NRC-87-0248, Application for Amend to License NPF-43,revising Tech Spec Sections 3/4.6.1 & 3/4.6.5 to Allow Closure Mechanisms for Primary & Secondary Containment Penetrations Located in Locked High Radiation Areas to Be Verified Closed.Fee Paid

Application for Amend to License NPF-43,revising Tech Spec Sections 3/4.6.1 & 3/4.6.5 to Allow Closure Mechanisms for Primary & Secondary Containment Penetrations Located in Locked High Radiation Areas to Be Verified Closed.Fee Paid

ML20148Q166
Person / Time
Site:	Fermi
Issue date:	01/26/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20148Q172	List: NRC-87-0248, Application for Amend to License NPF-43,revising Tech Spec Sections 3/4.6.1 & 3/4.6.5 to Allow Closure Mechanisms for Primary & Secondary Containment Penetrations Located in Locked High Radiation Areas to Be Verified Closed.Fee Paid
References
CON-NRC-87-0248 NUDOCS 8801290352
Download: ML20148Q166 (7)

Text

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l; B. Ralph SyM3 Group %ce President Detrol.t

=== 64 t-C ISOn =00NarthDmeHegn*ay r *a January 26, 1988 NIC-87-0248 U. S. Nuclear Regulatory Conmission Attn Document Control Desk Washington, D. C. 20555

Reference:

Fermi 2 NIC Docket No. 50-341 NBC License No. NPF-43

Subject:

Propm ' Technical Specification Change (License Ame6 t) - Primary Containment (3/4.6.1) and Secondary Coni ent n/4.6.5)

Pursuant to 10CFR50.90, Detroit Fdison Conpany hereby proposes to anend Operating License NPP-43 for the Fermi 2 plant by incorporating the enclosed change into the Plant Technical Specifications.

The proposed change allows closure mechanisms for primary and secondary containnent penetrations which are located in locked high radiation creas to be verified closed each Cold Shutdown (if not performed within the previous 31 days) rather than every 31 days.

Additionally, the proposed revision clarifies that the primary containment penetrations .locatal in locked areas which rm.ain high radiation areas during the Cold Shutdown may be verified by review of high radiation area access controls. This proposed change inplenents the AIAFA (As Low As Reasonably Achievable) philosophy while still giving assurance that containnent integrity is being maintained.

Detroit Fdison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved.

The Fermi 2 Cnsite Review Organization has approved and the Naclear Safety Review Group has reviewed the proposed Technical Specifications ard concurs with the enclosed determinations.

Pursuant to 10CFR170.12(c), encioned with this anendnent request is a check for one hundrcd fifty dollars ($150.00) .

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USNRC January 26, 1988 NRC-87-0246 Page 2 In accordance with 10CFR50.91, Detroit Rlison has provided a copy of this letter to the State of Michigan.

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

Sincerely, Enclosure

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cc: A. B. Davis E. G. Greenman T. R. Ctlay W. G. Rogers Supervisor, Advanced Planning and Review Section, Michigan Public Service Comission l

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USNIC .

January 26, 1988 NIC-87-0248 Pge 3 I, B. PALPH S'lLVIA, 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 SE9I Group Vice President On this 26FL _

day of____[ 6 m r

,1988, before me personally appeared B. Ralph Sylv'la,- being first duly sworn and says that he executed the foregoing as his free act and deed.

Ys. 4)t. -

Notary Public I

KAREtt~frREED f:tt:ry Put.lic, facnroe County, Mich.

(tr, rinicn Expires May 14. 1999

Enclosure to NIC-87-0248 Page 1 I. BACKGROUPD/ DISCUSSION 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 contairment penetrations not capable cf being closed by operable containnent automatic isolation valves ard requird 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 containnent is recognized by providing a decreased frequency for such valves. Specification 4.6.5.1.b.3 provides a similar 31-day surveillance requirerent for secondary containnent penetrations.

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

Physical verification of each item locatM within a locked high ra31ation area during full power operation would result in an estimated occupational exposure of ten (10) man-ren each year.

Detroit Edison believes that this exposure is excessive considering that the penetrations are located in locked areas to which entry is closely controlled.

The proposed specification would establish a verification frequency for such penetrations located in locked high radiation areas of each Cold Shutdown, if not perforned within the previous 31 days, and allow penetrations located in locked areas which remain high radiation areas during the Cold Shutdown to be verified by review of high rMiation 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. The control over locked high radiation area entry greatly reduces the probability of any penetration being disturbed. The proposed surveillance frequency for penetrations t located in locked high radiation areas could be considered as l providing equivalent assurance of containnent 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 containnent bourdary valves, it is definitely reasonably achievable.

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Enclosure to NIC-87-0248 Page 2 SIGNIFICANP IRZAIDS COPEIDEIRTION In accordance with 10CFR50.92, Detroit Bilson has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit n11 son has established that operation in accordance with the proposed amerdnent would not: 1) involve a significant increase in the probability or consequences of an xcident previously evaluated, or 2) create the possibility of a new or different kind of mcident from any mcident previously evaluated, or 3) involve a significant reduction in a margin of safety.

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

2. The proposed change does not create the possibility of a new or different kind of accident from any mcident previcusly 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 significant reduction in a margin of safety. The proposed change only contains an alternative frequency and method of verifying a primary and secordary containnent penetration isolation and thus results in an identical plant configuration with an unchanged margin of safety.

COPCLUSION Based on the evaluations above: 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 conpliance with the conmission's regulations and the proposed amendnent will not be inimical to the common defense and security or to the health and safety of the public.

II. REVISFD 'ITCHNICAL SPBCIFICATI0tE The requested revision is attached.

III. ENVIROEDENmL DMCT Detroit Elison has reviewed the proposed 'Nchnical Specification changes against the criteria of 1CCFR51.22 for environnental l considerations. As shown above, the proposed changes do not involve a significant hazards consideration, nor change the types or increase

l Enclosura to NIC-87-0248 Page the amounts of effluents that may be released offsite, nor significantly increane irdividual or cunulative occupational' radiation exposures.

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

Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do neet the criteria given-in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Inpact Statenent.

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