NRC-25-0007, Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, TSTF-439.
| ML25035A110 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/04/2025 |
| From: | Domingos C DTE Electric Company |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NRC-25-0007 | |
| Download: ML25035A110 (1) | |
Text
Christopher P. Domingos Site Vice President DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5025 Fax: 734.586.5295 Email: christopher.domingos@dteenergy.com 10 CFR 50.90 February 4, 2025 NRC-25-0007 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:
Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, "Revise the Risk Informed Completion Time (RICT) Program" In Reference 1, DTE Electric Company (DTE) submitted a License Amendment Request (LAR) to Revise Fermi Technical Specifications to adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,"
References:
- 1) DTE Letter NRC-24-0001, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times -
RITSTF Initiative 4b," TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, "Revise the Risk Informed Completion Time (RICT) Program", dated March 21, 2024 (ML24081A326)
- 2) NRC E-mail Capture, Fermi 2: Audit Questions from the Audit Team Supporting Review of the LAR to Adopt TSTF-505 (EPID: L-2024-LLA-0034), dated July 30, 2024 (ML24213A322)
- 3) DTE Letter NRC-24-0069, Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, "Revise the Risk Informed Completion Time (RICT) Program", dated December 19, 2024 (ML24354A255)
USNRC NRC-25-0007 Page 2 TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO," and TSTF-591, Revision 0, "Revise the Risk Informed Completion Time (RICT) Program." In Reference 2, an email from Mr. Surinder Arora to Mr. Eric Frank dated July 30, 2024, the NRC sent DTE audit questions based on the staffs review of the LAR to adopt TSTF-505, TSTF-439 and TSTF-591. Reference 3 provided responses to NRC audit questions that the audit team requested to be docketed along with a supplement to the Reference 1 LAR resulting from audit question responses.
The enclosure of this supplement provides an update to the response to Audit Question STSB l and markup to Example 1.3-8 to correct an error in TSTF-505 and align with NUREG-1433 along with the associated clean page and Attachment 5 cross reference page. The supplemental pages in the enclosure replace their respective pages from Reference l and Reference 3.
DTE has determined that the information provided in this supplement does not alter the conclusions reached in the l O CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal 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.
In accordance with 10 CFR 50.91(b)(l ), a copy of this application, with the enclosure, is being provided to the designated State of Michigan official.
No new commitments are being made in this submittal.
Should you have any questions or require additional information, please contact Mr. Eric Frank at (734) 586-4772.
I declare under penalty of pe1jury that the foregoing is true and correct.
Executed on February 4, 2025 at*\
Christoplr P. Domingos Site Vice President
Enclosure:
Supplement to NRC-24-0001 & NRC-24-0069
USNRC NRC-25-0007 Page 3 cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy
Enclosure to NRC-25-0007 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplement to NRC-24-0001 & NRC-24-0069
Enclosure to NRC-25-0007 Page 1 Technical Specifications Branch (STSB) Fermi Unit 2 TSTF-505 Audit Questions Audit Question STSB1: NRG staff recognizes that the licensee's proposed change is consistent with the NUREG-1433 TS markups in TSTF-505, Revision 2. However, it has been brought to staff's attention that some of the TSTF-505 markups contain errors. The proposed completion time for required action B. 1 and proposed required action B. 2 are not consistent with BWR STS and Fermi 2's other TS examples in this section. Discuss why these values are appropriate or provide a revision.
DTE Response:
The following is a proposed revision to Example 1.3-8 consistent with NUREG-1433 Example 1.3-8:
B. Required 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 /> Action and associated AND Completion Time not met.
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 />
Enclosure to NRC-25-0007 Page 2 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 2
EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.
A.1 Restore subsystem to OPERABLE status.
7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.
The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
INSERT A Enclosure to NRC-25-0007 Page 3 12 4
Enclosure to NRC-25-0007 Page 4 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 3
(continued)
FERMI - UNIT 2 1.3-13 Amendment No. 134 Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-7 (continued) is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A,
provided the Completion Time for Required Action A.2 has not expired.
EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.
A.1 Restore subsystem to OPERABLE status.
7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours When a subsystem is declared inoperable, Condition A is entered.
The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Com pletion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.
Enclosure to NRC-25-0007 Page 6 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 5
Enclosure to NRC-25-0007 Page 7 Cross Reference of TSTF-505, TSTF-591, TSTF-439 and Fermi 2 Technical Specifications TSTF-505-A TS Title / Section /
Condition Description TSTF-505-A TSTF-439-A TS/RA Fermi 2 TS/RA Disposition Comments Completion Times 1.3 1.3 Discussion and Example 1.3.3 Discussion and Example 1.3.3 Discussion and Example 1.3.3 Incorporated Example TSTF-439 changes are incorporated.
Example 1.3-8 Example 1.3-8 Example 1.3-8 Incorporated Example TSTF-505 changes are incorporated.
Changed the completion time for B.1 to be in MODE 3 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the Mode to 4 for in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for B.2 to remain consistent with the remainder of the Section 1.3 examples.
Standby Liquid Control (SLC) System 3.1.7 3.1.7 A. [Concentration of boron in solution not within limits but > [ ]
3.1.7 N/A No Change for TSTF-439 The Fermi 2 TS do not contain this TS.
B. One SLC subsystem inoperable [for reasons other than Condition A]
3.1.7 B1 3.1.7 A1 Added RICT to 3.1.7A1 No Change for TSTF-439 TSTF-505 changes are incorporated.
TSTF-439 changes are not incorporated.
The Fermi 2 TS do not contain this TS.
TS 3.1.7, Action A.1 addresses one pump inoperable. Although numbering of