NRC-90-0150, Application for Amend to License NPF-43,revising Tech Specs Re Control Room Emergency Filtration Sys

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Application for Amend to License NPF-43,revising Tech Specs Re Control Room Emergency Filtration Sys
ML20059J803
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/11/1990
From: Orser W
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059J805 List:
References
CON-NRC-90-0150, CON-NRC-90-150 NUDOCS 9009200191
Download: ML20059J803 (17)


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f detroit ,. s .. u w Edison EFGEN wm,. i e j I f i

Septaber 11, 1990 .i l 10C-90-0150 i

l 1 U. S. !bclear Degulatory Ccmsnission '

Attn ' Docanent control Desk-Washington, D. C. 20555 ,

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References:

'1)' Fermi 2. '

NIC Docket !b. 50-341 l 10C License No. ,!PF-43 -'

2) Detroit Edison Letter to N}C, I VP-86-0132, " Proposed Technical f

Specification Control Rocan ~

hergency Filtration System ,

3/4.7.2," dated October 24, 1986  !

3) Detroit Edison Letter to NIC, NIC-89-0215, $
  • Proposed Technical Specification Chege (License  !

Anendnent) - Control Room Energency Filtration Systern (3/4.7.2)," dated November 16, 1989 , ,

4) Detroit Edison letter to 100, N}C-89-0242, "Supplenent to Proposed Technical Specification Change (License Anendnunt) - Energency Equipnent '

Cooling Water Systmi (3/4.7.1.2), Energency Equipnent Service Water System (3/4.7.1.3),- and i Ultimate Ileat Sink (3/4.7.1.5)," dated January 3, 1990 .;

I 5) Detroit Edison Letter to NIC, NIC-88-0185, [

" Proposed-%chnical Specification Change (License l g Anerdrent) - Control Rocxn hergency Filtration i go J System (3/4.7.2)," dated Decenber 22, 1988- l L

88 Sb

Subject:

Proposed Technical Specification Chmge (License

-y Anendnent) - Control Room Energency Filtration  !

y System (3/4.7.2)  ;

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L 7 Pursuant to 10CFR50.90, Detroit Edison Conpany hereby proposes to anend Operatin i

l- gg the enclosed cig License on langes 'intoIPF-43 for the the Plant Fermi 2Specifications.

Technical plant by incorporating The .

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-. Sg tenber 11, 1990 10C-90-0150 Page 2 <

- prcposed chmge to Specification 3/4.7.2 provideo clarification of those redurdant conponcnts which constitute an TEIABIE Control Rocan. '

Energency Filtration Systen subsystesa and the actions required in tM event that one or both subsystems are inoperable.- In a5dition, changes have been prcposed to the Surveillance Requirements sections.

to revise the listing of actuation signals. for tie system and to minimize unneessary run tine for the recirculation ard energency ;

makeup air filter trains.

Many of the changes proposed herein were previously' addressed-in thef  !

Deference 5 Technical Specification change proposal, which was. r recently witidrawn by Detroit Edison. Following its witidrawal, '

Detroit Edison reviewed the changes proposed,in Reference 5, modified the prcposals as appropriate ard hac included those changes which were determined to te necessary in this submittal.

This proposal provideo improvments to safety by inproving the'  !

Specification's usability, eliminating unnecessary system operation' '

for surveillance purposes and eliminating provisions which can cause' a plant shutdown when such action is not warrated. Pronpt 100 review of this prcposal is requested in order to allow thene safety-inprovements to be inplenented in a timely manner.

Detroit Edison has evaluated the prcposed Technical Specifications  :

against the criteria of 10CFR50.92 and determined that _no Significant hazards consideration is involved. The Fermi- 2 Onsite Review :

Organization has approved and the ibelear Safety Review Group has reviewed the prcposed Technical Specifications ard concurs with the.

nnelosed determinations. In tccordance with 10CFR50.91f Detroit Illison is providing a copy of this letter to the State of Michigan.

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

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Sincerely, Enclosure bW cc A. B. Davis R. W. DeFayette W. G. Rogers J. F. Stang Supervisor, Electric Operators, Michigan Public Service Commission - J. R. Pa:19 ett; I

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. Septenber 11, 1990 j 10C-90-0150 -

Page 3 l I. WILLIAM S. ORSE31, do hereby affirm that the foregoing statertents .l are tumed on facts and circunstances which are true and accurate to  :

the' test of nvy knowledge and relief. j i

WIILIAM S. ORSER '  ;

Senior Vice President '  ;

On this N s//b day of /

    • ' # .,.1990, before ne -

personal.ly appeared William S.4rsier, being first duly sworn and says that he executa3 the foregoing as his free act and: deed. l Notary PubTic '

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Notory Pubnc, Monroe County, M1  !

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^ . Enclosure to NRC-90-0150 Page 1 INTMODUCTION The proposed amendment revises Technical Specification (TS) 3/4.7.2 for the Control Room Emergency Filtration System (CREFS). The Fermi 2 CREFS differs from a typical CREFS design upon which the Standard Technical Specifications (STS) are based. Typically, complete.

redundancy of both passive and redundant equipment is installed..

The Fermi 2 CREFS consists of a combination of redundant active and passive components and non-redundant passive components.- The system-1s configured into two subsystems of redundant components which are l capable of establishing the required flow path through non-redundant ,

l j duct work and air filter trains. The system is described in UFSAR  !

j Section 9.4.1. The Fermi 2 design was evaluated and found to be l acceptable in sections 6.4 and 9.4.1. of the NRC staff's Safety

Evaluation Report for Fermi 2 (NUREG-0798). +

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The proposed amendment will better reflect the unique features of tre  !

Fermi 2 design. The changes can be divided into categories as  !

described below

1) Revision of the Limiting Condition for Operation (LCO) to better t reflect the system configuration in regards to redundant and non-redundant components. -
2) Revision of action requirements to correspond with the LCO changes of 1) above and to accommodate surveillance activities q which may be required-during power operation.  ;

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3) Revision of the monthly system operation surveillance to' j eliminate unnecessary. operation of the system filter trains.  ;

l 4) Revision of the surveillance requirement for system actuation

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j instrumentation to delete the Reactor Building Ventilation i ,

l Exhaust Radiation Monitor from the listing of actuation signals.

ETALUATION i

Proposed Change Number 1 h Revision of the Limiting Condition for Operation (LCO) to better reflect the system configuration in regards to redundant and i non-redundant components.

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' . Enclosure tp- l NRC-90-0150- .

c . Page 2 i e i Basis.

i Limiting Condition for Operation (LCO) 3 7 2 currently describes the i system requirements in a. manner which does not clearly show the system .

configuration. The proposed LCO more completely . lists the redundant l subsystems and has included the chiller units as required equipment. l The chiller units are required to ensure Control Roon habitability.in l post-accident environment and' to provide cooling during normal operations under certain external environmental conditions. The i surveillance requirements for.the system insure the system fulfills j these requirements during normal operation. There is no explicit. 1 surveillance requirement to ensure the post-accident function is J

capable of being fulfilled. It is therefore possible to incorrectly  !

interpret that if the chiller is inoperable that the system remeina j

. 0PERABLE as long-as the temperature surveillance requirement is net. i Listing the chiller units in the LCO ensures that the impact of . i' chiller unit inoperability is correctly assessed.

Since the chiller units rely on Energency Equipment Cooling Water (EECW) and Energency Equipment Service Water (EESW) to provide cooling support, it la appropriate to include this LC0 in the listing LCOs  ;

contained in the EECW LCO, 3 7.1.2, and the EEsW LCO, 3 7.1 3 This  :

change is included in this submittal. However, the changes to LCO  !

- 3 7 1.2 and 3 7.1 3 will be unnecessary if approval of the Reference 16 -

TS change proposal precedes the approval of this submittal. t l The proposed LCO adds dampers required to support. system operation to  ;

l the list of redundant equipment. There are many dampers in the j l Control Roon Emergency Filtration System (see. attached figure), some of which are required to operate for the system to perform its ,

function. The existing specification includes dampers in the action statement, but not the LCO. The proposed wording lista " dampers required to support system operation" in the LCO specifically.as part of what is needed for a subsystem to be OPERABLE and thus'they are. '

i covered in the action statement,under subsystem inoperability.

i Inoperability of dampers in the common flow path.is covered;under the LCO requirement for an OPERABLE flon path,'so a-separate line ites is not needed. l The proposed flow path LCO incorporates the air filter trein requirements which were previously listed separately. This revised -

requirement is easier to apply to situations where passive redundant air filter train components become inoperable. Currently such situations could be interpreted as a filter train inoperability. '

However, the actual impact of the inoperability is limited to one subsystem, and a flow path is still available. ,

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. EnclosurO to NRC-90-0150

. Page 3 An addition was made to the description of the flow path capable of supplying energency makeup air to the control room. The proposed wording specifies that the flow path needs to be capable of supplying energency makeup air for the north and the south energency intakes.

The control room dose calculation contained:in Reference 3 and in Section 6.4 of the Safety Evaluation Report for Fermi 2 (NUREG-0798) used an allowance for dual air intakes as permitted by Standard Review Plan 6.4 Section III.3.d.(4).(11). Therefore, a pathway from both the north and south energency intakes is required to be OPERABLC, though only one pathway would be used at any time. The proposed wording clarifies the need for both pathways, rather_than pst a pathway from a single energency intake.

Detroit Edison believes that the revised CREFS LCO will provide a clearer understanding and a more consistent application of the requirements. This reduces the chance of misinterpretation and misapplication of the requirements and thus enhances safety during plant operation.

Proposed Change Number 2-Revision of action requirements to correspond with the LCO changes of Proposed Change 1 above and to accommodate surveillance activities which may be required during power operation.

Basis This change is limited to action statements b. and c. of this LCO. . In both cases, the nomenclature is editorially modified to be consistent with the LCO changes of Proposed Change Number 1. The allowed times to take the required actions have not been changed.

A new provision is proposed to be added to action b.1, which addresses the inoperability of non-redundant equipment while in Operational Condition 1, 2, or 3 Ordinarily, such inoperabilities require the ,

plant be in at least.the Hot Shutdown condition within six hours. It-is proposed to allow a six hour delay in this action for the purpose of performing a surveillance which may be required.

The Surveillance Requirements (SR) in question are SR 4.7.2.c and SR 4 7 2.d. SR 4.7.2.c is required on an 18-month frequency; after any structural maintenance on a filter or charcoal adsorber housing; and following painting, fire, or chemical release in any ventilation zone  ;

communicating with the CREFS. Three requirements _are imposed by SR I 4.7.2.c. Two of the requirements, in place penetration testing.and system flow rate testing, may be performed within the guidelines of the CREFS LCO and action requirements. The third involves removal of a representative carbon sample for laboratory testing within 31 days-of removal. SR 4 7.2.d provides another requirement to remove a representative carbon sample for laboratory testinS within 31 days _of L

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. Enclosure to NRC-90-0150

-Page 4

-removal. SR 4.7.2.d is required after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation. The sample removal process requires that the-affected non-redundant filter train be made inoperable and thus causes-entry into. action b.1.

'lhe proposed delay of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is limited to the circumstances which may occur during plant operation but would not otherwise cause the CREFS to be inoperable. The need for the proposed delar is expected to occur very infrequently. The events which may cause SR 4.7.2.0 to be required which fall into;this category are painting,lrire and chemical release in any ventilation zone communicating with the system. Great effort is made to prevent this condition...The use of the delay would-thus occur only when these. preventive measures fail, which is expected to be infrequently. The 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation time frame could expire while,the plant is operating. Typically, less than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of' charcoal adsorber operation occur between charcoal ~ samples obtained during plant shutdowns at least every 18 months. Unusual periods of operation would have to occur to cause the need to use this delay and thus it is considered an infrequent event. Although, as described above, this use of the proposed delay is expected to be infrequent, Detroit Edison believes the delay has sufficient safety benefits to merit'its inclusion in the TS.

The process for removal of a carbon sample involves entering the filter train, removing a sample, and performing an in-place leak test 1 of the adsorber. A six hour period'is proposed to be allowed to  !

perform this removal.

Since following the restoration of filter train integrity the CREFS is restored to operable status, the sir, hour delay prevents >the unnecessary entry into the Hot Shutdown action. The new pro'. sion eliminates a power reduction and subsequent escalation which would be undertaken during the same time ~as the charcoal sample removal evolution. The elimination of the simultaneous evolutions and the i elimination of the plant thermal cycle are safety enhancements.

The delay in the action is limited to situations where a charcoal j sample is required to be taken during plant operation for analysis J within the following 31 days. The system is fully operable except for during the charcoal sample removal process, which is of limited duration and is required in order to perform a necessary laboratory analysis. Inoperability of the CREFS for.any other reason will still require that the TS actions be taken without delay.

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. gnclosure t9 NRC-90-0150 ,

. Page 5 l The proposed provision does not appear. in the STS since, typically,-  ;

required charcoal samples can be obtained during plant operation by sequentially entering redundant filter trains. This is covered in the STS by specifying allowed outage times of sufficient duration. Thus,  ;

the need for this provision is due to the installation of non-redundant filter trains at Fermi 2.

In summary this changes i r

o Eliminates an entry into a Hot Shutdown action for an l inoperability of a known infrequent limited duration.

o Provides the safety benefit of eliminating simultaneous I evolutions and unnacessary plant thermal cycling. . .;

4 f o' Reflects a Fermi 2 design difference. fron the design on..which the  !

STS were based. }

In addition, the condition of both redundant subsystems being inoperable is proposed to be included in action b.1. Action b.1 would thus fully address the loss of the CREFS function.-' Currently, loss of

. non-redundant components is explicitly covered in Action b.1, where

. loss of both redundant subsystems is covered by TS 3 0 3 Although i the time frames involved are similar, Detroit Edison believes the provisions are best combined into one action since the impact vn:the -

CREFS function is the same. +

i Action c.1. addresses the inoperability of-redundant equipment when the plant is not operating. Currently, seven days are allowed to restore  ;

the inoperable subsystem to operable status,'following which the CREFS j is placed in the recirculation mode of operation.

ACTION c.1 has been proposed to be modified to explicitly allow the option of declaring the system as a whole inoperable when one <

subsystem is inoperable. This allows' continuous operation of the .

OPERABLE subsystem to be halted in situations where a long. term outage of one subsystem is required Such operation when plant conditions do not require it (i.e., ACTION c.2 is met) causes unnecessary degradation ~of the operating subsystem. ' Detroit Edison believes that .

this option is currently allowed but believes in this case the option i should be more explicitly stated to aid in operator use of the Specification, i

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, - Enclosure to ,

NRC-90-0150

.Page 6 Proposed Change Number 3  ;

1 Revison of the monthly system operation surveillance to eliminate ,

unnecessary operation of the system filter trains. l Basis' -j

. Surveillance Requirement 4.7.2.b currently requires that the control I room energency filtration systen shall be demonstrated OPERABLE at least once per 31 days on a staggered test basis, by initiating fan  !

operation from the control roca, and establishing flow through the '

HEPA filters and charcoal adsorbers, and verifying that the systen. j operates for at least ;10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the associated energency makeup -1 inlet air heater operable.: As~ stated:in the Bases of Technical- ,

Specifications, this 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> operation is to be continuous. Since ]

tthere are two subsystems, each of which utilizes a' shared j recirculation and energency makeup air' train,.this results in '

operating the filtration train twice monthly for-'10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each time '!

for a total of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per 31. days. The requirements of Regulatory  ;

Position C.4.d of Regulatory Guide 1.52; Revision 2, March 1978 i requires that each ESF atmosphere cleanup train be operated at least ]

10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month with the heaters in service, in order to reduce the I buildup of moisture on the adsorbers and HEPA filters. Therefore, 1 Detroit Edison is proposing.to revise the. surveillance requirement to.

reduce the run time of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per 31 days, which is required by current staggered testing, to greater than or equal to 10 bours per 31 ,

days. This will, at the same time, demonstrate that each subsystes  !

can be initiated from the control room and establish flow through the HEPA filters and charcoal adsorbers, and that flow is maintained for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per 31 days with:the energency makeup. inlet air heater operable.

Detroit Edison believes that the application of a staggered test basis to the monthly surveillances in Standard Technical Specifications is i based upon a typical system design which includes two independent i filter trains. Thus a staggered test basis provides a benefit of a )

nore uniform testing frequency for each of the independent j subsystems. Application of the staggered test basis to the Fermi 2 i design is not appropriate as the Fermi 2 design consists of a single  !

system with certain redundant portions. As described above, this '

requirement further causes unnecessary filter train operation and attendant reduction in filter life. However, to assure that the testing is as uniform as possible tae subon't used to satisfy the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> run time requirement is proposed to be W 4gered such that each '.

subsystem is utilized for. .the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> run-at wast every 62 days. .

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.- . Enclosure to

-NRC-90-0150

[. . Page 7

. Proposed Change Number 4 Revision of the surveillance requirement system actuation

-instrumentation to delete the Reactor Building Ventilation Exhaust Radiation Monitor from the listing of actuation signals.

, Basis- s Detroit Edison is proposing to delete the Reactor Building Ventilation Exhaust Radiation Monitor from the list of actuation signals in Specification 4.7.2.e.2. In' Reference 2, Detroit Edison requested removal of the Turbine Building and Radwaste Building Ventilation Exhaust Radiation Monitors from this list. This request was granted in Amendment 7 to the Fermi 2 Operating License. In the supporting Safety. Evaluation, the NRC staff concluded that:

Signals from the control room outside air radiation monitors, as-well as the reactor protection signals, are sufficient to initiate the control. room HVAC energency ventilation modec such that the dose guidelines of General Design Criteria (GDC) 19 are met with respect to all design basis airborne radioactivity release accidents, including the LOCA.

The staff further stated:

The additional emergency ventilation signals, as listed in Technical Specification 3/4.7.2, are not necessary to meet,GDC 19 requirements and, hence, represent signals of marginal importance. '

With the Reactor Building Ventilation Exhaust Radiation Monitor inoperable, the CREFS nust be considered inoperable =and the appropriate action taken. Detroit Edison believes that this cesulting impact on plant operation is unwarranted when the systeriability to 'j perform its' intended'functiors (seet GDC 19) is not degraded.

. . i The Control Center Inlet Radiation Monitor and Fuel Pool Ventilation i Exhaust Radiation Monitor signals remain as listed actuation signals as well as the High Drywell Pressure and Low Reactor Vessel Water Level signals. -The Fuel Pool Ventilation Exhaust Radiation Monitor 1 signal is retained to provide diversity-to the Control Center Inlet  ;

Radiation Monitor signal for a Fuel Handling Accident sconario: since. i this scenario would not result in changes to reactor water. level and l drywell pressure. l I

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. Enclosuro to NRC-90-0150

. Page 8-Other design basis airborne radioactivity release accidents, such as l

Loss of Coolant Accidsnts,.and Steam Line Breaks inside and outside of I containment, are responded to by the combination of the control room '

inlet radiation monitor and either the low reactor water level or high drywell pressure signals. Thus, it is not necessary for the 3eactor_. a Building Ventilation Exhaust Radiation Monitor to be specified as an y actuation signal for the recirculation mode.

The alternative option to provide less restrictive ACTION requirements  ;

for.this actuation signal was considered. ,This was not done as the l further complication of tnis already complex specification was: Judged- '

I to be unwarranted considering the marginal importance.of.this signal.

l The change provides the safety benefit of eliminating potential plant ,

shutdown transients due to an inoperability of this signal.. The i

remaining signals meet the design requirements for divsrae actuation .

instrumentation for the CREFS. Detroit Edison therefore believes this-  !

I change is acceptable.

SIGNIFICANT HAEARDS CONSIDERATION s

In accordance with 10CFR50 92, Detroit Edison has made a determination l 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 not 1) involve a significant increase in the-probability or consequences of an accident previously evaluated, or 2) create the i possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a >

l margin of safety. '

t The four aspects of the proposal are addressed individually below:

Proposed Change Number 1:

Revision of the Limiting Condition for Operation (LCO) to better. l '

reflect the system configuration in regards. to redundant and non-redundant components.

Basis .

1) The proposed change to Limiting condition for Operation 3 7.2, ,

Control Room Emergency Filtration System, to define those .'

required components which constitute an OPERABLE' subsystem and flow path does not involve a significant increase in the.

probability or consequences of an accident prevlously evaluated.

The proposed change would require that two redundant subsystems be operable and further specifies that each operable subsystem consists of an emergency makeup inlet air heater, an energency recirculation. fan, a return fan, a supply fan, a chiller unit,

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.- Enclosure to-NRC-90-0150

.-* Page 9 and dampers required to support system operation. This proposed change provides greater detail which eliminates the need to interpret the omponents effect on system operability. The addition of the chiller units as required components makes this Specification more conservative than the current Specification.

The addition to the description of the energency makeup air flow path to specify both the north and south'energency intakes are required provides additional detail to prevent aisinterpretation. In addition;'the change does not involve any modification to the plant or systea operation and no safety-related equipment is altered.

2) The propcsed change to Techdical' Specification 3/4.7.2, Control Room Energency Filtration System, to more clearly define the required components.which constitute an operable subsystes and-flow path 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 1 modifications to the plant or system operation and no safety-related. equipment is altered. .The requested change does not create any new accident mode.

3) The proposed change to Technical specification 3/4.7.2, Control Roon Emergency Filtration System, to core clearly define the required components which constitute an operable subsystem and flow path does not involve a significant reduction in a margin of safety. As stated in 1) above, the change provides more detailed j guidance as which components constitute an operable subsystem, R adds the chiller units and provides corresponding action requirements. The more detailed-guidance reduces the possibility af misinterpretation thus. enhancing the margin of-safety. i

.I Proposed Change Number 2 Revision of action requirements-to correspond with the LCO changes of Proposed Change 1 above and to acconnodate surveillance activities which may be required during power operation. '

I Basis  !

1) The changes to the action requirements which correspond to the .  ;

change in the LCO nomenclature of Proposed Change 1,do not result  !

in any change to the action time frames of the current Technical i Specifications and'thus do not affect the operation of-the plant.

A six-hour delay in plant' shutdown is proposed to allow charcoal samples to be obtained as required by surveillance requirements.

The probability and consequences of any previously evaluated-accident has not-been significantly increased as the additional delay of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is a short period of time. This 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> delay minimizes the allowable restoration time'without requiring I

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'Page 10 1 unnec % 4ry plant shutdowns and subsequent startups when they ara-unwarranted. 'The events which can cause the use of-the.6 hour- t

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. delay are very, infrequent. This acts-to further reduce-the . j probability lthat the recirculation mode of-the CREFS will be. s needed while-this new delay provision is in.effect. l'

' Additional changes _are made:to more clearly or consistently.-

address the: required action with both redundant.CREFS subsystems =  ;

inoperable during' plant operation or_with oneLredundant'subsysten [

inoperable _when the.. plant is_not in operation _._.These' proposed _ ,

actions are the amme.or more conservative than what is currently, .

required.. Therefore,-the. proposed changes do not involve a-significantz increase in the probability lor consequences of an .

accident previously evaluated.

' 2)? The changes solely. affect the time frames for= action when CREFS .

-equipment becomes inoperable. The changesd 7 o,not affect the q, "2FS equipment design.or configuration and do not create a new -

mode of aeration.' Therefore, the proposed changes"do not create 1 the possii,111ty of a new or different. accident from.any accident '

'previously evaluated.

3) The proposed changes provide the rase or more conservative ~ action.  !

times than provided in the currer; Technical' Specifications except where a.6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. delay _14 c.oposed to allow for an 1 infrequent surveillance requ!wnt. By eliminating unnecessary i plant trans.ients the proposec ;.elay enhances:the overall'safetyJ  ;

margin. Therefore,.the proposed changes.do not-involve a.-  !

significant' reduction.In a margin of safety.  !

Proposed Change Number 3 Revision of'the monthly system operation surveillance to eliminate.

unnecessary operation of the system. filter trains..

Basis 3

1) The proposed change eliminates-the requirement ~to maintain 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of system operation,each month.with both CREFS subsystems.: *

.The requirement for:10 hours of, system operation comes?from .

Regulatory Position C.4.d.of Regulatory GuideL1 52,, Revision'2,

~

-March 1978, which states that each ESP atmosphere cleanup train be operated P.t least 10, hours per month with the heaters;on,in; order to reduce the buildup of, moisture:within the filter '

t trains. Since both CREFS subsystems /use the.same: filter trains,J  !

the current requirement results in ~ 20, hours of operation;per- ' '

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. Encitcure' to.

NRC-90-0150.- i

.- Page'11 l: 1 The proposed change eliminates the extra 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />'of operation while still assuring that each subsystem is. confirmed to be-i operable each month.and while maintaining the testing as uniform 1 l~ as possible between subsystems. .

The probability and' consequences'of an accident has not been increased since.the proposed change conforms with the Regulatory

[ Position while'at.the same time minimizes. unnecessary run time on

.the filter trains. Reduction in1the required,run time' lengthens- '

the life of the filter trains.;'In' addition, the_ change ~does not= 'l result in any_ modifications toithe plant or' system. operation _and j

~

no safety-related~ equipment is altered.

2) The proposed change solely modifies:the duration _of CREFS- i testing. As such,-the change does not create any new mode of: _ _

j plant or system operation. Therefore, the change does not create t the possibility of'a new or different accident from any accident ' ]

previously evaluated.-

3) The proposed change provides the'same assurance'of CREFS

,1 operability while eliminating unnecessary filter train operation. .This lengthens the life of the filter train. The change, therefore,'does not involve a reduction,in a margin-of.

safety.- q Proposed Change Number 4

. Revision of. the surveillance ' requirement' for;systen 'actuatilon

instrumentation-to delete the Reactor Building: Ventilation Exhaust Radiation Monitor from the listing'of actuationfeignals. -1 Basis
1) The proposed change-to Surveillance Requirement 4.7 2.e.2 to, eliminate Reactor Building' Ventilation Exhaust Radiation Monitor as an automatic initiation signal does notl involve a significant-increase in the probability or consequences of an accident previously evaluated. The ability to' isolate the control' room is- i not significantly changed and' remains in compliance with the' l design bases. Each accident scenario which< involves'CREFS j automatic. operation continues to>have diverse actuation signals 1 listert in the Technical Specifications.

1

2) The proposed change t'o Surveillance Requirement 4.7.2.e.2 to , ,

eliminats i5e Reactor Building Ventilation Exhaust Radiation Monitor as an actuation signal does not' create the possibility _of

~

a new or different. kind of accident from any< accident previo "ly evaluated. No change in normal system operation'has.been made' and no new accident modes are created, t

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. 'Encicturf to NRC-90-0150 2 , 'Page12

3) The proposed change to Surveillance. Requirement 4.7.2;e.5 to eliminate the Reactor Building Ventilation Exhaust Radiation '

Monitor as an actuation signal does~ not involve a significant-reduction in a margin of safety. The safety margin is maintained since:all design criteria remain satisfled.: The.resulting,  ;

elimination of overly restricting action requirerents and the attendant ~ elimination.of plant transients which may_be_ caused by?

these action requirements act'to increase the safety margin., j Based on the above,-Detroit Edison has determined.that the proposed amendment does not Pyolve a significantLhanards ~ consideration.

ENVIROIBENTAL IMPACT'-

Detroit. Edison has reviewed the proposed ~Tschnical' Specification, changes against the criteria ofc10CFR51.22 for environmental'  ;

considerations. 'The proposed change does not, involve a significant hazards consideration,: nor'significantly change _ the ' types or significantly: increase the1 amounts of effluents that may be. released j

offsite, nor significantly ~ increase individual or cumulative ,

. occupational' radiation exposures. Based on the foregoing, Detroit, '

Edison concludes that the proposed Technical Specifications do mest the criteria given-in.10CFR51.22(c)(9) for afcategorical exclusion from the requirements for an: Environmental Impact Statement.:  !

CONCLUSION Based.on.'the evaluation above: 1)1there is reasonable assurance'that- -

the health and safety of the public will not be endangered:by1 operationJin the proposed aanner, and'2) such activities will-be- .

conducted in compliance with the Commission's: regulations and proposed .!

amendments will'not be inimical to the common-defcnse and security or _j to the health and safety of the public.-

The proposed changes of this submittal are independent of-the~ changes proposed in7R eference 3.. The Reference 3 changes and this submittal's changes can be reviewed-and incorporated into the. Technical ~

Specifications in any_ order. q ir j

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