ML20154N743

Requests Review of Encl 880126 Application for Amend & Preparation of Safety Evaluation Supporting Conclusions Re Acceptability of Proposed Changes.Salp Input Also Requested for Review Effort

ML20154N743
Person / Time
Site:	Fermi
Issue date:	05/26/1988
From:	Muller D Office of Nuclear Reactor Regulation
To:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
TAC-67100, NUDOCS 8806030055
Download: ML20154N743 (2)

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May 26, 1988 i

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' MEMORANDUM FOR: Hubert J. Mill r',# Director ~

. Division of Reactor Safety ,

Region III

FROM: Daniel R. Muller,-Acting Director Project Directorate III-1 Division of Reactor Projects - III, IV, V and Special Projects y i

SUBJECT:

TECHNICAL REVIEW 0F FERMI-2 TS AMENDMEIO l (TAC P0. 67100) ,

Detroit Edison Company has submitted a request'for an amendment to the Technical Specifications for Fermi-2.

We request that Region III~ review the enclosed amendment request datad January 26, 1988, and prepare a Safety Evaluation supporting your conclusions regarding the acceptability of the proposed changes. A SALP , '

input should also be provided for associated review effort. The requested completion date is September 15, 1988. This date and the subject evaluation were previously discussed with Monte Phillips of your staff. If further information or support is necessary for this technical review, please contact the assigned backup project manager, Lynn Kelly, at FTS 492-1305.

Please have your staff sign and return the blue sheet as appropriate, original signed by s806030005 000526 Daniel R. Muller, Acting Director PDR ADOCK 05000 P 1

Pro,jectDirectorateIII-l P Division of Reactor Projects - III, IV, V and Special Projects

Enclosures:

1. Amdt. Request dtd.

1/26/88

2. Work Request Transmittal (blue sheet) l CONTACT:

L. Kelly, DRSP/NRR l FTS 492-1305 j DISTRIBUTION  !

-Docket t11es " c NRC & Loc'al"PDR's PD31 gray file RIngram DMuller LKelly ux 0FFICE: LA/PD3 PM/PD3-1 D/

SURNAME: RIn ram P LKelly/r1 0 e DATE: 05 /88 05/r4/88 05/u,/88 t

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[r%k p, UNITED STATES NUCLEAR REGULATORY COMMISSION l

I 3- l WASHINGTON, D. C. 20555 1 g ,/ May 26, 1988 1

MEMORANDUM FOR: Hubert J. Miller, Director Division of Reactor Safety Region III FROM: Daniel R. Muller, Acting Director Project Directorate III-1 Division of Reactor Projects - III, IV, V and Special Projects

SUBJECT:

TECHNICAL REVIEW 0F FERMI-2 TS AMENDMENT (TAC NO. 67100)

Detroit Edison Company has submitted a request for an amendment to the Technical Specifications for Ferni-2.

We request that Region III review the enclosed amendment request dated January 26, 1988, and prepare a Safety Evaluation supporting your conclusions regarding the acceptability of the proposed changes. A SALP input should also be provided for associated review effort. The requested completion date is September 15, 1988. This date and the subject evaluation were previously discussod with Monte Phillips of your staff. If further information or support is necessary for this technical review, please contact the assigned backup project manager, Lynn Kelly, at FTS 492-1305.

Please have your staff sign and return the blue sheet as appropriate.

Daniel R. Muller, Acting Director  !

Project Directorate III-1 Division of Reactor Projects - III, i IV, V and Special Projects  ;

Enclosures:

1. Amdt. Request dtd. l 1/26/88 l

2. Work Request Transmittal (blue sheet)

CONTACT: 1 L. Kelly, DRSP/NRR l FTS 492-1305  ;

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8. Ralph Sylvia Grovo wee presioont 6

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son =400NonnDioeHighway January 26, 1988 NIC-87-0248 U. S. Wclear Regulatory Connission Attn Document Control Desk Washington, D.,C. 20555 IMference: Fermi 2 NIC Docket No. 50-341 NIC License No. NPF-43

Subject:

Proposed '1%chnica1' Specification Chege (License Amendment) - Primary Containment (3/4.6.1) and Secondary Containment (3/4.6.5)

Pursuant to 10CFR50.90, Detroit D31 son Conpany hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed chmge into the Plant Technical Specifications.

The proposed change allows closure mechanisms for primary and secondary containment penetrations which are locatM in Iceked high radiation areas to be verified closed each Cold shutdown (if not performed within the previous 31 days) rather thm every 31 days.

Additionally, the proposed revision clarifies that the primary containment penetrations located in locked areas which remain high radiation areas during the Cold Shutdown may be verified by review of high radiation area access controls. This proposed chmge inplements the AIABA (As Low As Reasonably Achievable) philosophy while still giving assurance that containment integrity is being maintained.

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 Chaite Review Organization has approved arti the melear Safety Review Group has reviewed the proposed Technical Specifications ard concurs with the enclosed determinations.

Pursuant to ICCFR170.12(c), enclosed with this amendment request is a check for one hundred fifty dollars ($150.00) .

8901 6 51 7F /. _. - --_ -.

s- l USNRC January 26, 1988 1 NIC-87-0248 I Page 2 I I

In accordance with 10CFR50.91, Detroit Edison has provided a copy of '

this letter to the State of Michigan.

If you have any questions, please contact Mr. Glen Ohlemacher at (313) 586-4275.

Sincerely, i

Enclosure i cc: A. B. Davis l

i E. G. Greenman I T. R. Cuay ,

j W. G. Rogers l Supervisor, Advanced Planning and Review Section, I Michigan Public Service Comissico 4

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.' January 26, 1988 NIC-87-0248 Page 3 I, B. PALPH SYLVIA, 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.

B. PALL 41 SV 6IA Group Vice President Ch this 26H' day of dh a^ct- , 1980, before me personally appeared B. Ralph Sylv'la, being' first duly sworn and says 1 that he executed the foregoing as his free act and deed.

Nw. Yh.

Notary Public KAREN D EED I tct::y rutlic, Menroe County, Mkh, l (c.r.rinkn Excites May 14,1990

r' l Enclosura to s NIC-87-0248 Page 1 I. BAGGROUtO/DIEUSSICE j 1

Fermi 2 Technical Specification 4.6.1.1.b provides a surveillance '

requirement to verify, at a frequency of at least once per 31 days, that all primary containnent penetrations not capable of being closed by operable containment automatic isolation valves and required to be closed during accident conditions are closed by locked closed valves,-

blank flanges, or deactivated automatic valves secured in position, except as provided in Table 3.6.3-1 of Specification 3.6.3.

Inaccessibility of valves locatM in the containment is recognized by providing a decreased frequency for such valves. Specification 4.6.5.1.b.3 provides a similar 31-day surveillance requirenent for secondary containnent penetrations. l

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At Fermi 2 approximately thirty (30) items which fall under the verification requirement of Specifications 4.6.1.1.b or 4.6.5.1.b.3 are 1ccated in areas which are normally locked high rMiation areas during reactor power operations. Access to these locked high radiation areas is controlled by an administrative program which requires control over and documentation for each entry.

Physical verification of each item located within a locked high I rMiation area during full power operation would result in an estimated occupational exposure of ten (10) man-rem ea:h year. l Detroit niison believes that this exposure is excessive considering I that the penetrations are locatM in locked areas to which entry is l closely controlled. -

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The proposed specification would establish a verification frequen:y for such penetrations located in locked high radiation areas of each l Cold Shucdown, if not performed within the previous 31 days, ard allow '

penetrations located in locked areas which remain high radiation areas during the Cold Shutdown to be verified by review of high radiation area access controls. The latter provision covers the TIP (Transverse Incore Probe) Room, in the case of a short Cold Shutdown following use of the probes, since the room is tenporarily inaccessible due to high radiation following probe use. 'Ite control over locked high radiation area entry greatly reduces the probability of any penetration being disturbed . '1he proposed surveillance frequency for penetrations located in locked high radiation areas could be considered as providing equivalent assurance of containment integrity as verification of normally accessible penetrations every 31 days.

Based on the reduction in dose that this change achieves, it is supported by the AIAPA philosophy. Since this proposed revision still provides assurance of control over containment boundary valves, it is definitely reasonably achievable.

i Enclosure to NIC-87-0248 Page 2 l

SIGNIFICANP 1RZMDS CONSIDimhTION l l

In accordance with 1(LTR50.92, Detroit B31 son has made a determination that the proposed amendment involves no significmt hazards considerations. To make this determination, Detroit Edison has established that operation in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or ~

consequences of an accident previously evaluate 3, or 2) create the possibility of a new or different kind of accident from any accident i previously evaluated, or 3) involve a significant reduction in a margin of safety. 1 l

1. The proposed change does not involve a significant increase in l the probability or consequences of an accident previcusly l evaluated. The change provides an alternative frequency and l means of verification of primary and secondary containment penetration isolation which still provides assurance that required conditions are being maintained.

2. The prc;N: sed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not add any new equipment, does not affect the operation of any of the systems, or alter any of the design assunptions previously evaluated.

3. The proposed change does not involve a significmt reduction in a margin of safety. The proposed chmge only contains an alternative frequency and method of verifying a primary and secoMary containment penetration isolation and thus results in an identical plant configuration with an unchanged margin of safety.

C0tCIESIGN Based on the evaluations abover 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 coupliance with the Commission's regulations aM the proposed amendment will not be inimical to the common defense and security or to the health and safety of the public.

II. IEVISED 'IBCMICAL SPICIFICATICEE The requested revision is attached.

III. EN7I1ONENML IMPACT Detroit niison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. As shown above, the proposed changes do not involve a significant hazards consideration, nor change the types or increase i

s' Enclosur@ to

_ NIC-87-0248 Page 3 the amounts of effluents that may be released offsite, nor significantly increase individual or cunulative occupational radiation exposures.

The change reduces cunulative occupational radiation exposures while maintaining an equivalent assurance that containment integrity is being maintained. -

Based on the foregoing, Detroit IMison corcludes that the proposed Technical Specifications do meet the criteria given in 1CCTR51.22(c)(9)' for a categorical exclusion from the requirements for an Environmental Inpact Statement.

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t CONTAINMENT SYSTEMS 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT PRIMARY CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 PRIMARY CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2* and 3.

ACTION:

1 Without PRIMARY CONTAINMENT INTEGRITY, restore PRIMARY CONTAINMENT INTEGRITY l within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT SHUTOOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUT 00WN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 1

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4. 6.1.1 PRIMARY CONTAINMENT INTEGRITY shall be demonstrated:

a. After each closing of each penetration subject to Type B testing, except the primary containment air locks, if opened following Type A or B test, by leak rate testing the seals with gas at P,, 56.5 psig, and verifying that when the measured leakage rate for these seals is added to the leakage rates determined pursuant to Surveillance Requirement 4.6.1.2.b for all other Type B and C penetrations, the combined leakage rate is less than or equal to 0.60 L,.

tr--- A east once per 31 days by verifying that all primary conta See penetra ca able of being closed by OPE ainment zw y- automatic isolation va v ir c osed during accident g conditions are closed b ose nk flanges, or deactivated valves secured in position, exce ed 1st e .6.3-1 of Specification 3.6.3.

c. By verifying each primary containment air lock is in compliance with the requirements of Specification 3.6.1.3.

d. By verifying the suppression chamber is in compliance with the require- l ments of Specification 3.6.2.1.

• See Special Test Exception 3.10.1.

alves, flanges, and deactivated automatic valves which ar I inside the co and are locked, sealed or ot ecured in the l closed position. These M h r fied closed during each COLD SHUTOOWN except such verif eed no ed when the primary l containment en deinerted since the last verif c re often per 92 days.

FERMI - UNIT 2 3/4 6-1 Q L/ p ,1 0 77

i Insert A -

b. At least once per 31 days by verifying that all primary containment penetrations except those inside the containnent or in locked high radi.. tion areas not capable of being closed by CPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by locked closed valves, blank flanges, or dea:tivated automatic valves secured in position, except as provided in Table 3.6.3-1 of Specification 3.6.3.

1. Valves, flanges, and deactivated automatic valves which are located inside the containment, and are locked, sealed or otherwise secured in the closed position shall be verified J closed during each CGD SHinDWN except such verification need not be performed when the primary containment has not been deinerted since the last verification or more often than once per 92 days. ,

2. Locked closed valves, flanges, and deactivated autcenatic valves which are located outside the containment within locked high l radiation areas shall be verified closed during each cad I SHtHDOWN if not performed within the previous 31 days. The penetrations in locked areas which resnain high radiation areas during the CED SHinDOWN may be verified by review of high radiation area access controls.

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_3/4.6.5 SECONDARY CONTAINMENT SECONDARY CONTAINMENT INTEGRITY ,

LIMITING CONDITION FOR OPERATION 3.6.5.1 SECONDARY CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, and ".

ACTION:

Without SECONDARY CONTAINMENT INTEGRITY:

a. In OPERATIONAL CONDITION 1, 2, or 3, restore SECONDARY CONTAINMENT INTEGRITY within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT SHUTOOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUT 00WN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. In Operational Conoition * , suspend handling of irradiated fuel in the secondary containment, CORE ALTERATIONS and operations with a ,

potential for draining the reactor vessel. The provisions of l Specification 3.0.3 are not applicable. )

SURVEILLANCE REQUIREMENTS j l

4.6.5.1 SECONDARY CONTAINMENT INTEGRITY shall be demonstrated by: l y' a. Verifying at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the vacuum within the secondary l containment is greater than or equal to 0.125 inch of vacuum water gauge.

b. Verifying at least once per 31 days that:

1. All secondary containment equipment hatches and pressure relief doors are closed and sealed and one railroad bay access door is closed. j.

2. At least one door in each access to the secondary containment l is closed. 7 g jy fy g;g7/g gg l All secondary containment penetrations 4not capable of being 3.

closed by OPERABLE secondary containment automatic isolation dampers / valves and required to be closed during accident conditions are closed by valves, blank flanges, or deactivated gugmgicdampers/valvessecuredintheclosedposition. 7 cl. )(. At least once per 18 months:

1. Verifying that one standby gas treatment subsystem will draw down the secondary containment to greater than or equal to 0.25 inch of vacuum water gauge in less than or equal to 567 seconds at a flow rate not exceeding 3800 cfm, and

2. Operating one standby gas treatment subsystem for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and main-taining greater than or equal to 0.25 inch of vacuum water gauge in the secondary containment at a flow rate not exceeding 3000 cfm.

• When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.

FERMI - UNIT 2 3/4 6-51

i Insert B

c. Valves, flanges, and deactivated automatic isolation danpers/ valves which are located within locked high radiation areas and required to be closed as described in Section 4.6.5.1 shall be verified closed during each Cao SanDOWN if not perforned within the previous 31. days.

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