NRC-89-0228, Supplemental Application for Amend to License NPF-43, Revising Tech Spec 3/4.3.7.5, Accident Monitoring Instrumentation to Add Fourth Instrument Range Per Generic Ltr 89-01

Supplemental Application for Amend to License NPF-43, Revising Tech Spec 3/4.3.7.5, Accident Monitoring Instrumentation to Add Fourth Instrument Range Per Generic Ltr 89-01

ML19332D337
Person / Time
Site:	Fermi
Issue date:	11/16/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19332D338	List: ML19332D339 NRC-89-0228, Supplemental Application for Amend to License NPF-43, Revising Tech Spec 3/4.3.7.5, Accident Monitoring Instrumentation to Add Fourth Instrument Range Per Generic Ltr 89-01
References
CON-NRC-89-0228, CON-NRC-89-228 GL-89-01, GL-89-1, TAC-72049, NUDOCS 8912010034
Download: ML19332D337 (5)

Text

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8.Calph Sylvb~ '

, ( t, e Senor Vice President .

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November-16,-1989 NIC-89-0228 7 U. S. Nuclear ~ Begulatory Consnission .

k Attn: Document Control Desk Washington, D. C. 20555 ,

References:

1) Fermi 2 NIC Docket No. 341 NIC License No. WF-43

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2) Detroit Edison Letter to NIC, NIC-88-0189,

" Proposed Technical Specification Change =

(License Amendment) - Accident Monitoring Instrumentation (3/4.3.7.5), Drywell and 1 Suppression Chamber Oxygen Concentration (3/4.6.6.2),. and Special Test Exceptions - >

Oxygen Concentration (3/4.10,5)", dated .

Novenber 15, 1988.

3) - NIC Generic Letter 89-01, "Inplementation >

of Progransnatic Controls for Radiological Effluent '

Technical Specifications 'in' the Administrative L

i' Controls Section of. the Technical Specifications 1

and the Relocation of Procedural Details of REIS to the Offsite Dose Calculation Manual or to the

. Process Control Program", dated January 31, 1989

Subject:

Supplement to Proposed Technical Specification f Change (License Amendment) - Accident Monitoring Instrmentation (3/4.3.7.5) (TAC No. 72049)

Pursuant to 10CFR50.90, Detroit Fdison Company hereby proposes to .

amend Operating License NF-43 for the Fermi 2 plant by incorporating y the enclosed changes. into the Plant Technical Specifications. The Reference 2 submittal proposed, among other things, to clarify the i requirements for the StanSby Gas Treatment System Radiation Monitors by specifying three instrument ranges of ' concern. This submittal adds ,

a fourth instrument range to the listing. Detroit Edison determined that it was appropriate to include the fourth instrument range in Specification 3/4.3.7.5 during the review of radiological effluent controls in conjunction with the inplementation of Generic Letter 89-01 (Reference 3) .

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• : 4 Novenber 16, 1989.

A NIC-89-0228 Page 2-Detroit Edison has determined that the no significant hazards ..

considerations analysis contained in Refereroe 2 remains applicable to.-

. the proposal as modified herein..

g The Fermi 2 Oncite Review Organization has approved and< the Nuclear.

Safety Review Group has reviewed the proposed Technical Specifications p

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and concurs with the enclosed determinations. In accordance with 10CPR50.91, Detroit Riison has provided a copy of this letter to the State of Michigan.

If you have any questions, please conta::t Mr. Glen Ohlemacher at (313)'

586-4275.

Sincerely, u

Enclosure i

cc: A. B. Davis  !

R. W. Defayette i

-W. G. Rogers J. F. Stang Supervisor, Advanced Planning and Review Section, Michigan Public Service Ccanission

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'*- ..  : Novenber~16,,1989 NHC-89-0228

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l I, B.' RALPH SYLVIA, do hereby affirm that the foregoing statenents are based on facts and circunstances which are true and accurate to the best of my knowledge and belief.

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5.' RALM1 SJLTIA Senior Vice President- cl i

1 On this / day of tW l - 1989, before me-personally appeared B. Ralph Sylfia, being- first duly sworn and says-  !

that he executed the foregoing as his free act and deed.

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Relosure to A -NHC-89-0228 w Page 1 1

i Modified Provisions for Standbv (tam Trenhant System Radiation Monitors In Reference 2 Detroit Edison proposed Tecimical Specification changes to clarify certain requiranents of Technical Specification 3/4.3.7.5, Accident Monitoring Instrumentation. Among these requirenents are those for the Standby Gas Treatment System (SGTS) Radiation Monitors.

Currently, the monitors of concern are poorly defined. Footnotes gplied-to the table items listire these nonitors indicate that'the j item refers:to the "High~ (accident) rage n&le. gas monitors." In 1 light of the information contained in these footnotes, Detroit Edison - :l proposed to specify the< two accident range instrument ranges, the

- SGTS-AXM -. Noble Gas (Mid-range and High-range), in the Reference 2; proposal along with the SGTS - Noble Gas (Mid-range) instrument range. 'Ihe lSGTS - Noble Gas (Mid-range)' was included since that instrument range contained the automatic start feature of the AXM ,I instrument ranges.

The SGTS - Noble Gas (Low-range) was not included in the Reference 2 listing of ranges since it is not associated with the description of 1 the monitors contained in the Table footnotes; that is, the SGTS -

Noble Gas (Low Range) is not a "High -(accident) range noble gas l monitor." Rather, it- is the normal range effluent monitoring '

instrument for the SGTS effluent pathway.

In Generic Letter 89-01, (Beierence 3) the NIC made provisions to allow licensees to relocate details concerning the controls for the .i l-normal effluent monitoring function to the Off-site Dose Calculation L

Manual (CDO6) . At Fermi 2, this would include the Technical l

Specification controls for the SGTS - Noble Gas (Low Range) 1 instrumentation.

In reviewing: the provisions in Generic Letter 89-01 Detroit R11 son 3 i

determined that the SGTS - Noble Gas (Low Range) played a role in the monitoring of releases in off-normal transient events. Included were transients which would cause Emergency Response Plan activation for abnormal radiological releases at the Alert level. For these' reasons,  ;

Detroit Fdison determined that the remedial actions contained in l Specification 3/4.3.7.5 for the SGTS accident range Noble Gas instrumentation should also be @ plied to the SGTS - Noble Gas (Low Range) Instrumentation.

Detroit Fdison considered applying these controls administratively ,

through the ODCM. However, for consistency it was determined that the requirement was best included with the requirenents for the other three ranges which had already been proposed to be listed in Specification 3/4.3.7.5.

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,f, Enclosure to'

- NIC-89-0228 Page 2-uit .

Cross-references between the entries in- Specification 3/4.3.7.5 and 3/4.3.7.12 for.the SGTS '- Noble Gas (Low-Range) Monitor were added to remind the users that the monitor appears in more than one location in I

• ' the Technical Specifications. This is a human factors enhancement.

For coupleteness; the' attached Technical SpecifJcation change pages include all changes proposed in Reference 2.

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This submittal modifies the Reference 2 proposal solely to amend the  :

list'ing of. instrument ranges provided to clarify the accident.

^ monitoring instrumentation for the SGTS. The basis for the proposed-

' conclusion that the Reference 2 prcposal does not involve a

. significant hazards consideration was published in the Federal

.Begister on May 17, ~ 1989 (54 FR 21305) . In regards to the

. clarification of the required SGTS Radiation Monitors instrumentation the conclusion was besed upon the proposed change solely providing a more detailed list of. requirements. Since this underlying purpose of the proposal remains-that of providing this detailed listing.of required' instrumentation, the conclusion as published does not change.

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