ML20133G774

Application for Amend to License NPF-23,changing Tech Spec 3.10.5 to Delay Inerting of Containment Until 120 EFPDs Achieved.Fee Paid

ML20133G774
Person / Time
Site:	Fermi
Issue date:	10/09/1985
From:	Jens W DETROIT EDISON CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML20133G777	List: ML20133G774 ML20133G784
References
RC-LG-85-0052, RC-LG-85-52, NUDOCS 8510160119
Download: ML20133G774 (4)

Text

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Newport M ch gan 4816 Nuclear Ed@Q g g3'3)5M 4 xo Operations October 9, 1985 RC-LG-85-0052 Director of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

Fermi 2 NRC Docket No. 50-341, NRC License No. NPF-#3

Subject:

Request,for Exemption and Amendment to NPF-%3 Regardinc Containment Inertinc In accordance with the Code of Federal Regulations, Title 10, Part 50.12, Detroit Edison hereby requests an exemption from the requirement of Part 50.44(c )( 3 )( i) . This section states in part, " Effective Hay 4, 1982 or 6 months after initial criticality, whichever is later, an inerted atmosphere shall be provided for each boiling light-water nuclear power reactor with n Mark I or Mark II type containment". Initial criticality at Fermi 2 occurred on June 21, 1985. Therefore, to comply with this regulation requires Fermi 2 to inert the containment by December 21, 1985.

The startup test program will not be completed by the December date because of delays in power ascension. The frequent entries into containment required by the startup test program would require significant delays if the containment would have to be de-inerted and re-inerted for each entry. This would result in an additional significant delay in progressing toward Commercial Operation.

Accordingly, Detroit Edison requests that Technical Specification 3.10.5 be changed as indicated in the Attachment.

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Mr. B. J. Youngblood October 9, 1985 RC-LG-85-0052 Page 2 This proposed change would achieve the intended measure of safety by minimizing the time the reactor operates. As a result, the amount of fission products generated prior to inerting the containment would be minimized while not unduly hampering the required startup test phase program.

Detroit Edison has reviewed the proposed change to the Technical Specifications and concluded that no significant hazards are involved in its implementation.

The proposed change will not:

1) involve a significant increase in the probability or consequences of an ac c id en t 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.

This change is similar to item (vi) of examples of amendments not likely to involve significant hazards considerations in 48 FR 14870. Item (vi) reads, "A change which either may result in some increase to the probability or consequences of a previously analyzed accident or may

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reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan: for example, a change resulting from the application of a small refinement of a previously used calculational model or design method."

To delay the inerting of the containment until the achievement of 120 Effective Full Power Days instead of 6 months of calendar time following initial criticality would result in a negligible change in the consequences of a LOCA. This is true because the fission product inventory is still maintained within the bounds of that which could be generated within six months, assuming full power operation.

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Mr. B. J. Youngblood

, detober 9, 1985 RC-LG-85-0052 Page 3 With regard to the determination of no significant hazards, it has been a long established NRC staff policy to permit the operation of Boiling Water Reactors during start-up-testing with non-inerted containments. The high frequency of containment entries during this period of plant operations makes it impractical to operate with an inerted containment. This practice has been reviewed and found acceptable in a number of prior cases.

Detroit Edison recognizes that these Technical Specifications amendments and exemptions to 10CFR50.44 do not authorize a change in effluent types or total amount, or increase in power level. Furthermore, such changes would not result in any significant environmental impact.

Pursuant to 10CFR170.21, Detroit Edison has enclosed the application fee of one hundred fifty dollars ( $150.00) .

In accordance with 10CFR50.91, the State of Michigan has been provided a copy of this letter. Should you have any questions, please contact Mr. A. E. Wegele at (313) 586-4210.

Sincerely, I

f W,' k With attachment 6

cc: Mr. P. M. Byron Mr. M. David Lynch Supervisor, Advance Planning and Review Section Michigan Public Service Commission

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Mr. B. J. Youngblood October 9, 1985 kC-LG-85-0052 Page 4-I, WAYNE H. JENS, 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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WAYNE H. JENS j Vice P re s id en t Nuclear Operations t

On this -day of , 1985, b e f o'r e me personally appeared Wayne H. Jens, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public MARCIA BUCK-Netary Public, Washtenaw County, Mi My Commission Expires Dec.23,1987 j

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