ML16069A006

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Issuance of Amendment Technical Specifications to Adopt Technical Specifications Task Force - 523, Generic Letter 2008-01, Managing Gas Accumulation
ML16069A006
Person / Time
Site: Fermi 
Issue date: 04/20/2016
From: Sujata Goetz, Jennivine Rankin
Plant Licensing Branch III
To: Fessler P
DTE Electric Company
Rankin J
References
CAC MF6756
Download: ML16069A006 (24)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 20, 2016 Mr. Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, Ml 48166

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE {TSTF) - 523, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (CAC NO.

MF6756)

Dear Mr. Fessler:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 204 to Facility Operating License No. NPF-43 for the Fermi 2 facility. The amendment consists of changes to the technical specifications (TSs) in response to your application dated September 24, 2015 {Agencywide Documents Access and Management System (ADAMS) Accession No. ML15268A149).

The amendment revises TS to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," {ADAMS Accession No. ML072910759) as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" (ADAMS Accession No. ML13053A075).

P. Fessler A copy of the Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, k.~a.nager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 204 to License No. NPF-43
2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 204 License No. NPF-43

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the DTE Electric Company (DTE, the licensee) dated September 24, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-43 is hereby amended to read as follows:

Enclosure 1

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 204, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION ChJ 9- cl'---

David J. Wrona, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-43 and Technical Specifications Date of lssuance:Apr i 1 2 o , 2o1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 204 FACILITY OPERATING LICENSE NO. NPF-43 DOCKET NO. 50-341 Replace the following page of Facility Operating License NPF-43 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT Page 3 Page 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.4-20 3.4-20 3.4-22 3.4-22 3.5-4 3.5-4 3.5-5 3.5-5 3.5-10 3.5-10 3.5-11 3.5-11 3.5-13 3.5-13 3.6-34 3.6-34 3.6-36 3.6-36 3.9-11 3.9-11 3.9-14 3.9-14

(4) DTE Electric Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material such as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) DTE Electric Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) DTE Electric Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level DTE Electric Company is authorized to operate the facility at reactor core power levels not in excess of 3486 megawatts thermal ( 100% power) in accordance with conditions specified herein and in Attachment 1 to this license. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 is hereby incorporated into this license.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 204, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions DTE Electric Company shall abide by the agreements and interpretations between it and the Department of Justice relating to Article I, Paragraph 3 of the Electric Power Pool Agreement between DTE Electric Company and Amendment No. 204

RHR Shutdown Cooling System-Hot Shutdown 3.4.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 * * * * * * * * * * * * * * * * * * *NOTE * * * * * * * * * * * * * * * * * * *

  • Not required to be met until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.4.8.2 * * * * * * * * * * * * * * * * * * *NOTE * * * * * * * * * * * * * * * * * * *

  • Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation with the are sufficiently filled with water. Surveillance Frequency Control Program FERMI

  • UNIT 2 3.4-20 Amendment No. -l-34, ~. 204

RHR Shutdown Cooling System-Cold Shutdown 3.4.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Initiate action to Immediately cooling subsystem in restore one RHR operation. shutdown cooling subsystem or one AND recirculation pump to operation.

No recirculation pump in operation. AND B.2 Verify reactor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from coolant circulating discovery of no by an alternate reactor coolant method. circulation AND B.3 Monitor reactor Once per hour coolant temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9 .1 Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.4.9.2 Verify RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation with the are sufficiently filled with water. Surveillance Frequency Control Program FERMI - UNIT 2 3.4-22 Amendment No. -+/-J4, 2{)..l., 204

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 5.1.1 Verify correct voltage and breaker In accordance alignment to the LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.1.2 - -- --- -- - - --* * * * -* *NOTE* * * * * -* * * * * * * * -* * * * -

When LPCI is placed in an inoperable status solely for performance of this SR, or when the LPCI swing bus automatic throwover scheme is inoperable due to EDG-12 being paralleled to the bus for required testing, entry into associated Conditions and Required Actions may be delayed up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for completion of the required testing.

Perform a functional test of the LPCI swing In accordance bus automatic throwover scheme. with the Surveillance Frequency Control Program SR 3.5.1.3 Verify, for each ECCS injection/spray In accordance subsystem, locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program (continued)

FERMI - UNIT 2 3.5-4 Amendment No. +/-J4, ~. 204

ECCS-Operati ng 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 5.1.4 -- --- -- - - -- -- -- ----NOTE -- ----- -- - -- --- ---- -

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.5.1. 5 Verify primary containment pneumatic supply In accordance pressure is ~ 75 psig. with the Surveillance Frequency Control Program SR 3.5.1.6 Verify the RHR System power operated cross In accordance tie valve is open. with the Surveillance Frequency Control Program SR 3.5.1. 7 Verify each recirculation pump discharge In accordance valve cycles through one complete cycle of with the full travel or is de-energized in the Surveillance closed position. Frequency Control Program (continued)

FERMI - UNIT 2 3.5-5 Amendment No. -lJ4, 2-Q.+/-, ~. 204

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required core spray (CS) In accordance subsystem, the: with the Surveillance

a. Suppression pool water level is Frequency

~ -66 inches: or Control Program

b. -* * - --* * --* * * -* * -NOTE * * -* * -* -* * * * -* -* -

Only one required CS subsystem may take credit for this option during OPDRVs.

Condensate storage tank water level is

~ 19 ft.

SR 3.5.2.3 Verify correct voltage and breaker In accordance alignment to the LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.2.4 Verify, for each required ECCS In accordance injection/spray subsystem, locations with the susceptible to gas accumulation are Surveillance sufficiently filled with water. Frequency Control Program (continued)

FERMI - UNIT 2 3.5-10 Amendment No. +/-J4. ~. 204

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 - --- --- -- -- -- -- --- -NOTES -- - --- --- - - ---- --*

1. LPCI subsystem(s) may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.
2. Not required to be met for system vent flow paths opened under administrative control.

Verify each required ECCS injection/spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path, that is Surveillance not locked, sealed, or otherwise secured in Frequency position. is in the correct position. Control Program SR 3.5.2.6 Verify each required ECCS pump develops the In accordance specified flow rate against a system head with the corresponding to the specified reactor Inservice pressure. Testing SYSTEM HEAD Program NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF cs ~ 5725 gpm 2 ~ 100 psig LPCI ~ 10,000 gpm 1 ~ 20 psig SR 3.5.2.7 -- - -- --- -----* -* -*

  • NOTE * -- -* -* * - -* -* -* * -* -*

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray In accordance subsystem actuates on an actual or with the simulated automatic initiation signal. Surveillance Frequency Control Program FERMI

  • UNIT 2 3.5-11 Amendment No. +/-J4 Jg4, 1, 204

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations In accordance susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program SR 3.5.3.2 -- --- -- -- - -- ---- ---NOTE - -- --- -- - -- -- -- ---- -

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual. power In accordance operated. and automatic valve in the flow with the path. that is not locked. sealed. or Surveillance otherwise secured in position. is in the Frequency correct position. Control Program SR 3.5.3.3 - -- --- -- - - -- -- -- -- -NOTE - -- -- --- - -- -- - -- -- --

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify. with reactor pressure ~ 1045 psig In accordance and ~ 945 psig, the RCIC pump can develop a with the flow rate ~ 600 gpm against a system head Surveillance corresponding to reactor pressure. Frequency Control Program SR 3.5.3.4 -- -- -- - -- - -- -- -- ---NOTE - -- -- --- - -- -- -- - -- --

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure ~ 200 psig, In accordance the RCIC pump can develop a flow rate with the

~ 600 gpm against a system head Surveillance corresponding to reactor pressure. Frequency Control Program (continued)

FERMI - UNIT 2 3.5-13 Amendment No. +/-J4. aG-l-. 204

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control Program can be aligned to the correct position.

SR 3.6.2.3.2 Verify each required RHR pump develops a In accordance flow rate ~ 9,250 gpm through the with the associated heat exchanger while operating Inservice in the suppression pool cooling mode. Testing Program SR 3.6.2.3.3 Verify RHR suppression pool cooling In accordance subsystem locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program FERMI

  • UNIT 2 3.6-34 Amendment No. -lJ4 l-9+/-, aQ.+/-, 204

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray In accordance subsystem manual. power operated. and with the automatic valve in the flow path that is Surveillance not locked. sealed. or otherwise secured Frequency in position is in the correct position or Control Program can be aligned to the correct position.

SR 3.6.2.4.2 Verify each RHR pump develops a flow rate In accordance

~ 500 gpm through the heat exchanger and with the suppression pool spray sparger while Inservice operating in the suppression pool spray Testing Program mode.

SR 3.6.2.4.3 Verify RHR suppression pool spray In accordance subsystem locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program FERMI - UNIT 2 3.6-36 Amendment No. -134, 2Q.l-, 204

RHR-High Water Level 3.9.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Suspend loading Immediately associated Completion irradiated fuel Time of Condition A assemblies into the not met. RPV.

AND B.2 Initiate action to Immediately restore secondary containment to OPERABLE status.

AND B.3 Initiate action to Immediately restore one standby gas treatment subsystem to OPERABLE status.

AND B.4 Initiate action to Immediately restore isolation capability in each required secondary containment penetration flow path not isolated.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify the RHR shutdown cooling subsystem In accordance is capable of decay heat removal. with the Surveillance Frequency Control Program SR 3.9.7.2 Verify required RHR shutdown cooling In accordance subsystem locations susceptible to gas with the accumulation are sufficiently filled with Surveillance water. Frequency Control Program FERMI - UNIT 2 3.9-11 Amendment No. 34, ~. 204

RHR-Low Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.9.8.2 Verify each RHR shutdown cooling subsystem In accordance is capable of decay heat removal. with the Surveillance Frequency Control Program SR 3.9.8.3 Verify RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation with the are sufficiently filled with water. Surveillance Frequency Control Program FERMI - UNIT 2 3.9-14 Amendment No. ~. ~. 204

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 204 TO FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By letter dated September 24, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15268A149), DTE Electric Company (the licensee) requested changes to the technical specifications (TSs) for Fermi 2. Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force {TSTF) Standard Technical Specifications {STS)

Change Traveler TSTF-523, Revision 2, "Generic Letter (GL) 2008-01, Managing Gas Accumulation" (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML13053A075), dated February 21, 2013. The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700), as part of the consolidated line item improvement process (CLllP).

The proposed change would revise surveillance requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS) and Reactor Core Isolation Cooling (RCIC) system. The proposed change would also add new SRs related to gas accumulation for the residual heat removal (RHR), suppression pool spray and shutdown cooling systems. TS Bases changes associated with these SRs would also be made.

The licensee stated that it has reviewed the information contained in the model safety evaluation dated December 23, 2013 (ADAMS Accession No. ML13255A169), and that the license amendment request (LAR) is consistent with NRG-approved TSTF-523.

The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed significant hazards consideration determination was published in the Federal Register on January 5, 2016 (81 FR 260).

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 Background Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in January 2008 to address the issue of gas accumulation in ECCS, OHR, and CS systems (ADAMS Accession No. ML072910759). The industry and NRC staff agreed that a change to the STS and plant-specific TS would be necessary to address some issues discussed in GL 2008-01.

TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the Fermi 2 TS using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 3.5.1.3, 3.5.1.4, 3.5.2.4, 3.5.2.5, 3.5.3.1, and 3.5.3.2, as well as the addition of new SRs 3.4.8.2, 3.4.9.2, 3.6.2.3.3, 3.6.2.4.3, 3.9.7.2, and 3.9.9.3 to TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," TS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.5.1, "ECCS - Operating," TS 3.5.2, "ECCS - Shutdown," TS 3.5.3, "RCIC System," TS 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling,"

TS 3.6.2.4, "Residual Heat Removal (RHR) Suppression Pool Spray," TS 3.9.7, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.8, "Residual Heat Removal (RHR) - Low Water Level," respectively.

2.3 Regulatory Review The regulations in Appendix A to Title 1O of the Code of Federal Regulations (10 CFR)

Part 50, "General Design Criteria for Nuclear Power Plants" provide design requirements. Appendix B to 10 CFR Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," the TSs, and the licensee quality assurance program provide operating requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39 and 40. GDC 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34 requires an RHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDCs 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements.

Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria. GDCs 38, 39, and 40 require a Containment Heat Removal System (CHRS) design that meets performance, inspection, and testing requirements.

Quality assurance criteria provided in 10 CFR Part 50, Appendix B, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII. Criteria Ill

and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management. Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36(c). The regulations at 10 CFR 50.36 require that the TSs include items in the following categories: ( 1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) SRs; (4) design features; and (5) administrative controls. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, Rev. 2, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33, Rev. 2 identifies instructions for filling and venting the ECCS and DHR system, as well as for draining and refilling heat exchangers.

Standard TSs and most licensee TSs include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4."

The NRC staff recognizes that the Standard Review Plan (SRP) is not the regulatory basis of the proposed TSs changes, and licensees are not required to confirm that the SRP guidance is applicable to Fermi 2.

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems is provided in the following revisions and sections of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition" (SRP) during the review.

  • Revision 5 of the SRP, Section 6.2.2, "Containment Heat Removal Systems,"

dated March 2007 (ADAMS Accession No. ML070160661 ), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDC 38, 39, and 40.

dated May 2010 (ADAMS Accession Number ML100680577), provides the procedures concerning the review of RHR system as it is used to cool the reactor coolant system (RCS) during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4" by TSTF-523.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36(c). The licensee proposed the following TS changes:

(1) Add SR 3.4.8.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" together with a note that states "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is less than the RHR cut in permissive pressure" and a frequency of "In accordance with the Surveillance Frequency Control Program."

(2) Add SR 3.4.9.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of "In accordance with the Surveillance Frequency Control Program."

(3) Revise the language for SR 3.5.1.3 from "Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve" to "Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water."

(4) Add a note to SR 3.5.1.4, which states, "Not required to be met for system vent flow paths opened under administrative control."

(5) Revise the language for SR 3.5.2.4 from "Verify, for each required ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve" to "Verify, for each required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water."

(6) Add a note to SR 3.5.2.5, which states, "Not required to be met for system vent flow paths opened under administrative control."

(7) Revise the language for SR 3.5.3.1 from "Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve" to "Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled

with water."

(8) Add a note to SR 3.5.3.2, which states, "Not required to be met for system vent flow paths opened under administrative control."

(9) Add SR 3.6.2.3.3, which states, "Verify RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of "In accordance with the Surveillance Frequency Control Program."

(10) Add SR 3.6.2.4.3, which states, "Verify RHR suppression pool spray subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of "In accordance with the Surveillance Frequency Control Program."

(11) Add SR 3.9.7.2, which states, "Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of "In accordance with the Surveillance Frequency Control Program."

(12) Add SR 3.9.8.3, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of "In accordance with the Surveillance Frequency Control Program."

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state "full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TS, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 10 CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "Verify the [system name] locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 3 with reactor steam dome pressure less than the RHR cut in permissive pressure is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules (STS Section 1.4), the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared not met.

The language for the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR Therefore, these notes are acceptable.

The NRC staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCO will be met. Therefore, the NRC staff finds the proposed amendment acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (81 FR 260), January 5, 2016.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributor: Matthew E. Hamm, NRR/DSS/STSB Date: April 20, 2016

ML16069A006 *via memo OFFICE DORL/LPL3-1 /PM DORL/LPL3-1 /LA DSS/STSB/BC* OGC NAME SGoetz MHenderson RElliot MRing DATE 3/17/2016 3/17/2016 2/24/2016 3/29/2016 OFFICE DORL/LPL3-1 /BC DORL/LPL3-1/PM DORL/LPL3-1 /PM NAME DWrona JRankin SGoetz DATE 4/14/2016 4/20/2016 4/20/2016

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