise specified) not just the vacuum breaker check valve.

o SRs 4.6.4.2.b.1.a, 4.6.4.2.b.1.b., 4.6.4.2.b.2.b and 4.6.4.2.b.2.c have been modified by adding "each valve", "on each valve" or "of each valve" to clarify that these SR apply to both valves.

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, Enclo2ure to L t. NRC-89-0273 Page 4 o- SR 4.6.4.2.b.2.a has been modified by adding " check valve" to clarify that this SR is only applicable to the vacuum breaker check valve. This SR is only applicable to the vacuum breaker check valve because the vacuum breaker check valve is self actuating on differential pressure, unlike the air operated isolation valve, and any unexpected resistance could potentially affect the valve's operation.

o SR 4.6.4.2.b.2.d has been added to insure that the automatic control system for each air operated isolation valve is operational and calibrated. The 18 month periodicity is consistent with the periodicity established in the Standard Technical Specification for a CHANNEL CALIBRATION on similar equipment.

The proposed change to TS 3.4<7 is justified because it corrects an inconsistency between the ACTION statements of TS 3 4.7 and 3 6.3 and-incorporates the more conservative requirements of the subject ACTION statements.

The proposed change ~to TS 3.6 3 is justified because it appropriately applies specific ACTION statements, with allowable out-of-service times which can be applied, to the Reactor Building to suppression chaaber vacuum breaker check valves and isolation valves. Because these valves perform two functions, containment isolation and

-containment vacuum relief, their design does not allow use of the

" generic" containment isolation valve out-of-service time in TS ACTION statement 3 6 3.a. ACTION statement 3.6 3.a requires isolation of a penetration that contains an inoperable containment isolation valve by deactivating an automatic valve in the isolated position, lock closing a manual valve or installation of a blank flange in order to continue plant operation. The Reactor Building to suppression chamber vacuum breaker check valves are self actuating and cannot be deactivated.

The isolation valve is designed to open when deactivated to fulfill its vacuum relief function. The vacuum relief lines do not contain any manual isolation valves and do not have provisions for the installation of a blank flange. Additionally, even if the ACTION statement 3 6 3.a provisions could be used, the amount of time spent in this ACTION statement is not limited as long as the ACTION statement's isolation provisions are satisfied. Use of the ACTION statement 3.6.3.a provisions would also prevent the vacuum relief function of the affected line, which is required by ACTION statement 3.6.4.2.b. Thus, these valves cannot and should not be positioned as called for in ACTION statements 3 6.3.a.2.& a.3 when an inoperability condition exists.

The proposed ACTION statements of TS 3 6.4.2 provide the required balance between the dual function of the subject valves. These ACTION statements incorporate the isolation function of TS 3.6.3 with a

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. NRC-89-0273 Page 5 commonly accepted TS out of service time (e.g., a limit of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) associated with redundant safety related systems.

Furthermore, the Definition of PRIMARY CONTAINMEWT INTEGRITY 1.29 states that PRIMARY CONTAINMENT INTEGRITY shall exist when the.

suppression chamber to reactor building vacuum breakers are in compliance with Specification 3 6.4.2. Therefore, the proposed change to TS 3 6.3 is consistent with the design of the subject vacuum relief system and is supported by our current TS Definition of PRIMARY CONTAINMENT INTEGRITY.

The proposed changes to TS 3 6.4.2 are justified because they add the air operated isolation valve to TS 3/4.6.4.2. Failure of these valves to automatically open is as detrimental to the operability of the Reactor Building to suppression chamber vacuum relief system as the failure of the vacuum breaker check valve. These changes will provide additional controls not currently specified to insure that the Reactor Building to suppression chamber vacuum relief system can perform its intended function.

The proposed addition of ACTION statement 3 6.4.2.c is consistent with the existing ACTION statement for TS 3 6.1.1, Primary Containment Integrity.

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 with the proposed amendment 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 margin of safety.

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident-previously evaluated because the proposed changes do not change any accident or transient analysis, does not physically modify the plant and does not introduce a new mode of plant operation.

The proposed change to TS 3.4.7 corrects an inconsistency between the ACTION statements of TS 3 4.7 and 3.6 3 Because the MSIVs are containment isolation valves, ACTION statement 3.6.3.a and 3.4.7.a apply to an inoperable MSIV. However, these ACTION statements are inconsistent in the amount of time allowed to deactivate and close an MSIV when complying with the subject ACTION statements. The proposed change incorporated the more

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conservative time from the subject TS to resolve this j L ' inconsistency. 3 The proposed change to TS 3 6.3 will appropriately apply specific ACTION statements, with allowable out-of-service times which can be applied, to the Reactor Building to suppression chamber vacuum breaker check valves and isolation valves. Because these' valves I perform two functions, containment isolation and containment vacuum relief, their design does not allow use of the " generic" containment isolation valve out-of-service time in TS ACTION ;

statement 3 6 3.a. ACTION 3 6 3.a requires isolation of a penetration that contains an inoperable isolation valve by deactivating an automatic valve in the isolated position, lock ,

closing a manual valve or installation of a blank flange in order L to continue plant operation. The Reactor Building to suppression ..*~'l l- ,

chamber vacuum breaker check valves are self actuating and cannot l be deactivated. The isolation valve is designed to open when ;

deactivated to fulfill its vacuum relief function.- The vacuum relief isolation valves do not contain any manual isolation valves and do not have provisions for installation of a blank L flange. Additionally, even if ACTION statement 3 6 3.a , i L provisions could be used, the amount of time spent in this ACTION l statement is not limited as long as the ACTION statement's "

isolation provisions are satisfied. Compliance with ACTION statement 3 6.3.a would also prevent the vacuum relief function of the affected line, which is required by ACTION statement 3 6.4.2.b. Thus, these valves cannot and should not be positioned as called for in ACTION statements 3 6 3.a.2 and a.3 when an inoperable condition exists.

The proposed ACTION statements of TS 3 6.4.2 provide the required I balance between the dual function of the subject valves. These l ACTION statements incorporate the isolation function of TS 3.6.3 )

with a commonly accepted TS out of service time (e.g., a limit of 1 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) associated with redundant safety related systems.

Furthermore, the Definition of PRIMARY CONTAINMENT INTEGRITY i states that " PRIMARY CONTAINMENT INTEGRITY shall exist when the 1 suppression chamber to reactor building vacuum breakers are in (

compliance with Specification 3 6.4.2." Therefore, the proposed l change to TS 3.6 3 is consistent with the design of the subject vacuum relief system and is supported by the current TS DEFINITION ~of PRIMARY CONTAINMENT INTEGRITY.

The proposed changes to TS 3 6.4.2 add the air operated isolation .

valve to TS 3/4.6.4.2. Failure of these_ valves to automatically open is as detrimental to the operability of the Reactor Building to suppression chamber vacuum relief system as the failure of the vacuum breaker check valve. These changes provide additional controls not currently specified to insure that the Reactor

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. Enclo:ura to d.i NRc-89-0273' Page 7

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-Building to suppression chamber vacuum relief system can perform

.Its-intended function.

The proposed addition of ACTION statement 3 6.4.2.c is consistent with the existing ACTION statement for TS 3 6.1.1, PRIMARY CONTAINMENT INTEGRITY.

2. The proposed changes do not create the possibility of a new or different. kind of accident from any accident previously evaluated l because'the proposed changes introduce no new mode of plant 3 j

operation or involve a physical modification to the plant.

3 The proposed changes do not involve a'significant reduction in j the margin of safety because, as previously mentioned in item 1, "

L the changes do not physically modify the plant and does not introduce a new mode of plant operation. These proposed changes

'will. increase the margin of safety because additional controls y not currently specified in the TSs will become TS requirements.

These new TS controls will provide additional assurance that the l

Reactor Building to suppression chamber vacuum relier system can perform its intended function. -]

? Based'on the above, Detroit Edison has determined that the proposed' amendment does not involve a significant hazards. consideration.

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed-Technical Specification j changes against the criteria of 10CFR51.22 for environmental .,

considerations. 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 cumulative occupational radiation exposures. Based on the foregoing, Detroit -l Edison-concludes that the proposed Technical Specificatiens do meet' the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

d)NCLUSION ,

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 compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.

NRC-89-0273, Application for Amend to License NPF-43,changing Tech Specs 3/4.4.7,3/4.6.3,3/4.6.4.2 & Definition 1.29 Re Containment Isolation Valves

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