NRC-88-0005, Application for Amend to License NPF-43,revising Tech Specs Tables 3.3.2-1,3.3.2-2 & 3.3.2-3,deleting Nongenerative HX Outlet Temp Signal from RWCU Sys Isolation Signals.Fee Paid

Application for Amend to License NPF-43,revising Tech Specs Tables 3.3.2-1,3.3.2-2 & 3.3.2-3,deleting Nongenerative HX Outlet Temp Signal from RWCU Sys Isolation Signals.Fee Paid

ML20196J914
Person / Time
Site:	Fermi
Issue date:	03/10/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196J918	List: ML20196J932 NRC-88-0005, Application for Amend to License NPF-43,revising Tech Specs Tables 3.3.2-1,3.3.2-2 & 3.3.2-3,deleting Nongenerative HX Outlet Temp Signal from RWCU Sys Isolation Signals.Fee Paid
References
CON-NRC-88-0005, CON-NRC-88-5 NUDOCS 8803150099
Download: ML20196J914 (7)

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, . B. Ralph Syida C<oup Vice Prescent Detroit 6 w-Ec ison =43) North'hoeHrghway March 10,1988 NIC-88-0005 U. S. Ibclear Pegulatory Conmission Attn: Docunent Control Desk Washington, D. C. 20555 Peference: Fermi 2 IE Docket tb. 50-341 tGC License No. IPF-43 S2bject: Proposed Technical Specification (Licensa Anendnent) Change

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Purstaant to 10CFR50.90, Detroit D31 son Conpany hereby proposes to amend Operating License IPF-43 for the Fermi 2 plant by incorporating the enclosed changes into Technical Specification Tables 3.3.2-1, 3.3.2-2 an3 3.3.2-3. The proposed change deletes the Ibn-regenerative Heat Exchanger (NRHX) Outlet Tenperature-High signal from the listing of Peactor Water Cleanup (IWCU) system isolation signals.

Detroit Fdison has evaluated the proposed 'Nchnical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Chsite Peview organization has approved and the tbclear Safety Review Group has reviewed these proposed Technical Specification changes and concurs with the enclosed determinations.

Pursuant to 10CFR170.12(c), enclosed with this anendnent is a check for one hundred fifty dollars ($150.00) . In accordance with 10CFR50.91, Detroit B31 son has provided a copy of this letter to the State of Michigan.

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8803150099 880310 PDR ADOCK 05000341 p DCD

USNBC March 10,1988 NIC-88-0005 Page 2 If you have any questions, please contact Mr. Glen Ohlemacher at (313) 586-4275.

Sincerely, Enclosure cc: A. B. Davis E. G. Greenman T. R. Quay I W. G. Ibgers ,

Supervisor, Advanced Planning and Review Section, '

1 Michigan Public Service Comission 6

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USNIC March 10,1988 NIC-88-0005 Page 3 I, B. PAIPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circunstances which are true and accurate to the best of my knowledge and belief.

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8. PAIfH SY~ A Group Vic resident On this day of dist/% z_, 1988, before me '

personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act and deal.

ed M Notary Public KAREN fl PIED ticury Public, TAcntce County, fdkh.

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Enclocure to NRC-88-0005 Page 1 BACKGBOUtD/ DISCUSSION Technical Specification 3/4.3.2 - Isolation Actuation Instrunentation, Table 3.3.2-1 in Item 2 provides isolation actuation instrunentation requirements for the Reactor Water Cleanup (INCU) system which are applicable in Operational Conditions 1, 2, and 3. Setpoints and surveillance requirenents for these signals are provided in Tables 3.3.2-2 and 3.3.2-3. The signals are also identified in UFSAR Section 7.6.1.7. These isolation signals, with the exception of the Standby Liquid Control System (SICS) initiation signal, cause the inboard and outboard isolation valves of the I6CU inlet line to isolate (valve groups 10 and 11) . The SIfS initiation signal causes the IMCU outboard isolation valve (valve group 11) to isolate. The MCU return line isolation is provided by a dual check valve arrangenent. The MCU system is described in UFSAR Section 5.5.8.2.

The Non-Regenerative Heat Exchmger (NFIN) Outlet Tenperature-Ligh signal acts to isolate the IMCU system at a tenperature of 1407 at the NRIE outlet. Following removal from service or an isolation of the IMCU system, thermal migration from a large volune of hot water trapped in the IMCU system to the smaller volune of colder water at the NRIE outfet causes the NRIE outlet tenperature to rise to greater than the 140 F NRIE Outlet Tetperature High setpoint. This secon3 signal acts to "soal in" the IMCU isolation and prevent tinely restoration of the MCU. This typically occurs in the period following a reactot scram from power since the scram transient may also cause a MCU punp trip.

Returning MCU to service in a tinely fashion is highly desirable during the post-scram period since the MCU system enhances reactor water level control and reactor water quality. However, having to perform a conplex, difficult operational sequence to return the MCU to service with the NRIM Outlet Tenperature-High isolation present is detrinental because the operator is extrenely busy during this period controlling the dynamic plant conditions.

The Technical Specification Bases for the isolation signals listed in Table 3.3.2-1 is to "ensure the effectiveness of the instrunentation used to mitigate the consequences of accidents by prescribing the operability trip setpoints and response tines for isolation of the reactor systens."

The non-regenerative heat exchanger outlet tenperature high isolation has no accident mitigation function. The basis for this 3. solation is to protect the ion exchange resins from deterioration due to high tenperature (UFSAR Section 7.6.1.7.3.1) . The isolation of the demineralizer resin vessels from the recctor vessel on high

Enclosure to hPC-08-0005 Page 2 tenperature will be retained in order to enharce system reliability and reduce the potential for detrinental reactor water chemistry.

Prevention of resin deterioration ensures the maintenance of clemup capacity and minimizes the potential for the introduction of chemical species which may be detrinental to reactor materials. The Non-regenerative heat exchanger outlet tenperature high signal is not utilized in the PHCU leak detection system. The MCU leak detcction is described in UFSAR Sections 7.6.1.7 ard 7.6.1.8.8. In addition, the RWCU pipe break evaluation is described in UFSAR Section 3.6.2.2.5.

In conclusion, the NRHX Outlet Tenperature High Signal acts solely to enhance ion exchange resin life by preventing resin deterioration and does not provide a feature to protect the public health or safety.

Based upon the above, Detroit Edison proposes to delete Item 2.f from Tables 3.3.2-1, 3.3.2-2 and 3.3.2-3.

The proposed changed pages are attzched.

S9tCUCBE.IBN@S_C0tiBDERM'ICH In accordance with 10CFR50.92, Detroit Eison has made a determination that the proposed anendnent involves no significant hazards considerations. Tb trake this determination, Detroit Eison nunt establish that operation in accordance with the proposed anendnent would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of cocident from any accident previously evaluated, or, 3) involve a significant reduction in a margin of safety.

1) The proposed change to remove Item 2.f from Tables 3.3.2-1, 3.3.2-2 and 3.3.2-3 does not involve a significant increase in the probability or consequences of an accident previously evaluated. The NRHX Outlet Tenperature-High signal does not mitigate postulatcd accidents and only acts to enhmce ion exchange resin life by preventing resin deterioration.

Features to prevent resin deterioration from high tenperature are being retained. Therefore, the change will result in no change to the assunptions or scenarios used to evaluate the probability or consequences of evaluated accidents.

2) The proposed change to remove Item 2.f from Table 3.3.2-1, ,

3.3.2-2 and 3.3.2-3 does not create the possibility of a new or !

different kind of tecident from any accident previously evaluated. The change does not modify system operation and no safety-relatcd equipnent is altercd. The NMIX Outlet I

Enclosure to NIC-88-0005 Page 3 Tenperature-IIigh isolation signal is not requira3 to prevent any accident. Features to prevent resin deterioration from high tenperature are being retained. Therefore, the requested change does not create any new accident mode.

3) The proposed change to rtinove Item 2.f from Table 3.3.2-1, 3.3.2-2 and 3.3.2-3 does not involve a significant reduction in a margin of safety. The NRIfX Outlet Tenperature-IIigh isolation signal is not relied upon to provide a margin of safety.

Therefore, the removal of the signal from Technical Specifications does not reduce any margin of safety.

Based on the above reasoning, Detroit D31 son has determined that the proposed amendnent does not involve a significant hazards consideration.

ENTIBOMIENmL IWACT Detroit Fdison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environnental considerations . As shown above, the proposed changes do not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or ctmulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed 'Ibchnical Specifications do neet the criteria given in 10CFR51.22(c) (9) for a categorical exclusion from the requirenent for an Environnental Inpact Statenent.

CRCLUSICH 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 Consission's regulations and proposed anendnents will not be inimical to the conmon defense and security or to the health and safety of the public.

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, E Erclosure to IE.'-88-0005 Page 4 PIEPOSED CBMEED PAGES

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