NRC-88-0225, Application for Amend to License NPF-43,modifying Tech Spec 3/4.7.1.5 Re UHS for Emergency Equipment Cooling Water & Svc Water Sys.Fee Paid

Application for Amend to License NPF-43,modifying Tech Spec 3/4.7.1.5 Re UHS for Emergency Equipment Cooling Water & Svc Water Sys.Fee Paid

ML20155B750
Person / Time
Site:	Fermi
Issue date:	09/30/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20155B754	List: ML20155B755 NRC-88-0225, Application for Amend to License NPF-43,modifying Tech Spec 3/4.7.1.5 Re UHS for Emergency Equipment Cooling Water & Svc Water Sys.Fee Paid
References
CON-NRC-88-0225, CON-NRC-88-225 NUDOCS 8810070058
Download: ML20155B750 (10)

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Septenber 30, 1988 tmC-88-0225 U. S. !Mclear Regulatory Ccrinicslon Attn Docu~cnt Control Dock Wanhington, D. C.

20555 P.eferencect 1) rami 2

!CC Docket No. 50-341

?mC Licence No. !TP-43 2)

Detroit Edicon I cter to imC, IEC-87-0244, "Prorcsed Technical Specification Change (Licence

/ m ndment) - Emergency Equirrent Cooling Water Ritte:u (3/4,7.1.2), Emergency Equi 1 rent Service b'ater ?,yctcra (3/4.7.1.1), and Ultimte Heat Sink (3/4.7.1.5)", dated !breh 10, 1988

Subject:

Prorocal Technical specification Change (Licence trmh'DtL _UltJ N t tilcat_Sj Dh_D/L L L 5}_

rursuant to 10CFR50.93, Introit D31rcn Ccquny hereby proposes to a end Cterating Licence !.TP-43 for the Femi 2 plant by incoqorating the enclosed change into the Plant Technical sprifications. The proporsed change rodifies specification 2/4.7.1.5 for the Ultinute Heat Sink to better reflect the Femi 2 design bares.

Detroit rdicon has evaluated the propascd Technical Egeifiestions against the criteria of 10TR50.92 and detemined that no cignificant lurarda conrideration in involved. The Femi 2 Chsite Revicv Organization has approved and the !bclear Safety Fnview Group has reviewd the proromi Tcdmical Srcx:ifications and concuru with the emlosed determinations, i

l Farsuant to 10CFR170.12(c) enciercd with this amntent request is a check for one hun 3 red iifty dollars (5150.00).

In accordance with 10Crn50.91, Detroit D31ren has provided a aopy of this letter to the State of Michigan, f

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USt&C Septator 30, 1988 imC-88-0225 Page 2 tions, pimo contact Mr. Glen D. Chie:mcher at 13 58 27 Sincerely, 20

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Enclosure cca Mr. A. B. Davis Mr. R. C. Knop Mt. T. R. Quay Mr. W. G. Rc9ers Nmrvisor, Mvanced Planning and Review Section#

Michigan Public Service Ccruission P

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e US!aC Septerter 30, 1988 1mC-88-0225 Page 3 I, B. PMEll SYLVIA, do hereby affim that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge ard belief.

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153VIA Senior Vice President Cn this Yb

. day ofs (ANa / !_8.d,1988, before re t

Mrsonally appared D. Palph Sylvid, being first duly sworn ard says that he executed the foregoirn as his free act ard deed.

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e Enclosure to NRC-88-0225 Page 1 BAGGQH)ALIg11SSIGt The Fermi 2 Ultimate Heat Sink consists of two one-half capacity reinforced-concrete Residual Heat Removal (RHR) reservoirs of Category I construction, each with a capacity of 3,450,000 gallons of water.

The reservoirs are connected by redundant valved lines to permit access to the conbined inventory of the two reservolts to either RHR division in the event of a mechanical failure in one of the RHR divisions. Each line contains two isolation valves of Category I construction that are remotely operable from the main control roan.

The Ultimate Heat Sink is described in UFSAR Section 9.2.5.

Specification 3.7.1.5 of the Fermi 2 Technical Specifications does not adequately address the Ultimate Heat Sink as a single source of water to both RHR divisions. Instead, the Limiting Condition for Operation (ILO) and,TrION requirements are written to inply that each reservoir can independently provide the required heat removal capability for either RHR division. Further, the surveillance requirenents for the system must be modified to be consistent with the Ultimate Heat Sink design bases.

These problems are addressed in the prc;osed Technical Specification changes which are described belew and are attached.

j PIGOSNLTBQMGL.EPECIFICMJGLCHA4. EE The proposed Limiting condition for Operation (Iro) for the Ultinnte Heat Sink is:

3.7.1.5 The Ultimate Heat Sink, comprised of two one-half canacity residual heat removal (RHR) reservoirs with the capability of being cross-connected, shall be OPERABLE with:

a.

A mininum water volume of 2,990,000 gallons in each reservoir (equivalent to an indicated water level of 25 feet or 580 feet elevation).

b.

Amaximumageragewatertemperatureoflessthanor equal to 80 for each reservoir.

c.

At least one OPERABLE coolf.ng tower with two cooling fans for each reservoir.

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l d.

A mininum contined water volume in the two reservoirs l

of 5,980,00 gallons.

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. AB Enclosure to NRC-88-0225 Page 2 A maximum conbined average water temperatuge for the e.

two reservoirs of less than or equal to 80 F.

f.

A minimum averp water temperature of greater than or equal to 41 F for each reservoir.

g.

Two reservoir cross-connect lines, each with two OPEMBLE motor operated cross-connect valves.

The new LCO now clearly indicates that the Ultimate Heat Sink is a single water source consisting of two reservoirs which must be capable of being cross-connected. The APPLICABILI'IY requirements remain unchanged.

The proposed ACTION requirments are:

a.

With one or more of the requirements of Specification 3.7.1.5.a, b, and c not satisfied declare the affected reservoir (s) inoperable and take the ACTION required by

d. or e. below.

I b.

With the conbined water volume requirenent of I

Specification 3.7.1.5.d or the conbined average water i

temperature of specification 3.7.1.5.e not satisfied declare both reservoirs inoperable and take the ACTION required by e. telow, c.

With one or more reservoir cross-connect valves inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> open and de-energize both valves in at least one cross-connect line and verify that these valves remain epen and de-energized at least once per 7 days. The provisions of Specification 3.0.4 are not applicable. Otherwise, declare both reservoirs inoperable and take the ACTION of e. below.

d.

With one reservoir inoperable declare the associated RHRSW system subsystem, EESW system subsystem, and diesel generator cooling water subsysten inoperable and take the i

ACTION required by Specifications 3.7.1.1, 3.7.1.3 and

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3.7.1.4.

e.

With both reservoirs inoperablet 1.

In CPEPATIONAL CotOITIONS 1, 2 or 3, be in at least HOP SHUIDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in CotD SHUTDNN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, l

1 Enclosure to NRC-88-0225 Page 3 2.

In OPERATIONAL 00tOITIONS 4 or 5, declare the RHRSW system, the EESW syst e and the diesel generator cooling water systems inoperable and take the ACTION required by Specifications 3.7.1.1, 3.7.1.3 and 3.7.1.4.

3.

In OPERATIONAL C0tOITION *, declare the diesel generator cooling water systems inoperable and take the ACTION required by Specification 3.7.1.4.

The provisions of Specification 3.0.3 are u t applicable.

f.

With the requirements of Specification 3.7.1.5.f for one or both reservoirs not satisfied, perform a visual inspection of the reservoir (s) at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to verify that no ice han formed. If ice is observed, demonstrate the OPERABILITY of each cafety related punp in the reservoir (s) by running each safety related purrp at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The provisions of Specification 3.0.4 are not applicable.

ACTION a. indicates that a reservoir is inoperable if any of the requirements of Specifications 3.7.1.5.a, b, and c for that reservoir are not satisfied. AcrION b. indicates that both reservoirs are considered inoperable if the conbined water volume or temperature requirments of Specification 3.7.1.5.d and e are not met.

ACTION c. provides ACTION tequirements for inoperable tcservoir cross-connect valves. With one or more inoperable cross-connect valves, operation can continue indefinitely if it is assured that the reservoirs are cross-connected and thus can fulfill the design goals of the Ultimate Heat Sink as a single water source.

ACTION d. provides the ACTION requirements where an individual reservoir is not capable of meeting the requirements to provide cooling for the systems which utilize the reservoir. However, the

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Ultimate Heat Sink as a whole can meet the plants' long term cooling requirements using systems cooled from the rmaining reservoir. These ACTIOtB are consistent with the current ACrIONS for a single inoperable reservoir.

ACTION e. provides the ACTION requirements for situations where the Ultimate Heat Sink as a whole can not meet its intended function. The required ACTIONS are consistent with current AcrION requirments for having both reservoirs inoperable.

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Enclosure to NRC-88-0225 Page 4 ACTIONS d. cnd e. are proposed to be consistent with the editorial change proposed in Reference 2.

This change limited the listing of affected equipnent to those directly cooled by the systen in question.

ACTION f. reiterates the existing ACTION provisions for low temperature in one or both reservoirs. The provision to exclude this AcrION from the provisions of Specification 3.0.4 has been added.

This exclusion is further discussed below.

The proposed Surveillance Requirements are:

4.7.1.5 The Ultimate Heat Sink shall be determined OPERABLE at least once per:

a.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the individual and conbined reservoir average water tarporature and water volume to be within their limits, b.

31 days by:

1.

Starting each cooling tower fan from the control room and operating the fan on slow speed and on fast speed,* each for at least 15 minttes.

2.

For each electrical division of cross-connect valves, verify at least one valve in the division is open.

c.

92 days by cycling each reservoir cross-connect valve through at least one cycle of rull travel.

• Fast speed necd not be test d during icing periods.

Specification 4.7.1.5.a is editorially modified to indicate that water volume is to be verified daily versus water level. Further, individual reservoir terrporatures and both crmbined and individual reservoir volum nust be verified. This is to be consistent with the modified LCO.

The Fermi 2 Ultinate Heat Sink is divided into two one-half capacity reservoirs in otdor to minimize the impact of a below grade breach of the reservoir structure (UPSAR Section 9.2.5.3.2). Detroit Edison believes that this event is extranely unlikely. Further, the loss of water is limited by the site ground water level. Since approximately 90 percent of the RHR reservoir capacity is located below the ground water level, the consequences of the below grade structural breach has not significantly changed. Detroit Edison therefore believes that

Enclosure to NRC-88-0225 Page 5 the marginal benefit of tequiring that the reservoirs be maintained not cross-connected is not merited in view of the additional emplexity this would entail. However, for the reasons set forth I

above, the normal system line-up is to maintain the two reservoirs not cross-connected. Therefore, this Specification is written to allow opnration with the reservoirs either cross-connected or not cross-connected. Surveillance requirenent 4.7.1.5.b.2 ensures that the reservoirs can be cross-connected in the event of a failure of one division of electrical power.

As AcrIONS c. and f. allow plant operation for an unlimited period of 3

time, a provision is included to exclude these ACTIONS from the provisions of Specification 3.0.4.

'Ihis is consistent with guidance provided by the NRC staff in Generic Letter 87-09.

When one or more of the cross-tie valves are inoperable the Ultimate Heat Sink remain 3 OPERABLE (as discussed above) as long as the two reservoirs are cross-connected as required by ACTION c.

Further, the cross-connect valves are located near the bottcm of the RHR reservoir I

and potentially present an unusual di4ficulty for repair.

In view of these circumstances, Detroit Edison believes that a change in OPERATIONAL CCt0ITION should be allowed when operating under the provisions of ACTION c.

When a reservoir temprature is less than 41 F, ACTION f allows continued operation provided that compensatory ACTION is taken to assure that the Ultimate Heat Sink OPERABILITY is not degraded due to potential ice formation. Detroit Edison believes that restricting changes in OPERATIONAL COtOITION when operating under the provision of ACPION f. is not warranted since acceptable means of assuring that the Ultimate Heat Sink remains OPERABLE exists in Technical Specifications.

In light of these compensatory AcrIONS taken to ensure OPERABILITY, and the guidance of Generic Letter 87-09, Detroit Edison is proposing that Specification 3.0.4 not apply to ACTION f.

SlDUFlfANr_IIMN06_CCt63DfBMJQi In accerdance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this detemination, Detroit Edison must establish that op ration in accordance with the proposed amendment would not: 1) involve a significant increase in the prcbability 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.

Enclosure to 4

NRC-88-0225 Page 6 The proposed change to modify the Ultimate Heat Sink Technical Specification provisions to better reflect the plant design bases do not:

1)

Involve a significant increase in the probability or consequence i

of.an accident previously evaluate 3.

The changes act to provide i

greater assurance that the Ultimate Heat Sink is available by providing provisions appropriate for its design as a single water source. By allowing unlimited operation with the reservoirs cross-connected the change acts to increase the consequences of a below grade breach of the Category I RHR reservoir structure.

This is because the level of both reservoirs instead of one reservoir would equalize with the site ground water level.

I However, since 90 percent of the reservoir capacity is below the l

ground rater level the resultant impact on the ability of the RHR 1

reservoirs to supply a 30-day coolinJ capacity is not judged to be significant. Further, adequate time for compensatory measures for any such breach is likely to be available since the rapid reservoir level decrease woald be easily detectable.

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2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not iaodify plant design. The change allows unlimited operation with the reservoirs cross-connected where currently a not cross-connected line-up is implied by the Iro requirment of two idependent reservoirs. Cross-connected operation does not create a new accident mode since cross-connecting the reservoirs is pre-establishing the conditions necessary for each PHR division to access the full capacity of the Ultimate Heat Sink. Thus, no new 1

mode of failure of the Ultimate Heat Sink is created.

3)

Involve a significant reduction in a margin of safety. By providing provisions appropriate to the design of the Ultimate Heat Sink the change acts to increase the margin of safety by reducing the possibility of inappropriate system operation.

The proposed change to exclude ACTIONS which allow continued operation for an unlimited time period frca the provisions of Specification 3.0.4 do not:

1)

Involve a significant increase in the probability or consequence of an accident previously evaluated. The change allows entry into an OPERATIONAL CONDITION where, if the situation covered by the ACTION wre to occur while in the OPERATIONAL CONDITION, operation for an unlimited time would be allowed. As the measures called for by the ACTIONS provide equivalent assurance that the Ultimate 4

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Enclosure to NRC-88-0225 Page 7 Heat Sink can perform its intended functions, the probability and consequences of any previously evaluated accident is not changed.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not modify plant design or operation and therefore creates no new accident modes.

3)

Involve a significant reduction in a margin of safety. The change allows power increases, by allowing OPERATIONAL CONDITION changes, which previously would have been prohibited until the situation causing the need for the AcrION was rectified.

In these cases, however, the conpensatory measures of the AcrION requirenents provide equivalent assurance that the Ultimate Heat Sink can perform its intended functions. Thus, the safety margin is maintained, l

Based on the above reasoning, Detroit Edison has determined that the proposed amendment does not involve a signifJeant hazards consideration.

M BCT Detroit Edison has reviewed the proposed Technical Specification 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 Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

CCHCIWlM Based on the evaluations 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 eccpliance with the Ccanission's regulations aid proposed amendments will not be inimical to the connon defence and security or i

to the health and safety of the public.

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