NRC-88-0226, Application for Amend to License DPR-09,allowing Facility to Be Maintained as Present Safe Storage Condition

Application for Amend to License DPR-09,allowing Facility to Be Maintained as Present Safe Storage Condition

ML20154L838
Person / Time
Site:	Fermi
Issue date:	09/15/1988
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154L843	List: ML20154L846 NRC-88-0226, Application for Amend to License DPR-09,allowing Facility to Be Maintained as Present Safe Storage Condition
References
CON-NRC-88-0226, CON-NRC-88-226 NUDOCS 8809260314
Download: ML20154L838 (13)

Text

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Nxmar Operates v.y Detroit ,.-

Edison EEF" 22-Septarber 15, 1988 NIC-88-0226 U.S. tbclear Regulatory Ccanission Attn Document Control Desk Washington, D. C. 20555

Reference:

1) Fermi 1 NBC Docket No. 50-16 NBC License No. DPR-9

2) Letter NRC to Detroit Edison, "Fermi 1, Extension of Possession Chly License, Request for Additional Information", July 28, 1988

3) Letter Detroit Edison to NBC, "Amendment Request for Extension of the Possession Only License for Fermi 1",

NE-85-0714, May 17, 1985

4) Letter !EC to Detroit Edison, "Request for Additional Information",

February 27, 1986 j 5) Letter Detroit Edison to NRC, "Supplemental Information on Fermi 1, VP-86-0092, July 23, 1986

6) Letter far to Detroit Edison, "Request for Additional Information",

May 22, 1986

7) Letter Detroit Edison to NIC, "Request for Additional Information As outlined in 10CFR51.45(b) for Fermi 1",

VP-86-Oll8, Septenber 15, 1986

8) Letter 100 to Detroit Edison, "Request for Additional Information -

t:nrico Fermi Atanic Power Plant, Unit Ib.1",

Decenber 2,1986

9) Intter Detroit Edison to NBC, "Sutnittal of Environmental Information for Fermi 1",

100-87-0051, May 5, 1987 8809260314 800915 PDR hOy5 P ADOCK 05000016 pg y

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US NRC 9/15/88 NRC-88-02P Page 2

10) Letter Detroit Edison to NIC 'Nransmittal of Supplemental Envirorynental Information Enrico Fermi Atctnic Power Plant, Unit 1",

NIC-87-0174, Septenber 25, 1987

Subject:

Proposed Technical Specification 01ange

.(LiG9Dse AmeDdmentL Fermi 1 On May 17, 1985 Detroit Edison requestal (Reference 3) that the Possession Only License for the Enrico Fermt Atomic Power Plant Unit 1 be extended 40 years, to expire in March 2025, at which time it is intended that all residual activity will be removed if desirable. %e extension would allow Fermi 1 to be maintained in its present safe storage (SAFSIOR) condition.

In addition to the current request for additional information (Reference 2) there has been correspondence (References 4, 5, 6, 7, 8, 9, & 10) and a meeting between the NRC Staff and Detroit Edison personnel on this amendment request. This document supplements References 3, 5, 9, and 10 and directly addresses the latest request for additional infornation (Reference 2) by proposing revised Femi 1 Technical Specif teations.

The proposed Technical Specifications have been revised to reflect the requests /recomendations as indicated in Reference 2 and current plant practices. Reference 2 requested the addition of Technical Specifications to monitor the liquid waste (approximately 7550 gallons) presently stored in two waste tanks at Fermi 1, unless this liquid waste is processed and disposed of within a short period of time (6 to 8 months). Monitoring specifications for the liquid waste have not been incorporated into this revision. Evaluation of the disposal options is underway and is expected to be completed by Decertber 31, 1988. By this time we will either sutmit ou6 plan, schedule and analysis for disposal of the 7550 gallons of contaminated water or submit the appropriate TS changes for monitoring and periodic sampling.

Since non-radioactive water can intrude through the Fuel and Repair Building drains and sunps and be punped to these wasta water tanks, including by infrequent testing of the sump punps, additional waste water may accunulate in the future.

Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License DPR-9 for the Fermi 1 plant as indicated in the enclosed proposed Plant Technical Specifications.

Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and detemined that no significant hazards consideration is involved. We Fermi Unit 1 Review Carmittee has approved J

US NRC 9/15/88 NRC-88-0226 Page 3 the proposed Technical specifications and concurs with the enclosed determinations.

'Ihe amendment fee, in accordance with 10CFR170.12(c) was included with Detroit Edison's initial amendment request (Reference 3). In accordance with 10CFR50.91, DetLoit Edison has provided a copy of thie letter to the State of Michigan.

If you have any questions please contact Mr. Gordon A. Nader at (313) 586-4513.

Sincerely, William S. Orser Vice President

!Alclear Operations GN/pir Enclosure cc: Mr. R. Cooper Mr. A. B. Davis Mr. P. B. Erickson Mr. T. R. Quay Mr. W. G. Rogers Supervisor, Mianced Planning and Review Section Michigan Public Service Cc m ission i

US NRC 9/15/88 NRC-88-0226 Page 4 l

I, WILLIAM S. ORSER, do hereby affirm that the foregoing statenents are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

WILLIAM S. ORSER Vice President, Nuclear Operations On this / Y k day o _

_ _-. 1988, before me personally appeared William S. Orce ng first duly sworn and says that he executed the foregoing as his free act and deed.

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Nottif Public hbhlh senJ. u s n:N Moksy P@% Meene Couafy. M1 84Comnestor@gemeen&tePt

US NBC 9/15/88 NRC-88-0226 Page 5 BfD UCIRD&l9flESIQi The Technical Specifications (TS) have been revised to reflect the present status of Fermi 1 and appropriate NPC rules and guidelines. This revision is largely administrative in nature with the majority of the changes imposing equivalent or slightly more restrictive control on the facility.

The changes are categorized, relative to the current TS, into three groups: 1) Updates to reflect current plant practice, current plant configuration or current industry practices, 2) additional surveillance requirenents, and 3) modification of existing requirenents to less restrictive current industry practices. A discussion of each category follows:

1. Updates to reflect currerst plant configuration, curreric plant practices, or currerit industry practices.

a. The Protected Area Definition (Section A.2) has been utxiated to be consistent with the 10CPR20(a)(14) definition of a Restricted Area.

b. The Necessary Conditions for Operation (N00) Definition has been deleted because other proposed changes to the TS (i.e.:

Surveillance requirenents) clearly spcify requircd plant conditions and traintenance evolutions for SAFSTOR of the facility,

c. The Periodic Test Activity Definition (proposed Section A.6) has been renamed "Surveillances" to be more nearly consistent with the majority of the tuclear Inx3ustry, Ferni 2, arri the lEC reconmendations as indicated in Reference 2. This definition has also been updatcd to describe how surveillance activities are currently initiated. !UTE: See section 3.a of this enclosure for discussion of proposed surveillance interval maximum allowable extension p riod.

d. The Abnonal Occurrence Definition (proposed Section A.7) has been renamed "Licensee Event Report" to be consistent with the rajority of the tuclear Industry, Fermi 2 and the imC's reccmmendations as indicated in Reference 2. The imC has also requested that any operation or condition prohibited by the plant's Technical Specifications require a LER. his requirenent is consistent with 10CFRSO.73(a)(2)(i)(B) . The tern Licensing Event Report (LER) is also used in proposed Specificatiorv3 I.8 and I.9.a.

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e. Figures B-1 and G-1 "Facility Plan" and "Sanpling Sites for Enrico Femi Unit 1 - Environmental Survey", respectively, have been updated to incorporate the present status of the facility and site. This ulxlate was requested by the NIC as indicated in Referen',i 2.

We Environmental Surveillance Specification (Section G) has been updated to clarify that the background sanpling stations for Swan Creek, Monroe and Detroit raw city water and Fenni Plant raw water are not shown on Figure G-1.

f. %e Facility Description Specification (Section B-1) has been updated to require all access points to the Protected Area to be locked except when open for use by an authorized person.

W is addition to the TS reflects current practices used to control access to the facility and is consistent with the NRC's recmmendations as indicated in Reference 2. Wis description has also been updated by deleting the reference to retirement work, which has been conpleted, and by replacing the term "site exclusion area" with the current terminology "owner controlled area".

9 The Primary System / Storage Tank Cover Gas Specification (Section D.1) has been updated to delete the option of using nitrogen as a reserve and backup supply cover gas. The primary system is connected to reserve and backup supplies of carbon dioxide, not nitrogen, to passivate the residual sodium. The name of this section has been changed because ,

1 the sezion no longer contains requirenents exclusively for

! the Primary System. A weekly surveillance requirement -

, pertaining to the sodium storage tanks in the Sodium Duilding

! canplex (which are not considered part of the primary system) has been added. ,

The Backup SuIrly Specification (Section D.2) has been modified by adding the words "Primary System". This change was made to clarify that only the Primary Systen has a cover gas backup supply.

h. The Fuel and Repair Building - Pools Specification has been r deleted. W is specification, which required sufficient l storage pool water level for shielding of blanket t subassenblics, is no longer needed because no radioactive '

i subassenblies are stored in the pool or on site. The final shipnent of blanket subassenblies off-site was conpleted in April, 1975.

US NRC 9/15/88 NRC-88-0226 Page 7 The Fuel and Repair Building - Access Specification (Section [

E.1) has been updated to retlect current practices used to ,

control access to the building. '

i. %e Radioactive Effluents Specification (Section F) requirements have been updated to reference the applicable ,

10CFR20 concentration limits for liquid gut gaseous effluents. We current TS requirements only specify radioactive liquid effluents. % is change is consistent with '

NRC recomendations as indicated in Reference 2. Section F has also been updated to reflect that liquid effluent  !

, monitoring equipment would have to be installed prior to any j liquid releases,

j. %e Facility Monitoring - Alarm (Section H.1) surveillance frequency has been modified from "not to exceed 7 months" to 4

"semi-annually" for consistency with other surveillance rea"irements. W is will allow the surveillance to adapt easier to a routine surveillance schedule (i.e., weekly,  ;

month 15, quarterly, smi-annually, annually, etc.) . Also, the proposed surveillance definition has a generic 25 percent 4

grace allowance which applies to all surveillances, if required. Additionally, this section and Table H-1 have been mdified by clearly specifying the location of the water 9

1 intrusion alarTns.

k. The primary syste pressute maxinum alarm point has been specified in Table H-1 "Formi 1 Monitoring Elements." This

, addition is consistent with the NBC's recomeMations as ,

indicated in Reference 2.

The Waste Water Sump water intrusion alarm point has also been added to Table 11-1. h is will ensure that the alarm is l checked semi-annually.

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! 1. A clarification sentuce has been added to the tocation of Alam Readout Specifications (Section H.2) . This sentence  ;

explains that a comon alarm for Formi Unit 1 is located in l the Fermi 2 control rom.

m. The Facility Monitoring - Radiation Surveillance (Section H.3) check frequency grace "not to exceed a four mnth interval" has been deleted. h e proposed surveillance definition has a generic 25 percent grace allowance which applies to all surveillances if requircd; thus, the current 3

specifications grace period is no longer required, i

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US tmC 9/15/88 fBC-88-0226 Page 8 Radiation surveillance of sodium drum storage areas inside the Fuel and Repair Building and the radiation analysis requir ments for blanket subassemblies storage pool water have been deleted because all sodium drums and blanket subassenblies have been rcmoved from the site. These updates are consistent with the imC's recomtrendations as indicatcd in Reference 2.

n. The Facility Pbnitoring - Inspection (Section H.4) has been updated to reflect present facility status. The current requir ments, which involve inspctions of large quantities of sodium that no longer exist on site, have been deleted and replaced with the surveillances discussed in Section 2.b of this enclosure. This update is consistent with the imC's recomendations as indicated in Reference 2.

o. The Administrative Standards (Section I) requirements have been ulxlated to reflect the expiration of the Power Reactor Develoirent Ccepany (PMX:) and the addition of present owner, The Detroit Edison Ccepany. This update is consistent with the tac's reccumendations as outlined in Reference 2.

p. The Administrative Operation Engineer Specification (Section I.2.a) has been incorporated into "Custodian or Delegate" and updated to reflect present responsibilities of the position.

Most of the work at Fermi Unit 1 is maintenance and surveillance orientatcd as opposed to operational; thus the existing title and description of this position is not accurate. The description has been updatcd to allow the person in this position to coordinate all of the work activities at the facility. This change is reflected throughout the proposed TS (i.e., Section A.4, A.5, A.6, and H.4.b).

q. The Administrative Maintenance Engineer specification has been deleted. This position, which was prinarily used to organize the retircrent tasks associatcd with dismantling the facility and to supervise the Plant Service Group, is no longer required because the current retircment plan has been conpleted. The Plant Service Group is an obsolete organizational title at Detroit Edison. Fermi 1 work is done by appropriate personnel provided from Fermi 2 or elsewhere in the Cocpany,

r. The Mministrative specification requircrnent for Operating Personnel has been deleted. This section, which required operator licenses when dealing with nolten sodium or

US NRC 9/15/88 NRC-88-0226 Page 9 transferring of liquid sodium, is no lorger required. All larger quantities of sodium have been rm oved from the site in accordance with the Decomissioning Plan which was formally completed in Novmber 1984.

s. The Health Physic Technician Specification (section I.3) has been renamed for clarification (the current name is Health Physic Surveillance). Also the requirment that this individual be approved by the Custodian has been deleted because it is repetitive to the proposed "Custodian or Delegate" definition,

t. The Administrative Control of Access to the Facility Specification (section I.5) has been updated by deleting the reference to the completcd retirment plan and by specifying the current facility access key control practice.

u. An Administrative Dosimetry specification (Section I 6) has been added. This specification defines the type of dosinntry required when inside the Protected Area for unescorted and escorted access. The addition of this specification is consistent with the t E 's reccarendation as outlined in Reference 2.

v. The Administrative specification on Procedures (Section I.7) has been updated by deleting the requirement to prepare and utilize procedures for transfer of sodium and blanket material. This requirement is no longer needed because all sodium and blanket material wre rmoved from the site in accordance with the Decmmissioning Plan which was formally completed in Novertber 1984,

w. The Administrative Record Keeping (Section I.9) Specificat. ion has been updated to include the applicable requirements of 10CFR50.75(g) - the new (June 27, 1988) decomissioning rule. The addition to this specification is consistent with the tE's reccmrendations as outlined in Reference 2.

The above proposed requirements are updated administrative changes that note clearly define and control plant nointenance and surveillance activities. These changes have been made to conply with the imC recomendations as indicatcd in Reference 2 or to obtain consistency throughout the TS with current practices. These changes will enhance the effectiveness of maintaining the facility in a safe condition.

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!ac-88-0226 Page 10

2. Added Surveillance Requirments:

a. %e following surveillance requirements have been aMad to the Primary System / Storage Tank Cover Gas Specification (Section D.3) in accordance with the WC's ra<vunnandations as indicated in Reference 2:

1. Cover gas ( ) pressure in the Primary Syste shall be checked recorded weekly. (Please note that the word "reactor" has been replaced by "Primary System" for clarification; the CO,, cover gas is over the Prinary Syst s , as defined by' Definition A.8, not just the reactor. This is a minor deviation from Reference 2.

This specific change is also applicable to Itan 2.a.2 below).

2. %e Primary System cover gas pressure relief valve shall be tested y.

3. Cbservation of the nitrogen cover gas pressure over essentially empty soditan storage tanks in the Sodium Building Ccuplex shall be performed weekly. (Please note that the Septenber 1987 Supplemental Environmental Inf: nration Report (Reference 10) mistakenly identified carbon dioxide as the cover gas for the sodium storage tanks. Also, the words "in the Sodium Building Cmplex" have been added to clarify the location of the sodium storage tanks. The addition of these words was not addressed by Reference 2.)

b. The following surveillance requiranents have been ackled to the racility Monitoring - Inspection Specification (Section H.4) in accordance with the IUC's rccormendations as indicated in Reference 2:

1) A weekly general walk-through and inspection of the Protected Area shall be performed.

2) A monthly inspection of the Protected Area shall be made and potential prcblons reported to the Custodian or Delegate.

3) A monthly level check of liquid in the waste tanks shall be recorded. (Please note that the word "volume" has been replaced by "level" for operational convenience.

%is is a minor change frcrn Reference 2) .

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4) A mnthly visual water level check frons the top of all active sumps shall be performed. (Please note that this requiranent has been modified from Peference 2 to clarify the specific activity performed.)

The addition of the above proposed surveillances will increase the control of the facility by increasing t'.e amount of information used to assess the plant's status. This additional infomation will allow for timely and corrective accions to prevent unusual or unexpected conditions on theso systems.

3. Modification of existing requirements to less restrictive requirenents that are consistent with current industry practices:

a. The proposed Surveillance definition (Section A.6) includes a generic 25 percent time tolerance for performing surveillance activities beyond the specified normal surveillance interval; the existing TS do not have this type of provision. ' Itis tolerance is necessary to provide sore operational flexibility because of scheduling and performance considerations. For exanple, environmental sa:rples are best taken during mild weather conditions.

b. The current Liquid Effluent TS (Section F) limits discharges of radioactivity to one MPC at any given time and 1/30 MPC when averaged over a year. The proposed specification limits discharges to the limits given in 10CFR20, Appendix B, Table II, Column 2 i.e., one MPC when averaged over a period not to exceed one year (10CFR20.106(a)). The proposed specification is consistent with the ?mC's recentrendations as indicated in Reference 2.

Even through the above proposed rcquirarents are less restrictive than the current TS requirements, they are consistent with proven irdustry practices which have acceptable margins of safety designed into than.

There is no unique reason why these iMustry requirements cannot apply to Fermi 1.

SJGUFJDNtJtMN06_fD61 DIN 2'JCN In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed TS anen&cnt involves no significant hazards considerations. 'Ib make this determination, Detroit Edison nust establish that operation in accordance with the propoced anen&cnt

US NRC 9/15/88 NRC-88-0226 Page 12 would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the p ssibility of a new or different kind of accident from any accident previously evaluated, or, 3) involve a significant reduction in a margin of safety.

1. The proposed changes outlined above in Section 1 are administrative changes that more clearly define and control current plant mintenance and surveillance activities. These changes enhance the effectiveness of maintaining the facility in a safe condition.

The proposed changes outlined above in Section 2 increase the nunber of surveillance requirments. Theco surveillances will result in additional control of the facility by increasing the amount of information used to assess the plant status. This will ensure sufficient time for corrective action to preclude any unusual or unexpected condition.

The proposed changes outlined above in Section 3 are consistent with proven industry practices that have acceptable m rgins of safety designed into thcm. There is no unique reason why these requircrnents cannot apply to Fermi 1.

Thus, the changes will not involve a significant increase in the probability or consequences of an accident previously evaluated because collectively the changes JpcIspan the effectiveness of mintaining the facility, lacIsasa the arount of information used to assess plant status, and align the facility closer to accepted and proven industry requircrnents.

2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluatcd because the changes introduce no new node of plant operation nor involve any physical modification to the plant.

3. The proposed c Mnges do not involve a significant reduction in the margin of safety because the majority of the changes are either note clearly defined administrative or note restrictive surveillance requirments which enhance the overall safety of the facility.

US NRC 9/15/88 NRC-88-0226 Page 13 Based on the above, Detroit Edison has determined that the proposed TS amendment does not involve a significant hazards consideration.

ElmDHt0ERHQ Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental 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 off-site, nor significantly increase individual or cunulative occupational radiation 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 frm. the requirement for an Environmental Inpact Statement.

GM221Gi Based on the evaluations above: (1) there is reasonable assurance that the health and safety of the giblic will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Ccanission's regulations and the proposed amendment will not be inimical to the coimon defense and security or to the health and safety of the public.

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