NRC-91-0080, Requests Withdrawal of 890531 & 900103 Applications for Amend to License NPF-43 Re Emergency Equipment Cooling Water Sys,Reviews Circumstances Leading to Request & Outlines Course of Action to Resolve Any Outstanding TS Issues

Requests Withdrawal of 890531 & 900103 Applications for Amend to License NPF-43 Re Emergency Equipment Cooling Water Sys,Reviews Circumstances Leading to Request & Outlines Course of Action to Resolve Any Outstanding TS Issues

ML20081L802
Person / Time
Site:	Fermi
Issue date:	07/02/1991
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-91-0080, CON-NRC-91-80 NUDOCS 9107080094
Download: ML20081L802 (3)

Text

. . _. . . . .

T W)Hlam S orser Seruer Vice Prescent um b'k['

Detrol [ wo narm om, s g%

^ '"""" ""*'**'

EdLSU^l l "p"o"> ~um' "sm"i operations July 2, 1991 NRC-91-0080 U. S. Nuclear Regulatory Commission Attn: Document Control Deck Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison letter to NRC, NRC-89-0042, dated May 31, 1989

3) Detroit Edison let t er to NRC, NRC-89-0242, dated January 3,1990

4) Detroit Edison let ter to NRC, NRC-87-0244, dated March 10, 1988

Subject:

Withdrawal of Proposed Technical Specification Change - Emergency Equipment Cooling Water System In accordance with 10CFR2.107. Detroit Edison requests that the Reference 2 & 3 operating License amendment applications be withdrawn. The purpose of this letter is to review the circumstances leading to this request and outline Detroit Edison's intendedf course of action to resolve any outstanding Technical Specification . issues concerning the Emergency Equipment Cooling Water (EECW) system.

The central issue being addresced by the proposals in question is that of the appropriate allowed outage time (A0T) for a loss of EECW cooling. Technical Specification (TS) 3.7.1.2 provides a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A0T, af ter which the associated safety-related equipment is to be declared inoperable and the applicable action requirements for the supported equipment followed.

If, through an alternative interpretation of the TS, the action requirements for inoperable supported equipment must be immediately followed then inoperability of an EECW subsystem would require an immediate commencement of plant shutdown. However, Detroit Edis on believes based on the wording of. the TS that this was neither intended nor, as discussed in this letter, is it necessary for safety.

9107080094 910702 /

h a PDR ADOCK 05000341 P PDR t \g 1

t t

USNRC July 2.1991 NRC-91-0080 Page 2 From a safety perspective, there are several aspects to be examined.

First, the. remaining operable equipment (support ed by the operable EECW subsystem) must be suf fe cient for safe shutdown of the plant and to assure the health and safety of the public. In this case, the UFSAR evaluation of ECCS performance with a battery f ailure provides a conservative evaluation which shows that the ECCS meets the 10CFR50.46 acceptance crit eria.

Steps vet be taken to assure that other inoperable systcas/ subsystems do not cxist that would form a compounded situation where continued plant operation for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is not appropriate. Equipment supported by the remaining operable EECW subsystem must not be inoperable without taking the required action for the inoperability of both divisions of supported equipment, or entering TS 3.0.3 if no action exists. Detroit Edison has established administrative controls to assure that these actions, which are commonly referred to as ,

" cross-t rain checking", take place.

Thirdly, actual impact of loss of cooling to the supported equipment can be examined. Supported systems which have more restrictive A0Ts of less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> receive indirect support, such as area cooling.

Thus, the systems retain scoe functionality beyond the immediate complete loss of functionality which must be assumed when specifying A0Ts for supported syst em LCOs.

Two additional generic potential safety concerns have been expressed by the NRC staf f on not applying the supported system action requirements. The first is that the ouc-of-service time of some particular piece of equipment can be artificially extended by combining the two A0Ts involved. The operating philosophy at Fermi 7 is that safety equipment be promptly restored regardless cf the A0T involved. As a result. EECW subsystem outages have generally been of a less than 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> duration. This operating philosophy acts to minimize the potential for these situations becoming a possibility and also acts to prevent any inappropriate A0T extension in the event -that such a possibility would arise.

The second concern is that the supported system action requirements could contain requirements other than A0Ts (such as, system line-up or testing requirements) which may be appropriate for the situation. In this case, EECW supports the Shutdown Cooling Mode of the RHR system.

I The appropriate TS for this function calls for establishing an alternative means of decay heat removal within one hour. Both the Reference 2 and 3 TS proposals and the administrative' controls in place at Fermi 2 recognize that it is not appropriate to delay this action for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Finally, in examining -the appropriateness of e 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A0T. it must be noted that the situation is very similar to that of the c'G's in the

r 1

t USNRC July 2, 1991 NRC-91-0080 Page 3 range of af fect ed equipment. A division of EDG's may la inope r able for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if cross train checks are satisfactorily completed.

The issue of the ECCW TS ACT was identified in 1987. At that time, it was believed tha* to document the basis for not applying the support ed syst em action requirements immediately, a license amendment would be ne ed ed . This 1%J to the Reference 2 through 4 applications.

Over the same time period, extensive discussions between industry and the NRC over the generic implications of this issue have occurred.

The issue is generic since all plants have support system TS and, in addition, several plants have a similar relation between the service water TS requitec,ents and the ECCS TS requirements.

The industry-NRC interaction has confirmed that a TS change rhould be pursued to provide EECW action requirements which more fully address the issues relat ed to a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ACT for EECW. This interaction has also made it clear that additional information will be needed to support the necessary TS change.

De t roi t Edison is therefore proposing to withdraw the pending TS changes on this subject with the intention of submitting a subsequent applicatinn by November 30, 1991. This vill result in a single integrated document for NRC review of this subject.

In the interim, Detroit Edison will use the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ACT for EECW in conjunction with the administrative controls discussed in this letter. Such operation is consistent with the safe and r_' ,_rar operation of the Fermi 2 plant as described above and in the UFSAR.

We welcome tha opportunity tu discuss this item with you at your couvenience. If you have any questions concerning this request, please contact Mr. Glen D. Ohlemacher at (313) 586-4275.

Since rely,

,r ) ,

cc C. E. Ca rpent er, Jr.

A. B. Davis R. W. DeFayet te S. Stasek