NRC-25-0015, 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

From kanterella
(Redirected from NRC-25-0015)
Jump to navigation Jump to search

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
ML25078A292
Person / Time
Site: Fermi 
Issue date: 03/19/2025
From: Banker S
DTE Electric Company
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-25-0015
Download: ML25078A292 (1)
v • d • e


Text

Stephanie P. Banker Vice President - Engineering & Technical Support DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734-586-4431 Email: stephanie.banker@dteenergy.com March 19, 2025 10 CFR 50.90 NRC-25-0015 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"

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)
4) DTE Letter NRC-25-0007, Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times DTE

USNRC NRC-25-0015 Page 2 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,"

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. Reference 4 provided an update to the response to Audit Question STSB1 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 enclosure of this supplement provides an update to Technical Specifications 3.3.5.1 E.2 and F.2 to remove the note specifying that RICT is not applicable when trip capability is not maintained for the Automatic Depressurization System (ADS). The required actions for 3.3.5.1 E.2 and F.2 are protected from a loss of safety function by required actions E.1 and F.1. Both E.1 and F.1 are linked by an AND statement to E.2 and F.2 and require declaring all ADS valves inoperable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when a loss of initiation capability in both ADS trip systems occurs. If this were this to occur, it would require entry into TS 3.5.1 Condition J which requires being in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a Reactor Pressure of less than 150psig within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Therefore, a note in Technical Specifications 3.3.5.1 E.2 and F.2 specifying that RICT is not applicable when trip capability is not maintained is not needed. The need for this change was discussed in phone calls on February 25, 2025 and March 11, 2025 with the NRC audit team and Fermi 2 Licensing staff. The supplemental pages in the enclosure replace their respective pages from References 1, 3, 4 & 5.

DTE has determined that the information provided in this supplement does not alter the conclusions reached in the 10 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)(1), 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.

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 February 4, 2025 ( ML25035A110)

USNRC NRC-25-0015 Page 3 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 March 19, 2025 Sincerely, Stephanie. Banker Vice President - Engineering & Technical Support

Enclosure:

Supplement to NRC-24-0001, NRC-24-0069 & NRC-25-0007 cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure to NRC-25-0015 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplement to NRC-24-0001, NRC-24-0069 & NRC-25-0007

Enclosure to NRC-25-0015 Page 2 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 2 (Blue mark-ups are changes from NRC-25-0015)

V ACTIONS (continued)

CONDITION E.

As required by Required Action A.l and referenced in Table 3.3.5.1-1.

FERMI

Place channel in trip.

ECCS Instrumentation 3.3.5:1 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from*

discovery of loss of ADS initiation capability in both trip systems 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channel concurrent with HPCI or reactor core isolation cooling (RCIC) inoperable AND 8 days (continued)

Amendment No. 134 OR

NOTE-----

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program or in accordance with the Risk Informed Completion Time Program Delete Arrow Delete Note 3.3-38

u ACTIONS (continued)

CONDITION F. As required by F.1 Required Action A.1 and referenced in Table 3.3.5.1-1.

AND F.2 G.

Required Action and G.l associated Completion Time of Condition B.

C. D. E. or F not met.

FERMI - UNIT 2 ECCS Instrumentation 3.3.5.1 REQUIRED ACTION COMPLETION TIME

      • -****-NOTE---**--*

Only applicable for Functions 4.c. 4.e.

4.f. 4.g. 5.c. 5.e.

5.f. and 5.g.

Declare ADS valves l hour from inoperable.

discovery of loss of ADS initiation capability in both trip systems Restore channel to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from OPERABLE status.

discovery of inoperable channel concurrent with HPCI or RCIC inoperable AND 8 days Declare associated Immediately supported feature(s) inoperable.

3.3-39 Amendment No. 134 OR

NOTE-----

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program or in accordance with the Risk Informed Completion Time Program Delete Arrow Delete Note

.* (

(

Enclosure to NRC-25-0007 Page 5 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 3

ACTIONS (continued)

CONDITION E.

As required by Required Action A.1 and referenced in Tab l e 3. 3. 5. 1-1.

FERMI - UNIT 2 E.1 AND E.2 REQUIRED ACTION Declare Automatic Depressurization System (ADS) valves inoperable.

Place channel in trip.

3.3-38 ECCS Instrumentation 3.3.5.1 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCI or reactor core isolation cooling (RCIC) inoperable AND (continued)

(continued)

Amendment No. lJ4

ACTIONS (continued)

CONDITION E.

(continued)

F.

As required by Required Action A.1 and referenced in Tab l e 3. 3. 5. 1-1.

FERMI - UNIT 2 F.1 AND ECCS Instrumentation 3.3.5.1 REQUIRED ACTION

NOTE --------

Only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, 5.f, and 5.g.

Declare ADS valves inoperable.

3.3-39 COMPLETION TIME 8 days OR In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems (continued)

Amendment No. lJ4

ECCS Instrumentation 3.3.5.1 ACTIONS F.

(continued)

F.2 Restore channel to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or in OPERABLE status.

accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCI or RCIC inoperable AND 8 days OR In accordance with the Risk Informed Completion Time Program G.

Required Action and G.1 Declare associated Immediately associated Completion supported feature(s)

Time of Condition B, inoperable.

C, D, E, or F not met.

FERMI - UNIT 2 3.3-39a Amendment No.

Enclosure to NRC-25-0007 Page 9 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 4 (Blue mark-ups are changes from NRC-25-0015)

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. (NOTE is provided in TS to state that RICT is not applicable when trip capability is not maintained.)

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

Delete Note BASES ECCS Instrumentat ion B 3.3.5.l ACTIONS (continued)

FERMI - UNIT 2 continue.

If Required Action D.2.1 or D.2.2 is performed, measures should be taken to ensure that the HPCI System piping remains filled with water. Alternately, if it is not desired to perform Required Actions D.2.1 and D.2.2 (e.g.,

as in the case where shifting the suction source could drain down the HPCI suction piping), Condition G must be entered and its Required Action taken.

E. l and E.2 Required Action E.l is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within similar ADS trip system A and B Functions result in redundant automatic initiation capability being lost for the ADS.

Redundant automatic initiation capability is lost if either (a) one Function 4.a channel and one Function 5.a channel are inoperable and untripped, (b) one Function 4.b channel and one Function 5.b channel are inoperable and untripped, or (c) one Function 4.d channel and one Function 5.d channel are inoperable and untripped.

In this situation (loss of automatic initiation capability),

the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 day allowance, as applicable, of Required Action E.2 is not appropriate and all ADS valves must be declared inoperable within l hour after discovery of loss of ADS initiation The Com

,on Time is intended to allow the operator time to uate and repair any discovered inoperabilities. This mpletion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

For Required Action E.l, the Completion Time only begins upon discovery that the ADS cannot be automatically initiated due to inoperable, untripped channels within similar ADS trip system Functions ~ ~l@:!~~-*~-~,e._...

_M*.!'"~~.!-==============-=:-

paragraph above.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Compl of loss of initiation capabilit i minimizes risk while allowin ime tripping of channels.

Because of the divers* y of sensor ___ _ _ _......,_......., ______ ___.

initiation signals d the redundancy of the ECCS design, an allowable out of ervice time of 8 days has been shown to be acceptable (Re. 4) to permit restoration of any inoperable channel to RABLE status if both HPCI and RCIC are OPERABLE.

f either HPCI or RCIC is inoperable, the time is B 3. 3. 5. 1 - 28 Revision 0-

or in accordance with the Risk Informed Completion Time Program.

(NOTE is provided in TS to state that RICT is not applicable when trip capability is not maintained.)

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. (NOTE is provided in TS to state that RICT is not applicable when trip capability is not maintained.)

Delete Note Delete Note BASES ECCS Instrumentation B 3.3.5.l ACTIONS (continued)

Thus, a total loss of manual inhibit capability for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 8 days (as allowed by Required Action F.2) is allowed.

  • The Completion Time is intended to allow the o~e r time to evaluate and repair any discovered ino 1lities. This Completion Time also allows for an °v 0 - ~ion to the normal "time zero" for beginning the wed outage time "clock."

For Required Action F.l Completion Time only begins upon discovery th e ADS cannot be automatically initiated d o inoperable channels within similar ADS trip syste ctions as described in thi paragraph above.

The our Completion Time from discovery of loss of initiation capability is acceptable because it minimizes risk while owing time for restoration or tripping of channels.

Because o he diversity of sensors available to provide initiations, ls and the redundancy of the ECCS design, an allowable out of vice time of 8 days has been shown to be acceptable (Ref. 4) to rmit restoration of any inoperable channel to OPERABLE status

  • both HPCI and RCIC are OPERABLE (Required Action F.2 If either HPCI or RCIC is inoperable, the time shortens to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

If the status of HPCI or RCIC changes such that the Completion Time changes from 8 days to 96 hou

, the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> begins upon discovery of HPCI or RCIC

  • e ability. However, the total time for an ino e channel cannot exceed 8 days.

If the status I or RCIC changes such that the Completion Time changes from 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to 8 days, the 11titne zero" for beginning the 8 day "clock" begins upon discovery of the inoperable channel.

If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition G must be entered and its Required Action taken.

The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.

.-------'-----. G. l FERMI - UNIT 2 With any Required Action and associated Completion Time not met, the associated feature(s) may be incapable of performing the intended function, and the supported feature(s) associated with inoperable untripped channels must be declared inoperable immediately.

B 3. 3. 5. 1 - 30 Revision 0-

Enclosure to NRC-25-0007 Page 12 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revision to Attachment 5 (Blue mark-ups are changes from NRC-25-0015)

Enclosure to NRC-25-0007 Page 13 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 F. As required by RA A.1 and referenced in Table 3.3.5.1-1 Place channel in trip.

3.3.5.1F.2 3.3.5.1E.2 Added RICT to 3.3.5.1E.2 TSTF-505 changes are incorporated.

Although the Fermi 2 TS numbering of the RA is different from the NUREG 1433, this is an administrative deviation from TSTF 505 with no impact on the NRC's model safety evaluation dated November 21, 2018.

Applied RICT to the COMPLETION TIME statement :96 Hours from discovery of inoperable channel concurrent with HPCI or Reactor Core Isolation Cooling (RCIC) inoperable. This change clarifies that RICT begins from discovery and not when the Action Condition is entered.

This is consistent with TSTF-592.

However, under certain circumstances, with more than one channel inoperable, a loss of function may occur. Therefore, a Note is added to the Completion Time which prohibits applying a RICT when trip capability is not maintained.

G. As required by RA A.1 and referenced in Table 3.3.5.1-1 3.3.5.1G.2 3.3.5.1F.2 Added RICT to 3.3.5.1F.2 TSTF 505 changes are incorporated.

Although the Fermi 2 TS numbering of the RA is different from the NUREG 1433, Delete I

~

~

Retrieved from "https://kanterella.com/w/index.php?title=NRC-25-0015,_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&oldid=5566618"