NRC-92-0048, Forwards Addl Info Re 910924 Application for Amend to License NPF-43 for Uprated Power Operation,Per NRC 920221 & 25 Requests.Power Uprate Safety Analysis Withheld

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Forwards Addl Info Re 910924 Application for Amend to License NPF-43 for Uprated Power Operation,Per NRC 920221 & 25 Requests.Power Uprate Safety Analysis Withheld
ML20095K987
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Site: Fermi DTE Energy icon.png
Issue date: 04/30/1992
From: Orser W
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19354F331 List:
References
CON-NRC-92-0048, CON-NRC-92-48 TAC-M82102, NUDOCS 9205060139
Download: ML20095K987 (23)
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4.s +- -e..~ Ecisort we-ca. April 30,1992 NRC-92-0048 U.= S. Nuclear Regulatory Commission Attn:' Socuent Control Desk Washington Es C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Det roit Edison Letter NRC-91-0102. " Proposed License Amendment - Uprated Power Operation", dated September 24, 1991
3) NRC Letter, dated February 21, 1992. " Fermi Request for Additional Information Upzated Power Operation License Araendment Request (TAC No.

-M82102)" l

4) NRC Letter, dated February 25, 1902. " Fermi l Request for Additional Information Uprated Power Operation License Amendment Request (TAC No.

M82102)"

5) Detroit Edison Letter. NRC-92-0043. " Detroit Edison

-Response to NRC Instrumontation'and Controls Branch Questions on Fermi 2 Power Uprate Submittal", dated March 26, 1992 1

6). ' Detroit Edison Letter. NRC-92-0038 " Detroit Edison i

Response to NRC Mechanical Engineering Branch -Questions on Fermi-2 Power Uprate Submit tal", datwl March 23, 1992

Subject:

Revision to Proposed License Amendment for Uprato.d . Power Operation and to the Fermi 2 Pover Uprate Safety Analysis (TAC No. M82102) The purpose of this letter is to provide the NRC Staf f with addittomc, -Technical Specification (TS) changes necessary for Fermi 2 uprated f Ot 9205060139 920430 PDR-ADOCK 05000341 P-ppg l( 3% i e

USNRC l* April 30. 1992 NRC-92-0048 Page #2 power operation and with amendments to the Fermi 2 Pcwer berate Safety Analysis (PUSA). The power uprate license amendment request and the Fermi 2 FUSA were submittcd by Reference 2. This supplemental information is the result of NRC questions on the subtit t al (References 3 and i), together with Detroit Edison reviews associated with the NRC questions and implementation of power uprate. Encirsure 1 includes the description and evaluation of the additional TS ct wges for power uprate. These changes involve the Main Steamline Flow Priuery Cortainment Tsolation setpoints and the new motor operated va.1ve being added to the Reactor Core Isolation Cooling (RCIC) system.. Part 1 and Part 2, is the marked up TS pages for the additional changes and a complete set of the typed proposed Operating 1,icense and TS pages, respectively. is the PUSA amendment requesttd by the NRC staff in Ref erence 4 and commit t ed to by Det roit Edison in Reference 5. The changes are summarized below: o Revised Section 3.5 to state that the Reactor Pressure Coolant Boundary (RCPB) piping design will address power uprate prior to impl ement ation, o Revised Section 5.1.2 to include discussion of the use of the GE ins t rument setpoint methodology (NEDC-31336) as commit ted to in Reference 5. o Revised Section 10.3 to include perf ormance testing of RCIC and s HPCI systems. o Revised Section 10.1.1.5 and Table 10-1 to reflect that the RWCU break in the torus room is not a limiting break. Revised Section 11 as appropriate to reflect the additional TS o changes described in Enclosure 1. A substantial portion of Enclosure 3 was provided by General Electric s Co. (GE) and is identified as proprietary information. Enclosuru 4 provides GE's af fidavit to that effect. Therefore, in ancordance with 10CFR2.790, it is requested that Enclosure 3 information identified as proprietary be withheld f rom public disclosure.

USNRC l( April 30, 1992 NRC-92-0048 Page #3 Please contact Mr. Terry L. Riley, Supe rv is or, Nuclear Licencing at (313) 586-1684 to coordinate any further actions on this statter, ac needed. Sincerely. lf Enclosures o cc: T. G. Colburn A. B. Davis M. P. Phillips S. Stasek } l I i

w-UShRC April 30, 1992 NRC-92-0048 l Page #4 l \\'+ I. WILLIAM S. ORSER do hereby af firm that the foregoing statements are trased on facts and circumstances which are true and accurate to the best of my knowledge and belief. jfff(' WILLI di.. ORSER Senior Vice President On this day of / (145 1992, before me personally appeared William S. Order, being first duly sworn and says that he executed the foregoing as his free act and deed. k& IN<.b. -{A1[lff') Notary Public AEALE A Ahl J j l A NOTARY Punt!C TTATE Or mig [iCAN MONFC E COU' TTY AfY CT)YV!%, a l D;' i.,. M 10 )-

_3 GENERAL ELECTRIC COMPANY AFFIDAVIT ' I.-David J; Robare,--being duly sworn, depose and stat (i as-follows: 1.. ,1-_ am' Manager,- Plant: Licensing Services,- General Electric Company, and have been delegated the function of reviewing the information~ described in:paracraph 2 which is sought to be withheld and have been authorized to ' apply for its withholding.

- 2.-

The :informationE sought to be withheld is contained in Detroit Edison Report Fermi-2-91-150, Revision = 1, " Power Uprate Safety Analysis", ~AprilE1992. The' GE. Proprietary portions of this report-are l identifiableiby-the "GE Proprietary Informstion" designation at the top of the page. 3. _In designating material' as-_ proprietary, General Electric utilizes the definition of-- propr.ietary-information and-trade secrets-set forth in the " Americanl Law-.-Institute's Restatement of Torts, Section 757. This definition provides: - "A trade isecret may consist of any formula, -pattern, device or compilation of Linformation which is used-in-one's business and whicht gives him -an ' opportunity _ to. obtain -an advantage over _ competitors who do not-.know or u e it...A substantial. element of secrecy must exist, so that, except by the use ~of improper neans, there would be_ difficulty.in acquiring information...Some factors to be1 considered -in -determining whether given information is one's trade-secret'are (1) the. extent-to which the information is known=outside of his business;-(2)ethe. extent _to_which-it.is-knownlby employees and others involved -in his business;-(3) the extent -.of measures"taken - by him-to guard - the. secrecy' of the information;;(4) the value of the information to' him and 'to his J competitors; -(5):. the amount' of effort or; money expanded 'by him . developing-the information; (6)- the ease er difficulty with which 'the information could _be properly acquired or duplicated by others.' - 4. ?Some examples of_ categories of information which fit into the definition of Propristary Information are: a.- Information that discloses a trocess, method or apparatus where - prevention ; of :its; use by General. Electric's competitors - without license from General Electric constitutes a competitive economic-advantage over other companies;_

GENERAL ELECTRIC C0MPANY b. Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, 1 e.g., by optimization or improved marketability; c. Information which if used by a competitor, would reduce his expenditures of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; d. Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; e. Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial vah.e to General Electric; f. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; g. Information which General Electric must treat as proprietary according to agreements with other parties. 5. Initial approval of proprietary treatment of a document is typically made by the Subsection Manager cf the originating component, the person who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary. 6. The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project Manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitively effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees then only with appropriate pro %ction by applicable regulatory provisions or proprietary agreements. 7. The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information wh'.ch is proprietary and which is customarily held in confidence Lj deneral Electric.

___,y- ~. -. - - - ~ ~ - - -, - -, - GENERAL ELECTRIC C0MPANY l 8. The information to the best of my knowledge and belief has consistently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disticsures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the information in confidence. 9. Public dischsure of the information sought to be witnheld is likely to cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other parties, including competitors, with valuable information. 1

'f'u/ fy J ! o g. 1 - G_E N E R A L.i ELECTRIC C0MPANY t

STATE OF CALIFDRNIA )

L ) ss: COUhTY;OF SANT4 CLARA ' ) i.;- David J. Robars -being duly sworn, deposes and says: e That he has read.the foregoing affidavit and the matters-stated therein are truly and correct cto the best of his knowledge, information, and belief. ~ s ~ Executed at San Jose, California,'this ti day of M R.) L 19 92. David J. Robare. General Electric Company-Subscribed;and sworn before meLthis day of d D d k 1992. ..+: i f '{ - Kg .~......a ~" ! OFFICIAL SEAL-PAULA F. HUSSEY - No1Artf pustic. cAuw .s. NotaryPublic,StateofCalifornia wm expires APR 5.1W4 {y y SANTA CLARA cowry ' t*._ m-m.mw a ~ ! I 1 w e

Fermi 2 ^ Proposed License Amendment - Power Uprate '~) TAC No. M82102 Revision 1,. April 1992 INSTRUCTIONS The proposed amendment for operation of Fermi 2 at uprated power level was filed with the NRC on Septen.oer 27,1991. These Revision 1 instructions indicate replacement and additional pages. Please remove the existing pages and insert the replacement and/or additional pages where indicated in the binder originally provided. LOCATION REMOVE INSERT TAB: Proposed License Am.endment Following TAE Detroit Edison Letter NRC-92-0048 (l Pages 1 through 4 v NRC-92-0048 Pages 1 through 6 Following Enclosure 1 hTC-91-0102 Page 13 Revision 1, Apri! 1992 - Part 1 - Part 1 Revisica 1, April 1992 Technical Specification Technical Specification Page 3/4 3-15 Page 3/4 3-15 Revision 1, April 1992 Following Technical Technical Specification Specification Page 3/4 ".23 (]) Page 3/4 7-14 Revision 1. April 1992 1 Revision 1, April 1992

Revision 1 Instructions LOCATION BEMOVE INSERT Following Technical Specification Page 6-21 - Part 2 - Part 2 Revision 1, April 1992 Typed Technical Typed Technical Specification Specification Pages 3 through 6-21 Pages 3 through 6-21 (32 pages) (33 pages) TAB: Power Uprate Safety Analysis Revision 1, April 1992 Signature / Proprietary Signature / Proprietary Information Notice Information Notice i/ii(Table of Contents) i/ii(Table of Contents) Section 3 3-5/3-6 3-5/3-6 3-7/3-8 3-7/3-8 Section 5 5-1/5-2 5-1/5-2 through through 5-5/5-6 5-5/5-6 Section 10 10-1/10-2 10-1/10-2 through through 10-7/ Blank 10-7/ Blank Section 11 11-11/11-12 11-11/11-12 through through 11-21/11-22 11-21/11-22 O l evi* ion 1, April 1992 2 D

Revision 1 Instructions 0 LOCATION REMOVE INSERT Following Figure 113 Revision 1, April 1992 Following Enclosure 4 GE Affidasit (2 pages) - O 4 I O l' I 3 Revision 1, April 1992

wuusm S. orser Senior Vice Pres, cent MYt' Detroit re-o 6400 Nortn Dme Hi J E C I S O n m a w " ghwav Nuclear on-u~ April 30,1992 NRC-92-0048 U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, D. C. 20555 Referetces:

1) Fe rmi 2 NRC Docket No. 50-341 NRC License No. N?F-43
2) Detroit Edison Letter, NRC-91-0102, " Proposed License Amendment - Uprated Power Operation", dated Sept embe r 24, 1991

'N

3) NRC Letter, da t ed Feb rua ry 21, 1992 "Fe rmi ~_)

Request for Additional Information Uprated Power Operation License Amendment Request (TAC No. M82102)"

4) NRC Letter, dated February 25, 1992, "Fe osi Request for Additional Information Uprated Power Operation License Amendment Request (TAC No, M82102)"
5) De t roit Edison Lotter, NRC-92-0043, " Detroit Edison Response to NRC Instrumentation und Controls Branch Questions on Fermi 2 Power Uprate Submittal", dated March 26, 1992 o) De t roit Edison Le tter, NRC-92-0038, " Detroit Edison Response to NRC Mechanical Engineering Branch Questions on Fermi-2 Power Uprate 3ubmittal", dated March 23,1992

Subject:

Revision to Proposed License Amendment for Uprated Power Operation and to the Fermi 2 Pcwer Uprate Safety Analysis (TAC No. M82102) The purpose of this letter is to provide the NRC Staf f with additional Technical Specification (TS) changes necessa ry for Fermi 2 uprated ,,s / \\ \\mj

USHRC April 30,1992 g HRC-92-0048 Page #2 power operation and with amendments to the Fermi 2 Power Uprate Safety m Analysis (FUSA). The pcVer uprate license amendment request and the Fermi 2 FUSA vere submitted by Reference 2. This supplemental information is the result of NPC questions on the [ submittal (Referenens 3 and 4), together with Detroit Edison reviews p asacciated with the NPC q ieations and implementation of power uprate. L i Encionure 1 includes the description and evaluation of the additional TS chat.ges f or power uprate. These changes involve the Main Steamline Y1cv Prims ty Cont ainme nt Isolation setpoints and the new motor cperated valve being added to the Reactor Core Isolation Cooling (RCIC) system. i Ene2 oware 2. Part 1 and Part 2. is the marked up TS pages for the additfr ial changes and a complete set of the typed proposed Operating g Licensa and TS pages, respectively. E closure 3 is the PUSA amendment requested by the NRC staf f in hef e rence 4 and committed to by Detroit Ecison in Ref erence 5. The charges are statmarized belows 9 o ' Revised Soetion 3.5 to state that the Recctor Pressure Coolant Soundary (PCPB) piping design will address power uprate prior to implementation. o Revisad Section 5.1.2 to include discussion of the use cf the GE inst r unent setpoint methodology (NEDC-31336) as c ommit t ed t o ir Reforence 5. o Revised Section 10.3 to include perf ormance testing of RCIC and HPCI systems. , g_ m o Rev.ised Section 10.1.1.5 and Table 10-1 to reflect that the RWCU break in the torus room is not a limiting break. o Revised Siition 11 as appropriate to reflect the additional TS g cha.nges described in Enclosure 1. lg A substantial portion of Enclosure 3 was provided by General Electric g - Co. (GE) and is identified as proprietary inf ormation. providen GE's af fidavit to that efi. set. Therefore, in accordance with 10CLR2.79% it is requested that Enclosure 3 information identitied as propriet&ty be withheld f rom public disclosure. 2 O w a l-

IP .?. USNP.C t April 30, 1992 f (] NP.0-92-0048 (s Page #3 Please contact Mr. Terry L. Riley Supervisor Nuclear Licensing at (313) 586-1684 to :oordinate any further actions on this matter, as needed. Sincerely. 'b Enclosures cc: T. G. Colburn A. B. Davis M. P. Phillips S. Stasek o LJ

USNRC April 30,1992 NP.C-92-0048 Page #4 I, WILLIAH S. ORSER, do hereby af firm that the foregoing statements are based on f acts and circumstances which are true and accurate to the best of my knowledge and belief. S / hkat aV WILLI If ORSER Senior Vice President O On this e day of (h[ 1992, before me personally appeared William S. vrder, being first duly sworn and seys that he executed the foregoing as his f ree act and deed. Akkdb<b. 4) Notary Public kO5AUL A AudLilA NOTARY PUBUC STATE Of MiC1 UCAN MONEOF CGUNTY My cnMyte.', w niiif']/ ?n 1M O

F l Enclosuro i to NRC-92-0048 fy Page 1 A../ t f r ENCLOSURE 1 DESCRIPTION AND EVALUATION. OF THE PROPOSED TECIINICAL SPECIFICATION CllANGES u. to NRC-92-0048 Page 2 REVISION TO PROPOSED TECHNICAL SPECIFICATION PAGES FOR UPRATED POWER OPERATION Introduction Two changes to the Reference 2 proposed Technical Specificat:on (TS) pages are being made. The first is to provide a corrected Trip Setpoint, and Allowable Value for the Main Steam Line Flow-High Primary Containment Isolation Actuation Instrumentation (Table 3 3 2-2 item 1.c.3). The second is to add the Reactor Core Isolation Cooling System warmup bypass valve (E51-F095) to the table of Motor operated Valves (HOVs) contained in Table 3 8.4 3-1, Hot.or-operated Valves Thermal Overload Protection. Evaluation - Main St.can Line Flow Isolation Actuat. ion Instrumentation The Trip Setpoint and Allowable Value for the Main Steam Line Flow-High Primary Containment Isolation Actuation Instrumentation is being modified to correct a discrepancy in the assumed fluid density used in the original calculation. This discrepancf was discovered during Detroit Edison's review of General Electric design records. The new calculation was submitted to the NRC staff with the Referenc9 5 response to staff questions on instrumentation and controls. This calculation derived the new Trip Setpoint and Allowable Value in accordance with the General Electric Inst,rument Setpoint Methodology (NEDC-31336). The current Trip Setpoint and Allowable Value are specified both in terms of differential pres.sure and percent of rated flow. The specification in teres of percent of rated flow is proposed to be eliminated. The steam flow instrumentation measures a differential pressure (dp) across a flow restriction in the steam line. Excessive steam flew causes a high dp signal which causes an isolation signal when the dp exceeds the instrument trip setting. The instrumentation does not make a conversion to mass flow rate. A value listed in terms of percent of rated flow is only equivalent to a dp value under specific steam temperatures and pressures. Under other conditions, the two specified values will represent different mass flow rates. EH minating the value not actually used in setting the instrumentat. ion will eliminate any potential ambiguity or confusion from the application of the TS. O l r 1

. to NRC-92-0048 Fase 3 ) m 1he dual specifications of the steam flow isolation setpoints for ECIC and the High Pressure Coolant Injection (HPCI) systems were eliminated for similar reasons in Acendment 43 to the Fermi 2 Operating License. Also, thn BWR-4 Standard TS only lists a dp value for this function and a dual specification for the Main Steam Flow isolation is not known to crist in other BWR TS. Evaluation.. RCIC Hot.or Operated Valve TS 3 8.4 3 requires that the thermal overload protection for HOVs listed in TS Table 3.8.4 3-1 be operable to ensure that the thermal overlor,d protection will not prevent these safety related valves from perfo,* ming their function. To implement power uprate, a one inch HOV (E51-F095) will be installed around the RCIC steam admission valve (E51-F045). The proposed change adds E51-F095 to the table of safety related valves for which operable thermal everload protection is required by the TS. Tho new bypass valve is being added to reduce the chance of a RCIC turbine overspeed trip in accordance with the recommendation of GE Service Inforuation Letter 377 The inclusion of the new bypasa valve in the RCIC Jection of this Table will ensure that safety benefit of J~N the increased RCIC system reliability is not lost due to an inoperable ) thermal overload protection device. The original Fermi 2 design included a RCIC warmup bypass valve utilizing a salenoid operated valve. Due to maintainability concerns with this solenoid valve the bypass line was removed from service by blanking the line. Testing had demonstrated that adequate margin between the peak RCIC turbine speed and the RCIC turbine overspeed trip setpoint existed. With the higher steam inlet paessure conditions under uprated power conditions it was determined that the warmup bypass function should be restored. The desirability of a bypass valve was identified in the Reference 2 submittal. Subsequently, it was determined that for reliability an HOV should be used. As a result of this determination, an additional TS change beyond those identified in Reference 2 is needed. No Significant 11azards Analysis In accordance with 10CFR50 92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison has determined that operation in accorderice with the proposed amendment will not:

1) involve a significant increase in the probabilley or consequences of an accident previously evaluated or 2) create the possibility of a new or different kind of accident from any accident

() previously evaluated, or 3) involve a significant reduction in a margin of safety. ~-

Cnclosure 1 to WRC~92-0048 Ptge 4 g The proposed change to modify the anin steamline flow primary containaent isolation actuation sotpoint and eliminate the dual specification of the setpvint in terms of percent rated flow does not: 1) Involve a.significant increase in the probability or consequences of an accident previously evaluated. The main steamline flow setpoints are changed to reflect. the rudefinition of rated main steamline flow that accompanies uprated power operation. These limits continue to ensure that an adequa:e trip avoidance margin is maintained for the normal plant testing of MSIVs and turbine control /stop valves. The setpoints were selected to provido assurance that isolation protection will still be provided for a main steamline break accident. These setpoints have no effect on the probability of the occurrence of a main steamline break. Also, since a high level of assurance of break isolation is maintained, these setpoint changes do not significantly increase the consequences of the main steamline break accident. The specification of the main steamline flow isolation actuation instrumentation setpoints in terms of percent rated flow is eliminated. The instrument.ation is set in accordance with the h differential pressure values. The percent rated flow values are informational and the elimination has no effect on the safety analysis. Thus, the change does not significantly affect the probability or consequences of an a :cident. 3) Create the poasibility of a new or different kind of accident from any accident previously evaluated. The change modifies the main steamline flow primary containment isolation actuation instrumentation to reflect uprated power conditions and to eliminate a dual specification of the setpoint, No new design or operating modes are involved. Therefore, the change d:es not create the possibility of a new or different kind of accident from any accident previously evaluated. ~3) Involve a significant reduction in a margin of safety. The change modifies the instrument etpoint to be consistent with uprated power conditions which has been previously evaluated in Reference 2 and determined to not involve a significant reduction in safety. The elimination of the dual specification of the setpoint is adsinistrative and thus does not affect safety margins. O

Lnolosure 1 to NRC-92-0048 Fage 5 C The proposed chango t.o include the Reactor Core Isolation Cooling waruup bypass valve in TS Table 3 8.4 3-1, Hotor-operated valve Thermal Overload Protection does nott 1) Involve a significant in:rease in the probability or consequences of an accident previously evaluated. The inclusion of the RCIC warsup bypass valve in the table for thermal overload protection requirements assures that the thermal overload protection does not 1spact the valve's function. Since the change acts to increase the RCIC system's reliability it does not result in a significant increase in the probability or consequences of a previously evaluated accident. 2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed modification implements the General Electric Service Information Letter 377 which recommends a one-inch steam inlet bypass valve which reduces the RCIC turbine tendency to overspeed before adequate governor control valve hydraulic oil pressure is achieved from the turbine driven all pump. This modification will be designed to the same quality standards as the RCIC O. system. Line breaks for piping within the RCIC room have been evaluated with satisfactory results and the new HOV meets the same ASME Class II code integrity requirements of the original valve. Other evaluated concerns for electrical design, seismic criteria, operability, and environmental qualification for this modification are in compliance with the system design bases. Based on this compliance und design, there is no creation of a new failure mode or violation of existing failure mode design criteria. The equipment added/ modified under this design change does not introduce a failure mechanism that has not been previously evaluated. This will ensure that.the possibility of an accident of a new or different type than previously evaluated is not created. 3) Involve a significant reduction in a margin of safety. The proposed change ensures that the function of the new RCIC warsup bypass HOV is not impacted by an inoperable thermal overload protection device. The new valve functions to reduce the peak RCIC turbine speed on startup thus maintaining the margin to the overspeed trip setpoint under uprated power conditions. Therefore, the change does not involve a significant l reduction in a margin of safety. ' O

l to NRC-92-0048 Page 6 g The no significant hazards analysia for power uprato, which is Section 11.4 of the Power Uprate Safety Analysis (PUSA), has been revised to reflect the Pevised TS proposal. '1he revisions to PUSA Section 11.4 are included in Enclosure 3 to this sutaittal. Based upon the above, Detroit Edison concludes that the revised power uprate amendment does not involve a st nificant hazards considerstion. 6 Envirorument.al Impact The revision prooosed to the power uprate amendment does not affect the environmental evaluation contained in Reference 2. The Reference 2 conclusion that the proposed TS meet the criteria given in 10C/R51.22(c)(9) for a categorical exclusion from the requirements of an 2nvironvintal Ispact Stateacnt remains valid. Conclusion Based on the ovaluation above

1) there is reasonable assurance that the heal e and safety of the public will not be andangered by operation in the propcsed manner, and 2) such activities will be conducted in comp 11anca with the Commission's regulations and proposed esendments will not be inimical to the common defense and security or h

to the health anu safety of the public. O l

O ENCLOSURE 2 l PROPOSED OPERATING LICENSE i AND TECHNICAL SPECIFICATION CIIANGES O I. 1 t r + l. i o l Revision 1 April 1992 l ,, -, _ ~, -.. -. -, ..~......y ,_4 _.4 m .--.-..~.._._...._._...,.._..___-_,,.......,_.m_..

.. - = O ENCLOSURE 2 PART 1 PROPOSED OPERATING LICENSE L AND TECIINICAL SPECIFICATION PAGE MARKUPS O 1 i O t l.- Revision 1, April 1992

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