NRC-94-0047, Application for Amend to License NPF-43,incorporating Changes to Ts,Removing Component Lists from TS Sections 3.6.3 & 3.8.4.3 Per GL 91-08

Application for Amend to License NPF-43,incorporating Changes to Ts,Removing Component Lists from TS Sections 3.6.3 & 3.8.4.3 Per GL 91-08

ML20029E030
Person / Time
Site:	Fermi
Issue date:	05/10/1994
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029E031	List: ML20029E032 NRC-94-0047, Application for Amend to License NPF-43,incorporating Changes to Ts,Removing Component Lists from TS Sections 3.6.3 & 3.8.4.3 Per GL 91-08
References
CON-NRC-94-0047, CON-NRC-94-47 GL-91-08, GL-91-8, NUDOCS 9405160127
Download: ML20029E030 (16)

Text

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j' ~

Douglas R. Gipson

. Scrwe Vnv Present

%*ar Generwon Detroit r-Ec ison - a.s<wouw*uy na %w-Hay 10, 1994 NRC-94-0047 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

References:

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

2) Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications," dated May 6, 1991

Subject:

Proposed Technical Specification Change (License Amendment) Removal of Component Lists from Technical Specifications Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications (TS).

The proposed changes removes the component lists from TS Sections 3.6.3 (Table 3.6 3-1, Primary Containment Isolation Valves) and 3.8.4 3 (Table 3 8.4.3-1, Motor-Operated valves Thermal Overload Protection) in accordance with the guidance set forth in NRC Generic Letter 91-08 (Reference 2). In addition to removing the subject component lists, this proposed amendment modifies portions of the TS that specifically reference these lists. .The lists removed from the TS will be incorporated into plant procedures subject to the administrative controls of TS 6.5.3 and 6.8. This modification is a line item TS improvement as described in Reference 2.

Detroit Edison has evaluated the proposed TS 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 Nuclear Safety Review Group has reviewed the proposed TS and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

9405160127 940510 PDR P

ADOCK 05000341 PDR -(\ j

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May 10, 1994 NRC-94-0047 Page 2 Additionally, Detroit Edison is expected to save over $200,000 over the remaining plant' lifetime if this TS change is approved.

Furthermore, if this TS change is approved it will prevent Detroit -

Edison from having to submit at least one additional component list TS change- for NRC approval prior to startup from the present extended outage. Consequently, the proposed change is being requested to coincide with the present refueling outage (RF04) and Detroit Edison requests that it be approved by July 15, 1994. t A summary of the proposed changes, an Evaluation, the Significant Hazards.and Environmental Impact Considerations and a Conclusion are provided in Attachment 1. Attachment 2 provides a copy of the proposed TS changes.

If you have any questions, please contact Mr. Glen D. Ohlemacher at (313) 586-4275 Sincerely, g M Enclosures cc: T. G. Colburn J. B.' Martin M. P. Phillips K. R. Riemer Supervisor, Electric Operators, Michigan Public Service Commission - J. R. Padgett I'

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L USNRC May 10, 1994 NRC-94-0047 Page 3 i

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I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and l accurate to the best of my knowledge and belief. I DOUGLAS k. GIPSON Senior Vice President 4

On this /8 day of < 4tV , 1994 before me personally appeared Douglas R. Gipsoh, geing first duly sworn and says that he executed the foregoing as(his free act and deed.

4M la k. 41 Notary Public '

ROMUE A ARAEITA

NOTARY PUBUC STATE ONQ9CAN NONROE COUNTY My cr56.4tWON EXP. NOV. 20,1995 4

ATTACIIMENT 1 PROPOSED TECIINICAL SPECIFICATION CIIANGE (LICENSE AMENDMENT)

RDIOVAL OF COMPONENT LISTS FROM TECIINICAL SPECIFICATIONS 1

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Attachment I to NRC-94-0047 Page 1 of 12 INTRODUCTION The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications," on May 6,1991. This GL provides 4 guidance for preparing a request for a license amendment to relocate component lists from Technical Specifications (TS) into plant procedures. This guidance included incorporating the component lists into plant procedures that are subject to the change control provisions in the Administrative Controls Section of the TS, This will provide an acceptable alternative to identifying every component by its plant identification number as it is currently listed in the TS Tables. The change contml provisions of the TS provide an adequate means of contmiling changes to these component lists, without including them in the TS. The removal of these component lists is acceptable because it does not alter existing TS requirements or those components to which they apply. The nuclear industry and the NRC identified this line-item ,

TS improvement during investigations of TS concerns.

Detroit Edison proposes to relocate the component lists of TS Tables 3.6.3-1 (Primary Containment Isolation Valves) and 3.8.4.3-1 (Motor-Operated Valves Thermal Overload Protection) to plant procedures, in accordance with the guidelines provided by GL 91-08.

These component lists will then be subject to the procedure change control provisions contained in the Fermi 2 TS Sections 6.5.3 and 6.8, which are subsections of the TS Administmtive Controls Section (6.0). In addition to removing the subject component lists, this proposed amendment will modify portions of the TS that specifically reference these lists.

The plant procedures, that the TS component lists are being relocated to, will include all-components and applicable footnotes currently listed in the TS. The operability requirements for components being relocated (e.g., LIMITING CONDITION FOR OPERATION, APPLICABILITY, ACTION and SURVEILLANCE REQUIREMENTS) remain in the TS.

l In accordance with Generic Letter 91-08, the following changes to the TS am being proposed.

The changes are described in the order in which the associated TS appears in the Technical Specifications.

1. TS INDEX

a. The index is being revised to make editorial corrections to reflect the deletion of TS Tables 3.6.3-1 and 3.8.4.3-1, which contain component lists as described below. The proposed TS page changes are attached. They are prepared in accordance with the guidance in Reference 2 .

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Attachment I to NRC-94-0047 Page 2 of 12

2. DEFINITIONS

a. Revise section a.2 of Definition 1.29, PRIMARY CO'NTAINMENT ,

INTEGRITY, to delete reference to table 3.6.3-1 and to denote the following:

" Closed by at least one manual valve, blank flange, or deactivated automatic valve secured in its closed position, except for valves that are open under administmtive control as pennitted by Specification 3.6.3. "

Section a.2 of Definition 1.29, PRIMARY CONTAINMENT INTEGRITY is proposed to be revised to delete the reference to Table 3.6.3-1 (Primary Containment Isolation Valves) and the Definition wording is mvised accordingly. The referenced Table 3.6.3-1 is being deleted from the TS and >

relocated to plant procedures. The list of primary containment isolation valves is not necessary to support the actions or surveillances required by the TS. The proposed word changes are consistent with the guidance provided in GL 91-08.

3. ISOLATION ACTUATION INSTRUMENTATION (3/4.3.2)

a. Delete the column " Valve Gmups Operated By Signal" in Table 3.3.2-1, delete Table 3.3.2-1, Table Notations (d), (c) and (j); and relocate (as specified below)

Table 3.3.2-1, Table Notations (***), (f) and (g) associated with the valve groups.

Table 3.3.2-1 includes information on the " VALVE GROUPS OPERATED BY SIGNAL." This information identifies the valve group by each isolation trip function and includes a number of notes which are associated with the trip  ;

function or the valve groups. Specifically, the valve groups are proposed to be deleted from the TS and relocated to plant procedures. The valve gmups identified in this TS are for infonnation only and require a listing of the individual valves (associated with the groups) to be of use. The curmnt listing of individual valves (associated with the gmups) is currently provided in Table 3.6.3-1 (Primary Containment Isolation Valves). Table 3.6.3-1 is also being deleted fmm the TS and relocated to plant procedures. The valve groups are not necessary to support the actions or surveillances required by the TS.

The footnotes associated with Table 3.3.2-1 will be distributed as described telow:

Attachment I to NRC-94-0047 -

Page 3 of 12 ROTE NEW LOCATION Retain as is in TS Retain as is in TS Relocate with valve group infonnation to plant procedures and retain in TS - Relocate footnote under Trip Function column in Table 3.3.2-1 (a) Retain as is in TS (b) Retain as is in TS (c) Retain as is in TS (d) Relocate with valve group infonnation to plant procedures and delete in TS (e) Relocate with valve group infonnation to plant pmcedures and delete in TS (f) Relocate with valve group infornution to plant procedures and retain in TS - Relocate footr.ote under Trip Function column in Table 3.3.2-1 (g) Relocate with valve group information to plant procedures and retain in TS - Relocate footnote under Trip Function column in Table 3.3.2-1 (h) Retain as is in TS (i) Retain as is in TS (j) Relocate with valve group infonnation to plant procedures and delete in TS Identified changes to the infonnation being relocated to plant procedures will continue to be controlled and reviewed in accordance with TS Sections 6.5.3 and 6.8, which are subsections of the TS Administrative Controls Section (6.0), As a result, the deletion and subsequent relocation of this infonnation from the TS

r Attachment I to NRC-94-0047 Page 4 of 12 complies with the guidance contained in GL 91-08. The proposed change, therefore, does not result in a technical change to the TS.

b. Delete Footnote (#) in Table 3.3.2-3.

Table 3.3.2-3, Footnote (#), is proposed to be deleted sinc 3 it refemnces Table 3.6.3-1 (Primary Containment Isolation Valves) and valve groups. Specifically, the valve groups are proposed to be deleted from the TS and relocated to plant procedures. The valve groups identified in this TS are for information only and require a listing of the individual valves (associated with the groups) to be of use.

The current listing of individual valves (associated with the groups) is currently provided in Table 3.6.3-1 (Primary Containment Isolation Valves). Table 3.6.3-1 is also being deleted from the TS and relocated to plant procedures. The valve groups are not necessary to support the actions or surveillances required by the TS.

Table 3.6.3-1. The reference to the tables and the valve groups is for information only and is not necessary to support the actions or surveillances requimd by the TS.

Additionally, Isolation System Response Time is adequately defined in TS 1.16, therefore the (#) note in Table 3.3.2-3 is only infonnational. Also, Detroit Edison has submitted a TS change to remove all response time tables from the TS in accordance with GL 93-08. These response time tables will be relocated to the UFSAR..

4. PRIMARY CONTAINMENT INTEGRITY (3/4.6.1)

a. Revise SR 4.6.1.1.b to delete reference to Table 3.6.3-1 and to denote the following:

" At least once per 31 days by verifying that all primary containment penetrations except those inside the containment or in locked high radiation areas (listed in Table 4.6.1.1-1) not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by locked closed valves, blank Ranges, or deactivated automatic valves secured in position, except for valves that are open under administrative control as permitted by Specification 3.6.3. "

l SR 4.6.1.1.b is proposed to be revised to delete the reference to Table 3.6.3-1 l (Primary Containment Isolation Valves) and the SR wording is revised )

accordingly. The referenced Table 3.6.3-1 is being deleted from the TS and j relocated to plant procedures. The list of primary containment isolation valves 1 is not necessary to support the actions or surveillances required by the TS. The  !

proposed word changes are consistent with the guidance provided in GL 91-08.

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Attachment 1 to NRC-94-0047 Page 5 of 12 l

5. PRIMARY CONTAINMENT LEAKAGE (3/4.6.1)

a. Revise LCO 3.6.1.2.b to delete reference to Table 3.6.3-1 and to denote the following:

"A combined leakage rate of less than or equal to 0.60 La for all primag i containment penetrations and all primary containment isolation valves, except ,

for main steam line isolation valves

• and primay containment isolation valves l which are hydrostatically tested, subject to Type B and C tests when pressurized l to Pa, 56.5 psig."

LCO 3.6.1.2.b is proposed to be revised to delete the reference to Table 3.6.3-1 (Primary Containment Isolation Valves) and the LCO wording is mvised accordingly.

The referenced Table 3.6.3-1 is being deleted from the TS and relocated to plant procedures. The list of primary containment isolation valves is not necessary to support the actions or surveillances required by the TS. The proposed word changes  !

are consistent with the guidance provided in GL 91-08.

b. Revise ACTION Statement (with) 3.6.1.2.b, and ACTION Statement (restore) 3.6.1.2.b to delete mferences to Table 3.6.3-1 and to denote the following, respectively:

ACTION Statement 3.6.1.2.b: l WITH " The measured combined leakage rate for all primary containment penetrations and all primary containment isolation valves, except for main steam line isolation valves

• and primary containment isolation i valves which are hydrostatically tested, subject to Type B and C tests exceeding 0.60 La ,or "

l RESTORE " The combined leakage rate for all primary containment penetrations and all primary containment isolation valves, except for main steam line isolation valves

• and primary containment isolation valves which are .l hydrostatically tested, subject to Type B and C tests to less than or equal l to 0.60 La, and "

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ACTION Statement (with) 3.6.1.2.b, and ACTION Statement (restom) 3.6.1.2.b are l proposed to be revised to delete the references to Table 3 6.3-1 (Primary Containment  !

Isolation Valves) and the ACTION Statement wording is revised accordingly. The l referenced Table 3.6.3-1 is being deleted from the TS and relocated to plant procedures. The details in this table are not necessary to support the actions or  ;

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Attachment I to N~RC-94-0047 Page 6 of 12 surveillances required by the TS. The proposed word changes are consistent with the guidance provided in GL 91-08.

c. Revise footnote (*) for SR 4.6.1.2.b to remove the reference to Table 3.6.3-1 and to denote the following:

" *Unless a hydrostatic test is required."

Footnote (*) associated with SR 4.6.1.2.b is proposed to be revised to delete the reference to Table 3.6.3-1 (Primary Containment Isolation Valves). The referenced Table 3.6.3-1 is being deleted from the TS and relocated to plant procedures. The details in this table are not necessary to support the actions or surveillances required by the TS. The proposed word changes are consistent with the guidance provided in GL 91-08.

d. Added footnote (#) for SR 4.6.1.2.b to denote the following:

" # Except for LPCI I. cop A and B Injection Isolation Valves, which are hydrostatically tested in accordance with SpeciGcation 4.4.3.2.2 in lieu of this requirement."

Footnote (#) is proposed to be added to SR 4.6.1.2. since Table 3.6.3-1 (Primary Containment Isolation Valves) is being deleted. Table 3.6.3-1 effectively addressed this issue with footnote (s). However, because the table is being deleted, footnote (s) will also be deleted. Therefore, the (#) footnote was added to SR 4.6.1.2 to clarify the hydrostatic testing of LPCI Loop A and B Injection Isolation Valves Ell-F015A and El1-F015B. The proposed worti changes are consistent with the guidance provided in GL 91-08.

6. PRIMARY CONTAINMENT ISOLATION VALVES (3/4.6.3)

a. Revise LCO 3.6.3 to delete reference to Table 3.6.3-1 and the reference to isolation times shown in Table 3.6.31 as denoted by the following:

"Stch primary containment isolation valve and reactor instmmentation line excess flow check valve hLall be OPERABLE.**"

LCO 3.6.3 is proposed to be revised to delete the reference to Table 3.6.3-1 (Primary Containment Isolation Valves). The referenced Table 3.6.3 denotes primary containment isolation valves and associated isolation times.

The table is being deleted from the TS and relocated to the plant procedures.

The list of primary containment isolation valves is not necessary to support P

Attachment I to

- NRC-94-0047 Page 7 of 12 the actions or surveillances required by the TS. The footnote (**) was also added to the LCO as per the guidance in GL 91-08. The new footnote reads as follows: " ** Locked or sealed closed valves may be opened on an intermittent basis under administrative control. " The proposed word changes are consistent with the guidance provided in GL 91-08.

b. Revise ACTION Statements 3.6.3.a aud 3.6.3.b and SR 4.6.3.1, SR 4.6.3.2, SR 4.6.3.3, and SR 4.6.3.4 to delete references to Table 3.6.3-1 and to denote  ;

the following, respectively:

ACTION Statement 3.6.3.a; "With one.or more of the primary containment isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:"

ACTION Statement 3.6.3.b:

" With one or more of the reactor instrumentation line excess flow check valves inoperable, operation may continue and the provisions of Specification 3.0.3 are not applicable provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either: "

i SR 4.6.3.1:

" Each primary containment isolation valve shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by cycling the valve through at least one complete cycle of full travel and verifying the isolation time.*"

SR 4.6.3.2:

" Each primary containment automatic isolation valve shall be demonstrated OPERABLE during COLD SHUTDOWN or REFUELING at least once per 18 months by verifying that on a containment isolation test signal each automatic isolation valve actuates to its isolation position. " ,

SR 4.6.3.3:

" The isolation time of each primary containment power operated or automatic valve shall be determined to be within its limit when tested pursuant to Specification 4.0.5. "

Attachment 1 to NRC-94-0047 Page 8 of 12 SR 4.6.3.4:

" Each reactor instmmentation line excess flow check valve shall be demonstrated OPERABLE at least once per 18 months by verifying that the valve checks flow. "

ACTION Statements 3.6.3.a and 3.6.3.b and SR 4.6.3.1, SR 4.6.3.2, SR 4.6.3.3, and SR 4.6.3.4 are pmposed to be mvised to delete the mference to Table 3.6.3-1 (Primary Containment Isolation Valves). The referenced Table 3.6.3-1 is being deleted from the TS and relocated to the plant procedures. The details in this table are not necessary to support the actions or surveillances required by the TS.

c. Revise SR 4.6.3.1 to delete the word "specified" and to denote the following:

"Each primary containment isolation valve shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by cycling the valve through at least one complete cycle of full tmvel and verifying the isolation time" The

• at the end of SR 4.6.3.1 will also remain. It signifies a footnote which states, " Except for TIP shear valves which are demonstated OPERABLE per Specification 4.6.3.5."

SR 4.6.3.1 is proposed to be revised to delete the word "specified" since, with the deletion of Table 3.6.3-1 (Primary Containment Isolation Valves), the isolation times for primary containment isolation valves are no longer specified.

Table 3.6.3-1 is being deleted from the TS and relocated to the plant procedures. The reference to the isolation times are not necessary to support the actions or surveillances required by the TS.

d. Delete Table 3.6.3-1, " Primary Containment Isolation Valves" and retain a single page with the following note: "3/4 6-22 through 3/4 6-47 are 'not used'," which will account for the skipped pages.

Table 3.6.3-1 is pmposed to be deleted from the TS and relocated to plant procedures. Table 3.6.3-1 currently denotes primary containment isolation valves associated with Specification 3/4.3.2 (Isolation Actuation Instmmentation), Specification 3/4.6.1.1 (Primary Containment Integrity),

Specification 3/4.6.1.2 (Primary Containment Leakage) and Specification

Attachment I to NRC-94-0047 Page 9 of 12 3/4.6.3 (Primary Containment Isolation Valves). The table also consists of a list of associated valve numbers and maximum isolation times. The footnotes associated with Table 3.6.3-1 are also proposed to be relocated to plant procedums. The footnotes in this table are for information only. The list of primary containment isolation valves is not necessary to support the actions or surveillances required by the TS. The information being relocated to plant procedures will be controlled in accordance with TS Sections 6.5.3 and 6.8, which are subsections of the TS Administrative Controls Section ( 6.0). As a result, the deletion and subsequent relocation of this information from the TS complies with the guidance contained in GL 91-08. The proposed change, therefore, does not result in a technical change to the TS.

c. Revise Bases Section 3/4.6.3, " Primary Containment Isolation Valves" (page B .

3/4 6-6) to include a clarification of those actions which constitute

" administrative controls" as used in TS 3.6.3, Footnotes (*) and (**), for locked or sealed closed containment valves which are permitted to be opened under "administmtive controls." This Bases Section is revised to add the following words:

" The opening of locked or sealed closed containment isolation valves on an intermittent basis under administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with the control mom, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment."

Bases Section 3/4.6.3, " Primary Containment Isolation Valves" (page B 3/4 6-

6) is proposed to be revised to add the above wording. This change to the Bases Section is recommended by GL 91-08.

7. MOTOR-OPERATED VALVES TIIERMAL OVERLOAD PROTECTION

a. Revise LCO 3.8.4.3 to delete reference to Table 3.8.4.3-1 and added the words, "...used in safety systems...", as denoted by the following:

"The thermal overload protection of each valve used in safety systems shall be OPERABLE."

LCO 3.8.4.3 is proposed to be revised to delete the reference to Table 3.8.4.3-1 (Motor-Operated Valves Thermal Overload Protection) and the LCO wording is revised accordingly. The table is being deleted from the TS

Attachment I to i NRC-94-0047 l Page 10 of 12 i

and relocated to the plant procedures. The list provided in Table 3.8.4.3-1 is not necessary to support the actions or surveillances required by the TS. The proposed word changes am consistent with the guidance provided in GL 91-08.

b. Delete Table 3.8.4.3-1, " Motor-Operated Valves Thermal Overload Protection" and retain a single page with the following note: "3/4 8-21 through 3/4 8-24 are

'not used'," which will account for the skipped pages.

Table 3.8.4.3-1 is proposed to be deleted from the TS and relocated to plant procedures. The table currently denotes a list of requimd motor-operated valves with thennal overload protection including associated valve mimbers and systems affected. The list of required motor-operated valves with thermal overload protection is not necessary to support the actions or surveillances required by the TS. The information being relocated to plant procedures will be controlled in accordance with TS Sections 6.5.3 and 6.8, which are subsections of the TS Administrative Controls Section (6.0). As a result, the deletion and subsequent relocation of this infonnation from the TS complies with the guidance contained in GL 91-08. The proposed change, therefore, does not  !

result in a technical change to the TS.

The proposed TS page changes are attached. They am written in accordance with the guidance in Reference 2.

EVALUATION This proposal relocates the component lists for Primary Containment Isolation Valves (TS Table 3.6.3-1) and Motor-Operated Valves Thermal Overload Protection (TS Table 3.8.4.3-1) to the plant procedures. Relocating these component lists to the plant procedures will allow Fermi 2 to administratively control changes to these tables in accordance with TS Sections 6.5.3 and 6.8. These administrative controls include requirements for the review of changes in accordance with 10CFR50.59. This specinc change, in itself, has no effect on the surveillance or system requirements and so, no effect on plant safety. Additionally, this proposed TS change is a line item TS improvement which is encouraged by Refemnce 2.

SJISNIFICANT IIAZARDS CONSIDERATION ,

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 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 i

- Attachment I to NRC-94-0047 Page 11 of 12 t

previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident pmviously evaluated, or (3) involve a significant reduction in a margin of safety.

The proposed amendment will allow Fermi 2 to administratively control changes to the component lists for Primary Containment Isolation Valves and Motor-Operated Valves Thermal Overload Protection in accordance with the provisions of Generic Letter 91-08 (Reference 2) without the need to process a license amendment request. This modification is a line item TS improvement.

1. The proposed changes do not involve a significant increase in the pmbability or consequences of an accident previously evaluated. The proposed change will not result in any hardware or opemting changes. The proposed change is based upon Generic Letter 91-08 and merely remo';es component lists, removes details relating to the component lists, provides clarifying information supponing the mmoval of the-component listings, or removes details (which are considered administrative) that am no longer applicable to the TS. The removal of tabular component listings fmm the TS does not impact affected component OPERABILITY requirements. TS will continue to  !

require the components to be OPERABLE. Action statements and surveillance ,

requirements for the components will also remain in the TS. The tabular component  !

lists will be relocated to plant procedures which will be controlled in accordance with the provisions specified in the Administrative Controls Section of the TS. Therefore, this change is administrative in nature and does not involve a significant incmase in the probability or consequences of an accident previously evaluated. Further, the proposed changes do not alter the design, function, or operation of the components involved and therefore, do not affect the consequences of any previously evaluated accident.

2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes will not impose any different operational or surveillance requimments. The changes propose to relocate these component lists to plant procedures whereby adequate contml of information is maintained. Further, as stated above, the proposed changes do not alter the design, function, or operation of the components involved and therefore, no new accident scenarios are created.

3. The proposed changes do not involve a signincant reduction in a margin of safety. The pmposed change will not reduce a margin of safety because it has no impact on any safety analysis assumption. The proposed change does not alter the scope of equipment currently required to be OPERABLE or subject to surveillance testing nor does the proposed change affect any instmment setpoints or equipment safety functions.

Therefore, the change does not involve a significant reduction in a margin of safety.

Attachment I to NRC-94-0047 Page 12 of 12 ENVIRONMENTAL IMPACT l

Detroit Edison has reviewed the proposed Technical SpeciGcation changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor signiGcantly change the types or significantly increase the amour.ts of effluents that may be released offsite, nor significantly increase individual or ctimulative occupational radiation exposures. Based on the foregoing, Detroit Edison .

concludes that the proposed Technical Specifications meet the criteria given in l 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental i Impact Statement.

CONCLUSION Based on the evaluations 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 conducted in compliance with the Commission's regulations, and the proposed amendment will not be inimical to the common defense and security or the health and safety of the public.

In order to accomplish procedure changes associated with this change, Detroit Edison requests that the proposed license amendment be issued with a 60-day implementation period.

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ATTACIIMENT 2 PROPOSED TECIINICAL SPECIFICATION <

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ATTACIIMENT 2 PROPOSED TECIINICAL SPECIFICATION CIIANGFE 1

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