View source for NRC-91-0150, Submits Formal Commitments Re Control Room Emergency Filtration Sys,Per NRC 911021-25 Visit to Facility.Ts Change Proposal,To Incorporate New Charcoal Lab Analysis Std,Will Be Submitted by 920131

{{Adams
| number = ML20086A107
| issue date = 11/11/1991
| title = Submits Formal Commitments Re Control Room Emergency Filtration Sys,Per NRC 911021-25 Visit to Facility.Ts Change Proposal,To Incorporate New Charcoal Lab Analysis Std,Will Be Submitted by 920131
| author name = Orser W
| 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-91-0150, CON-NRC-91-150
| document report number = NUDOCS 9111180242
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 2
| project = 
| stage = Other
}}

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                      =1n:6                                                               ,.a Detroit  -
                       -n Edison %%==                                                                             um.
Novembe r 11. 1991 NkC-91-0150 U. S. Nuclear Regulatory Car. mission Attn     Document Control Desk Washington, D. C. 20555

==References:==
: 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
: 2) Detroit Edison letter to NRC NRC-90-0150, dat ed September 11, 1990
: 3) Detroit Edison letter to NRC. NRC-89-0215 dated November 16, 1989

==Subject:==
Commitments Concerning Control Room Emergency Filtration System During the period of October 21-25. 1991, members of the NRC staff visited Fet1ni 2 to discuss pending licensing actions concetning the Control Room Emergency Filtration System (CREFS). The purpose of this -
letter is to make formal commitments in regards to the items discussed              .
during this visit.
The first item concerns the requitements for charcoal laboratory analysis contained in the CCHVAC Technical Specification (TS) suneillance-requirements. The TS curtently refers to Regulatory Position C.6.b of Regulatory G? tide 1.52. Revision 2. March 1978. As discussed in the NRC staf f visit. nare recent standards exist which give more consistent and accurate results. Dets oit Edison will evaluate the available standards and, based upon technical adequacy and the availability of qualified laboratories . propose a TS change to incorporate s new CREFS charcoal laboratory analysis standard. This evaluation will be given a high priority and the TS change proposal is expected to be submitted within the next dou:h. In any case, the TS change proposal will be subtaitted no later tnan January 31, 1992.
The TS surveillance requirements for the Standby Cas Treatment System (SGTS) also includes charcoal laboratory at alysis requirements specifying the same standards. Therefore, the TS change proposal wil1~
also update the charcoal laboratory at.alysis standard for the SGTS.
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         ~ - . . - - - - . - - - ~ _
USHRC eNovember 11, 1991 NRC-91-0150 Fage 2 The second item involvos the proposed CREFS TS change of Reference 2.
This proposal includes, under special circumstances, a six hour delay in taking the action of shutting down the plant due to inoperability of the non-redundant emergency filt ration flowpath. This proposed delay is litdt ed to the perf ormance of TS 4.7.2.c due to painting, fire, or chemical release in any ventilation zone communicating with the CREFS or to perf orn TS 4.7.2.d. TS 4.7.2.d requires a chatcoal sample be taken following every 720 hours of charcoal adsorber operation. If unusual periods of filter operation occur, performance of TS_4.7.2.d could be required during plant operation.
As discussed during the staf f visit and in Reference 2 this provision is expected to be used very infrequently. Nonetheless, to ensure that any use of the proposed delay receives appropriate regulatory attent3on, Detroit Edison will make a special report to the NRC within 30 days deceribing the circumstances of any use of thfe provision.
This reporting requirement will be included in the plata administrative procedures for regulatory reporting requirements.        It will also be included in the charcoal sampling procedute for the CREFS. These procedure changes wi13 be made an part of the implementation of the-Reference 2 TS change. In order to allow adequate time to make these and other procedure changes associated with the TS change. Detroit Edison req ~ests that the Reference 2 TS change a ns.w;,d vith a 10 day implementation period.
I Also discussed during the staff visit, was the proposed CREFS duct visual inspection and leakage testing program submitted by Reference
                                 -3. -This program addresses concems about. the use of silicone sealant on portions ef CREFS duct external' to the Control Roca and consists of TS requirements for annual visual inspections and 36-moth leakage tests.      In response to staff concerns, Detroit Edison has prepared a supplement to the' Rt:ference 3 proposal to increase the scopo of the visual inspection and to update the testing standard to a more recent
                                 -standard.- This supplemental proposal is currently in the review process and will be submitted in the very near future.
If you have any-questions on these matters, please contact Mr. Glen D.
Ohlemacher at (313) 586-4275.
Sincerely.
Ld//
                                - cet - A. B. Davis R. W. DeFayette
                                          .J. F. Stang.
S. Stasek
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