NRC-17-0044, License Amendment Request to Revise Technical Specification 5.5.7, Ventilation Filter Testing Program, to Be Consistent with Standard Technical Specifications

License Amendment Request to Revise Technical Specification 5.5.7, Ventilation Filter Testing Program, to Be Consistent with Standard Technical Specifications

ML17226A277
Person / Time
Site:	Fermi
Issue date:	08/14/2017
From:	Polson K DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-17-0044
Download: ML17226A277 (21)

Text

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: keith.polson@dteenergy.com August 14, 2017 10 CFR 50.90 NRC-17-0044 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

References:

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

Subject:

License Amendment Request to Revise Technical Specification 5.5.7, Ventilation Filter Testing Program, to be Consistent with Standard Technical Specifications In accordance with the provisions of 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, DTE Electric Company (DTE) requests amendment to Appendix A, Technical Specifications of Renewed Facility Operating License NPF-43 for Fermi Unit 2 (Fermi 2).

This submittal requests modification of the Fermi 2 Technical Specifications (TS) for the Ventilation Filter Testing Program (VFTP) (5.5.7) to adopt the formatting and language of the Standard Technical Specifications (STS) (5.5.8).

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan State Official. provides a detailed description and evaluation of the proposed changes, including an analysis of the significant hazards considerations using the standards of 10 CFR 50.92. DTE has concluded that the changes proposed herein do not result in a significant hazards consideration. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. There are no TS Bases associated with the proposed TS changes and therefore no revisions to the TS Bases are being made.

This license amendment request contains no regulatory commitments.

USNRC NRC-17-0044 Page2 DTE requests approval of the proposed License Amendment by August 1, 2018 to allow for implementation prior to Refueling Outage 19 in the fall of 2018. Upon approval, the amendment will be implemented within 60 days.

Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager-Nuclear Licensing at (734) 586-5076.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 14, 2017 Keith J. Polson Site Vice President Nuclear Generation

Enclosures:

1. Evaluation of the Proposed License Amendment

2. Marked-up Pages of Existing Fermi 2 TS

3. Clean Pages of Fermi 2 TS with Changes Incorporated cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-17-0044 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification 5.5.7, Ventilation Filter Testing Program, to be Consistent with Standard Technical Specifications Evaluation of the Proposed License Amendment to NRC-17-0044 Page 1 Evaluation of the Proposed License Amendment Contents Acronym List 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Analysis 4.4 Conclusions 5.0 Environmental Consideration 6.0 References Acronym List ASME American Society of Mechanical Engineers ASTM American Society for Testing & Materials BWR Boiling Water Reactor CFR Code of Federal Regulation CRE Control Room Envelope CREF Control Room Emergency Filtration DBA Design Basis Accident DTE DTE Electric Company ESF Engineered Safety Feature HEPA High Efficiency Particulate Air NRC Nuclear Regulatory Commission SGT Standby Gas Treatment STS Standard Technical Specification TS Technical Specification VFTP Ventilation Filter Testing Program to NRC-17-0044 Page 2 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, DTE Electric Company (DTE) requests an amendment to Appendix A, Technical Specifications of Renewed Facility Operating License NPF-43 for Fermi Unit 2 (Fermi 2).

The proposed amendment revises Technical Specification (TS) 5.5.7, Ventilation Filter Testing Program, to adopt the formatting and language in NUREG-1433, Standard Technical Specifications (STS) for General Electric BWR/4 Plants, Revision 4. Adoption of the STS formatting and language will remove the requirement to test the HEPA filters after charcoal adsorber bank replacement and the requirement to test the charcoal adsorber after HEPA filter bank replacement, as these tests are not required by Regulatory Guide 1.52, Revision 2 or ASME N510-1980. The specific requirements to perform testing in accordance with Regulatory Guide 1.52, Revision 2 and ASME N510-1980 will be maintained in the licensee-controlled Ventilation Filter Testing Program (VFTP) as steps in station surveillance procedures.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The VFTP described in TS 5.5.7 establishes the required testing of Engineered Safety Feature (ESF) filter ventilation systems, specifically the Standby Gas Treatment (SGT) system and the Control Room Emergency Filtration (CREF) system in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980.

The SGT system consists of two separate and parallel 100 percent capacity equipment and filter trains. On detection of radioactivity or conditions that could lead to a release of radioactivity, the SGT system functions to minimize the release-related offsite dose rates by permitting the venting and purging of both the primary and secondary containment atmospheres under accident or abnormal conditions, and at the same time containing any airborne particulate or halogen contamination that might be present. Either train may be considered as an installed spare, with the other train being capable of passing the required amount of air. Either train alone is capable of exchanging the total reactor building air volume once in a 24-hour period.

Each SGT equipment train consists of a moisture separator, a prefilter, an electric heater, a high efficiency particulate air (HEPA) filter, a charcoal adsorber, a second HEPA filter, an exhaust fan, and a cooling air fan installed in parallel with the exhaust fan.

The CREF system provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. CREF is a single system that performs its safety function with redundant active components and non-redundant passive components, including a Control Room Envelope (CRE) boundary that limits the inleakage of unfiltered air. The CREF system also includes associated ductwork, dampers, to NRC-17-0044 Page 3 doors, barriers and instrumentation. The CREF system is designed to maintain a habitable environment in the CRE for a 30-day continuous occupancy after a DBA without exceeding 5 rem total effective dose equivalent.

During emergency operation of CREF, two emergency filter trains are automatically put in operation. The emergency makeup filter train consists of a mist eliminator, redundant divisional electric heater, a HEPA filter, a two inch deep charcoal adsorber, and a second HEPA filter. The emergency recirculation filter train consists of a prefilter, a HEPA filter, a four inch deep charcoal adsorber, and a second HEPA filter. Air is drawn through these emergency filters by one of two redundant divisional emergency recirculation air fans. Redundant air operated dampers are provided to direct the air to the proper components. The redundant active components of the CREF System are independent and divisionally separated. Each division operates as a unit and therefore can be considered separate subsystems, although they share non-redundant passive components.

2.2 Existing Technical Specification Requirements TS 5.5.7 Part a establishes the requirement to demonstrate for each of the ESF filter ventilation systems that an inplace test of the HEPA filters shows a penetration and system bypass less than specified values when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the specified system flowrate +/- 10%.

TS 5.5.7 Part b establishes the requirement to demonstrate for each of the ESF filter ventilation systems that an inplace test of the charcoal adsorber shows a penetration and system bypass less than specified values when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the specified system flowrate +/- 10%.

Parts a and b list the flowrate as 3800 cfm and the penetration and system bypass as 0.05% for SGT. In addition, they list the flowrate values as 1800 cfm (makeup filter) or 3000 cfm (recirculation filter) and the penetration and system bypass value as 1.0% for CREF. Parts a and b also state that their respective VFTP tests shall be performed at the following frequencies:

1. Once per 18 months;

2. After each complete or partial replacement of the HEPA filter bank or charcoal adsorber bank;

3. After any structural maintenance on the HEPA filter or charcoal adsorber housing; and

4. Following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation.

TS 5.5.7 Part c establishes the requirement to demonstrate for each of the ESF filter ventilation systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the specified value specified when tested in accordance with ASTM D3803-1989 at a temperature of 30ºC and at the specified relative humidity. For SGT, it lists the penetration value as 0.100% and the relative humidity value as 70%. For CREF, it lists the penetration value as 1.0% and the relative humidity as 70%.

to NRC-17-0044 Page 4 The tests associated with Part c have the following performance frequencies:

1. Once per 18 months;

2. After 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation;

3. After any structural maintenance on the HEPA filter or charcoal adsorber housing; and

4. Following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation.

TS 5.5.7 Part d establishes the requirement to demonstrate for each of the ESF filter ventilation systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the specified value when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the specified system flowrate +/- 10%. For SGT, it lists the Delta P value as 11.0 inches water gauge and the flowrate as 3800 cfm. For CREF, it lists the Delta P value as 3.0 inches water gauge (makeup train) or 4.2 inches water gauge (recirculation train) and the flowrate as 1800 cfm (makeup train) or 3000 cfm (recirculation train).

TS 5.5.7 Part e establishes the requirement to demonstrate that the heaters for each of the ESF filter ventilation systems dissipate the specified value when tested in accordance with ASME N510-1980. It lists the Wattage as 24 kW for SGT and 12.0 +/- 2.0 kW for Control Room Emergency Makeup Inlet Air.

TS 5.5.7 Parts d and e state that the tests shall be performed once per 18 months.

2.3 Reason for the Proposed Change The proposed change will improve consistency between the existing TS and the NUREG-1433 STS. The VFTP performance frequencies listed in the existing TS are more succinctly referenced in the STS as the frequencies specified in Regulatory Guide 1.52, Revision 2. The testing requirements will then be controlled in the licensee-controlled program that implements Regulatory Guide 1.52, Revision 2.

The adoption of the STS formatting and language will eliminate the requirement to test the HEPA filters after charcoal adsorber bank replacement (TS 5.5.7 Part a) and the requirement to test the charcoal adsorber after HEPA filter bank replacement (TS 5.5.7 Part b), as these tests are not required by Regulatory Guide 1.52, Revision 2 or ASME N510-1980.

In addition, the adoption of the STS formatting and language will eliminate the specified 18-month frequency from TS 5.5.7 Part d. Regulatory Guide 1.52, Revision 2 and ASME N510-1980 do not specify a required frequency to test the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers (TS 5.5.7 Part d). The performance frequency will be relocated and maintained in the licensee-controlled VFTP.

to NRC-17-0044 Page 5 2.4 Description of the Proposed Change The TS 5.5.7 change will revise the introductory paragraph from The VFTP shall establish the required testing of Engineered Safety Feature (ESF) filter ventilation systems to A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2, and in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980.

For TS 5.5.7 Parts a, b, and c, the initial sentence The following tests shall be performed: and the detailed listing of the four performance frequencies will be deleted.

For TS 5.5.7 parts d and e the initial sentence of The following tests shall be performed once per 18 months. will be deleted.

In addition, the following minor editorial changes will be made in order to align with the NUREG-1433 STS:

TS 5.5.7 Part c will change the words at a temperature of 30°C and at the relative humidity to at a temperature of 30°C (86°F) and the relative humidity, TS 5.5.7 Part d will change the words at the system flowrate specified as follows +/-

10%: to at the system flowrate specified below +/- 10%.,

TS 5.5.7 Part e will change system to systems and the colon following ASME N510-1980 will be changed to a period.

Following the adoption of these proposed TS changes, there will be only minor differences between the Fermi 2 proposed TS and the STS. One difference will be that the section specified is numbered 5.5.7 versus the STS numbering of 5.5.8. All other differences are plant-specific as designated by brackets in the STS.

See Enclosure 2 for the existing TS pages marked up to show the proposed changes described above and Enclosure 3 for the revised (clean) TS pages. There are no TS Bases associated with the proposed TS changes and therefore no revisions to the TS Bases are being made.

3.0 TECHNICAL EVALUATION

The change is consistent with NUREG-1433, the improved STS for General Electric Boiling Water Reactor/4 (BWR/4) plants. In addition, the VFTP testing details and frequencies will be in accordance with ASME N510-1980 and Regulatory Guide 1.52, Revision 2, and described in the licensee-controlled VFTP that implements those requirements.

Regulatory Guide 1.52, Revision 2, regulatory position C.5.c applies to existing TS 5.5.7.a and states that HEPA filter sections should be tested in place (1) initially, (2) at least once per 18 months thereafter, and (3) following painting, fire, or chemical release in any ventilation zone communicating with the system.

to NRC-17-0044 Page 6 Regulatory Guide 1.52, Revision 2, regulatory position C.5.d. applies to existing TS 5.5.7.b, and states that Adsorber leak testing should be conducted (1) initially, (2) at least once per 18 months thereafter, (3) following removal of an adsorber sample for laboratory testing if the integrity of the adsorber section is affected, and (4) following painting, fire, or chemical release in any ventilation zone communicating with the system.

Regulatory Guide 1.52, Revision 2, regulatory position C.6.b applies to existing TS 5.5.7.c, and states that testing should be performed (1) initially, (2) at least once per 18 months thereafter for systems maintained in a standby status or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, and (3) following painting, fire, or chemical release in any ventilation zone communicating with the system.

Therefore, frequency requirements 1 and 4 of TS 5.5.7 Parts a and b and frequency requirements 1, 2, and 4 of TS 5.5.7 Part c of the existing TS 5.5.7 are retained by the reference to the Regulatory Guide instead of being explicitly stated.

The VFTP testing is required by TS Chapter 3 Surveillance Requirements. SR 3.0.1 requires Surveillance Requirements to be met during the performance of the Surveillance or between performances of the Surveillance. The SR 3.0.1 Bases explain this requirement and state, Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Therefore, frequency requirement 3 of TS 5.5.7 Parts a, b, and c of the existing TS 5.5.7 is retained as a TS requirement.

As discussed in the description of change, the adoption of the STS formatting and language will eliminate the requirement to test the HEPA filters after charcoal adsorber bank replacement (TS 5.5.7 Part a, frequency 2) and the requirement to test the charcoal adsorber after HEPA filter bank replacement (TS 5.5.7 Part b, frequency 2), as these tests are not required by Regulatory Guide 1.52, Revision 2, or ASME N510-1980. The elimination of this testing requirement is justified since the HEPA filters would not be affected by a complete or partial replacement of the charcoal adsorber bank and the charcoal adsorber would not be affected by a complete or partial replacement of the HEPA filter bank. Therefore, this testing frequency not required by Regulatory Guide 1.52, Revision 2, or ASME N510-1980 can be eliminated from the Fermi TS and the Fermi VFTP. The requirements to test the HEPA filters after complete or partial replacement of the HEPA filter bank or to test the charcoal adsorber after complete or partial replacement of the charcoal adsorber bank will be retained in the VFTP.

Therefore, all testing requirements currently specified in the Fermi 2 TS are retained as a reference to the Regulatory Guide instead of being explicitly stated, retained as a Technical Specifications requirement, or are justifiably eliminated from the Fermi TS and VFTP.

The removal of the testing performance frequency details from TS 5.5.7 is acceptable because this type of information is not necessary to be included in the TS to provide adequate protection of public health and safety. The TS still retain the requirements to perform tests on the ventilation filters on a frequency and in a manner consistent with Regulatory Guide 1.52, Revision 2, and SR 3.0.1. Also, this change is acceptable because these types of procedural to NRC-17-0044 Page 7 details will be adequately controlled in VFTP. The adequacy of the VFTP will be maintained in accordance with 10 CFR 50.59. This change is designated as a less restrictive removal of detail change because procedural details for meeting TS requirements are being removed from the TS.

The Fermi 2 license amendment request to convert to STS (Reference 6.1) did not directly adopt the wording of NUREG-1433, Revision 1. The justification given stated the VFTP was modified to include a detailed description of the required SR frequencies to improve clarity and to facilitate use by the plant staff. The justification went on to state that there were no technical changes to the requirements as specified in NUREG-1433, Revision 1; therefore, the change was not a significant or generic deviation from NUREG-1433. In order to increase the consistency between the Fermi 2 TS and the STS, the wording of STS 5.5.8 is now being requested.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 36(c)(5),

Administrative Controls, states:

Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in § 50.4.

The proposed changes are consistent with the requirements of 10 CFR 50.36 and are consistent with NUREG-1433.

4.2 Precedent The proposed changes are in accordance with NUREG-1433, Standard Technical Specifications (STS) for General Electric BWR/4 Plants, Revision 4 (Reference 6.2).

In 2014, Hatch requested and subsequently received approval of a TS revision to adopt the VFTP wording and format from NUREG-1433 (References 6.3 and 6.4).

4.3 No Significant Hazards Consideration Analysis DTE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

to NRC-17-0044 Page 8 The proposed change aligns the introductory paragraph and testing requirements of Specification 5.5.7, Ventilation Filter Testing Program (VFTP), to be consistent with the STS. The Fermi 2 VFTP will implement the required testing of ESF filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2, and in accordance with Regulatory Guide 1.52, Revision 2 and ASME N510-1980. Specific frequency requirements to perform testing are retained either as a reference to Regulatory Guide requirements and general requirements in Surveillance Requirement (SR) 3.0.1 or in the licensee-controlled VFTP. Implementation of these requirements will be in the licensee-controlled VFTP. The VFTP will be maintained in accordance with 10 CFR 50.59.

Since SGT and CREF are ESF systems and not accident initiators, the probability of an accident evaluated in the UFSAR will not be increased. As such, the probability of occurrence for a previously analyzed accident is not significantly increased.

The consequences of a previously analyzed event are dependent on the initial conditions assumed for the analysis and the availability and successful functioning of the equipment assumed to operate in response to the analyzed event. The proposed change does not affect the performance of any credited equipment, and the details of testing do not alter the assumptions made in the safety analysis. As such, the consequences of an accident previously evaluated are not significantly increased.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. The changes do not alter the assumptions made in the safety analysis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises TS 5.5.7, Ventilation Filter Testing Program (VFTP), to be consistent with the STS. The proposed change will not reduce a margin of safety because it has no effect on any safety analysis assumption. In addition, no regulatory requirements are being removed, but are either being replaced with references to be performed as described in Regulatory Guide 1.52, Revision 2, and the requirements of SR 3.0.1 or are being held in the licensee-controlled VFTP. Therefore, this proposed change does not involve a significant reduction in a margin of safety.

to NRC-17-0044 Page 9 Based on the above, DTE concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions There are no changes being proposed in this license amendment request such that commitments to applicable regulatory requirements and guidance documents described above would come into question. The evaluations documented above confirm that DTE will continue to comply with all applicable regulatory requirements. In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

DTE has reviewed the proposed changes pursuant to 10 CFR 50.92 and determined that it does not involve a significant hazards consideration. In addition, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in the individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, in accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection to the proposed amendment.

6.0 REFERENCES

6.1 DTE Electric Company Letter to NRC, NRC-98-0043, Proposed Technical Specification Change (License Amendment) - Conversion to Improved Standard Technical Specifications, dated April 3, 1998 6.2 NUREG-1433, Standard Technical Specifications (STS) for General Electric BWR/4 Plants, Revision 4 (ML12104A192) 6.3 Southern Nuclear Operating Company Letter to NRC, Edwin I. Hatch Nuclear Plant, Units 1 and 2 - Adoption of Previously Approved Generic Technical Specification Changes and Other Changes, dated October 10, 2014 (ML14288A226) 6.4 NRC Letter to Southern Nuclear Operating Company, Edwin I. Hatch Nuclear Plant, Units Nos. 1 and 2 - Issuance of Amendments Regarding Multiple Technical Specification Changes, dated September 29, 2016 (ML16231A041)

Enclosure 2 to NRC-17-0044 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification 5.5.7, Ventilation Filter Testing Program, to be Consistent with Standard Technical Specifications Marked-up Pages of Existing Fermi 2 TS

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.7 Ventilation Filter Testing Program CVFTP)

I*Insert # 1 *r->~ I. The \/FTP shell esteblish the reqHired testiRg FeattJre CESF> filter 'ieRtil ati eR systems .

ef ERgiReere~ Safe~ I 1.

2.

Delete )

Text 3.

4.

Demonstrate for each of the ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass <

specified below when tested in accordance with Regulatory Guide 1.52. Revision 2. and ASME N510*1980 at the system flowrate specified below+/- 10.t.

Penetration and ESF Ventilation System Flowrate Ccfm) System Bypass U* Standby Gas Treatment 3800 0.05.t Control Room Emergency 1800 (makeup filter) 1.0.t Filtration 3000 (recirculation filter)

b. be performed:

1.

2.

Delete i--->~

Text 3.

4.

~-/ (continued)

FERMI - UNIT 2 5.0-12 Amendment No. 134

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program CVFTP) (continued)

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52. Revision 2. and ASHE NSl0-1980 at the system flowrate specified below+/- lOt.

Penetration and ESF Ventilation System Flowrate Ccfm) System Bypass Standby Gas Treatment 3800 0.05.t Control Room Emergency 1800 (makeup filter) 1.0t Filtration 3000 (recirculation filter)

c. be performed:

1.

2.

\_)

• Delete Text 1---> 3 .

4.

Demonstrate for each.of the ESF systems that a laboratory test of a sample of the charcoal adsorber. when obtained as described in Regulatory Guide 1.52. Revision 2. shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803*1989 at a temperature of 30°C an ~ the relative humidity specified l(860F) I below. /f ESF Ventilation System Penetration RH Standby Gas Treatment 0.100.t 70.t Control Room Emergency 1.0.t 70.t Filtration (continued)

FERMI

• UNIT 2 5.0-13 Amendment No. 134

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program CVFTP> (continued)

Delete Text

d. IThe foll owing tests shall be perf.cemed 011ce per 18 months.

Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters. the prefilters. and I

the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52.

Revision 2. and ASHE N510*1980 at the system flowrate specified as fellows : lQt:

Ibelow+/- 10%. ~I ___________,;1 Delta P Flowrate ESF Ventilation System Cinches water gauge) Ccfm)

Standby Gas Treatment 11.0 .3800

• Control Room Emergency 3.0 (makeup train) 1800 Filtration CCREF) 4.2 (recirculation 3000 train)

.e. IThe fo11 owing t ests shall be perfer nietl once oer 18 months. I Delete Demonstrate that the heaters for each of the ESF system ~(~-11systernsl Text

---

~ dissipate the value specified below when tested in

• accordance with ASHE N510*1980-r []

ESF Ventilation System Wattage CkW)

Standby Gas Treatment ~ 24 Control Room Emergency 12.0 +/- 2.0 Makeup Inlet Air The *provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

u FERMI

• UNIT 2 5.0*14

. (continued)

Amendment No.,444', 142

Insert #1 A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2, and in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980.

Enclosure 3 to NRC-17-0044 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification 5.5.7, Ventilation Filter Testing Program, to be Consistent with Standard Technical Specifications Clean Pages of Fermi 2 TS with Changes Incorporated

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2, and in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980.

a. Demonstrate for each of the ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass <

specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

Penetration and ESF Ventilation System Flowrate (cfm) System Bypass Standby Gas Treatment 3800 0.05%

Control Room Emergency 1800 (makeup filter) 1.0%

Filtration 3000 (recirculation filter)

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

Penetration and ESF Ventilation System Flowrate (cfm) System Bypass Standby Gas Treatment 3800 0.05%

Control Room Emergency 1800 (makeup filter) 1.0%

Filtration 3000 (recirculation filter)

(continued)

FERMI - UNIT 2 5.0-12 Amendment No. 134

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.

ESF Ventilation System Penetration RH Standby Gas Treatment 0.100% 70%

Control Room Emergency 1.0% 70%

Filtration

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

Delta P Flowrate ESF Ventilation System (inches water gauge) (cfm)

Standby Gas Treatment 11.0 3800 Control Room Emergency 3.0 (makeup train) 1800 Filtration (CREF) 4.2 (recirculation 3000 train)

(continued)

FERMI - UNIT 2 5.0-13 Amendment No. 134

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ASME N510-1980.

ESF Ventilation System Wattage (kW)

Standby Gas Treatment 24 Control Room Emergency 12.0 +/- 2.0 Makeup Inlet Air The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

(continued)

FERMI - UNIT 2 5.0-14 Amendment No. 134, 142