ML23243A885
| ML23243A885 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/18/2023 |
| From: | Shilpa Arora Plant Licensing Branch III |
| To: | Peter Dietrich DTE Electric Company |
| Arora S | |
| References | |
| EPID L-2022-LLA-0112 | |
| Download: ML23243A885 (1) | |
Text
September 18, 2023 Mr. Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166
SUBJECT:
FERMI UNIT 2 - ISSUANCE OF AMENDMENT NO. 225 REGARDING REVISION OF TECHNICAL SPECIFICATIONS 3.7.2, EMERGENCY EQUIPMENT COOLING WATER (EECW)/EMERGENCY EQUIPMENT SERVICE WATER (EESW) SYSTEM AND ULTIMATE HEAT SINK (UHS)
(EXIGENT CIRCUMSTANCES) (EPID L-2022-LLA-0112)
Dear Mr. Dietrich:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 225 to Renewed Facility Operating License No. NPF-43, for Fermi, Unit 2 (Fermi 2). This amendment is in response to your application dated August 10, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23222A037), as supplemented by letters dated August 25, 2023 (ML23237B419 and ML23237B402), August 30, 2023 (ML23242A189), and September 11, 2023 (ML23254A157).
The amendment revises Technical Specification 3.7.2, Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS) to allow for a one-time extension of the Condition A Completion Time to perform repairs to the Division I Mechanical Draft Cooling Tower A and C fan pedestals.
The license amendment is issued under exigent circumstances pursuant to the provisions of Paragraph 50.91(a)(6) of title 10 of the Code of Federal Regulations to allow DTE Electric Company to perform fan pedestal maintenance online and avoid a potential plant shutdown for this work.
P. Dietrich A copy of the related safety evaluation is also enclosed. The safety evaluation describes the exigent circumstances under which the amendment is issued. 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. 225 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. 225 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 August 10, 2023, As supplemented by letters dated August 25, 2023, August 30, 2023, and September 11, 2023, 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. 225, 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 2 days of the date of issuance. The one-time extension requested in the amendment request will expire at 2359 on November 19, 2023.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jeffrey Jeffrey A. A. Whited Date: 2023.09.18 Whited 15:07:34 -04'00' 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: September 18, 2023
ATTACHMENT TO LICENSE AMENDMENT NO. 225 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 contains marginal lines indicating the areas of change.
REMOVE INSERT 3.7-3 3.7-3
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, 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 225
EECW/EESW System and UHS 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)
LCO 3.7.2 Two EECW/EESW subsystems and UHS shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTES----------------------------------
- 1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating," for diesel generator made inoperable by UHS.
- 2. Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by EECW/EESW or UHS.
CONDITION REQUIRED ACTION COMPLETION TIME A. One reservoir A.1 Restore reservoir to 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s*
inoperable. OPERABLE status.
B. One EECW/EESW B.1 Restore the EECW/EESW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem inoperable subsystem to OPERABLE for reasons other than status.
Condition A.
(continued)
- The 72-hour Completion Time is extended to 7 days one time for each of the Division I MDCT fan pedestals (A and C) to allow repair online during Cycle 22, regardless of whether maintenance is completed during the attempt. This proposed completion time extension and associated compensatory measures are documented in LAR NRC-23-0050. This completion time extension will expire at 2359 on November 19, 2023.
FERMI - UNIT 2 3.7-3 Amendment No. 134, 209, 225
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 225 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341
1.0 INTRODUCTION
By application dated August 10, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23222A037), as supplemented by letters dated August 25, 2023 (ML23237B419 and ML23237B402), August 30, 2023 (ML23242A189), and September 11, 2023 (ML23254A157), DTE Electric Company (DTE or the licensee), requested changes to the technical specifications (TSs) for Fermi 2.
The proposed changes would modify the TS to include a footnote to TS 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), Condition A, One reservoir inoperable, Required Action A.1, Restore reservoir to OPERABLE status, with a Completion Time (CT) of 72-hours. The proposed footnote would allow a CT for up to 7-days to repair the Division 1 mechanical draft cooling tower (MDCT) A and C fan pedestals during the current operating Cycle 22.
The supplements dated August 25, 2023, August 30, 2023, and September 11, 2023, 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, or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on September 1, 2023 (88 FR 60504).
2.0 EXIGENT CIRCUMSTANCES
The NRCs regulations contain provisions for issuance of amendments when the usual 30-day public comment period cannot be met. These provisions are applicable under exigent circumstances. Consistent with the requirements in 10 CFR 50.91(a)(6), exigent circumstances exist when: (1) a licensee and the NRC must act quickly; (2) time does not permit the NRC to publish a Federal Register notice allowing 30 days for prior public comment; and (3) the NRC determines that the amendment involves no significant hazards consideration. As discussed in Enclosure 2
the licensees application dated August 10, 2023, the licensee requested that the NRC process the proposed amendment on an exigent basis.
Specifically, in the license amendment request (LAR), Enclosure 1, provides the following circumstances establishing the need for an exigent amendment pursuant to title 10 of the Code of Federal Regulations 10 CFR Section 50.91(a)(6):
On July 18, 2023, at 0424 [hours] Eastern Daylight Time (EDT), the Division II Residual Heat Removal Service Water (RHRSW) Mechanical Draft Cooling Tower (MDCT) fan D tripped due to high vibrations caused by a degraded, non-conforming gearbox pedestal. Corrective actions were required to correct the conditions and restore the equipment to an operable status, using extra time allowed by the Notice of Enforcement Discretion (NOED) requested by our letter NRC-23-0049 and verbally approved by the NRC on July 20, 2023. During that time the UHS was declared inoperable. During the extent of condition review, it was discovered that the MDCT A and C fan pedestals were also degraded and non-conforming, but remained Operable, and also in need of similar repair. This request is being made to be proactive and repair the Division I MDCT A and C fan pedestals. Additionally, this request provides justification that obtaining an extension of the Completion Time to repair the Division I MDCT fan pedestals online instead of waiting until the next refueling outage. The proposed amendment is being requested due to an exigent circumstance pursuant to 10 CFR 50.91(a)(6).
Under the provisions in 10 CFR 50.91(a)(6), the NRC notifies the public of the licensees exigent request in one of two ways: (1) by issuing a Federal Register notice providing an opportunity for hearing and allowing at least 2 weeks from the date of the notice for prior public comments; or (2) by using local media to provide reasonable notice to the public in the area surrounding the licensees facility. In this case, the NRC staff issued a Federal Register notice on September 1, 2023 (88 FR 60504) and no public comments were received.
Based on the above circumstances, the NRC staff finds that the licensee made a timely application for the proposed amendment following identification of the issue. In addition, the NRC staff finds that the licensee could not avoid the exigency without a significant impact to the outage schedule, if the proposed repairs were carried out during the plant shutdown. 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 exigent provisions of 10 CFR 50.91(a)(6).
3.0 REGULATORY EVALUATION
The regulatory requirements and guidance on which the NRC staff bases its acceptance of risk-informed allowed outage time, (i.e., CT) extension requests are:
Regulatory Guide (RG) 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, dated January 2018 (ML17317A256), describes a risk-informed approach acceptable to the NRC for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This RG also provides risk-acceptance guidelines for evaluating the results of such evaluations.
RG 1.177, Revision 2, An Approach for Plant-Specific, Risk Informed Decisionmaking:
Technical Specifications, dated January 2021 (ML20164A034), describes an acceptable risk informed approach for assessing TS changes, specifically changes to CTs. This RG also provides risk acceptance guidelines for evaluating the results of such assessments.
Section C.2.4, Acceptance Guidelines for Technical Specification Changes, of RG 1.177 provides the following three-tiered TS acceptance guidelines for evaluating the risk associated with CT changes:
The licensee has demonstrated that the TS CT change has only a small quantitative impact on plant risk. An ICCDP [incremental conditional core damage probability] of less than 1x10-6 and an incremental conditional large early release probability of less than 1x10-7 are considered small for a single TS condition entry (Tier 1).
The licensee has demonstrated that there are appropriate restrictions on dominant risk- significant configurations associated with the change (Tier 2).
The licensee has implemented a risk-informed plant configuration control program, including procedures to use, maintain, and control such a program (Tier 3).
RG 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated March 2009 (ML090410014), describes one acceptable approach for determining whether the quality of the probabilistic risk assessment (PRA),
in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decisionmaking for light water reactors.
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition, (SRP) Chapter 16, Section 16.1, Risk-Informed Decision Making: Technical Specifications dated March 27, 2007 (ML070380228) contains five key principles of the NRC staff's philosophy of risk-informed decision making. They are:
- 1. the proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change; 2 . the proposed change is consistent with the defense-in-depth (DID) concept;
- 3. the proposed change maintains sufficient safety margins;
- 4. when proposed changes result in an increase in core damage frequency (CDF) or risk, the increases should be small and consistent with the intent of the Commission's Safety Goal Policy Statement. (Safety Goals for the Operations of Nuclear Power Plants; Policy Statement, 51 FR 30028 (Aug. 4, 1986))
- 5. the impact of the proposed change should be monitored using performance measurement strategies.
NUREG-0800, SRP, Section 19.1, Determining the Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment Requests after Initial Fuel Load, (ML12193A107) provides guidance on evaluating PRA technical adequacy.
NUREG-0800, SRP, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, (ML071700658) provides general guidance for evaluating the technical basis for proposed risk-informed changes.
3.1 System Description and Operation The Fermi 2, Updated Safety Analysis Report (ML22325A160) (USAR), provides description of the UHS in Section 9.2.5, Ultimate Heat Sink. The UHS is provided by water supply in the form of residual heat removal (RHR) reservoir and a means of heat rejection in the form of MDCT.
The UHS consists of two one-half capacity reinforced concrete reservoirs each with a capacity of 3.41 X 106 gallons of water, corresponding to an elevation of 583 feet. The two reservoir divisions are connected by two redundant cross-tie lines to provide access to the combined inventory to either division of cooled equipment in the event of a failure in one of the divisions. A two-cell MDCT is located over each division reservoir. Each MDCT contains two fans, Fans A &
C (Division I) and Fans B & D (Division II).
Each MDCT is the cooling source for that divisions RHR service water (RHRSW) subsystem, and EESW subsystem, as well as the diesel generator service water pumps for that divisions emergency diesel generators (EDGs).
The RHRSW system is designed to a) remove decay heat and residual heat from the nuclear system so that refueling and nuclear system servicing can be performed, b) supplement the fuel pool cooling system with additional cooling capacity, c) remove decay heat and residual heat from the nuclear system by cooling the suppression pool water, following a postulated loss of coolant accident (LOCA), d) provide a method to flood the reactor pressure vessel (RPV), acting as a backup in the extremely unlikely event that all RHR and core spray pumps fail to operate following a postulated LOCA, and e) provide a method to flood primary containment so that the fuel can be removed from the RPV following a postulated LOCA.
The EESW is designed to provide a cooling water source for the EECW system. The system functions only during a loss of offsite power, high drywell pressure, or upon failure of the reactor building closed cooling water system.
The diesel generator service water system is designed to provide a cooling water source for the EDGs during testing and emergency operation. Diesel generator cooling water is supplied from the RHR reservoirs with each diesel generator supplied by its own pump.
The safety function of MDCTs is to support cooling of its division plant loads (one RHR heat exchanger, one EECW heat exchanger, and two EDGs).
3.2 Proposed Change The amendment requests to include the following footnote to Fermi TS 3.7.2, Condition A, CT:
- The 72-hour Completion Time is extended to 7 days one time foreach of the Division I MDCT fan pedestals (A and C) to allow repair online during Cycle 22, regardless of whether maintenance is completed during the attempt. This proposed completion time extension and associated compensatory measures are documented in LAR NRC-23-0050. This completion time extension will expire at 2359 on November 19, 2023.
3.3 Regulatory Requirements Under 10 CFR 50.90, whenever a holder of a license wishes to amend the license, including technical specifications in the license, an application for amendment must be filed, fully describing the changes desired. 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 in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
The categories of items required to be in the TSs are provided in 10 CFR Section 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs include Limiting Conditions for Operations (LCOs),
which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The remedial actions must continue to provide reasonable assurance of public health and safety.
Fermi 2 is designed in accordance with Appendix A to 10 CFR 50. The following General Design Criteria (GDC) are relevant to the design of the UHS:
GDC 2 - Design Bases for Protection Against Natural Phenomena GDC 44 - Cooling Water Regulatory Guidance NUREG-0800 SRP Section 9.2.5 (ML070550048), Ultimate Heat Sink,Section IV Evaluation Findings, states in part, that:
The applicant meets GDC 2 requirements for capability to withstand the effects of natural phenomena like earthquakes, tornadoes, tornado missiles, hurricanes, and floods. Acceptance is based on RG 1.27, [Ultimate Heat Sink for Nuclear Power Plants, Revision 3, dated November 2015 (ML14107A411)] Positions C.2 and C.3.
The applicant meets GDC 44 UHS requirements. Acceptance is based on RG 1.27, Positions C.2 and C.3; RG 1.72, [Spray Pond Piping Made from Fiberglass-Reinforced Thermosetting Resin, Revision 2, dated November 1978 (ML003740253)] Positions C.1, C.4, C.5, C.6, and C.7; and ANSI/ANS 5.1 [American National Standards Institute/
American Nuclear Society Decay Heat Power for Light Water Reactors, October 1979].
4.0 TECHNICAL EVALUATION
4.1 Plant Systems Evaluation The UHS is provided by the RHR complex, which contains the RHRSW system, the EESW, the diesel generator service water system, the MDCTs, the emergency alternating current power system (diesel generators), and the reservoir. The reservoir contains two divisions and a two-
cell MDCT located over each reservoir division. Each MDCT contains two fans, Fans A & C (Division I) and Fans B & D (Division II) mounted on their own pedestals.
Each fan is mounted on a pedestal and driven by a 150-hp two-speed motor. The motor is connected to the Engineered Safety Feature bus of the EDGs for a redundant power supply and is manually started and stopped from the main control room. The towers and fan drives are provided with a reinforced-concrete protective shell for tornado, earthquake, and missile protection in accordance with GDC 2.
The RHRSW system, EESW system, and EDG service water system, are designed in accordance with Criterion 44 to transfer heat from structures, systems, and components (SSCs) important to safety, to the UHS under normal operating and accident conditions. As described in the USAR, acceptance is based on compliance with RG 1.27. However, MDCT redundancy will be unavailable during the proposed maintenance on the degraded fan pedestals.
On July 18, 2023, the MDCT Fan D of Division II tripped due to high vibrations caused by a degraded, non-conforming gearbox pedestal. Corrective actions were required to correct the conditions and restore the equipment to an operable status. During that time the UHS was declared inoperable and a NOED (ML23205A139) was required because the repair time extended beyond the 72-hour TS completion time. In its LAR, the licensee indicates that during the extent of condition review, it was discovered that the MDCT A and C fan pedestals were also degraded and non-conforming requiring similar repair. To resolve the degraded condition, the licensee is requesting a one-time extension of the TS CT to allow repair of the MDCT Division I fan pedestals while online. Based on the duration of MDCT fan D repair, the licensee is requesting 7-day completion time to avoid a potential NOED situation. The proposed TS footnote would allow a CT of up to 7-days to repair the degraded MDCT Fans A and C pedestals during the current operating Cycle 22.
In order to approve this time extension, the licensee must demonstrate that UHS system remains capable of performing its safety function and additional actions have been taken to reduce risk during the extended period of repair.
During normal operation, the UHS has suitable redundancy with both MDCTs operable to accommodate a single failure without hindering the safety function of the systems. Each MDCT tower is designed to cool one division of the plant load (one RHR heat exchanger, one EECW heat exchanger, and two EDGs), thus providing complete redundancy. During these scheduled Division I fan repairs, both fans (B and D) within the other Division II MDCT tower will remain operable to perform the UHS safety function. While Fan D was repaired during the recent NOED, as discussed above, the NRC staff requested status of MDCT Fan B and whether similar corrosion or operational issues are present. As noted in the supplement dated August 25, the licensee is aware that MDCT Fan Pedestal B is in a non-conforming condition but remains operable and has performed satisfactorily.
The licensee indicated within the NOED that the operability surveillance includes running the MDCT fans in low and high speed. The most recent performance of these surveillances was on June 21, 2023, for Division II.
The MDCT system is designed such that it can function even if one division tower is damaged, rendered out of service, or is unavailable. With the two divisional reservoirs of the UHS cross-connected to permit access to the entire UHS inventory, each division has the capacity to safely and orderly shutdown the reactor during normal and/or accident conditions completely
independent of the other. As indicated in the USAR, the UHS is sized to provide sufficient cooling for 7 days following a reactor shutdown without makeup and includes provisions for required makeup. Therefore, the MDCTs can perform their function with one division unavailable.
In its supplement dated August 10, 2023, the licensee confirmed defense in depth measures are available for the three systems (Standby Feedwater (SBFW), Hardened Containment Vent and FLEX) listed in Section 3.2 of LAR NRC-23-0050 as being excluded from elective maintenance, and that will remain available during the MDCT Fan maintenance. The licensee can also release decay heat using the steam lines to the condenser and FLEX equipment remains available if needed to provide supplemental cooling.
To minimize risk, the LAR commits to compensatory measures defined in the LAR during unavailability of redundant SSCs while the Division I MDCT A (or C) fan is unavailable. During the maintenance, Division II MDCT and fans will remain operable and retain the ability to perform its safety function.
In summary, the UHS RHRSW complex normally provides redundancy with the MDCTs (Division I & II). Either division is capable of performing the MDCT safety function and maintaining plant in safe condition. While performing maintenance on a degraded fan pedestals within the Division I MDCT, the other MDCT division remain operable to perform its safety function. The licensee has described additional defense in depth systems that are available for cooling and decay heat removal. Therefore, one MDCT remains operable during duration of maintenance.
The NRC staff finds that the operable MDCT will remain capable of performing its safety function of maintaining cooling of one division of the plant load (one RHR heat exchanger, one EECW heat exchanger, and two EDGs). The commitment to compensatory measures and additional protective actions will further reduce risk during the maintenance activity. With the operable Division II MDCT ability to perform its safety function, application of compensatory measures and low risk, as analyzed below, the NRC staff finds that the one-time extension of TS required action to 7 days for each MDCT Fans A & C repair is acceptable.
4.2 Mechanical Engineering Evaluation The NRC staff reviewed the LAR with respect to mechanical engineering activities that might impact the plant status during the repair of the MDCT A and C fan pedestals at Fermi 2. Based on its review, the staff issued a request additional information (RAI) (ML23235A182) from the licensee regarding its plans to avoid TS surveillances and inservice testing (IST) program tests during the repair time for the MDCT A and C fan pedestals that might cause an inadvertent plant trip. In response to this request, the licensee stated in its August 25, 2023, supplement that surveillances and testing were considered as part of Enclosure 4, DTE PRA Technical Evaluation TE-E11-23-052, of its LAR with the specific section corrected by its letter dated August 30, 2023. In particular, the licensee stated that while in the proposed extended CT, overall plant risk will be managed by the existing Configuration Risk Management Program (CRMP). The licensee specified that this program evaluates increases in risk posed by potential combinations of equipment out-of-service and potential increases in initiating event frequency and requires that risk management actions be implemented as appropriate for a given plant configuration. The licensee plans to schedule maintenance and testing during the allowed completion time extension as warranted to minimize the aggregate risk at Fermi 2. The licensee stated that this will specifically include work performed on safety significant systems and their
applicable support systems. The licensee will evaluate emergent conditions under the CRMP.
The NRC staff finds that the licensee has established adequate plans to address the performance of surveillance and testing that might impact plant operations during the repair time of the MDCT A and C fan pedestals while Fermi 2 is online.
4.3 Risk Insights The NRC staff evaluated the licensees processes and methodologies for determining that the risk associated with operating the plant with one Division 1 RHRSW MDCT fan unavailable for a period of 7 days utilizing the guidance in RG 1.177 and RG 1.174. Since MDCT Fans A and C will not be simultaneously unavailable, the licensee performed a separate quantification for each fan, and it is conservative to evaluate loss of the division as a bounding evaluation. The results of the NRC staffs review are discussed below.
RG 1.177 describes an acceptable approach for developing risk-informed applications for proposed TS changes to CTs. All risk-informed applications for changes to plant TS should explicitly address the five key principles described in RG 1.174 and RG 1.177. These key principles are the following:
Principle 1: The proposed licensing basis change meets the current regulations unless it is explicitly related to a requested exemption (i.e., a specific exemption under 10 CFR 50.12).
Principle 2: The proposed licensing basis change is consistent with the DID philosophy.
Principle 3: The proposed licensing basis change maintains sufficient safety margins.
Principle 4: When proposed licensing basis changes results in an increase in risk, the increases should be small and consistent with the intent of the Commissions policy statement on safety goals for the operations of nuclear power plants (Safety Goals for the Operations of Nuclear Power Plants; Policy Statement, 51 FR 30028 (Aug. 4, 1986)).
Principle 5: The impact of the proposed licensing basis change should be monitored using performance measurement strategies.
In addition to the key principles, RG 1.177 identifies a four element, three-tiered approach to evaluating proposed changes to a plants design, operations, and other activities that require NRC approval. In its response to APLB RAI 6 dated August 25, 2023, the licensee provided discussion regarding the following four elements as described in RG 1.177:
Element 1: Define the Proposed Change Element 2: Perform Engineering Analysis Element 3: Define Implementation and Monitoring Program Element 4: Submit Proposed Change The NRC staffs evaluation of the licensees proposed amendment is presented in the following sections.
Key Principle 1 The regulation pertinent to the licensee's proposed TS amendment request is 10 CFR 50.36(c)(2)(i). The TS include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met. To meet the regulations discussed in Section 3.3, "Regulatory Requirements" above, the remedial actions must provide reasonable assurance that the health and safety of the public will not be endangered, and that the regulations will be met.
The licensee proposed a one-time modification to include a footnote to TS 3.7.2 extending the TS completion time from 72-hours to 7-days to allow Division I MDCT fan pedestal repairs. The unavailability of the MDCT system will be limited to a 7-day duration for each fan to complete repair/maintenance activities. No exemption was requested. The requested change does not propose any deviation or exemption to the regulation itself but requests a one-time change to the remedial action to be taken when the LCO cannot be met. The design and function of these systems would not be permanently changed because of the proposed MDCT fan maintenance.
The NRC staff's analysis of the licensee's justification of how continued operation for seven days will provide the requisite reasonable assurance of public health and safety and will meet the regulations is discussed throughout this SE.
Key Principle 2 The DID is an approach to designing and operating nuclear facilities that prevents and mitigates accidents that release radiation or hazardous materials. This approach creates multiple independent and redundant layers of defense to compensate for potential human and mechanical failures so that no single layer, no matter how robust, is exclusively relied upon. DID includes the use of access controls, physical barriers, redundant, and diverse key safety functions, and emergency response measures. DID is often characterized by varying layers of defense, each of which may represent conceptual attributes of nuclear power plant design and operation or tangible objects such as the physical barriers between fission products and the environment.
The licensee indicates that both MDCT fans foundation and operational issues will not be resolved in parallel in order to maintain DID and will continue to have three fans available while performing the maintenance (Division II fans and either MDCT Fan A or C).
In response to the NRC staffs request for available DID measures during repairs, the licensees August 10, 2023, supplement identified the three systems (SBFW, Hardened Containment Vent, and FLEX) listed in Section 3.2 of LAR NRC-23-0050 as being excluded from elective maintenance, and that will remain available during the MDCT Fan maintenance. The licensee also identified the ability to release decay heat using the steam lines to the condenser, and FLEX equipment remains available if needed to provide supplemental cooling.
As discussed throughout RG 1.174, consistency with the DID philosophy is maintained by the following measures:
Preserve a reasonable balance among the layers of defense.
Preserve adequate capability of design features without an overreliance on programmatic activities as compensatory measures.
Preserve system redundancy, independence, and diversity commensurate with the expected frequency and consequences of challenges to the system, including consideration of uncertainty.
Preserve adequate defense against potential CCFs [common-cause failures].
Maintain multiple fission product barriers.
Preserve sufficient defense against human errors.
Continue to meet the intent of the plants design criteria.
The NRC staff has reviewed the information provided in the LAR and the USAR against the DID attributes discussed in RG 1.174, and finds for each that:
A reasonable balance among the layers of defense is preserved.
The design basis of the RHR complex and MDCT system is to provide the cooling source for that divisions RHRSW subsystem, and EESW subsystem, as well as the diesel generator service water pumps for that divisions EDGs. The licensee is proposing no change to the design of the plant or any operating parameters, no new operating configurations, and no new changes to the design basis in the proposed TS change. The design and function of these systems would not be permanently changed because of the proposed one-time MDCT fan pedestal maintenance.
TS 3.7.2 currently allows operating 72-hours with an inoperable MDCT fan, and the licensee is requesting a one-time 7-day allowance. The purpose of the TS one-time CT extension is to allow a temporary relaxation of the single failure criterion to perform necessary repairs before a reactor shutdown would be required. During the Division I MDCT fan repair the Division II MDCT system will remain operable and maintain the system functions, and the compensatory actions protecting SSCs listed in the LAR reduce risk. The operable MDCT division is adequate to shut down the plant and mitigate the consequences of any design-basis accident.
Therefore, the NRC staff finds that a reasonable balance among the layers of defense is preserved.
Adequate capability of design features without an overreliance on programmatic activities as compensatory measures is preserved.
The proposed change will not involve any new programmatic activities or credit any new operator actions for assuring the MDCT system can perform its safety function. The Division II MDCT system will remain operable during the one-time (per fan) maintenance duration.
In addition to the operable MDCT, the licensee commits to compensatory measures defined in the LAR during unavailability of supported redundant SSCs while the Division I MDCT Fan A (or C) fan is unavailable. During the maintenance Division II MDCT will retain the ability to perform its safety function of providing cooling to RHRSW, EESW and EDG, if needed during the temporary plant configuration. The use of these compensatory measures minimize risk and does not reduce the capability of MDCT design features.
These compensatory measures include:
Restricting elective maintenance on operable Division II systems.
Restricting elective maintenance on non-divisional three systems (SBFW), Hardened Containment Vent and FLEX).
Signage defining systems under protection both within and when entering protected area.
Switchyards will be controlled by the Main Control Room and will be restricted to only essential work, with no elective maintenance being performed.
Plant Midcontinent Independent System Operator communications, Operations will verify no work affecting the 120kV or 345kV switchyards occurs.
Weather conditions will be verified to be acceptable prior to authorizing work.
Actions will be taken per plant procedure MOP01-200, Severe Weather Guidelines, in response to advanced notification of possible severe weather conditions.
Therefore, the NRC staff finds that the proposed one-time TS change preserves adequate capability of design features without an overreliance on programmatic activities as compensatory measures.
System redundancy, independence, and diversity commensurate with the expected frequency and consequences of challenges to the system, including consideration of uncertainty is preserved.
The licensee is proposing no change to the design of the plant or any operating parameters, and no new changes to the design basis in the proposed TS change. The addition of a TS note allowing a one-time 7-day completion time extension for a single MDCT cooling fan is needed to perform repairs on the degraded foundations to maintain redundancy, independence, and diversity.
The purpose of the CT extension is to allow a temporary relaxation of the single failure criterion to perform necessary maintenance before a reactor shutdown would be required. The UHS contains two completely independent and redundant MDCT divisions to avoid any impact on an operable Division during repairs. One MDCT division is adequate to mitigate the consequences of any design-basis accident, and Division II MDCT will remain operable during the one-time 7-day maintenance duration. Repairs on MDCT Division I will not impact operability of Division II.
Therefore, the NRC staff finds that system redundancy, independence, and diversity commensurate with the expected frequency and consequences of challenges to the system is preserved.
Adequate defense against potential common-cause failures is preserved.
Each independent MDCT system contains two fans. Only one fan (A or C) within Division I will be taken out of service at a time for repair, and there will be no time when both fans of the same division are out of service simultaneously. Both fans of Division II MDCT system will remain operable and maintain the system functions, and the compensatory actions protecting SSCs will be used to reduce risk. Therefore, the NRC staff finds that adequate defense against potential CCFs is preserved.
Multiple fission product barriers are maintained.
The relationship of any MDCT system to individual barriers will not change as a result of the one-time extension. Division II MDCT will remain operable and retain the ability to perform its safety function during the one-time 7-day maintenance duration. Therefore, the NRC staff finds that multiple fission product barriers protection is unaffected and maintained.
Sufficient defense against human errors is preserved.
Operator response during normal, abnormal, and emergency operating conditions will continue to be in accordance with station approved procedures. Dedicated and trained operators are stationed in key areas to assure that specified cooling functions are performed in the time required.
The licensee is applying compensatory measure restricting elective maintenance and access to specific protected systems during repairs. Therefore, the NRC staff finds that sufficient defense against human error will continue to be preserved.
The intent of the plants design criteria continues to be met.
The requested change does not result in any design or physical changes to the MDCT system.
Therefore, the NRC staff finds that the plant will continue to meet the intent of the plants design criteria.
Key Principle 3 Section 2.2.2 of RG 1.177, Revision 2, states, in part, that sufficient safety margins are maintained when:
Codes and standards or alternatives approved for use by the NRC are met.
Safety analysis acceptance criteria in the Updated Final Safety Analysis Report are met or proposed revisions provide sufficient margin to account for analysis and data uncertainties.
The licensee is not proposing to change any quality standard, material, or operating specifications. Acceptance criteria for operability of equipment are not changed and use of the extended CT only affects the MDCT fan operability specific to repair/replacement activities and when maintenance is being performed.
The proposed changes do not alter the plant design, nor do they affect the assumptions contained in the safety analyses. Specifically, there are no changes being made to the MDCT fan design. The licensee indicates the proposed changes have been evaluated and margins of safety regarding cooling system availability and to plant risk have been determined to be not significantly reduced. As analyzed in the USAR, the loss of the Division I MDCT fans would not cause a significant reduction in safety because the MDCT system is redundant and can perform its function with one division unavailable.
Key Principle 4 Tier 1: PRA Capability and Insights As discussed in RG 1.174 and RG 1.177, Principle 4 states that when proposed licensing basis changes result in an increase in risk, the increases should be small and consistent with the intent of the Commissions policy statement on safety goals for the operation of nuclear power plants. The licensees proposed TS change uses the three-tiered approach described in RG 1.177 to address the calculated change in risk as measured by the change in core damage frequency (CDF), the change in large early release frequency (LERF), the ICCDP, and the incremental conditional large early release probability (ICLERP). The use of compensatory measures to reduce risk was also evaluated.
The license indicated that the Fermi V12 PRA model was utilized to evaluate the impact on CDF and LERF to support the application. The Fermi V12 model is a component-level model which includes contributions from random failures, CCFs, test downtime, and maintenance downtime. The Fermi V12 model has been peer-reviewed against RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities. All findings have been closed and non-Capability Category II supporting level requirements have been addressed. Resolutions have been incorporated into the Fermi V12 model. Additional peer reviews have not been performed, as there have been no PRA upgrades to the model.
The licensee performed quantitative risk evaluations for the purpose of comparing the ICCDP and ICLERP of operating the plant with one Division 1 RHRSW MDCT Fan (A or C) unavailable against the thresholds set forth in RG 1.177. The licensee stated that separate quantification was performed for each cooling tower fan because MDCT Fan A and C would not be concurrently unavailable. During the relevant quantification, only the basic events relating to the subject component were modified in the Fermi V12 PRA model. Further, the quantitative risk evaluation does not include credit for FLEX equipment.
The license stated that to fully characterize the risk presented by this condition, an assessment was required to be performed on external event factors that could impact safety during the period of extended CT. Fermi has developed an Other External Hazards (OEH) Screening Report to determine the applicability of various external events to Fermi. The result of the screening report was that only internal fires and seismic hazards require additional detailed evaluation. Internal flooding, which was also determined to be applicable, is already included in the Fermi V12 model.
A peer review of the Fermi OEH Screening Report was conducted in May 2014 by industry peers under the auspices of the Boiling Water Reactor Owners Group (BWROG). The peer review report shows details of the Facts and Observations (F&Os) that were written as a result of this assessment. The report found that all supporting requirements meet Capability Category I/II/III of the ASME/ANS standard. All findings from this peer review have subsequently been closed. As only fire and seismic hazards were identified as necessary, no further external hazards need to be evaluated for this application.
The licensee performed a review of the Individual Plant Examination for External Events (IPEEE) which uses the Electric Power Research Institute Fire Induced Vulnerability Evaluation (FIVE) methodology to qualitatively evaluate fires that could impact Division II RHR decay heat removal and normally rely upon the Division I counterparts (which would be unavailable) for
achieving safe shutdown. The following six unscreened risk significant fire areas were evaluated in the context of the proposed plant configuration to develop risk-informed insights for fire hazards.
RB Reactor Building 2nd Floor 03AB - Relay Room 09AB - Control Room 12AB - Division II Switchgear Room 04ABN - Division I Switchgear Room 11ABE - Division I Portion Miscellaneous Room The licensee stated that for fire areas RB-06, 03AB, 09AB, and 12AB, the following risk management actions (RMAs) will be taken during the period of requested CT. These actions reduce the probability of a consequential fire in the above risk significant areas of the plant.
Minimize transient combustibles.
Prohibit hot work or limit with adequate compensatory measures per plant procedure ODE-20, Protected Equipment.
Confirm availability of detection and suppression systems.
Confirm fire barriers intact.
Inspect area for fire source degradation.
Minimize electrical switching at panels as applicable or establish compensatory measures per ODE-20.
The licensee stated that fire RMAs are not required for fire areas 04ABN and 11ABE because no dominant fires impact the ability of Division II RHR to remove decay heat.
The NRC staff concludes that the qualitative assessment of the significant fire risk areas provide confidence that the licensees use of IPEEE insights demonstrate that the impact of the proposed above actions are adequate to reduce fire hazards.
The licensee stated that seismic events are likely to cause core damage by disrupting offsite power. As such, existing measures to protect Division II EDGs and Division II RHR are considered prudent measures to reduce the risk of seismic events during the planned one-time CT extension period.
The licensee provided the table below, to summarize its calculated CDF, LERF, ICCDP, and ICLERP for the proposed one-time CT extension from Fermi V12 internal events quantification.
Base Conditional Delta CT ICCDP/
(/yr) Risk (/yr) (/yr) ICLERP (days) (yr)
CDF 1.93E-06 1.95E-06 2.00E-08 7 1.92E-02 3.83E-10 (MDCT A or C)
LERF 5.65E-07 5.65E-07 1.10E-08 7 1.92E-02 2.11E-10 (MDCT A or C)
The licensee identified compensatory measures in place to mitigate sources of increased risk with the proposed CT. The above table indicates that the impact on plant risk from implementing
the one-time CT extension satisfies the acceptance guidelines in RG 1.177, i.e., ICCDP <
1.00E-06 and ICLERP < 1.00E-07.
The NRC staff concludes that the proposed risk associated with a one-time extension of the CT from 72-hours to 7-days to allow repair of the Division 1 MDCT A and C fan pedestals while online meets the limits of RG 1.177. The licensee provided sufficient evidence to conclude that the PRA is acceptable to support the risk analysis. This conclusion is further supported when consideration is given to the risks associated with Fermi external events, and additional compensatory measures committed to by the licensee.
Tier 2: Potentially High-Risk Configurations In the RG 1.177 approach, the licensee should provide reasonable assurance that risk-significant plant equipment outage configurations will not occur when specific plant equipment is out of service in accordance with the proposed TS changes. The avoidance of risk-significant plant configurations limits potentially high-risk configurations that could exist if equipment, in addition to that associated with the proposed TS change, are simultaneously removed from service or other risk-significant operational factors such as concurrent system or equipment testing are involved. Therefore, Tier 2 helps ensure that appropriate restrictions are placed on dominant risk-significant configurations relevant to the proposed TS change.
The licensees Tier 2 evaluation identified the following design features that enhance Fermis ability to successfully mitigate most initiating events during the proposed one-time extension of the CT.
Fermi has two physically and electrically independent sources of Offsite power (120 kV and 345 kV lines). These offer the site greater electrical redundancy.
Fermi has two EDGs per Division.
Fermi has four combustion turbine generators (CTGs), one of which is self-black-start capable. The other three are capable of black-start with the assistance of a black start diesel generator. The CTGs normally provide power to Division 1 loads, and the PRA model credits operator action to crosstie to Division 2.
Fermi has a high-pressure inventory makeup system SBFW, in addition to High Pressure Coolant Injection and Reactor Core Isolation Cooling. SBFW is a motor driven system which can also be utilized at low reactor pressures and can be powered by any of the four CTGs.
The NRC staff reviewed the licensees assessment and finds that the licensees Tier 2 program is consistent with the guidance in RG 1.177 and therefore, is acceptable.
Tier 3: Configuration Risk Management Program A Tier 3 program ensures that while MDCT Fan A and C is in an LCO condition, additional activities will not be performed that could further degrade the capability of the plant to respond to a condition the inoperable MDCT Fan A and C or system was designed to mitigate, and as a result, increase plant risk beyond that assumed by the risk-informed licensing action.
Tier 3 programs: (1) ensure that additional maintenance does not increase the likelihood of an initiating event intended to be mitigated by the out-of-service equipment, (2) evaluates the effects of additional equipment out-of-service during MDCT Fan A and C maintenance activities
that would adversely impact MDCT Fan A and C CT risk such as from redundant or associated systems or components, and (3) evaluates the impact of maintenance on equipment or systems assumed to remain operable by the MDCT Fan A and C CT analysis.
The licensee has developed a CRMP based on a risk-informed assessment process to manage the risk associated with planned and unplanned (emergent) plant maintenance activities.
Fermis overall plant risk will be managed by the existing CRMP. This program evaluates increases in risk posed by potential combinations of equipment out-of-service and potential increases in initiating event frequency and requires that risk management actions be implemented as appropriate for a given plant configuration. Maintenance and testing during the allowed completion time extension will be scheduled for Fermi as warranted to minimize aggregate risk. This will specifically include work performed on safety significant systems and their applicable support systems. The licensee stated that the emergent conditions will be evaluated by operations under the CRMP. No quantitative credit was taken in the evaluation for the implementation of the CRMP nor the compensatory measures.
Based on the above discussion, the NRC staff concludes that the licensees CRMP will adequately address the risk associated with planned and emergent plant maintenance activities during the extension of the CT.
Conclusion for Key Principle 4 The NRC staff finds that the licensee has demonstrated that the scope, level of detail, and technical adequacy of its PRA models are sufficient to support the proposed one-time CT extension. The risk metrics used to support the proposed one-time CT extension are consistent with RG 1.177. The NRC staff further finds that the licensee has followed the three-tiered approach outlined in RG 1.177 to evaluate the risk associated with the proposed change, and therefore, the proposed change satisfies the fourth key safety principle of RG 1.177.
Key Principle 5 RG 1.174 and RG 1.177 establish the need for an implementation and monitoring program to ensure that no adverse safety degradation occurs because of the changes to the TSs. An implementation and monitoring program intended to ensure that the impact of the proposed TS change continues to reflect the reliability and availability of SSCs impacted by the change.
Furthermore, Section 3.2, Maintenance Rule Control, of RG 1.177 states, in part, that:
To ensure that extension of a TS CT The licensee should ensure, as part of its Maintenance Rule program (10 CFR 50.65), that when equipment does not meet its performance criteria, the scope of evaluation required under the Maintenance Rule includes prior related TS changes.
In their response to RAI 6, the licensee stated, regarding the RG 1.177 four element approach, that Element 3 is not applicable to this LAR because the completion time extension is temporary to restore the fan pedestals to their original design. The NRC staff does not agree with this statement. There is no such exclusion in the guidance in RG 1.177.
Subsequently, in response to the NRC staffs RAI, the licensee in its letter dated August 30, 2023, confirmed that the EECW/EESW System is monitored under the Fermi Maintenance Rule program. If the established Maintenance Rule program reliability or availability performance
criteria for the EECW/EESW System are exceeded, the performance criteria are evaluated for 10 CFR 50.65(a)(1) actions, which requires increased management attention and goal setting in order to restore the EECW/EESW System performance to an acceptable level.
Conclusion for Key Principle 5 Based on the above discussion, the NRC staff finds that the implementation and monitoring program for the proposed TS 3.7.2 change described by the licensee satisfies the fifth key principle of RGs 1.174 and RG 1.177.
Key Principles Conclusion The NRC staff reviewed the proposed changes. One acceptable approach for making risk-informed decisions about proposed TS changes is to show that the proposed changes meet the five key principles stated in RG 1.177. The NRC staff found that the proposed change does meet the key principles, and is therefore, acceptable.
4.4 Technical Evaluation Conclusion
Based on the above evaluation, the NRC staff finds that the proposed TS change will continue to provide reasonable assurance of public health and safety. The licensee is not requesting approval of design changes. Further, the licensee sufficiently justified its proposal for continued operation during the one-time extended CT to perform maintenance on MDCT Fan A and C.
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.
An evaluation of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
DTE will use the compensatory measures and Fermi 2 Configuration Risk Management program requirements outlined Section 3.2 above and in Enclosure 4 during the duration of the proposed extension of the Completion Time for the MDCT fan pedestal repair. The risk impact of the proposed Completion Time is deemed acceptable and meets the requirements of RG 1.177.
Therefore, the proposed changes do 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 changes do not involve a change in design, configuration, or method of operation of the plant. The proposed changes will not alter the manner in which equipment is initiated, nor will the functional demands on credited equipment be changed. The proposed changes do not impact the interaction of any systems whose failure or malfunction can initiate an accident. There are no identified redundant components affected by these changes and thus, there are no new common cause failures or any existing common cause failures that are affected by extending the Completion Time. The proposed changes do not create any new failure modes.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed changes do not alter the plant design, nor do they affect the assumptions contained in the safety analyses. Specifically, there are no changes being made to the MDCT fan design. The proposed changes have been evaluated and margins of safety ascribed to EECW availability and to plant risk have been determined to be not significantly reduced. The risk impact of the proposed changes is acceptable to the compensatory measures and other requirements, as outlined in outlined Section 3.2 above and in Enclosure 4. As analyzed in the UFSAR, the loss of the Division I MDCT fans would not cause a significant reduction in safety because the MDCT system is redundant and can perform its function with one division unavailable.
The evaluation provided above shows that the proposed changes will not significantly increase the probability or the consequences of any accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in the 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 final 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 Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment on August 29, 2023. The State official had one comment concerning the inconsistent revisions of RG 1.177 referenced in the LAR. This inconsistency was resolved by the licensees supplement dated September 11, 2023.
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 and changes SRs.
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, as published in the Federal Register on September 1, 2023 (88 FR 60504), 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.
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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: G. Curran, NRR J. Wilson, NRR N. Iqbal, NRR C. Moulton, NRR T. Scarbrough, NRR Date of Issuance: September 18, 2023
ML23243A885 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC NRR/DRA/APLB/BC NAME SArora SRohrer (SLent for) MJardneh JWhitman DATE 8/29/23 9/13/23 9/11/23 9/11/23 OFFICE NRR/DRA/SCPB/BC NRR/DEX/EMIB/BC OGC - NLO NRR/DORL/LPL3/BC NAME BWittick SBailey DRoth JWhited DATE 9/08/23 9/12/23 9/14/23 9/18/23 OFFICE NRR/DORL/LPL3/PM NAME SArora DATE 9/18/23