NRC-12-0071, Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item Improvement Process

Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item Improvement Process

ML12318A337
Person / Time
Site:	Fermi
Issue date:	11/13/2012
From:	Conner J Detroit Edison, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-12-0071
Download: ML12318A337 (17)

Text

J. Todd Conner Director, Nuclear Production DTE Energy Company 6400 N.Dixie Highway, Newport, MI 48166 Tel: 734.586.5325 Fax: 734.586.5295 Email: connert@dteenergy.com DYE Energy-10 CFR 50.90 November 13, 2012 NRC-12-0071 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

Reference:

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

Subject:

Application to Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month,"

Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Detroit Edison is submitting a request for an amendment to the Technical Specifications (TS) for Fermi 2.

The proposed amendment would modify TS requirements to operate ventilation systems with charcoal filters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month in accordance with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month." provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed changes, for information only.

Detroit Edison requests approval of the proposed license amendment by May 15, 2013, with the amendment being implemented within 60 days.

No new commitments are made in this submittal.

USNRC NRC-12-0071 Page 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Michigan Official.

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

Sincerely,

Enclosures:

1. Description and Assessment of the Proposed Changes

2. Marked-Up pages of Fermi 2's Existing TS

3. Revised (clean) Fermi 2 TS pages

4. Marked-Up pages of Fermi 2 TS Bases (For Information Only) cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-12-0071 Page 3 I, J. Todd Conner, 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.

J. od Conner Site ice President, Nuclear Generation On this (3 day of N ove J/ , 2012 before me personally appeared J. Todd Conner, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S. MARSHALL NOTARY PULIC, COUNTY OF MONROE STATE OFMI ACTING MYCOMMISSION INCOUNTY OF /1-f o,Jun14, EXPIRES ro' 2013

Enclosure 1 to NRC-12-0071 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Description and Assessment of the Proposed Changes to NRC-12-0071 Page 1 Description and Assessment of the Proposed Changes 1.0 Description The proposed change revises the Surveillance Requirements which currently require operating ventilation systems with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days.

The Surveillance Requirements are revised to require operation of the systems for 15 continuous minutes every 31 days.

The proposed amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

2.0 Assessment 2.1 Applicability of Published Safety Evaluation Detroit Edison has reviewed the model safety evaluation dated September 20, 2012 as part of the Federal Register Notice of Availability. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-522. As described in the subsequent paragraphs, Detroit Edison has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to Fermi 2 and justify this amendment for the incorporation of the changes to the Fermi 2 TS.

2.2 Optional Changes and Variations Detroit Edison is not proposing any variations or deviations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 20, 2012.

The Fermi 2 TS utilize different numbering and titles than the Standard Technical Specifications (STS) on which TSTF-522 was based. Specifically, Fermi 2 TS 3.7.3 is titled "Control Room Emergency Filtration (CREF) System" and TSs 5.5.7 and 5.5.10 describe the "Ventilation Filter Testing Program" and "Technical Specifications Bases Control Program," respectively. These differences are administrative and do not affect the applicability of TSTF-522 to the Fermi 2 TS.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination Fermi 2 requests adoption of an approved change to the standard technical specifications (STS) and plant specific technical specifications (TS), to revise Technical Specification (TS) 3.6.4.3, "Standby Gas Treatment (SGT) System," and TS 3.7.3, "Control Room Emergency Filtration to NRC-12-0071 Page 2 (CREF) System to revise the Surveillance Requirement to operate the SGT System and CREF System with the electric heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days. The Surveillance Requirement is revised to require operation of the systems for 15 continuous minutes every 31 days.

As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:

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

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the SGT System and CREF System equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents. Thus the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change replaces an existing Surveillance Requirement to operate the SGT System and CREF System equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

to NRC-12-0071 Page 3 The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change replaces an existing Surveillance Requirement to operate the SGT System and CREF System equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

The design basis for the ventilation systems' heaters is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety. Based on the above, Detroit Edison concludes that the proposed change presents no 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.

4.0 Environmental Evaluation The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Enclosure 2 to NRC-12-0071 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Marked-Up Fermi 2 Existing TS pages

SGT System 3.6.4.3 SURVEILLANCE .EFREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for 31 days continuous with heaters operating.

SR 3.6.4.3.2 Perform-required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an 18 months actual or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT filter cooler bypass 18 months damper can be opened and the -fan started.

FERMI UNIT 2 3.6-50 Amendment No. 134

CREF System 3.7.3

(.SURVEILLANCE REQUIREMENTSFRQEC SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate -ne- CREP subsystem for z 4- 31 days -en- -

continuous with 4he. heate operating -STA6ERESe-T tubsysten for -.- 1 mtntite SR 3.7.3.2 ---------------- NOTE---------- -------

When the CREF system is made inoperable in MODE 1, 2, or 3 solely for VFTP required surveillances, entry into associated Conditions, and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Perform required CREF filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.3.3 Visually inspect silicone sealant on 12 months accessible portions of CREF system duct work outside the control room that are at negative pressure-during accident conditions and for which potential in-leakage would not receive full filtration.

SR 3.7.3.4- Verify each CREF subsystem actuates on an 18 months actual or simulated initiation signal.

(continued)

FERMI - UNIT 2 3.7-9 Amendment No. 134

Enclosure 3 to NRC-12-0071 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Revised (clean) Fermi 2 TS pages

SGT System 3.6.4,3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for z 15 31 days continuous minutes with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an 18 months actual or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT filter cooler bypass damper 18 months can be opened and the fan started.

FERMI - UNIT 2 3.6-50 Amendment No. "%

CREF System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREF subsystem for z 15 31 days continuous minutes with heaters operating.

SR 3.7.3.2 -----------------NOTE--------------------

When the CREF system is made inoperable in MODE 1, 2, or 3 solely for VFTP required surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Perform required CREF filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.3.3 Visually inspect silicone sealant on 12 months accessible portions of CREF system duct work outside the control room that are at negative pressure during accident conditions and for which potential in-leakage would not receive full filtration.

SR 3.7.3.4 Verify each CREF subsystem actuates on an 18 months actual or simulated initiation signal.

(continued)

FERMI - UNIT 2 3.7-9 Amendment No,

Enclosure 4 to NRC-12-0071 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Marked-up pages of Fermi 2 TS Bases (for information only)

SGT System B 3.6.4.3 BASES ACTIONS (continued)

Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

Ifboth SGT subsystems are inoperable inMODE 1,2,or 3, the SGT System may not be capable of supporting the required radioactivity release control function.. Therefore, actions are required to enter LCO 3.0.3 immediately.

E,1 ahd E.2

. Wien two SGT subsystems are inoperable, if applicable,

.movement of recently irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of.

these activities shall not preclude completion of movement of a component to a safe position. Also, if dpplicable, actions must immediately'be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown'and subsequent potential for fission product release. Actions

- must continue until OPDRVs are suspended.

The Required Actions have been modified by a Note stating that LCO 3.0.3 isnot applicable.' Ifmoving irradiated fuel assemblies while inMODE 4 or 5, LCO 3.0.3 would not specify any action. Ifmoving recently irradiated fuel assemblies while inMODE 1,2, or 3,the fuel movement is independent of reactor operations. Therefore, ineither case, inability to suspend movement of recently irradiated fuel assemblies would not .be a sufficient reason to require a reactor shutdown.

SURVEILLANCE SR' 3.6.4.3,1 g/so r REQUIREMENTS SOerating each SG subsystem from -the control room with flow through the HEPA ilters and charcoal adsorbers for -

continuous ensures that both subsystems are OPERABLE and that all associated controls are functioning properly.

It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action,

-pet e -heatePS-en-(utentde-heateP-eye4ng-te--

m~i~t~i tepertur) fr ~10 ontnuts hours-tevry oisture Uthe c3orber3 aA-FERMI UNIT 2 B 3.6.4.3-5 Revision 8

SGT System B 3.6,4,3 BASES SURVEILLANCE REQUIREMENTS (continued) oers: The 31 day Frequency was developed in consideration-of the known reliability'of fan motors and.

controls and the redundancy available inthe system.

SR ' 3.6,4.3.2 This SR verifies that the required SGT filter testing is performed inaccordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing.HEPA .filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed indetail inthe VFTP.

SR 3,6.4.3.3 This SR Verifies that each SGT subsystem starts and associated dampers open on receipt of an actual or simulated initiation signal. While this Surveillance can be performed with the reactor at power, operating experience has shown that these components usually pass.the Surveillance when performed at the 18 month Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function. Therefore, the Frequency was found to be acceptable from a reliability standpoint.

SR 3.6.4.3.4 This SR verifies that the filter cooler bypass damper can be remote manually opened and the fan remote manually started.

This ensures that the ventilation mode of SGT System operation is available. While this Surveillance can be performed with the reactor at power, operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was found to be acceptable from a reliability standpoint.

FERMI UNIT 2 B 3.6.4.3-6 Revision 8 I

CREF System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts from the control room on demand and continues to operate.

Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and notmal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. -leater-peratter dreis-out-M-4e--t haths-euua~I ah hrolas

. eft #r-e-um-44y-An4,ae-am crt-air.-9nsubsystem-mut-be-operate c~cgicop~ignra~ ic,.n cylngbtweefw 4hpaootr-y u omcd ni-be-per 9a4Gd-Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available. Th ITTt 3-1tjhour-t -ng m-be altornated each 31 d.ytet.]c that ahrdnnt SR 3.7.3.2 This SR verifies that the required CREF testing is performed in accordance with the Ventilation Filter Testing Program.

(VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail intheVFTP.

The Note for this SR provides an allowance to delay entry into the associated Conditions and Required Actions for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> inMODES 1, 2, and 3, This allowance prevents intentional entry into LCO 3.0.3 that would otherwise be caused by tests required by the VFTP. The tests that may be required while operating in MODE 1, 2, or 3 are: 1)the periodic charcoal sample; and 2) tests and samples required after exposing the filtration system to ventilation from '

painting, fire, or chetiical release; Other VFTP required surveillances can be scheduled when the plant is not operating in MODE 1; 2, or 3.

Operation with the heaters on for ' 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

FERMI : UNIT 2 B 3.7.3-7' Revision 0