ML19288A073
| ML19288A073 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/18/2019 |
| From: | Sujata Goetz, Booma Venkataraman Plant Licensing Branch III |
| To: | Peter Dietrich DTE Electric Company |
| Goetz S, 415-8004 | |
| References | |
| EPID L-2019-LLA-0041 | |
| Download: ML19288A073 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 18, 2019 Mr. Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 260 TAC 6400 North Dixie Highway Newport, MI 48166
SUBJECT:
FERMI 2 - ISSUANCE OF AMENDMENT NO. 215 RE: REVISION TO TECHNICAL SPECIFICATION 3.3.5.3 (EPID: L-2019-LLA-0041)
Dear Mr. Dietrich:
By "NRC-19-0001, License Amendment Request to Revise Technical Specification 3.3.5.3, Reactor Pressure Vessel (RPV) [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Instrumentation|letter dated February 27, 2019]], and supplemented by letter dated June 18, 2019, DTE Energy Company (DTE, the licensee) proposed to revise technical specifications (TSs) for Fermi 2. The proposed amendment modifies surveillance requirements for TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation," to allow for delayed entry into the associated conditions and required actions when a channel is inoperable due to testing.
A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Docket Nos.
50-341
Enclosures:
- 1. Amendment No. 215 to NPF-43
- 2. Safety Evaluation cc: Listserv Sincerely, Booma Venkataraman, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 215 Renewed License No. NPF-43
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by DTE Electric Company (DTE, the licensee),
dated February 27, 2019, and supplemented by letter dated June 18, 2019, 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 Renewed 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. 215, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 45 days.
Attachment:
Changes to the Renewed Facility Operating License No. NPF-43 and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION
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Nancy L. Salgado, Branch Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:
December 1 8, 2 O 1 9
ATTACHMENT TO LICENSE AMENDMENT NO. 215 RENEWED FACILITY OPERATING LICENSE NO. NPF-43 FERMI 2 DOCKET NO. 50-341 Replace the following pages of the Renewed Facility Operating License No. NPF-43 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.
Renewed Facility Operating License No. NPF 43 REMOVE INSERT TECHNICAL SPECIFICATIONS REMOVE 3.3-49b INSERT 3.3-49b (2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 215, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Antitrust Conditions DTE Electric Company 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 DTE Electric Company and Consumers Power Company as specified in a letter from The Detroit Edison Company to the Director of Regulation, dated August 13, 1971, and the letter from Richard W. McLaren, Assistant Attorney General, Antitrust Division, U.S. Department of Justice, to Bertram H. Schur, Associate General Counsel, Atomic Energy Commission, dated August 16, 1971.
(4)
Deleted (5)
Deleted (6)
Deleted (7)
Deleted (8)
Deleted (9)
Modifications for Fire Protection {Section 9.5.1, SSER #5 and SSER #6)*
DTE Electric Company shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report for the facility through Amendment 60 and as approved in the SER through Supplement No. 5, subject to the following provision:
(a) DTE Electric Company may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
- The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.
Renewed License No. NPF-43 Amendment No. 215
ACTIONS (continued)
CONDITION D. As required by Required Action A.1 and referenced in Table 3.3.5.3*1.
OR Required Action and associated Completion Time of Condition C not met.
SURVEILLANCE REQUIREMENTS D.1 RPV Water Inventory Control Instrumentation 3.3.5.3 REQUIRED ACTION COMPLETION TIME Declare associated Immediately low pressure ECCS injection/spray subsystem inoperable.
NOTES ------------------------------------
- 1. Refer to Table 3.3.5.3-1 to determine which SRs apply for each ECCS Function.
- 2. When a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions l.a and 2.a.
provided the associated Function maintains ECCS initiation capability.
SURVEILLANCE SR 3.3.5.3.1 Perform CHANNEL CHECK.
SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.
SR 3.3.5.3.3 Perform CHANNEL FUNCTIONAL TEST.
FERMI - UNIT 2 3.3-49b FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. :?1-1, 215
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 215 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341
1.0 INTRODUCTION
By "NRC-19-0001, License Amendment Request to Revise Technical Specification 3.3.5.3, Reactor Pressure Vessel (RPV) [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Instrumentation|letter dated February 27, 2019]] (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19058A251 ) and as supplemented by letter dated June 18, 2019 (ADAMS Accession No. ML19169A070), DTE Energy Company (DTE, the licensee) proposed to revise technical specifications (TSs) for Fermi 2. The proposed amendment would modify surveillance requirements (SRs) for TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation," to allow for delayed entry into the associated conditions and required actions when a channel is inoperable due to testing, provided the associated Function maintains Emergency Core Cooling System (ECCS) initiation capability.
This license amendment request (LAR) is related to Fermi 2 Amendment 211, issued on September 17, 2018 (ADAMS Accession ML18247A452), adopting Technical Specifications Task Force (TSTF) Traveler TSTF-542, "Reactor Pressure Vessel Water Inventory Control,"
Revision 2 (ADAMS Accession ML16343B008). The TSTF-542 replaced TSs related to operations with a potential for draining the reactor vessel with new requirements on reactor pressure vessel (RPV) water inventory control to protect Safety Limit 2.1.1.3, which requires RPV water level to be greater than the top of the active irradiated fuel.
2.0 REGULATORY EVALUATION
2.1 System Design and Operation The RPV contains penetrations below the top of the active fuel (T AF) that have the potential to drain the reactor coolant inventory to below the fuel. If the water level drops below the TAF, decay heat removal is reduced which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures. TS 3.3.5.3 requires RPV water inventory control to be available in Modes 4 and 5 in order to protect Safety Limit 2.1.1.3 and the fuel cladding barrier, so as to prevent the release of radioactive material should a draining event occur. Amendment 211 consolidated the requirements necessary to maintain RPV water level above TAF into TS Section 1.1, "Definitions", "DRAIN TIME,"
TS 3.3.5.3, TS 3.5.2, RPV water inventory control.
The purpose of the TS 3.3.5.3 is to support the low-pressure emergency core cooling system (ECCS) requirements of limiting condition for operation (LCO) 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control," and the definition of DRAIN TIME. TS Table 3.3.5.3-1 contains the instrumentation Functions required to be OPERABLE in support of RPV water inventory control during Modes 4 and 5 activities.
Functions 1.a and 2.a of TS Table 3.3.5.3-1 contain requirements for "Reactor Steam Dome Pressure - Low (injection permissive)" for core spray (CS) and low-pressure coolant injection (LPCI), respectively. These functions are used as permissives for the low-pressure ECCS subsystems' injection functions. They ensure that prior to opening the injection valves of the low-pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is typical during Modes 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low (Injection Permissive) signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.
The Reactor Steam Dome Pressure - Low (Injection Permissive) signals are initiated from four pressure transmitters that sense the reactor steam dome pressure. The transmitters are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic. All four channels are required to be OPERABLE in Modes 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.
2.2 Proposed Change The licensee proposed to add a Note in TS 3.3.5.3, Under "SURVEILLANCE REQUIREMENTS" that applies to the SRs stating:
When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1.a and 2.a, provided the associated Function maintains ECCS initiation capability.
DTE stated in the LAR that the note would be applicable to TS Table 3.3.5.3-1, Functions 1.a and 2.a, similar to how it is applied in TS Table 3.3.5.1-1 for Modes 1 through 3. Prior to the Fermi 2 TSTF-542 amendment, TS 3.3.5.1 SR Note 2(b) applied to Modes 1 through 5.
2.3 Applicable Regulations to Instrumentation Systems The regulation in Title 10 of the Code of Federal Regulations (10 CFR), section 50.36(c)(2),
states that the Limiting Conditions for Operation (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of a facility. The regulation further requires that, when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the condition can be met.
10 CFR50.36(c)(3) states that surveillance requirements SRs 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 LCOs will be met.
The proposed note described above would modify the SRs in a manner which would not require performance of remedial actions (entering associated actions and conditions) for up to six hours when the LCO is not met due to SR performance.
2.4 Applicable Design Criteria Per Fermi 2's Updated Final Safety Analysis Report, Revision 22 (ADAMS Accession No. ML19128A108), Section 3.1, the Fermi 2 principal design criteria comply with the current General Design Criteria (GDC) located in Appendix A to 10 CFR Part 50. The U.S. Nuclear Regulatory Commission (NRC or Commission) staff used GDC 13 for this evaluation, which states that instrumentation shall be provided to monitor variables and systems over their antidpated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.
3.0 TECHNICAL EVALUATION
Prior to Fermi 2's TSTF-542 license amendment, SR Note 2(b) in LCO 3.3.5.1 contained a similar allowance for the Reactor Steam Dome Pressure-Low functions that included the Mode 4 and 5 requirements, now located in TS 3.3.5.3. TSTF-542 did not include the note in TS 3.3.5.3. DTE proposed to add a note that would apply to SRs in TS 3.3.5.3, which allows a delay to enter an Action statement for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> while performing a required surveillance test. The note would apply to all SRs required for Reactor Steam Dome Pressure-Low function.
During performance of a test a channel will be unable to perform its function and, therefore, be inoperable. The proposed note would require the remaining channels to perform the safety function to use the 6-hour allowance. DTE stated in the LAR that restoring the SR Note for TS 3.3.5.3 is consistent with the requirements prior to the TSTF-542 license amendment.
Furthermore, DTE described how the injection permissive function is maintained during testing without placing the inoperable channel in trip (as is currently required in Fermi 2 TS 3.3.5.3 Condition C) in a supplemental letter dated June 18, 2019. Regarding both reactor steam dome pressure injection permissive Functions, 1.a (CS) and 2.a (LPCI), the licensee explained:
... the injection permissive Function can be maintained with only two OPERABLE channels, provided the two OPERABLE channels are in one division. Note that injection permissive Function is assured with three total OPERABLE channels, regardless of which division the channels are in.
In this configuration, where two channels in one division are OPERABLE, the injection permissive Function is maintained to both divisions of both CS and LPCI systems. lnoperability of the other two channels in the opposite division would not prohibit the injection permissive Function.
Maintaining two channels for each division and two divisions (i.e. four total channels as indicated in TS Table 3.3.5.3-1) provides capability for the CS and LPCI systems to accommodate single failures.
In the case of surveillance testing, only a single instrumentation channel is made inoperable by the test. The remaining three channels are OPERABLE, including two channels in one of the divisions. Since two channels in one division are assured to be OPERABLE, the Function is assured to be maintained. In this testing configuration, there are certain single failures, but not all, which would prevent the Function. Therefore, the surveillance testing configuration ensures the Function is maintained, but is at a small increased risk of preventing the Function (due to single failure) relative to the configuration where all four channels are OPERABLE in accordance with TS Table 3.3.5.1-1.
The NRC staff reviewed the licensee's supplemental response and finds that the proposed SR Note in TS 3.3.5.3 would only allow delay of entry into an action statement during channel testing as long as the injection permissive is capable of performing its function, i.e., there are at least two operable channels in one division. Conversely, if there are insufficient channels for this configuration, rendering the injection permissive function incapable of meeting its function, then Fermi 2 TS Table 3.3.5.3-1 directs entry into Condition C which requires placing the inoperable channels in trip within one hour.
The NRC staff reviewed DTE's LAR and supplemental letter which proposed to add an SR Note allowing delayed entry into an action statement during SR performance. The note would apply to the Reactor Steam Dome Pressure - Low injection permissive for CS (Function 1.a) and LPCI (Function 2.a) TS Table 3.3.5.3-1, RPV Water Inventory Control Instrumentation. The NRC staff determined that the proposed note has similar requirements for the injection permissive that were applicable to Modes 1 through 5, prior to adoption of TSTF-542 which did not transfer the allowance to TS 3.3.5.3. Currently, the note applies only to Modes 1 through 3 in TS 3.3.5.1: The NRC staff concludes that restoring the SR Note allowance for Modes 4 and 5 operations in TS 3.3.5.3 is acceptable because the Fermi 2 design will continue to meet GDC 13, which requires in part, that instrumentation shall be provided for accident conditions as appropriate to assure adequate safety. The NRC staff determined the proposed SR Note is in compliance with GDC 13 because it requires that the injection permissive instrumentation is capable (due to the operability of the channels not under test) of supporting operability of a low pressure ECCS subsystem per TS 3.5.2. The NRC staff finds that the proposed change also meets 10 CFR 50.36(c)(2) because it allows a temporary relaxation to perform required SR testing if the required function in support of LCO 3.3.5.3 is met.
4.0 TECHNICAL CONCLUSION The NRC staff determined the proposed SR Note is in compliance with GDC 13 because it requires that the injection permissive instrumentation is capable (due to the operability of the channels not under test) of supporting operability of a low-pressure ECCS subsystem per TS 3.5.2. The NRC staff finds that the proposed change also meets 10 CFR 50.36(c)(2) because it allows a temporary relaxation to perform required SR testing of the required function in support of LCO 3.3.5.3.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified on June 13, 2019, 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 installation or use of a facility component 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 a proposed finding that the amendment involves no significant hazards consideration on June 4, 2019 (84 FR 25835), and there has been no public comment on such finding. 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.
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: K. N. West, NRR Date of issuance:
December 1 8, 2 O 1 9
SUBJECT:
FERMI 2-ISSUANCE OF AMENDMENT NO. 215 RE: REVISION TO TECHNICAL SPECIFICATION 3.3.5.3 (EPID: L-2019-LLA-0041) DATED DECEMBER 18, 2019 DISTRIBUTION:
PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNrrDSS Resource RidsNrrDorllpl3 Resource RidsNrrDssSnsb Resource RidsNrrDssStsb Resource RidsNrrDexEicb Resource RidsNrrPMFermi2 Resource RidsNrrLASRohrer Resource RidsRgn3MailCenter Resource ADAMS A ccess1on N ML19288A073 o.:
OFFICE NRR/DORL/LPL3/PM N RR/DORL/LPL3/LA NRR/DSS/SNSB NAME SGoetz SRohrer JBorromeo*
DATE 10/3/19 10/2/19 10/25/19 OFFICE NRR/DEX/EICB*
OGC-NLO*
NRR/DORL/LPL3/BC NAME MWaters STurk NSalgado (SWall for)
DATE 8/15/19 11/26/19 12/18/19 OFFICIAL RECORD COPY
- B
- 1
,ve-ma1 NRR/DSS/STSB/
VCusumano*
10/24/19 NRR/DORL/LPL3/PM BVenkataraman 12/18/19