View source for NRC-89-0156, Application for Amend to License NPF-43,specifying Normal Flow Path for Primary Containment Nitrogen Control When Operating in Operational Conditions 1,2 & 3,per Generic Ltr 89-01

{{Adams
| number = ML20247R676
| issue date = 07/24/1989
| title = Application for Amend to License NPF-43,specifying Normal Flow Path for Primary Containment Nitrogen Control When Operating in Operational Conditions 1,2 & 3,per Generic Ltr 89-01
| author name = Sylvia B
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-89-0156, CON-NRC-89-156
| document report number = GL-89-01, GL-89-1, NUDOCS 8908080080
| package number = ML20247R679
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 12
| project = 
| stage = Request
}}

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  *   *-            B. RIlph Sylyb -
Ses.or vice Pressdent Detroi,t       , , , _ , , ,
Edison ==-"-
July 24, 1989
                                                              ,                    NIC-89-0156 U. S. Itclear Regulatory Comnission Attn         Document Control Desk Washington, D. C. 20555

==References:==
: 1)   Fermi 2 Nic Docket No. 50-341       +
NRC License No. IPF-43
: 2)   Detroit Mison Letter to NIC, NEC-88-4293, " Proposed 'Mchnical Specification Change (License Ami::iGieJit) - Gaseous Effluults, Venting and Purging, (3/4.11.2.8), Containment Systems, Drywell and Suppression Chanber Systen (3/4.6.1.8), Gaseous Effluents, Dose Rate (3/4.11.2.1), Radioactive Gaseous Effluent Monitoring Instrumentation (3/4.3.7.12)", dated Decenber 22, 1988
: 3)   Detroit Mison Letter to NIC, NFC-89-0082, "dithdrawal of Proposed Tuchnical Specification (License Amendment) - Addressed by Generic Letter 89-01 ('BC Nos. 72053 awl 72056)", dated April 5,1989
: 4)   Detroit Edison Letter to NIC, NEC-89-0279,                                                    I
* Proposed 'lehnical Specification Change (License                                           l' Ame:dment) - Isolation Actuation Instrumentation (3/4.3.2)", Decenber 227 1988                                        .

==Subject:==
Proposed Technical Specification Change (License Amendment) - Cbntairment System Drywell and Suppression Chanber Purge l                                         System (3/4.6.1.8)                                                                                  .
1                                                                                                                                            \
Pursuant to 10CFR50.90, Detroit Edison Coupany hereby pecposes to amend Operating Licenne NPF-43 for the Fermi 2 plant by incorporating                                                  ,
l                   the enclosed changes to Technical Specification 3/4.6.1.8, "Drywell                                                      l l
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PNV     ',                                                                            .

USNIC July 24, 1989 NRC-89-0156
         . Page 2 and Suppression Chamber Purge Systst", and the associated Bases. The proposed change specifies the normal flow path for primary containment nitrogen control (vent / makeup) ard pressure control when operating in OPERATIONE COIDITIONS 1, 2, and 3. This change was identified by the Technical Specifications Improvement Program.
The attached proposed changes were previously submitta3, along with scne other proposed changes, in mcordance with Reference 2.
Reference 2 was subsequently withdraan, by Reference 3, when the NIC issued Generic Letter 89-01 (Removd of Radiological Effluent Technical Specifications) . This change is being resubmitted because it it, not directly associated with Generic ' Letter 89-01.
Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 107R50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Organization has approved and the Ibclear Safety Review Group has reviewed the proposed Technical Specification change and concurs with the enclosed determinat ions. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.
In order to allow sufficient time for impimentation of these changes, Detroit D31 son requests that this amendment be effective 30 days after NIC issuance.
If you have any questions, pleac3 contmt Mr. Gordon NaSer at (313) 506-4513.
Sincerely, f
Enclosure cc: A. B. Davis R. C. Knop W. G. Rogers J. F. Stang Supervisor, Advanced Planning and Review Section.
Michigan Public Service Camission l
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USNIC July 24, 1989 10 0-89-0156
    . Page 3 I, B. RALPH SYLVIA, do herd >y affirm that ta e foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge ard belle:f.
thfiv/               Y)
B. ma snfa-Senior Vice President On this                 day of,      It/o          ,1989, before rac personally appeared B. Ralph Sylv   , bepg first duly sworn and says that I?e executed the foregoing a his free act and 6eed.
g/UL$ h.             GM lbtary Public RO'M
                                                      .!E A. ADMETTA PbtoY Pubi'c MyConnwoo.Momoo County MI fxPre3Jcn.101992
                                                                               .s

Enclosure to NRC-89-0156 Page 1 IW/HODUCTJON Primary containment purge capability is provided for the purpose of removing fission product activity from the containment atmosphere and as a backup to hydrogen and pressure control. Fermi 2 design is such that all purging and venting from primary containment is directed into f.ither the Reactor Building Heating Ventilating and Air Conditioning System (RBHVAC), whi'h then exhausts into the Reactor Building Exhaust Plenum and out the R1 actor Building Exhaust stack, or into the Standby Gas Treatment System (SGTS) which exhausts out the SGTS stack. The SGTS is utilized to reduce the fission product activity released to the environment if the released activity is projected to exceed the annual radiological gaseous effluent Technical Specification limits.
The purge system is comprised of a large piping system used primarily for purging and inerting and a smaller system used for nitrogen vent / makeup and pressure control. The larger purge system consists of 6, 10, 20 and 24 inch containment isolation valves. The large purge system has individual supply and exhaust lines for the Drywell and Suppression Chamber. The small pur6e system consists of 1' inch containment isolation valves. The smaller system has only.3one line connected to the Drywell and one connected to the Suppression Chamber. These lines are used for venting, makeup and pressure control, Automatic containment isolation occurs for all the above mentioned valves on low reactor water level and high drywell pressure.
Please note that these valves also currently isolate on a Fuel Pool Exhaust Radiation Signal. However, as stated in Reference 4, this signal's input to these valves is not required to mitigate any of the design basis accidents.
EVALUATION The larger purge lines, in general, are restricted for use except during cold plant conditions. However, Technical Specification 3/4.6.1.8 allows one supply and one exhaust line open for inerting, deinerting or pressure control provided purging through the SGTS is limited to 90 hours / year. Specification 3/4.6.6.2 provides the inerting and deinerting requirements. Technical Specification                                           '
3/4.6.1.8 suspends the 90 hours / year time limit if the 6 inch purge l       valves are used. The basis for this time limit is to reduce the potential for damaging the SGTS charcoal filters as a result of the l
initial pressure transient from a Loss of Coolant Accident (LOCA).
Should a LOCA occur while the pathray is through the SGTS the associated initial pressure surge, before the purge valves c1cse, may adversely affect the integrity of the SGTS's charcoal filters even though these purge valves are qualified to close in the event of a LOCA. This concern is not applicable wnen purging through the RBHVAC

Enclosura to NRC-89-0156 Page 2' because RBHVAC is not relied upon for accident mitigation, unlike the I
SGTS.
During normal power operation the smaller-purse system is used for                                                          ;
nitrogen concentration and pressure controlr not.the 6 inch purge                                                             j valves. Automatic control of the drywall pressure is by means.of.a                                                        .j pressure controller that maintains a slightly. positive pressure on the                                                       l drywell by venting through a 1-inch exhhust valve. Suppression                                                                :
chamber pressure control is similar, through a separate 1-inch vent                                                          j valve.- Manual control of containment pressure is by means of the same 1-inch valves by putting nitrogen into, or venting nitrogen from,.the drywell'or suppression chamber.- Therefore, the proposed Technical                                                          ]
Specification changes.are being submitted to more accurately represent                                                        i normal (at power) plant operating practices and to clarify which sys M s are applicable to the 90 hour / year time limit. The' specific.                                                     ,
proposed changes (attached) to Technical Specification 3.6.1.8 and                                                          -
associated Bases are:
o     Added'a sentence to the LCO that specified nitrogen venting / makeup and' pressure control are allowed with the 1-inch            .
valves. This sentence was added to clarify that the 1-inch purge valves, which were designed to be used.under normal plant j
operation for nitrogen and pressure control, can be used in-lieu of the 6-inch valves.      (Please note that the current Technical                                                      {
Specifications do not prohibit the use of the 1-inch valves for                                                         i purging and venting.)                                                                                               '!
o     Modified the
* footnote.such that primary containment nitrogen                                                        j VENTING and pressure control utilizing the 1-inch valves is not                                                        j under the 90 hour / year limit and thus,'added the 6-inch valyes to                                                    l the list of valves which are applicable.to this limit.
                                                                                                                                                                                             ]
o     Added additional operating configuration description to the Bases                                                      i and clarified that purging and venting through the RBHVAC is'not time limited because the basis for this time limit is only applicable to the SGTS, as mentioned previously.                                                                      ;
t The proposed changes are justified based on the following:                                                                   ;
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: 1)    The proposed Technical Specification is more restrictive because the time limit exemption on venting and purging through the SGTS is only applicable to the smaller 1-inch purge valves, not the                                                          l 6-inch va!ves.                                                                                                          !
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: 2)    The proposed Technical Specification does not result in any modification to the plant cr introduce a new mode of plant operation.

                                -     Enclogure to NRC-89-0156 Page 3
: 3)    The use of the 1-inch purge alves for nitrogen concentration adjustments and pressure control is in accordance with the UFSAR Section 6,.2.5.2.5 and the NRC Safety Evaluation Report,                 j Supplement 3, Appendir H.
SIGNIFICANt HAZARDS 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 of 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.
: 1)    The proposed change changes do not involve o significant increase in the probability or consequences of an accident previously evaluated because the changes do not involve a physical modification to the plant or introduce a new mode of operation.
The prrposed Technical Specification is more restrictive than the current Technical Specification because the time limit exemption on venting and purging through the STGS is applicable to the             ;
smaller 1-inch purge valves, not the 6-inch purge valves. The             l 1-inch purge valves are the valves normally used at power for nitrogen concentration and pressure control and their use for venting and purging is not prohibited by the existing Technical Specifications.
: 2)    The proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed because, as stated above, the proposed changes do not introduce a new mode        ;
of plant operation nor involve a physical modification to the plant.
: 3)    The proposed changes do not involve a significant reduction in the margin of safety because the proposed changes impose more restrictive requirements for purging through the SGTS. The l
proposed Technical Specification specifies the normal (at power) j                                           nitrogen concentration and pressure control flow path. This flow l                                           path is discussed in the UFSAR Section 6.2.5.2.5 and the NRC's Safety Evaluation Report, Supplement 3 Appendix H.
Based on the above, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.
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    "'      Enclorurs to NRC-89-0156                                                              ,
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ENVIRONMENTAL IMPACT
           . Detroit Edison has reviewed.the proposed Technical Specification changes against the criteria of-10CFR51.22 for environmental considerations. The proposed change does not involve a significant      a hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual-or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
CONCLUSION Based on the evaluation above:    1) there is reasonable assurance that the health and safety of the public will not be endangered by           1 operation in the proposed manner, and 2) such activities' will be        ;
conducted in compliance with the Commission's regulations and proposed   ;
amendments will not be inimical to the common defense and security or to the health and safety of the public.                                j I
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