NRC-17-0056, Supplemental Information Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3

Supplemental Information Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3

ML17228A082
Person / Time
Site:	Fermi
Issue date:	08/15/2017
From:	Polson K DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-17-0056
Download: ML17228A082 (5)

Text

Keith J. Poison Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: keith.polson <<dteenergy.com DTE Energy August 15, 2017 NRC-17-0056 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 Letter to NRC, "License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, 'TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing'," NRC-16-0036, dated July 25, 2016 (ML16207A433)

Subject:

Supplemental Information Regarding License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3 In Reference 2, DTE Electric Company (DTE) submitted a license amendment request (LAR) to revise the Technical Specifications (TS) to adopt TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing." Supplemental information regarding the LAR is enclosed. The supplemental information does not impact the conclusions of the Regulatory Analysis, including the no significant hazards consideration, documented in Reference 2.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 15, 2017 Keith J. Polson Site Vice President

USNRC NRC-17-0056 Page 2

Enclosure:

Supplemental Information for License Amendment Request to Adopt TSTF-545, Revision 3 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)

Enclosure to NRC-17-0056 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information for License Amendment Request to Adopt TSTF-545, Revision 3

Enclosure to NRC-17-0056 Page 1 Supplemental Information DTE Electric Company (DTE) submitted a License Amendment Request (LAR) to revise the Fermi 2 Technical Specifications (TS) on July 25, 2016 (Reference 1). The LAR requested to adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing. Specifically, the proposed changes were to eliminate the Section 5.5.6, Inservice Testing and Inspection Program, from the TS. The DTE LAR was based on the model LAR provided in TSTF-545, Revision 3. Section 2.2 of the DTE LAR identified optional changes and variations specific to Fermi 2. Subsequent review determined that Section 2.2 did not describe an additional variation taken from the TSTF-545, Revision 3, model LAR. This supplement provides information regarding the additional variation.

The conversion of the Fermi 2 TS to adopt the BWR/4 Standard Technical Specifications (STS) in NUREG-1433 (Reference 2) was approved by the NRC as License Amendment 134 (Reference 3).

During this conversion to STS, DTE chose to combine the Inservice Testing (IST) Program and the Inservice Inspection (ISI) Program into a single TS in Section 5.5.6 called the Inservice Testing and Inspection Program. Inclusion of the ISI Program in TS 5.5.6 at that time was a departure from the STS in NUREG-1433. TS 5.5.6 is the only place in the Fermi 2 TS where the ISI Program is explicitly referenced, unlike the IST Program which is explicitly referenced from multiple Surveillance Requirements (SRs) as indicated in the LAR.

In the background information, TSTF-545, Revision 3, states that:

[R]estructuring Technical Specifications (TS) chapters during the development of the Improved Standard Technical Specifications (ISTS) resulted in unintended consequences when Section 3.0, Surveillance Requirement Applicability, provisions were made applicable to Section 5.0 TS. The NRC staff concluded that Surveillance Requirement (SR) 3.0.2 and SR 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR.

TSTF-545, Revision 3, further states that:

[I]f a licensee finds that the requirements of the TS conflict with the requirements of 10 CFR 50.55a, then the licensee must amend their TS to comply with 10 CFR 50.55a.

Consistent with this discussion, the Fermi 2 conversion to STS created the unintended consequence where Section 3.0 SR provisions were made applicable to TS 5.5.6, which included both the IST Program and the ISI Program. In order to meet the intent of TSTF-545, both the IST Program and ISI Program needed to be addressed since they had been combined in the Fermi 2 TS. Therefore, the Fermi 2 LAR also eliminated the ISI Program requirements currently contained in TS 5.5.6. This was indicated by the markup of TS 5.5.6 included in the LAR, but was not explicitly discussed in the text of the LAR. The TSTF-545, Revision 3, model LAR also did not explicitly discuss removal of the ISI Program since the BWR/4 STS in NUREG-1433 do not contain requirements for ISI, only IST. This variation is an administrative change to maintain consistency with the STS in NUREG-

Enclosure to NRC-17-0056 Page 2 1433. NUREG-1433 does not contain ISI requirements. Requirements to perform inservice inspection of Class 1, 2, and 3 components in accordance with the American Society of Mechanical Engineers (ASME)Section XI are contained in 10 CFR 50.55a and are governed by the ISI Program at Fermi 2. The proposed change does not eliminate any inservice inspections. Inservice inspections are covered by the existing ISI Program required by 10 CFR 50.55a, and do not meet the criteria of 10 CFR 50.36, Technical Specifications. Further, the ISI Program is described in Section 5.2 of the Updated Final Safety Analysis Report (UFSAR). Revision of this item in TS does not impact DTEs implementation or performance of the ISI Program.

The removal of the ISI Program requirements along with the IST Program requirements from the Fermi 2 TS as part of the adoption of TSTF-545, Revision 3, is consistent with the license amendment request for Limerick (Reference 4) which was previously reviewed and approved by the NRC (Reference 5). In addition, the NRCs model safety evaluation for adoption of TSTF-545, Revision 3, includes a discussion of both inservice inspection and inservice testing in Section 2.3, Regulatory Requirements, Licensing Information, Guidance Documents, and indicates that the requirements are contained in 10 CFR 50.55a.

In summary, removal of the ISI Program along with the IST Program from Section 5 of the Fermi 2 TS is necessary to meet the intent of TSTF-545 and maintain consistency with NUREG-1433. The TS markups and clean pages associated with this change were previously provided in Enclosures 2 and 3 of the original LAR. Although this change was not explicitly discussed in the text of the original LAR, it is an administrative variation from TSTF-545 as described in the supplemental information above. There is no impact on the no significant hazards conclusion in the original LAR as the ISI requirements eliminated from the TS are duplicative of those in 10 CFR 50.55a.

References

1. Letter from DTE to U. S. NRC, NRC-16-0036, License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, dated July 25, 2016 (ML16207A433).

2. Letter from DTE to U. S. NRC, NRC-98-0043, Proposed Technical Specification Change (License Amendment) - Conversion to Improved Standard Technical Specifications, dated April 3, 1998.

3. Letter from U. S. NRC to DTE, Fermi 2 Issuance of Amendment Re: Conversion of Current Technical Specifications to Improved Technical Specifications (TAC No. MA1465), dated September 30, 1999.

4. Letter from Exelon (Limerick Generating Station) to U. S. NRC, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, dated July 26, 2016 (ML16210A227).

5. Letter from U. S. NRC to Exelon, Limerick Generating Station, Units 1 and 2 - Issuance of Amendments to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-545 (CAC Nos. MF8193 and MF8194), dated May 16, 2017 (ML17103A081).