NRC-23-0059, Response to Request for Additional Information Exigent License Amendment Request for Technical Specification 3.7.2,Emergency Equipment Cooling Water (Eecw)/Emergency Equipment Service Water (Eesw) System and Ultimate Heat Sink (UHS)

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Response to Request for Additional Information Exigent License Amendment Request for Technical Specification 3.7.2,Emergency Equipment Cooling Water (Eecw)/Emergency Equipment Service Water (Eesw) System and Ultimate Heat Sink (UHS)
ML23237B419
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 08/25/2023
From: Peter Dietrich
DTE Electric Company
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-23-0059
Download: ML23237B419 (1)
v • d • e


Text

Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Email: peter.dietrich@dteenergy.com DTE August 25, 2023 10 CFR 50.90 NRC-23-0059 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 Exigent License Amendment Request for Technical Specification 3.7.2,Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)

References:

1) DTE Letter NRC-23-0050, Exigent License Amendment Request for Technical Specification 3.7.2, Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), dated August 10, 2023 (ML23222A037)
2) NRC E-mail Capture, Request For Additional Information Changes to TS 3.7.2, Emergency Equipment Cooling Water (EECW)/ Emergency Equipment Service Water (EESW) System And Ultimate Heat Sink (UHS)

(EPID L-2023-LLA-0112) (ML23235A182)

3) NRC E-mail Capture, Request For Additional Information Changes to TS 3.7.2, Emergency Equipment Cooling Water (EECW)/ Emergency Equipment Service Water (EESW) System And Ultimate Heat Sink (UHS)

(EPID L-2023-LLA-0112)

In Reference 1, DTE Electric Company (DTE) submitted an Exigent license amendment request to revise the Fermi 2 Technical Specifications (TS). In the Reference 2, an email from Mr.

Surinder Arora to Mr. Eric Frank dated August 22, 2023, 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. contains an updated Section 2.3 of Enclosure 1 from the original LAR. This update is in support of RAI #10. In Reference 3, an email from Mr. Surinder Arora to Mr. Eric Frank dated August 24, 2023, the NRC sent DTE an additional RAI regarding the license amendment request.

USNRC NRC-23-0059 Page2 No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr. Eric Frank, Manager- Nuclear Licensing, at (734) 586-4772.

I declare under penalty of pe1jury that the fo

  • true and correct.

Peter Dietrich Senior Vice President and Chief Nuclear Officer : Response to Request for Additional Information : Update to Proposed Technical Specification Changes (Mark-Up) : Update to Revised Technical Specification Pages : Revised Section 2.3 from NRC-23-0050 Enclosure 1 cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure 1 to NRC-23-0059 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information to NRC-23-0059 Page 1 Response to Request for Additional Information By application dated August 10, 2023 (ADAMS) Accession No. ML23222A037), DTE Electric Company requested changes to the technical specifications for Fermi 2. The proposed changes would modify the TS to include a footnote to TS 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), Condition A, one reservoir inoperable, Required Action A.1, Restore reservoir to OPERABLE status, with a Completion Time (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 for up to 7 days to repair the Division 1 MDCT A and C fan pedestals during the current operating Cycle 22.

The regulation in 10 CFR 50.36(c)(2)(i) states in part:

Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

In reviewing the submitted information, the U.S. Nuclear Regulatory Commission staff has developed the below request for additional information to complete the review of your application.

Request for Additional Information SCPB questions:

GDC 44 requires redundance in components and features, and suitable interconnection, leak detection, and isolation capabilities. As indicated in Fermi UFSAR Section 3.1.2.4.1.5, the RHRSW, EESW, and the EDG service water systems are designed in accordance with Criterion 44 to transfer heat from SSCs important to safety to the ultimate heat sink under normal operating and accident conditions and suitable redundancy to accommodate a single failure without hindering the safety function of the systems. 10 CFR 50.65(a)(4) states the following:

Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

The staff request additional information related to risk configuration during maintenance:

1. Discuss Division 2 (D fan) component resolution. On July 19, 2023 (approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> into the 72-hour TS LCO completion time), you identified the vibrations were caused by a degraded mounting between the gear reducer and its pedestal, degraded bushings on the to NRC-23-0059 Page 2 driveshaft coupling to the gear reducer, or both." Confirm whether Mechanical Draft Cooling Tower (MDCT) fan A & C are experiencing similar vibration or operational issues.

DTE Response to SCPB 1:

Mechanical Draft Cooling Tower (MDCT) Division 1 fan pedestals A & C do not currently exhibit evidence of similar vibration or operational issues. Monthly surveillances have been performed without tripping the vibration switch and associated relay. As discussed in Section 2.2 of LAR NRC-23-0050 (ML23222A037), Fermi did find that the MDCT A & C fan pedestals were also degraded and non-conforming but remained operable. Fermi intends to inspect and repair them as needed to avoid a failure similar to the MDCT Division 2 fan pedestal D.

2. Licensee has performed resolution of issues related to MDCT Division 2 (D fan) via enforcement discretion actions. Confirm status of alternate Division 2 MDCT Fan B and whether similar corrosion or operational issues are noted in Fan B pedestal.

DTE Response to SCPB 2:

As discussed in NOED NRC-23-0049 (ML23205A139), Division II MDCT fan B has performed satisfactorily.

It is known that the MDCT Fan Pedestal B is in a non-conforming condition, it had been inspected and repaired in 2009 and has not been exposed to the environmental conditions for as long as Fan A and C. MDCT Fans A and C are original and have not had maintenance performed on them. Based on this, there is a low probability of significant corrosion on MDCT Fan B pedestal and there is less urgency to repair the MDCT Fan B pedestal prior to the next refueling outage this spring (RF22).

3. During maintenance of either Fan A or C, clarify whether this results in unavailability of both fans of same division (i.e., complete MDCT inoperable and unavailable). Confirm PRA analysis has accounted for both Fans A & C being unavailable during maintenance.

DTE Response to SCPB 3:

Only one fan (A or C) will be taken out of operation at a time for repair, there will be no time when both fans of the same division are out of service simultaneously. Therefore, having both fans being unavailable is not included in the Fermi PRA analysis NRC-23-0050 Enclosure 4. In the PRA analysis the Common Cause Factor (CCF) contributions involving the MDCT A (or C) were modified to remove the subject component and to only include failures of the remaining components.

to NRC-23-0059 Page 3

4. Due to lack of redundancy during maintenance, provide discussion of contingency plans or backup capability in the event of issue with either operable fan (B or D) or supported SSCs during the maintenance. For example:
a. Discuss any piping cross-ties between EESW, RHRSW or DGSW divisions (other than reservoir) available to provide inventory to either Div 1 & 2 equipment with operable MDCT during maintenance.
b. Describe any non-safety systems available as defense in depth in case of an accident or event.

DTE Response to SCPB 4:

4.a Fermi does not have the ability to cross tie between Division I and II Systems.

4.b The three systems (Standby Feedwater [SBFW], Hardened Containment Vent and FLEX) listed in Section 3.2 of LAR NRC-23-0050 will be excluded from elective maintenance and be available for defense in depth. Fermi would also be able to release decay heat using the steam lines to the condenser. The FLEX equipment remains available if needed to provide supplemental cooling.

5. Fermi is requesting 14 days of inoperable MDCT (7 days per division) to perform maintenance on MDCT fans separately. Provide discussion on why foundations and operational issues arent resolved in parallel to minimize inoperable duration.

DTE Response to SCPB 5:

The foundation and operational issues are not resolved in parallel in order maintain defense-in-depth and continue to have three fans available while performing the maintenance (Division II fans and either MDCT Fan A or C). In addition, the maintenance resources required to perform the maintenance for a single fan not easily allow performing repairs on both fans at one time. This is not only a personnel availability concern, but would also require using separate lifting and rigging equipment and cranes in the same general area (footprint).

APLB Question:

6. An application of this nature (a risk-informed TS change) should follow the Four-Element Approach to Integrated Decisionmaking for Risk-Informed TS Changes, (as described in RG 1.177 An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications) or an alternative, similarly comprehensive, approach.

RG 1.177, Revision 1, May 2011, Sections B, states:

In implementing risk-informed decisionmaking, TS changes are expected to meet a set of key principles to NRC-23-0059 Page 4 Regulatory Guide 1.174 provides additional information regarding the staffs expectations with respect to implementation of these principles. Each of these principles should be considered in the risk-informed, integrated decisionmaking process...

Although the LAR relies on the RG for quantitative acceptance criteria, the LAR does not appear to include discussion of the four elements described in the RG. Provide this discussion. This discussion should include defense-in-depth, safety margin, and performance monitoring, along with the rest of the information described in the RG 1.177 approach.

DTE Response to APLB 6:

Below is a summary of how NRC-23-0050 addresses and is compliant with the four-element approach of RG 1.177.

Element 1: Define the Proposed Change The reason for the proposed change is to allow for online proactive repair of the MDCT Division I A & C Fan Pedestals, which are currently in a degraded condition and is described in detail in Enclosure 1 of LAR NRC-23-0050.

Element 2: Perform Engineering Analysis The intent of the license amendment request is to allow additional time to restore the fan pedestals to their original design configuration. LAR NRC-23-0050 documents the engineering analysis to justify the temporary completion time extension. The fan pedestals will continue to comply with regulatory requirements as documented in Section 4.0 of Enclosure 1. Adequate defense in depth is maintained and documented Section 4 of Enclosure 4. The extended completion time is temporary, and no design change is being made therefore, the plant continues to maintain sufficient safety margin as discussed in Section 4.3 of Enclosure 1. The risk associated with operating the plant with one Division 1 RHRSW MDCT Fan unavailable for a period of 7 days was found to meet the thresholds of RG 1.177. To augment this evaluation, risk will be minimized during the proposed extended completion time by implementation of the compensatory measures described in this evaluation. These compensatory measures will be in effect prior to entry into the period of unavailability. This risk conclusion is documented in Section 6.0 of Enclosure 4.

Element 3: Define Implementation and Monitoring Program Element 3 is not applicable to this license amendment request because the completion time extension is temporary to restore the fan pedestals to their original design. The completion time will be restored to its original duration to ensure operational safety does not degrade over time.

to NRC-23-0059 Page 5 Element 4: Submit Proposed Change The evaluations performed to justify the proposed TS changes have been documented, maintained, and included in the license amendment request submittal NRC-23-0050 in accordance with Section C.6 of RG 1.174.

EMIB Question:

7. The LAR does not discuss TS surveillances or Inservice Testing (IST) program tests during the repair time of the MDCT A and C fan pedestals while Fermi 2 is online. What are the plans to avoid TS surveillances and IST program tests during the repair time for the MDCT A and C fan pedestals that might cause an inadvertent plant trip?

DTE Response to EMIB 7:

Surveillances and testing were addressed in NRC-23-0050 Enclosure 4 Section 6. While in the proposed extended Completion Time (CT), overall plant risk will be managed by the existing Configuration Risk Management Program (CRMP). This program evaluates increases in risk posed by potential combinations of equipment out-of-service and potential increases in initiating event frequency and requires that risk management actions be implemented as appropriate for a given plant configuration. Maintenance and testing during the allowed completion time extension will be scheduled for Fermi 2 as warranted to minimize aggregate risk. This will specifically include work performed on safety significant systems and their applicable support systems. Emergent Conditions will be evaluated by operations under the CRMP.

STSB Questions:

8. Not all of the compensatory measures included in the July 26, 2023 NOED are included in the LAR. Provide a discussion describing why the excluded compensatory measures are no longer needed for this proposed one-time extended completion time.

DTE Response to STSB 8:

The risk quantification performed for this LAR resulted in different risk contributors than those identified in the July 2023 NOED. This was due to both a change in the division affected by the equipment unavailability and the impact of the common cause factor changes.

A review of the results under this LAR identified different contributors which are addressed using different compensatory measures as identified in the risk evaluation.

9. The proposed TS markups appear to have potential for misinterpretation by licensee operators and NRC inspectors. Please clarify the proposed Fermi 2, TS 3.7.2 marked-up pages by addressing the following elements:

to NRC-23-0059 Page 6

a. Revise the footnote to specify that it is limited to a one-time use of the CT extension to 7 days for each applicable Division I MDCT fan pedestals (A and C), regardless of whether maintenance is completed during the attempt.
b. The extended completion time is contingent on the compensatory measures listed in the LAR. In the TS 3.7.2 footnote, reference the document (the LAR) that contains the list of all compensatory measures, explicitly making them requirements.

DTE Response to STSB 9:

The proposed footnote for TS 3.7.2 (mark-up page) has been revised to address RAI questions 9.a and 9.b and is included in Enclosure 2. A revised TS 3.7.2 (clean) is included in Enclosure 3.

10. Section 2.3 of the LAR states in part:

The proposed license amendment would revise the LCO 3.7.2, Condition A Completion Time, LCO 3.8.1, Condition B Completion Time, and LCO 3.8.4, Condition A by adding the following footnotes The LCO 3.7.2 Actions NOTES requires entry into LCO 3.8.1 and LCO 3.4.8, and LCO 3.0.6 appears to limit the LCOs required to be entered to these. Verify that the wording in LAR section 2.3 regarding LCO 3.8.4 referenced above is correct and was not a transposition error that should be LCO 3.4.8 as required by the note.

The only TS proposed to be revised by this LAR is LCO 3.7.2. As currently worded, the completion times for LCO 3.4.8 Condition A and LCO 3.8.1 Condition B would not be extended. These Conditions and Required Actions are required to be entered by the 3.7.2 Note. Verify this is the intent of LAR, or if footnotes should be included for those LCOs, or those LCOs be included in the LCO 3.7.2 footnote.

DTE Response to STSB 10:

Section 2.3 of LAR NRC-23-0050 is not correct. LCOs 3.8.1 and 3.8.4 do not require a footnote. Enclosure 4 contains the revised Section 2.3 to show that the footnote is being added to only LCO 3.7.2. For RHR Shutdown Cooling (SDC) subsystems to be operable, it requires Residual Heat Removal Service Water (RHRSW) to be operable and this would be covered under Fermis procedure MOP05, Safety Function Determination (SFD), for the Ultimate Heat Sink (UHS). Using a SFD, the Max Out of Service Time (MOST) extends the time action that is required ie. - UHS LCO time is added. Therefore, having the UHS LCO extended per the exigent LAR does not require a note for the impacted LCO's under to NRC-23-0059 Page 7 the SFD (TS's 3.5.1, 3.6.2.3, 3.6.2.4, 3.6.4.3, 3.7.1, 3.7.4, 3.7.8, 3.8.4, 3.8.7). These TSs would be entered, but the actions would delayed as allowed by LCO 3.0.6 and the use of the SFD. This is also true for TS 3.8.1 which has a completion time of 14 days is not impacted by this exigent LAR.

11. The July 26, 2023 NOED states:

Inoperability of the UHS, EECW and EESW systems also caused entry into TS 3.8.7, Distribution Systems - Operating, Conditions A and B, TS 3.8.4, DC Sources -

Operating, Condition B, and TS 3.7.8, Emergency Diesel Generator Service Water EDGSW) System, Condition A which initiated entry into TS 3.8.1, AC Sources -

Operating, Condition B Will these conditions be entered during the planned maintenance described in the LAR?

Describe how the plant will maintain compliance with the TS for the supported systems.

DTE Response to STSB 11:

The conditions will not be entered, see response to RAI 10.

Additional RAI Question (added 8/24/2023):

12. DTEs amendment request letter dated August10, 2023, states, This request is to enable DTE to perform this maintenance online and avoid a potential unnecessary plant shutdown or need for enforcement discretion without a corresponding health and safety benefit.

Given that Fermi 2 is currently in a forced shut down, to address the pipe leakage in the drywell, (1) explain why maintenance of the MDCT A and C fan pedestals cannot be performed in the present situation; and (2) provide updated justification to support an exigent request.

DTE Response to RAI 12:

1. The plant conditions required to repair the Reactor Recirculation sample line repair will prevent the use of Division 2 Shut Down Cooling (SDC). Therefore Division 1 SDC will be relied on for decay heat removal. Attempting repairs on the Division 1 MDCT fans (A

& C) during this time would place the plant in a vulnerable configuration and challenge the defense in depth for the key safety function of Decay Heat Removal. If these fans were required to be repaired during this Forced Outage, it would have to be performed after completion of the leak repair and restoration of the reactor vessel configuration, resulting in the addition of 7-8 more days to the forced outage schedule.

to NRC-23-0059 Page 8

2. The justification for support of an exigent request does not change. The exigent request is still based on allowing online maintenance of the MDCT A and C fans during a planned and scheduled evolution in October 2023. 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 for a forced shutdown or enforcement discretion.

Enclosure 2 to NRC-23-0059 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Update to Proposed Technical Specification Changes (Mark-Up)

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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 proposed 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. -+/-J4, 209

Enclosure 3 to NRC-23-0059 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Update to Revised Technical Specification Pages

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 proposed 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

Enclosure 4 to NRC-23-0059 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revised Section 2.3 from NRC-23-0050 Enclosure 1 to NRC-23-0059 Page 1 EECW/EESW subsystems are separated from each other so that failure of one subsystem will not affect the OPERABILITY of the other subsystem.

The UHS is provided by a single highly reliable water supply in the form of the RHR reservoirs and a means of heat rejection in the form of mechanical draft cooling towers. The UHS consists of two one-half capacity reinforced concrete reservoirs each with a capacity of 3.41 X 10 6 gallons of water, corresponding to an elevation of 583 feet. The two reservoirs are connected by two redundant cross-tie lines to provide access to the combined inventory to either division of cooled equipment in the event of a failure in one of the divisions. Each RHR reservoir is the cooling source for that division's RHRSW subsystem, and EESW subsystem, as well as the diesel generator service water pumps for that division's emergency diesel generators (EDGs). A two-cell mechanical draft cooling tower is located over each division reservoir. Each cooling tower is designed to cool one division of supported equipment, thus providing full redundancy.

2.2 Circumstances Establishing Need for the Proposed Exigent Amendment On July 18, 2023, at 0424 Eastern Daylight Time (EDT), the Division II Residual Heat Removal Service Water (RHRSW) Mechanical Draft Cooling Tower (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 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 also in need of similar repair. This request is being made to be proactive and repair the Division I MDCT A and C fan pedestals. Additionally, this request provides justification that obtaining an extension of the Completion Time to repair the Division I MDCT fan pedestals online instead of waiting until the next refueling outage. The proposed amendment is being requested due to an exigent circumstance pursuant to 10 CFR 50.91(a)(6).

2.3 Description of the Proposed Change The proposed license amendment would revise the LCO 3.7.2, Condition A Completion Time by adding the following footnote:

LCO 3.7.2

  • The 72-hour Completion Time is extended to 7 days for each of the Division I MDCT fan pedestals (A and C) to allow repair online during Cycle 22 and will expire at 2359 on November 19, 2023.

A marked-up copy of the proposed change is provided in Enclosure 2. Enclosure 3 provides revised (clean) pages.

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