ML20233A838

Issuance of Amendment No. 216 - Revision to Technical Specification in Response to GE Energy-Nuclear's 10 CFR Part 21 Safety Communication SC05-03

ML20233A838
Person / Time
Site:	Fermi
Issue date:	10/05/2020
From:	Shilpa Arora Plant Licensing Branch III
To:	Peter Dietrich DTE Electric Company
Arora S
References
EPID L-2019-LLA-0200
Download: ML20233A838 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 5, 2020 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. 216 - REVISION TO TECHNICAL SPECIFICATIONS IN RESPONSE TO GE ENERGY-NUCLEARS 10 CFR PART 21 SAFETY COMMUNICATION SC05-03 (EPID L-2019-LLA-200)

Dear Mr. Dietrich:

The U.S. Nuclear Regulatory Commission (NRC) has issued the following enclosed Amendment No. 216 for the Renewed Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment is in response to your application dated September 5, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19248C571).

The amendment revises the Fermi 2 technical specification (TS) 2.1.1, Reactor Core Safety Limits, reactor steam dome pressure from 785 pounds per square inch gauge (psig) to 686 psig and TS Table 3.3.6.1-1, Primary Containment Isolation Instrumentation, Function 1.b, Main Steam Line Pressure - Low, isolation function allowable value from 736 psig to 801 psig. These changes address the GE Energy-Nuclears Title 10 of the Code of Federal Regulations Part 21 Safety Communication SC05-03.

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

Sincerely,

/RA/

Surinder Arora, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 216 to Renewed NPF-43

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI-2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 216 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 (the licensee) dated September 5, 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 The Technical Specifications contained in Appendix A as revised through Amendment No. 216 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Enclosure 1

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Nancy Nancy L. L. Salgado Date: 2020.10.05 Salgado 14:18:21 -04'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-43 and Technical Specifications Date of Issuance: October 5, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 216 FERMI 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DOCKET NO. 50-341 Replace the following page of the Renewed Facility Operating License with the revised page.

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

Remove Insert Page 4 Page 4 Replace the following pages of the 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 2.0-1 2.0-1 3.3-55 3.3-55 3.3-58 3.3-58

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 216, 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. 216

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 686 psig or core flow < 10% rated core flow:

THERMAL POWER shall be 25% RTP.

2.1.1.2 With the reactor steam dome pressure 686 psig and core flow 10% rated core flow:

MCPR shall be 1.08 for two recirculation loop operation or 1.09 for single recirculation loop operation.

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.1 Restore compliance with all SLs; and 2.2.2 Insert all insertable control rods.

FERMI - UNIT 2 2.0-1 Amendment No. 134, 138,164, 216

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 1 of 5)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

1. Main Steam Line Isolation

a. Reactor Vessel Water 1,2,3 2 D SR 3.3.6.1.1 24.8 Level Low Low Low, SR 3.3.6.1.2 inches Level 1 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7

b. Main Steam Line 1 2 E SR 3.3.6.1.1 801 psig Pressure Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4(b)(c)

SR 3.3.6.1.5

c. Main Steam Line Flow 1,2,3 2 per D SR 3.3.6.1.1 118.4 psid High MSL SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7

d. Condenser Pressure 1, 2 D SR 3.3.6.1.1 7.05 psia High SR 3.3.6.1.2 (a) (a) 2 , 3 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

e. Main Steam Tunnel 1,2,3 2 per D SR 3.3.6.1.1 206°F Temperature High trip SR 3.3.6.1.2 string SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

f. Deleted

g. Turbine Building Area 1,2,3 4 D SR 3.3.6.1.1 206°F Temperature High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

h. Manual Initiation 1,2,3 1 per G SR 3.3.6.1.6 NA valve (continued)

(a) Except when bypassed during reactor shutdown or for reactor startup under administrative control.

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual.

FERMI - UNIT 2 3.3-55 Amendment No. 134 189, 212 216

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 4 of 5)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

5. Reactor Water Cleanup (RWCU) System Isolation

a. Differential 1,2,3 1 F SR 3.3.6.1.1 63.4 gpm Flow - High SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Area Temperature - 1,2,3 1 per F SR 3.3.6.1.1 183°F High area SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5

c. Area Ventilation 1,2,3 (e) F SR 3.3.6.1.1 53°F Differential SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.4 SR 3.3.6.1.5

d. SLC System Initiation 1,2 2(d) I SR 3.3.6.1.5 NA

e. Reactor Vessel Water 1,2,3 2 F SR 3.3.6.1.1 103.8 inches Level - Low Low, SR 3.3.6.1.2 Level 2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

f. Manual Initiation 1,2,3 1 per G SR 3.3.6.1.6 NA valve

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1,2,3 1 F SR 3.3.6.1.1 95.5 psig Pressure - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Reactor Vessel Water 3 2 J SR 3.3.6.1.1 171.9 inches Level - Low, Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

c. Manual Initiation 1,2,3 1 per G SR 3.3.6.1.6 NA valve (continued)

(d) SLC System Initiation only inputs into one of the two trip systems.

(e) For Function 5.c, Reactor Water Cleanup (RWCU) System Isolation, Area Ventilation Differential Temperature - High, the required channels is 1 per room.

FERMI - UNIT 2 3.3-58 Amendment No. 134, 173 189, 211 216

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 216 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI-2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated September 5, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19248C571), DTE Electric Company (DTE, the licensee) requested changes to the Technical Specifications (TSs) for Fermi 2. The requested changes would revise the Fermi 2 TSs safety limit (SL) to increase the low pressure isolation setpoint allowable value (AV) which will result in earlier main steam line isolation. The revised main steam line low pressure isolation capability and the revised SL are intended to ensure that Fermi 2 remains within the TSs SLs in the event of a pressure regulator failure maximum demand transient.

The proposed changes address a condition with the potential to momentarily exceed the reactor core SLs during a pressure regulator failure maximum demand (open) (PRFO) transient. This condition was identified by GE Energy-Nuclear (GE) in a March 29, 2005, notification (ADAMS Accession No. ML050950428), to the U.S. Nuclear Regulatory Commission (NRC or Commission) under Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance.

When the steam dome pressure is less than 785 pounds per square inch gauge (psig) or core flow is less than 10 percent of rated core flow, TS 2.1.1.1 currently requires that thermal power shall be less than or equal to 25 percent of rated thermal power (RTP) for Fermi 2. GE, in its 10 CFR Part 21 notification, identified, by using newer computer analysis codes, that a PRFO transient could result in a condition where the reactor steam dome pressure momentarily decreases below 785 psig, while thermal power is above the plant-specific thermal power limit specified in TS 2.1.1.1. This condition would exceed the reactor core SL in TS 2.1.1.1. The proposed changes are to fix the potential of exceeding the low steam dome pressure SL.

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 Proposed Change The licensee has determined that the current main steam line isolation valve low pressure isolation setpoint (LPIS) analytical limit (AL) of 720 psig at Fermi 2 is not sufficient to preclude reactor vessel steam dome pressure from falling below the current 785 psig SL, while thermal power exceeds 25 percent of rated power during a PRFO event. The licensee proposed in the license amendment request (LAR) to reduce the reactor steam dome pressure consistent with the lower-bound pressure of the critical power correlations for the fuel design that currently comprises the Fermi 2 core. The proposed safety limit TS changes are:

Reduce the reactor vessel steam dome pressure limit specified in TS SL 2.1.1.1 from

< 785 psig to < 686 psig.

Reduce the reactor vessel steam dome pressure limit specified in TS SL 2.1.1.2 from 785 psig to > 686 psig.

Fermi limiting condition for operation (LCO) LCO 3.3.6.1 requires the primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 "Primary Containment Isolation Instrumentation" to be OPERABLE in the modes specified in Table 3.3.6.1-1. The licensee proposed to make changes to TS Table 3.3.6.1-1, Function 1.b, Main Steam Line Pressure - Low, by increasing the allowable value (AV) from > 736 psig to > 801 psig.

The TS Table includes surveillance requirements, and Function 1.b requires, among other things, performance of Surveillance Requirement (SR) 3.3.6.1.4, which is a channel calibration.

The proposed amendment would also modify the SR for this function (i.e., main steam line pressure-low) by adding two notes (b) and (c), consistent with the provisions of Technical Specification Task Force (TSTF) 493, Option A) to assess channel performance during surveillance testing to verify instrument channel setting values. Conforming changes (e.g.,

relabeling note (d) as note (e)) are proposed in the "required channels per trip system" column, but not substantive changes are proposed in those conforming changes.

2.2 Applicable Regulatory Requirements and Guidance The regulatory requirements and guidance documents that the NRC staff considered in its review of the LAR are:

Requirements Under 10 CFR 50.92(a), determination on whether to grant an applied-for license amendment is to be guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards for licenses and construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public. The regulation in 10 CFR 50.36, Technical specifications, establishes the requirements related to the content of the TSs. Pursuant to 10 CFR 50.36(c), TSs are required to include items in five specific categories related to station operation: (1) safety limits, limiting safety system settings (LSSS),

and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements;

(4) design features; and (5) administrative controls. The proposed changes in this LAR relate to the safety limit, and surveillance requirement categories.

SLs are defined in 10 CFR 50.36(c)(1)(i)(A) as limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity.

LSSS are defined in 10 CFR 50.36(c)(1)(ii)(A) as settings for automatic protective devices related to those variables having significant safety functions. 10 CFR 50.36(c)(1)(ii)(A) requires, in part, that where a limiting safety system setting (LSSS) is specified for a variable on which an SL has been placed, the setting be so chosen that automatic protective action will correct the abnormal situation before a safety level is exceeded.

Per 10 CFR 50.36(c)(2)(i), limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

Per 10 CFR 50.36(3), 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 for operation will be met.

10 CFR 50, Appendix A, General Design Criteria [GDC] for Nuclear Power Plants describes the minimum requirements for the principal design criteria for water-cooled nuclear power plants. For Fermi 2, Section 3.1, Conformance with General Design Criteria, of the Updated Final Safety Analysis Report (UFSAR) evaluates the plant design basis against the GDC or draft GDC, as appropriate. The UFSAR evaluation concludes that the GDCs of 10 CFR Part 50, Appendix A, have been satisfied in the Fermi 2 design. GDC 10 requires the reactor core and associated coolant, control, and protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences (AOOs).

Guidance Chapter 4, Reactor, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (ADAMS Package Accession No. ML070660036), provides guidance to the NRC staff on the acceptability of the reactivity control systems, reactor core, and fuel system design. Specifically, Section 4.2, Fuel System Design (ADAMS Accession No. ML070740002), specifies the fuel damage criteria to be used in evaluating whether a fuel design meets the specified acceptable fuel design limits. Section 4.4, Thermal and Hydraulic Design (ADAMS Accession No. ML070550060), provides guidance for reviewing thermal-hydraulic design in meeting the requirement of GDC 10 and the fuel design criteria established in Section 4.2. Section 4.4 also states that the critical power ratio (CPR) is to be established such that at least 99.9 percent of fuel rods in the core would not be expected to experience departure from nucleate boiling, or onset of transition boiling, during normal operation or AOOs.

Regulatory Guide (RG) 1.105, Revision 3, Setpoints for Safety-Related Instrumentation (ADAMS Accession No. ML993560062), provides guidance for ensuring that instrument

setpoints are initially within and remain within the TS SLs. This regulatory guide endorses ISA-S67.04-1994, Part I, Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants.

Branch Technical Position 7-12, Guidance on Establishing and Maintaining Instrument Setpoints (ADAMS Accession No ML16019A200), in NUREG-0800, provides guidance to NRC staff for reviewing the process a licensee follows to establish and maintain instrument setpoints.

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 (ADAMS Accession No. ML051810077), discusses issues that could occur during testing of LSSSs and which, therefore, may have an adverse effect on equipment operability. It provides an approach for addressing these issues for use in licensing actions that require prior NRC staff approval. Primarily, the RIS states that verifying that the as-found instrument channel trip point is within appropriately- established acceptance band limits during test or calibration is part of the determination that an instrument is functioning as required. The as-found tolerance band should be established using the following specific conditions: (1) the setting (as-left) tolerance band should be less than or equal to the square root of the sum of the squares of reference accuracy, measurement and test equipment, and readability uncertainties; (2) the setting tolerance (as-left tolerance) should be included in the total loop uncertainty, and (3) the pre-defined test acceptance criteria band for the as-found value includes either, the setting tolerance or the uncertainties associated with the setting tolerance band, but not both of these.

3.0 TECHNICAL EVALUATION

3.1 Reactor 3.1.1 Evaluation Each fuel vendor has developed critical power correlations valid over specified pressure and flow ranges (mass flow rates). These critical power correlations have become increasingly fuel design dependent as advanced fuel designs evolve. The critical power correlations for some advanced fuel designs have received NRC approval, or were developed using NRC-approved methodologies, to a lower pressure than those approved previously. The lower bound of the extended pressure ranges for these advanced fuel designs can be used to justify a lower reactor steam dome pressure than specified in the TSs for previous fuel designs. As such, a wider pressure range would be available for transients to demonstrate compliance with minimum critical power ratio (MCPR) limits.

As stated above, the licensee proposes to reduce the reactor steam dome pressure specified in TS 2.1.1.1 and TS 2.1.1.2 from 785 psig to 686 psig at Fermi 2 based on the lower-bound pressure for the critical power correlation for the fuel currently used in the reactor core for the facility. Also, the AV in TS Table 3.3.6.1-1, Function 1b, Main Steam Line Pressure-Low, is proposed to increase from > 736 psig to > 801 psig.

In its application, the licensee stated that Fermi 2 currently has a full core of GE14 fuel type.

The CPR calculations for GE14 fuel use the critical power correlations known as GEXL14. The

GEXL14 correlation is documented in Global Nuclear Fuel (GNF) Topical Report NEDC-32851P-A, GEXL14 Correlation for GE14 Fuel, Revision 5, dated April 2011 (ADAMS Package Accession No. ML111290540). As discussed in these reports, the GEXL14 correlation is used in the core design process to determine the expected thermal margin for the operating cycle. In the safety analysis process, the correlations are used to determine the change in CPR during postulated transients and to determine the MCPR SL.

The acceptability of the GEXL14 correlation is associated with the NRC-approved GNF Licensing Topical Report (LTR) NEDE-24011-P-A, General Electric Standard Application for Reactor Fuel (referred to as GESTAR II). This LTR provides, in part, generic information relative to the fuel design and analyses of boiling-water reactors that use the GE fuel designs.

This LTR consists of a description of the fuel licensing criteria and fuel thermal-mechanical, nuclear, and thermal-hydraulic analyses bases. In accordance with TS 5.6.5, Core Operating Limits Report (COLR), Fermi 2 may use the analytical methods in versions of GESTAR II that have been previously reviewed and approved by the NRC to determine the core operating limits.

GESTAR II includes a methodology for development of critical power correlations and also contains criteria for when NRC approval of new critical power correlations is needed. The GEXL14 correlation report was approved by the NRC, and a copy of the associated NRC safety evaluation is included with NEDC-32851P-A. Based on this, the NRC staff considers the use of the GEXL14 correlation for GE14 fuel to be acceptable for use in CPR calculations at Fermi 2.

The GEXL14 correlation report discuss the pressure range over which the critical power correlations are valid for the GE14 fuel. As discussed in Section 3.0 of the application, the lower-bound pressure limit for the GEXL14 correlation is 700 psia (700 psia is approximately 685.3 psig). The licensees application proposed to reduce the reactor steam dome pressure specified in Fermi 2 TS 2.1.1.1 and TS 2.1.1.2 to 686 psig. The proposed 686 psig value falls within the pressure range over which the critical power correlations are valid for the GE14 fuel; therefore, the NRC staff determined that the proposed 686 psig limit for TS 2.1.1.1 and TS 2.1.1.2 is acceptable for the fuel in the Fermi 2 core.

Automatic closure of the main steam isolation valves (MSIVs) on low main steam line (MSL) pressure is provided to protect the reactor system against uncontrolled depressurization.

Protection is provided against a pressure regulator malfunction which results in the turbine control and/or bypass valves opening. The MSL low pressure isolation setpoint is specified to limit the duration and severity of the depressurization. The proposed change to the Main Steam Line Pressure-Low Isolation function AV from 736 psig to 801 psig was derived from a revised Main Steam Line Pressure-Low Isolation AL of 785 psig. The revised plant-specific AL was calculated using a methodology that employs the most limiting plant configuration and operating conditions for evaluating the effect of the PRFO transient and a scaling technique.

The new nominal trip setpoint and TS AV are established by estimating the total instrument channel uncertainty and ensuring that the margin between the AL and the setpoints is large enough to accommodate the total channel uncertainty. The NRC staff evaluated the licensees methodology for estimating the total instrument channel uncertainty (see Section 3.2 below) and determined the revised setpoint and AV to be acceptable based on the fact that the new setpoint results in an earlier steam line isolation to terminate depressurization making the transient less severe, while accounting for instrument channel uncertainty. Further, the proposed changes will not alter the PRFO transient to a limiting event.

The revised AV at 801 psig is higher than the current AV of 736 psig and will result in earlier main steam line isolation to terminate a rapid depressurization event. The combination of the lower TS SLs and the higher Main Steam Line Pressure-Low Isolation Setpoint trip setpoint and AV from 736 psig to 801 psig provides a wider pressure range margin for transients, while maintaining compliance with MCPR limits. Thus, the proposed change offers a greater pressure margin in TS 2.1.1.1 for the PRFO transient than what is currently available such that the reactor pressure remains above the proposed low-pressure SL of 686 psig; therefore, the NRC staff finds this acceptable.

3.1.2 Technical Conclusion The proposed TS 2.1.1.1 requires thermal power to be less than or equal to 25 percent RTP when the reactor steam dome pressure is less than 686 psig, or core flow is less than or equal to 10 percent rated core flow. Reducing the reactor vessel steam dome pressure limit specified in TS SLs 2.1.1.1 and 2.1.1.2, in conjunction with increasing the AV and trip setpoint specified in TS Table 3.3.6.1-1, Function 1.b, for the main steam line low pressure isolation, adequately mitigates the PRFO transient event such that the reactor vessel steam dome pressure will remain above the proposed revision to the TS SLs.

The NRC staff further concludes that as long as the core pressure and flow are within the range of validity of the critical power correlation applicable to the current Fermi 2 reactor core, the proposed changes to TS 2.1.1.1 and TS 2.1.1.2 provide reasonable assurance that 99.9 percent of the fuel rods in the core are not expected to experience onset of transition boiling during normal operation or AOOs. As such, the SLs will continue to ensure that specified acceptable fuel design limits are not exceeded during normal operation or AOOs, consistent with the requirements in GDC 10. Furthermore, the staff concludes that the proposed changes establish reactor core SLs reasonably certain to protect the integrity of the fuel cladding barrier and guard against an uncontrolled release of radioactivity, consistent with 10 CFR 50.36(c)(1)(i)(A)(stating "Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down."). Therefore, the NRC staff concludes that the proposed amendments are acceptable.

3.2 Instrumentation 3.2.1 Evaluation As described above, the licensee proposes to reduce the reactor steam dome pressure ALs specified in TS 2.1.1.1 and TS 2.1.1.2 from 785 psig to 686 psig at Fermi 2 based on the lower bound pressure for the critical power correlation for the fuel currently used in the reactor core for the facility.

LCO 3.3.6.1 requires the primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 "Primary Containment Isolation Instrumentation" to be OPERABLE in the modes specified in Table 3.3.6.1-1. Table 3.3.6.1-1 also includes surveillance requirements. In conjunction with this change, the AV in TS Table 3.3.6.1-1, Function 1b, Main Steam Line Pressure-Low Isolation, is proposed to change from 736 psig to 801 psig, and thereby is effecting a change in the LCO. The licensee also proposed changes to the SR for Main Steam Line Pressure-Low via notes and made conforming non-substantive changes to two other entries in Table 3.3.6.1-1. To demonstrate the adequacy of the technical basis for the new AV of 801 psig, the licensee provided the associated setpoint calculation for staff evaluation within

Enclosure 6 of the LAR. The purpose of Fermi 2 Design Calculation DC-4533, Main Steam Line Pressure Surveillance Procedure Validation, is to validate that instruments provided for TS Function 1b, Main Steam Line Pressure-Low, in TS Table 3.3.6.1-1, are adequate with respect to engineering design requirements and surveillance procedure requirements. Specifically, the licensee prepared the calculation to determine with high degree of certainty that there exists an adequate positive margin between the Technical Specifications AV and AL, and between the Nominal Trip Setpoint (NTSP) and AL. The licensees calculation demonstrates that there remains adequate margin to accommodate the existing calculated total instrument channel uncertainty for the AV and NTSP when applying them to the proposed new AV of 801 psig and NTSP of 821 psig. The calculated theoretical AV was found to be 793.6 psig, while the calculated theoretical NTSP was found to be 798 psig. Both of these values are adequate to accommodate the appropriate instrument channel performance uncertainty, and therefore, selections of a new AV of 801 psig and a new NTSP of 821 psig are deemed by the staff to provide adequate margin to accommodate the instrument channel performance uncertainty.

The licensees calculation also evaluates margins for licensee event report (LER) avoidance and spurious trip avoidance associated with the NTSP of 821 psig, finding that there is adequate margin for both. The licensees calculation is based on the licensees setpoint calculation methodology, which is based in part on methodology described in GEH Licensing Topical Reports NEDC-31336P-A, General Electric Instrument Setpoint Methodology, September 1996 and NEDE-33633P-A, GEH Methodology for Implementing TSTF-493 Revision 4, January 2014. The staffs review of this calculation confirms the licensees finding that there is adequate margin for LER avoidance and spurious trip avoidance.

The NRC staff evaluated the instrument channel performance uncertainty within the licensees design calculation using the guidance in RG 1.105, Revision 3, Branch Technical Position 7-12 of Chapter 7 of NUREG-0800, and RIS 2006-17. The methodology includes estimating individual uncertainty terms and combining random, independent terms using the square-root-of-the-sum-of-the-squares method multiplied by a factor representing the number of sample standard deviations needed to identify an uncertainty tolerance interval that contains 95 percent of the uncertainty population at a high confidence level. Systematic, uncertainty bias terms are added algebraically to this software requirement specification (SRSS) combination. This process is consistent with the guidance in Revision 3 of RG 1.105, Revision 3, which identifies ISA-S67.04-1994, Part I, as the endorsed standard.

Within the LAR, the licensee did not propose any changes to the design of the main steam line pressure-low actuation instrumentation. The existing transmitter is capable of being calibrated to the new setpoints, without introducing any additional error. The identification of the individual process parameters used in the setpoint calculation remain unchanged. The principles used in the calculation methodology associated with the current NTSP and AV have not changed. The assumptions, types of errors, error combinations method, and thus the error magnitude remain unchanged. The new NTSP was established to be 821 psig (decreasing) and the new AV was established to be 801 psig (decreasing).

The as-found and as-left tolerances have also been established and documented in the calculation, to support the inclusion of the proposed footnotes to be added to the bottom of TS Table 3.3.6.1-1 in a manner consistent with TSTF-493, Revision 4, Option A, and as described in GEH Licensing Topical Report NEDE-33633P-A, GEH Methodology for Implementing TSTF-493 Revision 4, dated January 2014. In its letter dated November 6, 2013 (ADAMS Accession No. ML13254A042), the NRC staff found that TR NEDE-33633P is acceptable for referencing in licensing applications for nuclear power plants to the extent identified in the staffs

safety evaluation. The proposed footnotes state:

b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual.

3.2.2 Technical Conclusion The NRC staff has reviewed the information provided within the calculation in Enclosure 6 of the LAR, using the regulatory guidance identified above. For the reasons outlined in Section 3.2.1, the staff finds that the calculation results are reasonable and that the staff agrees with the conclusions of the licensee that there is adequate margin to accommodate instrument channel performance uncertainty between the proposed new instrument channel NTSP of 821 psig and the new AL, and adequate margin between the new AV of 801 psig and the AL. Accordingly, the change to the AV in Table 3.3.6.1-1 MSL-low entry will specify the lowest functional capability or performance levels of equipment required for safe operation of the facility and meets 10 CFR 50.36(c)(2)(i). Additionally, the licensee has identified appropriate channel performance acceptance criteria (i.e., As-Found Tolerance and As-Left Tolerance limits) for use when performing instrument channel TS required surveillances and has made correct use of the footnotes to be placed into Table 3.3.1-1 regarding these tolerances. Therefore, the change complies with the requirements of 10 CFR 50.36(c) in that the SR provides reasonable assurance that, with respect to the Main Steam Line Pressure-Low parameter, the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Further, the SR changes are consistent with the guidance in RG 1.105 Revision 3 and RIS 2006-17. Last, the conforming changes to the other parts of Table 3.3.6.1-1 do not make substantive changes to the associated functions associated with reactor water cleanup and standby liquid control.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Michigan State official was notified of the proposed issuance of the amendment on August 12, 2020. The State official had no comments.

5.0 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. 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, and there has been no public comment on such finding

(December 3, 2019; 84 FR 66227). Accordingly, the amendments meet 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 amendments.

6.0 CONCLUSION

The NRC staff 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 Commissions 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: J. Wilson D. Rahn Date of Issuance: October 5, 2020

ML20233A838

• By email OFFICE DORL/LPL3/PM DORL/LPL3/LA* DSS/STSB/BC* DE/EICB/BC* DSS/SNSB/BC*

NAME SArora SRohrer VCusumano MWaters SKrepel DATE 8/ 20 /20 8/ 25 /20 9/ 02 /20 9/ 01 /20 8/ 26 /20 OFFICE OGC - NLO* DORL/LPL3/BC* DORL/LPL3/PM*

NAME DRoth SWall for NSalgado SArora DATE 9/ 23 /20 10/ 02 /20 10/ 05 /20