Text

License Amendment Request to Revise Technical Specification Surveillance Requirements for Direct Current Batteries
	ML14113A445
Person / Time
Site:	Fermi
Issue date:	04/23/2014
From:	Conner J; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-14-0010
	Download: ML14113A445 (34)
	v • d • e

J. Todd Conner Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.5295 Email: connerj@dteenergy.com DTE Energy-10 CFR 50.90 April 23, 2014 NRC-14-0010 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) NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 29, 1998

3) NRC Letter to DTE, "NRC Component Design Bases Inspection Report 05000341/2013008," dated October 29, 2013

4) Letter from S. Burns (NRC) to E. Ginsburg (NEI), dated July 14, 2010 [NRC ADAMS Accession No. ML101960180]

Subject:

License Amendment Request to Revise Technical Specification Surveillance Requirements for Direct Current Batteries Pursuant to 10 CFR 50.90, DTE Electric Company (DTE) hereby submits this License Amendment Request (LAR) to the Fermi 2 Plant Operating License to revise Technical Specifications (TS) Surveillance Requirements (SR) associated with TS 3.8.4, "DC Sources - Operating" and TS 3.8.6, "Battery Cell Parameters."

The changes requested in this LAR are submitted in accordance with Reference 2 for the resolution of non-conservative TS. Currently, Fermi 2 plant operations under TS SR 3.8.4.2, SR 3.8.4.5 and SR 3.8.6.3 are administratively controlled consistent with Reference 2. In accordance with the guidance in Reference 2, this LAR is required to resolve non-conservative TS, and is not a voluntary request from a licensee to change its licensing basis. Furthermore, in Reference 3, the NRC identified the need to resolve another issue regarding the frequency of testing specified in SR 3.8.4.8. Accordingly, this LAR should not be subject to "forward fit" considerations as discussed in Reference 4.

USNRC NRC-14-0010 Page 2 provides a technical and regulatory evaluation of the proposed license amendment. Enclosure 1 includes an analysis of the issue of significant hazards consideration using the standards of 10 CFR 50.92. DTE has concluded that the changes proposed in this submittal do not result in a significant hazards consideration.

Proposed changes to the TS are provided on markups of current TS pages in and a clean version of the TS pages with changes incorporated is provided in Enclosure 3. Markups of TS Bases pages are provided in Enclosure 4 for information only.

DTE has reviewed the proposed changes against the criteria of 10 CFR 51.22, and has concluded that they meet the criteria provided in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

DTE requests NRC approval of this LAR by April 2015 with an implementation date within 60 days of NRC approval.

No new commitments are being made in this submittal.

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

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

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

Sincerely,

Enclosures:

- Evaluation of the Proposed License Amendment - Marked-Up Pages of Existing Fermi 2 TS - Clean Pages of Fermi 2 TS with changes incorporated - Marked-Up Pages of Existing Fermi 2 TS Bases cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

USNRC NRC-14-0010 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. T dd C er Sit Vice resident, Nuclear Generation On this g3 day of April 2014 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 NOTARY PUBLIC, STATE OF MI COUNTYOF MONROE MY COMMISSION EXPIRES Jun 14, 2019 ACTING INCOUNTY OF N{o at

Enclosure 1 to NRC-14-0010 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Evaluation of the Proposed License Amendment to NRC-14-0010 Page 1 Evaluation of the Proposed License Amendment

Subject:

License Amendment Request to Revise Technical Specification Surveillance Requirements for Direct Current Batteries

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS Figure 1A, Battery Configuration Figure 1B, Battery Inter-Cell Connectors to NRC-14-0010 Page 2 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, DTE Electric Company (DTE) is requesting a license amendment to revise Surveillance Requirements (SRs) 3.8.4.2, 3.8.4.5, 3.8.4.8, and 3.8.6.3 of the Fermi 2 Plant Operating License, Appendix A, Technical Specification (TS) 3.8.4, DC Sources-Operating and TS 3.8.6, Battery Cell Parameters, respectively. This License Amendment Request (LAR) proposes to:

A. Correct non-conservative TS issues with respect to the following Fermi 2 Surveillance Requirements (SRs):

SR 3.8.4 2 and 3.8.4.5 current requirement:

Verify each battery cell to cell and terminal connection resistance is 1.5 E-4 ohm.

SR 3.8.6.3 current requirement:

Verify average electrolyte temperature of representative cells is > 60°F.

B. Address the NRCs 2013 Component Design Bases Inspection (CDBI) (Reference 6.1) concern with the following Fermi 2 SRs non-conformance with the frequency for performance testing of a degraded battery:

SR 3.8.4.8 current requirement:

Verify battery capacity is 80% of the manufacturers rating when subjected to a performance discharge test every 60 months; and 18 months when battery shows degradation or has reached 85% of expected life.

2.0 DETAILED DESCRIPTION 2.1 Revision of TS SR 3.8.4.2 and SR 3.8.4.5 2.1.1 Proposed Revision TS SR 3.8.4.2 and SR 3.8.4.5 are proposed to be revised as follows:

Both SRs would be revised to add the Total Allowable Aggregate Battery Measured Resistance limit of 2.7E-3 ohm for each 130 VDC battery section as another acceptance criterion, in addition to the existing criterion for a single cell to cell and terminal connection resistance limit of 1.5E-4 ohm.

to NRC-14-0010 Page 3 2.1.2 Basis for Revision Fermi 2 TS SR 3.8.4.2 and SR 3.8.4.5 verify that each cell-to-cell and terminal connection resistance is 1.5E-4 ohm. However, if all connection resistances were postulated to approach the value of 1.5E-4 ohm, the total battery resistance would exceed the value allowed in the design basis calculations and may cause excessive voltage drops.

In this instance, the safety related DC equipment may not have adequate voltage across its terminals for performing its intended design functions.

Fermi 2 Design Basis Calculations (Reference 6.2) provides the technical basis for adopting 2700 µ as the Total Allowable Aggregate Battery Resistance value across each 130 VDC (nominal) battery output terminal. Administrative controls are currently in place to ensure compliance with this value. The controls have been implemented in pertinent site procedures to preclude battery resistance values from exceeding the design calculation limits.

In 2013, the NRC completed a CDBI at Fermi 2. In its corresponding Inspection Report (Reference 6.1), the NRC identified a finding of very low safety significance and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for DTEs failure to submit a LAR to revise this non-conservative TS in a timely manner. Furthermore, the NRC noted that since DTE has established and implemented administrative controls for the total battery resistance for some time, these same administrative controls would provide a basis for the request for a TS change.

2.2 Revision of TS SR 3.8.6.3 2.2.1 Proposed Revision TS SR 3.8.6.3 is proposed to be revised as follows:

The SR would be revised to require verification of average electrolyte temperature of representative cells is greater than 70°F.

2.2.2 Basis for Revision Fermi 2 TS SR 3.8.6.3 verifies the average electrolyte temperature of representative cells is > 60°F. In November 2012, revised and reconstituted design basis calculations for the DC batteries were finalized. The design basis calculations addressed sizing of safety related batteries at 70°F, and verified that all safety related equipment required to operate during a design basis accident (DBA) is supported with adequate voltage. Standard Technical Specifications (STS)/NUREG-1433, Vol. 1 (Reference 6.3) includes a surveillance requirement to verify battery cell temperature is greater than or equal to minimum established design limits. This minimum limit has been established in the Fermi design basis reconstituted calculations at 70°F. Pursuant to the identification of to NRC-14-0010 Page 4 this issue, administrative controls have been implemented for maintaining this temperature greater than 70°F as described in NRC Administrative Letter (AL) 98-10 (Reference 6.4) until this LAR has been approved and implemented. The proposed revision to SR 3.8.6.3 will align the TS surveillance requirements with the corresponding plant design bases Calculation.

2.3 Revision of TS SR 3.8.4.8 2.3.1 Proposed Revision TS SR 3.8.4.8 is proposed to be revised as follows:

The SR would be revised to require verification that battery capacity is 80% of the manufacturers rating when subjected to a performance discharge test at 60 months interval; AND at 12 months when the battery shows degradation, or has reached 85%

of the expected life with capacity < 100% of manufacturers rating; AND at 24 months when the battery has reached 85% of the expected life with capacity > 100%

of manufacturers rating.

2.3.2 Basis for Revision In the 2013 CDBI report (Reference 6.1), NRC identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV 05000341/2013008-04),

Degraded Battery Testing Not in Conformance with Design Standards for TS requirements that do not adhere to the IEEE Std. 450 requirement for test frequency.

Fermi 2 TS SR 3.8.4.8 verifies battery capacity is 80% of the manufacturers rating when subjected to a performance discharge test at 60 months interval; and 18 months when battery shows degradation or has reached 85% of expected life. STS/NUREG-1433, Vol. 1 prescribes essentially the same type of test at intervals of 60 months; and 12 months when battery shows degradation, or has reached [85]% of the expected life with capacity < 100% of manufacturers rating; and 24 months when battery has reached

[85]% of the expected life with capacity > 100% of manufacturers rating.

3.0 TECHNICAL EVALUATION

3.1 System Description DC power Class 1E loads at Fermi 2 are supplied from two separate divisions of center-tapped 260 VDC (nominal) batteries. Each division is physically, electrically, and functionally independent of the other division in accordance with IEEE Standard 308 (Reference 6.5) and 10 CFR 50, Appendix A, General Design Criterion 17. The divisional batteries are housed in two separate rooms located on the third floor of the Auxiliary Building, and are separated by a to NRC-14-0010 Page 5 12-in concrete wall. The battery chargers and other related equipment for the Class 1E batteries are located outside the battery rooms, in accordance with the separation criteria required for redundant systems.

Each divisional 260 VDC battery is made up of two 130 VDC (nominal) battery sections of 2 VDC (nominal) cells connected in series, supplying 130 VDC power for control functions and 260 VDC for DC motors and motor-operated valves. Each 130 VDC battery is composed of two rows, each row with 29 cells (Figure 1A). Cell-to-cell connections are accomplished by double-post inter-cell connectors (Figure 1B) and inter-row connections by jumper cabling.

Each 130 VDC battery section has an adequately sized battery charger. Each charger uses a fused connection to charge and keep its respective battery on float voltage during normal operation. For each 260 VDC battery, a 130 VDC spare battery charger is provided as a backup to either one of the normal 130 VDC connected chargers. Charger replacement can be made manually when it has been verified that the charger is properly connected to the pertinent 130 VDC battery.

3.2 Technical Evaluation 3.2.1 Identification of Connection Resistance Issue and Administrative Controls In September 2009, an engineering self assessment (Reference 6.7) identified that the existing design calculations for station safety related batteries did not account for the battery cell-to-cell and terminal connection resistance. Subsequent investigation under the Corrective Action Program identified the non-conservative TS issue with TS SR 3.8.4.2 and SR 3.8.4.5 that verify battery cell-to-cell and terminal connection resistance is 1.5E-4 ohm. Once the non-conservative TS was identified, operability determination via an Engineering Functional Analysis (EFA) (Reference 6.6) was performed to assess the status of the batteries, based on the results of the surveillances for measuring the connection resistance. The EFA verified that resistance values are low enough to demonstrate operability of the batteries. Additionally, as required by NRC Administrative Letter 98-10 (Reference 6.4), administrative controls were established to limit the maximum battery aggregate measured connection resistance for each safety related 130 VDC battery section to 2700 . The administrative controls were implemented in the stations battery surveillance procedures. Administrative Controls will remain effective as an interim corrective action to ensure batteries will continue to perform their design functions until this LAR has been approved by the NRC and implemented at the station.

The non-conservative TS issue surrounding the cell-to-cell and terminal connection resistance is derived from the worst case scenario whereby multiple connection resistances in the battery would simultaneously approach the 150 µ value. In this case, the surveillance tests described under SR 3.8.4.2 and SR 3.8.4.5 would still be met; however, the aggregate of such elevated connection resistances could cause excessive to NRC-14-0010 Page 6 voltage drops and result in insufficient battery terminal voltage for supporting the design function of the supported safety related equipment. The EFA evaluated the maximum allowable as-found 130 VDC Battery Total Aggregate Measured Connection Resistance that would still provide the minimum required voltages to support safety related DC equipment in performing their intended design functions.

The EFA calculated the Total Allowable 130 VDC Battery Aggregate Measured Connection Resistance of 2700µ based on the Battery Manufacturers design and rating parameters, surveillance test data, Updated Final Safety Analysis Report (UFSAR) voltage limits and the Fermi 2 design cycle loads.

Manufacturer inputs include:

The design voltage drop across each cell-to-cell (intercell) connection (30mV);

The design voltage drop across each inter-row connection (100mV); and Various other design ratings related to battery design.

3.2.2 Technical Bases for the 2700 µ and Verification of Equipment Design Functionality The current Fermi 2 design basis calculation (Reference 6.2) provides the technical basis for the 2700 µ value by verifying the design functionality of all safety related equipment with the existing batteries. In the process, the Design Calculation also confirms the adequacy of the battery capacity by calculating the number of positive plates required in each battery to support design functionality and comparing the calculated result with the actual installed number of plates in each battery. The calculation used the ETAP PowerStation qualified software as the platform for modeling and performing the calculations. The methodology utilized can be summarized as follows:

Using the Total Allowable Battery Aggregate Measured Connection Resistance of 2700 µ as a design input parameter to the design calculation. This represents the total measured connection resistance values per 130 VDC battery and includes the cell-to-cell, inter-row and battery lug to post (terminal) connections. Any inter-cell connection resistance (additional R) that is not already accounted for within the battery curves must be directly entered into the ETAP model. This additional R value is determined by finding the difference between the above-stated total battery measured connection resistance and the total connection resistance value accounted for in the battery curve. Since Fermi 2 has 58 cells and 57 inter-cell connections for each 130 VDC battery string, the total connection resistance value accounted for in battery curve is equal to (57 x 15s = 855s).

to NRC-14-0010 Page 7 Summarizing this calculation described above:

Additional R = Total Admin Limit - [(# of cells-1) x (per cell Inter- cell connection resistance accounted for in battery curve)]

Additional R = 2700 - (57 x 15)

Additional R = 1845 This additional resistance of 0.001845 (1845s) was added to the model for the batteries in the ETAP runs used for the Battery Discharge and Sizing analysis.

Screening design bases accident (DBA) scenarios as stipulated in the Fermi 2 UFSAR and selecting those scenarios that potentially give rise to limiting DC loadings. The selection is then used to review the loads and determine the bounding loading scenarios to be used in the computer modeling.

For each loading scenario, performing the voltage drop / load flow for calculating the various bus / node voltages. The battery terminal voltage (cell voltage during discharge) is determined within the software program for the multiple load flow calculations performed in accordance with IEEE Std. 485 (Reference 6.8).

Performing the device terminal voltage calculations for both the automatic DBA actuation paths and the non-automatic actuation paths for safety related devices required to operate. The non-transient voltages from the bounding battery discharge DBA scenarios were compared with the required minimum node voltages determined in the non-automatic path calculations to allow reasonable determination of whether these non-automatic DBA actuation devices could be manually operated individually during non-transient voltage time periods within the DBA event if needed.

For each battery scenario, performing the ETAP battery discharge runs to determine the minimum required battery terminal voltage for each device. The minimum battery sizing voltage can be a different value between the different loading scenarios being evaluated depending on the specific load scenario timing and the limiting load for each loading scenario. The voltage margin was subtracted from the calculated battery terminal voltage for that particular time interval the device is required to operate in order to determine the minimum allowable battery voltage for each load being evaluated.

to NRC-14-0010 Page 8 Selecting among the scenarios the highest minimum of these required minimum allowable battery voltages provides the basis for determining the bounding volt per cell (Vpc) value to be used in the sizing of the battery.

By performing the battery sizing model runs, a confirmation is provided that the existing as-installed batteries have the required number of positive plates (and therefore, capacity) to handle the bounding loads and deliver the terminal battery voltages as already derived above, or that bigger batteries may be required.

Therefore, validation by ETAP model runs of the correct sizing of the existing Fermi 2 safety related batteries confirms that all safety related equipment required to operate in the limiting DBA scenario are provided with adequate voltage support; and also provides a sound technical basis for the 2700 µ value, as the limit of the Total Allowable Battery Aggregate Measured Connection Resistance for each 130 VDC (nominal) battery section.

3.2.3 Alignment of Electrolyte Temperature in TS and Design Basis Calculations Design Basis Calculation (Reference 6.2) demonstrates acceptable results using a 70 degree Fahrenheit electrolyte temperature. The current Fermi 2 TS SR 3.8.6.3 verifies the average electrolyte temperature of representative cells is > 60°F. If the electrolyte temperature were allowed to be as low as the existing TS limit of 60 degrees, adequate capacity would be challenged. This license amendment request will correct this potentially non-conservative TS issue and align the TS with the design basis calculations.

3.2.4 Adjusted Frequency for Performing Capacity Discharge Tests for Degraded Batteries The current Fermi 2 TS SR 3.8.4.8 verifies battery capacity is 80% of the manufacturers rating when subjected to a performance discharge test at 60 months interval and at 18 months when the battery shows degradation or has reached 85% of expected life. The change requested in this LAR brings alignment of the testing frequency specified in this SR with the STS. The proposed change would also address the NRC CDBI finding in Reference 6.1.

The proposed change would result in the verification that battery capacity is 80% of the manufacturers rating when subjected to a performance discharge test at 60 months interval AND at 12 months when the battery shows degradation, or has reached 85% of its expected life with capacity < 100% of manufacturers rating AND at 24 months when the battery has reached 85% of its expected life with capacity 100% of manufacturers rating.

to NRC-14-0010 Page 9 3.3 Implementation of Administrative Controls 3.3.1 Total Allowable Battery Aggregate Measured Connection Resistance The implementation of Administrative Control limits under the Corrective Action Program resulted in the revision to surveillance procedures. The Battery Aggregate Measured Connection Resistance of 2700 µ was added to all the relevant procedures as an acceptance criterion to be met in addition to the existing acceptance criterion of verifying each battery cell-to-cell and terminal connection resistance is 1.5 E-4 ohm.

The battery has to pass both acceptance criteria.

For all surveillance procedures, the Acceptance Criteria are:

Verify each battery cell-to-cell and terminal connection resistance is 1.5E-4 ohm; and Total Allowable Battery Aggregate Measured Connection Resistance 2.7E-3 ohm.

3.3.2 Battery Electrolyte Temperature Currently, Fermi 2 plant operation under TS SR 3.8.6.3, Verify average electrolyte temperature of representative cells is > 60°F is administratively controlled to verify average electrolyte temperature of representative cells is > 70°F in accordance with NRC Administrative Letter (AL) 98-10 (Reference 6.4).

3.3.3 Accelerated Frequency of Battery Capacity Testing The need to perform SR 3.8.4.8 at a frequency of less than the standard 60 months interval due to a degraded or aged battery is currently tracked under the Corrective Action Program. Division 1 (2PA) batteries were initially put in service in April 2000 and Division 2 (2PB) batteries were put in service in April 2009. The table below shows current design basis information regarding battery design parameters. Based on the design age of the batteries, several years remain before any battery reaches its 85% of expected life. SR 3.8.4.8 was last performed in November 2010 on both Division 1 and Division 2 batteries. For all four 130 VDC batteries, the surveillance results verified that battery capacity is > 100% of the manufacturers rating with no degradation. The performance of the next SR 3.8.4.8 testing is currently scheduled in September 2015 for both Division 1 and Division 2 batteries.

to NRC-14-0010 Page 10 The table below provides key design parameters of the safety related batteries at Fermi 2:

% Excess Capacity(1)

Battery Minimum Battery Volt per Aging Over Design Requirement Battery 130VDC Terminal Voltage Cell for Factor LOOP /LOCA (2)

Section (Volt) for Sizing Sizing Applied LOOP / LOCA HPCI / RCIC (3)

Test 2A-1 111.36 1.92 1.25 31.3 26.9 Div. 1 (2PA) 2A-2 111.94 1.93 1.25 13.8 11.9 2B-1 107.30 1.85 1.25 8.47 8.14 Div. 2 (2PB) 2B-2 107.88 1.86 1.18 3.53 3.28 Notes:

(1) % Excess capacity is defined in terms of percentage of the number of installed excess positive plates over design requirement, divided by the number of installed positive plates (2) The LOOP/LOCA Design Basis Accident scenario assumes a concurrent Loss of Offsite Power and a Loss of Coolant Accident that require the initiation of the High Pressure Cooling Injection and Reactor Core Isolation Cooling systems (3) The LOOP/LOCA HPCI / RCIC Test scenario assumes the LOOP / LOCA DBA during HPCI / RCIC testing.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 4.1.1 10 CFR 50.36, Technical Specifications 10 CFR 50.36(b) requires each license authorizing operation of a utilization facility to include technical specifications (TS). 10 CFR 50.36(c) specifies the categories that are to be included in the TS. 10 CFR 50.36(c)(3), which identities Surveillance Requirements (SRs) as one of the categories to be included in the TS, states: Surveillance Requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Revision of the SRs by adding Total Allowable Aggregate Battery Measured Resistance of 2.7E-3 ohm as a parameter to be monitored will ensure that the station DC Systems are able to perform their safety related functions. Thus, the Limiting Condition for Operation (LCO) will continue to be met. Therefore, Fermi 2 will continue to meet this regulation with the proposed changes to TS SR 3.8.4.2 and SR 3.8.4.5.

to NRC-14-0010 Page 11 The alignment of performance / capacity testing with Standard Technical Specifications represents the adoption of best maintenance practice and monitoring of the batterys state of health by making the proposed changes to Fermi 2s TS SR 3.8.4.8.

The change of the electrolyte temperature under TS SR 3.8.6.3 to > 70°F aligns the Fermi 2 TS with the actual operating condition, Standard TS and the station design bases.

Therefore, Fermi 2 will continue to meet this regulation with the proposed changes to TS SR 3.8.6.3.

4.1.2 10 CFR 50, Appendix A, GDC 17 and 18 10 CFR 50, Appendix A, General Design Criterion (GDC) 17, Electric Power Systems, states, in part: An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specific acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences, and (2) the core is cooled, and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

10 CFR 50, Appendix A, GDC 18, Inspection and Testing of Electric Power Systems, requires, in part: Electric power systems important to safety shall be designed to permit appropriate periodic inspection of important areas and features...

Revision of the SRs as herein proposed does not affect Fermi 2 compliance with GDC 17 and 18.

4.1.3 10 CFR 50.63, Loss of All Alternating Current Power 10 CFR 50.63(a), Requirements, requires, in part: Each light-water-cooled nuclear power plant licensed to operate under this...must be able to withstand for a specified duration and recover from a station blackout as defined in 10 CFR 50.2...

Revision of the SRs as herein proposed will not affect compliance with the above regulation.

to NRC-14-0010 Page 12 4.2 Precedent Previous NRC approvals of similar LARs for revisions to TS SR 3.8.4.2 and SR 3.8.4.5 battery connection resistance values include the following:

1) Callaway Plant, Unit 1a - Issuance of Amendment (TAC No. ME0292), dated December 9, 2009. [NRC ADAMS Accession No. ML093220075.]

2) Cooper Nuclear Station - Issuance of Amendment (TAC No. ME0848), dated March 18, 2010. [NRC ADAMS Accession No. ML100610233.]

3) Wolf Creek Generating Station - Issuance of Amendment (TAC No. ME2965),

dated December 20, 2010. [NRC ADAMS Accession No. ML103190469.]

4) McGuire Nuclear Station, Units 1 and 2 - Issuance of Amendment (TAC Nos.

ME2936 and ME2937), dated December 20, 2010. [NRC ADAMS Accession No. ML103270096.]

5) Turkey Point, Units 3 and 4 - Issuance of Amendment (TAC Nos. ME6859 and ME6860), dated August 8, 2012. [NRC ADAMS Accession No. ML12208A298.]

6) St. Lucie Plant, Units 1 and 2 - Issuance of Amendment (TAC Nos. ME9297 and ME9298), dated June 18, 2013. [NRC ADAMS Accession No. ML13150A337.]

Other similar LARs for revisions to TS SR 3.8.4.2 and SR 3.8.4.5 battery connection resistance values currently under NRC review include the following:

1) River Bend Station, Unit 1 - LAR, dated February 7, 2013. [NRC ADAMS Accession No. ML130944A058.]

2) Quad Cities Nuclear Power Station, Units 1 and 2 - LAR, dated June 10, 2013.

[NRC ADAMS Accession No. ML13161A315.]

4.3 No Significant Hazards Consideration Determination In accordance with 10 CFR 50.92, DTE has made a determination that the proposed amendment involves no significant hazards consideration. Revision of the SRs, by:

Adding a Total Allowable Aggregate Battery Measured Resistance of 2.7E-3 ohm as another Acceptance Criterion to be monitored; Increasing the average electrolyte temperature of representative cells to be verified from 60°F to 70°F; and Accelerating the surveillance frequency from 18 months to 12 months when the battery shows degradation or has reached 85% of expected life with capacity < 100%

of manufacturers rating; and adding a surveillance frequency of 24 months when the battery has reached 85% of the expected life with capacity 100% of manufacturers rating; to NRC-14-0010 Page 13 does not involve a significant hazards consideration based on the responses to the following questions:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Performing the proposed changes in battery parameter surveillance testing and verification is not a precursor of any accident previously evaluated. Furthermore, these changes will help to ensure that the voltage and capacity of the batteries is such that they will provide the power assumed in calculations of design basis accident mitigation.

Therefore, DTE concludes that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not involve any modification of the plant or how the plant is operated; they only involve surveillance testing and verification activities. Therefore, DTE concludes that these proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding, the reactor coolant system, and the containment system. The performance of the fuel cladding, reactor coolant, and containment systems will not be impacted by the proposed changes.

The proposed Fermi 2 revisions of the SRs ensure the continued availability and operability of the batteries. As such, sufficient DC capacity to support operation of mitigation equipment remains within the design basis. Therefore, DTE concludes that the proposed changes do not involve a significant reduction in the margin of safety.

to NRC-14-0010 Page 14 4.4 Conclusions Based on the above evaluation, DTE concludes that the proposed license amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.

5.0 ENVIRONMENTAL CONSIDERATION

S DTE has reviewed the proposed changes against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor do they significantly change the types or significantly increase the amounts of effluents that may be released offsite. The proposed changes do not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, DTE concludes that the proposed changes meet the criteria provided in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement or and Environmental Assessment.

to NRC-14-0010 Page 15

6.0 REFERENCES

6.1 Fermi Power Plant, Unit 2, NRC Component Design Bases Inspection (CDBI) Report 05000341/2013008, dated October 29, 2013. [ADAMS Accession Number ML13302B260.]

6.2 Fermi 2 Design Calculation DC-6480, Vol. I, Rev. A, 130/260V DC System Analysis, dated July 9, 2013.

6.3 Standard Technical Specifications (STS)/NUREG-1433, Vol. 1.

6.4 NRC Administrative Letter 98-10, Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety, dated December 29, 1998.

6.5 IEEE Standard 308-1971, IEEE Standard Criteria for Class IE Electric Systems for Nuclear Power Generating Stations.

6.6 Fermi 2 Engineering Functional Analysis, EFA-R32-10-003, Rev. 0, dated February 21, 2010.

6.7 Fermi 2 CARD 09-27471, 2009 CDBI Self-Assessment - The Cell-to-cell and Terminal Connection Resistance May Need to be addressed in DC-213 (09SA-RFI-001), dated September 25, 2009.

6.8 IEEE Std. 485 6.9 IEEE Std. 450-1972.

to NRC-I14-0010 Page 16 FIGURE lA BATTERY CONFIGURATION C

n N _

CC 116 115 14 1 - 90 E8 88 to NRC-14-0010 Page 17 FIGURE 1B BATTERY INTER-CELL CONNECTORS RESISTANCE MEASUREMENTS NOTE: The resistance of intertier and interrack-connections, with or without connection plates, can be performed using the following steps.

1.0 Measure the intercell connection resistance of each intercell connection by measuring:

1.1 From terminal post A to terminal post C.

1.2 From terminal post B to terminal post D.

2.0 -Record measurements.

POST A POST B POTC INTERCELL STRAP tOST D (POSIiVE) (NEGATNE)

(NEGATNVE) (POSITNE INTERCELL STRAP

Enclosure 2 to NRC-14-0010 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Marked-Up Pages of Existing Fermi 2 TS Pages:

3.8-17, 3.8-18 &

3.8-24

DC Sources Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is 7 days 125.7 V on float charge.

SR 3.8.4.2 Verify no visible corrosion at battery 92 days terminals and connectors.

OR Verify each battery cell-to-cell and terminal connection resistance is 1.5E-4 ohm.

AND Verify total battery cell-to-cell and terminal connection resistance is 2.7E-3 ohm.

SR 3.8.4.3 Verify battery cells, cell plates, and 18 months racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

SR 3.8.4.4 Remove visible corrosion and verify battery 18 months cell to cell and terminal connections are coated with anti-corrosion material.

SR 3.8.4.5 Verify each battery cell-to-cell and 18 months terminal connection resistance is 1.5E-4 ohm.

AND Verify total battery cell-to-cell and terminal connection resistance is 2.7E-3 ohm.

SR 3.8.4.6 Verify each required battery charger 18 months supplies 100 amps at 124.7 V for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

(continued)

FERMI - UNIT 2 3.8-17 Amendment No. 134, 136

DC Sources Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.7 -------------------NOTE-------------------

The performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4.7 once per 60 months.

Verify battery capacity is adequate to 18 months supply, and maintain in OPERABLE status, the actual or simulated emergency loads for the design duty cycle when subjected to a battery service test.

SR 3.8.4.8 -------------------NOTE------------------

This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR.

60 months Verify battery capacity is 80% of the manufacturer's rating when subjected to a AND performance discharge test.

1218 months when battery shows degradation or has reached 85% of expected life with capacity 100% of manufacturers rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturers rating FERMI - UNIT 2 3.8-18 Amendment No. 134

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet 92 days Table 3.8.6-1 Category B limits.

AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after battery discharge

< 105 V AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after battery overcharge

> 145 V SR 3.8.6.3 Verify average electrolyte temperature of 92 days representative cells is > 6070F.

FERMI - UNIT 2 3.8-24 Amendment No. 134, 136

Enclosure 3 to NRC-14-0010 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Clean Pages of Fermi 2 TS Pages: