ML102770382

Issuance of Amendment to Revise Degraded Voltage Function to Reflect Modification

ML102770382
Person / Time
Site:	Fermi  (NPF-043)
Issue date:	10/20/2010
From:	Mahesh Chawla Plant Licensing Branch III
To:	Jennifer Davis Detroit Edison
Chawla M, NRR/DORL, 415-8371
References
TAC ME1477
Download: ML102770382 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 20, 2010 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166 SUB~IECT:

FERMI 2 - ISSUANCE OF AMENDMENT TO REVISE DEGRADED VOLTAGE FUNCTION TO REFLECT MODIFICATION (TAC NO. ME1477)

Dear Mr. Davis.

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 183 to Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment consists of changes to the Technical Specifications in response to your application dated June 10, 2009, supplemented by letters dated September 16,2009, July 23,2010, and October 4,2010.

The amendment revises Table 3.3.8.1-1 to add a new time delay logic associated with Function 2 for degraded voltage concurrent with a loss-of-coolant accident to address issues discussed in NRC Inspection Report 05000341/2008008, dated June 20,2008. The amendment also revises the maximum and minimum allowable values for the 4160V emergency bus undervoltage for Surveillance Requirements 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14, and 3.8.1.17.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Mahesh L. Chawla, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 183 to NPF-43

2. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DETROIT EDISON COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 183 License No. NPF-43

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by the Detroit Edison Company (the licensee) dated June 10, 2009, as supplemented by letters dated September 16, 2009, July 23, 2010, and October 4, 2010, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-43 is hereby amended to read as follows:

- 2 Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 183, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. DECo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented upon startup from the fourteenth refueling outage.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachment Changes to the Technical Specifications Date of Issuance: October 20, 2010

ATTACHMENT TO LICENSE AMENDMENT NO. 183 FACILITY OPERATING LICENSE NO. NPF-43 DOCKET NO. 50-341 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT Page 3 Page 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.3-73 3.3-73 3.8-3 3.8-3 3.8-4 3.8-4 3.8-5 3.8-5 3.8-6 3.8-6 3.8-7 3.8-7 3.8-9 3.8-9

- 3 (4)

DECo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material such as sealed neutron sources for reactor startup, sealed sources for reactor instrumen tation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

DECo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)

DECo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level DECo is authorized to operate the facility at reactor core power levels not in excess of 3430 megawatts thermal (100%

power) in accordance with conditions specified herein and in Attachment 1 to this license. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 is hereby incorporated into this license.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment 183, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. DECo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Antitrust Conditions DECo shall abide by the agreements and interpretations between it and the Department of Justice relating to Article I, Paragraph 3 of the Electric Power Pool Agreement between Detroit Edison Company and Amendment No. 183

LOP Instrumentation 3.3.8.1 Table 3.3.8.1*1 (page 1 of 1)

Loss of Power Instrumentation REQUIRED CHANNELS SURVEILLANCE FUNCTION PER BUS REQUIREMENTS ALLOWABLE VALUE

1. 4.16 ~V Emergency Bus Undervoltage (Loss uf Voltagel

a. Bus Undervoltage 4

b. T1me Delay 4

2. 4.16 (V Emergency Bus Undervoltage (Degraded Voltage)

a. Bus trndervo1tage 4

b. 'Ttne Delay 4

c. T1me Delay (with LOCAl 4

.v-:

(

\\..

(a)

Division I:

Divis*ion II:

~ 2972.3 V and ~ 3093.7 V

~ 3016.4 V and ~ 3139.6 V (bl Division I:

Division II:

~ 1.9 sec and S 2.1 sec

~ 1.9*sec and S 2.1 sec (c)

Division I:

DiVision II:

~ 3904.4 V and S 3944.8 V

~ 3659.4 V* and ~ 3699.8 V (d)

Div1sion I:

Division II:

~ 41.8 sec and ~ 46.2 sec

~ 20.33 sec and s 22.47 sec (e)

Division I:

~ 6.16 sec and ~ 7.31 sec Division II:

~ 6.16 sec and ~ 7.31 sec SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR 3.3.8.1.1 3.3.8.1.2 3.3.8.1.3 (al 3.3.8.1.1 3.3.8.1.2 3.3.8.1.3 (bl 3.3.8.1.1 3.3.8.1.2 3.3.8.1.3 (el.

3.3.8.1.1 3.3.8.1.2 3.3.8.1.3 (dl 3.3.8.1.1 3.3.8.1.2 3.3.8.1.3

, (el FERMI - UNIT 2 3.3-73 Amendment No. +/-J4 183

AC Sources --Operating SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.

SR 3.8.1.2 NOTES*

1.

AH E9G starts nay be preceded by an engine prelube period and followed by a.warmup p~riodprior to loading.

2.-

A modified EDG start involving idling and gradual acceleration to synchronous speed may be used fo~-this SR ao? recommended by the manufacturer.

Verify each EnG starts and achieves steady state voltage ~ 3950 V and ~ 4580 V and

(

frequency ~ Sa.8 Hz ahd ~ 61.2 Hz.

SR 3.8.1.3

~

NOTES*

1; EDG loadings.may include gradual loading as recommended by the manufacturer.

2.

Momehtary transients below the load limit do not invalidate this test.

3.

Thi 5 Survei 11 ance shall be conducted on only one EDG at a time.

Verify each EDG is synchronized and loaded and operates for 2 60 minutes at a load 2 2500 kW.

3.8.1 FREQUENCY 7 days 31 days 31 days (continued)

FERMI. UNIT 2 3.8-3 Amendment No.,t,t)..pg 183

AC Sources -- Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.4 Verify each day tank contains ~ 210 gal fuel oil.

of SR 3.8.1.5 Check for and remove each day tank.

accumulated water from

£R 3.8.1.6

-Verify each fuel oil transfer system operates to automatically transfer fuel oil from storage tanks to th~ day tanks.

(

_SR 3.8-.-1._7_

. -.*- - -.. - -".. "..*** NOTE* -. -. ----. ----. -. --.

All EOG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

,J *******

Verify each'EOG starts from standby condition and achieves:

a.

In ~ 10 seconds, voltage ~ 3950 V and frequency ~ 58.8 Hz; and

b.

Steady state voltage ~ 3950 V and

~ 4580 V and frequency ~ 58.8 Hz and

~ 61.2 Hz.

SR __ 3.8.1.8 Verify each EDG rejects a load greater than or equal to its associated single largest post-accident load, and following load rejection, the frequency is ~ 66.75 Hz.

3.8.1 FREQUENCY 31 days 31 days 31 days 184 days 18 months (continued)

FERMI. UNIT 2 3.8-4 Amendment No. ~}, +/-+g 183

AC Sources --Operating SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.9 Verify each EOG does not trip and voltage is maintained ~ 5267 Vduring and following a load rejection of ~ 2850 kW.

SR 3.8.1.10

-. ---------. -. -----NOTE-. ---. ----. --------

All EDG starts may be preceded by an engine

-pre=J ube period.

Verify on simulated loss of offsite power signal:

a.

Qe~energization of emergency buses;

b.

lQad shedding from emergency buses:

and

c.

EDG auto-starts and:

1. energizes permanently connected

(

loads in ~ 10 seconds,

2. energizes auto-connected shutdown loads through load sequencer,

3. maintains steady state voltage

~ 3950 V and ~ 4580 V~

4. maintains steady state frequency

~ 58.8 Hz and ~ 61.2 Hz. and

5. supplies permanently connected and auto-connected shutdown loads for

~ 5 minutes.

3.8.1 FREQUENCY 18 months 18 months (continued)

FERMI - UNIT 2 3.8-5 Amendment. No. iti. jl/J. m 183

AC Sources --Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.'8.1.11

---

. ------NOTE------------. ------

All EDG starts may be preceded by an engine prelube period~

~

Verify on an actual or simulated Emergency Core Cooling System (ECCS) initiation signal each EDG auto-starts and:

a.

In,~ 10 seconds after auto-start and

-during tests, achieves voltage

~ 39~O Vand frequency ~ 58.8 Hz;

b. Achieves steady state voltage ~ 3950 V and ~ 4580 V, and frequency ~ 58.8 Hz and ::s; 61.2-Hz.-:-and

. c.

Operates fur ~ 5 minutes.

SR 3.8.1.12 Verify each EOG's automatic trips are

.(

bypassed on an actual or simulated emergency start signal except:

a.

Engine overspeed;

b. Generator differential current;

c.

Low lube oil pressure;

d.

Crankcase overpressure; and

e.

Failure to start.

FREQUENCY.

18 months 18 months (continued)

FERMI - UNIT 2 3.8-6 Amendment No. Itl. m 183

AC Sources >>-Operati ng SURVEILLANCE REQUIREMENTS (continued)

SLiRVEI LLANCE SR 3.8.1.13

• • • • • • • • • • • • • • • • • • NOTE*********************

Momentary transients outside the load range do not invalidate this test.

~

Verify each EDG operates for ~ 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

a.

For all but the final ~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded

~ 2500 kW and ~ 2600 kW; 'and*

b.

Fo~ the final ~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the test loaded ~. 2800 kW and ~ 2900 kW.

SR 3.8.1.14

_****-~~-****NOTES**--*_**_*_***_*_*

'1.

This Surveillance shall be perfnrmed

-w-itl9i-n..5.. minutes of shutting down the EDGafter the EDG has operated

~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded*~ 2500 kW or until operating temperatures have stabil ized..

(

Momentary transients below the load limit do*not invalidate this test.

2.. All EDG starts may be preceded by an engine.prelube period.

Verify each EDG starts and achieves:

a.

In ~ 10 seconds, voltage ~ 3950 V and frequency ~ 58.8 Hz; and

b.

Steady state voltage ~ 3950 V and

~ 4580 Vand frequency ~ 58.8 Hz and

~ 61.2 Hz.

3.8.1 FREQUENe-V 18 months 18 months (continued)

FERMI. L1NIT 2 3.8*]

Amendment No. Xi;!, m 183

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.8.1.17

---

. -.. ---. --.. NOTE*. --. --.. -. --. -.....

All EDG starts may be preceded by an engine prelube period.

Verify, on "simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal:

a.

De-energization of emergency buses;

b.

Lqad shedding from emergency buses; and

c.

EDG auto-starts and:

1.

energizes permanently connected loads in ~ 10 seconds,

2. energizes auto-connected emergency loads through load sequencer,

(

"3.

achieves steady state voltage

~ 3950 V and ~ 4580 V,

4.

achieves steady state frequency

~ 58.8 Hz and ~ 61.2 Hz, and

5.

supplies permanently connected and auto-connected emergency loads for ~ 5 minutes.

SR 3.8.1.18... ---..... --.. ---.NOTE*.. --. --. -. -... -.. -.

All EDG starts may be preceded by an engine prelube period.

Verify, when started simultaneously each EDG achieves, in s 10 seconds, frequency

~ 58.8 Hz.

FREQUENCY 18 months 10 years FERMI - UNIT 2 3.8-9 Amendment No. J'/>1, m 183 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.183 FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDISON COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated June 10, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091680379), Detroit Edison (the licensee) submitted a license amendment request for Fermi 2 Nuclear Generating Power Plant to revise Technical Specifications (TS) Table 3.3.8.1-1. In response to the Nuclear Regulatory Commission (NRC) staff's requests for additional information, the licensee supplemented the application by letters dated September 16, 2009 (ADAMS Accession No. ML093070294), July 23, 2010, (ADAMS Accession No. ML102140429), and October 4,2010 (ADAMS Accession No. ML102780145).

The proposed amendment would revise the Degraded Voltage Function in TS Table 3.3.8.1-1, "Loss of Power Instrumentation," including addition of a new time delay relay for loss of coolant accident. Specifically, the amendment WOUld:

1. Revise the allowable value in Footnote (c) from "~ 3873.0 V and ~ 4031.0 V," to

"~ 3904.4 V and ~ 3944.8 V." for Division I.

2. Revise allowable value in Footnote (c) from "~3628.0 V and ~ 3776.0 V," to "~3659.4 V and ~ 3699.8 V." for Division II.

3. Add Function 2c, Time Delay (with LOCA), with Footnote (e) for Allowable Value "~6.16 sec and ~ 7.31 sec" for Division I and Allowable Value"~ 6.16 sec and ~ 7.31 sec" for Division II and Surveillance Requirements SR 3.3.8.1.1, SR 3.3.8.1.2, and SR 3.3.8.1.3.

In the July 23, 2010, letter the licensee stated that the NRC Component Design Bases Inspection (CDBI) identified issues related to the electrical design bases calculations. To address the CDBI issues, reconstitution of electrical design bases calculations necessary to support the modification was performed. As a result of the reconstituted calculations, the licensee determined that it was necessary to revise the proposed time delay proposed in the initial amendment request of June 10, 2009, for the logic associated with Function 2 in Table 3.3.8.1-1 for the concurrent conditions of degraded voltage and loss-of-coolant accident (LOCA). Additionally, the licensee determined that it was necessary to revise the maximum and minimum allowable values for the 4160 Volt Emergency Bus Undervoltage (Degraded Voltage)

Enclosure

- 2 function in Table 3.3.8.1-1, and also revise the minimum emergency diesel generator (EDG) output voltage in SRs 3.8.1.2,3.8.1.7,3.8.1.10,3.8.1.11,3.8.1.14 and 3.8.1.17.

There were also concerns raised by the NRC staff regarding the setting tolerances for the relays. Specifically, Setpoint Calculation: DC-0919, Volume I DCD 1, Revision A, submitted by the licensee does not show computation of as-found tolerance (AFT) values. The licensee provided the clarification in an e-mail dated September 27,2010 (ADAMS Accession No. ML102770115), stating that allowable values are used for the AFT values. The NRC staff finds this practice to be non-conservative. During further discussions, the licensee agreed to correct the calculation and show the computation of AFT values in the revised calculation. The licensee provided its response in the letter dated October 4, 2010.

The additional changes submitted by the licensee after the issuance of the original Federal Register notice (74 FR 40235, dated August 11, 2009) led the NRC staff to publish a revised notice (75 FR 48373, dated August 10, 2010). The licensee's October 4, 2010, letter contains only clarifying information that did not change the scope of the proposed amendment; there is thus no need to further revise the revised notice of August 10, 2010.

2.0 REGULATORY EVALUATION

Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50), Appendix A, General Design Criterion (GDC) 17, "Electric power systems," requires that an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences, and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents. The loss of power instrumentation settings and control assures proper operation of safety-related loads as required by GDC 17 of 10 CFR Part 50, Appendix A.

Part 50 of Title 10 of the Code of Federal Regulations, Section 36 (10 CFR 50.36), "Technical Specifications," requires that "each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section." Specifically, 10 CFR 50.36(c)(1 )(ii)(A) states, "Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded." Furthermore, 10 CFR 50.36(c)(3) states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

GDC 13, "Instrumentation and Control," requires that instrumentation be provided to monitor variables and systems and that controls be provided to maintain these variables and systems within prescribed operating ranges.

- 3 GDC 20, "Protection System Functions," requires that the protection system be designed to initiate the operation of appropriate systems to ensure that specified acceptable fuel design limits are not exceeded.

Regulatory Guide (RG) 1.105, "Setpoints for Safety-Related Instrumentation," Revision 3, describes a method that the NRC staff finds acceptable for use in complying with the NRC's regulations for ensuring that setpoints for safety-related instrumentation are initially within, and will remain within, the TS limits. RG 1.105 endorses Part I of Instrument Society of America-S67.04-1994, "Setpoints for Nuclear Safety Instrumentation," subject to NRC staff clarifications.

Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications,' regarding Limiting Safety System Settings during Periodic Testing and Calibration of Instrument Channels" (dated August 24,2006, Accession No. ML051810077) addresses requirements on limiting safety system settings that are assessed during the periodic testing and calibration of instrumentation. RIS 2006-17 discusses issues that could occur during the testing of limiting safety system settings and that, therefore, may have an adverse effect on equipment operability.

Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (NUREG-0800), Branch Technical Position (BTP) 8-6, March 2007 (similar to the previous BTP PSB-1, July 1981) "Adequacy of Station Electric Distribution System Voltages," states that the TS should include limiting conditions for operations, surveillance requirements, trip setpoints, and maximum and minimum allowable values for the first level of undervoltage protection (loss of offsite power) relays and the second level (degraded voltage) protection sensors and associated time delay devices.

3.0 TECHNICAL EVALUATION

Currently, TS Table 3.3.8.1-1 has only one time delay function associated with degraded voltage, and it pertains to both LOCA and non-LOCA conditions. NRC Inspection Report 05000341/2005016, dated January 13, 2006 (Accession No. ML060200574), postulates that the existing degraded voltage relay time delays of 44+/-2.2 seconds and 21.4+/-1.07 seconds for Division 1 and 2, respectively, could delay water injection flow into the reactor vessel during a LOCA concurrent with a degraded voltage condition (contrary to the assumption used for accident analysis). This deficiency was identified as an unresolved item, and resulted in Task Interface Agreement 2007-003. Consequently, the NRC staff conveyed its conclusion in a letter dated June 20, 2008 (ADAMS Accession No. ML081720585), to the licensee, stating that the time delay relay settings for the degraded voltage relays for both divisions could impact the emergency core cooling system injection timing requirements. In its letter dated August 4, 2008 (Accession No. ML082250256), the licensee agreed to provide a modification to the degraded voltage protection scheme. The modification would provide additional degraded voltage logic that will separate the safety-related buses from the electrical grid if a degraded voltage is present for approximately 6-10 seconds concurrent with a safety injection/LOCA signal.

In its June 10, 2009, letter the licensee proposed modifications which would provide additional time delay logic such that if degraded voltage were to occur concurrent with a LOCA, the safety-related buses would switch from the electrical grid (offsite power) to the onslte power (EDGs) in less than 10 seconds. However, if degraded voltage were to occur under non-LOCA

- 4 conditions, the safety-related buses would remain connected to the offsite power for up to 44+/-2.2 seconds and for up to 21.4+/-1.07 seconds, respectively, for Division 1 and 2, as per existlnq time delay logic. In particular, in case of a degraded voltage condition occurring concurrent with a LOCA condition, the time delay proposed was ~7.6 seconds and ::;8.4 seconds (nominal 8+/-OA seconds).

Bye-mail dated July 27, 2009 (ADAMS Accession No. ML092090231), the NRC staff asked the licensee to provide additional information relating to the proposed modification. The licensee provided its response in a letter dated September 16, 2009. However, since this response did not provide adequate information, the NRC staff in its letter dated February 24, 2010 (ADAMS Accession No. ML100350668) asked the licensee to provide additional information/clarifications.

The licensee provided the additional information by letter dated July 23, 2010.

In the July 23,2010, letter the licensee stated that the NRC CDBI identified issues related to the electrical design bases calculations. To address the CDBI issues, reconstitution of electrical design bases calculations necessary to support the modification was performed. As a result of the reconstituted calculations, the licensee determined that it was necessary to revise the proposed time delay proposed in the initial amendment request of June 10, 2009, for the logic associated with Function 2 in Table 3.3.8.1-1 for the concurrent conditions of degraded voltage and LOCA. Additionally, the licensee determined that it was necessary to revise the maximum and minimum allowable values for the 4160 Volt Emergency Bus Undervoltage (Degraded Voltage) function in Table 3.3.8.1-1, and also revise the minimum voltage EDG output voltage in SR 3.8.1.2,3.8.1.7,3.8.1.10,3.8.1.11,3.8.1.14 and 3.8.1.17.

3.1 Proposed TS Changes

3.1.1 Table 3.3.8.1-1, Function 2 -4160 V Emergency Bus Undervoltage (Degraded Voltage)

The licensee proposed to add Function 2.c to this table to account for degraded voltage occurring concurrent with LOCA with the following Time Delay Values:

Division I: ~6.16 seconds and ::;7.31 seconds (nominal 6.7 seconds)

Division II: ~6.16 seconds and ::;7.31 seconds (nominal 6.7 seconds)

The licensee proposed to revise the degraded voltage allowable values of Function 2.a as follows:

Division I: ~3904A V and ::;3944.8 V Division II: ~3659.4 V and ::;3699.8 V The existing values of Function 2.a are as follows; the revised values are considered conservative compared to the existing values:

Division I: ~3873.0 V and ::;4031.0 V Division II: ~3628.0 V and ::;3776.0 V Following is the NRC staff's evaluation of the licensee's response provided in its July 23, 2010, letter:

(1)

In response to the NRC staff's request to provide the bases for the switchyard voltages considered in the electrical design bases calculations, the licensee stated that the

- 5 following grid contingencies considered in the Annual Grid Study provide justification that the voltages will remain above 93.3 percent at 120 kV and 98.4 percent at 345 kV switchyard buses:

a) The loss of Fermi 2 with and without a fault b) The-loss of any generating unit on the Transmission Owner's grid that could affect Fermi 2 c) The loss of any major transmission circuit or intertie on the Transmission Owner's grid that could affect Fermi 2 d) The loss of any large load due to failures of transmission system elements that could affect Fermi 2 e) Power transfers that could affect Fermi 2 The contingencies are also monitored on real time basis (approximately every 10 minutes) by the transmission system owner. A Nuclear Plant Operating Agreement is in place that requires notifying the plant if any of these contingencies would result in voltages lower than 93.3 percent on Division 1 and 98.4 percent on Division 2.

Based on review of the above, the NRC staff considers the licensee's assumed minimum switchyard voltages in the electrical design bases calculations acceptable.

(2)

In response to the NRC staff's request to provide the analysis to show that the degraded voltage relay settings are adequate, the licensee stated that analyses performed by the licensee demonstrate that the electrical system will perform as follows with the minimum switchyard voltages:

The system will not separate from the grid due to either the loss of voltage or degraded voltage relay actuation.

All 4 kV and 480 V safety-related continuous duty motors required to start on a LOCA signal will successfully start within the required time frames.

All safety-related Motor Operated Valves (MOVs) will start within the required time frames.

No running safety-related continuous duty motors will stall as a result of the voltage transient.

No safety-related thermal protective devices for LOCA autostart loads will spuriously trip as a result of excessive load currents or inrush current durations due to the transient.

No safety-related 120 V motor control center motor starters/contactors will drop out as a result of the transient.

The licensee stated that the relay settings and ranges are based on the results of the steady state voltage analysis at the minimum voltage analytical limits, transient analysis for motor starting associated with a LOCA, and motor starting transient analysis for the largest motor in a non-LOCA condition. The selection of degraded voltage relay (DVR) voltage and timing setpoints includes consideration of instrument tolerances and relay drift.

- 6 The licensee also stated that with respect to the protective function of the DVR relay settings, the ability of safety-related equipment to operate is evaluated based on the analytical limit of the degraded voltage setpoints. That is, the ability of safety-related 480 V motors to start and run, safety-related alternating current MOVs to operate, and low voltage control circuits to remain energized or change state is based on 4160 V essential bus voltages at the proposed minimum allowable values of the degraded voltage relay setpoint.

The licensee provided a copy of the calculation - Undervoltage Relay Setpoints, DC-0919 Volume 1, which provides the calculations for proposed TS values of allowable values and time delay values of degraded voltage relay settings. In this calculation, the licensee stated that voltage settings of degraded voltage relay are calculated such that the maximum possible reset point is within the recovery voltage limits of the voltage analysis. The time settings are calculated such that lower analytical limit is just above the core spray pump acceleration time, and the upper analytical limit of time delay supports the 13 second EDG start time from the LOCA analysis.

The results of the setpoint analysis are used in the transient analysis to verify degraded voltage relay reset values during a LOCA transient and during start of the largest motor during non-LOCA conditions. In Enclosure 7 of the July 23, 2010, letter the licensee provided LOCA voltage transient profiles at 4.16 kV safety-related buses (with minimum grid voltages), with superimposed maximum reset and drop out values of degraded voltage relay. The curves provide verification that degraded voltage relay settings are such that the relays will not trip due to LOCA voltage transients at safety-related buses with minimum switchyard voltages.

Based on review of the response provided by the licensee, the NRC staff considers that the proposed degraded voltage relay settings are acceptable.

(3)

The NRC staff asked if, according to the licensee's letter dated September 16, 2009, the existing ABB 27D relays will be replaced with ABB 27N relays and additional time delay relays added to achieve the LOCA degraded voltage time delay logic. The licensee responded by its letter of July 23, 2010.

The licensee stated that ABB 27N relays will provide a nominal 6.7 seconds delay for degraded voltage with LOCA. In case of non-LOCA, for Division I, the existing Agastat relay will provide 37.3 seconds (nominal) time delay (42 seconds - 6.7 seconds). In case of non-LOCA, for Division II, the existing Agastat relay will provide 14.7 seconds (nominal) time delay (19.4 seconds - 6.7 seconds). In this manner, the need for the additional Agastat time delay relays to provide the LOCA related time delay will be avoided.

The staff reviewed this response and considers it acceptable.

(4)

The NRC staff asked if, according to the licensee's September 16, 2009, letter the loads will be resequenced and the residual heat removal (RHR) pump motor can re-start within a minimum of one second after tripping, in case degraded voltage relay trips within 7.6 seconds to 8.4 seconds of LOCA signal. The licensee was also asked to confirm whether one second will be adequate for the RHR pump motor to decrease its residual

- 7 voltage to less than 25 percent rated voltage (typically considered safe for restarting purposes), and to explain the function of degraded voltage and loss of voltage relaying after the safety-related loads are shifted from offsite source to the EDG.

The licensee clarified that the time delay of 7.6 seconds to 8.4 seconds is now revised as 6.16 to 7.31 seconds. The time period from initiation of the LOCA signal until EDG breaker closure following a load shed can be up to 13 seconds and remain within the accident analysis. The RHR pump motor starts on LOCA signal. Upon load shedding, the motor would be re-sequenced and start within 13 seconds. The licensee stated that per National Electrical Manufacturers Association Standard MG-1-2006, section 21.34.1, reclosing is recommended after a period equal to or greater than 150 percent of the open circuit time constant (in seconds) of the largest motor, which is consistent with a decay below 25 percent residual voltage. Based on this recommendation and open circuit time constant information from the RHR pump motor vendor, the most limiting minimum time delay to allow for residual motor voltage decay is determined to be 4.41 seconds for the 2250-horsepower RHR pump motor. A change to increase the time delay following load shed initiation to provide this delay is included in the planned modification. This is accomplished by adjusting the setting for an existing Agastat time delay relay in the EDG output breaker close control circuit, which is connected in series with load shed relaying.

The licensee also clarified that the degraded voltage and loss of voltage relaying output is blocked after loads are transferred to the respective EDG. The relay output to load shedding relays is reinstated upon closure of the offsite power breaker to the respective essential 4160 V bus and opening of the EDG output breaker for the associated EDG.

The staff reviewed the licensee's response and considers it acceptable.

Based on the above discussion of the licensee's response to the NRC staffs questions, the NRC staff considers the proposed changes to Table 3.3.8.1-1, Function 2, acceptable.

3.1.2 EDG Output Voltage in SRs Currently, the minimum steady state EDG voltage in SRs 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14, and 3.8.1.17 is specified as 3873 V. Since, the upper limit of degraded voltage relay allowable value, for Division I, is now calculated as 3944.8 V based on the revised analysis, the licensee proposed to revise the minimum steady state EDG voltage as 3950 V for these SRs.

The NRC staff agrees that, since the proposed minimum steady state EDG voltage (3950 V) is more than the allowable values of degraded voltage relay settings for both divisions (3944.8 V),

the proposed EDG minimum voltage is considered conservative, and will ensure adequate voltage to the safety-related loads. Thus, the NRC staff considers the proposed changes to EDG output voltage in the SRs 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14, and 3.8.1.17 acceptable.

- 8 3.1.3 Evaluation of Associated Instrumentation The licensee used the General Electric Co. (GE) setpoint methodology in GE Report No. NEDC-31336, "GE Proprietary Information, GE Instrument Setpoint Methodology" which was approved by the NRC staff on November 6, 1995 (Accession No. 9511140068).

The licensee provided Design Calculation DC-0919, dated June 20, 2010, and October 1, 2010, for NRC staff review. The licensee calculated the nominal trip setpoint (NTSP) from an upper analytical limit (UAL) of 3,972.8 V and from a lower analytical limit (LAL) of 3873.0 V.

The licensee calculated the NTSP by subtracting or adding the total loop uncertainties (TLU) from UAL and LAL depending on whether it is an ascending or a descending process, and then selecting the final NTSP to meet both the requirements. The licensee calculated the TLU by taking the algebraic sum of the bias uncertainties with the square root of the sum of the squares (SRSS) of all random independent uncertainties.

The licensee calculated the allowable values (AVs) by adding and subtracting from the NTSP the SRSS of the setting repeatability tolerance provided by the vendor, and the drift based on existing relay data provided by the former relay vendor. The vendor of the new relays did not provide the drift data. The licensee confirmed that it will monitor the drift data in the plant maintenance program.

During a conference call between NRC staff and the licensee, it was noted that the Design Calculation DC-0919, dated June 20,2010 did not show any calculation of AFTs. The licensee had provided clarification in an e-mail dated September 27,2010 (ADAMS Accession No. ML102770115) that AVs were used for AFT values. The NRC staff evaluated the calculation of AV values and found that the licensee was using an extra term in the equation for determination of the AV values. The licensee agreed to revise the calculation to individually calculate the values for AFTs and not use the AVs in place of AFTs. The revised calculation was submitted by licensee in a letter dated October 4, 2010. The NRC staff reviewed the revised calculation and found the revised AFTs to be acceptable.

The licensee calculated the as-left tolerance limit by using the setting repeatability tolerance provided by the vendor.

The licensee also provided part of the plant procedures which indicate that the licensee has adequate procedures for when the as-found values go beyond the AVs or cannot be set within the as-left tolerance bound. The NRC staff finds that these plant procedures comply with the NRC guidance provided in RIS 2006-17.

Based on this evaluation, the NRC staff finds that the proposed TS changes comply with10 CFR 50.36, GDC 13, and GDC 20, and are thus acceptable. The NRC staff also finds that the methodology for calculating the setpoints and the plant procedures conforms with RG 1.105, and RIS 2006-17.

- 9 3.1.4 Summary of Technical Evaluation The NRC staff has reviewed the licensee's proposed changes to Table 3.3.8.1-1, Function 2, and proposed changes to EDG output voltage limits in SRs 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14, and 3.8.1.17. Based on this review as set forth above, the NRC staff concludes that the proposed changes are in compliance with the regulatory requirements set forth in Section 2.0 above. Therefore, the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the proposed amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the use of facility components located within the restricted area as defined in 10 CFR Part 20, and changes surveillance requirements.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued proposed findings that the amendment involves no significant hazards consideration and there has been no public comment on such findings (74 FR 40235 and 75 FR 48373). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Vijay Goel, NRR Subinoy Mazumdar, NRR Date: October 20, 2010

October 20,2010 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166 SUB~IECT:

FERMI 2 - ISSUANCE OF AMENDMENT TO REVISE DEGRADED VOLTAGE FUNCTION TO REFLECT MODIFICATION (TAC NO. ME1477)

Dear Mr. Davis:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 183 to Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment consists of changes to the Technical Specifications in response to your application dated June 10, 2009, supplemented by letters dated September 16, 2009, July 23, 2010, and October 4, 2010.

The amendment revises Table 3.3.8.1-1 to add a new time delay logic associated with Function 2 for degraded voltage concurrent with a loss-of-coolant accident to address issues discussed in NRC Inspection Report 05000341/2008008, dated June 20, 2008. The amendment also revises the maximum and minimum allowable values for the 4160V emergency bus undervoltage for Surveillance Requirements 3.8.1.2, 3.8.1.7, 3.8.1.10, 3.8.1.11, 3.8.1.14, and 3.8.1.17.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRAJ Mahesh L. Chawla, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 183 to NPF-43

2. Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL3-1 RlF RidsRgn3MailCenter Resource RidsOgcRp Resource RidsNrrDirsltsb Resource RidsAcrsAcnw_MailCTR Resource ROrlikowski, Rill RidsNrrDorlLpl3-1 Resource RidsNrrDorlDpr Resource SMazumdar, NRR RidsNrrLABTully Resource RidsNrrPMFenni2 Resource VGoel, NRR MMorris, Rill Amendment Accession Number ML102770382 OFFICE NRRlLPL3-1/PM NRRlLPL3-1/LA EEEB/BC (A)

EICB/BC DIRS/ITSB OGC-NLO w/comments NRRlLPL3-1/BC NAME MChawla BTuily RMathew' WKemper V.Cusumano for RElliott LSubin RPascarelli DATE 10/18/10 10/18/10 919/10' 10113/10 10/14/10 10/15/10 10120/10

• Memo transmitting safety evaluation Input (Accession No. ML102510265).

OFFICIAL RECORD COpy