Text

Application for Amend to License NPF-43,revising Tech Specs 3/4.3.7.5,3/4.6.6.2 & 3/4/10.5 Re List of Required Instrumentation in Order to Minimize Need for Interpretation in Tech Spec 3/4.3.7.5
	ML20206F340
Person / Time
Site:	Fermi
Issue date:	11/15/1988
From:	Sylvia B; DETROIT EDISON CO.
To:	; NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206F345	List: ML20206F347; NRC-88-0189, Application for Amend to License NPF-43,revising Tech Specs 3/4.3.7.5,3/4.6.6.2 & 3/4/10.5 Re List of Required Instrumentation in Order to Minimize Need for Interpretation in Tech Spec 3/4.3.7.5;
References
	CON-NRC-88-0189, CON-NRC-88-189 NUDOCS 8811210096
	Download: ML20206F340 (15)
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8. Ralph Syme Sm We Prekdeet t to .

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t N:wenber 15, 1988 i NtC-88-0189 j i

i U. S. tuclear Regulatory Cennission l Attnt Document Control Desk Washington, D. C. 20555 ,

References:

1) Fermi 2 [

NN: Docket No. 50-341 -

NN: License No. ?PF-43 j

2) Detroit B$ison letter to NR:, R:-I4-85-0050, "Regulatory Guide 1.97 Conpliance Report", date! :

l Feptember 30, 1985 l

3) BWR Owners' Group Licensing Topical Report, f l "Poultion on NM Regulatory Guide J .97, Revision -i l

3 Requireraents for Post-Accident Neutron l l

Monitoring System" (General Electric Report NEDO 5 i

31558)

L

Subject:

Proposed Technical Specifications Change (License :

l

! Amendment) - Accident Monitoring Instrumentation [

( (3/4.3.7.5), Drywell and Suppression Chamber Oxygen !

j Correctration (3/4.6.6.2), and Special hst j l Exceptions - Oxygen COTCentration l l (3/4.10.5) !

Pursuant to 10CFR50.90, Detroit Blison Co +any hereby proposes to amervi Operating License tet'-43 for the Fermi 2 plant by [

incorporating the erclosed changes into the Plant Technical :

Specifications. The proposed change provides a revised list of i

! required instrumentation in order to minimize the need for i interpretations in Specification 3/4.3.7.5, Accident Monitoring l Instrumentation. As a result of this prcposed change, other l Specifications were identified for concurrent changes. Table t 3.3.7.5-1 contains a footnote referring to a special hst l Exception for Oxygen Concentration. As the period for which this [

exception was valid has pansei, this change includes deletion of !

the Special Test Exception (Specification 3/4.10.5) arri !

corresporviing footnote in Specification 3/4.6.6.2 as well as !

deleting the Table 3.3.7.5-1 footnote. Deletion of the correeponding Bases for the Special Test Exception is also '

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proposed. !

9811210096 881115 gDR ADOCK 0500 g b I4 r

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USNBC Novenber 15, 1986 100-88-0189 Page 2 Detroit niison has evaluated the proposul Technical Specificationn against the criteria of 10CFR50.92 ary! determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Group has reviewel the proposed Tcchnical Specifications and concurs with the enclosed determinations.

Pursuant to 10CFR170.12(c), emlosal with this anordnent request is a check for one hundred fif ty dollars (S150.00) . In accordance with 10CFR50.91, Detroit niison htrs provided a copy of this letter to the State of Michigan.

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

Sincerely, QL Enclosure cct A. B. Davis R. C. Knop l J. R. Starg W. G. Rogers Supervisor, Mvancal Planning ard Review Section, Michigan Pulnic Service Ccanission l

USMC .

November 15, 1988 i 10C-88-0189 l Page 3 L 3.

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s j I, B. RAIPH SYLVIA, do heraby affirm that the foregoing f statments are based on facts arsi circunstances which are true ;

and accurate to the best of ny knowledge ard belief. l l

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n0 h 'B. RALPff SYLp [

Senior Vice President r i

i On this /6 day of _'OMW8JC._, 1988, before me personally appeared B. Ralph Sylvia, being first duly swo'.n ard l says that he exacuted the foregoing as his free act ard des 3. ;

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Enclosura to NRC-C-0189 Page 1 BACKGROUND DISCUSSION Technical Specification 3/4 3 7 5, Accident Monitoring Instrumentation, currently containa instrument requirements which are not well defined, particularly whcn more than one range of the instrument exists. For example, neutron flux is listed without indicating which range of instrument is required. The proposed change adds the required instrumentation to correspond to Regulatory Guide l 1 97, Revision 2, December 1980, in order to clarify the requirements. In addition, several othe:' changes are being proposed in order to clarify the instrumentation required to implement this Regulatory Guide in specific terms in order to minimize the need for i

clarification by 6he users. In addition to the proposed change to l Specification 3/4 3 7.5, Accident Monitoring Instrumentation, several l other Specifications were identified for revision.

Specifically, a footnote to the requirement for Drywell Oxygen i

Ct.ncentration in Table 3 3 7.5-1, Accident Monitoring Instrumentation, l references Specification 3 10.5, Special Test Exceptions-Oxygen l Concentration. This test exception was applicable with reactor I operational exposure up to 120 Effective Full Power Days (EFPD).

Fermi-2 has operated greater than this limit, and thus the exception is no longer valid. The special test exception is also footnoted in l Specification 3/4.6.6.2, Drywell and Suppression Chamber Oxygen l Concentration. Deletion of Specification 310.5 and corresponding references to 310.5 are included in this proposed change.

TECHNICAL SPECIFICATION CHANCES I The Technical Specification changa request would specifically charge the following items: (new language is underscored) l (1) 3/4.3 7.5, Table 3 3 7.5-1, item 2 l

1 Current: 2. Reactor Vessel Water Level, Fuel Zone Proposed: 2. Reactor Vessel Water Level

a. Fuel Zone E~ Wide Range The criteria of Regulatory Guide 1 97, Revision 2, December 1980,

! requires indication from the bottom of the core support plate te '

l the lesser of either the top of vessel or center line of the main steam lines. The fuel zone range is appropriate for monitoring the lower portion of this required range but not the higher portion. Therefore, wide range water level indication is also .

required to fully monitor the required range.

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Enclosure to NRC-88-0189 Page 2 (2) 3/4 3 7.5, Table 3 3 7.5-1, item 9 Current: 9. Drywell Oxygen Concentration 8

- - See Special Test Exception 3 10.5 Proposed: 9, Drywell Oxygen Concentration The special test exception is no longer applicable since 120 EFPD has been exceeded.

(3) 3/4.3 7.5, Table 3 3 7.5-1, item 13 Current: 13. Standby Gas Treatment Systen Radiacion Monitors ee

" High (accident) range noble gas monitors (one channel per flow path)

Required number of channels 2 Hiniaun Channels OPERABLE 2 ACTION 81 Proposed: 13. Standby Gas Treatment Systen Radiation Monitors **

a. SCTS - Neole Gas (Mid-range)

b. SGTS AXM-Noble Gas (Mid-range)

c. SGTS AXH-Noble Gas (High-range) as 1 per OPERABLE SGTS subsystem Required number of channels 2 Minimum Channels OPERABLE 2 ACTION 81 The radiation monitors installed in the SCTS system are located such that the SGTS mor itor and the SCTS AXM nonitors sample from ductwork for each subsystem rather than from a common ductwork.

l This means that these radiation monitors are dedicated to a given SCTS subsystem and therefore not redundant of each other regardless of the SGTS subsystem in service. As currently listed, this is not clear and requires an administrative l

clarification to support the Specification in regards to which I monitors support a given subsysten. The proposed change, which l will eliminate the need for clarification, lists the SGTS AXH l nid-range and high-range monitors which are the channals that are l required for monitoring in this Specification. The SGTS

nid-range noble gas monitor channel automatically starts the SGTS l AXM monitor. It is, therefore, required to support this Specification.

(4) 3/4.3 7.5, Table 3 3 7.5-1, iten 14 l

Current: 14. Neutron Flux

Enclosure to NRC-88-0189 Page 3 Required number of channels 2 Proposed: 14. Neutron Flux

a. Intermediate Range Monitors

b. Power Range Monitors Required number of channels 1/ division The current specification states "neutron flux" without specifying the instr *.inentation required. In order to comply with iatory Guide 1.97, Re'.*ision 2, December 1980, a range of regg%to100%powerisrequired.

10' In reference 2. Detroit Edison stated that the combined range of the Intermediate Range the Monitors (IRM)andAveradePowerRangeMonitors(APRM)meeg%to intent of the Regulatory Guide. The combined range is 10' greater than 100% power. Detroit Edison's position is that power monitoring at lower levels is not required following an accident because the functional requirement of assuring that a successful tor scram has occurred can be completed with a lower range of reag%.

10' Titis is more conservative than the Boiling Water Reactor Owners Group position submitted to the NRC in reference 3 which states that tho APRM instrument meets all post-accident neutron flux monitoring requirements. In order to clarify these requirements, the two ranges of neutron monitors have been specified as a subheading of the neutron flux entry.

1 Additionally, the current specification lists the required number of channels as 2. In order to provide redundancy in power supply and instrument electronics, it is desirable to specify 1 channel ,

per division.

(5) 3/4 3 7 5, Table 3 3 7.5-1, iten 15 l Current: 15. Drywell Susp Level Proposed: 15. Deleted Drywell sump level is listed in Regulatory Guide 1.97 Revision 2, December 1980 as a Type B and Type C variable as it indicates whether plant safety functions are being accomplished and provides indication as to the status of the Reactor ',oolant Systen Boundary. However, in the BWR Mark I containment design, the drywell sumps are isolated upon a 1,ots of Coolant Accident (LOCA) signal. Subsequently, the sunps fill and spill into the suppression pool where level information is available throughout the course of an accident. Since the post-accident function described for the Drywell dump Level indication in Regulatory ,

Guide 1.97 is carried out by the Suppression Pool Level instrument (whic' is listed in Specification 3 3 7.5) Detroit l

r . _ _ _ _ _ _ _ . -______ _ _ _ _ _ _ _ _ __ _

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Enclosure to NRC-88-0189 Page 4 Edison requests that Drywell Sump Level be deleted from this i Specification. The Drywell Sump Level instruments normal operating functiun continues to be covered by Specification 3/4 3 4.1, Leakage Detection Systems.

(6) 3/4 3 7 5. Table 3 3 7 5-1, item 16 Current 16. Primary Containment Isolation Valve Position 6 ACTION 80 Proposed: 16. Primary Containment Automatio isolation Valve Position ACTION 82 This item does not currently specify which primary containment isolation valves are required by this Specification. Regulatory Guide 1.97, Revision 2, December 1980, describes the purpose of this indication as being verification of the accomplishment of isolation and that check valves are excluded from the requirement. Detroit Edison believes that the intent of this ,

purpose is to ensure the operator has sufficient indication to i determine the position of valves which may have automatically changed position during the cou.ase of an accident. Manual isolation valves can only be reposi'.taned by direct operator action. This proposed change to adG the word "automatic" to the listed parameter will avoid further confustor..

ACTION 80, as currently required, results in the following i action With the number of OPERABLE accident monitoring instrumentation channels less than the Minimus Channels ;

OPERABLE requirements of Table 3 3 7 5-1, restore the inoperable channel (s) to OPERABLE status within 48 L hours or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ACTION 82, as proposed, results in the following action:

With the number of OPERABLE accident monitoring Instrumentation channels less than required by the l Minimum Channels OPERABLE requirements of Table 3 3 7.5-1, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months either j t

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t b< .

U - gnclosure to NRC-88-0189 Page 5 ;

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s. Restore the inoperable channel (s) to OPERABLE t status, or l

b. Declare the affected isolation va*Ve inoperable and h take the ACTION specified by Specification 3.6 3 i ACTION a. [

The time frame of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore OPERAg!LITY remains :'

unchanged in the proposed change. The ACTION of Specification 3/4.6 3, Primary Containeer.t tuolation valves, will result in , i appropriate isolation of the penetration or will result in a 1 shutdown to NOT SHUTDOWN within the next, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , as does ACTION :

80, and COLD SHUfDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ACTION 80 fails l to provide an esplicit requirement to reach COLD SHUTDONN. !

(7) 3/4 3 7 5, Table 4 3 7 5-1, Accident Monitoring Instrumentation Surveillance Wequirenents. j The Surveillance Requirements were revised to reflect the !

I revisions in Table 3 3 7 5-1 for the list of instruments. t (8) 3 6.6.2 APPLICABILITY !

Current: OPERATIONAL CONDITION 18 during... [

'See Special Test Except.icn 3 10.5 i i

Proposed: OPERATIONAL CONDITION 1, during... f The footnote, ', in the proposed change is being deleted since the APPLICABILITY requirements to apply the exception (less than i.

I 120 EFPD) has been exceeded.

i, (9) 3/4.10.5, oxygen Concentration i Current: The provisions of Specification 3.6.6.2 and the OPERABILITY requirements of the Drywell Oxygen [

Ccncentration instrument of Specification ,1 3 7.5 may l be suspended daring the performance of the Startup Test, (

Prograa untti either the required 10CJ of RATED THERNAL l' POWER trip tests have been completed or the reactor has ,

operated for 120 Effective hil Power Days. [

i Proposed: Since this exception is no longer valid due to the i plant exceeding 120 EFPD, this entire specification is i i

proposed to be deleted.

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. Enclosure to NRC-88-0189 Page 6 SIGNIFICANT HAZARDS CONSIDERATION, In accordance uith 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant bazards considerations. To make this determination, Detroit Edison must establish that operation in accordance with the proposed amendment 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 accident from any accidet.t previously evaluated, or 3) itivolve a significant reduction in a margin of safety,

1) The proposed charge to Technical Specifications 3/4 3 7 5.

Accident Monitoring Instrumentation, to list which instruments are required to monitor the required parameters over the ranges specified in Regulatory Guide 1.97, Revision 2, December 1980 for Reactor Vessel Water L,evel, Standby Gas Treatment System i Radiation Monitors, and Neutron Flux Joes r.ot involve e significant increase in the probability or con.=rquences of an accident previously evaluated. The proposed enange for Reactor Vessel Water '.evel licts Fuel Zone and Wide Range. The pi>oposed change for Standby Gas Treatment Systen Radiation Monitors lists SGTS-Noble Gas (Hid range) which is the channel that automatically starts the accident monitors, SGTS AXM-N(')1e Gas (Mid Range), and SGTS AXM-Noble Gas (High Range) which are the accident monitoring channels. The footnote clarifles that the i specified channels are required for each Standby Gas Treatment System subsystem since the monitoring channels monitor only a single subsystem each. The proposed change for Neutron Flux lists Power Range Monitors and Intermediate Range Monitors. This .

proposed change is an enhancement to provide a more detailed list

of required instrumentation. The probability and consequences of ,

an accident have not been increased by providing a more detailed I list of requirements. In addition, the change does not result in t

- any modifications to the plant or systen operation and no !

safety-related equipnent is altereo.

1

) The proposed change to Twchnical Specifications 3/4 3 7 5, 1 Accidens 'tonitoring Instrumentation, for Neutron Flux to change ;

the Required Number of Channels from 2 to 1/ division dces not l involve a significant increase in the probability or consequences (

of an accident previously evaluated. The proposed change r requires that of the 2 channels required, at least 1 of these !

' channels is in each division for purposes of redundancy in power I supply and instrument electronics. The probability t.nd l consequences of an accident have hot been increased by requiring redundancy for the required instrumentation and in fact it has ;

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- Encicsura L3 NRC-88-0189 Page 7 L

been decreased. In addition, the change does not result in any modifications to the plant or systen operation and no safety-related equipment is altered.

The proposed change to Technical Specifications 3/4 3 7 5.

Accident Monitoring Instrumentation, to add the word "automatic" to Primary Containment Isolation Valve Position does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change specifies ;

automatic valves, which are those specified in 3/4.6 3, Primary Containment Isolation Valves, Section A, Automatic Isolation Valves. This is consistent with the intent of Regulatory Guide l 1.97, Revision 2, December 1980. he probability and consequences of an accident have not been increased as this change is a clarification of the Specification. In addition, the change does not result in any modifications to the plant or l tystem operation and no safety-related equipment is altered. .

The proposed change to Technical Specifications 3/4 3 7.5.

Accident Monitoring Instrumentation Primary Containment Isolation Valve Position to change from ACTION 80 to 82 does nrt l involve a significant increase in the probability or consequences i of an accident previously evaluated. The proposed change allows i 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the indication to OPCHABLE status as does the current ACTION. At that time, the current Specification requires that the plant be in at least HOT SHUTDOWN within tt., next 12 l hours. '!he proposed change would declare the valve inoperable .

and specifies ACTION a. of Specification 3/4.6.3, Primary l' Containment Isolation Valves. If the ACTIONS of Specification 3/4.6 3 cannot be satisfied, this would also result in a shutdown to at least HOT SHUTDOW within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and further specifies COLD SHUTDOW within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The probability and r.onsequences of an accident have not been .

increased since the ACTIONS of the Primary Containment Isolation !

Valve specifirstion will ensure PRIMARY CONTAINMENT INTF.GRITY is i promptly restored or result in a shutdown to HOT SHUTDOW in the i

same period of time as the current specified ACTION and aaditionally requires the plant to be in COLD SHUTDOWN within the t following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In addition, the change does not result in any modifications to the plant or systen operation and no [

safety-related equipment is altered. ,

The proposed change to Technical Specifications 3/4 3 7.5, Accident Monitoring Instrumentation, to delete Drywell Susp Level .

I does not involve a significant increase in the probability or '

censequences of an accident previously evaluated. These sumps I r.re automatically isolated on a LOCA signal. The sumps will

Enclosura te

NRC-O-0189 Page 8 overflow to the Suppression Pool where level information is available throughout the course of an accident. The probability and consequencer of an accide.:t have not been increased since the post-accident function intended by Regulatory Guide 1.97, Revision 2, December 1980 is performed by the suppression pool instrumentation which is available and required by this Specification, In addition, the change does aot result in any modifications to the plant or system operation and no l safety-related equipment is altered.

The proposed change to Technical Specifications 3/4 3 7 5, ,

Accident Monitoring Instruner.tation, Surveillance Requirements, !

to coincide with the proposed changes to the required Instruments in Table 3 3 7 5-1 daes not involve a significant increase in the probability or consequences of an accident previously evaluated. ;

The proposed change to the Surveillance liequirements is necessary such that the Surveillance Requirements support the OPERABILITY ,

of the required instrumentation. The probability and !

consequences of an accident have not been increased as the l proposed change is required to support OPERABILITY of the instrumentation. In addition, the change does not result in any j modification to the plant or system operation and no

.afety-related equipment is altered.

l The propoacd change to Technical Specifications 3/4.10.5, Special Test Exceptions - Oxygen Concentratten, to delete the ,

specification and to delete the footnote in Specifications ,

3/4.3 7.5, Accident Honitoring Instrumentation and 3/4.6.6.2, f Drywell and Suppression Chamber Oxygen Concentration, which refers to this test exception does not invnive a significant increase in the probability or consequences of an accident previously evaluated. Tnis proposed change deletes a special test exception which is not applicable after 120 Effective Full Power Days (EFFD) of reactor operation. Fermi 2 has operated greater than this limit. The probability and consequences of an ,

accident have not been increr. sed since the Specification is no l longer valid due to exceeding the conditions of the exception.

In add 1 Lion, the change does not result in any modifications te l the plant or system operation and no safety-related equipment is 7 altered. ;

l

2) The proposed change to the Technical Specifications 3/4 3 7 5, l Accident Monitoring Instrumentation, to list which instruacnts :

l are required to monitor the required parameters over the ranges i

specified in Regulatory Guide 197, Revision 2, December 1980 for l Reactor Vessel Water Level, Standby Gas Treatment System l Radiation Monitors, and Neutron Flux does not create the l l l \

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Enclosura to NRC-88-0189 Page 9 possibility of a new or different kind of acci .r.t from any accident previously evaluated. As stated in 1, .Nye, the change does not result in any modifications to the plare or systen operations and no safety-related equipment is altered. 11,e requested change does not create any new accident mode. t The proposed change to Technical Specifications 3/'4 3 7.5, Accident Monitoring Instrumentation, Neutron Flux to changa t.he Required Number of Channels from 2 to 1/ division does not. cr % te the possibility of a new or different kind of accident from any accident previously evaluated. As stated in 1) above, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered. The requested change dcas not create any new accident mode.

The proposed change to Technical Specifications 3/4 3 7.5, Accident Monitoring Instrumentation, to add the word "automatic" <

i to Primary Containment Isolation Valve Position does not create the possibility of a new or different kind of accident from any accident previously evaluated. As stated in 1) above, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered. The r! quested change does not create any new accident mode.

The proposed change to Technical Specifications 3/4 3 7 5 Accident Monitoring Instrumentation, Primary Containment Isolation Valve Position to change from ACTION 80 to 82 does not create the possibility of a new or different kind of t.ccident f.*on any accident previously evaluated. As stated in 1) above, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered. The requested change does not create any new accident no<'e.

! The proposed change to Technical Specifications 3/4 3 7.5, l Accident Monitoring Instrumentatic,n, to delete Drywell Sump 1.evel !

does not create the possibility of a new or dif ferent kind of l 1 accident from any accident previously evaluated. As stated in 1) '

l above, the change does not result in any modifications to the i plant or system operation and no safety-related equipment is altered. The requested change does not create any new accident I mode.

The proposcd change to Technical Specifications 3/4 3 7.5, l

Accident Monitoring Instrumentation, Surveillance Requirements, to coincide with the proposed changes to the required instruments in Table 3 3 7.5-1 does not create the nossibility or a new of different kind of accident from any accident prt,viously

. Enclosura to NRC-88-0189 Page 10 evaluated. As stated in 1) above. the change does not result in any modifications to the plant or systen operation and no safety-related equipment is altered. The requested change does not create any new accident mode.

The proposed change to Technical Specifications 3/4.10.5, Special Test Exceptions - Oxygen Concentration, to delete the spectrication at,i tu delete the footnote in Specifjcations 3/4 3 7.5, Accident Monitoring Instrumentation and 3/4.6.6.2, Drywell and Suppression Chamber Oxygen Concentration, which refers to this test exception does not create the possibility of l a new or different kind of accident from any accident previously evaluated. As stated in 1) above, the change does not result in any modifications to the plant or system operation and no safety-related equipment is altered. The requested change does not create any new accident mode.

1

3) The proposed change to the Technical Specification 3/4 3 7.5, 1 Accident Monitoring Instrumentation, to list which instruments are required to monitor the required parameters over the ranges specified in Regulatory Guide 1.9", Revision 3, Decesber 1980, for Reactor Vessel Water Level, Jtandby Cas Treatment Systen Radiation Monitors, and Neutre.i Flux does not involve a l algnificant reduction in a margin of safety. As stated in 1) i above, this proposed change provides a more detailed list of the J

instruments required since the current Specification only lists I the parameter. Where more than one range of instrumentation is required to monitor the specific parameter, these instruments have been specified.

The proposed enange to Technical Specifications 3/4 3 7.5, Accident Monitoring Instrumentation, Neutron Flux to change the Required Nunber of Channels from 2 to 1/ division does not involve a significant reduction in a margin of safety. As stated in 1) above, this proposed cha:.ge does not reduce the number of channels required, but specifies that at least one channel is required for each division in order that this instrumentation be redundant.

The proposed change to Technical Specifications 3/4 3 7.5 Accident Monitoring Instrumentation, to add the word "automatic" to Primary Containment Isolation Valve Position does not involve a significant reduction in a margin of safety. As stated in 1) above, since the primary containment automatic isolation valves are the specific item of concern, adding the word "automatic" would serve to clarify the specific requirement.

Enclosure to vtC-C2-0189

. age 11 The proposed change to Technical Specifications 3/4 3 7 5, Accident Manitoring Instrumentation, Primary Containment Isolation Valve Position to change from ACTION 80 to 82 does not involve a significant reduation in a margin of safety. As stated in 1) above, this proposed change would revise the ACTION stateacnt such that after a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period to restore to OPERABLE status, reducing power to at least HOT SHUTDOWN within the next ;

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is not the only option. The proposed change would allow '

the alternative of declaring the valve inoperable and taking the ACTION required by Specification 3/4.6.3, Primary Containment ,

Isolation Valves, ACTION a. It may be possible to isolate the i penetration, as described in 3/4.6.3 and continue to operate. If this is not accomplished, the same ACTION would result, i.e., in at least HOT SHVTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and further, to COLD SHUTDC..H within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The proposed change to Technical Specifications 3/4 3 7 5 Accident Monitoring Instrumentation, to delete Drywell Sump Level does not involve a sippificant reduction in a margin of safety.

As stated in 1) abovt, the drywell sumps are isolated on a LOCA signal and the instraments do not perform a post-accident function. The sumpu, will overflow to the suppression pool where level can be monite,ted throughout an accident scenario.

t The proposed change to Technical Specification 3/4.3 7 5, Accident Monitoring Instrumentation, Surveillance Requirements, to coincide with the proposed changes to the required instruments in Table 3 3 7.51 does not involve a significant reduction in a margin of safety. As stated in 1) above, this proposed change la necessary la ordar to suppurt the OPERABILITY requirements of the instrumentation listed in Table 3 3.).5-1, Accident Monitoring Instrumentation, as revised by this proposed change.

The proposed change to Technical Specification 3/4.10.5, Special Test Exceptions - Oxygen Concentration, to del?te the specification and to delete the footnote in Specifications 3/4 3 7.5, Accident Monitoring Instrumentation and 3/4.6.6.2, Drywell and Suppression Chamber Oxygen Concentration, which refers to this test exception does not involve a significant reduction in a nargin of safety. As stated in 1) above, the provisions of this Specificaticn are no longer applicable since the operating exposure of the reactor core has exceeded 120 Effective Full Power Days. The test exception was only valid with exposures less than this maximum limit.

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

Enclosure to NRC-88-0189 Page 12 ENV!RONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification

hanges against the criteria 9f 10CFR51.22 for environmental consideratiors. The proposed change does not involve a significant hazards conssderatton, nor significantly change the typ6s or significantly increase the amounts of effluents that may be released ;

of fsita, nor significantly increase individual or cumulative occupational radiatier. exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet <

the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental tapact Statement.

i CONCLUSION Based on the evaluation above 1) there is reasonable assurance that the health and safaty of the pubito will not be endangered by !

operatioa in the proposed manner, and 2) such activities will be conducted in compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.

1 i

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NRC-88-0189, Application for Amend to License NPF-43,revising Tech Specs 3/4.3.7.5,3/4.6.6.2 & 3/4/10.5 Re List of Required Instrumentation in Order to Minimize Need for Interpretation in Tech Spec 3/4.3.7.5

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