NRC-23-0071, Response to Request for Additional Information (RAI) for Exigent License Amendment Request for Revision of Technical Specification (TS) 3.8.1 AC Sources - Operating

Response to Request for Additional Information (RAI) for Exigent License Amendment Request for Revision of Technical Specification (TS) 3.8.1 AC Sources - Operating

ML23286A112
Person / Time
Site:	Fermi
Issue date:	10/13/2023
From:	Frank E DTE Electric Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-23-0071, EPID L-2023-LLA-0134
Download: ML23286A112 (1)

Text

DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 DTE October 13, 2023 10 CFR 50.90 NRC-23-0071 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Response to Request for Additional Information (RAI) for Exigent License Amendment Request for Revision of Technical Specification (TS) 3.8.1 "AC Sources - Operating"

References:

1) DTE Letter NRC-23-0068, "Exigent License Amendment Request for Technical Specification 3.8.1, "AC Sources - Operating" dated September 28, 2023. (ML23271Al 88)

2) NRC E-mail Capture, "Request for Additional Information for Changes to TS 3.8.1, "AC Sources - Operating," (EPID L-2023-LLA-0134) dated October 10, 2023.

In Reference 1, DTE Electric Company (DTE) submitted an exigent License Amendment Request (LAR) to revise the Fermi 2 Technical Specifications (TS). In the Reference 2, an email from Mr. Surinder Arora to Mr. Eric Frank dated October 10, 2023, the NRC sent DTE a Request for Additional Information (RAI) regarding the LAR.

The RAI and DTE's response are outlined in Enclosure 1 of this letter.

No new commitments are being made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan State Official.

Should you have any questions or require additional information, please contact Mr. Eric Frank, Manager, Licensing at (734) 586-4772.

USNRC NRC-23-0071 Page2 Ex& ~2023 I declare under penalty of perjury that the foregoing is true and correct.

Eric Frank Manager - Nuclear Licensing

Enclosures:

1. Response to RAJ for MDCT Pedestal Fan Repair Exigent LAR cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure 1 to NRC-23-0071 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to RAI for MDCT Pedestal Fan Repair Exigent LAR to NRC-23-0071 Page 1 By letter dated September 28, 2023 (Agencywide Document Access Management System (ADAMS) Accession No. ML2327JAJ88), DTE Electric Company (DTE, the licensee) requested an amendment to the Renewed Facility Operating License No. NPF-43 for Fermi 2 Power Plant (Fermi 2). The proposed amendment would revise technical specification (TS)

Limiting Condition for Operation (LCO) 3. 8.1 Required Action B. 4, for both Emergency Diesel Generators (EDGs) in one division inoperable, by adding a footnote to allow a one-time extension of the Completion Time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days during the current operating Cycle 22.

This one-time extension would be used twice, once for each fan during the allotted time approved by the NRC.

The US. Nuclear Regulatory Commission (NRC) staff has determined that the following additional information is needed to complete its review of the license amendment request (LAR).

Request for Additional Information (RA/)

RAl#1 Section 3.0, "Technical Evaluation," of the LAR provides, in part, the discussion of the operation of the MDCT system with one division unavailable. However, the LAR does not include the discussion of the operation of the Emergency Diesel Generators (EDGs) with one division unavailable. The NRC staff notes that TS 3. 7.2 contains a note "Enter applicable Conditions and Required Actions of LCO 3.8.1, *c Sources-Operating," for diesel generator made inoperable by UHS." This would require the entry of TS 3.8.1 Condition B, "Both EDGs in one division inoperable."

The NRC staff requests the discussion of the plant configuration in response to the following conditions during the implementation of the proposed change, in which two EDGs are unavailable for seven days:

1. Loss of offsite power (LOOP)

2. LOOP concurrent with loss of coolant accident (LOCA)

DTE Response:

The repair of the Mechanical Draft Cooling Tower (MDCT) fan A and C pedestals will be performed one at a time. During the time of the repair, EDG11 and EDG12 (Division I), as well as other systems such as Emergency Equipment Service Water (EESW)/Emergency Equipment Cooling Water (EECW) and Residual Heat Removal Service Water (RHRSW) (including the other MDCT fan) will be designated as INOPERABLE in accordance with the Technical Specifications. Although INOPERABLE, these systems and equipment, including to NRC-23-0071 Page2 their supporting subsystems, will still be in stand-by and available to perform their safety functions if called upon due to a Loss of Offsite Power (LOOP) and/or Loss of Coolant Accident (LOCA), including required load sequencing. After the EDG has started, if required, it will also still automatically tie to its respective bus after offsite power is tripped, independent of or coincident with a LOCA signal.

In the event of a loss of normal power, the ESF electrical loads will still be automatically connected to the EDGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a LOCA.