Text

Issuance of Amendment No. 218, Revision to Technical Specifications to Change Certain Surveillance Intervals to Accommodate a 24-Month Fuel Cycle
	ML20358A155
Person / Time
Site:	Fermi
Issue date:	02/24/2021
From:	Shilpa Arora; Plant Licensing Branch III
To:	Peter Dietrich; DTE Electric Company
	Arora S S-NRR/DORL 301-415-1421
References
	EPID L-2019-LLA-0249
	Download: ML20358A155 (53)
	v • d • e

February 24, 2021 Mr. Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 260 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT NO. 218 - REVISION TO TECHNICAL SPECIFICATIONS TO CHANGE CERTAIN SURVEILLANCE INTERVALS TO ACCOMMODATE A 24-MONTH FUEL CYCLE (EPID L-2019-LLA-0249)

Dear Mr. Dietrich:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 218 to Renewed Facility Operating License No. NPF-43, for the Fermi 2 facility.

The amendment consists of changes to the technical specifications in response to your application dated November 8, 2019, as supplemented by letters dated June 23, 2020, and September 11, 2020.

The amendment revises the technical specifications to increase certain surveillance requirement intervals from 18 months to 24 months to accommodate a 24-month fuel cycle.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Surinder S. 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. 218 to NPF-43

2. Safety Evaluation cc: Listserv

ML20358A155 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/SCPB/BC NAME SArora SRohrer (JBurkhardt for) BWittick DATE 12/17/2020 01/05/2021 12/14/2020 OFFICE NRR/DSS/STSB/BC* NRR/DEX/EICB NRR/DEX/EEOB NAME VCusumano MWaters BTitus DATE 12/15/2020 12/16/2020 12/15/2020 OFFICE OGC (NLO) NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME DRoth NSalgado SArora DATE 02/09/2021 02/24/2021 02/24/2021 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 218 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 dated November 8, 2019, as supplemented by letters dated June 23, 2020, and September 11, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

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. 218, 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. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Nancy L. Nancy L. Salgado Date: 2021.02.24 Salgado 14:17:00 -05'00' 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: February 24, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 218 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-341 Renewed Facility Operating License No. NPF-43 Replace the following page of the Renewed Facility Operating License No. NPF-43 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

REMOVE INSERT Technical Specifications 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 5.0-12 5.0-12 5.0-19a 5.0-19a

-- 5.0-19b

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 218, 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. 218

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980. Testing will be performed at the frequencies specified by Regulatory Guide 1.52, Revision 2, except testing specified as having an 18-month frequency will be performed at a 24-month frequency.

a. Demonstrate for each of the ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass <

specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

Penetration and ESF Ventilation System Flowrate (cfm) System Bypass Standby Gas Treatment 3800 0.05%

Control Room Emergency 1800 (makeup filter) 1.0%

Filtration 3000 (recirculation filter)

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

Penetration and ESF Ventilation System Flowrate (cfm) System Bypass Standby Gas Treatment 3800 0.05%

Control Room Emergency 1800 (makeup filter) 1.0%

Filtration 3000 (recirculation filter)

(continued)

FERMI - UNIT 2 5.0-12 Amendment No. 134, 208, 218

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREF System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and assessed every 24 months.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.15 Surveillance Frequency Control Program This program provides controls for the Surveillance Frequencies.

The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with the NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

The one-time 24 Month Fuel Cycle related Surveillance Requirement Frequency changes approved by the NRC in License Amendment 218 are not subject to this provision. Subsequent changes are subject to the Surveillance Frequency Control Program.

(continued)

FERMI - UNIT 2 5.0-19a Amendment No. 198, 201, 218

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Surveillance Frequency Control Program (continued)

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

FERMI - UNIT 2 5.0-19b Amendment No. 218

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 218 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By application dated November 8, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19312A110), as supplemented by letters dated June 23, 2020 and September 11, 2020 (ADAMS Accession Nos. ML20175A788 and ML20255A166, respectively), DTE Electric Company (the licensee), requested changes to the technical specifications (TS) for Fermi 2.

The proposed changes will revise the TS for Fermi 2 to increase certain surveillance requirement (SR) intervals from 18 months to 24 months for SRs whose frequency is controlled within the licensees Surveillance Frequency Control Program (SFCP). The proposed changes also increase SR intervals for other TS within the Administrative Controls section of the TS. The licensee stated that all the proposed changes were made in accordance with the guidance of Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2, 1991 (ADAMS Accession No. ML031140501).

The supplemental letters dated June 23, 2020, and September 11, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC, the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on February 11, 2020 (85 FR 7790).

2.0 REGULATORY EVALUATION

2.1 Background

Improved reactor fuels allow licensees to consider an increase in the duration of the fuel cycle for their facilities. The NRC staff has reviewed requests for individual plants to modify TS surveillance intervals to be compatible with a 24-month fuel cycle. The NRC staff issued Enclosure 2

GL 91-04 to provide guidance to licensees for preparing such license amendment requests (LARs).

On September 16, 2014, DTE requested an amendment to the Fermi 2 TS to implement Technical Specifications Task Force (TSTF) Change Traveler TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b (ADAMS Accession No. ML14259A564). By letter dated July 14, 2015, the NRC issued Amendment No. 201 which approved the requested TS changes (ADAMS Accession No. ML15155B416). Amendment No. 201 incorporated TS 5.5.15, Surveillance Frequency Control Program (SFCP), into the Fermi 2 TS. The licensee stated that at that time DTE was not contemplating transitioning Fermi 2 to a 24-month fuel cycle.

The SFCP transferred most SR intervals from the TS to a licensee-controlled program. As discussed during DTEs presentation to the NRC staff during the pre-submittal meeting held on December 4, 2018 (ADAMS Accession No. ML18337A025), DTE is requesting NRC approval of a 24-month fuel cycle license amendment based on GL 91-04 in-lieu of the SFCP.

GL 91-04 has been used as the basis for 24-month fuel cycle SR interval changes in several recent examples of boiling-water reactor (BWR) facilities. As there are no precedents or prior experience with using the SFCP for the transition to a 24-month fuel cycle, the licensee proposed utilizing the GL 91-04 approach in its request for 24-month fuel cycle SR interval changes at Fermi 2.

2.2 Proposed Changes The proposed amendment would modify the Fermi 2 TS to support a 24-month fuel cycle and revises TS 5.5.15 for the SRs whose interval is contained in the licensee controlled SFCP, which are as follows:

SR 3.1.7.8, SR 3.1.7.9, SR 3.1.8.2, SR 3.3.1.1.13, SR 3.3.1.1.14, SR 3.3.1.1.15, SR 3.3.1.1.16, SR 3.3.1.1.17, SR 3.3.2.1.4, SR 3.3.2.2.3, SR 3.3.2.2.4, SR 3.3.3.1.2, SR 3.3.3.2.2, SR 3.3.3.2.3, SR 3.3.4.1.3, SR 3.3.4.1.4, SR 3.3.5.1.4, SR 3.3.5.1.5, SR 3.3.5.1.6, SR 3.3.5.2.4, SR 3.3.5.2.5, SR 3.3.5.2.6, SR 3.3.5.3.3, SR 3.3.6.1.4, SR 3.3.6.1.5, SR 3.3.6.1.6, SR 3.3.6.1.7, SR 3.3.6.2.4, SR 3.3.6.2.5, SR 3.3.6.3.3, SR 3.3.6.3.4, SR 3.3.7.1.5, SR 3.3.7.1.6, SR 3.3.7.2.3, SR 3.3.7.2.4, SR 3.3.7.3.3, SR 3.3.7.3.4, SR 3.3.8.2.2, SR 3.3.8.2.3, SR 3.4.3.2, SR 3.4.6.3, SR 3.5.1.7, SR 3.5.1.10, SR 3.5.1.11, SR 3.5.1.12, SR 3.5.1.13, SR 3.5.1.14, SR 3.5.2.8, SR 3.5.2.9, SR 3.5.3.4, SR 3.5.3.5, SR 3.6.1.1.2, SR 3.6.1.3.8, SR 3.6.1.3.9, SR 3.6.1.3.10, SR 3.6.1.6.1, SR 3.6.1.6.2, SR 3.6.1.7.3, SR 3.6.1.8.3, SR 3.6.4.1.5, SR 3.6.4.1.6, SR 3.6.4.2.3, SR 3.6.4.3.3, SR 3.6.4.3.4, SR 3.7.2.5, SR 3.7.3.3, SR 3.7.6.3, SR 3.7.6.4, SR 3.8.1.13, SR 3.8.1.14, SR 3.8.1.16, SR 3.8.4.3, SR 3.8.4.4, SR 3.8.4.5, SR 3.8.4.6, & SR 3.8.4.7.

In addition to the TS surveillance frequencies controlled via the SFCP, there are three TS Section 5.5 programs that currently have periodic 18-month frequency requirements that are not within the scope of the SFCP. The licensee additionally proposes to change these 18-month periodic requirements to 24 months. These three programs are TS 5.5.2, Primary Coolant Sources Outside Containment, TS 5.5.7, Ventilation Filter Testing Program (VFTP), and TS 5.5.14, Control Room Envelope Habitability Program. TS 5.5.2 includes integrated leak test requirements for systems within the scope of TS 5.5.2 at refueling cycle intervals or less.

The licensee stated that although there are no wording changes required for TS 5.5.2, the technical justification utilizing GL 91-04 was included in the amendment request.

The LAR divided the SR frequency changes into the following two categories consistent with GL 91-04: (1) changes to surveillance frequencies not involving channel calibrations, identified as Non-Calibration Changes, and (2) changes to surveillance frequencies involving channel calibrations, identified as Calibration Changes.

There are no changes to the TS Bases associated with this amendment request. With the implementation of the SFCP by Amendment No. 201, the TS Bases were revised to replace specific SR intervals with references to the SFCP.

2.3 Regulatory Requirements and Guidance 2.3.1 Regulatory Requirements The NRC staff considered the following regulatory requirements related to this application:

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, details the content and information that must be included in a facilitys TS. Specifically, 10 CFR 50.36 states in part:

Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section.

The regulation at 10 CFR 50.36(c)(3) states:

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.

Additionally, 10 CFR 50.36(c)(5) states:

Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

The regulation at 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, requires that preventative maintenance activities must not reduce the overall availability of the systems, structures, and components.

Furthermore, the NRC staff used the guidance in Section 2.3.2 of this safety evaluation to review the proposed TS changes against these requirements to ensure that there is reasonable assurance that the systems affected by the proposed TS changes will perform their required safety functions.

2.3.2 Regulatory Guidance The NRC staff considered the regulatory guidance provided in GL 91-04. GL 91-04, , indicates that SRs with an 18-month frequency requirement that are not instrument calibration related (i.e., Non-Calibration Changes) should be evaluated for the effect on safety associated with an extension to a 24-month required interval. This evaluation should address the following three criteria:

The licensee should analyze the effect on plant safety from the change in surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small, The licensee should confirm that historical plant maintenance and surveillance data support the conclusion that the effect on safety is small, and The licensee should confirm that the performance of surveillance at the bounding surveillance interval limit would not invalidate any assumption in the plant licensing basis.

For those SRs where the evaluation accomplishes these goals, the licensees need not quantify the effect of the change in surveillance intervals on the availability of individual systems or components. No change in the existence, testability, or availability of plant systems and components is being requested in this LAR, only an extension in the frequency of the tests or inspections.

GL 91-04, Enclosure 2, identifies the following seven steps for the evaluation of instrumentation calibration related (i.e., Calibration Changes) frequency changes.

1. Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.

2. Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.

3. Confirm the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model, number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications.

4. Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints.

If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.

5. Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to affect a safe shutdown with the associated instrumentation.

6. Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and channel calibrations.

7. Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.

Regulatory Guide (RG) 1.105, Revision 3, Setpoints for Safety-Related Instrumentation, December 1999 (ADAMS Accession No. ML993560062), describes a method that the NRC staff considers acceptable for complying with the agencys regulations for ensuring that setpoints for safety-related instrumentation are initially within and remain within the TS limits. RG 1.105 endorses Part 1 of Instrument Society of America (ISA) Standard 67.04-1994, Setpoints for Nuclear Safety-Related Instrumentation, subject to NRC staff clarifications. The NRC staff used this guide to establish the adequacy of the licensees setpoint calculation methodologies and the related plant surveillance procedures.

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), addresses requirements on limiting safety system settings that are assessed during the periodic testing and calibration of instrumentation. RIS 2006-17 discusses issues that could occur during the testing of limiting safety system settings and that, therefore, may have an adverse effect on equipment operability.

The NRC has previously approved similar license amendments for sites satisfying the criteria in GL 91-04, including:

Grand Gulf Nuclear Station, Unit 1 (ADAMS Accession No. ML13343A109),

Cooper Nuclear Station (ADAMS Accession No. ML12251A098), and River Bend Station, Unit 1 (ADAMS Accession No. ML102350266).

The past amendments were used to inform the scope of this review and the acceptability of proposed approaches.

3.0 TECHNICAL EVALUATION

Improved reactor fuels allow licensees to consider an increase in the duration of the fuel cycle for their facilities, which increases the time interval between refueling outages and the performance of the associated TS SRs. The NRC staff has reviewed requests for individual plants to modify TS surveillance intervals to be compatible with a 24-month fuel cycle. The NRC staff issued GL 91-04 to provide generic guidance to licensees for preparing such amendment requests.

Consistent with the Fermi 2 LAR and the guidance in GL 91-04, the NRC staffs evaluation is divided into two categories: (1) Non-Calibration Changes and (2) Calibration Changes. Non-Calibration Changes are discussed in LAR Section 4.1.1 and its Enclosure 5. Calibration Changes are discussed in LAR Section 4.1.2 and its Enclosures 5, 6, and 7.

3.1 Non-Calibration Changes 3.1.1 GL 91-04 Regulatory Guidance and Licensee Evaluation GL 91-04 identifies three steps to evaluate Non-Calibration Changes. The licensee provided the following general evaluations to those three steps.

Step 1: Licensees should evaluate the effect on safety of an increase in 18-month surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.

Licensee Evaluation of Step 1: Each proposed Non-Calibration SR interval change has been evaluated with respect to the effect on plant safety. The methodology utilized to justify the conclusion that changing the SR interval to 24 months has a minimal effect on safety is based on whether the associated function/feature is:

1. Tested on a more frequent basis during the operating cycle by other plant programs,

2. Designed to have redundant counterparts or be single failure proof, or

3. Highly reliable.

The licensee provided a summary of the evaluation of the effect on safety for each proposed Non-Calibration SR interval change in Enclosure 5 of the amendment request.

Step 2: Licensees should confirm that historical plant maintenance and surveillance data support this conclusion.

Licensee Evaluation of Step 2: The SR test history of the affected SRs has been evaluated, and this evaluation consisted of a review of available SR test results and associated maintenance records for at least five cycles of operation. With the extension of the SR interval to 24 months, there will be a longer period between each SR performance. If a failure results in the loss of the associated safety function during the operating cycle and would only be detected by the performance of the 18-month TS SR, then the increase in the SR testing interval could reduce the associated function availability. In addition to evaluating these SR failures, potential common failures of similar components tested by different SRs were also evaluated. This additional evaluation determined whether there is evidence of repetitive failures among similar plant components. These common component failures have been further evaluated to determine if there was an impact on plant reliability.

The licensees evaluation documented in Enclosure 5 of the amendment request determined that current plant programs are adequate to ensure system reliability. SR failures that are discussed in Enclosure 5 of the amendment request exclude failures that:

1. Did not impact a TS safety function of TS operability,

2. Are detectable by required testing performed more frequently that the 18-month SR being extended, or

3. The cause can be attributed to an associated event such as a preventative maintenance task, human error, previous modification, or previously existing design deficiency, or that were subsequently re-performed successfully with no intervening corrective

maintenance (e.g., plant conditions or malfunctioning measurement and test equipment may have caused aborting the test performance).

The licensee stated that these categories of failures are not related to potential unavailability due to SR interval extension and are therefore not listed or further evaluated in this submittal.

This review of SR test history validates the conclusion that the impact, if any, on system availability will be minimal as a result of the change to a 24-month SR interval. Specific SR test failures and justification for this conclusion are discussed in Enclosure 5 of the amendment request.

While reviewing the amendment request, the staff noted that the above evaluation to satisfy Step 2 was not included in the LAR. The staff drafted an audit plan dated April 8, 2020 (ADAMS Accession No. ML20094G814), to review the failures evaluation via a licensee-provided portal. Following the audit (the August 31, 2020, audit summary is available under ADAMS Accession No. ML20237F441), the licensee docketed the failures evaluation in its letter dated June 23, 2020, DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle 1, dated July 1st, 2019 (ADAMS Accession No. ML20175A788).

Step 3: Licensees should confirm that assumptions in the plant licensing basis would not be invalidated on the basis of performing any surveillance at the bounding SR interval limit provided to accommodate a 24-month fuel cycle.

Licensee Evaluation of Step 3: The impacts of the proposed SR changes were reviewed to confirm that assumptions in the plant licensing basis would not be invalidated. In general, SR intervals are not discussed in the descriptions of functions in the plant licensing basis. A review of the Fermi 2 Updated Final Safety Analysis Report (UFSAR) and Fermi 2 commitment tracking database identified that no assumptions in the plant licensing basis that would be invalidated by the proposed SR interval changes. Any necessary conforming changes will be made during implementation of the license amendment as required by 10 CFR 50.71(e), or as permitted by 10 CFR 50.59.

In its September 11, 2020 letter, the licensee further stated that the Maintenance Rule Program monitors and trends performance of structures, systems, and components (SSCs) included in the program scope. Degraded performance of SSCs are evaluated so that appropriate corrective measures can be taken. The evaluation of degrading performance that may result from the proposed SR interval changes would be considered routinely as part of this evaluation.

The NRC staff requested the licensee to confirm that the operability of the component or the system will not be impacted due to the SR extension and the operability after the SR extension will be based on the new SR interval. In its September 11, 2020, letter, the licensee confirmed that The proposed changes to surveillance intervals in no way alter the meaning of the Technical Specifications (TS) definition of OPERABILITY or alter the determination of OPERABILITY. The process and criteria for determining OPERABILITY when a SR is not satisfied remains the same for all SRs, regardless of the frequency. The staff confirmed the explanation provided by the licensee is consistent with the guidance in GL 91-04 and finds this position acceptable.

3.1.2 Non-Calibration SR Interval Change Evaluation In Section 2.A of LAR Enclosure 5, the licensee provided its evaluation of the proposed non-calibration changes. The licensee stated that the proposed changes increase the SR interval

from 18 to 24 months (a maximum of 30 months including the 25 percent extension afforded by TS SR 3.0.2 where applicable) for the non-calibration SRs. The licensee stated that the evaluations provided for each of the proposed changes support the conclusion that: the effect of these changes on plant safety, if any, is small; the proposed changes do not invalidate any assumption in the plant licensing basis; and the impact, if any, on system availability is minimal.

Observation of no failures during completion of the SRs is acceptable because they will have little or no effect on safety.

The NRC staff reviewed the evaluations related to all non-calibration changes proposed by the licensee. The staff finds the changes meet the guidance of GL 91-04 as explained under the following individual items.

3.1.2.1 TS 3.1.7, Standby Liquid Control (SLC) System The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.1.7.8 Verify flow through one SLC subsystem from pump into reactor pressure vessel.

SR 3.1.7.9 Verify all piping between storage tank and explosive valve is unblocked.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

These two SRs are performed during outage conditions because these tests could inadvertently cause a reactor transient if performed with the unit operating.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The SLC pumps and valves are powered and controlled from separate buses and circuits so that a single electrical failure will not prevent system operation. The pumps are tested quarterly in accordance with the Inservice Testing (IST) Program per SR 3.1.7.7. SR 3.1.7.1 verifies the available volume of the sodium solution every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Additionally, the temperature of the sodium pentaborate solution in the storage tank and the temperature of the pump suction piping are verified to be within limits every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per SRs 3.1.7.2 and 3.1.7.3 respectively. An installed backup heater is used to maintain solution temperature above the saturation point. In addition, SR 3.1.7.4 verifies the continuity of the charge in the explosive valve every 31 days.

These more frequent tests ensure that the SLC system remains operable during the operating cycle.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed increase in frequency of SRs 3.1.7.8 and 3.1.7.9 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.2 TS 3.1.8, Scram Discharge Volume (SDV) Vent and Drain Valves The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.1.8.2 Verify each SDV vent and drain valve:

a. Closes in 30 seconds after receipt of an actual or simulated scram signal; and

b. Opens when the actual or simulated scram signal is reset.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

This SR ensures SDV vent and drain valves close in 30 seconds after receipt of an actual or simulated scram signal and open when the actual or simulated scram signal is reset.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.1.8.2 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.3 TS 3.3.2.1, Control Rod Block Instrumentation SR 3.3.2.1.4 Perform CHANNEL FUNCTIONAL TEST.

o Function 3 - Reactor Mode Switch - Shutdown Position No failures were reported for this SR. Therefore, the NRC staff finds the change meets the guidance of GL 91-04 and is acceptable.

3.1.2.4 TS 3.4.3, Safety Relief Valves (SRVs)

The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.4.3.2 Verify each required SRV is capable of being opened.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

SRVs are required to actuate in the safety mode or automatically upon receipt of specific initiation signals (ADS [automatic depressurization system] or LLS [low-low set]). A manual actuation of each required SRV per SR 3.4.3.2 is performed to verify that the valve is functioning properly, and no blockage exists in the valve discharge line.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.4.3.2 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.5 TS 3.5.1, ECCS [Emergency Core Cooling System]-Operating The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.5.1.7 Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position.

SR 3.5.1.10 Verify, with reactor pressure 215 psig [pounds per square inch gauge],

the HPCI [high-pressure coolant injection] pump can develop a flow rate 5000 gpm [gallons per minute] against a system head corresponding to reactor pressure.

SR 3.5.1.11 Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.

SR 3.5.1.12 Verify the ADS actuates on an actual or simulated automatic initiation signal.

SR 3.5.1.13 Verify each ADS valve is capable of being opened.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically operable and will close when required.

Upon initiation of an automatic LPCI [low-pressure coolant injection] subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps.

The flow tests for the HPCI System are performed at two different pressure ranges such that system capability to provide rated flow against a system head corresponding to reactor pressure is tested at both the higher (SR 3.5.1.9, in accordance with the IST Program) and lower (SR 3.5.1.10) operating ranges of the system. The required system head should overcome the RPV [reactor pressure vessel] pressure and associated discharge line losses. Adequate reactor pressure must be available to perform these tests. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the HPCI System diverts steam flow. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests. Adequate reactor steam pressure must be 165 psig [pounds per square inch gage] to perform SR 3.5.1.10. Adequate steam flow is represented by main turbine generator online or turbine bypass valves at least 15%

open in auto-pressure control. Reactor startup is allowed prior to performing the low-

pressure SR test because the reactor pressure is ow and the time allowed to satisfactorily perform the SR test is short.

The ECCS and ADS functional tests ensure that a system initiation signal (actual or simulated) to the automatic initiation logic will cause the systems or subsystems to operate as designed. The ECCS logic has built-in redundancy so that no single active failure prevents accomplishing the safety function of the ECCS.

The pumps associated with ECCS are tested quarterly in accordance with the IST Program and SR 3.5.1.8 (some valves may have approval under 10 CFR 50.55a for less frequent IST testing). This testing ensures that the major components of the systems can perform their design function. The SRs proposed to be extended need to be performed during outage conditions since they have the potential to initiate an unplanned transient if performed during operating conditions.

Valve operability and the setpoints for overpressure protection are verified, per ASME

[American Society of Mechanical Engineers] Code requirements, prior to valve installation. Actuation of each required ADS valve is performed to verify that mechanically the valve is functioning properly.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SRs 3.5.1.7, 3.5.1.10, 3.5.1.11, 3.5.1.12, and 3.5.1.13 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.6 TS 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control SR 3.5.2.8 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

SR 3.5.2.9 Verify the required ECCS injection/spray subsystem can be manually operated.

Among all the documented SRs in these two functions, there were a few isolated failures that either did not affect the safety function or the failures were random and not repetitive time-based failures as described in the licensees letter dated June 23, 2020. Some of these events did not have any impact on safety. The SR failure noted in SR 3.5.2.8 was due to a maintenance

failure which qualifies as an exemption from failure because it is not SR extension related. In SR 3.5.2.9, there were five noted failures. Three of these events were due to improper indication but there was no loss of function. One event was caused by a broken wire which is not a failure that would be affected by an SR extension. One failure happened because the procedure could not be carried out as written. This failure is not related to an SR extension.

Considering that the described failures had no impact on safety and they are non-repetitive in nature, the NRC staff finds the licensees position meets the guidance of GL 91-04, and the requested extension to a 24 month SR interval is acceptable.

3.1.2.7 TS 3.5.3, RCIC [Reactor Core Isolation Cooling] System The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.5.3.4 Verify, with reactor pressure 200 psig, the RCIC pump can develop a flow rate 600 gpm against a system head corresponding to reactor pressure.

SR 3.5.3.5 Verify the RCIC System actuates on an actual or simulated automatic initiation signal.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

The flow tests for the RCIC System are performed at two different pressure ranges such that system capability to provide rated flow is tested both at the higher (SR 3.5.3.3) and lower (SR 3.5.3.4) operating ranges of the system.

Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Reactor steam pressure must be 945 psig to perform SR 3.5.3.3 (each 92 days) and 150 psig to perform SR 3.5.3.4. The functional test ensures that a system initiation signal (actual or simulated) to the automatic initiation logic will cause the system to operate as designed.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SRs 3.5.3.4 and 3.5.3.5 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.8 TS 3.6.1.1, Primary Containment The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.1.1.2 Verify drywell to suppression chamber differential pressure does not decrease at a rate > 0.2 inch water gauge per minute tested over a 10 minute period at an initial differential pressure of 1 psid.

In the LAR, the licensee stated that the technical justification for the proposed change addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

This SR ensures the drywell to suppression chamber bypass leakage is limited to an amount equivalent to a hole < 1.0 inch in diameter. The SR interval was developed considering it is prudent that this SR be performed during a unit outage and because component failures that might have affected this test are identified by other primary containment SRs.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failure Report and determined that the proposed change for SR 3.6.1.1.2 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extension for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.9 TS 3.6.1.3, Primary Containment Isolation Valves (PCIV)

The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.1.3.8 Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.9 Verify a representative sample of reactor instrumentation line EFCVs

[excess flow check valves] actuates to the isolation position on an actual or simulated instrument line break to restrict flow.

SR 3.6.1.3.10 Remove and test the explosive squib from each shear isolation valve of the TIP system.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated DBAs [design-basis accidents] to within limits. Primary containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA.

During the operating cycle, SR 3.6.1.3.5 requires automatic PCIV isolation times to be verified in accordance with the IST Program. Stroke testing of PCIVs tests a significant portion of the PCIV circuitry as well as the mechanical function of the valve. The ASME OM [Operations and Maintenance] Code specifies valve stroke testing at 92-day intervals; however, includes exceptions for valves that cannot be stroked during normal operation.

The SR 3.6.1.3.9 excess flow check valves (EFCV) SR interval is based on the need to perform the SR during a plant outage when there is not the potential for a plant transient if the surveillance was performed during power operation. A representative sample is tested each refueling interval such that the total population is tested every 10 years.

In addition to the SR 3.6.1.10 Traversing Incore Probe (TIP) System explosive squib testing, SR 3.6.1.3.4 verifies continuity of the TIP shear isolation valve explosive charge on a 31-day SR interval providing confidence that the TIP explosive squibs would perform their safety function.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SRs 3.6.1.3.8, 3.6.1.3.9, and 3.6.1.3.10 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.10 TS 3.6.1.6, Low-Low Set (LLS) Valves The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.1.6.1 Verify each LLS valve is capable of being opened.

SR 3.6.1.6.2 Verify the LLS System actuates on an actual or simulated automatic initiation signal.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

The SR interval for SR 3.6.1.6.1 is based on the SRV tests required by the ASME OM Code. SR 3.3.6.3.1 requires a more frequent CHANNEL FUNCTIONAL TEST at a 31-day interval. This CHANNEL FUNCTIONAL TEST ensures that a major portion of the LLS instrumentation is operating properly and will detect significant failures within the instrument loop. Additionally, the LLS valves (i.e., SRVs assigned to the LLS logic) are designed to meet applicable reliability, redundancy, single failure, and qualification standards and regulations as described in the Fermi 2 UFSAR. As such, these functions are designed to be highly reliable.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SRs 3.6.1.6.1 and 3.6.1.6.2 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no

assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.11 TS 3.6.1.7, Reactor Building-to-Suppression Chamber Vacuum Breakers The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.1.7.3 Verify the opening setpoint of each vacuum breaker is 0.5 psid.

In the LAR, the licensee stated that the technical justification for the proposed change addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

This SR ensures that the vacuum breaker opening setpoint safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid

[pounds per square inch differential] is valid. SR 3.6.1.7.1 (14 days) and SR 3.6.1.7.2 (31 days) performed at shorter intervals convey the proper functioning status of each vacuum breaker.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of this SR. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.6.1.7.3 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.12 TS 3.6.1.8, Suppression Chamber-to-Drywell Vacuum Breakers The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.1.8.3 Verify the opening setpoint of each vacuum breaker is 0.5 psid.

In the LAR, the licensee stated that the technical justification for the proposed change addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

This SR ensures that the vacuum breaker opening setpoint safety analysis assumption regarding vacuum breaker opening differential pressure of 0.5 psid is valid. SR 3.6.1.8.1 (7 days) which is performed at shorter intervals, establishes the requisite initial conditions for the proper functioning of each vacuum breaker.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of this SR. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.6.1.8.3 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extension for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.13 TS 3.6.4.1, Secondary Containment The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, on a STAGGERED TEST BASIS, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.4.1.5 Verify each standby gas treatment (SGT) subsystem will draw down the secondary containment to 0.25 inch of vacuum water gauge in 12 minutes.

SR 3.6.4.1.6 Verify each SGT subsystem can maintain 0.25 inch of vacuum water gauge in the secondary containment for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a flow rate 3000 cfm [cubic feet per minute].

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

To ensure that all fission products are treated, the test required per SR 3.6.4.1.5 is performed utilizing one SGT subsystem (on a STAGGERED TEST BASIS) to ensure secondary containment boundary integrity. SR 3.6.4.1.1 (every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ), 3.6.4.1.2 (every 31 days), and 3.6.4.1.3 (every 31 days) provide more frequent assurance that no significant boundary degradation has occurred.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SRs 3.6.4.1.5 and 3.6.4.1.6 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.14 TS 3.6.4.2, Secondary Containment Isolation Valves (SCIVs)

The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.4.2.3 Verify each automatic SCIV actuates to the isolation position on an actual or simulated actuation signal.

In the LAR, the licensee stated that the technical justification for the proposed change addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

Verifying that each automatic SCIV closes on a secondary containment isolation signal is required to prevent leakage of radioactive material from secondary containment following a DBA or other accidents. This SR ensures that each automatic SCIV will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function.

During the operating cycle, SR 3.6.4.2.2 requires the isolation time of each power operated automatic SCIV to be tested (i.e., stroke timed to the closed position) every 92 days. The stroke testing of these SCIVs tests a portion of the circuitry and the mechanical function and provides more frequent testing to detect failures.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of this SR. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.6.4.2.3 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.15 TS 3.6.4.3, Standby Gas Treatment (SGT) System The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or simulated initiation signal.

SR 3.6.4.3.4 Verify each SGT filter cooler bypass damper can be opened and the fan started.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

These SGT functional tests ensure that subsystems operate as designed. The SGT subsystems are redundant so that following initial draw-down of post-LOCA

[loss-of-coolant accident] Reactor Building pressure, no single-failure prevents accomplishing the safety functions of filtering the discharge from secondary containment and directing the discharge to the Elevated Release Point. This SGT subsystem redundancy assures overall reliability of the SGT system function. More frequent verification of portions of the SGT function are accomplished by operating each SGT subsystem and heaters every 31 days per SR 3.6.4.3.1.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SRs 3.6.4.3.3 and 3.6.4.3.4 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.16 TS 3.7.2, Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.7.2.5 Verify each EECW/EESW subsystem actuates on an actual or simulated initiation signal.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

This SR verifies that the automatic isolation valves of each EECW/EESW subsystem will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety-related equipment during an accident. This SR also verifies the automatic start capability of the EECW and EESW pumps in each subsystem. The EECW and EESW subsystems are designed with sufficient redundancy so that no single-failure can prevent accomplishing the safety function of providing the required cooling.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.7.2.5 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.17 TS 3.7.3, Control Room Emergency Filtration (CREF) System The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.7.3.3 Verify each CREF subsystem actuates on an actual or simulated initiation signal.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety

evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

The CREF System maintains the habitability of the Control Room Envelope from which occupants can control the unit following an uncontrolled release of radioactivity during certain DBAs. More frequent verification of portions of the CREF System function is accomplished by operating the CREF System every 31 days per SR 3.7.3.1. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.7.3.3 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.18 TS 3.7.6, The Main Turbine Bypass System and Moisture Separator Reheater The LAR proposes to increase the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.7.6.3 Perform a system functional test.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

SR 3.7.6.3 ensures that on increasing main steam line pressure events, the main turbine bypass system will operate as designed.

SR 3.7.6.1 verifies that each main bypass valve opens at least 5% every 120 days. This provides assurance of proper operation of each bypass valve

and tests the valve, operator and portions of the actuation circuitry on a more frequent basis than SR 3.7.6.3.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of this SR. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The licensee stated that the impact, if any, on system availability is minimal from the proposed SR interval change from 18 to 24 months. Based on other more frequent testing of the system, system design, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.7.6.3 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extension for the above SR acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed change.

3.1.2.19 TS 3.8.1, AC [Alternating Current] Sources - Operating The LAR requests a revision of TS 3.8.1 by changing the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.8.1.13 Verify each EDG [emergency diesel generator] operates for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For all but the final 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 2500 kW [kilowatt] and 2600 kW; and

b. For the final 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the test loaded 2800 kW and 2900 kW.

SR 3.8.1.14 Verify each EDG starts and achieves:

a. In 10 seconds, voltage 3950 V [Volt] and frequency 58.8 Hz

[Hertz]; and,

b. Steady state voltage 3950 V and 4580 V and frequency 58.8 Hz and 61.2 Hz.

SR 3.8.1.16 Verify interval between each sequenced load block is within +/- 10% of design interval for each load sequencer timer.

In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04.

For non-calibration SRs, GL 91-04 recommends that licensees should perform evaluations and confirmations, including the following, to support the change in surveillance intervals to accommodate a 24-month fuel cycle:

a) Evaluate of the effect on safety of the change in surveillance intervals to support a conclusion that the effect on safety is small.

b) Confirm that historical maintenance and surveillance data do not invalidate the conclusion that the effect on safety is small.

c) Confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.

In the LAR, the licensee provided a summary of the evaluation to address GL 91-04 recommendation (a) above. In the LAR, the licensee stated that:

The EDGs are infrequently operated; therefore, the risk of wear-related degradation is minimal.

The SR testing during operation proves the ability of the EDGs to start and operate under various load conditions.

More frequent testing of the AC sources is also required as follows:

SR 3.8.1.1 Verifying correct breaker alignment and indicated power availability for each required offsite circuit every 7 days; SR 3.8.1.2 and SR 3.8.1.3:

Verifying the EDG starting and load carrying capability is demonstrated every 31 days; SR 3.8.1.4 Verify each day tank contains one-hour supply of fuel oil every 31 days; SR 3.8.1.5 Check for and remove accumulated water from each day tank every 31 days; SR 3.8.1.6 Verify each fuel oil transfer system operates to automatically transfer fuel oil from storage tanks to the day tanks, every 31 days; SR 3.8.1.7 Verifying the ability of each EDG to reach rated voltage and frequency within required time limits every 184 days will provide prompt identification of any substantial EDG degradation or failure; SR 3.8.3.1 Verify each required EDG fuel oil storage tank contains a 7-day supply of fuel; SR 3.8.3.3 Verify each required EDG air start receiver pressure is 215 psig

[pounds per square inch gauge] every 31 days; and SR 3.8.3.4 Check for and remove accumulated water from each required EDG fuel oil storage tank every 31 days.

The NRC staff notes that the Fermi 2 Class 1E alternating current (AC) sources consist of the offsite power sources and the onsite standby power sources provided by four EDGs. This design configuration provides sufficient redundancy in AC power sources. The staff also notes that more frequent testing of the AC power sources listed above could maintain the ability of the EDGs to start to provide the safety functions necessary to safely shut down the reactor and maintain the reactor in safe condition. Therefore, the NRC staff agreed that the licensees evaluation to address GL 91-04 recommendation (a) above provides a reasonable assurance that the effect on safety of the change in surveillance intervals is small.

Regarding GL 91-04 recommendation (b) above, the LAR states that a review of SR test history identified no failures of the TS functions that would have been detected solely by the periodic performance of these SRs. For GL 91-04 recommendation (c) above, the LAR states that a review of the Fermi 2 UFSAR and Fermi 2 commitment tracking database identified that no assumptions in the plant licensing basis that would be invalidated by the proposed SR interval changes.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.8.1.13, SR 3.8.1.14, and SR 3.8.1.16 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.20 TS 3.8.4, DC Sources - Operating In the LAR, the licensee stated that the direct current (DC) sources consist of two 260-volt DC (VDC) batteries, one for each division. Each 260 VDC battery is divided into two 130 VDC batteries connected in series. Each 130 VDC battery section has a battery charger connected in parallel with its respective battery. Each 260 VDC battery has a spare battery charger that can replace either of the normal 130 VDC connected chargers. Each division's two 130 VDC batteries and their chargers are the source of DC control power for that respective division, including the respective EDG. Each 260 VDC source furnishes power to DC motors necessary for shutdown conditions. During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC loads are automatically powered from the batteries.

The LAR requests a revision of TS 3.8.4 by changing the interval of the following non-calibration SRs from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.8.4.3 Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

SR 3.8.4.4 Remove visible corrosion and verify battery cell to cell and terminal connections are coated with anti-corrosion material.

SR 3.8.4.5 Verify each battery:

a. Cell-to-cell and terminal connection resistance is 1.5 E-4 ohm; and

b. Total cell-to-cell and terminal connection resistance is 2.7 E-3 ohm.

SR 3.8.4.6 Verify each required battery charger supplies 100 amps at 124.7 V for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SR 3.8.4.7 Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the actual or simulated emergency loads for the design duty cycle when subjected to a battery service test.

For non-calibration SRs, GL 91-04 recommends that the licensees should perform evaluations and confirmations, including the following, to support the change in surveillance intervals to accommodate a 24-month fuel cycle:

a) Evaluate of the effect on safety of the change in surveillance intervals to support a conclusion that the effect on safety is small.

b) Confirm that historical maintenance and surveillance data do not invalidate the conclusion that the effect on safety is small.

c) Confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations above. In particular, the licensee stated that SR 3.8.4.1 and SR 3.8.4.2 are performed at 7-day and 92-day intervals respectively. These more frequent tests verify battery terminal voltage and condition of battery terminals and connectors. These more frequent tests provide additional confidence that the batteries are capable of performing their safety functions.

A review of SR test history identified no failures of the TS functions that would have been detected solely by the periodic performance of these SRs. Accordingly, the impact, if any, on system availability is minimal from the proposed change to a 24-month SR interval. Based on other more frequent testing of the system, and the history of system performance, the impact of this change on safety, if any, is small.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.8.4.3, SR 3.8.4.4, and SR 3.8.4.5, SR 3.8.4.6, and SR 3.8.4.7 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.21 TS 5.5.2, Primary Coolant Sources Outside Containment The program shall include the following:

b. Integrated leak test requirements for each system at refueling cycle intervals or less.

No changes are proposed for TS 5.5.2. The phrase refueling cycle intervals or less is not being changed. However, refueling interval will be understood to mean 24 months.

In the LAR, the licensee stated that this program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include Core Spray, High Pressure Coolant Injection, Residual Heat Removal, Reactor Core Isolation Cooling, Reactor Water Sampling, Post Accident Sampling, Reactor Water Cleanup, Hydrogen Recombiners, Primary Containment Monitoring, Control Rod Drive discharge headers, and SGT.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for TS 5.5.2 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.22 TS 5.5.7, Ventilation Filter Testing Program (VFTP)

The LAR requests a revision of TS 5.5.7 that increases the testing interval specified by RG 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, March 1978 (ADAMS Accession No. ML003740139), from 18 months to 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

The licensee proposes changing TS 5.5.7 from:

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2, and in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980.

to:

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980. Testing will be performed at the frequencies specified by Regulatory Guide 1.52, Revision 2, except testing specified as having an 18-month frequency will be performed at a 24-month frequency.

The VFTP requires the following testing of the ESF filter ventilation systems in accordance with RG 1.52, Revision 2, and ASME N510-1980 at the frequencies specified in RG 1.52, Revision 2 (i.e., 18 months). The performance/evaluation criteria can be found in TS 5.5.7. The proposed amendment increases the frequencies from 18 to 24 months by satisfying the requirements in paragraphs a, b, c, d, and e below without any change to those paragraphs:

a. Demonstrate for each of the ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1980 at the system flowrate specified below +/- 10%.

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ASME N510-1980.

In the LAR, the licensee provided a summary of the evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

Regulatory Guide 1.52, Revision 2, specifies performance of these tests once every 18 months. Additionally, Regulatory Guide 1.52, Revision 2, requires testing of High Efficiency Particulate Air Filters (HEPA) and charcoal adsorbers after 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of operation, and following painting, fire, or chemical release in any ventilation zone communicating with the system.

The proposed change does not affect the requirements to perform HEPA and charcoal adsorber testing after 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of operation, and following painting, fire, or chemical release in any ventilation zone communicating with the system.

The licensee reviewed the SR and test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these tests. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for TS 5.5.7 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above testing in TS 5.5.7 is acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.23 TS 5.5.14, Control Room Envelope Habitability Program (CREHP)

The LAR requests a revision to TS 5.5.14 that increases the testing interval from once every 18 to 24 months, on a STAGGERED TEST BASIS, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2. The proposed change also increases the trending and assessment interval from every 18 to 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

The licensee proposes changing item d of TS 5.5.14 from:

Measurement, at designated locations, of the CRE [control room envelope]

pressure relative to all external areas adjacent to the CRE boundary during the

pressurization mode of operation by one subsystem of the CREF System, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and assessed every 18 months.

to:

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREF System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and assessed every 24 months.

The licensee reviewed the SR and test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these tests. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for TS 5.5.14 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above TS acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.1.2.24 TS 5.5.15, Surveillance Frequency Control Program The proposed amendment would modify the Fermi 2 TS to support a 24-month fuel cycle. The proposed TS change revises TS 5.5.15, Surveillance Frequency Control Program. DTE has already adopted TSTF-425 which added TS 5.5.15, Surveillance Frequency Control Program, and transferred most SR intervals from the TS to the licensee-controlled list required by TS 5.5.15.a. The list includes the SR intervals that are proposed to be changed to 24 months, except for testing required by Programs and Manuals Section 5.5, TS 5.5.7, Ventilation Filter Testing Program (VFTP) and TS 5.5.14, Control Room Habitability Testing Program.

TS 5.5.15 permits the licensee to change TS SR intervals in the licensee-controlled list as provided by TS 5.5.15.b.

Currently, TS 5.5.15.b. states:

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with the NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

The licensee stated that GL 91-04, has been, and continues to be, the approach used as the basis for 24-month fuel cycle SR interval changes. As such, DTE proposes to add the following provision to TS 5.5.15.b:

The one-time 24 Month Fuel Cycle related Surveillance Requirement Frequency changes approved by the NRC in License Amendment 218 are not subject to this provision. Subsequent changes are subject to the Surveillance Frequency Control Program.

The licensee provided the following explanation regarding the proposed change to TS 5.5.15:

This provision provides an exception to the TS 5.5.15.b, requirement to evaluate the 24-month fuel cycle SR interval changes using NEI 04-10, Revision 3. In conjunction with this change, DTE is submitting the technical justification requested by GL 91-04. The overall impact of this approach is that the process for changing SR intervals for Fermi 2 is the same as for previous plants including those identified in Section 5.2. DTE is requesting a license amendment to change the SR intervals using technical justification which addresses the information requested by GL 91-04. The difference between Fermi 2 and previous 24-month fuel cycle submittals is how the changes are reflected administratively in the TS.

Once the amendment is approved, the associated NRC Safety Evaluation (SE) documenting review of the supporting GL 91-04 technical justification will provide the basis for incorporating the revised SR intervals into the SFCP list required by TS 5.5.15.a. Any future changes to the revised SR intervals will be governed by TS 5.5.15.

The NRC staff reviewed the changes made to TS 5.5.15 and the licensees evaluation supporting the proposed changes. The staff finds that additional language added to TS 5.5.15.b properly annotates that the TS SR interval changes requested in this amendment request were evaluated using the criteria in GL 91-04 and that any subsequent changes are subject to the provisions of the Surveillance Frequency Control Program. Therefore, the NRC staff finds that the changes made to TS 5.5.15.b are acceptable and appropriate.

3.2 Other Non-Calibration Changes (B-1)

The licensee has proposed to change SR interval from 18 to 24 months for a maximum of 30 months, including a 25 percent extension provided by SR 3.0.2.

The Logic System Functional Tests (LSFTs) and selected Channel Functional Tests (CFTs) are discussed in Sections 3.2.1 and 3.2.2 of this safety evaluation. The selected 18-month interval CFTs discussed in these Sections apply only to manual initiation logic.

3.2.1 Guidance/Licensee Evaluation Logic systems subject to the 18-month interval LSFT and associated instrument channels are subject to more frequently performed CHANNEL CHECKS and CFTs. Other activities such as analog trip module calibrations, and confirmation of satisfactory operation such as during the performance of IST of actuated pumps and valves, provide assurance of proper operation.

These more frequent activities test and exercise major portions of the logic system circuitry and will detect significant failures of the associated instrumentation. The actuation instrumentation and logic, controls, monitoring capabilities, and protection systems, are designed to meet applicable reliability, redundancy, single failure, qualification standards and regulations as described in the Fermi 2 UFSAR. Accordingly, these functions are designed to be highly reliable. Furthermore, as stated in the July 15, 1993, NRC Safety Evaluation Report relating to

extension of the Peach Bottom Atomic Power Station, Units 2 and 3 (ADAMS Accession No. ML011440159), surveillance intervals from 18 months to 24 months:

Industry reliability studies for boiling water reactors (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems reliabilities are not dominated by the reliabilities of the logic systems, but by that of the mechanical components, (e.g., pumps and valves), which are consequently tested on a more frequent basis.

Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the LOGIC SYSTEM FUNCTIONAL TEST interval represents no significant change in the overall safety system unavailability.

The licensee stated that the above justification for increasing the SR interval from 18 to 24 months is applicable to the LSFT and CFT SRs identified in Section 3.2.2 below.

3.2.2 Other Non-Calibration (B-1) SR Interval Change Evaluation 3.2.2.1 TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.13 Perform CHANNEL FUNCTIONAL TEST SR 3.3.1.1.15 Perform LOGIC SYSTEM FUNCTIONAL TEST There were a large number of surveillances performed in these two categories. One failure was noted in the SR 3.3.1.1.13. This failure was not a failure to perform the safety function but was instead a failure in the test equipment cable. This failure is not related to SR extension. There were a few failures in the SR 3.3.1.1.15; however, these failures were either event-driven or test/calibration failures which did not affect the performance of the safety function. The NRC staffs review indicates that effect on safety will be very small or negligible. The SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.2 TS 3.3.2.2, Feedwater and Main Turbine High Water Level Trip Instrumentation SR 3.3.2.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST There were only a small number of surveillances performed for this test. There was a failure on April 2, 2009, due to a transmitter failure. The transmitter failure was noted as an age-related failure. However, there was no discussion about a replacement program. In its September 11, 2020, letter in response to the NRC staffs request for additional information, the licensee clarified that the transmitter was installed in June 1991 and had a qualified life of 50 years. The transmitter failed in less than half of its qualified life, which is not considered to be an age-related failure. The licensee concluded that the transmitter failure was a random hardware-related failure and not an indication of age-related repetitive failure, and it will not affect the SR extension. There were four additional failures described, none of which had any impact on safety. The above review indicates that decrease in safety will be very small, and the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.3 TS 3.3.3.2, Remote Shutdown System SR 3.3.3.2.2 Verify each required control circuit and transfer switch is capable of performing the intended functions.

There were only a small number of surveillances performed for this test. There was one reported failure which was event-driven and had no impact on performance of the safety function. The NRC staffs review indicates that any decrease in safety will be very small, and the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.4 TS 3.3.4.1, Anticipated Transient Without Scram Recirculation Pump Trip (ATWS/RPT) Instrumentation SR 3.3.4.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST including breaker actuation There were a small number of surveillances performed with one reported event-driven failure which did not affect the performance of the safety function. The staffs review indicates that any decrease in safety will be very small and hence the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.5 TS 3.3.5.1, Emergency Core Cooling (ECCS) Instrumentation SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST SR 3.3.5.1.6 Perform CHANNEL FUNCTIONAL TEST There were a large number of surveillances performed and a few failures including one event-driven failure. However, none of them had an associated loss of safety function. The NRC staffs review indicates that any decrease in safety will be very small, and the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.6 TS 3.3.5.2, Reactor Core Isolation Cooling (RCIC) System Instrumentation SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONALITY TEST SR 3.3.5.2.6 Perform CHANNEL FUNCTIONAL TEST There were a small number of surveillances performed for SR 3.3.5.2.5 and a few failures, but none of them had a loss of safety function. In addition, there was one event-driven failure which did not cause a loss of safety function. There was one failure in SR 3.3.5.2.6 which did not affect the safety function. The NRC staffs review indicates that any effect on safety will be very small, and the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.7 TS 3.3.5.3, RPV Water Inventory Control Instrumentation SR 3.3.5.3.3 Perform CHANNEL FUNCTIONAL TEST There were a small number of surveillances performed for SR 3.3.5.3.3 with a few failures, but none of them had a loss of safety function. There were a few event-driven failures which did not cause a loss of safety function. Therefore, the change meets the acceptance criteria guidance as explained in section 3.1 of the SE. The NRC staffs review indicates that any effect on safety

will be very small, and the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.8.a TS 3.3.6.1, Primary Containment Isolation Instrumentation SR 3.3.6.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST SR 3.3.6.1.6 Perform CHANNEL FUNCTIONAL TEST There was a large data set for these two functions with only a few failures which did not cause loss of safety functions; there were a few data equipment-related failures, a limit switch needed recalibration, and there were some other failures which did not cause a loss of safety function.

The failures were relatively small and the effect on safety was very small. Hence, the SR extension is acceptable to the NRC staff based on the guidance of GL 91-04.

3.2.2.8.b TS 3.3.6.2, Secondary Containment Isolation Instrumentation SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST There was a medium size data set for this function and three reported failures, none of which caused a loss of safety function. Based on its data review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.2.2.9 TS 3.3.6.3, Low-Low Set (LLS) Instrumentation SR 3.3.6.3.4 Perform LOGIC SYSTEM FUNCTIONAL TEST There was a medium size data base with four failures which did not affect the safety function, and there was one event-driven failure which was not repetitive or time-based and did not affect the safety function. Based on its data review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.2.2.10 TS 3.3.7.1, Control Room Emergency Filtration (CREF) System Instrumentation SR 3.3.7.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST There was a medium size data base with three failures which did not affect the safety function, and one event-driven failure which was not repetitive or time-based and did not affect the safety function. Based on its data review, the NRC staff finds that the potential effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.2.2.11 TS 3.3.7.2, Mechanical Vacuum Pump (MVP) Trip Instrumentation SR 3.3.7.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST including MVP breaker actuation No failures were reported for this SR. Therefore, based on its data review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.2.2.12 TS 3.3.7.3, Gland Seal Exhauster (GSE) Trip Instrumentation SR 3.3.7.3.4 Perform LOGIC SYSTEM FUNCTIONAL TEST including GSE breaker actuation No failures were reported for this SR. Therefore, based on its review of available data, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.2.2.13 TS 3.3.8.2, Reactor Protection System (RPS) Electric Power Monitoring SR 3.3.8.2.3 Perform a system functional test There was a small number of data pertaining to this SR with some failures but none of the failures were attributable to loss of function. Based on its data review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.3 Other Non-Calibration Changes (B-2)

The interval for the SRs discussed in Sections 3.3.1 and 3.3.2 of this safety evaluation is being increased from once every 18 to 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

3.3.1 Guidance/Licensee Evaluation In the LAR, the licensee stated the TS functions associated with the RESPONSE TIME tests are verified to be operating properly throughout the operating cycle by the performance of other more frequently performed SRs (e.g., CHANNEL CHECKS and CHANNEL FUNCTIONAL TESTS). This testing ensures that a significant portion of the circuitry is operating properly and will detect significant failures of this circuitry. These functions, including the actuating logic, are designed to be highly reliable with suitable redundancy to address single failures in accordance with 10 CFR Part 50 Appendix A, General Design Criteria for Nuclear Power Plants. Moreover, the Fermi 2 TS Bases (as well as NUREG-1433, Standard Technical Specifications BWR/4) states that the SR interval of response time testing is based in part upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel failure, are infrequent occurrences.

Additionally, the licensee stated that a review of SR test history identified no failures of the TS functions that would have been detected solely by the periodic performance of these SRs.

Accordingly, the licensee stated the impact of increasing the SR testing interval to 24 months, if any, on system availability is minimal. Based on other more frequent testing of the systems, the ability to readily detect system performance deficiencies, and the history of system performance, the impact of these changes on safety, if any, is small.

3.3.2 Other Non-Calibration (B-2) SR Interval Change Evaluation 3.3.2.1 TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.17 Verify the RPS RESPONSE TIME is within limits There were a small number of surveillances performed for this test with one failure. The failure did not result in loss of function per the guidance of GL 91-04. Therefore, based on its data review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.3.2.2 TS 3.3.6.1, Primary Containment Isolation Instrumentation SR 3.3.6.1.7 Verify the Main Steam Line Isolation Instrumentation DC Output Relays response time allows the overall ISOLATION SYSTEM RESPONSE TIME to remain within limits.

There were a small number of surveillances performed for this test with one failure. The failure did not result in loss of function per the guidance of GL 91-04. Therefore, based on its data review, the NRC staff finds that the potential effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.3.2.3 TS 3.5.1, ECCS-Operating SR 3.5.1.14 Verify ECCS RESPONSE TIME is within limits There were a small number of surveillances performed for this test with some failures. Two of the failures were caused by two different event-driven failures (one due to wrong test equipment and the other due to a defect in circuit continuity). There was one unique failure which did not occur on repetitive basis and is not a time-based failure; therefore, it does not affect the SR extension. There was no loss of function due to the remaining two failures. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.3.2.4 TS 3.7.6, The Main Turbine Bypass System and Moisture Separator Reheater The LAR requests a revision of TS 3.7.6 by changing the interval of the following non-calibration SR from once every 18 months to once every 24 months, for a maximum interval of 30 months, including the 25 percent extension afforded by TS SR 3.0.2.

SR 3.7.6.4 Verify the TURBINE BYPASS SYSTEM RESPONSE TIME is within limits In the LAR, the licensee stated that the technical justification for the proposed changes addresses the information requested by GL 91-04. For non-calibration SRs, GL 91-04 instructs licensees to perform evaluations and confirmations as described in Section 3.1.1 of this safety evaluation to support the change in surveillance intervals to accommodate a 24-month fuel cycle.

In the LAR, the licensee provided a summary of its evaluation to address the GL 91-04 recommendations. In the LAR, the licensee stated:

SR 3.7.6.1 verifies that each main bypass valve opens at least 5% every 120 days. This provides assurance of proper operation of each bypass valve and tests the valve, operator and portions of the actuation circuitry.

The licensee reviewed the SR test history and identified no failures of the TS functions that would have been solely detected by the periodic performance of these SRs. The NRC staff confirmed this by reviewing DTE-19001, Surveillance Historical Failure Analysis in Support of a 24 Month Fuel Cycle License Amendment Request, Revision 1, dated July 1, 2019.

The NRC staff reviewed the proposed change and the Failures Report and determined that the proposed change for SR 3.7.6.4 is consistent with the intent of GL 91-04. The NRC staff finds the proposed interval extensions for the above SRs acceptable because (1) the effect on safety would be small, (2) historical data do not contradict this conclusion, and (3) no assumptions in the plant licensing basis would be invalidated as a result of the proposed changes.

3.4 Calibration Changes 3.4.1 GL 91-04 Regulatory Guidance and Licensee Evaluation GL 91-04 identifies seven steps to evaluate Calibration Changes. The licensee provided the following general evaluations regarding those seven steps.

Step #1: Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.

Licensee Evaluation of Step #1: The licensee stated that the effect of the proposed calibration SR interval changes on the associated TS instrumentation was evaluated by performing a review of the SR test history for the affected instrumentation including where appropriate an instrument drift study. In performing the historical evaluation, the licensee stated that the recorded channel calibration data for associated instruments for at least five operating cycles were retrieved. By obtaining this past recorded calibration data, the licensee stated that an acceptable basis for drawing conclusions about the expectation of satisfactory performance can be made.

In Enclosure 7, DTE-19001 of the LAR, the licensee provided the methodology used for analyzing historical instrument as-found and as-left calibration data to establish drift at the current calibration interval and to extrapolate the drift to a proposed interval. The licensee also stated that the Surveillance Failure Analysis identified no SR failures that would call into question the acceptability of the proposed extension of surveillance intervals. The licensee further stated that the drift evaluations for the Calibration SRs do not result in any changes to TS Allowable Values (AV). The licensee clarified in its September 11, 2020, letter that no digital components were evaluated using the DTE-18001 drift methodology. Drift for digital components, such as indicators and recorders was evaluated using conventional methods. The licensee further noted that the overall absence of 18-month calibration failures identified in DTE-19001 also supports a conclusion that this approach is sound.

Step #2: Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence.

Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.

Licensee Evaluation of Step #2: The licensee provided a listing of the instrument make, model, and range affected by this amendment request in Enclosure 6 of the LAR. The licensee stated that the effect of longer calibration intervals on the TS instrumentation was evaluated by performing an instrument drift study. In performing the drift study, the licensee stated that the recorded channel calibration data for associated instruments was obtained for at least five operating cycles. This historical calibration was analyzed to determine a statistically valid representation of instrument drift.

The licensee stated that the methodology used to perform the drift analysis in consistent with the methodology utilized by other utilities requesting transition to a 24-month fuel cycle. The licensee stated that the Fermi 2 methodology is based on Electric Power Research Institute (EPRI) 3002002556 (TR-103335R2), Guidelines for Instrument Calibration Extension/Reduction, Revision 2; Statistical Analysis of Instrument Calibration Data, and the licensee provided this information in Enclosure 7 of the LAR.

Step #3: Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications.

Licensee Evaluation of Step #3: The licensee stated that in accordance with the methodology described in Enclosure 7 of the LAR, the magnitude of instrument drift has been determined with a high degree of confidence and a high degree of probability (at least 95/95) for a bounding calibration interval of 30 months for each instrument make, model, and range.

For instruments not in service long enough to establish a projected drift value, or where an insufficient number of calibrations have been performed to utilize the statistical methods (i.e.,

fewer than 30 calibrations for any given group of instruments), the SR interval is proposed to be extended to a 24-month interval based on a justification obtained from analysis as presented in of the LAR.

Additionally, the licensee provided the list of affected channels by TS section, including instrument make, model, and range in Enclosure 6 of the LAR.

Step #4: Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints. If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.

Licensee Evaluation of Step #4: The licensee stated that the projected 30-month drift values were compared to the design allowances as calculated in the associated instrument setpoint analyses. The projected drift values were incorporated in to the setpoint calculations, and the analysis of the setpoint, allowable vale, and/or analytical limit was reviewed. The licensee

stated that the setpoint calculations were revised, as necessary, to reflect appropriate drift values. The licensee stated that the setpoint calculation revisions were performed in accordance with GE Hitachi Nuclear Entergy report NEDC-31336P-A, General Electric Instrument Setpoint Methodology, September 1996 (non-proprietary version available at ADAMS Accession No. ML073450560). The licensee stated that the revised calculations determined that sufficient margins are maintained relative to the applicable safety analyses and confirmed that the associated instruments are capable of performing their intended design function.

The licensee stated that there are no changes required to TS Allowable Values. Calibration information is affected for some instrumentation as noted in Enclosure 5 of the LAR. The affected calibration surveillance procedures will be revised as part of implementation prior to the first 24-month cycle of operation.

Step #5: Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to affect a safe shutdown with the associated information.

Licensee Evaluation of Step #5: The licensee stated that Enclosure 5 of the LAR discusses the evaluation of the impact of drift on instrument setpoint and uncertainty calculations associated with increasing the calibration interval from 18 to 24 months and that this evaluation includes instrumentation used for safe shutdown. The revised setpoint and uncertainty calculations change calibration information if needed to accommodate 24-month calibration intervals. The changes in calibration information provide assurance that the instrumentation will perform with the required accuracy to effect a safe shutdown. The licensee stated that the calibration information is implemented through plant calibration procedures and that the affected calibration surveillance procedures will be revised as part of implantation, prior to the first 24-month cycle of operation.

Step #6: Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant SR procedures for channel checks, channel functional tests, and channel calibrations.

Licensee Evaluation of Step #6: The licensee stated that as discussed in the evaluation of Step #5, the required setpoint and uncertainty calculations result in changes to calibration information which are implemented through plant calibration procedures. The affected calibration surveillance procedures will be revised as part of implementation, prior to the first 24-month cycle of operation.

Additionally, the licensee stated that existing plant processes ensure that the conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests and channel calibrations.

Step #7: Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.

Licensee Evaluation of Step #7: The licensee stated that instruments with TS calibration SR intervals extended to 24 months will be monitored and trended in accordance with station procedures including recording of as-found and as-left calibration data.

The licensee also stated that as required by plant procedures, out-of-tolerance conditions are entered into the corrective action program and are evaluated and trended. This approach will identify occurrences of instruments found outside of their allowable value and instruments whose performance is not as assumed in the drift or setpoint analysis. The licensee stated that when the as-found conditions are outside the allowable value, an evaluation will be performed in accordance with the station corrective action program to evaluate the effect, if any, on plant safety.

The NRC staff finds the explanation of the seven steps above acceptable per the guidance of GL 91-04. The justification for each SR is explained below.

3.4.2 Calibration SR Interval Changes Evaluation 3.4.2.1 TS 3.3.3.1, Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.14 Perform CHANNEL CALIBRATION SR 3.3.1.1.16 Verify Turbine Stop Valve-Closure and Turbine Control Valves Fast Closure Functions are not bypassed when THERMAL POWER is 29.5% RTP A number of surveillances were performed for SR 3.3.1.1.14. A few failures were noted related to limit switch out of tolerance and transmitter tolerances exceeding the allowable tolerances value and all were calibrated within tolerance. None of them caused a loss of function. There was one additional failure of a transmitter after its functional check when adjusting a multi-turn potentiometer which was replaced. There was no loss of safety function. There was a hardware failure in one transmitter not related to its safety function due to a signal conditioner problem and it was replaced.

There were a small number of surveillances performed related to SR 3.3.1.1.16 with only one indicator needle sticking, which had no effect on safety.

Based on its review, the NRC staff accepts that the reduction in safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.2 TS 3.3.2.2, Feedwater and Main Turbine High Level Trip Instrumentation SR 3.3.2.2.3 Perform CHANNEL CALIBRATION. The Allowable Value shall be 219 inches There were a small number of surveillances performed related to SR 3.3.2.2.3 with a few failures. Three failures were related to transmitter out of tolerances which were successfully calibrated to be within the tolerances. One failure was due to a trip unit failure which was non-repetitive and not time based. None of the failures caused a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.3 TS 3.3.3.1, Post Accident Monitoring (PAM) Instrumentation SR 3.3.3.1.2 Perform CHANNEL CALIBRATION There were a large number of SR surveillances performed related to SR 3.3.3.1.2 with a few failures. Some of the failures are event-driven while others are due to different reasons.

However, none of the failures caused a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.4 TS 3.3.3.2, Remote Shutdown System SR 3.3.3.2.3 Perform CHANNEL CALIBRATION There were a small number of surveillances performed related to SR 3.3.3.2.3 with a few failures. Two failures were due to stuck indicators. The indicators are not required for operability. One failure was due to the recorder but the indicator was operational. The recorder was replaced. None of the failures caused a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.5 TS 3.3.4.1, Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation SR 3.3.4.1.3 Perform CHANNEL CALIBRATION. The Allowable Values should be:

o a. Reactor Vessel Water Level - Low Low, Level 2: 103.8 inches; and o b. Reactor Pressure Vessel High: 1153 psig There were a small number of surveillances performed related to SR 3.3.4.1.3 with one failure caused by a bad indicator. The failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.6 TS 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation SR 3.3.5.1.4 Perform CHANNEL CALIBRATION There were a large number of surveillances performed related to SR 3.3.5.1.4 with a few failures. Some of the failures are due to indicator failures and some are calibration failures.

However, none of the failures caused a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.7 TS 3.3.5.2, Reactor Core Isolation Cooling (RCIC) System Instrumentation SR 3.3.5.2.4 Perform CHANNEL CALIBRATION There were a small number of surveillances performed related to SR 3.3.5.2.4 with two transmitters failures due to out of tolerance during calibration but were calibrated successfully within the tolerance range. One failure was due to a damaged transmitter vent side cap which is only used during calibration and had no effect on its safety function. One failure was reported due to a damaged indicator, which was replaced. The transmitter, however, was found within

calibration. The failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.8 TS 3.3.6.1, Primary Containment Isolation Instruments SR 3.3.6.1.4 Perform CHANNEL CALIBRATION There were a very large number of surveillances performed related to SR 3.3.6.1.4 with a few failures. Many failures are related to out of tolerance readings which were successfully calibrated and did not cause a loss of function. Some of the failures were one of a kind but did not cause a loss of function. There were some indication failures and one maintenance failure but none of the caused a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.9 TS 3.3.6.2, Secondary Containment Isolation Instrumentation SR 3.3.6.2.4 Perform CHANNEL CALIBRATION There were a small number of surveillances performed related to SR 3.3.6.2.4 with two calibration failures and one event-driven failure which were not related to SR extension. The failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.10 TS 3.3.6.3, Low-Low Set (LLS) Instrumentation SR 3.3.6.3.3 Perform CHANNEL CALIBRATION There were a small number of surveillances performed related to SR 3.3.6.3.3 with two calibration failures and one event-driven failure which were not related to SR extension. The failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.11 TS 3.3.7.1, Control Room Emergency Filtration (CREF) System Instrumentation SR 3.3.7.1.5 Perform CHANNEL CALIBRATION There were a small number of surveillances performed related to SR 3.3.7.1.5 with two calibration failures and one event-driven failure which were not related to SR extension. The failures did not cause a loss of function. Based on the above review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.12 TS 3.3.7.2, Mechanical Vacuum Pump (MVP) Trip Instrumentation SR 3.3.7.2.3 Perform CHANNEL CALIBRATION. The Allowable Value shall be 3.6 x full power background There were a small number of surveillances performed related to SR 3.3.7.2.3 with one failure attributed to the recorder which is not required for operability. The failures did not cause a loss

of function. Based on its review, the NRC staff finds that the effect in safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.13 TS 3.3.7.3, Gland Seal Exhauster (GSE) Trip Instrumentation SR 3.3.7.3.3 Perform CHANNEL CALIBRATION. The Allowable Value shall be 3.6 x full power background There were a small number of surveillances performed related to SR 3.3.7.3.3 with one failure attributed to the recorder which is not required for operability. The failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.14 TS 3.3.8.2, Reactor Protection System (RPS) Electric Power Monitoring SR 3.3.8.2.2 Perform CHANNEL CALIBRATION. The Allowable Values shall be:

o Overvoltage 132 V o Undervoltage 108 V o Underfrequency 57 Hz There were a small number of surveillances performed related to SR 3.3.8.2.2 with a few failures. The failures were related to under frequency, over voltage and a failure of a keylock switch. These failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.4.2.15 TS 3.4.6, RCS Leakage Detection Instrumentation SR 3.4.6.3 Perform a CHANNEL CALIBRATION of required leakage detection instrumentation.

o a. Drywell floor drain sump flow monitoring system; o b. The primary containment atmosphere gaseous radioactivity monitoring system; and o c. Drywell floor drain sump level monitoring system.

There were a small number of surveillances performed related to SR 3.4.6.3 with one out of calibration failure and one event-driven failure pertaining to indication and not loss of function.

The failures did not cause a loss of function. Based on its review, the NRC staff finds that the effect on safety is very small and the SR extension is acceptable based on the guidance of GL 91-04.

3.5 TECHNICAL CONCLUSION The licensee provided an explanation for non-calibration-related SR changes and calibration-related SR changes. The licensees positions for these SR changes were reviewed and found acceptable by NRC staff. The justification for previously documented failures would have no effect on safety with the proposed SR interval was found to be consistent with the guidance of GL 91-04. The failure report was reviewed by the staff and the failure report data were found to be acceptable by the staff per the guidance of GL 91-04. The NRC staff finds the extension of surveillance intervals from 18 months to 24 months is acceptable and the changes

proposed in the LAR continue to meet 10 CFR 50.36(c)(5) by providing administrative controls necessary to assure operation of the facility in a safe manner.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment on December 16, 2020. The State official had no comments as confirmed in an e-mail message dated December 18, 2020.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the 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 (85 FR 7790), 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.

6.0 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 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: D. Scully, G. Singh, K. Nguyen, C. Tilton Date of Issuance: February 24, 2021

v t e Letter Sequence Approval
EPID:L-2019-LLA-0249, TSTF-425, TSTF-545 (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions 12 August 2020 Answers 11 September 2020 Results Approval, Approval Other: ML20094G814
MONTHYEAR2020-06-23 [Table View]

ML20358A155

Text

SUBJECT:

Dear Mr. Dietrich:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 Background

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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