ML23297A051

Issuance of Amendment No. 226 Regarding Revision of Technical Specifications 3.8.1, AC Sources - Operating (Exigent Circumstances)

ML23297A051
Person / Time
Site:	Fermi
Issue date:	10/30/2023
From:	Shilpa Arora Plant Licensing Branch III
To:	Peter Dietrich DTE Electric Company
Arora S
References
EPID L-2022-LLA-0134
Download: ML23297A051 (23)

Text

October 30, 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. 226 REGARDING REVISION OF TECHNICAL SPECIFICATIONS 3.8.1, AC SOURCES -

OPERATING (EXIGENT CIRCUMSTANCES) (EPID L-2022-LLA-0134)

Dear Mr. Dietrich:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 226 to Renewed Facility Operating License No. NPF-43, for Fermi, Unit 2 (Fermi 2). This amendment is in response to your application dated September 28, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23271A188), as supplemented by letters dated October 13, 2023 (ML23286A112) and October 18, 2023 (ML23291A143).

The amendment revises Technical Specification (TS) 3.8.1, AC Sources - Operating and makes an editorial correction to the one-time footnote on TS 3.7.2 that was approved in exigent amendment 225. These changes to the TSs allow for a one-time extension of the Completion Times for Required Actions A.1 and B.4, for TS 3.7.2 and TS 3.8.1, respectively, 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. 226 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. 226 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 September 28, 2023, as supplemented by letters dated October 13, 2023, and October 19, 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. 226, 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: 2023.10.30 Whited 09:14:45 -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: October 30, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 226 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 pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.7-3 3.7-3 3.8-2a 3.8-2a

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 226, 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 226

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 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, 226

AC Sources Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s), supported discovery of by the inoperable the inoperable EDGs, inoperable when EDGs concurrent the redundant with required feature(s) inoperability are inoperable. of redundant required AND feature(s)

B.3.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> EDG(s) are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for OPERABLE EDG(s).

AND B.4 Restore one EDG in 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s*

the division to OPERABLE status.

C. One or both EDGs in C.1 Restore both EDGs in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> both divisions one division to inoperable. OPERABLE status.

D. One offsite circuit D.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. for OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND (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 completion time extension and associated compensatory measures are documented in LAR NRC-23-0068. This completion time extension will expire at 2359 on November 19, 2023.

FERMI - UNIT 2 3.8-2a Amendment No. 170, 175, 222, 226

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 226 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By application dated September 28, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23271A188), as supplemented by letters dated October 13, 2023 (ML23286A112) and October 18, 2023 (ML23291A143), DTE Electric Company (DTE or the licensee), requested changes to the Technical Specifications (TSs) for Fermi 2.

By letter dated September 18, 2023 (ML23243A885), the NRC staff approved, under exigent circumstances, amendment 225 to extend the completion time (CT) of TS 3.7.2 to support the repair of the Division I mechanical draft cooling tower (MDCT) fan pedestals. The licensee has indicated the original amendment did not contain all required TS CT extensions needed to perform the maintenance. This amendment is to implement an additional one-time change to TS 3.8.1 to incorporate a note supporting the same planned maintenance.

The proposed changes would modify the TS to include a footnote to TS 3.8.1 AC Sources -

Operating, Condition B, Both EDGs in one division inoperable, Required Action B.4, Restore one EDG in the division to OPERABLE status, with a CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The proposed footnote would allow a CT of up to 7-days to repair the Division 1 MDCT A and C fan pedestals during the current operating Cycle 22. This footnote would support the previously approved TS 3.7.2 amendment allowing maintenance of the MDCT, and findings remain valid for this proposed amendment as documented below. The proposed change also makes an editorial correction to the one-time footnote on TS 3.7.2 that was approved in exigent amendment 225.

The two supplements dated October 13, 2023, and October 18, 2023, provided additional information that clarified the application scope and did not change the U. S. Nuclear Regulatory Commission (NRC, or the Commission) staffs determination of the original proposed no significant hazards consideration as published in the Federal Register on October 13, 2023 (88 FR 71037).

Enclosure 2

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 the licensees application dated September 28, 2023, the licensee requested that the NRC process the proposed amendment on an exigent basis.

Specifically, 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 Eastern Daylight Time (EDT), the Division II Residual Heat Removal Service Water (RHRSW) 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 are also in need of similar repair. These fans do not currently exhibit evidence of similar vibration or operational issues as was experienced on MDCT D. Monthly surveillances have been performed without issues. This request is being made to be proactive and inspect and repair these two fans to avoid a failure similar to the MDCT D fan pedestal. In addition, if a fan failure were to occur prior to the scheduled online maintenance, it would allow the emergent maintenance of those fans to be performed without the need of a forced shutdown or enforcement discretion.

On September 18, 2023, License Amendment 225 was approved (Reference 6.6) under exigent circumstances to extend of the Completion Time to Technical Specification 3.7.2 to support the repair the Division I MDCT fan pedestals online instead of waiting until the next refueling outage. That original amendment did not contain all required Technical Specification Completion Time extensions needed to perform this work online. This request is to implement an additional one-time amendment to Technical Specification 3.8.1 to support the same planned online maintenance. Therefore, this additional proposed amendment is also 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 (88 FR 71037) on October 13, 2023, 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

3.1 System Description and Operation The Fermi 2, Updated Safety Analysis Report (ML22325A160) (USAR), provides description of the ultimate heat sink (UHS) in Section 9.2.5, Ultimate Heat Sink. The UHS is provided by water supply in the form of a 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 of 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 Emergency Equipment Service Water (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 Emergency Equipment Cooling Water (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).

According to Section 8.3.1.1.8, Standby AC Power System, of the USAR, the standby alternating current (AC) power system for Fermi 2 consists of four EDGs. Each EDG is started automatically on loss of voltage to its respective bus, on low reactor water level, or on high drywell pressure. If offsite power is lost during parallel operation with the electrical system, the EDG breaker will be opened automatically via underfrequency relaying. Upon the occurrence of a LOCA and on receipt of an automatic signal from the power plant relays, each EDG automatically "fast starts," comes to rated voltage and synchronous speed, and is capable of

operating as an isolated source to start the loads sequentially. If a loss of system power has occurred, the EDG is automatically connected to the bus.

Section B 3.2 of Fermi-2 TS Bases states that the ability to provide onsite emergency AC power is dependent on the ability of the UHS to cool the EDGs. The long-term cooling capability of the RHR and core spray pumps is also dependent on the cooling provided by the EECW/EESW System.

3.2 Proposed Changes 3.2.1 Proposed Technical Specification Changes By letter dated September 18, 2023 (ML23243A885), the staff approved under exigent circumstances an amendment to extend the Completion Time of TS 3.7.2 to support the repair of the Division I MDCT fan pedestals. The licensee has indicated the previous amendment did not contain all required TS Completion Time extensions needed to perform the maintenance.

This amendment incorporates an additional footnote to TS 3.8.1 to support the same planned maintenance.

The amendment requests to include the following footnote to Fermi TS 3.8.1, Condition B, Required Action B.4 CT:

• 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 completion time extension and associated compensatory measures are documented in LAR NRC-23-0068. This completion time extension will expire at 2359 on November 19, 2023.

The LAR also makes an editorial correction to revise the footnote for TS 3.7.2 that was approved in amendment No. 225 to remove the word proposed to match the proposed footnote request for TS 3.8.1.

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 and electrical power system:

GDC 2 - Design Bases for Protection Against Natural Phenomena GDC 17 - Electrical Power Systems 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].

NUREG-0800 SRP, Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions, states, in part, that To facilitate approval of an extended allowed outage time (AOT) for onsite or offsite power source, some licensees have provided a detailed PRA risk-informed evaluation and installed commercial-grade diesel generators capable of supplying power to the required safe-shutdown loads on the train removed from service for the maintenance outage.

This BTP specifically discusses the defense-in-depth aspects for onsite and offsite power sources from a deterministic perspective. A supplemental power source should be available as a backup to the inoperable EDG or offsite power source, to maintain the defense-in-depth design philosophy of the electrical system to meet its intended safety function.

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 decision making 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.

4.0 TECHNICAL EVALUATION

4.1 Electrical Engineering Evaluation The NRC staff's evaluation of the proposed change considered potential plant conditions that could be encountered while implementing the one-time CT extension. Potential plant conditions include LOOP and LOOP concurrent with LOCA. The NRC staff reviewed information in the application and its supplements pertaining to the electrical power systems, the USAR, TS Bases, and applicable TS LCO to verify the capability and capacity of the affected electrical power systems to perform their safety functions (assuming no additional failures of electrical components) is maintained. The NRC staff uses BTP 8-8 as guidance for the review of applications requesting TS CT extension up to 14 days. The staffs deterministic evaluation of the proposed change is provided below.

4.1.1 Evaluation of Impact on Safe Operation of the Plant According to Section 8.3.1.1.8, of the USAR, if offsite power is lost during parallel operation with the electrical system, the EDG breaker will be opened automatically via underfrequency relaying. On occurrence of a LOCA and on receipt of an automatic signal from the power plant relays, each EDG automatically "fast starts," comes to rated voltage and synchronous speed, and is capable of operating as an isolated source to start the loads sequentially.

Section 8.3.1.2.2.1 of the USAR states that the design of the onsite standby AC power supply system is a one engineered safety features (ESF) bus/one-EDG arrangement (two such arrangements per ESF division) with the redundant loads of each division split among four buses. Each EDG is of sufficient capacity to carry the essential loads of its respective bus. A single failure that could cause the loss of a division pair of EDGs would not prevent safe reactor shutdown.

Regarding the capability of the Fermi-2 onsite AC power system to provide its required safety function during the implementation of the proposed change, in the letter dated October 18, 2023, the licensee stated that the configuration, capacities, and capabilities of all Division II Safety Systems will remain operable and able to support a LOOP and/or LOCA. Repair activities on the Division I MDCT will not impact the configuration, capabilities, and capacities of the Division II Safety Systems. The Division II EDGs (13 & 14), including support systems, will remain operable, in standby and capable of supporting a LOOP and/or LOCA. All compensatory measures are described in Section 3.3 of NRC-23-0068 and will ensure that the Division II Safety Systems are protected and operable during the repair of the Division I MDCTs.

Based on the information in the USAR and the LAR and its supplements, the NRC staff finds that during the implementation of the proposed CT extension, with the proposed compensatory measures implemented, the remaining two EDGs (EDG 13 and EDG 14) in Division II together would maintain the capacity and capability to safely shut down the reactor and maintain it in safe condition if a LOOP or LOOP concurrent with LOCA occurs.

4.1.2 Evaluation of Supplemental Power Source Section B, Branch Technical Position, of BTP 8-8 states, in part, that it is the staffs position that the availability of an additional power source is a condition for approval of the extended EDG or offsite power AOT. Therefore, a supplemental power source (or alternate AC (AAC) power source) must be available when extending the current AOT allowed by the plant TS for a

single inoperable EDG or offsite power source up to 14 days provided the extended AOT is also supported by a risk-informed evaluation. The BTP further states that the supplemental source must have capacity to bring a unit to safe shutdown in case of a LOOP concurrent with a single failure during plant operation. As for the time to make the AAC source available, BTP 8-8 states that for plants using AAC or supplemental power sources, the time to make the AAC or supplemental power source available, including accomplishing the cross-connection, should be approximately one hour to enable restoration of battery chargers and control reactor coolant system inventory.

Regarding the Fermi 2 supplemental power source, in the letter dated October 18, 2023, the licensee stated that one of four onsite combustion turbine generators (CTGs) could be used to provide emergency power when a fire occurs in the fire areas of concern, or for a LOOP should the EDGs be unavailable. The CTG diesel fuel level maintained by plant procedures to ensure nominal fuel availability for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation for a single CTG unit at 10 MW load. If CTG 11-1 is not available, either CTG 11-2, CTG 11-3 or CTG 11-4 (with AC starting motors) can be established on a standby basis as the black start power source for alternative shutdown power source using a standby starting diesel generator.

Section 8.4.2 of the USAR states that CTG 11-1 is designated as an AAC power source for the plant and is available within one hour to the blacked-out unit. In the event CTG 11-1 is inoperable, one of the remaining CTGs can be started using a standby diesel generator. The alternative CTGs have the same time availability criteria as CTG 11-1.

The staff finds that the Fermi 2 supplement power source (i.e., four CTGs) has sufficient capacity and would be available within one hour to safely shut down the reactor if a LOOP occurs concurrently with a single failure; and therefore, the proposed supplemental power source is consistent with BTP 8-8.

4.1.3 Evaluation of Compensatory Measures Section 3.3, Compensatory Measure, of the LAR provides restrictions on elective maintenance activities for electrical equipment including the switchgear, offsite power, and the Division 2 EDGs. The access to those electrical components and systems will also be restricted. These compensatory measures would minimize the impact on the availability of both offsite and onsite power equipment. The NRC staff finds that these compensatory measures, including monitoring weather conditions, would minimize human errors and the impact on the licensee's ability to continue to meet the intent of GDC 17 concerning the availability, capacity, and capability of the electrical power systems.

4.1.4 Evaluation of defense-in-depth When EDGs 11 and 12 are designated as INOPERABLE during the implementation of the proposed CT extension, the redundancy of the electrical power system is temporarily reduced.

The NRC staff finds that the defense-in-depth of the electrical power system, acknowledging that temporary reduction, is sufficiently maintained to allow the electrical power system to perform its intended safety functions provided a) the remaining equipment (EDG 13 and EDG

14) are available to perform the safety function; b) the supplemental power source is available; and c) the proposed compensatory measures are implemented to minimize the adverse impact on ability of the offsite power system and onsite standby AC power system to perform their safety functions.

In addition, with regard to crediting the INOPERABLE EDGs as the backup equipment, in the letter dated October 13, 2023, the licensee stated that the repair of the MDCT fan A and C pedestals will be performed one at a time. During the time of the repair, EDG 11 and EDG 12 (Division I), as well as other systems such EESW/EECW and RHRSW (including the other MDCT fan) will be designated as INOPERABLE in accordance with the TSs. Although INOPERABLE, these systems and equipment, including their supporting subsystems, will still be in stand-by and available if called upon due to a LOOP and/or 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 letter dated October 18, 2023, the licensee further stated that the emergency diesel generator service water (EDGSW) for EDGs 11 and 12, although INOPERABLE due to TS 3.7.2 entry (i.e., one INOPERABLE MDCT), will remain in standby, functional, and capable of auto-start if needed and will provide cooling if the associated EDG auto-starts. The UHS will continue to provide cooling water to the EDGSW system during this repair. Either Division I MDCT (A or C) will still be in standby, functional, and capable of providing cooling to the UHS, while the other MDCT is being repaired.

Based on the information provided by the licensee, the NRC staff finds that during the implementation of the proposed CT extension, the availability of INOPERABLE EDGs 11 and 12 (with associated cooling sources available) could provide backup AC power, if necessary. The use of backup equipment as means to provide an additional layer of defense-in-depth is acceptable.

4.1.5 Electrical Evaluation Conclusion Based on the above evaluations, the NRC staff found that a) during the proposed CT extension, with the proposed compensatory measures implemented, the remaining two EDGs (EDG 13 and EDG 14) in Division II would maintain the capacity and capability to safely shutdown the plant and maintain it in safe condition; b) the proposed CT extension for EDG 11 and EDG 12 is consistent with BTP 8-8 regarding the availability of the supplement power source; and c) while the redundancy of the onsite power system is temporarily reduced, the proposed compensatory measures would minimize the impact on the licensee's ability to continue to meet the intent of GDC 17 concerning the availability, capacity, and capability of the electrical power systems.

Therefore, the NRC staff found the proposed one-time CT extension for EDG 11 and EDG 12 acceptable.

4.2 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 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 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.

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 the plant in safe condition. While performing maintenance on a degraded fan pedestal within the Division I MDCT, the other MDCT division remains 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 proposed addition of TS 3.8.1 note does not impact the previous finding documented in the SE dated September 18, 2023 (ML23243A885). 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. Based on the operable Division II MDCTs ability to perform its safety function, the application of compensatory measures, and the 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.

4.3 Mechanical Engineering Evaluation In response to the licensees LAR dated August 10, 2023, for the proposed TS 3.7.2 modification (ML23222A037) as supplemented on August 25, 2023 (ML23237B419), the NRC staff reviewed that 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. In the submittals for the LAR for the proposed TS 3.7.2 modification, the licensee stated that it plans to schedule maintenance and testing during the allowed completion time extension as warranted to minimize the aggregate risk at Fermi 2. The licensee noted that this will specifically include work performed on safety significant systems and their applicable support systems. The licensee will evaluate emergent conditions under the Fermi 2 Configuration Risk Management Program (CRMP). Based on the previous evaluation, the NRC staff finds this information to also be applicable to the LAR for the proposed TS 3.8.1 modification such 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.

4.4 Risk Insights A risk-informed justification for this change has been previously evaluated and approved by the NRC staff in Amendment 225, dated September 18, 2023.

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 staff reviewed the proposed changes in the SE for Amendment 225. The NRC staffs evaluation of the licensees proposed changes is contained in Section 4.3 of the previously issued amendment 225 SE. 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 met the key principles, and was therefore, acceptable.

Based on the previous evaluation, the NRC staff finds that the proposed change meets the key principles, and is therefore, acceptable.

4.5 Editorial Change to TS 3.7.2 The NRC staff reviewed the proposed change to the TS 3.7.2 footnote and found that it is an editorial change that does not substantively alter the TS requirements, and it is therefore acceptable.

4.6 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 in Section 3.3 of Enclosure 1 of the license amendment request and in the previously approved amendment 225 during the duration of the proposed extension of the CT for the MDCT fan pedestal repair. The risk-informed justification for the proposed extension was also evaluated and approved in amendment 225.

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 change 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 Section 3.3 of Enclosure 1 of the license amendment request and in the previously approved amendment 225. 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.

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 October 17, 2023. The State official had no comment.

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 October 13, 2023 (88 FR 71037) 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 K. Nguyen, NRR C. Moulton, NRR T. Scarbrough, NRR Date of Issuance: October 30, 2023

ML23297A051 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC NRR/DRA/APLB/BC NAME SArora SRohrer SMehta JWhitman DATE 10/19/23 10/24/23 10/23/23 10/23/23 OFFICE NRR/DRA/SCPB/BC NRR/DEX/EMIB/BC NRR/DEX/EEEB/BC OGC - NLO NAME BWittick SBailey WMorton BVaisey DATE 10/23/23 10/23/23 10/24/23 10/25/23 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME JWhited SArora DATE 10/30/23 10/30/23