NRC-13-0019, Response to Supplemental Information Request for Acceptance of License Amendment Request for Measurement Uncertainty Recapture Power Uprate

Response to Supplemental Information Request for Acceptance of License Amendment Request for Measurement Uncertainty Recapture Power Uprate

ML13095A456
Person / Time
Site:	Fermi
Issue date:	04/05/2013
From:	Conner J DTE Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-13-0019, TAC MF0650
Download: ML13095A456 (6)

Text

J. Todd Conner Site Vice President DTE Energy Company 6400 N. Dbde Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.5295 Email: connerj@dteenergy.com DTE Enrgy-10 CFR 50.90 April 5, 2013 NRC-13-0019 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) DTE Electric Company Letter to NRC, "License Amendment Request for Measurement Uncertainty Recapture (MUR) Power Uprate," NRC-13-0004, dated February 7, 2013 (ML13043A659)

3) NRC Letter to DTE, "Fermi 2 - Supplemental Information Needed for Acceptance of License Amendment Request for Measurement Uncertainty Recapture (TAC No. MF0650)," dated March 21, 2013 (ML13080A229)

Subject:

Response to Supplemental Information Request for Acceptance of License Amendment Request for Measurement Uncertainty Recapture Power Uprate In Reference 2, DTE Electric Company (DTE) submitted a license amendment request for a Measurement Uncertainty Recapture (MUR) power uprate for Fermi 2.

In Reference 3, the NRC staff requested supplemental information in order to complete acceptance review of the license amendment request. The requested supplemental information is enclosed.

DTE has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 2. The additional information provided in this submittal has no effect on the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Also, the additional information provided in this

USNRC NRC-13-0019 Page 2 submittal has no effect on the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

Should you have any questions or require additional information, please contact Mr.

Zachary W. Rad of my staff at (734) 586-5076.

Sincerely, Enclosure cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-13-0019 Page 3 I, J. Todd Conner, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

J. Todd Conner Site Vice President Nuclear Generation On this 3 day of April, 2013 before me personally appeared J. Todd Conner, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S. MARSHALL COUNTY NOTARY PUBLIC, OF MONROE STATE OF Mp ACTING INCOt NrrY YCOMMISSION -~re EXPIRES un 14,2013

Enclosure to NRC-13-0019 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information for License Amendment Request for Measurement Uncertainty Recapture (MUR) Power Uprate

Enclosure to NRC-13-0019 Page 1 Supplemental Information for License Amendment Request for Measurement Uncertainty Recapture (MUR) Power Uprate Supplemental Information Requested:

The Nuclear Regulatory Commission staff would need specific statements addressing:

1. Whether the time availablefor any operatoraction has been reduced, and, if so, how does Fermi know that the action is stillfeasible;

2. Any effects on the Safety ParameterDisplay System (SPDS); and

3. A statement confirming licensee's intent to revise existing plant operatingprocedures related to temporary operation above full steady-state licensedpower levels to reduce the magnitude of the allowed deviationfrom the licensedpower level.

Response

1. Time Available for OperatorAction Operator actions that are sensitive to power uprate, and any effects of power uprate on the time available for operator actions, have been identified and evaluated. The time available for operator actions described in Fermi 2 licensing basis documents remains unchanged, and the operator actions described remain feasible.

Operator actions described in the Fermi 2 licensing and design basis were reviewed to determine if the time available for operator actions would be reduced as a result of the MUR power uprate.

Many time-dependent operator actions are not impacted by the power uprate due to bounding initial evaluations (e.g., analyses were performed at 102% of the Current Licensed Thermal Power (CLTP) of 3430 MWt) or time dependencies that are not directly associated with power level. The only time-dependent operator actions identified that are impacted by the MUR power uprate are associated with post-fire plant shutdown from outside the main control room.

The Fermi 2 UFSAR describes the sequence of events for a post-fire plant shutdown from outside the main control room (i.e., safe shutdown analysis) and provides times for initiation of reactor vessel injection with the standby feedwater system, initiation of suppression pool cooling, initiation of drywell cooling, and initiation of shutdown cooling. These times are based on operation of the plant at the CLTP of 3430 MWt prior to the event. Evaluations and calculations supporting the Fermi 2 safe shutdown analysis indicate that the times available for operator actions are longer than those stated in the UFSAR. In addition, the validated and verified times required to perform the necessary actions are shorter than those stated in the UFSAR. Therefore, the increased power level will not change the times available for operator actions associated with the safe shutdown analysis described in the UFSAR and the operator actions remain feasible.

Enclosure to NRC-13-0019 Page 2 As stated in Reference 2, Enclosure 7, Section 6.7.1, no further plant-specific Appendix R analysis is necessary for the Thermal Power Optimization Safety Analysis Report (consistent with section 5.11.1 of the NRC SER for topical report NEDC 32938P, ML031050138, dated April 1, 2003). The calculations supporting UFSAR credited operator actions associated with post-fire plant shutdown from outside the main control room will be updated during implementation of the MUR license amendment to reflect the increase in licensed thermal power.

2. Safety ParameterDisplay System (SPDS)

No changes to the Safety Parameter Display System have been identified as a result of the MUR License Amendment request.

3. Plant OperatingProcedures Plant operating procedures related to temporary operation above full steady-state licensed power levels (e.g., Fermi 2 procedure MOP03, "Policies and Practices") will be revised as part of the implementation of the MUR License Amendment, to reduce the magnitude of the allowed deviation from the licensed power level, as applicable.