NRC-98-0034, Application for Amend to License NPF-43,revising Footnote Specifying Conditions Where Isolation Valves Associated W/ LPCI Sys Operation Are Repositioned

Application for Amend to License NPF-43,revising Footnote Specifying Conditions Where Isolation Valves Associated W/ LPCI Sys Operation Are Repositioned

ML20217J568
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
ML20217J574	List: ML20217J584 NRC-98-0034, Application for Amend to License NPF-43,revising Footnote Specifying Conditions Where Isolation Valves Associated W/ LPCI Sys Operation Are Repositioned
References
CON-NRC-98-0034, CON-NRC-98-34 NUDOCS 9804060329
Download: ML20217J568 (11)

Text

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.: Douglas R. Gipson

, Senior Vice President, Nudear Generation Fermi 2 6400 North Dixie llwy., Newport, Michigan 48166 Tel: 313.586.5201 Fax 313.586.4172 Detroit Mison 10CFR50.92 March 27,1998 NRC-98-0034 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

Reference:

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

Subject:

Proposed Technical Specification Change to Amend the Footnote for Limitine Condition for Operation 3.5.1 and 3.5.2 '

Pm suant to 10CFR50.90, the Detroit Edison Company hereby proposes to amend the Fermi 2 Plant Operating License NPF-43, Appendix A, Technical Specifications (TS), by revising the footnote specifying conditions where isolation valves ansociated with the Low Pressure Coolant Injection (LPCI) system operation are re positioned. The proposed revision clarifies a footnote in the TS. The clarification -

involves Residual Heat Removal (RHR)/ Shutdown Cooling (SDC) system operation.

The TS footnote acknowledges operator action to manually open the RHR suction valves El1-F004A, C or B, D to the suppression pool after the receipt of a LPCI signal. The footnote does not anticipate the additional operator actions required to realign the LPCI system in the event of an automatic SDC isolation on low reactor

- water level which would be expected to occur prior to LPCI initiation.

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 of 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.

Detroit Edison has reviewed the proposed TS change 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 - n significantly increase individual or cumulative occupational radiation exposures.

Based on the foregoing, Detroit Edison concludes that the proposed TS changes meet 9904060329 990327 PDR ADOCK 05000341 P. PDR b. AIrrE Energy Company

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NRC-98-0034 Page 2 i the criteria provided in 10CFR51.22.c (9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

The Fermi 2 Onsite Review Organization has reviewed and recommended approval of the proposed TS change. The Nuclear Safety Review Group has reviewed the proposed TS change and concurs with the enclosed determinations.

Detroit Edison requests that the NRC approve and issue these changes by June 30,1998 with an implementation period of within 90 days following NRC approval. The requested approval date will permit implementation prior to the next Fermi 2 refueling outage, the next planned occasion when the conditions addressed by the proposed change are encountered. Although this proposed change is encompassed by conversion to the Improved Standard Technical Specifications -

(ISTS), the ISTS conversion for Fermi 2 will not be completed prior to the next refueling outage.

Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (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

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

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l DOUGLAS R. GIPSON l Senior Vice President, Nuclear Generation

'I On this day of 4014 .1998 before me personally appeared Douglas R. Gipson, being first duly sworn and says that he executed the foregoing as his free act and deed.

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, Enclosure I to

"'RC-98-0034 ENCLOSURE 1 FERMI 2 NRC DOCKET NO. 50-341 NRC LICENSE NO. NPF-43 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

OPERATOR ACTION TO INITIATE LOW PRESSURE COOLANT INJECTION SYSTEM OPERATION FROM RESIDUAL HEAT REMOVAL SHUTDOWN COOLING OPERATION DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES l

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NRC-98-0034 Page 2

' DESCRIPTION AND EVALUATION OF '

THE PROPOSED CHANGES -

DESCRIPTION: .

o The purpose of this proposed license amendment is to modify the Fermi 2 Operating License NPF-43, Emergency Core Cooling System (ECCS) - OPERATING and SHUTDOWN, Technical Specifications (TS) 3.5.1 and 3.5.2 Limiting Condition fbr Operation (LCO) footnotes to clarify the existing TS footnotes and associated E BASES 3.5.1 and 3.5.2. The clarification involves conditions permitted _by TS

, during OPERATIONAL CONDITIONS 3 (HOT SHUTDOWN),4 (COLD l

SHUTDOWN), and 5 (REFUELING) where operator action would be required for L

initiation of the Low Pressure Coolant Injection (LPCI) system for the loop operating - l in Residual Heat Removal (RHR) Shutdown Cooling (SDC) mode. 1 l TS 3.5.1/3.5.2 requires LPCI consisting of subsystems each comprised of:

L 1. Two pumps, and

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2. ' Operable flow path capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.

A footnote regarding the flow path acknowledges that manual operator action is L required to realign the suction path if LPCI is to operate from RHR SDC mode per _ i TS 3.4.9.1 or 3.4.9.2.

L RHR SDC has provisions for auto isolation on low reactor water (i.e., level 3) or

= high reactor pressure. If the system isolates on decreasing level (since level 3 is not as low as level 1) before LPCI initiates, the SDC suction and injection valves (i. e., .

, ElIF008,9,15A and B) close, and pumps trip on loss of suction path. The LPCI  ;

' loop pumps which are lined up in standby mode are not alTected. '

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If the system is operating in SDC mode and LPCI injection is necessary due to low

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reactor water level, additional operator actions are necessary to reset the SDC'.

i isolation and reset pump trips which occur with the isolation of the suction path. The j LPCI injection valves' logic must be reset for the loop in SDC and the loop in LPCI

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standby mode using the divisional push buttons in the control room. The isolation of ~

the SDC suction valves causes the operating pump to trip, and therefore, the control switch needs to be reset for starting any RHR pumps that were aligned for SDC.

The proposed amendment to the TS 3.5.1 and 3.5.2 is to revise the footnote for the actions required when the LPCI system is manually realigned from the control room  ;

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l. ' (i.e., remote manual) after receipt of a low reactor water level (i.e., level 3) isolation i o

. Enclosure I to NRC-98-0034 Page 3 in SDC while in OPERATIONAL CONDITIONS 3,4, and 5. TS 3.5.1 and 3.5.2 footnote allows operator action to manually realign the suppression pool division 1 and 2 RHR LPCI suction path after receipt of the SDC isolation signal. Additional required actions ofclosing the associated SDC supply valve (s) (i.e., El1F006A, B, C, or D), resetting the LPCI injection valve logic, and resetting the RHR pump trips is included in the proposed change for the TS footnotes. All of these actions are accomplished in the control room.

The current TS only provides an avenue to realign the selected RHR LPCI suction path. The proposed change corrects this deficiency by modifying the "** *" and "**"

footnotes to TS 3.5.1 and 3.5.2, respectively. Specifically, the footnotes are modified to permit the required operator action to realign the system. This corrects the problem encountered when SDC is operating and the operability of the LPCI system is in question due to nomial plant operation.

This TS wording is corrected by the Improved Standard Technical Specifications (ISTS), NUREG-1433, Revision.1, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision 1, dated April 1995. The proposed change is j consistent with the ISTS.

Additionally, TS 3.5.1 Anolicability: OPERATIONAL CONDITION 3* **,is being revised to correct a typographical error where 3* *

• should be 3***. g EVALUATION OF THE PROPOSED CHANGE:

1 The RHR system has multiple operating modes. The two operating modes discussed in this evaluation are SDC and LPCI.

SDC is started manually after the reactor pressure has been reduced by the discharge -

of steam from the Reactor Pressure Vessel (RPV) to a pressure that will not result in over pressurization of the RHR components and piping. The SDC provides the a transfer of reactor core decay heat and reactor primary system sensible heat to Residual Heat Removal Service Water (RHRSW) in order to permit cooldown. The

] i RHR SDC suction path draws water from the Reactor Recirculation (RR) "B" loop via the RHR suction valves El1-F008 and F009, common to both division 1 and 2.

One of the LPCI inboard injection valves (El1-F015A and F015B), closed during the LPCI standby mode, is opened during SDC mode to complete the return path to the

. RPV. The SDC suction and injection valves close automatically for RHR SDC isolation if RPV level decreases to level 3 or high RPV pressure is detec" )

All SDC evolutions are performed when RPV level is well above lev.d 3. The RPV level 3 isolation signal in SDC may indicate an RPV drain problem. Because SDC  !

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NRC-98-Ous4 Page 4'

. could be causing the reduction of RPV water level, automatic vessel isolation is the most conservative action in SDC.

The current TS Limiting Condition For Operation (LCO) 3.5.1 and 3.5.2 footnote and Bases do not fully discuss the actions required to support the plant's SDC design. The LPCI suction path on loops aligned for SDC are realigned manually after a SDC system isolation by closing the SDC pump suction valves (EllF006A,-

B, C, or D) and opening the suppression pool suction isolation valves (ElIF004A, B, C or D). The selected (based on LPCI loop select) LPCI injection valve is given permissive to open automatically when the SDC isolation logic is reset after a SDC isolation. The F015 reset push button and suction valves control switches are located on the same divisional control room panel. The additional action to reset the LPCI injection valve logic is of minor consequence because the reset push buttons of the division 1 and 2 subsystems respectively, are located in close proximity to _the control switches. The switches are easily accessible to the operators and the action can b'e taken in an expeditious manner per procedure. The non-operating RHR loop,

. if aligned for LPCI, already has the suction valves in the correct position. This loop only requires that the El1-F015A or B logic be reset. A pump trip would occur for )

any pump that had its suction path isolated. The pump control switch would have to . j be taken to the off/ reset position and placed in RUN once a suction flow path is aligned.

The bases for this design is that at reduced RPV pressures and decay heat levels, a ~

reduced complement of ECCS subsystems provides the required core cooling - l allowing for the operation of RHR SDC when necessary. The changes proposed in

.this TS Amendment are consistent with those of other plants (e.g., Duane Arnold, .

Amendment 200) and with the standard General Electric design for ECCS. I 4

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. Enclosure 2 to NRC-98-0034

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I l ENCLOSURE 2 i

FERMI 2 NRC DOCKET NO. 50-341 NRC LICENSE NO. NPF-43 1

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10CFR50.92 EVALUATION 1

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. . Enclosure 2 to NRC-98-0034 Page 2 10CFR50.92 EVALUATION BASIS FOR SIGNIFICANT HAZARDS DETERMINATION The proposed Technical Specification (TS) changes described in Enclosure 1 do not involve a significant hazards consideration for the following reasons: j 1.- The proposed change does not involve a significant increase in the probability or .

consequences ofan accident previously evaluated.

The changes involve actions required to realign the Low Pressure Coolant Injection (LPCI) system for LPCI injection if LPCI is required when operating -

in the Shutdown Cdoling (SDC) mode. The additional actions described involve -

resetting isolations and trips which could occur prior to LPCI initiation.

Resetting these logics does not initiate any valve operation or pump start; the LPCI initiation signals and interlocks remain in control of valve and pump logic.

The equipment interlocks that provide the isolation signal for the LPCI injection valves were designed to prevent drain down of the Reactor Pressure Vessel -

(RPV) when in SDC. The injection valve closure is the most conservative action in response to an RPV drain event. The current TS acknowledges that operator action to realign the suction path is necessary. The proposed change acknowledges that operator action to reset injection valve logic and pump trips is necessary. The time required to realign LPCI is not significantly different than the existing actions to realign the suction path.

No changes in either system design or operating strategies will be made as a result of these changes, thus no opportunity exists to increase the probability or consequences of a previously analyzed accident. Therefore, the proposed '

' change does not involve a significant increase in the probability or consequences of a previously evaluated accident.

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

1 The rnanual realignment of the LPCI system from SDC following an isolation

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. signal does not affect the accident analysis described in Chapter 15 of the L UFSAR. No new limiting single failure has been identified as a result of the proposed changes. The possibility of a new or different kind of accident from those previously analyzed will not be created by the change to the TS footnote or Bases, because the proposed change merely clarifies the actions necessary to realign the LPCI system. The time required to realign the system is not 3

significantly different than the time necessary to realign the suction path. .

Therefore, no new or different types of failures or accident initiators are l 3

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NRC-98-0034 Page 3 -

introduced by the proposed changes.

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

The proposed change described above affects the plant's ability to enter Operational Conditions 3,4 and 5, and to achieve and maintain COLD SHUTDOWN conditions when shutting down the plant. The proposed change in combination with existing restrictions within the TS provide assurance that there -

is no credible mechanism to inhibit running the LPCI system.: The minor additional operator action required to realign LPCI from SDC requires minimum time and effort considering controls for each division are located on their respective control panel. As a result of this change, there will be no changes in either system design or operating strategies because the proposed changes merely.

clarify existing TS requirements and actions necessary to meet TS requirements.

Therefore, the proposed change does not involve a significant reduction in a ,

I margin of safety.

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, Enclosure 3 to NRC-98-0034 ENCLOSURE 3 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NPF-43 REQUEST TO REVISE TECHNICAL SPECIFICATIONS TECHNICAL SPECIFICATION CHANGE j

Attached is a mark-up of the existing Technical Specifications (TS), indicating the proposed changes (Part 1) and a typed version of the TS incorporating the proposed changes with a list ofincluded pages (Part 2).

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