ML12333A327

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Issuance of Amendment for Revising the Residual Heat Suppression Pool Cooling Flow Rate in Technical Specification Surveillance Requirement 3.6.2.3.2
ML12333A327
Person / Time
Site: Fermi 
(NPF-043)
Issue date: 12/21/2012
From: Mahesh Chawla
Plant Licensing Branch III
To: Plona J
Detroit Edison, Co
Chawla M NRR/DORL/LPL3-1 301-415-8371
References
TAC ME7828
Download: ML12333A327 (12)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 21, 2012 Mr. Joseph H. Plona Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT FOR REVISING THE RESIDUAL HEAT SUPPRESSION POOL COOLING FLOW RATE IN TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.6.2.3.2 (TAC NO. ME7828)

Dear Mr. Plona:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 191 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 January 10, 2012.

The amendment revises Technical Specification (TS) 3.6.2.3, "RHR [Residual Heat Removal]

Suppression Pool Cooling," to specify a new minimum developed RHR pump flow rate in Surveillance Requirement (SR) 3.6.2.3.2. This change brings the flow required in the plant design basis in alignment with the TS SR. The change would increase the operating margin of the RHR Suppression Pool Cooling system to the SR. Also, this change would clarify that SR 3.6.2.3.2 applies to only the RHR pumps required to meet Limiting Condition of Operation 3.6.2.3.

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,

~mL-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. 191 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. 191 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 (DECo, the licensee) dated January 10, 2012, 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. 191, 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 within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Robert D. Carlson, 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: December 21, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 191 FACILITY OPERATING LICENSE NO. NPF-43 DOCKET NO. 50-341 Replace the following pages,of the Facility Operating License and 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 License Page 3 License Page 3 Page 3.6-34 Page 3.6-34

- 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 No. 191 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. 191

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling subsystem manual. power operated. and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

31 days SR 3.6.2.3.2 Verify each required RHR pump develops a flow rate ~ 9,250 gpm through the associ ated heat exchanger wh'j 1e operati ng in the suppression pool cooling mode.

In accordance with the Inservice Testing Program FERMI - UNIT 2 3.6-34 Amendment No. lJ4 191

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 191 TO FACILITY OPERATING LICENSE NO. NPF-43 DETROIT EDISON COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

In a letter dated January 10, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML120110145), Detroit Edison requested a license amendment to the operating license for Fermi 2 in the form of changes to the Technical Specifications (TSs).

Detroit Edison's proposed amendment revises TS 3.6.2.3, "RHR [Residual Heat Removal]

Suppression Pool Cooling," to specify a new minimum developed RHR pump flow rate in Surveillance Requirement (SR) 3.6.2.3.2. The proposed change brings the flow required in the plant design basis in alignment with the TS SR. The change would increase the operating margin of the RHR Suppression Pool Cooling system to the SR. Also, the proposed change would clarify that SR 3.6.2.3.2 applies to only the RHR pumps required to meet Limiting Condition of Operation (LCO) 3.6.2.3. There are two RHR pumps in each of the two RHR Suppression Pool Cooling Subsystems.

1.1 Proposed Changes TS SR Section 3.6.2.3.2 currently requires that the flow rate developed by each RHR pump through the associated heat exchanger be greater than or equal to 10,000 gallons per minute (gpm) in Suppression Pool Cooling mode. The proposed change would require greater than or equal to 9,250 to be the SR flow.

The wording in TS SR 3.6.2.3.2 is currently "Verify each RHR pump develops a flow... ", the proposed change would have the wording be "Verify each required RHR pump develops a flow... ". This change would allow the SR to be met if one pump in each of the two subsystems were operable.

1.2 Precedent There are several Boiling Water Reactors (BWRs) that have wording in TS SR 3.6.2.3.2 that includes "each required RHR pump." These plants include Fitzpatrick, Dresden, Hatch, LaSalle, Monticello, Nine Mile Point, Peach Bottom, and Quad Cities.

Enclosure

- 2

2.0 REGULATORY EVALUATION

The Commission's regulatory requirements related to the contents of TS, set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, require that the TS limiting conditions for operations are consistent with assumed values of the initial conditions in the licensee's safety analyses. 10 CFR 50.36( c)(2)(i) states: "limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

10 CFR 50 Appendix A, General Design Criterion 38, "Containment Heat Removal."

A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

3.0 TECHNICAL EVALUATION

The pressure suppression chamber is a steel pressure vessel, in the shape of a torus, below and encircling the drywell. It has a major diameter of 112 ft 6 in and a cross-sectional diameter of 30 ft 6 in. It contains a total volume of approximately 251,980 ft3. The suppression chamber is supported vertically by inside and outside columns and by a saddle support that spans the inside and outside columns. The support system transmits dead weight and seismic and hydrodynamic loading to the reinforced-concrete foundation slab of the reactor building. Space is provided outside the chamber for inspection and maintenance. The pressure suppression chamber is designed for a temperature of 281°F and a pressure of 56 pounds per square inch gauge (psig).

After a design-basis accident (DBA), the RHR Suppression Pool Cooling System removes heat from the suppression pool. The suppression pool absorbs the initial heat load from the primary system. The core continues to generate residual and decay heat after the initial heat load and it is also cooled by the suppression pool. The pool must eventually be cooled so that it stays within its design limits. The RHR Suppression Pool Cooling system allows for this heat removal.

The TS SR 3.6.2.3.2 ensures the RHR suppression pool cooling system is able to meet its design-basis requirements to protect the suppression pool and containment.

The suppression pool cooling subsystem cools the suppression pool by using the RHR pumps and heat exchangers in a closed loop with the suppression pool. The suppression pool cooling subsystem is put into operation to limit the water temperature immediately after a blowdown to 170 OF when reactor pressure is above 135 psig. During this mode of operation, water is pumped from the suppression pool through the RHR system heat exchanger and back to the suppression pool. There are two redundant RHR suppression pool cooling subsystems that

- 3 include two RHR pumps and a heat exchanger in each. The heat exchangers are cooled by the RHR Service Water system which is cooled by the ultimate heat sink.

The licensee analyzed post DBA-loss of coolant accident (LOCA) long term suppression pool temperature response using General Electric-Hitachi SHEX model. The analysis showed a peak post DBA-LOCA suppression pool temperature of 196.5 of. The limit is a temperature of 198 oF. The RHR suppression pool cooling system is modeled with a K-factor as well as the difference between the inlet temperatures of the RHR and the RHR service water systems.

One RHR pump in one subsystem of the RHR suppression pool cooling system is capable of meeting the overall post-accident suppression pool cooling requirements. As such, one subsystem is capable of performing its design-basis requirement with one pump operable.

Redundancy is maintained as the other subsystem would also be capable of performing the design-basis required flow rate with one of its two pumps operable. Considering this and the precedence established for other BWRs, the NRC staff finds the proposed change to add the word "required" to TS 3.6.2.3 to be acceptable.

The licensee tests each of the two RHR heat exchangers every other refueling outage while operating in RHR system shutdown cooling mode. The licensee measures heat exchanger inlet and outlet fluid temperatures and flows and use the results to determine the heat exchanger performance or fouling factor. This is based upon standard heat exchanger modeling methods.

The fouling factor is used to determine that the heat exchanger meets the minimum required thermal performance needed to satisfy the containment cooling safety analysis. The fouling factors are a function of the nature of the fluids, the temperatures involved, and the fluid velocities. The heat exchanger designer includes the fouling factor in calculating the overall thermal resistance and provides sufficient surface area to allow the required heat transfer rate while in the fouled condition. The current RHR heat exchanger thermal performance is extrapolated to use 9,250 gpm on the shell side of the heat exchanger, which is the RHR suppression pool cooling system flow rate used in analysis. Using the lower flow rate requires the licensee to maintain stricter fouling factors in the heat exchanger to maintain performance that meets the DBA analysis requirement to cool the suppression pool. The license amendment changes the TS SR flow rate from 10,000 gpm to 9,250 gpm to reduce the margin to the assumed flow rate.

The licensee stated that the Suppression Pool Cooling system return lines were deSigned to deliver approximately 10,000 gpm of flow. This combined with a corrective action that found that the flow rated indicated during surveillance tests was biased upwards 200 gpm has the licensee operating with little margin to the TS SR flow rates. The licensee stated that typical recorded flow results for the TS SR 3.6.2.3.2 are near the required value. The request for the license amendment puts the TS SR in line with the analyzed condition so that the operating conditions do not challenge operability of the system under the TS without need.

The licensee's acceptance criteria for the TS SR include corrections for allowable pump degradation, EDG frequency tolerance, test instrument accuracy, and temperature-flow bias.

The licensee currently uses 9,250 gpm to verify the heat exchanger performance. The licensee has shown that conservatisms would still exist in the analysis of the RHR suppression pool cooling system performance if the TS SR flow rate is reduced to 9,250 gpm.

-4 The NRC staff has reviewed the request to lower the TS SR 3.6.2.3.2 flow rate from 10,000 gpm to 9,250 gpm. Given the conservatisms that exist and the additional margin in the DBA analysis for the RHR suppression pool cooling system, the staff finds the proposed change to be acceptable.

The NRC staff has reviewed the proposed amendment to TS SR 3.6.2.3 and found the proposed change to maintain operability and satisfy the design-basis requirements of the RHR suppression pool cooling system.

4.0

SUMMARY

The Reactor Systems Branch (SRXB) staff has reviewed the proposed TS changes to SR 3.6.2.3.2 regarding decreasing the required minimum developed RHR Suppression Pool Cooling flow rate as well as the change to the wording of the SR to "each required RHR pump."

The staff finds that revising the flow rate to 9250 gpm meets the design criteria for the RHR Suppression Pool Cooling system and is still conservative and therefore finds the change to be acceptable. The staff found that adding the word "required" to TS SR 3.6.2.3.2 had precedent.

The LCO states that the subsystems must be operable. One pump in each subsystem provides the full flow required by the design basis. Two subsystems being operable provides redundancy. The staff finds the change acceptable. Therefore, the U.S. Nuclear Regulatory Commission (NRC) staff has concluded that the proposed TS changes are acceptable.

Furthermore, the NRC staff finds that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in this manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 STATE CONSULTATION

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

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or change the surveillance requirements. The 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 a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (77 FR 25755). 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.

-5

7.0 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) there is reasonable assurance that 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 Contributor: Joshua Miller Date: December 21, 2012

December 21,2012 Mr. Joseph H. Plona Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT FOR REVISING THE RESIDUAL HEAT SUPPRESSION POOL COOLING FLOW RATE IN TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.6.2.3.2 (TAC NO. ME7828)

Dear Mr. Plona:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 191 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 January 10, 2012.

The amendment revises Technical Specification (TS) 3.6.2.3, "RHR [Residual Heat Removal]

Suppression Pool Cooling," to specify a new minimum developed RHR pump flow rate in Surveillance Requirement (SR) 3.6.2.3.2. This change brings the flow required in the plant design basis in alignment with the TS SR. The change would increase the operating margin of the RHR Suppression Pool Cooling system to the SR. Also, this change would clarify that SR 3.6.2.3.2 applies to only the RHR pumps required to meet Limiting Condition of Operation 3.6.2.3.

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. 191 to NPF-43
2. Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:

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