NRC-21-0045, Response to Request for Additional Information Regarding License Amendment Request to Revise the Fermi 2 Technical Specifications

Response to Request for Additional Information Regarding License Amendment Request to Revise the Fermi 2 Technical Specifications

ML21229A090
Person / Time
Site:	Fermi
Issue date:	08/17/2021
From:	Peter Dietrich DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-21-0045
Download: ML21229A090 (9)

Text

Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: peter.dietrich@dteenergy.com 10 CFR 50.90 August 17, 2021 NRC-21-0045 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Response to Request for Additional Information Regarding License Amendment Request to Revise the Fermi 2 Technical Specifications

References:

1) DTE Letter NRC-21-0001, License Amendment Request to Revise Technical Specifications to Remove Obsolete Information, Make Minor Corrections, and Make Miscellaneous Editorial Changes, dated March 31, 2021 (ML21090A194)

2) NRC E-mail Capture, Fermi 2 - License Amendment Request: Request for Additional Information (EPID L-2021-LLA-0057), dated July 23, 2021 (ML21214A149)

In Reference 1, DTE Electric Company (DTE) submitted a license amendment request to revise the Fermi 2 Technical Specifications (TS). In the Reference 2 email from Mr. Surinder Arora to Ms. Margaret Offerle dated July 23, 2021, the NRC sent DTE a Request for Additional Information (RAI) regarding the license amendment request. The response to the RAI is provided in Enclosure 1. As described in the RAI response in Enclosure 1, updates to the proposed TS mark-ups and clean pages are provided in Enclosures 2 and 3, respectively.

No new commitments are being made in this submittal.

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

Bennett III, Manager - Nuclear Licensing, at (734) 586-4273.

USNRC NRC-21-0045 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 17, 2021 Peter Dietrich Senior Vice President and Chief Nuclear Officer

Enclosures:

1) Response to Request for Additional Information

2) Update to Proposed Technical Specification Changes (Mark-Up)

3) Update to Revised Technical Specification Pages cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure 1 to NRC-21-0045 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information to NRC-21-0045 Page 1 Response to Request for Additional Information (RAI)

NRC RAI REQUEST FOR ADDITIONAL INFORMATION PROPOSED LICENSE AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.5.4.1.c FERMI NUCLEAR GENERATING STATION, UNIT 2 DTE ELECTRIC COMPANY DOCKET NO. 50-341

References:

1. Letter dated March 31, 2021 (Agencywide Documents Access Management System (ADAMS)

Accession Number ML21090A194) from DTE Electric Company, proposing revisions to Fermi 2 technical specifications (TS) to remove some obsolete information, make minor corrections, and make miscellaneous editorial changes.

2. Fermi 2 technical specification (ADAMS Accession No. ML053060228).

3. NUREG-0667, Probability of the Intersystem LOCA: Impact Due to Leak Testing and Operation Changes, (ADAMS Accession No. ML19323E667).

The NRC staff has reviewed the Fermi 2 license amendment request (Reference 1), specifically, the proposed change to TS surveillance requirement (SR) 3.4.5.1.c, and requires the following additional information to complete its review:

EMIB-RAI-1:

The amendment request proposes a change in the wording of SR 3.4.5.1.c for isolation check valves (E1100F050A and E1100F050B) from the term testable check valves to just valves.

The current TS 3.4.5 uses description of these isolation valves as check valves. The NRC staff also reviewed the Fermi 2 TS Bases, the Inservice Testing (IST) Program, and the NRC approved Alternative Request No. RR-VRR-003 (ADAMS Accession No. ML20014E731) and found that all these documents describe these isolation valves as testable check valves. Furthermore, the Fermi 2 TS Bases 3.5.4 states, in part, that A study (NUREG-0677) evaluated various PIV configurations to determine the probability of intersystem LOCAs. This study concluded that periodic leakage testing of the PIVs can substantially reduce intersystem LOCA probability.

This study cited in NUREG-0677 only considered check valves, for evaluation. Therefore, NRC staff considers the proposed change to be inconsistent with the terminology used in other documents and these isolation valves should be check valves instead of just valves.

Based on the above, please justify the proposed change to SR 3.4.5.1.c which changes the term testable check valves to just valves.

to NRC-21-0045 Page 2 DTE RESPONSE As identified in the license amendment request submitted by DTE Electric Company (DTE) letter NRC-21-0001 dated March 31, 2021 (ML21090A194), Fermi 2 Technical Specification (TS) Surveillance Requirement (SR) 3.4.5.1.c was proposed to be revised to change inboard injection isolation testable check valves to inboard injection isolation valves. The intent of the proposed change was to remove the unnecessary descriptive text of the subject valves to ensure the purpose of the SR (i.e., leak rate testing) was clear. As identified in the NRCs RAI, the inboard injection isolation valves being check valves may have been part of the technical basis considered when determining requirements. Therefore, elimination of the word check in the proposed mark-up in letter NRC-21-0001 may have been more than an administrative change. To ensure that the basis for the changes in the proposed license amendment request remains that the changes are administrative in nature, the proposed TS mark-up of SR 3.4.5.1.c will be modified as shown in Enclosure 2 to retain the word check; only the word testable will be removed. The updated TS clean page is provided in Enclosure 3.

DTE has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Sections 5.1 and 6.0 of of the license amendment request in DTE letter NRC-21-0001. The minor modification to the proposed TS changes provided in this RAI response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

Enclosure 2 to NRC-21-0045 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Update to Proposed Technical Specification Changes (Mark-Up)

RCS PIV Leakage 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 -------------------NOTE--------------------

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV, In accordance at an RCS pressure 1035 and 1055 psig: with the INSERVICE

a. For PIVs other than LPCI loop A and B TESTING PROGRAM injection isolation valves is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm;

b. For LPCI loop A and B outboard injection isolation valves is 0.4 gpm through-seat, and 5 ml/min external leakage; and

c. For LPCI loop A and B inboard injection isolation testable check valves is 10 gpm.

delete text FERMI - UNIT 2 3.4-12 Amendment No. 134, 207

Enclosure 3 to NRC-21-0045 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Update to Revised Technical Specification Pages

RCS PIV Leakage 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 -------------------NOTE--------------------

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV, In accordance at an RCS pressure 1035 and 1055 psig: with the INSERVICE

a. For PIVs other than LPCI loop A and B TESTING PROGRAM injection isolation valves is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm;

b. For LPCI loop A and B outboard injection isolation valves is 0.4 gpm through-seat, and 5 ml/min external leakage; and

c. For LPCI loop A and B inboard injection isolation check valves is 10 gpm.

FERMI - UNIT 2 3.4-12 Amendment No. 134, 207