NRC-07-0047, Transmittal of Revised Technical Specifications (TS) Pages for Use with the Application to Add an Action Statement for Two Inoperable Control Center Air Conditioning Subsystems in TS 3.7.4

Transmittal of Revised Technical Specifications (TS) Pages for Use with the Application to Add an Action Statement for Two Inoperable Control Center Air Conditioning Subsystems in TS 3.7.4

ML072620127
Person / Time
Site:	Fermi
Issue date:	09/11/2007
From:	Plona J Detroit Edison
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-07-0047, TSTF-477, Rev 3
Download: ML072620127 (16)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport. MI 48166 Tel: 734.586.5910 Fax: 734..586.4172 Detroit Edison A DTE Energy Company 10 CFR 50.90 September 11, 2007 NRC-07-0047 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 Docket No. 50-34 1 License No. NPF-43

2) Detroit Edison Letter to NRC, "Application for Technical Specification Change (TSTF-477) to Add an Action Statement for Two Inoperable Control Center Air Conditioning Subsystems to Technical Specification 3.7.4 Using the Consolidated Line Item Improvement Process," NRC-07-0030, dated June 12, 2007

Subject:

Transmittal of Revised Technical Specifications (TS) Pages for Use with the Application to Add an Action Statement for Two Inoperable Control Center Air Conditioning Subsystems in TS 3.7.4 In Reference 2, Detroit Edison requested NRC approval of a proposed change to Technical Specification (TS) 3.7.4, "Control Center Air Conditioning (AC) System."

Specifically, the proposed change would modify TS 3.7.4 by adding an Action Statement to the Limiting Condition for Operation (LCO). The new Action Statement allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one Control Center AC subsystem to operable status and requires verification that control room temperature remains below 90 degrees Fahrenheit every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The proposed change is consistent with the NRC-approved Industry / Technical Specification Task Force (TSTF)-477, Revision 3. The availability of this TS improvement was published in the Federal Register on March 26, 2007 as part of the consolidated line item improvement process (CLIIP).

Aoo(

USNRC NRC-07-0047 Page 2 In a conference call with NRC on August 3, 2007, the NRC staff raised a question regarding the terminology used in the new Action Statement. Specifically, the staff questioned the use of the term "control center" in the proposed Required Action B. 1.

TSTF-477, Revision 3, as approved by the NRC uses the term "control room" in Required Action B. 1, and does not include the term in brackets. Therefore, the proposed Required Action B. 1 should use the term "control room."

Updated TS and TS Bases pages that include this revision are provided in Enclosures to this letter. Enclosure I provides updated existing TS pages marked up to show the proposed change. Enclosure 2 provides updated revised (clean) TS pages. Enclosure 3 provides updated existing TS Bases pages marked up to show the proposed corresponding change. These TS and TS Bases pages replace the ones provided in Reference 2.

In accordance with 10 CFR 50.91, a copy of this letter, with enclosures, is being provided to the designated Michigan State Official.

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

Ronald W. Gaston, Manager, Nuclear Licensing at (734) 586-5197.

Sincerely,

Enclosures:

1. Proposed Technical Specification Changes

2. Revised Technical Specification Pages

3.

Marked up Technical Specification Bases Changes (for information only) cc:

NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-07-0047 Page 3 I, Joseph H. Plona, 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.

JOSEPH H. PLONA Site Vice President - Nuclear Generation On this e day of 4d&'

, 2007 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.

CYNTMI A. WISNIEWSKI NOTARY PUBLIC, STATE OF M' COUNTY OF WAYNE MY COMMISSION EXPIRES Mar "0, 9'l ACTING IN COUNTY OF No ry Public

ENCLOSURE 1 TO NRC-07-0047 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Pages 3.7-11, 3.7-12 and 3.7-13

• Control Center AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Center Air Conditioning (AC) System LCO 3.7.4 Two control center AC subsystems shall be OPERABLE.

APPLICABILITY:

MnnOE 1. 2, and 3 During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One control center AC A..1 Restore control 30 days subsystem inoperable, center AC subsystem to OPERABLE status.

,E'.

Required Action and X.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C

associated Completion Time of Condition A<,.,

AND not met in MODE 1, 2, },.

or 3.

/12 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (conti nued)

B.-1%o Co toL conpv 01 V

3.

roI Oc e 4ku, AC a V-&

+ A-Vi * < 9 00F Res3y

.z~

c,-v"3't 7%

2-vc Cew\\feý Ac

-4OPEKN~BLý

+ds FERMI - UNIT 2 3.7-11 Amendment No. /

144

Control Center AC System 3.7.4 ACTIONS (cont inued)

CONDITION REQUIRED ACTION COMPLETION TIME

/

V Required Action and associated Completion Time of Condition A not met during movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs.

---

NOTE -------------

LCO 3.0.3 is not applicable.

/.1 OR Place OPERABLE control center AC subsystem in operation.

Suspend movement of recently irradiated fuel assemblies in the secondary containment.

Immediately I.

/2 T1>

1 Immediately Immediately AND 1/2.2 D

Initiate action to suspend OPDRVs.

(conti nued)

FERMI - UNIT 2 3.7-12 Amendment No. /i4,144

Control Center AC System 3.7..4 ACTIONS (conti nued)i CONDITION REQUIRED ACTION COMPLETION TIME E.......

nt l...

NOTE...-------------

NOTE LCO 3.0.3 is not applicable.

during movement of--

recently irradiated fuel assemblies in the E.1 Suspend movement of Immediately secondary containment recently irradiated or during OPDRVs.

fuel assemblies in the secondary containment.

AND E.2 Initiate actions to he F3 suspend OPDRVs.

Immediately SURVEI LLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify the control room air temperature is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

< 950F.

FERMI - UNIT 2 3.7-13 Amendment No. ý4,144

ENCLOSURE 2 TO NRC-07-0047 PROPOSED TECHNICAL SPECIFICATIONS PAGES Pages 3.7-11, 3.7-12 and 3.7-13

Control Center AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Center Air Conditioning (AC)

System LCO 3.7.4 Two control center AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

During movement of recently irradiated the secondary containment, During operations with a potential for vessel (OPDRVs).

fuel assemblies in draining the reactor ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One control center AC A.1 Restore control 30 days subsystem inoperable.

center AC subsystem to OPERABLE status.

B.

Two control center AC B.1 Verify control Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> subsystems room area inoperable, temperature <900 F.

AND B.2 Restore one control 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> center AC subsystem to OPERABLE status.

C.

Required Action and C.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND or B not met in MODE 1, 2, or 3.

C.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> I

FERMI - UNIT 2, 3.7-11 Amendment No.

• 4, 1A44

Control Center AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and

---

NOTE ----------------

associated Completion LC03.0O3 is not applicable Time of Condition A not met during movement of recently irradiated fuel D.1 Place OPERABLE Immediately assemblies in the control center AC secondary containment subsystem in or during OPDRVs.

operation.

OR D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND D.2.2 Initiate action to Immediately suspend OPDRVs.

(continued)

FERMI - UNIT 2 3.7-12 Amendment No.

14., *44/

Control Center AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and

---

NOTE-----------

associated Completion LCO 3.0.3 is not applicable Time of Condition B not met during E.1 Suspend movement of Immediately movement of recently recently irradiated irradiated fuel fuel assemblies in assemblies in the the secondary secondary containment containment.

or during OPDRVs.

AND E.2 Initiate actions to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify the control room air temperature is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

• 950F.

FERMI - UNIT 2 3.7-13 Amendment No.

A43, 144

ENCLOSURE 3 TO NRC-07-0047 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES Pages B 3.7.4-3, B 3.7.4-4 and B 3.7.4-5 (plus Insert 1, 1 page)

Control Center AC System B 3.7.4 BASES APPLICABILITY (continued)

a.

During operations with a potential for draining the reactor vessel (OPDRVs); and

b.

During movement of recently irradiated fuel assemblies in the secondary containment.

Due to radioactive decay, the Control Room AC. System is only required to be OPERABLE during fuel handling involving recently irradiated fuel.

"Recently irradiated fuel" is fuel that has occupied part of. a critical reactor core within the previous 6.3 days provided that it is verified that the limits in Footnote 11 of Regulatory Guide 1.183 are not exceeded.

Otherwise, "recently irradiated fuel" is fuel that has occupied part of a critical reactor core within the previous 37 days.

Handling new (non-irradiated) fuel bundles over the open reactor core or the spent fuel pool is subject to the same requirements of handling recently irradiated fuel, as long as any fuel in the core or fuel pool is recently irradiated.

ACTIONS A.1 With one control center AC subsystem inoperable, the inoperable control center AC subsystem must be restored to OPERABLE. status within 30 days.

With the unit in this condition, the remaining OPERABLE control center AC subsystem is adequate to perform the control center air conditioning function.

However, the.overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the control center air conditioning function.

The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate safety and nonsafety cooling methods.

rt4~RT I

6~A1 and Y.2 In MODE 1, 2, or 3, if the inoperable control center AC su system cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes risk.

To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are FERMI

- UNIT 2 B 3.7.4-3 Rev~ision 31

Control Center AC System B 3.7.4 BASES ACTIONS. (continued) reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D D

~,,el, Q2.1 and Z.2 D

The Required Actions of Condition/are modified by a Note indicating that LCO 3.0.3 does not apply.

If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

DUring moivbent d

6f i6teily ifdi~tad fuel assemblies in the secondary containment or during OPDRVs, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE control center AC subsystem may be placed immediately in operation.

This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room.

This places the unit in a condition that minimizes risk.

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately.

Suspension of these activities shall not preclude completion of movement of a component to a safe position.

Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.

Actions must continue unfil the OPDRVs are suspended.

FERMI - UNIT 2 B 3.7.4-4 Revision 8

Control Center AC System B 3.7.4 BASES ACTIONS (continued)

E.. and E.2 The Required Actions of Condition E are modified by a Note indicating that LCO 3.0.3 does not apply.

If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of recently irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown.

A?,;p_4 A During movement of recently irradiated fuel assemblies in 8,1 ~

6.2 4~notthe secondary: containment or during OPDRVs, '.,it-h t-w eemrs c.y.2z, A,

H8P Fabl, action must be taken.-&-----,---.

Le k-et;;m

-4A immediately-4&e-suspend activities that present a potential re*..'-d C) for releasing radioactivity that might require isolation of the control room.

This placesthe unit in a condition that e 5

• minimizes risk.

If applicable, handling of recently irradiated fuel in the secondary containment must be suspended immediately.

Suspension.of these activities shall not preclude completion of movement of a component to a safe position.

Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.

Actions must continue until the OPDRVs are suspended.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load.

The SR consists of a verification of the control room temperature.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is appropriate since significant degradation of the Control Center AC System is not expected over this time period.

REFERENCES

1.

UFSAR, Section 6.4.

2.

UFSAR, Section 9.4.1.

FERMI

- UNIT 2 B ý.7.4-5 Revision 8 to NRC-07-0047 INSERT 1 B. 1 and B.2 If both Control Center AC subsystems are inoperable, the Control Center AC System may not be capable of performing its intended function. Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected.

With the control room temperature being maintained within the temperature limit, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restore a Control Center AC subsystem to OPERABLE status. This Completion Time is reasonable considering that the control room temperature is being maintained within the temperature limit and the low probability of an event occurring requiring control room isolation.