NRC-10-0047, Proposed Emergency License Amendment for a Onetime Extension of the Completion Time in Technical Specification 3.7.3, Control Room Emergency Filtration (CREF) System, Condition B

Proposed Emergency License Amendment for a Onetime Extension of the Completion Time in Technical Specification 3.7.3, Control Room Emergency Filtration (CREF) System, Condition B

ML101370249
Person / Time
Site:	Fermi
Issue date:	05/14/2010
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-10-0047
Download: ML101370249 (16)

Text

Joseph H.

Joseph H. Plona Piona Site Vice President Site Vice President 6400N, 6400 N. Dixie Dixie Highway, Highway, Newport, Newport, MI!vII 48166 48166 Tel: 734.586.5910 Tel: 734.586.5910 Fax:Fax: 734.586.4172 734.586.4172 DYE EnergVy DTE Enell'gy~

10 10 CFR CPR 50.90 50.90 May 14, May 14, 2010 2010 NRC-IO-0047 NRC-10-0047 Nuclear Regulatory U. S. Nuclear U. Regulatory Commission Commission Attention: Document Attention: Document Control Control Desk Desk Washington DC Washington DC 20555-0001 20555-0001

Reference:

Fermi

Reference:

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

Subject:

Proposed Emergency Proposed Emergency License License Amendment Amendment for a Onetime Extension Extension of of Completion Time in Technical the Completion Technical Specification Specification 3.7.3, 3.7.3, "Control "Control Room Emergency Emergency Filtration (CREE)

(CREF) System, Condition B Pursuant to 10 CFRCPR 50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating Operating License, Appendix Appendix A, Technical Technical Specifications Specifications 3.7.3 "Control "Control RoomRoom Emergency Filtration (CREF) System,"

Emergency Filtration System," Condition B, "Two CREF subsystems boundary in MODE 1, 2 or 3,"

inoperable due to inoperable control room boundary 3,"

Completion Time from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> on a onetime basis.

Completion provides an evaluation of the proposed proposed license amendment, including an analysis of the issue of significant hazards consideration consideration using the standards of of 10 CPR CFR 50.92. Detroit Edison has concluded concluded that the change proposed in this submittal does not result in a significant hazards consideration.

consideration. Enclosure 2 provides marked up pages of the existing Technical Specifications Specifications to show the proposed change. Enclosure 33 provides a typed version of the affected Technical Specifications Specifications pages with the proposed change incorporated. No change change isis proposed to the current current Technical Specification Bases as aa result of this license amendment amendment request.

reviewed the proposed change against the criteria of Detroit Edison has reviewed of 10 CPRCFR 51.22 51.22 and has has concluded that it meets the criteria criteria provided in in 10 CPRCFR 51.22(c)(9) for aa categorical exclusion from the requirements for an an Environmental Environmental Impact Statement or or an Environmental Environmental Assessment.

Assessment.

USNRC USNRC NRC-10-0047 NRC-1O-0047 Page 2 Detroit Edison is requesting that this license amendment request be processed as an emergency emergency Technical Technical Specification change in accordance accordance with 10CFR50.91(a)(5) lOCPRSO.91(a)(5) where "failure to act in a timely way would result in derating or shutdown of a nuclear nuclear power power plant."

plant."

The Fenni Fermi 2 Onsite Review Organization Organization and Nuclear Nuclear Safety Review Group have reviewed reviewed and concurred with the proposed change.

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

infonnation, please additional information, Should you have any questions or require additional contact please contact Mr. Rodney W.W. Johnson of my staff at (734) 586-5076.

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

USNRC USNRC NRC-10-0047 NRC~1O~0047 Page 3 I, Joseph H. Plona, do hereby affirm that the foregoing statements are based on facts circumstances which are true and accurate and circumstances knowledge and accurate to the best of my knowledge and belief.

Joseph Joseph H. Plona Site Vice President, Nuclear Nuclear Generation On this 1;/

/day of dayof;G1 laya~ before me 2010 before

,,2010 appeared Joseph H. Plana, personally appeared being first duly sworn and says that he Plona, being he executed the foregoing as his free act and deed.

P(/L.~ A t-1r1~~~

Notary Public Public SMlONS MAORSHAE "YCMMIISU1N EXPIRES CfflNIWtUETs. A01s Jun14, onroe

ENCLOSURE ENCLOSURE 1 NRC-10-0047 TO NRC-IO-0047 50-341 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 NPF-43 PROPOSED EMERGENCY PROPOSED AMENDMENT FOR A EMERGENCY LICENSE AMENDMENT A ONETIME REVISION OF THE COMPLETION TIME OF CONDITION BIN B IN TECHNICAL SPECIFICATION 3.7.3 3.7.3 FOR THE CONTROL ROOM EMERGENCY FILTRATION (CREF) SYSTEM SYSTEM EVALUATION OF THE PROPOSED LICENSE AMENDMENT EVALUATION AMENDMENT to NRC-10-0047 NRC-l 0-0047 Page 1 of the Proposed Evaluation of License Amendment Proposed License Amendment

Subject:

Revision of the Completion Completion Time for Condition B of Technical Specification 3.7.3, Specification 3.7.3, "Control Emergency Filtration (CREF) System" "Control Room Emergency TABLE OF CONTENTS Subject Page 1.0 Description 2 2.0 Proposed Change 2 3.0 Background Background 2 4.0 Technical Analysis 3 5.0 Regulatory Safety Safety Analysis 6 6.0 Environmental Considerations Considerations 8 to NRC-10-0047 NR C-1 0-0047 Page 2 1.0 Description proposed onetime emergency revision to the requesting NRC approval of this proposed Detroit Edison is requesting Fermi 2 Technical Technical Specification Emergency Filtration (CREF)

Specification (TS) 3.7.3 "Control Room Emergency System," Condition B, System," subsystems inoperable due to inoperable control B, "Two CREF subsystems room control room boundary in MODE 1,2 Completion Time from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to complete repairs 1, 2 or 3," Completion of Division 2 Return Air Fan.

2.0 Proposed Proposed Change proposed change would allow the extension The proposed Completion Time for Condition B of TS extension of the Completion 3.7.3 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> on a onetime onetime basis.

3.0 Background Emergency Filtration (CREF) System and is applicable in governs the Control Room Emergency TS 3.7.3 governs irradiated fuel assemblies in the secondary 1, 2, 3, during movement of recently irradiated Modes 1,2,3, containment, and during dming operations with a potential for draining the reactor vessel (OPDRVs).

Condition B states that with two CREF subsystems inoperable inoperable due to inoperable control room boundary boundary in Mode 1,2,1, 2, or 3 the boundary OPERABLE status within 24 boundary is to be restored to OPERABLE Required Action of Condition B is not met within the hours. Condition C states that, if the Required the associated Completion Time, the unit must be placed in 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 MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Regulation Regulation 10 CPRCFR 50.91(a)(5) where the Nuclear Regulatory Commission (NRC) 50.91(a)(5) states that where emergency situation exists, in that failure to act in a timely manner would result in finds that an emergency derating or shutdown of a nuclear power plant, or in prevention of either resumption of operation operation output up to the plant's licensed power level, it may issue a license or of increase in power output license amendment involving amendment involving no significant hazards consideration consideration without prior notice and opportunity opportunity for a hearing regulation also states that the NRC will decline to hearing or for public comment. The regulation comment on the determination dispense with notice and comment determination of no significant hazards if it determines significant hazards determines emergency provision by failing to make timely application for licensee has abused the emergency that the licensee the amendment and thus itself creating the emergency. The regulation regulation requires that a licensee emergency amendment explain why the emergency requesting an emergency occurred and why the emergency situation occurred explained below, an emergency amendment licensee could not avoid the situation. As explained amendment is needed needed unnecessary plant shutdown, and Detroit Edison could not have reasonably to preclude an unnecessary reasonably avoided the situation or made timely application for an amendment.

At 0830 hrs on May 12, 2010, Division 2 of the Control Center Air Conditioning (AC) (AC) System System (TS 3.7.4) and Division 2 of the CREF System declared inoperable. This System (TS 3.7.3) were declared obtained on the Division 2 Return Air Fan declaration was made due to a high vibration reading obtained before the readings were taken, a loud cyclical rumbling noise in the inboard bearing. Shortly before to NRC-10-0047 NRC-1O-0047 Page 3 Control Room. Vibration readings taken on fan housing was heard in the area and in the Main Control shutdown and the TS administrative limit; therefore, the fan was shutdown the bearing exceeded the administrative Required Actions were entered. TS 3.7.4, Action A, for one inoperable control center AC OPERABLE status within 30 days and TS subsystem requires restoration of the subsystem to OPERABLE subsystem restoration of the subsystem to inoperable CREF subsystem requires restoration 3.7.3, Action A, for one inoperable OPERABLE OPERABLE status within 7 days.

bearing housing showed Spectral analysis taken on the fan bearing Spectral running showed several multiples of fan mnning indicates looseness in the fan bearings. Based on this, it has been determined speeds which indicates determined that vibration or a loose bearing was the likely cause of the high vibrations. No adverse trends in vibration or potential failure were known about this fan before other indications of potential before May 12, 2010.

developed for the repair of the Return Air Fan by replacing the shaft and both A plan has been developed outboard bearings. The plan requires breaching inboard and outboard section of the ductwork common breaching a section to both Divisions of the system; therefore, Condition B ofTSof TS 3.7.3 would be entered. The affecting the repairs indicates that the common schedule for affecting ductwork would be common section of the ductwork be open for 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> which is longer than the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time for restoring the control room boundary boundary to OPERABLE status.

There are three access hatches in the area where the fan repairs will be performed. Covers will hatches to provide access to the work area. The largest access hatch is be removed from these hatches is approximately 22 inches by 22 inches in size. Additionally, a smaller size hatch will be removed at the location where the fan shaft protrudes out of the ductwork. If the need arises during the time the system is breached, openings can be restored within 20 minutes by dedicated breached, all four openings dedicated personnel personnel stationed in the area for this purpose.

Amendment Request provides the technical basis for a onetime This Emergency License Amendment onetime extension of the Completion extension associated with Condition Completion Time associated of TS 3.7.3 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 48 Condition B ofTS requested to allow for completion of the repairs required to the Division 2 change is requested hours. The change return air fan in order to restore CREF subsystem OPERABLE status within the allowed 7-day subsystem to OPERABLE 7 -day for TS 3.7.3, Completion Time forTS 3.7.3, Condition A.

4.0 Technical Analysis Analysis radiologically controlled environment from which the unit can be System provides a radiologically The CREF System Accident (DBA). The CREF System is designed to operated following a Design Basis Accident safely operated maintain maintain the control room environment environment for occupancy after a DBA without a 30 day continuous occupancy without exceeding 5 rem whole body dose or its equi valent to any part of the body of the control room equivalent room occupants.

recirculated air, bypassing The CREF System normal mode supplies outside air to mix with recirculated bypassing the control room environment.

operations to maintain the control emergency filters, during normal unit operations Upon receipt of an initiation signal, the CREF System automatically switches to the recirculation

Enclosure I to Enclosure NRC-10-0047 NRC-1O-0047 Page 4 mode of operation contaminated air into the control room. A part of the operation to prevent infiltration of contaminated the recirculated air is routed through the emergency recirculation filter train. Outside air is taken in recirculated emergency outside air ventilation intakes and is passed through the emergency at one of two emergency emergency before being mixed with recirculated makeup filter train before makeup air. The air mixture is then returned to recirculated air.

the control room.

The ability of the CREF System to maintain the habitability of the control room is an explicit assumption for the safety analyses presented in the Fermi 2 Updated Final Safety Analysis recirculation mode of the CREF System is assumed to operate following Report (UFSAR). The recirculation accident involving recently irradiated coolant accident, fuel handling accident a loss of coolant steam irradiated fuel, main steam control rod drop accident.

line break, and control System performs The CREF System components and non-performs its safety function with redundant active components components The non-redundant redundant passive components components and both divisions of the non-redundant passive components components of the CREF System must be OPERABLE redundant active components OPERABLE to ensure that the safety function can be performed assuming any active single failure.

system safety inoperable CREF subsystem must be restored to inoperable, the inoperable With one CREF subsystem inoperable, OPERABLE status within 7 days. With the unit in this condition, OPERABLE remaining OPERABLE condition, the remaining OPERABLE adequate to perform control room radiation protection. However, the overall CREF subsystem is adequate because a single failure in the OPERABLE subsystem could result in reduced because reliability is reduced reduced CREF System capability. The 7 day Completion Completion Time is based on the low probability of probability of a DBA occurring during this time period, and that the remaining subsystem can provide the the required capabilities.

boundary is inoperable If the control room boundary inoperable in MODE 1,2 perform 1, 2 or 3, the CREF system cannot petform OPERABLE control room boundary intended function. Actions must be taken to restore an OPERABLE its intended within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24-hour Completion Completion Time is a typically typically reasonable time to diagnose, plan problems with the control and possibly repair, and test most problems boundary; however, for the control room boundary~

conditions described in this license amendment extension of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion amendment request, an extension complete the planned repairs.

Time is required to complete System is not assumed to be an initiator of any analyzed The CREF System analyzed accident. Therefore, the proposed change does not affect the probability of any accident previously evaluated.

accident previously Probabilistic Risk Assessment modeled in the Fermi 2 Probabilistic Additionally, the CREF System is not modeled prevention of core damage or large-mitigating function for the prevention (PRA) because it does not serve a mitigating early containment release; therefore, the PRA does not model the impact of the CREF System non-risk significant system in the Maintenance boundary outage time. CREF is also a non-risk Maintenance Rule qualitative and quantitative considerations).

(based upon both qualitative considerations).

shutdown and startup transitions. The Fermi Certain plant transients are more likely during plant shutdown 2 PRA does not directly model these transitions. Therefore, for the purpose of assessing these transitions, an increase in reactor trip frequency is assumed during shutdown and startup to NRC-10-0047 NRC-1O-0047 Page 5 transitions. Station PRA analysis indicates that the risk associated with plant shutdown transltlOns. shutdown and re-approximate increase in Core Damage Frequency (CDF) of about 9.8%

start would result in an approximate 9.8%

1.53E-06 per year) during the transition. The Large Early Release Frequency (baseline is 1.53E-06 Frequency 1.36% (baseline of 1.47E-07 increase is about 1.36%

(LERF) increase While 1.47E-07 per year). Whi remains Ie the overall risk remains low, this approximation approximation demonstrates increase in risk associated with the demonstrates that there is an increase the shutdown and startup transitions.

shutdown The additional requested requested 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allows maintenance personnel a total of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to complete maintenance personnel repairs when the common section of the system ductwork breached and the fan motor shaft is ductwork is breached required to be completed in order to repair Division 2 of the CREF pulled. This evolution is required System and exit the 7-day extension of Allowed Outage Condition. The requested 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension 7 -day TS Condition. Outage Time provides the plant staff with sufficient time to replace the fan shaft and bearings without bearings without entering a Technical Specification shutdown Technical Specification challenging the plant staff and equipment.

shutdown and challenging The NRC published a model safety evaluation and model no significant hazards consideration consideration Technical Specification (NSHC) for Technical Force (TSTF)-448 Specification Task Force regarding habitability of the control (TSTF)-448 regarding room envelope on January 17, evaluation and NSHC allows licensees to 17, 2007. The safety evaluation restoration action for the existing changing the restoration request changing existing technical specification condition for technical specification boundary from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 90 days, provided that mitigating actions are in place to control room boundary ensure that control room envelope occupants exposure to radiological, chemical and smoke envelope occupants exceed limits. The safety evaluation hazards will not exceed completion time for evaluation states that the 90 day completion restoration determination that mitigating actions will ensure protection restoration is reasonable based on the determination protection envelope occupants within analyzed limits while limiting the probability that of control room envelope protective measures that may adversely affect implement protective control room occupants will have to implement affect shutdown condition in the event of a their ability to control the reactor and maintain it in a safe shutdown Design Basis Accident Accident (DBA).

During the CREF System breach, compensatory measures will be in place compensatory measures place to restore the control boundary and Division 1 of the CREF System to operable envelope boundary room envelope operable status within 20 Accident (DBA) occur. A walkdown of the area has been minutes should a Design Basis Accident performed to identify any potential sources of hazards in the vicinity of the repair area that could could hazardous material into the control room envelope. No hazards result in the introduction of hazardous hazards in the immediate work area were identified that would pose any risk to control room occupants. It was also verified that no unnecessary combustibles are located in the area that could unnecessary transient combustibles could increase the risk of fire or smoke infiltration into the control room envelope. These increase measures and controls compensatory measures compensatory exposures control room occupant radiological exposures controls ensure that control calculated dose in the DBA analysis, and that control will be minimized and will not exceed the calculated room occupants occupants are protected from hazardous hazardous chemicals and smoke.

During the breach of the control room envelope boundary, the fan shaft will be removed removed and replaced with a new identical shaft that will seal the ductwork. If unforeseen problems are encountered that would prevent normal removal or installation encountered installation of the shaft, a temporary modification modification has been prepared to cover the fan shaft hole which would seal the common to Enclosure NRC-10-0047 NRC-1O-0047 Page 6 ductwork breach ductwork breach and restore the control room boundary. All access hatches and restore hatches can be restored restored needed by replacing the within 20 minutes if needed the hatch hatch covers securing the covers and securing the bolts.

While performing While Division 1 of the CREF System repair work on Division 2 return air fan, Division performing the repair System controls and power supplies will be protected. The including all the controls including The station work schedule station work schedule has reviewed to identify any risk been reviewed work during significant work risk significant All activities evolution. All during the evolution. activities identified identified significant will be suspended as risk significant suspended during breach evolution. Additionally, no other during the system breach other significant work will be allowed during risk significant during that time.

During the period control room envelope period that the control boundary is inoperable, envelope boundary inoperable, compensatory compensatory measures will be in place restore the boundary to protect control place to promptly restore control room occupants hazards such potential hazards from potential such as radioactive chemicals, smoke, contamination, toxic chemicals, radioactive contamination, smoke, temperature temperature conditions arise that would require restoration physical security. If conditions and relative humidity, and physical restoration ofof activities would be immediately maintenance activities the boundary, maintenance immediately suspended ductwork breach suspended and the ductwork breach dedicated personnel that will be stationed will be closed by dedicated specifically for this purpose. Once stationed specifically Once breach is restored, Division 1 of the CREF System the breach System is fully operable.

5.0 Regulatory Safety Safety Analysis Analysis In accordance accordance with 10 CFR 50.92, Detroit Edison has made a determinationdetermination that the proposed amendment involves no significant hazards amendment consideration.

hazards consideration. The proposed one-time change to increase the Control Room Emergency Filtration (CREF) system Technical Specification 3.7.3 Technical Specification 3.7.3 Required Required Action B Completion Completion Time for restoring the control room boundary from 24 to 48 consideration for the following reasons:

hours does not involve a significant hazards consideration 1.

1. The proposed change does not involve a significant increase in the probability or or consequences of an accident previously evaluated.

consequences The CREF System is not assumed to be an initiator of any analyzed analyzed accident. Therefore, Therefore, the proposed change does not affect the probability accident previously probability of any accident previously evaluated.

The CREF System is not modeled in the Fermi 2 Probabilistic Risk Assessment (PRA) because it does not serve a mitigating function for the prevention of core damage or large-early containment release; therefore, the PRA does not model the impact of the CREF boundary outage time. The Control Center Air conditioning (AC) and the CREF Systems significant systems in the Maintenance are non-risk significant Maintenance Rule (based upon both qualitative and considerations).

quantitative considerations).

The CREF System provides a radiologically controlled environment environment from which the plant can be safely operated following a Design Basis Accident. If the control room boundary is is inoperable in MODE 1,2, 1, 2, or 3, cannot perform its intended function.

3, the CREF system Call110t Actions must be taken to restore an OPERABLE control room boundary within the specified time. During the period that the control room boundary is inoperable, appropriate specified to NRC-10-0047 NRC-IO-0047 Page 7 compensatory measures (consistent with the intent of GDC 19) are utilized to protect compensatory protect control room operators from potential hazards such as radioactive control contamination, toxic radioactive contamination, chemicals, smoke, temperature chemicals, temperature and relative relative humidity, and physical security. The proposed Completion Time extension to provide for Division 2 Return Air fan one time 24-hour Completion maintenance is reasonable maintenance based on the low probability of a design basis accident (DBA) reasonable based occurring compensatory measures. The requested occurring during this period, and the use of compensatory requested one Technical Specification change time Technical Completion Time provides an adequate change to a 48-hour Completion adequate time to repair the Division 2 Return Air Fan and to restore the control room envelope envelope boundary.

maintenance work plan for repairing the Division 2 Return Air Fan includes stationing The maintenance stationing dedicated personnel in the vicinity of the breach area in radio contact with the control dedicated room. If necessary, the fan shaft hole can be sealed and the common access common ductwork access hatches hatches restored restored within 20 minutes to minimize minimize the potential for an unfiltered inleakage into the ductwork that can affect dose to the control room occupants occupants in the event of a accident A security watch will also be performed during the period the design basis accident. the control center envelope control temperature and humidity will be envelope is breached. Control room temperature controlled controlled by the Division 1 control center center air conditioning conditioning system which will be running running during the maintenance maintenance evolution.

evolution.

additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the proposed change to allow a onetime additional Therefore the proposed Therefore the pressure boundary inoperable control room pressure inoperable maintenance on boundary to operable status to facilitate maintenance significant increase in the probability or the Division 2 Return Air Fan does not involve a significant consequences accident previously consequences of an accident previously evaluated.

evaluated.

2. The proposed create the possibility of a new or different change does not create proposed change accident different kind of accident from any accident accident previously previously evaluated.

The proposed one-time change increases the CREF system Technical proposed one-time Technical Specification Specification 3.7.3 Completion Time for restoring the control room boundary from 24 to 48 Required Action B Completion hours.

No physical changes are being made to the installed considered installed CREF system that were not considered by the original Technical Specifications.

original Technical different accident scenarios are created Specifications. No new or different created by this change.

different kind of change does not create the possibility of a new or different Therefore, the proposed change Therefore, of accident from any accident accident previously evaluated.

3. The proposed change change does not involve reduction in the margin of safety.

involve a significant reduction discussed above the proposed onetime 24-hour Completion Time extension As discllssed extension to provide provide the time required to complete the maintenance activity is reasonable based on the low occurring during this period, and the use of compensatory probability of a DBA occurring measures.

compensatory measures.

to Enclosure NRC-10-0047 NRC-1O-0047 Page 8 The The maintenance work plan maintenance work plan for the the repair repair the the Division Division 22 Return Return Air Air Fan includes includes stationing stationing of the personnel in the vicinity of dedicated personnel dedicated the breach breach area inin radio contact the control contact with the room. If If needed, can be promptly needed, the fan shaft hole can common ductwork sealed and the common promptly sealed hatches can be restored access hatches access within 20 minutes to minimize restored within potential for an unfiltered minimize the potential unfiltered inleakage ductwork that can inleakage into the ductwork affect dose to the control room can affect occupants in the event room occupants event of aa design basis accident. Furthermore, design basis accident initiator and CREF system is not an accident Furthennore, the CREF and prevention of core function for the prevention does not serve a mitigating function damage or large-early core damage large-early containment containment release.

Therefore, involve a significant change does not involve Therefore, the proposed change reduction in the margin significant reduction margin of of safety.

on the above, Detroit Edison Based on proposed license amendment does determined that the proposed Edison has determined does not involve a significant significant hazards hazards consideration.

consideration.

6.0 Environmental Considerations Considerations reviewed the proposed Detroit Edison has reviewed proposed change criteria of 10 CFR against the criteria change against CPR 51.22 for considerations. The proposed environmental considerations.

environmental significant hazards proposed change does not involve a significant consideration, nor does it significantly change consideration, increase the amounts of significantly increase change the types or significantly of effluents that may be released offsite. During the system breach, effluents measures compensatory measures breach, compensatory are in envelope boundary and Di place to restore the control room envelope vision 1 of the Control Room Division Emergency Filtration (CREF) System to operable Emergency operable status within 20 minutes should a Design Basis change does not significantly Therefore, the proposed change Accident (DBA) occur. Therefore, Accident significantly increase individual or cumulative occupational radiation exposures.

cumulative occupational exposures. Based on the foregoing, Detroit Edison concludes that the proposed change meets the criteriacriteria provided CFR 51.22(c provided in 10 CPR 51.22(c)(9)

)(9) for categorical exclusion a categorical Environmental Impact Statement or an exclusion from the requirements for an Environmental Environmental Assessment.

Environmental

ENCLOSURE 2 ENCLOSURE TO NRC-10-0047 NRC~ 10~0047 FERMI 2 NRC DOCKET NO. NO. 50-341 50~341 OPERA TING LICENSE NO. NPF-43 OPERATING NPF ~43 PROPOSED EMERGENCY PROPOSED AMENDMENT FOR A LICENSE AMENDMENT EMERGENCY LICENSE A ONETIME OF THE COMPLETION TIME OF CONDITION REVISION OF REVISION CONDITION B B IN TECHNICAL SPECIFICATION 3.7.3 3.7.3 FOR THE CONTROL ROOM EMERGENCY EMERGENCY FILTRA TION (CREF) SYSTEM FILTRATION SYSTEM MARKED-UP TS MARKED~UP PAGE Affected Page:

3.7-6

CREF System CREF System" 3.7.3 3.7.3 3.7 PLANT 3.7 PLANT SYSTEMS SYSTEMS 3.7.3 Control 3.7.3 Control Room Room Emergency Emergency Filtration (CREF) System Filtration (CREF- System LCD 3.7.3 LCO 3.7.3 The CREF The CREF System System shall sha1l bebe OPERABLE.

OPERABLE.

-. -. --NOTE NOTE-------" . ---... -.. ""-. "-.. ----".. ------

The The control control room room boundary boundary may may be be opened opened intermittently intermittently under administrative under administrative control.

control.

APPLICABILITY:

APPLICABILITY: MODES 1, MODES I, 2, 2, and and 3,3, During movement During movement of of recently recently irradiated irradiated fuel fuel assemblies assemblies in in the secondary contai"nment, the secondary containment, During operations During operations withwith aa potential potential for for draining draining the the reactor reactor vessel vessel (OPDRVs).

(OPDRVs).

ACTIONS ACTIONS CONDITION CONDITION REQUIRED ACTION REQUIRED ACTION COMPLETION COMPLETION TIME TIME A. "One A. One CREF CREF subsystem subsystem A.l A.1 Restore CREF Restore CREF 77 days days 1inoperable, noperable. SUbsystem subsystem to to OPERABLE OPERABLE status.

status.

~

B. Twa B. Two CREF inoperable CREF subsystems inoperable due inoperable subsystems inoperable control roam-boundary room boundary in 1.

1, 2, 2. or or 3.

3.

due to to control in MODE MODE B.1 B.1 Restore Restore control boundary boundary status.

status.

control room to to room OPERABLE OPERABLE EV 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />'P C.C. Required Required Action Action andand C.l C.1 Be Be in in MODE MODE 3. 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours associated associated Completion Completion Time Time of of Condition" Condition-A A or or AND AND B not met in B not met in MODE 1, MODE 1, 2,

2, or or 3.

3. C.2 C.2 " Be Be in in MODE MODE 4. 4." 36 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> hours (continued)

(continued)

~~

tSThe The 24 hours Completion 24hours Completion Time extended toto48 Timeisis extended hours t~

48hours to co~plete complete repairs of epairs"of Division Division 22ReturnReturn Air AirFan Fanin May2010.

inM~y 2010.

FERI -NIT - ".3.7-6 . Amendment Amendment No". Bi, A.M, No. 134, /*t,149 149

ENCLOSURE 3 ENCLOSURE NRC-10-0047 TO NRC-I0-0047 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 OPERATING EMERGENCY LICENSE AMENDMENT PROPOSED EMERGENCY FOR A ONETIME AMENDMENT FOR ONETIME REVISION CONDITION B IN REVISION OF THE COMPLETION TIME OF CONDITION 3.7.3 FOR THE CONTROL ROOM EMERGENCY TECHNICAL SPECIFICATION 3.7.3 FILTRATION FILTRA SYSTEM TION (CREF) SYSTEM CLEAN TS PAGE CLEAN New Page:

3.7-6 3.7-6

CREF System CREF System 3.7.3 3.7.3 3.7 PLANT 3.7 PLANT SYSTEMS SYSTEMS 3.7.3 Control 3.7.3 Control Room Room Emergency Emergency Filtration Filtration (CREF)

(CREF) System System LCO 3.7.3 LCO 3.7.3 The CREF The CREF System System shall shall be be OPERABLE.

OPERABLE.

-"------ -- -- ------. . .... -NOTE -------

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

The control The control room room boundary boundary maymay be be opened opened intermittently intermittently under under administrative administrative control.

control.

APPLICABILITY:

APPLICABILITY: MODES 1, MODES 1, 2, 2, and and 3, 3,

During movement During movement of of recently irradiated recently irradiated fuel fuel assemblies assemblies in in the secondary the secondary containment, containment, During operations During operations withwith aa potential potential for for draining draining the the reactor react9r vessel (OPDRVs).

vessel (OPDRVs).

ACTIONS ACTIONS CONDITION CONDITION REQU I RED ACTION REQUIRED ACT! ON COMPLETION TIME COMPLETION TIME

.A.

A. One One CREF CREF subsystem subsystem A.l A.1 Restore CREF Restore CREF 7 days 7 days inoperable.

inoperable, subsystem to subsystem to OPERABLE OPERABLE status.

status.

B. Two B. Two CREF CREF subsystems subsystems B.1 B.1 Restore Restore control control room room 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*

24 hours*

inoperable inoperable due due toto boundary boundary to to OPERABLE OPERABLE inoperable inoperable control control status.

status.

room room boundary boundary inin MODE MODE 1.

1, 2, 2, oror 3.

3.

C.

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

2, or or 3.3. C.2 C.2 Be Be in in MODE MODE 4. 4. 36 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> hours (continued)

(continued)

• • The The 2424 hours0.0281 days <br />0.673 hours <br />0.00401 weeks <br />9.22332e-4 months <br /> hours Completion Completion Time Time is is extended extended to to 48 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> hours to to complete complete repairs repairs of of Division Division 22 Return Return Air Air Fan Fan in in May May 2010.

2010.

FERMI FERMI .- UNIT UNIT 22 3.7-6 3.7-6 Amendment Amendment No.No. ii4, Ai, AA4,

/A4, +/-49 149