NRC-98-0033, Application for Amend to License NPF-43,eliminating Incorrect Descriptive Info Re Water Inventory in CST Reserved for Hpci/Rcic & Raising CST Min Water Level for Core Spray

Application for Amend to License NPF-43,eliminating Incorrect Descriptive Info Re Water Inventory in CST Reserved for Hpci/Rcic & Raising CST Min Water Level for Core Spray

ML20217J524
Person / Time
Site:	Fermi
Issue date:	03/27/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217J530	List: ML20217J544 NRC-98-0033, Application for Amend to License NPF-43,eliminating Incorrect Descriptive Info Re Water Inventory in CST Reserved for Hpci/Rcic & Raising CST Min Water Level for Core Spray
References
CON-NRC-98-0033, CON-NRC-98-33 50-341-97-11, EA-97-479, NUDOCS 9804060322
Download: ML20217J524 (11)

Text

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. - , . Douglas R. Gipum I

. Senior Vice President, Nuclear Generation Fermi 2 i 0400 North Dixie llwy, Newport, Michigan 48166 i l

Tek 313.5S61401 Fax: 313fA6 41~2 Detroit Edison 10CFR50.92 '!

March 27,1998 NRC-98-0033 1

U. S. Nuclear Regulatory Commission I Attention: Document Control Desk Washington D C 20555-0001 '

References:

1) Fermi 2 ,

NRC Docket No. 50-341 l NRC License No. NPF-43

2) Detroit Edison Letter NRC-97-0104," Reply to Notice of Violation 50-341/97011-02," dated November 26,1997

3) NRC Letter EA 97-479,"NRC Engineering and Technical Support Inspection Report 50-341/97011 (DRS) and Notice of Violation," dated October 29,1997

Subject:

Proposed Technical Specification Change (License Amendment) for Volume and Level Reauirements for the Condensate Storace Tank Pursuant to 10CFR50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating License NPF-43, Appendix A, Plant Technical Specifications (TS). In reply to Notice of Violation 50-341/97011-02 (Reference 2), the proposed change eliminates incorrect descriptive information regarding water inventory in the Condensate Storage Tank (CST) reserved for HPCI/RCIC and raises the CST minimum wazer level for Core Spray in TS Sections 3.5.2.a.2.b and 3.5.3.b.3 and TS Bases Section 3/4.5.1 and 3/4.5.2.

Enclosure 1 provides a description and evaluation of the proposed TS change.

Enclosure 2 provides an analysis of the issue of significant hazards consideration using the standards in 10CFR50.92. Enclosure 3 provides marked up pages of the ,

existing TS to show the proposed changes and a typed version of the affected TS pages with the proposed changes incorporated.

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Detroit Edison has reviewed the proposed TS changes against the. criteria of ,  ;

10CFR51.22 for environmental considerations. The proposed changes do not g' g

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USNRC-NRC-98-0033 Page 2

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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 Edison concludes that the proposed TS changes meet the criteria provided in 10CFR51.22(c)(9).

Detroit Edison requests that the NRC approve and issue these changes by February 28,1999, with an implementation period of within 90 days following NRC approval.

Should you have any questions or require additional information, please contact Mr.

- Nonnan K. Peterson of my staff (734) 586-4258.

Sincerely, -

Enclosures cc: A. B. Beach B. L. Burgess G. A. Harris A. J. Kugler Supervisor, Electric Operators, Michigan Public Service Commission l

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I I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which r re true and accurate to the best of my knowledge and belief.

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i DOUGLAS R. GIPSON Senior Vice President, Nuclear Generation On this M _

day of &LCI ,1998 before me personally-appeared Douglas R. Uipscc, being first huly swern and says that he executed the foregoing as his free act and deed.

I Notary Public bnuW i l

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, ' ROSAUE A. ARMETTA '

WOTARY PUBLIC-MONROECOUNTYMi i MYCOMMISSION EXPlRES10/11Al0 .j

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.' Enclosure 1 NRC-98-0033 i

ENCLOSURE 1 FERMI 2 NRC DOCKET NO 50-341 OPERATING LICENSE NPF-43 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

VOLUME AND LEVEL REQUIREMENTS FOR THE CONDENSATE STORAGE TANK DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES i

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,' Enclosure 1 NRC-98-0033 l Page 2 l

DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES DESCRIPTION:

The CST is a 600,000 gallon aluminum tank which provides a source of water for the )

High Pressure Coolant Injection (HPCI), Reactor Core Isolation Cooling (RCIC), i Standby Feedwater (SBFW), Core Spray, Main Condenser Hotwell, and Control Rod l Drive pumps. The HPCI/RCIC pump suction piping is designated Seismic Category f I and the tank and other piping systems are designated non-Category I.

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The HPC1/RCIC pump' suctions are normally aligned to the CST when the systems f are in the standby mode. Since the level in the CST is higher than the highest point {

in the HPCI/RCIC suction and discharge piping, the head in the CST provides the -  !

keep-fill function. Selection of the CST as the initial source of make-up water also j minimizes the frequency of pumping non-reactor quality water into the reactor. In j

order to maintain a Category I suction source for HPC1/RCIC, the pump suction is j transferred to the suppression pool automatically upon a condensate storage tank low i level (equivalent to about 38,000 gallons of water in the tank at the minimum Technical Specification setpoint) or suppression pool high level for HPCI  !

(approximately 2 inches above normal suppression pool water level). The transfer to the suppression pool feature is provided to assure an adequate long-term quantity of r coolant and to control suppression pool level. The CST volume for HPCI/RCIC is not credited in any accident analysis since the suppression pool is the safety-related  !

l source of water for HPCI/RCIC.

Notice of Violation 50-341/97011-02 (Reference 3) identified inaccuracies with Technical Specification (TS) 3.5.3.b.3 and UFSAR Sections 6.3.2.6 and 9.2.6.1 regarding Condensate Storage Tank (CST) water inventories. With respect to TS, Reference 3 states that the TS inaccurately equates 300,000 available gallons of l water (for HPCI/RCIC) in the CST to a level of I 8 feet. A level of 18 feet does not correspond to 300,000 available gallons because the HPCI/RCIC suction line has a c short standpipe (silt protector) that rises 51/4" above the bottom of the tank.

I Because of this silt protector, approximately 7,000 gallons is physically not available for use from the CST. A level of I8 feet actually corresponds to approximately '

293,000 gallons.

Additionally, while investigating this issue, Detroit Edison discovered that the level of 18 feet also appears in TS 3.5.2.a.2.b describing the volume ofwater available for Core Spray. The 18 foot level does not account for the necessary submergence of the Core Spray standpipe, which is required to avoid vortexing/ air entrainment into the Core Spray System.

Core Spray suction is normally aligned to the suppression pool. The suction path from the CST is used primarily for vessel injection testing. It is normally isolated by r.

.I Enclosure 1 J. - NRC-98-0033 lPage 3 a locked closed manual valve since the upstream piping is not safety-related.

However, during plant shutdown conditions, Core Spray can be lined up to CST as a suction source for emergency' core cooling if the suppression pool is unavailable.

. EVALUATION OF THE PROPOSED CHANGES:

Detroit Edison is proposing to revise TS Sections 3.5.2.a.2.b and 3.5.3.b.3 and TS

. Bases Section 3/4.5.1 and 3/4.5.2 to: 1) raise the water level within the CST to assure an adequate water supply for the Core Spray System,2) more appropriately relocate plant system design details such as CST level to volume relationships expressed in units of gallons from TS Sections to the TS Bases Section, and 3) eliminate the incorrect HPCI/RCIC volume description in the footnote to TS Section 3.5.3.b.3 1 since this footnote is discussing operation in Operational Conditions 4 and 5, which 1 does not apply to the steam drivea HPCI/RCIC Systems. An evaluation'of these ~ l changes are provided below:

l Chance to TS Se'e tion 3.5.2.a.2.b:  !

The proposed change increases the 0: quired value of tank level to correspond to 150,000 gallons of water that is physically available for use by the Core Spray i System. The Core Spray suction standpipe height is 8'-10 3/8" and the additional

' tank height corresponding to 150,000 gallons is also 8'-10 3/8". The level above the u Core Spray standpipe necessary to avoid vortexing and air entrainment is l'-2." The  ;

tank level to provide 150,000 usable gallons for Core Spray is the sum of these, j totaling 18'-10 3/4", which is rounded to 18' 11".' The required CST water level for. I Core Spray System is therefore raised to 19 ft.

The requirement expressed in units of gallons for the Core Spray System will also be removed from TS 3.5.2.a.2.b and relocated to the Bases section because these are . l details that relate required CST contained volume to its respective indicated level.

Moving these details of system design to the Bases does not impact the requirement i for maintaining CST volume because this requirement is implemented in equivalent '!

level of feet, which is how the control room measures volume of water. The basis j for the CST volume is that the CST contain enough water to ensure that Core Spray  !

can supp!y at least 150,000 gallons of makeup water to the Reactor Pressure Vessel.

Based upon the above, the proposed changes are acceptable. l Channe to TS Section 3.5.3.b.3:

Similar to the discussion above, the proposed changes to TS Section 3.5.3.b.3 l include raising the water level inside the CST from 18 feet to 19 feet and more j l" appropriately relocating the level to volume relationship to the Bases Section. With respect to the accompanying footnote to TS 3.5.3.b.3, this change is also removing -

discussion of HPCI/RCIC reserve (150,000 gallons) because it does not have any

- meaning for the operability of Core Spray and is not relied on elsewhere for HPC1/RCIC Systems. Since the level to volume relationships as related to Core L j

.' Enclosure 1 NRC-98-0033 Page 4 Spray are being included in the Bases Section (see change to TS Section 3.5.2.a.2.b),

the footnote corresponding to TS 3.5.3.b.3 is removed in its entirety.

As discussed above, the water level inside the CST is raised to include considerations  ;

for air entrainment/vortexing for the Core Spray System. This extension ensures that the minimum volume requirement is met and the total water volume is available for {

use. The level to volume relationship of 300,000 gallons is also more appropriately relocated from ?c TS Section to the Bases Section because it reflects plant specific g design details for CST required volume.

The footnote associated to TS 3.5.3.b.3 contains volume information that is erroneous with respect to HPCI/RCIC water inventory and is proposed that this information be removed. The volume information, which is located in the footnote, {'

is inappropriate becauce Tc 3 4 '; b.3 is discussing flow paths while in Operating Conditions 4 and 5 where CST volume for HPCI/RCIC Systems are not applicable. ,

Since the steam driven HPCI/RCIC systems cannot be used in Operating Conditions j 4 and 5, relative volumes reserved for HPCI/RCIC are irrelevant in this TS. As required by TS 3.5.1 and 3.7.4, the source of water for HPCI/RCIC is the  !

suppression pool.  !

Based on the above, the proposed changes are acceptable.  ;

Chance to the TS Bases Section 3/4.5.1 and 3/4.5.2:

The proposed change includes adding three sentences to the end of the second paragraph of Bases Section 3/4.5.1 and 3/4.5.2, Page B 3/4 5-i. The paragraph states (added sentences are shown underlined),"The CSS is a primary source of emergency core cooling after the r: actor vessel is depressurized and a source for flooding of the core in case of accidental draining. In the case when the reactor is shutdown or suppression pool is unavailable as a source of waterdhe CSS takes suction from the condensate storace tank for core cooline. For this condition. the condensate storace tank nrovides et least 150.000 callons of available water for CSS. This reauires a volume of at least 300.000 callons of water plus marcin to preclude vortex formation for the CSS. eauivalent to a level of at least 19 ft."

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.'. Enclosure 2 NRC-98-0033 ENCLOSURE 2 FERMI 2 NRC DOCKET 50-341 NRC LICENSE NPF-43 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION i

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. Enclosure 2 NRC-98-0033 Page 2 10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION BASIS FOR SIGNIFICANT HAZARDS DETERMINATION:

In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards consideration. The proposed Technical Specification (TS) changes described above do not involve a significant hazards consideration for the following reasons:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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The changes will not affect the performance or reliability of the Condensate

• Storage System which could lead to an accident because the Condensate Storage Tank (CST) is not involved as an initiator of any accident previously evaluated.

The proposed change meets the design standards of the Condensate Storage ,

System by providing assurance that sufficient water volume is available for the Core Spray System. This change also removes erroneous discussion of water l inventory for HPC1/RCIC Systems while in Operating Conditions 4 and 5. The removal ofinformation is acceptable since HPCI/RCIC Systems are not operable in these modes and will therefore not increase the probability of an accident. The increase in volume provides for vortex / air entrainment avoidance in the Core Spray System and will not increase consequences. Furthermore, the elimination  ;

of HPCI/RCIC information will not increase consequences of an accident i previously evaluated because these systems are not credited for accident l

mitigation in Operating Conditions 4 and 5.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change does not add or modify any equipment or components i related to the Condensate Storage System and will therefore not create any new i failure modes or common failure modes. This proposed change raises the water.

level within the CST to ensure sufficient water volume is maintained and updates {

the TS by removing descriptive information with respect to CST water inventory ]

L for HPCI/RCIC Systems while in Operating Conditions 4 and 5. The Condensate  !

Storage System will continue to operate as intended and as designed. This change will therefore not create the possibility of a new or different type of accident.  ;

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3. The change does not involve a significant reduction in the margin of safety.

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The proposed ' change increases the required CST water level to provide at least 150,000 grilons of water available for the Core Spray System while maintaining adequate sub;nergence of the Core Spray standpipe.for avoiding vortex and air entrainment. As such, the proposed change involves no reduction on any margin of safety. Revision to TS Bases concerning discussion of reserve volume in CST fo'r HPCI and RCIC, does not alter the requirement for Core Spray or Suppression Pool operability and does not involve a reduction in any margin of safety.

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

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l l Enclosure 3 NRC-98-0033 I

ENCLOSURE 3 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NPF-43 REQUEST TO REVISE TECHNICAL SPECIFICATIONS VOLUME AND LEVEL REQUIREMENTS FOR TIIE CONDENSATE STORAGE TANK Attached is a mark-up of the existing Technical Specifications (TSs), indicating the proposed changes (Part 1) and a typed version of the TSs incorporating the proposed changes with a list ofincluded pages (Part 2).

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