View source for NRC-18-0032, Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

{{Adams
| number = ML18138A149
| issue date = 05/17/2018
| title = Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control
| author name = Polson K
| author affiliation = DTE Electric Company, DTE Energy
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000341
| license number = NPF-043
| contact person = 
| case reference number = NRC-18-0032
| document type = Letter type:NRC, Response to Request for Additional Information (RAI)
| page count = 11
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Keith J. Polson Senior Vice President and CNO DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515    Fax: 734.586.1431 Email: keith.polson@dteenergy.com May 17, 2018 NRC-18-0032 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 NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

==References:==
: 1)      DTE Electric Letter to NRC, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-17-0067, dated August 31, 2017 (ML17243A422)
: 2)      DTE Electric Letter to NRC, Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-18-0019, dated April 4, 2018 (ML18094A165)
In Reference 1, DTE Electric Company (DTE) submitted a license amendment request (LAR) to replace existing Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. In Reference 2, DTE sent a response to a NRC request for additional information (RAI) along with supplemental information in support of the LAR. In an email from Ms. Sujata Goetz to Mr. Jason Haas dated May 9, 2018, the NRC sent DTE a RAI regarding this LAR. The response to the RAI is included in . to this letter provides the existing TS pages marked to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4

USNRC NRC-18-0032 Page 2 provided the existing TS Bases pages marked to show the proposed changes for information only.
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 May 17, 2018 Keith J. Polson Senior Vice President and CNO

==Enclosures:==
: 1. Response to Request for Additional Information
: 2. Proposed Technical Specification Changes (Mark-Up)
: 3. Revised Technical Specification Pages (Clean)
: 4. Proposed Technical Specification Bases Changes (Mark-Up)
(For Information Only) 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 1 to NRC-18-0032 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" Response to Request for Additional Information to NRC-18-0032 Page 1 Response to Request for Additional Information By applicationdatedAugust 31, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17243A422), DTE Electric Company (DTE or the licensee),
requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2, ML16074A448 which changes the technicalspecifications (TS) for Fermi 2. Your applicationwas also supplement by letter dated April 4, 2018 (ADAMS Accession No. ML18094A165).
RAI EICB-3 In Enclosure 2 of the LAR, page 3.5-11, you proposedto adopt SR 3.5.2.9 (equivalentto TSTF-542 SR 3.5.2.8), which states, "Verify the requiredECCS injection/spray subsystem actuates on a manual initiationsignal."
In Enclosure 4 of the LAR, page 3.5.2-9, you provided the associatedBasesfor SR 3.5.2.9 (similarto TSTF-542 TS basesfor SR 3.5.2.8), which states in part:
The requiredECCSsubsystem is requiredto actuate on a manual initiationsignal. This Surveillance verifies that a manual initiation signalwill cause the requiredCS [Core Spray] subsystems or LPCI [Low PressureCoolantInjection] subsystem to startand operate as designed, includingpump startup and actuation of all automatic valves to their requiredpositions.
You stated in your letter datedApril 4, 2018:
Fermi 2 does not have the capability to actuate an entire subsystem of CS or LPCI by a single manualpushbutton, as describedin the response to RAI EICB-1. Instead, a CS or LPCI subsystem is actuatedby manually controllingeach individualcomponent of that subsystem in accordancewith approvedplantprocedures. In this context, the phrase "manual initiationchannel" in the proposedTS Basespage B 3.3.5.3-3 is used to collectively describe all of the individual components requiredto manually initiate a subsystem and is not intendedto imply thatpushing one or two buttons actuates an entire subsystem.
Your design description does not align with the TSTF-542 standardtechnicalspecifications design description of manual initiation,which assumes that an entire ECCS subsystem can be started automaticallywith the press of one button. Adoption of language identicalto the StandardTechnical Specifications when there is a design difference couldpotentially cause .
confusion of the requirements. Conversely, in proposedFermi 2 TS Table 3.3.5.3-1, functions 1.b and 2.b, the manual initiationfor the CS andLPCI systems, respectively, each has a caveat; footnote (c) indicates that the manual initiation occurs through manipulationof individual component controls. (A similarfootnote isfound in currentFermi 2 TS table 3.3.5.1-1.)
to NRC-18-0032 Page 2 Please revise SR 3.5.2.9, and any associatedbases, to reflect the appropriateFermi 2 ECCS manual initiationdesign requirements.

===RESPONSE===
DTE proposes to revise Technical Specification (TS) Surveillance Requirement (SR) 3.5.2.9, as indicated in Enclosures 2 and 3, to reflect the existing Fermi 2 Emergency Core Cooling System (ECCS) design that manual initiation occurs by means of individual component controls. The proposed SR 3.5.2.9 requires verification that the required ECCS subsystem can be manually operated. The associated TS Bases has similarly been revised as indicated in Enclosure 4 and clarifies that the SR verifies that manual initiation by means of individual component controls will cause the required CS or LPCI subsystems to start and operate. The proposed SR aligns with TS Table 3.3.5.3-1, RPV Water Inventory Control Instrumentation, footnote (c) which states that the Manual Initiation function of CS and LPCI is by means of individual component control and is an acceptable variation from TSTF-542, Revision 2.
DTE has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Sections 3.1 and 4.0 of Enclosure 1 of the Reference 1 LAR. The supplemental information provided in this letter 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-18-0032 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" Proposed Technical Specification Changes (Mark-Up)
Revised Page 3.5-11 (3.5.2 RPV Water Inventory Control)

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS     (continued)
SURVEILLANCE                             FREQUENCY SR 3.5.2.9       ------------------- NOTE -------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray      In accordance subsystem can be manually operated.           with the Surveillance Revised per                                         Frequency NRC-18-0032                                         Control Program FERMI - UNIT 2                        3.5-11     Amendment No. 134 184, 21, 204

Enclosure 3 to NRC-18-0032 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" Revised Technical Specification Changes (Clean)
Revised Page 3.5-11 (3.5.2 RPV Water Inventory Control)

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS   (continued)
SURVEILLANCE                             FREQUENCY SR  3.5.2.9    ------------------- NOTE--------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray      In accordance subsystem can be manually operated.           with the Surveillance Frequency Control Program FERMI - UNIT 2                       3.5-11     Amendment No. 134 184, 291, 204

Enclosure 4 to NRC-18-0032 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" Proposed Technical Specification Bases Changes (Mark-Up)
(For Information Only)
Revised Page 3.5.2-9 (B 3.5.2 RPV Water Inventory Control)

NEW TS 3.5.2 Bases                                                RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE      REQUIREMENTS (continued)
SR 3.5.2.8 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.                         Revised per NRC-18-0032 SR 3.5.2.9 The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that manual initiation by means of individual component controls will cause the required CS subsystems or LPCI subsystem to start and operate as designed, including pump Deleted per        startup and actuation of al aetemteie valves to their required positions.
NRC-18-0032        The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.
REFERENCES           1.       Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.
: 2.        Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.
: 3.        Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f)," August 1992.
: 4.        NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.
: 5.       Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.
: 6.       General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 314/5/6," February 1983.
FERMI - UNIT 2                              3.5.2-9                                Revision}}