View source for NRC-23-0068, Exigent License Amendment Request for Revision of Technical Specification (TS) 3.8.1 AC Sources - Operating

{{Adams
| number = ML23271A188
| issue date = 09/28/2023
| title = Exigent License Amendment Request for Revision of Technical Specification (TS) 3.8.1 AC Sources - Operating
| author name = Dietrich P
| author affiliation = DTE Electric Company
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000341
| license number = NPF-043
| contact person = 
| case reference number = NRC-23-0068
| document type = Letter type:NRC, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Amendment
| page count = 1
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter: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 September 28, 2023                                                                       10 CFR 50.90 NRC-23-0068 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:==
Exigent License Amendment Request for Revision of Technical Specification (TS) 3.8.1 AC Sources - Operating

==References:==
: 1) NRC letter to DTE Electric Company, Fermi Unit 2 - Issuance Of Amendment No. 225 Regarding Revision Of Technical Specifications 3.7.2, Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System And Ultimate Heat Sink (UHS) (Exigent Circumstances) (EPID L-2022-LLA-0112), dated September 18, 2023 (ML23243A885)
In accordance with the provisions of Title 10 Code of Federal Regulations (10 CFR) 50.90, DTE Electric Company (DTE) requests an amendment to the Fermi 2 Plant Operating License, Appendix A, TS 3.8.1 Required Action B.4 for a one-time extension of the Completion Time to allow repair of the Division I Mechanical Draft Cooling Tower (MDCT) A and C fan pedestals while online. The proposed amendment is being requested due to an exigent circumstance pursuant to 10 CFR 50.91(a)(6).
The requested amendment would revise Limiting Condition for Operation (LCO) 3.8.1 Required Action B.4, for both Emergency Diesel Generators (EDGs) in one division inoperable, by adding a footnote to allow a one-time extension of the Completion Time from 72 hours to 7 days during the current operating Cycle 22. This one-time extension would be used twice, once for each fan during the allotted time approved by the NRC.
On September 18, 2023, License Amendment 225 was approved (Reference 1) under exigent circumstances to extend of the Completion Time to Technical Specification 3.7.2 Required Action A.1 to support the same repair activity on the Division I MDCT A and C fans. That original amendment did not contain all required Technical Specification Completion Time extensions needed to perform this work online. This request is to implement an additional one-time amendment to Technical Specification 3.8.1 to support the same planned online

USNRC NRC-23-0068 Page 2 maintenance. In addition, this requested amendment also makes an editorial correction to revise the one-time footnote on TS 3.7.2 that was approved in amendment No. 225 to remove the word proposed.
DTE requests approval of the proposed amendment by October 25, 2023. The proposed amendment will be implemented within two days of the U.S. Nuclear Regulatory Commission approval. This timing is to support performing repairs of the MDCT A and C separately in the Division I work weeks of 10/30/23 and 11/6/23. We are requesting an expiration date of 11/19/23 for the one-time extension. This expiration date aligns with the previously approved one-time amendment (No. 225).
No new commitments are being made in this submittal.
In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan State Official.
Should you have any questions or require additional information, please contact Mr. Eric Frank, Manager, Licensing at (734) 586-4772.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on September 28, 2023 Peter Dietrich Senior Vice President and Chief Nuclear Officer

==Enclosures:==
: 1. Evaluation of the Proposed License Amendment
: 2. Marked-up Pages of Existing Fermi 2 TS
: 3. Clean Pages of Fermi 2 TS with Changes Incorporated cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure 1 to NRC-23-0068 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Evaluation of the Proposed License Amendment to NRC-23-0068 Page 1 Evaluation of the Proposed License Amendment Contents 1.0 

==SUMMARY==
DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Circumstances Establishing Need for the Proposed Exigent Amendment 2.3 Description of the Proposed Change

==3.0 TECHNICAL EVALUATION==

3.1 Technical Specification Requirements 3.2 System Description (UFSAR 9.2.5.2.2) 3.3 Compensatory Measures

==4.0 REGULATORY EVALUATION==

4.1 Applicable Regulatory Requirements and Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusion

==5.0 ENVIRONMENTAL CONSIDERATION==

==6.0 REFERENCES==

to NRC-23-0068 Page 2 1.0     

==SUMMARY==
DESCRIPTION In accordance with the provisions of Title 10 Code of Federal Regulations (10 CFR) 50.90, DTE Electric Company (DTE) requests an amendment to the Fermi 2 Plant Operating License, Appendix A, Technical Specifications (TS) 3.8.1, to allow for a one-time extension of the Required Action B.4 Completion Time to allow repair of the Division I Mechanical Draft Cooling Tower (MDCT) A and C fan pedestals while online. This change would align with changes previously approved under Amendment 225 (Reference 6.6).
Repair of MDCT Fan Pedestal B is not addressed in this License Amendment Request (LAR).
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 similar non-conforming condition, but it had been inspected and repaired in 2009 and has not been exposed to the environmental conditions for as long as Fans 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).
This proposed one-time license amendment will add a footnote to Technical Specification 3.8.1 AC Sources - Operating Required Action B.4 Completion Time to extend the time from 72 hours to 7 days during Cycle 22. This one-time extension would be used twice, once for each fan during the allotted time approved by the NRC.
Tech Spec Footnote:
* 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 Completion Time extension and associated compensatory measures are documented in LAR NRC-23-0068. This Completion Time extension will expire at 2359 on November 19, 2023.
This requested amendment also makes an editorial correction to revise the footnote for TS 3.7.2 that was approved in amendment No. 225 to remove the word proposed so that it matches the footnote included in this request for TS 3.8.1. This correction is documented in Enclosure 2.
2.0     DETAILED DESCRIPTION 2.1     System Design and Operation AC Sources - Operating, which includes the Emergency Diesel Generators (EDGs), is a support system for the Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) system. The EECW/EESW System is designed to provide cooling water for the removal of heat from equipment, such as Residual Heat Removal (RHR) and Core Spray (CS),
pump coolers, and room coolers for Emergency Core Cooling System (ECCS) and other safety-to NRC-23-0068 Page 3 related equipment, required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient.
Components cooled by each EECW subsystem are normally cooled by the Reactor Building Closed Cooling Water (RBCCW) system, which cools various plant equipment primarily in the Reactor Building. An EECW subsystem contains a single 1775 gpm nominal capacity pump, a heat exchanger, a make-up tank, valves, piping, and associated instrumentation. A second 100% capacity heat exchanger is also provided as a backup. Upon receipt of a loss of off-site power, a high drywell pressure signal, or low RBCCW System pressure, both EECW subsystems are activated. Upon activation, the EECW pump starts, the EECW loop isolates from the remainder of the RBCCW system, and other system valves reposition as needed to isolate non-essential loads and configure the system for emergency operation.
Each EECW subsystem's heat exchanger is cooled by the same division's EESW subsystem. The EESW subsystem contains a single 1600 gpm nominal capacity pump that pumps from the division's Residual Heat Removal (RHR) Reservoir through the EECW subsystem's heat exchanger and returns to the RHR Reservoir. Each EESW subsystem functions to cool the associated EECW subsystem. The EESW pump automatically starts on the same actuation signals as the EECW System. The two EECW/EESW subsystems are separated from each other so that failure of one subsystem will not affect the OPERABILITY of the other subsystem.
The Ultimate Heat Sink (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 106 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 (MDCT)is located over each division reservoir. Each cooling tower is designed to cool one division of supported equipment, thus providing full redundancy.
Note: Fermi does not have the ability to cross-tie between the Emergency Equipment Service Water (EESW), Residual Heat Removal Service Water (RHRSW) or Diesel Generator Service water (DGSW) Division I and II Systems to provide inventory to equipment with operable MDCT during maintenance 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) 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 to NRC-23-0068 Page 4 Enforcement Discretion (NOED) requested by our letter NRC-23-0049 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 are also in need of similar repair. These fans do not currently exhibit evidence of similar vibration or operational issues as was experienced on MDCT D. Monthly surveillances have been performed without issues. This request is being made to be proactive and inspect and repair these two fans to avoid a failure similar to the MDCT D fan pedestal. 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 of a forced shutdown or enforcement discretion.
On September 18, 2023, License Amendment 225 was approved (Reference 6.6) under exigent circumstances to extend of the Completion Time to Technical Specification 3.7.2 to support the repair the Division I MDCT fan pedestals online instead of waiting until the next refueling outage. That original amendment did not contain all required Technical Specification Completion Time extensions needed to perform this work online. This request is to implement an additional one-time amendment to Technical Specification 3.8.1 to support the same planned online maintenance. Therefore, this additional proposed amendment is also 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 current one-time note in LCO 3.7.2, Required Action A.1 (added in Amendment 225) and add a new one-time note to 3.8.1 Required Action B.4 Completion Time as follows:
LCO 3.7.2
                *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 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.
LCO 3.8.1
                *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 Completion Time extension and associated compensatory measures are documented in LAR NRC-23-0068. This Completion Time extension will expire at 2359 on November 19, 2023.
to NRC-23-0068 Page 5 Marked-up copies of the proposed changes are provided in Enclosure 2. Enclosure 3 provides revised (clean) pages.

==3.0     TECHNICAL EVALUATION==

The proposed change does not alter the plant design, nor does it affect the assumptions contained in the safety analyses. Specifically, there are no changes being made to the original fan pedestal design. As described in the UFSAR sections noted in Section 3.2, all conditions have been previously analyzed.
Note: A Probabilistic Risk Assessment (PRA) has not been performed as part of this amendment request. A risk-informed justification for this change had been previously evaluated and approved under Reference 6.6. This PRA analysis has not changed since that approval and that analysis also applies to this LAR submittal.
Repairs will be made to only one MDCT fan (A or C) at a time. There will be no time when both fans of the same division are out of service simultaneously. These fans are not taken out of service at the same time 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 do 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).
3.1     Technical Specification Requirements (TS 3.7.2)
In MODEs 1, 2, and 3, the Fermi 2 TS 3.7.2, Emergency Equipment Cooling Water (EECW)
/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), requires two EECW/EESW subsystems and UHS to be operable. When one or more are inoperable, the following TS 3.7.2 Condition A.1 applies:
A.1 - Restore reservoir to OPERABLE status.
If REQUIRED ACTION A.1 cannot be completed within its 72-hour COMPLETION TIME, then TS 3.7.2 CONDITION C applies. CONDITION C contains two REQUIRED ACTIONS, C.1, to be in MODE 3 with a COMPLETION TIME of 12 hours and C.2, to be in MODE 4 with a COMPLETION TIME of 36 hours.
This TS also contains Note 1 within the Actions to:
Enter applicable Conditions and Required Actions of LCO 3.8.1, AC Sources -
Operating, for diesel generator made inoperable by UHS.
to NRC-23-0068 Page 6 (TS 3.8.1)
In MODEs 1, 2, and 3, the Fermi 2 TS 3.8.1, AC Sources - Operating, requires the following AC Power Sources to be OPERABLE:
: a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and
: b. Two Emergency Diesel Generators (EDGs) per division.
With the UHS inoperable, it would result in both EDGs in that division to also be inoperable. If both EDGs in one division are inoperable then Required Action B.4 applies:
B.4 - Restore one EDG in the division to OPERABLE status.
If Required Action B.4 cannot be completed within its 72-hour Completion Time, then TS 3.8.1 Condition G applies. Condition G requires to be in MODE 3 within 12 hours.
Additional Associated Technical Specifications As stated in the TS 3.7.2 Note 2, TS 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown is also required to be declared inoperable when EECW/EESW or the UHS is made inoperable. TS 3.4.8 is applicable in Mode 3 with reactor steam dome pressure less than the RHR cut in permissive pressure. A one-time extension note is NOT being added to TS 3.4.8. If the plant is required to enter Mode 3 during the period when the MDCT A or C fans are being repaired, Operations will perform TS 3.4.8 Required Actions as written.
Also, the following additional supported systems TS are associated to this one-time extension of the TS 3.7.2 completion times. These TS will be tracked under the Fermi Operations Safety Function Determination (SFD) process and the Maximum Out of Service Time (MOST) extensions. Based on this process, the extension of TS 3.7.2 Required Action A.1 and TS 3.8.1 Required Action B.4 do not require a similar one-time extension note for the impacted LCO's under 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 TS would be entered, but the actions would be delayed as allowed by LCO 3.0.6 and the use of the SFD.
* TS 3.5.1 ECCS - Operating Action A.1 and C
* TS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling Action A.1
* TS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray Action A.1
* TS 3.6.4.3 Standby Gas Treatment (SGT) System Action A.1
* TS 3.7.1 Residual Heat Removal Service Water (RHRSW) System Action C.1
* TS 3.7.4 Control Center Air Conditioning (AC) System Action A.1
* TS 3.7.8 Emergency Diesel Generator Service Water (EDGSW) Action A.1
* TS 3.8.4 DC Sources - Operating Action B.1
* TS 3.8.7 Distribution Systems - Operating Action A.1 and B.1 to NRC-23-0068 Page 7 3.2      System Description (UFSAR 9.2.5.2.2)
A two-cell induced-draft cooling tower is located over each division reservoir of the Ultimate Heat Sink (UHS). The towers are of Category I fireproof construction with reinforced-concrete shells, cement board fill, and mist eliminators. Each tower is designed to cool one division of the plant load (one Residual Heat Removal (RHR) heat exchanger, one EECW heat exchanger, and two Emergency Diesel Generators (EDGs)), thus providing complete redundancy. Component design parameters for each tower are given in UFSAR Table 9.2-7.
Each RHRSW cooling tower cell fan is driven by a 150-hp two-speed motor. The motor is connected to the Engineered Safety Feature (ESF) bus of the EDGs for a redundant power supply and is manually started and stopped from the main control room.
The towers and fan drives are provided with a reinforced-concrete protective shell for tornado, earthquake, and missile protection.
Operation With One Division Unavailable (UFSAR 3.5.1.3.2.2 & 3.8.4.1.2)
The Mechanical Draft Cooling Tower (MDCT) system is designed such that it can function even if one tower division is damaged, rendered out of service, or is unavailable. With the two divisional reservoirs of the Ultimate Heat Sink (UHS) cross-connected to permit access to the entire UHS inventory, each division has the capacity to safely and orderly shutdown the reactor during normal and/or accident conditions completely independent of the other. Therefore, the Mechanical Draft Cooling Towers can perform their function with one division unavailable.
As stated above, operation with one division of the Mechanical Draft Cooling Towers unavailable has been previously analyzed in the UFSAR and the maintenance activities planned for the MDCT Fan A and C pedestals are bound by this analysis.
Tornado / Missile Accident Analysis (UFSAR 3.5.1.3.2.2 & 9.2.5.2.2)
The fans are provided with a brake system to prevent overspeed from the design-basis tornado.
The fan drive shaft is provided with a shield to protect it from tornado missiles. The cooling tower structure is designed to withstand horizontal and vertical tornado missiles. The cooling fan motor is enclosed in a concrete cubicle designed to repel both types of missiles, and the cooling tower gear hub and shaft are protected by missile shields.
Additionally, a study was performed to determine the probability that both cooling tower divisions can be rendered out-of-service by tornado- generated missiles entering the fan discharge stack. The result of this study found that this probability is very small and is conservatively estimated between 10-9 and 10-10 per year. Notwithstanding this low probability, two spare sets of two RHR cooling tower fan blades and the necessary tools to install them are stored in the RHR complex building in a location protected from the tornado and tornado to NRC-23-0068 Page 8 missiles. In the event that the cooling tower fan blades are damaged, the blades can be replaced, and the fan restored to an operating condition. Plant safe shutdown will not be precluded in the event of tornado missile damage to all four of the RHR cooling tower fans, including assuming a loss of offsite power and a single independent failure. The plant organization estimates that it would take six hours or less to replace a set of cooling tower fan blades. If no fans are available for six hours, reservoir temperature is calculated to rise to approximately 100 degrees F. All essential equipment cooled by the UHS is capable of performing its required safety functions at the higher reservoir temperature. One cooling tower fan can maintain hot standby and two cooling tower fans can achieve cold shutdown under these conditions.
In addition to missiles, miscellaneous debris can fall into the tower from the tornado. The debris would not damage the fan blades or other structural components of the towers. The debris would be removed while the blades are being replaced.
As stated above, the Mechanical Draft Cooling Tower system has been analyzed in the UFSAR for tornado and missile events. The maintenance activities planned for the MDCT Fan A and C pedestals are bound by this analysis.
Loss of Offsite Power (UFSAR 8.3.1 & 9.2.5)
The motors for the MDCT fans are connected to the ESF bus of the EDGs for a redundant power supply. In the event of a loss of normal power, the ESF electrical loads are automatically connected to the EDGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a Loss of Cooling Accident (LOCA).
As stated above, the Mechanical Draft Cooling Tower fan motors have been analyzed for operation in case of a loss of offsite power. The maintenance activities planned for the MDCT Fan A and C pedestals are bound by this analysis.
In summary, the Mechanical Draft Cooling Towers are comprised of two redundant divisions, with each division individually capable of providing the necessary cooling of the Ultimate Heat Sink during all plant modes of operation and in accident conditions. The removal of one division of the Mechanical Draft Cooling Towers from service has been analyzed in the UFSAR and the maintenance activities planned for the MDCT Fan A and C pedestals are bound by this analysis.
3.3    Compensatory Measures The following equipment protections will be in effect in accordance with Fermi procedures MOP05-100 Protected Equipment and ODE-20, Protected Equipment, while the Division 1 RHRSW MDCT A (or C) Fan is unavailable:
: 1. Elective maintenance will not be performed on the following Division 2 Systems:
Emergency Equipment Cooling Water (EECW)
Emergency Equipment Service Water (EESW)
Ultimate Heat Sink (UHS)
Switchgear

Enclosure 1 to NRC-23-0068 Page 9 Emergency Diesel Generators (EDGs)
High Pressure Coolant Injection (HPCI)
Core Spray (CS)
Residual Heat Removal (RHR)
Standby Gas Treatment System (SGTS)
Control Center Heating, Ventilation, and Air Conditioning (CCHVAC)
Offsite Power
: 2. The following three systems will be excluded from elective maintenance and will remain 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.
* Standby Feedwater (SBFW)
* Hardened Containment Vent
* FLEX
: 3. Restricted access to all previously stated systems in accordance with MOP05-100 and ODE-20.
: 4. Signage defining systems under protection both within and when entering protected area.
All offsite power sources are currently operable and offsite power is being supplied to both the 120 kV and 345 kV switchyards from the transmission network by five transmission lines.
Throughout the requested completion time, access to the switchyards will be controlled by the Main Control Room and will be restricted to only essential work, with no elective maintenance being performed. Shift Manager approval will be required to access the switchyards.
During the morning shift Midcontinent Independent System Operator (MISO) communications, Operations will verify no work affecting the 120kV or 345kV switchyards occurs. Weather conditions will be verified to be acceptable prior to authorizing work. Actions will be taken in accordance with Fermi procedure MOP01-200, Severe Weather Guidelines, in response to advanced notification of possible severe weather conditions.

==4.0     REGULATORY ANALYSIS==

4.1    Applicable Regulatory Requirements/Criteria 4.1.1 10 CFR 50.36 10 CFR 50.36, Technical Specifications, defines the content required in licensee TS.
Specifically, 10 CFR 50.36(c)(2)(i) requires that the TS include Limiting Conditions for Operation (LCO) that are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The EECW, EESW and UHS Systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). The proposed changes will allow a one-time change to TS 3.8.1 Required Action B.4 to extend the Completion Time. Based to NRC-23-0068 Page 10 on this evaluation, the proposed extended Completion Time continues to support compliance to 10 CFR 50.36(c)(2).
4.1.2 10 CFR 50.91 10 CFR 50.91(a)(6) provides the requirements to be met to allow the NRC to perform expedited approval of a license amendment under exigent circumstances. As discussed in Section 3, Fermi is requesting exigent processing of this license amendment request, as a delay in approval of the proposed change could result in a potential unnecessary plant shutdown or need for enforcement discretion without a corresponding health and safety benefit. Accordingly, this license amendment request satisfies the criteria for the Commission to issue a license amendment under the exigent provisions of 10 CFR 50.91(a)(6).
4.1.3 General Design Criteria Criterion 44 A system to transfer heat from structures, systems, and components important to safety to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions.
Suitable redundance in components and features, and suitable interconnection, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished assuming a single failure.
The proposed change to add an allowance for a longer Completion Time for TS 3.8.1 Action B.4 has no impact on the permanent physical configuration, design, or function the EECW, EESW and UHS Systems. Even with the MDCT fans A and C isolated for the extended period, the remaining cooling water systems are still supported by functional equipment. Therefore, conformance to Criterion 44 is unaffected by the proposed changes.
The proposed change does not affect compliance with these regulations or guidance and will ensure that the lowest functional capabilities or performance levels of equipment required for safe operation are met.
4.2     Precedent On September 18, 2023, License Amendment 225 was approved (Reference 6.6) under exigent circumstances to extend of the Completion Time to Technical Specification 3.7.2 to support the same repair activity on the Division I MDCT A and C fans. That original amendment did not contain all required Technical Specification Completion Time extensions needed to perform this to NRC-23-0068 Page 11 work online. This request is to implement an additional one-time amendment to Technical Specification 3.8.1 to support the same planned online maintenance.
This request is similar in nature to the following license amendments to extend Completion Times for Exigent Circumstances, as previously authorized by the NRC. These amendments also involve Completion Time extensions for cooling water systems required for plant shutdown.
This proposed change does not alter the plant design, nor does it affect the information contained in the UFSAR.
Comanche Peak Nuclear Plant, Unit Nos. 1 and 2 - license amendment to extend the completion times for one station service water train inoperable and for one diesel generator inoperable from 72 hours to 8 days. (Reference 6.2)
Prairie Island Nuclear Generating Plant, Units 1 and 2 - license amendment to extend completion time for inoperable cooling water system supply header from 4 hours to 36 hours. (Reference 6.3)
Vogtle Electric Generating Plant, Unit 3, License Amendment to provide Technical Specification Exceptions for In-Containment Refueling Water Storage Tank Operability Prior to Initial Criticality. (Reference 6.4)
Fermi 2, License Amendment regarding Revision Of Technical Specifications 3.7.2, Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System And Ultimate Heat Sink (UHS). (Reference 6.6)
This Exigent License Amendment Request is also similar to a recent Notice of Enforcement Discretion (NOED) approved by the NRC for DTE TS 3.7.2 and 3.8.1 to allow for repair of MDCT D.
Notice of Enforcement Discretion (NOED) For Fermi Power Plant, Unit Two -
Technical Specification 3.7.2, Emergency Equipment Cooling Water (EECW) /
Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS) 4.3     No Significant Hazards Consideration DTE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment for extending the Completion Time to repair of the Division I Mechanical Draft Cooling Tower (MDCT) A and C fan pedestals while online by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
DTE will use the compensatory measures and Fermi 2 Configuration Risk Management program requirements outlined Section 3.3 above and in previously approved amendment to NRC-23-0068 Page 12 225 (Reference 6.6) during the duration of the proposed extension of the Completion Time for the MDCT fan pedestal repair.
Note: A risk-informed justification for this change had been previously evaluated and approved under Reference 6.6.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes do not involve a change in design, configuration, or method of operation of the plant. The proposed changes will not alter the manner in which equipment is initiated, nor will the functional demands on credited equipment be changed. The proposed changes do not impact the interaction of any systems whose failure or malfunction can initiate an accident. There are no identified redundant components affected by these changes and thus, there are no new common cause failures or any existing common cause failures that are affected by extending the Completion Time. The proposed changes do not create any new failure modes.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed changes do not alter the plant design, nor do they affect the assumptions contained in the safety analyses. Specifically, there are no changes being made to the MDCT fan design. The proposed changes have been evaluated and margins of safety ascribed to Emergency Equipment Cooling Water (EECW) availability and to plant risk have been determined to be not significantly reduced. The risk impact of the proposed changes is acceptable to the compensatory measures and other requirements, as outlined in outlined Section 3.3 above and in in previously approved amendment in Reference 6.6. As analyzed in the UFSAR, the loss of the Division I MDCT fans would not cause a significant reduction in safety because the MDCT system is redundant and can perform its function with one division unavailable.
The evaluation provided above shows that the proposed changes will not significantly increase the probability or the consequences of any accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a

Enclosure 1 to NRC-23-0068 Page 13 significant reduction in the margin of safety. Therefore, the proposed changes meet the criteria of 10 CFR 50.92(c) and no significant hazard consideration is involved.
4.4     Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==5.0     ENVIRONMENTAL CONSIDERATION==

The proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

==6.0     REFERENCES==

6.1     U.S. Nuclear Regulatory Commission, Regulatory Guide 1.177, Revision 2, An Approach for Plant-Specific, Risk-Informed Decision making: Technical Specifications, January 2021 (ML20164A034) 6.2     U.S. Nuclear Regulatory Commission, Letter to Mr. Ken J. Peters, Comanche Peak Nuclear Power Plant, Unit Nos. 1 And 2 - Issuance of Amendment Nos. 178 And 178 Regarding One-time Revision to Technical Specifications 3.7.8, Station Service Water System (SSWS), And 3.8.1, AC Sources - Operating, February 12, 2021.
(ML20324A627) 6.3     U.S. Nuclear Regulatory Commission, Letter to Mr. Christopher P. Domingos, Prairie Island Nuclear Generating Plant, Units 1 and 2 - Issuance of Amendment NOS. 237 and 225 Re: Inoperable Cooling Water Supply System Supply Header, November 23, 2021.
(ML21281A017) 6.4     U.S. Nuclear Regulatory Commission, Letter to Mr. Brian H. Whitley, Vogtle Electric Generating Plant, Unit 3  Issuance of Amendment: Technical Specification Exceptions for Incontainment Refueling Water Storage Tank Operability Prior to Initial Criticality (Exigent Circumstances) February 8, 2023 (ML23031A359) to NRC-23-0068 Page 14 6.5    U.S. Nuclear Regulatory Commission, Letter to Mr. Peter Dietrich, Notice of Enforcement Discretion (NOED) For Fermi Power Plant, Unit Two - Technical Specification 3.7.2, Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS),
July 26, 2023 (ML23206A127) 6.6    U.S. Nuclear Regulatory Commission, Letter to Mr. Peter Dietrich, Fermi Power Plant, Unit Two, Issuance of Amendment No. 225- Regarding Revision of Technical Specification 3.7.2, Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), (Exigent Circumstances) September 18, 2023 (ML23243A885)

Enclosure 2 to NRC-23-0068 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Marked-up Pages of Existing Fermi 2 TS

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 hours*
inoperable.                       OPERABLE status.
B. One EECW/EESW              B.1      Restore the EECW/EESW    72 hours 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 prepesed 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. -lM, ~ . m

AC Sources-Operating 3.8.1 ACTIONS CONDITION                    REQUIRED ACTION            COMPLETION TIME B.  (continued)               B.2      Declare required          4 hours from feature(s), supported     discovery of by the inoperable         the inoperable EDGs , inoperable when    EDGs concurrent the redundant             with required feature(s)       inoperability are inoperable .          of redundant required
                                 -AND                                feature(s)
B.3.1    Determine OPERABLE        24 hours EDG(s) are not inoperable due to common cause failure.
                                     -OR B.3.2    Perform SR 3.8.1.2        24 hours for OPERABLE EDG(s).
                                 -AND B.4      Restore one EDG in        72 hours the division to OPERABLE status.
C. One or both EDGs in    C.1      Restore both EDGs in      2 hours both divisions                  one division to inoperable.                     OPERABLE status.
D. One offsite circuit    D.1      Perform SR 3.8.1 .1       1 hour inoperable.                     for OPERABLE offsite circuit.                 -AND Once per 8 hours thereafter
                                 -AND (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 completion time extension and associated compensatory measures are documented in LAR NRC-23-0068. This completion time extension will expire at 2359 on November 19, 2023.
FERMI - UNIT 2                        3.8-2a         Amendment No. l+G, 1-79, 222

Enclosure 3 to NRC-23-0068 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Clean Pages of Fermi 2 TS with Changes Incorporated

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 hours*
inoperable.                       OPERABLE status.
B. One EECW/EESW             B.1      Restore the EECW/EESW   72 hours 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 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, 225

AC Sources  Operating 3.8.1 ACTIONS CONDITION                  REQUIRED ACTION           COMPLETION TIME B.  (continued)             B.2      Declare required        4 hours from feature(s), supported   discovery of by the inoperable       the inoperable EDGs, inoperable when   EDGs concurrent the redundant           with required feature(s)     inoperability are inoperable.         of redundant required AND                              feature(s)
B.3.1    Determine OPERABLE      24 hours EDG(s) are not inoperable due to common cause failure.
OR B.3.2    Perform SR 3.8.1.2      24 hours for OPERABLE EDG(s).
AND B.4      Restore one EDG in      72 hours*
the division to OPERABLE status.
C. One or both EDGs in   C.1      Restore both EDGs in    2 hours both divisions                 one division to inoperable.                    OPERABLE status.
D. One offsite circuit   D.1      Perform SR 3.8.1.1      1 hour inoperable.                    for OPERABLE offsite circuit.                AND Once per 8 hours thereafter AND (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 completion time extension and associated compensatory measures are documented in LAR NRC-23-0068. This completion time extension will expire at 2359 on November 19, 2023.
FERMI - UNIT 2                       3.8-2a         Amendment No. 170, 175, 222}}