NRC-90-0042, Application for Amend to License NPF-43,changing Tech Spec 3/4.3.7.1 to Ensure That Second Fuel Storage Pool Area Criticality Monitor Maintained Operable

Application for Amend to License NPF-43,changing Tech Spec 3/4.3.7.1 to Ensure That Second Fuel Storage Pool Area Criticality Monitor Maintained Operable

ML20043B206
Person / Time
Site:	Fermi
Issue date:	05/18/1990
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20043B207	List: ML20043B208 NRC-90-0042, Application for Amend to License NPF-43,changing Tech Spec 3/4.3.7.1 to Ensure That Second Fuel Storage Pool Area Criticality Monitor Maintained Operable
References
CON-NRC-90-0042, CON-NRC-90-42 NUDOCS 9005250076
Download: ML20043B206 (6)

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.w .o 1 Wmaam S. orter1 h*S [ . a- t Vice President Nuclear operations '

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.l May 18,11990 NRC-90-0042-i  !

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U.1S. Nuclear Regulatory Commission Attns, = Document Control; Desk -

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Washington, D. C. .20555 Reference Fermi 2' NRC Docket' No. 50-341

.NRC License No. NPF-43  !

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Subjectt. Proposed ~ Technical Specification Change (License 1

. Amendment) ;- Radiation Monitoring Instrumentation "a (3/4.3.7'1)

Pursuant to 10CFR50.90. Detroit Edison Company hereby proposes to ai

".g amend: Operating License 'NPF-43 forl the Fermi 2 plant by incorporating. .j r the' enclosed change -into the Plant Technical Specificotions.- The

, , proposed : change to the subject Technical Specification .wilr ensure _ . ,

that;a.second_ Fuel Storage Pool-Area Criticality Monitor as required

". by 10CFR70.~24, is maintained OPERABLE.

Detroit Edison has evaluated the proposed Technical. Specification y' against the criteria- of.10CFR50.92 and determined that no significat ' "

hazards consideration is involved.. The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed the' proposed Technical Specification and-' concurs with the.

.g enclosed determinations. In accordance with 100FR50.91,. Detroit::

Edison'has provided a copy of this letter to the' State of'. Michigan. - '

l K;i.: . If you have -ony questions, please contact Mr. Gordon Nader at - (313) 3 l-1~ 586-4513. i Sincerely, l

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cc:- A. B. Davis '

@ R..W..DeFayette Qq$[37 9h/

nW. G. Rogers J. F. Stang:

~ Supervisor, Electric Operators, Michigan ,

L, Public' Service Commission - J. Padgett l

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May'18. 1990

- NRC-90-0042-j .; ,. Page 2

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I.- WILLIAM S. ORSER. :do hereby af firm that r.he foregoing. statements are based- on facts and circumstances which are 'true and accurate to-

.the best of my knowledge and belief.

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e WILLIAM S. ORSER -

. Vice President Nuclear Operations On this. / [b day of FAX , 1990, before me personally appeared William S. OrAKeing first duly sworn and says that-he executed the foregoing as his free act and deed..

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[N. 3 D' -- Enclosure 'to:

NRC-90-00421

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b, IlrTRODUCTION l q

,  : The, Criticality Area Monitors are designed; to provide a f ast alarm F response to initiate local personnel evacuation in the unlikely event N, '

- of'an ' inadvertent criticality and to alert control room personnel of .

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the, situation. -' The proposed amendment adds a requirement- that two U fuel storage pool: criticality ares monitors be OPERABLE when fuel ise i p i in the-storage pool (see proposed change attached).. The current

' '!echnical Specification (TS) requires only.one channel to be C^ OPERABLE. ;The. cecond monitor is proposed to ensure that the spent fuel' pool monitoring' re~ irements .of '10CFR70.24 " Criticality Accident g '

Requirements";are maintained. 10CFR70.24 requires, in part. that mach' applicable licensee maintain'in areas where specified quantities of g  : special nuclear materials are handled, used!or stored, a monitoring

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system _ consisting of:two detectors capable of detecting a criticality that produces an absorbed dose in sof t tissue of 20 rads of combined - .l 3 neutron and gamma radiation at unshielded distance of.2 meters from- I

/ the reacting; material within one minute. . Detroit Edison is currently -t y eJministratively controlling. In lieu of this proposed TS requirement.

two; monitors in order to ensure compliance with the specifled code requirement.- ~

- EVALUATION

The' Fermi 2f s criticality' monitoring system for the fuel pool storage j b area consists of two redundant detectors. D21-N115 (currently 1 required .;

by the TSs) .and D21-N117 (proposed to be included 'in the TSs). - These  ;

detectors are high sensitivity gamma ray detactors and are located on '

the east wall of the Reactor Buildink fifth floor (refueling floor) approximately 9; feet and 12 feet'above the floor. The-alarm system is '

designed to be fail safe such that a low (failure) alarm will be .

. activated.whenever the indicator and associated trip unit reaches a downscale setpoint due to a detector .or' circuit malfunction. Both j detectors have control room annunciation and a separate local audio -t E - ala rm.- Detector D21-N117 ~also is designed upon actuation to initiate a 1ocal beacon indicator.

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c ' Regule. tory Guide 8.12 " Criticality Accident Alarm Systemsa describes a j l' ,'

system that is generally acceptable to the NRC staf f. Fermi 2  ;

L criticality monitors for the fuel storage pool area are in compliance q b .. with the requirements of this regulatory guide.

$ t The alarm / trip setpoint(s) specified in the current TS has bee

- evaluated in accordance with Regulatory Guide 8.12 and determined to be appropriate for both of the spent fuel pool area criticality monitors. Therefore, the existing alarm / trip setpoint(s) is i

! "z applicable to both monitors, t L

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;The following changes' are proposed

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o The' number of Criticality Monitor Channels required to be- 1

< OPERABLE = for the Fuel Storage Pool- (TS Table 3.3.7.1-1 ~ Item 2.a.2)"has been increased from one to- two.

l o .' ACTION statement 72 has been added to- address the increase <in tr.e -

number of TS required Fuel Storage Pool Criticality Monitors andt associated compensatory requirements. Proposed ACTION statement 1!

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72 a)-- requires. that area surveys be performed. 'once per 24' hours 'j if one or more monitors are inoperable. - L This , requirement is ,

W!- consistent'with the-philosophy-of the existing.TS and the.  :>

Standard Technical Specification'(STS). Proposed. ACTION.

statement 72 ' b) requires that. a continuous monitor < (e.g. . l portable) be OPERABLE if both criticality monitorsiare inoperable  ;!

and fuel movement is in progress. Even though ACTION statement 72 b) is not required lby: the STS.t it more accurately addresses -

• the intent of the Limiting Condition for Operation (LCO) by 'i

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requiring a continuous monitor when fuel movement is -in progress

• and both criticality :nonitors are ia. operable. The proposed.

! wording' of--ACTION statement 72 b) isiconsistent withlthe current 'I TS wording of ACTION statement 81 which outlines compensatory measures for inoperable Containment High Range Radiation' Monitor

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channels. -(

lJ .c p The proposed changes are justified based on the following: [

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o 'The reliability of the Criticality Monitorirg System for the Fuel j Storage Pool has been increased-because an additional redundant :I

- monitor. will be required OPERABLE by the TSs. This will ensure that two Fuel ' Storage Pool Criticality Monitors are appropriately J' maintained - and OPSRABLE. .

o The proposed monitor, as well as the existing monitor, are in k, compliance with the requirements of Regulatory Guide 8.12. This Regulatory Guide has been generally accepted by the NRC for the y design of Criticality Accident Alarm Systems.  ;

o The addition of the proposed monitor into the Technical Specifications does -not physically modify the plant or introduce {

l a new mode of plant operation because existing equipment will be  !

used to comply with the proposed TS.-

4 o The proposed ACTION statement more accurately represents the LCO .t by requiring continuous monitoring of the subject area if both ,

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s . criticality monitors are inoperable and fuel movement is _in _:

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SIGNIFICANT HAZARDS CONSIDERATION g 'In accordance with 10CFR50.92.: Detroit Edison has: made a determination - J

. that the_ proposed' amendment involves no- significant hazards considerations. To make'this determination. Detroit Edison must-

establish that operation in accordance~with the_ proposed amendment would nots- 1): involve a significant increase in the_ probability or consequences of an accident previously evaluated or 2); create the-

,  ; possibility of a new or dif ferent kind of . accident from any accident previously evaluated. or 3) involve a significant reduction in a -f margin of. safety. ,  ;

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'1)- 'The proposed change does not involve a significant increase in l

' the: probability or consequences of an accident previously

-evaluated because the proposed change does not change or affect '

1any' accident or transient analysis, does not physically modify

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.the plant and does;not introduce a new mode of plant: operation.

The proposed change adds a second Area Criticality Monitor to the '

Technical Specifications to ensure that the redundancy j requirement of 10CFR70.24-is maintained. The addition of this' d '

monitor. to; Technical (Specification does not require a plant' modificationJor new mode of plant operations because the subject 't monitor is currently installed and fully functional. The- g

? proposed ACTION'statementimore. accurately represents the LCO by-

• l requiring continuous monitoring of_ the subject area if both criticality monitors are inoperable and fuel movement is in- -i progress. j

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2) .The proposed change does not create the possibility of a new or different kind of accident from any accident previously' evaluated because the proposed change does not introduce a new mode of plant operation or involve a physical modification to the plant.

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3) The proposed change does not involve a significant reduction in a 4 margin of safety because, as previously mentioned in item 1. the

• change does not physically mcdf.fy the plant and does not introduce a _new mode of plant operation. The proposed' change does not change any safety limit or lief ting safety system setpoint, or modify any safety related system. The' proposed 1 change will increase the margin of safety because the reliability  ;

of'the spent fuel pool area criticality monitoring system has been increased by requiring two monitors as compared to one.

. Additionally, the proposed ACTION statement more accurately i

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[. represents the LCO by requiring contineous monitoring of 'the .

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cubject: area if both criticality monitors are inoperable and fuel movement . is in progress. ,

Based on the 'above. Detroit Edison'has determin!41that the proposed  :

amendment- does not' involve a .significant hazards consideration.

-ENVIRolBGDfTAL IMPACT

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Detroit Edison has reviewed the proposed. Technical Specificat?.on d changes against. the criteria of.10CFR51.22 for environmental

conside rations.' ' The proposed change does' not involve. a significant hazards consideration, nor.significantly change'the types or-significantly : increase f the amounts of effluents that may be released-offsite.Jnor- significantly increase: individual or~ cumulative' l occupational radiation exposures. Based on the foregoing.' Detroit.

o  : Edison concludes that the proposed. Technical Specifications do meet

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criteria given in 10CFR51.22(c)(9) for a categorical exclusion i fror. the- requiremer to for en Environmental Impact Statement.

CONCLUSION-

'l Based on the evaluation 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

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conducted in compliance with the Commission's Jegulations andcproposed ,

amendments will not be. inimical to the common. defense and security or

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-to the health.and safety of the public. ="

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