ML23229A012
| ML23229A012 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/17/2023 |
| From: | Shilpa Arora NRC/NRR/DORL/LPL3 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| EPID L-2022-LLA-0113 | |
| Download: ML23229A012 (1) | |
Text
August 17, 2023 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 UNIT 2 - ISSUANCE OF AMENDMENT NO. 224 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-568, REVISE APPLICABILITY OF BWR TS 3.6.2.5 AND TS 3.6.3.2 (EMERGENCY CIRCUMSTANCES) (EPID L-2022-LLA-0113)
Dear Mr. Dietrich:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 224 to Renewed Facility Operating License No. NPF-43, for Fermi, Unit 2 (Fermi 2). This amendment is in response to your application dated August 15, 2023.
The amendment revises Fermi 2 Technical Specification (TS) 3.6.3.1, Primary Containment Oxygen Concentration to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR [boiling-water reactor]/4 TS 3.6.2.5 and TS 3.6.3.2.
The license amendment is issued under emergency circumstances pursuant to the provisions of paragraph 50.91(a)(5) of Title 10 of the Code of Federal Regulations because failure to act in a timely way would result in the derating or shutdown of Fermi 2. This amendment will provide Fermi 2 the ability to address an emergent plant condition related to unidentified leakage within the primary containment.
The NRCs related safety evaluation is also enclosed and describes the emergency circumstances under which the amendment is issued and the final no significant hazards determination. A Notice of Issuance addressing the final no significant hazards determination and opportunity for a hearing associated with the emergency circumstances 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. 224 to NPF-43
- 2. Safety Evaluation cc: Listserv
DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 224 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 June 5, 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.
- 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. 224, 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 1 day of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jeffrey A. Whited, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 17, 2023 Jeffrey A.
Whited Digitally signed by Jeffrey A. Whited Date: 2023.08.17 17:22:02 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 224 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 Licenses 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.
INSERT REMOVE Technical Specifications Replace the following page of the Appendix A, Technical Specifications with the attached revised page. The revised page is identified by amendment number and contain marginal lines indicating the areas of change.
REMOVE INSERT 3.6.3.1 3.6.3.1 Renewed License No. NPF-43 Amendment No. 224 (2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 224, 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.
FERMI - UNIT 2 3.6-39 Amendment No. 134, 159, 201, 224 Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Oxygen Concentration LCO 3.6.3.1 The primary containment oxygen concentration shall be
< 4.0 volume percent.
APPLICABILITY:
MODES 1 and 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment oxygen concentration not within limit.
A.1
NOTE---------
LCO 3.0.4.c is applicable.
Restore oxygen concentration to within limit.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1.1 Verify primary containment oxygen concentration is within limits.
In accordance with the Surveillance Frequency Control Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 224 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341
1.0 INTRODUCTION
By application dated August 15, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23227A221), as supplemented by email on August 16, 2023 (ML23228A147), DTE (the licensee) submitted a license amendment request for Fermi Unit 2 (Fermi 2).
The proposed changes would revise Technical Specification (TS) 3.6.3.1, Primary Containment Oxygen Concentration. The proposed changes would simplify and clarify the applicability statements, which, if misapplied, could conflict with the corresponding required actions. The proposed changes would also remove the undefined term reactor shutdown and provide adequate terminal actions.
The proposed amendments are based on Technical Specifications Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR [boiling-water reactor]/4 TS 3.6.2.5 and TS 3.6.3.2 (ML19141A122). The U.S. Nuclear Regulatory Commission (NRC, the Commission) approved TSTF-568, Revision 2, by letter dated December 17, 2019 (ML19325C444). The NRC staffs safety evaluation (SE) of the traveler was enclosed with the NRC staffs approval letter.
The licensee has proposed variations from the TS changes described in TSTF-568, Revision 2.
The variations are described in section 2.2.2 of this safety evaluation (SE) and evaluated in section 3.0.
The proposed change to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure, in TSTF-568 is not applicable to Fermi 2; therefore, the licensee did not include it in the application.
The email supplement provided a revised Technical Specification (TS) clean page to ensure the Fermi 2 TSs were consistent with the revision as shown in TSTF-568.
2.0 REGULATORY EVALUATION
2.1 Description of Structures, Systems, Components, and Technical Specification Sections 2.1.1 Current Containment Oxygen Concentration Requirement Title 10 of the Code of Federal Regulations (10 CFR) section 50.44, Combustible gas control for nuclear power reactors, states that for a plant with an inerted containment atmosphere, the oxygen concentration in the primary containment is required to be maintained below 4 percent by volume during normal plant operation. This requirement ensures that an accident that produces hydrogen does not result in a combustible mixture inside the primary containment.
Current TS 3.6.3.1 requires primary containment oxygen concentration to be less than 4 percent by volume when in Mode 1 during the period from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the thermal power exceeds 15 percent reactor thermal power (RTP) following startup and to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing the RTP to less than 15 percent RTP during the next reactor shutdown. TSTF-568, Revision 2, states that the 24-hour allowance above 15 percent RTP is provided in the primary containment oxygen concentration specification to delay inerting the primary containment in a plant startup and to accelerate de-inerting for a plant shutdown. This allowance is provided so that plant personnel can safely enter the primary containment without breathing apparatus to perform the needed inspections and maintenance adjustments.
The containment consists of a drywell (in the shape of an inverted light bulb), a suppression chamber (in the shape of a torus), and a network of vents that extend radially outward and downward from the drywell to the suppression chamber. The containment atmosphere is inerted with nitrogen gas during normal operation to prevent a combustible mixture of hydrogen and oxygen from forming during accident conditions. Long-term control of post loss-of-coolant accident (LOCA) hydrogen gas concentration is accomplished by adding additional nitrogen gas and then venting the primary containment through the standby gas treatment system.
2.1.2 Pressure Suppression Following a LOCA The drywell is immediately pressurized when a postulated line break occurs within the primary containment. As drywell pressure increases, drywell atmosphere (primarily nitrogen gas) and steam are blown down through the vents into the suppression pool via the downcomers. The steam condenses in the suppression pool, which suppresses the peak pressure in the drywell.
Non-condensable gases discharged into the suppression pool collect in the free air volume of the suppression chamber, increasing the suppression chamber pressure. As steam is condensed in the suppression pool and on the structures in the drywell, the pressure decreases until the suppression chamber pressure exceeds the drywell pressure and the suppression chamber-drywell vacuum breakers open and vent non-condensable gases back into the drywell.
2.1.3 TS 3.6.3.1, Primary Containment Oxygen Concentration The primary containment oxygen concentration is maintained to ensure that a LOCA - a postulated event that produces hydrogen, does not result in a combustible mixture inside primary containment. The TS requires that the primary containment oxygen concentration be maintained below 4 percent volume. Below this concentration, the primary containment is inerted and no combustion can occur.
2.2 Description of Proposed TS Changes 2.2.1 Proposed Changes to TS 3.6.3.1, Primary Containment Oxygen Concentration The applicability of TS 3.6.3.1 would be revised as shown below:
Current TS Applicability Proposed TS Applicability MODE 1 during the time period:
- a. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is > 15% RTP following startup, to
- b. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15%
RTP prior to the next reactor shutdown.
MODES 1 and 2.
Required Actions A.1 and B.1 and their associated completion times would be revised as shown below:
The NRC staff understands the overall purpose of the proposed changes is to simplify the applicability statement by adding a new note and revising the completion time. This change provides operational flexibility and requires that the plant be in Mode 3 if oxygen concentration cannot be restored to within limits.
2.2.2 Variations The proposed change to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure, in TSTF-568 is not applicable to Fermi 2 and is not included.
The Fermi 2 TSs use different numbering than the Standard Technical Specification (STS) on which TSTF-568 was based. Specifically, STS 3.6.3.2, Primary Containment Oxygen Concentration, is the Fermi 2 TS 3.6.3.1, Primary Containment Oxygen Concentration. This difference does not affect the applicability of TSTF-568 to the Fermi 2 TSs.
2.3 Applicable Regulatory Requirements and Guidance Section 50.90, Application for amendment of license, construction permit, or early site permit, of 10 CFR requires that whenever a licensee desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired and following, as far as applicable, the form prescribed for original applications.
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards for licenses and construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
Section 50.36, Technical specifications, of 10 CFR establishes the regulatory requirements related to the content of TSs. Section 50.36(a)(1) of 10 CFR requires an application for an operating license to include proposed TSs. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, must also be included in the application, but shall not become part of the TSs.
The regulation in 10 CFR 50.36(b) states:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.
The categories of items required to be in the TSs are listed in 10 CFR 50.36(c).
In accordance with 10 CFR 50.36(c)(2), limiting conditions for operation (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When LCOs are not met, the licensee must shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. In addition, 10 CFR 50.36(c)(2)(ii)(B) requires a TS LCO of a nuclear reactor must be established for a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The regulation in 10 CFR 50.44(b)(2)(i) states, All boiling water reactors with Mark I or Mark II type containments must have an inerted atmosphere. Section 50.44(a)(1) of 10 CFR defines inerted atmosphere as a containment atmosphere with less than 4 percent of oxygen by volume.
NUREG 0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition (SRP), chapter 6.2.1.1.C, Revision 7, Pressure-Suppression Type BWR Containments, dated March 2007 (ML063600403), states:
The acceptability of pool dynamic loads for plants with Mark I containments is based on conformance with NRC acceptance criteria found in NUREG-0661.
The NRC staffs guidance for the review of TSs is in section 16.0, Revision 3, Technical Specifications, of the SRP, dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STS for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable reference STS (i.e., the current STS), as modified by NRC-approved travelers. The STS applicable to Fermi 2 is NUREG-1433, Revision 5.0, Standard Technical Specifications, General Electric BWR/4 Plant, Volume 1, Specifications, and Volume 2, Bases, dated September 2021 (ML21272A357 and ML21272A358, respectively).
3.0 TECHNICAL EVALUATION
The proposed amendments are based on NRC-approved TSTF-568, Revision 2. The NRC staff also considered the regulations and guidance discussed in section 2.3 of this SE in its review.
3.1 Proposed Changes to TS 3.6.3.1 3.1.1 Proposed Changes in the Applicability In accordance with NRC-approved TSTF-568, Revision 2, the licensee proposed to expand the applicability of this LCO to Modes 1 and 2 without exception. The NRC staff finds the proposed change acceptable because it is more restrictive since an unlikely LOCA event leading to a degraded core that could produce hydrogen has the highest probability of occurrence during Modes 1 and 2 conditions.
3.1.2 Proposed Changes in Required Action A.1 In accordance with NRC-approved TSTF-568, Revision 2, the licensee proposed to add the following note to Required Action A.1: LCO 3.0.4.c is applicable. TS LCO 3.0.4.c allows entering the mode of applicability of TS LCO 3.6.3.1 with the LCO not met. Therefore, the proposed change would permit entry into Modes 1 and 2 with primary containment oxygen concentration higher than the required limit. The NRC staff concludes the addition of the note is acceptable because it clarifies and simplifies the intent of the current TS LCO 3.6.3.1 applicability statement a of allowing startup operation with the LCO not met.
3.1.3 Proposed Changes in the Completion Time of Condition A In accordance with NRC-approved TSTF-568, Revision 2, the licensee proposed changing the completion time from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on the following sequence of operations:
allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to de-inert the containment to permit safe personnel access, allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the required maintenance or repair work, and allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to inert the containment.
The NRC staff determined that the presence of a higher oxygen concentration for the 72-hour completion time is appropriate, considering the low safety significance of the change for potential accidents and the additional restrictions and conservatisms in the revised applicability.
3.1.4 Proposed Changes in Required Action B.1 In accordance with NRC-approved TSTF-568, Revision 2, the licensee proposed to change the applicability statement of TS LCO 3.6.3.1 to Modes 1 and 2. If the oxygen concentration cannot be restored within the required limit and completion time of Required Action A.1, the reactor
shall be brought to Mode 3. In this mode, the reactor would be in a hot shutdown condition (control rods fully inserted) with all reactor vessel head bolts fully tensioned.
The NRC staff recognizes that on entering Mode 3, the decay heat is rapidly decreasing. Steam is initially available for operating the reactor core isolation cooling/high-pressure coolant injection steam turbine-driven pumps until the reactor pressure, and thus, water temperature, is substantially reduced. As the decay heat continues to decrease, operators have increased time and options for achieving adequate water injection using the low-pressure emergency core cooling system to avoid core damage and associated generation of combustible gas. Therefore, the occurrence of a LOCA leading to degraded core is highly unlikely in Mode 3.
The NRC staff finds the proposed change in Required Action B.1 acceptable because it provides a more appropriate terminal action since it requires the plant to be placed in a mode in which the LCO does not apply, and the oxygen concentration limit is no longer required. The previous terminal action allowed an indefinite period of operation at 15 percent RTP.
Therefore, the NRC staff concluded the proposed change is acceptable because it continues to protect containment integrity and meets 10 CFR 50.36(c)(2) by providing the lowest functional capability of equipment required for safe operation of the plant.
3.1.5 Proposed Changes in the Completion Time of Condition B In accordance with NRC-approved TSTF-568, Revision 2, the licensee proposed to change the Condition B completion time from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, stating that 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a reasonable time to reduce reactor power from full power conditions to Mode 3 in an orderly manner and without challenging plant systems. The proposed change from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for bringing the reactor to a hot shutdown condition from full power is acceptable to the NRC staff because it is not a significant change and is based on industry operating experience.
3.1.6 Variations The variations are described in section 2.2.2 of this SE. The NRC staff finds these variations are acceptable because the variations do not substantively alter TS requirements.
3.1.7 Technical Conclusion for Proposed Changes to TS 3.6.3.1 The NRC staff concludes the proposed changes in the applicability statement for TS 3.6.3.1 are acceptable since they are more restrictive, as the applicability now extends to Modes 1 and 2 without exception. Therefore, the changes proposed in TS 3.6.3.1 are acceptable and continue to meet 10 CFR 50.36(c)(2).
4.0 EMERGENCY SITUATION The NRCs regulations in 10 CFR 50.91(a)(5) state that where the NRC finds that an emergency situation exists, in that, failure to act in a timely way would result in derating or shutdown of a nuclear power plant, or in prevention of either resumption of operation or of increase in power output up to the plants licensed power level, the NRC may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment. In such a situation, the NRC will publish a notice of issuance under 10 CFR 2.106, providing for opportunity for a hearing and for public comment after issuance.
In the application letter dated August 15, 2023, the licensee requested that the NRC process the proposed amendment on an emergency situation basis. The licensee stated that this request will provide them the ability to address an emergent plant condition related to unidentified leakage within primary containment. The current leakage rate is projected to approach the TS limit of 5 gallons per minute within two weeks. Implementation of this license amendment would allow additional time above 15 percent RTP to identify and correct the leakage without requiring a shutdown of the plant or operation below 15 percent RTP after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of exceeding the oxygen concentration limit.
The NRC staff reviewed the licensees basis for processing the proposed amendment as an emergency amendment (as discussed above) and determined that an emergency situation exists consistent with the provisions in 10 CFR 50.91(a)(5). Furthermore, the NRC staff determined that: (1) the licensee used its best efforts to make a timely application; (2) the licensee could not reasonably have avoided the situation; and (3) the licensee has not abused the provisions of 10 CFR 50.91(a)(5). Based on these findings, and the determination that the amendment involves no significant hazards consideration as discussed below, the NRC staff has determined that a valid need exists for issuance of the license amendment using the emergency provisions of 10 CFR 50.91(a)(5).
5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
As required by 10 CFR 50.91(a), by letter dated August15, 2023, the licensee provided its analysis of the issue of no significant hazards consideration, which is presented below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.1, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the STS format and content. Primary containment oxygen concentrations are not initiators to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not affected by the proposed change.
Primary Containment Oxygen Concentrations are assumptions in the mitigation of some accidents previously evaluated. The Applicability of TS 3.6.3.1 is changed from Mode 1 when thermal power is greater than 15% to Modes 1 and 2. This expands the Applicability of the TS and will not have an effect on the consequences of an accident.
The existing Applicability exceptions are removed and replaced with a longer Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The consequences of an event that could affect the primary containment oxygen concentration are no different during the proposed Completion Time than the consequences of the same event during the existing Completion Times. A note referencing Limiting Condition for Operation (LCO) 3.0.4.c is added to the Actions to
permit entering the Applicability with the LCO not met. The note replaces the existing Applicability exceptions. This change is administrative and has no effect on the consequences of an accident.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.1, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the STS format and content. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed).
No credible new failure mechanisms, malfunctions, or accident initiators that would have been considered a design basis accident in the UFSAR are created because the Nuclear Regulatory Commission has determined that hydrogen generation is not risk significant for design basis accidents.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.1, Primary Containment Oxygen Concentration, and presents the requirements in a manner more consistent with the STS format and content. No safety limits are affected. No Limiting Conditions for Operation or Surveillance limits are affected. The Primary Containment Oxygen Concentration Technical Specification requirements assure sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants licensing basis. The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.
6.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Michigan State official was notified of the proposed issuance of the amendment on August 16, 2023. The State official had no comments.
7.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR part 20. The NRC staff has determined that the amendments involve 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. 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 amendments.
8.0 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: C. Ashley Date of issuance: August 17, 2023
ML23229A012 NRR-058 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC NAME SArora SRohrer MJardaneh DATE 8/16/23 8/17/23 8/16/23 OFFICE OGC NLO NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME DRoth JWhited SArora DATE 8/17/23 8/17/23 8/17/23