NRC-17-0066, Supplemental Information Regarding License Amendment Request to Eliminate Main Steam Line Radiation Monitor Reactor Trip and Primary Containment Isolation System Group 1 Isolation Functions

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Supplemental Information Regarding License Amendment Request to Eliminate Main Steam Line Radiation Monitor Reactor Trip and Primary Containment Isolation System Group 1 Isolation Functions
ML17298A185
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/18/2017
From: Polson K
DTE Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-17-0066
Download: ML17298A185 (7)
v • d • e


Text

Keith J. Polson Senior Vice President and CNO DTE Energy Company 6400 N. Dixie Highway, Newport, Ml 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: keith.polson@dteenergy.com

October 18, 2017 NRC-17-0066 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 R~ferences: 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) DTE Electric Letter to NRC, "License Amendment Request to Revise Technical Specifications to Eliminate Main Steam Line Radiation Monitor Reactor Trip and Primary Containment Isolation System Group 1 Isolation Functions," NRC-17-0012, dated August 24, 2017 (MLl 7237Al 76)
3) NRC Letter to DTE, "Fermi 2 Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Revise Technical Specifications to Eliminate Main Steam Line Radiation Monitor Reactor Trip and Primary Containment Isolation System Group 1 Isolation Functions (CAC No. MG0228; EPID L-2017-LLA-0274)," dated October 10, 2017 (MLl 7271A220)

Subject:

USNRC NRC-17-0066 Page2 No new commitments are being made in this submittal.

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

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

Executed on October 18, 2017 Keith J. Polson Senior Vice President and CNO Enclosed CD:

1. Fermi 2 MSLRM License Amendment Request Electronic Data Additional

Enclosures:

1. Supplemental Information for License Amendment Request to Eliminate Main Steam Line Radiation Monitor Reactor Trip and Primary Containment Isolation System Group 1 Isolation Functions 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-17-0066 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information for License Amendment Request to Eliminate Main Steam Line Radiation Monitor Reactor Trip and Primary Containment Isolation System Group 1 Isolation Functions

Enclosure 1 to NRC-17-0066 Page 1 Response to Request for Supplemental Information NRCREQUEST Additional information is needed to review the new set of atmospheric dispersion factors provided in the August 24, 2017, license amendment request (LAR). The atmospheric dispersion factors for accident analysis from the condenser and steam-jet air ejector included in Table 1 of Enclosure 1 to the LAR submittal represent new or different values for the turbine building vent and reactor building exhaust stack release points from those that were reviewed when license amendment 160 was issued in September 28, 2004, "Selective Implementation ofAlternative Radiological Source Term Methodology" (ADAMS Accession No. ML042430179). As discussed in our September 29, 2017, phone call, please provide the following information:

a. The hourly meteorological dataset (in electronic format) used to derive the updated x!Q values in the format specified/or input to the ARCON96 atmospheric dispersion model (i.e.,

Appendix A to RG 1.194).

b. The ARCON96 input and output files used for all source-receptor pairs.
c. A graphic showing the relative locations of the sources and MCR receptors.
d. A table identifying the distance and direction of the source-receptor pairs, as well as the heights of the MCR intakes and release points.

DTE RESPONSE The main steam line radiation monitor (MSLRM) license amendment request identifies two release points in Enclosure 1page18:

(1) Main condenser leakage to the main control room (MCR) is released via theturbine building ventilation stack.

(2) Steam jet air ejector (SJAE) discharge to the MCR is released via the reactor building exhaust stack.

These two release points do not represent new release points, but are release points that have been previously reviewed by the NRC staff in prior license amendments regarding the use of alternate source term (AST) methodology. The turbine building ventilation stack is the same release point as utilized for main steam isolation valve (MSIV) leakage during a loss of coolant accident (LOCA) as

. identified in Table 4 of DTE letter NRC-03-0007 dated February 13, 2003 (ML030520582). The reactor building exhaust stack is the same release point as utilized for the fuel handling accident (FHA) as identified in Table 8 of that same DTE letter. The license amendment request submitted by DTE letter NRC-03-0007 was approved by the NRC as License Amendment 160, dated September 28, 2004 (ML042430179). This information was discussed with the NRC staff on a clarification call on September 29, 2017. The specific information requested by the NRC staff is provided below.

to NRC-17-0066 Page 2

a. The NRC previously approved the Fermi 2 implementation of AST methodology for the FHA in License Amendment 144, dated September 28, 2001 (ML012290521). In support of a request for additional information (RAJ) for License Amendment 144, DTE submitted a compact disc (CD) by DTE letter NRC-01-0036 dated May 2, 2001 (MLOl 1290016), with meteorological data from 1

1995 to 1999 used to calculate xJQ values. In an RAJ for License Amendment 160 (ML03 l 970671 ), the NRC staff stated that the staff had access to the meteorological data from 1995 to 1999 previously submitted for License Amendment 144.

The MSLRM license amendment request referenced this same meteorological data from 1995 to 1999 in Enclosure 1 page 18. The meteorological data used in the analyses for the MSLRM license amendment request has not been changed since that previously provided to the NRC as discussed in License Amendments 144 and 160. To support the NRC staffs review, the meteorological data in Table A is provided on the enclosed CD.

Table A Description File Name 1995 Meteorological Data F1995.met 1996 Meteorological Data F1996.met 1997 Meteorological Data F1997.met 1998 Meteorological Data F1998.met 1999 Meteorological Data F1999.met

b. The MSLRM license amendment request describes the use of the ARCON96 computer code in Enc19sure 1 page 18. ARCON96 computer code input files were previously provided in response to an RAJ for License Amendment 160 submitted by DTE letter NRC-03-0053 dated July 8, 2003 (ML03197Q671). No changes were made to the ARCON96 inputs for the reactor building exhaust cases (note that the MSLRM license amendment request conservatively uses the reactor building exhaust LOCA cases rather than the FHA cases; both cases were provided in NRC-03-0053). Subsequent to License Amendment 160, DTE made modifications to the ARCON96 inputs for the turbine building ventilation stack cases through the Fermi 2 Corrective Action Program to correct physical attributes of the stack. No changes to the inputs were made specifically for the analyses associated with the MSLRM license amendment request. The ARCON96 input and output files listed in Table B are provided on the enclosed CD.

to NRC-17-0066 Page 3 Table B Description File Name Reactor building exhaust stack to north RBVNorth.rsf MCR intake - input file Reactor building exhaust stack to north RBVNorth.log MCR intake - output files RBVNorth.cfd Reactor building exhaust stack to south RBVSouth.rsf MCR intake - input file Reactor building exhaust stack to south RBVSouth.log MCR intake - output files RBVSouth.cfd ;

Turbine building ventilation stack to north TBS- N.rsf MCR intake - input file Turbine building ventilation stack to north TBS_N.log MCR intake - output files TBS N.cfd Turbine building ventilation stack to south TBS- S.rsf MCR intake - input file Turbine building ventilation stack to south TBS_S.log MCR intake - output files TBS S.cfd

c. The relative locations of the sources and MCR receptors are shown in Updated Final Safety Analysis Report (UFSAR) Figure 1.2-19. UFSAR Revision 20 was submitted by DTE letter NRC-16-0034 dated May 26, 2016 (ML16165A441 I ML16165A442). The turbine building ventilation stack is located between column lines N-3 and N-4 (labeled as TBHVAC vent exhaust). The reactor building exhaust stack is located between column lines F-9 and F-10 (labeled as RBHVAC exhaust stack). There are two intakes for the MCR. The north MCR intake is located between column lines G-17 and H-17 (labeled as CCHVAC north). The south MCR intake is located between column lines G-9 and H-9 (labeled as CCHVAC south).
d. The location of the two release points and the two MCR intakes are provided in Table D.1 below.

The X and Y values are based on using reference column N-16 in UFSAR Figure 1.2-19. The Z values are based on a site elevation of 583 ft above sea level as described in UFSAR Section 2.4.1.1. The values in Table D.1 were then used to calculate the ARCON96 inputs for the distance and direction of the source-receptor pairs, as well as the heights of the release points and intakes, as indicated in Table D.2 below. Note that although both the MCR north and south intakes are considered, the MSLRM license amendment request conservatively uses the xfQ values associated with the MCR south intake.

to NRC-17-0066 Page4 Table D.1 Location x (ft) y (ft) z (ft)

Turbine building

-295.25 -11.00 131.5" ventilation stack MCR north intake 25.67 161.33 60.5 MCR south intake 1 -139.75 154.08 96.5 Reactor building

-129.00 202.58 178.0 exhaust stack MCR north intake 25.67 161.33 60.5 MCR south intake2 -137.00 165.33 96.5 1

For the turbine building ventilation stack, the center of the MCR south intake was utilized.

2 For the reactor building exhaust stack, the closest point of the MCR south intake was utilized.

Table D.2 XY Distance Direction Release Intake Pair (m) (degrees)* Height (m) Height (m)

Turbine building ventilation stack to MCR 111.06 170 40.09 18.45 north intake Turbine building ventilation stack to MCR 69.14 152 40.09 29.42 south intake 1 Reactor building exhaust 48.80 214 54.25 18.44 stack to MCR north intake Reactor building exhaust 11.60 301 54.25 29.42 stack to MCR south intake

  • The direction includes a correction for plant north vs. true north of approximately 19 degrees as described in DTE letter NRC-01-0036.
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