ML23241B016

Exigent License Amendment Request for Additional Information RAI-12 (EPID L-2023-LLA-0112) (Email)

ML23241B016
Person / Time
Site:	Fermi
Issue date:	08/24/2023
From:	Shilpa Arora Plant Licensing Branch III
To:	Frank E DTE Electric Company
Arora S
References
EPID L-2023-LLA-0112
Download: ML23241B016 (1)

Text

Surinder Arora

From: Surinder Arora Sent: Thursday, August 24, 2023 4:07 PM To: Eric Frank Cc: Roxanne Vonhabsburg; Scott Wall; Jeff Whited

Subject:

One Additional RAI Question

Importance: High

Eric,

The staff has the following additional RAI question. Please try to include your response with the previous RAI questions, if possible. Otherwise, please respond by Monday, August 28, 2023.

Thanks, Surinder

Surinder Arora, P. E.

Project Manager, Fermi 2 and Dresden 2 & 3 NRR/DORL/LPL3 surinder.arora@nrc.gov 301-415-1421

REQUEST FOR ADDITIONAL INFORMATION CHANGES TO TS 3.7.2, EMERGENCY EQUIPMENT COOLING WATER (EECW)/ EMERGENCY EQUIPMENT SERVICE WATER (EESW) SYSTEM AND ULTIMATE HEAT SINK (UHS)

(EPID L-2023-LLA-0112)

FERMI 2 DTE ELECTRIC COMPANY DOCKET NO. 50-341

Background:

By (UHS)|letter dated August 10, 2023]] (ADAMS Accession No. ML23222A037), DTE Electric Company (the Licensee) submitted an Exigent License Amendment Request (LAR) for TS 3.7.2, to allow for a one-time extension of the Condition A Completion Time to allow repair of the Division I Mechanical Draft Cooling Tower (MDCT) A and C fan pedestals, while online. Section 2.2 of Enclosure 1 of the LAR, titled, Circumstances Establishing Need for the Proposed Exigent Amendment states that this request provides justification that obtaining an extension of Completion Time to repair Division I MDCT fan pedestals online instead of waiting until the next refueling outage. Based on this justification, DTE requested that the amendment request be treated as an exigent circumstance pursuant to 10 CFR 50.91(a)(6).

Regulatory Basis

Title 10 Code of Federal Regulations (CFR) Part 50, Section 50.91, Notice for public comment; State consultation, states that under 10 CFR 2.105, the NRC may provide notification of the proposed issuance of an amendment: (1) through an individual notice in the Federal Register, (2) by inclusion of a notice in the periodic Federal Register notice of proposed actions, or (3) by publishing both such notices.

1 The regulation in 10 CFR 50.91(a)(2)(ii) states that each notice will (1) contain the staffs proposed determination under the standards in 10 CFR 50.92 (i.e., proposed no significant hazards consideration (NSHC) determination); (2) provide a brief description of the amendment and the facility involved; (3) solicit comments on the proposed NSHC determination; and (4) provide for a 30-day comment period. For biweekly notices, item 3 (solicit comments) and item 4 (provide 30-day comment period) are included in the boilerplate language in the Federal Register notice (i.e., text preceding the plant-specific notices). Per 10 CFR 50.91(a)(2)(iii), the comment period will begin on the day after the date of the publication of the first notice, and normally, the amendment will not be granted until after this comment period expires.

If a licensee believes that a proposed amendment is needed in a timeframe that does not permit the NRC staff to publish a Federal Register notice allowing for the normal 30-day period for public comment on the proposed NSHC determination, the licensee may apply for the amendment under exigent circumstances using the provisions of 10 CFR 50.91(a)(6).

RAI Question:

12. DTEs amendment request letter dated August10, 2023, states, This request is to enable DTE to perform this maintenance online and avoid a potential unnecessary plant shutdown or need for enforcement discretion without a corresponding health and safety benefit.

Given that Fermi 2 is currently in a forced shut down, to address the pipe leakage in the drywell, (1) explain why maintenance of the MDCT A and C fan pedestals cannot be performed in the present situation; and (2) provide updated justification to support an exigent request.

2