NRC-88-0031, Application for Amend to License NPF-43,deleting Requirement to Perform 10CFR50,App J Type C Leakage Testing on RHR Shutdown Cooling Inboard Isolation Valves.Related Info Encl. Fee Paid

Application for Amend to License NPF-43,deleting Requirement to Perform 10CFR50,App J Type C Leakage Testing on RHR Shutdown Cooling Inboard Isolation Valves.Related Info Encl. Fee Paid

ML20196C363
Person / Time
Site:	Fermi
Issue date:	02/10/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196C371	List: ML20196C425 NRC-88-0031, Application for Amend to License NPF-43,deleting Requirement to Perform 10CFR50,App J Type C Leakage Testing on RHR Shutdown Cooling Inboard Isolation Valves.Related Info Encl. Fee Paid
References
CON-NRC-88-0031, CON-NRC-88-31 NUDOCS 8802160084
Download: ML20196C363 (10)

Text

- __-

e*

B. Rfph Sytvin Group vice Fresident Detrol!

6400 North Dme Hi Edisonta=

ghway February 10, 1988 frC-88-0031 U. S. tbclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Pafererce:

Fermi 2 NIC Docket tb. 50-341 tHC License No. tPF-43

Subject:

Proposed Technical Specification (License Anendment)

Chance - Primary Containment Isolation Valves (3/4.6.3)

Pursuant to 10CFR50.90, Detroit Edison Conpany hereby proposes to amed Operating License IPF-43 for the Fermi 2 plant by incorporating the enclosed changes into Technical Specification 3/4.6.3 Primary Containnent Isolation Valves. The proposed change deletes the requirement to perform lOTR50 AppeMix J Type C leakage testing on the Residual Heat Removal Shutdown Cooling inboard isolation valves.

Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Chsite Review organization has approved ard the teclear Safety Review Group has reviewed these proposed Technical Specification changes and concurs with the erclosed determinations.

Pursuant to ICCFR170.12(c), enclosed with this ameMment is a check for one hundred fif ty dollars ($150.00). In a:cordance with ICCFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

Detroit Elison anticipates that the circumstances expected during the upcoming Local Leak Rate Test outage scheduled for March 1988 will require this amendtrent. Therefore, your pronpt consideration of this proposal is requested.

j pool

$BS22885SS8*h c)e6 P

go f

)

J. ',.

. g y.

USNPC=

February 10, 1988

...'l NIC-88-0031

[

Page 2

't j

t

j

,t'

}!

i 5

-c If you have any questions,:pleve conta:t Mr. Glen Ohlemacher.at (313)

.i ~;

586-4275.

(

d Sincerely;

'D T

Enclosures cc: A. B. Davis E. G. Greenman T. R. Cuay 4

W. G. Rogers Supervisor, Advanced Planning and Review Section

~

Michigan Public Service Comission

\\

s

/.

d F

l

\\

l

,i i

t

.)

1 q

AI j

\\

i e-e-g

-t,, -

ww

-r y,

=

4.r.e-<

2 wy

-pr'.

-t 6

r w,

my-

+w-e W

')

,,t w

j. '

th US!E.;je-6 A-February 10, 1988.

~

IE-88-0031 M

. PaJ. e 3 a

7 y

0 l 1.,

I l #f -

~

I, B.- PALPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circustances which are true and x: curate to the best of my knowledge and belief, i

t i

I a

N]?

)

+

B. FAL9fi SYI>ffA Grcup Vic[ President On this M

day of dhaw __,1988, before me l

personally appeared B. Ralph Sylvia, being first duly swc,rn ami cays that he executed the foregoing as his free act'and deed.

I I

i MLL

%s

/M' Notary Pubiid l

Patricia Lyme Rcherts tbtary Nblic, Wyne Omty, if My Ommission Dcpires Jan. 20, 1992 i

(kting in &nroe County, tichigan) i h

'i

-Enclosur$ to NIC 0031 '

Page i BACKGR00tOA)TECUSSTQ.!

Technical Specification Table 3.6.3-1, "Primary Containment Icolation valves," is being revised to delete the requiremnt to Type C tast the Residual Heat Removal (RHR) Shutdown Cooling inboard isolation valves. Since the RHR system is considered a closed system ootsido containmnt, only one isolation valve is required. The basis for this change is discussed below.

General Design Critoria (CDC) 55, "Romtor Coolant Preocure Bourdary Penetrating Containment," defines the isolation requirements for systems which penetrate the primary rea: tor containment ed are part of the reactor coolant pressure boundary. CDC 55, however, allows other isolation provisions if it can be demonstratcd that the containment isolation provisions are acceptable on some other defined basis. The following discussion defines the "other defined basis" for primary <:ontainment penetration X-12 which ircludes valves Ell-F009, Ell-F608, Ell-F008, and Ell-F408 (see attached figure).

The Ecsidual Heat Remaval System (RHR) is an engineered safety feature (ESP) which provides emergency core cooling in the event of a design basis accident. The system is a closed system outside containment and meets the requirements of ANS-56.2, "Contairment Isolation Provicions for Fluid Systems," (see also UFSAR Sections 6.2.4.2.1 aM

6. 2. 4.2.2.3.1) :

1. The system does not cormunicate with the outside atmosphere;

2. Meets Safety Class 2 design requirements;

3. Is able to withstand tenperatures and internal pressures which are auch greater than containrr.ent design pressure;

4. Can withstand loss-or'-coolant accident temsient ard environmental conditions (all four containnent penetration valves are normally closed are are not needed to mitigate LOCA/HELB);

5. Meets Seismic Category I design requirements; l

6. Is protected against overpressure from thermal expansion when isolated (discharge from the relief valves is piped back to the-primary containment); and,

7. Is protected against high energy line breaks outside the containment.

The piping between containmenc penetration X-12 and vahe Ell-F008 meets the requiremnts of ANS-56.2. The penetration is a fluod heai design which includes a guard pipe and penetration sleeve. The pipe penetration is designed for peak transient corxlitions expected during a LCCA and will withsterl or is shielded from the forces caused by inpingenent of f2uid from the rupture of the largest local pipe or t

Enclosure to hT-88-0031 Page 2 connection (see UFSAR Section 6.2.1.2.1. 4). The piping has been designed to specific stress criteria to preclude any possibility of a pipe break.

The outboard isolation valve (Ell-F008) is located approxinately one foot from the penetration asseably. The penetration asseably and valve are connected by a one foot section of Schdule 60 pipe. The penetration aM this section of piping outside containmnt are located in an area which does not contain any high energy piping systems.

The effects of high energy pipe breaks (HEIB) have been analyzed aM the results documented in UFSAR Section 3.6, "Protcction Against Dynamic Effects Associated With the Postulated Ripture of Piping.'

Penetration X-12 is unaffected by_ any analyzed pipe break. In Mdition, al? four containnent penetration valves are closed during power operacion. During plant shutdown, the appr >priate conbination of valves is opened to enter the shutdown cooling node of the RHR system.

For closed systems outside containnent which are also ESP systerns, one isolation barrier is required after the occurrence of a single active failure (ANS-56.2). For the RHR system, the active isolatiw carrier in the shutdown cooling suction piping should be the Ell-F008 valve, The recond isolation barrier is the piping and corponents of the PER system itself. Thus, the inboard valves Ell-F009, Ell-F609 aM Ell-F408 are not required to be Type C leak testcd.

Although the inboard isolation valves will no Jonger be Type C leak tested as containment isolation valves, they will be testcd aM nonitored in accordance with other leakage nonitoring programs.

The RHR system is nonitorcd for leakage in recordance with the Fermi 2 Icakage Reduction Program. This program is required by Technical Specification 6.8.5 ard requires neasuring and recording any leakage from the system and its conponents dur%g operation in various operating configurations. As a mininum, the program is perforced at least once per refueling cycle.

l Tn addition, the penetration valves Ell-F009, E11-F608 ard E1.1-F008 1

are leak tested as reactor coolant cystem pressure isolation valves in Tcordarce with 'Ibchnical Specif'. cation 4.4.3.2.2.

This testing requires pressurizing the valves to 1040 110 psig with water and reasuring valve seat leakage. Valve leakage is limited to 1 gpm per valve. This leakage is not included in the limits specified in 107R50 Appendix J for containment isolation valves, l

i I

Enclosure to NIC-88-0031 Page 3 Containmnt isolation valve Ell-F008 is Type C leak rate tested in accordance with the requiremnts and limits of ICCFR50, AppeMix J.

11ENUCAL SPECIFICMT0r: CENGES The Fermi 2 Technical Specifications should be nrdified to include a reference to Primary Containmnt Isolation Valves Table Notation "(r)"

in Table 3.6.3-1 (see proposed page changes) for RHR valves Ell-F009, Ell-F608 ard Ell-F408. This proposed change will eliminate the.

requirement to perform 10CFR50 Apperdix J Type C leakage testing. Per USFAR Section 6.2.4.2.2.3.1, the RHR system is a closed-loop system outside the containment. This system can mcommodate a single mtive failure and still maintain containment integrity. It is designed to Category I standards, is classified as Quality Group B, ard will maintain its integrity should the containment experience its design tenperature and pressure transient. A single isolation valve, Ell-F008 is used outside the containment to provide contaLvnent isolation.

f SIGNTFTCANP MEAIDS CCMSTDERATION In accordance with 10CFR50.92, Detroit Micon has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit dison nust establish that operation in accordance with the proposed anendment would not: 1) involve a significant inocease in the probability or consequences of an meldent previously evaluated, or 2) create the possibility of a new or different kird of accident from any accident previously evaluated, or, 3) involve a significant reduction in a margin of safety.

1) The proposed change to eliminate the requirement to perform i

1(CFR50 Appendix J Type C leakage testing does not involve a significant increcse in the probability or consequerces of an mcident previously evaluated. The RHR system is a closed system 1

outside the containment and mets the requirmentn of ANC-56.2, Containment Isolation Provisions for Fluid System 3, for closed systems (refer also to UFSAR Sections 6.2.4.2.1 aM 6.2. 4.2.2.3.1). For closed systems outside containment, which are also EFF cystena, one isolation barrier is required after the i

occurrence of a single active failure (ANS-56.2). For the RHR system, the zctive isolation barrier in tt.e shutdown cooling suction piping should be the E11-F008 valve. The sacord 1. solation barrier is the piping and conponents of the PER system itself.

This design is an meeptat.le alternative to G3C 55(4) dich j

l

Enclosure to tmC-88-0031 Page 4 requires two isolation barriers consisting of one automatic isolation valve inside and one automatic isolation valve outside containmnt. The proposed change to eliminate the requirenents to perform Type C leakage testing 1s consistent with the requirenents of (DC 55. The inboard isolation valves (Ell-F608, Ell-F009 aM Ell-F008) are periodically tested ard nonitored in accordance with Technical Specification 4.4.3.2.2 (Reactor Coolant System Pressure Isolation valve Testing) and the system outside containant is -

nonitored for leakage in accordance with Technical Specification 6.8.5 (Ieakage Reduction Program). The reduction in testing therefore does not significantly increme the probability or consequences of an a:cident previously evaluated.

2) The proposed change to eliminate the requirement to pecform 10CFR50 AppeMix J Type C leakage testing does not create the possibility of a new or different kird of accident, from any accident previously evaluated.- As discussed in 1) above, this change meets the intent of General Design Criteria 55. The requested change does not result in any modifications to the plant or system operation and no safety-relatei equipment or function is altered. The requested change does not result in or create any new accident modes.

3) The proposed change to eliminate the requirement to perform 10CFR50 Appendix J Type C leakage testing does not involve a significant reduction in a margin of safety. The ability of the primary containment to perform its safety function is unchanged by this Technical Specification change. These valves are part of the Section XI valve TSI Program and are leak tested as described in 1 above. Their closure times are also nonitored as part of this program. The RHR system will be operating post a:cident at a pressure greater than containment design pressure, whether in suppression pool cooling mode, coolant injection mode, or decay i

heat removal (shutdown cooling) mode. 'niese valves are normally closed aM are not relied on to mitigate a LOCA/HELB accident.

Therefore, there is no significant reduction in the margin of safety.

Based upon the above reasoning, Detroit Edison has determined that the prcposed amerdment does not involve a significant hazards consideration.

MmOPOENmL TMPACT Detroit niison has reviewed the proposed Technical Specification changen against the criteria of ICCFR51.22 for environnental i

l

Enclosure to.

i NIC-88-0031 Page 5 l

considerations. - As shown above, the proposed change does not involve a significant hazards consideration, nor significmtly change the types or significantly increase the amounts of effluents that may be

+

released offeite, nor significantly increase individual or cunulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes the proposed Technical Specifications do neet the criteria given in 1CCFR51.22(c) (9) for a categorical exclusion from the requirenent for an Environmental Inpact Statenent.

l CGCLUSICM Based on the evaluations above:

(1) there is remonable assurece 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 conplianco with the comicsion's regulations and propoced i

anendaents will nos be inimical to the connon defense and security or to the health and safety of the public.

The change requested herein has been determined not to involve a Significant Hazards consideration as the change is consistent with the requirements of CDC 55.

I i

1 e

1

,,h

,4M_,

3 4

A e_2.-.-4.w-...6eu*u 4m m-

&he-_me s-_.

a a

-,-,h..

w e

9 t

I

)

b i

l i

r P

i i

1 l

1

?

.i I

I i

FIGUIE 1 1

e r

f i

i L

l I

s

'l l

f.

1 o

1 I

I J

)

J I

1 i

(

l e

I

.I l

i

I Penetration X-12 TV OUTSIDE i INSIDE I L I

M0 MO TB FROM REACTOR RI R c

puses' E1150F008

'<t TB 7'

r 7 FN RECIRCULATION va-2oso E1150F009 p,,,yo 20' TB Tc so

+

- TC tv mTm i

3/4" 7 '

l 150F608 q hE1100F408 vs-3875 TV l

.-,.m--,--w-e

.,.,,,y,_,ym.__-,-,

.,__,_,.y_

.ww.p.

e-e.,,,

w- -,. w p > - - -

-