NRC-17-0063, License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities.

License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities.

ML17283A248
Person / Time
Site:	Fermi
Issue date:	10/09/2017
From:	Polson K DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-17-0063
Download: ML17283A248 (16)

Text

Keith J. Polson Senior Vice President and CNO DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: keith.polson@dteenergy.com October 9, 2017 10 CFR 50.90 NRC-17-0063 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

References:

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

Subject:

License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR 50.90), DTE Electric Company (DTE) is submitting a request for an amendment to technical specifications (TS) for Fermi Unit 2 (i.e. Appendix A, Technical Specifications of Renewed Facility Operating License NPF-43).

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities. The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides the proposed TS changes in final typed format (i.e. clean TS pages). Enclosure 4 provides the existing TS Bases pages marked up to show the proposed change. Enclosure 4 is provided for information only.

DTE requests approval of the proposed license amendment by August 31, 2018, to support the next refueling outage, with the amendment being implemented within 60 days.

USNRC NRC-17-0063 Page 2 In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan State Official.

Should you have any questions or require additional information, please contact Mr. ScottA. Maglio, Manager - Nuclear Licensing at (734) 586-5076.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 9, 2017 Keith J. Polson Senior Vice President and CNO

Enclosures:

1. Evaluation of Proposed Change

2. Proposed Technical Specification Change (Mark-Up)

3. Proposed Technical Specification Change (Re-Typed)

4. Proposed Technical Specification Bases Change (Mark-up) cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-17-0063 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Evaluation of Proposed Change to NRC-17-0063 Page 1 Contents 1.0 Description 2.0 Proposed Change 3.0 Background 4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Determination 5.2 Applicable Regulatory Requirements / Criteria 6.0 Environmental Consideration 7.0 References to NRC-17-0063 Page 2

1.0 DESCRIPTION

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 200°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities. The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, Inservice Leak and Hydrostatic Testing Operation. Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

This application is being made in accordance with the CLIIP. DTE Electric Company (DTE) is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the NRC staffs model safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

4.0 TECHNICAL ANALYSIS

DTE has reviewed the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. DTE has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Fermi Unit 2 and therefore justify this amendment for the incorporation of the proposed changes to the Fermi Unit 2 TS.

The technical justification presented in the SE prepared by the NRC staff discusses the TS requirement for two low-pressure Emergency Core Cooling System (ECCS) injection / spray subsystems to be operable in Mode 4. This requirement is consistent with the current Fermi 2 TS 3.5.2. Note that DTE has submitted a license amendment request to adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, which modifies the number of subsystems required to to NRC-17-0063 Page 3 be operable in Mode 4 for TS 3.5.2. This pending change, which is technically justified in TSTF-542, does not impact the conclusions of the SE dated October 27, 2006.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Determination DTE Electric Company (DTE) has reviewed the no significant hazards determination published on August 21, 2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. DTE has concluded that the determination presented in the notice is applicable to Fermi Unit 2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 Applicable Regulatory Requirements / Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

6.0 ENVIRONMENTAL CONSIDERATION

DTE has reviewed the environmental evaluation included in the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. DTE has concluded that the staffs findings presented in that evaluation are applicable to Fermi Unit 2 and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1. Federal Register Notice, Notice of Availability published on October 27, 2006 (71 FR 63050).

2. Federal Register Notice, Notice for Comment published on August 21, 2006 (71 FR 48561)

3. TSTF-484 Revision 0, Use of TS 3.10.1 for Scram Times Testing Activities

Enclosure 2 to NRC-17-0063 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Proposed Technical Specification Change (Mark-Up)

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System Cold Shutdown," may be suspended to allow reactor coolant temperature > 200°F,:

For to allow performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 200F.

FERMI - UNIT 2 3.10-1 Amendment No. 134

Enclosure 3 to NRC-17-0063 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Proposed Technical Specification Change (Re-Typed)

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System Cold Shutdown," may be suspended to allow reactor coolant temperature > 200°F:

For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 200F.

FERMI - UNIT 2 3.10-1 Amendment No. 134

Enclosure 4 to NRC-17-0063 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of TSTF-484, Rev. 0, Use of TS 3.10.1 for Scram Time Testing Activities Proposed Technical Specification Bases Change (Mark-Up)

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 200F (normally corresponding to MODE 3) or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures

> 200°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 200°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod WithdrawalCold Shutdown," during MODE 4 operation.

Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.10, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure.

Periodic updates to the RPV P/T limit curves are performed as necessary, based upon the results of analyses of representative irradiated surveillance specimens as part of the BWR Vessel and Internals Project (BWRVIP) Integrated Surveillance Program (Ref. 3). Hydrostatic and leak testing may eventually be desired required with minimum reactor coolant temperatures > 200F. However, even with required minimum reactor coolant temperatures 200°F, maintaining RCS temperatures within a small band during the test can FERMI - UNIT 2 B 3.10.1-1 Revision 17

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES BACKGROUND (continued) be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

The Inservice hydrostatic and RCS system leakage pressure tests require increasing pressure to greater than normal reactor operating pressure without exceeding the Safety Limit of 1375 psig approximately 1050 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures 800 psig.

Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

APPLICABLE Allowing the reactor to be considered in MODE 4 during SAFETY ANALYSES hydrostatic or leak testing, when the reactor coolant temperature is > 200F, during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 requirements, including exceptions to OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems. Since the hydrostatic or leak tests are performed nearly water solid, at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in coolant activity above the LCO 3.4.7, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

FERMI - UNIT 2 B 3.10.1-2 Revision 72

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE SAFETY ANALYSES (continued)

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 200F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures

> 200F, while the ASME inservice test itself requires the safety/relief valves to be gagged, preventing their OPERABILITY. Additionally, even with required minimum reactor coolant temperatures 200°F, RCS temperatures may drift above 200°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak or hydrostatic testing.

While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

FERMI - UNIT 2 B 3.10.1-3 Revision 26

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO (continued)

If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. Additionally, all control rods will remain fully inserted when >200F, while using this Special Operations LCO. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures

> 200F for the purpose of performing either an inservice leak or hydrostatic test, and for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements that are in effect immediately prior to and immediately after this operation.

APPLICABILITY The MODE 4 requirements may only be modified for the performance of, or as a consequence of, inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, so that these operations can be considered as in MODE 4, even though the reactor coolant temperature is > 200F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate FERMI - UNIT 2 B 3.10.1-4 Revision 0

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS (continued) compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

A.1 If an LCO specified in LCO 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with. Required Action A.1 has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to 200F.

A.2.1 and A.2.2 Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.1 to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to 200F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LCO 3.0.3 to reach MODE 4 from MODE 3.

SURVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LCO is being met.

A discussion of the applicable SRs is provided in their respective Bases.

REFERENCES 1. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.

2. UFSAR, Section 15.6.4.

3. BWRVIP-86-A, October 2002 FERMI - UNIT 2 B 3.10.1-5 Revision 17