ML20206P955

Application for Amend to License NPF-43,changing Tech Specs to Reduce Reporting Requirements on Primary Coolant Iodine Spikes & to Delete Shutdown Requirements,Per Generic Ltr 85-19.Fee Paid

ML20206P955
Person / Time
Site:	Fermi
Issue date:	06/27/1986
From:	Agosti F DETROIT EDISON CO.
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20206P961	List: ML20206P955 ML20206P963
References
GL-85-19, VP-86-0028, NUDOCS 8607020310
Download: ML20206P955 (6)

Text

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- ce P sus t Nuclear Operations M lI r.,ms : DT Edison BI5EF" Wm:1.

June 27, 1986.

VP-86-0028 Director of Nuclear Reactor Regulation Ms. Elinor G. Adensam, Director Project Directorate No. 3 Division of BWR Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555 1

Reference:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 l 2) NRC to Detroit Edison Generic Letter 85-19, " Reporting Requirements on Primary Coolant Iodine Spikes", dated September 27, 1985

Subject:

Request for Amendment to Technical Specification 3.4.5, Specific Activity Detroit Edison hereby requests revisions to the Technical Specifications for Fermi 2 in accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101. The proposed change is based on recommendations made in Generic Letter 85-19 concerning primary coolant iodine spiking.

Detroit Edison has reviewed the proposed change with the standards provided by the Commission for determining whether a significant hazards consideration exists (10CFR50.92(c)) and proposes a determination that no significant hazards are involved.

The technical description and the basis for a no significant hazards determination are provided in Attachment 1.

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Ms. E. G. Adensam June 27, 1986 VP-86-0028 Page 2 The affected Technical Specification pages from sections 3.4.5, 6.9, and Bases 3/4.4.5, are included in Attachment 2 for your use.

In accordance with 10CFR170.21, a check in the amount of

$150.00 in payment of a license amendment application fee is attached.

In accordance with 10CFR50.91, the State of Michigan has been provided a copy of this letter. If you have any questions concerning this matter, please contact Mr. R. L. Woolley at (313) 586-4211.

Sincerely,

~

l - $d With attachments cc: Mr. M. D. Lynch NRC Resident Inspector Supervisor, Advance Planning and Review Section Michigan Public Ser; ice Commission USNRC Document Control Desk Washington, D.C. 20555

Mr. E. G. Adansam June 27, 1986 VP-86-0028 Page 3 I, FRANK E. AGOSTI 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.

d FRANK E. AGOSTI Vice President Nuclear Operations On this day of , 1986, before me i

personally appeared Frank E. Ef6sti 3 being first duly sworn and says that he executed the foregoing as his free act and deed.

fY Notary Public f/MCIA EUCK Nctary Public. Washten: ; county, MI My Commission Expircs Dr.c.23,1937

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VP-86-0028  !

Attachment 1 TECHNICAL JUSTIFICATION AND SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGE TO FERMI 2 TECHNICAL SPECIFICATION 3.4.5 Description and Technical Justification NRC Generic Letter 85-19 identified two Technical Specification reporting requirements that may be deleted generically. The generic letter reduced the reporting requirements on primary coolant iodine spikes, as a part of the NRC's continuing program to delete unnecessary reporting requirements. The generic letter also revised the action requirements in the Specific Activity Technical Specification, to eliminate unnecessary requirements to shutdown a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period.

Both these suggested Technical Specification changes resulted from information gained through industry experience and improvements in the quality of nuclear fuel over the past decade. The generic letter noted that normal coolant iodine activity, industrywide, is well below the NRC Standard Technical Specification limits. Therefore, the NRC determined-these Technical Specification limits are no longer necessary on the basis that proper fuel management by licensees and existing reporting requirements [10CFR50. 72 (b) (1) (ii) ]

should preclude ever approaching the limits.

As suggested by NRC Generic Letter 85-19, this change will not relax the limit on Reactor Coolant System specific activity. Rather, the change is primarily administrative, relaxing only the requirements for reporting iodine spikes and for shutting down the plant if reactor coolant activity exceeds the previously specified limit for more than 800-hours per year.

Therefore, the radiological consequences from release of reactor coolant in a postulated accident remain unchanged from those calculated in the Fermi 2 FSAR. As noted in the NRC's Generic Letter 85-19, administrative controls, current sampling and analysis requirements, and improved fuel performance are adequate to assure that plant operation with coolant activity levels approaching the NRC's limit is extremely unlikely.

Accordingly, Detroit Edison requests that Fermi 2 Technical Specification 3.4.5, Specific Activity, be revised as shown in the attached markup.

p Al-2 VP-86-0028 Basis for No Sionificant Hazards Determination Detroit Edison has reviewed the proposed change per 10CFR50.92 and determined that the proposed change will not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated:

The proposed change is primarily administrative in nature, relaxing requirements for prompt reports of iodine spikes and for shutting down the plant if reactor coolant system activity exceeds the iodine limit for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> per year. This change does not increase the current limit on specific activity and, therefore, does.not increase the radiological consequences of any accident in which reactor coolant is postulated to be released to the environment.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated:

The proposed change is primarily administrative, and does not increase the current limits on coolant activity, or alter the conclusions presented in the Fermi 2 FSAR.

(3) Involve a significant reduction in the margin of safety.

Modifying the reporting frequency requirement is only an administrative change. Frequency of reporting'and the elimination of the provision for a percentage of total yearly operating time do not involve a significant reduction in a safety margin because proper fuel management, improved fuel quality and existing reporting requirements should preclude approaching the limit.

Therefore, Detroit Edison concludes that the proposed change does not present a significant hazards consideration under 10CFR50.92.

j A2-1 l VP-86-0028 )

Attachment 2 Proposed Changes for Technical Specifications 3.4.5 and 6.9.1.5 and Bases 1

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